AQ_F_0100237_20210219_CMPL_NOV-NRE (4)

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ROY COOPER NORTH CAROLINA
Covernor Environmental Quality
MICHAEL S.REGAN
Secretary
MICHAEL ABRACZINSKAS February 19, 2021
Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Mark Blalock
General Manager
Canfor Southern Pine—Graham Plant
4408 Mt. Hermon-Rock Creek Road
Graham,North Carolina 27253-8909
SUBJECT: Notice of Violation/Notice of Recommendation for Enforcement
40 CFR Part 63, Subpart A Requirements
Canfor Southern Pine—Graham Plant
Graham,Alamance County,North Carolina
Air Permit No. 06740T22
Facility ID No. 0100237
Fee Class: Title V
Dear Mr. Blalock:
The Division of Air Quality(DAQ)has reviewed Canfor Southern Pine's "Semiannual
Title V Air Permit Report," submitted on January 30,2021. The report provided information
about the operation of the facility's continuous opacity monitoring systems (COMS)during the
third and fourth quarters of 2020. Our review of the third quarter report and subsequent email
correspondence confirmed that the amount of monitor downtime was excessive and indicative of
improper operation and maintenance (O&M) of the COMS on Boiler Nos. 2 and 3 (ID Nos. B-2
&B-3). 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.
DAQ considers COMS sources with percent monitor downtime(%MD) greater than 6%
for any single calendar quarter or greater than 3% for two consecutive quarters, to have operated
with improper O&M practices. The failure to exercise proper O&M practices is a violation of
Section 3, General Condition F of Air Quality Permit No. 06740T22; therefore, this letter
serves as a Notice of Violation (NOV) of 15A NCAC 02D .1111 "Maximum Achievable
Control Technology(MACT)" as promulgated in 40 CFR Part 63, Subpart A for not
qE ,
North Carolina Department of Environmental Quality I Division of Air Quality
217 West Jones Street 11641 Mail Service Center I Raleigh,North Carolina 27699-1641
919.707.8400

Mr. Mark Blalock
February 19, 2021
Page 2
complying with the provisions of§63.6 as well as the general duty requirement of
§63.860(d) for Boilers B-2 and B-3.
As a result of the excessive monitor downtime,this letter also serves as a Notice of
Recommendation for Enforcement(NRE). An enforcement report is being prepared by this
office addressing these violations. It is requested that a written response to this NOWNRE be
submitted as soon as possible, but not later than March 30, 2021.The response should
outline the steps that you plan to take or have taken to assure compliance with the
aforementioned requirements at all times.
These violations can result in possible civil penalties as per North Carolina General
Statute 143-215.114A. A civil penalty may be assessed against a company who violates or fails
to act in accordance with the terms, conditions, and/or requirements of any permit issued under
General Statute 143-215.108.
As an additional reminder,this Notice of Violation is required to be referenced in your
facility's annual compliance certification(ACC), in accordance with Section 3, General
Condition P of your Title V permit.
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. Your cooperation and concern for the environment are appreciated. If you should have
any questions,please contact Alan Drake of my staff at(919) 707-8493.
Sincerely,
Stephen G. Hall, Chief
Technical Services Section
Division of Air Quality,NCDEQ
SGH/ad
c: Mark Blalock, Canfor Southern Pine(e-copy)
Kristie Hill, Canfm Southern Pine(e-copy)
Ray Stewart, DAQ WSRO (e-copy and hardcopy)
Gary Saunders,DAQ SSCB (e-copy)
IBEAM Documents, 0100237 (e-copy)