AQ_F_0100237_20220324_CMPL_NOV-NRE

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ROY COOPER
Governor
ELIZABETH S.BISER ` ,�L
Secretary
MICHAEL ABRACZINSKAS NORTH CAROLINA
Director Environmental Quality
March 24, 2022
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Mark Blalock, General Manager
Canfor Southern Pine—Graham Plant
4408 Mt. Hermon-Rock Creek Road
Graham,North Carolina 27253-8909
SUBJECT: Notice of Violation/Notice of Recommendation for Enforcement
40 CFR Part 63, Subpart A Requirements
Canfor Southern Pine—Graham Plant
Graham, Alamance County,North Carolina
Air Permit No. 06740T22
Facility ID No. 0100237
Fee Class: Title V
Dear Mr. Blalock:
The Division of Air Quality(DAQ) has reviewed the 2021 periodic 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. These reports included an assessment of the
continuous opacity monitoring systems(COMS)that operated on Boilers Nos. 2 and 3 (ID Nos. B-2 &
B-3) during the second half of 2021. Wood fuel-fired Boiler Nos. B-2 and B-3 are subject to 15A NCAC
02D A I I I -Maximum Achievable Control Technology(MACT), specifically, 40 CFR Part 63, Subpart
DDDDD—National Emission Standards for Hazardous Air Pollutants (NESHAP)for Major Sources:
Industrial, Commercial, and Institutional Boilers and Process Heaters,which includes Subpart A—
General Provisions in accordance with Air Permit No. 06740T22, Specific Condition 2.2.C.La. After
reviewing the reports, a follow-up email on March 14, 2022 confirmed there were nine(9) deviations of
the 10% opacity operating limit(daily block average) as listed below.
Boiler No. B-2 Boiler No. B-3
11% - 11/17/21 11% - 10/13/21 11% - 11/23/21
11% - 11/27/21 12%- 10/27/21 12% - 12/17/21
13% - 11/28/21 11% - 11/02/21 14% - 12/18/21
Canfor determined the likely cause of the opacity deviations was dust and moisture on the
COMS lens, which in turn was caused by temperatures and paving activities at the facility. Since the
opacity operating limit deviations constitute as a violation of 40 CFR 63.7500(a)(2), this letter
serves as a Notice of Violation (NOV) of 15A NCAC 02D .1111 - MACT as promulgated in 40 CFR
Part 63, Subpart DDDDD for not complying with the emission limitations of§63.7500 as specified
in Table 4 of the Boiler MACT.
or� D E Q A North Carolina Department of Environmental Quality I Division of Air Quality
—r _` I 217 West Jones Street 1641 Mail Service Center I Raleigh,North Carolina 27699-1641
a \ /� 919.707.8400

Mr. Mark Blalock
March 24, 2022
Page 2
Due to the stated opacity operating limit violations, this letter also serves as a Notice of
Recommendation for Enforcement(NRE). An enforcement report is being prepared by this office
addressing these violations. It is requested that a written response to this NOWNRE be submitted
as soon as possible, but not later than April 29,2022. The response should outline the steps that you
have taken or plan to take to assure compliance with the aforementioned requirements at all times.
These violations and any other violations of air quality regulations are subject to civil penalties
pursuant to North Carolina General Statute 143-215.114A. A civil penalty may be assessed against a
company who violates or fails to act in accordance with the terms, conditions, and/or requirements of
any permit issued under General Statute 143-215.108.
Also please note that this Notice of Violation is required to be referenced in your facility's annual
compliance certification(ACC), in accordance with Section 3, General Condition P of your Title V
permit.
In addition to the mailing of this letter, an electronic copy(e-copy) is being provided for your
records. Your cooperation and concern for the environment are appreciated. If you should have any
questions,please contact Alan Drake of my staff at(919) 707-8493.
Sincerely,
�LJ
Stephen G. Hall, Chief
Technical Services Section
Division of Air Quality,NCDEQ
SGH/ad
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 (hardcopy and e-copy)
Gary Saunders, DAQ SSCB (e-copy)
IBEAM Documents, 0100237 (e-copy)
Central File, Alamance County