AQ_F_0400039_20211018_CMPL_NOV

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ROY COOPER
Governor
DIONNE DELLFGATTI j6
Secretary
MICHAEL ABRACZINSKAS NORTH CAROLINA
Director Environmental Quality
18 October 2021
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Ms. Sharon Clark
Senior Vice President Regulatory Affairs & Compliance
Perdue AgriBusiness - Ansonville
PO Box 1537
Salisbury, MD 21802
Subject: Notice of Violation— 15A NCAC 02Q .0711 "Emission Rates Requiring A Permit"
Perdue AgriBusiness -Ansonville Air Permit 07495R09
Ansonville,NC, Anson County Facility ID No. 06/04-00039
Fee Category: Small
Dear Ms. Clark:
On 5 October 2021, Gregory Reeves of the Division of Air Quality(DAQ) Fayetteville
Regional Office (FRO)received a phone call from Joey Baggett, Perdue AgriBusiness Regional
Environmental Manager, inquiring about whether an air permit was required for treatment of
feed mixes with Termin-8`t liquid antimicrobial preservative. Mr. Baggett indicated that the
Termin-88 product contains Formaldehyde and that some of this material evaporates during the
mixing process and is emitted to the atmosphere. On 7 October 2021, Mr. Baggett provided Mr.
Reeves with annual process throughputs for the feed mixes using Termin-80, addition rates of
Termin-8`t, retention rates of Termin-8' in the finished feed mix, and hourly process rates for the
feed mixing operation. Calculations based on this data indicate an emission to the atmosphere of
2.3 8 pounds per hour of Formaldehyde at the production rates specified. The supplied
throughput data also indicated that the Termin-80 addition has been occurring since 2007.
15A NCAC 02Q .0711(b) "Emission Rates Requiring a Permit"requires, in part,that
"...A permit to emit toxic air pollutants shall be required for any facility if all emission release
points are unobstructed and vertically oriented whose actual rate of emissions from all
sources isgreater than any one of the following toxic air pollutant permitting emissions
rates:...-"and further specifies that the toxic air pollutant permitting emissions rate for
Formaldehyde is 0.16 pounds per hour. The calculated emission rate of 2.3 8 pounds per hour of
Formaldehyde from the Termin-80 mixing process exceeds this permitting emission rate. This
constitutes a violation of 15A NCAC 020 .0711, as no permit was obtained prior to exceedance
of the specified maximum emission rate.
.a...--. Z North Carolina Department of Environmental Quality I Division of Air Quality
D,.EQ C,Aj
Fayetteville Regional Office I 225 Green Street,Suite 714 ( Fayetteville,North Carolina 28301
NUH't'HCAfdULJNA
Department of Environmontat Quality 910.433.3300 T 1910.485.7467 F

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Notice of Violation
Perdue AgriBusiness- Ansonville
Page 2 of 2
The above violation and any future violation of an air quality regulation are subject to the
assessment of civil penalties per North Carolina General Statute 143-215.114A. In addition,
each day of continuing violation after written notification from the Division of Air Quality shall
be considered a separate offense.
Please submit a permit application for emissions of Formaldehyde, including a
dispersion modeling demonstration for Formaldehyde emissions, no later than 8 November
2021.
We appreciate your immediate attention to this environmental concern. If you have any
questions about this violation or the required permit application,please contact Gregory Reeves,
Environmental Engineer, or Jeffrey Cole, Acting Permits Coordinator, at(910) 433-3300.
Sincerely,
Heather S. Carter
Regional Supervisor
Division of Air Quality,NCDEQ
HSC/gwr
cc: FRO Facility Files
Mr. Joey Baggett,Perdue AgriBusiness,242 Perdue Road,Cofield,NC 27922