AQ_F_1800073_20180418_ST_RvwMemo (12)

DIVISION OF AIR QUALITY
Technical Services Section
April 18, 2018
MEMORANDUM
To: Bruce Ingle, Mooresville Regional Office
From: Gregg O'Neal, P.E., Stationary Source Compliance Branch (SSCB) ICU
Subject: Duke Energy Carolinas LLC
Marshall Steam Station, Facility ID 1800073, Tracking No. 2017-136ST
Terrell, Catawba County, North Carolina, Air Permit No. 03676T55
Particulate Matter(PM) Emissions Testing of Unit No. 4
Source ID No. ES-4 Controlled by CD-U4FGD
Performed on February 2, 2017 by Grace Consulting, Inc.
The report of the subject test has been reviewed. The EPA Method 5 filterable PM emissions
testing of Source ID No. ES-4 was performed February 2, 2017. The Method 5 test was
performed as approved with an elevated filter temperature maintained at 320±25°F. The test
results demonstrate compliance with the applicable limits.
Emission source and control devices: Boiler ES-4 equipped with a low NO,,concentric firing
system, separated overfire air/lowered fired low-NO),technologies(SOFA/LOFIR), and alkaline-
based fuel additive ES-4, and associated selective non-catalytic reduction system (SNCR) NO.
reduction system CD-11 c(U4SNCR), sulfur trioxide flue gas conditioning system CD-1 2, powdered
activated carbon system CD-U4ActC, electrostatic precipitator CD-13(ESPnew), and wet flue gas
desulfurization system consisting of spray tower absorber CD-U4FGD.
15A NCAC 2D .0536 Particulate Emissions From Electric Utility Boilers applies to ES-4. Permit
condition 2.1.A.4.a lists the 15A NCAC 2D .0536 PM emissions limit for ES-4 as 0.18 pounds
per million Btu (lb/mmBtu). The maximum heat input rate stated in the permit for ES-4 is 7,110
million Btu per hour(mmBtu/hr). The test average calculated heat input rate was 7,499
mmBtu/hr, The results of EPA Method 5 testing are listed in the table below.
Marshall Unit No. 4: 15A NCAC 2D .0536 Results February 2, 2017 Emission Test
Permitted Maximum Actual Heat Emission Rate Allowable
Heat Input Rate, Input Rate, Adjusted for Soot Emission Rate,
mmBtu/hr mmBtulhr Pollutant Blowing,Ib/mmBtu Ib/mmBtu Compliance
7,110 7,499 Filterable PM 1 0.002 0.18 Indicated
In accordance with the permit, if particulate emissions exceed 80% of the limit, additional
semiannual testing is required. The result is approximately 1% of the 15A NCAC 2D .0536
emissions limit.
The test results were also submitted to Dennis Igboko, SSCB-Continuous Emissions Monitoring
(CEM)group, to determine the 40 CFR 63.50 Mercury and Air Toxics Standards (MATS) CEM
Relative Response Audit(RRA). SSCB-CEM will respond directly to the facility.
Compliance was indicated with 15A NCAC 2D .0536. If there are any questions concerning this
matter, please contact me at(919) 707-8415 or gregg.oneal(a)_ncdenr.gov.
cc: Central Files, Catawba County
IBEAM Documents - 1800073