AQ_F_0100237_20081217_CEM_RptRvwLtr

6
North Carolina Department of Environment and Natural Resources
Division of Air Quality
Michael F. Easley, Governor William G. Ross, Jr., Secretary
B. Keith Overcash, P.E., Director
December 17, 2008
Mr. Donald E. Olson
Chief Operating Officer
New South Lumber Company, Inc. — Graham Plant
4408 Mt. Hermon-Rock Creek Road
Graham, North Carolina 27253
Dear Mr. Olson:
SUBJECT: 2008 Semiannual Report, First Semester;
Certification Report for COMS on Boiler#4; and
Compliance,Monitoring and Reporting Requirements
Facility ID: 0100237
New South Lumber Company, Incorporated—Graham Plant
Alamance County
Dear Mr, Olson:
Thank you for your timely submittal of the subject report, received on July 31, 2008. The Division
of Air Quality (DAQ) has reviewed the report and offers the following comments:
COMS Certification
The Continuous Opacity Monitoring System(COMS) certification report was submitted by New
South Lumber—Graham Plant for the following unit:
Source ID Manufacturer Model / Serial No. Parameter
Boiler#4 Exhaust Stack Teledyne Monitor Labs 560/ 5601529 Opacity
The certification report review addressed three key elements of 40 CFR 60, Appendix B, Performance
Specification 1 (PS-1), namely: 1)design specification of ASTM D 6216-98, 2) manufacturer's
performance specification of ASTM D 6216-98, and 3) field audit performance specification. The
COMS unit appears to meet the above key elements of PS-1 and therefore, the certification report is
hereby accepted. Since Calibration Drift(CD)was successfully tested from January 9, 2008 until
January 16, 2008, the COMS unit is certified effective January 16, 2008.
Technical Services Section One
1641 Mail Service Center,Raleigh,North Carolina 27699-1641 NorthCarolina
2728 Capital Blvd. Raleigh,North Carolina 27604 NaturallyPhone: 919-733-1728/FAX [phone]/Intemet: www.ncair.org
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper

Mr.Donald E.Olson
December 17,2008
Page 2
No component of the COMS may be substituted or added for opacity measurement at the Boiler #4
Exhaust Stack without DAQ notification. Depending on the component, the COMS unit may need to
be recertified.
Monitoring & Reporting Requirements
The mandatory monitoring and reporting requirements for opacity data collected by the COMS on
Boiler #4 Exhaust Stack are specified in 40 CFR 60, Subpart A, Section 60.7(c)&(d) and 40 CFR 60,
Subpart Dc, Section 60.47(c) and 60.48(c). Most of these requirements can be summarized in the
attached excess emissions summary forms. We encourage you to use the forms in submitting required
information. Please feel free to modify the forms in order to accommodate any additional information
that you are required to report. Excess emission reports are due to this office by the 30th day
following the end of the reporting period. Applicable rules and NC G.S. 143-215.65 require that you
submit excess emissions reports (EER) quarterly even though Title V permits often specify semiannual
reporting. Because of these dual requirements, we are asking sources to submit their EERs quarterly.
However, when the percent excess emission (%EE) or percent monitor downtime (%MD) do not
exceed the acceptable target criteria described in the Compliance Demonstration below.
Compliance Demonstration
We use the emission information submitted during the reporting period to make two assessments of
compliance. The first assessment is to evaluate compliance with the underlying emission standard (i.e.,
6-minute average opacity not to exceed 20%except for one 6-minute period per hour of not more that
27%)pursuant to Section 60.43c(c) and Air Quality Permit No.06740T13, Condition 2.1 B.2. In
making this initial assessment for opacity, we exempt excess emissions due to startup (SU), shutdown
(SD) and malfunctions. Any other non-exempt emissions are considered a violation of the underlying
standard. DAQ may pursue enforcement action beginning with a Notice of Violation (NOV) and may
also pursue civil penalties/injunctive relief for non-exempt emissions as applicable.
The second assessment is an evaluation of a facility's compliance with good operation and
maintenance (O&M) practices pursuant to CFR 60.11(d). In this assessment, all excess emissions,
including those from SU, SD, and malfunctions are included (i.e., no exemptions). DAQ uses
enforcement discretion to evaluate and determine proper O&M practices. A facility shall be deemed to
have good O&M practices if the quarterly %EE and/or%MD are less than 6% for one calendar quarter
or less than 3% for two consecutive quarters. See the attached quarterly EER forms on how to
calculate %EE and %MD. If any of the above percentages are exceeded, DAQ may pursue
enforcement action beginning with an NOV and may also pursue civil penalties/injunctive relief for
improper O&M practices and/or monitor performance, as applicable.
Quality Assurance
All installed monitors are required to be regularly calibrated,maintained and audited to ensure the data
produced by the monitor is valid. A Quality Assurance Program(QAP) is used to accomplish this task
and is required under 15 NCAC 2D.0613. The QAP should be developed, implemented and made
available on-site for inspection no later than 30 days after COMS certification. The COMS
manufacturer's manual could be used for calibration and maintenance of the monitor and referenced as
part of the QAP.

Mr.Donald E.Olson
December 17,2008
Page 3
The CEM group routinely inspects monitors installed within the state to ensure that they are
adequately calibrated and maintained. During such inspection we typically review records pertaining
to COM data, calibrations and maintenance records as well as emission and audit reports submitted to
DAQ. This information is also required to be kept on-site for at least two years as specified by the
general provisions of 40 CFR 60, section 60.7(f).
2008 Semiannual Report
Through discussions with Mr. Terry Bishop of your staff, DAQ has determined that excess opacity
emissions presented in your first semiannual report will not be reviewed for compliance with
underlying standards and for good O&M practices since the COMS unit was operating during the
boiler's shakedown period involving initial testing and certification of the boiler. The COMS unit
was tested and calibrated on December 18, 2007, and completed calibration drift on January 16,
2008. Boiler #4 successfully passed stack testing on May 9, 2008. However, beginning with the
second semester 2008 semiannual report, we expect you to submit excess emission reports as
specified in your operating permit and this letter. The report will be reviewed for compliance with
the aforementioned regulations.
If you should have any questions, please call me at [phone].
Sincerely,
Alan Drake
Environmental Engineer
Attachments: Quarterly Excess Emissions Report for COMS;
Quarterly Excess Emissions and Monitoring Systems Incident Report
cc: Mike Landis, MRO
Michael Pjetraj
Central Files, Rowan County
IBEAM (8000003)

Attachment 1: uarterl Excess Emission Re ort for Continuous Opacity MonitoringSystems
Quarter/Year
Company/Address
Process Unit Name/Description
Pollutant/Diluent/Emission Limit
Averaging Time Increment
Monitor Mfg/Model No./Serial No.
Date of Latest COMS Certification/Audit
Total Source Operating Time(Minutes)
Emission Data Summary
1.)Duration of Excess Emissions in Reporting Period Due To:
Incident Code Periods(6-Minutes)
A: Startup/Shutdown 1
B: Control Equipment Problems 2
C: Process Problems 3
D: Other Known Causes 4
E:Unknown Causes 5
2.)Total Duration of Excess Emissions (Sum of A, B,C,D&E)
3.)Percent Excess Emissions(%EE) /EE= Periods of Excess Emissions x 6 x loo
Total Source Operating Time-Monitor Downtime
Monitor Performance Summary
1.)Monitor Downtime in Reporting Period Due To:
Incident Code Periods(Minutes)
A: Monitor Equipment Malfunctions 6
B:Non-Monitor Equipment Malfunctions 7
C: Quality Assurance Procedures 8
D: Other Known Causes 9
E: Unknown Causes 10
2.)Total Duration of Monitor Downtime (Sum of A,B,C,D&E)
Minutes of Monitor Downtime
3.)Percent Monitor Downtime(%MD) %MD= x100
Total Source Operating Time
I certify that the information contained in this report is true,accurate and complete.
Name (Print) Title
Signature Date
To Be Completed By State Agency
Date Postmarked/Due IBEAM
Status

Attachment 2: Quarterly Excess Emissions and Monitoring Systems Incident Report
Quarter
Company
Pollutant
Total Source Operating Time
Date Time of Incident Duration Average Explanation of Incident and any
Month/Day (Start—Finish) (Minutes) Emission Corrective Actions Taken