AQ_F_0100237_20140826_CEM_RptRvwLtr (4)

Alk F74-9*
FqCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
August 26, 2014
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 2014 First Semester COMS Report
New South Lumber Company, Inc. —Graham Plant
Graham, Alamance County,North Carolina
Facility ID No. 0100237
Air Permit No. 06740T18
Dear Mr. Bishop:
Thank you for your timely submittal of the subject report dated July 24, 2014, from 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 first half of 2014.
The Division of Air Quality(DAQ) has completed its review of the COMS-related information
in the report 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 violations of the applicable
standard. Excess emissions from the wood-fired boiler 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 also 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 first
quarter, percent excess emissions (%EE) were reported as 0.13% and percent monitor
downtime (%MD) as 0.00%. For the second quarter, %EE was reported as 0.04% and%MD
as 0.00%. Thus, the COMS unit appears to indicate the use of good O&M practices since
quarterly %EE and%MD were less than 6% for any single calendar quarter and less than 3%
for two consecutive quarters.
1641 Mail Service Center,Raleigh,North Carolina 27699-1641
Phone:[phone] Internet:www.ncdenr.gov
An Equal Opportunity 1 Affirmative Action Employer—Made in part by recycled paper

Mr. Terry Bishop
August 26, 2014
Page 2
3. Finally, we wish to inform you that EPA has released a new QA/QC rule (40 CFR Part 60,
Appendix F, Procedure 3) for all COMS units subject to NSPS regulations. The effective date of
the new rule is November 12, 2014. A copy of the federal register notice (79 FR 28439) can be
found online. Essentially, the new federal rule establishes requirements for daily instrument zero
and upscale drift checks, daily status indicator checks, quarterly performance audits and annual
zero alignments. It also requires that source owners and operators have a corrective action
program in place for a malfunctioning COMS. The requirements contained in the new rule were
modeled after manufacturers' maintenance recommendations. Please include all quarterly and
annual audit results with your COMS excess emissions reports.
If you should have any questions, please contact me at [phone] or [e-mail].
Sincerely,
Alan Drake
Environmental Engineer
cc: Lisa Edwards, WSRO
Michael Pjetraj, RCO
Central Files, Alamance County
IBEAM (0100237)