AQ_F_2000123_20190807_CMPL_InspRpt (3)

Z000 t A16
NORTH CAROLINA DIVISION OF Asheville Regional Office
AIR QUALITY Harrison Construction Division of APAC-Atlantic,
Inc.
Inspection Report NC Facility ID 2000123
Date: 08/09/2019 County/FIPS: Cherokee/039
Facility Data Permit Data
Harrison Construction Division of APAC-Atlantic, Inc. Permit 08976/R10
235 Marrestop Road Issued 8/14/2015
Murphy,NC 28906 Expires 7/31/2023
Lat: 35d 0.6660m Long: 84d 13.6320m Class/Status Synthetic Minor
SIC: 2951 /Paving Mixtures And Blocks Permit Status Active
NAILS: 324121 /Asphalt Paving Mixture and Block Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Don Mason Don Mason Don Mason NSPS: Subpart I
Environmental Environmental Environmental
Compliance/Quality Compliance/Quality Compliance/Quality
Control Control Control
828 421-0448 828 421-0448 828 421-0448
Compliance Data
Comments:
Inspection Date 08/07/2019
Inspector's Name Michael Koerschner
Inspector's Signature: ,/� - p � Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: 1lon
On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2014 --- --- --
2009 0.1700 3.63 0.9100 0.0600 0.3300 0.1600 5.37
*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
Directions: Travel on Hwy. 64 about 12 miles west of Murphy. About 4 miles past Ranger Elementary School, turn
left off of Hwy. 64, across the median, across the east bound lanes, and on to Marrestop Road. Marrestop Road is
not well marked from the west bound side of Hwy. 64(between Mile Marker 5 & 6). Go about 112 mile on
Marrestop Road,facility is on the left(drive into quarry and you'll see asphalt plant ahead).

8/07/2019 Inspection
Page 2
Safety Equipment required: Hard hat, safety glasses,safety shoes, &high-visibility vest(recommend).
1. Facility Overview
Discussion/Introduction
On August 7,2019, I(Michael Koerschner)met with Mr. Matt Picon,Asphalt Plant Foreman,to conduct an annual
compliance inspection. The inspection was unannounced.I arrived at the facility at—09:30 and observed it in
operation making—140 TPH 9.5C asphalt for private work until about 09:50 a.m. The mix temperature was 310-330
degrees Fahrenheit. According to Mr. Picon,they had started up about 09:15 a.m.
This facility operates on a sporadic basis(demand based)and typically only operates—1 hour per day of operations.
Based on stated asphalt production and estimated average production rate of 140 TPY,they have run—70 hours this
calendar year.
The bagfilter-collected solids are mechanically conveyed to a dump truck via an auger system and then a belt
conveyor.The material is wetted by sprays. This is unusual for this type of facility and Mr. Picon said that the
amount of waste generated was a function of the local aggregate(contains copper?)and that they generate 6-8 dump
trucks of dust per 1000 tons asphalt produced.
Facility Contacts
The facility contacts appear to be up-to-date in IBEAM.
Facility Description
Harrison Construction Division of APAC-Atlantic, Inc.—Murphy Asphalt Plant is a hot mix asphalt batch plant,
subject to NSPS Subpart 1,with a maximum rated capacity of 300 tons per hour. The plant started production the
season on April 3 and has produced—9231 tons year-to-date. This facility is making upgrades to prepare for
expected increased area asphalt demand associated with a 2020 widening of Hwy 64 through Murphy.
2. Emission Sources and Regulatory Review
The following emission sources were observed not in operation during the inspection:
__.... - ........ ..
Fan
FEmissio Emission Source Control System
Description Description
____...
One hot mix asphalt batch plant(300 tons per hour maximum capacity)consisting of:
one natural gas\No.2(virgin or DAQ approved CD2,one
recycled)fuel oil\No.4(virgin or DAQ knock-out box,
approved recycled)fuel oil-fired hot mix (1,408 cubic Observed in operation firing
feet)in series
ES 1 asphalt batch plant(88 million Btu per hour recycled No.4 fuel with no visibl
(NSPS) maximum heat input rate while combusting with CDl, emissions.Pressure drop across tl
natural gas and 110 million Btu per hour one bagfilter bagfilter was—Y WC.
maximum heat input rate while combusting fuel (11,130
oils) square feet of
filter area) j
Observed in operation with visibl:
FES2one hot mix asphalt storage silo(200 tons emission associstorage capacity) NIAload ng of 10-I_..---- asphalt)_-- - -- -
Observed not in operation. There
Fone main plant truck loadout operation N/A was a leak of asphalt from this
loadout.It appeared that the leak
was coming from the elevator chu'i

8/07/2019 Inspection
Page 3
7an
Emission Emission Source Control System
Source IDF Description Description
Mr.Picon showed me a replacement
elevator and chute the facilila is
- preparing to install. P
CDS, one Observed not in operation. This
ES5 one lime storage silo(26 tons of storage bagfilter(150 operation is no longer used
capacity) square feet of(formerly used for Georgia State
filter area) !asphalt)and is defunct.
- - -- - -
one hot mix asphalt storage silo truck loadout Observed in operation with visible
ES6 N/A emissions typical of this type of
operation
operation.
Compliance with specific permit conditions and limitations
Specific Condition 3: Particulate Control Requirement-Hot Mix Asphalt Plants -
The allowable particulate emission rate from the facility is limited to 60 pounds per hour;visible emissions from any
stack,vent,or any fugitive emission is limited to 20%opacity;and,the facility must be equipped with a scavenger
process dust control system for the processing of the aggregate. The results of the 10/08/2015 stack test indicates
compliance with the particulate limits for the aggregate dryer.
Specific Condition 4: Particulate Control Requirement-Miscellaneous Industrial Processes
This condition limits particulate emissions from the lime silo. This operation has not been operational for a number
of years(at least 5 years,per Mr. Picon)and was not in operation at the time of the inspection.
Specific Condition S: Sulfur Dioxide Requirement
This condition applies to the aggregate dryer and limits sulfur dioxide emissions to 2.3 pounds per million Btu.
Compliance with this condition was established by calculation during the last permit renewal. The fuel oil
combusted(recycled No.4)at this facility is less than 0.5% Sulfur. Continued compliance is expected.
Specific Condition 6: Visible Emissions Control Requirement
Visible emissions from the lime storage silo are limited to 20%opacity. As indicated above,the lime storage silo
was not in operation and has not been observed in operation for a number of years. Compliance is indicated.The
lime silo is not operational and should be removed from the air permit.
Specific Condition 7: New Source Performance Standards
The facility is to comply with the NSPS emission limitations of 90mg/dscm(0.04 gr/dscf)particulate and 20%
opacity. The results of the 10/08/2015 stack test indicates compliance with this condition(see Section 4 below).
Specific Condition 9: Fugitive Dust Control Requirement
This condition prohibits fugitive dust emissions from crossing the property boundary. The haul roads had been
watered prior to the inspection and dust from the haul roads was minimal. No fugitive emissions were observed
nearing the property boundary. Compliance is indicated. According to Mr. Picon,the adjacent quarry has a water
truck and APAC uses their water truck when they operate.
Specific Condition 10: Testing Requirement
This condition requires the facility to conduct Methods 5, 9, and 202 stack testing with the results due to this office
within 60 days of re-start to verify compliance with federal and state regulations. The facility stack tested on
10/08/2015 and submitted the required results on 12/O1/2015. The DAQ Stationary Source Compliance Branch
reviewed the stack test and determined that the test results were acceptable [ref: 7/22/2016 memo from Gary
Saunders to Brendan Davey]. This requirement has been met.

8/07/2019 Inspection
Page 4
Specific Condition IP Notification Requirement
The facility was required to notify this office, in writing,within 15 days of re-start. According to past inspection
reports,this requirement was met and triggered(within 60 days of startup)the 10/08/2015 stack test.
Specific Condition 12: Toxic Air Pollutant Emissions Limitation and Reporting
The facility has triggered a toxics review for benzene and formaldehyde, and has modeled compliance with the
AALs. In order to demonstrate compliance,the facility has production limitations. Hourly asphalt production shall
not exceed 300 tons,and annual asphalt production shall not exceed 259,000 tons. So far this season,the facility has
only produced about 9231 tons of asphalt. The facility is keeping records that demonstrate compliance with this
condition.
Specific Condition 13: Control and Prohibition of Odorous Emissions
This condition requires the facility to restrict objectionable odors to the property. No objectionable odors were
observed on or off the property during the inspection.
Spec fc Conditions 14 and 1 S: Synthetic Minor Limitation and PSD Avoidance
In order to avoid Title V and PSD applicability,the facility has requested emission limitations on PM1o, SOi,NOx
and CO to become a synthetic minor source. In order to demonstrate compliance with these limits,the facility has
an annual production limitation of 259,000 tons(the same as that listed in Specific Condition 12),as well as a
limitation of 2.0%sulfur content by weight of the recycled No.4 fuel combusted in the dryer. The sulfur content of
the highest load of fuel delivered was 0.31% Sulfur by weight. In addition;the facility must perform annual
inspections of the control devices to ensure that they are operating properly to control particulate matter emissions.
All records indicate compliance with the emission limitations. The last inspection of the bagfilter system(including
knock-out box)took place on March 27,2019.
Specific Condition 16: Vendor Supplied Recycled Fuel Oil Requirement
The facility is only allowed to use recycled fuel oil that meets the specifications set forth in the permit. The facility
must maintain analytical records of the recycled fuel oil,as well as the amount of fuel oil combusted at the facility.
An annual report is also required summarizing the analytical testing results as well as the annual usage of recycled
fuel oil. The facility has received 2 loads(-14,000 gallons)of recycled No.4 fuel oil this season and included the
required analyses. 0.31%sulfur was the sulfur content of that load. The fuel is supplied by Enterprise Waste Oil of
Knoxville,TN. All records and reports are up to date,and indicate compliance with this condition.
Specific Conditions 17 and 18: Toxic Air Pollutant Emissions Limitation Requirement
The facility has demonstrated that their emissions of various toxic air pollutants are below the level that requires a
permit to emit these toxics. As long as the facility does not go over the annual production limitation set forth in
Specific Condition 12,emissions of these pollutants will remain below the TPER.
Recordkeeping and Reporting Requirements Review
The facility is required to maintain records of asphalt production, control device I&M, and recycled fuel usage with
fuel certifications. The facility is required to report asphalt production and recycled fuel usage with fuel
certifications annually. The required records are maintained at the facility and the last annual report received on
01/17/2019 indicated compliance. In 2018,the facility produced 6290 tons of asphalt, and combusted 17,190
gallons of No.4 fuel with the highest sulfur content of 0.22%.
Insignificant Sources Listing
Source Notes
I-1 - One No. 2 fuel oil-feed asphalt tank heater(1.38 Observed n operation Currently combusting only
million Btu per hour heat input) propane. No 2 fuel oil is no longer burned at this site. !.
I-2-fuel oil storage tank(10,000 gallon capacity or less) See below

8/07/2019 Inspection
Page 5
NOT LISTED ON CURRENT AIR PERMIT There are two fuel oil storage tanks at this facility.The
No.2 fuel oil storage tank(15,000 gallons capacity) facility no longer uses No.2 fuel oil but there is a
No. 4 fuel oil storage tank(20,000 gallons capacity) 15,000 gallon No.2 fuel oil tank.Not sure if it's empty.
ADD at next permit opportunity. The No.4 fuel oil is stored in a 20,000 gallon tank.
3. Compliance History Review
The facility was issued a Notice of Deficiency on February 10,2016 for the late submittal of the 2015 annual report.
The facility has had no other documented violations in the past five years..
4. Stack Test Review
The facility was required to perform Methods 5,9,and 202 stack tests for this permit cycle with the results due to
this office within 60 days of the re-start. The results of the required stack tests,performed on October 8,2015,while
producing 236 tons per hour and combusting recycled No.4 fuel,are shown in the table below:
Source Standard Emission Limit Test Results Compliance
Indicated?
60 Subpart I 90 mg/dscm 0.008 gr/dscf) Yes
ES-1 0.04 r/dsc
15A NCAC 2D .0506 54.0 lb/hr 4.75 lb/hr Yes
5. 112r Review - h
The facility is not subject to 112r.
6. Compliance Assistance
The facility does not appear to need assistance at this time.
7. Recommendation/Conclusion/Compliance Statement
During this inspection,this facility appeared to be operating in compliance with the Air Quality standards and
regulations as specified in Air Permit No. 08976R10.
it