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HomeMy WebLinkAboutAQ_F_1300172_20210428_CMPL_InspRpt NORTH CAROLINA DIVISION OF Mooresville Regional Office AIR QUALITY Sloan Construction Co. (A Division of Reeves)- Bonds Plant Inspection Report NC Facility ID 1300172 Date: 04/27/2021 County/FIPS: Cabarrus/025 Facility Data Permit Data Sloan Construction Co. (A Division of Reeves)-Bonds Plant Permit 10437/RO1 7139 Weddington Road,NW Issued 2/20/2020 Concord,NC 28027 Expires 7/31/2023 Lat: 35d 22.7142m Long: 80d 4l.6301m 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 Alan Gambill Zach Green Colton Ginn NSPS: Subpart I Plant Supervisor President Environmental Manager (704)682-3518 (864)416-0200 (864)580-1760 Compliance Data Comments: Inspection Date 04/27/2021 Inspector's Name Donna Cook Inspector's Signature: Danna eov* J93;R Operating Status Operating Compliance Status Compliance-inspection Action Code FCE Date of Signature: 04/28/2021 Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP SO2 NOX VOC CO PM10 *HAP No emissions inventory on record.The emissions inventory is due 05/02/2023. *Highest HAP Emitted(in pounds) 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 Sloan Construction Co. (A Division of Reeves)—Bonds Plant April 27, 2021 Page 2 Type Action: X Full Compliance _Partial Compliance _Complaint Other: Evaluation Evaluation/Reinspection Investigation Data Tracking: X Date submitted for initial review 4/28/2021 _IBEAM WARNING/OB,NOD,NOV,NRE X IBEAM Document X IBEAM Inspection,list date inspected _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 4/01/2022 Directions: From Mooresville Regional Office to Concord,travel Highway 3 South;turn right on Odell School Road;turn right at the stop light onto Poplar Tent Road due to the no left turn; make a U turn at the next stop light;past the interchange of Interstate 85 turn right at the stop light onto Pitts School Road; 1 '/2 miles turn right at the first stop light onto Weddington Road; '/2 mile turn left into the entrance of Martin Marietta Materials,Inc.,Bonds Quarry;past the office/weigh scale and turn left at next unpaved road. The address of the asphalt plant is 7139 Weddington Road. The phone number for Mr. Jason Adams,plant operator, at the asphalt plant is(704) 897-6275. The phone number for Mr. Colton Ginn, environmental manager, is(864) 580-1760. Safety Equipment: This company has no safety requirements. It is recommended that a hard hat, steel- toed shoes, safety vest, and hearing protection must be worn by the inspector at this facility. Safety Issues: Inspector should be cautious of heavy equipment and truck traffic at the asphalt plant. Lat/Long Coordinates: A review of the "Facilities Regulated by Air Quality" on the DAQ web site 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 not locked in IBEAM. Email Contacts: The emails for the facility, authorized,technical, and invoice contacts were verified by Mr. Jason Adams,plant operator,and Mr. Colton Ginn, environmental manager. I changed the email address for the authorized contact to Zach Green,president, in IBEAM. COVID-19 Information: Mr. Jason Adams,plant operator of this company at(704) 897-6275,and I discussed the COVID-19 restrictions at this facility. Mr. Adams 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 on-site air quality inspection was conducted outside of the asphalt plant with Mr. Jason Adams,plant operator. I wore a mask and maintained a distance of more than six feet(social distancing) from Mr. Adams and other plant personnel during the inspection. Sloan Construction Co. (A Division of Reeves)—Bonds Plant April 27, 2021 Page 3 General Information: l. The purpose of this site visit was to conduct a routine air quality inspection. Sloan Construction Company operates a continuous drum type hot mix asphalt plant that produced 96,883 tons of asphalt while burning natural gas in 2020 calendar year and 5,907 tons of asphalt from January 1, 2021 through March 31, 2021. 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. Jason Adams, plant operator, accompanied me during this inspection. Mr. Adams stated that this plant operates 2 to 10 hours per day, 5 days per week, 50 weeks per year. 2. Facility Contact Information: During the inspection, I verified the facility contact information in IBEAM with Mr. Adams. I changed the authorized contact to Zach Green,president,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 Continuous drum type,hot mix asphalt plant(225 tons per hour) ES1 (NSPS) natural gas/No. 2 fuel CD1 bagfilter(9,184 square feet of oil/recycled No. 2 fuel filter area)with inertial oil/No. 4 fuel oil/recycled separator No. 4 fuel oil-fired (propane-fired pilot light) aggregate dryer(72 million Btu per hour maximum heat input rate)with associated mixer Propane is the fuel source to initially light the pilot on the burner of the rotary drum aggregate dryer. After lighting on propane,the fuel is switched to natural gas. Natural gas is the only fuel source for the rotary drum aggregate dryer. The sand and aggregate are placed in five bins by a front end loader. These materials are conveyed by five aggregate feeder belts (24 inch belts under each of the five feeders in bottom of bins)to one collector aggregate conveyor belt(30 inch) and then to one vibrating single deck screen. After the screening process,these materials are conveyed by one aggregate weigh bridge conveyor belt(30 inch),then through a chute to a second aggregate conveyor belt(30 inch),to one aggregate slinger conveyor belt(24 inch)and then into the inlet of the rotary drum aggregate dryer. Only three bins were in use at the time of the inspection. The nine belt conveyors and the vibrating screen deck screen were in operation with no visible emissions observed by me. Sloan Construction Co. (A Division of Reeves)—Bonds Plant April 27, 2021 Page 4 A front end loader is used to place the reclaimed asphalt product(rap)into one grizzly screen and then dropped into one feeder bin. From the feeder bin,the rap is conveyed by one feeder belt(24 inch)to one vibrating single deck screen. After the screening process,the rap is conveyed by one weigh bridge conveyor belt(24 inch)to a chute and then into the rotary mixer drum. The two belt conveyors and the vibrating single deck screen were in operation with no visible emissions. Mr. Adams stated that 20%rap is mixed in the mixer drum with liquid asphalt and any particulate matter from the inertial separator and bagfilter(ID No. CD 1) and the heated sand and aggregate materials from the rotary drum aggregate dryer. This company hired an outside contractor to crush rap at this asphalt plant. Mr. Adams stated that the crushing of RAP was not being conducted at the time of the inspection. I observed no portable RAP crushing plant at this facility. After the drying process,the sand and aggregate are dropped by chute into the rotary mixer drum. The sand and aggregate materials are mixed with liquid asphalt,reclaimed asphalt product(rap) and any particulate matter from the inertial separator and bagfilter(ID No. CD I)in the rotary mixer drum. There is no drying in the mixer drum. After the mixing process,the hot mix asphalt product is conveyed by the drag slat to storage silo (ID No. ES3 or company ID No. 1)or from the drag slat to the traverse conveyor. From the traverse conveyor,the hot mix asphalt product is conveyed into storage silo (ID No. ES4 or company ID No. 2). The hot mix asphalt product is gravity dropped from the two storage silos into the beds of dump trucks. During the inspection,the surface mix asphalt product,9.5C,was being stored in silo(ID No. ES4 or company ID No. 2). The storage silo(ID No. ES3 or company ID No. 1)was empty. The surface mix asphalt product was being gravity dropped from the two storage silos into the beds of dump trucks with no visible emissions observed by me. The particulate matter emissions from the rotary drum aggregate dryer exhaust to an inertial separator. At the base of the inertial separator,the particulate matter emissions are gravity dropped through a chute into the mixer drum. From the bagfilter,the particulate matter emissions are screw conveyed into the mixer drum. This company has a gauge measured in inches of water that is used to determine the pressure differential across the bagfilter. The gauge is located on the control panel inside the plant office. Observed. The continuous drum mix asphalt plant was operating at 100 tons per hour and producing surface mix asphalt product, 9.5C. The rotary drum aggregate dryer was firing on natural gas. The mix temperature in the rotary drum aggregate dryer was 300 degrees Fahrenheit. The pulse jet type bagfilter was in operation. The pressure differential gauge across the bagfilter read 4.8 inches of water. I observed no visible emissions from the exhaust of the vertical and uncapped bagfilter stack at the time of the inspection. ES2 lime silo (35.7 tons capacity, CD2 bagfilter(233 square feet of 25 tons per hour maximum filter area) process rate) Mr. Adams stated that the lime silo and bagfilter will not be constructed at this facility. Observed. No lime silo and associated bagfilter were observed by me at this facility. ES3 hot mix asphalt storage silo N/A N/A �(200 ton maximum capacity) Sloan Construction Co. (A Division of Reeves)—Bonds Plant April 27, 2021 Page 5 The hot mix asphalt product from the rotary mixer drum is conveyed from the drag slat to hot mix storage silo (ID No. ES3 or company ID No. 1). The hot mix asphalt product is gravity dropped from storage silo#1 into the beds of dump trucks. Observed. No hot mix asphalt product was being stored in storage silo(ID No. ES3 or company ID No. 1)at the time of the inspection. ES4 hot mix asphalt storage silo N/A N/A (200 ton maximum capacity) The hot mix asphalt product from the rotary mixer drum is conveyed from the drag slat to the traverse conveyor. From the traverse conveyor,the hot mix asphalt product is stored in storage silo (ID No. ES4 or company ID No. 2). The hot mix asphalt product is gravity dropped from storage silo#2 into the beds of dump trucks. Observed. The hot mix asphalt product, surface mix 9.5C,was being stored in silo(ID No. ES4 or company ID No. 2). I observed no visible emissions from storage silo#2 or the gravity dropping of asphalt into the beds of dump trucks. ESS Itruck loadout operation FN/A N/A The hot mix asphalt products are gravity dropped from the two storage silos(ID Nos. ES3 or company ID No. 1 and ES4 or company ID No. 2) into the beds of dump trucks. Observed. No hot mix asphalt product was being stored in storage silo(ID No. ES3 or company ID No. 1). The gravity dropping of the hot mix asphalt product, surface mix 9.5C, from the storage silo (ID No. ES4 or company ID No. 2)into the beds of the dump trucks was being conducted at the time of the inspection with no visible emissions observed by me. 5. Observations of insignificant air emission sources and control devices listed on the current permit: Source Exemption Source of Source of Title Regulation TAPs? V Pollutants? IES5 -natural gas-fired hot oil heater(1.2 2Q 0102 (h)(1)(B) Yes Yes million Btu per hour maximum heat input) F The natural gas-fired hot oil heater(ID No. IES5) is used to heat the hot oil in two horizontal liquid asphalt cement storage tanks(30,000 gallons,each),two hot mix asphalt storage silos(ID Nos. ES3 or company ID No. 1 or ES4 or company ID No. 2) and the liquid asphalt lines. The stack of the natural gas-fired hot oil heater is vertical and uncapped. Observed. The natural gas-fired hot oil heater was in operation at the time of the inspection. I observed no visible emissions from the exhaust of the hot oil heater stack. IES6—liquid asphalt cement storage tank F2Q 0102 (g)(4) No No (30,000 gallons capacity) The liquid asphalt is stored in a horizontal tank(ID No. IES6; 30,000 gallons). The sand and aggregate materials are mixed with the liquid asphalt,reclaimed asphalt product(rap) and any particulate matter("dust")from the inertial separator and bagfilter(ID No. CD-1)in the rotary mixer drum. Observed. No tanker truck unloading of liquid asphalt into the horizontal storage tank was occurring Sloan Construction Co. (A Division of Reeves)—Bonds Plant April 27, 2021 Page 6 at the time of the inspection. The liquid asphalt in the horizontal tank was in use. I observed no visible emissions or detected any odors from the vertical tank at the time of the inspection. IES7—liquid asphalt cement storage tank F2Q 0102 (g)(4) No F No (30,000 gallons capacity) The liquid asphalt is stored in a horizontal tank(ID No. IES7; 30,000 gallons). The sand and aggregate materials are mixed with the liquid asphalt,reclaimed asphalt product(rap) and any particulate matter("dust")from the inertial separator and bagfilter(ID No. CD-I)in the rotary mixer drum. Observed. No tanker truck unloading of liquid asphalt into the horizontal storage tank was occurring at the time of the inspection. The liquid asphalt in the horizontal tank was in use. I observed no visible emissions or detected any odors from the vertical tank at the time of the inspection. IES8—propane storage tank(500 gallons F2Q .0102 (g)(4) No No capacity The propane is the fuel source to initially light the pilot on the burner of the rotary aggregate dryer. Then the fuel is switched to natural gas. Observed. Mr. Adams informed me that the storage tank(500 gallons) for the propane has been removed from this facility and replaced with a 25 pound tank. The 25 pound propane tank was not in use at the time of the inspection. The size of the propane storage tank should be changed to 25 pounds during the next permit revision. 6. Observations of air emission sources and control devices not listed on the current permit: a. The diesel fuel for the front end loader and service trucks is stored in one aboveground tank with a capacity of 1,000 gallons. The storage tank is exempt per 15A NCAC 2Q .0102 (g)(4). b. A release agent 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. This process is exempt per 2Q .0102(g)(14)(B). 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 2022 calendar year to MRO DAQ. Observed. I informed Mr.Adams and Mr. Ginn that the air permit expires on July 31,2023 and the air pollution emission inventory report with certification sheet for 2022 calendar year must be submitted with the permit renewal request. I advised Mr. Adams and Mr. Ginn to contact Jennifer Womick or Denise Hayes if they have any questions regarding air quality permitting. 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," Sloan Construction Co. (A Division of Reeves)—Bonds Plant April 27, 2021 Page 7 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 or fugitive emissions from the facility. Compliance with allowable emissions rate was indicated during the permit application process. C. Condition A.4. Particulate Control Requirement-As required by 15A NCAC 2D .0515 "Particulates from Miscellaneous Industrial Processes,"particulate matter emissions from the lime silo (ID No. ES2) shall not exceed allowable emission rates. Observed. The lime silo has not been installed at this facility. The particulate matter emissions from the lime silo will not exceed the allowable emission rates as indicated in the permit review. Compliance with this stipulation was indicated during the permit application process. d. Condition A. 5. 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"21) .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. e. Condition A. 6. 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, except that six-minute periods averaging not more than 87 percent opacity may occur not more than once in any hour nor more than four times in any 24- hour period. Observed. The asphalt plant was in operation at the time of the inspection. I observed no visible emissions from the exhaust of the vertical and uncapped bagfilter stack or any other sources at this facility. Compliance with this stipulation is indicated. f. Condition A. 7. 15A NCAC 2D .0524 "New Source Performance Standards" -For drum mix type asphalt plant(ID No. ES1),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 Part 60, Subpart I, including Subpart A, "General Provisions." Sloan Construction Co. (A Division of Reeves)—Bonds Plant April 27, 2021 Page 8 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 at the time of the inspection. I observed no visible emissions from the exhaust of the bagfilter stack or any other sources at this facility. Compliance with this stipulation is indicated. g. Condition A. 8.Notification Requirement-As required by 15A NCAC 2D .0535, states that 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 records review and the conversation with Mr. Adams and Mr. Ginn, no excess emissions have occurred at the facility. Compliance with this stipulation is indicated. h. Condition A. 9. 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.Adams stated that Martin Marietta Materials,Inc. has a truck that is utilized by this facility to water the unpaved areas at this asphalt plant. The plant roads at this facility were wet. During the inspection,I observed no fugitive emissions from the unpaved areas at this facility. Compliance with this stipulation is indicated. i. Condition A. 10. Toxic Air Pollutant Emissions Limitation and Reporting Requirement- Pursuant to 15A NCAC 2D .1100 "Control of Toxic Air Pollutants," and in accordance with the approved application for an air toxic compliance demonstration,the following permit limits in the table below shall not be exceeded. The permittee has submitted a toxic air pollutant dispersion modeling analysis dated May 1,2015 for the facility's toxic air pollutant emissions as listed in the below table. The modeling analysis was reviewed and approved by the DAQ Air Quality Analysis Branch(AQAB)on May 26,2015. Placement of the emissions sources,configuration of the emission points, and operation of the sources shall be in accordance with the submitted dispersion modeling analysis and should reflect any changes from the original analysis submitted as outlined in the AQAB review memo Sloan Construction Co. (A Division of Reeves)—Bonds Plant April 27, 2021 Page 9 Affected Source(s) Toxic Air Pollutant FEmission Limit aggregate dryer with associated Benzene (71-43-2) F97.5 pounds per year mixer(ES I) aggregate dryer with associated Formaldehyde (50-00-0) F6975 pounds per hour mixer(ES 1) aggregate dryer with associated Nickel metal(Component F 4 pounds per day mixer(ES1) ofNIC) (7440-02-0) �hot mix asphalt storage silos [Benzene (71-43-2) 0.975 pounds per year (ES3 and ES4) �hot mix asphalt storage silos Formaldehyde (50-00-0) FOO189 pounds per hour (ES3 and ES4) truck loadout operation(ES5) IBenzene (71-43-2) 0.54 pounds per year truck loadout operation(ES5) Formaldehyde (50-00-0) 10.000823 pounds per hour i. Restrictions-To ensure compliance with the above limits,the following restriction shall apply: A. The amount of asphalt produced shall not exceed 250,000 tons per year, regardless of which fuel type is combusted. Recordkeeping Requirements -The following recordkeeping requirements apply: i. Recordkeeping and reporting requirements contained in synthetic minor stipulation 15A NCAC 2Q .0315 will be used to demonstrate compliance with the above limits. Observed. This facility performed a modeling analysis on a facility-wide basis for emissions of benzene,formaldehyde, and nickel metals since these toxic air pollutants were above the TPER limits. The modeling was based on 250,000 tons of asphalt production per year. The initial startup of this plant for asphalt production occurred on December 9,2016. This plant produced 2,102 tons of asphalt for December 2016. The maximum annual asphalt production rate of 250,000 tons per year was not being exceeded. The asphalt production records are being kept by this company. Based on the asphalt production rate of 96,883 tons during calendar year 2020,the asphalt plant will not exceed the modeled limits. Compliance with this stipulation is indicated. j. Condition A. 11. 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. Sloan Construction Co. (A Division of Reeves)—Bonds Plant April 27, 2021 Page 10 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. k. Condition A. 12. 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 "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-monthperiod) PM10 100 SO, 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 250,000 tons per consecutive 12-month period regardless of fuel type. This limit is based on the limit used to demonstrate compliance with toxics. B. The sulfur content of the No. 2 fuel oils and No. 4 fuel oils shall be limited to 0.5%and 2.0% sulfur by weight,respectively, and D. If multiple fuels are used, emissions should be determined using the sum of the individual emissions rates. Observed. This plant produced 96,883 tons of asphalt when combusting only natural gas during calendar year 2020. There is no fuel oil storage at this facility. Compliance with this stipulation is indicated. ii. Inspection and Maintenance Requirements- A. Fabric Filter Requirements includingcartridge artridge 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. To comply with the provisions of this permit and ensure that emissions do not exceed the regulated limits,the permittee shall perform periodic inspections and maintenance (I&M)as recommended by the manufacturer. In addition,the permittee shall perform an annual(for each 12 month period following the initial inspection)internal inspection of each fabric filter system. iii. Recordkeeping Requirements- A. The permittee shall record monthly and total annually the following: Sloan Construction Co. (A Division of Reeves)—Bonds Plant April 27, 2021 Page 11 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. C. A log book(in written or electronic format) shall be kept on site for each control device and made available to Division of Air Quality personnel upon request. The permittee shall record all inspection,maintenance and monitoring requirements listed above in the logbook.Any variance from the manufacturer's recommendations shall be investigated with corrections made and date of actions recorded in the log book. Observed. The log book provided by Mr.Adams indicated that the inspection and maintenance activities are being conducted by this company. This company conducted the internal inspections of the bagfilter on 4/12/21; 6/27/20; 4/27/20; 2/27/20; 10/8/19; 7/10/19; 6/21/19; 6/18/19; 6/12/19; 6/4/19; and 2/16/19. 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 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. The records of the asphalt production and associated fuel are kept by this company on a daily basis. The monthly and annual asphalt production records and calculated emissions data, CO and S02, are compiled by Mr. Colton Ginn, environmental manager. The asphalt plant only combusts natural gas. No fuel oil is combusted or stored at this facility. Compliance with this stipulation is indicated. iv. Reporting Requirements -Within 30 days after each calendar year,regardless of the actual emissions,the permittee shall submit the following: i. emissions and/operational data listed below. The data should include monthly and 12 month totals for the previous 12 month period. A. The tons of asphalt produced for each fuel type, B. The facility-wide CO and S02 emissions. Observed. On January 13,2021,this office received the annual report from this company for calendar year 2020. This company reported the following information: 6.82 tons of carbon monoxide(CO) emissions; 0.01 tons of sulfur dioxide (S02) emissions; 96,883 tons of asphalt produced while combusting natural gas during calendar year 2020. Compliance with this stipulation is indicated. Sloan Construction Co. (A Division of Reeves)—Bonds Plant April 27, 2021 Page 12 1. Condition A. 13. 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 SOz 11 250 Observed. The facility-wide SOz emissions were reported by this company as 0.01 tons during calendar year 2020. Compliance with this stipulation is indicated. in. Condition A. 14. 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) supplied by a DAQ-approved vendor as follows: i. Specifications -The recycled fuel oils have to be equivalent to unadulterated fossil fuel by meeting the following criteria: Constituent/Pro er Allowable Level Arsenic 1.0 ppm maximum Cadmium 2.0 ppm maximum Chromium 5.0 ppm maximum Lead 100 ppm maximum Total Halogens 1000 ppm maximum Flash Point No. 2 100°F minimum No. 4 130°F minimum Sulfur No. 2 0.5%maximum(by weight) No.4 2.0%maximum(by weight) Ash IF1.0%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. Sloan Construction Co. (A Division of Reeves)—Bonds Plant April 27, 2021 Page 13 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. The asphalt plant combusts only natural gas. There is no fuel oil storage at this facility. The annual report for 2020 calendar year indicated that no recycled fuel oilshad been combusted in the rotary drum aggregate dryer at this facility. Compliance with this stipulation is indicated. n. Condition A. 15. Toxic Air Pollutant Emissions Limitation Requirement-Pursuant to 15A NCAC 2Q .0711 "Emission Rates Requiring a Permit" for each of the below listed toxic air pollutants (TAPs),the permittee has made a demonstration that facility-wide actual emissions,where one or more emission release points are obstructed or non- vertically oriented, do not exceed the Toxic Permit Emission Rates(TPERs) listed in 15A NCAC 2Q .0711(a). The facility shall be operated and maintained in such a manner that emissions of any listed TAPs from the facility, including fugitive emissions,will not exceed TPERs listed in 15A NCAC 2Q .0711(a). Chronic Acute Acute Permit Review Pollutant Carcinogens Toxicants Systemic Irritants R00 (lb/yr) (lb/day) Toxicants ( (lb/hr) lb/hr) Benzo(a)pyrene 0.00441 lb/yr (Component of 2.2 83329/POMTV& 56553/7PAH) (50-32-8) Carbon disulfide(75-15- 3.9 0.0134 lb/day 0) Hexane,n-(110-54-3) F 23 F 5.17 lb/day Hydrogen sulfide(7783- 1.7 �F 0.2591b/day Sloan Construction Co. (A Division of Reeves)—Bonds Plant April 27, 2021 Page 14 06-4) MEK(methyl ethyl 0.145 lb/day ketone,2-butanone) (78- 78 22.4 6.03E-03 lb/hr 93-3) Methyl chloroform(71- 250 64 0.259 lb/day 55-6) 1.08E-02 lb/hr Methylene chloride(75- 71600 0 0.00823 lb/yr 09-2) .39 7.40E-06 lb/hr Perchloroethylene 0.0801 lb/yr (tetrachloroethylene) 13000 (127-18-4) Phenol(108-95-2) F__FO.24 F 9.05E-04 lb/hr Styrene(100-42-5) 1 2.7 F 12.16E-04 lb/hr 75 Toluene (108-88-3) F98 F 14.4 lb/day 0.656 6561b/hr �Xylene(mixed isomers) 1.30 lb/day (1330-20-7) F57 F 16.4 0.0543lb/hr Observed. The TPER limits for 2Q .0711(a)apply for the above listed pollutants because these air toxics are emitted as fugitive emissions from the truck loadout and silo filling. The actual emission rates were obtained from the asphalt emissions calculator spreadsheet based on a production of 250,000 tons per year of asphalt at a maximum process rate of 225 tons per hour using recycled No.4 fuel oil(worst case)based in an operation schedule of 24 hours per day, 50 weeks per year and 2,000 hours per year. Compliance with the respective TPER limits is shown in the above referenced table. This company has asphalt production records to verify that the TPERs are not being exceeded. Based on the asphalt production rate of 96,883 tons during calendar year 2020,this asphalt plant will not exceed the TPERs. Compliance with this stipulation is indicated. o. Condition A. 16. "Toxic Air Pollutant Emissions Limitation Requirement"-Pursuant to 15A NCAC 2Q .0711 "Emission Rates Requiring a Permit" for each of the below listed toxic air pollutants (TAPS),the permittee has made a demonstration that facility-wide actual emissions,where all emission release points re unobstructed and vertically oriented, do not exceed the Toxic Permit Emission Rates (TPERs)listed in 15A NCAC 2Q .0711(b). The facility shall be operated and maintained in such a manner that emissions of any listed TAPS from the facility, including fugitive emissions,will not exceed TPERs listed in 15A NCAC 2Q .0711(b). Sloan Construction Co. (A Division of Reeves)—Bonds Plant April 27, 2021 Page 15 Chronic Acute Acute Permit Review Pollutant Carcinogens Toxicants Systemic Irritants R00 (lb/yr) (lb/day) Toxicants (lb/hr) (lb/hr) Acetaldehyde(75-07-0) 1 F—F— 28.43 10.293 lb/hr Acrolein(107-02-8) ��— 0.08 0.00585 lb/hr Arsenic&Compounds 0.14 lb/yr (total mass of elemental AS, arsine and all 0.194 inorganic compounds) (ASC (7778394)) Cadmium Metal, 0.103 lb/yr elemental,unreacted 0.507 (Component of CDC) (7440-43-9) Chromium(VI) Soluble 0.00243 lb/day Chromate Compounds 0.026 (Component of CRC) (So1CR6) Hexachlorodibenzo-p- 3.25E-07 lb/yr dioxin 1,2,3,6,7,8 0.007 (57653-85-7) 7 Hydrogen chloride 0.0473 lb/hr (hydrochloric acid) 0.74 (7647-01-0) Manganese& 1.3 0.04161b/day compounds (MNC) Mercury,vapor 0.0140 lb/day (Component of HGC) 0.025 (7439-97-6) Tetrachlorodibenzo-p- 5.25E-08 lb/yr dioxin,2,3,7,8- (Component of CLDC 0.0002767 & 83329/POMTV) (1746-01-6) Observed. The air toxics that are only emitted from the aggregate dryer and mixer are subject to 2Q .0711(b)because the emission release point is unobstructed and vertically orientated as indicated in the permit application. The actual emission rates were obtained from the asphalt emissions calculator spreadsheet based on a production of 250,000 tons per year of asphalt at a maximum process rate of 225 tons per hour using recycled No. 4 fuel oil(worst case)based in an operation schedule of 24 hours per day, 50 weeks per year and 2,000 hours per year. Compliance with the respective TPER limits is shown in the above referenced table. Sloan Construction Co. (A Division of Reeves)—Bonds Plant April 27, 2021 Page 16 This company has asphalt production records to verify that the TPERs are not being exceeded. Based on the asphalt production rate of 96,883 tons during calendar year 2020,this asphalt plant will not exceed the TPERs. 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. This company does not own or operate any rap crushing, screening, or conveying equipment. However,the portable rap crushing, screening, and conveying operations conducted by an outside contractor at this facility is subject to 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 engines operated at this facility are not subject to NSPS Subpart 1111(41) 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. This company has no boilers, emergency/peak shaving generators, fire pump engines or gasoline storage tanks at this facility. The asphalt plant is not subject to MACT Subpart LLLLL—Asphalt Processing and Asphalt Roofing Manufacturing. The natural gas-fired hot oil heater(ID No. IES5)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 natural gas-fired process heater is not subject to the area source boiler NESHAP Subpart 6J. 9. Summary of changes needed to the current permit: a. This facility replaced the 500 gallon propane storage tank with a 25 pound propane storage tank. The size of the propane storage tank will need to be changed to 25 pounds in the insignificant/exempt activities during the next permit revision. b. The electronic yellowsheet for permit changes needed has been completed and placed in the facility's electronic file. 10. Compliance assistance offered during the inspection: None. 11. Section 112(r) gpplicabilitX: 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. Sloan Construction Co. (A Division of Reeves)—Bonds Plant April 27, 2021 Page 17 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://neconnect.sharepoint.com/sites/DAQ-MRO/Counties/CABARRUS/00172/INSPECT 20210427.doex