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HomeMy WebLinkAboutAQ_F_0400061_20210607_PRMT_PmtApp Gyuw61, 41/1 Cavanaugh&Associates, P.A. PO Box 11197 Winston Salem,NC 27116 C AVA N A U G H www.CavanaughSolutions.com May 28, 2021 VIA MAIL RECEIVED Heather Carter JUN -7 2021 Regional Supervisor, Fayetteville Regional Office NCDEQ Division of Air Quality 225 Green Street,Suite 714 DEQ-FAYE7TEVILLE REGIONAL OFFICE Fayetteville, NC 28301 RE: Catawba Biogas, LLC Air Permit No. 10593R00 Permit Modification Dear Mrs. Carter, Catawba Biogas, LLC proposes to modify Air Permit No. 10593R00 for its proposed biogas production facility in Anson County, NC.The permit modification aims to limit the operation of the shrouded biogas flare (CD-1)when the flare is used to combust raw, unprocessed biogas, so that the flare does not exceed the emission rate for hydrogen sulfide (HzS)for vertically oriented, unobstructed emission release points defined in 15A NCAC 02Q.0711. Enclosed is an application for the permit modification for Catawba Biogas. Also enclosed with this application is the fee for a small facility in the amount of$50. Thank you for your assistance. Please contact me at gus.simmons@cavanaughsolutions.com with any questions. Regards, PGusSim"P.E. Director of Bioenergy Cavanaugh &Associates, P.A. Page 1 of 1 Catawba Biogas, LLC Air Permit Modification May 27, 2021 Air Permit No. 10593R00 Overview of Air Permit Modification This permit modification aims to limit the operation of the shrouded biogas flare (CD-1) at the Catawba Biogas facility when the flare is used to combust raw, unprocessed biogas,so that the flare does not exceed the emission rate for hydrogen sulfide (HzS)for vertically oriented, unobstructed emission release points, as defined in 15A NCAC 02Q.0711. During normal operation when the hydrogen sulfide removal system (CD-2) is operating,the facility does not have the potential to exceed the hydrogen sulfide emission rate of 5.1 Ibs/day defined in 15A NCAC 02Q.0711.Therefore,the proposed limitations only apply to the facility when it is combusting unprocessed biogas that has not been treated using the hydrogen sulfide removal system. The completed permit application for Catawba Biogas(0400061.18A)submitted to the Division of Air Quality showed a potential hydrogen sulfide emission rate of 0.245 Ibs/hr when the flare is used to combust the maximum flow rate of unprocessed biogas without hydrogen sulfide removal. If operated for 24 hours at that emission rate,the facility would emit 5.9 Ibs/day of hydrogen sulfide which exceeds the 5.1 Ibs/day emission rate defined in 15A NCAC 02Q.0711. This permit modification proposes to limit the operation of the facility, using a limitation on the daily volume of biogas flared, so that the emission rate is no longer exceeded. Proposed Limitation The following limitation is proposed for the Catawba Biogas facility as part of this permit modification. The limitation will be used to maintain a hydrogen sulfide emission rate below 5.1 Ibs/day. • Operating Limitation: When the hydrogen sulfide removal system (CD-2) is not operating,the facility will combust no greater than 1,130,400 standard cubic feet (scf) of unprocessed biogas in the shrouded biogas flare (CD-1) per 24-hour day. The hydrogen sulfide emission rate calculations provided below show that the limitation listed above will result in an emission rate below 5.1 Ibs/day.To ensure the limitation is enforced,the facility will record the total volume of unprocessed biogas combusted in the flare each day to ensure the volume listed above is not exceeded. Biogas flow to the flare will be stopped when the volume of unprocessed biogas flared equals the volume defined above in the Operating Limitation. The anaerobic digesters at the facility are designed to allow one day of biogas storage, meaning that there is sufficient headspace in each digester to store the rated biogas flow rate for one day. During commissioning and startup when the facility is anticipated to flare the greatest volume of unprocessed biogas,the anaerobic digesters are anticipated to produce less than the rated volume of biogas.This will enable the facility to store biogas and remain within the limitation defined above.When the facility reaches steady-state operation and greater biogas production is achieved,the hydrogen sulfide removal system will be fully commissioned and operational to remove hydrogen sulfide from the gas.The facility can further comply with the limitation by reducing feedstock supply to the anaerobic digesters to decrease biogas production for a period of time. Page 1 of 2 Catawba Biogas, LLC Air Permit Modification May 27, 2021 Air Permit No. 10593R00 Emission Rate Calculations Detailed calculations for the limitation listed above are provided with this application to determine the resulting HzS emission rate.The HzS emission rate resulting from the Operating Limitation is 5.0 Ibs/day. The emission rate was calculated using a daily flared unprocessed biogas volume of 1,130,400 scf and a biogas HzS concentration of 2,500 ppm.The daily volume would result in an average biogas flow rate to the flare of 785 standard cubic feet per minute (scfm),which is 85%of the rated biogas volume of 924 scfm. Application Documents The additional documents provided as part of this modification are listed below. A. NCDEQ Division of Air Quality Permit Application Forms a. Form A b. Form A2 c. Form D1 d. Form D5 B. HZS Emission Rate Calculation Page 2 of 2 FORM A GENERAL FACILITY INFORMATION REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate A NOTE-APPLICATION WILL NOT BE PROCESSED WITHOUT THE FOLLOWING: ❑ Local Zoning Consistency Determination Appropriate Number of Copies of Application Application Fee lease check one option below (new or modification only) ❑ p APp pp (p p ) ❑ Responsible OfficiaUAuthorized Contact Signature ❑✓ P.E.Seal(if required) ❑ Not Required ❑ePayment ❑ Check Enclosed GENERAL INFORMATION Legal Corporate/Owner Name: Catawba Biogas,LLC Site Name: Catawba Biogas,LLC Site Address(911 Address)Line 1: 1133 Blewett Falls Road Site Address Line 2: City: Lilesville State: NC Zip Code: 28091 County: Anson CONTACT INFORMATION Responsible Official/Authorized Contact: Invoice Contact. Name/Title: Ted Niblock Name/Title: Ted Niblock Mailing Address Line 1: PO Box 11197 Mailing Address Line 1: PO Box 11197 Mailing Address Line 2: Mailing Address Line 2: City: Winston Salem State: NC Zip Code: 27116 City: Winston Salem State: NC Zip Code: 27116 Primary Phone No.: 215-932-8017 Fax No.: None Primary Phone No.: 215-932-8017 Fax No.: None Secondary Phone No.: None Secondary Phone No.: None Email Address: ted.niblock@ductor.com Email Address: ted.niblock@ductor.com Facility/Inspection Contact: Permit/Technical Contact: Name/Title: Ted Niblock Name/Title: Ted Niblock Mailing Address Line 1: PO Box 11197 Mailing Address Line 1: PO Box 11197 Mailing Address Line 2: Mailing Address Line 2: City: Winston Salem State: NC Zip Code: 27116 City: Winston Salem State: NC Zip Code: 27116 Primary Phone No.: 215-932-8017 Fax No.: None Primary Phone No.: 215-932-8017 Fax No.: None Secondary Phone No.: None Secondary Phone No.: None Email Address: ted.niblock@ductor.com Email Address: ted.niblock@ductor.com APPLICATION IS BEING MADE FOR New Non-permitted Facility/Greenfield U Modification of Facility(permitted) ❑ Renewal Title V ❑ Renewal Non-Title V ❑Name Change ❑ Ownership Change ❑ Administrative Amendment ❑ Renewal with Modification FACILITY CLASSIFICATION AFTER APPLICATION(Check Only One) General Small L Prohibitory Small IJ Synthetic Minor L_ Title V FACILITY(Plant Site)INFORMATION Describe nature of(plant site)operation(s):The plant will generate biomethane,also referred to as renewable natural gas(RNG),through the anaerobic digestion of poultry waste.The raw biogas will undergo cleaning steps to upgrade it to RNG.The RNG will be injected into the existing natural gas pipeline and combusted off-site for electricity generation.The non-methane constituents of the biogas will be combusted at the plant with one shrouded flare using natural gas as pilot fuel.The digestate and wastewater will undergo multiple conditioning steps.The digestate will be used offsite as an organic fertilizer.The heat needed to run the process will be generated using a natural gas-fired boiler.The point sources of air emissions will be the shrouded flare and the natural gas-fired boiler. Facility ID No.0400061 Primary SIC/NAICS Code:211130 Current/Previous Air Permit No.10593R00 Expiration Date:September 30,2027 Facility Coordinates: Latitude:34.971239 Longitude:-79.915973 Does this application contain ***If yes,please contact the DAQ Regional Office prior to submitting this confidential data? ❑ YES NO application.*** (See Instructions) PERSON OR FIRM THAT PREPARED APPLICATION Person Name: Gus Simmons Firm Name:Cavanaugh&Associates,P.A. Mailing Address Line 1:PO Box 11197 Mailing Address Line 2: City:Winston Salem State:NC Zip Code:27116 County:Forsyth Phone No.: 877-557-8923 Fax No.: None Email Address:gus.smmons@cavanaughsolutions.com SIGNATURE OF RESPONSIBLE OFFICIAL/AUTHORIZED CONTACT Name(typed):Ted Niblock Title:Manager X Signature(Blue Ink): Date: May 28,2021 Attach Additional Sheets As Necessary Page 1 of 2 FORM A (continued, page 2 of 2) GENERAL FACILITY INFORMATION REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate A SECTION AA1 -APPLICATION FOR NON-TITLE V PERMIT RENEWAL (Company Name)hereby formally requests renewal of Air Permit No. There have been no modifications to the originally permitted facility or the operations therein that would require an air permit since the last permit was issued. Is your facility subject to 40 CFR Part 68"Prevnetion of Accidental Releases"-Section 112(r)of the Clean Air Act? ❑ YES ❑ NO If yes,have you already submitted a Risk Manage Plan(RMP)to EPA? ] YES ❑ NO Date Submitted: Did you attach a current emissions inventory? ❑ YES ❑ NO If no,did you submit the inventory via AERO or by mail? U Via AERO ❑ Mailed Date Mailed: SECTION AA2-APPLICATION FOR TITLE V PERMIT RENEWAL In accordance with the provisions of Title 15A 2Q.0513,the responsible official of (Company Name) hereby formally requests renewal of Air Permit No. (Air Permit No.)and further certifies that: (1) The current air quality permit identifies and describes all emissions units at the above subject facility,except where such units are exempted under the North Carolina Title V regulations at 15A NCAC 2Q.0500; (2) The current air quality permit cits all applicable requirements and provides the method or methods for determing compliance with the applicable requirements; (3) The facility is currently in compliance,and shall continue to comply,with all applicable requiremetns. (Note: As provided under 15A NCAC 20.0512 compliance with the conditions of the permit shall be deemed compliance with the applicable requirements specifically identified in the permit); (4) For applicable requirements that become effective during the term of the renewed permit that the facility shall comply on a timely basis; (5) The facility shall fulfill applicable enhanced monitoring requirements and submit a compliance certification as required by 40 CFR Part 64. The responsible official(signature on page 1)certifies under the penalty of law that all information and statements provided above,based on information and belief formed after reasonable inquiry,are true,accurate,and complete. SECTION AA3-APPLICATION FOR NAME CHANGE New Facility Name: Former Facility Name: An official facility name change is requested as described above for the air permit mentioned on page 1 of this form. Complete the other sections if there have been modifications to the originally premitted facility that would requie an air quality permit since the last permit was issued and if ther has been an ownership change associated with this name change. SECTION AA4-APPLICATION FOR AN OWNERSHIP CHANGE By this application we hereby request transfer of Air Quality Permit No. from the former owner to the new owner as described below. The transfer of permit responsibility,coverage and liability shall be effective (immediately or insert date.) The legal ownership of the facility described on page 1 of this form has been or will be transferred on (date). There have been no modifications to the originally permitted facility that would require an air quality permit since the last permit was issued. Signature of New(Buyer)Responsible Official/Authorized Contact(as typed on page 1): X Signature(Blue Ink): Date: New Facility Name: Former Facility Name: Signature of Former(Seller)Responsible Official/Authorized Contact: Name(typed or print): Title: X Signature(Blue Ink): Date: Former Legal Corporate/Owner Name: In lieu of the seller's signature on this form,a letter may be submitted with the seller's signature indicating the ownership change SECTION AA5-APPLICATION FOR ADMINISTRATIVE AMENDMENT Describe the requested administrative amendment here(attach additional documents as necessary): Attach Additional Sheets As Necessary Page 2 of 2 FORMS A2, A3 EMISSION SOURCE LISTING FOR THIS APPLICATION -A2 112r APPLICABILITY INFORMATION -A3 REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate A2 EMISSION SOURCE LISTING: New, Modified, Previously Unpermitted, Replaced, Deleted EMISSION SOURCE EMISSION SOURCE CONTROL DEVICE CONTROL DEVICE ID NO. DESCRIPTION ID NO. DESCRIPTION Equipment To Be ADDED By This Application(New, Previously Unpermitted,or Replacement) ES-1 Natural Gas-Fired Boiler ES-2 Biogas Production Equipment CD-1,CD-2 One Shrouded Flare,Hydrogen Sulfide Removal Vessel ES-3 Waste Liquefaction System Existing Permitted Equipment To Be MODIFIED By This Application Equipment To Be DELETED By This Application 112(r)APPLICABILITY INFORMATION A 3 Is your facility subject to 40 CFR Part 68"Prevention of Accidental Releases"-Section 112(r)of the Federal Clean Air Act? Yes L1 No If No,please specify in detail how your facility avoided applicability: The ammonia water stored at the facility will not exceed the threshold ammonia concentration of 20%.The maximum ammonia concentration will be 19%. If your facility is Subject to 112(r),please complete the following: A. Have you already submitted a Risk Management Plan(RMP)to EPA Pursuant to 40 CFR Part 68.10 or Part 68.150? Yes No Specify required RMP submittal date: If submitted,RMP submittal date: B. Are you using administrative controls to subject your facility to a lesser 112(r)program standard? Yes F No If yes,please specify: C. List the processes subject to 112(r)at your facility: PROCESS LEVEL MAXIMUM INTENDED INVENTORY PROCESS DESCRIPTION (1,2,or 3) HAZARDOUS CHEMICAL (LBS) Attach Additional Sheets As Necessary FORM D1 FACILITY-WIDE EMISSIONS SUMMARY REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate D1 CRITERIA AIR POLLUTANT EMISSIONS INFORMATION-FACILITY-WIDE EXPECTED ACTUAL EMISSIONS POTENTIAL EMISSIONS POTENTIAL EMISSIONS (AFTER CONTROLS/ (BEFORE CONTROLS/ (AFTER CONTROLS/ LIMITATIONS) LIMITATIONS) LIMITATIONS) AIR POLLUTANT EMITTED tons/yr tons/yr tons/yr PARTICULATE MATTER(PM) 0.08 0.17 0.08 PARTICULATE MATTER<10 MICRONS(PM,,) 0.03 0.14 0.07 PARTICULATE MATTER<2.5 MICRONS(PM2.5) 0.07 0.14 0.07 SULFUR DIOXIDE(S02) 1.91 98.90 1.91 NITROGEN OXIDES(NOx) 16.51 32.73 16.52 CARBON MONOXIDE(CO) 13.71 27.32 13.71 VOLATILE ORGANIC COMPOUNDS(VOC) 0.90 1.79 0.90 LEAD GREENHOUSE.GASES(GHG)(SHORT TONS) OTHER HAZARDOUS AIR POLLUTANT EMISSIONS INFORMATION-FACILITY-WIDE EXPECTED ACTUAL EMISSIONS POTENTIAL EMISSIONS POTENTIAL EMISSIONS (AFTER CONTROLS/ (BEFORE CONTROLS/ (AFTER CONTROLS/ LIMITATIONS) LIMITATIONS) LIMITATIONS) HAZARDOUS AIR POLLUTANT EMITTED CAS NO. tons/yr tons/yr tons/yr Acetaldehyde(TH) 75070 2.48E-06 4.94E-06 2.48E-06 Acrolein(TH) 107028 2.94E-06 5.86E-06 2.94E-06 Ammonia(T) 7664417 6.24E-01 1.15E+00 6.24E-01 Arsenic unlisted compounds (TH) ASC-other 0.00E+00 0.00E+00 0.00E+00 Benzene(TH) 71432 3.43E-04 6.83E-04 3.43E-04 Benzo(a)pyrene (TH) 50328 1.96E-07 3.90E-07 1.96E-07 Beryllium metal(unreacted)(TH) 7440417 0.00E+00 0.00E+00 0.00E+00 Cadmium metal(elemental unreacted) (TH) 7440439 0.00E+00 0.00E+00 0.00E+00 Chromic acid(VI)(TH) 7738945 0.00E+00 0.00E+00 0.00E+00 Cobalt unlisted compounds(H) COC-other 1.37E-05 2.73E-05 1.37E-05 Formaldehyde(TH) 50000 1.22E-02 2.44E-02 1.22E-02 Hexane,n-(TH) 110543 2.94E-01 5.86E-01 2.94E-01 Lead unlisted compounds(H) PBC-other 8.16E-05 1.63E-04 8.16E-05 Manganese unlisted compounds(TH) MNC-other 0.00E+00 0.00E+00 0.00E+00 Mercury vapor (TH) 7439976 0.00E+00 0.00E+00 0.00E+00 Napthalene (H) 91203 9.96E-05 1.98E-04 9.96E-05 Nickel metal (TH) 7440020 0.00E+00 0.00E+00 0.00E+00 Selenium compounds(H) SEC 3.92E-06 7.81E-06 3.92E-06 Toluene(TH) 108883 5.55E-04 1.11E-03 5.55E-04 *Highest HAP-Ammonia 7664417 6.24E-01 1.15E+00 6.24E-01 *Total HAPs 9.31 E-01 1.76E+00 9.31E-01 TOXIC AIR POLLUTANT EMISSIONS INFORMATION-FACILITY-WIDE INDICATE REQUESTED ACTUAL EMISSIONS AFTER CONTROLS/LIMITATIONS. EMISSIONS ABOVE THE TOXIC PERMIT EMISSION RATE(TPER)IN 15A NCAC 2Q.0711 MAY REQUIRE AIR DISPERSION MODELING. USE NETTING FORM D2 IF NECESSARY. Modeling Required? TOXIC AIR POLLUTANT EMITTED CAS NO. Ib/hr lb/day lb/year Yes No Acetaldehyde(TH) 75070 6.72E-07 1.61 E-05 4.96E-03 X Acrolein(TH) 107028 7.96E-07 1.91 E-05 5.88E-03 X Ammonia(T) 7664417 1.66E-01 3.98E+00 1.25E+03 X Arsenic unlisted compounds (TH) ASC-other 0.00E+00 0.00E+00 0.00E+00 X Benzene(TH) 71432 9.28E-05 2.23E-03 6.86E-01 X Benzo(a)pyrene (TH) 50328 5.30E-08 1.27E-06 3.92E-04 X Beryllium metal(unreacted)(TH) 7440417 0.00E+00 0.00E+00 0.00E+00 X Cadmium metal(elemental unreacted) (TH) 7440439 0.00E+00 0.00E+00 0.00E+00 X Soluble chromate compounds,as chromium(VI)equivalent SoICR6 0.00E+00 0.00E+00 0.00E+00 X Formaldehyde(TH) 50000 3.32E-03 7.96E-02 2.45E+01 X Ht xane,n-(TH) 110543 7.96E-02 1.91 E+00 5.88E+02 X Hydrogen Sulfide 7783064 2.45E-01 5.00E+00 2.03E-02 X Manganese unlisted compounds(TH) MNC-other 0.00E+00 0.00E+00 0.00E+00 X Mercury vapor (TH) 7439976 0.00E+00 0.00E+00 0.00E+00 X Nickel metal (TH) 7440020 0.00E+00 0.00E+00 0.00E+00 X Toluene(TH) 1108883 1.50E-04 3.61E-03 1.11E+00 X *Total TAPs 4.94E-01 I 1.10E+01 I 1.86E+031 X COMMENTS: Attach Additional Sheets As Necessary FORM D5 TECHNICAL ANALYSIS TO SUPPORT PERMIT APPLICATION REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate D5 PROVIDE DETAILED TECHNICAL CALCULATIONS TO SUPPORT ALL EMISSION,CONTROL,AND REGULATORY DEMONSTRATIONS MADE IN THIS APPLICATION. INCLUDE A COMPREHENSIVE PROCESS FLOW DIAGRAM AS NECESSARY TO SUPPORT AND CLARIFY CALCULATIONS AND ASSUMPTIONS. ADDRESS THE FOLLOWING SPECIFIC ISSUES ON SEPARATE PAGES: A SPECIFIC EMISSIONS SOURCE(EMISSION INFORMATION)(FORM B and 131 through 139)-SHOW CALCULATIONS USED,INCLUDING EMISSION FACTORS,MATERIAL BALANCES,AND/OR OTHER METHODS FROM WHICH THE POLLUTANT EMISSION RATES IN THIS APPLICATION WERE DERIVED. INCLUDE CALCULATION OF POTENTIAL BEFORE AND,WHERE APPLICABLE,AFTER CONTROLS. CLEARLY STATE ANY ASSUMPTIONS MADE AND PROVIDE ANY REFERENCES AS NEEDED TO SUPPORT MATERIAL BALANCE CALCULATIONS. B SPECIFIC EMISSION SOURCE(REGULATORY INFORMATION)(FORM E2-TITLE V ONLY)-PROVIDE AN ANALYSIS OF ANY REGULATIONS APPLICABLE TO INDIVIDUAL SOURCES AND THE FACILITY AS A WHOLE. INCLUDE A DISCUSSION OUTING METHODS(e.g.FOR TESTING AND/OR MONITORING REQUIREMENTS)FOR COMPLYING WITH APPLICABLE REGULATIONS,PARTICULARLY THOSE REGULATIONS LIMITING EMISSIONS BASED ON PROCESS RATES OR OTHER OPERATIONAL PARAMETERS. PROVIDE JUSTIFICATION FOR AVOIDANCE OF ANY FEDERAL REGULATIONS(PREVENTION OF SIGNIFICANT DETERIORATION(PSD),NEW SOURCE PERFORMANCE STANDARDS(NSPS),NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS(NESHAPS),TITLE V),INCLUDING EXEMPTIONS FROM THE FEDERAL REGULATIONS WHICH WOULD OTHERWISE BE APPLICABLE TO THIS FACILITY. SUBMIT ANY REQUIRED INFORMATION TO DOCUMENT COMPLIANCE WITH ANY REGULATIONS. INCLUDE EMISSION RATES CALCULATED IN ITEM"A"ABOVE, DATES OF MANUFACTURE,CONTROL EQUIPMENT,ETC.TO SUPPORT THESE CALCULATIONS. C CONTROL DEVICE ANALYSIS(FORM C and C1 through C9)-PROVIDE A TECHNICAL EVALUATION WITH SUPPORTING REFERENCES FOR ANY CONTROL EFFICIENCIES LISTED ON SECTION C FORMS,OR USED TO REDUCE EMISSION RATES IN CALCULATIONS UNDER ITEM"A"ABOVE. INCLUDE PERTINENT OPERATING PARAMETERS(e.g.OPERATING CONDITIONS,MANUFACTURING RECOMMENDATIONS,AND PARAMETERS AS APPLIED FOR IN THIS APPLICATION)CRITICAL TO ENSURING PROPER PERFORMANCE OF THE CONTROL DEVICES). INCLUDE AND LIMITATIONS OR MALFUNCTION POTENTIAL FOR THE PARTICULAR CONTROL DEVICES AS EMPLOYED AT THIS FACILITY. DETAIL PROCEDURES FOR ASSURING PROPER OPERATION OF THE CONTROL DEVICE INCLUDING MONITORING SYSTEMS AND MAINTENANCE TO BE PERFORMED. D PROCESS AND OPERATIONAL COMPLIANCE ANALYSIS-(FORM E3-TITLE V ONLY)-SHOWING HOW COMPLIANCE WILL BE ACHIEVED WHEN USING PROCESS,OPERATIONAL,OR OTHER DATA TO DEMONSTRATE COMPLIANCE.REFER TO COMPLIANCE REQUIREMENTS IN THE REGULATORY ANALYSIS IN ITEM"B"WHERE APPROPRIATE. LIST ANY CONDITIONS OR PARAMETERS THAT CAN BE MONITORED AND REPORTED TO DEMONSTRATE COMPLIANCE WITH THE APPLICABLE REGULATIONS. E PROFESSIONAL ENGINEERING SEAL- PURSUANT TO 15A NCAC 2Q.0112"APPLICATION REQUIRING A PROFESSIONAL ENGINEERING SEAL," A PROFESSIONAL ENGINEER REGISTERED IN NORTH CAROLINA SHALL BE REQUIRED TO SEAL TECHNICAL PORTIONS OF THIS APPLICATION FOR NEW SOURCES AND MODIFICATIONS OF EXISTING SOURCES. (SEE INSTRUCTIONS FOR FURTHER APPLICABILITY). / William G. Simmons, Jr., P.E. attest that this application for Catawba Biogas, LLC has been reviewed by me and is accurate,complete and consistent with the information supplied in the engineering plans,calculations,and all other supporting documentation to the best of my knowledge. I further attest that to the best of my knowledge the proposed design has been prepared in accordance with the applicable regulations. Although certain portions of this submittal package may have been developed by other professionals,inclusion of these materials under my seal signifies that I have reviewed this material and have judged it to be consistent with the proposed design. Note: In accordance with NC General Statutes 143-215.6A and 143-215.6B,any person who knowingly makes any false statement,representation,or certification in any application shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed$10,000 as well as civil penalties up to$25,000 per violation. (PLEASE USE BLUE INK TO COMPLETE THE FOLLOWING) PLACE NORTH CAROLINA SEAL HERE NAME: William G. Simmons, Jr., P.E. DATE: May 27, 2021 ®"x® CA COMPANY: Cavanaugh &Associates, P.A. s ADDRESS: PO Box 11197 Winston Salem, NC 27116 4?�'�� TELEPHONE: 910.392.4462 go SIGNATURE: eir AL PAGES CERTIFIED: 2S EIYIission lRate Calculation 7 J (IDENTIFY ABOVE EACH PERMIT FORM AND ATTACHMENT ��too $Its" THAT IS BEING CERTIFIED BY THIS SEAL) Attach Additional Sheets As Necessary H,S Emission Rate Calculation for Operating Limitation Daily Biogas Production to Flare: 1,130,400 scf/da Biogas H2S Concentration: 2,500 ppm Daily Biogas H2S to Flare: 2,826 scf/day Biogas H2S Load to Flare: 250 Ibs/day See Equation 1 below. Flare Oxidation Efficiency: 98 % H2S Emission Rate: 5.00 Ibs/day Equation 1: m, — MWxPxV R x T where: m = mass flow rate (Ibs/day) MW = H2S molecular weight= 34.08 Ib/Ibmol P= standard pressure = 14.7 psia V=volumetric H2S production (scf/day) R= gas constant= 10.73 (psia*ft3)/(Ibmol*R) T = standard temperature = 528 R �p� C 29098 CAVANAUG H &ASSOCIATES P.A. a CH B,�wl L�sT COMPANY NORTH � � NORTH CAROLIN Prowu Djorlm P.O.BOX 11197 WINSTON SALEM,NC 27116 66-112/531 (336)759-9001 5/28/2021 cc a o N PAY TO THE ** Q NC DEQ 50.00 ORDER OF N m Fifty and 00/100************************************************************************************************************** m 1 DOLLARS U Cn NC DEQ VOID AFTER 90 DAYS Fayetteville Regional Office _ 8 a 225 Green Street, Suite 714CEI �. Fayetteville, NC 28301 LMO = AUTHORIZED SIGNATURE j RECEIVED JUN — 7 2021 r)EQ-FAYETTEVILLE REGIONAL OFFICE 1 11"l.6 Lfdoo& /VT75 P2'(r((j