AQ_F_0800107_20161122_CMPL_NRE-Resp

Huddleston, Betsy
From: Garald Cottrell <[e-mail]>
Sent: Tuesday, November 22, 2016 12:20 PM
To: Huddleston, Betsy
Subject: RE: Secondary power 30-day rolling averages NOV/NRE
Ok. In talking with the manufacturer(Babcock&Wilcox) on the ESP controller, they told me that the controller is
designed to operate in the automatic mode and that the proposed method to ensure "compliance" of a min 3.4 kW
doesn't take into account that the computer is managing the ESP to minimize emissions while reducing electrical
operating costs. As an example, the ESP works"harder" (ie power consumption goes up)when there is a heavy
particulate load.This may be a function of the firing rate of the boilers or just the type of fuel (bark compared to chips
to sawdust).
So, in essence,just because the kW was low is not indicative that the ESP was not doing its job, just that the particulate
load being seen by the ESP controller was low and therefore the ESP did not have to work as hard to remove it as
compared to the day the stack testing was done.
With that being said, I had a brief call with our ESP tech. Based on that discussion, I believe that we can go into the
controller package and dictate that while the controller is in Auto, that the minimum kW not be allowed to fall below
14 kW.
Thanks again and we will work to schedule a time for the tech to be onsite to make the adjustment.
.a;ra I d
From: Huddleston, Betsy [mailto:[e-mail]]
Sent: Monday, November 21, 2016 5:07 PM
To: Garald Cottrell <[e-mail]>
Cc' Bright, Robert L<[e-mail]>
Subject: Secondary power 30-day rolling averages NOV/NRE
Hi Garald,
The Excel file I emailed you where I attempted to re-calculate the 30-day rolling averages to compare to your averages is
incorrect, so please discard. I forgot that each average has to count back for every operating hour over 30 calendar
I
ays (and some of the days are shut down days that aren't in your spreadsheet).
I'did present your original submitted ESP secondary power thirty-day rolling average data to Rob Fisher, and it's been
decided that DAQ will issue a Notice of Vio►ation/Notice of Recommendation of Enforcement for averages that fell
below 3.4 kW. The NOV/NRE will cite that there are 53 operating days during which the average fell below the
minimum.
Note in the attached that I've highlighted some calendar days in yellow that did not appear to be labeled in the Excel
file, but do look to be separate operating days.
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The NOV/NRE letter should be issued Wednesday this week. Just let me know if you want an electronic copy emailed to
you. You'll have a couple of weeks to respond to it before the Washington Regional Office assembles any enforcement
package to Raleigh Stationary Source Compliance Branch.
Betsy Huddleston
Division of Air Quality
North Carolina Department of Environmental Quality
252 948 3836 office
252 975 3716 fax
Betsy.Huddleston(@ncdenr.gov
943 Washington Square Mall
Washington, NC 27889
..-�Nothtng Cornpares.,,,,_
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
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