HomeMy WebLinkAboutAQ_F_0300076_20221031_CMPL_InspRpt NORTH CAROLINA DIVISION OF Winston-Salem Regional Office
AIR QUALITY Maymead Materials,Inc.-Laurel Springs Plant
NC Facility ID 0300076
Inspection Report County/FIPS:Alleghany/005
Date: 10/31/2022
Facility Data Permit Data
Maymead Materials,Inc.-Laurel Springs Plant Permit 09551 /R02
11995 NC HWY 18 Issued 4/28/2015
Laurel Springs,NC 28644 Expires 3/31/2023
Lat: 36d 24.9720m Long: 81d 15.4800m Class/Status Synthetic Minor
SIC: 2951 /Paving Mixtures And Blocks Permit Status Active
NAILS: 324121 /Asphalt Paving Mixture and Block Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Wiley Roark Wiley Roark Wiley Roark NSPS: Subpart I
President President President
(423)727-2000 (423)727-2000 (423)727-2000
Compliance Data
Comments:
Inspection Date 10/26/2022
Inspector's Name Ryan Dyson
Inspector's Signature: 2D1, L DMM Operating Status Operating
vim/ Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: 10/31/2022 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2014 --- --- ---
2009 --- --- ---
* ---
Highest HAP Emitted inpounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
1
Permitted Emission Sources
Emission Emission Source Control Control System
Source ID Description S ystem ID Description
1
One drum-mix asphalt plant(150 tons per hour maximum rated capacity),consisting of:
ES-2 Hot mix asphalt storage silo I N/A F N/A
ES-1 FNo.2/recycled No.4 fuel oil-fired aggregate dryer(96.8 CD-1 Bagfilter
(NSPS) million Btu per hour maximum heat input capacity) (7,163 square feet of filter area)
ES-3 I Truck loadout operation N/A N/A
Insignificant/Exempt Activities
Source of Source of Title V
Source Exemption Regulation TAPS? Pollutants?
IES-1 -Fuel oil storage tank(10,000-gallon capacity) 2Q.0102(c)(1)(D)(i) F
IES-2-Fuel oil storage tank(3,000-gallon capacity)
IES-3 -Liquid asphalt cement storage tank(20,000-gallon capacity) 2Q.0102(c)(1)(L)(xii) Yes Yes
IES-4-No.2 fuel oil-fired asphalt storage tank heater(LO million F
.0102(c)(2)(13)(i)(1)
Btu per hour maximum heat input capacity)
Introduction
On October 26,2022,Mr.Ryan Dyson,Environmental Specialist for the Winston-Salem Regional Office of the North Carolina
Division of Air Quality(WSRO-DAQ),conducted a Full Compliance Evaluation(FCE)of Maymead Materials,Inc.-Laurel Springs
Plant. This facility was most recently inspected by Mr.Dyson on November 3,2021 and appeared to be in compliance with all
applicable Air Quality standards and regulations at that time as the facility had not been constructed.This facility is a greenfield site
for a proposed 150 ton per hour maximum rated capacity drum-mix asphalt plant,and it has had a permit since December 22,2005.
Prior discussions with Mr.Mackey indicate that the company is in the process of ordering the necessary equipment to eventually be
constructed and operated on-site.During Mr.Dyson's last inspection of the facility,Mr.Mackey indicated that this process would
likely not occur until the end of calendar year 2022 at the absolute earliest.However,there may be significant delays in acquiring
equipment as it relates to supply chain issues after the COVID-19 pandemic.Mr.Mackey had also stated that the asphalt plant they are
planning on eventually constructing at this site will differ slightly from the specifications in the facility's current permit,in that it will
have a lower rated capacity than what they are currently permitted for.Therefore,Mr.Mackey stated that he will apply for a permit
modification prior to ever constructing the new asphalt plant or placing it in operation.Mr.Mackey also previously indicated that he is
aware of all requirements pertaining to notifications of start-up.Mr.Dyson elected to go ahead and conduct an inspection of this
facility,as it is scheduled for an upcoming permit renewal.While performing other field work in the area on October 26,2022,Mr.
Dyson drove to the property in question and confirmed that there were not yet any signs of construction of an asphalt plant at this
property,save for the demolition of the abandoned school building that used to sit on the property.
Safety Equipment
Proper Personal Protective Equipment for this facility,once operations commence,includes safety shoes, safety glasses,hearing
protection,a hard hat,and a reflective safety vest.
Applicable Regulations
Permit Condition A.1 states that the facility is subject to the following regulations:Title 15A North Carolina Administrative Code
(NCAC), Subchapter 2D.0202,2D .0506,2D .0516,2D .0521,2D.0524(40 CFR 60, Subpart I),2D.0535,2D.0540,2D .0611,2D
.1100,2D.1806,2Q.0304,2Q .0309,2Q.0315,2Q .0317(Avoidance)and 2Q.0711.This facility is not subject to the Risk
Management Plan(RMP)requirements of the Section 112(r)Program,as it does not purchase,produce,utilize,or store any of the
regulated substances in quantities above their associated threshold limits.The facility is still subject to the General Duty clause in this
rule.
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Discussion
The facility is currently permitted for a 96.8 million Btu per hour maximum heat input capacity No.2/recycled No.4 fuel oil-fired
aggregate dryer(ES-1)and associated bagfilter(CD-1),a hot mix asphalt storage silo(ES-2)and a truck loadout operation(ES-3).
The facility's current permit also lists multiple insignificant/exempt sources,including a 10,000-gallon fuel oil storage tank(IES-1),a
3,000-gallon fuel oil storage tank(IES-2),a 20,000-gallon liquid asphalt cement storage tank(IES-3)and a 1.0 million Btu per hour
maximum heat input capacity No.2 fuel oil-fired asphalt storage tank heater(IES-4).As indicated above,none of these sources were
constructed on-site at the time of this inspection,and Mr.Mackey indicated that the asphalt plant that the company is planning on
constructing in the future will be of a lower rated capacity.Mr.Mackey stated that he will apply for a permit modification prior to
constructing or operating the future asphalt plant.
Upon startup,the facility will be required to submit quarterly and annual reports.The quarterly reports,as required by 15A NCAC 2D
.1100"Control of Toxic Air Pollutants"and 15A NCAC 2Q .0315 "Synthetic Minor Facilities,"must convey the amount of asphalt
produced,fuel certification records and sulfur dioxide emissions associated with the facility. The annual report,as required to avoid
the applicability of Rule 2Q .0700,must convey a summary of the results of analytical testing on the recycled fuel oil used by the
facility and the amount of recycled fuel used over the prior 12 months.Although the facility is not yet constructed,the facility is
already submitting these reports in conjunction with those required for the other Maymead facilities in this region.The most recent
quarterly report,for instance,was received on October 13,2022.This report stated that,"There is no functioning facility at this
location."
NSPS/NESHAP
The facility will become subject to 40 CFR Part 60, Subpart I,once it is constructed. In accordance with 15A NCAC 2D .0524 "New
Source Performance Standards"(NSPS)as promulgated in 40 CFR 60,Subpart I,including Subpart A"General Provisions",as
referenced by Condition A.7 of the facility's current permit,the facility will be required to submit a report conveying the actual date of
initial start-up of the No.2/recycled No.4 fuel oil-fired aggregate dryer,postmarked within 15 days after such date.If the asphalt plant
is not a mass-produced source purchased in completed form,then a report conveying the date of construction or reconstruction of an
affected source must be postmarked no later than 30 days after such date.Additionally,within 60 days after achieving the maximum
production rate at which the aggregate dryer will be operated,but not later than 180 days after the initial start-up of the aggregate
dryer,for each fuel permitted,the facility must conduct the required Method 5 and Method 9 testing and submit two copies of a
written report of the tests.Mr.Mackey previously indicated that he is aware of these requirements,and future compliance is
anticipated.
Facility-Wide Emissions
The following table,borrowed from the permit review for Air Quality Permit No. 09551 R02 (written by Ms. Caroline Sun and dated
April 28,2015),projects the facility's actual and potential emissions.
Projected Actual Emissions Potential Emissions with Potential Emissions without
Pollutants Pollutant Controls and Limits Controls or Limits
(ton/year) (ton/year) (ton/year)
PM 3.17 45.48
PMI0 2.27 20.87
SO2 23.62 868.44
NOx 5.58 36.76
CO 12.08 87.23
VOC 4.34 31.61
HAP Total 0.92 6.75
Highest HAP
0.29 2.09
(Formaldehyde)
Permit Issues/Considerations
Mr.Mackey indicated that the asphalt plant that will eventually be constructed at this location will be of a lower capacity than as
currently permitted.Mr.Mackey stated that he will apply for a permit modification prior to constructing the asphalt plant.
The reporting requirements pertaining to recycled fuel oil,currently listed under Condition A.18.d of Air Permit No.09551R02,may
be able to be removed during the next permit opening.
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Stack Testing
No stack testing has ever been performed at this facility,according to the IBEAM database.
5 Year Compliance History
This facility has not been issued a NOD,NOV,or NOV/RE in the past 5 years.
Conclusion
Based on the fact that there is currently no functioning facility at the site,Maymead Materials,Inc.-Laurel Springs Plant appeared to
be in compliance with all applicable Air Quality standards and regulations at the time of this inspection.
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