AQ_F_0900043_20100608_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Elizabethtown Power,LLC
NC Facility ID 0900043
Inspection Report County/FIPS: Bladen/017
Compliance-
wn Power,LLC _ __ _ Inspection Date 06/08/2010
Elizabethtown
3100 West Po Street Inspector's Name Jim Moser
Elizabethtown,NC 28337 Operating Status Operating
Elizabethtown,
bet34dhto n,NC8086m Long: 78d 38.4900m Compliance Code Compliance inspection
SIC: 4911 /Electric Services Action Code Res
ult
NAILS: 221112/Fossil Fuel Electric Power Generation On-Site Inspection Result Compliance
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 05455/T15
issued 5/18/2010
Michael Wood, Trisha Elizondo Trisha Elizondo Expires 3/31/2013
Environmental Specialist 2705 Bee Caves Rd, 2705 Bee Caves Rd, Classification Title V
PO Box 809 Suite 340 Suite 340 Permit Status Active
1838 NC`I1 &903 Austin,TX 78746 Austin,TX 78746
Kehansville,NC 28349 [phone] [phone]
[phone] office
[phone] cell
Inspector'sSignature: Comments:
Date of Signature: 10d/�
MACT/GACT and NSPS Requirements: The facility was notified for probable applicability of
NESHAP 40 CFR 63 Subpart ZZZZ for the emergency fire pump motor.They are checking the motor
nameplate data to verify the applicable conditions. They will notify us of their findings. This has been
pink sheeted for future reference.
(1) DIRECTIONS TO SITE:
Take Hwy 87 South toward Elizabethtown. Elizabethtown Power, LLC is on the left side of the road,
approximately 1 mile prior to entering Elizabethtown on 87-Business.
(2) FACILITY DESCRIPTION:
Elizabethtown Power, LLC is a coal-fired steam powered electric generation facility located in
Elizabethtown, Bladen County, North Carolina. Their equipment is shutdown and has been prepared
for long term storage.
(3) INSPECTION SUMMARY:
I met with Mike Wood, Facility Contact for the Elizabethtown Energy facility. Also in attendance for
the meeting was Randy Coates, Plant Manager and Mike Houston,WWTP Technician. The plants
are staffed with a minimal crew of personnel. Both Elizabethtown and Lumberton Energy plants have
been shutdown and mothballed for long term storage. The facility operated briefly in the first quarter
of calendar year 2009. Rick and Randy provided all the maintenance and monitoring reporting that 1
required and gave me a state of the business report. Their business previously had been to generate
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steam for the nearby Alamac plant and to serve as a standby source for Progress Energy (formerly
CP&L). Alamac purchased 2 new boilers and began producing their own steam, It is very uncertain
when the facilities will operate again. The new management company,Coastal Carolina Clean
Power, is trying to market the facility as a source of electric energy produced by sustainable
resources They do-notanticinate restarting the boilers on coal and do not expect to operate the
MOBOTEC lime injection and_R_OFA burner_fm m ¢ ansv
1l1e Hid,it
-using w wan ,b m a
constructed exactly alike.They anticipate restart of Elizabethtown or Lumberton facilities will be with
wood firing of the boilers. Very obviously it will require a significant permit modification to be able to
restart this facility.
Randy provided all of the required documentation for demonstrating compliance to the permit
stipulations. They are continuing to track all maintenance work on a Computerized Maintenance
Management System. The system is also being used as a calendar reminder by issuing a work order
to Randy to audit all I&M responsibilities outlined in the permit, quarterly, to assure that they are being
completed.
This facility is currently permitted to combust the following fuels in the two (2)electric steam-
generating boilers: coal/natural gas/No. 2 and No. 4 fuel oil/tire derived fuel/pelletized paper
fuel/flyash briquette. The facility is also permitted to burn wastewater basin sludge/evaporation pit
sludge, spent activated carbon from the water treatment process, and boiler cleaning solution as well
as "regenerated"spent cation/anion resins, and boiler cleaning solution. They have burned only coal
this year.
I saw the appropriate logbooks and the Preventive Maintenance work orders associated with the
permit requirements.
(4) PERMITTED EMISSION SOURCES:
The following table contains a summary of all permitted emission sources and associated air pollution control devices
ands ` urtenances:
Emission Emission Source Description Control Control Device Description
Source Device ID
two coal/NG/No. 2 and No. 4 fuel oil/tire
ES-1A derived fuel/pelletized paper fuel/flyash CD-1A two bagfilters (16,800 square feet
and briquette-fired steam, electric generating, and of filter area)
ES-1 B boilers(215 MBtu/hour heat input each) CD-1 B
ES-2A two coal bunkers CD-2A two bagfilters (64 square feet of
and and filter area,each)
ES--226 CD-2B
E one fly ash silo with wet slurry pug mill for CD-3one silo binvent(100 square feet
unloadingof filter area
ES-4 one bottom ash silo with a retractable bulk CD-4 one silo binvent(100 square feet
unloading spout and enclosed vent return of filter area
two ash system vacuum transport pumps CD-5E one simple cyclone (42 inches in
diameter) the bottom ash silo
CD-5D one bagfilter(528 square feet of
ES-5A filter area)on the fly ash silo
and CD-5C one simple cyclone (42 inches in
ES-5B diameter) I on the fly ash silo
CD-5A two in-line filters (one per pump)
and
CD-5 B
ES-6 coal unloading/storage and transfer Wetsup wet suppression/chemical binder
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I
*Boiler Plate Information:
Boiler Manufacturer Year Serial No. Design Pressure
ES-lA Foster Wheeler 1985 6705 1750 psig
ES-1 B Foster Wheeler 1985 6708 1750 psig
Oetails of Equipment Description and Operation
Ash loading-Two ash silos are used to store the two different ashes that are produced as a byproduct of
the combustion process. Bottom ash is collected from the boiler grate and pneumatically conveyed by
vacuum pumps in the ash transport system to the bottom ash silo. Bottom ash is collected in the silo by
separation from the air stream using two cyclones and a bagfilter. (the primary collector on the bottom
ash silo and the primary collector and bagfilter on the fly ash silo). Fly ash is collected from the bagfilter
installed on each boiler and pneumatically conveyed by the vacuum pumps in the ash transport system to
the fly ash silo. Fly ash is collected in the fly ash silo by separation from the air stream using the primary
collector and bagfilter on the fly ash silo. A final cartridge type in-line filter further controls the particulate
before each of the two vacuum pumps. Particulate emissions from the filling of each silo are controlled by
a fabric filter binvent located on each silo. The pumps in the ash transport system create a vacuum from
the bagfilter hopper to the silo. The cyclones remove ash from the air is like a vacuum cleaner.
Wet/Chemical Suppression - The wet suppression system consists of PVC pipe with nozzles. Operates
when unloading only. At the time of the inspection, not unloading.The chemical binder system is
installed around the active and inactive coal piles. This system is used only when needed which is
usually during a drought. There are two spray nozzles installed around the coal piles. The facility has no
dust complaints.
Permitted Items Included As Insignificant Activities:
Emission Source Description Insignificant Regulation
one diesel fired 340 hp emergency fire pump 15A NCAC 2Q .0503(8)
one diesel fuel oil storage tank 15A NCAC 2Q .0503(8)
one fire pump fuel oil storage tank 15A NCAC 2Q .0503(8)
one solvent parts cleaner 15A NCAC 2Q .0503(8)
one turbine tube oil tank vent 15A NCAC 2Q.0503(8)
one cooling tower 15A NCAC 2Q .0503(8)
*tire shredders 15A NCAC 2Q .0503(8)
These Lire shredders have not been installed yet. The facility has
no immediate plan for installing these tire shredders however
they would like to keep them on their permit)
(5) SPECIFIC PERMIT CONDITIONS:
15A NCAC 2D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS
Emissions of particulate matter from the combustion of fuel discharged from these sources into the
atmosphere shall not exceed 0.23 pounds per million Btu heat input.
Monitoring and Recordkeeping: Particulate matter emissions from each boiler shall be controlled by a
bagfilter. To assure compliance, the Permittee shall perform inspections and maintenance as
recommended by the manufacturer.
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• annual internal inspection of the bagfilters for structural and fabric filter integrity (minimum
requirement)
• install, operate, and maintain a pressure drop indicator on each bagfilter (the pressure drop
across each'bagfilter shall not exceed 10 inches of water)
;,arUa SemiannuaLsummaFvreoorts
In Compliance Reports have been submitted on time
Inspection Observations: Inspections and maintenance completed as required. Recorded pressure
drop across bagfilters less than 10 inches.
In Compliance Required Loqbooks indicated compliance.
15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
Emissions of sulfur dioxide from these sources shall not exceed 2.3 pounds per million Btu heat input.
MonitoringlRecordkeeping' The Permittee shall assure compliance with 15A NCAC 2D .0516 by
determining sulfur dioxide emissions in pounds per million Btu using a continuous emissions monitoring
(CEM)system meeting the requirements of 40 CFR Part 75.
Reporting - Quarterly
The Permittee shall submit the continuous emissions monitoring data showing the 24-hour daily
block values in pounds per million Btu for each 24-hour daily block averaging period during the
reporting period. All instances of deviations from the requirements of this permit must be clearly
identified.
• The Permittee shall submit sulfur dioxide CEM systems monitor downtime reports, including
monitor availability values (as calculated for 40 CFR Part 75) for the last hour of the reporting
period.
Inspection Observations:
In Compliance CEMs reports indicate compliance Reports have been submitted
On time.
15A NCAC 2D .0521: .CONTROL OF VISIBLE EMISSIONS
Visible emissions from the boilers and all other equipment shall not be more than 20 percent opacity
when averaged over a six-minute period.
Monitoring and Recorcikeeping: Daily VE observations to be recorded in logbook (indicating normal,
recommend including a description of normal in the logbook) for the boilers, weekly observations for all
other equipment
Reporting: Semiannual summary reports for all equipment
Inspection Observations:
In Compliance No visible emissions were noted during my visit.(The facility was
not operating) The facility considers zero visible emissions for these sources to
be normal Logbook was being maintained Reports have been submitted on
time:
15A NCAC 2D .0501(e): COMPLIANCE WITH NATIONAL AMBIENT AIR QUALITY STANDARDS
Particulate matter emissions from boilers shall not exceed 6.02 pounds per hour per boiler.
Sulfur dioxide emissions from boilers shall not exceed 322.5 pounds per hour per boiler.
Nitrogen oxide emissions from boilers shall not exceed 141.9 pounds per hour per boiler.
Carbon monoxide emissions from boilers shall not exceed 120.4 pounds per hour per boiler.
The maximum sulfur content of any coal received and burned- 1.0 percent by weight.
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In Compliance Based on CEMS and COMS reports submitted semi-annually
Mon itoringlRecordkeepinglReporting -semiannual reporting of the following
The Permittee shall follow the monitoring, recordkeeping, and reporting requirements for the ba9filters.
r=cnntant=o = p.-( ae may-using-coa"upplier-certification per total
menr received The anal supplier cartificationshall- corded in a logbook (written or electronic -_ --
format) per total shipment and include the name of the coal supplier; the maximum sulfur content of the
coal received per total shipment; a statement verifying that the methods used to determine the maximum
sulfur content of the coal was in accordance with the following:
A sampling--ASTM Method D 2234;
B. preparation--ASTM Method D 2013;
C. gross calorific value (Btu)--ASTM Method D-5865
D. moisture content--ASTM Method D 3173; and
E. sulfur content--ASTM Method D 3177 or ASTM Method D 4239.
Mon itoringlRecordkeepindlReeorting -quarterly reporting of the following
She Permittee shall assure compliance with sulfur dioxide and nitrogen dioxide emission standards by
determining sulfur dioxide and nitrogen oxide emissions in pounds per hour using a continuous emissions
monitoring (CEM)system meeting the requirements of 40 CFR Part 75.
The Permittee shall submit the continuous emissions monitoring data showing the 24-hour daily block
values in pounds per hour for each 24-hour daily block averaging period during the reporting period on a
quarterly basis.
The Permittee shall submit sulfur dioxide and nitrogen oxide CEM systems monitor downtime reports,
including monitor availability values (as calculated for 40 CFR Part 75) for the last hour of the reporting
period.
Inspection Observations:
In Compliance CEMs reports indicate compliance.
Alternative OLeratnxt Scenano for Emissions of_Sulfur Dioxide 0niv While
operating ROTAA4IX rotating mixlnc s. sty ln SO• reduction technology with
(--g n i -1--y— ) - —`
lime/limestone
as Sulfur dioxide emissions from each boiler (ID Nos. ES-1A and 113) shall not exceed 322.5
pounds per hour per boiler. [15A NCAC 2D .0501(e)]
Testing (15A NCAC 2D .0501(c)]
bb. If emissions testing is required, the testing shall be performed in accordance with 15A
NCAC 2D .0501(c) and General Condition JJ found in Section 3. If the results of this test are
above any limit given in Section 2.1 A. 4. aa. above, the Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0501(e).
Monitorina/Recordkeeoing [15A NCAC 2Q .0508(f)]
cc. The Permittee shall assure compliance with 2.1 A. 4.aa. above by determining sulfur dioxide
emissions in pounds per hour using a continuous emissions monitoring (CEM) system meeting
the requirements of 40 CFR Part 75 except that unbiased values may be used (missing data shall
be filled in accordance with 40 CFR Part 75, except that the lookback periods per 40 CFR 75.33
(Tables 1 and 2) shall consists of the available data up to the appropriate quality-assured hours.
Also, the replacement procedures for monitor data availability between 80 and 90 percent may be
used at values below 80 percent). Compliance with emission sulfur dioxide standards shall be
determined by averaging hourly continuous emission monitoring system values over a 24-hour
block period beginning at midnight. To compute the 24-hour block average, the average hourly
values (missing data shall be filled in accordance with 40 CFR Part 75, except that the lookback
periods per 40 CFR 75.33 (Tables 1 and 2) shall consists of the available data up to the
5

appropriate quality-assured hours: Also, the replacement procedures for monitor data availability
between 80 and 90 percent may be used at values below 80 percent) shall be summed, and the
sum shall be divided by 24. The minimum number of data points, equally spaced, required to
determine a valid hour value shall be determined by 40 CFR Part 75. if any 24-hour block
he-limits- r-2.1- a aa. above or the records are not maintained, the
Permittee shall tie-deemed nnoncomplianmwith-lOA NCAC213 .0501 a__
In Compliance CEMs reports indicate compliance.
Reporting [15A NCAC 2Q .0508 (f)]
dd. The Permittee shall submit the continuous emissions monitoring data showing the 24-hour daily
block values in pounds per hour for sulfur dioxide emissions for each 24-hour daily block
averaging period during the reporting period no later than January 30 of each calendar year for
the preceding three-month period between October and December, April 30 of each calendar
year for the preceding three-month period between January and March, July 30 of each calendar
year for the preceding three-month period between April and June, and October 30 of each
calendar year for the preceding three-month period between July and September. All instances
of deviations from the requirements of this permit must be clearly identified.
In Compliance CEMs reports indicate compliance.
ee. CEMs Monitor Availability - The Permittee shall submit sulfur dioxide CEM system monitor
downtime reports, including monitor availability values (as calculated for 40 CFR Part 75)for the
last hour of the reporting period, no later than January 30 of each calendar year for the preceding
three-month period between October and December, April 30 of each calendar year for the
preceding three-month period between January and March, July 30 of each calendar year for the
preceding three-month period between April and June, and October 30 of each calendar year for
the preceding three-month period between July and September.
In Compliance CEMs reports indicate compliance.
15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
Particulate matter emissions from each boiler shall not exceed 0.028 pounds per million Btu heat input
Sulfur dioxide emissions from each boiler shall not exceed 1.50 pounds per million Btu heat input.
Nitrogen oxide emissions from each boiler shall not exceed 0.66 pounds per million Btu heat input
Carbon monoxide emissions from each boiler shall not exceed 0.56 pounds per million Btu heat input.
The maximum sulfur content of any coal received and burned in the boilers shall not exceed 1.0 percent
by weight
In Compliance based on CEMS and Coms Reporting
Monitorina/Recordloo I!ig/Reporting -semiannual reporting of the following
The Permittee shall follow the monitoring, recordkeeping, and reporting requirements for the bagfilters.
The Permittee shall monitor the sulfur content of the coal by using coal supplier certification per total
shipment received. The coal supplier certification shall be recorded in a logbook (written or electronic
format) per total shipment and include the name of the coal supplier; the maximum sulfur content of the
coal received per total shipment; a statement verifying that the methods used to determine the maximum
sulfur content of the coal was in accordance with the following:
A. sampling --ASTM Method D 2234;
B. preparation--ASTM Method D 2013;
C. gross calorific value (Btu)--ASTM Method D-5865
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D. moisture content--ASTM Method D 3173; and
F. sulfur content--ASTM Method D 3177 or ASTM Method D 4239.
Monitoring/Recordkeeping/Reporting -quarterly reporting of the following
------T-he=p-e=ittee-shalt assure cmmPliance with sulfur dioxide and nitrogen dioxide emission standards by
sleternu ' uLu dioxide and-nitro en oxide emissions inPounds Per our usin a�onnnugas err ssrons
monitoring (CEM)system meeting the requirements o a
The Permittee shall submit the continuous emissions monitoring data showing the 24-hour daily block
values in pounds per hour for each-24-hourdaily block averaging period during the reporting period on a
quarterly basis.
The Permittee shall submit sulfur dioxide and nitrogen oxide CEM systems monitor downtime reports,
including monitor availability values (as calculated for 40 CFR Part 75) for the last hour of the reporting
period.
In Compliance CEMs reports indicate compliance.
Recordkeeping/Reportina when burning TDF at a rate greater than 20% - annual reporting of the
following
The Permittee shall maintain and submit to the Regional Supervisor fora period of 5 years following the
date at which the facility commences operation burning TDF at a rate greater than 20%, information
demonstrating that this change in TDF consumption does not result in a greater than significant emissions
increase. This demonstration shall, at a minimum, include the original annual baseline emissions for all
PSD regulated pollutants, representative of normal source operation prior to the increase in TDF
consumption and the annual emissions for all PSD regulated pollutants after this change.
Alternative Op Scenario for Emissions of Sulfur Dioxide Only - While
operating ROTAMIX (rotating mixing system) SO2 reduction technology with
lime/limestone
aa. Sulfur dioxide emissions from each boiler (ID Nos. ES-1A and 1B) shall not exceed 1.50 pounds
per million Btu heat input. [15A NCAC 2D .0530]
Testing [15A NCAC 2D .0501(c)]
bb. If emissions testing is required, the testing shall be performed in accordance with 1 re
NCAC 2D '.0501(c) and General Condition JJ found in Section 3. If the results of this test are
above any limit given in Section 2.1 A. 5. aa. above, the Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0530.
Monitoring/Recordkeepina [15A NCAC 2Q .0508 (f)]
cc. The Permittee shall assure compliance with 2.1 A. 5.aa. above by determining sulfur
dioxide emissions in pounds per million Btu using a continuous emissions monitoring (CEM)
system meeting the requirements of 40 CFR Part 75 except that unbiased values may be used
(missing data shall be filled in accordance with 40 CFR Part 75, except that the lookback periods
per 40 CFR 75.33 (Tables 1 and 2) shall consists of the available data up to the appropriate
quality-assured hours. Also, the replacement procedures for monitor data availability between 80
and 90 percent may be used at values below 80 percent). Compliance with emission sulfur
dioxide standards shall be determined by averaging hourly continuous emission monitoring
system values over a 24-hour block period beginning at midnight. To compute the 24-hour block
average,the average hourly values (missing data shall be filled in accordance with 40 CFR Part
75, except that the lookback periods per 40 CFR 75.33 (Tables 1 and 2) shall consists of the
available data up to the appropriate quality-assured hours. Also, the replacement procedures for
monitor data availability between 80 and 90 percent may be used at values below 80 percent)
shall be summed, and the sum shall be divided by 24. The minimum number of data points,
equally spaced, required to determine a valid hour value shall be determined by 40 CFR Part 75.
If any 24-hour block average exceeds the limits per 2.1 A. 5. aa. above or the records are not
7

maintained, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530.
In Compliance CEMs reports indicate compliance.
- RnnnrtinaT1 RA�ICAC 2Q 0508(f)] _ —_ --- - -
dd. The Permittee shall submit the continuous emissions monitoring data showing the 24-hour daily
block values in pounds per million Btu for sulfur dioxide emissions for each 24-hour daily block
averaging period during the reporting period no later than January 30 of each calendar year for
the preceding three-month period between October and December, April 30 of each calendar
year for the preceding three-month period between January and March, July 30 of each calendar
year for the preceding three-month period between April and June, and October 30 of each
calendar'year for the preceding three-month period between July and September. All instances
of deviations from the requirements of this permit must be clearly identified.
In Compliance CEMs reports indicate compliance.
ee. CEMs Monitor Availability The Permittee shall submit sulfur dioxide CEM_ system monitor
downtime reports, including monitor availability values (as calculated for 40 CFR Part 75) for the
last hour of the reporting period,no later than January 30 of each calendar year for the preceding
three-month period between October and December, April 30 of each calendar year for the
preceding three-month period between January and March,July 30 of each calendar year for the
preceding three-month period between April and June, and October 30 of each calendar year for
the preceding three-month period between July and September.
In Compliance CEMs reports indicate compliance.
15A NCAC 2Q .0700: TOXIC AIR POLLUTANT PROCEDURES
The Permittee is allowed to burn the following as supplemental fuels in the boilers, provided that the
high
I h, wastes are generated at this plant-site and are combusted under conditions of high fire producing
steam demand:
waste water basin/evaporation pit sludge of a maximum feed rate of 1% by weight not to exceed
20tpy
activated carbon filters from the water treatment process not to exceed 10 tpy
boiler cleaning solution with a maximum injection rate of 10 gallons per minute of the solution per
100,000 pounds of steam flow not to exceed 35,000 gallons per year.
Tire derived fuel feed rate shall not exceed 40% of the heat input of each boiler.
Fuel flyash briquettes provided toxic pollutant emissions are less than the emissions from the
firing of coal in the boilers. Limit of 36 tons per day of flyash briquettes will be fired in the boiler.
Pelletized paper fuel(PPF)
The Permittee may use the following for normal start-up of the boilers, provided the oil is generated
onsite
unadulterated oil soaked rags, wood scraps, used oil absorbents, used/fuel oil soaked rags, and used oil
soaked wood chips.
The Permittee may burn 'regenerated' spent cation/anion resins [spent demineralizer resin] in the boilers
(under high fire producing high steam demand) once the following conditions have been met: Testing to
determine the quantity and type of any toxic materials forwarding test results to the Fayetteville Regional
Supervisor. Written permission must be obtained prior burning and the regenerated material may not
exceed 40 tpy and must be generated onsite.
Monitoring/Recordkeepina: The Permittee shall maintain a plant waste fuel start-up logbook onsite with
the following information: date of start-up, hours of start-up, and quantity and type of materials used
8

when plant wastes are used to start-up the boilers. Maintain individual records for each type of plant
waste combusted including date, quantity, feed rates of waste and coal, any details or analysis of fuel.
Reporting-Annual due by January 30th
-ofce Repsrt3#►eve=b ime
_ - Inspection Observations:
In Compliance based on annual reporting Facility only burned coal
(1),The facility has not burned any of the above mentioned fuels except for spent demineralizer resin.
This was burned in the boiler on 10/16/98. This was prior to the stipulation concerning spent
demineralizer resin being put into their permit(prior to permit No. 05455R08 being issued).
(2) The facility is not currently combusting used oil. All items that may contain used oil are picked up by
a disposal company.
15A NCAC 2D .1417: EMISSION ALLOCATIONS FOR LARGE COMBUSTION SOURCES'
The following limits apply beginning May 31 through September 30, 2004 and May 1 through September
30, 2005 and each year thereafter until revised according to 15A NCAC 2D .1420. Sources using the
nitrogen oxide budget trading program to comply shall have installed and begun operating by May 1,
2004,a continuous emissions monitoring system that complies with 40 CFR Part 96.
NOx EMISSION ALLOCATIONS (tons/season)
SOURCE
2004 1 2005 1 2006 and later
Boilers (ID Nos. ES-1A 115 143 126
and 1B
Monitoring/Recordkeeping Determine nitrogen oxide emissions in tons per ozone season using a
continuous emissions monitoring (CEM) system that meets the requirements of 40 CFR Part 75 Subpart
H. The Permittee shall comply with the recordkeeping requirements of 40 CFR 96, Budget Trading
Program for State Implementation Plans. if nitrogen oxide emissions for any ozone season exceed the
allowances held in the Compliance Account as of November 30 of each year or the recordkeeping
requirements are not complied with, the Permittee shall be deemed in noncompliance with 15A NCAC 2D
.1417.
Reporting The Permittee shall report no later than July 30 of each year the tons of nitrogen oxides
emitted during the previous May and June and shall report no later than October 30 the tons of nitrogen
oxides emitted during the previous ozone season. One copy of this report shall be sent to the appropriate
Regional Office and one copy shall be sent to the Stationary Source Compliance Supervisor at the
address shown in General Condition D.
Inspection Observations:
In Compliance Reports submitted to date indicate compliance.
Two coal bunkers (ID Nos. ES-2A and ES-28) and associated bagfilters (ID Nos. CD-2A and CD-2B)
One fly ash silo (ID No. ES-3) with wet slurry pug mill for unloading and associated binvent (ID No.
CD-3),
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One bottom ash silo (ID No. ES-4) with a dry bulk unloading spout with vent return line and
associated binvent(ID No. CD-4)
Two ash system vacuum transport pumps (ID Nos. ES-15A and ES-513) and associated inline filters
(ID Nos. CD-5A and CD-5B),simple cyclones (ID Nos. CD-5C and 5E), and bagfilter(ID No. CD-51))
I A—Nrnr n 051-E okoTICULATce corms MISCE LANE011S INDLSTRIALP-R -- - -
Monitorina/Recordkeeping : Minimum monitoring requirements are completion of an annual internal
inspection of the simple cyclones structural integrity and an annual internal inspection of the
bagfilters/binvents/inline filters for structural and fabric filter integrity. The results of inspection and
maintenance shall be maintained in a logbook.
Reporting -Semiannual summary reports.
Inspection Observations:
In Compliance Review of logbooks indicate compliance.
15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
Visible emissions from these sources shall not be more than 20 percent opacity.
MonitorindlRecordkeeping : Weekly monitoring of sources. Results of monitoring shall be maintained in
logbook.
Reporting-Semiannual summary reports.
Inspection Observations:
In Compliance Review of logbooks indicate compliance.
15A NCAC 2D.0530i PREVENTION OF SIGNIFICANT DETERIORATION
Monitoring/RecordkeepinglReporting: Minimum monitoring requirements are completion of an annual
internal inspection of the simple cyclones structural integrity and an annual internal inspection of the
bagfilters/binvents/inline filters for structural and fabric filter integrity. The results of inspection and
maintenance shall be maintained in a logbook.
Reporting -Semiannual summary reports.
Inspection Observations:
In Compliance Review of logbooks indicate compliance no VE observed. The
facility considers zero visible emissions for these sources to be normal. Reports
have been submitted on time.
Coal unloading/storage and transfer(ID No. ES-6)
15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
Visible emissions from these sources shall not be more than 20 percent opacity.
Mon itoring/Recordkeeping : Weekly monitoring of sources. Results of monitoring shall be maintained in
logbook.
Reporting-Semiannual summary reports.
Inspection Observations:
In Compliance Logbooks indicate compliance no VE observed. No coal
unloading or transfer observed during the inspection. Reports have been
submitted On time.
15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
The Permittee shall employ wet suppression on coal unloading, front end loader operations, coal storage
pile load in/out, and wind erosion coal piles. Maintain partial enclosures on conveyors.
Monitoring/Recordkeeping The inspection and maintenance requirement must include a monthly
external visual inspection of the system for integrity of piping and nozzles. The inspection and
maintenance requirement must also include a monthly visual inspection along with appropriate
10

maintenance for the partially enclosed conveyors to ensure covers are structurally sound and in good
repair. Inspections and maintenance are to be recorded in logbook.
Reporting —Semi-annual summary report.
Inspection Observations:
I -Complianr.P Re-view of logbooks indicate compliance. No VE observed from
-- proi:e s—AlesMsibte-emissions-frnm-thecoal=storaag=and transfer-0pQL ton.--T-e--.— --=---
11 March 2010
facility considers zero visible emissions for these sources to be normal
Facility-Wide Emissions—state enforceable only
16ANCAC 2Q.0700: TOXIC AIR POLLUTANT PROCEDURES
The facility shall be operated and maintained in such a manner that emissions of any listed toxic air
pollutant(s) from the facility, including fugitive emissions, will not exceed the TPERs specified in 15A
NCAC 2Q .0711_
TPERs Limitations
Pollutant Carcinogens Chronic Toxicants Acute SystemicF Acute Irritants
and (lblyr) (lb/day) Toxicants (ib/hr)
Application Date ib/hr
cadmium 0.37
February 26, 1996
nickel 0.13
Februa 26,1996
In Compliance based on annual emission inventories
(6)' COMPLIANCE HISTORY:
2005 November 16 NOV for failure to submit ACC to EPA.
2006 May10 NOV for failure to submit ACC to EPA.
2009 November 25 NOV failure to report emission allocations
2010 March 11 Nov for failure to in clued General Conditions in the ACC
(7), CONCLUSIONS/RECOMMENDATIONS:
At the time of this inspection, June 8, 2010, Elizabethtown Energy appeared to be operating in
compliance with their permit no. 05455/T15 issued May 18, 2010.
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