AQ_F_0400050_20100218_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY NCEMC-Anson Plant
Inspection Report NC Facility ID 0400050 '
Date: 02/19/2010 County/FTPS:Anson/007
Facility Data Compliance Data
NCEMC -Anson Plant Inspection Date 02/18/2010
749 Blewett Falls Rd 'Inspector's Name;Tien Nguyen
Lilesville, NC 28091 ' Operating Status Operating
Lat: 34d 58,0090m ` Long: 79d 55.3220m Compliance Code Compliance
SIG: 4911/Electric Services inspection
NAICS: 221112/Fossil Fuel Electric Power Generation Action Code PCE
On-Site Inspection Result Compliance.
Contact Data Permit Data
Facility,Contact Authorized Contact Technical Contact
Permit 09492/R04
Shawn Fowler Terrence Ryan June Small Issued 3/5/2007
Manager,Combustion _ VP,Asset Management Director of Expires 12/31/2009
Tutbine'Generation (919)875-31 H Environmental Affairs Classification Title V ,
[phone] [phone] Permit Status Active
Inspector's Signature: Comments:
Date of Signature:
I. MACTs/GACTs:
The facility does not appear to be subject to any MACTVGACTs at this time.
II. 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 l 5 miles after
crossing the Pee Dee River,turn right onto Clark Mountain Road(SR 1244). 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 Bleweit 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 is a simple-cycle,natural gas-fired(low sulfur No. 2 fuel oil backup]combustion turbine electricity
generating facility 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 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 efficiencyduring 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(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.
The Plant Information(PI)System was installed at this facility for plant-wide monitoring and annalysis. The system
handles the collection,storage,and retrieval of numerical and data.They also act 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 RI=Data Archive. —-- -----------
The facility does not have a continuous emission monitoring system(CEMs)for NOx emission rate. However,
they have the 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.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.
V. INSPECTION SUMMARY:
Tien Nguyen of the Fayetteville Regional ffice met with Mr.Shawn Fowler to conduct
an air quality compliance inspection.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.'Mr.Fowler+provided documents for the recordkeeping review.Mr..
Fowler explained the turbine characteristics,controls and monitoring equipment and software. The plant was not
operating orf tbWdate.This plant only operates as it"peaking"facility to meet peale'power demands on a daily or
seasonal basis:
VI. PERMITTED EMISSION SOURCES: (multiply by 12) '
NSPS-One Pratt&Whitney FT8 Swift Pac simple-cycle gas turbine equipped with water injection and an
oxidation catalyst system and one generator(300million Btu per hour nominal heat input capacity when firing
natural gas,and MI million Btu per hour nominal heat input capacity when firing No. 2 fuel oil.
VII, REGULATORY/STIPULATION REVIEW:
A. 15A NCAC 2D J 100,Control of Toxic Pollutants-Requiled because a sulfuric acid mist(TAP H2SO4)is
part'of theloxidation catalystsystem. The permit contains daily operating limits when firing fuel oil.
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 Tess 132
0.045 or less 144
0.040 or less 168
0.030 or less > 204
0.025 or less unlimited
The Permittee shall record the number of startup and shutdown hours for each turbine on a daily basis.
Turbine startup and shutdown shall be limited to an average oft hours per day per turbine.
IN COMPLIANCE The facility combusts only ultra-low sulfur No. 2 fuel oil(<1 Sppmw), 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 7ppm. The facility had combusted No.2 fuel oil only a few times during,2009 for preventive
and maintenance purpose. The average startup and shutdown for each turbine were</a hour per day
during 2009.According to Mr. Fowler, it takes about 10 minutes to startup,and shutdown an engine. In
order to exceed 2 hours limit per day, the average startup and shutdownfor each turbine must be more
than 12 times per day. The records show that the average startup and shu€down for each turbine are about
3-4 times per day. The facility.records are maintained in a control building:

B. 15A NCAC 2D.0521.Control of Visible Emissions-visible emissions from the combustion turbines(ID
Nos.ES 1-A,ES I-B,ES2-A,ES2-B,ES3-A,ES3 B,ES4-A,ES4-B,ES5-A,ES5-B,ES6-A,ES6-B) ,
manufacturedsfter July 1,'1971,shall-not be more than 20 percent opacity each when averaged over a six-
minute period except during startup,shutdowns,and malfunctions.
IN COMPLIANCE-Natural gas and No. 2 fuel"oil are clean burning fuels and as such the opacity
shouldalways be-in compliance witk the 20 Percent limitation No turbines were-operating-during the
inspection.
C. 15A NCAC 2D.0524,New Source Performance Standards(Subpart KKKK)
a. S02 emission limit(both fuels'-0.06 lb/mmBtu):
IN COMPLIANCE The facility demonstrated compliance with the'NSPS limits based on stack
test reports approved by the Raleigh Central Office. (Notice: The facility had conducted a
number of stack tests on the turbines, but some of stack test reports are still waning for'approval)
b. NOx emissions limit(oil-14ppm at 15%,02).
IN COMPLIANCE-Thefiacility demonstrated compliance with the NSPS limits based on stack
test reports approved by the Raleigh Central Office.,(Notice: The facility had conducted a
number of stack tests on the turbines, but some of stack test reports are still waiting for approval)
c. NOx emissions limit(NO 25 ppm at 15%02),
IN COMPLIANCE-The facility demonstrated compliance with the NSPS limits based on stack z
test reports approved by the Raleigh Central Office. (Notice; The facility had conducted a,
number of stack tests on the turbines, but some of stack test reports are still waiting for approval)
D, Performance testing per General Provisions and the NSPS.
INCOMPLIANCE based on dates and types of notifications received, tests conducted, and results
submitted.
I ',Monitoring and Recordkeeping. Operate systems,to minimize emissions;Permittte must install,calibrate,
maintain and operate,a continuous monitoring system to monitor and record the fuel consumption and the
ratio of water to fuel being;fired in the turbines.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 20grains of sulfur or less per 10.0 standard cubic feet.
IN COMPLIANCE-Based on NG certtfication provided by supplier(Transco), the total sulfur content
for natural gas is less 20 grains of sulfur per 100 standard cubic feet. They only purchdse fu81 oil with -
sulfur content less than 15ppmw. The facility installed a predictive emission monitor system to monitor and -
calculate emissions from the turbines, The,records show that the water and fuel meters were initial
calibrated during2006. Mr,Flowler stated that they are required to calibrate the meters for every five
years.;
F. 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' received' Semiannual reports received'on time.
G. 15A NCAC 2Q 0317,PSD(.213.0530)Avoidance Conditions(245 TPY.NOx and CO). Requires
emissions testing for CO and NOx(the NSPS performance testing suffices for NOx)with both oil and
NO.
IN COMPLIANCE- The average NOx and CO emissions were well below 245TPY per consecutive 12-
month rolling period. The facility demonstrated compliance with the NSPS performance testing based'on
dates and types of notifications received, tests conducted, and results submitted--

i
w ,
H, Monitoring/Recording-NOx. Facility shall 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,perind
IN COIVIPLtANCE—Th—efa—cility continuous mom orb recor s empera re by a saftw
�are nown as
Pt<'Ms. The facility uses this,software to monitor and determine NOx emissions from the gas turbines.
The records indicate the highest NOx emissions were approximately 88 tons per consecutive 127month
rolling period.
1. 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 15AQ semiannually. Facility must monitor exhaust temperature
at the gas generator and.turbine heat input every 15`seconds,and use stack test-derived emissions data t'o
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 facility continuously monitors the EGT and maintains the temperature within permit
limit ranges. The report indicates average CO emissions were approximately 40 tons per consecutive 12-
month rolling period
J. Reporting-NOx and CO. Report results of monitoring semiannually.
IN COMPLIANCE-Based on last report received at FRO on 30 January 2010,NOx and CO emissions
were below the permit emission limits.
K. 15ANCAC 2D.1418,New Electric Generating Units. This regulation applies to electricity, "retail'unitsi
constructed after 31 Oct2000 with capacity greater than 25 MW. NOx emissions limited to 0.15
lbs)mmBtu(gas and solid fuels)and 0.181b/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 ozotie'season(1 May—30 Sep). The methodology,using stack test data
and exhaust temperatures meets the requirement.
,
IN COMPLIANCE-,Per the manufacturer's data, at design,for natural gas using the high heat value,
the NOx emission is 0.10 pounds per million Btu and for No. 2 fuel oil using the high heat value, the NOx
emission is 0.178 pounds per;million Btu.
VIII. CONCLUSIONS/RECOMMENDATIONS:
Based on observations made during the 18 February 2010 inspection,NCEMC Anson County Combustion
Turbine Facility appeared to be in compliance with all requirements outlined in their current air permit.
Two fuel tanks should be added to insignificant activities.
/txn
Cc: DAQ Central Files
FRO`Facility Files;-
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