AQ_F_1700015_20200717_CMPL_InspRpt

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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: 07/21/2020
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: Facility not constructed.
Inspection Date 07/17/2020
Inspector's Name Blair Palmer
Inspector's Signature: " Operating Status Operating
Compliance Code Compliance-inspection f
Action Code FCE
Date of Signature: 07/21/2020 MTH On-Site 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 Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
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Permitted Emission Sources
Emission Emission Source Control Control System
Source ID � Description System ID Description
One drum mix,hot mix asphalt plant(250 tons per hour maximum rated capacity)consisting of:
_... .:. m..:__ ..._ __ ._.. _. ......................_.....:........... ......:....... ...... _.: . .... .._...........:.:. :.:.. _, :..:. ......._................................_.......­ .......................................
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,each) N/A N/A
ES-S3,ES-S4,ES-S5 Three(3)hot mix asphalt storage silos(200 tons capacity,each) I N/A T N/A
ES-LO1,ES-1,02 ITwo(2)truck loadout operations I N/A N/A
ES-H1 Natural gas/No.2 fuel oil-fired liquid asphalt cement heater(1.2 N/A N/A
million Btu per hour maximum heat input)
.......... _ m . _..........
ES H2 Natural gas/No.2 fuel oil-fired liquid asphalt cement heater(1.1 N/A N/A
.......... .. .. ._... __.... .._......:........._....._ ........ .... .m.........._.... ......_. .......... _... :. ...... _.....
One truck mix,concrete batch plant(120 cubic yards per hour maximum rated capacity)consisting of.
.......- Wes. _._ :::. W._ w::.: _ w.:.,.: _
ES-RM1 Cement storage silo(185 tons capacity)
ES-RM2 Fly ash storage silo(135 tons capacity) Bagfilter(1,433 square f
ES-RM3 Cement/fly ash weigh batcher(5 tons capacity) CD-2 feet of filter area)
.._.._ __ ..... ...�:..: _ _:...._ m_._..
ES-RM4 Truck loadout operation
One RAP processing operation consisting of:
ES-CRSH(NSPS 000) IRAP impact crusher(65 tons per hour maximum rated capacity) N/A N/A
ES-CNV(NSPS 000) IRAP 36"inclined conveyor N/A N/A
ES-SCN(NSPS 000) IRAP 8'x 20'double deck screen N/A N/A
Insignificant Sources
Exemption Source of Source of
Source ID Source Description Title V
Regulation TAPs? pollutants?
IES 1 Above ground storage tank containing fuel oil(20,000 gallons capacity) 2Q 0102(g)(4) Yes Yes
_..._..._ ._ .. ...._ ..__..m.__......_.._................_. ._ _... ................_._.... ............ .._. ... ....... . ._.. ..... ._:..
IES 2, Two(2)above ground storage tanks containing liquid asphalt cement 2Q.0102(g)(14)(B) Yes Yes
IES 3 1(30,000 gallons capacity,each)_ _._ .._... _.. ..__ ........: ..........._.: ... ....:. .... ,:.:_ ._....... :....: .:.....:.. ..... - :::..:.
Introduction:
On July 17, 2020, Blair Palmer,DAQ-WSRO Environmental Specialist, confirmed that Carolina Sunrock LLC - Prospect
Hill Facility in Caswell County was not operational, and the purpose was for a targeted compliance inspection. No
equipment was installed, and there did not appear to be any electricity on-site. The facility appeared to be not in operation.
The facility was issued a new permit on January 3,2018 but has not yet started operating. According to permit review RO1
(Ms. Taylor Hartsfield, Compliance Supervisor for WSRO-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 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 ID 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 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:
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The facility appeared to be not operating as of July 17,2020. 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 facility appears to be complying
due mainly because of no equipment being operated or fully constructed.
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-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 0.0241bs/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-HMA1) is
subject to this regulation. The plant must limit particulate emissions according to the following equations:
E=4.9445 (P)0.4311 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.
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:
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E=4.10(P)0.67 when P<_30 tons/hour
o. i_ I
E=55.0(P) 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.
ImisslonSource
e Esm'PSIYs$1s/lho ri]R�`a te Ex t'�ez RctaeProcon3s onSYe
ge [p F wlb de A[lbctsu aF1`�VF IElsh w
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ES-RM1 Cement storage silo .35 41.32 [ 0.117
ES-RM2 IFIy ash storage silo 35 41.32 0.346
f _....., _. ........................................... .. ........ ......_ ......: _._......
I ES RM3 �Cement/fly ash weigh batcher ( 35.76 [ 41.51 4.314
Rio w _
_ _.
�S-RM4 Truckloadoutoperation [ � 240.966� � � 60.55 �� 4.386
820 yd'hr x(448bs ce men/yd'+14 81b s fly ash/yd')_2,000 lbs/ton=35.76 ton/hr
h' ' 4 ')"120ydrx( , 6stotay - 0swater/yd
_2,000 Ibs/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-HMA 1)and two liquid asphalt cement heaters(ES-HI 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-HNIA1)has
a sulfur dioxide emission rate of 0.011 lbs/MMBtu(natural gas), 0.0341bs/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 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/dsef)and the opacity limit of 20%. The 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 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 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.
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Condition A.11 contains the 15A NCAC 2D .0535 is the 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 have been received in the source file and/or registered in IBEAM for this permitted facility. Compliance
with the condition is expected.
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Condition A.12 contains the 15A NCAC 2D .0540 fugitive dust control requirement.No fugitive dust was observed j
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. r
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 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
(1 MA)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.
" 1VI rm�um ;
Averaging ax A 1[, AAL
)Cmrssro ` Rates Concentrate
Emi�sioh(s)Source TAP� CAS#) s Period.' Q
3 MMR ,
Pro No.natural Arsenic unlisted compounds
p ASC-other 4.911bs/yr � 0.00158 .0021 W 75
gas/No.2 fuel � ) Annual
oil/recycled No.2 F�—Benzene(71-43-2) [_"3,470lbs/yr I---0.112 ^[0.12 93
fuel oil/recycled No ... .. .__ . ...:.._.
Formaldeh de 50 00 0 3 191bs/hr 1 hr 62 150 41
4 fuel oil-fired drum __ Y _ _ ) _ _ ( __ I _ ...
dryer/mixer Mercury vapor(7439-97-6) y0 06241bs/24""hrs — 0 00115 6.6 2
_": �._...�._... ._..__. .".. .."...... ..__ __ 24-hrs _ .— .....�...
(ES-HMA1) Nickel metal(7440-02-0) 1.51 Ibs/24-hrs j 0.215 I 6 4
..................._........................._..._......._.........,..................._...........................................................................s......................................................................._..............................................._....._......._,........ ..................:...._.............._..._.........._...._.................-..............................:..........._....._.............__.
Arsenic unlisted compounds
Natural gas/No.2 0.168 lbs/yr
fuel oil-fired liquid (ASC-other) Annual See above—the above values
_ ....
asphalt cement Benzene(71-43 2) 0.0861 lbs/yr are presented as facility-wide.
heaters(ES-H1) """ �"
Formaldehyde(50-00-0) 0.00113 lbs/hr 1-hr
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aeU+✓ ' ;, � �. .� ` of �1.verain � axlmn '*�" 0AA�
.. .. „h «, . " .. ...�
Mercury vapor(7439-97-6) ',� 0.000346 lbs/24-hrs
......... 24-hrs
Nickel metal 7440-02-0 0.0003461bs/24-hrs
Arsenic unlisted compounds 0.1541bs/yr
(ASC-other) Annual
Natural gas/No.2
fuel oil-fired liquid Benzene(71-43-2) 0.0789 lbs/yr
asphalt cement Formaldehyde(50-00-0) 0.00104 1bs/hr 1-hr
heaters(ES-H2)
Mercury vapor(7439-97-6) �0 000317 lbs/24-hrs
__ 24-hrs
Nickel metal(7440-02-0) �0.0003171bs/24-hrs
. .... .......
... . ...:
Five hot mix asphalt Benzene(71-43-2) 5.12 lbs/yr,each ( Annual
storage silos(ES-S1 _ _� _...� W._..__._..._._._:__. ....
through ES-SS) Formaldehyde(50 00-0) 0.02101bs/hr,each1-hr I
Two truck loadout FBenzene(71-43-2) 2.84 lbs/yr,each Annual
operations(ES-LO1
and ES-1,02) Formaldehyde(50-00-0) 0.0007321bs/hr,each 1-hr
_.
__F
One truck mix, Arsenic unlisted compounds 2.31 lbs/yr Annual
concrete batch plant (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 re-evaluated once the facility has been fully constructed by DAQ on-site observations and any
height and locations of subject equipment. The facility will be required to record monthly asphalt production 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 .l 100 will be re-evaluated
once the facility is fully operational. Compliance is expected.It should note that the facility did report by January 301 and
the last report was received in the WSRO on January 11, 2020 indicating no production.
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.
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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 15A NCAC 2Q .0309 contains the language in accordance with North Carolina General Statute I
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 i
tons per year of sulfur dioxide(S02)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%. Fuel supplier certifications must be kept on-site. The facility will be required to report by January 30 of
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each year the total amount of asphalt produced and the facility-wide year sulfur dioxide and carbon monoxide emission.
Compliance can be 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 j
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 PCB's. No operations have commenced at the facility and zero
recycled fuel has been delivered. Compliance is expected.
NSPS/NESHAP: I
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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:
Expected and potential emissions during permit review R00 by Ms. Taylor Hartsfield,WSRO-DAQ Environmental
Engineer,now Compliance Supervisor on September 17, 2017. 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.
PatentlaY Enn1S$lU�1S tOpS� ear k 1
�Pollutnt Expected Actual Emissions C Y
[tonslyear�:, ore�controls/��rintt After.contols/�rmr7s�
_... � 0 . ( 54.41PM � 2 7
._............... . .. :.... _ ........
PVto 14.32 233.48 31.21 ..
--
o for Title V* ( 61.25+0 23*= 61.48 20.54+0.23* =20.77
SOz 5.12 ( 665.79 67.43
.W_...._..:.:....:..::..:..........._...............:__.,.,....,....._ .................... _.._....:............:......................:............:......_...._.._.._.........:.::::..................._.............:_.._.......:..:...................
NOx ( 4.69 ( 61.66 42.38
._..:.._.:.:._.. _..._...._: ._.. _ .... _ . ........_ _. ...................
CO 16.93 145.48 ._. _.._._ 99.00
VOC _ FT 6.04 _ 52.69 35.82
HAPTotal � 0.76_F 11.26 7.66
HAPxisi,est(Formaldehyde) 0.40 3.49 2.37
............................._ . ..........._... ............ .. ............ ._............_....._....I._.........
.. .... ..
*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 PMio•
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Permit Discussion:
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 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 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 since Permit Issuance:
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:
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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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