AQ_F_1800073_20080110_CEM_RptRvwLtr

6
NCDNR
North Carolina Department of Environment and Natural Resources
Division of Air Quality
Michael F. Easley, Governor William G. Ross, Jr., Secretary
B. Keith Overcash, P.E., Director
January 10. 2008
Mr. Barry E. Pulskamp
Vice President
Regulated Coal Fleet Operations
Duke Energy
PO Box 1006
Charlotte, North Carolina 28201-1006
SUBJECT: 3"d Quarter 2007 Continuous Opacity Monitoring (COM)
Excess Emissions Report(EER)
Duke Energy's Marshall Steam Station Permit#03676T42
Facility I.D. No. 1800073
Dear Mr. Pulskamp:
1. The Division of Air Quality(DAQ) has reviewed your third quarter 2007 opacity excess
emissions report (EER) dated October 24, 2007 for Duke Power's Marshall Steam Station units.
2. The EER was reviewed for compliance with the following the State Only Requirements for
good operation and maintenance(O&M) practices and the NCAC 2D .0521 (g)provisions.
3. When the EER was reviewed for compliance with good O&M practices, the data indicated the
opacity excess emissions and COM downtimes were within acceptable levels as prescribed in North
Carolina Air Permit No. 03676T42 Section 2.1 A(7).
4. When the EER was reviewed for compliance with NCAC 2D .0521 (g)requirements, Marshall
Units 1 through 4 data indicated thirteen (13)non-exempt six-minute exceedances during the quarter
and are shown in the attached Table 1. The referenced non-exempt excess emissions appear to meet
the requirements of 2D .0521(g)(1) of no more than four 6-minute periods per day or the requirements
of 2D .0521(g)(2)of no more than 0.8 percent of the total operating hours in a quarter.
5. In the EER report, Duke requested exemptions under 2D .0521(g)for Marshall Unit 3 for
eight(8) six-minute exceedances during the quarter. The exceedances for which exemptions are
requested are shown in the attached Table 2 and appear to have met the requirements of 2D .0535(c)
and/or(g). The cause and corrective action descriptions given in Table 2 are acceptable. The 8 six-
.minute exceedances are considered exempt or excused.
Technical Services Section
1641 Mail Service Center,Raleigh,North Carolina 27699-1641 One
2728 Capital Blvd.,Raleigh,North Carolina 27604 NorthCarolina
Phone: [phone]/FAX [phone]/Internet: www,ncair.org )Vaturally
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Mr. Barry E. Pulskamp
January 10, 2008
Page Two
6. As noted in previous excess emission reviews from DAQ, all opacity monitor readings in
excess of 40%(regardless of duration)would be summed and their duration compared with either the
four, 6-minute opacity standard per day or the 0.8% of the operating time as calculated in the rule
unless the facility demonstrates to the Director that the excess emissions meet the requirements of
NCAC 2D.0535 (c) and/or(g). Also, the excess emissions should cross-reference the malfunction
abatement plan(MAP) cause code definitions and corrective actions.
7. Based on the third quarter 2007 EER review, we conclude the excess emissions,for Unit 3
listed in Paragraph 5 above and in Table 2 attached, are excused pursuant to 15A NCAC 2D .0521 (g),
2D .0535 (c)(malfunctions) and/or 2D .0535 (g)(startup and shutdown). The non-exempt and
excused excesses do not prevent you from certifying compliance in your Annual Compliance
Certification(ACC)for the calendar year 2007.
8. If you have any questions with reference to this matter, please do not hesitate to contact me at
[phone].
Sincerely,
/41
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Richard R. Simpson
Environmental Engineer
cc w/attachment:
Randy Wooten- Duke Power
eke Aldridge-DAQ Central Office
Dennis Igboko-DAQ Central Office
Don Van der Vaart- DAQ Central Office
Mike Landis—DAQ MRO
Central Files: Catawba Co./Marshall
IMPAQ—Documents— 1800073

Company: Duke Energy Corporation
Facility: Marshall
Report Type: Excess Emission Report
Time Period: 3rd Quarter, 2007
Pollutant: Opacity
Date of Review: January 10, 2007
The Total% of EE
Compared to the
NCAC 2D .0521(g) No.of Six-Minute Exceedances Operating Time as
Table 1 No. of Non-Exempt That Are Excused and Meet Per NCAC 2D
Facility and Unit Six-Minute Exceedances NCAC 2D .0535(c) and/or(g) .0521 (g)(2) 0.8% Rule
Marshall 1 and 2 2 0 0.01%
Marshall 3 7 8 0.08%
Marshall 4 4 0 0.02%
Total 13 8
Note 1: A 6-minute Exceedance= 1,
EE - Excess Emissions,SU- Startup, SD- Shutdown, OLM- Offline Maintenance, MF- Malfunctions
EER request to excuse SU, SD and MF
data for rule NCAC 2D .0535 (c) and/or (g) Total Number of
during the 3rd Quarter of 2007 6-minute Excess
Table 2 Cause Code Emissions Above Duke Energy's Corrective
Facility and Unit Date Description 40% Opacity Action Description
Followed the MAP to minimize emmisions.
7/16/07 Startup 6 Adjusted air and fuel for proper
combustion. Energized ESP's as soon as
Marshall 3 practicable.
Malfunction: Boiler control upset.
This occurred when the second boiler
When the boiler upset conditions occurred;
7/16/07 feed pump was put in service. This 2 load was reduced. Adjustments were made
caused a swing in the feedwater flow
resulting in a swing in the fuel and air to the control system. System stabilized.
flows.
TOTAL= 8