AQ_F_0100237_20220325_ENF_Enf-FND

STATE OF NORTH CAROLINA NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL
COUNTY OF ALAMANCE QUALITY
FILE NO. DAQ 2022-006
IN THE MATTER OF: )
CANFOR SOUTHERN PINE— ) CIVIL PENALTY ASSESSMENT
GRAHAM PLANT )
FOR VIOLATION OF: )
GENERAL CONDITION 31 OF )
AIR PERMIT NO. 06740T22 )
Acting pursuant to North Carolina General Statutes (G.S.) 143-215.114A, I, Michael A.
Abraczinskas, Director of the Division of Air Quality ("DAQ"or"Division"), make the
following:
I. FINDINGS OF FACT:
A. Canfor Southern Pine—Graham Plant(Facility ID: 0100237) operates a lumber
mill in Graham, North Carolina.
B. Canfor Southern Pine—Graham Plant was issued Air Permit No. 06740T22 on
September 6, 2019.
C. Condition 31 of the above referenced Air Quality Permit requires that the facility
shall be properly operated and maintained at all times in a manner that will affect
an overall reduction in air pollution. No emission source may be operated without
concurrent operation of its associated air cleaning device.
D. The facility reported the failure of the electrostatic precipitator(Control Device
ID No. ESP-2) controlling Boiler B-2 to DAQ on November 8,2021. Specifically,
the facility cited a control switch failure of ESP-2,beginning on November 5,
2021.
E. The facility submitted a written follow-up report on November 15, 2021. The
report indicated that Boiler B-2 operated from Friday,November 5, 2021 at
6:36am to Tuesday,November 9, 2021 at 2:30pm without the associated
electrostatic precipitator, totaling approximately 104 hours. In the report, the
facility provided an estimated filterable PM emission rate of 0.29 pounds per
million Btu, which was based on stack testing performed from on B-2 from
October 3-9, 2013,prior to the installation of ESP-2.
F. A Notice of Violation/Notice of Recommendation for Enforcement(NOV/NRE)
dated November 30,2021, was sent to Canfor Southern Pine for not properly
operating and maintaining the facility at all times in a manner that will affect an
overall reduction in air pollution and operating an emission source without the
concurrent operation of its associated air pollution control device, in violation of

Canfor Southern Pine—Graham Plant
DAQ 2022-006
Page 2
Condition 31 of Air Quality Permit No. 06740T22. A response letter was
received on December 13, 2021, indicating the control switch was replaced and
ESP-2 went back into operation on November 9, 2021. Additionally,the response
indicated that the multicyclones for the boiler continued to operate during the
control switch failure. The response also noted that a more recent stack test for
Boiler B-2, conducted on October 9, 2018 indicated a filterable emission rate of
0.14 pounds per million Btu (without ESP-2), which represents a decrease from
the original estimate. Finally,the response stated that the facility has taken steps
to resolve such issues more quickly in the future,including keeping spare parts at
the facility and establishing procedures to immediately respond to emission
exceedances that occur over the weekend.
G. Air Quality compliance history over the past five years:
• An NOWNRE 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
.1111 "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 125,640 minutes with 14,292 minutes (equal to
11.4%) of monitor downtime. The COMS downtime was attributed to a
power outage that 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
for 14,106 minutes during the third and fourth quarters of 2020. A civil
penalty of$2,457 was assessed for these violations and was paid in full.
• On February 3, 2021, an NOWNRE was issued for violation pursuant
to 40 CFR Part 60, Subpart Dc for filterable PM emissions rate for boiler
B-3 of 0.034 pounds permillion Btu which exceeded the limit of 0.030
pounds per million Btu occurring on a stack test on August 25, 2020. A
civil penalty of$4,258 was assessed for this violation and was paid in
full.
• An NOWNRE was issued on March 26, 2020, for having improper O&M
practices resulting in an excessive amountof monitor downtime. A
review of the semiannual summary report regarding the facility's
operation of the 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 and was paid in full.
• A Notice of Deficiency was issued on March 12, 2020, for a late
internal inspection of a bagfilter and cyclone.
• An NOWNRE was issued on December 13, 2019, for a failed stack test.
The test results indicated a violation of the NSPS Subpart Dc PM

Canfor Southern Pine—Graham Plant
DAQ 2022-006
Page 3
emissions limit for boiler B-4. The test results indicated a filterable PM
emissions rate of 0.0447 pounds per mill ion Btu which exceeded the
limit of 0.030 pounds per million Btu. A civil penalty of$4,253 was
assessed for this violation and was paid in full.
H. The costs of investigation or inspection in this matter totaled $367.
Based on the above Findings of Fact, I make the following:
II. CONCLUSIONS OF LAW:
A. Canfor Southern Pine—Graham Plant is in violation of Condition IF of Air Quality
Permit No. 06740T22 for not properly operating and maintaining the facility at all times
in a manner that will affect an overall reduction in air pollution and operating an emission
source without the concurrent operation of its associated air pollution control device. The
total amount of time the facility operated boiler B-2 without one of the associated air
pollution control devices was 104 hours.
B. G.S. 143-215.114A provides that a civil penalty of not more than twenty-five thousand
dollars per violation may be assessed against a person who violates or fails to act in
accordance with the terms, conditions, or requirements of a permit required by G.S. 143-
215.108 or who violates any regulation adopted by the Environmental Management
Commission.
C. G.S. 143-215.3(a)(9)provides that the costs of any investigation or inspection may be
assessed against a person who violates or fails to act in accordance with the terms,
conditions, or requirements of a permit required by G.S. 143-215.108 or who violates any
regulation adopted by the Environmental Management Commission.
Based upon the above Findings of Fact and Conclusions of Law, I make the following:

Canfor Southern Pine—Graham Plant
DAQ 2022-006
Page 4
III. DECISION:
Canfor Southern Pine—Graham Plant is hereby assessed a civil penalty of:
$ $" S 2y • for one(1) violation of Condition 3.F of Air
Quality Permit No. 06740T22, occurring on
November 5-9, 2021.
$ 9,9-2 y •°o TOTAL CIVIL PENALTY,which is 3 y
percent of the maximum penalty authorized by
NCGS 143-215.114A.
$ 367 Investigation Costs
$ _ 1, V37. oo TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.114A,in determining the amount of the penalty, I considered the
factors listed in G.S. 143B-282.1(b) and 15A NCAC 2J .0106,which are the following:
1) The degree and extent of harm to the natural resources of the State,to the public
health, or to private property resulting from the violation(s);
2) The duration and gravity of the violation;
3) The effect on ground or surface water quantity or quality or on air quality;
4) The cost of rectifying the damage;
5) The amount of money saved by noncompliance;
6) Whether the violation was committed willfully or intentionally;
7) The prior record of the violator in complying or failing to comply with programs over
which the Environmental Management Commission has regulatory authority; and
8) The cost to the State of the enforcement procedures.
2 5 21 41"-Lk CA C
Date Michael A. Abraczinskas, Director
Division of Air Quality