AQ_F_1800073_20010520_CEM_GenCorr (2)

North Carolina
Department of Environment and Natural Resources i
Division of Air quality
Technical Services Section i
Michael F.Easley, Governor NCDENR
William G.Ross,Jr., Secretary
Alan W. Klimek,P.E.,Director
May 20, 2001
Mr. Gregg Worley - Chief
Operating Source Section
Air and Radiation Technology Branch
U.S. Environmental Protection Agency
The Atlantic Federal Center, 61 Forsyth Street
Atlanta, Georgia 30303
SUBJECT: Part 75 Audit Summary Report
Duke Power's Marshall Steam Plant, Unit 3
Dear Ms. Pierce:
. Attached is the Part 75 Level II audit report for Duke Power's Marshall Steam Plant,
Unit 3 that I conducted on February 19, 2001. The audit addressed all aspects of a Level II
audit including: Inspections of the CEMS, Records review and RATA observation.
In general, no compliance problems involving any regulatory requirements of Part 75
were observed. The Quality Assurance manual appears complete and fully implemented.
The maintenance logs as well as emission data records including missing data periods also
appear complete. These records reflect correctly the daily activities on the CEM systems.
If you have any questions regarding this audit,please call me at
[phone].
Sincerely,
Richard R. Simpson
Environmental Engineer
Attachment
cc: Ms. Kim Nguyen, EPA Clean Air Market Division
Mr. Steven Isenhour, Duke Power
Designated Representative,MRO
Central Files,Catawba County
Mike Aldridge,NCDENR-w/o attachment
1641 Mail Service Center, Raleigh, North Carolina 27699-1641
2728 Capital Blvd., Suite 166, Raleigh, NC 27604
Phone: [phone] \ FAX: [phone] \ Internet:http://da0,state.nc.us/
AN EQUAL OPPORTUNITY \ AFFIRMATIVE ACTION EMPLOYER— 50%RECYCLED /10%POST CONSUMER PAPER

Part 75 Audit Report
APPENDIX A
Duke Power: Marshall Steam Station
Unit #3

Appendix A-1 (Section 2.2)
Pre-Audit Data:
Audit Date: February 19,2001
Company Name: Duke Power
Plant Name: Marshall Steam Station CRIS Code: 2727 Unit ID: 3
Company Contact: Steven Isenhour Plant Contact: Cam Ritchie
Phone Number: 704-373-3230 Phone Number: 828-478-2121
Address: Energy Center P.O. Box 1006 Address: 8320 East N.C. 150
Charlotte, N.C.28201-1006 Terrell, N.C. 28682
Inspector Name: Richard Simpson
Phone Number: 919-715-0726
Attendee: Randy Wooten
Phone Number: 704-382-6730
Representing: Duke Power Environ.
Main fuel type: Coal Gas Oil
Back-up/emergency fuel type: Coal Gas Oil
Normal load: High Mid Low
SO, (ppm) NO. (ppm) CO, (ppm) Opacity(%)
Typical emission 509.2 228 12.8 14.2
Emission limit if applicable

Appendix A-3 (Section 2.7)
Pre-Audit Meeting Check List
X Purpose of inspection
X Inspection agenda
X Specific areas to be observed
X Safety requirements
X Records to be reviewed and copying needed
X Facility's policies on photography and confidentiality
X Inspection and audit techniques to be used
_NA System's response time
X "Hands-off" policy and the need for a CEMS technician
X Plant point of contact for different parts of the audit

Appendix A-4 (Section 3)
CEMS Inspection
Probe and umbilical line (Section 3.1)
YES NO Comments
The probe in the same location as X
when the unit was certified/recertified
Any unusual event(s)that required an X
explanation from the source
Conditioning and dilution air systems f Section 3.2)
YES NO Comments
Chemical used to remove potential X Desicates and H2O.
contaminants changed according to a
prescribed schedule
Filter changed according to schedule X Changed on a quarterly basis.
Analyzer(Section 3.3)
YES NO Comments
System configured as it was when it X
received certification/recertification
Any modification to the systems that X
may affected its performance
Preventative Maintenance performed X
according to schedule
Major component replaced since X
certification/recertification
Span setting in the proper position X
Rotameter (sample flow rate) X Setting at 5 liter/min. If out of range of 3-8,
settings agreed with QA plan then alarm sounds. Also referenced in the
Quality Assurance Manual(QA).
Analyzer Comments
S02 I.D. #301 TECO Serial No. 43H-45221-273
NO I.D.#302 TECO Serial No. 42D-46848-276
Diluent
C0)02 I.D. #303 TECO Serial No. 41 H-46117-275
Flow I.D. #304 Panametrics CEM68 Serial No. 170
Opacity I.D. #305 United Sciences 500C Serial No. 0993672

Appendix A- 4 (Section 3) Page 2
CEMS Inspection (Cont.)
Accessories (Section 3.4)
Gas Cylinder Cert. Type of gas Cylinder Expiration Certificate on
No. Conc. (SRM/CRM/GMIS/Protocol) Pressure Date file
NOx CC52136 819.33 Triblend High gas 800 3/9/01 Yes
S02 " " 1460 " " " " " " " "
CO2 It It 1 6.6% i{ „ f{ „ f{ „ i{ It
NOx CC117317 556.42 Triblend Bias Gas 600 11/9/01 Yes
S02 It " 963 " ,1 iL 11 ff „ " It
CO2 It It 11.2% «
O2 CC59907 12.6% Mid Gas 600 10/22/01 Yes
Regulators:
Are correct type of regulators used? YES NO
Are the regulators damaged? YES NO
Data Acquisition and Handling System (Section 3.5)
How is the daily calibration recorded?
Automatically through DAHS.
How are the linearity, RATA tests results recorded?
Automatically on DAHS.
When and how frequent does the source back up the data?
Twice per week with backup tape and electronically.
YES NO Comments or explanation
Are all pertinent data recorded? X
Is any data input by hand? If so, does X
DAHS data agree with hard copy data?
Can the source display last missing X
dataperiod?
I

Appendix A-5 (Section 4.1)
Quality Assurance Records Review
Does the source have a written CEMS QA Plan? YES NO
Did the sources have difficulty locating it? YES NO
Date of the most recent update: 4/1/00- Revision 4
Comments:
None
Do the following items appear in the CEMS QA Plan?:
YES NO Comments or explanation
Calibration error test X In section 6.3 pg. 21 of QA Manual.
procedures
Linearity check procedures X In section 7.1 pg. 26 of QA Manual and Appendix B.
Calibration adjustment X In section 6.3 pg.24 of QA Manual.
procedures
Linearity adjustment X In section 7.1 pg.26 and Appendix B of QA Manual.
procedures
RATA procedures X In section 7.2 pg.29 of QA Manual.
Corrective maintenance RATA X In section 7.2 pg.29 and section 7.2.8 of QA Manual.
procedures
Preventive Maintenance X In section 8 pg.30 of QA Manual.
procedures
Spare parts list NA
Troubleshooting matrix X In Figure 8-10 pg.51 of QA Manual.
Record keeping and reporting X In section 9 pg. 52 of QA Manual.
Add-on emission control(s) X Existing ESP.
information (if applicable)

Appendix A-6 (Section 4.2)
Maintenance Log review
Comments:
None
Do the following items appear in the Maintenance Log?:
being followed Comments or explanation
daily preventive X In section 8.3 pg. 32 &figure 8-2 pg. 34 of QA Manual.
maintenance Last performed on 2/19/01.
weekly preventive X In section 8.3 pg. 32 of QA Manual and Figure 8 pg. 35. Last
maintenance performed on 2/19/01.
monthly preventive X NA
maintenance
quarterly preventive X In section 8.3 pg. 32 of QA Manual and Figure 8-5 pg. 37.
maintenance Last performed on 2/8/01.
semi-annual preventive X In section 8.3 pg. 32 & 37 of OA Manual and Figure 8-5
maintenance pg.38. Last performed on 7/19/01.
annual preventive X In section 8.3 pg. 32 of QA Manual and Figure 8-5 pg. 39.
maintenance Last performed on 2/23/00.
I I ( I
5
Amount of maintenance log reviewed: 90 (# of days)
Indicate if the following items appeared in the Maintenance Log:
YES NO N/A Comments
Recurring failures or malfunctions X
Repeated adjustments to the zero X
and/or span
Parts replacement and/or adjustment X Annually rebuild pumps as preventive
maintenance.
Analyzer, DAHS replacement X
Performance evaluations, stack tests X
Corrective actions for malfunctions, X
calibrations, etc.
Pre-RATA (adjustments before X
RATA)
Reported monitor availability X Availability 99%.
1 I

Appendix A-7 (Section 4.3)
Emissions Data Records Review
Amount of data reviewed: 90 (#of days) from:_1/01/01_to: 2/19/01
YES NO Comment
Reported emission values were X NOx on 2/6/01 at 14:00.
correctly adjusted Code 13 Analyzer failure.
Daily calibrations conducted X
Linearity test conducted as required X
RATA/Bias test conducted as X
required
Is the source in compliance with the Not Applicable.
NOx emission limit if applicable?
Missing data period(s) identified in X Value was verified.
the quarterly report
Missing period(s) agreed with the X
quarterly report data
Correct values used during missing X
data period(s)
Data missing period agrees with the X Value was verified.
maintenance log data
Method of deterrnination code is X
correctly applied
Event(s) in the maintenance log X
book reflected in the quarterly
report
Any unusual event(s) required X
explanation from the source
If a back up monitor was used, is NA- No backup.
there an explanation as to why the
primary monitor wasn't used?

Appendix A-8 (Section 5)
Daily Calibration Summary
Plant: Duke Power-Marshall Steam Station State: NC ORIS Code: 2727
Common Stack or NADB Boiler ID(s):_Unit 3
If offline calibrations are done,was the offline-online test passed? NA
System/Component ID: 301 _ Parameter Monitored: S02 Span Value,S: 1700
CE Results
Date/time Calibration Value,R CEM Response,A
(ppm,%, SCFH or fpm) (ppm,%,SCFH or fpm) (%of span) R-A
(ppm,%,SCFH or fpm)
Zero level check 2/19/01 253 252.2 0.0
Upscale check 7:05 AM 1440 1453.0 0.8
System/Component ID: 302 _ Parameter Monitored:_ NOx Span Value,S: 600
CE Results
Date/time Calibration Value, R CEM Response,A
(ppm,%, SCFH or fpm) (ppm,%,SCFH or fpm) (%of span) R-A
(ppm,%,SCFH or fpm)
Zero level check 2/19/01 91.7 91.3 0.1
Upscale check 7:05 AM 523.0 527.0 0.7
System/Component ID: 303 Parameter Monitored: CO2 Span Value,S: 20
CE Results
Date/time Calibration Value, R CEM Response,A
(ppm,%, SCFH or fpm) (ppm,%, SCFH or fpm) (%of span) R-A
(ppm,%,SCFH or fpm)
Zero level check 2/19/01 3.0 3.2 0.2
System/Component ID: Parameter Monitored: Span Value,S:
CE Results
Date/time Calibration Value, R CEM Response,A
(ppm,%, SCFH or fpm) (ppm,%, SCFH or fpm) (%of span) R-A
(ppm,%,SCFH or fpm)
Zero level check
Upscale check
For NOx and SO.:
CE = IN - Al x 100
S
For CO2 and 02:
CE = IR - AI
where: CE = Calibration Error(%of span) A = Actual CEMS Response
R = Reference Gas Value S =CEMS Span Value

Appendix A-10 (Section 6.2)
Page of
Gas CEMS RATA Performance
Plant:Duke Power:Marshall Steam Station State: NC ORIS Code:2727
Common Stack or NADB Boiler ID#(s): Unit 3
System ID: 301--304 Parameter Monitored:S02/NOx/CO2/Flow
GENERAL TEST INFORMATION REQUIRED OPTIONAL
INFORMATION INFORMATION
Test Date 2/19/01
Was a calibration error check conducted on the source CEMS prior YES
to initiating the RATA?
Were the check results acceptable? YES
Document the zero and upscale calibration error results for the day: ZERO:
UPSCALE:
Were any pre RATA adjustments made? NO
Is the reference measurement system set-up consistentwith the YES
system described within the test protocol?
Verify calibration gas concentrations and certifications: YES
Optional RM sampling system leak check conducted? YES
Acceptable pre-test linearity check? YES
Three-point RM sample traverse conducted during test runs? NO
Traverse point locations(measured in reference to stack wall(ft.,in.)
or as a%of diameter): (1)80.75"
(2)112.25"
(3)143.75"
RM calibration checks conducted between test runs? YES
Drift checks acceptable for observed test runs? YES
Sampling system bias checks acceptable for observed test runs? YES
No prohibited maintenance or adjustments made during the test? No
(Part 75,App.A,Sec. 6.5)
Was the primary fuel combusted during test? (Part 75,App.A,Sec. YES,Coal
6.5)
Total number of RATA test runs observed: 5
Data reduction activities performed on-site by the test contractor? YES
Reference measurement data (corrected for drift and bias)collected YES
by the observer? (see RATA Field Data Forms)
Relative accuracy results calculated on-site? YES
Plant operated during RATA outlined in test protocol? YES
Source CEMS concentration data reported by the DAHS on a wet or Wet
dry basis?
Relative Accuracy Result
Reviewer Name: Richard Simpson Agency:NCDENR-DAQ
Signature: Date Review Completed:2/19/01

Appendix A-11 (Section 6.2)
Page of
Flow Rate Monitor RATA Performance
Plant::Duke Power: Marshall Steam Station State: NC ORIS Code:2727
Common Stack or NADB Boiler ID(s): Unit 3
System ID: 304 Peaking/Bypass Unit NA
GENERAL TEST INFORMATION REQUIRED OPTIONAL
INFORMATION INFORMATION
Were any pre RATA adjustments made? NO
Were any adjustments made to the monitor during the test? NO
RM pitot type(i.e.,Type S,standard,etc.): I S-TYPE
Differential pressure readout device(i.e.,manometer): Manometer
Is the reference measurement system set-up consistent with YES
the system described within the test protocol?
How is moisture determined? METHOD 4
How often is moisture determined? EVERY RUN
Was an optional pre-test pitot system leak check conducted? ) YES
Cross-sectional area: I -
--
Numberof RM traverse points: 12
RM traverse points in accordance with EPA Method 1? ) YES
RM results calculated on-site by the test contractor? YES
RM and flow rate monitor data corrected to wet standard I YES
conditions?
Relative accuracy result calculated on-site? YES
LOAD-LEVEL SPECIFIC INFORMATION Low Load Normal Load High Load
Test Date 2/19/01
Boiler unit load level(MW): 690
Cyclonic flow checked? NA
Post-test pitot system leak check conducted?(mandatory) YES
Post-test Method 4 leak check conducted? YES
Number of RM test runs observed: 5
Relative Accuracy Result See
comments.
COMMENTS:
Initial final results:S02-1.0%,NOx-1.9%,CO2-0.6%,
Flow(high)-1.8%
Reviewer Name: Rich rd Simpson Agency: NCDENR-DAQ
Signature: � Date Review Completed: 2/19/01