AQ_F_0100237_20220321_CEM_RptRvwLtr (4)

Etc STATE
o o.'73 O
ROY COOPER
Governor
ELIZABETH S.BISERf,zM
Secretary
MICHAEL ABRACZINSKAS NORTH CAROLINA
Director Environmental Quality
March 21, 2022
Mr. Mark Blalock
General Manager
Canfor Southern Pine—Graham Plant
4408 Mt. Hermon-Rock Creek Road
Graham,North Carolina 27253-8909
SUBJECT: Review of 2021 Semiannual COMS Reports, Second Half
Canfor Southern Pine—Graham Plant
Graham, Alamance County,North Carolina
Air Permit No. 06740T22
Facility ID No. 0100237
Dear Mr. Blalock:
Thank you for your timely submittal of the semiannual reports: Semiannual Title V Air Permit
Report dated January 28, 2022 and NESHAP Semiannual Compliance Report dated January 31, 2022,
from Canfor Southern Pine's Graham Plant. The report included an assessment of the continuous
opacity monitoring systems (COMS)that operated on Boilers Nos. 2, 3 and 4 (ID Nos. B-2, B-3 &B-4)
during the second half of 2021. Additional information regarding deviations of the opacity operating
limit was provided by Gina Faust of Trinity Consultants on March 14, 2022. The Division of Air Quality
(DAQ) has completed its review of the COMS-related information in the report and has the following
comments:
1. Wood fuel-fired Boiler Nos. B-2, B-3 and B-4 were reviewed for compliance with the 10% opacity
operating limit(6-minute period, daily block average) set forth in 15A NCAC 02D .1111 -Maximum
Achievable Control Technology, specifically, 40 CFR Part 63, Subpart DDDDD—National Emission
Standards for Hazardous Air Pollutants for Major Sources:Industrial, Commercial, and
Institutional Boilers and Process Heaters, and Air Permit No. 06740, Specific Condition 2.2.C.La.
The COMS report indicated Boiler No. B-2 had three (3) deviations and Boiler No. B-3 had six (6)
deviations of the 10% opacity operating limit (daily block average) as follows:
Boiler No. B-2 Boiler No. B-3
11% on 11/17/21 11% on 10/13/21 11% on 11/23/21
11% on 11/27/21 12% on 10/27/21 12% on 12/17/21
13% on 11/28/21 11% on 11/02/21 14% on 12/18/21
As a result of these opacity deviations,your facility may be subject to an enforcement action
beginning with a Notice of Violation.
D Q2177 North Carolina Department of Environmental Quality I Division of Air QualityE West Jones Street 11641 Mail Service Center I Raleigh,North Carolina 27699-1641
NORTH CAROLINA
oePanment of Environmental Uwi\ /� 919.707.8400

Mr. Mark Blalock
March 21, 2022
Page 2
2. Wood fuel-fired Boiler No. B-4 was also reviewed for compliance with the 20% opacity limit
(6-minute period) set forth at 15A NCAC 02D .0524 -New Source Performance Standards (NSPS),
specifically, 40 CFR Part 60, Subpart Dc - Standards of Performance for Small Industrial-
Commercial-Institutional Steam Generating Units, and Specific Condition 2.1.AAA. The COMS
report indicated there were no deviations of the applicable standard. Excess emissions from the
wood-fired boiler were attributed to either startup, shutdown, malfunction, or other exempt
emissions. These emissions were reviewed and allowed in accordance with applicable monitoring
rules.
3. A review was also conducted for compliance with good operation and maintenance (O&M)practices
pursuant to NCAC 2D .0524 (NSPS Dc, including Subpart A- General Provisions), 40 CFR
60.11(d), 40 CFR 60.13(e), and Specific Condition 2.1.A.4; NCAC 2D .1111 (NESHAPS DDDDD
including Subpart A - General Provisions), 40 CFR 63.7500(a), 40 CFR 63.8(c)(4), and Specific
Condition 2.2.C.1. When compared to the total operating time of the boilers,percent excess
emissions (%EE) and percent monitor downtime (%MD) were reported as follows:
Source Quarter %EE %MD
Boiler No. B-2 3rd 0.0 0.0
4th 3.4 0.0
Boiler No. B-3 3rd 0.0 0.0
4th 6.7 0.0
Boiler No. B-4 3rd 0.1 0.1
4th 0.0 0.1
Unless otherwise specified in regulation, DAQ considers sources to have operated with good O&M
if the %EE and%MD are less than the target criteria of 6% for any single quarter and less than 3%
for two consecutive quarters. Based on the information provided, Boiler Nos. B-2 and B-3 appear to
have operated with improper O&M for minimizing emissions during the fourth quarter of 2021.
4. The 2021 third and fourth quarter audits of the COMS units were reviewed in accordance with 40
CFR Part 60, Appendix F, Procedure 3 - Quality Assurance Requirements for Continuous Opacity
Monitoring Systems at Stationary Sources. The QA test results for the COMS audits appear to have
met the quarterly specifications.
In addition to the mailing of this letter, an electronic copy (e-copy) is being provided for your
records. If you should have any questions, please contact me at(919) 707-8493 or
[e-mail].
Sincerely,
+Ian�Drake, E vironmental ngineer
Division of Air Quality,NCDEQ

Mr. Mark Blalock
March 21, 2022
Page 3
c: Mark Blalock, Canfor Southern Pine (e-copy)
Kristie Hill, Canfor Southern Pine (e-copy)
Gina Faust, Trinity Consultants (e-copy)
Ray Stewart, DAQ WSRO (e-copy)
Gary Saunders, DAQ SSCB (e-copy)
IBEAM Documents, 0100237 (e-copy)
Central File, Alamance County