Air Quality Permit File SOOP # Lindy Paving, Inc. I Homer City Plant

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1 OffiCIAL FILE COPY SOUTHWEST REGIONAL OFFICE MEMO TO FROM THROUGH DATE Air Quality Permit File SOOP # Lindy Paving, Inc. I Homer City Plant Sheila A. Shaffer~ Air Quality Engineering S~ecialist Barbara R. Hatch, P.E. ~ \ Environmental Engineer~ January 8, 2013 anager ~1/T Mark A. Wayner, P.E. Air Quality Manager RE Review of State Only Operating Permit Renewal Application Center Township, Indiana County APS# ; AUTH # ; PF# Background On June 12, 2009, the Department received a synthetic minor operating permit renewal application for IA Construction Corporation I Homer City Asphalt Plant located in Center Township, Indiana County. The Department determined the renewal application was administratively complete on June 29, The last authorized operating permit was issued on November 16, 2004 and expired November 16, On June 7, 2012, the Department was notified ofthe Change of Ownership from IA Construction to Lindy Paving, Inc. Lindy Paving acquired ownership on April4, The Responsible Official and Permit Contact is Paul Reiner, General Manager. Authorizations On September 19, 2012, the Department authorized the Request for Determination (RFD) for the installation and operation of a temporary portable recycled asphalt paving crushing and screen operating under 25 Pa Code Section ( a)(8). The authorization included a Metso ST356 portable crusher and screen rated less than 150 tons per hour, 415 bhp Caterpillar CPXL 12.0 ESK diesel engine and a 300 bhp Mtso C-9 diesel engine. The total NOx emissions from the engines do not exceed 100 lbslhr, 1,000 lbslday, 2.75 tons per ozone season and 2.87 tons per year. The crusher was authorized to operate no more than 12 days and process a maximum throughput of 15,000 tons of RAP. On August 19, 2011, the Department authorized the Request for Determination (RFD) for the replacement of 2 asphalt storage tanks (11,500 gallons and 12,500 gallons) with one 30,000 gallon asphalt storage tank under 25 Pa Code (a)(9). The existing 2.0 MMBtu oil heater remained in place and is of sufficient capacity to heat the proposed 1

2 tank. The existing storage tanks remain in operation at this time. The new tank is onsite but has yet to be permanently installed and connected. On May 16,2011, the Department authorized the Request for Determination (RFD) for the installation of a warm mix system injecting H20 into the asphalt mix under 25 Pa Code (c)(2). The process would allow lower mixing temperatures and less fuel. No chemical additives are used in the injection and this process did not cause an increase in emissions. This has yet to be installed. On April19, 2011, the Department authorized the Request for Determination (RFD) for the replacement of a 27,000 gallon asphalt storage tank with one 30,000 gallon asphalt storage tank under 25 Pa Code (c)(2). The existing 2.0 MMBtu oil heater remained in place and is of sufficient capacity to heat the proposed tank. The existing storage tank remains in operation at this time. The new tank is onsite but has yet to be permanently installed and connected. On April 19, 2011, the Department authorized the Request for Determination (RFD) for the temporary operation of a fiber additive machine to add cellulose fiber to the asphalt mix under 25 Pa Code (c)(1). The operation consists of 15,000 tons of stone matrix mix containing 0.3 percent fiber for a total of90,000 pounds. The process is powered by electricity and will not cause an increase in emissions. On July 13, 2010, the Department authorized the Request for Determination (RFD) for the temporary use of 5 percent of manufacturer reject shingles in the asphalt mix under 25 Pa Code (a)(8). This temporary addition did not increase or change emissions. On April27, 2010, the Department authorized the Request for Determination (RFD) for the change in timeframe for annual tune-up to mirror the General Plan Approval/ Operating Permit (GP-13). The burner tuning must be performed no later than June 15 of each year or within 4 weeks after each start-up. On May 3, 2007, the Department received a letter notifying that the dryer burner was destroyed in a truck accident on April 30, 2007 while in route to the manufacture for routine maintenance. The manufacturer replaced the burner with a Hauck Manufacturing, Eco-Star 11 Model 75 burner rated at 82 MMBtulhr. The previous burner was rated at 86 MMBtulhr. Sources, Control Devices and Emissions Lindy Paving owns and operates a Hot Mix Asphalt (HMA) plant and produces asphalt concrete using a batch mixing process. The facility consists of a 240 ton per hour batch asphalt plant that was installed in 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. Eco-Star 11, Model 75 burner. This burner was installed in May 2007 and has a rated heat input of 82 MMBtu!hr. The burner can be fired with natural gas, No. 2 fuel oil, liquid propane or 2

3 waste derived liquid fuel (WDLF). The plant is equipped with a Settling Chamber Warren Rail Car Service Knockout Box, Model HC1010 and Reverse Air Amerex Baghouse, Model RP D6 installed in 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 490,000 tons per year of asphalt to limit CO emissions to less than 100 tons per year. AP- 42 and NAP A emission factors are used in determining potential emissions from the entire site. Table 1: Facility Wide Potential Emissions based on 490,000 tons of production TonsNear co NOx SOx PM voc HAPs Batch Plant Material Handling Storage Total Emissions: An Alternative Operating Scenario (AOS) has been incorporated into the operating permit to address the temporary operation and processing of Recycled Asphalt Pavement (RAP). Lindy contracts companies to bring in RAP processing equipment which consists of crushing and screening when the stockpile gets low or is ready to use. The operation is powered by diesel engine(s) which are also brought on site by a contractor. Lindy is limited to NOx emissions of 100 lbs/hour, 1,000 lbs/day, 2.75 tons per ozone season and 6.6 tons per 12 month rolling total, for all combined engines used, this process based on the RFD exemption, 25 Pa Code ( a)(8)-( 6). The CO emissions are not permitted to equal or exceed 1.0 tons per 12 month rolling total based on the facility being synthetic minor for CO. Lindy is also required to obtain proof of authorization from the contractor to operate each engine, GP-13, manufacturer's specifications including emission factors and/or most recent stack testing approved by the Department. Testing On July 9, 2009, Air Nova Inc. conducted testing of the baghouse exhaust to determine the filterable particulate matter (EPA Method 5), NOx (Method 7E), carbon monoxide (Method 1 0), VOC (Method 18 and 25A) and visible emissions (Method 9). The Department determined the test runs were performed in accordance with acceptable standard sampling methods, calculations were correct and the results appeared to be valid. On April , the Department determined the facility was in compliance based on the stack test performed. Lindy is required to perform the next stack testing prior to 2015 and every 5 years thereafter. 3

4 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 abnormal visible emission, fugitive emission and malodor restrictions in 25 Pa. Code 123.1, 123.2, , and Records of the daily survey performed must be recorded. Preventative maintenance inspections are to be performed on the control devices and recorded in an on-site log. The facility is also required 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 0.04 gr/dscf and visible emissions are not to exceed 20 percent opacity at any time from the baghouse exhaust stack. The facility is not permitted to exceed the production of 490,000 tons per year of asphalt. Annual burner tuning must be performed each season within four weeks of startup or by June 15. The facility must also conduct a stack test every five years for PM, NOx, CO, and VOC. 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. As indicated above, IA submitted the permit renewal application on June 12, 2009 which was 5 months prior to the expiration date ofnovember 16, Per Title 25 Pa Code (e): Applications for permit renewals shall be submitted at least 6 and not more than 18 months before expiration ofthe existing permit. The Department was then unable to issue the operating permit before the expiration date and through no fault of the permittee the Department did not approve or disapprove the application within 18 months after receiving the complete application as required in Title 25 Pa Code (b). No action was taken by the Department regarding the late submittal at the time of receipt of application. The facility has not received a violation or an enforcement action from the Department in the last five years. Due to the change of ownership, the Department's failure to issue the permit within the requirements and the compliance status of the facility in the last five years, I feel enforcement action is not necessary in this situation. Regulatory Analysis Lindy 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, The facility is subject to the emission limitations and recordkeeping requirements. Conclusions and Recommendations On June 12, 2009, IA Construction /Homer City Asphalt Plant applied for a State Only Operating Permit renewal for their facility located in Center Township, Indiana County. IA complied with the municipal notification requirements contained in 25 Pa. Code and the application fee requirements contained in 25 Pa. Code (b)(3). The draft Operating Permit will be submitted to Lindy Paving for review. The Notice of Intent to Issue will be published in the PA Bulletin for a 30-day public comment period. 4

5 On July 26, 2012, annual compliance inspection was performed by Mr. Thomas Norris, Air Quality Specialist. Mr. Norris did not note any violations at the time of his inspection. It is my recommendation that the State Only Operating Permit for Lindy Paving, Inc. I Homer City Asphalt Plant, SOOP , be issued. 5