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HomeMy WebLinkAboutAQ_F_1900015_20201216_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: 12/22/2020 Facility Data Permit Data Arauco North America,Inc. Permit 03449/T53 985 Corinth Road Issued 6/16/2020 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 NAICS: 321219/Reconstituted Wood Product Manufacturing Current Permit Application(s)PSD Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP/Title V/PSD Savannah Carroll Jeff McMillian Savannah Carroll MACT Part 63: Subpart DDDD, SubpartDDDDD, Subpart ZZZZ EHS Manager Plant Manager EHS Manager (919)544-3025 (919)545-5865 (919)544-3025 NSPS: Subpart Dc,Subpart IIII Compliance Data Comments: In Compliance. Notes to Permit Writer: On T53 permit page 16, complied should be changed to compiled in the Data Representativeness Inspection Date 12/16/2020 sections. Recordkeeping requirement e(iii)on page 32 of T53 permit appears to Inspector's Name Matthew Mahler apply to the MDF plant and not to the WESP of the PB plant. Recordkeeping Operating Status Operating requirement m(iv)and m(v)on page 35 of T53 permit appear to no longer be part Compliance Code Compliance-inspection of the MACT SD requirements. 80FR72816,November 20,2015 shows that Action Code FCE these two requirements have been removed. On-Site Inspection Result Compliance Inspector's Signature: Date of Signature:6/27/2021 Total Actual emissions in TONSIYEAR: TSP S02 NOX VOC CO PM10 *HAP 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 2017 124.14 12.64 216.83 708.04 340.86 123.16 350114.49 *Highest HAP Emitted(in pounds) 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 10/12/2016 NOV/NRE Permit Permit Condition 11/04/2016 10/12/2016 NOV/NRE 2D.0512 Particulates from Wood Products Finishing 11/04/2016 Plants 10/12/2016 NOV/NRE 2D.0521 Control of Visible Emissions 11/04/2016 10/12/2016 NOV/NRE 2D.0515 Particulates from Miscellaneous Industrial 11/04/2016 Processes 10/12/2016 NOV/NRE 2Q.0317 Avoidance Conditions 11/04/2016 Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested (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 1/2 mile on the left. Sign in at the log cabin. (II) FACILITY DESCRIPTION: Arauco Panels USA LLC manufactures medium density fiberboard(MDF) and particleboard(PB),both of which are primarily sold to the furniture and flooring industry. The facility runs seven days a week using two 12-hour shifts. At the time of the inspection the facility was staffed by approximately 291 employees. Standard safety equipment is sufficient at this facility. Due to truck traffic, be cautious when walking outside around the plant grounds. 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. The MDF/HDF and the particleboard plants have historically used urea formaldehyde resin to serve as a bonding agent but during the past few years, the facility has been experimenting with using diphenylmethane diisocyanate (MDI) as bonding agent. MDI, when used in this application, is thought to generate less off- gassing emissions as compared to the urea formaldehyde resins. At this point, neither plant has been able to utilize MDI without the board quality being compromised. The first MDF board from the new plant was processed on February 17, 2010. The particleboard products are composed of wood chips, shavings, and saw dust. Particleboard consists of three layers: surface layer, core layer, and surface layer. The outside surface layers are comprised of sawdust that is approximately 20% hardwood/80%pine. The core layer is comprised of chip flakes that are also approximately 20% hardwood/80%pine. In both the MDF and PB plants, the boards are pressed to varying thicknesses and widths. The continuous MDF press is able to form boards with thickness ranging from 3.0 mm to 28 mm and with widths from 2.45 to 3.15 meters (8 to 10.3 feet). The particleboard plant produces sheets that are typically 5 feet wide by 9 feet long. A previous inspection report indicated that this plant produces particleboard ranging in thickness from %2"to 1 '/4". The MDF and particleboard presses operate at 500°F and 350°F respectively. (III)INSPECTION SUMMARY: On December 16, 2020, I (Matt Mahler) 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, the new MDF moulding line operations and the particleboard plant. The MDF plant, including the new moulding line were in operation, but the particleboard plant had been shut down permanently since April 2020. The new moulding line had 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. Afterwards, we returned to the facility's administration building to complete a record review. The records appeared to be well maintained and mostly complete. Ms. Carroll had to leave the site for a personal appointment before the end of the inspection. (IV) PERMITTED EMISSION SOURCES: At the time of this inspection, Arauco was operating under Air Permit No. 03449T53, which became effective on June 16, 2020, 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 filter (ID No. CD05); -Saw System (ID No. ES-07) controlled by one fabric filter (ID No. CD07); -Sander System No. I (ID No. ES-08) controlled by one fabric filter (ID No. CD08); -Recycled Fiber Silo No. I (ID No. ES-09) controlled by bin vent filter (ID No. CD09); -Sander System No. 2 (ID No. ES-10) controlled by one fabric filter (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 filter (ID No. CD15); -Sander Dust Silo No. 2 (ID No. ES-17) controlled by one bin vent filter (ID No. CDI7); -Diesel Fuel-Fired Emergency Generator (1592 Brake Horsepower output) (ID ES-21); MDF Moulding Line Operations consisting of: -MDF moulding line- moulding zone (ID No. ES-MIA) controlled by Reverse flow bag filter (ID No. CD- 2006), High efficiency cyclone (CD-3570), and Reverse flow bag filter (ID No. CD-3575) -MDF moulding line—coating and drying zone (ID No. ES-MIB) C. Particleboard Mill: -Sawdust rock and metal separator (ID No. 3501) and associated cyclone (ID No. CD-SC) and bagfilter (ID No. CD- 3501); -Surface layer dryer (ID No. 1430) and associated multicyclone (ID No. CD-1431; 60 million Btu per hour maximum rated heat input), and wet electrostatic precipitator (ID No. CD-PB-WESP); -Core layer dryer No. I (ID No. 1420) and associated multicyclone (ID No. CD-1421; 50 million Btu per hour maximum rated heat input), and wet electrostatic precipitator(ID No. CD-PB-WESP); -Wellons wood suspension dust-fired burner (ID No. 3201; 40 million Btu per hour maximum rated heat input) exhausting to either surface layer triple pass, rotary drum (#3) dryer[ID No. 1430] and/or core layer single pass, and rotary drum (#I) dryer [ID No. 14201; -Surface material transport(ID No. 3515) and associated cyclones (ID Nos. CD-3500 & CD-3512-B) and bagfilter (ID No. CD-3515); -Surface formers and mat dumps (ID No. 3525) and associated cyclones (ID Nos. CD-3520- A, CD-3520-B, & CD-3521) and bagfilter (ID No. CD-3525); -Flying cut off saw,pretrim saws, and production collection (ID No. 3535) and associated cyclones (ID Nos. CD-3530, CD-3531, & CD-3533) and bagfilter (ID No. CD-3535); -Particleboard press (ID No. DEF-2010) controlled by dryer (ID No. 1430 or No. 1420) and associated multicyclone (ID No. CD-1431 or CD-1421); 60 million Btu per hour maximum rated heat input), and wet electrostatic precipitator (ID No. CD-PB-WESP); -Particleboard cooler (ID No. PB-BC); -Particleboard Steinemann calibrating sander (ID No. 3565) and associated cyclone (ID Nos. CD-3570) and bagfilters (ID No. 5001 & CD-3575); -Schelling saw board trim (ID No. 3555) and associated cyclone (ID No. CD-3522) and bagfilter(ID No. CD-3555); -Sander filter transport for filters 3545 and 3565 (ID No. 3575) and associated cyclone (ID No. CD-3570) and bagfilter(ID No. CD-3575); -PZKR green chip flakers (ID No. 3585) and associated bagfilter (ID No. CD-3585); -Oversized material Pallmann mill (ID No. 3595) and associated bagfilter (ID No. CD- 3595); and -Dry waste transport system (ID No. 3577) and associated cyclone (ID No. CD-3532) and bagfilter(ID No. CD-3577; -Diesel Fuel-fired Fire Pump Engine (347 Brake Horsepower output) (ID ES-DFP-1); -Diesel Fuel-fired Emergency Generator (465 Brake Horsepower output) (ID ES-ODG). D. 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 had been shutdown permanently since April 2020. The new moulding line had started up in September 2020. All facility emission sources were observed and most sources in the MDF were in operation. As indicated in previous inspection reports and prior to shutdown, one of the two particleboard core layer dryers (ID No. 1410) is inoperable. This dryer was severely damaged in a 2007 fire and has been removed from the permit. The laminating mill was decommissioned on December 8, 2016, resumed operation in May 2018, and ceased operation in late 2018. The wastewater evaporator, ID No. EVAP-1,was decommissioned in August 2017. Ms. Carroll was able to locate all of the sources in the material handling sources permitted equipment list. Prior to shutdown, the Wood Fuel Pad and Boiler Transfers were no longer used since the Wellons had no longer combusted wood. The Hog Fuel Hopper in the MDF plant is also no longer used. With T53 permit, the Particleboard Mill Steinemann Finishing Sander(ID No. 3545)was removed from the permit equipment list. Overall, the equipment appeared to be adequately maintained. (V) PERMIT STIPULATIONS: As is the case with all Title V permits, Air Quality Permit No. 03449T53 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 BURNING 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]), and Wellons (ID No. 3201) during OS2 (natural gas fueled- exhausting to atmosphere). 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.0504:PARTICULATES FROM WOOD BURNING INDIRECT HEAT EXCHANGERS- The following emission source is subject to 2D.0504: The Wellons burner (ID No. 3201) during OSI (exhausting to dryers). IN COMPLIANCE—The facility installed a natural gas burner on the Wellons burner and is now burning exclusively natural gas. During a previous inspection, Mr. Bird stated that it would be difficult to burn wood in the Wellons, the way that the equipment is laid out. Natural gas combustion is typically a clean process generating low levels of particulates. Compliance is expected. (3) 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. 1 (ID No. ES-08), Recycled Fiber Silo No. (ID No. ES-09), Sander System No. 2 (ID No. ES-10), Sander Dust Silo No. 1 (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), Surface Material Transport (ID No. 3515), Surface Formers and Mat Dumps (ID No. 3525), Flying Cut Saw, Pretrim Saws, &Production Collection (ID No. 3535), Particleboard Press (ID No. DEF-2010), Particleboard Cooler(ID No. PB-BC), Particleboard Mill Steinemann Calibrating Sander(ID No. 3565), Schelling Saw Board Trim (ID No. 3555), Sander Filter Transport for Filters 3545 and 3565 (ID No. 3575), PZKR Green Chip Flakers (ID No. 3585), Dry Waste Transport System (ID No. 3577), Oversized Material Pallmann Mill (ID No. 3595). 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 had performed the required monthly and annual inspections since the last DAQ inspection. The particleboard plant annual inspections are spread throughout the year. The most recent particleboard plant and MDF plant annual inspections were conducted in May 2020 and October 2020, respectively. 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. (4) 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), PB surface layer dryer (ID No. 1430), PB core layer dryer No. I (ID No. 1420), and the short cycle laminating presses (ID Nos. 3593 & 3594). 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 PB surface layer dryer(ID No. 1430) and one of the PB core layer dryers (ID No. 1420)was tested on October 22, 2009. During the test, the lowest throughput of material passing through these two dryers was 97,350 lb/hr. Using this lower throughput rate ensures the lowest calculated particulate limit. Using the applicable formula associated with the regulation, the calculated particulate limit for this unit is 55.37 lb/hr. The performance results from the October 22, 2009 test indicated that the particulate emission rate for the combined dryer exhaust stack was 8.89 lb/hr. This emission rate is well below the 15A NCAC 2D .0515 particulate emissions standard. 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. The facility has discontinued the use of the photochemical gas treatment(PGT)unit due to a number of problems. The venturi scrubbers are still operational. 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, EP14). 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. The laminating mill is also regulated by 2D .0515. The processes in the laminating mill do not produce large amounts of particulates. There is a bagfilter controlling emissions from the mill. Note that the laminating mill was decommissioned on December 8, 2016, resumed operation in May 2018, and ceased operation in late 2018. 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, Wet ESP, 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. It was noted that the particleboard plant had been shutdown permanently since April 2020. The permit does require the facility to perform monthly and annual inspections of the laminating mill bagfilter in addition to regular maintenance activities. Upon request, the facility was able to provide records that demonstrated that the required monitoring and recordkeeping was being conducted as described in the permit through the period prior to shutdown of the laminating mill in late 2018. The submission of semiannual reports has been performed as prescribed in the permit. (5) 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES- The following emission sources are subject to 2D .0516: The thermal oil heaters (MDF Plant—ID Nos. ES-18, ES-19, ES-20), PB surface layer dryer (ID No. 1430), PB core layer dryer No. 1 (ID No. 1420), Wellons burner (ID No. 3201), thermal oil heater(ID No. Pr-Heatl), emergency generator (ES-21), and emergency generator (ES-ODG). 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. (6) 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS-All of the permitted emission sources are subject to 2D.0521. 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 does require 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 and the particleboard 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 most of the applicable sources. The permittee was previously required to monitor the Energy System(ID ES-02-A) exhaust for opacity daily but the current permit revision allows for weekly observations. It appeared that all the opacity readings were being performed as required. (7) 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). 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 is tracking daily fuel usage for the MDF plant. (8) 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). 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. In a previous inspection, 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. According to the facility records, the fire pump had 440.0 hours on the hour meter during the September 26, 2017 inspection; 467.4 hours during the March 2019 inspection; and 579.1 hours during this inspection. (9) 15A NCAC 2D.0530:PREVENTION OF SIGNIFICANT DETERIORATION(PSD) — The following emission sources are subject to 2D .0530: PB surface layer dryer (ID No. 1430), PB core layer dryer No. I (ID No. 1420), Sawdust Rock and Metal Separator (ID No. 3501), Surface Material Transport(ID No. 3515), Surface Formers and Mat Dumps (ID No. 3525), Flying Cut Saw, Pretrim Saws, &Production Collection (ID No. 3535), Particleboard Press (ID No. DEF-2010), Particleboard Cooler (ID No. PB-BC), Particleboard Mill Steinemann Calibrating Sander (ID No. 3565), Particleboard Mill Steinemann Finishing Sander (ID No. 3545), Schelling Saw Board Trim (ID No. 3522), Sander Filter Transport for Filters 3545 and 3565 (ID No. 3575), PZKR Green Chip Flakers (ID No. 3585), Dry Waste Transport System (ID No. 3577), and Oversized Material Pallmann Mill (ID No. 3595). IN COMPLIANCE - The various sources of the particleboard plant have established PMlo, volatile organic compound, and opacity limits. Overall, to ensure compliance with 15A NCAC 2D .0530, the permit limits total particleboard production to 180,000,000 square feet per year on a 3/4-inch basis and a limit to the operating hours of each of the particleboard dryers (8,500 hours). According to the 1"2020 semiannual report, the highest 12-month rolling total particleboard production rate in that 6-month period was 144,542,000 square feet on a 3/4-inch basis (April 2019—March 2020). Similarly, the highest 12-month rolling total number of dryer hours in that 6-month period was the surface layer dryer at 5,682 hours (January 2020—December 2020). Recordkeeping of the maintenance performed on woodworking operations sources was observed as SAP work orders. The permit lists specific Best Available Control Technology(BACT) limits for each of the subject emission sources. 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. The permit also specifies that none of the subject emission sources should be operated without their respective control devices also in operation. Each type of control device has specific testing, monitoring, record keeping, and reporting requirements outlined in the permit. One of the requirements is that the cyclones and multicyclones (CD-1421, 1431)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. There are requirements to operate the wet electrostatic precipitator with at least two out of three fields functioning. In discussion with Ms. Carroll, she indicated that the data is available to monitor the number of fields that have been operating. Ms. Carroll indicated that the precipitator has been able to maintain at least two fields operating in the unit. The facility is required to perform weekly inspections on the burners, fans, blowers, and process control equipment associated with the dryers. In addition, an annual internal inspection of the dryers is also required. 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 1st 2020 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), the MDFplant's biofilter (ID No. CD-18), and the PB Mill's wet electrostatic precipitator (ID No. CD-PB-WESP). IN COMPLIANCE—The biofilter CAM requirements focus on operating the biofilter within a minimum and maximum bed temperature range. These limits have not yet been established. A stack test is planned for October 2018 to determine a wider bed temperature range. The PB CAM requirements focus on monthly external visual inspections of the associated cyclones (CD-1421, CD-1431). The permit also requires that the primary voltages and currents be monitored on the wet electrostatic precipitator(ESP). Records indicated one voltage excursion in the first half of 2020 and one current excursion in the second half of 2020 for the WESP, which is below the Quality Improvement Plan (QIP) threshold of six each. Records also indicated three excursions for the venturi scrubbers in the second half of 2019, which is below the Quality Improvement Plan (QIP) threshold of six. Notes to Permit Writer: On T53 permit page 16, complied should be changed to compiled in the Data Representativeness sections. Recordkeeping requirement e(iii) on T53 permit page 32 appears to apply to the MDFplant and not the WESP of the PB plant. (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. 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. The facility had selected a Photocatalytic Gas Treatment(PGT) system for both the particleboard plant and the MDF plant. These systems proved fairly effective for removing methanol and formaldehyde from exhaust streams. Over the course of the past few years, safety concerns over the UV lights, hydrogen peroxide, and nitric acid grew to the point where the facility began to investigate optional control systems. Presently, the facility is under SOC 2020-002 that was signed on September 10, 2020. A pilot study for the particleboard plant resulted in the facility choosing to use a production-based compliance option with no controls. However, the particleboard plant has been permanently shutdown since April 2020. 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 has had operational issues and the facility was required to perform remedial work under the conditions of the prior SOC 2019-001. Contractor remediation work of the biofilter was completed on December 4, 2019 as required by the prior SOC 2019-001. The biofilter is currently in operation under the terms of SOC 2020-002. SOC 2020-002 acknowledges that the facility conducted investigatory testing on February 27, 2020 and found that the biofilter's formaldehyde destruction removal efficiency(DRE)was greater that 90 percent. The facility has submitted a permit application to DAQ, which includes an updated BACT analysis. The facility provided an SDS sheet by email on April 2, 2019, which showed 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. Ms. Carroll was able to show 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 .1111: Emergency Generator (ID No. ES-21), Fire Pump Engine (ID No. I-DFP-1), and Emergency Generator (ID No. I-ODG). 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 511 hours on March 24, 2019 and 579.1 hours during this inspection. Records showed that annual maintenance was conducted on October 1, 2020. 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 405 hours during the September 26, 2017 inspection, 503 hours during the March 28, 2019 inspection, and 535 hours during this inspection. Annual maintenance on ES-21 was conducted on July 20, 2020. (13) 15A NCAC 2D.1111:MACT SUBPART DDDDD—BOILERS AND PROCESS HEATERS- The following emission sources are subject to 2D .1111: Wellons (ID No. 3201) when operating in OS-2. IN COMPLIANCE—Operating scenario (OS-2) characterizes this unit when combusting natural gas. This heater has been historically fueled by hog waste wood and presently the unit is utilizing a newly installed natural gas burner. The initial tune up and one-time energy assessment were due by January 31, 2016. According to the previous inspection report, the energy assessment on the Wellons Unit was done in April 2014 and was a part of the project to scope out and convert the unit to natural gas. Per EPA's online Central Data Exchange (CDX) archived documents,the initial tune-up on the Wellons Unit was done in July 2015. However, this tune-up did not meet the requirements listed in 40CFR 63.7540(a)(10)(i-vi) according to the compliance report. The facility conducted a subsequent tune-up, which did meet requirements, on November 30, 2016. The MACT compliance report was archived in CDX on 1/24/2017. Onsite recordkeeping indicated that the most recent tune-up was conducted on November 13, 2019. Note to Permit Writer: Recordkeeping requirement m(iv) and m(v) on page 35 of T53 permit appear to no longer be part of the MA CT 5D requirements. 80FR72816, November 20, 2015 shows that these two requirements have been removed. (14) 15A NCAC 2Q Q.0317: CONDITIONS TO AVOID PREVENTION OF SIGNIFICANT DETERIORATION (PSD):All of the following emission sources are subject to the PSD avoidance limitation:MDF Plant. IN COMPLIANCE— 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, VOC, PM-2.5, and PM-10 to the following respective annual limits (tons): 177.8, 337, 111.9, and 116.9. To establish these emission rates, performance tests were performed. Some of the testing occurred in May 2011 and June 2011. The testing was not completed until 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—33.881b/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 is also required to monitor 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 keeping track of these parameters. The facility is also required to determine what the 12-month rolling total MDF emission rate for PM-10, PM-2.5 and NOx, and report it on a semiannual basis. Previously, the facility reported emission rates to the Raleigh Regional Office quarterly. The most recent report (1st 2020 semiannual) indicated that highest 12-month rolling total over that six-month period for each of these three types of pollutants is as follows: PM-10— 89.5 tons, PM- 2.5 — 88.7 tons, and NOx— 143.7 tons. Note: the facility is exceeding its VOC limit since no controls are in place until the biofilter testing period is completed. The facility is operating under the terms of an SOC covering this exceedance. (15) 15A NCAC 2D.1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS-All of the facility's permitted emission sources are subject to 2D.1806. 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. There was one complaint lodged in August 2006 concerning a citrus smell that burned the nose of the complainant. The subsequent odor investigation did not substantiate the complaint. (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 RAPS 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-B), two Back-up Dryers (ES-02-C &ES-02-D), 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. (IX) EMISSION INVENTORY REVIEW: The difference in facility emissions comparing 2018 and 2019 calendar years were explained in the review of the 2019 emissions inventory. Specifically, the following text was provided in the DAQ IBEAM emission inventory database: "Changes in emissions that are greater than 10%between 2018 and 2019 inventories are explained as follows. Most Criteria pollutants, HAPS/TAPS emission increases were due to either or both an 8% increase in hours of usage of the MDF Plant two-stage wood dryer ES-02-B in OS69 and a 17% increase in throughput of the PB Plant's drum dryer with burner, ESID 1420 in OS3. In addition to OS3, PM/PM10/PM2.5 emission increases were also due to an 8% increase in fuel use in ES-02-A Wood Burning in Energy Plant. Cadmium emission decrease was due to an 89%reduction in natural gas burned in the Wellons Bypass for PB process, ESID 3201, OS36. Hexachlorodibenzo-p-dioxin 1,2,3,6,7,8, Phosphorus Metal, and vinyl chloride emission decreases were due to a 27% decrease in fuel use for OS75, ESID ES-02-A Energy System Bypass Mode. Other pollutants with a greater than 10% change were below the de minimus." (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. CD18)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 II 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 I" semiannual report and a late 2na 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 with the exception of the ongoing violations covered under SOC 2020-002. It is recommended that an annual inspection be performed within the next 12 months.