AQ_F_0100237_20180917_CEM_RptRvwLtr

QUAM
ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretary
MICHAEL ABRACZINSKAS
Director
September 17, 2018
Mr. Mark Blalock
General Manager
New South Lumber Company, Inc.—Graham Plant
4408 Mt. Hermon-Rock Creek Road
Graham,North Carolina 27253
SUBJECT: Review of 2018 Semiannual COMS Report, First Half
New South Lumber Company, Inc.—Graham Plant
Graham, Alamance County,North Carolina
Facility ID No. 0100237
Air Permit No. 06740T20
Dear Mr. Blalock:
Thank you for your timely submittal of the subject report, dated July 25, 2018, from New
South Lumber's Graham Plant. The report included an assessment of the continuous opacity
monitoring system (COMS)that operated on Boiler 94 (ID No. B-4) during the first half of
2018. The Division of Air Quality(DAQ)has completed its review of the COMS-related
information in the report and has the following comments:
1. The wood fuel-fired boiler(B-4)was reviewed for compliance with the underlying
opacity standard set forth at NCAC 2D .0524 (40 CFR Part 60, Subpart Dc - Standards of
Performance for Small Industrial-Commercial-Institutional Steam Generating Units)and
Air Permit No. 06740 specific condition 2.1.B. The EER indicated there were no
violations of the applicable standard. Excess emissions from the wood-fired boiler were
attributed to either startup, shutdown, malfunction, or other exempt emissions. These
emissions were reviewed and allowed in accordance with applicable monitoring rules.
2. A review was also conducted for compliance with good operation and maintenance
(O&M)practices pursuant to NCAC 2D .0524 (NSPS Dc, including Subpart A - General
Provisions), 40 CFR 60.11(d), 40 CFR 60.13, and specific condition 2.1.B. When
compared to the total operating time of the boiler, percent excess emissions (%EE)were
reported as 0.2% for the first quarter and 0.1% for the second quarter, whereas percent
monitor downtime(%MD)was reported as 0.2% for the first quarter and 0.0% for the
oaw�M of 5rvtrommn�0.ft
me
North Carolina Department of Environmental Quality I Division of Air Quality
217 West Jones Street 1 1641 Mail Service Center I Raleigh,North Carolina 27699-1641
919.707.8400

Mr. Mark Blalock
September 17, 2018
Page 2
second quarter. The COMS unit appears to indicate the use of good O&M practices for
minimizing emissions since quarterly%EE and %MD were less than 6% for any single
calendar quarter and less than 3% for two consecutive quarters.
3. The first and second quarter audits of the COMS unit were reviewed in accordance with
Procedure 3 of 40 CFR Part 60, Appendix F - Quality Assurance Procedures. The QA
test results for the COMS appear to have met the quarterly specifications.
If you should have any questions,please contact me at [phone] or [e-mail].
Si cerely,
'Alan Drake, Environmental Engineer
Division of Air Quality, NCDEQ
c: Lisa Edwards, DAQ WSRO
Gary Saunders,DAQ RCO
IBEAM Documents, 0100237
Central File, Alamance County