AQ_F_0400050_20130207_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: 02/20/2013
Facility Data Compliance Data
NCEMC-Anson Plant Inspection Date 02/07/2013
749 Blewett Falls Rd Inspector's Name Heather Hawkins
Lilesville,NC 28091 Operating Status Operating
Lat: 34d 58.0837m Long: 79d 55.3361m Compliance Code Compliance- inspection
SIC: 4911 /Electric Services Action Code FCE
NAICS: 221112/Fossil Fuel Electric Power Generation On-Site Inspection Result Compliance
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 09492/T06
Shawn Fowler Terrence Ryan June Small Issued 4/11/2012
Manager,Combustion VP,Asset Management Director of Expires 5/31/2015
Turbine Generation [phone] Environmental Affairs Classification Title V
[phone] [phone] Permit Status Active
Inspector's Signature: Comments:
Date of Signature: L13
MACTs/GACTs:
The facility does not appear to be subject to any MACTs/GACTs at this time.
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 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.
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.
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, which does not recover beat 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.
INSPECTION SUMMARY:
On 7 February 2013, I met with the facility manager, Shawn Fowler, at the Anson facility to conduct an
air quality compliance inspection. Mr. Fowler verified that the contact information is correct, and stated
that they will be removing the catalytic oxidizers when the modified permit is issued. He provided all
records for review, as required,by the permit. We reviewed the draft permit language for the PSD
condition for CO emissions. The draft permit condition currently states that the units will burn ultra low
sulfur fuel oil (15ppm S). One of the fuel oil tanks received a shipment of higher sulfur oil in 2011 and
the test results currently show a value of 15.5ppm S in this tank. I advised Mr. Fowler that he could
either burn the oil in the tank prior to the issuance of the modified permit and fill it with oil below 15ppm
or request the ultra low sulfur requirement in the permit condition be changed to just low sulfur fuel oil
(500ppm S).
We briefly spoke about the combined effort from the facility and DAQ to petition EPA to allow an
alternative method for calculating the NOx emissions. Effectively, the current method (a straight 4-hr
rolling average) indicates the facility is in non-compliance by exceeding the NOx emissions limit. These
units usually startup in the last few minutes of the 4"'quadrant of an hour(prior to the start of a new hour)
and the water injection is ramping up during that time which indicates the water-to-fuel ratio is zero (6)
for the entire last quadrant and, similarly, shutdown occurs the first few minutes after the start of an hour
and the water injection is declining during that time which indicates the water-to-fuel ratio is zero (0) for
the entire quadrant. These zeros, when averaged in the current rolling4hr block, shows that the NOx
emissions are exceeding the limit. The proposal is to calculate the NOx emission rate based on water-to-
fuel ratio on a 240 minute rolling basis and not a straight 4-hr block. This would potentially show the
NOx emissions rate is below the limit for the rolling 240 minute period.
PERMITTED EMISSION SOURCES: No turbines were operating during the inspection.
Emission Emissions Source Description Control Control Device
Source Device Description
ID No. 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 CD-lA
firing No.2 fuel oil)and one generator per set of turbines Oxidation catalyst
system
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 CD-1B
firing No.2 fuel oil)and one generator per set of turbines Oxidation catalyst
system
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 CD-2A
firing No.2 fuel oil)and one generator per set of turbines Oxidation catalyst
system
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 CD-2B Oxidation catalyst
firing No.2 fuel oil)and one generator per set of turbines system
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 CD-3A
firing No.2 fuel oil)and one generator per set of turbines Oxidation catalyst
system
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 CD-3B
firing No.2 fuel oil)and one generator per set of turbines Oxidation catalyst
system
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 CD-4A
firing No.2 fuel oil)and one generator per set of turbines Oxidation catalyst
system
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 CD-4B
firing No.2 fuel oil)and one generator per set of turbines Oxidation catalyst
system
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 CD-5A
firing No.2 fuel oil)and one generator per set of turbines Oxidation catalyst
system
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 CD-5B
firing No.2 fuel oil)and one generator per set of turbines Oxidation catalyst
system
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 CD-6A
firing No.2 fuel oil)and one generator per set of turbines Oxidation catalyst
system
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 CD-6B
firing No.2 fuel oil)and one generator per set of turbines Oxidation catalyst
system
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 0.06lbs 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 and also quarterly. The most recent quarterly analysis showed 7.4 ppm S
(0.0015%) in Tank#1 and 15.5 ppm S (0.00076%) 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.
PENDING- The facility is currently working with the DAQ SSCB and EPA to develop an
alternate method of calculating NOx excess emissions over a rolling 240 minute period vs the
current rolling 4hr block. Compliance will be determined pending the outcome of those
discussions. However,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. See the discussion in the Inspection Summary regarding facility compliance with current
average NOx emission rate calculation parameters and proposed solution.
C. 15A NCAC 2Q .0400: ACID RAIN REQUIREMENTS- Subject sources: twelve turbines(ES-lA&B
thru ES-6A&B). There are no specified S02 Allowance Allocations and NO,, limits under this rule.
APPEARED IN COMPLIANCE-Contacted the DAQ SSCB,Alan Drake,who stated that,"Since this
facility emitted more than their 2012 allocations, it appears they used banked allowances or purchased
additional allowances from the open market. Since EPA did not contact DAQ regarding any
reconciliation violations,the sources appear to be in compliance."
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 and CO limit of 245 TPY. Startup/Shutdowns limited to
2hrs/day and must record # of startup/shutdowns per day. Exhaust gas shall be b/w 840 and 1800
degrees F. Calculate and record CO emissions monthly and for prev 12 month period, and NOx
emissions daily. Submit a summary rpt semi-annually.
APPEARED IN COMPLIANCE- Records of startup/shutdown, exhaust gas temp, and monthly
CO/daily NOx emissions appeared valid and complete. Total 2012 emissions for CO and NOx were
80.01 and 133.71 tons,respectively. Reports have been received on time and appear complete and valid.
E. 15A NCAC 2D .1100: CONTROL OF TOXIC AIR POLLUTANTS- Subject sources: twelve
turbines(ES-lA&B thru ES-6A&B). (Required because a sulfuric acid mist(TAP -H2SO4) is part of

the oxidation catalyst system.) Record number of startup/shutdowns per day for each turbine. Limit
turbine startup/shutdown to 2hrs/day. Operation of the combust turbines is limited while burning No.
2 fuel oil depending on the sulfur content(see permit for limits)
APPEARED IN COMPLIANCE- The facility combusts only ultra- low sulfur No. 2 fuel oil (<
25ppmw), therefore; the operational turbine hours per day are unlimited. The facility takes quarterly
samples of No. 2 fuel oil from the fuel tanks for the sulfur content analysis. The most recent analysis
showed sulfur content of 7.4 ppm for Tank #1 and 15.5 ppm for Tank #2. The facility continues to
combusted primarily Natural Gas (due to cost savings compared to fuel oil) but does combust No.2
fuel oil periodically for preventive maintenance purposes. The average startup/shutdown for each
turbine was<2 hour per day during 2012.
F. 15A NCAC 2Q .0400: PHASE H ACID RAIN PERMIT REQUIREMENTS- Subject sources:
twelve turbines (ES1-A&B thru ES6-A&B) There are no specified S02 Allowance Allocations and
NO,, limits under this rule. Facility must comply with the approved Acid Rain Permit Application
that is part of this permit.
APPEARED IN COMPLIANCE-Contacted the DAQ SSCB,Alan Drake,who stated that, "Since this
facility emitted more than their 2012 allocations, it appears they used banked allowances or purchased
additional allowances from the open market. Since EPA did not contact DAQ regarding any
reconciliation violations,the sources appear to be in compliance."
G. 15A NCAC 2Q .2403: CLEAN AIR INTERSTATE RULES (CAIR) PERMIT
REQUIREMENTS- Subject sources: twelve turbines (ES1-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-Contacted the DAQ SSCB,Alan Drake,who stated that, "Since this
facility emitted more than their 2012 allocations, it appears they used banked allowances or purchased
additional allowances from the open market. Since EPA did not contact DAQ regarding any
reconciliation violations,the sources appear to be in compliance."
H. 15A NCAC 2Q .2405: CLEAN AIR INTERSTATE RULES (CAIR) PERMIT
REQUIREMENTS- Subject sources: twelve turbines (ES1-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-Contacted the DAQ SSCB,Alan Drake,who stated that,"Since this
facility emitted more than their 2012 allocations, it appears they used banked allowances or purchased
additional allowances from the open market. Since EPA did not contact DAQ regarding any
reconciliation violations,the sources appear to be in compliance."
I. 15A NCAC 2Q .2404: CLEAN AIR INTERSTATE RULES (CAIR) PERMIT
REQUIREMENTS- Subject sources: twelve turbines (ES1-A&B thru ES6-A&B). S02 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 COMPLIANCE-Contacted the DAQ SSCB,Alan Drake,who stated that, "Since this
facility emitted more than their 2012 allocations, it appears they used banked allowances or purchased
additional allowances from the open market. Since EPA did not contact DAQ regarding any
reconciliation violations,the sources appear to be in compliance."

112R STATUS
NCEMC- Anson Plant is not required to have a written plan, but is subject to the General Duty clause of
this regulation.
FIVE YEAR COMPLIANCE HISTORY:
No compliance issues during the last 5 yrs.
CONCLUSIONS/RECOMMENDATIONS:
Based on observations made during the 7 February 2013 inspection, NCEMC - Anson Plant appeared to
be in compliance with the requirements outlined in their current air permit, pending the result of
discussions with DAQ and EPA regarding method of determining compliance with NOx emissions for
NSPS KKKK.
/hsh