AQ_F_0100308_20211202_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Winston-Salem Regional Office
AIR QUALITY Alamance Aggregates,LLC
NC Facility ID 0100308
Inspection Report County/FIPS: Alamance/001
Date: 12/02/2021
Facility Data Permit Data
Alamance Aggregates, LLC Permit 10612/R00
342 Clark Road Issued 4/15/2019
Snow Camp,NC 27349 Expires 3/31/2027
Lat: 35d 51.9816m Long: 79d 25.1814m Class/Status Small
SIC: 1429/Crushed And Broken Stone Nee Permit Status Active
NAICS: 212319/Other Crushed and Broken Stone Mining and Quarrying Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact
SIP
Chad Threatt Chad Threatt Chad Threatt NSPS: Subpart 000
Vice President Vice President Vice President
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 12/02/2021
Inspector's Name Chris Bryant
Inspector's Signature: DMM Operating Status Operating W* &7j
Compliance Status Compliance- inspection
Action Code FCE
Date of Signature: tIZ 40
Z- Inspection Result Deficiency
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 " HAP
No emissions inventory on record.The emissions inventory is due 12/31/2026.
X Highest HAP Emitted inpounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE: None
Date Test Results Test Method(s) Source(s)Tested
Permitted Sources
..._._........_ ........_. ._ __. .
Emission Emission Source Control Control System
Source ID Description System ID Description
......... ......... _._ ._._..... ...._.... . ......... .. ..... i
;Non-metallic Mineral Processing Plant, utilizing water suppression with no other control devices,including:
... . .... . .. . ..... .... ....... . . . .
ES-Crush Crushing operations N/A N/A
(NSPS-000)
.............._........._ _ .... .... ......... ......... _........ _.__......__.__...._..._. _............ ...._...........
ES-Screen Screening operations N/A N/A
(NSPS-000) III
ES-Convey Conveying operations N/A N/A
(NSPS-000)
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Introduction
On December 2,2021, Chris Bryant, Environmental Specialist of DAQ-WSRO, met with Mr. Chad Threatt,Vice
President of Alamance Aggregates, LLC, for an announced compliance inspection. The inspection was scheduled in
advance to ascertain potential safety concerns and ensure the facility contact would be on-site. The facility is permitted as
a non-metallic mineral processing plant that is capable of crushing 700 tons per hour. Mr. Threatt is considered the
facility, invoice,technical,and authorized contact.Alamance Aggregates,LLC was issued its first permit on April 15,
2019 and is beginning to commence operation at 342 Clark Road in Snow Camp,NC. The facility was last inspected and
found to be in compliance on April 8, 2020 by this inspector. At that time there was not equipment on-site. It was
established during an email on March 25,2020 with the facility contact, Chad Threatt,that the facility had not yet
commenced construction. Mr. Threatt indicated during that conversation that the company was hopeful to break ground
by in the year 2020. Mr.Threatt indicated via email correspondence with Mr. Bryant that the crushing, conveying, and
screening equipment started up on August 19,2021. As of December 2,2021,the facility has five emission sources on-
site, including the main jaw crusher,cone crusher,2 conveyors, and screen. IBEAM contacts are up to date. Expected
operating schedule is 16 hr/day, 7 days/wk and 52 wk/yr(5,824 hr/yr). This facility was issued a"flexible"permit which
allows the addition or removal of equipment from the facility. The emission sources(see permitted sources above) are
categorized as ES-Crusher for all crushing operations,ES-Screen for all screening operations, and ES-Convey for all
conveying operations.
Safety Equipment
When in operation; safety shoes,hard hat and eye protection are required. As with DAQ-WSRO policy,a reflective vest
and hearing protection is required for quarry visits. Also, inspectors should use wheel chocks at this facility.
Applicable Regulations
Applicable regulations for this facility include: Title 15A North Carolina Administrative Code(NCAC), Subchapter 2D
.0202,2D .0510,2D .0524(40 CFR 60, Subpart 000), 2D .0535, 2D .0540,and 2D .1806. The facility is not subject to
the RMP requirements of the 112(r)program since it does not use or store any of the regulated chemicals in quantities
above the threshold in the rule. The facility is only subject to the General Duty clause of the Section 112(r)program.
Discussion
The emission sources at the facility include those associated with the conveying(ES-Convey), screening(ES-Screen), and
crushing(ES-Crushing)operations. However,the facility is in the beginning setup phase and has only brought in 5 pieces
of equipment. This includes the jaw crusher(CR1), cone crusher(CR2), conveyor#1 (C 1), conveyor#2 (C2), and screen
#1 (S 1). All of the sources appear to be subject to the provisions of the New Source Performance Standards as written in
40 CFR 60, Subpart 000. Mr. Threatt supplied a copy the visible emission evaluation and testing for the crusher and
conveyor that was conducted in Virginia on July 7, 2021. The testing evaluation did not include any testing approval
documentation from the Virginia Department of Environmental Quality. The facility equipment list and flow diagram,
supplied during the permit application process, includes a number of additional conveyors, screens, and feeders that have
not been installed yet. The facility's Subpart 000 compliance status and requirements will be discussed in the
NSPS/NESHAP section below.
Currently,the facility has commenced operation on a limited basis.None of the sources were in use during the inspection,
however. There is power infrastructure at the site,but the equipment and operations have not been tied on the grid as of
12/2/21. The five sources currently on-site have been running off built-in generators, as the equipment is tracked portable
equipment. The engines are certified to EPA Tier 4 standards and utilize Diesel Exhaust Fluid(DEF). According to Mr.
Threatt,the company is hoping to be on supplied power in the next month. The facility has begun to break ground on the
quarry hole. According to Mr. Threatt,Alamance Aggregates has been digging for about three weeks. Once fully
constructed and operational,the facility plans to produce aggregate sizes including coarse, fines, #57,#67,#78, #89,
surge, and specialty orders. According to the application,the facility will be capable of crushing 700 tons per hour from
the primary crusher. The stone is carried by trucks, using plant haul roads, and dumped into the main jaw crusher. After
crushing,the stone is conveyed to the first screening station and from there to the main stockpile, class A, class B, surge
piles, or onto the cone crusher(which can feed the surge/storage pile). Materials from the surge pile are conveyed to the
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second screen, into the second cone crusher, or to a specific pile. From there the material will be returned to the second
screening station and sent to one of the four storage piles or into the "fines."The facility will also implement a wash
screen for the"fines"conveyor and product conveyor segment. Most of the equipment has not been installed as of
December 2, 2021 and the equipment list should be updated as new sources are added. Emissions from the mining and
processing operation will consist of particulate emissions, including PM 10 and PM2.5. A detailed description of the
operations can be found in the Emission Assumptions and Calculations section (EA&C)of the permit application.
Applicable Regulations:
Condition A.2 contains the 15A NCAC 2D .0202,"Permit Renewal and Emissions Inventory Requirements."The facility
was issued a brand-new permit on April 15, 2019 that will expire on March 31, 2027 and the facility is required to submit
a renewal request and emissions inventory report for the 2025 calendar year 90 days prior to the expiration of the permit.
This condition was discussed with Mr. Threatt. Compliance is anticipated.
Condition A.3 contains the 2D .0510 "Particulate Control Requirements."This requires the operator of a sand, gravel,
and crushed stone operations to not cause or allow particulate emissions without taking certain measures to minimize
airborne PM emissions. This facility is using wet suppression on the five installed sources in order to control process
particulate matter. The facility is currently only operating on a limited basis and only uses the crusher and conveyor a few
hours a week. There was a very limit amount of material in the surge piles and the quarry was only dug down about 30
feet. The facility has proper inspection documentation for the limited number of days the crushing operation and wet
suppression systems were operating. The facility, according to Mr. Threatt,will continue to perform daily inspection on
the wet suppression. Compliance is expected.
Condition A.4 contains the 15A NCAC 2D .0521, "Visible Emissions Control Requirements."This facility is limited to
20% opacity of visible emissions, for sources manufactured after July 1, 1971,when averaged over a six-minute period.
The facility was not operating any of the crushing operations during the inspection. The facility has brought in five
emission sources from the application equipment list. These are new pieces of equipment that were manufactured in the
last couple of years and are equipped with dust suppression. Compliance with 2D .0521 is expected.
Condition A.6 contains the requirements for 15A NCAC 2D .0535 "Excess emissions reporting and Malfunctions."For
any malfunction, breakdown of process or control equipment, or any other abnonnal conditions that lead to a source of
excess emissions lasting longer than four hours in duration,the facility is required to notify WSRO DAQ (by 9:00 the
following business day). Tile notification should include the name and location of the facility where the excess emissions
occurred,the nature and cause of the malfunction or breakdown,the time when the malfunction or breakdown was first
observed,the expected duration, and the estimated rate of emissions. The director must also be informed when corrective
measures have been completed. There were no instances of excess emissions according to the facility contact and none
have been reported to the WSRO-DAQ. Compliance is expected.
Condition A.7 contains the requirements for 15A NCAC 2D .0540, "Particulates from Fugitive Dust Emission Sources."
This condition mandates that the facility not cause or allow fugitive dust emissions to contribute to substantive complaints
or excess visible emissions beyond the property boundary. There were minimal dust emissions as a result of the
construction and heavy equipment that was being used to scrape down the road area. The emissions were limited to within
the property boundaries and were controlled by a road wetting process. There have been no complaints recorded in the
IBEAM database. Compliance expected.
Condition A.8 contains the"Equipment Reporting"requirements as outlines in 15A NCAC 2D .0605. The facility shall
maintain an on-site equipment list and a plant(or flow)diagram of all equipment covered under the current permit. The
equipment list must contain the following information for each piece of equipment:
• A description of equipment including applicability of New Source Performance Standards,
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• Width of belt conveyors,
• Dimensions and configuration(e.g.,triple deck)of screens,
• Rated capacity(tons or tons/hr)of all nonmetallic mineral processing equipment,
• A unique ID number,
• The date the equipment was manufactured,the dates any required performance testing was conducted
and submitted to the Regional Supervisor,Division of Air Quality,
• The Permittee shall provide written notification to the Regional Supervisor,DAQ, including a revised
equipment list and plant(or flow)diagram,each time nonmetallic mineral processing equipment is
installed or relocated at a facility. This written notification shall be submitted at least 15 days before
the equipment is installed or relocated at the facility unless otherwise approved by the Director.
The facility submitted a"Summary of the material handling and storage related equipment"during the permit application
process. This list was referenced during the inspection but had not been updated to include the required elements as
outlined in this condition.Although the list did contain descriptions of the sources and unique ID numbers, it did not
contain:
• Width of belt conveyors,
• Dimensions and configuration(e.g.,triple deck) of screens,
• Rated capacity(tons or tons/hr) of all nonmetallic mineral processing equipment,
• The date the equipment was manufactured,
• New Source Performance Standards applicability,including the dates any required performance
testing was conducted and submitted to the Regional Supervisor,Division of Air Ouality.
The most recent plant flow diagram was also supplied in the original permit application. The facility currently has five
emission sources at the facility. These include the main jaw crusher#1 (CR1),primary cone crusher 42(CR2), conveyor
#1 (C 1), conveyor#2 (C2), and screen#1 (S 1). It appeared that the conveyors were 36"x80"and this was confirmed by
Mr. Threatt.
According to Mr.Threatt,the remaining equipment will systematically be brought on site as the facility ramps up
production. As new equipment is brought on,the equipment list and flow diagram must be updated to reflect new
changes. The new equipment list and flow diagram must bear the date of the current revision. The permittee shall provide
documentation for any required testing with seven days a written request. The facility may install and relocate existing
nonmetallic mineral processing equipment but must notify the WSRO 15 days before processing equipment is installed or
relocated. This includes all crushers, screens, conveyors, and loadout bins.
The facility is deficient in fulfilling the requirements of 15A North Carolina Administrative Code (NCAC) 2D
.0605,as referenced by Condition A.8 of Air Permit No. 106121100.The equipment list maintained by the facility
has not included the width and dimension of the conveyors,dimensions of the screens, rated capacity,
manufactured date or performance testing information on the equipment list.The flow diagram should also be
amended to reflect current operating parameters at the facility. A Notice of Deficiency(NOD)will be set to this
facility.
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Condition A.9 contains the requirements for 15A NCAC 2D .l 806, "Control and Prohibition of Odorous Emissions."
This condition requires the facility to control and prohibit odorous emissions.No objectionable odors were present during
the inspection. There have been no previous odor complaints associated with this facility.Compliance with the condition
is expected.
NSPS/NESHAP
This facility is subject to 2D .0524 New Source Performance Standards(NSPS), for the nonmetallic mineral processing
equipment, as promulgated in 40 CFR 60, Subpart 000, including Subpart A"General Provisions"as referenced in
permit condition A.5. Under this rule,the facility is required to:
• Notify the Regional Supervisor, in writing, of the startup of an affected facility.
o The facility had a placeholder date in IBEAM that was issued after the permit was issued on April 15, 2019. The
facility did not start construction on the site until 2021.
o The facility reported,through email,that the initial start-up day as August 19,2021.
• A l 5% opacity limit is set for any crusher and 10%opacity for conveyor belts, screening operations and other affected
facilities constructed, modified or re-constructed after August 31, 1983,but before April 22,2008.
o The crushers,conveyors, and screens were all manufactured after April 22, 2008.
• A 12%opacity limit is set for any crusher and 7% opacity for conveyor belts,screening operations and other affected
facilities constructed,modified or re-constructed on or after April 22, 2008.
o The facility has 5 subject sources on site. These are all manufactured after April 22,2008. This includes
the jaw crusher(CRI), cone crusher(CR2), conveyor#1 (CI),conveyor#2 (C2), and screen #1 (S 1). The
facility supplied a copy of a visible emission evaluation that was apparently for the main crusher(CRI)
and conveyor(C1)which was conducted in Virginia on July 7, 2021.In reviewing the test report, it is
unclear whether all of the required transfer points for this equipment in its present configuration have
been tested.
• The facility is required to perform monthly inspections of the wet suppression systems for sources constructed on or
after April 22,2008 and must record these inspections within a logbook.
o The facility is partly operational. The facility is conducting monthly inspections of the wet suppression systems
and maintaining a logbook.
At the time of this inspection,compliance with 40 CFR Part 60 Subpart 000 could not be determined.Upon
receipt of a complete equipment list for all the equipment installed at this site,DAQ will be able to fully evaluate
the installed equipment for subjectivity/compliance with this subpart. Should the equipment require testing,it will
be required within 60 days after achieving the maximum production rate but not later than 180 days after the
initial start-up.The facility will be advised of this requirement,along with the NSPS written start-up notification
requirement in the NOD letter that is being sent to them.
The engines associated with the tracked quarry equipment may be subject to federal Reciprocating Internal Combustion
Engine(RICE)regulations such as 40 CFR 63 Subpart ZZZZ and 40 CFR 60 Subpart 1111. Should these engines be placed
in a single location for more than 12 months,they will be subject. They may also be subject to DAQ permitting
requirements. Additional information regarding this facility's intention for these engines will be requested in the NOD
letter that is being sent to the facility.
This facility does not appear to be subject to any other NSPS/NESHAP rules at this time.
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Facility Wide Emissions
Actual and potential emissions taken from Permit Review 10612R00(Leo Governale,P.E.,April 15,2019)
= _ Potent><al Emissions
Ex ected Actual Emissions?
Pollufant _ Ctgnslyi=d] a� [tonslyr]
. � w/o wet suppression �-w/wet:suppressaon�
M..,�, �.,.,... ....:
C. PM ......._. ._.:.._ 35.16 _......... 421.22 .......:. :... 35.1.6 .. I
Ir_. . .. PMto �...._� 12.86 � ..149.22 F 12.86 .�..�.�_._.....W..
I Expected actual emissions are calculated based on 8,760 hr/yr;therefore,actual emissions=potential emissions w/wet suppression.It is noted that these emissions
are from crushing and material handling operations. Fugitive emissions,i.e.,unpaved road and storage pile wind emissions,were submitted with the application;
however,they are not needed and therefore are not taken into account.
zWet suppression is required by NSPS Subpart 000 and 2D.0510. As such,potential emissions with wet suppression(not without wet suppression)are considered
for facility classification purposes.
Facility Considerations/Issues
• Power has not been connected to the equipment of office building as of December 2,2021. This equipment is
being powered by onboard diesel engines that are certified to Tier 4 EPA standards and utilize DEF.
Stack Testing
No stack testing has ever been conducted at this facility.
Conclusion
Based on review of records and visual observations,Alamance Aggregates, LLC appears to be deficient in fulfilling the
requirements of 15A North Carolina Administrative Code(NCAC)2D .0605,as referenced by Condition A.8 of Air
Permit No. 10612R00 for the failing to maintain a complete on-site equipment list. To demonstrate compliance with 15A
NCAC 2D .0605,the permittee shall maintain on-site an updated equipment list and plant flow diagram of all equipment
covered under this permit. The current equipment list and flow diagram does not represent current operational status and
is missing the following required elements:
• Width of belt conveyors,
• Dimensions and configuration (e.g.,triple deck)of screens,
• Rated capacity(tons or tons/hr) of all nonmetallic mineral processing equipment,
• The date the equipment was manufactured,
• New Source Performance Standards applicability, including, including the dates any required performance
testing was conducted and submitted to the Regional Supervisor, Division of Air Quality.
An NOD will be sent to the facility.
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