AQ_F_0400050_20180517_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY NCEMC-Anson Plant
NC Facility ID 0400050
Inspection Report County/FIPS: Anson/007
Date: 05/23/2018
Facility Data Permit Data
NCEMC-Anson Plant Permit 09492/T08
749 Blewett Falls Road Issued 12/21/2015
Lilesville,NC 28091 Expires 11/30/2020
Lat: 34d 58.0837m Long: 79d 55.3361m Classification Title V
SIC: 4911 /Electric Services Permit Status Active
NAICS: 221112/Fossil Fuel Electric Power Generation Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Shawn Fowler John Cook Khalil Porter NSPS: Subpart KKKK
Manager,Combustion Vice President,Asset Environmental Scientist
Turbine Generation Management [phone]
[phone] [phone]
Compliance Data
Comments:
Inspection Date 05/17/2018
Inspector's Name Jeffrey D. Cole
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: S/� /�� On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2016 6.65 --- 112.22 15.56 136.21 6.65 1843.31
2015 4.83 --- 82.12 10.03 82.71 4.83 1163.67
2014 3.45 --- 59.73 7.38 52.07 3.45 830.17
*Highest HAP Emitted inpounds)
Five Year Violation History:None
Date Letter Tyne Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

I. DIRECTIONS:
From FRO take 401 S. to Wagram. Turn right on Old Wire Road (NC 144) just south of
Wagram. Stay on NC 144,(this road will cross over 15/501) until you reach HWY 74. Turn right
on HWY 74. Just after crossing the Pee Dee River, turn right onto Power Plant Road. Travel
approx a mile and turn left onto Blewett Falls Road. The facility will be on the right.
H. SAFETY CONSIDERATIONS:
Required safety equipment includes, safety shoes,eye protection and hardhat. Open no doors and
touch no plumbing while the turbine is in operation.
III. FACILITY/PROCESS DESCRIPTION:
This facility has simple-cycle, natural gas-fired (low sulfur No. 2 fuel oil backup) combustion
turbines generating electricity in Anson County. The facility can produce 340 MW of electrical
power to retail distribution during periods of high demand or during emergencies. This facility
uses six Pratt and Whitney FT-8 Swift-Pac simple cycle gas turbine generator sets. Each of the
six units consists of two turbines, each equipped with water injection, and one generator. The
two turbines associated with each FT-8 do not have to operate simultaneously. The double-ended
configuration allows for greater efficiency during partial load usage. This plant operates as a
"peaking" facility to meet peak power demands on a daily or seasonal basis. Pollution control is
demineralized water injection to control NOx. "Simple cycle gas turbine" means any stationary
gas turbine that does not recover heat from the gas turbine exhaust to either preheat the inlet
combustion air or to heat water or generate steam.
The Plant Information (PI) System was installed at this facility for plant-wide monitoring and
analysis. The system handles the collection, storage, and retrieval of parametric data. It also acts
as a data server for Microsoft Windows-based client applications that operators, engineers,
managers, and other plant personnel use to view the plant data stored in the PI Data Archive.
The facility chooses to use a predictive emission monitor systems (PEMs) to monitor NOx
emissions in lieu of CEMs. The predictive emission monitor systems have been proven to be as
accurate as the CEMs and are in fact more economical from the cost and maintenance. The
facility uses this software program to monitor and determine NOx emissions from the gas
turbines in real time. Continuous NOx emission rate is determined based on vendor's data and
turbine operating parameters.
IV. INSPECTION SUMMARY:
On 5/17/2018,1, Jeffrey Cole and Danielle Rice of DAQ FRO,met with Mr. Shawn Fowler, plant
manager, and Mr.Khalil Porter, environmental scientist,at the Hamlet facility to conduct an air
quality compliance inspection, consisting of a records review. The Anson facility was not
operating at the time. Mr.Fowler showed us the facility's current permit and reviewed the
FacFinder,where he found that no changes were needed. Mr. Fowler and Mr. Porter provided all
records for review,as required by the permit. Note that all twelve turbines(six gen sets)are
under contract with Duke/Progress Energy and are all run as close to equal time as possible, in
order to maintain their"peaking" status for federal rule applicability.
After reviewing the records,we proceeded outside and inspected the interior of one of the twelve
turbines which is not usually possible for a state inspector, due to their frequent use. Mr. Fowler
explained the individual components and the operational aspects of the facility.

Upon returning to the facility office, I informed Mr.Fowler and Mr. Porter that I had found the
facility to be in compliance and thanked them for their help. I noted to Mr. Porter and Mr.Fowler
that our office had wished to conduct a source test observation while they were conducting their
5-year(i.e.,required every 20 calendar quarters)source testing to update their facility's NOx
PEMS curves,however,the testing that was previously scheduled to still be occurring had
finished the night before(5/16/2018). Mr. Porter apologized for not informing our office that the
source test contractors,over the scheduled 8-day testing,were conducting additional testing in the
evenings thus cutting the testing to six days. He stated that in the future he will maintain better
communication with FRO and inform us of any changes in the schedule.
V. PERMITTED EMISSION SOURCES:
. ..... ._. .
Emission Control Control Device
Source ID Emissions Source Description Device Description
No. ID No.
ES-lA One Pratt&Whitney FT8 Swift-Pac simple-cycle gas Water injection
turbine(300 million Btu per hour nominal heat input system(one
NNotS capacity when firing natural gas, and 281 million Btu per CD-lA system per
Operating hour nominal heat input capacity when firing No.2 fuel turbine)
oil)and one generator per set of turbines
ES-1B One Pratt&Whitney FT8 Swift-Pac simple-cycle gas i Water injection
turbine(300 million Btu per hour nominal heat input system(one
NNtS capacity when firing natural gas, and 281 million Btu per CD-113 system per
Operating hour nominal heat input capacity when firing No.2 fuel turbine)
oil)and one generator per set of turbines
ES-2A One Pratt&Whitney FT8 Swift-Pac simple-cycle gas Water injection
NSPS turbine(300 million Btu per hour nominal heat input CD-2A ! system(one
Not capacity when firing natural gas,and 281 million Btu per I system per
Operating hour nominal heat input capacity when firing No.2 fuel turbine)
oil)and one generator per set of turbines
ES-2B One Pratt&Whitney FT8 Swift-Pac simple-cycle gas Water injection
turbine(300 million Btu per hour nominal heat input system(one
NNtS CD-2B
capacity when firing natural gas, and 281 million Btu per system per
Operating hour nominal heat input capacity when firing No. 2 fuel turbine)
oil)and one generator per set of turbines
ES-3A One Pratt&Whitney FT8 Swift-Pac simple-cycle gas Water injection
turbine(300 million Btu per hour nominal heat input system(one
NYPS CD-3A
capacity when firing natural gas,and 281 million Btu per system per
ot
hour nominal heat input capacity when firing No.2 fuel turbine)
Oljer`rt'r'g oil)and one generator per set of turbines
ES-3B One Pratt&Whitney FT8 Swift-Pac simple-cycle gas Water injection
turbine(300 million Btu per hour nominal heat input I system(one
NNotS capacity when firing natural gas,and 281 million Btu per CD-3B system per
hour nominal heat input capacity when firing No.2 fuel ( turbine)
Operating oil)and one generator per set of turbines

ES-4A One Pratt&Whitney FT8 Swift-Pac simple-cycle gas Water injection
NSPS turbine(300 million Btu per hour nominal heat input CD-4A system(one
Not capacity when firing natural gas,and 281 million Btu per system per
hour nominal heat input capacity when firing No. 2 fuel i turbine) C
p g i !
O Gratin oil)and one generator per set of turbines
ES-4B One Pratt&Whitney FT8 Swift-Pac simple-cycle gas - Water injection
NSPS turbine(300 million Btu per hour nominal heat input CD 4B system(one
Not capacity when firing natural gas,and 281 million Btu per system per
Operating hour nominal heat input capacity when firing No. 2 fuel turbine)
oil)and one generator per set of turbines
^ES-SA One Pratt&Whitney FT8 Swift-Pac simple-cycle gas Water injection
turbine(300 million Btu per hour nominal heat input system(one
NNotS capacity when firing natural gas,and 281 million Btu per CD-SA system per
Operating hour nominal heat input capacity when firing No. 2 fuel turbine)
oil)and one generator per set of turbines
ES-SB One Pratt&Whitney FT8 Swift-Pac simple-cycle gas Water injection
turbine(300 million Btu per hour nominal heat input system(one
NSPNo
capacity when firing natural gas,and 281 million Btu per CD-SB system per
Operating hour nominal heat input capacity when firing No.2 fuel turbine)
oil)and one generator per set of turbines
ES-6A One Pratt&Whitney FT8 Swift-Pac simple-cycle gas Water injection
NSPS turbine(300 million Btu per hour nominal heat input CD-6A i system(one
Not capacity when firing natural gas,and 281 million Btu per system per
Operating hour nominal heat input capacity when firing No. 2 fuel turbine)
oil)and one generator per set of turbines ,
One Pratt&Whitne
ES-6B j y FT injection
Swift-Pac simple-cycle gas Water �ection
turbine(300 million Btu per hour nominal heat input system(one
NNa s CD-6B
capacity when firing natural gas, and 281 million Btu per system per
Operating hour nominal heat input capacity when firing No. 2 fuel j turbine)
oil)and one generator per set of turbines
Insignificant Activities per 15A NCAC 2Q.0503(8):
ID Nos. Emission Source Description
IES-11 One natural gas-fired heater for warming up pipeline natural gas used in combustion
Not Operating ' turbines
Operating One 500,000 gallon No. 2 fuel oil storage tank
IES-13
Operating
One 500,000 gallon No. 2 fuel oil storage tank

VI. PERMIT CONDITIONS&LIMITATIONS:
A. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS—Subject sources:twelve
turbines(ID Nos. ES-lA and B through ES-6A and B). VE is limited to 20% opacity for each
turbine when averaged over a six-minute period,except during startup, shutdown and
malfunctions.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.
APPEARED IN COMPLIANCE—The facility combusts primarily natural gas, and it combusts
No. 2 fuel oil only as a backup. Both of these fuels are clean burning, so the opacity should
always be in compliance with the 20% limit. The turbines were not observed in operation during
this inspection. Mr.Fowler stated that he has not seen any visible emissions from any of the units
while operating on either fuel.
B. 15A NCAC 2D .0524: NSPS,40 CFR PART 60,SUBPART KKKK—Subject sources:twelve
turbines (ID Nos. ES-lA and B through ES-6A and B).
a. The permittee shall comply with the notification,testing,recordkeeping, and monitoring
requirements for S02.The S02 emission limit can be met by demonstrating that the S02
content in</=0.05%for No. 2 fuel oil and</=20 grains per 100 scf of natural gas.The
permittee shall submit the following semi-annual reports: a summary/deviation report and an
excess emissions/monitor downtime(including startup,shutdown,and malfunction)report.
APPEARED IN COMPLAINCE—The facility initially demonstrated compliance with the
NSPS limits based on source tests that were reviewed and approved by the Raleigh Central
Office. Fuel oil sulfur content is determined by representative sampling after adding loads to
the storage tank, in accordance with 40 CFR Part 75 Appendix D Section 2.2.4.2.In addition,
quarterly sampling is conducted whether fuel oil has been received or not. The most recent
analysis shows 7.6 ppm S in Tank#1 and 7.2 ppm S in Tank#2.NG sulfur content,
according to the Transco website,was within a range of 0.03 to 0.50 grains/100 scf from Jan
2017 through Dec 2017. The most recent semi-annual and excess emissions/monitor
downtime reports were received on 1/30/18 and appear to be complete.
b. The permittee shall comply with the notification,testing,recordkeeping,and monitoring
requirements for NOx.The maximum NOx emission limits are 25 ppm at 15%02 when
firing NG and 74 ppm at 15% 02 when firing No. 2 fuel oil; The permittee can demonstrate
compliance using the NOx emission estimation following 40 CFR Part 75 Appendix E,
including re-certifying NOx emissions rate versus heat input rate correlation curve every 5
years. The permittee must demonstrate"peaking" status using the average capacity factor of
no more than 10%during three previous calendar years and no more than 20%during each of
those individual years. The permittee must keep records for the following: hourly records of
time, load to unit, fuel flow rate,heat input, and hourly calculated NOx emissions. The
permittee shall submit semi-annual excess emissions/monitor downtime reports for all
periods including startup, shutdown,and malfunction.
APPEARED IN COMPLIANCE—The facility was not operating during the inspection.
Records show that each turbine is maintaining its"peaking" status with a three-year average
capacity factor of 5.4-6.0%and a year to date capacity factor of 3.7-4.5%. The facility
chooses to use a Predictive Emissions Monitoring System(PEMS)that uses a water-to-fuel
ratio curve,which is established via testing at least every 5 years(last test was conducted in
2013,the new testing was just finished on 5/16/18),to predict hourly NOx emissions. The
fuel and water flow meters were last calibrated in September 2015 and are re-calibrated at

least every 5 years(depending on capacity used per turbine,quarterly)so the next calibration
is tentatively planned for September 2020. The PEMS activates an alarm if NOx emissions
exceed 25/74 ppm (gas/oil)for more than 60 seconds(once water flow is established)and if
at 720 seconds the emissions still exceed then the unit automatically shuts down in order to
avoid exceeding the NOx limit for the rolling 240-minute period. There have been no periods
of NOx emissions exceeding the established limits since the last inspection. The most recent
semi-annual summary/deviation report and excess emission/monitor downtime report were
received on 1/30/18 and appear to be complete.
C. 15A NCAC 2D.0530 PREVENTION OF SIGNIFICANT DETERIORATION—Subject sources:
twelve turbines(ID Nos. ES-lA and B through ES-6A and B). CO total emissions shall not exceed
405.5 tons per consecutive 12-month period. Each unit shall not exceed 1,230 hrs run time on natural
gas or 710 hrs run time on No. 2 fuel oil(</=0.002%S)annually,not including startup/shutdown
time.
APPEARED IN COMPLIANCE—The 12-month rolling total CO emissions(May 2017 to Apr
2018)was 128.00 tons. All units were below the hour run time limit for this same period,300 hrs on
NG and 81.1 hrs on No.2 fuel oil being the highest that any one unit ran.
D. 15A NCAC 2Q.0317 PSD AVOIDANCE—Subject sources:twelve turbines(ID Nos. ES-lA and B
through ES-6A and B). The NOx limit is 245 TPY. The permittee must record the number of
startup/shutdowns per day and monitor NOx emissions in accordance with 40 CFR Part 60 Subpart
KKKK(item B, above). The permittee must calculate NOx emissions from each turbine daily
(including start-up and shut-down and daily load), and calculate combined NOx emissions from all
turbines monthly and on a 12-month rolling basis. Semi-annual reporting of monthly and 12-
month rolling total NOx emissions.
APPEARED IN COMPLIANCE—Daily records of startup/shutdowns and calculated
daily/monthly/12-month rolling total NOx emissions per turbine appeared valid and complete. The
NOx emissions from May 2017 to Apr 2018 were 134.91 tons. The most recent semi-annual report
was received on 1/30/18 and appeared to be complete.
E. 15A NCAC 2Q.0400:PHASE H ACID RAIN REQUIREMENTS—Subject sources:twelve
turbines(ID Nos.ES-lA and B through ES-6A and B). There are no specified S02 Allowance
Allocations under this rule. The DAQ allocates tons of SOz allowances from a general fund for
new sources.
APPEARED IN COMPLIANCE—EPA's Air Markets Program Data website shows the facility
held an allowance of one ton of SOz at the beginning of 2017 and reported emissions of"0"tons of
S02 at the end of 2017. They carried over an allowance of 29 tons for 2017. While the full CY 2018
data is not yet available,the I'quarter allowance is also"0."
F. CROSS STATE AIR POLLUTION RULES(CSAPR)PERMIT REQUIREMENTS—The
permittee shall comply with all applicable requirements of 40 CFR 97 Subparts 5A, 513, and 5C.
a. 40 CFR 97 Subpart 5A—ANNUAL TRADING PROGRAM — NOx
APPEARED IN COMPLIANCE—The facility participates in the NOx Trading program.
According to EPA's Air Markets Program Data website,they held an allowance of 94 tons NOx
at the beginning of 2016 and reported emissions of 87 tons of NOx at the end of 2017. They
carried over an allowance of 7 tons NOx into 2018. The 2018 data is not yet available.

b. 40 CFR 97 Subpart 5B—OZONE SEASON TRADING PROGRAM — NOx
APPEARED IN COMPLIANCE— The facility no longer participates in NOx trading
during ozone season as the entire State is now listed as in attainment.
c. 40 CFR 97 Subpart 5C—GROUP 1 TRADING PROGRAM — SOz
APPEARED IN COMPLIANCE — The facility participates in the SOz Group 1 Trading
program. According to EPA's Air Markets Program Data website, "0" SOz allowances were
used in 2017, and the facility had"0" SOz allowances available for trading at the end of 2017.
The 2018 data is not yet available.
G. PERMIT GENERAL CONDITION LA and I.B REPORTING REQUIREMENTS FOR
EXCESS EMISSIONS AND PERMIT DEVIATIONS — The facility is required to report
excess emission events and malfunctions that last more than 4 hours per the requirements of 15A
NCAC 2D .0535.
APPEARED IN COMPLIANCE—Mr. Fowler indicated that the facility has had no excess
emission/malfunction events and therefore no notification has been required.
H. PERMIT GENERAL CONDITION P—COMPLIANCE CERTIFICATION
REQUIREMENT: The facility is required to submit an Annual Compliance Certification
(ACC)report postmarked before March 1 of each year, stating compliance with all permit
conditions or noting any deviations during the previous calendar year.
APPEARED IN COMPLIANCE—The most recent ACC report was received on 2/15/18 and
appeared to be complete and accurate.
I. PERMIT GENERAL CONDITION X—ANNUAL EMISSION INVENTORY
REQUIREMENTS—Facility shall submit an Annual Emission Inventory postmarked on or
before June 30"of each year.
APPEARED IN COMPLIANCE — The facility's 2016 AQEI was received on 03/23/2017 and
appeared to be complete and accurate. The facility's 2017 AQEI was received on 04/26/2018 and
has yet to be reviewed.
J. PERMIT GENERAL CONDITION MM—FUGITIVE DUST CONTROL
REQUIREMENT—The Permittee shall not cause of allow fugitive dust emissions to cause or
contribute to substantive complaints or excess visible emissions beyond the property boundary.
APPEARED IN COMPLIANCE—Mr. Fowler stated that no dust complaints had been received
by the facility, and FRO has not received any dust complaints. The facility is completely paved.
Therefore,there should not be any issues with fugitive dust from this site.
VII. NON-COMPLIANCE HISTORY SINCE 2010:
None
VIII. RISK MANAGEMENT (112r):
The facility does not store any of the listed chemicals in amounts that exceed the threshold quantities.
Therefore,they are not required to maintain a written Risk Management Plan(RMP).

IX. COMPLIANCE STATEMENT AND RECOMMENDATION:
Based on compliance inspection conducted on 5/17/2018 inspection, NCEMC - Anson Plant
appeared to be in compliance with the requirements outlined in their current air permit
PINK SHEET ITEMS:
No additional comments, items to address from previous inspection still remain.
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