AQ_F_1700005_20220607_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Winston-Salem Regional Office
AIR QUALITY Piedmont Asphalt,LLC-Pelham Plant
NC Facility ID 1700005
Inspection Report County/FIPS: Caswell/033
Date: 06/08/2022
Facility Data Permit Data
Piedmont Asphalt,LLC-Pelham Plant Permit 01902/R21
1675 Rock Quarry Road Issued 5/4/2021
Pelham,NC 27311 Expires 5/31/2023
Lat: 36d 32.4000m Long: 79d 27.6500m Class/Status Synthetic Minor
SIC: 2951 /Paving Mixtures And Blocks Permit Status Active
NAICS: 324121 /Asphalt Paving Mixture and Block Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Julian Stinson Douglas Dawson Julian Stinson NSPS: Subpart I
HR/Safety Representative General Manager HR/Safety Representative
[phone] [phone] [phone]
Compliance Data
Comments: None.
Inspection Date 06/07/2022
Inspector's Name Blair Palmer
Inspector's Signature: DMM Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: 6/9/2022 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2014 2.05 0.0074 1.81 2.88 8.09 1.45 378.81
2009 1.25 6.28 3.47 1.61 4.91 0.9800 299.10
* 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
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Permitted Sources:
.............................................................................__..............._...._................._..............
........._......_.....................__...............
Emission Emission Source Control Control System
Source ID Description System ID Description
350 tons per hour Hot Mix Asphalt Drum Mix Plant(NSPS)capable of processing
recycled asphalt pavement and recycled asphalt shingles,consisting of:
Natural Gas/No. 2 Fuel Oil/Used No. 2 Fuel Oil/ Bagfilter
ES1 No. 4 Fuel Oil/Used No. 4 Fuel Oil-fired CD1 (10,842 square feet
(NSPS) (116 million Btu per hour maximum heat input)
Double Barrel Drum Mixer of filter area)
ES2.1• Three(3)Hot Mix Asphalt Storage Silos
ES2.2 (200 tons maximum design capacity, each) N/A N/A
ES2.4
..................................................................................................................................._...........................................................................__..................................................................................................._....................._..............._..__ .:._................................._.:.............................._......._...............__..._......................................_................
..........
ES2.3 ( Cold Asphalt Storage Silo(40 ton capacity) I N/A N/A i I
ES3 Truck Loadout Operation
ES2.5 RAP/RAS Handling System N/A N/A
Insignificant/Exempt Activities:
Exemtion Source of
Source p !Source of Title V Pollutants?
Regulation TAPs?
I-1 -Natural Gas/No. 2 Fuel Oil-fired
Hot Oil Heater 2Q .0102 (h)(1)(A) Yes Yes
(1.6 million Btu per hour maximum heat in
................................................................................................................_......................._....._................................................................................................................................................................._.............--__...._...................................
I-2 -Fuel Oil Storage Tank
(1,000 gallons capacity)
.............. ...: .I......:
1-3 Recycled Fuel Oil Storage Tank
(25,000 gallons capacity)
.
I-ES6 -
Liquid
..Asphalt
...Storage Tank.................................
(30,000 gallons capacity) 2Q .0102(g)(4) Yes Yes
............................
.................................._..........::..................................................................................................:................................
I-ES7 -Liquid Asphalt Storage Tank
(30,000 gallons capacity)
.................................:........................................._._..........................................................................................................................................................
.
I-ES8 -Liquid Asphalt Storage Tank
(1,000 gallons capacity)
I-ES9- Electric furnaces 2Q .0102 (g)(3)(A) Yes Yes
used for QA/QC testing activities
Introduction/Discussion:
On June 7,2022,Mr. Blair Palmer, Environmental Specialist II of the DAQ WSRO,contacted Douglas Dawson,General
Manager,and Angela Hill,Plant Operator,both Piedmont Asphalt,LLC employees,for a compliance inspection. The
facility was last inspected by this inspector on May 7,2021, and appeared to be operating in compliance. This facility
operates a 350 ton/hr(max)batch hot mix asphalt plant producing asphalt for residential and commercial purposes. The
permitted facility is drum-mix asphalt plant and generally operates up to 8-12 hours/day, 5 days/week, and up to 40-45
weeks/year depending upon weather conditions.
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Typically,this plant does not operate in January and February based on records review. Production has increased since
2020. No new equipment has been added since the last inspection conducted on May 7,2021.
Applicable Regulations:
Applicable regulations listed in the current permit(01902R21)are: 2D .0202, 2D .0506, 2D .0516, 2D .0521,2D .0524
(40 CFR 60, Subpart I),2D .0535,2D .0540,2D .0611,2D .1806, 2Q .0315, and 2Q .0317(Avoidance Conditions). This
facility is not subject to the RMP requirements of Section 112(r)program since they do not use or store any of the
regulated pollutants in quantities greater than the thresholds listed in the rule. They are only subject to the General Duty
requirements contained in the General Duty Clause.
Site Safety:
A safety vest should always be worn. Safety shoes,glasses,and hardhat are required while on site. Inspectors should be
aware of the truck traffic from this facility.
Process:
Using a front-end bucket loader,the facility loads each of the individual aggregate components into their respective cold
feed bins. Once in the bins, a preset amount of stone, gravel, and sand are dropped onto a conveyor. The conveyor feeds
the aggregate into the 116 million BTU/hr rotary drum mixer/dryer asphalt plant,ES HMAP-1. This plant utilizes a
mixer/dryer(ES1). Once in the drum,the aggregate is heated and enters the mixing area in the outer region of the drum.
Earlier in the mixing area, asphalt cement is injected. Approximate mixing proportions are 95%aggregate and
approximately 5% asphalt cement. Reclaimed Asphalt Pavement(RAP), sorted from a sizing screen, is also conveyed
into the drum's mixing area. Emissions from this process are controlled with one large bagfilter(CD1). Pulsed air causes
the collected particulate to fall into the bag filter's collection hopper,which is returned to the druni's mixing area via a
screw auger. From the drum,the asphalt is discharged onto the drag conveyor,which feeds the asphalt into one of three
adjacent, electrically heated storage silos(ES2.1,ES2.2, and ES2.4). There is also a separate truck loadout(ES3) located
at the facility. The plant operates at 200 tons/hour and has a RAP mixture of 30%. The plant is now permitted to use
Reclaimed Asphalt Shingles(RAS)as part of ES 2.5,and the facility began using RAS in late 2021, and the plant
typically uses a 5%RAS in the mix.
There are several exempt activities onsite and listed in the permit. These insignificant sources include a natural gas/No.2
fuel oil fired hot oil heater(I-1), 1,000-gallon fuel oil storage tank(I-2), a 25,000-gallon recycled fuel oil storage tank(I-
3),two 30,000-gallon liquid asphalt storage tanks(I-ES6,I-ES7)and a 1,000-gallon liquid asphalt storage tank(I-ES8).
These exempt items were observed during the inspection. I-3 is currently empty. I-2 contains off-road diesel fuel used
for the facility's front-end loader. The asphalt heater was observed combusting natural gas, and the facility no longer uses
any fuel oil, according to the last inspection report confirmed during this inspection.
Asphalt mixture is designed in the laboratory to ensure satisfactory aggregate gradation, optimum asphalt content, and
satisfactory mix volumetrics, including air voids and voids in mineral aggregate(VMA). The aggregate and asphalt binder
blending and mixing process in the lab are different than that at the asphalt plant, so it is essential to validate that the mix
produced during plant production is within the allowable tolerances of the designed mix. The facility has a small separate
building used for this asphalt mixture laboratory (I-ES-9) located towards the front of the property. Currently, two small
electric-fired furnaces are used for testing the physical properties of the asphalt mix types, including the aggregate. Both
furnaces have exhaust ductwork that vent outside via the back section of the building, each oriented horizontally through
the building. Neither was in operation, but both are subject to 2D .0521 (assuming 20% source).
The facility uses,at times, a portable mobile crusher and associated equipment(owned by Adams Construction of
Danville,VA)to crush Reclaimed Asphalt Pavement(RAP). Mr.Palmer inquired about this equipment as part of this
FCE. It appears that all necessary testing per NSPS Subpart 000, "Standards of Performance for Nonmetallic Mineral
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Processing Plants," using EPA Method 9 was conducted on April 23,2015, in Virginia based on information received via
email. Mr. Stinson,HR/Safety Representative for Piedmont Asphalt, stated previously to Mr. Palmer during a DAQ
inspection,that the crusher and associated equipment moved from other Piedmont Asphalt locations in NC and VA. RAP
was last crushed on site in May of 2022, but the crushing will continue sometime in June 2022 and possibly July 2022. A
total of 2,979 tons of RAP has been crushed in 2022 thus far. The crushing was performed by Adams Construction(a
joint venture with Piedmont Asphalt). The crushing capacity of the crusher is 400 tons per hour,according to Mr.
Stinson, and is over the 150 tons/hour exemption limit. Information for NSPS 000 for testing purposes is in the source
file and SharePoint.
Inspection(including permitted items and exempt sources):
The asphalt plant was in operation during the inspection and fired only on natural gas at the current time. The plant was
operating at 180 tons/hour, and Mr. Palmer witnessed one of the silos being(ES2.4)loaded with asphalt and the truck
loadout(ES3)running too. The bagfilter system had a recorded pressure drop of 4.5 inches of water column,but the
gauge is 0.5inches too high according to plant personnel. Mr.Palmer recommend that hey fix the gauge.
Permit Conditions:
Mr. Palmer went over the requirements with Mr. Dawson. Condition A.2 contains the permit renewal and emissions
inventory(EI)requirement of 15A NCAC 2D .0202. To fulfill this requirement,the facility must submit a permit renewal
request and an air pollution inventory report(with Certification Sheet)for the 2021 calendar year at least 90 days prior to
the expiration date of the permit. The current air permit expires on May 31,2023. A reminder letter from the WSRO will
mailed out approximately 6.5 months before the expiration. Future compliance is anticipated.
Condition A.3 contains the 15A NCAC 2D .0506 particulate control requirement. This rule limits particulate emissions
from hot mix asphalt plants based on the process throughput rate in tons per hour. Based on the throughput rate of this
plant of 300 tons/hr.,the maximum allowable PM emissions rate is 60 lbs/hr(based upon 300 tons/hr). This rule also
limits the stack at this plant to 20 percent opacity visible emissions when averaged over a six-minute period. It requires
that fugitive dust emissions be controlled as needed by 15A 2D .0540. For discussion on fugitive dust emissions, see
condition A.9 discussion below. The allowable emissions limit per 2D .0506 is 54.6 lb/hr(based on 271.4 lb/hr
production)based on an SSCB memo dated January 26, 2015. For PM emissions,AP-42 Table 11.1-3 emissions factors
dictate that a control efficiency of 99.286% is required for the bagfilter at this facility. According to permit review R20,
the control efficiency of the bagfilter system is expected to be 99.9%. Compliance is expected for the PM limit and
opacity requirement since the bagfilter is installed and appears well maintained. The facility had last tested on May 19,
2017, at 1.24lb/hr. Compliance is indicated.
Condition A.4 pertains to 2D .0516, "Sulfur Dioxide Emissions from Combustion Sources."This regulation limits the
emissions of SO2 from any source of combustion discharged from any vent, stack,or chimney to 2.3 pounds of S02 per
million Btu input. The drum mixer(ID No. ES1)and the exempt hot oil heater(I-1)are subject to this rule. Using AP-42
Table 11.1-7 (Hot Mix Asphalt Plants, revised 04/04),the following equations demonstrate compliance with this
regulation for the drum mixer:
S02,NG=(0.0034 lb SO2/ton asphalt)x(350 ton asphalt/hr)- 116 MMBTU/hr=0.010 lb SO2/MMBtu
S02,No,2 F.o. _(0.011 lb SO2/ton asphalt)x(350 ton asphalt/hr)- 116 MMBTU/hr=0.033 lb SO2/MMBtu
S02,No,4 F.o._(0.058 lb SO2/ton asphalt)x(350 ton asphalt/hr)_ 116 MMBTU/hr=0.18 lb SO2/MMBtu
Note: waste oil S02 emission factor is used for No. 4 fuel oil for the worst case scenario.
The SO2 emissions from the drum mixer firing NG,No.2 fuel oil or No.4 fuel oil are less than 2.3 lb SO2/MMBtu.
Using AP-42 Table 1.4-2(NG Combustion, revised 07/98)and Table 1.3-1 (Fuel Oil Combustion,revised 09/98),the
following equations demonstrate compliance with this regulation for the exempt hot oil heater:
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SO2 NG=(0.6 lb S02/MMft3 NG)x(ft3 NG/1,020 Btu)=0.0006 lb S02/MMBtu
S02 No.2F.o.=(142 x 0.5 lb S02/103 gal.F.O.)x(103 gal.F.O./140 MMBtu)=0.51 lb S02/MMBtu
Note: it is assumed that the NG heat value is 1020 Btu/ft3l and the No. 2 fuel oil heat value is 140 MMBtu/103 gal. The
default sulfur content for No. 2 fuel is 0.5%, therefore S= 0.5 is used in this calculation.
The S02 emissions from the hot oil heater firing NG or No.2 fuel oil are less than 2.3 lb S02/MMBtu.
Condition A.5 contains the requirements for 2D. 0521" Control of Visible Emissions." This facility is limited to 20%
opacity when averaged over a six-minute period for sources manufactured after July 1, 1971, and 40%opacity for sources
manufactured as of July 1, 1971, when averaged over a six-minute period. During the DAQ inspection,the inspector did
not observe any visible emissions other than some condensable water vapor from the dryer's exhaust. Compliance with
2D .0521 is indicated.
Condition A.6 contains the 2D .0524 requirements associated with "New Source Performance Standards." It pertains to 40
CFR 60, Subpart I, including Subpart A, "General Provisions." To comply with this rule,the facility must perform
Methods 5 and 202 source tests to ensure that the PM emission rate does not exceed the 90 mg/dscm limit. The facility
must also perform a Method 9 visible emissions observation to ensure that visible emissions do not exceed the 20%
opacity limit. Compliance with 2D .0524 was determined as a result of a May 19,2017, performance test. July 18, 2017,
DAQ Stationary Source Compliance Branch(SSCB)memo provides the following:
Pollutant Method Emissions Emissions Limit Regulation Compliance
Filterable PM 5 4.41 mg/dscm 90 mg/dscm 60 Subpart I Yes
0.5 lb/hr
Condensable PM 202 11.76 mg/dscm
1.36 lb/hr
Total PM 5/202 1.86 lb/hr 60 lb/hr 2D .0506 Yes
Visible Emissions 9 0% <20% 2D .0506 Yes
Condition A.7(213 .0535)addresses"Notification Requirement." The facility must notify the director of DAQ of a
malfunction or breakdown resulting in excess emissions lasting more than four hours. No notifications have been
received, and plant personnel indicated that there had been no plant upsets since the last DAQ inspection. Compliance is
indicated.
Condition A.8 pertains to the 15A NCAC 2D .0540 fugitive dust control requirement. According to the DAQ IBEAM
database, no complaints have been received regarding fugitive dust emissions at this facility. This rule was discussed with
plant personnel during the inspection. The facility utilizes the water truck from the adjacent Southside Materials,LLC-
Shelton Quarry(1700009),but this quarry operates intermittently. Mr. Palmer did not observe dust near the property
boundaries or adjoining vegetation. Compliance with this condition is likely indicated.
Condition A.9 per 2D .0611, "Fabric Filter Requirements," requires inspection and maintenance of the facility's bagfilter
(BH-1), including performing an internal inspection at least once every 12 months. The last inspection or care for the
bagfilter was on March 20,2022, and a section of ductwork was replaced. Bags were last checked on November 25,
2021, and no problems were noted. Extra bags are kept onsite and according to plant personnel,and 200 bags are
currently in inventory. The ductwork also appeared to be in good condition based on Mr.Palmer's inspection
observations. Compliance is indicated.
Condition A.10 contains the control and prohibition of odorous emissions requirement of 15A NCAC 2D .1806. To
comply with this condition,the permittee must operate the facility in such a manner as to prevent odorous emissions from
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causing or contributing to objectionable odors beyond the property boundary. No discernible odors were detected during
the approach to the facility,and no odor complaints attributed to this facility have been received since the date of the last
inspection. Compliance with this condition is indicated.
Condition A.I I (2Q .0315)deals with "Synthetic Minor Facilities." To maintain synthetic minor classification,the
facility-wide emissions of SO2 and CO shall be less than 100 tons per 12-month period. To ensure that emissions do not
exceed these limits,the amount of asphalt produced shall be less than 720,000 tons per 12-month period. The facility
shall also record the amount of asphalt produced monthly and annually. A review of the records showed that the facility
was recording monthly production information and was up to date on onsite records. Up through June 6,2022 a total of
1 62,048 tons were produced. The facility must also report each calendar year the monthly and total CO and SO2 emissions
and asphalt produced for the previous 12 months. The last required annual report(for CY 2021)was received on
February 4,2022(on time). The report showed a total of 143,861 tons of asphalt produced.
In comparison,the facility reported 110,837 tons of asphalt in CY 2020. The CY 2021 report also showed facility-wide
CO emissions of 9.4 tons and SO2 emissions of 0.01 tons. Only natural gas is used at the plant. Compliance is indicated.
Condition A.12 references the regulation 15A NCAC 2Q .0317 to avoid the applicability of 15A NCAC 2D .0530
"Prevention of Significant Deterioration." To comply,the facility must limit its emissions of SO2 to below 250 tons per
consecutive 12-month period. The facility has demonstrated that the SO2 emissions are well below 250 tons per 12-
month period.
i
Condition A.13 lists the "Recycled Asphalt Shingle Requirements." This permit condition was added during revision R21.
This condition contains the requirements for 2Q .0317 to avoid the applicability of 20 .0700 and 2D .1100 for asbestos
and NESHAP 40 CFR 61 Subpart M,National Emission Standard for Asbestos for using post-consumer reclaimed asphalt
roofing shingles(also known as PRAS). The PRAS is considered equivalent to unadulterated asphalt if the shingles are
tested by polarized light microscopy and contain less than 1%of asbestos-containing material. Certification must be
provided by an asbestos inspector or roofing supervisor accredited by the Division of Public Health's Health Hazards
Control Unit. The facility is responsible for using only certified PRAS and for any discrepancy discovered by the DAQ.
The facility must also comply with any additional regulations or obtain any additional permits associated with the PRAS.
The DAQ has the right to require additional testing and/or monitoring of the PRAS in accordance with 2Q .0317. To
comply,the facility must record the amount of PRAS delivered to and used at the facility. Each load or batch of PRAS
received shall include the following:
• A delivery manifest document clearly showing the shipment content and amount, its place and date of loading,
and place and date of destination;
• A batch specific analytical report contains analysis for all constituent/properties listed above in the specification.
Analytical results of the samples representative of the recycled shingles/roofing materials shipment from the
vendor shall be no more than one year old when received;
• Batch signature information consisting of the following: a batch number,batch weight, or volume of recycled
shingles/roofing materials delivered;and
• A certification statement indicates that the recycled shingles were sampled according to best practices and tested
according to appendix E,40 CFR Part 763, Section I and do not contain ACM or are otherwise asbestos-free as
determined by PLM before grinding.
Based on a review of records by this permitted facility, shingles were received beginning later in 2021 and used in the
process. At no point were shingles containing asbestos used. According to the facility's records,the final delivery of
asphalt shingles at the plant occurred on November 12,2021. A total of 102.52 tons were received. Mr.Palmer also
reviewed all records for each batch received at the plant, outlining the above requirements. Only one batch has been used
to certify the above requirements. . Twenty-five loads of shingles(from batch 1)have been received up through the
inspection(and since the beginning of the shingle use)
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Condition A.14 contains the vendor-supplied recycled No(s). 2 and 4 fuel oil requirements of 15A NCAC 2Q .0317. This
regulation requires all recycled fuel oil the facility receives to meet the criteria for unadulterated fuel. The recycled fuel
oil must meet the following requirements:
Co nstituent/Property Allowable Level
F�� Arsenic 1.0 ppm maximum
_..............._.._._._... .....:.
.............____.::_._.............. ..............._..............................
_.......
.............._ __.... ..........
........
w.........
.......
_...
...............�.�..............._.........................._...................
___.......... ._......................:.....:._....:.:..:.. ..........._.........._................._.....:.........._....._.................................................:............................................:
Cadmium I 2.0 ppm maximum
Chromium F 5.0 ppm maximum
Lead 100 ppm maximum
. ..........
Flash Point(No. 2 fuel oil) 100°F minimum
Flash Point(No. 4 fuel oil) 130°F minimum
W WWW�WSulfur(No. 2 fuel oil) 0.5 %maximum (by weight)
Sulfur(No. 4 fuel oil) 2.0 %maximum (by weight)
Ash 1.0%maximum
The facility is required to maintain records of all recycled fuel delivered to and combusted onsite on an annual basis. The
facility must also keep delivery manifest documents detailing the shipment content and amount and a batch specific
analytical report to demonstrate that the criteria above are met. Compliance with this condition is indicated. As indicated
by the records provided by plant personnel and discussion during this FCE,this facility has not received any recycled No.
4 fuel oil since the last inspection or in many years.
WSRO-DAQ Compliance History(within the last five years):
No Notice of Deficiencies(NODS)or Notices of Violations(NOVs)have been issued to this permitted facility. No dust
or odor complaints are logged or received in the WSRO for the permitted location.
Permit Discussion or Consideration:
• ES2.3 is no longer on site;and there are no plans to replace the equipment.
• I-ES8 should be an additive storage tank used in the liquid asphalt.
• 1-3 is empty and not disconnected.
NSPS/MACT/GACT:
The permitted facility is subject to a New Source Performance Standards(NSPS)regulation. The facility is subject to 40
CFR Part 60, Subpart I for"Hot Mix Asphalt Facilities" as discussed in Condition A.6 above. The facility is not subject
to National Emission Standards for Hazardous Air Pollutants(NESHAP)regulations.
The facility is not subject to any MACT or GACT currently. The facility currently does not have any emergency
generators or boilers onsite. There is also no gasoline dispensing equipment at this plant.
Facility-Wide Emissions(borrowed from Permit R21 review by Leo Governale,WSRO Environmental Engineer):
"The table below indicates the expected facility-wide emissions, except for potential S02 and CO emissions, after
controls/limits, as submitted with the application,which are estimated based on the permitted asphalt production limit of
7

720,000 tons/yr and the use of No. 4/Used No.4 Fuel Oil having a sulfur content of 1.05%,by weight. The potential SOz
and CO emissions, after controls/limits, are in accordance with the Synthetic Minor limit."
'Potential Emissions
Expected (tons/year)'
Pollutant Actual Emissions ~--�
I (tons/year) Before After Controls/Limits
Controls/Limits
PM 39.09 42,959.89 79.10
PM10 16.87 _ 9,974.74 45.15
-156.93 �_ <100
i NOx
.. 20.82 .. . ........._.._8..__5.......3......4._....... .... �
_._ 85.34.._ ......... ...._.... ....... _..... C�....... ...� _..... . _.. .........
_............
203.46 <1004 ................._. _____._...................
CO
VOC 17.35 72.01 72.01
HAP Total
10.80 15.64 15.64
j 1lAPxigi,est(Formaldehyde) 4.88(1.15 4.88
Conclusion:
Based on review of records and visual observations during this inspection,the permitted facility appears to comply with
all applicable air quality regulations and standards.
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