COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 PERMIT NO: CONSTRUCTION PERMIT DATE ISSUED: January 7, 2015 ISSUED TO: 13LR2446 Issuance 1 Correction THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Stationary Hot Mix Asphalt plant, and associated materials storage, unloading, loading and stockpiles facility, located at 1800 North Taft Hill Road, in Larimer County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: AIRS Point 005 Description One (1) Astec, Model: Turbo 400, Serial Number: 97-010, Counter flow drum Mix plant. One (1) Hauck, model: SJ-4580, Serial Number: PRN27815 burner design rated at 120 MMBtu per hour. Particulate matter (PM) emissions are controlled by a Fabric Filter Baghouse and the associated storage silos. Silo emissions of PM are controlled by a fabric filter baghouse. Fugitive emissions of particulate matter resulting from onsite truck traffic, aggregate stockpiles, and material handling. Particulate control measures listed at the end of this permit are used to control fugitive emissions. Allowable Fuels natural gas and liquid petroleum gas (LPG) for the drum and heater. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL APPROVAL 1. Within one hundred and eighty days (180) after Issuance of this permit, compliance with the conditions contained on this permit shall be demonstrated to the Division. It is the permittee's responsibility to self certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit or enforcement action by the Division. Information on how to certify compliance was mailed with the permit or can be obtained from the Division. (Reference: Regulation No. 3, Part B, IlI.G.2). AIRS ID: 069/0128/005 Page 1 of 12 Version 2009-1
2. Within one hundred and eighty days (180) after issuance of this permit, the operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, III.E.) 3. The owner or operator shall develop an operating and maintenance (O&M) plan, along with a recordkeeping format, that outlines how the applicant will maintain compliance on an ongoing basis with the requirements of this permit. Compliance with the O&M plan shall commence at startup. Within one hundred and eighty days (180) after issuance of this permit, the owner or operator shall submit the O&M plan to the Division. Failure to submit an acceptable operating and maintenance plan could result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.E.) 4. Within thirty (30) days after issuance of this permit, the permit number shall be marked on the subject equipment for ease of identification. (Reference: Regulation No. 3, Part B, III.E.) (State only enforceable) EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations (as calculated using the emission factors included in the Notes to Permit Holder section of this permit). Monthly and Annual records of the actual emission rates shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: AIRS Point Tons per Year PM PM 10 PM 2.5 NO x SO 2 VOC CO Emission Type 005 5.4 1.8 1.3 6.5 0.8 7.6 72.2 Point 005 3.7 0.9 0.1 - - - - Fugitive See Notes to Permit Holder #4 for information on emission factors and methods used to calculate limits. Compliance with the annual limits shall be determined by recording the facility s annual emissions for the pollutants listed above on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months data. The permit holder shall calculate monthly emissions and keep a compliance record on site, or at a local field office with site responsibility, for Division review. Note: Compliance with the fugitive emission limits shall be demonstrated by not exceeding the production limits in condition number 9 and by following the attached particulate emissions control plan. 6. The particulate emission control measures listed on the attached page (as approved by the Division) shall be applied to the particulate emission producing sources as required by Regulation No. 1, Section III.D.1.b. AIRS ID: 069/0128/005 Page 2 of 12
7. The following control equipment shall be maintained and operated to ensure satisfactory performance. The owner or operator shall monitor compliance with this condition through the results of approved compliance tests (when required), compliance with the Operating and Maintenance Plan, compliance records, and other methods as approved by the Division. (Reference: Regulation No. 3, Part B, Section III.E.) AIRS Point Control Device Controlled Pollutants 005 Baghouse PM, PM10, and PM 2.5 005 005 Vapor Recovery System on tanks Ducted recovery system on storage and transfer points PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum consumption, processing and/or operational rates as listed below. Monthly and Annual records of the actual process rate shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits VOC VOC AIRS Point 005 005 Process Parameter Total production of, including produced with LPG, shall not exceed Production of while heating the drum with LPG shall not exceed Annual Limit 475,000 tons per year 40,000 tons per year Compliance with the yearly process limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months data. The permit holder shall calculate monthly process rate and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Opacity shall be determined using EPA Method 9. (Reference: Regulation No. 1, Section II.A.1. & 4.) 10. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 11. This source is subject to Regulation No. 6 Standards of Performance for New Stationary Sources, Part A Federal Register Regulations Adopted By Reference, Subpart I - Standards of Performance for Hot Mix Asphalt Facilities, including, but not limited to, the following: AIRS ID: 069/0128/005 Page 3 of 12
a. Concentration of particulate matter in the gases discharged into the atmosphere shall not be in excess of 0.04 grain per dry standard cubic foot. b. Discharge into the atmosphere shall not exhibit 20 % opacity, or greater. 12. The following requirements of Regulation No. 6, Part A, Subpart A, General Provisions, apply. a. At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (Reference: Regulation 6, Part A. General Provisions from 40CFR60.11 b. No article, machine, equipment or process shall be used to conceal an emission that would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard that is based on the concentration of a pollutant in the gases discharged to the atmosphere. ( 60.12) c. Records of startups, shutdowns, and malfunctions shall be maintained, as required under 60.7. d. Performance tests shall be conducted as required under 60.8. e. Compliance with opacity standards shall be demonstrated according to 60.11. A copy of the complete applicable subpart(s) may found at: http://www.gpoaccess.gov/cfr/retrieve.html 13. This source is located in an ozone non-attainment area, and an attainment-maintenance area for CO. NOx and VOCs are regulated as precursors to ozone. Therefore this source is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2 for those pollutants. RACT for this source is determined to be a vapor recovery system installed on the storage tanks, a ducted recovery system to capture VOC emissions from the HMA storage silo and transfer points leading from the drum to the silo and reroute them back to the drum, and good combustion practices incorporated in to the plant design. OPERATING & MAINTENANCE REQUIREMENTS 14. The owner or operator shall develop an operating and maintenance (O&M) plan, along with a recordkeeping format, that outlines how the applicant will maintain compliance on an ongoing basis with the requirements of this permit. Compliance with the O&M plan shall commence at startup. Within one hundred and eighty days (180) after commencement of operation, the owner or operator shall submit the O&M plan to the Division. Failure to submit an acceptable operating and maintenance plan could result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.E.) AIRS ID: 069/0128/005 Page 4 of 12
COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The owner or operator shall demonstrate compliance with Condition #11 (NSPS Subpart I), using EPA Method 9 to measure opacity from the stack. For purposes of determining initial compliance, the minimum total time of observations shall be 3 hours and the opacity observations shall be conducted concurrently with the initial performance test required in 60.8. (Reference: Regulation No. 6, Part A, Subpart A, General Provisions 60.11) 16. A source initial compliance test shall be conducted at the main stack on this plant to demonstrate compliance with the pollutant emission rates listed below. The test protocol, test and test report must be in accordance with the requirements of the Compliance Test Manual using EPA approved methods. The protocol shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. (Reference: Common Provisions II.C and Regulation No. 3, Part B; III.G.3) Particulate Matter (PM): 5.133 tons per year 0.04 grains per dscf of exhaust. (NSPS Subpart I) Carbon Monoxide (CO): 69.113 tons per year 0.291 pounds per ton of produced Oxides of Nitrogen (NOx): 6.175 tons per year 0.026 pounds per ton of produced ADDITIONAL REQUIREMENTS 17. This permit replaces the following permits and/or points, which are canceled upon issuance of this permit. Permit No. AIRS ID Notes 97PO0030 777/1050/001 Permit is being reissued as a stationary permit. 18. The AIRS ID number shall be marked on the subject equipment for ease of identification. (Reference: Regulation No. 3, Part B, III.E.) (State only enforceable) 19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year of a criteria pollutant, a change in annual actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO x ) in ozone nonattainment areas emitting less than one hundred tons of VOC or AIRS ID: 069/0128/005 Page 5 of 12
NO x per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more of a criteria pollutant, a change in annual actual emissions of five percent or fifty (50) tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For sources emitting any amount of lead, a change in actual emissions of fifty (50) pounds of lead above the level reported on the last APEN submitted. For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 20. Public access shall be precluded in all areas within the modeling receptor exclusion zone (as seen in attachment A) as submitted with the modeling in the application. The exclusion zone shall be and posted with no trespassing signs and patrolled during hours of operation. (Reference: Regulation No. 3, Part B, Section III.B.5 21. The source shall notify the Division if there is a change in the location of the plant to determine if a revision to the ambient air quality analysis is necessary. 22. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Colorado Regulation No. 3, Part D, Section VI.B.4). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: AIRS Point Equipment Description Pollutant Emissions - tons per year Threshold current permit limit 005 Asphalt Plant CO 250 72.2 AIRS ID: 069/0128/005 Page 6 of 12
GENERAL TERMS AND CONDITIONS: 23. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the Division as provided in Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 24. If this permit specifically states that final approval has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit is considered initial approval and does not provide "final" approval for this activity or operation of this source. Final approval of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final approval cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final approval. Details for obtaining final approval to operate are located in the Requirements to Self-Certify for Final Approval section of this permit. The operator shall retain the permit final approval letter issued by the Division after completion of selfcertification with the most current construction permit. 25. This permit is issued in reliance upon the accuracy and completeness of information supplied by the applicant and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the applicant or applicant's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. By: K.C. Houlden Permit Engineer By: R K Hancock III, P.E. Construction Permits Unit Supervisor Permit History Issuance Date Description Initial Approval December 23, 2014 Issued to Martin Marietta Materials. Conversion from portable permit # 97PO0030. Correction January 7, 2015 Language in requirements to self certify was changed from After commencement of operation to from issuance of this permit since source has been operating prior to issuance of this permit. Emission factor for NOx in condition No. 16 was corrected from 0.26 to 0.026. AIRS ID: 069/0128/005 Page 7 of 12
Notes to permit holder: 1) The production or raw material processing limits and emission limits contained in this permit are based on the production/processing rates requested in the permit application. These limits may be revised upon request of the permittee providing there is no exceedence of any specific emission control regulation or any ambient air quality standard. A revised air pollutant emission notice (APEN) and application form must be submitted with a request for a permit revision. 2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: http://www.cdphe.state.co.us/regulations/airregs/5ccr1001-2.pdf. 3) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emission Rate (lb/yr) Are the emissions reportable? Controlled Emission Rate (lb/yr) Formaldehyde 50000 1,473 YES 1,473 005 Hexane 110543 437 YES 437 Toluene 108883 71 NO 71 Benzene 71432 185 NO 185 Ethylbenzene 100414 114 NO 114 5) The emission levels contained in this permit are based on the following emission factors: Point 005 Drum Mixer when operating on Natural Gas: Emission Factors - Uncontrolled Emission Factors Controlled Pollutant lb/ton of Source lb/ton of Source PM 27.916 Division Derived 0.02162 Division Derived PM10 8.3748 Division Derived 0.00649 Division Derived PM2.5 2.3476 Division Derived 0.00454 Division Derived NO x 0.0260 AP-42 0.0260 AP-42 CO 0.2910 Applicant 0.2910 Applicant VOC 0.0320 AP-42 0.0320 AP-42 AIRS ID: 069/0128/005 Page 8 of 12
Emission Factors - Uncontrolled Emission Factors Controlled Pollutant lb/ton of Source lb/ton of Source SO2 0.0034 AP-42 0.0034 AP-42 Point 005 Drum Mixer when operating on Liquid Petroleum Gas (LPG): Emission Factors - Uncontrolled Emission Factors Controlled Pollutant lb/ton of Source lb/ton of Source PM 27.916 Division Derived 0.02162 Division Derived PM10 8.3748 Division Derived 0.00649 Division Derived PM2.5 2.3476 Division Derived 0.00454 Division Derived NO x 0.0260 AP-42 0.0260 AP-42 CO 0.4000 AP-42 0.4000 AP-42 VOC 0.0320 AP-42 0.0320 AP-42 SO2 0.0034 AP-42 0.0034 AP-42 Point 005 Asphalt Heater when operating on Natural Gas and Liquid Petroleum Gas (LPG): Emission Factors - Uncontrolled Emission Factors Controlled Pollutant lb/mmcf Nat. Gas Source lb/mmcf Nat. Gas Source PM 7.60 AP-42 7.60 AP-42 PM10 7.60 AP-42 7.60 AP-42 PM2.5 7.60 AP-42 7.60 AP-42 NO x 100.00 AP-42 100.00 AP-42 CO 84.00 AP-42 84.00 AP-42 VOC 5.50 AP-42 5.50 AP-42 SO2 0.60 AP-42 0.60 AP-42 Materials Hauling and Stockpile (Fugitive): Particulate Matter (TSP):... 0.0005 pounds per ton of HMA produced Particulate Matter < 10 µm (PM10):..0.0005 pounds per ton of HMA produced Particulate Matter < 2.5 µm (PM2.5):.0.0003 pounds per ton of HMA produced Silo Operations: Particulate Matter (TSP):... 0.0006 pounds per ton of HMA produced Particulate Matter < 10 µm (PM10):..0.0006 pounds per ton of HMA produced Particulate Matter < 2.5 µm (PM2.5):.0.0003 pounds per ton of HMA produced AIRS ID: 069/0128/005 Page 9 of 12
6) This facility is classified as follows: Applicable Requirement Operating Permit PSD NANSR Status Synthetic Minor facility for CO Synthetic Minor facility for CO Minor facility 7) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.90-60.93 Subpart I 8) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 9) Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the Division to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 10) Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Division on grounds set forth in the Colorado Air Pollution Prevention and Control Act and regulations of the AQCC including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the applicant, or the Division revokes a permit, the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Division s action. 11) Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollutant Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 12) Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. AIRS ID: 069/0128/005 Page 10 of 12
PARTICULATE EMISSIONS CONTROL PLAN FOR MATERIAL PROCESSING ACTIVITIES THE FOLLOWING PARTICULATE EMISSIONS CONTROL MEASURES SHALL BE USED FOR COMPLIANCE PURPOSES ON THE ACTIVITIES COVERED BY THIS PERMIT, AS REQUIRED BY THE AIR QUALITY CONTROL COMMISSION REGULATION NO.1, Section III.D.1.b. THIS SOURCE IS SUBJECT TO THE FOLLOWING EMISSION GUIDELINES: a. Processing Activities - Visible emissions not to exceed 20%, no off-property transport of visible emissions. b. Haul Roads - No off-property transport of visible emissions shall apply to on-site haul roads, the nuisance guidelines shall apply to off-site haul roads. c. Haul Trucks - There shall be no off-property transport of visible emissions from hauls trucks when operating on the property of the owner or operator. There shall be no off-vehicle transport of visible emissions from the material in the haul trucks when operating off of the property of the owner or operator. CONTROL MEASURES 1. Material stockpiles shall be watered as necessary to control fugitive particulate emissions. Aggregate materials shall be sprayed with water during material loading into the storage bins or stockpiles if necessary. 2. On site haul roads used to move aggregate shall be graveled. Watering shall be implemented if dust problems occur. 3. On site haul roads for removal of hot mix from site shall be paved and or graveled. Watering shall be implemented if dust problems occur. 4. Vehicle speed on haul roads and service roads shall be restricted to 15 miles per hour. Speed limit signs shall be posted. AIRS ID: 069/0128/005 Page 11 of 12
Attachment A Figure: map/aerial image identifying stack and radius. AIRS ID: 069/0128/005 Page 1 of 12 Version 2009-1