AQ_F_0400050_20170111_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: 01/18/2017
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 S.Ragsdale Khalil Porter NSPS: Subpart KKKK
Manager,Combustion VP of Asset Management Environmental Scientist
Turbine Generation [phone] [phone]
[phone]
Compliance Data
Comments:
Inspection Date 01/11/2017
Inspector's Name Heather Carter
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: !/�g//( On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
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
2013 16.44 0.3200 53.26 9.71 47.01 16.44 713.55
*Highest HAP Emitted(inpounds)
Five Year Violation History:
None
Performed Stack Tests since last FCE:
None
1) DIRECTIONS TO SITE:
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 151501) 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.

2) 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.
3) FACILITY 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
Jmeet peak power demands on a daily or seasonal basis. Pollution control is dernmeralized 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
iCEMs 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.
4) INSPECTION SUMMARY:
On 11 January 2017, I, Heather Carter, met with Mr. Shawn Fowler, Plant Manager, at the Hamlet
facility. The Anson facility was not operating at the time, therefore I elected to conduct an air quality
compliance inspection consisting of records review from the Hamlet facility where all records for
Hamlet and Anson are available. Mr. Fowler provided all records for review, as required by the
permit. 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.
5) PERMITTED EMISSION SOURCES:
Emission Emissions Source Description Control Control Device
Source ID No. Device Description
ID No.
ES-lA One Pratt&Whitney FF8 Swift-Pac simple-cycle gas turbine(300 CD-1 Water injection
NSPS million Btu per hour nominal heat input capacity when firing system
Not Operating natural gas,and 281 million Btu per hour nominal heat input
capacity when firing No.2 fuel oil)and one generator per set of
turbines

ES-1B One Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbine(300 CDA Water injection
NSPS million Btu per hour nominal heat input capacity when firing system
Not Operating natural gas,and 281 million Btu per hour nominal heat input
capacity when firing No.2 fuel oil)and one generator per set of
turbines
ES-2A One Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbine(300 CD-1 Water injection
NSPS million Btu per hour nominal heat input capacity when firing system
Not Operating natural gas,and 281 million Btu per hour nominal heat input
capacity when firing No.2 fuel oil)and one generator per set of
turbines
ES-2B One Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbine(300 CDA Water injection
NSPS million Btu per hour nominal heat input capacity when firing system
Not Operating natural gas,and 281 million Btu per hour nominal heat input
capacity when firing No.2 fuel oil)and one generator per set of
turbines
ES-3A One Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbine(300 CDA Water injection
NSPS million Btu per hour nominal heat input capacity when firing system
Not Operating natural gas,and 281 million Btu per hour nominal heat input
capacity when firing No.2 fuel oil)and one generator per set of
turbines
ES-3B One Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbine(300 CDA Water injection
NSPS million Btu per hour nominal heat input capacity when firing system
Not Operating natural gas,and 281 million Btu per hour nominal heat input
capacity when firing No.2 fuel oil)and one generator per set of
turbines
ES-4A One Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbine(300 CD-1 Water injection
NSPS million Btu per hour nominal heat input capacity when firing system
Not Operating natural gas,and 281 million Btu per hour nominal heat input
capacity when firing No. 2 fuel oil)and one generator per set of
turbines
ES-4B One Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbine(300 CD-1 Water injection
NSPS million Btu per hour nominal heat input capacity when firing system
Not Operating natural gas,and 281 million Btu per hour nominal heat input
capacity when firing No. 2 fuel oil)and one generator per set of
turbines
ES-5A One Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbine(300 CD-1 Water injection
NSPS million Btu per hour nominal heat input capacity when firing system
Not Operating natural gas,and 281 million Btu per hour nominal heat input
capacity when firing No.2 fuel oil)and one generator per set of
turbines
ES-5B One Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbine(300 CD-1 Water injection
NSPS million Btu per hour nominal heat input capacity when firing system
Not Operating natural gas,and 281 million Btu per hour nominal heat input
capacity when firing No.2 fuel oil)and one generator per set of
turbines
ES-6A One Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbine(300 CD-1 Water injection
NSPS million Btu per hour nominal heat input capacity when firing system
Not Operating natural gas,and 281 million Btu per hour nominal heat input
capacity when firing No.2 fuel oil)and one generator per set of
turbines
ES-6B One Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbine(300 CD-1 Water injection
NSPS million Btu per hour nominal heat input capacity when firing system
Not Operating natural gas,and 281 million Btu per hour nominal heat input
capacity when firing No. 2 fuel oil)and one generator per set of
turbines

6) REGULATORY/STIPULATION REVIEW:
A. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS — Subject sources: twelve
turbines (ES-lA&B thru ES-6A&B). VE is limited to 20% opacity for each turbine when
averaged over a 6 min period,except during startup, shutdown and malfunction.
APPEARED IN COMPLIANCE- Facility combusts primarily natural gas, and No. 2 fuel oil
only as backup. Both are clean burning fuels and as such the opacity should always be in
compliance with the 20 percent limitation. Turbines were not observed in operation during this
records review inspection. Mr. Fowler stated he has not seen any visible emissions from the units
while operating on any fuel.
B. 15A NCAC 2D .0524: NSPS, 40 CFR PART 60, SUBPART KKKK— Subject sources: twelve
1 turbines(ES-lA&B thru ES-6A&B).
a. SO2 emissions limit=For fuel oil- max sulfur content will be</=0.05%, for NG- max sulfur
content will be </= 20 grains per 100scf, SO2 monitoring= fuel sampling/analysis to
determine sulfur content, SO2 reporting= submit semi-annually. summary/deviation report,
and 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 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 to
quarterly sampling whether fuel oil has been received or not. The most recent analysis
showed 8.2 ppm S in Tank#1 and 7.0 ppm S in Tank#2. NG sulfur content, according to the
Transco website, was within a range of 0.08 to 0.15 grains/100 scf from Jan 2016 through
Dec 2016. Most recent semi-annual and excess emissions/monitor downtime report received
on 7/28/16.
b. NOx emission limits= 25 ppm at 15 percent 02 when firing NG or 74 ppm at 15 percent OZ
when firing No. 2 fuel oil; NOx monitoring= 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; Demonstrate "peaking" status = avg capacity factor of no
more than 10% during 3 previous calendar years and no more than 20% during each of those
individual years. Recordkeeping= hourly records of time, load to unit, fuel flow and heat
input; and hourly calculated NOx emissions. NOx reporting= submit semi-annual excess
emissions/monitor downtime reports for all periods including startup, shutdown, and
malfunction.
APPEARED IN COMPLIANCE- Records show that each turbine is maintaining its
"peaking" status with a 3yr average capacity factor of 3.6-4.6% and a yearly (so far in 2017)
capacity factor of 0.1-0.2%. 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 in 2013, next test due in 2018),to predict hourly NOx emissions. The
fuel and water flow meters were last calibrated in March 2016 and are re-calibrated at least
every 5 years (depending on capacity used per turbine, quarterly) so next calibration is
tentatively planned for March 2021. 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. Most recent semi-
annual summary/deviation report and excess emission/monitor downtime report was received
on 7/28/16.

C. 15A NCAC 2D .0530 PREVENTION OF SIGNIFICANT DETERIORATION- Subject sources:
twelve turbines (FS-lA&B thru ES-6A&B). CO total emissions shall not exceed 405.5 tons/12 mth
period. Each unit shall not exceed 1230 hrs run time on natural gas or 710 hrs run time on No. 2 fuel
oil(d=0.002%S)annually,not including startup/shutdown time.
APPEARED IN COMPLIANCE- The 12-month rolling total CO emissions (Jan 2016 to Dec
2016)was 134.31 tons. All units were below the hour run time limit for this same period,737 hrs on
NG and 9.58 hrs on fuel oil being the highest any one unit ran.
D. 15A NCAC 2Q .0317 PSD AVOIDANCE- Subject sources: twelve turbines (ES-lA&B thru ES-
6A&B). NOx limit of 245 TPY. Must record # of startup/shutdowns per day. Monitor NOx
emissions in accordance with 40 CFR Part 60 Subpart KKKK (item B, above). Calculate NOx
emissions from each turbine daily (including SUSD + 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. Total
NOx emissions from Jan 2016 to Dec 2016= 120.96 tons. Most recent semi-annual report received
on 7/28/16.
E. 15A NCAC 2Q .0400: PHASE II ACID RAIN REQUIREMENTS- Subject sources: twelve
turbines(FS-lA&B thru ES-6A&B). There are no specified S02 Allowance Allocations under this
rule. The DAQ allocates tons of S02 allowances from a general fund for new sources. i
APPEARED IN COMPLIANCE—EPA's Air Markets Program Data website shows the facility
held an allowance of 29 tons S02 at the beginning of 2015 and reported emissions of 0 tons of S02 at
the end of 2015. They carried over an allowance of 29 tons for 2016. The 2016 data is not yet
available.
F. CROSS STATE AIR POLLUTION RULES (CSAPR) PERMIT REQUIREMENTS —
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 103 tons
NOx at the beginning of 2015 and reported emissions of 84 tons of NOx at the end of 2015.
They carried over an allowance of 19 tons NOx into 2016. The 2016 data is not yet available.
b. 40 CFR 97 Subpart 5B—OZONE SEASON TRADING PROGRAM- NOx
APPEARED IN COMPLIANCE: The facility participates in NOx trading during ozone
season. According to EPA's Air Markets Program Data website,they held an allowance of 65
tons NOx for the 2015 ozone season and reported emissions of 47 tons of NOx during the 2015
ozone season. They carried over an allowance of 19 tons NOx into 2016 ozone season. The
2016 data is not yet available.
c. 40 CFR 97 Subpart SC—GROUP 1 TRADING PROGRAM-S02
APPEARED IN COMPLIANCE: The facility participates in the S02 Group 1 Trading
program. According to EPA's Air Markets Program Data website, 0 S02 allowances were
used in 2015, and the facility had 0 S02 allowances available for trading at the end of 2015.
The 2016 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 213 .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 I of each year,stating compliance with all permit
conditions or noting any deviations during the previous calendar year.
1 APPEARED IN COMPLIANCE—The most recent ACC report was received on 02/17/16.
I. 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 2015 AQEI was received on 06/15/2016 and
appeared to be complete and accurate.
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.
7) CLEAN AIR ACT SECTION 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).
8) CONCLUSIONS/RECOMMENDATIONS:
Based on records review during the 11 January 2017 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.
/hsc