AQ_F_1900135_20210923_CMPL_NOV (4)

ROY COOPER =_
Governor
ELIZABETH S.BISER
Secretary
MICHAEL ABRACZINSKAS NORTH CAROLINA
Director Environmental Quality
September 23, 2021
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Bobby Branch, Owner
C & D Materials Recovery Facility - Goldston
2111 South Main Street
Goldston,North Carolina 27252
SUBJECT: Notice of Violation—NSPS Subpart EEEE Testing and Reporting Requirements
Pinnacle Waste, LLC dba C & D Materials Recovery Facility - Goldston
Goldston, Chatham County,North Carolina
Air Permit No. 10656G00
Facility ID No. 1900135
Fee Class: Title V (General)
Dear Mr. Branch:
During an air quality compliance inspection on September 15, 2021, it was discovered that your
facility had not submitted a notification of intent to construct or a planned initial startup date for
your air curtain incinerator located at your facility in Goldston,North Carolina. An EPA Method 9
test had also not been completed for the air curtain incinerator. C & D Materials Recovery Facility—
Goldston is required by Air Permit No. 10656G00 to submit the aforementioned information prior to
commencing construction of your air curtain incinerator, and to perform an initial and ongoing
annual EPA Method 9 tests. The intent of this letter is to remind you of the specific reporting
requirements outlined in your air permit. Section 2.1 A.2.g.i of your air quality permit reads as
follows:
i. Prior to commencing construction on your air curtain incinerator, submit the three items
described in subparagraphs (i)(1) through (3) below.
(1) Notification of intent to construct the air curtain incinerator.
(2) Planned initial startup date.
(3) Types of materials you plan to burn in your air curtain incinerator.
Additionally, Section 2.1 A.2.d of your air quality permit reads as follows:
d. Within 60 days after your air curtain incinerator reaches the charge rate at which it will
operate, but no later than 180 days after its initial startup, the Permittee shall conduct the
following performance tests:
i. Use Method 9 of Appendix A of 40 CFR Part 60 and in accordance with General
Condition JJto determine compliance with the opacity limitations.
ii. Conduct an initial test for opacity as specified in 40 CFR 60.8.
D E
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� North Carolina Department of Environmental Quality I Division of Air Quality
Raleigh Regional Office 1 3800 Barrett Drive I Raleigh,North Carolina 27609
NOFTiH GPROLINA
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919.791.4200 T 1919.881.2261 F

C & D Materials Recovery Facility - Goldston
September 23, 2021
Page 2
During the September 15, 2021 inspection, the air curtain incinerator was not in operation and with
no intent to restart it any time soon. Although the initial test for opacity is past due, we are not requiring
you to restart the air curtain incinerator just to perform the initial test for opacity. However, if the air
curtain incinerator is restarted, then the initial test for opacity is expected to be performed at the restart.
After the restart, results of the initial test for opacity are required to be submitted to DAQ within 30 days
of the restart date. Also note that a notification of intent to test must be provided at least 10 days prior to
allow a Division of Air Quality staff to plan to observe the initial test for opacity.
This letter represents a Notice of Violation for failure to provide initial notifications and to
perform an initial test for opacity as required by your current air permit. This violation and any future
violation(s) of air quality regulations are subject to the assessment of civil penalties as per North
Carolina General Statute 143-215.114A.
By October 15, 2021,please submit the following to this office:
• The construction date and initial startup date of the air curtain incinerator and the types
of materials you have burned and plan to burn.
• Whether the facility intends to continue to operate the unit (and conduct a planned EPA
Method 9 test upon restarting of the unit) or an air permit rescission request following
the removal of the air curtain incinerator from your facility.
• A written response describing actions taken by your company to ensure future
compliance with your air permit testing and reporting requirements.
This office also recommends that you or a designated company representative review your air
permit to ensure that you understand all the specific and general permit conditions. Please note the
monitoring, record keeping, and reporting requirements, and make the necessary provisions to ensure
that these requirements are met within the specified time frames.
As an additional reminder, this Notice of Violation is required to be referenced in your
facility's Annual Compliance Certification (ACC),in accordance with General Condition 3.P of
your Title V permit. Your 2021 ACC is due by March 1, 2022.
Your cooperation is this matter is appreciated. If you have any questions,please do not hesitate to
call Sindy Huang, Environmental Engineer, or Will Wike, Compliance Supervisor, at(919) 791-4200.
Sincerely,
--J 74q—b"
Taylor Hartsfield, EIT, CPM
Raleigh Regional Supervisor
Division of Air Quality,NC DEQ
cc: RRO Files
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Nprth Carolina Department of Environmental Quality I Division of Air Quality
Raleigh Regional Office 1 3800 Barrett Drive I Raleigh,North Carolina 27609
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919.791.4200 T 1919.881.2261 F