HomeMy WebLinkAboutAQ_F_1900039_20181120_CMPL_NOV (3) ` srA-Q,, uNAILEID
ROY COOPER e`
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Governor � i ,,,
MICHAEL S.REGAN o,
Secretory
MICHAEL ABRACZINSKAS y ^"'
Director
NORTH CAROLINA
Environmental Quality
November 20, 2018
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Glen Lang, Southeast Operations Manager
Boise Cascade Wood Products, LLC - Moncure
306 Corinth Road
Moncure,NC 27559
SUBJECT: Notice of Violation—New Source Performance Standards (NSPS) Subpart IIII
Operating Limitations and Title V Semiannual Reporting Requirements
Boise Cascade Wood Products, LLC -Moncure
Air Permit No. 03424T26,Moncure, Chatham County
Facility ID Number: 1900039; Fee Class: Title V
Dear Mr. Lang:
The North Carolina Division of Air Quality(NC DAQ) received a permit application from your
facility on January 30, 2018, to pen-nit a 250 hp diesel-fired fire pump emergency engine (ID No. IES-
23) as a non-emergency engine. The modification was requested since the fire pump engine was used to
respond to a 2017 fire event but had also inadvertently exceeded 50 hours of non-emergency use during
2017. Subsequently,NC DAQ issued a Notice of Deficiency(NOD)to your facility on May 31,2018
regarding this exceedance. In a June 28t11 email correspondence pertaining to the permit application, a
staff member of Boise Cascade stated that Boise Cascade Wood Products, LLC—Moncure had
exceeded the maximum allowable non-emergency hours for calendar year 2018 for your facility's fire
pump emergency engine. The allowable non-emergency hours are prescribed under New Source
Performance Standards(NSPS) Subpart IIII and Maximum Achievable Control Technology(MACT)
Subpart ZZZZ. The exceedance was also documented in your facility's NOD response letter dated July
5, 2018. According to records reviewed during a September 6, 2018 inspection, 226.8 hours of non-
emergency operation and 244.8 hours of combined non-emergency/maintenance checks/readiness
testing have been logged in 2018. While this piece of equipment is listed as an"Insignificant Activity
under 15A NCAC 02Q .0503(8)" in your T26 permit,compliance with the NSPS and MACT standards
and their provisions is still required.
Operating an emergency engine for more than 50 hours per calendar year in non-emergency
situations and for more than 100 hours per calendar year in combined situations of non-
emergency/maintenance checks/readiness testing are considered exceedances. Operating an emergency
engine in this manner maybe subject to the assessment of civil penalties as per the authority of North
Carolina General Statute 143-215.114A. This letter is to inform you that operating your emergency
engine for more than 50 hours per calendar year in non-emergency situations and for more than 100
hours per calendar year combined situations of non-emergency/maintenance checks/readiness testnng
North Carolina Department of EnvironmentaJ Quality I Division of Air Quality
-DW Raleigh Regional Office ! 3800 Barrett Drive! Raleigh,North Carolina 27609
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919.79142001'1919.881.2261 F
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Products, LLC -Moncure
November 20, 2018
Page 2
are violations of the operating limitations requirements referenced in your air quality permit and outlined
under NSPS Subpart I1I1 and MACT Subpart ZZZZ. Note that MACT Subpart ZZZZ requirements are
met through the compliance with NSPS Subpart IIII requirements.
The NSPS Subpart IIII standard at 40 CFR §60.4211(f)(3)states as follows:
Emergency stationafy ICE may he operated,for i p to 50 hours per calendar year-in non-
emergency situations. The 50 hours of'operation in non-emergency sititations are counted as
part of the 100 hours per calendar year for maintenance and testing and emergency demand
response provided in paragraph (f)(2) of this section.
Please be aware of this regulatory requirement in order to assure that, in the Riture,non-emergency
usage hours remain at or below 50 hours per calendar year until the modified air pennit changes the
status of the engine to non-emergency. Likewise, the sum of maintenance hours, readiness testing and
non-emergency hours must be 100 hours or less. Since the 50 hours per calendar year and 100 hours per
calendar year have been exceeded in 2018,your facility must demonstrate compliance through an initial
performance test within one year of your engine exceednlg the 50-hour limit or 100-hour limit. This
NSPS IIII requirement is described in 40 CFR §60.4211(g)(2). Your facility can request in writing from
our office to have the initial performance testing requirement waived.
Additionally, on September 6, 2018,Matthew Mahler of this office conducted a compliance
inspection of the subject facility based on Air Pennit No. 03424T26. During that inspection, Mr. Mahler
discovered that one of the permit-required Compliance Assurance Monitoring(CAM) reporting
requirements for the fluidized bed wood burner and multicyclone (Emission Source ID No. ESO1-
A/Control Device ID No. CD02) was not being met. An onsite records review indicated that there were
16 days in the first half of 2017 in which the differential pressure drop across CD02 was outside the
acceptable range. The Quality Improveinent Plan(QIP) threshold is triggered when there are ten
excursions in a six-month reporting period. On July 28, 2017, the Raleigh Regional Office received a
2nd half semiannual report for calendar year 2017 from your facility in Moncure, North Carolina.
However,the report documented only five excursions in the first half of 2017. Failure to submit an
acc�.:rate sa�r.:na., of the excursions and a description of the actions taken to implement a QIP on your
facility's multicyclone CD02 is a violation of permit Stipulation 2.1.C.5(e),which reads as follows:
e. AL a minimtnn, the report shall include the.following elements:
i. Sunnnaty information on the number, dirration and cause (including unknown cause, if
applicable) of excursions or exceedances, as applicable, and the corrective actions taken;
ii. SZnninmy information on the number, duration and cause (including unknown cause, if
applicable)for monitor(pressure gauge) downtime incidents (other than downtime associated
with zero and.span or other daily calibration checks, if applicable); and
iii. A description of the actions taken to implement a QIP during the reporting period as specified
in 40 (TR 64.5. Upon completion of a QIP, the owner or operator shall include in the next
sunrmal-v report documentation that the implementation of the plan has been completed and
reduced the likelihood of similar levels of texcursions or exceedances occurring.
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North Carolina Department of Environmental Quality I Division of Air Quality
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� Raleigh Regional Office i 3800 Barrett Drive l Raleigh,North Carolina 27609
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Boise Cascade Wood Products, LLC -Moncure
November 20,2018
Page 3
This Notice of Violation are hereby issued to Boise Cascade Wood Products, LLC for failure to
comply with the above referenced air pernut conditions. Please submit a written response to this
Notice of Violation by December 20, 2018, describing actions taken by your company to ensure
future compliance with the NSPS I111,MACT ZZZZ,and Compliance Assurance Monitoring
regulations. Please develop a QIP and submit a description of the actions taken to implement the
QIP during the reporting period. This office also reconumends that you or a designated company
representative review your air pen-nit to ensure that you understand all of the specific and general pen-nit
conditions. Please note the operating limitation and semiannual reporting requirements, and make the
necessary provisions to ensure that these requirements are met within the specified time frames.
This is the second incident of exceeding the NSPS Subpart IIII operating limitations that this office
has documented against the subject facility within the last five years. Boise Cascade Wood Products,
LLC was issued a Notice of Deficiency on May 31, 2018, for exceeding the maximum allowable non-
emergency hours for calendar year 2017. Likewise, this is the second incident of failure to submit a
timely or complete Title V report that this office has documented against the subject facility within the
last five years. Boise Cascade Wood Products,LLC was issued a Notice of Violation on August 10,
2015, for a late performance test and test report submission. It is imperative that you take whatever
steps necessary to ensure that, in the future, the Title V operating limitations and semiannual reporting
requirements are adhered to as referenced in your air quality permit. As an additional reminder,these
Notices of Violation and the 2018 Notice of Deficiency are 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 2018 ACC is due by March 1, 2019. Also,upon completion of a
QIP,the facility shall document the completion of the implementation in the next semiannual
report.
We appreciate your immediate attention to this concern. If you have any questions, please contact
Matthew Mahler,Environmental Engineer, or Will Wike, Compliance Supervisor, at(919) 791-4200.
Sincerely,
T.R y Ste , Jr.,P.E., �P
Regional Supervisor
Division of Air Quality,NC DEQ
cc: RRO Files
North Carolina Department of Environmental Quality 1 Division of Air Quality
Raleigh Regional Office ` 3800 Barrett Drive I Raleigh North Carolina 27609
ONparinlanlol Envnamn!Aa19udI11Y 919,791.4200 T 1919.881.2261 F
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