AQ_F_0200098_20190109_CMPL_Fac-Ltr

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PIEDMONT NC DEPARTMENT OF
COMPOSITES s TOOLING ENVIRONMENT;-,L QUALITY
January 8,2019 RECEIv!3k)
Ms. Karyn Barksdale ,JAN ® 9 2019
North Carolina DEQ
Division of Air Quality,MRO MOORESVILLE REGIONAL OFFICE
610 East Center Avenue,Ste. 301 DIVISION OF AIR QUALI.T'Y
Mooresville,North Carolina 28115
Subject: Response to Notice of Violation and Recommendation for Enforcement
Piedmont Composites and Tooling, LLC
Taylorsville, North Carolina
Alexander County
Air.Permit Number 09941T03
Dear Ms. Barksdale:
I hope that you are well. This letter is in response to your letter dated January 4, 2018, regarding the compliance
inspection performed on December 51h,2018. 1 would like to take this opportunity to provide a timeline of events at
the facility,which led to your finding.
On December 3,2018,it was discovered by facility personnel that the tracking of HAP coatings materials had been
overlooked for the months of August,September and October due to personnel changes at PCT. Facility personnel
compiled the HAP coating usages and forwarded them to our consultant, who began work on the calculations for
those months. Your inspection of the facility took place on December 5, 2018. Our consultants completed the
calculations as quickly as they could.The calculations for August,September and October were sent to you via email
within 3 business days(December loth),followed by November's calculations being emailed on December 121h,2018.
While the tracking of HAP coating materials was overlooked, I wish to assure you that the omission was accidental,
and we were in the process of rectifying the situation at the time of your visit. We feel that it is important to note
that no emissions']imits were exceeded during the time in question,and there are now procedures in place to ensure
that this omission doesn't occur again.We have 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 VP of PCT and myself. In addition, PCT is creating or enhancing what was already in place a
process controls manual outlining,in detail,all procedures in our facility with a section dedicated to the environment
for continuity if personnel changes occur.Our consultant will also send us monthly reminders for redundancy.
We understand the importance of compliance with all conditions of our Air Permit and respectfully request that no
enforcement action be taken. Please feel free to contact me at(828)632-8883 if you have any questions. Thank
you for your time and consideration.
Sincerely,
�,�WvIl'I"tz
David Himebaugh
President
33 LEWITTES ROAD PHONE:[phone]
TAYLORSVILLE, NC z8681 FAX:[phone]
PIEDMONTCOMPOSITES.COM
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