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HomeMy WebLinkAboutAQ_F_0400050_20090219_CMPL_InspRpt ha 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