AQ_F_1300101_20210224_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Blythe Brothers Asphalt Co.,LLC-Concord Plant
NC Facility ID 1300101
Inspection Report County/FIPS:Cabarrus/025
Date: 02/24/2021
Facility Data Permit Data
Blythe Brothers Asphalt Co.,LLC-Concord Plant Permit 07449/RI 1
660 Goodman Road Issued 2/20/2018
Concord,NC 28027 Expires 1/31/2026
Lat: 35d 24.3970m Long: 80d 42.0010m 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
Tye Pickett Frank Blythe Alec Blythe NSPS: Subpart I
Plant Foreman Member Manager Air Quality Manager
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 02/24/2021
KAK Inspector's Name Donna Cook
Inspector's Signature: 004UM C0oh Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: V212412V21 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2016 5.84 0.0200 4.48 8.23 22.69 4.12 1090.00
2012 14.72 0.0100 3.08 5.64 15.56 6.70 224.93
*Highest HAP Emitted in ounds)
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

Blythe Brothers Asphalt Co.,LLC—Concord Plant
February 24,2021
Page 2
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Tracking: X Date submitted for initial review 02/24/2021 _IBEAM WARNING/OB,NOD,NOV,NRE
X IBEAM Document
X IBEAM Inspection,list date inspected X 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 02/01/2022
Directions: From Mooresville Regional Office to Concord,travel Highway 3 South;turn right on Odell
School Road;turn right on Poplar Tent Road and make a U-turn at the next stop light; and 0.7 mile turn
left on Goodman Road(road prior to Interstate 85); and 0.2 mile on the left is entrance to the asphalt
plant. The street address of the asphalt plant is 660 Goodman Road. The phone number for Mr. Tye
Pickett,plant foreman of this company,is [phone].
Safety Equipment: This company has no safety requirements at this facility. It is recommended that
steel toe shoes,hard hat and hearing protection be worn by the inspector at the asphalt plant.
Safety Issues: Inspector should be cautious of heavy equipment and truck traffic at the asphalt plant.
Lat/Lon2 Coordinates: A review of the "Facilities Regulated by Air Quality" on the DAQ website
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 locked in IBEAM.
Email Contacts: The emails for the facility, authorized,technical, and invoice contacts were verified by
Mr. Tye Pickett,plant foreman. No changes to the email addresses in IBEAM are needed.
COVID-19 Information:
Mr. Tye Pickett,plant foreman of this company at(704) 788-0275, and I discussed the COVID-19
restrictions at this facility prior to the site visit. Mr. Pickett stated that this company will allow the
inspector on-site access to the outside asphalt plant and its inside control room if a face covering(mask) is
worn and the physical distancing of at least six feet(social distancing)is maintained from other plant
personnel.
Before conducting the inspection, I completed the NC Employee Screening for Employees Reporting
Onsite form on the oshr.nc.gov web site. Based on my responses to the questions in this form,I was able
to proceed with the on-site inspection.
The routine air quality inspection was conducted by me outside near the asphalt plant. I spoke with Mr.
Pickett by telephone regarding this inspection. I did not encounter any plant personnel during the on-site
inspection.

Blythe Brothers Asphalt Co.,LLC—Concord Plant
February 24,2021
Page 3
General Information:
1. The purpose of this site visit was to conduct a routine air quality inspection. Blythe Brothers
Asphalt Co., LLC operates a counterflow continuous drum type hot mix asphalt plant that
produced 231,566 tons of asphalt while burning 6,461 decatherms of natural gas during calendar
year 2020. 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. Pickett stated that this plant operates 7 a.m. to
5 p.m.,9 hours per day, 6 days per week,47 weeks per year.
2. Facility Contact Information:
During the inspection, I verified the facility contact information in IBEAM with Mr. Pickett. No
changes are needed to the facility contact information in IBEAM.
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 Description System ID Description
ES-1 (NSPS) drum mix type,natural CD-1, CD-2 cyclone(ID No. CD-1; 8 feet
gas/No.2 fuel oil/recycled in diameter)installed in
No. 2 fuel oil/recycled No.4 series with bagfilter(ID No.
fuel oil-fired hot mix asphalt CD-2; 12,818 square feet of
plant(350 tons per hour filter area)
maximum rated capacity;
116 million Btu per hour
maximum heat input rate)
Natural gas is the primary fuel source for the rotary drum mix asphalt dryer. No.4 recycled fuel oil
is the secondary fuel source for this dryer. No. 2 fuel oil and recycled No. 2 fuel oil are listed on the
permit description as the backup fuel sources for this dryer.
This company reported that 6,461 decatherms of natural gas was combusted by this dryer(ID No.
ES-1)during calendar year 2020. The recycled No. 4 fuel oil,No. 2 fuel oil and recycled No. 2 fuel
oil were not combusted in the rotary drum aggregate dryer during calendar year 2020.
The sand and aggregate materials are placed in the six bins by a front end loader. These materials
are conveyed by the six virgin aggregate feeder belts(belt under each of the six feeders in bottom of
each bin)to one aggregate collector belt conveyor and then to one vibrating double deck screen
(two screens installed 5'x 12', each). After the screening process,these materials are conveyed to
one aggregate scale belt conveyor into the inlet of the rotary drum. The eight belt conveyors and
one vibrating double deck screen were in operation with no visible emissions observed.
The reclaimed asphalt pavement(rap)is placed by front end loader into two grizzly screens and
then dropped into two feeder bins. From the bottom of the feeder bin,the rap is conveyed to two

Blythe Brothers Asphalt Co.,LLC—Concord Plant
February 24,2021
Page 4
feeder belts(one belt under each feeder in the bottom of each bin)to one collector belt conveyor
and then to one vibrating single deck screen(3'x 6'). Then the oversized materials from the
vibrating single deck screen drops from a chute onto another belt conveyor and then conveyed to the
hammermill to be crushed. After the crushing process,the rap materials are returned by the
collector belt conveyor to the vibrating single deck screen and then conveyed to one scale belt
conveyor and then into the rotary drum mix asphalt dryer. The five belt conveyors and one
vibrating double deck screen were in operation with no visible emissions. Mr. Pickett stated that
30%rap is being used in the hot mix asphalt product.
This company hired Red Clay Industries, Inc.to crush rap at the asphalt plant. Mr. Pickett stated
that the crushing of rap was not being conducted during the inspection. I observed no portable rap
crushing plant at this facility. Mr. Pickett stated that this company crushed 51,745.82 tons of rap in
calendar year 2020.
The particulate matter emissions from the rotary dryer are exhausted into the cyclone and then to the
pulse jet type bagfilter(12,818 square feet of filter area; manufacturer,Herman Grant Co). At the
base of the cyclone and bagfilter,the particulate matter emissions are screw conveyed to the incline
auger and then into the rotary drum. This company has a gauge(Goyer demand cleaning)
measured in inches of water that is used to determine the pressure differential across the bagfilter.
The gauge is located at ground level near the bagfilter.
Observed. The drum mix asphalt plant was operating at 150 tons per hour and producing binder
asphalt product, 19.00, during the inspection. The mix temperature in the rotary drum mix asphalt
dryer was 314 degrees Fahrenheit. The rotary drum aggregate dryer was firing on natural gas. The
pulse jet type bagfilter was in operation. The pressure differential gauge across the bagfilter read 3
inches of water. I observed no visible emissions except for the dissipation of the steam plume
from the exhaust of the vertical and uncapped bagfilter stack.
ES-2,ES-3,ES-4 three(3)HMA storage silos N/A N/A
�(200 tons capacity, each)
The hot mix asphalt product from the rotary drum mix asphalt dryer is conveyed by the drag slat to
the two hot mix asphalt(hma)conveyors(referred to as the traverse conveyors by this company).
The two hma conveyors are located above the three hot mix storage silos(ID Nos. ES-2,ES-3, ES-4
or company ID Nos. 1,2 and 3). The hot mix asphalt product is transported by the two hma
conveyors into a designated hot mix storage silo by the plant operator.
The hot mix asphalt is stored in the three hma storage silos. The three silos(ID Nos. ES-2 or#1;
ES-3 or#2 and ID No. ES-4 or#3) are electrically heated. The hot mix asphalt is gravity dropped
from the three hma storage silos into the beds of dump trucks.
Observed. The three silos(ID Nos. ES-2 or#1;No. ES-3 or#2;new silo installed January 2017,
which like-for-like and ES-4 or#3) contained binder asphalt product, 19.00. The hot mix asphalt
products were being gravity dropped from the three storage silos into the beds of dump trucks. I
observed no visible emissions from the three hma storage silos or the gravity dropping of asphalt
products from the three hma storage silos into the beds of dump trucks.

Blythe Brothers Asphalt Co.,LLC—Concord Plant
February 24,2021
Page 5
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?
IES-2 -natural gas/No. 2 fuel oil-fired hot oil 2Q 0102
heater(2.2 million Btu per hour maximum heat(h)(1)(A) Yes Yes
input rate)
The Heatec model natural gas-fired hot oil heater(ID No. IES-2) is no longer in use at this facility.
This company installed a new natural gas-fired hot oil heater rated at 2.2 million Btu per hour
maximum heat input rate in November 2020. The heater is used to heat the hot oil in the two
vertical liquid asphalt storage tanks(30,000 gallons, each) also installed in November 2020; one
heat exchanger(pre-heater for No.4 recycled fuel oil); asphalt drag slat conveyor;hot oil lines for
mixer(bottom outer shell drum or mixing chamber)and one traverse conveyor. The hot oil is
recirculated. The hot oil heater a vertical stack with a rain cap.
No. 2 fuel oil is listed as the backup fuel source for the previous hot oil heater. Mr. Pickett stated
that the hot oil heater is not connected to the No.2 fuel oil line.
This office received a permit applicability determination from this company regarding the
installation of the natural gas-fired hot oil heater and the two liquid asphalt storage tanks (30,000
gallon, each). A letter dated April 15, 2020 from this office was to this company exempting these
sources from air quality permitting. These sources were added to the electronic yellowsheet.
Observed. The hot oil heater installed in November 2020 was operating on natural gas. I observed
no visible emissions from the stack exhaust of the hot oil heater.
IES-3 -two compartment liquid asphalt
storage tank(capacities of 20,000 and 10,000 2Q .0102 No No
gallons per compartment) (g)(14)(B)
The two compartment liquid asphalt storage tank(20,000 and 10,000 gallons, each; installed 1992)
is no longer in use at this facility. The liquid asphalt is currently stored in two vertical storage tanks
(30,000 gallons, each)installed in November 2020. The liquid asphalt is mixed with sand,
aggregate,rap and bagfilter dust in the rotary drum and then heated by the rotary dryer to produce
the hot mix asphalt product.
This office received a permit applicability determination from this company regarding the
installation of the natural gas-fired hot oil heater and the two liquid asphalt storage tanks(30,000
gallon, each). A letter dated April 15, 2020 from this office was to this company exempting these
sources from air quality permitting. These sources were added to the electronic yellowsheet.
Observed. The liquid asphalt was being mixed in the rotary drum with sand,aggregate,rap and
bagfilter dust and then heated by the dryer to produce the hot mix asphalt product. I observed no
visible emissions from the two vertical liquid asphalt storage tank(30,000 gallons,each).
IES-4-recycled No.4 fuel oil storage tank 2Q .0102 (g)(4) Yes Yes
(20,000 gallon capacity)
Mr. Pickett stated that this tank is referred to as the holding tank. No. 4 recycled fuel oil is used as
the secondary fuel source for the rotary drum mix asphalt dryer. A heat exchanger(pre-heater)is
used to heat the No.4 recycled fuel oil prior to this dryer.

Blythe Brothers Asphalt Co.,LLC—Concord Plant
February 24,2021
Page 6
Observed. The No. 4 fuel oil tank was not in use during the inspection due to this dryer firing on
natural gas.
IES-5 -recycled No.4 fuel storage tank 2Q .0102 (g)(4) Yes Yes
(12,000 gallon capacity)
Mr. Pickett stated that this tank is referred to as the burn tank. The No.4 recycled fuel oil is used as
the secondary fuel source for the rotary drum mix asphalt dryer. A heat exchanger(pre-heater)is
used to heat the No.4 recycled fuel oil prior to this dryer.
Observed. The No. 4 fuel oil tank was not in use during the inspection due to this dryer firing on
natural gas.
IES-6-No. 2 fuel oil storage tank(20,000 2Q .0102 (g)(4) Yes Yes
gallon capacity)
The No. 2 fuel oil(off-road virgin) is used in the front end loader and truck. The No. 2 fuel oil
could be used as the backup fuel source for the rotary drum aggregate dryer(ID No. ES-1)and the
hot oil heater(ID No. IES-2). The rotary drum aggregate dryer is currently operating on natural
gas. The hot oil heater has never been installed on the No. 2 fuel oil line and never operated on No.
2 fuel oil.
Observed. The No. 2 fuel oil was not in use during the inspection due to this dryer firing on natural
gas.
6. Observations of air emission sources and control devices not listed on the current permit:
a. This company has a heat exchanger(referred to by this company as the pre-heater)that is
used to heat the No.4 recycled fuel oil using thermal fluid(hot oil flows through coils
and transfers heat to the No. 4 recycled fuel oil) from the two No. 4 recycled fuel oil
tanks(ID Nos. IES-4,20,000 gallon capacity; and IES-5, 12,000 gallon capacity)prior to
the burner of the rotary drum aggregate dryer.
b. A release agent (manufacturer, ChemStation Co. of NC; and product name 4147) 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.
C. This company has two hma conveyors(referred to as traverse conveyors)to transport the
hot mix asphalt product into designated hot mix storage silos(ID Nos. ES-2 or#1;
ES-3 or#2; and ES-4 or#3)by the plant operator.
d. This company has eight aggregate belt conveyors; one vibrating aggregate double deck
screen(5'x 12';400 tons per hour maximum process rate; five rap conveyors; one rap
hammermill(12 tph maximum rated capacity); and one single rap deck screen(3'x 6;
180 tons per hour maximum rated capacity). These sources were permitted under
revision 9 and removed from revision 10. These sources are not listed on the permit
because they are considered fugitive sources. The conveyors and screens were in
operation during the inspection. I observed no visible emissions from the conveyors and
screens during the inspection.
e. This company has two aboveground diesel tanks (2,000 gallons, each)that are used to
fuel the shop trucks for Blythe Development. Mr. Pickett stated that one tank has on-

Blythe Brothers Asphalt Co.,LLC—Concord Plant
February 24,2021
Page 7
road diesel fuel and the second tank has off-road diesel fuel. The two diesel fuel tanks
are exempt per 15A NCAC 2Q .0102 (g)(4).
f. This office received a permit applicability determination from this company regarding the
installation of the natural gas-fired hot oil heater and the two liquid asphalt storage tanks
(30,000 gallon,each). A letter dated April 15,2020 from this office was to this company
exempting these sources from air quality permitting. These sources were added to the
electronic yellowsheet.
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 2024 calendar year to MRO DAQ.
Observed. I informed Mr. Pickett that the current air permit expires on January 31,
2026. 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 emissions except for the
dissipation of a steam plume from the exhaust of the bagfilter stack or fugitive emissions
from this facility. Compliance with this stipulation is indicated.
C. Condition A. 4. 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 "213 .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.
d. Condition A. 5. 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.

Blythe Brothers Asphalt Co.,LLC—Concord Plant
February 24,2021
Page 8
Observed. The asphalt plant was in operation during the inspection. I observed no
visible emissions except from the dissipation of steam from the exhaust of the bagfilter
stack or any other sources at this facility. Compliance with this stipulation is indicated.
e. Condition A. 6. 15A NCAC 2D .0524 "New Source Performance Standards" -For
asphalt plant(ID No. ES-1),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 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 during the inspection. I observed no
visible emissions except for the dissipation of the steam plume from the exhaust of the
bagfilter stack. Compliance with this stipulation is indicated.
f. Condition A. 7.Notification Requirement-As required by 15A NCAC 2D .0535,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 a conversation with Mr. Pickett,no excess emissions have occurred
at the facility. Compliance with this stipulation is indicated.
g. Condition A. 8. 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. Pickett stated that Vulcan Construction Materials,LLC,
Cabarrus Quarry has a water truck that wets the unpaved areas at this asphalt plant for
this company. The plant roads at this facility were wet due to recent rainy weather. I
observed no fugitive emissions from the unpaved areas at this facility. Compliance with
this stipulation is indicated.

Blythe Brothers Asphalt Co.,LLC—Concord Plant
February 24,2021
Page 9
h. Condition A. 9. Testing Requirement-Under the provisions of North Carolina General
Statute 143-215.108 and in accordance with 15A NCAC 2D .0605,the permittee shall
demonstrate compliance with the emission limit(s)by testing the emission source(s) for
the specified pollutant(s)as follows:
Affected Source(s) Pollutant Target Test Method
Affected Source(s) rp
Parameter
drum mix type,natural gas/No. 2 fuel oil/
recycled No. 2 fuel oil/recycled No. 4 fuel oil-
fired hot mix asphalt plant(350 tons per hour PM(TSP) 60 lb/hr Method 5
maximum rated capacity; 116 million Btu per
hour maximum heat input rate) (ES-1)
drum mix type,natural gas/No. 2 fuel oil/
recycled No. 2 fuel oil/recycled No. 4 fuel oil-
fired hot mix asphalt plant(350 tons per hour PM(TSP) 60 lb/hr Method 202
maximum rated capacity; 116 million Btu per
hour maximum heat input rate) (ES-1)
drum mix type,natural gas/No. 2 fuel oil/
recycled No. 2 fuel oil/recycled No. 4 fuel oil- DAQ
fired hot mix asphalt plant(350 tons per hour Visible 20%opacity Approved
maximum rated capacity; 116 million Btu per Emissions Method
hour maximum heat input rate) (ES-1)
Observed. This facility is required per DAQ memo to perform the particulate matter
(methods 5 and 202) and visible emissions (method 9)testing on the rotary drum mix
asphalt dryer once every ten years. This office sent a letter dated September 13,2013
advising this facility of emission testing procedures.
The last stack testing for visible(EPA reference method 9) and particulate(EPA
reference method 1-5-filterable PM&202-condensible PM) emissions testing of the hot
mix asphalt plant was performed by Integrity Air Monitoring,Inc. on June 20,2019.
This plant was burning natural gas and the averaged production rate of asphalt was 320
tons per hour.
The results of this testing indicated that this asphalt plant had a filterable particulate
matter(PM)emission rate of 0.0081 gr/dscf or 1.22 lb/hr;total particulate matter(PM)
emission rate of 1.51 lb/hr; condensable particulate matter(PM) emission rate of 0.291
lb/hr; and Method 9 visible emissions evaluation for the highest six-minute average was
0.8%opacity. This office sent the test results to SCCB in Raleigh on July 10, 2019.
This office sent a letter dated May 22, 2020 to this company stating that the results
of these tests indicated compliance with the applicable particulate matter and visible
emissions limitations. Compliance with this stipulation is indicated.
i. Condition A. 10. Fabric Filter Requirements including cartridge filters, baghouses, and
other dry filter particulate collection devices - As required by 15A NCAC 2D .0611,
particulate matter emissions shall be controlled as described in the permitted equipment
list. The permittee shall perform, at a minimum, an annual internal inspection of the
particulate collection device system within 12 month period following the initial

Blythe Brothers Asphalt Co.,LLC—Concord Plant
February 24,2021
Page 10
inspection. In addition,the permittee shall perform periodic inspections and maintenance
as recommended by the equipment manufacturer. The results of all inspections and any
variance from manufacturer's recommendations shall be investigated with corrections
made and dates of actions recorded in the logbook(in written or electronic format). The
logbook shall be kept on-site and made available to DAQ personnel upon request.
Observed. The logbook provided by Mr. Pickett indicated that the internal inspections
of the bagfilter were conducted by this company on 8/17/2020, 7/30/2020, 4/13/2020 and
previously on 2/25/2020. 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 No. 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. Compliance with this stipulation is indicated.
j. Condition A. 11. Cyclone Requirements -As required by 15A NCAC 2D .0611,
particulate matter emissions shall be controlled as described in the permitted equipment
list. The permittee shall perform,at a minimum, an annual inspection of cyclone system
within 12 month period following the initial inspection. In addition,the permittee shall
perform periodic inspections and maintenance as recommended by the equipment
manufacturer. The results of all inspections and any variance from manufacturer's
recommendations shall be investigated with corrections made and dates of actions
recorded in the logbook(in written or electronic format). The logbook shall be kept on-
site and made available to DAQ personnel upon request.
Observed. The logbook provided by Mr. Pickett indicated that the inspections for the
cyclone were conducted on 2/26/2020, 7/30/2020 and previously on 2/21/2020. The
inspections of the cyclone 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 cyclone
inspection and maintenance activities are being kept by this company for more than two
years. Compliance with this stipulation is indicated.
k. Condition A. 12. 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.
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.
1. Condition A. 13. 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

Blythe Brothers Asphalt Co.,LLC—Concord Plant
February 24,2021
Page 11
"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-month period)
S02 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 1,494,000 tons per
consecutive 12-month period when burning natural gas or No. 2 fuel
oil/No. 2 recycled oil that is 0.5%sulfur by weight;
B. the asphalt produced shall be less than 320,000 tons per consecutive 12-
month period when combusting recycled No.4 fuel oil that is 2.0%
sulfur by weight;
C. If multiple fuels are used, emissions should be determined using the sum
of the individual emissions rates.
ii. Recordkeeping Requirements -
A. The permittee shall record monthly and total annually the following:
1. the tons of asphalt produced for each fuel type.
2. the facility-wide CO and S02 emissions.
B. Fuel supplier certification shall be kept on-site and made available to
DAQ personnel upon request.
Observed. The records of the asphalt production are kept by this company on a
daily basis. The monthly and annual asphalt production records and calculated
emissions data of SO2 and CO are compiled by Mr.Alec Blythe, air quality
manager, and Mr. Pickett.
The recycled No. 4 fuel oil was not combusted by the rotary drum mix asphalt
dryer during calendar year 2020. The recycled No. 4 fuel oil was last combusted
in this dryer on January 31,2014 due to natural gas curtailment by the supplier.
This company has fuel oil certification records on site indicating that the sulfur
content of the No. 4 recycled fuel oil is below the allowable limit. Compliance
with this stipulation is indicated.
iii. Reporting Requirements -Within 30 days after each calendar year,regardless of
the actual emissions,the permittee shall submit the following:

Blythe Brothers Asphalt Co.,LLC—Concord Plant
February 24,2021
Page 12
A. emissions and/or operational data listed below. The data should include
monthly and 12 month totals for the previous 12 month period.
1. the tons of asphalt produced for each fuel type.
2. the facility-wide SO2 and CO emissions.
Observed. The annual report for calendar year 2020 was received by this office
on January 21,2021. This company reported the following information: 0.02
tons of sulfur dioxide(S02)emissions; 16.13 tons of carbon dioxide(CO)
emissions; 231,566 tons of asphalt when combusting 6,461 decatherms of
natural gas in the rotary dryer; and no fuel oils were combusted in the
rotary dryer during calendar year 2020. Compliance with this
stipulation is indicated.
M. Condition A. 14. 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 SO2 250
Observed. The facility-wide SO2 emissions were reported by this company as 0.02 tons
during calendar year 2020. Compliance with this stipulation is indicated.
n. Condition A. 15. 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) as follows:
i. Specifications -The recycled fuel oil(s)have to be equivalent to unadulterated
fossil fuel by meeting the following criteria:
Constituent/Property Allowable Level
Arsenic 1.0 ppm maximum
Cadmium 2.0 ppm maximum
Chromium 5.0 ppm maximum
Lead F,00 ppm maximum
Total Halogens 1000 ppm maximum
Flash Point
No. 2 100°F minimum
No. 4 130°F minimum
Sulfur
No. 2 [2.
.5%maximum(by weight)
No. 4 0%maximum(by weight)

Blythe Brothers Asphalt Co.,LLC—Concord Plant
February 24,2021
Page 13
Constituent/Property Allowable Level
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.
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. This company is keeping records of the recycled No. 4 fuel oil delivered and
combusted by the rotary drum aggregate dryer at this facility. The annual report for
calendar year 2020 was received by this office on January 21,2021. The recycled No. 4
fuel oil was not combusted by the rotary drum aggregate dryer during calendar year 2020.
The recycled No. 4 fuel oil was last combusted in the rotary aggregate dryer on January
31,2014 due to natural gas curtailment by the supplier. 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.

Blythe Brothers Asphalt Co.,LLC—Concord Plant
February 24,2021
Page 14
This company does not own or operate any rap crushing, screening, and conveying equipment.
However,the portable rap crushing, screening, and conveying operations conducted by an outside
contractor at this facility is subject to NSPS 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 internal combustion engines operated at this facility are not subject to
NSPS Subpart IIII (4I) and NESHAP Subpart ZZZZ (4Z), since these engines are classified as a
"nonroad engine" according to 40 CFR 1068.30 and covered under Title II of the Clean Air Act.
The asphalt plant is not subject to MACT Subpart LLLLL—Asphalt Processing and Asphalt
Roofing Manufacturing.
This company has no boilers, emergency/peak shaving generators, fire pump engines or gasoline
storage tanks at this facility.
The natural gas-fired/No. 2 fuel oil-fired hot oil heater(ID No. IES-2) 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 process heater is not subject to the area source
boiler NESHAP Subpart 6J.
9. Summary of changes needed to the current permit:
a. The test method for visible emissions should be changed from DAQ Approved Method to
Method 9 in condition A. 9. Testing Requirement.
b. This company has two new liquid asphalt storage tanks(30,000 gallons, each). These
tanks has been added to the yellowsheet. The natural gas-fired hot oil heater(2.2 million
Btu per hour maximum heat input)was added to replace the natural gas/No.2 fuel oil-
fired hot oil heater(ID No. IES-2).
C. The electronic yellowsheet for permit changes needed has been completed and placed in
the facility's electronic file.
10. Compliance assistance offered duringthe he inspection:
None.
11. Section 112(r)aPplicability:
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.

Blythe Brothers Asphalt Co.,LLC—Concord Plant
February 24,2021
Page 15
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:dlc
c: MRO File
https://nceonnect.sharepoint.com/sites/DAQ-MRO/Counties/CABARRUS/00101/INSPECT_20210224.docx