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HomeMy WebLinkAboutAQ_F_0900043_20140320_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 03/24/2014 Facility Data Permit Data Elizabethtown Energy, LLC 3100 West Broad Street Permit 05455/T17 Elizabethtown,NC 28337 1 Issued 5/8/2012 Lat: 34d 38.8086m Long: 78d 38.4900m Expires 12/31/2016 SIC /E Services m m Classification Title a NAICSS: 221112 12/Fossil Fuel Electric Power Generation Permit Status Active € Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact F Technical Contact i SIP/Title V/PSI) Michael Wood I{yle Michael Michael Wood MACT Part 63: Subpart 6J, Subpart ZZZZ Regional EHS , Plant Manager Regional EHS t Manager (910)296-1909 '' Manager (910)296-1809 (910)296 1809 1 , Compliance Data Comments: 4° P Inspection Date 03/20/2014 Inspector's Name Jim Moser Inspector's Signature,,://,,�� /�f®,J/ r Operating Status Operating j Compliance Code Compliance-inspection (j Action Code FCE Date of Signature: q On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 * HAP 2012 --- --- 0.0600 0.3100 0.0100 --- 0.0279 2011 0.0500 03100 0.0100 --- 0.0274 2010 --- --- 0.0500 0.3100 0,0100 0.0274 @ Highest HAP Emitted(in pounds) : Five Year Violation�Historv. Date Letter Type Rule Violated Violation Resolution Date 01/09/2011 NOV/NRE Permit Late Title V ACC 03/09/2011 03/11/2010 NOV Permit Late Title V ACC 03/11/2010 Performed Stack Tests since last FCE. None Date Test Results Test Method(s):. Source(s)Tested I, MACTIGACT 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 both Elizabethtown Energy and Lumberton Energy. Randy is also the only full-time employee at either facility. Both Elizabethtown and Lumberton Energy plants have been shut down 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 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 I&M responsibilities outlined in the permit, quarterly,to assure that they are being completed. (4) PERMITTED EMISSION SOURCES: Enitz°SaJ.0ri n aOntFOI � t + Em`tsston,Sot rCe SPUfGe� " � DesCrC d DteSt�se Con-col Devt©egDeservpttOn , t6:46<.I No :vu -6...,..., 66eF p vines r, xis a Er IDftvlftl `3 t *' v tt } ai _xs__....._:v�_:G . ._.Yw,...vay.m- two coal/natural gas/No. _ CD-1A3' & g two selective non-catalytic reduction systems 2 and No. 4 fuel oil/tire CD-1B3* y (300 Ibs/hr aqueous ammonia injection rate a derived fuel/pelletized CD-1A2' & each) ES-1A and '_ paper fuel/flyash ii CD-1 B2 two multiclones (132 Nos. tubes each, 9 inches ES-1 B € briquette/non-CISWI Ij CD-1A4f & in diameter each) PSD subject wood-fired CD-164*' 1 two dry sorbent injection systems (50 Ibs/hr f CAM steam, electric sodium bicarbonate or sodium sesquicarbonate f generating, boilers (215 CD-1A & F (trona) injection rate each) MBtu/hr heat input CD-1 B' two bagfilters (each not to exceed 3.26:1 air-to- each) cloth rats sES-2A and f CD 2A & two bagfilters (64 square feet of filter area, 1 two coal bunkers ES 2B PSD CD 26 each ` ...a,... . o�= ` ES 3 PSD one fly ash silo w/wet CD 3 one silo binvent filter(400 square feet of filter unloadin slurr pugmill area) x �Y. ,a ES-4 PSD one bottom ash silo CD-4 one silo binvent filter(100 square feet of filter area s CD-5E I cyclone (42 in diameter) on the bottom ash silo ES-5A and two ash system vacuum CD-5D bagfilter(528 sq ft filter area) on the fly ash silo y CD-5C cyclone (42 inches in diameter) on the fly ash ES-513 PSD transport pumps j CD 5A & silo �_uu CD 5B I two m line filters one per pump M ES 6 PSD t coal Wetsup S wet suppression/chemical binder unload/store/transfer . r _ ammonia sto age tank None N/A ES-15 ., .; ES-1 diesel Iired 340 hp None N/A�L �� emer er fire um ES 1R ��FosterWheeler li 1985 ���j 6705 _.m.�� 1750psig ES 2A Foster Wheeler �I 1985 6708 1750 psig ,I .�m ....... Insignificant Activities: IES-2 j one diesel fuel oil storage tank IES-3 one fire pump fe 1 oil storage tank IE S-4 one e solvent olvent pa pa rts clean s_ -..nwer__�w ,..,. ... ..A. ........... w.._ d IES-5 one turbine Iube oil tank vent IES-6 ��one cooling tower -__ ,. -( .... .u-t-a- . ............. .. ...........w. . w . IES-7 � tare shredders (Never/ns, talled) IES-8 I truck 1 for receiving biomass fuel (Not Yet Installed) IES-9 truck dum er 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 (Not Yet Installed) m IES-12 paved roads IES-13 ' one sorbent silo li IES-14 �1 one bottom and sifting ash bunker �E ............................_...._. IES-UNPVDRD 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. 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 burning 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. 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/Recordkeepina/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 3121/14. 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 _ .........e... ... .. ...... 5 i M; r , ...M. 0 .0F28_.... .....m i PM (TSP) i �i 7 _,..... NOx 0.56 _ Mon itoring/Recordkeepina/Reportina 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. When burning non-CISWI sub[ect wood The following Best Available Control Technology (BACT) limits shall not be exceeded: �...- -.� . v-._...�_ m_ CO 0.45 Ib/MBtu 1 good combustion control Boilers q [stack test: 3-run average] , i ES-1A and ES-1 B u Sulfuric aad 0 011 Ib/MBtu use of low sulfur wood mist �1 Lstack test: 3 run average] .. m------ -----------............................ 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. Monitoring/Recordkeeping or Reporting No monitoring/record keeping shall be required for emissions of CO and sulfuric acid mist from boilers. Apparent Comollance 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 sub[ect wood The followin2 Best Available Control Technology (BACT) limits shall not be exceeded: ,..,..... .. .....,. ,,..„M......,,.,._.ilter...m.._. _n��.�.n.m......... .........,.. mm.,.m. .s..,_....�. ` PM/PM10 0.036 Ib/MBtu(both f lterable and condensable) multiclone and bagfilter [stack test 3-run average] ]9 alb 0 011 Ib/MBtu (both flterable and condensable PMz s [organic and inorganic including sulfuric acid I mulhclone and bagfilter Boilers mist]) [stack test 3 run average] (ID Nos. ES- 1Aand ES- SOz 0 025 Ib/MBtu * [CEM 30 day rolling average] use of low sulfur wood 1 B) NOx 0 1251b/MBtu [CEM 30 day rolling average] SNCR VOC 0.031b/MBtu [stack test 3 run average] good combustion control Hg 3 5 x 10 s Ib/MBtu [stack test 3-run average] [ bagfilter _,m -_..n. ...w Testing Permittee shall demonstrate compliance with the emissions limits for PM/PMro, PM2 ,S02, 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 S02 BACT emission limit shall be established using the representative stack test data, S02 CEMS data, boiler operational data, and fuel sulfur content data.A testing protocol that describes how the final S02 BACT emission limit will be established shall be approved by the DAQ. Mon itoring/Record keeping a. The Permittee shall monitor NOx and S02 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/PMio, 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 Reporting a. Reporting requirement for PM emissions from boilers above shall be sufficient to assure compliance with PM/PM,o, PM2.5 and 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. 15A NCAC 2D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY for 40 CFR 63 Subpart JJJJJJ, Industrial, Commercial and Institutional Boilers. The permittee shall meet the requirements in the referenced federal regulation. The facility was required to conduct an energy assessment related to the two boilers by the deadline—21 March 2014—the day after the inspection. Deviation Noted. For the sources OD Nos. ES-1A and ES-1B1 the EA was not completed. Two coal bunkers ES-2A and ES-2121, 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 Monitoring/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/Recordkeeping : 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 Mon itoring/Record keep!nq/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. 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. Mon itoring/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. 16A 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/Recordkeepinq 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 table provides a summary of limits and standards for the emission source(s)described above: .........._._ d __ y ..__ lip mom € r Toxic r See Section 2.2 A 1 State only requirement i 15A NCAC 2D 1100 Ai t Pollutants See Section 2.2 A.3.State-only requirement 15A NCAC 2Q .0711 { 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 16A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES M o n i to ri n g/Re co rd ke e y i n g/Re p o rt i n g 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 Compllance 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 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 was May 3, 2013. The subject engine is on the EPA certified engine listing. "Facility-Wide Emissions —state enforceable only"" 15A NCAC 2D .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: �Acrolem 0064lb/hr I Ammonia Arsenic and inorganic arsenic 83.2 Ib/yr compounds �[ i - Benzene 19701b/yr Benzo(a)pyrene 9791b/yr ' Boilers Beryllium 411bs/yr ES-1A and ESAB Combined Emission Cadmium �] 15.81bs/yr Rate Chlor 0.77 lb/hr ine 18.6 lb/day Soluble chromate compounds,as chromium 0.036 lb/day I e uivalent €, Hydrogen chloride L,4 3 34 Ibs/hr Formaldehyde 1 89 Ib/hr Manganese and compounds �' 3.1 lb/day -RA N� � _ _. 9 Mercury,vapor �j 038lb/day 1 Nickel,soluble compounds,as I 0.341b/day nickel 1 Hexachlorodibenzo p-dioxin I j 6lbs/yr j 1,2 3 6 7,8 Vinyl chloride L67 4 Ibstyr Acrolem 5 75 x 10s Ib/hr .., w Benzene 2.91 x 10-0 Ib/yr Emergency Fire Benzo(a�pyrene �'� 5 86 x 10�Ib/yr Pump ES-1 .....v.. Soluble chromate compounds as 1 4.49 x 10s lb/day chromium(VI)equivalent Formaldehyde t 7 36 x 10-0 Ib/hr m :..._.-n.n........e.-..... Aqueous Ammoma Storage Tank ES-15 Ammonia 0.99 Ib/hr 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. Mon itoring/Recordkeeping 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: 3 i 3 fi} I 3 3 acetaldehyde � ®�� � � 6.8 1 3 butadiene u g)g k 11 9 w .». �chlorobenzene 14 46 chloroform ] 290 ( �� �ethylenedichlonde 260 s ......y�, , ,. .W».. methylene chloride 1600 i 0.39 y (methyl chloroform �s 250 64 met yl thyl �perclooethylen heee pentachlorophenol 0.063 0.0064 E Ps polychlorinated biphenyls �� 5.6 �T �� �5 I .. ...F........ . .,. ._�....�g ,.� .,, a...... .... -3 toluene ' 98 �� (_ 144 �. ..... .... tnchloroethylene 4000 trichlorofluoromethane i:__._._ --_ .----- --mF- � ......__... 57 16.4 a .. Monitoring/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, iv. 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. ii. The Permittee shall request and obtain written permission from the Fayetteville Regional Supervisor, Division of Air Quality, prior to burning the resins. iii. 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, ii. hours of start-up, and H. 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, ii. type of plant waste combusted, iii. quantity of waste materials combusted, V. 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, ii. quantity of TDF combusted, iii. feed rate of TDF to the boiler, V. 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, I. description of PPF combusted, H. quantity of PPF combusted, V. 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 H. 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. 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 i ES-Unit 1A Unit 1 f E 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 30"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 2010 March 11 Nov for failure to include General Conditions in the ACC (8) CONCLUSIONS/RECOMMENDATIONS: At the time of this inspection, March 20, 2014, Elizabethtown Energy appeared to be in compliance with their permit no. 05455/T17 issued May 8, 2012. Recommend that a Notice of Deviation be issued for missing the energy assessment required by 40 CFR 63 Subpart JJJJJJ.