AQ_F_0100237_20210426_ENF_Enf-FND

STATE OF NORTH CAROLINA NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL
COUNTY OF ALAMANCE QUALITY
FILE NO. DAQ 2021-007
IN THE MATTER OF: )
CANFOR SOUTHERN PINE - GRAHAM )
PLANT ) CIVIL PENALTY ASSESSMENT
FOR VIOLATION OF: )
40 CFR PART 60, SUBPART Dc )
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 No. 0100237) operates a
lumber mill that processes pine logs into dimensional lumber in Graham, North
Carolina.
B. Canfor Southern Pine - Graham Plant was issued Air Permit No. 06740T22 on
September 6, 2019.
C. Canfor Southern Pine - Graham Plant is subject to 40 CFR Part 60, Subpart Dc
"Standards of Performance for Small-Industrial-Commercial-Institutional Steam
Generating Units" as referenced by 15A North Carolina Administrative Code
(NCAC) 02D .0524 "New Source Performance Standards"per Condition 2.LA.4
of the above referenced Air Quality Permit. According to 40 CFR 60.43c(e)(1),
the facility shall comply with an emission limit 0.030 pounds per million Btu for
filterable particulate matter (PM)for the wood fuel-fired boiler(Emission Source
ID No. B-4) controlled by two multicyclones (Control Device ID Nos. MC-4 and
MC-4A) and one electrostatic precipitator (Control Device ID No. ESP-4).
D. A stack test was performed on the wood fuel-fired boiler(Emission Source ID
No. B-4) on August 25-27, 2020. The results from this test were received on
October 2, 2020, and were reviewed by DAQ's Stationary Source Compliance
Branch on January 27, 2021. According to the results, the filterable PM
emissions were 0.034 pounds per million Btu. This is a violation of 40 CFR Part
60, Subpart Dc.
E. A Notice of Violation and Notice of Recommendation for Enforcement
(NOV/NRE) dated February 3, 2021,was sent to Canfor Southern Pine - Graham
Plant relative to the above noted violation. The certified mailing card indicated
that the letter was received on February 12, 2021. Response letters were received
on February 19, 2021 and March 10, 2021. Per the response letters, the facility
has worked closely with Hurst boiler experts, AC Technical Services and the

Canfor Southern Pine-Graham Plant
DAQ 2021-007
Page 2
manufacturer of the electrostatic precipitator to troubleshoot the system. A re-test
occurred on February 2, 2021. However, operational problems with the fuel
delivery system prevented the valid test runs and the test was postponed. The
boiler was shutdown, cleaned out and thoroughly inspected during the week of
February 17—24, 2021. Based on the troubleshooting to date, the likely cause is
variable moisture levels in the fuel and due to an ash buildup in the windbox.
Upgrades are being made to the fuel delivery system which include replacement
of pulse drive feed control system with a variable drive system along with
replacement of the stoker screws. The ash was removed from the windbox. A re-
test occurred on March 17, 2021, with the final test report being due on April 17,
2021.
F. Air Quality Compliance History:
• A Notice of Violation/Recommendation for Enforcement was issued on
March 26, 2020, 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) 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.
• 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 emissionss limit for boiler B-4.
The test reults indicated a filterable PM emissions rate of 0.0447 pounds
per million Btu which exceeded the limit of 0.030 pounds per million Btu.
A civil penalty of$4,253 was assessed and was paid for this violation.
G. The costs of investigation or inspection in this matter totaled $258.00.
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 40 CFR Part 60, Subpart
Dc for filterable PM emissions rate of 0.034 pounds per million Btu which
exceeded the limit of 0.030 pounds per million Btu occurring on August 25, 2020.
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.

Canfor Southern Pine-Graham Plant
DAQ 2021-007
Page 3
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:
III. DECISION:
Canfor Southern Pine - Graham Plant is hereby assessed a civil penalty of:
$ oUo - Oo for one (1)violation of 40 CFR Part 60,
Subpart Dc, referenced in Condition 2.1.A.4 of
Air Quality Permit 06740T22, occurring on
August 25, 2020.
$ 6°U -00 TOTAL CIVIL PENALTY,which is ((p
percent of the maximum penalty authorized by
NCGS 143-215.114A.
$_258.00 Investigation Costs
$ 41 Z 3 8 • 00 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.
y /L /Z-
Date Michael A. Abraczinskas, Director
Division of Air Quality