AQ_F_1000127_20210702_ST_RvwMemo

DIVISION OF AIR QUALITY
Technical Services Section
July 2, 2021
MEMORANDUM
To: Brad Newland, P.E., Wilmington Regional Office
From: Gregg O'Neal, P.E., Stationary Source Compliance Branch (SSCB) P�
Subject: Chuck's Construction Mine
Calabash, Brunswick County, North Carolina, Air Permit No. 10643G01
Initial Visible Emissions Testing of NSPS Subpart EEEE Trench Burner ID No. ACI
Performed on September 24, 2020 by Chuck's Construction Mine
Facility ID 1000127, Tracking No. 2020-260ST
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 a McPherson M30G Trench Burner
(8 tons per hour firing capacity) that commenced construction after December 9, 2004. The
Method 9 opacity results are tabulated below.
The emissions standards that apply are:
• 15A NCAC 2D .1904 Air Curtain Incinerators
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.
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.
40 CFR Part 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: Initial Test for EPA Method 9 Opacity Emission: (Test Readings as Observed by Charles Bellamy)
Emission
Limit
Source Emission Source Test Test Results Opacity Emissions
ID Description Date Average Opacity Standard Compliance
McPherson M30G Trench Burner 7.06%(3-hour Test Average) <_10% 15A NCAC 2D .1904 Indicated
ACI (8 tons per hour firing capacity) 09-24-20 8 54%(Highest 6-minute Average) <_10% 1 60 Subpart EEEE Indicated
Note: NCDAQ test observer Scott Saunders also took Method 9 readings during Run 1 as included with this report.
Scott's data for Run 1 indicated a 7.81% 1-hour average opacity and a 9.375% highest 6-minute average.
The visible emissions observation forms indicate the test period operating mode was 95% of
maximum normal. Representative testing is considered to be greater than approximately 90%
of maximum normal. Therefore this test was accepted.
Compliance was indicated for visible emissions from McPherson M30G Trench Burner ACI.
Note permit conditions 2.1.A.1.f.iv and 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 [phone] or gregg.oneal(@ncdenr.gov.
cc: Central Files, Brunswick County
IBEAM Documents— 1000127