AQ_F_0100237_20130212_CEM_RptRvwLtr

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Air Quality
Pat McCrory Sheila C. Holman John E. Skvarla, III
Governor Director Secretary
February 12, 2013
Mr. Terry Bishop
General Manager
New South Lumber Company, Inc. —Graham Plant
4408 Mt. Ilermon-Rock Creek Road
Graham,North Carolina 27253
SUBJECT: Review of 2012 Second Semester COMS Report
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 21, 2013, from the New
South Lumber's Graham Plant. The report included an assessment of the continuous opacity
monitoring system (COMS)that operated on Boiler#4 (ID No. B-4) during the second half of
2012. 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 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),40 CFR 60.13,permit specific condition 2.1.B.2, and
general condition F. When compared to the total operating time of the boiler during the third
quarter, percent excess emissions (%EE) were reported as 0.47% and percent monitor
downtime (%MD) as 29.6%. For the fourth quarter, %EE was.reported as 0.18%. and%MD
as 0.0%.
DAQ considers sources whose %EE or %MD are greater than 6% for any single calendar
quarter or greater than 3%for two consecutive quarters to have operated with poor O&M
practices; therefore, an enforcement action beginning with a Notice of Violation (NOV)
Technical Services Section
1641 Mail Service Center,Raleigh,North Carolina 27699-1641
217 West Jones Street,Raleigh,North Carolina 27603
Phone:[phone]/Fax:[phone]
Internet:www.ncair.oLg
An Equal Opportunity 1 Affirmative Action Employer—Made in part by Recycled Paper

Mr. Terry Bishop
February 12, 2013
Page 2
will likely be issued for excessive monitor downtime (29.6%) for the third quarter of
2012.
If you should have any questions,please contact me at [phone] or [e-mail].
Sincerely,
C7J—�-_
Alan Drake
Environmental Engineer
cc: Margaret Love, WSRO
Michael Pjetraj, RCO
Central Files, Alamance County
IBEAM (0100237)