AQ_F_0800107_20180920_CMPL_NOV-NRE

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ROY COOPER NORTH CAROLINA
Governor Env/ronmental Quality
MICHAEL S.REGAN
Secretary
MICHAEL ABRACZINSKAS
Dlrector
September 20,2018 CERTIFIED MAIL 7017 0660 0001 0937 6278
RETURN RECEIPT REQUESTED
Mr. Garald Cottrell, President
W. E. Partners II,LLC
312 South Front Street, Suite 6
New Bern,North Carolina 28562
SUBJECT: Notice of Violation/Notice of Recommended Enforcement
Electrostatic Precipitator Field 2 Transformer Failure
40CFR Part 63,Subpart JJJJJJ,Section 63.11201(c) and Table 3
Permit Specific Condition I Ledi.D.
40CFR Part 63,Subpart A,Section 63.10(d)(5)(ii)
G.S. 143-215.108(c)(1)and Permit General Condition B.6.
W.E.Partners II,LLC
Lewiston,Bertie County,North Carolina
Facility ID: 0800107,Fee Category: Synthetic Minor
Air Permit No. 10126R03
Dear Mr. Cottrell:
On August 17,2018 Ms. Betsy Huddleston of this office received an email from you notifying the
Division of Air Quality that the transformer on the second field of the ESP had failed. Your email stated
that a fuse to the communication feedback loop was also lost with the transformer failure, so personnel
did not have an indication that only one field on the ESP was in operation.The email also stated that the
secondary power 30-day rolling average data had dropped below the parametric monitoring minimum
limit established during performance testing for compliance with 40 CFR Part 63, Subpart JJJJJJ. Based
upon when the rolling average began to fall below the minimum,you stated that the transformer likely
failed sometime in June 2018. Therefore,the boilers have operated with only one ESP field in operation
for at least nine weeks.
The failure of the ESP secondary power thirty-day rolling averages to meet the 3.4 kW minimum
is considered a continuing violation of 40CFR 63.11201(c),Table 3 of Subpart JJJJJJ,and Permit
Specific Condition I Le.ii.D. The minimum was established during the required performance testing of
the boilers while both ESP fields were in operation on 5/10/2012.
Per General Statute 143-215.108(c)(1)and permit General Condition No. 6, "the facility shall be
properly operated and maintained at all times in a manner that will effect an overall reduction in air
pollution. Unless otherwise specified by this permit,no emission source may be operated without the
concurrent operation of its associated air cleaning device(s)and appurtenances." Your August 17,2018
email notification states that a new transformer will not arrive for ten to twelve more weeks. The permit
DFQ
North Carolina Department of Environmental Quality I Division of Air Quality
Washington Regional office 1 943 Washington Square Mall I Washington,North Carolina 27889
252.946.6481 T 1 252.975.3716 F

- —Mr. Garald Cottrell - --
September 20,2018
Page 2 of 2
has no condition allowing a long-term alternate operating scenario on the ESP,and control equipment
downtime is not acceptable without a permit or special consent issued by the DAQ. W.E.Partners II is
considered in continuing violation of Permit General Condition B.6.
Since you stated the ESP is equipped and designed to meet the particulate emission limit with one
of two fields operational,the office requires that W.E.Partners II,LLC confirm compliance by
performing EPA Methods 1-5 particulate stack testing at the outlet of the ESP with only the first field in
operation. A test protocol must be submitted to this office within 10 days of receipt of this letter. The
testing must be completed no later than 30 days of receipt of this letter.
Please be aware that 40CFR Part 63, Subpart A, Section 63.1 0(d)(5)(ii)states, any time an action
taken by an owner or operator during a startup or shutdown that caused the source to exceed any
applicable emission limitation in the relevant emission standards, or mayinction (including actions taken
to correct a mayiinction) is not consistent with the procedures specified in the affected source's startup,
shutdown, and ma�Nnction plan, the owner or operator shall report the actions taken for that event
within 2 working days after commencing actions inconsistent with the plan followed by a letter within 7
working days after the end of the event. The immediate report required under this paragraph (d)(5)(h)
shall consist of a telephone call(or facsimile (FAA) transmission) to the Administrator within 2 working
days after commencing actions inconsistent with the plan, and it shall be followed by a letter, delivered or
postmarked within 7 working days after the end of the event, that contains the name, title, and signature
of the owner or operator or other responsible official who is certifying its accuracy, explaining the
circumstances of the event, the reasons for not following the startup, shutdown, and matAmction plan,
describing all excess emissions and/or parameter monitoring exceedances which are believed to have
occurred(or could have occurred in the case of matNrictions), and actions taken to minimize emissions in
conformance with§63.6(e)(1)(i)." W.E.Partners did not provide notification to the Division of Air
Quality of the transformer failure within two days of discovery.
Each violation can result in possible civil penalties as per North Carolina General Statute 143-
215.114A. A civil penalty may be assessed against a company who violates or fails to act in accordance
with the terms, conditions,and/or requirements of any permit issued under General Statute 143-215.108.
If you have any questions or concerns, please contact Ms. Betsy Huddleston or me at(252)946-6481.
r
Sincerely,
Robert P. Fisher,Regional Supervisor
Division of Air Quality,NCDEQ
RPF/eth
r cc: Washington Regional Office Files
RCO/SSCB
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