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Home My WebLink AboutAQ_F_1900039_20181120_CMPL_NOV (3) ` srA-Q,, uNAILEID ROY COOPER e` '. �., Z _ , 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 If Atl A N Q Ocpttmenl nl FnVhommnlnlQua4 919.79142001'1919.881.2261 F C � .cr✓-M a i Py . 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. � Q North Carolina Department of Environmental Quality I Division of Air Quality ` •/ � Raleigh Regional Office i 3800 Barrett Drive l Raleigh,North Carolina 27609 x V^.LH fJ:MLI`tl Onp:nlminl of Enimmlenlal quzQlY 919.741.4200 T 1919.881.2261 F 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 O y