Page 1 of 32
Permit Issue Date:
Region: Mooresville Regional Office
County: Catawba
NC Facility ID: 1800073
Inspector’s Name: Tonisha Dawson
Date of Last Inspection: 06/03/2015
Compliance Code: 3 / Compliance - inspection
Facility Data
Permit Applicability (this application only)
NORTH CAROLINA DIVISION OF
AIR QUALITY
Air Permit Review
All applicable regulations subject to review
SIP:
NSPS:
NESHAP:
PSD:
PSD Avoidance:
NC Toxics:
112(r):
Other:
Applicant (Facility’s Name): Duke Energy Carolinas, LLC - Marshall Steam
Station
Facility Address:
Duke Energy Carolinas, LLC - Marshall Steam Station
8320 East NC Hwy 150
Terrell, NC
28682
SIC: 4911 / Electric Services
NAICS: 221112 / Fossil Fuel Electric Power Generation
Facility Classification: Before: Title V After: Title V
Fee Classification: Before: Title V After: Title V
Application Data
Facility Contact
J LaSala
Senior EHS Professional
(828) 478-7820
8320 East NC Hwy 150
Terrell, NC 28682
Authorized Contact
Rick Roper
General Manager III
(828) 478-7600
8320 East NC Hwy 150
Terrell, NC 28682
Technical Contact
William Horton
Lead Environmental
Specialist
(980) 373-3226
526 South Church Street
Charlotte, NC 28202
Application Number: 1800073.13B, 14E, 15C,
16A and 16B
Date Received: See chronology
Application Type: Renewal
Application Schedule: TV-Renewal/Modification
Existing Permit Data
Existing Permit Number: 03676/T53
Existing Permit Issue Date: 02/10/2017
Existing Permit Expiration Date: 01/31/2022
Total Actual emissions in TONS/YEAR:
CY
SO2
NOX
VOC
CO
PM10
Total HAP
Largest HAP
2014
5917.45
9917.04
100.94
2180.70
1004.30
99.98
84.76
[Hydrogen chloride (hydrochlori]
2013
4703.86
11854.28
89.99
1952.62
1201.47
105.27
86.10
[Hydrogen chloride (hydrochlori]
2012
4599.15
11027.63
105.42
2305.47
1070.66
141.29
116.74
[Hydrogen chloride (hydrochlori]
2011
3852.98
9086.27
132.55
2898.98
1809.95
179.07
147.14
[Hydrogen chloride (hydrochlori]
2010
3657.90
9608.90
145.52
3177.09
1295.51
192.06
160.65
[Hydrogen chloride (hydrochlori]
Review Engineer: Joseph Voelker
Review Engineer’s Signature:
Date:
Comments / Recommendations:
Issue 03676/T54
Permit Issue Date:
Permit Expiration Date:
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Purpose of Application
Duke Energy Carolinas, LLC - Marshall Steam Station (referred to as Duke or Duke Energy) operates four No.2 fuel oil / coal fired electric utility boilers. The purpose of this application(s) is to:







Subject the modifications addressed in permit no. T49 to the TV permitting process. (application no. 13B)
Renew the air permit as requested pursuant to application no. 14E
Modify the Title IV Acid Rain permit pursuant to application no. 15C
Renew the Title IV Acid Rain permit pursuant to application no. 16A
Subject the modifications addressed in permit no. T51 to the TV permitting process. (application no. 16B)
Address Applicability Determination no. 2953 - Request to burn coal contaminated by inadvertent spills
Address Applicability Determination no. 2954 - Coal Pile Dust Suppressant
Chronology
The following is a chronology of important dates relating to the applications currently being addressed at this time. See Section
III for the complete permitting history since last permit renewal.
Date
10/02/2013
3/13/2014
07/30/2014
12/11/2014
2/27/2015
06/26/2015
7/14/2015
11/19/2015
2/1/2016
2/29/2016
05/31/2016
7/1/2016
7/27/2016
08/11/2016
10/11/2016
Description
An application to incorporate the Condition 2.1.A.10 into the TV permit was received and assigned
application no. 13B. This is the “second step” for the modifications of condition 2.1.A.10
incorporated into Permit No. T49. See Section III for full description of application.
An application to add a portable hydrated lime dry sorbent injection system for SO3 control on Units
1 thru 4. and to add language to allow the use of PM CEMS for the Utility Mercury and Air Toxics
Standards (MATS) Rule compliance was received and assigned application no. 14B.
An application to renew the TV air permit was received and assigned application no. 14E.
Application no. 14B was amended to remove the request to add a portable hydrated lime dry sorbent
injection system for SO3 control on Units 1 thru 4.
Application no. 14B was amended and assigned new application no. 15A. This application is being
processed by Ed Martin in a separate permitting action.
An application to modify the Title IV Acid Rain permit was received and assigned application no.
15C.
An application to add Halide salt injection for the control of Hg for compliance with 40 CFR Part 63
Subpart UUUUU, “National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired
Electric Utility Steam Generating Units” (MACT 5U) was received and assigned application no.
15D. This application is being processed by Ed Martin in a separate permitting action.
An email was received requesting the removal of the CAIR requirements from the permit.
An application to renew the Title IV Acid Rain permit was received and assigned application no.
16A.
An addendum to application no. 15A was received. Ultimately, all requested items are addressed in
the current permitting action.
An application to incorporate the ES-U4ACIsilo and associated control device into the TV permit
was received and assigned application no. 16B. This is the “second step” for the modifications
incorporated into Permit No. T51. See Section III for full description of application.
Applications assigned to Joe Voelker
A request via email was sent to Bill Horton requesting information supporting the toxic air pollutant
(TAP) modeling demonstration approved by the DAQ on 01/26/2011.
Email response from Bill Horton stating
please use the air toxics air dispersion modeling analysis and files we previously submitted for your
evaluation of chromium VI (chromic acid) against the NC 24-hour AAL.
Email received from Bill Horton requesting to minimize permit condition renumbering.
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Date
11/7/2016
11/14/2016
11/21/2016
11/22/2016
12/13/2016
Description
ADD INFO email sent to Bill Horton requesting the Permittee to review and justify any permit shield
it wishes to keep in the revised permit.
ADD INFO email sent to Bill Horton requesting the Permittee to review and update the CAM
applicability analysis submitted with the renewal application (14E).
CAM information requested on 11/14/2016 was received via email.
An ADD INFO email was sent to Bill Horton stating that the removal of PSD avoidance condition
2.1.A.10 could not be removed based on the information available. A request was made for the
Permittee to submit calculations/supporting information to justify the removal of the condition
Information requested on 11/22/2016 was received via email. The calculations upon review show
that the original installation of the selective catalytic reduction (SCR) would not have triggered PSD
without the existence of the flue gas and flyash conditioning systems, which have been removed
from the permit
12/19/2016
Information requested on 11/7/2016 received via email.
01/17/2017
Draft of permit was sent to Bill Horton
02/08/2017
Comments on draft permit were received via email from Bill Horton.
02/10/2017
Permit No. T53 issued in response to application nos. 15A and 15D, which were processed by Ed
Martin. The draft permit sent on 01/17 and the comments received on that draft on 02/08 will
combined into the permit issued on this date. The revised draft will be resent to the Permittee.
02/27/2017
A revised draft permit was sent to Bill Horton
03/15/2017
Bill Horton responded via email stating the revised draft is acceptable.
MM/DD/YYYY
Public Notice published on NCDENR DAQ website; concurrent public/EPA comment period begins
MM/DD/YYYY
Public comment period ends. No comments received.
MM/DD/YYYY
EPA comment period ends. No comments received.
Permit History Since Last Renewal
The following are all the permitting actions completed since the last permit renewal (permit no. T46, issued 09/07/2010). The
descriptions contain excerpted language from the original permit reviews. Comments added by this review engineer are
indicated in italics. Current outstanding applications are noted in Section II.
Permit Issue Date
Permit No.
Application No.
Application Type
09/07/2010
T46
Description: Permit Renewal
.08A
TV-Renewal
Permit Issue Date
Application No.
Application Type
Permit No.
09/14/2010
T47
.10A
TV-minor
Description: Duke Energy Carolinas, Inc. (“Duke Energy”) has requested to obtain a permit approval to conduct evaluations
of mercury emissions control for Unit 4 boiler (ID No. ES-4) when spray-applying and injecting calcium dibromide and
powdered activated carbon, respectively.
This resulted in the addition of PSD and NSR avoidance conditions into the permit (conditions 2.1.A.14 and 15) and the
addition of control devices for Unit 4 boiler: systems for spray-applying calcium dibromide (ID No. CD-U4CaBr2(Temp))
and powdered activated carbon (ID No. CD-U4ActC(Temp)). Also, a new generator (ID No. ES-37(EmGenLF)) was added,
which required the submittal of a toxics demonstration by 09/29/2010.
Page 4 of 32
Permit Issue Date
Permit No.
Application No.
Application Type
08/26/2011
T48
0.11A
TV-Sign–501(c)(2)
Description: Duke Energy Carolinas is requesting a modification to the Marshall Steam Station’s current air permit to conduct
a short-term trial test study to evaluate the effectiveness of liquid calcium di-bromide (sorbent) on the control of mercury
emissions on Units 1 and 2. The study will be conducted over a two-week period where the calcium di-bromide (CaBr2)
solution will be spray-applied to the coal going into the boilers at a rate ranging from 0.25 – 2.5 lbs/ton of coal. Approximately
30,000 lbs of liquid CaBr2 (53% solution by weight) will be spray-applied onto approximately 37,500 tons of coal. Mercury
emissions before and after the test will be monitored using a speciated mercury CEM.
This study is similar to a study on Marshall Unit 4 in the fall of 2010, where CaBr2 and powdered activated carbon were both
used to determine the effects on mercury emissions; except powdered activated carbon is not being used for the Units 1 and 2
study.
Even though, as shown below, emissions are expected to be well below PSD significance, Duke has requested (permanent)
PSD and NSR avoidance conditions rather than a condition under 02D .0530(u) only requiring five years of reporting to
determine if the change results in a significant PSD net emissions increase. At this time the change is for a short-term study
and Duke states that if they pursue this sorbent injection long term, they would reapply and justify a change in the permit
language based on data gathered during the trial test. If they do not pursue sorbent injection long-term, they could apply to
have the PSD avoidance condition removed.
This is a significant Title V permit modification pursuant to rule 15A NCAC 02Q .0501(c)(2). Duke must submit a Title V
application for the changes made to permit Sections 2.1.A.16 and 2.1.A.17 on or before 12 months after commencing
operation. The permit shield described in General Condition R does not apply to these changes.
For Units 1 and 2, this resulted in PSD avoidance condition for PM/PM and NSR avoidance condition for PM 2.5 (conditions
2.1.A.16 and 17). This conditions have been subsequently removed from permit no. T51. As a result no “second step”
application has been submitted.
Permit Issue Date
Permit No.
Application No.
Application Type
01/15/2013
T49
0.12B
TV-Sign–501(c)(2)
Description: Duke Energy Carolinas is requesting a modification to the Marshall Steam Station’s air permit to revise the PSD
avoidance condition for sulfuric acid emissions in Section 2.1.A.10. This condition limits sulfuric acid emissions from Unit
3 to the PSD significance level of 7 tons per consecutive 12–month period. The condition was added to the permit in T41,
issued February 1, 2007, when a SCR NOx control system was permitted for the Unit 3 boiler, as a result of the increase in
sulfuric acid emissions resulting from the SCR. The avoidance condition required the coal sulfur dioxide content not to exceed
2.8 lb/mmBtu based on a 12-month rolling average. Duke is now requesting the condition be revised to increase the coal
sulfur dioxide content not to exceed 4.0 lb/mmBtu to allow Duke the flexibility to burn higher sulfur coals. However, DAQ
has determined that a better approach is to require the ammonia injection ash conditioning system to operate at all times when
the sulfur trioxide flue gas conditioning system is in operation rather than the coal sulfur dioxide (SO2) limit.
Duke is also requesting a change to the Unit 3 ammonia emission limit in Section 2.1.A.8.a.
Duke was asked to address and provided GHG emission information as required by the GHG “Tailoring” rule and 40 CFR
70.5(c) for sources with Title V permits when they apply for, renew, or revise their permits now that GHGs are a regulated
pollutant (see emissions information in email to Ed Martin from Bill Horton dated December 11, 2012).
This is a significant Title V permit modification pursuant to rule 15A NCAC 02Q .0501(c)(2). Duke must submit a Title V
application for the changes made to permit Section 2.1.A.10 on or before 12 months after commencing operation. The permit
shield described in General Condition R does not apply to this change.
The “second step” application has been submitted and is being processed as application no. 13B.
Permit Issue Date
Permit No.
Application No.
Application Type
04/19/2013
T50
.13A
TV-Minor
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Description:
Duke Energy is requesting a permit modification to allow permanent use of various alkaline-based fuel additives (e.g. Coal
Treat 300, 500 and 600) at a maximum rate of 7 pounds per ton of coal on an as-needed basis to reduce the formation of sulfur
trioxide in the boiler which in turn reduces condensable particulate emissions in the form of sulfuric acid mist and also to
reduce boiler slagging. Duke is testing these additives when burning various blends of Central and Northern Appalachian and
Illinois Basis coals in preparation to meet the Utility MATS rule. They originally requested written approval to conduct
temporary coal testing using the additives in a letter dated October 5, 2011, and were given approval to use the additives at
Allen, Belews Creek, Cliffside and Marshall through the end of 2012 in DAQ’s letter dated November 8, 2011; and approval
extending the test period through the end of 2013 was given in DAQ’s letter dated August 22, 2013. Duke submitted this
application (1800073.13A) in April 2013for long-term use of the additives; however, processing the application was delayed
due to workload and the permit could not be issued before the end of the extended test period (December 31, 2013) as Duke
expected. Therefore, Duke requested another extension of the test period to allow further testing until the application could
be processed to revise the permit permanently, and DAQ approved extending the testing through the end of 2014 in a letter
dated December 18, 2013. This approval also included the use of trona, which had been approved through December 31, 2013
in an email dated August 26, 2013 (Ed Martin to Bill Horton, cc J. Evans and D. van der Vaart).
The additives are drip- or spray-applied to the coal on the conveyor belts. No equipment or control devices require permitting.
This is a minor permit modification pursuant to rule 15A NCAC 02Q .0515. The permit shield described in General Condition
R does not apply to these changes. Public notice of the draft permit is not required. No new regulations apply for this change.
This modification resulted in adding the footnote *** which addressed the use of alkaline-based fuel additive for Units 1-4
(with footnote ***).
Permit Issue Date
Permit No.
Application No.
Application Type
11/06/2014
T51
.14C
TV-Sign–501(c)(2)
Description:
Duke Energy is requesting a permit modification to operate a brominated powered activated carbon injection (ACI) system
on Unit 4 on a permanent basis for the purpose of reducing mercury emissions in preparation for compliance with the MATS
rule. Duke was permitted in Permit T47 on September 14, 2010, to conduct a short-term evaluation of reducing mercury
emissions on Unit 4 using both spray-applying calcium dibromide and injection of activated carbon on a temporary basis, for
a total calcium dibromide use of 62,000 lbs. and total activated carbon use of 150, 000 lbs. This was placed in the permit at
conditions 2.1.A.14 and 15 which are now being revised as discussed below. No new equipment was permitted at that time
for the evaluation. The evaluation has been completed and provisions for calcium dibromide are no longer needed and this is
being removed from the permit. This permit modification will add a 14’ diameter x 60’ high dry storage injection (DSI) ACI
storage silo (ID No. ES-U4ACISilo) with a bin vent filter (ID No. CD-U4ACISiloBf). Duke was given approval to construct
this equipment (Notice of Intent to Construct) on March 17, 2014, prior to receipt of the air permit as allowed by N.C.G.S.
143-215.108A(b).
After the draft permit was sent to Duke for review on October 15, 2014, they requested the following additional changes be
made:
To remove burning of “off-specification oil” in Units 2 and 3 (in equipment description and state-only condition 2.1.A.8) and
remove burning of waste tetra-ammonium or di-ammonium ethylene di-amine tetra-acetic acid (EDTA) boiler cleaning
solution in Units 1, 2, 3 and 4 (in state-only conditions 2.1.A.8.d and 2.1.A.9) as Duke has discontinued burning these
substances. Duke requested the 02D .1100 toxic limits for ammonia in Section 2.1.A.8 that were established through modeling
for combustion of off-specification oil and waste EDTA boiler cleaning solution be retained (see Section V.C below) (ref.
emails from Bill Horton to Ed Martin dated October 16, 21, 23 and 27, 2014).
To remove spray applying calcium dibromide on the coal for Units 1 and 2 that was placed in the permit for a short-term trial
for a mercury reduction evaluation that has now ended (in PSD avoidance condition 2.1.A.16 for PM/PM10 and NA NSR
condition 2.1.A.17) (ref. emails from Bill Horton to Ed Martin dated October 16, 2014 and October 21, 2014).
To delete insignificant activities I-25, I-28, I-34.1 and I-38 (ref. two emails from Bill Horton to Ed Martin dated October 21,
2014).
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To request the state-only 02D .2500 mercury condition 2.1.A.13 be revised consistent with previous changes to the same
condition for Cliffside Units 1-5 in Permit No. 04044T34, condition 2.1.A.8 (see Section V.B below) (ref. emails from Bill
Horton to Ed Martin dated October 17, 2014 and October 21, 2014).
This is a significant permit modification pursuant to rule 15A NCAC 02Q .0501(c)(2). The permit shield described in General
Condition R does not apply to these changes. Public notice of the draft permit is not required at this time. The Permittee must
file a Title V Air Quality Permit Application pursuant to 15A NCAC 02Q .0504 for these changes on or before 12 months
after commencing operation in accordance with General Condition NN.1.
Note that the avoidance conditions 2.1A.16 and 17, which were added in permit no T48 and triggered a significant permit
application submittal requirement, were removed during this permitting action. Hence, the permit application submittal
requirement included in permit no. T48 is no longer necessary.
Also note that the Unit 4 control device ID No. CD-U4ActC (Temp) added in permit no. T47, was revised to just CD-U4ActC.)
The “second step” application triggered by this modification has been submitted and is being processed as application no.
16B.
Permit Issue Date
Permit No.
Application No.
Application Type
12/15/2014
T52
.11B
TV-Significant
Description:
This application is to renew the Title IV Acid Rain portion of the Title V permit. The Acid Rain Permit Application was
received June 14, 2011. The Phase II NOx Compliance Plan was received June 27, 2011, and the Phase II NOx Averaging
Plan was received December 23, 2011; both of which are part of the Acid Rain application. The effective dates for the Acid
Rain requirements in the previous permit covered the five calendar-year period 2007-2011 and were different than the effective
dates of the Title V permit itself. The Acid Rain requirements are now being renewed for a period matching the effective
dates of the Title V permit and will expire on August, 2015 along with expiration of the Title V permit. This is in order to
align the effective dates of the Acid Rain requirements with the effective dates of the Title V permit so that the Acid Rain
requirements can, in the future, be renewed along with the Title V permit. Therefore, separate effective dates in the Acid Rain
section are being removed. Duke will need to submit the next Acid Rain renewal application with the Title V permit renewal
application and therefore this current Acid Rain renewal will cover a period of less than five years. The Acid Rain Permit
Application, Phase II NOx Compliance Plan and Phase II NOx Averaging Plan will become part of the Title V permit (as
attachments).
These changes are significant permit modifications being made in accordance with 15A NCAC 02Q .0501(d)(1). Public notice
of the draft permit is required at this time.
Note that the Acid Rain permit is currently being revised and renewed as requested in applications 15C and 16A.
Consolidated TV Permit Modification Applications
A number of permit applications were consolidated into this renewal application (14E). Below is a description for each one.
These applications are significant modifications that were incorporated into the air permit via the “two step procedure” but not
subjected to public notice procedures. In general, the modifications addressed below will require no new regulatory
applicability over that contained in the original permit review at the time they were incorporated into the air permit other than
revising some regulatory authority references. See the Table of Changes for a complete listing of these changes, including
administrative and minor corrections incorporated into the revised air permit. More substantive regulatory discussion will be
included Section VIII of this review as necessary.
Subject the modifications addressed in permit no. T49 to the TV permitting process. (application
no. 13B)
In application .06D, which resulted in the issuance of Permit no. T41 on 02/10/2007, Duke, along with other modifications,
modified the control systems on the Unit 3 boiler by removing the selective non-catalytic reduction (SNCR) NOx reduction
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system, installing a selective catalytic reduction (SCR) NOx reduction system and adding an anhydrous ammonia flue gas
conditioning system. This resulted in the addition of a PSD avoidance condition addressing H2SO4 and lowering the allowable
ammonia emission limit under the state enforceable only 02D .1100 permit condition from 8.875 to 0.534 lb/hr.
In application no. 12B, which resulted in the issuance of Permit no. T49 on 01/15/2013 (see Section III), Duke requested
modifying the 02D .1100 condition to replace the ammonia emission limit of 0.534 lb/hr with 8.869 lb/hr, which was a rate at
which they had modeled to support compliance with the ammonia acceptable ambient level (AAL). Duke also requested to
revise the monitoring associated with the H2SO4 PSD avoidance condition. As this revision was considered a significant
modification and the application was processed in the “two step” fashion pursuant to 15A NCAC 02Q .0504, a follow-up
application was required to process the modification via the TV permitting procedures. The Permittee submitted this follow-up
application and it was received 10/10/2013 and assigned application no. 13B.
Certain modifications addressed as part of permit application no. 15A
On February 29, 2016, an email was received from Duke requesting some changes to the permit be handled as necessary via
the active application no. 15A. Application no. 15A, which primarily deals with the incorporation of MATS requirements is
being processed in a separate permitting action. Two the five requests are straightforward and to keep the focus of application
no. 15A narrow, are being processed under this permitting action. These requests are as follows:
2) Removal of the Unit 3 503 and NH3 flue gas treatment systems (CD-12 and CD12B(NH3FGC) on Marshall
Unit 3 and removal of avoidance condition 12.1 A. 10. The 503 FGT system was installed for intermittent
operation as needed for certain coals. The system is no longer needed and has been rendered mechanically
non-functional and tagged out. Likewise, the NH3 FGT system, also installed for intermittent use as needed,
is not needed and has been rendered mechanically non-functional and tagged out.
3) Removal of anhydrous ammonia storage tanks (189 and I 89.1) from the insignificant activities list. These
two tanks have been emptied and removed from the site.
It was confirmed that although the ID Nos. referenced above were for Unit 4 (i.e., CD-12 and CD12B(NH3FGC), the intent
was to remove the systems associated with Unit 3 (i.e., CD-8 and CD-8b(FGC)). Since these systems, which were also part of
the reason for including the H2SO4 PSD avoidance condition at section 2.1 A.10, are being removed, there is no need to
subject the modification addressed in Permit no. T41 to public notice and EPA review procedures. Instead of processing this
request as part of application no. 15A, it will be addressed in this permit application. The Permittee supplied calculations on
12/16/2016 showing that without these conditioning systems the PSD avoidance condition is unnecessary. The condition will
be removed from the revised permit as will the following control systems:


One flue gas conditioning system consisting of an integral sulfur trioxide ash conditioner (ID No. CD-8)
Anhydrous ammonia injection ash conditioning system (20 ppm maximum injection rate) (ID No. CD-8b(FGC)
Implications of these changes with respect to the NC air toxics rules (02D .1100 and 02Q .0700) will be discussed elsewhere in
this review document.
Subject the modifications addressed in permit no. T51 to the TV permitting process. (application
no. 16B)
In application no. 14C, which resulted in the issuance of permit no. T51 on 11/06/2014, Duke, along with other modifications,
requested to operate a brominated powered activated carbon injection (ACI) system on Unit 4, to revise the 15A NCAC 02D
.2500: MERCURY RULES FOR ELECTRIC GENERATORS permit condition, and to remove the system for spray-applying
calcium bromide on coal.
As this revision was considered a significant modification and the application was processed in the “two step” fashion pursuant
to 15A NCAC 02Q .0504, a follow-up application was required to process the modification via the TV permitting procedures.
The Permittee submitted this follow-up application and it was received 05/31/2016 and assigned application no. 16B.
The changes incorporated into permit no. T51 will, via the current permitting action, be subjected to the TV permitting
procedures, which include a 30 -day public comment period and a 45- day EPA comment period. Since the modifications have
been made consistent with the original application (14C), the original review document will simply be included as an
attachment (Attachment A) to this review.
No changes to the current permit are necessary
Page 8 of 32
Acid Rain Permit Renewal and Modifications (application nos. 14E, 15C and
16A)
Phase II Acid Rain Permit Renewal (2014)
The existing Acid Rain permit includes an Acid Rain application dated June 10, 2011, a Phase II NOx Compliance Plan dated
June 24, 2011 and a Phase II NOx Averaging Plan dated December 19, 2011.
On July 30, 2014 the DAQ received a letter (processed as application no. 14E) stating the following:
Please accept our application for renewal of the Marshall Steam Station Title V air permit.
The current Title V permit expires on August 31, 2015. As information, there are pending
applications to modify [permit no.] T50 at the time of this renewal application. We request
that the Marshall renewal permit incorporate these previously requested updates:
• Updated insignificant source list.
• Federal renewal applications for Acid Rain (June 10/2011), Phase II NOx (June 24,
2011) and system-wide NOx Averaging Plan (December 19, 2011).
We also request that Title V renewal, acid rain, and Phase II NOx renewal schedules have
the same expiration dates.
Thus, the intent of the Permittee was to not only the renew the TV permit but satisfy the Acid Rain permit renewal
requirements as well.
Phase II Acid Rain Permit Revised NOx Emission Limitations
On June 26, 2015 the DAQ received a letter (processed as application no. 15C) stating the following:
The Duke Energy Progress, Inc. and Duke Energy Carolinas, LLC facilities throughout
North Carolina had been operating under a multi-state NOx Averaging Plan for
compliance with the Phase II NOx emissions limitations under the Acid Rain Program.
The averaging plan for Duke Energy Progress, Inc. expired in 2014.
With the submission of the enclosed documents, we are respectfully requesting that the
compliance approach be modified to account for an approach where all North Carolina
facilities implement a state-wide emissions averaging plan. Emissions averaging plans for
a single jurisdiction are required to be submitted prior to July 1, 2015.
The letter included revised Acid Rain NOx Compliance Plan and Acid Rain NOx Averaging Plan forms. The existing acid rain
permit includes Acid Rain NOx Compliance and Averaging Plans that cover many units in multiple states, including North
Carolina, South Carolina, Indiana, and Kentucky.
The revised averaging plan will consist of the following units with the following emission limitations and heat input
limitations.
The Btu-weighted annual emission rate will be calculated as follows:
Page 9 of 32
The values chosen by Duke for Marshall in columns a, b and c were used to verify the Btu-weighted emission rates shown in
the equation above (step 2 of the Acid Rain NOx Averaging Plan). This program is enforced by the USEPA and hence the
details of the determination of the emission limits and heat input limitations included in the averaging plan are beyond the
scope of this review. Note that pursuant to 40 CFR 76.11,
(4) Each unit included in an averaging plan shall have a minimum allowable annual heat input value
(mmBtu), if it has an alternative contemporaneous annual emission limitation more stringent than that
unit's applicable emission limitation under §76.5, 76.6, or 76.7, and a maximum allowable annual heat
input value, if it has an alternative contemporaneous annual emission limitation less stringent than that
unit's applicable emission limitation under §76.5, 76.6, or 76.7.
At Marshall, only Unit 3 has as an alternative contemporaneous annual emission limitation more stringent than its applicable
emission limitation under §76.5, 76.6, or 76.7.
The air permit will be revised as necessary to include the revised Acid Rain NOx Compliance and Averaging Plans effective as
of calendar year 2015 (as stated in the revised plan). See Table of Changes for listing of all changes to the Acid Rain Permit
(Permit section 2.4).
Phase II Acid Rain Permit Renewal (2016)
On February 1, 2016 the DAQ received a letter (processed as application no. 16A) stating the following:
Please accept our applications for the renewal of the GG Allen and Marshall Station Acid
Rain Permits, which were last updated June 10, 201 l. The applications have been signed
and dated by the Acid Rain Alternate Designated Representative on file.
Also enclosed are revised applications for GG Allen and Marshall Station Acid Rain NOx
Compliance Plans and NOx Averaging Plans that were submitted to EPA-CAMD on June
23, 2015. These were also signed by the Alternate Designated Representative. We
respectfully request that these updated applications be incorporated at the next
opportunity into the Title V Air Permits and that the acid rain permits remain aligned with
Title V permit dates.
Note that:


reference is made to the revised Acid Rain NOx Compliance Plans and NOx Averaging Plans submitted to the DAQ
on June 26, 2015 (i.e., application no. 15C discussed above)
a request the renew the Acid Rain permit was made although the Permittee had requested to renew it in the application
no. 14E.
As mentioned previously the facility has (and had) a number of permit applications active simultaneously. It appears with
application no. 16A, the Permittee is ensuring the TV permit when revised will contain the latest relevant information and
applications.
The net effect of this is that the revised TV permit will include the revised Acid Rain NOx Compliance Plans and NOx
Averaging Plans as well as the latest submitted TV renewal application as attachments.
Page 10 of 32
Minor Modifications Since Last Renewal
Minor modifications that have occurred since last permit issuance are discussed below, since the modifications that have
occurred pursuant to these procedures will now be subjected to TV public notice and EPA review. In general, the modifications
addressed below will require no new regulatory applicability over that contained in the original permit review at the time they
were incorporated into the air permit other than revising some regulatory authority references. See the Table of Changes for a
complete listing of these changes, including administrative and minor corrections incorporated into the revised air permit. More
substantive regulatory discussion will be included Section V of this review as necessary.
Subject minor modification application no. 10A to TV public notice /EPA review procedures
Permit application no. 10A which resulted in the issuance of Permit no. T47, issued 09/14/2010, was processed as a minor
modification pursuant to 15A NCAC 02Q.0515. See description of modification in Section III above. As minor modifications,
changes to the permit are not covered by the permit shield pursuant to 15A NCAC 02Q .0512. Concurrent with the current
permitting action, the modifications addressed in permit no. T47 will now be subjected to public and EPA review. Upon
issuance, the modifications addressed in T47 will be covered under the permit shield. The review document for permit no. T47
will be included as an attachment (Attachment B) to this review. Note that some of the modifications undertaken in permit no.
T47 were removed or modified in permit no. T51. See discussion in Section III above for the T51 modification, which was
processed as a “two-step” significant modification pursuant to 15A NCAC 02Q .0504.
Subject minor modification application no. 13A to TV public notice /EPA review procedures
Permit application no. 13A which resulted in the issuance of Permit no. T50, issued 04/19/2013, was processed as a minor
modification pursuant to 15A NCAC 02Q.0515. See description of modification in Section III above. As minor modifications,
changes to the permit are not covered by the permit shield pursuant to 15A NCAC 02Q .0512. Concurrent with the current
permitting action, the modifications addressed in permit no. T47 will now be subjected to public and EPA review. Upon
issuance, the modifications addressed in T50 will be covered under the permit shield. The review document for permit no. T50
will be included as an attachment (Attachment C) to this review.
Applicability Determinations
The Permittee has requested the following applicability determinations. They are discussed individually below.
Applicability Determination - Coal Pile Dust Suppressant
On 02/29/2016, the DAQ received a letter which requested 5 items. Item 5 reads follows:
5
Request an off-permit applicability determination for addition of an eco-friendly additive to the
coal pile at vendor recommended doses for voluntary mitigation of fugitive dust
The letter included the following information:
Page 11 of 32
Based on the submitted information it appears the only pollutant emitted or increasing as a result of this product would be CO2.
Thus, this activity meets the definition of insignificant activities “because of size or production rate" pursuant to 15A NCAC
02Q .0503(8).
For conservatism, assume the product had the density of water (7.45 lb/gallon) and was all carbon (12 lb/lbmol), the amount of
CO2 (44 lb/lbmol) that could be generated would be
Since this CO2 is generated by the combustion in the utility boilers, this proposed activity is a modification to an existing
source. However, since the only increase in pollutants is associated with CO2 (CO2e), PSD would not apply regardless of the
level of emissions consistent with 15A NCAC 02D. 0530(a).
This dust suppressant will be combusted in the utility boilers, which are subject to MACT 5U and hence exempt from the NC
air toxics rules (02D .1100 and 02Q .0700) pursuant to 15A NCAC 02Q .0702(a)(27)(B). This activity will simply be added to
the insignificant activities list pursuant to 15A NCAC 02Q .0503(8).
Page 12 of 32
Applicability Determination - Request to burn coal contaminated by inadvertent spills
On January 11, 2016, the Mooresville Regional Office (MRO) received an email stating:
Given the size of these boilers, the pollutants (including CO2) resulting from the combustion of 500 gallons of
hydraulic/lubricating oil or antifreeze spilled onto coal over the course of the year would be minuscule. This oil will be
combusted in the utility boilers, which are subject to MACT 5U and hence exempt from the NC air toxics rules (02D .1100 and
02Q .0700) pursuant to 15A NCAC 02Q .0702(a)(27(B). At the request of the Permittee and approved by the Permitting
Section Chief, the following language will be added as a footnote to Section 1 of the permit for all four boilers: “Incidental
spills of oil, antifreeze, etc. that might get on the coal from mobile equipment is allowed to be burned in these boilers.”
Page 13 of 32
Regulatory Review
With the exceptions presented below, all existing permit conditions upon review appear to be consistent with their underlying
applicable regulations. See Section XIII. Changes Implemented in the Revised permit for a complete listing of all changes,
including administrative and minor corrections.
2.1.A – Four coal/No. 2 fuel oil-fired electric utility boilers (ID Nos. ES-1 through ES-4)
State Enforceable Only requirement
15A NCAC 02D .2500 Mercury Rules for Electric Generators
This regulation expired on February 1, 2016 and hence reference to it will be removed from the revised permit. Mercury
Emissions from these utility boilers are now regulated under 15A NCAC 02D .1111 Maximum Achievable Control
Technology (MACT) as promulgated in the most current version of 40 CFR Part 63 Subpart UUUUU, “National Emission
Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units” (MACT 5U). A number
of the previous permitting actions including those consolidated into the renewal application have dealt with determining
appropriate control strategies to comply with MACT 5U. Permit applications (application nos. 15A and 15D) have been
submitted and were processed separately from this permitting action to include practically enforceable permit terms and
conditions. Permit No. T54 was issued on 02/10/2017 and included the applicable requirements MACT 5U.
Cross-State Air Pollution Rule (CSAPR)
On July 6, 2011, the US Environmental Protection Agency (EPA) finalized the Cross-State Air Pollution Rule (CSAPR),
requires states to reduce power plant emissions that contribute to ozone and/or fine particle pollution in other states. In a
separate, but related, regulatory action, EPA finalized a supplemental rulemaking on December 15, 2011 to require five states Iowa, Michigan, Missouri, Oklahoma, and Wisconsin - to make summertime nitrogen oxides (NOX) reductions under the
CSAPR ozone season control program. CSAPR requires a total of 28 states to reduce annual SO2 emissions, annual NOX
emissions and/or ozone season NOX emissions to assist in attaining the 1997 ozone and fine particle and 2006 fine particle
National Ambient Air Quality Standards (NAAQS). On February 7, 2012 and June 5, 2012, EPA issued two sets of minor
adjustments to the CSAPR.
The timing of CSAPR's implementation has been affected by a number of court actions. On December 30, 2011, CSAPR was
stayed prior to implementation. On April 29, 2014, the U.S. Supreme Court issued an opinion reversing an August 21, 2012
D.C. Circuit decision that had vacated CSAPR. Following the remand of the case to the D.C. Circuit, EPA requested that the
court lift the CSAPR stay and toll the CSAPR compliance deadlines by three years. On October 23, 2014, the D.C. Circuit
granted EPA's request. Accordingly, CSAPR Phase 1 implementation occurred in 2015, with Phase 2 beginning in 2017.
Under this rule, each of the units at this facility is considered a "large electric generating unit", per 40 CFR 52.34. This rule
and all requirements thereof are considered Federally-enforceable only. Compliance will be determined by the US EPA, not
the NC DAQ. A reference to this rule will be added to the permit as follows:
Federally-Enforceable Only
Cross State Air Pollution Rules (CSAPR) Permit Requirements
For the four boilers (ID Nos. ES-1 thru ES-4), the Permittee shall comply with all applicable requirements of
40 CFR Part 97, Subpart AAAAA "TR NOx Annual Trading Program", Subpart BBBBB "TR NOx Ozone
Season Trading Program", and Subpart CCCCC "TR SO2 Group 1 Trading Program".
Clean Air Interstate Rule (CAIR)
The Clean Air Interstate Rule (CAIR) addressed regional interstate transport of soot (fine particulate matter) and smog (ozone).
CAIR required 28 eastern states to make reductions in SO2 and NOX emissions that contribute to fine particle and ozone
pollution in downwind states. CAIR was replaced by the CSAPR, as of January 1, 2015.
On February 1, 2016, the rules under 15A NCAC 02D .2400 which had implemented CAIR expired. Therefore, references to
those rules have been removed from the permit.
2.1.B.
Limestone Receiving, Transfer, Storage, and Processing Equipment:
Page 14 of 32
15A NCAC 02D .0524: NSPS 40 CFR PART 60 SUBPART OOO
NSPS Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants was substantially revised, affected
as of April 28, 2009. The current permit condition addressing this regulation needs to be revised to address the changes in
opacity requirements for building openings (excluding vents) at 40 CFR 60.672(e).
Prior to April 28, 2009, the rule required:
(e) If any transfer point on a conveyor belt or any other affected facility is enclosed in a building, then each
enclosed affected facility must comply with the emission limits in paragraphs (b) and (c) of this section,
or the building enclosing the affected facility or facilities must comply with the following emission
limits:
(1) No owner or operator shall cause to be discharged into the atmosphere from any building
enclosing any transfer point on a conveyor belt or any other affected facility any visible fugitive
emissions except emissions from a vent as defined in §60.671}.
(e)(1) has been revised and currently reads:
(1) Fugitive emissions from the building openings (except for vents as defined in §60.671) must
not exceed 7 percent opacity; and
Thus, if the Permittee chooses to comply with this option, the opacity limits for non-vent openings has been relaxed from 0 to
7%. Since this is a relaxation, there is no need to require testing to comply with this less stringent limit. The current permit
already contains adequate monitoring, recordkeeping, and reporting (M/R/R) to ensure compliance with limit. No other
changes to the NSPS OOO have implications with respect to the current equipment or permit condition. The permit will be
revised accordingly. All changes to the permit condition are addressed in the Table of Changes.
2.1.C - One 1,000 HP, No. 2 fuel oil fired emergency use water pump (ID No. ES-26 (EQWP))
15A NCAC 02D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
(MACT – 40 CFR PART 63 SUBPART ZZZZ)
This engine was added to permit no. T29 issued February 5, 2004 as the result of application no .03B. The MACT ZZZZ
permit condition was added to permit no. T41 issued February 01, 2007. The review for permit no. T41 stated the engine was
constructed prior to December 19, 2002 and as such would be an existing source pursuant to 40 CFR 63.6590(a)(1). The
Permittee has confirmed via email on 8/23/2016 however, that the manufacture date was sometime in 2005. Thus the engine
was not constructed at the time it was permitted. Thus it is a “new stationary RICE” consistent with §63.6590(a)(2)(i). The
Permit condition will be revised to be consistent with current DAQ permit conditions for this subcategory of engine. The only
requirement for this engine is a notification requirement that was effectively met with the original permit application no. 03B.
2.1.H. One No. 2 fuel oil-fired emergency/blackout protection diesel generator (ID No. ES-35
(EmGen)) and one No. 2 fuel oil-fired diesel emergency air compressor (ID No. ES-36 (AC))
15A NCAC 02D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
(MACT – 40 CFR PART 63 SUBPART ZZZZ)
The MACT ZZZZ permit condition was added to permit no. T33 issued 12/03/2004. The review at that time stated these
engines were “new stationary RICE.” The permit condition will be revised to be consistent with current DAQ permit
conditions for this subcategory of engine. The only requirement for these engines is a notification requirement that was
effectively met with the original permit application no. 04D.
2.1.J. One 100 kW No. 2 Fuel Oil-Fired Emergency Generator Located at Landfill (ID No. ES-37
(EmGenLF))
This source was added to the permit no T47 issued 09/14/2010.
Page 15 of 32
15A NCAC 02D .0524: NEW SOURCE PERFORMANCE STANDARDS (40 CFR PART 60 SUBPART IIII)
This condition will be revised to be consistent with current DAQ standards, to remove outdated requirements (e.g. fuel sulfur
requirements prior to October 2010) and to account for the revisions to the rule since the original permit was issued, primarily
addressing how the engine may be operated in non-emergency situations.
Facility-wide considerations
15A NCAC 02D .1100 TOXIC AIR POLLUTANTS
15A NCAC 02Q. 0700 TOXIC AIR POLLUTANT PROCEDURES
Pursuant to 15A NCAC 02Q. 0707 PREVIOUSLY PERMITTED FACILITIES:
Any facility with a permit that contains a restriction based on the evaluation of a source exempted under Rule
.0702 of this Section may request a permit modification to adjust the restriction by removing from
consideration the portion of emissions resulting from the exempt source unless the Director determines that
the removal of the exempt source will result in an acceptable ambient level in 15A NCAC 02D .1104 being
exceeded. The Director shall modify the permit to remove the applicability of the air toxic rules to the exempt
source. No fee shall be charged solely for such permit modification.
Also, pursuant to the current 15A NCAC 02Q .0702 rule:
(a) A permit to emit toxic air pollutants shall not be required under this Section for:
***
(27) an air emission source that is any of the following:
(A) subject to an applicable requirement under 40 CFR Part 61, as amended;
(B) an affected source under 40 CFR Part 63, as amended; or
(C) subject to a case-by-case MACT permit requirement issued by the Division pursuant to Paragraph (j)
of 42 U.S.C. Section 7412, as amended;
Requirements of the above sections of the air quality rules are implemented in the following conditions of the current air permit
presented below in italics. Note that these current conditions specifically affect sources subject to a MACT (MACT 5Ufor the
boilers and MACT ZZZZ for internal combustion engines) and thus meet the requirements of 02Q .0702(a)(27)(B). Thus a
review will be conducted to determine if certain requirements under 02D .1100 and 02Q .0711 can be removed from the
revised air permit.
STATE ONLY REQUIREMENT
2.1.A.11. 15A NCAC 2Q .0309: TERMINATION, MODIFICATION, AND REVOCATION OF PERMITS for AVOIDANCE
OF 15A NCAC 2Q .0705 APPLICABILITY
a.
b.
Pursuant to 15A NCAC 2Q .0309 and in accordance with the approved application for compliance with air toxics requirements,
the following permit limit shall not be exceeded:
Emission Sources
Toxic Air Pollutants
Emission Limits
Unit 1 Boiler (ID No. ES-1)
Unit 2 Boiler (ID No. ES-2)
Unit 3 Boiler (ID No. ES-3)
Unit 4 Boiler (ID No. ES-4)
Arsenic
0.8278 tons per year total
Testing [15A NCAC 2Q .0508(f)]
If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the results of this
test are above the limit given in Section 2.1.A.10.a above, the Permittee shall be deemed in noncompliance with 15A NCAC
02D .0705.
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring, recordkeeping, or reporting requirements shall be necessary
Page 16 of 32
STATE ONLY REQUIREMENT
2.2.B.1. 15A NCAC 2Q .0309: TERMINATION, MODIFICATION, AND REVOCATION OF PERMITS for AVOIDANCE
OF 15A NCAC 2Q .0705 APPLICABILITY
a. The following table provides a summary of limits and standards for the facility:
b.
c.
Regulated Pollutant
Limits/Standards
Applicable Regulation
Arsenic
0.8288 tons/year
15A NCAC 2Q.0309
(2Q .0705 avoidance)
Testing [15A NCAC 2Q .0508(f)]
If emissions’ testing is required, the testing shall be performed in accordance with General Condition JJ. If the results of this
test are above the limit given in Section 2.2 B.1.a above, the Permittee shall be deemed in noncompliance with 15A NCAC 02D
.0705.
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
No monitoring, recordkeeping, or reporting requirements shall be necessary.
Sections 2.1 A.11 and 2.2 B.1 were added to permit no. T45, issued 10/16/2009 as the result of permit application .09B. Prior
to that permitting action in 2008, the facility had submitted a facility-wide demonstration at the request of the DAQ. This
demonstration included most combustion sources (some very small ones were not included) and coal and ash handling
operations. The DAQ approved this modeling in a memo dated March 3, 2009. An excerpt from the modeling report submitted
is provided as follows to explain the purpose:
This modeling effort was performed in response to a request from NC DAQ as part of an ongoing initiative of
the NC Environmental Management Commission to evaluate the need for regulating combustion sources
which burn unadulterated fossil fuels, which are currently exempt from the NC TAPS rules. Based on
screening modeling using the HEM-3 exposure risk model, the additional AERMOD modeling for the Facility
was required by NC DAQ to determine whether the Facility should be subject to a Director’s Call as provided
in the NC TAPS rules (15 NCAC 2Q.0712). Duke Energy was provided the opportunity to perform this
modeling on its own in lieu of NC DAQ performing the modeling.
The following table shows the results of the approved analysis.
Page 17 of 32
Table 1.
March 3, 2009 Memo
The modeling showed arsenic impacts of 82.5% of the AAL. With the exception of Arsenic and Chromium (VI), all impacts
were well below the AAL. As a result of this modeling analysis, the Permittee submitted application no. 09B. The following is
an excerpt from the permit review:
In order to avoid a Director’s Call, Duke Energy Carolinas, LLC – Marshall Steam Station requested an
emissions limit that is equal to approximately 96% of the AAL for arsenic and conducted AEROMOD
emissions modeling (revised modeling for arsenic received on May 30, 2009) to demonstrate compliance with
the AALs for the emissions sources. Arsenic emissions from each unit shall not exceed 0.8672 tons per year
and the facility-wide arsenic emissions are limited to 1.741 tons per year. Actual facility emissions of arsenic
are expected to be approximately 0.05212 tons per year from each unit, or approximately 0.1038 tons per
year facility-wide. This emissions rate is approximately 1/10th the permitted rate and therefore monitoring
of arsenic will not be required at this time.
In summary, source specific and facility wide emission limitations of Arsenic were placed into the air permit no. T45. It is
unclear why Chromium VI was not a concern at this time. The referenced May 30, 2009 modeling was not available at the time
of this review.
In any case, the AAL for Arsenic was subsequently revised from 2.3 E-04 ug/m3 to 2.1 E-03 ug/m3 in 2014, hence an increase
over-9-fold. Thus, the 2008 modeling impacts which resulted in an impact of 82% of the ALL would result in an impact of
approximately 9% of the revised AAL. A review of the 2013 and 2014 emissions inventory data show (the latest approved
inventory data) that the facility has reported emissions of arsenic 25 to 47% greater than the emissions modeled in the 2008
analysis but still well below the limits in current condition 2.1.A.11 and by extension 2.1.A.12. Thus if the facility was to
remodel using the reported emission inventory data, it is reasonable to assume that the % of AAL impacts would increase on
the order of 25 to 47% which would be on the order of 11 to 13% of the current arsenic AAL. It is reasonable to assume then
that the emission of Arsenic would have to increase many-fold before ambient concentrations of Arsenic would approach the
revised AAL.
The issue of the emission inventory estimates of actual emissions exceeding the modeled emission rates is beyond the scope of
this review. It appears the Permittee, when submitting emission inventory data, was using conservative emission factors to be
consistent with other environmental reporting requirements. Because the permit did not contain TAP emission limitations
specific to each boiler, the Permittee was not concerned with demonstrating compliance with such limits. The Permittee
maintains that the potential emission rates used in all of the modeling discussed here are the best estimate of potential
emissions. The Permittee is considering revision in its conservative emissions inventory reporting practices to avoid such
confusion in the future.
Based on the above discussion, it seems reasonable that the removal of the permit restrictions for Arsenic found at current
permit conditions 2.1 A.11 and 2.2 B.1 will not result in a AAL in 15A NCAC 02D .1104 being exceeded. These conditions
will be removed from the revised permit.
Page 18 of 32
STATE ONLY REQUIREMENT
2.2.B.2. 15A NCAC 02Q .0709 DEMONSTRATIONS
a. No later than September 29, 2010, the Permittee shall submit a modeling protocol to the NCDAQ for the purpose of
demonstrating compliance with 15A NCAC 02D .1100.
b. No later than 120 days following the date the NCDAQ approves the modeling protocol, the Permittee shall submit a complete
permit application that includes a demonstration as required by 15A NCAC 02D .1100. All sources at the facility, excluding
sources exempt from evaluation in 15A NCAC 02Q .0702, emitting these toxic air pollutants shall be included in the
evaluation. Notwithstanding 15A NCAC 02Q .0702(a)(18), on and after July 10, 2010, an evaluation of a modification to a
combustion source shall also include emissions from all permitted combustion sources as defined in 15A NCAC 02Q .0703.
[15A NCAC 02Q .0706]
This requirement was placed into permit no. T47, issued on 09/14/2010 as a result of permit application no. 10A. The trigger
was the installation of a new 100 kW diesel-fired generator (ID No. ES-37(EmGenLF), which at that time was not exempt
pursuant to 02Q .0702 and hence triggered a toxics review.
A modeling demonstration was submitted, reviewed and approved by the DAQ via a memo dated January 26, 2011. The results
were as follows:
Table 2.
January 26, 2011 Memo
Maximum Impacts
Duke Energy – Marshall – Catawba Co., NC
Pollutant
Averaging Period
% of AAL
1,3-Butadiene
Annual
<1 %
Acetaldehyde
1-hour
<1 %
Acrolein
1-hour
1%
Benzene
Annual
12 %
Benzo(a)Pyrene
Annual
<1 %
1-hour
12 %
Toluene
24-hour
<1 %
Formaldehyde
1-hour
3%
1-hour
<1 %
Xylenes
24-hour
<1 %
Note that this table represents TAPs which were expected to increase with the installation of the generator. The sources
included in the modeling analysis summarized in Table 2 above included all combustion sources on site as well as gasoline
dispensing operations but not the coal and ash handling operations that were included in the 2008 analysis summarized in
Table 1 above. The gasoline dispensing operations were not included in the 2008 (Table 1) analysis.
Upon review, the emission estimates in both analyses for the engines were based on AP-42 emission factors, which does not
include emissions for metals (e.g., Arsenic Hg, Ni, and Cr(VI)). Typically, DAQ provided spreadsheets are used to estimate
emissions from internal combustion engines. These spreadsheets are based on AP-42 emission factors for internal combustion
(IC) engines, but also use metal TAP emission factors from AP-42 Chapter 1.3, “External Combustion Sources: Fuel Oil
Combustion.”
Duke failed to submit a permit application demonstrating compliance with 15A NCAC 02D .1100 pursuant to Section 2.2
B.2.b. Had a permit application been submitted, the modeled emission rates would have been reviewed and limits incorporated
into the permit at that time. However, the NC air toxic rules have changed since then and, as discussed above, if a source is
subject to a MACT standard, the 02D .1100 emission limitations can be removed from the permit if it would not pose an
unacceptable risk by doing so. In the situation here, if no unacceptable risk is posed, 02D. 1100 emission limitations will not
be added to the revised air permit. To determine if a remodeling analysis is necessary, the results of Table 2 (2010 analysis)
will be reviewed in conjunction with the 2008 modeling analysis as discussed previously (Table 1).
In Table 1, with the exception of Cr(VI), arsenic, beryllium and sulfuric acid, the modeling impacts as a percent of the
applicable AALs are well under 1%. The modeled rates assumed 8760 hours of operation per year for all sources except for the
emergency engines, and each source operating at its maximum hourly rate. However, as stated previously, metal TAP emission
estimates were not included in the emission estimates for the internal combustion engines. A table was created (see Attachment
D) that includes all the emission rates included in the 2008 as well as the 2010 analyses. Note that the largest TAP contributors,
Page 19 of 32
the utility boilers, had the same TAP emission rates in both models. Using the DAQ spreadsheets, potential emissions of metal
TAPs from all of the IC engines currently on site were calculated. The facility wide totals were then calculated for each TAP
(column A of the attached spreadsheet). For comparison, a percent difference was calculated (column B) between these values
and the largest previously modeled totals values in either the 2008 or 2010 analysis (column C). Negative percent differences
can be interpreted to mean that the total amount of a particular TAP that had been modeled in 2008 or 2010 was larger than the
overall potential to emit of the same TAP under the current permit. The opposite would be true for positive percent
differences. Not surprisingly, these positive differences are associated with the metallic TAP emissions not included in the
previous TAP analyses. However, the largest positive percent difference is 0.7%. This was for Beryllium, which was modeled
in 2008 with a maximum impact of 1.2% of the AAL. Given the relatively small contributions from these internal combustion
engines, it is not expected that their inclusion in a revised model would result in any AAL impacts being significantly different.
Thus, the 2010 and 2008 modeling results are sufficient enough to make the statement that it is unlikely that exempting these
sources from the requirements of 02D .1100 pursuant to 15A NCAC 02Q .0702 will pose an unacceptable risk to human
health. These permit conditions will be removed from the revised air permit.
Permit Shield
Section 2.3 of the permit addresses permit shields for non-applicable regulations as allowed pursuant to 15A NCAC 02Q
.0512. The current permit had a number of permit shields for the utility boilers (ID Nos. ES-1 through ES-4). Upon review a
number of them appeared to no longer apply given the changes in the 02D .0900 VOC rules over the years, changes in
attainment status of the county, etc. Section 2.3 was sent to the Permittee to re-justify the listed shielded regulations. As a
result, a number of changes were made. Given that this section strictly addresses shields included at the request of the
Permittee and not applicable requirements, no discussion will be made to justify any shields removed. The following table are
the shields requested by the Permittee to be included in the revised permit along with their justification.
A. The following requirements are not applicable to boilers (ID Nos. ES-1 through ES-4):
1.
2.
3.
4.
5.
6.
7.
15A NCAC 02D .0537, “Control of Mercury Emissions,” is not applicable because it does not apply to fuel combustion.
15A NCAC 02D .0521(d), “Control of Visible Emissions,” visible emissions shall not exceed 20% opacity, is not
applicable because these sources were manufactured as of July 1, 197l.
15A NCAC 02D .0607, “Large Wood and Wood-Fossil Fuel Combination Units”, does not apply as these sources do not
combust wood and wood-fossil fuels.
15A NCAC 02D .1110, “National Emission Standards for Hazardous Air Pollutants” promulgated in 40 CFR Part 61, is
not applicable because no NESHAP promulgated pursuant to 40 CFR Part 61 applies.
15A NCAC 02D .0900, “Volatile Organic Compounds” does not apply to these sources pursuant to 02D .0902(e), (f) or
(g).
15A NCAC 02D .0903, Recordkeeping: Reporting: Monitoring does not apply to these sources because there are no rules
applicable to these sources in 02D .0900.
15A NCAC 02D .0912, “General Provisions on Test Methods and Procedures,” is not applicable because there are no rules
applicable to these sources in 02D .0900.
B. The following requirements are not applicable to the storage tanks listed in the table below:
Emission Source
I.D.
Emission Source Description
I-8
500,000 gallon above ground main No. 2 fuel-oil storage tank and associated unloading stations,
contract awarded on tank in 1973
500,000 gallon above ground main No. 2 fuel-oil storage tank and associated unloading stations,
contract awarded on tank in 1973
30,000 gallon fuel oil storage tank at coal handling area
I-9
500 gallon capacity lube oil storage tank at coal handling tractor shed
I-9.1
750 gallon capacity lube oil storage tank at coal handling tractor shed
I-9.2
1000 gallon capacity lube oil storage tank at coal handling tractor shed
I-10
400 gallon storage tank for car dumper
I-11
75 gallon storage tank for coal handling knuckle boom
I-7
I-7.1
Page 20 of 32
Emission Source
I.D.
I-12
I-13
I-20
1.
2.
3.
Emission Source Description
1000 gallon above ground gasoline storage tank and associated unloading station
550 gallon above ground gasoline storage tank and associated unloading station (Mosquito Control
Facility)
10,000 gallon turbine oil storage tank used for maintenance on Unit 1
I-20.1
10,000 gallon turbine oil storage tank used for maintenance on Unit 2
I-21
I-84
I-85
I-93
I-127
I-129
12,000 gallon turbine oil storage tank used for maintenance on Units 3 & 4
1600 gallon above ground diesel fuel oil storage tank (Emergency Generator)
190 gallon above ground diesel fuel oil storage tank (Emer. Air Compressor)
220 gallon oil storage tank in Coal Handling Tractor Shed
100 gallon above ground diesel fuel oil storage tank (Emergency Quench Pump)
150 gallon above ground diesel fuel oil storage tank (Emergency Landfill Generator)
15A NCAC 02D .0900, “Volatile Organic Compounds”, does not apply to these sources as they meet none of the
applicability requirements pursuant to 02D .0902 (b), (e), (f) or (g).
15A NCAC 02D .0903, Recordkeeping: Reporting: Monitoring does not apply to these sources because there are no rules
applicable to these sources in 02D .0900.
15A NCAC 02D .0912, “General Provisions on Test Methods and Procedures,” is not applicable because there are no rules
applicable to these sources in 02D .0900.
NSPS, NESHAPS, PSD, Attainment Status, 112(r), and CAM
NESHAPS and NSPS
The subject facility is a major source of HAP emissions. The revised permit is up to date with all current applicable
requirements except where discussed below.
The utility boilers are subject to of 40 CFR Part 63 Subpart UUUUU, “National Emission Standards for Hazardous Air
Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units.” The current permit has a placeholder condition.
Practically enforceable M/R/R conditions are being developed as a result of permit application no. 15D and will be
incorporated into the TV permit at a later date.
The boilers are not subject to any NSPS.
All on site internal combustion engines are subject to 40 CFR 63, Subpart ZZZZ “National Emissions Standards for Hazardous
Air Pollutants for Stationary Reciprocating Internal Combustion Engines.
Engine (ID No. ES-37) is subject also subject to 40 CFR Part 60 Subpart IIII, Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines.”
The limestone receiving, transfer, storage, and processing equipment is subject to 40 CFR Part 60 Subpart OOO - Standards of
Performance for Nonmetallic Mineral Processing Plants.
The four coal conveyors (ID Nos. ES-CCONV2, ES-CCONV6, ES-CCONV7 and ES-CCONV8) are subject to 40 CFR Part
60, Subpart Y - Standards of Performance for Coal Preparation and Processing Plants.
All regulatory implications associated with this application are discussed in Section VIII. above.
112(r)
The facility is below all 112(r) applicable thresholds.
Attainment Status
Currently, Catawba County is in attainment for all pollutants.
CAM
Page 21 of 32
The applicability of 15A NCAC 02D. 0614 Compliance Assurance Monitoring (CAM), which implements the federal rule at
40 CFR 64, was reviewed for all currently permitted sources. The Permittee supplied a CAM applicability discussion on the
DAQ standard form E6 with the renewal application and revised via email on 11/21/2016 to account for One MS4 DSI ACI
storage silo (ID No. ES-U4ACISilo) and associated ACI storage silo bin vent filter baghouse (ID No. CD-U4ACISiloBf). This
equipment had been added to the permit since the renewal application was originally submitted.
In general, all of the material handling sources are exempt from CAM by either; pre-controlled emissions being less that major
thresholds, the “control devices” are considered inherent to the process and hence not subject to CAM, or no controls.
All internal combustion engines are exempt from CAM as they are well below major source thresholds and have no control
devices.
The four utility boilers are subject to CAM for PM with respect to 15A NCAC 02D .0536: PARTICULATE EMISSIONS
FROM ELECTRIC UTILITY BOILERS. The CAM plan was placed into the permit during the last permit renewal. No
changes are necessary to this existing CAM plan. The utility boilers are not subject to CAM for any other pollutant since either
no emission standard applies for the pollutant or no controls are used for compliance (i.e., CO, VOC) or it uses a continuous
compliance method (i.e., NOx, SO2 CEMs,) or for HAPs, is subject to MACT 5U, which was promulgated after 1990, and
hence exempt from CAM.
PSD
Catawba County is currently in attainment for all pollutants. The subject facility is a PSD major source. The permit contains
one PSD avoidance condition at Section 2.1.A 14 for PM 10 and an NSR avoidance condition at Section 2.1 A.15 for PM 2.5.
These conditions were added in permit no, T47 issued 09/24/2010 for the modification involving the addition of control
devices for Unit 4 boiler: systems for spray-applying calcium dibromide (ID No. CD-U4CaBr2(Temp)) and powdered
activated carbon (ID No. CD-U4ActC(Temp)). At that time Catawba County was in non-attainment for PM2.5. These
conditions will remain in the revised air permit.
A PSD avoidance condition for PM2.5 was added in permit no. T53 issued 02/10/2017 for the use of halide salt mercury fuel
additives. It will also remain in the revised permit.
Compliance History
As excerpted from the compliance inspection report of June 03, 2015 by Tonisha Dawson from the MRO.
Based on my observations during this inspection, this facility appeared to be in compliance with the applicable
air quality regulations.
The inspection report notes no violations in the previous five years.
Changes Implemented in Revised Permit
Existing
Section
Cover
New Section
Same
ISA
Same
Description of Changes
 Revised header/footer, permit number dates etc.
 Removed paragraph addressing application submittal requirement pursuant to
15A NCAC 02Q .0504 for the air emission source(s) and associated air
pollution control device(s) (ID Nos. ES-U4ACISilo and CD-U4ACISiloBf)
and for the changes to Sections 2.1.A.14 and 15 for the activated carbon
injection system Application was submitted and assigned application no. 16B
 I-8 – changed from 1000 to 30,000 gallon
 I-9, 9.1, 9.2 – changed from
“fuel oil storage tanks, and associated unloading station”
to
“lube oil storage tanks, at coal handling tractor shed.
 Removed I-14
 Removed I-54
 Removed I-89, 89.1
Page 22 of 32
Existing
Section
New Section
Description of Changes





Removed I -92, I-94
Removed I-108
Removed I-132,133,134 and 135
Added activity I-136 – Coal pile dust suppressant
I-7.1 - added the following language: (empty: permanently closed and tagged
out in 2003
 I-10 – revised descriptor to include lube oil
 Removed the following sources that are categorically exempt or do not emit a
regulated pollutant: I-35, 35.1, 36, 37, 46, 60, 60.1, 90, 90.1, 90.2, 130, 131
 Removed I-64
TOC
Same
Removed reference to:
 2.5 Clean Air Interstate Rule (CAIR) Requirements
 ATTACHMENT Clean Air Interstate Rule Application dated June 25,
2007
Revised reference to the following attachments from
Acid Rain Permit Application dated June 10, 2011
Phase II NOx Compliance Plan dated June 24, 2011
Phase II NOx Averaging Plan dated December 19, 2011
To
Acid Rain Permit Application dated January 27, 2016
Phase II NOx Compliance Plan dated June 23, 2015
Phase II NOx Averaging Plan dated June 23, 2015
Section 1:
Permitted
equipment list
Same
 Removed reference to CD-8 and CD-8b on Unit 3
 Pursuant to request received on February 23, 2017, removed reference to CD2a from unit 1, CD-5a from unit 2 and CD-12B from Unit 4.
 Removed footnote (†) addressing application submittal requirement pursuant
to 15A NCAC 02Q .0504 for the air emission source(s) and associated air
pollution control device(s) (ID Nos. ES-U4ACISilo and CD-U4ACISiloBf).
This application was received and assigned application no. 16B.
 Removed 15A NCAC 02Q .0515 minor modification footnote (**) for the
injection of powdered activated carbon (ID No. CD-U4ActC), and
installation of emergency generator (ID No. ES-37 (EmGenLF))
 Removed 15A NCAC 02Q .0515 minor modification footnote (***) for the
use of alkaline-based fuel additives in Units 1 through 4.
 All affected sources of MACT and NSPS standards had indicators placed (or
corrected as necessary) next to their respective ID Nos. consistent with
permitting policy
 Added the footnote to the four boilers – “** - Incidental spills of oil,
antifreeze, etc. that might get on the coal from mobile equipment is allowed
to be burned in these boilers”.
 The following footnote was removed:
Alkaline-based fuel additive may be used on an as-needed basis not to exceed
7 pounds per ton of coal burned.
Upon review of the original permit application for the additives (Permit no.
T50), the Permittee would not be in violation of any applicable standard if it
used more than 7 lb/ton of the additive. Consistent with permitted equipment
descriptors that are not necessary for regulatory compliance, this usage rate
will be memorialized in the equipment descriptor.
 The following footnote was removed:
Fuel additives shall not contain any toxic air pollutants listed in 15A NCAC
02Q .0711.
Page 23 of 32
Existing
Section
New Section
Description of Changes
The boilers are no longer subject to 15A NCAC 02 D.1100 pursuant to 15A
NCAC 02Q .0702(a)(27)(B). see the permit review. In addition, the use of an
additive that contained a TAP listed in 02Q .0711 would not necessarily
imply a permit violation. Consistent with permitted equipment descriptors
that are not necessary for regulatory compliance this type of material will be
memorialized in the equipment descriptor.
 The following footnote was removed:
Fuel additive products not equivalent to those specified in Application
1800073.13A are not allowed without permit modification.
This condition is over-restrictive. All modifications are subject to permitting
rules with some exceptions. Thus, the use of other products may meet such
exception requirements.
Global
Same
 Updated regulation references from “2D” and “2Q” to “02D” and “02Q” to
be consistent with regulation nomenclature.
 For all testing conditions, updated regulatory reference from 15A NCAC 02D
.2601 to 02Q .0508(f).
 For all testing conditions, revised reference to “15A NCAC 02D .2601 and
General Condition JJ” to just “General condition JJ”. Condition JJ addresses
the requirements of 02D .2601.
 Revised all conditions as necessary to reference other paragraphs consistently
according to current DAQ permitting policy
Sections
2.1 B.2.c
2.1 B.3.g
2.1 E.2.c
2.1 F.2.d
2.1 G.2.c
2.1 I.2.c
2.1 K.2.c
Section 2.1 A
Same
 Removed the language
“The Permittee shall establish “normal” for these sources in the first 30 days
following the start-up of these sources”.
The Permittee confirmed all of the affected source have completed start up
and have established ‘normal” pursuant to the applicable requirement
Same
Applicable
regulations
table
Same
 Removed notification of construction requirement for CD-8b. Notification
was submitted via letter dated June 8, 2014.
 Removed notification of construction requirement for CD-U4ActC.
Notification was submitted via letter dated May 12, 2016.
 Removed notification of construction requirement for alkaline-based fuel
additive on Unit 3. Notification was submitted via letter dated April 9, 2014.
 Removed reference to CD-8 and CD-8b on Unit 3 at request of Permittee.
“The system is no longer needed and has been rendered mechanically nonfunctional and tagged out.”
 Pursuant to request received on February 23, 2017, removed reference to CD2a from unit 1, CD-5a from unit 2 and CD-12B from Unit 4.
 In the applicable regulations table, removed reference to CAIR requirements
and added reference to CSAPR requirements
 Removed reference to 15A NCAC 02D .1100 and 02Q .0309 state
enforceable only air toxics conditions
 Removed reference to 15A NCAC 02D .2500
 Removed reference to CAIR requirements for SO2 pursuant to 15A NCAC
02D .2400 (40 CFR 96)
 Added reference to CSAPR requirements for SO2 pursuant to 40 CFR 97.
 Removed reference to CAIR requirements for NOx pursuant to 15A NCAC
02D .2400 (40 CFR 96)
 Added reference to CSAPR requirements for NOx pursuant to 40 CFR 97.
Page 24 of 32
Existing
Section
New Section
Description of Changes
 Simplified the 02D .0521 Limit/standards description. The language is
redundant with the language found in the permit condition. The intent of the
table is for quick reference purposes only.
1
Same
a.
Same
c
Same
15A NCAC 02D .0519 condition
 Revised wording of condition to clarify the emission limits when burning
single fuels and to align with existing rule language. No change in intent was
made.
 Removed the following language:
For monitoring purposes, the following emission limits will apply:
i. When only coal is burned, the emission limit shall be 1.8 pounds per
million Btu heat input.
ii. When only oil is burned, the emission limit shall be 0.8 pounds per
million Btu heat input.
iii. When oil is burned other than for startup, the emission limit shall be
1.1 pounds per million Btu heat input corresponding to no more than
70 percent of total heat input being from oil.
These values are actually emission limitations for the given fuel firing
configuration which are not just for “monitoring purposes.” Thus, the language is
also redundant given the revision to condition a. described above. No changes in
intent were made.
7
Same
b and c
Same
8
(RESERVED)
8
10
10
(RESERVED)
 Removed 15A NCAC 02Q .0317 (PSD Avoidance) condition for H2SO4
which was associated with the now removed conditioning systems on Unit 3
(ID Nos. CD -8 and CD-8b). This condition is now a placeholder entitled
RESERVED to preserve the existing permit condition numbering at the
request of the Permittee.
11
11
(RESERVED)
 Removed State Enforceable Only 15A NCAC 02Q .0309 Arsenic Annual
Emission Limit, consistent with current DAQ policy for sources subject to a
MACT standard. See permit review for details. This condition is now a
placeholder entitled RESERVED to preserve the existing permit condition
numbering at the request of the Permittee.
12
Same
 In condition a, the descriptor that included “off-specification oil” was
removed. The boilers have not been permitted to fire off-specification oil as
of permit no. T51.
 Revised title of condition to reference the underlying applicable requirement
for which CAM is being implemented (i.e., 15A NCAC 02D .0536).
 Corrected external reference from 2.1 A.4 e to 2.1 A.4.d in the indicator
range discussion
13
13
(RESERVED)
 The condition addressing “15A NCAC 02D .2500 Mercury Rules for Electric
Generators” was removed. This regulation expired on February 1, 2016. This
condition is now a placeholder entitled RESERVED to preserve the existing
permit condition numbering at the request of the Permittee.
15A NCAC 02D .0606 condition
 Added reference to Appendix P of Part 51 performance specifications to the
PM and SO2 CEMS requirements
 This Section was a placeholder indicated as “reserved” It has been replaced
with a CSAPR condition which is Federally Enforceable Only.
Page 25 of 32
Existing
Section
New Section
Description of Changes
14
Same
15A NCAC 02Q .0317 PSD Avoidance (15A NCAC 02D .0530) Condition
a
Same
b
Same
c.
Same
d.
Same
15
a
Same
Same
b
Same
c
Same
d
Same
16
Same
various
Same
2.1 B.3.d(A)
Same
2.1 B.3.e
Same
 Removed the following language:
THIS CONDITION IS NOT SHIELDED PURSUANT TO 15A NCAC 02Q
.0512(a).
This condition was included as part of a minor modification in permit no. T47. It
is now being subjected to public /EPA review and qualifies for a permit shield.
See permit review for discussion.
 Revised regulatory reference from 15A NCAC 02D .0601 to 15A NCAC
02Q. 0508(f) consistent with current permitting policy
 Revised regulatory reference from 15A NCAC 02Q .0308 to 15A NCAC
02Q. 0508(f)
 Added non-compliance language consistent with current DAQ permitting
policy
 Revised regulatory reference from 15A NCAC 02Q .0308 to 15A NCAC
02Q. 0508(f)
 Revised layout to be consistent with current permitting standards. No changes
in intent were made.
15A NCAC 02Q .0317 NANSR Avoidance (15A NCAC 02D .0531) Condition
 Removed the following language:
THIS CONDITION IS NOT SHIELDED PURSUANT TO 15A NCAC 02Q
.0512(a).
This condition was included as part of a minor modification in permit no. T47. It
is now being subjected to public /EPA review and qualifies for a permit shield.
See permit review for discussion.
 Revised regulatory reference from 15A NCAC 02D .0601 to 15A NCAC
02Q. 0508(f) consistent with current permitting policy
 Revised regulatory reference from 15A NCAC 02Q .0308 to 15A NCAC
02Q. 0508(f)
 Added non-compliance language consistent with current DAQ permitting
policy
 Corrected reference from 2.1 A. 13.c. to 14.c.
 Revised regulatory reference from 15A NCAC 02Q .0308 to 15A NCAC
02Q. 0508(f)
 Corrected reference from 2.1 A.13.d to 14.d
15A NCAC 02D .1111: MAXIMUM ACHIEVABLE CONTROL
TECHNOLOGY (40 CFR PART 63 SUBPART UUUUU) Condition
 Revised paragraph numbering to be consistent with current permitting policy.
All non-compliance statement paragraphs were numbered.
This section was revised pursuant to be consistent with the NSPS OOO, which
was revised in 2009 after the previous permit renewal. With the exceptions of
vents, opacity limits from building openings have been changed from 0 % to 7 %
opacity. See review for details.
 Added standard non-compliance language to the TV testing requirement.
2.1 C
applicable
regulations
table
2.1 C.1
Same
Same
 Simplified the 02D .0521 Limit/standards description. The language is
redundant with the language found in the permit condition. The intent of the
table is for quick reference purposes only.
02D .0516 condition
Page 26 of 32
Existing
Section
New Section
Description of Changes
b
c
NA
b
 simple renumbering
 added 15A NCAC 02Q .0508(f) regulatory reference
 Added standard TV testing condition pursuant to current TV permitting shell.
2.1 c.2. e
same
 Corrected reference from Section 2.1 A.7.c to Section 2.1 A.7.d
2.1 C.3.
Same
2.1 D.
Same
Revised MACT ZZZZ to be consistent with current DAQ conditions and
memorialize initial notification. No changes in intent were made.
 Added State Enforceable Only requirement indicator to this condition
2.1.E.
Same
2.1 E
applicable
regulations
tables
Sections 2.1
E, G, H, I J K
2.1 H.1
Same
b
c
NA
b
 simple renumbering
 added 15A NCAC 02Q .0508(f) regulatory reference
 Added standard TV testing condition pursuant to current TV permitting shell.
2.1 H.2.e
Same
 Corrected reference from section 2.1 A.7.c to 2.1 A.7.d
2.1 H.3
Same
2.1. J.2
same
2.1 J.3.
Same
 Revised MACT ZZZZ to be consistent with current DAQ conditions and
memorialize initial notification. No changes in intent were made.
 Revised the NSPS Subpart IIII condition to removed outdated fuel sulfur
requirements, account for changes in the rule that address how the engine
may be operated in non-emergency situations
 Revised MACT ZZZZ to be consistent with current DAQ conditions.
Section 2.1 K.
Same
2.1 K.1
same
b.
Same
Same
c and e
2.1 K.2.
Same
b.
Same
c, d and e.
same
d.
same
2.2 A.1
Same
2.2 B.1
NA
 Revised listing of equipment to clarify ES-FTLW1 and 2 (wet flyash loading
equipment) have no PM controls; No changes are necessary to the M/R/R
requirements.
 Simplified the 02D .0521 Limit/standards description. The language is
redundant with the language found in the permit condition. The intent of the
table is for quick reference purposes only.
02D .0516 condition
 Removed asterisked notification requirement. This requirement was met via
notification letter dated July 14, 2015.
15A NCAC 02D .0515 condition
 Added standard shell testing requirement to be consistent with current TV
permitting policy.
 Revised regulatory reference from 15A NCAC 02Q .0308 to 15A NCAC
02Q. 0508(f)
15A NCAC 02D .0521 condition
 Added standard shell testing requirement to be consistent with current TV
permitting policy.
 Revised regulatory reference from 15A NCAC 02Q .0308 to 15A NCAC
02Q. 0508(f)
 Added non-compliance statement consistent with current DAQ permitting
policy
 Added State enforceable only requirement indicator to this condition
 Removed the 15A NCAC 02Q .0309 State Enforceable Only avoidance limit
for the applicability of 15A NCAC 02Q .0705. Rule 02Q.0705 was repealed
May 1, 2014. In addition, the arsenic limit was based on the previous arsenic
Page 27 of 32
Existing
Section
New Section
Description of Changes
AAL, which has been revised upward 9-fold. See permit review for
discussion.
 Removed the State Enforceable Only 15A NCAC 02Q .0309 requirement to
submit a toxics modeling demonstration. The Permittee has met this
requirement. See review for discussion.
 The permit shield section was substantially revised. See review for
discussion.
Phase II Acid Rain Permit Requirements
 Added permit effective dates to be consistent with other NC Acid Rain
permits
Revised layout of Section B to remove redundant language; Changes include:
 SO2 allowance language and footnote were combine into a single table
 NOx limit language was combined to minimize redundancy. Each unit’s
emission limits and heat input limits were combined into a table. Note
unit 3 has a minimum heat input limit in contrast to the other units.
 Revised effect date from 2012 to 2015 as included in the revised NOx
averaging plan. Since the plan does not have a termination date, no
termination date was included in the revised permit condition.
 Removed language addressing multistate environmental programs
approval. The revised averaging plan consists solely of units within
North Carolina.
 Revised dates
2.2 B.2
NA
Section 2.3
Same
Section 2.4
Same
B
Same
D
Same
Section 2.5,
Conditions A,
B C and D.
NA
Removed all CAIR permit requirements which included conditions addressing
the following repealed regulations:
 15A NCAC 02D .2403: NITROGEN OXIDE EMISSIONS
 15A NCAC 02D .2405: NITROGEN OXIDE EMISSIONS DURING
OZONE SEASON
 15A NCAC 02D .2404: SULFUR DIOXIDE EMISSIONS
General
Conditions
Same
Revised General Conditions from version 3.6 to current version 4.0 Changes
include:
 Updating regulation references from “2D” and “2Q” to “02D” and
“02Q” to be consistent with regulation nomenclature.
 References to DENR were revised to DEQ
 Minor typographical corrections
Page 28 of 32
Public Notice/EPA and Affected State(s) Review
The changes addressed in the permit application will be addressed as a Title V major modification pursuant to 15A NCAC 02Q
.0516. A notice of the DRAFT Title V Permit shall be made pursuant to 15A NCAC 02Q .0521. The notice will provide for a
30-day comment period, with an opportunity for a public hearing. Copies of the public notice shall be sent to persons on the
Title V mailing list and EPA. Pursuant to 15A NCAC 02Q .0522, a copy of each permit application, each proposed permit and
each final permit pursuant shall be provided to EPA. Also pursuant to 02Q .0522, a notice of the DRAFT Title V Permit shall
be provided to each affected State at or before the time notice provided to the public under 02Q .0521 above.
Recommendations
It is recommended that permit no. 03676T54 be issued.
Attachment A
Region: Mooresville Regional Office
County: Catawba
NC Facility ID: 1800073
Inspector’s Name: Tonisha Dawson
Date of Last Inspection: 06/23/2014
Compliance Code: 3 / Compliance - inspection
Permit Applicability (this application only)
NORTH CAROLINA DIVISION OF
AIR QUALITY
Air Permit Review
Permit Issue Date: 11/06/2014
Facility Data
SIP: 2D .0515, .0521
NSPS:
NESHAP:
PSD:
PSD Avoidance: 2Q .0317 for PM-10
NC Toxics:
112(r):
Other: 2Q .0317 NAA NSR Avoidance for PM-2.5
Applicant (Facility’s Name): Duke Energy Carolinas, LLC - Marshall Steam
Station
Facility Address:
Duke Energy Carolinas, LLC - Marshall Steam Station
8320 East Highway 150
Terrell, NC
28682
SIC: 4911 / Electric Services
NAICS: 221112 / Fossil Fuel Electric Power Generation
Facility Classification: Before: Title V After: Title V
Fee Classification: Before: Title V After: Title V
Contact Data
Facility Contact
Authorized Contact
George Tolbert
EHS Professional
(336) 623-0415
900 South Edgewood
Road
Eden, NC 27288
Brian Weisker
General Manager
(828) 478-7600
8320 East Highway 150
Terrell, NC 28682
Application Data
Technical Contact
William Horton
Senior Environmental
Specialist
(980) 373-3226
526 South Church Street
(EC13K)
Charlotte, NC 28202
Application Number: 1800073.14C
Date Received: 04/04/2014
Application Type: Modification
Application Schedule: TV-Sign–501(c)(2)
Existing Permit Data
Existing Permit Number: 03676/T50
Existing Permit Issue Date: 03/05/2014
Existing Permit Expiration Date: 08/31/2015
Total Actual emissions in TONS/YEAR:
CY
SO2
NOX
VOC
CO
PM10
Total HAP
Largest HAP
2012
4599.15
11027.63
105.42
2305.47
1070.66
141.29
116.74
[Hydrogen chloride (hydrochlori]
2011
3852.98
9086.27
132.55
2898.98
1809.95
179.07
147.14
[Hydrogen chloride (hydrochlori]
2010
3657.90
9608.90
145.52
3177.09
1295.51
192.06
160.65
[Hydrogen chloride (hydrochlori]
2009
4570.86
9744.37
145.22
3175.69
1324.23
198.42
165.90
[Hydrogen chloride (hydrochlori]
2008
6174.76
13234.28
149.90
3237.13
7151.50
190.50
154.02
[Hydrogen chloride (hydrochlori]
Review Engineer: Ed Martin
Review Engineer’s Signature:
Comments / Recommendations:
Issue 03676/T51
Permit Issue Date: 11/06/2014
Permit Expiration Date: 08/31/2015
Date: 11/06/2014
1
I.
Purpose of Application
Duke Energy is requesting a permit modification to operate a brominated powered activated carbon injection (ACI)
system on Unit 4 on a permanent basis for the purpose of reducing mercury emissions in preparation for compliance
with the Utility Mercury and Air Toxics Standards (MATS) rule. Duke was permitted in Permit T47 on September
14, 2010, to conduct a short-term evaluation of reducing mercury emissions on Unit 4 using both spray-applying
calcium dibromide and injection of activated carbon on a temporary basis, for a total calcium dibromide use of
62,000 lbs. and total activated carbon use of 150, 000 lbs. This was placed in the permit at conditions 2.1.A.14 and
15 which are now being revised as discussed below. No new equipment was permitted at that time for the
evaluation. The evaluation has been completed and provisions for calcium dibromide are no longer needed and this
is being removed from the permit. This permit modification will add a 14’ diameter x 60’ high dry storage injection
(DSI) ACI storage silo (ID No. ES-U4ACISilo) with a bin vent filter (ID No. CD-U4ACISiloBf). Duke was given
approval to construct this equipment (Notice of Intent to Construct) on March 17, 2014, prior to receipt of the air
permit as allowed by N.C.G.S. 143-215.108A(b) (see Section V.A below).
After the draft permit was sent to Duke for review on October 15, 2014, they requested the following additional
changes be made:
1.
To remove burning of “off-specification oil” in Units 2 and 3 (in equipment description and state-only
condition 2.1.A.8) and remove burning of waste tetra-ammonium or di-ammonium ethylene di-amine
tetra-acetic acid (EDTA) boiler cleaning solution in Units 1, 2, 3 and 4 (in state-only conditions 2.1.A.8.d and
2.1.A.9) as Duke has discontinued burning these substances. Duke requested the 2D .1100 toxic limits for
ammonia in Section 2.1.A.8 that were established through modeling for combustion of off-specification oil and
waste EDTA boiler cleaning solution be retained (see Section V.C below) (ref. emails from Bill Horton to Ed
Martin dated October 16, 21, 23 and 27, 2014).
2.
To remove spray applying calcium dibromide on the coal for Units 1 and 2 that was placed in the permit for a
short-term trial for a mercury reduction evaluation that has now ended (in PSD avoidance condition 2.1.A.16
for PM/PM10 and NA NSR condition 2.1.A.17) (ref. emails from Bill Horton to Ed Martin dated October 16,
2014 and October 21, 2014).
3.
To delete insignificant activities I-25, I-28, I-34.1 and I-38 (ref. two emails from Bill Horton to Ed Martin dated
October 21, 2014).
4.
To request the state-only 2D .2500 mercury condition 2.1.A.13 be revised consistent with previous changes to
the same condition for Cliffside Units 1-5 in Permit No. 04044T34, condition 2.1.A.8 (see Section V.B below)
(ref. emails from Bill Horton to Ed Martin dated October 17, 2014 and October 21, 2014).
This is a significant permit modification pursuant to rule 15A NCAC 2Q .0501(c)(2). The permit shield
described in General Condition R does not apply to these changes. Public notice of the draft permit is not
required at this time. The Permittee must file a Title V Air Quality Permit Application pursuant to 15A
NCAC 2Q .0504 for these changes on or before 12 months after commencing operation in accordance with
General Condition NN.1.
II.
Permit Changes
The following changes were made to the Duke Energy Carolinas LLC- Marshall Air Permit No. 03676T50:
Page No.
Section
Change
--
Cover
Amended permit numbers and dates.
--
Insignificant
Activities List
Removed sources I-25, I-28, I-34.1 and I-38.
2
3-4
4
Section 1, table
of emission
sources
Removed “off-specification oil” from equipment description for Units 2 and 3.
Removed Unit 4 control device: system for spray-applying calcium bromide on coal
(ID No. CD-U4CaBr2(Temp)).
Removed “(Temp)” from Unit 4 control device ID No. CD-U4ActC (Temp).
6
Added MS4 DSI ACI storage silo (ID No. ES-U4ACISilo) and ACI storage silo bin vent
filter baghouse (ID No. CD-U4ACISiloBf).
Removed spray-application of calcium bromide (ID No. CD-U4CaBr2(Temp)) from
footnote **.
Removed “(Temp)” from ID No. CD-U4ActC (Temp) from footnote **.
7
9
Section 2.1.A,
equipment
description
14
Section 2.1,
regulation table
Section
2.1.A.1.d
Section
2.1.A.2.c
Section 2.1.A.8
14
Section 2.1.A.9
17
Section 2.1.A.13
17-18
Section 2.1.A.14
and
Section 2.1.A.15
Section 2.1.A.16
and
Section 2.1.A.17
Section 2.1.K
9
10
18
35-36
III.
Removed “off-specification oil” from equipment description for Units 2 and 3.
Removed Unit 4 spray-application system for calcium bromide (ID No.
CD-U4CaBr2(Temp)) from equipment description.
Removed “(Temp)” from Unit 4 equipment description for powered activated carbon
system ID No. CD-U4ActC(Temp).
Removed reference to Section 2.1.A.16 for PM/PM10 and removed reference to
Section 2.1.A.17 for PM2.5.
Added to clarify that missing data shall be filled in accordance with 40 CFR Part 75
whenever the unit combusts any fuel.
Added to clarify that missing data shall be filled in accordance with 40 CFR Part 75
whenever the unit combusts any fuel.
Removed this condition for burning off-specification oil and waste tetra-ammonium
or di-ammonium ethylene di-amine tetra-acetic acid (EDTA) boiler cleaning solution.
Removed this condition for burning waste tetra-ammonium or di-ammonium ethylene
di-amine tetra-acetic acid (EDTA) boiler cleaning solution.
Revised mercury requirements.
Revised these conditions to remove spray applying calcium dibromide and change the
amount of amount of injected powered activated carbon from a total of 150,000 lbs to
9,000,000 lbs per year.
Removed these conditions for spray-applying calcium dibromide on the coal.
Added this section for the MS4 DSI ACI storage silo.
Facility Description
Duke Power’s Marshall Steam Station is an electric utility that generates electrical power. The Marshall
Steam Station is permitted for four coal/No. 2 fuel oil-fired electric utility boilers (ID Nos. ES-1, ES-2, ES-3,
ES-4) and various supporting equipment.
IV.
Summary of Changes to Emission Sources and Control Devices
The equipment description changes for the above modifications are as follows (changes in bold):
Emission
Source
ID No.
Emission Source Description
Control Device
ID No.
3
Control Device Description
Emission
Source
ID No.
Control Device
ID No.
Control Device Description
CD-U4CaBr2
(Temp)
System for spray-applying calcium bromide
on coal**
CD-11c (U4SNCR)
Selective non-catalytic reduction (SNCR) NOx
reduction system*
Emission Source Description
CD-12
One No. 2 fuel oil/coal-fired electric
utility boiler (7,110 million Btu per
hour heat input) equipped with a
low NOx concentric firing system,
separated overfire air/lowered fired
low-NOx technologies
(SOFA/LOFIR), and alkaline-based
fuel additive***
ES-4
CAM
Unit 4
CD-12B
(NH3FGC)
Anhydrous
ammonia
injection
ash
conditioning system (20 ppm maximum
injection rate)*
CD-U4ActC
(Temp)
System for injecting powdered activated
carbon**
CD-13 (ESPnew)
CD-U4
FGD
ES-U4ACISilo†
**
†
V.
MS4 DSI ACI storage silo (6000
cubic feet capacity)
One flue gas conditioning system consisting of
an integral sulfur trioxide ash conditioner*
CD-U4ACISiloBf†
One cold-side electrostatic
(768,108 feet of plate area)
precipitator
Wet flue gas desulfurization system consisting
of spray tower absorber (approximately 165
gal/min limestone slurry injection rate)
ACI storage silo bin vent filter (259 square
feet of filter area)
The spray-application of calcium bromide (ID No. CD -U4CaBr2(Temp)), injection of powdered activated carbon (ID No.
CD-U4ActC(Temp)), and installation of emergency generator (ID No. ES-37 (EmGenLF)) are listed as a minor
modification per 15A NCAC 2Q .0515. The compliance certification as described in General Condition P is required. Unless
otherwise notified by NC DAQ, the affected terms of this permit (excluding the permit shield as described General Condition
R) for this source shall become final on November 13, 2010. Until this date, the affected permit terms herein reflect the
proposed operating language that the Permittee shall operate this source under pursuant to 15A NCAC 2Q .0515(f).
These emission source(s) and/or control device(s) (ID Nos. ES-U4ACISilo and CD-U4ACISiloBf) are listed as a 15A NCAC
2Q .0501(c)(2) modification. The Permittee shall file a Title V Air Quality Permit Application on or before 12 months after
commencing operation in accordance with General Condition NN.1. The permit shield described in General Condition R does
not apply and compliance certification as described in General Condition P is not required.
Emission and Regulatory Evaluation
Emissions from the ACI system result from injection of the powered activated carbon and from filling the
ACI storage silo as follows:
A. Emissions from Injection of Powered Activated Carbon
The maximum annual activated carbon injection rate is 9,000,000 lb/yr. At the mean ESP collection
efficiency of 99.5% over the period from 2004 to 2006, prior to installation of the FGD scrubber, which does
not account for the additional particulate removal in the FGD scrubber, the potential PM emission rate at
8760 hours per year operation is:
Annual PM emission rate: (9,000,000 lb/yr) (1-0.995) / (2000 lb/ton) = 22.5 tpy
Using the particle distribution information Duke submitted with the application for bromated powered
activated carbon from Calgon (most conservative worst case among the supply vendors), shows PM-10 to be
59% of total PM and PM-2.5 to be 17% of total PM.
Therefore PM-10 and PM-2.5 emissions are:
4
Annual PM-10 emission rate:
Annual PM-2.5 emission rate:
PM annual emission rate x 0.59 = (22.5 tpy) (0.59) = 13.28 tpy
PM annual emission rate x 0.17 = (22.5 tpy) (0.17) = 3.83 tpy
Emissions from Filling Storage Silo
The bagfilter is designed for a manufacturer’s guaranteed outlet grain loading of 0.005 grains/ft3at a
maximum air flow rate of 1000 cfm. The resulting emissions are:
(1000 ft3/min) (0.005 gr PM/ft3) (1 lb/7000 gr PM) (60 min/hr) (8760 hr/yr) / (2000 lb/ton)
= 0.19 tpy of PM/PM-10/PM-2.5
The total emissions for the ACI system from injection of the powered activated carbon and from filling the
storage silo are:
Total annual PM emissions:
Total annual PM-10 emissions:
Total annual PM-2.5 emissions:
22.5 tpy + 0.19 tpy = 22.69 tpy
13.28 tpy + 0.19 tpy = 13.47 tpy
3.83 tpy + 0.19 tpy = 4.02 tpy
< PSD/NSR threshold of 25 tpy
< PSD/NSR threshold of 15 tpy
< PSD/NSR threshold of 10 tpy
2Q .0317 to avoid applicability of 2D .0530 and 2D .0531
The above emission rates are below the PSD and NA NSR thresholds and therefore the existing avoidance
conditions 2.1.A.14 (to avoid applicability of PSD) and 2.1.A.15 (to avoid applicability of NA NSR) are
being revised to allow a powdered activated carbon injection rate not to exceed 9,000,000 lbs per year.
Monitoring and recordkeeping is required of the amount of powered activated carbon injected monthly. The
Permittee shall submit a semi-annual summary report of monitoring and recordkeeping activities containing
the monthly amount of powdered activated carbon injected in the Unit 4 boiler for the previous 17 months.
The emissions must be calculated for each of the 12-month periods over the previous 17 months.
Using the “streamlining” clause in Part 70, the Permittee will be required to comply with the monitoring,
recordkeeping and reporting requirements of PM-10 under the PSD avoidance condition to demonstrate
compliance with the requirement for PM-2.5 under NA NSR. Compliance with the monitoring,
recordkeeping and reporting requirements under PSD avoidance shall be deemed as complying with the
monitoring requirement for NA NSR avoidance condition. There are no actual changes to the NA NSR
avoidance condition 2.1.A.15, since it relies on the PSD avoidance condition 2.1.A.14; however, for that
reason both conditions are not shielded pursuant to 2Q .0512(a).
Note, in the application Duke requested removal of condition 2.1.A.15, saying Catawba Co is not currently
designated as non-attainment for PM-2.5. However, the county is still non-attainment and EPA plans to
promulgate final PM-2.5 designations in December of 2014 (according to
http://www.ncair.org/planning/pm2dot5/EPA_PM25_Resp_08192014.pdf). Therefore 2.1.A.15 cannot be
removed yet.
NSPS Applicability
This modification is not a modification under NSPS, since the primary function of the ACI system is the
reduction of air pollutants and is therefore exempted in accordance with 40 CFR 60.14(e)(5).
The ACI system is subject to the following regulations:
One MS4 DSI ACI storage silo (ID No. ES-U4ACISilo) and associated ACI storage silo bin vent
filter baghouse (ID No. CD-U4ACISiloBf)
1.
15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL
PROCESSES
Emissions of particulate matter from these sources shall not exceed an allowable emission rate as
calculated by the following equation: [15A NCAC 2D .0515(a)]
5
E = 4.10 x P 0.67
for P  30 tons/hr, or
E = 55.0 x P 0.11 - 40
for P > 30 tons/hr
where: E = allowable emission rate in pounds per hour
P = process weight in tons per hour
Monitoring/Recordkeeping Requirements
To ensure that optimum control efficiency of particulate matter is maintained by the bagfilter,
inspections and any required maintenance will be performed as recommended by the manufacturer.
If manufacturer’s recommendations are not available, as a minimum, inspections will include
annual internal inspections of the bagfilter to ensure structural integrity and monthly visual
(external) inspections of the system ductwork and material collection unit for leaks.
The Permittee shall keep records of the following:
(A)
(B)
the results of each inspection, and
any maintenance performed on the bagfilter.
Reporting Requirements
The Permittee will submit the results of any maintenance performed on the bagfilters within 30 days
of a written request by DAQ. A summary report of monitoring and recordkeeping shall be
submitted by January 30 and July 30 of each year.
2.
15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
Visible emissions from this source shall not be more than 20 percent opacity (except during startups,
shutdowns, and malfunctions) when averaged over a six-minute period. However, six-minute
averaging periods may exceed 20 percent not more than once in any hour and not more than four
times in any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity.
Monitoring/Recordkeeping Requirements
One visual observation monthly of the emission point shall be performed for any visible emissions
above normal operating conditions. The results of the observations shall be recorded.
Reporting Requirements
A summary report of the visual observations shall be submitted by January 30 and July 30 of each
year.
Note, during permit renewal, Duke should address the requirements of CAM related to the ACI system.
modification.
B. Revisions to 2D .2500 Mercury Rules for Electric Generators (condition 2.1.A.12)
Duke is requesting that this condition be revised consistent with changes to the Cliffside permit (04044T34).
This is necessary due to vacatur and repeal of the Clean Air Mercury Rule, 40 CFR Part 60, Subpart HHHH
(CAMR) effective April 16, 2012. The Cliffside permit was the first utility permit to be revised for these
changes.
Portions of 2D .2500 relied heavily on the CAMR requirements and were rendered unworkable on April 16,
2012. However, as determined by the Attorney General’s Office (memorandum dated April 24, 2012),
certain portions of this rule are severable from CAMR and remain applicable as mercury emission
requirements. Therefore, the permit is being revised consistent with the Attorney General’s memorandum to
remove the CAMR requirements and modified to include only the applicable portions of the following
state-only 2D .2500 sections:
6




The following part of 15A NCAC 2D .2500(a): “Purpose. The purpose of this Section is to control
mercury emissions from coal-fired electric steam generating Hg units[.]”
15A NCAC 2D .2501(e)
15A NCAC 2D .2509(b) through (e)
15A NCAC 2D .2511(a) through (f)
C. Duke has requested (see emails referenced in Section I above) the burning of “off-specification oil” in Units 2 and 3
and burning of waste EDTA boiler cleaning solution in Units 1, 2, 3 and 4 be removed from Section 2.1.A.8 since
Duke has discontinued burning these substances. These are the only substances referenced in Section 2.1.A.8 for
the toxic limits listed. However, Duke requested the toxic limits (shown below) for ammonia in this section be
retained since they were established through modeling for combustion of off-specification oil and waste EDTA
boiler cleaning solution as well as for other reasons including the anhydrous ammonia injection flue gas treatment
conditioning system and SCR ammonia slip.
Emission
Source(s)
Unit No. 1
Unit No. 2
Unit No. 3
Unit No. 4
Toxic
Air
Pollutant(s)
Ammonia
Ammonia
Ammonia
Ammonia
Emission Limit(s)
16.364 pounds per hour
16.366 pounds per hour
8.869 pounds per hour
8.867 pounds per hour
Since the condition does not reference the reasons for the ammonia limits other than burning of
off-specification oil and EDTA, Duke was informed (and agreed) that the limits would need to be removed
from the permit but that the modeled rates were still valid without requiring new modeling. In any event,
when the MATS rule (Utility MACT Subpart UUUUU) becomes effective (on April 16, 2015 for existing
EGUs), the boilers will not be subject to NC toxics but will need to be evaluated for presenting an
unacceptable risk to human health.
Note, Duke has discontinued burning any waste oil whether it’s off-specification oil or on-specification oil at
Marshall.
VI.
Other Requirements
PE Seal
A PE seal is not required since the bagfilter (ID No. U4ACISiloBf) flow rate is less than 10,000 acfm in
accordance with 2Q .0112.
Zoning
A letter was included with the application from the Catawba County Department of Planning, Parks &
Development stating their office received the application and had been given the opportunity for review.
Fee Classification
The facility fee classification before and after this modification will remain as “Title V”.
VII.
Recommendations
The draft permit was sent to Bill Horton at Duke on October 15, 2014 for review. Duke’s comments were
incorporated as shown herein as requested in emails from Bill Horton to Ed Martin dated October 16, 17 and 21,
2014. The permit was also sent to Tonisha Dawson at MRO and to SSCB for comment on October 15, 2014. No
comments were received from MRO or SSCB.
Issuance is recommended.
7
Attachment B
Region: Mooresville Regional Office
County: Catawba
NC Facility ID: 1800073
Inspector’s Name: Tonisha Dawson
Date of Last Inspection: 06/29/2009
Compliance Code: 3 / Compliance - inspection
NORTH CAROLINA
DIVISION OF AIR QUALITY
Air Permit Review
Permit Issue Date: September 14, 2010
Facility Data
Permit Applicability (this application only)
Applicant (Facility’s Name): Duke Energy Carolinas, LLC - Marshall Steam
Station
Facility Address:
Duke Energy Carolinas, LLC - Marshall Steam Station
8320 East Highway 150
Terrell, NC 28682
SIP: 2D .0521
NSPS: IIII
NESHAP: ZZZZ
PSD:
PSD Avoidance: PM10
NC Toxics:
112(r):
Other: NAA NSR Avoidance for PM2.5
SIC: 4911 / Electric Services
NAICS: 221112 / Fossil Fuel Electric Power Generation
Facility Classification: Before: Title V After: Title V
Fee Classification: Before: Title V After: Title V
Contact Data
Facility Contact
Authorized Contact
Application Data
Technical Contact
Application Number: 1800073.10A
Date Received: 06/21/2010
Donna Burrell
Stephen Immel
William Horton
Application Type: Modification
Principle EHS
Regional Manager
Senior Environmental
Application Schedule: TV-Minor
Professional
(828) 478-7600
Specialist
Existing Permit Data
(828) 478-7820
8320 East Highway 150
(980) 373-3226
Existing Permit Number: 03676/T46
8320 East Highway 150
Terrell, NC 28682
526 South Church Street
Existing Permit Issue Date: 9/7/2010
Terrell, NC 28682
Charlotte, NC 28202
Existing Permit Expiration Date: 8/31/2015
Review Engineer: Rahul Thaker
Comments / Recommendations:
Issue 03676/T47
Review Engineer’s Signature:
Date: September 14, 2010
Permit Issue Date: 9/14/2010
Permit Expiration Date: 8/31/2015
1. Purpose of Application
Duke Energy Carolinas, Inc. (“Duke Energy”) has requested to obtain a permit approval to conduct evaluations of
mercury emissions control for Unit 4 boiler (ID No. ES-4) when spray-applying and injecting calcium dibromide
and powdered activated carbon, respectively.
2. Facility Description
The Marshall Steam Station is an electric power plant.
3. Application Chronology
Refer to “Events Update” screen in the I-BEAM.
4. Statement of Compliance
1
The Responsible Official has certified compliance with all applicable requirements in Form E5 of the application.
The inspection report for the last visit to the facility (08/26/2009) includes, “Based on my (Tonisha Dawson)
observations, this facility appeared to be in compliance with the applicable air quality regulations at the time of the
inspection.”
5.
Permit Modification/Changes
5.1 To conduct evaluations of mercury emissions control for Unit 4 boiler (ID No. ES-4) when spray-applying
and injecting calcium dibromide and powdered activated carbon, respectively.
In preparation for any future regulations requiring control of mercury emissions from electric generating units
(EGU), Duke Energy has planned for two separate mercury control evaluation studies on this boiler.
The first study will focus on the effectiveness of liquid calcium dibromide (CaBr 2) on the oxidation of mercury and
its capture by the downstream control equipment; ESP and wet FGD. This study will be conducted by EPRI during
the first two weeks of November 2010.
The second study will be an evaluation of the effectiveness of powdered activated carbon (PAC) in controlling
emissions of mercury. This study will be conducted by ADA during the last two weeks of November 2010.
Spray-applying of Calcium Dibromide (CaBr2) [ID No. CD-U4CaBr2 (Temp)]
During the first 4-5 days of the study, liquid 53% (by weight) CaBr 2 will be spray-applied onto the coal feeder just
above the pulverizer-mills at an application rate ranging from 0.25 to 2.5 lb CaBr 2 per ton of coal. During this first
week, optimum injection rate of this sorbent is identified. In the second week, this optimum rate of application will
be continued for application. During the study, the contractor plans to apply approximately 62,000 lbs of CaBr 2 on
28,500 tons of coal. Mercury emissions before and after the study will be monitored using speciated mercury CEM.
During the combustion, vapor phase mercury in the coal can form HgBr and HgBr 2, which will adhere to the flyash.
It will be captured by the ESP with additional control provided by FGD. The calcium can reform as CaSO4, CaO2,
CaCO3, etc. The above compounds add to the particulate emissions.
Based upon the usage of 62,000 lbs of CaBr 2 and 57,000,000 lbs of coal during the study, and the fly ash content of
11%w and the PM emission rate of 0.03 lb/million Btu (both from recent particulate emission test on Unit 4 boiler),
the amount of PM emissions attributable to this study will be approximately 0.0002 lb/million Btu.
Thus, based upon the maximum heat input rate of 7,110 million Btu/hr for the boiler, the PM emission rate
attributable to the study for two weeks (325 hours) time period can be approximately 0.23 tons/yr or 0.21 tons/yr
PM10 (assuming 90% of PM is PM10). Finally, based upon 8,760 hours of operation, the potential PM emission
rate can be estimated as 6.3 tons/yr or 5.67 tons/yr PM10.
Injection of Powdered Activated Carbon (PAC) [CD-U4ActC (Temp)]
During the first week, non-brominated and brominated PAC will be injected downstream of the air preheater at
varying rates ranging from 300 to 1,000 lbs/hr. Also, the application rate corresponding to optimum mercury
control will be identified. In the second week, this optimum application rate will be continued for application. The
contractor will use about 150,000 lbs of PAC.
Based upon 150,000 lbs of PAC usage during the study, and PM control of 98.5% with ESP and 50% with FGD, the
amount of PM10 attributable to study will be approximately 0.563 tons/yr.
For 300 lbs/hr of PAC usage, PM control of 98.5% with ESP and 50% with FGD, maximum heat input rate of 7,110
million Btu/hr for the boiler, and the 8,760 hours of operation, the potential PM emissions attributable to the PAC
injection can be estimated as approximately 9.96 tons/yr PM or 8.87 tons/yr PM10.
2
Similarly for 1,000 lbs/hr of usage of PAC, the potential PM emissions can be as high as 32.85 tons/yr or 29.57
tons/yr PM10 (6.75 lbs/hr). This equals the PM10 emission rate of 0.00095 lb/million Btu.
Thus, the potential PM emissions from the applications of these sorbents (calcium bromide and powdered activated
carbon) for controlling mercury emissions will be as follows: 16.2 tons/yr to 39.2 tons/yr PM, 14.5 tons/yr to 35.2
tons/yr PM10. In addition, it is assumed that PM2.5 emissions are the same as PM10 emissions, thus the potential
PM2.5 emissions will also be between 14.5 tons/yr to 35.2 tons/yr PM10.
Therefore, a permit limit is needed to avoid PSD for both PM and PM10. In addition, because the County of
Catawba is in non-attainment (NA) of PM2.5 NAAQS, a limit is also required under NA NSR for PM2.5 emissions.
The following includes monitoring approach for both avoidance stipulations:
2Q .0317 to avoid applicability of 2D .0530
The amounts of spray-applying calcium dibromide and injecting powdered activated carbon in Unit 4 boiler (ID No.
ES-4) during the mercury control evaluation studies shall not exceed 62,000 lbs and 150,000 lbs, respectively. The
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the amounts of spray-applying calcium
dibromide and injecting powdered activated carbon in Unit 4 boiler (ID No. ES-4) are not monitored or the amounts
of spray-applying calcium dibromide and injecting powdered activated carbon in Unit 4 boiler (ID No. ES-4) exceed
the respective amounts included above.
The Permittee shall submit a summary report acceptable to the Regional Air Quality Supervisor of monitoring and
recordkeeping activities, postmarked on or before 30 days from the completion of mercury control evaluation
studies. The report shall contain the following: The amounts of spray-applying calcium dibromide and injecting
powdered activated carbon in Unit 4 boiler for the mercury control evaluation studies.
2Q .0317 to avoid applicability of 2D .0531
Using the “streamlining” clause in Part 70, the Permittee will be required to comply with the monitoring (including
record keeping and reporting) requirements of PM10 under PSD avoidance stipulation to demonstrate compliance
with the requirement for PM2.5 under NA NSR, and no additional monitoring requirements shall apply.
Compliance with the monitoring requirement under PSD avoidance shall be deemed as complying with the
monitoring requirement for NA NSR avoidance condition. Similarly, reporting requirement under PSD avoidance
shall be sufficient for satisfying reporting requirement in NA NSR avoidance stipulation.
2D .0536
The only other applicability, which needs to be addressed, is the compliance with the existing SIP standard of 0.18
lb/million Btu under 2D .0536.
Based on the recent particulate emission test showing emission rate of 0.03 lb/million Btu, the PM emissions after
this modification can be estimated as follows: (0.03 + 0.002 + 0.00095) lb/million Btu = 0.0329 lb/million Btu,
which is less than the SIP limit of 0.18 lb/million Btu.
Hence, the compliance is expected for this SIP standard.
5.2 To install 100 kW diesel-fired emergency generator (157 HP engine output) at landfill (ID No. ES-37
(EmGenLF)).
For the proposed 100 kW diesel-fired emergency generator (157 HP engine output), based upon 500 hours of
operation, the potential uncontrolled emissions of each criteria pollutant are less than 5 tons/yr and potential
uncontrolled emissions of each hazardous air pollutants are less than 1,000 lbs/yr. Thus, DAQ may deem this source
“insignificant activity because of category” under the provision of 2Q .0503(8) and hence, can list accordingly as an
attachment to the revised permit. But, DAQ will not be able to classify this emission source as insignificant
activity under 2Q .0503(8) and will permit it with specific conditions. See Section 7 for details.
3
The applicable requirements for the proposed generator are 2D .0521, .0524, .1111, and 2Q .0700.
15A NCAC 2D .0521 "Control of Visible Emissions"
For sources manufactured after July 1, 1971, visible emissions shall not be more than 20 percent opacity when
averaged over a six-minute period. However, except for sources required to install COMs, six-minute averaging
periods may exceed 20 percent opacity if:
(1) No six-minute period exceeds 87 percent opacity;
(2) No more than one six-minute period exceeds 20 percent opacity in any hour; and
(3) No more than four six-minute periods exceed 20 percent opacity in any 24-hour period.
The proposed generator is subject to 20 percent opacity limit. The compliance with this requirement will be verified
after their commencement of operation.
15A NCAC 2D .0524 "New Source Performance Standards"
Applicability
EPA has promulgated NSPS Subpart IIII "Standards of Performance for Stationary Compression Ignition Internal
Combustion Engine" in 71 FR 39154 on July 11, 2006. This NSPS became effective on September 11, 2006. The
affected source under the NSPS is each stationary compression ignition (CI) internal combustion engine (ICE) [CI
ICE], whose construction, modification or reconstruction commenced after July 11, 2005. The date of construction
is the date the engine is ordered by the owner or operator.
Owners and operators of stationary CI ICE that commence construction after July 11, 2005 where the stationary CI
is manufactured after April 1, 2006 and is not a fire pump engine, is subject to the requirements of this NSPS as per
§60.4200(a)(2).
The proposed emergency generator’s electric output capacity is 100 kW. It will be driven by CI ICE to produce
power for emergency use only. This generator will commence construction after July 11, 2005 and the engine will
have a manufacturing date after April 1, 2006. Hence, the proposed generator is subject to the requirements of the
NSPS Subpart IIII.
Emissions Standards
In accordance with §60.4205(b) and §60.4202(a)(2), the following emissions standards shall apply for this
generator:
AFFECTED SOURCE
POLLUTANT
emergency generator
(ID No. ES-37 (EmGenLF))
nitrogen oxides + VOCs
EMISSION LIMIT
(g/hp-hr)
4.0
carbon monoxide
5.0
PM
0.30
Monitoring/Recordkeeping/Reporting

For operation after October 1, 2007, the engine must use diesel fuel with a sulfur content of less than 500 ppm.
For operation after October 1, 2010, the engine must use diesel fuel with sulfur content of less than 15 ppm.
[§60.4207, and 40CFR80.510(a) and (b)]
4

The engine must be equipped with a non-resettable hour meter prior to startup, for an engine that is to be
classified as emergency use. [§60.4209(a)]

If the emergency generator is equipped with diesel particulate filter to comply with the above emission
standards, the Permittee shall install backpressure monitor on diesel particulate filter that notifies the Permittee
when the high backpressure limit of the engine is approached. [§60.4209(b)]

The owner/operator must operate and maintain the engine in accordance with the manufacturer’s written
instructions. The owner or operator may only change those engine settings that are permitted by the
manufacturer. [§60.4211(a)]

The owner or operator of an engine for 2007 or later must comply by assuring that the engine purchased is
certified to meet the applicable emissions standards and must install and configure the engine according to the
manufacturers specifications. [§60.4211(c)]

An emergency engine may be operated for maintenance and readiness checks for up to 100 hours per year.
Operation during an actual emergency is not subject to a limit on hours. [§60.4211(e)]

No initial notification is required for an emergency use engine. However, the owner or operator must keep
records of all the operation of the engine in emergency and non-emergency service that are recorded through the
non-resettable hour meter, unless the engine is shown to meet the standards applicable to non-emergency use
engines. [§60.4214(b)]

If the emergency stationary CI ICE of emergency generator is equipped with diesel particulate filter, the
Permittee shall keep records of any corrective action taken after the backpressure monitor has notified the
Permittee that the high backpressure limit of the engine is approached. [§60.4214(c)]
15A NCAC 2D .1111 "Maximum Achievable Control Technology"
Applicability
EPA has promulgated MACT Subpart ZZZZ “National Emission Standards for Hazardous Air Pollutants for
Reciprocating Internal Combustion Engines (RICE MACT)” in 69 FR 33506 on June 15, 2004 with an effective date of
August 16, 2004. This MACT was last time revised at 75 FR 9674 on March 3, 2010.
The MACT applies to RICE located at a major or an area source of HAP emissions with a site-rating of less, equal to or
greater 500 BHP.
A stationary RICE with a site-rating of equal to or less than 500 HP located at a major source of HAP is defined as
“new” if you commenced construction of the stationary RICE on or after June 12, 2006.
The proposed RICE has a site-rating of 157 HP and it will be constructed after June 12, 2006 at a “major” source of
HAP. Hence, this generator is deemed “new” affected source at a “major” source under this Subpart. Hence, it will
be required to demonstrate compliance with the MACT upon startup.
If the “new” emergency use stationary RICE located at a “major” source is subject to NSPS Subpart IIII
requirements, then the RICE must meet the requirements of MACT Subpart ZZZZ by meeting all applicable
requirements under NSPS Subpart IIII. No further requirements shall apply to such engines under MACT Subpart
ZZZZ. Refer to §63.6590(c).
15A NCAC 2Q .0700 “Toxic Air Pollutant Procedures”
See Section 7 for details.
5.3 Others
5
The proposed temporary air compressor, identified as ES-38 (TempAC), is to be brought on site by ADA
(contractor) to support its mercury emissions testing in November 2010. Thus, ADA provides contractual service to
Duke Energy Marshall Steam Station. The compressor is in total control of the contractor and thus it is not
considered part of the Marshall Steam Station facility. Therefore, the compressor is not required to be evaluated for
any air permitting (including determination of any insignificant activity) for the Marshall Steam Station permit, in
accordance with the DAQ memo of 10/15/2007 (Keith Overcash to Preston Howard). However, the contractor
(ADA) needs to evaluate whether any air permit is needed under its name for this equipment before the PAC study
commences and its compliance with various requirements. In brief, this source will not appear in the Marshall
Steam Station permit in any form.
6. NSPS, NESHAPS, PSD, Attainment Status, 112(r), and CAM
NSPS
The proposed sorbent injection systems for control of mercury emissions from Unit 4 boiler are deemed “system or
device whose primary function is the reduction of air pollutants”, thus they are NOT considered “modification”
under Part 60 (NSPS). Refer to §60.14(e)(5).
NESHAP/MACT
Not applicable to the proposed modification. EPA is to promulgate a 112(d) MACT in future. At that time, the
applicability for the MACT needs to be evaluated for all electric generating units (EGUs) at the facility.
For the proposed 157 HP diesel -fired emergency generator identified as ES-37 (EmGenLF), it is subject to RICE
MACT. Please see the complete details on this issue in Section 5.2 above.
Attainment Status and PSD
Catawba County is in attainment of all NAAQS except for PM2.5 NAAQS. PSD program applies for all attainment
pollutants and non-attainment new source review (NAA NSR) applies for PM2.5 and its precursors (SO 2 and NOx
in NC) in this county. Please refer to Section 5.1 for complete details on PSD and NAA NSR.
112(r)
This facility is subject to Section 112(r) of the Clean Air Act requirements.
CAM
The analysis on applicability of CAM requirement is not required for the proposed sorbent injection systems,
because this application is processed using the “minor modification” provisions, and not under the “significant
modification” or the “renewal” procedures.
7. Facility Wide Air Toxics
The current permit includes applicable requirements in 2D .1100, and 2Q .0711 and .0317 (2Q .0705 avoidance).
The current air permit stipulation in Section 2.2 B.1. includes facility wide emission limit for arsenic to avoid air
toxics review in 2Q .0705. In addition, the facility (all existing EGUs) has been modeled as per 2D .1100 for
emissions of ammonia, cadmium, and nickel, as per the current permit stipulation Section 2.1 A. 10.a.
NC's state enforceable only requirements in 2Q .0700 has recently been revised effective July 10, 2010, with respect
to new and modified combustion sources.
In particular, if the “modification” provision in 2Q .0703 is triggered for any air toxics listed in 2Q .0711, then the
facility must evaluate the emissions for that pollutant from the modified Unit (Unit 4 boiler), all permitted
6
combustion sources, all permitted non-combustion sources, and all insignificant activities (all activities listed to the
cover letter to the permit and any new activity included in this application) emitting the same pollutant.
As stated above, the CaBr2 is spray-applied onto the coal being conveyed on the coal feeder (located just above the
pulverizers).
The company contends that the MSDS for CaBr2 does not list any pollutant regulated in NC’s air toxics program nor
does it indicate any that would be emitted as a consequence of the combustion.
But, the MSDS for this sorbent on page 3 indicates that “thermal decomposition products may include toxic and
corrosive fumes of hydrogen bromide and/or bromine”.
Bromine is a regulated pollutant under 2Q .0700. In addition, the spray-applied coal is combusted (at high
temperatures) in the boiler, so the possibility of thermal decomposition of the sorbent, and thus, formation/emission
of bromine must need to be addressed.
Upon DAQ’s comment, the company has investigated this issue and offered the following rebuttal (in double
quotes):
“...After combustion at > 500 °C, bromine will leave the WFGD as bromide...Thus, most of the bromine added to
the coal as CaBr2 is leaving a limestone-based WFGD once again as CaBr2 with its off-water. Only a very small
amount is emitted at the stack as HBr (< 1 mg HBr / dscm), but not as bromine.”
“Halogen measurement methods (M26) are not sensitive enough to detect the levels of concentration you (Bill H.)
cited for NC requirements. Any halogen emitted at the stack is likely to be HBr and not Br2, and HBr will be below
detection limits. The practical detection limit for bromides at the stack using M26 is ~0.04 ppm. At the detection
limit, it would be very difficult to determine what the accurate speciation may be. The NC TPER level for bromine
of 0.054 lb/hr is about 0.003 ppm for Marshall [Unit 4] (assume 700 MWe), well below the 0.04 ppm detection limit
for bromides via M26. In addition, two EPRI reports (not yet published) support this statement and show bromides
at the stack to be below detection limits by all practical purposes. These reports have not been officially published
and are confidential at this time.”
After reviewing the above information, DAQ concludes that the formation/emission of bromine (Br2) is not
expected at the stack conditions and thus, “modification” provision in 2Q .0700 is not triggered. Thus, NC air toxics
requirements do not apply to the proposed project involving CaBr 2 spray-application.
For PAC, the company states that the associated MSDSs do not list any air toxics. It adds that while the MSDSs
indicate that thermal composition (burning) may produce formaldehyde, the PAC is not burned; therefore there is no
release of formaldehydes or ethylene. In addition, it stated that although the PAC could be injected either before or
after the air preheater, it intends to inject the PAC after the air preheater (approximate temperature 290 oF), and there
would no combustion in this ductwork.
DAQ believes that the injection of PAC in the ductwork after the air preheater is not expected to create emissions of
formaldehyde, and therefore, it concludes that NC air toxics regulation does not apply to the mercury control study
involving PAC injection.
Finally, regarding the construction and operation of a new emergency generator (100 kW) to be located at the
Marshall facility landfill, as stated above, the facility has been modeled for emissions of ammonia, cadmium, and
nickel, as per the current permit stipulation Section 2.1 A. 10.a.
Based on the rule revisions as discussed above, the facility now must make an evaluation of all NC regulated toxics
expected from this generator, and all permitted sources (combustion and non-combustion) and all insignificant
activities, if emitting the same pollutants emitted by the new generator. As per the current DAQ policy, the permit
applications received by DAQ prior to air toxics rule revisions effective date of July 10, 2010 will be processed and
the permit revisions will be issued with compliance schedules using the provision in 2Q .0709 “Demonstrations”. In
brief, the compliance schedule will include requirements of submittal of modeling protocol and the complete permit
7
application including facility-wide evaluation of air toxic emissions. This permit revision for Marshall Steam
station will include such compliance schedule.
8. Facility Emissions Review
The following is an emission summary for the facility wide emissions. Actual emissions are 2009 actual emissions
as included in the I-BEAM. The estimate for potential emissions is not available.
Pollutant
Actual Emissions
tons/yr
PM
PM-10
PM-2.5
SO2
NOx
CO
VOC
Single HAP (HCl)
Aggregate HAP
1,386
1,324
1,230
4,571
9,744
3,176
145
166
198
9. Stipulation Review
The following describes the changes to be performed to the current permit 03676T46:
Old Page No.
(03676T46)
New Page No.
(03676T47)
Condition No.
4
4
Section 1 Table
7
7
Section 2.1A.
9
9
Section 2.1 A. Table
-
20
Section 2.1 A.14. and
15.
-
35
Section 2.1 J.
-
39
Section 2.2.B.2.
Changes
Include control devices for Unit 4 boiler: systems for
spray-applying calcium dibromide (ID No. CDU4CaBr2(Temp)) and powdered activated carbon (ID
No. CD-U4ActC(Temp)). Also, include new generator
(ID No. ES-37(EmGenLF)).
Revise the source descriptor for Unit 4 boiler to include
the following control devices: systems for spray-applying
calcium dibromide (ID No. CD-U4CaBr2(Temp)) and
powdered activated carbon (ID No. CD-U4ActC(Temp)).
Revise the Table to include the applicability for 2Q .0317
for both PSD avoidance for PM/PM10 and NA NSR
Avoidance for PM2.5.
Include these new requirements under 2Q .0317 for both
PSD avoidance for PM/PM10 and NA NSR Avoidance
for PM2.5.
Include all applicable requirements for this new generator
(ID No. ES-37(EmGenLF)).
Include the new requirement for facility-wide air toxic
demonstration under 2Q .0709.
10. Conclusions, Comments, and Recommendations

PE seal is not required for the proposed sorbent injection systems because these are trial studies. If the permit is
issued for the permanent systems, PE seal will be required.
8

Local zoning consistency is not required for the proposed sorbent injection systems, because they are to be
located at a facility, which is not a “new facility” nor the facility can be deemed “an expansion of an existing
facility”.

The draft permit was sent to MRO for review and comments on September 3, 2010. The regional office did not
review the draft permit.

The draft permit was sent to the Permittee for review on September 3, 2010. The company commented on
September 8th the monitoring requirements under both PSD and NA NSR avoidance, and the compliance
schedule with respect to air toxics. The specific company comments and the DAQ response are as follows:
Company Comment 1:
“The wording for the PSD avoidance condition differs in the draft permit from what is discussed in the permit
review document. The permit review says PM emissions "attributable to" bromide and carbon addition shall be
less than 15 tons (for PSD) and 10 tons (for non-attainment NSR). The draft permit says PM emissions "when"
adding bromide and carbon shall be less than 10 and 15 tons. The difference in this wording is that "when"
implies that the total includes existing ash emissions as well as any new bromide or carbon emissions.
"Attributed to" makes it clear that we will only count the new emissions.”
DAQ Response:
Agreed. This change will be performed.
Company Comment 2:
“The calculations above are incomplete. The calculation above yields a lb/hr emission rate not a tons/yr
estimate. Hours of operation when injecting the product must be factored into the calculation. We do not
understand where the 0.00095 lb/mmBtu factor is derived for activated carbon, based on the calculations we
submitted. Again, the study is a short-term, 2 week study where PSD thresholds cannot be exceeded. We are
not seeking permit conditions for a permanent arrangement as the scope could change based on the study
findings. As such monthly records requirements and semi-annual reporting seems very odd. Why not simply
state that we must keep records and submit a single report at the end of the study to document the PSD
thresholds were not exceeded.”
DAQ Response:
The equations to calculate PM10 or PM2.5 emissions will be removed. Nevertheless, the 0.00095 lb/million
Btu emission rate due to injection of PAC is derived as follows:
7.5 lbs/hr controlled emission rate x 0.9 (90 % of PM is PM10 and PM2.5 is 100% of PM10) / 7,110 million
Btu/hr
As discussed in the permit application, the use of 62,000 lbs of CaBr2 and 150,000 lbs of PAC during the
mercury control evaluation studies can result in approximately 0.77 tons of PM10 emissions, less than the
significant threshold of 15 tons/yr. Because, the emissions of PM10 during the evaluation studies are not
expected to reach this threshold level, DAQ will require monitoring for the use of both CaBr 2 and PAC, and it
will not require monitoring for emissions of PM10. Finally, the Permittee will be required to keep records for
the amounts of the usage of these sorbents and will also be required to report the same within 30 days of the
completion of the studies.
Company Comment 3:
“We do not understand the inclusion of this condition as written. The NC Air Toxics provision says that we must
submit a protocol to do air toxics modeling for all combustion sources within 15 days of DAQ issuing the
permit. That makes little sense since we just completed a full air toxics modeling demonstration for the facility
9
in January 2009, including emissions from existing diesel engines for any pollutant that exceeded the TPER.
There were no issues identified relative to the air toxics associated with diesel engines. No additional pollutants
are emitted that will exceed TPER as a result of this 1 new small new engine. Other than arsenic and chromium
(which are not associated with diesel engines), all pollutants modeled were found to be at less than 2% of the
AALs. The new diesel engine will emit insignificant additional quantities of these modeled pollutants.
“We respectfully request this issue get additional review by the DAQ Permits Section Management. Couldn’t
DAQ help expedite the toxics review by allowing us to use the previous 2009 model as a sufficient to
demonstration of compliance, for the addition of one small diesel engine given we have submitted a recent
model showing the facility is nowhere near the AALs. The small diesel emergency engine would not be a
significant contribution to facility-wide air toxics to call the recent modeling demonstration into question. Does
the Permits Section not have authority/discretion to require an updated toxics modeling analysis periodically
when there have been noteworthy changes at a facility. If DAQ disagrees, at a minimum we request more time
than 15 days following permit issuance to submit a modeling protocol. This is clearly not enough time and
would require preparation of a protocol well before the permit is final. Thirty days should be quick enough.
Likewise, 90 days is more reasonable for submittal of the toxics modeling analysis.”
DAQ Response:
DAQ will include 15 days from the date the revised permit is issued to require submitting the modeling protocol
and 120 days for submittal of air toxic evaluation from the date the protocol is approved.

This engineer recommends issuing the revised permit.
10
Attachment C
Region: Mooresville Regional Office
County: Catawba
NC Facility ID: 1800073
Inspector’s Name: Tonisha Dawson
Date of Last Inspection: 07/31/2013
Compliance Code: 3 / Compliance - inspection
Permit Applicability (this application only)
NORTH CAROLINA DIVISION OF
AIR QUALITY
Air Permit Review
Permit Issue Date: 03/05/2014
Facility Data
Applicant (Facility’s Name): Duke Energy Carolinas, LLC - Marshall Steam
Station
SIP:
NSPS:
NESHAP:
PSD:
PSD Avoidance:
NC Toxics:
112(r):
Other:
Facility Address:
Duke Energy Carolinas, LLC - Marshall Steam Station
8320 East Highway 150
Terrell, NC
28682
SIC: 4911 / Electric Services
NAICS: 221112 / Fossil Fuel Electric Power Generation
Facility Classification: Before: Title V After: Title V
Fee Classification: Before: Title V After: Title V
Contact Data
Facility Contact
Authorized Contact
George Tolbert
EHS Professional
(336) 623-0415
900 South Edgewood
Road
Eden, NC 27288
Brian Weisker
General Manager
(828) 478-7600
8320 East Highway 150
Terrell, NC 28682
Application Data
Technical Contact
William Horton
Senior Environmental
Specialist
(980) 373-3226
526 South Church Street
(EC13K)
Charlotte, NC 28202
Application Number: 1800073.13A
Date Received: 04/19/2013
Application Type: Modification
Application Schedule: TV-Minor
Existing Permit Data
Existing Permit Number: 03676/T49
Existing Permit Issue Date: 01/15/2013
Existing Permit Expiration Date: 08/31/2015
Total Actual emissions in TONS/YEAR:
CY
SO2
NOX
VOC
CO
PM10
Total HAP
Largest HAP
2012
4599.15
11027.63
105.42
2305.47
1070.66
141.29
116.7382
[Hydrogen chloride (hydrochlori]
2011
3852.98
9086.27
132.55
2898.98
1809.95
179.07
147.1396
[Hydrogen chloride (hydrochlori]
2010
3657.90
9608.90
145.52
3177.09
1295.51
192.06
160.6485
[Hydrogen chloride (hydrochlori]
2009
4570.86
9744.37
145.22
3175.69
1324.23
198.42
165.9019
[Hydrogen chloride (hydrochlori]
2008
6174.76
13234.28
149.90
3237.13
7151.50
190.50
154.0190
[Hydrogen chloride (hydrochlori]
Review Engineer: Ed Martin
Review Engineer’s Signature:
Comments / Recommendations:
Issue 03676/T50
Permit Issue Date: 03/05/2014
Permit Expiration Date: 08/31/2015
Date: 03/05/2014
1
I.
Purpose of Application:
Duke Energy is requesting a permit modification to allow permanent use of various alkaline-based fuel additives
(e.g. Coal Treat 300, 500 and 600) at a maximum rate of 7 pounds per ton of coal on an as-needed basis to reduce
the formation of sulfur trioxide in the boiler which in turn reduces condensable particulate emissions in the form
of sulfuric acid mist and also to reduce boiler slagging. Duke is testing these additives when burning various
blends of Central and Northern Appalachian and Illinois Basis coals in preparation to meet the Utility MATS rule.
They originally requested written approval to conduct temporary coal testing using the additives in a letter dated
October 5, 2011, and were given approval to use the additives at Allen, Belews Creek, Cliffside and Marshall
through the end of 2012 in DAQ’s letter dated November 8, 2011; and approval extending the test period through
the end of 2013 was given in DAQ’s letter dated August 22, 2013. Duke submitted this application
(1800073.13A) in April 2013for long-term use of the additives; however, processing the application was delayed
due to workload and the permit could not be issued before the end of the extended test period (December 31,
2013) as Duke expected. Therefore, Duke requested another extension of the test period to allow further testing
until the application could be processed to revise the permit permanently, and DAQ approved extending the
testing through the end of 2014 in a letter dated December 18, 2013. This approval also included the use of trona,
which had been approved through December 31, 2013 in an email dated August 26, 2013 (Ed Martin to Bill
Horton, cc J. Evans and D. van der Vaart).
The additives are drip- or spray-applied to the coal on the conveyor belts. No equipment or control devices
require permitting.
These additives have been approved for use on other facilities as follows:

Duke’s Roxboro Plant was initially given email approval in June 2009 to conduct a trial injection
of Mg(OH)2 (magnesium hydroxide or milk of magnesia) as a fuel additive and was permitted to
use Mg(OH)2 in September 2010. Later in February 2011, approval was given by letter to use
more generic alkaline-based fuel additive products (CoalTreat 300, 500, 600) deemed equivalent
to Mg(OH)2, and the use of the more generic additive was recently added to the Roxboro permit
(Permit No. 01001T48, issued February 7, 2014).

Duke’s Mayo Plant was permitted in December 2010 to use some of the same additives as Duke is
now requesting to use.

Edgecombe Genco’s Plant was given approval in March 2010 to conduct a trial using magnesium
hydroxide slag modifier (Coal Treat 300).
This is a minor permit modification pursuant to rule 15A NCAC 2Q .0515. The permit shield described in
General Condition R does not apply to these changes. Public notice of the draft permit is not required. No
new regulations apply for this change.
II.
Permit Changes:
The following changes were made to the Duke Energy Carolinas LLC- Marshall Air Permit No. 03676T49:
Page No.
Cover
3-6
Section
7
-Section 1, table of
emission sources
Section 2.1.A
50-58
Section 3
Change
Amended permit numbers and dates.
Added the use of alkaline-based fuel additive for Units 1-4 (with
footnote ***).
Added the use of alkaline-based fuel additive to equipment
description for Units 1-4.
Updated General Provisions with the most recent revision (version
3.6).
2
III.
Facility Description
Duke Power’s Marshall Steam Station is an electric utility that generates electrical power. The Marshall
Steam Station is permitted for four coal/No. 2 fuel oil-fired electric utility boilers (ID Nos. ES-1, ES-2, ES3, ES-4) and various supporting equipment.
IV.
Summary of Changes to Emission Sources and Control Devices
The equipment description changes for the above modifications are as follows (changes in bold):
Page
No.
Emission
Source
ID No.
Emission Source Description
7, 43,
48
CD-1c
(U1SNCR)
ES-1
CAM
One No. 2 fuel oil/coal-fired electric
utility boiler (4,230 million Btu per
hour heat input) equipped with a low
NOx concentric firing system,
separated overfire air/lowered fired
low-NOx technologies
(SOFA/LOFIR), and alkaline-based
fuel additive***
Unit 1
7, 44,
48
One No. 2 fuel oil/off-specification
oil/coal-fired electric utility boiler
(4,230 million Btu per hour heat input)
equipped with a low NOx concentric
firing system, separated overfire
air/lowered fired low-NOx
technologies (SOFA/LOFIR), and
alkaline-based fuel additive***
Unit 2
ES-3
CAM
One No. 2 fuel oil/off-specification
oil/coal-fired electric utility boiler
3
Control Device Description
Selective non-catalytic reduction
(SNCR) NOx reduction system*
CD-2
One flue gas conditioning system
consisting of an integral sulfur trioxide
ash conditioner*
CD-2a
Anhydrous ammonia injection ash
conditioning system (20 ppm maximum
injection rate)*
CD-3
One cold-side electrostatic precipitator
(267,720 square feet of plate area)
CD-U1/2
FGD
Wet flue gas desulfurization system
consisting of spray tower absorber
(approximately 165 gal/min limestone
slurry injection rate)
CD-4c
(U2SNCR)
ES-2
CAM
7, 45,
48
Control
Device
ID No.
Selective non-catalytic reduction
(SNCR) NOx reduction system*
CD-5
One flue gas conditioning system
consisting of an integral sulfur trioxide
ash conditioner*
CD-5a
Anhydrous ammonia injection ash
conditioning system (20 ppm maximum
injection rate)*
CD-6
One cold-side electrostatic precipitator
(267,720 square feet of plate area)
CD-U1/2
FGD
Wet flue gas desulfurization system
consisting of spray tower absorber
(approximately 165 gal/min limestone
slurry injection rate)
CD-7c (SCR)
Selective catalytic reduction (SCR) NOx
reduction system*
Emission
Source
ID No.
Page
No.
Emission Source Description
(7,110 million Btu per hour heat input)
equipped with a low NOx concentric
firing system, separated overfire
air/lowered fired low-NOx
technologies (SOFA/LOFIR), and
alkaline-based fuel additive***
Control
Device
ID No.
CD-8
One flue gas conditioning system
consisting of an integral sulfur trioxide
ash conditioner*
CD-8b
(FGC)
Anhydrous ammonia injection ash
conditioning system (20 ppm maximum
injection rate)*
CD-9
(ESPnew)
One cold-side electrostatic precipitator
(768,108 square feet of plate area)
CD-U3
FGD
Wet flue gas desulfurization system
consisting of spray tower absorber
(approximately 165 gal/min limestone
slurry injection rate)
System for spray-applying calcium
bromide on coal**
Unit 3
7, 46,
48
CDU4CaBr2
(Temp)
CD-11c
(U4SNCR)
ES-4
CAM
One No. 2 fuel oil/coal-fired electric
utility boiler (7,110 million Btu per
hour heat input) equipped with a low
NOx concentric firing system,
separated overfire air/lowered fired
low-NOx technologies
(SOFA/LOFIR), and alkaline-based
fuel additive***
Control Device Description
CD-12
Selective non-catalytic reduction
(SNCR) NOx reduction system*
One flue gas conditioning system
consisting of an integral sulfur trioxide
ash conditioner*
CD-12B
(NH3FGC)
Anhydrous ammonia injection ash
conditioning system (20 ppm maximum
injection rate)*
CD-U4ActC
(Temp)
System for injecting powdered activated
carbon**
CD-13
(ESPnew)
One cold-side electrostatic precipitator
(768,108 feet of plate area)
CD-U4
FGD
Wet flue gas desulfurization system
consisting of spray tower absorber
(approximately 165 gal/min limestone
slurry injection rate)
Unit 4
*** Alkaline-based fuel additive may be used on an as-needed basis not to exceed 7 pounds per ton of coal burned. Fuel
additives shall not contain any toxic air pollutants listed in 15A NCAC 2Q .0711. Fuel additive products not equivalent
to those specified in Application 1800073.13A are not allowed without permit modification. The use of alkaline-based
fuel additive is listed as a minor modification per 15A NCAC 2Q .0515. The compliance certification as described in
General Condition P is required. Unless otherwise notified by NC DAQ, the affected terms of this permit (excluding
the permit shield as described General Condition R) for this source shall become final on May 4, 2014. Until this date,
the affected permit terms herein reflect the proposed operating language that the Permittee shall operate this source
under pursuant to 15A NCAC 2Q .0515(f).
V.
Emission and Regulatory Evaluation
Duke has stated in the original October 5, 2011 request to use the additives and in an email from Bill
Horton dated February 10, 2014, that the use of the additives does not result in a physical change or change
4
in the method of operation since the boilers had the ability to accommodate coal with sorbents/anti-slag
additives before January 6, 1975. DAQ concludes that, based on Duke’s statement, neither PSD nor NSPS
regulations apply as discussed below:
PSD Applicability
Under PSD regulation §51.166(b)(2)(i), a major modification means “ any physical change in or change in
the method of operation of a major stationary source that would result in significant emissions increase.”
Provision §51.166(b)(2)(iii)(e)(1) allows an exemption such that a physical change or change in the method
of operation shall not include the use of an alternative fuel or raw material by a stationary source which the
source was capable of accommodating before January 6, 1975. Therefore, this exemption applies and the
use of the additives is not a major modification under PSD.
Even though Duke states the change is not a physical change or change in the method of operation, they
have provided conservative calculations that show emissions of filterable PM increase somewhat due to the
addition of the additive, but emissions of condensable PM (H 2SO4) decrease to more than offset the
filterable PM increase, resulting in an overall reduction of total PM.
NSPS Applicability
Under NSPS regulation §60.14(a), “… any physical or operational change to an existing facility which
results in an increase in the emission rate to the atmosphere of any pollutant to which a standard applies
shall be considered a modification.” However, under §60.14(e)(4), if the facility was designed to
accommodate an alternate fuel or raw material under the facility’s construction specifications prior to the
date of any applicable NSPS standard, it shall not considered to be a modification under NSPS. Therefore,
this exemption applies and the use of the additives is not considered a modification under NSPS.
VI.
Other Requirements
PE Seal
A PE seal is not required since the application does not involve control systems in accordance with 2Q
.0112.
Zoning
A zoning consistency is not required since there is no expansion of the facility.
Fee Classification
The facility fee classification before and after this modification will remain as “Title V”.
VII.
Recommendations
Issuance is recommended. The draft permit was sent to Bill Horton at Duke on February 17, 2014 for
review. Duke had one comment to include the use of the additives in the Section 2.1.A equipment
description in addition to having it in the Section 1 table. This was done. The permit was also sent to
Tonisha Dawson at MRO for comment on February 19, 2014. No comments were received from MRO.
5
Attachment D
ATTACHMENT D
2D .1100 TAP Emissions Review
engine
emission
factors
engine horsepower
small <600
engine
emission
factors
NG
emission
factors
large >600
hr/yr
Ammonia
Hydrazine
Hydrochloric Acid
Hydrofluoric Acid
Sulfuric Acid
Arsenic Unlisted Compounds (ASC-Other)
Beryllium Metal (Unreacted)
Cadmium Metal (Unreacted)
Chromium VI
Manganese Unl. Compounds (MNC-Other)
Mercury Vapor
Nickel Metal
Acetaldehyde
Acrolein
Benzene
Benzyl chloride
Di[Bis](2-Ethylhexyl)phthalate
Carbon disulfide
Chlorobenzene
Chloroform
Cresol (p-)
Ethylene Dibromide (Dibromoethane (1,2-)
Dichlorobenzene (1,3-)
Dichlorobenzene (1,4-)
Hexane (n-)
Xylene (m/p)
Methyl chloroform
Methylene chloride
Methyl isobutyl ketone
Phenol
Styrene
Toluene
Trichlorofluoromethane
Vinyl chloride
Xylene (o-)
Dioxin and Dioxin-like Compounds
Benzo(a)pyrene
Methyl ethyl ketone
formaldehyde
(lb/HP-hr)
(lb/HP-hr)
NA
NA
NA
NA
NA
0.000000028
0.000000021
0.000000021
0.000000021
0.000000042
0.000000021
0.000000021
5.37E-06
6.48E-07
6.53E-06
NA
NA
NA
NA
NA
0.000000028
0.000000021
0.000000021
0.000000021
0.000000042
0.000000021
0.000000021
1.76E-07
5.52E-08
5.43E-06
2.86E-06
1.97E-06
2.00E-06
1.35E-06
1.32E-09
8.26E-06
5.52E-07
lb/mmBtu
8.36E-03
Coal
Unit 1
Combustion
Emission Factor
Unit 2
Unit 3
Unit 4
Emergency Emergency Emergency
Water Pump Generator
Air
(ES-26)
(ES-35)
Compressor
(ES-36)
Coal Storage Ash Storage
and Handling and Handling
both models
both models
both models
both models
2008 model 2008 model 2008 model
2008 model
mmBtu/hr
mmBtu/hr
mmBtu/hr
mmBtu/hr
0.1327
4230
4230
7110
7110
500
8760
8760
8760
8760
lb/yr
Test Data
Test Data
Test Data
Test Data
EPRI
Test Data
Test Data
Test Data
Test Data / EPA
Test Data
Test Data
Test Data
5.55E-01 EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
EPRI
na
lb/yr
lb/yr
lb/yr
lb/yr
137.8
0.0
3082.96
296.25
33,104.6
36.59
1.16
5.51
2.29
40.19
24.45
105.13
110.9
65.9
135.2
9.7
124.8
38.1
5.5
27.7
38.1
90.1
34.7
38.1
17.0
28.4
21.1
124.8
79.7
114.4
24.3
58.9
30.2
25.31
15.3
0.254
0.1
107.5
137.8
0.0
3082.96
296.25
33,104.6
36.59
1.16
5.51
2.29
40.19
24.45
105.13
110.9
65.9
135.2
9.7
124.8
38.1
5.5
27.7
38.1
90.1
34.7
38.1
17.0
28.4
21.1
124.8
79.7
114.4
24.3
58.9
30.2
25.31
15.3
0.254
0.1
107.5
231.1
0.0
5182.00
497.96
85,622.2
61.51
1.94
9.26
3.85
67.56
41.10
176.71
186.5
110.7
227.3
16.3
209.8
64.1
9.3
46.6
64.1
151.5
58.3
64.1
28.6
47.8
35.5
209.8
134.0
192.3
40.8
99.1
50.7
42.54
25.6
0.427
0.1
180.6
231.1
0.0
5182.00
497.96
85,622.2
61.51
1.94
9.26
3.85
67.56
41.10
176.71
186.5
110.7
227.3
16.3
209.8
64.1
9.3
46.6
64.1
151.5
58.3
64.1
28.6
47.8
35.5
209.8
134.0
192.3
40.8
99.1
50.7
42.54
25.6
0.427
0.1
180.6
0.02
0.01
0.54
0.05
0.02
1.55
0.28
0.03
0.34
2008 model
New Em.
Emergency Emergency Emergency
Diesel Gen. Water Pump Generator
Air
(ES-37)
(ES-26)
(ES-35)
Compressor
(ES-36)
steam jenny
(I-74)
2010 model
2010 model
2010 model
2010 model
2010 model
4.04E-01
2.44E-02
4.91E-01
8.82E-02
2.76E-02
2.72E+00
2.51E-01
7.85E-02
7.74E+00
1.41E+00
8.50E-02
1.71E+00
0.00E+00
0.00E+00
5.62E-03
1.501E-01
6.755E-01
1.924E+00
5.237E-01
2.865E-03
6.76E-01
1.92E+00
5.24E-01
2.86E-03
na
lb/yr
lb/yr
0.08
0.02
0.00
0.02
0.26
0.00
0.15
2.66
0.74
0.06
0.83
8.86
0.03
5.06
0.20
0.56
0.15
7.20E-03
0.14
0.38
0.10
1.50E-01
6.76E-01
1.92E+00
5.24E-01
2.86E-03
0.00
0.00
0.00
4.95E-05
0.00E+00
0.00E+00
1.73E-04
0.00E+00
0.00
0.00
0.00
6.21E-01
2.76E-01
7.86E-01
2.17E+00
8.67E-01
ATTACHMENT D
2D .1100 TAP Emissions Review
column C
LP Portable
Generator (I106)
2010 model
Gasoline
Gasoline
Tank &
Tank &
Dispensing (I- Dispensing (I12)
13)
2010 model
Facility Total Facility Total largest (either
(2008 analysis) (2010 analysis) 2008 or 2010)
2010 model
9.72E+00
9.04E+00
2.26E+00
0.00E+00
0.00E+00
4.89E+00
0.00E+00
0.00E+00
2.59E+00
3.115E-01
1.484E+00
7.871E-01
3.12E-01
1.48E+00
7.87E-01
3.12E-01
1.48E+00
7.87E-01
6.60E-06
0.00E+00
0.00E+00
6.42E+01
0.00E+00
0.00E+00
737.80
0.00
16529.92
1588.42
237453.60
198.94
6.96
29.60
13.13
224.62
131.13
568.89
595.15
353.26
727.43
52.00
669.20
204.40
29.60
148.60
204.40
483.20
186.00
204.40
91.20
152.40
113.20
669.20
427.40
613.40
130.20
316.91
161.80
135.70
82.42
1.36
0.40
576.20
0.00
737.80
0.00
16529.92
1588.42
237453.60
196.20
6.20
29.54
12.28
215.50
131.10
563.68
606.67
362.46
747.40
52.00
669.20
204.40
29.60
148.60
204.40
483.20
186.00
204.40
91.20
158.26
113.20
669.20
427.40
613.40
130.20
321.72
161.80
135.70
87.66
1.36
0.40
576.20
68.89
737.80
0.00
16529.92
1588.42
237453.60
198.94
6.96
29.60
13.13
224.62
131.13
568.89
606.67
362.46
747.40
52.00
669.20
204.40
29.60
148.60
204.40
483.20
186.00
204.40
91.20
158.26
113.20
669.20
427.40
613.40
130.20
321.72
161.80
135.70
87.66
1.36
0.40
576.20
68.89
Column A
difference
%difference
2008-2010
2008-2010
0.00
0.00
0.00
0.00
0.00
2.74
0.76
0.06
0.85
9.12
0.03
5.21
11.52
9.20
19.97
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
5.86
0.00
0.00
0.00
0.00
0.00
4.81
0.00
0.00
5.24
0.00
0.00
0.00
68.89
0.00
#DIV/0!
0.00
0.00
0.00
1.38
10.92
0.20
6.47
4.06
0.02
0.92
1.94
2.60
2.75
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
3.84
0.00
0.00
0.00
0.00
0.00
1.52
0.00
0.00
6.36
0.00
0.06
0.00
#DIV/0!
New Em. Diesel
Gen. (ES-37)
Emergency
Water Pump
(ES-26)
Emergency
Generator
(ES-35)
Emergency
Air
Compressor
(ES-36)
steam jenny
(I-74)
calculated
calculated
calculated
calculated
calculated
100kW= 134 HP
hp
hp
hp
LP Portable Generator (I106)
Facility Total
(CALCULATED)
under current permit
scenario and policy
Column B
difference
(current - max
of 2008 or
2010)
% difference =
(current 2008)/2008
calculated
0.1327 mmBtu/hr=52 hp
small
large
large
small
small
134
1000
2848
525
10
small
52
500
500
500
500
500
500
lb/yr
lb/yr
lb/yr
lb/yr
lb/yr
lb/yr
lb/yr
diff
% diff
lb/day
lb/hr
0
0
0
0
0
1.88E-03
1.41E-03
1.41E-03
1.41E-03
2.81E-03
1.41E-03
1.41E-03
3.60E-01
4.34E-02
4.38E-01
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1.92E-01
0
0
1.34E-01
0
8.82E-05
0
0.55342
0
0
0
0
0
1.40E-02
1.05E-02
1.05E-02
1.05E-02
2.10E-02
1.05E-02
1.05E-02
8.80E-02
2.76E-02
2.72E+00
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
9.85E-01
0
0
6.75E-01
0
0
0
0.276
0
0
0
0
0
3.99E-02
2.99E-02
2.99E-02
2.99E-02
5.98E-02
2.99E-02
2.99E-02
2.51E-01
7.86E-02
7.73E+00
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2.81E+00
0
0
1.92E+00
0
0
0
0.786048
0
0
0
0
0
7.35E-03
5.51E-03
5.51E-03
5.51E-03
1.10E-02
5.51E-03
5.51E-03
1.41E+00
1.70E-01
1.71E+00
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
7.52E-01
0
0
5.24E-01
0
3.45E-04
0
2.16825
0
0
0
0
0
1.40E-04
1.05E-04
1.05E-04
1.05E-04
2.10E-04
1.05E-04
1.05E-04
2.68E-02
3.24E-03
3.27E-02
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1.43E-02
0
0
9.98E-03
0
6.58E-06
0
0.0413
0
0
0
0
0
7.28E-04
5.46E-04
5.46E-04
5.46E-04
1.09E-03
5.46E-04
5.46E-04
1.40E-01
1.68E-02
1.70E-01
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
7.44E-02
0
0
5.19E-02
0
3.42E-05
0
0.21476
737.80
0.00
16529.92
1588.42
237453.60
199.00
7.01
29.65
13.18
224.72
131.18
568.94
597.07
353.54
745.28
52.00
669.20
204.40
29.60
148.60
204.40
483.20
186.00
204.40
91.20
154.67
113.20
669.20
427.40
613.40
130.20
323.09
161.80
135.70
87.39
1.36
0.40
576.20
4.04
0.00
0.00
0.00
0.00
0.00
0.06
0.05
0.05
0.05
0.10
0.05
0.05
9.60
8.92
2.12
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
3.59
0.00
0.00
0.00
0.00
0.00
1.38
0.00
0.00
0.27
0.00
0.00
0.00
64.85
0.000
#DIV/0!
0.000
0.000
0.000
0.032
0.685
0.162
0.364
0.043
0.037
0.008
-1.607
-2.523
-0.284
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
-2.319
0.000
0.000
0.000
0.000
0.000
0.426
0.000
0.000
-0.310
0.000
0.061
0.000
-1605.216
2.021
0.000
45.287
4.352
650.558
0.545
0.019
0.081
0.036
0.616
0.359
1.559
1.636
0.969
2.042
0.142
1.833
0.560
0.081
0.407
0.560
1.324
0.510
0.560
0.250
0.424
0.310
1.833
1.171
1.681
0.357
0.885
0.443
0.372
0.239
0.004
0.001
1.579
0.011
0.084
0.000
1.887
0.181
27.107
0.023
0.001
0.003
0.002
0.026
0.015
0.065
0.068
0.040
0.085
0.006
0.076
0.023
0.003
0.017
0.023
0.055
0.021
0.023
0.010
0.018
0.013
0.076
0.049
0.070
0.015
0.037
0.018
0.015
0.010
0.000
0.000
0.066
0.000