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HomeMy WebLinkAboutAQ_F_0400032_20170714_CMPL_InspRpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Duke Energy Progress,LLC-Blew7ett NC Facility lD 0400032 Inspection Report County/FIPS:Anson/007 Date: 07/21/2017 Facility Data Permit Data Duke Energy Progress,LLC-Blewett Permit 06093/R08 2598 Power Plant Road Issued 1/4/2017 Lilesville,NC 28091 Expires 12/31/2024 Lat: 34d 58.9112m Long: 79d 52.6220m Classification Synthetic Minor 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 S11P Kimberly Kashmer Thomas Hanes William Horton MACT Part 63: Subpart ZZZZ Lead EHS Professional Station Manager Lead Environmental (910)205-2111 (910)205-2101 Specialist (980)373-3226 Compliance Data Comments: Inspection Date 07/14/2017 Inspector's Name Joshua L.Harris Inspector's Signature: ` � Operating Status Operating Compliance Code Compliance-inspection Action Code FCE Date of Signature: p��L,� ,_, On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: �( TSP S02 NOX VOC CO PM10 *HAP 2015 -- 9.90 25.30 --- --- --- 110.71 2011 --- 4.00 9.40 --- --- --- 12.50 *Highest HAP Emitted(inpounds) Five Year Violation History:None Date Letter Type Rule Violated Violation Resolution Date Performed Stack Tests since last FCE:None Date Test Results Test Metbod(s) Source(s)Tested I. DIRECTIONS TO SITE: In Laurinburg,take 74 West through Rockingham, and into Anson County. After crossing the Pee Dee River,turn right onto the first road,Power Plant Road. The plant is approximately 3 miles away, at the end of Power Plant Road. Press the button at the gate callbox in order to gain entry. The admin building is the first building on the left. U. SAFETY: Standard FRO safety gear. Double hearing protection is required when the combustion turbines are operating; ear muffs can be provided by the facility. III. FACILITY DESCRIPTION: Duke Energy Progress Blewett is an electricity generation plant which operates six 4 MW hydroelectric units,and four 18 MW,No. 2 fuel oil fired Combustion Turbines(CT). The CTs are only operated as fast-start(6 minutes)peaking units or during maintenance or repair of the hydroelectric units, or to cover gaps in service if other units in the region drop offline for any reason.This situation normally only occurs during the colder months. The turbines do not utilize water injection,nor is the air entering the combustion chamber pre-cooled, so turbine efficiency is greatly influenced by ambient air temperatures. Throughputs: 2016 68,410 2015 140,200 2014 202,023 2013 24,508 IV. INSPECTION Si-NM Y: On 14 July 2017, Mike Thomas, and I,Joshua Harris, both of FRO DAQ, conducted a compliance inspection of Duke Energy Progress—Blewett in Lilesville,Anson County. The facility can be remotely operated, so it is typically unmanned and inspections should be pre-planned. We met with Kim Kashmer, Lead EHS Professional, and Joe Rivers, Combustion Turbine Operator for an announced inspection of the facility;the plant was not operating at the time. Ms. Kashmer and Mr. Rivers verified the facility contact information and no changes were noted. Mr. Rivers provided the required records,which were very well organized. After reviewing the facility's records,Ms.Kashmer and Mr. Rivers showed us to the facility's bum pit which is used to disposed of vegetative materials that are collected in the screens at the hydroelectric plant; there did not appear to be any non-vegetative material present. We also observed the facility's insignificant emergency generator, which provides emergency power to the microwave tower in the event of a power outage. We then departed the facility. V. PERMITTED EMISSION SOURCES: Emission Emission Soar Control e: Description l �stc System II1 Dec. titan No. 2 fuel oil-fired combustion turbine 4IC2 (277 7 million Btu per hour maximum heat input) Not operating No. 2 fuel oil-fired combustion turbine million Btu per hour maximum heat input) Not operating N/A N/A No. 2 fuel oil-fired combustion turbine ES I0 (277 million Btu per hour maximum heat input) Not operating No. 2 fueI oil-fired combustion turbine ES IC4 (277 million Btu per hour maximum heat input) Not operating VI. APPLICABLE AIR QUALITY REGULATIONS: A. 15A NCAC 2D .0202—PERMIT RENEWAL AND EMISSION INVENTORY REQIREMENT —The Permittee shall submit an application for permit renewal, including an emission inventory for CY 2015, no later than 90-days prior to permit expiration. APPEARED IN COMPLLANCE. The facility's permit was recently renewed on 04 January 2017, and the application was received on time_ The renewal application will be due no later than 02 October 2024, and must include an emission inventory for CY2023. B. 15A NCAC 2D .0516—SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES— SOz emissions from the CTs shall not exceed 2.3 lb/mmBtu. APPEARED IN COMPLIANCE: The facility is permitted to combust No. 2 fuel oil up to 0.5 wt.% sulfur, which has an AP-42 emission factor of 0.51 lb S02/mmBtu. The facility only accepts ultra-low sulfur diesel(ULSD), as verified by fuel certifications. The facility also takes fuel samples annually, and the last sample indicated a su m content of 0.0087 wt. %. Mr. Rivers stated that the facility used to combust oil with a sulfur content of 0.5 wt.% and that the tank was drained then refilled with ULSD when the facility made the switch. The higher sulfur content in the sample may be due to the mixing of ULSD with any residual oil left in the tank when it was drained and refilled. In any event, combustion offuel oil with this sulfur content will not exceed the permit limit. C. 15A NCAC 2D .0521 —CONTROL OF VISIBLE EMISSIONS—VE<20% opacity. APPEARED IN COMPLIANCE: No emission sources were operating at the time of the inspection. Mr. Rivers stated that he has never seen visible emissions while the turbines operate. D. 15A NCAC 2D .0535—NOTIFICATION REQUIREMENT—Notify DAQ in the event of excess emissions lasting longer than 4 hours. APPEARED IN COMPLIANCE: There are no indications of excess emissions which would require a notification by the facility. Ms. Kashmer and Mr. Rivers are well aware of the requirement, and there have not been any complaints from local residents received by the facility or by DAQ. E. 15A NCAC 2D.0540—PARTICULATES FROM FUGITIVE DUST EMISSION SOURCES— Fugitive dust emissions shall not cause/contribute to substantive complaints or excessive VIE across property boundaries. APPEARED IN COMPLIANCE: No fugitive dust concerns were noted during the inspection.All roads are paved, and there have not been any complaints received by the facility or by DAQ. F. 15A NCAC 2D .2400—CLEAN AIR INTERSTATE RULES (CAIR)— _ No requirements under these rules as they have been replaced by the Cross State Air Pollution Rules (CSAPR). G. CROSS STATE AIR POLLUTION RULES (CSAPR)PERMIT REQUIREMENTS—The Permittee shall comply with all applicable requirements of 40 CFR 97 Subparts 5A, 5B, and 5C. OBIS W: 2707 a. 40 CFR 97 Subpart 5A—TRANSPORT RULE NOx ANNUAL TRADING PROGRAM APPEARED IN COMPLLANCE: The facility participates in the NOx Trading program. 10 allowances were used in 2016, and the facility has 14 allowances available for trading. b. 40 CFR 97 Subpart 5B—TRANSPORT RULE NOx OZONE SEASON TRADING PROGRAM APPEARED IN COMPLIANCE: The facility does participate in NOx trading during ozone season. 8 allowances were used in 2016, and the facility has 12 allowances available for trading. c. 40 CFR 97 Subpart 5C—TRANSPORT RULE SO2,GROUP 1 TRADING PROGRAM APPEARED IN COMPLIANCE: The facility participates in the S02 Group I Trading program. 4 allowances were used in 2016, and the facility has 8 allowances available far trading. H. 15A NCAC 2Q .0315—SYNTHETIC MINOR FACILITIES—Operate within the following limits to maintain SO2 and NOx emissions less than 100 tons annually.Records of fuel use and NOx emissions calculations. Annual reporting. APPEARED IN COMPLIANCE: Records indicate 75,539 gallons of fuel oil have been combusted in the last 12 months, as of 30 June 2017. The facility maintains fuel certifications on-site, and only accepts ULSD. Fuel sampling indicates that the fuel oil currently on-site has a sulfur content of 0.0087 wt.%. NOx emissions for the last 12-month period were 3.72 tons, as of 30 June 2017. We asked to see how the calculations were made for emissions, to verify the correct Part 75 emission factors were being used. Bill Horton, Lead Environmental Specialist,provided a copy of the calculation documents, and the calculations are made using the tool in ECMPS, which has built-in emission factors per Part 75. The last annual report was received on 23 January 2017, and indicated compliance. I. 15A NCAC 2Q .0317—LIMITATION TO AVOID PSD—Limit SO2 and NOx emissions to 250 tons per consecutive 12-month period. APPEARED IN COMPLMNCE: The facility complies with this stipulation by operating within its Synthetic Minor limitations. J. 15A NCAC 2Q .0102—FEDERAL AND STATE RULES APPLICABLE TO EXEMPTED SOURCES— a. NESHAP Subpart ZZZZ (Stationary Reciprocating Internal Combustion Engines) —Emergency engine lEmGenMWT is subject. Requirements include installation of a non-resettable hour meter, oil and filter change and hose and belt checks at 500 hours/annually, check spark plugs 1,000 hours/annually. 100-hour annual limit on operation for maintenance, 50-hour annual limit for non-emergency use. APPEARED IN COMPLIANCE: Periodic I&M is conducted as required, with the last annual maintenance being completed on 13 September 2017. We reminded Ms. Kashmer and Mr. Rivers that this is an annual requirement and that the annual maintenance would need to be completed by the end of this year. We also provided Mc. Kashmer with a copy of the generic permit language for NES11AP Subpart 4Z. The engine was verified to have a manufacture date of 13 November 2003, and we observed the non-resettable hour meter, which read 758.4 hours during the inspection. Ms. Kashmer mentioned that there is a plan to move the microwave tower and engine closer to the turbines at some point in the future. VII. INSIGNIFICANT ACTIVITIES: 101LTANKI No.2 fuel oil storage tank 2Q.0102(g)(14)(B) Yes Yes (850,000 gallon capacity) 1LUBETANK 1 Lube Oil Storage Tank#1 2Q .0102(g)(14)(B) Yes Yes (550 gallon capacity) 1LUBETANK2 Lube Oil Storage Tank#2 2Q .0102(g)(14)(B) Yes Yes (1800 gallon ca achy) 1LUBETANK3 Lube Oil Storage Tank 43 2Q.0102(g)(14)(B) Yes Yes (1800 gallon ca achy) ILUBETANK4 Lube Oil Storage Tank#4 2Q .0102(g)(14)(B) Yes Yes (1800 gallon ca achy) 1LUBETANK5 Lube Oil Storage Tank#5 2Q .0102(g)(14)(B) Yes Yes (1800 gallon capacity) lEmGenMWT 35kW Propane-fired Emergency Generator 2Q .0102 (h)(5) Yes Yes (NESHAP Subpart ZZZZ) VIII. NON-COMPLIANCE HISTORY SINCE 2010: This facility has no negative compliance history. IX. RISK MANAGEMENT (112r): This facility does not store any 112(r)subject materials above threshold limits.Therefore, it is not required to maintain a written Risk Management Plan(RMP)_ X. CONCLUSION AND RECOMMENDATIONS: - Duke Energy Progress,LLC—Blewett appeared to be operating IN COMPLIANCE with their air permit at the time of this inspection. PINK SHEET ADDITIONS: For the inspector,the previous fuel oil limit of 1,602,175 gallons per 12-month period(at 0.5 wt.% sulfur) can be used to verify compliance with the 100 TPY S02 limit. - At next permit action, include a recordkeeping requirement for 12-month SOZ emissions. Jlh