AQ_F_0100010_20210407_ST_STO-Rpt (4)

NORTH CAROLINA DIVISION OF Winston-Salem Regional Office
AIR QUALITY Stericycle,Inc.
NC Facility ID 0100010
Stack Test Observation Report County/FIPS:Alamance/001
Date: 04/08/2021
Facility Data Compliance Data
Stericycle,Inc. Observation Date: 04/07/2021
1168 Porter Avenue Observer's Name: Thomas Gray
Haw River,NC 27258 Operating Status: Operating
Lat: 36d 3.9660m Long: 79d 20.9230m Action Code:23 /STACK TEST OBSERVED
SIC: 4953/Refuse Systems
NAICS: 562213 /Solid Waste Combustors and Incinerators
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact permit: 05896/T25
Don Nuss Kirk Yarbrough Don Nuss Issued: 12/19/2016
Regional Compliance Facility Manager Regional Compliance Expires: 11/30/2021
Manager [phone] Manager Classification: Title V
[phone] [phone] Permit Status:Active
Inspector's Signature: /�� DMM Comments:
Date of Signature: M h-
Tested Emission Sources:
emissions Emissions Source Control n
'source YU bescription System.ID �
Control System Description
t
:...........................................................................,............................ .......... ....................................................E,...,...............................................................,............................................................................,,................................................,..,.............
........,..................
......................
dual chamber hospital,medical: ;one selective non-catalytic reduction(SNCR)system with
and infectious waste CD07 :ammonia or urea injection(19,700 ACFM,outlet airflow rate),
incinerator(HMIWI)firing :one packed bed scrubber and associated quench column in series
ESO1 natural gas(4.6 million Btu/hr CD01 :with
primary chamber burner and CD03 one venturi scrubber equipped with a mist eliminator,and
6.0 million Btu/hr secondary E CD05 :one sulfur impregnated carbon bed(6,000 ACFM, inlet airflow
chamber burner) :rate)
dual chamber hospital,medical CDO- one selective non-catalytic reduction(SNCR)system with ammor
infectious waste incinerator(HP !urea injection(19,700 ACFM, outlet airflow rate),
ESO: firing natural gas(4.6 million B CDO: one packed bed scrubber and associated quench column in series,:
primary chamber burner and 6.( CDO,;one venturi scrubber equipped with a mist eliminator,and
Btu/hr secondary chamber burn CDO,;one sulfur impregnated carbon bed(6,000 ACFM,inlet airflow ra
Introduction:
On April 6-7,2021,Mr.Thomas Gray,QSTI(I-IV),Environmental Specialist I,of the Winston Salem Regional Division of Air
Quality,contacted Mr.Don Nuss,Regional Compliance Manager,and Mr.Kirk Yarbrough,Facility Manager,both of Stericycle, Inc.,
for the purpose of observing the required triennial Toxic Air Pollutants(TAP)emissions testing of the facility's two dual chamber
hospital,medical and infectious waste incinerators(HMIWI)firing natural gas(ESO1,ES02).Mr.Derek Brewster,Project Manager,
of TRC Environmental Solutions,Inc.,was the lead for the test crew. Stericycle,Inc. is a hospital,medical,and infectious waste
incineration facility consisting of two identical units. Typical hours of operation are 24 hours/day,7 days a week,52 weeks a year.
The facility was last inspected by Ms.Taylor Hartsfield,Former WSRO Compliance Supervisor,on September 2,2020,and was
found to be operating in procedural compliance with all applicable air quality rules and regulations at that time.Due to COVID-19
concerns,Mr. Gray contacted the facility prior to the source test observation to review current on-site COVID-19 safety protocols.

According to telephone conversation with Mr.Yarbrough,there were no current active cases of COVID-19 at the facility,nor any
employees out for quarantine.Upon arrival to the facility,Mr.Gray was asked a series of questions(Travel History,Current
Symptoms,Etc.).During the observation,masks were worn by all parties and all CDC/NC DEQ COVID-19 guidelines were followed
including social distancing.
Safety:
The following PPE is required:reflective vests,safety shoes,safety glasses,and hearing protection.Due to COVID-19,a face
mask was worn. Inspectors should be aware of any vehicle/machinery traffic.
Process Description:
(As borrowed from the September 2,2020 Compliance Inspection Report,T.Hartsfield,Former WSRO-DAQ Compliance
Supervisor)A basic description of the operation of a HMIWI at this facility is as follows:A hopper is loaded with boxes of HMIW,
which represents a charge.The hopper is tipped into an open pre-incineration chamber,and,after closing,a hydraulic ram pushes the
charge into the primary combustion chamber.From there,the charge is combusted as it moves down the primary chamber,aided by
other rams and underfire air.At the end of the primary chamber,the ash and non-combusted material is quenched with water and an
Auger transfers the ash to a waste bin.This bin then goes to a landfill as the waste no longer has its original hazardous properties.Back
in the incinerator,the combustion gases from the primary chamber travel up to a secondary chamber.A secondary burner destroys any
combustible content of the primary combustion gases and reduces CO emissions.The exhaust then enters the SNCR system where
ammonia or urea is injected in order to reduce NOx formation.Afterwards,the gases enter a packed bed scrubber and associated
quench column.The packed bed scrubber has a caustic solution to reduce acid gas emissions.The quencher reduces temperature
which reduces dioxin/furan emissions.After quenching,the gases pass into the venturi scrubber to reduce PM emissions.Following
the venturi scrubber,the gases go through a mist eliminator to remove some of the steam plume.The last step is for the exhaust to pass
through the sulfur impregnated carbon bed to reduce mercury emissions.Also Associated with the two HMIWIs are two exempt
cooling towers(1-CT-1 and 1-CT-2)each with a 55,200 gallons per hour water recirculation rate.The cooling towers assist the
quencher in reducing the temperature of the exhaust.
Applicable Regulations&Emissions Limits:
Incinerators ESO1 and ES02 are subject to 15A NCAC 2D.1206 Hospital, Medical and Infectious Waste Incinerators; 15A NCAC 2D
.1100 Control of Toxic Air Pollutants;40 CFR 60 Subpart Ce Emission Guidelines and Compliance Times for
Hospital/Medical/Infectious Incinerators;40 CFR 60 Subpart Ec Standards of Performance for Hospital/Medical/Infectious
Incinerators for Which Construction is Commenced After June 20, 1996;and 40 CFR 62 Subpart HHH Federal Plan Requirements for
Hospital/Medical/Infectious Incinerators Constructed on or Before June 20, 1996.
Current Permit Conditions associated with Emissions Testing:
Condition 2.1.A.La—This condition the requirements for 2D .1100,"Control of Toxic Air Pollutants,"which limits the release of
toxic air pollutant(TAP)emissions.The limits for each TAP emitted by the affected emissions sources are described in the table
below.The facility conducted source testing on both units.from April 28-May 1,2015.The results of that test were approved by the
DAQ-SSCB per the memo issued on June 22,2016.Historically,the facility was required to complete annual TAP testing.However,
during the last permit opening,the facility requested that due to the margin of compliance for some taps(>95%C.E with the
exception of Pb,Cd,Hg)indicated during previous testing,that annual testing should not be required.Following the issuance of Air
Permit No.05896/T25,the facility now only tests for hydrogen chloride,cadmium,and mercury on a three-year cycle.The last three-
year test was conducted on April 10-11,2018,and the results of that test were approved by the DAQ-SSCB per the memo issued on
June 4,2018.The following table summarizes 2015CY&2018CY testing results.Testing was conducted to determine ongoing
compliance with these emission limits.
Affected IJmisson Emission Limit; 4/Z8 51112015
4/IU 111201$
Toxic Air Pollutant Vest ResultNo
s
ouce(s} (total for both) Test Results{total)
j
:........ (total) .::.....
..............................:....................................................................................................................._................................... .._............................................................_..............._...........................
Arsenic 2.673 lbs/yr 0.11654 lbs/yr Not tested
Incinerators
Beryllium ! 47.641bs/yr <0.0330 lbs/yr F Not tested ,
(ID Nos.ESO1 C ...............: ........................................- .... _ .............: _ .....:.: _ _ ........: ....... ....... ........ .. .. ................. .............
Chlorine 24.00 lbs/day; <0.0261 Ibs/day; Not tested
1.00 lbs/hr 0.00108 lbs/hr

Affected Emission Emission I,ymrt 4/28 5/1/2015 4/IA 11/2018
Tax�c Arr Pollutant Test Results
Sources) � . . (total far both) Test Results(total). �
(total)
............... ............. ......':.......
Chromium VI 0.964 lbs/yr 0.06701bs/yr Not tested
Hexachlorodibenzo-P-dioxin 0.8831 lbs/yr 5.62E-08 lbs/yr Not tested ,
E Tetrachlorodibenzo-P-dioxin , 0.0349 Ibs/yr F 4.10E-07 lbs/yr Not tested
.....:...........H....dro..�..en:..Chlori.......mm.......:_..... ..............................................___........................ .. ..........,.......:.._.........:........ .:.......
.....
Hydrogen de 2.21bs/hr 0.009111bs/hr 0.00261bs/hr
H dro en Fluoride 24.00 lbs/day; <0.02801bs/da ; Not tested
y g 1.00lbs/hr <0.001171bs/hr
Manganese 8.22 1bs/hr <0 00131 lbs/hr Not tested
.._.............................................................................._..................._......._..............................._...._._.................I..............._........................ ....................... ..........................__. _........................... ..................._.........._.........
<5.54E-04 lbs/da <5.81 E-04
Mercury 3.821bs/day y Ibs/day
... �_...........................................................................................................................................:............................._.........................................................................................................................
E
Nickel 1 12.00 Ibs/day 0.00300 Ibs/day Not tested
Conditions 2.1.A.2.a and b-This condition contains the emissions limits for both HMIWI units(ESO 1 and ES02)as stipulated by
Table I of 40 CFR Part 60, Subpart Ce.As described above,the facility conducted source testing on the units from April 10-11,
2018,and the results of that test were ultimately approved by the DAQ-SSCB per the memo issued on June 4,2018.Testing was
conducted to determine ongoing compliance with these emission limits.
µ 4f10 1V2p18 Test Results.
Pollutant Emxssian��mts*�*'"
(Averages).
ESOI F ESQ2
...._........_m_.._............ _......................................_............_.............: ...................._...._............,.....m........................_._......_.................._... .............._...................................................... ....._........._.......................................................... . .....
25 milligrams per dry standard cubic meter(mg/dscm)OR 8.78 m /dscm 9.21 m /dscm
Particulate matter 0.011 rains per d standard cubic foot r/dsc g g
gP_ dry (g
_.............................................................................................................................................................:..................................................................................
..................................................................
'Carbon monoxide 11 parts per million by volume(ppmv) Not tested(GEMS) Not tested
(CEMS)
9.3 nanograms per dry standard����cubic meter tot
al dioxins/furans
(ng/dscm)OR
Dioxins/furans 4.1 grains per billion dry standard cubic feet(gr/101 dscf) Not tested Not tested
OR
0.054 ng/dscm TEQ OR
0.024 gr/109 dscf TEQ
Hydrogen chloride 6.6 parts per million by volume(ppmv) 0.0354 ppmvd 0.0976 ppmvd
Sulfur dioxide _.F9.O�parts per million by volume(ppmv) Not tested Not tested
_...__.............
..................._._........_..........:......_.. _.............._............................. ..............................................._..................._.___.. ..._..... ................................. _.............................................................._...... ....... __............ ....... _........................_................. � ......................_....._.........................
Nitrogen dioxide 140 parts per million by volume(ppmv) Not tested Not tested
_.._._...._...._._,_....._._._______.._...__._..........................._..._.....w._..._,......._.......................... _............._....,........._............,.,............................._...._..... .s......._... _......................................................
0.036 milligrams per dry standard cubic meter(mg/dscm)OR 0.0275
Lead 0.0108 mg/dscm
0.016 grains per thousand dry standard cubic feet(gr/10 dscf) mg/dscm
Cadmium 0.0092 milligrams per dry standard cubic meter(mg/dscm)OR 0.00227 mg/dscm 0.000482
0.0040 grains per thousand dry standard cubic feet(gr/10 dscf) ( mg/dscm
0.018 milligrams per dry standard cubic meter(mg/dscm)OR <0.000994 <0.000973
Mercury 0.0079 grains per thousand dry standard cubic feet(gr/103 dscf) mg/dscm mg/dscm
Opacity F6%opacity(6-minute block average) 0% 0%
.._,,a-'_..................._......_.............................................................................................._...................................................................................-....._.....__.................................................. ...............................................................................
*Limits..b..ased on 7%oxygen(dry basis)
**Limits based on a three-run average with a minimum sample time of one hour per run,except for dioxins/furans which is based on a three-run average
with a minimum sample time of four hours per run
Conditions 2.1.A.2.d through g-These conditions state that the facility shall conduct an initial performance test in order to determine
compliance with the emission limits in Condition 2.1.A.2.a&b above,and to establish maximum and minimum values for the

following operating parameters for each control device,as applicable:maximum charge rate;maximum flue gas/carbon bed inlet
temperature;minimum secondary chamber temperature;minimum pressure drop across the venturi scrubbers,or minimum amperage
to wet scrubber;minimum venturi scrubber liquor flow rate;minimum packed bed scrubber liquor pH;and minimum SNCR reagent
flowrate.The facility may conduct repeat performance tests at any time in order to establish new operating parameters.Upon receipt
of an approved test that demonstrates different operating parameters,the facility shall attach the approval memo containing the revised
operating parameters to this permit and maintain the parameters in the associated ranges contained therein.The facility may conduct a
repeat performance test within 30 days of violation of applicable operating parameter(s)to demonstrate that the affected facility is not
in violation of the applicable emissions limit(s).Repeat performance tests conducted pursuant to this paragraph shall be conducted
using the identical operating parameters that indicated a violation.The facility was actively recording all appropriate process data
during the testing.That data will be provided at the end of this report.
Conditions 2.1.A.2.h through k-These conditions contain the requirements and frequency for emissions testing.The facility shall
conduct annual performance tests for the opacity limit and meet the requirements of 40 CFR 60.56c(b).For compliance with the PM
and HCl emissions limits,the facility shall start by testing annually.If three tests over a three-year period indicate compliance,then
the facility may test for PM and HCl once every three years(no more than 36 months from previous test).Annual tests shall be
resumed if a test results in non-compliance. For compliance with the mercury,cadmium,and lead emission limits,the facility shall test
once every three years(no more than 36 months from previous test).For each metals test,the facility shall track and record details for
the waste being burned and the material that may be carried over into the stack test period.Tracking shall include,at a minimum: a
cross-reference of the identity of the waste generator with the company's customer list(the identity information shall include the
nature of the business activity);the type of business waste;the total weight of each container;and the time the material entered the
incinerator.This information shall be summarized and submitted as part of the stack test report.The use of the bypass stack during a
performance test shall invalidate the performance test.As mentioned before,the facility is currently on a 3-year cycle(triennial)for
testing both units,except that opacity testing is annual.The most recent annual opacity testing for both units occurred on April 8,
2020.The results demonstrated compliance(0%opacity for both units)and were approved on May 12,2020.Visible emission
evaluations were conducted in conjunction with the Metals&HCl testing on both Aprils 6-7,2021.No visible emissions were noted
during the observation.This will be discussed in greater detail in the"testing"section of this report.Mr.Yarbrough confirmed that all
waste incinerated during the testing was tracked and will be included in the final test report.
Condition 2.1.A.2.n—This condition states that the facility shall ensure that all operating parameters remain within the acceptable
range as measured on a 3-hour rolling average,following the date on which the maximum and minimum operating parameters are
established.Operation outside of acceptable ranges shall constitute a violation of established operating parameter(s),except that
operating parameter limits do not apply during performance tests or during periods of startup and shutdown when no waste is being
charged.The facility has an electronic control system with interlocks that prevents charging of the units if the operating parameters are
not met.As mentioned above,the facility was actively recording all applicable parametric values during the course of the testing.
They will be provided at the end of this report.
FT
Opernting.Parameter ;
(based on 3 hour rolling ayg)
T2S 4/10 11/lg T25 '411U 11/18
Limit Source Test Limit Source Test
::...............................................:.......................................................................................................................::.................... ......................::......................:...........:....._........._....................:.......................................:::_............ .........................:..............«:.._..............
Max.charge rate(lbs/hr) 1,870.0 1,704.3 1,870.0 1,704.7
Min.pressure drop across venturi scrubber 39.0 44.2 38.9 42.4
(in.W.C.)
Min.secondary chamber temperature(°F) 1,762.8 1,951.2 1,759.5 �2,008.0
Min.venturi scrubber liquor flow rate(gpm) F65.2 F 73.9 F66.7 72.6
..................................................... .... .........
.... .......................-...........,.........._... .......................................... .....................«..................................9_...........«........«........«...................«..«,......«........«...............«..........
Min.packed bed scrubber liquor pH 4.10 4.6 , 4.10 4.5
«.........................._,...........,_....._._...._....,._...,.., ....,.............,......................«........._,_._......,........._.........«._,._.w _..... ...... ..._.......
Max.flue gas/carbon bed inlet temp. (°F) 168.1 � _«� «�153 5 � 164.1 153 1
Min. SNCR flow rate for urea(gph) 1.1 - � -
Min. SNCR flow rate for ammonia(gph) 1.0 . 1.2 1.0 1.2�

Protocol Submittal Form:
The WSRO-DAQ received the protocol submittal form(PSF)for the proposed triennial testing of both incinerators on February 12,
2021.The PSF was subsequently forwarded to SSCB on February 12,2021,and ultimately approved on March 30,2021.The
approved methods as provided in the protocol approval letter dated March 30,2021 (Gregg O'Neal,RE, Env.Engineer,SSCB)are
provided in the table below:
Incinerator ESO1 and ES02-Pollutants and Test Methods
Sources to Be Tested Target/Pollutant EPA Method Rum Time Notes
Oxygen and Carbon Dioxide 3A 3 runs,60-120 minutes Concurrent with
each 5/29 and 26A
ESO1 Filterable Particulate, 3 runs, 120 minutes
and Cadmium(Cd),Lead(Pb), 5/29 each
ES02 Mercury(Hg)
Visible Emissions 9 3 runs,60 minutes each
Hydrogen Chloride(HCI) I 26A 13 runs,60 minutes each
The tester must verify the absence of cyclonic flow as described in Section 11.4 of EPA Method 1.
It should be noted that there was language in the PSF approval letter requiring TRC Environmental Solutions to perform a pre-test
analysis of the filter blanks used in the Method 29 metals trains as described in section 7.2.1.This blank analysis was to be performed
and submitted to the DAQ prior to the testing. Following discussion with Mr.Derek Brewster,Project Manager,of TRC
Environmental Solutions,this was not completed prior to the testing,and the language was from previous testing events.Prior to TRC
taking over the testing at Stericycle,the facility historically had high hits(greater than maximum method correction)on their Method
29 filter/reagent blanks during the initial testing.According to Mr.Brewster and previous report review, it appears blanks have not
been;an issue during the previous testing.Method 29(filter and reagent)and Method 26A(reagent)blanks will be provided with the
final.test report as required by the methods.The PSF indicated a test period charge rate of 1,710 lbs/hour for both units.
Testing Discussion:
As mentioned above, TRC Environmental Solutions completed the required testing. Testing was completed over the course of two
days: April 6, 2021 for ESO1, and April 7, 2021 for ES02. Two-hour Metals (Method 29) runs were completed with one-hour HCL
runs beginning 30 mins after the beginning of the metals and finishing 30 mins prior to the completion of the metals(This is arranged
such that the probes can be port-changed at the same time, and points can be traversed such that there is no interference). It should be
noted that Method 29 requires longer sample times and larger sample volumes to drive down the detection limits for the method in
respect to the applicable emission limits. Method 3A for 02/CO2 was also performed during the runs for pollutant concentration
corrections, as well as molecular weight determination. Three (1)-hour runs of EPA Method 9 for visible emissions was also
performed.Detailed descriptions of the Methods are provided below:
• Method 26A-EPA Method 26A for halogens and halides was performed for Hydrogen Chloride. Method 26A utilizes acidified
impinger solutions(0.1 N H2SO4)and basic impinger solutions(0.1 N NaOH)to capture the halides(Cl"**,F­,or Br)and halogens
(Cl2 and Br),respectively.Halogens(Cl2 and Br2)have a low solubility in an acidified solution and hence tend to not be captured
to a large extent in the first set of impingers containing 0.1 N H2SO4,whereas they are captured effectively in the 0.1 N NaOH
solution. Meanwhile,the halides(HC1,HF,and HBr)are effectively captured in the 0.1 N H2SO4 and hence removed before they
can get to the NaOH solution.Analysis is accomplished in both sets of solutions by ion chromatography.During the test runs,the
Method 26A probe and filter temperatures were maintained greater than 248°F and less than 273°F,as required by the method.
No moisture was observed accumulated in the filter bells during the runs,as this is known to cause negative bias in
Halogen/Halide results. In the event of moisture condensation in the filter bell,the post-test purge in section 8.16 of the method
should be followed.Following the post-run leak checks,the back-half filter bells,and impingers were then rinsed with DI water,
and appropriate samples then transferred to PE(polyethylene)bottles where they are subsequently shipped to the lab for
halogen/halide analysis.Reagent blanks were also prepared for analysis(DI Rinse Water,0.1N H2SO4)
o April 6,2021 (ESO1)Run 1: 09:40-10:56 Run 2: 12:40-13:45 Run 3: 15:25-16:30
o April 7,2021 (ES02)Run 1: 08:50-09:54 Run 2: 11:35-12:41 Run 3-14:00-15:05

• Method 29-The facility completed three 120-minute Method 29 Runs on both units.Using this method,stack gas is withdrawn
isokinetically from the source,with particulate emissions collected in the probe and on a heated filter,and gaseous emissions
collected in an aqueous acidic solution of hydrogen peroxide(analyzed for all metals including Hg)and an aqueous acidic
solution of potassium permanganate(analyzed only for Hg).The recovered samples are digested,and appropriate fractions are
analyzed for Hg by cold vapor atomic absorption spectroscopy(CVAAS)and for Sb,As,Ba,Be,Cd,Cr,Co,Cu,Pb,Mn,Ni,P,
Se,Ag,Tl,and Zn by inductively coupled argon plasma emission spectroscopy(ICAP)or atomic absorption spectroscopy(AAS).
The Method 29 Metals trains used during the testing consisted of the following:Glass Nozzle,Quartz-fiber Pallflex filter
(pretared,desiccated and dried under ambient conditions since PM was determined on front half),Impingers 2-3 were charged
with 100 mL of 5%HNO3/10%H202 acidified nitric acid/hydrogen peroxide solution,with the first impinger being an empty
(knockout)impinger which is generally used in sources with high moisture catches(100 mL to prevent possible overflow into the
KMnO4 impingers),and impinger 4 also being empty,followed by impingers 5-6 which were charged with 100 mL each of 4%
KMnO4/10%H2SO4 acidified Potassium Permanganate/Sulfuric Acid,followed by the final silica gel impingers.During the
testing,probe and filter temperatures were maintained at the required 248+25 degrees Fahrenheit per the method.All post run
leak checks were well within the method allowance of 0.02 CFM.Following the post run leak check,the filter bell was removed,
and the probe was rinsed and brushed in triplicate with acetone(PM/Metals Filter—Sample 1,Nozzle,Probe&FH Filter holder
acetone rinse-Sample 2),followed by a rinse in triplicate with 0.1 N HNO3(100 mL total)to recover any residual metals stuck in
the probe liner and filter bells(Sample 3).It should be noted that if PM is being performed,the Sample 2 acetone analysis has to
be done at ambient conditions with no added heat,with the rinse being reconstituted back into Sample 3 for metals analysis
following the PM analysis.All moisture in the back-half filter bell/impingers 1-3 were then recovered,measured,and the
glassware subsequently rinsed with 100 mL HNO3(100 mL total)for Sample fraction No.4.The empty impinger No.4 was also
rinsed in triplicate with 0.1 N HNO3 and for Sample Fraction No. 5A.Impingers 5-6 were then measured,and rinsed in triplicate
with 100 ml of KMnO4,followed by 100 mL of DI water,with those contents then combined in Sample Fraction No 5B.Finally,
any visible precipitated deposits remaining after the KMn04/H20 rinses were then subjected to a rinse with 25 mL of 8N HCl and
added to the final sample fraction 5C(diluted to 200ml with DI water). The silica gel impinger was finally weighed for moisture
determination.All samples were sealed in Glass/PE bottles,and prepared for transport to the lab.Reagent and filter blanks will
also be submitted for analysis as required by the method.
• April 6,2021 (ESO1)Run 1: 09:10-11:26 Run 2: 12:10-14:15 Run 3: 14:55-17:00
• April 7,2021 (ES02)Run 1: 08:20-10:24 Run 2: 11:05-13:11 Run 3- 13:30-15:35
• Method 3A-The facility also performed Method 3A via CEMS to determine molecular weight as well as Oxygen concentration
for effluent corrections.All calibration gases were observed,and verified as EPA protocol gases,and were well within their
expiration dates. Sampling was performed by pulling stack gas through a stainless-steel probe,through a heated sample line,
through a conditioner(chiller),and finally split to the necessary monitors.All direct calibrations(2%of span),bias(5%of span),
and drift(3%)were well within method allowances.CEMS were measured at a single point,as the stack was considered
unstratified,per the WE stratification check.Preliminary results are provided below:
April 6,2021
Run 1 Run 2 Run 3
Pollutant Average
09:10-11:10 12:10-14:1Q 1455-1' :00
02% 11.22 10.30 9.94 10.48
CO2% 7.62 8.46 8.67 8.25
April 7,2021
Run 1 Run 2 Run 3
Pollutant Average .
08:20 1020 11:05-13.05 3:
0-15:30 _
11.06 11.81 11.77 11.54
CON( 7.58 7.33 7.18 7.36

Process Data:
ES01
Operating Parameter
ESQ2
(hosed hn 3 hour rolling a�g) _
T25MOT
4/1011I18 4l6/21 T25 /1011/18 417I21
limit Source Test limit Source T. !
Max. charge rate lbs/hr 1,870.0 1 704.3 1713.0 1 870.0 1 704.7 1711.7
Min.pressure drop across venturi
scrubber 39.0 44.2 38.9 42.4 42.1
(in.W.C.) 45.0
m.m._..:..._....:_ _. ....:. _.............................................._..........
...__....................
Min. secon 1,762.8 1,951.2 1974.2 1,759.5 2,008.0 2010.4
temperature(OF)
dary chamber
... ... ...�......V....__....�...._.�._......._.,...V.._._._...._w_.___.....�....�. _W�.�...____�....,.__�..V �..._ww....W�.._...V...�.�,. _W._.�.�._.�.........�..�._._..._._.w_..,W.�...._.�... _._.�.....__V...._..._..r......ww...�.. ._.___....WW.�,..�.�..�..W..
Min.venturi scrubber liquor flow 65.2 73.9 66.7 72.6 71.1
rate(gpm) _ _ 70.8
Min. acked bed scrubber li uor H 4.10 4.6 5.4 4.10 4.5 5 5 1
Max.flue gas/carbon bed inlet temp. 168.1 w 153.5 150.6 164.1 153.1 156.3
(
oF) 4
Min. SNCR flow rate for ammonia 1.0 1.2 1.1 1.0 3 1.2 1.1
h3
. .(gP ) ................._........... . :..__...:.:......_...........................:..........................................................:_.....: ........:.....:......................._...
The process data above is preliminary and may be subject to slight adjustments,as Mr. Gray was required to import the run data from
a word document to excel to calculate averages.It appears all control devices were operated within the acceptable ranges as described
i1fPermit Condition 2.1.A.2.n.
Conclusion:
No deviations from the approved protocol were noted by the observer during the course of the testing.The final test report will be due
tothe WSRO-DAQ by May 7,2021.A final compliance determination will be ultimately made by Stationary Source Compliance
Branch(SSCB)following review of the final test report.