AQ_F_0800107_20181010_CMPL_InspRpt

NORTH CAROLINA DIVISION.OF Washington Regional Office
AIR QUALITY W.E.Partners II,LLC-Lewiston Woodville
NC Facility ID 0800107
Stack Test Observation Report County/FIPS:Bertie/015
Date: 10/18/2018
Facility Data Compliance Data
W.E.Partners Il,LLC-Lewiston Woodville Observation Date 10/10/2018
3539 Governors Road Observer's Name Betsy Huddleston
Lewiston Woodville,NC 27849 Operating Status Operating
Lat: 36d 8.3590m Long: 77d 13.3450m Action Code 23/STACK TEST OBSERVED
SIC: 4961 /Steam Supply
NAICS: 22133 /Steam and Air-Conditioning Supply
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 10126/R03
Garald Cottrell Garald Cottrell Garald Cottrell Issued 12/8/2016
President President President Expires 11/30/2024
[phone] [phone] [phone] Classification Synthetic Minor
Permit Status Active
Inspector's Si nature: Comments: This stack test is required by the 9/20/2018
NOV/NRE issued to the facility.The Method 5 stack test
appeared to be properly conducted.
LDateof Signature:
On 8/17/2018 Mr.Garald Cottrell notified this office by email that the transformer on the second field of the
ESP had failed. The email stated that a fuse to the communication feedback loop was also lost with the
transformer failure,so personnel did not have an indication that only one field on the ESP was in operation.
The email also stated that the secondary power 30-day rolling average data had dropped below the
parametric monitoring minimum limit established during performance testing for compliance with 40 CFR
Part 63, Subpart JJJJJJ. Based upon.when the rolling average began to fall below the minimum,the
transformer likely failed sometime in June 2018.
DAQ issued a NOV/NRE on 9/20/18 citing the following violations:
1) failure of the ESP secondary power thirty-day rolling averages to meet the 3.4 kW minimum is a
continuing violation of 40CFR 63.11201(c),Table 3 of Subpart JJJJJJ,and Permit Specific
Condition 1 Le.ii.D.
2) violation of General Statute 143-215.108(c)(1)and permit General Condition No. 6
The 8/167/2018 email stated that a new transformer would not arrive for ten to twelve more weeks.
Because of the length of the continuing violation the NOV/NRE,and the argument from the facility that the
ESP fields are oversized and they can meet the emission limit with one field in operation,DAQ required the
facility to perform EPA Methods 1-5 particulate stack testing at the outlet of the ESP with only the first field
in operation.
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The test protocol was submitted with 10 days of the NOV/NRE. S SCC provided a protocol approval letter
on 10/08/2018. The test was conducted on 10/10/2018(within 30 days of NOV/NRE issuance). I was G
present to observe Runs 1 and 2. Each test run was two hours in length. The boilers were firing 100%
litter.
The test was conducted by Environmental Source Samplers,Inc. (ESS). The ladder to the test ports was
too tall for me to safely climb the stack to observe the method train. However,I could see ESS moving the
probe to each sampling point and port. I observed their test data immediately following each run.
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I confirmed that the ESP second field was still down,and that the first field was operating for the test.
During the first run Mr. Cottrell explained to me that when half of the 2"d field transformer had failed,ALL
of the rappers had quit operating for both fields(this was new information to me). They connected a new
controller to the other operating transformer,and managed to get the rappers back into operation,along with
raising the secondary power to the operational field over 3.4 kW beginning 9/19/2018. They still have three
more weeks before the new transformer arrives. Operator logs for 9/17-23./2018 are attached to the file
copy of this report.
The first test run was already in progress when I learned that all rappers had been down following the
transformer failure. The rappers were in operation during the run. I asked that the rappers be turned off for
the remaining test runs. The first run was completed with the rappers on. W.E.Partners made the decision
to perform a 4'run with the rappers off. Before the second ran began, I observed the control panel data
confirming that the rappers were turned off.
The steam demand varied during the test runs. It is my understanding that they can produce as much as 80
KPPH steam on rare occasions. Valley Proteins steam demand is usually at 50-56 KKPH(80-90% of the
time). At the beginning of Run 1 the steam demand was 61.6 KPPH. Over the course.of Run 1 I observed
steam demand as high as 78 KPPH and as low as 46 KPPH.
While I was assured that they were firing the boilers as close to maximum heat input as possible,I was
concerned that the swing in steam demand may compromise their meeting the 90%of maximum heat input
testing requirement. They turned on the evaporator at about 10:40 AM;which then pushed the boilers,
prompting the system to blow steam(which is triggered when the steam line is at 345-350 psi). They
continued to operate this way through the second run. The turbine was also in operation during the testing.
The boiler drafts were-0.20, -0.42 and-0.44 inch H2O. The steam line to Valley was observed at 129 PSI
and 324°F.
I reminded Mr.Cottrell they needed to record steam/Btu data for the boilers at least every 15 minutes during
the test runs. He pulled the data from their control panel at the end of each run.
The 02/CO2 calibration gases were observed as follows:
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Mid% Exp.Date High% Exp.Date
02 12.08 12/15/22 20.45 2/18/23
CO2 8.9 12/15/22 17.38 2/18/23
Zero(nitrogen)gas cylinder expiration date is 8/31/2019.
DGM gas volume during Run 1 was 79 cf. DGM gas volume during Run 2 was 70.4 cf.
Highest vacuum during Run 1 was 1 in.Hg. Highest vacuum during Run 2 was 3 in. Hg.
I periodically observed visible emissions from the boilers during test Runs 1 and 2. VE did not exceed 5%.
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(Sharepoint\Facilities\Bertie08\00107\Compliance\20181010stk PM.doc)

NC DAQ Source Test Observers Checklist - Particulate Testing EPA Methods 1 - 5
Facility Name/Location : VV E-Par4nCf$ Levw 64"-Woodv,J1 c ()g l50)0-?
Source Contact/Phone#: artd d /, , 0J
Testing Firm/Contact: �� l:�_�.
Permit#/Source tested: I D Z(p RS 3 E99_1 , �SB�2 rse-3 E5fi' Syl c
Applicable Regulation/Limit (see reverse side): o ly
0 N FS A f' Sub �+� 5 0,07 �MN►B �-
Process Data/Production Rate(see reverse side):
Sample Date/Time:Run 1 (o r a / 915 - Run 2 16 10 / IISO _ Run 3 /
Ask for an explanation to any question answered"No"and attach comments to this form.
Method l - Sample and Velocity Traverses for Stationary Sources YES NO
1.1)Method 1 calculated correctly(see reverse side)?
1.2)Cyclonic flow check completed? (Average of absolute value of all angles<20 degrees?)
Method 2 -Determination of Stack Gas Velocity and Volumetric Flow Rate YES NO
2.1)Pitot tube leak check completed after each run?
2.2)Visual check of pitot tube heads-good condition?
2.3)Manometer level and zeroed correctly?
2.4)Static pressure measured durine the test day?
2.5)Barometric pressure recorded and adjusted for elevation?(see reverse side) 30,•01 tnrr-
2.6)Pitot tube heads oriented to axis of flue?/Pitot tube perpendicular to axis of stack?
2.7)Temperature recorded at each sampling point? 541e— S
Method 3 - Gas Analysis for O , CO, and Dry Molecular Weight YES NO
3.1)Multi point integrated sample/Bag evacuated and leak free? WA
3.2)Ors ,e ectronic analyzer r Fyrites used?(circle)(see reverse side) rtm ! m 6 7co 2. /1
3.3)Orsat performed in triplicate?Analysis consistent?(see reverse side) /V/A
3.4)Calculate F,/Within range?(see reverse side)
Metho - etermination of Moisture Content in Stack Gases YES NO
4. mpingers d or some other type of condenser? Multi point sample?
4.2)H2O in first 2 impingers,3rd impinger empty,silica gel in 4th impinger?
4.3)Temperature at the exit of impingers/condenser<68 F?(see reverse side) vyj4 Vd+)S J
4.4)Silica gel in good condition?-Blue-new,Pink-spent(unable to absorb more H2O)
Method 5- Determination of Particulate Emissions from Stationary Sources YES NO
5.1)Methods 2-5 run concurrently?
5.2)Visually inspect sample nozzle for damage/Nozzle opening facing direction of flow?
5.3)Pre test run leak check,optional(watch)Leak Rate<0.02cfm? Run 1 8 e 15 ' �^� O e(o"
5.4)Post test run leak check,mandatory(watch)Leak Rate<0.02cfm? " pye o p 1, f22S f 5
5.5)Nozzle Diameters Run 1: ®,ZS Run 2: /J Run 3:
5.6)Isokinetic rates between 90%and 110%?(see reverse side)
5.7)Filter and probe temperatures at 248+/-25F(or applicable subpart)? %,2 y6_Z4(3 ba A MO.<
5.8)During a run,was any equipment changed(ie.filter,nozzle,impinger)and why? (Do not explain a"No") N
5.8a)Was a leak check performed prior to the equipment change?(May not be applicable). A
5grement
calibration values-OH@: , Y: Date Calibrated:
5umbers Run 1: Z^L Run 2: Run 3:
5late sample clean-up:
nozzle,probe,and glassware(before the filter)rinsed and brushed in triplicate(minimum)?
older disassembled on site or transported to lab intact?(circle)
urement of condensibles-Liquid in impingers shipped to lab?(May not be applicable)
Regulation: SIP Sources require Ihr particulate test runs and a minimum sample of 30 dscf. NSPS regulations may require different sample
'/IC,W c:� � �5 I

rates,times,and temperatures. Investigate prior to test.
Process Data:It is absolutely imperative for the facility to record the pertinent data during the test so that the measured emissions can be
correlated to a production rate and compared to the permit limit. The test will be unacceptable without production data.
Method 1: If stack is between 4"- 12"then Method la must be employed. If duct is<4"then alternative methods must be used(contact SSCU
with any test questions)
Stack Diameter? Measured on site?
Port distance from upstream disturbance(A) Upstream Diameters(A)
Port distance from downstream disturbance(B) Downstream Diameters(B)
#of Sampling Points? (Draw a line vertically from the"Distance A"axis down to the step chart,and from the"Distance B"axis up
to the step chart. The maximum#of points marked'on the chart yields the minimum#of points to be sampled.)
Duct Diameters Upstream from Flow Disturbance*(Distan Duct Diameters Upstream from Flow Disturbance*(Distance A)
5 .5 1.0 1.5 2 111.0 2.5 5 .5 1.0 1.5 2.0 2.5
14108091WLS 6r Ducts isturb n e 'W�l86�MAhr Ducts Dissttaurb n e
4
� nt
u 4 M I r nt
M 3 ly
24&25 Disturb n e Disturb n e
2 20 2
16 Stack Diameter 0.6 m(24 in.) 16 Stack Diameter>0.6 m(24 in.)
12
1 Dlsrkrm.Eno��O r�,�XSBnosion,Contr ction Lfc. 1 DIsrt�i'bfa'ncN('t�Andl;IXOR°lion,Contr coon e�c.
Stack Diameter=Ou to un m(12--: Stack Diameter=0.3 to 0.61 m(12-24 in.)
0 0
Duct Diameters Downstream from Flow Disturbance*(Dis Duct Diameters Downstream from Flow Disturbance*(Distance
Figure I'-1.Minimum number of traverse points for particulate traverses. Figure 1-2.Minimum number of traverse points for velocity(nonparticulate)traverses.
Points correctly marked on the pitot tube? Port length accounted for in calculations?
Remarks: 1
Barometric Pressure:Barometric pressure must be adjusted minus 0.1"per 100ft elevation increase or vice versa for elevation decrease.
(Elevation at which barometric pressure is measured to the elevation at the test platform.)
Orsat,Analyzer or Fyrites: The measurement of OZ&CO,is usually performed with an Orsat. However,it is acceptable to use an analyzer
if it has been calibrated per Method 3a. I;yrites are acceptable for CO,measurement. An OZ fyrite can be grudgingly accepted when the results
are used to calculate molecular weight only. In no case shall an OZ fyrite be accepted if the emission standard is in terms of lb/mmBtu or
corrected to a percentage of oxygen.
Orsat Triplicate: For each test run there must be three individual analysis of the OZ&CO2 concentrations in the flue gas. The analysis must
be repeated until the following analysis criteria is met:
CO2-any three analyses differ by 02-any three analysis differ by
a)<0.3%when CO2>4.0% a)<0.3%when 02> 15.0%
b)<0.2%when CO2<4.0% b)<0.2%when 02<15.0%
Calculate F.:
Coal: Anthracite and lignite 1.016-1.130 Gas: Natural 1.600- 1.836
Bituminous 1.083-1.230 Propane 1.434- 1.586
G U/ — /OU2) Oil: Distillate 1.260-1.413 Butane 1.405- 1.553
F� %C Residual 1.210-1.370 Wood: 1.000- 1.120
Exit Temperature: The temperature of the dry gas leaving the impingers/condenser must be below 68F. When the ambient temperature is
above 68F it may take approximately 5 minutes for the thermal effects of the ice bath to cool the exit thermometer below 68F.
Leak Check: If the results of the leak check indicate a leak(>0.02cfin),record the leakage rate. Suggest repeating the run,but it is the
discretion of the test team and facility to accept the leak. However,the sample volume will be adversely adjusted due to the leakage rate.
Isokineties: If the test team indicates that the isokinetic rate of a run is over 110%or under 90%,the run should be voided and repeated.
Particulate Sample Clean-up: If any particulate sample is lost during clean-up,the run should be voided and repeated.
Remarks: