AQ_F_0800044_20170315_ST_RvwMemo (4)

DIVISION OF AIR QUALITY
March 15,2017
MEMORANDUM
To: Robert Fisher,Washington Regional Office
From: Brent W. Hall, Stationary Source Compliance Branch(SSCBLI)gv
Subject: Avoca Incorporated
Merry Hill,Bertie County,North Carolina
Facility ID 0800044,Permit No. 01819T47
Particulate Matter,Hydrogen Chloride, Carbon Monoxide and Mercury Emissions
Testing of Biomass Boilers ES-BBl and ES-BB2
Performed December 14, 2016 by Air-Tech Environmental, Inc.
Tracking No.2016-283ST
Air-Tech Environmental,Inc. conducted particulate matter(PM),hydrogen chloride(HCI), carbon
monoxide(CO), and mercury(Hg)emissions testing of the two biomass boilers,ES-BB 1 and ES-13132,
while only firing wood. The test results are acceptable to demonstrate that the boilers were in compliance
with the applicable emissions standards during the testing period.
ES-BB 1 and ES-BB2 are two biomass boilers(24 million Btu per hour maximum permitted heat input
rate each)controlled by simple cyclone CD-BB1C followed by a bagfilter CD-BB1BH. 15A NCAC 2D
.0503 Particulates From Fuel Burning Indirect Heat Exchangers and 40 CFR 63 Subpart DDDDD
National Emissions Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional
Boilers and Process Heaters apply to the biomass boilers.
Air-Tech Environmental performed EPA Method 5 and 26A for PM and HCI, EPA Method 10 for CO,
and EPA Method 30B for Hg emissions. 63 Subpart DDDDD limits PM to 0.030 pounds per million Btu
(lb/mmBtu)heat input, limits HCI to 0.0221b/mmBtu, limits CO to 620 parts per million by volume on a
dry basis corrected to 3 percent oxygen(ppmvd@ 3%02), and limits Hg to 0.00000080 lb/mmBtu. The
results for the emissions testing are shown in the table below.
Pollutant Test Results Emission Limit Standard Compliance
Filterable PM 0,00151b/mmBtu 0.030 lb/mmBtu Yes
HCl 0.000068 lb/mmBtu 0.022 lb/mmBtu 63 Subpart Yes
CO 214 ppmv@ 3%02 620 ppmv 3%02 DDDDD Yes
Mercury 2.9E-71b/mmBtu 8.0E-7lb/mmBtu Yes
63 Subpart DDDDD Table 7 requires Avoca to"determine the highest hourly average of the three test run
averages during the performance test, and multiply this by 1.1 (110 percent)as [the] operating limit." The
maximum hourly average of the three test runs was 23,396 lb/hr steam. Therefore,the maximum
operating steam load is 25,735 lb/hr steam. For emissions sources with an applicable CO emissions limit,
Table 7 requires a minimum oxygen content value be established as"the lowest hourly average during the
performance test." The oxygen concentration and steam load data,including acceptable maximum steam
load value(as required by Table 7) are tabulated on the following page.

Robert Fisher
March 15,2017
Page 2
Parameter/Boiler Run 1 Run 2 Run 3 Average Approved Value
%02 BB 10.6 i 10.5 10.6 10.5 10.5%Minimum
%02 BB2 11.2 11.2 10.5 11.0 10.5%Minimum
Steam, lb/hr 22,979 23,026 23,396 23,134 25,735 lb/hr maximum
The test results are acceptable to demonstrate that the filterable PM,HCl, CO, and Hg emissions were in
compliance with the applicable emission limits during the testing period. If you have any questions
regarding this review,please contact me at Brent.HallCamcdenr.gov or(919)707-8427.
cc: Central Files, Bertie County
IBEAM Documents-0800044