AQ_F_0700152_20180501_ST_ProtRvw (4)

ROY COOPER
Governor
MICHAEL S. REGAN
secretary
Nf.1 0.
Air Quality MICHAEL A. ABRACZINSKAS
ENVIRONMENTAL QUALITY Director
May 1,2018
Brian Mellor,NESHAP Program Manager
Power Secure
4068 Stirrup Creek Dr.
Durham,NC 27703
Subject: Food Lion—Washington
Washington,Beaufort County,North Carolina
Facility ID 07/00152,Permit Exempt
Carbon Monoxide(CO)Emissions Testing of Diesel Peak Shaving Engines
ES-1 [1345 US 264 East-Store#144]—CAT Model 3406,519hp/400kW—S/N KPS01092
ES-2 [851 Washington St.-Store#2220]—CAT Model 3406, 519hp/350kW—S/N KPS01093
To be performed by Environmental Source Samplers,Inc. (ESS)
Proposed Test Date: May 8, 2018
DAQ Tracking No. 2018-057st
Dear Mr.Mellor:
The North Carolina Division of Air Quality(DAQ)has reviewed the protocol submittal form(PSF)for
CO emissions testing of the subject engines. The sources are permit-exempt No.2 fuel oil-fired peak
shaving/non-emergency Caterpillar diesel engine/generators located at the subject Food Lion stores.
These engines are greater than 500 brake horsepower(hp)at an existing area source. The proposed
methods are acceptable for the proposed 3-year CO testing.
40 CFR 63 Subpart ZZZZ National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines(RICE NESHAP)applies and limits CO emissions to
23 ppmvd at 15%02 OR requires at least 70%reduction of CO emissions. In addition,Table 2b of
40 CFR 63 Subpart ZZZZ requires maintaining the pressure drop across the catalyst within f2 inches of
water from the pressure drop value established during the initial performance test. Table 2b also requires
maintaining the catalyst inlet temperature>450°F and<1350°F. CO emissions testing must be conducted
every 8,760 hours of operation or 3 years,whichever comes first.
The primary purpose for testing is to demonstrate compliance with 40 CFR 63 Subpart ZZZZ. The
proposed test methods are EPA Method 10 for CO and EPA Method 3A for oxygen/carbon dioxide.
The other purpose of performance testing is to establish or re-establish continuous monitoring parameters.
Those parameters are: catalytic oxidizer inlet temperature and oxidizer differential pressure. Note that
instrumentation used for this monitoring should be calibrated on a regular basis,for example,once per
year. [Continuous oxidizer inlet temperature monitoring,as defined by the rule,is required whenever
these sources are operating. Oxidizer differential pressure(DP)monitoring is required a minimum of
once per month whenever these sources are operating.]
State of North Carolina I Environmental Quality I Air Quality
217 W.Jones Street 1 1641 Mail Service Center I Raleigh,North Carolina 27699-1641
919 707 8400

Mr.Brian Mellor,NESHAP Program Manager
May 1,2018
Page 2 DAQ Tracking No.2018-057st
Approved Test Methods for CO esting,Non-emergency CI RICE>500HP
Target EPA Test No.of Test Test Run No.of Sampling Standard/
Pollutant Method Runs Duration Points Comment Emission Limit
02 3A 3 60 minutes * Concurrent with M10
CO 10 3 60 minutes * 63 subpart ZZZZ <_23 ppmvd @ 15%02
or
Table 2d reduce CO by>70%
* See 40 CFR 63 Subpart ZZZZ Table 4 for the procedure to determine the number of sampling points.
The proposed test methods are acceptable for the specified pollutants. Approval of the protocol does not
exempt the tester from the minimum requirements of the applicable methods and 63 Subpart ZZZZ.
Since no deviations from the applicable methodology were addressed in the protocol,the testing should
be conducted in strict accordance with the requirements EPA Reference Methods 10 and Method 3A.
The rated electrical energy(kW)output of the sources is listed in the Subject. Testing must be conducted
at full load t10%.
Please notify the Washington Regional Office(WaRO)at least 15 days before the actual test date to
provide WaRO the opportunity to schedule a test observer.
The final test report must include the operating rate and supporting documentation(historical operating
data to support maximum normal operation stated if not operated at full load f 10%). Also include control
device parameters inlet temperature and differential pressure across the device. Include the data and
averages for each run and the overall test averages. Record the engine serial No. and record the eng
operating hours meter reading at completion of testing and report them in the final test report. Also report
the engine manufacture date and if reconstructed,the date of reconstruction.
If you have questions,please contact me at(919)707-8412 [e-mail].
Sincerely, �v
James E.Hammond,Environmental Engineer
Division of Air Quality,NCDEQ
cc: Matt Gatian,ESS
Robert Fisher,Washington Regional Office
Central Files,Beaufort County
IBEAM Documents-0700152