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ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretary
MICHAEL ABRACZINSKAS February 16, 2021
Director
Mr. Mark Blalock
General Manager
Canfor Southern Pine—Graham Plant
4408 Mt. Hermon-Rock Creek Road
Graham,North Carolina 27253-8909
SUBJECT: Review of 2020 Semiannual COMS Report, Second Half
Canfor Southern Pine—Graham Plant
Graham, Alamance County,North Carolina
Air Permit No. 06740T22
Facility ID No. 0100237
Dear Mr. Blalock:
Thank you for your timely submittal of the subject report, dated January 30, 2021, from Canfor
Southern Pine's Graham Plant. The report included an assessment of the continuous opacity
monitoring systems (COMS)that operated on Boilers Nos. 2, 3 and 4 (ID Nos. B-2, B-3 & B-4)
during the second half of 2020. Additional requested clarification regarding monitor downtime
was provided by Kathy Ferry on February 15, 2021. The Division of Air Quality(DAQ)has
completed its review of the COMS-related information in the report and has the following
comments:
1. Wood fuel-fired boilers B-2, B-3 and B-4 were reviewed for compliance with the 10%
opacity operating limit(6-minute period, daily block average) set forth in NCAC 02D .1111
(40 CFR, Subpart 63, DDDDD—National Emission Standards for Hazardous Air Pollutants
for Major Sources:Industrial, Commercial, and Institutional Boilers and Process Heaters)
and Air Permit No. 06740, Specific Condition 2.2.C.La. The COMS report indicated there
were no violations of the applicable standard.
2. Wood fuel-fired boiler B-4 was also reviewed for compliance with the 20% opacity limit
(6-minute period) set forth at NCAC 02D .0524 (40 CFR Part 60, Subpart Dc—Standards of
Performance for Small Industrial-Commercial-Institutional Steam Generating Units) and
Specific Condition 2.1.A.4.d. The COMS report indicated there were no violations of the
applicable standard. Excess emissions from the wood-fired boiler were attributed to either
startup, shutdown, malfunction, or other exempt emissions. These emissions were reviewed
and allowed in accordance with applicable monitoring rules.
NORTH CAROHNAD_E Q
Depart-1,of Environmental Duality
North Carolina Department of Environmental Quality I Division of Air Quality
217 West Jones Street 1 1641 Mail Service Center I Raleigh,North Carolina 27699-1641
919.707.8400

Mr. Mark Blalock
February 16, 2021
Page 2
3. A review was also conducted for compliance with good operation and maintenance (O&M)
practices pursuant to NCAC 2D .0524 (NSPS Dc, including Subpart A - General Provisions),
40 CFR 60.11(d), 40 CFR 60.13(e), and Specific Condition 2.1.A.4;NCAC 2D .1111
(NESHAPS DDDDD including Subpart A - General Provisions), 40 CFR 63.7500(a), 40
CFR 63.8(c)(4), and Specific Condition 2.2.C.1. When compared to the total operating time
of the boilers,percent excess emissions (%EE) and percent monitor downtime (%MD)were
reported as follows:
Source Quarter %EE %MD
Boiler B-2 3rd 0.0 11.0
4th 0.0 0.5
Boiler B-3 3rd 0.0 11.4
4th 0.0 2.4
Boiler B-4 3rd 0.0 0.1
4th 0.1 0.1
Unless otherwise specified in regulation, DAQ considers sources to have operated with good
O&M if the %EE and%MD are less than the target criteria of 6% for any single quarter and
less than 3% for two consecutive quarters. The facility indicated that during the third quarter
of 2020, a power outage impacted the data feeds from the COMS units to the data acquisition
system. Consequently, data communication from boilers B-2 and B-3 did not reset properly
causing data loss for a significant period of time. As a result of the excessive %MD during
the third quarter of 2020,your facility may be subject to an enforcement action
beginning with a Notice of Violation (NOV).
4. The 2020 third and fourth quarter audits of the COMS units were reviewed in accordance
with Procedure 3 of 40 CFR Part 60, Appendix F - Quality Assurance (QA)Procedures. The
QA test results for the COMS appear to have met the quarterly specifications.
Due to COVID-19 restrictions on DAQ staff and our office operations, the mailing of this letter
may be delayed. In the meantime, an electronic copy(e-copy) is being provided for your records.
If you should have any questions,please contact me at(919) 707-8493 or [e-mail].
Sincerely,
Alan Drake, vironmental ngineer
Division of Air Quality,NCDEQ
c: Mark Blalock, Canfor Southern Pine (e-copy) Gary Saunders, DAQ SSCB (e-copy)
Kristie Hill, Canfor Southern Pine (e-copy) IBEAM Documents, 0100237 (e-copy)
Ray Stewart, DAQ WSRO (e-copy) Central File, Alamance County