AQ_F_0900043_20150317_CMPL_InspRpt

_ NORTH CAROLINA DIVISION OF __ Fayetteville.Regional Office
AIR QUALITY North Carolina Renewable Power-Elizabethtown,
LLC
Inspection Report NC Facility ID 0900043
Date: 03/17/2015 County/FIPS: Bladen/017
Facility Data Permit Data
North Carolina Renewable Power-Elizabethtown,LLC Permit 05455/T20
3100 West Broad Street Issued 2/11/2015
Elizabethtown,NC 28337 Expires 12/31/2016
Lat: 34d 38.8086m Long: 78d 38.4900m Classification Title V
SIC: 4911 /Electric Services Permit Status Active
NAICS: 221112/Fossil Fuel Electric Power Generation Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V/PSD
Chris Colucci Chris Colucci Chris Colucci MACT Part 63: Subpart 6J,Subpart ZZZZ
VP of Operations VP of Operations VP of Operations
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 03/17/2015
��� Inspector's Name Joshua L.Harris
Inspector's Signature: Y�� �' /—� Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: p,31z On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2013 --- 0.0500 0.3100 0.0100 --- 0.0229
2012 --- 0.0600 0.3100 0.0100 --- 0.0279
2011 0.0500 0.3100 0.0100 --- 0.0274
*Highest HAP Emitted(inpounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
03/09/2011 NOWNRE Permit Late Title V ACC 03/09/2011
_ Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

L MACT/GACT._
The facility has an emergency fire pump(ES-1)that is subject to NESHAP 40 CFR 63, Subpart ZZZZ(4Z).The
boilers(ES-lA&B)are subject to NESHAP Subpart JJJJJJ(6J).
H. 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.
III. SAFETY: Standard FRO safety gear.
IV. FACILITY DESCRIPTION: North Carolina Renewable Power—Elizabethtown, LLC is the current name of a
facility that has a long list of previous owners,with the current owners purchasing the facility in August 2014,and
receiving their permit on 11 February 2015.Previously known as Elizabethtown Energy,LLC,the facility is an old
coal burning power plant,which houses two boilers and is permitted for a myriad of fuels.The facility, along with
its sister facility in Lumberton(7800166),is currently undergoing modification to allow the boilers to burn primarily
wood fuel,with some percentage of poultry litter to produce steam for energy production.
V. INSPECTION SUMMARY: On 17 March 2015,I,Joshua Harris, along with Robert Hayden,of the Fayetteville
Regional Office arrived at North Carolina Renewable Power—Elizabethtown,LLC in Elizabethtown,Bladen
County.Upon arrival,we found the gate to be chained and locked,and there was no apparent activity at the facility.
Earlier in the day,we met with Mr.Randy Coates,and Mr. Charles Gress,both of NRG Energy Services.Mr.
Coates has been listed as the facility contact in the past as the Plant Manager,and is a contracted operator for the
plant.Mr.Gress,a Business Development Manager from the Houston,TX office, is on-site temporarily at the
Lumberton plant to help get the plant up and running.The modifications to the Lumberton facility are being made
using parts scavenged from the Elizabethtown plant. Once the Lumberton plant is operational,the Elizabethtown
plant will be modified using new replacement parts. We were invited to visit the Elizabethtown plant,but were
informed that it was not manned.
The conversation with Mr. Coates and Mr. Gress echoed a conversation had on 13 Mar 2015 with Mr. Steve Ingle,
an engineer with Green Fuels Energy of Birmingham,AL. I,along with Steven Vozzo,RAQS FRO,spoke with Mr.
Ingle with regard to plans for the two facilities,and also to inquire about the absence of an ACC report. The ACC
was determined to be the responsibility of previous owner,who is in the process of getting the report submitted to
FRO and the EPA.During the conversation,Mr.Ingle expressed the desire to be informed in advance of future
inspections,as he would like to be present.Mr. Ingle also informed us that there will likely be a permit modification
submitted sometime in late March or early April that is intended to update the permit with the plant's future
operating conditions.

VI. PERMITTED EMISSION SOURCES:
*No sources were observed to be operating,nor have any sources operated at the facility since 2009. This list will
likely undergo many changes with the next permit iteration.*
,®,�1� H 9�' .: s
ES-IA and two coal/natural gas/No.2 and No.4 CD-IA3 and CD- two selective non-catalytic
ES-1B fuel oil/tire derived fuel/pelletized paper 1B3 reduction systems(300 lbs/hr
PSD fuel/flyash briquette/non-CISWI subject aqueous ammonia injection rate
CAM wood-fired steam,electric generating, each)
boilers(215 million Btu per hour heat
input each)including over-fire air CD-IA2 and CD- two multiclones(132 Nos.tubes
systems* 1B2 each,9 inches in diameter each)
CD-lA4 and CD- two dry sorbent injection systems
1B4 (50 lbs/hr sodium bicarbonate or
sodium sesquicarbonate(trona)
injection rate each)
CD-lA and CD-lB two bagfilters(each not to exceed
3.26:1 air-to-cloth ratio)
ES-2A and two coal bunkers CD-2A and CD-2B two bagfilters(64 square feet of
ES-2B filter area,each)
PSD
ES-3 one fly ash silo with wet slurry pugmill CD-3 one silo binvent filter(400 square
PSD for unloading feet of filter area)
ES-4 one bottom ash silo with a retractable CD-4 one silo binvent filter(100 square
PSD bulk unloading spout and enclosed vent feet of filter area)
return
ES-5A and two ash system vacuum transport pumps CD-5E one simple cyclone(42 inches in
ES-5B diameter)located on the bottom
PSD ash silo
CD-5D one bagfilter(528 square feet of
filter area)located on the fly ash
silo
CD-5C one simple cyclone(42 inches in
diameter)located on the fly ash
silo
CD-5A &CD-513 two in-line filters(one per pump)
ES-6 coal unloading/storage and transfer Wetsup wet suppression/chernical binder
PSD
ES-15 one 7100 gallons aqueous ammonia None N/A
storage tank
ES-1 one diesel fired 340 hp emergency fire None N/A
PUMP

VIL INSIGNIFICANT ACTIVITIES:
Insignificant Activities pursuant to 15A NCAC 2Q .0503(8)
Source ID No. Emission Source Description
IES-2 one diesel fuel oil storage tank
IES-3 one fire pump fuel oil storage tank
IES-4 one solvent parts cleaner
IES-5 one turbine lube oil tank vent
IES-6 one cooling tower
IES-7 tire shredders
IES-8 truck dumper No. 1 for receiving biomass fuel
IES-9 truck dumper No. 2 for receiving biomass fuel
IES-10 fuel storage piles
IES-11 fuel material handling including conveyors,
front-end loader/dozer and other vehicular
traffic in the fuel yard
IES-12 paved roads
IES-13 one sorbent silo
IES-14 one bottom and sifting ash bunker
IES-UNPVDRD unpaved roads
VIH. NON-COMPLIANCE HISTORY SINCE 2010:
03/25/2014 NOD for failure to conduct an energy assessment IAW NESHAP 67 requirements.
03/09/2011 NOWNRE for continuing late ACC submittal.Facility was assessed a$2,171 enforcement on 15
April 2011,which was paid in full on 17 May 2011
03/11/2010 NOV for late ACC.
IX. RISK MANAGEMENT(112r):This facility does not use or store any 112(r)subject materials above threshold
limits.
X. CONCLUSION AND RECOMMENDATIONS:
- North Carolina Renewable Power—Elizabethtown, LLC appeared to be in compliance with their air quality
permit at the time of the inspection.
- Recommend conducting regular compliance inspections,and maintaining contact with the facility operators
to determine a start-up date for the facility.
PINK SHEET ADDITIONS:
- None