AQ_F_0100237_20200811_ENF_Enf-FND

STATE OF NORTH CAROLINA NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL
QUALITY
COUNTY OF ALAMANCE ) FILE NO. DAQ 2020-019
IN THE MATTER OF: )
CANFOR SOUTHERN PINE— )
GRAHAM PLANT ) CIVIL PENALTY ASSESSMENT
FOR VIOLATION OF: )
40 CFR PART 60, SUBPART A )
40 CFR PART 63, SUBPART A )
AIR PERMIT NO. 06740T22, )
GENERAL CONDITION F )
Acting pursuant to North Carolina General Statutes (G.S.) 143-215.114A, 1, Michael A.
Abraczinskas, Director of the Division of Air Quality(DAQ),make the following:
I. FINDINGS OF FACT:
A. Canfor Southern Pine-Graham Plant(Canfor-Graham,NC)operates a lumber mill
that processes pine logs into dimensional lumber. Canfor - Graham, NC operates
four wood-fired boilers (ID Nos. B-1 through B-4). The DAQ Facility ID Number
is 0100237.
B. Wood-fired boilers B-2,B-3 and B-4 vent emissions through separate stacks that are
continuously monitored for opacity.
C. Canfor - Graham, NC, was issued Air Permit No. 06740T22 (the Permit) on
September 6, 2019, with an expiration date of April 30, 2023, for operation of its
facility located at 4408 Mt. Hermon-Rock Creek Road, Graham,Alamance County,
NC. Air Permit No. 06740T22 was the permit in effect at the time of the violations.
D. Air Permit No. 06740T22 contains the following pertinent provisions:
a. Specific Condition 2.1A.4.a requires wood-fired boiler B-4 to comply with all
applicable provisions of 15A NCAC 02D .0524 (40 CFR Part 60, Subpart Dc -
Standards of Performance for Small Industrial-Commercial-Institutional Steam
Generating Units,which includes Subpart A—General Provisions).The general
provisions 40 CFR Part 60, Subpart A includes the operation and maintenance
(O&M)provisions of 60.11(d) and 60.13(e). 40 CFR 60.13(e)(1) states that all
continuous monitoring systems used for measuring opacity "shall complete a
minimum of one cycle of sampling...and one cycle of data recording for each
successive 6-minute period." Specific Condition 2.1.A.4.g requires Canfor -

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DAQ 2020-019
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Graham, NC to install, calibrate, maintain, and operate a continuous opacity
monitoring system (COMS) on wood-fired boiler B-4 to measure opacity
discharged to the atmosphere.
b. Specific Condition 2.2.C.l.a requires wood-fired boiler B-2, B-3 and B-4 to
comply with all applicable provisions of 15A NCAC 02D .1111 (40 CFR Part
63, Subpart DDDDD - National Emission Standards for Hazardous Air
Pollutants for Major Sources:Industrial, Commercial, and Institutional Boilers
and Process Heaters, which includes Subpart A — General Provisions). The
general provisions 40 CFR Part 63, Subpart A includes the O&M provisions of
63.6 as well as the general duty requirement of§63.860(d).40 CFR 63.8(c)(4)(i)
states that"[a]ll COMS shall complete a minimum of one cycle of sampling and
analyzing for each successive 10-second period and one cycle of data recording
for each successive 6-minute period." Specific Condition 2.2.C.l.p requires
Canfor - Graham, NC to install, calibrate, maintain, and operate a COMS on
wood-fired boilers B-2, B-3 B-4 to measure opacity discharged to the
atmosphere.
c. General Condition F requires the facility to be properly operated and maintained
at all times and that no emission source may be operated without the concurrent
operation of its associated air pollution control device(s)and appurtenances.
E. On January 30, 2020, Canfor-Graham,NC submitted their periodic report entitled,
Semiannual Title V Air Permit Report,to the DAQ Winston-Salem Regional Office
(WSRO).The report indicated there was excessive monitor downtime on wood-fired
boilers B-2, B-3 and B-4 during the third quarter of 2019.
F. On March 16, 2020, Kristie Hills provided additional information upon request via
email which confirmed the reported excessive monitor downtime for the COMS on
wood-fired boilers B-2, B3 and B-4 during the third quarter of 2019. The monitor
downtime for each COMS was attributed to a communication error that caused the
new data acquisition system to stop recording opacity readings between July 6,2019
and August 26,2019.
G. DAQ informed Canfor- Graham,NC in its review letter of March 19,2020,that an
enforcement action,beginning with a Notice of Violation(NOV),might be pursued
for excessive monitor downtime on wood-fired boilers B-2, B3 and B-4 during the
third quarter of 2019.
H. The COMS on wood-fired boilers B-2, B 3 and B-4 were deemed to have operated
with improper O&M practices during the third quarter of 2019 due to reported
monitor downtimes of 68.7% on B-2, 67.2% on B-3 and 68.4% on B-4. It was
determined there were three (3) violations of excessive monitor downtime caused
by one event. An NOV and a Notice of Recommendation of Enforcement (NRE)
was issued to Canfor- Graham,NC on March 26, 2020, for violation of Subpart A
of 40 CFR Part 60, Subpart A of 40 CFR Part 63, and General Condition F of Air
Permit No. 06740T22.

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I. Canfor-Graham,NC submitted a written response to the NOWNRE in a letter dated
April 1,2020.
J. Because of the findings in paragraph H above, this action will account for the
excessive COMS downtimes of wood-fired boilers B-2,B 3 and B-4 during the third
quarter of 2019.
K. Air Quality enforcement history over the past five years:
• On December 13,2019, an NOWNRE was issued for violation of PM emissions
limit pursuant to 40 CFR Part 60, Subpart Dc; A civil penalty in the amount of
$4,253 was assessed on April 16, 2020 and was paid in full.
• On March 12, 2020, a Notice of Deficiency was issued for failure to conduct a
required inspection of cyclone and bagfilter.
L. The costs of investigation and inspection in the matter totaled$449.00.
Based upon the above Findings of Fact, I make the following:
II. CONCLUSIONS OF LAW:
A. Canfor - Graham, NC was in violation of 40 CFR Part 60 Subpart A, 40 CFR Part
63 Subpart A, and Air Permit No. 06740T22, General Condition F for improper
operation and maintenance of their COMS during the third quarter of 2019. A total
of three (3) violations caused by one event is assessed for the COMS installed on
wood-fired boilers B-2, B-3 and B-4.
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.

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Based upon the above Findings of Fact and Conclusions of Law, I make the following:
III. DECISION:
Canfor- Graham, NC is hereby assessed a civil penalty of:
$ 3•o00• dp For violation of 40 CFR Part 60 Subpart A,40 CFR Part 63 Subpart
A,and Air Permit No. 06740T22,General Condition F for improper
operation and maintenance of the COMS unit on wood-fired boilers
B-2, B-3 and B-4 during the third quarter of 2019. A total of three
(3) violations caused by one event is assessed for the COMS
installed on wood-fired boilers B-2,B-3 and B-4.
$ 3,(>00 .oo TOTAL CIVIL PENALTY, which is I percent of the
maximum penalty authorized by G.S. 143-215.114A.
$_ 449.00 Investigation costs.
$ 3,9 41 .OU TOTAL AMOUNT DUE.
Pursuant to G.S. 143-215.114A in determining the amount of the penalty, I have 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(s);
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.
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Date Michael A. Abraczinskas, Direct
Division of Air Quality