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Background

OffiCiAL ALE COF

SOUTHWEST REGIO AL OFFICE

Air Quality Permit File SOOP # 63-00629 Hanson Aggregates BMC, Inc. I Dunningsville Asphalt Plant

Sheila A. Shaffer ~ Air Quality Engineering Specialist Bureau of Air Quality

Barbara R. Hatch, P .E. Environmental Enginee · Bureau of Air Quality

January 30, 2013

~'9)/ Mark A. Wayner, P.E. Air Quality Manager Bureau of Air Quality

Review of State Only Operating Permit Renewal Application Somerset Township, Washington County APS# 691252; AUTH # 789450; PF# 515538

MEMO

On April 17, 2009, the Department received a synthetic minor operating permit renewal application for Hanson Aggregates BMC, Inc. I Dunningsville Asphalt Plant located in Somerset Township, Washington County. The Department determined the renewal application was administratively complete on June 12, 2009. The last authorized operating permit was issued on November 17, 2004 and expired November 17, 2009. Hanson has been operating under 25 Pa Code Section 127.446(c): The terms and conditions of an expired permit are automatically continued pending the issuance of a new permit when the permittee has submitted a timely and complete application and paid the fees required by Subchapter I and the Department is unable, through no fault of the permittee, to issue or deny a new permit before the expiration of the previous permit.

Sources, Control Devices and Emissions

The facility consists of a 300 ton per hour McCarter batch asphalt plant that was installed in 1998. The process involves drying aggregate material in the form of sand, gravel, crushed stone, or a combination of these materials in a large rotary drum dryer. The dryer is equipped with a Hauck Manufacturing Co. Model SJOG4580E burner unit that has a rated heat input of 120 MMBtu/hour. The burner can be fired with natural gas, No. 2 fuel oil, No. 4 fuel oil, No. 6 fuel oil or waste derived liquid fuel (WDLF). This plant is equipped with a knockout box and fabric filter with a flow of 64,000 acfrn at 250 degrees Fahrenheit. The particulate removal efficiency of the baghouse is rated at 99.9 percent.

The facility wide potential emissions below are based on an annual production limit of 500,000 tons per year of asphalt to limit CO emissions to less than or equal to 100 tons

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per year. AP-42 Emission Factors Chapter 11 and 13 are used in determining potential emissions from the entire site.

Table 1: Facility Wide Potential Emissions based on 500,000 tons of production

Tons/Year

co NOx SOx PM voc HAPs

Batch Plant 100.00 30.00 22.00 10.50 9.00 1.93

Aggregate Handling/Stockpiling 0.00 0.00 0.00 0.23 0.00 0.00

Total Emissions: 100.00 30.00 22.00 10.73 9.00 1.93

Testing

The facility was required under the previously issued operating permit to perform stack testing for PM, CO, NOx, and VOC once during the term of the permit. The last performed stack testing was conducted on August 27, 2008 . The results were determined acceptable by the Department on November 26, 2008 . Moving forward, the facility will be required to perform annual dryer burner tune-ups using a portable CO analyzer. Permit has been conditioned to require stack testing for particulate (Method 5 and Method 9) within one year of issuance of the permit and every five years thereafter.

Compliance

The facility is required to conduct a daily survey of the facility during daylight hours while the facility is operating to ensure compliance with the visible stack emission, fugitive emission and malodor restrictions in 25 Pa. Code§§ 123.1 , 123.2, and 123.31. Records of the daily survey performed must be recorded. Monthly preventative maintenance inspections are to be performed on the control devices and recorded in an on-site log. The facility is also required to minimize drop height from loaders to bins, maintain compact stockpi les, maintain a set vehicle pattern, post speed limit sign of 15 mph as well as promptly remove earth or other material from paved roads onto with earth or other material has been transported by trucking or earth moving equipment, or other means. Particulate matter emissions are not to exceed 0.02 gr/dscf and visible emissions are not to exceed 10 percent opacity from the baghouse exhaust stack. The facility is not permitted to exceed the production of 500,000 tons per year of asphalt. Annual burner tuning must be perforn1ed each season within two weeks of startup. The facility must also conduct a stack test every five years for particulate. Records of daily asphalt production, as well as weekly preventative maintenance inspections and 12-month rolling totals of each fuel type and quantity used are required to be kept on site for five years.

On April 17, 2009, as required , an Air Pollution Control Act Compliance Review Form was submitted with the renewal application. Listed in Section D, the facility violated the opacity limit from the baghouse. The violation was corrected on September 11 , 2006

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including a penalty payment of $5,000. The facility has not received a violation or an enforcement action from the Department since 2006.

Regulatory Analysis

Hanson is subject to 40 CFR Part 60 Subpart I- Standards of Performance for Hot Mix Asphalt Facilities per 60.90(b): any facility that commences construction or modification after June 11, 1973. The particulate matter standards set forth in §60.92 are less stringent than what was established in plan approval PA-63-629A. The facility is subject to Subpart I; however, there are no applicable requirements, recordkeeping or emission limitations subject to Hanson.

Hanson is subject to 40 CPR Part 60 Subpart Kb- Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleun Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced after 1984. The facility is subject to the monitoring and recordkeeping requirements ofthis subpart.

Conclusions and Recommendations

On April 17, 2009, Hanson Aggregates BMC, Inc. I Dunningsville Asphalt Plant applied for a State Only Operating Permit renewal for their facility located in Somerset Township, Washington County. Hanson has complied with the municipal notification requirements contained in 25 Pa. Code§ 127.413 and the application fee requirements contained in 25 Pa. Code §127.704 (b)(3). The draft Operating Permit will be submitted to Hanson for review. The Notice of Intent to Issue will be published in the PA Bulletin for a 30-day public comment period.

On July 27, 2012, a compliance inspection was performed by Mr. Dennis Kozimer, Air Quality Specialist. Mr. Kozimer did not note any violations at the time of his inspection. It is my recommendation that the State Only Operating Permit for Hanson Aggregates BMC, Inc. I Dunningsville Asphalt Plant, SOOP 63-00629, be issued.

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