AQ_F_0800044_20221007_ST_StkTstProt_2022-261st

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Avoca,LLC
Avoca LLC PO Box 129
841 Avoca Farm Rd
Merry Hill,NC 27957
The World's Premier Botanical Extraction Company Phone: [phone]
p y Fax:[phone]
E 0 E I V E
October 5, 2022 f
Ms. Betsy Huddleston ` OCT 2022
Regional Supervisor
North Carolina Division of Air Quality q�
Washington Regional Office DAC), ���'h RO -
943 Washington Square Mall
Washington, NC 27889
Re: Protocol Submittal for Boiler MACT Testing of the Biomass Boilers
Emission Source ID Nos. ES-13131 & ES-13132
Avoca, LLC.
Merry Hill, NC
Permit No. 01819T53
Dear Ms. Huddleston:
Avoca LLC., (Avoca) owns and operates two biomass boilers at our facility that are subject to
the Boiler NESHAP (or Boiler MACT), 40 CFR Part 63, Subpart DDDDD. Based on previous test
results and the requirements listed within Permit Condition No. 2.1-E.5.g and §63.7515, the
facility is currently on a three year testing schedule for the biomass boilers. The last test was
performed on December 18, 2019.
In accordance with Subpart DDDDD, the every third-year test must be conducted within 37
months of the previous test, or on or before January 18, 2023. Avoca is tentatively planning
to test on December 13, 2022. Avoca will provide a 15 day notice of testing as required in
15A NCAC 02D .2602.
In accordance with Permit Condition 2.1-E.5, Subparts A and DDDDD of Part 63, and 2D .2600,
Avoca is submitting this letter and the attached DAQ test protocol. Avoca is not submitting a
full test plan as outlined in Subpart DDDDD as such plan was previously submitted for the
initial February 2013 test and was approved by DAQ. Avoca will not be performing fuel
sampling as part of this test.
Avoca will be monitoring the operating parameters under the NESHAP (Le., 02 and steam
rate) as this is a continuous monitoring requirement under Subpart DDDDD and will collect
all operating data as required during testing. It is our intent to confirm based on the results
of this testing that the previous operating limits for 02 and steam are adequate for our
boilers. As you may know, a facility is required to operate in compliance with the current
operating limits during each test, and while doing so, the limits will inherently become more

Ms. Huddleston
Page 2
stringent with each source test. For this reason, Avoca will plan to verify or confirm our
current operating limits are adequate and should not change as a result of this next test.
The Boiler MACT (Subpart DDDDD) has two pertinent regulatory references that discuss the
development, verification and confirmation of operating limits. They are included as follows:
1. §63.7515(f) -You must report the results of performance tests and the associated fuel
analyses within 60 days after the completion of the performance tests.This report must also
verify that the operating limits for each boiler or process heater have not changed or provide
documentation of revised operating limits established according to §63.7530 and Table 7 to
this subpart, as applicable.The reports for all subsequent performance tests must include
all applicable information required in§63.7550.
2. §63.7540(a)(1) - Following the date on which the initial compliance demonstration is
completed or is required to be completed under§63.7 and§63.7510,whichever date comes
first, operation above the established maximum or below the established minimum
operating limits shall constitute a deviation of established operating limits listed in Table 4
of this subpart except during performance tests conducted to determine compliance with
the emission limits or to establish new operating limits. Operating limits must be confirmed
or reestablished during performance tests.
Avoca has italicized and underlined key terms from the above regulatory citations. The Boiler
MACT rule provides no definition or regulatory guidance on how to justify that the operating
limits should not change or how to confirm the current operating limits. Avoca is planning to
provide information as part of the Notice of Compliance Status submittal to justify that our
current operating limits should not change and to confirm that the current operating limits
are permissible for our boilers.
In accordance with §63.7545(e), Avoca will submit a Notice of Compliance Status with all test
results within 60 days of completion of onsite testing.
If you have any questions regarding the attached protocol, please feel free to contact Mr.
Brian Conner at (252)-482-2133, I?xt. 287, or Mr. Jim Lewis of Integrity Air Monitoring, Inc. at
[phone].
Sincerel)id
Augus ritsen
Vice Pt
Avoca, LLC.
cc: Mr. Brian Conner, Avoca
Mr. Jim Lewis, Integrity
Mr. Dale Overcash, 'Trinity Consultants
Enclosures:
DAQ Protocol Form
Testing Port Schematic

Ms. Huddleston
Page 3
Process Flow Diagram

NFr-' a
PROTOCOL SUBMITTAL FORM (Rev. 2016)
Environmental
Quality DIVISION OF AIR QUALITY PAGE 1 OF 2
Purpose: The goals of the Protocol Submittal Form are to initiate communication between representatives of the permitted facility,
the testing consultant, and the DAQ as well as to identify and resolve any specific testing concerns prior to testing.
Instructions: Use Guidance Document to fill out this form. Submit all forms and additional information to the DAO Regional
Supervisor at least 45 days Drior to testing. Complete one form for each sampling location. If this form does not supply
sufficient space to completely answer all questions or if additional relevant information is necessary,attach additional
documentation and/or information to the original form. Questions and/or comments should be directed to the appropriate
Regional Supervisor.
This form and its Guidance Document are available at dep.nc.eov/about/divisions/air-quality/air-guality-
enforcem ent/em ission-m easu rem ent.
Specify Appropriate Regional Office: (check one)
❑Asheville ❑ Fayetteville ❑ Mooresville ❑ Raleigh ® Washington
g El Wilmington El Winston-Salem
Facility ID No: 0800044 Test Company Name: Integrity Air Monitoring, Inc.
Facility Name Avoca, LLC
Facility Contact Person/mailing address& email: Testing Company Contact Person/mailing address&email:
Brian Conner James Lewis
Avoca, LLC P.O. Box 559
841 Avoca Farm Rd. Huntersville, NC 28070-0559
Merry Hill, NC 27957
Email Address: brian.conner@ash/and.com Email Address: [e-mail]
Phone: [phone] Fax: [phone] Phone: [phone] Fax: [phone]
Mobile No.: I I Mobile No.: [phone]
Air Permit Number&Revision: 01819T53 Permitted Source Name and ID No.: ES-13131 & ES-13132 controlled
by a bagfilter(ID No. CD-BB1 BH)
Permitted Maximum Process Rate: Maximum Normal Operation Process Rate: Target Process Rate for Testing:
24 mmBtu/hr each 21.6 mmBtu/hr each 21.6 mmBtu/hr each
1.1)What is the specific purpose for the proposed testing? (Permit condition,NSPS,NESHAP,etc.-See guidance doc.)To comply with 40
CFR 63 Subpart DDDDD.
Is this an initial performance test? ❑ Yes or ®No
1.2)List all state and federal regulations that apply to the proposed testing.(See guidance doc.)
Permit Condition 2.1.E.5. , NCAC 02Q.0508(f) and 40 CFR 63 Subpart DDDDD
1.3)Will the test results be used for other regulatory purposes(e.g. emission inventories,permit application,etc.)beyond that stated above?
® Yes or ❑No If yes,explain. May be used for future permit revisions and emissions inventories.
1.4)How will production/process&control device data be documented during testing?(list specific control equipment,process parameters
instrumentation that will be used, frequency of data collection,collected by computer/manually,etc.) Test will not be accepted
without appropriate production/process&control device operation data. Boiler heat input rates will be determined in
conjunction with the stack test using EPA Method 19 (F-factor for wood of 9240). The facility will record boilers exhaust
oxygen concentrations and steam rates. Bagfilter utilizes a leak detection system.
1.5)Provide a brief description of the source(including control equipment)and attach source or process flow diagram from source through
stack exit. Two biomass-fired boilers with emissions controlled by a common bagfilter. Process flow diagram attached.
1.6)Provide a brief description of the sampling location,attach schematic of sampling location,and indicate whether concurrent testing will
be conducted at other sampling locations.(Approval of protocol without this data will not exempt you from Method 1 criteria.)
The bagfilter exhaust is a round stack 35" in diameter, with two sampling ports located 900 apart. Method 1 data sheet
attached. No concurrent sampling will be performed at other sampling locations.

PROTOCOL SUBMITTAL FORM (Rev. 2016)
Environmental
Quality DIVISION OF AIR QUALITY PAGE 2 OF 2
2.1)Provide the following information for each test parameter.
Target Proposed Number of Test Run #of
Pollutant Test Method Test Runs Duration Sampling Comments
Points
Volumetric flow 1, 2 & 4 3 24
rate & moisture
02/CO2 & 3A 3 2-hours 1 Stratification check will be performed
molecular weight
PM/HCl 5/26A 3 24
CO 10 3 1
1-hour
Hg 30B 3 3
Heat Input 19 3 NA NA F-factor for wood of 9240
2.2) Will all testing be conducted in strict accordance with the applicable test methods? If"No",attach complete
documentation of all proposed modifications and/or deviations to the applicable test methods. ® Yes ❑No
2.3) Does the proposed sampling location meet the minimum EPA Method 1 criteria for acceptable measurement sites? ❑
Attach supporting documentation. ® Yes No
2.4) Will you conduct a"verification of absence of cyclonic flow"(EPA Method 1 Section 11.4)?
Absence of cyclonic flow must be documented during this testing. ® Yes El No
2.5) Will oxygen concentration be determined by❑ EPA Method 3 via Orsat or® strict EPA Method 3A?(Specify)
If"No",recheck line item 2.2 above.(Fyrites are NOT allowed according to 15A NCAC 2D .2606). ®Yes ❑ No
Is an audit sample from an Accredited Provider available for the proposed test method(s)?(Additional information
2.6) available at deq.nc.gov/about/divisions/air-quality/air-quality-enforcement/emission-measurement/stationM- ❑Yes ®No
source-test-audit-information)
2.7) Has all testing equipment been calibrated within the past year? If"No",explain. ®Yes ❑No
2.8a)Have all calibration gases been certified by EPA Protocol 1 procedures? (Answer only as applicable.) ®Yes ❑No
2.8b)Is a dilution system(EPA Method 205)proposed? (Answer only as applicable.) ❑Yes ®No
2.8c)Attach a summary of expected calibration gas concentrations for all proposed instrumental test methods.
2.9) What is proposed test schedule?DAO Regional Supervisor must be notified a minimum of 15 days prior to the actual test
dates THIS FORM DOES NOT CONSTITUTE 15 DAY REGIONAL OFFICE NOTIFICATION
Test scheduled for December 13, 2022.
Additional Comments: Expected cal gas concentrations:02/CO2-12.5/10,21/18%, CO- 1000/500ppm
Signatures: Representatives from the permitted facility and the contracted testing company must provide signatures below certifying
that the information provided on this form and any attached information is accurate and complete.
}�-0S-202.2.. . /
Permi ac' ty Representative Date Testing Company Representative llate
Name: Augustinus Gerritsen Name: James Lewis
Title: Vice President Title: Vice President/Quality Manager
Company: Avoca, LLC Company: Integrity Air Monitoring, Inc.

EPA Method 1
Determination of Sampling Points
Sampling Location Dimensions
Client Avoca,LLC Far Wall to Outside of Port
City,St. Merry[fill,NC Nipple Length
Sampling Location Bagfilter Exhaust 35.0 Depth of Duct
Date Width(Rectangular Duct)
Equivalent Diameter Calculation(DE) Distance to Ports From Nearest Disturbance
2 X Length X Width B A
DE= ------------------------ _ 252 240 Distance,inches
Length+Width 7.2 6.9 No.Diameters
Stack Area 6.681 ft 2
Traverse Points-Percentage of Stack ID
A
Rectangular Stacks
2 3 4 5 6
1 25 16.7 12.5 10 8.3
2 75 50 37.5 30 25
3 83.3 62.5 50 41.7 B
4 1 1 1 87.5 70 58.3
5 90 75
6 91.7
Location of Sampling Points
Circular Stacks Point %of Stack ID Inches From Nipple Inches From
4 6 8 10 12 Stack ID inches Inside Wall Length Outside of Port
l 6.7 4.4 3.2 2.6 2.1 1 4.4 35.0 1.54
2 25 14.6 10.5 8.2 6.7 2 14.6 5.11
3 75 29.6 19.4 14.6 11.8 3 1 29.6 1 10.36
4 93.3 70.4 1 32.3 22.6 17.7 4 70A 24.64
5 85.4 67.7 34.2 25 5 85.4 29.89
6 95.6 80.6 65.8 35.6 6 95.6 33.46
7 89.5 77.4 64.4 7
8 96.8 85.4 75 8
9 91.8 82.3 9
10 97.4 88.2 10
11 93.3 ]1
12 97.9 11 1�712
Method 1 Section 11.3.1.4
no less than 0.5"from stack wall for Stacks between 12-24"
no less than 1.0"from stack wall for Stacks greater than 24"

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Avoca,LLC
Avoca LLC PO Box 129
841 Avoca Farm Rd
Merry Hill,NC 27957
The World's Premier Botanical Extraction Company Phone: [phone]
p y Fax:[phone]
E 0 E I V E
October 5, 2022 f
Ms. Betsy Huddleston ` OCT 2022
Regional Supervisor
North Carolina Division of Air Quality q�
Washington Regional Office DAC), ���'h RO -
943 Washington Square Mall
Washington, NC 27889
Re: Protocol Submittal for Boiler MACT Testing of the Biomass Boilers
Emission Source ID Nos. ES-13131 & ES-13132
Avoca, LLC.
Merry Hill, NC
Permit No. 01819T53
Dear Ms. Huddleston:
Avoca LLC., (Avoca) owns and operates two biomass boilers at our facility that are subject to
the Boiler NESHAP (or Boiler MACT), 40 CFR Part 63, Subpart DDDDD. Based on previous test
results and the requirements listed within Permit Condition No. 2.1-E.5.g and §63.7515, the
facility is currently on a three year testing schedule for the biomass boilers. The last test was
performed on December 18, 2019.
In accordance with Subpart DDDDD, the every third-year test must be conducted within 37
months of the previous test, or on or before January 18, 2023. Avoca is tentatively planning
to test on December 13, 2022. Avoca will provide a 15 day notice of testing as required in
15A NCAC 02D .2602.
In accordance with Permit Condition 2.1-E.5, Subparts A and DDDDD of Part 63, and 2D .2600,
Avoca is submitting this letter and the attached DAQ test protocol. Avoca is not submitting a
full test plan as outlined in Subpart DDDDD as such plan was previously submitted for the
initial February 2013 test and was approved by DAQ. Avoca will not be performing fuel
sampling as part of this test.
Avoca will be monitoring the operating parameters under the NESHAP (Le., 02 and steam
rate) as this is a continuous monitoring requirement under Subpart DDDDD and will collect
all operating data as required during testing. It is our intent to confirm based on the results
of this testing that the previous operating limits for 02 and steam are adequate for our
boilers. As you may know, a facility is required to operate in compliance with the current
operating limits during each test, and while doing so, the limits will inherently become more

Ms. Huddleston
Page 2
stringent with each source test. For this reason, Avoca will plan to verify or confirm our
current operating limits are adequate and should not change as a result of this next test.
The Boiler MACT (Subpart DDDDD) has two pertinent regulatory references that discuss the
development, verification and confirmation of operating limits. They are included as follows:
1. §63.7515(f) -You must report the results of performance tests and the associated fuel
analyses within 60 days after the completion of the performance tests.This report must also
verify that the operating limits for each boiler or process heater have not changed or provide
documentation of revised operating limits established according to §63.7530 and Table 7 to
this subpart, as applicable.The reports for all subsequent performance tests must include
all applicable information required in§63.7550.
2. §63.7540(a)(1) - Following the date on which the initial compliance demonstration is
completed or is required to be completed under§63.7 and§63.7510,whichever date comes
first, operation above the established maximum or below the established minimum
operating limits shall constitute a deviation of established operating limits listed in Table 4
of this subpart except during performance tests conducted to determine compliance with
the emission limits or to establish new operating limits. Operating limits must be confirmed
or reestablished during performance tests.
Avoca has italicized and underlined key terms from the above regulatory citations. The Boiler
MACT rule provides no definition or regulatory guidance on how to justify that the operating
limits should not change or how to confirm the current operating limits. Avoca is planning to
provide information as part of the Notice of Compliance Status submittal to justify that our
current operating limits should not change and to confirm that the current operating limits
are permissible for our boilers.
In accordance with §63.7545(e), Avoca will submit a Notice of Compliance Status with all test
results within 60 days of completion of onsite testing.
If you have any questions regarding the attached protocol, please feel free to contact Mr.
Brian Conner at (252)-482-2133, I?xt. 287, or Mr. Jim Lewis of Integrity Air Monitoring, Inc. at
[phone].
Sincerel)id
Augus ritsen
Vice Pt
Avoca, LLC.
cc: Mr. Brian Conner, Avoca
Mr. Jim Lewis, Integrity
Mr. Dale Overcash, 'Trinity Consultants
Enclosures:
DAQ Protocol Form
Testing Port Schematic

Ms. Huddleston
Page 3
Process Flow Diagram

NFr-' a
PROTOCOL SUBMITTAL FORM (Rev. 2016)
Environmental
Quality DIVISION OF AIR QUALITY PAGE 1 OF 2
Purpose: The goals of the Protocol Submittal Form are to initiate communication between representatives of the permitted facility,
the testing consultant, and the DAQ as well as to identify and resolve any specific testing concerns prior to testing.
Instructions: Use Guidance Document to fill out this form. Submit all forms and additional information to the DAO Regional
Supervisor at least 45 days Drior to testing. Complete one form for each sampling location. If this form does not supply
sufficient space to completely answer all questions or if additional relevant information is necessary,attach additional
documentation and/or information to the original form. Questions and/or comments should be directed to the appropriate
Regional Supervisor.
This form and its Guidance Document are available at dep.nc.eov/about/divisions/air-quality/air-guality-
enforcem ent/em ission-m easu rem ent.
Specify Appropriate Regional Office: (check one)
❑Asheville ❑ Fayetteville ❑ Mooresville ❑ Raleigh ® Washington
g El Wilmington El Winston-Salem
Facility ID No: 0800044 Test Company Name: Integrity Air Monitoring, Inc.
Facility Name Avoca, LLC
Facility Contact Person/mailing address& email: Testing Company Contact Person/mailing address&email:
Brian Conner James Lewis
Avoca, LLC P.O. Box 559
841 Avoca Farm Rd. Huntersville, NC 28070-0559
Merry Hill, NC 27957
Email Address: brian.conner@ash/and.com Email Address: [e-mail]
Phone: [phone] Fax: [phone] Phone: [phone] Fax: [phone]
Mobile No.: I I Mobile No.: [phone]
Air Permit Number&Revision: 01819T53 Permitted Source Name and ID No.: ES-13131 & ES-13132 controlled
by a bagfilter(ID No. CD-BB1 BH)
Permitted Maximum Process Rate: Maximum Normal Operation Process Rate: Target Process Rate for Testing:
24 mmBtu/hr each 21.6 mmBtu/hr each 21.6 mmBtu/hr each
1.1)What is the specific purpose for the proposed testing? (Permit condition,NSPS,NESHAP,etc.-See guidance doc.)To comply with 40
CFR 63 Subpart DDDDD.
Is this an initial performance test? ❑ Yes or ®No
1.2)List all state and federal regulations that apply to the proposed testing.(See guidance doc.)
Permit Condition 2.1.E.5. , NCAC 02Q.0508(f) and 40 CFR 63 Subpart DDDDD
1.3)Will the test results be used for other regulatory purposes(e.g. emission inventories,permit application,etc.)beyond that stated above?
® Yes or ❑No If yes,explain. May be used for future permit revisions and emissions inventories.
1.4)How will production/process&control device data be documented during testing?(list specific control equipment,process parameters
instrumentation that will be used, frequency of data collection,collected by computer/manually,etc.) Test will not be accepted
without appropriate production/process&control device operation data. Boiler heat input rates will be determined in
conjunction with the stack test using EPA Method 19 (F-factor for wood of 9240). The facility will record boilers exhaust
oxygen concentrations and steam rates. Bagfilter utilizes a leak detection system.
1.5)Provide a brief description of the source(including control equipment)and attach source or process flow diagram from source through
stack exit. Two biomass-fired boilers with emissions controlled by a common bagfilter. Process flow diagram attached.
1.6)Provide a brief description of the sampling location,attach schematic of sampling location,and indicate whether concurrent testing will
be conducted at other sampling locations.(Approval of protocol without this data will not exempt you from Method 1 criteria.)
The bagfilter exhaust is a round stack 35" in diameter, with two sampling ports located 900 apart. Method 1 data sheet
attached. No concurrent sampling will be performed at other sampling locations.

PROTOCOL SUBMITTAL FORM (Rev. 2016)
Environmental
Quality DIVISION OF AIR QUALITY PAGE 2 OF 2
2.1)Provide the following information for each test parameter.
Target Proposed Number of Test Run #of
Pollutant Test Method Test Runs Duration Sampling Comments
Points
Volumetric flow 1, 2 & 4 3 24
rate & moisture
02/CO2 & 3A 3 2-hours 1 Stratification check will be performed
molecular weight
PM/HCl 5/26A 3 24
CO 10 3 1
1-hour
Hg 30B 3 3
Heat Input 19 3 NA NA F-factor for wood of 9240
2.2) Will all testing be conducted in strict accordance with the applicable test methods? If"No",attach complete
documentation of all proposed modifications and/or deviations to the applicable test methods. ® Yes ❑No
2.3) Does the proposed sampling location meet the minimum EPA Method 1 criteria for acceptable measurement sites? ❑
Attach supporting documentation. ® Yes No
2.4) Will you conduct a"verification of absence of cyclonic flow"(EPA Method 1 Section 11.4)?
Absence of cyclonic flow must be documented during this testing. ® Yes El No
2.5) Will oxygen concentration be determined by❑ EPA Method 3 via Orsat or® strict EPA Method 3A?(Specify)
If"No",recheck line item 2.2 above.(Fyrites are NOT allowed according to 15A NCAC 2D .2606). ®Yes ❑ No
Is an audit sample from an Accredited Provider available for the proposed test method(s)?(Additional information
2.6) available at deq.nc.gov/about/divisions/air-quality/air-quality-enforcement/emission-measurement/stationM- ❑Yes ®No
source-test-audit-information)
2.7) Has all testing equipment been calibrated within the past year? If"No",explain. ®Yes ❑No
2.8a)Have all calibration gases been certified by EPA Protocol 1 procedures? (Answer only as applicable.) ®Yes ❑No
2.8b)Is a dilution system(EPA Method 205)proposed? (Answer only as applicable.) ❑Yes ®No
2.8c)Attach a summary of expected calibration gas concentrations for all proposed instrumental test methods.
2.9) What is proposed test schedule?DAO Regional Supervisor must be notified a minimum of 15 days prior to the actual test
dates THIS FORM DOES NOT CONSTITUTE 15 DAY REGIONAL OFFICE NOTIFICATION
Test scheduled for December 13, 2022.
Additional Comments: Expected cal gas concentrations:02/CO2-12.5/10,21/18%, CO- 1000/500ppm
Signatures: Representatives from the permitted facility and the contracted testing company must provide signatures below certifying
that the information provided on this form and any attached information is accurate and complete.
}�-0S-202.2.. . /
Permi ac' ty Representative Date Testing Company Representative llate
Name: Augustinus Gerritsen Name: James Lewis
Title: Vice President Title: Vice President/Quality Manager
Company: Avoca, LLC Company: Integrity Air Monitoring, Inc.

EPA Method 1
Determination of Sampling Points
Sampling Location Dimensions
Client Avoca,LLC Far Wall to Outside of Port
City,St. Merry[fill,NC Nipple Length
Sampling Location Bagfilter Exhaust 35.0 Depth of Duct
Date Width(Rectangular Duct)
Equivalent Diameter Calculation(DE) Distance to Ports From Nearest Disturbance
2 X Length X Width B A
DE= ------------------------ _ 252 240 Distance,inches
Length+Width 7.2 6.9 No.Diameters
Stack Area 6.681 ft 2
Traverse Points-Percentage of Stack ID
A
Rectangular Stacks
2 3 4 5 6
1 25 16.7 12.5 10 8.3
2 75 50 37.5 30 25
3 83.3 62.5 50 41.7 B
4 1 1 1 87.5 70 58.3
5 90 75
6 91.7
Location of Sampling Points
Circular Stacks Point %of Stack ID Inches From Nipple Inches From
4 6 8 10 12 Stack ID inches Inside Wall Length Outside of Port
l 6.7 4.4 3.2 2.6 2.1 1 4.4 35.0 1.54
2 25 14.6 10.5 8.2 6.7 2 14.6 5.11
3 75 29.6 19.4 14.6 11.8 3 1 29.6 1 10.36
4 93.3 70.4 1 32.3 22.6 17.7 4 70A 24.64
5 85.4 67.7 34.2 25 5 85.4 29.89
6 95.6 80.6 65.8 35.6 6 95.6 33.46
7 89.5 77.4 64.4 7
8 96.8 85.4 75 8
9 91.8 82.3 9
10 97.4 88.2 10
11 93.3 ]1
12 97.9 11 1�712
Method 1 Section 11.3.1.4
no less than 0.5"from stack wall for Stacks between 12-24"
no less than 1.0"from stack wall for Stacks greater than 24"

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