AQ_F_0100237_20160831_CEM_RptRvwLtr (6)

PAT MCCRORY
Governor
1C_
DONALD R. VAN DER VAART
Secretary
Air Quality SHEILA C. HOLMAN
ENVIRONMENTAL QUALITY Director
August 31, 2016
Mr. Mark Blalock
General Manager
New South Lumber Company, Inc. —Graham Plant
4408 Mt. Hermon-Rock Creek Road
Graham,North Carolina 27253
SUBJECT: Review of 2016 First Semester COMS Report
New South Lumber Company, Inc. —Graham Plant
Graham, Alamance County, North Carolina
Facility ID No. 0100237
Air Permit No. 06740T 18
Dear Mr. Blalock:
Thank you for your timely submittal of the subject report, dated July 27, 2016, 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 first half of 2016.
Additional information regarding COMS audits was provided by Kristie Hill of your staff upon
request on August 31, 2016. 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 wood fuel-fired boiler(B-4)was reviewed for compliance with the underlying opacity
standard set forth at NCAC 2D .0524 (40 CFR Part 60, Subpart Dc - Standards of
Performance for Small Industrial-Commercial-Institutional Steam Generating Units) and Air
Permit No. 06740 specific condition 2.1.B. The EER indicated 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 NCAC 2D .0524 (NSPS Dc, including Subpart A - General Provisions),
40 CFR 60.11(d), 40 CFR 60.13, and specific condition 2.1.B. When compared to the total
operating time of the boiler,percent excess emissions (%EE) were reported as 0.0% for the
first quarter and 0.1% for the second quarter; percent monitor downtime (%MD)was
reported as 0.1% for the first and second quarters. 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.
State of North Carolina I Environmental Quality I Air Quality
1641 Mail Service Center 1 217 W.Jones Street,Suite 4000 1 Raleigh,NC 27609-1641
919 707 8400 T

Mr. Mark Blalock
August 31, 2016
Page 2
3. The first and second quarter audits of the COMS unit were reviewed in accordance with
Procedure 3 of 40 CFR Part 60, Appendix F - Quality Assurance Procedures. The QA test
results for the COMS appear to have met the quarterly specifications.
If you should have any questions,please contact me at(919) 707-8493 or [e-mail].
Sincerely,
_s.
Alan Drake, Environmental Engineer
Division of Air Quality,NCDEQ
c: Lisa Edwards, WSRO
Michael Pjetraj, RCO
IBEAM, 0100237
Central Files, Alamance County