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HomeMy WebLinkAbout6.0 Correspondence & Supplemental Information ResearchMe02/23,'2012 14:55 FAX 9706258247 ■ . ..0 .. RIFLE EQUIPMENT 2/23/12 To: Garfield County Commissioners Re: Asphalt Plant —Bedrock Resources 001 t) ( P10L C 1 have read about the concerns of the nearby organic farm, but has anyone considered the excessive truck traffic that will be created by having a plant away from its aggregate source? If they are going to buy their aggregate from either Silt Sand & Gravel or Flag Sand & Gravel for every truck load of asphalt hauled out, there will be more than one load of material going in to make every load of asphalt. County road 346 with the two sharp corners and as narrow as it is can, not handle that kind of truck traffic and I would sure hate to live along that route if that was allowed. If they plan on hauling it out of Lafarge or Grants pit on the north side of the interstate that's still going to create a lot more truck traffic up the lower part of Mamm Creek Co Rd 315. Putting an asphalt plant outside of an existing gravel pit is not very practical and should be looked at for more than just the farms concerns. Harry Harry f I-)6avy Haulers Glenn Hartmann Ftwig L+JA ') From: Eric McCafferty [eric@a compassmountain.net] Sent: Wednesday, February 22, 2012 4:56 PM To: Glenn Hartmann Subject: File MIPA 7030 - Asphalt Batch Plant Hello Glenn — Will you please include the following letter to the BOCC in your next round of staff comments in this matter? Please contact me with any questions or comments. Thank you — Eric McCafferty 970.618.0837 Gentlemen -- I have been reviewing the question of whether to approve the Asphalt Batch Plant proposed for a location off of County Road 315, east of the Garfield County Airport and adjacent to an operating, organic farm. I have no affiliation with either side and offer these comments only as an interested citizen. It seems to me that perhaps the best way to evaluate whether to approve the proposed use would be to consider a cost - benefit analysis. Garfield County is attempting to amend its land use regulations to allow and encourage economic development and a more -streamlined land use review process. Efforts, that I support and encourage. I have reviewed the staff reports, supporting documentation and much of the public testimony. I find no information relative to an analysis of the costs and benefits associated with approving one land use over the possibility of damaging an existing land use. There has been substantial testimony relative to this matter, but no quantitative analysis, so far as I can tell. The decision before the Board of County Commissioners (BOCC) is not an easy one. The BOCC has been attempting to encourage economic development yet, in this instance, may render a decision that could negatively affect the overall economics of the County. I realize the existing land use regulations do not create a direct tie to this possible consideration. However, a cost benefit analysis that considers the costs and benefits of the two competing land uses would be a valuable tool in making the final decision. Ultimately, I believe that the BOCC will be faced with exactly this type of economic question as it moves forward with economic development initiatives and how these initiatives may conflict with future land use proposals. Very Truly Yours, Eric D. McCafferty Compass Mountain Land Use, LLC Glenwood Springs 970.518.0837 1 STATE OF COLORADO John W Hickenlooper, Governor Christopher E. urtaina, MD, MPH Executive Director Gond Chief Nkedical Officer Dedicated to protecting and improving the health and environment al the people of Colorado 4300 Cherry Creek Dr. S. Laboratory Services Division Denver, Colorado 0024&-1530 8100 Lowry Blvd. Phone (303) &92.2000 Denver, Colorado 00230-6920 Located in Glendale, Colorado (303) G92-3090 httpliwww.cdphe.slate.co.us January 20, 2012 Charles Ellsworth Frontier Paving Inc. 1414 County Road 311 New Castle, CO 81647 Re. Permit #12GA1083 Dear Applicant: Colorado Dcparnne€1t of Public Health afid ErwirnnrncnI The Colorado Air Pollution Control Division has received and logged in your construction permit application for a hot mix asphalt plant to be operated at a location approximately 1/3 of a mile east of the Garfield County Airport on County Road 315. This hot mix asphalt plant is currently permitted at a different location under permit number 07GA0457. The permit number assigned to this equipment at the new location is 12GA1083. Your application is now ready for initial review. If you should have any questions concerning the status of your permit application, please contact me at 303,692.2285. When calling, please reference the permit number listed above. You can also research the status of your application online at http:11www.cdphe.state.co.uslaplssisspcpt.html. The next step in processing your construction permit application is to determine if all of the information we need is contained within your application. If so, we will begin our preliminary engineering analysis. If any information is missing, however, we will contact you in the near future to obtain the needed material. State taw requires that the Division determine the completeness of an application within 60 days of receipt. If you do not hear from the Division by 02/27/2012, you can assume that your application is complete. Sincerely, Paul Rusher Construction Permit Unit Glenn Hartmann From: Jeff Simonson [JeffS@sgm-inc.comj Sent: Tuesday, January 24, 2012 11:06 AM To: Steve Anthony Cc: Glenn Hartmann; Charles Ellsworth; jlt@sopris.net Subject: RE: Attachments: Bedrock Conditions 4 and 5.pdf Hi Steve, Attached is a PDF of the pertinent conditions to your email of 12/19/11 to Glenn, Per our discussion earlier today, after you had a chance to review John Taufer's letter on the weed management plan, the necessity of condition #4 no longer exists (ie., providing a detailed weed management plan). However, note that John is in the process of providing us an irrigation plan for the drip irrigation system for the trees and shrubs. Likewise, he is getting us a detail on the means necessary to protect the trees and shrubs from wildlife. Finally, we are finalizing the acreage calculations for the areas that will be permanently seeded so as to provide proper security at $2,500 per acre. Once these pieces of information are put together, I will forward accordingly so as to be able to address Glenn's condition #5. As we discussed, to formally address condition #4, I would suspect that Glenn need's an email concurring with this email or a memo that identifies such. I put all necessary contacts on this email so as to help you reply accordingly. Thanks and call with questions!! Jeff From: Steve Anthony[mailto:santhonyCgarfield-county,com] Sent: Tuesday, January 24, 2012 10:16 AM To: Jeff Simonson Subject: Steve Anthony Garfield County Vegetation Manager 0298 CR 333A Rifle CO 81650 Office: 970-625-8601 Fax: 970-625-8627 Email: santhonyOcarfield-county_com Glenn Hartmann From: Jeff Simonson [JeffS@sgm-inc.com] Sent: Tuesday, January 24, 2012 12:50 PM To: merion@resource-eng.com Cc: Glenn Hartmann; Charles Ellsworth Subject: Existing Fuel Containment for Bedrock Resources Attachments: FUEL CONTAINMENT 386.jpg; FUEL CONTAINMENT 387,jpg; FUEL CONTAINMENT 388.jpg Hi Michael, As we discussed, I am forwarding the attached JPG's that identify the fuel tank containment to be employed by Bedrock Resources on their Mamm Creek Property. The pictures depict the current facilities at their Frei pit location which will be duplicated here. Call with questions! Thanks! Jeff Original Message From: Debbie [mailto:deb54540sopris.net] Sent: Monday, January 23, 2012 8:42 AM To: Jeff Simonson Subject: Emailing: FUEL CONTAINMENT 386, FUEL CONTAINMENT 387, FUEL CONTAINMENT 388 The message is ready to be sent with the following file or link attachments: FUEL CONTAINMENT 386 FUEL CONTAINMENT 387 FUEL CONTAINMENT 388 Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. 1 Page 1 of 1 Jeff Simonson From: Charles Ellsworth [Charles c©FrontierPavinglnc.cofn] Sent: Tuesday, January '7, 2012 10:55 AM To: Jeff Simonson; Damian Ellsworth Subject: Fw: GP03 Original Message ----- From: Hancock, Chip To: Charles Ellsworth Sent: Tuesday, January 17, 2012 9:55 AM Subject: RE: GP03 Charles, Per our discussion, if the land disturbance is 25 acres or more, or the project will take 6 months or more then a land development permit is needed (see Reg. 3, Part A, Il.0.1.j. at: http://www.cdphe.state.co.us�regulations/a rregs/SCCR1001-5.pdf). R K "Chip" Hancock III, P.E. Construction Permits Unit Supervisor Stationary Sources Program Air Pollution Control Division Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, CO 80246-1530 303-692-31681 r.hancock@state.co.us From: Charles Ellsworth [ma to:Charles@FrontierPavingInc.com] Sent: Tuesday, January 17, 2012 9:39 AM To: Hancock, Chip Subject: RE: GP03 Chip, Do we need a permit for a land improvement project that would disturb 20 acres on a site of 36 acres besides the SWMP permit? Thanks, Charles Ellsworth 1/26/2012 PIAL AND RETAIN THIS COPY BEFORE AFFIXiI O TO THE PACKAGE. MO POUCH NEEDED. E.,5_. • a 1 D g. N 1:.I • d 16 c1i 2§l! 0 CI 0 - 2 g U L] .y 0 U 1 n r a f cE F i]jI Lo EA 2 14 IP vs 0. - n STATE OF COLORADO }edicated to prole din g and improving the health and environment of the people el Colorado .1300 Cherry Creek 0r. S. Denver, Colorado 8024.1530 Phone (303) 692-2000 TDD Line (303) 691-7700 Located in Glendale, Colorado ht tp:ihsrorw.cdphe.state.co. us Colorado Deparmieilt of Public Health and Environment For Agency Use Only Permit Number Assigned COR00- Date Received 1 Month Day Year COLORADO DISCHARGE PERMIT SYSTEM (CDPS) STORMWATER DISCHARGE ASSOCIATED WITH CONSTRUCTION ACTIVITIES APPLICATION PHOTO COPIES, FAXED COPIES, PDF COPIES OR EMAII.S WILL NOT BE ACCEPTED. Please print or type. Original signatures are required. All items must be completed accurately and in their entirety for the application to be deemed complete. Incomplete applications will not be processed until all information is received which will ultimately delay the issuance of a permit. If more space is required to answer any question, please attach additional sheets to the application form. Applications must be submitted by mail or hand delivered to: Colorado Department of Public Health and Environment Water Quality Control Division 4300 Cherry Creek Drive South WQCD-P-82 Denver, Colorado 80246-1530 Any additional information that you would like the Division to consider in developing the permit should be provided with the application. Examples include effluent data andlor modeling and planned pollutant removal strategies. PERMIT INFORMATION Reason for Application: Pg NEW CERT n RENEW CERT EXISTING CERT # Applicant is: X Property Owner ❑ Contractor/Operator A. CONTACT INFORMATION - NOT ALL CONTACT TYPES MAY APPLY * indicates required *PERMITTEE (if more than one please add additional pages) *ORGANIZATION FORMAL NAME: 842(kr) c- c2: 614. r (;.los / LC 1) *PERMITTEE the person authorized to sign and certify the permit application. This person receives all permit correspondences and is legally responsible for compliance with the permit. Responsible Position (Title): _ rnci ,ve;4.yt+J2 , Currently Held By (Person): )`� f ea � Telephone No: i].07/L email address C hari2_s ,prx.v � {v Organization: [3 oc 't? t^ck.c-t"o S .! Mailing Address: /0) -'4 ( I•A"f-' oc..(0 3 1 City: Irk) Q o-? ( : 1') (2 state: CO )a ru.[QC., zip: 0 /6."-/i) 4 A! ( in This form must be sjngd by the Permittee (listed in item 1) to be considered complete. Per Regulation 61 In ail cases, it shall be signed as follows: a) In the case of corporations, by a responsible corporate officer. For the purposes of this section, the responsible corporate officer is responsible for the overall operation of the facility from which the discharge described in the application originates. b) in the case of a partnership, by a genera! partner, c) In the case of a sole proprietorship, by the proprietor. di In the case of a municipal, state, or other public facility, by either a principal executive officer or ranking elected official page 1 of 5 revised April 2011 2) DMR COGNIZANT OFFICIAL (i.e. authorized agent) the person or position authorized to sign and certify reports required by the Division including Discharge Monitoring Reports *DMR's, Annual Reports, Compliance Schedule submittals, and other information requested by the Division. The Division will transmit pre-printed reports (ie. DMR's) to this person. 0 more than one, please add additional pages. Same As 1) Permittee 0 Responsible Position (Title): ,c42. P_ ? : co' A 1' Currently Held By (Person): a (Person): D = ; R.. i ,i) S �c r4 r Telephone No:! 9c f) 84'fl C O7 email address *s'1 7r "C nr7 + ie..; 'V :SNC . Cc r7 � Organization: FSDsyy r (kJ r N 1' •''JG Mailing Address: / 1•9 (QLi e) -f fedad) 3 / / City: COST State: :...GY �3 Artr�'f t;? Zip: R. 9 t) Per Regulation 61.: All reports required by permits, and other information requested by the Division shall be signed by the permittee or by a duly authorized representative of that person. A person is a duly authorized representative only if: (1) The authorization is made in writing by the permittee (ii) The authorization specifies either an individual or a position having responsibility for the overall operation of the regulated facility or activity such as the position of plant manager, operator of a well or a well field, superintendent, position of equivalent responsibility, or an individual or position having overall responsibility for environmental matters for the company. (A duly authorized representative may thus be either a named individual or any individual occupying a named position); and (iii) The written authorization is submitted to the Division 3) '*SITE CONTACT focal contact for questions relating to the facility & discharge authorized by this permit for the facility. X Same A5 1) Permittee Responsible Position (Title): Currently Held By (Person): Telephone No: email address Organization: Mailing Address: City: State: Zip: 4) * BILLING CONTACT if different than the permittee Responsible Position (Title): Currently Held By (Person): Telephone No: email address Organization: Mailing Address: City: State: Zip: Page 2 of 5 revised April 2011 5) OTHER CONTACT TYPES (check below) Add pages if necessary: ResponsiblePosition (Title): ► f" r1: C• + Act. Currently Held By (Person): J'eft 5;:r, c r,� c -4„' , . C r r Telephone No:i'17O g'`i -4) ar) email address C''C S. C 5 G M ' ► r : Cci tY\ . Organization: 5sv.4 m w.r�s S� l,2Gc c��its r2 r, pp51-'4%41)"►4i x Mailing Address: 1_ � � 1.&)� 6 �� Cit " I ['5fik.5 } . state: i, 4,2 p: a Pretreatment Coordinator o Environmental Contact o Biosolids Responsible Party o Property Owner LI Inspection Facility Contact f_] Stormwater MS4 Responsible ( Consultant Person Compliance Contact Stormwater Authorized Representative f] Other B. Permitted Project/Facility Information Project/Facility Name (Crd(fit rcu 5.. in 4 m iv, CrK e Street Address or cross streets - i S ' ' • C L r. (e.g., "S. of Park St. between 5th Ave. and 10`1' Ave.", or "W. side of C.R. 21, 3.25 miles N. of Hwy 10"; A street name without an address, intersection, mile marker, or other identifying information describing the location of the project is not adequate. For linear projects, the route of the project should be described as best as possible with the location more accurately indicated by a map.) City, ; 1 t Zip Code Si 16, 5.2.. County 6Gt r r e /cL Facility Latitude/Longitude— (approximate center of site to nearest 15 seconds using one of following formats O01A Latitude 3c'f 31 O 93 Longitude /D) � . 2O (e.g-, 39.703°, 104.933°') degrees (to 3 decimal places) degrees (to 3 decimal places) or 001A Latitude " Longitude ° " (e.g., 39°46'11"N, 104°53'11"W) degrees minutes seconds degrees minutes seconds For the approximate center point of the property, to the nearest 15 seconds. The latitude and longitude must be provided as either degrees, minutes, and seconds, or in decimal degrees with three decimal places. This information may be obtained from a variety of sources, including: o Surveyors or engineers for the project should have, or be able to calculate, this information. o EPA maintains a web -based siting tool as part of their Toxic Release Inventory program that uses interactive maps and aerial photography to help users get latitude and longitude. The siting tool can be accessed at iiivww.epa.govitri/reportisiting_tool/index.htm o U.S. Geological Survey topographical rnap(s), available at area map stores. o Using a Global Positioning System (GPS) unit to obtain a direct reading. Note: the latitude/longitude required above is not the directional degrees, minutes, and seconds provided an a site legal description to define property boundaries. C. MAP (Attachment) If no map is submitted, thepermit will not be issued. Map: Attach a map that indicates the site location and that CLEARLY shows the boundaries of the area that will be disturbed. Maps must be no larger than 11x17 inches. D. LEGAL. DESCRIPTION Legal description: if subdivided, provide the legal description below, or indicate that it is not applicable (do not supply Township/Range/Section or metes and bounds description of site) Subdivision(s): _ Lot(s): Block(s); OR SK Not applicable (site has not been subdivided) page 3 of 5 revised April 2011 E. AREA OF CONSTRUCTION SITE Total area of project site (acres): 3 ) - Area of project site to undergo disturbance (acres): 0 a Note: aside from clearing, grading and excavation activities, disturbed areas also include areas receiving overburden (e.g., stockpiles), demolition areas, and areas with heavy equipment/vehicle traffic and storage that disturb existing vegetative cover Total disturbed area of Larger Common Plan of Development or Sale, if applicable: Ov/A (i.e., total, including all phases, things, lots, and infrastructure not covered by this application) Provide both the total area of the construction site, and the area that will undergo disturbance, in acres. Note: aside from clearing, grading and excavation activities, disturbed areas also include areas receiving overburden (e.g., stockpiles), demolition areas, and areas with heavy equipment/vehicle traffic and storage that disturb existing vegetative cover (see construction activity description under the APPLICABILITY section an page 1j. If the project is part of a larger common plan of development or sale (see the definition under the APPLICABILITY section on page 1), the disturbed area of the plan must also be included.. F. NATURE OF CONSTRUCTION ACTIVITY Check the appropriate box(s) or provide a brief description that indicates the general nature of the construction activities. (The full description of activities must be included in the Stormwater Management Plan.) Single Family Residential Development Multi -Family Residential Development Commercial Development Oil and Gas Production and/or Exploration (including pad sites and associated infrastructure) Idighway/Road Development (not including roadways associated with commercial or residential development) Other— Description: cow yt:.e ci ,„0 N (V S[' `2 &Cc cz s s Ro• s -I (( �4 fiJ II P` /4 7 7�" -,1•42 �R-10-4' G - - i f ." t i a .0 t r c Ci 0.� , r 5A G. ANTICIPATED CONSTRUCTION SCHEDULE Construction Start Date: f G i; 'AA r C f 201 a, Final Stabilization Date: NO irn bor 3 t} -? f *Construction Start Date - This is the day you expect to begin ground disturbing activities, including grubbing, stockpiling, excavating, demolition, and grading activities. •Fina! Stabilization Date - in terms of permit coverage, this is when the site is finally stabilized. This means that ail ground surface disturbing activities at the site have been completed, and all disturbed areas have been either built on, paved, or a uniform vegetative cover has been established with an individual plant density of at least 70 percent of pre -disturbance levels. Permit coverage must be maintained until the site is finally stabilized. Even if you are only doing ane part of the project, the estimated final stabilization date must be for the overall, project. If permit coverage is still required once your part is completed, the permit certification may be transferred or reassigned to a new responsible entity(s). H. RECEIVING WATERS (If discharge is to a ditch or storm sewer include the name of the ultimate receiving waters? immediate Receiving Water(s): /3'] a. rsn fr. C f eQ �[ Ultimate Receiving Water(s): C WO ; la rV cn g i"" identify the receiving water of the stormwater from your site. Receiving waters are any waters of the State of Colorado. This includes ail water courses, even if they are usually dry. If stormwater from the construction site enters a ditch or storm sewer system, identify that system and indicate the ultimate receiving water for the ditch or storm sewer. Note: a stormwater discharge permit does not allow a discharge into a ditch or storm sewer system without the approval of the owner/operator of that system. page 4 of 5 revised April 2011 I. REQUIRED SIGNATURES (Both parts i. and ii. must be signed) Signature of Applicant: The applicant must be either the owner and/or operator of the construction she. Refer to Part 8 of the instructions for additional information. The application must be signed by the applicant to be considered complete. In ail cases, it shall be signed as follows: {Regulation 61.4 (lei) a) In the case of corporations, by the responsible corporate officer is responsible for the overall operation of the facility from which the discharge described In the form originates b) In the case of a partnership, by a general partner. c) In the case of a sole proprietorship, by the proprietor. di In the case of a municipal, state, or other public facility, by either a principal executive officer, ranking elected official, la principal executive officer has responsibility for the overall operation of the facility from which the discharge originates). STOP!, ,A Stormwater Manafemvnt Plan must be cQmDIPted prior to silr:n'ing the following certifications! i. STORMWATER MANAGEMENT PLAN CERTIFICATION "i certify under penalty of law that a complete Stormwater Management Plan, has been prepared for my activity. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible far gathering the information, the Stormwater Management Plan is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for falsely certifying the completion of said SWMP, includin ossibility of fine and imprisonmen for knowing violations." ...., n/w1 Signature of Legally Responsible Person or Authorized Agent (submission must include original signature) xx Name (printed) Ar crr Title 16 2c'i�-� 0ate igned il. SIGNATURE OF PERMIT LEGAL CONTACT "I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the Information, the information submitted is to the best of my knowledge and belief, true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations." "I understand that submittal of this application is for coverage under the State of Colorado General Permit for Stormwater Discharges Associated with Construction Activity for the entirety of the construction site/project described and applied for, until such time es the application is amended or the certification i transferred, inactivated, or expired." xx Signature of Legally Responsible Person (submission must include original signature) may /0!aivez_ Q Title DO NOT INCLUDE A COPY OF THE STORMWATER MANAGEMENT PLAN DO NOT INCLUDE PAYMENT --AN INVOICE WILL BE SENT AFTER THE CERTIFICATION IS ISSUED, 1 Narne (printed <1 7-k if 6, Cf, Date Signed page 5 of 5 revised April 2011 Glenn Hartmann From: Charles Ellsworth [Charles@FrontierPavinglnc.com] Sent: Wednesday, February 15, 2012 10:56 AM To: Glenn Hartmann; Dave Smith Cc: Damian Ellsworth Subject: Organic info Glenn and Dave, I just talked to Mischa Popoff, some of the info is quite interesting. The statement that the USDA and the National Organic Program frowns upon an asphalt plant being close to an organic farm is totally false. The burden to remain "organic" is the farmer's responsibility. The only materials that are of concern to the USDA and the NOP are fertilizers and pesticides that are on the do not use list. The farmer is to have a 25' buffer between the source and the crop. Currently there is no testing for any organic farms. The USDA mandates an annual report an the farm. The report is written by the inspector. The inspector has to be certified by the International Organic Inspectors Association. The certifier hires the inspector. The certifier collects 1 to 3% of the farms gross revenue for his income. The report is not public knowledge. The report is given to the farmer and the certifier. The USDA plans to start testing organic farms for pesticides and fertilizers in the future. When they start testing, it will be approximately 5% of the farms. If you have any questions, this guy has a lot of information. His phone # is 250-495-2902. Thank You, Charlie 1 Mail Processing Center Federal Aviation Administration Southwest Regional Office Obstruction Evaluation Group 2601 Meacham Boulevard Fort Worth, TX 76137 Issued Date: 01/10/2012 Charles Ellsworth Bedrock Resources, LLC. 1014 County Road 311 New Castle, CO 81647 Aeronautical Study No. 2011-ANM-2945.OE ** DETERMINATION OF NO HAZARD TO AIR NAVIGATION ** The Federal Aviation Administration has conducted an aeronautical study under the provisions of 49 U.S.C., Section 44718 and if applicable Title 14 of the Code of Federal Regulations, pan 77, concerning: Structure: Building Lime Silo Location: Rifle, CO Latitude: 39-31-25.87N NAD 83 Longitude: 107-42-07.54W Heights: 5588 feet site elevation (SE) 43 feet above ground level (AGL) 5631 feet above mean sea level (AMSL) This aeronautical study revealed that the structure does not exceed obstruction standards and would not be a hazard to air navigation provided the following condition(s), if any, is(are) met: It is required that FAA Form 7460-2, Notice of Actual Construction or Alteration, be completed and returned to this office any time the project is abandoned or: At least 10 days prior to start of construction (7460-2, Part 1) Within 5 days after the construction reaches its greatest height (7460-2, Part II) Based on this evaluation, marking and lighting are not necessary for aviation safety. However, .if marking/ lighting are accomplished on a voluntary basis, we recommend it be installed and maintained in accordance with FAA Advisory circular 70/7460-1 K Change 2. This determination expires on 0711012013 unless: (a) (b) extended, revised or terminated by the issuing office. the construction is subject to the licensing authority of the Federal Communications Commission (FCC) and an application for a construction permit has been filed, as required by the FCC, within 6 months of the date of this determination. In such case, the determination expires on the date prescribed by the FCC for completion of construction, or the date the FCC denies the application. NOTE REQUEST FOR EXTENSION OF THE E1 FI;CTIVE PERIOD OF THIS DETERMINATION MUST BE E -FILED AT LEAST 15 DAYS PRIOR TO THE EXPIRATION DATE AFTER RE-EVALUATION Page 1 of 3 OF CURRENT OPERATIONS IN THE AREA OF THE STRUCTURE TO DETERMINE THAT NO SIGNIFICANT AERONAUTICAL CHANGES HAVE OCCURRED, YOUR DETERMINATION MAY BE ELIGIBLE FOR ONE EXTENSION OF THE EFFECTIVE PERIOD. This determination is based, in part, on the foregoing description which includes specific coordinates , heights, frequency(ies) and power . Any changes in coordinates , heights, and frequencies or use of greater power will void this determination. Any future construction or alteration , including increase to heights, power, or the addition of other transmitters, requires separate notice to the FAA. This determination does include temporary construction equipment such as cranes, derricks, etc., which may be used during actual construction of the structure. However, this equipment shall not exceed the overall heights as indicated above. Equipment which has a height greater than the studied structure requires separate notice to the FAA. This determination concerns the effect of this structure on the safe and efficient use of navigable airspace by aircraft and does not relieve the sponsor of compliance responsibilities relating to any law, ordinance, or • regulation of any Federal, State, or local government body. Any failure or malfunction that lasts more than thirty (30) minutes and affects a top fight or flashing obstruction light, regardless of its position, should be reported immediately to (877) 487-6867 so a Notice to Airmen (NOTAM) can be issued. As soon as the normal operation is restored, notify the same number. If we can be of further assistance, please contact our office at (816) 329-2508. On any future correspondence concerning this matter, please refer to Aeronautical Study Number 2011-ANM-2945-OE. Signature Control No: 153296739-156996802 Vee Stewart Specialist Attachments) Map(s) Page 2 of 3 (DNE) TOPO Map for ASN 2011-ANM-2945-OE Page 3 of 3 Page 1 of 2 Jeff Simonson From: Steve Anthony [santhony©garfield-county.com] Sent: Friday, January 27, 2012 4:26 PM To: Glenn Hartmann Cc: Jeff Simonson Subject: RE: Hi Glenn I concur with Jeff's comments below,1 did miss the weed management plan in the packet originally, and had based my comments on the map that was provided. Condition 4 has been addressed by the applicant. Steve Anthony Garfield County Vegetation Manager 0298 CR 333A Rifle CO 81650 Office: 970-625-8601 Fax: 970-625-8627 Email: santhonyAgarfield-county.com From: Jeff Simonson [mailto:JeffS@sgm-inc.com] Sent: Tuesday, January 24, 2012 11:06 AM To: Steve Anthony Cc: Glenn Hartmann; Charles Ellsworth; jlt@sopris.net Subject: RE: Hi Steve, Attached is a PDF of the pertinent conditions to your email of 12/19/11 to Glenn. Per our discussion earlier today, after you had a chance to review John Taufer's letter on the weed management plan, the necessity of condition #4 no longer exists (ie., providing a detailed weed management plan). However. note that John is in the process of providing us an irrigation plan for the drip irrigation system for the trees and shrubs. Likewise, he is getting us a detail on the means necessary to protect the trees and shrubs from wildlife. Finally, we are finalizing the acreage calculations for the areas that will be permanently seeded so as to provide proper security at $2,500 per acre. Once these pieces of information are put together, I will forward accordingly so as to be able to address Glenn's condition #5. As we discussed, to formally address condition #4, I would suspect that Glenn need's an email concurring with this email or a memo that identifies such. I put all necessary contacts on this email so as to help you reply accordingly. Thanks and call with questions!! Jeff From: Steve Anthony [mailto:santhony@garfield-county.com] Sent: Tuesday, January 24, 2012 10:16 AM To: Jeff Simonson 1/30/2012 Page 2 of 2 Subject: Steve Anthony Garfield County Vegetation Manager 0298 CR 333A Rifle CO 81650 Office: 970-625-8601 Fax: 970-625-8627 Email: santhonyparfield-county.com 1/30/2012 Page 1 of 2 Jeff Simonson From: Jeff Simonson Sent: Friday, January 27, 2012 12:07 PM To: `Kevin Whelan' Cc: 'Charles Ellsworth"; 'Glenn Hartmann' Subject: RE: Bedrock Resources -major impact review Attachments: Fhyd 1111odelL SUCTION.pdf; DRY HYDRANT.pdf Bedrock Resources LLC fire mitigation plan.doc Kevin, Per our meeting last Friday, I am providing this email to follow up with the details that I promised that I would send on relative to the dry hydrant and water line installation for the fire suppression system that is being installed for the Bedrock Resources project. Per our meeting, both hydrants will be DRY hydrants and fitted with the appropriate adapters. You will find attached two PDF files that reflect the hydrant and the suction line installation. Also, you will find attached the fire mitigation plan that Charlie has prepared. I trust that with this information and with our ability to answer your questions by the submittal of our prior correspondence to Glenn, you can provide concurrence to the County by "reply all" to this email as I have also included Glenn Hartman on the Cc list. Thank you again for the time you gave us to meet last Friday and please call if you have any questions! Thanks Jeff Simonson 970-384-9005 or 970-379-4691 From: Kevin Whelan [mailto:kewhelan@riflef redept.org] Sent Tuesday, December 27, 2011 10:23 AM To: Jeff Simonson Subject FW: Bedrock Resources -major impact review Jeff, I hope your time off was good over the recent holidays! I did call your office to talk with you prior to sending in my comments in the below e-mail to the county. When you get a chance, please give me a call and we can go over them in more detail. 1 also attached our requirements for developing a private water supply system and our hai mat declaration packet that I referenced in my review. !look forward to hearing from you and again hope you had a good time off! Kevin C. Whelan Division Chief/ Fire Marshal Rifle Fire Protection District 1850 Railroad Ave Rifle, CO 81650 kewhelan@a riflefiredept.org Office- 970-625-1243 ext 12 Fax- 970-625-2963 1/30/2012 Page 2 of 2 Cell -970-618-7388 The Mission of the Rifle Fire Protection District is to Enhance Health and Safety and to Protect the Life,Home and Property of the People We Serve." From: Kevin Whelan[mailto:kewhelan@riflefiredept.org] Sent: Tuesday, December 27, 2011 10:13 AM To: 'g ha rtmann@ga rfield-county.com' Subject; Bedrock Resources -major impact review Glenn, I have reviewed the documents for the Bedrock Resources LLC- Asphalt Batch Plant Major Impact Review-MIPA- 7030. The following are my comments: 1. Fire Protection Water Supply: a. Calculations need to verified i. Height of buildings b. Draft height c. Wet fire hydrant vs dry hydrant d. Is 100'x50' shop the most demanding building for fire protection water? e. Design should meet Rifle Fire's guidance documents which in some cases, give further details then NFPA 1142. 2. Fueling area and petroleum products for the plant and associated activities may drive submittal of a hazardous materials declaration to Rifle Fire. This depends on the quantities. 3. Roads: a. Grades of 10% are at the upper limits of policy requirements and should be avoided where at all possible. b. Proposed Access Road does not meet the minimum width for a fire access road. More information is needed an what this road serves or will serve. Due to the holidays, i was unable to contact Jeff Simonson of SGM but i will forwarded a copy of this e-mail and all appropriate review documents from Rifle Fire Protection District that are applicable. I would anticipate with more information from Jeff, that some of the above comments would then be satisfied. His vacation lasts into the first week of January. Kevin C. Whelan Division Chief/ Fire Marshal Rifle Fire Protection District 1850 Railroad Ave Rifle, CO 81650 kewhelan@rifiefiredept.org Office- 970-625-1243 ext 12 Fax- 970-625-2963 Cell -970-618-7388 The Mission of the Rifle Fire Protection District is to Enhance Health and Safety and to Protect the Life,Honie and Property of the People We Serve." 1/30/2012 rbi kn NI Ln o0 4 Bedrock Resources LLC. Fire MitigationPlan 0500 County Road 315 Silt Colorado 81652 The site is approximately 36 acres bordered by County Road 315 and by rural mesa type property with vegetation comprised mostly of Cheat grass and Russian Knapweed. The proposed development for the mesa portion of the subject property will be an asphalt plant with associated aggregate stockpiles for virgin aggregate as well as recycled asphalt material, a shop building and a three sided equipment storage building. The driving and parking surfaces will be graveled and treated with mag -chloride. The access road will be constructed up through the steep portion of the property and the office will be constructed on the lower flat area close to County Road 315. The areas disturbed from construction will be revegetated with natural dry land type grasses and a few shrubs and trees. The shrubs and trees will have an irrigation system. The lower flat area and the steep slope area of the property will be cleaned up of any dead vegetation and trash. Any noxious weeds will be sprayed and cut on a regular basis. The upper mesa area will be mostly gravel surfaces, the asphalt plant and the associated stockpiles. The upper mesa is also where the fire protection pond is located. The proposed buildings will be steel construction with steel siding and roofs. The berms that will be constructed for noise, visibility and dust abatement will be revegetated in the same fashion as the lower areas on the property. The noxious weeds will be sprayed and cut on a regular basis. In summary, we intend on clearing and disposing of any dead shrubs and trees from alI areas that will not be disturbed in the construction process. The revegetation will consist of natural grasses and a small number of less flammable shrubs and trees. The focus will be on Defensible Space. Sincerely, Charles Ellsworth Page 1 of 2 Jeff Simonson Frorn: Damian (Damian rr7frontierpavinginc.coml Sent: Tuesday, January 24, 2012 11:05 AM To: Jeff Simonson Subject: Fw: Bedrock Resources LLC - ---- Original Message ----- From: Ray Sword To: damianafrontierpavinginc.com Sent: Tuesday, January 24, 2012 10:14 AM Subject: FW: Bedrock Resources LLC - Damian - 1 sent this to Glenn and CC`d you, but misspelled your name in your address. Just getting in a hurry! Sorry. Here you go. Ray From: Ray Sword Sent: Tuesday, January 24, 2012 10:11 AM To: Glenn Hartmann Cc: 'damion@frontierdavinginc.com'; Betsy Suerth Subject: Bedrock Resources LLC - Glenn - As per our conversation on 1/23/2012, regarding the combined driveway access for Bedrock Resources LLC, and my meeting with Charles and Damian Ellsworth. The Road & Bridge Department has agreed to allow the two driveways to remain separated. Conditionally, Bedrock Recourses has agreed to remove one tree on the County right of way north of the single family driveway to improve visibility, and to clean the bar ditch north and south of said driveway to allow for improved drainage. The single family driveway will serve as temporary access to the construction site until the new driveway/road is established. Any additional use of this driveway after construction, should be limited to light truck traffic, and emergency access only. Dust control will be required at all times on the temporary and newly constructed roads. The permit owner will also be responsible for any temporary signage, as well as keeping County Road 315 free of dirt, dust and debris during the construction period. Any loading/unloading of equipment on the County road or right of way, will require appropriate signage and flaggers. As a condition of the access/driveway permit, we have agreed to a 100'X20'X4" asphalt pad, with no less than 200' (300' preferred for visibility to the north) between the existing driveway to the north, and the new driveway. Additionally, the pad should 1/30/2012 Page 2 of 2 have a V -pan design to promote drainage away from the County road, and in to the existing bar ditch. A culvert in the existing bar ditch under the new driveway will not be required due to the design of the new drainage plan. A stop sign at the entrance/exit of the driveway will be required. Please do not hesitate to contact me should you have any additional questions or concerns. le- Garfield County Ray Sword District 3 Foreman Road & Bridge 0298 CR 333A Rifle, CO 81650 Mobile: 970-987-2702 Office: 970-625-8601 x4311 Fax: 970-625-8627 rsword@garfield-county.com 1/30/2012 Glenn Hartmann From: Ray Sword Sent: Wednesday, January 18, 2012 8:06 AM To: Glenn Hartmann Subject: Bedrock Resources LLC - Asphalt Batch Plant Mr. Hartmann: After further review of the MIR for the Bedrock Resources LLC project, I have determined that the aforementioned drainage issues in my initial site evaluation will not be an issue. All new construction drainage should be adequate to handle any runoff or drainage issues. Please feel free to contact me if any further explanation is need. Thank you, Ray Garfield County Ray Sword District 3 Foreman Road & Bridge 0298 CR 333A Rifle, CO 81650 Mobile: 970-987-2702 Office: 970-625-8601 x4311 Fax: 970-625-8627 rsword@garfield-county.com Colorado Department of Public Health and Environment Air Pollution Control Division Notre 'subalt An Overview of Environmental Regulations In order to protect and preserve Colorado's public health and valuable resources, hot mix asphalt (HMA) plants (or facilities) must adhere to strict air, water, and waste requirements administered by the Colorado Department of Public Health and Environment (CDPHE). As Colorado moves forward, so has the need for asphalt materials. Today, over 12 million tons of hot mix asphalt are produced by over 60 HMA facilities in Colorado each year. This fact sheet provides an overview of the asphalt production process and the environmental requirements that apply to HMA facilities in Colorado. The Asphalt Production Process Hot mix asphalt paving materials are a mixture of aggregate, sand, and asphalt binder, and may include recycled asphalt pavement. The HMA process involves mixing the crushed aggregate with asphalt cement (a product of oil refining that acts to glue the aggregates together) to form a hot asphalt mixture that can be laid down as a smooth road surface. Air Emissions Controlling the emission of harmful pollutants into the air is the guiding principle behind the state's air quality standards, Stringent limits are set for a range of pollutants based on their known effects on human health and the environment. Technology and control systems are available to modern HMA facilities so that they comply with the air quality standards of the State of Colorado. Operation and Maintenance Plans are submitted by the permittee to ensure and document that their controls are working in the most efficient manner. In addition, dust control plans are required to be in place to control fugitive dust from material storage and handling areas and from trucks traveling on haul roads, HMA plants have the potential to emit various pollutants. Potential emissions include volatile organic compounds (VOCs), carbon monoxide (CO), nitrogen oxides (NO,), sulfur dioxide (SO2) if sulfur is present in the fuel, and particulate matter (PM). Asphalt plants are required to install controls or take other measures to reduce harmful air emissions. These measures and controls may include counter -flow mixing equipment technology, baghouse systems to control particulate emissions, enclosed or partially enclosed conveyor systems, and top -of -silo emission recovery systems. In addition, best management practices to minimize emissions during HMA production have been established by the asphalt industry. These best management practices include guidance on facility operation and maintenance to maximize efficiency and minimize emissions. Air Reporting & Permitting Requirements All Colorado HMA plants are required to report their air emissions to the CDPHE Air Pollution Control Division (APCD) and obtain an air permit. HMA plants must report their air emissions by submitting an Air Pollutant Emission Notice (APEN) to the APCD. The APEN includes information on the location and ownership of the plant and detailed information on the site-specific process equipment and air pollution control measures. The APCD uses the information provided on the APEN to write an air permit for the HMA plant. A Final Approval air permit is issued only when the HMA plant demonstrates and certifies compliance with all state and federal air quality standards. In addition to obtaining an air permit, HMA plants must comply with federal requirements called New Source Performance Standards provided in An Air Permit Includes.,, • Limits on annual asphalt production • Required air pollution controls • Opacity (visual emissions) limitations • Recordkeeping requirements • Operating and maintenance requirements • Other key areas that may need to be addressed e.g., methods for controlling fugitive dust at the site. Colorado Regulation No. 6, Part A, Subpart I, Standards of Performance for Hot Mix Asphalt Facilities. The performance standard limits the particulate emissions from the HMA plant. To show that the HMA plant can meet the air emission limits, the owner/operator must conduct a performance test for particulates, opacity, and sometimes CO emissions. The test must be conducted within the first six months Hot Mix Asphalt: An Overview of Environmental Regulations November 2008 Colorado Department of Public Health and Environment Air Pollution Control Division of operation after the HMA plant receives an initial approval permit to construct the plant. NEW - New Source Performance Standard Subpart 1111 This performance standard limits emissions of nitrogen oxides (NOx), particulate matter (PM), carbon monoxide (CO), and Non -methane hydrocarbons (NMHC) from Stationary Compression Ignition Internal Combustion Engines (CI ICE's). Sulfur oxides (SOx) will also be controlled through low sulfur fuel requirements. Owners or operators of CI ICE's that commence construction, reconstruction, or modification (as defined at 40 CFR 60.14) after July 11, 2005 will be subject to this rule. An example of a CI ICE is a diesel generator that is not a non -road engine. All CI ICE's manufactured after 2007 must be certified by the manufacturer to meet EPA Non -road engine standards, and emergency generators are required to have non- resettable hour meters to track hours of operation. All Stationary Compression Ignition Internal Combustion Engines shall be reported to the Division on an APEN form prior to operating the engine. Rental equipment. will have to be permitted as well. Air Inspections and Enforcement The APCD enforcement staff conducts routine inspections of Colorado HMA plants to ensure that plant operators are properly maintaining the required air pollution equipment, keeping records, and complying with all conditions of the air permit. Most HMA plants are inspected every 3 to 5 years, while others are inspected annually. The APCD also responds to citizen complaints on dust or odor at HMA plants. When a permit violation or noncompliance issue leads to enforcement proceedings, corrective action is required and fines of up to $15,000 per violation per day can be levied against HMA plants. Stormwater/Colorado Discharge Permit System (CDPS) Almost all Colorado HMA plants are required to obtain a Stormwater General Permit for Light Industrial Activity or to be covered under a Stormwater General Permit for Construction Activities if the plant is dedicated to a specific construction site covered by this permit. Stormwater refers to runoff resulting from rain or snowmelt events. When stormwater comes into contact with plant operations or storage piles, it can become contaminated with sediments, oil and grease, or other pollutants that could impact Colorado INablicl-kaJd3 and Fawinortnisni waterways. The Stormwater General Permit requires an HMA plant to develop and implement a Stormwater Management Plan (SWMP) that includes best management practices to prevent the discharge of pollutants in stormwater runoff. In addition, spills of oil or fuel of greater than 25 gallons, or spills of any size that reach State waters, must be reported to CDPHE. Spill remediation and monitoring is required. Stormwater and process water permits are issued under the Colorado Discharge Permit System (CDPS) administered by the CDPHE Water Quality Control Division (WQCD). Solid and Universa! Waste A typical HMA plant does not generate hazardous waste and generates very little solid and universal waste. Some wastes, such as petroleum - contaminated soils, may be reused in the asphalt production process. Alt wastes must be properly managed and disposed of. Community Right to Know On March 1 of each year, every HMA production facility is required by state and federal law to report the storage of regulated onsite chemicals. This information is sent to emergency planning organizations. Concerned citizens can obtain this public information from state and federal agencies. Questions? Air Emission Reporting and Permitting: • Small Business Assistance Program (SBAP) — (303) 692- 3175 or (303) 692-3148 IrItp::!ws�'w rdphe.slale cel ,I5,'7rri4I tp n p Hazardous and Solid Waste Management: • Generator Assistance Program (GAP) — (303) 692-3415 • Technical Assistance Hotline -- (303) 692-3320 r.dphr 61 ileco LP£-'rinliga) gi)Iiorn aSJ Wastewater and Stormwater Permitting: • Water Quality Control Division — (303) 692-3500 Ccij hr titr, co u5+u' Wwilhionl asr w Hot Mix Asphalt: An Overview of Environmental Regulations November 2008 sEAps,:,.; .K+all SJS1NI55 A5515TAA».t PROGPA.M Small Business Assistance Program Colorado Department of Public Health and Environment http://www.cdphe.state.co.uslapfsbap.asp An Overview of Colorado Air Regulations for: Surface Mining Operations, Concrete Batch Plants & Hot Mix Asphalt Plants Surface mining operations in Colorado, including sand and gravel pits, borrow pits, and quarries, as well as concrete batching operations and hot mix asphalt plants. release air pollutants that are regulated by the Air Pollution Control Division (Division) at the Colorado Department of Public Health and Environment. This document provides an overview of the air pollution reporting and permitting requirements that apply to these operations. Y WHAT AREA IS MY BUSINESS IN? Air emission reporting and permitting requirements in Colorado vary based on whether a business is located in an "attainment/attainment maintenance" area or a "nonattainment" area of Colroado. In general. air regulations are more stringent in "nonattainrnent" areas because these areas exceed the National Ambient Air Quality Standards for regulated pollutants. The Small Business Assistance Program (303-692-3150) can assist you in determining which area your business is located in. AIR POLLUTANTS The Air Pollution Control Division regulates two types of air pollutants: criteria and non -criteria pollutants. Criteria pollutants include particulate matter, carbon monoxide. nitrogen oxides, sulfur dioxide, and volatile organic compounds (VOCs), among other pollutants. Non -criteria pollutants include a list of over 188 chemicals listed in Colorado Regulation No. 3, Appendix B. Surface mining operations, concrete batch plants, and hot mix asphalt plants commonly emit particulate matter, including total suspended particulates [TSP] and particulates with a diameter of 10 microns or less [PM 10]. Particulate matter is emitted from processes such as conveying, screening, crushing, stockpiling. storing, and hauling materials. Dryers fired with natural gas. oil, propane, or diesel. may also emit TSP, PM 10, carbon monoxide and nitrogen oxides. Dryers niay emit VOCs or sulfur oxides depending on the type of fuel used. AIR EMISSION REPORTING AND PERMITTING REQUIREMENTS In Colorado. obtaining an air permit is a two-step process. The first step is to report your air emissions through the submission of an Air Pollution Emission Notice (APEN) to the Division. For businesses with Colorado Small Business Assistance Program Page 1 of 8 emissions above permitting thresholds, the second step involves obtaining an air permit. Reporting and permitting thresholds are presented in Attachment A. The Division will use the information provided on your APEN to determine whether your business requires an air permit. Kan air permit is required, the APEN will become part of your permit application package. If this application package is incomplete, the Division will request additional information. The Division issues two types of air permits: Construction Permits and Operating Permits. Construction Permits are issued to minor sources of air pollution which ernit less than 100 tons of pollutants in a nonattainment area, and less than 250 tons of pollutants in an attainment area. Operating Permits are issued to major sources that exceed these levels. A source with the "potential to emit" pollutants above these levels may choose to be designated as a "synthetic minor" source. Synthetic minor sources can obtain Construction Permits with restrictions on throughput or operating parameters to keep emissions below major source thresholds. In Colorado, Construction Permits are issued in two phases: Initial Approval and Final Approval. • An Initial Approval permit allows the plant to be constructed and begin operation. • A Final Approval permit is issued after the owner certifies that the operation is in compliance with the conditions of the Initial Approval permit. The owner must submit the certification within six months of the beginning of operations or issuance of the permit. A pen -nit describes key areas that an operator needs to address. The permit defines the type of air pollution control measures to be used, limits the annual production at the site, provides guidelines for opacity (how dense the visible emissions are allowed to be), and includes recordkeeping requirements. GUIDELINES FOR SUBMITTING AN APEN AND/OR OBTAINING AN AIR PERMIT Specific guidelines for submitting an APEN and/or obtaining a permit for surface mining operations, surface mining process equipment, concrete batch plants, and hot asphalt plants are provided below. AH APEN and related forms are available through the Division and can be downloaded at: littp://www.cdphe.state.co.usiapidownloadforms.asp Surface Minink Sites The APEN form titled "Mining Operations — APEN and Application for Construction Permit and Fugitive Particulate Emissions Control Plan" is used to report: air emissions at surface mining operations. The form requests information on the location and ownership of the site and detailed information on the nature of site emissions. production, and equipment. The APEN for Mining Operations also requests information on your site's Fugitive Particulate Emissions Control Plan. If an air permit is issued for the site, the permit will contain a Particulate Emission Control Plan (PECP) that is derived from the information provided on the APEN. The PECP restricts visible emissions on-site and off -property transport of dust. The PECP includes control measures such as watering, revegetation, controlling vehicle speeds, and reclamation of disturbed areas. Note: Surface mining activities that mine 70,000 tons or fewer of product material per year (i.e., raw material removal or processing for sale, which could include top soil, overburden, and raw material) are specifically exempt from permitting requirements per Regulation 3, Section 11I.D.1.g. Colorado Small Business Assistance Program Page 2 of 8 However, an APEN may still be required even ifa permit is not. Also, because site equipment is evaluated separately from the surface mining activities. site equipment such as screens and crushers may require an APEN and permit even if the surface mining activities do not. Surface Mining Process Equipment The process equipment located at a surface mining site. such as generators. crushers. screen decks, and conveyor systems. are treated separately from the mining operations. As a rule of thumb. process equipment almost always requires the submission of an APEN to the Division. and almost always requires an air permit. Process equipment is reported on the "General APEN" form. This form requires general information about the equipment such as the type of equipment. make. model. and serial number, hours of operation. and quantity of material processed through the equipment. Use the General APEN fora} to indicate whether the process equipment is portable or fixed: Portable equipment can be moved from site to site: however. a '`Notice of Relocation" must be submitted to the Division at least 10 days prior to the relocation of permitted portable equipment. Records should be maintained on the location of each piece of equipment at the home base. Fixed equipment must remain at the source location indicated in the permit for at least two years. If you decide to move fixed equipment. you must submit an APEN to modify the permit to reflect "portable" equipment prior to the move. Each individual piece of process equipment is typically reported on a separate APEN form. However. multiple pieces of equipment may be grouped and reported on a single General APEN form if the equipment will always remain together (i.e.. pieces of equipment can not be added or removed from the group). For example. if a portable group of equipment is moved to a new site, each piece of equipment in that group must move to the new site, and no piece of equipment can be left behind. Grouping equipment onto a single General APEN, can help you avoid extra APEN filing and permitting fees. Special Ren ulrrtory Requirements for Surface Mining Process Equipment: Process equipment that was built or modified after August 31, 1983 may also be subject to New Source Performance Standards set forth in 4() C.F.R. Part 60. Subpart 000. Specifically. the following process equipment is subject to Subpart 000: Portable Plants: • Portable sand and gravel plants and crushed stone plants with maximum design capacities of greater than 150 tons per hour (based on the combined capacity of all initial or primary crushers) are subject to Subpart 000. in addition. all affected equipment (i.e., equipment that is in-line with the primary or initial crusher) is subject to Subpart 00O. Stationary (Fixed) Plants: • Fixed sand and gravel plants and crushed stone processing equipment with maximum design capacities of greater than 25 tons per hour (based on the combined capacity of all initial orprimary crushers) are subject to Subpart 000. in addition, all affected equipment (i.e., equipment that is in- line with the primary or initial crusher) is subject to Subpart 000. Subpart 000 does not apply to Portland cement production. underground mines. or stand-alone screens without crushers of grinding mills. Colorado Small Business Assistance Program Page 3 of 8 Equipment subject to Subpart 000 must undergo an opacity test in order to obtain a Final Approval permit. Opacity tests are used to verify that the equipment is operating in a manner consistent with the emission limits of Subpart 000. The source must give the Division notice of their intent to conduct performance tests at least 30 days prior to the test date(s). Opacity tests must be conducted within 60 days of reaching maximum production levels and within 180 days of initial startup. Opacity tests are conducted using EPA Method 9. The standard requires a three-hour test for particulate emissions. This may be reduced if no individual readings exceed 10 percent and fewer than three reading of 10 percent occur during the first hour of the test. Opacity tests are not required for wet screening, bucket elevators, and conveyors when the material is saturated with water. This exemption applies up to, but not including, the crusher. Equipment located in an enclosed building must undergo fugitive emission testing using EPA Method 22. Subpart 000 includes very specific requirements regarding monitoring of operations, reporting and recordkeeping. and changing equipment. if your equipment is subject to Subpart 000, take time to review and understand the requirements of this standard. Additional guidance on Subpart 000 is provided in the "Guidance Manual for Nonmetallic Mineral Processing Plants" developed by the Division. This document is available for download at hits://www.cdphe.state.co.uslap/downf000cov.ndf. Concrete Batch Plants Surface mining operations are often co -located with concrete batch plants. Regardless of the overall site activities, minor source surface mining operations and concrete batch plants are always reported and permitted separately. The APEN form titled "Concrete Batching Plants - APEN and Application for Construction Permit" is used to report air emissions at surface mining operations. This form requests information on the location and ownership ot'the site. detailed information on air pollution control equipment, and information on air emissions from stacks and silos. storage piles, and on-site haul vehicles and roads. Unlike surface mining operations, which require separate APENs for the mining site and the process equipment. an entire concrete batch facility can be included on the APEN for Concrete Batch Plants. A concrete batch facility may include boilers, silos, control equipment such as bagfilters and filter socks, and transfer points such as sand and aggregate transfer to elevated bins, cement unloading to elevated storage silos. weigh hopper loading. mixer loading and truck loading. Concrete batch plants can be permitted as either fixed or portable plants. When portable plants are moved, a Notice of Relocation must be submitted to the Division at least 10 days prior to the relocation. If you decide to move a fixed concrete batch plant. you must submit an APEN to modified the permit to reflect a '`portable" plant prior to the move. Hot Mix Asphalt Plants Surface mining operations are often co -located with hot mix asphalt plants. Regardless of the overall site activities, minor source surface mining operations and hot mix asphalt plants are always reported and permitted separately. All Colorado hot mix asphalt plants constructed or modified after June 1 1, 1973 must file and APEN and obtain an air permit. regardless of the level of pollutants emitted at the site. (Note: Hot mix asphalt plants built prior to June 1 l . 1973 must submit an APEN only if the APEN reporting thresholds in Attachment A are exceeded). Colorado Small Business Assistance Program Page 4 of 8 The APEN form titled "Hot Mix Asphalt Plants - APEN and Application for Construction Permit" is used to report air emissions at hot mix asphalt plants. This form requests information on the location and ownership of the site and detailed information regarding the product. fuel, stack emissions. and air pollution control measures. Unlike surface mining operations. which require separate APENs for the mining site and the process equipment, an entire hot mix asphalt facility can be included on the APEN for Hot Mix Asphalt. A hot mix asphalt facility is comprised only of any combination of the following: dryers; systems for screening. handling, storing, and weighing hot aggregate; systems for loading, transferring, and storing mineral tiller; systems for mixing hot mix asphalt: and the loading, transfer. and storage systems associated with emission control systems. Hot mix asphalt plants can be permitted as either fixed or portable plants. When portable plants are moved, a Notice of Relocation must be submitted to the Division at least 10 days prior to the relocation. if you decide to move fixed hot mix asphalt plant. you must submit an APEN to modified the permit to reflect "portable" plant prior to the move. ,Special Regulatory Requirements Hot mix asphalt plants built or modified after June 11, 1973 are subject to New Source Performance Standards set forth in 40 C.F.R. Part 60, Subpart 1. In accordance with this standard, asphalt plants must undergo stack tests for particulate concentrations and opacity tests in order to obtain a Final Approval permit. EPA Method 5 is used to demonstrate that emissions of particulate matter are below 0.04 gr/dscf. EPA Method 9 is used to demonstrate that opacity (visible emission) is below 30 percent. The source must give the Division notice of their intent to conduct the tests at least 30 days prior to the test date(s). Opacity tests must be conducted within 60 days of reaching maximum production levels and within 180 days of initial startup. Additional information on regulatory requirements for the hot mix asphalt industry is available on the Division webpage at littp://www.cdphe.state.co.usielieross media/asphalt/lrmahom.astr. KEEPING YOUR APEN AND/OR AIR PERMITCURRENT APENS are valid for five years and must be updated when certain changes occur at the site. It is important to submit revised or renewed APENs to keep your air permit accurate and up-to-date. A revised or renewed APEN must be submitted under the following scenarios: 1. Submit an APEN... Annually whenever a significant change in emissions occurs. Sources must submit a revised APEN to inform the Division of significant changes in actual emissions by April 301h of the following year (e.g.. a change in emissions in calendar year 2003 must be reported by April 30, 2004.) The definition of a "significant change in emissions" varies based on whether the source emits criteria or non -criteria pollutants, as described below. Criteria Pollutants: • For sources emitting less than 100 tons per year a change in actual annual emissions of 5 tons per year or more above the level reported on the last APEN submitted to the Division; Colorado Small Business Assistance Program Page 5 of 8 • For volatile organic compound (VOC) sources in ozone nonattainment areas emitting less than 100 tons per year of VOC. a change in actual annual emissions of 1 ton or more. or 5 percent, whichever is greater above the level reported on the last APEN submitted to the Department: • For sources emitting 100 tons per year or more, a change in actual annual emissions of 50 tons or more, or 5 percent, whichever is less above the level reported on the last APEN submitted to the Division; • A change in actual emissions of 50 pounds per year of lead. above the level reported on the last APEN submitted to the Division. Non -Criteria Pollutants: • An increase in actual annual emissions of 50 percent or 5 tons, whichever is less. 2. Submit an APEN... When there is a change in ownership or a change in the business/source location. An APEN must be submitted to the Division whenever the ownership or location of a business (or source) changes. For a change in ownership, the new owner must also supply a signed agreement containing the specific date for the transfer of the permit, responsibility, coverage and liability between the current and new permittee. After the Division receives the APEN, fee and written agreement, the Division will issue a new permit reflecting the ownership change. If a company is changing its name only. and all other procedures and information as stated in the last APEN submitted by the business remains unchanged, the company must only submit one APEN indicating the name change and a Permit Amendment form specifying the name change if a permit exists. 3. Submit an APEN... When new or different air pollution control equipment is installed. An APEN is required whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment. Revised APENs are not required for routine maintenance or repair of control equipment. 4. Submit an APEN... When a permit limit is modified. If you have an existing permit that requires modification (e.g., the owner wishes to change the operation equipment or throughput), a revised APEN must be submitted. Make sure you know your permit limits. if you think you may exceed those limits, you may want to modify your permit. 5. Submit an APEN... Before the current APEN expires. An APEN is valid for five years. A new, complete APEN form must be submitted at least 30 days before expiration of the five year term of the current APEN. Contact the Division at 303-692-3150 if you are unsure when your APEN expires. WHAT FEES APPLY? Filing Fee: A $11.9.96 filing fee is required for each APEN submitted. This includes APENs submitted for administrative changes (e.g.. change in ownership. change in location). Fees are subject to change by the legislature on an annual basis. Colorado Small Business Assistance Program Page 6 of 8 Annual Fee: All sources required to file APENs must pay annual fees. The Division bills each source subject to an APEN filing fee of $13.54 per ton of criteria pollutants emitted and $90.34 per ton of non - criteria (hazardous air pollutants) emitted. The Division mails invoices for these fees in May or June dead) year. Fees are subject to change by the legislature on an annual basis. Permit Processing Fee: In addition to the $1 19.96 APEN filing fee, permit -processing fees will be assessed at an hourly rate of $59.98Ihr. If the total processing time is anticipated to be more than 30 hours the Division will contact the applicant in writing and provide an estimate of the projected processing time. The applicant can waive this notice by submitting a letter making this request when the application is submitted. `r RECORD KEEPING Surface mining operations, concrete batch plants, and asphalt plants must maintain annual records of product throughput in order to demonstrate compliance with the permit limits and requirements. These records must be rnade available to the Division for inspection upon request. For portable plants, records should indicate where the plant has been located, the length of time at each location, and the amount of material processed at each location. The site owner or operator should also maintain a copy of the most recent APEN and air permit (if required). The permit number must be permanently affixed on each piece of permitted equipment. SMALL BUSINESS ASSISTANCE PROGRAM The Small Business Assistance Program (SBAP) is available to answer questions you may have regarding environmental issues at your site. The SBAP can help you understand regulations. help you determine what your company has to do to be in compliance. help you file required forms. help you complete the APEN process (if required), help you calculate your emissions. or provide information by presenting a workshop for your company or for your industry. We are here to help, and our services are always free and confidential. Small Business Assistance Program Colorado Department of Public Health and Environment Horne Page: www.cdphe.state.co.usiap/sbap.asp Program Contacts: Joni Canterbury — (303) 692-3175 Margo Griffin — (303) 692-3148 Colorado Department Of Public Health and Environment Colorado Small Business Assistance Program Page 7 of 8 ATTACHMENT A APEN REPORTING THRESHOLDS Pollutant Category Uncontrolled Actual Emissions Attainment Area Non -attainment Area Criteria Pollutants 2 tons per year 1 ton per year Lead 100 pounds per year 100 pounds per year Non -Criteria Pollutants' Bin A — 50 pounds per year Bin B — 500 pounds per year Bin C — 1,000 pounds per year Bin A — 50 pounds per year Bin 13 — 500 pounds per year Bin C — 1,000 pounds per year 'Non -criteria pollutants are organized into Bin A, B, and C in Regulation 3, Appendix B. The reporting thresholds for these pollutants vary depending on the pollutant. release point height, and distance to the property line. and are determined using the procedures provided in Regulation 3, Appendix A. The most conservative reporting thresholds for non -criteria pollutants are provided in this table. AIR PERMITTING THRESHOLDS Pollutant Category Uncontrolled Actual Emissions Attainment Area (tons per year) Non -attainment Area (tons per year) PM -l0 5 1 Total suspended particulates 10 5 Volatile organic compounds 5 2 Carbon monoxide 10 5 Sulfur dioxide 10 5 Nitrogen oxides 10 5 Lead 200 pounds per year 200 pounds per year Other criteria pollutants: fluorides, sulfuric acid mist, hydrogen sulfide, total reduced sulfur. reduced sulfur compounds. 2 2 Colorado Small Business Assistance Program Page 8 of 8 United States Department of Agriculture 1400 Independence Avenue SW, Agricultural Marketing Service Room 2646 -South Building National Organic Program Washington, DC 20250 NOP 4002 Effective Date: July 22, 201 1 Page 1 of 9 Instruction National Organic Program Enforcement 1. Purpose This instruction provides policy and procedural guide lines for taking enforcement actions against violations of the National Organic Program (NOP) (7 CFR Part 205) and the Organic Foods Production Act of 1990 (OFPA), as amended (7 U.S.C. 6501 et seq.). Its purpose is to establish appropriate and consistent sanction guidelines for instances where evidence confirms that noncompliances have occurred. 2. Scope This procedure applies to NOP and all accredited certifying agents and certified operations. 3. Background The National Organic Program (NOP) was establishes as a result of the OFPA. The NOP develops, implements, and administers national production, handling, and labeling standards for organic agricultural products. It accredits certifying t.gents (foreign and domestic) who inspect organic production and handling operations to certify that they meet USDA standards. It enforces organic production, handling, and labeling standards. In carrying out its mission, the NOP and its accredited certifying agents take a variety of actions to enforce compliance with the Act and its related regulations. 4. Policy 4.1 General NOP enforcement actions include the following: 1. Notice of Denial 2. Combined Notice of Noncompliance and Denial 3. Notice of Noncompliance 4. Notice of Proposed Suspension or Revocation 5. Combined Notice of Noncompliance and Proposed Suspension/Revocation 6. Notice of Suspension or Revocation 7. Consent Decree or Settlement Agreement 8. Cease -and -Desist Letter 9. Civil Penalty Generally, the recipients of enforcement actions fall into three groups: (1) certified operations (including new and renewal applicants); (2) accredited certifying agents; and (3) uncertified Original Issue Date: 04/23/10 Authorized Distribution: Public File Name: NOP 4002 Enforcement Practices Internal Rev° 1 07 22 11 United States Department of Agriculture 1400 Independence Avenue SW. Agricultural Marketing Service Room 2646 -South Building National Organic Program Washington„ DC 20250 NOP 4002 Effective Date: July 22. 201 1 Page 2 of 9 operations (not applicants). The following table illustrates the enforcement actions as they apply to the three groups. Applicant For Cenifie-anon Certified Operation Accredited Cervi tying Agents Uncertified Operation Notice of Notice of Notice of Combined mice of Consent Decree Cease -and -Desist C it i1 Noncompliance Denial Proposed Not pension/ or Settlement Letter Penalty Suspension/ vocation Agreement Revocation X X X X x 1 t k X X k 4.2 Definition and Categorization of Violations Any deviation from the regulation is a violation and requires the initiation of an appropriate enforcement action to address the noncompliance. In practice, the NOP recognizes that violations have various degrees of severity, incur different consequences, and are treated differently. The following definitions and distinctions provide guidelines for the NOP in determining the different types of enforcement actions to take under different circumstances. I. Willful violation: An intentional violation of the Act or plain indifference to its requirements. 2. Minor Noncompliance: A violation that is correctable, does not affect the integrity of the organic system or the organic product, and does not preclude the certification or continued certification of an otherwise qualified organic producer or handler. Examples of a "minor noncompliance" include failure to submit information on time, failure to update the organic system plan, and inadequate record-keeping. Major Noncompliance: A violation of organic standards that affects the integrity of the organic system or the organic product and precludes the certification or continued certification of a producer or handler. Examples of a "major noncompliance" include the application of a prohibited substance, the commingling of organic with nonorganic products, the contamination of organic products with prohibited substances, and the failure to correct a minor noncompliance. 4. Organic integrity: The qualities of an organic product or production or handling system which are obtained through compliance with NOP requirements and which must be maintained from production through handling to the point of final sale in order for the final product to be labeled and/or marketed as organic. Original Issue Date: 04/23/10 Authorized Distribution: Public File Name: NOP 4002 Enforcement Practices Internal Rev01 07 22 11 United States Department of Agriculture Agricultural Marketing Ser -vice National Organic Program 1400 independence Avenue SW. Room 2646 -South Building Washington. DC 20250 NOP 4002 Effective Date: July 22. 2011 Page 3of9 The distinction between "minor" and "major" noncompliance is particularly relevant in the assessment of civil penalties. 5. Procedure 5.1 Enforcement Actions towards Applicants for Organic Certification: Issuance of Notices § 205.405 specifies procedures for denial of certification for applicants for organic certification. § 205.681(a) specifies certification appeals procedures. All notices (noncompliance, denial, combined notice) issued to applicants for certification shall follow procedures specified in § 205.405 and § 205.681(a). The written notification must be sent through certified mail or other service that provides for a signed receipt. 1. Notice of Noncompliance (NONC) § 205.405(a) specifies that when a certifying agency has reason to believe that an. applicant for certification is not able to comply or is not in compliance with the requirements of the regulations, the certifying agent must provide a written notification of noncompliance to the applicant. The NONC shall include: a. A description of each noncompliance; b. The facts upon which the NONC is based; and c. The date by which the applicant must rebut or correct each noncompliance and submit supporting documentation of each such correction when correction is possible. The response to the NONC is evaluated. When the corrective action or rebuttal is sufficient for the applicant to qualify for certification, an approval of certification is issued. When the corrective action or rebuttal is not sufficient, a written notice of denial of certification is issued. 2. Notice of Denial of Certification § 205.405(d) specifies that a notice of denial of certification must state: a. The reason(s) for denial; and b. The applicant's right to: i. Reapply for certification pursuant to §§ 205.401 and 205.405(e); ii. Request mediation pursuant to § 205.663 or if applicable, pursuant to a State organic program; or iii. File an appeal of the denial of certification pursuant to § 205.681 or, if applicable, to a State organic program. 3. Combined Notice of Noncompliance and Denial of Certification If a certifying agent has reason to believe that an applicant for certification has willfully made a false statement or otherwise purposefully misrepresented the applicant's operation or its compliance with certification requirements, a combined notice of noncompliance and denial of certification may be issued without first issuing a NONC. Original Issue Date: 04/23110 Authorized Distribution: Public File Name: NOP 4002 Enforcement Practices Internal Rev01 07 22 11 United States Department of Agriculture Agricultural Marketing Service National Organic Program 1400 Independence Avenue SW. Room 2646 -South Building Washington. DC 20250 NOP 4002 Effective Date: July 22. 201 1 Page 4 of 4 5.2 Enforcement Actions towards Certified Operations: Issuances of Notices All notices (noncompliance, proposed suspension or revocation, combined notice, and notice of suspension/revocation) issued to certified operations shall follow the Compliance and Appeals procedures specified in § 205.660 — 205.662, and 205.681(a). When a noncompliance is identified, written notification must be sent through certified mail or other service that provides for a signed receipt. 1. Notice of Noncompliance (NONC) § 204.662(a) specifies that when any noncompliance with the Act or regulations is found, a written notification of the noncompliance shall be sent to the certified operation. The NONC should include: a. A description of each noncompliance. b. The facts upon which the NONC is based and the relevant sections of the National Organic Standards. 7 CFR Part 205, that are in violation. c. A statement that a written response must be received that either corrects the violation. or rebuts the alleged violation. d. The timeline for responding to the NONC. Generally, a response is due within 30 days of receipt of the NONC. The timeline for responding can be changed under exceptional circumstances such as when organic integrity is threatened. e. Notification that if a written response is not received within the required time period further action, including proposed suspension or revocation of certification may ensue. The response to the NONC is evaluated. Proposed corrective actions are evaluated to determine if they will correct the violation. Additional documentation and/or inspections may be required to verify that the corrective actions have been implemented. Rebuttals are evaluated to determine if adequate information is provided to reconsider the issuance of the NONC. In the case of rebuttals, additional documentation and/or inspections may be required to verify that no violation has occurred. When it has been verified that the violation has been corrected (or the rebuttal verifies that no violation occurred), a written notification of noncompliance resolution is sent to the certified operation. 2. Notice of Proposed Suspension (NOPS) or Revocation (NOPR) of Certification Following the issuance of a NONC, when rebuttal is unsuccessful or correction of the noncompliance is not completed within the prescribed time period, a written notice of proposed suspension or revocation shall be sent. Generally speaking, a NOPS should be issued when the noncompliance is still deemed correctable. The intention of a NOPS is to give the operation some time to work on the noncompliance, achieve compliance, and be reinstated. On the other hand, a NOPR should be used when the noncompliance is deemed not correctable, due to the willful and Original Issue Date: 04/23/10 Authorized Distribution: Public File Name: NOP 4002 Enforcement Practices Internal RevOl 07 22 11 United States Department of Agriculture 1400 Independence Avenue SW. Agricultural Marketing Service Room 2646 South Building National Organic Program Washington. DC' 20250 NOP 4002 Effective Date: July 22, 2011 Page 5 of 9 egregious nature of the violation and/or subsequent impact on the organic integrity of the operation. The NOPS and NOPR include: a. The reasons for the proposed suspension or revocation; b. The facts upon which the Notice (NOPS or NOPR) is based and the relevant sections of the regulation, 7 CFR Part 205 that are in violation; c, The proposed effective date of the Suspension or Revocation of Certification (minimum of 30 days from the date of the proposed notice plus reasonable mail time); d. The proposed length of the suspension for NOPS; e. The impact of suspension or revocation on future eligibility for certification; and f. The right to request mediation pursuant to § 205.663 or to file an appeal pursuant to § 205.681, timeline for the request, and contact information. Combined Notice of Noncompliance and Proposed Suspension or Revocation (§ 205.662(c)) A combined NONC and NOPS or NOPR may be issued when correction of a noncompliance is not possible, or when the violations are egregious or willful. Examples of such violations include sale of conventional products as organic, use of prohibited substances, use of conventional feed, and denial of access to pasture. A combined notice should include the following: a. A description of the noncompliance; b. The reasons for the proposed suspension or revocation; c. The facts upon which the Notice (NOPS or NOPR) is based and the relevant sections of the National Organic Standards, 7 CFR Part 205 that are in violation; d. The proposed effective date of the Suspension or Revocation of Certification (minimum of 30 days from the date of the proposed notice plus reasonable mail time); c. The proposed length of the suspension for NOPS; f. The impact of suspension or revocation on future eligibility for certification; and g. The right to request mediation pursuant to § 205.663 or to file an appeal pursuant to § 205.681, timeline for the request, and contact information. 4. Notice of Proposed Suspension or Revocation — Willful Violations (§ 205.662(d)) When evidence of willful violation is found, a notification of proposed suspension or revocation can be issued directly without an initial notice of noncompliance. The content Original Issue Date: 04/23/10 Authorized Distribution: Public File Name: NOP 4002 Enforcement Practices Internal RcvOl 07 22 11 United States Department of Agriculture Agricultural Marketing Service National Organic Program 1400 Independence Avenue SW. Room 2646 -South Building Washington, DC 20250 NOP 4002 Effective Date: July 22. 2011 Page 6 of 9 of the notice should be similar to the items listed in the previous subsection (Combined Notice of Noncompliance and Proposed Suspension or Revocation). 5. Partial Suspension or Partial Revocation — Willful Violations or Unsuccessful Rebuttal or Correction (§ 205.662 (c) and (d)) A partial suspension may be issued by the certifying agent or State Organic Program's governing official to suspend a portion of an operation, as applicable to the noncompliance. As an example, a partial suspension may be applicable when an operation is certified for two or more areas of operation (crops, wild crops, livestock, and handling) and when one area of the operation has committed an uncorrectable violation or an unsuccessful rebuttal or correction to a noncompliance. A partial revocation may be issued as a result of a willful violation or making a false statement under the Act to the Secretary, a State organic program's governing State official, or a certifying agent (§ 205.662 (g)). A partial revocation is rarely applicable and certifying agents should consult with the NOP prior to issuing a proposed partial revocation. There are very few circumstances that would warrant a partial revocation and each case should be determined on an individual basis. 6. Notice of Suspension or Revocation (§ 205.662(e)) A written notification of suspension or revocation shall be sent when a certified operation fails to respond to the NOPS or NOPR, or Combined Notice, through request for mediation or appeal. 5.3 Appeals § 205.681 An applicant for certification may appeal a certifying agent's notice of denial of certification, and a certified operation may appeal a certifying agent's notice of proposed suspension or revocation of certification to the Agricultural Marketing Service (AMS) Administrator. When the applicant or certified operation is subject to an approved State Organic Program, the appeal must be made to the State Organic Program. 1. Dismissed Appeals Appeals are dismissed when they are untimely filed, or the issues are not appealable. 2. Sustained Appeals If the Administrator or State Organic Program sustains (agrees with) a certification applicant's or certified operation's appeal of a certifying agent's decision, the applicant will be issued organic certification, or the certified operation will continue its certification, as applicable. 3. Denied Appeals If the Administrator or State Organic Program denies (does not agree with) an appeal, the certifying agent's decision remains effective. 4. Formal Administrative Proceeding (§ 205.681(a)(2)) Original Issue Date: 04/23/10 Authorized Distribution: Public File Name: NOP 4002 Enforcement Practices Internal Rev01 07 22 11 United States Department of Agriculture 1400 Independence Avenue SW. Agricultural Marketing Service Room 2646 -South Building National Organic Program Washington. DC 20250 NOP 4002 Effective Date: July 22. 2011 Page 7 of 9 Following a denial of appeal, a formal administrative proceeding will be initiated to suspend or revoke the certification. Such proceeding shall be pursuant to the U.S. Department of Agriculture's Uniform Rules of Practice or the State organic program's rules of procedures. 5. Appeal Closures without a Decision Sometimes, appeals are closed without a decision. For example. an appeal can be closed via a stipulated agreement in lieu of issuing a decision. (Refer to the Compliance and Analysis NOP Appeals Procedures in the NOP Program Handbook or at www.ams.usda.gov/NOPAppealsProcess for further details on the appeals process.) 5.4 Levying of Civil Penalties (§ 205.662(g)) In addition to suspension or revocation, any certified operation that knowingly sells or labels a product as organic, except in accordance with the Act, shall be subject to a civil penalty of not more than $11,000 per violation. 1. The NOP will consider pursuing civil penalties when there is clear and convincing evidence that a noncompliance is both willful and major. 2. Accredited certifying agents shall refer such noncompliances to the NOP Compliance and Enforcement Division (C&E) for review and action. The referral should be accompanied with supporting documentation and should be submitted within 30 days of the verification of willful and major noncompliance. 3. The C&E will conduct review of such referrals, based on documentation submitted by the accredited certifying agents and/or appeal decisions and files. The NOP will recommend civil penalties against operations that have willful or major violations of the OFPA or the NOP regulations. 5.5 Enforcement Actions towards Accredited Certifying Agents § 205.665 specifies noncompliance procedures for certifying agents. § 205.681(b) specifies accreditation appeals procedures. When an accredited certifying agent is found to be in noncompliance with the Act, a written notification of noncompliance shall be sent to the certifying agent. All notices (noncompliance, proposed suspension or revocation, combined notice, and notice of suspension/revocation) issued to certifying agents shall follow the Compliance and Appeals procedures specified in § 205.660, 205.665. and 205.681(b). The options and progression in issuing the various notices are similar to those specified in Section 5.2. 5.6 Enforcement Actions towards Uncertified Operations § 205.100 What has to be certified. § 205.102 and§205.300 Use of the term, "Organic." Original Issue Date: 04/23/10 Authorized Distribution: Public File Name: NOP 4002 Enforcement Practices Internal RevOl 07 22 11 United States Department of Agriculture Agricultural Marketing Service National Organic Program 1400 Independence Avenue SW. Room 2646 -South Building Washington. DC 20250 NOP 4002 Effective Date: July. 22. 2011 Page 8of9 NOP regulations require that operations or portions of operations that produce or handle agricultural products that are intended to be sold, Labeled, or represented as "100 percent. organic," "organic," or "made with organic (specified ingredients or food group(s)) be certified by accredited certifying agents. Producers and handling operations that sell less than $5,000 a year in organic agricultural products are exempt from certification. They may label their products organic if they abide by the standards, but they cannot display the USDA Organic seal. The term, "organic," may only be used on labels and in labeling of raw or processed agricultural products, including ingredients, that have been produced and handled in accordance with the NOP regulations. 1. issuance of Cease -and -Desist Letters: Uncertified operations found in violation of the NOP Regulations are issued cease-and- desist letters that stop the violation and warn against future relapse. 2. Levying of Civil Penalties (§ 205.100) & 7 CFR § 3.91 § 205.100 (c) Any operation that: (1) Knowingly sells or labels a product as organic, except in accordance with the Act, shall be subject to a civil penalty of not more than §3.91(b)(1)(xxxvii) of this title (7 CFR Subtitle A Subpart 1 Adjusted Civil Monetary Penalties) per violation. § 3.91 (xxxvii) Civil penalty for knowingly labeling or selling a product as organic except in accordance with the Organic Foods Production Act of 1990, codified at 7 U.S.C. 6519(a), has a maximum of $11,000. The NOP will levy civil penalties against uncertified operations found in willful and major violations of NOP regulations. Major violations include, but are not limited to, selling conventional products as organic, selling, labeling, and representing products as organic without certification while not exempt or excluded, falsely claiming to be certified, and using USDA seal in websites and advertisements. 6. References Organic Foods Productions Act (1990 as amended) 7 U.S.C. Sec.6519, Violations of Title. (a) Misuse of Label NOP Regulations (as amended to date) 7 CFR § 205.100 What has to be certified. 7 CFR § 205.401 Application for certification. 7 CFR § 205.405 Denial of certification.... (d) A notice of denial of certification must state the reason(s) for denial and the applicant's right to; (e) An applicant for certification who has received a written notification of noncompliance or a written notice of denial of certification... Original Issue Date: 04/23/10 Authorized Distribution: Public File Name: NOP 4002 Enforcement Practices Internal Rev01 07 22 11 United States Department of Agriculture Agricultural Marketing Service National Organic Program 1400 Independence Avenue SW. Room 2646 -South Building Washington. DC 20250 NOP 4002 Effective Date: July 22, 2011 Page 9 of 9 7 CFR § 205.660 General. 7 CFR § 205.661 Investigation of certified operations. 7 CFR § 205.662 Noncompliance procedure for certified operations. 7 CFR § 205.663 Mediation. 7 CFR § 205.681 Appeals. (a) Certification appeals. Other Laws and Regulations 7 CFR §3.9I Adjusted civil monetary penalties Approved on July 22, 2011 Original Issue Date: 04/23/10 File Name: NOP 4002 Enforcement Practices Internal Rev01 07 22 11 Authorized Distribution: Public Glenn Hartmann From: Tom Peterson [tompeterson@co-asphalt.com] Sent: Wednesday, February 08, 2012 11:44 AM To: 'Damian' Cc: Glenn Hartmann Subject: FW: Rifle asphalt plant plan concerns organic farm FYI —below. Thomas Peterson, P.E., Executive Director Colorado Asphalt Pavement Association 6880 South Yosemite Ct., Suite 110 Centennial, CO 80112 (303) 741-6150 ext. 152 cell: (303) 229-6710 www.co-asphalt.com, tompetersonla,co-asphalt.com Register today for the 30 Annual Rocky Mountain Asphalt conference & Equipment Show, Feb. 22-24, 2012 www.rmaces.orE From: Mischa Popoff [mailto:mischaCiisitorganic.ca] Sent: Wednesday, February 08, 2012 7:21 AM To: Tom Peterson Subject: Rifle asphalt plant plan concerns organic farm Dear Tom: 1 grew up on an organic farm and worked for five years in the United States and Canada as an organic inspector. I'm not aware of y rules in the USDA National Organic Program that make an asphalt plant the "worst possible neighbor that an organic farm could have." The reporter of this story has been seriously misled by the organic activists he interviewed. I'm the author of a critically -acclaimed book on the organic industry which discusses red herrings like this. My work to clean up the multi -billion -dollar organic industry has been covered by Barron's, The National Post and The Packer, as well as by many highly reputable websites including American Thinker and RealClearScience, and I'd be happy to discuss this with you if you're interested. Mischa Popoff Author of is it organic? The inside story of the organic industry Some people won't like this book, but you will Osoyoos BC Canada Home: 250-495-2902 Temp: 407-238-5000 ext. 723413 www.isitorganic.ca 1 Glenn Hartmann From: Andrews, Crystal [Crystal.Andrews@ag.state.co.us] Sent: Thursday, February 09, 2012 9:38 AM To: Glenn Hartmann Subject: RE: additional Information Hi Glenn, Here's that link for you: http://www.colorado.govjcs/Satellite/Agricu Iture-Mai n/CDAG/1216022437979 You'll look at Organic Producers and the Commodities directory. Not all certified entities are listed as permission needs to be granted by the operation for listing. I also wanted to draw your attention to the NOP regulation that discusses pesticide residue and environmental residue. The link to the regulations is here: http Jecfr.gpoaccess.gov/cgi/t/text/text- idx?c=ecfr&sid=3f34f4c22f9aa8e6d9864cc2683cea02&tpl=/ecfrbrowse/Title07/7cfr205 main 02.tp1 Please take a look at Section 205.670(e) and 205.671 I'm not real clear on what the "unavoidable residual environmental contamination" would be. Perhaps the EPA is the next step. Hope this sheds some additional light on the issue. Best Regards, Crystal Andrews Organic Certification Specialist Colorado Department of Agriculture 700 Kipling Street, Ste 4000 Lakewood, CO 80215 Office 303.239.4136 Fax 303.239.4177 From: Glenn Hartmann [mailto:ghartmann@garfield-county.com] Sent: Wednesday, February 08, 2012 5:08 PM To: Andrews, Crystal Subject: RE: additional Information Hi Crystal: This is the correct email. Thanks again for your insight and expertise regarding our organic questions. You mentioned a site on your web page that lists certified organic operators in Colorado but I wasn't able to locate it. Any guidance in that regard would be most appreciated. Thanks again. Sincerely, Glenn Hartmann Garfield County Building and Planning Department From: Andrews, Crystal fmailto:Crystal.Andrewsag.state.co.us[ Sent: Wednesday, February 08, 2012 1:13 PM 1 To: Glenn Hartmann Subject: additional Information Hi Glenn, We spoke this morning and I wanted to send you additional information regarding your organic questions. Is this the correct email? Best Regards, Crystal Andrews Organic Certification Specialist Colorado Department of Agriculture 700 Kipling Street, Ste 4000 Lakewood, CO 80215 Office 303.239.4136 Fax 303.239.4177 2 STATE OF COLORADO COL ADO DEPARTMENT OF AGRICULTURE Division of Plant Industry 700 Kipling Street, Suite 4000, Lakewood, CO 80215-8000 DEPARTMENT OF Tel: (303) 239-4140 Fax: (303) 239-4177 www.colorado.gov/ag/dpi AGRICULTURE Organic Certification Program DPI.ORG.OGSCPCQ (Rev 61t1) 627 OFFICE USE ONLY - DO NOT WRITE IN THIS SPACE Reviewed by Date Organic Greenhouse/Specialty Crop Plan Certification Questionnaire ❑ I have made copies of this form and other supporting documents for my own records QUESTIONNAIRE MUST BE FULLY COMPLETED AND TYPED OR IN INK Every question must he completed for this plan to be sent to the inspector. If a question does not pertain to your operation, simply state "n/a". Attach current production map(s) detailing all areas. Other attachments include Inspection Appointment Form, Summary Statement, Field History Sheets, applicable tests for water, soil, and plant tissue and/or residue analyses, if required. Section 1: General Information Applicant/Company Name (This is what will be printed on your certificate) DBA (if applicable) Owner's Name Manager's Name Primary Contact's Name Physical Address City State Zip Code County Mailing Address City State Zip Code County Phone Fax Email Best way to contact you to complete the plan Year first certified List previous organic certification by other agencies List current organic certification by other agencies Do you understand the organic standards? Yes ❑ No ❑ Year when last complete Process Handling Questionnaire was last submitted: For re -certification, were conditions placed on your last year's certification? Yes ❑ No I. If yes, what were the conditions? Were all conditions addressed? Yes ❑ No ❑ If yes, how? Have you ever been denied certification? Yes ❑ No ❑ If yes, describe the circumstances Do you have any outstanding noncompliances? Yes ❑ No If yes, what is(are) the noncompliance(s)? CDA Organic Greenhouse/Specialty Crop Plan Ouestionnalre for Dale. Page 1 of 20 Field Numbers/ Total Acres or Square Range/House (if ft. per Crop applicable Section 2: Crop Plan Information NOP Rule 205.201(a) and 205.202(a) and (b) Please complete the table below and attach field history sheets and current maps that show all fields or Greenhouses (organic [Q], and non-organic [C]) field numbers or Greenhouse numbers, acres or sq. ft.„ crops planted, projected yields and projected total production. The acreages listing in this table must equal Field Histories and maps. 36 month history is required for all cropsflands sowed In the ground it is not applicable for container plants/crops. Attach additional sheets if needed Crop Requested for Certification Organic (0) or Non - Organic (C) Projected Yield/Acre or Sq. ft. Projected Total Production Total Acres or Sq. Ft. Organic Section 3: History and Eligibility NOP Rule 205.202(b) The NOP Rules require that to be eligible for certification, a site producing crops intended to be sold, labeled or represented as organic must have had no prohibited substances applied to it for at least 36 months preceding harvest of the crop. 1. Do you grow any plants in the ground? Yes ❑ No If no, please skip to Section 4. 2. Have you completed a three-year field history form for all sites used for organic crop production? If no, you must complete and attach a three-year field history form for these areas. 3, Have you managed all areas intended for organic crop production for 3 or more years? Yes ❑ No Yes ❑ No If no, you must attach an affidavit completed by the landowner or manager(s) of any areas not managed by you for the past 3 years. 4. Are all fields/Greenhouses requested for certification located at the main farm address listed above? Yes n No Li Complete this information for each parcel that is in a separate location from the main farm address: Field Numbers/Greenhouse Parcel Address/Legal Description No. Acres or Sq. Ft. Organic/Transitional/ Conventional 0 C Rented (R)1 Owned (0) CDA Organic Greenhouse/Specialty Crop Pian questionnaire for Dale. Page 2 of 20 D. WATER USE: ❑ None 1. For what purposes is water used on your operation: ❑ irrigation ❑ foliar sprays n washing crops ❑ greenhouse ❑ cooking ❑ cleaning organic product ❑ cooling ❑ cleaning equipment CJ other (specify): 2. Source of water: ❑ on-site wells ❑ river/creek/pond ❑ spring n municipal/county ❑ irrigation district Name of municipal / irrigation district, if applicable. Include current water tests for coliform bacteria and nitrates. 3. Type of irrigation system: drip flood ❑ overhead sprinkler , other (specify): 4. What input products (fertilizers, insecticides, etc.) are applied through the irrigation system? Inputs listed above should be listed on the Fertility Input Table on page 5. What products do you use to clean irrigation lines/nozzles? 6. is the system shared with another operator? If yes, what inputs and/or cleaning products do they use? 7. Is the system flushed between non-organic and organic use? ❑ Yes If Yes, how is the flush documented? 8. List known contaminants in water supplies in your area. Attach residue analysis and /or salinity test results if available. 9. What water contamination problems do you experience (why and where)? 10. Describe your efforts to minimize the water contamination problems listed above. ❑ none ri none U none E Yes Li No No ❑ N/A (no non-organic use) 11. Describe how you monitor the effectiveness of your water quality program. 12. How often do you conduct water quality monitoring? ❑ weekly ❑ monthly ❑ annually - as needed other (specify): CDA Or Greenhouse/Specialty Crop Plan Questionnaire for Date Page 8 of 24 NOP Rule 205.205, 20' Crop Rotation Plan (List Crop Sequence Include Green Manure, Cover Crops and Fallow) Section 7: Speciality Crop Management The NOP Rule requires a crop rotation plan that maximizes soil organic matter content, prevents weed, pest and disease problems, and manages deficient or excess plant nutrients. Your crop rotation may include sod, cover crops, green manure crops and catch crops. Producers must utilize sanitation measures to remove disease vectors, weed seeds and habitat for pests. Cultural practices, including selection of plant species and varieties adapted to site-specific conditions, must be used to enhance crop health. Approved synthetic materials on the National List 205.601 may only be used when management practices are insufficient to prevent or control problems. All weed, pest and disease inputs must be approved. A "restricted" input has specific annotations for its use. If you use a "restricted" material, you must provide evidence of how you address the annotation. A. Crop Rotation Plans E N/A: No Crops Planted in the ground (Skip to Section B) Location Where Plan is Followed Ilr l Anticipated Changes B. Weed Management Plan: 1. How do you monitor the effectiveness of your weed management program? n weed counts ❑ observation of weed types ❑ observation of crop health Q comparison of crop yields ▪ records of observations 1 counts ❑ other (specify): 2. How often do you conduct weed monitoring? n weekly ❑ monthly n annually as needed Li other (specify): 3. Rate the effectiveness of your weed management program: ✓ excellent © satisfactory needs improvement What changes do you anticipate? 4. What are your problem weeds? 5. What weed control methods do you use? ❑ crop rotation tillage n prevention of weed seed set seeding monitoring n use of fast emerging var mechanical cultivation ❑ hand weeding ® mowing ❑ livestock grazing 0 flame weeding E fallow ❑ black non -synthetic mulch 5 synthetic mulch ❑ soap -based herbicides E green manure crops E other (specify): n No weed probie n smother crops ❑ cover crops 6. Do you keep a record of how often you utilize these weed control methods, (e.g., dates and fields when you cultivate or flame weed a specific field?) ❑ Yes ❑ A MS eties 0 CDA Organic Greenhouse/Specialty Crop Plan Questionnaire for pate Page 9 of 20 7. List all weed control products used or intended for use in the current season on proposed organic fields/crops. All weed contro during the 'last 36 months must also be listed on your Field Histories. Attach labels for all inputs. Attach Additional Sheets if Needed Pest Problem Product Name (Including Formulation) inputs used ❑ Not applicable (No weed control products used) Manufacturer or Brand Name WSDA or OMR! Approved? G. Pest Management Plan: 1. How do you monitor the effectiveness of your pest management program? ❑ insect monitoring with traps ❑ observation of crop health ▪ monitoring records kept ❑ other (specify): No pest problems ❑ comparison of crop yields ❑ crop quality testing Have copies of any test results available for inspection. 2. How often do you conduct pest monitoring? ❑ weekly ❑ monthly ❑ annually ❑ as needed ❑ other (specify): 3. Rate the effectiveness of your pest management program: excellent ❑ satisfactory ❑ needs improvement What changes do you anticipate? 4. What are your problem pests? insects (list): rodents ❑ gophers I birds ❑ other animals 5. Do you work with a pest control advisor or Commercial Pest Control Company? If yes, give name: 6. What strategies do you use to control pest damage to field crops? ❑Yes ❑No ❑ None ❑ crop rotation ❑ monitoring ❑ development of habitat for natural enemies ❑ timing of planting ❑ companion planting ❑ IPM ❑ selection of plant species/varieties ❑ traps ▪ lures ❑ insect repellents ❑ release of predators/parasites of pest species ❑ physical removal ❑ use of approved products ❑ trap crops ❑ use of restricted products ❑ physical barriers ❑ hand picking ❑ animal repellents ❑ limited use of prohibited products ❑ other (specify): 7. Do you keep a record of how often you utilize these pest control methods? (e.g., dates when you scout or apply inputs to a specific field or crop)? Yes ❑ No GOA Organic Greenhouse/Specialty Crop Plan Questionnaire for Date. Page i 0 of 20 WSDA or OMR! approved? 8. List all pest control products used or intended for use in the current season on proposed organic fields 1 crops. All pest control inputs used during the last 36 months must also be listed on your Field History Sheets. Attach Additional Sheets if Needed Not applicable (No pest control products used) Pest Problem Product Name (including Formulation) Manufacturer or brand name D. Disease Management Plan: 1. Rate the effectiveness of your disease management program: Qexcellent Li satisfactory n needs improvement What changes do you anticipate? 2. How do you monitor the effectiveness of your disease management program? U soil testing ❑ observation of soil El observation of crop health ▪ comparison of crop yields ❑ tissue testing crop quality testing n limited use of prohibited products microbiological testing 7 other (specify): Have copies of any test results available for inspection. 2. How often do you conduct disease monitoring? weekly ❑ monthly ❑ annually Li as needed ❑ other (specify): 4. What are your problem crop diseases? 5. What disease prevention strategies do you use? 7 crop rotation Li plant spacing 7 use of approved materials n timing of planting © No Disease problems n none ❑ field sanitation 0 selection of plant species/varieties ❑ timing of planting/cultivating n vector management ❑ companion planting compost/tea use heat treatment 0 use of restricted materials • limited use of prohibited materials n other (specify): CDA Organic Greenhouse/Specialty Crop Plan Questionnaire for. Date. Page 11 of 20 6. List all disease management inputs used or intended for use on proposed organic fields / crops. All disease control inputs used during the last 36 months must also be listed on your Field Histories. Attach Additional Sheets if Needed n Not applicable (No weed control products used) Disease Problem Product Name (Including Formulation) Manufacturer or Brand Name WSDA or ©MRI Approved? Section 8: Maintenance of Organic Integrity NOP Rule 205.105 (a)(5) and 205.202(c) To prevent commingling and contamination, all equipment used in organic crop production must be free of non-organic crops (residues) and prohibited materials. Contamination includes risk from oil, fuel, and hydraulic fluids. Equipment used for both organic and non-organic farming must be cleaned prior to use on organic fields or crops. Keep records of equipment cleaning. A. EQUIPMENT 1. List equipment used for planting, tillage, spraying and harvesting (includes seeders, tractors, trucks, etc): n Not applicable Equipment NamefType Owned (0), Rented (R), Custom (C) CHECK (') IF USED ON BOTH ORGANIC & CONVENTIONAL HOW IS EQUIPMENT CLEANED BEFORE USE ON ORGANIC FIELDS/PRODUCTIONS? If equipment is sanitized, please indicate if clear water rinse is used L 2. Is your equipment maintained so that fuel, oil and hydraulic fluid do not leak? 3. If you use a sprayer (on organic crops or fields) List type: Do you use any seeding equipment? If yes, list the steps/procedures that are documented to show that you are maintaining organic integrity: U Yes ❑ No Did you purchase it new (N) or used (U)? Not applicable ▪ Not applicable ▪ Yes B. Harvest: NOP Rule 205.272(b)(1) and (2) require that containers, bins, and packaging materials must not contain synthetic fungicides, preservatives, or fumigants. All reusable containers must be thoroughly cleaned and pose no risk of contamination prior to use. 1. How are your organic crops harvested? ri mechanical n by hand ❑ No Harvesting. Are any organic crops custom harvested? If yes provide name and address of custom harvester: Describe steps taken to protect organic crops from commingling and contamination during harvest: No ❑ Yes E No 2. What containers are used for harvesting? E gravity wagons/boxes 0 truck boxes cardboard/waxed boxes ❑ wooden totes El plastic containers other (specify): CDA Organic Greenhouse/Specialty Crop Plan Questionnaire far: Date Page 12 of 20 Section 4: Seeds NOP Rule 205.204 The NOP Rules requires the use of organically grown seeds, unless the variety is not commercially available, except, that, organically produced seed must be used for the production of edible sprouts. Synthetic seed treatments are prohibited unless included on the National List. Genetically engineered / modified (GMO) seeds and inoculants are prohibited in organic production. The NOP Rule uses the phrase "excluded methods" to refer to GMO products. Please save all seed and inoculants labels and documentation of commercial unavailability of organic seeds. Certificates are needed for all organic seed. Please complete a Commercial Non- Availability Form if applicable LIST ALL SEEDS USED IN ORGANIC PRODUCTION: (use attachment if necessary) No seeds used n Brand Name Type of Treatment Is Seed Certified Organic? If seed is not organic you must provide documentation of attempts to source organic seed (Commercial Availability forrp�i COST IS NOT A VALID REASON TO SOURCE NON-ORGANIC SEED Section 5: Source if Seedlings and Perennial Stock NOP Rule 205.204 Annual seedlings must be produced according to organic standards. Non-organic perennial plants (planting stock) must be managed organically for at least one year prior to harvest of crop or sale of the plant as certified organic planting stock. Organic seedlings and planting stock must be used if commercially available. A. If you purchase organic seedlings 1 mushroom spawn: None purchased List Suppliers of Organic Seedlings Suppliers Certification Agent (include a copy of the suppliers current organic certificate) Mushroom growers: if you use non-organic spawn or planting stock, complete the seed non-availability form. B. If you grow organic seedlings: 1. What type and size is your greenhouse? 2. Do you raise potted plants or plant the crops directly in the ground in the greenhouse? 3. If treated wood is used in any part of your greenhouse, where is it used (which part of the structure)? 4. List all soil mix ingredients or type of growth medium (mushroom): Attach labels and have labels available for inspection. ATTACH ADDITIONAL SHEETS IF NEEDED None grown rmr- Product Name (Include formulation) Brand or .Manufacturer OMRI or WSDA Listed If restricted, List NOP Rule CDA Organic Greenhouse/Specialty Crop Pian Questionnaire for. Date. Page 3 of 20 C. Perennial Stock: (Use additional sheets if necessary) Not applicable Date Planted Plan Type Transplant Source Organic Non -Organic* Expected Harvest Date *Keep documentation of commercial unavailability. D. If you grow both organic and non-organic plants in your greenhouse: ❑ Not applicable 1. How do you separate and identify organic and non-organic growing areas? 2. How do you prevent co -mingling of organic and non-organic soil mixes during mixing and storage? 3. How do you label organic and non-organic seedlings/plants? 4. How do you prevent drift of prohibited materials through ventilation andlor watering systems? 5. How do you clean seedling containers and equipment? 6. Where do you store inputs used for non-organic production? E. Parallel and Split Production: 1. Do you grow the same crops organically and non -organically? Yes No Please list the crops which are grown both conventionally and organically: 2. Which category best describes your current operation? E 100% Organic El Predominantly Organic In Transition 0 Predominantly conventional crop production If you farm conventionally, do you plan to fully convert to 100% organic production? ❑ Yes If Yes, what is your plan and time frame for conversion to organic production? No ® N/A (no conventional production) COA Organic Greenhouse/Specialty Crop Plan Questionnaire for: Date. Page 4 of 20 3. List all fertilizers and soil amendments used for conventional production: Product Name Who Applies? Self(S) Custom(C) FieldlGreenhouses Numbers Where Applied 4. List all herbicides/pesticides used for conventional production: Product Name Who Applies? Self(S) Custom(C) El Not applicable Where Stored? (On -Farm or Off Farm; Where on Farm?) FieldlGreenhouses Numbers Where Applied n Not appli able Where Stored? (On -Farm or Off Farm; Where on Farm?) Section 6: Sail and Crop; Fertility Management k a • ; 1 1 The NOP Rule requires active management to build soil fertility, manage plant nutrients, protect natural resources, and prevent soil erosi diversified crop rotation is required. All fertility inputs must be approved. A "restricted" input refers to an approved material on the Natio that has a specific annotation for its use (see NOP Rule 205.6010)(1-8), (k) and 205.602(g) and (h). If you use a "restricted" material, you provide evidence of how you address the annotation. Under NOP Rule 205.201(a)(3), the operator must monitor fertility practices and pro to verify that the organic plan is effectively implemented. Plant and animals materials (manure, compost, and uncomposted plant materia be managed so that they do not contribute to contamination of crops, soil, and water by plant nutrients, pathogenic organisms, heavy m residues of prohibited substances. on. A Natio! A. General Information 1. How do you monitor the effectiveness of your fertility management program? Soil testing Microbiological testing Tissue testing Observation of soil ❑ Observation of crop health 0 Comparison of crop yields ® Crop quality testing other (specify) c Not appli 2 . How often do you conduct conservation monitoring? El Weekly Monthly El Annually As needed ❑ Other (specify): 3. Rate the effectiveness of your fertility management program: ❑ Excellent n Satisfactory Needs improvement 4. What changes do you anticipate in your fertility management program? 5. What are the major components of your soil and crop fertility plan? Crop rotation ❑ Soil amendments Side dressing n Foliar fertilizers n Compost Soil inoculants nOn-farm manure 111 Off -farm manure ❑ Green manure c Biodynamic preparations Incorporation of crop residues c other (specify) 6. What are your soil types? 7. What are your soil/nutrient deficiencies? Attach copies of test results. n Not appl 8. List all green manure and cover crops used: [J Not appl List must cedures Is) must etals, or cable cable cabte CDA Organic Greenhouse/SpecI Ity Crop Plan Questionnaire for Date Page 5 of 20 9. List all fertility products intended for use in the current season in organic greenhouses. All fertility inputs used during the current year and previous three years must also be listed on your Field Histories. Attach copies of labels. Product Name (including formulation) Brand Name or Manufacturer OMRI or WSDA Approved? Not applicable (no fertility inputs used) Reason for Use of Product Number o Applications Year f per Attach additional sheets if needed B. COMPOST USE L__. Not applicable (no compost used) NOP RULE §205.203(c)(2) requires that the composting process must include an initial C:N ratio of between 25:1 and 40:1 and maintenance of temperatures between 131° and 170°F for a specific number of days, depending on the method of composting. Keep a compost production record (or obtain a record from the compost supplier) to verify compliance. (If CDA cannot verify that compost which contains animal manure meets the requirements in §205.203 (c)(2) through records, it will be considered raw manure and must meet the preharvest interval when used on products for human consumption according to §205.203(c)(1).) Mushroom: manure and any nonorganic agricultural material used as a growth substrate must be composted. Compost used as a growth substrate must be produced in accordance with 205.203(c)(2). 1. Did you purchase your compost? [1 Yes No If Yes. please attach documentation from supplier stating the requirements of NOP Rule 205.203 (c)(2). If No; please complete the remaining questions in this section. 2. List all compost ingredients and additives. 3. What composting method do you use? other (specify) r in -vessel U static ❑ aerated pile windrows 4. What is the initial C:N ratio of your compost? other (specify): 5. Do you monitor temperature? ® Yes ® No 6. If yes, what temperature is maintained? 7. How long is this temperature maintained? 8. If compost is windrowed, how many times are materials turned? CDA Organic Greenhouse/Speciatty Crop Plan Questionnaire for pate Page 6 of 20 C. MANURE USE NOP RULE 205.203(c)(1) requires that raw manure must be fully composted unless applied to fields with crops not for human consumption, or incorporated into the soil 120 days prior to harvest for crops whose edible portion has direct contact with the soil, or 90 days prior to harvest for all other crops for human consumption. Mushroom: manure and any nonorganic agricultural materia! used as a growth substrate must be composted. Compost used as a growth substrate must be produced in accordance with 205.203(c)(2). 1. What forms of manure do you use? n liquid other (specify): Esemi-solid piled fully composted 2. What type of crops do you grow on soils to which manure is applied (check all that apply)? crops not used for human consumption E crops for human consumption whose edible portion has direct contact with the soil E crops for human consumption whose edible portion does not have direct contact with the soil 3. Do you monitor the temperature of your compost? If Yes, what is the maintained temperature? If Yes, how long is this temperature maintained? 4. If compost is windrowed, how may times are materials turned? pelleted Yes No n NIA 5. If you grow crops for human consumption and use uncomposted manure, complete the following table. Include manure deposited by grazing livestock. Crops Field Number/ Greenhouse Number Date Manure is Incorporated Expected Date of Harvest^ 8. What is the source of the manure you use? El on-farm ❑ off -farm ❑ both List all sources of off -farm manure List all manure ingredients/additives (bedding materials, etc.). If you use off -farm sources of manure, what are the potential contaminants (pit additives, feed additives, heavy metals, etc.) from these sources? Attach residue analysis/additive specifications of off -farm manure if available. COA Organic Greenhouse/Specialty Crop Plan Questionnaire tor Date Page 7 of 20 3. Are containers new or used? if used, what did they contain prior to organic use? 4. Are containers cleaned prior to organic crop harvesting? L Yes 5. If sanitized is a clear water rinse used? 6. Are the containers used for organic crops only? 7, What potential contamination or commingling problems do you have with harvest or transport of organic crops? No New fl Used Not applicable Yes Yes No fl None Section 9: Labeling and Product Composition NOP Rule 205.105, 205.270, 205.300 - 205.305, 205.307-205.311 The NOP Rule allows four categories of products to use the word "organic". These are "140% organic", "organic", "made with organic (specified ingredients or food group(s))", and products with less than 74% organic ingredients. The percentage of organic ingredients is calculated by dividing the total net weight or volume of combined organic ingredients by the total weight or volume of all ingredients (excluding salt and water), Products labeled "100% organic": • Must contain 100% organic ingredients. including processing aids • No ingredients may be produced using excluded methods (genetic engineering), sewage sludge, or Ionizing radiation Products labeled "organic": • Must contain at least 95% organic ingredients • Non-organic ingredients must not be commercially available in an organic form • Must not include organic and non-organic forms of the same ingredient • All synthetic ingredients and processing aids must be on the National List (as allowed). • Neither organic nor non-organic ingredients may be produced using excluded methods (genetic engineering). sewage sludge, or ionizing radiation • Refer to the National List, Section 205.605 and 205.606, to determine which non-agricultural substances and non -organically produced agricultural ingredients are allowed Products labeled "made with organic (specified ingredients or food group(s))": • Must contain at least 70% organic ingredients • Neither organic nor non-organic ingredients may be produced using excluded methods (genetic engineering), sewage sludge. or ionizing radiation • Refer to the National List, Section 205.605 and 205.606, to determine which non-agricultural substances and non -organically produced agricultural ingredients are allowed Products with less than 70% organic ingredients: • Can only identify the organic ingredients on the information panel • The term "organic" may not appear anywhere other than the information panel The NOP Rule has specific requirements for principal display panel information relating to the use of the term "organic," depending on the percentage of organic ingredients in the finished product. For all products, the organic ingredients must be identified in the ingredient information panel. Up to three ingredients or food groups may be listed on the principal display panel for products labeled as "made with organic (ingredients or food group(s))." The term "organic" may not be used to describe a non-organic ingredient in a product name. Water and salt may not be identified as "organic." The name of the certifying agent (Colorado Department of Agriculture) must be identified on the information panel below the name of the handler or distributor, preceded by the statement, "Certified organic by..." or similar phrase. The USDA seal may be used on "100% organic" or "organic" products, but not on products labeled "made with organic...." The Colorado Department of Agriculture (CDA) Organic Certification Program seal can be used on "100% organic," "'organic" or "made with organic..." (only on ingredient information panel). Products with less than 70°1 organic ingredients may not display either the USDA seal or the CDA name, seal or logo. if both seals are used, the CDA seal cannot be displayed more prominently than the USDA seal. CrDA Organ€c Greenhouse/Specialty Crop Plan Questionnaire for: rima Page 13 of 20 0 No labels are used to market any finished products PRODUCTS LABELED AS "100%a ORGANIC" (All ingredients are certified 100% organic, including processing aids) 1. List all products labeled or planned to be labeled as "100% Organic" and check appropriate boxes. THE FINISHED PRODUCT LABEL STATES "100% ORGANIC" No 100% "organic" product Name of Product (as it appears on the label) Are organic ingredients identified on the label? CDA identified on the label? CDA seal on label? USDA seal on the label? PRODUCTS LABELED AS "ORGANIC" (At least 95% certified organic ingredients) 2. List all products labeled or planned to be labeled as "Organic" and check appropriate boxes. THE FINISHED PRODUCT LABEL STATES "ORGANIC" No 95% "organic" products Name of Product (as it appears on the label) Are organic ingredients identified on the label? CDA identified on the label? CDA seal on label? USDA seal on the label? Product Profile Forms (PPF): 1 A Product Profile Form must accompany each multi ingredient finished product label. The PPF must be attached to the label to receive approval. 2. The finished product label and the PPF must match; the ingredients listed must be the same. 3. If the Product Profile Form is not complete, the finished product label will not be approved. Section 10: Cleaning, Sanitation NOP Rule 205.103, 205.270, 205.272 The NOP Rule requires that handling practices and procedures present no contamination risk to organic products from commingling with non-organic products or contact with prohibited substances. Procedures used to maintain the organic integrity of ingredients or products must be documented. Chlorine: For crop operations: direct crop contact or cleaning irrigation water applied to soil should not exceed residual chlorine materials at levels set forth by the SDWA. Chlorine materials may be used up to maximum - labeled rates for disinfecting and sanitizing equipment and tools. Rinsing is not required before equipment is used in contact with organic crops. For food handling facilities and equipment: chlorine materials may be used up to maximum - labeled rates for disinfecting and sanitizing food contact surfaces. Rinsing is not required unless mandated by the label use directions. Direct post-harvest crop or food contact (including flume water to transport fruit or vegetables, wash water in produce lines, egg or carcass washing): water is permitted to contain chlorine materials at levels approved by the FDA or the EPA. Also, certified operations should monitor the chlorine level of the final rinse water, the point which the water last contacts the organic product. The level of chlorine in the final rinse water must meet limits as set forth by the SDWA. 1. Check all cleaning methods used prior to processing or handling organic products. Q No Cleaning or Purging Occurs n Sweeping n Steam cleaning E Clean in place (GIP) n Vacuuming ❑ Compressed air ❑ Manual washing 0 Scraping n Sanitizing ® Purging of equipment 0 Soap and water 111 Other (please specify) CDA Organic Greenhouse/Specialty Crop Plan Questionnaire for Date. Page 14 of 20 Please list all cleaning andlor sanitation materials used on food contact equipment and food contact surfaces. ❑ None used Please indicate which cleanserslsanitizers will be used during handling or processing of organic food products. CleanserslSanitizers Used Where is the material used? (on what equipment or surface) Used Prior to Organic Handling or Processing? Frequency of Use Check if cleaning is documented ❑ Note: Provide labels of all products used 2. Is chlorine, calcium hypochlorite, If No, move to question 3, If Yes, what is the chlorine use ❑ Direct contact with Pre-harvest ❑ Handling Facilities chlorine dioxide, or sodium hypochlorite (BLEACH) used in wash water or flume water at your Yes for? Organic Product ❑ Irrigation System Cleaning ❑ Crop Equipment and Tool Cleaning/Sanitizing ❑ Handling Operation Equipment n Food Contact Surfaces organic product (including flume water, wash water in produce lines, egg or carcass washing) crop contact andlor for cleaning irrigation systems applied to soil, what is the amount of chorine used? crop equipment andlor tools, what is the maximum rate listed on the label? handling operation equipment, andlor food contact surfaces, what is the maximum rate listed on the label? a clean water rinse? Yes ❑ No ❑ post-harvest organic product (including flume water, wash water in produce lines, egg or carcass washing), used? follow? Yes ❑ No ❑ chlorine level of the final rinse {s at or below the level of chlorine limits set by the SWDA (4PPM)? by a potable water rinse? Yes surfaces or rinsate water for cleanertsanitizer residues? Yes used prior to processing andlor handling organic products? Yes are known to leave residues on food contact surfaces. to prevent contamination of food products if Quaternary Ammonia products are used at your facility. to prevent contamination of organic food? facility? ❑ No ❑ PPM in Direct Contact with Post-harvest a. If used for direct pre-harvest b. If used for cleaning/sanitizing c. If used for handling facilities, Does the label require d. If used for direct contact with what is the amount of chlorine Does a clean water rinse How do you monitor that the 3. Is the use of cleansers followed 4. Does your facility test food contact 5. Are Quaternary Ammonia products Note: Quaternary Ammonia products You must ensure steps are taken If Yes, what steps are taken PPM PPM PPM ❑ No ❑ No ❑ ❑ No CDA Organic Greenhouse/Specially Crop Plan Questionnaire for Date Page 15 of 20 6. Please describe how your operation ensures organic products are not contaminated by a cleanser or sanitizer at your facility. 7. Is equipment purged prior to handling or processing organic products? If Yes, please list and describe purge procedures and the quantities purged. Yes 8. Please describe how your operation documents and records cleaning, sanitation, andlor purge practices and procedures. No Section 11: Packing, Storage Containers. and Shipping Containers NOP Rule 205.270, 205.272 The NOP Rule requires that handling practices and procedures present no contamination risk to organic products from commingling with non-organic products or contact with prohibited substances. Packaging materials„ bins, and storage containers must not contain a synthetic fungicide, preservative, or fumigants. Reusable bags or containers that have been in contact with any substance in such a manner as to compromise the organic integrity unless the bag or container has been thoroughly cleaned. Procedures used to maintain the organic integrity of ingredients or products must be documented. 1. Does this facility pack organic products into retail packages or place organic products in storage or shipping containers? Yes n No n If No, move onto Section 12 If Yes, what type(s) of packaging materials or storage/shipping containers do you use? Please check all that apply n Paper Metal ▪ Other (please specify): Cardboard Wood Foil Waxed paper Plastic Aseptic Poly Synthetic fiber L] Glass U Natural fiber 2. Are all packaging materials andfor storage and shipping containers food grade? Yes No 3. Have any packaging and/or storage and shipping containers been exposed to synthetic fungicides, preservatives, or fumigants? Yes No 4. Are packaging materials and/or storage and shipping containers reused? Yes No n If Yes, please describe how organic products are protected from contamination when placed in the reused container. 5. Please describe how you identify packages or containers as organic. 6. Describe the information provided an labels of all organic products. 7. Do you use the USDA organic seal on your organic products? 8. Do you use the CDA organic seal on your organic products? 9. Is the statement "certified organic by the Colorado Department of Agriculture" on the information panel of your labels? Yes Yes —I No Yes n No n No No NIA n 10. Is all packaging and labeling equipment cleared of organic identification prior to all subsequent conventional runs? Yes CDA Organic Greenhouse/Specialty Crop Plan Questionnaire for Date Page 16 of 20 Section 12: Shipping - Outgoing Organic Products NOP Rule 205.270, 205.272 1. How do organic products leave your facility? Please check all that apply. 1=1Bins ❑ Bulk trailer ElBulk bags n Totes ❑ Drums ❑ Wholesale boxes ElRetail packages ❑ Racks/shelves n Flats ❑ Other (please specify)_ 2. What potential contamination or commingling problems do you have with the transport of organic crops? None Describe: 3. What steps are taken to protect the integrity of organic products during transport? n Dedicated organic only ❑ Use of Clean Truck Affidavits ❑ Other (please specify): ❑ Inspecting transport units prior to loading ❑ Cleaning transport units prior to loading n Letter/contract with transport company stating organic requirements 4. Please indicate what transportation or sales documents are maintained by your company. Please check all that apply. n Pallet/tote ticket ❑ B• ill of lading ❑ Purchase order 111 S• cale ticket ❑ Other (please specify): 5. Do all documents clearly identify products as organic? Sales invoice n Contracts 6. Does your company arrange outgoing product transport? If No, go to Section 15 If Yes, have transport companies been notified of organic handling requirements? How were they notified? (in writing, verbal, as part of contract requirements, etc.) ❑ Clean truck affidavit n Certificates of analysis 7. How does your company ensure outgoing transport units are cleaned prior to loading loose, bulk organic products? ❑ Not Applicable, only packaged products are shipped ❑ Other (please specify): (Have this documentation available for inspection) ❑ Clean truck/equipment affidavits Li Clean out records 8. Are organic products shipped in the same transport units as non-organic products? If Yes, please indicate what steps are taken to segregate organic products. Use of separate pallets ❑ Separate area in transport unit ❑ Other (please specify): Organic product shrink wrapped ❑ Organic product seated in impermeable containers Yes No Yes ❑ No Yes ❑ No ❑ Yes ❑ No CDA Organic Graenhouse/Specialty Crop Plan Questionnaire for Dale. Page 17 of 20 Section 13: Record Keeping System NOP Rule 205.103 NOP Rule requires that records disclose all activities and transactions of the operation, be maintained for 5 years, and demonstrate compliance with the NOP Rule. Organic products must be tracked back to the field/location where they were produced/harvested. All records must be available to view and/or copy. RECORDS: 1. Which of the following records do you keep for organic production? E field maps O machine use log(s) n field activity logs) field histories (crops grown and dates and rates of all inputs applied) n planting records (dates and seeding rates) n documentation of previous land use for rented and/or newly purchased land ninput records for soil amendments, seeds. manure, foliar sprays and pest control products (keep all labels) documentation of attempts to source organic seeds and/or planting stock U documentation of organic seedlings residue analyses of inputs (i.e.. manure sourced off -farm) compost production records ❑ monitoring records (soil tests, tissue tests, water tests, quality tests. observational) equipment cleaning records ® harvest records that show field numbers, date of harvest and harvest amounts (including custom harvest records) ® labor records storage records that show storage location, storage identification. field numbers, amounts stored. and cleaning activities E clean transport records 7 sales records (purchase order, contract. invoice, cash receipts, cash receipt journal. sales journal, etc.) E shipping records (scale ticket. dump station ticket, bill of lading) U Transaction Certificates 2. Flow long do you keep your records? If records kept fewer than 5 years explain: 3. Which of the following records do you keep for non-organic production? L field maps ❑ input records complaints to operators Not applicable (no non-organic production) n labor records ri fi• eld history sheets 0 storage records 7 sales records n h• arvest records ❑ shipping records Other (please specify): DOA Organic Gree &house/Specialty Crop Plan Questionnaire for Date Page 18 of 20 ADDITIONAL INFORMATION In the development of this questionnaire we have tried to provide an opportunity to include all items required in the organic systems plan as required in § 205.201, organic production and handling system plan. § 205.201 states that: (a) The producer or handler of a production or handling operation, except as exempt or excluded under §205.101, intending to sell, label, or represent agricultural products as "100 percent organic," "organic," or "made with organic (specified ingredients or food group(s))" must develop an organic production or handling system plan that is agreed to by the producer or handler and an accredited certifying agent. An organic system plan must meet the requirements set forth in this section for organic production or handling. An organic production or handling system plan must include: (1) A description of practices and procedures to be performed and maintained, including the frequency with which they will be performed. If through the completion of this questionnaire there are any practices or procedures that you perform that have not be described or documented include them here. (2) A list of each substance to be used as a production or handling input, indicating its composition, source, location(s) where it will be used, and documentation of commercial availability, as applicable; If through the completion of this questionnaire there are any substances that are used that have not been fisted and documented,. include them here and describe their composition, source, location where used and documentation of commercial availability if applicable. (3) A description of the monitoring practices and procedures to be performed and maintained, including the frequency with which they will be performed, to verify that the plan is effectively implemented: If through the completion of this questionnaire there are monitoring practices and procedures that you perform and maintain that are not listed and documented, include them here and describe the frequency they are performed. This may include how you train and monitor employees to ensure they follow appropriate practices for organic production. (4) A description of the recordkeeping system implemented to comply with the requirements established in §205.103; if during the completion of this questionnaire there are recordkeeping items that have not been described and documented that should be to comply with the recordkeeping keeping requirements in §205.103, make sure they are included here. (5) A description of the management practices and physical barriers established to prevent commingling of organic and non-organic products on a split operation and to prevent contact of organic production and handling operations and products with prohibited substances; if any management practices or physical barriers have not been described include them here. (6) include any additional information that will help the Colorado Department of Agriculture determine if your operation meets the NOP rules. Attach additional sheets if this is needed. GDA Organic Greenhouse&Speciafy Crop Plan Questionnaire for I' Page 19 of 20 Section 14: Affirmation I affirm that all statements made in this application are true and correct. No prohibited products have been applied to any of my organically managed fields during the three-year period prior to projected harvest. I understand that the operation may be subject to unannounced inspection and/or sampling for residues at any time as deemed appropriate to ensure compliance with the NOP Rules. I understand that acceptance of this form in no way implies granting of certification by the Colorado Department of Agriculture. I agree to follow all the applicable organic standards set forth in the National Organic Program regulations, 7 CFR Part 205. Signature of Operator: Date: The business is operating as a: • Sole Proprietorship Partnership ▪ Corporation Date Incorporated: ▪ Other Describe: List the person(s) authorized to receive and accept service of summons and legal notices of all kinds for the applicant in the state of Colorado. Name Title. Complete Address have attached the following additional documents: E Notices of non-compliance or denial of certification from other certifying agencies (Required) Description of corrective actions taken regarding previous non -compliances) and evidence of such actions 111 Maps of all parcels/fields (showing adjoining land use. buffers and field identification) • Field history sheets (with letter of three-year history for fields owned or rented for less than three years) ri Documentation of fields owned or rented for less than three years. if applicable n Water test, if applicable F Soil and/or plant tissue tests, if applicable U Residue analyses, if applicable I l Input product labels. if applicable n Organic product labels, if applicable Inspection Appointment Form with directions to inspection location • Other (please list): Submit completed application, fees and supporting documentation to: COLORADO DEPARTMENT OF AGRICULTURE Division of Plant Industry 700 Kipling Street, Suite 4000 Lakewood, Colorado 80215-8000 CDA Organic GreenhouselSpeciatty Crop Plan Questionnaire for Date Page 20 of 20 Electronic Code of Federal Regulations: Page 1 of 2 Home Page > Executive Branch > Code of Federal Regulations > Electronic Code of Federal Regulations Electronic Code of Federal Regulations • TM e -CFR Data is current as of February 7, 2012 Title 7: Agriculture PART 205—NATIONAL ORGANIC PROGRAM Subpart G—Administrative Inspection and Testing, Reporting, and Exclusion from Sale Browse Next § 205.670 Inspection and testing of agricultural product to be sold or labeled "organic." (a) All agricultural products that are to be sold, labeled, or represented as "100 percent organic," "organic," or "made with organic (specified ingredients or food group(s))" must be made accessible by certified organic production or handling operations for examination by the Administrator, the applicable State organic program's governing State official, or the certifying agent. (b) The Administrator, applicable State organic program's governing State official, or the certifying agent may require preharvest or postharvest testing of any agricultural input used or agricultural product to be sold, labeled, or represented as "100 percent organic,' "organic," or "made with organic (specified ingredients or food group(s))" when there is reason to believe that the agricultural input or product has come into contact with a prohibited substance or has been produced using excluded methods. Such tests must be conducted by the applicable State organic program's governing State official or the certifying agent at the official's or certifying agent's own expense. (c) The preharvest or postharvest tissue test sample collection pursuant to paragraph (b) of this section must be performed by an inspector representing the Administrator, applicable State organic program's governing State official, or certifying agent. Sample integrity must be maintained throughout the chain of custody, and residue testing must be performed in an accredited laboratory. Chemical analysis must be made in accordance with the methods described in the most current edition of the Official Methods of Analysis of the ADAC International or other current applicable validated methodology determining the presence of contaminants in agricultural products, (d) Results of all analyses and tests performed under this section: (1) Must be promptly provided to the Administrator; Except, That, where a State organic program exists, all test results and analyses shall be provided to the State organic program's governing State official by the applicable certifying party that requested testing; and (2) Will be available for public access, unless the testing is part of an ongoing compliance investigation. (e) If test results indicate a specific agricultural product contains pesticide residues or environmental contaminants that exceed the Food and Drug Administration's or the Environmental Protection Agency's regulatory tolerences, the certifying agent must promptly report such data to the Federal health agency whose regulatory tolerance or action level has been exceeded. Browse Next For questions or comments regarding e -CFR editorial content, features, or design. email ecrrnara qov. http://ec fr. gpoaccess.gov/cgi/tltext/text-idx?c=ecfr&sid=e f73 6667ef2d 7a3 9 fdOd2c45a3 c 77d... 2/9/2012 Electronic Code of Federal Regulations: Page 1 of 1 Home Page' Executive Branch > Code or Federal Regulations a Electronic Code of Federal Regulations Electronic Code of;Federal Regulations e -CFR TM e -CFR Data is current as of February 9, 2012 Title 7: Agriculture PART 205—NATIONAL ORGANIC PROGRAM Subpart G—Administrative Inspection and Testing, Reporting. and Exclusion from Sale Browse Previous I Browse Next § 2O5.671 Exclusion from organic sale. When residue testing detects prohibited substances at levels that are greater than 5 percent of the Environmental Protection Agency's tolerance for the specific residue detected or unavoidable residual environmental contamination, the agricultural product must not be sold, labeled, or represented as organically produced. The Administrator, the applicable State organic program's governing State official, or the certifying agent may conduct an investigation of the certified operation to determine the cause of the prohibited substance. Browse Previous I Browse Next For questions or comments regarding a -CFR editorial content, features, or design, email ecfr@nara goy. For questions concerning e -CFR programming and delivery issues, email webteam [,goo goy, Section 508 1 Accessibility http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=Oece81 c 107b45cb 12b77f85b3e8a... 2/13/2012 United States Office Of Air Quality EPA -4541R -O0-019 Environmental Protection Planning And Standards December 2000 Agency Research Triangle Park, NC 27711 Air %lir, EPA HOT MIX ASPHALT PLANTS EMISSION ASSESSMENT REPORT EPA 454/R-00-019 HOT MIX ASPHALT PLANTS EMISSION ASSESSMENT REPORT This document was prepared by: Emissions Monitoring and Analysis Division Office of Air Quality Planning and Standards United States Environmental Protection Agency Research Triangle Park, NC and under contract, by: Midwest Research Institute Kansas City, MO and Cary, NC EPA Contract Number 68D-98-027 and Eastern Research Group, Inc. 1600 Perimeter Park P.O. Box 2010 Moorisville, NC EPA Contract Number 68-D7-0068 U.S. ENVIRONMENTAL PROTECTION AGENCY Office of Air and Radiation Office of Air Quality Planning and Standards Research Triangle Park, North Carolina 27711 December 2000 This page intentionally left blank. This page intentionally left blank. PREFACE This report was produced by the Source Measurement Technology Group of EPA's Emissions Measurement Center located in Research Triangle Park, NC. It is one of a series of twelve reports prepared to document an EPA program to characterize emissions to the air from hot mix asphalt plants. These twelve reports and their associated EPA document numbers and publication dates are: Document Title EPA Document Number Publication Date Hot Mix Asphalt Plants Emission Assessment Report EPA 4541R-00-019 December 2000 Hot Mix Asphalt Plants Kiln Dryer Stack Instrumental Methods Testing Asphalt Plant A, Cary, North Carolina EPA 454/R-00-020 April 2000 Hot Mix Asphalt Plants Kiln Dryer Stack Manual Methods Testing Asphalt Plant A, Cary, North Carolina Volume 1 of 2 Volume 2 of 2 EPA 4541R-00-021 a EPA 454/R -00-021b April 2000 April 2000 Hot Mix Asphalt Plants Kiln Dryer Stack instrumental Methods Testing Asphalt Plant B, Clayton, North Carolina EPA 45418-00-022 April 2000 Hot Mix Asphalt Plants Kiln Dryer Stack Manual Methods Testing Asphalt Plant B, Clayton, North Carolina Volume 1 oft Volume 2 of 2 EPA 4541R -00-023a EPA 4541R -00-023b April 2000 April 2000 Hot Mix Asphalt Plants Truck Loading and Silo Filling Instrumental Methods Testing Asphalt Plant C, Los Angeles, California EPA 454/R-00-024 May 2000 Hot Mix Asphalt Plants Truck Loading and Silo Filling Manual Methods Testing Asphalt Plant C, Los Angeles, California Volume 1 of 8 Volume 2 of 8 Volume 3 of 8 Volume 4 of 8 Volume 5 of 8 Volume 6 of 8 Volume 7 of 8 Volume 8 of 8 EPA 454/R -00-025a EPA 454/R -00-025b EPA 454/R -00-025c EPA 454/R -00-025d EPA 45418-00-025e EPA 454/R -00-025f EPA 4541R -00-025g EPA 4541R -00-025h May 2000 May 2000 May 2000 May 2000 May 2000 May 2000 May 2000 May 2000 Hot Mix. Asphalt Plants Technical Systems Audit of Testing at. Asphalt Plant C Asphalt Plant C, Los Angeles, California EPA 45418-00-026 May 2000 iv Document Title EPA Document Number Publication Date Hot Mix Asphalt Plants Truck Loading Instrumental Methods Testing Asphalt Plant D, Barre, Massachusetts EPA 454/R-00-027 May 2000 Hot Mix Asphalt Plants Truck Loading Manual Methods Testing Asphalt Plant D, Barre, Massachusetts EPA 454/R-00-028 May 2000 Hot Mix Asphalt Plants Response to Comments on Testing Program for Asphalt Plants C and D EPA 45418-00-029 May 2000 Hot Mix Asphalt Plants Stakeholders Opinions Report EPA 454/R-00.030 These documents, including this Emissions Assessment Report document, are available for downloading, on CD-ROM and in paper. Downloads can be made from: http//www.epa.govittn/emeasphalt.html Copies of the CD ROM can be requested by mail at: Emission Measurement Center, MD -19 US Environmental Protection Agency Research Triangle Park, NC 27711 Paper copies of the reports can be obtained from: National Technical Information Service 5285 Port Royal Road Springfield, VA 22161 Phone orders 1-800-553-6847 or (703) 605-6000; FAX orders (703) 605-6900 http://www.ntis.gov/products/environment.htm v ACKNOWLEDGMENTS Many individuals contributed to the development of this report. Ron Myers of the Emission Measurement Center's Source Measurement Technology Group (SMTG), Brian Shrager, Scott Klamm, Richard Marinshaw, and Amy Marshall of Midwest Research Institute (MRI), are the primary authors of the report. Bob McConnell of EPA's Region l office, David Mobley, Acting Director of EPA's Emissions Monitoring and Analysis Division, Bill Lamason, Mike Toney, Gary McAlister, and Candace Sorrell of EPA's Emission Measurement Center, Ron Ryan and Dennis Beauregard of EPA's Emission Factor and Inventory Group, Laura Autry of EPA's Air Quality Trends Analysis Group, participated in the review. We also acknowledge the contributions of numerous reviewers and advisors from PES, MRI and EPA. vi LIST OF TABLES Number Page 1. ESTIMATED ANNUAL EMISSIONS FOR A TYPICAL BATCH MIX HMA FACILITY 6 2. ESTIMATED ANNUAL EMISSIONS FOR A TYPICAL DRUM MIX HMA FACILITY 7 3. MATRIX OF EMISSION FACTORS DEVELOPED FOR HMA SOURCES .... 17 4. LOCATIONS OF SUPPORTING DATA FOR EMISSION FACTORS 18 5. ESTIMATED ANNUAL EMISSIONS FOR A TYPICAL BATCH MIX PLANT DRYER, HOT SCREENS, AND MIXER 19 6. ESTIMATED ANNUAL EMISSIONS FOR TYPICAL BATCH MIX PLANT LOAD -OUT OPERATIONS 20 7. ESTIMATED ANNUAL EMISSIONS FOR TYPICAL BATCH MIX PLANT ASPHALT STORAGE TANK 21 8. ESTIMATED ANNUAL EMISSIONS FOR A TYPICAL DRUM MIX DRYER 22 9. ESTIMATED ANNUAL EMISSIONS FOR TYPICAL DRUM MIX PLANT LOAD -OUT OPERATIONS 23 10. ESTIMATED ANNUAL EMISSIONS FOR TYPICAL DRUM MIX PLANT SILO FILLING OPERATIONS 24 11. ESTIMATED ANNUAL EMISSIONS FOR TYPICAL DRUM MIX PLANT ASPHALT STORAGE TANK 25 12. ESTIMATED ANNUAL YARD VOC EMISSIONS FOR TYPICAL BATCH MIX AND DRUM MIX HMA PLANTS 26 Viii This page intentionally left blank. DISCLAIMER The information in this document has been funded by the Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency (EPA) under contract 68-D-98-027 to Midwest Research Institute and under contract 68-D-70-068 to Eastern Research Group, Inc. The EPA has made additions and revisions to the information submitted by the contractors. This final report has been subjected to the Agency's review, and it has been approved for publication as an EPA document. Mention of trade names or commercial products is not intended to constitute endorsement or recommendation for use. iii TABLE OF CONTENTS Page 1. EXECUTIVE SUMMARY 1 1.1 INTRODUCTION 1.2 OVERVIEW OF HMA INDUSTRY 1.3 DEVELOPMENT AND USE OF EMISSION FACTORS FOR HMA FACILITIES 1 1,4 ESTIMATED ANNUAL EMISSIONS FROM TYPICAL HMA FACILITIES 2 2. ASSESSMENT OF HOT MIX ASPHALT EMISSIONS 9 2.1 INDUSTRY OVERVIEW AND PROCESS DESCRIPTION 9 2.1.1 Batch Mix Plants 9 2.1.2 Drum Mix Plants 10 2.1.3 Recycle Processes 10 2.1.4 Emissions and Controls 11 2.2 EMISSION FACTOR DEVELOPMENT FOR AP -42 SECTION 11.1, HOT MIX ASPHALT PLANTS 11 2.2.1 Batch Mix and Drum Mix Dryers 12 2.2.2 Hot Oil Heaters 13 2.2.3 Truck Load -Out 13 2.2.4 Silo Filling 14 2.2.5 Asphalt Storage Tanks 14 2.2.6 Yard Emissions 14 2.3 OTHER APPLICABLE AP -42 SECTIONS 15 2.4 EMISSION INVENTORY FOR TYPICAL HOT MIX ASPHALT PLANTS 16 2.5 EMISSION ESTIMATES FOR TYPICAL HOT MIX ASPHALT PLANTS 16 APPENDIX A AP -42 Section 11.1, Hot Mix Asphalt Plants, December 2000 APPENDIX B Emission Factor Documentation for AP -42 Section 11.1, Hot Mix Asphalt Production, December 2000 Final Report APPENDIX C Chapter 3: Preferred and Alternative Methods for Estimating Air Emissions from Hot Mix Asphalt Plants. Emission Inventory Improvement Program (EIIP), July 1996. LIST OF FIGURES Number Page I. General process flow diagram for batch mix asphalt plants 4 2. General process flow diagram for counter -flow drum mix asphalt plants 5 vii LIST OF ACRONYMS ASTM American Society of Testing and. Materials Btu British thermal unit CH4 methane CO carbon monoxide (as measured by EPA Method 10) CO2 carbon dioxide (as measured by EPA Method 3) EPA Environmental Protection Agency HAP hazardous air pollutant (listed in or pursuant to section 112(b) of the 1990 Clean Air Act Amendments) HMA hot mix asphalt NOx nitrogen oxides (as measured by EPA Method 7) PAH polycyclic aromatic hydrocarbon (a class of HAPs) PM particulate matter (as measured by EPA Methods 5 or 17) PM -10 particulate matter less than 10 microns in diameter PM -2.5 particulate matter less than 2.5 microns in diameter RAP reclaimed asphalt pavement RTFOT rolling thin film oven test (ASTM Method D2872-88) SCC source classification code SO2 sulfur dioxide (as measured by EPA Methods 6 or 8) SOx sulfur oxides TOC total organic compounds (as measured by EPA Method 25A) VOC volatile organic compound (refer to 40 CFR 51.100); VOC is TOC plus formaldehyde, less methane, ethane, acetone, and other chemicals listed as negligibly photochemically reactive. ix 1. EXECUTIVE SUMMARY 1.1 INTRODUCTION This report presents an assessment of emissions from hot mix asphalt (HMA) manufacturing facilities. Included in the report is a description of the manufacturing process and the emissions associated with HMA production; the procedures for developing emission factors and emission inventories for the HMA industry; and estimated annual emissions for typical HMA facilities. 1.2 OVERVIEW OF HMA INDUSTRY Hot mix asphalt is used primarily as paving material and consists of a mixture of aggregate and liquid asphalt cement, which are heated and mixed in measured quantities. Hot mix asphalt facilities can be broadly classified as either drum mix plants or batch mix plants, according to the process by which the raw materials are mixed. In a batch mix plant, the aggregate is dried first, then transferred to a mixer where it is mixed with the liquid asphalt. In a drum mix plant, a rotary dryer serves to dry the aggregate and mix it with the liquid asphalt cement. After mixing, the HMA generally is transferred to a storage bin or silo, where it is stored temporarily. From the silo, the HMA is emptied into haul trucks, which transport the material to the job site. Figure 1 presents a diagram of a typical batch mix HMA plant; a typical drum mix HMA plant is depicted in Figure 2. In 1996, approximately 500 million tons of HMA were produced at the 3,600 (estimated) active asphalt plants in the United States. Of these 3,600 plants, approximately 2,300 are batch plants, and 1,300 are drum mix plants. The total 1996 HMA production from batch and drum mix plants is estimated at about 240 million tons and 260 million tons, respectively. Based on these figures, an average batch mix plant produces approximately 100,000 tons of HMA annually, and an average drum mix plant produces about 200,000 tons of HMA per year. Natural gas fuel is used to produce 70 to 99 percent of the HMA. The remainder of the HMA is produced using oil, propane, waste oil, or other fuels. The primary emission sources associated with HMA production are the dryers. hot bins, and mixers, which emit particulate matter (PM) and a variety of gaseous pollutants. Other emission sources found at HMA plants include storage silos, which temporarily hold the HMA; truck load -out operations. in which the HMA is loaded into trucks for hauling to the job site; liquid asphalt storage tanks; hot oil heaters, which are used to heat the asphalt storage tanks; and yard emissions, which consist of fugitive emissions from the HMA in truck beds. Emissions also result from vehicular traffic on paved and unpaved roads, aggregate storage and handling operations, and vehicle exhaust. The PM emissions associated with 1 -IMA production include the criteria pollutants PM -l0 (PM less than 10 micrometers in aerodynamic diameter) and PM -2.5, hazardous air pollutant (HAP) metals, and HAP organic compounds. The gaseous emissions associated with HMA production include the criteria pollutants sulfur dioxide (SO2), nitrogen oxides (NOx), carbon monoxide (CO), and volatile organic compounds (VOC), as well as volatile HAP organic compounds. 1.3 DEVELOPMENT AND USE OF EMISSION FACTORS FOR HMA FACILITIES An emission factor relates the quantity (weight) of pollutants emitted to a unit of activity of the source. Emission factors for the HMA industry are generally determined in units of pounds of pollutant emitted per ton of HMA produced. These emission factors typically are used to estimate area -wide 1 emissions for a large number of facilities and emissions for specific facilities where source -specific emissions data are not available or where source testing is cost prohibitive. To develop emission factors for the HMA industry, data from more than 390 emission test reports and other documents on the industry were compiled and reviewed. Through a careful screening process, the documents that were determined to be unusable for emission factor development were excluded from further evaluation. The remaining reports were compiled by plant type, emission source, pollutant, and emission control. For each emission test, emission factors were calculated by dividing the measured emission rates by the HMA production rate measured at the time of the emission test. These emission factors were then grouped by source, pollutant, and control device, and an average emission factor was calculated for each group. Emission factors can be used to estimate emissions from one or more HMA facilities by multiplying the emission factor by the HMA production rate. For example, the emission factor for CO emissions from a natural gas-fired drum mix dryer is 0.13 pounds per ton (lb/ton). If the dryer produces 200,000 tons per year (ton/yr), the estimated CO emissions during that period would be: 200,000 ton/yr x 0.13 lb/ton = 26,000 lb/yr or 13 tons/yr. 1.4 ESTIMATED ANNUAL EMISSIONS FROM TYPICAL HMA FACILITIES Annual emissions for a facility can be estimated by summing up the emissions from each emission source over the course of a year. Annual emissions for a specific source can be estimated by multiplying the annual throughput or production rate for that source by its corresponding emission factors. For an HMA facility, annual emissions can be estimated by multiplying the annual HMA production rate by the emission factors for each type of source at the facility. Table 1 summarizes annual emissions for a typical HMA batch mix plant, and Table 2 summarizes annual emissions for a typical drum mix HMA plant. The estimates presented in these tables account for all of the identified emission sources at each type of facility. For both batch mix plants (Table 1) and drum mix plants (Table 2), the estimate includes emissions from the dryer/mixer, load -out operations, asphalt storage, yard (fugitive emissions from loaded trucks), diesel exhaust, paved and unpaved road dust, and aggregate processing (screening, conveyor transfer, and reclaimed asphalt pavement [RAP] crushing). Additionally, for the drum mix plant (Table 2), the estimate includes emissions from silo filling operations. Estimates are presented for criteria pollutants (pollutants for which national ambient air quality standards have been developed) and hazardous air pollutants (HAPS, as defined in section 1 12(b) of the 1990 Clean Air Act Amendments). Criteria pollutants include PM -10, VOC, CO, SO2, and NOx. Emissions for three classes of HAPs are presented in Tables 1 and 2: polycyclic aromatic hydrocarbons (PAHs), volatile organic HAPs, and metal HAPs. The emissions were estimated using the emission factors developed for the HMA industry and the following assumptions: • Dryers are fueled with natural gas or No. 2 fuel oil (estimates are presented for both types). It is estimated that between 70 and 90 percent of HMA plants use natural gas, although some HMA plants use fuel oil as an alternative to natural gas. • Dryer emissions are controlled with fabric filters. • PM emissions from load -out and silo filling are entirely PM -10. • Annual HMA production rate for a typical batch mix plant is 100,000 ton/yr. • Annual HMA production rate for a typical drum mix plant is 200,000 ton/yr. • The typical HMA plant has two 18,000 -gallon asphalt storage tanks. As indicated in Table 1, a typical batch mix plant using a No. 2 fuel oil -fired dryer emits over 74,000 1b/yr of criteria pollutants, and a typical batch mix plant using a natural gas-fired dryer emits over 2 56,000 Ib/yr of criteria pollutants, of which approximately 41,0001b/yr are CO and approximately 10,700 lb/yr are PM -10; emissions of other criteria pollutants range from about 500 to about 12,000 lb/yr. The same plant would emit about 770 lb/yr of HAPs. A typical drum mix plant using a No. 2 fuel oil -fired dryer emits about 83,000 lb/yr of criteria pollutants, and a typical drum mix plant using a natural gas-fired dryer emits around 75,000 lb/yr of criteria pollutants, of which approximately 28,000 Ib/yr are CO, about 10,000 lb/yr are VOC, and around 31,000 lb/yr are PM -10. A typical drum mix plant emits from 1,300 to 2,000 Ib/yr of HAPs, depending on the fuel used in the dryer. 3 C1 ce . a w o n I-. °- =d 2w x LL F W W 2 t 8 r Emission Points Ducted Emissions 2 .s a .E w a 0.0 00 L7 O Y'• o- W: 1 IZ� 1 '-**--+K t e ��\ BIM RI! 1 ulr0I—=_I: it rii N �4r 3cC 3-05-002-13) 4 c�] z as eta a) z 0 U 0 R3 U 1�-.. 0 Q J 1.. 0 0 eti 0 1` 441 (_L., <• 0 • J it 0 4 CC 0LUI Den J0 0 h QCt. W �d Cn < 0 .IU u I I �r'MO Mit M.. # 117 ii rrnunI Ir, I C% } Y Irt z`, 0 0J co RAP BIN & CONV } i 0 O 0 W z O c) j CC CC 0 W UJ Lr- t9z a QW <0 Emission Points. Ducted Emissions Process Fugitive Emissions Dust Emissions 0 000 0 O WI • 5 (SCC 3-05-002-12) 0 0 4C .[ cn W 0 0 0 0 J . ecS 0 U 0 0 en 0 tC E 0 G 0 0 J i CA 0 0 [IS 0 c3 L.. 0 0 CY s.. 0 N M r5 en 0 0 Q G N to eil 0 0 d 0 O 0 0 Cl 67 CCr kr) W N O ,0 0 6U1 • x N 47 N 5. 7*vr CIT L'"' - 0 as a33 a Q 0 0 - Q 20(0 v tr c 6 -- 6 r- r, O ,a Q O 6 — d N r~ r.- tiG O -- O •Tr N Q 4 PO _. kr) Nr 0 r- r- t-- - 65 J V O. Q '0 0 0 N C7 0 0 Nr - 4D 0 -- C 1 I 1D r C, ON Volatile HAPs a X Total HAPV 6 vi w oa vi 2 0 ?+ D 0 0 L "y R e. a =— O .0 cio Q 0 v -o 0 v 8 a. v c' 0 b 4 0 0 ) 0 y 4). • C.6 .C.' .0 •G 0 2 Q ¢ to j L.0 © • x . E - V nw w 6 } — r U sU T . b L'. Q W N 0 d Q • 0 i0©•— 7:6g vi'rn ^�G - . p R(0elX VI 66 0 W O ©. 0 W y l O 6) N 4: 7 N •o v 6) ._•. ^O U cCr: a4o2va ' t L DRUM MIX HMA FACILITYa TABLE 2. ESTIMATED ANNUAL EMISSIONS FOR A TYPIC Annual emissions by source, pounds per year ^'C7 OD 9 C:, C] C C C7 00 N 9 N C7 00 4.,:- i + In C 6 C7 C — CDf�O C R 4..i'-' 0 C _ O C C O O N C C7 C7 00 C CS ON C r j wt et 9 rel N eV 'I- try en ..+ N `.0 Cif 04 O _ C= r- --N 9 ,ten C V ,s7 00 tra r-, n o 59 9 00 C C 00 efl Natural gas-fired dryer` C] C %.o C G �t ,O C C a rel N C] 00 •to C 0 r if) C r- o 4 \o 0 CV .776.. 'fl .Ck Z�`" ch CD ,..0N Q r N o ,-- kr, OG to -c. of G Ti 'O (G C N Mobile sources (diesel exhaust) C CA CA C CS, — O 9 PI r 1 C `D m C V:i 1--- �N irs 0 O A. Criteria air pollutants Particulate matter less than 10 micrometers (PM -10) Volatile organic compounds (VOC) Carbon monoxide (CO) Sulfur dioxide (SOS) Nitrogen oxides (NQS) Hazardous air pollutants (HAPs) Polycyclic aromatic hydrocarbons (PAHs) Phenol Volatile HAPs Metal HAPs Total HAPs'' 7 al y 4 'n p $„ C a 1=)::4-D.15 eel p t C7 ▪ U D ) C 6 7:06 -9 O..:),"': -3 p - O --L.- W � Y d d O'er fl'4: =z2 flora' Aa- „ 6] RS cn 2 V U O Z z a u0,..OC co C ... _' of 1 'in ra rte- 7• p O G .a C _ CA GGA aq p N N E p C7 ? N • m C 71 iL C ".. �" n a u f u e.. w r This page intentionally left blank. 8 2. ASSESSMENT OF HOT MIX ASPHALT EMISSIONS This section presents the results of an assessment of emissions from HMA manufacturing. An overview of the HMA industry and process operations is provided first (Section 2.1). Section 2.2 summarizes the methodology used to develop emission factors for the HMA industry. Section 2.3 identifies other sections of AP -42 that apply to HMA plants. An overview of the process for conducting an emission inventory is presented in Section 2.4, and Section 2.5 presents estimates of annual emissions from typical HMA facilities. 2.1 INDUSTRY OVERVIEW AND PROCESS DESCRIPTION' Hot mix asphalt paving materials are a mixture of well -graded, high-quality aggregate and liquid asphalt cement, which is heated and mixed in measured quantities. The aggregate often includes RAP. Aggregate and RAP (if used) constitute over 92 percent by weight of the total mixture. Aside from the amount and grade of asphalt cement used, mix characteristics are determined by the relative amounts and types of aggregate and RAP used. A certain percentage of fine aggregate (less than 74 micrometers [um] in physical diameter) is required for the production of good quality HMA. Hot mix asphalt plants can be classified by their mixing operation as one of the following: (1) batch mix plants, (2) continuous rnix (mix outside dryer drum) plants, (3) parallel flow drum mix plants, and (4) counterflow drum mix plants. An HMA plant can be constructed as a permanent plant, a skid -mounted (easily relocated) plant, or a portable plant. All plants can have RAP processing capabilities. In 1996, approximately 500 million tons of HMA were produced at the 3,600 (estimated) active asphalt plants in the United States. Of these 3,600 plants, approximately 2,300 are batch plants, 1,000 are parallel flow drum mix plants, and 300 are counterflow drum mix plants. The total 1996 HMA production from batch and drum mix plants is estimated at about 250 million tons and 260 million tons, respectively. About 85 percent of new plants being constructed today are of the counterflow drum mix design, while batch plants and parallel flow drum mix plants account for 10 percent and 5 percent respectively. Continuous mix plants represent a very small fraction of the plants in use 00.5 percent) and, therefore, are not discussed further. While most HMA plants have the capability to use both fuel oil and natural gas, it is estimated that between 70 and 90 percent of the HMA in the U. S. is produced using natural gas. The process operations at typical batch mix and drum mix plants are described in the following paragraphs. 2.1.1 Batch Mix Plants2 Processing begins as the aggregate is hauled from onsite storage piles and is placed in the appropriate hoppers of the cold feed unit. The material is metered from the hoppers onto a conveyer belt and is transported into a rotary dryer (typically gas- or oil -fired). As the hot aggregate leaves the dryer, it drops into a bucket elevator, is transferred to a set of vibrating screens, then separated into as many as four different grades (sizes), and dropped into "hot' bins according to size, At newer facilities, RAP may be transferred to a separate heated storage bin. At the same time, Liquid asphalt cement is pumped from a heated storage tank to an asphalt bucket, where it is weighed to achieve the desired aggregate -to -asphalt cement ratio in the final mix. To control the aggregate size distribution in the final batch mix, the operator transfers material from various hot bins (and RAP bins, if used) to a weigh hopper until the desired mix 1 See Appendix A, Section 11.1.1, and Appendix B, Section 2.1, for more detailed information. 2 See Appendix A, Section 11.1.1.1, and Appendix B, Section 2.2.1, for more detailed information. 9 and weight are obtained. The aggregate from the weigh hopper is dropped into the mixer (pug mill) and dry -mixed for 6 to 10 seconds. The liquid asphalt is then dropped into the pug mill where it is mixed for an additional period of time. At older plants, RAP typically is conveyed directly to the pug mill from a storage hopper and combined with the hot aggregate. Total mixing time usually is less than 60 seconds. Then, the hot mix is conveyed to a hot storage silo or is dropped directly into a truck and hauled to the job site. Figure 1 depicts a typical batch mix plant. 2.1.2 Drum Mix Plants3 This process is a continuous mixing type process. The major difference between this process and the batch process is that the dryer is used not only to dry the material but also to mix the heated and dried aggregates with the liquid asphalt cement. In a parallel flow drum mixer, the aggregate is introduced to the drum at the burner end. As the drum rotates, the aggregate, as well as the combustion products from the burner, 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. In a counterflow drum mixer, the material flow in the drum is opposite or counterflow to the direction of exhaust gases. In addition, the liquid asphalt cement mixing zone is located behind the burner flame zone so as to remove the materials from direct contact with hot exhaust gases. After mixing, the mixture is discharged at the end of the drum and is conveyed to either a surge bin or HMA storage silos. Figure 2 illustrates a counterflow drum mix plant. In a parallel flow mixer, the exhaust gases also exit the end of the drum and pass on to the collection system. Parallel flow drum mixers have an advantage, in that mixing in the discharge end of the drum captures a substantial portion of the aggregate dust, therefore lowering the load on the downstream PM collection equipment. For this reason, most parallel flow drum mixers are followed only by primary collection equipment (usually a baghouse or venturi scrubber). However, because the mixing of aggregate and liquid asphalt cement occurs in the hot combustion product flow, organic emissions (gaseous and liquid aerosol) may be greater than in other processes. Counterflow drum mix plants likely will have organic stack emissions (gaseous and liquid aerosol) that are lower than parallel flow drum mix plants because the liquid asphalt cement, virgin aggregate, and RAP are mixed in a zone removed from the exhaust gas stream. A counterflow drum mix plant normally can process RAP at ratios up to 50 percent with little or no observed effect upon emissions. 2.1.3 Recycle Processes4 Reclaimed asphalt pavement significantly reduces the amount of new aggregate and asphalt cement needed to produce HMA. In the reclamation process, old asphalt pavement is removed from the road base. This material is then transported to the plant, and is crushed and screened to the appropriate size for further processing. The paving material then is heated and mixed with new aggregate (if applicable), and the proper amount of new asphalt cement is added to produce HMA that meets the quality requirements of the customer. 3 See Appendix A, Sections 11.1.1.2 and 11.1.1.3, and Appendix B, Sections 2.2.2 and 2.2.3, for more detailed information. 4 See Appendix A, Section 11.1.1.4, and Appendix B, Section 2.2.4, for more detailed information. 10 2.1.4 Emissions and Controls Hot mix asphalt plants have two major categories of emissions: ducted sources (those vented to the atmosphere through some type of stack, vent, or pipe), and fugitive sources (those not confined to ducts and vents but emitted directly from the source to the ambient air). Dryers are the most significant ducted sources of emissions from both batch mix and drum mix HMA plants. Emissions from these sources consist of water (as steam evaporated from the aggregate); PM; products of combustion (carbon dioxide [CO2], NOx, and sulfur oxides [SOO); CO; and small amounts of organic compounds of various species (including VOC, methane [CH4], and HAPs). The CO and organic compound emissions result from incomplete combustion of the fuel and also are released from the heated asphalt. At batch mix plants, other potential process sources include the hot -side conveying, classifying, and mixing equipment, which are vented to either the primary dust collector (along with the dryer gas) or to a separate dust collection system. These emissions are mostly aggregate dust, but they also may contain gaseous organic compounds, CO, and a fine aerosol of condensed organic particles. This organic aerosol is created by the condensation of gas into particles during cooling of organic vapors volatilized from the asphalt cement in the mixer. The amount of organic aerosol produced depends to a Targe extent on the temperature of the asphalt cement and aggregate entering the mixer. Organic vapor and its associated aerosol also are emitted directly to the atmosphere as process fugitives during truck load -out, from the bed of the truck itself during transport to the job site, and from the asphalt storage tank. Both the low molecular weight organic compounds and the higher weight organic aerosol may contain small amounts of HAP. The ducted emissions from the heated asphalt storage tanks may include gaseous and aerosol organic compounds and combustion products from the tank heater. At most HMA facilities, fabric filters are used to control emissions from dryers. Other controls used include mechanical collectors and scrubbers. Emissions from aggregate handling and transfer typically are controlled with fabric filters or scrubbers. Large diameter cyclones and settling chambers also are used as product recovery devices. The material collected in those devices is recycled back into the process. There also are a number of fugitive dust sources associated with batch mix HMA plants, including vehicular traffic generating fugitive dust on paved and unpaved roads, aggregate material handling, and other aggregate processing operations. 2.2 EMISSION FACTOR DEVELOPMENT FOR AP -42 SECTION 1 1.1, HOT MIX ASPHALT PLANTS A detailed description of how the emission factors were developed for the HMA industry is provided in Section 4 of Appendix 13. The following paragraphs summarize the methodology used. To develop emission factors for the HMA industry, data from about 390 emission test reports and other documents on the industry were compiled and reviewed (a complete list of these references is provided following Section 4 of Appendix B). The majority of these reports documented measurements of emissions from batch plant dryer/mixers and drum plant dryers. Through a careful screening process, 35 of the reports were determined to be unusable for emission factor development and were excluded from further evaluation. About 350 reports remained and were compiled by plant type, emission source, pollutant, and emission control. These emission factors were then grouped by source, pollutant, and 5 See Appendix A, Section 1 1.1.2, and Appendix B, Section 2.3, for more detailed information. 1I control device, and an average emission factor was calculated for each group. Table 3 presents a matrix of all of the sources and pollutants for which emission factors are presented in AP -42 (Appendix A). While the particulate, CO2, CO, and TOC emission factors are based on over 100 tests, most of the remaining criteria pollutant emission factors are based on between 5 and 10 tests. A few HAP emission factors are based on more than 5 tests, although the majority are based on between 2 and 5 tests. Information on the supporting data for specific emission factors and the quality rating assigned to the emission factor is included in the section or table in Appendices A and B as indicated in Table 4. Column four of Table 4 references the tables in Appendix A that present the emission factors and quality ratings. Column five of Table 4 references the paragraphs in Appendix B that discuss the basis for the emission factors developed for all of the sources and pollutants. Column six of Table 4 references the tables in Appendix B that present the emission factors and the individual data used to develop the emission factors. Generally, the amount of supporting data is typical of many AP -42 sections. However, the amount of data supporting the particulate, CO2, CO, and TOC emission factors is greater than most AP -42 sections. The following paragraphs summarize the procedures followed to develop the emission factors for HMA facilities. 2.2.1 Batch Mix and Drum Mix Drvers The usable data on batch mix and drum mix plant dryer emissions were compiled according to source type, emission control, and pollutant. Data on fuel types, the percentage of RAP used in the mix, and the process operating rate (e.g., dryer production rate) also were recorded. The quality of the emission data was evaluated with respect to the level of documentation in the report, the test methods used, the number of test runs, and any reported problems with the sampling procedures or the operation of the source during the test period. On the basis of this evaluation, data ratings of A, B, C, or D were assigned to each data set. Specific procedures used to evaluate the data are specified in Procedures for Preparing Emission Factor Documents (EPA-454IR-95-015). For each emission test, an emission factor also was calculated for each pollutant sampled. These test -specific emission factors then were grouped according to source type, emission control device, pollutant, and, in the case of combustion sources, fuel type. At this stage in the process, D -rated data sets were discarded, provided there were higher quality data available for that particular group (i.e., that specific combination of source, control, fuel, and pollutant). In addition, where there were data from multiple tests on the same specific emission source, the test -specific emission factors were averaged to yield a source -specific emission factor. In subsequent calculations, this source -specific emission factor was used. A statistical analysis of the data for batch and drum mix dryers was perforrned to determine the effects of RAP content, fuel type, production rate on emissions of several pollutants. The analysis showed no strong correlation between these parameters and emission factors. Details on the statistical analysis can be found in Section 4.3 of Appendix B. To develop emission factors, the mean of the test -specific emission factors was calculated for each of the emission factor groups discussed above. In some cases, the data for two or more groups were combined and an overall mean emission factor was calculated. For example, if the data indicated that fuel type had no apparent effect on emissions of a specific pollutant, fuel type was ignored and all of the data for that source type and pollutant were combined. The final step in developing emission factors is to assign a quality rating of A, B, C, D, or E. Quality ratings are a function primarily of the number of data points 12 from which a specific emission factor is calculated. Additional information on the rating system used is discussed in Section 3 of Appendix B. 2.2.2 Hot Oil Heaters For hot oil heaters, only a single test report for an oil -fired hot oil heater was available. The report was reviewed and the emission factors compiled using the procedures described previously. Appendix 8, Section 4.2.4.2, provides a detailed description of how these emission factors were developed. It should be noted that most hot oil heaters are gas-fired, and the emission factors developed from the available data would not necessarily be representative of gas-fired heaters. 2.2.3 Truck Load -Out Truck Toad -out emissions were developed from two emission tests sponsored by the U. S. Environmental Protection Agency (EPA) (Appendix B References 355 and 356). In designing, performing and evaluating these two tests, EPA was involved with a number of groups. The groups included citizens, State and local health agencies, State and local air pollution control agencies, and industry associations. These different groups provided input on the selection of facilities for emissions testing, the design of the test program, reviewed the individual site-specific test plans, observed emissions testing, commented on the draft test reports and provided suggestions for analysis of the data to develop emission factors. The procedures used to develop emission factors generally were the same as those described above. However, additional steps were taken to ensure the quality and consistency of the data and the representativeness and universality of the emission factors developed from the data. For example, two quality assurance scientists from Research Triangle Institute were employed to independently audit the test. These additional steps are summarized below. Detailed explanations of the methodology used are provided in Section 4.4 of Appendix B. At one of the facilities the sampling area was enclosed but did not meet EPA requirements for a total enclosure. Consequently, the capture efficiency was quantitatively estimated and the data were corrected for capture efficiency. At one facility, emissions due to diesel truck operation could not be segregated from emissions due to truck load -out. Therefore, background concentrations also were sampled. To account for background levels of various pollutants emitted from truck operation, the as -measured background concentrations were subtracted from the capture efficiency corrected load -out emission concentrations. For the most part, values were treated as zero if the background concentration exceeded the capture -efficiency -adjusted run concentration. Because the asphalt types and temperatures for the two facilities differed, adjustments also were made to normalize the emission data. To account for differences in the volatility of the liquid asphalts used, samples of asphalt were collected during the emission tests and analyzed by ASTM Method D 2872- 88, Effects of Heat and Air on a Moving Film of Asphalt (Rolling Thin Film Oven Test - RTFOT) to determine the "loss -on -heating" values for the asphalts. Additional loss -on -heating data also were obtained from several State departments of transportation laboratories in order to determine a common RTFOT value to use as a default in those situations where no historical information is available. Based upon the RTFOT data collected and the desire to select a default which encourages the use of site-specific data, a default of -0.5 percent was selected as a default value for use in the predictive emission factor equations developed from the data. 13 To account for differences in the load -out temperatures of the two facilities the data were adjusted using the Clausius-Clapeyron equation, which relates vapor pressure and temperature of a substance. This equation and the asphalt laboratory data provide a mechanism to normalize the emissions to a temperature of 325°F, which is the maximum midpoint load -out temperature recommended by the Asphalt Pavement Environmental Council's Best Practices Guide dated March 2000. Using the adjusted data and the temperature and volatility relationship described above, separate predictive emission factor equations were developed for emissions of total PM, organic PM, total organic compounds (TOC), and CO from drum mix and batch mix load -out operations. Additionally, adjusted data for a variety of HAP's were used to develop ratios of the HAP pollutant to either organic PM or TOC (speciation profiles). These speciation profiles are applicable to load -out emissions and yard emissions. 2.2.4 Silo Filling Silo filling emission factors were developed from one of the emission tests described in the previous paragraphs for load -out emissions (Appendix B Reference 355). These data also were collected and evaluated with stakeholder involvement. Additionally, the same basic methodology described in the previous paragraphs for load -out emissions was used to adjust the data on emissions from silo fulling operations. Predictive emission factor equations also were developed for total PM, organic PM, TOC, and CO. A detailed explanation of the methodology used to develop these equations is provided in Section 4.4.4 of Appendix B. Speciation profiles for silo filling emissions were also developed using the methodology described for load -out emissions. The speciation profiles from silo filling are applicable to asphalt storage tank emissions. 2.2.5 Asphalt Storage Tanks To estimate emissions from heated organic liquid storage tanks, the methodologies described in Chapter 7 of AP -42 and the TANKS software are generally used. The emissions from these types of tanks depend on the contents of the tank, the volume of gas vented, and the operating temperature range of the liquid in the tank. Emissions during the filling of these tanks (working Toss) are governed by the saturation concentration of the liquid stored in the tank and the volume of gas displaced by the addition of liquid to the tank. Emissions during other periods (breathing losses) are governed by the saturation concentration of the liquid stored in the tank and the changes in the volume of the gas caused by temperature variations. Although vapor pressure information on paving asphalt is not available to allow the use of the TANKS program without additional information, information was available from the silo filling test report to infer emissions during the filling of the asphalt storage tank and, by extension, the vapor pressure characteristics of paving asphalt at the typical operating temperatures. Using these data, input values for Antoine's equation and liquid and vapor molecular weight were developed for use with the TANKS program to calculate working and breathing losses for asphalt storage tanks. A detailed explanation of the methodology used to develop these values is presented in Section 4.4.5 of Appendix B. 2.2.6 Yard Emissions At one of the EPA -sponsored emission tests described in the previous paragraphs for load -out emissions (Appendix B Reference 355), data also were collected on Fugitive emissions from loaded trucks as they sat in the yard prior to departure for the job site. As with the other data from this reference, these data were evaluated with stakeholder involvement. The data obtained were fitted to a power function in order to develop an equation for these yard emissions as a function of time. A specific emission factor for cumulative emissions over an 8 -minute period (which represents the maximum time represented by the 14 data) was calculated using the power function equation developed from the emission data. A detailed explanation of the methodology used to develop the equations and the emission factor is provided in Section 4.4.6 of Appendix B. 2.3 OTHER APPLICABLE AP -42 SECTIONS Emission factors for other generic sources associated with HMA facilities can be found in other sections of AP -42 (http://www.epa.gov/ttn/chief/ap42/index.html). As discussed above, methodologies for estimating emissions from asphalt storage tanks can be found in Chapter 7 of AP -42. Methods for estimating fugitive dust emissions from vehicular traffic are presented in AP -42 Chapter 13 (Sections 13.2.1 and 13.2.2). Material handling emissions and storage pile emissions are addressed in AP - 42 Chapter 11 (Section 11.19.2) and Chapter 13 (Section 13.2.4). Emission factors for truck exhaust are provided in AP -42 Volume II: Mobile Sources (http:llwww.epa.govloms/ap42.htm). To calculate the material handling and mobile source emission estimates presented in Tables 1 and 2 of this report, suitable emission factors for these material handling and mobile sources were determined. The following paragraphs describe the basis for the emission factors that were used: • Receipt of new aggregate — Used equation from AP -42 Section 13.2.4, assuming an average moisture content of 1.5 percent and an average wind speed of 10 miles per hour (mph). The resulting PM -10 emission factor is 0.0041 lblton of new aggregate. The resulting PM -2.5 emission factor is 0.0013 lb/ton of new aggregate. • Transfer of aggregate from storage to conveyor belt or between conveyor belts — Used controlled emission factor from AP -42 Section 11.19.2. The PM -l0 emission factor is 0.000048 lb/ton of new aggregate. • Screening of aggregate — Used controlled emission factor from AP -42 Section 11.19.2. PM -10 emission factor is 0.00084 lb/ton of new aggregate. • RAP crushing — Used controlled tertiary crushing emission factor from AP -42 Section 11.19.2. PM -10 emission factor is 0.00059 lb/ton of new aggregate. • Paved road dust emissions — Used paved roads equation from AP -42 Section 13.2.1, assuming an average vehicle weight of 22 tons and a road silt content of 3 grams per square meter. The resulting PM -10 emission factor is 0.016 lb per vehicle mile traveled. The resulting PM -2.5 emission factor is 0.0040 Ib per vehicle mile traveled. • Unpaved road dust emissions — Used unpaved roads equation from AP -42 Section 13.2.2, assuming an average vehicle weight of 6 tons, a road silt percentage of 10 percent, a surface moisture content of 0.7 percent. The resulting PM -10 emission factor is 2.04 lb per vehicle mile traveled. The resulting PM -2.5 emission factor is 0.29 Ib per vehicle mile traveled. • Diesel exhaust emissions — Used heavy duty diesel truck emission factors for idling and for an average speed of 10 mph with a 250 brake horsepower engine. The diesel engines get 10 miles per gallon at 10 mph and bum 1 gallon per hour (gal/hr) of fuel at idle. The sulfur content of diesel fuel is 0.05 percent. At idle, the emissions factors for diesel engines are: VOC - 0.208 grams per minute (g/min) (0.00046 pound per minute [lb/min]), CO - 1.57 g/min (0.0035 Ib/min), NOx 0.917 g/min (0.0020 lb/ min), SO2 - 0.157s pounds per gallon of fuel (lblgal) (where s is fuel sulfur content) and PM - 0.043 g/min (0.000095 lb/min). When traveling at an average speed of 10 mph, the emission factors for diesel engines are: VOC - 3.18 grams per mile (g/mile) (0.0070 pounds per mile [Ib/mile]), CO - 18.82 g/mile (0.041 lb/mile), NOx - 8.50 g/mile (0.019 Ib/mile), SO2 - 0.157s lb/gal fuel (where s is fuel sulfur content), and PM - 0.1011 grams per brake horsepower hour (0.00022 pounds per horsepower hour). For organic HAP emissions - Used medium duty diesel truck emission 15 factors from article by Schauer, et. al., in Environmental Science & Technology of May 15, 1999. The volatile HAP emission factors presented were 0.084 grams per kilometer (g,/km) (0.00030 lb/mile) and 0.0016 g/km (0.0000057 lb/mile) for PAHs. The ducted and process fugitive emissions estimates presented in Tables 1, 2, 7, and 11 are based on the following additional assumptions: • 84,800 ton/yr of new aggregate for batch mix plant. • 10,000 ton/yr of recycled pavement for batch plant. • 1.25 million gallons (5,200 tons) of asphalt for batch plant. • 150,900 ton/yr of new aggregate for drum mix plant. • 40,000 ton/yr of recycled pavement for drum mix plant. • 2.5 million gallons (10,400 tons) of asphalt for drum mix plant. • Two 18,000 -gallon asphalt storage tanks. • Five open conveyor transfer points for new aggregate. • Front end loader travel over unpaved roads of 0.25 mile per ton of RAP used. • Vehicle travel over paved roads of 1.5 miles per 25 tons of HMA produced. • Vehicle idling time of 128,000 min (an average of 4 trucks in line during the average 8 -minute load -out time) for batch plant. • Vehicle idling time of 72,000 min (an average of 6 trucks in line during the average 1.5 -minute load -out time) for drum mix plant. 2.4 EMISSION INVENTORY FOR TYPICAL HOT MIX ASPHALT PLANTS To perform an emission inventory for a typical HMA plant, the first step is to identify the types of emission sources and to count the total number of each type of source. The next step is to identify the best emission estimation tools, which include: (1) facility -specific emissions test data; (2) source -specific emission factors; (3) other types of source -specific data, such as mass balance data; (4) emission factors for similar sources; (5) emission factors for sources that are believed to be somewhat similar to the source being considered; and (6) engineering estimates. After selecting appropriate emission estimation tools, activity factors, such as production rates, should be determined for each source so that emissions can be estimated for a specified period of time. The emissions over the specified period of time for each source and pollutant then are summed to complete the emission inventory. Appendix C provides more detailed information on procedures for ,performing an emission inventory at an HMA plant. 2.5 EMISSION ESTIMATES FOR TYPICAL HOT MIX ASPHALT PLANTS Tables 1 and 2 present annual estimates of emissions of criteria pollutants and HAPs for typical batch mix and drum mix HMA plants, respectively. The estimates presented in these tables account for the most significant emission sources at each type of facility. Tables 5 through 12 present more detailed annual emission estimates for typical batch and drum mix HMA plants. Table 5 summarizes the estimated emissions from a typical batch mix plant dryer, hot screens, and mixer. Included in the table are estimates for criteria pollutants as well as specific PAHs, volatile HAPs, and metal. HAPs for which emission factors were developed. Estimated annual criteria pollutant, PAH and volatile HAP emissions from typical batch mix plant load -out operations and asphalt storage tank are summarized in Tables 6 and 7. Tables 8, 9, 10, and 11 summarize the estimated annual emissions from a typical drum mix plant dryer, load -out operations, silo filling operations, and asphalt storage tank respectively. These tables includes estimates for criteria pollutants, PAI -Is, volatile HAPs, and metal HAPs for which emission factors were developed. Finally, Table 12 presents estimates of fugitive emissions from loaded trucks (yard emissions) for a typical 16 batch mix and drum mix plant. The emissions estimates presented in Tables 5 through 12 are based on the emission factors developed for the HMA industry and the following assumptions: • Batch mix plant and drum mix plant dryers are fueled with either natural gas or fuel oil. It is estimated that between 70 and 90 percent of HMA plants use natural gas, although some HMA plants use fuel oil as an alternative to natural gas. As shown in Tables 5 and 8, fuel oil -fired mixers and dryers have higher emissions of SO2, NOx, and some HAPS. • Batch mix plant dryer, hot screens, and mixer and drum mix plant dryer emissions are controlled with fabric filters. PM emissions from load -out and silo filling are entirely PM -10. (However, the organic portion of these emissions also can be assumed to be PM -2.5. Information is available in AP -42 Appendix B.l, Particle Size Distribution Data and Sized Emission Factors for Selected Sources, for categorizing the inorganic or filterable PM into PM -10 and PM -2.5 fractions.) • Average asphalt loss on heating is -0.5 percent (asphalt volatility). • Average HMA load -out temperature is 325°F. • The typical HMA plant has two asphalt storage tanks that are 50 feet long and 8 feet in diameter. It is estimated that these storage tanks require a total heating capacity of about 200,000 Btulhr, based on a heat loss of 60 Btulft2 of tank surface area. The asphalt storage tanks are kept at 325°F continuously for the five months the HMA plant operates. As a result, 720 million Btu are used to maintain the temperature of the asphalt in the storage tank. For a gas-fired hot oil heater, 720,000 ft3 of gas is combusted. For an oil -fired hot oil heater, 5,100 gallons of fuel oil are combusted. It should be noted that this fuel usage is about 3 percent of the fuel used in a typical batch mix plant and 1.6 percent of the fuel used in a typical drum mix plant. TABLE 3. MATRIX OF EMISSION FACTORS DEVELOPED FOR HMA SOURCES Plant type Source Criteria pollutants HAPS Other pollutants Batch mix Dryer, hot screens, and mixer PM -10, NOx, CO, SO2, VOC 24 organic HAPs 9 metal HAPs CO2 4 other organics 3 other metals blot oil heaters 22 organic HAPs Load -out PM, CO, VOC, 41 organic HAPs 3 other organics Yard emissions VOC 19 organic HAPs Drurn mix Dryer PM -10, NOx, CO, SO2, VOC 58 organic HAPs 11 metal HAPs CO2 15 other organics, 6 other metals Hot oil heaters 22 organic HAPs Load -out PM, CO, VOC 41 organic HAPS 3 other organics Silo filling PM, CO, VOC 28 organic HAPs 3 other organics Yard emissions VOC 19 organic HAPs 17 TABLE 4. LOCATIONS OF SUPPORTING DATA FOR EMISSION FACTORS Plant Type Source Pollutant Appendix A Table Appendix B Section Appendix B Table Batch Mix Dryer, hot screens, mixer PM -10 11.1-1, 11.1-2 4.2.4.3.1-4.2.4.3.6 4-19 CO 11.1-5 4.2.4.3.7 4-20 CO2 11.1-5 4.2.4.3.8 4-20 NOx 11.1-5 4.2.4.3.9 4-20 SO2 11.1-5 4.2.4.3.10 4-20 TOCIVOC/methane 11.1-6 4.2.4.3.11, 4.2.4.3.12 4-20 Speciated organics 11.1-9 4.2.4.3.12-4.2.4.3.15 4-22 Trace metals 1 1.1-1 1 4.2.4.3.16 4-21 Drum Mix Dryer/mixer PM -10 11.1-3, 11.1-4 4.2.4.1.1-4.2.4.1.6 4-14 CO 11.1-7 4.2.4.1.7 4-15 CO2 11.1-7 4.2.4.1.8 4-15 NOx 11.1-7 4.2.4.1.9 , 4-15 SO2 1 1.1 -7 4.2.4.1.10 4-15 TOCIVOC/methane \ 1 1.1-8 4.2.4.1.11 4-15 HCl 1 1.1-8 4.2.4.1.18 4-17 Spectated organics 1 1.1-1 0 4.2.4.1.12-4.2.4.1.15. 4.2.4.1.19 4.17 Dioxin/furans r 11.1-10 4.2.4.1.17 4-17 Trace metals 11.1-12 4.2.4.1.16 4-16 Batch or Drum Mix Hot oil heater Organic pollutants 11.1-13 4.2.4.2 4-18 Load -out PM, organic PM, TOC, CO, spectated organics 1 1.1-14 11.1-15 11.1-16 4.4.4 4-27 to 4-37, 4-43, 4-44 Silo filling PM, organic PM, TOC, CO, speciated organics 11.1-14 11.1-15 11.1-16 4.4.4 4-38 to 4-44 Asphalt storage Speciated organics 1 1.1-15 11.1-16 4.4.5 4-43, 4-44 Yard emissions Speciated organics 11.1-15 11.1-16 4.4.6 4-45, 4-46 18 TABLE 5. ESTIMATED ANNUAL EMISSIONS FOR A TYPICAL BATCH MIX PLANT DRYER, HOT SCREENS, AND MIXERa Pollutant Oil -fired dryer 1 Natural gas-fired dryer Emissions, lb/yr Criteria Pollutants PM -10 2,700 2,700 VOC 820 820 CO 40,000 40,000 SO, 8,800 460 NO, 12,000 2,500 PAHs (semi -volatile HAPs) Naphthalene 3.6 3.6 2 -Methylnaphthalene 7.1 7.1 Acenaphthene 0.090 0.090 Acenaphthylene 0.058 0.058 Anthracene 0.021 0.021 Benzo(a)anthracene 0.00046 0.00046 Benzo(a)pyrene 0.000031 0.000031 Benzo(b)fiuoranthene 0.00094 0.00094 Benzo(g,h,i)perylene 0.00005 0.00005 Benzo(k)fluoranthene 0.0013 0.0013 Chrysene 0.00038 0.00038 Dibenz(a,h)anthracene 0.0000095 0.0000095 Fluoranthene 0.016 0.016 Fluorene 0.16 0.16 Indendo(1,2,3-cd)pyrene 0.00003 0.00003 Phenanthrene 0.26 0.26 Pyrene 0.0062 0.0062 Total PA Hs 11 11 Volatile HAPs Acetaldehyde 32 32 Benzene 28 28 Ethylbenzene 220 220 Formaldehyde 74 74 Quinone 27 27 Toluene 100 100 Xylene 270 270 Total Volatile HAPS 751 751 _ Metal HAPs - Arsenic 0.046 0.046 Beryllium 0.015 0.015 Cadmium 0.061 0.061 Chromium 0.057 0.057 Lead 0.089 0.089 Manganese 0.69 0.69 Mercury 0.041 0.041 Nickel 0.3 0.3 Selenium 0.049 0.049 Total metal HAPs 1.35 1.35 Dryer, hot screens, and mixer controlled by fabric filter producing 100,000 tons of hot mix asphalt per year. Between 70 and 90 percent of HMA is produced using natural gas; most of the remaining HMA is produced using fuel oil. 19 TABLE 6. ESTIMATED ANNUAL EMISSIONS FOR TYPICAL BATCH MIX PLANT LOAD -OUT OPERATIONSa Pollutant Emissions, Ib/yr Criteria Pollutants PM -10 VOC CO 52 391 135 PAHs (semi -volatile HAPs) Acenaphthene Acenaphthylene Anthracene Benzo(a)anthracene Benzo(b)fluoranthene Benzo(k)fluoranthene Benzo(g,h, i )pery l ene Benzo(a)pyrene Benzo(e)pyrene Chrysene D i benz(a,h )anthracene Fluoranthene Fluorene Indeno(1,2,3-cd)pyrene 2 -Methylnaphthalene Naphthalene Perylene Phenanthrene Pyrene Total PAHs _ 0.089 0.0095 0.0239 0.0065 0.0026 0.00075 0.00065 0.00078 0.0027 0.035 0.00013 0.017 0.26 0.00016 0.8 i 0.43 0.0075 0.28 0.051 2.02 Other semi -volatile HAPs Phenol 0.40 Volatile HAPs Benzene Bromomethane 2-Butanone Carbon disulfide Chloroethane Chloromethane Cumene Ethylbenzene Formaldehyde n -Hexane Isooctane Methylene chloride Methyl tert-butyl ether Styrene Tetrachloroethene Toluene 1,1,1 -Trichloroethane Trichloroethene Trich loro fluorornethane m -Ip -Xylene o -Xylene Total volatile HA Ps 0.22 0.040 0.20 0.054 0.00087 0.062 0.46 1.16 0.37 0.62 0.0075 0.00 0.00 0.030 0.032 0.87 0.00 0.00 0.0054 1.70 0.33 6.18 a Uncontrolled emissions from 100,000 tons of hot mix asphalt per year. 20 TABLE 7. ESTIMATED ANNUAL EMISSIONS FOR TYPICAL BATCH MIX PLANT ASPHALT STORAGE TANKa Pollutant Emissions, Ib/yr Criteria Pollutants PM -10 VOC CO ND 32 3 PAHs (semi -volatile HAPs) Acenaphthene Acenaphthylene Anthracene Benzo(b)fluoranthene Fluoranthene Fluorene Naphthalene Phenanthrene Pyrene Total PAHs 0.0027 0.0010 0.00092 0.00051 0.00022 0.00016 0.087 0.025 0.00016 0.12 Volatile HAPs Benzene Bromomethane 2-Butanone Carbon disulfide Chloroethane Chloromethane Ethylbenzene Formaldehyde n -Hexane Isooctane Methylene chloride Phenol Styrene Toluene m -/p -Xylene o -Xylene Total volatile HAPs 0.010 0.0016 0.012 0.0051 0.0012 0.0074 0.012 140 0.032 0.000099 0.000086 0.00 0.0017 0.020 0.061 0.018 140 a Uncontrolled emissions from plant producing 100,000 tons of hot mix asphalt per year. Includes emissions from oil -fired hot oil heaters. All calculated PAH emissions and almost all of the formaldehyde emissions are from the oil -fired hot oil heater. 21 TABLE 8. ESTIMATED ANNUAL EMISSIONS FOR A TYPICAL DRUM MIX DRYERa Pollutant No. 2 fuel oil -fired dryer 1 Natural gas-fired dryer Emissions, lb/yr Criteria Pollutants PM -10 4,600 4,600 J VOC 6,400 6,400 CO 26,000 26,000 SO2 2,200 680 NO, 11,000 5,200 PAHs (semi -volatile HAPs) 2 -Methylnaphthalene 34 15 Acenaphthene 0.28 028 Acenaphthylene 4.4 1.7 Anthracene 0.62 0.044 Benzo(a)anthracene 0.042 0.042 Benzo(a)pyrene 0.0020 0.0020 Benzo(b)fluoranthene 0.020 0.020 Benzo(e)pyrene 0.022 0.022 Benzo(g,h,i)perylene 0.0080 0.0080 Benzo(k)fluoranthene 0.0082 0.0082 Chrysene 0.036 0.036 Fluoranthene 0.12 0.12 Fluorene 2.2 0.76 Indeno(1,2,3-cd)pyrene 0.0014 0.0014 Naphthalene 130 18 Perylene 0.0018 0.0018 Phenanthrene 4.6 1.5 Pyrene 0.60 0.11 I olal l'AI k 180 37 Volatile HAPs , Isooctane - 8.0 8.0 Hexane 184 180 Benzene 78 78 Ethylbenzene 48 48 Formaldehyde 620 620 Methyl chloroform 9.6 9.6 Toluene 580 30 Xylene 40 40 Total volatile HAPs 1,568 1,020 Metal HAPs Lead 3 0.12 Mercury 0.52 0.048 Antimony 0.036 0.036 Arsenic 0.11 0.11 Beryllium 0.000 0.000 Cadmium 0.082 0.082 Chromium 1.1 1.1 Manganese 1.5 1.5 Nickel 12.6 12.6 Selenium 0.070 0.070 Total metal HAPS 19 16 m Dryer controlled by fabric filter producing 200,000 tons of hot mix asphalt per year. Between 70 and 90 percent of HMA is produced using natural gas; most of the remaining HMA is produced using fuel oil. 22 TABLE 9. ESTIMATED ANNUAL EMISSIONS FOR TYPICAL DRUM MIX PLANT LOAD -OUT OPERATIONSa Pollutant I Emissions, lb/yr Criteria Pollutants PM -10 VOC CO 104 780 270 PAHs (semi -volatile HAPS) Acenaphthene 0.177 Acenaphthylene 0.0191 Anthracene 0.0477 Benzo(a)anthracene 0.013 Benzo(b)fluoranthene 0.0052 Benzo(k)fluoranthene 0.0015 Benzo(g,h,i)perylene 0.0013 Benzo(a)pyrene 0.00157 Benzo(e)pyrene 0.0053 Chrysene 0.070 Dibenz(a,h)anthracene 0.00025 Fluoranthene 0,034 Fluorene 0.53 lndeno(1,2,3-cd)pyrene 0.00032 2 -Methylnaphthalene 1.62 Naphthalene 0.85 Perylene 0.015 Phenanthrene 0.55 Pyrene 0.10 Total PA Hs 4.05 Other semi -volatile HAPS Phenol 1 0.80 Volatile HAPS Benzene 0.43 Bromomethane 0.080 2-Butanone 0.41 Carbon disulfide 0.11 Chloroethane 0.0017 Chloromethane 0.12 Cumene 0.91 Ethylbenzene 2.3 Formaldehyde 0.73 n -Hexane 1.25 Isooctane 0.015 Methylene chloride 0.00 Methyl tert-butyl ether 0.00 Styrene 0.06 Tetrachlomethene 0.064 Toluene 1.74 1,1,1 -Trichloroethane 0.00 Trich Ioroethene 0.00 Trichlorofluoromethane 0.011 m -/p -Xylene 3.40 o -Xylene 0.66 Total volatile HAPS 12.35 a Uncontrolled emissions from 200,000 tons of hot mix asphalt per year. 23 TABLE 10, ESTIMATED ANNUAL EMISSIONS FOR TYPICAL DRUM MIX PLANT SILO FILLING OPERATIONSa Pollutant 1 Emissions, lb/yr Criteria Pollutants PM -10 VOC CO 120 2,400 240 PAHs (semi -volatile HAPs) Acenaphthene 0.24 Acenaphthylene 0.0071 Anthracene 0.066 Benzo(a)anthracene 0.028 Benzo(e)pyrene 0.0048 Chrysene 0.11 Fluoranthene 1 0.076 Fluorene 0.51 2 -Methylnaphthalene 2.7 Naphthalene 0.92 Perylene 0.015 Phenanthrene 0.91 Pyrene 0.22 Total PAHs 5.8 Other semi -volatile HAPs Phenol 1 0.00 Volatile HAPs Benzene 0.78 Bromomethane 0.12 2-Butanone 0.95 Carbon disulfide 0.39 Chloroethane 0.095 Chloromethane 0.56 Ethylbenzene 0.93 Formaldehyde 17 n -Hexane 2.4 Isooctane 0.0076 Methylene chloride 0.0066 Styrene 0.13 Toluene 1.5 m -Ip -Xylene 4.6 o-Xytene 1.4 Total volatile HAPs 31 a Uncontrolled emissions from 200,000 tons of hot mix asphalt per year. 24 TABLE 11. ESTIMATED ANNUAL EMISSIONS FOR TYPICAL DRUM MIX PLANT ASPHALT STORAGE TANKa Pollutant Emissions, lb/yr Criteria Pollutants PM -10 ND VOC 64 CO _ 6 PAHs (semi -volatile HAAs) Acenaphthene 0.0027 Acenaphthylene 0.0010 Anthracene 0.00092 Benzo(b)fluoranthene 0.00051 Fluoranthene 0.00022 Fluorene 0.00016 Naphthalene 0.087 Phenanthrene 0.025 Pyrene 0.00016 Total PA Hs 0.12 Volatile HAPs Benzene 0.020 Bromomethane 0.0031 2-Butanone , 0.025 Carbon disulfide 0.010 Chloroethane 0.0025 Chloromethane 0.015 Ethylbenzene 0.024 Formaldehyde 140 n -Hexane 0.064 Isooctane 0.00020 Methylene chloride 0.00017 Phenol 0.00 Styrene 0.0035 Toluene 0.040 m -/p -Xylene 0.12 o -Xylene 0.036 Total volatile HAPs 140 a Uncontrolled emissions from plant producing 200,000 tons of hot mix asphalt per year. Includes emissions from an oil -fired hot oil heater. All of the calculated PAH emissions and almost all of the formaldehyde emissions are from the oil -fired hot oil heater. 25 TABLE 12. ESTIMATED ANNUAL YARD VOC EMISSIONS FOR TYPICAL BATCH MIX AND DRUM MIX HMA PLANTSa a Fugitive VOC emissions from loaded haul truck for eight minutes after completion of load -out. b Uncontrolled emissions from plant producing 100,000 tons of hot mix asphalt per year. c Uncontrolled emissions from plant producing 200,000 tons of hot mix asphalt per year. 26 Batch mixb Drum mixc Pollutant Emissions, lb/yr Criteria Pollutants PM -10 ND ND VOC 110 220 CO 36 72 PAHs (semi -volatile HAPs) ND ND Other semi -volatile HAPs Phenol 1 0.00 1 0.00 Volatile HAPs Benzene 0.057 0.11 l3romomethane 0.011 0.021 2-Butanone 0.054 0.11 Carbon disulfide 0.014 0.029 Chloroethane 0.00023 0.0046 Chloromethane 0.017 0.033 Cumene 0.12 0.24 Ethylbenzene 0.31 0.62 Formaldehyde 0.10 0.19 n -Hexane 0.17 0.33 Isooctane 0.0020 0.0040 Methylene chloride 0.00 0.00 Styrene 0.0080 0.016 Tetrachloroethene 0.0085 0.017 Toluene 0.23 0.46 Trichlorofluoromethane 0.0014 0.0029 m -/p -Xylene 0.45 0.90 o -Xylene 0.088 0.18 Total volatile HAPs 1.6 3.3 a Fugitive VOC emissions from loaded haul truck for eight minutes after completion of load -out. b Uncontrolled emissions from plant producing 100,000 tons of hot mix asphalt per year. c Uncontrolled emissions from plant producing 200,000 tons of hot mix asphalt per year. 26 APPENDIX A AP -42 Section 1 1.1 Hot Mix Asphalt Plants This page intentionally left blank. APPENDIX B Emission Factor Documentation for AP -42 Section 11.1 Hot Mix Asphalt Production This page intentionally left blank. APPENDIX C Chapter 3: Preferred and Alternative Methods for Estimating Air Emissions from Hot Mix Asphalt Plants Emission Inventory Improvement Program (EIIP) July 1996 This page intentionally left blank. TECHNICAL REPORT DATA (Please read Instructions on reverse before completing) 1. REPORT NO. EPA -454/R -00-0I9 2. 3. RECIPIENTS ACCESSION NO, 4. TITLE AND SUBTITLE Hot Mix Asphalt Plants Emission. Assessment Report 5 REPORT DATE December 200() b. PERFORMING ORGANIZATION CODE 7. AUTHOR(5) Ron Myers (EPA) Brian Shrager (MRI) Gary Brooks (ERG) K. PERFORMING ORGANIZATION REPORT NO. 9. PERFORMING ORGANIZATION NAME AND ADDRESS U.S. Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park, NC 27711 10, PROGRAM ELEMENT NO. 1 1. CONTRACT/GRANT NO. 68D-98 27 (MRI} 68--D7-0068 (ERG) 12. SPONSORING AGENCY NAME AND ADDRESS Office of Air Quality Planning and Standards Office of Air and Radiation U.S. Environmental Protection Agency Research Triangle Park, NC 27711 13, TYPE OF REPORT AND PERIOD COVERED 14. SPONSORING AGENCY CODE EPA/200104 15. SUPPLEMENTARY NOTES 16. ABSTRACT The United States Environmental Protection Agency (EPA) Emission Factors and Inventory Group (EFIG) is investigating the Hot Mix Asphalt industry to identify and quantify criteria and hazardous air pollutants (HAP's) emitted from kiln stacks, transport truck loading and silo filling. EFIG obtained over 300 emission tests from kiln stacks that characterize emissions of criteria pollutants and hazardous air pollutants' emissions. EFIG requested that EPA's Emission Measurement Center (EMC) conduct the required testing of the transport truck and silo filling operations. Under separate EPA contracts, Midwest Research Institute (MRI) and Pacific Environmental Services (PES) performed two emissions tests. The primary objective of the testing program was to characterize uncontrolled emissions of the criteria pollutants particulate matter (PM) and total hydrocarbons (THC) and emissions of volatile and semi -volatile organic HAP's including polycyclic organic matter, phenol, benzene, toluene, xylene, ethyl benzene, 2-butanone, cumene, formaldehyde, hexane, isooctane and others. The results of the two test reports and responses to comments on. these test reports are covered in separate EPA reports (EPA 454/R-00-024, EPA 454/R-00-025 (a through h), EPA 4541R-00-026, EPA 454/R-00-027, EPA 454/R-00-028 and EPA 454/R-00-029). This document characterizes hot mix asphalt plant operations, summarizes emissions from the typical batch mix and drum mix plants, presents emission factors specifically developed for hot mix asphalt plants and presents analyses used to develop the emission factors developed and presents information needed to inventory the emissions at hot mix asphalt plants. 17. KEY WORDS AND DOCUMENT ANALYSIS a DESCRIPTORS _ b. IDENTIFIERS/OPEN ENDED TERMS c. COSATI Field/Group Air Pollution control 18, DISTRIBUTION STATEMENT Release Unlimited 19 SECURITY CLASS ( erori) Unclassifiedi 21. NO. OF PAGES 592 20. SECURITY CLASS (Page) Unclassified 22. PRICE EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION 15 OBSOLETE This page intentionally left blank. The Asphalt Paving Industry A Global Perspective • Inifigiuction, Use, Properties, and Occupational Exposure Reduction Technologies and Trends National Asphalt Pavement Association EARA European Asphalt Pavement Association The Asphalt Paving Industry: A Global Perspective is a joint publication of the European Asphalt Pave- ment Association (EAPA) and the National Asphalt Pavement Association (NAPA). EAPA is the European industry association which represents the manufacturers of bituminous mixtures and companies engaged in asphalt road construction and maintenance. Its mission is to promote the good use of asphalt in the creation and maintenance of a sustainable European road network, EAPA represents asphalt producers in 18 countries in Europe. NAPA is the only trade association that exclusively represents the interests of the U.S. asphalt pave- ment material producer/contractor on the national level with Congress, government agencies, and other national trade and business organizations. The association, which counts more than 1,100 com- panies as its members, was founded in 1955. EAPA EUROPEAN ASPHALT PAVEMENT ASSOCIATION nue du Commerce 77 • 1040 Brussels, Belgium Tel: +32.2.502.58.88 ■ Fax: +32.2.502.23.58 www.eapa.org ■ info@eapa.org NAPA WargfAINNY NAPA Building ■ 5100 Forbes Blvd. ■ Lanham, MD 20706-4407 U.S.A. Tel: 301-731-4748 ■ Fax: 301-731-4621 Toll free 888-468-6499 ■ www.hotmix.org 2011 National Asphalt Pavement Association and European Asphalt Pavement Association. World rights reserved. This publication may not be republished or copied (including mechanical reproduction) without written consent. isBN 0-914313-06-1 Third Edition Global Series 101 Produced August 2011 The AspiiaIt Paying Inilu*q JI Global PerspectLve Third Edition 'Production, U ,'Pr.operties, rand O c mat Lona I *Expo su se &eduction technologies and 'hoods NAPA National Asphalt Pavement Association NAPA Building 5100 Forbes Boulevard Lanham, Maryland 20706-4407 U.S.A. Tel: 301-731-4748 Fax: 301-731-4621 Toll Free: 888-468-6499 www.hotmix.org EAPA European Asphalt Pavement Association Rue du Commerce 77 1040 Brussels, Belgium Tel. +32.2.502.58.88 Fax: +32.2.502.23.58 www.eapa.org info@eapa.org Contents The Asphalt Paving Industry A Global Perspective Third Edition Description of the Asphalt Paving Industry 5 Chemical and Physical Data 7 Production, Transport, and Placement of Asphalt Mixes 10 Bitumen Fume Exposure and Exposure Reduction 14 Appendix 1: Bitumen Industry Terms 21 Appendix 11: Summary European Exposure Data by Country 29 Appendix 111: Summary United States Exposure Data by Country 31 References 35 1 Description of the Asphalt Paving Industry 1.1 Introduction The asphalt paving industry is the industry segment that builds the world's asphalt motorways, highways, streets, airport runways, parking areas, driveways, coastal protection, canal linings, reservoirs, footpaths and cycle paths, and sport and play areas. In order to avoid confu- sion, the term "asphalt" as used in this document is in accord with European convention and refers to a mixture of bitumen and mineral aggregate designed for specific paving applications. Asphalt plays a vital role in global transportation infrastructure and drives economic growth and social well-being in developed as well as developing countries (Mangum, 2006). Public investment in highway, street, and bridge con- struction in Europe totals about E80 billion ($110 billion U.S.) per year. In the U.S., public investment is around E55 billion ($80 billion U.S) per year. These numbers do not include private -sector investments in streets, parking facilities, or commercial and residential facilities, and other transportation -related structures. Because of the importance of the infrastructure and the need to ensure the quality and durability of the paved facilities, the industry, in every country, must provide materials and apply production methods which result in an end -product acceptable according to the high standards set by owner agencies. According to the bitumen industry, 85 percent of all bitumen used world-wide is used in asphalt pavements, 10 percent is used for roofing, and the remaining 5 percent is used in other ways (Asphalt Institute and Eurobitume, 2008). 1.2 Asphalt End Uses In addition to the construction and maintenance of motorways and trunk roads (major highways), asphalt is also used extensively for rural roads and urban streets, airport runways and taxiways, private roads, parking areas, bridge decks, footways, cycle paths, and sports and play areas. Europe and North America have by far the most exten- sive networks ofpaved roads and highways in the world. In Europe, it is estimated that more than 90 percent of the 5,2 million km (3.2 million mi) ofpaved roads and highways are surfaced with asphalt. In the U.S., more than 92 percent of the more than 4 million km (2.5 million mi) of roads and highways are surfaced with asphalt. In addition, about 85 percent of airport runways and 85 percent of parking areas in the U.S. are surfaced with asphalt (Mangum, 2006). Canada has about 415,000 km (258,000 mi) of paved roads, and Mexico has about 178,000 km (110,000 mi). In Canada about 90 percent of roads are surfaced with asphalt, as are about 96 percent in Mexico. There are about 344,000 km (176,000 mi) of roads in Central and South America; about 64,000 km (77,000 mi) in Australia and New Zealand combined; about 1.5 million km (979,000 mi) in China; and 2.5 million km (1.3 million mi) in the rest of Asia. 1.3 Asphalt Production Statistics In 2007, the latest year for which figures are available, about 1.6 trillion metric tonnes of asphalt was produced worldwide. The chart below shows the geographic dis- tribution of production by continent. 1.4 Number of Asphalt Production Sites — Europe and U.S. Europe has about 4,000 asphalt production sites and produces about 435 million metric tonnes per year. In Europe, 90 percent of companies involved in the produc- tion and placement of asphalt can be classified as small and medium sized enterprises. Figure 1,3 Estimated World Production of Asphalt in 2007 (in rnlllron nnetrlc tonnes; ■ Africa 1 Asia ti Australia • Europe (incl. Russia) e North America • Mid America • South America 30 495 10 435 550 35 45 1600 twww.eapa.orgldelaull_news. hlm) GL 101, Third Edition 5 The U.S. also has roughly 4,000 asphalt production sites and produces about 410 million metric tonnes per year. The paving industry in the U.S. largely grew out of small, family-owned businesses. Today, there is a growing trend for the family-owned businesses in the U.S. to be acquired by larger companies, including multi -national companies operating in both the U.S. and Europe. Most countries have far fewer plants. For example, Mexico has approximately 400 asphalt plants, South Africa has 60, and New Zealand has 45. An exception is China, where 6,500 small plants collectively produce about 150 million tonnes annually (compared to 4,000 plants producing 435 million tonnes in Europe). 1.5 Number of Workers — Europe and U.S. In the U.S. and Europe the asphalt paving industry collectively employs about 400,000 workers in the manu- facture, transport, and placement of asphalt. Figures for the number of workers in other countries are not readily available. 6 GL 101, Third Edition 2 Chemical and Physical Data 2.1 Asphalt Pavement Mixes Typical Composition Asphalt pavement material typically is composed of about 95 percent mineral aggregates mixed with 5 percent paving bitumen (CAS #8052-42-4), with bitumen func- tioning as the glue that binds the mineral aggregates in a cohesive mix. Every asphalt pavement mix is designed for a specific pavement application, varying its composi- tion accordingly. The amount of paving bitumen used is typically in the range of 4 to 6 percent by weight of the asphalt mix, depending on the specifications and intended use of the pavement. 2.2 Mineral Aggregates Aggregates used for asphalt mixtures are typically comprised of crushed rock, gravel, sand, or mineral filler.. Occasionally, products from other industries, including foundry sand, blast furnace slag, and glass, may be re- cycled into asphalt pavement as aggregate. Aggregates are selected and classified according to size and other properties for a specific asphalt mix design and pavement end-use specification. 2.3 Reclaimed Asphalt Pavements Reclaimed asphalt pavement (RAP) is commonly used in the production of asphalt pavement material to replace virgin mineral aggregates and bitumen. The percentage of RAP included in an asphalt mix depends on several factors. Specifications vary in terms of the amount of RAP allowed and the particular pavement application. Percentages typically vary from 0 to about 30 percent for highway pavements, and may go as high as 60 percent for some applications. 2.4 Properties of Paving Bitumen 2.4-a Physical Properties Typically, paving bitumen is specified based upon spe- cific physical properties relating to consistency, adhesion properties, viscosity, hardness, or brittleness at a specified temperature. These attributes are important to effective asphalt pavement applications and to the resulting qual- ity and durability of the pavement. Pavement designers select particular paving bitumens that are appropriate to the climate, traffic, and other conditions in which the pavement is used. An important physical attribute is the fact that bitumen becomes softer and more fluid when heated and hardens again when cooled. This attribute allows for the mixing, placement, and compaction of the asphalt mix to form a quality asphalt pavement that can be expediently turned over to traffic. In Europe and elsewhere, paving bitumen is denoted by the permissible range of penetration value (expressed as a "pen grade," e.g. 40/60 pen grade, 100/150 pen grade), which is indicative of the consistency of the material at a temperature of 25°C. The softer the bitumen, the higher the penetration, In Europe the bitumen is standardized according to CEN (Central European Normalization) guidelines, differentiating paving grade versus other bitu- men types (hard industrial, oxidized, etc.). In the U.S. and elsewhere, a performance grade ("PG") system has been in use since the mid-1990s. Under this system, both traffic levels and climatic conditions are taken into account. For example, a PG designation of PG 64-22 represents the high and low temperatures (in terms of degrees Centigrade) at which the bitumen would be expected to perform satisfactorily. A further distinction can be made to clearly differ- entiate paving bitumen that has been subjected to mild oxidation (see, Air Rectified Bitumen) from fully oxi- dized bitumen as used in other applications (e.g; Type III built-up roofing). Using European harmonized standards and specifications EN 1426 (Penetration of Bituminous Materials) and EN 1427 (Softening Point of Bitumen), a Penetration Index ("PI") reference value is calculated. The recommended differentiation criteria are: • Air Rectified = PI 2.0 • Oxidized Bitumen = PI > 2.0 Further, oxidized bitumen requires higher temperatures to become liquid and demonstrates elastic behavior. This contrasts with paving bitumen, including those mildly oxidized, that demonstrate viscous behavior. 2.4-b Chemical Properties Bitumens are complex chemical mixtures that may be manufactured to yield very different physical and GL 101, Third Edition 7 chemical attributes. For example, paving bitumen, CAS #8052-42-4, is most commonly produced through refining of crude oil using atmospheric or vacuum distillation and sometimes mild oxidation (often referred to as air rectifica- tion or semi -blowing). Mildly oxidized bitumen, such as is sometimes used to produce semi -blown (air -rectified) paving bitumen, has physical properties similar to those of atmospheric or vacuum -distilled paving bitumen. As noted in Section 2.4a, bitumen consistency has historically been measured by standardized test procedures, e.g. penetration value, ring & ball softening point, and penetration index. While these test results point to a given set of physical properties, it is the chemical constituents of bitumen that determine its consistency. To wit, the relative proportion of asphaltenes (high molecular weight) are responsible for strength and stiffness; resins are responsible for adhesion; and oils (low molecular weight) are responsible for vis- cosity and fluidity (Wong 2001). Paving bitumens differ from oxidized bitumen or blown bitumen (CAS #64742- 93-4). Oxidized bitumen is made by passing air through bitumen at elevated temperatures in order to stiffen it and/or increase the softening point (Asphalt Institute and Eurobitume 2008). In this process, chemical reactions change the chemistry of the bitumen while increasing the material's average molecular weight. Such intense oxida- tion is not used to produce paving bitumen. 2.4-c Physical Chemistry Generation of fume and worker exposures are directly linked to the heating and cooling processes. Production of conventional asphalt pavement material is typically accomplished in the range of 140T -160T (280T -320°F) (Brown et al. 2000; Brown et al. 2009); however, spe- cialty mixtures range up to 170°C in the U.S. and up to 180°C in Europe. The asphalt mix begins to cool when it is transferred from the plant to the trucks transporting it to the pavement site, so placement temperatures are somewhat lower than production temperatures (reduc- tions at this phase of the process being around 5°C or 10°F). The quantity and nature of the fume that workers may be exposed to has also been significantly associated with other factors, such as the temperature and conditions of generation (Thayer et al. 1981, Brandt and de Groot 1985, Brandt and Molyneux 1985, Niemeier et al. 1988, Blackburn and Kriech 1990, Lien 1993, Machado et al. 1993, Kitto et al. 1997, Butler et al. 2000, Burstyn et al. 2000, Law et al. 2006, Ruhl et al. 2006, Kriech 2007, Lange et al. 2007, Ruhl et al. 2007). In the past decade, warm -mix asphalt technologies have been developed, al- lowing production temperatures to be lowered to between 100°C -140°C (2i2F-280°F) (Prowcll et al., 2011). 2.4-c Summary of Physical and Chemical Properties In summary, all bitumens are not the same. Each bitu- men is designed and produced for a specific end-use appli- cation. Beyond physical characteristics, conditions such as application temperature and other application -related factors should be considered when trying to understand and evaluate exposure potential (see also Chapter 4, Bitu- men Fume Exposure and Exposure Reduction). 2.5 Mastic — A Special Pavement Application Mastic asphalt (referred to as gussasphalt in Germany) is a special product sometimes used for road surfaces in Europe. It is also used in roofing and industrial flooring. A discussion of mastic asphalt can be found in the docu- ment The Mastic Asphalt Industry–A Global Perspective (2009), and information about roofing can be found in The Bitumen Roofing Industry–A Global Perspective (2008). While mastic is sometimes used for specific paving ap- plications in Europe, it is not used in the U.S. and should not be confused with the predominant and typical asphalt paving applications in both the U.S. and Europe. Application methods, equipment, and job tasks for mastic asphalt vary from those of conventional asphalt paving. Mastic, as used in road paving, can be spread by hand or with a special paving machine. Harder bitumen grades are used in mastic asphalt, resulting in mixing and placement at 180°C -250°C (356F -482°F) — higher than the temperatures for typical asphalt pavements. 2.6 Other Special Applications Modifications (by fluxing or emulsification) of paving - grade bitumens have specific secondary roles within the asphalt paving industry. Fluxed bitumen involves the mixing ofa specific bitumen with lower -viscosity diluents to produce a cutback bitumen which allows application at lower temperatures. It should be noted that cutback bitumen has been largely replaced with the more envi- ronmentally friendly bitumen emulsion. Emulsification involves the fine dispersion of bitumen in a solution of water and surfactant. Like cutbacks, emulsified bitumen can be applied at lower temperatures. These products are commonly used to provide a waterproof layer under new pavement surfaces and sometimes to improve bonding between various layers of asphalt pavement; in these cases they are known as "tack coats" or "bond coats." They are also used in some surface sealing applications such as surface dressing and slurry sealing and to produce a cold -mix patching material that can be stored for longer 8 GL 101, Third Edition periods. These special bitumens are typically applied at ambient temperature. 2.7 Coal Tar in Bituminous Pavement Applications In the past, another type of binder, coal tar (often re- ferred to simply as tar), was used in the paving industry, in varying degrees in Europe, Southern Africa, Australia, and the United States. Because of their similar appearance, little distinction was made between bitumen and tar as a construction material in the past. However, their origin and consequently the chemical composition is quite differ- ent. While bitumen is a product of the petroleum refining process, coal tar is a by-product of one of two processes. One process, which results in coke oven tar, is the pro- cessing of coal by thermal degradation in a coking plant, used in steel manufacture. The second process yields coal tar as a by-product of making oil from coal. This is sometimes known as the Sasol process, and the product is sometimes called Lurgi tar (Jamieson, 1979). As a result of the destructive distillation of coal, coal tar contains polycyclic aromatic hydrocarbons (PAHs). It is well recognized that the PAH content—such as that of B(a)P (Benzo[a]Pyrene)—in coal tar is far higher than the PAH content in bitumen. The economics and availability contributed to different approaches, for example in South Africa tar was relatively abundant and cheaper than bitumen, whereas in the U.S. tar was more expensive and represented only 1 to 2 per- cent of the binder market (McGovern et al., 1974). Europe Coal tar has been used in all layers of pavement applications in Europe. It was sometimes used at 100 percent, sometimes as a mixture of petroleum -derived bitumen along with tar, and sometimes in a blend with polymers. Some of the products had brand names like Carbo -bitumen (a product of bitumen with tar) that con- tributed to confusion with regard to the difference between petroleum -derived bitumen and coal tar. Only after bitumen had replaced coal tar almost com- pletely in Europe during the 1970s and 1980s – due to increasing oil production and declining coke usage and the related economic factors – was the hazard of coal tar to human health and to the environment realized. In Europe, by the early 1990s, the use of coal tar in road paving had been generally discontinued. Unfortunately, many people are still confused by the terminology relating. to the historic use of the term "tar." Coal tar was used in the following European countries: Belgium (until 1992), Czech Republic (until 1999), Ger- many (until 1995), Denmark (until 1975), Finland (until 1960s), France (until 1970), Netherlands (until 1991), Norway (until 1960),. Sweden (until 1974), Slovakia (until 1980), Turkey (until 1979), and UK (until 1999). Controls on coal tar use in Europe since about 1990 are intended to prevent the significant presence of coal tar in pavements as a result of recycling. United States In contrast, coal tar has not been used much in asphalt pavement applications in the U.S. since World War II. Throughout this time, the economies of petroleum - derived bitumen have been favorable while the sourcing of coal tar was on the decline. Following World War II, there was an increase in traffic volume, travel speeds, and axle loads concurrent with an increased demand for asphalt road construction and maintenance. Production of coal tar for road building applications declined from 675 million litres (178 million gallons) in 1945 to about 2 million litres (540,000 gallons) in 1963, resulting in coal tar being used in less than 3 percent of all bituminous paving materials for road construction in that year. There is evidence of very limited coal tar use as late as 1965 in areas of the country where coal and steel production were prominent. More recent applications for coal tar have been limited to a few non -road applications such as airfields and emulsion application as a pavement sealer for parking lots, driveways, and bridges. State specifica- tions typically prohibit the use of RAP known to contain coal tar (Mundt et al., 2009). South Africa and Australia The primary uses of coal tar in South Africa and Aus- tralia have been in primers and chip seals. Some tar mixes have been used in the late 1960s and '70s in base courses and surface courses including container terminals which are subject to fuel spills, car parks, and bus terminals. In. South Africa, estimated use of coal tar in the 1970s was less than 25 percent of all road binders (Jamieson, 1974) and it declined significantly after that time. Road agencies and contractors in South Africa have indicated an intention to discontinue its use (SABITA, 2005). GL 101, Third Edition 9 Production, Transport and Placement of Asphalt Mixes 3.1 Description -- The Asphalt Mixing Plant 3.1.1 Process Control Mandated by Quality Specifications and Environmental Protection Today's asphalt plant can be characterized as a mod- em facility belonging to a sophisticated process industry where emissions are low and well-controlled. Typically, it takes only three to five people to run an asphalt mix- ing plant. In every country, the asphalt industry must comply with stringent regulations and specifications with respect to materials used, process conditions, and pavement specifications. These regulations and specifica- tions are designed to protect the environment as well as to ensure the quality, durability, smoothness, and safety of the roads. 31.2 The Asphalt Mixing Process There are two types of asphalt plants: batch plants and drum plants. In both, the mineral aggregates are dried and heated in a rotating drum. In batch plants, aggregates are stored in hot bins prior to mixing with bitumen in discrete batches before being stored or loaded into trucks. In drum plants, the mixing of the aggregate and the bitumen takes place in the same drum, after which it is stored in a silo before being loaded into trucks for delivery. Today the predominant plant type in the U.S. and New Zealand is the drum -mix plant. Batch plants prevail in Europe, South Africa, and Australia. The following diagrams (Figures 3.1a, 3.1b) show the batch plant design and the drum -mix plant design. Process sketches and flow diagrams along with process description follow. Various asphalt mix formulas are used for the vari- ous types of pavement materials. These formulas are engineered to meet the needs of the owner of the pave- ment. In the case of major roads, highways, and airport runways, the owners are typically governmental entities. In the case of parking areas, low-volume roads, and other facilities, many owners are from the private commercial market, but they often use specifications from govern- ment agencies. Bitumen is stored in heated tanks on site between 150°C (302°F) and 180°C (356°F), which enables the viscous liquid to be pumped through insulated pipes to the mixing plant. The mineral aggregates — stone, sand, and gravel — are stored in stockpiles at ambient temperature. In addition to virgin aggregates, most facilities have stock- piles of reclaimed asphalt pavement (RAP). The aggregate stockpiles are neatly sorted by type and size. Aggregate and reclaimed materials are taken from various stockpiles and loaded into specific bins. Each size of aggregate and reclaimed asphalt material is fed onto conveyor belts in proportions specified by the job mix formula and transported to be dried in a drum. At a batch plant, the aggregates are dried and heated in a rotating drum, where the aggregates tumble through a stream of hot air. After drying, the aggregates and any fillers are then mixed in batches with the exact propor- tions of bitumen and possibly RAP in a second machine called a pug mill. In contrast, at a drum mix plant, the bitumen is added to the dried aggregates and continuously mixed in the same drum used for drying. Here, the RAP and bitumen are added to aggregate far downstream from the source of heat. Every part of the plant has enclosures and/or control technologies. Most plants are fuelled by natural gas or fuel oil, and state-of-the-art scrubbers keep combustion - related emissions very low. Dust is controlled in the baghouse, where fines and dust are collected on the outside of filter bags, while clean air passes through the center of the bags. The fines are periodically subjected to bursts of air which force them to the floor of the baghouse, where they are collected for metering back into the paving mix. Clean air is vented out the top. Most plants are on permanent sites, but even portable mixing plants have the advanced environmental controls that are seen on plants on permanent sites. 10 GL 101, Third Edition Figure 3.1a Batch Plant Figure 3.1b Drum Plant BATCH PLANT DAGHODSE RECLAIMED ASPHALT BIN AGGREGATE FEED BINS DRUM PLANT • CONTROL TOWER GL 101, Third Edition 11 3.2 Description — Truck Loading and Transport to Paving Site After the aggregates have been dried and thoroughly mixed with the bitumen at the required temperature, the asphalt pavement material may either be temporarily stored in silos on the plant site or discharged directly into a truck for transport to the paving site. The asphalt mix is transported from the plant site to the paving site in trucks. Transport distances vary, but are normally on the order of up to 30-80 km (18-50 mi). The distance of transport is limited, as asphalt must be delivered to the paving site while it is still warm enough to be placed and compacted on the road. 3.3 Description —Asphalt Placement and Roller Compaction In the beginning of the 20th century, hot asphalt mix- tures were spread manually by hand and shovel. Later, asphalt paving machines (mechanical spreaders) were introduced. Beginning in the late 1930s, these paving machines were provided with floating screeds for bet- ter levelling and pre -compaction of the asphalt paving mixture The earliest ones were mechanical; they were followed by hydraulic, and later electronic, levelling controls and vibratory screeds. Today, paving machines incorporate the latest technol- ogy. Trucks discharge the hot asphalt mix into a hopper on the paving machine. The material then is conveyed through the paving machine where it is spread across the width of the machine by an auger at the rear of the machine. As the auger distributes the material along the screed, the paver continues to move forward, so that Figure 3.3a Paving Machine the screed keeps the paving mat level and smooth. The asphalt mix cools throughout this process and must be quickly compacted by a roller to the required pavement density and smoothness by one or more rollers following the paving machine. A paving crew typically consists of one or two paver operators, one or two screed operators, and two or three laborers with rakes and lutes. Each roller has its own operator. A typical paving machine and roller are illustrated below (Figures 3.3a -3.3b ). Typical Roller Paving machinery and work practices have constantly evolved since the beginning of the 20th century, as illus- trated in (Figures 3.3c). Figure 3.3b Roller 12 GL 101, Third Edition Figure 3.3c Evolution of Paving Practices Laying machinery and work practices have constantly evolved since the beginning of the 20th century as illustrated in this pictorial representation. Manual spreading at the beginning of 20th century Introduction of machine spreading 1985 paving GL 101, Third Edition 2009 paving 13 4 Bitumen Fume Exposure and Exposure Reduction 4.1 Fume Exposure Potential and Job Tasks Bitumen fume exposure potential, including the quantity and nature of organic compounds, is directly dependent upon the specific application process condi- tions including temperature. For 22 U.S. paving bitumens studied in the laboratory, it was found that PAH emissions from bitumen are highly temperature -dependent. It has also been reported that only simple aromatics and very low amounts of 2-3 ring PAHs are emitted at temperatures typically employed for asphalt paving applications (140- 160 °C; 284-320 °F) (Thayer et al. 1981, Brandt and de Groot 1985, Brandt and Molyneux 1985, Niemeier et al. 1988, Blackburn and Kriech 1990, Lien 1993, Machado et al. 1993, Kitto ct al. 1997, Butler et al. 2000, Burstyn et al. 2000, Law et al. 2006, Ruhl et al. 2006, Kriech 2007, Lange et al. 2007, Ruhl et al. 2007). According to the bitumen refining industry, lowering the bitumen temperature by 11-12.5°C (20-22°F) reduces Figure 4.1.1 Asphalt Plant Operator BSM (benzene -soluble matter) fume emissions by a fac- tor of 2 (Asphalt Institute and Eurobitume 2008). As was noted above, production of conventional asphalt pavement material is typically accomplished in the range of 140°C - 160°C (280°F -320°F). In the past decade, warm -mix as- phalt technologies have been developed and deployed to allow the production and placement of asphalt pavements at between 100°C -140°C (212°F -280°F). Following is a description of job tasks, together with an assessment of the potential for exposure based on both the temperature of the material at different points in the production and placement processes and the proximity of the workers to fume over time. 4.1.1 Plant Worker Tasks and Bitumen Fume Exposure Potential. Typically, a small crew controls the entire asphalt plant mixing process. The plant operator sits in a climate - controlled operations center. Typically, the other person- nel on site are an aggregate loader operator and a main- tenance person. These workers tend to be very mobile. Ground -level emissions are sporadic and of short duration, and arc typically associated with truck loading. Since the number of workers is 14 small and the persons on site are not in direct contact with a sustained fume environment, it is evident that the possibility for workers to be exposed to bitumen fume at the plant site is limited. 4.1.2 Truck Driver Task and Bitumen Fume Exposure Potential Truck drivers may encounter fume sporadi- cally during the process of loading a truck at the plant site or unloading the truck at the paving site. Any potential exposure is of short duration and is mediated by the natural factors of wind speed and wind direction, especially that of truck movement. The process of load- ing or unloading is typically a matter of sec- onds or minutes during each operation. As a GL 101, Third Edition Figure 4.1.2 Truck Drivers result, there is little opportunity for sustained exposure relating to the truck -driving task. In addition, the trans- ported asphalt is constantly cooling, thereby diminishing a primary factor relating to the release of fume. 4.1.3 Placement and Compaction Worker Tasks and Potential for Bitumen Fume Exposure In comparison to plant workers, placement and com- paction workers have higher potential for exposure to bitumen fume. These include the paver operators (pavers), screed operator (screedmen), the laborers/rakers, and the roller operator (rollers). Substantial industrial hygiene data has been collected in relation to these tasks. The data presented below substantiate that exposure levels in all tasks are today typically below recommended exposure limits established by the National Institute for Occupational Safety and Health in the U.S. (NNIOSH) and the American Conference of Governmental Industrial Hygienists (ACGIH). Following is a description of the tasks as referenced in exposure assessment data. 4.1.4 Placement and Compaction Tasks Defined A typical paving crew in. Europe or the U.S. consists of about five to nine people, as follows: i• Paver operators (pavers, paving machine operators) — One or two operators are stationed on top of the place- ment machine (paver) to drive it as it receives asphalt from delivery trucks and distributes it on the road prior to compaction by rolling. The paver is equipped with a hopper to receive dumped asphalt from truck transport. The primary opportunity for fume ex- posure for these workers would be from the paver hopper or the screed auger. • Screed operators (screedmen) — One or two screed operators are stationed at the rear of the paver to control the dis- tribution and grade of the asphalt mat as the paving machine moves forward. The screed is equipped with a spreading auger to ensure a uniform mat prior to compaction. The primary opportunity for fume exposure for these workers would be from the spreading auger, due to proximity. • Rakers —One or two people shovel and rake excess pavement material, fill in voids, and prepare joints for compaction. Rakers are mobile and move around as needed, but typically are in proximity to the paving machine. Their primary opportunity for fume exposure would be the freshly placed asphalt mat or the spreading auger, depending upon proximity. ▪ Laborers — Laborers sometimes perform the same tasks as rakers and may be on site to perform miscel- laneous tasks. This position tends to be more mobile and can be somewhat removed from the primary source of fume surrounding the paving machine. • Foremen — In Europe, a foreman is often in close proximity to the screed while supervising the crew, as reflected in Figure 4,1.3. In the U.S., a foreman is likely to be more mobile. • Roller operators (rollers) — One to three roller operators drive machinery designed to compact the asphalt by rolling it to specifications. Their primary opportunity for fume exposure would be the freshly placed asphalt mat, depending upon their proximity to the placement operation. Operators of the rollers are mobile, operating at varying distances from the primary source of fume surrounding the paving machine. Generally, the foreman, paver operators, and roller operators do not perform different jobs, while the screed operators, rakers, and laborers may perform a variety of tasks throughout the workday. Crewing schemes may vary from country to country, and according to labor and company work practices. GL 101, Third Edition 15 Figure 4.1.3 Paving Placement Workers Paver Operator Screedman Roller Operator Raker/Laborer Roller Operators Foreman Screedman Paver Operator Truck Driver 16 GL 101, Third Edition 4.2 Bitumen Fume Sampling and Analytical Methods Factors Affecting Exposure Assessment Occupational exposure to bitumen fume is measured using a personal monitoring sampler. The type of sampler used and the method by which it is analyzed can lead to substantial differences between measured values (Ekstrom et al., 2001). When comparing results of personal exposure monitoring surveys it is important to take into account the method used and the metric being evaluated. Exposure sampling and analytic methods for bitumen fume generally fall into three main categories that measure the following: • Particulate matter TPM (Total Particulate Matter): this includes aerosol matter from the bitumen and inorganic material such as dust, rock fines, filler, etc. Because TPM methods collect material from non -bitumen sources the resulting values can suggest artificially high exposure values, especially in dusty environments. Solvent soluble fraction of particulate matter BSM/BSF (Benzene Soluble Matter/Fraction) or CSM/ CSF (Cyclohexane Soluble Matter/Fraction): these methods rely on collection of the particulate fraction as described above. However, in order to reduce the confounding exposure to inorganic particulate matter a solvent is used to extract only the organic fraction of the particulates. Such methods more accurately define the exposure to the agent of interest (bitumen fume). A sub -set of such methods uses a special monitoring cassette to collect only a specific fraction of the par- ticulate matter, e.g. the respirable, thoracic fractions or inhalable fraction. • Organic matter TOM/THC (Total Organic Matter/Total Hydrocarbon): the sum of the organic part of the particulate fraction plus organic vapour phase collected using a back-up absorbent. At present, no international standard for the assess- ment of exposure to bitumen fume exists. As a result, reported values of exposures over time, between stud- ies within the same country, and between the various countries vary significantly and must be considered carefully as to the intended use. Occupational assess- ment of bitumen fume exposures is susceptible to significant variability in magnitude and constituent from a variety of influencing factors. More research is needed to develop a universally valid, reliable, and easy method of assessing exposures to bitumen fume. Table 4.2 gives an overview of some important factors influencing the outcome of exposure monitoring. Sampling and analytical protocols for assessment of exposure to bitumen fume vary significantly from country to country. There is a difference between bitumen fume and bitu- men vapour. When a bitumen is heated a vapour and an aerosol phase are emitted; together, these two phases are collectively known as "fumes from bitumen." The vapour phase is sometimes called semi -volatiles and the aerosol phase is called bitumen fume. It can also be referred to as blue smoke. The bitumen fume has a higher boiling point distribution than the semi -volatile fraction (Brandt et al., 1993). In an analysis of paving worker exposures in Finland, France, Germany, Norway, the Netherlands and Sweden, no consistent correlation between bitumen fume and bitumen vapour levels could be established (Burstyn et al., 2002). Table 4.2 Important Factors Influencing the Outcome of Exposure Monitoring Measurement Task Influencing Factor Sub -Factor influences Sampling of bitumen fume Sampling Device Type of sampler (filter media etc.); sampling characteristics (rate, duration; etc.) Climate Wind speed/direction; air temperature; humidity Ambient Environment Physical obstacles, tunnels, etc. Bitumen Application Bitumen type and source, application temperature, equipment Being Monitored type and controls; proximity to source Analysis of bitumen fume Metric Under Examination, Dynamic nature of bitumen fumes; aerosol, vapour, TPM, BSM/BSF, CSM/CSF, and solvent soluble fraction of particulate matter. Total Vapour, TOM, THC etc. Analytical Method Extraction solvent, analytical instrumentation, gravimetric, infrared spectroscopy, total absorbance, GC, calibration standard, etc. GL 101. Third Edition 17 In order to better interpret the meaning of different ex- posure monitoring results, it is important to understand the effect of temperature on fume generation. The Asphalt In- stitute and Eurobitume have observed, "During handling of bitumen, or bitumen -containing materials at elevated temperatures, small quantities of hydrocarbon emission are given off. In a laboratory study, in the temperature range relevant for paving applications...the Benzene Soluble Fraction emission rate increases by a factor of 2 about every 11-12.5°C (20-22°F) temperature increase." (Asphalt Institute and Eurobitume, 2008). 4.3 European Exposure Data — Personal Airborne As was illustrated in section 4.2 above, the reported data in the available national occupational bitumen ex- posure fume studies vary considerably, particularly due to the various sampling and analytical methods used. In 2000 an extensive review of published literature regard- ing worker exposure in the road construction industry was published (Burstyn et.al., 2000 AIHJA). The review stated that "the published reports provide some insight into the identity of factors that influence exposure to bitu- men among road construction workers: type of work per- formed, meteorological conditions, temperature of paved asphalt. However, there is a lack of (a) comprehensive and well-designed studies that evaluate determinants of exposure to bitumen in road construction, and (b) standard methods for bitumen sampling and analysis. Information on determinants of other exposures in road construction is either absent or limited. It is concluded that data available through published reports have limited value in assessing historical exposure levels in the road construction indus- try." Available European asphalt paving worker data are summarized in Appendix II. These data illustrate the vari- ability in sampling and analytic protocol, related exposure metrics, and resulting data country -to -country. 4.4 U.S. Exposure Data — Personal Airborne Because of the above -referenced disparity in exposure measurement techniques among various countries in Eu- rope, this section is limited to exposure data collected at paving sites within the United States where the exposure method has been reasonably consistent and where the database is large. In the U.S., NIOSH reference method 5042 for Total Particulate and Benzene Soluble Fraction is the typical reference method with reporting on a time weighted average (TWA), eight hour shift basis. Tables 4.4a, 4.4b, and 4.4c in Appendix 111 reflect a compilation ofU.S. exposure data that was reported in the 2000 NIOSH Health Effects Evaluation of Occupational Exposure to Asphalt in addition to any new U.S. studies conducted and published since the NIOSH 2000 document (Butler et al., 2000). 4.5 Dermal Absorption and Use of Biomarkers — An Emerging Science In the Investigation of Bitumen Fume Exposures Use of biomarkers to investigate potential bitumen fume exposure, both dermal and inhalation, is an emerg- ing science. Recent scientific efforts have deployed the use of dermal wipe samples and skin patch samples along with specific biomarkers such as urine metabolytes to investigate both inhalation and dermal exposures (Hicks, 1995; McClean et al., 2004 a, b; Zey, 1992 a, b, c; Zhou, 1997). Selected biomarkers of PAH exposure have been employed in such studies along with both laboratory and statistical attempts to quantify the relative influ- ence of dermal versus inhalation pathways on selected biomarkers such as 1 -hydroxy pyrene urine metabolite. The use of such tools for dermal exposure assessment is limited today due to difficulty in distinguishing dennal absorption influence on selected biomarkers from that of inhalation influence and due to potential confound- ing from sources other than bitumen fume exposure. In addition, bitumen fume is a complex mixture (McClean, 2004 a) with poorly understood and potentially complex pharmacokinetics involving the various components of bitumen fume. Given this complexity, much discussion has focused on the selection of appropriate biomarkers for purposes of future research. A comprehensive review of past research efforts is provided by van Rooij et. al. in a report entitled "Review of Skin Permeation Hazards of Bitumen Fumes." A major research initiative on dermal absorption has recently been completed that better characterized the action of individual PACs — their source, nature, and bioavailability. Various control measures to reduce paving worker dermal exposures were also examined (Cavallari et al. 2011, Kriech et al. 2011, Osborn et al. 2011, Olsen et al. 2011), demonstrating potential to significantly reduce exposures through a combination of temperature reduction and work practices modification (Cavallari et al. 2011). 4.6 National Occupational Exposure Limits (OELs) 4.6.1 Europe The existing occupational exposure limits (OELs) for bitumen fume vary from country to country within Europe, depending mainly on the measurement method; 18 GL 101, Third Edition Table 4.6 Comparison of Occupational Exposure Limits thy Country Bitumen fume – CAS number 8052-42-4 Country Limit Basis (mg/m3) Analytical Metric Denmark 1.0 TWA* Cyclohexane - soluble fraction Finland 5.0 TWA Organic dust (also bitumen vapors) Germany 10.0 TWA Aerosol and vapor Ireland 0.5 10.0 TWA 15 min. STEL** Benzene -soluble fraction of aerosol Italy 0.5 TWA Benzene -soluble inhalable particulate Netherlands 5.0 TWA Set aside as of Jan. 1, 2007 Norway 5.0 TWA TPM*** Portugal 0.5 TWA Benzene -soluble inhalable particulate Spain 0.5 Daily exposure limit Benzene -soluble inhalable particulate Sweden No limit Switzerland 10.0 TWA Total hydrocarbon UK 5.0 10.0 TWA 10 min. STEL TPM Time -weighted average ** Short-term exposure limit *** Total particulate matter however, even countries adopting the same measurement method may prescribe different limit values. At present neither a binding nor an indicative EU occupational ex- posure limit value for bitumen fume exists. To provide an indication of the variety of limit values that exist, a summary of values in some countries is given in Table 4.6. The countries with low occupational exposure limit values, e.g. Ireland, use a specific organic fraction of the aerosol particulate matter originating from the bitumen to control the emission levels. Countries with higher emission values, e.g. Germany, also take into account additional factors such as vapour. 4.6.2 United States There is no current federal OSHA (Occupational Safety and Health Administration) existing occupational exposure limit (OEL) for bitumen fume in the U.S. The NIOSH -recommended exposure limit was set in 1977 and remains at 5 mg/m', 15 minutes. In 2000, the ACGIH- recommended threshold limit value for bitumen exposures was set at 0.5 mg/m' (8 -hr TWA) as inhalable fraction, benzene -soluble particulate matter (ACGIH, 2000). The particle size selective sampling device required for mea- surement of inhalable fraction has been shown to have little effect on the assessment of bitumen fume exposures as the particle size is small (Ekstrom et.al, 2001). As a result, one can make a direct comparison of the ACGIH threshold limit value to traditional U.S. data generated according to NIOSH method 5042 when reported as benzene soluble matter (I3SM). 4.7 Exposure Reduction -- Europe and U.S. Recent research reported significant reductions in paving workplace exposure levels since 1960 in Europe (Burstyn et. al. 2003). The discontinuance of coal tar use in Europe combined with best practices and technological advances have had a dramatic effect on paving worker exposures. Over the past decade or more, the paving industry in the U.S. has intensively engaged in bitumen fume reduc- tion efforts surrounding paving operations (Acott 2007, APEC 2000). Beginning in 1996, the asphalt industry in the U.S. initiated a partnership with NIOSH, labor unions, and FHWA to explore opportunities to minimize fume exposure surrounding paving operations through the application of engineering controls. This effort led to a voluntary agreement with OSHA to install such control systems on all highway -class paving machines manufac- tured in the U.S. after July 1, 1997.This process included the development of guidelines for the engineering controls (Mead and Mickelson, 1997). It is estimated that most highway -class pavers currently in use in the U.S. are now equipped with engineering con- trols. This same government/industry/labor partnership recently conducted a follow-up study to benchmark the use and effectiveness of engineering controls (Michelsen et.al, 2006). Personal monitoring of the paver operator, raker, and screedman was completed along with aero- dynamic particle size measurements. NIOSH sampling and analytic protocol 5042 was employed, yielding 437 samples— a combination of total particulate (TP) matter and benzene -soluble fractions (BSF). Results from the study indicated a TP arithmetic mean of 0.36 mglm3, 95 GL 101, Third Edition 19 percent confidence limits (0.27, 0.69) and BSF arithmetic mean of 0.13 mg/m3, 95 percent confidence limits (0.07, 0.43). Both TP and BSF means were significantly below NIOSH- and ACGIH-recommended exposure limits of Smglm3 and 0.5 mg/m' respectively on a time -weighted average basis. Application temperature is widely recognized as a very significant parameter in the generation of fume. More recently, warm -mix asphalt has been developed as an in- novative method of fume reduction at the source. These technologies allow asphalt to be produced and placed on the road at significantly lower temperatures than conven- tional asphalt mixes. Lowering the mixing and placement temperature by 10-38°C (50-100°F) has numerous other operational and environmental benefits. Most important, warm -mix asphalt has the potential to virtually eliminate fume surrounding paving workers. Led by an industry/agency/academia partnership, these various technologies are undergoing rigorous laboratory and field performance testing as well as industrial hygiene monitoring in the U.S., Europe, and other parts of the world. U.S. warm -mix asphalt use is on an exponential growth curve (Acott, 2008). The industry and its associa- tions, government agencies, and academic institutions are jointly supporting accelerated research and deployment as well. The mission is to accelerate the implementation of warm -mix technologies by providing technical guidance. In addition, formal mechanisms are in place to coordinate information and education efforts between international audiences. Significant documents on warm mix include Warm -Mix Asphalt: Best Practices (Prowell et al., 2011) and The use of Warm Mix Asphalt (EAPA, 2009). 20 GL 101, Third Edition Edi Industry Terms Percent by mass. The mass of material reflects the quantity of matter within a sample. Percent by weight. Weight is defined as the mass mul- tiplied by the force of gravity (Earth gravity is approxi- mately 9.8m.s-1). ACID MODIFIED ASPHALT/BITUMEN Bitumen modified by the addition of inorganic acids, typi- cally phosphoric, or polyphosphoric acid. AIR BLOWING The process by which compressed air is blown into a BI- TUMEN feedstock typically at 230-260°C (446-500°F), sometimes in the presence of catalysts (typically ferric chloride, phosphoric acid, or phosphorus pentoxide). This process results in complex reactions which raise the soft- ening point and viscosity of the bitumen. See OXIDIZED BITUMENS. AIR -BLOWN ASPHALTS See OXIDIZED BITUMENS AIR -BLOWN BITUMENS BITUMEN products produced by AIR BLOWING. See OXIDIZED BITUMENS. AIR -REFINED BITUMENS. Penetration bitumens produced by partial blowing, Ar- chaic term, no longer in use. AIR -RECTIFIED BITUMEN (synonym SEMI -BLOWN BITUMEN) A bitumen that has been subjected to mild oxidation with the goal of producing a bitumen meeting paving grade bitumen specifications. Air -rectified bitumens are used in paving applications as well as roofing applications, such as shingle saturants and Type 1 Built Up Roofing Asphalt (BURA), and also for some industrial applications. ASPHALT A mixture of BITUMEN and mineral materials used as a paving material that is typically produced at temperatures in the range of 140-160°C (280-320°F). ASPHALT BINDER Term used in the U.S. and some other countries for BI- TUMEN. ASPHALT CEMENT Term used in the U.S. and some other countries for BI- TUMEN. ASPHALT COLD MIXES ASPHALT mixtures made using CUTBACK BITUMENS or BITUMEN EMULSIONS, which can be placed at ambient temperatures. ASPHALTENES Highly polar aromatic materials. Asphaltenes have high viscosity or stiffness at ambient temperatures and are re- sponsible for the overall stiffness of BITUMENS. They can be precipitated with n-heptane and are sometimes referred to as n-heptane insolubles. ASPHALT MIXES (MIXTURES) Mixtures of graded mineral aggregates (sized stone fractions, sands and fillers) with a controlled amount of bitumen. ATMOSPHERIC DISTILLATION Distillation at atmospheric pressure ATMOSPHERIC RESIDUE Residue of ATMOSPHERIC DISTILLATION BASE OILS Petroleum -derived products consisting of complex mix- tures of straight and branch -chained paraffinic, naphthenic (cycloparaffin) and aromatic hydrocarbons, with carbon numbers of 15 or more and boiling -points in the range of 300-600°C (570-1110°F). Depending on climatic condi- tions BASE OILS can be used to reduce the low stiffness of BITUMENS to resist low temperature cracking of pavements. BENDING BEAM RHEOMETER A machine used to determine the low temperature stiff- ness properties of BITUMENS that have been laboratory aged to simulate extended aging of the BITUMEN in ASPHALT pavements. Results are part of the PERFOR- MANCE GRADED BITUMEN specification. BINDER According to EN 12597; Material serving to adhere to aggregate and ensure cohesion of the mixture. A more general term used to identify BITUMEN plus potential modifiers used to produce ASPHALT mixes. The term BINDER reflects that some ASPHALT mixes may utilize MODIFIED BITUMENS. BITUMEN BLOCKS Small size blocks (typically 20kg) of BONDING BITU- MEN for being melted in kettles. GL 1 01 , Third Edition 21 BITUMEN, PETROLEUM DERIVED A dark brown to black cement -like residuum obtained from the distillation of suitable CRUDE oils. The distilla- tion processes may involve one or more of the following: atmospheric distillation, vacuum distillation, steam distil- lation. Further processing of distillation residuum may be needed to yield a material whose physical properties are suitable for commercial applications. These additional processes can involve air oxidation, solvent stripping or blending of residua of different stiffness characteristics. BITUMEN EMULSION A mixture of two normally immiscible components ($I- TUMEN and water) and an emulsifying agent (usually a surfactant). Bitumen emulsions are utilized in paving, roofing and waterproofing operations. These materials are called. EMULSIFIED ASPHALTS in North America. BITUMEN ENAMEL (BITUMEN PAINT) An external coating for protecting steel pipes, The term can also be used for bitumen paints (formulated CUTBACK BITUMENS or BITUMEN EMULSIONS). BITUMEN FUME The gases and vapors emitted from heated BITUMEN, and the aerosols and mists resulting from the condensation of vapors after volatilization from heated BITUMEN. BITUMEN GRADING TERMINOLOGY There are currently three main grading systems employed world-wide for identifying and specifying bitumens used in road construction. These systems are PENETRA- TION, VISCOSITY and PERFORMANCE GRADED. Although each system has test methods that are unique to that system, similar bitumens are used across all grading systems. The particular system used within a given country or region is generally a result of historical practices or governmental stipulations. BITUMEN MACADAM A type of ASPHALT mix with a high stone content and containing 3-5 percent by weight of bitumen. BITUMEN PAINT A specialized CUTBACK BITUMEN product that con- tains relatively small amounts of other materials that are not native to BITUMEN or to the diluents typically used in cutback products, such as lampblack, aluminum flakes, and mineral pigments. They are used as a protec- tive coating in waterproofing operations and other similar applications. BITUMEN PRIMER ACUTBACK BITUMEN made to treat bare metal surfac- es giving a bond between the metal and an ENAMEL. BITUMEN ROOFING FELT A sheet material, impregnated with BITUMEN, generally supplied in rolls and used in roof construction, BITUMINOUS Of or related to BITUMEN. In this document the terms BITUMEN and BITUMINOUS refer exclusively to pe- troleum derived BITUMEN as defined above. BLENDED BITUMENS Blends of two or more BITUMENS with different physical characteristics or blends of Bitumen(s) and high boiling point petroleum fractions (e.g. heavy vacuum gas oil) in order to achieve desired physical properties. BLOWING STILL (Also known as OXIDIZER or Bitumen Blowing Unit.) Equipment used to air blow BITUMEN. BONDING BITUMEN OXIDIZED BITUMEN or POLYMER MODIFIED BI- TUMEN used for HOT APPLIED ROOFING. BRIQUETTE See BRIQUETTING. Archaic term, no longer in use. BRIQUETTING The process by which fine materials (e.g.. coal dusts, metal tailings) are mixed with a bitumen (or other) binder to form conveniently handled blocks or pellets. Archaic term, no longer in use. BUILT UP ROOFING (BUR) North America: A continuous roofing membrane con- sisting of plies of saturated organic (e.g., cellulose) felts or coated inorganic (e.g., glass fiber) felts, assembled in place with alternate layers of BITUMEN or COAL TAR PITCH, and surfaced with mineral aggregate, a granule surfaced sheet, or a roof coating. Europe: A continuous roofing membrane consisting of plies of coated inorganic (e.g., glass fiber) felts. assembled in place with alternate layers of BITUMEN, and surfaced with mineral aggregate, a granule surfaced sheet, or a roof coating. BUILT UP ROOFING ASPHALT (BURR) OXIDIZED BITUMEN used in the construction of low -slope built-up roofing (BUR) systems; specification defined by ASTM D3 12. This material is called Built -Up Roofing ASPHALT (BORA) in North America. CAS REGISTRY A large database of chemical substance information in the world containing more than 29 million organic and inorganic substances and 57 million sequences.www. cas.org/ CAS REGISTRY NUMBER A CAS Registry Number is assigned to a substance when it enters the CAS REGISTRY database. CATALYTIC AIR -BLOWN BITUMENS OXIDIZED BITUMENS produced using catalysts in AIR BLOWING. COAL TAR A dark brown to black, highly aromatic material manu- factured during the high-temperature carbonization of bituminous coals which differs from bitumen substantially in composition and physical characteristics. It has previ- ously been used in the roofing and paving industries as an alternative to BITUMEN. 22 GL 101, Third Edition COAL TAR PITCH A black or dark -brown cementitious solid that is obtained as a residue in the partial evaporation or fractional distil- lation of COAL TAR. Coal Tar Pitch has been used in the past in roofing as an alternative to BITUMEN. COATING BITUMEN An AIR -BLOWN or OXIDIZED or polymer modified bitumen used to manufacture roofing membranes or shingles. COLD ADHESIVE Bituminous CUTBACK used as a glue for application at ambient temperature of polymer modified bitumen membranes. COLD -APPLIED ROOFING BITUMEN Bitumen roofing products that are applied at ambient temperatures at the work place without any heating (e.g. peel and stick bitumen membrane or membranes applied with the use of a cold adhesive). COLLOID MILLS High-speed shearing devices in which hot bitumen can be dispersed using a surfactant in an aqueous solution to produce a BITUMEN EMULSION COLORED MINERAL GRANULES Natural- or factory -colored minerals used as light surface protection for bitumen membranes or bitumen shingles. CRACKING -RESIDUE BITUMENS ]THERMAL BITUMENS] Archaic term, no longer in use. CRUDE OIL See CRUDE PETROLEUM CRUDE PETROLEUM A naturally occurring mixture consisting predominantly of hydrocarbons' but also containing sulfur, nitrogen, or oxy- gen derivatives of hydrocarbons, which can be removed from the earth in a liquid state. CUTBACK BITUMENS (PETROLEUM) Bitumen whose viscosity has been reduced by the addition of a CUTBACK SOLVENT derived from petroleum. CUTBACK SOLVENT (PETROLEUM) Relatively volatile petroleum solvent used in the manu- facture of CUTBACK BITUMEN. Typically white spirit (Stoddard Solvent) and kerosene are the petroleum -derived solvents employed. CYCLICS (NAPHTHENE AROMATICS) Compounds with aromatic and naphthenic nuclei with side chain constituents. They are viscous liquids and represent the major proportion of the dispersion medium for the ASPHALTENES and adsorbed resins in bitumen. They constitute 30-60% by mass of the total bitumen DRUM MIXER An ASPHALT mixing device in which mixtures of MINERAL AGGREGATE and bitumen are heated and combined continuously in a rotating drum. DYNAMIC SHEAR RHEOMETER A testing device used to determine the stiffness of bitu- mens over a range of temperatures and test frequencies. Typically a standard amount of bitumen (25 mm in diameter by 1 mm in thickness) tested between two flat plates (25 mm in diameter). An oscillatory stress or strain of known value is applied to the bitumen sample and the resultant strain or stress is measured. From these data the stiffness of the bitumen is calculated. The stiffness results are part of the specification within the PERFORMANCE GRADED system of specifications, DURABILITY TESTING See WEATHERING TEST. EINECS European INventory of Existing Commercial chemical Substances; analogous to the CAS system by which chemical substances were registered under the EU Exist- ing Substances Regulation. ELASTOMER A polymeric substance (natural or synthetic) which when stretched to a length that is less than its point of rupture and released will recovery substantially to its originally length. Examples are vulcanized natural rubber, styrene butadiene latex rubber, and styrene butadiene styrene block copolymer. EMULSIFIED ASPHALTS See BITUMEN EMULSIONS. EQUIVISCOUS TEMPERATURE (EVT) The temperature at which BITUMEN has a viscosity that is optimum for application in BUILT-UP ROOFING (BUR.) systems. For mop application the optimum ap- parent viscosity is 125 centipoise (cP); for mechanical application it is 75cP. FILLER (Paving) Fine mineral matter employed to give body to a bituminous binder or to fill the voids of a sand. FILLER (Roofing) Fine mineral matter, typically limestone, or slate dust mixed with. BITUMEN prior to being applied as a coating in the manufacture of ROOFING SHINGLES and other roofing products. FLASHPOINT The temperature at which a combustible vapor forms above the surface of BITUMEN in a specific test method. Methods used for ROOFING BITUMEN products are EN ISO 2592 or ASTM D92 for Open Cup Flashpoint and EN ISO 2719 orASTM D93 for Closed Cup Flashpoint. FLEXIBLE PAVEMENTS Road surfacings made from layers of ASPHALT mixes. FLUXED BITUMEN (PETROLEUM) A bitumen whose viscosity has been reduced by the addi- tion of a flux oil derived from petroleum. Note: Typically gas oils of various distillation ranges are employed as the flux oil. FLUXED BITUMEN differs from CUTBACK GL 101, Third Edition 23 BITUMENS which also are reduced viscosity BITU- MENS in that the flux oils have negligible volatility at ambient temperatures compared to the petroleum solvents used to produce CUTBACK BITUMENS. FLUX This term has different meanings in different regions, e.g; North America; also referred to as ROOFING FLUX. A term of art referring to a raw material from which OXIDIZED BITUMEN is made. Typically soft bitumens [Iess than 50 Pa.s @ 60°C (140°F)] are used, although bitumens of higher viscosity can be included within the definition of FLUX. Europe; FLUX refers to FLUX or FLUX OIL; Relatively involatile fluid (oil) used in the manufacture of fluxed bitumen. FLUX OILS (PETROLEUM) This term has different meanings in different regions, e.g; North America: High -flashpoint hydrocarbon oils (gen- erally paraffinic) added to a ROOFING FLUX prior to oxidizing. The purpose of a FLUX OIL is to enable manu- facture of OXIDIZED BITUMEN with higher penetration values at a given softening point than would be possible without incorporation of the FLUX OIL. Europe: FLUX refers to FLUX or FLUX OIL; Relatively involatile fluid (oil) used in the manufacture of fluxed bitu- men, it also refers to the diluent used in the manufacture of OXIDIZED BITUMEN. FOREMAN Supervises a crew or a particular operation in the place- ment and compaction process of asphalt. FUME -SUPPRESSING BUR BITUMENS Proprietary BUR BITUMEN products which contain small amounts of polymer (added during manufacture or at the job site) that forms a layer on the surface of the heated BITUMEN, lowering the rate of fume generation. Also known as Low -Fuming BITUMENS. GAS OIL A liquid petroleum distillate with a viscosity and boiling range between those of KEROSENE and lubricating oil. GELSONITE A natural, resinous hydrocarbon found in the Uintah Basin in northeastern Utah, USA. GLASS MAT OR FELT A nonwoven mat made with short glass fibers adhered together with a resin and suitable for coating and impreg- nation with BITUMEN for roofing products. HALF WARM MIX A European term used to describe experimental asphalt mixes designed to reduce temperature within the range of 60°C - 100°C (140 °F - 212 °F). HARD BITUMEN A BITUMEN possessing low penetration value and high softening point. These are used in the manufacture of high -modulus ASPHALT MIXTURES HOT -APPLIED ROOFING Application of roofing membranes with hot BONDING BITUMEN as a glue by mopping, pouring, or with me- chanical spreaders (pour & roll technique).This is also called HOT BONDING ROOFING. HOT BONDING ROOFING See HOT -APPLIED ROOFING. HOT -MIX ASPHALT A mixture of BITUMEN and mineral materials used as a paving material that is typically produced at temperatures in the range of 140-160°C (280-320°F). In Europe, the term is synonymous with ASPHALT. HOT WELDING ROOFING See TORCHING KEROSENE (KEROSINE) A petroleum distillate consisting of hydrocarbons with carbon numbers predominantly in the range of C9 through C16 and boiling in the range of 150-290°C (300-550°F). LABORERS Sometimes perform raker tasks and may be on site to perform miscellaneous tasks. LAKE ASPHALT Most common fonn of NATURAL ASPHALT, occurring in Trinidad. LOSS ON HEATING A common industrial BITUMEN test which measures the weight Toss after exposing a small BITUMEN sample to 163°C (325°F) for five hours. See ASTM D6. LOW -SLOPE ROOFING Roofing products designed for a roof slope of less than or equal to 14 degrees. MALTENES Relatively low molecular weight oily fraction ofbitumen. The maltenes are believed to dissolve, or disperse theAS- PHALTENES in the colloidal structure ofbitumen. They are the n-heptane soluble fraction of bitumen. MASTIC ASPHALT Mastic asphalt (MA) is a voidless asphalt mixture with bitumen as a binder in which the volume of the filler and binder exceeds the volume of remaining voids (see EN 13108-6). Typically placed at temperatures in the range of 230280°C (450-536°F). MEMBRANE A factory -made flexible layer of bitumen with internal or extemal incorporation of one or more carriers, supplied in roll form ready for use. MINERAL AGGREGATE A combination of stone fractions and FILLER. MODIFIED BITUMENS Bituminous binder whose rheological properties have 24 GL 101, Third Edition been modified during manufacture by the use of one or more chemical agents. MOPPER A worker who spreads hot bitumen on a roof with a mop. NATURAL ASPHALT Naturally occurring mixture of bitumens and mineral matter formed by oil seepages in the earth's crust. Natural asphalts include Trinidad Lake, Rock, Gilsonite, Selenice, and others. OXIDIZED BITUMEN (OXIDISED BITUMEN) — CAS #44742-93-4 Bitumen whose rheological properties have been substan- tially modified by reaction with air at elevated tempera- tures. This material is also sometimes referred to as "blown bitumen" and, in the USA, AIR -BLOWN ASPHALT, OXIDIZED BITUMEN MEMBRANE A ROOFING BITUMEN product typically made by coating a glass fiber or polyester mat with a mixture of OXIDIZED BITUMEN and mineral filler, and then pack- aging the finished product in rolls. In North America these products may be made with a mineral granule surface and are called ROLL ROOFING. OXIDIZER See BLOWING STILL. PAH, PAC Polycyclic Aromatic Hydrocarbons is the collective name for a large group of several hundred chemicals that have a characteristic structure of two or more fused aromatic rings. They are a class of organic compounds and also a sub -group of the larger family of chemicals - Polycyclic Aromatic Compounds (PAC). PAVER OPERATORS (PAVERS) Person stationed on top of the paving machine (placement machine) to drive it as it receives asphalt from delivery trucks and distributes it on the road prior to compaction by rolling. PAVING BITUMEN (ASPHALT CEMENT IN THE U.S.) — CAS #8052-42-4 A bitumen used to coat mineral aggregate, mainly used in the construction and maintenance of paved surfaces and hydraulic works. PAVING MACHINE A machine designed for placement of a uniform asphalt mat onto a road surface prior to roller compaction. PENETRATION -GRADED BITUMENS Bitumens classified by the depth to which a standard needle will penetrate the bitumen sample under specified test conditions. (See ASTM D5 and/or EN 1426 for an explanation of the penetration test.) PENETRATION INDEX Indication of the thermal susceptibility ofa bituminous binder. The penetration index is calculated from the values of PENETRATION and the SOFTENING POINT, It is based on the following hypothesis of Pfeiffer and Van Doormael: a) At the temperature of the softening point, the penetra- tion ofa bitumen is 800 dmm. b) When the logarithm (base 10) of PENETRATION is plotted against temperature, a straight line is obtained, the slope A of which is defined by: A PENETRATION INDEX of zero is attributed to a bitu- men with a PENETRATION at 25°C (77°F) of 200 drum and a SOFTENING POINT of 40 °C (104°F). PENETRATION TEST Specification test to measure the hardness of bitumen under specified conditions, in which the indentation of a bitumen in tenths ofa millimeter (dram) at 25°C (77°F) is measured using a standard needle with a loading of 100 g and 5s duration. Details of the test can be found in ASTM D5 and/or EN 1426 as well as other sources. PERFORMANCE -GRADED BITUMENS Bitumens classified based on the research results of the Strategic Highway Research Program (SHRP) in the U.S. PERFORMANCE -GRADED (PG) specifications are based on the stiffness of the bitumen at the high- and low-temperature environment in which the bitumen will be expected to perform within pavement. Currently Performance -Graded Bitumens are most widely utilized in the United States and Canada. PETROLEUM PITCH The residue from the distillation of thermal -cracked or steam -cracked residuum and/or catalytic cracked clarified oil with a SOFTENING POINT from 40°C -180°C (104°F - 356°F). Composed primarily of a complex combination of three or more membered condensed ring aromatic hydrocarbons. PLASTOMER A polymer type which exhibits stiffness and strength but does not recover substantially when deformed. Examples of this type of polymer used in bitumens are ethylene vinyl acetate, ethylene methacrylate, polyethylene, and atactic polypropylene. PLY A layer of felt or sheet in a roof membrane; a four -ply membrane has at least four plies of felt or sheet at any vertical cross section cut through the membrane. POLYMER -MODIFIED BITUMEN (POLYMER -MOD- IFIED ASPHALT CEMENT 1N THE U.S.) (PMB/A) Modified Bitumen/Asphalt Cement in which the modifier used is one or more organic polymers. POLYMER -MODIFIED BITUMEN MEMBRANE A factory -made flexible layer of STRAIGHT RUN and/or OXIDIZED bitumen modified with elastomeric or plasto meric polymers with internal or external incorporation of one or more carriers. supplied in roll form ready for use. POLYPHOSPHORIC ACID (PPA) CAS No.: 8017-16-1, Molecular Formula: H6P4013. POLYPHOSPHORIC ACID includes Tong -chain po- GL 101, Third Edition 25 lymerised units of PO4 units. A key feature in POLY - PHOSPHORIC ACID is the absence of free water. PROPANE -PRECIPITATED ASPHALT (PROPANE BITUMEN) See SOLVENT PRECIPITATION. PUG MILL Mixer used to combine stone materials and bitumen in an asphalt -mixing plant. The mixing is effected by high-speed stirring with paddle blades at elevated temperatures. RAFFINATE The part of a liquid, especially an oil, remaining after its more soluble components have been extracted by a solvent. RAKER Person who shovels and rakes excess asphalt, fills in voids, and prepares joints for compaction by rolling to ensure a road surface free from defects. Sometimes referred to as LABORER. REFINERY A facility composed ofa group of separation and chemical engineering unit processes used for refining crude oil into different oil products. RESINS (POLAR AROMATICS) Very adhesive fractions of relatively high molecular weight present in the MALTENES. They are dispersing agents (referred to as peptizers) for the ASPHALTENES. This fraction is separated using solvent precipitation and adsorption chromatography. ROAD OILS Term sometimes used for very soft VACUUM RESIDUE or harder BITUMENS that have FLUX OIL added, or CUTBACKS that have been produced using petroleum with a boiling point greater than 225°C (435°F) added to reduce the viscosity. ROAD OILS are generally used to produce ASPHALT paving mixes for use on very low- volume roads in moderate to cold climates. ROCK ASPHALT Naturally occurring form of ASPHALT, usually a combi- nation of bitumen and limestone. Found in southeastern France, Sicily, and elsewhere. ROLL ROOFING See OXIDIZED BITUMEN MEMBRANE or POLY- MER -MODIFIED MEMBRANE. ROLLER OPERATORS (ROLLERS) Person driving machinery designed to compact the AS- PHALT by rolling to finished specifications. ROLLING THIN FILM OVEN TEST (RTFOT) A common paving BITUMEN test which subjects a thin film of BITUMEN on the inside ofa rolling glass jar to 163°C (325°F) for 85 minutes. See ASTM D2872, or EN 12607-1. ROOFER'S FLUX (also called ROOFING FLUX) A low -viscosity, high -flashpoint, generally paraffinic residue of vacuum distillation of an appropriate petroleum crude oil used as a feedstock in the manufacture of OXI- DIZED BITUMEN used in roofing applications. ROOFING BITUMEN/ASPHALT Bitumen used for manufacture of roofing systems or roofing products, such as bitumen shingles, BURA, POLYMER -MODIFIED membranes, saturated felt un- derlayment. and roofing adhesives. ROOFING CEMENT A material made by adding filler and fibers to either a BITUMEN EMULSION or CUTBACK. BITUMEN to make an adhesive used for maintenance and in applying flashings on a new roof. Depending on the performance characteristics sought for particular cements, the BITU- MEN used in the formulation may be OXIDIZED or STRAIGHT -RUN. ROOFING FELT A sheet material, impregnated with BITUMEN, generally supplied in rolls and used in roof construction. See BITU- MEN ROOFING FELT. ROOFING KETTLE A vessel used to heat binders such as OXIDIZED BITU- MEN for use in the construction of BUILT-UP ROOF- ING and some POLYMER -MODIFIED BITUMEN roof systems. ROOFING SHINGLES A STEEP -SLOPE ROOFING product. BITUMEN roofing shingles are typically made by coating a glass mat with filled COATING BITUMEN and then surfacing with colored mineral granules. ROTARY DRUM DRYER A device in an asphalt -mixing plant used to dry and heat stone materials. SATURANT BITUMEN BITUMEN that is used to saturate organic felt to make roofing felt or to make organic based shingles. It can be STRAIGHT -RUN or OXIDIZED BITUMEN. SATURATES Predominantly straight and branched-chain aliphatic hy- drocarbons present in BITUMENS, together with alkyl naphthenes and some alkyl aromatics. This fraction forms 5 to 20 percent of the mass of BITUMENS. SCREED Leveling device at the rear ofa paving machine. SCREEDMAN Person stationed at the rear of the paver to control the distribution and grade of the ASPHALT mat as the paving machine moves forward. SELENICE A NATURAL ASPHALT from Albania. SELF-ADHESIVE BITUMEN MEMBRANE Roofing or waterproofing POLYMER -MODIFIED BITU- MEN MEMBRANE applied at ambient temperature with the peel and stick method. 26 GL 101, Third Edition SEMI -BLOWN BITUMEN See AIR -RECTIFIED BITUMEN. SKIP HOIST A device for transfer of ASPHALT MIXES from a PUG MILL to storage. SOFT -APPLIED ROOFING BITUMEN roofing products that are applied by heating the BITUMEN membrane sufficiently with a torch or hot-air welder to ensure good adhesion to the substrate. SOFTENING POINT A specification test measuring the temperature, measured in °C, at which material under standardized test conditions attains a specific consistency. (See ASTM D36 and/or EN 1427). SOLVENT EXTRACTS Aromatic byproducts (extracts) obtained from the refining of BASE OILS. SOLVENT PRECIPITATION The process by which a hard product, PROPANE - PRECIPITATED ASPHALT, is separated from a vacuum residue by solvent precipitation (usually with propane). PROPANE -PRECIPITATED ASPHALT is truly a bitu- men by the definitions applied in this monograph. In the USA, this process is called `solvent deasphalting' and the product, SOLVENT -REFINED ASPHALT. SOLVENT -REFINED ASPHALT Term used in the USA for PROPANE -PRECIPITATED ASPHALT, also referred to PDA pitch or PDA asphalt. STEAM -REFINED BITUMENS VACUUM RESIDUES that have been subjected to STEAM STRIPPING. STEAM STRIPPING Injection of steam into a residue which aids VACUUM DISTILLATION. STONE MASTIC ASPHALT, STONE -MATRIX AS- PHALT (SMA) Referred to as STONE MASTIC ASPHALT in Europe or STONE -MATRIX ASPHALT in the United States. SMA is a gap -graded asphalt mixture with bitumen as a binder, composed of a coarse crushed aggregate skeleton bound with a mastic mortar. (In Europe SMA is specified by EN 13108-5, while in the U.S. it is specified regionally by state highway agencies.) It is paved at temperatures typically employed for conventional ASPHALT mixtures. STEEP -SLOPE ROOFING Roofing products designed for a roof slope of more than 14 degrees. STRAIGHT -REDUCED BITUMENS VACUUM RESIDUES used as bitumens. STEAM STRIPPING may have been used in their production. STRAIGHT -REDUCED BITUMENS refer to bitumens produced to a specific target grade without blending with other bitumen grades to achieve the desired result. STRAIGHT -RUN BITUMENS Similar to STRAIGHT -REDUCED BITUMENS and STEAM -REFINED BITUMENS SULFUR -EXTENDED ASPHALT (SULPHUR -EX- TENDED ASPHALT) A hot -mix asphalt in which part of the bituminous binder is replaced by elemental sulfur, typically at levels between 20-40%m of the original bitumen content. SURFACE DRESSING Process used to seal road surfaces; a thin film of BITU- MEN, CUTBACK BITUMEN or BITUMEN EMUL- SIONS is spread, covered with a single or double layer of chippings, and then rolled. SURFACE TREATMENT May include SURFACE DRESSING and other tech- niques, such as spraying with minor amounts of BITU- MEN EMULSION to bind surfaces together. TEAR OFF To remove an existing roof system for replacement. TERMINAL A facility outside a refinery where bitumen is held for intermediate storage prior to delivery to (or collection by) customers. THERMALLY CRACKED BITUMENS Also known as residues (petroleum), thermal cracked, vacuum: BITUMENS produced by thermal cracking. TOPPING PLANT A `stand-alone' distillation plant. Topping plants are usually found in terminals and used to remove distillate materials added to bitumens for transportation purposes. TORCHING Application of a roofing membrane with a propane gas flame, used for melting the side of the roofing membrane, without addition of hot bonding bitumen. This is also called HOT WELDING ROOFING. TRINIDAD LAKE ASPHALT A NATURAL ASPHALT obtained from the La Brea region of Trinidad, UNDERLAYMENT Factory -made flexible sheets of BITUMEN (OXIDIZED or MODIFIED) which are used as underlay to coverings of sloping roofs (e.g. tiles, slates, shingles). VACUUM DISTILLATION Distillation of ATMOSPHERIC RESIDUE under vacuum. VACUUM RESIDUE Residue obtained by VACUUM DISTILLATION. VISBREAKING A relatively mild thermal cracking operation mainly used to reduce the viscosity and pour point of vacuum residues for subsequent use in heavy fuel oils. The process converts a proportion of the residue feedstock to distillate product, e.g. gas oil. GL 101, Third Edition 27 VISCOSITY Resistance to flow of a substance when a shearing stress is imposed on the substance. For BITUMEN products, test methods include vacuum -capillary, cone and plate, orifice -type, and rotational viscometers. Measurements of viscosity at varying temperatures are used by tech- nologists in all industry segments that utilize BITUMEN materials. VISCOSITY -GRADED BITUMEN BITUMEN which is graded and specified by the viscos- ity at a standard temperature, which is typically 60 °C (140°F). ASTM D2171 and EN 12596 are the most com- monly used viscosity tests. WARM -MIX ASPHALT Asphalt mixtures produced at lower temperatures as compared to those typically associated with rolled asphalt pavement. Warm -mix asphalts are produced and placed at temperatures in the range of 100°-140°C (212-280°F) and are typically 10— 0°C (50-100°F) lower than conventional rolled asphalt. WEATHERING TEST Various accelerated durability tests have been developed for OXIDIZED BITUMENs used in roofing applications. The most prevalent is the Xenon. Arc Accelerated Weath- ering test. where thin OXIDIZED BITUMEN films are applied to aluminum panels and then subjected to light, heat, and water sprays in several combinations of time and temperature. See ASTM 13479£1, ASTM D 1669, and. ASTM D1670. WHITE SPIRIT A distillate petroleum product free of rancid or objec- tionable odors, boiling -range 150-200 °C (300-390 °F); sometimes described as "Stoddard solvent" 28 GL 101, Third Edition Appendix 11 Summary European Exposure Data by Country 1-,lble 1. Personal Airborne Exposure Levok. (rngini3) Measured 74 OnPr European Paving Sites Exposure Metric Job category Number of samples Geometric mean (mg/m3) Arithmetic ---Median F mean (mglm3) (mg/re3) Reference number Totalparticulate all 45 * 0.6 12 17 0.58 0.66 ' 2 all except pavers 215 * 0.3-0.7 * 1 pavers 72 * 1.1 * 1 20 0.4 0.7 * 7 5 * 0.58 * 8 16 0.3 * 11 rakers 13 0.4 0.6 * 7 screedmen 10 0.5 0.6 * 7 12 * 0.83 * 8 32 0.3 * * 11 rollers 10 0.2 0.2 * 7 8 0.4 * * 11 others 4 0.3 0.4 * 7 1.)?212Parols pavers 119 * * 2.58 10 screedmen 149 * * 2.78 10 rollers 47 * * 0.98 10 Bitumen fume all 175 0.03 0.10 3a 83 0.13 0.35 . 36 pavers 20 0.15 0.35 * 7 rakers 13 0.17 0.17 * 7 screedman 10 0.12 0.19 * 7 rollers 10 0.04 0.05 * 7 others 4 0.08 0.10 * 7 2arrtgagisulfide all 51 0.28 * 9 Chloroform extractame VOlariVi 58 total * 1.2 . 6 rollers * 0.3 * 6 Cyclohexane extractapie pavers 5 * 0.17 * 8 screedmen 12 * 0.16 * 8 all 17 * 1 5 8 0.6 * 12 PAHs (oie) a •avers 11 * * 0.62 4 12 3.20 4.28 7 12 1.8 * 11 rakers 37 * • 0.64 4 10 2.69 3.50 7 screedmen 11 0.48 4 10 2.97 3.64 7 29 1.6 . * 11 rollers 13 * * 0.50 4 10 1.87 2.38 7 7 1.3 " 11 others 4 0.44 1.09 ,, 7 4-6 rind PAHs (pg/m3) pavers 12 0.07 0.18 * 7 rakers 10 0.18 0.27 • 7 screedmen 10 0.19 0.26 * 7 rollers 10 <0.05 0.14 * 7 others 4 <0.05 <0.05 * 7 SVOCs pavers 20 1.9 4.2 * 7 rakers 13 2.6 3.3 • 7 screedmen 10 1.9 3.1 * 7 rollers 10 0.8 1.1 ' 7 others 4 0.4 0.6 • 7 Oil mist pavers 7 0.23 * 11 screedmen* 9 0.09 . 11 GL 101, Third Edition a) See references 4, 7, and 11 for identification of specific PAHs included in these data. b) Entries with an asterisk (') indicate that these data were not reported. e) Exposure Metrics and sampling and analytical methods vary by country d) Summary statistics from references 1, 8, 9, and 12 are based on analyses in NIOSH 2000 e) Summary statistics from reference 6 are based on analyses in Burstyn et al. 2000. Table 1 References No. Citation Country 1 Byrd and Mikkelsen 1979 Denmark 2 Burstyn et al, 2002a Netherlands 3a Burstyn et al. 2002b, 1991 data Norway 3b Burstyn et al. 2002b, 1992 data Norway 4 Cirla et al. 2007 Italy 5 Claydon et al. 1984 Netherlands 6 Ekstrom 1990 7 Heikkila et al 2002 Sweden Finland 8 Monarca et al. 1987 (summary data from NIOSH 2000) Italy 9 Norseth, et al. 1991 (summary data from NOSH 2000) Norway 10 Rohl et al. 2007 Germany 11 Ulvestad et al. 2007 Norway 12 Virtamo et al. 1979 Finland 30 GL 101, Third Edition Appendix 111 Summary United States Exposure Data by Country The following tables reflect a compilation of U.S. exposure data that was reported in the 2000 NIOSH Health Effects Evaluation of Oc- cupational Exposure to Asphalt (Reference NIOSH Hazard Review Document, Table 4-12) in addition to any new U.S. studies conducted and published since NIOSH 2000 document. Tah 1.4a. Personal Airborne Exposure Levels (mgfm3) Measured at Open U.S. Paving Sites Measurement type Job category Number of Geometric mean Arithmetic mean Reference samples (mm3) (mg/n') number Total particulate pavers 7 .45 1 10 0.17 0.21 3 2 0.8 5 2 0.85 R 6 2 0.62 7 2 0.39 8 1 0.0087 R 9 4 0.34 10 2 0.17 11 44 0.34 12 laborers/rakers 20 0.39 1 7 0.34 0.34 2 3 0.27 0.35 3 5 0.33 5 7 0.27 6 8 0.48 7 4 0.077 R 8 4 0.031 9 4 0.16 10 10 0.22 11 44 0.32 12 screedmen 12 0.72 10 0.48 15 0.24 0.54 0.28 2 0.43 1 2 3 5 2 0.31 6 4 0.70 7 8 0.10 8 4 0.078 (A) 9 2 0.22 10 4 0.12 11 44 0.36 12 rollers 13 5 1 5 4 2 0.23 0.30 0.36 0.053 021 0.18 0.4 0.36 2 3 5 6 7 4 0.057 8 0.04 9 4 0.055 R 10 6 0.10 11 other Respirable particulates pavers rakers screedmen Benzene solubles rollers pavers 37 15 7 20 12 13 7 10 2 0.37 0.19 0.21 0.15 0.27 0,05 0.11 0.05 0.59 0.43 0.23 2 3 R 0.0 1 1 1 1 1 3 5 2 0.33 7 4 0.22 10 44 0.16 12 GL 101, Third Edition 31 Measurement type Job category Number of Geometric mean Arithmetic mean Reference samples (mg/rr13) (mglm3) number laborers/rakers 20 0.10 1 3 0.11 0.16 3 5 0.17 ' 5 8 0.13 7 4 0.055 • 10 44 0.08 12 screedmen 12 0.27 1 2 0.29 2 15 .08 0.13 3 4 0.19 7 2 0.082 ' 10 44 0.15 12 rollers 13 0.06 1 1 0.07 0.07 3 5 0.022 ' 5 2 0.014 ' 7 4 0.030 10 other 15 0.07 0.10 3 Total PACs rakers 24 screedmen 15 0.0036 0.0073 4 4 rollers 11 0.001 4 PAC370 pavers 2 2 0.030 5 0.018 7 1 0.0027 ' 8 2 0.0018 ' 9 2 0.060 ' 10 laborers/rakers 5 0.0079 5 8 0.0081 ' 7 3 0.00039 ' 9 2 0.016 10 2 4 0.017 7 PAC370 screedmen 2 0,0091 5 4 0.0015 8 4 0.00087 9 2 0.072 10 1 0.0039 ' 11 PAC370 rollers 5 0.00018 5 2 0.0014 ' 6 2 0.0011 7 1 0.0011 8 6 0.00007 9 PAC400 pavers 4 2 2 0.0053 0.0043 0.0024 10 5 7 laborers/rakers 1 2 2 5 8 0.00043 0.00027 0.0085 0.0012 0.0011 8 9 10 5 7 screedmen 3 2 2 2 4 0.00009 0.0024 0.0030 0.0013 0.0023 9 10 11 5 7 4 4 2 0.00020 8 0.00015 9 0.0098 rollers 1 5 0.0012 0.00004 2 2 1 6 4 0.00025 0.00015 10 11 5 6 7 0.00017 8 0.00001 9 0.00067 10 32 GL 101, Third Edition Table 4.4a. References a) Note: All Data from original references 1, 2 and 5 -11 are taken from the summary tables in the NIOSH Hazard Review (2000) with one exception. Data for TPM; Screedmen (A), reference 9, were taken from the original report due to inability to corroborate with data reported by NIOSH. European data (Norseth et. al.) was excluded from this analysis since this analysis is U.S. specific. b) Data for references 3, 4 and 12 were taken from original reports published since the NIOSH Hazard Review (2000). c) Entries with an asterisk (') indicate that these data were not reported. d) Reference 3, Kriech et. al. 2002 includes data from sites employing pavers with and without engineering controls. e) Reference 12, Michelsen et. al. 2006 data are the arithmetic means of measurements taken at 11 different sites where all pavers were equipped exclusively with engineering controls. By Number 1 Gamble et al. 1999 2 Flocks 1995 3 Kriech et al. 2002 4 McClean et al. 2004a 5 Miller and Burr 1996b 6 Hanley and Miller 1996b 7 Kinnes et al. 1996 8 Almaguer et al. 1996 9 Miller and Burr 1996a 10 Miller and Burr 1998 11 Hanley and Miller 1996a 12 Mickelsen et al. 2006 In order to examine the entire data set (by task) a statistical summary was generated by calculating the arithmetic means of the study data geometric means and the 95% confidence intervals, weighted by number of samples in each specific task study population (Table 4.4b). As evidenced by this analysis the exposure hierarchy from highest to lowest is as follows: Screedmen, pavers, rakers, rollers, an order that is entirely consistent with the hierarchy established above for European paving workers. Table 4.4b. Consolidated Summary (By Task) of Personal Airborne Exposure Data Reflected in Table 4.4a. U.S. Open Paving Sites —Total Particulate and Benzene Soluble: Measurement type Job category Total number Mean among studies Minimum mean Maximum mean of samples (95% CI, mg/m3) among studies among studies Total particulate pavers 76 0.36 0.009 0.85 (0.32,0.39) rakers 116 0.31 0.031 0.66 (0.29,0.33) screedmen 107 0.37 0.078 0.72 (0.33,0.41) rollers 50 0.15 0.040 0.36 (0.13,0.17) Overall 401 0.32 0.009 0.85 (0.31,0.32) Benzene solubles pavers 69 0.16 0.005 0.59 (0.12,0.21) rakers 84 0.10 0.010 0.31 (0.08,0.11) screedmen 79 0.17 0.005 0.37 (0.10,0.24) rollers 25 0.04 0.014 0.07 (0.03,0.06) Overall 272 0.13 0.005 0.59 (0.12,0.14) The weighted arithmetic means among the study data (Y in the equation below) were calculated by summing the products of each study's number of samples (ni, column 3 in Table 1) and reported mean concentration (yi, column 4 in Table 1), and then dividing this sum by the total number of samples in all the studies: r (,,, - The 95% confidence intervals were calculated as: C1 r Y t rlu,rta-01N 1Y Where s is the sample standard deviation (see below), N is the number of studies, is the desired significance level (1 -CI, or 0.05), and t(/2, N-1) is the upper critical value of the two-sided t distribution with N-1 degrees of freedom. 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Cincinnati, Ohio, USA. 36 GL 101, Third Edition NAPA National Asphalt Pavement Association NAPA Building 5100 Forbes Blvd. Lanham, Maryland 20706-4407 U.S.A. www.hotmix.org napa @ hotmix.org Tel: 301-731-4748 Fax: 301- 731-4621 Toll Free: 1-888-468-6499 GL 101 Third Edition EAPA European Asphalt Pavement Association Rue du Commerce 77 1040 Brussels Belgium www.eapa.arg info@eapa.org Tel: +32.2.502.58.88 Fax: +32.2.502.23.58 NAPA UPDATE lilack enhances green Asphalt association continues to lead environmental crusade By Mike Anti While annual production of HMA paving material has increased by more than 250% over the past 40 years, total emissions from HMA plants have dropped by 97% or more in that same period. 24 JANUARY 2003 The National Asphalt Pavement Association (NAPA) and the hot -mix asphalt (HMA) industry have a track record on environmental stewardship that cannot even be approached by any other, industry that I know of. Our everyday effdrts conserve precious natural Experts say the air quality effects of HMA production have been evaluated more thoroughly than those of any other industry. resources. minimize the impact of our opera- tions on the environment and reduce reliance on landfills. The continuous process of reducing the industry's impact on the environment has led Ill some astonishing results. For example. ui 2002. the U.S. Environmental Protection Agency declared in two separate actions that HMA production facilities do not luive the potential to be major sources or hazardous air pollutants and. further. that all HMA facilities together are trivial sources or specific pollu- tants, These Afelisiing" actions confirmed what we have always believed and what the science shows—emissions front HMA plants arc very low and well-controlled. Experts say the air oluulity effects of HMA production have been evaluated more thor- oughly than those. of any other industry in the country. NAPA, our members and the EPA. have funded studies and worked in partnership for many years to quantity emissions and add to the knowledge base about HMA plants. The investments have been substantial. Over a tour -year period in the early Ie)90s. NAPA itself invested more than $30(L(1(0 in the test - ROADS & BRIDGES ing of seven asphalt plant. Additional finan- cial support for the research also carne from HMA producer members whose plants were tested and from equipment manufacturers and other companies in the industry. The EPA - sponsored testing was estimated to have cost S1.5 million at several HMA facilities around the country. The delisting of asphalt plants was not the first time NAPA and the HMA industry have been recoganzed in a positive way by our part- ners at federal regulatory agencies. The National Institute for Occupational Safety and Health (NIOSH) bestowed the first NORA Award on the partnership that put engineering controls on highway -class pavers. NIOSH recently affirmed that partnership with a grant for the ongoing "phase two"" study of the use and effectiveness of the systems. Not only dues NAPA work effectively with partners to improve our environmental perfor- mance, we have a major program within the industry to encourage and recognize continu- ous improvement in this arena. The Diamond Achievement Commendation for Excellence in Hot Mix Asphalt Plant/Site Operations has more than 365 current participants and is changing the way America thinks about our operations. Taking a positive approach to potential chal- lenges. NAPA sponsors research at the Nation- al Center for Asphalt Technology on ways to reduce emissions and odors where they may occur. We are gaining new knowledge about asphalt binders and devising new tools for contractors. Not only do asphalt pavements provide long - life solutions for highway construction. they also are 1(104 recyclable. In fact. asphalt pavement is the No. I recycled material in the U.S. Some types of asphalt pavement reduce noise pollution and other environmental con- cerns. And. while annual production of HMA paving material has increased by more than 250% over the past 40 years, total emissions from LIMA plants have dropped by 97% or more in than sante period, \Wc have clearly made the case for asphalt as a sustainable material. This is a legacy in which we can take pride. W Acott is president of NAPA, Lanham, Md. www. ROADS B R IDGES. (OM