1 / 19

Enforcement of Hot Mix Asphalt Plant Regulations

Enforcement of Hot Mix Asphalt Plant Regulations. Dana Podell and Marley Shoaf. Presentation Overview. Typical Inspection What are we looking for during an inspection? Fines and Penalties Avoiding Enforcement. Typical Inspection. Compliance with permit conditions;

Download Presentation

Enforcement of Hot Mix Asphalt Plant Regulations

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript


  1. Enforcement of Hot Mix Asphalt Plant Regulations Dana Podell and Marley Shoaf

  2. Presentation Overview • Typical Inspection • What are we looking for during an inspection? • Fines and Penalties • Avoiding Enforcement

  3. Typical Inspection • Compliance with permit conditions; • Compliance with O&M plan; • Inspection of equipment; and • General inspection of facility/site.

  4. Typical Permit - General Information • Permit Number • Facility Information • Address • Equipment Type • Permitted Fuel Type • Control Equipment • Permit Conditions • AIRS ID

  5. Typical Permit - Notes to Permit Holder • APEN filing deadline • Malfunction Reporting • Emission Factors • Source Type

  6. Toward the end of each HMA permit. Used when the Division calculated your emissions. NOT optional. May include speed limit, watering requirements, no off- property transport. Typical Permit - Control Measures

  7. Compliance with Permit Conditions • Is the equipment located at the correct address? • If the plant is portable, have relocation notices been filed? • Is the permitted equipment onsite? • Asphalt drum model and serial number • Control equipment • Burner • Silos and additional storage tanks • Generators • Is there any un-permitted equipment onsite? • Is the burner using the permitted fuel type?

  8. Compliance with Permit Conditions • Visible emissions shall not exceed 20% opacity (30% allowed during startup, modification, and adjustment of control equipment).

  9. Compliance with Permit Conditions • Prevention of Significant Deterioration (PSD) requirements and Operating Permit (OP) requirements shall apply when the potential to emit above the applicable PSD and OP threshold exists. • No off-specification oil shall be burned (or similar fuel requirement). • Permit number shall be marked on the equipment.

  10. Compliance with Permit Conditions • Source shall be limited to maximum production rate. Compliance determined on a rolling twelve (12) month total. If daily limits apply, must demonstrate compliance. Compliance records kept onsite. • Emissions of air pollutants shall not exceed specified limitations. Compliance determined on a rolling twelve (12) month total. Compliance records kept onsite.

  11. Recordkeeping Example

  12. Compliance with Permit Conditions • Operating and Maintenance Plan • - Submitted to the Division before Final Approval of the Permit. • - Keep a copy at the plant. • - Operators should know what it says and be following it. • - Keep records of maintenance work or operational conditions as stated in the plan.

  13. Compliance with Permit Conditions • Regulation No. 6, Part A, Subpart I: Standards of Performance for Hot Mix Asphalt Facilities. • - PM discharge shall be 0.04 gr/dscf or less. • - Opacity shall be 20% or less. • - Operation and maintenance consistent with good air pollution control practices. • - Written notification of construction and startup dates. • - Records of startup, shutdown, and malfunction shall be maintained. • - Opacity observations and performance tests (required for final approval).

  14. Compliance with Permit Conditions • Particulate emission control measures shall be applied. • No off-property transport of visible emissions from processing activities, haul roads, and haul trucks. • Water stockpiles as necessary. • Paving or watering of all entryways, service roads, and batching areas. • Posted speed limit signs. • Air Pollutant Emission Notice (APEN) • At least every 5 years. • Change in owner, process, activity, and new or replaced control equipment. • Modification of permit limits. • Significant increase in emissions.

  15. Compliance with Permit Conditions FINAL APPROVAL • Must demonstrate compliance with all permit conditions to the Division within 180 days after starting operation. • Includes submittal of: • Operating & Maintenance Plan. • Manufacturer, model, serial number of equipment. • Performance/Compliance tests and opacity readings required under Subpart I. • Notice of Start-up. • Self-Certification form.

  16. The Enforcement Process Two Tracks: Formal and Informal • Formal: the Division issues a Notice of Violation (NOV) • Lists alleged violations • Parties meet to discuss • Division calculates penalties & issues a compliance order • Informal: the Division issues a Compliance Advisory (CA) • Less formal document • Parties meet to discuss • Division calculates penalties & issues a settlement offer • Significant penalty reductions for a negotiated settlement

  17. Fines and Penalties • Can be assessed for any violation of Federal and State regulations and permit conditions. • Can be assessed for operating equipment without a permit. • Most common violations for HMA plants include: • Opacity exceedance. • Recordkeeping (no emissions calculations, incomplete records). • Not following O&M Plan or Fugitive Dust Control Plan.

  18. Avoiding Enforcement • Familiarize plant operators with permit conditions and State/Federal regulations. • Familiarize plant operators with opacity requirements. • Conduct routine self-audits of plants. • Follow O&M Plan. • Ensure that all equipment is permitted, if necessary. • Provide any requested data or APENs by the date specified.

  19. Division Contacts • Field Services - Receptionist (303) 692-3150 • Final Approval - Doug Ryder (303) 692-3189 • Small Business Assistance Program (303) 692-3148 Christine Hoefler (303) 692-3175 Joni Canterbury

More Related