Document XRMyQy3wyMamrK4RkEBkra3qw

Region 2 Caribbean Environmental Protection Division Multimedia Permits and Compliance Branch Air Protection Team CAA Inspection Report Inspection Date(s): July 17-20, 2023 Facility Names: PR Asphalt Barranquitas; PR Asphalt Caguas; PR Asphalt Carolina; PR Asphalt Humacao; and PR Asphalt Salinas Facility Addresses: PR-152 Km 1.0, Barrio Quebrada Grande, Barranquitas, PR 00794 PR 152, km 56.9, Bo. Caabn Caguas, PR 00727 PR-887 km 0.6, Bo. San Martn, Carolina, PR 00987 PR-198 KM 26.6, Barrio Cotto Mab, Humacao, PR 00791 PR-1 KM 83.4, Sector Sabana Llana, Salinas, PR 00751 EPA Lead Inspector: Alex Rivera, Environmental Engineer, 787-977-5845, rivera.alex@epa.gov EPA Asst. Inspector(s): Gloria Daz-Galarza, Environmental Engineer, 787-977-5882 diaz-galarza.gloria@epa.gov Bryan Lange, ERG Inspector, 919-622-2374, Bryan.Lange@erg.com Facility Contact: Jorge A. Daz Mayoral, Responsible Officer, 787-710-2525, jadiaz@prasphalt.com Jesus C. Acosta, Corporate Manager, 787-636-1249, jacosta@prasphalt.com Loyda De Jess, Compliance Resource Inc. Pedro Rosa, Carolina Manager Harry Melndez, Humacao Plant Manager Wadellys Lozada, Humacao Plant Operator Ramiro Perdomo, PR Asphalt Maintenance Supervisor Luis Ortiz, Salinas Manager This report documents Clean Air Act ("CAA") compliance inspections performed by the United States Environmental Protection Agency ("EPA") at five facilities owned and operated by Puerto Rico Asphalt, LLC ("PRA"). The five facilities are located in Barranquitas, Caguas, Carolina, Humacao, and Salinas. Alex Rivera, EPA, led the inspection assisted by EPA's Gloria Daz-Galarza Page 1 of 8 and contractor personnel, Bryan Lange, from Eastern Research Group, Inc. ("ERG"). The purpose was to identify potential compliance concerns with CAA regulations. Permitted Regulatory Program(s) and Other Information Reviewed: 1. Puerto Rico Regulations for Control of Atmospheric Pollution (RCAP) 2. General Provisions - 40 CFR Part 60 Subpart I 3. Records received in response to EPA 2023 CAA Section 114 Information Request Letters1 4. Facility Operating Permit Compliance This report is a summary of observations and information gathered from the facilities at the time of the inspections. The information provided does not constitute a final decision on compliance with CAA regulations or applicable permits, nor is it meant to be a comprehensive summary of all activities and processes conducted at the facilities. 1. Inspection Summary Opening Meeting The inspectors (i.e., Alex Rivera, Gloria Daz-Galarza, Bryan Lange) arrived at each facility on consecutive mornings starting on July 17, 2023, and continuing through July 20, 2023 (shown in Table 1 below). On the first day the inspectors were received by the corporate manager Mr. Jess C. Acosta, Ms. Loyda De Jess and Mr. Pedro Rosa at the PRA facility in Carolina. Mr. Acosta and Mr. Rosa also accompanied the inspectors at the Caguas and Barranquitas facilities. At each facility inspectors observed hot mix asphalt production, as well as trucks exiting with hot mix. Daily production and visible emissions observations were recorded and shown in Table 1 below. Table 1: Conditions on Arrival PR Asphalt Date; Arrival and Daily Production Total Visible Emission Facilities Departure Time (Type Produced) * observations in Baghouse or Silo Exhaust (Background) Carolina July 17, 2023. Monday 9:45 am - 11:45 am 741 tons (5V and S-75) No visible emissions from either source. Salinas July 19, 2023. Wednesday 450 tons or 18 trucks 10:00 am - 11:15 am (5V) No visible emissions from either source. Caguas July 18, 2023. Tuesday 8:55 am - 10:45 am 292 tons (S1) No visible emissions from either source. Barranquitas July 20, 2023. Thursday 10:30 am - 11:15 am 400 tons (5V) No visible emissions from either source. July 18, 2023. Tuesday 548 tons Poor background Humacao 12:45 am - 2:00 pm (5V) conditions for visible emission observation; cloudy. * Production details were provided by facility specific control room operators. The 5V type is commonly purchased by municipalities. S-75 is used as a base layer. 1 Diaz, Jorge A. Response to Request for Information Reference Number: CAA-02-20231415 Puerto Rico Asphalt. July 21, 2023, and June 26, 2023. Page 2 of 8 At the Carolina facility, Mr. Acosta briefly explained the shared history of the PRA Facilities. According to Mr. Acosta, prior to 2016 Betteroads and Betterecycling previously owned all five (5) Facilities. Mr. Acosta added that in 2016, due to bankruptcy the lender Banco Popular took ownership of the Facilities. After some time, PRA began renting and operating the Facilities from the bank. In 2021, PRA purchased the Facilities. Mr. Acosta also informed that Eng. Rosario Jimnez, an environmental consultant (Compliance Resource Inc.) was then contracted to support PRA with their compliance requirements. Mr. Acosta explained the various challenges related to the CAA Section 114 request for information letter ("114 RFI") issued by EPA on April 4, 2023. Among these challenges, Mr. Acosta mentioned that records were lost when ownership changed and that many permit records were lost in 2017 due to Hurricanes Mara subsequent high humidity conditions. ERG took photos at each of the inspected PRA Facilities. Attachment 1 contains a digital photo log for each Facility, including the description of each photo, its details, and any applicable comments. Daily Operations: The following is a summary of the PRA Facilities operations based on PRA representative's general overview. Hot mix processing begins as the aggregate (i.e., virgin aggregate, reclaimed asphalt pavement [RAP]2) is transported using a front-end loader from storage piles and placed in appropriate hoppers of the cold feed unit. Materials are metered from the hoppers onto a conveyer belt and are transported into a rotary dryer. All PRA Facilities have a single dryer that is heated with PREPA fuel (mixture of 50% used fuel oil and 50% diesel). Dryers are equipped with flights designed to shower the aggregate inside the drum to promote drying efficiency. The mixture is discharged at the end of the drum and is conveyed to storage silos, where it is dropped into transport trucks. Burner exhaust gases exit the end of the drum and pass to particulate matter (PM) collection systems. x Three (3) PRA Facilities (i.e., Salinas, Carolina, Humacao) operate a counterflow drum mixer. The material flow in the drum is opposite or counterflow to the direction of exhaust gases. The liquid asphalt mixing zone is behind the burner flame zone. Liquid asphalt flow is linked to the virgin aggregate and RAP weigh scales. It is injected into the mixing zone along with any RAP and PM from cyclone and baghouse.3 Mr. Acosta indicated that counterflow mixers are more fuel efficient. x The other PRA Facilities (i.e., Barranquitas, Caguas) operate a parallel drum mixer. Aggregate is introduced to the drum at the burner end. As the drum rotates, the 2 In the reclamation process, old asphalt pavement is removed from the road base. PR Asphalt has a single location for RAP collection and crushing in Carolina. Crushing creates a homogeneous material. The RAP collection Facility was not visited. 3 Pedro Rosa shared a YouTube video to help the Inspectors visualize the counterflow process. https://www.youtube.com/watch?v=v6PrPTpXKDY. Note, not all PR Asphalt mixers are currently insulated. Page 3 of 8 aggregates move toward the other end of the drum in parallel. Liquid asphalt cement is introduced in the mixing zone midway down the drum in a lower temperature zone, along with any RAP and PM from collectors. There were unique production and ownership observations at two (2) Facilities: x The Salinas Facility mixer system was unique in that it had two (2) drums. One (1) to counterflow drum to dry the aggregate, the second is where the RAP and liquid asphalt are added and mixed. x The Humacao Facility drum mixer was leaking aggregate from two (2) different locations. On Thursday (July 20, 2023), Mr. Acosta was asked about these leaks and explained that repair parts had been ordered. x The Humacao Facility is partially owned by Harry Auto Kool, Inc. According to PRA representatives, one goal of the plant managers and operators is to match production and distribution sales. At the end of the day, all silos are inspected to confirm they are empty. Unused material is piled on-property and recycled. Diesel fuel is stored and distributed to outbound trucks loaded with hot mix and onsite equipment (e.g., front-end loader). Table 2: Storage Capacities Operational Silo PREPA Fuel Diesel Fuel Liquid Asphalt (gallons) (tons) (gallons) (gallons) Carolina 3 x 175 ton * * 1 x 20,000 gallon 1 x 30,000 gallon Salinas 1 x 100 ton** 1 x 10,000 gallon 2 x 2,000 gallon 1 x 24,000 gallon 1 x 14,000 gallon Caguas 2 x 150 ton 2 x 8,000 gallon 2 x 2,000 gallon 1 x 30,000 gallon 1 x 8,000 gallon Barranquitas 2 x 110 ton 2 x 8,000 gallon 1 x 4,000 gallon 1 x 20,000 gallon Humacao 2 x 100 ton 2 x 8,000 gallon 1 x 1,000 gallon 1 x 20,000 gallon * This information was not collected by the inspectors. ** The facility has a second 100-ton silo which was inoperable during the inspection. Liquid Asphalt All PRA Facilities tanks were maintained at approximately 300F to maintain a low viscosity. The sulfur content of the fuel oil was not confirmed during the inspection because these records have been shared as part of the 114-RFI. Each Facility received liquid asphalt via tanker truck. PRA owns a liquid asphalt marine terminal in Guayanilla, PR. Atop each storage tank is a CECO mist elimination filter (Model Number: TVF-40). Each filter system is equipped with a pressure drop sensor. Mr. Acosta was not able to characterize the performance of the filter or the contents of the filter containers. Specifically, he did not know if they contained activated carbon. The inspectors stated that activated carbon would require occasional testing for breakthrough (i.e., volatile organic compounds) to achieve proper pollution capture, further pressure drop may not be an accurate indicator of performance. On Tuesday, Page 4 of 8 July 18, 2023, in between inspections, Mr. Lange spoke to a CECO manufacturer representative who characterized performance expectations and shared a factsheet of the equipment. Above ground pipes transport liquid asphalt to the drum mixer. Periodically, to prevent clogging, liquid asphalt is pumped backwards. There is a capture reservoir but judging from the small amount of cooked liquid asphalt on the side of the tank, there is occasional spillage. x At the Carolina Facility, the inspectors observed a 9,000-gallon tanker truck delivery. The inspectors observed the connection and beginning of transfer. Staff indicated that the transfer process requires a two-person crew to open valves and guard against overflow; the process takes approximately 30 minutes. As the tanks filled a low volume of head space was displaced and the tank emissions were visible. x At the Humacao Facility, mist was visible exiting the top of the CECO filter. The pressure gauge was cloudy and was not legible due to an opaque film. Table 3: Liquid Asphalt heating and Mist Elimination Carolina Salinas Caguas Barranquitas Humacao CECO Filter Pressure drop (inches of water) 0; Full of water 0; 0.8 0 0 Not legible. Pressure Gage, Next Calibration Not legible. Both - Oct. 2023 Not legible. Not legible. Not legible. Particulate Control PRA Facilities used a water truck to reduce road and parking lot fugitives. Fugitives from aggregate storage piles and front loader activity was managed with sprinklers. Sprinkler heads were approximately 10 feet high. These sprinklers also increase the material moisture. The conditions of the raw materials are measured before production begins. There is automation with the addition of ingredients. High moisture in the raw materials (e.g., gravel, sand) can affect weight and must be accounted for. Each Facility had procedures in place to maintain baghouse performance. Specific maintenance activities include frequent pulses (which will breakup filter cake), measuring baghouse pressure drop, and periodic inspections. At the Carolina facility, Mr. Rosa showed the inspectors a photo of a failed/ripped filter bag that was encountered at the last inspection. The Humacao Facility baghouse pressure drop gage read zero inches of water. On Thursday (July 20, 2023) Mr. Acosta was asked about this issue; he indicated this could be the result of a clog in the pressure line and stated that a repair would be initiated. Page 5 of 8 Table 4: Particulate Control Devices Cyclone Present Carolina No Salinas Yes Caguas No Barranquitas No Humacao Yes Baghouse Pressure Drop (inches of water) 1.3 3.4 3.5 3.2 0.2 Pressure Gage, Next Calibration Not legible Oct. 2023 Oct. 2023 Oct. 2023 2023 (Difficult to read month) Power Generation Four (4) of the five (5) PRA Facilities had a generator onsite. The Salinas Facility used LUMA (Puerto Rico power grid operator) 120 volts (V) electricity to power the administrative building. The laboratory required 480 V produced by an onsite generator to power production equipment (e.g., mixer, baghouse fans). The situation at the Barranquitas Facility is similar. According to the Facility representatives, the voltage provided by the power grid operated by LUMA is insufficient to start up the production equipment. The onsite generator is used each day of operation to begin production. PRA Caguas Plant had a 534 horsepower (HP) emergency generator onsite, but it was not connected to any equipment. The inspectors could not read the hours of operation because the display was electronic. Table 5: Generator Details Carolina Salinas Caguas Barranquitas Humacao Generator Status Emergency generator Manufacture; Size Detroit Diesel; 1000 HP Used during production Cyclonetic; 1000 HP Disconnected Used at each startup No generator onsite. Caterpillar; 534 HP Caterpillar; 546 HP - Operating Hours 4,138-hours Not able to read. Noisy and hearing protection unavailable. Digital display disconnected. 14,455-hours - Areas of Concern 1. Production information provided in 114 RFI responses: There were some notable occurrences in the production information and operating hours of the facilities submitted by PRA in response to the 114 RFI. These were addressed by facility operators with the following responses: x Carolina - Mr. Acosta was asked about the Carolina Facility inconsistency with hours of operation and production trend. Specifically, production in 2022 increased by approximately 90,000 tons or a 50% increase. Mr. Acosta stated that no additional equipment or modifications had been made to increase production in 2022. Page 6 of 8 x Salinas - The Facility operated less than 200 hours in 2022. Mr. Ortiz confirmed that the facility capacity is underutilized, and explained that there are competitors in close proximity, and that production in 2023 has been higher. x Two Facilities (i.e., Barranquitas, Caguas) have restricted operations, weekdays from 6am to 6pm. Preventive maintenance, including an internal baghouse inspection, is scheduled for each Saturdays. 2. Missing Equipment The 2021 EPA inspection of Carolina was discussed and specific acknowledgment that the active air permit, issued in 2019, included a single liquid asphalt storage tank. Mr. Acosta indicated that DNER had still not been notified that the permit contained an incomplete list of emission units. The inspectors also observed four (4) military storage tanks store diesel fuel and have a max capacity of 36,000-gallons each. Mr. Acosta indicated that 2 were empty. The inspectors recommend that PRA catalogue all emission units located at each Facility and compare the list with active air permit. All discrepancies should be communicated to DNER. If equipment exists onsite that is operated or owned by a second party that should also be communicated. The inspectors also recommend that air permit renewal permit applications be submitted where active air permits are expired. Do not delay those applications until ownership changes are recognized. 3.Citizen Complaints Mr. Acosta indicated that the Carolina plant occasionally receives citizen complaints, but they are not logged. Mr. Acosta explained that odors can be attributed to liquid asphalt tank filling and indicated that liquid asphalt manufactured in Texas has a stronger odor. Mr. Acosta also indicated that neighbors have complained about fugitive dust accumulating on vehicles. Mr. Acosta indicated that the Barranquitas Facility became aware of a citizen complaint in a local newspaper article. He explained that complaints are often filed with the regulatory authority DNER. The inspectors recommended that citizen complaints should be catalogued. These records can document improvements in pollution control strategies and confirm perceptions like Mr. Acosta's comment that liquid asphalt received from Texas has stronger odors. Page 7 of 8 Inspection Report Sign-Off Lead Inspector's Name: Alex Rivera Rivera, Alex Digitally signed by Rivera, Alex Date: 2023.09.14 12:22:56 -04'00' Assisting Inspector's Name: Gloria Daz-Galarza GLORIA DIAZ- Digitally signed by GLORIA DIAZ-GALARZA GALARZA Date: 2023.09.14 15:21:35 -04'00' Additional Assisting Inspector's Name: Bryan Lange Digitally signed by Bryan Bryan Lange Lange Date: 2023.09.14 13:08:09 -04'00' Supervisor's Name: Nancy Rodrguez NANCY Digitally signed by NANCY RODRIGUEZ RODRIGUEZ Date: 2023.09.14 16:12:42 -04'00' Page 8 of 8 Carolina - PR Asphalt Date Description 7/17/2023 3 hot mix silos 7/17/2023 Baghouse exhaust with storage tank in background 7/17/2023 Liquid asphalt storage tank, product receiving area hose. 7/17/2023 Liquid asphalt storage tank, cooked product on the side of the tank. 7/17/2023 Front end loader adding raw materials to the production line. 7/17/2023 Product dropped onto silo conveyor. 7/17/2023 Side view of dryer. Visible is piping that conveys liquid asphalt into the dryer. 7/17/2023 Control room screen #1 showing operational details for the dryer burner and baghouse. 7/17/2023 Control room screen #2 showing moisture of virgin materials. 7/17/2023 Control room screen #3 showing the constituents in a batch, type S-75. 7/17/2023 Conveyor moving aggregate into the dryer. 7/17/2023 Conveyor moving aggregate into the dryer. Visible in the background is the water tanker used for fugitive dust control. 7/17/2023 Two liquid asphalt storage tanks. Visible are the CECO mist elimination filters. 7/17/2023 Baghouse pressure gage. 7/17/2023 Baghouse pressure gage control system. 7/17/2023 Mr. Rosa's phone showing a photograph of a failed bag documented by staff during the most recent inspection. 7/17/2023 Latex storage tank. 7/17/2023 Diesel generator, hours of operation. 7/17/2023 Diesel generator, hours of operation from a second angle. 7/17/2023 Diesel generator, name plate. 7/17/2023 Diesel generator. 7/17/2023 #1 CECO mist elimination filter pressure gauge. 7/17/2023 #1 CECO mist elimination filter name plate. 7/17/2023 View from top of liquid asphalt storage tank; visible is piping that conveys liquid asphalt into the dryer. 7/17/2023 #2 CECO mist elimination filter name plate. 7/17/2023 #2 CECO mist elimination filter pressure gauge. 7/17/2023 Liquid asphalt tanker truck on scale. 7/17/2023 Liquid asphalt paper receipt #1. 7/17/2023 Liquid asphalt paper receipt #2. 7/17/2023 Liquid asphalt storage tank, receiving product. 7/17/2023 Four shipping container diesel storage tank. 7/17/2023 Close up of one shipping container diesel storage tank. Photo # IMG-2520 IMG-2521 IMG-2523 IMG-2524 IMG-2526 IMG-2533 IMG-2534 Time 9:49 AM 9:52 AM 10:08 AM 10:09 AM 10:12 AM 10:14 AM 10:14 AM Comments Product entering one on the right; fugitive PM is visible. Poor conditions for a visible emissions observation. Periodically, to prevent clogging, liquid asphalt is pumped backwards. IMG-2536 10:17 AM IMG-2538 10:33 AM IMG-2539 10:37 AM IMG-2540 10:47 AM IMG-2541 10:47 AM IMG-2542 10:48 AM IMG-2543 10:50 AM IMG-2544 10:51 AM IMG-2545 10:52 AM IMG-2546 IMG-2547 IMG-2548 IMG-2549 IMG-2550 IMG-2551 IMG-2553 10:55 AM 10:56 AM 10:56 AM 10:56 AM 10:56 AM 10:59 AM 10:59 AM An uncommon hot mix ingredient. IMG-2554 11:00 AM IMG-2555 IMG-2556 IMG-2558 IMG-2559 IMG-2560 IMG-2561 11:01 AM 11:01 AM 11:02 AM 11:07 AM 11:07 AM 11:14 AM Mist visible. Exhaust bypasses the CECO mist elimination filter. IMG-2566 11:15 AM Unclear if these exist on the air permit. IMG-2567 11:17 AM Salinas - PR Asphalt Date Description 7/19/2023 2 hot mix silos 7/19/2023 Wide view of equipment including the PREPA storage tank, liquid asphalt storage tank, and control room. 7/19/2023 #1 CECO mist elimination filter pressure gauge and name plate. 7/19/2023 #2 CECO mist elimination filter pressure gauge and name plate. 7/19/2023 Wide view of equipment including the liquid asphalt storage tank, silo, and lab. 7/19/2023 Wide view of equipment including the cyclone prefilter, end of dryer, and final product conveyor to silo. 7/19/2023 Inside of retaining wall for the liquid asphalt and PREPA fuel storage tanks. 7/19/2023 Emergency generator name plate 7/19/2023 7/19/2023 7/19/2023 7/19/2023 7/19/2023 7/19/2023 7/19/2023 7/19/2023 7/19/2023 7/19/2023 7/19/2023 Boiler, maintains temperature in the liquid asphalt storage tanks. Gas-oil burner Gas-oil burner, hours of operation not legible. Dryer with cyclone prefilter. Two drum dryer; cyclone prefilter. Baghouse pressure gauge. Inside of retaining wall for fuel storage tanks. Wide view of equipment including the cyclone prefilter, baghouse, two drum dryer, and fuel storage tank. Baghouse pressure gauge; second angle. Baghouse pressure gauge. Wide view of equipment including the cyclone prefilter and dryer. Photo # IMG-2643 IMG-2644 IMG-2645 IMG-2646 IMG-2647 IMG-2648 IMG-2649 IMG-2650 IMG-2651 IMG-2652 IMG-2653 IMG-2654 IMG-2655 IMG-2656 IMG-2657 IMG-2658 IMG-2659 - IMG-2661 Movie # - - - - - - - - IMG-2660 - Time 10:13 AM 10:14 AM 10:15 AM 10:16 AM 10:16 AM 10:16 AM 10:18 AM 10:20 AM 10:21 AM 10:22 AM 10:22 AM 10:25 AM 10:27 AM 10:29 AM 10:30 AM 10:33 AM 10:35 AM 10:35 AM 10:47 AM Comments To loud to record hours of operation. Not equipped with hearing protection. Error with file. Caguas - PR Asphalt Date Description 7/18/2023 Virgin raw material conveyor. 7/18/2023 Virgin raw material conveyor with baghouse and stack in the background. 7/18/2023 Conveyor transporting final hot mix product into one of two silos. 7/18/2023 Truck expecting a load of final hot mix product. Control room screen #1, baghouse parameters (i.e., pressure reading, damper position, 7/18/2023 inlet temp). Control room screen #2, production details including: dryer burner fuel flow, virgin 7/18/2023 aggregate and liquid asphalt throughput rates (tons/hr). 7/18/2023 Baghouse exhaust; no visible emissions. 7/18/2023 Dryer with burner visible. 7/18/2023 Virgin aggregate storage piles. Sprinklers visible to manage moisture and fugitive dust. Three liquid storage tanks. The color of the liquid asphalt tank is black and PREPA fuel is 7/18/2023 stored in two vertical white tanks. 7/18/2023 Baghouse and three liquid storage tanks. 7/18/2023 Baghouse pressure gauge. 7/18/2023 #1 CECO mist elimination filter pressure gage and name plate 7/18/2023 Liquid asphalt storage tank, cooked product on the side of the tank. 7/18/2023 Liquid asphalt storage tank, cooked product on the side of the tank. 7/18/2023 Liquid asphalt storage tank, cooked product on top of the tank. 7/18/2023 Horizontal diesel fuel liquid storage tank at edge of the property. 7/18/2023 Two horizontal PREPA fuel liquid storage tanks. 7/18/2023 Inside of retaining wall for the two horizontal PREPA fuel liquid storage tanks. Inside of retaining wall for the horizontal PREPA fuel liquid storage tank at edge of the 7/18/2023 property. 7/18/2023 Caterpillar generator name plate. 7/18/2023 Caterpillar generator name plate with serial number details. Caterpillar generator, digital operating hours display. Display is blank because the 7/18/2023 generator is not operating. 7/18/2023 Caterpillar generator, cords are disconnected. Photo # IMG-2570 IMG-2571 IMG-2572 IMG-2573 Time 8:56 AM 8:56 AM 8:56 AM 8:57 AM Comments IMG-2574 9:35 AM IMG-2575 9:35 AM IMG-2576 9:46 AM IMG-2577 9:46 AM IMG-2578 9:51 AM IMG-2579 9:51 AM IMG-2580 IMG-2581 IMG-2582 IMG-2583 IMG-2584 IMG-2585 IMG-2586 IMG-2587 IMG-2588 9:51 AM 9:52 AM 9:57 AM 10:08 AM 10:08 AM 10:08 AM 10:08 AM 10:09 AM 10:10 AM IMG-2589 10:17 AM IMG-2590 10:33 AM IMG-2591 10:33 AM IMG-2592 10:33 AM IMG-2593 10:34 AM Barranquitas - PR Asphalt Date Description 7/20/2023 Baghouse pressure gauge. 7/20/2023 Dryer exit and conveyor for final product. 7/20/2023 Dryer inlet with virgin materials conveyor. 7/20/2023 Liquid asphalt storage tank. 7/20/2023 Emergency generator name plate. 7/20/2023 Emergency generator name plate. 7/20/2023 Emergency generator, hours of operation. 7/20/2023 #1 CECO mist elimination filter pressure gauge and name plate. 7/20/2023 #1 CECO mist elimination filter. 7/20/2023 Liquid asphalt storage tank; overflow valve. 7/20/2023 Liquid asphalt storage tank; boiler exhausts here after heating asphalt. 7/20/2023 Liquid asphalt storage tank, product receiving area hose. Photo # IMG-2665 IMG-2666 IMG-2667 IMG-2668 IMG-2669 IMG-2670 IMG-2671 IMG-2672 IMG-2673 IMG-2674 IMG-2675 IMG-2676 Time 10:29 AM 10:30 AM 10:31 AM 10:36 AM 10:41 AM 10:41 AM 10:43 AM 10:46 AM 10:48 AM 10:49 AM 10:49 AM 10:51 AM Comments Humacao - PR Asphalt Date Description 7/18/2023 Form #1, documenting daily fuel consumption and hours of operation. 7/18/2023 Form #2, documenting visible emission, condition of filters. 7/18/2023 2 hot mix silos 7/18/2023 Liquid asphalt storage tank. Visible is the CECO mist elimination filter. 7/18/2023 Liquid asphalt delivery truck. 7/18/2023 Liquid asphalt delivery received into the storage tank. 7/18/2023 Inside of retaining wall for the liquid asphalt storage tank. 7/18/2023 CECO mist elimination filter name plate. 7/18/2023 CECO mist elimination filter pressure gauge. 7/18/2023 CECO mist elimination filter pressure gauge. 7/18/2023 Breathing emissions exiting the top of the liquid asphalt storage tank. 7/18/2023 Boiler, hours of operation. 7/18/2023 Boiler, paper documentation. 7/18/2023 Inside of retaining wall for the liquid asphalt storage tank. 7/18/2023 Liquid asphalt storage tank, cooked product on the side of the tank. 7/18/2023 Baghouse pressure gage. 7/18/2023 Baghouse pressure gage control system. 7/18/2023 Dryer and conveyor transporting final hot mix product into silos. 7/18/2023 An accumulation of raw material that had leaked from the dryer. 7/18/2023 Two vertical storage tanks containing PREPA fuel. 7/18/2023 Inside of retaining wall for the PREPA fuel storage tanks. 7/18/2023 Video of the shadow of emissions exiting the baghouse stack 7/18/2023 Baghouse stack. 7/18/2023 Raw material leaking from the dryer. 7/18/2023 Raw material leaking from the dryer. 7/18/2023 Truck after receiving a load of final hot mix product. 7/18/2023 Wide view of equipment including the baghouse, final product silos, and liquid asphalt storage tank. 7/18/2023 Mist emissions exiting the CECO filter. 7/18/2023 Wide view of equipment including the baghouse, final product silos, and liquid asphalt storage tank. 7/18/2023 Truck expecting a load of final hot mix product. In the background is the administrative and laboratory space. 7/18/2023 Ownership sign located on exterior of the administrative building. 7/18/2023 Equipment including the dryer, cyclone prefilter, and baghouse. 7/18/2023 Final product conveyor to the silos. 7/18/2023 Wide view of equipment including the baghouse, final product silos, and liquid asphalt storage tank. Photo # IMG-2594 IMG-2595 IMG-2596 IMG-2597 IMG-2598 IMG-2599 IMG-2600 IMG-2601 IMG-2602 IMG-2603 IMG-2605 IMG-2606 IMG-2607 IMG-2608 IMG-2609 IMG-2610 IMG-2611 IMG-2612 IMG-2613 IMG-2614 - IMG-2616 IMG-2617 IMG-2619 IMG-2620 - IMG-2622 IMG-2623 IMG-2624 IMG-2625 IMG-2626 IMG-2627 Movie # IMG-2604 - - IMG-2615 - IMG-2618 - - IMG-2621 - - - - Time Comments 12:47 PM 12:48 PM 1:06 PM 1:07 PM 1:08 PM 1:09 PM 1:10 PM 1:11 PM 1:11 PM Gauge is not legible. 1:11 PM Gauge is not legible. 1:11 PM 1:12 PM Paperwork was saturated and barely illegible. It was assumed that unfolding the paperwork 1:13 PM would further damage it. 1:14 PM 1:14 PM 1:16 PM 1:16 PM 1:17 PM 1:18 PM 1:20 PM 1:20 PM 1:23 PM Poor conditions for visible emission 1:24 PM observation. 1:24 PM 1:25 PM 1:26 PM 1:27 PM 1:27 PM Staff indicated the green cylindrical tank on the 1:28 PM far left was not operational. 1:29 PM 1:29 PM 1:33 PM 1:33 PM The approximate location of staff's routine 1:50 PM visible emission observations.