AQ_F_0800107_20170925_CMPL_InspRpt

ORTH CAROLINA DIVISION OF Washii:�.rn Regional Office
AIR QUALITY W.E. Partners II,LLC-Lewiston Woodville
NC Facility ID 0800107
Inspection Report County/FIPS: Berrie/015
Date: 1 0102/2 0 1 7
Facility Data Permit Data
W.E. Partners 11, LLC- Lewiston Woodville ✓ Permit 10126/R03
3539 Governors Road Issued 12/8/2016
Lewiston Woodville,NC 27849 Expires 11/30/2024
Lat: 36d 8.3590m Long: 77d 13.3450m Classification Synthetic Minor
SIC: 4961 /Steam Supply Permit Status Active
NAICS: 22133 /Steam and Air-Conditioning Supply Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Cntact SIP
/ MACT Part 63: Subpart 6.1
Garald Cottrell Garald Cottrell Garald Cottrell NSPS: Subpart Dc
President President President
[phone] [phone] [phone]
Compliance Data
Comments: The facility appeared to operate in compliance with the permit
conditions and applicable regulations at the time of the inspection. Inspection Date 8/10/2017, 8/23/2017,09/25/2017
Inspector's Name Betsy Huddleston and
Inspector's Signature: David Harwood
Operating Status Operating
Compliance Code Compliance-inspection
Date of Signature: Action Code FCE
10 / 6 /17 On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2014 35.28 359.38 1254.53 72.76 1913,77 24.25 1697.70
* Highest HAP Emitted(in ounds)
Five Year Violation History:
Date Letter Tyne Rule Violated Violation Resolution Date
06/07/2017 NOV Permit Permit Condition 06/07/2017
1 1/22/2016 NOWNRE 2D .I I I I Maximum Achievable Control Technology 03/24/2017
05/12/2015 NOWNRE Part 63 -NESHAP/GACT Subpart JJJJJJ Industrial, 06/12/2015
Commercial and Institutional Boilers at Area Sources
Performed Stack Tests since last FCE:
Date Test Results Test Methods) Source(s)Tested
05/04/2017 Pending 5/202,7E and 10 ESB-I,ESB-2, ESB-3
Directions
From Washington take Highway 17 North to Windsor,and then turn left onto Highway 308W at the
second stoplight in Windsor(Bill Clough Ford dealership is on the right). Stay on Highway 308 through
Lewiston Woodville. Turn left at the Perdue chicken processing plant and drive down to the Valley
Prot ins rendering plant. W.E. Partners II is located directly in front of the rendering plant.

r 1 r'I
General Facility Summary
W.E. Partners II, LLC is a subsidiary of Wellons Energy Solutions, LLC. It is a biomass cogeneration
facility. It supplies steam to the Valley Proteins rendering plant(Facility ID 0800081). Steam is also
used to heat wastewater treatment system for both Valley Proteins and Perdue(ID 0800109) during cold
months. The facility has one 500 kW turbine that supplies power to the grid. The facility began
operation on 1/]7/2012.
Safety Concerns
Required safety equipment includes hard hat, hearing protection, safety glasses, and steel-toe shoes.
Permit History
• Permit ROO was issued on December 29,2010 for a greenfield facility.
• Permit RO1 was issued on Nov. 28, 2011 for the following modifications:
- Addition of cotton gin residues, soybean hulls and peanut shells as biomass fuel.
- Addition of an electrostatic precipitator to further control particulate emissions from the boilers.
The ESP was installed to meet the Boiler GACT particulate limit for new biomass boilers (sized
between 10-30 MMBtu/hr).
- Increase in the synthetic minor annual fuel consumption limit.
• Permit R02 was issued on 06/12/2013 for the following changes:
- Changed each boiler description to`one clean cellulosic biomass-fired boiler." The permit
included approval to buns screened turkey poultry litter wood shavings. Also added definition of
"clean cellulosic biomass"per 40 CFR 241.2 and 241.3 and a permit condition for adding new
fuels under this definition.
- Removed Specific Condition No. 9 because the testing has been completed.
- Updated the monitoring requirements for the ESP and the performance testing requirements to
reflect changes in 40 CFR 63, Subpart JJJJJJ, as issued in the Federal Register on 2/01/2013.
- Updated the synthetic minor condition to include the tested CO emission rate(dated June 19,
2012) in the calculations for compliance with 2Q.0315.
- Removed permit conditions for toxics. Because the boilers are NESI4AP Subpart JJJJJJ
applicable,the facility is no longer required to review toxics for them.
• Applicability Determination No. 2546—NHSM determination for creosote railroad ties was issued to
W. E. Partners on 1/07/2015. The ties met the legitimacy criteria under 40 CFR 24 L3(d)(1).
• Applicability Determination No. 2596-Secondary Material Determination for creosote telephone
poles was received by DAQ on 3/16/2015. The determination was issued by DAQ on 6/05/2015.
The poles met the legitimacy criteria under 40 CFR 241.3(d)(1).
• Permit renewal R03 was issued on 12/08/2016. S133 BACT conditions were added to the permit.
The Boiler GACT Subpart W conditions were updated to reflect revisions to the regulation.The fuel
bunker was removed from the permit and added to the insignificant activities attachment.
Inspection Observations and Regulatory Review
On 8/10/2017 David Harwood and I conducted an inspection of the facility with the assistance of Mr.
Chad Hoggard(cell number 252-287-5097). I requested a number of records that I agreed for them to
email me. Some of those records were supplied by email on 8/23/2017,and the remainder was
supplied by email on 9/25/2017.
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The following sources are incl,..ed on the permit and Insignificant/Exempt. .,;tivities attachment to
the permit:
Permitted Sources
Emission Emission Source Control Device Control System
Source ID Description ID Description
ESB-1 done clean cellulosic biomass-fired boiler MC-1 multi-cyclone
(NSPS, ;(29.4 million Btu per hour maximum heat (18 tubes,each 9 inches in diameter)
NESHAP) input)
ESP-, electrostatic precipitator
�(9,222 sq ft total collection plate area,
j Itwo fields with 60 kv charge per field)1
ESB-2 one clean cellulosic biomass-fired boiler MC-2 �mul[i-cyclone
(NSPS, (29.4 million Btu per hour maximum heat 1(18 tubes,each 9 inches in diameter)
NESHAP) in 1
ESP-1 electrostatic precipitator
(9,222 sq ft total collection plate area,
two fields with 60 kv charge per field)
ESB-3 mu one clean cellulosic biomass-fired boiler MC-3 lti-cyclone
(NSPS, (29.4 million Btu per hour maximum heat (18 tubes,each 9 inches in diameter)
NESHAP) input)
ESP-1 electrostatic precipitator
(9,222 sq ft total collection plate area,
two fields with 60 kv charge per field)
Insignificant Source
Source Exemption Source of Title V
Source of TAPS?
Regulation Pollutants?
ISB-1 -Green wood fuel storage bunker 2Q .0102(h)(5) j No Yes
The facility generally operates 6 days a week, with Sunday as the down day. They were cleaning the
boilers(600 hp each)one at a time the day we performed the inspection(they do cleanouts every
Thursday). None of them were in operation at the beginning of the inspection (no fuel was added). By
the end of the inspection one boiler was in operation with steam production at 11.79 KPPH
They were combusting green wood chip and screened turkey litter at an approximately 40/60 ratio during
the inspection. The facility began burning the turkey litter in February 2014. Their supplier is Butterball,
which has a yard in Wallace,NC, where the litter is screened before shipping. W.E. Partners screens it
again at a yard they own at a separate location. Chad said they do see some non-combustible material in
the litter even after double screening. They try to minimize it as much as possible because it creates a lot
of ash. The facility is not currently purchasing railroad ties.
The turbine was not in operation during the inspection. Chad said they have been running the turbine
most of the time in the last year.
Daily fuel is calculated by backing out from steam production. Each day their computer system auto-
generates a report of the hourly steam production. A monthly report is also generated. The daily and
monthly steam/fuel reports are identical to those at the Cofield facility. Example daily steam reports are
attached to the file copy of this report and saved to the WaRO LAN at
G:\AQ\Shai-ed\BertieO8\00107\AQ16s.
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Daily and monthly fuel use is also tracked through truck weight tickets. Wood tickets by supplier are
tallied weekly in a spreadsheet and then summed monthly. Mr. Hoggard noted that the litter tickets are
stored and summed monthly. The ticket weights for January through June 2017 and the week before our
inspection are attached to the file copy of this report and are saved on the WaRO LAN at
G•\AO\Shared\Bertie08\00107\AO16s\20170823 Fuel Totals 2017.xlsx and ....\20170823 Copy of July
31-Aup-4 loads.xlsx. 13,436 tons of litter have been consumed January-July 2017. 10,655.3 tons of
wood chip have been burned January-July 2017. At total of 44,123 tons of blended fuel was combusted
in CY2016.
The inventory runs fairly constant into the bunker,so fuel usage is considered equal to the tons of fuel
received. They aim for the monthly calculated and weighed tonnages to be close, but not exact(within
10%).
The fuel bunker has large augers and moving floor grates that carry the wood chip under the floor to the
boiler room. Litter is sectioned off in the bunker. The boiler controls are set so that augers and floor
grates will automatically adjust the feed rates for the different biomass fuels to the required percentages.
W.E. Partners supplies 70-80%of the steam demand at the rendering plant. W.E. Partners is not capable
of snaking enough steam to supply 100% if Valley is in full production. Valley Proteins usually operates
one of their boilers. On a continuous full operation day the total Valley Proteins Plant steam demand
averages about 75,000-80,000 lbs/hr. Mr. Cottrell emailed on 8/23/2017 that the plant has been averaging
3.4 lbs steam/lb wood. They averaged about 3.49 lbs steam/lb wood for CY2016.
The amount of steam produced at W.E.Partners is dependent on the demand from Valley Proteins. The
rendering plant does not necessarily operate all equipment all of the time. Only the feather dryer was in
operation during the inspection. Once one of the boilers came online, the stack temperature from the ESP
was 299°F. The combined steam pressure was 120 psi. The boiler in full operation had a draft of-0.51
in H2O.
The multiclones are inside the building with the boilers. There are small doors at the base of the
multiclones that can be easily opened to observe dust as it falls out. A truck is filled with the ash and it is
carried to the landfill. They also have an ash bin for backup storage, and a small roofless, 3-sided
retaining wall for ash storage. There were a few clinkers on top of the pile still smoking.
I observed the following instantaneous TR field data for the ESP on the operator control panel during the
inspection:
Field 1 Field 2
Voltage(kV) 31.5 49.5
Current(mA) 5 304
S ark Rate(spin) 0 29
The ESP will throttle back on one TR set if the other is sufficiently carrying the particulate load. The
system is designed to operate efficiently(i.e. minimize power). We observed the TR Field 2 secondary
power on the control panel at 8-9 kW. The 12-hr average secondary power for the previous day was 6.3
kW in the AM and 6.3 kW in the PM.
2D.0202 "Registration of Air Pollution Sources"
This Rule gives the Director the authority to require the registration of air pollution sources, and require
theta to submit information about the source. It is under this Rule that the Division is requiring facilities
to submit an emissions inventory 90 days before a Permit expires. W.E. Partners will owe a 2023
emissions inventory with their next permit renewal application.
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2D.0504 "Particulates from Wood Burning Indirect Heat Exchangers"
DAQ is treating the crop residuals,turkey litter,railroad ties and telephone poles as wood under this rule.
The allowable emissions of particulate(PM) from the boilers are calculated by the equation
E= 1.1698 Q......
Where E=allowable emission limit for particulate matter in lb/million Btu
Q= Maximum heat input in million Btu/hour.
The total of maximum heat inputs of all wood burning indirect heat exchangers at the facility must be
used to determine the allowable emission limit for each boiler. Therefore, a total of 88.2 MMBtu/hour is
applied to calculate limits. Each boiler has a limit of 0.43 lb PM(filterable+ condensable)/MMBtu.
In their greenfield application W.E. Partners provided an emission factor of 0.38 lb/MMBtu for biomass.
Because the emission factor was vendor supplied and the facility has a synthetic minor limit, the permit
contained a filterable PM testing condition for one of the boilers. There was also filterable and
condensable PM testing requirement for all three boilers against the GACT particulate limit. Filterable
testing was performed after the ESP for all three boilers on 5/10/2012 (test ID 2012-176ST). The average
emission rate was 0.0079 Ib/MMBtu. The test report was reviewed and approved by SSCB (memo
2/13/2013).
The W.E.Partners I Cofield facility(ID 4600106)was required by permit to perform a particulate
condensable Method 202 test as well. The biomass boilers at that facility have only multi-cyclone
control. DAQ agreed to the facility's request to not include condensables in the 5/10/2012 particulate
test, if compliance with 213.0504 was demonstrated at Cofield. The Cofield condensable test result was
0.02 lb PM/MMBtu and the total particulate was in compliance with the 213.0504 limit. SSCB has
reviewed and approved those test results(memo 3/21/2012).
W.E. Partners performed M5/202 testing on 5/04/2017(for S133 BACT)at the stack following the ESP.
The test result was 0.045 Ib/MMBtu. The results have not yet been reviewed by SSCB.
The multiclones and ESP appeared to be in good shape during the inspection. The facility is meeting the
inspection and maintenance conditions of the permit. As long as the control devices are properly
operating,W.E.Partners should be in compliance with 2D.0504.
2D.0515 "Particulates from:Miscellaneous Industrial Processes"
This rule applies to the fuel bunker. According to the application the maximum truck fill rate for the
bunker is 100 tons/hour. The unloading rate is 12 tons/hour.
The equation to calculate the emission limit for filling is E=55.0(P)°"-40
The equation to calculate the unloading emission limit is E=4.10(P)° '
E=the maximum allowable emission rate for particulate matter in Ibs/hour(calculated to three significant
figures for process rates greater than 30 tons/hour)
P =the process rate in tons/hour
The filling emission limit is 51.277 Ibs/hour. The unloading emission limit is 21.669 lbs/hour.
I've never found a specific particulate emission factor for truck unloading of bark and wood chip to the
bunker. There is a factor for aggregate handling and storage piles in AP-42 Section 13.2.4. The
particulate factor has to be calculated using moisture content and silt(fines)content. Assuming most of
the wood fuel will be supplied by the wood products industry, the aggregate factor that Weyerhaeuser
New Bern (facility ID No. 2500104)calculated for its wood chip truck unloading and chip handling
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seems to be the best conservative factor(8.5E-4 lb/ton)for the bunker emission. Weyerhaeuser's factor
was established based on green wood/bark chip use.
Filling 100 tons/hour(8.5E-4 lb/ton)= 0.09 lbs/hour
Unloading 12 tons/hour(8.5E-4 lb/ton)=0.01 lbs/hour
The annual fuel bunker emissions are insignificant. Based upon the emissions estimate the bunker is
assumed to be in compliance with 2D.0515.
2D.0516 "Sulfur Dioxide Emissions front Combustion Sources"
Sulfur dioxide emissions from fuel combustion may not exceed 2.3 Ibs/MMBtu heat input. This rule does
not apply if there is a limit provided in NSPS for the source. NSPS De applies to the boilers. However,
Subpart De provides no sulfur dioxide limit for wood or other vegetative combustion. This means that
2D.0516 is the more restrictive rule and applies to the facility.
Wood is low in sulfur content. The AP-42 emission factor for sulfur dioxide emissions from wood
combustion is 0.025 lb/MMBtu. For the other fuels I calculated a very conservative lb S02/MMBtu based
upon 6,720 Ibs fuel/hr(max for one boiler), the sulfur measured in their NSHM fuel analyses,and
stoichiometric conversion to S02. The soybean hulls' sulfur content is approximately 0.06% by weight
(0.2 lb S02/MMBtu),and the railroad ties' sulfur content is approximately 0.02% by weight(0.08 lb
S02/MMBtu). The sulfur content of the turkey litter was analyzed at 3501 ppm, or 0.3%by wt(1.6 lb
S02/MMBtu). The creosote poles contain 0.03% sulfur by weight(0.15 lb SO2/MMBtu). Cotton waste
sulfur content was similar to that of the litter. The boilers are in compliance with 213.0516.
2D.0521 "Control of Visible Emissions"
This rule states that the 20% opacity limit does not apply if an affected source has an applicable NSPS
limitation. NSPS De applies to the boilers; however, there is no NSPS opacity limit for the boilers
because their sizes are less than 30 MMBtu/hour. Therefore, the limit under 2D.0521 applies as it is a
more restrictive limit.
The boilers and the fuel bunker must meet a limit of 20%when averaged over a six-minute period. One
exceedance in an hour is acceptable(if less than 87%), up to four times in a 24-hour period. It was a
cloudy, rainy day during the inspection. I observed the visible emissions before entering the facility and
again before leaving the facility. During the inspection we observed the VE from the stack at
approximately 5%.
Because the facility operates an ESP, visible emissions are expected to be low. The turkey litter chip size
is much smaller than the green wood chips. A portion of the litter may qualify as sawdust. Any higher
than expected visible emissions may be due to firing the odd fuel blend chip sizes or due to ash
composition to the ESP.
2D.0524 "New Source Performance Standards,"40CFR 60,Subpart Dc
Subpart De applies to any steam generating unit constructed after 6/09/1989 and that has a maximum
design heat input capacity less than 100 MMBtu/hr and greater than 10 MMBtu/hr. The regulated
pollutants are S02 and PM. However,there are no S02 or PM emissions limitations provided for these
boilers. 60.43c(c)exempts boilers under 30 MMBtu/hr from opacity requirements. 60.43c(e)(1)
exempts boilers under 30 MMBtu/hr from particulate limits. NSPS is essentially hollowed out for the
boilers at this facility.
Permit Specific Condition No. 6.a. requires the facility to record the amount of fuel combusted daily. The
facility records the daily amounts of fuel by back calculating from the steam production and keeping their
truck weight tickets. Their logs are identical to those kept at the Cofield facility.
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As required by the regulation V .. . Partners II submitted their notice of con, action on 3/25/2011. The
notice of startup was received by DAQ on 1/18/2012. The facility appears to be in compliance with
2D.0524.
2D.0535 "Excessive Emissions Reporting and Malfunctions"
NSPS Subpart A has general requirements for excess emissions recordkeeping for the NSPS De boilers.
However, 2D.0535 provides requirements for reporting. The permit condition requires the facility to
report excessive emissions that require more than four hours to repair. Any excess emissions that do not
occur during start-up or shut-down are considered a violation of the applicable standard unless the facility
demonstrates to the Director that the excess emissions are the result of a malfunction. No excess
emissions have been reported by W.E. Partners 11.
2D.0540 "Particulates front Fugitive Dust Emission Sources"
This rule requires the facility to prevent fugitive dust emissions from causing or contributing to
substantive complaints or excess visible emissions beyond the property boundary. Some fugitive dust
may be generated when loading and unloading fuels on-site, or from truck traffic. No fugitive dust was
observed on or off of the property during the inspection. The facility appears to be in compliance with
2D.0540.
2D.0611 "Monitoring Emissions front Other Sources"
I&M permit conditions are crafted under this rule. Permit Specific Condition No. 9 requires the facility to
perform an annual internal inspection and monthly external inspections on the multi-cyclones. We
reviewed the records, and the most recent internal inspections were performed on 11/01/2016(previously
10/22/2015). A copy of the inspection is attached to the file copy of this report, and is saved to the
WaRO LAN. No problems were noted.
The boiler operators also inspect the exterior of the multi-clones on a shift basis, and check the ash
discharge from them by opening the discharge door. They also the suction at the ports on the rotary
valves. The inspections are noted in a specific line item in the operator shift logs. Chad said if any issues
are discovered,they notify him and repairs are immediately conducted.
Permit Specific Condition No. 10 requires the facility to perform periodic i&M and an annual internal
inspection of the ESP. The annual inspection has to include rappers, ash removal equipment, electrodes,
buildup on the plenum, hopper, and insulators. The most recent internal inspection was on 11/01/2016
(previously 10/20/2016). A copy is attached to the file copy of this report.
Day-to-day maintenance activities are recorded in the hand—written operator shift notebook, which was
reviewed by David Harwood. They perform maintenance and inspection activities on Sundays whenever
Valley Proteins is shut down for its own maintenance. W.E. Partners keeps grease and filter change
records on the ESP. An example is attached to the hard copy of this report.
An annual outage is scheduled for the first week of November, and internal inspections for this year
should be performed then. The ESP will be cleaned out at that time,as well.
The facility appears to be in compliance with 2D.0611.
2Q.0705 "Existing Facilities andSlC Calls,"2Q.0706 "Morlifrcations,"2Q.0711 `Emission Rates
Requiring a Permit,"and 2D.1100 "Control of Toxic Air Pollutants"
According to 2Q.0706(c), after July 10, 2010 a modification to a combustion source that causes an
increase in emissions will trigger evaluation of toxics from all permitted combustion sources. However,
the NC toxics rules were modified to exempt facilities from performing toxics review for MACT/GACT
sources. R00 was issued before the toxics rule changes, so there is toxics modeling based on potential
emissions in the DAQ file for W.E. Partners It. DAQ updated the modeling to include combustion of
poultry litter up to 100%on 5/29/2013. It appears that the facility is in compliance with 2D.1100.
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2D.1111 "Maximum Achievable Control Technology,"40 CFR 63,Subpart JJJJJJ- "NESHAP for Area
Sources.Industrial, Commercial, and Institutional Boilers"
Per the regulation,these boilers are categorized"new"biomass boilers because they began construction
after June 4,2010. A summary of W requirements, along with comments from the inspection, are
provided as follows:
• Each boiler is limited to 0.07 lb PM/MMBtu (filterable).The facility was required to test the boilers
for filterable particulate(Methods 1-5) and provide the testing results within 180 days of startup. The
test was performed on 5/10/2012 and startup was 1/17/2012. All three boilers were tested at
maximum heat input and steam production(61.876 klbs/hr). The test was performed at the ESP
stack. The average result was 0.0079 lb/MMBtu. SSCB has reviewed and approved the test report
(test ID 2012-176ST).
Because the boilers' performance test results showed that PM emissions are equal to or less than half
of the PM emission limit,no further performance tests for PM were required. However, Subpart 6.1
has since been revised to require five-year testing. For boilers that have already performed initial
testing under the old language,they have until 9/14/2021 to do their next test, and then test every five
years thereafter. This new test schedule was addressed in the permit renewal R03.
The facility tested for filterable+condensable particulate(M5/202)on 5/04/2017 to demonstrate
compliance with the SB3 BACT limit. The filterable emission result was 0.042 Ib/MMBtu. They did
not include any secondary power data with the stack test report. Based upon the hourly average data
from the parametric monitor for the 12:00 PM-4:00 PM period of the test,the average secondary
power was approximately 4.3 W. Since they are not required to test for particulate until 2021 under
6J, I am unsure whether they re-established minimum kW for 6J monitoring when they performed the
BACT testing. I am in progress of discussing this question with DAQ MACT Workgroup members
and SSCB. Even if the minimum was re-established 5/04/2017, the 30-day rolling average appears to
have been well above 4.3 kW since the test.
• The Permittee shall maintain the operating load of each unit such that it does not exceed 110 percent
of the average operating load recorded during the most recent performance stack test. The particulate
test was conducted at close to 100% load for each boiler, so the boilers are not likely to exceed the
percentage limit.
• During the performance test, W.E. Partners had to establish the minimum secondary power to the
ESP. The regulation requires the facility to maintain the secondary power input at or above the
lowest 1-hour average secondary electric power measured during the most recent particulate
performance test(63.11201). The lowest hour during the test averaged 3.4 kW. Both the 5/10/2012
stack test report and W.E. Partners' site specific monitoring plan set the minimum secondary power at
3.4 W.
• The secondary power must be monitored according to the following requirements:
- Collect the secondary amperage and voltage,or total power input monitoring system data for the
electrostatic precipitator according to 63.11224 and 63.11221, and Table 7 to Subpart JJJJJJ. The
kW must be measured and stored at a minimum of one cycle of operation every 15 minutes.
There must be a minimum of four cycles of operation representing each of the four 15-minute
periods in an hour, or at least two 15-minute data values during an hour when CMS calibration,
quality assurance, or maintenance activities are being performed,to have a valid hour of data.
The TR set software at W.E. Partners records secondary power every six minutes, and averages
those readings to each hour. They only discount hours where all readings within the hour are zero
due to shutdown of the boilers.
- The regulation requires hourly data be reduced to thirty-day rolling averages. W.E. Partners
tracks compliance with their kW minimum on a twelve-hr block average, which was originally
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required by the 6J reg,..ation when it was first promulgated. DAQ .,aRO agreed the twelve-hr
block average is still considered an acceptable method for compliance demonstration because it is
more restrictive than the thirty-day rolling average.
The twelve-hr average data for the previous day is sent from the ESP TR set panels to the
computer in the control room. It is view only on the computer;the data is saved in the TR control
set hardware. The operators record the twelve-hour block averages for the previous day into their
daily inspection checklist.
There is a one-hour offset in how the system records the hourly averages. For example,the 10
AM recorded hour average is actually for the 9 AM hour.
The thirty-day rolling average total secondary electric power must be maintained at or above the
minimum total secondary electric power measured during the most recent performance test
(63.11211). Deviations from this requirement must be reported in an annual compliance
certification report.
David and I reviewed all of the 12-hr average data in the operator daily logs. We identified a
number of days where the secondary power was below 3.4 kW, and there were several days
where the 12-hr averages were not recorded. We copied much of the records, and they are
attached to the file copy of this report. I requested to see the hourly averages for the ESP April
through July 2017. Mr. Cottrell provided the hourly averages by email on 9/25/2017 for
9/26/2016 through 9/20/2017. The hours where the boilers were not operating are not included in
the rolling 30-day averages.
I have printed the April through July 2017 hourly and 30-day rolling average data as an example
attachment to the file copy of this report. The full set of data is saved to the WaRO LAN at
9:\AQ\Shared\Bertie08\00107\ag16s\September 2016 through September 2017 ESP Hourly
Secondary power.xlsx and October 2016 through September 2017 ESP Hourly Data Betsy
Calculations.xlsx. The file with my name contains my notes from reviewing all of the data.The
highlighted data are hours where Mr. Cottrell failed to correctly copy over the hourly average
(example: instead of 12.5 kW, he transferred over 2.5,dropping the tens digit). As a result,their
30-day averages were a bit lower than they actually were. It did not matter, because the data
appears to still demonstrate compliance with the 30-day average minimum 3.4 kW secondary
power.
I did use the hourly data to calculate and compare some of the 12-hr averages in the daily
operator checksheets, and the data appears to correlate.
Record the results of any inspections, calibrations,or validation checks. Calibrations and
validation checks are done by the manufacturer. They work on the ESP only when requested, and
Chad noted they were last at the plant in September 2016.
§63.11221(c)and §63.11225(c)(6)require the facility to track periods of monitoring downtime
and monitor malfunctions. The Division of Air Quality's"North Carolina Continuous
Monitoring Enforcement Plan (NCCEP)"applies to regulatory required parametric monitors as
well as continuous emissions monitors. There were no recorded kW monitor issues. Chad said
they have had no secondary power monitoring downtime.
All monitoring data must be retained and accessible for at least five years. The data is only
retained for a year within the TR set hardware, so Chad Hoggard saves the data every six months
to a separate source in order to meet the 5-year retention requirement.
r/
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• Startup and shutdowns must be according to manufacturer's recommended procedures. It is my
understanding that the operators are trained according to the manufacturer's requirements. It's my
understanding the Valley Proteins plant generally only operates on Sundays(and Saturdays to some
degree) if there are overflow loads or backlogged loads. Mr. Hoggard previously stated when W.E.
Partners start up their boilers on Monday,the ESP goes online when the stack temperature reaches
250°F, then steam can be sent over to the Valley Proteins facility. He also noted the ESP remains on
no matter the level of boiler operation until the next plant or full boiler shutdown.
• The facility was required to submit a Site Specific Monitoring Plan 60 days prior to the initial
performance test. The facility failed to submit this on time, and was issued a Notice of Deficiency on
2/20/2013. The plan was submitted on 2/13/2013. It is attached to the file copy of the 2/02/2014
inspection report. The monitoring plan states that operators are to notify management when any
twelve-hr block average secondary power is below 3.4 W. There has been [to change to the plan
since the date of last DAQ inspection.
• Biennial tune-ups are required. The following must be completed as part of the tune-up:
- As applicable, inspect the burner, and clean or replace any components of the burner as necessary
(the Permittee may delay the burner inspection until the next scheduled unit shutdown, but must
inspect each burner at least once every 36 months).
- Inspect the flame pattern, as applicable,and adjust the burner as necessary to optimize the flame
pattern.The adjustment should be consistent with the manufacturer's specifications, if available.
- Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly
calibrated and functioning properly.
- Optimize total emissions of carbon monoxide. This optimization should be consistent with the
manufacturer's specifications, if available.
- Measure the concentrations in the effluent stream of carbon monoxide in parts per million, by
volume, and oxygen in volume percent, before and after the adjustments are made(measurements
may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments
are made).
- Maintain onsite a biennial report
A copy of the initial tune-up results are in the WARO file. The CO ppmv tested after the tune-up
were in keeping with what was measured during the 6/19/2012 stack test. The 2016 tune-ups were
completed 1/08/2016, and are on file at the facility. A copy is in the WaRO file.
• The facility must keep annual records of fuel usage. The facility must keep records of tune-ups and
tests. The facility must keep records of their NHSM determinations. All malfunctions and corrective
actions must be recorded. Most of their malfunction records are kept within the operators' logs.
NHSM records are kept at Garald Cottrell's office. W.E. Partners appears to be in compliance with
these requirements.
• The facility was required to provide a notification of startup. DAQ received the notification on
1/18/2012. A Notification of Compliance Status was due within 60 days of the initial stack test. The
NOCS must include statement that the tune-up was completed and startups and shutdowns are
conducted according to manufacturer's specifications. The NOCS was late,and a Notice of
Deficiency was issued to W.E. Partners on 2/20/2013. The NOCS was submitted on 2/13/2013. The
NOCS was resubmitted on CEDRI on 10/07/2014.
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The facility must compile annual compliance certifications by March 1' _ach year. They are not
required to submit the certifications to DAQ unless requested or if there are deviations. Their
3/01/2017 report was on file at the facility.
Based upon review of the secondary power data supplied and other associated Subpart 6J records, W.E.
Partners appears to be in compliance with Subpart 6J.
2D.1806- "Control and Prohibition of Odorous Emissions"
This rule requires the facility to prevent objectionable odors from the facility from moving off the
property. We did not observe any odors from the turkey litter during the inspection. The facility
appears to be in compliance with 2D.1806.
2Q.0315 "SynthelicAtinorFacilities"
The uncontrolled potential facility wide PMio,CO and NOx emissions are greater than 100 tons per year.
The permit limits criteria emissions to less than 100 tons/year each so that W.E. Partners can be a
synthetic minor facility.
CO is the limiting pollutant for tracking against the synthetic minor 100 tpy limit. Carbon monoxide
testing was completed on 6/19/2012 (test ID 2012-176ST), and the average emission rate was measured
0.45 Ib/MMBtu.The test report was approved by SSCB on 2/13/2013. CO was tested on the boilers at
the Cofield facility on 10/13/2015 at a rate of 0.259 lb/MMBtu.
NOx was tested at the Cofield facility on 10/13/2015 at a rate of 0.289 Ib/MMBtu.
On 5/04/2017 the facility tested the boilers for all three pollutants for compliance demonstration with the
SB3 BACT limits. The average filterable+condensable PM emission was 0.042 Ib/MMBtu. The CO
average emission was 0.42 Ib/MMBtu. The average NOx was 0.33 Ib/MMBtu. These test results are
currently in review by SSCB.
Permit Condition 13.a. requires the facility to calculate CO and NOx emissions each month. W.E.
Partners must also submit an annual report(due January 30"i)of tons of fuel combusted each month, CO
monthly emissions and NOx monthly emissions. The CY 12-month totals are also reported. The 2016
repot was received on 1/06/2017. CY2016 CO emissions were reported at 86.87 tons (they applied the
0.45 tb/MMBtu test factor and 4,375 Btu/Ib), with the highest rolling annual tonnage of 86.87 tons in
December 2016. CY2015 NOx emissions were 56.95 tons(based on vendor factor of 0.295 lb/MMBtu),
with the highest rolling annual tonnage of 56.95 in December 2016.
The NOx and CO emissions appear to be in compliance with 2Q.0315.
2Q.0317 "Avoidance Conditions"
Because uncontrolled potential emissions of PMio are over 250 tons/year, a PSD avoidance condition was
added to the permit. Because the facility has a 100 tpy limit for PMio to be a synthetic minor,this permit
condition points to the synthetic minor recordkeeping and reporting conditions to ensure compliance.
BACT Determination for Boilers ESB-1 and ESB-2
General Assembly of North Carolina,Session Late 2007-397,Senate Bill 3 (SB3)
The Renewable Energy and Energy Efficiency Portfolio Standard(REPS)requires 3%of North Carolina
retail sales for each electric public utility to come from renewable energy resources. One of the ways to
meet this requirement is to purchase electric power from a new renewable energy facility. W.E. Partners
is such a facility.
Senate Law 2007-397, Senate Bill 3 (S133)(62-133.7(g)) requires biomass combustion processes at a new
renewable energy facility to meet Best Available Control Technology(BACT). The BACT determination
is performed in the same manner as required by PSD. W.E. Partners II submitted a BACT analysis on
10/05/2010. A revised BACT analysis was submitted on 8/11/2015. DAQ RCO Permits determined that
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the crop residual fuels,railroad ties,and turkey litter are considered equivalent to green wood in
consideration of the BACT analysis, so there was no need to update the BACT analysis for addition of
these fuels.
i
Permit Condition A.15. for BACT was added in permit R03. The facility must complete initial
performance testing for NOx, PM/PMIo/PM2.5 and CO on the boilers no later than June 6,2017(180 days
from permit issuance date). W.E. Partners conducted this testing on 5/04/2017. It is my understanding
that the fuel mix during the test was 60%litter/40%wood chip. The test report was submitted to WaRO
on 6/06/2017 (slightly more than the required 30 days after testing per condition 15.h.). The test report is
still in review by SSCB, so compliance with the permit condition has not yet been determined.
The permit required W.E. Partners to ensure that the boilers are operated during testing at or near
maximum normal production rate as determined by operations over the previous 12 months. The permit
requires the emission test report to include data supporting the determination of maximum normal
production rate and average production rates determined during each testing period. It does not appear
that supporting documentation was supplied with the test report. I have noted this to the SSCB review
engineer.
Permit condition 15A.requires the facility to submit test protocols at least 45 days prior to the test date(s),
so that DAQ may review and pre-approve the testing. Condition 15.e. requires at least 15 days' notice
prior to the testing. W.E. Partners failed to submit the protocol and to notify the regional office prior to
the test date. Therefore,no DAQ staff had the opportunity to observe the testing. A Notice of Violation
was issued to W.E. Partners on 6/07/2017.
The BACT limits and testing summary requirements are provided in the table below:
l Pollutant SB3 BACT Emission Limit Compliance Method
Staged Combustion and
Good Combustion Practices,
NOx 0.34 Ib/MMBtu Initial Testing,then additional testing
(3-hr average) once per permit term thereafter
by test method determined by
DAQ approved testing protocol
SO2 Firing Clean Permitted or approved NHSM biomass fuels
Cellulosic Biomass
Initial Testing then additional testing
0.05 Ib/MMBtu once per permit term thereafter
PM/PMio/PM25 (filterable and condensable) by test method determined by DAQ
(3-hour average) approved testing protocol
Good Combustion Practices
CO 0.45 lb/MMBtu Initial Testing, then additional testing
(3-hour average) once per permit term thereafter by test method
determined by DAQ approved testing protocol
Compliance with applicable provisions for
VOC Good Combustion Practices inspection and maintenance of air pollution
control equipment in 15A NCAC 02D .0315
Compliance with applicable provisions for
Hg Good Combustion Practices inspection and maintenance of air pollution
control equipment in 15A NCAC 02D .0315
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Following the initial testing,i. Permittee shall demonstrate compliance b, .asting the boilers for NOx,
PM/PMr0/PM2.5 and CO once every eight years (permit term). The tests must be completed within 30 days
before and 30 days after the eight-year span between test dates.
New Source Performance Standard(NSPS)for Commercial and Industrial Solid Waste Incineration
(CISWI), 40 CFR 60,Subpart CCCC
DAQ is requiring facilities to compare renewable fuels they wish to burn to the legitimacy criteria in
40CFR 241 to be defined as non-hazardous secondary material(NHSM). Permit R02 was issued to
change each boiler description to"one clean cellulosic biomass-fired boiler(29.4 million Btu per hour
maximum heat input)." With this descriptor, W.E. Partners is able to combust any biomass fuel that
specifically meets the definition of"clean cellulosic biomass" in 40 CFR 241.2 (NHSM rule). DAQ
issued a determination on 1/26/2011 approving combustion of peanut hulls, soybean hulls, and cotton gin
residues. EPA Region IV issued a NHSM determination to W.E. Partners on 03/11/2013 approving
screened turkey poultry litter. On 1/07/2015 DAQ issued a letter to W.E. Partners approving railroad ties
as clean cellulosic fuel. On 6/05/2015 DAQ issued a letter approving creosote telephone poles.
W.E. Partners is required in permit Specific Condition A.16.to notify the DAQ in writing within 30 days
of beginning use of a new clean cellulosic biomass fuel. For any fuel that is not clearly defined as clean
cellulosic biomass in 40 CFR 241 or separately approved as a non-hazardous secondary material
(NHSM), biomass fuel by the Environmen.al Protection Agency,they must first submit a NHSM
determination request to the Division of Air Quality.
Compliance History
See the WaRO file and previous inspection reports for detailed information on the listed enforcement
cases below.
2/20/2013 Notice of Deficiency
NESHAP 6J(Boiler GACT)
Failure to Submit Site Specific Monitoring Plan and Notice of Compliance Status
• 9/22/2014 Notice of Deficiency
NESHAP 6J (Boiler GACT)
ESP Operation with Respect to the Definition of Boiler Startup and
Requirements for Secondary Power Monitoring
• 5/12/2015 Notice of Violation/Notice of Recommendation of Enforcement
40CFR Part 63, Subpart JJJJJJ, Boiler GACT
ESP Operation with Respect to the Definition of Boiler Startup and
Requirements for Secondary Power Monitoring and Recordkeeping
Enforcement Case 2015-022,Assessment$3,545.00
• 6/22/2016 Notice of Violation/Notice of Recommendation of Enforcement
40CFR Part 63, Subpart JJJJJJ, Section 63.11201(c)and Table 3
Electrostatic Precipitator Secondary Power Thirty-Day Rolling Averages Below Minimum 3.4 kW
Enforcement Case 2016-035, Assessment$7,739.00
• 6/07/2017 Notice of Violation
SB3 BACT Permit Specific Conditions A.15.d. and A.15.e.
Failure to Submit Test Protocol Submittal and Test Notification Requirements
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Conclusion
The facility appeared to be in compliance with the permit conditions and applicable regulations at the
time of the inspection.The SSCB review of the SB2 BACT testing results is forthcoming, so compliance
determination with the SB3 limits can't be made at this time. I am in progress of obtaining guidance oil
whether the SB3 testing would cause a reset of the secondary power parametric monitoring minimum for
the Boiler GACT.
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