AQ_F_0800044_20190821_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Washington Regional Office
AIR QUALITY Avoca LLC
NC Facility ID 0800044
Stack Test Observation Report Coanty/FIPS:Bertie/015
Date: 08/30/2019
Facility Data Compliance Data
Avoca LLC Observation Date 08/21/2019
841 Avoca Farm Road Observer's Name Betsy Huddleston
Merry Hill,NC 27957 Operating Status Operating
Lat: 36d 0.0030m Long: 76d 42.6550m Action Code 23/STACK TEST
SIC: 2087/Flavoring Extracts And Syrups,nec OBSERVED
NAICS: 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: Comments: See notes concerning issue discussed below with
H101 Run 1 post leak check.
Date of Signature: 8/30/2019
Avoca contracted McHale Environmental(Mike Dickerson)to conduct the following performance tests on No.2
fuel oil-fired boilers H-101 and 1-1-102(20.3 MMBtu/hr max.heat input)to comply with the Boiler MACT(Subpart
DDDDD):
Volumetric Flow, Molecular Weight, and Moisture Methods 1-4
Filterable Particulate Method 5
Carbon Monoxide Method 10
Mercury Method 30B
Hydrochloric Acid Method 26A
Avoca opted to perform one-time tests rather than monthly fuel sampling to demonstrate compliance with the
emission limits for these boilers. The emission limits are provided in permit condition 2.I.A.5. as follows:"
HCI 1.1E-03 pounds per million Btu of heat input
Mercury 2.0E-06 pounds per million Btu heat input
CO 130 ppm by volume on a dry basis corrected to 3 percent
oxygen
Filterable PM 7.9E-03 lb per million BTU heat input;or(6.2E-05 lb per
or TSM million BTU heat input)
Pursuant to §63.7515(h), because these oil-fired boilers burn ultra-low sulfur fuel,Avoca is not required to conduct
further performance tests if the pollutants measured during the initial compliance performance tests meet the above
emission limits,provided that Avoca monitors type and volume of fuel combusted on a monthly basis.
Avoca submitted a protocol on 3/21/2019, and DAQ approved the protocol by letter on 5/02/2019. Avoca provided
notification to the regional office of the test dates on 7/25/2019,within the required 15 days of the test dates.
The boilers are identical with stacks of the same diameter. 12 points were tested to complete Methods 5 and 26A.
McHale chose to do two measurements per point (6-minutes between measurements). Mike showed me the audit
sample for Method 26A(it was ordered before the last audit contractor terminated with EPA).

H-102 Testing on 8/20/2019
I arrived on-site just before the end of Run 1 of M5 and M26A. Run 1 of M30B had already finished, as it was one
hour in length compared to two hours for M5/M26A.
The sampling port is a bit lower than they had planned due to some physical obstruction. I don't think this is a
problem as the stack is completely vertical.
I looked at the control panel for the boiler. Steam pressure was 150 psi and the stack temperature was 436°F. Steam
data will have to be used to back calculate the boiler operating rate for submittal with the report. Brian Conner
assured me that the boilers were operating at maximum heat input.
Methods 5 and 26A Observations
Box Data:
AH- 1.89
Y—1.023
Calibration date:4/18/2019
Ran 1 Data(I reviewed the data sheet and noted ranges of data recorded):
Start time 8:57 AM,port change 10:27 AM
Nozzle diameter 0.4971 (all three runs)
Initial leak check 0.001 cfm @ 24"Hg
K factor 36.2
Barometric pressure 30.09 mm Hg(for all three runs)
DGM start 766.001 cf
Impinger temperature ranged from 51-677 during the run
The highest vacuum was 17.5"Hg
Probe temperature 241-2507
Filter box temperature 253-2577
DGM temperature 90-111°F
Ap 0.05-0.11
Stack temperature 350-4287
Final DGM 871.2 cf
I observed the Run 1 post-leak check. The box operator is a new McHale employee, and was in training during
these tests. He did not wait a full minute during the leak check or remember to record the vacuum. However, I
observed the vacuum at about 19 inches, and after about twenty seconds the gas meter had recorded about 0.002 cf.
Run 2 Data
The sample train was correct and the desiccant looked new.
Start time 12:18 PM,port change 1:32 PM
I observed the pre-leak check at 0.005 cfm @ 24"Hg
The pitot check was good.
DGM start 871.833 cf
Impinger temperature ranged from 52-63OF during the run
The highest vacuum was 13"Hg
Probe temperature 248-267OF
Filter box temperature 250-260OF
DGM temperature 107-115OF
AH 2.172-3.982
Ap 0.06-0.08
Stack temperature 355-4307
I observed the post leak check(done correctly)at 0.0 cfm @ 15"Hg
Method 30B Observations
Mike had installed calibrated digital flowmeters to more accurately record and control flow for this test. They did
install condensers in the sample lines. Side 2 was the spike sample. The spikes are 15 ng concentration.
Side 1 Y—0.9984, calibration date 9/9/2018 (0.2%deviation)
(SharePointTacilities\Bertie08\00044\Stack Testing\20190821 H101 and H102 stk.doc) Page 2

Side 2 Y— 1.0241, calibration date 9/9/2018(2.4%deviation)
The method was sampled across 6 points in the stack with two readings per point(a reading every 5 minutes).
The sample rate was targeted at 1 liter/minute.
I was not present during Runl,but I looked at the data sheet. The sample lines pulled 56 liters and 58 liters during
Run 1.
I observed the pre-leak check for Run 2. Both sides were 0.0 liter/minute @ 25"Hg. The run started at 12:18 PM.
During Run 2 the following ranges were observed:
Probe Tern OF Vacuum inches Hg Meter Temp°F
Side 1 262-329 2.2-4.9 83-102
Side 2 248-329 3.5-6.0 85-99
Side 1 sampled 58.7 liters during Run 2. Side 2 sampled 61.14 liters during Run 2. I observed the post leak check.
Both Side 1 and Side 2 were 0.0 cfin @ 25"Hg.
Method 10 Observations
Calibration Gases
02 CO2 CO
Mid gas value/exp date 1 10.10%/7/16/2027 9/82%/7/16/2027 45 ppm/5/14/2021
High gas value/exp date 19.82%/7/22/2027 19.95%/7/22/2017 101 m/ 10/10/2026
The initial calibration was conducted using three CO gases at 45 ppm, 101 ppm and 501 ppm (exp. 10/31/2026).
Once the test got underway, it became quickly apparent that the CO emissions from the boiler was very low (less
than 1 ppm).Therefore,they used the 45 ppm cylinder for bias checks.
There was a condenser in the gas sample line.
I was no present to observe Run 1 but I retrieved the results from their computer:
Average raw Adjusted
CO 0.73 ppm 0.8 ppm
02 4.9% 5.0%
CO2 11.9% 11.9%
The bias data for pre and post Run I looked good.
I did observe the Run 2 post-bias check. Zero readings were good. The upper gas readings were 10.1%02, 9.75%
CO2,and 44.75 ppm CO.
Run 2 results were
Average raw
CO 0.90 ppm
02 4.43%
CO2 12.27%
H-101 Testing on 8/21/2019
1 arrived on-site just before the end of Run 1 of M5 and M26A. The same box was used. Run I of M30B had
already finished.
I looked at the control panel for the boiler. Steam pressure was 150 psi and the stack temperature was 398°F. Steam
data will have to be used to back calculate the boiler operating rate for submittal with the report. Brian Conner
assured me that the boilers were operating at maximum heat input.
Methods 5 and 26A Observations
Run 1 Data(I reviewed the data sheet and noted ranges of data recorded):
Nozzle diameter 0.4971 (all three runs)
(SharePoint\Facilities\Bertie08\00044\Stack Testing\20190821 H101 and H102 stk.doc) Page 3

Initial leak check 0.001 cfm @ 24"Hg
DGM start 10 1.192 cf
Impinger temperature ranged from 51-61°F during the run
The highest vacuum was 7.5"Hg
Probe temperature 243-247°F
Filter box temperature 251-259°F
DGM temperature 90-111°F
AH 1.348-2.353
Ap 0.05-0.06
Stack temperature 350-428°F
Following the run, the tester on the stack accidentally kicked the impinger box,and then the post leak check
failed. When he righted the box and adjusted the impingers, they passed with 0.0 cfm @15". Rather than
re-doing the run, Mike suggested if the moisture content comes out the same as Run 2 and the moisture
measured for H-102 the previous day, the run can be accepted without the past leak check. The impinger
train had already been disassembled for volume measurement before I had Mike contact Gary Saunders
directly about this approach. The two of them worked out an agreement.
A photo of the impinger volume data for Run 1 is attached to the file copy of this report. A photo of the volumes
for H-102 testing the day before is also attached.
I observed the Run 2 pre-leak check at the impingers 0.0 cfin @ 14" Hg. They then conducted a full train leak
check of 0.0 c&n @ 14"Hg.
Run 2 Data
I watched part of the first half of this run and all of the second half. I observed the following ranges during the
second half:
Impinger temperature ranged from 52-67°F during the run
The highest vacuum was 15"Hg
Probe temperature 255-257°F
Filter box temperature 257-264°F
DGM temperature 101-107°F
AH 1.96—2.40
Ap 0.05-0.06
Stack temperature approx.379°F at end of run
I observed the post leak check of 0.001 cfm @ 15"Hg.
Method 30B Observations
They used the same equipment as for H-102 testing.
The sample rate was targeted at 1 liter/minute. I was not present during Runl, but I looked at the data sheet. The
pre-leak check for both sides for Run I was 0.0 I/min @ 25" Hg. The sample lines pulled 59.26 liters and 58.8
liters during Run 1.
RUN 1 Probe Temp°F Vacuum inches Hg Meter Temp°F
Side 1 261-291 3.5-5.2 75-80
Side 2 267-291 2.9-5.2 78-81
1 observed the pre-leak check for Run 2. Both sides were 0.0 liter/minute @ 25"Hg. The run had to be interrupted
for a port change for M5/26A. Another leak check was completed before resuming(dead stop at 15"Hg). During
Run 2 the following ranges were observed:
Side 1 sampled 59.647 liters during Run 2. Side 2 sampled 59.802 liters during Run 2. 1 observed the post leak
check. Both Side 1 and Side 2 were 0.0 cfrn @ 25"Hg.
Method 10 Observations
(SharePoint\Facilities\Bertie08\00044\Stack Testing\20190821 H101 andH102 stk.doc) Page 4

The same equipment was used for this test as on 8/20/2019. The initial calibration was conducted using three CO
gases 45 ppm, 101 ppm and 501 ppm(exp. 10/31/2026).
I was not present to observe Run 1 but I retrieved the results from their computer:
Average raw
CO 0.90 ppm
02 4.43%
COz 12.27%
Run I ended at about 10:30 AM. The calibration, and bias data for pre and post Run 1 looked good. The post run
bias was done immediately after the run ended. Zero readings were good. The upper gas readings were 10.05%Oz,
9.95%CO2, and 44.75 ppm CO.
Run 2 started 11:47 AM and ended 1:01 PM.
Run 2 results were
Average raw
CO 0.21 ppm
Oz 5.41%
COZ 11.53
(SharePoint\Facilities\Bertie08\00044\Stack Testing\20190821 H101 and H102 stk.doc) Page 5

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Huddleston, Betsy j
From: Brian Conner <[e-mail]>
Sent: Thursday, July 25, 2019 12:04 PM
To: Huddleston, Betsy
Cc: Dale Overcash; Dana Norvell
Subject: [External] RE: Boiler MACT 5D Testing
a
Betsy,
Avoca plans to test the 2 No. 2 fuel Oil Boilers on August 20-21, 2019.This email is being sent within the required 15 day
notice to NCDAQ. Are those dates good for you, and do you need a formal letter with the testing date intent or is this
email sufficient?
Thanks,
Brian Conner
From: Huddleston, Betsy<[e-mail]>
Sent: Wednesday,June 19, 2019 3:18 PM
To: Brian Conner<[e-mail]>
Subject: Boiler MACT 5D Testing
—This is an external email message.Confirm the sender before opening attachments or clicking links.Avoid content that looks suspicious.*"'
Hey Brian,
Just checking in with you on plans for Boiler MACT testing. The protocol had noted testing being completed sometime in
May or June.
i
Betsy Huddleston.
Envuromwentral Enginur
Divi mof Air QualitV,Wasiu >cn Regional Office
252.449-3836(office) 94311raslzingtam Square Mall
252.97:5.3716(:ax) Wadilihngtort,NC 27889
[e-mail]
This e-mail contains information which may be privileged,confidential,proprietary,trade secret and/or otherwise legally protected.It is not intended for
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I
This e-mail contains information which may be privileged,confidential,proprietary,trade secret and/or otherwise legally protected.It is not intended for W®w<,..m....
transmission to,or receipt by,any unauthorized persons.If you are not the intended recipient,please do not distribute this e-mail.Instead,please delete this e-mail
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ROY COOPER NORTH CAROLINA
Governor Environmental Quattly
MICHAEL S.REGAN
Secretary
MICHAELABRACZINSKAS f
D/rector
May 2,2019 -
Dr.David M.Peele,Ph.D.
President
Avoca LLC
P.O.Box 129
Merry Hill,NC 27957-0129
Subject: Avoca LLC
Merry Hill,Bertie County,North Carolina
Facility ID 0800044,Air Permit No.01819T52
Protocol for Particulate Matter(PM),Hydrogen Chloride(10),Carbon Monoxide(CO),and
Mercury(Hg)Emissions Testing of No.2 Fuel Oil-Boilers H-101 and H-102 j
Proposed Test Date: May 20, 2019,To Be Performed by McHale Environmental
Tracking No.2019-092ST
Dear Mr. Peeler
The protocol submittal for emissions testing boilers H-101 and H-102 has been reviewed and is acceptable.
Testing will be performed as required by permit condition 2.1.A(5)to demonstrate compliance with
40 CFR 63 Subpart DDDDD National Emission Standards for Hazardous Air Pollutants forMajor Sources:
Industrial, Commercial, and Institutional Boilers and Process Heaters and for emissions inventory.
15A NCAC 02D.1109 CAA§ 1120) Case-by-Case MACT for Boilers&Process Heaters emission limits as
defined in permit condition 2.1.A(4)apply through May 19,2019.
The emissions sources are to be tested are: 4
• Boiler(ID No.H-101)is a No.2 fuel oil-fired boiler(20.3 million Btu per hour maximum heat input rate,and
• Boiler(ID No.H-102)is a No.2 fuel oil-fired boiler(20.3 million Btu per hour maximum heat input rate.
Testing will be performed firing ultra low sulfur No. 2 fuel oil in accordance with permit condition
2.1.A(5)(g). Provided the subject test results meet the emissions limits the facility intends follow the
requirements of 40 CFR 63.7515(h)to demonstrate'ongoing emissions compliance and avoid further
performance tests. 40 CFR 63.7515(h)requires the facility to record the type of fuel combusted on a monthly
basis for ongoing compliance.
The proposed test process rate for boilers H-101 and H-102 of approximately 18 MMBtu/hr each. The
following table addresses the parameters/pollutants,test methods,run time, and minimum sample collection
volumes with applicable regulations and limitations for each boiler. Note a minimum of 3-test rums per boiler
are to be performed.
F
IIEI E D
R
MAY - 6 2419
D
AQ wARO
North Carolina Department of Environmental Quality 1 Division of Air Quality
217 West Jones Street 11641 Mail Service Center I Raleigh,North Carolina 27699-1641
919.707.8400

Dr.David M.Peele,Ph.D.,President
May 2,2019
Page 2(Avoca LLC -Boilers H-101 and H-102,40 CFR 63 Subpart DDDDD MACT Testing)
Table 1:Testin Methods and Limits for each Boiler Tested
EPA
Parameters/Pollutants Method: Run Time Emission Limit Regulation
Volumetric Flow Rate 1 2,3A, 3 runs Concurrent
Molecular Weight Moisture Content and 4 with Methods 5,26A,30B
3 runs,>:60 minutes each
Filterable PM 5 (minimum 3 dscm/run) 7.9E-031b/MNIBtu of heat input Standard starling MAY _
40 CFR 63 Subpart DDDDD
CO 10 3 runs,60 minutes each 130 ppmvd Q 3%02 Permit Section 2.1 A(5)(e)
Hg 30B 3 runs,minimum sample as 2 0 -06 lb/M v1Btu of heat input Standard through Mav 19,2019
specified in the method 15A NCAC 02D.1109
[CAA§1126)]
Permit Section 2.1 A
3 runs,>_60 minutes each
HCI 26A (minimum 2 dscm/run) 1.1E 031b/NIIvIBtu of heat input Standard starling Mav 20,2019
40 CFR 63 Subpart DDDDD
Permit Section 2.1 A(5)(e)
Note an audit samples analysis is required for EPA Method 26A. McHale Environmental has submitted an
audit sample order request. The sample must be present for inspection on request during the test period. For
additional information please see EPA web page https•//www.,pa.gov/emc/emc-technical-support.
No deviations from the applicable testing methodology were requested in the test protocol. Testing should be
conducted in strict accordance with the requirements of EPA Methods 1,2, 3A,4,5, 10,26,and 30B. The
proposed test methods are acceptable for the specified pollutants. Approval of the protocol does not exempt
the tester from the minimum requirements of the applicable methods.
The final test report should include information to establish that the testing performed was near maximum
normal or approximately>90%of maximum normal. The applicable test period monitoring parameters
should also be included.
If there are questions concerning this matter,please contact me at(919)707-8415 or
g_reie.onealAmcdenn gov.
Sincerely,
r
71OXA
Thomas G. ONeal,III,P.E., Environmental Engineer
Division of Air Quality,NCDEQ
cc: Brian Conner,Avoca LLC-Merry Hill,NC
Michael Dickerson,McHale Environmental-Durham,NC
Robert Fisher,Washington Regional Office
Central Files,Bertie County
IBEAM Documents-0800044
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0101f 09,:71517 u l Z
Avoca,LLC
Avoca' LLC 841 Avoca Farm
Far m Rd m Rd
e
Merry Hill,NC 27957
The World's Premier Botanical Extraction Company Phone:252-482-
2133 P Y Fax:[phone]
March 15, 2019
Mr. Robert Fisher _
Regional Supervisor
North Carolina Division of Air Quality
Washington Regional Office
943 Washington Square Mall
Washington, NC 27889
Re: Test Protocol Submittal
No. 2 Oil Fired Boilers
Avoca, Inc.
Merry Hill, NC
Permit No. 01819TS1
Dear Mr. Fisher:
Avoca Inc., (Avoca) owns and operates two existing No. 2 oil-fired (ultra low sulfur diesel or
ULSD) boilers (20.3 million BTU per hour, each) at our facility that are subject to the Boiler
NESHAP (or Boiler MALT) 40 CFR Part 63 Subpart DDDDD. The boilers are currently
operating under a 112(j) requirement as listed in Permit Condition No. 2.1-A.4. of the current
permit. The 112(j) requirement will expire on May 19, 2019.
On May 20, 2019, the boilers will become subject to the Boiler MACT requirements of 40 CFR
Part 63, Subpart DDDDD. The Boiler MACT requirements are listed within Permit Condition `
No. 2.1-A.5. of the current permit.
i
In accordance with Subpart DDDDD, the boilers must be tested within 180 days of the May 20,
2019 compliance date. Testing is required for PM, Hg, HCl, and CO. Avoca proposes to
conduct stack testing for the above pollutants and does not propose to conduct any fuel
sampling.
This protocol, or test plan as referenced within Subpart DDDDD, is being submitted 60 days
prior to any proposed testing. As part of this test plan submittal, Avoca proposes to
demonstrate ongoing compliance with the Subpart DDDDD requirements for the boilers by
utilizing §63.7515(h), as outlined below:
"(h) If your affected boiler or,process heater is in the unit designed to burn light liquid
subcategory and you combust ultra-low sulfur liquid fuel, you do not need.
further performance tests (stack tests or fuel analyses) if t ol�ta�psie�s e D
during the initial compliance performance tests meet the e '^ i�an Itlhits in Tables 1 1D
or 2 of this subpart providing you demonstrate ongoing co iI I`(pnce with th� ��ryf1'tpp
emissions limits by monitoring and recording the type of fu cbb'mb*2d 9n a Othl
basis. If you intend to use a fuel other than ultra-low sulfur iquid fuel, natural gas,
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refinery gas, or other gas 1 fuel, you must conduct new performance tests within 60
days of burning the new fuel type."
Based on the above requirements, if the boiler is tested in compliance with the emission
limits in the permit and Subpart DDDDD, ongoing compliance with the limits will be
documented by monitoring and recording the type of fuel combusted on a monthly basis.
Considering the above requirements, Avoca does not propose to install an oxygen analyzer _
and does not propose to set boiler load limits during this testing, as we have concluded such
is not required as a result of following the §63.7515(h) requirements.
Per Permit Condition 2.1-A.5, Subparts A and DDDDD of Part 63, and 2D .2600,Avoca is
submitting with this letter a test protocol form. Avoca is not submitting a full test plan as
outlined in Subpart DDDDD since we are proposing to conduct stick testing and propose to
follow the §63.7515(h) requirements as outlined previously.
In accordance with §63.7545(e),Avoca will submit a Notice of Compliance Status with all test
results within 60 days of completion of onsite testing.
Avoca is proposing to test the boilers sometime in late May or June. In accordance with 15A j
NCAC 2D .2602(d), Avoca will provide your office at least a 15 day notice prior to the test
date.
If you have any questions regarding the attached protocol, please feel free to contact Mr.
Brian Conner at (252)-482-2133, Ext. 287, or Mr. Mike Dickerson at [phone].
Sincerel ,
David M. Peele, PhD.
President
Avoca, Inc.
cc: Mr. Brian Conner,Avoca
Mr. Mike Dickerson, McHale EMS
Mr, Dale Overcash, Trinity Consultants
Enclosures:
DAQ Protocol Form r
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PROTOCOL SUBMITTAL FORM (Rev,2016)
�1(lli}:dh!'1lfh
DIVISION OF AiR QUALITY PAGE it OF 2
Purpose: The goals of the Protocol Submittal Perm are to initiate communication between representatives of the pomtitted facility,
the testing consultant,and the DAQ as well as to identify and resolve any specific testing concerns prior to testing.
Instructions: Use Guidance Document to fill out this form Submit all forms and additional information to the DAD R o onai.
Supervisor at least 45 de vs prior to Iestin . Complete one form for each sampling location. If this form does not supply
sufficient space to completely answer all questions or if additional relevant information is necessary,attach additional
documentation and/or information to the original form. Questions and/or comments should be directed to the appropriate
Regional Supervisor.
Thlt form and its Guidance Document are available at da5t .ev/ahmt�d)kitrt,/air-ottaiity/nir_ggnty-
10A ttg7 till/el Isti on-meaguremunt —
Specify Appropriate Regional Office:(check one)
0 Asheville ❑Fayetteville ❑Mooresville ❑Raleigh RWashington ❑Wilmington ❑Winston-Salem
Facility 10 No: A Test Company Name,
Facility Name: ft V06.4 LLC.
AYIa Al.fF C-AAs -
Facility ConractParson/mailing address&email: Testing Company Contact Person/mailing address&email!
-3al } ) C onel M 11r6 71t 1c¢r� se rt
4vo&A 4,LC M��fq�� C-M5
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Merry 1Frtf , N,S z79s7
Email.Addresv: ,l��(y '" Gi.Sb.FWn12? . GW11 Email Address:A41 K C. DIe-IeCf. 9c.'�1Ifr/�ALti. I
Phone:Z52 Lten-z133 Fax; Phone: G5 5578- 4
Mobile No.: 25 Z c{�j 2 - f(o z Z- Mobile No.:'714 703- 3 S,S L S
Air P Number&Revision: Permitted Source Name as ID No.:
Ot " TS t 1- 101 H laZ r�o. Z r71L_fr�c� 3011
Permitted Maximum Process Rate: Eximum Normal Operation Prooesa Rate: Target Process Rate for Testing:
20 . 3 YA/K-7l TN/1-1-t'� b , 3 MM 137-u
1.1)What is the specific purpose for the proposed tearing? (Permit condition,NSPS,NESHAP etc.-See guidance doc.1
Tb l�rNer»ST✓ATC Go'+rP i r an c¢ t417-14 1,44LT, c10 CF/�i3 5tJ Her Dr7DZ>D 45
1s this an initial rformance test? Yes or ❑Nn STA 3FDD 0-1 e�'.✓ntr r 15A 4C4C OUZ .OTIS-'t F)
1.2)List all state and federal regulations that apply to the proposed testing.(See guidance doc.) j5
3 NCAG DMA •f loll
C-"E 13Y CASE r l4GT� M4GT � S 7�PODD ATATCD tN &3.7s'oo TRblt2.
1.3)Will the test results be used for other regulatory purposes(e.g.emission inventories,permit_gplication,etc.)beyond that stated above?
Yes of 0No I£Yes,explain Ggl55ta-»S rAVEhTOR.y 1 uruit, ivtlrs �arGmo�lr
1.4)How will productionfprocess&control device data be documented during testing?(list specific control MuipWMu _proc g parameters,
it -trwncntationthatwill be used ftquenc ryofdata collection cannot byg�).lpute.r/msnuully etr.) 'rest Von not be accepted
pAthout ap r�opriate production/process&control device operation data. "4 Fe Wr!1 4 Sue 7:)4 r4 L
r D�f9t 11���1 'jfigpnnel uttrl 7ocu'116,17- 801ter of �ar1.1� t�rtnlr/wry sLICA fs,
Fuef FLowr s q,n cx,rp-1T i4e-4,r L.044,-)
1.5)Provide a brief description of the source(including control equipment)and At�11ch source or process flow diagram from source through
stack exit. 1�iLF!' eW-�i4LATE'7� T6 ATmos:phe e— -Zrpi-94- '574 1C . 600-1) [.ptvy�VSTlar)
rrrinsAey 1p_4n� or C 77rro)
1.6)Provide brief description of the sampling,location,.Attach schematic of sampling:location,and indicate whether concurrent testing will
be conducted at other sampling locations.(Approval of protocol without this data will not exempt you from Method criteria.)
At& -'AM1P1/iJ6 44 - IC COG47`tiv>i ( -SCTF SuavtF �216�'1 e lFST�
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PROTOCOL SUBMITTAL FORM Rev.2016
""w'�`'' DIVISION OF AIR UALl'PY PAGE 2 of 2
2.1)Provide the following information for each test parameter.
Target Proposed Number of Test Run #of Sampling
Pollutant Test Method Test Runs Duration Points Comments
t°tvl l4DfS(W f-t Z 3 76 P Ce>046U err LA ITN
®z 34 3 18 D "D C01100 ipulewc, 4li auas
ISM 3 3 T-8D 7'pD MrurMtrM 3 BscMljwN
Hp- Zb�l 3 T�lD i�17 MhrrnttlM 2 r3scM/�N
L-� 3o fb 3 i I31� �D
2.2) Will all testing be conducted In strict accordance with the applicable test methods? If"No",attach complete
documentation of all proposed modifications and/or deviations to the applicable test methods. ®Yes El No
2.3) Does the proposed sampling location Cmeet the cminimum EPA Method I criteria for acceptable measurement sites?
Attach supporting documentation. tIITE tS�14VFy 10 7EvA"ssce ti'i Yes ❑No
2.4) Will you conduct a"verification of absence of cyclonic flow"(EPA Method 1 Section 11.4)?
Absence of cyclonic now must be documented during this testing. ( .Yes ❑No
2,5) Will oxygen concentration be determined by❑EPA Method 3 via Orsat or�Lttict EPA Method 3A?(Spccify)
If"No",recheck line item 2.2 above.(Fyrites are NOT allowed according Id 15A NCAC 2D.2606). Yes ❑No '
Is an audit sample from an Accredited Provider available for the proposed test metbod(s)?(Additional information
2.6) available atdoe.uc.gnv/a oud ivtstons/air•gitg ' /air-c�upltp n'" tr=nt/tLlitsSrotut�r,tsti�e ( t t;�ut�lx [9Yes ❑No
�ooccc•lest-.asttiiair '.artati 11
2.7) Has all testing equipment been calibrated within the past year7 If"No",explain. ®.Yes ❑No j
2.8a)Have all calibration gases been certified by EPA Protocol t procedures? (Answer only as applicable.) -Yes ❑No
2.8b)Is a dilution system(EPA Method 205)proposed'? (Answer only as applicable. ❑Yes ZurNo
2.8c)Attach a summary of expected calibration gas concentrations for all proposed instrumental test methods.
2.9) What is proposed test schedule?DAO Regional 4unervimr mustbe notift , n viinlnrum of 15 days Wrier to fife actual test date(.)
THIS FORM DOES NOT CONSTITUTE,15 DAY REGIONAL OFFICE NOTIFICATION
E
i
Additional Comments:
Signatures: Representatives from the permitted facility and the contracted testing company must orovide signatures below certifying
that the information provided on this form and any attached information is accurate and complete.
It
Permitted Facility Representative Date 404inscu4piny Representative Date
Name: ��l/le�j%�//• e��� Namc:�l�j4EG � /llL�[G-'KSd>+
Title: �/s/i' MKT Titie; N�✓1A7e)LrNZ IeGNu
Company: //dCll I�G Company: l �l/
it

NORTH CAROLINA DIVISION OF Washington Regional Office
AIR QUALITY Avoca LLC
NC Facility ID 0800044
Stack Test Observation Report Coanty/FIPS:Bertie/015
Date: 08/30/2019
Facility Data Compliance Data
Avoca LLC Observation Date 08/21/2019
841 Avoca Farm Road Observer's Name Betsy Huddleston
Merry Hill,NC 27957 Operating Status Operating
Lat: 36d 0.0030m Long: 76d 42.6550m Action Code 23/STACK TEST
SIC: 2087/Flavoring Extracts And Syrups,nec OBSERVED
NAICS: 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: Comments: See notes concerning issue discussed below with
H101 Run 1 post leak check.
Date of Signature: 8/30/2019
Avoca contracted McHale Environmental(Mike Dickerson)to conduct the following performance tests on No.2
fuel oil-fired boilers H-101 and 1-1-102(20.3 MMBtu/hr max.heat input)to comply with the Boiler MACT(Subpart
DDDDD):
Volumetric Flow, Molecular Weight, and Moisture Methods 1-4
Filterable Particulate Method 5
Carbon Monoxide Method 10
Mercury Method 30B
Hydrochloric Acid Method 26A
Avoca opted to perform one-time tests rather than monthly fuel sampling to demonstrate compliance with the
emission limits for these boilers. The emission limits are provided in permit condition 2.I.A.5. as follows:"
HCI 1.1E-03 pounds per million Btu of heat input
Mercury 2.0E-06 pounds per million Btu heat input
CO 130 ppm by volume on a dry basis corrected to 3 percent
oxygen
Filterable PM 7.9E-03 lb per million BTU heat input;or(6.2E-05 lb per
or TSM million BTU heat input)
Pursuant to §63.7515(h), because these oil-fired boilers burn ultra-low sulfur fuel,Avoca is not required to conduct
further performance tests if the pollutants measured during the initial compliance performance tests meet the above
emission limits,provided that Avoca monitors type and volume of fuel combusted on a monthly basis.
Avoca submitted a protocol on 3/21/2019, and DAQ approved the protocol by letter on 5/02/2019. Avoca provided
notification to the regional office of the test dates on 7/25/2019,within the required 15 days of the test dates.
The boilers are identical with stacks of the same diameter. 12 points were tested to complete Methods 5 and 26A.
McHale chose to do two measurements per point (6-minutes between measurements). Mike showed me the audit
sample for Method 26A(it was ordered before the last audit contractor terminated with EPA).

H-102 Testing on 8/20/2019
I arrived on-site just before the end of Run 1 of M5 and M26A. Run 1 of M30B had already finished, as it was one
hour in length compared to two hours for M5/M26A.
The sampling port is a bit lower than they had planned due to some physical obstruction. I don't think this is a
problem as the stack is completely vertical.
I looked at the control panel for the boiler. Steam pressure was 150 psi and the stack temperature was 436°F. Steam
data will have to be used to back calculate the boiler operating rate for submittal with the report. Brian Conner
assured me that the boilers were operating at maximum heat input.
Methods 5 and 26A Observations
Box Data:
AH- 1.89
Y—1.023
Calibration date:4/18/2019
Ran 1 Data(I reviewed the data sheet and noted ranges of data recorded):
Start time 8:57 AM,port change 10:27 AM
Nozzle diameter 0.4971 (all three runs)
Initial leak check 0.001 cfm @ 24"Hg
K factor 36.2
Barometric pressure 30.09 mm Hg(for all three runs)
DGM start 766.001 cf
Impinger temperature ranged from 51-677 during the run
The highest vacuum was 17.5"Hg
Probe temperature 241-2507
Filter box temperature 253-2577
DGM temperature 90-111°F
Ap 0.05-0.11
Stack temperature 350-4287
Final DGM 871.2 cf
I observed the Run 1 post-leak check. The box operator is a new McHale employee, and was in training during
these tests. He did not wait a full minute during the leak check or remember to record the vacuum. However, I
observed the vacuum at about 19 inches, and after about twenty seconds the gas meter had recorded about 0.002 cf.
Run 2 Data
The sample train was correct and the desiccant looked new.
Start time 12:18 PM,port change 1:32 PM
I observed the pre-leak check at 0.005 cfm @ 24"Hg
The pitot check was good.
DGM start 871.833 cf
Impinger temperature ranged from 52-63OF during the run
The highest vacuum was 13"Hg
Probe temperature 248-267OF
Filter box temperature 250-260OF
DGM temperature 107-115OF
AH 2.172-3.982
Ap 0.06-0.08
Stack temperature 355-4307
I observed the post leak check(done correctly)at 0.0 cfm @ 15"Hg
Method 30B Observations
Mike had installed calibrated digital flowmeters to more accurately record and control flow for this test. They did
install condensers in the sample lines. Side 2 was the spike sample. The spikes are 15 ng concentration.
Side 1 Y—0.9984, calibration date 9/9/2018 (0.2%deviation)
(SharePointTacilities\Bertie08\00044\Stack Testing\20190821 H101 and H102 stk.doc) Page 2

Side 2 Y— 1.0241, calibration date 9/9/2018(2.4%deviation)
The method was sampled across 6 points in the stack with two readings per point(a reading every 5 minutes).
The sample rate was targeted at 1 liter/minute.
I was not present during Runl,but I looked at the data sheet. The sample lines pulled 56 liters and 58 liters during
Run 1.
I observed the pre-leak check for Run 2. Both sides were 0.0 liter/minute @ 25"Hg. The run started at 12:18 PM.
During Run 2 the following ranges were observed:
Probe Tern OF Vacuum inches Hg Meter Temp°F
Side 1 262-329 2.2-4.9 83-102
Side 2 248-329 3.5-6.0 85-99
Side 1 sampled 58.7 liters during Run 2. Side 2 sampled 61.14 liters during Run 2. I observed the post leak check.
Both Side 1 and Side 2 were 0.0 cfin @ 25"Hg.
Method 10 Observations
Calibration Gases
02 CO2 CO
Mid gas value/exp date 1 10.10%/7/16/2027 9/82%/7/16/2027 45 ppm/5/14/2021
High gas value/exp date 19.82%/7/22/2027 19.95%/7/22/2017 101 m/ 10/10/2026
The initial calibration was conducted using three CO gases at 45 ppm, 101 ppm and 501 ppm (exp. 10/31/2026).
Once the test got underway, it became quickly apparent that the CO emissions from the boiler was very low (less
than 1 ppm).Therefore,they used the 45 ppm cylinder for bias checks.
There was a condenser in the gas sample line.
I was no present to observe Run 1 but I retrieved the results from their computer:
Average raw Adjusted
CO 0.73 ppm 0.8 ppm
02 4.9% 5.0%
CO2 11.9% 11.9%
The bias data for pre and post Run I looked good.
I did observe the Run 2 post-bias check. Zero readings were good. The upper gas readings were 10.1%02, 9.75%
CO2,and 44.75 ppm CO.
Run 2 results were
Average raw
CO 0.90 ppm
02 4.43%
CO2 12.27%
H-101 Testing on 8/21/2019
1 arrived on-site just before the end of Run 1 of M5 and M26A. The same box was used. Run I of M30B had
already finished.
I looked at the control panel for the boiler. Steam pressure was 150 psi and the stack temperature was 398°F. Steam
data will have to be used to back calculate the boiler operating rate for submittal with the report. Brian Conner
assured me that the boilers were operating at maximum heat input.
Methods 5 and 26A Observations
Run 1 Data(I reviewed the data sheet and noted ranges of data recorded):
Nozzle diameter 0.4971 (all three runs)
(SharePoint\Facilities\Bertie08\00044\Stack Testing\20190821 H101 and H102 stk.doc) Page 3

Initial leak check 0.001 cfm @ 24"Hg
DGM start 10 1.192 cf
Impinger temperature ranged from 51-61°F during the run
The highest vacuum was 7.5"Hg
Probe temperature 243-247°F
Filter box temperature 251-259°F
DGM temperature 90-111°F
AH 1.348-2.353
Ap 0.05-0.06
Stack temperature 350-428°F
Following the run, the tester on the stack accidentally kicked the impinger box,and then the post leak check
failed. When he righted the box and adjusted the impingers, they passed with 0.0 cfm @15". Rather than
re-doing the run, Mike suggested if the moisture content comes out the same as Run 2 and the moisture
measured for H-102 the previous day, the run can be accepted without the past leak check. The impinger
train had already been disassembled for volume measurement before I had Mike contact Gary Saunders
directly about this approach. The two of them worked out an agreement.
A photo of the impinger volume data for Run 1 is attached to the file copy of this report. A photo of the volumes
for H-102 testing the day before is also attached.
I observed the Run 2 pre-leak check at the impingers 0.0 cfin @ 14" Hg. They then conducted a full train leak
check of 0.0 c&n @ 14"Hg.
Run 2 Data
I watched part of the first half of this run and all of the second half. I observed the following ranges during the
second half:
Impinger temperature ranged from 52-67°F during the run
The highest vacuum was 15"Hg
Probe temperature 255-257°F
Filter box temperature 257-264°F
DGM temperature 101-107°F
AH 1.96—2.40
Ap 0.05-0.06
Stack temperature approx.379°F at end of run
I observed the post leak check of 0.001 cfm @ 15"Hg.
Method 30B Observations
They used the same equipment as for H-102 testing.
The sample rate was targeted at 1 liter/minute. I was not present during Runl, but I looked at the data sheet. The
pre-leak check for both sides for Run I was 0.0 I/min @ 25" Hg. The sample lines pulled 59.26 liters and 58.8
liters during Run 1.
RUN 1 Probe Temp°F Vacuum inches Hg Meter Temp°F
Side 1 261-291 3.5-5.2 75-80
Side 2 267-291 2.9-5.2 78-81
1 observed the pre-leak check for Run 2. Both sides were 0.0 liter/minute @ 25"Hg. The run had to be interrupted
for a port change for M5/26A. Another leak check was completed before resuming(dead stop at 15"Hg). During
Run 2 the following ranges were observed:
Side 1 sampled 59.647 liters during Run 2. Side 2 sampled 59.802 liters during Run 2. 1 observed the post leak
check. Both Side 1 and Side 2 were 0.0 cfrn @ 25"Hg.
Method 10 Observations
(SharePoint\Facilities\Bertie08\00044\Stack Testing\20190821 H101 andH102 stk.doc) Page 4

The same equipment was used for this test as on 8/20/2019. The initial calibration was conducted using three CO
gases 45 ppm, 101 ppm and 501 ppm(exp. 10/31/2026).
I was not present to observe Run 1 but I retrieved the results from their computer:
Average raw
CO 0.90 ppm
02 4.43%
COz 12.27%
Run I ended at about 10:30 AM. The calibration, and bias data for pre and post Run 1 looked good. The post run
bias was done immediately after the run ended. Zero readings were good. The upper gas readings were 10.05%Oz,
9.95%CO2, and 44.75 ppm CO.
Run 2 started 11:47 AM and ended 1:01 PM.
Run 2 results were
Average raw
CO 0.21 ppm
Oz 5.41%
COZ 11.53
(SharePoint\Facilities\Bertie08\00044\Stack Testing\20190821 H101 and H102 stk.doc) Page 5

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Huddleston, Betsy j
From: Brian Conner <[e-mail]>
Sent: Thursday, July 25, 2019 12:04 PM
To: Huddleston, Betsy
Cc: Dale Overcash; Dana Norvell
Subject: [External] RE: Boiler MACT 5D Testing
a
Betsy,
Avoca plans to test the 2 No. 2 fuel Oil Boilers on August 20-21, 2019.This email is being sent within the required 15 day
notice to NCDAQ. Are those dates good for you, and do you need a formal letter with the testing date intent or is this
email sufficient?
Thanks,
Brian Conner
From: Huddleston, Betsy<[e-mail]>
Sent: Wednesday,June 19, 2019 3:18 PM
To: Brian Conner<[e-mail]>
Subject: Boiler MACT 5D Testing
—This is an external email message.Confirm the sender before opening attachments or clicking links.Avoid content that looks suspicious.*"'
Hey Brian,
Just checking in with you on plans for Boiler MACT testing. The protocol had noted testing being completed sometime in
May or June.
i
Betsy Huddleston.
Envuromwentral Enginur
Divi mof Air QualitV,Wasiu >cn Regional Office
252.449-3836(office) 94311raslzingtam Square Mall
252.97:5.3716(:ax) Wadilihngtort,NC 27889
[e-mail]
This e-mail contains information which may be privileged,confidential,proprietary,trade secret and/or otherwise legally protected.It is not intended for
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you are notified that disclosing,copying,distributing or taking any action in reliance on the contents of this information is strictly prohibited.No waiver of any
applicable privileges or legal protections is intended(and nothing herein shall constitute such a waiver),and all rights are reserved.
I
This e-mail contains information which may be privileged,confidential,proprietary,trade secret and/or otherwise legally protected.It is not intended for W®w<,..m....
transmission to,or receipt by,any unauthorized persons.If you are not the intended recipient,please do not distribute this e-mail.Instead,please delete this e-mail
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ROY COOPER NORTH CAROLINA
Governor Environmental Quattly
MICHAEL S.REGAN
Secretary
MICHAELABRACZINSKAS f
D/rector
May 2,2019 -
Dr.David M.Peele,Ph.D.
President
Avoca LLC
P.O.Box 129
Merry Hill,NC 27957-0129
Subject: Avoca LLC
Merry Hill,Bertie County,North Carolina
Facility ID 0800044,Air Permit No.01819T52
Protocol for Particulate Matter(PM),Hydrogen Chloride(10),Carbon Monoxide(CO),and
Mercury(Hg)Emissions Testing of No.2 Fuel Oil-Boilers H-101 and H-102 j
Proposed Test Date: May 20, 2019,To Be Performed by McHale Environmental
Tracking No.2019-092ST
Dear Mr. Peeler
The protocol submittal for emissions testing boilers H-101 and H-102 has been reviewed and is acceptable.
Testing will be performed as required by permit condition 2.1.A(5)to demonstrate compliance with
40 CFR 63 Subpart DDDDD National Emission Standards for Hazardous Air Pollutants forMajor Sources:
Industrial, Commercial, and Institutional Boilers and Process Heaters and for emissions inventory.
15A NCAC 02D.1109 CAA§ 1120) Case-by-Case MACT for Boilers&Process Heaters emission limits as
defined in permit condition 2.1.A(4)apply through May 19,2019.
The emissions sources are to be tested are: 4
• Boiler(ID No.H-101)is a No.2 fuel oil-fired boiler(20.3 million Btu per hour maximum heat input rate,and
• Boiler(ID No.H-102)is a No.2 fuel oil-fired boiler(20.3 million Btu per hour maximum heat input rate.
Testing will be performed firing ultra low sulfur No. 2 fuel oil in accordance with permit condition
2.1.A(5)(g). Provided the subject test results meet the emissions limits the facility intends follow the
requirements of 40 CFR 63.7515(h)to demonstrate'ongoing emissions compliance and avoid further
performance tests. 40 CFR 63.7515(h)requires the facility to record the type of fuel combusted on a monthly
basis for ongoing compliance.
The proposed test process rate for boilers H-101 and H-102 of approximately 18 MMBtu/hr each. The
following table addresses the parameters/pollutants,test methods,run time, and minimum sample collection
volumes with applicable regulations and limitations for each boiler. Note a minimum of 3-test rums per boiler
are to be performed.
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North Carolina Department of Environmental Quality 1 Division of Air Quality
217 West Jones Street 11641 Mail Service Center I Raleigh,North Carolina 27699-1641
919.707.8400

Dr.David M.Peele,Ph.D.,President
May 2,2019
Page 2(Avoca LLC -Boilers H-101 and H-102,40 CFR 63 Subpart DDDDD MACT Testing)
Table 1:Testin Methods and Limits for each Boiler Tested
EPA
Parameters/Pollutants Method: Run Time Emission Limit Regulation
Volumetric Flow Rate 1 2,3A, 3 runs Concurrent
Molecular Weight Moisture Content and 4 with Methods 5,26A,30B
3 runs,>:60 minutes each
Filterable PM 5 (minimum 3 dscm/run) 7.9E-031b/MNIBtu of heat input Standard starling MAY _
40 CFR 63 Subpart DDDDD
CO 10 3 runs,60 minutes each 130 ppmvd Q 3%02 Permit Section 2.1 A(5)(e)
Hg 30B 3 runs,minimum sample as 2 0 -06 lb/M v1Btu of heat input Standard through Mav 19,2019
specified in the method 15A NCAC 02D.1109
[CAA§1126)]
Permit Section 2.1 A
3 runs,>_60 minutes each
HCI 26A (minimum 2 dscm/run) 1.1E 031b/NIIvIBtu of heat input Standard starling Mav 20,2019
40 CFR 63 Subpart DDDDD
Permit Section 2.1 A(5)(e)
Note an audit samples analysis is required for EPA Method 26A. McHale Environmental has submitted an
audit sample order request. The sample must be present for inspection on request during the test period. For
additional information please see EPA web page https•//www.,pa.gov/emc/emc-technical-support.
No deviations from the applicable testing methodology were requested in the test protocol. Testing should be
conducted in strict accordance with the requirements of EPA Methods 1,2, 3A,4,5, 10,26,and 30B. The
proposed test methods are acceptable for the specified pollutants. Approval of the protocol does not exempt
the tester from the minimum requirements of the applicable methods.
The final test report should include information to establish that the testing performed was near maximum
normal or approximately>90%of maximum normal. The applicable test period monitoring parameters
should also be included.
If there are questions concerning this matter,please contact me at(919)707-8415 or
g_reie.onealAmcdenn gov.
Sincerely,
r
71OXA
Thomas G. ONeal,III,P.E., Environmental Engineer
Division of Air Quality,NCDEQ
cc: Brian Conner,Avoca LLC-Merry Hill,NC
Michael Dickerson,McHale Environmental-Durham,NC
Robert Fisher,Washington Regional Office
Central Files,Bertie County
IBEAM Documents-0800044
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0101f 09,:71517 u l Z
Avoca,LLC
Avoca' LLC 841 Avoca Farm
Far m Rd m Rd
e
Merry Hill,NC 27957
The World's Premier Botanical Extraction Company Phone:252-482-
2133 P Y Fax:[phone]
March 15, 2019
Mr. Robert Fisher _
Regional Supervisor
North Carolina Division of Air Quality
Washington Regional Office
943 Washington Square Mall
Washington, NC 27889
Re: Test Protocol Submittal
No. 2 Oil Fired Boilers
Avoca, Inc.
Merry Hill, NC
Permit No. 01819TS1
Dear Mr. Fisher:
Avoca Inc., (Avoca) owns and operates two existing No. 2 oil-fired (ultra low sulfur diesel or
ULSD) boilers (20.3 million BTU per hour, each) at our facility that are subject to the Boiler
NESHAP (or Boiler MALT) 40 CFR Part 63 Subpart DDDDD. The boilers are currently
operating under a 112(j) requirement as listed in Permit Condition No. 2.1-A.4. of the current
permit. The 112(j) requirement will expire on May 19, 2019.
On May 20, 2019, the boilers will become subject to the Boiler MACT requirements of 40 CFR
Part 63, Subpart DDDDD. The Boiler MACT requirements are listed within Permit Condition `
No. 2.1-A.5. of the current permit.
i
In accordance with Subpart DDDDD, the boilers must be tested within 180 days of the May 20,
2019 compliance date. Testing is required for PM, Hg, HCl, and CO. Avoca proposes to
conduct stack testing for the above pollutants and does not propose to conduct any fuel
sampling.
This protocol, or test plan as referenced within Subpart DDDDD, is being submitted 60 days
prior to any proposed testing. As part of this test plan submittal, Avoca proposes to
demonstrate ongoing compliance with the Subpart DDDDD requirements for the boilers by
utilizing §63.7515(h), as outlined below:
"(h) If your affected boiler or,process heater is in the unit designed to burn light liquid
subcategory and you combust ultra-low sulfur liquid fuel, you do not need.
further performance tests (stack tests or fuel analyses) if t ol�ta�psie�s e D
during the initial compliance performance tests meet the e '^ i�an Itlhits in Tables 1 1D
or 2 of this subpart providing you demonstrate ongoing co iI I`(pnce with th� ��ryf1'tpp
emissions limits by monitoring and recording the type of fu cbb'mb*2d 9n a Othl
basis. If you intend to use a fuel other than ultra-low sulfur iquid fuel, natural gas,
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refinery gas, or other gas 1 fuel, you must conduct new performance tests within 60
days of burning the new fuel type."
Based on the above requirements, if the boiler is tested in compliance with the emission
limits in the permit and Subpart DDDDD, ongoing compliance with the limits will be
documented by monitoring and recording the type of fuel combusted on a monthly basis.
Considering the above requirements, Avoca does not propose to install an oxygen analyzer _
and does not propose to set boiler load limits during this testing, as we have concluded such
is not required as a result of following the §63.7515(h) requirements.
Per Permit Condition 2.1-A.5, Subparts A and DDDDD of Part 63, and 2D .2600,Avoca is
submitting with this letter a test protocol form. Avoca is not submitting a full test plan as
outlined in Subpart DDDDD since we are proposing to conduct stick testing and propose to
follow the §63.7515(h) requirements as outlined previously.
In accordance with §63.7545(e),Avoca will submit a Notice of Compliance Status with all test
results within 60 days of completion of onsite testing.
Avoca is proposing to test the boilers sometime in late May or June. In accordance with 15A j
NCAC 2D .2602(d), Avoca will provide your office at least a 15 day notice prior to the test
date.
If you have any questions regarding the attached protocol, please feel free to contact Mr.
Brian Conner at (252)-482-2133, Ext. 287, or Mr. Mike Dickerson at [phone].
Sincerel ,
David M. Peele, PhD.
President
Avoca, Inc.
cc: Mr. Brian Conner,Avoca
Mr. Mike Dickerson, McHale EMS
Mr, Dale Overcash, Trinity Consultants
Enclosures:
DAQ Protocol Form r
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PROTOCOL SUBMITTAL FORM (Rev,2016)
�1(lli}:dh!'1lfh
DIVISION OF AiR QUALITY PAGE it OF 2
Purpose: The goals of the Protocol Submittal Perm are to initiate communication between representatives of the pomtitted facility,
the testing consultant,and the DAQ as well as to identify and resolve any specific testing concerns prior to testing.
Instructions: Use Guidance Document to fill out this form Submit all forms and additional information to the DAD R o onai.
Supervisor at least 45 de vs prior to Iestin . Complete one form for each sampling location. If this form does not supply
sufficient space to completely answer all questions or if additional relevant information is necessary,attach additional
documentation and/or information to the original form. Questions and/or comments should be directed to the appropriate
Regional Supervisor.
Thlt form and its Guidance Document are available at da5t .ev/ahmt�d)kitrt,/air-ottaiity/nir_ggnty-
10A ttg7 till/el Isti on-meaguremunt —
Specify Appropriate Regional Office:(check one)
0 Asheville ❑Fayetteville ❑Mooresville ❑Raleigh RWashington ❑Wilmington ❑Winston-Salem
Facility 10 No: A Test Company Name,
Facility Name: ft V06.4 LLC.
AYIa Al.fF C-AAs -
Facility ConractParson/mailing address&email: Testing Company Contact Person/mailing address&email!
-3al } ) C onel M 11r6 71t 1c¢r� se rt
4vo&A 4,LC M��fq�� C-M5
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Email.Addresv: ,l��(y '" Gi.Sb.FWn12? . GW11 Email Address:A41 K C. DIe-IeCf. 9c.'�1Ifr/�ALti. I
Phone:Z52 Lten-z133 Fax; Phone: G5 5578- 4
Mobile No.: 25 Z c{�j 2 - f(o z Z- Mobile No.:'714 703- 3 S,S L S
Air P Number&Revision: Permitted Source Name as ID No.:
Ot " TS t 1- 101 H laZ r�o. Z r71L_fr�c� 3011
Permitted Maximum Process Rate: Eximum Normal Operation Prooesa Rate: Target Process Rate for Testing:
20 . 3 YA/K-7l TN/1-1-t'� b , 3 MM 137-u
1.1)What is the specific purpose for the proposed tearing? (Permit condition,NSPS,NESHAP etc.-See guidance doc.1
Tb l�rNer»ST✓ATC Go'+rP i r an c¢ t417-14 1,44LT, c10 CF/�i3 5tJ Her Dr7DZ>D 45
1s this an initial rformance test? Yes or ❑Nn STA 3FDD 0-1 e�'.✓ntr r 15A 4C4C OUZ .OTIS-'t F)
1.2)List all state and federal regulations that apply to the proposed testing.(See guidance doc.) j5
3 NCAG DMA •f loll
C-"E 13Y CASE r l4GT� M4GT � S 7�PODD ATATCD tN &3.7s'oo TRblt2.
1.3)Will the test results be used for other regulatory purposes(e.g.emission inventories,permit_gplication,etc.)beyond that stated above?
Yes of 0No I£Yes,explain Ggl55ta-»S rAVEhTOR.y 1 uruit, ivtlrs �arGmo�lr
1.4)How will productionfprocess&control device data be documented during testing?(list specific control MuipWMu _proc g parameters,
it -trwncntationthatwill be used ftquenc ryofdata collection cannot byg�).lpute.r/msnuully etr.) 'rest Von not be accepted
pAthout ap r�opriate production/process&control device operation data. "4 Fe Wr!1 4 Sue 7:)4 r4 L
r D�f9t 11���1 'jfigpnnel uttrl 7ocu'116,17- 801ter of �ar1.1� t�rtnlr/wry sLICA fs,
Fuef FLowr s q,n cx,rp-1T i4e-4,r L.044,-)
1.5)Provide a brief description of the source(including control equipment)and At�11ch source or process flow diagram from source through
stack exit. 1�iLF!' eW-�i4LATE'7� T6 ATmos:phe e— -Zrpi-94- '574 1C . 600-1) [.ptvy�VSTlar)
rrrinsAey 1p_4n� or C 77rro)
1.6)Provide brief description of the sampling,location,.Attach schematic of sampling:location,and indicate whether concurrent testing will
be conducted at other sampling locations.(Approval of protocol without this data will not exempt you from Method criteria.)
At& -'AM1P1/iJ6 44 - IC COG47`tiv>i ( -SCTF SuavtF �216�'1 e lFST�
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PROTOCOL SUBMITTAL FORM Rev.2016
""w'�`'' DIVISION OF AIR UALl'PY PAGE 2 of 2
2.1)Provide the following information for each test parameter.
Target Proposed Number of Test Run #of Sampling
Pollutant Test Method Test Runs Duration Points Comments
t°tvl l4DfS(W f-t Z 3 76 P Ce>046U err LA ITN
®z 34 3 18 D "D C01100 ipulewc, 4li auas
ISM 3 3 T-8D 7'pD MrurMtrM 3 BscMljwN
Hp- Zb�l 3 T�lD i�17 MhrrnttlM 2 r3scM/�N
L-� 3o fb 3 i I31� �D
2.2) Will all testing be conducted In strict accordance with the applicable test methods? If"No",attach complete
documentation of all proposed modifications and/or deviations to the applicable test methods. ®Yes El No
2.3) Does the proposed sampling location Cmeet the cminimum EPA Method I criteria for acceptable measurement sites?
Attach supporting documentation. tIITE tS�14VFy 10 7EvA"ssce ti'i Yes ❑No
2.4) Will you conduct a"verification of absence of cyclonic flow"(EPA Method 1 Section 11.4)?
Absence of cyclonic now must be documented during this testing. ( .Yes ❑No
2,5) Will oxygen concentration be determined by❑EPA Method 3 via Orsat or�Lttict EPA Method 3A?(Spccify)
If"No",recheck line item 2.2 above.(Fyrites are NOT allowed according Id 15A NCAC 2D.2606). Yes ❑No '
Is an audit sample from an Accredited Provider available for the proposed test metbod(s)?(Additional information
2.6) available atdoe.uc.gnv/a oud ivtstons/air•gitg ' /air-c�upltp n'" tr=nt/tLlitsSrotut�r,tsti�e ( t t;�ut�lx [9Yes ❑No
�ooccc•lest-.asttiiair '.artati 11
2.7) Has all testing equipment been calibrated within the past year7 If"No",explain. ®.Yes ❑No j
2.8a)Have all calibration gases been certified by EPA Protocol t procedures? (Answer only as applicable.) -Yes ❑No
2.8b)Is a dilution system(EPA Method 205)proposed'? (Answer only as applicable. ❑Yes ZurNo
2.8c)Attach a summary of expected calibration gas concentrations for all proposed instrumental test methods.
2.9) What is proposed test schedule?DAO Regional 4unervimr mustbe notift , n viinlnrum of 15 days Wrier to fife actual test date(.)
THIS FORM DOES NOT CONSTITUTE,15 DAY REGIONAL OFFICE NOTIFICATION
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Additional Comments:
Signatures: Representatives from the permitted facility and the contracted testing company must orovide signatures below certifying
that the information provided on this form and any attached information is accurate and complete.
It
Permitted Facility Representative Date 404inscu4piny Representative Date
Name: ��l/le�j%�//• e��� Namc:�l�j4EG � /llL�[G-'KSd>+
Title: �/s/i' MKT Titie; N�✓1A7e)LrNZ IeGNu
Company: //dCll I�G Company: l �l/
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