AQ_F_1300172_20220426_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Reeves Construction Company-Bonds Asphalt
Plant
Inspection Report NC Facility ID 1300172
Date: 04/26/2022 County/FIPS: Cabarrus/025
Facility Data Permit Data
Reeves Construction Company-Bonds Asphalt Plant Permit 10437/R02
7139 Weddington Road,NW Issued 2/24/2022
Concord,NC 28027 Expires 7/31/2023
Lat: 35d 22.7142m Long: 80d 4l.6301m 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
Alan Gambill Zach Green Jake Flores NSPS: Subpart I
Plant Manager President Environmental Manager
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 04/26/2022
Inspector's Name Donna Cook
Inspector's Signature: Datum Lao* Agm Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: 04/29/2022 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
No emissions inventory on record.The emissions inventory is due 05/02/2023.
*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

Reeves Construction Company—Bonds Asphalt Plant
April 26,2022
Page 2
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Tracking: X Date submitted for initial review 04/29/2021 _IBEAM WARNING/OB,NOD,NOV,NRE
X IBEAM Document
X IBEAM Inspection,list date inspected _IBEAM LAT/LONG,Facility Locked
X IBEAM Inspection,list date draft is submitted X IBEAM LAT/LONG,Coordinates checked
X IBEAM Inspection,pollutants/programs checked IBEAM Complaint
X IBEAM Planning,Next Inspection Date 04/01/2023
Directions: From Mooresville Regional Office to Concord,travel Highway 3 South;turn right on Odell
School Road;turn right at the stop light onto Poplar Tent Road due to the no left turn; make a U turn at
the next stop light;past the interchange of Interstate 85 turn right at the stop light onto Pitts School Road;
1 '/2 miles turn right at the first stop light onto Weddington Road; '/2 mile turn left into the entrance of
Martin Marietta Materials,Inc.,Bonds Quarry;past the office/weigh scale and turn left at next unpaved
road. The address of the asphalt plant is 7139 Weddington Road. The phone number for Mr. Jason
Adams,plant operator, at the asphalt plant is(704) 897-6275. The phone number for Mr. Jake Flores,
environmental manager, is(704)682-5393.
Safety Equipment: This company requires that a hard hat, steel-toed shoes, safety vest, safety glasses
and hearing protection must be worn by the inspector at this facility.
Safety Issues: The inspector should be cautious of heavy equipment and truck traffic at the asphalt plant.
Lat/Long Coordinates: A review of the "Facilities Regulated by Air Quality" on the DAQ web site
indicates the facility's location is accurate and matches the facility's latitude and longitude coordinates
listed in IBEAM.No changes to the latitude and longitude coordinates of this facility are needed in
IBEAM. The latitude and longitude coordinates of this facility are not locked in IBEAM.
Email Contacts: The emails for the facility, authorized,technical, and invoice contacts were verified by
Mr.Jason Adams,plant operator.No changes to the email contact information are needed in IBEAM.
1. General Information:
The purpose of this site visit was to conduct a routine air quality inspection. Reeves Construction
Company operates a continuous drum type hot mix asphalt plant that produced 69,089 tons of
asphalt while burning natural gas in 2021 calendar year and 5,744 tons of asphalt from January 1
through March 31, 2022. The asphalt plant operates on a varied schedule, which is dependent
upon weather conditions and road projects. This facility is subject to NSPS Subpart I-"Standards
of Performance for Hot Mix Asphalt Facilities." Mr. Jason Adams, plant operator, accompanied
me during this inspection. Mr. Adams stated that this plant operates 2 to 10 hours per day, 5 to 6
days per week, 50 weeks per year.
2. Facility Contact Information:
During the inspection, I verified the facility contact information in IBEAM with Mr. Adams. No
changes to the facility contact information are needed in IBEAM.

Reeves Construction Company—Bonds Asphalt Plant
April 26,2022
Page 3
3. Compliance history file review:
No problems have been noted in the last five years by DAQ prior to this inspection. The current
compliance status is discussed in the following sections.
4. Observations of permitted air emission sources and control devices:
Emission Emission Source Control Control System
Source ID FDescription System ID Description
Continuous drum type,hot mix asphalt plant(225 tons per hour)
ES1 (NSPS) natural gas/No. 2 fuel CD1 bagfilter(9,184 square feet of
oil/recycled No. 2 fuel filter area)with inertial
oil/No. 4 fuel oil/recycled separator
No.4 fuel oil-fired
(propane-fired pilot light)
aggregate dryer(72 million
Btu per hour maximum heat
input rate)with associated
mixer
Propane is the fuel source to initially light the pilot on the burner of the rotary drum aggregate dryer.
The propane is stored in portable 25 pound tanks. After lighting on propane,the fuel is switched to
natural gas.Natural gas is the only fuel source for the rotary drum aggregate dryer.
The sand and aggregate are placed in five bins by a front end loader. The materials are conveyed
by five aggregate feeder belts (24 inch belts under each of the five feeders in bottom of bins)to one
collector aggregate conveyor belt(30 inch) and then to one vibrating single deck screen.After the
screening process,the materials are conveyed by one aggregate weigh bridge conveyor belt(30 inch),
then through a chute to a second aggregate conveyor belt(30 inch),to one aggregate slinger conveyor
belt(24 inch)and then into the inlet of the rotary drum aggregate dryer. Only two bins were in use at
the time of the inspection. The nine belt conveyors and the vibrating screen deck screen were in
operation with no visible emissions observed by me.
A front end loader is used to place the reclaimed asphalt product(rap)into one grizzly screen and
then dropped into one feeder bin.From the feeder bin,the rap is conveyed by one feeder belt(24
inch)to one vibrating single deck screen.After the screening process,the rap is conveyed by one
weigh bridge conveyor belt(24 inch)to a chute and then into the rotary mixer drum. The two belt
conveyors and the vibrating single deck screen were in operation with no visible emissions.Mr.
Adams stated that 20%rap is mixed in the mixer drum with liquid asphalt and any particulate matter
from the inertial separator and bagfilter(ID No. CD1) and the heated sand and aggregate materials
from the rotary drum aggregate dryer.
Portable crushing, screening and conveying equipment is used to crush the rap at this asphalt plant.
Mr. Adams stated that the crushing of RAP was not being conducted at the time of the inspection. I
observed no portable RAP crushing plant at this facility.

Reeves Construction Company—Bonds Asphalt Plant
April 26,2022
Page 4
After the drying process,the sand and aggregate are dropped by chute into the rotary mixer drum.
The sand and aggregate materials are mixed with liquid asphalt,reclaimed asphalt product(rap) and
any particulate matter from the inertial separator and bagfilter(ID No. CD 1)in the rotary mixer
drum. There is no drying in the mixer drum.After the mixing process,the hot mix asphalt product
is conveyed by the drag slat to storage silo (ID No. ES3 or company ID No. 1)or from the drag slat to
the traverse conveyor. From the traverse conveyor,the hot mix asphalt product is conveyed into
storage silo (ID No. ES4 or company ID No. 2). The hot mix asphalt product is gravity dropped from
the two storage silos into the beds of dump trucks.
During the inspection,the surface mix asphalt product,9.5C,was being stored in silo(ID No. ES4 or
company ID No. 2). The storage silo(ID No. ES3 or company ID No. 1)was empty. The surface
mix asphalt product was being gravity dropped from the storage silo(ID No. ES-4 or company ID
No. 2)into the beds of dump trucks with no visible emissions observed by me.
The particulate matter emissions from the rotary drum aggregate dryer exhaust to an inertial
separator. At the base of the inertial separator,the particulate matter emissions are gravity dropped
through a chute into the mixer drum. From the bagfilter,the particulate matter emissions are screw
conveyed into the mixer drum. This company has a gauge measured in inches of water that is used to
determine the pressure differential across the bagfilter. The gauge is located on the control panel
inside the plant office.
Observed.The continuous drum mix asphalt plant was operating at 120 tons per hour and producing
surface mix asphalt product, 9.5C. The rotary drum aggregate dryer was firing on natural gas. The
mix temperature in the rotary drum aggregate dryer was 300 degrees Fahrenheit. The pulse jet type
bagfilter was in operation. The pressure differential gauge across the bagfilter read 6.1 inches of
water. I observed no visible emissions from the exhaust of the vertical and uncapped bagfilter stack at
the time of the inspection.
ES2 lime silo (35.7 tons capacity, CD2 bagfilter(233 square feet of
25 tons per hour maximum filter area)
process rate)
Mr. Adams stated that the lime silo and bagfilter will not be constructed at this facility.
Observed. No lime silo and associated bagfilter were observed by me at this facility.
ES3 hot mix asphalt storage silo N/A N/A
�(200 ton maximum capacity)
The hot mix asphalt product from the rotary mixer drum is conveyed from the drag slat to hot mix
storage silo (ID No. ES3 or company ID No. 1). The hot mix asphalt product is gravity dropped from
storage silo#1 into the beds of dump trucks.
Observed.No hot mix asphalt product was being stored in storage silo(ID No. ES3 or company ID
No. 1)at the time of the inspection.
ES4 hot mix asphalt storage silo N/A N/A
(200 ton maximum capacity)
The hot mix asphalt product from the rotary mixer drum is conveyed from the drag slat to the
traverse conveyor. From the traverse conveyor,the hot mix asphalt product is stored in storage silo
(ID No. ES4 or company ID No. 2). The hot mix asphalt product is gravity dropped from storage
silo#2 into the beds of dump trucks.

Reeves Construction Company—Bonds Asphalt Plant
April 26,2022
Page 5
Observed.The hot mix asphalt product, surface mix 9.5C,was being stored in silo(ID No. ES4 or
company ID No. 2). I observed no visible emissions from storage silo#2 or the gravity dropping of
asphalt into the beds of dump trucks.
ESS Itruck loadout operation N/A N/A
The hot mix asphalt products are gravity dropped from the two storage silos(ID Nos. ES3 or
company ID No. 1 and ES4 or company ID No. 2) into the beds of dump trucks.
Observed.No hot mix asphalt product was being stored in storage silo(ID No. ES3 or company ID
No. 1). The gravity dropping of the hot mix asphalt product, surface mix 9.5C, from the storage silo
(ID No. ES4 or company ID No. 2)into the beds of the dump trucks was being conducted at the time
of the inspection with no visible emissions observed by me.
5. Observations of insignificant air emission sources and control devices listed on the current permit:
Source Exemption Source of Source of Title V
Regulation TAPS? Pollutants?
IES5 -natural gas-fired hot oil heater(1.2 2Q 0102 (h)(1)(B) Yes FYes
million Btu per hour maximum heat input)
The natural gas-fired hot oil heater(ID No. IES5) is used to heat the hot oil in two horizontal liquid
asphalt cement storage tanks(30,000 gallons,each),two hot mix asphalt storage silos(ID Nos. ES3
or company ID No. 1 or ES4 or company ID No. 2) and the liquid asphalt lines. The stack of the
natural gas-fired hot oil heater is vertical and uncapped.
Observed.The natural gas-fired hot oil heater was in operation at the time of the inspection. I
observed no visible emissions from the vertical and uncapped stack of the hot oil heater stack.
IES6—liquid asphalt cement storage tank 2Q 0102 (g)(4) No No
(30,000 gallons capacity)
The liquid asphalt is stored in a horizontal tank(ID No. IES6; 30,000 gallons). The sand and
aggregate materials are mixed with the liquid asphalt,reclaimed asphalt product(rap)and any
particulate matter("dust")from the inertial separator and bagfilter(ID No. CD-1)in the rotary mixer
drum.
Observed.No tanker truck unloading of liquid asphalt into the horizontal storage tank was occurring
at the time of the inspection. The liquid asphalt in the horizontal storage tank was in use. I observed
no visible emissions or detected any odors from the horizontal storage tank at the time of the
inspection.
rS7—liquid asphalt cement storage tank2Q 0102 (g)(4) No No
0,000 gallons capacity)
The liquid asphalt is stored in a horizontal tank(ID No. IES7; 30,000 gallons). The sand and
aggregate materials are mixed with the liquid asphalt,reclaimed asphalt product(rap) and any
particulate matter("dust")from the inertial separator and bagfilter(ID No. CD-1)in the rotary mixer
drum.

Reeves Construction Company—Bonds Asphalt Plant
April 26,2022
Page 6
Observed.No tanker truck unloading of liquid asphalt into the horizontal storage tank was occurring
at the time of the inspection. The liquid asphalt in the horizontal tank was in use. I observed no
visible emissions or detected any odors from the horizontal tank at the time of the inspection.
6. Observations of air emission sources and control devices not listed on the current permit:
a. The diesel fuel for the front end loader and service trucks is stored in one aboveground
tank with a capacity of 1,000 gallons. The aboveground storage tank is exempt per 15A
NCAC 2Q .0102 (g)(4).
b. A release agent is sprayed in the beds of trucks prior to the asphalt loadout process. The
release agent stops the bonding of the asphalt to the beds of the trucks. This process is
exempt per 2Q .0102(g)(14)(B).
7. Compliance with specific permit conditions and limitations:
a. Condition A. 2. Permit Renewal and Emission Inventory Requirement—The permittee at
least 90 days prior to the expiration date of this permit shall request permit renewal by
letter with an application form and submit the air pollution emission inventory report
with certification sheet for 2022 calendar year to MRO DAQ.
Observed. I informed Mr.Adams that the air permit expires on July 31,2023 and the air
pollution emission inventory report with certification sheet for 2022 calendar year must
be submitted with the permit renewal request. I advised Mr. Adams to contact Jennifer
Manning if he has any questions regarding air quality permitting. Compliance with this
stipulation is indicated.
b. Condition A. 3. Particulate Control Requirement-As required by 15A NCAC 2D .0506
"Particulates from Hot Mix Asphalt Plants,"
i. Particulate matter emissions resulting from the operation of a hot mix asphalt
plant shall not exceed allowable emission rates.
ii. Visible emissions from stacks or vents at a hot mix asphalt plant shall be less
than 20 percent opacity when averaged over a six-minute period.
iii. Fugitive non-process dust emissions shall be controlled as required by 15A
NCAC 2D .0540 "Particulates from Fugitive Dust Emission Sources."
iv. Fugitive emissions for sources at a hot mix asphalt plant not covered elsewhere
under this Rule shall not exceed 20 percent opacity averaged over six minutes.
Observed.During the inspection,I observed no visible or fugitive emissions from the
facility. Compliance with allowable emissions rate was indicated during the permit
application process.

Reeves Construction Company—Bonds Asphalt Plant
April 26,2022
Page 7
C. Condition A.4. Particulate Control Requirement-As required by 15A NCAC 2D .0515
"Particulates from Miscellaneous Industrial Processes,"particulate matter emissions from
the lime silo (ID No. ES2) shall not exceed allowable emission rates.
Observed.The lime silo has not been installed at this facility. The particulate matter
emissions from the lime silo will not exceed the allowable emission rates as indicated in
the permit review. Compliance with this stipulation was indicated during the permit
application process.
d. Condition A. 5. Sulfur Dioxide Control Requirement-As required by 15A NCAC 2D
.0516 "Sulfur Dioxide Emissions from Combustion Sources," sulfur dioxide emissions
from the combustion sources shall not exceed 2.3 pounds per million Btu heat input.
Observed. Per MRO memo"21) .0516 analysis"dated 04/10/97, compliance is indicated
for No. 1 fuel oil,No. 2 fuel oil,natural gas,butane,propane,and wood fuel. Compliance
with this stipulation was indicated during the permit application process.
e. Condition A. 6. Visible Emissions Control Requirement-As required by 15A NCAC 2D
.0521 "Control of Visible Emissions," visible emissions from the emission sources,
manufactured after July 1, 1971, are limited to 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.
Observed.The asphalt plant was in operation at the time of the inspection. I observed no
visible emissions from the exhaust of the vertical and uncapped bagfilter stack or any
other sources at this facility. Compliance with this stipulation is indicated.
£ Condition A. 7. 15A NCAC 2D .0524 "New Source Performance Standards" -For drum
mix type asphalt plant(ID No. ES1),the permittee must comply with all applicable
provisions including notification,testing,reporting,recordkeeping,and monitoring
requirements contained in Environmental Management Commission Standard 15A
NCAC 2D .0524 "New Source Performance Standards" (NSPS)as promulgated in 40
CFR Part 60, Subpart I, including Subpart A, "General Provisions."
i. NSPS Emissions Limitations-As required by 15A NCAC 2D .0524, the permittee
shall not discharge or cause the discharge into the atmosphere from any affected
source any gases which:
A. Contain particulate matter in excess of 90 mg/dscm(0.04 gr/dscf); or
B. Exhibit 20 percent opacity or greater.
Observed.The asphalt plant was in operation at the time of the inspection. I observed no
visible emissions from the exhaust of the bagfilter stack or any other sources at this
facility. Compliance with this stipulation is indicated.

Reeves Construction Company—Bonds Asphalt Plant
April 26,2022
Page 8
g. Condition A. 8.Notification Requirement-As required by 15A NCAC 2D .0535, states
that the permittee of a source of excess emissions that last for more than four hours and
that results from a malfunction, a breakdown of process or control equipment or any
other abnormal conditions, shall notify the Director or his designee of any such
occurrence by 9:00 a.m. Eastern time of the Division's next business day of becoming
aware of the occurrence.
Observed.Based on records review and the conversation with Mr. Adams,no excess
emissions have occurred at the facility. Compliance with this stipulation is indicated.
h. Condition A. 9. Fugitive Dust Control Requirements-As required by 15A NCAC 2D
.0540 "Particulates from Fugitive Dust Emissions Sources,"the permittee shall not cause
or allow fugitive dust emissions to cause or contribute to substantive complaints or
excess visible emissions beyond the property boundary. If substantive complaints or
excessive fugitive dust emissions from the facility are observed beyond the property
boundaries for six minutes in any one hour(using Reference Method 22 in 40 CFR,
Appendix A),the owner or operator may be required to submit a fugitive dust plan as
described in 2D .0540(f).
Observed.MRO DAQ has not received any fugitive dust emissions complaints regarding
this facility. Mr. Adams stated that Martin Marietta Materials,Inc. has a truck that is
utilized by this facility to water the unpaved areas at this asphalt plant. During the
inspection, I observed no fugitive emissions from the unpaved areas beyond the property
boundaries of this facility. Compliance with this stipulation is indicated.
i. Condition A. 10. Toxic Air Pollutant Emissions Limitation and Reporting Requirement-
Pursuant to 15A NCAC 2D .1100 "Control of Toxic Air Pollutants," and in accordance
with the approved application for an air toxic compliance demonstration,the following
permit limits in the table below shall not be exceeded. The permittee has submitted a toxic
air pollutant dispersion modeling analysis dated May 1, 2015 for the facility's toxic air
pollutant emissions as listed in the below table. The modeling analysis was reviewed and
approved by the DAQ Air Quality Analysis Branch(AQAB)on May 26,2015.Placement
of the emissions sources,configuration of the emission points,and operation of the sources
shall be in accordance with the submitted dispersion modeling analysis and should reflect
any changes from the original analysis submitted as outlined in the AQAB review memo
Affected Source(s) Toxic Air Pollutant FEmission
Limit
Natural gas/No. 2 fuel oil/recycled No. 2 fuel
oil/No. 4 fuel oil/recycled No.4 fuel oil-fired
aggregate dryer(72 million Btu per hour Benzene(71-43-2) 97.5 pounds
maximum heat input)with associated mixer per year
(ES1)
Natural gas/No. 2 fuel oil/recycled No. 2 fuel
oil/No. 4 fuel oil/recycled No. 4 fuel oil-fired 0.6975
aggregate dryer(72 million Btu per hour Formaldehyde (50-00-0) pounds per
maximum heat input)with associated mixer hour
(ES1)

Reeves Construction Company—Bonds Asphalt Plant
April 26,2022
Page 9
Natural gas/No. 2 fuel oil/recycled No. 2 fuel
oil/No. 4 fuel oil/recycled No.4 fuel oil-fired Nickel metal 0.34 pounds
aggregate dryer(72 million Btu per hour (Component of NIC) per day
maximum heat input)with associated mixer (7440-02-0)
(ES I)
hot mix asphalt storage silos(200 ton [0.975 pounds
maximum capacity) (ES3),hot mix asphalt Benzene(71-43-2)storage silo (200 ton maximum capacity) (ES4) r year
hot mix asphalt storage silos(200 ton 0.0189
maximum capacity) (ES3),hot mix asphalt Formaldehyde(50-00-0) pounds per
storage silo (200 ton maximum capacity) (ES4) hour
truck loadout operation(ES5) Benzene(71-43-2) 0.54 pounds
per year
0.000823
truck loadout operation (ES5) Formaldehyde (50-00-0) pounds per
hour
i. Restrictions-To ensure compliance with the above limits,the following restriction
shall apply:
A. The amount of asphalt produced shall not exceed 250,000 tons per year,
regardless of which fuel type is combusted.
Recordkeeping Requirements -The following recordkeeping requirements apply:
i. Recordkeeping and reporting requirements contained in synthetic minor
stipulation 15A NCAC 2Q .0315 will be used to demonstrate compliance
with the above limits.
Observed.This facility performed a modeling analysis on a facility-wide basis for
emissions of benzene,formaldehyde, and nickel metals since these toxic air pollutants
were above the TPER limits. The modeling was based on 250,000 tons of asphalt
production per year.
The initial startup of this plant for asphalt production occurred on December 9,2016.
This plant produced 2,102 tons of asphalt for December 2016. The maximum annual
asphalt production rate of 250,000 tons per year was not being exceeded.
The asphalt production records are being kept by this company. Based on the asphalt
production rate of 69,089 tons during calendar year 2021,the asphalt plant will not
exceed the modeled limits. Compliance with this stipulation is indicated.
j. Condition A. 11. Control and Prohibition of Odorous Emissions-As required by 15A
NCAC 2D .1806 "Control and Prohibition of Odorous Emissions," the permittee shall not
operate the facility without implementing management practices or installing and
operating odor control equipment sufficient to prevent odorous emissions from the
facility from causing or contributing to objectionable odors beyond the facility's
boundary.

Reeves Construction Company—Bonds Asphalt Plant
April 26,2022
Page 10
Observed. MRO DAQ has not received any odor complaints concerning this facility.
During the inspection,the asphalt plant was in operation. I detected a noticeable asphalt
odor at this facility,which is consistent with normal operations. Compliance with this
stipulation is indicated.
k. Condition A. 12. Limitation to Avoid 15A NCAC 2Q .0501-Pursuant to 15A NCAC 2Q
.0315 "Synthetic Minor Facilities,"to avoid the applicability of 15A NCAC 2Q .0501
"Purpose of Section and Requirement for a Permit," as requested by the permittee,
facility-wide emissions shall be less than the following:
Pollutant Emission Limit
(Tons per consecutive 12-monthperiod)
PM10 100
SO2 100
CO 100
i. Operations Restrictions - To ensure emissions do not exceed the limitations
above,the following restrictions shall apply:
A. The amount of asphalt produced shall be less than 250,000 tons per
consecutive 12-month period regardless of fuel type. This limit is based
on the limit used to demonstrate compliance with toxics.
B. The sulfur content of the No. 2 fuel oils and No. 4 fuel oils shall be
limited to 0.5%and 2.0% sulfur by weight,respectively.
D. If multiple fuels are used, emissions should be determined using the sum
of the individual emissions rates.
Observed.This plant produced 69,089 tons of asphalt when combusting only
natural gas during calendar year 2021. There is no fuel oil storage at this facility.
Compliance with this stipulation is indicated.
ii. Inspection and Maintenance Requirements-
A. Fabric Filter Requirements includingcartridge artridge filters,baghouses, and
other da filter particulate collection devices-As required by 15A
NCAC 2D .0611,particulate matter emissions shall be controlled as
described in the permitted equipment list. To comply with the provisions
of this permit and ensure that emissions do not exceed the regulated
limits,the permittee shall perform periodic inspections and maintenance
(I&M)as recommended by the manufacturer. In addition,the permittee
shall perform an annual(for each 12 month period following the initial
inspection)internal inspection of each fabric filter system.
iii. Recordkeeping Requirements-
A. The permittee shall record monthly and total annually the following:

Reeves Construction Company—Bonds Asphalt Plant
April 26,2022
Page 11
1. The tons of asphalt produced for each fuel type.
2. The facility-wide CO and SO2 emissions.
B. Fuel supplier certification shall be kept on-site and made available to
DAQ personnel upon request.
C. A log book(in written or electronic format) shall be kept on site for each
control device and made available to Division of Air Quality personnel
upon request. The permittee shall record all inspection,maintenance
and monitoring requirements listed above in the logbook.Any variance
from the manufacturer's recommendations shall be investigated with
corrections made and date of actions recorded in the log book.
Observed.The log book provided by Mr.Adams indicated that the inspection
and maintenance activities are being conducted by this company. This company
conducted the internal inspections of the bagfilter on 11/17/21;4/12/21; 6/27/20;
4/27/20; and 2/27/20. The inspections of the bagfilter are within the 12 month
period time frame as indicated by this condition.
This facility is required by General Condition and Limitation B. 2. of the current
permit to keep records on site for a minimum of two years. The records of the
bagfilter inspection and maintenance activities are being kept by this company
for more than two years.
The records of the asphalt production and associated fuel are kept by this
company on a daily basis. The monthly and annual asphalt production records
and calculated emissions data, CO and S02,are compiled by Mr. Jake Flores,
environmental manager.
The asphalt plant only combusts natural gas.No fuel oil is combusted or stored at
this facility. Compliance with this stipulation is indicated.
iv. Reporting Requirements -Within 30 days after each calendar year,regardless of
the actual emissions,the permittee shall submit the following:
i. emissions and/operational data listed below. The data should include
monthly and 12 month totals for the previous 12 month period.
A. The tons of asphalt produced for each fuel type,
B. The facility-wide CO and S02 emissions.
Observed. On January 20,2022,this office received the annual report from this
company for 2021 calendar year. This company reported the following
information: 5.01 tons of carbon monoxide(CO) emissions; 0.009 tons of sulfur
dioxide (S02) emissions; 69,089 tons of asphalt produced while combusting
natural gas during 2021 calendar year. Compliance with this stipulation is
indicated.

Reeves Construction Company—Bonds Asphalt Plant
April 26,2022
Page 12
1. Condition A. 13. Limitation to Avoid 15A NCAC 2D .0530 "Prevention of Significant
Deterioration" -In accordance with 15A NCAC 2Q .0317,to comply with this permit and
avoid the applicability of 15A NCAC 2D .0530 "Prevention of Significant Deterioration,"
as requested by the permittee, emissions shall be limited as follows:
Affected Source(s) Pollutant Emission Limit
Tons Per Consecutive 12-month Period
Facility Wide S02 250
Observed.The facility-wide SO2 emissions were reported by this company as 0.009 tons
during 2021 calendar year.Compliance with this stipulation is indicated.
M. Condition A. 14. Vendor Supplied Recycled No(s). 2 and 4 Fuel Oil Requirements - In
accordance with Rule 2Q .0317, the permittee is avoiding the applicability of Rule 2Q
.0700 by using recycled fuels which are equivalent to their virgin counterparts. The
permittee is allowed to use the recycled fuel oil(s) supplied by a DAQ-approved vendor
as follows:
i. Specifications -The recycled fuel oils have to be equivalent to unadulterated
fossil fuel by meeting the following criteria:
Constituent/Pro er Allowable Level
Arsenic 1.0 ppm maximum
Cadmium 12.0 ppm maximum
Chromium 15.0 ppm maximum
Lead 100 ppm maximum
Total Halogens 1000 ppm maximum
Flash Point
No. 2 100°F minimum
No.4 130°F minimum
Sulfur
No. 2 0.5%maximum(by weight)
No.4 2.0%maximum(by weight)
Ash 1.0%maximum
ii. The permittee is responsible for ensuring that the recycled fuel oil(s), as received
at the site, meet(s) the approved criteria for unadulterated fuel. The permittee is
held responsible for any discrepancies discovered by DAQ as a result of any
sampling and analysis of the fuel oil(s).
iii. Recordkeeping Requirements - The permittee shall maintain at the facility for a
minimum of three years, and shall make available to representatives of the DAQ
upon request, accurate records of the following:
A. The actual amount of recycled fuel oil(s) delivered to, and combusted at
the facility on an annual basis.

Reeves Construction Company—Bonds Asphalt Plant
April 26,2022
Page 13
B. Each load of recycled fuel oil received shall include the following:
1. A delivery manifest document clearly showing the shipment
content and amount, its place and date of loading, and place and
date of destination.
2. A batch specific analytical report that contains an analysis for all
constituents/properties listed above. Analytical results of the
samples representative of the recycled oil shipment from the
vendor shall be no more than one year old when received.
3. Batch signature information consisting of the following: a batch
number, tank identification with batch volume of recycled oil,
date and time the batch completed treatment, and volume(s)
delivered.
4. A certification indicating that the recycled fuel oil does not
contain detectable PCBs(<2ppm).
iv. The DAQ reserves the right to require additional testing and/or monitoring of the
recycled fuel oil(s) on an annual basis or without notice.
Observed.The asphalt plant combusts only natural gas. There is no fuel oil storage at
this facility. The annual report for 2021 calendar year indicated that no recycled fuel oils
had been combusted in the rotary drum aggregate dryer at this facility. Compliance with
this stipulation is indicated.
n. Condition A. 15. Toxic Air Pollutant Emissions Limitation Requirement-Pursuant to
15A NCAC 2Q .0711 "Emission Rates Requiring a Permit" for each of the below listed
toxic air pollutants (TAPs),the permittee has made a demonstration that facility-wide
actual emissions,where one or more emission release points are obstructed or non-
vertically oriented, do not exceed the Toxic Permit Emission Rates(TPERs) listed in 15A
NCAC 2Q .0711(a). The facility shall be operated and maintained in such a manner that
emissions of any listed TAPS from the facility, including fugitive emissions,will not
exceed TPERs listed in 15A NCAC 2Q .0711(a).
Acute Permit
Carcinogens Chronic Systemic Acute Review R00
Pollutant (lb/yr) Toxicants Toxicants Irritants
(lb/day) (lb/hr) (lb/hr)
Benzo(a)pyrene(Component 0.00441 lb/yr
of 83329/POMTV& 2.2
56553/7PAH) (50-32-8) 1 _F
Carbon disulfide(75-15-0) F 3.9 F 0.0134 lb/day
Hexane,n-(110-54-3) 23 F- 0. 59 lb/day
Hydrogen sulfide(7783-06-4) 1.7 ��0.2591b/day
MEK(methyl ethyl ketone,2- 78 22.4 0.145 lb/day

Reeves Construction Company—Bonds Asphalt Plant
April 26,2022
Page 14
butanone) (78-93-3) F—FF—6.03E-03 lb/hr
- F_ ay
Methyl chloroform(71-55-6) 250 64 0.08E-0 lb/hr
Methylene chloride(75-09-2) 1600 7- ..39 F 0.00823 lb/yr
7.40E-06 lb/hr
Perchloroethylene 0.0801 lb/yr
(tetrachloroethylene) (127-18- 13000
4)
Phenol(108-95-2) F_ 7- ..24 F 9.05E-04 lb/hr
Styrene(100-42-5) 1 F_F 2.7 F—2.16E-04 lb/hr
__[_
15.75
Toluene (108-88-3) 98 14.4 .656 lb/day
06561b/hr
Xylene(mixed isomers) 1.30 lb/day
(1330-20-7) F57 16.4 0.0543lb/hr
Observed.The TPER limits for 2Q .0711(a) apply for the above listed pollutants because
these air toxics are emitted as fugitive emissions from the truck loadout and silo filling.
The actual emission rates were obtained from the asphalt emissions calculator
spreadsheet based on a production of 250,000 tons per year of asphalt at a maximum
process rate of 225 tons per hour using recycled No.4 fuel oil(worst case)based in an
operation schedule of 24 hours per day, 50 weeks per year and 2,000 hours per year.
Compliance with the respective TPER limits is shown in the above referenced table.
This company has asphalt production records to verify that the TPERs are not being
exceeded. Based on the asphalt production rate of 69,089 tons during 2021 calendar year,
this asphalt plant will not exceed the TPERs. Compliance with this stipulation is
indicated.
o. Condition A. 16. "Toxic Air Pollutant Emissions Limitation Requirement"-Pursuant to
15A NCAC 2Q .0711 "Emission Rates Requiring a Permit" for each of the below listed
toxic air pollutants (TAPS),the permittee has made a demonstration that facility-wide
actual emissions,where all emission release points re unobstructed and vertically
oriented,do not exceed the Toxic Permit Emission Rates (TPERs)listed in 15A NCAC
2Q .0711(b). The facility shall be operated and maintained in such a manner that
emissions of any listed TAPS from the facility, including fugitive emissions,will not
exceed TPERs listed in 15A NCAC 2Q .0711(b).
Chronic Acute Acute Permit Review
Pollutant Carcinogens Toxicants Systemic Irritants R00
(lb/yr) (lb/day) Toxicants (lb/hr)
(lb/hr)
Acetaldehyde(75-07-0) 1 F—F— 28.43 10.293 lb/hr
Acrolein(107-02-8) 1 F_F_ 0.08 10.005851b/hr
Arsenic&Compounds 1 0.194 F 10.14 lb/yr

Reeves Construction Company—Bonds Asphalt Plant
April 26,2022
Page 15
(total mass of elemental
AS, arsine and all
inorganic compounds)
(ASC (7778394))
Cadmium Metal, 0.103 lb/yr
elemental,unreacted 0.507
(Component of CDC)
(7440-43-9)
Chromium(VI) Soluble 0.00243 lb/day
Chromate Compounds 0.026
(Component of CRC)
(So1CR6)
Hexachlorodibenzo- 3.25E-071b/yr
p-dioxin 1,2,3,6,7,8 0.007
(57653-85-7)
Hydrogen chloride 0.0473 lb/hr
(hydrochloric acid) FO 74
(7647-01-0)
Manganese& 0.0416 lb/day
compounds (MN —T—T—]
F1.3
— —F
Mercury,vapor 0.01401b/day
(Component of HGC) Fo
.025
(7439-97-6)
Tetrachlorodibenzo-p- 5.25E-08 lb/yr
dioxin,2,3,7,8-
(Component of CLDC 0.0002767
& 83329/POMTV)
(1746-01-6)
Observed.The air toxics that are only emitted from the aggregate dryer and mixer are
subject to 2Q .0711(b)because the emission release point is unobstructed and vertically
orientated as indicated in the permit application. The actual emission rates were obtained
from the asphalt emissions calculator spreadsheet based on a production of 250,000 tons
per year of asphalt at a maximum process rate of 225 tons per hour using recycled No.4
fuel oil(worst case)based in an operation schedule of 24 hours per day, 50 weeks per
year and 2,000 hours per year. Compliance with the respective TPER limits is shown in
the above referenced table.
This company has asphalt production records to verify that the TPERs are not being
exceeded. Based on the asphalt production rate of 69,089 tons during 2021 calendar year,
this asphalt plant will not exceed the TPERs. Compliance with this stipulation is
indicated.
8. NSPS/NESHAP Review:
The asphalt plant is subject to NSPS Subpart I - Standards of Performance for Hot Mix Asphalt
Facilities.

Reeves Construction Company—Bonds Asphalt Plant
April 26,2022
Page 16
The portable rap crushing, screening, and conveying operations conducted at this facility is
subject to Subpart 000 — Standards of Performance for Nonmetallic Mineral Processing Plants.
No crushing, screening, or conveying equipment was on-site during the inspection.
Any portable diesel-fired engines operated at this facility are not subject to NSPS Subpart IIII(41)
and NESHAP Subpart ZZZZ (4Z), since these engines are classified as a "nonroad engine"
according to 40 CFR 1068.30 and covered under Title 11 of the Clean Air Act.
This company has no boilers, emergency/peak shaving generators, fire pump engines or gasoline
storage tanks at this facility.
The asphalt plant is not subject to MACT Subpart LLLLL—Asphalt Processing and Asphalt
Roofing Manufacturing.
The natural gas-fired hot oil heater(ID No. IES5)is excluded from the definition of a boiler as
specified in 63.11237 of National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Industrial, Commercial, and Institutional Boilers Area Sources(40 CFR Part 63, Subpart
JJJJJJ or 6J). Therefore,this natural gas-fired process heater is not subject to the area source
boiler NESHAP Subpart 6J.
9. Summary of changes needed to the current permit:
None.
10. Compliance assistance offered during the h�pection:
None.
11. Section 112(r) aPplicabili1y:
This facility does not appear to be subject to the requirements of the Chemical Accident Release
Prevention Program, Section 112(r)of the Clean Air Act.
12. Compliance determination:
Based on my observations, this facility appeared to be in compliance with the applicable air
quality regulations at the time of the inspection.
DLC:Ims
c: MRO File
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