AQ_F_1000067_20160415_CMPL_RFI

P'AT MCCRORY
DONALD R. VAN DER VAART
�ec1'etarz
w SHEILA C. HOLMAN
Air Quality
ENVIRONMENTAL QUALITY
CERTIFIED MAIL: 7014 2120 0003 9404 8687
RETURN RECEIPT REQUESTED
April 15, 2016
Mr. David H. Groves
Plant Manager
CPI USA North Carolina—Southport Plant
1281 Powerhouse Drive
Southport,NC 28461
SUBJECT: Post-Project Actual Emissions for 2015
Air Quality Permit No. 05884T19
CPI USA North Carolina LLC
Southport, Brunswick County
Facility ID: 1000067
Dear Mr. Groves:
The Division of Air Quality (DAQ) has evaluated your February 26, 2016 submittal,
consisting of post-project actual emissions for calendar year 2015 for the subject facility sources,
pursuant to the requirement in 15A NCAC 02D .0530(u) and as included in Section 2.1.A.5. of the
current permit. Based on this evaluation, the DAQ offers the enclosed comments.
If you have any questions or concerns, please contact me at [phone] or at
[e-mail]; or contact Rahul P. Thaker, P.E., QEP, at [phone] or at
[e-mail].
Sincerely,
h��' A�_
William D. Willets, P.E., Chief, Permitting Section
Division of Air Quality, NCDEQ
Enclosure
c: Wilmington Regional Office
Central Files
State of North Carolina I Environmental Quality I Air Quality
1641 Mail Service Center 217 W.Jones Street,Suite 4000 1 Raleigh,NC 27609-1641
919 707 8400 T

CPI Southport NC
Back round
Air Quality Permit 05884T05
Air Quality Permit 05884T05 (June 11, 2004) included in the source descriptor a permission to
burn tire-derived fuel (TDF), along with other fuels such as coal, natural gas, Nos. 2 and 4 fuel
oils,pelletized paper and flyash briquette. No limitation for burning of any of the fuels was
included in the permit.
Air Quality Permit 05884T06
The DAQ issued an air permit 05884T06 (December 19, 2005) allowing the burning of
unadulterated wood and restricting firing of TDF to no more than 35 percent of the heat input
rate for each boiler(ES-14A, ES-14B, ES-14C, ES-2-1A, ES-24B, and ES-24C). The
agency assured compliance with the "state-only" air toxics requirement pursuant to 15A NCAC
02Q .0700 for regulated air toxics and with PSD by including avoidance requirements pursuant
to 02Q .0317 for NOx, S02, and CO, along with the associated enforceable, combined emissions
limits for all of the above boilers.
Air Quality Permit 05884T08
The DAQ issued an air permit 05884T08 (March 31, 2009) allowing for the increased firing of
TDF in each boiler from the previously permitted limit of 35 percent to 50 percent of heat input
rate. In addition,the agency approved as a part of the project, installation of SO2 (furnace
sorbent injection) and NOx control systems (rotating over-fire air and non-selective catalytic
reduction), and alkaline silo and bagfilter. This permit replaced the existing PSD avoidance
stipulation as described above with the requirements pursuant to 02Q .0530(u) [Use of projected
actual emissions to avoid the applicability of PSD] for PM, PMio,NOx, CO, S02, and VOC, and
required establishment of emissions factors through stack testing. The permit also included non-
enforceable (pre-project) projected actual emissions and required the Permittee to report(post-
project) actual emissions for each of the five calendar years upon commencement of changes as
described above. Finally, this stipulation also mandated that the Permittee include in each report
an explanation for any given year if actual emissions exceeded the projected actual emissions.
Air Quality Permit 05884T15
The DAQ issued an air permit on 05884T15 (December 18, 2014) correcting the type of change
allowed (i.e., TDF firing rate increased up to 50 percent of heat input rate among other changes)
in the previously issued permit 05884T08. The DAQ had erroneously described the approved
change as firing at exact 50% TDF rate and included stack testing requirement with a deadline of
180 days from commencement of each of the following changes: firing at 50% TDF AND
installing rotating opposed over fire air systems AND furnace sorbent injection systems AND
selective non-catalytic reduction systems,AND installing alkaline sorbent silo and associated
vent fabric filter.
1

The correct description for the change involving TDF firing rate would be increasing the TDF
firing rate in ANY boiler above 35% but up to 50% of heat input rate in each boiler. The correct
trigger date for stack testing deadline would be the completion of ANY of the previously
approved changes in permit 05884T08. That is, (i) commencement of feeding tire derived fuel
above 35%, but less than or equal to 50% of the heat input rate in any individual boiler, OR(ii)
installing rotating opposed over fire air system on any individual boiler, OR(iii) installing
furnace sorbent injection system on any individual boiler, OR(iv) installing selective non-
catalytic reduction system on any individual boiler, OR(v) installing alkaline sorbent silo and
associated vent fabric filter.
Thus, the air permit 05884T15 corrected both description of the previously approved project and
the trigger date for performing the stack test with a deadline to complete all testing for each of
the affected pollutants by June 30, 2015,as per 02D .0530(u).
Air Quality Permit 05884T17
Finally,the DAQ issued an air permit 05884T17 (April 2, 2015), removing stack testing
requirement for establishing emissions factors for NOx, S02, and CO, and replacing it with
development of emissions factors using the data collected from the use of existing, certified
continuous emission monitoring (CEM) systems. The DAQ also replaced the existing stack
testing deadline from June 30, 2015 for the remaining pollutants; PM, PM10, and VOC, to
October 8, 2015.
CPI Roxboro Submittal of February 26, 2016
As required, this submittal from CPI is a first report for calendar year 2015 including post-
project actual emissions for the project described above and approved initially through air permit
05884T08.
The following summarizes the post-project actual emissions v. the pre-project projected actual
emissions:
Pollutant (Pre-project) (Post-Project) Do Actual Emissions
Projected Actual Actual Emissions, Exceed Projected Actual
Emissions, tons/yr Emissions?
tons/yr
PM 86.1 66.2 No
PM10 83.2 115.1 Yes
VOC 27 6.6 No
NOx 1296 874.6 No
SO2 3700 4774 Yes
CO 306 1592 Yes
'The installation of selective non-catalytic reduction systems on each boiler is optional.
2

The actual emissions for 2015 year were based upon the information derived from Emission
Collection and Monitoring Plan System(ECMPS)report. The report includes information on
actual emissions of NOx and S02, and operating hours and heat inputs to each boiler on a
quarterly basis, for the calendar year 2015. The actual emissions of CO are based upon CEMS
data acquisition system report for 2015. In addition, the actual emissions for PM, PM10, and
VOC are based upon emissions factors derived from stack testing conducted on September 15-
17, 2015 and the actual heat inputs from the above ECMPS report for 2015. It needs to be stated
here that the Permittee could not conduct a stack for PMio and had used observed PM emissions
rates during the stack testing to derive emission factor for PMio.
The following Table includes the emissions factors as developed through the above testing and
reported by the Permittee:
Emission Source PM, lb/million Btu PM10, lb/million VOC, lb/million Btu
Btu
Common Stack 0.017 0.028 0.00143
CS001 for three
boilers, ES-1-IA, ES-
1-113 and ES-1-IC
Common Stack 0.014 0.026 0.00170
CS002 for three
boilers, ES-2-IA, ES-
2-1B and ES-2-1C
Analysis and Questions
(i) It is not clear whether the emissions factors for both PM (i.e. PMioo) and PM10 include both
filterable and condensible portions.
(ii) With respect to (post-project) actual emissions of PMio, S02 and CO, exceeding the (pre-
project)projected actual emissions, as per §51.166(b)(40)(ii)(c)2, the Permittee can exclude from
the projected actual emissions of that portion of the emissions that it could have accommodated
during the selected baseline period (24-month consecutive period) and that are unrelated to the
project including any increased utilization due to product demand growth. Thus, the regulation
establishes two criteria a source must meet before excluding emissions from its projection: (1)
the unit could have achieved the necessary level of utilization during the selected consecutive
24—month period, used to establish the baseline actual emissions; and (2)the increase is not
related to the physical or operational change(s) made to the unit.
That means that the applicant may be able to show to the DAQ that certain emissions are
excludable from the actual emissions (for calendar year 2015) if during the selected baseline
period, it actually and legally emitted at levels, corresponding to the actual operating hours,
actual operating loads, actual fuels used, and the appropriate emission factors for the fuels fired
2 Definition of projected actual emissions incorporated into NC's SIP-approved PSD regulation in 15A NCAC 02D
.0530.
3

during the baseline period. In addition, emissions that could have been accommodated due to
the increased utilization of the unit, meeting the above criteria, may be excludable from the
(post-project) actual emissions.
The Permittee had used the baseline periods of January 2004 through December 2005 for
emissions of SO2 and January 1, 2006 through December 31, 2007 for PM10 and CO at the time
of approval of air permit 05884T08. As also described above,the Permittee was permitted to
burn TDF up to 35 percent of heat input in each boiler, along with coal (no heat input limitation)
and unadulterated wood (no heat input limitation), among other fuels, during these selected
baseline periods for each of the above pollutants. Thus, the Permittee is required to use
appropriate emissions factors for these pollutants for fuel combinations containing up to 35 %
percent TDF firing rate, as long as the Permittee had actually burned TDF with any other fuel
(coal, unadulterated wood). If the TDF was not burned at all during the selected baseline period,
the emission factor would appropriately represent only the coal and wood, if they are the only
fuels fired during the baseline period.
When it comes to boiler operating load (actual heat inputs), the Permittee can use the highest
demonstrated (observed) monthly operating load and can scale it up for the entire year to
demonstrate that it could have accommodated this short-term highest demonstrated monthly load
for the entire year during the baseline period.
Finally,the Permittee needs to document and provide sources of information for calculations of
excludable emissions.
Conclusions
The applicant needs to provide the information on questions (i) and(ii) above. Using the
approach in (ii) above, the Permittee needs to demonstrate to the DAQ that after removing the
excludable emissions (if appropriate),the project involving increased TDF firing above 35
percent, but, up to 50 percent of heat inputs to boilers, did not trigger PSD.
4