Stack Test Protocol Letter
July 27, 2006

Wayne Gravely
Troy Lumber Company
PO Box 748
Troy, NC 27371

Subject: Troy Lumber Company, Troy, Montgomery County, North Carolina; Facility ID 62/00029; Permit No. 02330T14; Protocol for Filterable and Condensible Particulate Emissions Testing of Boiler No. 1; Proposed Test Date: August 8, 2006

Dear Mr. Gravely:

The North Carolina Division of Air Quality has reviewed the protocol submittal forms (PSF) for the particulate emissions testing of the wood-fired Boiler No. 1 (ID No. ES-B1). Boiler No. 1 has two multicyclones for control of particulate matter (PM). The testing will be performed in order to demonstrate compliance with 15A NCAC 2D .0504 Particulates From Woodburning Indirect Heat Exchangers. The proposed testing is acceptable only as discussed below.

Analytical Testing Consultants, Inc. has proposed EPA Method 1, 2, 3A, 4, 5 and 202 to determine the filterable and condensible particulate matter emissions at the multicyclone exhaust. ATC stated 12 points would be sampled over three, 60-minute test runs. The only deviation from the applicable methods involves EPA Method 3A. Instead of an Orsat analyzer, ATC proposes using a Fyrite to measure oxygen (O2) and carbon dioxide (CO2). This deviation is acceptable. In addition, a determination of cyclonic flow must be performed at the sampling location prior to sampling per EPA Method 1.

The PSF proposed operating at a heat input rate between 40.5 and 44.5 million BTU per hour (mmBtu/hr) during emission testing. This is 90% or greater than the maximum permitted heat input rate of 44.5 mmBtu/hr. This is an acceptable processing rate.

Approval of the sampling protocols does not exempt the tester from the minimum requirements of the test methods. Any deviations from the methods remain subject to approval by DAQ. If you have any questions regarding the results of this review, please contact me at (919) 715-4207 or at


Paula M. Hemmer