AQ_F_0500008_20200918_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: 09/18/2020
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: 8 1 d 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
Project Manager President Sr.Project Manager
[phone]' [phone] [phone]
Compliance Data
Comments:
Inspection Date 09/18/2020
/- Inspector's Name Robert Barker
Inspector's Signature: w2✓ / qA'11LJ61 Operating Status Operating
Compliance Code Compliance-inspection
Action'Code FCE
Date of Signature: 9/� D MTH On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2016 1.40 4.40 2.50 )1.90 5.30 1.0000 249.80
2011 1.26 2.16 1.56 0.1106 3.47 1.26 45.10 l`
Hi hest HAP Emitted inpounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution bate
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

Permitted Emission Sources:
....... m._.,, ..�....m .. ........ ........ .:. ..m....,... .m...... ...: ..,..
E Emission Emission Source Control Control S stern -
i SourceID'. Descrigtion System ID Descpt on
�� .: .. :. �.:::._: ........ ��__ ...._.. ......_..,_...... �.....�� ........ _..�._
. ....._7 _.....
One drum mix,hot mix asphalt plant(200 tons per hour maximum rated capacity)including:
a HMAPI� atural gas/No. 2/recycled No.4 fuel oil-fired rotary drum Bagfilter(8,679 square
(NSPS) mix asphalt plant(96.8 million Btu per hour burner capacity) CS-1 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 w N/A
TL-1 Truck load-out operation N/A N/A
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:
j Source Exemption Source of Source of Title V
Regulation TAPS? Pollutants?
1-3 Fuel oil aboveground storage tank(250 gallon capacity)
....... .... .. .....:. ......: ...... . . -. --....__.......
I 4 Fuel oil above ground storage tank(10,000 gallon capacity)
Q .0102 Yes
I-5a-Liquid asphalt above,ground storage tank(20,000 gallon capacity) 2 Yes
I-7 Fuel oil above ground storage tank(10;000 gallon capacity)
(g)(4)
I-8 -Propane above ground storage tank(100 gallon capacity) F No
Introduction
On September 18,2020,Robert Barker,Environmental Engineer of the DAQ-WSRO, contacted Steven Gentry, Plant
Operator,at Maymead Materials,Inc.-Jefferson Plant'and conducted a full compliance inspection. It should be noted
that due to the COVID-19 restrictions and while the facility was inspected, some of the records were emailed to Mr.
Barker by Mr. Sean Mackey, Senior Project Manager. The authorized, invoice,facility,and technical contacts have not
changed. The plant is a drum mix asphalt plant with a maximum capacity of 200 tons per hour. The facility only operates
a few months out of the year and only when asphalt is needed in that immediate area. The facility was previously
inspected(PCE)on April 27,2020 by this inspector,and found to be operating in compliance.
Safety
The only protective equipment that may be required at the facility is safety glasses, ear protection, safety shoes, hardhat,
and a reflector vest.' During the inspection Mr. Barker adhered to all COVID-19 related precautions as required by DAQ.
Applicable Regulations
Applicable'regulations listed in the permit are 2D .0202, 2D .0503,2D .0506,2D .0516,2D .0521,2D .0524(40 CFR 60,
Subpart I),2D .0535,'2D.0540,2D .0605,2D.0611,2D .1100, 2D .1806, 2Q .0315 2Q .0317(21) .0530 and 2Q .0700
Avoidance)and 2Q.0711. The facility is not subject to the RMP requirements of the Section 112(r)program since it does
not use or store any of the regulated chemicals in quantities above the threshold levels in the rule. It should be noted that
the facility is subject to the General Duty clause of the Section 112(r)program.
Stack Tests
A stack emissions test was performed at this facility on July 30,2014 to demonstrate compliance with 40 CFR Part 60,
Subpart 1. The test results,which demonstrated compliance,are summarized in the table below.DAQ Stationary Source
Compliance Branch(SSCB)approved the test results on December 16,2014.
2

x d s
2 Pollutants s Test P�salt }�tss omp cc
t r c t .;��, S.S''
Filterable PM 23 m /dscm 90 m /desm 60 Subpart I Yes
2.39 lbs./hr. --- --- ---
Condensable PM 1.20 lbs./hr. -- -- ---
Total PM 3.59 lbs./hr. 45.03 lbs./hr. 2D .0506 Yes
Visible Emissions 0%Greatest 6-min average 20% 60 Sub art I Yes
Discussion
The facility is permitted for a natural gas/No. 2/recycled No.4 fuel oil-fired rotary drum mix asphalt plant(HMAPIa).
During the inspection,the asphalt plant was combusting natural gas and operating at 135 tons per hour. The asphalt that
was being produced contained about 21%RAP, The asphalt plant has a bagfilter(CS-1)as a control device. The pressure
drop across the bagfilter was at 1.5"with a stack temperature of 290°F. Asper 2D .0506,the plant is required to comply
with the allowable particulate emission rate,opacitylimit, and control fugitive dust.emissions(21) .0540). The facility
has an opacity limit of 20%when averaged over a six-minute period. Based on stack test data from July 30,2014,
particulate emissions from the dryer/mixer were 3.59 pounds per hour and visible emissions were 0% opacity.`The total
particulate matter limit is calculated to be 45.63 pounds per hour. Compliance with 2D .0506 is demonstrated.'It should
be noted that during the inspection,no visible emissions were observed coming from the stack, indicating compliance
with 2D .0521. The sulfur dioxide emissions from the drum dryer shall not exceed 2.3 lbs/million Btu of heat input.
Since the sulfur dioxide emissions from the combustion of natural gas are negligible, compliance with 2D .0516 is
indicated.
The facility is permitted for two hot mix asphalt storage silos(SILO-1 and SILO-2), a truck load-out operation(TL-1),
an4;allo''. 2 fuel oil-fired liquid asphalt he Liquid asphalt is mixed with dried aggregate to produce asphalt. The
asphalt is then conveyed into one of the storage silos and then loaded into asphalt trucks. During the inspection,no visible
enissions were observed coming from the stack for the asphalt,heater,indicating compliance with 2D .0521. The sulfur
dioxide emissions from the asphalt heater shall not exceed 2.3_lbs/million Btu of heat input. Based on the calculations'`
from the permit review for Air Permit No. 00481R20,the sulfur dioxide emissions from the combustion of No: 2 fuel oil
is'0.51 lbs/million Btu. Compliance with 2D .0516 is indicated.
The facility is permitted for five insignificant sources consisting of a 250 gallon fuel oil above ground storage tank(1-3),
two 10,000 gallon fuel oil above ground storage tanks(I-4 and 1-7), one 20,000 gallon liquid asphalt above ground storage
tank(I-5a),and one 100 gallon propane above ground tank(I-8). With the exception of the recycled No. 4 fuel oil storage ;
tank(1-7), which is gone,all of the other insignificant sources were observed on-site.
Permit Conditions
Condition A.2 contains the requirements for 2D .0202"Registration of Air Pollution Sources," The permit for this
facility expires on April 30,2025. At least 90 days prior to the expiration of this permit,the Permittee shall submit a
permit renewal and an emissions inventory for the 2023 calendar year. Compliance is expected:
Condition A.3 contains the requirements for 2D .0503 "Particulates from Fuel Burning Indirect Heat Exchangers." This
rule applies to the No. 2 fuel oil-fired liquid asphalt heater. Particulate matter emissions from this fuel burning indirect
heat exchanger shall not exceed the allowable emission rate listed below;
MCI
No. 2 fuel oil-fired liquid asphalt heater 0.60
(1.45 million Btu per hour maximum heat input)(H-1)
' ' T7 ,

Based,on the permit review for Air Permit No. 00481R20,the particulate emission rate for No. 2 fuel oil is 0.024
lb/million Btu. 'Compliance is indicated.
Condition A.7 contains the requirements for 2D .0524"New Source Performance Standards." The dryer/mixer is subject
to 40 CFR 60,Subpart I. The facility has NSPS emission limitations,and shall not discharge or cause the discharge into
the atmosphere from any affected source any gases,which:
i. Contain particulate matter in excess of 90 mg/dscm; or
ii. Exhibit 20,percent opacity;or greater.
The facilityperformed a stack test for the plant on July 30,2014. The results,of the stack,test were reviewed by SCB
and were found acceptable. The test results showed that the affected source gases contained particulate matter of 23
mg/dscm and the highest 6-minute average for opacity was 0%. Compliance was indicated.
Condition A.8 contains the requirements for 2D .0535 "Excess Emissions Reporting and Malfunctions. The facility is to
notify DAQ of a malfunction or breakdown requiring more than four hours to repair resulting in excess emissions. No
notifications have been received since the last on-site inspection. Compliance is indicated:
Condition A.9 contains the requirements for 2D.0540"Particulates from Fugitive Dust Emission Sources." This
condition states that 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. No complaints of fugitive dust emissions have
been received since the last inspection. Compliance is indicated.
Condition A.10 contains the requirements for 2D .0605 and deals with a"Testing Requirement." As per this regulation,
the facility conducted a stack test on July 30, 20.14 and.demonstrated compliance with the emission limits at an asphalt
production rate of 155.9 tons per hour. The facility is required to maintain daily records(each day of operation),showing
the total daily.production in tons,the hours of operation,and the highest targeted hourly production rate for that day. A'
review of the records indicate that the facility is doing this. If a production rate exceeds the production rate shown above,
plus ten percent,the facility shall notify DAQ within 15 days. If a production rate exceeds the production rate shown
above, plus ten percent,the facility shall test the emission source within 60 days. The facility is aware.of these
requirements and none of the production rates appeared,to be above this limit. The facility shall test the asphalt plant and
submit two.copies of the test results to DAQ by December 31,2024. Compliance is expected.
Condition A.11 contains the requirements for 2D .0611 "Fabric Filter Requirements." To ensure that emissions do not
exceed the regulatory limits,the Permittee shall perform,at a minimum,an annual internal inspection of the bagfilter
system. The last annual internal inspection was performed on September 1,2020. During this annual inspection no
problems were noted. Compliance is indicated:.
Condition A.12 contains the requirements for 2D .1100"Control of Toxic air Pollutants." In this condition,the facility
has limits it shall not exceed. To ensure compliance with these limits,the following restrictions shall apply:
L Hot mix asphalt production shall not exceed 491,000 tons per:calendar year. For 2019, the facility produced
27,293.10 tons of asphalt.
ii. 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. For 2019, the facility combusted 6,700.00 gallons of No.2 fuel oil in the asphalt heater.
W. The height of the bagfilter(ID No. CS-1) stack shall not be less than 21.6 feet and it shall be located at UTM
coordinates 17N 463833.00 4033957.00. Based on the last full compliance inspection, the height of the
bagifllter stack was measured to be not less than 21.6 feet. Mr. Gentry said that the baglillter stack has not been
changed or moved since the last inspection.
4

iv. The height of the two hot mix asphalt•storage silos(ID Nos. SILOA and SILO-2)stack shall not be less than 58
feet and shall be located at UTM coordinates 17N 463864.00 4033961. Based on the last full compliance
inspection, the height of the hot mix asphalt storage silos were measured to be not less than 58 feet. Mr.
Gentry said that the silos have not been changed or moved.
V. 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. Based on the last full compliance inspection, the height of the asphalt
heater stack appeared to be not less than 9 feet. Mn Gentry said that the asphalt heater stack has not been
changed or moved since the last inspection.
vi. If any actual(as-built)values(coordinates)differ from those used in the modeling analysis submitted by the
Permittee to DAQ on July 5,2013, and revised on May 10,2016 and July 3, 2018,the Permittee shall notify the
DAQ and provide the new values. The DAQ will re-evaluate the validity of the original modeling analysis and
notify the Permittee in writing whether additional modeling is required. The Permittee shall not operate the
affected sources until written approval from the DAQ is received. Mr. Gentry said that none of the equipment at
the facility has been moved -
The facility is required to report within 30 days of each calendar year quarter,the total amount of hot mix asphalt
produced,and the total amount of No. 2 fuel oil combusted in the liquid asphalt heater from the beginning of the calendar
year. The last report was received on July 10,2020. The report contained all the required data. From January of 2020
through June of 2020,the facility produced 23,653.18 tons of asphalt and combusted 2,352.00 gallons of No. 2 fuel oil in
the asphalt heater. Compliance is indicated. y
l
The Tacility is also required to record the monthly quantity of hot mix asphalt produced and No. 2 fuel oil combusted in
the liquid asphalt heater. Mr.Mackey emailed Mr.Barker a copy of these records,which were reviewed. Compliance is
indicated.
Condition A.13 contains the requirements for 2D .1806"Control and Prohibition of Odorous Emissions." The facility
shall prevent odorous emissions from the facility from causing or contributing to objectionable odors beyond the facility's
boundary. No odor complaints about the facility have been received since the last inspection. Compliance is indicated.
Condition A.14 contains the requirements for 2Q .0315 "Synthetic Minor Facilities." To maintain synthetic minor
classification,the facility-wide emissions shall be less than the following:
1Sdzr��''� 151-
r t� �' � ��F kE �V�.,� „� \\���y
� � � s
....................
............
a, a v oIl$j �GQ �tiV Oath0 ),a
... ... :_ ...... _ W w_... ........ ... __
� .......
..,._ � .. SO2 � 1�0
_... _ z_ _�. .._,mm �.......­_
co 100
To ensure that emissions do not exceed these limits,the facility has operational restrictions. The sulfur content of the fuel
oils combusted shall be limited to 0.5%sulfur and the production of asphalt shall be less than 491,000 tons per
consecutive 12-month period. A review of the records and fuel certification sheets indicate that the facility did not exceed
the 491,000 tons per consecutive'12-month period and sulfur content of the fuel oil did not exceed 0.5% sulfur by weight.
Mr. Gentry said that the facility has not received any recycled No. 4 fuel oil since the last inspection. The facility is
required to record monthly and total annually the amount of asphalt produced in tons and keep fuel supplier certifications
on-site. Records reviewed during the inspection indicate that the facility is doing this.
The facility is required to report within 30 days of each calendar year,the monthly and 12-month totals of SO2 and CO
emissions,asphalt produced for the previous 12-month period,and submit a summary of fuel certification records. The
5

last report was received on July 10, 2020. The report contained all the required data. From January of 2019 through
December of 2019;the facility produced 27,293.10 tons of asphalt. The facility during this time period emitted 0.0 tons of
SO2 and 1.95 tons of CO. Compliance is indicated.
Condition A.15 contains the requirements for 21) .0530"Prevention of Significant Deterioration." In accordance with 2D
.0317,to comply with this permit and avoid applicability to 21) .0530,the facility shall be limited as follows:
Y a3fIt 1 IIIIS ZS�III Ii r 5
Affects our e£s �oltutan� bns R; Cot►sec 12 ninthZ Reril)
Facility Wide S02 _ 250
_.. _._._... _. >_..W._.._,_. _._....._ _.._....__.�
According to the facility's second quarter report for 2020,which was received on July 10,2020,the SO2 emissions for the
previous 12 months totaled 0.0 tons. Compliance is indicated.
Condition A.16 contains the"Vendor Supplied Recycled No(s). 4 Fuel Oil Requirements." In accordance with 2Q .0317,
the Permittee is avoiding the applicability of 2Q .0700 by using recycled fuels which are equivalent to virgin counterparts.
The Permittee is allowed to use recycled fuel oil that meet the following criteria:
Arsenic 1.0 ppm maximum
........
Cadmium C 2.0 ppm maximum
Chromium 5.0 ppm maximum
...W...... _ ..,..... _ �__.._. _. ..
Lead 100 ppm maximum
.......
.......
..:_.. . . ..... .....
.....
Total Halogens ) 1000 ppm maximum
Flash Point No.4 1300F minimum
Sulfur No 4 �__._. 2 0%maximum(by weight)
_....._....®. .. ..._:.: _, . ___.. ...... ....... .. . ._o.:. ....m: .
Ash 1 0%maximum
The facility is required to maintain records of the actual amount of recycled fuel oil delivered to and combusted on an
annual basis and a delivery manifest document for each shipment. As per Mr,Gentry,the facility has not received or
combusted any recycled No. 4 fuel oil since the last full inspection.
Condition A.17 contains the requirements for 2Q .0711"Emission Rates Requiring a Permit." Pursuant to 2Q .0711, for
each of the TAPS listed in the permit,the Permittee has made a demonstration that facility-wide actual emissions do not
exceed the TPERs listed in 2Q .0711. As per the permit review for Air Permit No. 00481R20,the actual emission rates
are below the TPERs. Compliance is indicated.
Facility-Wide Emissions
The emissions below were,taken from the 2016 Emissions Inventory,with the exception of S02 and CO. They were taken
from the 2019 annual report.
F yIt WIN,
PM 2.8
PMio 2.0
SOz 0.0
NO, 5.•0
c0 1.95
VOc 3.8
6

HAP Total 0,811
HAP MOW(Formaldehyde) 0.25
Compliance History for the last five years
February 5,2018 -NOD for late submittal of a quarterly report. The report was received on time(January 30,2018),but
contained exceedance of the total annual allowable amount of No. 2 fuel oil combusted in the asphalt heater(H-1). The
allowable amount was 27,005 gallons and the facility reported 46,626 gallons. The facility responded to the NOD on
February;14, 2018 and stated that the facility combusted 14,400 gallons of fuel oil in the asphalt heater for 2018.
MACT and GACT Applicability Determination
The facility does not currently appear to be subject to any MACTs or GACTs at this time.
Permit Issues
The 10,000 gallon above ground storage tank(I-7)for No. 4 fuel oil has been removed.
Fuel oil storage tank I-3 is no longer used.
Propane storage tank 1-8 is no longer used.
Location
Latitude and longitude for this facility were verified.
Conclusion
Based on review of the records and visual observations,the facility appeared to be operating in compliance with Air
Quality standards and regulations at the time of this inspection.
7

i