AQ_F_0100237_20120220_CEM_RptRvwLtr

AT4 •0
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Air Quality
Beverly Eaves Purdue Sheila C. Holman Dee Freeman
Governor Director Secretary
February 20, 2012
Mr. Terry Bishop
General Manager
New South Lumber Company, Inc.—Graham Plant
4408 Mt. Hermon-Rock Creek Road
Graham,North Carolina 27253
SUBJECT: Review of 2011 Semiannual COMS Report, Second Half
New South Lumber Company, Inc.— Graham Plant
Graham, Alamance County,North Carolina
Facility ID No. 0100237; Air Permit No. 06740T17
Dear Mr. Bishop:
Thank you for your timely submittal of the subject report dated January 27, 2012. The report
included an assessment of the continuous opacity monitoring system (COMS) operating at the
New South Lumber Graham Plant during the second semester of 2011. The Division of Air
Quality (DAQ) has completed its review of the COMS-related information and offers the
following comments:
1. The report was reviewed for compliance with 20% opacity limit found at 40 CFR Part 60,
Subpart Dc and permit condition 2.1.B.2. There were no reported exceedances of the
applicable standard. For Boiler#4 (ID No. B-4), excess emissions were attributed to either
startup, shutdown, malfunction, or other exempt emissions. These emissions were reviewed
and allowed in accordance with applicable monitoring rules.
2. A review was conducted for compliance with good operation and maintenance (O&M)
practices pursuant to 40 CFR 60.11(d),NCAC 2D .0606,and permit condition 2.1.B.2. When
compared to the total operating time of the boiler during the third quarter, percent excess
emissions (%EE)were reported as 0.15% and percent monitor downtime(%MD) was reported
as 0.00%. For the fourth quarter, %EE was 0.41% and%MD was 0.00%. Thus,the COMS unit
appears to indicate the use of good O&M practices since quarterly %EE and %ND were less
than 6% for any single calendar quarter or less than 3%for two consecutive quarters. These
O&M indicators were within acceptable levels as prescribed in the permit and the North
Carolina continuous monitoring system enforcement policy (NCCEP).
Technical Services Section
1641 Mail Service Center,Raleigh,North Carolina 27699-1641 One
217 West Jones Street,Raleigh,NC 27603 North Carolina
Phone: [phone]/FAX [phone]/Internet: www.ncair.org Naturally
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%4 Post Consumer Paper

Mr. Terry Bishop
February 20, 2012
Page 2
If you should have any questions, please contact me at [phone] or alan.drake(c>>,ncdenr.gov.
Sincerely,
Alan Drake
Environmental Engineer
cc: Margaret Love, WSRO
Michael Pjetraj, RCO
Central Files, Alamance County
IBEAM(0100237)