AQ_F_0800044_20191218_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Washington Regional Office
AIR QUALITY Avoca LLC
NC Facility ID 0800044
Stack Test Observation Report County/FIPS:Bertie/015
Date: 12/19/2019
Facility Data Compliance Data
Avoca LLC Observation Date 12/18/2019
841 Avoca Farm Road Observer's Name Robert Bright
Merry Hill,NC 27957 Operating Status Operating
Lat: 36d 0.0030m Long: 76d 42.6550m Action Code PCE and Stack Test Observed
SIC: 2087/Flavoring Extracts And Syrups,nec
NAILS: 31193/Flavoring Syrup and Concentrate Manufacturing
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 01819/T53
Brian Conner Augustinus Gerritsen Brian Conner Issued 8/6/2019
Environmental Health& Vice President Environmental Health& Expires 12/31/2021
Safety Manager [phone] Safety Manager Classification Title V
[phone] [phone] Permit Status Active
Inspector's Signature: 1����/fj' Comments:
Boiler MACT DDDDD(CO,HCI,Hg and PM)
2019-311ST
Date of Signature: De tuber 20,2019
On 12/18/19,I observed the emissions testing performed on boiler ES-BB1 and ES-13132 (20.3 MMBtu/hr max.heat input)to
demonstrate compliance with 40 CFR Part 63, Subpart DDDDD, as referenced in permit specific condition 2.I.A.E. Avoca
contracted McHale Environmental (Mike Dickerson) to conduct the tests. Avoca submitted a protocol on 10/15/2019, and
DAQ approved the protocol by letter on 11/21/2019.
Volumetric Flow,Molecular Weight,and Moisture Methods 1-4
Filterable Particulate Method 5
Carbon Monoxide Method 10
Mercury Method 30B
Hydrochloric Acid Method 26A
The emission limits are provided in permit condition 2.1.A.E.
HCI 2.2E-02 pounds per million Btu of heat input
Mercury 8.0E-07 pounds per million Btu heat input
CO 620 ppm by volume on a dry basis corrected to 3 percent oxygen,3-
run average
Filterable PM(or TSM) 3.0E-02 pounds per million Btu heat input or(2.6E-05 pounds per
million Btu heat input
I arrived on-site just before the end of Run 1 of M5, M26A and M30B had already finished as they were each two hours in
duration. The first CO run per Method 10 had been completed and Mike was going through the post run calibrations and
bias/drift checks.
Methods S and 26A Observations
Metering box M-5 was used (OH - 1.89; Y— 1.023; Calibration date: 4/18/2019). Each test run was two hours in duration.
Eight sampling points were used across two traverses,with sampling times of eight minutes per point. Readings were taken
every four minutes(two per point). Over 100 cubic feet was pulled for each run.
I observed the post-run leak checks and probe acetone rinses for runs 1 and 2 and the results are given below:
Run 1: 0.002 CFM at 10"Hg(2.5"Hg was the highest vacuum during the run)
https://neconnect.sharepoint.com/sites/DAQ-WaRO/FacilitiesBertieo8/00044/Stack Testing/20191218 BBI and BB2_DDDDD.stk.docx1

Steam production was around 21,000 pounds per hour and no VE was observed. The filter appeared very clean. The
isokinctic rate was 105%.
Run 2: 0.020 CFM at 12"Hg(8"Hg was the highest vacuum during the run)
Steam production was around 24,000 pounds per hour and no VE was observed. The filter had more accumulation than that
observed during run 1.
Method 30B Observations
Metering box HG-220-2116 was used with two activated carbon traps, A and B. The sample rate was targeted at 1
liter/minute. I was present during runs 1 and 2 and observed the following leak checks.
Post run 1:A-0.011 CFM at 10"Hg and B—0.012 CFM at 10"Hg
Pre-run 2:A-0.022 CFM at 10"Hg and B—0.024 CFM at 10"Hg
Post run 2:A-0.007 CFM at 10"Hg and B—0.020 CFM at 10"Hg
Method 10 Observations
All the cylinders used for CO,CO2 and 02 were within their respective expiration date. I was onsite for runs 1 and 2 and the
post run calibrations and bias/drift were within their respective limitations.
Comments,Conclusions and Recommendations
The stack test appeared to be conducted in accordance with the EPA methods/procedures. WaRO waits on Stationary Source
Compliance Branch acceptance before pursuing any compliance action that may result from any stack tests performed.
No visible emissions were observed from any other Avoca emission sources during the inspection.

NORTH CAROLINA DIVISION OF Washington Regional Office
AIR QUALITY Avoca LLC
NC Facility ID 0800044
Stack Test Observation Report County/FIPS:Bertie/015
Date: 12/19/2019
Facility Data Compliance Data
Avoca LLC Observation Date 12/18/2019
841 Avoca Farm Road Observer's Name Robert Bright
Merry Hill,NC 27957 Operating Status Operating
Lat: 36d 0.0030m Long: 76d 42.6550m Action Code PCE and Stack Test Observed
SIC: 2087/Flavoring Extracts And Syrups,nec
NAILS: 31193/Flavoring Syrup and Concentrate Manufacturing
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 01819/T53
Brian Conner Augustinus Gerritsen Brian Conner Issued 8/6/2019
Environmental Health& Vice President Environmental Health& Expires 12/31/2021
Safety Manager [phone] Safety Manager Classification Title V
[phone] [phone] Permit Status Active
Inspector's Signature: 1����/fj' Comments:
Boiler MACT DDDDD(CO,HCI,Hg and PM)
2019-311ST
Date of Signature: De tuber 20,2019
On 12/18/19,I observed the emissions testing performed on boiler ES-BB1 and ES-13132 (20.3 MMBtu/hr max.heat input)to
demonstrate compliance with 40 CFR Part 63, Subpart DDDDD, as referenced in permit specific condition 2.I.A.E. Avoca
contracted McHale Environmental (Mike Dickerson) to conduct the tests. Avoca submitted a protocol on 10/15/2019, and
DAQ approved the protocol by letter on 11/21/2019.
Volumetric Flow,Molecular Weight,and Moisture Methods 1-4
Filterable Particulate Method 5
Carbon Monoxide Method 10
Mercury Method 30B
Hydrochloric Acid Method 26A
The emission limits are provided in permit condition 2.1.A.E.
HCI 2.2E-02 pounds per million Btu of heat input
Mercury 8.0E-07 pounds per million Btu heat input
CO 620 ppm by volume on a dry basis corrected to 3 percent oxygen,3-
run average
Filterable PM(or TSM) 3.0E-02 pounds per million Btu heat input or(2.6E-05 pounds per
million Btu heat input
I arrived on-site just before the end of Run 1 of M5, M26A and M30B had already finished as they were each two hours in
duration. The first CO run per Method 10 had been completed and Mike was going through the post run calibrations and
bias/drift checks.
Methods S and 26A Observations
Metering box M-5 was used (OH - 1.89; Y— 1.023; Calibration date: 4/18/2019). Each test run was two hours in duration.
Eight sampling points were used across two traverses,with sampling times of eight minutes per point. Readings were taken
every four minutes(two per point). Over 100 cubic feet was pulled for each run.
I observed the post-run leak checks and probe acetone rinses for runs 1 and 2 and the results are given below:
Run 1: 0.002 CFM at 10"Hg(2.5"Hg was the highest vacuum during the run)
https://neconnect.sharepoint.com/sites/DAQ-WaRO/FacilitiesBertieo8/00044/Stack Testing/20191218 BBI and BB2_DDDDD.stk.docx1

Steam production was around 21,000 pounds per hour and no VE was observed. The filter appeared very clean. The
isokinctic rate was 105%.
Run 2: 0.020 CFM at 12"Hg(8"Hg was the highest vacuum during the run)
Steam production was around 24,000 pounds per hour and no VE was observed. The filter had more accumulation than that
observed during run 1.
Method 30B Observations
Metering box HG-220-2116 was used with two activated carbon traps, A and B. The sample rate was targeted at 1
liter/minute. I was present during runs 1 and 2 and observed the following leak checks.
Post run 1:A-0.011 CFM at 10"Hg and B—0.012 CFM at 10"Hg
Pre-run 2:A-0.022 CFM at 10"Hg and B—0.024 CFM at 10"Hg
Post run 2:A-0.007 CFM at 10"Hg and B—0.020 CFM at 10"Hg
Method 10 Observations
All the cylinders used for CO,CO2 and 02 were within their respective expiration date. I was onsite for runs 1 and 2 and the
post run calibrations and bias/drift were within their respective limitations.
Comments,Conclusions and Recommendations
The stack test appeared to be conducted in accordance with the EPA methods/procedures. WaRO waits on Stationary Source
Compliance Branch acceptance before pursuing any compliance action that may result from any stack tests performed.
No visible emissions were observed from any other Avoca emission sources during the inspection.