AQ_F_1800419_20171128_ST_RvwMemo (4)

DIVISION OF AIR QUALITY
November 28,2017
MEMORANDUM
To: Bruce Ingle,Mooresville Regional Office
From: Shannon Vogel, Stationary Source Compliance Branch �''Y�J
Subject: Prysmian Cables and Systems USA,LLC
Claremont, Catawba County,North Carolina
Facility ID 1800419,Permit No. 07334T27
Emissions Testing Performed February 14, 2017 by Air-Tech Environmental LLC
Tracking No. 2017-045st
Air-Tech performed EPA Method 5/26A to determine the filterable particulate matter(PM),hydrogen
chloride(HCI),hydrogen fluoride(BF)and chlorine(Cl)emissions and EPA Method 7E to determine
nitrogen oxide(NOx)emissions on February 14,2017. The test results are acceptable to demonstrate
compliance with the applicable emissions standards.
Testing was performed at the outlets of two control devices:
3WS Wet Scrubber consisting of a variable throat venturi scrubber with greater than 90 gallons per
minute(gpm)caustic solution injection(pH 8 or higher as determined from source testing)controlling
emissions from ES-1 chemical vapor deposition units Cells 5, 6, 7, and ES-4 gas cabinets,ES-14
collapse furnaces,ES-11 chemical room and ES-18 SiCla Storage Room, and
ID No.2DS consisting of fabric filter with hydrated lime injection(30 dry pounds per hour lime
injection or higher as determined by testing)controlling emissions from Emissions Source ES-9a
over-cladding units -Cell 6,Cell 7 and remaining Cell 5 Units.
The following regulations and emissions limits apply:
15A NCAC 2D .0515 Particulates From Miscellaneous Industrial Processes which limits particulate
matter(PM)based on process weight rate. Air-Tech reported a 2D .0515 emission limit of 0.72
pounds per hour. Per the Stack Test Observation Form,"Note: compliance should be based on how
many units(confidential information)can be operated at one time to determine potential hourly
emissions. The facility kept track of the number of units operating during the test and should remain
confidential."
15A NCAC 2D .1100 Control of Toxic Air Pollutants applies. The permit limits HCI to 9.063 pounds
per hour(lb/hr),BF to 3.2021b/hr and Cl to 5.582 lb/hr and 133.97 pound per day(lb/day).
15A NCAC 2Q .0317 Avoidance Conditions to avoid applicability of 15A NCAC 2D .0530
Prevention of Significant Deterioration applies and limits NOx emissions to 250 tons per year(tpy).
The test results are acceptable to demonstrate compliance with the applicable emissions standards as
tabulated below.

Lisa Edwards,P.E.
November 28,2017
Tracking No.2017-045st
Page 2
Scrubber 3WS-ES-1 CVD Units EPA Method 5/26A Test Results
Pollutant Test Results Emission Limit Regulation Compliance
Filterable PM 0.028 lb/hr 0.721b/hr 2D .0515 Yes
HCl 0.0017 lb/hr 9.063 lb/hr Yes
BF 0.020 lb/hr 3.2021b/hr 2D .1100 Yes
0.30 lb/hr 5.582 lb/hr
Chlorine 7.3lb/da * 133.97lb/da F- -Y--
Based on 24 hours per day operation
Scrubber 3WS Process Parameters 2/14/17
Parameter Test Average Permit Limits
Liquid Flow Rate 92.3 gpm >90 gpm
H 9.7 >8 as determined from source testing
Mist Eliminator OP 10.5 10<OP< 15 in.H2O
Fabric Filter 2DS—ES-9a Overcladdi EPA Method 7E Test Results ES-9a
Pollutant Test Results Emission Limit Re lation Compliance
45.61b/hr --- --- ---
NOx
200 tpy 250 tpy 2Q .0317 PSD Yes
Compliance was demonstrated. If you have any questions regarding the results of this review,please
contact me at 919-707-8416 or shannon.vogelcr.?ncdenr.gov.
cc: Central Files,Catawba County
IBEAM Documents— 1800419