AQ_F_0100237_20180827_ST_ProtRvw (4)

x.. >
`ara+ �
ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretary
MIC14AEL ABRACZINSKAS
Director
August 27,2018
Mr.Mark Blalock,General Manager
Canfor Southern Pine—Graham Plant
4408 Mt Hermon-Rock Creek Road
Graham,NC 27253-8909
Subject: Canfor Southern Pine—Graham Plant
Graham,Alamance County,North Carolina,
Facility ID 0100237,Air Permit No.06740T20
Wood Boilers ID Nos.B-2,B-3, and B-4
Protocol for Filterable Particulate Matter(PM),Hydrogen Chloride equivalent
(HCl-equivalent), Carbon Monoxide(CO)and Mercury(Hg)Emission Testing
Proposed September 18 through 20,2018 by TRC Environmental Corporation(TRC)
DAQ Tracking No. 2018-247st
Dear Mr.Blalock:
The emissions test protocol for the subject facilities has been reviewed. The test protocol is approved
only as discussed in this letter. The proposed sources to be tested are three Boilers,ID Nos.B-2,B-3, and
B-4. Boilers B-2 and B-3 are wood fuel-fired boilers(28.7 million Btu per hour heat input capacity each)
controlled by two multicyclones each. Boiler B-4 is a wood fuel-fired boiler(57.6 million Btu per hour
heat input capacity)controlled by two multicyclones and an electrostatic precipitator ESP-4. Testing will
be performed to demonstrate compliance with 15A NCAC 2D.11091126) Case-By-Case Maximum
Achievable Control Technology listed in permit condition 2.2.C.1. Note that hydrogen chloride-
equivalent emission rate must be calculated and reported(not HCl only). Also,Boilers B-2,B-3, and B-4
are subject to 40 CFR 60 Subpart Dc Standards of Performance for Small Industrial-Commercial-
Institutional Steam Generating Units listed in permit conditions 2.1.A and 2.1.B and 15A NCAC
2D .0504 Particulates from Wood Burning Indirect Heat Exchangers listed in permit condition 2.1.A.
TRC proposed the following EPA Methods:
1 Sample and Velocity Traverses for Stationary Sources,
2 Determination of Stack Gas Velocity and Volumetric Flow Rate(Type S Pitot Tube),
3A Determination of Oxygen and Carbon Dioxide Concentrations in Emissions From Stationary Sources
(Instrumental Analyzer Procedure),
4 Determination of Moisture Concentration in Stack Gases,
5 Determination of Particulate Matter Emissions from Stationary Sources,
10 Determination of Carbon Monoxide Emissions From Stationary Sources(Instrumental Analyzer
Procedure),
26A Determination of Hydrogen Halide and Halogen Emissions From Stationary Sources Isokinetic
Method
30B Determination of Total Vapor Phase Mercury Emissions From Coal-Fired Combustion Sources
Using Carbon Sorbent Traps
�,
aIN
C_
North Carolina Department of Environmental Quality I Division of Air Quality
217 West Jones Street 11641 Mail Service Center I Raleigh,North Carolina 27699-1641
919.707.8400

Mark Blalock
August 27,2018
Page 2 DAQ Tracking No.2018-247st
Pollutants and Approved Test Methods.
EPA Test No.of Test Run No. Sampling
Tar et Pollutant Method Test Runs Duration Points Comments
Stack gas flow 1,2,4 3 Sampling points
rate,moisture determined by
Oz/COz 3A Method 1
CO 10 verification
90 Minutes See Comment including absence
Filterable PM 5 3 (See Note) of cyclonic flow
determination and
HCl-equivalent 26A Method 7E section
(HCl&Clz) 8.1.2 stratification
Mercury 30B test
Note:Testing must be long enough to collect sufficient Mercury to analyze.
If TRC uses a combined EPA Method 5/26A sampling train for PM and hydrogen halide/halogen
emissions,the combined method is acceptable provided that the Method 26A Teflon filter support is used
(the alternative Teflon probe liner,cyclone, and filter holder are not acceptable). Also,the probe and
filter temperature requirements of both EPA Method 5 and Method 26A must be met.
Approval of the testing proposals does not exempt the tester from the minimum requirements of the
applicable test methods. Please note that when using EPA Methods 26A and 30B,the limits of detection
are based on actual source parameters. There are no estimated detection limits in the test protocol.
Therefore,the responsibility will remain with Canfor Southern Pine—Graham Plant and TRC to ensure
that the minimum detection limits are low enough to demonstrate compliance with the applicable
emissions limits.
Canfor Southern Pine—Graham Plant shall be responsible for ensuring,within the limits of practicality,
that the subject sources are operated at or near maximum normal production rate(i.e. approximately 90%
to 100%of the maximum permitted heat input rate). The final test report should include information to
establish that the near maximum normal requirement was met during the test period. The report must also
include the applicable test period control system data.
TRC has submitted a Method 26A audit sample order request. The sample must be present for inspection
by DAQ observer during testing. For additional information please see this EPA web page
htti2://www.epa.L,:ov/ttn/emc/email.html#audit.
If there are any questions concerning this matter,please contact me at(919)707-8412 or
[e-mail].
cerely,
ames E.Hammond,Environmental Engineer
Division of Air Quality,NCDEQ
cc: Bryce Morgan,TRC Environmental Lisa Edwards,P.E.,Winston-Salem Regional Office
Central Files,Alamance County IBEAM Documents-0100237