AQ_F_1900015_20160831_CMPL_Fac-Ltr

ARAUCO
985 Corinth Road
Moncure, North Carolina 27559
Michael Pjetraj, P.E. August 31,2016
Stationary Source Compliance Branch Supervisor
Division of Air Quality
North Carolina Department of Environmental Quality
1641 Mail Service Center
Raleigh, NC 27699-1641
Subject:SOC 2015-02 Extension of Internal Timeline Biofilter Pilot Moncure Particleboard
As discussed in our July 22"d,2016 meeting with DEQ regarding the status of SOC compliance,Arauco
Panels is requesting a three month extension of the deadline to trial a biofilter on the particleboard
plant. Per SOC 2015-02,Section II.B.iii,a biofilter trial is to be completed one year after execution of the
order(i.e., by November 2,2016). This request will not affect the SOC final compliance date.Although
Arauco has been diligently working towards attaining a pilot unit for the particleboard plant, it is clear
that we will need additional time to evaluate the effectiveness of a biofilter over the course of several
seasons. Please note that a MACT control strategy that avoids the use of a thermal oxidizer remains our
priority to avoid fossil fuel use and subsequent NOx and GHG emissions.
Arauco initially attempted to comply with PCWP MACT at the particleboard plant by converting to pMDI
resin in July 2015. The plant conducted a compliance test of the press and demonstrated compliance
with the MACT production based compliance option (PBCO). An engineering test was conducted
similarly on the particleboard dryers to see if the removal of urea-formaldehyde recycled material from
the dryers would result in PBCO compliance but the test was not successful. In February 2016,due to
the inability to comply with the PBCO for green rotary dryers and an inability to produce consistent,
quality pMDI particleboard product,the facility converted back to urea-formaldehyde resin.
On April 19th, 2016,Arauco began receiving proposals from the likely supplier of the MDF biofilter for a
pilot unit. Arauco attempted to negotiate the pilot unit as part of the primary MDF project but the
contract is still in negotiation and these ongoing negotiations would delay the pilot unit from being
constructed.Additionally,a technical revelation occurred with this supplier on May 101h,2016. A
conference call was held between the supplier and Arauco discussing a failed trial of their biofilter
technology on a composite panel plant in 2008.The vendor revealed to Arauco that at temperatures
between 1200E-1301F,the biofilter would not be efficiently operating in mesophilic(low temperature)
or thermophilic(high temperature) bacteria ranges and that destruction efficiency may be relatively
poor as seen in the 2008 trial. This challenging operational window is the expected exhaust
temperature of Moncure particleboard while the Moncure MDF plant is safely within the thermophilic
range at all times.
Arauco personnel then approached a new vendor to provide a different biological technology pilot unit.
This technology incorporates an ambient air stream to drive the exhaust stream temperature down to
mesophilic temperature ranges. The first proposal was received from this second biofilter vendor in July

2016. The contract was negotiated with the vendor and a purchase order was issued to the vendor in
August 2016. On August 24th, 2016 a conference call was held with the vendor to determine startup
date of the pilot unit and the pilot is expected to be delivered and started the week of September 12th,
2016. The vendor stated they would need two weeks to get adequate biological activity before testing
the unit so testing could not effectively commence until September 26th,2016 leaving Arauco only 5 and
a half weeks of testing and evaluation for an extremely critical aspect of the project. Further, by
terminating the trial by November 2"d we would not get to evaluate performance over the course of
multiple seasons.A three month extension would incorporate high and low operating seasonal
temperatures.
The vendor conducting the trial has installed three full scale biofilters on particleboard plants for MACT
compliance but the exhaust streams at these other facilities were cooler and drier allowing for a simpler
design and better mesophilic activity. This is why Arauco is requesting additional time to ensure the
biological activity can be sustained in Moncure Particleboard's exhaust over an extended period of time
and source testing can be conducted on the unit. Arauco is requesting the deadline for the biofilter pilot
unit be extended three months(i.e.,complete the trial by February 2"d, 2017).To not materially affect
major SOC deadlines,we are also proposing to submit the air permit application 60 days after trial
completion instead of 90 days and can reduce the construction timeline from 20 months to 18 months
for the completion of the final control device.
As an alternative strategy to add-on control device technologies,Arauco will also simultaneously be
pursuing the option of dry rotary dryers as defined in 40 CFR 63.2292. A new green rotary dryer at a
sister facility in South Carolina has freed up excessive dry wood furnish for Moncure Particleboard and
could allow us to convert all of Moncure's particleboard dryers in to dry rotary dryers requiring wood
moisture content measurement, maximum inlet temperature monitoring,and no add-on control devices
to comply with the PCWP MACT. Arauco will also pursue PBCO testing on the particleboard press since
we have seen positive results on two particleboard lines in Arauco's North American operations using
urea-formaldehyde based resins.
If there are any questions with this request, please contact Todd Phillips at 919-545-5849 or myself at
919-642-6658.
Sin rely,
Joh ird, P. .
th America Environmental Manager
cc: Rich Weber, EHS Director
Tom Quesenberry, Regional Manufacturing Director