AQ_F_1300002_20160324_CEM_RptRvwLtr (3)

PAT MCCRORY
Governor
Ic-
DONALD R. VAN DER VAART
Secretary
Air Quality SHEILA C. HOLMAN
ENVIRONMENTAL QUALITY Director
March 24, 2016
Mr. Chad VonCannon, P.E.
Assistant Engineering Director
WSACC Rocky River Regional WWTP
P.O. Box 428
Concord,North Carolina 28026-0428
SUBJECT: Review of 2015 Second Semester CEMS Report
WSACC Rocky River Regional WWTP
Concord, Cabarrus County,North Carolina
Permit No. 04475R19
Facility ID: 1300002
Dear Mr. VonCannon:
Thank you for your timely submittal of the subject report, dated February 17, 2016, from the
Water and Sewer Authority of Cabarrus County (WSACC) Rocky River Regional Wastewater
Treatment Plant (WWTP). The report included an assessment of the total hydrocarbon(THC)
and carbon monoxide (CO) /oxygen (02) continuous emissions monitoring systems (GEMS)
operating on the sewage sludge incinerator(ID No. 1) during the second half of 2015. The
Division of Air Quality(DAQ)has completed its review and offers the following comments:
1. The report was reviewed for compliance with the THC emission limit (100 ppmvd, corrected
to 7% 02, monthly average)pursuant to 15A NCAC 02D .1204 -Sewage Sludge and Sludge
Incinerators, 40 CFR Part 503, Subpart E -Standards for the Use or Disposal of Sewage
Sludge, and Air Permit No. 04475, specific condition A.14.a. There were no reported
exceedances of the THC limit.
2. A review was also conducted for compliance with proper operation and maintenance (O&M)
practices pursuant to permit specific conditions A.5, A.10 and A.18; 15A NCAC 02D .1204,
which includes the monitoring provisions of 02D .0600 and 02D .0611(d). When expressed
as a percentage of the total operating time of the sewage sludge incinerator, percent excess
emissions (%EE) and percent monitor downtime (%MD) were reported as follows:
Unit Quarter Monitor %EE %MD
3rd THC 0.0 0.5
Sewage Sludge 3rd CO/02 -- 0.1
Incinerator 4th THC 0.0 7.2
(ID No. 1)
4th CO/02 -- 1 7.1
State of North Carolina I Environmental Quality I Air Quality
1641 Mail Service Center 1 217 W.Jones Street,Suite 4000 1 Raleigh,NC 27609-1641
919 707 8400 T

Mr. Chad VonCannon
March 24, 2016
Page 2
3. DAQ considers sources whose %EE and%MD are less than 6% for any single calendar
quarter and less than 3% for two consecutive quarters to have operated with proper O&M
practices for minimizing emissions. As indicated in our Notice of Deficiency, dated March
16, 2016, the %MD for the THC and CO/02 CEMS exceeded the 6%target criteria during
the fourth quarter of 2015.
4. For the third quarter, THC and CO cylinder gas audits (CGAs)were conducted in accordance
with specific condition A.9.b and 40 CFR Part 60, Appendix F - Quality Assurance
Procedures. Each CEMS appears to have met the 15% accuracy requirement. For the fourth
quarter, our office has noted that WSACC successfully passed the relative accuracy test audit
(RATA) conducted on October 28, 2015.
If you should have any questions,please contact me at [phone] or [e-mail].
Sincerely,
ti.
Alan Drake, Environmental Engineer
Division of Air Quality,NCDEQ
c: Ron Slack, MRO
Mike Pjetraj, RCO
IBEAM Documents, 1300002
Central Files, Cabarrus County