AQ_F_1900015_20160125_CMPL_Fac-Ltr

985 Corinth Road
Nbncure,North cam|in
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January 21. 2O1G
Mr. Michael Pjetraj. P.E.
NCOENR—Oivisiono[AirQua|dx
217 West Jones Street
1G41 Mail Service Center `�'' � �-� "IZ, O T�/ ��
Raleigh, NC � `^ �~ �|
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Subject: Deferral of Enforcement Request—NOxContnd/pMCUTria| /
K0oncure. {�he�mmCou�y. No�hCarolina . � J�� � � �U|0
Air Pennit#O3440l44
Dear Mr. pjetnaj:
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Arauco's Moncure MDF facil���[���n �� U��U|����� n�—o |
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formaldehyde free alternative binding technology—on December 1G. 2O15. The trial was unsuccessful duabothopMO| .
activating prior to being pressed. Arauoo personnel believe the reason for this is that the urea injection for the selective
non-catalytic reduction(SNCR)of NOx at the outlet of the Teaford Energy System (ES-02-A)is inefficient and generating
ammonia slip. The ammonia is then entering the dryers where the resin is blended with dried fiber and reacting with the
pK8D| pnamsdune|y.
Arauco personnel feel there are multiple potential root causes and would like to investigate via an environmental trial in a
pMD|thai A potential root cause for the ammonia slip could be that the furnace demand is not consistently above 1600OF
during the use of pMDI because pMDI demands a higher moisture content in the fiber than urea-formaldehyde based
resins. The SNCR reaction occurs between temperatures of18OO-18OO"Ftocomplete the reduction cfNOx. Urea does
not negatively impact Arauco's typical urea-formaldehyde based resins so ammonia slip would go unnoticed.
Arauco has conducted pMDI trials successfully in the past but in November 2014 Moncure increased the urea injection
rate from O.1gpmboO.2gpm The goal was to reduce NOx emissions for its PSD Avoidance limit so the increase to 0.2
gpm may have reached a critical bnomkavenpoint.
Arauco personnel would like to temporarily fluctuate the addition of urea during another follow-up pMDI trial to determine if
ammonia slip is the root cause of the pMDI inactivity. Simultaneously,Arauco personnel would use a NOx emissions
monitor ho determine the actual emissions with lowered urea injection andosUmabatheeffioiencyand|imitationooftha
existing urea injection system. pMD1 runs in the future may require no or lowered urea injection as well and Arauco may
need bo conduct a compliance test for a separate emission factor if urea injection pnovmnhobotherootnou000fthepyWD|
failure.
The facility rolling NOx PSD Avoidance Limit is 177.8 TPY and the facility as of December 2015 is 70.5%of the limit on the
last 12-monthblock. The estimated emissions from decreasing the urea injection would result in possibly up to a 50%
increase inNOx emissions for a12 hour trial. The maximum projected onderfi|aforpK8O| pnoducts(phmah|yfloohng)imO
days of production per month potentially increasing our total NOx 12-month rolling average by 10%,which should still
keep the facility below the PSO Avoidance Limit.
If you have any questions related to this request, please contact Todd Phillips, Moncure's Environmental Manager, at 919-
545-5849 or John Bird at 919-642-6658.
Sincerely,
Tom Quesenberry
Site Manager
CC: Rich Weber, Fkaheboand Director of Environment and Government Affairs