AQ_F_1900015_20151211_ST_ProtRvw

PAT MCCRORY
Governor
Kr'r1V
DONALD R. VAN DER VAART
Secretary
Air Quality SHEILA C. HOLMAN
ENVIRONMENTAL QUALITY Director
December 11, 2015
Mr.Tom Quesenberry
Arauco Panels USA LLC
985 Corinth Road
Moncure,North Carolina 27559
Subject: Arauco Panels USA LLC
Moncure, Chatham County,North Carolina
Facility ID 1900015,Air Quality Permit No. 03449T44
Emissions Test Protocol for Particleboard Press ID DEF-2010
Integrity Air Monitoring,Inc.
Proposed Test Date: January 14,2016
Tracking No. 2016-004st
Dear Mr. Quesenberry:
The North Carolina Division of Air Quality(DAQ)has reviewed the subject protocol submittal form
(PSF)for the emissions testing of particleboard press DEF-2010. The purpose of testing is to
"demonstrate compliance with the PWCP MACT production based compliance option for the Moncure
Particleboard Press"per December 8, 2015 email from John Bird,P.E. Carolina Regional EHS Manager,
Arauco—North America. The proposed testing is acceptable to establish to the hazardous air pollutant
(HAP) emissions only as discussed below.
Emission Source ID DEF-2010 is a particleboard press, which is currently permitted as being controlled
by packed bed scrubber with photochemical gas treatment CD-PB-PGT. As indicated in the
"particleboard press air flow schematic" submitted with the PSF and allowed in Special Order by Consent
(SOC)for Arauco Panels USA,LLC dated November 2, 2015,the PGT is no longer in service.
The proposed testing location is the outlet of the particleboard press prior to the dryers,to determine the
total HAP emissions for the production based compliance option in the applicable regulation. 40 CFR
63.2292 states"total hazardous air pollutant emissions means, for the purposes of this subpart,the sum of
emissions from the following six compounds,acetaldehyde, acrolein, formaldehyde,methanol,phenol,
and propionaldehyde."
40 CFR 63 Subpart DDDD National Emission Standards for Hazardous Pollutants:Plywood and
Composite Wood Products applies and specifies the production based compliance option emissions limits
and testing requirements. Table I to Subpart DDDD of Part 63—Performance Based Compliance
Options specifies a total HAP emission limit of 0.30 pounds per thousand square feet of% inch
(lb/MSF'14") for reconstituted wood product presses.
Table 4 to Subpart DDDD of Part 63—Requirements for Performance Tests requires the following:
sampling port location and number of traverse points by EPA Method 1,velocity and volumetric flow rate
by EPA Method 2, molecular weight by EPA Method 3, gas moisture by EPA Method 4 and total HAP
emission measurement by EPA Method 320 or NCASI 99.02 or NCASI 105.01. Table 4 also requires
State of North Carolina I Environmental Quality I Air Quality
1641 Mail Service Center 1 217 W.Jones Street,Suite 4000 1 Raleigh,NC 27699-1641
919 707 9400 T

Mr.Tom Quesenberry
December 11,2015
Page 2
capture efficiency determinations for each reconstituted wood product press subject to a compliance
option in Table 1 A.
Table 2 of Subpart DDDD of Part 63 -Operating Requirements specifies that"process unit that meets a
compliance option in Table IA of this subpart"must"maintain on a daily basis the process unit
controlling operating parameter(s)within the ranges established during the performance test according to
63.2252(n)."40 CFR 63.2262(n)Establishing operating requirements for process units meeting
compliance options without a control device states"you must establish your process unit operating
parameters [emphasis added] according to paragraphs(n)(1)through(2)of this section"and"during the
performance test,you must identify and document the process unit controlling parameter(s)that affect
total HAP emissions during the three-run performance test." Table 5 to Subpart DDDD of Part 63
Performance Testing and Initial Compliance Demonstrations for the Compliance Options and Operating
Requirements requires that the operating parameters be measured and recorded during the performance-
based compliance option testing.
Integrity Air has proposed three 60-minute NCASI 105.01 sampling runs to determine total HAP
emissions. The molecular weight of 29.0 will be assumed per EPA Method 2 Section 8.6. NCASI
Method 105.01 is an acceptable method per 63 Subpart DDDD. In order for the proposed testing to be
acceptable to establish compliance with 63 Subpart DDDD for the performance based compliance option,
Arauco should address all the requirements in Subpart DDDD, including the requirements to determine
the"controlling"operating parameter and capture efficiency. Please see attachment for excerpts from 63
Subpart DDDD for relevant regulatory language and detailed requirements.
The stated permitted maximum,maximum normal and proposed production rate for testing are 180
million square feet per year(MMsf/yr),26 thousand square feet per hour(MSF/hr)and 21 MSF/hr,
respectively. The proposed production rate for testing is 8 1%of stated normal maximum. DAQ
recommends testing at an operating rate which is at least 90%of maximum normal rate. However,DAQ
approves the proposed rate to determine the HAP emissions at the location for press operating rates up to
approximately 110%of the actual tested rate.
Approval of this sampling protocol does not exempt the tester from the minimum requirements of 40 CFR
63 Subpart DDDD and sampling methods. Any deviations remain subject to approval by DAQ. If you
have any questions,please contact me at 919-707-8416 or shannon.vogelCamcdenngov.
Sincerely,
Shannon Vogel, Environmental Engineer
Division of Air Quality,NCDEQ
cc: Central Files, Chatham County Patrick Butler,Raleigh Regional Office
Todd Phillips,Arauco John Bird, Arauco
Jim Lewis,Integrity Air Monitoring, Inc. IBEA_M Documents— 1900015

Attachment
Table 2 to Subpart DDDD of Part 63—Operating Requirements
If you operate a(n) . . . You must. . . Or you must. . .
(5)Process unit that meets a Maintain on a daily basis the process Maintain the 3-hour block average THC
compliance option in Table unit controlling operating concentration"in the process unit exhaust
1A of this subpart,or a processparameter(s)within the ranges below the maximum concentration
nit that generates debits in an established during the performance established during the performance test.
emissions average without the test according to §63.2262(n)
se of a control device
§63.2262 How do I conduct performance tests and establish operating requirements?
(n)Establishing operating requirements for process units meeting compliance options without a control
device. If you operate a process unit that meets a compliance option in Table 1 A to this subpart, or is a process unit
that generates debits in an emissions average without the use of a control device,you must establish your process
unit operating parameters according to paragraphs(n)(1)through(2)of this section.
(1)During the performance test, you must identify and document the process unit controlling
parameter(s)that affect total HAP emissions during the three-run performance test. The controlling parameters
you identify must coincide with the representative operating conditions you describe according to
§63.2262(b)(2).For each parameter,you must specify appropriate monitoring methods,monitoring
frequencies, and for continuously monitored parameters,averaging times not to exceed 24 hours. The
operating limit for each controlling parameter must then be established as the minimum,maximum, range, or
average(as appropriate depending on the parameter)recorded during the performance test.Multiple three-run
performance tests may be conducted to establish a range of parameter values under different operating conditions.
(2)You may establish different controlling parameter limits for your process unit by submitting the
notification specified in§63.2280(g)and conducting a repeat performance test as specified in paragraph(n)(1)of
this section that demonstrates compliance with the compliance options in Table 1 A to this subpart or is used to
establish emission averaging debits for an uncontrolled process unit.
State of North Carolina Environmental Quality 1 Air Quality
1641 Mail Service Center 1 217 W.Jones Street,Suite 4000 1 Raleigh,NC 27699-1641
919 707 8400 T

Table 4 to Subpart DDDD of Part 63—Requirements for Performance Tests
For. You must . Using.
(1)each process unit subject to a select sampling port's location Method 1 or I of 40 CFR part 60,
compliance option in table 1 A or 1 B to and the number of traverse appendix A(as appropriate).
this subpart or used in calculation of an ports
emissions average under §63.2240(c)
(2)each process unit subject to a determine velocity and Method 2 in addition to Method 2A,2C,
compliance option in table IA or I to volumetric flow rate 2D,2F, or 2G in appendix A to 40 CFR
this subpart or used in calculation of an part 60 (as appropriate).
emissions average under §63.2240(c)
(3) each process unit subject to a conduct gas molecular weight Method 3, 3A,or 3B in appendix A to 40
compliance option in table I or I to analysis CFR part 60 (as appropriate).
this subpart or used in calculation of an
emissions average under §63.2240(c)
(4)each process unit subject to a measure moisture content of Method 4 in appendix A to 40 CFR part 60;
compliance option in table I or I to the stack gas OR Method 320 in appendix A to 40 CFR
this subpart or used in calculation of an part 63; OR ASTM D6348-03 (IBR, see
emissions average under§63.2240(c) §63.14(b)).
(6)each process unit subject to a measure emissions of total Method 320 in appendix A to 40 CFR part
compliance option in table 1 A to this HAP (as defined in §63.2292) 63; OR the NCASI Method IM/CAST/WP-
subpart; OR for each process unit used 99.02 (IBR, see §63.14(f)); OR the NCASI
in calculation of an emissions average Method ISS/FP-A105.01 (IBR, see
under§63.2240(c) §63.14(f)); OR ASTM D6348-03 (MR, see
§63.14(b))provided that percent R as
determined in Annex A5 of ASTM D6348-
03 is equal or greater than 70 percent and
less than or equal to 130 percent.
(10)each reconstituted wood product determine the percent a TTE and Methods 204 and 204A through
press at a new or existing affected capture efficiency 204F(as appropriate)of 40 CFR part 51,
source or reconstituted wood product appendix M. As an alternative to installing
board cooler at a new affected source a TTE and using Methods 204 and 204A
subject to a compliance option in through 204F,you may use the tracer gas
table IA to this subpart method contained in appendix A to this
subpart. Enclosures that meet the design
criteria(1)through(4)in the definition of
wood products enclosure,or that meet
:Method 204 requirements for a PTE (except
for the criteria specified in section 6.2 of
Method 204) are assumed to have a capture
efficiency of 100 percent.Measured
emissions divided by the capture efficiency
provides the emission rate.
(11)each process unit subject to a establish the site-specific data from the parameter monitoring
compliance option in tables IA and operating requirements system or THC CEMS and the
I to this subpart or used in (including the parameter applicable performance test method(s).
calculation of an emissions average limits or THC concentration
under§63.2240(c) limits)in table 2 to this
subpart

COMPLIANCE OPTIONS,OPERATING REQUIREMENTS,AND WORK PRACTICE REQUIREMENTS
§63.2240 What are the compliance options and operating requirements and how must I meet them?
You must meet the compliance options and operating requirements described in Tables IA, 1B, and 2 to this
subpart and in paragraph(c) of this section by using one or more of the compliance options listed in paragraphs(a),
(b), and(c)of this section. The process units subject to the compliance options are listed in Tables lA and 1B to
this subpart and are defined in §63.2292. You need only to meet one of the compliance options outlined in
paragraphs(a)through (c)of this section for each process unit. You cannot combine compliance options in
paragraph(a), (b),or(c) for a single process unit. (For example,you cannot use a production-based compliance
option in paragraph(a) for one vent of a veneer dryer and an add-on control system compliance option in paragraph
(b) for another vent on the same veneer dryer. You must use either the production-based compliance option or an
add-on control system compliance option for the entire dryer.)
(a) Production-based compliance options. You must meet the production-based total HAP compliance
options in Table 1A to this subpart and the applicable operating requirements in Table 2 to this
subpart.You may not use an add-on control system or wet control device to meet the production-based
compliance options.
Table 5 to Subpart DDDD of Part 63—Performance Testing and Initial Compliance Demonstrations for the
Compliance Options and O erating Requirements
For the following
compliance options and
operating requirements
For each. You have demonstrated initial compliance if. .
(1)Process unit listed in Meet the production-based The average total HAP emissions measured using the
Table I to this subpart compliance options listed methods in Table 4 to this subpart over the 3-hour
in Table 1 A to this subpart performance test are no greater than the compliance
option in Table 1A to this subpart; AND you have a
record of the operating requirement(s)listed in Table
2 to this subpart for the process unit over the
performance test during which emissions did not
exceed the compliance option value.
(6)Reconstituted wood Compliance options in You submit the results of capture efficiency
product press at a new or Tables lA and 1B to this verification using the methods in Table 4 to this
existing affected source, or subpart or the emissions subpart with your Notification of Compliance Status.
reconstituted wood product averaging compliance
board cooler at a new option in §63.2240(c)
affected source