AQ_F_1900039_20161128_ST_RvwMemo

DIVISION OF AIR QUALITY
November 28, 2016
MEMORANDUM
To: Patrick Butler,P.E.,Raleigh Regional Office *V0
From: Shannon Vogel, Stationary Source Compliance Branch
Subject: Moncure Plywood, Moncure, Chatham County,North Carolina
Facility ID 1900039,Permit No.03424T25
Total Particulate Emissions Testing of Veneer Dryer M-72
Performed June 30, 2016 by Civil&Environmental Consultants,Inc. (CEC)
Tracking No.2015-154st
CEC performed EPA Method 5/202 of the direct wood-fired veneer dryer M72. The total particulate
matter(PM)testing was performed at the ES 10 dryer emissions points(3 hot zone stacks and 2 cool zone
stacks).The results are acceptable to demonstrate compliance with the applicable emission standards as
discussed in this memorandum.
The following sources are subject to the emissions limitation in 15A NCAC 2D .0515 Particulates From
Miscellaneous Industrial Processes: fluidized bed wood burner ID No. ESO1-A supplying heat to wood
boiler ID No.ES-01-B (both controlled by multicyclone ID No.CD02),with the recombined gas stream
supplying direct heat to: direct wood-fired veneer dryers M72(ES09) and M72 (ES10)and vat
operations ID No. ES20. Permit Condition 2.I.A.c states"the Permittee shall demonstrate compliance
with the emissions limit(s)above by testing the combined emissions of the above sources." 15A NCAC
2D .0515 limits total PM based on production rate.
There are 5 emission points associated with each of the two dryers ES09 and ES 10(10 emissions points
total). CEC tested the five emission points from the ES 10 dryer.The emissions points are Cool Zones I
and 2 and Hot Zones 1, 2, and 3.The emissions from ES09 are estimated based on the ES 10 emissions
test results. Compliance with the 2D .0515 emission limit will be demonstrated"using twice the total
mass emission rate from the five M72-ES 10 stacks to demonstrate compliance for the entire system."The
EPA Method 5/202 test results are acceptable and presented in the tables below.
Total Particulate Matter EPA Method 5/202 Emissions Test Results
Emission Point Test Results Emission Limit Standard Compliance
ES 10 Hot Zone 1 1.14 lb/hr --- --- ---
ES 10 Hot Zone 2' 1.19 lb/hr --- --- ---
ES 10 Hot Zone 3' 1.47 lb/hr --- --- ---
ES 10 Cool Zone 1 1.51 lb/hr --- --- ---
ES 10 Cool Zone 2 0.74 lb/hr --- --- I ---
ES 10 Total 6.05 lb/hr --- --- ---
ES09 Tota12 6.05 lb/hr --- --- ---
M72 Total(ES09+ES 10) 1 12.10 lb/hr 17.0 lb/hr 2D .0515 Yes
1. Three run average result with Run I calculated based on corrected volume sampled as discussed on
following page.
2. ES09 emissions are estimated based on ES 10 total emissions results. The estimates should be conservative
since ES 10 has higher production rates.

Patrick Butler, P.E.
Tracking No. 2015-154st
November 28, 2016
Page 2
Filterable, Condensible and Total Particulate Matter-ES10 Emission Points
Emission Point Test Results,lb/hr
Filterable PM Condensible PM Total PM
Hot Zone 1 0.96 0.18 1.14
Hot Zone 2 0.89' 0.30 1.19
Hot Zone 3 0.96' 0.51 1.47
Cool Zone 1 1.08 0.44 1.51
Cool Zone 2 0.46 0.28 0.74
1. Three run average result with Run 1 calculated based on corrected volume sampled as discussed below.
The Dryers Hot Zones 2 and 3 locations have automatic dampers which were closed during the second
half of Run 1 and for Runs 2 and 3. Run 1 sampling continued with no flow in the stacks. Therefore,the
Run 1 PM results were corrected for the"sample volume for the first thirty minutes." The Hot Zone 2
and 3 dampers were closed during Runs 2 and 3 and no sampling was performed. The Hot Zone 2 and
Hot Zone 3 results presented are the three run average including the corrected Run 1 value and the zero
emissions during Runs 2 and 3.
The reported total production for ES10 and ES09 was 20.2 and 11.9 tons per hour,respectively. CEC
calculated the 2D .0515 emission limit based on the total production values of 20.2 and 11.9 tons, instead
of the average production rates in tons per hour. SSCB calculated the ton per hour production rates based
on the reported production per run and the total sampling time per run. The average production rates for
the ES09 and ES10 dryers were 3.01 and 5.36 tons per hour(8.37 tons per hour),respectively. The
average 2D .0515 emission limit is 17.0 pounds per hour.
Compliance with 2D .0515 was demonstrated. If you have any questions regarding the results of this
review, please contact me at 919-707-8416 or shannon.vogelL&ncde4r.4ov_.
cc: Central Files, Chatham County
IBEATM Documents- 1900039