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ROY COOPER NORTH CAROLINA, Generar Environmental Quay MICHAEL S. REGAN secretary MICHAEL ABRACZINSKAS- Director August 24, 2018 Certified Mail 7016 0910 0000 6171 3084 RETURN RECEIPT REQUESTED Mr. John Achzet, VP Operations Royal Pest Solutions, Inc., dba Royal Fumigation 53 McCullough Drive New Castle, DE 19720 SUBJECT: Notice of Violation / Notice of Recommendation for Enforcement Facility ID No. 6500356 County: New Hanover Air Permit No. 10313R01 (Permit Class: Synthetic Minor) Permittee: Royal Pest Solutions, Inc. VIOLATION: _ Exeeedance of the 10-ton HAP limit during the months of May, June, and July 2018 Dear Mr, Achzet, Wilmington Regional Office Division of Air Quality (DAQ) Compliance Inspector (Linda Willis) requested the methyl bromide use for the fumigation facility located at the Port of Wilmington (Facility 1D No. 6500356) from the Royal Pest Solutions, Inc. Regional Manager (James Fealey) for the months of January, February and March (2018). Mr. Fealey provided the requested information and indicated that the aeration process typically used for fumigated shipping containers was not performed and that the unaerated containers were loaded for export, Subsequently, Royal Pest Solutions, Inc. representatives (Jim Fealey and Anne Bookout) were notified by the DAQ Compliance Inspector (Linda Willis) that a leak rate would need to be applied to determine the methyl bromide emissions for recordkeeping and reporting purposes, The Royal Pest Solutions, Inc. representatives (Jim Fealey and Anne Bookout) provided data for each of the containers fumigated during the months of January, February and March (2018). Data included the amount of methy! bromide charged to each container (ounces) and the amount measured in the air space inside the containers (after an unspecified amount of time had elapsed, but prior to export) using aFumiscope. The difference between the two were calculated with the average being approximately 20%, North Carta Department of Evtonmetal Quay | Divison of Ale Quay ‘iinet ResionlOtice 1 2 Cardnt Drive Extension | Wiimote, North Carena 25405, “1079572157 | 9103802008 ‘A 20% leak rate was agreed upon by both RPS representatives and DAQ for the purpose of calculating the methyl bromide emission from unaerated containers for the months of January, February and March, 2018, RPS then submitted monthly methyl bromide emission reports to the DAQ on August 13, 2018 for each month beginning January 2018 and ending July 2018. A review of the reports received indicated the monthly methyl bromide uses were 109.9, 263.6 and 616.3 pounds for the months of January, February and March of 2018, respectively. The 12-month rolling total methyl bromide uses ending May, June and July of 2018 were 20,201.8, 20,980.8 and 20,166.3 pounds respectively. DAQ requested a written explanation for the exceedances on August 13, 2018. Ms. Anne Bookout provided an explanation for the exceedance in a letter received by the DAQ on August 22, 2018 In accordance with the Synthetic Minor Facilities (Specific Condition A.5.a.i.) requirements specified in your Air Quality Permit 10313RO1, you are required to remain below the 10-ton methyl bromide (Hazardous Air Pollutant) limit, This requirement is pursuant to 15A North Carolina Administrative Code 2Q .0315 to avoid the applicability of 15 NCAC 2Q .0501 “Purpose of Section and Requirement for a Title V Permit” Based upon the information provided by Royal Pest Solutions, Ine., it has been determined by this, office that the 12-month rolling total methyl bromide emissions exceeded the 10-ton Synthetic Minor limitation for the months of May, June and July (2018). This letter serves as a Notice of Initiation of Enforcement Action. The Wilmington Regional Office is considering sending a recommendation for assessment of a civil penalty to the Director of the Division of Air Quality. If you would like to provide any additional information with respect to this Notice of Violation and Recommendation for Enforcement, please provide that information within 15 business days of receipt of this Notice. Any further response by you will be reviewed and if an enforcement action is still deemed appropriate, your explanation(s) will be forwarded to the Director with the enforcement package for his consideration, The above violation and any future violations of this type are subject to the assessment of civil penalties as per North Carolina General Statute 143-215,114A, We appreciate Royal Pest Solution, Inc.'s attention to this environmental concern. If you have any questions, please contact Linda Willis at 910-796-7235 or myself at 910-796-7234, Sincerely, Vl Brad Newland Wilmington Regional Supervisor Division of Air Quality Ce: WiRO Permit Folder 6500356 ROY COOPER Gren . MICHAEL S, REGAN MICHAEL A. ABRACZIN Director ABRA SKAS NORTH CAROLINA Environmental Quality CERTIFIED MAIL RETURN RECEIPT REQUESTED ‘7017 0190 0000 1635 8790 ‘November 5, 2018 ‘Mr. John Achzet, VP Operations Royal Pest Solutions, Inc., dba Royal Fumigation 53 McCullough Dr. New Castle, DE 19720 SUBJECT: Civil Penalty Assessment for Violation(s) 2Q .0315 Synthetic Minor Facilities FileNo: — DAQ 2018-055 Violator: Royal Pest Solutions, Inc., dba Royal Fumigation County: New Hanover Facility ID: 6500356 Dear Mr, Achzet: This letter transmits notice of civil penalty assessed against Royal Pest Solutions, Inc., dba Royal Fumigation in the amount of $4,500 and $404 investigative costs, for a total of $4,904. Enclosed is a copy of the assessment document explaining this penalty. This action was taken under the authority vested in me by the delegation pursuant to North Carolina General Statutes (NCGS) 143-215.114A(4). Any new or continuing violation(s) may be the subject of a new enforcement action, including additional penalty. You must take one of the three actions outlined below within thirty (30) days from the date of receipt of this letter. Please be advised that if you fail to exercise one of the following options within thirty (30) days, ‘you will lose your right to appeal or contest this case and your case will be forwarded to the Attorney General's Office for collection. 1. Submit payment of the penalty: Payment should be made directly to the order of the North Carolina Department of Environmental Quality (NCDEQ). | When submitting payment, please reference your DAQ case number on your check to insure proper Posting. Please do not include the attached waiver form when submitting payment. Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s). Please submit payment to the attention of: Enforcement Group - Payment Department of Environmental Quality Division of Air Quality 1641 Mail Service Center Raleigh, NC 27699-1641 ‘Nar Cartina Departmen of Envzwamental Quali Divison Ale Quay 217 West Jones Set, Sate 400 | 1641 Mal Service Center| Raleigh, NC-27699-1641 sig.707 007