AQ_F_0100237_20220421_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Winston-Salem Regional Office
AIR QUALITY Canfor Southern Pine-Graham Plant
NC Facility ID 0100237
Inspection Report County/FIPS:Alamance/001
Date: 04/28/2022
Facility Data Permit Data
Canfor Southern Pine-Graham Plant Permit 06740/T22
4408 Mt Hermon-Rock Creek Road Issued 9/6/2019
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
NAICS: 321113/Sawmills Current Permit Application(s)TV-502(b)(10)
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Kristie Hill Mark Blalock Kristie Hill MACT Part 63: Subpart DDDD, SubpartDDDDD,Subpart ZZZZ
HR Manager Plant Manager HR Manager NSPS: Subpart Dc
[phone] [phone] [phone]
Compliance Data
Comments: Inspection Date 04/21/2022
Inspector's Name Andrew Kormos
Inspector's Signature: DMM Operating Status Operating
Compliance Status Violation-emissions
Action Code FCE
Date of Signature: Z3 2© Z Z Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
A20 35.15 8.76 77.06 316.78 190.39 24.66 30828.20
2019 35.14 8.42 74.05 319.28 156.94 24.63 31070.18
2018 42.00 8.36 73.60 309.08 93.18 33.55 30078.02
*Highest HAP Emitted in poundsh
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
03/24/2022 NOWNRE Part 63 -NESHAP/MACT Subpart DDDDD Industrial, Pending
Commercial,and Institutional Boilers and Process
Heaters
11/30/2021 NOWNRE Part 63 -NESHAP/MACT Subpart DDDDD Industrial, 12/13/2021
Commercial,and Institutional Boilers and Process
Heaters
11/30/2021 NOWNRE Permit Permit Condition 12/13/2021
02/19/2021 NOWNRE Part 63 -NESHAP/MACT Subpart A General 02/19/2021
Provisions
02/03/2021 NOWNRE Part 60-NSPS Subpart Dc Small Industrial- 12/13/2021
Commercial-Institutional Steam Generating Units
03/26/2020 NOWNRE Part 63 -NESHAP/MACT Subpart A General 03/26/2020
Provisions
03/26/2020 NOWNRE Part 60-NSPS Subpart A General Provisions 03/26/2020
12/13/2019 NOWNRE Part 60-NSPS Subpart Dc Small Industrial- 05/11/2020
Commercial-Institutional Steam Generating Units
Iwformed Stack Tests since last FCE:
Date Test Results Test Method(s) Source(s)Tested
03/09/2022 Pending
08/25/2021 Compliance Method 5 B-3
Page 1

PERMITTED SOURCES
Table 1 —Permitted Sources at the facility
ffN I Em
B-2 One wood fuel-fired boiler(28.7 million MC-2 Two multicyclones(16 nine-inch diameter
NSPS De; Btu per hour maximum heat input capacity) MC-2A tubes and 44 six-inch diameter tubes,
MACT DDDDD respectively)
ESP-2
One electrostatic precipitator
B-3 One wood fuel-fired boiler(28.7 million MC-3 Two multicyclones(16 nine-inch diameter
NSPS De; Btu per hour maximum heat input capacity) MC-3A tubes and 44 six-inch diameter tubes,
MACT DDDDD respectively)
ESP-3
One electrostatic precipitator
B-4 One wood fuel-fired boiler(57.6 million MC-4 Two multicyclones(36 nine-inch diameter
NSPS Dc; Btu per hour maximum heat input capacity) MC-4A tubes and 44 six-inch diameter tubes,
MACT DDDDD ESP-4 respectively)
One electrostatic precipitator
B-5 One natural gas-fired boiler equipped with
PSD• low NOx burners and an 02 trim system NA NA
NSPS,Dc; (25.2 million Btu per hour maximum heat
MACT,DDDDD input capacity)
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-I through K-6 Six steam heated lumber drying kilns NA NA
MACT DDDD
Debarker One enclosed rough log debarker NA NA
INSIGNIFICANT/EXEMPT SOURCES
Table 2—Insignificant Sources at the facility
MEMO In-ON"l OWN
IGen 1 -MACT Subpart ZZZZ Propane-fired emergency engine(118 hp)
I-Sawmill Green log sawmill
I-Silos Wood residue storage silos
I-Chippers Wood chippers
INTRODUCTION
On April 21, 2022, Mr. Andrew Kormos, DAQ-WSRO Environmental Engineer, and Mr. Mohammad Khan, DAQ-WSRO
Environmental Chemist, contacted Ms. Kristie Hill of Canfor Southern Pine to conduct an unannounced compliance inspection of the
above referenced facility. The facility was targeted this year and has a facility classification of Title V. Ms. Hill had Mike Timmons
(boiler operator)assist with the inspection with regards to boiler operations. Ms.Hill confirmed that there were no changes to the facility
contact information. The facility is a lumber mill that processes pine logs into dimensional lumber. The boilers and kilns operate 24
hours a day, 7 days a week, 50 weeks per year. The sawmill and planer mill operate 12 hours per day, 5 days per week, 50 weeks per
year. The facility schedules routine shutdowns twice a year, usually in June and October. The previous compliance inspection was
performed on June 24,2021,by Mr. Jim Hafner, DAQ-WSRO Environmental Engineer.According to Mr. Hafner's inspection report,
the facility appeared to be in compliance with all applicable Air Quality rules and regulations at the time of the inspection.
SAFETY
Safety shoes,safety glasses, reflective vest,hard hat,and hearing protection are required at the facility. General safety practices should
always be followed. Inspectors should be cognizant of heavy forklift traffic,
LATITUDE/LONGITUDE
The latitude and longitude coordinates of the facility were verified and are correctly documented in IBEAM.
Page 2

APPLICABLE REGULATIONS
The following Title.15A North Carolina Administrative Code(NCAC)air quality regulations apply to Canfor Southern Pine-Graham
Plant:2D.0503,2D.0504,2D.0512,2D.0516,2D.0521,2D.0524(40 CFR 60, Subpart Dc),2D.0530,2D.0535,2D.0540,2D.1100,
2D.1109,21) .1111 (40 CFR 63, Subparts DDDD,ZZZZ,DDDDD),2D .1806, and 2Q .0711.
CISCUSSION
Canfor Southern Pine-Graham Plant is a lumber mill that processes whole pine logs into dimensional lumber. The logs arrive on site
and are first weighed before being processed through the Debarker. The removed bark is then conveyed to a storage bin and removed
from the site. During the inspection, the debarker in operation and no visible emissions were observed. The debarked logs are then
conveyed into the sawmill building where the logs are cut to spec.As mentioned,the sawmill is located in an enclosed building in which
particulate emissions are contained within. The greenwood sawdust from the building is collected and conveyed to the facility's three
wood silos, which are used to fire the facility's boilers. The larger chips are screened out and conveyed to a different storage bin and
hauled offsite. From the saw mill, the cut lumbers is conveyed and collected by type of wood, size, ect. by the facility's automated
imaging system.The lumber is then compiled,arranged,then dried in one of the six steam heated drying kilns.Steam from this operation
is provided by the three wood-fired boilers.During the operation,all six kilns were in the process of drying lumber,and all three boilers
were operating (ID Nos. B-2 through B-4). It should be noted the facility is permitted a natural gas-fired boiler (B-5), but it is not
installed onsite.Ms.Hill said there are no plans to construct this boiler on site.After 19 to 24 hours of drying in the kilns,the dry lumber
is then processed by the facility's planer mill(ID No.No. PM-2),which is controlled by a cyclone(C-2)and bagfilter(BH-1)system.
The planar operation is enclosed for safety reasons, but it was operating during the inspection. The duct work to the baghouse system
appeared to be in adequate condition with no visible emissions from the emission point.The dust from the facility's planer mill is also
sent to wood residue storage silos and subsequently burned in one of the wood-fired boilers. Note: The facility submitted a like for like
replacement for cyclone(C-2)via a 502(b)(10)notification on June 9,2021. The replacement is scheduled for the planned shutdown in
June 2022.
As mentioned,all 6 steam heated drying kilns and all three constructed boilers were operating during the inspection.The steam pressure
in each kiln were observed,and are noted in following table.
Table 3 -Observed pressure of supplied steam in each kiln
K-1 118
K-2 119
K-3 119
K-4 120
K-5 126
K-6 119
Boiler B-2, a 1995 Hurst boiler and is controlled by two multicyclones (MC-2 & MC-2A) and an electrostatic precipitator (ESP-2).
Boiler B-3 is a 1998 Hurst boiler and is controlled by two multicyclones (MC-3 & MC-3A) and an electrostatic precipitator(ESP-3)
Boiler B-4 has a manufacture date of 2007 and is controlled by two multicyclones (MC-4& MC-4A)and an electrostatic precipitator
(ESP-4). Records of the daily fuel usage for each boiler is kept in the boiler control room.Each boiler is a bottom feeding stoker screw
fire tube boiler. The daily records are then given to Ms. Hill and entered electronically. The following operating parameters of the
boilers were observed during the inspection:
Table 4—Operating arameters of Boilers B-2 through B-4
B-2 4,000 122.1 11.5 0.11 2.0 372 VAC
Observed but 55 kVDc
B-3 not recorded 12,100 121.5 6.9 Ob erved 0.65 2.0 Not observed
by inspector
B-4 30,900 128.9 4.5 0.35 1.8 Not observed
The propane-fired emergency generator(IGen 1)was manufactured by Kohler(Model# C-605, serial#09649) and was not in use at
-time of the inspection. The facility also has wood chippers(1-4)listed as exempt/insignificant sources. These were not observed.
PERMIT CONDITIONS
Section 2.—Specific Limitations and Conditions
Page 3

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)all in series
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
Dc as referenced in 15A NCAC 02D .0524. To comply with this regulation, the two boilers must be controlled by their associated
multicyclones (MC-2, MC-2A, MC-3, and MC-3A) as shown on the permitted equipment list. The system ductwork and material
collection units must be visually inspected once per month for leaks. Additionally, each multicyclone must be internally inspected at
least annually 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 June 2021 through March 2022 were reviewed. The records appeared to be sufficient
to demonstrate compliance. An annual internal inspection was done on each multicyclone on June 4, 2021, during the plant's annual
shutdown. The latest semiannual report was received on February 1, 2022 (Postmarked January 30, 2022) and indicated compliance
with this permit condition. It appears that the facility is in compliance with 2D .0504.
Condition 2.I.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(i.e sawdust) is inherently low enough in sulfur to always be in compliance
with this rule.
Condition 2.I.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 rule. 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 n \
more than once in any hour and not more than four times in any 24-hour period. To demonstrate compliance, visible emissiok
observations 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. Three days of absent observations are allowed per semiannual
period.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, B-3, and B-4 were observed operating with no detectable visible emissions. Instantaneous opacity
for all three boilers can be viewed from the displays of each continuous emissions monitor(COM). As noted previously in Table 4,all
three boilers had instantaneous opacities below 1%. The daily visible emission observation records were reviewed, and all indicated
that none of the readings were above normal. The facility does daily visible emissions observations on all three boilers(B-2,B-3,and
B-4)even though there are no requirements for boiler(B-4).The VE observation records were spot checked and appeared to be complete.
As noted above,the facility is allowed three days of absent observations per semiannual reporting period. As such,the facility appears
to be in compliance with this permit condition.
The boilers should meet the opacity requirements for 2D .0521 if compliance with NESHAP DDDDD is demonstrated. The facility
demonstrates compliance with NESHAP Subpart DDDDD through remaining below 10% opacity which is gauged using continuous
opacity monitors.The facility still appears to be in compliance with 2D .0521.
Condition 2.1.A.4—This contains the requirements for 2D :0524 for complying with the New Source Performance Standards(NSPS)
regulations promulgated by the EPA. The three wood-fired 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. Monthly records of fuel usage are also required for boiler B-4. Because boiler B-
4 is larger than 30 million Btu per hour, it is subject to the PM and opacity standards under NSPS Subpart Dc.
Visible emissions from boiler B-4 are limited to no more than 20 percent opacity when averaged over a six-minute period, except for
one six-minute period per hour of not more than 27 percent opacity. Particulate matter emissions from boiler B-4 are limited to less
than 0.030 pounds per million Btu heat. These standards apply at all times,except during periods of start-up,shutdown,and malfunction.
Page 4

To ensure compliance with the emission limits above,boiler B-4 and its associated control equipment is to be operated in such a manner
that the parameters of the most recently approved emissions tests for this source are maintained at the levels established on that test date
including,but not limited to,process rates,heat inputs,fan speeds,and power levels of the ESP.
(—'�COM is required in accordance with 40 CFR Part 60,Appendix B"Performance Specifications"and Appendix F"Quality Assurance
ocedures." Records of any occurrence and duration of any startup, shutdown,or malfunction in the operation of boiler B-4 are to be
maintained. A semiannual report summarizing any excess opacity emission reports as measured by the COM must be postmarked no
later than 30 days after each calendar year semiannual period. If there are no excess emissions, then a report stating that no excess
emission occurred during the reporting period must be submitted.
Boiler B-4 was observed in operation with no detectable visible emissions (0.35%per COM). Fuel usage records were provided and
reviewed during the inspection. Daily fuel usage is written on the back of the strip charts for each boiler. Daily amounts are handwritten
onto a sheet that tracks monthly usage. Data from the daily and monthly record are entered into a spreadsheet. Ms. Hill maintains the
electronic records. The spreadsheet is updated at least monthly. The facility recorded about 300,000 lbs of fuel usage from April 1 to
April 20.
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. Testing for compliance with the boiler MACT was conducted on September 10,2019. The results of this
test indicated an exceedance of the NSPS Subpart Dc emission limit 0.030 lb PM/mmBtu. A re-test was conducted on January 30,2020,
and the results indicated compliance with NSPS subpart Dc. A subsequent test on August 25, 2020, indicated an exceedance of the
emission limit. The re-test conducted on March 17,2021 indicated compliance. The results of tests are provided in the table below.
Boiler B-4 Emission Testing History
03/18/2008 0.050 lb/mmBtu No
05/09/2008 0.007 lb/mmBtu Yes
09/10/2019 0.044 lb/mmBtu No
01/30/2020 Filterable PM 0.01921b/mmBtu 0.0301b/mmBtu Yes
08/25/2020 0.0341b/mmBtu No
03/17/2021 0.0007 lb/mmBtu Yes
C3/09/2022 Pending TBD
iNotes.
• 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 May 2008 testing results were approved in a memorandum by Shannon Vogel of the SSCB dated June.20,2008.
• The September 10,2019,results were approved in a memorandum by Shannon Vogel of the SSCB dated November 27,2019.
• The January 30,2020,testing results were approved in a memorandum by Shannon Vogel of the SSCB dated May 11,2020.
• The August 25,2020,testing results were approved in a memorandum by Shannon Vogel of the SSCB dated January 27,2021.
• The March 17,2021,test results were approved in a memorandum by Shannon Vogel of the SSCB dated December 17,2021
• The March 9,2022 testing results are pending.Preliminary results indicate compliance.
The facility has installed the COM on boiler B-4 and has been complying with the reporting requirements. Records of excess emissions
are also submitted as part of the semiannual reporting requirements. The COMS report for the second half of CY 2021 was received on
January 30,2021, and contained copies of the excess emission reports. Alan Drake of the DAQ Raleigh Central Office reviewed the
report and indicated that boiler B-4 was in compliance for the recordkeeping and reporting requirements related to the COM for boiler
B-4 under NSPS Subpart Dc. (NOTE: Facility was in non-compliance for this report due to opacity issues for Boilers B-2 and B-3).
Operational parameters for boiler B-4 as well as boilers B-3 and B-4 are also required as part of the requirements for NESHAP Subpart
DDDDD. Boiler B-4 also must meet the opacity limit of 10%under Subpart DDDDD. Therefore,the boiler should meet the opacity
requirements for 21) .0524 if compliance with NESHAP DDDDD is demonstrated. In addition, NESHAP Subpart DDDDD requires
that the opacity must be monitored and establishes limits for 02 trim and steam production rate based on stack testing. The facility
appears to be in compliance with 2D .0524 and 40 CFR 60, Subpart Dc.
B. One planer mill(ID No.PM-2)with associated cyclone(ID No. C-2)in series with one bagfilter(ID No.BH-1)
Condition 2.1.B.1—This contains the requirements for 2D.0512 for controlling particulate emissions from miscellaneous wood product
0 fishing plants. The planer mill(PM-2)is subject to this regulation. To comply with this regulation,the planer mill must be controlled
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 during each 12-month period 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.
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Monthly external visual inspection records were provided from May 2021 through March 2022. The records were reviewed and
appeared to be complete.Annual internal inspection of the cyclone and bagfilter were last done June 19,2020 and June 8,2021,where
bags and the wheel fan motor were replaced. The facility typically completes the internal inspections of the control devices during the
plant's shutdown. The latest semiannual report was received on February 1, 2022 (Postmarked January 30, 2022), and indicated
compliance with this permit condition. Compliance is indicated.
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 observations 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. The cyclone and bagfilter were in operation, and no visible emissions were
observed. Weekly visible emission observation records from June 2021 through March 2022 were provided and all indicated that none
of the VE observations and pressure drop readings were above normal. The latest semiannual report was received on February 1,2022
(Postmarked January 30,2022),and 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 rule.The rule 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 an(
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 detectable visible emissions.The facility appears to be in compliance with this regulation.
D. One natural gas-fired boiler equipped with low-NOx burners and an 02 trim system (ID No. B-5)
Note: This boiler has not been installed.Therefore,Conditions 2.1.D.1 through 2.1.D.5 are not discussed in this report.
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. During the permit renewal (Air Permit T18), the toxic demonstration for the arsenic
emissions was deferred since the arsenic AAL was under review by EMC. On February 1-2,2011,boilers B-2 and B-4 were tested to
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. The facility appears to
be in compliance with the permit condition as shown in the table below which compares actual emissions reported in the CY2020
emissions inventory with the established air toxic limits.
¢ s 3 �`s} �_'Fi, 8, ...'s
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Boiler B-2 Acrolein 0.00224 lbs/hr 0.0015 lbs/hr
Arsenic 0.478 lbs/12 mos. 0.0022 lbs/yr
Page 6

r
Benzene 251.4 lbs/12 mos. 46.2 lbs/yr
Beryllium 0.229 lbs/12 mos. 0.1551bs/yr
Cadmium 1.31 lbs/12 mos. 0.88 lbs/yr
Chromium 0.00538 Ibs/day 0.003 Ibs/day
(nonspecific Cr(VI)compounds
Formaldehyde 0.0204 lbs/hr 0.0014 lbs/hr
Nickel 0.0124 lbs/day 0.00841bs/day
Phenol 0.0004021bs/hr 0.00027 lbs/hr
Boiler B-3 Acrolein 0.00224 lbs/hr 0.0013 lbs/hr
Arsenic 0.478 lbs/12 mos. 0.0025 lbs/yr
Benzene 251.41bs/12 mos. 39.4 lbs/yr
Beryllium 0.2301bs/12 mos. 0.13 lbs/yr
Cadmium 1.31 lbs/12 mos. 0.76 lbs/yr
Chromium 0.0054 Ibs/day 0.0061bs/day
(nonspecific Cr(VI)compounds
Formaldehyde 0.0204 lbs/hr 0.0091bs/hr
Nickel 0.0124 Ibs/day 0.0072 Ibs/day
Phenol 0.000403 lbs/hr 0.00023 lbs/hr
Boiler B-4 Acrolein 0.004491bs/hr 0.00341bs/hr
Arsenic 0.078 lbs/12 mos. 0.041 lbs/yr
Benzene 504.6 lbs/12 mos. 103.61bs/yr
Beryllium 0.459 lbs/12 mos. 0.35 lbs/yr
Cadmium 2.63 lbs/12 mos. 0.321bs/yr
C Chromium 0.0108 Ibs/day 0.0025 Ibs/day
(nonspecific Cr(VI)compounds
Formaldehyde 0.0409 lbs/hr 0.031 lbs/hr
Nickel j 0.02495lbs/day 0.0035 Ibs/day
Phenol 0.000806 lbs/hr 0.0006 lbs/hr
Kilns K-1 -K6 Acrolein 0.25361bs/hr 0.13 lbs/hr
Formaldehyde 0.955 lbs/hr 0.32 lbs/hr
Phenol 0.2814 lbs/hr 0.17lbs/hr
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 compares actual emissions reported in the CY2020 Emissions Inventory with the TPER limit for
each air toxic listed in the permit condition. The facility appears to be in compliance with 2Q.0711.
acetaldehyde 6.81bs/hr 0.92 lbs/hr
DEHP Di 2 eth lhex 1 hthalate 0 63 Ibs/da
_ _._ 0009 lbs/day
carbon disulfide 3.9 lbs/day 0.25 lbs/day
chlorobenzene_ € ... 461bs/day ___. . 0.33 lbs/day
chloroform 290 lbs/yr 21.72 Ibs/yr
hydrochloric acid 0.18 lbs/hr 0.031 lbs/hr
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�. m
hexane 23 lbs/day 0.56 Ibs/day
manganese 0 63 Ibs/dy 0 053 Ibs/da
... ___ __.__ . .._Y_
m a
mercury 0.013 lbs/day 0.00063 lbs/day
methylene chloride 0.39 lbs/hr; 1600 lbs/yr 0.043 lbs/hr;378.3 lbs/yr
MIBK 7.6 lbs/hr;52 lbs/day F 0.0018 lbs/hr;0.044 lbs/day
pentachlorophenol 0.0064 lbs/hr;0.063 Ibs/day 3.7 x 10 5 lbs/hr,8.89 x 10 41bs/day
styrene 2.7 lbs/hr 0.05 lbs/hr
toluene 14.41bs/hr,98 lbs/day 0.0023„lbs/hr;0.056 lbs/day
trichloroethylene 4000 Ibs/yr 19.61 Ibs/yr
vinyl chloride ,F 26 lbs/yr 12.6 Ibs/yr
xylene 16.4 lbs/hr,57 Ibs/day 0.002 lbs/hr;0.054 lbs/day
B. Six steam heated lumber drying kilns(ID Nos. K-1 through K-6)
Condition 2.2.B-This contains the requirements for 2D. 1111 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. The facility appears to be in compliance with NESHAP Subpart DDDD.
C. Wood-fired boilers(ID Nos. B-2, B-3& B-4)
Condition 2.2.C.1 - This contains the requirements for 2D .1111 for complying with 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." As required,an initial tune-up for each wood-fired boiler and
one-time energy assessment were to be completed no later than May 20, 2019. Each boiler must comply with applicable emission
standards at all times except during periods of startup and shutdown. Compliance with the emission limits must be demonstrated usi
performance stack testing,fuel analysis,or continuous monitoring systems(CMS), including a continuous emission monitoring systel,,_
(CEMS), or particulate matter continuous parameter monitoring system(PM CPMS),where applicable. The monitoring requirements
of this rule require the facility to install, operate, and maintain a CMS that includes operating load monitors, oxygen analyzer systems
and COMS.The following operating limits apply:
• the 30-day rolling average operating load for each-wood-fired boiler must be maintained such that it does not exceed 110
percent of the highest hourly average operating load recorded during most recent performance test;
• the 30-day rolling average oxygen content must be maintained at or above the lowest hourly average oxygen concentration
measured during the most recent CO performance test;and
• Maintain opacity of each wood-fired boiler to less than or equal to 10 percent opacity or the highest hourly average opacity
reading measured during the performance test run demonstrating compliance with the PM emission limitation (daily block
average).
Currently, performance tests are to be done on an annual basis for each wood-fired boiler. However, if the facility demonstrates
compliance with performance tests,NESHAP DDDDD allows for the tests to be completed on a less frequent basis. The performance
tests must be completed no more than 13 months after the previous performance test. Continuous compliance with each emission limit
and operating limit must be demonstrated based on parameters established during performance tests.The amount of fuel burned in each
boiler during each reporting period must be kept to demonstrate compliance the HCL and mercury emission limits. A tune-up of each
boiler is required every five years and must be conducted within 61 months after the previous tune-up. During start-ups and shutdowns,
the facility must meet work practice requirements that include operating the CMS and vent emissions through the control devices
(multicyclones and ESPs). All notifications and reports submitted to comply with this Subpart must be kept for 5 years with records
kept on-site for at least 2 years. A compliance report must be submitted and postmarked no later than 30 days after each calendar year
semiannual period. The compliance report must also be submitted to the EPA via CEDRI.
The initial tune-ups for each boiler were completed May 14,2019(B-2),May 15,2019(B-3), and May 16,2019(B-4). The one-tirh ,
energy assessment was completed on April 30,2019. The Notification of Compliance Status was received on November 12,2019.Th
facility demonstrates compliance with the applicable emission limits through performance testing. An updated Notice of Compliance
status report was received on April 8,2021.As shown in the table below,boiler(B-4)failed to show compliance with the NSPS Subpart
Dc limit of 0.030 lb/mmBtu during the performance test on August 25,2020. A re-test was done on March 17,2021. A review of the
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test results shows that Boiler (B-4) complies with the NSPS Subpart Dc limit of 0.030 lb/mmBtu. The results for the most recent
filterable PM and CO emissions testing are currently under review.
13-4 3/9/22 Filterable PM Results submittedetd 5/9/22 0.030 lb/mmBtu MACT DDDDD TBD
CO and under review 1500 m 3.0%02
B-3 F8/26/21 Filterable PM 0.0007 lb/mmBtu 0.030 lb/mmBtu FMACTDDDDD Yes
CO 374.9 in 3.0%02 1500 ppm 3.0%02
0.45 lb/mmbtu 2D .0504 Yes
Filterable PM 0.0007 lb/mmbtu
B-4 3/17/21 0.037lb/mmbtu Yes
CO 838.8 ppmvd@3%02 1500 ppmvd @3%02 MACT DDDDD Yes
Filterable PM 0.0028 lb/mmbtu 0.45 lb/mmbtu 2D .0504 Yes
0.037 lb/mmbtu Yes
B-2 8/27/20 HCl <3.91E-5lb/mmbtu 0.0221b/mmBtu Yes
CO 358.7 ppmvd@3%02 1500 ppmvd @3%02 MACT DDDDD Yes
Hg 2.2E-7lb/mmBtu 5.7E-61b/mmBtu Yes
Filterable PM 0.016 lb/mmbtu 0.45 lb/mmbtu 2D .0504 Yes
0.037 lb/mmbtu Yes
B-3 8/26/20 HCl <4.1E-51b/mmbtu 0.022lb/mmBtu Yes
CO 466.6 ppmvd@3%02 1500 ppmvd @3%02 MACT DDDDD Yes
Hg 2.5E-7 lb/mmBtu 5.7E-6 Win Btu Yes
Filterable PM 0.034 lb/mmbtu 0.030 lb/mmbtu NSPS Dc No
0.0371b/mmbtu Yes
B-4 8/25/20 HCl <4.3E-5lb/mmbtu 0.022lb/mmBtu Yes
CO 860.6 ppmvd@3%02 1500 ppmvd @3%02 MACT DDDDD Yes
Hg I 2.4E-71b/mmBtu 5.7E-6lb/mmBtu Yes
=B- 1/30/20 Filterable PM 0.0192 lb/mmBtu 0.030 lb/mmBtu NSPS Dc Yes
1
0.0371b/mmbtu MACT DDDDD Yes
C :ne boilers are required to be testing annual unless the test results are below 75% of the emission limit for each pollutant for 2
consecutive source tests. In that case, each pollutant can be sourced test every 37 months. Based on the previous results, B-2 source
testing will be due for all pollutants on 9/27/23, B-3 will be due for Hg and HCl on 9/26/23 and for PM and CO on 9/26/24,and B-4
will be due for HCl and Hg on 9/25/23 and for PM and CO on 4/9/25. IBEAM Source Testing module was also updated accordingly.
The following operating limits have been established(steam flow and 02 trim are based on stack test parameters).
PM and Hg Opacity< 10% Table 4 Subpart DDDDD
Steam Flow <20,397 lb/hr 110%of the highest hourly average operating load recorded during most
B-2 - recent performance test
the 30-day rolling average oxygen content must be maintained at or
02 Trim >5.3% above the lowest hourly average oxygen concentration measured during
the most recent CO performance test
PM and Hg Opacity< 10% Table 4 Subpart DDDDD
Steam Flow < 19,784 lb/hr 110%of the highest hourly average operating load recorded during most
B-3 - recent perfonnance test
the 30-day rolling average oxygen content must be maintained at or
02 Trim >5.3% above the lowest hourly average oxygen concentration measured during
the most recent CO performance test
PM and Hg Opacity< 10% Table 4 Subpart DDDDD
Steam Flow <41,294 lb/hr 110%of the highest hourly average operating load recorded during most
B-4** - recent performance test
the 30-day rolling average oxygen content must be maintained at or
02 Trim >4.2% above the lowest hourly average oxygen concentration measured during
the most recent CO performance test
*B-4 Operating limits based on prelimina results of 3/9/22 stack test
The facility demonstrates compliance with each applicable limit through performance testing. Compliance with the above operating
limits have been verified for the following:
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• Having the setting for each 02 trim system above the levels as indicated in the table above.
o B-2 and B-3 02 trim were observed to be both above 10%during the inspection. B-4 Oz Trim was observed at 4.5%
with a setpoint of 4.25%
• Monitoring the COM daily block average to verify each boiler does not exceed the 10%opacity limit: and
• Recording the 30-day rolling average steam flow and verifying it is not higher than the limits established for each boiler.
The latest compliance report was received on February 1, 2022 (postmarked January 30, 2022) and indicated non-compliance with
NESHAP Subpart DDDDD. This report indicated that the facility had a total of nine(9)deviations of the 10%opacity operating limit
(daily block average) in Boilers B-2 and B-3 from October 13,2021 through December 18, 2021. The facility records also indicated
exceedances of the 10%opacity limits in these boilers.The facility was issued a NOV/NRE on March 24,2022 for this non-compliance.
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. BH-1)
Conditions 2.3.A.1 contains the 2D .0614 compliance assurance monitoring requirements. This permit condition 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.I.B 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. On November 8,2021, Ms. Hill notified
WSRO-DAQ about an ESP failure at the facility that resulted in excess emissions.An excess emissions report was received on November
15,2021 detailing this failure. It was reported that the facility operated B-2 for 104 hours without the ESP operating. The facility was
issued an NOV/NRE for this event.No other notifications were received at DAQ-WSRO nor did facility records indicate any other such
events. 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 perml.
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(1).
Condition 3.P contains the 2Q.0508(n)compliance certification requirements.The annual compliance certification report was received
by DAQ-WSRO on March 1, 2022. Deviations for COMs monitor downtimes and ESP switch failure were appropriately reported as
required.The facility appears to be in compliance with 3.P.
Condition 3.X contains the 2Q.0207 annual emission inventory requirement. The facility is required to submit an emissions inventory
by July 1st for the previous year. The annual emissions inventory for CY 2020 was submitted via AERO on May 4,2021 and accepted
by Mr. Hafner on September 29,2021. 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/forklifts. However, at the time of inspection, fugitive dust generated onsite was not
observed beyond the property boundary. 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.D.4.
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 Compo�_)
Wood Products"as previously discussed under Condition 2.2.B.
• 40 CFR Part 63, Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Major Sources:
Industrial,Commercial,and Institutional Boilers and Process Heaters."as previously discussed under Condition 2.2.C.1.
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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 a non-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 log is maintained in the building housing the engine and it lists all the instances the engine operated and the purpose for
operating it. On May 17,2022, Ms. Hill sent the inspector the 2021 maintenance records for the engine. The work was
completed on April 5,2021 and was completed by Canfor's maintenance. The records indicated the service on the engine
included checking the engine's belts,hoses,and battery as well as changing the oil and filter. On May 17,2022,Ms.Hill
reported that the hour meter read 65.7 hours,indicating that the engine ran for 7.4 hours since the last compliance inspection
on June 24,2021. The generator is used to pump cooling water to each boiler in the event of loss of power to the plant.
The engine is turned on once every 2 months for readiness testing. The facility appears to be in compliance with 21).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 CY2018,CY2019,and CY2020 are provided in the header of this report.
PEERMIT CONSIDERATIONS
�. e requirement for daily visible emission observation for the two wood-fired boilers under 21) .0521 seems redundant now that each
boiler is equipped with a COM as required by NESHAP Subpart DDDDD.
Notifications of start-up of the natural gas-fired boiler should be included in the permit condition for NSPS Subpart Dc.
There are no inspection and maintenance requirements for the electrostatic precipitators. These should be added if necessary.
The NSPS particulate limit for boiler B-4 in permit condition 2.1.A.4.d.ii.states that the limit is 0.03 pounds per million Btu heat input.
This needs to be corrected to 0.030 pounds per million Btu heat input.
COMPLIANCE HISTORY
A Notice of Violation/Recommendation for Enforcement was issued on March 24,2022 for COMB exceedances on Boilers B-2 and B-
3. It is currently being reviewed to potentially assess civil penalties.
A Notice of Violation/Recommendation for Enforcement was issued on November 30,2021 for failing to operate ESP-2 while operating
B-2.A civil penalty of$8,887 was assessed and paid for this violation.
A Notice of Violation/Recommendation for Enforcement was issued on February 3, 2021, for a failed stack test. The test results
indicated a violation of the NSPS Subpart Dc PM emission limit for boiler B-4. A civil penalty of$4,258 was assessed for this violation.
A Notice of Violation/Recommendation for Enforcement was issued on February 19, 2021, for having improper O&M practices
resulting in an excessive amount of monitor downtime. A review of the semiannual summary report regarding the facility's operation
of the continuous monitoring system(COMS) indicated violations of NCAC 02D .I I I I "Maximum Achievable Control Technology".
Boiler B-2 operated for 129,360 minutes with 14,238 minutes (equal to 11.0%) of monitor downtime and Boiler B-3 operated for
25,640 minutes with 14,292 minutes(equal to 11.4%)of monitor downtime. The COMS downtime was attributed to a power outage
1t occurred on August 1,2020 and impacted the data feeds from the COMS units on Boilers B-2 and B-3 to the data acquisition system
--cor 14,106 minutes during the third and fourth quarters of 2020.A civil penalty of$2,457 was assessed for these violations.
A Notice of Violation/Recommendation for Enforcement was issued on March 26,2020,for having improper O&M practices resulting
in an excessive amount of monitor downtime. A review of the semiannual summary report regarding the facility's operation of the
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continuous monitoring system (COMS)during the third and fourth quarter of calendar year 2019 indicated violations of NCAC 02D
.1111 "Maximum Achievable Control Technology"and NSPS Subpart A.A civil penalty of$3,449 was assessed for these violations.
A Notice of Deficiency was issued on March 12,2020,for a late internal inspection of a bagfilter and cyclone.
A Notice of Violation/Recommendation for Enforcement was issued on December 13, 2019, for a failed stack test. The test results
indicated a violation of the NSPS Subpart Dc PM emission limit for boiler B-4. A civil penalty of$4,253 was assessed for this violation
CONCLUSION
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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