AQ_F_1800419_20160207_ST_ProtRvw

PAT MCCRORY
Governor
DONALD R. VAN DER VAART
K" µ Secretory
Air Quality
ENVIRONMENTAL QUALITY SHEILA C. HOLMAN
Director
February 7, 2016
Mr. Rick Miller
2512 Penny Road
Claremont,NC 28610
Subject: Prysmian Cables and Systems USA, LLC
Claremont, Catawba County,North Carolina
Air Permit No. 07334T27, Facility ID 1800419
Proposed Test Date: Week of February 14, 2016
DAQ Tracking No. 2016-029ST and 2016-030ST
Dear Mr. Miller:
The North Carolina Division of Air Quality(NC DAQ)has reviewed your protocol submittal
form (PSF), and is approving the test plan as outlined below. For test report tracking purposes,
the NC DAQ has assigned two tracking numbers. Tracking No. 2016-029ST has been assigned
to the testing of the wet scrubber outlet(3WS) for halogens and particulate matter. Tracking No.
2016-030ST has been assigned to the inlet and outlet testing of the dry scrubber(2DS) for
nitrogen oxides (NOx). The discussion of each test series is provided below.
Tracking No. 2016-029ST
As required by permit conditions in Section 2.1.A.La, the reconfigured wet scrubber system
(3WS) outlet is being tested for particulate matter emissions and halogens after restart of these
emission sources and the reconfiguration and restart of the control equipment. The emissions
sources venting into the scrubber system include the chemical vapor deposition(CVD) cells 5, 6,
and 7 (ES-1), the chemical room (ES-11), the collapse furnaces for cells 5, 6, and 7 (ES-14). The
SiC14 storage room (ES-18, currently not operating), and the gas cabinets for cells 5, 6, and 7
(ES4-3WS). The wet scrubber is a variable throat venturi. The pressure drop range across the
scrubber is 10-15 inches of water. The permit specifies a minimum flow of 90 gallons per
minute (gpm) and a scrubber liquid pH of 8.0 or other value as determined from the performance
testing.
Particulate matter shall be sampled using EPA Reference Method 5. The emission rate shall be
compared with the allowable emission limits under 15A NCAC 2D.0515 (process weight). This
is the initial performance testing for particulate matter for this scrubber configuration. The
halogens consisting of hydrogen fluoride (HF),hydrogen chloride (HCl) and chlorine(Cl) shall
be sampled using EPA Method 26A. The emissions data from the Method 26A shall be
compared with 15A NCAC 2Q.0317 (MALT Avoidance) as specified in the permit. As noted in
the PSF, an audit sample is required for the Method 26A testing. Each run for shall be at least 60
State of North Carolina I Environmental Quality I Air Quality
1641 Mail Service Center 1 217 W.Jones Street,Suite 4000 1 Raleigh,NC 27699-1641
919 707 8400

Mr. Rick Miller
February 7, 2016
Page 2
minutes in length for both testing methods. The number of sampling points and location shall be
in accordance with EPA Method 1. Based upon the information provided, NC DAQ approves
the use of air as the gas characteristic for molecular weight determination.
Tracking No. 2016-030ST
As required by permit conditions in Section 2.1.A.Lb,performance testing is being conducted on
the hydrated lime dry scrubber(2DS) that control emissions NOx emissions from the over-
cladding units for cells 6, 7, and remaining cell 5 units. A minimum lime feed rate of 30 pounds
per hour is specified in the permit. The testing is proposed at the inlet and the outlet of the dry
scrubber using EPA Reference Method 7E to determine the NOx emission rate. The emission
rate of NOx shall be compared to a Prevention of Significant Deterioration (PSD) avoidance
limit under 15A NCAC 02D.0530.
A single point test is proposed for Method 7E and is allowed by the method if the requisite
stratification check included in the method is conducted. In addition to Method 7E, an EPA
Method 205 dilution system is proposed to provide the monitor calibration gases. An NOx
calibration range of approximately 500 ppm is specified in the PSF. EPA Methods 1-4 are also
proposed in support of the method 7E testing. The testing period for Method 7E is three runs of
60 minutes each. The testing period for Methods 1-4 is proposed at three runs of 30 minutes
each. This is acceptable provided the flow characteristics are not varying over the test period.
In summary, the proposed testing is approved. Since no variations from the test methods was
requested, testing must be conducted in strict accordance with the reference methodology.
Documentation of operating values during the test must be provided in the final test report. If you
have questions, please contact me at(919) 707-8413 or [e-mail].
Sincerely,
Gary L. Saunders
Environmental Engineer
Division of Air Quality,NCDEQ
cc: Ron Slack, Mooresville Regional Office
Central Files, Catawba County
IBEAM Documents- 1800419