AQ_F_1900015_20190605_CMPL_NOV-NRE (4)

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ROY COOPER
Governor
MICHAEL S.REGAN isrs
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Secretor, I C
MICHAEL ABRACZINSKAS
Director
NORTH C:AROUNA
Environmental Quality
June 5,2019
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr.Jeff McMillian,Plant Manager
Arauco North America,Inc.
985 Corinth Road
Moncure,NC 27559
SUBJECT: Notice of Violation/Notice of Recommendation for Enforcement
15A NCAC 2D.1111 MACT Subpart DDDD Operating Requirements
15A NCAC 2D .0530 Prevention of Significant Deterioration Emission
Limitation Requirements
General Condition 3.F Requirements
Arauco North America,Inc.
Moncure, Chatham County,North Carolina
Current Air Permit No. 03449T51
Facility ID Number: 1900015; Fee Class: Title V
Dear Mr.McMillian:
Air Permit No. 03449T51 was issued to Arauco North America, Inc. in Moncure,North Carolina on March
6,2019,for the operation of a medium density fiberboard(MDF)plant and particle board manufacturing plant.
The MDF plant uses a biofilter(Control Device ID No. CD18)to control total volatile organic compound(VOC)
and hazardous air pollutant(HAP) emissions from the two stage dryer system with backup natural gas burners
(ES-02-B, ES-02-C-1,ES-02-C-2, and ES-02-D), the MDF board cooler(ES-06-B), and the MDF press and press
hall(ES-16). On May 8,2019,Arauco personnel notified the Division of Air Quality(DAQ)by email that the
biofilter had been shut down indefinitely that morning"due to concerns around employee safety, catastrophic
equipment failure, and control device downtime". The facility followed-up with a letter dated May 9,2019,
addressed to the DAQ Raleigh Regional Office,which further detailed the concerns surrounding the shutdown.
From a prior conversation with facility staff, our office understood that the shutdown of the biofilter would occur
without simultaneously ceasing the operation of the emission sources whose emissions it was designed and
permitted to control.
Due to these actions,your facility is in violation of two federal air quality regulations and one permit
condition in Air Permit No.03449T51. First,with the issuance of a prior air quality permit(No. 03449T45),your
facility had selected the operation of the biofilter as the MDF plant's Best Available Control Technology (BACT)
for the emission sources referenced above. Through operating the emission sources referenced above without the
concurrent operation of the biofilter,your facility is in violation of 15A NCAC 2D .0530 Prevention of Significant
Deterioration (PSD), as referenced by Specific Condition 2.2.B.2 of Air Permit No. 03449T51. Section 2.2.B.2
of the permit summarizes the BACT permit limitations of the MDF plant pursuant to 15A NCAC 2D .0530
Prevention of Significant Deterioration. More specifically,that rule requires that the emission sources referenced
above be controlled by the biofilter in order to meet the minimum permit-required 50%destruction removal
efficiency(DRE)of Wood Products Protocol 1 (WPPI)VOC.
North Carolina Department of Environmental Qua lit v Division of Air Quality
Raleigh Regional Office ( 380o Barrett Drivc:i Raleigh.North Carolina 27601)
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Mr.Jeff McMillian
June 5, 2019
Page 2
Second, your facility had selected the operation of the biofilter as the Maximum Achievable Control
Technology(MACT)capable of controlling HAP emissions from the refiner(ES-01), energy system consisting of
a dry/wet wood/woodwaste-fired burner(ES-02-A),two stage dryer system(ES-02-B),two backup natural gas-
fired dryer burners (ES-02-C, and ES-02-1)), and the MDF press and press hall(ES-16). By operating the
emission sources referenced above without the concurrent operation of the biofilter,your facility is in violation of
15A NCAC 2D .1111:Maximum Achievable Control Technology as referenced by Specific Condition 2.2.A.1 of
Air Permit No. 03449T51. Section 2.2.A.1 of the permit summarizes the facility-wide MACT permit limitations
and standards pursuant to 15A NCAC 2D .1111:Maximum Achievable Control Technology. More specifically,
that rule requires that the MDF plant emission sources referenced above be controlled by the biofilter in order to
meet one of six permit-required HAP emission control options. Your facility had selected to reduce formaldehyde
emissions by 90%as your facility's method of demonstrating compliance with the Subpart DDDD MACT
regulation as referenced by permit Stipulation 2.2.A.1(g)(v).
Lastly,General Condition 3.17 Circumvention on page 58 of Air Permit No. 03449T51 states that unless
otherwise specified by this permit,no emission source may be operated without the concurrent operation of its
associated air pollution control device(s) and appurtenances.
Therefore,this Notice of Violation/Notice of Recommendation for Enforcement(NOV/NRE)is issued to
the subject facility for failure to demonstrate compliance with the Subpart DDDD emission limit requirements,
PSD BACT emission limit requirements, and General Condition 3.17 requirements. This violation and any future
violations of air quality regulations are subject to the assessment of civil penalties as per the authority of North
Carolina General Statute 143-215.114A.
As indicated in the"subject" above,this letter represents not only a Notice of Violation for the three
violations referenced above,but also puts Arauco North America,Inc. on notice that an enforcement report is
being prepared by this office addressing the violations. Please submit a written response to this office by June
28,2019,describing any actions taken or planned 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. After this date,in lieu of any mitigating circumstances brought to our attention,
this office will submit the enforcement report to the Director of the Division of Air Quality and make
recommendations for the assessment of appropriate civil penalties.
If you have any questions related to this matter,please do not hesitate to contact Matthew Mahler,
F.
,nvixonnmital Engineer, ar Will > Complianee Supervisor,
Sincerely
T.Yay Ste , Jr.,P.E., C
Raleigh Regional Supervisor
Division of Air Quality,NC DEQ
cc: RRO Files
�� North Carolina Department of F..nvironmental Quality I Division of Air Quality
DBE� ' Raleigh Regional Office 13800 Barrett Drive 1 Raleigh.North Carolina 27609
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