NCG160001_Regional Office Historical File Pre 2018

- ROY
,C t'
Ml' AEL S
Environmental
Quality
June 5., 2017
Mr. Alec Blythe, Project Manager
Blythe Brothers Asphalt Company, Inc
1415 E. Westinghouse Boulevard
Charlotte, NC 28273
Subject: Multimedia Compliance Inspection
Blyth Brothers Asphalt Company, Inc Concord Plant
Cabarrus County
Dear Mr. Blythe:
Ori Tuvia, Brad Newton and Andrew Martin from the Mooresville Regional Office conducted a
multimedia compliance inspection Blyth Brothers Asphalt Company, Inc plant at Concord on May
16,2017, for permits and programs administered by the following Divisions:
Division of Air. Oualitv I NC ID: 1300101
Division of Enemy, Mineral and Land Resources I Stormwater Permit Number: NCG160001
Division of Waste Management I - EPA ID: NC900002414
Your cooperation during the multimedia inspection was much appreciated. Enclosed are the air quality,
Stormwater and waste management reports.
If you have any questions regarding this' multimedia inspection, please contact Ori Tuvia, Division of
Water Resources at [phone].
Sincerely,
Ori Tuvia, Environmental Engineer
Mooresville Regional Office
Division of Water Resources, DEQ
Enclosure:
Air Quality Inspection Report
Stormwater Inspection Report
Waste Management Report
Cc: DAQ MRO Files, DEMLR MRO files, DWR MRO Files, DWM MRO Files (E-copy) .
COOPER
Governor
RRGAN
Secretary
State of North Carolina I Environmental Quality I Mooresville Regional Office
Mooresville Regional Office 1 610 E. Center Ave Suite 301 1 Mooresville, NC 28117
704-663-1699 T 1 704-663-6040 F

I
NORTH CAROLINA DIVISION OF
Mooresville Regional Office
AIR QUALITY
Blythe Brothers Asphalt Co., LLC - Concord
Plant
Inspection Report
NC.Facility ID 1300101
Date: 05/16/2017
County/FIPS: Cabarrus/025
Facility Data
Permit Data
Blythe Brothers Asphalt Co., LLC - Concord Plant
Permit 07449 / RI
660 Goodman Road
Issued 12/10/2015
Concord, NC 28027
Expires 2/28/2018
Lat: 35d 24.3970m Long: 80d 42.0010m
Classification Synthetic Minor
SIC: 2951 / Paving Mixtures And Blocks
Permit Status Active
NAILS: 324121 / Asphalt Paving Mixture and Block Manufacturing
Current Permit Application(s) None
Program Applicability
SIP
Contact Data
.Facility Contact
Authorized Contact
Technical Contact
Tye Picket
Frank Blythe
Alec Blythe
NSPS: Subpart I
Plant Foreman
Member Manager
Air Quality Manager
[phone]
[phone]
JI
[phone]
Compliance Data
Comments: Multimedia inspection
Inspection Date 05/16/2017
f
Inspector's Name Ori Tuvia
Inspector's Signature: —
Operating Status Operating
Compliance Code Compliance - inspection
Action Code FCE
Date of Signature: S-�2 y
On-Site'Inspection Result- Compliance
Total Actual emissions in TONSIYEAR:
TSP
SO2
NOX
VOC
CO .
PM10
* HAP
2012
14.72
0.0100
3.08
5.64
15.56
6.70
224.93
2007
5.30
13.70
1.80
6.20
17.10
3.60
814.79
* Highest HAP Emitted (in pounds
Five Year Violation History: None
Date Letter Tyne Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE: None
Date Test Results Test Method(s) Source(s) Tested

Blythe Brothers Asphalt Co., LLC - Concord Plant
May 16, 2017
Page 2
Type Action: X Full Compliance _ Partial Compliance
Evaluation Evaluation/Reinspection
Data Tracking: X Date submitted for initial review 05/22/2017
X IBEAM Inspection, list date inspected
X IBEAM Inspection, list date draft is submitted
X IBEAM Inspection, pollutants/programs checked
Complaint Other:
Investigation
_ IBEAM WARNI I / , NOD, NOV, NRE
X IBEAM Documen
X IBEAM LAT/LONG, Facility Locked
X IBEAM LAT/LONG, Coordinates checked
IBEAM Complaint
X IBEAM Planning, Next Inspection Date
05/01/2019
Directions: Travel from Mooresville to Concord via Highway 3 South; turn right on Odell School Road;
turn right at the stop light onto Poplar Tent Road due to the no left turn; make a U turn at the next stop
light; and 0.7 mile turn left on Goodman Road (road prior to Interstate 85). Blythe Brothers Asphalt
Company, LLC, Concord Plant is located 0.2 mile on the left at 660 Goodman Road.
Safety Equipment: This company has no safety requirements at this facility. It is recommended that steel
toe shoes, safety glasses, hard hat and safety vest be worn by the inspector at this facility.
Safety Issues: No safety issues were noted by me during the inspection.
Lat/Long: A review of the facility's coordinates on "Maps of DAQ Regulated Facilities" indicates the
facility latitude and longitude coordinates are accurate. No changes to the latitude and longitude coordinates
of this facility in IBEAM are needed. Latitude and longitude coordinates of this facility are locked in
IBEAM.
Email Contacts: The emails for the facility, authorized, technical, and invoice contacts were verified by
Mr. Alec Blythe, air quality manager. No changes to the email contacts are needed in IBEAM.
1. The purpose of this site visit was to conduct. a multimedia inspection. Blythe Brothers Asphalt
Company, LLC operates a drum mix type asphalt plant that produced 342,184.3 tons of asphalt
while burning 79,191 decatherms of natural gas during calendar year 2016. The asphalt plant
operates on a varied schedule, which is dependent upon weather conditions and road projects.
This facility is subject to NSPS Subpart I -"Standards of Performance for Hot Mix Asphalt
Facilities". Mr. Tye Pickett, plant foreman, and Alec Blythe, air quality manager, accompanied
Brad Newton of DWM; Andrew Martin of DWM and me during this inspection. Mr. Pickett
stated that this plant operates 6 a.m. to 6 p.m., 2 to 6 hours per day on average, 6 days per week
with an occasional Saturday, 47 weeks per year.
2. Facility Contact Information:
During the inspection, I verified the facility contact information in IBEAM with Mr. Blythe. No
changes are needed in IBEAM.
Compliance history file review:
No problems have been noted in the last five years by DAQ prior to this inspection. The current
compliance status is discussed in the following sections.

Blythe Brothers Asphalt Co., LLC - Concord Plant
May 16, 2017
Page 3
4. Observations of permitted air emission sources and control devices:
Emission
Source >�
Iemission Source
( Description
Control
�ystem ID
Control System
Description
ES-1 (NSPS)
drum mix type, natural
CD71, CD-2
cyclone (ID No. CD-l; 8 feet
gas/No. 2 fuel oil/recycled
in diameter) installed in series
No. 2 fuel/recycled No. 4
with bagfilter (ID No. CD-2;
fuel oil -fired hot mix.
12,818 square feet of filter
asphalt plant (350 tons per
area)
hour maximum rated
capacity; 116 million Btu
per hour maximum heat
input rate)
(.
atural gas is the primary fuel source for the rotary drum dryer. No. 4 recycled fuel oil is the secondary
iel source for the rotary drum dryer. No. 2 fuel oil and recycled No. 2 fuel oil are listed in the permit
ascription as the. backup.fuel sources for the rotary drum dryer.
Is company reported that 79,191 decatherms of natural gas. was combusted by the rotary drum dryer
No. ES-1) during calendar year 2016. Recycled No. 4 fuel oil, No. 2 fuel oil and recycled No. 2 fuel
were not combusted in the -rotary drum dryer during calendar year 2016.
Sand and aggregate materials are placed in the six bins.by a front end loader. These materials are
conveyed via six virgin. aggregate feeder belts (belt under each of the six feeders in bottom of each bin)
to one aggregate collector conveyor belt and then to one vibrating double deck screen (two screens
installed 5' xl2', each). After the screening process, these materials are conveyed via one aggregate
scale conveyor belt into the.inlet of the rotary drum dryer. Eight aggregate conveyor belts and vibrating
double deck, screen were operation. during the inspection. I observed no visible emissions from these
Reclaimed asphalt pavement (RAP) is placed via front end loader,into two grizzly screens and then
dropped into two feeder bins. From the bottom of the feeder bin, the rap is conveyed to two feeder belts
(one belt under each feeder in the bottom of each bin) to one collector conveyor belt and then to one
vibrating single deck screen (3' x 6'). Then the oversized -materials from the vibrating single screen
drops from a.chute to one collector conveyor belt and then conveyed to the hammermill to be crushed.
After the crushing process, the rap materials are returned via this conveyor to this -vibrating single deck
screen and, then conveyed via one scale conveyor belt to rotary drum mixer. Mr. Pickett stated that 30%
rap is being used in the hot mix asphalt product. Five rap conveyor belts, hammermill, and single deck
screen were in operation during the inspection. I observed no visible emissions from these sources.
This company hired Red Clay Industries, Inc. to crush rap at this asphalt plant. During calendar year
2016, Red Clay'Industries, Inc. crushed 154,356.6 tons of RAP. During the inspection, no crushing of
RAP was being conducted.
7. Pickett stated that. the bagfilter (12,8,18 square feet of filter area; manufacturer, Herman Grant Co.)
.s installed from December 22, 2015 to January 31, 2016 and became operational on January 31,
16. The cyclone (ID No. CD-l; 8 feet in diameter) was not replaced by this company.

Blythe Brothers Asphalt Co., LLC - Concord Plant
May .L6, 2017
Page 4
rticulate matter emissions from the rotary drum dryer are exhausted into the cyclone and then to the
Ise jet type bagfilter (12, 818 square feet of filter area; manufacturer, Herman Grant Co). At the base
the cyclone and bagfilter, the particulate matter that is captured by the control system is conveyed to
incline auger and then into the rotary drum mixer. This company has a gauge (toyer demand
;aping) measured in inches of water that is used to determine the pressure differential across the
gfilter. The gauge is. located at ground level near the bagfilter.
Observed: Drum mix asphalt plant was operating on natural gas during the inspection. Pulse jet type
bagfilter was in operation. I observed no visible emissions from the exhaust of the bagfilter stack.
ES-2, ES-3, ES -4 three (3) HMA storage
silos (200 tons capacity, N/A N/A
each)
Hot mix asphalt product from the rotary drum dryer is conveyed via the drag slat conveyor to the two
hot mix asphalt (HMA) conveyors (referred to as traverse conveyors by this company; not listed in the
current permit). Two HMA conveyors are located above the three hot mix storage silos (ID Nos. ES-2,
ES-3, and ES-4 or company IDNos. 1-A, 1-B, and 1-Q. Hot mix asphalt product is transported by the
two HMA conveyors into a designated hot mix storage silo by the plant operator.
t mix asphalt is stored in the three heated silos (ID Nos: ES-2, ES-3, and ES-4 or company ID Nos. 1-
1-B, and 1-C). Two silos (ID Nos. ES-2 or 1-A or,#1 and IDNo. ES-3 or 1-B or #2) are electrically
Lted. The loadout cone portion of silo (ID No. ES-4 or 1-C or #3) is heated by the natural gas -fired
oil heater (ID No. IES-2), Hot mix asphalt is gravity dropped from the three storage silos into the
Is of dump trucks.
Observed: Hot ,'mix asphalt was being stored.in three silos (ID Nos: ES-2 or company ID No. 1-A or
#1, ES-3 or 1-B or #2 and ES-4 or 1-C or #3) during the inspection. I observed 10% visible emissions
from the top of the three storage silos.
Observations of insignificant air emission sources and control devices listed on the current permit:
Source Exemption Source of Source of Title V
Regulation T.APs? Pollutants?
IES-2 -natural gas/No. 2 fuel oil102
-
fired hot oil heater (2.2 million Btu . �(2)(B)(i)(I) Yes Yes
per hour maximum heat input rate
Natural gas -fired hot oil heater is used to heat the hot oil in two compartment liquid asphalt tank (ID No.
MS-3); one heat exchanger (pre -heater for No. 4 recycled fuel oil); asphalt drag slat conveyor; hot oil
lines for mixer (bottom outer shell drum or mixing chamber); one traverse conveyor; and the loadout
cone on asphalt silo (ED No. ES-4 or 1-C or 93). The hot oil is recirculated.
o. 2 fuel oil is listed as the backup fuel source for the hot oil heater. This heater has the capability to
)crate on No. 2 fuel oil if it was connected to the No. 2 fuel oil line. Mr. Pickett stated that hot oil
-later has never been installed on the No.'2 fuel oil line and never operated on No. 2 fuel oil.
Observed: Hot oil heater was operating on natural gas during the inspection. I observed no visible
emissions from the hot oil heater.

Blythe Brothers. Asphalt Co., LLC - Concord Plant
May 16, 2017
Page 5
TES-3 -'two compartment liquid
asphalt storage tank (capacities of
2Q .0102
20,000 and 10,000 gallons per
No
No
compartment)
�(c)(1)(L)WO
Liquid asphalt is stored in the two compartment -liquid asphalt storage tank (20,000 and 10,000 gallons, I
'1992).
each; installed Liquid asphalt is mixed with sand, aggregate, and RAP in the rotary drum and
then heated by the dryer to produce the hot mix asphalt product.
Observed: Liquid asphalt was being mixed in the rotary drum with sand, aggregate, and RAP and then
heated by the dryer to produce the hot mix asphalt product. I observed no visible emissions from two
compartment liquid asphalt storage tank (ID IES-3).
rIES-4.-recycled No. 4 fuel oil
2Q .0102 (c)(1)(D)(i)
Yes
���
Yes
orage tank (20,000 gallon capacity) I
This tank is referred to as the holding tank. No. 4 recycled fuel oil is used as the secondary fuel source
for the rotary drum dryer. A heat exchanger (pre' -heater) is used to heat the No. 4 recycled fuel oil prior
to the rotary drum dryer. i
Observed: No.. 4 fuel oil tank was not in use during this inspection. I observed no visible emissions
from this tank.
IES-5 - recycled No. 4 fuel storage
tank (12,000 [2Q .0102 (cj(1)(D)(i) Yes Yes
gallon capacity)
This tank is referred to as the burn tank. No. 4 recycled fuel oil is used as the secondary fuel source for
the rotary drum dryer. A heat exchanger (pre -heater) is used to heat the No. 4 recycled fuel oil prior to
the rotary drum dryer.
Observed:, No. 4 fuel oil tank was not in use during this inspecti.o_ n.
IES-6 —No. 2 fuel oil storage tank 2( ..0102 I(1)(i))(i)
(20,000
Yes
—7 Yes
gallon capacity)
No. 2 fuel oil (off -road virgin) is used in the front end loader and trucks. No. Ifuelpil could be used as
the backup fuel source for -the rotary drum dryer (ID No. ES-1) and hot. oil heater OD No. IES-2). Mr.
Pickett stated that rotary drum dryer (ID No. ES-1) was currently operating on natural gas. However,
the hot oil heater (ID No. IES-2) has never been installed on the No. 2 fuel oil line and never operated
on No. 2 fuel oil.
I
Observed: No. 2 fuel oil tank was not in use during this inspection.
6. Observations of air emission sources_ and control devices not listed on the current permit:
a. This company has a heat exchanger (referred to by this company as the pre -heater) that is
used to heat the`No. 4 "recycled fuel oil using thermal fluid (hot oil flows through coils
and transfers heat to the No. 4 recycled fuel oil) from the two No. 4 recycled fuel oil
tanks (ID Nos. IES-4, 20,000 capacity; and IES-5, 12,000 gallon capacity) p' nor.to the
burner of the rotary drum dryer.
b.. A release agent (manufacturer, ChemStation Co. of NC; and product name 4.147) is
sprayed in the beds of trucks prior to the asphalt loadout process. The release agent stops
the bonding of the asphalt to the beds of the trucks.

Blythe Brothers Asphalt Co., LLC - Concord Plant
May 16, 2017
Page 12
ii. Each load of recycled fuel oil received shall include the following:
A. A delivery manifest document clearly showing the shipment
content and amount, its place and date of loading, and place and
date of destination.
B. A batch specific analytical report that contains an analysis .for all
constituents/properties listed above. Analytical results of the
samples representative of the recycled oil shipment from the
vendor shall be no more than one year old when received.
C. Batch signature information consisting of the following: a batch
number, tank identification with batch volume of recycled oil, date
and time the batch completed treatment, and volume(s) delivered.
D. A certification. indicating that the recycled fuel oil does not
contain detectable PCBs (<2ppm).
d. Reporting Requirements -Within 30 days after each calendar year, regardless of the
amount received or combusted, the permittee shall submit in writing to the
Regional Supervisor, DAQ, the following:
i. A summary of the _ results of the analytical testing for the previous 12
months.
I! The .total gallons of recycled fuel oil(s) from each approved vendor
combusted at the facility for the previous 12 months.
Observed. Recycled No. 4 fuel oil and recycled No. 2 fuel oil were not
combusted. in the rotary drum dryer during calendar year 2016. Recycled No. 4
fuel oil was last combusted on January 31, 2014`due fo natural gas curtailment by
the supplier. The analytical results of the recycled No. 4 fuel oil indicated that
the above allowable levels were not exceeded. Compliance with this stipulation
is indicated.
8. GACT/MACT Review:
This company does not Have any engines/generators or fire pumps at this facility..
9. Summary of changes needed to the current permit:
a. Per the DAQ memo dated August 13, _2013, asphalt plants are now required to test once
every 1.0 years. This office sent a letter dated a letter dated September 13, 2013 advising
this facility, of emission testing procedures.. The last stack testing was .performed for
visible emissions (Method 9) and particulate emissions (Method 5 & 202) on July 23,
2009. The results of these tests indicated compliance with the visible and particulate
emissions limitations. The stack testing requirement should be added during the next
permit renewal cycle in 2018.
b. The electronic yellowsheet for permit changes needed has been completed and placed in
the facility's electronic file.

D
Blythe Brothers Asphalt Co., LLC - Concord Plant
May 16, 2017
Page 13
10. Compliance assistance offered during the inspection:
No compliance assistance was offered during the inspection.
11. Section 112(r) applicability:
This facility does not appear to be subject to the requirements of the Chemical' Accident Release
Prevention Program, Section 112(r) of the Clean Air. Act.
12. Compliance determination:
Based on my observations, this facility appeared to be in compliance with the applicable air
quality regulations at the time of the inspection.
OR:lhe
c: MRO File
G:\AQ\Shared\WPDATA\COUNTIES\CABARRUS\00101\INSPECT 20170516 MULTRvMDIA.doex

Compliance Inspection Report
Permit: NCG160001 Effective: 10/02/14 Expiration: 09/30/19 owner: Blythe Brothers Asphalt Company L L C
SOC: Effective: Expiration: Facility: Blythe Brothers Asphalt -Concord Plant
County: Cabarrus 660 Goodman Rd
Region: Mooresville
Concord NC 28027
Contact Person: Franklin W Blythe Title: Owner Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):.
On -Site Representative(s):
Related Permits:
Inspection Date: 05/16/2017
Primary Inspector: Od A Tuvia
Secondary Inspector(s):
Certification:
Phone:
Entry. Time: 09:30AM Exit Time: 12:OOPM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Asphalt Paving Mixture Stormwater Discharge COC
Facility Status: 0 Compliant Not Compliant.
Question Areas:
Storm Water
(See attachment summary)
Page: 1

Permit: NCG160001 Owner - Facility: Blythe Brothers Asphalt Company L L C
Inspection Date• 05/1612017 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: NCG160001 Ownar - Facility: Blythe Brothers Asphalt Company L L C
Inspection Date: 05116/2017 Inspection Type: Compliance Evaluation Reason for visit: Routine
Stormwater Pollution Prevention Plan
Does the site have a Stormwater Pollution Prevention Plan?
# Does the Plan include a General Location (USGS) map?
# Does the Plan include a "Narrative Description of Practices"?
# Does the Plan include a detailed site map including outfall locations and drainage areas?
# Does the Plan include a list of significant spills occurring during the past 3 years?
# Has the facility evaluated feasible alternatives to current practices?
# Does the facility provide all necessary secondary containment?
# Does the Plan include a BMP summary?
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
# Does the facility provide and document Employee Training?
# Does the Plan include a Iist.of Responsible Party(s)?
# Is the Plan reviewed and updated; annually?
# Does the Plan include a Stormwater Facility Inspection Program?
Has the Stormwater Pollution Prevention Plan been implemented?
Comment: Records must be better maintained and organized.
No record of training as been documented.
Qualitative Monitorinq
Has the facility conducted its Qualitative Monitoring semi-annually?
Comment:
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment:
Permit and Outfalls
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
# If the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment:
Yes No NA NE
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❑■❑❑
❑ M' ❑ ❑
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Yes No NA NE
ME] ❑❑
Yes No NA NE
❑ ❑ ❑
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Yes No NA NE
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Page: 3

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WASTE MANAGEMENT
HAZARDOUS WASTE SECTION
COMPLAINT INVESTIGATION REPORT
1. FACILITY INFORMATION:
Name:
Blythe Brothers Asphalt Co., LLC - Concord Plant
EPA ID Number:
NCS000002414
Type of Facility:
CESQG
Facility Location:
660 Goodman Road., Concord, NC 28027
Facility Address:
Same
Telephone Number:
[phone]
County:
Cabarrus
2. AUTHOR OF REPORT: Andrew Martin, Environmental Senior Specialist, NCDEQ
919-270-3507 andrew.mardn a ncdenx.gov
Date of Report: June 1, 2017
3. FACILITY CONTACT: Tye Picket — Plant Foreman
Office: [phone]
4. INSPECTORS: Andrew Martin-NCDEQ Hazardous Waste Section; Ms. Donna Cook of MRO DAQ, Ori Tuvia
of MRO DWR
5. DATE OF INSPECTIONS: May 16, 2017, 9:30a.m. —12:30 p.m.
6. PURPOSE OF EVALUATION: To determine compliance with hazardous waste management regulations
7. REPORT: On May 16, 2017, a multimedia inspection at the subject facility was conducted. The facility is
currently operating as a Conditionally Exempt Small Quantity Generator (CESQG).
Blythe Brothers Asphalt Company, LLC operates a drum mix type asphalt plant. The asphalt plant operates on a
varied schedule, which is dependent upon weather conditions and road projects. The facility generates used oil and
aerosol containers. A 12,000 and 20,000-, gallon above ground "Recycled Fuel" tanks are located onsite. The
recycled oil is provided by Safety-Meen and is used as a secondary fuel source for the rotary drum dryer.
8. COMMENTS AND RECOMMENDATIONS
• It is a reminder that per 40 CFR 279.22 (c)(1), containers and aboveground tanks used to store used oil at
generator facilities must be labeled or marked clearly with the words "Used Oil."
It is a reminder that spills of petroleum must be immediately cleaned up and properly disposed of.
• Aerosol cans could be listed as a hazardous waste. It is a reminder that the facility ensure that used, spent, or
waste aerosol containers are properly managed by conducting a waste determination per 40 CFR 262.11.
9—�Pwwl 6-1-2017
By Mail
INSPECTOR (DATE)
cc: Sean Morris, Western Area Compliance Supervisor
Central Office Files
FACILITY CONTACT