AQ_F_1000067_20180712_CMPL_NOV-NRE

ROY COOPER
{'. Governor
MICHAEL S. REGAN
Seereavy
Air Quality MICHAEL A. ABRACZINSKAS
ENVIRONMENTAL QUALITY Dhecto,
July 12, 2018
Certified Mail No. 7016 0910 0000 6171 3671
Return Receipt Requested
Mr. Frank Hayward, Plant Manager
CPI USA North Carolina - Southport Plant
1281 Powerhouse Drive SE
Southport,NC 28461
SUBJECT: Addendum to January 24, 2017 Notice of Violation/Notice of Recommendation for
Enforcement
15A NCAC 2D .0530 "Prevention of Significant Deterioration" (PSD)
40 CFR 51.166 "Prevention of Significant DeterioraTi-on of Air Quality"
S02 Emissions—Boiler ID Nos. ES-1 and ES-2
CPI USA North Carolina - Southport Plant
Southport, Brunswick County,North Carolina
Air Permit No. 05884T21, Facility ID No. 1000067
Dear Mr. Hayward:
Reference is made to the NOV/NRE dated January 24, 2017 that was sent by this office to your facility
for failure to submit a Prevention of Significant Deterioration (PSD) permit application for the 2008
Boiler Control Retrofit and Increased Wood/Biomass Firing Project. As described in the 2017
NOV/NRE, the Division of Air Quality received a report on March 2, 2016, from CPI USA North
Carolina- Southport Plant (CPI) summarizing projected vs. actual emissions for the plant boilers, ID
Nos. ES-1 and ES-2.
In the report, the actual emissions of carbon monoxide (CO), sulfur dioxide (S02), and particulate
matter(PM) were significantly higher than the projected emissions contained in the original permit
application for the project. This resulted in DAQ reviewing the calculations contained in the original
application and utilized by the facility to justify the avoidance of submitting a PSD application. DAQ
determined that your facility's CO and PM emissions were greater than the projected actual emissions
originally submitted, which resulted in the January 24, 2017 NOV/NRE. Since that time, our central
office permitting staff conducted an additional review and found that the PSD threshold level of 40
tons per year for S02 was also exceeded. Based on this analysis, a PSD application for S02 should
have been submitted for the 2008 project.
Slate of North Carolina Environmental Quality I Air Quality
Wilmington Regional Office 1127 Cardinal Drive Extension I Wilmington.North Carolina 28405
910 796 7215 T 1 910 350 2004 F

CPI - Southport
Page 2
This letter is intended to notify you that CPI is in violation of 15A NCAC 2D .0530 and 40 CFR
50.166 for failure to submit a Prevention of Significant Deterioration (PSD) permit application
for S02 for the 2008 NOx/SO2 Boiler Control Retrofit and Increased Wood/Biomass Firing
Project. After the January 24, 2017 NOV/NRE, CPI Southport did submit the required PSD
application for CO and PM. Please submit a PSD application for S02 to this office within 45
days of receipt of this NOWNRE.
Please be advised that this office intends to submit a recommendation for enforcement action to the
Director of the Division of Air Quality. North Carolina General Statute 143-215.114A provides
that 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, or requirements of a permit
required by North Carolina General Statute 143-215.108.
If you have an explanation for the violation that you wish to present, or if you believe the findings
stated in this letter are incorrect, please respond in writing within fifteen (15) days after receipt of
this letter. Your documentation will be forwarded with the enforcement package to the Director for
his review.
If you have any questions or concerns regarding this matter,please contact Ashby Armistead or myself
at 910-796-7215.
Sincerely,,)l
v�
Brad ewland
Regional Air Quality Supervisor
Division of Air Quality, NCDEQ
cc: WiRO Files
BTN