AQ_F_1800419_20210827_ST_RvwMemo

DIVISION OF AIR QUALITY
Technical Services Section
August 27, 2021
MEMORANDUM
To: Bruce Ingle, Mooresville Regional Office
From: Gregg O'Neal, P.E., Stationary Source Compliance Branch (SSCB)
Subject: Prysmian Cables and Systems USA, LLC
Claremont, Catawba County, North Carolina
Nitrogen Oxides (NOX) Testing Over-cladding Units ID No. ES-9 (Cell 4 &four Cell 5 units)
And Over-cladding Units ID No. ES-9a (Cells 6, 7 & remaining Cell 5 units)
Performed March 23, 2021 by McHale &Associates, Inc.
Facility ID 1800419, Permit No. 07334T29, Tracking No. 2021-019ST
McHale performed EPA Method 7E NOX emissions testing of the ES-9 and ES-9a over-cladding
units. The NOX emissions test results demonstrate compliance with the applicable limits as
discussed below.
Emissions Source ES-9 consists of over-cladding units: Cell 4 and Cell 5 (four units) controlled by
a hydrated lime injection dry scrubber fabric filter system 1 DS or a selective catalytic reduction
system 1 SCR. Emissions Source ES-9a consists of over-cladding units: Cells 6, 7, and remaining
Cell 5 units controlled by a hydrated lime injection dry scrubber fabric filter system 2DS or a
selective catalytic reduction system 2SCR. The EPA Method 7E sampling was performed
"upstream of the baghouse and lime injection" to determine the uncontrolled NOX emissions from
ES-9 over-cladding units and for ES-9a over-cladding units.
15A NCAC 2Q .0317 Avoidance Conditions for 15A NCAC 2D .0530 Prevention of Significant
Deterioration applies to ES-9 and ES-9a. The permit limits NOX emissions from each group of
emissions sources associated Over-cladding Units ES-9 and
Over-cladding Units ES-9a.
Permit Conditions 2.2.A.1 and 2.2.13.1 specify the 15A NCAC 2Q .0317 NO.emissions limits for
ES-9 and ES-9a and their respective associated sources as 250 tons per 12-month period each.
Permit Conditions 2.2.A.1.c.i and 2.2.B.1.c.i require NO, emissions testing to determine
uncontrolled NO,"emissions rates in pounds of NOX per unit-hour to be used in demonstrating
compliance with the PSD avoidance condition." The NO,,emissions "shall be determined by
multiplying operating hours for each over-cladding unit group type by the pounds of NO, per unit-
hour determined from source testing." The test results tabulated below are acceptable to establish
the "pounds of NO, per unit-hour" emissions factor for 15A NCAC 2Q .0317 PSD avoidance.
Over-cladding Units ES-9 and ES-9a - NO,, Emissions Results: March 23, 2021 Test
Pollutant EPA Test Method Emissions Sources Test Results Standard
7E ES-9 20.1 Ib/hr
NOX Over-cladding Units 15A NCAC 2Q .0317
7E ES-9a 43.0 Ib/hr PSD Avoidance
Over-cladding Units
The test results are acceptable for the monthly NOX calculations for 15A NCAC 2Q .0317
PSD avoidance. If there are any questions concerning this matter, please contact me at
[phone] or gregg.oneal ncdenr.gov.
cc: Central Files, Catawba County
IBEAM Documents - 1800419