AQ_F_0200098_20190613_ENF_RemissLet

TPIEDMONT
COMPOSITES & TOOLING
May 1,2019
Enforcement Group-Remission
Department of Environmental Quality
Division of Air Quality
1641 Mail Service Center
Raleigh, North Carolina 27699-1641
Subject: Response to Civil Penalty Assessment for Violation(s)
2D.1111 Maximum Achievable Control Technology
File No.:DAQ 2019-006
Piedmont Composites and Tooling,LLC(PCT)
Taylorsville,North Carolina
Alexander County
Air Permit Number 09941T03
Dear Mr. Michael A.Abraczinskas:
This letter is in response to your letter dated April 5, 2019, regarding the civil penalty assessed from the
compliance inspection performed on December 51h,2018. PCT respectfully requests that the determination of Non-
Compliance be reviewed in light of the information presented in this letter.
We readily admit that as new management with no prior experience in any NCDEQ-monitored industry, PCT has
needed time to become familiar with not only the Title V requirements but with the vocabulary used.We believe
that our inexperience led to some confusion during Ms. Barksdale's visit. The prior owner had handled all the
Emissions Safety compliance and the transition in ownership(including communication of compliance procedures)
was not as smooth as all parties would have preferred.
Since receipt of the Civil Penalty notification on April 5, 2019, 1 have spoken with Ms. Thaochi Vu (April 24) and
then Mr. Bruce Ingle and Mr.Joe Foutz(April 25).All three were exceedingly helpful. Mr. Ingle pointed out during
our call that NCDEQ's primary concern was that the data appeared not to be on site during Ms. Barkdale's visit.
However, we believe that this miscommunication was due to our inexperience as PCT actually did have all of the
data used in the calculations; the only piece we did not have at the time of her visit was completed calculations
from Value Environmental,our outside consultant.
I believe it is also important to note that PCT was well under emissions limits during the time in question. Even
despite our inexperience at the time, intuitively we knew that our material usage had not increased and therefore
our Title V permit limitations were not being exceeded. We continued to collect data on a daily and weekly basis
throughout the period in question and only neglected to send out the data to our vendor to complete calculations.
I would like to affirm that this entire incident was accidental, and we have implemented new procedures. PCT has
set automatic alarms to notify several people at PCT on the first of each month to complete HAP usages. It will
notify the designated person in charge of HAP usage, office manager, plant manager, the Vice President of PCT,
and myself. Our consultant will also send us reminders for redundancy. We have also requested that suppliers
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provide necessary documentation more quickly so that we minimize the time between material usage and final
calculations.
For ease of reference we have included a summary of the issues in question,a timeline of events(Appendix 1)and
factual disputes relating to the Civil Penalty notification (Appendix 2). Documentation supporting PCT's claims are
accompanied with this letter and any additional required information will of course be made available upon
request.
We understand the importance of compliance with all conditions of our Air Permit and respectfully request
remission and that the assessment be removed or significantly reduced. Please feel free to contact me at (828)
632-8883 if you have any questions. Thank you for your time and consideration.
Sincerely,
David Himebaugh
President
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Executive Summary
Below is a chart outlining the specific compliance work undertaken by PCT during the period in question.There is
further discussion and explanation in Appendix 2.
2.1.A.2 sections c,d,and a(one laminating/gel coat operation and one resin storage tank)
July August September October November
2.1.A.2.d
Invoices received from Yes,but Yes,but Yes, but Yes,but
vendors and copied into Yes accidentally accidentally accidentally accidentally
logbook to be used for not made not made not made not made
calculations available available available available
2.1.A.2.c(first step)
Logbook sent to Value August 7 December 3 December 3 December 3 December 11
Environmental for calculations
2.1.A.2.c(second step)
Calculations received from September
Value Environmental and 21 December 10 December 10 December 10 December 12
added to logbook
2.1.A.2.e Included on Included on Included on Included on Included on
Bi-yearly reporting Jul-Dec Jul-Dec Jul-Dec Jul-Dec Jul-Dec
report report report report report
2.1.B.3 sections b,c,and d(dry filter-type surface coating operation)
July August September October November
2.1.B.3.b
Monthly records of usage Yes,but Yes,but Yes,but Yes,but
accidentally accidentally accidentally accidentally
(gallons)maintained in Yes logbook not made not made not made not made
available available available available
2.1.B.3.c
Five years of on-site records Yes Yes Yes Yes Yes
2.1.B.3.d Included on Included on Included on Included on included on
Bi-yearly reporting Jul-Dec Jul-Dec Jul-Dec Jul-Dec Jul-Dec
report report report report report
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Our understanding is that the Civil Penalty notification cited PCT for violations color-coded above:
1. 2.1.A.2.d-A lack of Emissions Usage Data as recorded in the logbook(green)
2. 2.1.B.3.b—A lack of Emissions Usage Data as recorded in the logbook(red)
3. 2.1.A.2.c—A lack of monthly Emissions Usage Calculations on hand at the time of Ms. Barksdale's visit
(yellow and blue)
2.1.A.2.d and 2.1.B.3.b
We mistakenly communicated to Ms. Barksdale that we did not have the Emissions Usage Data(green and red).
This information was actually in a separate binder at our Accounts Payable desk in our shipping office,where
applicable vendor invoices were added on a daily or weekly basis to track usage. Due to recent staffing changes,
the employee who spoke with Ms. Barksdale was not aware of this additional information and did not show it to
Ms. Barksdale during her visit.
Other than this miscommunication,we believe that PCT was in full compliance to 2.1.A.2.d and 2.1.B.3.b as the
part of the logbook containing vendor invoices tracking usage was complete and current and organized by month
but acknowledge that we failed to demonstrate to Ms. Barksdale how we had logged the data.
2.1.A.2.c
We also failed to communicate that the only data that was NOT present on-site was the Emissions Usage
Calculations from Value Environmental(yellow and blue).Our mistake was due to the new management's
inexperience in documenting Title V compliance.We did make this part of the logbook available to Ms.Barksdale
but take responsibility for inadvertently miscommunicating to her where the"missing"data was at that time.In
conclusion,we believe the following three items are relevant to 2.1.A.2.c compliance:
1. The Usage Data had been sent out to be used for Calculations two days prior to her visit(Dec 3 vs Dec 5)
demonstrating that any negligence in compliance had been discovered and resolved prior to her visit
2. Only three months'worth of Calculations could be considered late,not four(yellow(late)vs.blue(not
late))
3. We cannot find any language in 2.1.A.2.c stipulating that these Calculations have to be completed
monthly or at any point other than the bi-yearly reports.We strongly believe that maintaining monthly
Calculations are best practice and have instituted procedures to ensure monthly compliance in the future,
but do not believe PCT violated the Title V permit.
In summary,we believe the PCT is responsible for not fully understanding the Title V permit,for not achieving
fluency in the language used to describe compliance,and for inadvertently miscommunicating to Ms. Barksdale
during her visit.We respectfully ask that the NCDEQ consider the challenges for new management to undertake
this compliance in addition to other environmental and safety regulations while maintaining the job security of our
fifty employees through good customer service practices and fiscally responsible manufacturing practices.
However,PCT does not believe it is culpable of violating any part of the Title V permit.Nonetheless we understand
how our inexperience led Ms. Barksdale to her conclusions and respectfully ask that the findings of fact be
reconsidered in light of the circumstances and compliance described in this letter.
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Appendix 1:Timeline of Events
July 2018 Emissions Usage Data compiled in the form of vendor invoices per 2.1.A.2.d.i. This
process,which has not changed since PCT took over operations, is ongoing and ad hoc
and the Logbook(2.1.A.2.d) is updated whenever an applicable vendor's invoice was
processed.The data was sent to Value Environmental during the first week of August
and calculations were received back by mid-September.
August 2018 Emissions Usage Data compiled.PCT did not send the data to Value Environmental for
calculations until Dec 3.Calculations received Dec 10.
September 2018 Emissions Usage Data compiled.PCT did not send the data to Value Environmental for
calculations until Dec 3.Calculations received Dec 10.
October 2018 Emissions Usage Data compiled.PCT did not send the data to Value Environmental for
calculations until Dec 3.Calculations received Dec 10.
November 2018 Emissions Usage Data compiled.The data was sent to Value Environmental during the
first week of December and calculations were received back by mid-December.
Monday,Dec 3,2018 PCT personnel discovered that Aug/Sept/Oct data had not been sent to Value
Environmental per PCT's usual procedure (first work day of the month, or when the
last applicable invoice is received) due to a change in staffing.This data was sent out
to complete Emissions Usage Calculations.
Wednesday,Dec 5,2018 Ms. Barksdale visited the plant. PCT employee Haley Millsaps provided the Emissions
Usage Data logbook in the form of a white binder containing monthly reports,
calculations and other information, but mistakenly communicated that we were
missing three months'worth of data (that was in a black binder in a different office).
We had every month's raw data located in the accounting department at the plant(for
both 2.1.A and 2.1.6), but did not have the final Emissions Usage Calculations for
Aug/Sept/Oct.
Monday,Dec 10,2018 Value Environmental completes Emissions Usage Calculations for Aug/Sept/Oct.These
are emailed to Ms. Barksdale.
Wednesday,Dec 12,2018 Value Environmental completes Emissions Usage Calculations for November. These
are emailed to Ms. Barksdale.
April 5,2019 PCT receives the Civil Penalty notification via US Mail.
April 24,2019 I contacted Ms. Thaochi Vu to discuss the matter. We spoke at length and informed
her of some items that she and/or others were probably not aware of that may have
affected the assessment levied. Ms.Vu suggested that I contact Mr.Bruce Ingle and to
describe the situation that we spoke about to him.
April 25,2019 I spoke with Mr. Ingle first thing in the morning on April 25, 2019 and conferenced
with him and Mr. Joe Foutz who was sitting in Mr. Ingle's office at that time. We
discussed the violation(s)including specific points listed in Appendix 2(these were also
discussed with Ms.Vu during our conversation.
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Appendix 2: Factual Disputes
(1) PCT can find no non-compliance with the Title V permit 2.1.A.2 sections c,d,and a(one laminating/gel coat
operation and one resin storage tank)other than miscommunication
This section is one of two cited by the NCDEQ Civil Penalty Assessment.It places the following requirements:
• 2.1.A.2.c—Calculating weighted average emission factor to ensure compliance with the permit limits
• 2.1.A.2.d—"The results of the monitoring shall be maintained in a logbook on-site and made available to
an authorized representative upon request."
• 2.1.A.2.e—Bi-yearly reporting
PCT's process for Title V compliance is as follows:
(a) PCT uses invoices from vendors to determine usage(as allowed in 2.1.A.2.d.i).When PCT receives invoices
from vendors that relate to HAP emissions,these are logged in our QuickBooks software and as a physical
copy in an emissions monitoring logbook in our accounting office (hereafter referred to as "Emissions
Usage Data").
(b) Periodically an Excel spreadsheet located on the company server is updated and emailed to our outside
consultant at Value Environmental,who uses the Emissions Usage Data to calculate a weighted emission
factor per the Title V permit(section 2c,part i).
(c) The calculations (hereafter referred to as "Emissions Usage Calculations") are stored on our company
server and Air Quality binder and are used by Value Environmental to generate the bi-yearly reports per
the Title V permit(section 2e).
(d) There are no specific reporting deadlines specified in the Title V Permit(section 2e)except for July 30 and
January 30 for completed calculations. PCT has successfully met these deadlines.
When Ms. Barksdale visited on December 5,we inadvertently failed to make Ms. Barksdale aware of the Emissions
Usage Data in our logbook,which covered the entirety of PCT's operation history including the months in question
(August, September, October, and November). PCT clearly had the Usage Data available, as it had been sent to
Value Environmental two days prior to Ms. Barksdale's visit. All of the information was on-site, but we failed to
demonstrate compliance due to miscommunication.
The Emissions Usage Data for July-November had been emailed to the consultant two days prior to Ms. Barkdale's
visit but we had not yet received their completed Emissions Usage Calculations.
The Civil Penalty notification states that HAP emissions must be calculated on a monthly basis. PCT cannot find
anywhere in section 2.1.A of the Title V permit stating that Emissions Usage Calculations must be completed on a
monthly basis. PCT has maintained full compliance with the reporting requirement (2.1.A.2.e) and made all
logbooks available to Ms. Barksdale(2.1.A.2.d).
We believe that confusion occurred when PCT employee Haley Millsaps(hired in September and, at the time, not
involved in Title V compliance) mistakenly informed Ms. Barksdale that PCT did not have data available. She was
not familiar with the Title V requirements and only had limited working knowledge of compliance processes. PCT
did actually have the Emissions Usage Data and was waiting on completed Emissions Usage Calculations.
PCT believes it is best practice to maintain monthly Emissions Usage Calculations and has instituted processes and
process controls to ensure our Emissions Usage Calculations are completed within 30 days of final tabulation of the
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Emissions Usage Data. However we do not believe our failure to do monthly Emissions Usage Calculations violates
any part of the Title V permit.
(2) PCT can find no non-compliance with the Title V permit 2.1.6.3 sections b, c, and d (dry filter-type surface
coating operation)other than miscommunication
This section is one of two cited by the NCDEQ Civil Penalty Assessment. It places the following requirements:
• 2.1.B.3.b—"The Permittee shall keep records of gallons of HAP coatings that are used to coat plastic parts
or products on a monthly basis to ensure compliance."
• 2.1.B.3.c—Five years of records on-site
• 2.1.B.3.d—Bi-yearly reporting
At PCT, the same vendors and materials are used for this process (2.1.13) as the above process (2.1.A) but the
monitoring requirements are different:(1)no calculations are required,just usages;(2)these records must be kept
monthly.
When Ms. Barksdale visited on December 5,we inadvertently failed to make Ms. Barksdale aware of the Emissions
Usage Data in our logbook,which covered the entirety of PCT's operation history including the months in question
(August, September, October, and November). All of the information was on-site, but we failed to demonstrate
compliance due to miscommunication.
(3) All Emissions Usage Calculations had been started prior to Ms.Barksdale's visit
The Civil Penalty notification states: "During [Ms. Barksdale's Dec. 5, 2018] inspection it was determined that HAP
emission limit calculations were not conducted for a four-month period from August 2018 through November
2018."
The Civil Penalty letter implies that PCT had forgotten about Title V compliance. This is not accurate. As stated
above, PCT maintained records of HAP emission usage throughout the period in question. Management continued
to receive invoices during the months in question from our consultant that calculates the emissions, therefore
believing PCT to be continuing proper procedures for compliance. We began the process of finalizing Emissions
Usage Calculations two days prior to Ms. Barksdale's visit. The calculations themselves were the only component
that was not present at the time of the visit.
(4) Violations were assessed for four months when the time period in question was three months
The Civil Penalty letter states that "During [Ms. Barksdale's Dec. 5, 2018] inspection it was determined that HAP
emission limit calculations were not conducted for a four-month period from August 2018 through November
2018."
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PCT believes that this period in question is incorrect. It would be virtually impossible for PCT to have completed
Emissions Usage Calculations for the previous month ready on the morning of the third work day of each month
(e.g. when Ms. Barksdale visited). Reasons for delay include(1) lag related to receiving invoices from vendors; (2)
work hours necessary to compile invoices into a report to be sent to PCT's consultant; (3) lag related to the
consultant's work.
We believe that it is for this reason that a 30-day period is allowed for the biyearly reports,and we would expect a
similar standard to be held for site visitations. Emissions Usage Data for November was available to Ms. Barksdale
during her visit,and Emissions Usage Calculations were emailed to her on December 12.
(5) Consideration for change of ownership re:past violations
The Title V permit in question was inherited from the permit originally given to Piedmont Fiberglass, Inc. (PFI). PFI
sold its assets to PCT on March 9, 2018. New ownership's first day at the facility was March 12, 2018. Ms.
Barksdale came to PCT on March 14, 2018. Violations occurred in January of 2018 under previous ownership.
While we inherited the Title V permit and all that goes with it, new management was unaware of any violations
until the March 2018 violations letter was received. Previous ownership agreed to handle the issue. While it does
not absolve us from the current issue,we would appreciate this being taken under consideration
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STATL OF NORTH CAROUNA NORTH CAROLINA
EINVIRONWNTALMANAGEMENT
COMMISSION
County of Alexander FILE NO.DAQ 201.9-006
II THE MA 7117ER OF ASSESSMF-NT REQUEST FOR RFMISSION OF CIVIL
OF CIVIL PENAUMS AGAINST PENALTIES;WAIVER OF RIGHT TO
Piedmont Composites and!Doling, LLB` AN ADMINISTRATIVE BEARING
AND STIPULA110N OF FACTS
Having been assesscd civil penalties totaling$4,542 for violation(s)of.
2D .1 I I I Maximum Achievable Control Technology
as set forth in the assessment document of the Director,Division of Air Quality dated April 5,
2019,the undersigned, desiring to seek remission of the civil penalties,does hereby waive right
to an administrative hearing in the al we-stated matter and does stipulate that the facts are as
alleged in the assessment document. The undersig.,ned further understands that all evidence
presented in support of remission of this civil penalty must be submitted to the Director of the
Division of Air Quality within thirty(30)days of receipt of the notice of assessment. No new
evidence in support of a remission request will be allowed after thirty(30) days from.the receipt
of the notice of assessment.
This the, C day of- 20/'�
Signature
By
Print Name
Address iv M F I
V?
Telephone