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ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretary
MICHAEL ABRACZINSKAS August 27, 2020
Director
Mr. Rick R. Roper
General Manager III
Duke Energy Carolinas, LLC - Marshall Steam Station
8320 East NC Hwy 150
Terrell,N.C. 28682
SUBJECT: Review of 2020 Second Quarter CEMS Reports
Duke Energy Carolinas, LLC—Marshall Steam Station
Terrell, Catawba County,North Carolina
Air Permit No. 03676T57
Facility I.D. No. 1800073
Dear Mr. Roper:
Thank you for the timely submittal of the subject reports, dated July 13, 2020. The reports
included an assessment of the continuous emissions monitoring systems (CEMS) operating on
Marshall Steam Station's Units 1 and 2 Boilers as a combined stack (CS 1), Unit 3 Boiler(ES-3)
and Unit 4 Boiler(ES-4) during the second quarter of 2020. The Division of Air Quality (DAQ)
has completed its review of the CEMS-related information for the coal-fired units and has the
following comments:
1. The quarterly excess emissions report(EER) was reviewed for compliance with applicable
state emission standards for particulate matter(PM), sulfur dioxide (S02), nitrogen oxides
(NOx) and mercury(Hg). There were no nonexempt exceedances reported for any of the
pollutants.
2. A review of the Mercury and Air Toxics Standards (MATS) compliance report (40 CFR Part
63, Subpart UUUUU-National Emission Standards for Hazardous Air Pollutants: Coal-
and Oil-Fired Electric Utility Steam Generating Units) for CS 1, ES-3 and ES-4 indicated
there were no exceedances of any MATS pollutants with applicable state emission standards.
3. A review was conducted for compliance with good operation and maintenance (O&M)
practices pursuant to NCAC 2D .0521 (g), NCAC 2D .0606, and General Condition F.
Unless otherwise specified in regulation, DAQ considers sources to have operated with
proper O&M if percent excess emissions (%EE) and percent monitor downtime (%MD) are
less than the target criteria of 6% for any single quarter and less than 3% for two consecutive
NORTH CAROHNAD_E Q
Depart—t of Environmental Duality
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. Rick R. Roper
August 27, 2020
Page 2
quarters. Based upon the reported information shown in the table below, the CEMS appear to
have operated using proper O&M practices for minimizing emissions. The table also
summarizes applicable limits, %EE, %MD and percent monitor availability(PMA) reported
for each unit:
Unit/CEMS %EE %MD PMA Applicable Regulation: Limit
CS1
PM 0.00 0.0 100 2D .0521(c): 40%
2D .0521(g): 0.8%EE
2D .0536: 20%AAO
2D .0606: 3%EE; 2%MD
SO2 0.00 0.0 99.9 2D .0501(e): 0.56 lb/mmBTU
2D .0606: 3% EE; 2%MD
0.00 0.0 100 2D .1111: 0.20 lb/mmBTU
NOx 0.00 -- 99.9 2D .0519: 0.8 lb/mmBTU
PM 0.00 0.0 100 2D .1111: 0.03 lb/mm Btu
Hg 0.00 0.0 100 2D. 1111: 0.011lb/GWh
Unit 3 (ES-3)
PM 0.0 0.1 99.9 2D .0521(c): 40%
2D .0521(g): 0.8%EE
2D .0536: 20%AAO
2D .0606: 3%EE; 2%MD
SO2 0.00 0.0 99.9 2D .0501(e): 0.56 lb/mmBTU
2D .0606: 3% EE; 2%MD
0.00 0.0 99.9 2D .1111: 0.20 lb/mmBTU
NOx 0.00 -- 99.8 2D .0519: 0.8 lb/mmBTU
PM 0.00 0.1 99.9 2D .1111: 0.03lb/mmBTU
Hg 0.00 0.1 99.9 2D.1111: 0.011lb/GWh

Mr. Rick R. Roper
August 27, 2020
Page 3
Unit/CEMS %EE %MD PMA Applicable Regulation: Limit
Unit 4 (ES-4)
PM 0.00 0.1 99.9 2D .0521(c): 40%
2D .0521(g): 0.8%EE
2D .0536: 20%AAO
2D .0606: 3%EE; 2%MD
SOa 0.00 0.0 99.9 2D .0501(e): 0.56 lb/mmBTU
2D .0606: 3% EE; 2%MD
0.00 0.0 100 2D .I 111: 0.20 lb/mmBTU
NOx 0.00 -- 99.9 2D .0519: 0.8 lb/mmBTU
PM 0.00 0.1 99.9 2D .I 111: 0.03lb/mmBTU
Hg 0.00 0.1 99.9 2D.II11: 0.011lb/GWh
4. We also reviewed the Absolute Correlation Audits (ACAs) for the PM CEMS on CS1, ES-3
and ES-4. The quarterly PM CEMS ACAs were performed in accordance with requirements
found at 40 CFR Part 60 Appendix F, Procedure 2. Based on our review, the results appear
to meet the requirements of Procedure 2 and are therefore acceptable.
Similarly, we reviewed the quarterly linearity tests for the Hg CEMS installed on CS1, ES3
and ES4. Based on our review, the results appear to meet the requirements of 40 CFR Part 63,
Subpart UUUUU, Appendix A, Section 5.1.2.2 and are also acceptable. A linearity test was
conducted on May 14, 2020, for the Hg CEMS installed on CS 1 following the 168 hours of
operation; and a second linearity test was conducted on May 15, 2020 for the second quarter.
5. Finally, annual average opacity(AAO)reports for CS1, ES-3 and ES-4 were reviewed for
compliance with the state-only 20% opacity limit(365-day rolling average) pursuant to NCAC
2D .0536 -Particulate Emissions from Electric Utility Boilers and Specific Condition 2.1.A.5.
The AAO reports, which were based on the compliance option when a PM CEMS is used,
indicated compliance with the permitted opacity limit.
Due to the COVID-19 restrictions on DAQ staff and our office operations, the mailing of this letter
may be delayed. In the meantime, an electronic copy (e-copy) is being provided for your records. If
you should have any questions,please contact me at [phone] or [e-mail].
S' cerely, _
Dennis U. Igb/oko, Environme al Engineer
Division of Air Quality,NCD Q

Mr. Rick R. Roper
August 27, 2020
Page 4
c: Rick Roper, Duke Energy (e-copy)
Ann Quillian, Duke Energy (e-copy)
Scott La Sala, Duke Energy (e-copy)
Bruce Ingle, DAQ MRO (e-copy)
Gary Saunders, DAQ RCO (e-copy)
IBEAM Documents, 1800073 (e-copy)
Central File, Catawba County