AQ_F_0800107_20200406_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Washington Regional Office
AIR QUALITY W.E.Partners I,LLC—Cofield
NC Facility ID 4600106
Inspection Report W.E.Partners II,LLC-Lewiston Woodville
Date: 04/21/2020 NC Facility ID 0800107
Facility Data Permit Data
W.E.Partners I,LLC-Cofield and W.E.Partners II,LLC-Lewiston Woodville Permit 10064/R04 and 10126/R03
242 Perdue Road 3539 Governors Road Issued 5/23/2018 and 12/8/2016
Cofield,NC 27922 Lewiston Woodville,NC 27849 Expires 10/31/2024 and 11/30/2024
Lat: 36d 21.8044m Lat: 36d 8.3590m Class/Status Synthetic Minor
Long: 76d 53.9166m Long: 77d 13.3450m Permit Status Active
SIC: 4961 /Steam Supply Current Permit Application(s)None
NAILS:221119/Other Electric Power Generation,
22133/Steam and Air-Conditioning Supply Program Applicability
Contact Data
SIP
Facility Contact Authorized Contact Technical Contact MACT Part 63: Subpart 6J
Garald Cottrell Garald Cottrell Garald Cottrell NSPS: Subpart Dc
President President President
[phone] [phone] [phone]
Compliance Data
Comments:
A partial compliance evaluation(PCE)was completed for the facilities via file Inspection Date 3/27/2020(surveillance at
reviews and facility contact interview. The PCEs were conducted during the Cofield)and 04/06/2020(PCE both facilities)
Covid-19 teleworking period. No issues were discovered. Inspector's Name Betsy Huddleston
Operating Status Operating
Compliance Code Compliance-inspection
Inspector's Signature: Action Code PCE
On-Site Inspection Result Compliance
Date of Signature: 4/21/2020
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2013(Cofield) 61.00 4.90 58.10 3.30 88.60 55.50 7478.00
2014(Lewiston) 1.60 16.50 56.90 3.30 86.80 1.10 1697.70
*Highest HAP Emitted inpounds)
Five Year Violation History(Cofield facility 4600106)
Date Letter Type Rule Violated Violation Resolution Date
03/19/2018 NOV/NRE Permit Condition 01/04/2019
01/20/2018 NOV Permit Condition 03/02/2018
Five Year Violation History(Lewiston facility 0800107):
10/04/2019 NOV 2Q.0315 Synthetic Minor Facilities 10/04/2019
09/20/2018 NOV/NRE Part 63 -NESHAP/GACT Subpart JJJJJJ Industrial, 10/10/2018
Commercial and Institutional Boilers at Area Sources
06/07/2017 NOV Permit Condition 06/07/2017
11/22/2016 NOV/NRE 2D.I 111 Maximum Achievable Control Technology 03/24/2017
05/12/2015 NOV/NRE Part 63 -NESHAP/GACT Subpart JJJJJJ Industrial, 06/12/2015
Commercial and Institutional Boilers at Area Sources
Performed Stack Tests since last FCE :
Date Test Results Test Method(s) Facility ID Source(s)Tested
11/02/2018 Compliance Method 10 4600106 ESB-2
10/10/2018 Compliance Method 5 0800107 ESB-1

On 3/27/2020 I observed visible emissions from the Cofield W.E. Partners facility while I was
investigating a complaint on the adjacent Perdue facility at approximately 5:00 PM. Both boilers
appeared to be in operation. The background was blue sky and the smoke is white. I read the VE with
the sun at my back. I observed their stacks for about 3 minutes. The visible emissions from each stack
appeared to be 15-20%opacity.
On 4/06/2020 I conducted a partial inspection of both the Cofield and Lewiston W.E. Partners facilities. I
did not conduct a physical on-site inspection due to the COVID-19 stay-at-home order by the
Governor. Instead,I conducted a short phone interview with Chad Hoggard,plant manager for both
facilities, completed a file review, and performed an IBEAM modules review.
File Review
W.E. Partners I,LLC and W.E. Partners II are both subsidiaries of Wellons Energy Solutions, LLC. They
are biomass cogeneration facilities. Each supplies steam to the Perdue feedmill and soybean oil
extraction plant in Cofield and the Valley Proteins plant in Lewiston. Each facility has a turbine that
supplies to the grid as well.
The boilers and multiclones at both facilities are identical. However,the Lewiston facility employs an
electrostatic precipitator to further control particulates to meet the Boiler NESHAP Subpart JJJJJJ limit
for new boilers,which does not apply to the Cofield boilers due to age.
W.E. Partners I Sources and Controls
Emission Emission Source Control Control System
Source ID Description System ID Description
ESB-1 one clean cellulosic biomass-fired boiler MC-1 multi-cyclone
(NSPS,NESHAP) (29.4 million Btu per hour maximum (18 tubes,each 9 inches in diameter)
heat input)*
ESB-2 one clean cellulosic biomass-fired boiler MC-2 multi-cyclone
(NSPS,NESHAP) (29.4 million Btu per hour maximum (18 tubes,each 9 inches in diameter)
heat input)*
W.E.Partners II Sources and Controls
Emission Emission Source Control Device Control System
Source ID 7 Description ID Description
ESB-1 one clean cellulosic biomass-fired boiler MC-1 multi-cyclone
(NSPS, (29.4 million Btu per hour maximum (18 tubes,each 9 inches in diameter)
NESHAP) heat input)
ESP-1 electrostatic precipitator
(9,222 sq ft total collection plate area,
two fields with 60 kv charge per field)
ESB-2 one clean cellulosic biomass-fired boiler MC-2 multi-cyclone
(NSPS, (29.4 million Btu per hour maximum (18 tubes,each 9 inches in diameter)
NESHAP) heat input)*
ESP-1 electrostatic precipitator
(9,222 sq ft total collection plate area,
two fields with 60 kv charge per field)
ESB-3 one clean cellulosic biomass-fired boiler MC-3 multi-cyclone
(NSPS, (29.4 million Btu per hour maximum (18 tubes,each 9 inches in diameter)
NESHAP) heat input)*
ESP-1 electrostatic precipitator
(9,222 sq ft total collection plate area,
two fields with 60 kv charge per field)

The Cofield facility's current Permit R04 was issued as a resolution to a NOV issued on 01/30/2018. A
new carbon monoxide BACT determination was issued and the CO S133 limit was increased to 0.45
lb/MMBtu. Specific Condition 10.b. was also modified to require calculation and reporting of the
monthly and 12-month rolling total emissions of PMio and CO using the most current stack testing results
that are approved by DAQ. An equation for calculation of emissions is provided in the condition.
The Lewiston facility's current permit R03 was issued to add SB3 BACT conditions to the permit. The
Boiler GACT Subpart 6J conditions were updated to reflect revisions to the regulation. The fuel bunker
was removed from the permit and added to the insignificant activities attachment.
I conducted the most recent full compliance evaluations at both facilities(11/02/2018 Cofield and
9/26/2019 at Lewiston). The Cofield plant was found to be compliant with applicable regulations and
permit conditions, a violation was discovered for the Lewiston plant. I obtained the monthly wood
tonnages and determined for August 2018-July 2019 there were 100.07 tons of CO emissions in violation
of the synthetic minor condition A.13. of the permit. A NOV was issued 10/04/2019.
Although both facilities have an enforcement history,there are no current compliance issues for either
facility. There is some concern that the VE from the boilers at both facilities could exceed 20%opacity,
and continued surveillance outside of annual FCE would be preferred.
In recent months there has been discussion within DAQ as to whether poultry litter should be considered
`wood' for applicability of NCAC 2D.0504 and NSPS Subpart Dc,or as a distinct biomass fuel for which
neither of those regulations would apply. After several discussions by the Compliance Workgroup,
consulting EPA and other states,last week the director determined that DAQ will treat poultry litter as
wood. WaRO wrote both the Cofield and Lewiston permits assuming poultry litter as wood. Therefore,
conditions for 2D.0504 and Subpart Dc are already present in the permits.
The only known increase in emissions from litter compared to wood is HCI. It is significantly higher
from un-screened litter combustion. Some testing has been conducted from litter boilers at other facilities
in the state. From the first issuance of the W.E. Partners permits, W.E. Partners has screened their litter
offsite before bringing it to the facilities for combustion. While it's likely the HCI emissions are
elevated at the W.E. Partner plants, it should be much less than the unscreened litter. HCI testing may
need to be added when the permit is renewed in 2024.
Outside of possibly requiring HCI testing in the next permit revisions,no other changes are needed in the
permits.
Another benefit to screening the litter is reduction in odor. Both plants do burn up to 100%poultry litter,
but there has never been an issue with odor at either site.
Both facilities owe an annual synthetic minor report by January 30t1i. These were submitted on time
postmarked 1/30/2020. The CO emissions violation cited above was properly included in the Cofield
report.
Both facilities are required to compile compliance reports under the Boiler GACT due March 1 st,but
Cofield's are biannually vs. annually at Lewiston. They are only required to submit them to DAQ if there
were deviations of the 6J regulation. It's my understanding they had no issues for the previous year.
Biennial tune-ups are required by the Subpart 6J. Boiler tune-ups at both facilities were completed on
1/23/2018, so tune-ups should have been completed early in 2020.
Both permits have S133 BACT conditions. For the Cofield facility, stack testing is required every eight
years for NOx,PM/PM I O/PM2.5, and CO against the respective BACT limits.. The tests must be done
within a±30 day window of eight years from the date of last test. All pollutants at Cofield were tested on
ESB-1 on 10/13/2015, so it will not need to be tested again until October 2023. All pollutants were tested
on ESB-2 at Cofield on 10/12/2017,but the CO emission was greater than the BACT limit. W.E.

Partners submitted an application with a revised BACT analysis. A new CO limit was established in the
permit, and the facility retested for CO on 11/02/2018. Therefore,the next testing for NOx and
particulate on ESB-2 is due October 2025, and CO testing on this boiler is due November 2026. The
ESP stack on the Lewiston boilers was tested for NOx,PM/PM 10/PM2.5 and CO on 5/04/2017, so the
next testing is due May of 2025. The Lewiston boilers were tested for particulate on 10/10/2018,but the
ESP was operating with one TR set down,which is not normal operation.
I reviewed the data for both 0800107 and 4600106 in every module of IBEAM. I made the following
changes:
• The most recent Lewiston inspection document was incorrectly saved to the Cofield facility in the
Documents module. I deleted it.
• The most recent Lewiston inspection document is saved twice to the public file. No action is
needed.
• I added NOx to the SIP in Actions Pollutants for Cofield. It has a synthetic minor limit and is a
S133 BACT pollutant.
• I inactivated SO2 in the NSPS program for Lewiston. The boilers are less than 30 MMBtu/hr, so
don't have a SO2 NSPS limit. Because this program/pollutant is somehow tied to a record
elsewhere(likely an old report) in IBEAM, I could not delete it.
• 1 added the Lewiston 11/22/2016 NOV and 9/29/2016 FCE to PUB file in Documents.
• 1 added the Cofield 4/25/2017 FCE to the PUB file in Documents.
I looked at the electronic files for both facilities in SharePoint. The files date back to 2010, so I didn't
purge any records.
Plant Contact Interview
I contacted Chad Hoggard on 4/06/2020 to complete the partial compliance evaluation. He said that both
W.E. Partners facilities are in full operation with no reduction in workforce planned. The Valley Proteins
and Perdue facilities are operating through the pandemic, and W.E. Partners is their steam supply.
I reminded him that they should be keeping up with their maintenance and inspection requirements for the
multiclones at both facilities and the ESP at the Lewiston facility. He confirmed their records are in good
shape. I asked if they'd had any issues with their secondary power monitoring. He responded that they
were fine with meeting all of their monitoring and recordkeeping requirements. I reminded him to pay
attention to the boilers' opacities.