AQ_F_1400166_20210210_ST_RvwMemo

DIVISION OF AIR QUALITY
February 10,2021
MEMORANDUM
To: Brendan Davey,P.E., Asheville Regional Office
From: Shannon Vogel, Stationary Source Compliance Branchlmv,�ep
Subject: Sealed Air Corporation-Hudson,Hudson,Caldwell County,North Carolina
Facility ID 1400166,Permit No. 07550R09
VOC Emissions Testing of Regenerative Thermal Oxidizer OX-3 Controlling
Curing Room ES-CR,Fluff Processing Operations ES-FP, and
Polyethylene Foam Extruders EXT-1,EXT-2,EXT-3 and EXT-4
Performed August 11,2020 by Civil&Environmental Consultants,Inc.
Tracking No. 2020-134st
Civil &Environmental Consultants,Inc. (CEC)performed EPA Method 1 through 4 and 25A VOC
emissions testing at the inlet and outlet of regenerative thermal oxidizer OX-3 to determine the VOC
destruction efficiency. The test results are acceptable to determine the VOC destruction efficiency as
detailed below. No capture efficiency testing or permanent total enclosure verification was performed in
conjunction with the subject destruction efficiency testing.
OX-3 controls emissions from curing room ES-CR,fluff processing operations ES-FP, and four
polyethylene foam extruders EXT-1,EXT-2,EXT-3 and EXT-4. 15A NCAC 2Q .0315 Synthetic Minor
Facilities applies to avoid the applicability of 15A NCAC 2Q .0501 Purpose of Section and Requirement
for a Permit. Permit Condition A.12 specifies a 100 ton per 12-month period VOC limit for 2Q .0315.
CEC reported a total production rate of 204.6 pounds per hour for the polyethylene foam extruders.
Permit Condition A.12.b states the"combustion zone temperature shall be maintained at a minimum
three-hour average of 1600 degrees Fahrenheit,unless otherwise established by stack testing." The
permit also requires the"process capture efficiency shall not be less than 97 percent, and the destruction
efficiency of the thermal oxidizer shall not be less than 95 percent. The overall control efficiency
(capture efficiency times destruction efficiency)shall not be less than 92 percent."
The VOC emissions test results as tabulated below demonstrate that the oxidizer efficiency meets VOC
destruction efficiency requirement in the permit. The test results are not acceptable for use as VOC mass
emissions rates. CEC did not report the combustion zone temperature during testing.
Pollutant/Parameter Test Results Requirement
Inlet VOC as carbon' 90.0 lb/hr ---
Outlet VOC as carbon' 1.0 lb/hr ---
Destruction Efficiency 98.9% ?95%
Capture Efficiency Not Tested 97%
Overall Control Efficiency Not Determined 92%
1. Acceptable for Destruction Efficiency calculation only and shall not be used for mass emissions rate reporting/estimations.
In conclusion,the EPA Method 25A testing demonstrates OX-3 meets the destruction efficiency
requirements of the permit. If you have any questions regarding the results of this review,please contact
me at 919-707-8416 or shannon.vogeigncdenr.gov.
cc: IBEAM Documents 1400166