AQ_F_2000123_20200908_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Asheville Regional Office
AIR QUALITY Harrison Construction Division of APAC-Atlantic,
Inc.
Inspection Report NC Facility ID 2000123
Date: 09/15/2020 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 X
Don Mason Don Mason Don Mason NSPS: Subpart I
Environmental Environmental Environmental
Compliance/Quality Compliance/Quality Compliance/Quality
Control Control Control
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 09/08/2020
Inspector's Name Michael Koerschner
Inspector's Signature: i(�n •� Operating Status Operating
` Compliance Code Compliance- inspection
Action Code FCE
Date of Signature: C[I?�C� Z© On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR: !
TSP S02 NOX VOC CO PM10 *HAP
2014 --- --- --- --- --- ---
2009 0.1700 3.63 0.9100 0.0600 0.3300 0.1600 5.37
*Highest HAP Emitted(inpounds',
Five Year Violation History:None
Date Letter Tyne Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
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 8,2020,I(Michael Koerschner)met with Mr. Derrick Stiles,Asphalt Plant Foreman,to conduct an
annual compliance inspection. The inspection was announced in advance due to COVID-19.1 arrived at the facility
at—09:30 am and observed it starting up making—115 TPH asphalt-using 15%RAP-for State work.I observed
the asphalt plant in operation until—10:45 am when I left the site.According to Mr. Stiles,the plant was producing
500-600 tons on that day.
During my visit, visible emissions from the bagfilter exhaust appeared to be less than 5%opacity.Visible emissions
from the storage silo(while being loaded)were occasionally up to 15%opacity(blue haze)and visible emissions
from truck loadout appeared occasionally up to 20%opacity.There is a pick-up line from the pug mill to the top of
the knock-out box that was puffing visible dust emissions.I brought this to the facility's attention and a field
operator climbed up to the pug mill and had the asphalt plant operator cut off the fan.This stopped the dusting.I
asked the field operator what had occurred and he stated that they were letting the bagfilter fan(main fan)pull the
dust.
This facility has historically operated on a sporadic basis(demand based).However, due to a widening project of
64/74 through Murphy,this facility is expected to operate higher production for the next year to two years.Then it is
expected to revert back to sporadic operations.
This facility is unique in that the bagliter-collected dust is mechanically conveyed to a dump truck via an auger
system and then a belt conveyor.The material is wetted by sprays that are manually adjusted on startup. I observed
the sprays being adjusted by plant operators during startup.A previous inspection report states that they generate 6-8
dump trucks of dust per 1000 tons asphalt produced.
Facility Contacts
The facility contacts appear to be up-to-date in IBEAM.
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 plant started production this
season on 6/22/2020. This facility has made upgrades to prepare for expected increased area asphalt demand
associated with a 2020 widening of Hwy 64 through Murphy. The upgrades include new ductwork on the ID side
of the bagfilter fan,improvements to the aggregate elevator, and a new asphalt storage silo.Note that the facility is
permitted for the addition of 2 new asphalt silos but only one is currently installed.
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 1 System ID Description
One hot mix asphalt batch plant(300 tons per hour maximum capacity)consisting of:
ESl (NSPS) one natural gas/No. 2(virgin or recycled) CD2 one knock-out box(1,408
fuel oil\No.4(virgin or recycled)fuel cubic feet)(CD2)in series with
oil-fired hot mix asphalt batch plant(88 CDT one bagfilter(11,084 square
million Btu per hour maximum heat input feet of filter area)(CD I)
rate while combusting natural gas and
110 million Btu per hour maximum heat
input rate while combusting fuel oils)
processing asphalt and reclaimed asphalt
product(RAP)
- -
ES2,ES7,and ES8 three hot mix asphalt storage silos(200 N/A N/A
tons storage capacity, each)

Emission Emission Source Control Control System
Source ID Description System ED — Description
ES3 one main plant truck loadout operation N/A N/A
ES6 one hot mix asphalt storage silo truck N/A N/A
loadout operation
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. The haul roads had been
watered and dust from the haul roads was minimal. No road-generated fugitive emissions were observed.
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 records to
demonstrate compliance with this condition. I did not inspect the log book of production data during this inspection.
Specific Condition 9: Control and Prohibition of Odorous Emissions
This condition requires the facility to restrict objectionable odors to the property. There have been recent odor
complaints associated with this facility and I drove in the neighborhood(but not to exact addresses)where the
complainants live.No objectionable odors were observed on or off the property during the inspection.
Specific Conditions 10 and II: 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 last inspection of the bagfilter system(including knock-out
box)took place on April 1,2020. I reviewed the inspection records.

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. I reviewed the fuel oil records.The facility has received 2 loads(--14,000 gallons)of recycled No.4 fuel oil
this season and included the required analyses. Sulfur contents of the loads were 0.16%and 0.22%.All records and
reports are up to date, and indicate compliance with this condition.
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
O1/10/2020 indicated compliance. In 2020,the facility produced 19,881 tons of asphalt.
Insignificant Sources Listing
Source ' Notes _
FT One No.2 fuel oil-fired asphalt tank heater(1.38 Observed n 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
I-2 -fuel oil storage tanks facility no longer uses,N, 2� rel oil but there is a
15,000 gallon No.2 fuel(N 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 I 90 mg/dscm 0.008 gr/dscf) Yes
ES-1 (0.04 gr/dscf)
15A NCAC 2D .0506 54.0 lb/hr 4.75 Ib/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 appeared to be operating in compliance with the Air Quality standards and
regulations as specified in Air Permit No. 08976RI 1.