AQ_F_0500008_20190612_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: Ashe/009
Date: 06/12/2019
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 4/30/2025
Lat: 36d 27.0000m Long: 8 1 d 24.2100m 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
Sean Mackey Wiley Roark Sean Mackey NSPS: Subpart I
Project Manager President Sr. Project Manager
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 06/12/2019
Inspector's Name Robert Barker
Inspector's Signature: < � Operating Status Operating
Compliance Code Compliance- inspection
Action Code FCE
Date of Signature: �/�31/ 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 in poun s
Five Year Violation History:None
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 Emission Sources:
........... ..... .. ..........._.........._................. ... .. ...................................................................................................................
Emission ( Emission Source Control Control System
Source ID Description System ID C Description
.. . ...... . .......... .......... . . ........ . . ...... . .. .........
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One drum mix, hot mix asphalt plant(200 tons per hour maximum rated capacity) including:
__„ .....__ µ._.w..,.ww ._ ....___.__.__..__ __.. ._.. .... ............._...._..w_._ .._. . ��. __._.._ __._ ......._..
HMAPIa Natural gas/No. 2/recycled No. 4 fuel oil-fired rotary drum CS-1 Bag filter(8,679 square
(NSPS) mix asphalt plant(96.8 million Btu per hour burner capacity) 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 capa( _N/A N/A
TL-1 _ 1 Truck load-out operation N/A N/A
W
F
H-1 _._.__.___.__ No. 2 fuel oil-fired liquid asphalt heater N/A N/A
(1.45 million Btu per hour maximum heat input)
Insignificant/Exempt Activities:
_.._....._.__... _. . _......._._,._. . ___... _..____ ..._4..._.. _.._._ _..__ .,..
Re ulat�on Source of Source of
Source p Title V
g TAPS? Pollutants?
�I-3 - Fuel oil above ground storage tank(250 gallon capacity)
I 4 -Fuel oil above ground storage tank(10,000 gallon capacity)
I 5a Liquid asphalt above ground storage tank(20,000_g_allon capacity) 2Q .0102 es i Yes i
1-7 - Fuel oil above ground storage tank(10,000 gallon capacity) _ (g)(4) I
I-8 - Propane above ground storage tank(100 gallon capacity) No I
Introduction
On June 12, 2019, Robert Barker Environmental Engineer of the DAQ-WSRO, contacted Bart Roark, Operations
Manager, and Steven Gentry, Plant Operator, at Maymead Materials, Inc. -Jefferson Plant and conducted a targeted
compliance inspection. 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 5, 2018 by Paul
Williams (formerly of DAQ)and found to be operating in compliance.
Safe
The only protective equipment required at the facility is safety glasses, ear protection, safety shoes, hardhat, and a
reflector vest.
Applicable Regulations
Applicable regulations listed in the permit are 2D .0202,2D .0503,2D .0506, 2D .0516, 2D .0521,2D .0524(40 CFR 60,
Subpart I),2D .0535,2D .0540,2D .0605,2D .0611,2D .1100,2D .1806, 2Q .0315, 2Q .0317(2D .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. It should be noted that the
facility is subject to the General Duty clause of the Section 112(r)program.
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.
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Pollutant Test Results Emission Limit' Standard Compliance'`
Filterable PM 23 m /dscm 90 m dcsm 60 Subpart I Yes
2.39 lbs./hr. --- --- ---
Condensable PM 1.20 lbs./hr. --- --- ---
Total PM 3.59 lbs./hr. 45.03 lbs./hr. 2D .0506 Yes
Visible Emissions 0%Greatest 6-min averse 1 20% 60 Subpart I Yes
Discussion
The facility is permitted for a natural gas/No. 2/recycled No. 4 fuel oil-fired rotary drum mix asphalt plant(HMAPIa).
The asphalt plant was in operation during the inspection. The asphalt plant was combusting natural gas and operating at
149 tons per hour. Mr. Gentry said that the asphalt that was being produced contained about 15% RAP. The asphalt plant
has a bagfilter(CS-1) as a control device. The pressure drop across the bagfilter was at 1.2"with a stack temperature of
288°F. As per 2D .0506, the plant is required to comply with the allowable particulate emission rate, opacity limit, and
control fugitive dust emissions (21) .0540). The facility has an opacity limit of 20% when averaged over a six-minute
period. No visible emissions were observed coming from the stack during the inspection, only some steam. Only a small
amount of dust was observed from the trucks traveling the plant during the inspection. 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 2D .0506 is demonstrated.
The sulfur dioxide emissions from the drum dryer shall not exceed 2.3 Ibs/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 is permitted for two hot mix asphalt storage silos(SILO-1 and SILO-2), a truck load-out operation(TL-1),
and a No. 2 fuel oil-fired liquid asphalt heater. Liquid asphalt is mixed with dried aggregate to produce asphalt. The
asphalt is then conveyed into one of the storage silos and then loaded into asphalt trucks. Several trucks were observed
being loaded, with only a small amount of steam being emitted during the loading of each truck. No visible emissions
were observed coming from the stack for the asphalt heater, indicating compliance with 2D .0521. The sulfur dioxide
emissions from the asphalt heater shall not exceed 2.3 Ibs/million Btu of heat input. Based on the calculations from the
permit review for Air Permit No. 00481 R20, the sulfur dioxide emissions from the combustion of No. 2 fuel oil is 0.51
Ibs/million Btu. Compliance with 2D .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(I-5a), and one 100 gallon propane above ground tank(1-8). During the inspection, all of these
sources were observed 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 pertains to 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 pertains to 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:
Source Emission Limit(lbs/million-Btu)
_..... .: ... .......... ..... .....
No. 2 fuel oil-fired liquid asphalt heater
0.60
(1.45 million Btu per hour maximum heat input)(H-1)
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Based on the permit review for Air Permit No. 00481 R20,the particulate emission rate for No. 2 fuel oil is 0.024
lb/million Btu. Compliance is indicated.
Condition A.7 pertains to 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.
No visible emissions were observed coming from the stack during the inspection,only some steam. 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 pertains to 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 pertains to 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 fugitive dust emissions were observed beyond the property
boundary during the inspection and no dust complaints have been received since the last inspection. Compliance is
indicated.
Condition A.10 pertains to 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. A
review of the records indicate that the facility is doing this. 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 pertains to 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. The
facility's inspection and maintenance records were reviewed and found to be adequate. The last annual internal inspection
was performed in January of 2019. During this inspection, all of the bags and three sections of the tube sheets were
replaced. Compliance is indicated.
Condition A.12 pertains 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 2018,the facility produced
26,994.84 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 2018,the facility combusted 9,656 gallons of No.2 fuel oil in the asphalt heater. I
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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. Using a range finder and calculating for the height of a triangle, it
appears that the height of the bagfilter stack is not less than 21.6 feet. Mr. Gentry said that the bagfilter
stack has not been changed or moved since the last inspection. It should be noted that dispersion modeling
analysis for the plant was conducted in July of 2018. The purpose of the modeling was to correct release
location and to continue to demonstrate compliance guidelines specified in 2D .1104.
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. Using a range finder and calculating
for the height of a triangle,it appears that the height of the hot mix asphalt storage silos is not less than
55.5 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. The height of the asphalt heater stack appears 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.
It should be noted that dispersion modeling analysis for the plant was conducted in July of 2018 . The
purpose of the modeling was to correct release location and to continue to demonstrate compliance
guidelines specified in 2D .1104.
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.
Condition A.13 pertains to 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. During the inspection, no objectionable odors were detected past the facility boundary and no odor complaints
about the facility have been received since the last inspection. Compliance is indicated.
Condition A.14 pertains to regulation 2Q .0315 "Synthetic Minor Facilities." To maintain synthetic minor classification,
the facility-wide emissions shall be less than the following:
Pollutant Emission Limit
(Tons:per consutive 2-mo
ec nth:period)
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 and 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.
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 were reviewed and found to be in compliance.
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The facility is required to report each calendar year quarter,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 April 30, 2019. The report contained all the required data. From April of 2018 through March of 2019,
the facility produced 26,994.84 tons of asphalt. The facility during this time period emitted 2.16 tons of S02 and 1.92 tons
of CO. Compliance is indicated.
Condition A.15 pertains to 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:
Emission Limit
Affected Sources) Pollutant Tons:Per Consecutive 12-monthNPeriod
� c )
_ . _ _ _ _.
Facility Wide ; S02 250
.... . . . __.. ..._ l
According to the facility's first quarter report for 2019, which was received on April 30, 2019, the S02 emissions for the
previous 12 months totaled 2.16 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:
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` Constituent/Piroperty _ a 6 . Allowable'Leve1
I Arsenic 1.0 ppm maximumW_
Cadmium 2.0 ppm maximum
Chromium I 5.0 ppm maximum
.......
Lead 100 ppm maximum
Total Halogens ( 1000 ppm maximum
Flash Point No.4 130OF minimum
Sulfur No.4 2.0%maximum(by weight)
.... ......... .. ....... ........ ......... .........
Ash 1.0%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 pertains to 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. 00481 R20, the actual emission rates are below
the TPERs. Compliance is indicated.
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 2018 fourth quarter report.
���_ fs3 '�s 3 y •j ,t. � s ,,�' vity ��� �'i `- ,a1 Ud] ��rtI8Sl�rlS`y t
PM 2.8
PMip 2.0
S02 2.4
NO, 5.0 '
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,i'„ .„ ., �.,.
s; 2Q16:A.etual,Emissions. t
CO 1.96
VOC 3.8
HAP Total 0.811
HAP Highest(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 is 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(I-7) for No. 4 fuel oil is no longer is service.
Location
Latitude and longitude for this facility were verified.
Conclusion
Based on review of records and visual observations,the facility appeared to be operating in compliance with Air Quality
standards and regulations at the time of this inspection.
It should be noted that the facility was sent a letter dated November 20, 2018 concerning the stack test that had been
conducted on July 30, 2014. The letter stated that the stack test had been conducted below 50% of the permitted
maximum rated capacity and that the facility needed to respond to this by one of two following options.
I. The facility may request that the DAQ administratively amend the Air permit to include a new condition stating that
the facility will be required to retest the asphalt plant within 60 days of exceeding the production rate achieved during
the last source test,plus 10%, or
2. The facility may request to perform an immediate retest in order to test at or above 90%of the permitted maximum
rated capacity or test at or above 50%of the permitted maximum rated capacity while demonstrating particulate
matter emissions at or less than 25% of the standard.
The facility requested for an Administrative Amendment for the air permit based on the letter dated November 20, 2018.
The condition was added in Air Permit No. 00481 R21 dated March 15, 2019.
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