AQ_F_1900039_20190715_CMPL_NOV (4)

ROY COOPER N� INSTATF<< �
Governor
MICHAEL S.REGAN
Secretary C
MICHAEL ABRACZINSKAS
NORI1-i(':AROL.INA
Environmental Quality
July 15, 2019
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Ora Kendall Adams,Managing Member
Southern Veneer Specialty Products, LLC—Moncure
PO BOX 279
Fitzgerald, GA 31750
SUBJECT: Notice of Violation—Title V Monitoring and Recordkeeping Requirements
General Condition 3.B Requirements
Southern Veneer Specialty Products, LLC—Moncure
Moncure, Chatham County,North Carolina
Air Permit No. 03424T28
Facility ID No. 1900039
Fee Class: Title V
Dear Mrs. Adams:
On June 24, 2019, 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 several violations of the Title V permit monitoring, recordkeeping, and permit availability
requirements detailed in your facility's current air permit no. 03424T28. The violations discovered are
described below:
1. The facility did not retain and have available a copy of the current air permit. On page 23
of your air permit, General Condition 3.B Permit Availability requires that the facility shall
have available at the facility a copy of this permit...
2. A review of the facility's permit recordkeeping revealed that the facility was not recording
and maintaining records of the monthly amounts of wood fuel fired in the wood boiler(ES
ID. No. ES01-B) from March 2019 through May 2019. Each of these three missing records
represents a distinct violation of Air Permit No. 03424T28 Stipulation 2.LAA(b) (pursuant
to 15A NCAC 2D .0524 NSPS 40 CFR Part 60 Subpart Dc). This stipulation reads as
follows:
Recordkeeping[15,4 NCAC 02Q.05080]
b. In addition to any other recordkeeping required by 40 CFR 60.48c or
recordkeeping requirements of the EPA, the Permittee shall record and maintain
records of the amounts of wood filel fired in the source (ID Nos. ES01-B) during
each month. All records shall be maintained by the Permittee for a period of two
—Lr North Carolina Department rat'&rrvir'onmentai Q-uality Division of Air Quality
Raleigh Regional Office ( 3800 Barrett Drive Raleigh.North Carolina 2760()
90.791.4700 T 911d.ri8t.1.261 F

Ora Kendall Adams
July 15, 2019
Page 2
years following the date of such record. The Permittee shall be deemed in
noncompliance with 15A NCAC 02D .0524 if these records are not maintained.
3. On April 30, 2019 and May 6, 2019, your facility did not monitor or record the differential
pressure drop across the multicyclone (control device ID. No. CD02), which controlled the
fluidized bed wood burner(ES ID No. ES01-A) operating on those two days. Each of
these two missed monitoring events and two missing records represents a distinct violation
of Stipulations 2.1.A.5(c) and(d), respectively(pursuant to 15A NCAC 2D .0614
Compliance Assurance Monitoring). Excerpts of these stipulations read as follows:
c. Monitoring Approach [I5A NCAC 02Q.050869]
When the emission source is in operation, the differential pressure across the
multicyclone will be monitored via a differential pressure gauge.
d. Recordkeeping[15A NCAC 02Q.050869]
The owner or operator shall maintain records of the following:
i. Date and time of all monitoring activities;
ii. The results of the differential pressure drop monitoring, noting any excursions
along with corrective actions taken;
4. The facility's permit recordkeeping revealed that the facility was not monitoring and
recording the monthly hazardous air pollutants (HAPs) emissions from March 2019
through May 2019. Each of these three missed monitoring events and three missing
records represents a distinct violation of Stipulation 2.2.A.1(b) (pursuant to 15A NCAC
02Q .0317 for avoidance of 15A NCAC 02D .1111 Limitation To Avoid Being Major For
Hazardous Air Pollutants). An excerpt of this stipulation reads as follows:
c. Monitoring/Recordkeeping[15A NCAC 02Q.0508(f)]
The Permittee shall maintain monthly KAPs emissions records as follows:
The Permittee shall calculate the methanol emissions, using the equations
below, on a monthly basis, to ensure compliance with condition 2.2 A. 1. a.,
above.
Facility Wide methanol emissions (tons/month) _ [Eq. 1 + Eq. 2 +Eq. 3]
Equation 1, 2, and 3 calculate monthly methanol emissions from the
dryersiboilers, presses, and vat operations, respectively.
This letter represents a Notice of Violation(NOV) for failure to have a copy of your air permit
available upon request; for failure to record the monthly amounts of wood fuel fired in the wood boiler
for three months; for failure to monitor and record the differential pressure drop across the multicyclone
on two days of operation; and for failure to monitor and record the monthly HAPs emissions for three
-7,� North Carolina Department of F.rrvironmental Quality i Division of A4 Quality
E ri✓ Raleigh Regional 011ke 1 3800 Barrett Drive I Raleigh.North Carolina 27W)
onN;�nmenlclmvuumnn�a;dmrna° ! 914.791.4200T1919.881.2261F

Ora Kendall Adams
July 15, 2019
Page 3
months. The lack of permit retention and the failure to monitor and record operational and emissions
data were all requirements of your current permit, which were not met. 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.
Please submit a written response to this office by August 2, 2019, 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 added note, General Condition 3.0 Retention of Records on page 26 of your air permit requires all
plant records to be maintained in a form that is suitable and in an area that is readily available for
expeditious inspection and review.
As an additional reminder, this Notice of Violation is required to be referenced in your
facility's annual compliance certification (ACC),in accordance with Section 3, General Condition
P of your Title V permit. Your 2019 ACC is due by March 1, 2020.
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,
r
T. iay kSteAJr., P.E.,qCP
Raleigh Regional Supervisor
Division of Air Quality, NC DEQ
cc: RRO Files
North Carolina Department of Envir'onmentaI Quality j Division of Air Quality
J� Raleigh Regional Office- 1 3800 Barrett Drive Raleigh.North Carelina 27b01)
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