AQ_F_0100237_20211130_CMPL_NOV-NRE (4)

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ROY COOPER
Governort�. �a ' �O
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CLCZABETI-f S.B1SER ...�,.
Secretary
MICHAEL ABRACZINSKAS NORTH CAROLINA
Director Environmental Quality.
November 30, 2021
CERTIFIED MAIL NUMBER 7019 1120 0001 5504 5496
RETURN RECEIPT REQUESTED
Mr. Mark Blalock, Plant Manager
Canfor Southern Pine—Graham Plant
4408 Mt. Hermon—Rock Creek Road
Graham,NC 27253
Subject: Notice of Violation and Notice of Recommendation for Enforcement
Canfor Southern Pine—Graham Plant
Graham,North Carolina
Alamance County
04-0100237-TV Air Permit No. 06740T22
Dear Mr. Blalock:
On November 8, 2021,this office received an email from Ms. Kristie Hill,Human Resources
Manager at Canfor Southern Pine,concerning the failure of the facility's electrostatic precipitator(ESP,
Control Device ID No. ESP-2), which controls particulate emissions from Boiler 2 (Emission Source ID
No. B-2). As required by General Condition 3.I.A of Air Quality Permit 06740T22, the facility notified
this office by email of the excess emissions caused by the ESP failure.
As reported by Ms. Hill's subsequent emails and in the Excess Emissions Written report received
by this office on November 15, 2021,your facility experienced a control switch failure for ESP-2
resulting in excess particulate matter emissions. The issue was detected on Monday,November 8,2021;
however, it was determined the ESP failure began on Friday,November 5, 2021 at 6:36am. The control
switch was replaced on Tuesday,November 9, 2021 at 2:30pm, and the ESP returned to operation. During
this time, Boiler 2 continued to operate with the two multicyclone control system (Control Device ID
Nos. MC-2 and MC-2A)to supply steam to the associated kiln drying process. The total time the facility
operated B-2 without ESP-2 was approximately 104 hours.
According to the October 4 through 9, 2013 stack test results, Boiler B-2's filterable PM emission
rate was 0.23 lb./MMBtu when operating with only the multicyclone control devices. This emission rate
was assumed to estimate the quantity of particulate emission during the ESP failure. This emission rate
exceeds the filterable particulate matter emission limit of 0.037 lb./MMBtu as listed in Permit Condition
2.2.C.10). This is a violation of 40 CFR 63, Subpart DDDDD"National Emission Standards for
Hazardous Air Pollutants for Major Sources: Industrial, Commercial,and Institutional Boilers and
Process Heaters"as referenced in Condition 2.2.C.1 and General Condition 3.F of Air Quality Permit
06740T22. These violations are discussed in the following paragraphs.
North Carolina Departrnt nt of Environmental Quality 1 Division of Air Quality
E ,
Winston-Salem Regional ofPict } 450 West Hanes M(11 Road,Suite300 j �h'instorrSalem,worth Carolina 2710E
Departs,n a Envlrmmwtalnuality 336-76-98o0 T i :3:36,776.9797 F

Mr. Mark Blalock
November 30, 2021
Page 2
Per §63.7500(a)(1)of 40 CFR 63, Subpart DDDDD,the facility"must meet each emission limit
and work practice standard in Tables 1 through 3, and 11 through 13 to this subpart that applies to your
boiler or process heater, for each boiler or process heater at your source, except as provided under
§63.7522." Based on the assumed estimation rate of 0.23 lb. PM/MMBtu during the ESP failure and the
filterable PM emission limit of 0.037 lb./MMBtu provided in Table 2.7(b)to Subpart DDDDD of Part 63
-Emission Limits for Existing Boilers and Process Heaters,your facility failed to meet the filterable PM
emission limit of this subpart.
Per General Condition 3.F of the above referenced Air Quality Permit, "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." The total
amount of time the facility operated Boiler 2 without the ESP control device was approximately 104
hours.
Each day that you operate in violation of 40 CFR 63, Subpart DDDDD or General Condition 3.17
may constitute an additional violation. Each violation is subject to enforcement action, including a civil
penalty of up to $25,000 and/or injunctive relief, pursuant to North Carolina General Statute(NCGS)
143-215.114A or permit revocation as authorized by NCGS 143-215.108(b)(3). You may wish to contact
the Division of Environmental Assistance and Customer Service at 1-877-623-6748 if you need
assistance.
We have prepared a report detailing these violations and intend to forward it to the Division of
Air Quality staff in Raleigh. The report concludes with a recommendation by this office for enforcement
action for the violations of 40 CFR 63 Subpart DDDDD and General Condition 3.17. If you wish to
present an explanation for the cited violations or if you believe there are other factors which should be
considered, please send the information to me in writing within 10 days following receipt of this letter.
The information will be reviewed and, if an enforcement action is still deemed appropriate, your
explanation will be forwarded to the Director with the enforcement package for consideration.
Please contact Andrew Kormos at 336-776-9642 (andrew.kot•[e-mail]) or me if you
have any questions.
Sincerely
I/
T. Ra Ste rt, r., P.E., CPM, R ional Supervisor
Division of Air uality,NCDEQ
c: WSRO county fileDnrtii
WSRO enforcement file