AQ_F_0800044_20121207_CMPL_AltTMRR

A74LA..
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Air Quality
Beverly Eaves Perdue Sheila C. Holman Dee Freeman
Governor Director Secretary
December 7, 2012
Dr. David Peelle
President
Avoca Incorporated
Post Office Box 129
841 Avoca Farm Road
Merry Hill,NC 27957
SUBJECT: Boiler NESHAP Testing Requirements—Dioxin/Furan Test Waiver Response
Air Quality Permit No. 01819T38
Avoca Incorporated
Facility ID: 0800044, Merry Hill, Bertie County
Facility Classification: Title V
Dear Dr. Peele:
The DAQ has received and is responding to your letter dated November 15, 2012. In
your letter, you stated that Avoca is preparing to re-test the boilers that failed the particulate test
in June of 2012. You have indicated that you plan to perform all emissions tests required except
for the dioxin/furan test. On March 16, 2012, the DAQ waived the test requirement for
dioxin/furan due to the December 23, 2011 Boiler MACT proposed revisions that would
eliminate dioxin/furan testing and instead use CO as a surrogate to insure compliance with
volatile HAPs. Avoca demonstrated compliance with the CO emissions standard on June 26,
2012. The simultaneous failure of the particulate test appears to be related to control device
issues and not combustion issues. Therefore, the DAQ believes that the June 2012 CO test is
valid although we are requiring re-testing for CO concurrent with PM testing.
The DAQ will consider your request under the performance test waiver provisions of
63.7(h)(3)(ii).
The rule states in 63.7(h)(4):
(4)Approval of request to waive performance test. The Administrator will approve or
deny a request for a waiver of a performance test made under paragraph (h)(3) of this
section when he/she-
(i)Approves or denies an extension of compliance under 63.6 i 8 ; or
(ii)Approves or disapproves a site-specific test plan under§63.7(c)(3); or
Technical Services Section
1641 Mail Service Center,Raleigh,North Carolina 27699-1641 One
217 West Jones Street,Raleigh,NC 27603 NorthCarolina
Phone: [phone]/FAX [phone]/Internet: www.ncair.org Aaturally
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper

Dr. David Peele
December 7, 2012
Page 2
(iii) Makes a determination of compliance following the submission of a required
compliance status report or excess emissions and continuous monitoring systems
performance report; or
(iv)Makes a determination of suitable progress towards compliance following the
submission of a compliance progress report, whichever is applicable.
The DAQ will grant a waiver of the dioxin/furan source test under the provisions of
63.7(h)(4)(iii) once the CO testing has been performed, and the compliance with the CO
emission standard, as a surrogate of dioxin/furan, is demonstrated. If the sources cannot
demonstrate compliance with the CO limit,then dioxin/furan testing may be required if the
3/21/11 rule is still in effect.
If you have any other questions regarding this letter, please contact Michael Pjetraj, P.E., at 919-
707-8497.
Sincerely!.---
---" L Darnel hief
T chnical Services Section
Cc: Central Files
Ec: Rob Fisher—WARO Supervisor
Michael Pjetraj —SSCB Supervisor
Don van der Vaart—Permits Chief

A74LA..
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Air Quality
Beverly Eaves Perdue Sheila C. Holman Dee Freeman
Governor Director Secretary
December 7, 2012
Dr. David Peelle
President
Avoca Incorporated
Post Office Box 129
841 Avoca Farm Road
Merry Hill,NC 27957
SUBJECT: Boiler NESHAP Testing Requirements—Dioxin/Furan Test Waiver Response
Air Quality Permit No. 01819T38
Avoca Incorporated
Facility ID: 0800044, Merry Hill, Bertie County
Facility Classification: Title V
Dear Dr. Peele:
The DAQ has received and is responding to your letter dated November 15, 2012. In
your letter, you stated that Avoca is preparing to re-test the boilers that failed the particulate test
in June of 2012. You have indicated that you plan to perform all emissions tests required except
for the dioxin/furan test. On March 16, 2012, the DAQ waived the test requirement for
dioxin/furan due to the December 23, 2011 Boiler MACT proposed revisions that would
eliminate dioxin/furan testing and instead use CO as a surrogate to insure compliance with
volatile HAPs. Avoca demonstrated compliance with the CO emissions standard on June 26,
2012. The simultaneous failure of the particulate test appears to be related to control device
issues and not combustion issues. Therefore, the DAQ believes that the June 2012 CO test is
valid although we are requiring re-testing for CO concurrent with PM testing.
The DAQ will consider your request under the performance test waiver provisions of
63.7(h)(3)(ii).
The rule states in 63.7(h)(4):
(4)Approval of request to waive performance test. The Administrator will approve or
deny a request for a waiver of a performance test made under paragraph (h)(3) of this
section when he/she-
(i)Approves or denies an extension of compliance under 63.6 i 8 ; or
(ii)Approves or disapproves a site-specific test plan under§63.7(c)(3); or
Technical Services Section
1641 Mail Service Center,Raleigh,North Carolina 27699-1641 One
217 West Jones Street,Raleigh,NC 27603 NorthCarolina
Phone: [phone]/FAX [phone]/Internet: www.ncair.org Aaturally
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper

Dr. David Peele
December 7, 2012
Page 2
(iii) Makes a determination of compliance following the submission of a required
compliance status report or excess emissions and continuous monitoring systems
performance report; or
(iv)Makes a determination of suitable progress towards compliance following the
submission of a compliance progress report, whichever is applicable.
The DAQ will grant a waiver of the dioxin/furan source test under the provisions of
63.7(h)(4)(iii) once the CO testing has been performed, and the compliance with the CO
emission standard, as a surrogate of dioxin/furan, is demonstrated. If the sources cannot
demonstrate compliance with the CO limit,then dioxin/furan testing may be required if the
3/21/11 rule is still in effect.
If you have any other questions regarding this letter, please contact Michael Pjetraj, P.E., at 919-
707-8497.
Sincerely!.---
---" L Darnel hief
T chnical Services Section
Cc: Central Files
Ec: Rob Fisher—WARO Supervisor
Michael Pjetraj —SSCB Supervisor
Don van der Vaart—Permits Chief