AQ_F_1900015_20200102_PRMT_Permit

ROY COOPER
Governor
MICHAEL S.REGAN
Secretary .
MICHAEL ABRACZINSKAS
Director
NORTH CAROLINA
Environmental Quality
January 02,2020
Jeff McMillian
Plant Manager
Arauco North America,Inc.
985 Corinth Rd.
Moncure,North Carolina 27559
SUBJECT: Air Quality Permit No. 03449T52
Facility ID: 1900015
Arauco North America,Inc.
Moncure,North Carolina
Chatham County
Fee Class: Title V
PSD Status: Major
Dear Mr.McMillian:
In accordance with your completed air quality permit application for the significant modification of
your Title V permit,received August 14, 2018, amended December 28, 2018 and October 17, 2019,we are
forwarding herewith Air Quality Permit No. 03449T52 to Arauco North America,Inc., 985 Corinth Road,
Moncure,North Carolina,authorizing the construction and operation,of the emission source(s)and associated
air pollution control device(s)specified herein. Additionally,any emissions activities determined from your
Air Quality Permit Application as being insignificant per 15A North Carolina Administrative Code 02Q
.0503(8)have been listed for informational purposes as an "ATTACHMENT." Please note the requirements
for the annual compliance certification are contained in General Condition P in Section 3.The current owner
is responsible for submitting a compliance certification for the entire year regardless of who owned the facility
during the year.
As the designated responsible official it is your responsibility to review,understand,and abide by all
of the terms and conditions of the attached permit. It is also your responsibility to ensure that any person who
operates any emission source and associated air pollution control device subject to any term or condition of
the attached permit reviews, understands, and abides by the condition(s) of the attached permit that are
applicable to that particular emission source.
If any parts,requirements,or limitations contained in this Air Quality Permit are unacceptable to you,
you have the right to request a formal adjudicatory hearing within 30 days following receipt of this permit,
identifying the specific issues to be contested. This hearing request must be in the form of a written petition,
conforming to NCGS (North Carolina General Statutes) 15013-23, and filed with both the Office of
Administrative Hearings,6714 Mail Service Center,Raleigh,North Carolina 27699-6714 and the Division of
Air Quality,Permitting Section, 1641 Mail Service Center,Raleigh,North Carolina 27699-1641. The form
for requesting a formal adjudicatory hearing may be obtained upon request from the Office of Administrative
Hearings. Please note that this permit will be stayed in its entirety upon receipt of the request for a hearing.
Unless a request for a hearing is made pursuant to NCGS 15013-23,this Air Quality Permit shall be final and
binding 30 days after issuance.
North Carolina Department of Environmental Quality i Division of Air Quality
ani cwxira
-E Q
217 West]ones Street 1 1641 Mail Service Center 9 Raleigh,North Carolina 27699-1641
nw�wmmEmtramemaiauwq � 919.707.8400

Mr.McMillian
January 02,2020
Page 2
You may request modification of your Air Quality Permit through informal means pursuant to NCGS
150B-22. This request must be submitted in writing to the Director and must identify the specific provisions
or issues for which the modification is sought. Please note that this Air Quality Permit will become final and
binding regardless of a request for informal modification unless a request for a hearing is also made under
NCGS 150B-23.
The construction of new air pollution emission source(s) and associated air pollution control
device(s), or modifications to the emission source(s) and air pollution control device(s) described in this
permit must be covered under an Air Quality Permit issued by the Division of Air Quality prior to construction
unless the Permittee has fulfilled the requirements of NCGS 143-215.108A(b)and received written approval
from the Director of the Division of Air Quality to commence construction.Failure to receive an Air Quality
Permit or written approval prior to commencing construction is a violation of NCGS 143-215.108A and may
subject the Permittee to civil or criminal penalties as described in NCGS 143-215.114A and 143-215.114B.
Chatham County has triggered increment tracking under PSD for PM,o,SOz and NO.. However,this
permit modification does not consume or expand increments for any pollutants.
This Air Quality Permit shall be effective from January 02, 2020 until June 30, 2021, is
nontransferable to future owners and operators, and shall be subject to the conditions and limitations as
specified therein. Should you have any questions concerning this matter,please contact Joseph Voelker, at
[phone] or joseph.voelker@ncdenr gov.
Sincerely yours,
4
William D. Willets,P.E.,Chief,Permitting Section,
/ Division of Air Quality,NCDEQ
Enclosure
cc: Kelly Fortin,EPA Region 4
Connie Horne(cover letter only)
Raleigh Regional Office
Central Files

ATTACHMENT to cover letter to Permit No. O3449T52
Insignificant Activities per 15A NCAC 02Q .0503(8)
Emission Source ID No. Emission Source Description
I-VENTS Roof ventilators
I-GAS One 500 gallons above ground gasoline storage tank
I-TANKI,I-TANK2,I-TANKS,I-
TANK4 Four above ground propane storage tanks, 1000 gallons each
I-LPA LoR Process;-Area
I-MDFR-1,I-MDFR-2,I-NIDFR-3,
I-MDFR-4 Four MDF Resin Storage Tanks
MACT DDDD
I-DFP-1
MACT ZZZZ, NSPS HU Diesel fuel-fired Fire Pump Engine(347 Brake Horsepower output)
I-ODG Diesel-fuel Fired Emergency Generator(465 horsepower,3,026 million Btu
MACT ZZZZ per hour heat input)
I-Irrigation fugitive Spray irrigation Field F itives
I-Wastewater ponds Fu itives from wastewater la oons
I-SRray paints MACT DDDD Paints and strip.ing for marking wood panels
1. Because an activity is insignificant does not mean that the activity is exempted from an applicable requirement or
that the owner or operator of the source is exempted from demonstrating compliance with any applicable requirement.
2. When applicable, emissions from stationary source activities identified above shall be included in determining
compliance with the permit requirements for toxic air pollutants under 15A NCAC 02D.1100"Control of Toxic Air
Pollutants"or 02Q.0711 "Emission Rates Requiring a Permit".
3. For additional information regarding the applicability of MACT see the DAQ page titled"The Regulatory Guide for
Insignificant Activities/Permits Exempt Activities".The link to this site is as follows:
h=://dgg.state.nc.us/permits/insig/

ATTACHMENT to cover letter to Air Quality Permit No. 03449T52
Table of Changes
Existing New Condition
Condition No. Changes
No.
Cover Same • Updated permit revision numbers,issue and effective dates,etc.
Letter
Permit, Same • Revised dates
a e 1 ,permit numbers,etc.
• Removed reference to wastewater evaporator EVAP-1.
• Removed application submittal requirement footnote for EVAP-1
Section 1 Same • Removed application submittal requirement footnote for MDF plant 02Q
.0501(b)(2)modification.The current application satisfies this requirement.
• Revised the MACT 5D condition to reflect:
■ 5 year tune up and reporting frequency allowed under the rule for the use
2.1 D.5 same of oxygen trim systems
■ Renumbered condition and made other minor corrections to make
consistent with current IMQ permittingstandards.
2.1 G 2.1 G Reserved • Removed all requirements for the wastewater evaporator EVAP-1.The source
has been removed from the site.
2.2 A.1 same MACT DDDD condition
h same • Added minimum and maximum biofilter temperatures of 132 IF and 145 OF,
respectively.
• Added the monitoring parameter value of 0.3%established during the last
performance test
1. same • Broke the paragraph in two paragraphs i and I
• Added language in paragraph ii consistent with current permitting policy to
highlight how the monit2r'nE parameter may be subsequently revised.
The following paragraph will be added at Section 2.2 A.1 m.
NA m.i i. The Permittee shall test the biofilter,reestablish the monitoring
parameters at Section 2.2 A.Lh and submit the test results within 180
days after completion of the remedial work as described in the Special
Order of Consent 2019-001.
r and s. • Removed initial testing requirements as these tests have been conducted.
r and s. RESERVED Condition will remain as RESERVED to avoid renumbering of permit
condition
U. • Renumbered subparagraphs to accommodate the addition of u.iv.
• Added the following language to be consistent with rule:
NA u.iv. To the extent practical,startup and shutdown of emission control
systems must be scheduled during times when process equipment is
also shut down.L40 CFR 63.2251@
V. same
• Added a routine control device maintenance exemption for the biofilter
as requested and described in letter dated September 26,2019
aa.v same • Revised to read:
"associated records for sections 2.2 A.1.0 throu h "
• Added the following recordkeeping condition for the resin content at the
NA aa.vi. PB plant:
"associated records for sections 2.2 A.1.1"
NA • Removed these conditions as the Permittee has met these notification
through vi. requirements.
2.2 B.3 NA • 02Q .0504[i.e.,02Q.0501(b)(2)] application submittal requirement
removed.The current application satisfied this requirement.

Existing New Condition
Condition No. Changes
No.
NA ATTACHMENT . As required by MACT DDDD,the request letter for the biofilter RCDME
B is included as an attachment to the TV permit
NA ATTACHMENT . SOC 2019-001 has been included as an attachment to the permit
C

-' State of North Carolina
E Q Department of Environmental Quality
4*04LI
o�Errv+ronn+entalQuaMy Division of Air Quality
AIR QUALITY PERMIT
Permit No. Replaces Permit No. Effective Date Expiration Date
03449T52 03449T51 January 02, 2020 June 30, 2021
Until such time as this permit expires or is modified or revoked,the below named Permittee is permitted to construct and operate
the emission source(s)and associated air pollution control device(s) specified herein, in accordance with the terms, conditions,
and limitations within this permit. This permit is issued under the provisions of Article 2113 of Chapter 143,General Statutes of
North Carolina as amended,and Title 15A North Carolina Administrative Codes(15A NCAC), Subchapters 02D and 02Q, and
other applicable Laws.
Pursuant to Title 15A NCAC, Subchapter 02Q,the Permittee shall not construct,operate,or modify any emission source(s)or air
pollution control device(s)without having first submitted a complete Air Quality Permit Application to the permitting authority
and received an Air Quality Permit,except as provided in this permit.
Permittee: Arauco North America, Inc.
Facility ID: 1900015
Facility Site Location: 985 Corinth Road
City, County, State, Zip: Moncure, Chatham County,North Carolina 27559
Mailing Address: 985 Corinth Road
City, County, State, Zip: Moncure, Chatham County,North Carolina 27559
Application Number: 1900015.18B and .19C
Complete Application Date: August 14,2018 and October 17,2019
Primary SIC Codes: 2493
Division of Air Quality, Raleigh Regional Office
Regional Office Address: 3800 Barrett Drive, Suite 101
Raleigh,North Carolina 27609
Permit issued this the 2°a day of January 2020
2cl-iamD. Willets, P.E., Chief, Permitting Section
By Authority of the Environmental Management Commission

Table of Contents
SECTION 1: PERMITTED EMISSION SOURCE(S) AND ASSOCIATED
AIR POLLUTION CONTROL DEVICE(S)AND APPURTENANCES
SECTION 2: SPECIFIC LIMITATIONS AND CONDITIONS
2.1 - Emission Sources Specific Limitations and Conditions
(Including specific requirements)
2.2 - Multiple Emission Source(s) Specific Limitations and Conditions
2.3 - Permit Shield for Non-Applicable Requirements
SECTION 3: GENERAL PERMIT CONDITIONS
ATTACHMENTS
List of Acronyms
RCDME Request Letter
Special Order of Consent 2019-001

Air Permit 03449T52
Page 3
SECTION 1 - PERMITTED EMISSION SOURCE(S) AND ASSOCIATED AIR
POLLUTION CONTROL DEVICE(S) AND APPURTENANCES
The following table contains a summary of all permitted emission sources and associated air pollution control devices
and a unnenances:
!t[)
ion Source Emission Source Description Control Device ID Control Device Description
No. No.
Material Handlin Sources
7001 or SP-1 Truck/Rail Chip Handling System, N/A N/A
MACT DDDD Enclosed
7004 or SP-2 Truck/Rail Sawdust Handling System, N/A N/A
MACT DDDD Enclosed
7010 Particle Board Mill Truck Dump N/A N/A
MACT DDDD
7012,7014, Dump bunkers and CL dryer dump N/A N/A
7015,7029
MACT DDDD
7052,7054, Wood residue bunkers N/A N/A
7055,7056
MALT DDDD
6001,7002-A, Wood chip piles-Medium Density N/A N/A
�7002-B,7002-C, Fiberboard Mill
7002-D
MACTDDDD
6003,7006, Wood Fuel Pad and Boiler Transfers N/A N/A
7007,7022
MACT DDDD
7005-D,7005-E, Sawdust transport to A-frame N/A N/A
7005-F,7005-G
MACT DDDD
7025 Scale transfer conveyors N/A N/A
MACT DDDD
7019,7026 Fiber dump and reject filter bins N/A N/A
MACT DDDD
7027 Hog fuel hopper N/A N/A
MACT DDDD
7040,7044,7046, Particleboard Mill chip transfer N/A N/A
7048,7050
MACT DDDD
SP Fuel Sawdust and Chip Storage Piles N/A N/A
MACT DDDD
7024 Particleboard Mill feed bins N/A N/A
MACT DDDD
Medium Density Fiberboard MDF Facilities
ES-01 Refiner CD01 Refiner Abort Cyclone(66 inches in
PSD diameter) 1
MACT DDDD CD02 Venturi scrubber
in series with
CD 18 Biofilter
CD14 Venturi scrubber
In series with
CD 18 Biofilter
For operation during startup,shutdown and malfunction only.

Air Permit 03449T52
Page 4
Emission Source Emission Source Description Control Device ID Control Device Description
ID No. No.
ES-18,ES-19,and Three natural gas-fired hot oil heaters N/A N/A
ES-20 (30.4 million Btu per hour maximum
PSD heat input each)
NSPS Dc
MACT DDDDD
ES-02-A Energy System consisting of one CD02-A Urea/water injections •stem
PSD dry/wet wood/woodwaste-fired burner CD02 Venturi scrubber
MACT DDDD (205 million Btu per hour heat input) In series with
CD18 Biofilter
CD14 Venturi scrubber
In series with
CD18 Biofilter
ES-02-B Two Stage Dryer System CD02 Venturi scrubber
and and In series with
ES-02-C-I and ES- Three backup natural gas-fired dryer CD18 Biofilter
02-C-2, ES-02-D burners(35,35,and 17 million Btu per CD14 Venturi scrubber
PSD hour heat input respectively) In series with
MACT DDDD CD18 Biofilter
ES-16 MDF Press and Press Hall CD02 Venturi scrubber
PSD In series with
MACT DDDD CD18 Biofilter
CD14 Venturi scrubber
In series with
CD18 Biofilter
ES-06-B MDF Board Cooler CD02 Venturi scrubber
PSD In series with
MACT DDDD CD18 Biofilter
CD14 Venturi scrubber
In series with
CD18 Biofilter
ES-03 Fiber Sifter System CD03 Fabric Filter(12,290 square feet of
PSD filter area)
MACT DDDD
ES-04 Forming Line Clean-Up System CD04 Fabric Filter(9,346 square feet of
PSD filter area)
MACT DDDD
ES-05 Mat Reject System CD05 Fabric Filter(9,346 square feet of
PSD filter area)
MACT DDDD
ES-07 Saw System CD07 Fabric Filter(6,793 square feet of
PSD filter area)
MACT DDDD
ES-08 Sander System No.1 CD08 Fabric Filter(12,290 square feet of
PSD filter area)
MACT DDDD
ES-09 Recycled Fiber Silo No.1 CD09 Bin Vent Filter(226 square feet of
PSD filter area)
MACT DDDD
ES-10 Sander System No.2 CD10 Fabric Filter(12,290 square feet of
PSD filter area)
MACT DDDD
ES-12 Sander Dust Silo No. 1 CD12 Bin Vent Filter(226 square feet of
PSD filter area)
MACT DDDD

Air Permit 03449T52
Page 5
FF Emission Source Emission Source Description Control Device ID Control Device Description
ID No. No.
ES-13 Dry Sawdust Silo CD13 Bin Vent Filter(226 square feet of
PSD filter area)
MACT DDDD
ES-15 Recycled Fiber Silo No.2 CD15 Bin Vent Filter(226 square feet of
PSD filter area)
MACT DDDD
ES-17 Sander Dust Silo No.2 CD17 Bin Vent Filter(226 square feet of
PSD filter area)
MACT DDDD
ES-21 Diesel Fuel-fired Emergency N/A N/A
PSD Generator(1592 brake Horsepower
MACT ZZZZ output)
Particleboard Mill
3501 Sawdust Rock and Metal Separator CD-SC High efficiency cyclone-72 inches in
PSD diameter
MACT DDDD
CD-3501 Reverse flow bag filter with 2,410
square feet of surface area
1430 Surface layer triple pass,rotary drum CD-1431 High efficiency multi-cyclone with 2
PSD (#3)dryer with one wood suspension tubes,each 132 inches in diameter
MACT DDDD dust/natural gas-fired burner(60
million Btu per hour maximum rated CD-PB-WESP Wet electrostatic precipitator
heat input)
1420 Core layer single pass,rotary drum CD-1421 High efficiency multi-cyclone with 4
PSD (#1)dryer with one wood suspension tubes,each 80 inches in diameter
MALT DDDD dust/natural gas-fired burner(50
million Btu per hour maximum rated CD-PB-WESP Wet electrostatic precipitator
heat input)
3201 One"Wellons"unit operating as a CD-1431 High efficiency multi-cyclone with 2
PSD natural gas-fired burner(21.8 million tubes,each 132 inches in diameter
MACT DDDD Btu per hour maximum rated heat
input); AND/OR
exhausting to either CD-1421 High efficiency multi-cyclone with 4
tubes,each 80 inches in diameter
surface layer triple pass,rotary drum AND
(#3)dryer[ID No. 1430]and/or
CD-PB-WESP Wet electrostatic precipitator
core layer single pass,rotary drum(#1)
dryer ID No. 1420
3201 One"Wellons"unit operating as a N/A N/A
MACT DDDDD natural gas-fired indirect heat
exchanger(21.8 million Btu per hour
maximum rated heat input)
3515 Surface Material Transport CD-3500, Simple cyclone-72 inches in
PSD (SL fines from screening operation) diameter
MACT DDDD CD-3525
Reverse flow fabric filter with 6,918
square feet of surface area
CD-3512B Simple cyclone-72 inches in
diameter
CD-3515 Reverse flow fabric filter with 5,767
s u ire feet of surface area

Air Permit 03449T52
Page 6
Emission Source Emission Source Description Control Device ID Control Device Description
ID No. No.
3525 Surface Formers and Mat Dumps CD-3520A, Three(3)simple cyclones-each 96
PSD CD-3520B, inches in diameter
MACT DDDD CD-3521
CD-3525 Reverse flow fabric filter with 6,918
square feet of surface area
3535 Flying Cut Off Saw,Pretrim Saws,& CD-3530 Simple cyclone-84 inches in
PSD Production Collection diameter
MACT DDDD
CD-3531 Simple cyclone- 108 inches in
diameter
CD-3533 Simple cyclone- 108 inches in
diameter
CD-3535 Reverse flow fabric filter with 6,918
square feet of filter area
3545 Particleboard Mill Steinmann CD-2006 Reverse flow bag filter with 61918
PSD Finishing Sander square feet of surface area
MACT DDDD
CD-3570 High efficiency cyclone- 144 inches
in diameter
CD-3575 Reverse flow bag filter with 1,159
s uare feet of surface area
DEF-2010 Particleboard Press N/A N/A
PSD
MACT DDDD
PB-BC Particleboard Cooler N/A N/A
PSD
MACT DDDD
3565 Particleboard Mill Steinmann CD-5001 Reverse flow fabric filter with 6,918
PSD Calibrating Sander square feet of surface area
MACT DDDD
CD-3570 High efficiency cyclone- 144 inches
in diameter
CD-3575 Reverse flow bag filter with 1,159
square feet of surface area
3555 Schelling Saw Board Trim CD-3522 High efficiency cyclone- 120 inches
PSD in diameter
MAC T DDDD
CD-4005 Reverse flow bag filter with 6,918
square feet of surface area
3575 Sander Filter Transport for Filters CD-3570 High efficiency cyclone- 144 inches
PSD 3545&3565 in diameter
MACT DDDD
CD-3575 Reverse flow bag filter with 1,159
square feet of surface area
3585 PZKR Green Chip Makers CD-3585 Reverse flow bag filter with 4,880
PSD square feet of surface area
MACT DDDD
3595 Oversize Material Palhnann Mill CD-3595 Reverse flow bagfilter(Maximum
MACT DDDD air-to-cloth ratio of 3.0 ACFM/total
filter surface area).

Air Permit 03449T52
Page 7
Emission Source Emission Source Description Control Device ID Control Device Description
ID No. No.
3577 Dry waste transport system i CD-3532 Simple cyclone-60 inches in
PSD diameter
MACT DDDD
CD-3577 Reverse flow bag filter with 4,068
skjuare feet of surface area
Laminator Mill
3593 and 3594 Two(2)Short Cycle LaminatingCD
-3593 Reverse flow bagfilter(Maximum
Presses air-to-cloth ratio of 4.1 ACFM/total
filter surface area).
Pr-Heatl Natural gas or No.2 fuel oil-fired hot N/A N/A
Case-by-Case oil heater(4.7 million Btu per hour
MACT heat input)used with short cycle
laminating presses

Air Permit 03449T52
Page 8
SECTION 2 - SPECIFIC LIMITATIONS AND CONDITIONS
2.1 - Emission Source(s) and Control Devices(s) Specific Limitations and
Conditions
The emission source(s)and associated air pollution control device(s)and appurtenances listed below are subject to
the following specific terms,conditions,and limitations,including the testing,monitoring,record keeping,and
reporting requirements as specified herein:
A. The following Material Handling Sources:
Table 2.1.A.
—[
Emission Source ID Control Control
No. Emission Source Description Device ID Device
No. Description
7001 or SP-1 Truck/Rail Chip Handling System,Enclosed N/A N/A
7004 or SP-2 Truck/Rail Sawdust Handling System,Enclosed N/A N/A
7010 Particle Board Mill Truck Dump N/A N/A
7012,7014,7015 7029 Dump bunkers and CL dryer dump N/A N/A
7052,7054,7055,7056 Wood residue bunkers N/A N/A
6001,7002-A,7002-B, Wood chip piles-Medium Density Fiberboard N/A N/A
7002-C,7002-D Mill
6003,7006,7007,7022 Wood Fuel Pad and Boiler Transfers N/A N/A
7005-D,7005-E,7005- Sawdust transport to A-frame N/A N/A
F,7005-G
7025 Scale transfer conveyors N/A N/A
7019,7026 Fiber dump and reject filter bins N/A N/A
7027 Hog fuel hopper N/A N/A
7040,7044,7046,7048,7050 Particleboard Mill chip transfer N/A N/A
SP Fuel Sawdust and Chi Storage Piles N/A N/A
7024 Particleboard Mill feed bins N/A N/A
The following table provides a summary of limits and/or standards for the material handling sources.
Regulated Pollutant Limits/Standards Applicable Regulation
Visible emissions 20 ercent opacity 15A NCAC 02D.0521
HAPs No applicable requirements 15A NCAC 02D.1111
Odors State Enforceable Onl► 15A NCAC 02D.1806
Odorous emissions must be controlled- See Section 2.2.A.2
1. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from these sources shall not be more than 20 percent opacity when averaged over a six-
minute period. However,six-minute averaging periods may exceed 20 percent not more than once in any hour
and not more than four times in any 24-hour period. In no event shall the six-minute average exceed 87
percent opacity.
Testing[15A NCAC 02Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the
results of the test performed exceed the limits given in Section 2.1.A.La. (above)for visible emissions,the
Permittee shall be deemed in noncompliance with 15A NCAC 02D.0521.
Monitorin /Recordkee in2/Re ortin [15A NCAC 02Q .0508(f)]
c. No monitoring,record keeping,or reporting is required for visible emissions from these emission sources.

Air Permit 03449T52
Page 9
B. Medium Density Fiberboard Facilities woodworking operations as presented in Table
2.1.13.
Table 2.1.13.
Emission Control
Source ID Emission Source Description Device ID Control Device Description
No. No.
ES-03 Fiber Sifter System CD03 Fabric Filter(12,290 square feet of filter
area)
ES-04 Forming Line Clean-Up System CD04 Fabric Filter(9,346 square feet of filter
area)
ES-05 Mat Reject System C1305 Fabric Filter(9,346 square feet of filter
area
ES-07 Saw System CD07 Fabric Filter(6,793 square feet of filter
area
ES-08 Sander System No. 1 CD08 Fabric Filter(12,290 square feet of filter
area
ES-09 Recycled Fiber Silo No. 1 CD09 Bin Vent Filter(226 square feet of filter
area)
ES-10 Sander System No.2 CD10 Fabric Filter(12,290 square feet of filter
area
ES-12 Sander Dust Silo No. 1 CD12 Bin Vent Filter(226 square feet of filter
area)
ES-13 Dry Sawdust Silo CD13 Bin Vent Filter(226 square feet of filter
area
ES-15 Recycled Fiber Silo No.2 CD15 Bin Vent Filter(226 square feet of filter
area
ES-17 Sander Dust Silo No.2 CD17 Bin Vent Filter(226 square feet of filter
area)
The following table provides a summary of limits and/or standards for the woodworking operations in Table 2.1.B.
Regulated Pollutant Limits/Standards Applicable Regulation
PM adeL uate duct work and prope U1 designed collectors 15A NCAC 02D.0512
Visible emissions 20 percent opacity 15A NCAC 02D.0521
National Emission Standards for Hazardous Air 15A NCAC 02D.1111
HAPs Pollutants:Plywood and Composite Wood Products (40 CFR Part 63 Subpart DDDD)
See Section 2.2 A.1
Odors State Enforceable Only 15A NCAC 02D.1806
See Section 2.2 A.2
NOx,PM2.5,PMio See Section 2.2 B.1. 15A NCAC 02Q.0317
(PSD Avoidance
VOCs Best Available Control Technology 15A NCAC 02D.0530
See Section 2.2 B.2.
1. 15A NCAC 02D.0512: PARTICULATES FROM WOOD PRODUCTS FINISHING PLANTS
a. 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. In no case shall the ambient
air quality standards be exceeded beyond the property line.

Air Permit 03449T52
Page 10
Monitoring [15A NCAC 02Q.0508(f)]
b. Particulate matter emissions from the MDF wood working operations shall be controlled as presented in Table
2.1.B. To ensure compliance,the Permittee shall perform inspections and maintenance as recommended by the
manufacturer,if any. As a minimum,the inspection and maintenance program shall include:
i. monthly external inspection of the ductwork,cyclones,and bagfilters noting the structural integrity;and
ii. annual(for each 12-month period following the initial inspection)internal inspection of the bagfilters
noting the structural integrity and the condition of the filters.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0512 if the ductwork,cyclones and/or
bagfilters are not inspected and maintained.
Recordkeeping[15A NCAC 02Q.0508(f)]
c. The results of inspection and maintenance for the cyclones and bagfilters shall be maintained in a logbook
(written or electronic format)on-site and made available to an authorized representative upon request. The
logbook shall record the following:
i. the date and time of each recorded action;
ii. the results of each inspection;and
iii. the results of maintenance performed on any control device.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0512 if these records are not
maintained.
Reporting[15A NCAC 02Q.0508(f)]
d. The Permittee shall submit the results of any maintenance performed on the control devices within 30 days of a
written request by the DAQ.
e. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on or
before January 30 of each calendar year for the preceding six-month period between July and December and
July 30 of each calendar year for the preceding six-month period between January and June. All instances of
deviations from the requirements of this permit must be clearly identified.
2. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the MDF wood working operations listed in Table 2.1.B.shall not be more than 20
percent opacity when averaged over a six-minute period. However,six-minute averaging periods may exceed
20 percent not more than once in any hour and not more than four times in any 24-hour period. In no event
shall the six-minute average exceed 87 percent opacity.
Testing[15A NCAC 02Q.0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in Section 2.1 B.2.a.,above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0521.
Monitoring [15A NCAC 02Q.0508(f)]
c. To ensure compliance,once a week the Permittee shall observe the emission points of these sources for any
visible emissions above normal.The weekly observations must be made for each week of the calendar year
period to ensure compliance with this requirement. If visible emissions from this source are observed to be
above normal,the Permittee shall either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements below,or
ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with
15A NCAC 02D.2610(Method 9)for 12 minutes is below the limit given in Section 2.1 B.2.a.above.
If the above-normal emissions are not corrected per(i)above or if the demonstration in(ii)above cannot be
made,the Permittee shall be deemed to be in noncompliance with 15A NCAC 02D.0521.

Air Permit 03449T52
Page 11
Recordkeeping [15ANCAC 02Q .0508(f)]
d. The results of the monitoring shall be maintained in a logbook(written or electronic format)on-site and made
available to an authorized representative upon request. The logbook shall record the following:
i. the date and time of each recorded action;
ii. the results of each observation and/or test noting those sources with emissions that were observed to be in
noncompliance along with any corrective actions taken to reduce visible emissions;and
iii. the results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0521 if these records are not
maintained.
Reporting[15ANCAC 02Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December and July 30 of each calendar
year for the preceding six-month period between January and June. All instances of deviations from the
requirements of this permit must be clearly identified.

Air Permit 03449T52
Page 12
C. Medium Density Fiberboard Facilities Operations as presented in Table 2A.C.
Table 2.1.C.
Emission Emission Source Control
Source Device ID Control Device Description Emission
ID No. Description p No. Point
CDO1 Refiner Abort Cyclone(66 inches
in diameter)a EPO 1
CD02 Venturi scrubber
ES-01 Refiner series with EP18
CD18 Biofilter
CD14 Venturi scrubber
In series with EP18
CD18 Biofilter
CD02-A Urea/water in'ection s stem EP18
Energy System consisting CD02 Venturi scrubber
of a dry/wet In series with EP18
ES-02-A wood/woodwaste-fired CD18 Biofilter
burner(205 million Btu per CD14 Venturi scrubber
hour heat input) In series with EP18
CD18 Biofilter
ES-02-B Two Stage Dryer System C1302 Venturi scrubber
In series with EP18
ES-02-C- Three backup natural gas- CD18 Biofilter
1,ES-02- fired dryer burners(35,35 CD14 Venturi scrubber
C-2 and and 17 million Btu per hour In series with
ES-02-D heat input respectively) CD18 Biofilter EP18
ES-06-B MDF Board Cooler CD02 Venturi scrubber
In series with EP18
CD18 Biofilter
CD14 Venturi scrubber
In series with EP18
CD18 Biofilter
CD02 Venturi scrubber
In series with EP18
ES-16 MDF Press and Press Hall CD18 Biofilter
CD14 Venturi scrubber
In series with EP18
CD18 Biofilter
2 For operation during startup,shutdown and malfunction only.

Air Permit 03449T52
Page 13
The following table provides a summary of limits and/or standards for the operations in Table 2.1.C.
rReMated Pollutant Limits/Standards livable Regulation
E=4.1 OP 1.67 or E=55.0(P)°-11-40
where;E=allowable emission rate in pounds per hour 15A NCAC 02D.0515
Pr dioxide 2.3 ounds'per million Btu heat input 15A NCAC 02D.0516
Visible emissions 20 ercent o acit 15A NCAC 02D.0521
PM 15A NCAC 02D.0614:
VOCs Compliance Assurance Monitoring
40 CFR 64
National Emission Standards for Hazardous Air
PM
Pollutants:Plywood and Composite Wood Products 15A NCAC 02D.I I I I
See Section 2.2 A.1 (40 CFR Part 63 Subpart DDDD)
Odors State Enforceable Only
See Section 2.2 A.2 15A NCAC 02D.1806
NOx,PM2.5,PMI° See Section 2.2 B.1. 15A NCAC 02Q.0317
(P SD Avoidance
VOCs Best Available Control Technology
See Section 2.2 B.2. 15A NCAC 02D.0530
HAPs
Schedule of Compliance 15A NCAC 021).1111
See Section 2.3 (40 CFR Part 63 Subpart DDDD)
VOCs 15A NCAC 02D.0530
1. 15A NCAC 02D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the emission sources in Table 2.1.C. shall not exceed an allowable
emission rate as calculated by the following equation(s):
Process Rate Allowable Emission Rate Equation
LLess than or ual to 30 tons per hour E=4.10 x P 0•67
Greater than 30 tons per hour E=55.0(P)0-"-40
Where E=allowable emission rate in pounds per hour
P=process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing[15A NCAC 02Q.0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in Section 2.1 C.La above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0515.
c. Under the provisions of NCGS 143-215.108,the Permittee shall demonstrate compliance with the emission
limit above on an annual basis by testing the emission point EP18 in accordance with General Condition JJ. If
the results of this test are less than 80 percent of the emission limit above,the Permittee shall be required to
stack test only once every five years following the previous stack test.If the results of this test are above the
limit given in Section 2.1 C.l.a.above,the Permittee shall be deemed in noncompliance with 15A NCAC 02D
.0515.

Air Permit 03449T52
Page 14
Monitoring[15A NCAC 02Q.0508(f)]
d. Particulate matter emissions from these sources shall be controlled by the venturi scrubbers as described in
Table 2.1.C.
e. The Permittee shall perform inspections and maintenance as recommended by the manufacturer.
f. The Permittee shall install,operate,and maintain instrumentation on the scrubbers identified in Table 2.1.C.to
continuously monitor the parameters in Table 2.1 C.Lf and maintain the parameters in the associated operating
ranges. These ranges are not required during performance testing.
Table 2.1 C.Lf
Parameter Control Device ID No. Minimum operating range,
per control device
Pressure drop(inches of water CD02 6.5
gauge,3-hour block average) CD14 6.5
Recirculating liquid flow rate CD02 378
(gallons per minute,3-hour block CD 14 416
average)
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515 if the monitoring requirements
in Sections 2.1 C.l.d through f are not met.
Recordkeeping[15A NCAC 02Q.0508(f)]
g. The results of any monitoring shall be maintained in a logbook(written or electronic format)on-site and made
available to an authorized representative upon request. The logbook shall record the following:
i. the date and time of each recorded action;
ii. the results of each inspection;
iii. the results of any maintenance performed on the control devices;
iv. any variance from manufacturer's recommendations,if any,and corrections made;and
v. pressure drop,and recirculating flow rate,(3 hour block averages)for each venturi scrubber.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515 if these recordkeeping
requirements are not met.
Reuorting[15A NCAC 02Q.0508(f)]
h. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on or
before January 30 of each calendar year for the preceding six-month period between July and December and
July 30 of each calendar year for the preceding six-month period between January and June. All instances of
deviations from the requirements of this permit must be clearly identified.
2. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the emission sources in Table 2.1.C.shall not be more than 20 percent opacity when
averaged over a six-minute period. However,six-minute averaging periods may exceed 20 percent not more
than once in any hour and not more than four times in any 24-hour period. In no event shall the six-minute
average exceed 87 percent opacity.
Testing[15A NCAC 02Q.0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in Section 2.1 C.2.a above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0521.
Monitoring[15A NCAC 02Q.0508(f)]
c. To ensure compliance,once a week the Permittee shall observe the emission point(EP18)for any visible
emissions above normal. The weekly observation must be made for each week of the calendar year period to
ensure compliance with this requirement.The Permittee shall re-establish"normal"within 30 days after the
initial operation of the biofilter(ID No.CD18)after the modifications undertaken in application no.
1900015.18A are completed.If visible emissions from this source are observed to be above normal,the
Permittee shall either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements below,or

Air Permit 03449T52
Page 15
ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with
15A NCAC 02D.2610(Method 9)for 12 minutes is below the limit given in condition a.above.
If the above-normal emissions are not corrected per(i)above or if the demonstration in(ii)above cannot be
made,the Permittee shall be deemed to be in noncompliance with 15A NCAC 02D.0521.
Recordkee in [15A NCAC 02Q.0508(f)]
d. The results of the monitoring shall be maintained in a logbook(written or electronic format)on-site and made
available to an authorized representative upon request. The logbook shall record the following:
i. the date and time of each recorded action;
ii. the results of each observation and/or test noting those sources with emissions that were observed to be in
noncompliance along with any corrective actions taken to reduce visible emissions;and
iii. the results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0521 if these records are not
maintained.
Reporting[15A NCAC 02Q.0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December and July 30 of each calendar
year for the preceding six-month period between January and June. All instances of deviations from the
requirements of this permit must be clearly identified.
3. 15A NCAC 02D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from 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-02-1))shall not
exceed 2.3 pounds per million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels,
wastes,ores,and other substances shall be included when determining compliance with this standard.
Testing[15A NCAC 02Q.0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.If the
results of this test are above the limit given in Section 2.1 C.3.a above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0516.
Monitoring/Recordkeeoine/Reporting [15A NCAC 02Q.0508(f)]
c. No monitoring,recordkeeping or reporting is required for sulfur dioxide emissions from wood combustion for
these sources.
4. 15A NCAC 02D.0614:COMPLIANCE ASSURANCE MONITORING[40 CFR 641
a. Pursuant to 40 CFR 64 and 15A NCAC 02D.0614,the Permittee shall comply with the conditions below for
the Pollutant Specific Emission Unit(s)controlled by the venturi scrubbers(ID Nos.CD02 and CD14).
Emission Limitations/Standards
b. The following table presents the regulated pollutants and the associated emission limitations/standards:
Regulated Pollutant Limits/Standards Applicable Regulation
PM See Section 2.1 C.1 15A NCAC 02D.0515
Monitoring Approach,[15A NCAC 02Q.0508(f),40 CFR 64.6]
c. The key elements of the monitoring approach for PM,including parameters to be monitored,parameter ranges
and performance criteria are presented in the following table.

Air Permit 03449T52
Page 16
Monitoring Indicator No. 1
Elements Indicator No.2
Measurement Injection rate measurements are made every Pressure drop measurements are made every
Approach 15 minutes 15 minutes
64.6 c 1 (i),(ii)]
Indicator Range An excursion is defined as a one-hour block An excursion is defined as a one-hour block
[64.6(c)(2)] average injection rate reading lower than the average pressure drop reading lower than the
respective 3-hour block average reading listed respective 3-hour block average reading listed
in Table 2.1 C.I of this permit.Excursions in Table 2.1 C.Lf of this permit.Excursions
trigger an inspection and corrective action. trigger an in pection and corrective action.
QIP threshold The QIP threshold is six excursions in a six- The QIP threshold is six excursions in a six-
[64.81 month Leporting period. month reporting period.
Data Measurements are made once every 15 Measurements are made once every 15
Representativeness minutes and complied into the appropriate minutes and complied into the appropriate
[64.6(c)(1)(iii), averaging periods. averaging periods.
64.3 b 1
Verification of Monitoring shall be required upon issuance of permit no.03449T45
Operational Status
64.3(b)(2
QA/QC Practices Flowmeter calibration shall be performed Pressure transducer calibration shall be
and Criteria according to manufacturer recommendations. performed according to manufacturer
[64.3(b)(3)1recommendations.
Monitoring Measurements are made by a computerized data acquisition and handling system once every 15
frequency minutes and complied into the appropriate averaging periods.
[64.3(b)(4)]
Data collection Non-SSM periods when flowrate or pressure drop falls below the acceptable ranges for more
procedure than one-hour will be documented.An electronic or written logbook will be kept of all control
[64.3(b)(4)] device inspections and corrective actions.
Recordkee in g Reg uirements[15A NCAC 02Q.0508(f),40 CFR 64.9]
d. The owner or operator shall maintain records of the following:
i. Date and time and results of all monitoring activities;
ii. Information on the number,duration and cause(including unknown cause,if applicable)of excursions or
exceedances,as applicable,and the corrective actions taken;
iii. Maintenance records of the differential pressure gauge;and
iv. Written QIP required pursuant to 40 CFR 64.8 and any activities undertaken to implement a quality
improvement plan.
Reporting Requirements[15A NCAC 02Q.0508(f),40 CFR 64.9]
e. The Permittee shall submit a summary report of all monitoring activities postmarked on or before January 30
of each calendar year for the preceding six-month period between July and December and July 30 of each
calendar year for the preceding six-month period between January and June. All instances of deviations for the
requirements of this permit must be clearly identified. At a minimum,the report shall include the following
elements:
i. Summary information on the number,duration and cause(including unknown cause,if applicable)of
excursions or exceedances,as applicable,and the corrective actions taken;
ii. Summary information on the number,duration and cause(including unknown cause,if applicable)for
monitor downtime incidents(other than downtime associated with zero and span or other daily calibration
checks,if applicable);and
iii. A description of the actions taken to implement a QIP during the reporting period as specified in 40 CFR
64.8.Upon completion of a QIP,the owner or operator shall include in the next summary report
documentation that the implementation of the plan has been completed and reduced the likelihood of
similar levels of excursions or exceedances occurring.

Air Permit 03449T52
Page 17
5. 15A NCAC 02D.0614: COMPLIANCE ASSURANCE MONITORING 140 CFR 641
a. Pursuant to 40 CFR 64 and 15A NCAC 2D.0614,the Permittee shall comply with the conditions below for the
Pollutant Specific Emission Unit(s)controlled by the biofilter(ID No.CD-18).
Emission Limitations/Standards
b. The following table presents the regulated pollutants and the associated emission limitations/standards:
Regulated Pollutant Limits/Standards EAppUcable Regulation
VOCs Best Available Control Technolog
See Section 2.2 B.2. AC 02D.0530
Monitoring roach[15A NCAC 02Q.0508(f),40 CFR 64.6]
c. The Permittee has elected to satisfy the presumptively acceptable monitoring requirements under MACT
DDDD for the biofilter as allowed at 40 CFR 64.4(b)(4).The Permittee shall be deemed in noncompliance
with 15A NCAC 02D.0530 if the biofilter bed minimum and maximum temperatures are outside the indicator
range found at Section 2.2 A.l.h.
RecordkeWing and Reoorting RA uirements[15A NCAC 02Q.0508(f),40 CFR 64.9]
d. The Permittee shall meet the recordkeeping and reporting requirements found in Section 2.2 A.l.aa through ii,
as applicable.The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if these
requirements are not met.
6. 15A NCAC 02D.0530(u): USE OF PROJECTED ACTUAL EMISSIONS TO AVOID APPLICABILITY OF
PREVENTION OF SIGNIFICANT DETERIORATION REQUIREMENTS
a. i. The Permittee 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 to achieve increases in throughput,reliability and safety when firing natural gas.
This project does not result in an increase in overall design capacity of the MDF Mill.This project is fully
described in application no. 1900015.17D.
ii. The Permittee has used projected actual emissions to avoid applicability of Prevention of Significant
Deterioration requirements for a project consisting of modifications to the MDF Mill to achieve increases
in throughput.This project is expected to result in an increase in overall design capacity of the MDF Mill.
This project is fully described in application no. 1900015.18A.
In order to verify the assumptions used in the projected actual emissions calculations,the Permittee shall
comply with the testing,record keeping and reporting requirements in Sections 2.1 C.6.b through a below.
Testing[15A NCAC 02Q.0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance General Condition JJ.
Recordkee i [15A NCAC 02D.0530(u)]
c. The Permittee shall maintain records of the actual emissions of PMIo,PM2.5,NO,and CO from the sources
indicated in the permitted equipment list in Section 1 as the Medium Density Fiberboard(MDF)Facilities
(MDF Facilities)in tons per year.Records shall start following the resumption of regular operations after the
modifications described in application no. 1900015.17D and shall continue for ten years after the resumption
of regular operations after the modifications described in application no. 1900015.18A.The first year shall
start on the first day of the first full calendar month after commencing regular operations after the modification
described in application no. 1900015.17D.Each subsequent year shall include the same 12-month period.
d. The reported actual emissions(post-construction emissions)of the MDF Facilities for each of the years will be
compared to the projected actual emissions(pre-construction projection)for the dryer as included below:

Air Permit 03449T52
Page 18
F7Pollutant Projected ActuaJyearl
Emissions*{tons er
PM10 92
PM2.5 92
NOx 144
CO 251
* These projections are not enforceable limitations. If projected emissions are exceeded,consistent
with 15A NCAC 02D.0530,the permittee shall include in its annual report an explanation as to
why the actual rates exceeded the projection.
The Permittee shall make the information,documented and maintained in this condition available to the
Director or the general public pursuant to the requirements in 40 CFR 70.4(1b)(3)(viii).
Reporting[15A NCAC 02D.0530(u)]
e. The Permittee shall submit a report of the actual emissions of the pollutants identified in Section 2.1 C.6.c from
the MDF Facilities to the Director within 60 days after the end of each year(as deemed in Section 2.1 C.6.c)
during which the records in Section 2.1 C.6.c must be generated. The report shall contain the items listed in 40
CFR 51.166(r)(6)(v)(a)through(c).
D. The following sources for the Medium Density Fiberboard Facilities
Emission Source ID No. Emission Source Description Control Control Device
Device ID No. Descri tion
ES-18,ES-19,and ES-20 Three natural gas-fired hot oil heaters
NSPS Dc (30.4 million Btu per hour maximum NA NA
MACT DDDDD heat in ut each)
The following table provides a summary of limits and/or standards for the emission sources above:
Regulated Pollutant Limits/Standards licable Re ulation
PM 0.25 pounds per million Btu heat input 15A NCAC 02D.0503
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 02D.0516
Visible emissions 20 percent o acih 15A NCAC 02D.0521
NA Notification and Recordkeeping 15A NCAC 02D.0524(NSPS
Subpart Dc
HAPs Annual tune ups 15A NCAC 02D.1111
Odors State-Enforceable Only 15A NCAC 02D.1806
See Section 2.2 A.2
NOx,PM2.5,PMto See Section 2.2 B.1. 15A NCAC 02Q.0317
(PSD Avoidance)
VOCs Best Available Control Technology 15A NCAC 02D.0530
See Section 2.2 B.2.
1. 15A NCAC 02D.0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS
a. Emissions of particulate matter from the combustion of natural gas that are discharged from these sources into
the atmosphere shall not exceed 0.25 pounds per million Btu heat input.
Testing [15A NCAC 02Q.0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance General Condition JJ.If the results
of this test are above the limit given in condition a.above,the Permittee shall be deemed in noncompliance
with 15A NCAC 02D.0503.
Monitoring/Recordkeepin-./Reporting [15A NCAC 02Q.0508(f)]
c. No monitoring/recordkeeping/reporting is required for particulate emissions from the firing of natural gas in
these sources.

Air Permit 03449T52
Page 19
2. 15A NCAC 02D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from these sources shall not exceed 2.3 pounds per million Btu heat input. Sulfur
dioxide formed by the combustion of sulfur in fuels,wastes,ores,and other substances shall be included when
determining compliance with this standard.
Testing[15A NCAC 02Q.0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in condition a.above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0516.
Monitoring/Recordkeeping [15A NCAC 02Q .0508(f)]
c. No monitoring/recordkeeping is required for sulfur dioxide emissions from natural gas combustion for these
sources.
3. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from these sources shall not be more than 20 percent opacity when averaged over a six-
minute period. However,six-minute averaging periods may exceed 20 percent not more than once in any hour
and not more than four times in any 24-hour period. In no event shall the six-minute average exceed 87
percent opacity.
Testing[15A NCAC 02Q.0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in condition a.above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0521.
Monitorin,/Recordkeepin2/Renortin2 [15A NCAC 02Q.0508(f)]
c. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of natural gas in these
sources.
4. 15A NCAC 02D.0524:NEW SOURCE PERFORMANCE STANDARDS
a. For these sources,the Permittee shall comply with all applicable provisions,including the notification,testing,
recordkeeping,and monitoring requirements contained in Environmental Management Commission Standard
15A NCAC 02D.0524"New Source Performance Standards(NSPS)as promulgated in 40 CFR Part 60
Subpart Dc,"Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating
Units"including Subpart A"General Provisions."
Recordkeepin:,Reuuirements[15ANCAC 02Q.0508(f)]
b. The Permittee shall record and maintain records of the amounts of each fuel fired during each month. [40 CFR
60.48c(g)(2)]These records shall be maintained by the Permittee for a period of two years following the date
of such record. [40 CFR 60.48c(i)]The Permittee shall be deemed in noncompliance with 15A NCAC 02D
.0524 if these recordkeeping requirements are not met.
Notification Requirements[15A NCAC 02Q.0508(f)]
c. The Permittee shall submit notification of the actual startup for each source within 15 days after such date. [40
CFR 60.7(a)(3),60.48c(a)]
5. 15A NCAC 02D.1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
Applicability[40 CFR 63.7485, §63.7490,§63.7499(l)]
a. For these sources the Permittee shall comply with all applicable provisions,including the monitoring,
recordkeeping,and reporting contained in Environmental Management Commission Standard 15A NCAC 02D
.1111 "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"and Subpart A"General Provisions."

Air Permit 03449T52
Page 20
Definitions and Nomenclature[§63.7575]
b. For the purpose of this permit condition,the definitions and nomenclature contained in§63.7575 shall apply.
40 CFR Part 63 Subpart A General Provisions[§63.7565]
c. The Permittee shall comply with the requirements of 40 CFR 63 Subpart A General Provisions according to the
applicability of Subpart A to such sources as identified in Table 10 to 40 CFR Part 63,Subpart DDDDD.
Compliance Date 1§63.7495(a)]
d. The Permittee shall comply with the applicable requirements upon startup of these sources.
Notifications 1§63.7545]
e. As specified in§63.9(b)(4)and(5),the Permittee shall submit an Initial Notification to the DAQ not later than
15 days after the actual date of startup of each affected source.l§ 63.7545(c)]
Work Practice Standards[15A NCAC 02Q.0508(f)]
f. i. The Permittee shall conduct a tune-up every five years for each source while burning the type of fuel(or
fuels in case of units that routinely bum a mixture)that provided the majority of the heat input to the boiler
or process heater over the 12 months prior to the tune-up,as specified below:
(A) As applicable,inspect the burner,and clean or replace any components of the burner as necessary.
The Permittee may perform the burner inspection any time prior to the tune-up or delay the burner
inspection until the next scheduled or unscheduled shutdown,but the burner must be inspected at least
once every 72 months.
(B) Inspect the flame pattern,as applicable,and adjust the burner as necessary to optimize the flame
pattern.The adjustment should be consistent with the manufacturer's specifications,if available;
(C) Inspect the system controlling the air-to-fuel ratio,as applicable,and ensure that it is correctly
calibrated and functioning properly(you may delay the inspection until the next scheduled unit
shutdown).
(D) Optimize total emissions of CO.This optimization should be consistent with the manufacturer's
specifications,if available,and with any NOx requirement to which the unit is subject.
(E) Measure the concentrations in the effluent stream of CO in parts per million,by volume,and oxygen
in volume percent,before and after the adjustments are made(measurements may be either on a dry or
wet basis,as long as it is the same basis before and after the adjustments are made).Measurements
may be taken using a portable CO analyzer.
(F) set the oxygen level no lower than the oxygen concentration measured during the most recent tune-up.
[§63.7500(a),§63.7540(a)(10),(a)(12)]
ii. Each 5-year tune-up shall be conducted no more than 61 months after the previous tune-up.The initial
tune-up shall be conducted no later than 61 months after the initial startup of the source. [40 CFR
63.7515(d)]
iii. If the unit is not operating on the required date for a tune-up,the tune-up must be conducted within 30
calendar days of startup. [§63.7540(a)(13),§63.7515(g)]
iv. At all times,you must operate and maintain any affected source,including associated air pollution control
equipment and monitoring equipment,in a manner consistent with safety and good air pollution control
practices for minimizing emissions.Determination of whether such operation and maintenance procedures
are being used will be based on information available to the Administrator that may include,but is not
limited to,monitoring results,review of operation and maintenance procedures,review of operation and
maintenance records,and inspection of the source. [§63.7500(a)(3)]
v. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the requirements in
Section 2.1 D.5.f are not met.
Recordkeevine Requirements[15A NCAC 02Q.0508(f)]
g. The Permittee shall:
i. keep a copy of each notification and report submitted to comply with this subpart,including all
documentation supporting any Initial Notification or Notification of Compliance Status,or compliance
report that has been submitted,according to the requirements in§63.10(b)(2)(xiv). [§63.7555(a)(1)]
ii. maintain on-site and submit,if requested by the Administrator,a report containing the information in
paragraphs(A)through(C)below:
(A) The concentrations of CO in the effluent stream in parts per million by volume,and oxygen in volume
percent,measured at high fire or typical operating load,before and after the tune-up of the boiler or

Air Permit 03449T52
Page 21
process heater;
(B) A description of any corrective actions taken as a part of the tune-up;and
(C) The type and amount of fuel used over the 12 months prior to the tune-up,but only if the unit was
physically and legally capable of using more than one type of fuel during that period.Units sharing a
fuel meter may estimate the fuel use by each unit.
[§63.7540(a)(10)(vi)]
iii. keep the associated records for Section 2.1 D.5.f;
iv. maintain records in a form suitable and readily available for expeditious review;
v. keep each record for 5 years following the date of each occurrence,measurement,maintenance,corrective
action,report,or record;and
vi. keep each record on site for at least 2 years after the date of each occurrence,measurement,maintenance,
corrective action,report,or record.The Permittee can keep the records offsite for the remaining 3 years.
[§63.7560,§63.10(b)(1)]
vii. be deemed in noncompliance with 15A NCAC 02D.I I I I if records are not maintained pursuant to
Section 2.1 D.5.g.
Revorting Reguirements[15A NCAC 02Q.0508(f)]
h. i. The Permittee shall submit compliance reports to the DAQ on a 5-year basis.The first report shall cover
the period beginning on the compliance date specified in Section 2.1 D.5 d(i.e.,start-up)and ending on
the earliest December 3111 less than one year from the compliance date. Subsequent 5-year reports shall
cover the periods from January 1 to December 31.The Permittee shall submit the compliance reports
postmarked on or before January 30 for the previous compliance period. [§63.7550(a),(b]
ii. The compliance report must also be submitted electronically via the Compliance and Emissions Data
Reporting Interface(CEDRI).CEDRI can be accessed through the EPA's Central Data Exchange(CDX)
(https://cdx.epa.gov/).)You must use the appropriate electronic report in CEDRI for this subpart.Instead
of using the electronic report in CEDRI for this subpart,you may submit an alternate electronic file
consistent with the XML schema listed on the CEDRI Web site
(http://www.epa.gov/ttn/chief/cedri/index.html),once the XML schema is available.If the reporting form
specific to this subpart is not available in CEDRI at the time that the report is due,you must submit the
report to the Administrator at the appropriate address listed in§63.13.You must begin submitting reports
via CEDRI no later than 90 days after the form becomes available in CEDRI. [§63.7550(h)(3)]
iii. The compliance report must contain the following information:
(A) Company name and address;
(B) Process unit information,emissions limitations,and operating parameter limitations;
(C) Date of report and beginning and ending dates of the reporting period;
(D) Include the date of the most recent tune-up for each unit required according to Section 2.1 D.5.f.
Include the date of the most recent burner inspection if it was not done on a 5-year period and was
delayed until the next scheduled or unscheduled unit shutdown.
(E) Statement by a responsible official with that official's name,title,and signature,certifying the truth,
accuracy,and completeness of the content of the report.
[§63.7550(a)and(c),Table 9]
iv. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the reporting
requirements in Section 2.1 D.5.h are not met.

Air Permit 03449T52
Page 22
E. The following Particleboard Mill operations:
Table 2.1 E.1
Emission Control
Source Emission Source Description Device Control Device Description
ID No. ID No.
Particleboard Mill Combustion Sources and Drvers
Surface layer triple pass,rotary drum CD-1431 High efficiency multi-cyclone with 2 tubes,
(#3)dryer with one wood suspension each 132 inches in diameter
1430 dust/natural gas-fired burner(60 CD-PB- Wet electrostatic precipitator
million Btu per hour maximum rated WESP
heat input)
Core layer single pass,rotary drum CD-1421 High efficiency multi-cyclone with 4 tubes,
(#1)dryer with one wood suspension each 80 inches in diameter
1420 dust/natural gas-fired burner(50 CD-PB- Wet electrostatic precipitator
million Btu per hour maximum rated WESP
heat input)
Operating Scenario 1 CD-1431 High efficiency multi-cyclone with 2 tubes,
One"Wellons"unit operating as a each 132 inches in diameter
natural gas-fired burner(21.8 million AND/OR
Btu per hour maximum rated heat
input); CD-1421 High efficiency multi-cyclone with 4 tubes,
each 80 inches in diameter
3201 exhausting to either
AND
surface layer triple pass,rotary drum
(#3)dryer[ID No. 14301 and/or CD-PB- Wet electrostatic precipitator
WESP
core layer single pass,rotary drum(#1
dryer ID No. 1420
Operating Scenario 2
3201 One"Wellons"unit operating as a NA NA
natural gas-fired indirect heat
exchanger(21.8 million Btu per hour
maximum rated heat input)

Air Permit 03449T52
Page 23
` Table 2.1 E.2
Emission Emission Source Control Device
Source Description ID No. Control Device Description
ID No.
Particleboard Mill Other Operations
Sawdust Rock CD-SC Hirsh efficiency cyclone-72 inches in diameter
F3501 and Metal CD-3501 Reverse flow bag filter with 2,410 square feet of surface
Separator area
CD-3500, Simple cyclone-72 inches in diameter
Surface Material CD-3525 Reverse flow fabric filter with 6,918 square feet of surface
Transport area
3515 (SL fines from in parallel with
screening CD-3512B, Simple cyclone-72 inches in diameter
operation) CD-3515 Reverse flow fabric filter with 5,767 square feet of surface
area
CD-3520A, Three(3)simple cyclones-each 96 inches in diameter
Surface Formers CD-3520B,
3525 and Mat Dumps CD-3521
Reverse flow fabric filter with 6,918 square feet of surface
CD-3525 area
Flying Cut Off Saw CD-3530 Simple cyclone-84 inches in diameter
3535 Pretrim Saws,& CD-3531 Simple cyclone- 108 inches in diameter
Production CD-3533 Simple cyclone- 108 inches in diameter
Collection I CD-3535 Reverse flow fabric filter with 6,918 square feet of filter area
CD-2006, Reverse flow bag filter with 6,918 square feet of surface
area
Particleboard Mill CD-3570, in series with
3545 Steinemann CD-3575 High efficiency cyclone- 144 inches in diameter
Finishing Sander in series with
Reverse flow bag filter with 1,159 square feet of surface
area
DEF-2010 Particleboard Press N/A N/A
PB-BC Particleboard N/A N/A
Cooler
CD-5001, Reverse flow fabric filter with 6,918 square feet of surface
area
Particleboard Mill CD-3570, in series with
3565 Steinemann CD-3575 High efficiency cyclone- 144 inches in diameter
Calibrating Sander in series with
Reverse flow bag filter with 1,159 square feet of surface
area
Schelling Saw CD-3522, High efficiency cyclone- 120 inches in diameter
3555 Board Trim CD-4005 Reverse flow bag filter with 6,918 square feet of surface
area
Sander Filter CD-3570, High efficiency cyclone- 144 inches in diameter
3575 Transport for Filters CD-3575 Reverse flow bag filter with 1,159 square feet of surface
3545&3565 1 area
3585 PZKR Green Chip CD-3585 Reverse flow bag filter with 4,880 square feet of surface
Makers area
3595 Oversize Material CD-3595 Reverse flow bagfilter(Maximum air-to-cloth ratio of 3.0
Palhnann Mill ACFM/total filter surface areaj.
CD-3532, Simple cyclone-60 inches in diameter
3577 Dry waste transport
system CD-3577 Reverse flow bag filter with 4,068 square feet of surface
area

Air Permit 03449T52
Page 24
The following table provides a summary of limits and/or standards for the particleboard mill.
Regulated Pollutant Limits/Standards Applicable Regulation
PM 0.30 lb/million Btu(ID No.3201)(OS-2 only) 15A NCAC 02D.0503
PM adequate duct work and properly designed collectors 15A NCAC 02D.0512
Affected facilities:
Sources listed in Table 2.1 E.2
PM E=4.10P 0.67 when P<30 tons per hour 15A NCAC 02D.0515
Or
E=55.OP 0•11 when P>30 tons per hour
where E=allowable emission rate in pounds per hour
P=process weight in tons per hour
Affected facilities:
Sources listed in Table 2.1 E.1 except(ID No.3201)
during OS-2
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 02D.0516
Affected facilities:
Sources listed in Table 2.1 E.1
Visible emissions 20 percent opacity opacfty 15A NCAC 02D.0521
PM10 15A NCAC 02D.0530
Carbon monoxide
VOCs See Section 2.1 E.6.
Nitrogen dioxide
Visible emissions
PM,PM10,VOC Compliance Assurance Monitoring 15A NCAC 02D.0614
40 CFR 64
HAPs National Emission Standards for Hazardous Air 15A NCAC 02D.1111
Pollutants for Major Sources:Industrial,Commercial, (40 CFR Part 63 Subpart
and Institutional Boilers and Process Heaters DDDDD)
(ID No.3201) (OS-2 onh)
HAPs National Emission Standards for Hazardous Air 15A NCAC 02D.1111
Pollutants:Plywood and Composite Wood Products (40 CFR Part 63 Subpart DDDD)
See Section 2.2 A.1
Odors State Enforceable Onh- 15A NCAC 02D.1806
See Section 2.2 A.2

Air Permit 03449T52
Page 25
1. 15A NCAC 02D.0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS
a. Emissions of particulate matter from the Wellons(ID No 3201,when operating in OS-2 only)that are
discharged from this source into the atmosphere shall not exceed 0.33 pounds per million Btu heat input.
Testing[15A NCAC 02Q.0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.If the
results of this test are above the limit given in Section 2.1 E.La above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0503.
Monitoring/Recordkeeping/Reporting[15A NCAC 02Q.0508(f)]
c. No monitoring/recordkeeping/reporting is required for particulate emissions from the firing of natural gas in
this source.
2. 15A NCAC 02D.0512: PARTICULATES FROM WOOD PRODUCTS FINISHING PLANTS
a. 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. In no case shall the ambient
air quality standards be exceeded beyond the property line.
Monitoring/Recordkeeping[15A NCAC 02Q.0508(f)]
b. Particulate matter emissions from the sources in Table 2.1 E.2 shall be controlled as presented in Table 2.1 E.2.
i. No monitoring,recordkeeping or reporting shall be required for the particulate matter emissions from the
particleboard press(ID No.DEF-2010)and particleboard cooler(ID No.PB-BC).
c. To ensure compliance,the Permittee shall perform inspections and as follows:
i. monthly external inspection of the duct work and cyclones,noting the structural integrity;and
ii. internal inspection of the bag filters,every 12 months,noting the structural integrity and the condition of
the filters.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0512 if the ductwork,cyclones,and
bag filters are not inspected and maintained.
d. The results of inspection and maintenance for the cyclones,and bag filters shall be maintained in a logbook
(written or electronic format)on-site and made available to an authorized representative upon request. The
logbook shall record the following:
i. the date and time of each recorded action;
ii. the results of each inspection;and
iii. the results of maintenance performed on any control device.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0512 if these records are not
maintained.
Reporting[15A NCAC 02Q.0508(f)]
e. The Permittee shall submit the results of any maintenance performed on the control devices in Table E.2 within
30 days of a written request by the DAQ.
f. The Permittee shall submit a summary report of monitoring and record keeping activities postmarked on or
before January 30 of each calendar year for the preceding six-month period between July and December and
July 30 of each calendar year for the preceding six-month period between January and June. All instances of
deviations from the requirements of this permit must be clearly identified.

Air Permit 03449T52
Page 26
3. 15A NCAC 02D.0515:PARTICULATE EMISSIONS FROM MISCELLANEOUS INDUSTRIAL
PROCESSES
a. Emissions of particulate matter from the emission sources in Table 2.1 E.1 that are discharged into the
atmosphere shall not exceed an allowable emission rate as calculated by the following equations:
Process Rate Allowable Emission Rate Equation
Less than or equal to 30 tons per hour E=4.10 x P 1.61
Greater than 30 tons per hour E=55.0(P)0•11-40
Where E=allowable emission rate in pounds per hour
P=process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing[15A NCAC 02Q.0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the
results of the test performed exceed the limits given in Section 2.1 E.3.a above for particulate matter,the
Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515.
Monitorin ecordkee in [15A NCAC 02Q.0508(f)]
c. Particulate matter emissions from the emission sources in Table 2.1 E.1.shall be controlled as presented in
Table 2.1 E.1
d. The monitoring,recordkeeping,and reporting requirements required in Sections 2.1 E.6.d.ii,e,f,i,m,and n
shall be followed in order to demonstrate compliance with 15A NCAC 02D.0515.
4. 15A NCAC 02D.0516:SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Sulfur dioxide from the emission sources in Table 2.1 E.1 shall not exceed 2.3 pounds per million Btu heat
input. Sulfur dioxide formed by the combustion of sulfur in fuels,wastes,ores,and other substances shall be
included when determining compliance with this standard.
Testing[15A NCAC 02Q.0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in Section 2.1 EA.a above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0516.
Monitoring/Recordkeeuing/Regorting[15A NCAC 02Q.0508(f)]
c. No monitoring,record keeping,or reporting is required for sulfur dioxide emissions from then sources.in Table
2.1 E.I.
5. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the emission sources in Table 2.1 E.1 and 2.1 E.2 shall not be more than 20 percent
opacity when averaged over a six-minute period. However,six-minute averaging periods may exceed 20
percent not more than once in any hour and not more than four times in any 24-hour period. In no event shall
the six-minute average exceed 87 percent opacity.
Testing[15A NCAC 02Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the
results of the test performed exceed the limits given in Section 2.1 E.5a above for visible emissions,the
Permittee shall be deemed in noncompliance with 15A NCAC 02D.0521.
Monitoring/RecordkeeBing[15A NCAC 02Q.0508(f)]
c. To ensure compliance,the Permittee shall observe,on a weekly basis,the following emission points in the
Particleboard mill for any visible emissions above normal:

Air Permit 03449T52
Page 27
Emission Source Description and ID No.
P Emission Point ID No.
Sawdust Rock and Metal Separator ID No.3501 CD-3501
Surface Layer Dryer JED No. 1430 -
Core Layer PQer#1 ID No.1420 CD-PB-ESP
"Wellons"Burner ID No.3201 OS-1 only)*
Particleboard Press ID No.DEF-2010 DEF-2010
Surface Material Transport ID No.3515) CD-3515 and CD-3525
Surface Formers and Mat Dumps ID No.3525 CD-3525
FlyiR&Cut Off Saw,Pretrim Saws,and Production Collection ID No.3535 CD-3535
Board Cooler ID No.PB-BC) PB-BC
Particleboard Mill Steinmann Calibrating Sander(ID No.3565) CD-3575
Particleboard Mill Steinmann Finishing Sander ID No.3545 CD-3575 and CD-2006
Schelhag Saw Board Trim ID No.3555 CD-4005
Sander Filter Transport for Filters 3545 and 3565 ID No.3575 CD-3575
PZKR Green Chip Flakers ID No.3585 CD-3585
Oversized Material Pallmann Mill ID No.3595 CD-3595
Dry Waste Transport System(I D No.3577 CD-3577
* No observations are required for the Wellons burner(ID No.3201)when operating in OS-2.
The weekly observation must be made for each week of the calendar year period to ensure compliance with
this requirement. If visible emissions from these sources are observed to be above normal,the Permittee shall
either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements below,or
ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with
15A NCAC 02D.2610(Method 9)for 12 minutes is below the limit given in condition a.above.
If the above-normal emissions are not corrected per(i)above or if the demonstration in(ii)above cannot be
made,the Permittee shall be deemed to be in noncompliance with 15A NCAC 02D.0521.
d. The results of the monitoring for visible emissions shall be maintained in a logbook(written or electronic
format)on-site and made available to an authorized representative upon request.To ensure quality,entries in
the logbook should be signed by personnel responsible for the effective operation of the units in the
particleboard mill and their air pollution control devices.The logbook shall record the following:
i. the date and time of each recorded action;
ii. the results of each observation and/or test noting those sources with emissions that were observed to be in
noncompliance along with any corrective actions taken to reduce visible emissions;and
iii. the results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0521 if these records are not
maintained.
Renortin[15A NCAC 02Q.0508(f)]
e. The Permittee shall submit a summary report of monitoring and record keeping activities postmarked on or
before January 30 of each calendar year for the preceding six-month period between July and December and
July 30 of each calendar year for the preceding six-month period between January and June. All instances of
deviations from the requirements of this permit must be clearly identified.

Air Permit 03449T52
Page 28
6. 15A NCAC 02D.0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. For PSD purposes,the following'Best Available Control Technology"(BACT)permit limitations shall not be
exceeded for units in the particleboard mill(ID No.PB):
Emission Source Pollutants Emission Limits*, Control Technology
Sawdust Rock and Metal PM10 0.02 lbs/hr cyclone and ba house
Separator(ID No.3501) VOC 5.56 lbs/hr,as C none
Opacity 20 percent cyclone and ba house
PM10 28.3 lbs/hr"" good combustion control with
Surface Layer Dryer(ID No. existin multi-cvclones and wet ESP
1430) VOC 163.3 lbs/hr,as C*" good combustion control with
Core Layer Dryer # 1(ID No. existingwet ESP
1420) CO 329.4 lbs/hr" good combustion control
NOx 94.7 lbs/hr" ood combustion control
Surface Material Transport(ID PM10 0.02 lbs/hr cyclones and ba house
No.3515) VOC 46.5 lbs/hr,as C none
Opacity 20 percent cyclones and ba house
Surface Formers and Mat Dumps PM10 0.06 lbs/hr cyclones and ba house
(ID No.3525) VOC 1.95 lbs/hr,as C none
Opacity 20 percent cyclones and ba house
Flying Cut Off Saw,Pretrim PM10 0.005 lbs/hr cyclones and ba house
Saws,and Production Collection VOC 1.77 lbs/hr,as C none
(ID No.3535) Opacity 20 2ercent cyclones and ba house
Particleboard Press(ID No. PM10 3.29 lbs/hour none
DEF-2010)and Board Cooler VOC 32.1 lbs/hour as C none
(ID No.PB-BC) Opacity 20 .ercent none
Particleboard Steinemann PM10 0.02 lbs/hour c clone and ba houses
Calibrating Sander(ID No.3565) VOC 1.08 lbs/hour as C none
Opacity 20 percent cyclone and ba houses
Particleboard Steinemann PM10 1.2 lbs/hour cyclone and ba houses
VOC 0.35 lbs/hour as C none
Finishing Sander(ID No.3545)
❑ acity 20 percent cyclone and ba houses
Schelling Saw Board Trim(ID PM10 0.01 lbs/hour cyclone and b house
No.3522) VOC 0.72 lbs/hour as C none
Opacity 20 percent cyclone and ba house
Sander Filter Transport for Filters PM10 4.0 lbs/hour cyclone and baghouse
3545 and 3565 (ID No.3575) VOC 1.77 lbs/hour as C none
Opacity 20 percent cyclone and ba house
PZKR Green Chip Makers(ID PM10 1.0 lbs/hour baghouse
No.3585) VOC 0.64 lbs/hour as C none
D achy 20 percent baghouse
Oversized Material Pallmann PM10 0.005 lbs/hour ba house
Mill(ID No.3595) VOC 1.77 lbs/hour as C none
Opacity 20 percent ba house
Dry Waste Transport System(ID PM10 0.005 lbs/hour cyclone and bajghouse
No.3577) VOC 1.77 lbs/hour as C none
Opacity 20 percent cyclone and ba house
* BACT limits shall apply at all times.However,emissions resulting from startup,shutdown or malfunction as
defined under 15A NCAC 02D.0535,exceeding the limits in condition a.above are permitted,provided that the
Permittee,to the extent practicable,maintains and operates each emission source including any associated air
pollution control equipment listed in this Table,in a manner consistent with good air pollution control practice for
minimizing emissions.
** BACT emission limits are a total for the two remaining particleboard dryers(ID Nos. 1420,and 1430).

Air Permit 03449T52
Page 29
Testing WMio. VOC, CO.NOx) [15A NCAC 02Q.0508(f)]
b. If emissions testing is required for visible emissions,PMIo,VOC,CO and NOx,the testing shall be performed
in accordance with General Condition JJ. If the results of this test exceed the limits given in Section 2.1 E.6.a.
above,the Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530.
c. For the dryers(ID No. 1420 and 1430),the Permittee shall conduct a source test for VOC within 180 days
following the initial introduction of the low moisture furnish.If the results of this test exceed the limits given
in Section 2.1 E.6.a.above,the Permittee shall be deemed in noncompliance with 15A NCAC 02D .0530.
Monitoring{PMiol [15A NCAC 02Q.0508(f)]
d. PMio emissions from the units in the particleboard mill[]ED No.PB]shall be controlled as follows:
i. In the sawdust rock and metal separator(ID No.3501),raw materials shall be sorted to remove unusable
material and transported through a high efficiency cyclone(ID No.SC),which is 72 inches in diameter.
Emissions from the cyclone shall be exhausted to a fabric filter(ID No.CD-3501)with 2,410 square feet
of filter surface area.
ii. Emissions from the sources in in Table 2.I.E.1.shall be controlled as presented in Table 2.1.E.1
iii. Emissions from the sources in in Table 2.1.E.2.shall be controlled as presented in Table 2.1.E.2
Cvclones.multi-cvclones and fabric filters in Tables 2.1.E.1 and 2.1.E.2
e. To ensure compliance and effective operation,the Permittee shall perform inspections and maintenance,as
recommended by the manufacturer. In addition to the manufacturer's inspection and maintenance
recommendations,or if there is no manufacturer's inspection and maintenance recommendations,as a
minimum,the inspection and maintenance requirement shall include the following:
i. a monthly visual external inspection of the control devices,system ductwork,and the material collection
units for leaks.
ii. for each bagfilter,an annual(for each 12 month period following the initial inspection)internal inspection
of the bagfilter's structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if the requirements in condition
e.are not met.
Wet electrostatic precipitator(ID No.CD-PB-WESP)
f. To ensure compliance and the effective operation of the wet electrostatic precipitator(ID No.CD-PB-WESP),.
the Permittee shall:
i. operate the wet electrostatic precipitator with a minimum of two of the possible three fields,excluding
periods when one of the two fields is in a wash cycle;
ii. monitor and record the secondary voltage and current through the precipitator.The lower limits(3-hour
block averages)are given below:
_ Table 2.1 E.61
Field No. Minimum Secondary Voltage, Minimum Current,milliamps
kilovolts
1 23 48
2 25 75
3 27 127
iii. shall meet the requirements for a dry rotary dryer at Sections 2.2 A.l.j in lieu of monitoring the water
injection rate to assure compliance with the VOC BACT limit in Section 2.1 E.6.a.
iv. The parameter ranges in Table 2.1 E.6.f are not required during performance testing.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if.
i. the voltage or current readings are not monitored or recorded,excluding periods of start-up,shut-down,
malfunction,and monitor downtime;and as provided in i.and ii.above;
ii. the voltage or current fall below the lower limits as established above in condition f.ii;or
iii. the requirements in f.iii are not met.
Monitorin_ (CO.VOC and NOx) [15A NCAC 02Q.0508(f)]
g. i. To ensure compliance and effective operation,the Permittee shall perform inspections and maintenance of
the particleboard dryers(ID Nos. 1420,and 1430). At a minimum,the inspection and maintenance
requirement shall include the following:

Air Permit 03449T52
Page 30
(A) a weekly inspection of burners,fans,blowers,and associated process control equipment.
(B) an annual(for each 12-month period following the initial inspection)internal inspection of the
particleboard dryers(1D Nos.1420,and 1430)for structural integrity.
ii. For VOCs from the particleboard dryers(11D Nos. 1420,and 1430),the Permittee shall meet the inlet
temperature and moisture monitoring requirements at Section 2.2 A.l.w through y.
If these monitoring requirements are not met,the Permittee shall be deemed to be in noncompliance with 15A
NCAC 02D.0530.
Monitorin /Recordkee im,- VE [15A NCAC 02Q.0508(f)]
h. The monitoring/recordkeeping requirements in Section 2.1 E.5.c and d shall be sufficient to ensure compliance
with 15A NCAC 02D .0530. If the requirements of Section 2.1 E.S.c and d are not met,the Permittee shall be
deemed in noncompliance with 15A NCAC 02D.0530.
Recordkeening WMO [15A NCAC 02Q.0508(f)]
For the cyclones,multi- clones and fabric filters and WESP in Tables 2.1.E.1 and 2.1.E.2
i. The results of inspection and maintenance activities shall be maintained in a logbook(written or electronic
format)on-site and made available to an authorized representative of DAQ upon request. The logbook shall
record the following:
i. the date and time of each recorded action;
ii. the results of each inspection;
iii. the results of any maintenance performed;and
iv. any variance from manufacturer's recommendations,if any,and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if these records are not
maintained.
Recordkee in CO VOC and NOx).[15A NCAC 02Q.0508(f)]
j. i. The results of inspection and maintenance of the particleboard dryers(ID Nos. 1420,and 1430)shall be
maintained in a logbook(written or electronic format)on-site and made available to an authorized
representative of DAQ upon request. The logbook shall record the following:
(A) the date and time of each recorded action;
(B) the results of each inspection;
(C) the results of any maintenance performed on the particleboard dryers;and
(D) any variance from manufacturer's recommendations,if any,and corrections made.
ii. For VOCs from the particleboard dryers(1D Nos. 1420 and 1430),the Permittee shall meet the inlet
temperature and moisture recordkeeping requirements at Section 2.2 A.l.aa and bb.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if these records are not
maintained.
MonitorinelRecordkeeping WMio;CO,VOC.NOx,and VE) [15A NCAC 02Q.0508(f)]
k. The total particleboard production at the Particleboard Mill(ID No.PB)during any consecutive 12-month
period shall not exceed 180,000,000 square feet on a%-inch basis. The Permittee shall maintain monthly
records of the total amount of particleboard produced in a logbook(written or in electronic format). Such
records shall indicate the amount of particleboard produced during the preceding month and the total amount
of particleboard produced over the preceding 12-month period. The Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0530 if these requirements are not met.
1. The operating hours for particleboard dryers(1D Nos. 1420 and 1430)shall not exceed 8,500 hours each
during any consecutive 12-month period. The Permittee shall keep monthly records of the hours of operation
for each particleboard dryer. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if
these requirements.are not met.
Re or 'ng(PMig,CO VOC and NOx [15A NCAC 02Q.0508(f)]
PMio.CO VOC and NOx
m. The Permittee shall submit the results of any maintenance performed on the control devices in Tables 2.1.E.1
and 2.1.E.2 and/or particleboard dryers(ID Nos. 1420,and 1430)within 30 days of a written request by the
DAQ.

Air Permit 03449T52
Page 31
n. The Permittee shall submit a summary report of monitoring and record keeping activities postmarked on or
before January 30 of each calendar year for the preceding six-month period between July and December and
July 30 of each calendar year for the preceding six-month period between January and June. All instances of
deviations from the requirements of this permit must be clearly identified.
i. For VOCs from the particleboard dryers(ID Nos. 1420 and 1430),the Permittee shall meet the reporting
requirements at Section 2.2 A.l.dd through gg.
VE
o. Reporting requirements in Section 2.1 E.5.e shall be sufficient to ensure compliance with 15A NCAC 02D
.0530.
Mo.CO VOC NO VE
p. By January 30 of each calendar year for the preceding six-month period between July and December and July
30 of each calendar year for the preceding six-month period between January and June,the following shall be
reported to the Regional Supervisor,Division of Air Quality:
i. the annual production rate at the Particleboard Mill(ID No.PB)in square feet on a 3/-inch basis.The
annual production rate must be calculated for each of the six twelve-month periods over the previous
seventeen months.
ii. the hours of operation for each particleboard dryer(ID Nos.m1420 and 1430)for each of the six twelve-
month periods over the previous seventeen months.
All instances of deviations from the requirements of this permit must be clearly identified.
7. 15A NCAC 02D.0614: COMPLIANCE ASSURANCE MONITORING[40 CFR 641
a. Pursuant to 40 CFR 64 and 15A NCAC 02D.0614,the Permittee shall comply with the conditions below for
the Pollutant Specific Emission Unit(s)controlled by the wet electrostatic precipitator(ID No.CD-PB-WESP).
Emission Limitations/Standards
b. The following table presents the regulated pollutants and the associated emission limitations/standards:
Regulated Pollutant Limits/Standards Applicable Regulation
PM See condition 2.1 E.1 15A NCAC 02D.0515
PM�o See condition 2.1 E.6 15A NCAC 02D.0530
VOCs See condition 2.1 E.6 15A NCAC 02D.0530
Monitoring A roach[15A NCAC 02Q.0508(f),40 CFR 64.6]
c. The key elements of the monitoring approach for PM and PMIo,including parameters to be monitored,
parameter ranges and performance criteria are presented in the following table.

Air Permit 03449T52
Page 32
Monitoring Indicator No.1 Indicator No.2
Elements
Measurement Secondary voltage readings on each of the Current readings on each of the three fields
Approach three fields are made on each field of the wet are made on each field of the wet ESP every
64.6 cJ 1 i ,(ii)] ESP eve!3 15 minutes 15 minutes
Indicator Range An excursion is defined as a one-hour block An excursion is defined as a one-hour block
[64.6(c)(2)] average voltage reading in any field lower average current reading in any field lower
than the respective 3-hour block average than the respective 3-hour block average
reading listed in Table 2.1.E.61.of this reading listed in Table 2.1.E.61 of this
permit.Excursions trigger an inspection and permit. Excursions trigger an inspection and
corrective action. corrective action.
QIP threshold The QIP threshold is six excursions in a six- The QIP threshold is six excursions in a six-
[64.81 month r orting period. month reporting period.
Data Measurements are made once every 15 Measurements are made once every 15
Representativeness minutes and complied into the appropriate minutes and complied into the appropriate
[64.6(c)(1)(iii), averaging periods. averaging periods.
64.3(b)(1
Verification of Monitoring shall be required upon issuance of permit no.03449T47
Operational Status
[64.3(b)(2)1
QA/QC Practices f Voltmeter calibration shall be performed Ammeter calibration shall be performed
and Criteria according to manufacturer recommendations. according to manufacturer recommendations.
LL64.3(b 3
Monitoring Measurements are made by a computerized data acquisition and handling system once every 15
frequency minutes and complied into the appropriate averaging periods.
64.3 4:
Data collection Non-SSM periods when voltage and current falls below the acceptable ranges for more than
procedure one-hour will be documented.An electronic or written logbook will be kept of all control
64.3(b)(4)] I device inspections and corrective actions
Monitorin-_Approach[15A NCAC 02Q.0508(f),40 CFR 64.6]
d. For VOC,the Permittee has elected to satisfy the presumptively acceptable monitoring requirements under
MACT DDDD for the dry rotary dryer as allowed at 40 CFR 64.4(b)(4).The Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0530 if the moisture and temperature values are outside the indicator
ranges found at Section 2.2 A.l.j.
Recordkee in r Re uirements[15A NCAC 02Q.0508(f),40 CFR 64.9]
e. The owner or operator shall maintain records of the following:
i. Date and time and results of all monitoring activities;
ii. Information on the number,duration and cause(including unknown cause,if applicable)of excursions or
exceedances,as applicable,and the corrective actions taken;
iii. Maintenance records of the differential pressure gauge;and
iv. Written QIP required pursuant to 40 CFR 64.8 and any activities undertaken to implement a quality
improvement plan.
v. For VOC,the Permittee shall meet the recordkeeping and reporting requirements found in Section 2.2
A.l.aa through ii,as applicable.The Permittee shall be deemed in noncompliance with 15A NCAC 02D
.0530 if these requirements are not met.
Reporting=Requirements[15A NCAC 02Q.0508(f),40 CFR 64.9]
f. The Permittee shall submit a summary report of all monitoring activities postmarked on or before January 30
of each calendar year for the preceding six-month period between July and December and July 30 of each
calendar year for the preceding six-month period between January and June. All instances of deviations for the
requirements of this permit must be clearly identified. At a minimum,the report shall include the following
elements:
i. Summary information on the number,duration and cause(including unknown cause,if applicable)of
excursions or exceedances,as applicable,and the corrective actions taken;
ii. Summary information on the number,duration and cause(including unknown cause,if applicable)for

Air Permit 03449T52
Page 33
monitor downtime incidents(other than downtime associated with zero and span or other daily calibration
checks,if applicable);and
iii. A description of the actions taken to implement a QIP during the reporting period as specified in 40 CFR
64.8.Upon completion of a QIP,the owner or operator shall include in the next summary report
documentation that the implementation of the plan has been completed and reduced the likelihood of
similar levels of excursions or exceedances occurring.
iv. For VOC,the Permittee shall meet the recordkeeping and reporting requirements found in Section 2.2
A.Laa through ii,as applicable.The Permittee shall be deemed in noncompliance with 15A NCAC 02D
.0530 if these requirements are not met.
S. 15A NCAC 02D.1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
Applicability[40 CFR 63.7485]
a. For this existing process heater designed to bum gas 1 fuels(H)No.3201),the Permittee shall comply with all
applicable provisions,including the monitoring,recordkeeping,and reporting contained in Environmental
Management Commission Standard 15A NCAC 02D.1111 "Maximum Achievable Control Technology"
(MACT)as promulgated in 40 CFR Part 63 Subpart DDDDD."National Emission Standards for Hazardous
Air Pollutants for Major Sources:Industrial,Commercial,and Institutional Boilers and Process Heaters"and
Subpart A"General Provisions."
i. Condition 2.1.E.8 applies only when the Permittee operates the Wellons(ID No.3201)in operating
scenario 2(OS-2).
Definitions and Nomenclature[40 CFR 63.7575]
b. For the purpose of this permit condition,the definitions and nomenclature contained in 40 CFR 63.7575 shall
apply.
40 CFR Part 63 Subpart A General Provisions[40 CFR 63.7565]
c. The Permittee shall comply with the requirements of 40 CFR Part 63 Subpart A General Provisions according
to the applicability of Subpart A to such sources as identified in Table 10 to 40 CFR Part 63 Subpart DDDDD.
Compliance Date 140 CFR 63.7495(b)]
d. The Permittee shall complete the initial tune up and the one-time energy assessment no later than January 31,
2016.140 CFR 63.7495(b),63.7510(e)]
i. If the Wellons(II)No.3201)is not operated in OS-2 prior to January 1,2016,the Permittee shall
complete the initial tune up no later than 30 days after startup. [40 CFR 63.75106)]
Notifications 140 CFR 63.7545,63.7530(d),(e),(f)]
e. The Permittee shall submit a Notification of Compliance Status. The notification shall contain the following:
i. A description of the affected unit(s)including identification of which subcategories the unit is in,the
design heat input capacity of the unit,and description of the fuel(s)burned.
ii. the following certification(s)of compliance,as applicable:
i.-"This facility complies with the required initial tune-up according to the procedures in condition g.i.
through g.v.and in. ii.' (40 CFR 63.7540(a)(10)(i)through(vi));and
ii.-"This facility has had an energy assessment performed according to condition k.(40 CFR
63.7530(e))."
The notification must be signed by a responsible official and sent before the close of business on the 60th day
following the completion of the initial tune up and one-time energy assessment(whichever is later).
General Compliance Requirements 140 CFR 63.7505(a),63.7500(f)]
f. The Permittee shall be in compliance with the work practice standards in this subpart.These standards apply at
all times the affected unit is operating.

Air Permit 03449T52
Page 34
Work Practice Standards[15A NCAC 02Q .0508(f)]
g. The Permittee shall conduct a tune-up of the process heater annually as specified below.
i. As applicable,inspect the burner,and clean or replace any components of the burner as necessary(the
Permittee may delay the burner inspection until the next scheduled unscheduled unit shutdown;
ii. Inspect the flame pattern,as applicable,and adjust the burner as necessary to optimize the flame pattern.
The adjustment should be consistent with the manufacturer's specifications,if available;
iii. Inspect the system controlling the air-to-fuel ratio,as applicable,and ensure that it is correctly calibrated
and functioning properly(the Permittee may delay the inspection until the next scheduled unit shutdown),
iv. Optimize total emissions of carbon monoxide.This optimization should be consistent with the
manufacturer's specifications,if available,and with any NOX requirement to which the unit is subject.
v. Measure the concentrations in the effluent stream of carbon monoxide in parts per million,by volume,and
oxygen in volume percent,before and after the adjustments are made(measurements may be either on a
dry or wet basis,as long as it is the same basis before and after the adjustments are made).Measurements
may be taken using a portable CO analyzer.
[40CFR 63.7500(a),63.7540(a)(10)]
h. Each annual tune-up shall be conducted no more than 13 months after the previous tune-up. [40CFR
63.7515(d)]
i. If the unit is not operating on the required date for a tune-up,the tune-up must be conducted within 30 calendar
days of startup.
[40 CFR 63.7540(a)(13),63.7515(g)]
j. At all times,the Permittee must operate and maintain any affected source,including associated air pollution
control equipment and monitoring equipment,in a manner consistent with safety and good air pollution control
practices for minimizing emissions.Determination of whether such operation and maintenance procedures are
being used will be based on information available to the Administrator that may include,but is not limited to,
monitoring results,review of operation and maintenance procedures,review of operation and maintenance
records,and inspection of the source.
[40 CFR 63.7500(a)(3)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the requirements in f.through i.
are not met.
Ener�,,v Assessment Reouirements[15A NCAC 02Q.0508(b)]
k. The Permittee shall have a one-time energy assessment performed by a qualified energy assessor.The energy
assessment must include the following items:
i. A visual inspection of the boiler system;
ii. An evaluation of operating characteristics of the affected boiler systems,specifications of energy use
systems,operating and maintenance procedures,and unusual operating constraints;
iii. An inventory of major energy use systems consuming energy from affected boiler(s)and which are under
control of the boiler owner or operator;
iv. A review of available architectural and engineering plans,facility operation and maintenance procedures
and logs,and fuel usage;
v. A list of major energy conservation measures that are within the facility's control;
vi. A list of the energy savings potential of the energy conservation measures identified;and
vii. A comprehensive report detailing the ways to improve efficiency,the cost of specific improvements,
benefits,and the time frame for recouping those investments.
1. The energy assessment will be 8 on-site technical labor hours in length maximum,but may be longer at the
discretion of the owner or operator of the affected source.The boiler system(s)and any on-site(excluding
MDF plant)energy use system(s)accounting for at least 50 percent of the affected boiler(s)energy(e.g.,
steam,hot water,process heat,or electricity)production,as applicable,will be evaluated to identify energy
savings opportunities,within the limit of performing an 8-hour on-site energy assessment.
[40 CFR 63.7500(a)(1),Table 3]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the requirements in k.through 1.
are not met.
Recordkeepin2 Reuuirements[15A NCAC 02Q.0508(f),40 CFR 63.7555]
in. The Permittee shall keep the following:

Air Permit 03449T52
Page 35
i. A copy of each notification and report submitted to comply with this subpart,including all documentation
supporting any Initial Notification or Notification of Compliance Status,or semiannual compliance report
that has been submitted,according to the requirements in 40 CFR 63.1 0(b)(2)(xiv).
[40 CFR 63.7555(a)(1)]
ii. Maintain on-site and submit,if requested by the Administrator,an annual report containing the
information in paragraphs(A)through(C)below:
(A) The concentrations of carbon monoxide in the effluent stream in parts per million by volume,and
oxygen in volume percent,measured before and after the adjustments of the source;
(B) A description of any corrective actions taken as a part of the combustion adjustment;and
(C) The type and amount of fuel used over the 12 months prior to the annual adjustment,but only if the
unit was physically and legally capable of using more than one type of fuel during that period.Units
sharing a fuel meter may estimate the fuel use by each unit.
[40 CFR 63.7540(a)(10)(vi)]
iii. The associated records for conditions f.through 1.including the occurrence and duration of each
malfunction of operation(i.e.,process equipment)or the required air pollution control and monitoring
equipment.
[40 CFR 63.10(b)(2)(ii)]
iv. maintain records of the calendar date,time,occurrence and duration of each startup and shutdown.
[40 CFR 63.7555(i)]
v. maintain records of the type(s)and amount(s)of fuels used during each startup and shutdown.
[40 CFR 63.75550)]
n. The Permittee shall:
i. maintain records in a form suitable and readily available for expeditious review;
ii. keep each record for 5 years following the date of each occurrence,measurement,maintenance,corrective
action,report,or record;and
iii. keep each record on site for at least 2 years after the date of each occurrence,measurement,maintenance,
corrective action,report,or record.The Permittee can keep the records offsite for the remaining 3 years.
[40 CFR 63.7560,63.10(b)(1)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if records are not maintained per
conditions in.through n.
Reporting Requirements[15A NCAC 02Q.0508(f)]
o. In lieu of a 1-year reporting requirement pursuant to 40 CFR 63.7550(b),the Permittee has elected to submit
compliance reports to the DAQ on a semi-annual basis.The Permittee shall submit the compliance report
postmarked on or before January 30 of each calendar year for the preceding six-month period between July and
December and July 30 of each calendar year for the preceding six-month period between January and June.
i. The first report shall cover the period beginning on January 31,2016 and shall be postmarked on or
before July 30,2016.
ii. These reports must also be submitted electronically through the EPA's Central Data Exchange(CDX)
(www.epa.gov/cdx).However,if the reporting form specific to this subpart is not available in CEDRI at
the time that the report is due the report the Permittee submit the report to the at the appropriate address
listed in 40 CFR 63.13. [40 CFR 63.7550(h)(3)]
A. The Permittee may submit the CDX report in condition o.ii.above on a 1-year basis as allowed
pursuant to 40 CFR 63.7550(b).
p. The compliance report must contain the following information:
i. Company name and address;
ii. Process unit information,emissions limitations,and operating parameter limitations;
iii. Date of report and beginning and ending dates of the reporting period;
iv. The total operating time during the reporting period;
iv. If there are no deviations from the requirements of the work practice requirements in condition g.above,a
statement that there were no deviations from the work practice standards during the reporting period;and
v. Include the date of the most recent tune-up for each unit required to conduct an annual tune-up according
to condition g.Include the date of the most recent burner inspection if it was not done annually and was
delayed until the next scheduled or unscheduled unit shutdown.
[40 CFR 63.7550(a)and(c),Table 9]

Air Permit 03449T52
Page 36
q. If there is a deviation from a work practice standard during the reporting period,the report must contain the
following information:
i. A description of the deviation and which emission limit or operating limit from which the Permittee
deviated;and
ii. Information on the number,duration,and cause of deviations(including unknown cause),as applicable,
and the corrective action taken.
[40 CFR 63.7550(a)and(d),63.7540(b),Table 9]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the reporting requirements in o.
through q.are not met.
F. Laminating Mill:
_ Table 2.1.F
[ Emission Emission Source Description Control Device Control Device Description
I' Source ID No. l _ ID No.
Two(2)Short Cycle Laminating Reverse flow bagfilter(Maximum
3593 and 3594 Presses CD-3593 air-to-cloth ratio of 4.1
� ACFM/total filter surface areal.
Natural gas-fired hot oil heater(4.7
Pr-Heatl million Btu per hour heat input)used N/A NA
with short cycle laminating presses
The following table provides a summary of limits and/or standards for the material handling sources.
Regulated Pollutant Limits/Standards Applicable Regulation
Affected source:[ID No.Pr-Heatl] 15A NCAC 02D.0503
0.60 pounds per million Btu heat in ut
PM Affected source: ID Nos.3593 and 3594)
E=4.10P 0.67
where;E=allowable emission rate in pounds per hour 15A NCAC 02D.0515
P=process weight in tons per hour
Sulfur dioxide Affected source: JID No.Pr-Heat I) 15A NCAC 02D.0516
2.3 pounds per million Btu heat input
Visible emissions 20 ercent opacity 15A NCAC 02D.0521
HAPs Affected source:(ID No.Pr-Heat I) 15A NCAC 02D.1109
Best Combustion Practices
Odors State-Enforceable Only 15A NCAC 02D.1806
See Section 2.2 A.2
1. 15A NCAC 02D.0503:PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS
a. Emissions of particulate matter from the combustion of natural gas from the hot oil heater(ID No.Pr-Heatl)
into the atmosphere shall not exceed 0.60 pounds per million Btu heat input.
Testing[15A NCAC 02D.0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the
results of this test exceed the limit given in condition a.above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0503.
Monitorin-.:'ltecordkeeuin�,/Ret)ortin [15ANCAC 02Q .0508(f)]
c. No monitoring,record keeping,or reporting is required for particulate emissions from the firing of No.2 fuel
oil and natural gas in the hot oil heater(ID No.Pr-Heatl).

Air Permit 03449T52
Page 37
2. 15A NCAC 02D.0515:PARTICULATE EMISSIONS FROM MISCELLANEOUS INDUSTRIAL
PROCESSES
a. Emissions of particulate matter from the units in the short cycle laminating presses(ID Nos.3593 and 3594)
that are discharged into the atmosphere shall not exceed an allowable emission rate as calculated by the
following equations:
[ Process Rate Allowable Emission Rate Equation
Less than orequal to 30 tons per hour E=4.10 x P 0.61
Greater than 30 tons per hour E=55.0(P)1.11-40
Where E=allowable emission rate in pounds per hour
P=process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing[15A NCAC 02Q.0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the
results of the test performed exceed the limits given in condition a.above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0515.
Monitoring/Recordkee in ;Me, ortiu:! [15ANCAC 02Q.0508(f)]
c. Particulate matter emissions from the short cycle laminating presses(ID Nos.3593 and 3594)shall be
controlled using the reverse flow bagfilter(ID No.CD-3593). To ensure compliance,the Permittee shall
perform inspections and maintenance as recommended by the manufacturer. In addition to the manufacturer's
inspection and maintenance recommendations,or if there are no manufacturer's inspection and maintenance
recommendations,as a minimum,the inspection and maintenance requirement shall include the following:
i. a monthly visual inspection of the system ductwork and material collection unit for leaks;and
ii. an annual(for each 12-month period following the initial inspection)internal inspection of the bagfilter's
structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515 if the ductwork and bagfilters
are not inspected and maintained.
d. The results of inspection and maintenance shall be maintained in a logbook(written or electronic format)on-
site and made available to an authorized representative upon request. The logbook shall record the following:
i. the date and time of each recorded action;
ii. the results of each inspection;and
iii. the results of maintenance performed on any control device.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0515 if these records are not
maintained.
Reporting[15A NCAC 02Q.0508(f)]
e. The Permittee shall submit the results of any maintenance performed on the bagfilter(ID No.CD-3593)within
30 days of a written request by the DAQ.
f. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on or
before January 30 of each calendar year for the preceding six-month period between July and December and
July 30 of each calendar year for the preceding six-month period between January and June. All instances of
deviations from the requirements of this permit must be clearly identified.
3. 15A NCAC 02D.0516:SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Sulfur dioxide emissions from the hot oil heater(ID No.Pr-Heatl)shall not exceed 2.3 pounds per million
Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels,wastes,ores,and other substances
shall be included when determining compliance with this standard.
Testing[15A NCAC 02Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in condition a.above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D .0516.

Air Permit 03449T52
Page 38
Monitorin-�/Recordkee in [15A NCAC 02Q.0508(f)]
c. No monitoring,record keeping,or reporting is required for sulfur dioxide emissions from the firing of natural
gas in the hot oil heater(ID No.Pr-Heatl).
4. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the sources listed in Table 2.1.F.shall not be more than 20 percent opacity when
averaged over a six-minute period. However,six-minute averaging periods may exceed 20 percent not more
than once in any hour and not more than four times in any 24-hour period. In no event shall the six-minute
average exceed 87 percent opacity
Testing[15A NCAC 02Q.0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the
results of the test performed exceed the limits given in condition a. (above)for visible emissions,the Permittee
shall be deemed in noncompliance with 15A NCAC 02D.0521.
Monitorin /Recordkee in [15A NCAC 02Q.0508(f)]
c. To ensure compliance,the Permittee shall observe,on a weekly basis,the following emission points in the
Particleboard mill for any visible emissions above normal:
Emission Source Emission Point ID No.
short cycle laminating presses(ID Nos.3593 and 3594) CD-3593
The weekly observation must be made for each of the calendar year period to ensure compliance with this
requirement. If visible emissions from the short cycle laminating presses are observed to be above normal,the
Permittee shall either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements below,or
ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with
15A NCAC 02D.2610(Method 9)for 12 minutes is below the limit given in condition a.above.
If the above-normal emissions are not corrected per(i)above or if the demonstration in(ii)above cannot be
made,the Permittee shall be deemed to be in noncompliance with 15A NCAC 02D.0521.
d. The results of the monitoring for visible emissions shall be maintained in a logbook(written or electronic
format)on-site and made available to an authorized representative upon request.To ensure quality,entries in
the logbook should be signed by personnel responsible for the effective operation of the units in the
particleboard mill and their air pollution control devices.The logbook shall record the following:
i. The date and time of each recorded action;
ii. the results of each observation and/or test noting those sources with emissions that were observed to be in
noncompliance along with any corrective actions taken to reduce visible emissions;and
iii. the results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521 if these records are not
maintained.
Reporting[15A NCAC 02Q .0508(f)]
e. The Permittee shall submit a summary report of monitoring and record keeping activities postmarked on or
before January 30 of each calendar year for the preceding six-month period between July and December and
July 30 of each calendar year for the preceding six-month period between January and June. All instances of
deviations from the requirements of this permit must be clearly identified.
5. 15A NCAC 02D.1109:Case-by-Case MACT
a. The Permittee shall use best combustion practices when operating the affected heater(ID No.Pr-Heatl). The
initial compliance date for this work practice standard and the associated monitoring,recordkeeping,and
reporting requirements is October 18,2013. These conditions need not be included on the annual compliance
certification until after the initial compliance date.

Air Permit 03449T52
Page 39
i. The Permittee shall comply with this CAA§1126)standard until May 19,2019.The initial compliance
date for the applicable CAA §112(d)standard for"National Emission Standards for Hazardous Air
Pollutants for Industrial,Commercial,and Institutional Boilers and Process Heaters"is May 20,2019,as
specified in Section 2.1.F.6.below.
Monitorina/Recordkeeninp-
b. To ensure compliance,the Permittee shall perform an annual boiler inspection and maintenance as
recommended by the manufacturer,or as a minimum,the inspection and maintenance requirement shall
include the following:
i. Inspect the burner,and clean or replace any components of the burner as necessary;
ii. Inspect the flame pattern and make any adjustments to the burner necessary to optimize the flame pattern;
and,
iii. Inspect the system controlling the air-to-fuel ratio,and ensure that it is correctly calibrated and functioning
properly.
The Permittee shall conduct at least one tune-up per calendar year to demonstrate compliance with this
requirement. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1109 if the affected
heater is not inspected and maintained as required above.
c. The results of inspection and maintenance shall be maintained in a logbook(written or electronic format)on-
site and made available to an authorized representative upon request. The logbook shall record the following:
i. The date of each recorded action;
ii. The results of each inspection;and,
iii. The results of any maintenance performed on the heater.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1109 if these records are not
maintained.
Reporting[15A NCAC 02Q.0508(f)]
d. No reporting is required.
6. 15A NCAC 02D.1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
Applicability[40 CFR 63.7485,.7490(d), .7499(1)]
a. For the heater(ID No.Pr-Heatl)(an existing source designed to burn gas 1 fuels with a heat input capacity of
less than or equal to 5 million Btu per hour),the Permittee shall comply with all applicable provisions,
including the monitoring,recordkeeping,and reporting contained in Environmental Management Commission
Standard 15A NCAC 02D.1111 "Maximum Achievable Control Technology"(MACT)as promulgated in 40
CFR Part 63 Subpart DDDDD,"National Emission Standards for Hazardous Air Pollutants for Major Sources:
Industrial,Commercial,and Institutional Boilers and Process Heaters"and Subpart A"General Provisions."
i. The Permittee shall comply with the CAA§1126)standard in Section 2.1.F.5.through May 19,2019.
The Permittee shall be subject to the requirements of this standard starting May 20,2019.Note that the
requirements of this standard may require action on behalf of the Permittee prior to May 20,2019.
Definitions and Nomenclature[40 CFR 63.75751
b. For the purpose of this permit condition,the definitions and nomenclature contained in 40 CFR 63.7575 shall
apply.
40 CFR Part 63 Subpart A General Provisions[40 CFR 63.75651
c. The Permittee shall comply with the requirements of 40 CFR Part 63 Subpart A General Provisions according
to the applicability of Subpart A to such sources as identified in Table 10 to 40 CFR Part 63 Subpart DDDDD.
Compliance Date 140 CFR 63.7510(e),63.56(b)]
d. The Permittee shall complete the initial tune up and the one-time energy assessment no later than May 20,
2019.
Notifications 140 CFR 63.7545(e)(8),63.7530(e),(f)]
c. The Permittee shall submit a Notification of Compliance Status. The notification must be signed by a
responsible official and sent before the close of business on the 60th day following the completion of the initial
tune up and one-time energy assessment(whichever is later).The notification shall contain the following:

Air Permit 03449T52
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i. A description of the affected unit(s)including identification of which subcategories the unit is in,the
design heat input capacity of the unit,and description of the fuel(s)burned.
ii. the following certification(s)of compliance,as applicable:
A. "This facility completed the required initial tune-up for all of the boilers and process heaters covered
by 40 CFR Part 63 Subpart DDDDD at the site according to the procedures in.40 CFR
63.7540(a)(10)(i)through(vi)' [i.e.,conditions g.i.through g.v.and 1.ii.];and
B. "This facility has had an energy assessment performed according to 40 CFR 63.7530(e)"[i.e.,
condition k.]and is an accurate depiction of the facility at the time of the assessment.
General Compliance Requirements 140 CFR 63.7505(a),63.7500(f)]
f. The Permittee shall be in compliance with the work practice standards in this subpart.These standards apply at
all times the affected unit is operating.
Work Practice Standards[15A NCAC 02Q.0508(f)]
g. The Permittee shall conduct a tune-up of the process heater every five years as specified below.
i. As applicable,inspect the burner,and clean or replace any components of the burner as necessary(the
Permittee may delay the burner inspection until the next scheduled or unscheduled unit shutdown,but the
burner must be inspected at least once every 72 months
ii. Inspect the flame pattern,as applicable,and adjust the burner as necessary to optimize the flame pattern.
The adjustment should be consistent with the manufacturer's specifications,if available;
iii. Inspect the system controlling the air-to-fuel ratio,as applicable,and ensure that it is correctly calibrated
and functioning properly(the Permittee may delay the inspection until the next scheduled unit shutdown)'
iv. Optimize total emissions of carbon monoxide.This optimization should be consistent with the
manufacturer's specifications,if available,and with any NOx requirement to which the unit is subject.
v. Measure the concentrations in the effluent stream of carbon monoxide in parts per million,by volume,and
oxygen in volume percent,before and after the adjustments are made(measurements may be either on a
dry or wet basis,as long as it is the same basis before and after the adjustments are made).Measurements
may be taken using a portable CO analyzer.
[40CFR 63.7500(a),(e),63.7540(a)(10),(a)(12)]
h. Each 5-year tune-up shall be conducted no more than 61 months after the previous tune-up. [40CFR
63.7515(d)]
i. If the unit is not operating on the required date for a tune-up,the tune-up must be conducted within 30 calendar
days of startup. [40 CFR 63.7540(a)(13),63.7515(g)]
j. At all times,the Permittee must operate and maintain any affected source,including associated air pollution
control equipment and monitoring equipment,in a manner consistent with safety and good air pollution control
practices for minimizing emissions.Determination of whether such operation and maintenance procedures are
being used will be based on information available to the Administrator that may include,but is not limited to,
monitoring results,review of operation and maintenance procedures,review of operation and maintenance
records,and inspection of the source. [40 CFR 63.7500(a)(3)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the requirements in f.throu.h
j. are not met.
Eneray. Assessment Requirements[15A NCAC 02Q.0508(f)]
k. The Permittee shall have a one-time energy assessment performed by a qualified energy assessor.The energy
assessment must address the requirements in 40 CFR Part 63 Subpart DDDDD,Table 3,with the extent of the
evaluation for items(a)to(e)in Table 3 appropriate for the on-site technical hours listed in§63.7575:
[§63.7500(a)(1),Table 3]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.I 111 if the requirements in condition
k. are not met.
Recordkee piniz Rec uirements[15A NCAC 02Q .0508(f),40 CFR 63.7555]
1. The Permittee shall keep the following:
i. A copy of each notification and report submitted to comply with this subpart,including all documentation
supporting any Initial Notification or Notification of Compliance Status,or semiannual compliance report
that has been submitted,according to the requirements in 40 CFR 63.1 0(b)(2)(xiv).
[40 CFR 63.7555(a)(1)]

Air Permit 03449T52
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ii. Maintain on-site and submit,if requested by the Administrator,an annual report containing the
information in paragraphs(A)through(C)below:
A. The concentrations of carbon monoxide in the effluent stream in parts per million by volume,and
oxygen in volume percent,measured before and after the adjustments of the source;
B. A description of any corrective actions taken as a part of the combustion adjustment;and
C. The type and amount of fuel used over the 12 months prior to the annual adjustment,but only if the
unit was physically and legally capable of using more than one type of fuel during that period.Units
sharing a fuel meter may estimate the fuel use by each unit.
[40 CFR 63.7540(a)(10)(vi)]
iii. The associated records for conditions f.through 1.including:
A. the occurrence and duration of each malfunction of operation(i.e.,process equipment)or the required
air pollution control and monitoring equipment.
[40 CFR 63.10(b)(2)(ii)]
iv. maintain records of the calendar date,time,occurrence and duration of each startup and shutdown.
[40 CFR 63.7555(i)]
v. maintain records of the type(s)and amount(s)of fuels used during each startup and shutdown.
[40 CFR 63.75556)]
in. The Permittee shall:
i. maintain records in a form suitable and readily available for expeditious review;
ii. keep each record for 5 years following the date of each occurrence,measurement,maintenance,corrective
action,report,or record;and
iii. keep each record on site for at least 2 years after the date of each occurrence,measurement,maintenance,
corrective action,report,or record.The Permittee can keep the records offsite for the remaining 3 years.
[40 CFR 63.7560,63.10(b)(1)]
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if records are not maintained as
described in conditions 1.through in.
Reporting Requirements[15ANCAC 02Q.0508(f)]
n. The Permittee shall submit compliance reports to the DAQ on a 5-year basis.The first report shall cover the
period beginning on the compliance date specified in condition d.and ending on the earliest December 31 st
following a complete 5-year period. Subsequent 5-year reports shall cover the periods from January 1 to
December 31.The Permittee shall submit the compliance reports postmarked on or before January 31.
[40 CFR 63.7550(a),(b)]
i. This report must also be submitted electronically through the EPA's Central Data Exchange(CDX)
(www.epa.gov/cdx).However,if the reporting form specific to this subpart is not available in CEDRI at
the time that the report is due the report the Permittee submit the report to the at the appropriate address
listed in 40 CFR 63.13. [40 CFR 63.7550(h)(3)]
o. The compliance report must contain the following information:
i. Company name and address;
ii. Process unit information,emissions limitations,and operating parameter limitations;
iii. Date of report and beginning and ending dates of the reporting period;
iv. The total operating time during the reporting period;
iv. If there are no deviations from the requirements of the work practice requirements in condition g.above,a
statement that there were no deviations from the work practice standards during the reporting period;and
v. Include the date of the most recent tune-up for each unit required according to condition g.Include the
date of the most recent burner inspection if it was not done as scheduled and was delayed until the next
scheduled or unscheduled unit shutdown.
[40 CFR 63.7550(a)and(c),Table 9]
p. If the Permittee has a deviation from a work practice standard during the reporting period,the report must
contain the following information:
i. A description of the deviation and which emission limit or operating limit from which the Permittee
deviated;and
ii. Information on the number,duration,and cause of deviations(including unknown cause),as applicable,
and the corrective action taken.
[40 CFR 63.7550(a)and(d),63.7540(b),Table 9]

Air Permit 03449T52
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The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the reporting requirements in
n.through p.are not met.
G. Reserved
H. Reserved
I. The following combustion source:
Table 2.1.I.
Emission Source ID Control Device
No. Emission Source Description Control Device ID No. Descri tion
ES-21 Diesel Fuel-fired Emergency
MACT ZZZZ Generator(1592 Brake Horsepower NA NA
output)
The following table provides a summa of limits and/or standards for the emission sources above:
Regulated Pollutant Limits/Standards Applicable Regulation
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 02D.0516
Visible emissions 20 percent opacity 15A NCAC 02D.0521
HAPs Maximum Achievable Control Technology 15A NCAC 02D.1111
(40 CFR Part 63 Sub art ZZZZ)
Odors State Enforceable Onl 15A NCAC 02D.1806
See Section 2.2 A.2.
NOx,PM2.5,PMI0 See Section 2.2 B.1. 15A NCAC 02Q.0317
(PSD Avoidance
L I VOCs Best Available Control Technology 15A NCAC 02D.0530
See Section 2.2 B.2.
1. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from this source shall not be more than 20 percent opacity when averaged over a six-minute
period. However,six-minute averaging periods may exceed 20 percent not more than once in any hour and not
more than four times in any 24-hour period. In no event shall the six-minute average exceed 87 percent
opacity.
Testing[15A NCAC 02Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the
results of this test are above the limit given in condition a.above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0521.
Monitorin¢lRecordkeeping/Reporting [15A NCAC 02Q.0508(f)]
c. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of diesel fuel in this
source.
2. 15A NCAC 02D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from this source shall not exceed 2.3 pounds per million Btu heat input. Sulfur
dioxide formed by the combustion of sulfur in fuels,wastes,ores,and other substances shall be included when
determining compliance with this standard.
Testing[15A NCAC 02Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ found

Air Permit 03449T52
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in Section 3. If the results of this test are above the limit given in condition a.above,the Permittee shall be
deemed in noncompliance with 15A NCAC 02D.0516.
Monitorina/Recordkeepinp [15A NCAC 02Q .0508(f)]
c. No monitoring/recordkeeping is required for sulfur dioxide emissions from the firing of diesel fuel in this
source.
3. 15A NCAC 02D.1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
Applicability[40 CFR 63.6585,63.6590(a)(1)(i)]
a. For this emission source(existing stationary RICE with a site rating of more than 500 brake HP located at a
major source of HAP emissions),the Permittee shall comply with all applicable provisions,including the
monitoring,recordkeeping,and reporting contained in Environmental Management Commission Standard 15A
NCAC 02D.1111 "Maximum Achievable Control Technology" (MACT)as promulgated in 40 CFR Part 63
Subpart ZZZZ"National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating
Internal Combustion Engines"and Subpart A"General Provisions."
Stationary RICE subject to limited requirements[40 CFR 63.6590(b)]
b. Pursuant to 40 CFR 63.6590(b)(3)(iii),these sources do not have to meet the requirements of 40 CFR Part 63
Subpart ZZZZ and Subpart A,including initial notification requirements.
2.2 - Multiple Emission Source(s) Specific Limitations and Conditions
A. Facility-wide affected emission sources
The following table provides a summary of limits and standards applicable facility wide:
Regulated Pollutant Limits/Standards Applicable Regulation
HAPs National Emission Standards for Hazardous 15A NCAC 02D.1111
Air Pollutants:Plywood and Composite Wood (40 CFR Part 63 Subpart
Products DDDD
Odors State Enforceable Only 15A NCAC 02D.1806
Odorous emissions must be controlled
1. 15A NCAC 2D.1111: MAXLVIUM ACHIEVABLE CONTROL TECHNOLOGY
Applicability[§63.2231]
a. For the emission sources subject to"MACT Subpart DDDD"as indicated in the permitted equipment list,the
Permittee shall comply with all applicable provisions,including the monitoring,recordkeeping,and reporting
contained in Environmental Management Commission Standard 15A NCAC 02D .1111 "Maximum
Achievable Control Technology" (MALT)as promulgated in 40 CFR 63,Subpart DDDD. "National Emission
Standards for Hazardous Air Pollutants:Plywood and Composite Wood Products"and Subpart A"General
Provisions."
Definitions and Nomenclature[§63.2292]
b. For the purposes of this permit condition,the definitions and nomenclature contained in§63.2292 shall apply.
40 CFR Part 63 Subpart A General Provisions[§63.2290]
c. The Permittee shall comply with the requirements of 40 CFR 63 Subpart A General Provisions according to
the applicability of Subpart A to such sources,as identified in Table 10 to 40 CFR Part 63, Subpart DDDD.
Affected Sources Not Subject to Operating Requirements[§63.2252]
d. For process units not subject to the operating requirements in Sections 2.2 A.Le through 1,The Permittee is not
required to comply with the compliance options,work practice requirements,performance testing,monitoring,

Air Permit 03449T52
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SSM plans,and recordkeeping or reporting requirements of this 40 CFR 63 Subpart DDDD,or any other
requirements in 40 CFR 63 Subpart A except for the initial notification requirements in§63.9(b).
Operatin_Requirements[15A NCAC 02Q.0508(f), §63.2240(b)]
Group I Coating Operations
e. The Permittee shall use non-HAP coatings(as defined§63.2292)in its Group 1 miscellaneous coating
operations(including ID No.I-Spray paints). [Table 3,40 CFR 63 Subpart DDDD]
MDF Plant
f. The emissions from the MDF process units in Table 2.2 A.1 shall be controlled by the biofilter(ID No.CD 18):
Table 2.2 A.1
Emission Source ID No. Emission Source Descri tion
ES-01 Refiner
ES-02-A Energy System consisting of a dry/wet wood/woodwaste-fired burner(205
million Btu per hour heat input)
ES-02-B Two Sta e Dryer System
ES-02-C and ES-02-D Two backup natural gas-fired dryer burners(78.5 and 17 million Btu per hour
heat input respectively)
ES-16 MDF Press and Press Hall
g. The HAP emissions from the sources in Table 2.2 A.1 above shall be controlled to meet one of the following
compliance options: [§63.2240]
i. Reduce emissions of total HAP,measured as THC(as carbon) by 90 percent;or
ii. Limit emissions of total HAP,measured as THC(as carbon)a,to 20 ppmvd;or
iii. Reduce methanol emissions by 90 percent;or
iv. Limit methanol emissions to less than or equal to 1 ppmvd if uncontrolled methanol emissions entering the
control device are greater than or equal to 10 ppmvd;or
v. Reduce formaldehyde emissions by 90 percent;or
vi. Limit formaldehyde emissions to less than or equal to 1 ppmvd if uncontrolled formaldehyde emissions
entering the control device are greater than or equal to 10 ppmvd.
h. The Permittee shall maintain the 24-hour block biofilter bed temperature within the following range as
established according to condition n. [§63.2240]
i. minimum biofilter bed temperature: 132 OF
ii. maximum biofilter bed temperature: 145 OF
i. The Permittee shall operate the MDF Press(ID No.ES16)in an enclosure that meets the definition of a wood
products enclosure in§ 63.2292. [§63.2240(b)]
PB Plant
j. The dryers(ID Nos. 1420,and 1430)shall be operated such that:
i. the process furnish will have a 24-hour block average inlet moisture content of less than or equal to 30
percent(by weight,dry basis);and
ii. the 24-hour block average inlet dryer temperature is less than or equal to 600*F.
[§63.2241]
k. The press(ID No.DEF-2010)shall meet the production-based compliance option by emitting less than 0.30 lb
of total HAP per thousand square feet of board,%"basis. [§63.2240]
1. i. For the press(ID No.DEF-2010),the Permittee has chosen the methanol and formaldehyde content in the
resin as the process unit controlling parameter.The Permittee shall maintain the methanol and
formaldehyde content of the resins used to levels below those used during the initial compliance

Air Permit 03449T52
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demonstration as shown below.The Permittee shall determine the methanol and formaldehyde resin levels
based on vendor supplied data on a per shipment basis. [§63.2262(n)]
Table 2.2 A.1.1
HAP I Resin content limit(%by weight)
Sum of Methanol and Formaldehvde 1 0.3
ii. The parameter value in Table 2.2 A.1.1 does not apply during performance testing.If,during performance
testing,the resin content used is less than the value in Table in 2.2 A.I J and is relied upon to demonstrate
compliance,the permittee shall submit a request to revise the value in the permit at the same time the test
report required pursuant to General Condition JJ.4 is submitted.The permit revision will be processed
pursuant to 15A NCAC 02Q.0514.If,during performance testing,the resin content used is greater than
the limit in Table 2.2 A.1.1,the Permittee may request to revise the value in the permit pursuant to 15A
NCAC 02Q.0515.
Testing[15ANCAC 02Q.0508(f)]
in. If emissions(performance)testing is required,the testing shall be performed in accordance General Condition
JJ.If the results of this test are above the limit given in Section 2.2 A.1.g above,the Permittee shall be deemed
in noncompliance with 15A NCAC 02D.1111.
i. The Permittee shall test the biofilter(ID No.CD18),reestablish the monitoring parameters at Section 2.2
A.l.h and submit the test results,within 180 days after completion of the remedial work as described in
the Special Order of Consent 2019-001(Attachment Q.
n. All initial performance tests shall be conducted pursuant to§63.2260.
o.. Any subsequent performance tests shall be conducted pursuant to§63.2262.
MDF Plant Biofilter
p. For the biofilter(ID No.CD18),the Permittee:
i. shall conduct the initial performance tests within 180 days following initial startup of the biofilter
[§63.2261];
ii. shall establish the biofilter bed temperature range during the initial performance tests;and
iii. may expand the biofilter bed temperature operating range;
according to§63.2262 and§63.2267.
q. For the biofilter(ID No.CD18),the Permittee shall conduct a repeat performance test using the applicable
method(s)specified in Table 4 to 40 CFR 63 Subpart DDDD two years following the previous performance
test and within 180 days after each replacement of any portion of the biofilter bed media with a different type
of media or each replacement of more than 50 percent(by volume)of the biofilter bed media with the same
type of media. [Table 4,40 CFR 63 Subpart DDDD]
r. Reserved
s. Reserved
t. If these tests are not conducted pursuant to and do not meet the requirements of Sections 2.2 A.Lin through s,
the Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111.
General Requirements[15A NCAC 02Q.0508(f),63.2250]
u. i. The Permittee must be in compliance with the compliance options,operating requirements,and the work
practice requirements in 40 CFR 63 Subpart DDDD at all times,except during periods of process unit or
control device startup,shutdown,and malfunction;prior to process unit initial startup;and during the
routine control device maintenance exemption specified in Section 2.2 A.l.v.The compliance options,
operating requirements,and work practice requirements do not apply during times when the process
unit(s)subject to the compliance options,operating requirements,and work practice requirements are not
operating,or during periods of startup,shutdown,and malfunction. Startup and shutdown periods must not
exceed the minimum amount of time necessary for these events.
ii. The Permittee must always operate and maintain the affected source,including air pollution control and
monitoring equipment,according to the provisions in§63.6(e)(1)(i).
iii. The Permittee must develop a written Startup,Shutdown,and Malfunction Plan(SSMP)according to the
provisions in§63.6(e)(3).
iv. To the extent practical,startup and shutdown of emission control systems must be scheduled during times
when process equipment is also shut down. [§ 63.2251(e)]
v. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .I 111 if these requirements are

Air Permit 03449T52
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not met.
Routine Control Device Maintenance Exemption RCDME [15A NCAC 02Q.0508(f)]
v. i. The emission limitations in section 2.2 A.l.g do not apply during times when control device maintenance
covered under the approved RCDME(per request letter dated September 26,2019)is performed.The
Permittee must minimize emissions to the greatest extent possible during these RCDME periods.
[§63.2251(d)]
ii. Operation of the process units controlled as described in Section 2.2 A.1.f during periods of RCDME as
requested in the letter dated September 29,2019 must not exceed 3 percent of annual operating uptime for
each process unit. [§63.225 1(b)]
iii. Pursuant to§63.2251(c),the request for the RCDME,must be incorporated by reference and attached to
the affected source's title V permit.The RCDME is attached to the title V permit as ATTACHMENT B.
Monitoring Requirements[15A NCAC 02Q.0508(f)]
Temperature Monitoring
w. i. The Permittee shall monitor and record the MDF Plant Biofilter(ID No.CD18)bed temperature and the
PB Plant dryers(ID Nos. 1420 and 1430)average inlet temperature with continuous parameter monitoring
systems(CPMS).
ii. The Permittee shall install,operate,and maintain each temperature CPMS according to§63.2269(a)and
(b)•
Moisture Monitoring
x. The Permittee shall install,operate,and maintain a moisture CPMS on the PB plant dryers(ID Nos. 1420 and
1430)according to§63.2269(a)and(c).
All CPMS
y. i. For the Biofilter(ID No.CD18),and dryers(ID No. 1420 and 1430)the Permittee shall determine the 24-
hour block average of all recorded readings,calculated after every 24 hours of operation as the average of
the evenly spaced recorded readings in the previous 24 operating hours(excluding periods described in
paragraphs ii and iii below. [§63.2270(e)]
ii. Except for,as appropriate,monitor malfunctions,associated repairs,required quality assurance or control
activities(including,as applicable,calibration checks and required zero and span adjustments)the
Permittee shall conduct all monitoring in continuous operation at all times that the process unit is
operating.For purposes of calculating data averages,the Permittee must not use data recorded during
monitoring malfunctions,associated repairs,out-of-control periods,or required quality assurance or
control activities.The Permittee must use all the data collected during all other periods in assessing
compliance.A monitoring malfunction is any sudden,infrequent,not reasonably preventable failure of the
monitoring to provide valid data.Monitoring failures that are caused in part by poor maintenance or
careless operation are not malfunctions.Any period for which the monitoring system is out-of-control and
data are not available for required calculations constitute an instance of noncompliance with the
monitoring requirements. [§63.2270(b)]
iii. The Permittee may not use data recorded during monitoring malfunctions,associated repairs,and required
quality assurance or control activities;data recorded during periods of startup,shutdown,and malfunction;
or data recorded during periods of control device downtime covered in any approved routine control
device maintenance exemption in data averages and calculations used to report emission or operating
levels,nor may such data be used in fulfilling a minimum data availability requirement,if applicable.The
Permittee must use all the data collected during all other periods in assessing the operation of the control
system. [§63.2270(c)]
iv. To calculate the data averages for each 24-hour averaging period,the Permittee must have at least 75
percent of the required recorded readings for that period using only recorded readings that are based on
valid data(i.e.,not from periods described in paragraphs ii and iii above0. [§63.2270(f)]
z. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the monitoring requirements
in Section 2.2 A.l.v through y are not met.
Recordkeeping Requirements[15A NCAC 02Q.0508(f),§63.2282 and.2283]
aa. The Permittee shall keep the following:

Air Permit 03449T52
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i. a copy of each notification and report submitted to comply with this subpart,including all documentation
supporting any Initial Notification or Notification of Compliance Status,according to the requirements in
§63.10(b)(2)(xiv);
ii. the records in§63.6(e)(3)(iii)through(v)related to startup,shutdown,and malfunction;
iii. documentation of the approved routine control device maintenance exemption,requested under§63.2251;
iv. records of performance tests and performance evaluations as required in§63.1 0(b)(2)(viii);
v. associated records for sections 2.2 A.l.0 through y;
vi. records showing that non-HAP coatings are being used;and
vii. associated records for sections 2.2 A.1.1;
bb. The Permittee shall:
i. maintain records in a form suitable and readily available for expeditious review as specified in
§63.10(b)(1).
ii. as specified in§63.10(b)(1),keep each record for 5 years following the date of each occurrence,
measurement,maintenance,corrective action,report,or record.
iii. keep each record on site for at least 2 years after the date of each occurrence,measurement,maintenance,
corrective action,report,or record according to§63.10(b)(1).The Permittee can keep the records offsite
for the remaining 3 years.
[§63.2283]
cc. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if records are not maintained
pursuant to Sections 2.2 A.l.aa through cc.
Reporting Requirements[15A NCAC 02Q.0508(f),§63.2281]
dd. The permittee shall submit a compliance report semiannually postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December and July 30 of each calendar
year for the preceding six-month period between January and June.All instances of noncompliance with the
requirements of this permit must be clearly identified. [§63.228l(b)(5)and§63.2281(g)]
The compliance report must contain the information in paragraphs(1)through(8)of this section.
(1) Company name and address.
(2) Statement by a responsible official with that official's name,title,and signature,certifying the truth,
accuracy,and completeness of the content of the report.
(3) Date of report and beginning and ending dates of the reporting period.
(4) If you had a startup,shutdown,or malfunction during the reporting period and you took actions consistent
with your SSMP,the compliance report must include the information specified in§63.1 0(d)(5)(i).
(5) A description of control device maintenance performed while the control device was offline and one or
more of the process units controlled by the control device was operating,including the information
specified in paragraphs(5)(i)through(iii)of this section.
(i) The date and time when the control device was shut down and restarted.
(ii) Identification of the process units that were operating and the number of hours that each process unit
operated while the control device was offline.
(iii)A statement of whether or not the control device maintenance was included in your approved routine
control device maintenance exemption developed pursuant to§63.2251.If the control device
maintenance was included in your approved routine control device maintenance exemption,then you
must report the information in paragraphs(5)(iii)(A)through(C)of this section.
(A) The total amount of time that each process unit controlled by the control device operated during
the semiannual compliance period and during the previous semiannual compliance period.
(B) The amount of time that each process unit controlled by the control device operated while the
control device was down for maintenance covered under the routine control device maintenance
exemption during the semiannual compliance period and during the previous semiannual
compliance period.
(C) Based on the information recorded under paragraphs(y)(5)(iii)(A)and(B)of this section for each
process unit,compute the annual percent of process unit operating uptime during which the
control device was offline for routine maintenance using Equation 1 of this section.
DT + DT
RiY1= (Eq. 1)
PUY +PUC
Where:
RM=Annual percentage of process unit uptime during which control device is down for routine
control device maintenance;

Air Permit 03449T52
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PUP Process unit uptime for the previous semiannual compliance period;
PUS Process unit uptime for the current semiannual compliance period;
DTP Control device downtime claimed under the routine control device maintenance exemption
for the previous semiannual compliance period;
DTI Control device downtime claimed under the routine control device maintenance exemption
for the current semiannual compliance period.
(6) The results of any performance tests conducted during the semiannual reporting period.
(7) If there are no instances of noncompliance with any applicable compliance option or operating
requirement,a statement that there were no instances of noncompliance with the compliance options or
operating requirements during the reporting period.
(8) If there were no periods during which the continuous monitoring system(CMS),including CPMS,was
out-of-control as specified in§63.8(c)(7),a statement that there were no periods during which the CMS
was out-of-control during the reporting period.
[§63.2281(c)]
ee. The compliance report must also include the following information for each instance of noncompliance from a
compliance option or operating requirement where you are using a CMS to comply with the compliance
options and operating requirements.This includes periods of startup,shutdown,and malfunction and routine
control device maintenance.
(1) The date and time that each malfunction started and stopped.
(2) The date and time that each CMS was inoperative,except for zero(low-level)and high-level checks.
(3) The date,time,and duration that each CMS was out-of-control,including the information in§63.8(c)(8).
(4) The date and time that each instance of noncompliance started and stopped,and whether each instance of
noncompliance occurred during a period of startup,shutdown,or malfunction;during a period of control
device maintenance covered in your approved routine control device maintenance exemption;or during
another period.
(5) A summary of the total duration of the instance of noncompliance during the reporting period and the total
duration as a percent of the total source operating time during that reporting period.
(6) A breakdown of the total duration of the instances of noncompliance during the reporting period into those
that are due to startup,shutdown,control system problems,control device maintenance,process problems,
other known causes,and other unknown causes.
(7) A summary of the total duration of CMS downtime during the reporting period and the total duration of
CMS downtime as a percent of the total source operating time during that reporting period.
(8) A brief description of the process units.
(9) A brief description of the CMS.
(10)The date of the latest CMS certification or audit.
(11)A description of any changes in CMS,processes,or controls since the last reporting period.
[§63.2271, §63.2281(e)]
ff. The compliance report must also contain the following information for each instance of noncompliance with a
compliance option or operating requirement and for each instance of noncompliance with the work practice
requirements that occurs where you are not using a CMS to comply with the compliance options,operating
requirements,or work practice requirements.This includes periods of startup,shutdown,and malfunction and
routine control device maintenance.
(1) The total operating time of each affected source during the reporting period.
(2) Information on the number,duration,and cause of instances of noncompliance(including unknown cause,
if applicable),as applicable,and the corrective action taken.
[§63.2271,§63.2281(d)]
gg. The permittee shall submit a report if a startup,shutdown,or malfunction during the reporting period occurred
that is not consistent with the SSMP.The report must contain the following:
i. Actions taken for the event and must be submitted by fax or telephone within two working days after
starting actions inconsistent with the plan.
ii. The information in§63.10(d)(5)(ii)and must be submitted by letter within seven working days after the
end of the event unless alternative arrangements have been made with the permitting authority.
[Table 9,40 CFR 63 Subpart DDDD]
hh. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.1111 if the reporting requirements in
Sections 2.2 A.1.dd through gg are not met.
Notification Reaufirements[§63.2280]
ii. The Permittee shall:

Air Permit 03449T52
Page 49
i. submit all of the notifications in§63.7(b) [Notification of Performance Test]and(c) [Quality Assurance
Program],63.8(e)[Performance evaluation of CMS],(f)(4)[alternative monitoring method]and(f)(6)
[alternative RA TA],63.9(b)through(e)[initial notifications],and(g) [CMS notifications]and(h)
[Notification of compliance status]by the dates specified. [§63.2280(a)]
ii. submit a written notification of intent to conduct a performance test at least 60 calendar days before the
performance test is scheduled to begin as specified in§ 63.7(b)(1).
iii. be deemed in noncompliance with 15A NCAC 02D A I I I if these notification requirements are not met.
STATE ENFORCEABLE ONLY
2. 15A NCAC 02D.1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a.The Permittee shall not operate the facility without implementing management practices or installing and
operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or
contributing to objectionable odors beyond the facility's boundary.
B. Medium Density Fiberboard Facilities
The following table provides a summary of the limits and/or standards for the MDF facilities:
Regulated Pollutant Limits/Standards Applicable Regulation
NOx,PM2.5,PMio See Section 2.2 B.1. 15A NCAC 02Q.0317
(P SD Avoidance
VOC Best Available Control Technology 15A NCAC 02D.0530
1. 15A NCAC 02Q.0317: AVOIDANCE CONDITIONS for 15A NCAC 02D.0530:PREVENTION OF
SIGNIFICANT DETERIORATION
a. In order to the avoid the applicability of 15A NCAC 02D.0530,the combined emissions from the sources
indicated in the permitted equipment list in Section 1 as the Medium Density Fiberboard Facilities(MDF
sources)shall not exceed the following limits:
i. Nitrogen oxide emissions shall not exceed 177.8 tons per consecutive 12-month.
ii. PM-2.5 emissions shall not exceed 111.9 tons per consecutive 12-month period.
ii. PM-10 emissions shall not exceed 116.9 tons per consecutive 12-month period.
Testing[15A NCAC 02Q.0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the
results of this test exceed the limits given in Section 2.2 B.La.above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0530.
c. Under the provisions of NCGS 143-215.108,the Permittee shall test the biofilter(ID No CD18)to establish
emission factors to be used for purposes of Section 2.2 B.Le and f below.Testing shall be completed within
180 days after the start-up of the biofilter(ID No.CD18). Testing shall be conducted in scenarios that
represent worst-case emissions.The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530
if these requirements are not met.
Monitoringl5A NCAC 02Q.0508(f)]
d. The Permittee shall maintain a minimum urea/water solution(45%urea concentration by volume)injection
rate of 0.24 gpm(3-hour block average)(ID No.CD02-A). This injection rate does not apply during
performance testing.
e. The Permittee shall calculate on a monthly basis the monthly and rolling 12-month total for each of the
nitrogen oxides,PM10 and PM2.5 emissions from the MDF sources.
f. For purposes of condition e.the Permittee shall utilize the following emission factors in Table 2.2.B.1 below.
If the Permittee conducts source testing that results in any emission factors greater than those in Table 2.2.13.1,
the Permittee shall,submit a permit application to revise the permit with the test report required in Section 2.2
B.1 c.
g. The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if the requirements in Sections
2.2 B.Ld through f are not met.
RecordkeepineI5A NCAC 02Q.0508(f)]
h. The Permittee shall keep the following records in a logbook(written or electronic format):
i. the 3-hour block averages of the urea/water injection rate(ID No.CD02-A);

Air Permit 03449T52
Page 50
ii. the monthly and rolling 12-month total for each of the nitrogen oxides,PM10 and PM2.5 emissions from
the MDF sources;and
iii. the process rates of the dryers in ODMT/hr,the process rates of the press in MSF/hr;and the heat inputs
for the combustion sources in MMBtu/hr.These values may be calculated on a monthly average basis.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if these requirements are not
met.

Air Permit 03449T52
Page 51
Table 2.2.B.1
-F
Emission Description PM-10 PM-2.5 NOx
Point
� EF Units EF Units EF Units
EP-01 Refiner Abort Cyclone 3.52 lb/hr 3.52 lb/hr
EP-03 Fiber Sifter System Filter 0.58 lb/hr 0.58 lb/hr
EP-04 Forming Line Clean-Up Filter 0.55 lb/hr 0.55 lb/hr
EP-05 Mat rejects stem Filter 0.48 lb/hr 0.48 lb/hr
EP-07 Saw System Filter 0.84 lb/hr 0.84 lb/hr
EP-08 Sander System No.I Exhaust Filter 0.90 lb/hr 0.9 lb/hr
EP-09 Recycled Fiber Silo No.I Filter 0.02 lb/hr 0.02 lb/hr
EP-10 Sander S-stem No-2 Exhaust Filter 0.45 lb/hr 0.45 lb/hr
EP-12 Sander Dust Silo No.I Filter 0.02 lb/hr 0.02 lb/hr
EP-13 DR Sawdust Silo Filter 0.02 lb/hr 0.02 lb/hr
EP-15 Recycled Fiber Silo No.2 Filter 0.02 lb/hr 0.02 lb/hr
EP-17 Sander Dust Silo No.2 Filter 0.02 lb/hr 0.02 lb/hr
EP-18/19/20 N.G.Combustion 7.45E-03 lb/MMBtu 7.45E-03 lb/MMBtu 0.098 lb/MNBtu
ES-02-A Energy System Abort(50150 dry/wet fuel) 0.5 lb/MMBtu 0.43 lb/MMBtu 0.33 lb/MMBtu
ES-02-A Energy System Abort(dry fuel) 0.36 lb/MMBtu 0.31 lb/MMBtu 0.33 lb/MMBtu
EP-16 Press Scrubber 0.088 lb/MSF 0.088 lb/MSF
EP-02/14 Dryer scrubber(SW) 0.51 lb/ODMT 0.51 lb/ODMT 0.33 lb/MMBtu
EP-02/14 Dryer scrubber(SW/HW) 0.51 lb/ODMT 0.51 lb/ODMT 0.33 lb/MMBtu
EP-16 Press Scrubber(CDMDT) 0.088 lb/MSF 0.088 lb/MSF
EP-02/14 Dryer scrubber(SW)(CDMDT) 0.51 lb/ODMT 0.51 lb/ODMT 0.33 lb/MMBtu
EP-02/14 Dryer scrubber(SW/HW)(CDMDT) 0.51 lb/ODMT 0.51 lb/ODMT 0.33 lb/MMBtu
SW-softwood only processing
SW/HW-softwood and hardwood processing
CDMDT-Control Device Maintenance Downtime,MACT Subpart DDDD,CD02-2,CD14-2,CD16-2

Air Permit 03449T52
Page 52
Reporting[15A NCAC 02Q.0508 (f)]
i. The Permittee shall submit a semi-annual summary report,acceptable to the Regional Air Quality Supervisor,of
monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December,and July 30 of each calendar year for the preceding six-month period
between January and June. The report shall contain the following:
i. a summary of the 3-hour block averages of the urea/water injection rate(ID No CD02-A);and
ii. the monthly and rolling 12-month total for each of the nitrogen oxides,PM10 and PM2.5 emissions from the
MDF sources.The 12 month rolling totals shall be calculated for each of the previous 17 months.
2. 15A NCAC 02D.0530:PREVENTION OF SIGNIFICANT DETERIORATION
a. For PSD purposes,the following'Best Available Control Technology"(BACT)permit limitations shall not be
exceeded for units at the MDF Facilities:
Table 2.2.13.2
Equipment/Process ID No. Emission Limits* Control Technology
MDF Facilities Operations
Two Stage Dryer System ES-02-B
with backup natural gas ES-02-C-1,C-2
burners ES-02-D [50%DRE of WPP1 VOC Biofilter(ID No.CD18)
MDF Board Cooler ES-06-B
MDF Press and Press Hall ES-16
MDF Woodworking Operations
Fiber Sifter System ES-03 0.082 lb WPP1 VOC/ODMT
Forming Line Clean-Up ES-04 0.082 lb WPP1 VOC/ODMT
System
Mat Reject System ES-05 0.082 lb WPP1 VOC/ODMT
Saw System ES-07 0.01 lb WPP1 VOC/MSF
Sander System No. 1 ES-08 0.01 lb WPP1 VOC/MSF
(Primary sander
Sander System No. 2 None
Finishin Sander ES-10 0.01 lb WPP1 VOC/MSF
Recycled Fiber Silo No. 1 ES-09 0.082 lb WPP1 VOC/ODMT
Recycled Fiber Silo No.2 ES-15 0.082 lb WPP1 VOC/ODMT
Sander Dust Silo No. 1 ES-12 0.268 lb WPP1 VOC/ODMT
Sander Dust Silo No.2 ES-17 0.268 lb WPP1 VOC/ODMT
Dry Sawdust Silo Filter ES-13 0.268 lb WPP1 VOC/ODMT
Other Emission Sources in the M[DF Plant
Work practice standards and
Diesel Fuel-fired Emergency ES-21 maintenance as required by 40 CFR None
Generators I-DFP 40 Part 63 Subpart ZZZZ and CFR
40 Part 60 Subpart IIII as applicable
Natural gas-fired hot oil ES-18,ES-19, Proper design,maintenance,and None
heaters ES-20 op gratin practices
Gasoline storage tank I-Gas Proper design,maintenance,and None
Diesel storage tanks Not permitted o erating practices _
* BACT limits shall apply at all times.However,emissions resulting from startup,shutdown or malfunction as defined
under 15A NCAC 02D.0535,exceeding the limits in condition a.above are permitted,provided that the Permittee,to the
extent practicable,maintains and operates each emission source including any associated air pollution control equipment
listed in this Table,in a manner consistent with good air pollution control practice for minimizing emissions.
** Wood Products Protocol 1 (WPP1)as provided in U.S.EPA,document entitled,"Interim VOC Measurement Protocol
for the Wood Products Industry,"July 2007,

Air Permit 03449T52
Page 53
Testing[15A NCAC 02Q.0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the
results of this test exceed the limits given in Section 2.2 B.2.a above,the Permittee shall be deemed in
noncompliance with 15A NCAC 02D.0530.
c. Under the provisions of NCGS 143-215.108,the Permittee shall demonstrate compliance with the emission limits in
Table 2.2 B.2.for the MDF facilities controlled by the biofilter(ID No.CD18).Testing shall be conducted in
accordance with the following:
i. The Pemuttee shall perform testing and establish a minimum and maximum biofilter bed temperature during
testing,using procedures specified in Section 2.2 A.Lrn through p,excepting p.i.
ii. The energy system(ID No.ES-02-A),the two-stage dryer system(ID No.ES-02-B),and the MDF Press(ID
No.ES-16)shall be in operation during source testing. The Permittee shall be responsible for ensuring,within
the limits of practicality,that the equipment or processes being tested are operated at or near their maximum
normal production rate or at a lesser rate if specified by the Director or his delegate.
iii. Testing shall be completed within 180 days after the issuance of permit no.03449T50 unless an alternate date is
approved by the DAQ.This alternate date may include any testing occurring after September 28,2018.
iv. The Permittee shall submit a written report of the test(s)results to the Regional Supervisor,DAQ within 60
days of completion of the initial test and include a permit application to revise the permit to include monitoring
parameters for the biofilter(ID No.CD18)at Section 2.2 13.21.
v. Subsequent testing shall be required concurrent with the testing requirements of Section 2.2 A.l.q. After the
establishment of the initial biofilter bed temperature range in Section 2.2 B.21,revisions to the bed temperature
range may occur only as the result of retesting to determine compliance with the emission limits in Table 2.2
B.2.for the MDF facilities controlled by the biofilter.
If the results of the tests are above any of the limits in Section 2.2 B.2.a above or if the testing is not conducted in
accordance with Section 2.2 B.2.c,the Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530.
Monitorin IRecordkee in Requirements [15A NCAC 02Q.0508(f)]
d. The Permittee shall perform inspections and maintenance as recommended by the manufacturer,if any,for the MDF
woodworking operations cited in Table 2.2.B.2. The results of inspection and maintenance activities for the MDF
woodworking operations shall be maintained in a logbook(written or electronic format)on-site and made available
to an authorized representative upon request. The logbook shall record the following:
i. the monthly throughput for each emission source in either ODMT or MSF,as appropriate.
ii. the results of any maintenance activities performed on the emission sources,including corrective actions.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if these monitoring and recordkeeping
activities are met.
e. The monitoring and recordkeeping requirements in Section 2.1 D.S.f through 1,as applicable,shall be sufficient to
ensure compliance with 15A NCAC 02D.0530 for the natural gas-fired hot oil heaters(ID Nos.ES-18,ES-19,and
ES-20). The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if these monitoring and
recordkeeping requirements are not met.
f. The Permittee shall comply with the work practice standards and maintenance requirements and associated
recordkeeping and reporting as required by 40 CFR 40 Part 63 Subpart ZZZZ and CFR 40 Part 60 Subpart IIII,as
applicable,for the emergency diesel fuel-fired engines(ID Nos.ES-21 and I-DFP). The Permittee shall be deemed
in noncompliance with 15A NCAC 02D.0530 if these monitoring and recordkeeping requirements are not met.
g. No monitoring or recordkeeping is required for VOC emissions from the MDF storage tanks cited in Table 2.2.B.2.
above.
h. The Permittee shall conduct the following monitoring and recordkeeping activities for the MDF facilities operations
in Table 2.2 B.2 above.
i. The Permittee shall record the monthly throughput for each emission source in either ODMT or MSF,as
appropriate.
ii. The Permittee shall install and operate and maintain continuous temperature monitoring system on the biofilter
(ID No.CD18)according to section 2.2 A.l.w.ii.
iii. The Permittee shall maintain the 24-hour block biofilter bed temperature within the following range as
established according to Section 2.2 B.2.c.
(A) minimum biofilter bed temperature:TBD IF
(B) maximum biofilter bed temperature: TBD IF
iv. For biofilter bed temperature monitoring,the Permittee shall monitor and collect data according to Section 2.2
A.l.y.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D.0530 if the biofilter bed temperature range
is not maintained or if the monitoring and recordkeeping requirements are not met.

Air Permit 03449T52
Page 54
Re ortin<, Req uirements[15A NCAC 02Q.0508(f)]
i. The Permittee shall submit the results of any maintenance performed on the biofilter(ID No.CD18)within 30 days
of a written request by the DAQ.
j. The Permittee shall submit a summary report of monitoring and record keeping activities postmarked on or before
January 30 of each calendar year for the preceding six-month period between July and December and July 30 of
each calendar year for the preceding six-month period between January and June. All instances of deviations from
the requirements of this permit must be clearly identified.
2.3 Permit Shield for Non-Applicable Requirements
The Permittee is shielded from the following non-applicable requirements[15A NCAC 02Q.0512(a)(1)(A)and(B)].
A. New Source Performance Standard(NSPS) Subpart Db is not applicable to the bio-mass fired Energy System(ID
No.ES-02A)because the system is considered a process heater and the primary purpose is to produce a final product.

Air Permit 03449T52
Page 55
SECTION 3 - GENERAL CONDITIONS (version 5.3, 08/21/2018)
This section describes terms and conditions applicable to this Title V facility.
A. General Provisions[NCGS 143-215 and 15A NCAC 02Q.0508(i)(16)]
1. Terms not otherwise defined in this permit shall have the meaning assigned to such terms as defined in 15A NCAC
02D and 02Q.
2. The terms,conditions,requirements,limitations,and restrictions set forth in this permit are binding and enforceable
pursuant to NCGS 143-215.114A and 143-215.114B,including assessment of civil and/or criminal penalties.Any
unauthorized deviation from the conditions of this permit may constitute grounds for revocation and/or enforcement
action by the DAQ.
3. This permit is not a waiver of or approval of any other Department permits that may be required for other aspects of the
facility which are not addressed in this permit.
4. This permit does not relieve the Permittee from liability for harm or injury to human health or welfare,animal or plant
life,or property caused by the construction or operation of this permitted facility,or from penalties therefore,nor does
it allow the Permittee to cause pollution in contravention of state laws or rules,unless specifically authorized by an
order from the North Carolina Environmental Management Commission.
5. Except as identified as state-only requirements in this permit,all terms and conditions contained herein shall be
enforceable by the DAQ,the EPA,and citizens of the United States as defined in the Federal Clean Air Act.
6. Any stationary source of air pollution shall not be operated,maintained,or modified without the appropriate and valid
permits issued by the DAQ,unless the source is exempted by rule. The DAQ may issue a permit only after it receives
reasonable assurance that the installation will not cause air pollution in violation of any of the applicable requirements.
A permitted installation may only be operated,maintained,constructed,expanded,or modified in a manner that is
consistent with the terms of this permit.
B. Permit Availability [15A NCAC 02Q.0507(k)and.0508(i)(9)(B)]
The Permittee shall have available at the facility a copy of this permit and shall retain for the duration of the permit term one
complete copy of the application and any information submitted in support of the application package. The permit and
application shall be made available to an authorized representative of Department of Environmental Quality upon request.
C. Severabilil N Clause[15A NCAC 02Q.0508(i)(2)]
In the event of an administrative challenge to a final and binding permit in which a condition is held to be invalid,the
provisions in this permit are severable so that all requirements contained in the permit,except those held to be invalid,shall
remain valid and must be complied with.
D. Submissions[15A NCAC 02Q.0507(e)and 02Q.0508(i)(16)]
Except as otherwise specified herein,two copies of all documents,reports,test data,monitoring data,notifications,request
for renewal,and any other information required by this permit shall be submitted to the appropriate Regional Office. Refer
to the Regional Office address on the cover page of this permit. For continuous emissions monitoring systems(CEMS)
reports,continuous opacity monitoring systems(COMS)reports,quality assurance(QA)/quality control(QC)reports,acid
rain CEM certification reports,and NOx budget CEM certification reports,one copy shall be sent to the appropriate
Regional Office and one copy shall be sent to:
Supervisor,Stationary Source Compliance
North Carolina Division of Air Quality
1641 Mail Service Center
Raleigh,NC 27699-1641
All submittals shall include the facility name and Facility ID number(refer to the cover page of this permit).
E. Duty to Comply[15A NCAC 02Q.0508(i)(3)]
The Permittee shall comply with all terms,conditions,requirements,limitations and restrictions set forth in this permit.
Noncompliance with any permit condition except conditions identified as state-only requirements constitutes a violation of
the Federal Clean Air Act. Noncompliance with any permit condition is grounds for enforcement action,for permit
termination,revocation and reissuance,or modification,or for denial of a permit renewal application.

Air Permit 03449T52
Page 56
F. Circumvention-STATE ENFORCEABLE ONLY
The facility shall be properly operated and maintained at all times in a manner that will effect an overall reduction in air
pollution. Unless otherwise specified by this permit,no emission source may be operated without the concurrent operation
of its associated air pollution control device(s)and appurtenances.
G. Permit Modifications
1. Administrative Permit Amendments[I 5A NCAC 02Q.0514]
The Permittee shall submit an application for an administrative permit amendment in accordance with 15A NCAC 02Q
.0514.
2. Transfer in Ownership or Operation and Application Submittal Content[15A NCAC 02Q.0524 and 02Q.0505]
The Permittee shall submit an application for an ownership change in accordance with 15A NCAC 02Q.0524 and 02Q
.0505.
3. Minor Permit Modifications[15A NCAC 02Q.0515]
The Permittee shall submit an application for a minor permit modification in accordance with 15A NCAC 02Q.0515.
4. Significant Permit Modifications[15A NCAC 02Q.0516]
The Permittee shall submit an application for a significant permit modification in accordance with 15A NCAC 02Q
.0516.
5. Reopening for Cause[15A NCAC 02Q.0517]
The Permittee shall submit an application for reopening for cause in accordance with 15A NCAC 02Q.0517.
H. Changes Not Reg uirin Permit Modifications
1. Reporting Requirements
Any of the following that would result in new or increased emissions from the emission source(s)listed in Section 1 must
be reported to the Regional Supervisor,DAQ:
a. changes in the information submitted in the application;
b. changes that modify equipment or processes;or
c. changes in the quantity or quality of materials processed.
If appropriate,modifications to the permit may then be made by the DAQ to reflect any necessary changes in the
permit conditions. In no case are any new or increased emissions allowed that will cause a violation of the emission
limitations specified herein.
2. Section 502(b)(10)Changes[15A NCAC 02Q.0523(a)]
a. "Section 502(b)(10)changes"means changes that contravene an express permit term or condition.Such changes
do not include changes that would violate applicable requirements or contravene federally enforceable permit
terms and conditions that are monitoring(including test methods),recordkeeping,reporting,or compliance
certification requirements.
b. The Permittee may make Section 502(b)(10)changes without having the permit revised if:
i. the changes are not a modification under Title I of the Federal Clean Air Act;
ii. the changes do not cause the allowable emissions under the permit to be exceeded;
iii. the Permittee notifies the Director and EPA with written notification at least seven days before the change is
made;and
iv. the Permittee shall attach the notice to the relevant permit.
c. The written notification shall include:
i. a description of the change;
ii. the date on which the change will occur;
iii. any change in emissions;and
iv. any permit term or condition that is no longer applicable as a result of the change.
d. Section 502(b)(10)changes shall be made in the permit the next time that the permit is revised or renewed,
whichever comes first.
3. Off Permit Changes[15ANCAC 02Q.0523(b)]
The Permittee may make changes in the operation or emissions without revising the permit if.
a. the change affects only insignificant activities and the activities remain insignificant after the change;or
b. the change is not covered under any applicable requirement.
4. Emissions Trading[15A NCAC 02Q.0523(c)]
To the extent that emissions trading is allowed under 15A NCAC 02D,including subsequently adopted maximum
achievable control technology standards,emissions trading shall be allowed without permit revision pursuant to 15A
NCAC 02Q.0523(c).

Air Permit 03449T52
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I.A Re ortin Reguirements for Excess Emissions and Permit Deviations[15A NCAC 02D.0535(f)and 02Q.0508(f)(2)]
"Excess Emissions"-means an emission rate that exceeds any applicable emission limitation or standard allowed by any
rule in Sections.0500,.0900,.1200,or.1400 of Subchapter 02D;or by a permit condition;or that exceeds an emission limit
established in a permit issued under 15A NCAC 02Q.0700. (Note:Definitions of excess emissions under 02D.1110 and
02D.HII shall apply where defined by rule)
"Deviations"-for the purposes of this condition,any action or condition not in accordance with the terms and conditions of
this permit including those attributable to upset conditions as well as excess emissions as defined above lasting less than
four hours.
Excess Emissions
1. If a source is required to report excess emissions under NSPS(15A NCAC 02D.0524),NESHAPS(15A NCAC 02D
.1110 or.1111),or the operating permit provides for periodic(e.g.,quarterly)reporting of excess emissions,reporting
shall be performed as prescribed therein.
2. If the source is not subject to NSPS(15A NCAC 02D.0524),NESHAPS(15A NCAC 02D.1110 or.1111),or these
rules do NOT define"excess emissions,"the Permittee shall report excess emissions in accordance with 15A NCAC
02D.0535 as follows:
a. Pursuant to 15A NCAC 02D.0535,if excess emissions last for more than four hours resulting from a malfunction,
a breakdown of process or control equipment,or any other abnormal condition,the owner or operator shall:
i. notify the Regional Supervisor or Director of any such occurrence by 9:00 a.m.Eastern Time of the Division's
next business day of becoming aware of the occurrence and provide:
• name and location of the facility;
• nature and cause of the malfunction or breakdown;
• time when the malfunction or breakdown is first observed;
• expected duration;and
• estimated rate of emissions;
ii. notify the Regional Supervisor or Director immediately when corrective measures have been accomplished;
and
iii. submit to the Regional Supervisor or Director within 15 days a written report as described in 15A NCAC 02D
.0535(f)(3).
Permit Deviations
3. Pursuant to 15A NCAC 02Q.0508(f)(2),the Permittee shall report deviations from permit requirements(terms and
conditions)as follows:
a. Notify the Regional Supervisor or Director of all other deviations from permit requirements not covered under
15A NCAC 02D.0535 quarterly. A written report to the Regional Supervisor shall include the probable cause of
such deviation and any corrective actions or preventative actions taken. The responsible official shall certify all
deviations from permit requirements.
I.B Other Requirements under 15A NCAC 02D.0535
The Permittee shall comply with all other applicable requirements contained in 15A NCAC 02D.0535,including 15A
NCAC 02D.0535(c)as follows:
1. Any excess emissions that do not occur during start-up and shut-down shall be considered a violation of the appropriate
rule unless the owner or operator of the sources demonstrates to the Director,that the excess emissions are a result of a
malfunction. The Director shall consider,along with any other pertinent information,the criteria contained in 15A
NCAC 02D.0535(c)(1)through(7).
2. 15A NCAC 02D.0535(g). Excess emissions during start-up and shut-down shall be considered a violation of the
appropriate rule if the owner or operator cannot demonstrate that excess emissions are unavoidable.
J. Emer encv Provisions[40 CFR 70.6(g)]
The Permittee shall be subject to the following provisions with respect to emergencies:
1. An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the
facility,including acts of God,which situation requires immediate corrective action to restore normal operation,and
that causes the facility to exceed a technology-based emission limitation under the permit,due to unavoidable increases
in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by
improperly designed equipment,lack of preventive maintenance,careless or improper operation,or operator error.

Air Permit 03449T52
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2. An emergency constitutes an affirmative defense to an action brought for noncompliance with such technology-based
emission limitations if the conditions specified in 3.below are met.
3. The affirmative defense of emergency shall be demonstrated through properly signed contemporaneous operating logs
or other relevant evidence that include information as follows:
a. an emergency occurred and the Permittee can identify the cause(s)of the emergency;
b. the permitted facility was at the time being properly operated;
c. during the period of the emergency the Permittee took all reasonable steps to minimize levels of emissions that
exceeded the standards or other requirements in the permit;and
d. the Permittee submitted notice of the emergency to the DAQ within two working days of the time when emission
limitations were exceeded due to the emergency. This notice must contain a description of the emergency,steps
taken to mitigate emissions,and corrective actions taken.
4. In any enforcement proceeding,the Permittee seeking to establish the occurrence of an emergency has the burden of
proof.
5. This provision is in addition to any emergency or upset provision contained in any applicable requirement specified
elsewhere herein.
K. Permit Renewal[15A NCAC 02Q.0508(e)and 02Q.0513(b)]
This 15A NCAC 02Q.0500 permit is issued for a fixed term not to exceed five years and shall expire at the end of its
term. Permit expiration terminates the facility's right to operate unless a complete 15A NCAC 02Q.0500 renewal
application is submitted at least six months before the date of permit expiration. If the Permittee or applicant has complied
with 15A NCAC 02Q.0512(b)(1),this 15A NCAC 02Q.0500 permit shall not expire until the renewal permit has been
issued or denied. Permit expiration under 15A NCAC 02Q.0400 terminates the facility's right to operate unless a complete
15A NCAC 02Q.0400 renewal application is submitted at least six months before the date of permit expiration for facilities
subject to 15A NCAC 02Q.0400 requirements. In either of these events,all terms and conditions of these permits shall
remain in effect until the renewal permits have been issued or denied.
L. Need to Halt or Reduce Activity Not a Defense[15A NCAC 02Q.0508(i)(4)]
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or reduce the
permitted activity in order to maintain compliance with the conditions of this permit.
M. Dui to Provide Information(submittal of information) [15A NCAC 02Q.0508(i)(9)]
1. The Permittee shall furnish to the DAQ,in a timely manner,any reasonable information that the Director may request
in writing to determine whether cause exists for modifying,revoking and reissuing,or terminating the permit or to
determine compliance with the permit.
2. The Permittee shall furnish the DAQ copies of records required to be kept by the permit when such copies are
requested by the Director.For information claimed to be confidential,the Permittee may furnish such records directly
to the EPA upon request along with a claim of confidentiality.
N. Duty to Supplement[15A NCAC 02Q.0507(f)]
The Permittee,upon becoming aware that any relevant facts were omitted or incorrect information was submitted in the
permit application,shall promptly submit such supplementary facts or corrected information to the DAQ. The Permittee
shall also provide additional information as necessary to address any requirement that becomes applicable to the facility
after the date a complete permit application was submitted but prior to the release of the draft permit.
O: Retention of Records[15A NCAC 02Q.0508(f)and 02Q.0508(1)]
The Permittee shall retain records of all required monitoring data and supporting information for a period of at least five
years from the date of the monitoring sample,measurement,report,or application. Supporting information includes all
calibration and maintenance records and all original strip-chart recordings for continuous monitoring information,and
copies of all reports required by the permit. These records shall be maintained in a form suitable and readily available for
expeditious inspection and review. Any records required by the conditions of this permit shall be kept on site and made
available to DAQ personnel for inspection upon request.
P. Compliance Certification[15A NCAC 02Q.0508(n)]
The Permittee shall submit to the DAQ and the EPA(Air and EPCRA Enforcement Branch,EPA,Region 4,61 Forsyth
Street SW,Atlanta,GA 30303)postmarked on or before March 1 a compliance certification(for the preceding calendar
year)by a responsible official with all federally-enforceable terms and conditions in the permit,including emissions
limitations,standards,or work practices. It shall be the responsibility of the current owner to submit a compliance
certification for the entire year regardless of who owned the facility during the year. The compliance certification shall

Air Permit 03449T52
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comply with additional requirements as may be specified under Sections 114(a)(3)or 504(b)of the Federal Clean Air Act.
The compliance certification shall specify:
1. the identification of each term or condition of the permit that is the basis of the certification;
2. the compliance status(with the terms and conditions of the permit for the period covered by the certification);
3. whether compliance was continuous or intermittent;and
4. the method(s)used for determining the compliance status of the source during the certification period.
Q. Certification by Responsible Official[15A NCAC 02Q.0520]
A responsible official shall certify the truth,accuracy,and completeness of any application form,report,or compliance
certification required by this permit. All certifications shall state that based on information and belief formed after
reasonable inquiry,the statements and information in the document are true,accurate,and complete.
R. Permit Shield for APRlicable R uirements[15A NCAC 02Q.0512]
1. Compliance with the terms and conditions of this permit shall be deemed compliance with applicable requirements,
where such applicable requirements are included and specifically identified in the permit as of the date of permit
issuance.
2. A permit shield shall not alter or affect:
a. the power of the Commission,Secretary of the Department,or Governor under NCGS 143-215.3(a)(12),or EPA
under Section 303 of the Federal Clean Air Act;
b. the liability of an owner or operator of a facility for any violation of applicable requirements prior to the effective
date of the permit or at the time of permit issuance;
c. the applicable requirements under Title IV;or
d. the ability of the Director or the EPA under Section 114 of the Federal Clean Air Act to obtain information to
determine compliance of the facility with its permit.
3. A permit shield does not apply to any change made at a facility that does not require a permit or permit revision made
under 15A NCAC 02Q.0523.
4. A permit shield does not extend to minor permit modifications made under 15A NCAC 02Q.0515.
S. TerminationModificatio and Revocation of the Permit[15A NCAC 02Q.0519]
The Director may terminate,modify,or revoke and reissue this permit if:
1. the information contained in the application or presented in support thereof is determined to be incorrect;
2. the conditions under which the permit or permit renewal was granted have changed;
3. violations of conditions contained in the permit have occurred;
4. the EPA requests that the permit be revoked under 40 CFR 70.7(g)or 70.8(d);or
5. the Director fmds that termination,modification,or revocation and reissuance of the permit is necessary to carry out the
purpose of NCGS Chapter 143,Article 21B.
T. Insignificant Activities[15A NCAC 02Q.0503]
Because an emission source or activity is insignificant does not mean that the emission source or activity is exempted from
any applicable requirement or that the owner or operator of the source is exempted from demonstrating compliance with
any applicable requirement. The Permttee shall have available at the facility at all times and made available to an
authorized representative upon request,documentation,including calculations,if necessary,to demonstrate that an emission
source or activity is insignificant.
U. Property Rights[15A NCAC 02Q.0508(i)(8)]
This permit does not convey any property rights in either real or personal property or any exclusive privileges.
V. Inspection and Entry[15A NCAC 02Q.0508(1)and NCGS 143-215.3(a)(2)]
1. Upon presentation of credentials and other documents as may be required by law,the Permittee shall allow the DAQ,
or an authorized representative,to perform the following:
a. enter the Permittee's premises where the permitted facility is located or emissions-related activity is conducted,or
where records are kept under the conditions of the permit;
b. have access to and copy,at reasonable times,any records that are required to be kept under the conditions of the
permit;
c. inspect at reasonable times and using reasonable safety practices any source,equipment(including monitoring and
air pollution control equipment),practices,or operations regulated or required under the permit;and
d. sample or monitor substances or parameters,using reasonable safety practices,for the purpose of assuring
compliance with the permit or applicable requirements at reasonable times.

Air Permit 03449T52
Page 60
Nothing in this condition shall limit the ability of the EPA to inspect or enter the premises of the Permittee under
Section 114 or other provisions of the Federal Clean Air Act.
2. No person shall refuse entry or access to any authorized representative of the DAQ who requests entry for purposes of
inspection,and who presents appropriate credentials,nor shall any person obstruct,hamper,or interfere with any such
authorized representative while in the process of carrying out his official duties. Refusal of entry or access may
constitute grounds for permit revocation and assessment of civil penalties.
W. Annual Fee Payment[15A NCAC 02Q.0508(i)(10)]
1. The Permittee shall pay all fees in accordance with 15A NCAC 02Q.0200.
2. Payment of fees may be by check or money order made payable to the N.C.Department of Environmental Quality.
Annual permit fee payments shall refer to the permit number.
3. If,within 30 days after being billed,the Permittee fails to pay an annual fee,the Director may initiate action to
terminate the permit under 15A NCAC 02Q.0519.
X. Annual Emission Inventor► Requirements[15A NCAC 02Q.0207]
The Permittee shall report by June 30 of each year the actual emissions of each air pollutant listed in 15A NCAC 02Q
.0207(a)from each emission source within the facility during the previous calendar year. The report shall be in or on such
form as may be established by the Director. The accuracy of the report shall be certified by a responsible official of the
facility.
Y. Confidential Information[15A NCAC 02Q.0107 and 02Q.0508(i)(9)]
Whenever the Permittee submits information under a claim of confidentiality pursuant to 15A NCAC 02Q.0107,the
Permittee may also submit a copy of all such information and claim directly to the EPA upon request. All requests for
confidentiality must be in accordance with 15A NCAC 02Q.0107.
Z. Construction and Operation Permits[15A NCAC 02Q.0100 and.0300]
A construction and operating permit shall be obtained by the Permittee for any proposed new or modified facility or
emission source which is not exempted from having a permit prior to the beginning of construction or modification,in
accordance with all applicable provisions of 15A NCAC 02Q.0100 and.0300.
AA. Standard Application Form and Required Information[15A NCAC 02Q.0505 and.0507]
The Permittee shall submit applications and required information in accordance with the provisions of 15A NCAC 02Q
.0505 and.0507.
BB. Financial Responsibility and Compliance History [15A NCAC 02Q.0507(d)(4)]
The DAQ may require an applicant to submit a statement of financial qualifications and/or a statement of substantial
compliance history.
CC. Refrigerant Requirements fStratoWheric Ozone and Climate Protection [15A NCAC 02Q.0501(e)]
1. If the Permittee has appliances or refrigeration equipment,including air conditioning equipment,which use Class I or H
ozone-depleting substances such as chlorofluorocarbons and hydrochlorofluorocarbons listed as refrigerants in 40 CFR
Part 82 Subpart A Appendices A and B,the Permittee shall service,repair,and maintain such equipment according to
the work practices,personnel certification requirements,and certified recycling and recovery equipment specified in 40
CFR Part 82 Subpart F.
2. The Permittee shall not knowingly vent or otherwise release any Class I or H substance into the environment during the
repair,servicing,maintenance,or disposal of any such device except as provided in 40 CFR Part 82 Subpart F.
3. The Permittee shall comply with all reporting and recordkeeping requirements of 40 CFR 82.166. Reports shall be
submitted to the EPA or its designee as required.
DD. Prevention of Accidental Releases-Section 112 r [15A NCAC 02Q.0508(h)]
If the Permittee is required to develop and register a Risk Management Plan with EPA pursuant to Section 112(r)of the
Clean Air Act,then the Permittee is required to register this plan in accordance with 40 CFR Part 68.
EE. Prevention of Accidental Releases General Duty Clause-Section 112(r)(1,—FEDERALLY-ENFORCEABLE ONLY
Although a risk management plan may not be required,if the Permittee produces,processes,handles,or stores any amount
of a listed hazardous substance,the Permittee has a general duty to take such steps as are necessary to prevent the accidental
release of such substance and to minimize the consequences of any release.

Air Permit 03449T52
Page 61
FF. Title IV Allowances[15A NCAC 02Q.0508(i)(1)]
This permit does not limit the number of Title IV allowances held by the Permittee,but the Permittee may not use
allowances as a defense to noncompliance with any other applicable requirement. The Permittee's emissions may not
exceed any allowances that the facility lawfully holds under Title IV of the Federal Clean Air Act.
GG. Air Pollution Eme encv Episode[15A NCAC 02D.0300]
Should the Director of the DAQ declare an Air Pollution Emergency Episode,the Permittee will be required to operate in
accordance with the Permittee's previously approved Emission Reduction Plan or,in the absence of an approved plan,with
the appropriate requirements specified in 15A NCAC 02D.0300.
HH. Re,2istration of Air Pollution Sources[15A NCAC 02D.0202]
The Director of the DAQ may require the Permittee to register a source of air pollution. If the Permittee is required to
register a source of air pollution,this registration and required information will be in accordance with 15A NCAC 02D
.0202(b).
II. Ambient Air Quaffiv Standards[15A NCAC 02D.0501(c)]
In addition to any control or manner of operation necessary to meet emission standards specified in this permit,any source
of air pollution shall be operated with such control or in such manner that the source shall not cause the ambient air quality
standards in 15A NCAC 02D.0400 to be exceeded at any point beyond the premises on which the source is located. When
controls more stringent than named in the applicable emission standards in this permit are required to prevent violation of
the ambient air quality standards or are required to create an offset,the permit shall contain a condition requiring these
controls.
JJ. General Emissions Testing and Reporting Reg uirements[15A NCAC 02Q.0508(i)(16)]
Emission compliance testing shall be by the procedures of Section.2600,except as may be otherwise required in Rules
.0524, .0912,.1110,.1111,or.1415 of Subchapter 02D.If emissions testing is required by this permit or the DAQ or if the
Permittee submits emissions testing to the DAQ to demonstrate compliance,the Permittee shall perform such testing in
accordance with 15A NCAC 02D.2600 and follow the procedures outlined below:
1. The owner or operator of the source shall arrange for air emission testing protocols to be provided to the Director
prior to air pollution testing.Testing protocols are not required to be pre-approved by the Director prior to air
pollution testing.The Director shall review air emission testing protocols for pre-approval prior to testing if
requested by the owner or operator at least 45 days before conducting the test.
2. Any person proposing to conduct an emissions test to demonstrate compliance with an applicable standard shall
notify the Director at least 15 days before beginning the test so that the Director may at his option observe the test.
3. The owner or operator of the source shall arrange for controlling and measuring the production rates during the
period of air testing.The owner or operator of the source shall ensure that the equipment or process being tested is
operated at the production rate that best fulfills the purpose of the test.The individual conducting the emission test
shall describe the procedures used to obtain accurate process data and include in the test report the average
production rates determined during each testing period.
4. Two copies of the final air emission test report shall be submitted to the Director not later than 30 days after sample
collection unless otherwise specified in the specific conditions. The owner or operator may request an extension to
submit the final test report.The Director shall approve an extension request if he finds that the extension request is a
result of actions beyond the control of the owner or operator.
a. The Director shall make the final determination regarding any testing procedure deviation and the validity of the
compliance test.The Director may:
i. Allow deviations from a method specified under a rule in this Section if the owner or operator of the source
being tested demonstrates to the satisfaction of the Director that the specified method is inappropriate for
the source being tested.
ii. Prescribe alternate test procedures on an individual basis when he finds that the alternative method is
necessary to secure more reliable test data.
iii. Prescribe or approve methods on an individual basis for sources or pollutants for which no test method is
specified in this Section if the methods can be demonstrated to determine compliance of permitted emission
sources or pollutants.
b. The Director may authorize the Division of Air Quality to conduct independent tests of any source subject to a
rule in this Subchapter to determine the compliance status of that source or to verify any test data submitted
relating to that source.Any test conducted by the Division of Air Quality using the appropriate testing
procedures described in Section 02D.2600 has precedence over all other tests.

Air Permit 03449T52
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KK. Reopening for Cause[15A NCAC 02Q.0517]
1. A permit shall be reopened and revised under the following circumstances:
a. additional applicable requirements become applicable to a facility with remaining permit term of three or more
yam;
b. additional requirements(including excess emission requirements)become applicable to a source covered by Title
IV;
c. the Director or EPA finds that the permit contains a material mistake or that inaccurate statements were made in
establishing the emissions standards or other terms or conditions of the permit;or
d. the Director or EPA determines that the permit must be revised or revoked to assure compliance with the
applicable requirements.
2. Any permit reopening shall be completed or a revised permit issued within 18 months after the applicable requirement
is promulgated. No reopening is required if the effective date of the requirement is after the expiration of the permit
term unless the term of the permit was extended pursuant to 15A NCAC 02Q.0513(c).
3. Except for the state-enforceable only portion of the permit,the procedures set out in 15A NCAC 02Q.0507,.0521,or
.0522 shall be followed to reissue the permit. If the State-enforceable only portion of the permit is reopened,the
procedures in 15A NCAC 02Q.0300 shall be followed. The proceedings shall affect only those parts of the permit for
which cause to reopen exists.
4. The Director shall notify the Permittee at least 60 days in advance of the date that the permit is to be reopened,except
in cases of imminent threat to public health or safety the notification period may be less than 60 days.
5. Within 90 days,or 180 days if the EPA extends the response period,after receiving notification from the EPA that a
permit needs to be terminated,modified,or revoked and reissued,the Director shall send to the EPA a proposed
determination of termination,modification,or revocation and reissuance,as appropriate.
LL. Reporting Requirements for Non-Operating Equipment[15A NCAC 02Q.0508(i)(16)]
The Permittee shall maintain a record of operation for permitted equipment noting whenever the equipment is taken from
and placed into operation. When permitted equipment is not in operation,the requirements for testing,monitoring,and
recordkeeping are suspended until operation resumes.
MM.Fu itive Dust Control ReQ uirement[15A NCAC 02D.0540]
As required by 15A NCAC 02D.0540"Particulates from Fugitive Dust Emission Sources,"the Permittee shall not cause or
allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the
property boundary.If substantive complaints or excessive fugitive dust emissions from the facility are observed beyond the
property boundaries for six minutes in any one hour(using Reference Method 22 in 40 CFR,Appendix A),the owner or
operator may be required to submit a fugitive dust plan as described in 02D.0540(f).
"Fugitive dust emissions"means particulate matter from process operations that does not pass through a process stack or
vent and that is generated within plant property boundaries from activities such as:unloading and loading areas,process
areas,stockpiles,stock pile working,plant parking lots,and plant roads(including access roads and haul roads).
NN.Specific Permit Modifications[15A NCAC 02Q.0501 and.0523]
1. For modifications made pursuant to 15A NCAC 02Q.0501(c)(2),the Permittee shall file a Title V Air Quality Permit
Application for the air emission source(s)and associated air pollution control device(s)on or before 12 months after
commencing operation.
2. For modifications made pursuant to 15A NCAC 02Q.0501(d)(2),the Permittee shall not begin operation of the air
emission source(s)and associated air pollution control device(s)until a Title V Air Quality Permit Application is
filed and a construction and operation permit following the procedures of Section.0500(except for Rule.0504 of
this Section)is obtained.
3. For modifications made pursuant to 502(b)(10),in accordance with 15A NCAC 02Q.0523(a)(1)(C),the Permittee
shall notify the Director and EPA(EPA-Air Planning Branch,61 Forsyth Street SW,Atlanta,GA 30303)in writing
at least seven days before the change is made. The written notification shall include:
a. a description of the change at the facility;
b. the date on which the change will occur;
C. any change in emissions;and
d. any permit term or condition that is no longer applicable as a result of the change.
In addition to this notification requirement,with the next significant modification or Air Quality Permit renewal,the
Permittee shall submit a page"ES"of the application forms signed by the responsible official verifying that the

Air Permit 03449T52
Page 63
application for the 502(b)(10)change/modification,is true,accurate,and complete. Further note that modifications
made pursuant to 502(b)(10)do not relieve the Permittee from satisfying preconstruction requirements.
00. Third Party Participation and EPA Review[15A NCAC 02Q.0521,.0522 and.0525(7)]
For permits modifications subject to 45-day review by the federal Environmental Protection Agency (EPA),EPA's
decision to not object to the proposed permit is considered final and binding on the EPA and absent a third party petition,
the failure to object is the end of EPA's decision-making process with respect to the revisions to the permit.The time period
available to submit a public petition pursuant to 15A NCAC 02Q.0518 begins at the end of the 45-day EPA review period.

Air Permit 03449T52
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ATTACHMENT A
List of Acronyms
AOS Alternative Operating Scenario
BACT Best Available Control Technology
Btu British thermal unit
CAA Clean Air Act
CAIR Clean Air Interstate Rule
CEM Continuous Emission Monitor
CFR Code of Federal Regulations
DAQ Division of Air Quality
DEQ Department of Environmental Quality
EMC Environmental Management Commission
EPA Environmental Protection Agency
FR Federal Register
GACT Generally Available Control Technology
HAP Hazardous Air Pollutant
MACT Maximum Achievable Control Technology
NAA Non-Attainment Area
NCAC North Carolina Administrative Code
NCGS North Carolina General Statutes
NESHAP National Emission Standards for Hazardous Air Pollutants
NOx Nitrogen Oxides
NSPS New Source Performance Standard
OAH Office of Administrative Hearings
PM Particulate Matter
PM10 Particulate Matter with Nominal Aerodynamic Diameter of 10 Micrometers or Less
POS Primary Operating Scenario
PSD Prevention of Significant Deterioration
RACT Reasonably Available Control Technology
SIC Standard Industrial Classification
SIP State Implementation Plan
SOa Sulfur Dioxide
tpy Tons Per Year
VOC Volatile Organic Compound

ATTACHMENT B
RCDME Request Letter dated September 26,2019

arauco
985 Corinth Road
Moncure,North Carolina 27559
Tel:[phone]
Toll Free:855-427-2826
Fax:[phone]
Certified Mail 7018 2290 00014576 3566 September 26,2019
Return Receipt Requested
William Willets t Received
NCDEQ—Division of Air Quality
217 West Jones Street SEP 3 A M
1641 Mail Service Center
Raleigh, NC 27699-1641 Air P"ennits Section
Subject: MACT DDDD Monitoring Permit Application Amendment
Facility ID No.1900015/Permit No.03449T51
Arauco North America, Inc.
Moncure,Chatham County, North Carolina
Dear Mr.Willets:
Arauco North America, Inc.(Arauco)Is submitting this application addendum to modify the tune-up
frequency for ES-18, 19,and 20, remove section 2.1.G language pertaining to the EVAP-1,satisfy the
part 2 application required for a significant modification,and incorporate a routine control device
maintenance exemption for CD-18.This application is a modification to the permit application submitted
August 14,2018 which included the necessary fees.
Arauco submitted permit application 1900015.18A June 2018 and received permit 03449T50 November
21,2018.Within this permit application was the request to replace the natural gas burners ES-18, 19,
and 20 at MDF from 26 to 30.4 MMBtu/hr units;the burners were replaced,and startup occurred March
1, 2019.When the burners were replaced,the new units operate with an oxygen trim system
(Attachment A).Arauco is submitting this modification to have the tune-up frequency and language in
Section 2.1.D.5 changed from annual to every five years according to the regulations under 63.7540(12),
a unit that has a continuous oxygen trim system.
Arauco submitted a letter to DEQ stating the emission source EVAPP-1 was no longer in operation on July
13,2018(Attachment B).As of October 2018,the evaporator was no longer located on Arauco's site.
Arauco is submitting this permit application to have all recordkeeping and reporting requirements and
any language associated with EVAP-1 in Section 2.1.G be removed from the Title V air quality permit.
Arauco is submitting this permit application to satisfy the requirements of submitting a permit
application on or before 12 months after commencing operation of equipment listed as 15A NCAC 02Q
.0501(b)(2). In application 1900015.15A(Attachment C),Arauco proposes several projects that will
increase the overall throughput capacity of the facility including:replacing the natural gas burners,
introducing a chip steaming system,implementing a steam wand, upgrades to the mat scalping system,
improvements to the press outfeed,and upgrades to the saw system.Since the 1900015.18A application
was approved,Arauco has implemented the natural gas burners,chip steaming system,steam wand,

and mat scalping system as originally described in the application.The press outfeed and finishing saw
upgrades will be implemented as described in the application when time and resources allow for project
completion.
The biofilter(CD-18)is now installed and commissioned and Arauco would like to request Routine
Control Device Maintenance exemptions per 40 CFR 63.2251 for two activities related to maintaining
the biofilter: 1)replacing,unplugging,or repairing spray nozzles over the media beds and 2)replacing or
repairing media in the biofilter.
Nozzle Maintenance
Arauco has found through limited operation that the nozzles inside the device are critical to maintaining
sizable aerobic bacteria colonies for the efficient destruction of formaldehyde. Arauco has also found
that it takes multiple days to cool the biofilter to a safe temperature because Arauco operates the
biofilter in a thermophilic temperature range(140-150°F). A typical shutdown of the Moncure
fiberboard plant for regular maintenance activities is only 12 hours and the biofilter internal
temperature due to the insulation of the concrete can still be as high as 105"F after shutdown for 12
hours. This high temperature makes work inside the unit extremely strenuous and dangerous for
operators and maintenance personnel.Arauco expects to only conduct this activity at most twice per
year based upon qualitative evaluation of spray patterns inside the biofilter appearing plugged or
decreases in flow rates from the water pumps in the biofilter.
Media Replacement
Arauco has not operated the new biofilter long enough to replace media but has found through
experience with other biofllters that every 5 years,the structured media begins to collapse. For similar
heat exposure reasons as mentioned above and due to potentially unpredictable catastrophic failure of
media,Arauco is requesting this activity be a permissible routine control device maintenance
exemption.
Emissions Minimization
Arauco plans to minimize operations by limiting production to nominal capacities during periods of
routine control device maintenance exemption. During construction of the biofilter,Arauco
demonstrated compliance with the North Carolina Air Toxics standard NCAC 2D.1100 for formaldehyde
while bypassing emissions from its original dryer stacks so Arauco expects no significant offsite impacts
related to formaldehyde while conducting routine control device maintenance.
if you have any questions about the requested changes,please contact Yvonne Couts,Moncure
Environmental Manager,919-545-5848 and/or [e-mail].
Sincerely,

) 0 mtL•
Jeff McMillian
Plant Manager

ATTACHMENT C
Special Order of Consent 2019-001

BEFORE THE NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
STATE OF NORTH CAROLINA )
COUNTY OF CHATHAM }
}
IN THE MATTER OF: ) SPECIAL ORDER BY CONSENT
ARAUCO NORTH AMERICA, INC. ) SOC 2019-001
MONCURE MANUFACTURING SITE ---
[FACILITY ID 1900015]
This SPECIAL ORDER BY CONSENT(hereinafter referred to as the"ORDER") is
made and entered into pursuant to North Carolina General Statute 143-215.110 by and between
ARAUCO North America, Inc. (hereafter referred to as"ARAUCO" or"COMPANY")and the
ENVIRONMENTAL MANAGEMENT COMMISSION, an agency of the State of North
Carolina(hereinafter referred to as the "COMMISSION").
WITNESSETH:
I. The COMMISSION and ARAUCO hereby stipulate and agree to the following:
A. ARAUCO North America,Inc. ("ARAUCO"or"COMPANY")operates a
manufacturing site (hereafter referred to collectively as the"FACILITY")that
includes a Medium Density Fiberboard Manufacturing Facility("MDF Facility')
in Moncure, Chatham County,North Carolina. The FACILITY currently operates
under Air Permit 03449T51 ("PERMIT")which was issued by the North Carolina
Division of Air Quality("DAQ") on March 6,2019.
B. The FACILITY is an affected source subject to requirements under 40 CFR Part
63 Subpart DDDD("Subpart DDDD"or"MALT")to control hazardous air
pollutants ("HAPs")and subject to certain requirements under the Prevention of

Special Order by Consent
ARAUCO North America, Inc.
Significant Deterioration("PSD")program. The MACT requirements for the
FACILITY are summarized in Section 2.2.A.1. of the PERMIT, and Section
2.2.B.2. of the PERMIT outlined the Best Achievable Control Technology
("BACT")under the PSD program. These requirements include a condition for
50%Destruction/Removal Efficiency("DRE")for Wood Products Protocol 1
Volatile Organic Compounds("WPP1 VOC")from the MDF Facility. Section
2.2.B.2.b. requires the COMPANY to demonstrate compliance with the 50%DRE
for WPP 1 VOC from the MPF Facility by May 20,2019. The COMPANY did
not complete the required testing by May 20,2019.
C. Air pollutants from the MDF FACILITY are controlled by a series of emission
control devices including a Biofilter(Permit ID No. CD-18) (hereafter referred to
as the`BIOFILTER"). The BIOFILTER was installed over the past three years
as prescribed under the terms of a prior Special Order by Consent between the
COMMISSION and ARAUCO(SOC 2015-02). The BIOFILTER replaced a prior
control device,which was a Photo-catalytic Gas Treatment (PGT)system
intended to oxidize and thereby destroy volatile organic emissions, including the
HAPs formaldehyde and methanol.
D. ARAUCO has experienced significant operational issues with the BIOFILTER
since startup in February 2018. In particular,the BIOFILTER has had to be
restarted on several occasions to assure sufficient biological growth for proper
operation. Startups have required adjustment of several factors to achieve
sufficient biological growth.The adjustments included eliminating urea injection
for 30 days under a Deferral of Enforcement issued by DAQ, slowly increasing
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Special Order by Consent
ARAUCO North America, Inc.
fan speed to increase emission loading of the BIOFILTER,and adding bacteria
from several different sources in order to diversify the biological population.
E. More recently,the COMPANY has discovered substantial damage within the
BIOFILTER including serious deterioration of the concrete structure. Continued
operation of the BIOFILTER without remedying the damage and deterioration
could result in failure of the BIOFILTER in addition to reduced pollutant control
and ultimately total degradation of the unit.
F. As a result of the operational problems with the BIOFILTER,the FACILITY has
documented lower than expected control efficiencies for methanol, a primary
WPP1 VOC and HAP associated with the MDF Facility operations. Although the
BIOFILTER has met the initial performance demonstration requirements of
MACT Subpart DDDD based on its control of formaldehyde emissions,the
COMPANY does not believe that the BIOFILTER can meet the 50%DRE for
WPP1 VOC BACT requirement under operational conditions to date.
G. To repair and optimize performance of the BIOFILTER will require physical
internal and external modifications. Accomplishing the required work will
necessitate total shutdown of the BIOFILTER. Once the modifications are
completed,a slow ramp up to restart the BIOFILTER will be required in order to
assure improved biological activity and overall system performance. These steps
will require significant time to complete.
H. In addition to the foregoing,the BIOFILTER vendor has raised concerns about
the urea injection system used to reduce nitrogen oxide("NOx") emissions from
the MDF Facility. In particular,the vendor believes that the urea may be
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Special Order by Consent
ARAUCO North America, Inc.
interfering with the operation and performance of the BIOFILTER and that
modification or elimination of the urea injection system may be necessary to
assure proper operation of the BIOFILTER.
I. On March 8, 2019, COMPANY representatives met with DAQ staff from the
Raleigh Regional Office and Raleigh Central Office Technical Services and
Permitting Sections to discuss the destruction efficiency and reliability problems
with the BIOFILTER and the measures necessary to correct them. On May 8,
2019,ARAUCO notified DAQ that the COMPANY had made the decision to
shut down the BIOFILTER on the day of the notification for an indefinite period
of time due to concerns about employee safety, catastrophic equipment failure;
and control device downtime.
J. On June 5, 2019,DAQ issued a Notice of Violation/Notice of Recommendation
for Enforcement("NOV/NRE")to ARAUCO for operation of the MDF Facility
without the BIOFILTER in operation resulting in violations of the FACILITY'S
BACT and MACT PERMIT requirements.
K. On June 28,2019, ARAUCO submitted its response to the June 5,2019
NOV/NRE. The COMPANY documented progress made to date in terms of
working with contractors and consultants to address the documented structural
and performance issues associated with the BIOFILTER. The COMPANY also
provided a proposed schedule of events that would allow the MDF Facility to be
in compliance with all PERMIT requirements subject to this ORDER by August
2020.
L. Given the expected extended period of noncompliance with PERMIT
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Special Order by Consent
ARAUCO North America,Inc.
requirements due to the BIOFILTER being shut down or bypassed while being
repaired and modified,the COMPANY requested to enter into this ORDER with
the COMMISSION.
M. This ORDER authorizes operation of the MDF Facility without operating the
BIOFILTER for the time periods specified herein for the CO TANY to modify,
restart the BIOFILTER, and optimize performance in order to meet the
requirements of the PERMIT.
N. During the period of this ORDER, all pollution control equipment at the
FACILITY,other than the BIOFILTER that is required by the current air permit
shall continue to operate in compliance with applicable requirements.
THEREFORE,the COMMISSION and the COMPANY, desiring to resolve and settle the
compliance issues between them,have agreed to enter into this ORDER with the following terms
and conditions:
II. The COMPANY,desiring to operate in a safe and environmentally sound manner in
accordance with the rules and regulations of the COMMISSION does hereby agree to
perform the following activities:
A. If not already signed by the effective date of this ORDER,the COMPANY shall
sign the necessary contract(s) for remedial work on the DEVICE within 30 days
after execution of this SOC.
B. If not already commenced as of the effective date of this ORDER,the
COMPANY shall commence the remedial work according to the specifications in
the contract(s)no later than 15 days after signing the necessary contract(s).
C. The COMPANY shall complete the remedial work as provided in the contract(s)

Special Order by Consent
ARAUCO North America, Inc.
by December 31,2019.
D. The COMPANY shall submit a test protocol for the BIOFILTER at least 60 days
prior to the compliance test date.
E. The COMPANY shall conduct engineering evaluation, shakedown, and
compliance testing to demonstrate compliance with all applicable PERMIT
requirements and submit a test report within 180 days after completion of the
remedial work.
F. The COMPANY shall submit no later than 14 days after the deadline for
completing each milestone required in Paragraph II written certification to the Air
Quality Regional Supervisor, Raleigh Regional Office,Division of Air Quality,
when such milestone has been performed.
III. The COMPANY agrees to pay the following civil penalties:
A. The COMPANY agrees to pay the COMMISSION a civil penalty in the mount of
$22,750. This amount shall be due and payable within 30 days of the effective date
of this ORDER.
B. The COMPANY agrees to pay the COMMISSION stipulated penalties in the
amounts of $7,500 per month for the period of time from shutdown of the
BIOFILTER until a test report demonstrating compliance with all applicable
PERMIT requirements is submitted to DAQ. The stipulated penalties shall be paid
in two payments. The first payment is due by January 15, 2020 and shall cover all
months the MDF Facility was out of compliance with PERMIT requirements in
calendar year 2019. The second payment is due within 15 days after the date that
the final BIOFILTER test report required by Paragraph II.E. of this ORDER is
submitted to DAQ and will cover all months the MDF Facility was out of
compliance in calendar year 2020. Partial months shall count as whole months
when determining the amount of stipulated penalties to be paid.
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Special.Order by Consent
ARAUCO North America,Inc.
IV. In the event that the COMPANY fails to comply with any deadline as set out in this
ORDER or fails to achieve final compliance with any applicable requirement in this
ORDER,the COMPANY agrees that,unless excused under Paragraph V, the
COMPANY will pay the COMMISSION'according to the following schedule:
Deadlines and Requirements Stipulated Penalties _
Failure to comply with any deadline $500 per day for the first 5 days and
s ecified in Paragraph II $1000 per da thereafter
Stipulated Penalties:
Failure within thirty(30) days of receipt of the Director's written demand to pay the
penalties will be grounds for a collection action,which the Attorney General is hereby
authorized to initiate. By entering this ORDER,the COMPANY waives any and all
defenses and agrees that the sole issues in such action are whether or not thirty(30)days
has elapsed and/or whether or not the COMPANY is excused pursuant to Paragraph V of
this ORDER The COMPANY shall pay all costs, including agency and attorney fees,
associated with collection of a delinquent stipulated penalty.
V. The COMPANY's obligation to comply with the requirements set forth in this ORDER
for which a stipulated penalty may be assessed,may be delayed or excused only to the
extent that noncompliance is caused by circumstances beyond control of the COMPANY,
as determined by the DAQ Director"DIRECTOR". Contractor delays or failure to obtain
funding will not be considered events beyond the COMPANY's control. If any such.
delaying event occurs,the COMPANY shall notify the DAQ in writing within ten(10)
days of encountering or discovering the delaying event,describing in detail the event or
delay,the precise cause(s)of the event or delay,the measure(s)taken and to be taken by
the COMPANY to prevent or minimize the event or delay, and the schedule by which
those measures will be implemented. If the DIRECTOR determines that noncompliance
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Special Order by Consent
ARAUCO North America, Inc.
with this ORDER was caused by circumstances beyond the control of the COMPANY,
the COMMISSION and the COMPANY jointly may stipulate and agree to a written
modification of this ORDER.Any modification shall be subject to the requirements of
15A NCAC 2D .2201 et seq.Extension of any compliance date pursuant to this
Paragraph shall not extend any subsequent deadlines established in the ORDER unless
the subsequent deadline necessarily is dependent upon completion of the earlier deadline.
VI. This ORDER resolves the violation(s)described in Paragraph I of this ORDER. Any
violation of Air Quality Standards by the COMPANY that is not resolved by this
ORDER remains subject to appropriate enforcement action pursuant to N.C.G.S. §§ 143-
215.114A, 143-215.114B and 215.114C.
VII. The COMPANY agrees to waive any rights it may have to seek judicial review to
challenge this ORDER or to seek a stay of enforcement of this ORDER in connection
with any judicial review of the State Implementation Plan. The COMMISSION
acknowledges that this waiver does not prohibit the COMPANY from seeking
modification of this ORDER if any regulatory standards upon which this ORDER is
based are changed subsequent to its execution. In such cases,the COMPANY may
petition that the ORDER be modified to reflect those regulatory changes.
VIII. In the event the COMMISSION or the DAQ find that reports,plans, specifications, or
permit applications required by Paragraph II are in any respect deficient or if additional
information is necessary to comply with the requirements of North Carolina General
Statutes 143-215.107 et seq.,any regulations promulgated thereunder, or any other
applicable laws or regulations,the COMPANY shall be notified by the DAQ as soon as
possible. The COMPANY shall be afforded an opportunity to modify, amend or
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Special Order by Consent
ARgUCO North America, Inc.
supplement its submissions to make such submissions complete and appropriate.
IX. All notices and reports required by this ORDER shall be delivered to:
Ray Stewart,Regional Air Quality Supervisor
N.C. Dept. of Environmental Quality
3800 Barrett Drive
Raleigh,North Carolina 27609
All payments required from the COMPANY by this ORDER shall be delivered to:
Enforcement Group-Payments
NCDEQ-DAQ
1641 Mail Service Center
Raleigh,North Carolina 27699-1641
X. This ORDER constitutes full and final settlement and satisfaction of all matters addressed
herein and any and all claims or prospective claims that the COMMISSION has or may
have for violations of regulations described in Paragraph I hereof,as of the date this
ORDER is approved by the COMMISSION and continuing until this Order expires as
provided in Paragraph XVI. This ORDER shall not affect the COMPANY's obligation to
comply with any Federal, State;or local laws or regulations.
XI. Final approval and entry into this ORDER are subject to the requirements that the
COMMISSION give notice of proposed consent decrees to the public, and that the public
have at least thirty(30)days within which to comment on the ORDER.
X1I. Should any prevision of this ORDER be declared by a court of competent jurisdiction to
be inconsistent with Federal or State law and therefore unenforceable,the remaining
provisions hereof shall remain in full force and effect.
XIII. Except as otherwise set forth herein,this ORDER is not and shall not be interpreted to be
a permit or modification of an existing permit under Federal, State or local law, and shall
not be construed to waive or relieve the COMPANY of its obligations to comply in the
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Special Order by Consent
ARAUCO North America. Inc.
future with any permit.
XIV. In the event of termination of operations and closure of the FACILITY,the COMPANY
shall notify the DIRECTOR in writing, within five (5) business days of the earlier of(i)
the date of any Workers Adjustment and Retraining Notification Act(WARNA)
notification, or(ii) FACILITY closure. Receipt of said notification from the COMPANY
by the DIRECTOR shall terminate any obligations of the COMPANY pursuant to this
ORDER, including those pertaining to stipulated penalties, and this ORDER shall
become null and void in its applicability to the COMPANY. The COMPANY
acknowledges its responsibilities pursuant to this ORDER from the date of final approval
and entry of this ORDER,through the date of receipt by the DIRECTOR of notification
of closure required by this Paragraph.
XV. This ORDER is effective on execution by the Division of Air Quality and shall expire on
December 31,2020,or on the date that the Division of Air Quality notifies ARAUCO in
writing that the test results submitted in accordance with Paragraph II.E. of this ORDER
are acceptable to demonstrate compliance with the applicable PERMIT requirements for
the MDF Facility,whichever date comes first.
This the-7(._day of T , 2019.
ARAUCO O AM ICA,INC. 4LAPPROVED AND ACCEPTED
BY: 1 BY: a
e C oll For the Environmental
Manufacturing Director Management Commission
Moncure,N.C.
DATE:
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