AQ_F_0400050_20150115_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: 01/20/2015
Facility Data Permit Data
NCEMC-Anson Plant Permit 09492/T07
749 Blewett Falls Road Issued 3/28/2013
Lilesville,NC 28091 Expires 5/31/2015
Lat: 34d 58.0837m Long: 79d 55.3361m Classification Title V
SIC: 4911 /Electric Services Permit Status Active
NAILS: 221112/Fossil Fuel Electric Power Generation Current Permit Application(s)Title IV,TV-
Renewal
Contact Data
Facility Contact Authorized Contact Technical Contact Program Applicability
SIP/Title V
Shawn Fowler Lee Ragsdale Khalil Porter
Manager,Combustion VP of Asset Management Environmental Scientist NSPS: Subpart KKKIC
Turbine Generation [phone] [phone]
[phone]
Compliance Data
Comments:
Inspection Date 01/15/2015
Inspector's Name Heather Carter
Inspector's Signature: Operating Status Operating
t Compliance Code Compliance-inspection
/// Action Code FCE
Date of Signature: j/ J On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2013 16.44 0.3200 53.26 9.71 47.01 16.44 713.55
2012 38.63 0.9300 133.70 2638 79.99 38.63 2135.99
2011 28.57 0.7000 105.76 20.33 61.14 28.57 1655.59
*Highest HAP Emitted(inpounds)
Five Year Violation History:
None
Performed Stack Tests since last FCE:
None
1) NIACTs/GACTs:
The facility does not appear to be subject to any MACTs/GACTs at this time.
2) 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.
3) 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.
4) 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
meet peak power demands on a daily or seasonal basis. Pollution control is demineralizer 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.
5) INSPECTION SUMMARY:
On 15 January 2015, 1, Heather Carter, along with Robert Hayden and Josh Harris, of this office, met
with Mr. Shawn Fowler, Plant Manager, at the Anson facility to conduct an air quality compliance
inspection. Mr. Fowler provided all records for review, as required by the permit. Mr. Fowler stated
that they did not use the purchase contract or tariff sheet option in the NSPS monitoring requirement
because they purchase fuel oil from more than one supplier and the rule required `one" source if that
option was selected for compliance demonstration. DAQ will research this issue for clarification.
The turbines were not operating at the time of inspection.
6) PERMITTED EMISSION SOURCES: No turbines were operating during the inspection.
O'Emtsston � Emissions Source Description Control ' Control Device
` {t o Device Descri tion A
fSourcett pss
IDi !
t1Vo. e ID No.
ES-lA 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 natural system
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 CD-1 Water injection
NSPS million Btu per hour nominal heat input capacity when firing natural system
as,and 281 million Btu per hour nominal heat illut 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 natural system
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 CD-1 Water injection
NSPS million Btu per hour nominal heat input capacity when firing 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 CD-1 Water injection
NSPS million Btu per hour nominal heat input capacity when firing natural system
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 CD-1 Water injection
NSPS million Btu per hour nominal heat input capacity when firing natural system
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 natural system
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 natural system
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 natural system
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 natural system
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 natural system
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 njection
NSPS million Btu per hour nominal heat input capacity when firing natural system
gas,and 281 million Btu per hour nominal heat input capacity when
firing No.2 fuel oil)and one generator per set of turbines
7) 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. No turbines were operating during the inspection.
B. 15A NCAC 2D .0524: NSPS, 40 CFR PART 60, SUBPART KKKK— Subject sources: twelve
turbines (ES-lA&B thin ES-6A&B).

a. S02 emissions limit= max sulfur content will be </= 0.05%; S02 monitoring= demonstrate
fuel will not exceed potential of 0.06 lbs S02/MMBtu by representative fuel sampling; S02
reporting= submit semi-annual excess emissions reports for all periods including startup,
shutdown, and malfunction.
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 sulfiir content is determined by representative sampling after adding loads to the
storage tank. The most recent analysis showed 7 ppm S in Tank#1 and 6 ppm S in Tank#2.
Reports have been received on time and appear complete and valid.
b. NOx emission limits= 25 ppm at 15 percent 02 when firing NG or 74 ppm at 15 percent 02
when firing No. 2 fuel oil; NOx monitoring= shall install, calibrate, maintain, and operate a
continuous monitoring system; NOx reporting= submit semi-annual excess emissions reports
for all periods including startup, shutdown, and malfunction.
APPEARED IN COMPLIANCE- The facility chose 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, to predict NOx emissions. The fuel and water flow meters are
calibrated at least every 5 years (depending on capacity used per turbine, quarterly). The next
scheduled calibration is fall of 2015. 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 slits 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. Reports have been
submitted on time and appear complete and valid.
C. 15A NCAC 2D .0530 PREVENTION OF SIGNIFICANT DETERIORATION- Subject sources:
twelve turbines (ES-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 Ins run time on No. 2 fuel
oil(</=0.002% S),not including startup/shutdown time.
APPEARED IN COMPLIANCE- The 12 mth rolling total CO emissions (Jan 2014 to Dec 2014)
was 65 tons. All units were below the hour run time limit for this same period, 371 hrs on NG and
39 his on fuel oil being the highest any one unit ran.
D. 15A NCAC 2Q .0317 OF 2D .0530: 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.
Calculate and record NOx emissions daily. Subm it a summary rpt semi-annually.
APPEARED IN COMPLIANCE- Daily records of startup/shutdowns and NOx emissions
appeared valid and complete. Total NOx emissions from Jan 2014 to Dec 2014=64 tons. Reports
have been received on time and appear complete and valid.
E. 15A NCAC 2Q .0400: PHASE II ACID RAIN REQUIREMENTS- Subject sources: twelve
turbines (ES-1A&B thru ES-6A&B). There are no specified S02 Allowance Allocations under this
rule. The DAQ allocated(from the general fund for new sources) an allowance of 30 tons S02 for
CY 2014.
APPEARED IN COMPLIANCE-The facility provided data that shows they had 0 S02 emissions
in 2014,which is well below the allowance.

F. 15A NCAC 2Q .2403: CLEAN AIR INTERSTATE RULES (CAIR)FOR NOx- Subject sources:
twelve turbines (ES1-A&B thin ES6-A&B). NOx emission limits= There are no specified NOx
emissions allowance allocations in the permit. Facility must comply with the approved CAIR
Permit Application that is part of this permit. The DAQ allocated (from the general fund for new
sources)an allowance of 133 tons NOx for CY 2014.
APPEARED IN COMPLIANCE-The facility provided data that shows they emitted 64 tons NOx,
which is well below the allowance.
G. 15A NCAC 2Q .2405: CLEAN AIR INTERSTATE RULES (CAIR) FOR NOx OZONE
SEASON- Subject sources: twelve turbines (ES1-A&B thin ES6-A&B). NOx emission limits=
There are no specified NOx emissions allowance allocations for ozone season in the permit. Facility
must comply with the approved CAIR Permit Application that is part of this permit. The DAQ
allocated (from the general fund for new sources) an allowance of 77 tons NOx during ozone
season for CY 2014.
APPEARED IN COMPLIANCE-The facility provided data that shows they emitted 24 tons NOx
during ozone season,which is well below the allowance.
H. 15A NCAC 2Q .2404: CLEAN AIR INTERSTATE RULES (CAIR)FOR 5O2- Subject sources:
twelve turbines (ESI-A&B thru ES6-A&B). SO2 emission limits= There are no specified SO2
emission allowance allocations in the permit. Facility must comply with the approved CAIR Permit
Application that is part of this permit. The DAQ allocated (from the general fund for new sources)
an allowance of 30 tons SO2 for CY 2014.
APPEARED IN COMPLIANCE-The facility provided data that shows they had 0 SO2 emissions
in 2014,which is well below the allowance.
8) 112R STATUS
NCEMC-Anson Plant is not required to have a written plan, but is subject to the General Duty clause
of this regulation.
9) CONCLUSIONS/RECOMMENDATIONS:
Based on observations made during the 15 January 2015 inspection,NCEMC -Anson Plant appeared
to be in compliance with the requirements outlined in their current air permit.
PINK SHEET ITEMS:
Recommend including minimal recordkeeping or annual reporting requirement associated with
BACT limits for CO.
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