AQ_F_1600155_20220422_ST_RvwMemo

DIVISION OF AIR QUALITY
April 22, 2022
MEMORANDUM
To: Brad Newland, P.E., Wilmington Regional Office
From: James E. Hammond, Stationary Source Compliance Branch (SSCB) RSH
Subject: Collins Tree Service Pit
Newport, Carteret County, North Carolina
Facility ID 1600155, Air Permit No. 10655G00
Visible Emissions Testing of NSPS Subpart EEEE Trench Burner ID No. ACI
Performed December 18, 2021 by Collins Tree Service Pit
Tracking No. 2021-341st
A report of the subject testing has been reviewed. The Method 9 visible emissions testing
results demonstrate compliance with the applicable emissions standards. The source tested is
a portable air curtain incinerator (ACI) listed in the permit as Air Burners T-300 Trench Burner
(10 tons per hour firing capacity) that commenced construction after December 9, 2004. The
Method 9 opacity results are tabulated below.
Applicable Emissions Standards
• 15A NCAC 2D .1904 Air Curtain Incinerators (as Readopted Eff. September 1, 2019)
o Limits opacity to <_ 10% opacity (as determined by the average of 3 1-hour blocks
consisting of 10 6-minute average opacity values) at all times, other than during
startup or during malfunctions.
o Limits opacity to <_ 35% opacity (as determined by the average of 3 1-hour blocks
consisting of 10 6-minute average opacity values) during startup of the incinerator.
Incinerator startup is defined as the first 30 minutes of operation.
• 40 CFR 60 Subpart EEEE Standards of Performance for Other Solid Waste Incineration
Units for Which Construction is Commenced After December 9, 2004, or for Which
Modification or Reconstruction is Commenced on or After June 16, 2006
o Limits opacity to <_ 10% opacity (6-minute average) at all times, except during the
startup period that is within the first 30 minutes of operation or during malfunctions.
o Limits opacity during the startup period to <_ 35% opacity (6-minute average) during
startup period that is within the first 30 minutes of operation.
Table 1:Annual Test for EPA Method 9 Opacity Emission: Test Readings as Observed by Kevin Wri ht
Test Results Emission Limit Emissions
Source ID Test Date Average Opacity Opacity Standard Compliance
ACI 12-18-2021 5.3%(3-hour Test Average) <_10% 15A NCAC 2D .1904 Indicated
7.3%(Highest 6-minute Average) <_10% 60 Subpart EEEE Indicated
The Method 9 visible emissions observation forms indicate ACI operated at approximately 90%.
Note that Collins should report the actual tested operating rate in the future as well as state the
operating rate percent of permitted rate (or maximum normal rate), whichever applies.
Compliance was indicated for visible emissions from Air Burners T-300 Trench Burner ACI.
Note permit condition 2.1.A.2.e require subsequent annual opacity testing no more than
12 calendar months following the date of the previous test. If there are any questions
concerning this matter, please contact me at 919 707-8412 or [e-mail]
cc: IBEAM Documents — 1600155