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Jaysen Schock
Cargill Incorporated
1754 River Road
Fayetteville, NC 28312
Subject: Test Protocol for Hydrogen Chloride (HCl) and Chlorine (Cl) Emissions on One Boiler; Cargill Incorporated, Fayetteville, Cumberland County, NC; Air Permit No. 03903T29, Facility ID: 06/26/00016; Proposed Test Date: July 28, 2006
Dear Mr. Schock:
The protocol submittal form (PSF) prepared by Analytical Testing Consultants, Inc. has been reviewed for the hydrogen chloride (HCl) and chlorine (Cl) emissions testing and deemed acceptable. The test is being conducted to demonstrate compliance with Air Permit No. 03903T29 specific conditions and limitations 2.1 E.6. The proposed test methods for this test consist of EPA Methods 1 through 4 and 26A.
The emission source to be tested consists of one coal/No. 6 fuel oil/No. 2 fuel oil/natural gas/landfill gas/refinery skimmings/reducer oil-fired boiler (ID No. ES22). The control device is a bagfilter (ID No. BF1).
The subject boiler is subject to 40 CFR Part 63 Subpart DDDDD National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process Heaters.
The testing should be conducted in strict accordance with the requirements of EPA Methods 1 through 4 and 26A. The only deviation from the applicable methods involves the carbon dioxide (CO2) being measured with a fyrite instead of using EPA Method 3A. This is acceptable. Please insure all relevant process/operating data is included and summarized in the test report.
Approval of the protocol does not exempt the tester in any way, from the minimum requirements of the applicable methods. Any other modifications to the applicable test methods remain subject to approval by the Division of Air Quality. If you have any questions, please feel free to contact me at David.B.Hughes@ncmail.net or (919) 715-2966.
Sincerely,
David B. Hughes
Environmental Engineer