AQ_F_1800419_20201021_ST_RvwMemo

DIVISION OF AIR QUALITY
October 21,2020
MEMORANDUM
To: Bruce Ingle, Mooresville Regional Office
From: Shannon Vogel, Stationary Source Compliance Branch,/X*VQ
Subject: Prysmian Cables and Systems USA,LLC
Claremont, Catawba County,North Carolina
Facility ID 1800419, Permit No. 07334T29
Nitrogen Oxides(NOx)Testing for ES-9 Over-cladding Units(Cell 4& four Cell 5 units)
And ES-9a Over-cladding Units(Cells 6, 7&remaining 5)
Performed March 5, 2020 by McHale& Associates, Inc.
Tracking No. 2020-023st
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 IDS 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.B.1 specify the 2Q.0317 NOx 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 NOx emissions testing to determine uncontrolled NOx"emissions rates in pounds of
NOx per unit-hour to be used in demonstrating compliance with the PSD avoidance condition."The NOx
emissions"shall be determined by multiplying operating hours for each over-cladding unit group type by the
pounds of NOx per unit-hour determined from source testing."The test results tabulated below are
acceptable to establish the"pounds of NOx per unit-hour"emissions factor for 2Q.0317 PSD avoidance.
Pollutant Emissions Sources Test Results Standard
ES-9 17.3 lb/hr
NOx Over-claddingUnits 2Q .0317
ES-9a 51.1 lb/hr PSD Avoidance
Over-cladding Units
The test results are acceptable for the monthly NOx calculations for 2Q .0317 PSD avoidance. If you have
any questions regarding this review,please contact me at 919-707-8416 or shannon.vogelAncdenr.gov.
cc: IBEAM Documents- 1800419