HomeMy WebLinkAboutAQ_F_1300101_20190620_ST_STO-Rpt NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Blythe Brothers Asphalt Co.,LLC-Concord Plant
NC Facility ID 1300101
Stack Test Observation Report County/FIPS: Cabarrus/025
Date: 06/20/2019
Facility Data Compliance Data
Blythe Brothers Asphalt Co.,LLC-Concord Plant Observation Date 06/20/2019
660 Goodman Road Observer's Name Donna Cook
Concord,NC 28027 Operating Status Operating
Lat: 35d 24.3970m Long: 80d 42.001 Om Action Code 23/STACK TEST
SIC: 2951 /Paving Mixtures And Blocks OBSERVED
NAICS: 324121 /Asphalt Paving Mixture and Block Manufacturing
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 07449/RI 1
Tye Pickett Frank Blythe Alec Blythe Issued 2/20/2018
Plant Foreman Member Manager Air Quality Manager Expires 1/31/2026
(704)784-5589 (704)588-0023 (704)588-0023 Classification Synthetic Minor
Permit Status Active
Inspector's Signature: o a Coo Comments:
Date of Signature: ',2 7-/ 9
Type Action: _Full Compliance _Partial Compliance _Complaint X Other: Stack Test Observation
Evaluation Evaluation/Reinspection Investigation Tracking#2019-158ST
Data Tracking: X Date submitted for initial review 06/24/2019. _IBEAM WARNING/OB,NOD,NOV,NRE
X IBEAM Document
IBEAM Inspection, list date inspected _IBEAM LAT/LONG,Facility Locked
IBEAM Inspection, list date draft is submitted _IBEAM LAT/LONG, Coordinates checked
IBEAM Inspection,pollutants/programs checked _IBEAM Complaint
L —IBEAM Planning,Next Inspection Date
Directions: From Mooresville Regional Office to Concord,travel Highway 3 South;turn right on Odell
School Road;turn right on Poplar Tent Road and make a U-turn at the next stop light; and 0.7 mile turn
left on Goodman Road(road prior to Interstate 85); and 0.2 mile on the left is entrance to the asphalt
plant. The street address of the asphalt plant is 660 Goodman Road.
Safety Equipment: This company has no safety requirements at this facility. It is recommended that
steel toe shoes, hard hat, safety vest and hearing protection be worn by the inspector at the asphalt plant.
Safety Issues: Inspector should be cautious of heavy equipment and truck traffic at the asphalt plant.
Blythe Brothers Asphalt Co.,LLC—Concord Plant
June 20,2019
Page 2
Background:
Blythe Brothers Asphalt Co., LLC operates a counterflow drum mix asphalt plant (ID No. ES-1). The
permitted maximum rated capacity of the drum mix type asphalt plant is 350 tons per hour. The
permitted maximum heat input rating of the rotary drum aggregate dryer is 116 million Btu per hour. The
particulate matter emissions from the rotary drum aggregate dryer are controlled by one cyclone (ID No.
CD-1; 8 feet in diameter) installed in series with a bagfilter (ID No. CD-2; 12,818 square feet of filter
area). The operational schedule of the asphalt plant is solely dependent upon weather conditions and
customer orders.
Natural gas is the primary fuel source for the rotary drum aggregate dryer. No. 2 fuel oil, recycled No. 2
fuel oil, and No. 4 fuel oil are listed in the permit description as the backup fuel sources for the rotary
drum aggregate dryer. No. 4 recycled fuel oil is the backup fuel source for the rotary drum aggregate
dryer. No. 4 fuel oil was last combusted in the rotary drum aggregate dryer on January 31, 2014, due to
natural gas curtailment by the supplier.
The hot mix asphalt plant(ID No. ES-1) is limited to 90 milligrams per dry standard cubic meter
(mg/dscm) or 0.04 grains per dry standard cubic foot(gr/dscf)for filterable particulate matter and visible
emissions to 20%opacity as required by 40 CFR Part 60, Subpart I and Air Permit No. 07449RI 1,
Specific Condition and Limitation No. A. 6. (15A NCAC 2D .0524 NSPS). This company is required to
demonstrate compliance with the above referenced emission limits by testing the hot mix asphalt plant(ID
No. ES-1)using EPA Reference Methods 5 for filterable particulate matter, Method 202 for condensable
particulate matter and Method 9 for visible emissions (ve) as required by Air Permit No. 07449R11,
Specific Condition and Limitation No. A. 9. "Testing Requirement." Two copies of the test results are
required to be submitted to MRO DAQ regional supervisor by July 31,2019 as specified in the Specific
Condition and Limitation No. A. 9. c. of this permit.
A testing protocol is also required by Specific Condition and Limitation No. 9. a. of this permit to be
submitted at least 45 days prior to conducting the emissions testing. This office received the protocol
forms for the EPA Reference Methods 5,202 and 9 particulate matter emissions testing of the hot mix
asphalt plant from this company. This company proposed in the testing protocol that the asphalt plant
would be operating on natural gas and the production rate would be greater than 315 tons per hour. The
testing protocol also indicated that the production/process and control device operational data will be
obtained by plant personnel from the computer of the asphalt plant. The protocol was reviewed and
approved by Shannon Vogel of DAQ SSCB on June 13, 2019.
Stack Test Observations on June 20,2019:
The purpose of this site visit was to observe stack testing on the rotary aggregate dryer of the drum mix
asphalt plant(ID No. ES-1). On June 20,2019,the particulate and visible emissions testing was performed
by Integrity Air Monitoring, Inc. using EPA Methods 5, 202 and 9. The testing consisted of three one hour
runs. The source testing personnel for Integrity Air Monitoring,Inc.was Tony Blanton, stack operator; Jim
Lewis, meter box operator and Mr. Andrew("Drew")Dickson,visible emissions observer. The asphalt plant
contacts for Blythe Brothers Asphalt Co.,LLC were Alec Blythe, air quality manager;Jon Parton, plant
superintendent; and Tye Pickett, plant foreman. I arrived at 8:40 a.m.to observe the last 16 minutes of the
first one hour test run and remained on-site until the completion of the third test ending at 11:35 a.m.
The drum mix plant was initially producing 331 tons per hour of asphalt upon startup as indicated by Tye
Pickett,plant foreman. The rotary aggregate dryer of the asphalt plant was operating on natural gas with a
process rate of 320 tons per hour of asphalt after startup during the three one hour runs. The double barrel
Blythe Brothers Asphalt Co.,LLC—Concord Plant
June 20,2019
Page 3
dryer was heating the virgin materials(sand and aggregate)at mix temperatures ranging from 307 to 310
degrees Fahrenheit with RAP (30%) introduced of the end of the dryer to produce the binder I 19.00 product
for the three test runs. The asphalt products were being stored in silos 1 and 2 and then loaded into dump
trucks during the three one hour test runs. The silo 3 was not being used during the testing. This company
received a delivery of liquid asphalt that was being pumped from the tanker truck into its storage tank during
test run 3.
The bagfilter was in operation during the three test runs. The differential pressure drops across the
surface of the bagfilter was 4 inches of water for test run 1 and 3 1/2 inches of water for test runs 2 and 3. 1
observed Andrew("Drew")Dickson conducting the Method 9 visible emissions evaluation concurrently
with the particulate stack sampling and verified that the observations were being made in accordance with
the method requirements. Mr. Dickson observed 5%to 10% opacity from fugitive dust being blown by
the front end loader in his direction at ground level,while he was reading the opacity from the bagfilter
stack during the three one hour runs. Mr. Dickson informed me that he observed no visible emissions
from the exhaust of the bagfilter. I observed no visible emissions from the vertical and uncapped bagfilter
stack during the three one hour runs.
Company personnel were taking screenshots and printout data of the production, pressure drop of the
bagfilter and other temperature controls. According to the control panel,the stack inlet and outlet
temperatures ranged from 269 to 399 degrees Fahrenheit. I informed Alec Blythe that all the operating
parameters of the asphalt plant must be submitted with the testing results.
The pre and post(after each run)run leak checks were conducted by Integrity Air Monitoring,Inc. The
run leak checks demonstrated to be 0.001 cfm each for the first and third one hour runs and 0.004 cfm
second hour run,which is below the allowable leak check rate of 0.02 cfm. Mr: Lewis stated that the
probe temperature was set to 250 degrees Fahrenheit. The filtration temperatures appeared to be in proper
ranges according to the method.
The particulate and visible emissions testing appeared to be conducted in accordance with the approved
protocol and testing methods. A copy of the NC DAQ Source Test Observers Checklist-Particulate
Testing EPA Methods 1-5 is located on pages 4-5 of this report. The data sheets,testing methods, and
operational data will be reviewed by the Stationary Source Compliance Branch(SSCB) in Raleigh in
order to determine the validity and compliance status of Methods 5, 202, and 9 tests.
DLC:Ihe
c: MRO File
https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/CABARRUS/00101/STK_OBSERVED 20190620.docx
Blythe Brothers Asphalt Co., LLC—Concord Plant
June 20,2019
Page 4
NC DAQ Source Test Observers Checklist-Particulate Testing EPA Methods 1-5
Facility Name/Location: T9r ure"_ fqrl ramre:
Source Contact/Phone#: 'Co o ca i- 1 —
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Facility ID/Source Tested: /' I lttl li ht� III i`
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Tracldng Number: 2 o TT-1 S S fi ZFS UI) Wo Il iom tur Wa rr• E�+p{y ce "
Test Date: 6-Z b_19 e.1 vac 1Cb-I) Image courtesy of the EPA
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17:53pfr WLAM 936,70b D1 4 ,Z ,µn3 1315 .33%
Z M /D;17AA 7k'13 525,36 47 2-3 1Lto0 ,315 LP/ ,32O10
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rkfAso,an explanation to any question answered'No"and attach comments to this form or in your report. co
1.1)Method I calculated correctly(see reverse side)?
1.2)Cyclonic flow check completed during test day?(Average of absolute value.of all angles<20 degrees?) ✓
2.1)Pitot tube leak check completed after each run?
2.2)Visual check of pitot tube heads-good condition?
2.3)Manometer level and zeroed correctly? ob., e-
2.4)Static pressure measured during the test day? o'3 o Static Pressure; ches HZ
2.5)Barometric pressure recorded and 4ghstea for a evatio (see reverse side) ✓
2.6)Pitottube'heads oriented to axis of flue?/Pitot tube perpendicular to axis of stack?
2.7)Temperature recorded at each sampling point? I ✓
2.8)Minimum sample of 30 dscf collected(or per applicable subpart?)(see Vm above)
3.1)Is molecular weight being assumed?(If yes,and allowed,skip rest of Method 3)(see reverse side) 0
3.2)Multi point integrated sample/Bag evacuated and leak free(if applicable) 4r awl ram^s
3.3)Electronic Analyzer;or Orsat(performed in triplicate,analysis consistent?)(circle)(see reverse side) -
3.4)Calculate Fe/Within Range?
NEWN Will
4.1)100 ml HZO in fast 2 impingers,3rd empty,silica gel in 4th?(see reverse for each impinger design req.)
4.2)Temperature at the exit of impingers/condenser<68 F?(see reverse side) plot-ev l�r.
4.3)Silica gel in good condition?-Blue-new,Pink-spent(unable to absorb more HZO)
'4^9
5.1)Methods 2-5 run concurrently?Test team accurately recording meterbox data at each sampling point?
5.2)Visually inspect sample nozzle for damage/nozzle opening facing direction of flow?
5.3)Pre non teak check,optonal(watch)Leak Rate 50.02cfm?
5.4)Post run leak check,mandatory(watch)Leak Rate 150.02cfm?Conducted a highest vacuum during run? Ii
5.5)Isokinetic rates between 9017o and 110%?(see reverse side) K factor:
5.6)Filter and probe temperatures at 248+/-25F(or applicable subpart,such as MATS)?
.7a)During a run,was any equipment changed(ie.filter,nozzle,impinger)Why?(Do not explain a"No') 1.
5.7b)Was a leak'check performed prior to the equipment change?(May not be applicable) r,)JA
5.8)Meterbpx calibration values- AH@:1 i glS(5 Y: D.1 9 b Date Calibrated: -�"-2--1 y Kom
5.9a)Particulate sample clean-up: --tone used?(or water if required by CFR such as MACT MM)?
5.9b)Inside of nozzle,probe,and glassware(before the filter)rinsed and brushed in triplicate(minimum)? v
5.9c)Is filter holder(isassembled on site or transported to lab intact?(circle)
5.9d)200 ml acetone blank prepared? Volume of acetone used for cleanup:
Blythe Brothers Asphalt Co.,LLC—Concord Plant
June 20, 2019
Page 5
RECORD PROCESS DATA:It is imperative for the facility and the observer to record the pertinent data during the
test so that the measured emissions can be correlated to a production rate and compared to the permit limit.The test
will be unacceptable without production data.Control device operating parameters should also be recorded.
DATA TABLE:DGM stands for"dry gas meter",the volume of dry gas collected typically in cf. The"Vm"is the DGM
meter change from the beginning to the end of the run,which is the total dry gas volume collected."Ave.Ap"is the average
pitot tube velocity head for the points sampled(in inches H20)."Nozzle 0"is the nozzle diameter,typically in inches."H20
Coll."is the water collected by Method 4. "Post leak"is the post leak check amount in cfm(see below).
METHOD 1:If stack is between 4"-12"then Method la must be employed.If duct is<4"then alternative methods must be
used. - Duct DlamVere that Meaeurament Site la Upetreamfrom Flow DistuMaricel(DIstance A)
60 5 1.0 1.5 2A 2.5
Stack Diameter: 41
"Higher Number is
How Determined? Rectangular St
rrrz 6�r i e. Sinks or or Ducts
Port Dist.upstream from disturbance(A): Z t/ n ao L�,__
aM'e�rUpstream Diameters(A): -Port Dist.downstream from disturbance(B): 2-76 30F24or25apc1,ft rx
Downstream Diameters(B) �, Z Is
11K'UdlnelverttcalTyrfrQtne"Drslan�e, 1t7XtSO 20 20pcirts yyackDameter>a51m 4in.)
15 dnW
tbthes� 1 ,�r�r[lf�itm hr' tst �g„ Sli Z
th-7 fist .1 '.�-� (e r iFranrrotmotMYTMod 12 point.
,st p J�#t 1�pZ� 4 fa 1 ar dton�� t; DsW 6onca(Send,EWerd.,% 6orea Nm
t'a�w 1, •'rF i� 1I � ; t` !t +` p r � 10 Conhtreor♦etc) Po
B tP11Tls 1) I tnidtmum,#d 'fio{n ' drn t t�, s
t 4 J�h iiPtf �tF��xtFiq kre Ir7r ataek Dlemetar=o.70t.0./1 m(12-24In.)
i.i?117- -D- 6 i�.bK5*14 foie `c4'kt`4, t.a p i
Minimum number of sampling points: 3 CJ z a 4 6 a r a 9 10
Duct Diameters that Measurement Site Isimm DtWmshoarrt to Flow Dlstutbant»f(Dtetams a)
Points correctly marked on the pilot tube? Flgu e 1-1,MlNmum m1,%t of lraveree polntc torperucu)ale traverses
Port length accounted for in calculations? (�s'n �: 5 G r�5 age Courtesy of the EPA
2.5 Barometric Pressure:pressure must be adjusted minus 0.1"Hg per 100ft elevation increase or vice versa for elevation decrease.
2.8 Sample Volume(Vm):SIP Sources require lhr particulate test runs and a minimum sample of 30 dscf.NSPS regulations may require
different sample rates,times,and temperatures.Investigate prior to test. Check"Vm"discussed above.
METHOD 3:The measurement of 02&CO2 is usually performed with an analyzer.Orsats may be used but must meet analysis criteria(see
guidance document). Assuming ambient air and a molecular weight may be acceptable for some stacks(asphalt plants).
20.9 - %0 Coal: Anthracite and lignite 1.016-1.130 Gas: Natural 1.600-1.836
Calculate: k - 2 Bituminous 1.083-1.230 Pmp'ane 1.434-1.586
%CO2 Oil: Distillate 1.260-1.413 Butane 1.405-1.553
Residual 1.210-1.370 Wood: 1.000-1.120
METHOD 4: 1st,3rd,4th impingers modified Greenburg-Smith design:2nd impinger Greenbtug-Smith design with the standard tip.
Impinger Exit Temperature-The temperature of the dry gas leaving the impingers/condenser must be below 68 Deg F.When the ambient
temperature is above 68 Deg F it may take approximately 5 minutes for the thermal effects of the ice bath to cool the exit thermometer below
68 Deg F.
METHODS: _
Leak Check:If the results indicate a leak(>0.02cfm),record the leakage rate.Suggest repeating the run,but it is the discretion of the test
team and facility to accept the leak.However,the sample volume will be adversely adjusted due to the leakage rate..
Isokinetics:If the test team indicates that the isokinetic rate of a run is over 110%or under 90%,the run should be voided and repeated.
Particulate Sample Clean-up:If any particulate sample is lost during.plean-up,the run should be voided and repeated.
REMARKS:(Record process data and applicable regulations here and/or in your observation report)
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