Preparing Your Hot Mix Asphalt Plant for Air Permit Compliance Testing

The saying “Time flies” never seems more appropriate than when air permits need to be renewed for Hot Mix Asphalt (HMA) plants.

If your plant’s permit is expiring soon (or even if it’s a bit down the road), it may benefit you to review the EPA-mandated testing required under your state-issued air permit.  With this in mind, allow us to provide a brief overview about air emissions testing for Hot Mix Asphalt plants.

Mobile Asphalt Plant by Wikisay (Own work) [CC BY-SA 3.0 ( or GFDL (], via Wikimedia Commons

Mobile Asphalt Plant by Wikisay

Why are Hot Mix Asphalt plants required to test air emissions?

In the past, HMA plants were notorious for generating noticeable levels of dust, smoke, odors, and noise.   In 1973, the EPA enacted New Source Performance Standards (NSPS), which required HMA producers to pass strict emission standards and install control systems to prevent the release of dust and smoke into the air. A facility must also meet stringent visible emissions tests in order to comply with regulations.  These NSPS rules have had a dramatic effect on the decreased levels of pollution emitted by HMA plants, and thus the testing continues to be a part of the regulations with which HMA plants must comply.

When do Hot Mix Asphalt plants need to test for air emissions?

The date by which an HMA plant must conduct compliance testing and submit a report to the state EPA office is outlined in each plant’s individual air permit.  In some cases, the air emissions test report may be due 12 months or more before the current permit expires.

It is important to note that new HMA plants are required to conduct performance testing within 60 days after achieving maximum production rate, but no later than 180 days after initial startup of the facility. (See 40 CFR 60 Subpart A §60.8)

Nearly all HMA plants operate on a limited calendar, with summer being the busiest season.  As a result, there are a limited number of days available to perform emissions testing.  It is best to plan testing so that it occurs earlier than the permit requires in case the weather causes a delay or cancellation of the intended testing.

How far in advance must Hot Mix Asphalt plants provide notice of testing to the state authorities?

NSPS rule 40 CFR 60 Subpart A §60.8 specifically requires owners to notify the state regulatory agency 30 days in advance of the anticipated test date.

The state authority may also require submission of protocols in advance of testing.  Check your individual air permit for your state’s test protocol submission rules.

What tests are required under NSPS 40 CFR 60 Subpart I – Standards of Performance for Hot Mix Asphalt Facilities?

 According to 40 CFR 60 Subpart I, the following EPA Methods are required for air compliance testing at Hot Mix Asphalt plants:

  • EPA Method 5 – Measures Filterable Particulate Matter (FPM)
  • EPA Method 9 – Measures Visible Emissions (VE)

Some states require additional particulate testing via EPA Method 202, although the NSPS does not require it.  Please check with your state regulatory agency for the requirements concerning your facility.

When are air emissions test reports due to the state regulatory office?

It depends.  For instance, South Carolina requires a hard copy in office (not just postmarked) by the 30th calendar day post-test, but North Carolina allows 60 days to submit the report.

However, we recommend that you consult your air permit for a specific answer.  Your state-issued air permit will outline all the specifics for your emissions compliance requirements.

Does ESS test air emissions at Hot Mix Asphalt plants?

Yes.  ESS currently conducts air emissions testing for Hot Mix Asphalt plants in North Carolina, South Carolina, and Virginia.

With some of the most experienced testing staff in the industry, ESS can meet all of your testing needs for a competitive price.  Our staff of professionals strives to provide courteous, timely service that exceeds client expectations.

Call us at 1-888-363-0039 or send an e-mail to [email protected] to discuss your specific air testing needs.  We will be happy to assist you.