AQ_F_6600167_20221026_ST_RvwLtr

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
MICHAEL ABRACZINSKAS NORTH CAROLINA
Environmental Quality Director
October 26, 2022
Greg Rhodes
Plant Manager
Enviva Pellets, LLC -Northampton Plant
309 Enviva Boulevard
Garysburg, NC 2783 I
Subject: Enviva Pellets, LLC -Northampton Plant
Garysburg, Northampton County, North Carolina
Facili ty lD 6600167, Permit No. 10203T09
Emissions testing: Regenerative Thermal Oxidizer (CO-RTO-1) and Regenerative
Catalytic Oxidizer (CD-RCO-2)
Performed June 29 -30, 2022
Tracking No. 2022-l 37ST
Dear Mr. Rhodes:
The results of the subj ect emissions testing have been reviewed by the Division of A ir Quality's
Stationary Source Compliance Branch. The testing of the regenerative thermal oxidizer (CD-
RTO-1) and regenerative catalytic oxidizer (CD-RCO-2) included the following methods: EPA
Method 5/202 fo r total particulate matter (PM), EPA Method 20 I A for PM I 0/PM2.5, EPA
Method 7E for nitrogen oxides (NOx)[RTO-1 only], EPA Method IO for carbon monoxide
(CO)[RTO-1 only], EPA Method 25A for VOC as propane to determine VOC emissions in
accordance with OTM 26, and EPA Method 320 for methane, acetaldehyde, acrolei n, methanol,
propionaldehyde, formaldehyde, and phenol emissions. The test results indicated compliance
with the applicable regulations for ail pollutants except formaldehyde on RT0-1. The test
results indicated the emissions of formaldehyde from CD-RTO-1 stack al 0.39 pounds per hour.
The emissions limit established in your current permit for compliance with air toxics (NCAC
20 .1100) for formaldehyde is 0.35 pounds per hour, thus demonstrating non-compliance for this
pollutant.
The tested emissions source, regenerative thermal oxidizer (CD-RTO-1 ), is the control device fo r
emissions from the five green hammermills, direct heat wood-fired dryer, eight dry hammermills
with integral cyclones and the dry shavings hammermills I and 2. The tested emi ssions source,
regenerative catalytic oxidizer (CD-RCO-2) is th e control device for em issions from the six
pellet coolers (each with a high efficiency cyclone). The regenerative thermal oxidizer (CD-
RTO-1) and the regenerative catalytic oxidizer (CD-RCO-2) are subject to 15A NCAC 2D .0515
Particulates from Miscellaneous Industrial Processes, which limits total PM based on actual
production rate. 15A CAC 2Q .0317 Avoidance Conditions for 15A NCAC 02D .0530
Prevention of Significant Deterioration applies; the permit specifies the facility-wide emissions
limits for PM/PM I 0/PM2.5 and VOC as 250 tons per consecutive 12-month period, each. 15A
North Carolina Department of Environmental Quality I Division of Air Quality
Raleigh Regional Office I 3800 Barrett Drive I Raleigh. North Carolina 27609
919,791.4200 T I 919.571.4718 F
Enviva Pellets, LLC -Northampton Plant
October 26, 2022
Page 2 of2
NCAC 2Q .0317 Avoidance Conditions for I SA NCAC 02D .1112 MACT apply and limit HAPs
to less than 25 tons per year (tpy) for combined HAPS and less than IO tpy for each single HAP.
15A NCAC 020.1100 Control o_[Toxic Air Pollutants also applies, and the permit specifies
emissions limits for acrolein and formaldehyde. Detailed emissions are summarized in tables
one through fou r in the attached memorandum. Compliance was demonstrated fo r all pollutants
except formaldehyde.
Please see the attached memorandum dated September 2 1, 2022, for more details on the test
results and emi ssions limits. The memo also includes a contact number for the test reviewer. A
notice concerning the noncompliance fo r formaldehyde will be sent under separate cover. If you
have any questions for the Raleigh Regional Office, please feel free to contact Dawn Reddix,
Environmental Engineer, or me at [phone].
Attachment
cc: RRO Files
Sincerely,
William T. Wike, Jr.
Compliance Supervisor
Division of Air Quality, Raleigh Regional Office