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HomeMy WebLinkAboutAQ_F_0900043_20110609_CMPL_InspRpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Elizabethtown Energy,LLC NC Facility ID 0900043 Inspection Report County/FIPS: Bladen/017 Date: 06/14/2 0 11 Facility Data Compliance Data Elizabethtown Energy, LLC Inspection Date 06/09/2011 Jim Name 3100 West Broad Street Inspector's im Moser Elizabethtown,NC 28337 Operating Status Operating Compliance Code Compliance -inspection Lat: 34d 3 8.8086m Long:78d 3 8.4900m Action Code FCE SIC: 4911 /Electric Services On-Site Inspection Result Compliance NAICS: 221112/Fossil Fuel Electric Power Generation p p Contact Data Permit Data Facility Contact Authorized Contact Technical Contact permit 05455/T15 Michael Wood Darren Stephens Mark Shepherd Issued 5/18/2010 p p Regional EHS President Director EHS& Expires 3/31/2013 Coordinator _ (512)314-8600 Compliance Classification. Title V 910 296-1909 Permit Status Active ( ) (512)314-8624 Inspector's Signatur Comments: AZ Date of Signature: ()1 Idled Facility MACT/GACT and NSPS Re. uirements: The facility was notified of applicability of NESHAP 40 CFR 63 Subpart ZZZZ for the emergency fire pump motor. I e-mailed Mike Woods copies of links that relate to Subpart ZZZZ and others. Safety Equipment: Standard FRO safety gear. (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 Energy, 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 last operated briefly in the first quarter of calendar year 2009. Rick and Randy provided all the maintenance and monitoring reporting that I required and gave me a state of the business report. Their business previously had been to serve as a standby source for Progress Energy (formerly CP&L 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 not anticipate restarting the boilers on coal and do not expect to operate the MOBOTEC lime injection and ROFA burner firing system. They are operating the Kenansville Plant boilers using wood pellets. The Kenansville plant, Lumberton and Elizabethtown plants were originally 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. The permit modifications are being processed currently. 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. 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 and appurtenances: Emissio Emission Source Description Control Control Device Description n Device 1D Source two coal/NG/No. 2 and No. 4.fuel oil/tire ES-1A derived fuel/pelletized paper fuel/flyash two bagfilters (16,800 square feet of and briquette-fired steam, electric generating, C n A filter area q g g and ) ES-1 B boilers(215 MBtu/hour heat input each) CD-1B ES-2A two coal bunkers CD-2A two bagfilters (64 square feet of filter and and area, each) E S-213 C D-2 B ES-3 one fly ash silo with wet slurry pug mill for CD-3 one silo binvent(100 square feet of unloading filter area ES-4 one bottom ash silo with a retractable bulk CD-4 one silo binvent(100 square feet of unloading spout and enclosed vent return filter area two ash system vacuum transport pumps CD-5E one simple cyclone(42 inches in diameter)on the bottom ash silo . CD-5D one bagfilter(528 square feet of ES-5A filter area) on the fly ash silo and one simple cyclone (42 inches in ES-513 CD-5C 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 *Boiler Plate Information: Boiler Manufacturer Year Serial No. Design Pressure ES-1 A Foster Wheeler 1985 6705 1750 psig ES-1 B Foster Wheeler 1985 6708 1750 psig Details 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 tire 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: Two coal/natural gas/No. 2 and No. 4 fuel oil/tire derived fuel/pelletized paper fueUflyash briquette-fired boilers (ID Nos. ES-lA and 1B) and associated bagfilters (ID Nos. CD-1A and 1B), each equipped with ROFA (rotating opposed fire air system) NOx reduction technology and ROTAMIX (rotating mixing system)- S02 reduction technology using lime/limestone (ID Nos. ES-lA and 1B) and associated bagfilters (ID Nos. CD-1A and 1B) 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. • 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) Reporting: Semiannual summary reports. 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 Logbooks 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. Mon itorin,g/Recordkeeping 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 Recordkeeping: 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 Com fiance No visible emissions were noted during m visit.(The facility was not operating) The facility considers zero visible emissions for these sources to be normal. Logbook was bein '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. In Compliance Based on CEMS and COMS reports submitted semi-annually Monito,ri,/Recordkeeping/Reporti g -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 D. moisture content -ASTM Method D 3173; and E. sulfur content--ASTM Method D 3-177 or ASTM Method D 4239. Mon itoring/Reco dkeeping/�porting -quarterly reporting of the following The 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 Operating Scenario for Emissions of Sulfur Dioxide Only - while operatin ROTAMIX (rotating ixi g rn ng system) Sot reduction technology with line/limestone aa. Sulfur dioxide emissions from each boiler (ID Nos. ESAA and 1 B) 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). Mon itoring/Recordkeeping_[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 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. 4. aa. above or the records are not- maintained, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501(e). 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 OEMs 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�TRliance. 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 CEMs reports indicate compliance Mon itoring/Recordkeepi g/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 suppliers 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 F. sulfur content--ASTM Method D 3177 or ASTM Method D 4239. Monitoring/Record,keeping/Reporting, -quarterly reporting of the following The 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. In Compliance CEMs reports vindicate comi2 iance. Record keepi ng/Reporti ng when burning TDF at a rate greater than 20% -annual reporting of the following The Permittee shall maintain and submit to the Regional Supervisor for a 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 operatin Scenari go for Emissions of sulfur Dioxide only - While operating ROTAMIX rotatin mixing- s stern Sot reduction technology with lime/limestone aa. Sulfur dioxide emissions from each boiler(ID Nos. ES-1 A and 1 B) shall not exceed 1.50 pounds per million Btu heat input. [1.5A NCAC 2D .0530] Testing[15A NCAC 2D .0501(c)] bb. !f ern�ssions 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. 5. aa. above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530. Mon itoring/Recordkeeping_[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 maintained, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530. In Compliance CEMs reporrfss 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 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 wastes are generated at this plant-site and are combusted under conditions of high fire producing high steam demand: • waste water basin/evaporation pit sludge of a maximum feed rate of 1% by weight not to exceed 2 0 thn'y • 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/Recordke,�e ,in,g: 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 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 3oth In Compliance Reports have been received on time Inspection Observations: in Com Hance based on annual reportincl. 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 2005 2006 and later Boilers (ID Nos. ES-1 A 115 143 126 and 1 B) Mon itoring/Record keeping 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 icier 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. ------------------------------------------------------------------------------------------------------------------------------------------- One fly ash silo (ID No. ES-3) with wet slurry pug mill for' unloading and associated binvent (ID No. CD-3), 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-5A and ES-513) and associated inline filters (ID Nos. CD-5A and C13-513), simple cyclones (ID Nos. CD-5C and 5E), and bagfilter (ID No. CD=51)) 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES Mon itoring/Recordkeepinq : 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. Mon itoring/Recordkeeping : 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 .0530: PREVENTION OF SIGNIFICANT DETERIORATION Mon itoring/Record keep inq/Reporting: 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 (11) No. ESm6 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS Visible emissions from these sources shall not be more than 20 percent opacity. Monitoring/Recordkeeping Weekly monitoring of sources. Results of monitoring shall be maintained in logbook. Report, ng—Semiannual summary reports. Inspection.Observations: In Com fiance Lo books indicate compliance, no VE observed. No coal unloading or transfer observed during the sjoe.ction. 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/Recordkeepi g 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 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. Reporti;ng—Semi-annual summary report. Inspection Observations: In Compliance Review of to books indicate compfiance. No VE observed from process. No visible emissions from -the coal storage and transfer operation. The facility considers, zero visible emissions for these sources to be normal. FacilitymWide Emissions -- state enforceable only 15A NCAC 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 Systemic Acute Irritants and (Ib/yr) (Ib/day) Toxicants (Ib/hr) Application Date (Ib/hr) cadmium 0.37 nickel 0.13 In Compliance based on worksheets calculations supplied with annual emission inventories (6) COMPLIANCE HISTORY: i 2005 November 16 NOV for failure to submit ACC to EPA. 2006 May 10 NOV for failure to submit ACC to EPA. 2009 November 25 NOV failure to report emission allocations 2010 March 11 Nov for failure to include General Conditions in the ACC (7) CONCLUSIONWRECOMMENDATIONS: At the time of this inspection, June 9, 2010, Elizabethtown Energy appeared to be,operating in compliance with their permit no. 05455 I T15 issued May 18, 2010.