AQ_F_0100237_20200416_ENF_Enf-FND

STATE OF NORTH CAROLINA NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL
COUNTY OF ALAMANCE QUALITY
FILE NO.DAQ 2020-006
IN THE MATTER OF: )
CANFOR SOUTHERN PINE -GRAHAM ) CIVIL PENALTY ASSESSMENT
PLANT )
FOR VIOLATION OF: )
40 CFR PART 60, SUBPARTDc )
Acting pursuant to North Carolina General Statutes(G.S.) 143-215.114A, I,Michael A.
Abraczinskas, Director of the Division of Air Quality ("DAQ"or"Division"), make the
following:
I. FINDINGS OF FACT:
A. Canfor Southern Pine -Graham Plant (Facility ID No. 0100237) operates a
lumber mill that processes pine logs into dimensional lumber in Graham,North
Carolina.
B. Canfor Southern Pine -Graham Plant was issued Air Permit No. 06 740T22 on
September 6, 2019.
C. Canfor Southern Pine -Graham Plant is subject to 40 CFR Part 60, Subpart De
"Standards of Performance for Small-Industrial-Commercial-Institutional Steam
Generating Units" as referenced by 15A North Carolina Administrative Code
(NCAC)02D .0524 "New Source Performance Standards"per Condition 2.LA.4
of the above referenced Air Quality Permit. According to 40 CFR 60.43c(e)(1),
the facility shall comply with an emission limit 0.03 pounds per million Btu for
filterable particulate matter(PM) for the wood fuel-fired boiler (Emission Source
ID No.B-4) controlled by two multicyclones (Control Device ID Nos. MC-4 and
MC-4A) and one electrostatic precipitator(Control Device ID No. ESP-4).
D. A stack test was performed on the wood fuel-fired boiler(Emission Source ID No.
B-4)on September 10,2019. The results from this test were received on September
17, 2019 and were reviewed by DAQ's Stationary Source Compliance Branch on
November 27, 2019. According to the results, the filterable PM emissions were
0.0447 pounds per million Btu.This is a violation of 40 CFR Part 60, Subpart De.
E. A Notice of Violation and Notice of Recommendation for Enforcement
(NOV/NRE)dated December 13, 2019, was sent to Canfor Southern Pine -
Graham Plant relative to the above noted violation. The certified mailing card
indicated that the letter was received on December 20, 2019. A response letter
was received on December 27, 2019. Per the response letter, the facility has
worked closely with Hurst boiler experts and the manufacturer of the electrostatic
precipitator to troubleshoot the system. No specific equipment malfunction has
been identified through the system review. The facility also has made a variety of

CanforSouthern Pine—Graham Plant
DAQ 2020-006
Page 2
small adjustments that are expected to improve the performance of the boiler and
control devices. Re-testing will be scheduled to demonstrate the compliance with
the filterable PM emission limit of 0.03 pounds per million Btu.
F. The facility does not have any DAQ related compliance history in the last five
years.
G. The costs of investigation or inspection in this matter totaled $253.00.
Based on the above Findings of Fact, I snake the following:
II. CONCLUSIONS OF LAW:
A. Canfor Southern Pine - Graham Plant is in violation of 40 CFR Part 60, Subpart
Dc for filterable PM emissions of 0.0447 pounds per million Btu which exceeded
the limit of 0.03 pounds per million Btu occurring on September 10, 2019.
B. G.S. 143-215.114A provides that a civil penalty of not more than twenty-five
thousand dollars per violation may be assessed against a person who violates or
fails to act in accordance with the terms, conditions,or requirements of a permit
required by G.S. 143-215.108 or who violates any regulation adopted by the
Environmental Management Commission.
C. G.S. 143-215.3(a)(9) provides that the costs of any investigation or inspection
may be assessed against a person who violates or fails to act in accordance with
the terms, conditions, or requirements of a permit required by G.S. 143-215.108
or who violates any regulation adopted by the Environmental Management
Commission.
Based upon the above Findings of Fact and Conclusions of Law, I make the following:
III. DECISION:
Canfor Southern Pine -Graham Plant is hereby assessed a civil penalty of:
$ y Do •00 for one (1)violation of 40 CFR Part 63,
Subpart Dc,referenced in Condition 2.1.A.4 of
Air Quality Permit 06740T22, occurring on
September 10, 2019.
$ �� 00-o 0 TOTAL CIVIL PENALTY,which is
percent of the maximum penalty authorized by
NCGS 143-215.114A.
$ 253.00 Investigation Costs
$ t 2 15'3 • 00 TOTAL AMOUNT DUE

Canfor Southern Pine—Graham Plant
DAQ 2020-006
Page 3
Pursuant to G.S. 143-215.114A, in determining the amount of the penalty, I considered the
factors listed in G.S. 143B-282.1(b) and 15A NCAC 2J.0106, which are the following:
1) The degree and extent of harm to the natural resources of the State,to the public
health, or to private property resulting from the violation(s);
2) The duration and gravity of the violation;
3) The effect on ground or surface water quantity or quality or on air quality;
4) The cost of rectifying the damage;
5) The amount of money saved by noncompliance;
6) Whether the violation was committed willfully or intentionally;
7) The prior record of the violator in complying or failing to comply with programs over
which the Environmental Management Commission has regulatory authority; and
8) The cost to the State of the enforcement procedures.
14 / , Z� C -
Date Michael A. Abraczinskas, Director
Division of Air Quality