AQ_F_0200103_20190717_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: 07/17/2019
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 54.7842m Long: 81 d 7.2120m 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 William Wallace Brynnan Lackey
HSE Coordinator HSE Director of North HSE Coordinator
[phone] America [phone]
[phone]
Compliance Data
Comments:
Inspection Date 07/17/2019,
Inspector's Name Donna Cook
Inspector's Signature: k Operating Status Operating
2( Compliance Code Compliance-inspection
1 Action Code FCE
Date of Signature: l On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
No emissions inventory on record.
* Highest HAP Emitted inpounds)
Five Year Violation History:Norte
Date Letter Tyne Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE: None
Date Test Results Test Method(s) Source(s)Tested

Borealis Compounds,Inc.
July 17, 2019
Page 2
Type Action: _Full Compliance _Partial Compliance _Complaint X Other: Compliance Assurance Visit
Evaluation Evaluation/Reinspection Investigation CAV
Data Tracking: X Date submitted for initial review 07/23/2019 J IBEAM WARNING/OB,NOD,NOV,NRE
/ X IBEAM Document
X IBEAM Inspection,list date inspected J / _IBEAM LAT/LONG,Facility Locked °�/
a
X IBEAM Inspection, list date draft is submitted X IBEAM LAT/LONG,Coordinates checked)k� .g
X IBEAM Inspection,pollutants/programs checked _IBEAM Complaint L L"
X IBEAM Planning,Next Inspection Date 07/01/2021/
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.
Safety Issues: The inspector should be cautious of forklift operations inside of this facility.
Lat/Long Coordinates: The facility's coordinates on "Maps of DAQ Regulated Facilities" are not
accessible on the DAQ web site. The latitude and longitude coordinates of this facility in IBEAM are
inaccurate and not locked. I changed the latitude and longitude coordinates in IBEAM to 35.914095
and-81.120501.
Email Contacts: The email addresses for the facility, authorized and technical contacts were verified by
Mr. Brynnan Lackey,health, safety and environmental coordinator. I changed the email addresses of the
facility,technical and authorized contacts in IBEAM.
Compliance Assurance Visit:
1. 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 this
facility from 6:30 am to 3 pm (1 shift),Monday through Friday, 50 weeks per year. Mr. Brynnan
Lackey, health, safety and environmental coordinator; Mr. Edward Turner, maintenance manager;
and Mr. Jason Menendez, operations manager, accompanied me during this visit.
2. Facility Contact Information:
During the inspection,I verified the facility contact information in IBEAM with Mr. Lackey. I
changed the facility, technical and authorized contact in IBEAM.

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Borealis Compounds,Inc.
July 17, 2019
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3. Compliance history file review:
This company has no compliance history since this facility is a greenfield. The current compliance
status is discussed in the following sections.
4. Source Observations:
This facility manufactures polypropylene pellets. The polypropylene in pellet form is delivered
by trucks in plastic-lined cardboard boxes. Mr. Lackey stated that polypropylene in pellet form
will be delivered in bulk either by rail and tanker truck later this year. The polypropylene in the
pellet form is unloaded manually from the plastic-lined cardboard boxes by using a wand to
pneumatically convey them 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 in pellet form is mixing 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 the 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 mater emissions. The six bag
break stations,two mixing silos, mixer, mixing room, pellet mixing room,top of the two
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. Another 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.
This facility.is currently only testing of products for customer specifications. No actual products
are being sold at this time. The polypropylene handling process was in operation at the time of
the visit. The talc handling and extrusion processes were not in operation. The two filter systems
were in operation. I observed no visible emissions from these emission sources or the filter
systems at the time of this visit.
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(225 gallons).
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,

Borealis Compounds,Inc.
July 17,2019
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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 diesel-fired fire pump engine has a non-resettable hour meter.The run hours on the meter
were 14.9. Mr. Lackey stated that the fire pump engine is tested once a week for 30 minutes.
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 IIII(4I). As a result,this
compression ignition engine complies with the requirements of the NESHAP Subpart 4Z by
meeting the requirements of NSPS Subpart 4I. No further requirements are required for this
engine under NESHAP Subpart ZZZZ(4Z)RICE.
This facility is 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.
The limitations of the 50 hours for on-emergency situations and 100 hours maximum for
maintenance checks and readiness testing have not been exceeded by this fire pump engine.
This office has not received any fugitive dust emissions complaints regarding this facility. This
company has paved roads at this facility. During this visit,I observed no fugitive dust from this
facility. I discussed with Mr.Lackey if any excess emissions had occurred at this facility since it
was in February 2019. Mr.Lackey stated that no excess emissions had occurred at this
facility since February 2019.
5. NSPS/NESHAP Review:
This company has no boilers, emergency/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 IIII(4I).
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 in pellet form,talc handling and extrusion
process 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 3 8,544,000
kg/yr(converted to 9,700 lbs/hr or 84,974,974 lbs/yr). The maximum process rate for the talc

Borealis Compounds, Inc.
July 17,2019
Page 5
handling is 5,000 ton/yr or 10,000,0001b/yr. Based on the maximum process rates from the
polypropylene pellet handling,talc handling and extrusion process,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.
This facility began operations in February 2019. This company is currently only testing of
products for customer specifications. No actual products are being sold at this time. The
maximum process rates were estimated by Mr. Jason Menendez, operations manager,to be 3,500
kg/hr(converted to 7,716 lbs/hr)for the polypropylene pellet handling and extrusion process; 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 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 of 14.9 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(21)
.0521-visible emissions; 2D .0535-excess emissions;2D .0540-fugitive dust emissions;40 CFR
Part 63 NESHAP Subpart ZZZZ(4Z)and 40 CFR Part 60 NSPS Subpart IIII(4I). The
compliance assurance visit checklist is attached on page 6.
'DLC:Ihe
c: MRO File
https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/ALEXANDER/00103/fNSPECT_20190717_CAV.docx

Borealis Compounds,Inc.
July 17,2019
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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]
Mailing Address: 401 W.E.Baab Industrial Drive,Taylorsville,NC 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): 6:30am to 3 pm(1shift),Monday-Friday,50weeks per year
Opacity(%)-indicate any non-zero opacities observed: 01%
Odors-indicate if any objectionable odors were detected beyond the property boundary: None
Fugitive dust-indicate whether fugitive 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 84,974,974lbs/yr)maximum process rate and talc handling 5,000 ton/yr or 10,000,000 Ib/yr;Actual process rates=
3,500 kg/hr(7,716lbs/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
usinga 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 subjectto 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,S02.NOx,VOCs,CO,HAPs,and TAPs
are each<5 tpy and whose actual total aggregate of these emissions are<10 tpy
•Can be subject to 40 CFR Part 63(MACTor GACT)and 40 CFR Part 60(NSPS)
•Cannot be subject to Rule 2Q.0315(Synthetic Minor Facilities)or 2Q.0500(Title V-Procedures)