AQ_F_0100237_20190410_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF AIR QUALITY Winston-Salem Regional Office
Cantor Southern Pine-Graham Plant
Inspection Report NC Facility ID 0100237
Date: 04/10/2019 County/FIPS: Alamance/001
Facility Data Permit Data
Canfor Southern Pine -Graham Plant Permit 06740/T21
4408 Mt Hermon - Rock Creek Road Issued 1/18/2019
Graham, NC 27253 Expires 4/30/2023
Lat: 35d 58.8660m Long: 79d 25.0320m Class/Status Title V
SIC: 2421 /Sawmills & Planing Mills General Permit Status Active
NAILS: 321113 /Sawmills Current Permit Application(s)PSD
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Kristie Hill Mark Blalock Kristie Hill MACT Part 63: Subpart DDDD, Subpart ZZZZ
NSPS: Subpart Dc
HR Manager Plant Manager HR Manager
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 04/10/2019
Inspector's Name Jim Hafner
Inspector's Signature: Operating Status Operating
Compliance Code Compliance- inspection
Action Code FCE
Date of Signature: ( . q MTH On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2017 54.59 10,55 92.88 321.14 122,61 44.60 31252.91
2016 48.65 8.59 75.57 307.88 96.98 39.41 29961,57
2015 46.83 8.39 73.83 301.87 58.60 37.93 30246.88
* Highest HAP Emitted in poundo
Five Year Violation History: None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:
Date Test Results Test Methods) Source(s)Tested
10/16/2018 Compliance Method 10, Method 26A,Method 30B,Method 5 B-2, B-3,B-4
Page 1 of 10

PERMITTED SOURCES
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B-2 One wood fuel-fired boiler(28.7 MC-2 Two multicyclones(16 nine-inch diameter tubes
NSPS De; million Btu per hour maximum heat MC-2A and 44 six-inch diameter tubes,respectively)
Case-By-Case MACT' input capacity)
MACT DDDDDZ ESP-2* One electrostatic precipitator
B-3 One wood fuel-fired boiler(28.7 MC-3 Two multicyclones(16 nine-inch diameter tubes
NSPS De; million Btu per hour maximum heat MC-3A and 44 six-inch diameter tubes, respectively)
Case-By-Case MACT' input capacity)
MACT DDDDDZ ESP-3* One electrostatic precipitator
B-4 One wood fuel-fired boiler(57.6 MC-4 Two multicyclones(36 nine-inch diameter tubes
NSPS De; million Btu per hour maximum heat MC-4A and 44 six-inch diameter tubes, respectively)
Case-By-Case MACT' input capacity) ESP-4* One electrostatic precipitator
MACT DDDDD
PM-2 One planer mill C-2 One cyclone(60 inches in diameter)
BH-1 One bagfilter(3,296 square feet of filter area
K-1 through K-6 Six steam heated lumber drying kilns NA NA
MACT DDDD
Debarker One enclosed rough log debarker NA NA
INSIGNIFICANT/EXEMPT SOURCES
Emission Source ID No. Emission Source Description
IGen 1 Propane-fired emergency engine(118 hp)
MACT Subpart ZZZZ
INTRODUCTION
On April 10,2019, Jim Hafner and George Williams,DAQ-WSRO Environmental Engineers, visited Canfor Southern Pine -Graham
Plant in Alamahce County in order to conduct an unannounced compliance inspection. The facility was targeted this year and has a
facility classification of Title V.The facility contact,Kristie Hill,HR Manager,was requested to help facilitate the inspection. Ms.Hill
confirmed that there were no changes to the facility contact information. Ms.Hill had Tim Blalock, Boiler and Kiln Lead, accompany
the inspectors. The facility is a lumber mill that processes pine logs into dimensional lumber. The boilers and kilns onsite operate 24
hours a day, 7 days a week, 50 weeks per year. The saw mill and planer mill operate 12 hours per day, 5 days per week, 50 weeks per
year. The facility schedules routine shutdowns twice a year. The previous compliance inspection was performed on July 20, 2018 by
Maria Aloyo,formerly of DAQ-WSRO. The facility appeared to be operating in compliance with all applicable regulations at that time.
SAFETY
Safety shoes,safety glasses, reflective vest, hard hat and hearing protection are required at the facility. General safety practices should
always be followed.
LATITUDE/LONGITUDE
The latitude and longitude coordinates of the facility were verified and are correctly documented in IBEAM.
APPLICABLE REGULATIONS
The following Title 15A North Carolina Administrative Code(NCAC)air quality regulations apply to Canfor Southern Pine -Graham
Plant:2D.0504,2D.0512,2D.0516,2D.0521,2D.0524(40 CFR 60,Subpart Dc),2D.0535,2D.0540,2D .1100,2D .1109,2D.I I I I
(40 CFR 63, Subparts DDDD,ZZZZ, DDDDD),2D .1806,and 2Q .0711.
Page 2 of 10

DISCUSSION
Cantor Southern Pine - Graham Plant is a lumber mill that processes whole pine logs into dimensional lumber. The logs are initially
debarked and then passed through the saw mill to cut and trim the logs into pieces approximately the size of the final product. From the
saw mill,the cut lumber is dried in the facility's kilns(ID Nos. K-1 through K-6), which are heated by steam provided by three wood-
fired boilers (1 )Nos. B-2 through B-4), After 22 to 24 hours of drying in the kilns,the dry lumber is then processed by the facility's
planer mill (11) No. No. PM-2). The dust from both the sawing operations and the facility's planer mill is burned in one of the wood-
fired boilers(ID Nos. B-2 through B-4). The facility has a fourth wood-fired boiler that has not been operated since 2009. This boiler
was removed from the permit when Air Permit No. 06740T21 was issued on January 18,2019. A permit application was submitted in
February 2019 to replace this boiler with a natural gas-fired boiler. The new boiler will be located in the same physical location as
boiler(B-1).
Pine logs are first debarked in the enclosed debarker unit. Once the logs are debarked,the bark waste is hauled offsite for disposal,and
the debarked logs are sent to the saw mill. Logs are processed by band saws and then further cut by a gang saw into 8 or 9 boards. From
the gang saw,the boards are trimmed and edged. Green wood dust generated in the saw mill and used as fuel in the boilers is conveyed
to three storage silos onsite. The facility collects the wood chips generated in the saw mill and sells it to various industries. The saw
mill operations are enclosed in a building. From the saw mill,the boards are dried in the kilns. Each kiln has 4 firing zones.
Once the boards are dried, they are processed in the planer mill, inspected, and then packaged. The planer unit is enclosed for safety
reasons. The facility has a camera inside of the enclosure to monitor the planer's operations. Emissions from the planer mill are
controlled by a closed loop system consisting of one cyclone(C-2) and one bagfilter(BH-1).
The following operating parameters of the boilers were observed during the inspection:
Emission Source ID No. Operating Temperature CF) Process Rate(lbs/hr Steam) Pressure(psi)
B-2 1419 25,860 128
B-3 1254 16,500 126
B-4 1694 37,000 130
Boiler B-2,a 1995 Hurst boiler and is controlled by two multicyclones(MC-2&MC-2A). To comply with the upcoming boiler MACT
DDDDD, the facility is in the process of installing an electrostatic precipitator(ESP-2). Boiler B-3 is a 1998 Hurst boiler. Emissions
from boiler B-3 are controlled by two multicyclones(MC-3 &MC-3A). An electrostatic precipitator(ESP-3)is being installed on this
boiler as well for compliance with MACT DDDDD, Boiler B-4 has a manufacture date of 2007. Emissions from boiler B-4 are
controlled by two multicyclones (MC-4 & MC-4A) and one electrostatic precipitator(ESP-4). The ESP was observed operating with
an instantaneous opacity of 6.7%. Records of the daily sawdust usage for each boiler is kept in the boiler control room. The daily
records are then given to Ms. Hill to produce the monthly usage records required by the permit.
The propane-fired emergency generator(1Gen 1) was manufactured by Kohler(Model # C-605, serial # 09649) and was not in use at
the time of the inspection. The hour meter read 52.2 hours. The generator is used to supply power to the water pumps servicing the
boilers in the event there is an interruption of power. Operational logs are located at the generator house.
PERMIT CONDITIONS
Section 2.—Specific Limitations and Conditions
Section 2.1 -Emission Source(s)and Control Devices(s)Specific Limitations and Conditions
A. One wood fuel-fired boiler(ID No. B-2)with associated multicyclones(ID Nos. MC-2 and MC-2A)and electrostatic
precipitator(ID No. ESP-2)all in series
One wood fuel-fired boiler(ID No. B-3)with associated multicyclones(ID Nos. MC-3 and MC-3A)and electrostatic
precipitator(ID No. ESP-3)all in series
One wood fuel-fired boiler(ID No. B-4)with associated multicyclones (ID Nos. MC-4 and MC-4A)and electrostatic
precipitator(ID No. ESP-4)ail in series
Page 3 of 10

Condition 2.1.A.1 —This contains the requirements for 2D .0504 which requires the facility to limit the particulate matter emissions
from any wood burning indirect heat exchanger. Boilers(B-2,and B-3)are each limited to 0.45 pounds of particulate matter emissions
per million Btu heat input. Boiler B-4 is not subject to 02D.0504 because it is subject to the PM emission standard under NSPS Subpart
De as referenced in 15A NCAC 02D .0524. To comply with this regulation, the two boilers must be controlled by four multicyclones
(MC-2, MC-2A, MC-3, and MC-3A)as shown on the permitted equipment list. The exterior of each multicyclone, at minimum, must
be visually inspected monthly for leaks from the ductwork and material collection units. Additionally, each multicyclone must be
internally inspected once a year to check the unit's structural integrity. All maintenance and inspection activities are to be recorded in
a logbook.A semiannual report summarizing all monitoring and recordkeeping activities must be postmarked no later than 30 days after
each calendar semiannual period.
Monthly external visual inspection records from July 2018 through April 2019 were provided to the inspectors and no leaks were
detected. The records appeared to be sufficient to demonstrate compliance. The most current annual internal inspection done on each
cyclone was on August 13,2018. The previous inspections were done on July 5,2017. Ms.Hill was contacted to make sure that annual
internal inspections are done within 12 months of the previous one as required. The required semiannual reports were received on July
30, 2018 and February 1, 2019 (postmarked January 29, 2019). Each report indicated compliance. It appears that the facility is in
compliance with 2D .0504.
Condition 2.1.A.2 — This contains the requirements for 2D .0516 which requires the facility to limit sulfur dioxide emissions from
combustion sources,such as the three boilers. Based on the permit review for T21,written by Charles F. Yirka,the facility demonstrated
compliance with this regulation since the fuel combusted is inherently low enough in sulfur to always be in compliance with this rule.
Condition 2.1.A.3—This contains the requirements for 2D .0521 which requires the facility to control the visible emissions from any
emission source that may be discharged from vents or stacks. Boilers(B-2& B-3) are subject to this regulation. Visible emissions are
not to exceed 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. To demonstrate compliance with this
regulation, visible emissions are to be performed once daily to determine if emissions are above normal. In the event emissions are
above normal, the facility must take appropriate actions to correct the above normal emissions as soon as practicable and within the
same monitoring period or demonstrate that the above normal emissions are less than 20%opacity when averaged over 12 minutes using
EPA Method 9. Logs of all the daily observations must be maintained in a logbook. A semiannual report summarizing all observations
must be postmarked no later than 30 days after each calendar year semiannual period.
During the inspection, boilers B-2 and B-3 were observed operating with no visible emissions. During the inspection, daily visible
emission observation records were reviewed, and all indicated that none of the readings were above normal. The required semiannual
observation reports were received on July 30, 2018 and February 1, 2019 (postmarked January 29, 2019). The reports indicated
compliance with the observation requirements. The facility appears to be in compliance with 2D .0521.
Condition 2.1.A.4 — This contains the requirements for 2D .0524 requirements for complying with the New Source Performance
Standards (NSPS)regulations promulgated by the EPA. The three wood-tired boilers (B-2, B-3 & B-4)are subject to 40 CFR Part 60,
Subpart Dc "Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units." Wood-fired boilers
are not subject to a sulfur limit under NSPS Subpart Dc. Also, only boilers with a heat capacity of 30 million Btu per hour or greater
are subject to the PM and opacity standards. Thus, the only requirement for boilers B-2 and B-3 under NSPS Subpart Dc is to record
and maintain records of the amount of fuel combusted during each month.Fuel usage records were provided. In 2018,a total of 18,797
and 12,233 tons of sawdust were used in boiler B-2 and B-3,respectively. Because boiler B-4 is larger than 30 million Btu per hour, it
is subject to the PM and opacity standards under NSPS Subpart De. The initial performance test to demonstrate compliance with the
PM emission standard was conducted on March 18,2008 with a retest conducted on May 9,2008. The results of tests are provided in
the table below. In 2018,a total of 43,313 tons of sawdust were combusted in boiler B-4. The facility appears to be in compliance with
2D .0524 and 40 CFR 60, Subpart Dc.
'test Dime E(Sltntaiit TestResilf"` Tprissiih Cixnit "Corn liance`
03/18/2008 Filterable PM 0.050 Ib/mmBtu 0.03 Ib/mmBtu No
05/09/2008 Filterable PM 0.007 Ib/mmBtu 0.03 Ib/mmBtu Yes
Notes:
• Ib/mmBtu=pound per million Btu ',,
• The March 2008 testing results were approved in a memorandum by Shannon Vogel of the Stationary Source Compliance Branch(SSCB)dated May 29,2008.
• The Ma 2008 testing results were ag2roved in a memorandum by Shannon Vogel of the SSCB dated June 20 2008.
Page 4 of 10

B. One planer mill(ID No. PM-2)with associated cyclone(]D No. C-2) in series with one bagfilter(ID No.BFI-1)
Condition 2.1.B.1—This contains the requirements for 2D.0512 requirements for controlling particulate emissions from miscellaneous
wood product finishing plants. The planer mill (PM-2) is subject to this regulation. To comply with this regulation, the planer mill
must be controlled by one cyclone(C-2)and one bagfilter(BH-1)as shown on the permitted equipment list. The exterior of the cyclone
and bagfilter, at minimum, must be visually inspected monthly for leaks from the ductwork and material collection unit. Additionally,
the cyclone and bagfilter must be internally inspected once a year to check the unit's structural integrity and condition of the filters. All
maintenance and inspection activities are to be recorded in a logbook. A semiannual report summarizing all monitoring and
recordkeeping activities must be postmarked no later than 30 days after each calendar semiannual period.
Monthly external visual inspection records were provided from July 2018 through April 2019. The records appeared to be sufficient to
demonstrate compliance. No issues were noted. The annual internal inspections of the cyclone and bagfilter were done on May 18-19,
2018. The required semiannual reports were received on July 30, 2018 and February 1, 2019 (postmarked January 29, 2019). Each
report indicated compliance. It appears that the facility is in compliance with 2D.0512.
Condition 2.1.B.2—This contains the requirements for 2D .0521 which requires the facility to control the visible emissions from any
emission source that may be discharged from vents or stacks.The planer mill(PM-2)is subject to this regulation. Visible emissions are
not to exceed 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. To demonstrate compliance with this
regulation, visible emissions are to be performed once weekly to determine if emissions are above normal. In the event emissions are
above normal, the facility must take appropriate actions to correct the above normal emissions as soon as practicable and within the
same monitoring period or demonstrate that the above normal emissions are less than 20%opacity when averaged over 12 minutes using
EPA Method 9. Logs of all daily observations must be maintained in a logbook. A semiannual report summarizing all observations
must be postmarked no later than 30 days after each calendar year semiannual period.
During the inspection, the planer mill was operating, and no visible emissions were observed. Weekly visible emission observation
records from July 2018 through April 2019 were provided and all indicated that none of the readings were above normal. The facility
is compliant with the monitoring requirements of this permit condition. The required semiannual observation reports were received by
DAQ-WSRO on July 30, 2018 and February 1, 2019 (postmarked January 29, 2019). The reports indicated compliance with the
observation requirements. The facility appears to be in compliance with 2D .0521.
C. One enclosed rough log debarker(ID No.Debarker)
Condition 2.1.C.1—This contains the requirements for 2D.0512 requirements for controlling particulate emissions from miscellaneous
wood product finishing plants. The enclosed rough log debarker is subject to this regulation. The regulation states that facility must
not cause, allow, or permit PM generated 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 ductwork and properly designed collectors.
Furthermore,the ambient air quality standards may not be exceeded beyond the property line. The debarking operations are located out
in the open on the facility's property. However, the debarker unit itself is enclosed which aids in minimizing PM emissions to the
atmosphere. The facility appears to be in compliance with this regulation.
Condition 2.1.C.2—This contains the requirements for 2D .0521 which requires the facility to control the visible emissions from any
emission source that may be discharged from vents or stacks. The enclosed rough log debarker is subject to this regulation. Visible
emissions are not to exceed 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. The debarker was observed
operating with no visible emissions. The facility appears to be in compliance with this regulation.
Section 2.2- Multiple Emission Source(s)Specific Limitations and Conditions
A. Facility-wide affected sources
Condition 2.2.A.1 —This contains the requirements for 2D .1100 for controlling toxic air pollutants. The facility previously triggered
a toxic review and exceeded the TPER limits for arsenic, acrolein, benzene, beryllium, cadmium, chromium, formaldehyde, nickel,
phenol from the boilers and kilns. The facility submitted an application to emit toxics and has demonstrated compliance via modeling
which was approved on November 17, 2009. However, during permit renewal T18 the toxic demonstration for the arsenic emissions
was deferred at that time since the arsenic AAL was under review by EMC. On February 1-2,2011,boilers B-2 and B-4 were tested to
Page 5 of 10

determine site specific arsenic emission factors. The test results,approved by DAQ-SSCB on November 18,2011,indicated compliance
with the allowable arsenic emission rates. On November 14,2013,the EMC approved the revised arsenic AAL. Therefore, during the
permit renewal T20,a screening level air model was performed using emission rates from the February 2011 tests and worst-case stack
parameters. The model demonstrated that the maximum impact of arsenic was 9% of the revised arsenic AAL. Actual emissions
reported in the 2017 CY emissions inventory are compared to the respective air toxic limits as shown in the table below.
Source Pollutants Emission Limits 2017 CY Emissions
Boiler B-2 Arsenic 0.478 Ibs/12 mos. 0.7653 Ibs/yr
Acrolein 0.00224lbs/hr 0,00224lbs/hr
Benzene 251.4lbs/12 mos. 53.0 Ibs/yr
Beryllium 0.229 Ibs/12 mos. 0.1786 Ibs/yr
Cadmium 1.31 lbs/12 mos. 1.02 Ibs/yr
Chromium 0.00538lbs/day 0.0044lbs/day
Formaldehyde 0.0204lbs/hr 0.0204lbs/hr
Nickel 0.00826lbs/day 0.012lbs/day
Phenol 0.000267lbs/hr 0.00040lbs/hr
Boiler B-3 Arsenic 0.478 Ibs/12 mos. 0.6771 Ibs/yr
Acrolein 0.00224lbs/hr 0.00224lbs/hr
Benzene 251.4 Ibs/12 mos. 46.9 Ibs/yr
Beryllium 0.229 Ibs/12 mos. 0.158 Ibs/yr
Cadmium 1.31 Ibs/12 mos. 0.903 Ibs/yr
Chromium 0.00538lbs/day 0.0044lbs/day
Formaldehyde 0.0204lbs/hr 0.204lbs/hr
Nickel 0.00826lbs/day 0.012lbs/day
Phenol 0.000267lbs/hr 0.00040 Ibs/hr
Boiler B-4 Arsenic 0.0781bs/12 mos. 0.296 Ibs/yr
Acrolein 0.00449lbs/hr 0.00449lbs/hr
Benzene 504.6 Ibs/12 mos. 128.14 lbs/yr
Beryllium 0.459 Ibs/12 mos. 0.43 Ibs/yr
Cadmium 2.63 Ibs/12 mos. 0.395 Ibs/yr
Chromium 0.0108lbs/day 0.0014lbs/day
Formaldehyde 0.0409lbs/hr 0.0409lbs/hr
Nickel 0.00826lbs/day 0.00398lbs/day
Phenol 0.000267lbs/hr 0.00081lbs/hr
Kilns K-1 -K6 Acrolein 0.2536 lbs/hr 0.12 Ibs/hr
Formaldehyde 0.955 lbs/hr 0.32 lbs/hr
Phenol 0.28141bs/hr 0.1761bs/hr
As shown in the table above,2017 CY actual emissions were reported above the permitted limits for arsenic(boilers B-2, B-3 & B-4),
nickel (boilers B-2 & B-3), and phenol (boilers B-2, B-3 & B-4). Arsenic emissions reported in the 2017 emissions inventory were
based on an emission factor of 3.9 x 10-1 Ib/mmBtu rather than the approved stack test results. Based on the approved stack test results
for boiler B-2 of 1.36 x 10' Ib/mmBtu (used as a basis for boiler B-3),and 1.07 x 10' Ib/mmBtu for boiler(B-4), the facility complies
with the arsenic limits of the permit based on 2017 actual production throughputs. The dispersion modeling analysis dated November
17,2009 provides the modeled emission rates for nickel and phenol.
Page 6 of 10

PollgtOrtts .'' .. ' Modeled,EmassonT2ate, ', th5ss�on,�2ate(Ibs/day) 201Z>CYEmissians
Boiler B-2 Nickel 0.000517lbs/hr 0.0124 0.012lbs/day
Phenol 0.000402lbs/hr NA 0.00040lbs/ly
Boiler B-3 Nickel 0.000518lbs/hr 0.0124 0.012lbs/day
Phenol 0.000403lbs/hr NA 0.00040lbs/hr
Boiler B-4 Nickel 0.00104 Ibs/hr 0,0245 0.00398 Ibs/day
Phenol 0.000806 Ibs/hr NA 0.0008 Ibs/hc
This indicates that the facility is in compliance with the emission limits based on the modeled emission rates and the emission limits for
nickel and phenol listed in the permit are in error. The emissions limits of 0,000267 Ibs/hr for phenol and 0.00826 Ibs/day for boilers
B-2, B-3, and B-4 are based on the modeled emission rates for boiler 13-1 (no longer listed on the permit). Air toxics may no longer
apply to the boilers due to revisions to the NC air quality rules. Sources subject to a MACT are no longer subject to air toxics. At one
time,the permit contained annual fuel usage limits for each boiler. The fuel limits were removed from the permit as a screening level
modeling analysis conducted using potential emissions from the boilers and kilns found that no acceptable ambient levels(AALs)were
exceeded. Therefore,based on the previous modeling analyses,the facility appears to be in compliance with 2D.1100,
Condition 2.2.A.2 -This contains the requirements for 2D .1806 for control and prohibition of odorous emissions requirements. At
the time of inspection, no objectionable odors were detected outside of the facility. A review of the facility's file shows no recent odor
complaints have been received by this office. The facility appears to be in compliance with 2D .1806,
Condition 2.2A.3 - This contains the requirements for 2Q .0711 rule requiring that the facility to be operated and maintained in a
manner such that any TAPS listed under 2Q .0711 does not exceed the Toxic Permit Emission Rates (TPERs) listed in 2Q .0711. A
permit to emit any of the TAPS is required prior to exceeding any TPER limit. The TAPS that have exceeded the TPER limits are
addressed under Condition 2.2.A.1. The facility must maintain operational records to demonstrate that actual TAP emissions are less
than the TPERs. The following table shows the TAPS that are listed under this permit condition and the actual emissions reported in the
2017 CY Emissions Inventory. The facility appears to be in compliance with 2Q .0711.
Ad
ItZ1�#II,11tAr!l €., ,an; IP
,`'° Qd,Q��l„ I_L ... .,s ( ,.i.,.::. Q17uRIE�t[t$s1Q9S:
acetaldehyde 6.8 Ibs/hr ( 0.94 Ibs/hr
F- bis(2-ethylhexyl)phthalate 0.63 lbs/day 0.00011 lbs/day µ
(d i(2-ethylhexyl)phthalate)
carbon disulfide 3.9 lbs/day 0.30 lbs/day
-
chlorobenzene j 46 lbs/day 0.039lbs/day
chloroform 290 lbs/yr 26.18 lbs/yr
hydrochloric acid 0.18 Ibs/hr 0.011 Ibs/yr
hexane 23 lbs/day 0.67 Ibs/day
manganese 0.63 Ibs/day 0.062 Ibs/day
mercury 0,013 Ibs/day 0.00036 Ibs/day
methylene chloride T j 0.39 Ibs/hr; 1600 Ibs/yr 0.052 Ibs/hr;456 Ibs/yr
MIBK 7.6 1bs hr 52 lbs/day 0.0022 Ibs/hr 0.053 lbs/day j
_ .. .... .... _
pentachlorophen-I 0.0064 lbs/hr,0.063 Ibs/day 4.4 x I O`lbs/hr,0.00011 Ibs/day
styrene ( 2.7 lbs/hr 0.062 Ibs hr
- toluene 14.41bs/hr;98 Ibs/day 0.0028 Ibs/hr; 0.067 Ibs/day
trichloroethylene 4000 Ibs/yr 23.64 Ibs/yr
vinyl chloride 26 Ibs/yr 15.20lbs/yr
xylene 16.4 Ibs/hr; 57 Ibs/day 0.0027 Ibs/hr; 0.065 Ibs/day
Page 7 of 10

B. Six steam heated lumber drying kilns(ID Nos.K-1 through K-6)
Condition 2.2.13-This contains the requirements for 2D. 11 I 1 for complying with the National Emission Standards for Hazardous Air
Pollutants(NESHAP)federal regulations promulgated by the EPA. The steam heated lumber drying kilns(K-1 through K-6)are subject
to 40 CFR Part 63, Subpart DDDD "National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood
Products." These sources have no applicable requirements other than an initial notification. The initial notification was received by
DAQ-WSRO on April 26, 2006.
C. Wood-fired boilers(ID Nos. B-2, B-3& B-4)
Condition 2.2.C.1-This contains the requirements for 2D.1109 Case-by-Case boiler MACT. The boilers(B-2,B-3,&B-4)are subject
to the 2D .1109 regulation. The facility became subject to the Case-by-Case MACT regulation when 40 CFR 63, Subpart DDDDD
(51)), "National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process
Heaters"was vacated in 2007. The compliance date for the Case-by-Case boiler MACT regulation was on June 28,2013 and the facility
must comply with this regulation until May 19,2019. On May 20,2019,the facility must comply with the requirements of NESHAP
51). This condition also requires that reports are submitted on a semi-annual basis. The reports must contain a summary of the test
results, a signed statement that no new types of fuel were fired,and identification of all instances of deviation.
Per this permit condition,the four boilers are limited to no more than 0.27 Ibs/MMBtu of filterable PM,0.000005 Ibs/MMBtu of mercury,
and 0.02 Ibs/MMBtu of hydrogen chloride. Boilers B-2, and B-3 are limited to 269 ppmvd of CO corrected at 7%02. Boiler B-4 is
limited to 508 ppmvd of CO corrected at 7%02• Within 180 days of the initial compliance date;June 28,2013,the facility was required
to conduct initial compliance testing while firing wood. The facility conducted initial compliance testing on October 8,2013, October
4, 2013, and October 9, 2013 on boilers B-2, B-3, and B-4, respectively. The test results were approved by DAQ-SSCB on March 3,
2014, indicating compliance with the emission limits. Subsequent performance testing must be conducted according to the schedule
outlined under this permit condition. Since the results from the initial tests met the five-year test eligibility requirements, the boilers
were re-tested in October 2018. The test results were approved by DAQ-SSCB on February 6, 2019, indicating compliance with the
emission limits. The boilers are also limited to 20% opacity except for one 6-minute period per hour of not more than 27%. The
monitoring and recordkeeping requirements under permit conditions 2.1.A.3 and 2.1.B.2 are sufficient to demonstrate compliance with
this opacity requirement. The table below lists the test results and the emission limits under the Case-by-Case boiler MACT and
NESHAP 5D. The facility is in the process of installing ESPs on boiler B-2 and B-3 in order to meet the filterable PM emission limit
of 0.037 Ib/mmBtu under NESHAP 51). Testing is scheduled for May 2019. The DAQ-WSRO acknowledged receipt of the testing
protocol on April 15,2019 and the protocol is currently under review by DAQ-SSCB.
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Filterable PM 0.23lbs./MMBtu 0,142Ibs./MMBtu 0.27Ibs./MMBtu 3.7E-02Ibs./MMBtu
B 2 Carbon Monoxide 161 ppmvd 7%02 158 ppmvd 7%02 269 ppmvd 7%02 1500 ppmvd 3%02
HCL Equivalent 0.00016 Ibs./MMBtu 0.0003 Ibs./MMBtu 0.02 Ibs./MMBtu 2.2E-02 Ibs./MMBtu
Mercury 1.75E-07lbs./MMBtu 1.63E-07lbs./MMBtu 5.0E-06Ibs./MMBtu 5.7E-06lbs./MMBtu
Filterable PM 0.18 Ibs./MMBtu 0.170 Ibs./MMBtu 0.27 Ibs./MMBtu 3.7E-02 Ibs./MMBtu
B3 Carbon Monoxide 204 ppmvd 7%02 259 ppmvd 7%02 269 ppmvd 7%02 1,500 ppmvd 3%"02
HCL Equivalent 0.00012 Ibs./MMBtu 0.0003 Ibs./MMBtu 0.02 Ibs./MMBtu 2.2E-02 lbs./MMBtu
Mercury 1.65E-07lbs./MMBtu 2.44-07lbs./MMBtu 5.0E-06lbs./MMBtu 5.7E-06lbs./MMBtu
Filterable PM 0.0032 Ibs./MMBtu 0.00220 lbs./MMBtu 0.27 lbs./MMBtu 3.7E-02 Ibs./MMBtu
B 4 Carbon Monoxide 370 ppmvd 7%02 196 ppmvd 7%02 508 ppmvd 7%0 02 1,500 ppmvd 3%02
HCL Equivalent 0.000091bs./MMBtu 0.0003 Ibs./MMBtu 0.02 Ibs./MMBtu 2.2E-02 Ibs./MMBtu
Mercu 1.25E-07lbs./MMBtu 2.36-07lbs./MMBtu 5.0E-06lbs./MMBtu 5.7E-06lbs./MMBtu
The facility must submit a Notification of Compliance(NOC)within 60 days following the completion of the final required performance
test/ or other initial compliance demonstration. In addition to the NOC, a semiannual summary report must be submitted to DAQ-
WSRO within 30 days after each semiannual period. The semiannual report must include the total tons of wood fired each month in
each boiler during the previous semiannual period. The NOC was submitted to DAQ-WSRO on December 3, 2013. The latest semi-
annual report was received on February 1, 2019 (postmarked January 29, 2019). The report indicated that 18,797, 12,233, and 43,313
tons of sawdust were combusted during CY 2018 in boiler B-2, B-3, and B-4, respectively. The facility appears to be in compliance
with 2D .1109.
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Condition 2.2.C.2 applies to the wood-fired boilers(B-2, B-3, & B-4)and lists the applicability of 40 CFR Part 63, Subpart DDDDD
"National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and
Process Heaters." This condition was placed in the permit to inform the facility that the boilers are subject to the boiler MACT on May
20, 2019 and until then the requirements of the Case-by-case boiler MACT will be effective.
Section 2.3- Permit Shield for Non-Applicable Requirements
A. One wood fuel-fired boiler(ID No. B-2)with associated multicyclones(ID Nos. MC-2 and MC-2A) installed in series
One wood fuel-fired boiler(ID No. B-3)with associated multicyclones(ID Nos. MC-3 and MC-3A)installed in series
One wood fuel-fired boiler(ID No. B-4)with associated multicyclones(ID Nos. MC-4 and MC-4A)and electrostatic
precipitator(ID No. ESP-4)all in series
One planer mill(ID No.PM-2)with associated cyclone(ID No.C-2)in series with one bagfilter(ID No.B11-1)
Conditions 2.3.A.1 contains the 2D .0614 compliance assurance monitoring requirements. This permit condition basically states that
the four wood-fired boilers (B-2, B-3, & B-4) and planer mill (PM-2) are not subject to the CAM requirements because the potential
pre-control emissions from each source do not exceed the major source thresholds as outlined in 40 CFR 64.2(a)(3).
General Conditions
Conditions 3.I.A & 3.1.13 contains the 2D .0535 rule requiring the facility to notify the director of any excess emissions lasting longer
than four hours resulting from a malfunction, a breakdown of process or control equipment. Ms. Hill indicated that there had not been
any excess emissions lasting more than four hours since the last inspection. There were no notifications in the facility's file. The
facility appears to be in compliance with 2D .0535,
Condition 3.0 contains the 2Q .0508(f)and 2Q.0508(1)records retention requirements. All required records as outlined in the permit
were available during the inspection and appeared to be sufficient to demonstrate compliance. The facility appears to be in compliance
with 2Q .0508(f)and 2Q .0508(I).
Condition 3.P contains the 2Q.0508(n)compliance certification requirements.The annual compliance certification report was received
by DAQ-WSRO on March 4, 2019 (postmarked February 27, 2019). The facility was requested to re-submit the report since they
certified compliance with Air Permit No. 06740T21 that was not in effect during CY 2018. The report was re-submitted on March 19,
2019.The facility appears to be in compliance with 2Q .0508(n).
Condition 3.X contains the 2Q.0207 annual emission inventory requirement. The facility was required to submit an emissions inventory
by July 2,2018. The annual emissions inventory for CY 2017 was submitted via AFRO on June 6,2018 and the inventory certification
was postmarked on June 11, 2018. The inventory was approved by DAQ on June 15, 2018. The facility appears to be in compliance
with 2Q .0207.
Condition 3.MM contains the 2D .0540 fugitive dust control requirements. The property is mostly dirt and gravel, and dust was
observed on the property from the haul trucks. However, at the time of inspection, fugitive dust generated onsite was not observed
beyond the property boundary. There's also an area beyond the property boundary,used by the haul trucks in order to properly maneuver
onto the facility's property, which may potentially create fugitive dust. A review of the facility's file shows no recent fugitive dust
complaints have been received by this office. The facility appears to be in compliance with 2D.0540.
NSPS/NESHAP/112(r)APPLICABILITY
The facility is subject to the following New Source Performance Standard(NSPS)regulations:
• 40 CFR Part 60, Subpart De, "Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating
Units"as previously discussed under Condition 2.1.A.4 and 2.1.B.2.
The facility is subject to the following National Emissions Standard for Hazardous Air Pollutants (NESHAP)regulations:
• 40 CFR Part 63,Subpart DDDD,"National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood
Products"as previously discussed under Condition 2.23.
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• 40 CFR Part 63, Subpart ZZZZ, "National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating
Internal Combustion Engines." The propane-fired emergency engine (IGen 1) is subject to 40 CFR Part 63, Subpart ZZZZ
"National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines." The
facility must minimize the engine's startup time and time spent at idle. The engine must be operated and maintained according
to manufacturer specifications such that emissions are minimized. The oil and filter must be changed every 500 hours or
annually, whichever comes first. The spark plugs must be inspected every 1,000 hours or annually, whichever comes first.
The hoses and belts are to be inspected every 500 hours or annually,whichever comes first. The facility may use the oil analysis
program to extend the oil change requirement. The engine must be equipped with anon-resettable hour meter and may be
operated for unlimited hours for emergency purposes. The engine is allowed 100 hours of operation for the purpose of
maintenance and testing. Of the 100 hours allotted to maintenance and testing, 50 hours may be used for non-emergency
purposes. A log must be maintained indicating the purposes in which the engine was operated. A semiannual report
summarizing all monitoring, recordkeeping, and deviation activities must be postmarked no later than 30 days after each
calendar year semiannual period. Note that the emergency demand response requirements no longer apply due to the mandate
issued by U.S. Court of Appeals for the District of Columbia Circuit in May 2016 vacating 40 CFR 63.6640(f)(2)(ii)-(iii).
The engine is used for the purpose of providing power to the boiler pumps. The engine was not in operation during the
inspection. A log is maintained at the engine and it lists all the instances the engine operated and the purpose for operating it.
The non-resettable hour meter read 52.2 hours and has operated five hours since the last inspection on July 20, 2018. The
engine is turned on once every 2 months for readiness testing. Maintenance records show that the engine was last serviced on
April 13,2018. The facility appears to be in compliance with 2D .I I I I and 40 CFR 63, Subpart ZZZZ.
The facility does not produce, use, or store any of the regulated chemicals in quantities above the thresholds listed in 40 CFR 68.130.
Therefore, it is not required to have a Risk Management Plan(RMP). However, this facility is subject to the general duty provision of
this regulation.
FACILITY EMISSIONS
The facility-wide actual emissions CY2015,CY2016,and CY2017 are provided in the header of this report.
PERMIT CONSIDERATIONS
The 2D .1100 permit condition(2.2.A.1) should be re-evaluated as part of the current open application to add a fourth boiler. The air
toxics were added as a result of a Director's Call. Combustion sources and sources subject to MACT or GACT rules are now exempt
from toxics under 2Q.0702(a)(18)and(27). If air toxics still apply due to the Director's Call,the emission limits for arsenic and nickel
that apply to boilers B-2, B-3 and B-4 may need to be corrected as noted above pertaining to Condition 2.2.A.1.
COMPLIANCE HISTORY
There have not been any Notices of Deviation or Violation issued to this facility in the last five years.
CONCLUSION
Based on a review of records and visual observations, Canfor Southern Pine - Graham Plant appeared to be operating in compliance
with Air Quality rules and regulations at the time of this inspection.
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