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Home My WebLink AboutAQ_F_0800044_20161208_ST_ProtRvw (4) PAT MCCRORY Governor DONALD R. VAN DER VAART Secretary Air Quality SHEILA C. HOLMAN ENVIRONMENTAL QUALITY Director December 8, 2016 Dr. David M.Peele, Ph.D. President Avoca Incorporated PO Box 129 Merry Hill,NC 27957-0129 Subject: Avoca Incorporated,Tracking No. 2016-283ST Merry Hill,Bertie County,North Carolina,Air Permit No. 01819T46,Facility No. 0800044 Protocol for Filterable Particulate Matter(PM),Hydrogen Chloride(HCl),and Mercury(Hg) Emission Testing Biomass/Bio-based Solids-fired Boilers(ES-BB1 and ES-BB2) Proposed Test Dates: December 13 through 14,2016 To be performed by Air-Tech Environmental, LLC Dear Dr.Peele: The protocol submittal prepared by Air Tech Environmental has been reviewed for the proposed particulate matter(PM), carbon monoxide(CO),hydrogen chloride(HCl)and mercury(Hg) emissions testing and deemed acceptable. Testing is being conducted to meet the requirement of 40 CFR 63 Subpart DDDDD, ES-BB 1 and ES-BB2 are two biomass/bio-based solids-fired boilers(24 million Btu per hour maximum heat input rate each)controlled by one simple cyclone CD-BB 1 C in series with one dry lime injected bagfilter CD-BB 1BH. The boilers are subject to 15A NCAC 2D .0503 Particulates From Fuel Burning Indirect Heat Exchangers, 40 CFR 63 Subpart DDDDD National Emissions Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process Heaters and 40 CFR 60 Subpart Dc Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units. The pollutants and methods are tabulated below: Table 1: Proposed Test Methods for testing ES-BB1 and ES-BB2 EPA Pollutant Methods Run Time Standard Emission Limit ■Filterable Particulate(PM) 5/26A 3 runs 60 minutes each ■Hydrogen Chloride(HCl) 40 CFR 63 Subpart 40 CFR 63 Subpart DDDDD ■ Carbon Monoxide(CO) 10 3 runs,60 minutes each DDDDD ■ Mercury(Hg) 30B 1 3 runs,60 minutes each Prior to sampling, the tester must verify the absence of cyclonic flow as described in Section 11.4 of EPA Method 1. The tester must also conduct a stratification test as described in Section 8.1.2 of EPA Method 7E to determine the sampling points. The final report must include the process rate information as measured during testing with any supporting information needed to establish that the results are representative. State of North Carolina Environmental Quality Air Quality 1641 Mail Service Center � 217 W.Jones Street,Suite 4000 1 Raleigh,NC 27699-1641 919 707 8400 T Dr.David M.Peele,Ph.D.,President December 8, 2016 Page 2 Please note that when using EPA Methods 26A and 30B,the limits of detection are based on actual source parameters. There are no estimated detection limits in the protocol. Therefore,the responsibility will remain with Avoca and Air-Tech 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. Note audit samples analysis is required for EPA Method 26A. Air Tech has submitted an audit sample order request and the sample must be present for inspection on request during the test period. For additional information please see EPA web page https://www.epa.gov/emc/emc-technical-support. Avoca shall be responsible for ensuring, within the limits of practicality,that the subject sources are operated at or near maximum normal production rate approximately 90%to 100%of the maximum permitted heat input rate. The target process rate for testing will be 21.6 million Btu per hour for each boiler. The final test report should include information to establish that the near maximum normal requirement was met during the test period. The report must also include the applicable test period control system data(i.e. sorbent injection rate). Avoca will also reestablish the operating parameters for oxygen(02)and steam rate under 40 CFR 63 Subpart DDDDD. Approval of the protocol 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 remains 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 greg .og nealna,ncdenr.gov. Sincerely, i Thomas G. ONeal, III, P.E..Environmental Engineer Division of Air Quality,NCDEQ cc: Brian Conner, Avoca Incorporated-Merry Hill,NC Darrell H.Doerle,Air-Tech Environmental, LLC -Research Triangle Park,NC Robert Fisher,Washington Regional Office Central Files, Bertie County IBEAM Documents-0800044