AQ_F_0900043_20130423_CMPL_InspRpt

Page lof 13
Permit 05455 T17
Facility ID 0900043
NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Elizabethtown Energy
NC Facility ID 0900043
} Inspection Report County/FIPS: Bladen/017
Date: 04/25/2013
Facility Data Compliance Data =
6
Elizabethtown Energy Inspection Date 04/23/2013
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 a
NAILS: 221112/Fossil Fuel Electric Power Generation On-Site Inspection Result Compliance
Contact Data ( Permit Data
',. Facility Contact Authorized Contact Technical Contact Permit 05455/T17
Issued 5/8/2012
Michael Wood Kyle Michael Michael Wood Expires 12/31/2016
Regional EHS Manager Plant Manager t Regional EHS Manager t Classification Title V
E [phone] [phone] [phone] t Permit Status Active
_
Inspector's Signature: 6c Comments:
Date of Signature:
MACT/GACT and NSPS Requirements: The facility has an emergency fire pump, ES-1, that is subject to
NESHAP 40 CFR 63 Subpart ZZZZ.The boilers, ES-1A and ES-1 B, are subject to NESHAP Subpart JJJJJJ.
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 was 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 sustainable energy
source of electrical power.There is no plan to restart the facility as a coal fired operation.
(3) INSPECTION SUMMARY:
I met with Mike Wood, Facility Contact and Randy Coates, Plant Manager of Elizabethtown Energy. Randy is
also the only full-time employee at this facility. 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.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(CCCP), is trying to market the facility
as a source of sustainable electric energy.They do not anticipate restarting the boilers on coal. CCCP is
operating the Kenansville Plant boilers using wood in various forms and from various sources.. The Kenansville
plant, Lumberton and Elizabethtown plants were originally constructed exactly alike.They anticipate that the

_ Page 2of 13
Permit05455 T17
Facility ID 0900043
restart of Elizabethtown and/or Lumberton facilities will be with a combination of non-CISWI wood and poultry
litter.
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 AM responsibilities
outlined in the permit, quarterly,to assure that they are being completed.
(4), PER-M''ITTED EMISSION SOURCES
yrgg !(H'FHUW ?3 ��i v` --i d0�` t I�il i€�t�O[�.' 4�flz?�l�v� -sv v3 L�`�f1Ii v " 5u�m ?6 r -�v gEil•ll it R �dvljS31. Solilr ,3'+v .'�� RiflE m �+v i1�.Er r� I
Asa �Sl6rkv �' L r SL, �v � i, ri317r'(}I DQV"I .v�£$ �'IiYQ[4 *�:
n r�� ° � iHlLimit
wy MINEi?I'i �OW
t 'C+. C v.. _.I� v eru v .a
ell
v_� .vtfi �tlw� :&orswz.�. E..—..,. ., ,,..�G__:.:, _ �.vsx �a!�� ;� jvv�! „��.,HIM� K2s ;M
two coal/natural gas/No. ' CD-1A3 & i two selective non-catalytic reduction systems j
2 and No. 4 fuel oil/tire CD-133 (300 Ibs/hr aqueous ammonia injection rate
derived fuel/pelletized CD-1A2 & each)
ES-1A and I ' paper fuel/flyash CD-1B2« two multiclones (132 Nos tubes each, 9 inches
t ES-1 B t briquette/non-CISWI' CD-1A4«` & in diameter each)
( PSD s subject wood-fired CD-1 B4 two dry sorbent injection systems (50 Ibs/hr
I CAM steam, electric sodium bicarbonate or sodium sesquicarbonate
generating boilers (215 CD 1A & (trona) injection rate each) €
MBtu/hr heat input j CD 1 B two bagfilters (each not to exceed 3 26 1 air-to- a
f each) 1 cloth ratio) n
ES-2A and CD-2A& two bagfilters (64 square feet of filter area,
; each
ES-2B PSD ,
two coal bunkers CD 2B ..,
one fly ash silo w/wet =' one silo binvent filter(400 square feet of filter
ES-3 PSD I CD-3 i unloading slurry pugmill I area)
ES-4 PSD one bottom ash silo CD 4
one silo binvent filter(100 square feet of filter
t � . area '
' CD-5E j cyclone (42 in diameter) on the bottom ash silo
CD-5D bagfilter(528 sq ft filter area) on the fly ash silo
ES-5A and two ash system vacuum e
ES 5B PSD transport pumps CD 5C s cyclone (42 inches in diameter) on the fly ash
(I CD 5A & 3 silo
CD 5B two in-line filters(one er um
ES-6 PSD coal Wetsup wet suppression/chemical binder
_ unload/store/transfer '
ES-15' 7100 gallons aqueous None N/A
ammonia stora a tank
� ES-1 diesel fired 340 hp None N/A
emer enc fire pump
_..,.....,...J:
iiiii
v «««...«.�...«x � _
I , ..r, 'r F.3 r E . . ft "i e 01E . * :0`11K � L s .a.—
� u ;i� 3 N � sr� . 3tg ,HI .= �7 a . e PesW93- J
ES-1A a Foster Wheeler mm1985 6705 1750 psig
ES-2/k t- Foster Wheeler a 1985 6708 1750 psig

Page 3of 13
— Permit 05455 T17
Facility ID 0900043
Insignificant Activities:
lmMTO _ ,ea rtmxiw „ : fyr PSc
_M( p :: _.
IES-2 one diesel fuel oil storage tank
IES-3 one fire pump fuel oil storage tank
IES 4solvent parts cleaner
_..__. ..m�.�.v. ...._�m
IES-5 one turbine lube oil tank vent
IES 6 s one cooling tower
IES-7 tire shredders (Neverinstalled)
i IES-8 i truck dumper No. 1 for receiving biomass fuel (Not Yet Installed)
IES-9 truck dumper No 2 for receiving biomass fuel (Not Yet Installed)
IES 10 fuel storage piles (Not Yet Installed)
IES-11 fuel material handling including conveyors, front-end loader/dozer and other
[ vehicular traffic in the fuel yard Nof Yet Installed
m
IES-12 [ paved roads
I IES-13 one sorbent silo
IES-14 one bottom and sifting ash bunker
�u IES-UNPVDRD a unpaved roads
(5) SPECIFIC PERMIT CONDITIONS:
Two coal/natural gas/No. 2 and No. 4 fuel oil/tire derived fuel/pelletized paper
fuel/flyash briquette/non-CISWI subject wood-fired boilers, ESAA and ES-1 B.
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.
Apparent Compliance Indicated Inspections and maintenance activities have been performed and recorded
in preventive maintenance logbook sheets. Summary reports have been received.

Page 4of 13
Permit 05455 T17
Facility ID 0900043
15A NCAC 2D .0504: PARTICULATES FROM WOOD BURNING INDIRECT HEAT
EXCHANGERS Emissions of particulate matter from the combustion of wood that are discharged from these
sources into the atmosphere shall not exceed 0.30 pounds per million Btu heat input.
Monitoring and Recordkeeping:
Particulate matter emissions from each boiler shall be controlled by a dedicated multiclone. To assure
compliance, the Permittee shall perform inspections and maintenance as recommended by the manufacturer. In
addition to the manufacturer's inspection and maintenance recommendations, or if there is no manufacturer's
inspection and maintenance recommendations, as a minimum, the inspection and maintenance requirement
must include the following:
• a monthly external visual inspection of the system ductwork and material collection unit for leaks;and
• an annual(for each 12 month period following the initial inspection) internal inspection of the
multiclone's structural integrity.
Reporting: Six month summary reports.
_Apparent Compliance Indicated Inspections and maintenance activities have been performed and recorded
in preventive maintenance logbook sheets. Summary reports have been received.
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/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.... 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 for the last hour of the reporting period.
Apparent Compliance Indicated Reports have been submitted on time. No deviations, facility shutdown.
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 for the boilers,
weekly observations for all other equipment
Reporting: Semiannual summary reports for all equipment
Apparent 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 NAAQS
When burnina coal
a. Particulate matter emissions from each boiler shall not exceed 6.02 pounds per hour per
boiler.
b. Sulfur dioxide emissions from each boiler shall not exceed 322.5 pounds per hour per
boiler.

Page 5of 13
Permit 05455 T17
Facility ID 0900043
C. Nitrogen oxide emissions from each boiler shall not exceed 141.9 pounds per hour per
— boiler.
d. Carbon monoxide emissions from each boiler shall not exceed 120.4 pounds per hour per
boiler
Monitoring/Record keeping/Reporting The Permittee shall be deemed in noncompliance if the
bagfilters are not inspected and maintained or if records are not maintained.The Permittee shall assure
compliance by determining sulfur dioxide and nitrogen oxide emissions in pounds per hour using a
continuous emissions monitoring (CEM)system
Reporting The Permittee shall submit the continuous emissions monitoring data quarterly.
Apparent Compliance Indicated Reports have been submitted on time. No deviations, facility shutdown.
15A NCAC 2D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY Subpart JJJJJJ
For the sources(ID Nos. ES-1A and ES-1 B),the Permittee shall demonstrate compliance by performing a
Tune up, Energy Assessment and initial notification by 3/21/14.
The permittee shall submit a notification of compliance status by 7/19/14.
Apparent Compliance Indicated The upcoming requirements were discussed at the inspection
conference. Company states that they understand all compliance requirements and will comply on time.
15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
When burning coal
II vtly ,� IIII,1
�' PQIIu ..t1t '�PSD�L(rt��1t r �d�@��ail�I N
f rnna-d � �/MF�' 1 H .( 1[7t.)h �� r ��Ei� �..
—MMMi.flfll-
.....::.......W°?..�aiu=
PM (TSP) 0028 q
S02_r... ,.,..., 1.50
CO 0.56
Monitoring/Recordkeeping/Reporting
a. The Permittee shall be deemed in noncompliance if the bagfilters are not inspected and maintained or if
records are not maintained.
b. The Permittee shall assure compliance using a continuous emissions monitoring (CEM)system.
c. The Permittee shall maintain and submit to the Regional Supervisor,on an annual basis 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.
d. The Permittee shall submit the continuous emissions monitoring data quarterly.
Apparent Compliance Indicated Reports have been submitted on time. No deviations,facility shutdown.

Page 6of 13
Permit 05455 T17
Facility ID 0900043
When burning non-CISWI subject wood
The following Best Available Control Technology(BACT) limits shall not be exceeded:
]V]i CIMN SA11� EPF]., LIU
, u 0 �T, 1 yQL dl�x i
Q
0.45 lb/MBtu
CO [ good combustion control
Boilers ] stack test 3 run average] ..v.
' ES-1A and ES-1BSulfuric acid i 0.011 Ib/MBtu �
mist [stack test 3 run avera a use of low sulfur wood
BACT emission limits.
Testing
Permittee shall demonstrate compliance with the emissions limits for CO and sulfuric acid mist above,
by testing one of boilers (ID Nos. ES-1A and ES-1 B)within 180 days of commencement of burning of
non-CISWI subject wood exclusively. If the average of all runs of the stack tests for CO or sulfuric acid
mist exceed the respective emissions limits above or the stack tests are not performed, the Permittee
shall be deemed in noncompliance with 15A NCAC 2D .0530.
Mon itoring/Recordkeeping or Reporting
No monitoring/record keeping shall be required for emissions of CO and sulfuric acid mist from boilers.
Apparent Compliance Indicated Facility is shutdown. No Non-CISWI wood has been burned.
**State-only Requirement**
SENATE BILL 3 (Session Law 2007-397)
When burning non-CISWI subiect wood
The following Best Available Control Technology (BAC limits shall not be exceeded
' E v n rt1TI5 [ 7ty,LI11TS ( N3L2QLI
,as� u_, �«...,-»_-.,,U �,� .a..«..,.,,�.u« ��..�1 E..............: ._...... 1 �[vr
# 0.036 Ib/MBtu (both filterable and condensable) i
PM/PM10 ? stack test 3-run avera e C mult,clone and bagfilter j
s
a
0.011 Ib/MBtu (both filterable and condensable
PM2.5 [organic and inorganic including sulfuric acid multiclone and bagfilter [
i Boilers mist]) stack test: 3 run average] m P
(ID Nos. ES- i
g 1A and ES- SO2 0.025 Ib/MBtu [CEM: 30 day rolling average] use of low sulfur wood
3 1B) t-NOx 0.1251b/MBtu [CEM: 30 day rolling average] SNCR
VOC 0.03 Ib/MBtu [stack test 3-run average] good combustion control i
3 H 5 x 10 s Ib/MBtu stack test 3 run avera e
g [ 9 ] bagfilter
.........�..m...» ».........,.. »mom...-......„..,� »...,... T.,.,m.���.,.�..»»,A._.�......,aem.. .,....,,.,..... _.....aa�..... ,.....».._ Ha_. »»...-..,.:a........
Testing Permittee shall demonstrate compliance with the emissions limits for PM/PMio, PM2.5,502, NOx,
VOC, and Hg above by testing one of boilers within 180 days of commencement of burning of non-CISWI
subject wood exclusively. The final SO2 BACT emission limit shall be established using the representative
stack test data, SO2 CEMS data, boiler operational data, and fuel sulfur content data.A testing protocol that
describes how the final SO2 BACT emission limit will be established shall be approved by the DAQ.

Page 7of 13
Permit 05455 T17
Facility ID 0900043
Monitoring/Recordkeepinq
a. The Permittee shall monitor NOx and SOz emissions from boilers using continuous emissions
monitoring (CEM) systems.
b. Monitoring/recordkeeping requirements for PM emissions from boilers shall be sufficient to
assure compliance with PM/PM10, PM2.5 and Hg BACT under Senate Bill 3 (Session Law 2007-
397).
C. No monitoring/record keeping shall be required for VOC emissions from boilers
Reportinq
a. Reporting requirement for PM emissions from boilers above shall be sufficient to assure
compliance with PM/PM,o, PM2.5and Hg BACT.
b. The Permittee shall submit a summary report of monitoring and recordkeeping activities every 6
months.
Apparent Compliance Indicated Reports have been submitted on time. No deviations, facility shutdown.
Two coal bunkers ES-2A and ES-2B, One fly ash silo ES-3, One bottom ash silo
ES-4 and Two ash system vacuum transport pumps ES-5A and ES-5B.
15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL
PROCESSES
Mon itoring/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.
Apparent Compliance Indicated Review of logbooks indicate apparent compliance.
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.
Apparent 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
Monitor!ng/Recordkeepinq/Reportinq: 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.
Apparent Compliance Indicated Review of logbooks indicate compliance,facility shutdown. Reports have
been submitted on time.

Page 8of 13
Permit 05455 T17
Facility ID 0900043
Coal unloading/storage and transfer 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.
Apparent Compliance Indicated Review of logbooks indicate compliance, no VIE 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.
Monitoring/Record keeping 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.
Apparent Compliance Indicated Review of logbooks indicate compliance, no VE observed,facility
shutdown. Reports have been submitted on time.The entire inventory of coal has been removed from the premises.
One 7100 gallons aqueous ammonia storage tank ES-15
The following tabl"rovides a summary of litits,anq standards for the emission sources)described above
mg
r �0 1 1wig ..
/ tattard A I able 13 tiori
J G �,ji �d - " 3Lf' $' �i�` _" r� d y .p t9L1K'4 i i2 i
_ ryryiitt.uaaazw.I.uz aac�ael�su.o1 .�l�az,.�r C "6 E�„ r�r . aLu�'ilk. id
Toxic Air See Section 2 2 A 1 State-onl re uirement ° 15A NCAC 2D 1100
�.�. x..� . na._�..�1 �
Pollutants See Section 2.2 A.3.
State onl re uirement ' 15A NCAC 2Q 0711 l
Apparent Compliance Indicated based on worksheets calculations supplied with annual emission
inventories and the fact that the facility is shutdown. Reporting has been submitted on time.
One diesel fired 340 hp emergency fire pump ID No. ES-1
15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
Mon itoring/Recordkeepinq/Reporti nq
No monitoring/recordkeeping/reporting is required for sulfur dioxide emissions from burning of diesel fuel in this
source.
Visible emissions from this source shall not be more than 20 percent opacity when averaged over a six-minute
period.
Apparent Compliance Indicated based on worksheets calculations supplied with annual emission
inventories and the fact that the facility is shutdown. Reporting has been submitted on time.VEs have been
maintained in the logbook

Page 9of 13
Pennit05455 T17
Facility ID 0900043
15A NCAC 2D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY Subpart ZZZZ
Permittee shall demonstrate compliance for ES-1 by complying with NSPS Subpart IIII.
Apparent Compliance Indicated The compliance date is May 3, 2013. The company personnel are
prepared to be in compliance by that date.
"Facility-Wide Emissions —state enforceable only**
15A NCAC 213 .1100 CONTROL OF TOXIC AIR POLLUTANTS
a. Pursuant to 15A NCAC 2D .1100 and in accordance with the approved application for an air toxic
compliance demonstration, the following permit limit shall not be exceeded:
'1 'aflL
s- �1a'` i C
`A510nb fll
�.
ax u,
n ;ra� :.:.'lu,I6� .�z :�,,.;-, �'7�ili.,,�: au`#`I
?v
v: m a
Acrolein 0.064 lb/hr
Ammonia 11416/hr E
m...._-�
° Arsenic and inorganic arsenic
compounds. 83.2 Ib/yr
g. Benzene _ 197016/yr
Benzoa)pyrene 9791b/�!r
I Beryllium 411bs/yr
Cadmium 15 8 Ibs/yr
0.771b/hr i
Boilers ' Chlorine 18 6 Ib/day r
ES-1A and ES-1B u
Combined Emission
Soluble chromate compounds as E
Rate chromium 0 036 Ib/day d
E (VI a uiw lent
Hydrogen chloride 3.34 Ibs/hr i
Formaldehyde 189lb/hr 3
Manganese and compounds 4 3.1 1b/day® =v
? Mercury,vapor 0.38 lb/day w 3
Nickel, soluble compounds as 0.34 Ib/day
_.fl
Hexachlorodibenzo-p-dioxin 61bs/yr
1,2 3 6,7,8
Vinyl chloride _ .. u 67.41bs/yr m
Ac_rolein 5 75 x 10-5 lb/hr l
Emergency Fire - -4
Pump ES-1 Benzene 2 91 x 10 Ib/ r
:
Benzoa?pyrene mm_nm T 5 86 x 10 a Ib/yr

Page 10of 13
Permit05455 T17
Facility ID 0900043
mvxt r r ' :sly g1 t1ti i n :i.q
cf}�) Mi
slnu,.,
SH","xw5r�'xi'i ;.tRdt �S? is
im.W5.;
Soluble chromate compounds, as 5
chromwm (VI) eWguivalent 4.49 x 10- lb/day
Formaldeh de 7.36 x 104 Ib/hr
Aqueous Ammonia €
Storage Tank ES-15 Ammonia 0.99 Ib/hr 9
Monitoring/Recordkeepinq/Reporting The maximum hours of operation for emergency fire pump
ES-1 shall not exceed 1,000 hours per rolling consecutive 12-month period. The Permittee shall record
monthly and total annually the hours of operation for this fire pump.
Apparent Compliance Indicated This facility is shutdown. Worksheets from emission inventories show
only trace amounts of TAP emissions from exercising the emergency fire pump.
15A NCAC 02Q .0317: AVOIDANCE CONDITIONS for 15A NCAC 02D .1111: MAXIMUM
ACHIEVABLE CONTROL TECHNOLOGY
In order to avoid applicability of this regulation, the total hazardous air pollutant (HAP)
emissions from the facility shall be less than 10 tons of any single HAP and 25 tons of combined HAP
per consecutive 12-month period.
Monitoring/Recordkeepinq
Calculations of emissions of HCI and chlorine shall be made at the end of each month and recorded monthly
in a logbook.
Reporting Reports are required every 6 months.
Apparent Compliance Indicated The facility is shutdown. HAP emissions from exercising the
emergency fire pump are each less than 1 pound per the emission inventory.
15A NCAC 2Q .0700: TOXIC AIR POLLUTANT PROCEDURES
Pursuant to 15A NCAC 2Q .0711, for each of the below listed toxic air pollutants (TAPS), the Permittee has made
a demonstration that facility-wide actual emissions do not exceed the Toxic Permit Emission Rates (TPERs)
listed in 15A NCAC 2Q .0711. 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. In accordance with the approved application, the Permittee shall maintain records of
operational information demonstrating that the TAP emissions do not exceed the TPER(s)as listed below:
mog�,:�� 3d 6t ma .;UP HM
"R �> ;�°' " S
r�c1e6ar'�tre! A)xa�
l�_ t t INE
i _ 'vli I',i
ttt v
k t
ag
it tIh/ter)t3
)0 MEN
..,w
acetaldehyde 3 6.8
gp 1 3 butadiene 11 3

Page I Iof 13
Permit 05455 T17
Facility ID 0900043
i yr iii° s pp.. pp. �.y p �j7 a I:.l. i>>
�il. M F
.iti+� ig .r x axe�' �U �2 8 M'olly.milig
: .� t a °�g3 v LI
im
� i��11� � 19I � ,5i _ rgS -i U I FIt�l�BAf �E
��tt MEN. pt
�.,�� "P 3 y
carbon tetrachloride 460 I
...
chlorobenzene 46 j I
chloroform 290 I
di(2 ethylhexyl)phthalate 0.63
ethylene dichloride 260 I "
methylene chloride = 1600 i 0 39 g
methyl chloroform a 250 64 °
[ methyl ethyl ketone 78 c 224
..._ - ,.,a ...,
perchloroethylene I 13000 ]
g pentachlorophenol C 0.063 0.0064
€ i
...»._...I .w..., m. 3
phenol 0.24 ] 1
polychlorinated biphenyls 5.6
styrene ([ 2.7
toluene� ««.. . 98 .. . , 14.4
.------ ._.., I
._.........t
trichloroethylene 4000
trichlorofluoromethane 3 140 C
xylene 57 16.4 ]
Mon itoring/Recordkeeping
a. 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:
i. waste water basin/evaporation pit sludge of a maximum feed rate of 1% by weight not to exceed 20
tons per year,
ii. activated carbon filters from the water treatment process not to exceed 10 tons per year, and
iii. 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.
b. The Permittee may use the following for normal start-up of the boilers, provided that the oil is generated at
_ this plant-site:
i. unadulterated oil soaked rags,
ii. wood scraps,
iii. used oil absorbents,
V. used/fuel oil soaked rags, and
V. used oil soaked wood chips.
c. The Permittee may burn 'regenerated' spent cation/anion resins [spent demineralizer resin] in the boilers
once the following conditions have been met:
i. Testing adequate to determine the quantity and type of any toxic materials listed in NCAC 2Q .0711
shall be performed. The results shall be forwarded to the Fayetteville Regional Supervisor, Division of
Air Quality.

Page 12of 13
Permit 05455 T17
Facility ID 0900043
ii. The Permittee shall request and obtain written permission from the Fayetteville Regional Supervisor,
Division of Air Quality, prior to burning the resins.
N. Combustion of these plant wastes will occur with the following limitations:
A. Wastes are generated from this plant-site,
B. Wastes are combusted in the boiler(s) operating under conditions of high fire producing high
steam demand,
C. Combustion of these plant wastes will occur with the following limitations that the maximum amount
of'regenerated' spent cation/anion resins [spent demineralizer resin] shall not exceed 40 tons per
year.
d. The tire derived fuel feed rate shall not exceed 40% of the heat input of each boiler.
e. To comply with this permit and avoid the applicability of 15A NCAC 2Q .0706, "Modifications" as requested
by the Permittee, toxic pollutant emissions from the firing of the alternative fuel flyash briquettes in the
boilers shall be less than the emissions from the firing of coal in the boilers. To ensure enforceability of this
limit,a total of no more than 36 tons per day of flyash briquettes will be fired in the boiler.
f. The Permittee shall maintain a plant waste fuel start-up logbook onsite with the following information:
i. date of start-up,
H. hours of start-up, and
iii. quantity and type of materials used when plant wastes are used to start-up the boilers.
g. The Permittee shall maintain a plant waste combustion logbook onsite with the following information:
i. date of plant waste combustion, '
it. type of plant waste combusted,
iii. quantity of waste materials combusted,
iv. feed rate of plant waste to the boiler,
V. feed rate of coal to the boiler,and
vi. documentation of any feed rate limitation, if applicable.
h. The Permittee shall maintain a tire derived fuel (TDF) combustion logbook onsite with the following
information:
i. date of TDF combustion,
it. quantity of TDF combusted,
iii. feed rate of TDF to the boiler,
iv, feed rate of coal to the boiler,and
V. documentation of any feed rate limitation, if applicable.
i. The Permittee shall maintain a pelletized paper fuel (PPF) combustion logbook onsite with the following
information:
i. date of PPF combustion,
H. description of PPF combusted,
iii. quantity of PPF combusted,
iv. feed rate of PPF to the boiler,
V. feed rate of coal to the boiler, and
vi. documentation of any feed rate limitation, if applicable.
j. The Permittee shall maintain a flyash briquette combustion logbook onsite with the following information:
i. daily quantity of flyash briquettes combusted, and
ii. daily recordkeeping is only required on days in which briquettes are burned.
Reporting
a. Within 30 days after each calendar year,the following shall be reported:
i. the total amount of the flyash briquettes burned, and
ii. the chemical composition datasheet and/or MSDS for each shipment of flyash briquettes received
during that calendar year.
b. Prior to combustion for the first time, the Permittee shall submit an analysis of the used oil and
unadulterated oil equivalency determination for approval.
c. Within 30 days after the end of each calendar year, the Permittee shall submit a report of the number of
gallons of used oil combusted and an analysis of the used oil.
d. Within 30 days after the initial use of each of these permitted alternative fuels and plant wastes, the
Permittee shall submit in writing the type of fuel or plant waste and the date in which the material was first
used in the boilers.

Page 13of 13
Permit 05455 T17
Facility ID 0900043
Apparent Compliance Indicated based on worksheets calculations supplied with annual
emission inventories and the fact that the facility is shutdown. Reporting has been submitted on time.
Clean Air Interstate Rule (CAIR) Permit Requirements
T.
rT
INN
I OU D4b1
ES Unit 1A Unit 1 °
ES-Unit 1 B Unit 2 '.
15A NCAC 2D .2403: NITROGEN OXIDE EMISSIONS ANNUAL
The total annual nitrogen oxide (NOx) emissions from the affected CAIR units listed above at the
Elizabethtown Energy, LLC shall not exceed
a. 86 tons annually for 2009-2014; and
b. 73 tons annually for 2015 and later
Apparent Compliance Indicated The facility is shutdown.The emission inventory emissions
Calculations worksheets indicate compliance.
15A NCAC 2D .2405: NITROGEN OXIDE EMISSIONS DURING OZONE SEASON
Ozone season NOx emissions from the affected CAIR units listed above at Elizabethtown
Energy, LLC shall not exceed:
a. 51 tons during the ozone season for 2009-2014; and
b. 43 tons during the ozone season for 2015 and later
The ozone season shall be defined as the period of time extending from May 1"to September 301"of each
calendar year.
Apparent Compliance Indicated The facility is shutdown.The emission inventory emissions
indicate compliance.
(6) PREVENTION OF ACCIDENTAL RELEASE, CAA Section 112r.
Apparent Compliance Indicated. The facility does not store or use chemical compounds in quantities to
require a written RMP.
(7) COMPLIANCE HISTORY:
2009 November 25 NOV failure to report emission allocations
i
2010 March 11 Nov for failure to include General Conditions in the ACC
(8) CONCLUSIONS/RECOMMENDATIONS:
At the time of this inspection, April 23, 2013, Elizabethtown Energy appeared to be in compliance with
their permit no. 05455/T17 issued May 8, 2012. The next inspection date has been planned in the
Actions Planning Module for April 15, 2014.