AQ_F_0100237_20150303_CEM_RptRvwLtr (3)

FIFWA
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
March 3, 2015
Mr. Terry Bishop
General Manager
New South Lumber Company, Inc. —Graham Plant
4408 Mt. Hermon-Rock Creek Road
Graham,North Carolina 27253
SUBJECT: Review of 2014 Second Semester COMS Report
New South Lumber Company, Inc.—Graham Plant
Graham, Alamance County,North Carolina
Facility ID No. 0100237
Air Permit No. 06740T18
Dear Mr.Bishop:
Thank you for your timely submittal of the subject report dated January 29, 2015, from New
South Lumber's Graham Plant. The report included an assessment of the continuous opacity
monitoring system (COMS) that operated on Boiler#4 (ID No. B-4) during the second half of
2014. The Division of Air Quality (DAQ) has completed its review of the COMS-related
information in the report and offers the following comments:
1. The report was reviewed for compliance with 20% opacity limit found at 40 CFR Part 60,
Subpart Dc and permit condition 2.1. There were no violations of the applicable
standard. Excess emissions from the wood-fired boiler were attributed to either startup,
shutdown, malfunction, or other exempt emissions. These emissions were reviewed and
allowed in accordance with applicable monitoring rules.
2. A review was also conducted for compliance with good operation and maintenance
(O&M) practices pursuant to 40 CFR 60.l 1(d), 40 CFR 60.13, permit specific condition
2.1.B. and general condition F. When compared to the total operating time of the boiler
during the third quarter, percent excess emissions (%EE) were reported as 0.15% and
percent monitor downtime (%MD) as 0.00%. For the fourth quarter, %EE was reported as
0. and %MD as 0.00%. Thus, the COMS unit appears to indicate the use of proper
O&M practices for minimizing emissions since quarterly %EE and %MD were less than
6% for any single calendar quarter and less than 3% for two consecutive quarters.
1641 Mail Service Center,Raleigh,North Carolina 27699-1641
Phone:[phone] Internet:www.ncdenr.gov
An Equal Opportunity 1 Affirmative Action Employer—Made in part by recycled paper

Mr. Terry Bishop
March 3, 2015
Page 2
If you should have any questions, please contact me at [phone] or [e-mail].
Sincerely,
Alan Drake, Environmental Engineer
Division of Air Quality, NCDENR
cc: Lisa Edwards, WSRO
Michael Pjetraj, RCO
Central Files, Alamance County
IBEAM (0100237)