AQ_F_0100237_20220309_ST_STO-Rpt (4)

NORTH CAROLINA DIVISION OF Winston-Salem Regional Office
AIR QUALITY Canfor Southern Pine-Graham Plant
NC Facility ID 0100237
Stack Test Observation Report County/FIPS:Alamance/001
Date: 03/11/2022
Facility Data Compliance Data
Canfor Southern Pine-Graham Plant Observation Date: 3/9/2022
4408 Mt Hermon-Rock Creek Road Observer's Name Thomas Gray
Graham,NC 27253 Operating Status Operating
Lat: 35d 58.8660m Long: 79d 25.0320m Action Code TR/STACK TEST
SIC: 2421 /Sawmills&Planing Mills General PERFORMED,OBSERVED
NAICS: 321113/Sawmills
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 06740/T22
Kristie Hill Mark Blalock Kristie Hill Issued 9/6/2019
HR Manager Plant Manager HR Manager Expires 4/30/2023
[phone] [phone] [phone] Classification Title V
Permit Status Active
Inspector's Signature: DMM Comments:
Date of Signature: VN/n
Emission Sources:
t
mission Pmission Source D"escriptlon s; Control Contro Device Description
Source ID o ,
B-4 One wood fuel-fired boiler(57.6 MC-4 Two multicyclones(36 nine-inch diameter tubes
NSPS Dc; million Btu per hour maximum heat MC-4A and 44 six-inch diameter tubes,respectively)
MACT DDDDD2 input capacity) ESP-4* One electrostatic precipitator
Introduction:
On March 9,2022, Mr.Thomas Gray,Environmental Specialist I, and Mr.Andrew Kormos,Environmental Engineer I,both of the
Winston Salem Regional Office-Division of Air Quality(WSRO-DAQ),contacted Mr. Chase Bridges, Project Manager,of TRC
Environmental Solutions,for the purpose of observing emissions testing at Canfor Southern Pine-Graham plant.The facility's wood
fuel-fired boiler(B-4)is subject to 40 CFR Part 63 Subpart DDDDD, "NESHAP for Major Sources:Industrial, Commercial, and
Institutional Boilers and Process Heaters,"and 40 CFR 60 Subpart Dc,"Standards of Performance for Small Industrial-Commercial-
Institutional Steam Generating Units."The WSRO-DAQ received the protocol submittal form from the facility on January 19,2022.
The PSF was subsequently forwarded to SSCB on January 20 2022,and was approved on February 9,2022.The proposed test
methods are provided in the table below:
Target Pollutant EPA Test No,of Test Run No Sampling Comments .
Method, Test` ns D:uration Pints"
Ru
Stack as;flow"rate,mot_gture ;; 1,2,4 3 Sampling points determined
OZ/CO2 3A by Method 1 verification
Co 10 including absence of cyclonic
3 120 minutes See Comment flow determination and
� Method 7E section 8.1.2 i�terable PM 5
stratification test
Prior Testing:
The facility was issued a NOV/NRE on February 3,2021 for the B-4 exceedance of the 40 CFR Part 60 Subpart Dc filterable PM limit
during the August 25-27,2020 emissions testing.The facility was also issued a similar NOV/NRE on December 13,2019 for the B-4
exceedance of the NSPS Subpart Dc filterable P.M limit during the September 10-12,2019 testing. The WSRO-DAQ received a
response from the facility on March 5,2021 in regard to the NOV/NRE for the failed test which stated the following: Boiler 4 was
shutdown, cleaned out, and thoroughly inspected the week of February 17-24, 2021. The boiler was thoroughly cleaned out and all

mechanical systems inspected including the multicyclones and ESP. The inspections did identify an unusual accumulation of ash
under the grates in the wind box. The ash was partially blocking the grates and most-likely impairing underfire airflow. The ash was
removed and cleaned.In addition, worn seals were noted on the air locks under the multiclones and preheated.All affected air locks
were replaced. The facility believes variable moisture levels in the fuel were contributing to the boiler performance issues. Therefore,
the site has updated the management practices most likely to influence fuel-moisture. The facility also implemented upgrades to the
fuel delivery system, as well as several other preventive measures.The tables as provided in the January 27,2021 memo from SSCB
are provided below:
Table 1-Results
Boiler/ Pollutant Test Results Emissions Limit Standard Compliance
Date
Filterable PM 0.0341b/mmBtu 0.030 lb/mmBtu 60 Subpart Dc No
0.037 lb/mmBtu Yes
B-4 HCl <4.3E-5 lb/mmBtu 0.022 lb/mmBtu 63 Subpart Yes
8/25/20
CO 860.E ppmvdp,3%02 1500 mvd 3%02 DDDDD Yes
Hg 2.4E-7lb/mmBtu 5.7E-61b/mmBtu Yes
Table 2: Test Conditions as reported by Canfor and TRC
Heat Input(M19) F-factor Steam Flow
Boiler/Run mmBtu/hr fuel analysis) lb/hr Opacity,% Oxygen Trim,
Operating Limit 20,853 lb/hr 10% 5.3%
Run 1 50.5 10109 37,411 0.72 6.1
Run 2 52.4 9927 37,250 1.18 5.9
8/25/20 Run 3 49.4 10226 36,366 1.22 5.8
/2
Average 50.7 mmBtu/hr 10087 scf/mmBtu 37,009 lb/hr 1.04% 5.9%
Operating Limit 41,2941b/hr 10% 5.7%
Following repairs,the facility ultimately retested for filterable particulate matter and carbon monoxide on March 17,2021.These
results were ultimately approved by SSCB on December 17,2021,and indicated compliance with all applicable emission standards.
The tables as provided in the review memo are provided below:
Boiler/ Pollutant Test Results Emissions Limit Standard Compliance
Date
Filterable PM 0.0007 lb/mmBtu 0.030 lb/mmBtu 60 Subpart Dc Yes
0.037 lb/mmBtu Yes
B-4 CO 374.9 mvd 3%02 1500 mvd 3%02 63 Subpart Yes
03/17/21
Heat Input 47.4 MMBtu/hr 57.6 MMBtu/hr DDDDD Yes
Steam Rate 37,360 lb/hr 41,400 lb hr Yes
Testim
As mentioned above,Mr. Chase Bridges,of TRC Environmental Solutions,was the lead for the testing.Method 3A for 02/CO2,
Method 10 for CO,and Method 5 for filterable PM were performed in conjunction for three 120-minute runs. Stack gas was extracted
through a heated CEMS probe through an out of stack filter,followed by a heated sample line(maintained 248 degrees Fahrenheit
plus)to a sampling conditioning system,where it is dried before entering the analyzers. According to observations and information
provided by Mr.Bridges,all direct calibrations,bias,and drift checks were within method allowances(Direct Cal<2%of span,bias
<5%of direct cal response,drift<3%of initial bias and final bias).Calibration gases were verified as EPA protocol 1 gases,with
expiration dates on all gases verified to be within range.A CO span of 4482 PPM CO was used,with an 02/CO2 span of 21.27%and
19.32%,respectively,also used.No deviations from the methods occurred according to observations from Mr. Gray.A stratification
check was conducted during run 1 on B-4.Results from the stratification check indicated a less than.5%deviation at each point using
02,allowing single point sampling at the centroid of the stack for the remainder of the runs. Method 1 was verified and double-
checked on site during previous visits by Mr. Gray. Cyclonic flow checks were completed before testing,and results indicated the
stack flow to be laminar as the results of the testing indicated all null angle readings were less than the 20-degree average requirement.
According to field data sheets provided by Mr.Bridges,all applicable requirements of Method 5 were met during testing.Probe and
filter temperature were recorded and maintained at 248±25 degrees Fahrenheit during the testing,with exit temperatures from the
impingers maintained below 68 degrees Fahrenheit.All leak checks were well below the method allowance of 0.02 cubic feet,with all
leak checks being performed greater than or at the highest vacuum achieved during the sampling run.At the completion of each run
(following post-run leak check),the probe and nozzle were brushed and rinsed in triplicate(as well as the front half of the filter bell)
with acetone and placed in sample container No.2(probe/FH filter bell rinse).Isokinetics were doublechecked by Mr.Gray for all
runs and appeared to meet the required 90-110%requirement of Method 5.Preliminary results and pictures are available below.

Process information for the boiler,multicyclones,and ESP as recorded by the facility are provided below also.The NCDAQ
Reference CEMS Methods&Method 5 observers checklist will also be attached.
Boiler 4(134):
Testing Performed on March 9,2022:
Preliminary Results
Run<#, stun Time
CO Wftklyy %Oz . f; C0 3 erret,Ox"' en mdv
1. 08:50- 10:53 431,89 7.39 572.41
2, 11:20-13:23 433.92 7.36 573.65
3 13:45-15:47 334.34 7.44 443.71
.Ayer"a a ', 292.92 1 7.39 1 529.92
• Limit is 1500 ppm @3%02
Observation Checklists:
Page 1 and 2 of the NC DAQ Method 5&Reference CEMS Observation checklists are attached below,respectively.
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Conclusion:
Preliminary.results indicate compliance with the applicable CO emission standards.Compliance with the PM standards will
be determined following gravimetric analysis at the laboratory.The final report will be due to the WSRO-DAQ by May 8,
2022.No deviations from the submitted PSF were observed during the course of the testing.