20221006_DAQ

Drafting and Design Services, Inc.
6728 Carbonton Road
Sanford, NC 27330
[phone]
September 29, 2022
Bradley Newland, Environmental Regional Supervisor
NC Department of Environmental Quality RECEIVED
Wilmington Regional Office — Division of Air Quality
127 Cardinal Drive Extension OCT 0 6 1011
Wilmington, NC 28405
LAND QUALITY
RE: Request for Division of Air Quality Permit Determination MINING PROGRAM
Primo Holdings, Inc. — Mobile Sand Screening Plant for Existing Sand Mine
Pender County —Cape Fear River Basin
Dear Mr. Newland:
Primo Holdings, Inc., is applying for a mining permit modification with the Division of Energy, Mineral,
and Land Resources (DEMLR) to permit a sand mining operation at Black River Club Drive, Pender County. Our
intent is to utilize a Terex M2100 three track mounted mobile sand wash plant with a four -cylinder CAT diesel
engine (131 HP @ 2200 PRM) to produce up to 200,000 tons of wet sand product per year. The mobile
screening operation will be removed from the site no later than 12 months from its placement.
We have completed the DAQ emissions calculation spreadsheet based upon the annual 200,000 ton
anticipated sand production and have attached the completed spreadsheet for your consideration. Based upon
this analysis, our estimated actual emissions of total particulate matter < 10 microns (PM10) for this mobile sand
screening operation will be approximately 0.24 tons per year with estimated potential emissions of 2.11 per
year. As these values are less than 10 tons per year, it appears that our mobile sand screening operation meets
the exemption from obtaining a DAQ permit under 15A NCAC 02Q .0102(d). We have also attached
manufacturer information on the Terex M2100 mobile screening system for your information.
Primo Holdings, Inc. respectfully requests that DAQ review this information and respond in writing
confirming that neither a DAQ permit nor registration is required at this time. In addition, we are requesting
clarification on whether or not we would be exempt from DAQ permitting if we decided to keep the mobile
screen onsite longer than 12 months while not exceeding annual production of 200,000 tons of wet sand
product based upon our very low estimated actual emissions of total particulate matter.
Thank you for your time and assistance with this matter. If you have any questions regarding
this matter, please contact Michael Blakey - Drafting and Design Services, Inc. [phone].
Sincerely,
Michael��
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