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Home My WebLink AboutAQ_F_0800044_20180420_CMPL_NOV ROY COOPER Governor a K- MICHAEL S. REGAN Secretary Air Quality MICHAEL A.ABRACZINSKAS ENVIRONMENTAL QUALITY Director April 20, 2018 CERTIFIED MAIL 7017 0660 0001 0937 6148 RETURN RECEIPT REQUESTED Dr. David Peele, President Avoca LLC PO Box 129 841 Avoca Farm Road Merry Hill,North Carolina 27957 SUBJECT: Notice of Violation 40 CFR Part 63,Subpart ZZZZ.—"NESHAPS for Stationary RICE",and 15A NCAC 2D .0530"Prevention of Significant Deterioration" Permit Specific Conditions 2.1.F.3.fi. and 2.2.B.2.r. Avoca LLC,Merry Hill,Bertie County,North Carolina Air Permit No.01819T49,Facility ID: 0800044,Fee Class: Title V Dear'Dr. Peele: Ms. Betsy Huddleston with the Washington Regional Office of the Division of Air Quality completed Avoca LLC's annual permit compliance inspection on April 9,2018. Review of permit required records for calendar year 2017 was conducted as part of the inspection. The review resulted in discovery that annual maintenance activities on two emergency engines. Additionally,the February 2017 monthly leak detection test on the Botanical process area pumps were not conducted. 40 CFR Part 63 Subpart ZZZZ, as referenced in Permit Specific Condition 2.1.17.31i., stipulates that the oil and filter must be changed every 500 hours of operation or annually, whichever comes first, on emergency engines ID Nos. E104 and FP. Avoca's maintenance records did not indicate that the oil and filter changes had been completed for calendar year 2017. Rather, a record was provided showing that Gregory Poole is contracted to perform the changeouts every other year. The failure to perform the annual oil and filter changes on E104 and FP is a violation of Subpart ZZZZ and condition 2.1.17.31i. The Division of Air Quality does have administrative authority to grant alternative work practices under Subpart ZZZZ, if they are formally requested by the facility. Since the engine maintenance schedule is at Gregory Poole's recommendation based on how little the engines operate,Avoca is eligible to submit such a request. Regarding leak detection,to demonstrate compliance with Best Available Control Technology VOC emissions limits established under 15A NCAC 2D .0530 "Prevention of Significant Deterioration" (PSD), Permit Specific Condition 2.2.B.2. contains leak detection and repair(LDAR)requirements for Rotocel and Recovery, Botanical and Biomass operations. The condition requires Avoca to follow LDAR procedures under Part 63, Subpart UU. This subpart, as referenced in condition 2.2.B.2.r. requires monthly instrumental LDAR tests of all pumps in light liquid service. A records review indicated that there was no record of the February 2017 pump LDAR for the Botanical Operation, and it was confirmed by Mr. Brian Conner that the LDAR was not conducted. While the Botanical process only operated with VOC emissions for one week(February 6,2017 through February 10,2017) in all of calendar year 2017, the monthly pump LDAR was still required, and failure to complete it is a violation of condition 2.2.B.2.r. State of North Carolina I Environmental Quality I Air Quality Washington Regional Office 1943 Washington Square Mall I Washington,NC 27889 252 946 6481 T 1 252 975 3716 F Dr. David Peele April 20,2018 Page 2 During the annual permit compliance inspection Ms.Huddleston and Mr.Jared Findley discussed maintenance and inspection of the wood boilers' bag leak detection system(BLDS)with respect to requirements provided in 40 CFR Part 63, Subpart DDDDD. It was concluded that Avoca is performing adequate inspection,maintenance and calibration activity on the bag leak detection system;however,the activities do not appear to be in complete accordance with the EPA guidance document EPA-454/R-98- 015 or the Goyen(manufacturer)operation manual. It is recommended that Avoca perform a review of BLDS maintenance and inspection activities against these documents to ensure the regulatory requirements are satisfied. It is also recommended that Avoca should then create a site-specific monitoring plan(that includes inspection, maintenance and calibration activities),and submit it to DAQ for approval of any alternative methods. Please be advised that any violation can result in possible civil penalties as per North Carolina General Statute 143-215.114A. North Carolina General Statute(a)(1)and(2)provides that a civil penalty may be assessed pursuant to North Carolina General Statute 143-215.107. Please remember to report this NOV in your March 2019 Title V Annual Compliance Certification for calendar year 2018, noting that the violations occurred in calendar year 2017. If you have any questions or concerns about this Notice of Violation,please do not hesitate to call Betsy Huddleston at(252)948-3836. Sincerely, .r Robert P. Fisher,Regional Air Quality Supervisor Division of Air Quality,NCDEQ RPF/eth cc: Washington Regional Office Files G:\AQ\Shared\Bertie08\00044\Enforcement\20180420NOV.doc ROY COOPER Governor a K- MICHAEL S. REGAN Secretary Air Quality MICHAEL A.ABRACZINSKAS ENVIRONMENTAL QUALITY Director April 20, 2018 CERTIFIED MAIL 7017 0660 0001 0937 6148 RETURN RECEIPT REQUESTED Dr. David Peele, President Avoca LLC PO Box 129 841 Avoca Farm Road Merry Hill,North Carolina 27957 SUBJECT: Notice of Violation 40 CFR Part 63,Subpart ZZZZ.—"NESHAPS for Stationary RICE",and 15A NCAC 2D .0530"Prevention of Significant Deterioration" Permit Specific Conditions 2.1.F.3.fi. and 2.2.B.2.r. Avoca LLC,Merry Hill,Bertie County,North Carolina Air Permit No.01819T49,Facility ID: 0800044,Fee Class: Title V Dear'Dr. Peele: Ms. Betsy Huddleston with the Washington Regional Office of the Division of Air Quality completed Avoca LLC's annual permit compliance inspection on April 9,2018. Review of permit required records for calendar year 2017 was conducted as part of the inspection. The review resulted in discovery that annual maintenance activities on two emergency engines. Additionally,the February 2017 monthly leak detection test on the Botanical process area pumps were not conducted. 40 CFR Part 63 Subpart ZZZZ, as referenced in Permit Specific Condition 2.1.17.31i., stipulates that the oil and filter must be changed every 500 hours of operation or annually, whichever comes first, on emergency engines ID Nos. E104 and FP. Avoca's maintenance records did not indicate that the oil and filter changes had been completed for calendar year 2017. Rather, a record was provided showing that Gregory Poole is contracted to perform the changeouts every other year. The failure to perform the annual oil and filter changes on E104 and FP is a violation of Subpart ZZZZ and condition 2.1.17.31i. The Division of Air Quality does have administrative authority to grant alternative work practices under Subpart ZZZZ, if they are formally requested by the facility. Since the engine maintenance schedule is at Gregory Poole's recommendation based on how little the engines operate,Avoca is eligible to submit such a request. Regarding leak detection,to demonstrate compliance with Best Available Control Technology VOC emissions limits established under 15A NCAC 2D .0530 "Prevention of Significant Deterioration" (PSD), Permit Specific Condition 2.2.B.2. contains leak detection and repair(LDAR)requirements for Rotocel and Recovery, Botanical and Biomass operations. The condition requires Avoca to follow LDAR procedures under Part 63, Subpart UU. This subpart, as referenced in condition 2.2.B.2.r. requires monthly instrumental LDAR tests of all pumps in light liquid service. A records review indicated that there was no record of the February 2017 pump LDAR for the Botanical Operation, and it was confirmed by Mr. Brian Conner that the LDAR was not conducted. While the Botanical process only operated with VOC emissions for one week(February 6,2017 through February 10,2017) in all of calendar year 2017, the monthly pump LDAR was still required, and failure to complete it is a violation of condition 2.2.B.2.r. State of North Carolina I Environmental Quality I Air Quality Washington Regional Office 1943 Washington Square Mall I Washington,NC 27889 252 946 6481 T 1 252 975 3716 F Dr. David Peele April 20,2018 Page 2 During the annual permit compliance inspection Ms.Huddleston and Mr.Jared Findley discussed maintenance and inspection of the wood boilers' bag leak detection system(BLDS)with respect to requirements provided in 40 CFR Part 63, Subpart DDDDD. It was concluded that Avoca is performing adequate inspection,maintenance and calibration activity on the bag leak detection system;however,the activities do not appear to be in complete accordance with the EPA guidance document EPA-454/R-98- 015 or the Goyen(manufacturer)operation manual. It is recommended that Avoca perform a review of BLDS maintenance and inspection activities against these documents to ensure the regulatory requirements are satisfied. It is also recommended that Avoca should then create a site-specific monitoring plan(that includes inspection, maintenance and calibration activities),and submit it to DAQ for approval of any alternative methods. Please be advised that any violation can result in possible civil penalties as per North Carolina General Statute 143-215.114A. North Carolina General Statute(a)(1)and(2)provides that a civil penalty may be assessed pursuant to North Carolina General Statute 143-215.107. Please remember to report this NOV in your March 2019 Title V Annual Compliance Certification for calendar year 2018, noting that the violations occurred in calendar year 2017. If you have any questions or concerns about this Notice of Violation,please do not hesitate to call Betsy Huddleston at(252)948-3836. Sincerely, .r Robert P. Fisher,Regional Air Quality Supervisor Division of Air Quality,NCDEQ RPF/eth cc: Washington Regional Office Files G:\AQ\Shared\Bertie08\00044\Enforcement\20180420NOV.doc