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HomeMy WebLinkAboutAQ_F_0600015_20210909_CMPL_Fac-Ltr . %-_.. a RECEIVED � S I B E L C 0 a -4� ..1 S E P 1 5 2021 Sibelco North America, Inc. 107 Harris Mining Co Road•Spruce Pine,NC 28777 DWon of Air OUSMy (PHONE)828/765-4251 Asheville Regional Office eptem er 9,2021 CERTIFIED MAIL RETURN RECEIPT REQUESTED Mr. Brendan Davey,P. E. Regional Supervisor Division of Air Quality;NCDEQ 2090 U. S. Highway 70 Swannanoa,North Carolina 28778 Subject: Scrubber Monitoring Parameters Sibelco North America, Inc.—Schoolhouse Facility Spruce Pine,North Carolina,Avery County Air Permit No. 04000R22 Dear Mr. Davey: In response to your letter dated August 23, 2021 regarding the compliance inspection conducted by Mr. Amro Ali on August 4, 2021, please note the following comments. I apologize for my delay in response as, due to mailing and courier delays, I did not receive your letter until yesterday morning September 8, 2021. First, regarding the liquid injection rate of the fluid bed dryer scrubber. From my discussions with the Environmental Supervisor, we determined that Wet Scrubber WS-01 did have sufficient flow greater than 26 gpm during the inspection. This type of flow meter has a tendency to become clogged due to the water containing particulates at times. We replaced the flow meter with a different style that is less susceptible to clogging. Once the flow meter was replaced, the flow indicated around 28 gallons per minute, well above permitted levels with no other changes performed by maintenance. Thus, the liquid injection rate was indeed maintained above the required minimum at all times. Wet Scrubber WS-01 was merely noting low reading due to particulate build up in the vortex of the sensitive flow meter. We hope this new type of flow meter will require less maintenance over time. Secondly, regarding the pressure drop meters. Please note Wet Scrubbers WS-01 and WS-02 contain two (2) pressure drop gauges on each control device. The first is located at the scrubber and is a manual Dwyer Magnehelic gauge. The second is an electronic meter that feeds readings back to the Schoolhouse HMI system (computer operating system). Due to the location of the manual meters, the reliance of the Dwyer instruments are not used to make the official pressure drop readings for the compliance documentation. Attached is a screenshot of the readings as they are transmitted to the HMI system. Unfortunately, on August 4 we experienced a network outage and were unable to show Mr.Ali the results on the HMI screen. The daily pressure drop readings were logged later that day once the network was restored. Mr. Brendan Davey Page 2 Sibelco strives to comply with environmental regulations and are very proactive in maintaining compliance at our facilities. We highly regret these issues have occurred as the flow meters are historically cleaned or replaced as soon as possible. To alleviate this issue, we have revised the operator logs to note mandatory values and require an acceptable value before letting the operator proceed with data entry. Otherwise, the operator is required to initiate a corrective action. All current operators and any new operators performing monitoring will be thoroughly trained to record monitoring data correctly and to document future work orders to replace required monitoring equipment as quickly as possible. Finally, I would like to express that as normally observed, there were no visible emissions occurring from any emission sources or control devices. If you have any questions regarding this matter or require further information, please do not hesitate to contact me directly. Regards, Rick Singleton Production Manager Schoolhouse Plant rick.sin leton(a�sibelco.com 828-765-4251 New WS-01 flow meter vT; g i i i g Schoolhouse HMI screen shot showing Pressure drop on scrubbers co IFunF coNrRot ❑ n021ollvectory sLarn SIBEL ❑ � 2:02:53 PM "FILTERED" to Atmosphere WATER Local �_ FA-07 SCRUBBER WS-03 FUME C0N7ROL EXHAUST FAN TREND 0.0 gpm WS-03 BULK STORAGE 0.0"WC ACID SCRUBBER to Fluoride Trench 6.8 pH ~s smrv8 PU-37 Ws-01 DR-01 DRYER BULK STORAGE WET SCRUBBER WS-03SUMP SUMP PUMP 30.0 gpm to Atmosphere Difl,Pressure 0.707 "WC WS-02 Running ji ACID ROOM 49.0 amps WET SCRUBBER 60.0 hZ pm Faun 29.s to Atmosphere Exhaust Fan s'�Kw 0.6"WC 8.0 pH Local Local FA-06 Pu31 SCRUBBER WS-02 SCRUBBER WS-02 EXHAUST FAN RECIRC PUMP