AQ_F_1900015_20140602_CMPL_DOE

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NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
June 2, 2014
Mr. Tom Quesenberry
Site Manager
Arauco Panels USA LLC
985 Corinth Road
Moncure, NC 27559
SUBJECT: Deferral of Enforcement—Wet Electrostatic Precipitator (WESP) Test Program
Air Quality Permit No. 03449T43
Arauco Panels USA LLC
Facility ID: 1900015, Moncure, Chatham County
Facility Classification: Title V
Dear Mr. Quesenberry:
This office is in receipt of your May 21, 2014 letter requesting a deferral of enforcement for
testing the WESP while controlling the two dryers (ID 1430 SL Dryer and ID 1420 Core Dryer) and
while allowing the "Wellons" Burner (ID No. 3201)to operate uncontrolled and the associated
excess emissions that may occur during the demonstration program. My staff has been in
communications with your environmental staff regarding this request over the past two weeks.
The Wellons (combusting wood) and the two dryers (combusting sander dust) contribute to
the particulate matter (PM) loading on the WESP and therefore contribute to the visible emissions
(VEs) from the WESP. Arauco's intent is to comply with the VE standard and complete the Special
Order by Consent (SOC) by combusting natural gas in the Wellons unit, which will produce very
low PM emissions. The WESP would then be able to control the PM emissions from the two dryers
and comply with the VE standard.
In order to convert the Wellons unit to natural gas, Arauco will need to rebuild the Wellons
natural gas burner. Prior to investing the capital expenditure on the burner, Arauco wants to
evaluate if the WESP can adequately control the PM loading from just the two dryers combusting
sander dust.
On February 25, and March 21, 2014, DAQ issued similar Deferrals of Enforcement for the
Wellons unit. According to your May 21,,2014 letter, Arauco plans to upgrade the pumps
supplying quench water to the WESP which will increase the total waterflow to the WESP on or
about June 4, 2014. Upon completion of the pump upgrades, Arauco has requested to operate the
Wellons unit uncontrolled so as to remove the particle loading from the WESP control system.
Arauco plans to perform the testing during the June 9-13, 2014 time frame.
1641 Mail Service Center,Raleigh, North Carolina 27699-1641
Phone:[phone] Internet:www.ncdencgov
An Equal Opportunity 1 Affirmative Action Employer-Made in part by recycled paper

Mr. Tom Quesenberry
June 2, 2014
Page 2
Therefore, DAQ will defer enforcement for the purpose of operating the Wellons unit
uncontrolled, while combusting hog fuel, for a period not to exceed two hours once the WESP
pumps have been upgraded. The deferral will also cover the expected excess emissions of PM and
associated VEs, as well as elevated levels of formaldehyde from the combustion of wood residuals
since the effluent stream will not be treated in the WESP.
However, the permit deviation of operating the Wellons unit uncontrolled as well as any
associated excess emissions shall be noted on your Title V semi-annual deviation report and your
Annual Compliance Certification.
Please notify Patrick Butler, Raleigh Regional Office Supervisor(919-791-4200) of the day
you intend to perform the test so that he can schedule a staff member to attend.
If you have any questions with reference to this matter, please do not hesitate to contact
Michael Pjetraj, P.E. at [phone].
Sincerely,
Sheila C. Holman, Director
Division of Air Quality, NCDENR
cc: Patrick Butler, P.E.,—DAQ Raleigh Regional Office Supervisor
Michael Pjetraj, P.E. — SSCB Supervisor
Central Files
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