AQ_F_1900039_20210416_CMPL_NOV

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ROY COOPERI ;:
Governor
DIONNE DELLFGATT[
Serretory
MICHAEL ABRACZINSKAS NORTH CAROLINA
Director Environmental Quality
April 16,2021
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Thomas Reams, EHS Coordinator
Southern Veneer Specialty Products, LLC—Moncure
306 Corinth Road
Moncure,NC 27559
SUBJECT: Notice of Violation—Title V Monitoring Requirements
Southern Veneer Specialty Products, LLC—Moncure
Moncure, Chatham County,North Carolina
Air Permit No. 03424T29
Facility ID No. 1900039
Fee Class: Title V
Dear Mr. Reams:
On December 19,2020, Matthew Mahler of the North Carolina Division of Air Quality (DAQ)
conducted a compliance inspection of the subject facility. During that inspection, Mr. Mahler
discovered two violations of the Title V monitoring requirements referenced in your facility's Air Permit
No. 03424T29. The two violations discovered are described below:
1. During the December 19, 2020 onsite inspection, an hour meter reading of 2.1 hours for the
diesel-fired fire pump emergency engine(ID No. IES-23)was observed. However, during
the prior air quality inspection on June 24, 2019,the hour meter was observed with a
reading of 1,112.3 hours. In a phone call on March 9, 2021, you indicated that a Southern
Veneer employee had reset the electronic hour meter on emergency fire pump engine(IES-
23) in December 2020 prior to repairs by a third-party company. Furthermore, you stated
that the engine is not equipped with a non-resettable hour meter. Failure to monitor engine
hours with a non-resettable hour meter represents a violation of the federal rule, 40 CFR 60
Subpart IIII-Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines. An excerpt of this federal rule reads as follows:
D_EQ� North Carolina Department of Environmental Quality I Division of Air Quality
Raleigh Regional Office 1 3800 Barrett Drive I Raleigh.North Carolina 27609
U".n WenWmo hloumip 919.791.4200T 1 919.881.2261F

Southern Veneer Specialty Products, LLC—Moncure
A ril 16 2021
Page 2
§60.4209 What are the monitoring requirements if I am an owner or operator of a
stationary CI internal combustion engine?
If you are an owner or operator,you must meet the monitoring requirements of
this section. In addition,you must also meet the monitoring requirements
specified in§60.4211.
(a) If you are an owner or operator of an emergency stationary CI internal
combustion engine that does not meet the standards applicable to non-
emergency engines,you must install a non-resettable hour meter prior to
startup of the engine.
2. The facility's diesel-fired fire pump emergency engine(ID No. IES-23) is also subject to
the requirements of the federal rule, 40 CFR 63 Subpart ZZZZ—National Emissions
Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion
Engines (RICE). IES-23 is classified as a new stationary RICE engine since it is located at
an area source of hazardous air pollutants (HAPs)and was manufactured after 2006. As a
new RICE engine, the compliance status of this engine with 40 CFR 63 Subpart ZZZZ is
determined by the compliance with the requirements of 40 CFR 60, Subpart IIII. Thus, the
facility is in violation of 40 CFR 63 Subpart ZZZZ due to the monitoring violation of 40
CFR 60, Subpart IIII,as described above. An excerpt of the Subpart ZZZZ federal rule
reads as follows:
§63.6590 What parts of my plant does this subpart cover?
This subpart applies to each affected source.
(c) Stationary RICE subject to Regulations under 40 CFR Part 60. An affected
source that meets any of the criteria in paragraphs (c)(1) through (7) of this
section must meet the requirements of this part by meeting the requirements
of 40 CFR part 60 subpart IIII,for compression ignition engines or 40 CFR
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apply for such engines under this part.
(1)A new or reconstructed stationary RICE located at an area source;
This letter represents a Notice of Violation(NOV) for failure to monitor engine hours of the
diesel-fired fire pump emergency engine (ID No. IES-23) using a non-resettable hour meter as required
by both 40 CFR 60 Subpart IIII and 40 CFR 63 Subpart ZZZZ. These violations 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.
North Carolina Department of Environmental Quality I Division of Air Qualify
E � Raleigh Regional Office 1 3800 Barrett Drive J Raleigh.North Carolina 27609
JWartrtivntpl LnrtNnmCntllml� /`� 919.791.4200 T 1919,881.2261F

r Southern Veneer Specialty Products, LLC—Moncure
April 16, 2021
Page 3
This is the third occurrence of monitoring requirement violations that this office has documented
against the subject facility within the last five years. The facility received a Notice of Violation (NOV)
dated July 15, 2019 for General Condition 3.13,NSPS Subpart Dc recordkeeping, CAM monitoring and
recordkeeping,and major source HAP avoidance monitoring and recordkeeping as was required in your
facility's prior Air Permit No. 03424T28. Prior to that, a NOV dated November 20,2018 was issued for
exceeding the allowable 50 hours for non-emergency use in 2018 for IES-23 and CAM monitoring and
reporting. Lastly, a Notice of Deficiency (NOD)dated May 31, 2018 was issued for exceeding the
allowable 50 hours for non-emergency use in 2017 for IES-23.
Please submit a written response to this office by May 7,2021,as to actions taken or planned
to address this issue. Additionally,this office recommends that you or a designated company
representative review your air permit to ensure that you understand all of the specific and general permit
conditions. Please note the required monitoring, recordkeeping, 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 Matthew Mahler,Environmental Engineer, or Will Wike, Compliance Supervisor, at
[phone].
Sincerely,
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Taylor Hartsfield, EIT, CPM
Raleigh Regional Supervisor
Division of Air Quality,NC DEQ
cc: RRO Files
D 4 North Carolina Department of Environmental Quality it Divisionof Air Quality
Raleigh Regional Office ; 3800 Barrett Drive Raleigh.North Carolina 2760e
o n m m 6,­11.1.11 Q : 919791A300"r i 919.881.226i r

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