AQ_F_0800107_20150512_CMPL_NOV-NRE

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North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R.van der Vaart
Governor Secretary
May 12,2015 CERTIFIED MAIL 7011 1150 0000 4206 7036
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 Recommendation of Enforcement
40CFR Part 63,Subpart JJJJJJ,Boiler GACT
ESP Operation with Respect to the Definition of Boiler Startup and
Requirements for Secondary Power Monitoring and Recordkeeping
W.E.Partners II,LLC
Lewiston,Bertie County,North Carolina
Air Permit No. 101261102,Facility ID: 0800107,Fee Category: Synthetic Minor
Dear Mr. Cottrell;
On September 22,2014 the Division of Air Quality(DAQ)issued a Notice of Deficiency(NOD)
to W.E.Partners 11,LLC,that set a deadline of November 30, 2014 for completion of changes in the ESP
secondary power monitoring data system to record and store all data in conformance with requirements in
the Boiler GACT(Subpart JJJJJJ). On March 19,2015,Ms. Betsy Huddleston of this office conducted a
permit compliance inspection of W.E. Partners II,LLC.,During the inspection she asked to view the ESP
secondary power monitoring data to confirm the system had been properly modified to store minute-
measurements,hourly averages and twelve-hour averages. She was told that the minute and hourly data
was not accessible at the plant. On March 20,2015 Ms. Huddleston received an email from you stating
that the modifications had not been made to the data system. On April 7,2015 Ms.Huddleston received
an email from you confirming that the system had been updated to store hourly averages beginning April
1,2015. On April 23,2015 you contacted Ms. Huddleston to inform it was discovered that the boiler
operating system did actually record secondary power on the ESP every six minutes,but the data rolled
over on an annual basis. Ms.Huddleston met with Mr. Chad Hoggard at the facility on May 1,2015 to
confirm the six-minute data is measured and electronically stored.
The September 22,2014 NOD also cited an issue concerning non-operation of the ESP while the
boilers supplied low steam to the wastewater treatment system during the winter when the rendering plant
was not in operation. During Ms.Huddleston's compliance inspection on March 19,2015, operator logs
indicated the facility continued to not operate the ESP while supplying low steam to the wastewater
treatment system on weekends when the rendering plant was down during the winter of 2014-2015. The
issue was discussed with Mr. Chad Hoggard, and he confirmed the practice.
This letter serves as a formal notification that the failure of W.E. Partners I1,LLC to meet the
November 30, 2014 deadline to modify the ESP secondary power monitoring data system is a violation of
Subpart JJJJJJ sections 63.111225(c)(6), 63.10(b)(1)and 63.10(b)(2)(vii). Section§63.11225(c)(6), states
1601 Mail Service Center,Raleigh,North Carolina 27699-1601
Phone;919-707-86001 Internet;www.ncdenr.gov
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Mr. Garald Cottrell
May 12, 2015
Page 2
that the facility must keep the records of all monitoring data. Furthermore, section 63.10(b)(1) states that
the facility must maintain files of all information required by the subpart recorded in a form suitable and
readily available for expeditious inspection. §63.10(b)(1)and§63.10(b)(2)(vii)require the facility to
"retain all measurements needed to demonstrate compliance with the relevant standard." All Subpart
JJJJJJ records must be retained for 5 years. This violation may be considered continuous until the subpart
records retention requirements are fully satisfied.
Furthermore,the failure to operate the ESP when the boilers are supplying steam to the plant or
wastewater system is a violation of Subpart JJJJJJ, section §63.11205,which requires the facility to
operate and maintain any affected source, including associated air pollution control equipment and
monitoring equipment, in a manner consistent with safety and good air pollution control practices for
minimizing emissions. The DAQ has determined two possible resolutions to the violation concerning
non-operation of the ESP under low steam conditions. First,W.E. Partners II may test the boiler
particulate emissions for compliance with the Subpart JJJJJJ standard of 0.07 lb/MMBtu(filterable u
fraction)while producing low steam without the operation of the ESP. Second the facility may consider
petitioning EPA for possible approval of an alternative operating scenario to comply with Subpart JJJJJJ.
The violation must be resolved prior to the start of the next winter season of supplying steam to the
wastewater treatment system.
This office intends to submit a recommendation for enforcement action to the Director of the
Division of Air Quality. These violations can result in possible civil penalties as per North Carolina
General Statute 143-215.114A. A civil penalty of not more than $25,000.00 per violation 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 believe there
are additional factors that should be considered,please send the information to the Washington Regional
Office within two weeks of receipt of this letter. Your documentation will be forwarded with the
enforcement package to the Director.
It is recommended that you review,and if needed, implement the Subpart JJJJJJ monitoring
downtime and malfunction requirements cited in the September 22, 2014 NOD. If we can provide
additional information or assistance,please do not hesitate to call Betsy Huddleston or me at
[phone].
Sincerely,
";�V
Robert P. Fisher
Regional Air Quality Supervisor
RPF/eth
cc: Washington Regional Office
(GAAQ\Shared\Bertie08\00107\20150512nre.doc).

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W. E. Partners II, LLC
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