AQ_F_2100073_20130712_ST_ProtRvw (4)

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RCDENR
North Carolina Department of Environment and Natural Resources
Division of Air Quality
Pat McCrory Sheila C. Holman John E. Skvarla, III
Governor Director Secretary
July 12,2013
Mr. Don Wynne
Domtar Paper Company,LLC
P.O. Box 787
Plymouth,North Carolina 27962
Subject: DOMTAR Paper Company,Plymouth,Martin County,NC
Air Permit No. 04291T39; Facility ID No. 5900069
Protocol for Filterable Particulate Matter,Particulate Matter less than 2.5 microns, Condensible
Particulate Matter, and Sulfur Dioxide Emissions Testing of Hog Fuel Boiler No.2 by TRC
Environmental,Inc.
Proposed Test Date: Week of July 15,2013
Tracking No. 2013-114 ST
Dear Mr. Wynne:
The North Carolina Division of Air Quality(DAQ)has reviewed the protocol submittal form(PSF)for
emissions testing of filterable, condensible particulate matter(PM),PM less than 2.5 micons(PM2.5),
and sulfur dioxide(S02). The source to be tested is the Hog Fuel Boiler No. 2 (ID No ES 65-25-0310),
which combusts hogged fuel, lignin, sludge distillate and residual fuel oil,and natural gas. In addition,
the boiler serves as the primary destruction device for the combustion of high volume, low concentration
non-condensible gas(HVLC NCG). Emissions from the boiler are controlled by a multicyclone(I.D.
Nos. CD-65-45-0100)and then by three parallel electroscrubbers (I.D.Nos. CD-65-60-0120, CD-65-60-
410, CD-65-60-0610). The proposed test is being conducted as a requirement of the permit after lignin
has been added to the fuel mix. The protocol requests that the test be conducted with the use of natural
gas in place of or in addition to oil to reflect future operations of this boiler with supplemental natural gas.
The proposed testingis's acceptable only as discussed below.
Testing will be performed in order to meet the permit requirements and emission limits:
Source Pollutant Test Method
Volumetric Flow Rate EPA Method 2
Oxygen, Carbon Dioxide EPA Method 3A
Hog Fuel Filterable Particulate Matter EPA Method 5
Boiler 2 Condensible Particulate Matter EPA Method 202
PM 2.5 EPA Method 201 A
Sulfur Dioxide EPA Method 6C
1641 Mail Service Center,Raleigh,North Carolina 27699-1641
217 West Jones Street,Raleigh,North Carolina 27603
Phone:[phone]/Fax:[phone]
Internet:v✓ww.ncair.0rg
An Equal Opportunity\Affirmative Action Employer—Made in part by Recycled Paper

Mr. Don Wynne
July 12, 2013
Page 2
The maximum permitted process rate is 889 million BTU/hr(MMBtu/hr)when firing any combination of
fuels. The nonnal process rate is between 250 to 400 thousand pounds of steam per hour. The target rate
is 275 and 375 thousand pounds of steam per hour. The proposed process rate is acceptable. Process
monitoring will be provided by the mill's information system,IP21,Process Explorer. The PSF indicates
that the Method 201A testing will be conducted while burning hog fuel only. The Method 5/202 testing
will be conducted with mixtures of fuels. A larger sample voume and nozzle size will be used for the
Method 5/202 sampling. This is acceptable.
The final test report should include the actual process rate data during the emission tests as well as any
control system parameters such as voltage across the electroscubbers. The test report should clearly
identify the test results as being representative of normal operations. One run must include sootblowing
In conclusion,the proposed test methods are acceptable. Approval of the testing protocols does not
exempt the tester from the minimum requirements of the test methods. Any deviations from the methods
remain subject to approval by DAQ. If you have any questions regarding the results of this review,please
contact me at(919) 707-8413 or at [e-mail]
Sincerely,
Gary L. Saunders
Environmental Engineer
cc: Robert Fisher, Washington Regional Office
Central Files,Martin County
Michael Worthy, TRC Environmental,Inc.
IBEAM Documents
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