AQ_F_1700015_20220408_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: 04/11/2022
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 Terry Mannis Scott Martino NSPS: Subpart I, Subpart 000
Envir.Compliance Chief Financial Officer Envir.Compliance
Manager [phone] Manager
[phone] [phone]
Compliance Data
Comments: None.
Inspection Date 04/08/2022
Inspector's Name Blair Palmer
Inspector's Signature: DMM Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: 04/11/2022 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *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 Description Sy
st m Description
One drum mix, hot mix asphalt plant(250 tons per hour maximum rated capacity)consisting of:
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Emission Emission Source Control Control System
Source ID Description Sy
ID m Description
Propane/natural gas/No.2 fuel oil/recycled No.2 fuel oil/recycled Bagfilter(7,778 square
ES-HMA1 (NSPS I) No.4 fuel oil-fired drum dryer/mixer(80 million Btu per hour CD-1 feet of filter area)
maximum heat input)
ES-S1,ES-S2 Two(2)hot mix asphalt storage silos(150 tons capacity, N/A N/A
each)
ES-S3,ES-S4,ES-SS Three(3)hot mix asphalt storage silos(200 tons capacity, N/A N/A
each)
ES-1,01,ES-L02 jTwo(2)truck loadout operations N/A N/A
ES-H1 Natural gas/No. 2 fuel oil-fired liquid asphalt cement heater N/A N/A
(1.2 million Btu per hour maximum heat input)
ES-H2 Natural gas/No. 2 fuel oil-fired liquid asphalt cement heater N/A N/A
(1.1 million Btu per hour maximum heat input)
One truck mix,concrete batch plant(120 cubic yards per hour maximum rated capacity)consisting of:
ES-RM1 ICement storage silo(185 tons capacity)
ES-RM2 jFly ash storage silo(135 tons capacity) Bagfilter(1,433 square
ES-RM3 Cement/fly ash weigh batcher(5 tons capacity) CD 2 feet of filter area)
ES-RM4 ITruck loadout operation
One RAP processing operation consisting of:
ES-CRSH(NSPS RAP impact crusher(65 tons per hour maximum rated N/A N/A
000) capacity)
ES-CNV(NSPS RAP 36" inclined conveyor N/A N/A
000)
ES-SCN(NSPS 000)IRAP 8'x 20' double deck screen I N/A N/A
Insignificant Sources:
Source F Exemption Source Source of
Source Description of Title V
ID Regulation TAPs? Pollutants?
IES-1 Above ground storage tank containing fuel oil(20,000 gallons F2Q .0102(g)(4) Yes Yes
capacity)
IES-2, Two(2)above ground storage tanks containing liquid asphalt F 2Q .0102 yes Yes
IES-3 cement(30,000 gallons capacity, each) (g)(14)(B)
Introduction:
On April 8, 2022, Blair Palmer, DAQ-WSRO Environmental Specialist 11, visited Carolina Sunrock LLC - Prospect Hill
Facility in Caswell County for a targeted compliance inspection. During the visit,Mr. Palmer confirmed that the site was
not operational. No equipment was installed,and there did not appear to be any electricity on-site. This inspector performed
a targeted inspection previously on April 13,2021 and confirmed that the facility had not started construction. The facility
was issued a new permit on January 3,2018. According to permit review RO1 (Ms.Taylor Hartsfield, former WSRO-DAQ
employee, now RRO Regional Supervisor for DAQ), on January 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
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processing 120 cubic yards per hour." This should be verified upon full operation. 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
Safety Equipment:
Safety shoes,safety glasses,hard hat,safety vest,and hearing protection are most likely required PPE equipment when
inspecting this facility,but this should be verified once the plant becomes operational.
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 .1100, 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 8,2022. The facility will be located at 4266 Wrenn Road,Prospect
Hill,North Carolina,was not constructed,and there was no evidence of any activity at the plant. Therefore,the facility is
in compliance.
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 at this time.
Condition A.3 pertains to 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-H1 and
ES-1­12). 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 lbs/MMBtu when combusting natural gas and No. 2 fuel oil,respectively. Compliance is expected.
Condition A.4 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-fired drum dryer/mixer(ES-H1\4A1) is
subject to this regulation. The plant must limit particulate emissions according to the following equations:
E=4.9445 (P)°.a316 for P<300 tons per hour
E=60 lbs/hr for P>300 tons per hour
The expected actual emission rate(8.25 lbs PM/hr) is below the allowable limit(55.4 lbs PM/hr). Compliance can be
expected.
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Condition A.5 contains the 15A NCAC 2D .0510 "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. No
evidence of dust nor any complaints have been received,even though plant is not built.
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)0.61 when P<_30 tonsihour
E=55.0(P)o.ii-40 when P>30 tons/hour
The rule applies to all 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 Expected Actual
Source ID Description [ton/hr] Rate(E) [lbs PM/hr] Emission Rate [lbs
PM/hr]
ES-RM1 Cement storage silo 35 41.32 0.117
ES-RM2 Fly ash storage silo F35 41.32 0.346
ES-RM3 Cement/fly ash weigh 35.76a 41.51 4.314
batcher
ES-RM4 Truck loadout operation 240.96b 60.55 4.386
a 120 yd3/hr x (448 lbs cement/yd3+ 148 lbs fly ash/yd3)-2,000 lbs/ton=35.76 ton/hr
b 120 yd3/hr x (4,156 lbs total/yd3 - 140 lbs water/yd3)-2,000 lbs/ton=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-HMA1)and two liquid asphalt cement heaters(ES-H1 and ES-
H2), 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-
HMA1)has a sulfur dioxide emission rate of 0.011 lbs/MMBtu(natural gas), 0.034 lbs/MMBtu(No. 2),and 0.185
lbs/MMBtu(No. 4). The two liquid asphalt cement heaters have a sulfur dioxide emission rate of 0.0059 lbs/MMBtu
(natural gas)and 0.51 lbs/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 pertains to 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 subject HMA plant,the facility is required to notify
DAQ of start-up. A source test will need to be conducted on the rotary drum mix asphalt plant(controlled by a bagfilter,
CD-1)to determine compliance with the emission limit of 90 mg/dscm(0.04 gr/dscf)and the opacity limit of 20%. The
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facility is not constructed and has 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 Reclaimed
Asphalt Pavement(RAP)crusher, conveyor, and screen. 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 crusher, screen, and conveyor. Once 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 that have been received in the source file and/or registered in IBEAM for this permitted 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 test(s),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-1
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 therefore does not have any bagfilter or maintenance
records.
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(for formaldehyde only)memorandum by Nancy Jones,DAQ Meteorologist for Air Quality Analysis Branch
(AQAB), was issued on September 14,2017. The following was borrowed from Ms. Jones, as part of the analysis.
"AERMOD (16216r)using five years(2011-2015)of meteorological surface data from Burlington and upper air data
from Greensboro was used to evaluate impacts in elevated terrain. Source locations and release parameters are attached.
Direction-specific building dimensions,determined using EPA's BPIP-Prime program,were used as input to the model for
building wake effect determination.Receptors were placed around the facility's property line at 25-meter intervals.
Receptors were spaced at 100 meter intervals out to 2,000 meters from the property line."The following table illustrates
the results of the modeling analysis.
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Maximum
Averaging L AAL
Emission(s) Source TAP(CAS#) Emissions Rates period Concentration /m3 o/a[µg/mil [AA
µg l [ ]
Arsenic unlisted 4.91 lbs/ r 0.00158 0.0021 75
!, Propane/natural Icompounds(ASC-other) y Annual
gas/No. 2 fuel
oiUrecycled No.2 Benzene(71-43-2) 3,470 lbs/yr 0.112 0.12 93
fuel oil/recycled No. Formaldehyde(50-00-0) F 3.19 lbs/hr 1-hr 62 F 156 F 41
4 fuel oil-fired drum Mercury vapor(7439-97-
dryer/mixer 6) 0.0624lbs/24-hrs 0.00115 0.6 I 2
(ES-HMA 1) 24-hrs
Nickel metal(7440-02-0) 1.51 lbs/24-hrs 0.215 I 6 -F
Arsenic unlisted 0.168 lbs/yr
compounds(ASC-other) Annual
Natural gas/No. 2 Benzene(71-43-2) 0.0861 lbs/yr
fuel oil-fired liquid Formaldehyde(50-00-0) 0.00113 lbs/hr 1-hr
asphalt cement
heaters(ES-HI) Mercury vapor(7439-97- 0.0003461bs/24-hrs
6) 24-hrs
Nickel metal(7440-02-0) 0.000346 lbs/24-hrs
Arsenic unlisted 0.154 lbs/yr
compounds(ASC-other) [Annual
Natural gas/No. 2 Benzene(71-43-2) 0.07891bs/yr
fuel oil-fired liquid Formaldehyde(50-00-0) 0.00104 lbs/hr 1-hr
asphalt cement See above—the above values
heaters(ES-H2) Mercury vapor(7439-97- 0.0003171bs/24-hrs are presented as facility-wide.
6) 24-hrs
Nickel metal(7440-02-0) 0.000317 lbs/24-hrs
Five hot mix asphalt Benzene(71-43-2) 5.12 lbs/yr, each Annual
storage silos(ES-S 1
through ES-SS) Formaldehyde(50-00-0) FO.02101bs/hr, each 1-hr
Two truck loadout Benzene(71-43-2) 2.84 lbs/yr, each Annual
operations(ES-LO1 0.000732 lbs/hr,
and ES-LO2) [Formaldehyde(50-00-0) each 1-hr
One truck mix, Arsenic unlisted 2.31 lbs/yr [Annual
concrete batch plant compounds(ASC-other)
(ES-RM1 through
ES-RM4) Nickel metal(7440-02-0) 0.0185 lbs/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 confirmed once the facility has been fully constructed. The facility will be required to
record monthly asphalt production in a logbook and kept on-site. In addition,the facility is 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. Compliance is indicated at this time. The last annual
report was received at the WSRO on January 19,2022 indicating no production.
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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 received in the WSRO. Compliance with the condition indicated at this time.
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. Compliance will be
evaluated upon construction of the facility.
Condition A.18 15A 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.
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(SO2)and carbon monoxide(CO)emissions. Therefore,the facility is considered
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% sulfur,by weight. Fuel supplier certifications must be kept on-site. The last annual report
was received at the WSRO on January 19,2022 indicating no production. Compliance is indicated at this time.
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)of 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 PCB'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 I"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
under Condition A.13, "Testing Requirements."
Facility-Wide Expected Emissions:
The following was taken from permit review R00 on September 17,2017, by Ms. Taylor Hartsfield, former WSRO-
DAQ Environmental Engineer,now RRO Regional Supervisor. 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 0.5%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
PM10 14.32 233.48 31.21
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Expected Actual Emissions Potential Emissions [tons/year]
Pollutant
[tons/year] Before controls/limits F After controls/limits
PMIo for Title V* 61.25+0.23* =61.48 20.54+0.23* =20.77
SO2 5.12 665.79 67.43
NO, 4.69 61.66 F42.38
CO 16.93 145.48 99.00
VOC 6.04 52.69 F35.82
HAPTotal F 0.70 11.26 F 7.66
HAPxignest(Formaldehyde) 0.40 3.49 2.37
*For Title V applicability,only emissions from the cement and fly ash storage silos after controls are considered from the concrete
batch plant.This is because the EPA considers emissions from cement/fly ash scales(weigh batchers)and truck loading operations to
be fugitive and uncontrolled.In addition,the EPA considers the bagfilter for the cement and fly ash silos to be integral.Therefore,the
facility does not trigger Synthetic Minor for PMto.
Permit Discussion:
The facility is not yet constructed, and it is unclear when the facility will begin constriction and operation at this
permitted location.
The stack coordinates will be verified for Toxics Modeling once the facility is fully operational and all equipment is in
place.
Source Tests Requirements:
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 include source testing requirements. The testing requirements are detailed in Condition A.13-15A NCAC
2D .0605 "General Recordkeeping and Reporting Requirements."
Compliance History since the Permit Issuance and within last five years:
The facility has not had any Notices of Deficiency(NOD)or Notice of Violation(NOV)within the past five years. The
facility has yet to be constructed.
Status/Conclusion:
The facility was found to be complying and has been fulfilling the reporting requirements as outlined in the current
permit, even though the plant has not yet begun construction.
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