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HomeMy WebLinkAboutAQ_F_0400050_20110406_CMPL_InspRpt i I NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY NCEMC-Anson Plant NC Facility ID 0400050 Inspection Report County/FIPS: Anson/007 Date: 04/27/2011 Facility Data Compliance Data NCEMC-Anson Plant Inspection Date 04/06/2011 749 Blewett Falls Rd Inspector's Name Heather Hawkins Lilesville,NC 28091 Operating Status Operating Lat: 34d 58.0837m Long:79d 553361m 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/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: 1. MACTs/GACTs: The facility does not appear to be subject to any MACTs/GACTs at this time. II. DIRECTIONS TO SITE: From FRO take 401 S. to Wagram. Tun 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. Approx 2 miles after crossing the Pee Dee River,turn right onto Clark Mountain Road(SR 1744). Go about a mile to the stop sign and turn right onto Vintage Road. Go a half mile and bear left at the split onto Blewett Falls Road. The entrance to the plant is about a mile on the left. III. 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. IV. 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 i 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 does not have a continuous emission monitoring system(CEMs)for NOx emission rate. However, they have the predictive emission monitoring system(PEMs)to monitor NOx emissions in lieu of CEMs. The predictive emission monitoring system has been proven to be as accurate as the CEMs and is in fact more economical from the cost and maintenance standpoint. 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. If NOx emission rate exceeds the limits(25 ppm for natural gas and 74 ppm for fuel oil)and lasts more than 172 seconds,the turbines will be automatically shut down. Ilj V. INSPECTION SUMMARY: On 6 April 2011,Robert Hayden,of the Fayetteville Regional Office,and I met with Mr.Shawn Fowler at the Anson facility to conduct an air quality compliance inspection. Mr.Fowler verified that the contact information is correct and there have been no changes at the facility since the last inspection. Mr.Fowler provided all records for review, as required by the permit. Mr.Fowler explained the turbine characteristics,controls and monitoring equipment and software. The plant was not operating on this date. This plant only operates as a"peaking"facility to meet peak power demands on a daily m•seasonal basis. Mr.Fowler explained that,due to a manufacturer's defect in the turbine fan system,they were in the process of disassembling and shipping the fan system to the mfg company for repair. He stated that they would only be taking down one unit(two fans)at a time so that they would still be able to generate enough power to the grid during high demand times. VI. 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-IA 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-I 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-313 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-313 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 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-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 VII. REGULATORY/STIPULATION REVIEW: A. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS—Subject sources:twelve turbines(ES-IA&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. Mr.Fowler stated that he never sees VE from the turbines. B. 15A NCAC 2D.0524:NSPS,40 CFR PART 60,SUBPART KKKK—Subject sources;twelve turbines (ES- lA&B thru ES-6A&B). a. SO2 emission limits=max sulfur content of fuel will be</=0.05%by weight;SO2 monitoring=either monitor total sulfur content of fuel being fired in each turbine,or demonstrate fuel will not exceed potential sulfur emissions of 0.06lbs sulfur/MMBtu by valid contract or representative fuel sampling; SO2 reporting=submit semi-annual excess emissions reports for all periods including startup,shutdown, and malfunction. IN COMPLAINCE-The facility demonstrated compliance with the NSPS limits based on source tests reviewed and approved by the Raleigh Central Office. Fuel oil sulfur content determined by representative sampling show avg of 0.0018%. Reports have been submitted on time. 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=shall install,calibrate,maintain,and operate a continuous monitoring system or install CEMS; NOx reporting=submit semi-annual excess emissions reports for all periods including startup,shutdown,and malfunction. IN COMPLIANCE-The facility demonstrated compliance with the NSPS limits based on source tests reviewed and approved by the Raleigh Central Office. The PEMS at the facility was calibrated in Sept 2010,and 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). Reports have been submitted on time. 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 0.151b/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. I 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 NO limits under this rule. IN COMPLIANCE-There are no SO2 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-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. IN COMPLIANCE-Records of startup/shutdown,exhaust gas temp,and monthly CO/daily NOx emissions appeared valid and complete. Total 2010 emissions for CO and NOx were 52.7 and 91.14 tons,respectively. Reports have been received on time. F. 15A NCAC 2D.1100: CONTROL OF TOXIC AIR POLLUTANTS-Subject sources:twelve turbines(ES- IA&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: Fuel Oil Sulfur Content Maximum Turbine-Hours/Da (total 12 turbines) 0.050%or less 132 0.045 or less 144 0.040 or less 168 0.030 or less 204 0.025 or less unlimited IN COMPLIANCE-The facility combusts only ultra-low sulfur No.2 fuel oil(<15ppmw),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 records show that the average sulfur content was approximately 18ppm. The facility had combusted No.2 fuel oil only a few times during 2010 for preventive and maintenance purpose. The average startup/shutdown for each turbine was<'/z hour per day during 2010. According to Mr.Fowler, it takes about 10 min to startup and 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 are about 3-4 times per day.The facility records are maintained in a control building. VIII. 112R STATUS NCEMC-Anson Plant is not required to have a written plan, but is subject to the General Duty clause of this regulation. IX. COMPLIANCE HISTORY: August 2006—CAI-Reporting X. CONCLUSIONS/RECOMMENDATIONS: Based on observations made during the 6 April 2011 inspection,NCEMC Anson County Combustion Turbine Facility appeared to be in compliance with all requirements outlined in their current air permit. /hsh