AQ_F_0100237_20200226_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: 02/26/2020
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)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Kristie Hill Mark Blalock Kristie Hill MACT Part 63: Subpart DDDD, Subpart
HR Manager Plant Manager HR Manager DDDDD, Subpart ZZZZ
[phone] [phone] [phone] NSPS: Subpart Dc
Compliance Data
Comments:
Inspection Date 02/26/2020
Inspector's Name Jim Hafner
Inspector's Signatur:44_�
Operating Status Operating
Compliance Code Violation-emissions
vvf Action Code FCE
Date of Signature: +°� � � MTH On-Site Inspection Result Deficiency
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2018 42.00 8.36 73.60 309.08 93.18 33.55 30078.02
2017 54.59 10.55 92.88 321.14 122.61 44.60 31252.91
2016 48.65 8.59 75.57 307.88 96.98 39.41 29961.57
*Highest HAP Emitted in pounds
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
12/13/2019 NOV/NRE Part 60-NSPS Subpart Dc Small Industrial- Pending
Commercial-Institutional Steam Generating Units
Performed Stack Tests since last FCE:
Date Test Results Test Method(s) Source(s)Tested
-1'30/2020 Pending
09/12/2019 Violation Method 10,Method 26A,Method 30B,Method 5 B-2,B-3,B-4
Page 1 of 13

PERMITTED SOURCES
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.,. .
Caat�ral.Dev�ce Coataralevxce Aesx► tan
Eu� sso Eu.�ss�a Sauarce D s
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Source ► tQ, lYo.
B-2 One wood fuel-fired boiler(28.7 million Btu MC-2 Two multicyclones(16 nine-inch diameter tubes
NSPS De; per hour maximum heat input capacity) MC-2A and 44 six-inch diameter tubes,respectively)
MACT DDDDD
ESP-2 One electrostatic precipitator
B-3 One wood fuel-fired boiler(28.7 million Btu MC-3 Two multicyclones(16 nine-inch diameter tubes
NSPS De; per hour maximum heat input capacity) MC-3A and 44 six-inch diameter tubes,respectively)
MACT DDDDD
ESP-3 One electrostatic precipitator
B-4 One wood fuel-fired boiler(57.6 million Btu MC-4 Two multicyclones(36 nine-inch diameter tubes
NSPS Dc; per hour maximum heat input capacity) MC-4A and 44 six-inch diameter tubes,respectively)
MACT DDDDD
ESP-4 One electrostatic precipitator
B-5 One natural gas-fired boiler equipped with
PSD; low NOx burners and an 02 trim system NA NA
NSPS,De; (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-1 through K-6 Six steam heated lumber drying kilns NA NA
MACT DDDD
Debarker One enclosed rough log debarker INA INA
INSIGNIFICANT/EXEMPT SOURCES
Em�ssxan SaurceD Na. Emass�an Source Descr�pt�an
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 February 26,2020, Jim Hafner, DAQ-WSRO Environmental Engineer, and Ryan Dyson, DAQ-WSRO Environmental Specialist,
visited Canfor Southern Pine - Graham Plant in Alamance County in order to conduct an unannounced compliance inspection. The
facility was targeted this year and has a facility classification of Title V. The facility contact, Kristie Hill, HR Manager,was not on-
site on the day of the inspection. The inspectors first met with Mark Blalock,Plant Manager. Mr. Blalock had Chad Whitfield, Green
End Superintendent, help facilitate the inspection. In addition to Mr. Whitfield, Nick Blalock and Tim Blalock also assisted the
inspectors with regards to boiler operations. Mr. Blalock 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 onsite operate 24 hours a day, 7
days a week, 50 weeks per year. The saw mill and planer mill operate 12 hours per day, 5 days per week, 50 weeks per year. The
facility schedules routine shutdowns twice a year. The previous compliance inspection was performed on April 10, 2019 by Mr.
Hafner and George Williams, formerly of DAQ-WSRO. The facility appeared to be operating in compliance with all applicable
regulations at that time.
Page 2 of 13

SAFETY
Safety shoes,safety glasses,reflective vest,hard hat and hearing protection are required at the facility. General safety practices should
always be followed.
LATITUDE/LONGITUDE
The latitude and longitude coordinates of the facility were verified and are correctly documented in IBEAM.
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.1109,2D .I 111 (40 CFR 63,Subparts DDDD,ZZZZ,DDDDD),2D.1806,and 2Q .0711.
DISCUSSION
Canfor Southern Pine- Graham Plant is a lumber mill that processes whole pine logs into dimensional lumber. The logs are initially
debarked and then passed through the saw mill to cut and trim the logs into pieces approximately the size of the final product. From
the saw mill, the cut lumber is dried in the facility's kilns (ID Nos. K-1 through K-6), which are heated by steam provided by three
wood-fired boilers (ID Nos. B-2 through B-4). After 22 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). The dust from both the sawing operations and the facility's planer mill is burned in one of
the wood-fired boilers (ID Nos. B-2 through B-4). The facility has a fourth wood-fired boiler(B-1)that has not been operated since
2009. This boiler was removed from the permit when Air Permit No.06740721 was issued on January 18,2019.
Pine logs are first debarked in the enclosed debarker unit. Once the logs are debarked, the bark waste is hauled offsite for disposal,
and the-debarked logs are sent to the saw mill. Logs are processed by band saws and then further cut by a gang saw into 8 or 9 boards.
From-the gang saw, the boards are trimmed and edged. Green wood dust generated in the saw mill and used as fuel in the boilers is
conveyed to three storage silos onsite. The facility collects the wood chips generated in the saw mill and sells it to various industries.
The saw mill operations are enclosed in a building. From the saw mill, the boards are dried in the six kilns. Each kiln has 4 firing
zones. During the inspection five of the six kilns were in operation. Kiln 2 was on hold and not in operation.
Once the boards are dried,they are processed in the planer mill, inspected, and then packaged. The planer unit is enclosed for safety
reasons. The facility has a camera inside of the enclosure to monitor the planer's operations. Emissions from the planer mill are
controlled by a closed loop system consisting of one cyclone(C-2)and one bagfilter(BH-1).
Air Permit No 06740T23 was issued on September 6, 2019 for the addition of a new natural gas-fired boiler. Per Mr.Mark Blalock,
currently there are no plans to install the boiler. He indicated that the earliest that it would be installed is CY 2022. If built, the
natural gas-fired boiler will be located in the same physical location as former boiler(B-1).
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. The daily records are then given to Ms.
Hill and entered electronically. The following operating parameters of the boilers were observed during the inspection:
° O aC ado Pressure ro D
�mass�on Source Caperat�ng ; Process Rate ' Pressure O ;Opacity f�, P ty p ..'
a
UIt�C COAeS
Tem erature: lbs/hr Steam s� l0 6 N1r�.Av '. nstantaneous M
C� ) y
inches z0 ,'.
B-2 1453 15,700 122.7 5.3 0.9 0.81 >10
B-3 1291 16,660 120.5 5.4 2.1 1.54 1.0
B-4 1495 43,000 125.9 6.2 2.7 1.65 4.6
Page 3 of 13

The propane-fired emergency generator(IGen 1)was manufactured by Kohler(Model#C-605, serial#09649)and was not in use at
the time of the inspection. The hour meter read 56.9 hours indicating that the engine ran for 4.7 hours since the last compliance
inspection on April 10, 2019. The generator is used to pump cooling water to each boiler in the event of loss of power to the plant.
Operational logs are located at the generator house.
PERMIT CONDITIONS
Section 2.—Specific Limitations and Conditions
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 April 2019 through February 2020 were provided to the inspectors. The records
appeared to be sufficient to demonstrate compliance. An annual internal inspection was done on each multicyclone during the week
of July 29,2019 during the plant's annual shutdown. The multicyclones for boiler B-4 were also internally inspected during the week
of January 13,2020. The previous inspections were done during the week of August 11,2018. The required semiannual reports were
received on August 1, 2019 (postmarked July 30, 2019) and on January 31, 2020 (postmarked January 30, 2020). Each report
indicated compliance. It appears that the facility is in compliance with 2D.0504.
Condition 2.1.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 is inherently low enough in sulfur to always be in compliance
with this rule.
Condition 2.1.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 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 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. 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 and B-3 were observed operating with no detectable visible emissions. The daily visible emission
observation records were reviewed, and all indicated that none of the readings were above normal. The required semiannual
observation reports were received on August 1, 2019 (postmarked July 30, 2019) and on January 31, 2020 (postmarked January 30,
2020). The reports indicated compliance with the observation requirements. NESHAP Subpart DDDDD limits opacity from boilers
B-2 and B-3 to 10%. Therefore,the boilers should meet the opacity requirements for 2D .0521 as long as compliance with NESHAP
Page 4 of 13

DDDDD is demonstrated. The facility has to demonstrate compliance with NESHAP Subpart DDDDD through continuous opacity
monitors.The facility appears to be in compliance with 2D.0521.
Condition 2.1.A.4 — This contains the requirements for 2D .0524 requirements 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 0.03 pounds per million Btu heat. These standards apply at all times, except during periods of start-up, shutdown and
malfunction.
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.
A continuous emissions monitor(COMS)for the opacity of emissions shall be installed,calibrated,maintained,tested,and operated in
accordance with 40 CFR Part 60, Appendix B "Performance Specifications" and Appendix F "Quality Assurance Procedures." The
Permittee shall be deemed in noncompliance with 15A NCAC 02D .0524 if these requirements are not met for boiler B-4. 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. Fuel usage records were provided and reviewed during the
inspection. The facility keeps an electronic copy of fuel usage using a spreadsheet. The spreadsheet is updated at least monthly. In
2019,a total of 17,600, 17,070,and 40,135 tons of sawdust were combusted in boilers B-2,B-3 and B-4,respectively
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 was also conducted on September 10,2019. The results of this test indicated an exceedance with
of the NSPS Subpart DC emission limit 0.03 lb PM/mmBtu. A re-test was conducted on January 30, 2020 and preliminary results
indicate that the boiler complies with the emission limit for NSPS subpart Dc. The results of tests are provided in the table below.
Test Date ' . 'ollutat. ; Vestteslt, Emssxan. iuraxt :Cam' haace .
03/18/2008 Filterable PM 0.050 lb/mmBtu 0.03 lb/mmBtu No
05/09/2008 Filterable PM 0.0071b/mmBtu 0.03 lb/mmBtu Yes
09/10/2019 Filterable PM 0.044 lb/mmBtu 0.03 lb/mmBtu No
01/30/2020 Filterable PM 0.01921b/mmBtu 0.03 lb/mmBtu Yes
Notes:
• lb/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 results have not been approved to date by the SSCB. A letter dated February 25,2020 from Thomas Gray,WSRO Stack Test Coordinator
indicated preliminary compliance with the emission standard. However,SSCB will make the final determination upon their review.
The facility has installed the COM on boiler B-4 and has been complying with the reporting requirements. Records of excess
emissions were observed. These records are also submitted as part of the semiannual reporting requirements. The facility submitted
the semiannual COMS report for the first half of CY 2019 on July 30,2019,Alan Drake of the DAQ Raleigh Central Office reviewed
the report. Per his review date December 11,2019,he stated that COMS report indicated that there have been no violations of NSPS
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Subpart Dc. The excess emissions reports provided indicated that all were attributed to startup, shutdown, malfunction, or other
exempt emissions. The COMS report for the second half of CY 2019 was submitted on January 31, 2020 (postmarked January 30,
2020)and contained copies of the excess emission reports. This report is currently under review by the DAQ Raleigh Central Office.
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 has to meet the opacity limit of 10%under Subpart DDDDD. Therefore,the boiler should meet the
opacity requirements for 21) .0524 as long as 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 21) .0524 and 40 CFR 60, Subpart Dc based on the preliminary results of the
test on January 30,2020.
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 requirements for controlling particulate emissions from
miscellaneous wood product finishing plants. The planer mill(PM-2)is subject to this regulation. To comply with this regulation,the
planer mill must be controlled by 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.
Monthly external visual inspection records were provided from April 2019 through February 2020. The annual internal inspection of
the cyclone and bagfilter was last done on July 29,2019. The previous internal inspections were done on May 18-19,2018. Since
the 2019 annual inspection was not done within 12 months from the previous one, the facility will be issued a Notice of
Deficiency. The required semiannual observation reports were received on August 1, 2019 (postmarked July 30, 2019) and on
January 31,2020(postmarked January 30,2020).
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 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, and no detectable visible emissions were observed. Weekly visible emission
observation records from April 2019 through February 2020 were provided and all indicated that none of the readings were above
normal. The required semiannual observation reports were received on August 1,2019(postmarked July 30,2019)and on January 31,
2020 (postmarked January 30, 2020). The reports 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 regulation. The regulation 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 any
emission source that may be discharged from vents or stacks. The enclosed rough log debarker is subject to this regulation. Visible
Page 6 of 13

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.
Condition 2.1.D.1 — This contains the requirements for 2D .0503 which requires the facility to limit the emissions of particulate
matter from the combustion of natural gas that are discharged from this source (ID No. B-5) into the atmosphere shall not exceed
0.252 pounds per million Btu heat input. No monitoring/recordkeeping/reporting is required for this permit condition.
According to emission factors published by US EPA, total PM emitted from the combustion of natural gas can be estimated as 7.6
pounds per million standard cubic feet of natural gas burned. Using the standard conversion rate of 1,020 Btu per standard cubic feet
of natural gas,the PM emission rate for natural gas burned in a boiler can be estimated as 0.007 pounds per million Btu. This assumes
that the boiler will be properly operated and maintained. Compliance is demonstrated.
Condition 2.1.D.2—This contains the requirements for 21) .0516 which requires the facility to limit sulfur dioxide emissions from
combustion sources. The rule limits S02 to less than 2.3 pounds per million Btu of heat input. No monitoring/recordkeeping/
reporting is required for this permit condition.
According to emission factors published by US EPA, S02 emitted from the combustion of natural gas can be estimated as 0.6 pounds per
million standard cubic feet of natural gas burned. Using the standard conversion rate of 1,020 Btu per standard cubic feet of natural gas,
the S02 emission rate for natural gas burned in a boiler can be estimated as 5.5 E-4 pounds per million Btu. S02 formation from natural
gas combustion is solely a product of the sulfur content of gas supplied to the source. Pipeline quality natural gas is never expected to
contain enough sulfur to cause compliance issues with the emission limit above. Compliance is demonstrated.
Condition 2.1.D.3—This contains the requirements for 2D .0521 which limits visible emissions from boiler(B-5)to less than 20%
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. No monitoring/recordkeeping/reporting is required for this permit
condition.
Small, well-maintained natural gas-fired boilers do not produce substantial visible emissions under normal circumstances. Because
the permit condition for NESHAP Subpart DDDDD has requirements for good operation,maintenance, and recordkeeping,the boiler
is expected to comply with the opacity limit.
Condition 2.1.D.4—This contains the requirements for 2D .0524 for complying with the NSPS regulations promulgated by the EPA.
Boiler (B-5) is subject to 40 CFR Part 60, Subpart Dc. Notifications of construction and initial start-up apply. In addition, this
Subpart requires that records on the amount of natural gas fired be recorded and maintained on a monthly basis.
The boiler has not been constructed to date and currently there are no plans to install it. Compliance with NSPS Subpart Dc will be
determined once the boiler is installed.
Condition 2.1.D.4—This contains the requirements for 2D .0530 for complying with Prevention of Significant Deterioration which
requires the facility to comply with Best Available Control Technology(BACT). For this boiler,VOC emissions are limited to 0.0054
pounds per million BTU. To achieve this limit,the facility is to employ good work and maintenance practices with no additional add-
on controls. The facility is required to perform periodic inspections and maintenance activities on a daily, weekly, monthly, semi-
annual and annual basis as specified in the permit. The results of monitoring activities are to be kept in a logbook. Summary reports
of the monitoring activities are to be submitted on a monthly basis. Since the boiler has not been installed to date, none of these
requirements apply at this time.
Condition 2.1.D.5 — 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." To comply with the notification requirements of
Supbart DDDDD, the facility is required to submit an Initial Notification to the DAQ not later than 15 days after the actual date of
Page 7 of 13

startup of the of the boiler,and submit an initial Notification of Compliance Status to the DAQ within 60 days of startup. The facility
is required to comply with work practice standards which requires a boiler tune-up every five years. Compliance reports are also due
on a five-year basis and must be submitted electronically via the Compliance and Emissions Data Reporting Interface (CEDRI).
Since the boiler has not been installed to date,none of these requirements apply at this time.
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 2018 CY emissions inventory with the established air toxic limits.
Pnlltants Emassan OR
2a18 CY Ernss�ons
Boiler B-2 Acrolein 0.00224 lbs/hr 0.0015 lbs/hr
Arsenic 0.478 lbs/12 mos. 0.0023 lbs/yr
Benzene 251.4 lbs/12 mos. 45.7 lbs/yr
Beryllium 0.229 lbs/12 mos. 0.15 lbs/yr
Cadmium 1.31 lbs/12 mos. 0.88 lbs/yr
Chromium 0.0053 81bs/day 0.0027 lbs/day
(nonspecific Cr(VI)compounds
Formaldehyde 0.02041bs/hr 0.0084 lbs/hr
Nickel 0.0124 lbs/day 0.012 lbs/day
Phenol 0.000402 lbs/hr 0.0003 lbs/hr
Boiler B-3 Acrolein 0.00224 lbs/hr 0.00098 lbs/hr
Arsenic 0.478 lbs/12 mos. 0.0015 lbs/yr
Benzene 251.4 lbs/12 mos. 29.7 lbs/yr
Beryllium 0.230 lbs/12 mos. 0.10 lbs/yr
Cadmium 1.31 lbs/12 mos. 0.57 lbs/yr
Chromium 0.0054 lbs/day 0.0044 lbs/day
(nonspecific Cr(VI)compounds
Formaldehyde 0.02041bs/hr 0.009 lbs/hr
Nickel 0.0124 lbs/day 0.0054 lbs/day
Phenol 0.000403 lbs/hr 0.00018 lbs/hr
Boiler B-4 Acrolein 0.00449 lbs/hr 0.0035 lbs/hr
Arsenic 0.078 lbs/12 mos. 0.04 lbs/yr
Benzene 504.6 lbs/12 mos. 105.3 lbs/yr
Beryllium 0.4591bs/12 mos. 0.35 lbs/yr
[Cadmium 2.63 lbs/12 mos. 0.32 lbs/yr
Page 8 of 13

Source Polutannts Emiissxan lmits': 2018 C ssia
Y Exnns
Chromium 0.0108 lbs/day 0.001 lbs/day
(nonspecific Cr(VI)compounds
Formaldehyde 0.0409 lbs/hr 0.0321bs/hr
Nickel 0.02495lbs/day 0.003 lbs/day
Phenol 0.000806 lbs/hr 0.0006 lbs/hr
Kilns K-1 -K6 Acrolein 0.2536 lbs/hr 0.13 lbs/hr
Formaldehyde 0.955 lbs/hr 0.31 lbs/hr
Phenol 0.28141bs/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 2018 CY 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.
Toxic Ar 'olutan µ 2Q.a71 TPR µ� C'Y2U18 Actual Exnxssian mm
µ
acetaldehyde 6.8 lbs/hr 0 901bs/hr
DEHP Di 2-eth lhex 1 hthalate 0.63 lbs/da 0.9.00.85 lbs/day
carbon disulfide 3.9 lbs/day 0.24 lbs/day
chlorobenzene 46 lbs/day 0 031 lbs/day
...............
.... w,.. . _.... ._.._._
.._. _�.._.._ ......._
chloroform 290 lbs/yr 20.74 lbs/yr
hydrochloric acid 0.18lbs/hr 0.00561bs/yr
y � m
hexane
23 lbs/da 0 53 lbs/day
__. w.
manganese 0 63 lbs/da `; 0.05 lbs/da
__. Y .. .. Y
mercury 0.013 1bs/day 0.000291bs/day
methylene chloride 0.39 lbs/hr; 1600 lbs/yr 0.041 lbs/hr;361 lbs/yr
_:,_...._..:_.......:_.,.......:._,__.. .........____.................._..........._.............,........_...._......_........._,........................_...................................._.............._.................................._.Y....._........_......_..........._............__......._........................_......_.............w...._..._........_......_.......__..........................._....._ ..._.......................
MIBK 7.6 lbs/hr; 52 lbs/day j 0.000181bs/hr;0.042 lbs/day
_ ...
pentachlorophenol 1 0.0064 lbs/hr;0.063 lbs/day 3.5 x 10-6 lbs/hr;8.4 x 10-5 lbs/day
styrene 2.7 lbs/hr 0 05 lbs/hr
I
toluene 14 4 lbs/hr;98 lbs/day 0.0022 lbs/hr;0.053 lbs/day
trichloroethy. . .. ...............len.....e 4000 lbs/yr 18.73 lbs/yr
......................
vinyl chloride 26 lbs/yr 12 0 lbs/yr
xylene 16.4 lbs/hr;57 lbs/day 0.0013 lbs/hr,0.031 lbs/day
'Y _ .._ .. . .. .
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
Page 9 of 13

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 .I I I I 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 using performance stack testing, fuel analysis, or continuous monitoring systems (CMS), including a continuous
emission monitoring system (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. 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 in order 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
for at least 2 years of occurrence on-site. 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.
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-time
energy assessment was completed on April 30, 2019. The Notification of Compliance Status was received on November 12, 2019.
The facility demonstrated compliance with the applicable emission limits through performance test conducted in September 2019.
The test results and applicable emission limits are shown in the table below.
T Result Ems i n.L1m. m,'1i n
Wx
imam Owt. ss a its o p, a +
..:.� �
Filterable PM 0.00478 lb/MMBtu 3.7E-02 lb/MMBtu Yes
B-2 Carbon Monoxide 503 mvd 3%02 1,500 mvd 3%02 Yes
HCL Equivalent 3.4E-5 lb/mmBtu 2.2E-02 lb/MMBtu Yes
mercury 2.83E-71b/mmBtu 5.7E-061b/MMBtu Yes
Filterable PM 0.031 lb/mm.Btu 3.7E-02 lb/MMBtu Yes
B-3 Carbon Monoxide 1006 ppmvdp,3%02 1,500 ppmvd @ 3%02 Yes
HCL Equivalent 3.4E-51b/mmBtu 2.2E-021b/MMBtu Yes
Mercury 2.96E-71b/mmBtu 5.7E-06lb/1\4MBtu Yes
Filterable PM 0.04471b/mmBtu 3.7E-02 lb/MMBtu Yes'
B-42 Carbon Monoxide 506 mvd 3%02 1,500 ppmvd @ 3%02 Yes
HCL Equivalent 3.7E-5 lb/mmBtu 2.2E-02 lb/MMBtu Yes
Mercury 4.51 E-7 lb/mmBtu 5.7E-06 lb/MMBtu Yes
Page 10 of 13

Source Patlutaut
MI
Test ResuitsxssXpu Limits Cornp�ance
13-2,B-3,B-4 Filterable PM 0.034 lb/mmBtu 0.0371b/mmBtu Yes
Wei hted Avera e 7
1. Compliance with 63 Subpart DDDDD was demonstrated using the weighted average emissions from Boilers B-2,B-3,and B-4
2. Boiler B-4 was re-tested on January 30, 2020 and preliminary results indicated a PM emission rate of 0.0192 lb/mmBtu demonstrating
compliance the emission limit. Canfor does not plan to use the emissions averaging to demonstrate compliance.
The following operating limits have been established(steam flow and 02 trim are based on stack test parameters).
Source HI
Farmeler O eratin Z.imt BasisDO
PM and Hg Opacity< 10% Table 4 Subpart DDDDD
Steam Flow <22,623 lb/hr 110%of the highest hourly average operating load recorded during most
recent performance test
B-2 the 30-day rolling average oxygen content must be maintained at or
02 Trim >5.6% 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 < 19,793 lb/hr 110%of the highest hourly average operating load recorded during most
recent erformance test
B-3 the 30-day rolling average oxygen content must be maintained at or
02 Trim >5.4% above the lowest hourly average oxygen concentration measured during
the most recent COperformance-test
PM and Hg Opacity< 10% Table 4 Subpart DDDDD
Steam Flow <44,340 lb/hr 110%of the highest hourly average operating load recorded during most
recent performance test
B-4 the 30-day rolling average oxygen content must be maintained at or
02 Trim >5.9% above the lowest hourly average oxygen concentration measured during
the most recent CO performance test
The facility plans to demonstrate compliance with each applicable limit through performance testing. Compliance with the above
operating limits have been verified for the following:
• Having the setting for each 02 trim system above the levels as indicated in the table above;
• 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 no higher than the limits established for each boiler.
The first NESHAP Subpart DDDDD compliance report was due on July 30, 2019 for the period between May 20, 2019 and June 30,
2019.This report was received on August 1,2019(postmarked July 30,2049)and indicated compliance. The latest compliance report
was received on January 31,2020(postmarked January 30,2020)and indicated compliance. An updated Notice of Compliance status
report was received on March 6, 2020. This report indicated that the facility plans to demonstrate compliance through performance
testing. The facility appears to be in compliance with NESHAP Subpart DDDDD.
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 basically states that
the four wood-fired boilers (B-2,B-3, & 13-4) 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).
Page 11 of 13

General Conditions
Conditions 3.I.A&3.I.11 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. The facility has not had any excess
emissions that have lasted more than 4 hours and there are no notifications in the facility's file. 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 permit
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 February 28,2020. The facility was requested to re-submit the report to document the deviation for the
late annual internal inspection of the planer mill cyclone and bagfilter. The report was re-submitted and was received on March 3,
2020. The report is currently under review. Compliance with 2Q.0508(n)will be determined pending the review of ACC.
Condition 3.X contains the 2Q .0207 annual emission inventory requirement. The facility was required to submit an emissions
inventory by July 1,2019. The annual emissions inventory for CY 2018 was submitted via AERO on June 19,2019 and the inventory
certification was postmarked on June 25,2019. The inventory was approved by DAQ on August 27,2019. 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 Dc, "Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating
Units"as previously discussed under Condition 2.l.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 Composite
Wood Products"as previously discussed under Condition 2.2.13.
• 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.
• 40 CFR Part 63,Subpart ZZZZ,"National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating
Internal Combustion Engines." The propane-fired emergency engine QGen 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.
The engine is used for the purpose of providing power to the boiler pumps. The engine was not in operation during the
inspection. A log is maintained at the engine and it lists all the instances the engine operated and the purpose for operating it.
Page 12 of 13

The hour meter read 56.9 hours indicating that the engine ran for 4.7 hours since the last compliance inspection on April 10,
2019. 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. Maintenance records show that the engine was last serviced on May 8,
2019. The facility appears to be in compliance with 2D.1111 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 CY2016,CY2017,and CY2018 are provided in the header of this report.
PERMIT CONSIDERATIONS
The requirement for daily visible emission observation for the two wood-fired boilers under 2D .0521 seems redundant now that each
boiler is equipped with a COM as required by NESHAP Subpart DDDDD.
Notifications of construction and 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.
COMPLIANCE HISTORY
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 re-test on January 30, 2020 indicated compliance
pending review from the SSCB. The violation has not been assessed to date.
CONCLUSION
With the exception of the late internal inspection of the planer mill cyclone and bagfilter, Canfor Southern Pine - Graham Plant
appeared to be operating in compliance with Air Quality rules and regulations at the time of this inspection. A Notice of Deficiency
will be issued for not completing an internal inspection of the planer mill cyclone and bagfilter within the required 12-month
period.
Page 13 of 13

3/11/2020 Mail-Hafner,Jim-Outlook
0) Reply all 111 Delete (S) Junk Block
[External] Re: question on boiler operations
KF Kathy Ferry <[e-mail]>
Wed 3/11/2020 12:11 PM I
Hill, Kristie <[e-mail]>; Hafner,Jim
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an
attachment to [e-mail]
Jim,
I have spoken with the site and can offer the following clarifications.
Boiler MACT uses 02 trim readings to establish the 02 trim setpoint for operating the boiler in
a manner consistent with the demonstration of compliance. The 02 trim system measures
oxygen continuously and makes adjustments to the boiler to keep the 02 trim readings as close
as possible to the 02 trim.setpoint. However, it is completely normal and expected for the
instantaneous reading to vary both higher and lower than the setpoint in response to variations
in steam demand, fuel flow and fuel moisture. The regulation acknowledges this by only �
restricting the setpoint and not the instantaneous readings.
The B-2 multiclone pressure drop reading was high at the time of your visit. The lines
connecting the pressure gauge to the upstream/downstream ductwork occasionally get plugged
with ash, and this had occurred the morning of your visit. The site used compressed air to blow
out the lines that afternoon, and the pressure drop readings returned to normal.
l
The ESP power is not directly controlled by the operators for a dry ESP (like the ones at
a
Graham). The original.Boiler MALT regulation set ESP power as a control parameter.; .
however, based on industry feedback, EPA removed this requirement for dry ESPs. ESP power
is now only used as a control parameter for wet ESPs. The final Boiler MACT only monitors
COM to determine ongoing compliance-with PM emission limits on boilers with dry ESPs.
Power levels on a dry ESP vary throughout operation, depending on the internal control system
of the unit. We record the power levels during testing, but the permit does not require these
I parameters to be monitored or recorded during normal operation. The facility has not made any
changes to the settings/operation of the 3 ESPs since testing. We continue to monitor opacity a
through the COMs, as well as operating load. The 02 trim.setpoints are all set to follow the
operating limits established during the demonstration of compliance.
i
I hope this helps. Please let me know if you have any other questions.
- l
Thanks,
Kathy
On Tuesday, March 10, 2020, 08:58:31 AM EDT, Hafner, Jim <[e-mail]>wrote:
Hi Kathy,
i
Perhaps you can provide me with answers to my following questions. I
Du
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