AQ_F_0800107_20190213_ST_RvwMemo_2018-303st

DIVISION OF AIR QUALITY
February 13,2019
MEMORANDUM
To: Robert Fisher,Washington Regional Office (
From: Shannon Vogel, Stationary Source Compliance Brancho
Subject: W.E. Partners II,LLC—Lewiston Woodville(WEPII)
Lewiston Woodville,Bertie County,North Carolina
Facility ID 0800107,Permit No. 10126R03
Particulate Emissions Testing of Boiler ESB-1
Performed by Environmental Source Samplers(ESS)on October 10,2018
Tracking No. 2018-303st
ESS performed EPA Method 5 filterable particulate matter(PM)testing to demonstrate compliance with
the applicable emissions standards while operating with one ESP field deactivated. The test results are
acceptable to demonstrate compliance with the filterable PM limits as discussed below.
Per the Stack Test Observation(STO),WEPII notified the regional office"that the transformer on the
second field of the ESP had failed"and a new transformer"would not arrive for ten to twelve weeks."
Therefore, due to the"length of the continuing violation... 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."
ESB-1 is a clean cellulosic biomass-fired boiler controlled by multiclones MC-1 and electrostatic
precipitator ESP-1. ESP-1 (two 60 kv charge fields)also controls emissions from ESB-2 and ESB-3
boilers. The maximum permitted heat input rate for the three boilers is 29.4 million Btu per hour
(mmBtu/hr), each. ESS reported an average heat input rate of 54.8 mmBtu/hr during testing.
The following regulations apply: SB3 BACT, 15A NCAC 2D .0504 Particulates from Wood Burning
Heat Exchangers,40 CFR 60 Subpart Dc Standards of Performance for Small Industrial-Commercial-
Institutional Steam Generating Units,40 CFR 63 Subpart JJJJJJ National Emissions Standards for
Hazardous Air Pollutants for Industrial, Commercial,Institutional Boilers Area Sources, 15A NCAC 2Q
0315 Synthetic Minor and 15A NCAC 2Q .0317 Avoidance Conditions for 15A NCAC 2D .0530
Prevention of Significant Deterioration(PSD). SB3 BACT limit for PM/PM10/PM2.5 is 0.05 pounds per
million Btu(lb/mmBtu). The 63 Subpart JJJJJJ limit for filterable PM is 0.070 lb/mmBtu. The test
results are tabulated below.
Pollutant Test Results Emissions Limit Standard Compliance
0.070 lb/mmBtu 63 Subpart JJJJJJ Yes
Filterable PM 0.0287 lb/mmBtu 0.051b/mmBtu1 SB3 BACT NAl
0.43 lb/mmBtu 2D .0504 Yes
1. SB3 BACT limit applies to total(filterable and condensible)PM for PM/PMIo/PM2.5.
Compliance was demonstrated. If you have any questions regarding the results of this review,please
contact me at 919-707-8416 or shannon.vogel(( ncdenr.g_o_v.
cc: Central Files,Bertie County IBEAM Documents—0800107