AQ_F_0200098_20180326_CMPL_NOV

ROY COOPER
} Governor
MICHAEL S. REGAN
Secretary
AieQualrty MICHAEL A. ABRACZINSKAS
ENVIRONMENTAL.DUALITY Director
March 26, 2018
CERTIFIED MAIL
RETURN RECEIPT REQUESTED 7016 1370 0000 2591 0899
Mr. David Himebaugh
President
Piedmont Composites and Tooling, LLC
33 Lewittes Road
Taylorsville,NC 28681
Subject: Notice of Violation—Monitoring Requirements
Piedmont Composites and Tooling, LLC
Taylorsville, North Carolina
Alexander County
03/0200098 —Title V
Air Permit No. 09941T02
Dear Mr. Himebaugh:
.Air Permit No. 09941T02 was issued to Piedmont Fiberglass, Taylorsville, Alexander County,
North Carolina on February 7, 2014, with an effective date of February 7, 2014. Specific Condition and
Limitation No. 2.1.A.2.d.i of said permit states in part:
"The results of the monitoring shall be maintained in a logbook (written or electronic
format) on-site and made available to an authorized representative upon request. The
logbook shall record the following:
i. all data, assumptions, and calculations used to determine organic HAP
emission factors including records of resin and gel coat use, organic
HAP content, and operation where the resin is used. Resin use records
may be based on purchase records if the Permittee can reasonably
estimate how the resin is applied. The organic HAP content records
may be based on MSDS or on resin specifications supplied by the resin
supplier [63.5895(c)]; and
ii. certified statement that the Permittee is in compliance with the work practice
requirements listed above.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if these
records are not maintained."
State of North Carolina I Environmental,Quality I Air Quality
Mooresville Regional Office I,610 East Center Avenue;Suite 301 I Mooresville,North Carolina 28115.
704:6631699 T 7046637579 F

Mr. David Himebaugh
March 26, 2018
Page 2
Ms. Karyn Barksdale of this office performed an inspection of your facility on March 14, 2018.
During that inspection, you were not able to provide records to show that monitoring was being conducted.
Several days after the inspection, it was communicated to Ms. Barksdale that the data she requested was
being compiled. Therefore, this Notice of Violation is issued to Piedmont Composites and Tooling, LLC
for violation of Air Permit No. 09941T02 Specific Condition and Limitation No. 2.LA.2.d.i.
Specific Condition and Limitation No. 2.1.B.3.b of said permit also states in part:
"The Permittee shall keep records of gallons of HAP coatings that
are used to coat plastic parts or products on a monthly basis to
ensure compliance. The Permittee shall be deemed in
noncompliance with 15A NCAC 2D .1111 if these records are not
maintained or the HAP coating usage exceeds the limits."
During the March 14, 2018 inspection, Ms. Barksdale observed that logs are not being maintained
as required. Therefore, this Notice of Violation is also issued to Piedmont Composites and Tooling, LLC
for violation of Air Permit No. 09941T02 Specific Condition and Limitation No. 2.1.B.3.b.
It is requested that a written response to this Notice of Violation be submitted to this office as
soon as possible, but no later than ten days following receipt of this notice. Your response should
describe any corrective actions that have been taken by the company to assure compliance with the
referenced permit conditions at all times.
In addition, it is requested that you submit a revised Title V Annual Compliance Certification for
calendar year 2017, to this office and the EPA (Air and EPCRA Enforcement Branch, EPA, Region 4, 61
Forsyth Street, Atlanta, GA 30303), identifying the above deviations from your Title V operating permit.
Please be advised that the violations cited in this letter are considered a deviation of your Title V
permit. These violations must be included in your semi-annual reports and/or annual compliance
certification, as outlined in your Title V permit.
It should be noted that the violation cited in this letter or any additional documented violations could
result in the initiation of an enfofcement action by this office in accordance with North Carolina General
Statute 143-215.114A,which provides for the assessment of civil penalties.

Mr. David Himebaugh
March 26,2018
Page 3
We appreciate your immediate attention to this environmental concern. If you have any questions
with reference to this matter,please do not hesitate to contact Ms. Barksdale or Mr. Joe Foutz, regional
compliance supervisor, at [phone].
Sincerely,
Bruce J.Ingle, Regional Supervisor
Division of Air Quality, NCDEQ
KRB:lhe
c: MRO File
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