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HomeMy WebLinkAboutAQ_F_0500008_20220623_CMPL_InspRpt (4) NORTH CAROLINA DIVISION OF Winston-Salem Regional Office AIR QUALITY Maymead Materials,Inc.-Jefferson Plant NC Facility ID 0500008 Inspection Report County/FIPS:Ashe/009 Date: 06/23/2022 Facility Data Permit Data Maymead Materials,Inc.-Jefferson Plant Permit 00481 /R21 2522 NC Highway 16 North Issued 3/15/2019 Crumpler,NC 28617 Expires 4/30/2025 Lat: 36d 27.0000m Long: 81d 24.2100m 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 Sean Mackey Wiley Roark Sean Mackey NSPS: Subpart I Secretary President Secretary (423)727-2005 (423)727-2000 (423)727-2005 Compliance Data Comments: Inspection Date 06/23/2022 Inspector's Name Ryan Dyson Inspector's Signature: DMM Operating Status Operating Compliance Status Compliance- inspection Action Code FCE Date of Signature: Inspection Result Compliance !*-64&0 LL Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PMIO *HAP 2016 1.40 4.40 2.50 1.90 5.30 1.0000 249.80 2011 1.26 2.16 1.56 0.1100 3.47 1.26 45.10 * Highest HAP Emitted inpounds) Five Year Violation History:None Date Letter Tyne 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 _ _ ...._......................._.._............y..�.�.....................................�._.._............._._...__....___.......__.......�..........�_... .....__......_....__.._.._...._......_ W.......,,....,..,....__.._...._..._... _._ __..._r Emission Emission Source Control Control System _.. ... .. Source ID Description System ID Description One drum mix,hot mix asphalt plant(200 tons per hour maximum rated capacity)including: �HMAPla Natural gas/No.2/recycled No.4 fuel oil-fired rotary drum mixF CS-1 Bagfilter(8,679 square (NSPS) asphalt plant(96.8 million Btu per hour burner capacity) �feet of filter area) SILO-1 Hot mix asphalt storage silo(150 tons capacity) N/A N/A SILO-2 Hot mix asphalt storage silo(150 tons capacity) N/A N/A _................................_..............................................._...._.....,............................................._......_................_._.............................................._..........._._.._........................................_.._......._............................. ............................__........__..._.__.._......................... ........................._..._......._......._.._.. ..................... TL-1 ( Truck load out operation N/A N/A �. ._ .:................ ._...._. W.... W.._..... ....�.,.,:...:..... .._.......�_._...._... ..................... _ _ -- . .:.. :., H-1 No.2 fuel oil-fired liquid asphalt heater N/A N/A (1.45 million Btu per hour maximum heat input) Insignificant/Exempt Activities Source Exegmption 'Source of Source of Title V Re ulation TAPS. Pollutants. ............. ..:..................................... ............................................ ........ .................... I-3 -Fuel oil above ground storage tank(250-gallon capacity) 1-4-Fuel oil above ground storage tank(10,000-gallon capacity) 2Q 0102 Yes I-5a-Liquid asphalt above ground storage tank(20,000-gallon capacity) (g)( ) Yes I-7-Fuel oil above ground storage tank(I0,000-gallon capacity) I-8-Propane above ground storage tank(100-gallon capacity) No Introduction On June 23,2022,Mr.Ryan Dyson,Environmental Specialist for the Winston-Salem Regional Office of the North Carolina Division of Air Quality(WSRO-DAQ),met with Mr. Steven Gentry,Plant Operator,and conducted a Full Compliance Evaluation(FCE)of Maymead Materials, Inc.-Jefferson Plant.This facility was most recently inspected by Mr.Dyson on April 9,2021 and appeared to be in compliance with all applicable air quality standards and regulations at that time.This facility is a drum mix,hot mix asphalt plant with a maximum rated capacity of 200 tons per hour.The facility typically only operates for a few months out of the year,and only when asphalt is needed in that immediate area.All IBEAM contact information was confirmed at the time of this inspection. Safety Equipment Proper Personal Protective Equipment(PPE)for this facility includes safety shoes,safety glasses,hearing protection,a hard hat and a reflective safety vest. Inspectors should be cautious of the traffic of heavy mobile equipment on-site. 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 .0503,2D.0506,2D .0516,2D .0521,2D.0524(40 CFR 60, Subpart I),2D.0535,2D.0540,2D .0605,2D .0611,213 .1100,2D .1806,2Q.0315,2Q .0317(2D.0530 and 2Q .0700 Avoidance)and 2Q .0711.This facility is not subject to the Risk Management Plan(RMP)requirements of the 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. Discussion The facility is permitted as a 96.8 million Btu per hour burner capacity natural gas/No.2/recycled No.4 fuel oil-fired rotary drum mix asphalt plant(HMAPIa)with a maximum rated capacity of 200 tons per hour.However,the most recent permit revision limits the asphalt plant production rate to 171.49 tons per hour(110%of the production rate of the plant at the time of the last stack test)because they did not test at 90%of their rated capacity during their most recent stack test on July 30,2014.The emissions from this rotary drum mix asphalt plant are controlled by bagfilter CS-1.The facility is also permitted for a No.2 fuel oil-fired liquid asphalt heater (H-1),as well as two, 150-ton capacity each,hot mix asphalt storage silos(SILO-1 and SILO-2)and a truck load-out operation(TL-1) located beneath these silos. Liquid asphalt at the facility is mixed with dried aggregate to produce asphalt.This asphalt is then conveyed to the facility's storage silos before it is ultimately loaded onto trucks for delivery.The facility's current permit also lists 2 several exempt storage tanks.These include a 250-gallon capacity above ground fuel oil storage tank(I-3),a 10,000-gallon capacity above ground fuel oil storage tank(I-4),a 20,000-gallon capacity above ground liquid asphalt storage tank(I-5a),a 10,000-gallon capacity above ground fuel oil storage tank(I-7)and a 100 gallon above ground propane storage tank(I-8). The facility was in operation at the time of this inspection.At the time of this inspection,the asphalt plant was combusting natural gas and producing asphalt at a rate of 130 tons per hour.Mr.Gentry explained that the facility is still capable of using No.2 fuel oil for back-up purposes but is no longer set up to be able to use any No.4 fuel oil.The asphalt being produced at the time of this inspection contained approximately 20%RAP.The facility's bagfilter(CS-1)was in operation,with a pressure drop of 3.0 inches of water and a stack temperature of 2787 at the time of this inspection. Slight visible emissions were observed from the bagfilter exhaust (approximately 10%opacity)at the time of this inspection.Although no trucks were observed being loaded(TL-1)at the time of this inspection,the facility was actively filling the hot mix asphalt storage silos.The visible emissions observed from the loading of the silos also appeared to exhibit approximately 10%opacity at the time of this inspection.The No.2 fuel oil-fired liquid asphalt heater (H-1)was also observed in operation,with a temperature of 3217 and no discernible visible emissions. All the facility's exempt storage tanks were observed on-site with the exception of I-7(10,000-gallon aboveground fuel oil storage tank),as this tank has been removed from the facility. It appears that this tank(I-7)used to contain recycled No.4 fuel oil. Permit Conditions Condition A.2 contains the permit renewal and emission inventory requirement of 15A NCAC 2D .0202. To meet this requirement, the facility must submit a permit renewal request and air pollution emission inventory report for the 2023 calendar year at least 90 days prior to the expiration date of the permit.The current permit for this facility expires April 30,2025.The requirements of this condition were discussed with Mr.Gentry at the time of this inspection,and future compliance is anticipated. Condition A.3 contains the particulate control requirement of 15A NCAC 2D .0503.To comply,particulate matter emissions from the facility's No. 2 fuel oil-fired liquid asphalt heater(H-1)must not exceed 0.60 lbs./million Btu.According to Permit Review R19, written by Mr.Dylan Wright,Environmental Engineer I1 for the WSRO-DAQ,particulate matter emissions from the facility's No.2 fuel oil-fired liquid asphalt heater(H-1)are calculated to be 0.024 lb.PM/million Btu. Compliance with this condition is indicated. Condition A.4 contains the particulate control requirement of 15A NCAC 2D .0506.To comply,particulate matter emissions resulting from the operation of a hot mix asphalt plant shall not exceed allowable emission rates.The facility's allowable emission rate is equal to 45.03 lbs. PM/hr.The facility's most recent stack test was conducted on July 30,2014.Total particulate matter emissions from HMAP1 a were found to be 3.59 lb./hr.at the time of the test,demonstrating compliance with this condition. This rule also requires that visible emissions from stacks or vents be limited to be less than 20 percent opacity when averaged over a six-minute period,and that fugitive dust emissions are controlled as required by 15A NCAC 2D.0540.The results from the aforementioned stack test indicated an average opacity of 0%.No visible emissions of greater than 10%opacity were observed from the facility's emission sources at the time of this inspection.This condition also states that fugitive dust emissions shall be controlled as required by 15A NCAC 2D .0540,which will be discussed in greater detail under Condition A.9. Compliance with this condition is indicated. Condition A.5 contains the sulfur dioxide control requirement of 15A NCAC 2D .0516.To comply,sulfur dioxide emissions from the facility's combustion sources must not exceed 2.3 pounds per million BTU heat input.This regulation applies to the drum mix asphalt plant(HMAP1)and the facility's No.2 fuel oil-fired liquid asphalt heater(H-1).According to Permit Review R19,sulfur dioxide emissions from HMAP1 are calculated to be 0.18 lb. SO2/million Btu,at a production rate of 200 tons of asphalt per hour. Sulfur dioxide emissions from the facility's No.2 fuel oil-fired liquid asphalt heater(H-1)are calculated to be 0.51 lb. SO2/million Btu. Compliance with this condition is indicated. Condition A.6 contains the visible emissions control requirement of 15A NCAC 2D.0521. Visible emissions from emission sources manufactured after July 1, 1971,shall not exceed 20 percent opacity when averaged over a six-minute period,except that six-minute periods averaging not more than 87 percent opacity may occur not more than once in any hour nor more than four times in any 24- hour period.No visible emissions were observed in exceedance of 10%opacity,indicating compliance with this condition at the time of this inspection. Condition A.8 contains the notification requirement of 15A NCAC 2D.0535.To comply with this condition,the facility shall notify the Director of any excess emissions that last for more than four hours and that result from any malfunction,breakdown of process or 3 control equipment,or any other abnormal circumstance.No notifications have been received since the date of the last inspection,and ;I Mr. Gentry stated that no such incidents had occurred since the date of the last inspection.Compliance with this condition is indicated. Condition A.9 contains the fugitive dust control requirement of 15A NCAC 2D .0540.To comply with this condition,the permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantiated complaints or excess visible emissions beyond I the property boundary.Although the movement of the facility's on-site mobile equipment appeared to be generating some dust,this dust was not observed traveling beyond the property boundary of the facility at the time of this inspection.Furthermore,no dust complaints appear to have been attributed to this facility since the last inspection.As noted by previous inspectors,the facility has a water tanker truck on-site that is used to wet down the area during dry periods.Compliance with this condition was indicated at the time of this inspection. Condition A.10 contains the testing requirement of 15A NCAC 2D.0605.To comply,the facility must demonstrate compliance with emission limits by testing emission sources and maintaining records of malfunctions,testing and monitoring. The facility is required to perform EPA Method 5 and Method 202 testing to demonstrate compliance with the facility's PM limits.The facility is required to submit written notification of testing at least 15 days prior to the testing. The permittee is also responsible for ensuring that the equipment being tested is operated near the maximum normal production rate.The most recent stack test was performed on July 30, 2014.This test was conducted at an asphalt production rate of 155.9 tons per hour,and the results of this test were approved by the Stationary Source Compliance Branch(SSCB)on December 16,2014. This facility was issued a letter on November 20,2018,stating that asphalt plants that tested emissions while operating at less than 90%of their maximum rated capacity and whose test results were greater than 25%of a standard must either re-test immediately or apply for an administrative amendment to amend their permit to require a re-test in the event the facility exceeds 110%of the production rate at which the facility tested. In response to this letter,the facility chose to apply for an administrative amendment,and Permit No.00481R21 was ultimately issued to the facility to incorporate this change.The facility is required to maintain daily records (for each day of operation)of the total daily production in tons,the hours of operation and the highest targeted hourly production rate for that day. If a production rate exceeds the production rate shown above,plus ten percent,the facility shall notify DAQ in writing within 15 days after such date and conduct emission source testing within 60 days. If an exceedance does not occur,the facility is still required to conduct a re-test,and submit the test results by December 31,2024,according to the facility's current permit. The facility's production records were provided and reviewed back to the date of the last facility inspection.According to the provided daily records,the facility appears to operate consistently at a rate between 139 and 140 tons per hour.Mr.Gentry verbally confirmed this at the time of the inspection and indicated that 150 tons per hour would realistically be the highest rate at which the facility could operate. Mr. Dyson noticed,however,that on September 14,27,28,29,30 and October 1,2021,hourly production values were calculated in the facility's excel spreadsheet between 200.25 and 215.32 tons per hour.These values,if valid,would appear to trigger re-testing at the facility. Mr.Dyson contacted Mr. Sean Mackey, Secretary,regarding this issue via a telephone call on June 27,2022. Mr. Mackey stated that Mr. Gentry had been unavailable to operate the plant during that stretch of time and a back-up plant operator was brought in. Mr. Mackey indicated that this back-up operator was unfamiliar with the data calculation and entry processes at the facility.Based upon Mr. Mackey's description,and all surrounding data, it appears that these values may have been calculated in error. Mr.Dyson requested additional clarifying information from Mr.Mackey.Mr.Mackey stated that his office will go through all their physical receipts and time records from that period to clarify these calculations.Mr.Dyson reminded Mr.Mackey of this additional information request via a telephone call on June 30,2022,and an email on July 7,2022.Mr. Mackey indicated that they were actively attempting to gather the information,but it may take some time due to the volume of physical paperwork they are searching through. Compliance with this condition is indicated,pending the results of Mr.Mackey's findings. Condition A.11 contains the fabric filter requirements of 15A NCAC 2D.0611.To comply with this condition,the facility shall perform,at a minimum,an annual(for each 12-month period following the initial inspection)internal inspection of each particulate collection device system.Records of these inspections must be kept on-site.Mr.Gentry provided these records,and they were reviewed back to the date of the last inspection.These records indicate that the facility conducts monthly internal inspections of the bagfilter system(CS-1),with the most recent internal inspection having occurred on June 13,2022.These records indicated that the bagfilter housing was patched and sealed on May 12,2021,and the dust chain was tightened on July 10,2021.Compliance with this condition is indicated. Condition A.12 contains the toxic air pollutant emissions limitation and reporting requirement of 15A NCAC 2D .1100.To comply, the facility must not exceed the emission limits for toxic air pollutants,as conveyed below: 4 Affected Source(s) Toxic Air Pollutant Emission Limit _................._............._... ....................._.._.__.......:......_.................................................._...._ ....,...........:..._............................._._......................................................._............_...."...............................................__......:......................._....._....,.......,............................._........................................_............_........ Arsenic&Compounds(total mass of elemental AS, arsine and all inorganic compounds)(ASC i 0.275 lbs/yr Natural gas/No.2/recycled No.4 (7778394)) fuel oil-fired rotary drum mix _ .. ... asphalt plant Benzene(71 43 2) 191 lbs/yr (96.8 million Btu per hour burner dmium Metal,elemental,unreacted(Component0.201 lbs/yr capacity) �6a f CDC)(7440-43-9) (HMAPIa) Formaldehyde(50-00-0) 0.62 Ibs/hr Nickel metal(Component of NIC)(7440-02-0) 0.302 lbs/24-hours Two Hot mix asphalt Benzene(71-43-2) �1.91 lbs/yr storage silos (SILO-1 and SILO-2) Formaldehyde(50-00-0) 0.0168 lbs/hr �uck load-out operation Benzene(71-43-2) 1.06 Ibs/yr (TL-1) Formaldehyde(50-00-0) I 0.000732 lbs/yr Arsenic&Compounds(total mass of elemental AS, arsine and all inorganic compounds) 0.00151 lbs/yr No.2 fuel oil-fired liquid asphalt (ASC(7778394)) heater Benzene(71-43-2) 0.000728 lbs/yr �(1.45 million Btu per hour maximum heat input) rdm aium Metal,elemental,unreacted(Component 0.00113 lbs/yr P ) f CDC)(7440-43-9) (H-1) Formaldehyde(50-00-0) 0.0000457 lbs/hr Nickel metal(Component of NIC)(7440 02 0) 0.0000111 lbs/24-hours To ensure compliance,the following requirements must be met: • Hot mix asphalt production shall not exceed 491,000 tons per calendar year. • The amount of No.2 fuel oil combusted in the liquid asphalt heater(ID No.H-1)shall not exceed 27,005 gallons per calendar year. • The height of the bagfilter(ID No. CS-1)stack shall not be less than 21.6 feet and shall be located at UTM coordinates 17N 463833.00 4033957.00. • The height of the two hot mix asphalt storage silos(ID No. SILO-1 and SILO-2)stack shall not be less than 58 feet and shall be located at UTM coordinates 17N 463864.00 4033961.00. • The height of the liquid asphalt heater(ID No.H-1)stack shall not be less than 9 feet and shall be located at UTM coordinates 17N 463833.00 4033949.00. The facility is required to maintain records of the monthly quantity,in tons,of hot mix asphalt produced,as well as the monthly quantity,in gallons,of No.2 fuel oil combusted in the liquid asphalt heater(H-1).These records were provided and reviewed back to the date of the last inspection.These records appeared to contain the necessary information for both monthly asphalt production and monthly No.2 fuel oil usage. The facility is also required to report,within 30 days after each calendar year quarter,the total amount, in tons,of hot mix asphalt produced and the total amount,in gallons,of No.2 fuel oil combusted in the liquid asphalt heater(H-1)from the beginning of the calendar year to the last day of the previous quarter.The most recent quarterly report was received on April 13,2022 and reviewed by this inspector.According to this report,60,158.16 tons of asphalt were produced at the facility in calendar year 2021,and no asphalt was produced in the first quarter of 2022.This report also indicated that 9,353 gallons of No.2 fuel oil were combusted in the liquid asphalt heater(H-1) in calendar year 2021,and 899 gallons were combusted in H-1 in the first quarter of 2022.Mr.Dyson compared the reported monthly asphalt production values to those contained in the facility records date back to the date of the last facility 5 inspection,and these values appeared to align. It did not appear evident to this inspector that any equipment on-site had been re- located since the last inspection.Historical Google Earth imagery also does not appear to indicate that any equipment has been re- located at the facility since the facility's dispersion modeling analysis was revised on July 3,2018.Compliance with this condition is indicated. Condition A.13 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 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.14 contains the limitation to avoid 15A NCAC 2Q.0501,pursuant to 15A NCAC 2Q .0315,"Synthetic Minor Facilities."This regulation allows the facility to take an operational restriction in order to avoid Title V permitting.To comply in this case,facility-wide emissions of S02 and CO must be less than 100 tons per consecutive 12-month period.The following operational restrictions are in place to ensure that the facility's emissions do not exceed emission limits: • The total amount of asphalt produced shall be less than 491,000 tons per consecutive 12-month period. • The sulfur content of the No.2 and recycled No.4 fuel oils shall be limited to 0.5%sulfur by weight. The facility is required to maintain records of the amount,in tons,of asphalt produced.These values are to be recorded monthly and totaled annually.The facility is also required to maintain fuel supplier certifications.A review of the facility's records indicates that the facility did not exceed the 491,000-ton asphalt production limit over the prior 12-month window.The facility's records also state that all fuels purchased are less than 0.5%sulfur by weight,and that the facility has not combusted any recycled#4 fuel oil since the date of the last inspection. Within 30 days after each calendar year,the facility is required to submit a report conveying monthly and 12-month totals for the previous 12-month period of the amount,in tons,of asphalt produced and the facility-wide sulfur dioxide and carbon monoxide emissions, in tons.The most recent annual report was received on January 26,2022.This report indicated that 60,158.16 tons of asphalt were produced at the facility in calendar year 2021.This report also indicated that 0 tons of sulfur dioxide and 4.23 tons of carbon monoxide were released form the facility in calendar year 2021.Compliance with this condition is indicated. Condition A.15 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 their emissions of S02 to below 250 tons per consecutive 12-month period.The facility already has restrictions listed in Condition A.14 to limit their emissions of S02.Therefore,compliance is demonstrated through compliance with Condition A.14. Condition A.16 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 that the facility receives to meet the approved criteria for unadulterated fuel.The recycled fuel oil must meet the following requirements: j Constituent/Property Allowable Level ........................_...........................................................,........._.............................. .......................................................................................... pp _ . _ . _ i Arsenic 1.0 m maximum - u. Cadmium 1�� 2 0 ppm maximum Chromium 5.0 ppm maximum I !......................................................................................................................................................................................... ......_ .......................... pp_ . ...........................................................Lead 100 m maximum I Flash Point(No.2 fuel oil) 100°F minimum Flash Point(No.4 fuel oil) 130°F minimum Sulfur(No.2 fuel oil) F2.0 5%maximum(by weight) S�o.4 fuel oil) %maximum(by weight) .� Ash 1.0%maximum ......................................................................................................................................................................................................................................._................................. ................:J 6 The facility is required to maintain records of all recycled fuel delivered to and combusted on-site 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.As indicated by the facility's records,this facility has not received any recycled fuel oil since the last inspection.Compliance with this condition is indicated. Condition A.17 contains the toxic air pollutant emissions limitation requirement of 15A NCAC 2Q .0711.To comply,the facility must be operated and maintained in such a manner that emissions of any listed Toxic Air Pollutant(TAP)will not exceed their associated Toxic Permit Emission Rates(TPERs).The following table,borrowed from Permit Review R19,shows the various TPERs associated with this facility.It should be noted that the facility's asphalt production rate has remained relatively steady,and the actual emission rates are calculated to be well below their associated TPERS.Therefore,continued compliance is anticipated. F TAP_ 2Q 07`11 TFER CY2016 Actual missions Rate �_.......:_ _ ........_..W......................................._. __. .....: ... .... ..... . Acetaldehyde 6.81b/hr 0.064lb/hr j _� Acrolein F—o.02 lb/hr F 0,001 lb/hr Benzo(a)pyrene 2.2 lb/yr 0.0014 1b/yr ................_............................................................_,............__................................................................................................_..................................................._..................,...................................................................................... Cry+soluble chromate compounds 0.013 lb/day 0.002 lb/day F 1,2,3,6,7,8-Hexachlorodi -dioxin _[ �0.0051 lb/yr 1 02E 07 lb/yr benzo-p .............. ...............................................:.......................__....................._....::................................................_...._...................:._...... .23 lb/day 0.375 lb/da........ n.. xane ( ..........._ y.... -He ................................:........................................._..........................._........................................................_........................................................................................................_ Hydrogen chloride 0.18 lb/hr 0.010 lb/hr r Manganese and compounds 0.63 1b/day �_6 003 lb/day I H va or 0.013lb/day (....... 0.001 lb/day........_.............................................._._._[ 64 lb/hr 0.002 lb/hr ... .._.._.._.._..._... .... ..Methyl chloroform �'� 2501b/day 0.019 lb/day (, 22.41b/hr O.00 l lb/hr Methyl ethyl ketone __,_ .�,. .... .. 78...1b/day.... ......_ 0 010,5 1b/day.... ... ....... [— 2,3,7,8-Tetrachlorodibenzo-p-dioxin F-0.0002 lb/yr �� 1 65E 08 lb/yr 14.41b/hr 0.143 lb/hr Toluene 981b/day � 1141b/day NSPS/NESHAP Condition A.7 references 15A NCAC 2D.0524,"New Source Performance Standards"as promulgated in 40 CFR 60, Subpart I, including Subpart A "General Provisions."To comply,the Permittee shall not discharge or cause the discharge into the atmosphere from any affected source any gases which contain particulate matter in excess of 90 mg/dscm(0.04 gr/dscf) or exhibit 20 percent opacity,or greater.The facility is required to perform testing to demonstrate that they are operating within compliance.The most recent stack test performed at the facility occurred on July 30,2014.This test yielded a filterable PM result of 23 mg/dscm and a visible emissions result of 0%opacity.Compliance with this condition was demonstrated. Facility-Wide Emissions The following table was borrowed from Permit Review R19 and updated.All emissions listed below were from the 2016 Emissions Inventory,with the exceptions of S02 and CO.These actual emissions were gleaned from the facility's most recent annual report,which was received on January 26,2022,and depicts emissions from the 2021 calendar year. A,9,YO al: PM 2.8 PM10 2.0 S02 0.0 NO,. 5.0 CO 4.2 7 i � :: . .. ., 1?olluitant ,.,...."'' � .., .. ',. " :Actual;E�►issior�s t 3 �.��M�. �e � : VOC 3.8 HAP TMI 0.811 HAP Hi hat(Formaldehyde) 0.25 Permit Issues/Considerations The 10,000 gallon above ground recycled No.4 fuel oil storage tank(I-7)has been removed from the facility. As Mr. Barker noted in his inspection report dated September 18,2020,"Fuel oil storage tank 1-3 is no longer used"and "Propane storage tank 1-8 is no longer used."Both storage tanks are still located on-site,however. Stack Testing The facility conducted a stack test on HMAP1 a on July 30,2014,to demonstrate compliance with 40 CFR Part 60, Subpart I and 15A NCAC 2D .0506. The test results,which are pictured below,demonstrated compliance. SSCB approved the test results on December 16,2014. j Pollutant Test Results Emission Limit Emission Standard Compliance Filterable PM 23 mg/dscm 90 mg/dscm Yes (0.01 gr/dscf) (0.04 gr/dscf) NSPS Subpart I Visible Emissions 0%* 20% Yes Filterable PM 2.39 lb./hr. --- --- Condensable PM 1.20 lb./hr. --- --- --- Total PM 3.59 lb./hr. 45.03 lb./hr. 15A NCAC 2D .0506 Yes 5 Year Compliance History On February 5,2018,the facility was issued a Notice of Deficiency(NOD)for an incomplete quarterly report,as required under 15A NCAC 2D.1100,"Control of Toxic Air Pollutants."This report was received on time(January 30,2018)but portrayed an exceedance of the total annual allowable amount of No.2 fuel oil combusted within the liquid asphalt heater(H- 1). The allowable amount was 27,005 gallons,and the facility reported 46,626 gallons.The facility responded to this NOD on February 14,2018 and indicated that the facility combusted 14,400 gallons of fuel oil in the asphalt heater in calendar year 2017.The 46,626 gallons were described as the amount delivered to the facility in the reporting period. Conclusion Based on visual observations and record review,Maymead Materials,Inc.-Jefferson Plant appeared to be in compliance with all applicable Air Quality standards and regulations at the time of this inspection.However,Mr. Mackey should be following up with Mr. Dyson regarding the compliance add info request described under Condition A.10. 8