Document jgpJKV9E2ee329b66rLw3dKbN

Region 2 Caribbean Environmental Protection Division Multimedia Permits and Compliance Branch - Air Protection Team CAA Inspection Report Inspection Date: Facility Name: Facility Address: Coordinates: ICIS-Air ID #: NAICS code: Facility Contact(s): EPA Inspector: State Inspector(s): March 9, 2021 Betterecycling Corporation PR-887 Km. 0.4 Julio N. Matos Industrial Park, Carolina PR Latitude: 18.379349 Longitude: -65.968071 PR0000007203100237 324121 - Asphalt Paving Mixture and Block Manufacturing Jorge L. Diaz, President, Betterecycling Corp, jldiaz@emdi.net Eng. Jess Acosta, Operations Engineer, 787-636-1249, jacosta@prasphalt.com Eng. Mario Prez, Environmental Health and Safety Engineer, 787-451-5832, marioperezherrera.safety@gmail.com Alex O. Rivera, Environmental Engineer, (787) 977-5845 Nenie Negrn; PR Department of Natural and Environmental Resources Air Inspector Applicable Regulation: 40 CFR Part 60 Subpart I - Standards of Performance for Hot Mix Asphalt Facilities Regulated Pollutant: Particulate Matter Page 1 of 7 I. Facility Background Information Betterecycling Corporation operates a hot mix asphalt plant facility located in PR-887, Km. 0.4, Martn Gonzlez Ward, Julio N. Matos Industrial Park, Carolina, Puerto Rico ("Facility"). Figure 1 provides an aerial view of the Facility location and other relevant information about the inspection. Silos Baghouse Stack Method 9 Observation Location Figure 1 - Aerial view of the area where Betterecycling Corp. Carolina Plant is located obtained from Google Earth Pro Page 2 of 7 II. Regulatory Background The Facility is subject to 40 CFR Part 60 Subpart I - Standards of Performance for Hot Mix Asphalt Facilities ("NSPS Subpart I"). 40 CFR 60.91 defines a hot mix asphalt facility as any facility used for manufacturing hot mix asphalt by heating and drying aggregate and mixing with asphalt cements. Pursuant to the provisions of the Department of Natural and Environmental Resources ("DNER") formerly known as Environmental Quality Board Regulations for the Control of Atmospheric Pollution and the provisions of the 40 CFR Part 60 Subpart I; the Facility is authorized to operate a stationary source of air pollutant emissions limited to the units and conditions described in DNER issued operating permit PFE-16-0613-0296-I-II-O ("Permit"), issued on July 31, 2019. The Permit expires on July 31, 2024. III. Inspection Purpose An unannounced inspection was conducted to assess the facility's compliance with NSPS Subpart I; DNER's Regulations for the Control of Atmospheric Pollution (RCAP); and overall compliance with the Facility's Permit. IV. Inspection Summary Inspector's Rivera arrived at the area where the Facility is located at approximately 5:45 AM. At the time of arrival, Inspector Rivera was able to observe trucks mobilizing in and out of the Facility. Emissions from the Facility stack and top of silos were noticeable. Inspector Rivera drove to a parking lot east of the Facility best suitable to conduct a Method 9 visible emission observation. The Inspector conducted a Method 9 reading from 6:42 AM to 7:12 AM, gray background was predominant during the observation. The highest 6 min average during the observation was 22 %. The Inspector conducted a second Method 9 reading from 7:22 AM to 7:42 AM, a light blue background was predominant during the observation. The highest 6 min average during the observation was 24 %. Both observations were conducted at the following coordinates: Latitude: 18.379328o / Longitude: -65.967409o. The Method 9 visible emissions observation forms and Inspector Rivera Method 9 observer certification can be found in Attachment 1 of this Report. DNER air inspector Nenie Negrn arrived at approximately 7:45 AM and met with Inspector Rivera at the location where the Method 9 readings were conducted. Inspector Rivera informed Inspector Negron about the Method 9 readings performed and agreed to access the Facility. Inspector Rivera and Inspector Negron accessed the Facility at 7:55 AM and were received by Engineer Mario Prez, Environmental Health and Safety Coordinator and Jos Coln, Plant Manager. Inspector Rivera informed the Facility operator about the purpose of the visit and showed the enforcement officer credentials. Inspector Rivera also informed the Facility representatives about the Method 9 observations conducted earlier in the morning. Eng. Prez and Mr. Coln agreed on providing a tour of the Facility. Inspector Rivera used a copy of the Facility Permit to verify the operational status of each of the Facility emission units included in the Permit. The following is a summary of the Facility walkthrough: a. According to the Permit the Facility has one 30,000 gallons tank for liquid asphalt storage (hot mix). The Facility representatives showed the 30,000 gallons storage tank used for hot mix liquid asphalt storage and an additional 20,000 gallons tank located next to the hot mix liquid asphalt tank, used for warm mix liquid asphalt storage. The 20,000 gallons tank is not included in the Permit. Page 3 of 7 b. The Facility Permit indicates that the Facility operates three (3) asphalt storage silos. The Facility representatives showed the location of the three (3) silos, confirmed that the Facility does not have any additional silos and stated that each silo has a capacity to store 175 tons of asphalt. c. The Facility representatives confirmed that the Facility operates seven (7) hoppers and four (4) transport belts used for the regular asphalt operations and one (1) additional hopper plus three (3) transport belts for the reclaimed asphalt pavement ("RAP") process operations. The Permit allows the Facility to operate eight (8) hopper and seven (7) belts. d. The Facility representatives showed and confirmed the location of the Facility drum mixer and baghouse described in the Permit. The Permit limits the production of asphalt to a maximum of 400,000 tons per year. e. The Facility has one (1) emergency power engine that is not currently in the Permit. According to the Facility representatives, the engine was installed as a result of Hurricane Maria but has not been used since the Facility started getting power from the Puerto Rico Electric and Power Authority. The engine was manufactured by Detroit Diesel, model number 71637305. f. The inspectors were escorted by the Facility representatives to the liquid asphalt tanks area to verify the operational status of the tanks' gases control filter and pressure meters. Both pressure meters were found out of operation and showing a reading of zero inches of water. Mr. Ramiro Perdomo (Maintenance Coordinator) stated that both meters were in operation until recently. The calibration seal was unreadable for both meters. g. The inspectors were escorted by the Facility representatives to the baghouse to verify the unit backpressure meter. The inspectors confirmed that the baghouse back-pressure meter was in operation and according to the calibration seal, the meter was calibrated on November 6, 2020. Inspector Rivera asked the Facility representatives about the most recent maintenance activity conducted to the baghouse. Mr. Perdomo indicated that around a year ago the unit was taken out of service for maintenance. h. Inspector Rivera asked the Facility representatives about the silos operation and maintenance. Mr. Perdomo indicated that the silos pressure valves and gates are inspected in a daily basis and once per year for structural integrity. Inspector Rivera asked if the inspections are documented. Mr. Perdomo stated that he conducted the most recent integrity inspection on January 2021, but the inspections are not being documented. Inspector Rivera recommended Mr. Perdomo to document every maintenance or inspection activity in a standard form or a logbook. i. Inspector Rivera asked the Facility representatives about the operations being conducted in the property. The Facility representatives stated that two (2) additional companies operate within the property. Petroleum Emulsion Manufacturing Company (PEMCO) produces the emulsion or primer that is applied to the surface prior to the asphalt; and the other operator is Ruben Martinez Oil Collection System, that collects and recycles used oil. Betterecycling Corp. buys Ruben Martinez's the oil used in the drum mixer (50% used oil / 50 % kerosene). j. The Facility owner is Betterecycling Corp. and is operated by Puerto Rico Asphalt. Puerto Rico Asphalt owner is Jorge Arturo Diaz. The owner of Betterecycling Corp. is Jorge Luis Diaz. Jesus Acosta is Puerto Rico Asphalt's Operations Director. Page 4 of 7 k. According to Mr. Coln, the Facility operation hours are from 7 AM to 4 PM, but can operate at earlier times depending on the clients needs. The Facility has six (6) employees. l. Inspector Rivera asked about the water spraying capabilities of the Facility. Eng. Prez indicated that the Facility has six (6) water spraying points in the aggregate materials piling area. Eng. Prez added that the Facility also has a 2,000 gallons water truck that is unavailable because is at the mechanic shop. m. The inspectors were escorted to the Facility control room. The Facility operator stated that the Facility ceased operations for the day at 9:05 AM and processed 516 tons of asphalt and used 1,131 gallons of fuel. The Facility operator showed the inspectors that the baghouse back pressure meter, which showed a measurement of 0.25 inches of water. According to the operator, the baghouse back-pressure should not exceed 0.5 inches of water, any pressure over such measurement indicates operational issues with the baghouse unit. The Facility control room has a computer to monitor the drum mixer and baghouse units. The Facility operator stated that Puerto Rico Asphalt has been operating the Facility since 2018 and that its asphalt production has increased since 2020. The operator also informed that the baghouse is inspected in a monthly basis and that an inspection and maintenance for is used by operators to document the Facility daily and monthly inspection and maintenance activities. The operator showed the inspectors the form that is used to document the Facility daily production registry in a daily basis. The inspectors concluded the Facility walkthrough and agreed to meet with the Facility representatives at Betterecycling Corp. conference room to complete the documentation review aspect of the inspection. Puerto Rico Asphalt owner Jorge Arturo Diaz; Betterecycling/PEMCO owner Jorge Luis Diaz; and Eng. Jess Acosta joined the inspection and the inspectors informed them about the purpose of the inspection. The inspectors asked the Facility representatives to show and provide copies of documentation for review to evaluate compliance with the Permit requirements. The following is a summary of the discussions held during the review: a. Eng. Prez provided a copy of the monthly fuel consumption reports files corresponding to the month of February 2021 dated March 3, 2021. b. Inspector Rivera informed the Facility representatives about the Method 9 visible emissions observations conducted early in the morning that confirmed that the Facility baghouse emissions were over the 20% opacity (6-minute average). c. Inspector Rivera asked the Facility representatives about the performance tests required by the Permit and the NSPS Subpart I. The Facility representatives confirmed that such tests have not been performed at the Facility and informed that Betterecycling Corp. recently conducted the tests at one of their plants located in the Municipality of Caguas. Inspector Rivera showed the Facility representatives where such tests are requested in the Permit and the NSPS Subpart I which testing methods are required. d. The Facility representatives informed that Betterecycling Corp. also owns asphalt plants in the municipalities of Salinas and Barranquitas. e. Inspector Rivera asked the Facility representatives about the Method 9 test required to be conducted at the RAP crusher unit and showed that such requirement is included in paragraphs 71 and 72 of the Permit. The Facility representatives confirmed that such test has not been conducted. Page 5 of 7 f. Eng. Prez showed copies of the calibration forms of the asphalt tanks pressure meters which according to the forms were calibrated in November 2020. g. Eng. Prez showed a copy of the baghouse filter inspection form from the month of January 2021. The form does not have the name of the person who completed the inspection nor any comments about the findings and activities performed. The form identified the filters that were replaced as a result of the inspection. h. Inspector Negrn asked the Facility to provide copies of the RAP material processed daily registry required in paragraph 68 of the Permit. Engs. Acosta and Prez confirmed that such registry is not being documented. i. Inspector Rivera informed Engs. Acosta and Prez that according to Mr. Perdomo the silos are being inspected in an annual basis as required by paragraph 80 of the Permit, but such inspections are not being documented in a registry as requested by paragraph 81 of the Permit. j. Mr. Jorge Luis Diaz contacted the consultant that conducted the tests in Betterecycling Corp. Caguas Plant to verify his availability to conduct the tests at the Facility. The consultant confirmed his availability to assist the Facility with the project. Mr. Jorge Luis Diaz also requested the consultant to conduct the same tests at Betterecycling Barranquitas and Salinas facilities. k. Eng. Acosta confirmed that he ordered the operators to cool down the baghouse to inspect the unit filters and verify if there are filters to be replaced. Eng. Acosta and Mr. Jorge Luis Diaz confirmed that the Facility will conduct a more detailed inspection of the unit during the weekend and will inform the inspectors about the findings and actions to be taken. V. Closing Meeting The inspectors concluded the documentation review part of the inspection and proceeded with the closing meeting on which the Facility was represented by Mr. Jorge L. Diaz and Engs. Prez and Acosta. The following is a summary of the action items discussed during the closing meeting: a. Method 9 and 5 tests requested in paragraph 40 of the Permit. b. Operational status of the asphalt storage tanks differential pressure meters. c. Baghouse filter inspection forms improvement. d. Method 9 test at RAP crusher and monthly registry of RAP material processed. e. Silos annual inspections registry. f. Jorge L. Diaz confirmed the inspectors that the company already approved the hiring of a second employee to assist with the Facility Environmental Health and Safety Department. The inspectors expressed gratitude to the Facility representative for the assistance during the inspection and concluded the inspection at 12:05 PM. The inspectors left the Facility at 12:15 PM. Page 6 of 7 Inspection Plan Sign-off Inspector's Name: Alex O. Rivera ALEX RIVERA Digitally signed by ALEX RIVERA Date: 2021.03.23 10:27:41 -04'00' Supervisor's Name: Nancy Rodrguez NANCY Digitally signed by NANCY RODRIGUEZ RODRIGUEZ Date: 2021.03.23 11:47:41 -04'00' Page 7 of 7 Attachment 1 VISIBLE EMISSIONS EVALUATOR Alex Rivera This is to certify that the above named observer has met the specifications of Federal Reference Method 9 and is qualified as a visible emissions evaluator. Maximum deviation on white and black smoke did not exceed 7.5% opacity and no single error exceeding 15% opacity was incurred during the certification test conducted by Eastern Technical Associates, Inc. of Raleigh, N.C. This certificate is valid for six months from date of issue. 473874 Certificate # 1/27/2021 Date of Certification 7/29/2021 Certification Expiration Date RIV215215 Student ID Number San Juan, PR Location 1/10/2017 Last Lecture Jody Monk General Manager