AQ_F_0100237_20210203_CMPL_NOV-NRE (4)

(''p1t
i iw !/mod
I
y� 1
ROY COOPER NORTH CAROLINA
Governor- Environmental Quality
MICHAEL S.REGAN
secreear-Y
MICHAEL ABRACZINSKAS
Director February 3, 2021
CERTIFIED MAIL NUMBER 7019 1120 0001 5504 6448
RETURN RECEIPT REQUESTED
Mark Blalock, Plant Manager
Canfor Southern Pine- Graham Plant
4408 Mt. Hermon-Rock Creek Road
Graham,NC 27253
SUBJECT: Notice of Violation and Notice of Recommendation for Enforcement
Canfor Southern Pine- Graham Plant
Graham,North Carolina
larrance County
04-0100237-Title V Air Permit No. 06740T22
Dear Mr. Blalock:
Reference is made to the test report for the mercury(Hg), hydrogen chloride(HC1), filterable
particulate matter(PM), and carbon monoxide(CO) emissions testing of the three wood fuel-fired boilers
(ID Nos. B-2, B-3, B-4) conducted August 25-27, 2020 at the above referenced facility. This report was
reviewed by the Technical Services Section of the Division of Air Quality on January 27,2021. Test
results for Boiler 2 (B-2) and Boiler 3 (B-3) indicated compliance with all applicable emission standards.
However, Boiler 4 (B-4) was found to have exceeded the filterable PM emission lirnit of 0.030 Ib/MMBtu,
as specified in 40 CFR Part 60, Subpart De, "Standards of Performance for Small-Industrial-
Commercial-Institutional Steam Generating Units." Results demonstrated filterable PM emissions from
Boiler 4 (B-4)to be 0.034 lb/MMBtu. This is a violation of 40 CFR Part 60, Subpart De, or more
specifically §60.43c(e), as referenced by 15A North Carolina Administrative Code(NCAC) 2D .0524
"New Source Performance Standards" per Condition 2.1.A.4 of Air Quality Permit 06740T22. Please
note that a previous NOV/NRE letter was issued on December 13, 2019 for an exceedance of the
filterable PM emission limit of 0.030 lb/mmBTU as specified in 40 CFR Part 60 Subpart Dc for Boiler 4
(B-4). The results from the stack test conducted on September 10-12, 2019 demonstrated filterable PM
emissions to be 0.447 lb/MMBtu.
Please advise this office in writing no later than February 17, 2021 of the cause of this violation,
what was done to rectify the situation, and what will be done to ensure that this type of violation does not
occur in the future. Please note that another emission test is required in accordance with 15A NCAC 2D
.2600 and General Condition JJ of Air Pen-nit No. 06740T22 to demonstrate compliance with the
filterable PM emission limit of 0.030 Ib/MMBtu for Boiler-4(B-4),
b8µeflln9(lt of[mirunmenlal Qu911ry
North Carolina Department of Environmental(duality Division of Air Quality
winston-salern Regional office 1 450 West Hanes Mill Road.Suite 300 ; WinstorrSalem,North Carolina 27105
336.776.9800 T 336.776 9797 F

Mark Blalock
February 3, 2021
Page 2
Each day that you continue to operate in violation 40 CFR Part 60, Subpart Dc may constitute an
additional violation. Each violation is subject to enforcement action, including a civil penalty of up to
$25,000 and/or injunctive relief, pursuant to North Carolina General Statute(NCGS) 143-215.114A or
permit revocation as authorized by NCGS 143-215.108(b)(3). You may wish to contact the Division of
Environmental Assistance and Outreach at 1-877-623-6748 if you need assistance.
We have prepared a report detailing this violation and intend to forward it to the Division of Air
Quality staff in Raleigh. The report concludes with a recommendation by this office for enforcement
action for the violation of 40 CFR Part 60, Subpart Dc. If you wish to present an explanation for the cited
violation or if you believe there are other factors which should be considered,please send the information
to me in writing within 10 days following receipt of this letter. The information will be reviewed and, if
an enforcement action is still deemed appropriate,your explanation will be forwarded to the Director with
the enforcement package for his consideration.
It should also be noted that the filterable PM results of 0.034 lb/MMBtu for Boiler 4(B-4)
indicated compliance with the limit of 0.037 lb/MMBtu for filterable PM as specified in 40 CFR Part 63,
Subpart DDDDD"National Emissions Standards for Hazardous Air Pollutants for Industrial,
Commercial, and Institutional Boilers and Process Heaters."
Please contact Jim,Hafner at(336) 776-9634 ([e-mail])or me if you have any
questions.
Sincerely,
T. Ray Ste rt, J , P.E., CPM, e Tonal Supervisor
Division of Ai IIIity,NC DEQ
Enclosure
c: WSRO county file
WSRO enforcement file NmTH