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NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY NCEMC-Anson Plant
NC Facility ID 04,00050
Inspection Report County/FIPS`Anson/007 -
Date :02/23/2009
Facility Data Compliance Data
NCEMC-Anson Plant Inspection Date.02/19/2009
749 BlewettTalls Rd Inspector',s Name Tien Nguyen
Lilesville,NC 28091 Operating Status Operating
.Lat: 34d 58.0090m Long:,79d 55.3220m Compliance Code Compliance-inspection
SIC : 4911 /Electric Services .�aa Action Code FCE
NAICS 221112/Fossil Fuel Electric.l�ower Generation On-Site Inspection Result Compliance"
Contact Data Permit Data
'Facility Contact Authorized Contact Technical Contact permit 09492/R04
Shawn Fowler Terrence Ryan', Jurie Small Issued" 3/5/2007
Manager,Combustion VP,Asset Managemen t Director of, Expires 12/3.1/2009
Turbine Generation (919)875-3111 Environmental Affairs Classification Title V
(704)848-4002J (919)875-3 i 16 Permit Status Active
Inspector's Signature: Comments:
Date of Signature:
I. 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. Approx 1.5 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.
� 1
IL FACILITY DESCRIPTION
This facility is a simple-cycl#natural gas-fired.(low sulfur No:2 fuel oil backup)combustion turbine electricity;
generating facility,in Anson i✓ounty. 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 FT8 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 water injection(NOx)and a high temperature oxidation catalyst(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.
Required safety equipment includes,'safety shoes,eye protection and hardhatl Open no doors and touch-no
plumbing while the turbine is in operation.
III, INSPECTION SUMMARY
On 19,February2009,I,Tien Nguyen of the Fayetteville Regional Of ee,'met with Mr.Shawn Fowler to conduct a
full compliance inspection.I observed visible emissions and plant''surroundings prior to entering the facility. I
checked opacity of all stacks that could be seen from the hillside.I`observed no visible emissions from,the stacks,
and no vegetative damage. During the inspection conference,Mr.Fowler checked the facility contact information
for correctness.Mr.Fowler verified that the facility contact information was correct and there had been no changes
at the facility since last inspection.I verified the facility had a copy of current air permit at the site.Mr.Fowler
provided documents for the recordkeeping review. He stated that the facility had burned No.2 fuel oil two times
since 2008.The records indicated that the turbines.had burned No2 fuel oil onc February;I9,2008 and January 6,
2009. Mr.Fowler explained details about the predictive emissiom monitoring system(PENIS).They continuous
monitor fuel consumption,gas exhaust temperature,and water to fuel ratio to determine NOx emissions.I noticed
the facility did not have the continuous emission monitoring(CEM)for NQx emissions.
Mr.Fowler stated that the facility continuously monitors and send to corporate;located in Raleigh,in 15-minute
intervals Mr.Fowler stated that the turbines would be automatically shutdown if any operation parameters were
out side the permit range.I reviewed the fuel oil certification for sulfur content.The records indicated the sulfur
content is less than 500 ppm.The highest sulfur content of No, fuel oil was 31 ppm at this facility.The facility
analyzes sulfur content of No.2 fuel oil quarterly.'Mr.Fowler gave me a tour of the facility.He explained details of
the turbines characteristics and maintenance,requirement:I noticed the facility,was not operating on the day of the
inspection:However,the facility appeared very clean and well maintained. Mr.Fowler stated that the facility,did
not have schedule to operate-on that day.This plant only operates:as a"peaking"facility to meet.peak power
demands on a daily or seasonal basis.
JAI
(IV)PERMITTED EMISSION SOURCES: (multiply by 12)
NSPS 1. One Pratt & Whitney FTB Swift-Pac simple-cycle gas turbine equipped with water injection and an
oxidation catalyst system and one'generator (300 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,ES1-A)
(V) REGULATORY/STIPULATION REVIEW:
A. 15A NCAC 21) .1100,Control of Toxic Pollutants-Required because a sulfuric acid mist(TAP-H2SO4) is part
of the oxidation catalyst system. The permit contains daily operating limits when firing;fuel oil. The facility must
monitor and-.record operating hour's and sulfur content when firing fuel oil, and report deviations semiannually.
Turbine startup and shutdown shall be limited to an averageof 2 hours per day per turbine.
IN COMPLIANCE-\The facility fuel oil is low sulfur;(0:031%"by weight). Thefacility had combusted fuel oil two
times since June 2008. -The semi-annual report indicated that there were'no exceptions from the total turbine
operating or daily startup and shutdown time. The facility continuous monitors hours of operation and fuel oil
consumption for all units.
B. 15A NCAC 21) .0521. Control of Visible Emissions-visible emissions from the combustion turbines (ID Nos.
ES1.-A, ES1-B, ES2-A, ES2-B, ES3=A, ES3-B, ES4-A, ES4-B, ES5-A, ES5-B, ES6-A ES6-B);manufactured after. ,
July 1, 1971,'shall not be more than 20 percent opacity each when averaged over a six-minute period except during
startup,shutdowns,and malfu ctions.
IN COMPLIANCE-I observed no visible emissions from the stacks. The facility was not operating on the day of the
inspection:,
i
C. 15ANCAC 21).0524,New Source Performance Standards(Subpart"KKKK)
I.. S02 emission limit_(both'f,iels-0.06 lb/mmBtu).
IN COMPLIANCE-based*on stack testing conducted in;March-April 2007 and 2008. DAQ reviewed and
determined that sulfur dioxide emissions are compliance with air permit:
2. NOx emissions limit(oil-74 ppm at 15%02).
IN COMPLIANCE-based on stack testing conducted in March-April 2001 and 2008. DAQ reviewed and
determined that nitrogen dioxide emissions are compliance with air permit.
3. NOx emissions limit(NO-25'ppm at 151/o 02).
IN COMPLIANCE-based on stack testing conducted in March-April 2007 and 2008, DAQ reviewed and
determined that nitrogen dioxide emissions are compliance with air permit.
_ Of
4. Performance testing per General Provisions and the NSPS.
INCOMPLIANCE -based on dates and types of notifications received, tests conducted, and results
submitted.
5. Monitoring and recording. Operate systems to minimize emissions; monitor S02 through either CEM or
fuel certifications and testing. Demonstrate that the fuel quality characteristics in a current, valid purchase
contract, tariff sheet or transportation contract for the fuel, specifies that the maximum total sulfur content
for oil is 0.05 weight percent (500 ppmw) or less, the total sulfur content for natural gas is 20 grains of
sulfur or less per 100 standard cubic feet.
IN COMPLIANCE- based on monthly NG certification provided by supplier (Transco), the total sulfur
content for natural gas is less 20 grains of sulfur per 100 standard cubic feet. The records indicate that the
facility analyzes the fuel oil sulfur content quarterly. They only purchase fuel oil with sulfur content less
than 0.05% by weight. The records also indicate that the test results for sulfur content are compliance
with the current air permit.
6. Reporting. Construction date and actual start-up, as well as semiannual excess emissions, per definition in
the permit and Subpart KKKK.
IN COMPLIANCE-All initial reports received. Semiannual reports received on time.
D. 15A NCAC 20 .0317,PSD(.2D.0530)Avoidance Conditions (245 TPY NOx and CO)
1. Testing. Requires emissions testing for CO and NOx (the NSPS performance testing suffices for NOx)
with both oil and NG.
IN COMPLIANCE based on stack tests conducted in March-April 2007 and 2008. DAQ reviewed and
determined that test results are considered an acceptable demonstration of compliance with NOx and S02
emission limits.
2. Monitoring/Recording-NOx. Facility must monitor ambient temperature and turbine heat input every 15
seconds, and use stack test-derived emissions data to calculate emissions rates. Include emissions during
start-ups and shut-downs at 5% load change per minute. Calculate and record daily NOx emissions.
Report 12-month rolling totals semiannually. Nitrogen dioxide emissions from the combustion turbines
shall be less than 245 tons per consecutive 12-month period
IN COMPLIANCE—the facility continuously monitors and collects data. The report indicates the average
NOx emissions were approximately 42 tons per consecutive 12-month rolling period. The emissions were
estimated based on stack test emission factors.
3. Monitoring/Recording - CO. Monitor exhaust gas for effectiveness of oxidation catalyst(should be 840-
1800 F) and estimate CO emissions with correlated data from stack testing (formula in permit). Calculate
rolling 12-month totals. Report totals to DAQ semiannually. Facility must monitor exhaust temperature at
the gas generator and turbine heat input every 15 seconds, and use stack test-derived emissions data to
calculate emissions rates. Include emissions during start-ups and shut-downs at 5% load change per
minute. Carbon monoxide emissions from the combustion turbines shall be less than 245 tons per
consecutive 12-month period.
IN COMPLIANCE-.The semi-annual report indicates that there were no excursions of the exhaust gas
temperature. The average minimum and maximum 3-hour block values for exhaust gas temperature were
approximately 1424 and 1314 °F respectively. The facility continuously monitors the EGT and maintains
the temperature within permit limit ranges. The report indicates average CO emissions were approximately
31 tons per consecutive 12-month rolling period.
4. Reporting-NOx and CO. Report results of monitoring semiannually.
IN COMPLIANCE- based on last report received at FRO on 30 January 2009. NOx and CO emissions
are compliance with NOx and CO emission limits.
15A NCAC 2D .1418,New Electric Generating Units
This regulation applies to electricity"retail"units constructed after 31 Oct 2000 with capacity greater than 25 MW.
NOx emissions limited to 0.15 lbs/mmBtu (gas and solid fuels) and 0.18 lb/mmBtu (liq fuel). Generators meeting
the definition of low-mass emission units in CFR 75.19 have alternatives to monitoring NOx via CEMs,and are thus
limited to 50 tons of NOX emissions during ozone season(1 May—30 Sep). The methodology using stack test data
and exhaust temperatures meets the requirement.
IN COMPLIANCE-based on stack testing conducted in March-April 2007 and 2008. DAQ reviewed
and determined that sulfur dioxide emissions are in compliance with air permit. The facility continuously
monitors fuel consumption,gas exhaust temperature, and water to fuel ratio to determine NOx emissions.However,
the facility did not have the continuous emission monitoring(CEM)for NOx emissions. The report indicates NOx
emissions are in compliance with air permit.
(VI)CONCLUSIONS/RECOMMENDATIONS:
Based on observations made during the 19 February 2009 inspection,NCEMC Anson County Combustion Turbine
Facility appeared to be in compliance with all requirements outlined in their current air permit.
Program Subpart Pollutant _ Compliance Violation Not Inspected
Procedural Emission
SIP CO W r I F
SIP NOx
f r —
SIP Toxics-VOC W
SIP Visible Emissions (�
Title V CO IJ
Title V NOx
NSPS Subpart KKKK NOx I�
NSPS Subpart KKKK S02 (d
/txn
Cc: DAQ Central Files
FRO Facility Files