AQ_F_0500008_20200427_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Winston-Salem Regional Office
AIR QUALITY Maymead Materials,Inc.-Jefferson Plant
NC Facility ID 0500008
Inspection Report County/FIPS:A$he/009
Date: 04/27/2020
Facility Data Permit Data
Maymead Materials,Inc.-Jefferson Plant Permit 00481 /R21
2522 NC Highway 16 North Issued 3/15/2019
Crumpler,NC 28617 Expires 4/30/2,,025
Lat: 36d 27.0000m Long: 81d 24,2100m Class/Status Synthetic Minor
SIC: 2951 /Paving Mixtures And Blocks Permit Active
NAICS: 324121 /Asphalt Paving Mixture and Block Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Sean Mackey Wiley Roark Sean Mackey NSPS: Subpart'I
Project Manager President Sr.Project Manager
[phone] [phone] [phone]
Compliance Data
Comments: PCE conducted due to COVID-19 restrictions.
Inspection Date 04/27/2020
Inspector's Name Robert Barker
Inspector's Signature: �✓�� �1 1~. ��,, Operating Status Operating
Compliance Code Compliance-inspection
Action Code PCE
Date of Signature: //21 12-0 MTH On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2016 1.40 4.40 2.50 1.90 5.30 1.0000 249.80
2011 1.26 2.16 1.56 0.1100 3.47 1.26 45.10
*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

Permitted Emission Sources:
Emisslon EmIs�16nSource yr ontrol Control S stern
Source ID Descrlptlon .A Sys ecrlpti
v
One drum mix,hot mix asphalt plant(200 tons per
hour maximum rateedd c capapacity)Including:
HMAPla Natural gas/No.2/recycled No. 4 fuel oil-fired rotary drum CS-1 Bagfilterr((8,679 square
(NSPS) mix asphalt plant(96.8 million Btu per hour burner capacity)C -1 feet of filter area)
SILO-1 Hot mix asphalt storage silo(150 tons capacity) N/A N/A
SILO-2 Hot mix asphalt storage silo(150 tons capacity) N/A N/A
TL-1 _ Truck load-out operation N/A N/A
H-1 No.2 fuel oil-fired liquid asphalt heater N/A N/A
(1.45 million Btu per hour maximum heat input)
Insisnificant/Exempt Activities:
`` ' Exemption "On cc
Source of Tit,le V
°Source;
Regulation TAPS? Pollutants?
1-3 -Fuel oil above ground storage tank(250 gallon capacity)
1-4-Fuel oil above ground storage tank(10,000 gallon capacity)
� 2Q '0102 Yes
1-5a Liquid asphalt above ground storage tank(20,000 gallon capacity) Yes
I 7-Fuel oil above ground storage tank(10,000 gallon capacity) (g)(4)
I 8`-Propane above ground storage tank(l 00 gallon capacity) No
Introduction
On April27,2020,Robert Barker Environmental Engineer of the DAQ-WSRO,contacted Steven Gentry,Plant Operator,
at Maymead Materials,Inc. -Jefferson Plant and conducted a partial compliance evaluation(PCE). Due to the COVID-19
restrictions,Mr.Barker contacted Mr. Gentry by telephone. It should be noted that Mr.Barker had previously contacted
Mr. Sean Mackey,Project Manager,on April 21,2020 concerning the PCE for the facility. The authorized, invoice,
facility,and technical contacts have not changed. The plant is a drum mix asphalt plant with a maximum capacity of 200
tons per hour. The facility only operates a few months out of the year and only when asphalt is needed in that immediate
area. The facility was previously inspected on June 12,2019 by this inspector and found to be operating incompliance.
Safety
The only protective equipment that may be required at the facility is safety glasses,ear protection, safety shoes,hardhat,
and a reflector vest.
Applicable Reimlations
Applicable regulations listed in the permit are 2D .0202,2D .0503,2D .0506,2D .0516,2D .0521,2D .0524(40 CFR 60,
Subpart 1),2D .0535,2D .0540,2D .0605, 2D .0611,2D .l 100,2D .1806,2Q .0315,2Q .0317(21) .0530 and 2Q .0700
Avoidance)and 2Q .0711. The facility is not subject to the RMP requirements of the 112(r)program since it does not use
or store any of the regulated chemicals in quantities above the threshold levels in the rule. However,the facility is subject
to the General Duty clause of the Section 112(r)program.
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Stack Tests
A stack emissions test was performed at this facility on July 30,2014 to demonstrate compliance with 40 CFR Part 60,
Subpart I. The test results,which demonstrated compliance, are summarized in the table below.DAQ Stationary Source
Compliance Branch(SSCB).approved the test results on December 16,2014.
ffm MAN
z Filterable PM 23 m /ds cm 90 m dcsm 60 Subpart I Yes
2.391bs./hr. / - -- _
Condensable PM 1.20 lbs./hr. --- -- ---
Total PM 3.591bs./hr. 45.03 lbs,/hr. 213.0506 Yes
Visible Emissions 0%Greatest 6-min average 20% 60 Subpart I Yes
Discussion
The facility has a natural gas/No.2/recycled No.4 fuel oil-fired rotary drum mix asphalt plant`(HMAP1a)listed on the
permit. Mr.Gentry said that the asphalt plant was in operation during the phone call The asphalt plant was combusting
natural gas and operating at 150 tons per hour. "Mr. Gentry,said that the asphalt that was being produced contained.about
27%RAP. The asphalt plant has a bagfilter(CS-1)as a control device. The pressure drop across the'bagfilter was'at 2,0"
with a stack temperature of 280°F. As per 2D .0506,the plant is required to comply with the allowable particulate
emission rate,opacity limit,and control fugitive dust emissions,(213 .0540). The facility has an opacity limit of 20%
when averaged over a six-minute period. Mr. Gentry said that there were no visible emissions coming from the stack,
only some steam. Based on stack test data from July 30,2014,particulate emissions from the dryer/mixer were 3.59
pounds per hour and visible emissions were 0%opacity. The total particulate matter limit is calculated to be 45.03
pounds per hour. Compliance with 213 .0506 is demonstrated. The sulfur dioxide emissions from,the drum dryer shall not
exceed 23 lbs/million Btu of heat input. Since the sulfur dioxide emissions from the combustion of natural gas are
negligible,compliance with 2D .0516 is indicated. -
The facility has two hot mix asphalt storage silos(SILO=1 and SILO-2), a truckload-out operation(TL-1),and a No.2
fuel oil-fired liquid asphalt heater listed on the permit. Liquid asphalt is mixed with dried aggregate to produce as
The asphalt is then conveyed into one of the storage silos and then loaded into asphalt trucks. Mr. Gentry said that there
was no visible emissions coming from the stack for,the asphalt heater. Since this emission source was not observed and
based on previous inspections, compliance with the D .0521 is expected. The sulfur dioxide emissions from the asphalt
heater shall not exceed 2.3 lbs/million Btu of heat input. Based on the calculations from the permit review for Air Permit
No. 00481R20,the sulfur dioxide emissions from the combustion of No. 2 fuel oil is 0.51 lbs/million Btu. Compliance
with 213 .0516 is indicated.
The facility has five insignificant sources listed on the permit. They consist of a 250 gallon fuel oil above ground storage
tank(I-3),two 10,000 gallon fuel oil above ground storage tanks(I-4 and I-7),one 20,000 gallon liquid asphalt above
ground storage tank(1-5a),and one 100 gallon propane above ground tank(1-8). Mr.Gentry said that all of these sources
were still on-site. It should be noted that recycled No. 4 fuel oil storage tank(I-7),is no longer used.
Permit Conditions
Condition A.2_deals with the requirements for regulation 2D .0202"Registration of Air Pollution Sources." The permit
for this facility expires on April 30,2025. At least 90 days prior to the expiration of this permit,the Permittee shall
submit a permit renewal and an emissions inventory for the 2023 calendar year. Compliance is expected.
Condition A.3 deals with the requirements for regulation 2D .0503 "Particulates from Fuel Burning Indirect Heat
Exchangers." This rule applies to the No.2 fuel oil-fired liquid asphalt heater. Particulate matter emissions from this fuel
burning indirect heat exchanger shall not exceed the allowable emission rate listed below:
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'x � z W 1 B
No 2 fuel oil fired liquid asphalt heater 0.60
�^ (1.45 million Btu per hour maximum heat input) H 1
.. .� ... .................
Based on the permit review for Air Permit No. 00481R20,the particulate,emission rate for No. 2 fuel oil is 0.024
lb/million Btu. Compliance is indicated.
Condition A.7 deals with the requirements for regulation 2D .0524"New Source Performance Standards." The
dryer/mixer is subject to 40 CFR 60, Subpart I. The facility has NSPS emission limitations,and shall not discharge or
cause the discharge into the atmosphere from any affected source any gases,which:
i. Contain particulate matter in excess of 90 mg/dscm; or
ii. Exhibit 20 percent opacity,or,greater.
The facility performed a stack test for the plant on July 30,2014. The results of the stack test were reviewed by SSCB
and were found acceptable. The test results showed that the affected source gases contained particulate matter of 23
mg/dscm and the highest 6-minute average for opacity was 0%. Compliance was indicated.
Condition A.8 deals with the requirements for regulation 2D .0535 "Excess Emissions Reporting and Malfunctions." The
facility is to notify DAQ of a malfunction or breakdown requiring more than four hours to repair resulting in excess
emissions. Since the last inspection,no notifications have been received. Compliance is indicated.
Condition A.9 deals with the requirements for regulation 2D .0540"Particulates from Fugitive Dust Emission Sources."
This condition states that the Permittee shall not cause or allow fugitive dust emissions to cause or contribute to
substantive complaints or excess visible emissions beyond the property boundary. No complaints of fugitive dust
emissions have been received since the last inspection. Compliance is indicated.
Condition.A30 deals with the requirements for regulation 2D .0605 and deals with a"Testing Requirement." As per this
regulation,the facility conducted a stack test on July 30,2014 and demonstrated compliance with the emission limits at an
asphalt production rate of 155.9 tons per hour. The facility, is required to maintain daily records(each day of operation)
showing the total daily production in tons,the hours of operation,and the highest targeted hourly production rate for that
day. Mr. Mackey emailed Mr.Barker'a copy of these records for review and they appeared to contain all the required
information. If a production rate exceeds the production rate shown above,plus ten percent,the facility shall notify DAQ
within 15 days. If a'production rate exceeds the production rate shown above,plus ten percent,the facility shall test the
emission source within 60 days. The'facility is aware of these,requirements. The facility shall test the asphalt plant and
submit two copies of the test results to DAQ by December 31,2024. Compliance is expected.
Condition A.11 deals with the requirements for regulation 2D .0611 "Fabric Filter Requirements." To ensure that
emissions do not exceed the regulatory limits,the Permittee shall perform,at a minimum, an annual internal inspection of
the bagfilter system. Mr.Mackey emailed Mr. Barker a copy of the annual inspections. The last annual internal
inspection was performed in June 16,2019. During this annual inspection,the facility replaced one hanger bearing on the
bottom auger. Compliance is indicated.
Condition A.12 deals with the requirements for regulation 2D .1100"Control of Toxic air Pollutants." In this condition,
the facility has limits it shall not exceed. To ensure compliance with these limits,the following restrictions shall apply:
i. Hot mix asphalt production shall not exceed 491,000 tons per calendar year. For 2019,the facility produced
27,293.10 tons of asphalt.
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ii. The amount of No.2 fuel oil combusted in the liquid asphalt heater(ID No.H-1)shall not exceed 27,005 gallons
per calendar year. For 2019,the facility combusted 6,700.00 gallons of No.2 fuel oil in the asphalt heater.
iii. The height of the bagfilter(ID No. CS-1) stack shall not be less than 21.6 feet and it shall be.located at UTM
coordinates 17N 463833.00 4033957.00. Based on the last compliance inspection,the height of the bagfilter
stack was measured to be not less than 21.6 feet..Mr.Gentry said that the bagfilter stack has not been
changed or moved since the last inspection.
iv. The height of the two hot mix asphalt storage silos(ID Nos. SILO-1 and SILO-2)stack shall not be less than 58
feet and shall be located at UTM coordinates 17N 463864.00 4033961. Based on the last compliance
inspection,the height of the hot mix asphalt storage silos were measured to be not less than 58.feet. Mr.
Gentry said that the silos have not been changed or moved.
V. The height of the liquid asphalt heater ID No.H-1)stack shall not be less than 9 feet and shall be located at UTM
coordinates 17N 463833.00 4033949.00. Based on the last compliance inspection,the height of the asphalt
heater stack appeared to be not less than 9 feet. Mr. Gentry said that the asphalt heater stack has not been
changed or moved since the last inspection.
vi. If any actual(as-built)values(coordinates)differ from those used in the modeling analysis submitted by the
Permittee to DAQ on July 5,2013,and revised on May 19, 2016 and July 3,2018,the Permittee shall notify the
DAQ and provide the new values. The DAQ will re-evaluate the validity of the original modeling analysis and
notify the Permittee in writing whether additional modeling is required. The Permittee shall not operate the
affected sources until written approval from the DAQ is received. Mr. Gentry said that none of the equipment
at the facility has been moved.
The facility is required to report within 30 days of each calendar year quarter,the total amount of hot mix asphalt
produced, and the total amount of No.2 fuel oil combusted in the liquid asphalt heater from the beginning of the calendar
year. The last report was received on January 3,2020. The report contained all the required data. From January of 2019
through December of 2019,the facility produced 27,293.10 tons of asphalt and combusted 6,700.00 gallons in the asphalt
heaters. Compliance is indicated.
The facility,is also required to record the monthly quantity of hot mix asphalt produced and No. 2 fuel oil combusted in
the liquid asphalt heater. Mr.Mackey emailed Mr.Barker a copy of these records,which were reviewed. Compliance is
indicated.
Condition A.13 deals with the requirements for regulation 2D .1806"Control and Prohibition of Odorous Emissions."
The facility shall prevent odorous emissions from the facility from causing or contributing to objectionable odors beyond
the facility's boundary. No odor complaints about the facility have been received since the last inspection. Compliance is
indicated.
Condition A.14 deals with the requirements for regulation 2Q .0315 "Synthetic Minor Facilities." To maintain synthetic
minor classification,the facility-wide emissions shall be less than the following:
i
E
e o '
SOz 100
CO 100
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To ensure that emissions do not exceed these limits,the facility has operational restrictions. The sulfur content of the fuel
oils combusted shall be limited to 0.5%sulfur and the production of asphalt shall be less than 491,000 tons per .
consecutive 12-month period. A review of the records emailed to Mr. Barker and a review of previous fuel certification
sheets indicate that the facility did not exceed the 491,000 tons per consecutive 12=month period and sulfur content of the
fuel oil did not exceed 0.5%sulfur by weight. Mr. Gentry said that the facility has not received any recycled No. 4 fuel
oil since the last inspection. The facility is required to record monthly and total annually the amount of asphalt produced
in tons and keep fuel supplier certifications on-site. The records emailed,to Mr.,Barker were reviewed and found to be in
compliance.
The facility is required to report within 30 days of each calendar year,the monthly and 12-month totals of S02 and CO
emissions,asphalt produced for the previous 12-month period,and submit a summary of fuel certification records. The
last report was received on January 3,2020. The report contained all the required data. From January of 2019 through
December of 2019,the facility produced 27,293.10 tons of asphalt. The facility during this time period emitted 0.0 tons of
S02 and 1.95 tons of CO. Compliance is indicated.
Condition A 15 deals with the requirements for regulation 2D .0530"Prevention of Significant Deterioration." In
accordance with 2D .0317,to comply with this permit and avoid applicability to 2D .0530,the facility shall be limited as
follows:
M01� 1
Facili Wide SOz 250
ri _
According to the facility's first quarter report for 2020,which was received on April 7,2020,the S02 emissions for the
previous 12 months totaled 0.00 tons. Compliance is indicated.
Condition A.16 deals with"Vendor Supplied Recycled No(s).4 Fuel Oil Requirements." In accordance with 2Q .0317,
the Permittee is avoiding the applicability of 2Q .0700 by using recycled fuels which are equivalent to virgin counterparts.
The Permittee is allowed to use recycled fuel oil that meet the following criteria:
Arsenic 1.0 ppm maximum
Cadmium 2.0 ppm maximum
I ... ..,.. ....Chromium 5.0 ppm maximum
Lead 100 ppm maximum
Pp.. ..
Total Halogens
1000 m maximum
g..
Fla.shm Pomt No 4 130OF munum
_-.. .. _ ., m.
Sulfur No.4 2.0%maximum(by weight)
Ash 1.0/o maximum
The facility is required to maintain records of the actual amount of recycled fuel oil delivered to and combusted on an
annual basis and a delivery manifest document for each shipment. As per Mr. Gentry,the facility has not received or
combusted any recycled No.4 fuel oil since the last inspection and does not plan on it.
Condition A.17 deals with the requirements for regulation 2Q .0711 "Emission Rates Requiring a Permit." Pursuant to
2Q .0711, for each of the TAPs listed in the permit,the Permittee has made a demonstration that facility-wide'actual
emissions do not exceed the TPERs listed in 2Q .0711. As per the permit review for Air Permit No. 00481R20,the actual
emission rates are below the TPERs. Compliance is indicated.
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Facility-Wide Emissions
The emissions below were taken from the 2016,Emissions Inventory,with the exception of S02 and CO. They were taken
from the 2019 annual report.
PM 2.8
PMI0 2.0
S02 0.0
NO, 5.0
CO 1.95
VOC 3,8
HAP Total 0.811
HAP AI hest (Formaldehyde) 0.25
Compliance History for the last five years
February 5,2018-NOD for late submittal of a quarterly report. The report was received on time(January 30,2018),but
contained exceedance of the total annual allowable amount of No.2 fuel oil combusted in the asphalt heater(H-1). The
allowable amount was 27,005 gallons and the facility reported 46,626 gallons. The facility responded to the NOD on
February 14,2018 and stated that the facility combusted 14,400 gallons of fuel oil in the asphalt heater for 2018.
MACT and GACT Applicability Determination
The facility does not currently appear to be subject to any MACTs or GACTs at this time.
Permit Issues
The 10,000 gallon above ground storage tank(1-7)for No.4 fuel oil is no longer is service.
Location
Latitude and longitude for this facility were verified.
Conclusion
At the time of the PCE,the facility appeared to be operating in compliance with Air Quality standards and regulations.
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