AQ_F_1900039_20180531_CMPL_NOD

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
Air Quality MICHAEL A. ABRACZINSKAS
ENVIRONMENTAL QUALITY Director
May 31,2018
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Glen Lang, Southeast Operations Manager
Boise Cascade Wood Products,LLC-Moncure
306 Corinth Road
Moncure,NC 27559
SUBJECT: Notice of Deficiency—Title V Operating Limitations
Boise Cascade Wood Products,LLC-Moncure
Moncure, Chatham County,North Carolina
Air Permit No. 03424T26
Facility ID Number: 1900039
Fee Class: Title V
Dear Mr. Lang:
The North Carolina Division of Air Quality(NC DAQ)received a permit application from your facility on
January 30, 2018,to permit a 250 hp diesel-fired fire pump emergency engine(ID No. IES-23) as a non-emergency
engine. In an April 19'email correspondence pertaining to the permit application, a staff member of Boise Cascade
stated that Boise Cascade Wood Products,LLC—Moncure had exceeded the maximum allowable non-emergency
hours for calendar year 2017 for your facility's fire pump emergency engine. The allowable non-emergency hours
are prescribed under NSPS IIH and MACT ZZZZ. The exceedance was also documented in the 2017 Title V
Annual Compliance Certification(ACC)received on March 1,2018 and March 5,2018 (revised ACC). This
engine was used to respond to a 2017 fire event in which the audible alarm associated with the start of the engine
malfunctioned. The audible alarm is intended to warn staff of a possible fire and remind them to shutoff the fire
pump when it is no longer needed. As a result,the engine continued to operate after the fire event until it ran out of
fuel. According to the April 19'email, approximately 60 hours of operation were logged for this event. This
exceeds the 50-hour per calendar year limit. While this piece of equipment is listed as an"Insignificant Activity
under 15A NCAC 02Q .0503(8)"in your T26 permit,compliance with this NSPS and MACT standard and their
provisions is still required.
The Subpart ZZZZ MACT standard at 40 CFR§63.6640(f)(3) states as follows:
Emergency stationary RICE located at major sources of HAP may be operated for up to 50 hours
per calendar year in non-emergency situations. The 50 hours of operation in non-emergency
situations are counted as part of the 100 hours per calendar year for maintenance and testing and
emergency demand response provided in paragraph (g(2) of this section. The 50 hours per year for
non-emergency situations cannot be used for peak shaving or non-emergency demand response, or
to generate income for a facility to supply power to an electric grid or otherwise supply power as
part of a financial arrangement with another'entity.
Since there are no records that document similar incidences in years past,DAQ is regarding this infraction as a
monitoring/recordkeeping oversight.
State of North Carolina I Environmental Quality I Air Quality
Raleigh Regional Office 1 3800 Barrett Drive I Raleigh,North Carolina 27609
919 791 4200 T 1 919 8812261 F

Boise Cascade Wood Products, LLC-Moncure
May 31, 2018
Page 2
Other than being aware of this regulatory requirement and assuring that in the future non-emergency use
hours remain at or below 50 hours per calendar year,there is no direct action that needs to be taken as a result of
this Notice of Deficiency(NOD). However,please be aware that the sum of maintenance hours, readiness testing
and non-emergency hours must sum to 100 hours or less.
40 CFR§63.6640(f)(2)(i) states as follows:
Emergency stationary RICE may be operated for maintenance checks and readiness testing,
provided that the tests are recommended by federal, state or local government, the manufacturer,
the vendor, the regional transmission organization or equivalent balancing authority and
transmission operator, or the insurance company associated with the engine. The owner or
operator may petition the Administrator for approval of additional hours to be used for
maintenance checks and readiness testing, but a petition is not required if the owner or operator
maintains records indicating that federal, state, or local standards require maintenance and testing
of emergency RICE beyond 100 hours per calendar year.
Based on past records of annual readiness testing hours, it appears that this limit will likely not be exceeded.
You should still carefully monitor this engine's hours of use each year. If an exceedance seems likely to occur,
please petition the DAQ for approval of additional hours. Additional hours of readiness testing can be granted if
testing is required by your insurance carrier.
To address the deficiency described above,please submit a written response to this office by July 2,
2018, describing actions taken by your company to ensure future compliance with the NSPS IIII and MACT
ZZZZ regulations. This office also recommends that you or a designated company representative review your air
permit to ensure that you understand all of the specific and general permit conditions. Please note the operating
limitation requirements, and make the necessary provisions to ensure that these requirements are met within the
specified time frames.
Any future exceedance of your engine's hourly limits may be considered a violation of your air permit. Any
violation of air quality regulations is subject to the assessment of civil penalties as per North Carolina General
Statute 143-215.114A. As an additional reminder,this Notice of Deficiency is required to be referenced in your
facility's annual compliance certification(ACC), in accordance with Section 3,General Condition P of your Title V
permit. Your 2018 ACC is due by March 1,2019.
We appreciate your immediate attention to this concern. If you have any questions,please contact Matthew
Mahler, Environmental Engineer, or me at(919) 791-4200.
Sincerely,
1hy-11
William T.Wike,Jr.,P.E.
Acting Supervisor of RRO,Compliance
Division of Air Quality,NCDEQ
cc: RRO Files