AQ_F_1900015_20140224_CMPL_Fac-Ltr

� 985 Corinth Road
(Plakeboard M l:919- , North Carolina 27559
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Toll Free:855-427-2826
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February 21, 2014
Mr. Michael Pjetraj, P.E. f
NCDENR—Division of Air Quality F F B Z 4 2�14
217 West Jones Street
1641 Mail Service Center
Raleigh, NC 27699-1641
r
Subject: Deferral of Enforcement Request—Wellons Wood Furnace Bypass
Moncure, Chatham County, North Carolina
Air Permit#03449T43
Dear Mr. Pjetraj:
As you are aware,Arauco's Moncure, North Carolina facility entered in to Special Order by Consent 2013-002 on June 3`",
2013 due to violation of Title V 03449 condition 2.1.F.5.a limiting the particleboard dryers to 20%opacity emissions. The
Wet ESP unit is controlling the emissions from three wood combustion units:the Wellons furnace used to heat thermal oil
for the particleboard press and two furnish dryer burners. The Wellons unit burns primarily hog fuel while the dryer
burners burn sanderdust, a byproduct of the particleboard sanding process.
In an effort to attain the 20%opacity limit,Arauco staff recently permitted an existing Wellons natural gas burner that had
not been commissioned or permitted since the 1987 startup of the Particleboard facility. The Wellons natural gas burner
permit was issued on January 10, 2014. Now, the Wellons has three permitted operating scenarios: combust wood with
emissions directed to dryers controlled by Wet ESP, combust natural gas with emissions directed to dryers controlled by
Wet ESP, and combust natural gas with emissions vented to atmosphere.
Deferral of Enforcement
Arauco has recently received proposals for rebuilding and refurbishing the natural gas burner in the Wellons unit. Prior to
performing this work,Arauco would like to attempt to run the Wellons while firing wood in bypass to see if the Wet ESP,
while controlling PM from the two dryers combusting sanderdust, can meet the 20%opacity limit. The Wellons is currently
subject to 40 CFR 63 Subpart DDDD PCWP MACT as the wood-fired operating scenario emits through PCWP MACT
equipment and is controlled by PCWP MACT control devices. The formaldehyde emitted from the combustion of wood
residuals will not be controlled. The Wellons burner is subject to 15A NCAC 2D.0516 SOZ emission limits for combustion
devices but should not violate this standard due to inherently low sulfur content in wood fuels. The Wellons is also subject
to the particulates emission standard for wood-burning indirect heat exchangers 15A NCAC 2D.0504. This emission
source has never been source tested so there is a potential to exceed 0.365 total particulate Ibs/MMBtu heat input during
this test event. The emissions from the Wellons in bypass will also potentially exceed the 20%opacity limit set by 15A
NCAC 2D.0521.
Arauco requests a deferral of enforcement for any excess emissions caused by the bypass of the Wellons stack during a
testing period preferably to occur within the next two weeks pending the weather(February 24th-March 7th) not to exceed 2
hours.Arauco has several Method 9 certified observers that will perform Method 9 observations during the trial.
If you have any questions related to this request, please do not hesitate to contact John Bird, Moncure's EHS Manager at
919-642-6658.
Sincerely,
Tom Quesenberry
Site Manager