AQ_F_0800044_20170417_ST_ProtRvw

ROY COOPER
Governor
MICHAEL S. REGAN
Kf Secretary
Air Quality MICHAEL A. ABRACZINSKAS
ENVIRONMENTAL QUALITY Director
April 17, 2017
Mr.Brian Conner
P.O.Box 129
Merry Hill,NC 27597
Subject: Avoca Incorporated
Merry Hill,Bertie County,North Carolina
Facility ID 0800044,Permit No. 01819T47
Proposed HAP Compliance Testing Protocol for ES4000-WW Operations
Submitted by Air-Tech Environmental
Proposed Test Date: May 10,2017
DAQ Tracking No. 2017-116ST
Dear Mr. Conner:
The protocol submittal form(PSF) submitted by Air-Tech Environmental(ATE)has been reviewed by
the N.C.Division of Air Quality(DAQ). The proposed EPA Method 18 gaseous organic compound
(hexane)testing for Sclareolide operations, ID No.ES-4000-WW(SDE-2), is conditionally acceptable as
discussed in this letter. The test is the initial hazardous air pollutant(HAP)compliance test for the
Sclareolide operations.
SDE-2, ID No.ES-4000-WW, operations include one chilled water condenser(ID No. CD-4002) in series
with a mineral oil scrubber(ID No. CD-4003-S)controlling emissions from the following:
• One 17,900 gallon virgin solvent tank(ID No. T-4001);
• Two 6,000 gallon process tanks(ID Nos. T-4017 and T-4018);
• One 4,200 gallon reactor with process condenser(EX-4001)(ID No.R-4004);
• One 4,200 gallon reactor with process condenser(EX-4002)(ID No. R-4005);
• One 4,200 gallon reactor with process condenser(EX-4003)(ID No. R-4044);
• One 1,500 gallon reactor(ID No. R-4015); and
• One centrifuge(ID No. C-4001)
40 CFR 63 Subpart FFFF National Emission Standards for Hazardous Air Pollutants:Miscellaneous
Organic Chemical Manufacturing and 15A NCAC 2D .1111 Maximum Achievable Control Technology
applies. Table 2 of Subpart FFFF states "the Permittee shall reduce collective uncontrolled organic HAP
emissions from the sum of all vents within SDE-2 operations by>95 percent by weight by venting
emissions from a sufficient number of the vents through one or more closed-vent systems to the chilled
water condenser(ID No. CD-4002) in series with the mineral oil scrubber(ID No. CD-4003-S)."
ATE has proposed using EPA Method 18 to characterize the total organic compound removal efficiency
of the control devices controlling the exhaust. The PSF indicates the concentration of hexane in the vent
streams is currently unknown. However,hexane is expected the be the sole organic that is detectable.
ATE proposes preparing gas chromatograph (GC)"calibration standards on site from n-hexane using the
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
i

hot impinger procedure of Method 18. Verification of the standards made on site will be performed by
comparison to a single hexane mixture bought from a third-party manufacturer. The concentration of the
secondary standard will approximate the anticipated inlet gas concentration." The proposed preparation
of calibration standards on site is conditionally acceptable provided the third-party manufacturer hexane
is a protocol gas.
ATE also proposes to employ gas stream spiking of methane to measure flow rate through the system.
This modification is allowed provided the methane spiking is performed by a calibrated,verifiable
dilution system and flow meter. The PSF also states the results may be used in emission inventories and
future permit applications. NCDAQ will not allow the use of this data for mass emission rates or use in
future permit applications unless a valid QAiQC protocol is included that governs the methane injections.
All operational data such as the mineral oil temperature,water condenser gas stream exit temperature, and
vent flow rates should be included in the final test report. The proposed modifications and variances to
the sampling are approved including the above stated conditions. Approval of the protocol does not
exempt the tester from the minimum requirements of the applicable method. If you have any questions
regarding this protocol review,please contact me at brent.hallCancdenngov or(919) 707-8427.
Sincerely,
Brent W. Hall
Environmental Engineer
Cc: David M. Peele, President,AVOCA
Darrell Doerle, Air-Tech
Robert Fisher,Washington Regional Office
Central Files, Bertie County
IBEAM Documents, 08-00044
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