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ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secrerory
MICHAEL ABRACZINSKAS
Director
October 29, 2020
Mr. Alonzo Collins, Owner
Collins Tree Service Pit
159 Oscar Hill Road
Newport,NC 28570
Subject: Approval of Extension Request for Initial NSPS Opacity Testing on Air Curtain Incinerator
Collins Tree Service Pit
Newport, Carteret County,North Carolina
Facility ID No. 1600155; Air Permit No. 10655G00
Dear Mr. Collins:
The Division of Air Quality(DAQ)has reviewed the information provided in your letter
dated October 13, 2020, in which your company makes a force majeure claim citing COVID-19
related issues and requests a 60-day extension to the deadline to complete New Source Performance
Standard(NSPS)visible emissions (opacity) testing for your air curtain incinerator(ACI). The ACI
at the Newport location is subject to NSPS Subpart EEEE -Standards of Performance for Other
Solid Waste Incineration Units for which Construction is Commenced after December 9, 2004, or
for which Modification or Reconstruction is Commenced on or after June 16, 2006. Section 2.l.A.2.
of Air Permit No. 10655G00 summarizes the specific NSPS Subpart EEEE requirements applicable
to your facility, including the requirement to conduct EPA Method 9 testing for visible emissions
within 60 days after the ACI reaches the charge rate at which it will operate,but no later than 180
days after its initial startup (Section 2.1.A.2.d). According to information you have provided to
DAQ,the ACI at the Newport location began operation on April 20, 2020 but has only operated
intermittently since initial startup. Therefore, the deadline for conducting the initial NSPS opacity
testing would have been October 17, 2020, unless an extension is granted.
The COVID-19 pandemic and resulting state restrictions on travel and business operations
have impacted companies throughout North Carolina. Specifically, your company has experienced
intermittent operations of the ACI due to COVID-19 related issues. Additionally,your company had
staff scheduled to attend Smoke School in Wilmington,NC in May 2020 to receive certification as
an official EPA Method 9 observer; however, Eastern Technical Associates(ETA) delayed the
Wilmington Smoke School until June 2020 and limited attendance due to COVID-19 concerns. The
next Smoke School classes in the Wilmington area are scheduled for November 3-5, 2020, and you
have staff registered to attend this session. Your company plans to complete the initial NSPS
opacity testing for the ACI at the Newport location shortly thereafter.
D- FW
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North Carolina Department of Environmental Quality I Division of Air Quality
217 West Jones Street 11641 Mail Service Center I Raleigh.North Carolina 276"-1641
919.707.8400

Collins Tree Service Pit
October 29,2020
Page 2 of 2
After considering the specific impacts of COVID-19 on your company, the DAQ considers
your force majeure claims as stated in your October 13, 2020 letter to be valid. Therefore, your
request for an extension to the deadline to conduct the initial NSPS visible emissions testing is
granted. The new deadline to complete the required EPA Method 9 test on the ACI at the Newport
location is December 16, 2020.
If you are not able to complete the required performance testing by the new deadline, you
may request an additional extension but must make a new and updated force majeure claim at that
time. The granting of this extension to the specific NSPS visible emissions testing deadline does not
relieve your company of the legal responsibility for compliance with any other applicable provisions
of your air quality permit or with any other applicable federal, state, or local requirements.
Due to the COVID-19 restrictions on DAQ office operations, the mailing of this letter may
be delayed. In the meantime, an electronic copy(e-copy)will be provided to you via email. If you
have any questions,please contact Gary Saunders, Stationary Source Compliance Branch
Supervisor, or me at 919-707-8400.
Sincerely,
d4e L
Stephen G. Hall
Section Chief, Technical Services
Division of Air Quality,NC DEQ
cc: Brad Newland, WIRO Air Quality Supervisor(e-copy and hard copy)
IBEAM Documents (1600155)
North Carolina Department of Environmental Quality I Division of Air Quality
217 West Jones Street 11641 Mall Service Center I Raleigh,North Carolina 27699-1641
919.707.8400