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Home My WebLink AboutAQ_F_2000123_20210928_CMPL_InspRpt - Al6 NORTH CAROLINA DIVISION OF Asheville Regional Office AIR QUALITY Harrison Construction Division of APAC-Atlantic, Inc. Inspection Report NC Facility ID 2000123 Date: 10/19/2021 County/FIPS: Cherokee/039 Facility Data Permit Data Harrison Construction Division of APAC-Atlantic, Inc. Permit 08976/RI 235 Marrestop Road Issued 6/30/2020 Murphy,NC 28906 Expires 7/31/2023 Lat: 35d 0.6660m Long: 84d 13.6320m 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 Don Mason Don Mason Don Mason NSPS: Subpart I Environmental Environmental Environmental Compliance/Quality Compliance/Quality Compliance/Quality Control Control Control (828)524-5455 (828)524-5455 (828)524-5455 Compliance Data Comments: Inspection Date 09/28/2021 Inspector's Name Michael Koerschner Inspector's Signature: Operating Status Operating Compliance Status Compliance-inspection Action Code FCE Date of Signature: ]q,.0-Z- Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP SO2 NOX VOC CO PMIO *HAP 2014 --- --- --- --- --- 2009 0.1700 3.63 0.9100 0.0600 0.3300 0.1600 5.37 * Highest HAP Emitted(in pounds) 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 Directions: Travel on Hwy. 64 about 12 miles west of Murphy. About 4 miles past Ranger Elementary School, turn left off of Hwy. 64, across the median, across the east bound lanes, on Marrestop Road. Marrestop Road is not well marked from the west bound side of Hwy. 64 (between Mile Marker 5& 6). Go about 114 mile on Marrestop Road, Harrison Quarry is on the left(drive into quarry--1 mile and you'll see asphalt plant). Safety Equipment required: Hard hat, earplugs, safety glasses, safety shoes, &high-visibility vest(recommend). 1. Facility Overview Discussion/Introduction On September 28,2021,I(Michael Koerschner)went to the site to conduct an annual compliance inspection. The plant was observed but WAS NOT IN OPERATION. This facility has historically operated on a sporadic basis(demand based). Facility Contacts The facility contacts appear to be up-to-date in IBEAM(per Don Mason, facility technical contact) Facility Description Harrison Construction Division of APAC-Atlantic,Inc.—Murphy Asphalt Plant is a hot mix asphalt batch plant, subject to NSPS Subpart I,with a maximum rated capacity of 300 tons per hour. The facility is permitted for the following operations air emission sources/air cleaning devices and appurtenances described below: .........................................................................,...:............................................................................................................................................................................................ Emission Emission Source Control = Control System Source ID Description System ID 1 Description .. One hot mix asphalt batch plant(300 tons per hour maximum capacity)consisting of: .. _.,...., _ ...._............ .:.........:.:_:..__... _:.__._. ............. ......... ES 1 (NSPS) one natural gas/No. 2(virgin or recycled)fuel oil\No.4 CD2 one knock-out box(1,408 (virgin or recycled)fuel oil-fired hot mix asphalt batch cubic feet)(CD2)in series with plant(88 million Btu per hour maximum heat input rate CDI one bagfilter(11,084 square while combusting natural gas and 110 million Btu per feet of filter area)(CD1) hour maximum heat input rate while combusting fuel .oils)processing asphalt and reclaimed asphalt product (RAP) f ES2,ES7, three hot mix asphalt storage silos(200 tons storage N/A N/A i 'and ES8 capacity,each) :._..... _......_.m._._. ._w_:...m ............. _----...__._..._._,_ ._ _...._...._..__�.___._._..._._ . .�._... _.�._.�_._...__...:__._. .�._�.._.. _...:... ES3 one main plant truck loadout operation N/A N/A ES6W done hot mix asphalt storage silo truck loadout operation N/A 1 ......................................................._................................................................................................................ I observed the equipment listed above—NOT IN OPERATION except that there are only two silos at this facility (permitted for 3). 2. Emission Sources and Regulatory Review Compliance with specific permit conditions and limitations Specific Condition 3: Particulate Control Requirement-Hot Mix Asphalt Plants Maximum allowable particulate emission rate from the facility are limited to 60 pounds per hour(at a process rate of 300 tons asphalt/hour);visible emissions from any stack,vent, or any fugitive emission is limited to 20%opacity; and,the facility must be equipped with a scavenger process dust control system for the processing of the aggregate. This facility is subject to NSPS Subpart I which is a concentration limit but is generally more stringent than 2D .0506.The results of the 10/08/2015 stack test indicates compliance with the particulate limits for the aggregate dryer. Specific Condition 4: Sulfur Dioxide Requirement This condition applies to the combustion sources and limits sulfur dioxide emissions to 2.3 pounds per million Btu. Compliance with this condition was established by calculation during the last permit renewal.The fuel oil combusted(recycled No.4)at this facility is generally less than 0.5%Sulfur and permit-limited to less than 1.0% Sulfur.Continued compliance is expected. Specific Condition 5: New Source Performance Standards The facility is to comply with the NSPS emission limitations of 90mg/dscm(0.04 gr/dscf)particulate and 20% opacity. The results of the 10/08/2015 stack test indicates compliance with this condition(see Section 4 below). Specific Condition 7: Fugitive Dust Control Requirement This condition prohibits fugitive dust emissions from crossing the property boundary. During my visit the facility was NOT IN OPERATION and no trucks were driving on the haul roads. Compliance is indicated. Specific Condition 8: Toxic Air Pollutant Emissions Limitation and Reporting The facility has triggered a toxics review for benzene and formaldehyde,and has modeled compliance with the AALs. In order to demonstrate compliance,the facility has production limitations. Hourly asphalt production shall not exceed 300 tons and annual asphalt production shall not exceed 485,000 tons. The facility keeps production records electronically to demonstrate compliance with this condition. According to records received via email on 9/29/2021,this facility has produced 24,490 tons asphalt year-to-date. The 2020 asphalt production was 15416 tons (annual report received 1/19/2021). Specific Condition 9; Control and Prohibition of Odorous Emissions This condition requires the facility to restrict objectionable odors to the property. There have NOT been recent odor complaints associated with this facility. Specific Conditions 10 and 11: Synthetic Minor Limitation and PSD Avoidance In order to avoid Title V and PSD applicability,the facility has requested emission limitations on SO2,NOx and CO to remain a synthetic minor source. In order to demonstrate compliance with these limits,the facility has an annual production limitation of 485,000 tons(the same as that listed in Specific Condition 8),as well as a limitation of , 1.0%sulfur content by weight of the recycled No.4 fuel combusted in the dryer. The sulfur content of the highest load of fuel delivered was 0.22%Sulfur by weight. In addition,the facility must perform annual inspections of the control devices to ensure that they are operating properly to control particulate matter emissions. All records indicate compliance with the emission limitations. The annual internal inspection of the bagfilter system(including knock-out box)took place on April 19,2021. I reviewed the inspection records provided via email 9/29/2021. It appears that the bagfilter is being adequately maintained. Specific Condition 12: Vendor Supplied Recycled Fuel Oil Requirement The facility is permitted to use recycled fuel oil that meets the specifications set forth in the permit. The facility must maintain analytical records of the recycled fuel oil,as well as the amount of fuel oil combusted at the facility. An annual report is also required summarizing the analytical testing results as well as the annual usage of recycled fuel oil.The annual report,received 1/19/2021, indicates compliance with the specifications mandated by the air permit. Specific Condition 13: Toxic Air Pollutant Emissions Limitation Requirement The facility has demonstrated that their emissions of various toxic air pollutants are below the level that requires a permit to emit these toxics. As long as the facility does not go over the annual production limitation set forth in Specific Condition 8,emissions of these pollutants will remain below the TPER. Recordkeeping and Reporting_Requirements Review The facility is required to maintain records of asphalt production, control device I&M,and recycled fuel usage with fuel certifications. The facility is required to report asphalt production and recycled fuel usage with fuel certifications annually. The required records are maintained at the facility and the last annual report received on O1/19/2021 indicated compliance. In 2020,the facility produced 15,416 tons of asphalt. Insignificant/Exempt Activities Listing ....... .._..... ......... ...... Source Notes ............................................. ..... .. ................... ...... I-1 -One No.2 fuel oil-fired asphalt tank heater'(1.3 8 iObserved in operation. Currently combusting only million Btu per hour heat input) propane. No.2 fuel oil is no longer burned at this site. ......_. ......... .. . ... .............................................................. ......... ......... ;There are two fuel oil storage tanks at this facility. The facility no longer uses No.2 fuel oil but there is a I-2-fuel oil storage tanks 15,000 gallon No.2 fuel oil tank.Not sure if it's empty. The No.4 fuel oil is stored in a 20,000 gallon tank. 3. Compliance History Review The facility has had no other documented violations in the past five years. 4. Stack Test Review The facility was required to perform Methods 5, 9, and 202 stack tests for this permit cycle with the results due to this office within 60 days of the re-start. The results of the required stack tests,performed on October 8,2015,while producing 236 tons per hour and combusting recycled No.4 fuel, are shown in the table below: Source Standard Emission Limit Test Results Compliance Indicated? 60 Subpart 1 90 mg/dscm 0.008 gr/dscf) Yes ES-1 (0.04 gr/dscf) 15A NCAC 2D .0506 54.0 lb/hr 4.75 lb/hr Yes 5. Compliance Assistance The facility does not appear to need assistance at this time. 6. Recommendation/Conclusion/Compliance Statement During this inspection,this facility WAS NOT OPERATING and thus there were no emissions observed. Based on records provided, it appears that the Inspection and Maintenance aspects of the air permit are being performed as specified in Air Permit No. 08976R11. I recommend an inspection this fall(this"asphalt season")to observe the plant in operation.