AQ_F_1900015_20180419_CMPL_DOE

ROY COOPER
Governor
MICHAEL S. REGAN
K41r'� F. Secretary
Air Quality MICHAEL A. ABRACZINSKAS
ENVIRONMENTAL QUALITY Director
April 19, 2018
Mr. Henry R. Scheller
Plant Manager
Arauco Panels USA, LLC
985 Corinth Road
Moncure,NC 27559
Subject: Approval of Deferral of Enforcement Request, 30-day Shutdown of Urea Feed to
the MDF Energy Systems Selective Non-Catalytic Reduction System
Arauco Panels USA, LLC
Air Quality Permit No. 03449T49
Facility ID: 1900015, Moncure, Chatham County
Facility Classification: Title V
Dear Mr. Scheller:
The North Carolina Division of Air Quality(NC DAQ) has received your March 29, 2018 letter
requesting deferral of enforcement for modified operations (outside the parameters of your Title
V permit) and associated increased emissions that may occur during an up to 30-day shutdown of
the urea feed to the selective non-catalytic reduction(SNCR) system to control nitrogen oxide
(NOX) emissions from the MDF energy system(ES-02-A). Your letter indicated that you are
currently commissioning a biofilter, as required by your Special Order by Consent (SOC) 2015-
02, and are currently conducting the required engineering evaluation and shakedown prior to
conducting compliance testing. The biofilter relies upon biological growth and activity in the
biofilter media to decompose formaldehyde and methanol to carbon dioxide and water.
During this commissioning and shakedown period, you indicated that there may be issues of
carryover of excess urea and/or ammonia from the SNCR system that may be creating a
potentially toxic environment for biological growth in the biofilter. You are requesting a
temporary shutdown of the urea feed to the SNCR for a period of thirty (30) days to allow any
excess ammonia to clear the control system and to obtain the necessary samples to observe
biological growth in the biofilter media. Based upon the data you have provided, you estimate
that the suspension of urea feed to the SNCR system will result in an increase in NOx emission
of approximately 18 pounds per hour or 6.5 tons over a 30-day period of urea feed suspension.
NC DAQ is granting your request to allow you to suspend the urea feed to the SNCR system for
a period not to exceed 30-days during this engineering evaluation and shakedown period. Please
note that this suspension of operation will require that you report this in your annual compliance
State of North Carolina I Environmental Quality I Air Quality
217 W.)ones Street 11641 Mail Service Center I Raleigh.North Carolina 27699-1641
919 707 8400

Mr. Henry R. Scheller
April 19, 2018
Page 2
certification(ACC) for calendar year 2018 as a deviation from your permit condition(Condition
2.2.B.l.d)requiring the minimum urea injection rate, during periods other than performance
testing, of 0.24 gpm(3-hour block average, 45% urea concentration by volume). Exceedance of
the NOx emission limit of 177.8 tons per consecutive 12-month period under Permit Condition
2.2.13.La(Avoidance Conditions for 15A NCAC 02D. 0530: Prevention of Significant
Deterioration) is not included in this deferral.
If you have any questions with reference to this matter,please do not hesitate to contact Gary
Saunders at(919) 707-8413.
Respectfully,
Michael Abraczinskas
Director
Division of Air Quality,NCDEQ
Cc: Will Wike, Acting Raleigh Regional Compliance Supervisor(RRO)
Central Files, Chatham County
IBEAM Documents - 1900015