AQ_F_1900134_20210618_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Raleigh Regional Office WTW
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AIR QUALITY Duke Energy Progress,LLC-Cape Fear STAR
Facility
Inspection Report NC Facility ID 1900134
Date: 06/18/2021 County/FIPS:Chatham/037
Facility Data Permit Data
Duke Energy Progress,LLC-Cape Fear STAR Facility Permit 10583/RO1
500 C P and L Road Issued 5/13/2020
Moncure,NC 27559 Expires 5/31/2027
Lat: 35d 35.2740m Long: 79d 1.9986m Class/Status 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
Jonathan Stamas Issa Zarzar Erin Wallace MACT Part 63: Subpart ZZZZ
Environmental Specialist GM CCP Project Lead Environmental NSPS: Subpart IIII
SME Management Specialist
[phone] [phone]
Compliance Data
Comments: In compliance.
Inspection Date 06/18/2021
Inspector's Name Dawn Reddix
Inspector's Signature: Dawn Reddix �1 , Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: June 18,2021 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
No emissions inventory on record.The emissions inventory is due June 30th of every year.
*Highest HAP Emitted in ounds
Five Year Violation History: None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:
Date Test Results Test Method(s) Source(s)Tested
01/27/2021 Pending
(I)DIRECTIONS:Duke Energy Cape Fear STAR Facility is located off Corinth Road at 500 CP&L
Road in Moncure, NC. From the RRO, head west on Barrett Drive, and turn right onto Six Forks
Road (0.7 mi). Turn left to merge onto 1-440 W. Keep left to stay on I-44OW (approx. 7.6 mi).
Keep left to continue on US-1 South (18.1 mi). Take exit 84 for Old US 1 (.3 mi). Turn right onto
State Road 1011/Old US 1 Hwy/Old US Hwy 1 (3.5 mi). Turn left onto Corinth Road(1.5 mi). Turn
right onto CP&L Road(0.5 mi). Stop at the automatic gate,put in the listed code to speak to security

and gain access to the facility. Park at the building on the left and meet the contact there.
II FACILITY DESCRIPTION: Duke Energy Progress, LLC—Cape Fear STAR Facility is a new,
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greenfield, coal ash beneficiation facility that is located at the site of the Progress Energy Carolinas—Cape
Fear Plant(Facility ID 1900134). Coal ash beneficiation uses a thermal process that transforms coal ash from
an unusable byproduct to a usable product. In this case,the staged turbulent air reactor(STAR) will process
fly ash into a material that is suitable for use as a replacement for Portland cement.
Safety Equipment: steel toed shoes; long sleeve shirt, hard hat, gloves, safety vest, hearing protection and
safety glasses.
(II1) INSPECTION SUMMARY: On Friday,June 18, 2021, Abdul Kadir and I, Dawn Reddix, traveled to
the Duke Energy STAR facility to conduct an air quality compliance inspection. We met with Mr. Jonathan
Stamas, Environmental Specialist SME, and Ms. Erin Wallace, Lead Environmental Specialist at the Duke
Energy site at 500 CP&L Road in Moncure,NC. We discussed safety and Mr. Stamas made requested copies
of the diesel engine maintenance records. Other records were emailed and reviewed in advance. Mr. Stamas
talked about how the STAR site is operated by the SEFA group,but the permit is held by Duke Energy, so all
correspondence, and site visits should be coordinated through Duke Energy. The permit conditions were
discussed during a TEAMS meeting on Friday, June 4, 2021. After the safety briefing, the four of us took a
Duke Energy truck to the STAR reactor site,which is about 0.5 miles down the road from the meeting
location. Sign ins were required at the first meeting point at the 500 CP&L Road Duke Energy location and
then also at the site of the STAR facility. We met with Mr. Todd Wilson, SEFA,who first directed us to a
conference room to watch a fifteen-minute safety video;he then led us on a tour of the site. Observing all of
the permitted and insignificant equipment required a walk around the site of the actual reactor, and then a
subsequent view of the ash basin,haul roads and screens and other related insignificant sources from the Duke
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Energy truck. There were no visible emissions, fugitive dust, or odorous emissions observed.
(IV)PERMITTED EMISSION SOURCES: At the time of the inspection, Duke Energy Progress, LLC-
Cape Fear STAR Facility was operating under Air Permit No. 10583R01,which was issued on May 13,2020,
expires on May 31, 2027, and includes the following emission sources and control devices:
Emission Control
Page Source Emission Source Description Device Control Device
No(s) ID No. ID No. Description
4 ES-5 STAR'(Staged Turbulent Air Reactor) CD-5A Dry FGD scrubber in
ash beneficiation process with a 140 series with a
million Btu per hour total maximum
firing rate,processing feedstock(fly ash CD-5B Baghouse(26,790
and other ingredient materials)into square feet of surface
commercial products and equipped with area)
propane low-NOx start-up burners(60
million Btu per hour maximum total
capacity)for use during start-up or
when necessary to maintain the desired
reactor temperature; an integral cyclone
and ba filter for product recovery

Emission Control
Page Source Emission Source Description Device Control Device
No(s) ID No. ID No. Description
8 ES-8 External heat exchanger A with 70 tons CD-8 Baghouse(20,925
per hour nominal capacity square feet of surface
area
8 ES-9 External heat exchanger B with 70 tons CD-9 Baghouse(20,925
per hour nominal capacity square feet of surface
area
10 ES-23 Crusher diesel-fired engine(300 N/A N/A
NSPS IIII horsepower)
GACT
ZZZZ
12 ES-15 Ash Basin N/A N/A
All emission sources were viewed during the compliance inspection.
(V)APPLICABLE AIR QUALITY REGULATIONS: To avoid redundancy in this report,the applicable air
quality regulations are discussed individually,and all the permitted emission sources that are subject to a
specific regulation are noted.
(1) 15A NCAC 2D.0515:PARTICULATES FROMMISCELLANEOUS INDUSTRIAL PROCESSES-
The following emission sources are subject to 2D.0515: STAR®(Staged Turbulent Air Reactor)
ash beneficiation process(ID No. ES-5)equipped with propane low-NOx startup burners
controlled by a FGD scrubber(ID No. CD-5A)and a baghouse(ID No. CD-5B); Two external
heat exchangers A and B(ID Nos. ES-8 and ES-9)with baghouses (ID Nos. CD-8 and CD-9)
IN COMPLIANCE— Particulate matter from the STAR(ES-5) is controlled by bag house CD-5B;
Particulate matter from the heat exchangers is controlled by baghouses CD-8 &CD-9. To demonstrate
compliance,the permittee must keep an inspection and maintenance logbook. The inspections and
maintenance required includes monthly visual inspections for leaks of the system ductwork,monthly
readings on the pressure gauges on the bagfilters,and an annual internal inspection of the bag filters. The
following was noted from logbook pages—The last monthly inspection was May 3,2021; all pressure
gauge readings were within the normal range,no annual internal inspection date noted as we are in the
first 12 months of operation.
(2) 15A NCAC 2D.0516:SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES- The
following emission sources are subject to 2D.0516: STAR®(Staged Turbulent Air Reactor)ash
beneficiation process(ID No. ES-5) equipped with propane low-NOx startup burners controlled by
a FGD scrubber(ID No. CD-5A) and a baghouse(ID No. CD-5B); Crusher diesel-fired engine(ID
No. ES-23)
IN COMPLIANCE—The SO2 emissions from(ES-5)are limited to 2.3 pounds per million Btu heat
input. To ensure compliance,the permittee must: operate FGD scrubber(CD-5A)any time the reactor is
in operation other than during startup, shutdown or malfunction; install a sulfur dioxide continuous
emissions monitoring(CEM) system including any required diluent monitor system;demonstrate
compliance with SO2 emission standard based on a three-hour rolling average of the sulfur dioxide
exhaust gas concentration measured by the CEM system;develop and implement a written quality
assurance program(40 CFR Part 60,Appendix F, Section 3,Quality Assurance Procedures); submit

semiannually an excess emissions and monitoring systems summary report; & submit semiannually an
emission report based on CEMs data.
A review of scrubber log demonstrated FGD scrubber is operated when reactor is operating;reported data
demonstrated SOz emissions comply with standard based on 3 hour rolling average; Mr. Stamas sent over
a digital copy of the 54-page Ash Beneficiation CEMS Quality Assurance Plan, Revision 0, dated August
2020. The first semiannual report with data will be for 1 H 2021. The facility did submit a semi-annual
report on January 25,2021,but there was no data to report. No monitoring/recordkeeping/reporting is
required for sulfur dioxide emissions from the firing of No. 2 fuel oil in ES-23.
(3) 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS—The following emission sources are
subject to 2D.0521: STAR®(Staged Turbulent Air Reactor)ash beneficiation process(ID No. ES-
5)equipped with propane low-NOx startup burners controlled by a FGD scrubber(ID No. CD-5A)
and a baghouse(ID No. CD-5B); Two external heat exchangers A and B(ID Nos. ES-8 and ES-9)
with baghouses(ID Nos. CD-8 and CD-9); Crusher diesel-fared engine (ID No. ES-23)
IN COMPLIANCE—Visible emissions from(ID Nos. ES-5,ES-8,ES-9& ES-23) shall not be more
than 20 percent opacity. Once a month,the Permittee shall observe the emission points of these sources
for any visible emissions above normal. The results of the monitoring(and any needed corrective action)
shall be maintained in a logbook. I reviewed the logbook, it does demonstrate monthly evaluations No
observations were recorded above normal. May 3 was the date of the last monthly VE observation for
each source. The facility submitted the records of establishing normal VE within 30 days of startup of
equipment. The normal was established on January 11, 2021, within 30 days of the 12/29/20 startup for
ES-8 and ES-9 and the 1/3/21 startup of ES-5. The facility described normal as being able to see a heat
wave from the stack,& sometimes water vapor,but no smoke or solids.No VE monitoring,
recordkeeping, or reporting is required when firing No. 2 fuel oil in No. ES-23.
(4) 15A NCAC 2D.0611:MONITORING EMISSIONS FROM OTHER SOURCES—The following
emission sources are subject to 2D.0611:STAR®(Staged Turbulent Air Reactor)ash
beneficiation process(ID No. ES-5) equipped with propane low-NOx startup burners controlled by
a FGD scrubber(ID No. CD-5A) and a baghouse(ID No. CD-5B)
IN COMPLIANCE— Emissions of sulfur dioxide(SO2) from the STAR ash beneficiation process(ES-5)
shall be controlled by a FGD scrubber(CD-5A). Permittee shall keep a logbook that documents
performance of inspections and maintenance and needed corrective actions,that include, as a minimum,
an annual(for each 12-month period following the initial inspection)internal inspection of the dry FGD
scrubber(including injection nozzles,pumping systems, and associated controls). I reviewed the logbook
that shows routine maintenance on multiple days during the months,exceeding the minimum
maintenance required. No annual internal noted(in 151 12 months of operation). The last entry for
monthly maintenance was dated May 31,2021.
(5) NCGS 143-215.108: CONTROL OF SOURCES OF AIR POLLUTION,PERMITS REQUIRED—
The following emission sources are subject to NCGS 143-215.108:STAR®(Staged Turbulent Air
Reactor)ash beneficiation process (ID No. ES-5)equipped with propane low-NOx startup burners
controlled by a FGD scrubber(ID No. CD-5A) and a baghouse(ID No. CD-5B)
IN COMPLIANCE— NCGS 143-215.108 requires Permittee to verify NOx emission factor specified in
Permit Application No. 1900134.18A by testing the reactor(ID No. ES-5) for NOx emissions. Testing
was required to be performed in accordance with General Condition 17-with a testing protocol approved
by the DAQ; testing required to be completed within 90 days of initial startup of the reactor. The final air

emission test report required to be submitted to the DAQ within 30 days after sample collection. Testing
was completed on January 27,2021,which was within 90 days of the initial startup of the reactor on
January 3,2021. The testing protocol was approved by DAQ with a review date of January 25,2021.
The final test report was submitted on February 12,2021 which was within the 30 days of the sample
collection. The final SSCB memo has not been issued for this test report.
(6) 15A NCAC 2D.0524:NEW SOURCE PERFORMANCE STANDARDS(NSPS)SUBPART IIII
REQUIREMENTS- The following emission sources are subject to 2D.0524: Crusher diesel-fired
engine (ID No. ES-23)
IN COMPLIANCE— Permittee shall use diesel fuel in the engine with max sulfur content 15 ppm.
Permittee shall keep a logbook that demonstrates recommended inspections and maintenance; if a PM
filter is used,keep records of corrective action taken after the high backpressure limit is approached.
Permittee must also keep documentation from the manufacturer that the engine is certified. Mr. Stamas
indicated that this permitted piece of equipment has not yet been received on site. As such,there are no
inspection and maintenance logs to review. The facility did send over a copy of the US EPA 2019 -year
Certificate of Conformity issued to Perkins Engine Co. Ltd—effective date—December 31,2018. A
copy of fuel oil receipt indicates diesel fuel with 15 ppm sulfur content.
(7) 15A NCAC 2D.I I11:MAMMUM A CHIE VABLE CONTROL TECHNOLOGY(MA CT) SUBPART
ZZZZ REQUIREMENTS—The following emission sources are subject to 2D.I111: Crusher diesel-
fired engine(ID No. ES-23)
IN COMPLIANCE—For this source(new stationary RICE located at an area source of HAP emissions),
the Permittee meets the requirements of Subpart ZZZZ and Subpart A by meeting the requirements of
Subpart IIII(see entry 6 above). The crusher has not yet been brought on site.
(8) 15A NCAC 02D.0535 EXCESS EMISSIONS REPORTING AND MALFUNCTION—All of the permitted
emission sources are subject to 2D.0535.
IN COMPLIANCE— The permittee shall notify DAQ with specific information by 9:00 am the next
business day of any excess emissions event that last for more than four hours resulting from a
malfunction,breakdown, or other abnormal conditions. Mr. Stamas indicated that there have been no
excess emissions events.
(9) 15A NCAC 02D.0540:PARTICULATES FROM FUGITIVE D UST EMISSION SOURCES—All of
the permitted emission sources are subject to 2D.0540.
IN COMPLIANCE— The Permittee shall not cause or allow fugitive non-process dust emissions to cause
or contribute to substantive complaints. There was no evidence of fugitive dust during the inspection;
there are no fugitive dust complaints against the facility.
(10) 15A NCAC 2D.1100: TOXIC AIR POLL UTANT EMISSIONS LIMITATION AND REPORTING
REQUIREMENT-All the permitted emission sources are subject to 2D.I 100.
IN COMPLIANCE— The Permittee has evaluated necessary toxic air pollutants and demonstrated
compliance with the permit limits in accordance with the completed permit application(1900134.20A).
No testing/monitoring/recordkeeping/reporting is required.
(I1)15A NCAC 02Q.0711: EMISSION RATES REQUIRING A PERMIT—All the permitted emission
sources are subject to 2Q.0711.

IN COMPLIANCE— For the listed pollutants,the Permittee has made a demonstration that facility-wide
actual emissions do not exceed the Toxic Permit Emission Rates(TPERs) listed in 15A NCAC 02Q
.0711(a). Continued compliance is expected as the facility is demonstrating that they are being operated
and maintained according to permit specifications. No monitoring,recordkeeping or testing is required.
(12)15A NCAC 02Q.0207: ANNUAL EMISSIONS REPORTING—All the permitted emission sources
are subject to 2Q.0207.
IN COMPLIANCE— The Permittee shall report by June 30 of each year the actual emissions of each air
pollutant listed in 15A NCAC 02Q .0207(a)from each emission source within the facility during the
previous calendar year. This condition was reviewed with the facility. Emissions reporting is expected
by June 30, 2021.
(13)1 SA NCAC 02Q.0304: APPLICATIONS—All the permitted emission sources are subject to 2Q
.0304.
IN COMPLIANCE— At least 90 days prior to the expiration date of this permit,the permittee will
request permit renewal by letter submitted to the Regional Supervisor. This condition was discussed with
the permittee.
(14)15A NCAC 02Q.0504: OPTION FOR OBTAINING CONSTRUCTION& OPERATION PERMIT
—All the permitted emission sources are subject to 2Q.0504.
IN COMPLIANCE—The Permittee is required to the Regional Office in writing of the date of beginning
operation of the first of the sources in Section 1 of the permit to startup,postmarked no later than 30 days
after such date. The Permittee shall file a Title V Air Quality Permit Application on or before 12 months
after commencing operation of any of the sources listed in Section 1.0 of this permit. The permittee
submitted the written notification of startup of equipment on September 24,2020,within 30 days of the
actual startup date(9/16/2020). The Title V Permit Application must be filed not later than September
24, 2021. This condition was discussed with the facility representatives. Ms. Wallace indicated that she
will make sure the application is submitted on time.
(VI) PERMIT EXEMPT EMISSION SOURCES: The facility currently has several emission sources included on
the Insignificant Activities List. No new exempt emission sources were observed during the inspection.
(VII) COMPLIANCE HISTORY: There are no compliance issues related to this site.
(VIII) 112(r)APPLICABILITY:—Duke Energy STAR is subject to the 112(r)-program general duty clause but
does not maintain sufficient quantities of regulated chemicals onsite to require a risk management plan.
(IX) STACK TESTING HISTORY: The facility was required to complete a stack test and submit the report within
a specified time frame. The testing was conducted on January 25-27, 2021 and the required report was submitted
within 30 days of the sampling as required. The SSCB memo has not yet been issued for this test.
(X)EMISSIONS INVENTORY: The calendar year 2020 emissions inventory is due by June 30,2021.
(XI) CONCLUSION/RECOMMENDATIONS: At the time of the inspection,the facility appeared to be in
compliance with all permitting requirements. It is recommended that this facility be re-inspected in one year.