AQ_F_0800107_20200826_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Washington Regional Office
AIR QUALITY W.E.Partners II,LLC-Lewiston Woodville
NC Facility ID 0800107
Inspection Report County/FIPS:Bertie/015
Date: 08/27/2020
Facility Data Permit Data
W.E.Partners II,LLC-Lewiston Woodville Permit 10126/R03
3539 Governors Road Issued 12/8/2016
Lewiston Woodville,NC 27849 Expires 11/30/2024
Lat: 36d 8.3590m Long: 77d 13.3450m Class/Status Synthetic Minor
SIC: 4961 /Steam Supply Permit Status Active
NAILS: 22133/Steam and Air-Conditioning Supply Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Garald Cottrell Garald Cottrell Garald Cottrell MACT Part 63: Subpart 6JNSPS: Subpart Dc
President President President
[phone] [phone] [phone]
Compliance Data
Comments: The facility appears to be operating in compliance with all applicable
Federal and State rules,regulations and permit conditions at the time of the Inspection Date 08/26/2020
inspection. Inspector's Name Kurt Tidd
Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
On-Site Inspection Result Compliance
Inspector's Signature:
Date of Signature: 09/04/2020
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2014 1.60 16.50 56.90 3.30 86.80 1.10 1697.70
*Highest HAP Emitted inpounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
10/04/2019 NOV 2Q .0315 Synthetic Minor Facilities 10/04/2019
09/20/2018 NOV/NRE Part 63 -NESHAP/GACT Subpart JJJJJJ Industrial, 10/10/2018
Commercial and Institutional Boilers at Area Sources
06/07/2017 NOV Permit Condition 06/07/2017
11/22/2016 NOV/NRE 21) .1111 Maximum Achievable Control Technology 03/24/2017
7Performed Stack Tests since last FCE:
Test Results Test Method(s) Source(s)Tested
018 Compliance Method 5 ESB-1
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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 Valley Proteins rendering plant(Facility ID 0800081). Steam is also
used to heat wastewater treatment system for both Valley Proteins and Perdue(ID 0800109)during cold
months. They operate an evaporator on site to handle a portion of boiler blowdown water. The facility
has one 500 kW turbine that supplies power to the grid. The facility began operations on 1/17/2012.
Safety Concerns
Required safety equipment includes hearing protection, safety glasses, and steel-toe shoes.
Permit History
• Permit ROO was issued on December 29, 2010 for a greenfield facility.
• Permit ROI was issued on Nov. 28, 2011 for the following modifications:
- Addition of cotton gin residues, soybean hulls and peanut shells as biomass fuel.
- Addition of an electrostatic precipitator to further control particulate emissions from the boilers.
The ESP was installed to meet the Boiler GACT particulate limit for new biomass boilers(sized
between 10-30 MMBtu/hr).
- Increase in the synthetic minor annual fuel consumption limit.
• Permit R02 was issued on 06/12/2013 for the following changes:
- Changed each boiler description to"one clean cellulosic biomass-fired boiler." The permit
included approval to burn screened turkey poultry litter wood shavings. Also added definition of
"clean cellulosic biomass"per 40 CFR 241.2 and 241.3 and a permit condition for adding new
fuels under this definition.
- Removed Specific Condition No. 9 because the testing has been completed.
- Updated the monitoring requirements for the ESP and the performance testing requirements to
reflect changes in 40 CFR 63, Subpart JJJJJJ, as issued in the Federal Register on 2/01/2013.
- Updated the synthetic minor condition to include the tested CO emission rate(dated June 19,
2012) in the calculations for compliance with 2Q.0315.
- Removed permit conditions for toxics. Because the boilers are NESHAP Subpart JJJJJJ
applicable,the facility is no longer required to review toxics for them.
• Applicability Determination No. 2546—NHSM determination for creosote railroad ties was issued to
W. E. Partners on 1/07/2015. The ties met the legitimacy criteria under 40 CFR 241.3(d)(1).
• Applicability Determination No. 2596-Secondary Material Determination for creosote telephone
poles was received by DAQ on 3/16/2015. The determination was issued by DAQ on 6/05/2015.
The poles met the legitimacy criteria under 40 CFR 241.3(d)(1).
• Permit renewal R03 was issued on 12/08/2016. S133 BACT conditions were added to the permit.
The Boiler GACT Subpart 6J conditions were updated to reflect revisions to the regulation. The fuel
bunker was removed from the permit and added to the insignificant activities attachment.
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On 6/05/2018 a permit determination application was submitted to Booker Pullen (RCO Permits) for
W.E. Partners to operate an evaporator. They planned to supply the evaporator with boiler blowdown
water and landfill leachate from the Bertie Republic Landfill. The leachate would be at a daily
volume not to exceed 24,000 gallons. The landfill would truck their leachate to the site. Booker
responded by email on 8/06/2018 requesting emissions estimates from the landfill leachate. To this
date W.E. Partners has not provided such estimates, nor has the facility added any leachate to the
evaporator (no contract was finalized). Both Booker and I verbally notified Mr. Cottrell that no
permit is required to evaporate the boiler blowdown water, and the facility has been operating the
evaporator for this purpose.
Inspection Observations and Regulatory Review
On 08/26/2020 I conducted a Full Compliance Evaluation of WE Partners in Lewiston Woodville
with the assistance of Clint Matthews,plant manager. I did not do a records review at the facility in
accordance with the DAQ's Covid 19 policy. Garald Cottrell had emailed me the records for my
review which was done as part of the inspection. The following sources are included on the permit
and Insignificant/Exempt Activities attachment to the permit:
Permitted Sources
Emission Emission Source Control Device Control System
Source ID Description ID Description
ESB-1 one clean cellulosic biomass-fired boiler MC-1 multi-cyclone
(NSPS, (29.4 million Btu per hour maximum heat (18 tubes,each 9 inches in diameter)
NESHAP) input)
ESP-1 electrostatic precipitator
(9,222 sq ft total collection plate area,
two fields with 60 kv charge per field)
ESB-2 one clean cellulosic biomass-fired boiler MC-2 multi-cyclone
(NSPS, (29.4 million Btu per hour maximum heat (18 tubes,each 9 inches in diameter)
NESHAP) input)
ESP-1 electrostatic precipitator
(9,222 sq ft total collection plate area,
two fields with 60 kv charge per field)
ESB-3 one clean cellulosic biomass-fired boiler MC-3 multi-cyclone
(NSPS, (29.4 million Btu per hour maximum heat (18 tubes,each 9 inches in diameter)
NESHAP) input)
ESP-1 electrostatic precipitator
(9,222 sq ft total collection plate area,
two fields with 60 kv charge per field)
Insignificant Source
Exemption 9 Source of Title V
Source Regulation Source of TAPS. Pollutants?
ISB-1 -Green wood fuel storage bunker 2Q . 1102(h)(5) No Yes
All three boilers were operating at the time of the inspection,they were producing approximately 52,000
pounds of steam for the Valley Proteins facility.
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W.E. Partners supplies 70-80%of the steam demand at the Valley Proteins rendering plant. W.E.
Partners is not capable of making enough steam to supply 100%if Valley is in full production. Valley
Proteins usually operates one of their own boilers as well. On a continuous full operation day,the total
Valley Proteins Plant steam demand averages about 75,000-80,000 KPPH. It is my understanding that
W.E. Partners can consistently produce a maximum of 63 KPPH but can support more than 70 KPPH for
short periods. On average W.E. Partners produces about 3.4 lbs steam/lb wood combusted.
The facility was operating Monday through Friday, shutting down on Saturday and coming back up on
Monday morning. A review of the operator's logs confirmed this. All 3 boilers were tuned on January 6,
2020 to meet the requirements of 40 CF 63.11223.
The facility began burning the turkey litter in February 2014. Their suppliers include Butterball, Case
Farms (egg houses) and independent contract poultry houses. Butterball has a yard in Wallace,NC,
where the litter is screened before shipping. W.E. Partners screens their litter at a yard they own at a
separate location. Records provided by WE Partners document the amount of wood/litter burned from
January through July of 2020. (Copy attached)
The facility is approved to combust chipped railroad ties,telephone poles and crop residuals. W.E.
Partners is not currently purchasing or receiving any of these materials for combustion in these boilers.
Daily fuel is calculated by backing out from steam production. Each day their computer system auto-
generates a report of the hourly steam production. A monthly report is also generated. The daily and
monthly steam/fuel reports are identical to those at the sister facility in Cofield.
Daily and monthly fuel use is also tracked through truck weight tickets. The inventory is constant into the
bunker, so fuel usage is considered equal to the tons of fuel received. About 9-10 loads are received each
weekday,with none usually received on weekends. They aim for the monthly calculated and weighed
tonnages to be close,but not exact(within 10%). Wood and litter tickets by supplier are tallied weekly in
a spreadsheet and then summed monthly. Weekly ticket weights for January-July 2020 are attached to
the file copy of this report and are saved in the facility SharePoint site.
The fuel bunker has large augers and moving floor grates that carry the chip under the floor to the boiler
room. It is my understanding that litter is not sectioned off in the bunker but is mixed directly into the
clean wood chip. The loading pad to the bunker was very clean, and all the fuel appeared to be contained
in the bunker.
The multiclones are inside the building with the boilers. There are small doors at the base of the
multiclones that can be easily opened to observe ash as it falls out. In the last year they began conveying
ash from the hopper directly to truck.
The amount of steam produced at W.E. Partners is dependent on the demand from Valley Proteins. The
rendering plant does not necessarily operate all equipment all of the time. All three boilers were in
operation during the inspection,producing a total of 52.00 KPPH steam. The stream pressure to Valley
was 125 psi. The ESP stack temperature was 262 'F. I observed the following data for the ESP fields:
ESP1 ESP2
59.3 kV 60.2 kV
126 ma 213 ma
26 spin 10 spin
7.0 kW 13.0 kW
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The 12-hr average secondary power for the AM hours of the previous day was 22.3 kW. The 12-hr
average secondary power for the previous day was 29.9 and 37.1 kW.
Note that the lower the spark rate,the easier it is to hold the voltage. Sparking increases with the increase
in concentration of particulates in the gas. If the gas stream is light in particulate,the kW will be higher.
If dirtier exhaust is introduced,the ESP kW will be lower,because less electricity is required to create a
charge. The system is automated to operate efficiently(i.e. minimize power), so the ESP will throttle
back on one TR set if the other is sufficiently carrying the particulate load. During the inspection I was
able to observe the ESP and heard the rappers going off.
2D.0202 "Registration of Air Pollution Sources"
This Rule gives the Director the authority to require the registration of air pollution sources and require
them to submit information about the source. It is under this Rule that the Division is requiring facilities
to submit an emissions inventory 90 days before a Permit expires. W.E. Partners will owe a 2023
emissions inventory with their next permit renewal application.
2D.0504 "Particulates from Wood Burning Indirect Heat Exchangers"
DAQ is treating the crop residuals,turkey litter,railroad ties and telephone poles as wood under this rule.
The allowable emissions of particulate(PM) from the boilers are calculated by the equation
E= 1.1698 Q-0.2230
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 88.2 MMBtu/hour is
applied to calculate limits. Each boiler has a limit of 0.43 lb PM(filterable+condensable)/MMBtu.
In their greenfield application W.E. Partners provided an emission factor of 0.38 lb/MMBtu for biomass.
Because the emission factor was vendor supplied and the facility has a synthetic minor limit, the permit
contained a filterable PM testing condition for one of the boilers. There was also filterable and
condensable PM testing requirements for all three boilers against the GACT particulate limit. Filterable
testing was performed after the ESP for all three boilers on 5/10/2012 (test ID 2012-176ST). The average
emission rate was 0.0079 lb/MMBtu. The test report was reviewed and approved by SSCB (memo
2/13/2013).
Note: The W.E. Partners I Cofield facility(ID 4600106)was required by permit to perform a particulate
condensable Method 202 test as well. The biomass boilers at that facility have only multi-cyclone
control. DAQ agreed to the facility's request to not include condensables in the 5/10/2012 particulate test
if compliance with 2D.0504 was demonstrated at Cofield. The Cofield condensable test result was 0.02
lb PM/MMBtu and the total particulate was in compliance with the 2D.0504 limit. SSCB has reviewed
and approved those test results (memo 3/21/2012).
W.E. Partners performed M5/202 testing on 5/04/2017(for SB3 BACT,test ID 2017-207ST) at the stack
following the ESP. The test result was 0.045 lb/MMBtu(condensable portion 0.0097 lb/MMBtu). The
results have been reviewed and approved by SSCB.
The ESP stack was most recently M5 tested on 10/10/2018 with one TR set in operation(test ID 2018-
303). This testing was required as part of resolution of the NRE issued on 9/20/2018. The test result was
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0.0287 lb/MMBtu. The results have been reviewed and approved by SSCB. I have informed Mr. Cottrell
that he is now eligible to submit an air permit application requesting modification to allow the boilers to
operate during a malfunction of one TR set, as long as the other set is in operation.
The facility is meeting the monthly external and annual internal inspection requirements of the permit.
The ESP was inspected at the last outage,which was the week of February 16,2020. If the control
devices are properly operating,W.E.Partners is in compliance with 2D.0504.
2D.0515 "Particulates from Miscellaneous Industrial Processes"
This rule applies to the fuel bunker. Because the bunker is an insignificant source,there is no condition
for this rule in the permit. According to the application the maximum truck fill rate for the bunker is 100
tons/hour. The unloading rate is 12 tons/hour.
The equation to calculate the emission limit for filling is E=55.0(P)0-1-40
The equation to calculate the unloading emission limit is E=4.10(P)o.6'
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 21.669 lbs/hour.
I've not found a specific particulate emission factor for truck unloading of bark and wood chip to the
bunker. There is a factor for aggregate handling and storage piles in AP-42 Section 13.2.4. The
particulate factor must be calculated using moisture content and silt(fines) content. Assuming most of
the wood fuel will be supplied by the wood products industry,the aggregate factor that International
Paper(facility ID No. 2500104) calculated in its previous inventories for its wood chip truck unloading
and chip handling seems to be a reasonable factor(8.5E-4 lb/ton)for the bunker emission. The factor was
established based on green wood/bark chip use.
Filling 100 tons/hour(8.5E-4 lb/ton)= 0.09 lbs/hour
Unloading 12 tons/hour(8.5E-4 lb/ton)=0.01 lbs/hour
The annual fuel bunker emissions are insignificant.No Visible Emissions were observed coming from the
fuel bunker during the inspection. Based upon the emissions estimate the bunker is in compliance
with 2D.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 a source. NSPS Dc applies to the boilers. However,
Subpart Dc provides no sulfur dioxide limit for wood or other vegetative combustion. This means that
2D.0516 is the more restrictive rule and applies to the facility.
Wood is low in sulfur content. The AP-42 emission factor for sulfur dioxide emissions from wood
combustion is 0.025 lb/MMBtu. For the other fuels I calculated a very conservative lb S02/MMBtu based
upon 6,720 lbs fuel/hr(max for one boiler),the sulfur measured in their NSHM fuel analyses, and
stoichiometric conversion to S02. Soybean hulls' sulfur content is approximately 0.06%by weight(0.2
lb S02/MMBtu), and railroad ties' sulfur content is approximately 0.02%by weight(0.08 lb
S02/MMBtu). The sulfur content of turkey litter was analyzed at 3501 ppm, or 0.3%by wt. (1.6 lb
S02/MMBtu). Creosote poles contain 0.03% sulfur by weight(0.15 lb S02/MMBtu). Cotton waste
sulfur content is similar to that of the litter. Documentation submitted by W.E. Partners show that they
are only combusting wood and turkey litter. The facility appears to be in compliance with 2D.0516.
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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 as it is a
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. I observed
the visible emissions for 2-3 minutes before entering the facility and again before leaving the facility.
The opacity at stack appeared to be 0-5%for both observations. I also performed visible emissions
surveillance on 5/30/2019 and 9/03/2019 while performing inspections of Perdue and Valley Proteins.
Opacity was observed at 0-5%for both dates.
Two staff retain VE certifications from Compliance Assurance Association. Their next smoke school
date is in October 2010. The smoke school is held at Perdue Cofield(facility ID 4600082).
Because the facility operates an ESP,visible emissions are expected to be less than 5%. The turkey litter
chip size is smaller than the green wood chips. A portion of the litter may qualify as sawdust. Any
higher than expected visible emissions may be due to firing the odd fuel blend chip sizes or due to ash
composition to the ESP.
2D.0524 "New Source Performance Standards,"40CFR 60,Subpart Dc
Subpart Dc applies to any steam generating unit constructed after 6/09/1989 and that has a maximum
design heat input capacity less than 100 MMBtu/hr and greater than 10 MMBtu/hr. The regulated
pollutants are S02 and PM. However,there are no S02 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. The
facility records the daily amounts of fuel by back calculating from the steam production and keeping their
truck weight tickets (the January—July 2020 weight records are attached to the file copy of this report).
Their logs' format is identical to that kept at the Cofield facility(facility ID 4600106).
As required by the regulation W.E. Partners 11 submitted their notice of construction on 3/25/2011. The
notice of startup was received by DAQ on 1/18/2012. The facility appears to be in compliance with
2D.0524.
2D.0535 "Excessive Emissions Reporting and Malfunctions"
It is stated in 2D.0535 that the regulation does not apply to sources that are NSPS and/or MACT/GACT
applicable. However, it does not make that discernment in the permit condition. 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 shutdown 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. Part 63, Subpart A has immediate reporting requirements for startup, shutdown, and
malfunction excess emissions. No Excessive Emissions reports have been received. The facility
appears to be in compliance with 2D.0535
2D.0540 "Particulates from Fugitive Dust Emission Sources"
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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 fuels on-site, or from truck traffic. No fugitive dust was
observed on or off the property during the inspection. The facility appears to be in compliance with
2D.0540.
2D.0611 "Monitoring Emissions from Other Sources"
I&M permit conditions are crafted under this rule. Permit Specific Condition No. 9 requires the facility to
perform an annual internal inspection and monthly external inspections on the multi-cyclones. We
reviewed the records, and the most recent internal inspections were performed during the outage on the
week of February 16,2020. The boiler operators inspect the exterior of the multi-clones on a shift basis
and check the ash discharge from them by opening the discharge door. They also the suction at the ports
on the rotary valves. The inspections are noted in a specific line item in the operator shift logs. If any
issues are discovered, operators notify shift leaders and repairs are immediately conducted. I reviewed
the shift records for May through August 26,2020 and the records indicated the multiclones were
inspected each shift the facility was in operation.
Permit Specific Condition No. 10 requires the facility to perform periodic I&M and an annual internal
inspection of the ESP. The annual inspection must include rappers, ash removal equipment, electrodes,
buildup on the plenum,hopper,and insulators. The most recent internal inspection was during the outage
February 16,2020. Corporate technicians clean out the ESP and calibrate instrumentation.
Day-to-day maintenance activities are recorded in the hand-written operator shift notebook. They
perform maintenance and inspection activities on Sundays whenever Valley Proteins is shut down for its
own maintenance. W.E. Partners also keeps grease and filter change records on the ESP as part of their
daily log. The facility is in compliance with 2D.0611.
2Q.0705 "Existing Facilities and SIC Calls,"2Q.0706 "Modifications,"2Q.0 711 "Emission Rates
Requiring a Permit,"and 2D.1100 "Control of Toxic Air Pollutants"
According to 2Q.0706(c), after July 10,2010 a modification to a combustion source that causes an
increase in emissions will trigger evaluation of toxics from all permitted combustion sources. However,
the NC toxics rules were modified to exempt facilities from performing toxics review for MACT/GACT
sources. R00 was issued before the toxics rule changes, so there is toxics modeling based on potential
emissions in the DAQ file for W.E. Partners 11. DAQ updated the modeling to include combustion of
poultry litter up to 100%on 5/29/2013. There should be no issue with the stack replacement last year, as
the new stack is identical in size and location. It appears that the facility is in compliance with
2D.1100.
2D.1111 "Maximum Achievable Control Technology,"40 CFR 63,Subpart JJJJJJ- "NESHAP for Area
Sources:Industrial, Commercial, and Institutional Boilers"
Per the regulation,these boilers are categorized"new"biomass boilers because they began construction
after June 4,2010. A summary of 6J requirements, along with comments from the inspection, are
provided as follows:
• Each boiler is limited to 0.07 lb PM/MMBtu(filterable). The facility was required to test the boilers
for filterable particulate(Methods 1-5)and provide the testing results within 180 days of startup. The
test was performed on 5/10/2012 and startup was 1/17/2012. All three boilers were tested close to
maximum heat input. Steam production rate was 61.876 KPPH. The test was performed at the ESP
stack. The average result was 0.0079 lb/MMBtu. SSCB has reviewed and approved the test report
(test ID 2012-176ST).
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Because the boilers' performance test results showed that PM emissions are equal to or less than half
of the PM emission limit,no further performance tests for PM were required. However, Subpart 6J
has since been revised to require five-year testing. For boilers that have already performed initial
testing under the old language,they have until 9/14/2021 to do their next test, and then test every five
years thereafter. This new test schedule was addressed in the permit renewal R03.
The facility tested for filterable+condensable particulate(M5/202) on 5/04/2017 (2017-207ST)to
demonstrate compliance with the SB3 BACT limit. The filterable emission result was 0.042
lb/MMBtu.
The ESP stack was most recently M5 tested on 10/10/2018 with one TR set in operation(test ID
2018-303). This testing was required as part of resolution of the NRE issued on 9/20/2018. The test
result was 0.0287 lb/MMBtu.
• The Permittee shall maintain the operating load of each unit such that it does not exceed 110 percent
of the average operating load recorded during the most recent performance stack test. The particulate
testing in 2017 and 2018 were conducted at close to 100%load for each boiler, so the boilers are not
likely to exceed the percentage limit.
• During the performance test,W.E. Partners had to establish the minimum secondary power to the
ESP. The regulation requires the facility to maintain the secondary power input at or above the
lowest 1-hour average secondary electric power measured during the most recent particulate
performance test(63.11201). The lowest hour during the test averaged 3.4 kW. Both the 5/10/2012
stack test report and W.E. Partners' site specific monitoring plan set the minimum secondary power at
3.4 kW.
W.E. Partners did not include any secondary power data with the 5/04/2017 or 10/10/2018 stack test
reports. During the 2017 test,based upon the hourly average data from the parametric monitor for the
12:00 PM-4:00 PM period of the test,the average secondary power was approximately 4.3 M.
Since they are not required to test for particulate until 2021 under 6J,I confirmed with Gary
Saunders, Supervisor SSCB that they don't have to re-establish the minimum kW for 6J monitoring
until they perform the 2021 6J particulate test.
• The secondary power must be monitored according to the following requirements:
- Collect the secondary amperage and voltage, or total power input monitoring system data for the
electrostatic precipitator according to 63.11224 and 63.11221, and Table 7 to Subpart JJJJJJ. The
kW must be measured and stored at a minimum of one cycle of operation every 15 minutes.
There must be a minimum of four cycles of operation representing each of the four 15-minute
periods in an hour,or at least two 15-minute data values during an hour when CMS calibration,
quality assurance, or maintenance activities are being performed,to have a valid hour of data.
The TR set software at W.E. Partners records secondary power every six minutes,and averages
those readings to each hour. They only discount hours where all readings within the hour are zero
due to shutdown of the boilers.
- The regulation requires hourly data be reduced to thirty-day rolling averages. W.E. Partners
operators usually tracks compliance with their kW minimum on a twelve-hr block average,which
was originally required by the 6J regulation when it was first promulgated. DAQ WaRO agreed
the twelve-hr block average is still considered an acceptable method for compliance
demonstration because it is more restrictive than the thirty-day rolling average.
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The twelve-hr average data for the previous day is sent from the ESP TR set panels to the
computer in the control room. It is view-only on the computer;the data is saved in the TR control
set hardware. The operators record the twelve-hour block averages for the previous day into their
daily inspection checklist.
Due to previous compliance issues,W.E. Partners can access hourly secondary power averages
for use in comparison to the 30-day rolling average limit. There is a one-hour offset in how the
system records the hourly averages. For example,the 10 AM recorded hour average is actually
for the 9 AM hour.
I reviewed the records for the secondary power trend data for both ESP fields on the date of the
inspection. Secondary power ranged 7-13W on those dates.
- The thirty-day rolling average total secondary electric power must be maintained at or above the
minimum total secondary electric power measured during the most recent performance test
(63.11211). Deviations from this requirement must be reported in an annual compliance
certification report.
W.E. Partners has to have their ESP corporate technician access the hourly kW data to create a
report. W.E Partners provided records for the 30-day rolling average, from September 1,2019
through July 31,2020. This documentation showed the minimum average value was 15.73 Kw.
There has been no violation of the minimum on a 12-hr or 30-day average basis. While at the
facility,I reviewed the daily operator logs for May through August 26,2020. The lowest 12-hr
average for secondary power during that period was 14.5 kW.
Record the results of any inspections, calibrations,or validation checks. Calibrations and
validation checks are done by the manufacturer(corporate technician)annually with the internal
inspection of the ESP. They work on the ESP only when requested or during annual outage.
- §63.11221(c)and§63.11225(c)(6)require the facility to track periods of monitoring downtime
and monitor malfunctions. The Division of Air Quality's"North Carolina Continuous
Monitoring Enforcement Plan(NCCEP)"applies to regulatory required parametric monitors as
well as continuous emissions monitors. Outside of the transformer failure violation(enforcement
case 2018-060),Mr. Hoggard said they have had no secondary power monitoring downtime since
my last inspection in August of 2018.
- All monitoring data must be retained and accessible for at least five years. The data is only
retained for a year within the TR set hardware, so the data is saved every six months to an
external hard drive in order to meet the 5-year retention requirement.
• Startup and shutdowns must be according to manufacturer's recommended procedures. It is my
understanding that the operators are trained according to the manufacturer's requirements. It's my
understanding the Valley Proteins plant generally does not operate on Sundays(and Saturdays to
some degree)if there are overflow loads or backlogged loads. Mr. Hoggard previously stated when
W.E. Partners start up their boilers on Monday,the ESP goes online when the stack temperature
reaches 250°F,then steam can be sent over to the Valley Proteins facility. He also noted the ESP
remains on no matter the level of boiler operation until the next plant or full boiler shutdown.
• The facility was required to submit a Site Specific Monitoring Plan 60 days prior to the initial
performance test. The facility failed to submit this on time, and was issued a Notice of Deficiency on
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2/20/2013. The plan was submitted on 2/13/2013. It is attached to the file copy of the 2/02/2014
inspection report. There has been no change to the plan since the date of last DAQ inspection. The
monitoring plan states that operators are to notify management when any twelve-hr block average
secondary power is below 3.4 kW.
• Biennial tune-ups are required. The following must be completed as part of the tune-up:
- As applicable, inspect the burner, and clean or replace any components of the burner as necessary
(the Permittee may delay the burner inspection until the next scheduled unit shutdown,but must
inspect each burner at least once every 36 months). The tune up was completed in January 2020.
- Inspect the flame pattern,as applicable, and adjust the burner as necessary to optimize the flame
pattern. The adjustment should be consistent with the manufacturer's specifications,if available.
- Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly
calibrated and functioning properly.
- Optimize total emissions of carbon monoxide. This optimization should be consistent with the
manufacturer's specifications,if available.
- Measure the concentrations in the effluent stream of carbon monoxide in parts per million,by
volume, and oxygen in volume percent,before and after the adjustments are made(measurements
may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments
are made).
- Maintain onsite a biennial report
The 2020 tune-ups were completed in January of 2020 and are on file at the facility. I reviewed the
records and they are complete.
• The facility must keep annual records of fuel usage. The facility must keep records of tune-ups and
tests. The facility must keep records of their NHSM determinations. All malfunctions and corrective
actions must be recorded. Malfunction records are kept within the operators' logs. NHSM records
are kept at Garald Cottrell's office. W.E. Partners appears to be in compliance with these
requirements.
• The facility was required to provide a notification of startup. DAQ received the notification on
1/18/2012. A Notification of Compliance Status was due within 60 days of the initial stack test. The
NOCS must include statement that the tune-up was completed, and startups and shutdowns are
conducted according to manufacturer's specifications. The NOCS was late, and a Notice of
Deficiency was issued to W.E. Partners on 2/20/2013. The NOCS was submitted on 2/13/2013. The
NOCS was resubmitted on CEDRI on 10/07/2014.
• The facility must compile annual compliance certifications by March Vt each year. They are not
required to submit the certifications to DAQ unless requested or if there are deviations. I reviewed
their most recent certification dated January 6,2020.
The facility appeared to be in compliance with Subpart 6J at the time of the inspection.
2D.1806- "Control and Prohibition of Odorous Emissions"
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This rule requires the facility to prevent objectionable odors from the facility from moving off the
property. W.E. Partners does not store litter on-site. It is processed within 24 hours of delivery. I did not
notice any odors from the facility at the time of the inspection.
The DAQ issued a memorandum last month that details the new exemption for storage and handling of
poultry litter from the state odor rule(new rule 2D.1806(d)(1 1)). 1 believe that this facility can qualify for
the exemption. I notified Garald Cottrell of eligibility by email on 8/26/2019. The exemption may not be
applied until the facility submits an application, and the permit is administratively amended. The facility
appears to be in compliance with 2D.1806.
2Q.0315 "Synthetic Minor Facilities"
The uncontrolled potential facility wide PMIo,CO and NOx emissions are greater than 100 tons per year.
The permit limits criteria emissions to less than 100 tons/year each so that W.E. Partners can be a
synthetic minor facility.
CO is the limiting pollutant for tracking against the synthetic minor 100 tpy limit. Carbon monoxide
testing was initially completed on 6/19/2012 (test ID 2012-176ST), and the average emission rate was
measured 0.45 lb/MMBtu. The test report was approved by SSCB on 2/13/2013. CO was tested on the
boilers at the Cofield facility on 10/13/2015 at a rate of 0.259 lb/MMBtu. NOx was tested at the Cofield
facility on 10/13/2015 at a rate of 0.289 lb/MMBtu.
Most recently,on 5/04/2017 the facility tested the boilers for all three pollutants for compliance
demonstration with the S133 BACT limits. The average filterable+condensable PM emission was 0.042
lb/MMBtu. The CO average emission was 0.42 lb/MMBtu. The average NOx was 0.33 lb/MMBtu.
These test results have been reviewed and approved by SSCB.
Permit Condition 13.a. requires the facility to calculate CO and NOx emissions each month. W.E.
Partners must also submit an annual report(due January 30t1i) of tons of fuel combusted each month, CO
monthly emissions and NOx monthly emissions. The 12-month totals are also reported. The 2018 report
was submitted on 1/17/2019. CY2018 CO emissions were reported at 90.23 tons(they applied the 0.42
lb/MMBtu test factor and 4,375 Btu/lb),this was the highest rolling 12-month CO emission for the year.
CY2018 NOx emissions were 70.90 tons(based on the test factor of 0.33 lb/MMBtu),December also
being the month of highest rolling annual tonnage.
In consideration of the above disclosure, during the inspection I asked for the 2020 monthly fuel tonnage
totals. They were summed and rounded to whole tons from the truck weight spreadsheets, so will be very
slightly different from those that will be provided in the January 2021 synthetic minor report(which is in
exact pounds)
January 5191.76 tons
February 3635.02 tons(shutdown was conducted this month)
March 4491.76 tons
April 4259.56 tons
May 4,479 tons
June 3,822 tons
July 4,234 tons
The 12 month rolling CO totals for January through July 2020 are as follows.
January 97.6 tons
February 99.0 tons
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March 97.3 tons
April 95.1 tons
May 93.8 tons
June 94.6 tons
July 94.8 tons
The facility appears to be in compliance with 2Q.0315.
2Q.0317"Avoidance Conditions"
Because uncontrolled potential emissions of PM,o are over 250 tons/year,a PSD avoidance condition was
added to the permit. Because the facility has a 100 tpy limit for PM,o to be a synthetic minor,this permit
condition points to the synthetic minor recordkeeping and reporting conditions to ensure compliance.
BACT Determination for Boilers ESB-1 and ESB-2
General Assembly of North Carolina,Session Law 2007-397,Senate Bill 3(SB3)
The Renewable Energy and Energy Efficiency Portfolio Standard(REPS)requires 3%of North Carolina
retail sales for each public utility to come from renewable energy resources. One of the ways to meet this
requirement is to purchase electric power from a new renewable energy facility like W.E. Partners.
Senate Law 2007-397, Senate Bill 3 (SB3) (62-133.7(g))requires biomass combustion processes at a new
renewable energy facility to meet Best Available Control Technology(BACT). A BACT determination
is performed in the same manner as required by PSD. W.E. Partners II submitted a BACT analysis on
10/05/2010. A revised BACT analysis was submitted on 8/11/2015. DAQ Permits determined that the
crop residual fuels,railroad ties, and turkey litter are considered equivalent to green wood for the BACT
analysis, so there was no need to update the BACT analysis for addition of these fuels.
Permit Condition A.15. for BACT was added in permit R03. The condition required the facility to
conduct initial performance testing for NOx,PM/PM,o/PM2.5 and CO on the boilers by June 6,2017 (180
days from permit issuance). W.E. Partners conducted this testing on 5/04/2017. It is my understanding
that the fuel mix during the test was 60%litter/40%wood chip. The average filterable+condensable PM
emission was 0.042 lb/MMBtu. The CO average emission was 0.42 lb/MMBtu. The average NOx was
0.33 lb/MMBtu. The test report was submitted to WaRO on 6/06/2017 (slightly more than the required
30 days after testing per condition 151.). The test report has been reviewed and approved by SSCB.
Permit condition 15.d.requires the facility to submit test protocols at least 45 days before the test date.
Condition 15.e.requires at least 15 days' notice prior to testing. W.E. Partners failed to submit the
protocol and notify the regional office prior to the test date. Therefore,no DAQ staff had the opportunity
to observe the testing. A NOV was issued to W.E.Partners on 6/07/2017.
The BACT limits and testing summary requirements are provided in the table below:
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Pollutant SB3 BACT Emission Limit Compliance Method
Staged Combustion and
Good Combustion Practices,
NOx 0.34 lb/MMBtu Initial Testing,then additional testing
(3-hr average) once per permit term thereafter
by test method determined by
DAQ approved testing protocol
S02 Firing Clean Permitted or approved NHSM biomass fuels
Cellulosic Biomass
Initial Testing then additional testing
0.05 lb/MMBtu once per permit term thereafter
PM/PMI0/PM2.5 filterable and condensable) by test method determined by DAQ
3-hour average) approved testing protocol
Good Combustion Practices
CO 0.45 lb/MMBtu Initial Testing,then additional testing
(3-hour average) once per permit term thereafter by test method
determined by DAQ approved testing protocol
Compliance with applicable provisions for
VOC Good Combustion Practices inspection and maintenance of air pollution
control equipment in 15A NCAC 02D .0315
Compliance with applicable provisions for
Hg Good Combustion Practices inspection and maintenance of air pollution
control equipment in 15A NCAC 02D .0315
Following the initial testing,the Permittee shall demonstrate compliance by testing the boilers for NOx,
PM/PMI0/PM2.5 and CO once every eight years(permit term). The tests must be completed within 30 days
before and 30 days after the eight-year span between test dates.
New Source Performance Standard(ASPS)for Commercial and Industrial Solid Waste Incineration
(CISWI), 40 CFR 60,Subpart CCCC
DAQ is requiring facilities to compare renewable fuels they wish to burn to the legitimacy criteria in
40CFR 241 to be defined as non-hazardous secondary material(NHSM). Permit R02 was issued to
change each boiler description to"one clean cellulosic biomass-fired boiler(29.4 million Btu per hour
maximum heat input)." With this descriptor,W.E. Partners can combust any biomass fuel that
specifically meets the definition of"clean cellulosic biomass"in 40 CFR 241.2 (NHSM rule). DAQ
issued a determination on 1/26/2011 approving combustion of peanut hulls, soybean hulls,and cotton gin
residues. EPA Region IV issued a NHSM determination to W.E. Partners on 03/11/2013 approving
screened turkey poultry litter. On 1/07/2015 DAQ issued a letter to W.E. Partners approving railroad ties
as clean cellulosic fuel. On 6/05/2015 DAQ issued a letter approving creosote telephone poles.
W.E. Partners is required in permit Specific Condition A.16. to notify the DAQ in writing within 30 days
of beginning use of a new clean cellulosic biomass fuel. For any fuel that is not clearly defined as clean
cellulosic biomass in 40 CFR 241 or separately approved as a non-hazardous secondary material
(NHSM),biomass fuel by the Environmental Protection Agency,they must first submit a NHSM
determination request to the Division of Air Quality.
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Compliance History (5-year)
See the WaRO file and previous inspection reports for detailed information on the listed enforcement
cases below.
• 6/22/2016 Notice of Violation/Notice of Recommendation of Enforcement
40CFR Part 63, Subpart JJJJJJ, Section 63.11201(c)and Table 3
Electrostatic Precipitator Secondary Power Thirty-Day Rolling Averages Below Minimum 3.4 kW
Enforcement Case 2016-035,Assessment$7,739.00
• 6/07/2017 Notice of Violation
SB3 BACT Permit Specific Conditions A.15.d. and A.15.e.
Failure to Submit Test Protocol Submittal and Test Notification Requirements
19/20/2018 Notice of Violation/Notice of Recommendation of Enforcement
Electrostatic Precipitator Field 2 Transformer Failure
40CFR Part 63, Subpart JJJJJJ, Section 63.11201(c)and Table 3
Permit Specific Condition I Le.ii.D.
40CFR Part 63, Subpart A, Section 63.1 0(d)(5)(ii)
G.S. 143-215.108(c)(1)and Permit General Condition B.6.
Enforcement Case 2018-060,Assessment$5,096.00
• 10/4/2019 During the last inspection records review resulted in discovery that the August 2018-July
2019 CO emission from the facility was 100.07 tons,which is a violation of the synthetic minor limit
and permit Specific Condition A.13.
Conclusion
The facility appeared to be operating in compliance with all applicable Federal and State rules,
regulations, and permit conditions the time of the inspection.
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