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HomeMy WebLinkAboutAQ_F_0400050_20120307_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: 03/08/2012 Facility Data Compliance Data NCEMC-Anson Plant Inspection Date 03/07/2012 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 NAILS: 221112/Fossil Fuel Electric Power Generation On-Site Inspection Result Compliance Contact Data Permit Data Facility Contact Authorized Contact Technical Contact Permit 09492/T05 Shawn Fowler Terrence Ryan June Small Issued 6/24/2010 Manager,Combustion VP,Asset Management Director of Expires 5/31/2015 Turbine Generation (919)875-3111 Environmental Affairs Classification Title V (704)848-4002 (919)875-3116 Permit Status Active Inspector's Signature: Comments: Date of Signature: 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 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. 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 an oxidation catalyst system, 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 controls are demineralizer water injection to control NOx, and a high temperature oxidation catalyst to control CO. "Simple cycle gas turbine" means any stationary gas turbine, which 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. INSPECTION SUMMARY: On 7 March 2012, 1 met with the facility operator, Frank, at the Anson facility to conduct an air quality compliance inspection/record review for both the Anson and the Hamlet plants because the facility contact, Mr. Shawn Fowler, was not available. Frank verified that the contact information is correct, verified that there have been no changes at the facility since the last inspection, and provided all records for review, as required by the permit. Due to a manufacturer's defect in the turbine fan system,they are in the process of disassembling and shipping the fan system to the mfg company for repair. They are only taking down one unit(two fans)at a time so that they can still be able to generate enough power to the grid during high demand times. They are currently waiting on manufacturer to return the fans from the last Unit. Frank stated that even though they run on NG with fuel oil as a back-up, part of their preventive maintenance program requires them to shut the units down, once a quarter, on fuel oil (and it's a manufacturer recommendation). He said it keeps them lubricated and running smoothly. We discussed the up-coming Acid Rain Recertification testing scheduled for April at the Anson plant and following that at the Hamlet Plant. I told them I (or someone from the office) will probably be present for several days of the testing. PERMITTED EMISSION SOURCES: Emission Emissions Source Description Control Device Control Device Source ID No. ID No. Description ES-lA One Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbine(300 CD-1 Water injection system 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-lA Oxidation catalyst firing No.2 fuel oil)and one generator per set of turbines system ES-1B One Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbine(300 CD-1 Water injection system 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-1B Oxidation catalyst firing No.2 fuel oil)and one generator per set of turbines system ES-2A One Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbine(300 CD-1 Water injection system 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-2A Oxidation catalyst firing No.2 fuel oil)and one generator per set of turbines 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 system 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-3A Oxidation catalyst firing No.2 fuel oil)and one generator per set of turbines system ES-3B One Pratt&WhitneyFT8 Swift-Pac simple-cycle gas turbine(300 CD-1 Water injections stem 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-3B Oxidation catalyst firing No.2 fuel oil)and one generator per set of turbines system ES-4A One Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbine(300 CD-1 Water injection system 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-4A Oxidation catalyst firing No.2 fuel oil)and one generator per set of turbines system ES-4B One Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbine(300 CD-1 Water injection system 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-4B Oxidation catalyst firing No.2 fuel oil)and one generator per set of turbines system ES-5A One Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbine(300 CD-1 Water injection system 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-5A Oxidation catalyst firing No.2 fuel oil)and one generator per set of turbines system ES-5B One Pratt&Whitney 17178 Swift-Pac simple-cycle gas turbine(300 CD-1 Water injection system 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-5B Oxidation catalyst firing No.2 fuel oil)and one generator per set of turbines system ES-6A One Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbine(300 CD-1 Water injection system 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-6A Oxidation catalyst firing No.2 fuel oil)and one generator per set of turbines system ES-6B One Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbine(300 CD-1 Water injection system 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-6B Oxidation catalyst firing No.2 fuel oil)and one generator per set of turbines 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. 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 0.061bs S02/MMBtu. by representative fuel sampling; S02 reporting= submit semi-annual excess emissions reports for all periods including startup, shutdown, and malfunction. APPEARS 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 20 ppm S (0.0020%) in Tank #1 and 7.1 ppm S (0.00071%) 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. APPEARS IN COMPLIANCE- The facility demonstrated compliance with the NSPS limits based on source tests reviewed and approved by the Raleigh Central Office. The facility operates the PENIS as their continuous monitoring system, and it was calibrated in Sept 2010. It is scheduled to be re-calibrated every 5 yrs, or if unit exceeds 168 hrs/quarter for 3 consecutive quarters it will be re-cal every year. The PENIS activates an alarm if NOx emissions exceed 25ppm for more than 60 seconds and if at 172 seconds the emissions still exceed then the unit automatically shuts down. Reports have been submitted on time and appear complete and valid. C. 15A NCAC 2D .1418: NEW ELECRTRIC GENERATING UNITS- Subject sources: twelve turbines (ES-lA&B thru ES-6A&B). NOx emissions shall not exceed 0.15 lb/MMBtu when firing gaseous or solid fuels and 0.18 lb/MMBtu when firing liquid fuels. Compliance shall be determined by using Appendix E of 40 CFR 75.12 to estimate hourly NOx emission rates in lieu of CEMs. IN COMPLIANCE- Facility uses Appendix E info to calculate NOx emissions. The records were complete and appeared valid. D. 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 NOx limits under this rule. IN COMPLIANCE-There are no S02 allowances and NOx limits are not required for gas and oil fired units. E. 15A NCAC 2Q .0317 of 2D .0530: PSD AVOIDANCE- Subject sources: twelve turbines (ES-1A&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. APPEARS IN COMPLIANCE-Records of startup/shutdown, exhaust gas temp,and monthly CO/daily NOx emissions appeared valid and complete. Total 2011 emissions for CO and NOx were 61.12 and 105.74 tons,respectively. Reports have been received on time and appear complete and valid. F. 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 shall be limited while burning No. 2 fuel oil as follows: APPEARS 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 20 ppm for Tank #1 and 7.1 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 2011. According to Frank, it takes about 5 min to startup and10 minutes to shutdown an engine. In order to exceed 2 hours limit per day, the average startup and shutdown for each turbine must be more than 6 times per day. The records show that the average startup and shut down for each turbine during peak times is about 3-4 times per day. 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 March 2012 inspection,NCEMC Anson County Combustion Turbine Facility appeared to be in compliance with all requirements outlined in their current air permit. /hsh