AQ_F_0100237_20200326_CMPL_NOV-NRE (4)

ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretary
MICHAEL ABRACZINSKAS March 26, 2020
Director
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, 2020, as well as additional requested
information related to third quarter opacity monitoring emailed by Kristie Hill of your staff on
March 16, 2020. The report provided information about the operation of the facility's continuous
opacity monitoring systems (COMS)during the third and fourth quarters of 2019. Our review of
the third quarter report and subsequent email, confirmed the amount of monitor downtime was
excessive and indicative of improper operation and maintenance(O&M) of the COMS on
Boilers Nos. 2, 3 and 4 (ID Nos. B-2,B-3 &B-4). Boiler No. 2 operated for 105,960 minutes
with 72,804 minutes (equal to 68.7%) of monitor downtime,Boiler No. 3 operated for 108,540
minutes with 72,912 minutes (equal to 67.2%) of monitor downtime, and Boiler No. 4 operated
for 106,320 minutes with 72,708 minutes(equal to 68.4%) of monitor downtime. The COMS
downtime was attributed to a communication error that caused the data acquisition system to stop
recording opacity readings from the COMS units between July 6, 2019 and August 26, 2019.
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
KURMOMM�EQS
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 26, 2020
Page 2
complying with the provisions of§63.6 as well as the general duty requirement of
§63.860(d)for Boilers Nos.2,3, and 4. Additionally,for Boiler No.4,this is a violation of
15A NCAC 02D .0524 "New Source Performance Standards (NSPS)" as promulgated in 40
CFR Part 60, Subpart A for not complying with the provisions of§60.13.
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 April 30,2020. 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.
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,
2� -,Z- d, d-41
Stephen G. Hall, Chief
Technical Services Section
Division of Air Quality,NCDEQ
SGH/ad
c: Kristie Hill, Canfor Southern Pine(e-copy)
Lisa Edwards, DAQ WSRO
Gary Saunders, DAQ RCO (e-copy)
IBEAM Documents, 0100237 (e-copy)
Central File, Alamance County