AQ_F_0800044_20130221_ST_STO-Rpt

NORTH CAROLINA DIVISION OF Washington Regional Office
AIR QUALITY Avoca Incorporated
NC Facility ID 0800044
Stack Test Observation Report County/FIPS:Bertie/015
Date: 03/15/2013
Facility Data Compliance Data
Avoca Incorporated Observation Date 02/20/2013
841 Avoca Farm Road Observer's Name Robert Fisher
Merry Hill,NC 27957 Operating Status Operating
Lat: 36d 0.0030m Long: 76d 42.6550m Action Code 23/STACK TEST
SIC: 2087/Flavoring Extracts And Syrups,nec OBSERVED
NAICS: 31193/Flavoring Syrup and Concentrate Manufacturing
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 01819/T39
Brian Conner David Peele Brian Conner Issued 1/4/2013
Environmental Health& President Environmental Health& Expires 7/31/2015
Safety Manager [phone] Safety Manager Classification Title V
[phone] [phone] Permit Status Active
Inspector's Signature: Comments:
Robert P.Fisher All testing appeared to be in accordance with the
Date of Signature:
approved protocol and EPA test methods.
� 1� C3
Directions from WaRO
Take US-17 N and turn right onto NC 171 N. Continue to Jamesville,NC. Turn right onto US-64 E.
Travel east through Plymouth and make a left onto NC 45 N at the Pines Elementary School. Travel
north on Hwy 45 and take a right onto Avoca Farm Road (SR 1502) (East) [signs to Avoca Farms &
Merry Hill]. Pass through Merry Hill and continue on Avoca Farm Road for several miles. The plant is
on the left. *
Facility Summary
a Avoca Inc. extracts oils and nutrients from various plants for use in perfume and as food additives.
The facility's primary product is sclareol that is extracted from sage. They provide nutrient
extractions for baby food and other food industries. They also produce crude Taxoll, which is an
active ingredient for an anti-cancer drug.
Facility Safety
Required PPE: safety-toe shoes,hard hat, ear protection. No cell phones are allowed in the production
plant.
Pre Inspection Meeting
I met with Brian Conner. I met Sam Tynch, Director of Operations. Brian showed he has the permit and
the recently signed civil penalty assessment for the previous test failure. He told me the sources were
operating as follows:
1. The Rotocel Operation was not operating.
2. The Recovery Operations were not operating,
K:\Bertie08\00044\20130221-biomss boilers stack test.doc Page 1 of 4

C
3. the Concrete Operations were not operating,
4. the Sclareol Recrystallization (SFG) Operations was operating,
5. the Biological Conversion Equipment for Purification of Sclareolide not operating,
6. the Sclareolide (SDE) Operations were operating,
7. the Plant Nutrient Extraction(PNE) Operations not operating,
- 8. The Ethyl Vanillin Glucoside (EVG) Operations were operating,
9. the Botanical Extraction Operations were operating,
10. the Biomass Extraction Operations were operating
a. (Extracting krill oil),I could smell a slight fishy odor on the yard.
11. Miscellaneous Operations
a. Two No. 2 fuel oil-fired boiler(20.3 million Btu)not operating
b. One No. 2 fuel oil-fired boiler(25.2 million Btu p)not operating
c. Two biomass/bio-based solids-fired boilers (18.6 million Btu)were running for the
test
d. One No. 2 fuel oil-fired rotary dryer(6.0 million Btu)not operating
e. One No. 2 fuel oil-fired limited use emergency generator(2,935 kw)not operating,
f. the wastewater plant was operating, -
g. Four No. 2 fuel oil-fired emergency generators were not operating
{ On Thursday February 21, 2013, I,Robert Fisher of the Washington Regional Office, attended the
emissions testing of ES-13131 and ES-BB2, two biomass/bio-based solids-fired boilers controlled by
simple cyclone CD-BB 1 C in series with one dry lime injected bagfilter CD-BB 1 BH at Avoca Inc.
ES-BB 1 is designated the"South"boiler and ES-13132 is designated the "North"boiler. The
maximum permitted heat input rate is 18.6 million Btu per hour per boiler. The boilers are permitted
to burn wood waste and sage from the sclareolide operations to produce process steam. The plan ,
1 is/was that sage will be fired during the harvest season(approximately June through August), then
wood will be fired from September through May. No other fuels are permitted to be fired in the
boilers.
jWood chips are brought on site and stored year round. Currently the facility is bringing in 4
truckloads of wood chips each day ("though it's less now since the Rotocell is down"). The boilers
are"base-loaded", meaning that they will always run and the oil-fired boilers will be brought on-line
as required by an increase in steam-demand.
Before the inspection I met with Brian Conner to discuss the plans for the test. Brian explained that
they have been running since February 8, when the auger was repaired. He mentioned that all of the
bags in the baghouse (fiberglass with a PTFE membrane)had been replaced in January (last month).
Later Jerry Finely, Boiler Engineer, showed pictures of some of the old bags that appeared to be
covered in a heavy crust and some had small holes. Brian and I also found what we believed were
the remains of some of the bags in a large cardboard box in a storage building near the main office.
40 CFR 60 Subpart Dc Standards of Performance for Small Industrial-Commercial-Institutional
Steam Generating Units and 40 CFR 63 Subpart DDDDD National Emissions Standards for
Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process
Heaters apply to the biomass boilers. Permit Condition 2.1.E. requires emissions testing to be -
performed annually, then tri-annually. The purpose for the testing is to demonstrate
K:\Bertie08\00044\20130221 biomss boilers stack test.doc Page 2 of 4

compliance with 40 CFR 63 Subpart DDDDD emissions limits and to establish boiler
monitoring and control parameters.
The testing was performed by AIR-TECH Environmental,LLC of Raleigh,NC. Darrell Doerle operated
the gas analyzers in the test trailer and Willie Gorgan was on the stack. They used EPA Method 5/26A
for filterable particulate matter and hydrogen chloride, Method 10 was performed for CO, and Method
30B was performed for Mercury emissions. EPA Methods 1, 2, 3A, and 4 were also performed to
determine exhaust gas flow rate, moisture, and molecular weight. Air-Tech used 16 traverse points
based on the reported stack dimensions. AVOCA personnel on hand for the test were Brian Conner,
Environmental,Health, & Safety Manager; Greg Bozwell and Mark Mizell, Boiler Operators, and Jerry
Finely, Boiler Engineer.
This test consisted of three 60-minute sampling runs. The first run commenced at 9:22 a.m. The boilers
-appeared to be running at capacity. These conditions appeared to be maintained fairly closely until
testing was complete. I observed the Boiler Control panel (SCADA) which showed information about
the steam pressure and oxygen(pictured). Beside the SCADA on the north boiler another panel
(UniComfort System)that displayed a CO reading (however Jerry explained that it was not connected).
It also displayed the Stack temps were as follows: ES2 (north) 240 deg C &ES 1 (south) 218 deg C. A
meter displayed steam—15k lbs/hour, —150 psi steam header pressure, and stack temperature of 290 deg
F. The Boiler Exhaust & Dryer Control Panel system control panel showed gas temperatures across
system(pictured). I did not discover the actual heat input and actual steam flow at the time believing
that this information would be forthcoming in the test report from Avoca.
I observed multiple momentary opacity observations during the test; all of which showed 0% opacity.At
11:57 am I conducted a 6-minute VE observation which showed 0% opacity (pictured). I also observed
the ash handling trailer that was covered. The small observation hole in the front of the trailer was open,
however this trailer is not pressurized and I observed no visible emissions from the observation hole
(pictured).
I observed what was labeled"broken bag level" indicator located on the wall near the wood chip
conveyors. It was currently reading a pressure drop of 7 inches water. Jerry Finely said the label was
correct. Also on the same wall was a chart indicating the "real" broken bag detector in the stack.
The three test runs were to be performed, one after the other with boiler load being held constant and
calibration&leak checks being run between each set of data. During each run,a data logger and a
series of analyzers were used to record data for CO, 02, and CO2. No problems were noted with the
data collection or operation of the boiler during the three test runs I observed. The table below
summarizes observed data from the three runs.
RUN START VE Average Averag Average Leak Bias
TIME CO (ppm) 02 (ppi CO2 (ppm) Check
1 9:22 0 57.2 uncor. 11.3 8.23 0.1 123
2 10:55 0 16.2 11.9 8.0 0.0 118
3 12:35 0 12.8 11.3 8.95 0.1 122
post 0.0 119
K:\Bertie08\00044\20130221-biomss boilers stack test.doc Page 3 of 4

Part of this test was to establish operating parameters which the facility could monitor(02)whichiwould
ensure emission limits were being met. So,the 02 analyzer readings taken by the testers will be
compared to the in-line 02 monitor readings of the plant. A spot-check comparison showed that the
analyzer read 11.3 ppm and the in-line monitor indicated 13.2 ppm. A complete analysis will be
provided in the stack test report.
I observed Brian Conner perform wood fuel sampling. He collected at least 12 half-full gallon-size
Ziploc-type bags of wood chips from random points around perimeter of the pile. The samples will be
sent to an off-site lab for analysis.
ATTACHMENTS
1. EPA Method 5 Visible Emissions Evaluation
2. Photos. See\\NROARI IWOLI\DATA\DAO\PICTURES 2013\08 Bertie\Facilities\Avoca\20130221 Avova
Stack Pics by R.Fisher.doc
3. (2)PRAXAIR Cal Gas Certifications for 123ppm & 225ppm CO.
COMMENTS/CONCLUSIONS
j Both of the new biomass boilers appeared to be operating near capacity for the test. All testing appeared
to be in accordance with the approved protocol and EPA test methods.
Note: I did not complete a NC DAQ Method 5 Observation Checklist or NC DAQ CEM Observation
Checklist
WaRO waits on the Stationary Source Compliance Branch acceptance before concluding
compliance from the stack test performed.
*The data included in this report are original observations by me, Robert Fisher. However much of the text of this report is
taken from prior reports submitted by Arni Hopkins for the stack test conducted on 6126112 and other inspections.
Follow Up
On March 26, 2013 Brain Conner called me and requested a conference call On April 1, 2013 to discuss
the parameters observed during the test. He indicated that the results from the test show compliance with
the monitored pollutants.
K:\Bertie08\00044\20130221-biomss boilers stack test.doc Page 4 of

Avoca Source Test Photos February 21, 2013 All photos taken by Robert Fisher
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2013-02-21 Stack Test Co
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2013-02-21 VEO location No VE
H:\DATA\DAQ\_ADMIN\Temp\20130221 Avova Stack Pics by R.Fisher.doc Page 1 of 4

Avoca Source Test Photos February 21, 2013 All photos taken by Robert Fisher
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2013-02-21 South Boiler Pressures
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2013-02-21 North Boiler Pressures
H:\DATA\DAQ\_ADMIN\Temp\20130221 Avova Stack Pics by R.Fisher.doc Page 2 of 4

Avoca Source Test Photos February 21, 2013 All photos taken by Robert Fisher
2013-02-21 firebox peep2
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H:\DATA\DAQ\_ADMIN\Temp\20130221 Avova Stack Pics by R.Fisher.doc Page 3 of 4

Avoca Source Test Photos February 21, 2013 All photos taken by Robert Fisher
OF
2013-02-21 Ash trailer front No VE
2013-02-21 Ash trailer side
H:\DATA\DAQ\_ADMIN\Temp\20130221 Avova Stack Pics by R.Fisher.doc Page 4 of 4

I
I
VISIBLE EMISSION OBSERVATION FORM No. I,
COMPANY NAME 108SERVATION ATE START TIME END TIME
A-vc Z LI f3 1 v. 1 12-,-03
b.R ET�ADDRESS � MI E 0 15 30 45 MI E 0 15 30 45
�6 0 b 17
CITY STATE I 17 i7 2
IV . . Y�T
3 0 0 S 3 33 a
HONE KEYCONdACi - - OUR iG•NO..•.•.•.•.• .• . •.•.-
�3`'Z--��z--.� .13.3 ems•(�s�'(' : . :'. . -0 b © 3
rRVSSE UIPME T PERA NG-MODE'.'-'. 5 35
ONTP.OL EO UIP E PERARNO.M 6 �p m '0 36
7 77
ESCRIBE EMISSION POINT g 38
14 1 40
HEIGHT ABOVE GROUND EIGHT RELATIVE TO OBSERVER 11 41
6a I La
ISTANCE FROM OBSERVER IRECTION FROM OBSERVER 12 42
I art'�'100 k&Eno fart �? 43
ESCRIBE EMISSIONS
trrt C'y¢W (.iloC`UiS End 14 44
MISSION COLOR WATER, DROPLET PLUME i5 45
,art rtfached
b0' End Cl VA Detached ❑ 16 46
OINT IN THE PLUME AT WHICH OPACITY WAS DETERMINED
i
,start •� � End S , 17 41
ESCRIBE PLUME BACKGROUND ig 48
I t r o �"� n 19 49
I6ACKGR ND Cu OR KY CONDITION
i
tart End fart (tV'`r End 20 50
LNG SPEED IND DIRECTION
'•Iarf �� End -fart End 2 5t
MBIENT TEMP BULB TEMP'- ' R4.pefoeM;• ;• ' ,,
Iar'. -V�S End . . 52
Stack SOURCE LAYOUT SKETCH Draw North Arrow
with (I r� 24 54 Plume I !V I . .
15Un I )5 S5
Wind L6 56
loEnission Point I 27 I 57
28 I SS 1
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29 59
I I 30 60
OBSERVER'S N .E
Observer's Position �s�--
OBSERVER'S SIGNAT ` _ �DAATE'• '•'• •3.:;
— — — — — — ® RGANIZATIONA rL
Sun Locat;on line Jv l}
A01)ITIONAC aNFORMATIQN;- '-'. '. '. '. ' . . ' . . ' .'- . ' . '. '. 'EREJFIEB 6Y; : ATE
: : : : : ; Ot1iINUED ON VEO.FORM-NUMBER; . .•. • .-. •. •. . . . . . . . . . .. . ..
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AQ-23 Rev. 11-20-87

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plR Praxair Distribution Mid-Atlantic
/) y h� I45 Shimersville Rd.
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DocNumber: 000013644 � Q��r✓` v Facsimile: [phone]
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Customer&Order Ilrforination:
CHEROKEE INSTRUMENTS INC* Praxair OrderNumfier: 17906416 FiRDate W012011
901 BRIDGE ST CustomerP.D.Number: 11496 ParlNimiherr NIC012SE-AS
FUQUAY VARINA NC 275260 Customer Reference Number: Lof Vunibm 917125333
CylWorSfyle&Outlet AS CGA350
Certified Concentration: Cylinder Premtre&Yahrere: 2000 psig 140 cu,ft.
Expiration Date: 1312014 NIST Traceable
Cylinder Number: SA14630 t/ Analytical Uncertainty:
123 ppm CARBON MONOXIDE f 1%
Balance NITROGEN
Certifcadon Information. CertiBcatlon Date: 101Y2011 Term: 36 Months Expiration Date: 10/3/2014
This cylinder was Certified according to the 1997 EPA Traceability Protocol,Document#EPA-600fR-971121,using Procedure G1
Do Not Use this Standard if Pressure is less than 150 PSIG
PGVP ID#F12011 i
Analylical Dala: (R=Rakiance Standard,2=2ero Gas,C=Gas Candidate)
1. component: CARBON MONOXIDE Reference Standard Tyli GMIS
Requested Concentration: 125 Ref.Std.Cylinder#: CC239392
Certified Concentration: 1 3 Ref.Sid.Cone: 195 PPM
Instrument Used: HORIBA VIA-3000 SIN Y9EY78L6 Ref.Std.Traceable to SRM#: 166012
Analytical Method:. NDIR SRMSample#: 21.1-05.
Last MultipointCalib'ratiort 912 212 01 1 SRM Cylinder#: CAL015749
First Analysts Data: Date: 912412011 - Second Analysis Data: Date: 1013120i 1 i
Z: 0 R: 194 C: 124 Cone: 123.79 M 0 R: 195 C; 124 Colic: 123.37
R: 196 Z: 0 C: 124 Cone: 123.79 R: 196 Z: 0 0:. 124 Colic: 123.37
z: 0 C: 124 R: 195 Cone: 123.79 Z: 0 C: 124 R: 196 Colic: 123.37
li PPM Mean Test Assay: 123,79 PPM UOM: PPM Mean Test Assay: 123.37 Pi
Analyzed by: r�l\ � Certified by: n,
Asj-
Vil Robin Morgan
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Information contained herein has been prepared at your request by qualified experts wthin Praxair Distribution,Inc.While we believe that the,information is accurate within the limits of the analytical
methods employed and is complete to the extent of the specific analyses performed,we make no warranty or representation as to the suitability of the use of the Information for any purpose. The
information is offered with the understanding that any use of the information is at the solo discretion and risk of the user. In no event shall the liability of Yrexair Distribution,Inc.,arising out of the
use of the information con tained herein exceed the fee established for providing such information.

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IPRAX 41R �/' Ptrtzeir Distribution Mid-Atlantic
hy� '✓ v ' 145 Shimetsvil16 Rd.
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'Telephone: [phone]
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gxr�^ FaCSimitc: (Gl0 758-8382
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,901`BRIDGE:ST Cuvomel-P.O.'Naiuber: 11207 PartNumben N160226E-As
FUQUAY VARINA NC 275260 Custoslet-Reference,Nainher: lot Number. 917107637
- . CylhitkrS8•leAOurkh AS: CGA350
Cyllmler Pre ire k I ahmicr 2000 psig 140 eu.ft.
CerllJied Coltcelttrodon:
Expiration Date: 3/29/2014 NISI Traceable
Cylinder Number: CC350375 Analytical Uncertainly:
226.7 ppm CARBON MONOXIDE t 1%
Balance NITROGEN
I
Cerlf/cal1011 Information. Certification Date: 3/29/2011 Term? 36 Months EXplret/on Date: 3/29/2614
i This cylinder Was certified according to the 1997 EPA Traceability Protocol,Document#EPA-600/R-97/121,using Procedure G1
Do Not Use this Standard if Pressure is less than 150 PSIG
AnalyliEnl Doric (R-Reference Standard,Z=Zero Gas,C=Gas Candidate)
1. Component; CARBON MONOXIDE Reference Standard Type: GMIS
Requested Concentration: 225 1 D t— Ref:Sid Cylinder#: HA4929.
Ceded Cdricenlralfon: �j ,j�gm„� Ref.Slid.Conti 651 PPM
Instrument Used: SIEMENS ULTRAMAT 6E SIN N7-04.0106 Ref.Std.Traceable to SRM#: 1680b
Analytical Method NON DISPERSIVE INFRARED SRM Sample i! 2.1-05
Lest Mulrtpoln CAbretion 3124120'11 SRM Cylinder p CAL015744
First pnalyals Data:- Date; 3/2 212 01 1 Second Analysts Data: Date: 3/2912011
.4: 6 R: 666.7 C: 229.9 Conc; 226.73 Z: 0 R: 650.8 C: 226.7 Cone; 228.79
Rt 669.7 k: 0 C: 229.8 Cone: 226.63 -R; 649.6 Z: 0 C: 226.8 Cone: 226.89 i
Y 0 C 229 7 ,A!. 659.9 Conc 226.53 Z: 0 C: 226.8 R 851.8 Cono: 226.89 i
UOk PPM Mean Test Assay 226.63 PPM UOM: PPM Mean Test Assay 226.86 PPM i
i Analyzed b Certified by:
"`d$fi Si'Prl is Robin Morgan l�
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Information contained herein has been prepared at your request by qualified experts within Praxair Distribution,Inc. While we believe that the information is accurate within the limits of the analytical
methods employed and is complete 16 the extent of the specific analyses performed,we make no warranty or representation as to the suitability of the use of the information for any purpose. The
lint ormalIon is offered With.INe understanding that any use of the information is at the sole discretion and risk of the user. In no event shall the liability of Praxair Distribution,Inc.,arising out of the
use of the information contained herein exceed the fee established for providing such Information,

NORTH CAROLINA DIVISION OF Washington Regional Office
AIR QUALITY Avoca Incorporated
NC Facility ID 0800044
Stack Test Observation Report County/FIPS:Bertie/015
Date: 03/15/2013
Facility Data Compliance Data
Avoca Incorporated Observation Date 02/20/2013
841 Avoca Farm Road Observer's Name Robert Fisher
Merry Hill,NC 27957 Operating Status Operating
Lat: 36d 0.0030m Long: 76d 42.6550m Action Code 23/STACK TEST
SIC: 2087/Flavoring Extracts And Syrups,nec OBSERVED
NAICS: 31193/Flavoring Syrup and Concentrate Manufacturing
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 01819/T39
Brian Conner David Peele Brian Conner Issued 1/4/2013
Environmental Health& President Environmental Health& Expires 7/31/2015
Safety Manager [phone] Safety Manager Classification Title V
[phone] [phone] Permit Status Active
Inspector's Signature: Comments:
Robert P.Fisher All testing appeared to be in accordance with the
Date of Signature:
approved protocol and EPA test methods.
� 1� C3
Directions from WaRO
Take US-17 N and turn right onto NC 171 N. Continue to Jamesville,NC. Turn right onto US-64 E.
Travel east through Plymouth and make a left onto NC 45 N at the Pines Elementary School. Travel
north on Hwy 45 and take a right onto Avoca Farm Road (SR 1502) (East) [signs to Avoca Farms &
Merry Hill]. Pass through Merry Hill and continue on Avoca Farm Road for several miles. The plant is
on the left. *
Facility Summary
a Avoca Inc. extracts oils and nutrients from various plants for use in perfume and as food additives.
The facility's primary product is sclareol that is extracted from sage. They provide nutrient
extractions for baby food and other food industries. They also produce crude Taxoll, which is an
active ingredient for an anti-cancer drug.
Facility Safety
Required PPE: safety-toe shoes,hard hat, ear protection. No cell phones are allowed in the production
plant.
Pre Inspection Meeting
I met with Brian Conner. I met Sam Tynch, Director of Operations. Brian showed he has the permit and
the recently signed civil penalty assessment for the previous test failure. He told me the sources were
operating as follows:
1. The Rotocel Operation was not operating.
2. The Recovery Operations were not operating,
K:\Bertie08\00044\20130221-biomss boilers stack test.doc Page 1 of 4

C
3. the Concrete Operations were not operating,
4. the Sclareol Recrystallization (SFG) Operations was operating,
5. the Biological Conversion Equipment for Purification of Sclareolide not operating,
6. the Sclareolide (SDE) Operations were operating,
7. the Plant Nutrient Extraction(PNE) Operations not operating,
- 8. The Ethyl Vanillin Glucoside (EVG) Operations were operating,
9. the Botanical Extraction Operations were operating,
10. the Biomass Extraction Operations were operating
a. (Extracting krill oil),I could smell a slight fishy odor on the yard.
11. Miscellaneous Operations
a. Two No. 2 fuel oil-fired boiler(20.3 million Btu)not operating
b. One No. 2 fuel oil-fired boiler(25.2 million Btu p)not operating
c. Two biomass/bio-based solids-fired boilers (18.6 million Btu)were running for the
test
d. One No. 2 fuel oil-fired rotary dryer(6.0 million Btu)not operating
e. One No. 2 fuel oil-fired limited use emergency generator(2,935 kw)not operating,
f. the wastewater plant was operating, -
g. Four No. 2 fuel oil-fired emergency generators were not operating
{ On Thursday February 21, 2013, I,Robert Fisher of the Washington Regional Office, attended the
emissions testing of ES-13131 and ES-BB2, two biomass/bio-based solids-fired boilers controlled by
simple cyclone CD-BB 1 C in series with one dry lime injected bagfilter CD-BB 1 BH at Avoca Inc.
ES-BB 1 is designated the"South"boiler and ES-13132 is designated the "North"boiler. The
maximum permitted heat input rate is 18.6 million Btu per hour per boiler. The boilers are permitted
to burn wood waste and sage from the sclareolide operations to produce process steam. The plan ,
1 is/was that sage will be fired during the harvest season(approximately June through August), then
wood will be fired from September through May. No other fuels are permitted to be fired in the
boilers.
jWood chips are brought on site and stored year round. Currently the facility is bringing in 4
truckloads of wood chips each day ("though it's less now since the Rotocell is down"). The boilers
are"base-loaded", meaning that they will always run and the oil-fired boilers will be brought on-line
as required by an increase in steam-demand.
Before the inspection I met with Brian Conner to discuss the plans for the test. Brian explained that
they have been running since February 8, when the auger was repaired. He mentioned that all of the
bags in the baghouse (fiberglass with a PTFE membrane)had been replaced in January (last month).
Later Jerry Finely, Boiler Engineer, showed pictures of some of the old bags that appeared to be
covered in a heavy crust and some had small holes. Brian and I also found what we believed were
the remains of some of the bags in a large cardboard box in a storage building near the main office.
40 CFR 60 Subpart Dc Standards of Performance for Small Industrial-Commercial-Institutional
Steam Generating Units and 40 CFR 63 Subpart DDDDD National Emissions Standards for
Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process
Heaters apply to the biomass boilers. Permit Condition 2.1.E. requires emissions testing to be -
performed annually, then tri-annually. The purpose for the testing is to demonstrate
K:\Bertie08\00044\20130221 biomss boilers stack test.doc Page 2 of 4

compliance with 40 CFR 63 Subpart DDDDD emissions limits and to establish boiler
monitoring and control parameters.
The testing was performed by AIR-TECH Environmental,LLC of Raleigh,NC. Darrell Doerle operated
the gas analyzers in the test trailer and Willie Gorgan was on the stack. They used EPA Method 5/26A
for filterable particulate matter and hydrogen chloride, Method 10 was performed for CO, and Method
30B was performed for Mercury emissions. EPA Methods 1, 2, 3A, and 4 were also performed to
determine exhaust gas flow rate, moisture, and molecular weight. Air-Tech used 16 traverse points
based on the reported stack dimensions. AVOCA personnel on hand for the test were Brian Conner,
Environmental,Health, & Safety Manager; Greg Bozwell and Mark Mizell, Boiler Operators, and Jerry
Finely, Boiler Engineer.
This test consisted of three 60-minute sampling runs. The first run commenced at 9:22 a.m. The boilers
-appeared to be running at capacity. These conditions appeared to be maintained fairly closely until
testing was complete. I observed the Boiler Control panel (SCADA) which showed information about
the steam pressure and oxygen(pictured). Beside the SCADA on the north boiler another panel
(UniComfort System)that displayed a CO reading (however Jerry explained that it was not connected).
It also displayed the Stack temps were as follows: ES2 (north) 240 deg C &ES 1 (south) 218 deg C. A
meter displayed steam—15k lbs/hour, —150 psi steam header pressure, and stack temperature of 290 deg
F. The Boiler Exhaust & Dryer Control Panel system control panel showed gas temperatures across
system(pictured). I did not discover the actual heat input and actual steam flow at the time believing
that this information would be forthcoming in the test report from Avoca.
I observed multiple momentary opacity observations during the test; all of which showed 0% opacity.At
11:57 am I conducted a 6-minute VE observation which showed 0% opacity (pictured). I also observed
the ash handling trailer that was covered. The small observation hole in the front of the trailer was open,
however this trailer is not pressurized and I observed no visible emissions from the observation hole
(pictured).
I observed what was labeled"broken bag level" indicator located on the wall near the wood chip
conveyors. It was currently reading a pressure drop of 7 inches water. Jerry Finely said the label was
correct. Also on the same wall was a chart indicating the "real" broken bag detector in the stack.
The three test runs were to be performed, one after the other with boiler load being held constant and
calibration&leak checks being run between each set of data. During each run,a data logger and a
series of analyzers were used to record data for CO, 02, and CO2. No problems were noted with the
data collection or operation of the boiler during the three test runs I observed. The table below
summarizes observed data from the three runs.
RUN START VE Average Averag Average Leak Bias
TIME CO (ppm) 02 (ppi CO2 (ppm) Check
1 9:22 0 57.2 uncor. 11.3 8.23 0.1 123
2 10:55 0 16.2 11.9 8.0 0.0 118
3 12:35 0 12.8 11.3 8.95 0.1 122
post 0.0 119
K:\Bertie08\00044\20130221-biomss boilers stack test.doc Page 3 of 4

Part of this test was to establish operating parameters which the facility could monitor(02)whichiwould
ensure emission limits were being met. So,the 02 analyzer readings taken by the testers will be
compared to the in-line 02 monitor readings of the plant. A spot-check comparison showed that the
analyzer read 11.3 ppm and the in-line monitor indicated 13.2 ppm. A complete analysis will be
provided in the stack test report.
I observed Brian Conner perform wood fuel sampling. He collected at least 12 half-full gallon-size
Ziploc-type bags of wood chips from random points around perimeter of the pile. The samples will be
sent to an off-site lab for analysis.
ATTACHMENTS
1. EPA Method 5 Visible Emissions Evaluation
2. Photos. See\\NROARI IWOLI\DATA\DAO\PICTURES 2013\08 Bertie\Facilities\Avoca\20130221 Avova
Stack Pics by R.Fisher.doc
3. (2)PRAXAIR Cal Gas Certifications for 123ppm & 225ppm CO.
COMMENTS/CONCLUSIONS
j Both of the new biomass boilers appeared to be operating near capacity for the test. All testing appeared
to be in accordance with the approved protocol and EPA test methods.
Note: I did not complete a NC DAQ Method 5 Observation Checklist or NC DAQ CEM Observation
Checklist
WaRO waits on the Stationary Source Compliance Branch acceptance before concluding
compliance from the stack test performed.
*The data included in this report are original observations by me, Robert Fisher. However much of the text of this report is
taken from prior reports submitted by Arni Hopkins for the stack test conducted on 6126112 and other inspections.
Follow Up
On March 26, 2013 Brain Conner called me and requested a conference call On April 1, 2013 to discuss
the parameters observed during the test. He indicated that the results from the test show compliance with
the monitored pollutants.
K:\Bertie08\00044\20130221-biomss boilers stack test.doc Page 4 of

Avoca Source Test Photos February 21, 2013 All photos taken by Robert Fisher
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2013-02-21 Stack Test Co
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2013-02-21 VEO location No VE
H:\DATA\DAQ\_ADMIN\Temp\20130221 Avova Stack Pics by R.Fisher.doc Page 1 of 4

Avoca Source Test Photos February 21, 2013 All photos taken by Robert Fisher
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2013-02-21 North Boiler Pressures
H:\DATA\DAQ\_ADMIN\Temp\20130221 Avova Stack Pics by R.Fisher.doc Page 2 of 4

Avoca Source Test Photos February 21, 2013 All photos taken by Robert Fisher
2013-02-21 firebox peep2
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H:\DATA\DAQ\_ADMIN\Temp\20130221 Avova Stack Pics by R.Fisher.doc Page 3 of 4

Avoca Source Test Photos February 21, 2013 All photos taken by Robert Fisher
OF
2013-02-21 Ash trailer front No VE
2013-02-21 Ash trailer side
H:\DATA\DAQ\_ADMIN\Temp\20130221 Avova Stack Pics by R.Fisher.doc Page 4 of 4

I
I
VISIBLE EMISSION OBSERVATION FORM No. I,
COMPANY NAME 108SERVATION ATE START TIME END TIME
A-vc Z LI f3 1 v. 1 12-,-03
b.R ET�ADDRESS � MI E 0 15 30 45 MI E 0 15 30 45
�6 0 b 17
CITY STATE I 17 i7 2
IV . . Y�T
3 0 0 S 3 33 a
HONE KEYCONdACi - - OUR iG•NO..•.•.•.•.• .• . •.•.-
�3`'Z--��z--.� .13.3 ems•(�s�'(' : . :'. . -0 b © 3
rRVSSE UIPME T PERA NG-MODE'.'-'. 5 35
ONTP.OL EO UIP E PERARNO.M 6 �p m '0 36
7 77
ESCRIBE EMISSION POINT g 38
14 1 40
HEIGHT ABOVE GROUND EIGHT RELATIVE TO OBSERVER 11 41
6a I La
ISTANCE FROM OBSERVER IRECTION FROM OBSERVER 12 42
I art'�'100 k&Eno fart �? 43
ESCRIBE EMISSIONS
trrt C'y¢W (.iloC`UiS End 14 44
MISSION COLOR WATER, DROPLET PLUME i5 45
,art rtfached
b0' End Cl VA Detached ❑ 16 46
OINT IN THE PLUME AT WHICH OPACITY WAS DETERMINED
i
,start •� � End S , 17 41
ESCRIBE PLUME BACKGROUND ig 48
I t r o �"� n 19 49
I6ACKGR ND Cu OR KY CONDITION
i
tart End fart (tV'`r End 20 50
LNG SPEED IND DIRECTION
'•Iarf �� End -fart End 2 5t
MBIENT TEMP BULB TEMP'- ' R4.pefoeM;• ;• ' ,,
Iar'. -V�S End . . 52
Stack SOURCE LAYOUT SKETCH Draw North Arrow
with (I r� 24 54 Plume I !V I . .
15Un I )5 S5
Wind L6 56
loEnission Point I 27 I 57
28 I SS 1
I
29 59
I I 30 60
OBSERVER'S N .E
Observer's Position �s�--
OBSERVER'S SIGNAT ` _ �DAATE'• '•'• •3.:;
— — — — — — ® RGANIZATIONA rL
Sun Locat;on line Jv l}
A01)ITIONAC aNFORMATIQN;- '-'. '. '. '. ' . . ' . . ' .'- . ' . '. '. 'EREJFIEB 6Y; : ATE
: : : : : ; Ot1iINUED ON VEO.FORM-NUMBER; . .•. • .-. •. •. . . . . . . . . . .. . ..
'
AQ-23 Rev. 11-20-87

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plR Praxair Distribution Mid-Atlantic
/) y h� I45 Shimersville Rd.
r` Bethlehem,PA I8015
/ ` n Telephone: [phone]
DocNumber: 000013644 � Q��r✓` v Facsimile: [phone]
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Customer&Order Ilrforination:
CHEROKEE INSTRUMENTS INC* Praxair OrderNumfier: 17906416 FiRDate W012011
901 BRIDGE ST CustomerP.D.Number: 11496 ParlNimiherr NIC012SE-AS
FUQUAY VARINA NC 275260 Customer Reference Number: Lof Vunibm 917125333
CylWorSfyle&Outlet AS CGA350
Certified Concentration: Cylinder Premtre&Yahrere: 2000 psig 140 cu,ft.
Expiration Date: 1312014 NIST Traceable
Cylinder Number: SA14630 t/ Analytical Uncertainty:
123 ppm CARBON MONOXIDE f 1%
Balance NITROGEN
Certifcadon Information. CertiBcatlon Date: 101Y2011 Term: 36 Months Expiration Date: 10/3/2014
This cylinder was Certified according to the 1997 EPA Traceability Protocol,Document#EPA-600fR-971121,using Procedure G1
Do Not Use this Standard if Pressure is less than 150 PSIG
PGVP ID#F12011 i
Analylical Dala: (R=Rakiance Standard,2=2ero Gas,C=Gas Candidate)
1. component: CARBON MONOXIDE Reference Standard Tyli GMIS
Requested Concentration: 125 Ref.Std.Cylinder#: CC239392
Certified Concentration: 1 3 Ref.Sid.Cone: 195 PPM
Instrument Used: HORIBA VIA-3000 SIN Y9EY78L6 Ref.Std.Traceable to SRM#: 166012
Analytical Method:. NDIR SRMSample#: 21.1-05.
Last MultipointCalib'ratiort 912 212 01 1 SRM Cylinder#: CAL015749
First Analysts Data: Date: 912412011 - Second Analysis Data: Date: 1013120i 1 i
Z: 0 R: 194 C: 124 Cone: 123.79 M 0 R: 195 C; 124 Colic: 123.37
R: 196 Z: 0 C: 124 Cone: 123.79 R: 196 Z: 0 0:. 124 Colic: 123.37
z: 0 C: 124 R: 195 Cone: 123.79 Z: 0 C: 124 R: 196 Colic: 123.37
li PPM Mean Test Assay: 123,79 PPM UOM: PPM Mean Test Assay: 123.37 Pi
Analyzed by: r�l\ � Certified by: n,
Asj-
Vil Robin Morgan
1
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Information contained herein has been prepared at your request by qualified experts wthin Praxair Distribution,Inc.While we believe that the,information is accurate within the limits of the analytical
methods employed and is complete to the extent of the specific analyses performed,we make no warranty or representation as to the suitability of the use of the Information for any purpose. The
information is offered with the understanding that any use of the information is at the solo discretion and risk of the user. In no event shall the liability of Yrexair Distribution,Inc.,arising out of the
use of the information con tained herein exceed the fee established for providing such information.

Z/1 1,3
IPRAX 41R �/' Ptrtzeir Distribution Mid-Atlantic
hy� '✓ v ' 145 Shimetsvil16 Rd.
- �W Telipho e:PA:18015
'Telephone: [phone]
OocNumber: 000009990 ). , .
gxr�^ FaCSimitc: (Gl0 758-8382
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CHB}20KES:INSTRUMENTS INC• ProxalrOrdeJ•Ndinber:. 16230993 >:it/Lhde: 3/1712011
,901`BRIDGE:ST Cuvomel-P.O.'Naiuber: 11207 PartNumben N160226E-As
FUQUAY VARINA NC 275260 Custoslet-Reference,Nainher: lot Number. 917107637
- . CylhitkrS8•leAOurkh AS: CGA350
Cyllmler Pre ire k I ahmicr 2000 psig 140 eu.ft.
CerllJied Coltcelttrodon:
Expiration Date: 3/29/2014 NISI Traceable
Cylinder Number: CC350375 Analytical Uncertainly:
226.7 ppm CARBON MONOXIDE t 1%
Balance NITROGEN
I
Cerlf/cal1011 Information. Certification Date: 3/29/2011 Term? 36 Months EXplret/on Date: 3/29/2614
i This cylinder Was certified according to the 1997 EPA Traceability Protocol,Document#EPA-600/R-97/121,using Procedure G1
Do Not Use this Standard if Pressure is less than 150 PSIG
AnalyliEnl Doric (R-Reference Standard,Z=Zero Gas,C=Gas Candidate)
1. Component; CARBON MONOXIDE Reference Standard Type: GMIS
Requested Concentration: 225 1 D t— Ref:Sid Cylinder#: HA4929.
Ceded Cdricenlralfon: �j ,j�gm„� Ref.Slid.Conti 651 PPM
Instrument Used: SIEMENS ULTRAMAT 6E SIN N7-04.0106 Ref.Std.Traceable to SRM#: 1680b
Analytical Method NON DISPERSIVE INFRARED SRM Sample i! 2.1-05
Lest Mulrtpoln CAbretion 3124120'11 SRM Cylinder p CAL015744
First pnalyals Data:- Date; 3/2 212 01 1 Second Analysts Data: Date: 3/2912011
.4: 6 R: 666.7 C: 229.9 Conc; 226.73 Z: 0 R: 650.8 C: 226.7 Cone; 228.79
Rt 669.7 k: 0 C: 229.8 Cone: 226.63 -R; 649.6 Z: 0 C: 226.8 Cone: 226.89 i
Y 0 C 229 7 ,A!. 659.9 Conc 226.53 Z: 0 C: 226.8 R 851.8 Cono: 226.89 i
UOk PPM Mean Test Assay 226.63 PPM UOM: PPM Mean Test Assay 226.86 PPM i
i Analyzed b Certified by:
"`d$fi Si'Prl is Robin Morgan l�
i
1
+
Information contained herein has been prepared at your request by qualified experts within Praxair Distribution,Inc. While we believe that the information is accurate within the limits of the analytical
methods employed and is complete 16 the extent of the specific analyses performed,we make no warranty or representation as to the suitability of the use of the information for any purpose. The
lint ormalIon is offered With.INe understanding that any use of the information is at the sole discretion and risk of the user. In no event shall the liability of Praxair Distribution,Inc.,arising out of the
use of the information contained herein exceed the fee established for providing such Information,