DEQ-CFW_00073726

SECTION 2 - SPECIFIC LIMITATIONS AND CONDITIONS
2.1 Emission Source(s) and Control Devices(s) Specific Limitations and Conditions
The emission source(s) and associated air pollution control device(s) listed below are subject to the following specific terms, conditions,
and limitations, including the testing, monitoring, recordkeeping, and reporting requirements as specified herein:
A. No.1 hog fuel boiler (ID No. ES-64-25-0290) firing lignin, natural gas, clean cellulosic biomass, No. 6 oil, No. 2 on, used
oil, sludge, and HVLC gases with a maximum heat input of 1,021 million Btu per hour when firing any combination of
fuels, 835 million Btu per hour when firing clean cellulosic biomass in combination with any other fuel, and 617 million
Btu per hour when firing No. 6 fuel oil alone, controlled by primary multicyclone (ID No. CD-64-45-0100) and secondary
multicyclone (ID No. CD-6445-0230) operating in series, followed by electroscrubbers (ID Nos. CD-64-60-0120, CD-64-60-
420 and CD-64-60-0720) operating in parallel, and
No. 2 hog fuel boiler (ID No. ES-65-25-0310) firing lignin, natural gas, clean cellulosic biomass, No. 6 oil, No. 2 oil, used
oil, sludge, and HVLC, LVHC, and SOG gases with a maximum heat input of 889 million Btu per hour when firing any
combination of fuel and 800 million Btu per hour when firing No. 6 fuel oil alone, controlled by multicyclone (ID No. CD-
65-45-0100) in series with electroscrubbers (ID Nos. CD-65-60-0120, CD-65-60-0410, and CD-65-60-0610) operating in
parallel.
The followine table nrovides a summary of limits and standards fnr the emissinn Qmirrpc riPcrrihPA ahnuP-
Regulated
Pollutant
Limits/Standards
A licable Regulation
Particulate Matter
Allowable emission limit when firing 2Wy wood residue:
15A NCAC 02D .0504
E = 1.1698 Q -0.2210 lbs/million Btu = 0.22 lb/million Btu
Where Q = maximum heat input in million Btu/hour from all wood
burning indirect heat exchangers.
Sulfur Dioxide
2.3 percent sulfur content fuel when firing only wood residue
15A NCAC 02D .0516
Nitrogen Oxides
NO2, shall not exceed:
15A NCAC 02D .0524
0.3 pounds per million Btu heat input when firing oil only or oil and
(40 CFR 60, Subpart D)
wood residue or natural gas and wood residue.
0.2 pounds per million Btu heat input when firing natural gas only.
Sulfur Dioxide
S02 emissions shall not exceed:
0.8 pounds per million Btu heat input when firing oil only or oil and
wood residue.
Particulate Matter
PM emissions shall not exceed:
0.10 pounds per million Btu heat input when firing oil only or oil and
wood residue or natural gas and wood residue.
Visible Emissions
VE shall not exceed:
20 percent opacity when averaged over a six -minute period, except for
one six -minute period per hour of not more than 27 percent opacity.
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Regulated
Pollutant
Limits/Standards
Applicable Regulation
Criteria Pollutants
CO emissions from the No.1 hog fuel boiler shall not exceed:
15A NCAC 02D .0530
• 1,646 pounds per hour when firing HVLC NCG gases
Emissions from the No. 2 hog fuel boiler shall not exceed:
• 1,433 pounds of CO per hour when firing HVLC NCG gases;
* 0.10 pounds of PMIo per million Btu heat input when firing any
fuel;
• 0.8 pounds of SO2 per million Btu heat input when firing oil with
wood;
• 339 pounds of H2SO4 mist consecutive 24-hour period when
firing LVHC and SOG NCG gases; and
• 235 pounds of total reduced sulfur (TRS) consecutive 24-hour
period when firing LVHC NCG and SOG gases
Where: HVLC NCG is high volume, low concentration
noncondensible gases,
LVHC NCG is low volume, high concentration noncondensible
gases, and
SOG is stripper off gas
Nitrogen oxides
NOx emissions from No. 2 hog fuel boiler shall not exceed:
15A NCAC 02Q .0317
1,771.3 tons per consecutive 12 month period.
(15A NCAC 02D .0530
Avoidance)
PMI0
Compliance Assurance Monitoring
15A NCAC 02D .0614
Hazardous Air
HAP emission shall not exceed limits in Section 2.1 A.7.b.
I
15A NCAC 021).1109
Pollutants
[CAA § 1126F)J
1. 15A NCAC 02D .0504: PARTICULATES FROM WOOD BURNING INDIRECT HEAT EXCHANGERS
a. Emissions of particulate matter from the combustion of wood that are discharged from the hog fuel boilers (ID Nos.
ES-64-25-0290 and ES-65-25-0310) into the atmosphere shall not exceed 0.22 pounds per million Btu heat input as
calculated according to the following equation:
E = 1.1698 Q -0.2211 lbs/million Btu
Where E = the allowable emission rate and Q = maximum heat input in million Btu(hour from all wood burning
sources.
[15ANCAC 02D .0504]
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the results
of this test are above the limit given in Section 2.1 A. La above, the Permittee shall be deemed in noncompliance with
15A NCAC 02D .0504.
Monitoring and Recordkeeping [15A NCAC 02Q .0508(f)]
c. Particulate matter emissions from the hog fuel boilers shall be controlled as specified in Section 2.1 A.3 j below and
inspected and maintained as specified in Section 2.1 A.3.k below. The Permittee shall be deemed in noncompliance
with 15A NCAC 02D .0504 if inspection and maintenance records (written or electronic format) are not created or
retained.
Reporting [15A NCAC 02Q .0508(f)]
d. Within 30 days of a written request from the DAQ, the Permittee shall submit a report of any maintenance performed
on the multicyclones or electroscrubbers.
2. 15A NCAC 02D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide when firing wood in the hog fuel boilers (ID Nos. ES-64-25-0290 and ES-65-25-0310) shall
not exceed 2.3 pounds per million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels, wastes, ores,
and other substances shall be included when determining compliance with this standard. [15A NCAC 02D .0516]
Testing [15A NCAC 02Q .0508(f)]
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b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found in
Section 3. If the results of this test are above the limit given in Section 2.1 A.2.a above, the Permittee shall be deemed
in noncompliance with 15A NCAC 02D .0516.
Monitoring/Recordkeeving [15A NCAC 02Q .0508(f)]
c. Monitoring, recordkeeping and reporting are not required for the combustion of wood residue in these boilers.
3. 15A NCAC 02D .0524: NEW SOURCE PERFORMANCE STANDARDS (40 CFR PART 60, SUBPART D)
a. The Permittee shall comply with all applicable provisions, including the notification, testing, reporting, recordkeeping,
and monitoring requirements in accordance with 15A NCAC 02D .0524, "New Source Performance Standards (NSPS)
as promulgated in 40 CFR Part 60, Subpart D, including Subpart A "General Provisions." [15A NCAC 02D .0524]
Emissions Limits [15A NCAC 02D .0524]
b. The following emission limits shall not be exceeded for each hog fuel boiler:
POLLUTANT
EMISSION LIMIT
Sulfur Dioxide
0.8 pounds per million Btu heat input when firing oil or oil and wood (except
during periods of startup, shutdown and malfunction)
Firing natural gas only
0.2 pounds per million Btu heat input when firing natural gas (except during
periods of startup, shutdown and malfunction)
Nitrogen Oxides
(expressed as NO2)
Firing oil or ruing wood with oil or wood with natural gas
0.3 pounds per million Btu heat input when firing oil or oil and wood residue or
natural gas and wood residue (except during periods of startup, shutdown and
malfunction)
Particulates
0.10 pounds per million Btu heat input when firing oil or oil and wood residue
(except during periods of startup, shutdown and malfunction)
Visible Emissions
20 percent opacity (except during periods of startup, shutdown and malfunction)
except for one six -minute period per hour of not more than 27 percent opacity
Operational Limit [15A NCAC 02D .0524]
c. The hog fuel boilers shall not burn No. 6 oil alone except under startup, shutdown, and malfunction conditions.
Testing [15A NCAC 02Q .0508(t)]
d. Under the provisions of North Carolina General Statutes 143-215.108 and in accordance with General Condition JJ,
the Permittee shall demonstrate compliance by testing the No. 1 and No. 2 hog fuel boilers (ID Nos. ES-64-25-0290
and ES-65-25-0310) for particulate emissions no later March 9, 2015 and once every five years, thereafter. During
testing, each boiler shall (1) fire the fuel or fuel combination expected to result in the highest emissions of each
pollutant and which is expected to contribute at least 10% of the 12-month average heat input for the boiler, and (2)
be controlled by gWy two of its three electroscrubbers for which at least 25% of the total elements have less than 1
kilovolt of voltage applied. If the result of any test is greater than a limit given in Section 2.1 A.3.b above, the
Permittee shall be deemed in noncompliance with 15A NCAC 02D .0524.
e. Under the provisions of North Carolina General Statutes 143-215.108 and in accordance with General Condition JJ,
the Permittee shall demonstrate compliance by testing the No. 1 and No. 2 hog fuel boilers (ID Nos. ES-64-25-0290
and ES45-25-0310) for sulfur dioxide emissions once every five years of normal operation. Normal operation does
not include periodic firing for building heat or maintenance. During testing, the boiler shall fire the fuel or fuel
combination expected to result in the highest emissions of each pollutant and which is expected to contribute at least
10% of the 12-month average heat input for the boiler. If the result of any test is greater than a limit given in Section
2.1 A.3.b above, the Permittee shall be deemed in noncompliance with 15A NCAC 02D .0524.
Monitoring [15A NCAC 02Q .0508(f)]
f. The Permittee shall install, calibrate, maintain, and operate a continuous opacity monitoring system (COMS) for
measuring the opacity of the visible emissions from each hog fuel boiler.
g. The Permittee shall demonstrate compliance with the opacity limit in Section 2.1 A.3.b above using six -minute
averages of the COMS values. If any six -minute period average exceeds 20 percent opacity (except during periods of
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startup, shutdown and malfunction) except for one six -minute period per hour of not more than 27 percent opacity,
the Permittee shall be deemed in noncompliance with 15A NCAC 02D .0524.
h. The Permittee shall install, calibrate, maintain, and operate a continuous emissions monitoring system (CEMS) for
measuring and recording the 1-hour average NOx and O2(or CO2) emission rates in pounds per million Btu heat input
during all periods of boiler operation, except for periods of CEMS breakdowns and repairs, in accordance with §60.13
and §60.48b. Data shall be recorded during calibration check and zero and span adjustments. The Permittee shall be
deemed in noncompliance with 15A NCAC 02D .0524 if the 3-hour average NOx emissions rate exceeds the emission
limit in 2.1 A.3.b above.
Particulate matter emissions from the No. 1 hog fuel boiler (ID No. ES-64-25-0290) shall be controlled by primary
and secondary multicyclones (ID Nos. CD-6445-0100 and CD-64-45-0230) operating in series with exhaust from
the secondary multicyclone controlled by three electroscrubbers (ID Nos. CD-64-60-0120, CD-64-60-0420, and CD-
64-60-0720) operating in parallel. Particulate matter emissions from the No. 2 hog fuel boiler (ID No. ES-65-25-0310)
shall be controlled by the multicyclone (ID No. CD-65-45-0100) followed by three electroscrubbers (ID Nos. CD-
65-60-0120, CD-65-60-0410, and CD-65-60-0610) operating in parallel. At least two of the three electroscrubbers
shall be in operation and at least 75% of total elements the two electroscrubbers must have voltage applied at no less
than 1 kilovolt per module each time a boiler operates. To assure compliance, the Permittee shall monitor and record
the following information once per day when a boiler is in operation:
i. the secondary voltage (in kilovolts) per module in service; and
ii. the total number of modules in service.
j. To assure compliance, the Permittee shall perform inspections and maintenance as specified in the approved Basic
Care Route or as recommended by the manufacturer. The Permittee shall, as a minimum, perform the following:
i. a monthly external visual inspection of the system ductwork, and material collection unit for leaks;
ii. a yearly internal inspection of the structural integrity of each multicyclone; and
iii. an internal inspection of each electroscrubber module at a frequency dictated by excess opacity, operational
performance trends and/or monthly external inspection and at a minimum of once every ten years. The inspection
shall include a check of the packing material and the cleaning/calibration of all associated instrumentation.
The dates and the results of inspection and maintenance, including any corrective measures taken, shall be maintained
in written or electronic format on -site and made available to an authorized representative upon request. The Permittee
shall be deemed in noncompliance with 15A NCAC 02D .0524 if the multicyclones and the electroscrubbers are not
operated and maintained as specified above.
Recordkeepine [15A NCAC 02Q .0508(f)]
k. The Permittee shall calculate and record excess emissions and monitor (COMS and CEMS) downtime on a quarterly
basis.
1. Pursuant to 40 CFR 60.7(b), the Permittee shall maintain records of the occurrence and duration of any startup,
shutdown, or malfunction in the operation of the hog fuel boilers and any malfunctions of the air pollution control
equipment.
m. The Permittee shall maintain a file of all measurements, including continuous monitoring system, monitoring device,
and performance testing measurements; all continuous monitoring system performance evaluations; all continuous
monitoring system or monitoring device calibration checks; adjustments and maintenance performed on these systems
or devices; and all other information required by 40 CFR 60 recorded in a permanent form suitable for inspection in
a manner consistent with the requirements of 40 CFR 60.7(f).
n. The Permittee shall record and maintain records of the amount and type of each fuel burned during each day and keep
fuel receipts from the supplier that certify the heating value and sulfur content of oil fired in the hog fuel boilers.
o. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0524 if the records required in Section 2.1
A.31 to 2.1 A.3.n above are not created and retained.
Reportine [15A NCAC 02Q .0508(f), 40 CFR 60.284(d), 40 CFR 60.7(c)(d)]
p. When o& No. 6 fuel oil is fired during a malfunction condition, the Permittee shall notify the NC DAQ Washington
Regional Supervisor at 252-946-6481 of this condition as soon as practically possible.
q. The Permittee shall submit an excess emissions and monitoring systems performance report and/or a summary report
meeting the requirements of 40 CFR 60.7(c) and (d) by January 30 of each calendar year for the preceding six-month
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period between July and December, and July 30 for the calendar year for the preceding six-month period between
January and June as follows:
i. Periods of excess emissions of nitrogen oxides are defined as any three-hour period during which the average
emissions (arithmetic average of three contiguous one -hour periods) exceed the applicable standards as specified
under 40 CFR 60.44.
ii. Periods of excess emissions of opacity that shall be reported are defined as any six -minute period during which the
average opacity of emissions exceeds 20 percent opacity, except that one six -minute average per hour of up to 27
percent opacity need not be reported.
iii. If the total duration of excess emissions for both quarters during the reporting period is less than 1 percent of the
total operating time for the reporting period and CMS downtime for the reporting period is less than 5 percent of the
total operating time for both quarters during the reporting period, only the summary report form shall be submitted
and the excess emission report need not be submitted unless requested by the Administrator.
iv. If the total duration of excess emissions for either quarter during the reporting period is 1 percent or greater of the
total operating time for the reporting period or the total CMS downtime for the reporting period is 5 percent or greater
of the total operating time for either quarter during the reporting period, the summary report form and the excess
emission report shall both be submitted.
4. 15A NCAC 02D .0530: Prevention of Significant Deterioration
Emissions Limits [15A NCAC 02D .0530]
a. The following Best Available Control Technology (BACT) limits shall not be exceeded:
Emission
Fuel Fired
Pollutant
Emission Limit
Control Technology
Source
No. 1 hog fuel
HVLC NCG
carbon
1,646 pounds per hour
Good combustion
boiler (ID No.
gases being
monoxide
practices
ES-64-25-0290)
fired with
wood/lignin
No. 2 hog fuel
HVLC NCG
carbon
1,433 pounds per hour
Good combustion
boiler (ID No.,
gases being
monoxide
practices
ES-64-25-0310)
fired with
wood/lignin
All fuels
PMio
0.1 pounds per million
Btu heat input
Series installation of
multicyclone and three
parallel electroscrubbers
Oil and
sulfur dioxide
0.8 pounds per million
Combination firing of oil
wood/lignin
Btu heat input
with bark/wood/lignin
residue
LVHC and
H2SO4 mist
339 pounds per
Good combustion
SOG gases
consecutive 24-hour
practices
period
LVHC and
TRS
235 pounds per
Good combustion
SOG gases
consecutive 24-hour
practices
period
Testing [15A NCAC 02Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found in
Section 3. If the results of this test are above the limit given in Section 2.1 A.4.a above, the Permittee shall be deemed
in noncompliance with 15A NCAC 02D .0530.
C. During the testing required in Section 2.1 A.3.d and e., the Permittee shall determine the pounds of PMio and sulfur
dioxide per million Btu heat input emitted from the No. 2 hog fuel boiler. To determine the PMjo emissions, the
Permittee shall conduct EPA Method 202 or EPA Method 201/201A (or other approved EPA test method for
determining PMIo emissions). The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0530 if PMIo
and/or sulfur dioxide is (are) emitted above the limit(s) specified in Section 2.1 A.4.a above.
Monitoring/Recordkeeping [15A NCAC 02Q .0508(f)]
d. The Permittee shall follow the monitoring and recordkeeping requirements in Section 2.1 A. 31 to o above.
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e. The Permittee shall keep records of the date and duration of the combustion of LVHC NCG and SOG gases in the No.
2 hog fuel boiler.
f. The Permittee shall record and maintain records of the- amounts of each fuel fired in the No. 1 hog fuel boiler each
month and the amounts of each fuel fired in the No. 2 hog fuel boiler each month and make these records available to
an authorized representative of DAQ upon request.
g. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0530 if the date and duration of LVHC NCG
and SOG combustion or the amounts of fuels fired each month are not recorded.
Reporting
h. The Permittee shall submit a semiannual summary report, acceptable to the Regional Air Quality Supervisor, of
monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding
six-month periods between July and December, and July 30 of each calendar year for the preceding six-month period
between January and June. The report shall identify all instances of deviations from the requirements of this permit
or a statement that no deviations occurred during the reporting period.
5. 15A NCAC 02Q. 0317: AVOIDANCE CONDITIONS for
15A NCAC 02D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of 15A NCAC 02D .0530 (g) for major sources and major modifications, the No.2 hog
fuel boiler (ID No. ES-65-25-0310) shall discharge into the atmosphere less than 1,771.3 tons of nitrogen oxides per
consecutive 12 month period.
Testing [15ANCAC 02Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found in
Section 3. If the results of this test are above the limit given in Section 2.1 A.5.a above, the Permittee shall be deemed
in noncompliance with 15A NCAC 02D .0530.
Monitoring/ Recordkeeping [15A NCAC 02Q .0508(f)]
c. The Permittee shall operate the CEMS, required in Section 2.1 A.3.h above, to measure and record the 1-hour average
NOx and 02 (or CO2) emission rates from the No. 2 hog fuel boiler during all periods of boiler operation including
during the firing of wood residue only.
d. Using all NOx CEMS data obtained when firing any fuel in the No. 2 hog fuel boiler, including during periods of startup,
shutdown and malfunction, the Permittee shall calculate and maintain records of the tons of NOx emitted each month
and each consecutive 12-month period. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0530
if, during any consecutive 12-month period, the NOx emissions rate exceeds the limit in Section 2.1 A.5.a above.
Reporting [15A NCAC 02Q .0508(f)]
e. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of
monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December and July 30 of each calendar year for the preceding six-month period
between January and June. The report shall contain the following:
i. the monthly nitrogen oxide emissions from the No. 2 hog fuel boiler each month for the previous 17 months and
the total consecutive 12-month nitrogen oxide emissions for each of the 12-month periods over the previous 17
months.
ii. All instances of deviations from the requirements of this permit must be clearly identified.
6. 15A NCAC 02D. 0614: COMPLIANCE ASSURANCE MONITORING
a. Per 40 CFR 64 and 15A NCAC 02D .0614, the Permittee shall comply with the following:
b. Background
i. Emission Unit(s)
(A) No. 1 Hog Fuel Boiler (ID No. ES-64-25-0290)
(B) No. 2 Hog Fuel Boiler (ID No. ES-65-25-0310)
ii. Applicable Regulation, Emission Limit, and Monitoring Requirements
(A) Regulations
15A NCAC 02D .0504, 02D .0524, and 02D .0530
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(B) Emission limits
(1) Particulate matter emissions from the equipment (ID Nos. ES-64-25-0290 and ES-65-25-0310) shall
not exceed 0.22 pounds per million Btu when firing only wood residue. [15A NCAC 02D .0504]
(2) Particulate matter emissions from the equipment (ID Nos. ES-64-25-0290 and ES-65-25-0310) shall
not exceed 0.10 pounds per million Btu when firing fuel oil only, oil and wood residue, or natural gas
and wood residue. [15A NCAC 02D .0524]
(3) Particulate matter (PM10) emissions from the equipment (ID No. ES-65-25-0310) shall not exceed 0.10
pounds per million Btu. [15A NCAC 02D .0530]
(C) Control Technology
(1) No. 1 Hog Fuel Boiler; two multiclones (ID Nos. 64-45-0100 and CD-64-45-0230) in series with
parallel electroscrubbers (II) Nos. CD-64-60-0120, CD-64-60-0420 and CD-64-60-0720).
(2) No. 2 Hog Fuel Boiler; a multiclone (ID No. CD-65-45-0100) in series with parallel
electroscrubbers (ID Nos. CD-65-60-0120, CD-65-60-0410 and CD-65-60-0610).
c. Monitoring Approach. The key elements of the monitoring approach for particulate matter, including parameters to
be monitored, parameter ranges and performance criteria are presented in the following table:
Measure
Indicator
I. Indicator
Visible emissions
Measuring approach
Visible emissions from the electroscrubbers will be monitored continuously using a
COM system on each boiler.
IL Indicator Range
An excursion is defined as visible emissions in amounts greater than 20 percent
opacity (3-hour rolling block average) excluding periods of start-up, shutdown or
malfunction. Excursions trigger an inspection, corrective action, and a reporting
requirement.
The QIP (Quality Improvement Plan) threshold is an accumulation of excursions
exceeding 1 percent duration of the operating time for a six-month reporting period.
The QIP shall be prepared within 30 days of reaching the QIP threshold and shall
contain procedures for evaluating control performance problems.
III. Performance Criteria
Data Representativeness
COMs installed in accordance with 40 CFR, Appendix B, Performance Specification
No. 1.
QA/QC Practices and Criteria
The COM systems shall be calibrated, maintained and operated according to 40 CFR
60, Appendix B, Performance Specification No.I and the requirements of 40 CFR
60, Subpart D.
Monitoring frequency
Data is collected continuously with COM systems.
Data Collection Procedures
Opacity and boiler operational status data are recorded in the mill database.
Averaging Period
3-hour rolling block average.
d. Justification
Background. The pollutant -specific emission units are two hog fuel boilers (ID Nos. ES-64-25-0290 and ES-65-25-
0310). The particulate matter emissions from each boiler are. controlled by multiclones in series with parallel
electroscrubbers.
Rationale for Selection of Performance Indicators. Visible emissions are selected as the performance indicator as a
surrogate for PM and PM10 because minimal visible emissions in the exhaust outlet indicates the electroscrubber units
are operating properly. Any significant increase in visible emissions indicates reduced performance of a (the)
electroscrubber unit(s). Therefore, the presence of visible emissions in levels exceeding or equal to 20% is used as a
performance indicator.
i. Rationale for Section of Indicator Ranges. Per supporting test data correlating emissions to opacity levels, the
facility has selected an indicator range of greater than or equal to 20% opacity, excluding startup, shutdown, or
malfunction. When an excursion occurs, corrective action will be initiated, beginning with an evaluation of the
occurrence to determine the action required to correct the situation. All excursions will be documented and
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reported. An increase in visible emissions is indicative of an increase in particulate emissions and COMS is a
well -established monitoring technique for these sources.
The selected QIP threshold for electroscmbbers visible emissions is greater than 1 percent of the operating time
in a 6-month reporting period. If the QIP threshold is exceeded in a semiannual reporting period, a QIP will be
developed and implemented.
e. Reuortine [15A NCAC 02Q .0508(f)]
The Permittee shall submit a summary report of all monitoring activities postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December and July 30 of each calendar year for
the preceding six-month period between January and June. All instances of deviations for the requirements of this
permit must be clearly identified.
7. 15A NCAC 02D .1109: CAA § 1120); Case -by -Case MACT for Boilers & Process Heaters
a. The Permittee shall comply with this CAA § 1120) standard until May 22, 2019. After May 22, 2019 the Permittee
shall comply with the applicable CAA § 112(d) standard for "National Emission Standards for Hazardous Air
Pollutants for Industrial, Commercial, and Institutional Boilers and Process Heaters."
Emission Limitations
b. Emissions from the hog fuel boilers shall not exceed the emissions limits listed below:
Pollutant
No.1 Hog Fuel Boiler
5-64-25-0290
No. 2 Hog Fuel Boiler
S-65-25-0310
Fuel Combusted
Mercury (Hg)
0.126 lb/hr
0.08671b/hr
Any
HCl Equivalent' (HCI)
274 lb/hr
1.83E+03 lb/hr
Any
- Hydrogen cyanide (HCN)
0.387 lb/hr
0.526 lb/hr
Any
Hydrogen fluoride (HF)
2.04 lb/hr
5.21 lb/hr
Any
Arsenic (As)
7.85E-03 lb/br
6.20E-03 lb/hr
Any
Beryllium (Be)
1.93E-04 lb/br
9.60E-04 lb/hr
Any
Cadmium (Cd)
1.33E-03 lb/hr
6.94E-04 lb/hr
Any
Chromium (Cr) VI
0.0167 lb/hr
0.02631b/hr
Any.
(Ph)
1.79 lb/hr
1.37 lb/hr
Any
BLead
Manganese (Mn)
7.00 lb/hr
2.42 lb/hr
Any
Nickel (Ni)
0.01981b/hr
0.0368 lb/hr
Any
Selenium (Se)
17.5 lb/hr
840 lb/hr
Any
Carbon Monoxide (CO)2
measured on a 30-day average
28 ppmvd@ 7% 02
28 ppmvd@ 7% 02
No. 6 fuel oil
3,500 ppmvd @ 3% 02
(2,718 ppmvd @7% 02)
3,500 ppmvd @ 3% 02
(2,718 ppmvd @7% 02)
Hog fuel (wood bark -
biomass)/used oil/sludge
HCl-equivalent is defined by the following equation:
E = Enc, + Ecu" (RfCacVRfCc12)
Where:
E = HC1-equivalent emission rate (in lbs/hr);
EHci = Hydrogen chloride emission rate (in lbs/hr);
Eci2 = Chlorine emission rate (in lbs/hr);
RfCHci = Reference concentration for HO (20 µl;W); and
RfC c,2 = Reference concentration for C12 (0.20 µg/m3)
The CO emissions limitation is proportional to the heat input of the particular fuels combusted.
30-day average, is calculated as follows:
Eco =128 (RFO) + 2718 (IMI/RFO + HF)
Where:
Eco = allowable CO emission rate in ppmvd, corrected to 7% 02;
RFO = heat input of residual No. 6 fuel oil; and
HF = heat input of hog fuel.
The limit in ppmvd, corrected to 7% 02, measured on a
c. The emissions limitations for a specific fuel type in Section 2.1 A.7.b above shall oy apply when the Permittee fires
at least 10% of that fuel in the boiler on a 12-month rolling average heat input basis. If the Permittee fires less than
DEQ-CFW 00073733

10% of a specific fuel in the boiler, the respective emissions limitations and the associated testing, monitoring, and
recordkeeping for that particular fuel shall not apply. However, the Permittee shall retain records of the fuels fired in
the boiler in accordance with Section 2.1 A.7.o.vii and viii below. The initial compliance date for these emission
limitations and associated testing, monitoring, recordkeeping and reporting requirements is February 23, 2014.
Control Device Monitor' i S stem Re uirements
d. Emissions from the No. 1 4d 2 hog fuel boilers (ID Nos. ES-64-25-0290 and ES-65-25-0310) shall be controlled as
specified in Section 2.1 Aabove. The Permittee shall inspect and maintain the control devices in accordance with
Section 2.1 A.3. above. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1109 if controlled
devices are not s cted and maintained.
Continuous O aci Monitoring System Re uirements -�
e. The Permittee shall install, operate, and maintain a COMS unit at a combined exhaust locati for each set of three
electroscrubbers associated with the hog fuel boilers in accordance with Sections 2.1 A.3) and and the site -specific
monitoring plan in 2.1 A.7.f below. The Permittee shall maintain the opacity of exhaust from the electroscrubbers at
less than or equal to 20 percent (6-minute average) except for one 6-minute period per hour of not more than 27
percent. The COMS data shall be maintained in a logbook (written or electronic format) and made available to an
authorized representative upon request. If any six -minute period average exceeds 20 percent opacity (except during
periods of startup, shutdown and malfunction) except for one six -minute period per hour of not more than 27 percent
opacity, the Permittee shall be deemed in noncompliance with 15A NCAC 02D .1109.
Site -Specific Monitoring Plan
f. The Permittee must develop a site -specific monitoring plan for each required continuous monitoring system. The plan
shall be submitted to the NC DAQ Stationary Source Compliance Branch (SSCB) at least 60 days before icy
performance evaluation of the CMS.
Compliance Requirements
The Permittee shall demonstrate initial compliance with each HAP emissions limit in Section 2.1 A.7.b above (except
no performance testing is required for BF and HCN) for each boiler by either of the following methods:
i. Initial and Periodic Stack Testing. Stack testing shall be performed while firing the fuel or fuel combination which
is expected to result in the highest emissions of each HAP and which is expected to contribute at least 10% of the
12-month average heat input for the boiler. The initial stack test shall be performed no later than August 21,
2014. Thereafter, each periodic stack test shall be conducted between 11 and 13 months after the previous stack
test or at a reduced frequency specified in Section 2.1 A.7.1, below. Periodic stack testing shall be performed at
the maximum normal operating load in accordance with General Condition JJ when the boiler is controlled by
only two of its three electroscrubbers for which at least 25% of the total elements have less than 1 kilovolt of
voltage applied; or
ii. Fuel Analysis. Fuel analysis shall be conducted in accordance with the site -specific fuel analysis plan dated
February 2014 or an alternate plan approved by the NC DAQ - SSCB prior to the initial compliance
demonstration. Within 180 days of the initial compliance date, the Permittee shall perform the initial fuel
analyses. Thereafter, each fuel analysis shall be conducted between 11 and 13 months after the previous analysis.
If a fuel analysis shows a potential exceedance of an emission limitation in Section 2.1 A.7.b above, the Permittee
shall conduct a follow-up stack test of the affected source within 90 days.
If the results of any stack test are above the limits given in Section 2.1 A.7.b above, the Permittee shall be deemed in
noncompliance with 15A NCAC 02D .1109.
h. The Permittee shall demonstrate initial compliance with the carbon monoxide (CO) emission limit above by testing
the Nos. 1 and 2, hog fuel boilers (ID Nos. ES-64-25-0290 and ES-65-25-0310) for CO in accordance with a testing
protocol approved by the DAQ. This testing shall be performed at the maximum normal operating load in accordance
with General Condition JJ. The initial stack test shall be performed within 180 days of the initial compliance date.
Thereafter, each stack test shall be conducted between 11 and 13 months after the previous stack test or at a reduced
frequency specified in Section 2.1 A.7.1 below.
After the initial compliance date, if the 12-month average heat input of a fuel, not accounted for during the initial
compliance demonstration, fired in a hog fuel boiler is equal to or greater than 10% for any 12-month period, the
Permittee shall conduct an initial compliance test for that boiler within 90 days following the end of the 12-month
period (unless such date is earlier than 180 days following the initial compliance date, in which case the test shall be
performed 180 days following the initial compliance date). Monitoring and recordkeeping requirements associated
with the specific fuel firing shall be implemented as soon as practicable, and in no case later than 90 days following
the end of the 12-month period.
DEQ-CFW 00073734

Fuel Analyses Plan
j. If the Permittee demonstrates compliance with this standard using one or more fuel analyses, the analyses shall be
conducted according to a DAQ approved site -specific fuel analysis plan.
k. The Permittee shall follow the site -specific fuel analysis plan dated February 2014 or develop and submit a new site -
specific fuel analysis plan to the NC DAQ — SSCB for review and approval no later than 60 days before the date that
the Permittee plans to demonstrate compliance.
Periodic Testing/Fuel Analysis Requirements
1. If the Permittee uses performance testing to demonstrate compliance with the standard, the Permittee must conduct
all applicable performance tests on an annual basis, unless it meets the requirements listed in i through iii below.
Annual performance tests, if required, must be completed between 11 and 13 months after the previous performance
test.
i. The Permittee may conduct performance tests less often for a given pollutant if the performance tests for at least
3 consecutive years show the emission rate is less than or equal to 80 percent of the allowable limit. In this case,
the Permittee need not conduct a performance test for that pollutant for the next 2 years, but must conduct a
performance test during each third year and no more than 36 months after the previous performance test.
ii. If the affected boiler or process heater continues to meet the emission limit, the Permittee may conduct
performance tests every third year, but each such performance test must be conducted no more than 36 months
after the previous performance test.
iii. If a performance test shows noncompliance with an emission limit, the Permittee must conduct annual
performance tests for that pollutant until all performance tests over a consecutive 3-year period show the emission
rate is less than or equal to 80 percent of the allowable limit.
If the results of any stack test are above the limits given in Section 2.1 A.7.b above, the Permittee shall be deemed in
noncompliance with 15A NCAC 02D .1109.
m. If the Permittee uses fuel analysis to demonstrate compliance with the standard, the Permittee must conduct a fuel
06 analysis on an annual basis for each fuel which contributes at least 10% of the 12-month average heat input of the
fuels burned in the boiler. Each fuel analysis shall be conducted between 11 and 13 months after the previous analysis.
If a fuel analysis shows a potential exceedance of an emission limitation in Section 2.1 A.7.b above, the Permittee
hall conduct a follow-up stack test of the affected source within 90 days. If the Permittee cannot conduct a follow-up
test within 90 days or if the follow-up test shows an exceedance of the emissions limitation in Section 2.1 A.7.b above,
it the Permittee shall be deemed in noncompliance with 15A NCAC 02D .1109.
If all fuel samples show a compound is below the detection limit, emissions of that compound can be considered zero.
If some samples show the compound is detected, any non -detect values shall be considered at half the detection limit.
Recordkeevina Requirement
o. The Permittee shall maintain the following in a logbook (written or electronic format) on -site and make available to
an authorized representative upon request:
i. A copy of each notification and report required by this standard, including all documentation supporting any
Notification of Compliance Status;
ii. Records of performance tests, fuel analyses, or other compliance demonstrations, and COMS performance
evaluations including calculations and supporting documentation;
Hi. Records of the COMS measurements needed to demonstrate compliance with a relevant standard (including, but
not limited to raw performance testing and evaluation measurements;
iv. A record of each period during which the COMS is malfunctioning or inoperative (including out -of -control
periods);
v. Records of all COMS calibration checks and all adjustments and maintenance performed on the COMS;
vi. Records of all monitoring data and calculated averages for applicable operating limits, such as pressure drop and
flow rate, used to demonstrate compliance with the standard;
vii. Records of monthly fuel use by each affected source, including the type(s) of fuel and amount(s) used; and
viii. If the Permittee limits the firing of a specific fuel to less than 10% on 12-month average heat input basis, he shall
create and retain the following records at least once per calendar month:
(A) Record the fuel use by each affected source, including the type(s) of fuel and amount(s) used, during the
previous calendar month; and,
(B) Calculate the 12-month average heat input from each fuel for each affected source during the previous 12-
month period.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1109 if these records are not created and
retained.
DEQ-CFW 00073735

Reporting [15A NCAC 02Q .0508(f)]
p. Notification of Compliance Status. The Permittee shall submit a Notification of Compliance Status in accordance
with 40 CFR 63.9(h)(2)(ii) within 60 days of completion of the final performance test or fuel analyses required for the
initial compliance demonstration. The Notification of Compliance Status report must contain the following
information, as applicable:
i. A description of each boiler including the fuels combusted, heat input capacity, and add -on controls used.
ii. A justification for the fuel(s) burned during the initial performance test.
iii. A summary of the results of all performance tests and calculations conducted to demonstrate initial compliance.
iv. A certification signed by the Responsible Official that the facility has met all applicable emission limits and work
practice standards.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .1109 if notification report is not submitted.
q. Semiannual Summary Report. The Permittee shall submita summary report by January 30 of each calendar year for
the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-
month period between January and June. The first report shall be required following the initial compliance date, but
no earlier than July 30, 2014. The report shall include the following:
i. The company name and address;
ii. A statement by a responsible official with that official's name, title, and signature, certifying the truth, accuracy,
and completeness of the content of the report;
iii. The date of report and beginning and ending dates of the reporting period;
iv. Identification of all periods during which the visible emissions were measured above 27% opacity and all periods
during which the visible emissions were measured above 20% opacity for more than one 6-minute period per
hour.
v. A summary of the results of any annual stack tests or fuel analyses performed during the preceding six-month
period; and
vi. A certification signed by the Responsible Official that the facility has met all applicable emission limits and work
practice standards.
DEQ-CFW 00073736