AQ_F_0200103_20210131_CMPL_CAV-Rpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Borealis Compounds,Inc.
NC Facility ID 0200103
Inspection Report County/FIPS:Alexander/003
Date: 01/27/2021
Facility Data Permit Data
Borealis Compounds,Inc. Permit n/a
401 W.E.Baab Industrial Drive Issued n/a
Taylorsville,NC 28681 Expires n/a
Lat: 35d 54.8457m Long: 8ld 7.2301m Class/Status Permit Exempt
SIC: 3087/Custom Compound Purchased Resins Permit Status Inactive
NAICS: 325991 /Custom Compounding of Purchased Resins Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Brynnan Lackey Brynnan Lackey Brynnan Lackey
HSE Coordinator HSE Coordinator HSE Coordinator
[phone] [phone] [phone]
Compliance Data
Comments:
KAK Inspection Date 01/27/2021
Inspector's Name Donna Cook
Inspector's Signature: Dat a eotl z Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: C113112C21 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
No emissions inventory on record.
*Highest HAP Emitted in ounds)
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

Borealis Compounds,Inc.
January 27, 2021
Page 2
Type Action: _Full Compliance _Partial Compliance _Complaint X Other: Compliance Assurance Visit
Evaluation Evaluation/Reinspection Investigation C( AV)
Data Tracking: X Date submitted for initial review 01/31/2021 _IBEAM WARNING/OB,NOD,NOV,NRE
X IBEAM Document
X IBEAM Inspection,list date inspected _IBEAM LAT/LONG,Facility Locked
X IBEAM Inspection,list date draft is submitted X IBEAM LAT/LONG,Coordinates checked
X IBEAM Inspection,pollutants/programs checked _IBEAM Complaint
X IBEAM Planning,Next Inspection Date 01/01/2023
Directions: From Mooresville Regional Office to Taylorsville,travel via Statesville Avenue;North
Broad Street and the name changes to Statesville Highway(Highway 115 North)and then to Charlotte
Highway(Highway 21 North and Highway 115 North); Interstate 77 North; Exit 51 (Hickory/Winston-
Salem)-Interstate 40 West toward Asheville; off Interstate 40 West take Exit 148-W. Statesville/
Taylorsville US Hwy. 64/NC 90;turn right off exit ramp onto Taylorsville Road US Hwy. 64; 13.2 miles
turn right on Millersville Road; 0.5 mile turn left at the stop sign onto Hwy. 90 East; and 0.1 mile turn
right on W. E. Baab Industrial Drive in the Alexander Industrial Park; and 0.3 mile to this facility at the
end of the road. The street address of this company is 401 W. E. Baab Industrial Drive.
Safety Equipment: This company requires that safety glasses, hard hat, safety vest, hearing protection
and steel toed shoes be worn by the inspector at this facility. The inspector must wear the colored safety
vest, colored hard hat and safety glasses with side shields that is provided by this facility. Due to the
coronavirus restrictions,no safety equipment was provided by this company.
Safety Issues: The inspector should be cautious of forklift operations inside of this facility.
Lat/Long Coordinates: A review of the "Facilities Regulated by Air Quality" on the DAQ website
indicates the facility's location is accurate and matches the facility's latitude and longitude coordinates
listed in IBEAM. No changes to the latitude and longitude coordinates of this facility are needed in
IBEAM. The latitude and longitude coordinates of this facility are not locked in IBEAM.
Email Contacts: The email addresses for the facility,authorized and technical contacts were verified by
Mr. Brynnan Lackey,health, safety and environmental coordinator. No changes to email addresses of
these contacts were needed in IBEAM.
COVID-19 Information:
Mr. Brynnan Lackey,health, safety and environmental(HSE) coordinator, at(828) 850-5161, and I
discussed the COVID-19 restrictions at this facility prior to the site visit. Mr. Lackey stated that this
company will allow the inspector on-site if a face covering(mask)is worn and the physical distancing of
at least six feet(social distancing) is maintained from other plant personnel. This company also requires
employees and visitors to have temperature checks and fill out a questionnaire regarding COVID
symptoms prior to entering the facility.
Before conducting the inspection, I completed the NC Employee Screening for Employees Reporting
Onsite form on the oshr.nc.gov web site. Based on my responses to the questions in this form,I was able
to proceed with the on-site inspection.

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January 27, 2021
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I met with Mr. Lackey outside the entrance to this facility. Mr. Lackey escorted me to the lobby of this
facility. I had my temperature checked by Lackey. I also completed the COVID-19 screening electronic
questionnaire. The on-site inspection was conducted by me inside the fire pump building and outside at
the storage silos and control devices. Both Mr. Lackey and I wore a face covering and maintained a
distance of more than six feet(social distancing) from each other and other plant personnel during
the CAV.
Compliance Assurance Visit:
1. General Information:
The purpose of this site visit was to conduct a compliance assurance visit (CAV). This facility
manufactures polypropylene pellets for the automotive industry. This company operates two
shifts at this facility from 6:00 am to 2 pm and 2pm to 10 pm, Monday through Friday, 50 weeks
per year.
2. Facility Contact Information:
During the inspection, I verified the facility contact information in IBEAM with Mr. Lackey. The
authorized contact was changed to Brynnan Lackey in IBEAM.
3. Compliance history file review:
This facility began operational in February 2019. No problems have been noted by MRO DAQ
prior to the CAV. The current compliance status is discussed in the following sections.
4. Source Observations:
This facility manufactures polypropylene pellets. The polypropylene pellets are delivered by
trucks in plastic-lined cardboard boxes or in bulk either by rail cars or tanker trucks. The
polypropylene pellets are unloaded manually from the plastic-lined cardboard boxes by using a
wand to pneumatically convey them into the three storage silos or pneumatically from the rail
cars and trucks into the three storage silos and then to the receiving bins inside of this facility.
The ingredients,talc,calcium carbonate and glass filled polypropylene, are added per the client
specifications to the polypropylene in pellet form. The supersacks of talc, calcium carbonate and
glass filled polypropylene are delivered by truck and stored inside of this facility.
The polypropylene pellets are mixed and compounded with the additive ingredients and re-
extruding in the two extruders 1 and 2. The pellets are extruded at temperature ranging from 450
to 500 degrees Fahrenheit. There are no polymerization reactions from the extrusion process.
The extrusion process has emissions of particulate matter,VOC,HAP and TAP. The only
pollutant being controlled is particulate matter.
This company has two injection molding machines. These machines are used to test samples for
breakage, stress and shrinkage. There is no venting to the outdoor atmosphere from the two
injection molding machines.
The polypropylene,talc and extrusion processes emit particulate matter emissions. The six bag
break stations,two mixing silos,mixer,mixing room,pellet mixing room,top of the two

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January 27, 2021
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extrusion lines 1 and 2 and three storage silos vent to a filter system(pleated filter inside with
fabric covering around it). The filter system exhausts to the outdoor atmosphere through a
vertical and capped stack. A second vacuum filter system(pleated filter inside with fabric
covering around it)is used to collect any particulate matter emissions from the floor area of this
facility. The filter system exhausts to the outdoor atmosphere through a vertical stack with a rain
cap.
The air emission sources and control devices at this facility became operational in February 2019.
The visible emissions from this facility are limited to 20%opacity when averaged over a six-
minute period as required by 15A NCAC 2D .0521 "Control of Visible Emissions." Mr. Lackey
stated that the polypropylene,talc and extrusion processes were in operation inside the building
of facility. I observed that the two filter systems located outside of this facility were in operation.
No visible emissions were observed by me from the two filter systems or from the building
housing the polypropylene,talc and extrusion processes.
The diesel-fired fire pump engine is used for emergency purposes only to pump water in case of a
fire at this facility. The ultra-low sulfur diesel fuel(15 ppm)is stored in a tank. The fire pump
and diesel tank are located inside a building. The fire pump engine exhausts horizontally through
the side of the building to the outdoor atmosphere. The stack is curved and uncapped. The fire
pump engine was not in operation at the time of this visit.
I observed the following information on the plate of the fire pump: Clarke,manufacturer of fire
pump(model,JU4H-UFADNG); and John Deere,manufacturer of the engine(model,
6068HFC28, serial#PE6068N008109; family#JJDXL06.8120; displacement 6.8 liter;
manufacture date,4/2018; and this engine complies with US EPA regulations for 2018 stationary
emergency diesel engines including fire pumps.
The specifications data provided by this company indicated that the engine is rated at 190 bhp and
142 kW and Tier 3 emissions certified. The label on the engine plate indicates that EPA has
certified it for 2018 model year. The emissions data and EPA certification of conformity were
obtained from the manufacturer, Clarke, of the fire pump engine and EPA. A copy of the EPA
certification of conformity and the emission data are in the file of this facility.
The fire pump engine was installed in December 2018 as indicated by Mr. Lackey. Based on this
information,the engine is classified as new with regard to NESHAP Subpart ZZZZ(4Z)RICE
because it commenced construction after June 12,2006.
The fire pump engine is also subject to requirements of NSPS Subpart 1111(41). As a result,this
compression ignition engine complies with the requirements of the NESHAP Subpart 4Z by
meeting the requirements of NSPS Subpart 41. No further requirements are required for this
engine under NESHAP Subpart 4Z.
This facility is required to install a non-resettable hour meter on the diesel-fired fire pump engine
if one is not already installed. The diesel-fired fire pump has a non-resettable hour meter. The
run hours on the digital meter are 47.7 and previously 14.9 hours during previous inspection on
July 17,2019.
The diesel-fired fire pump engine is not limited on emergency use,but limited to 50 hours per
calendar year in non-emergency situations and a maximum of 100 hours per calendar year for
maintenance checks and readiness testing per NSPS Subpart 41. Mr. Lackey stated that the diesel-

Borealis Compounds,Inc.
January 27, 2021
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diesel-fired fire pump engine is tested once a week for 30 minutes and has never operated for
emergency purposes. Mr.Lackey showed me a handwritten log containing the maintenance
activities and run hours for the diesel-fired fire pump engine. The run hours on the hour meter and
the maintenance logs indicated that the hour limitations in NSPS Subpart 41 have not been
exceeded. This company is complying with the requirements of NESHAP Subpart 4Z and NSPS
Subpart 41.
This facility is subject to the fugitive dust rule, 15A NCAC 02D .0540 and the odor rule, 15A
NCAC 02D .1806. This office has not received any fugitive dust emissions or odor complaints
regarding this facility. During this visit, I observed no fugitive dust from the paved roads or
detected any odors from this facility. I asked Mr. Lackey if any excess emissions had occurred at
this facility since the last inspection on July 17, 2019. Mr. Lackey stated that no excess emissions
had occurred at this facility.
5. NSPS/NESHAP Review:
This company has no boilers, emergency generators,peak shaving generators or gasoline storage
tanks at this facility.
The exempt diesel-fired fire pump engine(190 bhp and 142 kW)is subject to 40 CFR Part 63
NESHAP Subpart ZZZZ(4Z)and 40 CFR Part 60 NSPS Subpart 1111(41).
6. Exemption Qualification:
On October 30,2017,this office received a request from this company to exempt this greenfield
facility from air quality permitting. The polypropylene pellets,talc handling and extrusion processes
emit particulate matter emissions. The polypropylene pellets,talc handling and extrusion processes
are controlled by a filter system. The extrusion process also has emissions of VOC and HAP. There
are no polymerization reactions from the extrusion process. The maximum process rate for the
polypropylene pellet handling and extrusion processes are each 4400 kg/hr or 38,544,000 kg/yr
(converted to 9,700 lbs/hr or 84,972.000 lbs/yr). The maximum process rate for the talc handling is
5,000 ton/yr or 10,000,000 lb/yr. Based on the maximum process rates from the polypropylene
pellet handling,talc handling and extrusion processes,the emissions were calculated as 1.10 ton/yr
for PM after controls; 1.12 ton/yr for PM10 after controls; 2.42 ton/yr for uncontrolled VOC; 0.047
for HAP/TAP(acetaldehyde, acetic acid,acrolein, formaldehyde,MEK,propionaldehyde)and the
total aggregate emissions were 3.54 ton/yr.
MRO DAQ sent a letter dated November 29,2017 to this company exempting this facility from
permitting, since the facility-wide actual emissions of particulate matter(PM10), sulfur dioxide,
nitrogen oxides,volatile organic compounds, carbon monoxide,hazardous air pollutants(HAP and
toxic air pollutants (TAP), each are less than five tons per year and the total actual aggregate
emissions of these pollutants are less than ten tons per year per 15A NCAC 2Q .0102 (d). This
facility qualifies for this exemption, since it is not required to have a permit pursuant to 15A NCAC
2Q .0500.
Mr. Lackey stated that the polypropylene pellet handling and extrusion processes are 5,000
pounds per hour; and 4,000 pounds per month for the talc handling. The current process rates are
below the maximum process rates indicated in the permit applicability determination review. The
actual facility-wide emissions of all pollutants indicate that this facility still qualifies for
exemption under 15A NCAC 2Q .0102(d). This facility has not changed or modified the

Borealis Compounds,Inc.
January 27, 2021
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production equipment to increase emissions above the exemption thresholds since the permit
exemption request.
A diesel-fired fire pump rated at 190 bhp and 142 kW was installed in December 2018. Based on
the diesel fuel usage and run hours on the non-resettable hour meter,the fire pump engine is
exempt from air quality permitting per 2Q .0102 (h)(5).
7. Compliance determination:
Based on my observations,this facility appeared to be in compliance with the air quality rules
(02D .052 1-visible emissions; 02D .0535-excess emissions; 02D .0540-fugitive dust emissions;
02D .1 806-odorous emissions; 40 CFR Part 63 NESHAP Subpart ZZZZ(4Z)and 40 CFR Part 60
NSPS Subpart 1111(41). The compliance assurance visit checklist is attached on page 7.
DLC:
c: MRO File
https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/ALEXANDER/00103/INSPECT 20210127_CAV.docx

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Compliance Assurance Visit Checklist rev.11/03/16
Facility Name: Borealis Compounds,Inc.
Physical Site Address: 401 W.E.Baab Industrial Drive
City:Taylorsville Zip Code: 28681 County: Alexander
Facility Contact:Brynnan Lackey Title: HSE Coordinator
Phone No.: [phone] or(828)850-5161
Mailing Address: 401 W.E.Baab Industrial Drive,Taylorsville,INC 28681
Facility Contact Email Address: [e-mail]
Is the facility contact the person that you met? If not,fill out the following:
Contact Name: Title:
Phone No.:
Mailing Address:
Email Address:
Safety requirements:safety shoes(yes/no)-safety glasses(yes/no)-hearing protection(yes/no)-hardhat(yes/no)-
safety vest(yes/no) other(please describe): Safety glasses,hard hat and safety vest provided by facility.
Normal operating schedule(hr/d,d/wk,wk/yr): 2 shifts(6:00 am to 2 pm&2 pm to 10 pm),Monday-Friday,50weeks per year
Opacity(%)-indicate any non-zero opacities observed: 0%
Odors-indicate if any objectionable odors were detected beyond the property boundary: None
Fugitive dust-indicate whetherfugitive dust was observed leaving property boundary: None
Since last inspection,have there been any changes in equipment or operation? The start-up of this facility occurred in
February 2019.
Throughput and/or fuel usage with units: Polypropylene pellet handling and extusion 4400 kg/hr or 38,544,000
(9,700lbs/hr or 84,972,000lbs/yr)maximum process rate and talc handling 5,000ton/yr or 10,000,000lb/yr;Actual process rates=
5,000lbs/hr.(converted to 2,267.96 kg/hr)for polypropylene pellet handling and extrusion process and 4,000 pounds per month for the
talc handling.
Control device(s)(list): Two filter systems for particulate matter control
Properly operated and maintained? Yes
For a permit exempt facility found to be improperly operating or maintaining plant equipment:1)provide compliance
assistance as a first option;2)initiate enforcement action in egregious/repeat cases;3)re-evaluate facility's emissions
using a more representative control efficiency/emission factor;4)If re-evaluated actual emissions result in a classification/
registration change,follow enforcement guidelines for operation without a permit/registration;and 5)increase compliance
visit frequency.
Notes or calculation space:
Diesel-fired fire pump engine(190 bhp and 142 kW)is subject to the requirements of 40 CFR Part 63 NESHAP Subpart ZZZZ(4Z)and 40
CFR Part 60 NSPS Subpart IIII(41). The fire pump engine is exempt from air quality permitting per 2Q.0102(h)(5).
Permit Exemption:
•Actual emissions from the previous year(s)(and projected actual)of PM10,5O2,NOx,VOCs,CO,HAPs,and TAPs
are each<5 tpy and whose actual total aggregate of these emissions are<10tpy
•Can be subject to 40 CFR Part 63(MACT or GACT)and 40 CFR Part 60(NSPS)
•Cannot be subject to Rule 2Q.0315(Synthetic Minor Facilities)or 2Q.0500(Title V Procedures)