AQ_F_1000067_20130930_CMPL_AltTMRR

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
September 30, 2013
Mr. David Groves
Facility Manager
CPI USA North Carolina Southport Plant
1281 Powerhouse Dr. SE
Southport, NC 28461
SUBJECT: Clean Air Act Section I I2j Monitoring Approval
Air Quality Permit No. 05 884T 13
CPI USA North Carolina Southport Plant
Facility ID: 1000067, Southport, Brunswick County
Facility Classification: Title V
Dear Mr. Groves:
The Division of Air Quality (DAQ)has reviewed and approves your request for using a
CO2 monitor and equations from 40 CFR Part 60 Appendix A, Method 19, in order to calculate
an emission rate corrected to 7% 02.
In your August 6, 2013 letter to Don van der Vaart, Permitting Chief, DAQ, you
requested that the DAQ approve the use of CO and CO2 analyzers measuring a diluted, wet
emissions stream in conjunction with equations 19-1 and 19-7 from Method 19. Your reasoning
was that the installation of dry CO and dry 02 monitors, associated sampling equipment and
treatment systems would be cost prohibitive when the alternative monitoring you proposed
would yield data that can be used to demonstrate compliance.
The DAQ has the authority to approve this monitoring for our state Clean Air Act (CAA)
section 1120) boiler standard that will be in effect for eight years from the 1120) permit
issuance. However, when your facility demonstrates compliance with the CAA Section I I2(d)
Boiler MACT on May 23, 2019, you will need to either install monitoring specifically required
in the Boiler MACT or petition the EPA for approval of alternative monitoring. Either of these
actions should be taken well in advance of May 2019 so that you will be able to demonstrate
compliance by May 23, 2019.
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.org
An Equal Opportunity 1 Affirmative Action Employer—Made in part by Recycled Paper

Mr. David Groves
September 30, 2013
Page 2
The approved equation to determine the CO emissions at 7% 02 using a wet CO and CO2
measurement is:
Fc 100 (20.9 — %02 correction)
Cd = Cw x Fd x %CO2w x 20.9
Where:
Cd=pollutant concentration, dry basis
Cw=pollutant concentration, wet basis
Fc=Method 19 carbon F-factor for wood
Fd=Method 19 wet F-factor for wood
%02 correction= 7%
This approved monitoring and calculations will need to be included in your Title V
permit. Please contact Michael Pjetraj (michael.pjetraignedenr. ov) (919-707-8497) if you
have any questions.
Sincerely
J�
Lee 7A. Daniel, Chief
Technical Services Section
I
cc: Don van der Vaart, Permitting Section Chief
Brad Newland, Supervisor, Wilmington Regional Office
Central Files