3.

2 Asphalt Production

3.2.1 General Description of Source Category

LANL operates an existing small asphalt batch plant that produces hot mix
asphalt for minor road patching and paving. The plant, located at TA-3-73, is a Barber-
Greene Model No. 892 and was installed at LANL in 1960.

The plant mixes aggregate with liquid asphaltic cement to produce bituminous
pavement material. Aggregate is stored in piles near the plant. Asphaltic cement,
consisting of asphaltenes, resins, and oils, is stored in a tank adjacent to the plant. The
asphaltic cement is a solid at normal ambient temperature; a 1.4 MMBtu/hr natural gas
fired heater is used to liquefy the asphaltic cement during production.

When hot mix asphalt is required, aggregate is transported by conveyor to a

natural gas fired rotary dryer. A conveyor lifts the dry aggregate to a storage hopper.
The plant operator releases aggregate from the hopper onto a measuring tray. A
measured amount of aggregate is then dropped into a mixing chamber, where it is mixed
with the proper proportion of liquid asphaltic cement, to produce the desired consistency
of hot mix asphalt. The hot mix asphalt is dispensed directly into dump trucks for
transport to the job site.

A new asphalt plant, BDM Engineering, Model Number TM2000, will be

constructed to replace the existing plant, which will cease to operate upon startup of the
new plant. Moist rock and sand are fed into a rotary dryer where it is dried and heated
using a 25 MMBtu/hr propane gas burner. The dried aggregate is discharged into a
bucket elevator, which discharges onto a vibrating screen that separates the material into
different sizes. Material is discharged into a weigh hopper and then into a mixer where
liquid asphalt is added as a percentage of the total mixture. The dust from the dryer is
passed through a cyclone and baghouse to clean the gas stream. The clean gases are
discharged to the atmosphere while the dust collected is discharged into the hot elevator
by means of a screw conveyor and incorporated into the hot mix. The plant was permitted
under 20.2.72 NMAC in October of 2002. Start-up of the unit is expected early in 2003.
 LANL procures asphalt paving material from outside contractors whenever
possible. LANL will produce asphalt only when outside asphalt contractors are
unavailable to provide support. LANL will require any asphalt contractors bringing
equipment onto the site to provide a copy of their current air permit from the New
Mexico Environment Department and demonstrate they are in compliance with all
applicable air quality control requirements.

LANL wishes to establish a federally enforceable permitted production limit for

asphalt in order to limit criteria pollutant emissions. The proposed asphalt production
limit is 13,000 tons per year, 12-month rolling average. The production limit is based on
anticipated demand, and actual production rates for recent years.

3.2.2 Operating Schedule

The normal operating schedule for the Barber-Greene asphalt plant is less than 8
hours per day once or twice a week when patching is being performed. The maximum
asphalt production rate is 60 tons per hour (120,000 pounds per hour). The maximum
operating schedule for the BDM Engineering asphalt plant is 10 hours a day, 7 days a
week for approximately 25 weeks per year with a maximum production rate of 80 tons
per hour (160,000 pounds per hour). The actual schedule will be similar to the current
schedule. A proposed production limit of 13,000 tons per year will be set on the asphalt
plant through this application. The actual hours of operation will depend on the
production rate.

3.2.3 Process Flow Diagram

Flow diagrams for the operation of the two asphalt plants are provided in Figures
3.2-1 and 3.2-2.
 Figure 3.2-1. Process Flow Diagram for Existing Asphalt Plant – Barber Greene

1
4

MULTI-
CYCLONE HOPPER
9
SPRAY
2
SCRUBBER

OR
HEATER

EY
ASPHALT
MIXER 8

NV
TANK
3 6

CO
5

S ED
CLO
b
GAS
7
HEATER
G AS
TE OR
EG
A EY ROT
NV AR
GR CO DRY Y TRUCK
AG EN
ER
OP S O LID
S

LEGEND
AGGREGATE
PILE LANL NATURAL 1) Scrubber Exhaust 6) Recycle
GAS SUPPLY 2) Fresh Water 7) Hot Mix
3) Dirty Water 8) Asphalt Cement
4) Multicyclone Exhaust 9) Asphalt Tank
5) Particulate and Dryer Heater Exhaust
Exhaust
 Figure 3.2-2. Process Flow Diagram for New Asphalt Plant – BDM Engineering

Stack

Baghouse Exhaust
Eff: 99.9% Fan

Cyclone
Screen Eff: 70%
Bucket Elevator

Liquid Hot Bins

Asphalt
Weigh Hopper

Mixer Dryer
Rock Sand
Fuel

3.2.4 Emissions

Emissions from the asphalt plant include criteria pollutants (NOx , CO, SO2 , PM
and VOCs), and trace amounts of HAPs. The emissions estimates are presented in Table
3.2-1. The emission factors for regulated air pollutants from the asphalt plant are
summarized in Table 3.2-2. These factors were obtained from EPA’s AP-42, as well as
from results of a source test for controlled particulate matter emissions conducted by
Kramer and Associates on LANL’s asphalt plant on August 25, 1993 (see Appendix C).

Emissions were calculated using the following general formula:

lb lb ton asphalt
Emission Rate ( ) = [Emission Factor ( )] [Asphalt Production Rate ( )]
yr ton asphalt year

The controlled emission rate for particulate matter from the BDM Engineering
asphalt plant was calculated using the AP-42 uncontrolled emission rate factor and
applying the manufacturer’s suggested control efficiencies for the cyclone and the
baghouse.
 The particulate emissions from the BDM Engineering asphalt plant, calculated
using the proposed limit of 13,000 tons per year of asphalt produced are as follows:

 lb   lb    70     99.9  
Emission Rate   = Uncontroll ed Particulat e Emissions   * 1 −    * 1 −  
 year   year    100     100  

Table 3.2-1. Emissions Estimates for Asphalt Production

Emissions (ton/year)
Barber-Greene Plant BDM Engineering Plant
Uncontrolled Controlled Uncontrolled Controlled
NOx 0.16 0.16 0.16 0.16
SO2 0.03 0.03 0.03 0.03
PM 208 0.46 208 0.06
CO 2.60 2.60 2.60 2.60
VOC 0.05 0.05 0.05 0.05
HAP 0.05 0.05 0.05 0.05

Table 3.2-2. Asphalt Plant Emission Factors

Air Pollutant Emission Factor (lb/ton)
(a)
NOx 0.025
(a)
CO 0.40
(a)
SO2 0.0046
(a)
Uncontrolled PM 32
(b)
Controlled PM (Barber-Greene plant) 0.07
(c)
Controlled PM (BDM Engineering) 0.0096
(a)
VOC 0.0082
(a)
HAP 0.0076
(a) AP-42, 12/00, Section 11.1, Hot Mix Asphalt Plants, Tables 11.1-
1, 11.1-5, 11.1-6, and 11.1-9, Natural Gas-Fired Dryer
(b) Kramer and Associates, Source Test Performed 08/25/1993.
(c) Calculated using the AP-42 uncontrolled emission rate factor and
applying the manufacturer’s suggested control efficiencies for the
cyclone and the baghouse.
 3.2.5 Emissions Control Equipment

The Barber-Greene asphalt plant is equipped with a multiple cyclone and wet
scrubber Model Number CB-50, manufactured by Barber-Greene. This system of control
for particulate matter has been rated by the manufacturer as 93% efficient. The BDM
Engineering asphalt plant is equipped with a cyclone, Model Number 84M and a
baghouse, Model Number 18000M. The cyclone and baghouse are rated by the
Manufacturer, BDM Engineering, to have 70% and 99.9% efficiencies respectively.

3.2.6 Applicable Requirements

20.2.1l NMAC sets maximum particulate matter emission rates in pounds per
hour. In addition, the regulation requires the existence of a fugitive dust control system
such that all particulate emissions are limited to the stack outlet. The maximum asphalt
production rate of the Barber-Greene plant at TA-3-73 is 60 tons per hour (l20,000
pounds per hour). By interpolation, the limit from 20.2.1l NMAC is 33.8 pounds per hour
of particulate matter emitted from the stack. Based on a source test performed on August
25, l 993, provided in Appendix C, the particulate matter emission rate at maximum
capacity is 4 pounds per hour, well below the 33.8 pound per hour limit in 20.2.1l
NMAC. The BDM Engineering asphalt plant has a maximum production rate of 80 tons
per hour (160,000 pounds per hour). This production rate corresponds to a 35.4 pounds
per hour emission limit for particulate matter. Manufacturer’s data indicates that the
controlled hourly emissions are 1.44 pounds per hour. A source test will be performed to
demonstrate compliance. Table 3.2-3 summarizes the applicable requirements for asphalt
production. The proposed production limit of 13,000 tons per year listed in the table is a
combined limit for both asphalt plants.

Table 3.2-3. Applicable Requirements for Asphalt Plants

Source Applicable Requirement
Category
Barber-Greene Operating Requirements:
Asphalt Plant • Emission limit of 33.8 pounds per hour of particulate matter.
(20.2.11.107(A)(6)-(7) NMAC)
• The asphalt process equipment shall not operate without a fugitive dust
control system to limit particulate emissions to the stack outlet.
 Source Applicable Requirement
Category
(20.1.11.108 NMAC)
• Production shall not exceed 13,000 tons per year, 12-month rolling
average. (LANL proposed condition)
BDM Operating Requirements:
Engineering • Emission limit of 35.4 pounds per hour of particulate matter.
Asphalt Plant (20.2.11.107(A)(6)-(7) NMAC)
• Production shall not exceed 13,000 tons per year, 12-month rolling
average. (LANL proposed condition)
• Particulate matter (PM) emissions released to the atmosphere from the
baghouse, dryer, or mixer shall not exceed concentrations of 0.04
grains/dry standard cubic foot of particulate matter and shall not exhibit
20 percent opacity or greater. (40 CFR §60.92 and GCP-3-2195G
III.H.1)
• The asphalt process equipment shall not operate without a fugitive dust
control system to limit particulate emissions to the stack outlet.
(20.1.11.108 NMAC and GCP-3-2195G III.H.2)
• Official six (6) minute opacity readings must be performed monthly.
(GCP-3-2195G IV.C.1)
• The baghouse must be equipped with a device to continuously monitor
differential pressure across the baghouse. (GCP-3-2195G III.H.2.a.)
• Equip and operate all screens, conveyor belts, and transfer points with
dust collection and control systems sufficient to prevent opacity from
exceeding 20%. (GCP-3-2195G III.H.3.)
• Total sulfur content shall be no more than 0.75 percent by volume for
any natural gas used. (GCP-3-2195G III.C.3.c.)
• Total sulfur content shall be no greater than 0.5 percent by weight for
any propane used. (GCP-3-2195G III.C.3.a.)
• Hours of operation are limited to one-half hour following sunrise, one-
half hour before sunset, and those hours in between. (GCP-3-2195G
III.G.)
• Hours of operation are limited to 4,380 hours per year. (GCP-3-2195G
III.G.)
• Haul roads must be watered. (GCP-3-2195G III.I.)

3.2.7 Proposed Monitoring, Recordkeeping, and Reporting

Recordkeeping and reporting requirements are presented in the following table.

Required recordkeeping and reporting are followed with a citation for the basis of the
requirement.
 Table 3.2-4. Proposed Monitoring, Recordkeeping, and Reporting for Asphalt
Plants
Source Monitoring, Recordkeeping, and Reporting
Category
Barber-Greene Monitoring/Recordkeeping:
Asphalt Plant • Records will be maintained to document compliance with the proposed
production limit of 13,000 ton/year. (LANL proposed condition)
Reporting:
• Report criteria pollutant and HAP emissions on a semiannual basis.
(20.2.73.300 NMAC for criteria pollutants and LANL proposed
condition for HAPs and semiannual basis)
• Submit semiannual report of any required monitoring within 45 days
from the end of each reporting period. The reporting periods are January
to June and July to December. (20.2.70.302(E)(1) NMAC)
 Source Monitoring, Recordkeeping, and Reporting
Category
BDM Monitoring:
Engineering • Perform monthly six (6) minute opacity readings for each emission point
Asphalt Plant having opacity greater than zero. (GCP-3-2195G IV.C.1)
• Monitor the differential pressure (inches of water) across the baghouse
by the use of a differential pressure gauge. (GCP-3-2195G IV.C.2)
• A compliance test for particulate matter and opacity must be conducted
within 60 days of initial startup. (GCP-3-2195G IV.E.1, .3)
Recordkeeping:
• Keep records of actual hours of operation, production rates, number of
haul truck trips daily, pressure drop across the baghouse, fuel sulfur
content, tickets of fuel purchased, quantity and frequency of water
applied to haul roads, frequency of haul road sweeping, and copies of
proposed and performed maintenance. (GCP-3-2195G IV.D.2)
• Keep compliance test results for particulate matter and opacity performed
within 60 days of initial startup. (GCP-3-2195G IV.E.1, .3)
• Maintain results of the monthly six (6) minute opacity readings. (GCP-3-
2195G IV.C.1)
• Maintain records of the monitoring of the differential pressure across the
baghouse. (GCP-3-2195G IV.C.2)
• Retain records for 2 years. (GCP-3-2195G IV.D.1)
Reporting:
• Notify the Air Quality Bureau of the actual date of initial startup of the
asphalt plant within 15 days after the startup date. (GCP-3-2195G
IV.A.1.d)
• Schedule with the Air Quality Bureau a pre-test meeting at least 30 days
prior to the compliance test. (GCP-3-2195G IV.E.5)
• Submit to NMED the compliance test protocol at least one week prior to
the anticipated pre-test meeting date. (GCP-3-2195G IV.E.5.a)
• If a malfunction results in excess emissions, notify the Air Quality
Bureau within 24 hours and submit written report within 10 days. (GCP-
3-2195G III.B.2, GCP-3-2195G IV.A.2 and 20.2.7.110 NMAC)
• Submit copy of the compliance test results to NMED within 30 days after
completing the compliance test. (GCP-3-2195G IV.E.9)
• Report criteria pollutant and HAP emissions on a semiannual basis.
(20.2.73.300 NMAC for criteria pollutants and LANL proposed
condition for HAPs and semiannual basis)
• Submit semiannual report of any required monitoring within 45 days
from the end of each reporting period. The reporting periods are January
to June and July to December. (20.2.70.302(E)(1) NMAC)