AQ_F_3300170_20220128_CMPL_NOV-NRE (4)

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
MICHAEL ABRACZINSKAS
Direcror
NORTH CA ROLINA
Environmental Quality
January 28, 2022
CERTIFIED MAIL 7020 3160 0000 2219 0999
RETURN RECEIPT REQUESTED
Mr. Scott Ellis
Director of Manufacturing Support
HC Composites LLC
I 090 West Saint James Street
Tarboro, NC 27886
SUBJECT: Notice of Violation/Notice of Recommendation for Enforcement (NOV/NRE) -
MACT Subpart VVVV Semi-Annual Reporting Requirements
Dear Mr. Ellis:
HC Composites LLC
Tarboro, Edgecombe County, North Carolina
Facility ID No. 3300170;
Permit No. 08819T07;
Fee Class: Title V
The Raleigh Regional Office received a late MACT Subpart VVVV semi-annual report for the first six-
month period of the 2021 calendar year from your facility in Tarboro, Edgecombe County, North Carolina. HC
Composites LLC is required by Air Pennit No. 088 I 9T07 to submit this report semi-annually by March I and
September I of each year. An incomplete first half semi-annual report for calendar year 2021 was received on
September 13, 2021; the remaining information was submitted on November 29, 2021. The reporting is required
by federal rule 40 CFR Part 63, National Emission Standards/or Hazardous Air Pollutants (NESHAP), Subparl
VVVV for Boat Manufacturing. This letter is to inform you that failure to submit your semi-annual report by the
due date is a violation of the reporting requirements specified in Section 2.1 A.3.11. of your Title V permit,
which states the following:
The Permittee shall submit a semiannual report, acceptable to the Regional Air Quality Supervisor, of
the applicable information specified in Section 2.1 A.3.mm. below. The report must cover the applicable
semiannual reporting period from January JS' through June JO'h or from July /51 through December 3 JJ',
and must be postmarked no later than 60 calendar days after the end of the semiannual reporting
period.
Any report postmarked more than 60 days after the reporting period is considered delinquent and subject to the
assessment of civil penalties as per the authority of North Carolina General Statute I 43-215.1 l 4A.
North Carolina Department of Environmental Quality I Division of Air Quality
Raleigh Regional Office I 3600 Barrett Drive I Raleigh. North Carolina 27609
919.791.4200 T I 919.571.4716 F
HC Composites LLC
January 28, 2022
Page 2
As indicated in the "subject" above, this letter represents not only a Notice of Violation for the violation
addressed in this letter but also puts HC Composites LLC on notice that an enforcement report is being prepared
by this office addressing this violation. Please submit a written response to this office explaining any actions
taken to bring about compliance and any additional information or description of any mitigating circumstances
that you believe should affect the outcome of the enforcement evaluation.
Please submit a written response to this Notice of Violation/Notice of Recommendation for
Enforcement (NOV/NRE) by February 25, 2022. After this date, in lieu of any mitigating circumstances
brought to our attention, this office will submit an enforcement report to the Director of the Division of Air
Quality and make recommendations for the assessment of appropriate civil penalties.
This is the fifth occurrence of late or incomplete reporting which this office has documented against the
subject facility in the last five years. Your facility was issued an NOV dated July 16, 2018 for failing to submit
on time your calendar year 2017 Title V Emissions Inventory. An NOV dated February 19, 20 I 9 was issued for
failing to submit on time your second half 2018 semiannual report for 2D .0958 Work Practices for Sources of
VOCs. An NOV/NRE dated July 15,2019 was issued for failing to submit on time your calendar year 2018
Title V Emissions Inventory. And most recently, your facility was issued an NOV/NRE on June 25, 2021 for
failing to submit on time the calendar year 2020 Title V Annual Compliance Certification. It is imperative that
you take whatever steps necessary to ensure that, in the future, accurate and complete reports are submitted in a
timely manner as outlined in your air quality permit. As an additional reminder, this NOV/NRE is required
to be referenced in your facility's 2021 calendar year ACC report, in accordance with Section 3, General
Condition P of your Title V permit. Your 2021 ACC is due by March 1, 2022.
Your cooperation and concern for the environment are appreciated. If you have any questions concerning
this matter, please call Mary Rose Fontana Lee, Environmental Engineer, or Will Wike, Compliance
Supervisor, at (9 I 9) 791-4200.
cc: RRO Files
RRO Enforcement Files
Sincerely,
=ra;fot-~
Taylor Hartsfield, EIT, CPM
Raleigh Regional Supervisor
Division of Air Quality, NC DEQ