AQ_F_0100237_20210624_CMPL_InspRpt (4)

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: 06/24/2021
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 06/24/2021
Inspector's Name Jim Hafner
Inspector's Signature: DMM Operating Status Operating
Compliance Status Violation-emissions
< ,e Action Code FCE
Date of Signature: Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2019 35.14 8.42 74.05 319.28 156.94 24.63 31070.18
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
*Highest HAP Emitted inpounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
02/19/2021 NOWNRE Part 63 -NESHAP/MACT Subpart A General 02/19/2021
Provisions
02/03/2021 NOWNRE Part 60-NSPS Subpart Dc Small Industrial- Pending(approved stack test)
Commercial-Institutional Steam Generating Units
03/26/2020 NOWNRE Part 63 -NESHAP/MACT Subpart A General 03/26/2020
Provisions
03/26/2020 NOWNRE Part 60-NSPS Subpart A General Provisions 03/26/2020
12/13/2019 NOWNRE Part 60-NSPS Subpart Dc Small Industrial- 05/11/2020
Commercial-Institutional Steam Generating Units
Page I of 14

Performed Stack Tests since last FCE:
Date Test Results Test Methods) Source(s)Tested
03/17/2021 Pending
08/27/2020 Violation Method 10,Method 26A,Method 30B,Method 5 B-25 B-3, B-4
PERMITTED SOURCES
Emission Emission Source.Descrption Control Device Control Device Description
Source ID No. I..:
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 Dc; 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 NA NA
INSIGNIFICANT/EXEMPT SOURCES
Emission'Source ID!No Emission Source Description
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
Ms. Kristie Hill, HR Manager of Canfor Southern Pine - Graham Plant was contacted by Jim Hafner, DAQ-WSRO Environmental
Engineer to arrange a compliance inspection of the facility on June 24, 2021. The facility was targeted this year and has a facility
classification of Title V. Ms. Hill had Tim Blalock assist with the inspection with regards to boiler operations. Ms. Hill 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 sawmill and planer mill operate
12 hours per day, 5 days per week, 50 weeks per year. The facility schedules routine shutdowns twice a year, usually in June and
October. The previous compliance inspection was performed on February 26, 2020, by Mr. Hafner and Ryan Dyson, DAQ-WSRO
Environmental Specialist. The facility was issued an NOD letter on March 12, 2020, for failure to conduct an internal inspection on
Page 2 of 14

the bagfilter associated with the planer mill within 12-months of the previous inspection. Except for this noted deficiency,the facility
appeared to be in compliance with all applicable Air Quality rules and regulations at the time of the inspection.
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.1111 (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 sawmill (I-Sawmill) to cut and trim the logs into pieces approximately the size of the final
product. From the sawmill, 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
sent to wood residue storage silos (four total) and subsequently 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. 06740T21 was issued on January 18,2019. The facility also has a natural gas-fired boiler(B-5) listed on the
permit that has not been constructed. Per Mr. Mark Blalock,currently there are no plans to install the boiler. If built,the natural gas-
fired.boiler will be located in the same physical location as former boiler(13-1).
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 sawmill . 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 sawmill and used as fuel in the boilers is
conveyed to three storage silos onsite. The facility collects the wood chips generated in the sawmill and sells it to various industries.
The sawmill operations are enclosed in a building. From the sawmill, 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(131-1-1). The facility submitted a like for like
replacement for cyclone(C-2)via a 502(b)(10)notification on June 9,2021. The replacement is scheduled for the planned shutdown
in October.
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:
Page 3 of 14

Bo�lex eratan Process hate 'iressuxe Oz % Q act % 0 'ac�ty% 'ressure Arop ASP
P � ( ) P Y
Tmpexatuare (lbs/br Steam) (psi) (6 11I
u
Iticyclones
tantan M
eous) I20)
B-2 1428 10,000 2.0
126.1 0.12 389 VAC
55 kVDc
B-3 985 13,000 120.5 Not Not 0.87 2.0 350—385 VAC
Observed Observed 55 kvDc
B-4 1561 35,000 125.9 0.20 3.8 374 VAC
1.8 1 55 KvDc
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 facility also has wood chippers(I-4)listed as exempt/insignificant sources. These were not observed.
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 February 2020 through June 2021 were reviewed. The records appeared to be
sufficient to demonstrate compliance. An annual internal inspection was done on each multicyclone on June 11,2020,and on June 4,
2021,during the plant's annual shutdown. The multicyclones for boiler B-4 were also internally inspected during the week of January
13, 2020. In 2019,this inspection occurred during the week of July 29th. The latest semiannual report was received on January 30,
2021 and indicated compliance with this permit condition. It appears that the facility is in compliance with 21).0504.
Condition 2.1.A.2—This contains the requirements for 21) .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 rule. 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, visible emissions
observations are to be performed once daily to determine if emissions are above normal. In the event emissions are above normal,the
Page 4 of 14

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. Three days of absent observations are allowed per semiannual
period. 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, B-3, and B-4 were observed operating with no detectable visible emissions. Instantaneous opacity
for all three boilers can be viewed from the displays of each continuous emissions monitor(COM). As noted above, all three boilers
had instantaneous opacities below 1%. The daily visible emission observation records were reviewed, and all indicated that none of
the readings were above normal. The facility does daily visible emissions observations on all three boilers (B-2, B-3, and B-4) even
though there are no requirements for boiler (B-4). It was noted that there was no daily visible emissions observation recorded for
April 19,2021. Mr. Blalock could not provide a reason why there was no record for the day. As noted above,the facility is allowed
three days of absent observations per semiannual reporting period. As such, the facility appears to be in compliance with this permit
condition.
The latest semiannual report was received on January 30, 2021 and indicated compliance with this permit condition. 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 if compliance with NESHAP DDDDD is demonstrated. The facility demonstrates 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 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,0.030 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 COM is required in accordance with 40 CFR Part 60, Appendix B "Performance Specifications" and Appendix F "Quality
Assurance Procedures." 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 (0.20%per COM). Fuel usage records were provided and
reviewed during the inspection. Daily fuel usage is written on the back of the strip charts for each boiler. Daily amounts are
handwritten onto a sheet that tracks monthly usage. Data from the daily and monthly record are entered into a spreadsheet. Ms. Hill
maintains the electronic records. The spreadsheet is updated at least monthly.
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 for compliance with the boiler MACT was conducted on September 10, 2019. The results
of this test indicated an exceedance of the NSPS Subpart Dc emission limit 0.030 lb PM/mmBtu. A re-test was conducted on January
30,2020, and the results indicate compliance with NSPS subpart Dc. A subsequent test on August 25,2020, indicated an exceedance
with the emission limit. The re-test conducted on March 17,2021 indicating compliance. The results of tests are provided in the table
below.
Page 5 of 14

Boiler B-4 Emission Testing History
'Vest Date Pollutant,' Test Result ! Ernisslon Limit Coin liance
03/18/2008 0.050 lb/mmBtu No
05/09/2008 0.007 lb/mmBtu Yes
09/10/2019 Filterable PM 0.044 lb/mmBtu 0.030 lb/mmBtu No
01/30/2020 0.0192 lb/mmBtu Yes
08/25/2020 0.034 lb/mmBtu No
03/17/2021 0.00071b/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,testing results were approved in a memorandum by Shannon Vogel of the SSCB dated May 11,2020.
• The August 25,2020,testing results were approved in a memorandum by Shannon Vogel of the SSCB dated January 27,2021.
• The March 17,2021,test results are preliminary and are under review by SSCB.
The facility has installed the COM on boiler B-4 and has been complying with the reporting requirements. Records of excess
emissions are also submitted as part of the semiannual reporting requirements. The COMS report for the second half of CY 2020 was
received on January 30, 2021, and contained copies of the excess emission reports. Alan Drake of the DAQ Raleigh Central Office
reviewed the report and indicated that boiler B-4 was in compliance for the recordkeeping and reporting requirements related to the
COM for boiler B-4 under NSPS Subpart Dc. .
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 must meet the opacity limit of 10%under Subpart DDDDD. Therefore,the boiler should meet the
opacity requirements for 2D .0524 if 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 2D .0524 and 40 CFR 60,Subpart Dc.
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 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 March 2020 through May 2021. Annual internal inspection of the
cyclone and bagfilter were last done November 2, 2019, June 18, 2020, and June 19, 2021. There were no internal inspections done
on the cyclone and bagfilter from June 2018 to November 2019. The NOD letter dated on March 12,2020, was issued for failure to
conduct the required internal inspections within twelve months of the previous one. The facility now schedules the inspections during
the June shutdown. The latest semiannual report was received on January 30, 2021, and indicated compliance with this permit
condition. Compliance is indicated.
Condition 2.I.B.2—This contains the requirements for 21) .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 observations 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
Page 6 of 14

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 not operating as plant personnel were on a break. The cyclone and bagfilter were not in
operation as the bagfilter's magnehelic gauge was at 0 inches w.c. Weekly visible emission observation records from February 2020
through May 2021 were provided and all indicated that none of the readings were above normal. The latest semiannual report was
received on January 30,2021, and 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
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.
l:
D. One natural gas-fired boiler equipped with low-NOx burners and an 02 trim system (ID No. B-5)
i
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. The boiler is expected to comply with the 2D.0503.
Condition 2.1.D.2 —This contains the requirements for 2D .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. The boiler is expected to comply with the 2D.0516.
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.
Page 7 of 14

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
would be 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 monthly.
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 monthly. 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 .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." To comply with the notification requirements of
Subpart DDDDD, the facility is required to submit an Initial Notification to the DAQ not later than 15 days after the actual date of
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 2020 CY emissions inventory with the established air toxic limits.
Source Pollutants Emission Limits 2020 CY Emissions
9.
Boiler B-2 Acrolein 0.00224 lbs/hr 0.0015 lbs/hr
Arsenic 0.478 lbs/12 mos. 0.0022 lbs/yr
Benzene 251.4 lbs/12 mos. 46.2 lbs/yr
Beryllium 0.229 lbs/12 mos. 0.155 lbs/yr
Cadmium 1.31 lbs/12 mos. 0.88 lbs/yr
Chromium 0.005381bs/day 0.003 lbs/day
(nonspecific Cr(VI)compounds
Page 8 of 14

Sau rce ilia Emission!Limits 2020 CY Emissions
Formaldehyde 0.0204 lbs/hr 0.0014 lbs/hr
Nickel 0.0124 lbs/day 0.0084 lbs/day
Phenol 0.000,402 lbs/hr 0.00027 lbs/hr
Boiler B-3 Acrolein 0.00224 lbs/hr 0.0013 lbs/hr
Arsenic 0.478 lbs/12 mos. 0.0025 lbs/yr
Benzene 251.4 lbs/12 mos. 39.4 lbs/yr
Beryllium 0.230 lbs/12 mos. 0.13 lbs/yr
Cadmium 1.31 lbs/12 mos. 0.76 lbs/yr
Chromium 0.0054 Ibs/day 0.006 lbs/day
(nonspecific Cr(VI)compounds
Formaldehyde 0.0204 lbs/hr 0.009 lbs/hr
Nickel 0.0124 lbs/day 0.0072 lbs/day
Phenol 0.000403 lbs/hr 0,00023 lbs/hr
Boiler B-4 Acrolein 0.00449 lbs/hr 0.0034 lbs/hr
Arsenic 0.078 lbs/12 mos. 0.041 lbs/yr
Benzene 504.6 lbs/12 mos. 103.6 lbs/yr
Beryllium 0.459 lbs/12 mos. 0.35 lbs/yr
Cadmium 2.63 lbs/12 mos. 0.32 lbs/yr
Chromium 0.0108 lbs/day 0.0025 lbs/day
(nonspecific Cr(VI)compounds
Formaldehyde 0.04091bs/hr 0.031 lbs/hr
Nickel 0.024951bs/day 0.0035 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 0.9551bs/hr 0.32 lbs/hr
Phenol 0.2814 lbs/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 2020 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.
T oxicAir Pollutant 2Q 07Y1 TPER ! CY2020 Actual Emissions
... acetaldehyde � � 6.8 lbs/hr 0.92 lbs/hr
,�� � W�M
DEHP(Di(2-ethylhexyl)phthalate) 0.63 lbs/day 0.00009 lbs/day
carbon disulfide 3.9 lbs/day 0.25 lbs/day
chlorobenzene 46 lbs/day 0.33...lbs/day.............._..........................
..............
........
....................................__.........................................................................................................................:....................................m..........................................................._...........................................:....................................................................................................................
Page 9 of 14

moo.:.Toxic Air Pollutant 2 .0711 TPER C'Y2020 Actual Emissions
chloroform 290 lbs/yr [ 21.721bs/yr
...:..............
....
................................:_........_..T..........._........................._.......::................._......._.__.:.........:__......_....:......................._.._...._........................_......-......._..........................._....................._................... ....................................._................................................_...................._......................_..............._...........................
hydrochloric acid 0.18 lbs/hr 0.031 lbs/hr
hexane 23 lbs/day 0.56 lbs/day
_ _ _ _.
manganese 0.63 lbs/day 0.053 lbs/day
..........................................................................._............................................._..................................................................................................................._.........................................._.................................................__.....................................
mercury 0.013 1bs/day 0.00063 lbs/day
w4 � methylene chloride 0.39 lbs/hr; 1600 lbs/yr 0.043 lbs/hr;378.3 lbs/yr
MIBK 7.6 lbs/hr;52 lbs/day ; 0.0018 lbs/hr;0.044 lbs/day
......................................................................................................................................................................................................................................................................................................._...................................._...................................
pentachlorophenol 0.0064 lbs/hr;0.063 lbs/day 3.7 x 10-1 lbs/hr;8.89 x 10-1 lbs/day
:_._._..._..V�...�w..���..�W..�. ._._ _.�...,..�_w�...w... �......._..�.._�.�..___w. W.....�_ ..._.__._V..w...�_.v.�.w.�.�_�W�.._..�....M W.W_..w.�.-w�.V.�_. _.._____�_.w...��. .._�...Ww �..--._._._.._.....
styrene 2.7 lbs/hr 0.05 lbs/hr
F � toluene � � 14.4 lbs/hr;98 lbs/day 0.0023 lbs/hr;0.0561bs/day
_.._..._........................:._.._..................................._................:_....._.........:............_.._.........._........................._............._.........m..................................__......_......_............_....................._....m..........................._......._......_.,..................._........_..._...._...._........_..::.....__....._..................:.......__........._....................................._..._..._..._.........
trichloroethylene 4000 lbs/yr 19.61 lbs/yr
vinyl chloride 26 lbs/yr 12.6 lbs/yr
'
xylene 16.4 lbs/hr;57 lbs/day 0.002 lbs/hr;0.054 lbs/da
...................................................................................................._..........................................................................................................................................._.......................�......_......_...................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
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 to demonstrate compliance the HCL and mercury emission limits. A tune-up of each boiler is required
Page 10 of 14

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 kept on-site for
at least 2 years. 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 demonstrates compliance with the applicable emission limits through performance testing. An updated Notice of
Compliance status report was received on April 8,2021.As shown in the table below,boiler(B-4)failed to show compliance with the
NSPS Subpart Dc limit of 0.030 lb/mmBtu during the performance test on August 25,2020. A re-test was done on March 17, 2021.
A preliminary review of the test results shows that Boiler (B-4) complies with the NSPS Subpart Dc limit of 0.030 lb/mmBtu. The
results are currently under review.
Standard -
Test Date Pollutant Test Results Emissra►n L�m�ts Comphance
Filterable PM 0.0007 lb/mmbtu 0.45 lb/mmbtu 2D .0504 Yes
B-4 3/17/21 0.0371b/mmbtu Yes
CO 8380.8 ppmvd@3%02 1500 ppmvd @3%02 MACT DDDD Yes
Filterable PM 0.0028 lb/mmbtu 0.45 lb/mmbtu 2D .0504 Yes
0.037 lb/mmbtu Yes
B-2 8/27/20 HCI <3.91 E-5 lb/mmbtu 0.022 lb/mmBtu Yes
CO 358.7 ppmvd 3%02 1500 ppmvd @3%02 MACT DDDD yes
Hg 2.2E-7lb/mmBtu 5.7E-6lb/mmBtu Yes
Filterable PM 0.016 lb/mmbtu 0.45 lb/mmbtu 2D .0504 Yes
0.037 lb/mmbtu Yes
B-3 8/26/20 HCl <4.1 E-5 lb/mmbtu 0.022 lb/mmBtu MACT DDDD Yes
CO 466.6 ppmvd@3%02 1500 ppmvd @3%02 Yes
Hg 2.5E-7lb/mmBtu 5.7E-6lb/mmBtu Yes
0.030 lb/mmbtu NSPS Dc No
Filterable PM 0.0341b/mmbtu
0.037 lb/mmbtu Yes
B-4 8/25/20 HCl <4.3E-5lb/mmbtu 0.022lb/mmBtu Yes
CO 860.6 ppmvd@3%02 1500 ppmvd 3%02 MACT DDDD Yes
Hg 2.4E-7lb/mmBtu 5.7E-6lb/mmBtu Yes
B-4 1/30/20 Filterable PM 0.0192 lb/mmBtu 0.0301b/mmBtu NSPS Dc Yes
0.0371b/mmbtu MACT DDDD Yes
The following operating limits have been established(steam flow and 02 trim are based on stack test parameters).
So�ut�ce, Parameter 0' eratn �.�mxt Basis
PM and Hg O aci < 10% Table 4 Subpart DDDDD
Steam Flow <20,397 lb/hr 110%of the highest hourly average operating load recorded during most
B-2 recent perforinance test
the 30-day rolling average oxygen content must be maintained at or
02 Trim >5.3% 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 < 19,784 lb/hr 110%of the highest hourly average operating load recorded during most
B-3 recent performance test
the 30-day rolling average oxygen content must be maintained at or
02 Trim >5.3% above the lowest hourly average oxygen concentration measured during
the most recent CO performance test
Page 11 of 14

araree., Parameter O`exatx Dirt, asxs
PM and Hg O aci < 10% Table 4 Subpart DDDDD
Steam Flow <41,294 lb/hr 110%of the highest hourly average operating load recorded during most
B-4 recent performance test
the 30-day rolling average oxygen content must be maintained at or
02 Trim >5.7% above the lowest hourly average oxygen concentration measured during
L I I the most recent CO erformance test
The facility demonstrates 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 not higher than the limits established for each boiler.
The latest compliance report was received on February 1, 2021 (postmarked January 30, 2021) and indicated compliance with
NESHAP Subpart DDDDD. 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 states that the four
wood-fired boilers (B-2, B-3, & B-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).
General Conditions
Conditions 3.I.A&3.I.B 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 March 1,2021. Deviations for COMB monitor downtimes,the failed stack test for boiler B-4 along with
references to NOVs were identified as required.
Condition 3.X contains the 2Q .0207 annual emission inventory requirement. The facility is required to submit an emissions
inventory by July 1"for the previous year. The annual emissions inventory for CY 2020 was submitted via AERO on May 4, 2021
and is currently under review. The CY 2019 Emissions Inventory was submitted on April 17, 2020 and was approved on May 20 ,
2020. 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
Page 12 of 14

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 2.1.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.B.
• 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 (IGen 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.
A log is maintained in the building housing the engine and it lists all the instances the engine operated and the purpose for
operating it. The hour meter read 58.3 hours indicating that the engine ran for 1.4 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
April 5, 2020. Ms. Hill indicated that annual maintenance was scheduled for the following week (6/28—7/2). 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 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.
Page 13 of 14

The NSPS particulate limit for boiler B-4 n permit condition 2.1.A.4.d.ii.states that the limit is 0.03 pounds per million Btu heat input.
This needs to be corrected to 0.030 pounds per million Btu heat input.
COMPLIANCE HISTORY
A Notice of Violation/Recommendation for Enforcement was issued on February 3, 2021, for a failed stack test. The test results
indicated a violation of the NSPS Subpart Dc PM emission limit for boiler B-4. A civil penalty of$4,258 was assessed for this
violation.
A Notice of Violation/Recommendation for Enforcement 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$2457 was assessed for these
violations.
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.
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 emission limit for boiler B-4. A civil penalty of$4,253 was assessed for this
violation.
CONCLUSION
Canfor Southern Pine-Graham Plant appeared to be operating in compliance with Air Quality rules and regulations at the time of this
inspection.
Page 14 of 14