AQ_F_1800419_20170203_ST_ProtRvw (4)

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
Air Quality SHEILA C. HOLMAN
ENVIRONMENTAL QUALITY Director
February 3, 2017
Mr. Steve Linden,Plant Manager
Prysmian Cables and Systems USA, LLC
2512 Penny Road
Claremont,NC 28610-8634
Subject: Prysmian Cables and Systems USA,LLC,Facility ID 1800419, Tracking No.2017-045ST
Claremont, Catawba County,North Carolina,Air Permit No. 07334T27
Protocol for Particulate Matter(PM),Hydrogen Chloride(HC1),Hydrogen Fluoride(HF),
Chlorine (Cl), and Nitrogen Oxide(NO,,)Emissions Testing
Proposed Test Date: The Week of February 20,2017,
To be performed by Air-Tech Environmental, LLC
Dear Mr. Linden:
The emissions test protocol for the subject facility has been reviewed. Testing will be performed to meet
the requirements in permit conditions 2.l.A.La,2.2.A.Lb, and 2.2.C.Ld. The test methods are acceptable
to determine compliance with 15A NCAC 2D .0515 Particulates from Miscellaneous Industrial
Processes and 15A NCAC 2Q .0317 Avoidance Conditions for 15A NCAC 2D .1111 Maximum
Achievable Control Technology(MACT)and 15A NCAC 2D .0530 Prevention of Significant
Deterioration (PSD)listed in the air permit. In order to avoid MACT applicability,the permit limits
facility-wide individual hazardous air pollutants to less than 10 tons per consecutive 12-month period and
combined hazardous air pollutants to 25 tons per consecutive 12-month period. To avoid PSD
applicability,the permit limits NO,, emissions from all sources facility-wide to less than 250 tons per year.
Testing will be performed at the wet scrubber outlet to determine the (PM/HCl,BF,and Cl)emissions.
Testing will also be performed at the dry scrubber inlet to determine the NO,,emissions. The following
table lists the pollutants and the test methods:
Table 1: Pollutants and Test Methods - Sampling at Outlet of Wet scrubber 3WS
EPA Methods/
Source ID No. Test Location Run Time Target Standard Emissions Limit
Chemical vapor PM 15A NCAC 2D .0515 E=4.10 P0.67"
deposition Units`
Cell 5,6,7
(ES-1,ES-4-3WS,
ES-14) 3 runs HCl 15A NCAC 2Q .0317 Facility-wide
Chemical room 5/26A 60 minutes each HF,� MACT Avoidance of < 10 tons/yr each
(ES-11) Cl 15A NCAC 2D .I I 11 and
<25 tons/ combined
SiCL4 bulk storage Y1
room
(ES-18)
' Note:According to the protocol submittal only 2 units are operating and only 2 will be operating in 2016.
" For P<30 tons/hr: Allowable emissions limit E(lb/hr),Proccess weight P(tons/hr)
Note audit samples analysis is required for EPA Method 26A. During the test period the audit sample
must be present for inspection on request. For additional information please see EPA web page
http://www.ppa.;;ov/emc/emc-technical-support.
State of North Carolina I Environmental Quality I Air Quality
217 W.Jones Street 11641 Mail Service Center I Raleigh,North Carolina 27699-1641
919 707 8400

Mr. Steve Linden,Plant Manager
February 3, 2017
Page 2
Table 2: Pollutants and Test Methods - Sampling at Inlet of H drated lime injection fabric filter 2DS
EPA Methods/
Source ID No. I Test Location Run Time I Target Standard Emissions Limit
15A NCAC 2Q .0317
7E** 3 runs, NO, PSD Avoidance of <250 tons/yr
60 minutes each Over-cladding 15A NCAC 2D .0530
Units*Cell 5,6,7 1-4 3 runs, Flow Rate, --- --
(ES-9a) (With Method 7E) 30 minutes each Moisture
205 _ Calibration
(For Method 7E) Gas Dilution
* Note: According to the protocol submittal only 2 units are operating and only 2 will be operating in 2016.
*' The tester must conduct a stratification test as described in Section 8.1.2 of EPA Method 7E to determine the
NO,,sampling traverse points/point to be used.
The test protocol is approved. The tester must verify the absence of cyclonic flow as described in Section
11.4 of EPA Method 1. Please note that when using EPA Methods 26A 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 Prysmian Cables and Systems USA and Air-Tech Environmental to insure
that the minimum detection limits are low enough to demonstrate compliance with the applicable
emissions limits. The result cannot be reported as zero. The result must be reported as less than the
method detection limit determined from the test.
The EPA 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. Also the request to assign dry ambient air a molecular weight of 29.0 is approved provided
the tester documents the reasons the default value is appropriate.
Prysmian Cables and Systems USA shall be responsible for ensuring, within the limits of practicality,that
the subject facility being tested is operated at maximum normal operating conditions. The target process
rate is 0.0024 tons per hour. The final report must include information documenting the test period
production target rate and the permit required emissions factors for monitoring, recordkeeping and
reporting. The wet scrubber operating parameters during testing must also be included with the report
(i.e., pressure drop, liquid flow rate,pH,make up liquid rate).
Approval of the proposed testing methods 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 questions concerning this matter,please contact me at(919) 707-8415 or gregg.onealLwncdenngov..
Sincerely,
Thomas G. ONeal,I11,P.E., Environmental Engineer
Division of Air Quality,NCDEQ
cc: Rick Miller,Prysmian Cables and Systems USA,LLC -Claremont,NC
Mike Hartman/Darrell Doerie, Air-Tech Environmental, LLC -Durham,NC
Bruce Ingle,Mooresville Regional Office
Central Files,Catawba County
IBEAM Documents - 1800419