AQ_F_1900015_20220202_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Raleigh Regional Office WTW
AIR QUALITY Arauco North America,Inc.
NC Facility ID 1900015
Inspection Report County/FIPS: Chatham/037
Date: 02/02/2022
Facility Data Permit Data
Arauco North America,Inc. Permit 03449/T55
985 Corinth Road Issued 6/9/2021
Moncure,NC 27559 Expires 6/30/2021
Lat: 35d 36.0910m Long: 79d 2.6020m Class/Status Title V
SIC: 2493/Reconstituted Wood Products Permit Status Active
NAILS: 321219/Reconstituted Wood Product Manufacturing Current Permit Application(s)TV-
Administrative,TV-Renewal
Contact Data
Facility Contact Authorized Contact Technical Contact Program Applicability
Savannah Carroll Jeff McMillian Savannah Carroll SIP/Title V/PSDMALT Part 63: Subpart DDDD, Subpart
Regional Env.Manager Plant Manager Regional Env.Manager DDDDD, Subpart ZZZZ
[phone] [phone] [phone] NSPS: Subpart Dc, Subpart IIII
Compliance Data
Comments: Compliance inspection—Appears to be in compliance.
Inspection Date 02/02/2022
Inspector's Name Jeff Harris
Inspector's Signature: C Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature:02/04/2022 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2020 158.19 7.58 111.15 600.67 194.33 146.58 454362.98
2019 156.92 13.61 280.04 1260.94 579.34 156.92 570093.60
2018 131.05 13.75 245.13 985.75 493.30 130.56 466116.06
*Highest HAP Emitted inpounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
11/09/2020 NOV 2D.0530 Prevention of Significant Deterioration 11/14/2020
06/05/2019 NOV/NRE Part 63 -NESHAP/MACT Subpart DDDD Plywood and 07/01/2019
Composite Wood Products
06/05/2019 NOV/NRE 2D.0530 Prevention of Significant Deterioration 07/01/2019
06/05/2019 NOV/NRE Permit Permit Condition 07/01/2019
04/20/2017 NOV/NRE 2D.0521 Control of Visible Emissions 05/12/2017
04/20/2017 NOV/NRE 2Q.0317 Avoidance Conditions 05/12/2017
04/20/2017 NOV/NRE 2D.1111 Maximum Achievable Control Technology 05/12/2017
04/20/2017 NOV/NRE 2D.0530 Prevention of Significant Deterioration 05/12/2017
04/20/2017 NOV/NRE 2D.0512 Particulates from Wood Products Finishing 05/12/2017
Plants

Performed Stack Tests since last FCE:
Date Test Results Test Method(s) Source(s)Tested
10/21/2021 Compliance Method 202,Method 25A,Method 320,Method 5, ES-01
Method 7E,Method OTM-26
(I)DIRECTIONS: Arauco Panels USA is located at 985 Corinth Road, Moncure,NC, Chatham County. From
Raleigh, take US-1 South toward Sanford. Just over the Chatham County line, exit onto Old US-1 (SR-1011)
and turn south (right). Travel approximately 3 miles, turn left onto Corinth Road(SR-1916), and the plant will
be approximately '/2 mile on the left. Sign in at the log cabin.
(II) FACILITY DESCRIPTION: Arauco Panels USA LLC manufactures medium density fiberboard(MDF)
which is primarily sold to the furniture and flooring industry. The facility runs seven days a week using two 12-
hour shifts.
The COVID-19 Pandemic in 2020 impacted Arauco production significantly, and they ceased particleboard
operation in April 2020 after over 40 years. Additionally, as documented in a minor permit modification
application in February 2021, the site commissioned a second moulding line operation, which was incorporated
into air permit 03449T54 and T55. NCDEQ was notified of the commissioning of this system(ES-M1B) as
required on July 23, 2021.
The MDF plant was built from new and refurbished equipment. Some of the refurbished equipment originated
from a closed plant in Quebec. The MDF plant can also produce high density fiberboard (HDF). When making
MDF, the plant uses 100% southern pine chips according to the staff. HDF is 60%hardwood and the balance is
pine. The HDF is mainly used for flooring. The MDF/HDF plants utilize wood chips to form the boards. The
first MDF board from the new plant was processed on February 17, 2010.
In the MDF plant, the boards are pressed to varying thicknesses and widths. The continuous MDF press is able
to form boards with thickness ranging from 3.0 min to 28 min and with widths from 2.45 to 3.15 meters (8 to
10.3 feet). The MDF press operates at—500°F.
Safety Note: Standard safety equipment is sufficient at this facility, including hard hat, steel toed shoes, hearing
protection, and vision protection. Due to truck traffic, wear a visibility vest when walking outside around the
plant grounds.
(III)INSPECTION SUMMARY: On February 2, 2022, I (Jeff Harris) arrived to perform a compliance
inspection and met with the Facility Contact, Ms. Savannah Carroll, EHS Manager, Environmental Manager.
We began the inspection by touring both the MDF plant and the new MDF moulding line operations. The MDF
plant, including the new moulding line were in operation. Moulding line 3 has been permitted but is not yet
constructed. Construction is currently on hold but is still planned. The new molding line started up in September
2020. No visible emissions were observed. Overall, the facility appeared to be well maintained and being
operated in accordance with air quality regulations. Record review was performed via e-mail prior to the on-
site visit, due to the ongoing COVID-19 pandemic. The records appeared to be well maintained and complete.
Ms. Carroll stated that due to market and labor constraints, the Laminating Mill Gas-Fired Oil Heater Sources
(Pr-Heat-1), Laminating Mill Sources (Presses 3593, 3594) Fabric Filters, and Wellons Unit were not in
operation. The Laminating Line has not been operational since 2019. Likewise, the Wellons unit(Unit ID

3201) has not been in operation since 2019. The site is preparing to re-commission the sources for operation,
but the lamination operation is currently not running and has not been in production or operation in over two
years. Only one of the Laminating Presses will be recommissioned. The other unit is no longer operational,
having been used for parts. The Old PB source (Rock/Metal Separator)was not in operation in 2021.
(IV) PERMITTED EMISSION SOURCES: At the time of this inspection, Arauco was operating under Air
Permit No. 03449T55, which became effective on June 09, 2021, expires on June 30, 2021, and includes the
following emission sources and control devices:
A. Material Handling Sources:
-Truck/rail chip handling system (ID No. 7001 or SP-1);
-Truck/rail sawdust handling system (ID No. 7004 or SP-2);
-Particleboard mill truck dump (ID No. 7010);
-Dump bunkers and CL dryer dump (ID Nos. 7012, 7014, 7015, and 7029);
-Wood residue bunkers (ID Nos. 7052, 7054, 7055 and 7056);
-Wood chip piles -medium density fiberboard mill (ID Nos. 6001, 7002-A, 7002-B, 7002-C,
and 7002-D);
-Wood fuel pad and boiler transfers (ID Nos. 6003, 7006, 7007, 7022);
-Sawdust transport to A frame (ID Nos. 7005-D, 7005-E, 7005-F, 7005-G);
-Fuel sawdust and chip storage piles (ID No. SP);
-Scale transfer conveyors (ID No. 7025);
-Fiber dump and reject filter bins (ID Nos. 7019 and 7026);
-Hog fuel hopper(ID No. 7027);
-Particleboard mill chip transfer(ID Nos. 7040, 7044, 7046, 7048, and 7050); and
-Particleboard mill feed lines (ID No. 7024).
B.Medium Density Fiberboard Mill:
-Refiner (ID No. ES-01) and associated refiner abort cyclone (ID No. CD-01) and two
venturi/packed bed scrubbers (ID Nos. CD-02, CD-14);
-Three natural gas-fired hot oil heaters (24 mm/Btu per hour, ID Nos. ES 18, 19, 20);
-Energy System consisting of one dry/wet woodwaste-fired burner (205mm Btu per hour, ID
No. ES02-A) controlled by one Urea/water injection system (ID No. CD-02A) and two
venturi/packed bed scrubbers (ID Nos. CD-02, CD-14);
-Two stage dryer system (ID No. ES-02-B) and two backup natural gas-fired dryer burners
(78.5 and 17 mm Btu per hour, ID Nos. ES-02-C, ES-02-D);
-MDF Press and Press Hall (ID ES-16) controlled by one venturi scrubber and biofilter
(ID No. CD-02 and CD-18; and CD-14 and CD-18);
-MDF Board Cooler(ID ES-06-B) controlled by two venturi/packed bed scrubbers (ID
Nos. CD-02, CD-14);
-Fiber Sifter System (ID No. ES-03) controlled by one fabric filter (ID No. CD03);
-Forming Line Clean-Up System (ID No. ES-04) controlled by one fabric filter(ID No.
CD04);
-Mat Reject System (ID No. ES-05) controlled by controlled by one fabric falter (ID No.
CD05);
-Saw System (ID No. ES-07) controlled by one fabric falter (ID No. CD07);
-Sander System No. I (ID No. ES-08) controlled by one fabric falter (ID No. CD08);

-Recycled Fiber Silo No. I (ID No. ES-09) controlled by bin vent falter (ID No. CD09);
-Sander System No. 2 (ID No. ES-10) controlled by one fabric falter(ID No. CD10);
-Sander Dust Silo No. I (ID No. ES-12) controlled by bin vent filter(ID No. CD12);
-Dry Sawdust Silo (ID No. ES-13) controlled by one bin vent(ID No. CD13);
-Recycled Fiber Silo No. 2 (ID No. ES-15) controlled by one bin vent falter (ID No. CD15);
-Sander Dust Silo No. 2 (ID No. ES-17) controlled by one bin vent falter (ID No. CD17);
-Diesel Fuel-Fired Emergency Generator (1592 Brake Horsepower output) (ID ES-21);
C. MDF Moulding Line:
-MDF moulding line- moulding zones (ID No. ES-MIA, M2A, M3A) controlled by Reverse
flow bag filter (ID No. CD- 4005)
-MDF moulding line—coating and drying zones (ID No. ES-MI B, M2B, M3B)
-MDF moulding line shavings silo (ID No. ES-MSSI) controlled by Cartridge falter (ID No.
CD-MSSI)
D. Old Particleboard Mill.
-Sawdust rock and metal separator(ID No. 3501) and associated cyclone (ID No. CD-SC)
and bagfilter (ID No. CD- 3501);
E. Laminating Mill.
-Two short cycle laminating presses (ID Nos. 3593 & 3594) and associated bagfilter (ID
No. CD-3593); and
-Natural gas and No. 2 oil-fired thermal oil heater (ID No. Pr-Heat]).
The MDF plant, including the new moulding line were operating at the time of the inspection,but the
particleboard plant has been shutdown permanently since April 2020, and most of the equipment removed
from the revised permit. All facility emission sources were observed, and most sources were in operation.
Overall, the equipment appeared to be well maintained.
(V) PERMIT STIPULATIONS: As is the case with all Title V permits, Air Quality Permit No. 03449T55 lists
all of the air quality regulations that apply to each of the permitted emission sources. To avoid redundancy in
this report, the applicable air quality regulations are discussed individually, and all of the permitted emission
sources that are subject to a specific regulation are noted.
(1) 15A NCAC 2D .0503:PARTICULATES FROM FUEL B URNING INDIRECT HEAT EXCHANGERS- The
following emission sources are subject to 2D.0503: The thermal oil heaters (MDF Plant—ID Nos. ES-18, ES-
19, ES- 20), thermal oil heater(Laminating Plant-ID No. Pr-Heat].
Appears to be in compliance - The particulate emission limit for the subject sources when burning natural gas
or fuel oil is 0.35 pounds per million Btu heat input for the MDF plant thermal oil heaters and 0.60 pounds per
million Btu heat input for the particleboard thermal oil heater. When these combustion sources are burning
natural gas or fuel oil, the 15A NCAC 2D .0503 particulate emissions standard should be achieved during
normal operating conditions. To estimate the degree of compliance, emission factors from the NC DAQ's Fuel
Oil Combustion Spreadsheet were used. The estimated particulate emission rate for No. 2 fuel oil combustion

in these units would be 0.034 pounds per million Btu, well below the limit. Particulate emission rate from
natural gas combustion would be significantly less than the emissions from fuel oil combustion.
No particulate emission testing is required by this regulation. Additionally, no monitoring/record
keeping/reporting is required for particulate emissions from the firing of natural gas or fuel oil in these
combustion sources.
(2) 15A NCAC 2D .0512:PARTICULATES FROM MISCELLANEOUS WOOD PRODUCTS FINISHING
PLANTS— The following emission sources are subject to 2D.0512: Fiber Sifter System (ID No. ES-03),
Forming Line Clean-Up System (ID No. ES-04), Mat Reject System (ID No. ES-05), Saw System (ID No. ES-
07), Sander System No. I (ID No. ES-08), Recycled Fiber Silo No. (ID No. ES-09), Sander System No. 2 (ID No.
ES-10), Sander Dust Silo No. I (ID No. ES-12), Dry Sawdust Silo (ID No. ES-13), Recycled Fiber Silo No. 2
(ID No. ES-15), Sander Dust Silo No. 2 (ID No. ES-17), Sawdust Rock and Metal Separator(ID No. 3501),
MDF moulding lines 1-3 Moulding Zones (ID Nos. ES-MIA, ES-M2A, ES-M3A), MDF moulding lines 1-3
coating and drying zones (ID Nos. ES-MI B, ES-M2B, ES-M3B), MDF moulding line shavings silo (ID No. ES-
MSSI).
Appears to be in compliance - In accordance with 15A NCAC 2D .0512, the permittee shall not cause, allow,
or permit particulate matter caused by the working, sanding, or finishing of wood to be discharged from any
stack, vent, or building into the atmosphere without providing, as a minimum for its collection, adequate duct
work and properly designed collectors. To comply with this regulation, the facility must conduct monthly and
annual inspections of the ductwork and control devices, record the results of these inspections in a logbook, and
submit a deviation report to DAQ on a semiannual basis. A review of the records indicated that the facility has
been performing the required monthly and annual inspections since the last DAQ inspection. The most recent
MDF plant annual inspections were conducted in October 2021.
During the plant tour, observations indicated that the ductwork and control devices appeared to be in good
physical condition. No emission source subject to 15A NCAC 2D .0512 was observed in operation without its
respective control device. The submission of semiannual reports has been performed as prescribed in the
permit.
(3) 15A NCAC 2D .0515:PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES- The
following emission sources are subject to 2D.0515:Refiner(ID ES-01), Energy System (ID ES-02-A), Two
stage dryer system and backup dryer burners (ID ES-02-B, ES-02-C, ES-02-D), MDF Board Cooler(ID ES-06-
B), MDF Press (ID ES-16), MDF moulding lines 1-3 Moulding Zones (ID Nos. ES-MIA,ES-M2A,ES-M3A),
MDF moulding lines 1-3 coating and drying zones (ID Nos.ES-MIB,ES-M2B,ES-M3B),MDF moulding line
shavings silo (ID No.ES-MSSI).
Appears to be in compliance - The particulate emission limit for each of the subject emission sources is
determined based on the individual process throughput(weight)rates for each source.
The MDF plant installed control devices throughout the facility to help meet applicable emission standards.
The facility installed two parallel sets of venturi/packed bed scrubber combinations (CD02, CD14). These units
are connected to the refiners, the main energy system, the two-stage dryer system, and the board cooler. The
venturi scrubbers are primarily particulate control devices. To help monitor the efficiency of these venturi

scrubbers, the permit requires that 3-hour block averages be recorded on the pressure drop and the recirculating
liquid flow of the units.
According to a November 4, 2014 MDF dryers stack test report, the process rate was 67.32 tons per hour and
the total particulate emission rate was 15.32 pounds per hour. Using the equation for processes with
throughputs greater than 30 tons per hour, the calculated emission limit according to 2D .0515 is 47.39 pounds
per hour. The MDF Energy System/dryers are required to perform annual particulate testing (at emission points
- EP02, EP 14). If the results of the test are less than 80% of the limit, the testing frequency can be changed
from annual to every five years. The test results of 15.32 lb/hr is 32% of the limit (47.39 lb/hr).
The MDF plant is operating a biofiltration system (Control Device ID No. CD18) for the MDF plant. The
biofilter had not been achieving the required BACT VOC destruction efficiency under a prior SOC. Contractor
remediation work of the biofilter was completed on December 4, 2019 as required by the prior SOC. A new
SOC was signed on September 10, 2020.
To ensure ongoing compliance with the 15A NCAC 2D .0515 emissions standard, the permit requires that the
each of the subject emission sources be controlled by the associated particulate control devices (cyclones,
multicyclones, and wet scrubber) as listed in the permit during all periods of operation. All the particulate
control devices that were observed during the inspection appeared to be in good physical condition, and no
emission source was observed in operation without its respective particulate control device. Upon request, the
facility provided records demonstrating that the required monitoring and recordkeeping was being conducted as
described in the permit. The submission of semiannual reports has been performed as prescribed in the permit.
(4) 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES- The following
emission sources are subject to 2D.0516: The Energy System (ID No. ES-02-A) and the two-stage dryer system
(ID No. ES-02-B) with two backup natural gas-fired burners (ID Nos. ES-02-C-1 and-2 and ES-02-D), MDF
moulding lines 1-3 coating and drying zones (ID Nos. ES-MIB,ES-M213,ES-M313), thermal oil heaters (MDF
Plant—ID Nos. ES-18, ES-19, ES-20), thermal oil heater (ID No. Pr-Heatl), emergency generator(ES-21), and
emergency generator(ES-ODG).
Appears to be in compliance - The sulfur dioxide emission limit for each of the subject emission sources is 2.3
pounds per million Btu heat input. Since the facility burns exclusively natural gas,No. 2 fuel oil, and wood fuel
in its combustion equipment, the 15A NCAC 2D .0516 sulfur dioxide emissions standard should be achieved
during normal operating conditions. No sulfur dioxide emission testing is required by the facility's air permit.
Additionally, no monitoring/record keeping/reporting is required for sulfur dioxide emissions from the firing of
natural gas, fuel oil, or wood fuel in the combustion units.
(5) 15A NCAC 2D .052 1: CONTROL OF VISIBLE EMISSIONS-All of the permitted emission sources are
subject to 2D.0521.
Appears to be in compliance - The visible emission limit for all plant emission sources is 20 percent opacity.
Visible emissions testing (Method 9) is not required by the facility's air permit. The permit requires the facility
to perform visible emission observations (checking for above-normal opacity) on the affected equipment, record
the results of the evaluations in a logbook, and submit a summary report of the observations on a semiannual
basis. If the opacity appears above-normal, the facility is required to either correct the condition causing the
above-normal visible emissions or to perform an official Method 9 test to determine the opacity of the plume.

During the record reviews of the visible emission observations of the MDF dryers' emission points, all weekly
observations indicated that no opacity was logged at being over 20%. The submission of semiannual reports
has been performed as prescribed in the permit.
According to the air permit, weekly visible emissions monitoring is required for the applicable sources.
Records were provided which indicated that all the opacity readings were being performed as required.
(6) 15A NCAC 2D .0524:NEW SOURCE PERFORMANCE STANDARDS(40 CFR 60, Subpart Dc): The
following emission sources are subject to 2D.0524:Hot Oil Heaters (ID ES-18, ES-19, ES-20).
Appears to be in compliance -As with other NSPS regulations, applicable sources are required to give
construction and startup notifications. The construction notification was sent in April 2009. The startup
notification was sent in January 2010. The only other requirement for this unit under this regulation is
recording the monthly fuel usage. The MDF plant has only one gas meter that measures fuel usage for both the
backup gas dryer burners and the three Ness burners (hot oil heaters). Usually when the Ness burners are
operating, the backup dryer burners are also operating. When both units are operating, the fuel usage for
individual units can be estimated by using the known fuel usage ratios for the dryer and the hot oil heaters. The
facility provided records demonstrating that they are tracking fuel usage as required.
(7) 15A NCAC 2D.0524:NEW SOURCE PERFORMANCE STANDARDS(40 CFR 60, Subpart IIII): The
following emission sources are subject to 2D.0524:Fire Pump Engine (ID DFP-1).
Appears to be in compliance—The fire pump engine is rated at 347 horsepower. The facility had submitted
manufacturer's data that certifies this unit can meet Tier 3 standards and is in compliance with the NSPS
standards for its size. The facility presented fuel provider data sheets that indicate that the sulfur level is 15
ppm in the diesel fuel. The pump engine has a non-resettable hour meter installed on it. The fire pump hour
meter read 579.1 hours during the December 2020 inspection; and 593 hours during this inspection in February
2022.
(8) 15A NCAC 2D .0530:PREVENTION OF SIGNIFICANT DETERIORATION(PSD) — The following
emission sources are subject to 2D.0530: Particleboard Plant Sources: Sawdust Rock and Metal Separator (ID
No. 3501). MDF Plant Sources: Energy System (ID No. ES-02-A) and the two-stage dryer system (ID No. ES-
02-B) with two backup natural gas-fired burners (ID Nos. ES-02-C-1 and-2 and ES-02-D), MDF Board Cooler
(ID No. ES-06-B), MDF Press and Press Hall (Id No. ES-16), Fiber Sifter System (ID No. ES-03), Forming
Line Clean-Up System (ID No. ES-04), Mat Reject System (ID No. ES-05), Saw System (ID No. ES-07), Sander
System No. I (ID No. ES-08), Recycled Fiber Silo No. (ID No. ES-09), Sander System No. 2 (ID No. ES-10),
Sander Dust Silo No. I (ID No. ES-12), Dry Sawdust Silo (ID No. ES-13), Recycled Fiber Silo No. 2 (ID No.
ES-15), Sander Dust Silo No. 2 (ID No. ES-17), emergency generators (ID no. ES-21 and I-DFP), Natural gas-
fired hot oil heaters (ID Nos. ES-18, ES-19, ES-20), Gasoline &Diesel storage tanks (ID Nos. I-Gas).
Appears to be in compliance - The remaining sources of the particleboard plant have established PMio,
volatile organic compound, and opacity limits. The MDF plant sources have established volatile organic
compound limits and work practices.

The permit lists specific Best Available Control Technology(BACT) limits for the subject emission sources and
specifies that none of the subject emission sources should be operated without their respective control devices
also in operation. Each control device has specific monitoring, record keeping, and reporting requirements
outlined in the permit. The cyclones and baghouse for the sawdust rock and metal separator(ID No. 3501)
must be visually inspected monthly. As with the 15A NCAC 2D .0512 requirements, the bagfilters are required
to have monthly visual ductwork inspections and annual internal inspections. The MDF plant biofilter must
have periodic performance tests, and continuous parameter monitoring. Records of work practices for the
generators,process heaters, and tanks must be maintained in a log.
The facility is required to keep records of the monitoring activities and to submit a summary report every six
months documenting any compliance exceptions and summarizing total particleboard production. The 2H 2O21
semiannual report was submitted in time and indicated that all the monitoring had been performed throughout
the period. The facility appeared to be maintaining the required records.
(10) 15A NCAC 2D .0614: COMPLIANCE ASSURANCE MONITORING (CAM) — The following control
devices are subject to CAM requirements: the MDF plant's venturi scrubbers (ID Nos. CD02 and CD14), and
the MDF plant's biofilter(ID No. CD-18).
Appears to be in compliance—The biofilter CAM requirements focus on operating the biofilter within a
minimum and maximum bed temperature range (119°F - 154°F.) The PM CAM requirements focus on
monitoring parameters of the venturi scrubbers (CD02, CD14).
No QIP was required in 2021 for the facility as there were fewer than 6 excursions for each requiring condition
during each semi-annual reporting period.
Notes to Permit Writer: On TSS permit page 16, "complied"should be changed to "compiled" in the Data
Representativeness sections.
(11) 15A NCAC 2D.1111:MA CT SUBPART DDDD—PLYWOOD AND COMPOSITE WOOD
PRODUCTS- The following emission sources are subject to 2D.1111:All of the permitted emission sources
are potentially subject to 2D .I I I I except the thermal oil heaters (MDF Plant—ID Nos. ES-18, ES-19, ES- 20),
Emergency Generators (ID Nos. ES-21, ES-ODG), Fire Pump (ES-DFP-1) and the Laminator Mill emission
sources.
Appears to be in compliance—The facility chose to comply with this regulation by adding a control system to
reduce the hazardous air pollutants (HAP) generated by the processing of composite wood products.
After experimentation with other control options for the MDF plant, a biofilter was selected as the add-on
control for HAPS of concern and start-up of the unit was in February 2018. The NOCS for the biofilter was
dated August 10, 2018 and received at DAQ on August 13, 2018. The biofilter had operational issues and the
facility was required to perform remedial work under the conditions of SOC 2019-001. Contractor remediation
work of the biofilter was completed on December 4, 2019 as required by SOC 2019-001. SOC 2020-002
followed and acknowledged that the facility conducted investigatory testing on February 27, 2020 and found
that the biofilter's formaldehyde destruction removal efficiency(DRE) was greater than 90 percent.

SOC 2020-002 was formally closed on November 24, 2021 as the result of performance testing in October 2021
demonstrating compliance with MACT and PSD BACT emissions limit requirements established in a PSD
permit modification in May 2021. This major permit modification also included the ability to uncontrol the urea
injection NOx control system and removed old Particleboard sources.
The facility provided safety data sheets (SDSs) demonstrating that non-HAP coatings are used.
The facility is additionally required to have a Startup, Shutdown, and Malfunction Plan (SSMP) developed by
October 1, 2008. The facility demonstrated that a completed SSMP is maintained at the facility related to the
previous and new control equipment and was dated September 18, 2018.
(12) 15A NCAC 2D .1111:MACT SUBPART=—RECIPROCATING INTERNAL COMBUSTION
ENGINE-The following emission sources are subject to 2D .I I11:Emergency Generator(ID No. ES-21), Fire
Pump Engine (ID No. I-DFP-1), and Emergency Generator (ID No. I-ODG).
Appears to be in compliance—I-ODG, emergency generator, was rated at 465 horsepower(hp) and was
removed from the facility on December 16, 2019.
I-DFP-1, fire pump engine is rated at 347 bhp output and had an hours meter reading of 579.1 hours on
December 16, 2020 and 610 hours during this inspection. Records were presented showing that annual
maintenance on I-DFP-1 was conducted on May 17, 2021.
The emergency generator(ID No. ES-21, rated at 1592 hp) is located at the MDF plant. Due to its size, this
generator has no requirements under this MACT. The hour meter registered 535 hours during the December 16,
2020 inspection, and 593 hours during this inspection. Annual maintenance on ES-21 was conducted on
November 3,2021.
(13) 15A NCAC 2D .1111:MACT SUBPART DDDDD—BOILERS AND PROCESS HEATERS- The following
emission sources are subject to 2D.1111: Three natural gas-fared hot oil heaters (ID Nos. ES-18, ES-19, and
ES-20), and Natural gas or No. 2 fuel oil-fired hot oil heater(ID No. Pr-Heat]).
Appears to be in compliance—To comply with 15A NCAC 02D A I I I "Maximum Achievable Control
Technology" (MACT) as promulgated in 40 CFR 63, Subpart DDDDD "National Emission Standards for
Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process
Heaters"the facility must conduct a tune-up every five years for each source.
Onsite recordkeeping indicated that the most recent tune-up was conducted on February 28-March 1, 2019 for
hot oil heaters (ID Nos. ES-18, ES-19, and ES-20), and May 8,2018 for hot oil heater(ID No. Pr-Heat 1).
Hot oil heater(ID No. Pr-Heat I) is required to perform a one-time energy assessment, and to maintain records
of the type and amount of fuels used during each startup and shutdown. The facility provided these records on
request. These laminator mill heaters are part of the discontinued particle board operations and have not
operated since 2019.
(14) 15A NCAC 2Q.0317: CONDITIONS TO AVOID PREVENTION OF SIGNIFICANT DETERIORATION
(PSD):All of the following emission sources are subject to the PSD avoidance limitation:MDF Plant.

Appears to be in compliance—Arauco has used projected actual emissions to avoid applicability of Prevention
of Significant Deterioration requirements for a project consisting of modifications to the MDF dryer involving
natural gas burner replacement, which does not result in an increase in overall design capacity of the MDF Mill.
In order to verify the assumptions used in the projected actual emissions calculations, the facility must maintain
records of the actual emissions of PM10, PM2.5, and CO from the MDF Facilities, following the resumption of
regular operations after the modifications and continue for ten years after the resumption of regular operations.
The facility provided these records on request and included them in the annual report dated March 1, 2021.
To avoid applicability of the 15A NCAC 2D .0530 PSD regulations for the MDF plant, the facility is required
to limit the emissions of NOx, PM-2.5, and PM-10. PM-2.5, and PM-10 have annual limits in tons per year of
111.9, and 116.9, respectively. To establish these emission rates,performance tests were performed. Some of
the testing occurred in May 2011 and June 2011. The testing was completed in November 2011. The final test
results were submitted in January 2012 and were reviewed/accepted by the Stationary Source Compliance
Branch. The tests were to determine if the MDF plant emission rates exceeded the following limits: NOx—
33.88 lb/hr, VOC—54.28 lb/hr, PM10—9.5 lb/hr, PM2.5- 9.5 lb/hr.
The permit additionally requires that a solution of urea/water(45%urea concentration(by volume))be injected
into the Energy System at a minimum rate of 0.24 gpm (3-hour block average). This is to help control NOx
emissions. The injection rate was increased from 0.11 gpm to 0.24 gpm in May 2015 with permit revision T44.
Review of facility records indicate that the required PSD monitoring was performed as required. The facility
noted that the only time urea injection was operational for the last year was during a period of performance
testing on October 21, 2021.
The facility is also required to monitor& record the process rates of dryers in ODT/hr(oven-dried ton/hour),
the press process rates (MSF/hr), and heat input for the combustion sources. The facility is maintaining the
required records of these parameters.
The facility is also required to calculate the monthly and rolling 12-month total MDF emission rate for PM-10,
and PM-2.5, and report it on a semiannual basis. The most recent report (1st 2021 semiannual)was received on
time. Provided records indicated that highest 12-month rolling total over the last six-month period is: PM-10—
93.7 tons.
Additionally, the facility must perform inspections and maintenance for MDF plant sources and emergency
generators as recommended by the manufacturer and maintain a log of these activities. The facility provided
these records on request.
(15) 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS-All of the facility s
permitted emission sources are subject to 2D.1806.
Appears to be in compliance - To comply with 15A NCAC 2D .1806, the permittee shall not cause, allow, or
permit the facility to be operated without employing suitable measures for the control of odorous emissions. No
objectionable odors were noted during the compliance inspection. No citizen odor complaints have been filed
against the facility in the past 10 years.

(VI)EXEMPT EMISSION SOURCES: All sources currently listed on the facility's insignificant activities
attachment to the permit have been observed during past inspections. No additional exempt emission sources
were noted that would need inclusion on the permit's insignificant activities list.
(VII) CLEAN AIR ACT SECTION 112(r) REQUIREMENTS: Pursuant to 15A NCAC 2D .2100 "Risk
Management Program," if the Permittee is required to develop and register a risk management plan pursuant to
Section 112(r) of the Federal Clean Air Act, then the Permittee is required to register this plan with the USEPA
in accordance with 40 CFR Part 68.
IN COMPLIANCE—Arauco North America, Inc. is subject to the 112(r)program general duty clause, but does
not maintain regulated chemicals onsite above the threshold quantities, which would require a risk management
plan.
(VIII) STACK TEST REVIEW: The PB surface layer dryer(ID No. 1430) and one of the PB core layer
dryers (ID No. 1420) was tested in October 22, 2009 and the results from this testing demonstrated that
particulate emissions, volatile organic compounds, visible emissions, carbon monoxide, and nitrogen oxides
from the operating PB dryers were below the BACT standards. Some tests of the MDF facility started May
2012, occurred again in June 2012, and continued into November 2012. The particleboard plant testing was
performed in December 2012, January 2012, and in March 2012. There is an annual particulate testing
requirement for the Energy System (ES-02-A). There was a particulate test performed on the MDF Energy
System on November 29, 2012 and a test performed on October 23, 2013 with the results which indicated
compliance. A stack test of the MDF Energy System was performed on November 4, 2014 indicating
compliance to the NOX and particulate limits. These tests were performed with the PGT systems actively
controlling emissions. The PGT systems have been shut down and removed. On January 14, 2016, the facility
tested the particleboard press to determine selected ketone, aldehyde, and polar compound levels when the
emissions were uncontrolled. On June 12, 2018, the particleboard press vent(DEF-2010)was tested for HAP
to satisfy testing requirements of 40CFRPart63 DDDD and the test failed. The press was retested on July 19,
2018 and showed compliance. On July 24, 2018, the drum dryers (1420, 1430) and Wellons Unit(3201) were
tested for VOCs according to 2D .0503 Best Available Control Technology (BACT) limits and compliance was
shown. On July 25, 2018, the biofilter was tested for PM ad NOx according to 2Q .0317 PSD Avoidance
requirements and compliance was shown. On June 13, 2018, inlet/outlet air emissions testing was conducted on
the biofilter(CD-18), which controls emissions for the Refiner(ES-01), the Energy System (ES-02-A), a Two-
Stage Dryer System(ES-02-13), two Back-up Dryers (ES-02-C &ES-02-1)), the MDF Board Cooler and Press
Hall (ES-06-B) and the MDF Press (ES-16). The testing demonstrated compliance with the emission limits of
NCAC 2D .I I I I MACT, 40 CFR Part 63 Subpart DDDD,National Emission Standards for Hazardous Air
Pollutants: Plywood and Composite Wood Products and fulfilled a portion of the requirements of Special Order
By Consent (SOC 2015-02). The MDF operations controlled with the biofilter was tested later in 2018 with the
purpose of widening the bed media temperature range per the Plywood MACT (DDDD). On November 8,
2018 the MDF plant's biofilter(CD-18)was tested for compliance with the Plywood MACT (DDDD) (DAQ
Tracking No. 2018-249ST). Compliance was shown with the methanol and formaldehyde destruction removal
efficiency(DRE). The biofilter average temperature was 140.9 degrees F. On October 20, 2021 the MDF
plant's biofilter(CD-18) was tested for compliance with the Plywood MACT (DDDD) (DAQ Tracking No.
2021-251 ST). Compliance was shown with the methanol and formaldehyde destruction removal efficiency
(DRE). The biofilter average temperature was 142 degrees F.

(IX)EMISSION INVENTORY REVIEW: The difference in facility emissions comparing 2019 and 2020
calendar years were explained in the review of the 2020 emissions inventory. Specifically, the following text
was provided in the DAQ IBEAM emission inventory database: COVID impacted Arauco production
significantly, and they ceased particleboard operation in April 2020 after over 40 years. This is reflected in a
significant decrease in production emissions from old Particleboard sources, which have since been
removed from the permit. CO,NOx, As, Cd, CrVI, Hg, POM, naphthalene, acetaldehyde, acrolein, benzene,
bromine, chlorine, cumene, hexane, methanol, methylene chloride, MIBK, phenol,propionaldehyde, reductions
driven by process shutdown of particleboard processes. S02 reduction is erroneous, and results from incorrect
data entered for for OS51/ES-02-A Teaford Wood Burning in 2019. VOC reduction by process shutdown of
OS3 particleboard dryers, and changed emission factors for control device change to new biofilter for OS69,
ES-02-B Two Stage Dryer. Increase in beryllium, ethylene dichloride, hexachlorodibenzo-p-dioxin, methyl
chloride, phosphorus, vinyl chloride driven by increased operation of OS79 oil heaters and OS75/ES-02-A
Teaford Bypass.
(X) ENFORCEMENT HISTORY: An NOV was issued on November 9, 2020 for failure to meet the PSD
permit limitation of 50% DRE of VOCs with the biofilter. This NOV was associated with the terms of Special
Order by Consent, SOC 2020-002. The company entered a new SOC 2020-002 on September 10, 2020 to
replace the prior SOC 2019-001. SOC 2020-002 allowed the facility the time needed to submit a PSD permit
application with an updated BACT analysis for the MDF facility. An NOV/NRE was issued on June 5, 2019
for shutting down the biofilter(ID No. CD 18)while still operating the MDF plant, which resulted in violations
of PSD BACT, MACT Subpart DDDD, and general condition 3.F. An enforcement package penalty was
included into the SOC 2019-001 penalty which was assessed. An NOV/NRE was issued on April 20, 2017
detailing additional numerous instances of operational (monitoring) violations beyond those addressed in the
previous NOV/NRE. On November 2, 2016, an SOC was issued to the facility regarding the shutdown of the
PGT systems on September 20, 2015. An NOV/NRE was issued on October 12, 2016 to address numerous
instances of operational (monitoring)violations. An NOV was issued regarding this shutdown on October 23,
2015. Arauco has previously been issued two Notice of Violations (NOV) and nine Notices of
Violation/Notices of Recommendation for Enforcement(NOV/NRE) according to DAQ records. An
NOV/NRE was issued on March 12, 2013 for various monitoring and operational issues with an associated fine
of$23,574. An NOV/NRE was issued on May 3, 2012 for various recordkeeping/monitoring violations with an
associated fine of$20,774. An NOV/NRE was issued on April 12, 2012 for a visible emissions violation and
two releases of uncontrolled emissions. On November 14, 2011, an NOV was issued due to a late submission
of a Part 1I portion of an air permit application. An NOV/NRE was issued on February 17, 2011 for missing
test deadlines, and operating equipment with compromised or inoperative control equipment. The civil penalty
for the February 17, 2011 was $42,571. An NOV/NRE was issued on May 4, 2010 for not preparing a Startup,
Shutdown, and Malfunction Plan. Enforcement was not pursued on the May 4, 2010 NOV/NRE. An
NOV/NRE was issued on March 4, 2010 for a reporting violation with an associated fine of$1228.00. An
NOV/NRE was issued on August 12, 2009 for not performing a stack test by the due date with an associated
fine of$4292.00. On October 22, 2008, an NOV was issued for both a late Ist semiannual report and a late 2nd
quarter report for 2008. On May 3, 2006, the facility was issued an NOV/NRE for operating the particleboard
dryers without the associated regenerative thermal oxidizer online. The company entered a Special Order by
Consent to resolve these violations and paid $37,500 in settlement fees. On April 11, 2003, the facility was
issued an NOV/NRE for operating the particleboard dryers without the associated regenerative thermal oxidizer
online with an associated fine of$4219.00. On August 23, 2002, the facility was issued an NOV/NRE for an
annual emissions reporting violation with an associated fine of$1000.00.

(XI) CONCLUSIONS/RECOMMENDATIONS: Based on observations made during the inspection, the
facility appears to be in compliance. It is recommended that an annual inspection be performed within the next
12 months.

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