AQ_F_1000067_20161228_ST_RvwMemo

Brunswick County
DIVISION OF AIR QUALITY
Technical Services Section
December 28, 2016
MEMORANDUM
To: Brad Newland, Wilmington Regional Office
From: Gary L. Saunders, Stationary Source Compliance Branch(SSCB)�
Subject: CPI USA North Carolina-Southport Plant
Southport, Brunswick County, North Carolina, Air Permit No. 05884T17
Facility ID 1000067, Tracking No. 2015-167ST
Performance Testing of the Unit 1 and Unit 2 Boiler Stacks for 1126) Compliance and
Emission Factor Development
Conducted September 15-17, 2015
The SSCB has reviewed the test report for the above referenced testing. The purpose of the
testing was to demonstrate compliance with applicable 1120)limits for Case-by-Case MACT for
particulate matter(PM), hydrogen chloride(HCl), and mercury(Hg). In addition, emission data
would be produced for PM10 and volatile organic compounds (VOC) for emission factor
development.
Each unit consists of three boilers, each capable of firing a combination of natural gas, coal,
wood, tire derived fuel (TDF),pelletized paper fuel and flyash briquettes. Each boiler has a
maximum design heat capacity of 223 million Btu per hour(mmBtu/hr) and is controlled by a
fabric filter. During the testing, each of the boilers was operated at a normal load of between 169
to 193 mmBtu/hr while firing a blend of wood(46%), coal (4%), and TDF (50%).
The sampling ports are not large enough to accept a Method 201A sampling head to determine
PM10 through that method. In consultation with NCDAQ, the facility will use the results of the
Method 5 and Method 202 total as being representative of PM10 emissions. The filterable PM
results are used for determining compliance with the 1120) limits. Mercury emissions were
determined using Method 30B while HCl emissions were determined by Method 26 A. Finally,
VOC emissions (as carbon) were determined using Method 25A.
Table 1. Summary of Test Results for Unit 1
Pollutant Emission Rate, Emission Rate. Emission Limit, Compliance
lb/hr lb/mmBtu lb/mmBtu Indicated
PM 11.71 0.017 0.18 Yes
(filterable)
HCl 2.85 0.004 0.02 Yes
Hg - 5.73E-08 5.0E-06 Yes
PM 10 18.85 0.028 N/A N/A
VOC as C 1.43E-03 0.96 N/A N/A

Brad Newland
December 28, 2016
Page 2
Table 2. Summary of Test Results for Unit 2
Pollutant Emission Rate, Emission Rate. Emission Limit, Compliance
lb/hr lb/mmBtu lb/mmBtu Indicated
PM 8.83 0.014 0.18 Yes
(filterable)
HCl 3.89 0.006 0.02 Yes
Hg - 5.44E-08 5.0E-06 Yes
PM10 { 16.10 0.026 N/A N/A
VOC as C i' 1.70E-03 L 1.05 N/A N/A
All performance tests were conducted in accordance with the protocol that was submitted to the
DAQ and in accordance with EPA Reference Methods The test methods and results are deemed
acceptable. If you have any questions,please feel free to contact me at(919) 707-8413 or
[e-mail].
cc: Central Files, Brunswick County
IBEAM Documents - 1000067