AQ_F_1700005_20190507_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: 05/07/2019
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 Steven Ashworth NSPS: Subpart I
Plant Operator General Manager Safety Manager
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 05/07/2019
Inspector's Name Chris Bryant
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
5 J/� Action Code FCE
Date of Signature: / MTH On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP SO2 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 in ounds
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE: None
Date Test Results Test Methods) Source(s)Tested
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Permitted Sources
Emission Emission Source Control Control System
Source ID Description System ID Description
350 tons per hour Hot Mix Asphalt Drum Mix Plant(NSPS),consisting of:
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 �WW4LLY
(116 million Btu per hour maximum heat input) I (10,842 square feet of filter area)
rS2ES2.1,ES2.2 Three(3)hot mix asphalt storage silos —�—
. ES2.4 (200-ton capacity,each)
ES2.3 Cold asphalt storage silo(40-ton capacity) N/A N/A
fES-3- r Truck Loadout Operation
Insignificant/Exempt Activities
Source Exemption Source Source of Title V
Regulation of TAPs? : Pollutants?
II-1 -Natural gas/No. 2 fuel oil-fired hot oil heater 2Q .0102
(1.6 million Btu per hour maximum heat input)
C-2 Fuel oil storage tank(1000-gallon capacity) 2Q A102
�I-3 - Recycled fuel oil storage tank(25,000 gallons) (c)(1)(D)(i) Yes Yes
h-ES6&t-ES7 Two(2)liquid asphalt storage tanks(30,000 gallons capacity,each) r 2Q,0102
1-ES8-Liquid asphalt storage tank(1000 gallons capacity) (c)(1)(L)(xii) j
—J
Introduction
On May 7,2019, Mr. Chris Bryant, Environmental Specialist of the DAQ WSRO,contacted Mr.Carl Mitchell, Plant Operator of
Piedmont Asphalt, LLC of Pelham,North Carolina for an unannounced targeted compliance inspection. Mr. Douglas Dawson,
General Manager,was also briefly present during the inspection. The facility was previously inspected on July 19,2018 by this
inspector and was found 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 currently operates 8-12 hours/day,5-6 days/week,and approximately 44 weeks/year. Based
on the comments from Mr. Dawson and year-to-date production numbers,business at the facility has been steady. No new equipment
has been added since the last inspection. All contact and facility information are accurate as reported in (BEAM.
Safety Equipment
Safety shoes,ear protection,hard hat,safety vest,and eye protection are required within production areas.
Applicable Regulations
According to permit Condition A.1,the 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 1),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 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.
Discussion
Piedmont Asphalt, Inc. is located at 1675 Rock Quarry Road in Pelham,North Carolina near the Shelton Quarry. This drum mix
asphalt plant uses recycled asphalt pavement(RAP), liquid cement, and crushed stone. The RAP and aggregate are deposited onto a
conveyor and fed to the double-barrel drum mixer(ES 1)where the liquid asphalt is added. Currently,the mixer is being run on
natural gas,although it is permitted to burn No.2 fuel oil, recycled No. 2 fuel oil,No.4 fuel oil,and recycled No.4 fuel oil. The
facility has been using natural gas(dedicated line)consistently for the last few years and does not plan on switching fuels. Also onsite
are three hot mix asphalt storage silos ES2.1,ES2.2,and ES2.4(200 tons each). The silos are internally heated with hot oil
recirculation coils that allow the product to be heated until it can be loaded via the single truck loadout operation(ES3). The drum
mixer(ESI)is controlled by bagfilter CD1. Any particulate matter that falls out during the conveying or mixer processes is fed back
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into the drum mixer. Although the mixer, conveyors,and truck loadout emission sources were in use,no visible emission could be
observed. The cold asphalt storage silo is no longer in use.
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(1-2),a 25,000-gallon recycled fuel oil storage tank(1-3),two 30,000-gallon
liquid asphalt storage tanks(I-ES6, 1-ES7)and a 1,000-gallon liquid asphalt storage tank(I-ES8).These exempt items were observed
during this inspection. The asphalt heater was observed combusting natural gas,and the facility is no longer using any fuel oil,
according to Mr. Mitchell.
The facility has previously utilized a portable screener and crusher(owned by Adams Construction of Danville, VA),but this
equipment was not at the facility during the inspection,
Regulations Applicable to this Facility
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 certification sheet, for the 2021 calendar year at least 90 days prior to the expiration of the permit. This
condition was discussed with Mr. Mitchell. 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:
E=4.9445 * (P)°4176 for P<300 tons/hr,or
E=60 Ibs/hr for P>=300 tons/hr
Based on a process rate greater than 300 tons/hr(maximum process rate is 350 tons/hr),the allowable emission rate is 60 lb PM/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.
Zero visible emissions were observed during this inspection. The facility appears to be operation in compliance with the opacity
limits. The most recent stack test, May 19,2017, indicated compliance with the minimum efficiency guidelines. The minimum
controlled efficiency must be at least 99.4%and the last stack test indicated control efficiency of 99.99%. Prior to switching to natural
gas, the previous stack test(5/16/2006)showed that the emissions from the bagfilter stack averaged 8.6 lb/hr. During the most recent
stack test,conducted on May 19,2017,the facility was running at 1.86 lb/hr. Compliance has been demonstrated with this regulation.
Condition AA contains the 15A NCAC 2D .0516"Sulfur Dioxide Emissions from Combustion Sources"requirement. The condition,
applicable to the drum mixer(ES I)and hot oil heater(1-1),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,Caroline
Sun, 6/1/2015)were used to calculate emissions for the hot oil heater when combusting natural gas and No. 2 fuel oil. AP-42 Table
1 1.1-7 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 I-1:
SO2 Nn=(0.6 lb SO2/MMft'NG)x(ft'NG/1,020 Btu)=0.0006 lb SO21MMBtu
SO2 No.2 F.o._(142 x 0.5 lb SO2/10'gal. F.O.)x(10'gal. F.O./140 MMBtu)=0.51 lb SO2/MMBtu
Drum Mixer ES1:
SO2,NO=(0.0034 lb SO2/ton asphalt)x(350 ton asphalt/hr)= 116 MMBTU/hr=0,010 lb SO2/MMBtu
5O2,N%2 F.G._(0.011 lb SO2/ton asphalt)x(350 ton asphalt/hr)+ 116 MMBTU/hr=0.033 lb SO2/MMBtu
SO2,Nu.4 Fo._(0.058 lb SO2/ton asphalt)x(350 ton asphalt/hr)+ 116 MMBTU/hr=0.I8 lb SO2/MMBtu
Compliance is expected.
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. No visible emissions were observed during this visit. Compliance is expected.
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Condition A.6 contains the 15A NCAC 2D.0524"New Source Performance Standards(NSPS)" required as promulgated in 40 CFR
60, Subpart 1. The rule applies to the barrel drum mixer(ES 1)and sets provisions for notification,testing,reporting,recordkeeping,
and monitoring. The rule applies to all facilities that were constructed or modified after June 11, 1973 (§60.90(b). Office records
indicate that this rule is applicable since the facility was modified on February 2, 1989. Section §60.92 establishes the standards of
particulate matter. The rule states that no operator may discharge any gas which contains particulate matter in excess of 90 mg/dscm
§60.92(l)and that no discharge may exhibit greater than 20%opacity §60.92(2).
The most recent 10-year required stack test was performed on May 19,2017. The test results were reviewed and accepted by the
stationary source compliance branch(SSCB)and indicated that the filterable PM emission were 4.41 mg/dscm. This is below the 90
mg/dscm limit. Zero visible emissions were observed, in compliance with §60.92(2). Compliance is indicated.
Condition A.7 contains the 15A NCAC 2D. 0535 notification requirements. This requires the facility to notify the DAQ of any
malfunctions associated with a source causing an excess of emissions lasting more than four hours. Mr. Mitchell stated that there
have been no such incidents since the prior compliance visit. No notification or complaints have been received by this office
regarding malfunctions or breakdowns. Compliance is expected.
Condition A.8 contains the 15A NCAC 2D.0540 fugitive dust control requirement.No fugitive dust was observed traveling beyond
the property boundaries during this inspection. 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 with this condition is indicated.
Condition A.9 contains the 15A NCAC 2D .0605 testing requirements. This condition requires that the facility demonstrate
compliance with emission limits by testing the applicable sources for specified pollutants. Piedmont Asphalt must meet emission
limits detailed in 15A NCAC 2D .0506, including a 20%visible emission limit(Method 9)and a maximum 60 Ib/hr filterable plus
condensable particulate matter limit. In addition to the initial testing(performed May 15-16,2006),"The Division of Air Quality shall
require emission testing of hot mix asphalt plants at least once every 120 calendar months." Permit 01902R20 established that two
copies of the test results must be submitted to DAQ by December 31,2016. A source testing extension was requested on December
14,2016 and granted on January 6,2017. The extension was granted due to lack of production. The test protocol was received by
DAQ WSRO on March 7,2017.The facility submitted all required protocols,provided in writing a 15-day advanced notice of testing
date,and subsequently performed source testing on May 19,2017. The required stack test was conducted on May 19,2017 and was
observed by Thomas Gray, Environmental Specialist,as well as Paul Williams, formerly of DAQ. The test results were approved by
the Stationary Source Compliance Branch on July 18,2017. The test results concluded that the visible opacity was 0%, and the total
particulate matter(filterable and condensable)emissions were 1.86 Ib/hr(below the 60 Ib/hr limit). The next ten-year test is due by
December 31,2027.Compliance with this condition is expected.
Condition A.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 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 facility uses a"visual-lite test'which indicates leaks by using a blacklight. The results of all inspection and
maintenance activities must be recorded in a logbook. The facility is conducting monthly bagfilter inspection and performing
maintenance as needed and in fact observes and records bagfilter activities on a daily basis. The last monthly inspection records were
noted to be from April 4,2019,and March 11,2019. Detail in the February 2019 records indicated that the reducing sleeve and lining
were replaced. Compliance is expected.
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. There are no previous odor complaints in the IBEAM
database. Compliance with 2D .1806 is expected.
Condition A.12 contains the 15A NCAC 2Q .0309"Termination, Modification,and Revocation of Permits"condition. The permit
may be reopened, modified,or reissued in the event that any credible air emissions data is discovered. Additional emission controls of
restrictions may be required to demonstrate compliance with the condition. Compliance is expected.
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 SO2,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
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also limit asphalt production to 720,000 tons during any consecutive 12-month period. The facility's production rate was 126,087 tons
in the year 2018. Through the first four months of 2019,the total asphalt production is numerically similar to 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 Mr. Mitchell and Mr. Dawson.
The reporting requirements stipulate that that the permittee must shall 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. The 2018 annual report was received on January 30,2019. This report showed that the facility
emitted a total of 0.01 tons of SO2, 1.64 tons of NOx,and 8.36 tons of CO in 2017. The facility produced a total of 126,087 tons in
2018. The report stated that there were not any No.4 fuel oils combusted in 2018. The facility is,and plans on,using solely natural
gas. 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 SO2 emissions to 250 tons in a consecutive twelve-month period. The facility did not exceed these limits in CY
2018(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 30,2019. 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 1. 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 I). 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 its exhaust gases. No visible emissions,
being emitted from this source, were observed during this 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.
This facility does not appear to be subject to any other NSPS/NESHAP regulations at this time.
Facility Wide Emissions
The following emission information is borrowed from permit review R20(Caroline Sun,6/01/2015). The emission summary was
based on fuel production of 118,601 tons and natural gas combustion. The facility-wide emissions are consistent with the synthetic
minor classification.
Pollutant Actual Emissions Potential Emissions ton/ ear
ton/ ear Without Controls or Limits With Controls or Limits
PM 2.04 69.36 12.44
PMio 1,45 40.23 8.84
SO2 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 Tmai 0.34 17.43 4.09
Highest HAP 0.19 4.89 1.50
(Formaldehyde)
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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, 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 Environmental Specialists, Paul Williams and TJ Gray. The test
results, indicating compliance, were received by this office on June 22, 2017 and later approved by the SSCB on July 18, 2017. The
results showed total PM emissions rate(4.41 Ibs/hr),0%average opacity,and average production rate(335 tons/hr).
5 Year Compliance History
This facility has not been issued a NOD,NOV,or NOV/RE in the past 5 years.
Conclusion
Based on the visual observations and review of records during the inspection and subsequent review, Piedmont Asphalt, LLC was
found to be in likely compliance with its Air Quality Permit and other DAQ and federal air quality rules.
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