AQ_F_1700005_20200717_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Winston-Salem Regional Office
AIR QUALITY Piedmont Asphalt,LLC
NC Facility ID 1700005
Inspection Report County/FIPS: Caswell/033
Date: 07/22/2020
Facility Data Permit Data
Piedmont Asphalt,LLC Permit 019.02/R20
1675 Rock Quarry Road Issued 6/1/2015
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
Carl Mitchell Douglas Dawson Julian Stinson NSPS: Subpart I
Plant Operator; General Manager HR and Safety Manager
[phone] [phone] [phone]
Compliance Data
Comments: FCE and follow-up to 5/27/20 PCE due to COVID-19.
Inspection Date 07/17/2020
r Inspector's Name Blair Palmer
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature:07/22/20 MTH On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
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 inpounds)
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
1

Permitted Sources:
�1 ""((gyp a,.n. sm r4, a ,�a,� ,a: S.r.;
��s.7 L` on y t f;1�I"Iii
g h 3%e�hu, 5 (�1 }
3 1 :a s
, � tip ; ���y n1 ► � '
-� �
�14111r
ram...wkiT� h`...x-Zx`...
Natural gas/No 2 fuel oil/used No 2 fuel oiUNo 4 fuel Bagfilter
ES1 oil/used No.4 fuel oil-fired double barrel drum mixer CD1 (10,842 square feet of filter area)
(116 million Btu per hour maximum heat input)
ES2.1,ES2.2 Three(3)hot mix asphalt storage silos r�
and ES2.4 (200-ton capacity, each)
��- N/A N/A
ES2.3 ��Cold asphalt storage silo(40-ton capacity)
.._..._.. ......... ......_. ... _. ... ........ ....... .._::.... .._._ ...._ .... ......... ....
ES3 Truck Loadout Operation
Insignificant/Exempt Activities:
"OR",
11-1 -Natural gas/No.2 fuel oil-fired hot oil heater 2Q .0102 (c)(2)(B)(i)(I) I
(1.6 million Btu per hour maximum heat input)
I-2-Fuel oil storage tank(1000-gallon capacity)
I-3 -Recycled fuel oil storage tank(25,000 gallons) 2Q .0102(c)(1)(D)(i) yes Yes
C
....... . ...�_'. .... ....... ..... . .... ... .. .. ...... ....*. ... ..... ....
I ES6&I ES7 Two(2) liquid asphalt,storage tanks(30,000 gallons capacity,each) 2Q .0102(c)(1)(L)(xii)
I-ES8 -Liquid asphalt storage tank(1000 gallons capacity)
Introduction:
On July 17,2020,Mr. Blair Palmer,Environmental Specialist of the DAQ WSRO,contacted Mr. Rand(Julian) Stinson,
HSE of Piedmont Asphalt,LLC via email 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. The inquiry used June 12,2020 DAQ guidance as part of the phase 2 reopening and applicable field
activities. Mr.Palmer received information via email on July 8,2020, and Mr.Palmer concluded that the facility would
appear to be safe to conduct a Full Compliance Evaluation(FCE),with the understanding that all or most information was
received as part of the Partial Compliance Evaluation(PCE)conducted on May 27,2020. The COVID-19 response from
the facility and any other related information was shared with the appropriate WSRO-DAQ management. The May 27,
2020 inspection report or PCE can be found in IBEAM under either"Work"or"Public"sections. The facility is a double
barrel drum-mix asphalt plant and generally operates up 8-12 hours/day, 5-6 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 or PCE. Production has been relatively steady since
the start of COVID-19 at this particular plant.
On July 17,2020,Mr. Palmer met with Mr. Stinson,but also Mr.Douglas Dawson, General Manager for Piedmont
Asphalt,was also on-site for the FCE, and Mr.Palmer was on-site from 8:20 am to 9:05 am. Updated information was
obtained and/or updated because of the July 17, 2020 FCE and can be read later in this report.
2

This facility operates a350 ton/hr(max)batch hot mix asphalt plant producing asphalt for residential and commercial
purposes. Current operating hours are generally eight-ten hours per day(7:00 am-5:00 pm), five days per week(Monday-
Friday),and fifty-one weeks per year(shutdown Christmas week). However,the facility will operate intermittently
during the winter months(usually December and January). All contact information was verified, and no changes are
needed in IBEAM.
Safety Equipment while onsite:
Safety shoes,ear protection, hard hat,safety vest, and eye protection are required within production areas.
Applicable Regulations:
According to permit Condition A.l of Air Quality Permit No. 01920R20,this permitted facility is subject to the following
regulations: Title`15A North Carolina Administrative Code(NCAC),Subchapter 2D .0202, 2D .0506, 2D .0516, 2D
.0521,2D .0524(40 CFR 60, Subpart I), 2D .0535, 2D .05405 2D.0605, 20 .0611,2D .1806,2Q .0309, 2Q .0315,2Q
.0317 (PSD Avoidance and 2Q .0711 Avoidance). 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 in the rule.
The facility is only subject to the General Duty clause of the Section 112(r)program.
Process/Discussion:
e
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(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(CDl). 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 a separate truck loadout(ES3). During the FCE,Mr.Palmer was able to observe start-up for the day,at
the plant, and the facility began producing asphalt loading into one of the silos. Under cloudy sky conditions,Mr. Palmer
was able to observe any possible visible emissions, and none were observed, indicating compliance with 2D. 0521. It
should be noted that 2D .0506 requires fugitive emissions from asphalt sources to less than 20%o-opacity when averaged
over six minutes,fugitive emissions of 0-5%were present near the top of the storage silo being filled at time of
inspection, as asphalt was being loaded into one silo during the inspection(also mentioned earlier). The plant was
operating at approximately 200 tons/hour and a RAP mixture of 15%. The differential pressure gauge for the bagfilter
system was reading 1.1 inches of water column(wc).
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(1-2),a 25,000-gallon recycled fuel oil storage tank(I-
3),two30,000-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. The asphalt heater was observed combustingnatural 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
3

building used for this asphalt mixture laboratory located towards the front of the property and would be eligible for
exemption under 15A NCAC 02Q .0102,ACTIVITIES EXEMPTED FROM PERMIT:REQUIREMENTS. Specifically,
15A NCAC 02Q .0102(g)(3)(A), laboratory or classroom activities: bench-scale, on-site equipment used. for
experimentation, chemical or physical analysis for quality control purposes or for diagnosis of illness, training, or
instructional purposes. There are two small electric fired furnaces used for testing physical properties of the asphalt mixes
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 PCE,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. During CY2019,RAP was 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 filer
Applicable Facility Regulations updated/discussed because of July 17,2020 FCE:
Condition A.3 contains the particulate control requirement required by 15A NCAC 2D .0506"Particulates from Hot Mix
Asphalt Plants." The maximum allowable particulate emissions from hot mix asphalt plants is calculated using the
following two equations:
E=4.9445 * (P)o.a3'6 for P<300tons/hr, or
E=60 lbs/hr for.P>=300 tons/hr
Based on the throughput rate of this plant of 300 tons/hr.,the maximum allowable PM emissions rate is 60 lbs/hr(based
on 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 NCAC 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 control efficiency of 99.286%is required for the bagfilter at this facility.According to
permit review R20,the control efficiency of the filter is 99.9%. Compliance is expected for both the PM limit and opacity
requirement since the bagfilter is installed and appears to be well maintained. Compliance with this condition is also
confirmed based on the most recent May 19,2017 test stack results. The allowable emissions limit per 2D .0506
according to the SSCB memo dated July 18,2017 is 60 pounds per hour and production rate of 335 tons/hour. The
facility tested at 1.86 lb/hr.
Also,according to the rule,visible emissions must be limited to 20%when averaged over a six-minute period. Fugitive
emissions should be controlled from the drying, conveying, classifying,and mixing equipment according to 2D .0540.
Compliance is indicated since the facility tested at 0%and no fugitive emissions were noted during the inspection.
Condition A.5 contains the 15A NCAC 2D .0521,Visible Emissions Control requirement.This facility is limited to 20%
opacity for sources manufactured after July 1, 1971 and a 40% opacity for sources manufactured as of July 1, 1971,when
averaged over a six-minute period.Little to no visible emissions(0-5%)was observed being emitted from the bagfilter
exhaust stack, indicating compliance with 2D .0521. The asphalt heater was small vertical exhaust stack, and no visible
emissions were detected, indicating compliance with 2D .0521.
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
4

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 test. A July 18,
2017 DAQ Stationary Source Compliance Branch(SSCB)memo provides the following:
Pollutant EPA Emissions Emissions Limit Regulation Compliance
Method
4.41 mg/dscm
Filterable PM 5 0.5 lb/hr 90 mg/dscm 60 Subpart I Yes
-
Condensable PM 202 11.76 mg/dscm
1.36 lb/hr --- --- ---
Total PM 5/202 1.86 lb/hr 60 lb/hr 2D .0506 Yes
Visible Emissions 9 00 0 <20% 2D .0506 Yes
Condition A.7 contains the 15A NCAC 2D. 0535,Notification requirements. This requires the facility to notify the DAQ
director of any malfunctions associated with a source causing an excess of emissions lasting more than four hours. There
have no indications or reports indicating any problems with the facility. No notification or complaints have been received
by this office regarding malfunctions or breakdowns and no changes have occurred since the PCE on May 27,2020.
Compliance is expected.
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; Weather conditions leading up to the FCE have been dry
and hot. Compliance with this condition is likely indicated.
ConditionA.10 contains the 2D .0611 requirements for bagfilter maintenance and recordkeeping. The bagfilter(CD1) is
subject to this rule. The facility is required to perform, at aminimum, an annual (for each 12-month period following the
initial inspection) internal inspection of the bagfilter system and perform periodic inspections and maintenance as
recommended by the equipment manufacturer.'The results of all inspection and maintenance activities must be recorded
in a logbook. Based on records provided to Mer.Palmer back to the last DAQ inspection,the facility is conducting
monthly bagfilter inspection and performing maintenance as needed. The last annual inspection record available were
noted to be from March and May 19,2020, with no problems noted after looking at bags. Compliance is expected. The
facility utilizes a differential pressure gauge,and it a daily production logbook has readings recorded as being
approximately l inches of water column(wc). It is unclear what the normal operating range for the bagfilter system,
since one needle or higher setting was very high based on conversation with plant personnel. Mr.Palmer advised the
facility to investigate the matter and correct if possible.
Condition A.I I contains the 15A NCAC 2D .1806 control and prohibition of odorous emissions requirements. There were
no objectionable odors detected at the facility or within the property boundaries during last inspection. Mr. Palmer
observed little odors while on the premises. There are no previous odor complaints in the IBEAM database.Compliance
with 2D .1806 is indicated at this time.
Condition A.12 contains the 15A NCAC 2Q .0309"Termination,Modification,and Revocation of Permits"condition.
The permit may be reopened, modified,or reissued if any credible air emissions data is discovered. Additional emission
controls of restrictions may be required to demonstrate compliance with the condition. There does not appear to any
changes with equipment and/or or increase in emissions requiring this condition to be used. Compliance is expected.
5

Condition A.13 contains the 2Q 0315 "Synthetic Minor Facilities"requirement,which allows the facility to be classified
as Synthetic Minor and avoid Title V;permitting. To comply emission limits for S02,and CO emissions that do not
exceed the Title V threshold of 100 tons per consecutive 12-month period,the facility shall use No. 4/approved recycled
No. 4 fuel oil with a maximum sulfur content of 1.05 percent by weight. The total emission rate is reflected as the sum of
emission rates of all fuels that are used. The facility must also limit asphalt production to 720,000 tons during any
consecutive 12-month period. The facility's production rate was 107,691 tons in the year 2019 and 126,087 tons in
CY2018. Thus far in CY 2020,the total asphalt production is 42,982 total tons up thru the FCE July 17,2020, These
production totals are below the 120,000 tons limit. Furthermore,the facility has not combusted any No.4/recycled No. 4
fuel oil since 2013, according to facility's file and this FCE.
The reporting requirements stipulate that that the permittee must record monthly and annual values for total asphalt
production. Fuel supplier certification must also be kept on-site and be made available to the inspector.`To comply with
the reporting requirement,the facility must,within 30 days after each calendar year,the monthly and total carbon
monoxide and sulfur dioxide emissions and the total amount of asphalt produced. As mentioned,earlier, in CY 2020 thus
far,the total asphalt;production is 42,982 total tons up thru the FCE July,17,2020. The 2019 annual report was received
on January 30,2020(postmarked January 27,2020). This report showed that the facility emitted a total of 0.01 tons of
S02, 1.40 tons of NOx(not required to report),and 7.14 tons of CO in 2019. As mentioned earlier,this facility produced
a total of 107,691 tons of asphalt in CY 2019 and 126,087 tons in 2018. The report stated that there were not any No.4,
fuel oils combusted in 2019. The facility is,and plans on, using solely natural gas for all permitted and exempt
equipment. Compliance with this condition is indicated at this time.
NSPS/NESHAP:
The facility is subject to 15A NCAC 2D ,0524"New Source Performance Standards(NSPS)"required as promulgated in
40 CFR 60,'Subpart 1, "Standards of Performance for Hot Mix Asphalt Facilities."The specifics of the regulation are
discussed in detail underCondition A.6. This.condition applies to the natural gas/No. 2 fuel oil/used No. 2 fuel oil/No.;4
fuel oil/used No.4 fuel oil-fired double barrel drum mixer(ES1). This condition limits particulate matter to less than 90
mg/dscm or 0.04 gr/dscf and sets a maximum opacity of 20 percent for visible emissions using EPA Method 9. No visible.
emissions,being emitted from this source, were observed during last inspection. The most recent completed stack test,
performed May 19,2017, indicated an average opacity of 0% (when averaged over.a six-minute period)and an average
filterable particulate emissions concentration of 4.41 mg/dscm. The most recent source test was conducted on natural gas
as that is the only fuel currently being used at the facility. Compliance with this condition is expected, if the bagfilter is
working properly and it appeared to be based records review for May 27,2020 and observations(and some records
review)for this FCE.
This facility does not appear to be subject to any other NSPS/NESHAP regulations currently. There are no stationary
emergency or non-emergency engines.
Although no included in IBEAM or the current permit,the facility does perform periodically crush RAP at this location.
The equipment used is subject to NSPS 000,,and this is discussed in more detail earlier in this report.
Compliance History within last five years:
• This facility has not been issued a Notice of Deficiency(NOD)or a Notice of Violation(NOV).
Permit Discussion(also mentioned in May 27,2020 FCE),with one small new finding:
• Based on current DAQ guidance, testing is to be conducted every 10 years and Condition A.9 should be updated
accordingly during next permit opening.
• ES2.3 is no longer used and has not been in several years.
6

• New finding---The facility has a small separate building used mainly for QA/QC towards the front of the property
and would be eligible for exemption under 15A NCAC 02Q .0102, ACTIVITIES EXEMPTED FROM PERMIT
.REQUIREMENTS. Specifically, 15A NCAC 02Q .0102(g)(3)(A), laboratory or classroom activities: bench-
scale, on-.site equipment used for experimentation, chemical or physical analysis for quality control purposes or
for diagnosis of illness, training, or instructional purposes. There are two small electric fired furnaces used for
testing physical properties of the asphalt mixes 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).
Conclusion:
Based on information as part of the PCE conducted on May 27,2020,and this FCE,the permitted facility appears to be in
compliance with its Air Quality Permit, including applicable`DAQ and federal air quality rules.
7

,,
1
,_