AQ_F_0100237_20200319_CEM_RptRvwLtr (4)

QINM1
ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretary
MICHAEL ABRACZINSKAS Director March 19, 2020
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, 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, 2020, 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 2019. Additional requested information regarding monitor downtime
during the third quarter was provided by Kristie Hill of your staff on March 16, 2020. The
Division of Air Quality(DAQ)has completed its review of the COMS-related information in the
report and has the following comments:
I. 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 .1 111
(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 Air
Permit No. 06740 specific condition 2.1.AA.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.
NORT�CARO�LINA
oewe i of
9.m w Uutlla
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
March 19, 2020
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 .1I11
(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 68.7
4th 0.0 0.0
Boiler B-3 3rd 0.0 67.2
4th 0.0 0.0
Boiler B-4 3rd 0.1 68.4
4th 0.0 0.0
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 2019, a malfunction of the data recording system resulted in high%MD for each of the
boilers. As a result of excessive %MD during the third quarter,your facility may be
subject to an enforcement action beginning with a Notice of Violation (NOV).
4. The first and second 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.
If you should have any questions,please contact me at(919) 707-8493 or [e-mail].
S' cerely,
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