AQ_F_0900043_20120507_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Elizabethtown Energy,LLC
NC Facility ID 0900043
Inspection Report County/PIPS: Bladen/017
Date: 05/08/2012
Facility Data Compliance Data
Elizabethtown Energy, LLC Inspection Date 05/07/2012
3100 West Broad Street Inspector's Name Jim Moser
Elizabethtown,NC 28337 Operating Status Operating
Lat: 34d 38.8086m Long: 78d 38.4900m Compliance Code Compliance- inspection
SIC: 4911 /Electric Services Action Code FCE
NAICS: 221112/Fossil Fuel Electric Power Generation On-Site Inspection Result Compliance
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 05455/T16
Michael Wood Benjamin Ethridge,Jr. Mark Shepherd Issued 1/24/2012
Regional EHS Vice President Asset Director EHS& Expires 12/31/2013
Coordinator Management Compliance Classification Title V
[phone]_ [phone] Permit Status Active
L
r' ure: � Comments:
Signature:
MACT/GACT and NSPS Requirements: The facility was notified of applicability of NESHAP 40
CFR 63 Subpart ZZZZ for the Diesel fired 340I-IP emergency fire pump motor,ID#IES-1 during the
previous inspection. It is still shown as an insignificant source in this revision number,T16. It will
become a permitted source with the next revision. That revision should be issued in approximately one
month time. This facility has no emission sources subject to NSPS regulations.
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 was shut down in early 2009 and has
been prepared for long term storage. The facility is being marketed as a potential renewable energy
source of electrical power. In the future plans, coal will no longer be used as a fuel. The coal piles are
being removed from the grounds. The ROFA burner and MOBOTEC lime injection systems will be
removed as the PSD permit revision T17 is issued.
(3) INSPECTION SUMMARY:
I met with Mike Wood, Facility Contact and Randy Coates, Plant Manager of Elizabethtown Energy.
The plant is staffed with a minimal crew. Both Elizabethtown and Lumberton Energy plants have been
1

shutdown and mothballed for long term storage. The facility last operated briefly in the first quarter of
calendar year 2009. Randy provided all the maintenance and monitoring reporting that I required.
Their business previously had been to serve as a standby source for Progress Energy (formerly
CP&L. 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 ID
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, CandA 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 filter
and and area, each)
ES-26 CD-2B
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
unloadingspout 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 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 Wets up wet suppression/chemical binder
*Boiler Plate Information:
Boiler Manufacturer Year Serial No. Design Pressure
ES-1A Foster Wheeler 1985 6705 1750 psig
2

shutdown and mothballed for long term storage. The facility last operated briefly in the first quarter of
calendar year 2009. Randy provided all the maintenance and monitoring reporting that I required.
Their business previously had been to serve as a standby source for Progress Energy (formerly
CP&L. 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 ID
Source
two coal/NG/No. 2 and No. 4 fuel oil/tire
ES-1 A derived fuel/pelletized paper fuel/flyash CD-1 A two bagfilters (16,800 square feet of
and briquette-fired steam, electric generating, and 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 filter
and and area, each)
ES-213 CD-26
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-51D 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-56 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-1A Foster Wheeler 1985 6705 1750 psig
2

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. It
operates only when unloading. At the time of the inspection, the system was 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 20 .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 lube oil tank vent 15A NCAC 2Q 0503(8) I
one cooling tower I 15A NCAC 2Q 0503(8)
*tire shredders
These tire shredders have not been installed yet. The facility
has no immediate plan for installing these tire shredders 15A NCAC 2Q .0503(8)
however they would like to keep them on their permit)
(5) SPECIFIC PERMIT CONDITIONS:
Two boilers (ID Nos. ES-1A and 1B) and associated bagfilters
(ID Nos. CD-1A and CD-113)
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.
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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.
Compliance Indicated Reports have been submitted on time and 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.
Monitoring/Record keeping` 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 GEM systems monitor downtime reports, including
monitor availability values (as calculated for 40 CFR Part 75) for the last hour of the reporting
period.
Compliance Indicated 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
Compliance Indicated The facility was not operating during the inspection. Reports have been
complete and 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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EM and COMS reports submitted semi-annually. Facility
Compliance Indicated Based on C S p y Y
shut down.
Monitoring/Record keeping/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
D. moisture content--ASTM Method D 3173; and
E. sulfur content-- ASTM Method D 3177 or ASTM Method D 4239.
Mon itoring/Recordkeepinq/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.
Compliance Indicated Based on CEMS and COMS reports submitted quarterly. Facility shut
down.
Alternative Operating Scenario for Emissions of Sulfur Dioxide Only - While operating
ROTAMIX (rotating mixing system) S02 reduction technology with lime/limestone
This system is scheduled to be removed in the near future, corresponding to
issuance of permit revision T17.
Sulfur dioxide emissions from each boiler (ID Nos. ES-1A and 16) 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. as. above, the Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0501(e).
Monitoring/Recordkeepinq [15A NCAC 2Q .0508 (f)]
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
5

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. as. above or the records are not maintained, the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0501(e).
Compliance Indicated Quarterly CEMs reports indicate compliance.
Reporting [15A NCAC 2Q .0508 (f)]
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.
Compliance Indicated Quarterly CEMs reports indicate compliance.
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.
Compliance Indicated Quarterly 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.
Compliance Indicated Quarterly CEMs reports indicate compliance.
Mon itoring/Recordkeeping/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;
6

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.
Compliance Indicated Quarterly CEMs reports indicate compliance.
Recordkeepina/Reporting 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 Operating Scenario for Emissions of Sulfur Dioxide Only - While operating
ROTAMIX (rotating mixing system) SO2 reduction technology with lime/limestone
This system is scheduled to be removed in the near future, corresponding to
issuance of permit revision T17.
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 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.
Monitoring/Record keeping [15A NCAC 20 .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
7

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.
Compliance Indicated Quarterly CEMs reports indicate compliance.
Reporting [15A NCAC 2Q .0508 (f)]
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.
Compliance Indicated Quarterly CEMs reports indicate compliance.
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.
Compliance Indicated Quarterly 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 20 tpy
• 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
8

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/Record keep!nu: 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 30th
Compliance Indicated Based on annual reporting. Reports received on time. Facility
is shutdown.
(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. 054551108 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-1A 115 143 126
and 1B
Monitoring/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 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.
9

Compliance Indicated Reports submitted to date indicate compliance as confirmed
by Alan Drake..
One fly ash silo (ID No. ES-3) and associated binvent (ID No. CD-3),
One bottom ash silo (ID No. ES-4) and associated binvent (ID No. CD-4)
Two ash system vacuum transport pumps (ID Nos. ES-5A and ES-56) and
associated inline filters (ID Nos. CD-5A and CD-56), simple cyclones (ID
Nos. CD-5C and 5E), and bagfilter (ID No. CD-5D)
15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS
INDUSTRIAL PROCESSES
Monitoring/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.
Compliance Indicated 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/Record keep inq : Weekly monitoring of sources. Results of monitoring shall be
maintained in logbook.
Reporting—Semiannual summary reports.
Compliance Indicated Review of logbooks indicate compliance.
15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
Mon itoring/Recordkeepinq/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.
Compliance Indicated Review of logbooks indicate compliance, no VE observed,
facility shutdown. 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.
Monitoring/Recordkeepinq : Weekly monitoring of sources. Results of monitoring shall be
maintained in logbook.
Reporting—Semiannual summary reports.
Compliance Indicated Review of logbooks indicate compliance, no VE observed,
facility shutdown. 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.
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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 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.
In Compliance Review of logbooks indicate compliance, no VE observed, facility
shutdown. Reports have been submitted on time.
Facility-Wide 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
I_
cadmium I 0.37
nickel 0.13 ,...., ...-. .. __ _!
Compliance Indicated based on worksheets calculations supplied with annual
emission inventories and the fact that the facility is shutdown.
(6) PREVENTION OF ACCIDENTAL RELEASE, CAA Section 112r.
Compliance Indicated. The facility does not store or use chemical compounds in quantities to
require a written RMP.
(7) COMPLIANCE HISTORY:
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
(8) CONCLUSIONS/RECOMMENDATIONS:
At the time of this inspection, May 7, 2012, Elizabethtown Energy appeared to be operating in compliance
with their permit no. 05455/T16 issued January 24, 2012.
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