AQ_F_1700015_20190425_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Winston-Salem Regional Office
AIR QUALITY Carolina Sunrock LLC-Prospect Hill Facility
NC Facility ID 1700015
Inspection Report County/FIPS:Caswell/033
Date: 04/25/2019
Facility Data Permit Data
Carolina Sunrock LLC- Prospect Hill Facility Permit 10529/R01
4266 Wrenn Road Issued 1/3/2018
Prospect Hill,NC 27314 Expires 8/31/2025
Lat: 36d 15.3060m Long: 79d 10.2258m Class/Status Synthetic Minor
SIC: 2951 /Paving Mixtures And Blocks Permit Status Active
NAICS: 324121 /Asphalt Paving Mixture and Block Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Scott Martino Gregg Bowler Scott Martino NSPS: Subpart I, Subpart 000
Compliance Manager CFO Compliance Manager
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 04/25/2019
Inspector's Name Chris Bryant
Inspector's Signature: r ' � Operating Status Operating
Compliance Code Compliance- inspection
Action Code FCE
X
Date of Signature: N 11 ✓ I I MTH On-Site Inspection Result Compliance
Total Actual emissions in TONSIYEAR:
TSP SO2 NOX VOC CO PMIO *HAP
No emissions inventory on record.The emissions inventory is due 06/02/2025.
* Highest HAP Emitted inpounds)
Five Year Violation History: None
Date Letter Tyne Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE: None
Date Test Results Test Method(s) Source(s)Tested

Permitted Emission Sources
Emission Emission Source Control Control System
Source ID T — Description (System ID Description
---- - pl
One drum mix,hot mix asphalt plant(250 tons per hour maximum rated capacity)consisting of:
(Propane/natural gas/No. 2 fuel oil/recycled No. 2 fuel oil/recych d Bagfilter
ES-HMA 1 (NSPS 1) o.4 fuel oil-fired drum dryer/mixer CD-1 (7,778 square feet of
(80 million Btu per hour maximum heat input) filter area)
ES-Sl, ES-S2 ;Two(2)hot mix asphalt storage silos(I50 tons capacity,each) N/A N/A
ES-S3, ES-S4, ES-S5 iThree(3)hot mix asphalt storage silos(200 tons capacity,each) N/A N/A
ES-LO1,ES LO2 ITwo(2)truck loadout operations j N/A N/A j
NNatural gas/No 2 fuel oil fired liquid asphalt cement heater(1.2
ES-HI -) N/A N/A
million Btu per hour maximum heat input)
ES H2 [Natural gas/No 2 fuel oil-fired liquid asphalt cement heater(I.1 N/A N/A
million Btu per hour maximum heat input)
One truck mix,concrete batch plant(120 cubic yards per hour maximum rated capacity)consisting of
ES-RMl Cement storage silo(185 tons capacity)
ES-RM2 F Bagfilterly ash storage silo(135 tons capacity) CD-2 (1,433 square feet of
ES-RM3 iCement/fly ash weigh hatcher(5 tons capacity) filter area)
ES-RM4 Truck loadout operation
One RAP processing operation consisting of:
ES-CRSH(NSPS 000) RAP impact crusher(65 tons per hour maximum rated capacity) MA N/A
ES-CNV(NSPS 000) RAP 36" inclined conveyor N/A N/A
ES-SCN(NSPS 000) TRAP 8'x 20'double deck screen N/A N/A
Insignificant Sources
Exemption Source ofi Source of
ource ID S Source Description Title V
Regulation TAPs. I pollutants?
IES-1 Above ground storage tank containing fuel oil(20,000 gallons capacity) 2Q .0102(g)(4) Yes Yes
IES-2, Two(2)above ground storage tanks containing liquid asphalt cement 2Q.0102(g)(14)(B) Yes Yes
- IES-3 (30,000 gallons capacity, each)- —
Introduction
On August 25, 2019, Chris Bryant, DAQ-WSRO Environmental Specialist, visited Carolina Sunrock LLC - Prospect Hill
Facility in Caswell County for an unannounced targeted compliance inspection. Upon arrival, the inspector observed that
the facility was not in operation. Some equipment such as mixers and silos were laying on the ground. No equipment
was installed, and there did not appear to be any electricity on-site. There we no vehicles in the parking lot, and there
were no company personnel on-site. The facility appeared to be not in operation. The facility contact, Scott Martino,
confirmed that the facility is not operating but would hopefully be up and running by the end of the year. The facility was
issued a new permit on January 3, 2018 but has not yet started operating. According to permit review ROI (Taylor
Hartsfield, 1/3/2018), "Carolina Sunrock LLC - Prospect Hill Facility will be a drum mix, HMA plant capable of
processing 250 tons per hour and a truck mix, concrete batch plant capable of processing 120 cubic yards per hour." A
calculation of the modeling coordinates was done at the site on August 7, 2018. Although the exact location of the
equipment is not known, the location pin was taken at the centermost point.
Emissions Point IDI UTM Coordinates
Center Point 36.256100,-79.170400
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Safety Equipment
Safety shoes, safety glasses, hard hat, safety vest,and hearing protection are required equipment when inspecting this
facility.
Latitude/Longitude Verifications
The latitude and longitude coordinates were verified to be accurate as documented in IBEAM. The exact mapping
coordinates for the permitted equipment via be verified once the equipment has been installed.
Applicable Regulations
According to Condition A.1 the facility is subject to the following regulations: Title 15A North Carolina Administrative
Code (NCAC), Subchapter 2D .0202, 2D .0503, 2D .0506, 2D .0510, 2D .0515, 2D .0516, 2D .0521, 2D .0524 (40 CFR
60, Subparts I and 000), 2D .0535, 2D .0540, 2D .0605, 2D .0611, 2D .1 100, 2D .1806, 2Q .0304, 2Q .0309, 2Q .0315,
and 2Q .0317 (PSD and 2Q .0700 Avoidance) and 2Q .0711. This facility is not subject to RMP requirements of the
112(r) program since it does not use or store any of the regulated chemicals in quantities above the threshold levels in the
rule. The facility is only subject to the General Duty requirements contained in the General Duty Clause.
Discussion
The facility appeared to be not operating as of April 25, 2019. The facility, located at 4266 Wrenn Road, Prospect Hill,
North Carolina, was not constructed,and there was no evidence of any activity at the plant. The Authorized Contact,
Scott Martino was called, and he confirmed that the facility would not be constructed in the immediate future. The
current permit(01529R01)was issued on January 3, 2018, and it will expire on August 31, 2025. The permit has listed
several permitted sources which include drum mixer, storage silos, a truck loadout,and asphalt cement heaters. The
facility appears to be in compliance due to being not constructed or in use.
Permit Conditions/Applicable Regulations
Condition A.2 contains 15A NCAC 2D .0202 permit renewal and emissions inventory requirements. The facility was
issued a new permit on January 3, 2018. The permit expires on August 31, 2025, and the facility is required to submit a
renewal request and air pollution emission inventory report for the 2024 calendar year 90 days prior to the expiration of
the permit. Compliance is expected.
Condition A.3 contains the 15A NCAC 2D .0503 "Particulates from Fuel Burning Indirect Heat Exchangers"
requirement. The condition applies to the two natural gas/No. 2 fuel oil-fired liquid asphalt cement heaters(ES-HI and
ES-H2). The cement heaters will have a combined heat input of less than 10 MM/Btu/hr and are limited to 0.6
lbs/MMBtu. According to the permit review R00,the anticipated particulate matter emissions are equal to 0.0075 and
0.024 Ibs/MMBtu when combusting natural gas and No. 2 fuel oil, respectively. Compliance is expected.
Condition AA contains the 15A NCAC 2D .0506 "Particulates from Fuel Hot Mix Asphalt Plants"requirement. The
propane/natural gas/No. 2 fuel oil/recycled No. 2 fuel oil/recycled No. 4 fuel oil-Fred drum dryer/mixer(ES-HMA 1) is
subject to this regulation. The plant must limit particulate emissions according to the following equations:
E=4.9445 (P)14111 for P<300 tons per hour
E=60 Ibs/hr for P>300 tons per hour
The expected actual emission rate(8.25 Ibs PM/hr) is below the allowable limit(55.4 Ibs PM/hr). Compliance is expected.
Condition A.5 contains the 15A NCAC 2D .510"Particulates from Sand, Gravel,or Crushed Stone Operations"
requirement. The facility must take measures to minimize particulate matter from becoming airborne to prevent
exceedances of the ambient air quality standards for particulates. Fugitive dust must be controlled as referenced in 2D
.0540 and other emissions from crushed stone operations are applicable under 2D .0521. Compliance is expected.
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Condition A.6 contains the 15A NCAC 2D .0515 particulate control requirement.This condition sets the maximum
allowable particulate emissions using the following equations:
E=4.10(P)061 when P_<30 tons/hour
E= 55.0(P)011 - 40 when P> 30 tons/hour
The rule applies to all of the concrete batch sources. As referenced in permit review R00 by Taylor Hartsfield on
September 21, 2017,expected actual emission rates are from the NCDEQ Concrete Batch Plant spreadsheet submitted
with the application. As the expected actual rates are below the allowable rates, compliance is expected.
Emission Emission Source Process Weight(P) Allowable Emission Rate Expected Actual Emission j
Source ID Description [ton/hrl (E)jibs PM/hrl Rate jibs PM/brl
ES-RMl Cement storage silo I 35 41.32 0.117
— -.-.......
ES-RM2 Fly ash storage silo ( 35 r 41 32 0.346
�ES-RM3 �Cement/fly ash weigh hatcher 41.51 �J 4.314
ES-RM4 1Truck load(ut operation 240.966 60.55 4.386
"120 yd'/hr.(448 Ibs cement/yd'+148 Ibs ay ash/yd') 2,000 Ibs/ton=35.76 ton/hr
-'6 120 yd'/hr x(4,1561bs total/yd'- 1401bs water/yd') . 2,000 Ibs/lon=240.96 ton/hr
Condition A.7 contains the 15A NCAC 2D .0516 "Sulfur Dioxide Emissions from Combustion Sources" requirement.
The condition,applicable to the drum dryer/mixer(ES-HMA 1)and two liquid asphalt cement heaters(ES-HI and ES-
1­12), sets the maximum allowable sulfur dioxide emissions rate to be less than 2.3 pounds per million Btu heat input. The
emission factors from AP-42 Tables 1.3-1 and 1.4-2(borrowed from permit review R00)were used to calculate emissions
for the asphalt cement heaters when combusting natural gas and No. 2 fuel oil. AP-42 Table 11.1-7 was used to calculate
emissions for the drum mixer when combusting natural gas,No. 2 fuel oil,and No. 4 fuel oil. The drum dryer/mixer (ES-
HMAI) has a sulfur dioxide emission rate of 0.011 Ibs/MMBtu(natural gas), 0.034 Ibs/MMBtu(No. 2), and 0.185
Ibs/MMBtu(No. 4). The two liquid asphalt cement heaters have a sulfur dioxide emission rate of 0.0059 Ibs/MMBtu
(natural gas)and 0.51 Ibs/MMBtu (No. 2). Compliance is expected.
Condition A.8 contains the 15A NCAC 2D .0521 visible emissions control requirement. This facility is limited to 20%
opacity visible emissions, for sources manufactured after July 1, 1971, when averaged over a six-minute period. No
visible emissions were observed during this inspection because the business was not constructed. Compliance is
expected.
Condition A.9 contains the 15A NCAC 2D .0524 "New Source Performance Standards"that pertain to the
propane/natural gas/No. 2 fuel oil/recycled No. 2 fuel oil/recycled No. 4 fuel oil-fired drum dryer/mixer. The permittee
must comply with all notification,testing, reporting, recordkeeping,and monitoring requirements as promulgated under
40 CFR 60, Subpart I "Hot Mix Asphalt Facilities." Within 15 days after start-up of the HMA plant,the facility is
required to notify the DAQ of the start-up date in writing. A source test will need to be conducted on the rotary drum mix
asphalt plant(controlled by a bagfilter, CD-I)to determine compliance with the emission limit of 90 mg/dscm (0.04
gr/dscO and the opacity limit of 20%. The facility is not open and has therefore not submitted the initial start-up
notification or performed any source testing. Compliance is expected.
Condition A.10 contains the 15A NCAC 2D .0524 "New Source Performance Standards"that pertain to the crusher,
grinding operation, screening operation, bucket elevator, bagging operation, storage bin, enclosed truck, or loading
station. The rule is promulgated through 40 CFR 60, Subpart 000. Within 15 days after start-up of each source, the
facility must notify the DAQ of the start-up in writing. For the affected source, which will have commenced operation
after April 22, 2008, the visible emissions are limited to 12% opacity for crushers and 7% opacity from the belts, screens,
and other sources. A source test, using EPA Method 9, must be conducted on the crushers, screen, and conveyor. Once
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operating,the facility must perform periodic inspections of the wet suppression systems. The documentation of these
inspections must be recorded in a logbook. Compliance is expected.
Condition A.11 contains the 15A NCAC 2D .0535 notification requirement for excess emissions during a malfunction or
breakdown that lasts for more than 4 hours. The facility is not operating. No incidents or malfunctions were reported.
There are no issues registered in IBEAM for this facility. Compliance with the condition is expected.
Condition A.12 contains the 15A NCAC 2D .0540 fugitive dust control requirement. No fugitive dust was observed
traveling beyond the property boundaries during this inspection. According to the DAQ IBEAM database, no complaints
have been received regarding fugitive dust emissions at this facility. Compliance with this condition is expected.
Condition A.13 contains the 15A NCAC 2D .0605 general recordkeeping and reporting requirements section. The DAQ
director has established that all hot mix asphalt plant must source test for compliance every 10 years at a minimum.
Filterable and condensable particulate matter is tested through EPA Methods 5 and 202. The target parameters for the tests
are reinforced in 15A NCAC 2D .0506 and .0524. The visible emissions test should be conducted with Method 9 on the
crushers, conveyors, belts, and screen in accordance with 15A NCAC 2D .0524. This includes the initial 40 CFR 60,
Subpart 000 source tests, which must be conducted within 60 days after achieving maximum productions and within 180
days of actual start-up. Furthermore, a testing protocol must be provided 45 days to DAQ prior to testing. The facility
must notify this office 15 days prior to testing. Protocol, setup, and testing must be performed in accordance with 2D
.2602. Compliance is expected.
Condition A.14 contains the 2D .0611 requirements for bagfilter maintenance and recordkeeping. The bagfilters(CD-I
and CD-2)are subject to this rule. The facility is required to perform, at a minimum, an annual (for each 12-month period
following the initial inspection) internal inspection of the bagfilter systems and perform periodic inspections and
maintenance as recommended by the equipment manufacturer.The results of all inspection and maintenance activities
must be recorded in a logbook. The facility is not operating yet and does not have any bagfilter or maintenance records.
Compliance is expected.
Condition A.15 contains the 15A NCAC 2D .1100"Control of Toxics Air Pollutants"requirement. The hot mix asphalt
(HMA)facility has modeled for arsenic unlisted compounds(ASC-other), benzene, formaldehyde,mercury vapor,and
nickel metals since the expected actual emissions are above the respective toxic emission rates. The affected sources are
the drum dryer/mixer, storage silos, truck loadouts, liquid asphalt heaters, and batch plant. The final/revised modeling
analysis was received from the facility on September 14,2017. The modeling adequately demonstrated compliance with
the maximum allowable ambient level (AAL)according to DAQ-AQAB Meteorologist,Nancy Jones. Using five years of
meteorological data collected in the Burlington and Greensboro areas, five toxics(arsenic, benzene, formaldehyde,
mercury, and nickel) were evaluated against impacts on elevated terrain. The current modeling analysis was taken on-site,
at 25-meter intervals, and extending 2,000 meters from the property line. The following table illustrates the results of the
analysis.
Averaging Maximum AAL AAL
Emission(s)Source TAP(CAS#) Emissions Rates Concentration 3
Period lµg/m'i llrg/m l 1 ]
_i
Pro ane/natural Arsenic unlisted compounds
p I 4.911bs/yr 0.00158 0.0021 75
gas/No.2 f SC-other
uel (A ) _ Annual _
oil/recycled No.2 1 Benzene(71-43-2) 3,470 Ibs/yr F112 0.12 93
fuel oil/recycled No. _ _--..._ -...-.__
4 fuel oil-fired drum �. Formaldehyde(50 00 0) 3 19 Ibs/hr 1 hr 62 150 ) 41
_ __ ___...__
dryer/mixer Mercury vapor(7439-97 6) 0.0624 Ibs/24 hrs 24-hrs I 0.00115 0 6 2
(ES-HMAI) Nickel metal (7440- 22-0) I.51 Ibs/24-hrs � 0.215 6 ^� 4
5

ximum
Emissions Source TAP(CAS#) Emissions Rates Averaging
g Concentration .l AA
1'l /oL
Arsenic unlisted compounds 0.168 Ibs/yr
j (ASC-other) Annual
Natural Benzene( - - . s
' fuel oil-fired
liquid o.2 Benzene 7143 _2) 00861 Ib /yr_
asphalt cement Mercury vapor
(50-00-0) 0.00113 Ibs/hr 1-hr
r
heaters(ES-H 1) por(7439-97 6) r 0.000346 Ibs/24 hrs
Nickel metal(7
_.._ 440-02-0)_ 0.000346_ lbs/24-hrs__.... 24-hrs
Arsenic unlisted compounds 0.154 lbs/yr
(ASC-other) --� Annual
Natural Bed liquid
2 r —Benzene( )--07 yr
fuel oil-tired liquid 1 Benzene(71-43-2 0.0789 lbs/
asphalt cement Formaldehyde(50-00-0) 0.00104 Ibs/hr 1-hr See above-the above values_._ __ - ---
-_
Mercury vapor(7439-97 6) 0.000317 Ibs/24 hrs 24 hrs are presented as facility-wide.
heaters(ES-H2) -
Nickel metal (7440-02-0) 0.0003171bs/24-hrs
Five hot mix asphalt ' Benzene(71-43-2) 5.12 Ibs/yr,each Annual
storage silos(ES-S 1
through ES-SS) Formaldehyde(50-00-0) 0.0210 Ibs/hr, each I-hr
Two truck loadout Benzene(71-43-2) 2.84 Ibs/yr,each j Annual
operations(ES-LOI
and ES-1_02) I Formaldehyde(50-00-0) 0.000732 Ibs/hr,each I hr
One truck mix. Arsenic unlisted compounds 2.31 Ibs/yr Annual
concrete batch plant (ASC-other)
(ES-RM1 through
ES-RM4) Nickel metal(7440-02-0) 0.0185 Ibs/24-hrs 24-hrs
To ensure compliance,the facility must limit production to less than 1,488,581 tons per year of asphalt. The heights and
geodic positioning should be re-evaluated once the facility has been fully constructed. The monthly asphalt production
must be recorded in a logbook and kept on-site. In addition,the facility will be required to report, within 30 days after
each calendar year(by January 30) the total amount in tons of hot mix asphalt produced for the previous calendar year.
The facility has not produced any asphalt to-date. Geographic information, stack heights, and other restrictive condition
under 2D .1100 will be re-evaluated once the facility is up and running. Compliance is expected.
Condition A.16 15A NCAC 2D .1806 contains the control of odorous emissions requirement. No objectionable odors
around the facility boundary were noted during the inspection. There have been no complaints regarding odors at the
facility. Compliance with the condition is expected.
Condition A.17 15A NCAC 2Q .0304 contains the zoning specific requirements. The rule states that the facility must
comply with all applicable local ordinances that apply to the construction or operation of the facility. The proposed
operation is expected to comply with all applicable ordinances, Compliance is expected.
Condition A.18 ISA NCAC 2Q .0309 contains the language in accordance with North Carolina General Statute 143-
215.108(c), which allows the Director to modify or reissue the permit with additional limits or restrictions to demonstrate
compliance. Additional information such as emission estimates or more modeling may be required. Compliance is
expected.
Condition A.19 15A NCAC 2Q .0315 contains the"Synthetic Minor Facilities" requirements. The facility is limited to
100 tons per year of sulfur dioxide(S02)and carbon monoxide(CO)emissions. Therefore, the facility is considered
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synthetic minor and cannot produce more than 1,488,581 tons of asphalt per year. Also, the recycled No. 4 fuel oil is
limited to no more than 0.5%. Fuel supplier certifications must be kept on-site. The facility is required to report by
January 30 of each year the total amount of asphalt produced and the facility-wide year sulfur dioxide and carbon
monoxide emission. Compliance is expected.
Condition A.20 15A NCAC 2Q .0317 contains the avoidance condition to avoid applicability of 15A NCAC 2D .0530
"Prevention of Significant Deterioration." The facility is limited to 250 tons per year of sulfur dioxide emissions, facility-
wide. The facility is not currently constructed or operating. Compliance is expected
Condition A.21 15A NCAC 2Q .0317 contains the"Vendor Supplied Recycled Fuel Oil Requirements"to avoid
applicability of 2Q .0700"Toxic Air Pollutant Requirements." For the use of No. 2 and No. 4 fuel oils,the facility must
record and maintain records(for a minimum of three years)the actual amount of recycled fuel oil delivered and
combusted on an annual basis. The received loads must contain a delivery manifest, batch specific analytical report,
signature information,and a certification that there was no detectable PC13's. No operations have commenced at the
facility and zero recycled fuel has been delivered. Compliance is expected.
NSPS/NESHAP
The facility is subject 40 CFR 60, Subpart 1 "Hot Mix Asphalt Facilities." The specifics of the requirement are discussed
in Condition A.9. The facility is also subject to 40 CFR 60, Subpart 000 "Standards of Performance for Nonmetallic
Mineral Processing Plants" as discussed in Condition A.10. Furthermore, the facility has testing requirements that must
be performed in accordance with the EPA Reference Methods contained in 40 CFR 60, Appendix A. These are described
in Condition A.13 "Testing Requirements."
Facility-Wide Emissions
Expected and potential emissions from permit review R00(Taylor Hartsfield, 9/21/17). The facility-wide emissions were
calculated by adding the emissions from the NCDEQ asphalt,fuel oil combustion, and concrete batch spreadsheets.
Potential emissions before controls were based on a maximum production rate of 250 tons per hour, and 8,760 hours per
year, and a sulfur content of 2.1%. After control emissions are assuming a sulfur content of.5% and a production rate of
1,488,581 tons per year.
Expected Actual Emissions Potential Emissions [tons/year]
Pollutant
[tons/year] Before controls/limits After controls/limits
PM 27.91 - 707.80 54.41
PMio 14.32 233.48 ' -.. 31.21
PMio for Title V* 61.25+0.23* 61.48 20.54+0.23* =20.77
SOz _ 5.12 �- 665.79 67.43 -
---�- - 42.38 ._....-.
CO 16.93 -145.48 F 99.00
6.04 52.69 35.82
HAPTmei ( 0.70 1I26 7.66
HAPH,,;h,,1(Formaldehyde) 0.40 3.49 2.37
*For Title V applicability.only emissions from the cement and 0y ash storage silos after controls are considered from the concrete batch plant.
'?fhis is because the EPA considers emissions from cemenVny ash scales(weigh batchers)and truck loading operations to be fugitive and
;uncontrolled. In addition,the EPA considers the baglilter for the cement and 0y ash silos to be integral.Therefore,the facility does not trigger
;Synthetic Minor for PMio.
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Permit Issues
The facility appears not to be in operation. The facility is not constructed. According to a phone conversation between
this inspector and the facility contact(Scott Martino)on July 13, 2018, the facility was"still waiting"to finish setup of the
facility and would not be in operation until at least the fourth quarter of 2018. Mr. Martino has been made aware of the
testing requirements.
The stack coordinates should be verified for Toxics Modeling once the facility is fully up and running.
Source Tests
No stack testing or VE testing has ever been conducted at this facility. The facility is subject to 40 CFR 60,
Subpart I and 000, which outline the source testing requirements. Additional testing regulations are included in
Condition A.13-15A NCAC 2D .0605 "General Recordkeeping and Reporting Requirements."
Compliance History
The facility has not had any Notices of Deficiency or Violation in the past five years. The facility has not been
constructed.
Conclusion
The facility was found to be in compliance with its Air Quality Permit because it has not been constructed and is not
operational.
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