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ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretary
MICHAEL ABRACZINSKAS
Director April 14, 2020
Mr. Francis Hayward
Plant Manager
Capital Power Corporation
P.O. Box 10836
1281 Powerhouse Drive SE
Southport,North Carolina 28461
Subject: 4"Quarter 2019 Continuous Emissions Monitoring Compliance Report(CEMCR)
4"Quarter 2019 Excess Emission Report(EER)
Air Permit No. 05884T21
Facility ID No. 1000067
Dear Mr. Hayward,
The Division of Air Quality(DAQ)has received the subject reports (CEMCR and EER) submitted by
The Capital Power Corporation in a letter dated January 16,2020. The reports were submitted for the
continuous emission monitoring system(CEMS)and continuous opacity monitoring system(COMS)
operating on electric generating Unit 1 and Unit 2, each consisting of three Boilers with the common
stack.
DAQ has reviewed the quarterly reports for the period ending December 31,2019. The percent excess
emissions(%EE)and percent monitor downtime(%MD) are summarized as follows:
Emission Unit Pollutant % EE %MD Emission Applicable
Violations Regulation
CEMCR
Unit 1 NOx 0.00% 0.38% 0 §60.44b(a)/60.44b(c)
Boiler No. 0.00% 0.44% NCAC 213 .0530
ES-1-IA 0.00% 0.44% NCAC 2D .0501 c
ES-1-1B S02 0.00% 0.66% ----- NCAC 2D .0530, .0516, & SB3
ES-1-IC 51.91% 0.63% NCAC 2D .0501 c
Common Stack Opacity 0.00% 0.68% ----- §60.43b
CO 0.00% 0.44% ----- NCAC 2D .1109& .0501 c
Unit 2 NOx 0.00% 0.44% 0 §60.44b(a)/60.44b(c)
Boiler No. 0.00% 0.44% NCAC 2D .0530
ES-2-IA 0.00% 0.44% NCAC 2D .0501 c
ES-2-1B SO2 0.00% 0.44% 0 NCAC 2D .0530, .0516, & SB3
ES-2-IC 49.29% 0.47% NCAC 2D .0501(c)
Common Stack Opacity 0.00% 0.63% ----- 60.43b
CO 0.00% 0.44% 1 ----- NCAC 2D .1109& .0501 c
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North Carolina Department of Environmental Quality I Division of Air Quality
217 West Jones Street 1 1641 Mail Service Center I Raleigh,North Carolina 27699-1641
919.707.8400

Mr. Francis Hayward
April 14,2020
Page 2
A review of the quarterly excess emissions reports(EER) indicated there were no violations of the
applicable emissions standards.Please note that the SOa excess emissions of 51.91% and 49.29%for the
Unit 1 and Unit 2 are addressed in the Special Order by Consent(SOC 2016-001)signed on June 24,
2016. The other excess emissions noted above are excused pursuant to the applicable regulation. Please
note that each exceedance of the emission control standard unless excused by applicable regulation can be
credible evidence of a violation consistent with 40 CFR 60.11(g).
On December 27,2019 Mr.John Proulx of VIM Technology indicated in his e-mail that%MD is
calculated on a per boiler operating hours. Based on our review of the of the 4'Quarter EERs., it appears
that%MD is calculated on a per boiler operating hours for some units but not for all the units. We
indicated in our e-mail dated November 12, 2019 that the monitor downtime should be calculated at the
boiler level based on the individual boiler operating hours and the corresponding available valid hours of
CEMS emission data for that boiler,without using the data substitution. Please confirm that the software
error is rectified and 2019 4th Quarter%MD is properly calculated and reported on a per boiler operating
hours.
The reports were also reviewed with the general provision of 40 CFR 60.1 l(d), and 40 CFR 60.13 to
assess good operation and maintenance(O&M)practices for the facility and monitoring systems. As
summarized in the table on the previous page,the emission units and associated CEMS/COMS
appeared to have operated using good O&M practices since quarterly percent excess emissions(%EE)
and percent monitor downtime(%MD)were less than 3%for two consecutive quarters and 6% for any
single calendar quarter.
The CGA(NOx, SO2 and CO)result for the Unit 1 and Unit 2, conducted during fourth quarter were
within 15% specification given in 40 CFR 60,Appendix F.
The opacity monitor appears to meet the requirements of QA/QC rule(40 CFR Part 60,Appendix F,
Procedure 3).
Due to COVID-19 restrictions on DAQ staff and our office operations,the mailing of this letter may be
delayed. hi the meantime, an electronic copy(e-copy)is being provided for your records. If you should
have any questions,please contact me at(919) 707-8409 or samir.parekh(kncdenr.gov.
Sincerely,
Samir Parekh,P.E.,Environmental Engineer
Division of Air Quality,NCDENR
cc: Gary Saunders
Brad Newland—WiRO
Central File—Brunswick Co.
IBEAM—Documents— 1000067

Mr. Francis Hayward
April 14,2020
Page 3
Mr. Sean Spain
Plant Manager
NAES Corporation
Kings Mountain Energy Center
181 Gage Road
Kings Mountain,NC 28026

Mr. Francis Hayward
April 14,2020
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April 14,2020
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