AQ_F_0100237_20191213_CMPL_NOV-NRE (4)

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ROB'COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretary
MICHAEL ABRACZINSKAS
Director December 13, 2019
CERTIFIED MAIL NUMBER 7013 1710 0002 1865 8086
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
Alamance 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 September 10-12, 2019 at the above referenced facility. This report
was reviewed by the Technical Services Section of the Division of Air Quality on November 27,2019.
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 limit of 0.03
lb/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 0.447 lb/MMBtu. This is a violation of 40 CFR Part 60, Subpart Dc, or more
specifically §60.43c(e), as referenced by 15A North Carolina Administrative Code (NCAC) 2D .0524
"New Source Performance Standards"per Condition 2.LAA of Air Quality Permit 06740T22.
Please advise this office in writing no later than December 27, 2019 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 Permit No. 06740T22 to demonstrate compliance with the
filterable PM emission limit of 0.03 lb/MMBtu for Boiler 4 (B-4).
Each day that you continue to operate in violation 40 CFR Part 60, Subpart De 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.
w ._
De of En_vironmental Quality
North Carolina Department of Environmental Quality I Division of Air Quality
Winston-Salem Regional Office 1 450 West Hanes Mil[Road,Suite 300 Winston-Salem,North Carolina 27105
336.776.9800 T 1 33&776,9797 F

Mark Blalock
December 13, 2019
Page 2
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 0.447 lb/MMBtu for Boiler 4(B-4)were
above the limit of 0.0371b/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." However, §63.7422 specifies that"if you have more than one
existing boiler at your facility, you may demonstrate compliance by emissions averaging if your averaged
emissions are not more than 90 percent of the applicable emission limit."According to the test report,the
weighted average filterable PM emission rates for B-2,B-3, and B-4 were 0.034 lb/MMBtu, indicating
compliance with the applicable standard.
Please contact Jim Hafner or me if you have any questions.
Sincerely,
Lisa Edwards, P.E., Regional Supervisor
Division of Air Quality,NCDEQ
c: WSRO county file
WSRO enforcement file mTH