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Home My WebLink AboutAQ_F_1000067_20150909_ST_ProtRvw (4) A4� NCDENR North Carolina Department of Environment and Natural Resources Pat McCrory Donald R. van der Vaart Governor Secretary September 9, 2015 Virginia Grace Senior Advisor,Environment CPI USA North Carolina,LLC—Southport Plant 1281 Powerhouse Drive SE Southport,NC 28461 Subject: Protocol for Filterable Particulate Matter,Volatile Organic Compounds, Hydrogen Chloride,Mercury and PM10 Emissions Testing on Two Electricity Generating Units ES-1 (Unit 1)and ES-2(Unit 2) CPI USA North Carolina, LLC—Southport Plant Southport,Brunswick County,North Carolina Air Permit No. 05884T17,Facility ID 10/00067 Proposed Test Date: September 15 through 18,2015 Tracking No. 2015-167ST Dear Ms. Grace: The protocol submittal form(PSF)prepared by Grace Consulting Inc.has been reviewed for filterable particulate matter(PM),volatile organic compounds (VOC),hydrogen chloride(HCl),mercury(Hg) and PMto emissions testing and deemed acceptable. The test is being conducted to demonstrate compliance with Case-by-Case MACT. The emissions sources being tested are two electricity generating units consisting of. six(6)watertube design coal/natural gas/No.2 and No. 4 fuel oil/tire derived fuel/pelletized paper fuel/flyash briquette/unadulterated wood/unadulterated biomass/adulterated resonated wood/creosote treated wood- fired boilers ID Nos. ES-14A,ES-14B,ES-1-1C,ES-24A,ES-24B, and ES-24C and associated bagfilters,rotating overfire air(ROFA) systems, furnace sorbent injection(FSI) systems,and selective non-catalytic reduction(SNCR)systems. 15A NCAC 2D .l 109: Case-by-Case MACT applies. Permit Condition 2.1-A.7 stipulates the Case-by- Case MACT limits for the proposed pollutants. 40 CFR 60 Subpart Db Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units, 15A NCAC 2D .0501(c)Compliance with National Ambient Air Quality Standards, 15A NCAC 2D .0530 and.0530(u)Prevention of Significant Deterioration also apply. The sources,pollutants,and methods are tabulated below: Boiler ES-14A,ES-14B, Volumetric Flow Rates Ml,2,&4 ES-14C,ES-2-1A, ES-24B and Oxygen,Carbon Dioxide M3A ES-24C Filterable PM M5 VOC 25A Hydrogen Chloride 26A Mercury 30B PM10 M5/M201A 1641 Mail Service Center,Raleigh,North Carolina 27699-1641 Phone:91 9-707-8400 1 Internet:www,ncdenr.gov An Equal Opportunity 1 Affirmative Action Employer—Made in part by recycled paper Virginia Grace September 9,2015 Page 2 of 2 The proposed test methods are acceptable for the specified pollutants. Approval of the protocol does not exempt the tester in any way from the minimum requirements of the applicable methods. Since no deviations from the applicable testing methodology were addressed in the test protocol,the testing should be conducted in strict accordance with the requirements of EPA Methods 1,2, 3A,4, 5,25A, 26A, 30B and 5/201A. The permitted maximum process rate is 223 million Btu per hour(mmBtu/hr).The maximum normal process rate for each boiler is 223 million Btu per hour(mmBtu/hr). The target process rate for testing is approximately 223 mmBtu/hr per boiler. Permit Condition 2.1-A.7.d states that if the facility utilizes a sorbent injection system to comply with the HCl emissions standards,then the permittee shall maintain the minimum sorbent injection rate at or above the operating levels,adjusted for variability,established during the performance test that demonstrated compliance with the applicable emissions standards. The operating parameters per permit condition 2.1- A.7.h are; (1)the sorbent injection rate data must be collected every 15 minutes during testing and(2)the average sorbent injection rate for each test run must be calculated and reported with the final test results. Note that audit sample analysis is required for the Method 26A proposed. Grace Consulting Inc.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 this EPA web page http://www.epa.gov/ttn/emc/email.html#audit. Any modifications to the applicable test methods remain subject to approval by the Division of Air Quality(DAQ). Please insure all relevant process/operating data is included and summarized in the test report. If you have any questions,please feel free to contact me at David.B.HughesCancdenngov or(919) 707-8411. Sic rely, (� David B.Hughes,Envi onmental Engineer Division of Air Quality,NCDENR Cc: Michael Whitt, Grace Consulting Inc. Brad Newland—Wilmington Regional Office Central Files—Brunswick County IBEAM Documents 1000067 (09/15/15)