AQ_F_1900088_20190522_CMPL_InspRpt

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NORTH CAROLINA DIVISION OF Raleigh Regional Office
AIR QUALITY S.T.Wooten-Pea Ridge Asphalt Plant
NC Facility ID 1900088
Inspection Report County/FIPS: Chatham/037
Date: 05/30/2019
Facility Data Permit Data
S.T.Wooten-Pea Ridge Asphalt Plant Permit 08137/R10
1015 Pea Ridge Road Issued 6/11/2014
New Hill,NC 27562 Expires 5/31/2022
Lat: 35d 37.8620m Long: 79d 3.3370m 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
James Washburn Brian Gurganus James Washburn MACT Part 63: Subpart ZZZZNSPS: Subpart I
Environmental Vice President Environmental
Compliance Manager [phone] Compliance Manager
[phone] [phone]
Compliance Data
Comments: In compliance.
Inspection Date 05/22/2019
Inspector's Name Mary Rose Fontana
Inspector's Signature: fly Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: Z� �� On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2013 1.0000 6.11 2.50 1.10 3.20 0.7000 139.00
2008 2.10 7.58 3.80 2.10 6.30 1.40 288.00
*Hi hest HAP Emitted(in pounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
07/30/2015 NOV Permit Permit Condition 08/05/2015
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
(I) DIRECTIONS TO SITE: From the RRO, take I-440 W/US-1 S Outer Beltline. Continue on US-1 S for about 20 miles to
Exit 81,Pea Ridge Road.Take the exit,then turn left onto Pea Ridge Rd.About 300 yards turn right at the S.T.Wooten sign.

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(II) FACILITY DESCRIPTION: S.T. Wooten Corporation—Pea Ridge Asphalt Plant operates a drum mix asphalt plant. The
permit lists two plants for the site,but only one plant is located there,Plant 12.This facility only operates intermittently on an
as needed schedule.
Safety note:Personal protective equipment required on-site includes steel-toed boots,hard hat,safety glasses,safety vest,and
hearing protection.
(III) INSPECTION SUMMARY: On May 22, 2019, I, Mary Rose Fontana, visited S.T. Wooten's Pea Ridge Asphalt Plant to
conduct an air quality compliance inspection.When I arrived at the facility,the plant was in operation.I met with Mr.Beverly
Mack,Plant Manager.Mr.Mack provided a copy of the permit,bagfilter/cyclone inspection records, and production records
for review.These records appeared complete and up to date.
(IV) PERMITTED EMISSION SOURCES:
Emission Emission Source Control Control System
Source ID Description System ID Description
Drum Asphalt Plant 15
15ES1-1 natural gas/No.2/recycled No. 2/ 15CD1 baghouse(11,598 square feet of
(NSPS) No.4/recycled No.4 fuel oil-fired filter area)
aggregate dryer/mixer(120 mmBtu/hr
max.permitted heat input rate,400
tons/hr max.permited capacity)
15F1 load out operation N/A N/A
15ES3 hot mix surge bin(146 ton capacity) N/A N/A
Drum Asphalt Plant 12
12ES1-1 natural gas/No.2/recycled No.2/ 12CD2, 12CD1 horizontal cyclone(9 feet in
(NSPS) No.4/recycled No.4 fuel oil-fired diameter by 10 feet long),in series
drum-type hot mix asphalt plant(75 with baghouse(7,749 square feet o
mmBtu/hr max.permitted heat input filter area)
rate,270 tons/hr max.permitted
capacity)
12F1, 12F2, 121`3 load out point for each of the three hot N/A N/A
asphalt silos.
12ES3-1, 12ES3-2,three asphalt storage silos NIA N/A
12ES3-3
All equipment was viewed at the time of this inspection and was operating. No additional permitted sources were
observed.
(V) SPECIFIC CONDITIONS AND LIMITATIONS:
A.I. TheeiPermitteeshall-comply-with Titie 15A NCAC,Subehapter-2D .0202, 2D .0506, 2D .0516;-2-D 7052-I 21D-0524 (40
CFR 60,Subpart I),2D .0535,2D .0540,2D .0605,2D.0611,2D .1100,2D .1806,2Q .0315,2Q.0317(Avoidance) and
2Q .0711.
Appeared to be in compliance.
A.2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT: Within 90 days of permit expiration, the
Permittee is required to request permit renewal and to submit an emission inventory for CY 2020.
Appeared to be in compliance.This permit does not expire until 2022.
A.3. PARTICULATE CONTROL REQUIREMENT-As required by 15A NCAC 2D.0506"Particulates from Hot Mix Asphalt
Plants,"
a. Particulate matter emissions shall not exceed allowable emission rates.
b. Visible emissions from stacks or vents at a hot mix asphalt plant shall be<20%opacity when averaged over a six-
minute period.
c. Fugitive dust emissions shall be controlled as required by 15A NCAC 2D .0540 "Particulates From Fugitive Dust
Emission Sources."

d. Fugitive emissions for sources at a hot mix asphalt plant not covered elsewhere under this Rule shall not exceed 20%
opacity averaged over six minutes.
Appeared to be in compliance. The facility was operating during the inspection, and none of the equipment presented
any visible emissions or fugitive dust.
A.4. SULFUR DIOXIDE CONTROL REQUIREMENT — As required by 15A NCAC 2D .0516, SO2 emissions from
combustion sources shall not exceed 2.3 lbs/mmBtu.
Appeared to be in compliance. The plant has run on natural gas since April 2013. Sulfur dioxide emissions from the
combustion of this fuel are well below the limit.
A.S. VISIBLE EMISSIONS CONTROL REQUIREMENT-As required by 15A NCAC 2D .0521,visible emissions from the
emission sources shall not be>20%opacity when averaged over a six-minute period.
Appeared to be in compliance.No visible emissions were presented during this inspection.
A.6. 15A NCAC 2D .0524 "NEW SOURCE PERFORMANCE STANDARDS" - For the permitted drum asphalt plants (ID
Nos. 15ES1-1 and 12ES1-1),the Permittee shall comply with NSPS as promulgated in 40 CFR 60, Subpart 1, including
Subpart A"General Provisions."
a. NSPS Emissions Limitations-As required by 15A NCAC 2D .0524, the Permittee 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(0.04 gr/dscf);or
ii. Exhibit 20%opacity,or greater.
Appeared to be in compliance.The facility performed a stack test on August 5,2015 and the results showed compliance.
The test was performed at night so the opacity was not measured.
A.7. NOTIFICATION REQUIREMENT-As required by 15A NCAC 2D.0535,the Pernttee of a source of excess emissions
that last > 4 hr and results from a malfunction, a breakdown of process or control equipment or any other abnormal
conditions,shall notify DAQ by the next business day.
Appeared to be in compliance.Mr.Mack noted that no such incidents have occurred.
A.B. FUGITIVE DUST CONTROL REQUIREMENT-As required by 15A NCAC 2D .0540,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.
Appeared to be in compliance.No fugitive emissions were presented at the time of the inspection.No dust complaints
are on file against the facility.
A.9. TESTING REQUIREMENT - Under the provisions of North Carolina General Statute 143-215.108 and in accordance
with 15A NCAC 2D .0605,the Permittee shall demonstrate compliance with the emission limit(s)by testing the emission
source(s)for the specifiedpollutant(s)as follows:
Affected Source(s) Pollutant Emission Test Method
Limit
natural gas/No.2/recycled No.2/No.4/recycled No.4 fuel oil-fired Q
drum-type hot mix asphalt plant(75 million Btu per hour maximum 2D .0506 and Approved
permitted heat input rate,270 tons per hour maximum permitted capacity) PM(TSP) 2D .0524 Ap
(12ES 1-1) Method
a. The Permittee shall arrange for air emission testing protocols to be provided to the DAQ prior to testing.
Testing protocols are not required to be pre-approved by the DAQ prior to testing.The DAQ shall review
testing protocols for pre-approval prior to testing if requested by the Permittee at least 45 days before
conducting the test.
b. To afford the Regional Supervisor,DAQ,the opportunity to have an observer present,the Permittee shall
PROVIDE the Regional Office,in WRITING,at least 15 days'notice of any required performance test(s).
c. Two copies of the test results must be submitted to the Regional Supervisor,DAQ,in accordance with the
approved procedures of the Environmental Management Commission by December 10,2014.
d. This permit may be revoked,with proper notice to the Permittee,or enforcement procedures initiated,if the
results of the test(s)indicate that the facility does not meet applicable limitations.

e. The source shall be responsible for ensuring,within the limits of practicality,that the equipment or process
being tested is operated at or near its maximum normal production rate,or at a lesser rate if specified by the
Director or his delegate.
Appeared to be in compliance.The facility performed a stack test on August 5,2015 and the results showed
compliance.An NOV was sent July 30,2015 for failure to conduct the performance test.The plant was tested
on August 5,2015,which resolved this violation.The results of the test indicated compliance with the emission
limits of these regulations.
A.10. CYCLONE REQUIREMENTS— 15A NCAC 2D .0611 perform an annual inspection of the cyclone system.Records of
all maintenance activities shall be recorded in a logbook.
Appeared to be in compliance. The facility conducts monthly inspections. Daily inspections are conducted when the
facility is operating.
A.11. FABRIC FILTER REQUIREMENTS including cartridge filters baghouses and other dry filter particulate collection
devices - 15A NCAC 2D .0611 shall perform, at a minimum, an annual internal inspection of each bagfilter system. In
addition, the Permittee shall perform periodic inspections and maintenance as recommended by the equipment
manufacturer.Records of all maintenance activities shall be recorded in a logbook.
Appeared to be in compliance.The facility conducts monthly inspections.Daily inspections are conducted when the
facility is operating.
A.12. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORTING REQUIREMENT-Pursuant to
15A NCAC 2D.1100"Control of Toxic Air Pollutants," and in accordance with the approved application for an
air toxic compliance demonstration,see permit for limits.The pernuttee shall operate only one of the asphalt
plants at a time and only at the location that the plant was modeled.
Appeared to be in compliance.The facility has not installed new equipment or made changes to their process
that would increase toxic air emissions.The emission limits in this table are based on the maximum operating
rate of the plant.
A.13. CONTROL AND PROHIBITION OF ODOROUS EMISSIONS _As required by 15A NCAC 2D .1806, the Permittee
shall prevent odorous emissions from the facility from causing or contributing to objectionable odors beyond the facility's
boundary.
Appeared to be in compliance.No odors were detected during the inspection.No odor complaints are filed
against the facility.
A.14. LIMITATION TO AVOID 15A NCAC 20 .0501 - Pursuant to 15A NCAC 2Q .0315 "Synthetic Minor Facilities," to
avoid the applicability of 15A NCAC 2Q .0501 "Purpose of Section and Requirement for a Permit," as requested by the
Permittee,facility-wide emissions shall be less than the following:
Emission Limit
Pollutant (Tons per consecutive 12-month
period)
S02 100
CO 100
a. Operations Restrictions-the following restrictions shall apply:
i. The tons of asphalt produced shall be< 1,245,000 tons per consecutive 12-month period.
ii. The sulfur content of the No.2/recycled No.2/No.4/recycled No.4 fuel oil shall be limited to 0.5%sulfur by
weight.
b. Recordkeeping Requirements
i. The Permittee shall record monthly and total annually the following:
A. tons of asphalt produced;
B. fuel supplier certification shall be kept on-site and made available to DAQ personnel upon request. The
Permittee shall keep each record on file for a minimum of three years.
C. generator hours of operation.

c. Reporting Requirements-Within 30 days after each calendar year the Permittee shall submit the following:
i. monthly and 12 month totals for the previous 12-month period.
A. S02,and CO emissions,and
B. tons of asphalt produced.
Appeared to be in compliance.The facility's annual report was received at the RRO on January 16,2019.For
CY 2018,the facility produced 61,798 tons of asphalt.The 2018 annual report stated that no No.2 or No.4 fuel
oil was used in CY 2018 (the generator was not used).
A.15. LIMITATION TO AVOID 15A NCAC 213.0530"PREVENTION OF SIGNIFICANT DETERIORATION"-In
accordance with 15A NCAC 2Q .0317,emissions shall be limited as follows:
Affected Source(s) Pollutant Emission Limit
(Tons Per Consecutive 12-month Period)
Facility Wide S02 250
Appeared to be in compliance.By complying with A.14 above,the facility complies with this stipulation.
A.16. VENDOR SUPPLIED RECYCLED No(s) 2 and 4 FUEL OIL REOUIREMENTS -In accordance with Rule 2Q .0317,
the Permittee is avoiding the applicability of Rule 2Q .0700 by using recycled fuels which are equivalent to their virgin
counterparts.The Permittee is allowed to use the recycled fuel oil(s)supplied by a DAQ-approved vendor as follows:
a. Specifications—see permit for recycled fuel oil(s)criteria
b. The Permittee is responsible for ensuring that the recycled fuel oil(s), as received at the site, meet(s) the approved
criteria for unadulterated fuel.
c. R_ecordkeeping Requirements -The Permittee shall maintain at the facility for a minimum of three years, and shall
make available to representatives of the DAQ upon request,accurate records of the following:
i. The actual amount of recycled fuel oil(s)delivered to,and combusted at the facility on an annual basis.
ii. Each load of recycled fuel oil received shall include the following:A delivery manifest,a batch specific analytical
report,batch signature information,a certification indicating that the recycled fuel oil does not contain detectable
PCBs(<2ppm).
d. Reporting Requirements-Within 30 days after each calendar year,the Permittee shall submit:
i. A summary of the results of the analytical testing for the previous 12 months.
ii. The total gallons of recycled fuel oil(s)from each approved vendor combusted at the facility for the previous 12
months.
e. The DAQ reserves the right to require additional testing and/or monitoring of the recycled fuel oil(s) on an annual
basis or without notice.
Appeared to be in compliance.—The plant had not used recycled fuel since April 2012. Records were provided for this
requirement and they appear complete and up to date.
A.17. TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT-The facility shall be operated and maintained
in such a manner that emissions of any listed TAPS from the facility will not exceed TPERs listed in 15A NCAC 2Q.0711.
Appeared to be in compliance. The facility was evaluated based on the maximum production rate of the plant. Since
there have been no changes to the plant then there is no expectation of exceedance of these TPERs.
(VI) INSIGNICANT/EXEMPT SOURCES: There were two AC silos(30,000 gallons,each)at the site.
Source Exemption Source of Source of Title V
Regulation TAPs? Pollutants?
I-12ES4-1 -2 Million BTU Hot Oil 2Q .0102 Yes Yes
Heater (c)(2)(B)(i)(I)
(VH) 112R:Not applicable.
(VHI) STACK TEST HISTORY:
August 18,2003 The facility conducted a stack test for CO of 12ES 1-1 Natural Gas/No 2/recycled No 2/No 4/recycled No 4
fuel oil fired aggregate dryer/mixer(120 mmBtu/hr max.permitted heat input rate 270 tons/hr max permitted
capacity).The test was reviewed by Shannon Vogel in January 2004.Test results while combusting NG were
VE<5%opacity.The test was conducted at a process rate of 250 TPH.

b
August 5,2015 The facility conducted a stack test to determine compliance with 40 CFR 60 Subpart I and 2D .0506. The
plant was running at 207.8 tons per hour(---77% of capacity) and the results were 0.0068 gr/dscf and 2.36
lb/hr,which shows compliance with the emission limits of 0.04 gr/dscf and 51.1 lb/hr.
(IX) COMPLIANCE HISTORY: A review of DAQ files revealed the following permit violations by the facility:
• July 30, 2015 —An NOV issued for failure to conduct performance test. The plant was tested on August 5, 2015,
which resolved this violation.
(X) AIR EMISSIONS INVENTORY REVIEW: The production reduced from 90,265 tons per year in CY2008 to 43,608 tons
per year.
(XI) CONCLUSIONS/RECOMMENDATIONS: At the time of the inspection, S.T.Wooten's Pea Ridge plant appeared to be in
compliance with their permitting requirements.It is recommended that the facility be re-inspected in one year.