AQ_F_0800107_20121005_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Washington Regional Office
AIR QUALITY W.E. Partners II,ILLC
NC Facility ID 0800107
Inspection Report County/FIPS: Bertie/015
Date: 10/05/2012
Facility Data Compliance Data = s
W.E. Partners II,LLC Inspection Date 09/27/2012
3539 Governors Road Inspector's Name Yongcheng Chen
Lewiston Woodville,NC 27849 Operating Status Operating
Lat: 36d 8.3832m Long: 77d 13.4331m Compliance Code Compliance - inspection
SIC: 4961 /Steam Supply Action Code FCE
NAICS: 22133/Steam and Air-Conditioning Supply On-Site Inspection Result Compliance
I
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact
Permit ]0126/ RO 1 i
Garald Cottrell Garald Cottrell Garald Cottrell Issued 11/28/2011
President& General President& General President&General Expires 11/30/2015
Manager Manager Manager Classification Synthetic Minor
[phone] [phone] [phone] Permit Status Active !
Inspector's Signature: Cthe inspection.omments: The facility appeared in compliance \�ith all
!ro� the conditions and regulations in the permit at the time of
Date of Signature:. 7/I,✓
Directions:
Driving directions to 3539 Governors Rd,Lewiston Woodville, NC 27849
Washington Square Mall
719 West 15th Street
Washington,NC 27889
1.Head northwest on W 15th St toward Minuteman Ln
0.3 mi
2. Slight right onto U.S. 17 Business S
0.6 mi
3.Turn right onto US-17 N
17.7 mi
4.Continue onto US-17 BUS N
2.7 mi
5.Continue onto N Carolina 125 N/N Haughton St
Continue to follow N Carolina 125 N
12.5 mi
6.Continue onto NC-903 N/N Front St
Continue to follow NC-903 N
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3.8 mi
7.'Turn right onto N Carolina 11 N/N Carolina 42 E
10.4 mi
8.Turn left onto N Carolina 308 W/W Church St
Continue to follow N Carolina 308 W
Destination will be on the left
2.9 mi
3539 Governors Rd
Lewiston Woodville,NC 27849
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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 Perdue plant(DAQ Facility ID: 0800081). The boilers began operation
on June 1, 2012.
Permit History
• Permit ROO was issued on December 29, 2010 for a greenfield facility(three boilers with
multi-clones/ESP and the fuel bunker).
• Permit RO1 was issued on Nov. 28, 2011 for addition of green wood, cotton gin residue,
soybean and peanut crop residuals as fuels.
Safety Concerns
• Hard hat, safety glasses, ear plugs, and steel-toe shoes are required.
• Be aware of trip hazards.
• Much of the equipment is hot, so do not touch anything.
• Be careful around the fuel bunker. There are unloading activities and truck traffic.
F
Permitted Sources/Inspection Observations
On 9/27/2012, I, Yongcheng Chen conducted the annual inspection of the facility. Garald Cottrell
(president)and Ron Mark(boiler operator)assisted me during the inspection. All of the sources were
in operation and were inspected.
The following sources are included on the current permit(No. 10126ROI):
Emission Emission Source Control Control System
Source ID Description D IDCe Description
i
ESB-1 one biomass-fired boiler(green MC-1 ;multi-cyclone
(NSPS, wood, cotton gin residue, soybean (18 tubes,each 9 inches in
NESHAP) and peanut crop residuals,29.4 diameter)
million Btu per hour maximum heat ,
ESl 1 electrostatic precipitator
input);the biomass fuel is not (9,222 sq ft total collection plate't
considered a CISWI solid waste area, two fields with 60 kv
charge per field)
ESB-2 one biomass-fired boiler(green MC-2 multi-cyclone
(NSPS, wood, cotton gin residue, soybean (18 tubes,each 9 inches in
NESHAP) and peanut crop residuals,29.4 diameter)
million Btu per hour maximum heat
i input);the biomass fuel is not ESP-1 electrostatic precipitator
considered a CISWI "solid waste" (9,222 sq ft total collection plate
area, two fields with 60 kv
.charge per field)
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Emission Emission Source Control Control System
Device
Source II) Description ID 3 Description
ESB-3 one biomass-fired boiler(green MC-3 multi-cyclone
(NSPS, wood, cotton gin residue,soybean (18 tubes,each 9 inches in
NESHAP) and peanut crop residuals,29.4 diameter)
million Btu per hour maximum heat
ESP-1 jelectrostatic precipitator
input);the biomass fuel is not (9,222 sq ft total collection plate
considered a CISWI "solid waste" area, two fields with 60 kv
charge per field)
513-1 green wood fuel storage bunker N/A _ N/A
The boilers were in operation when I was there. I observed the visible emissions from the boiler stacks
with 0% - 5%. The total steam produced during the inspection was 47.40 KPPH. Stack testing data:
Boiler 1: 40.050 KKPH; Boiler 2: 40.081 KKPH; Boiler 3: 40.038 KKPH. Compliance indicated.
The fuel bunker has large augers and moving floor grates that carry the wood chip under the floor to the
boiler room. There were no visible emissions from the bunker.
Regulatory Review and Record keeping/R.eporting
2D.0504 "Particulates from Wood Burning Indirect Heat Exchangers"
DAQ is treating the residuals as wood under this rule. The allowable emissions of particulate(PM)from
the boilers are calculated by the equation
E = 1.1698 Q-02230
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 58.8 MMBtu/hour is
applied to calculate each limit. Each boiler has a limit of 0.47 lb particulate/MMBtu.
W.E. Partners provided an emission factor of 0.38 Ib/MMBtu for biomass in their initial application.
Because the emission factor is vendor supplied and the facility has a synthetic minor limit,the permit
contains a PM testing condition. The test was done and the report was received by WaRO on July 17,
2012 and the review was finished by RCO on May 21,2012.
The testing result is 0.0079 lb/mm Btu. The facility is in compliance with 213.0504.
2D.0515 "PARTICULATES FROMMISCELLANEOUS INDUSTRL4L PROCESSES"
This rule applies to the fuel bunker. The initial permit application stated that the maximum fill rate for
the bunker is 100 tons/hour. The unloading rate is 8 tons/hour.
The equation to calculate the emission limit for filling is E=55.0(P)0-11-40
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The equation to calculate the unloading emission limit is E=4.10(P) .
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 16.514 Ibs/hour.
The closest emission factor for the bunker is one 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.
The aggregate factor that Weyerhaeuser New Bern(facility ID No. 2500104) uses for its green wood chip
truck unloading and chip handling seems to be the best factor for the bunker emission.
Filling 100 tons/hour(8.5E-4 lbs/ton)= 0.09 Ibs/hour
Unloading 8 tons/hour(8.5E-4 lbs/ton)=0.01 lbs/hour
The facility is in compliance with 213.0515.
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 crop residual combustion. This means that
t>. 213.0516 is the more restrictive rule and applies to the facility.
} Wood is low in sulfur. The permittee analyzed the crop residuals for sulfur content. Sulfur is well under
0.5% by weight. The boilers are 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
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 2D.0521 applies(it becomes
the 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. Visible
emissions during the inspection were 0% - 5%. The facility is in compliance with 2D.0521.
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 SO2 and PM. However,there are no SOZ 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. 1
checked the record.
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As required by permit Specific Condition No. 6.b.,W.E. Partners II submitted their notice of construction
on 3/25/2011. The notice of startup was submitted on 1/18/2012.
The facility is in compliance with 2D.0524.
2D.0535 "I XCESSIVE EMISSIONS REPORTING AND MALFUNCTIONS"
NSPS Subpart A has general requirements for excess emissions recordkeeping for the NSPS Dc boilers.
However, 2D.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
demonstrates to the Director that the excess emissions are the result of a malfunction. The facility just
began operation. It is in compliance with 2D.0535.
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 the crop residuals on-site. None were observed on the
property during the inspection. The facility is in compliance with 2D.0540.
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 do not expect the wood and crop residuals to produce a strong odor while in storage or when
combusted. 'There was a strange smell(like sulfur)on-site when we first arrived at the facility,but we
suspect it came from Perdue. The smell dissipated soon after arrival. W.E. Partners is in compliance with
2 D.1806.
2D.2609 "PARTICULATE TESTING METHODS"
This rule states that particulate testing must be conducted using Methods 5 and 202. Permit Specific
Condition No. 9 was crafted so that the results could be compared to 2D.0504 and applied as a factor for
synthetic minor emissions reporting. There are not many boilers burning crop residuals.
The test report was received by WaRO on July 17, 2012(2012-176st)and the review was finished by
RCO on May 21, 2012(#2011-226st).
2Q Q.0315 "SYNTIIETIC MINOR FACILITIES"
The uncontrolled potential facility wide PM10 emission is greater than 100 tons per year. W.E. Partners
calculates the maximum actual emission at 88.32 tons/year,assuming 8760 hours of operation. The
company wishes to limit their PM10 emissions to less than 100 tons/year;therefore,the facility size is
synthetic minor.
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Permit Condition 14. requires the company to submit an annual report that includes the monthly amount
of each fuel combusted,the total annual amount of each fuel combusted and the associated emissions of
PM10. The report is due on January 300'every year. Conditions 10 and 11. also has I&M requirements for
annual internal inspection and monthly external inspections on the multi-cyclones and ESP. The facility
must keep a logbook of inspection and maintenance activities.
I checked their record(a copy is attached to this report)and compliance indicated.
The facility just started up,so it is in compliance with 2Q. 0315 and Specific Conditions Nos. 10/1 1.
MULTI-CYCLONE REQUIREMENTS(Condition No. 10).
As required by 15A NCAC 2D .0611,particulate matter emissions shall be controlled as described in the
permitted equipment list. Records checked and compliance indicated.
ELECTROSTATIC PRECIPITATOR REQUIREMENTS (Condition No. 11).
As required by 15A NCAC 2D .0611,particulate matter emissions shall be controlled as described in the
permitted equipment list. Records checked and compliance indicated.
LIMITATION TO A VOID 15A NCAC 2D.0530 "PREVENTION OF SIGNIFICANT
DETERIORATION'
In accordance with 15A NCAC 2Q .0317,to comply with this permit and avoid the applicability of 15A
NCAC 2D .0530 "Prevention of Significant Deterioration," as requested by the Permittee,facility-wide
PM and PMto emissions shall be less than 250 tons per consecutive 12-month period.
The facility just started up, so it is in compliance with this stipulation..
TOXIC AIR POLLUTANT EMISSIONS LIMITATIONAND REPORTING REQUIREMENT
Pursuant to 15A NCAC 2D .1100 "Control of Toxic Air Pollutants".Compliance indicated by modeling
using NCASI factors.
GENERALLYAVAILABLE CONTROL TECHNOLOGY
For the three biomass-fired boilers(ID Nos. ESBA,ESB-2 and ESB-3)the Permittee shall comply with
all applicable provisions, including the notification,testing, and monitoring requirements contained in
Environmental Management Commission Standard 15A NCAC 2D .1111, as promulgated in 40 CFR 63,
Subpart JJJJJJ, "National Emission Standards for Hazardous Air Pollutants for Area Sources: Industrial,
Commercial, and Institutional Boilers", including Subpart A "General Provisions."
I checked every line of the conditions in the permit and they company followed exactly these condition.
DAQ confirmed by letter(dated 3/16/2011)that the boilers are considered existing sources under the
MACT rule. W.E. Partners will have to perform a one-time energy assessment by 3/21/2014(37 months
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after the performance test). The company will also have to perform biennial tune-ups beginning
3/21/2012 and they did on May 10 and.June 19,2012. A sample data information is as follows:
Initial Results Prior to Tuning
Tuning Trials on "A" Boiler, Lewiston, NC
Using New recipe called Recipe 75
Trial 1 Change: Baseline testing.
10:55 Comments: Appears that we will need to reduce top overfire with the new
4"air line to the metering screw
`. HZ Trim Results
Firing Rate 70.9% 32.9 0 CO2 8.7%
Top Overtire (mz 42.0°/4 Excess Air 73%
Overfire 42.4% -1 CO 920-1100
UnderFire 34.1% 0 02 9.30%
02 computer 8.7%
1 D setti ng -0.5
Results After to Tuning
Tuning Trials on "A" Boiler, Lewiston,NC
Using New recipe called Recipe 75
Trial 1 Change. Baseline testing
4:42 Comment EXCELLENT results
% HZ Trim Results
Firing Rate 69.7% 32.5 0 CO2 10.7%
Metering screw 1 100.0% Excess Air 43%
Top Overfire (mi 40.01/o CO 150-165
Overtire 42.9% 0 02 6.60°/Q
UnderFire 33.7% 0
02 computer 5.9%
1 D setti ng -0.5
Compliance History and Conclusion
There have been no compliance issues for this facility. The facility was in compliance with all the
conditions in the permit at the time of the inspection.
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Operator: Oe�ek /Ken Date 6113119
700 Urs 1300 Hrs 1900 Hrs 0100 Hrs
Blr A Blr B Blr C Blr A Btr B Blr C Blr A Blr B Blr C Blr A Blr B Blr C
Electric Meter Readin #1
Electric Meter Readin #2 --�'
Rain Gauge in. (!f more 11=1.5",w.plae Bio Ration Repo") r
Steam Flow KPPH 314. 1 S 5-1/1 5-1 -7 2• (z D.
Steam Pressure Header a5 311 2 315
4W AN
Steam Pressure Line 130 131 I AV& /3("
Firing Rate 3(00/, qa 8.2
Exhaust Stack Temp S6 IMI g 3 540
Furnace Draft"H20 13.aq 13.6 a 13.I a 11, 13 I •6 r ,a 9 aS11.9, /D,vz 10-17 LevelNalve% S Z/q y 60 fi5 9S 7 941 179 177
ESP KW 12 Hr AVG AM 6•a
ESP KW 12 Hr AVG PM q
ESP Purge Air Heater Duct Control Tcm 1y(o 1 .6
ESP Purge Air Heater Overtri Temp 1 19fj /$D
ESP Field#1 Secondary Voltage O y8,P 7
ESP Field#2 Secondary Voltage O
ESP Ho Heater#1 Temp 'ASS AS 21 .32
ESP Hopper Heater#2 Temp 313 331 320
Blow Down Water Column ✓ ✓ ✓ ve
Blow Down Tri le Low SwitchBlow Down Si t Glass ✓ ✓ ✓Boiler Gas Outlet Tem TOO TOO 5'00 5"r D O
Bottom Blow Front Sidewall Headers ✓ ✓
Soot Blow Economizer ✓ ✓ ✓
Bottom Blow Back Sidewall Headers ✓ ✓
Soot Blow Airheater ✓ I ✓
Inspect Multiclone Discharge,Inspection Door 1,1 1 ✓
Air Compressor PSI 1014 J04/ 104Y /D
Air Compressor Temp 1 76' /7 0
Air Compressor Se rator and Dryer filter Diff ✓ ✓ ✓ ✓
Blow Down Air Compressor Water Tra ✓ ✓
Turbine Bearing Temperature ✓ i/ ✓
Turbine Bearing Vibration ✓
FD Fan Outlet Temperature 915' a75 X60 a70 1d #175 3o3 1.3j D 131a 3 S D 3mS
Grate Water Pump #operating)and Pressure oZ $a (a) SC!
Grate Water Temperature A44( .2.31
Feedwater Pump #operating)and Pressure 2 6 5'0 2 10 z S
Ash Container Inspection and Level ✓ ✓
ESP Ash Auger Inspection ✓ ✓ ✓
ESP Ash Roto Lock Inspection ✓
Fuel Bunker Conveyor Chain Inspection
Fuel Incline Conveyor Chain Inspection ✓
Turbine Bearing Oil Level ✓
Turbine Vibration Level ✓ •� '�
Turbine Bearing Temperature