AQ_F_1700005_20200527_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: 05/27/2020
Facility Data Permit Data
Piedmont Asphalt,LLC Permit 01902/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
NAICS: 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]
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Compliance Data
Comments:PCE due to COVID-19 restrictions.
Inspection Date 05/27/2020
�� Inspector's Name Blair Palmer
Inspector's Signature: --, ..._ Operating Status Operating
Compliance Code Compliance-inspection
Action Code PCE
Date of Signature: 05/29/2020 MTH On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
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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 in ounds
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Five Year Violation History:None j
Date Letter Type Rule Violated Violation Resolution Date
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Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
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Permitted Sources:
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J..SourceID s esripi4 temaID y s Des tion
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�.�,<,..; „�,.,.,;:..a..,a�.,.�,�.,.�.� „ � .H"+�.: ...,.,r„,.:»- �..,,,,...<,wF .,..�rF,.,,.� ,�..,.>.,.»...«.��..�. ,ai .,��c.� x �.,�a.�a��,.$• 7�, ,,,,�.:sw..a,.:z �n�» �',;� Z, ',
Natural gas/No. 2 fuel oil/used No. 2 fuel oil/No.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)
ra:
Three(3)hotmix asphaltstorage silosd 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:
.........._ ... ...... . ........... ... __ ....... _....._...
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_,,_, �.�� -,..., ,<, - \�„ `• :,., .. ;.�I+'. _ 4 �� �a�, e.l ..�� � �-,., �:� s.Q_p iltantS .,
I-1 -Natural gas/No.2 fuel oil-fired hot oil heater 2Q .0102 (c)(2)(B)(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
_._... .....__ ....... . ........ .___ ........................__...._................................. _ — _._._.. _.._.._
I ES6&I-ES7 Two(2) liquid asphalt storage tanks(30,000
gallons capacity,each) _ 2Q .0102 (c)(1)(L)(xii)
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I-ES8-Liquid asphalt storage tank(1000 gallons capacity)
Introduction:
On May 13,2020,Mr.Blair Palmer,Environmental Specialist of the DAQ WSRO,contacted via email and phone Mr.
Julian Stinson,HSE of Piedmont Asphalt,LLC located in Pelham,North Carolina for the purpose of Partial Compliance
Evaluation(PCE)due restrictions due to COVID-19. All information asked for was received on May 27,2020, and as
such,this is the date of the PCE. Mr. Stinson stated in May 14,2020 email..."The plant is now operational.There are no
problems at this time and there have been no drastic changes." The facility was previously inspected(Full Compliance
Evaluation)on May 7,2019 by WSRO-DAQ personnel and it appeared to be operating in compliance will all applicable
Air Quality standards and regulations at that time. The facility is a drum-mix asphalt plant and generally operates 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. f
Most contact and facility information are accurate as reported in IBEAM, except Julian Stinson has been changed in
IBEAM as the new technical contact.
Safety Equipment while onsite:
Safety shoes,ear protection,hard hat, safety vest,and eye protection are required within production areas.
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Applicable Regulations:
According to permit Condition A.1 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 .0540,2D .0605,2D .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:
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 j
controlled with one large bagfilter(CD 1). Pulsed air causes the collected particulate to fall into the bag filter's collection j
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 two,adjacent, electrically heated storage silos(ES2.1,ES2.2, and ES2.4).
There is a separate truck loadout(ES3). Because of COVID-19,Mr. Palmer was not able to verify operations.
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(1-1), 1,000-gallon fuel oil storage tank(I-2),a 25,000-gallon recycled fuel oil storage tank(I-
3),two 30,000-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 last inspection. The asphalt heater was observed combusting natural gas,
and the facility is no longer using any fuel oil, according to last inspection report and it was confirmed during this
inspection.
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 file. j
Applicable Facility Regulations:
Condition A.2 contains the 15A NCAC 2D .0202,Permit Renewal and Emissions Inventory requirements.The permit was
issued on June 1, 2015 and will expire on May 31,2023. The facility is required to submit a renewal request and air
pollution emission inventory report,with a signed certification page from facility,for the 2021 calendar year at least 90
days prior to the expiration of the permit. The facility will be inspected at least once more before expiration.
Compliance is expected.
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:
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E=4.9445 * (P)1.4111 for P<300 tons/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 a 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 it is assumed fugitive emission are being controlled.
Condition A.4 contains the 15A NCAC 2D .0516"Sulfur Dioxide Emissions from Combustion Sources"requirement.
The condition,applicable to the drum mixer(ES 1)and hot oil heater(I-1), sets the maximum allowable sulfur dioxide
emissions rate to be less than 2.3 pounds per million Btu heat input. The emission factors from AP-42 Table 1.3-1
(borrowed from permit review R20,Ms. Caroline Sun, 6/l/2015)were used to calculate emissions for the hot oil heater
when combusting natural gas and No.2 fuel oil.AP-42 Table 11.1-7 was used to calculate emissions for the drum mixer
when combusting natural gas,No. 2 fuel oil,and No. 4 fuel oil. The following emission rates, based on fuel type, are
listed below:
Hot oil heater 1-1:
S02 NG=(0.6 lb S02/MMft3 NG)x(ft3 NG/1,020 Btu)=0.0006 lb SO2/1\4MBtu
SO2 No.2 F.o. _(142 x 0.5 lb S02/10' gal.F.O.)x(10' gal. F.O./140 MMBtu) =0.51 lb S02/MMBtu
Drum Mixer ES I:
S02,NG=(0.0034 lb S02/ton asphalt)x(350 ton asphalt/hr)_ 116 MMBTU/hr=0.010 lb SO2/MMBtu
SO2,No,2 F.O._(0.011 lb SO2/ton asphalt)x(350 ton asphalt/hr)_ 116 MMBTU/hr=0.033 lb S02/MMBtu
S02,No,4 F.O._(0.058 lb SO2/ton asphalt)x(350 ton asphalt/hr)- 116 MMBTU/hr=0.18 lb SO2/MMBtu
Compliance is expected.
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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. Any possible visible emissions were not observed during PCE due to no on-site
inspection. Compliance cannot be determined at this time;however,the previous inspection report(FCE)indicated no j
visible emissions.
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
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:
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Pollutant EPA
d Emissions Emissions Limit Regulation Compliance
Filterable PM 5 4.41 mg/dscm 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 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. 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.Compliance f
with this condition is likely indicated.
Condition A.10 contains the 2D .0611 requirements for bagfilter maintenance and recordkeeping. The bagfilter(CD 1) is
subject to this rule. The facility is required to perform,at a minimum, 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 j
noted to be from March and May 19, 2020,with no problems noted after looking at bags. Compliance is expected. The
facility appears to have a differential pressure gauge,but the information is not recorded in their documentation. It is
unclear what the normal operating range for the bagfilter system.
Condition A.11 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.No on-site
inspection was conducted due to COVID-19. There are no previous odor complaints in the IBEAM database. Compliance
with 2D .1806 is likely.
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. Compliance is expected.
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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 SOz,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. Through the first four months of 2019,the total asphalt production is numerically like previous years' values.
These production totals are below the 720,000 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 PCE.
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
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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. Thus far in 2020,up thru May 14,
2020,the facility produced 19,893 tons,with no production occurring either January of February. 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 SO2, 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.
Condition A.14 contains the 2D .0530,"Prevention of Significant Deterioration Requirements." The facility must,to
remain compliant, limit its facility wide S02 emissions to 250 tons in a consecutive twelve-month period. The facility did
not exceed these limits in CY 2019(0.01 tons). Compliance with this condition is indicated.
Condition A.15 contains the 2Q .0317,"Vender Supplied Recycled Nos. 2 and 4 Fuel Oil Requirements." The condition
establishes criteria for maximum concentration levels of arsenic, cadmium,chromium, lead,total halogens,flash point,
sulfur,and ash for combusted recycled fuel. The facility must also maintain records of the amount annual amount of
recycled fuel oil(s)delivered and combusted. Each delivery of recycled fuel oil must have a manifest,batch specific
analytical report,batch signature information and certification indicating that the recycled fuel oil does not contain
detectable PCB's greater than or equal to 2 ppm. The facility must also submit an annual report within 30 days after each
calendar year the fuels testing summaries and total gallons of recycled fuel combusted. According to Mr.Dawson,this
facility no longer combusts any recycled No.2 or recycled No.4 fuel oil in any of its processes. A statement in the regard
was submitted in the annual report,received January 30, 2020(postmarked January 27, 2020). Compliance with this
condition is indicated.
NSPS/NESHAP:
The facility is subject to 15A NCAC 2D .0524"New Source Performance Standards(NSPS)"required as promulgated in
40 CFR 60, Subpart I, "Standards of Performance for Hot Mix Asphalt Facilities."The specifics of the regulation are
discussed in detail under Condition 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(ES 1). 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.
This facility does not appear to be subject to any other NSPS/NESHAP regulations at this time. 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.
Facility Wide Emissions:
The following emission information is borrowed from permit review R20 (Caroline Sun,6/01/2015-former WSRO DAQ
Environmental Engineer). The emission summary was based on natural gas combustion and production of 118,601 tons.
Based on review of annual reports since 2015,production on average is slightly higher, but facility-wide emissions are
consistent with the synthetic minor classification.
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$� Actual Emissions Potential Emissions ton/ ear
Pollutant ;. Without ontrgls or Limits ?ith Goo ntrols�or A ton/ ear f mrts
PM 2.04 69.36 12.44
PMI0 1.45 40.23 8.84
S02 0.0074 967.01 98.68
NOx 1.81 85.32 20.80
CO 8.09 203.42 47.96
VOC 2.87 73.75 17.33
HAP Total 0.34 17.43 4.09
Highest HAP 0.19 4.89 1.50
(Formaldehyde)
Previous Stack Testing:
Initial stack testing was performed at this facility on May 15-16, 2006. The initial protocol was received by DAQ WSRO
on March 21, 2006. The Stationary Source Compliance Branch(SSCB)approved the protocol, on May 1,2006. The final
report was received by DAQ WSRO on June 14,2006 and was found to be acceptable,by SSCB,on October 27,2006. The
results showed total PM emissions rate (8.6 lbs/hr), 0% average opacity, and average production rate (320 tons/hr), as
compliance was indicated.
Permit Condition A.9 stipulated that the facility should perform and submit required testing protocols results to DAQ by
December 31, 2016: The facility requested (on 12/14/2016) and was granted a 6-month testing extension on January 7, I
2017. The new test deadline was set to July 31, 2017. After protocols and notices were appropriately submitted, a source
test was performed at the facility on May 19, 2017. The test was observed by WSRO-DAQ personnel. The test results,
indicating compliance, were received by this office on June 22, 2017 and later approved by the SSCB on July 18, 2017. j
The results showed total PM emissions rate (4.41 lbs/hr), 0% average opacity, and average production rate (335 tons/hr).
Based on current DAQ guidance,testing is to be conducted every 10 years or for this facility,May 30,2027. A test deadline
will need to be added once the permit is updated with R21, since the test module is tied to permit revision.
Compliance History within last five years:
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• This facility has not been issued a Notice of Deficiency(NOD)or a Notice of Violation(NOV).
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Permit Discussion:
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• 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.
Conclusion:
Based on information received email,and some phone conversation with Mr. Stinson as part of the PCE,this permitted
appears to be in compliance with its Air Quality Permit, including applicable DAQ and federal air quality rules.
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