AQ_F_1400166_20171020_ST_ProtRvw (4)

ROY COOPER
,.., Governor
MICHAEL S. REGAN
secretary
Air Quality MICHAEL A. ABRACZINSKAS
ENVIRONMENTAL QUALITY Acting Director
October 20,2017
Mr.Vincent White
Site Manager
Sealed Air Corporation
2001 International Boulevard
Hudson,NC 28638-2731
Subject: Sealed Air Corporation-Hudson
Hudson, Caldwell County,North Carolina,Air Permit No. 07550R08
Facility ID 1400166,Tracking No. 2017-280ST
VOC Destruction Efficiency Testing-Electric Regenerative Thermal Oxidizer OX-2
Proposed Test Date:November 16,2017
To Be Performed by Civil&Environmental Consultants,Inc.
Dear Mr.White:
The emission test protocol for testing OX-2 has been reviewed. OX-2 is an electric regenerative thermal
oxidizer(RTO)described in the permit as a 115-kilowatt electric heater with natural gas injection for low
VOC loading,natural gas-fired back-up at a maximum heat input of 9 million Btu per hour. OX-2 is used
to control the emissions from polyethylene foam extruders(ID Nos.EXT-1,EXT-2,EXT-3 and EXT-4),
curing room(ID No.ES-CR), and fluff processing operation(ID No.ES-FP). Testing will determine the
VOC destruction efficiency of OX-2.
Testing will be performed as required in permit condition A.8 while operating RTO OX-2. The results
will be used to ensure facility wide emissions remain in compliance with 15A NCAC 2Q .0315 Synthetic
Minor Facilities and for the avoidance of the applicability of 15A NCAC 2Q .0501 Title V permitting
procedure. To avoid Title V permitting,permit condition A.11 requires facility wide emissions of VOC
remain less than 100 tons per consecutive 12-month period. The table below lists the pollutants and test
methods:
Table 1: Pollutants and Test Methods for Destruction Efficiency esting of RTO(ID No. OX-2)
Pollutant/Parameter EPA Method Test Locations Run Time
Volumetric Flow Rate 1 through 4 OX-2 Inlet and Outlet 3 runs,60 minutes at each test location
VOC/HAP 25A OX-2 Inlet and Outlet 3 runs,60 minutes at each test location
Calibration Gas Dilution 205 --- ---
Method 2 section 8.6 states that for processes emitting essentially air, a Method 3 analysis need not be
conducted;therefore,assume the dry molecular weight is 29.0. For processes burning natural gas,coal,
or oil a dry molecular weight of value of 30.0 may be assigned according to Method 3 Section 1.3. The
request to use the assigned dry molecular weight value is approved provided the tester documents the
reasons the default value is appropriate.
The tester has requested to use the wet bulb-dry bulb technique at the RTO inlet. Method 4 allows
approximating the moisture content using the wet bulb-dry bulb technique. This is an acceptable
approach since the Method 25A testing will not be performed isokinetically and is allowed according to
Method 2 section 2.2.
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.Vincent White, Site Manager
October 20,2017
Page 2(Sealed Air Corporation-Hudson,VOC Destruction Efficiency Testing RTO OX-2)
The Method 205 Verification of Gas Dilution Systems for Field Instrument Calibrations testing must be
performed prior to beginning the test. The dilution ratios to be used during the test period shall be
verified during the Method 205 procedure. The test data may be rejected if Method 205 is not performed
appropriately.
The proposed operating rate for testing is 60 lb/hr for each machine(240 lb/hr total). The protocol
submittal indicates that the maximum permitted process rate is 320 lb/hr total. Therefore,testing will
be conducted at 75%of the maximum normal production rate. Since the purpose of testing is to
demonstrate the RTO will comply with the minimum 95%destruction efficiency requirement listed in
permit condition A.8.b.i,this proposed operating rate is acceptable. The air permit also states that the
minimum RTO bed temperature shall not be less than 1790°F unless established otherwise by stack
testing. The final report must include the RTO operational parameters(i.e.,temperature, flow rate,and
pressure drop)as monitored at least every 15 minutes during the test. The final report must also include
information to document the production rate during the test period.
Approval of the testing proposals does not exempt the tester in any way from the minimum requirements
of the applicable test methods. Any deviations from the applicable methodologies not specifically
addressed in this letter remain subject to the approval of the Division of Air Quality. If there are any
questions concerning this matter,please contact me at(919)707-8415 or gregg oneal@,ncdenr.gov.
Sincerely,
Thomas G. O'Neal,III,P.E.,Environmental Engineer
Division of Air Quality,NCDEQ
cc: Quentin Best,Civil&Environmental Consultants,Inc. -Charlotte,NC
Brendan Davey,P.E,Asheville Regional Office
Central Files, Caldwell County
IBEAM Documents- 1400166