AQ_F_0200098_20190405_ENF_Enf-FND

STATE OF NORTH CAROLINA NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT
COMMISSION
FILE NO. DAQ 2019-006
COUNTY OF ALEXANDER )
IN THE MATTER OF: )
PIEDMONT COMPOSITES AND )
TOOLING, LLC ) CIVIL PENALTY ASSESSMENT
FOR VIOLATION OF: )
AIR PERMIT NO. 09941 T03 )
SPECIFIC CONDITION AND )
LIMITATION NOS. 2.1.A.2.c.i )
AND 2.1.B.3.b )
Acting pursuant to North Carolina General Statutes (G.S.) 143-215.114A, I,Michael A.
Abraczinskas, Director of the Division of Air Quality(DAQ), make the following:
I. FINDINGS OF FACT:
A. Piedmont Composites and Tooling, LLC (Facility ID: 0200098)was issued Air
Permit No. 09941T03 on April 18, 2018, with an effective date of April 18, 2018,
and an expiration date of March 31, 2023, for operation of its facility at 33
Lewittes Road,Taylorsville,Alexander County,North Carolina.
B. Said permit contains the following pertinent provisions:
1. Specific Condition and Limitation No. 2.1.A.2.c.i (15A NCAC 2D .I 111,
"Maximum Achievable Control Technology"), as promulgated in 40 CFR
63 Subpart WWWW, "National Emission Standards for Hazardous Air
Pollutants (NESHAP) for Reinforced Plastic Composites Production",
states in part:
"The Permittee shall demonstrate that,on average, you meet the individual
organic HAP emission limits for each unique combination of operation type
and resin application method or gel coat type listed [in your permit] by:
i. grouping the process streams by operation type and resin application
method or gel coat type listed [in your permit] and then calculate a
weighted average emission factor based 'on the amounts of each
individual resin or gel coat used for the last 12 months."

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2. Specific Condition and Limitation No. 2.1.B.3.b (15 NCAC 2Q .0317,
"NESHAP Avoidance Condition for Surface Coating of Plastic Parts and
Products (40 CFR 63, Subpart PPPP"), of said permit also states in part:
"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."
C. On December 5, 2018, Karyn Barksdale, of the Mooresville Regional Office,
Division of Air Quality, conducted a full compliance evaluation of the facility and
observed the following violation:
During that inspection it was determined that HAP emission limit calculations
were not conducted for a four-month period from August 2018 through November
2018. Several days after the inspection it was communicated to Ms. Barksdale by
the facility that the data requested was being compiled. The requested data was
emailed to Ms. Barksdale on December 10, 2018, and December 12,2018.
D. A Notice of Violation and Recommendation for Enforcement Letter(NOWNRE)
was issued to Piedmont Composites and Tooling, LLC on December 19,2018, for
the violations noted in Findings of Fact"C"above. The letter was returned to the
Mooresville Regional Office by the US Postal Service as "Return to Sender,No
Mail Receptacle,Unable to Forward". The Notice of Violation and
Recommendation for Enforcement was sent again on January 4, 2019, to the same
address via postal mail and email. Piedmont Composites and Tooling, LLC
responded to the Notice on January 9, 2019.
E. Prior Air Quality Compliance History:
• Piedmont Composites and Tooling, LLC was issued a Notice of
Violation on March 26, 2018, for violations of Specific Condition
and Limitation Nos. 2.1.A.2.d.i and 2.1.B.3.b that requires the
Permittee to document the HAP coatings used and calculate the
HAP emissions on a monthly basis to ensure compliance with 15
NCAC 2D .I 111.
F. The costs of investigation in this matter totaled$182.00.
Based upon the above Findings of Fact, I make the following:
II. CONCLUSIONS OF LAW:
A. Piedmont Composites and Tooling, LLC was in violation of Air Permit No.
09941T03, Specific Condition and Limitation No. 2.1.A.2.c.i (15A NCAC 2D
.1111, "Maximum Achievable Control Technology"), as promulgated in 40 CFR
63 Subpart WWWW, "NESHAP for Reinforced Plastic Composites Production"
and Specific Condition and Limitation No. 2.1.B.3.b (15 NCAC 2Q .0317,
"NESHAP Avoidance Condition for Surface Coating of Plastic Parts and Products
40 CFR 63, Subpart PPPP") as noted in Findings of Fact "C" above.

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B. G.S. 143-215.114A provides that a civil penalty of not more than twenty-five
thousand dollars per violation may be assessed against a person who violates or
fails to act in accordance with the terms, conditions, or requirements of a permit
required by G.S. 143-215.108 or who violates any regulation adopted by the
Environmental Management Commission.
C. G.S. 143-215.3(a)(9)provides that the costs of any investigation or inspection
may be assessed against a person who violates or fails to act in accordance with
the terms, conditions, or requirements of a permit required by G.S. 143-215.108
or who violates any regulation adopted by the Environmental Management
Commission.
Based upon the above Findings of Fact and Conclusions of Law, I make the following:
III. DECISION:
Piedmont Composites and Tooling, LLC is hereby assessed a civil penalty of:
$ 'L 10.uv for four(4)violations of Air Permit No. 09941 T03, Specific
Condition and Limitation No. 2.l.A.2.c.i (15A NCAC 2D .1111,
"Maximum Achievable Control Technology"), as promulgated in
40 CFR 63 Subpart WWWW, "NESHAP for Reinforced Plastic
Composites Production"for failure to conduct calculations for four
months to demonstrate that, on average, they met the individual
organic HAP emission limits for each unique combination of
operation type and resin application method or gel coat type listed
in their permit for each individual resin or gel coat used for the last
12 months and
$ 0. v0 for four(4) violations of Air Permit No. 09941T03, Specific
Condition and Limitation No. 2.1.B.3.b (15 NCAC 2Q .0317,
"NESHAP Avoidance Condition for Surface Coating of Plastic
Parts and Products 40 CFR 63, Subpart PPPP") for failure to
conduct calculations for four months to demonstrate total gallons
of HAP coatings used to coat plastic parts or products on a
monthly basis to ensure compliance with the rolling 12 consecutive
month limitation for the months of August 2018 through
November 2018.
$N_3(go -ot) TOTAL CIVIL PENALTY,which is 2 2 percent of the
maximum penalty authorized by G.S. 143-215.114A.
$ 182.00 Investigation costs.
$A sY 2. na TOTAL AMOUNT DUE

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Pursuant to G.S. 143-215.114A in determining the amount of the penalty, I considered
the factors listed in G.S. 143B-282.1(b) and 15A NCAC 2J .0106,which are the
following:
1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violation(s);
2) The duration and gravity of the violation;
3) The effect on ground or surface water quantity or quality or on air quality;
4) The cost of rectifying the damage;
5) The amount of money saved by noncompliance;
6) Whether the violation was committed willfully or intentionally;
7) The prior record of the violator in complying or failing to comply with programs over
which the Environmental Management Commission has regulatory authority; and
8) The cost to the State of the enforcement procedures.
� �r
Date Michael A. Abraczinskas,Dir or
Division of Air Quality