AQ_F_0100237_20191104_CEM_RptRvwLtr (4)

It
ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretary
MICHAEL ABRACZINSKAS November 4, 2019
Director
Mr. Mark Blalock
General Manager
Canfor Southern Pine—Graham Plant
4408 Mt. Hermon-Rock Creek Road
Graham,North Carolina 27253
SUBJECT: Review of COMS Certification Reports for Boiler 2 and Boiler 3
Canfor Southern Pine—Graham Plant
Graham,Alamance County,North Carolina
Facility ID No. 0100237
Air Permit No. 06740T22
Dear Mr. Blalock:
The Division of Air Quality(DAQ)has reviewed the subject certification test report,
which was submitted upon request by Kristie Hill of your staff on October 25, 2019, for the
following continuous opacity monitoring systems (COMS) installed on Boiler 2 (ID No. B-2)
and Boiler 3 (ID No. B-3):
Source Manuacturer/Model Serial No Parameter Test Date
B-2 Teledyne LightHawk/ 560ES 5603171 Opacity 5/16/2019
B-3 Teledyne LightHawk/ 560ES 5603172 Opacity 5/16/2019
1. The COMS were installed pursuant to 40 CFR, Subpart 63, DDDDD—National Emission
Standards for Hazardous Air Pollutants for Major Sources:Industrial, Commercial, and
Institutional Boilers and Process Heaters (commonly known as the Boiler MACT) and Air
Permit No. 06740T22, Specific Condition 2.2.C.La. The COMS will be used to demonstrate
ongoing compliance with the 10% opacity operating limit(6-minute period, daily block
average) as indicated in Table 4 of the Boiler MACT.
2. The COMS certification reports included the manufacturer design specification tests as well
as field audit specification tests pursuant to 40 CFR 60,Appendix B, Performance
Specification 1 (PS-1). We have reviewed and accept the manufacturer's design tests. The
Nonni CAnou
d6Mmenwpl Wulp�
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
November 4, 2019
Page 2
field audit specification tests were performed by Teledyne Monitor Labs, Inc. and included:
optical alignment assessments, calibration error tests, averaging period tests and system
response time tests conducted April 16-17, 2019; and 168-hour calibration drift tests
conducted May 9-16, 2019.
3. Since the manufacturer design specification tests and field audit test results met the
requirements of PS-1, the COMS operating on B-2 Stack and B-3 Stack are both certified
effective, May 16, 2019.
4. Consistent with Specific Condition 2. 2.C.1.a(2D .1111; 40 CFR 63.7550), your facility
must submit an excess emissions and continuous monitoring system performance report
and/or a summary report. The semiannual report shall be calculated on a quarterly basis and
contain the information required per 40 CFR 63.10(e)(3)(iv). DAQ considers sources whose
percent excess emissions (%EE) and percent monitor downtime(%MD)that are less than 6%
for any single calendar quarter and less than 3% for two consecutive quarters to have
operated with proper operation and maintenance.
If you should have any questions,please contact me at 919-707-8410 or [e-mail].
Sincerely,
1
Alan Drake, Environment 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