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HomeMy WebLinkAboutAQ_F_0400050_20140523_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: 06/04/2014 Facility Data Permit Data NCEMC-Anson Plant Permit 09492/T07 749 Blewett Falls Rd 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 NA1CS: 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 Lee Ragsdale Khalil Porter NSPS: Subpart KKKK Manager,Combustion VP of Asset Management Environmental Scientist Turbine Generation (919) 875-3056 (919)875-3088 (704)848-4002 Comments: Compliance Data Inspection Date 05/23/2014 Inspectors Name Heather Carter Inspector's Signature: `\ � Operating Status Operating h'a Compliance Code Compliance- inspection Date of Signature: Action Code FCE On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 * HAP 2012 38.63 0.9300 133.70 26.38 79.99 38.63 2135.99 2011 28.57 0.7000 105.76 20.33 61.14 28.57 1655.59 2010 31.29 0.7800 118.82 23.99 69.15 31.29 1868.05 *Highest HAP Emitted(inpounds) Five Year Violation History: None Performed Stack Tests since last FCE: Date Test Results Test Method(s) Source(s)Tested 08/23/2013 Compliance 08/08/2013 Compliance 08/01/2013 Compliance 07/25/2013 Compliance 07/19/2013 Compliance Method 10,Method 7E ES-5A,ES-513 07/09/2013 Compliance 1) MACTs/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-Pao 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 23 May 2014, 1, Heather Carter, met with Mr. Frank Bokuniewicz, O&M Planner and Scheduler, at the Anson facility to conduct an air quality compliance inspection. Mr. Shawn Fowler, facility contact, was not on site. Mr. Bokuniewicz verified that the contacts information is correct except for the invoice contact, which I will confirm with Khalil Porter, technical contact. He provided all records for review, as required by the permit. 6) PERMITTED EMISSION SOURCES: No turbines were operating during the inspection. C?Tmtsstou 13 Emissions Source Description Control Control Device Source Device Description IDNo.' 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 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 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-I 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-I 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 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 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 thru 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 Ibs 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 sulfur content is determined by representative sampling after every load is added to the storage tank. The most recent analysis showed 4.8 ppm S in Tank #1 and 5.2 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 the water-to-fuel ratio to predict NOx emissions, based on testing to establish the water-to-fuel curve. The PEMS activates an alarm if NOx emissions exceed 25ppm 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. 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 mtln period. Each unit shall not exceed 1230 firs run time on natural gas or 710 firs 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 (May 2013 to April 2014)was 51.98 tons. All units were below the hour run time limit for this same period, 331 firs on NG and 62 hrs 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- IA&B thru ES-6A&B). NOx limit of 245 TPY. Must record # of startup/shutdowns per day. Calculate and record NOx emissions daily. Submit a summary rpt semi-annually. APPEARED IN COMPLIANCE-Records of startup/shutdown and daily NOx emissions appeared valid and complete. Total NOx emissions from May 2013 to April 2014=60.23 tons. Reports have been received on time and appear complete and valid. E. 15A NCAC 2Q .0400: PHASE 11 ACID RAIN REQUIREMENTS- Subject sources: twelve turbines (ES-1A&B thru ES-6A&B). There are no specified S02 Allowance Allocations and NO, limits under this rule. APPEARED IN COMPLIANCE-The facility provided data that shows they had 0 S02 emissions in 2013. F. 15A NCAC 2Q.2403: CLEAN AIR INTERSTATE RULES (CAIR)FOR NOx- Subject sources: twelve turbines (ESI-A&B thru 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. APPEARED IN COMPLIANCE-The facility provided data that shows they emitted 47 tons NOx and held 133 allowances for 2013. G. 15A NCAC 2Q .2405: CLEAN AIR INTERSTATE RULES (CAIR) FOR NOx OZONE SEASON- Subject sources: twelve turbines (ESI-A&B thru 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. APPEARED IN COMPLIANCE-The facility provided data that shows they emitted 23 tons NOX and held 93 allowances for 2013. 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 S02 emission allowance allocations in the permit. Facility must comply with the approved CAIR Permit Application that is part of this permit. APPEARED IN COMPLL4,NCE-The facility provided data that shows they had 0 SO2 emissions in 2013. 8) 112RSTATUS 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 23 May 2014 inspection,NCEMC -Anson Plant appeared to be in compliance with the requirements outlined in their current air permit. /hsc