AQ_F_1700005_20210507_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: 05/17/2021
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
NAILS: 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:
Inspection Date 05/07/2021
LAction
Name Blair Palmer
Inspector's Signature: DMMtatus Operating
Status Compliance- inspection
FCE
Date of Signature: 05/20/2021 esult Compliance
Total Actual emissions in TONSIYEAR:
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 Cinpounds)
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
.........S1................. S Description
.. ............ ................. .... ........ p .. ....... . .........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/ Bagiilter
ESl No. 4 Fuel Oil/Used No. 4 Fuel Oil-fired CD1 (10,842 square feet
(NSPS) (116 million Btu per hour maximum heat input) of filter area)
Double Barrel Drum Mixer
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) N/A N/A
........................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................
ES3 Truck Loadout Operation N/A N/A
_............. ...:....._.....:....._..:..._......_...._............:.......:.:......._...:.:...........:...:.....:.,.,.......:...............................................,.__.._...._.............:.....:.....:......................................._..:...:......:._.............._...__..:
ES2.5 RAP/RAS Handling System N/A N/A
Insignificant/Exempt Activities:
Exemption Source of
Source _� Source of Title V Pollutants?
Regulation TAPs?
I-1 -Natural Gas/No. 2 Fuel Oil-fired -
Hot Oil Heater i 2Q .0102 (h)(1)(A) Yes i Yes
(1.6 million Btu per hour maximum heat input)
........................................................................................................................................................_.
1-2-Fuel Oil Storage Tank i
(1,000 gallons capacity)
....::...... ......... .. ......................_......_:..............:...........:.............:.:...............................:...:...:....:.......:.....:.......:.:...:.__............
I-3 -Recycled Fuel Oil Storage Tank
(25,000 gallons capacity)
.......................... _......._....................................................._................._:_....:......................._.................._...............................................:....:...
I-ES6 -Liquid Asphalt Storage Tank 2Q .0102 (g)(4) Yes Yes
(30,000 gallons capacity)
....................................................................................................................._.................................................._............................................_._........
I-ES7 -Liquid Asphalt Storage Tank
(30,000 gallons capacity)
I-ES8 -Liquid Asphalt Storage Tank
(1,000 gallons capacity) t
I-ES9-Electric furnaces
used for QA/QC testing activities 2Q .0102 (g)(3)(A) Yes Yes
Introduction/Discussion:
On May 5,2021,Mr. Blair Palmer,Environmental Specialist II of the DAQ WSRO, contacted Mr.Rand(Julian) Stinson,
HSE of Piedmont Asphalt,LLC via telephone about all COVID-19 related information at this permitted location. The
purpose was to establish safe guidelines and ask the facility about their COVID-19 requirements and any possible
COVID-19 cases for a May 7,2021 Full Compliance Evaluation(FCE)or also known as a Division of Air Quality(DAQ)
inspection. Based upon the above noted telephone call,Mr. Palmer and DAQ management concluded that it would be
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acceptable to proceed with the FCE. All permit required records were sent to Mr. Palmer via email prior to the inspection.
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. Typically,this plant does not operate in January and February based
upon records review. No new equipment has been added since the last inspection conducted on July 17,2020.
Production has been relatively steady.
On May 7, 2021,Mr. Palmer met with Mr. Stinson and Douglas Dawson, General Manger for Piedmont Asphalt to
conduct the scheduled inspection. This facility operates a 350 ton/hr(max)batch hot mix asphalt plant producing asphalt
for residential and commercial purposes. The plant had been scheduled to operate prior to the inspection, but it was
mostly not in operation during the inspection, except for I-1.
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 the 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:
Safety vest should be always 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 is dropped onto a conveyor. The conveyor then
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 then enters the mixing area in the outer region of the
drum. Once in the mixing area,asphalt cement is injected. Approximate mixing proportions are: 95% aggregate and 5%
asphalt cement. Reclaimed Asphalt Pavement(RAP),which is sorted from a sizing screen,also is conveyed into the
mixing area of the drum. RAP typically can range from 15%to 25% of the mix. Emissions from this process are
controlled with one large bagfilter(CD I). Pulsed air causes the collected particulate to fall into the bag filter's collection
hopper where it is returned into mixing area of the drum via 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 generally operates at 200 tons/hour
and a RAP mixture of 20-25%. The plant is now permitted for use Reclaimed Asphalt Shingles(RAS),as part of ES 2.2
and Mr.Dawson stated that the facility intends to use the RAS soon.
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. 1-2 contains off-road diesel fuel used
for the facility's front-end loader. The asphalt heater was observed combusting natural gas,and the facility is no longer
using any fuel oil, according to last inspection report and it was 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 is 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
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building used for this asphalt mixture laboratory(I-ES-9)located towards the front of the property. There are currently two
small electric fired furnaces used for testing physical properties of the asphalt mix types, including the aggregate. Both
furnaces do have exhaust ductwork that vent outside via the back section of the building and each oriented horizontally thru
the building. Neither one 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)for the purposes of crushing Reclaimed Asphalt Pavement(RAP). Mr.Palmer inquired about this equipment as part
of this FCE,and it appears that all necessary testing per NSPS Subpart 000,"Standards of Performance for Nonmetallic
Mineral Processing Plants"using EPA Method 9 was conducted on April 23,2015 in Virginia based on information
received via email. Mr. Stinson indicated that the crusher and associated equipment does move from other Piedmont
Asphalt locations in NC and VA. RAP was last crushed on site in July and August for a total of 39,250 tons. The crushing
was performed by Adams Construction(a joint venture with Piedmont). 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 for testing
purposes is in the source file.
Inspection(including permitted items and exempt sources):
The asphalt plant was not in operation during the inspection and the plant fires entirely only on natural gas at the current
time. The bagfilter system has a recorded pressure drop and it normally operates at 1-2 inches of water column.
Permit Conditions:
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. Future compliance is anticipated. A reminder letter from the WSRO will mailed out approximately 6.5
months before the expiration.
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 and requires
that fugitive dust emissions be controlled as required by 15A 2D .0540. For discussion on fugitive dust emissions see the
condition A.9 discussion below. 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 both the PM limit and opacity requirement since the
bagfilter is installed and appears to be well maintained. The allowable emissions limit per 2D .0506 is 54.6 lb/hr(based
on 271.4 lb/hr production)based upon a SSCB memo dated January 26, 2015. The facility had tested at 1.241b/hr.
Compliance is indicated.
Condition AA pertains to 2D .0516,"Sulfur Dioxide Emissions from Combustion Sources." This regulation limits the
emissions of SO2 from any source of combustion that is discharged from any vent, stack, or chimney to 2.3 pounds of SO2
per million Btu input. The drum mixer(ID No. ES1)and the exempt hot oil heater(1-1)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 S02/ton asphalt)x(350 ton asphalt/hr)- 116 MMBTU/hr=0.010 lb SO2/MMBtu
S02,No,2 F.o. _(0.011 lb S02/ton asphalt)x(350 ton asphalt/hr)_ 116 MMBTU/hr=0.033 lb SO2/MMBtu
S02,No,4 F.o. _(0.058 lb S02/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.
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The S02 emissions from the drum mixer firing NG,No.2 fuel oil or No. 4 fuel oil are less than 2.3 lb S02/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:
S02 NG=(0.6 lb S02/MMft'NG)x(ft3 NG/1,020 Btu)=0.0006 lb S02/MMBtu
S02 No.2 F.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 Btulft and the No. 2 fuel oil heat value is 140 MMBtul103 gal. The
default sulfur content for No. 2 fuel is 0.5%, therefore S= 0.S 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. Compliance with 2D .0521 is indicated.
Condition A.6 contains the 2D .0524 requirements associated with"New Source Performance Standards." It specifically
pertains to 40 CFR 60, Subpart 1, including Subpart A"General Provisions." To comply with this rule,the facility is
required to 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 result of a May 19, 2017 performance test.
A July 18, 2017 DAQ Stationary Source Compliance Branch(SSCB)memo provides the following:
Pollutant EPA Emissions Emissions Limit Regulation Compliance
MethoFilterable PM 5 4.41 mg/dscm 90 mg/dscm 60 Subpart I Yes
0.5 lb/hr
Condensable PM 202 11.76 mg/dscm
1.3 6 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(21) .0535)addresses"Notification Requirement." The facility is to notify the director of DAQ of a
malfunction or breakdown resulting in excess emissions that lasts more than four hours . No notifications have been
received and plant personnel indicated that there have been no plant upsets of any kind since the last DAQ inspection.
Compliance is indicated.
Condition A.8 pertains to the 15A NCAC 2D .0540 fugitive dust control requirement. Most of the higher traffic area are
paved. The facility utilizes water trucks to wet any unpaved drive areas during periods of dry weather. 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 quarry called
Southside Materials, LLC-Shelton Quarry(1700009),but this quarry operates intermittently. Mr. Palmer did not observe
any dust near the property boundaries or adjacent vegetation. Compliance with this condition is likely indicated.
Condition A.9 per 2D .0611,"Fabric Filter Requirements"requires inspection and maintenance on the facility's bagfilter
(BH-1), including performing an internal inspection at least once every 12 months. The last internal inspection for the
bagfilter was on February 25, 2021 and all bags were in good condition,with no visible signs of holes. The inspection
prior to the February 25,2021,was conducted on December 6,2020 and no visible signs of holes were found. Extra bags
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are kept onsite and according to Mr. Stanly, a total of ten bags are currently in inventory. The ductwork also appeared to
be in good condition based upon Mr. Palmer's observations during the inspection. 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
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 consecutive 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 consecutive 12-
month period. The facility shall also record monthly and total annually the amount of asphalt produced. A review of the
records showed that the facility was recording monthly production information and was up to date on on-site records.
Thus far in CY 2021 and up thru March 31st, a total of 6,901.56 tons were produced. The facility is also required to
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 2020)was received on January 26,2021. The report showed a total of 110,837
tons of asphalt produced. In comparison,the facility reported a total of 138,323 tons of asphalt in CY 2019. The CY
2020 report also showed facility wide CO emissions of 7.34 tons and SO2 emissions of 0.00 tons. 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 their emissions of S02 to below 250 tons per
consecutive 12-month period. The facility has demonstrated that the SO2 emissions are well below the 250 tons per
consecutive 12-month period.
Condition A.13 lists the"Recycled Asphalt Shingle Requirements." The facility has not been using recycled asphalt
shingles and this permit condition was added during revision R21. This condition contains the requirements for 2Q .0317
to avoid the applicability of 2Q .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
who is 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 is required record the actual 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 that contains an 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 indicating that the recycled shingles were sampled in accordance with best practices and
tested according to appendix E, 40 CFR Part 763, Section 1 and do not contain ACM or are otherwise asbestos-
free as determined by PLM prior to grinding.
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Based on review of records by this permitted facility, no shingles have been received yet. Mr. Palmer went over this new
permit requirement with Mr. Dawson during the inspection. Compliance is indicated.
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 that the facility receives to meet the approved criteria for unadulterated fuel. The
recycled fuel oil must meet the following requirements:
Constituent/Property Allowable Level
Arsenic 1.0 ppm maximum
Cadmium � � 2.0 ppm maximum
_. .. ___:----.........__:......._....__..__.:.:..m._..:....:............._...........:...:............_.. ...:...._......._...........:..._.m_.........._.... _......_......................................._._........_.................._.............:..__..__......_....._........................_.................................................................................................._....
i
Chromium 5.0 ppm maximum
Lead 100 ppm maximum
........................................................................_._..............................................................................................................._....................._....................................................................................................................................
Flash Point(No. 2 fuel oil) 100 F minimum
r. . _ o
i
Flash Point(No. 4 fuel oil) 130°F minimum
......................._..............................................................................................................................................................................................__..........................................................._.........
......................_._.....
......................,......... ..._......._..................................................................................................................................
t Sulfur(No. 2 fuel oil) 0.5 %maximum (by weight)
Sulfur(No. 4 fuel oil) 2.0%maximum (by weight)
Ash I 1.0%maximum
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 records provided by plant personnel
and discussion during the FCE,this facility has not received any recycled No. 4 fuel oil since the last inspection or in
many years. Compliance with this condition is indicated.
WSRO-DAQ Compliance History (within the last five years):
No Notice of Deficiency(NOD)or Notice of Violation(NOV)has been issued to this permitted facility. There are also
no dust or odor complaints logged or received in the WSRO for the permitted location.
Permit Discussion:
• ES2.3 is no longer on-site and there are no plans on replacing the equipment.
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
any 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 on-site. There is also no gasoline dispensing equipment at this plant.
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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
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 S02
and CO emissions, after controls/limits, are in accordance with the Synthetic Minor limit."
Potential Emissions
Expected (tons/year)=, ..
Pollutant Actual Emissions
Before
(tons/year) Controls/Limits
After Controls/Limits
I
�.._.�. PM � ._ 39.09 [_ _~42,959.89 �_ . 79.10
PM1 oo —[ ._.-16.87 F 9,974.74___µ F— � 45.15
�_...��....... ..���_.�.. _ _�. �._._. ...._.... ��.��_ ._�__.� �.��� ._.W..� ._..�.. _..._ ......... .�.� .w.. ......... _._...
} S02 ( 39.63 ; 156 93 <100
NOx �20.82 � 85.34 85.34
CO 48.28 � 203.46 <100
j VOC 17.35 72.01 i 72.01
HAP Totai 10.80 _F 15.64 �� 15.64
_..............w__._.............._.._...._...................._. .............................._.. ............._._....................._._..�__..._..........._._......... w_.......__.............. .... ......_.._.._..........
..............
__........
__ .__..
1lAPHighest(Formaldehyde) ( 1.15 �...... ..._.._..W 4.88 _.. 4.88
Conclusion:
Based on upon this FCE,the permitted facility appears to be in compliance with all applicable air quality rules and
standards.
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