Loading...
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. 2 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. 3 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. 4