AQ_F_0100237_20200130_ST_STO-Rpt (4)

d
NORTH CAROLINA DIVISION OF AIR QUALITY Winston-Salem Regional Office
Canfor Southern Pine-Graham Plant
Stack Test Observation Report NC Facility ID 0100237
Date: 02/06/2020 Coun /FIPS:Alamance/001
Facility Data Compliance Data
Canfor Southern Pine-Graham Plant Observation Date: 01/30/2020
4408 Mt Hermon-Rock Creek Road Observer's Name:Jim Hafner
Graham,NC 27253 Operating Status Operating
Lat: 35d 58.8660m Long:79d 25.0320m Action Code 23/STACK TEST
SIC: 2421 /Sawmills&Planing Mills General OBSERVED
NAICS: 321113/Sawmills
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact
Permit 06740/T22
Kristie Hill Mark Blalock Kristie Hill Issued 9/6/2019
HR Manager Plant Manager HR Manager Expires 4/30/2023
[phone] [phone] [phone] Classification: Title V
Permit Status: Active
Comments:
Inspector's Signature: I,' ,�j`
Date of Signature: �,J��l�� �'�'` l� MTH
Tested Emission Source:
Emission Source ID No. Emission Source Description Control Control Device Description
Device ID No.
B-4 One wood fuel-fired boiler(57.6 million MC-4 Two multicyclones(36 nine-inch
NSPS Subpart Dc; Btu per hour maximum heat input capacity) MC-4A diameter tubes and 44 six-inch
Case-By-Case MACT' diameter tubes,respectively)
MACT Subpart DDDDD2 ESP-4 One electrostatic precipitator
Introduction•
On January 30,2020,Mr.Jim Hafner,Environmental Engineer II of the Winston Salem Regional Office-Division of Air Quality
(WSRO-DAQ),contacted Mr.Mark Blalock,Plant Manager of Canfor Southern Pine-Graham Plant,for the purpose of observing
the re-test being performed on the facility's wood fuel-fired boiler(B-4).Boiler B-4 is a wood fuel-fired boiler(57.6 million Btu per
hour heat input capacity)controlled by two multicyclones and an electrostatic precipitator(ESP-4). Testing was performed to
demonstrate compliance with 15A NCAC 2D .1109,"1120) Case-By-Case Maximum Achievable Control Technology,"listed in
Permit Condition 2.2.C.1 as well as 40 CFR 60 Subpart Dc,"Standards of Performance for Small Industrial-Commercial-
Institutional Steam Generating Units,"listed in Permit Conditions 2.LA and 2.LB,and 15A NCAC 2D.0504,"Particulates from
Wood Burning Indirect Heat Exchangers,"listed in Permit Condition 2.1.A.Bryce Morgan,Project Manager of TRC
Environmental Solutions,was the leader of the test crew performing the sampling,with Tyler Johnson operating equipment on the
stack.
Background:
The facility originally performed the testing of facility boilers B-2,B-3,and B-4 on September 12, 11,and 10,2019,respectively.
Mr.Thomas Gray,QSTI,Environmental Specialist,and Mr.Davis Murphy,Environmental Engineer II,were present to observe
that testing event.The results from that test were reviewed by DAQ-SSCB,and it was discovered that the facility exceed the
filterable particulate matter(PM)limit of 0.03 lb/MMBtu for 40 CFR 60 Subpart DC on boiler B-4,with the results indicating
compliance for the remaining pollutants.The following table details the results provided in the memo issued from DAQ-SSCB on
November 27,2019:
1

Boiler/Date Pollutant Test Results Emissions Limit Standard Compliance
Filterable PM 0.0447 lb/mmBtu 0.03 lb/mmBtu 60 Subpart Dc No
B-4 0.0371b/mmBtu Yes'
9/10/19 HCl 3.7E-5 lb/mmBtu 0.022 lb/mmBtu 63 Subpart DDDDD
CO 506 mvd 3%02 1500 ppmvdp3%02
Per discussions with Ms.Kathy Ferry,facility consultant,the facility originally hypothesized that there was likely an issue with the
ESP on the unit.The facility contacted the manufacturer,who conducted an internal inspection and indicated that it appeared the unit
was operating as designed,and no issues were apparent.On January 7,2020,Mr.Gray visited the facility to observe the initial
retesting of B-4 for filterable PM.Following the first run,the facility as well as the consultant were concerned due to the appearance
of thick particulate on the Method 5 filter,as well as some heavy particulates in the rinse.After consultation with Mr.Gray, Shannon
Vogel from DAQ-SSCB,and Ms.Ferry,the facility decided not to continue testing as it appeared there were still issues with the ESP
or multicyclones.Following that testing event,the vendor for the multicyclones(MC-4,MC-4A)controlling the boiler were
contacted,and they did indeed find degradation in several tubes of the multicyclones,likely leading to excess particulate loading on
the ESP.The next retesting event was scheduled for January 30,2020,and it was observed by Mr.Hafner.That test will be discussed
in the testing section below.
Testin :
Three 1.5 hour runs of Method 5 for filterable particulate matter were performed on the outlet stack of boiler B-4 on January 30,2020.
Method 1 measurements were confirmed by Mr.Gray during the previous testing,and 24 points were utilized, 12 per port,with a
duration of 3:45 minutes being sampled at each point.During testing,filter bell and probe temperature were maintained within the
method allowance of 248 f25°F.The method-5-meter box had a delta H@ 1.958 and a gamma of 0.9876 and was last calibrated on
June 6,2019.A nozzle with a diameter of 0.276 was utilized for all three runs,with an average K-factor of 3.059.Preliminary field
data indicted isokinetics were maintained between the required 90-110%.All leak checks were observed and within the method
allowance of 0.02 CFM,and pitots were leak checked before and after each run and appeared to be properly installed per Method 2
and in excellent condition.Following post run leak checks,the probe and nozzle,front-half filter bell,and cyclone bypass were rinsed
in triplicate with acetone,then sealed in a glass sample container for the rinse fraction.The Method 5 filter was subsequently removed
and placed in a cleaned petri dish,where it will subsequently be analyzed gravimetrically for filterable PM results.Method 3A was
conducted for molecular weight during the testing. Sample was brought down from a heated CEMS probe and line to a sample
conditioner,where it was subsequently dried and conveyed to the analyzer for O2/CO2 analysis.Direct calibrations and bias checks
were within the 2%of span and 5%of span requirements,respectively as stated in Method 3A.The 02 and CO2 numbers were
approximately 12.158%and 8.5265%respectively.The stack on average was approximately 20.9%Bws(moisture),with a molecular
weight around 30.30 lb/lb mole,and an average velocity and flow of 61.9 ft/s and 14,094 dscfm,respectively.No deviations from the
methods were noted by Mr.Hafner during the testing.
Conclusion:
Results from the testing will be due to the WSRO-DAQ by March 2,2020.The NC DAQ Method 5 observers checklist completed by
Mr.Hafner is attached below.
I
2

NC DAO Source Test Observers Checklist-Particulate Testing EPAA.Methods 1-5
Facility Name/Location:
t"�P,t.1 tie e.
NrtYkwar� tom.
Source Contact/Phone#: Pc, ..
Testing Fir /Contact: '►
`` Gilwat . .t t l t
" ""(t•� � � �4`tW.
lttt 1�1 it ljfl: i
li#1 1 Elitl ltf i
Facility ID/, ource Tested: tr„, , . .l;il I�t ltt
... � ..
Tracking;>Number:
cad C> ling a courtes n the EPA
Test Date: ;. �' 3�,' rZ,,, • � � f
"'j"1 , :, IL "1Z` q W
N 0,
Ask for an explanation to t nygrtestion answered"No".and attach comments to this form nr in yo i report:
A
1.D Method r1 calculated correctly(see reverse side)?
1.2)Cyclonic check completed during test day?(Average of absolute value of all angles<20 degrees'?)
A
MVIMM
2.I)Pitot tube leak check completed after each run?
2,2)Visual;check ofpitot tube heads.-good condition? - yr
2.3)Manometer level and zeroed correctly?
2.4)Static pressure measured during the test day?;, Static Pressure:, inches H2O it
2.5).Barometric pressure recorded and adjusted for elevation?(see:reverse side)
2.6)Pitot tube heads oriented to axis of flue?/Pitot tube perpendicular to.axis of stack? J
2.7),Temperature recorded at each sampling point?
2,8)Miiumum sample of 30`dsef.collected(or per applicable subpart?)(see Vm above)'
3.1)�is molecular weight being assumed?(If yes,and allowed,skip refit of.Method 3)(see reverse side
3.2)Multi point integrated sample/Bag evacuated.and leak free(if applicable).
3.3)Electronic Analyzer;or Orsat(performed in triplicate,analysis consistent'?);(circle)(see reverse sid
3'.4)L'alculate F�/V✓ithin Range'? `3 `'
c
4.1)lob nil H2O in first Z impingers,3rd empty,silica gel;in 4th?`(see reverse for each impinges design.req.)
4.2)Temperature at the exit of impingers/condenser<68 F?(see reverse side).
4,3)Silica,gel In good condition?-Blue-new,Pink-spent(unable to absorb more:H2O),
� L
.5.1)Methods 2-5!run concurrently?Test team accurately recording meferbox data at each sampling point)
5;2)Visually inspect sample nozzle for damage/nozzle opening facing direction of flciw?
5.3)Pre run leak-check,optional(watch)Leak Rate<_0.02cf n?
5.4)Post run leak check,mandatory(watch)Leak Rate s0.02efm?Conducted>_highest vacuum during run?
5.5):Isokinetic rates.between 90%and I I0V�?(see reverse side) K.factor:
5.6)'Filter.and probe temperatures at 248+/-25F(or applicable subpart,such as MATS)? M
5.7a)During a run,was any equipment changed'(ie.filter,nozzle,impinger)Why`?(Do not explain a"No")
5.7b)Was a leak check Performed prior to the equipment change?(May not be applicable)
o'
Y: 4, G Date Calibrated:
5*,8)Meterbox calibration values AhIC .,, 75
"�
"Particulate sample.clean-ups acetone wed"(or water if required by CFR such as MACT MM:)?
of nozzle,probe,and glassware(before thi,filter).rinsed and brushed in triplicate(rninimuni)?
$�n i
'. r holder disassembled on site or transported to lab intact?(circle)
znl acetone blank pmpaued? Volume:of acetone used for cleanup.:
3

i
I