AQ_F_0100237_20191211_CEM_RptRvwLtr (9)

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ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretary
MICHAEL ABRACZINSKAS December 11, 2019
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 2019 Semiannual COMS Report,First 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 July 30, 2019, from Canfor
Southern Pine's Graham Plant. The report included an assessment of the continuous opacity
monitoring system (COMS)that operated on Boilers Nos. 2, 3 and 4 (ID Nos. B-2, B-3 &B-4)
during the first half of 2019. The Division of Air Quality(DAQ)has completed its review of the
COMS-related information in the report and has the following comments:
1. Certification reports for wood fuel-fired boilers B-2 and B-3 were reviewed in my letter of
November 11,2019, which certified the COMS effective May 16, 2019. Thus,both COMS
operated about two weeks in the first half of 2019.
2. 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.
3. Wood fuel-fired boiler B-4 was also reviewed for compliance with the underlying opacity
standard set forth at NCAC 2D .0524 (40 CFR Part 60, Subpart Dc—Standards of
Performance for Small Industrial-Commercial-Institutional Steam Generating Units) and Air
Permit No. 06740 specific condition 2.1.AAA. The COMS report indicated there were no
violations of the applicable standard. Excess emissions from the wood-fired boiler were
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
December 11,2019
Page 2
attributed to either startup, shutdown, malfunction, or other exempt emissions. These
emissions were reviewed and allowed in accordance with applicable monitoring rules.
4. 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 .l 111
(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)were reported as follows:
SourceQuarter %EE %MD
Boiler B-2 1st - -
2nd 0.0 0.0
-
Boiler B-3 1st -2nd 0.0 0.0
Boiler B-4 I st 0.0 0.0
2nd 0.1 0.4
Each of the COMS units appear to indicate the use of good O&M practices for minimizing
emissions since quarterly%EE and%MD were less than'6% for any single calendar quarter
and less than 3%for two consecutive quarters.
5. The first and second quarter audits of the COMS unit were reviewed in accordance with
Procedure 3 of 40 CFR Part 60,Appendix F - Quality Assurance Procedures. The QA test
results for the COMS appear to have met the quarterly specifications.
If you should have any questions, please contact me at [phone] or [e-mail].
S'ncerely,
I
Alan Drake, Environmental Engineer
Division of Air Quality,NCDEQ
c: Kristie Hill, Canfor Southern Pine(e-copy)
Lisa Edwards, DAQ WSRO
Gary Saunders, DAQ RCO
IBEAM Documents, 0100237
Central File, Alamance County