AQ_F_0800107_20111128_PRMT_PmtRvw

NORTH CAROLINA DIVISION OF Region: Washington Regional Office
AIR QUALITY County: Bertie
Air Permit Review NC Facility ID: 0800107
Inspector's Name:Betsy Huddleston
Date of Last Inspection: 08/03/2011
Permit Issue Date: November 28,ZOl l
Compliance Code: 3-In Compliance/Greenfield
Facility Data Permit Applicability(this application only)
Applicant(Facility's Name): W E Partners II,LLC SIP: 2D(.0504, .0516,.0521,.0540,.0611, .1100,
and.I 111)and 2Q(.0315 and.0711)
Facility Address: NSPS:N/A
W E Partners 11,LLC NESHAP: Boiler GACT,40CFR 63,Subpart 6J
3539 Governors Road PSD:N/A
Lewiston Woodville,NC 27849 PSD Avoidance: PM10
NC Toxics: N/A
SIC:4961 /Steam Supply 112(r): N/A
NAICS: 22133/Steam and Air-Conditioning Supply Other: Determination of non-solid waste under
CISWI, Session Law 2007-397 SB3 BACT
Facility Classification: Before: Synthetic Minor After: Synthetic Minor revision exemption for crop residuals
Fee Classification: Before: Synthetic Minor After: S nthetic Minor
Contact Data Application Data
Facility Contact Authorized Contact Technical Contact Application Number: 0800107.1 IA
Garald Cottrell Garald Cottrell Garald Cottrell Date Received: 09/26/2011
Manager Manager Manager Application Type: Greenfield Facility
[phone] [phone] [phone] Application Schedule: State
1836 Eastchester Drive, 1836 Eastchester Drive, 1836 Eastchester Drive, Existing Permit Data
Ste 108 Ste 108 Ste 108 Existing Permit Number: 10126R00
Existing Permit Issue Date: 12/29/2010
High Point,NC 27265 High Point,NC 27265 High Point,NC 27265 Existing Permit Expiration Date: H/30/2015
Review Engineer: Betsy Huddleston Comments/Recommendations:
Issue ]0126R01
Review Engineer's Signature: Date: 11/Z OK�/l
Permit Issue Date:November 28,2011
Permit Expiration Date:November 30,2015
1. Application Summary
W.E. Partners II, LLC is a subsidiary of Wellons Energy Solutions,LLC.The company is in progress of
constructing a new biomass cogeneration facility in Lewiston Woodville,Bertie County,adjacent to the
Perdue Grain and Oilseed,LLC chicken processing and rendering facilities.There will be three 20,700
pound per hour(600 hp,29.4 MMBtu/hr)biomass-fired boilers and a steam turbine generator that will
supply steam to Perdue and power to Dominion.
W.E. Partners II, LLC submitted an application to DAQ WARO on September 26, 2011 for the following
permit modifications:
a. Addition of cotton gin residues, soybean hulls and peanut shells as biomass fuel for
combustion in the boilers.
b. Addition of an electrostatic precipitator to further control particulate emissions from the boilers.
The ESP is being installed to meet the Boiler GACT particulate limit for new biomass boilers
(sized between 10-30 MMBtu/hr).The ESP will control emissions from the boilers and multi-
clones MC-1,MC-2 and MC-3.

C. An increase in the synthetic minor annual fuel consumption limit.The increase is due to the ESP
providing additional particulate control and the permittee applying a lower vendor-guaranteed
carbon monoxide emission factor.
The application was not sealed by a professional engineer for the ESP. Washington Regional Office
accepts that the boilers and all controls are designed"as an integral part of the process"(2Q.0112(cx I)).
The boilers,multi-clones and ESP are being installed as a package unit,all designed and constructed by
Wellons.
The permittee met the zoning notification requirements. There is no zoning in the county, so a notice was
placed in the Bertie Ledger newspaper on September 28,2011. W.E.Partners II provided photographs of
a sign notifying of intent to construct. The sign appears to be properly placed along the roadside.
Of the three crop residuals, W.E. Partners plans to primarily burn the cotton gin residue. The company
does not expect to burn a large amount of soybean and peanut residuals(likely no more than one 8'x20'
box of soybean or peanut residual per week during harvest season). Peanut residuals will need to be
added below 10%by weight in the fuel mix because the hulls are really lightweight and can become
suspended in the boiler.
2. Application Chronology
Application received(minus permit app. fee) 09/26/2011
Acknowledgment letter sent 09/28/2011
Permit application fee received 10/10/2011
ESP stack and toxics data sent to Raleigh for modeling 10/27/2011
RCO modeling review memo issued 11/17/2011
Permit draft submitted for review 11/23/2011
The permit needs to be issued prior to December 1st because the facility plans to begin
operations by the end of the year.
3. Regulatory Review/Permit Stipulation Review -
The sources and control devices in the permit are modified as follows:
Emission Emission Source :Control Device Control System
Source ID Description ID Description
..._..... ....... ........ _..... (18 tubes,each _
ESB-1 ;one biomass-fired boiler(green wood, MC-1 .multi-cyclone
( g
NSPS, cotton in residue soybean and peanut 9 inches in diameter)
NESHAP) crop residuals,29.4 million Btu per hour I
maximum heat input);the biomass fuel ESP-I electrostatic precipitator
is not considered a CISWI"solid waste" (9,222 sq ft total collection plate area,
two fields with 60 kv charge per field)
t
f
............................._ ...... .. .._.__............ .............. .......... .._........ .. ....
IESB-2 one biomass-fired boiler(green wood, MC-2 multi-cyclone
`(NSPS, cotton gin residue,soybean and peanut '(18 tubes,each 9 inches in diameter)
NESHAP) crop residuals,29.4 million Btu per hour
maximum heat input);the biomass fuel ESP-1 electrostatic precipitator v
is not considered a CISWI"solid waste" (9,222 sq ft total collection plate area,
two fields with 60 kv charge per field)
Page 2

Emission Emission Source Control Device Control System
Source ID Description ID Description
ESB-3 one biomass-fired boiler(greenwood, MC-3 r(18ttiubes,each
cyclone
(NSPS, cotton gin residue,soybean and peanut 9 inches in diameter)
NESHAP) crop residuals,29.4 million Btu per hour
maximum heat input);the biomass fuel ESP-1 electrostatic precipitator
is not considered a CISWI"solid waste" (9,222 sq ft total collection plate area,
two fields with 60 kv charge per field)
----- — _-_._......._._.............__..._....._..._..........................
_—._... _ _ _ _....._......_...._._.........................._......._...._
�SB-1 een wood fuel storage bunker N/A N/A
...___ Egr g i
2D.0504 "Particulates from Wood Burning Indirect Heat Exchangers,"
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.
The Boiler GACT limits particulate emissions to 0.07 lb filterable PM/MMBtu. The W.E.Partners I
Cofield facility(ID 4600106)is required by permit to perform condensables testing within 180 days of
startup(which was July 15,2011). The biomass boilers at that facility have only multi-cyclone control.
If compliance with 213.0504 is demonstrated at Cofield,the test results will be accepted for compliance
demonstration at this facility as well. The 2D.0504 particulate testing condition in the permit will be
modified to reference the Cofield condensables test.
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
states that the limit does not apply if there is a limit provided in NSPS or NESHAP for the source. NSPS
Dc and the Boiler GACT, Subpart 6J apply to the boilers. However,neither regulation provides a sulfur
dioxide limit for wood or crop residual combustion. This means that 213.0516 is the more restrictive rule
and applies to the facility.
See the calculation for SOZ emissions in the 2Q.0315 "Synthetic Minor Facilities" and"Emissions
Review" sections on pages 7 and 12. The boilers are expected to operate in compliance with 213.0516.
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 or
NESHAP limitation. NSPS Dc and the Boiler GACT, Subpart 6J apply to the boilers. However,no
opacity limit is stated in NSPS for boilers under 30 MMBtu/hr. For 6J,the facility has a choice to
comply with a 10%opacity limit through monitoring,or forego an opacity limit and instead monitor
secondary power to the ESP. W.E. Partners has chosen to monitor power to the ESP. Because neither
NSPS nor NESHAP require opacity limits for the boilers,2D.0521 applies. The crop residuals are
expected to burn similarly to wood, so compliance is expected with 2D.0521.
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. There should be no
issues with dust because the crop residuals are being unloaded into a housed fuel bunker with only one
open side.
2D. 1111 "Maximum Achievable Control Technology,"40 CFR 63,Subpart JJJJJJ—"NESHAP
for Area Sources: Industrial,Commercial,and Institutional Boilers"
The Boiler GACT recently became effective March of 2011. Per the regulation,the boilers are
categorized"new"biomass boilers because they began construction after June 4,2010. A summary of 6J
requirements is provided as follows:
Page 3
I

1. Each boiler is limited to 0.07 lb PM/MMBtu.The facility must test the new boilers for filterable
particulate(M1-5)and provide the testing results within 180 days of startup. The test protocol
has to be submitted>60 days before the test.The test result must be submitted within 60 days
following the test. After the initial performance tests,particulate testing must be performed
triennially. (63.11210 and 63.11212)
Dean Carroll(WIRO)sent me a copy of the EPA"Clean Air Act National Stack Testing
Guidance,"dated April 27,2009. This guidance allows for testing waivers for identical units
affected by NESHAP requirements. A facility can petition the administrator(DAQ)for test
waivers if the following criteria are met:
• the units are located at the same facility;
• the units are produced by the same manufacturer,have the same model number or other
manufacturer's designation in common,and have the same rated capacity and operating
specifications;
• the units are operated and maintained in a similar manner;and
• the delegated agency determines that the margin of compliance for the identical units
tested is significant and can be maintained on an on-going basis; or other factors allow
for the determination that the variability of emissions for identical tested units is low
enough for confidence that the untested unit will be in compliance. These factors may
include,historical records and fuel characteristics yielding low variability.
SSC has recently issued a waiver from testing identical 6J units(October 31,2011 letter to
Columbus Regional Health Care System). I emailed the EPA guidance and the waiver to Garald
Cottrell for consideration. Since the permit needs to be issued by the end of November,there is
limited time for the company to submit a waiver request. Therefore,the permit will contain PM
initial performance testing requirements for each boiler. The facility can test each boiler against
their individual limits or test all three boilers against a total 0.071b/MMBtu particulate limit.
2. The facility has chosen to monitor secondary power input 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
specifics of monitoring are provided in 63.11224 and Table 7.
3. Tune-ups must be performed biennially. The first tune up should be reported with the
Notification of Compliance Status(which is due within 60 days of the initial stack test).
(63.11223 and Table 2)
4. The facility will need to compile annual compliance certifications by March 1st each year. It
appears they are not required to submit the certifications to DAQ unless there are deviations. The
facility must also keep records of fuel consumption (63.11225).
The following permit conditions will be added/modified to address 6J requirements:
1. The DAQ MACT Workgroup issued a draft permit condition for 6J applicable biomass boilers on
November 16, 2011. It will be included in the permit as Specific Condition No. 13. It will reflect
the facility's choice to monitor secondary power to the ESP.
2. Reference to 6J requirements will be included in the ESP inspection and maintenance
Specific Condition No. 11 (see 2D.061 Ibelow).
Page 4

2D.0611 "Monitoring Emissions from Other Sources:"
This regulation allows DAQ to include inspection and maintenance requirements in the permit for the
multi-cyclones and the electrostatic precipitator. Requirements for annual internal inspection,monthly
external inspection,and SSM(startup,shutdown and malfunction) logbooks on the multi-clones are
included in the synthetic minor condition in permit R00. These requirements will be stated in an
individual condition(No. 10)for RO1. Specific Condition No. 11 will be added for inspection and
maintenance requirements for the ESP:
ELECTROSTATIC PRECIPITATOR REQUIREMENTS-As required by 15A NCAC 213 .0611,
particulate matter emissions shall be controlled as described in the permitted equipment list.
a. Inspection and Maintenance Requirements-To comply with the provisions of this permit
and ensure that emissions do not exceed the regulatory limits,the Permittee shall perform
periodic inspections and maintenance(I&M)as recommended by the manufacturer and as
required by 40 CFR 63, Subpart JJJJJJ. In addition,the Permittee shall perform an
annual (for each 12 month period following the initial inspection)inspection of the
electrostatic precipitator.
As a minimum, each annual inspection will include the following:
i. Visual checks of critical components such as rappers and ash removal equipment;
ii. Checks for any equipment that does not generate an alarm in the de-energized
state,to ensure it is operational;
iii. Observations of particulate deposits on discharge and collecting electrodes,for
comparison with past and future inspections;
iv. Checks for signs of plugging of gas distribution plates,and excessive buildup on
inlet and outlet plenum floor surfaces
V. Checks for signs of hopper plugging; and
vi. Checks for broken rapper rod insulators, cracked support bushing insulators, and
broken or loose stabilizer bar insulators(if installed), and replacement as required.
b. Recordkeeping Requirements-The results of all inspections and any variance from
manufacturer's recommendations or from those given in this permit(when applicable)
shall be investigated with corrections made and dates of actions recorded in a logbook.
Records of all maintenance activities shall be recorded in the logbook. The logbook(in
written or electronic format)shall be kept on-site and made available to DAQ personnel
upon request.
2D.1806 "Control and Prohibition of Odorous Emissions"
This rule requires the facility to implement management practices sufficient to prevent objectionable
odors from the facility to move beyond the facility property boundaries. Objectionable odor is not
expected from the crop residuals while in storage or when combusted.
Page 5

r
2Q.0315 "Synthetic Minor Facilities"
To avoid Title V permitting the company currently has a 58,000 tons wood/yr combustion limit(65.6%of
potential)based upon particulate emissions from firing only wood. The addition of the ESP will
significantly reduce particulate emissions so that particulate is no longer the TV limiting pollutant.
Carbon monoxide is now the limiting pollutant.
Wellons,the boiler manufacturer,has reduced their carbon monoxide emissions guarantee from 0.38 lb
CO/MMBtu to 0.32 lb CO/MMBtu. The permit currently contains a requirement to test one boiler for
CO. This condition will remain in the permit(the boilers have to be tested for CO as part of GACT 6J
tune-up as well).
If the CO test results come back less than 0.32 lb/NCviBtu,then NOx could become the limiting pollutant
with an emission rate of 0.295 lb/MMBtu. The NOx factor is a Wellons-supplied factor that is higher
than the AP-42 factor(0.22 lb/MMBtu).
Because the crop residuals contain significantly less moisture than wood,they have higher heat content
per pound. A single tonnage limit on fuel consumption to avoid Title V is not practical. The heat
contents will have to be considered in how emissions are tracked against synthetic minor limits.
The crop residuals were tested for heat and sulfur contents at low moisture(9-13%). The heat content of
wood combusted in the boilers is cited as 4375 Btu/lb in the application.
Crop Residual Heat (Btu/lb) Sulfur(% by wt.)
cotton gin residual 7,171 0.32
soy bean crop residual 7,394 0.13
peanut crop residual 7,483 0.16
To maximize the amount of fuel that can be burned,the permit Title V avoidance condition should track
emissions from the individual fuels. The permit avoidance condition is revised as follows:
LIMITATION TO AVOID 15A NCAC 2Q.0501 -Pursuant to 15A NCAC 2Q .0315 "Synthetic
Minor Facilities,"to avoid the applicability of 15A NCAC 2Q .0501 "Purpose of Section and
Requirement for a Permit,"as requested by the Permittee,facility-wide emissions shall be less than
the following:
Pollutant Emission Limit ­7
Tons per consecutive 12-month period)
PM10 100
CO 100
............._............................................................_......................._............._................_...................................._......_._..._._.......__......
NOx 100
SOZ 100
....._....... _........................................................._........................................_...................._..........................................................
......_._.......
VOC 100
a. Operations Restrictions-To ensure emissions do not exceed the limitations above,the
following shall be calculated monthly for the biomass boilers(ID Nos. ESB-1,ESB-2
and ESB-3):
i. CO and NOx emissions from each biomass fuel(wood,cotton gin residue,
soybean residual,and/or peanut residual). Each fuel's emission can be calculated
as follows:
Page 6

[(Ibs fuel)x(Btu/lb heat content)x(MMBtu/1.0E6 Btu)x(emission f ictor)J/2000
where: CO emission factor=0.32 lb/MMBtu or tested rate
NOx emission factor=0.295 lb/MMBtu
ii. the rolling 12-month facility-wide CO and NOx emissions.
b. Recordkeeping Requirements
i. The Permittee shall record monthly:
1. the monthly tons of each fuel combusted,and
2. the monthly and rolling 12-month CO and NOx emissions
c. Reporting Requirements-Within 30 days after each calendar year,regardless of the
actual emissions,the Permittee shall submit the following:
i. the tons of each fuel combusted per month in the calendar year,
ii. for each calendar month,the rolling 12-month total facility-wide CO and NOx
emissions.
Because the sulfur contents of the crop residuals are higher than wood, S02 emissions need to be
considered. Craven County Wood Energy(Facility ID 2500158, 06419T20)has a permit to burn cotton
gin residue. I referenced Mike Brandon's R17 permit review(dated October 1,2004)for Craven County
Wood Energy to calculate the sulfur dioxide increase when burning cotton gin residue. He used a more
practical approach over direct stoichiometric conversion. Wood sulfur content is 0.06%by weight(600
ppmw)and the cotton gin residue sulfur content is 0.32%by weight(3200 ppmw). The AP-42 factor for
S02 from wood/bark combustion is 0.025 lb/MMBtu(0.22 lb/ton). Assuming similar retention of sulfur
in the ash,a ratio of sulfur contents(3200/600)is applied to the factor to determine how much S02 may
be emitted from cotton gin residue.
(0.22 lb/ton wood factor)(5.33 ratio)(tons cotton gin residual)=200,000 lbs S02
cotton residual= 170,454 tons
The maximum cotton residue tonnages that can be burned while remaining under 100 tons CO and NOx
are less than that for S02, so it is not necessary to track crop residual fuel use against a synthetic minor
limit for sulfur dioxide.
2Q.0705"Existing Facilities and SIC Calls,"2Q.0706"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. Because
the facility is adding an ESP and is increasing the fuel combustion limit,the facility's toxics model needs
to be revised.
Page 7

The current model uses a single representative combined stack for all three boilers. For the revised
model, the ESP stack replaces the combined stack.
W.E. Partners II believes the cost estimate from their consultant to do a modeling revision is too high.
Due to the cost,the facility was considering dropping their request to increase the fuel synthetic minor
limit. I approached RCO Permits for help. Tom Anderson agreed to assist the facility by conducting the
modeling. The ESP stack parameters are as follows:
Gas flow-42,700 ACFM
Temperature-275-350°F
Height—69' 6"
Diameter 50"
For R00 the toxics emissions were calculated using the DAQ spreadsheet(which applies AP42 factors).
The AP-42 factors represent average emissions across boilers with various particulate control devices.
Tom performed the revised modeling twice; first using AP-42 emission factors and then using 2010
NCASI published Technical Bulletin 973 factors(Tables 7.1 and 7.2). Acrolein,arsenic and benzene
AP-42 emissions did not model within the AAL.The NCASI emissions did model well within the AALs.
NCASI is a respected wood products industry trade organization that specializes in environmental
assistance to member companies. NCASI has a good working relationship with EPA and DAQ. Wood
products companies in NC are using NCASI's wood boiler factors in their annual inventories. In TB973,
NCASI evaluated the test data that was used to develop the wood combustion AP-42 factors. NCASI also
included additional data from tests at other wood products facilities. NCASI employed statistical
analysis, so some data was rejected in the process of establishing their emission factors. In the report,
NCASI provides metal emission factors from wood combustion with ESP/fabric filter controls. I selected
the median values for all factors(rather than mean)because statistically the median is not swayed by
outliers and is therefore more representative. This selection is recommended by NCASI and the pulp mills
whose inventories I review. The emission factors for the ESP are generally one order of magnitude less
than that provided in AP-42.
I called Steve Schliesser with DAQ Toxics Section to discuss use of the NCASI factors. He agreed that
the factors are acceptable for use in toxics analysis.I proposed use of the NCASI factors to Garald
Cottrell,and he agreed.
The table below provides the list of toxics emissions that were modeled using NCASI factors(except for
chlorine,which NCASI did not address). The potential emissions provided in the table assume that there
are no synthetic minor limitations,and the boilers operate 8760 hrs/yr at maximum load.
Toxic NCASI Factor Potential
Ib/MNMtu Emission/Limit
Acrolein 107-02-8 3.16E-5 0.003lb/hr
Arsenic&Compounds(total mass of 3.21E-7 0.3 lb/yr
elemental AS,arsine and all inorganic
compounds) ASC 7778394)
Benzene 7143-2 2.35E-4 181.6lbs/ r
Beryllium Metal(unreacted) 3.27E-7 0.3 lb/yr
(Component of BEC 744041-7
Cadmium Metal,elemental,unreacted 3.73E-7 0.3 lb/yr
(Component of CDC)(744043-9)
NCASI did not 1.7 lbs/day, 0.07 lb/hr
Chlorine(7782-50-5) evaluate-use AP42
factor 7.9E-4
Page 8

Toxic NCASI Factor Potential
lb/MMBtu Emission/Limit
Formaldehyde 50-00-0) 8.83E-0 0.08lb/hr
Hydrogen chloride(hydrochloric acid) 1.57E-3 0.14 lb/hr
(7647-01-0
Manganese&compounds(MNC) 3.5E-5 0.07 lb/day
Note with the NCASI factors, acrolein and manganese are well below the TPERS. Beryllium, cadmium
and hydrochloric acid are close to the TPERs.
Reference to I&M conditions for the cyclones and the ESP will be included in the toxics condition to
ensure optimum control of metal toxic emissions.
The TAPS that are emitted below their TPERs(2Q.0711)remain unchanged from R00. The TPERs for
these pollutants are provided on the following page.
Chronic Acute
Pollutant Carcinogens Toxicants Acute Systemic Irritants
(lb/yr) (lb/day) Toxicants(lb/hr) (lb/hr)
........... ....................
........................
_.............................._............ . .........._........._.._............_-................ ............ ............................_....................._............_.............. ..
Acetaldehyde(75-07-0)............. j i 6.8
Benzo(a)pyrene(Component
lof 83329/POMTV& 2.2
['56553/7PAH)(50-32-8)
1 E
CFC-11
(Trichlorofluoromethane) 140
(75-69-4)
Carbon tetrachloride(56-23- a
5) 460
Chlorobenzene(108-90 7) -
Chloroform (67-66-3) 290
'Chromium(VI)Soluble
(Chromate Compounds 0.013
I(Component of CRC)
j(So1CR6)
_........_...
DEHP(Di(2- j I
ethylhexyl)phthalate)(117- 0.63
181-7) ; [
Ethylene dichloride _
(1 2-dichloroethane)(107-06- 260
2) I
Hexachlorodibenzo-p-dioxin
1,2,3,6,7,8(57653-85-7) 0.0051
MEK(methyl ethyl ketone, 78 ( 22.4
2-butanone)(78-93-3)
........
Mercury,vapor(Component I 0.013
lof HGC)(7439-97-6)
Methyl chloroform(71-55-6) F- 250 j 64
Methylene chloride(75-09-2) 16 00 ----- 0.39
Nickel metal(Component of 0.13
NIC)(7440-02-0)
_._ Page 9

Carcinogens Chronic I Acute S stemic Acute
Pollutant Toxicants ! y Irritants
(lb/yr) (lb/day) Toxicants(lb/hr) (Ib/hr)
PCB(polychlorinated 5.6
,biphenyls)(1336-36-3)
— ------. __....._ ..... . _. _..... .....__._......._.._._..._
Pentachlorophenol(87-86-5) f 0.063 0.0064
Perchloroethylene
(tetrachloroethylene)(127- 13000
18-4)
`Phenol(108-95-2) - _ 0.24
........... ..._.... ........--....._.....................
IStyrene(100-42-5) 2.7
TCE(trichloroethylene) 4000 E ----
1(79-01-6) [
iTetrachlorodibenzo-p-dioxin, [ i
2,3,7,8-(Component of i 0.0002
CLDC&83329/POMTV)
(1746-01-6)
:Toluene(108-88-3) - 98 14.4
.Vinyl chloride(75-01-4) 26
Xylene(mixed isomers)
'(1330-20-7) 57 16.4
General Assembly of North Carolina,Session Law 2007-397,Senate Bill 3(SB3),BACT
Determination for Boilers ESB-1,ESB-2 and ESB-3
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 for calendar year
2012. One of the ways to meet this requirement is to purchase electric power from a new renewable
energy facility. W.E. Partners II plans to serve as 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 BACT. The BACT analysis is performed in the same manner as
required by PSD. Raleigh Permits Section has established that BACT analysis has to be done for PM,
PMIo,NOx, S02,CO,VOC and mercury(August 27,2010 memo from Sheila Holman).
W.E.Partners II submitted a BACT analysis on October 5,2010. DAQ Central Office Permits Section
has yet to complete the review of the analysis. W.E.Partners had recommended that multi-cyclones serve
as BACT for particulate control.The recommendation has not changed with this application. The ESP is
not being installed as BACT, but is installed to meet the Boiler GACT particulate standard for new
biomass boilers.
When W.E. Partners I,LLC(Facility ID 4600106)applied for crop residual combustion in March 2011, I
spoke with Jeff Twisdale,DAQ Central Office Permitting,about whether the crop residual fuels needed
to be included in the BACT analysis. From our conversation it is my understanding that we are
considering the crop residual fuels as equivalent fuel,and there is no need to perform a BACT
determination for them.
40 CFR 60,Subpart CCCC,"NSPS for Commercial and Industrial Solid Waste Incineration
(CISWI)"
New biomass fuels must be compared to the definition of"solid waste"under Section 129 of the Clean
Air Act(CAA). DAQ is requiring applicants to submit information about their fuel so that a
Page 10

determination can be made. If a fuel is determined to be a solid waste,the New Source Performance
Standard(NSPS)for Commercial and Industrial Solid Waste Incineration(CISWI)would apply.
40 CFR 241 exempts biomass,as stated,
"Clean cellulosic biomass means those residuals that are akin to traditional cellulosic biomass such as
forest derived biomass (e.g., green wood,forest thinnings, clean and unadulterated bark,
sawdust, trim, and tree harvesting residuals from logging and sawmill materials), corn stover and other
biomass crops used specifically for energy production (e.g., energy cane, other fast growing grasses),
bagasse and other crop residues(e.g.,peanut shells),wood collected from forest fire clearance
activities, trees and clean wood found in disaster debris, clean biomass from land clearing operations,
and clean construction and demolition wood. These fuels are not secondary materials or solid wastes
unless discarded. Clean biomass is biomass that does not contain contaminants at concentrations not
normally associated with virgin biomass materials."
The NC Division of Waste Management and DAQ have also documented by email(3/22/2011,
\\Nroarl 1\volI\DATA\DAO\Bertie08\00107\FW CISWI determination-Alternative fuels for W.E.
Partners I.txt)that the cotton gin, soybean and peanut residuals are not considered CISWI solid wastes.
4. PSD,Attainment Status, 112r
a. PSD—PM is the only uncontrolled potential emission that could exceed 250 tpy. This
application does not affect the current PSD avoidance condition in the permit.
Bertie County is triggered for increment tracking for PM, PMjo, S02i and NOx(NO2).
This application results in PM and PM10 emissions decreases. S02 emissions can -
increase when blending with crop residual. The S02 increase provided below assumes
that half of the hourly heat input is cotton gin residue(has the highest sulfur content).
PM- 33.5 lbs/hr(under R00)-6.2 lbs/hr(under RO 1)=27.3 lbs/hr reduction
PM10- 30.8 lbs/hr(under R00)-4.5 lbs/hr(under RO1)=26.3 lbs/hr reduction
S02 - 4.7 lbs/hr(RO1,blended fuel)-2.2 lbs/hr(R00,all wood)=2.5 lbs/hr increase
b. Attainment Status-This facility is in an attainment area.
C. 112r-The facility will not handle, store, or use any 112R pollutants in enough quantity
to be subject to this regulation.
5. Emissions Review
The ESP will provide greater reduction in PM and PM10 emissions.The boilers each have to meet 0.07
lb/MMBtu for the Boiler GACT, so the facility chooses to use it as the particulate emission factor for this
application. Wellons,the boiler manufacturer,has guaranteed 0.32 CO lb/MMBtu to W.E.Partners 11.
There is no change in the NOx factor or VOC factor for the boilers. Except for sulfur dioxide emissions,
the crop residual criteria pollutant emissions are being considered same as wood.
The facility originally requested a fuel limit increase to 70,000 tons per rolling 12-months to avoid Title V
permitting. However,with the addition of crop residuals to the fuel mix, fuel moisture content will vary.
The residuals moisture content is 9-12%, and half of the heat input on the boilers could eventually be
from cotton gin residue. The average fuel heat content for wood is expected to be 4,375 Btu/1b(wet),and
the heat content of the residuals is expected to be 7,100-7500 Btu/lb(dry).
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Based upon 100 TPY of CO(synthetic minor limit),the boilers can burn up to 625,000 MMBtu/yr. If all
three boilers operate simultaneously at maximum heat input,they can run up to 7086 hrs per year. If only
wood is burned,the facility can consume up to 71,428 tons wood/year.
Assuming up to 50%of the total heat input can be cotton gin residue,the maximum annual emissions are
estimated as follows.
Pollutant Factor (lb/MMBtu) Actual Maximum
Emissions (after
control
PM 0.07 (GACT limit) 21.9+0.06 tpy from
fuel bunker
PMI0 0.052a 16.2
SO2 See synthetic minor limit 12.77 (cotton)+7.8
calculations wood
NOx 0.295 vendor factor 92.2
CO 0.32 (revised vendor factor) 100
VOC 0.017 AP-42 5.3
a AP-42 Table 1.6-5 states that PMIo is 74%of total PM emitted from ESP control.
b The vendor NOx factor is slightly higher than the AP-42 factor of 0.22 lb/MMBtu.
6. Conclusions, Comments and Recommendations
a. The DAQ MACT Workgroup currently has a draft permit condition for GACT
JJJJJJ new biomass boilers. I have modified this draft condition to reflect how
W.E. Partners II plans to comply with the regulation. The condition will be
included in the permit.
b. The regulation requires the facility to test all three boilers separately against the
individual PM limit. W.E.Partners may decide to test all of the boilers simultaneously
against at total of 0.07 lb/MMBtu.The combined test would be acceptable for showing
compliance with the regulation as well. Garald Cottrell believes that the facility will be
able to do a single test with all three boilers in operation,but will consider submitting a
performance testing waiver request for the identical boilers under GACT 6J(see 2D.I I I I
discussion in the Regulatory Review Section).
a. I decided to apply NCASI wood boiler emission factors to the toxics emissions
calculations for this facility's boilers. I obtained verbal agreement from Mr. Cottrell to
apply the NCASI factors. The factors has been discussed with Steve Schliesser,DAQ
Toxics Protection Branch.
b. I recommend that the Division of Air Quality issue Permit No. 10064ROI to W. E.
Partners II, LLC.
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