AQ_F_0800107_20161117_CMPL_InspRpt

DOC-
a
NORTH CAROLINA DIVISION OF WE gton Regional Office
AIR QUALITY W.E.Partners II,LLC
NC Facility ID 0800107
Inspection Report County/FIPS:Bertie/015
Date: 11/17/2016
Facility Data Permit Data
W.E.Partners II,LLC Permit 10126/R02
3539 Governors Road Issued 6/12/2013
Lewiston Woodville,NC 27849 Expires 11/30/2015
Lat: 36d 8.3590m Long: 77d 13.3450m Classification Synthetic Minor
SIC: 4961 /Steam Supply Permit Status Active
NAICS: 22133/Steam and Air-Conditioning Supply Current Permit Application(s)Renewal,
Modification
Contact Data
Program Applicability
Facility Contact Authorized Contact Technical Contact
Garald Cottrell ✓ Garald Cottrell Garald Cornell '� SIP
MACT Part 63: Subpart 6J
President President President NSPS: Subpart Dc
[phone] [phone] [phone]
Compliance Data
Comments: Based upon the 2016 hourly ESP secondary power averages provided
by the facility,there appears to be 1,227 thirty-day rolling averages(total of 68 Inspection Date 09/29/2016
days)calculated below the 3.4 kW minimum that was established with the required Inspector's Name Betsy Huddleston
Boiler GACT 6J stack testing. These averages are deviations of 40 CFR Operating Status Operating
63.11201(c)and Table 3 of the Boiler GACT,Subpart 6J. The facility otherwise Compliance Code Compliance-inspection
appeared to be in compliance with the permit conditions and applicable regulations Action Code FCE i
at the time of the inspection. On-Site Inspection Result Violation
Inspector's Signature:
Date of Signature: Z -2�/s~
Total Actual emissions in TONS/YEAR: CY2013
TSP S02 NOX VOC CO PM 10 * HAP
I
* Highest HAP Emitted(in ounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
05/12/2015 NOWNRE Part 63 -NESHAP/GACT Subpart JJJJJJ Industrial, 06/12/2015
Commercial and Institutional Boilers at Area Sources
Performed Stack Tests since last FCE:None
Directions
From Washington take Highway 17 North to Windsor, and then turn left onto Highway 308W at the
second stoplight in Windsor(Bill Clough Ford dealership is on the right). Stay on Highway 308 through
Lewiston Woodville.Turn left at the Perdue chicken processing plant and drive down to the Valley
Proteins rendering plant. W.E.Partners II is located directly in front of the rendering plant.

General Facility Summary
W.E. Partners II, LLC is a subsidiary of Wellons Energy Solutions,LLC. It is a biomass cogeneration
facility. It supplies steam to the Valley Proteins rendering plant(Facility ID 0800081). Steam is also
used to heat wastewater treatment system for both Valley Proteins and Perdue(ID 0800109)during cold
months. The facility has one 500 kW turbine that supplies power to the grid. The facility began
operation on 1/17/2012.
Safety Concerns
Required safety equipment includes hard hat, hearing protection, safety glasses, and steel-toe shoes.
Permit History
• Permit R00 was issued on December 29,2010 for a greenfield facility.
• Permit RO 1 was issued on Nov. 28,2011 for the following modifications:
- Addition of cotton gin residues, soybean hulls and peanut shells as biomass fuel.
- Addition of an electrostatic precipitator to further control particulate emissions from the boilers.
The ESP was installed to meet the Boiler GACT particulate limit for new biomass boilers(sized
between 10-30 MMBtu/hr).
- Increase in the synthetic minor annual fuel consumption limit.
• Permit R02 was issued on 06/12/2013 for the following changes:
- Changed each boiler description to"one clean cellulosic biomass-fired boiler." The permit
included approval to burn screened turkey poultry litter wood shavings. Also added definition of
"clean cellulosic biomass"per 40 CFR 241.2 and 241.3 and a permit condition for adding new
fuels under this definition.
- Removed Specific Condition No. 9 because the testing has been completed.
- Updated the monitoring requirements for the ESP and the performance testing requirements to
reflect changes in 40 CFR 63, Subpart JJJJJJ,as issued in the Federal Register on 2/01/2013.
- Updated the synthetic minor condition to include the tested CO emission rate(dated June 19,
2012)in the calculations for compliance with 2Q.0315.
- Removed permit conditions for toxics.Because the boilers are NESHAP Subpart JJJJJJ
applicable,the facility is no longer required to review toxics for them.
• Applicability Determination No.2546 NHSM determination for creosote railroad ties was issued to
W. E. Partners on 1/07/2015. The ties met the legitimacy criteria under 40 CFR 241.3(d)(1).
• Applicability Determination No. 2596-Secondary Material Determination for creosote telephone
poles was received by DAQ on 3/16/2015. The determination was issued by DAQ on 6/05/2015.
The poles met the legitimacy criteria under 40 CFR 241.3(d)(1).
• A permit renewal application was submitted on 9/03/2015.No changes were requested in the permit.
The permit renewal has been substantially delayed in issuance. The Renewable Energy and
Energy Efficiency Portfolio Standard(REPS), Session Law 2007-397, Senate Bill SB3 applies to the
facility and requires it to meet Best Available Control Technology(BACT). The Permittee submitted
a BACT analysis to the Division of Air Quality on 10/05/2010. Jeff Twisdale with RCO Permits
completed the BACT determination for the Cofield W.E. Partners facility(ID No. 4600106)on
12/11/2014 and requested that WaRO add BACT conditions to the W.E. Partners permit upon
renewal,for which the application was submitted 1/22/2015. RCO planned to then complete the
BACT determination for the Lewiston W.E.Partners facility prior to receipt of its permit renewal
application. However, a series of events occurred in association with the Cofield BACT
determination that caused a delay in RCO Permits completing the Lewiston determination. The
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Lewiston BACT deten------ition could not be completed separately c i own timeframe because CO
and NOx BACT limits for Lewiston were dependent on testing conducted in Cofield to resolve its
BACT limit conflicts. A revised BACT analysis was submitted for Lewiston on 8/11/2015. Note that
the Lewiston boilers are identical to the ones in Cofield.
While I could have issued the Lewiston facility's permit renewal without BACT permit conditions,
over four years had passed since the BACT analysis had been submitted by the facility-to DAQ. With
agreement from Mr. Garald Cottrell, I made the decision to delay issuance of the Lewiston permit
renewal until Cofield's BACT limit conflicts could be resolved and the Lewiston determination
completed by RCO.
Inspection Observations and Regulatory Review
On 9/29/20161 conducted an inspection of the facility with the assistance of Mr. Chad Hoggard.
The following sources are included on the permit and Insignificant/Exempt Activities attachment to
the permit:
Emission Emission Source Control Device Control System
1, Source ID Description ID Description
ESB-1 one clean cellulosic biomass-fired boiler MC-1 multi-cyclone
(NSPS, (29.4 million Btu per hour maximum heat (18 tubes,each 9 inches in diameter)
NESHAP) input)
ESP-1 jelectrostatic precipitator
9,222 sq ft total collection plate area,
wo fields with 60 kv charge per field)
ESB-2 one clean cellulosic biomass-fired boiler MC-2 multi-cyclone
(NSPS, (29.4 million Btu per hour maximum heat (18 tubes,each 9 inches in diameter)
NESHAP) input)
ESP-1 electrostatic precipitator
(9,222 sq ft total collection plate area,
two fields with 60 kv charge per field)
ESB-3 one clean cellulosic biomass-fired boiler �MC-3 multi-cyclone
(NSPS, (29.4 million Btu per hour maximum heat (18 tubes,each 9 inches in diameter)
NESHAP) input) _
ESP-1 electrostatic precipitator
(9,222 sq ft total collection plate area,
two fields with 60 kv charge per field)
'I-SB-1 (green wood fuel storage bunker j N/A N/A
The boilers(600 hp each)were in operation during the inspection. They were combusting green wood
chip and screened turkey litter at an approximately 50/50 ratio during the inspection(Mr. Hoggard noted
this is the mix they've been generally applying in the last year). The facility began burning the turkey
litter in February 2014. Their supplier is Butterball,which has a yard in Wallace,NC,where the litter is
screened before shipping. W.E. Partners screens it again at a yard they own at a separate location. The
facility is not currently purchasing railroad ties.
I did not detect any odor on-site or off-site from the litter.
The daily fuel use calculation is backed out from steam production. Each day their computer system
auto-generates the hourly steam production. A monthly report is auto-generated that provides the daily
steam production and calculated fuel usage. The daily and monthly steam/fuel log is identical to that used
at the Cofield facility.
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Daily and monthly fuel use is also tracked through truck weight tickets. Wood tickets by supplier are
tallied weekly in a spreadsheet and then summed monthly. Mr.Hoggard noted that the litter tickets are
stored and summed monthly. I generally reviewed the weekly and monthly spreadsheets that Mr.
Hoggard uses to record the load weights. We pulled the August 2016 records,which tallied 1,836 tons of
wood chip and 1,472 tons of litter received as of 8/28/2016.
The inventory runs fairly constant into the bunker, so fuel usage is considered equal to the tons of fuel
received. The monthly calculated and weighed tonnages are close, but not exact(within 10%). 31,522
tons of biomass were combusted in 2015.
W.E.Partners supplies 70-80% of the steam demand at the rendering plant. W.E.Partners is not capable
of making enough steam to supply 100% if Valley is in full production. Valley Proteins usually operates
one of their boilers(they alternate). On a continuous full operation day the total Valley Proteins Plant
steam demand averages about 75,000-80,000 lbs/hr.
The amount of steam produced at W.E.Partners is dependent on the demand from Valley Proteins. The
rendering plant does not necessarily operate all equipment all of the time. One cooker and the feather
dryer were operating when I arrived for the inspection. The cooker was brought down at the end of the
inspection. The combined steam production at the beginning of the inspection was approximately 50.03
klbs/hr(full load). The combined steam pressure was 273 psi. The stack temperature sensor out of the
ESP was broken. The boilers were operating at the following draft pressures during the inspection:
ESB-1 Boiler A) ESB-2 (Boiler B) ESB-3 Boiler C
Draft inches H2O -0.15 -0.57 -0.22
The multiclones are inside the building with the boilers. There are small doors at the base of the
multiclones that can be easily opened to observe dust as it falls out. A truck is filled with the ash and it is
carried to the landfill. They also have an ash bin for backup storage.
The fuel bunker has large augers and moving floor grates that carry the wood chip under the floor to the
boiler room. Litter is sectioned off in the bunker. The boiler controls are set so that augers and floor
grates will automatically adjust the feed rates for the different biomass fuels to the required percentages.
The turbine was in operation during the inspection.
On the operating control screen there was a programming malfunction that prevented viewing of the
instantaneous voltage,current, spark rate,and secondary power data on Field 1 of the ESP. However,the
main TR set control panel indicated that the secondary voltage was 3.5 kW. The TR control panel
displays operational trends for which specific time periods and individual data points can be selected and
viewed.
I observed the following instantaneous Field 2 data for the ESP on the operator control panel during the
inspection:
Field 2
Voltage kV 60.1
Current(mA) 65
Spark Rate(spin) 0
Secondary Power(kW) 4
On the operator control screen the 12-hr average secondary power for the AM was 4.1 kW, and the PM
was 3.3 kW.
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2D.0504 "Particulates from od Burning Indirect Heat Exchangers"
DAQ is treating the crop residuals,turkey litter,railroad ties and telephone poles as wood under this rule.
The allowable emissions of particulate(PM)from the boilers are calculated by the equation
E= 1.1698 Q-1.1210
Where E=allowable emission limit for particulate matter in lb/million Btu
Q=Maximum heat input in million Btu/hour.
The total of maximum heat inputs of all wood burning indirect heat exchangers at the facility must be
used to determine the allowable emission limit for each boiler. Therefore,a total of 88.2 MMBtu/hour is
applied to calculate limits. Each boiler has a limit of 0.43 lb PM(filterable+condensable)/MMBtu.
In their greenfield application W.E. Partners provided an emission factor of 0.38 lb/MMBtu for biomass.
Because the emission factor was vendor supplied and the facility has a synthetic minor limit, the permit
contained a filterable PM testing condition for one of the boilers. There was also filterable and
condensable PM testing requirement for all three boilers against the GACT particulate limit. Filterable
testing was performed on all three boilers on 5/10/2012 (test ID 2012-176ST). The average emission rate
was 0.0079 Ib/MMBtu. The test report was reviewed and approved by SSCB (memo 2/13/2013).
The W.E. Partners I Cofield facility(ID 4600106)was required by permit to perform a particulate
condensable Method 202 test as well. The biomass boilers at that facility have only multi-cyclone
control. DAQ agreed to the facility's request to not include condensables in the 5/10/2012 particulate
test, if compliance with 2D.0504 was demonstrated at Cofield. The Cofield condensable test result was
0.02 lb PM/MMBtu and the total particulate was in compliance with the 2D.0504 limit. SSCB has
reviewed and approved those test results(memo 3/21/2012).
The multiclones and ESP appeared to be in good shape during the inspection.The facility is meeting the
inspection and maintenance conditions of the permit. As long as the control devices are properly
operating,W.E.Partners should be in compliance with 2D.0504.
2D.0515 "Particulates from Miscellaneous Industrial Processes"
This rule applies to the fuel bunker. According to the application the maximum truck fill rate for the
bunker is 100 tons/hour. The unloading rate is 12 tons/hour.
The equation to calculate the emission limit for filling is E=55.0(P)"-40
The equation to calculate the unloading emission limit is E=4.10(P)o.6'
E=the maximum allowable emission rate for particulate matter in lbs/hour(calculated to three significant
figures for process rates greater than 30 tons/hour)
P=the process rate in tons/hour
The filling emission limit is 51.277 lbs/hour. The unloading emission limit is 21.669 lbs/hour.
I've never found a specific particulate emission factor for truck unloading of bark and wood chip to the
bunker. There is a factor for aggregate handling and storage piles in AP-42 Section 13.2.4. The
particulate factor has to be calculated using moisture content and silt(fines)content. Assuming most of
the wood fuel will be supplied by the wood products industry,the aggregate factor that Weyerhaeuser
New Bern(facility ID No. 2500104)calculated for its wood chip truck unloading and chip handling
seems to be the best conservative factor(8.5E-4 lb/ton) for the bunker emission. Weyerhaeuser's factor
was established based on green wood/bark chip use.
Filling 100 tons/hour(8.5E-4 lb/ton)= 0.09 lbs/hour
Unloading 12 tons/hour(8.5E-4 lb/ton)=0.01 lbs/hour
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The annual fuel bunker emissions are insignificant, so there is no permit condition for this rule.
Based upon the emissions estimate the bunker is assumed to be in compliance with 2D.0515.
2D.0516 "Sulfur Dioxide Emissions from Combustion Sources"
Sulfur dioxide emissions from fuel combustion may not exceed 2.3 lbs/MMBtu heat input. This rule does
not apply if there is a limit provided in NSPS for the source. NSPS Dc applies to the boilers. However,
Subpart Dc provides no sulfur dioxide limit for wood or other vegetative combustion. This means that
213.0516 is the more restrictive rule and applies to the facility.
Wood is low in sulfur content. The AP-42 emission factor for sulfur dioxide emissions from wood
combustion is 0.025 ib/MMBtu. For the other fuels I calculated a very conservative lb S02/MMBtu based
upon 6,720 lbs fuel/hr(max for one boiler),the sulfur measured in their NSHM fuel analyses,and
stoichiometric conversion to S02. The soybean hulls' sulfur content is approximately 0.06%by weight
(0.2 lb S02/MMBtu),and the railroad ties' sulfur content is approximately 0.02%by weight(0.08 lb
S02/MMBtu). The sulfur content of the turkey litter was analyzed at 3501 ppm,or 0.3% by wt(1.6 lb
S02/MMBtu). The creosote poles contain 0.03%sulfur by weight(0.15 lb S02/NfNmtu). Cotton waste
sulfur content was similar to that of the litter. The boilers are in compliance with 2D.0516.
2D.0521 "Control of Visible Emissions"
This rule states that the 20%opacity limit does not apply if an affected source has an applicable NSPS
limitation. NSPS Dc applies to the boilers;however,there is no NSPS opacity limit for the boilers
because their sizes are less than 30 MMBtu/hour. Therefore,the limit under 213.0521 applies as it is a
more restrictive limit.
The boilers and the fuel bunker must meet a limit of 20%when averaged over a six-minute period. One
exceedance in an hour is acceptable(if less than 87%),up to four times in a 24-hour period. It was a
cloudy, rainy day during the inspection. I observed the visible emissions before entering the facility and
again before leaving the facility. The VE was approximately 5-10%.
With the ESP visible emissions are expected to be low. The turkey litter chip size is much smaller than
the green wood chips. A portion of the litter may qualify as sawdust. Any higher than expected visible
emissions may be due to firing the odd fuel blend chip sizes or due to ash composition to the ESP.
2D.0524 "New Source Performance Standards,"40CFR 60,Subpart Dc
Subpart Dc applies to any steam generating unit constructed after June 9, 1989 and that has a maximum
design heat input capacity less than 100 MMBtu/hr and greater than 10 MMBtu/hr. The regulated
pollutants are S02 and PM. However,there are no S02 or PM emissions limitations provided for these
boilers. 60.43c(c)exempts boilers under 30 MMBtu/hr from opacity requirements. 60.43c(e)(1)
exempts boilers under 30 MMBtu/hr from particulate limits. NSPS is essentially hollowed out for the
boilers at this facility.
Permit Specific Condition No. 6.a. requires the facility to record the amount of fuel combusted daily. The
facility records the daily amounts of fuel by back calculating from the steam production and keeping their
truck weight tickets. Their logs are identical to those kept at the Cofield facility.
As required by the regulation W.E. Partners II submitted their notice of construction on 3/25/2011. The
notice of startup was received by DAQ on 1/18/2012.
The facility appears to be in compliance with 2D.0524.
2D.0535 "Excessive Emissions Reporting and Malfunctions"
NSPS Subpart A has general requirements for excess emissions recordkeeping for the NSPS Dc boilers.
However, 213.0535 provides requirements for reporting. The permit condition requires the facility to
report excessive emissions that require more than four hours to repair. Any excess emissions that do not
occur during start-up or shut-down are considered a violation of the applicable standard unless the facility
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demonstrates to the Director the excess emissions are the result of a i unction. No excess
emissions have been reported by W.E. Partners II.
2D.0540 "Particulates from Fugitive Dust Emission Sources"
This rule requires the facility to prevent fugitive dust emissions from causing or contributing to
substantive complaints or excess visible emissions beyond the property boundary. Some fugitive dust
may be generated when loading and unloading fuels on-site,or from truck traffic. No fugitive dust was
observed on or off of the property during the inspection. The facility appears to be in compliance with
2D.0540.
2D.0611 "Monitoring Emissions from Other Sources"
I&M permit conditions are crafted under this rule. Permit Specific Condition No. 9 requires the facility to
perform an annual internal inspection and monthly external inspections on the multi-cyclones. I reviewed
the records, and the most recent internal inspections were performed on 10/22/2015 (previously
10/28/2014). The boiler operators inspect the exterior of the multi-clones on a shift basis, and check the
ash discharge from them by opening the discharge door. The inspections are noted in a specific line item
in the operator shift logs.
Permit Specific Condition No. 10 requires the facility to perform periodic I&M and an annual internal
inspection of the ESP. The annual inspection has to include rappers,ash removal equipment,electrodes,
buildup on the plenum,hopper, and insulators. The most recent internal inspection was on 10/20/2015
(previously 11/03/2014). They performed a cleanout of the ESP in November 2015. Maintenance
activities are recorded in the hand—written operator shift notebooks. They also keep grease and filter
change records on the ESP.
An annual outage was scheduled for the week of 10/23/2016,when the internal inspections for this year
were performed.
They perform maintenance and inspection activities on Sundays whenever Valley Proteins is shut down
for its own maintenance. They keep a weekly maintenance checklist for the boilers and emissions
controls.
The facility appears to be in compliance with 2D.0611.
2Q.0705 "Existing Facilities and SIC Calls,"2Q.0 706 "Modifications,"2Q.0711 "Emission Rates
Requiring a Permit,"and 2D.1100 "Control of Toxic Air Pollutants"
According to 2Q.0706(c), after July 10,2010 a modification to a combustion source that causes an
increase in emissions will trigger evaluation of toxics from all permitted combustion sources. However,
the NC toxics rules were modified to exempt facilities from performing toxics review for MACT/GACT
sources. R00 was issued before the toxics rule changes, so there is toxics modeling based on potential
emissions in the DAQ file for W.E. Partners II. DAQ updated the modeling to include combustion of
poultry litter up to 100%on 5/29/2013. It appears that the facility is in compliance with 2D.1100.
2D.1111 "Maximum Achievable Control Technology,"40 CFR 63,Subpart JJJJJJ— "NESHAPfor
Area Sources:Industrial, Commercial, and Institutional Boilers"
Per the regulation,these boilers are categorized"new"biomass boilers because they began construction
after June 4,2010. A summary of 6J requirements,along with comments from the inspection,are
provided as follows:
• Each boiler is limited to 0.07 lb PM/MMBtu(filterable).The facility was required to test the boilers
for filterable particulate(Methods 1-5)and provide the testing results within 180 days of startup. The
test was performed on 5/10/2012 and startup was 1/17/2012. All three boilers were tested at
maximum heat input and steam production(61.876 klbs/hr). The test was performed at the ESP
stack. The average result was 0.0079 lb/MMBtu. SSCB has reviewed and approved the test report
(test ID 2012-176ST).
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Because the boilers' performance test results showed that PM emissions are equal to or less than half
of the PM emission limit, no further performance tests for PM were required. Subpart 6J has since
been revised to require five-year testing. For boilers that have already performed initial testing under
the old language,they have until 9/14/2021 to do their next test,and then test every five years
thereafter. This new test schedule will be addressed in the permit renewal.
• The Permittee shall maintain the operating load of each unit such that it does not exceed 110 percent
of the average operating load recorded during the most recent performance stack test. The particulate
test was conducted at close to 100% load for each boiler, so the boilers are not likely to exceed the
percentage limit.
• During the performance test, W.E. Partners had to establish the minimum secondary power to the
ESP. The regulation requires the facility to maintain the secondary power input at or above the
lowest 1-hour average secondary electric power measured during the most recent particulate
performance test(63.11201). The lowest hour during the test averaged 3.4 kW. Previous inspection
reports have rounded this value down to 3 kW,which is incorrect. Both the 5/10/2012 stack test
report and W.E. Partners' site specific monitoring plan set the minimum secondary power at 3.4 kW.
• The secondary power must be monitored according to the following requirements:
- Collect the secondary amperage and voltage,or total power input monitoring system data for the
electrostatic precipitator according to 63.11224 and 63.11221,and Table 7 to Subpart JJJJJJ. The
kW must be measured and stored at a minimum of one cycle of operation every 15 minutes.
There must be a minimum of four cycles of operation representing each of the four 15-minute
periods in an hour,or at least two 15-minute data values during an hour when CMS calibration,
quality assurance, or maintenance activities are being performed,to have a valid hour of data.
The TR set software at W.E. Partners records secondary power every six minutes,and averages
those readings to each hour.
- The regulation requires hourly data be reduced to thirty-day rolling averages. W.E. Partners
tracks compliance with their kW minimum on a twelve-hr block average,which was originally
required by the 6J regulation when it was first promulgated. DAQ WaRO agreed the twelve-hr
block average is still considered an acceptable method for compliance demonstration because it is
more restrictive than the thirty-day rolling average. The twelve-hr average data is sent from the
ESP TR set panels to the computer in the control room. It is view only on the computer;the data
is saved in the TR control set hardware. The operators record the twelve-hour block averages
each day by hand on a boiler operating data and inspection checklist.
Past inspections reports have noted that the twelve-hr average records have demonstrated a
comfortable margin of compliance(generally greater than 4 kW).
- The thirty-day rolling average total secondary electric power must be maintained at or above the
minimum total secondary electric power measured during the most recent performance test
(63.11211). Deviations from this requirement must be reported in an annual compliance
certification report.
I reviewed the twelve-hr average records on the operator checklists back to 1/01/2016 against a
3.0 kW minimum(at the time we were assuming this as the minimum). There were some logs
where the averages were not recorded(the notes I handwrote on those dates are attached to the
file copy of this report). Mr. Hoggard looked up the twelve-hr secondary power trends for the
missing logs on the TR set panel, and hand recorded the estimated average based on trend
observation. His observations are attached to the file copy of this report.
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During the inspectic copied 85 daily operator checklist recoi hat showed low secondary
power twelve-hour averages below 3.0 kW. We also copied the records for the day before and
day after each of these days,because the averages recorded each day are actually for the previous
day of operation. Because a significant number of the block averages indicated deviations per 40
CFR 63.11222(a)(1),I emailed Mr. Garald Cottrell on 10/03/2016, 11/04/2016 and 11/07/2016,
requesting hourly and thirty-day rolling average data. Mr. Cottrell provided the twelve-hour
averages by electronic file on 11/07/2016,and provided hourly averages and thirty-day rolling
averages by electronic file on 11/14/2016. The hourly data for days where the boilers were shut
down appear to be properly removed from the data set. I am unsure if Mr. Cottrell accurately
identified the exact hours of every startup for the boilers so far this year to properly remove them
from the data set. There may be a few half-hours of data which should have been counted toward
an hour average. In addition, for some days startup hours may have been included in the data set
to their disadvantage. The checklist copies,printouts of the electronic files and email
correspondence printouts are attached to the file copy of this report. The electronic files are
saved to the WaRO LAN at g•\AQ\Shared\Bertie08\00107\AO16s\2016 ESP 12 hour block
secondaa power avera e� s.xlsx and 20161115 W.E. Partners Hourly Secondary Power Averages
and 30-day Rolling Averages.xlsx.
According to the thirty-day average data provided by Mr. Cottrell,the averages fell below the 3.4
kW minimum during 53 operating days between mid-day on 3/28/2016 through early morning
on 5/30/2016.
Record the results of any inspections, calibrations,or validation checks.
§63.11221(c)and §63.11225(c)(6)require the facility to track periods of monitoring downtime
and monitor malfunctions. The Division of Air Quality's"North Carolina Continuous
Monitoring Enforcement Plan(NCCEP)"applies to regulatory required parametric monitors as
well as continuous emissions monitors. There were no recorded kW monitor issues.
All monitoring data must be retained and accessible for at least five years. The data is only
retained for a year within the TR set hardware, so W.E. Partners saves the data to a separate
source every June in order to meet the 5-year retention requirement. As of now,they have two
years' worth of data stored.
• Startup and shutdowns must be according to manufacturer's recommended procedures. It is my
understanding that the operators are trained according to the manufacturer's requirements. It's my
understanding the Valley Proteins plant generally only operates on Saturdays and Sundays if there are
overflow loads or backlogged loads. Mr. Hoggard stated when W.E.Partners start up their boilers on
Monday,the ESP goes online when the stack temperature reaches 250°F,then steam can be sent over
to the Valley Proteins facility. He also noted the ESP remains on no matter the level of boiler
operation until the next plant or full boiler shutdown.
• The facility was required to submit a Site Specific Monitoring Plan 60 days prior to the initial
performance test. The facility failed to submit this on time, and was issued a Notice of Deficiency on
2/20/2013. The plan was submitted on 2/13/2013. It is attached to the file copy of the 2/02/2014
inspection report. The monitoring plan states that operators are to notify management when any
twelve-hr block average secondary power is below 3.4 kW.
• Biennial tune-ups are required. The following must be completed as part of the tune-up:
- As applicable, inspect the burner,and clean or replace any components of the burner as necessary
(the Permittee may delay the burner inspection until the next scheduled unit shutdown,but must
inspect each burner at least once every 36 months).
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Inspect the flame pattern,as applicable,and adjust the burner as necessary to optimize the flame
pattern.The adjustment should be consistent with the manufacturer's specifications, if available.
- Inspect the system controlling the air-to-fuel ratio,as applicable,and ensure that it is correctly
calibrated and functioning properly.
Optimize total emissions of carbon monoxide.This optimization should be consistent with the
manufacturer's specifications, if available.
Measure the concentrations in the effluent stream of carbon monoxide in parts per million, by
volume, and oxygen in volume percent,before and after the adjustments are made(measurements
may be either on a dry or wet basis,as long as it is the same basis before and after the adjustments
are made).
Maintain onsite a biennial report
A copy of the initial tune-up results are in the WARO file. The CO ppmv tested after the tune-up
were in keeping with what was measured during the 6/19/2012 stack test. The previous tune-ups
were conducted in January 2014. The 2016 tune-ups were completed 1/08/2016. Copies of the tune-
up records are attached to the file copy of this report.
• The facility must keep annual records of fuel usage. The facility must keep records of tune-ups and
tests. The facility must keep records of their NHSM determinations. All malfunctions and corrective
actions must be recorded. Most of their malfunction records are kept within the operators' logs. With
the exception of the low secondary power data,W.E. Partners appears to meet these requirements.
• The facility was required to provide a notification of startup. DAQ received the notification on
1/18/2012. A Notification of Compliance Status was due within 60 days of the initial stack test. The
NOCS must include statement that the tune-up was completed and startups and shutdowns are
conducted according to manufacturer's specifications. The NOCS was late,and a Notice of
Deficiency was issued to W.E. Partners on 2/20/2013. The NOCS was submitted on 2/13/2013. The
NOCS was resubmitted on CEDRI on 10/07/2014.
• The facility must compile annual compliance certifications by March 1 It each year. They are not
required to submit the certifications to DAQ unless requested or if there are deviations. W.E. Partners
will need to include the secondary power thirty-day average deviations in their next annual
compliance certification report.
2D.1806- "Control and Prohibition of Odorous Emissions"
This rule requires the facility to prevent objectionable odors from the facility from moving off of the
property. I did not observe any odors from the turkey litter during the inspection. The facility appears
to be in compliance with 2D.1806.
2Q.031 S "Synthetic Minor Facilities"
The uncontrolled potential facility wide PMio,CO and NOx emissions are greater than 100 tons per year.
The permit limits criteria emissions to less than 100 tons/year each so that W.E. Partners can be a
synthetic minor facility.
CO is the limiting pollutant for tracking against the synthetic minor 100 tpy limit. Carbon monoxide
testing was completed on 6/19/2012(test ID 2012-176ST),and the average emission rate was measured
0.45 lb/MMBtu.The test report was approved by SSCB on 2/13/2013. CO has since been tested on the
boilers at the Cofield facility on 10/13/2015 at a rate of 0.259 lb/MMBtu.
NOx has not been tested at this facility, but was tested at the Cofield facility on 10/13/2015 at a rate of
0.289 lb/MMBtu.
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Permit Condition 13.a. requires the facility to calculate CO and NOx emission each month. W.E. Partners
must also submit an annual report(due January 301)of tons of fuel combusted each month,CO monthly
emissions and NOx monthly emissions. The 12-month totals are also reported. The 2015 report was
received on 1/18/2016. CY2015 CO emissions were 62.06 tons(they applied the 0.45 lb/MMBtu test
factor and 4,375 Btu/lb),with the highest rolling annual tonnage of 87.03 tons in February 2015. CY2015
NOx emissions were 40.68 tons(based on vendor factor of 0.295 lb/MMBtu),with the highest rolling
annual tonnage of 57.06 in February 2015.
iThe NOx and CO emissions appear to be in compliance with 2Q.0315.
2Q.0317"Avoidance Conditions"
Because uncontrolled potential emissions of PM,o are over 250 tons/year,a PSD avoidance condition was
added to the permit. Because the facility has a 100 tpy limit for PM�o to be a synthetic minor,this permit
condition points to the synthetic minor recordkeeping and reporting conditions to ensure compliance.
BACT Determination for Boilers ESB-1 and ESB-2
General Assembly of North Carolina,Session Law 2007-397,Senate Bill 3 (SB3)
The Renewable Energy and Energy Efficiency Portfolio Standard(REPS)requires 3%of North Carolina
retail sales for each electric public utility to come from renewable energy resources. One of the ways to
meet this requirement is to purchase electric power from a new renewable energy facility. W.E. Partners
is such a facility.
Senate Law 2007-397, Senate Bill 3 (SB3)(62-133.7(g))requires biomass combustion processes at a new
renewable energy facility to meet Best Available Control Technology(BACT). The BACT determination
is performed in the same manner as required by PSD. W.E. Partners II submitted a BACT analysis on
10/05/2010. A revised BACT analysis was submitted on 8/11/2015. DAQ Central Office Permits
Section has yet to complete the review of the analysis. See the discussion concerning the delay in the
BACT determination and issuance of the permit renewal in the Permit History section at the beginning of
this report.
DAQ RCO Permits has determined that the crop residual fuels,railroad ties,and turkey litter are
considered equivalent to green wood in consideration of the BACT analysis, so there was no need to
update the BACT analysis for addition of these fuels. Once the BACT determination is completed,
WaRO will complete the permit renewal and include BACT conditions.
New Source Performance Standard(NSPS)for Commercial and Industrial Solid Waste Incineration
(CISWI), 40 CFR 60,Subpart CCCC
DAQ is requiring facilities to compare renewable fuels they wish to burn to the legitimacy criteria in
40CFR 241 to be defined as non-hazardous secondary material(NHSM). Permit R02 was issued to
change each boiler description to"one clean cellulosic biomass-fired boiler(29.4 million Btu per hour
maximum heat input)." With this descriptor,W.E. Partners is able to combust any biomass fuel that
specifically meets the definition of"clean cellulosic biomass" in 40 CFR 241.2 (NHSM rule). DAQ
issued a determination on 1/26/2011 approving combustion of peanut hulls, soybean hulls,and cotton gin
residues. EPA Region IV issued a NHSM determination to W.E. Partners on 03/11/2013 approving
screened turkey poultry litter. On 1/07/2015 DAQ issued a letter to W.E. Partners approving railroad ties
as clean cellulosic fuel. On 6/05/2015 DAQ issued a letter approving creosote telephone poles.
W.E. Partners is required in permit Specific Condition A.16.to notify the DAQ in writing within 30 days
of beginning use of a new clean cellulosic biomass fuel. For any fuel that is not clearly defined as clean
cellulosic biomass in 40 CFR 241 or separately approved as a non-hazardous secondary material
(NHSM),biomass fuel by the Environmental Protection Agency,they must first submit a NHSM
determination request to the Division of Air Quality.
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Compliance History
• 2/20/2013 Notice of Deficiency
NESHAP 6J(Boiler GACT)
Failure to Submit Site Specific Monitoring Plan and Notice of Compliance Status
• 9/22/2014 Notice of Deficiency
NESHAP 6J(Boiler GACT)
ESP Operation with Respect to the Definition of Boiler Startup and
Requirements for Secondary Power Monitoring
• 5/12/2015 Notice of Violation/Notice of Recommendation of Enforcement
40CFR Part 63, Subpart JJJJJJ, Boiler GACT
ESP Operation with Respect to the Definition of Boiler Startup and
Requirements for Secondary Power Monitoring and Recordkeeping
Enforcement. Case 2015-022.Assessment:$3,545.00
Enforcement Case 2015-022 Summary
During a permit compliance inspection on 2/03/2014 it was discovered that the facility was not retaining
the 15-minute or hourly average secondary power data for five years per regulatory requirement. The .
data was also not accessible for review due to encryption issues. The failure of W.E. Partners II,LLC to
retain the secondary power data was considered a deviation of§63.11225,and a Notice of Deficiency
letter was issued to the company on 9/22/2014. The NOD set a deadline of 11/30/2014 for W.E. Partners
II, LLC to complete changes in the secondary voltage monitoring system to record and store all secondary
power data. This data was not accessible at the plant during DAQ inspection on 3/19/2015. The
company confirmed on 3/20/2015 that data collection changes had not yet been installed for the Lewiston
facility. W.E. Partners reported that Lewiston's data began to be saved starting 4/01/2015. The
5/12/2015 NOV/NRE was issued for failing to meet the deadline set in the NOD for storing data.
Per Permit Specific Condition 1 l.c., General Duty Clause(40 CFR 63.11205(a))and Permit General
Condition B.6. state at all times the Permittee must operate and maintain any affected source, including
associated air pollution control equipment and monitoring equipment, in a manner consistent with safety
and good air pollution control practices for minimizing emissions. Unless otherwise specified by the
permit,no emission source may be operated without the concurrent operation of its associated air cleaning
device(s)and appurtenances. During the 2/03/2014 compliance inspection it was discovered that the
boilers were supplying approximately 25,000 pounds of steam per hour to neighboring Valley Proteins,
but the electrostatic precipitator(ESP)on the boilers was not in operation. The reason the facility
provided is the ESP could not be turned on until the gas temperature reached 300°F. It takes longer to
reach 300°F when there is low steam demand, and if the ESP is energized too soon,there could be
condensate damage. The definition of boiler startup provided in §63.11237 is, "either the first-ever firing
of fuel in a boiler for the purpose of supplying steam or heat for heating and/or producing electricity, or
for any other purpose, or the firing of fuel in a boiler after a shutdown event for any purpose. Startup
ends when any of the steam or heat from the boiler is supplied for heating and/or producing electricity, or
for any other purpose."Therefore,the boilers were not in startup,and the ESP should have been in
operation. This deviation was included in the 9/22/2014 NOD(§63.11205). During the 3/19/2015
inspection,records indicated the facility had continued to supply steam to the wastewater treatment
system without operating the ESP. The violation was cited in the 5/12/2015 NOV/NRE.
W.E. Partners 11, LLC addressed the ESP temperature issue by meeting with Wellons Engineering
(manufacturer). Wellons issued revised guidance allowing the ESP to be energized at 250°F. W.E.
Partners II established a new SOP for start-up on the ESP. From cold startup the boilers can take up to
four hours before the temperature is good for ESP operation.Based upon my discussion with Mr.
Hoggard during this inspection and records review, it appears they are not supplying steam to Valley
Proteins until the ESP is in operation with the boiler. The lower temperature threshold appears to have
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also solved the problem whe rendering plant operations are reduced 'hen steam only need go to
the WWT system. The ESP is able to maintain temperature and continue to operate with low fire on the
boilers.
Conclusion
Based upon the 2016 hourly ESP secondary power thirty-day averages provided by the facility,there
appears to be 53 operating days during which the thirty-day averages were below the 3.4 kW minimum
that was established with required Boiler GACT 6J stack testing. Because it appears W.E. Partners' dates
listed with the data appear to run a day ahead,the deviations appear to be from mid-day 3/28/2016 until
early morning on 5/30/2016.
40 CFR 63.11201(c)states that the facility must comply with each operating limit specified in Table 3 to
this subpart that applies to the boilers. Table 3 states that the thirty-day rolling average total secondary
electric power must be maintained at or above the minimum total secondary electric power measured
during the most recent performance test(63.11211).
A Notice of Violation/Notice of Recommendation of Enforcement is recommended to be issued to the
facility for violations of 40 CFR 63.11201(c)and Table 3 of Subpart 6J. The facility otherwise appeared
to comply with the permit conditions and applicable regulations at the time of the inspection.
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