AQ_F_0800107_20161122_CMPL_NOV-NRE

PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary
Air Quality SHEILA C. HOLMAN
ENVIRONMENTAL QUALITY Director
November 22, 2016 CERTIFIED MAIL 7016 0340 0000 9267 7413
RETURN RECEIPT REQUESTED
Mr. Garald Cottrell, President
W. E. Partners II, LLC
312 South Front Street, Suite 6
New Bern,North Carolina 28562
SUBJECT: Notice of Violation/Notice of Recommendation of Enforcement
40CFR Part 63, Subpart JJJJJJ, Section 63.11201(c) and Table 3
Electrostatic Precipitator Secondary Power Thirty-Day Rolling Averages
W.E. Partners II,LLC
Lewiston, Bertie County,North Carolina
Air Permit No. 10126R02
Facility ID: 0800107, Fee Category: Synthetic Minor
Dear Mr. Cottrell:
W.E. Partners II, LLC is required under 40 CFR Part 63, Subpart JJJJJJ to maintain the
thirty-day rolling average total secondary electric power at or above the minimum measured
during the most recent performance test(40 CFR 63.11211, 63.11201(c) and Table 3). The
minimum was established as 3.4 kW during the May 10, 2012 stack test. On September 29,
2016 Ms. Betsy Huddleston performed a full compliance evaluation at the facility. During the
inspection she reviewed the twelve-hour block average ESP secondary power data recorded on
the daily operator logs from January 1, 2016 through September 28, 2016. The twelve-hour
block averages are recorded as an indicator of compliance. She observed a significant number of
logs with block averages below 3.4 kW, and requested the hourly average and thirty-day rolling
average secondary power data for the same time period(minus data associated with startup,
shutdown and malfunction), which you provided on November 14, 2016.
Per Ms. Huddleston's review of the hourly and thirty-day rolling average data you
provided, the ESP secondary power thirty-day rolling average was below the 3.4 kW minimum
during fifty-three operating days. Failure of the ESP secondary power thirty-day rolling
averages to meet the 3.4 kW minimum is a violation of 40CFR 63.11201(c) and Table 3 of
Subpart JJJJJJ. Each violation can result in possible civil penalties as per North Carolina
General Statute 143-215.114A.
This office intends to submit a recommendation for enforcement action to the Director of
the Division of Air Quality. If you believe there are additional factors that should be considered,
please send the information to the Washington Regional Office within two weeks of receipt of
this letter. Your documentation will be forwarded with the enforcement package to the Director.
State of North Carolina I Environmental Quality I Air Quality
Washington Regional Office 1 943 Washington Square Mall I Washington,NC 27889
252 946 6481 T 1 252 975 3716 F

Mr. Garald Cottrell
November 22, 2016
Page 2
Please remember to report these violations in your Annual Compliance Report for 2016,
which is required by 40CFR 63.11225(b), and due March 1, 2017. If you have any questions or
concerns,please contact Ms. Betsy Huddleston at(252) 948-3836 or
[e-mail].
Sincerely,
Robert P. Fisher, Regional Supervisor
Division of Air Quality,NCDEQ
RPF/eth
cc: Washington Regional Office Files
(G:\AQ\Shared\Bertie08\00107\Comphance\20161122NRE.doc)