AQ_F_0800107_20130221_CMPL_Fac-Ltr

/ ',ELLON C 1836 Eastchester Dr.
Suite 108%l Point,NC 27265
Energy Solutions Group H1gh 0:360.7503583
F:360.750.3483
February 13, 2013
Ms. Betsy Huddleston
Washington Regional Office
NCDENR-Division of Air Quality
943 Washington Square Mall
Washington,NC 27889
RE: Site Specific Monitoring Plan
Dear Ms.Huddleston;
Thank you for visiting our facility located at Lewiston, NC. We appreciate your time and consideration.
While you have not identified any major violations or issues, you have identified that a Site Specific
Monitoring Plan has not been filed with the NCDEQ as required. Please accept this Site Specific Monitoring
Plan as required under Permit#10126RO1.
Per the report conducted by Analytical Testing Consultants Inc. (ATC),testing confirmed that the particulate
emissions from the Lewiston facility are 0.0079 lbs/MMBtu. This actual performance is compared to our
permit requirement of 0.07 lb/IV MBtu.
As required by 15A NCAC 2D .I 111,the Permittee shall comply with the following requirements:
i. Establishing Operating Limits—The permittee shall establish the minimum secondary
power to the electrostatic precipitator during the three-run performance test for particulate
as required by 40 CFR 63.11211(b),Table 3, and Table 6 to Subpart JJJJJJ.
ii. Demonstrating Continuous Compliance(40 CFR 63.11222/Table 7 to Subpart JJJJJJ)—
The permittee shall:
A. Collect the secondary amperage and voltage, or total power input monitoring system
data for the electrostatic precipitator according to 63.11224 and 63.11220, and Table
7 to Subpart JJJJJJ;
B. Reduce the data to 12-hour block averages; and
C. Maintain the 12-hour average secondary amperage and voltage, or total power input
at or above the lowest 1-hour average secondary electric power measured during the
most recent performance test 63( 11214). Deviations from this requirement must be
reported in the annual compliance certification report.
Per 40 CFR 63.11222(a)(1), operation below the established minimum, or outsi e t allowable
range of the operating limits constitutes a deviation from the operating limits except during
performance tests conducted to determine compliance with the emission and operating
F E B 2 1 2013
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limits or to establish new operating limits. Operating limits are confirmed or
reestablished during performance tests.
The following is submitted and attached to confirm the above Site Specific Monitoring Plan has been
established.
1. A stack test was conducted to determine the emissions rate. See attachment 1 which confirms
that the facility particulate emissions are below the required 0.07 Ibs/MMBt.
2. Per Item i, "The permittee shall establish the minimum secondary power to the electrostatic
precipitator during the three-run performance test for particulate", See attachment 2.
Minimum Secondary power average kW usage during testing was determined to be 3.4 kW.
3. Demonstrate Compliance. Per item ii, the computer system maintains a 12 hour block average
(AM and PM). System is maintained so that average total power input is at or above the lowest
1-hour average of 3.4 kW as demonstrated during the stack test. This data is logged daily on
the operator log sheet. See attachment 3. As noted on the daily log, in the event that the 12
hour block average is below 3.4kW,operators must notify management personnel.
Should you have additional questions or require additional information, please do not hesitate in contacting
me at the number above.
Sincerely,
re11
President
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Attachment 1
Extract from ATC Stack Test Report conducted May 10`h,2012
Results
Results are presented in the preceding Summary. Additional information may be reviewed in the
Calculations and Appendix sections of this report.
Dining the particulate matter testing,actual velocity measurements averaged 49.95 feet per
second(ft/s) through the fourty-nine and a half(49.5) inch diameter exhaust stack yielding an
actual volumetric flow rate of 40,050 cubic feet per minute(acfin) for the three two hour runs.
Standard flows were calculated at 21,894 scfin and were based upon an average stack moisture
of 17.83%, stack temperature of 327.65°Fahrenheit, and a station (barometric)pressure of 29.70
inHg. Stack static pressure was measured at -0.25 inches of water.
During the CO measurements, actual velocity measurements averaged 49.04 feet per second
(ft/s)through the fourty-nine and a half(49.5) inch diameter exhaust stack yielding an actual
volumetric flow rate of 39,313 cubic feet per minute (acfin) for the three one hour runs.
Standard flows were calculated at 21,483 scfin and were based upon an average stack moisture
of 17.65%, stack temperature of 335.92°Fahrenheit, and a station (barometric)pressure of 30.00
mHg. Stack static pressure was measured at -0.16 inches of water.
Filterable particulate em' ' averaged 0.697 pounds per hour(lb/hr), 0.0037 grains per dry,
�1tu.standard cubic foot a 0.0
Carbon Monoxide emissions averaged 39.75 lb,In and 0.45 lb/MMBtuu.
Sampling and Data Issues
No sampling. data issues or method modifications were required during this test Program.
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Attachment 2
Flow and ESP kW rating during Stack Test
Run 2;1 Runr2 Run M3
Steam Flow ESP Steam Flow ESP Steam Flow ESP
Rate(PPM) kW Rate kW Rate kW
12:00 63,300 3.4 15:15 67,090 3.4 18:00 64,350 3.4
12:15 64,500 3.4 15:30 68,600 3.5 18:15 62,370 3.4
12:30 63,860 3.3 15:45 68,940 3.5 18:30 63,860 3.5
12:45 65,780 3.3 16:00 69,220 3.4 18:45 64,930 3.4
13:00 64,330 3.4 16:15 68,020 3.5 19:00 64,540 3.3
13:15 62,450 3.4 16:30 67,450 3.3 19:15 63,240 3.4
13:30 62,010 3.5 16:45 66,040 3.4 19:30 62,340 3.4
13:45 61,460 3.4 17:00 67,230 3.4 19:45 64,340 3.5
14:00 62,080 3.4 17:15 66,340 3.5 20:00 62,340 3.5
14:15 63,070 3.5 17:30 66,560 3.5 20:15 63,890 3.4
Average 63,284 3.4 Average 67,549 3.4 Average 63,620 3.4
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i
Attachment#3
Daily Operator Checklist and Data Log
Date
Operator
700 Hrs 1300 Hrs 1900 Hn 0100 Hrs
B1r A Blr B Blr C Blr A B1r B Blr C Blr A Blr B Blr C BIr A Blr B Blr C
Electric Meter Reading#1
Electric Meter Reading#2
Rain Gauge in (if�r thmi.5-,wny4e,awP—nqwd)
Steam Flow KPPH
Steam Pressure Header
Steam Pressure Line
Firing Rate
Exhaust Stack TerM
Furnace Draft"WO
0
P KW 12 Hr AVG AM(Cmraa FA*.r<34 kw
ESP KW 12HrAVG PM,(onwoFnNca-,4M
Heater Duct Corrtrol Te
ESP Purge Air Heater Overtrr e
ESP Field 91 Secondary Voltage
ESP Field#2 Secondary Voltage
ESP Hopp Heater#1 Tenip
ESP Hopper Heater#2 Ternp
Blow Down Water Column
Blow Down Triple Low Switch
Blow Down Sij#A Glass
Boiler Gas Outlet Temp
Bottom Blow Front Sidewall Headers
Soot Blow Economizer
Bottom Blow Back Sidewall Headers
Soot Blow Airheater
hispect Multiclone Discharge,Inspection Door
Air Compressor PSI
Air Compressor Tenip
Air Compressor Seperator and Dryer filter Diff
Blow Down Air Compressor Water Trap
Turbine Bearing Temperature
Turbine Bearing Vibration
FD Fan Outlet Temperature
Grate Water #operating)and Pressure
Grate Water Temperature
Feedwater #operating)and Pressure
Ash Container Ins ction and Level
ESP Ash Auger hispection
ESP Ash Roto Lock Inspection
Fuel Bunker Come or Chain Inspection
Fuel hlcline Conve or Chain Inspection
Turbine Bearing Oil Level
Turbine Vibration Level
Turbine Bean Te rnture
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