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Home My WebLink AboutAQ_F_7400283_20230822_CMPL_InspRptNORTH CAROLINA DIVISION OF AIR QUALITY Inspection Report Date: 08/22/2023 Washington Regional Office International Broadcasting Bureau - Transmitter Site B NC Facility ID 7400283 County/FIPS: Pitt/147 Facility Data International Broadcasting Bureau - Transmitter Site B 3919 VOA Site B Road Grimesland, NC 27837 Lat: 35d 28.0839m Long: 77d 11.9499m SIC: 4911 / Electric Services NAICS: 221112 / Fossil Fuel Electric Power Generation Permit Data Permit 08788 / R04 Issued 8/12/2021 Expires 7/31/2029 Class/Status Small Permit Status Active Current Permit Application(s) None Program Applicability SIP MACT Part 63: Subpart ZZZZ Contact Data Facility Contact Rick Williford Program Support Specialist (252) 752-7181 Authorized Contact Thomas Moore Station Manager (252) 752-7181 Technical Contact Rick Williford Program Support Specialist (252) 752-7181 Comments: Based on visual observation and records review, the facility appeared to operate in compliance with all applicable air quality regulations and permit conditions at the time of inspection. Inspector’s Signature: Date of Signature: 8/22/2023 Compliance Data Inspection Date 08/14/2023 Inspector’s Name Yongcheng Chen Operating Status Operating Compliance Status Compliance - inspection Action Code FCE Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP SO2 NOX VOC CO PM10 * HAP 2020 --- --- --- --- --- --- --- 2012 0.0200 --- 1.32 0.0300 0.2000 0.0200 0.3870 * Highest HAP Emitted (in pounds) Five Year Violation History: Date Letter Type Rule Violated Violation Resolution Date 01/27/2021 NOV Part 63 - NESHAP/MACT Subpart ZZZZ Stationary Reciprocating Internal Combustion Engines 01/27/2021 Performed Stack Tests since last FCE: Date Test Results Test Method(s) Source(s) Tested 09/09/2022 Compliance Method 10, Method 3A ES-GEN1 Location: From WaRO take Clarks Neck Road and at the stop sign turn left onto Grimesland Bridge Road. At the stop sign in Grimesland make a right onto Highway 33, Pitt Street. Turn left onto Chicod Street (second street on the left). Just before entering Black Jack turn left onto VOA Site B Road. The entrance to the facility is on your left. If you come to a stop sign you have gone too far. Call for access on the telephone provided at the gate and check in with the front desk. Facility Safety: Steel toe shoes and ear protection are recommended Facility Summary: This facility is commonly referred to as Voice of America (VOA) Greenville Transmitting Station – Site B. VOA is an international public broadcasting station operating as part of the U.S. Agency for Global Media (USAGM) and International Broadcasting Bureau (IBB). Sources: Emission Source ID Emission Source Description Control System ID Control System Description ES-GEN1 NESHAP ZZZZ 2000 kW diesel-fired peak shaving/emergency generator (2947 HP; 18.81 mil Btu/hr max firing rate) N/A N/A Inspection Observations/Results: On 8/14/2023, I, Yongcheng Chen conducted a Full Compliance Evaluation (FCE) with the assistance of Rick Williford, Program Support Specialist. Mr. Williford stated that no changes have been made since the time of last inspection and he provided me with the generator CEMS runtime test log from January 202 2 to December 2022. The CEMS is tested weekly whenever possible and the temperature and pressure drop is recorded. Mr. Williford showed me the generator and it appeared well maintained. It was not running at the time of inspection and I observed the hour meter at 2,290 hours. It was previously tested September 9, 2022 by Environmental Source Samplers (ESS) and the results are reviewed and approved January 6, 2023. REGULATORY REVIEW: 2D .0516 – “Sulfur Dioxide Emissions from Combustion Sources” Sulfur dioxide emissions from shall not exceed 2.3 pounds per million Btu heat input. The worst-case sulfur dioxide emissions coming from burning No. 2 fuel oil are about 0.6 lb/MMBtu. Compliance is indicated. 2D .0521 – “Control of Visible Emissions” Visible emissions (VE) from permitted sources shall not be more than 20% opacity when averaged over a six -minute period. The engine was not running at the time of inspection so no VE was observed. No complaints regarding VE have been received sin ce the time of last inspection. Compliance is indicated. 2D .0535 – “Excess Emissions Reporting and Malfunctions” There were no indications of equipment malfunctions that would result in excessive emissions requiring more than four hours t o repair. No such reports have been submitted since the time of last inspection. Compliance is indicated. 2D .0540 – “Particulates from Fugitive Dust Emission Sources” “Fugitive dust emissions” means particulate matter from process operations that does not pass through a stack or vent and that is generated within plant property boundaries from activities such as: unloading and loading areas, process areas stockpiles, st ock pile working, plant parking lots, and plant roads (including access roads and haul roads). No fugitive dust emissions were observed and no complaints regarding fugitive dust have been received since the time of last inspection. Compliance is indicated. 2D .1111 – “Maximum Achievable Control Technology” The Permittee shall comply with all applicable provisions, including the notification, testing, recordkeeping, reporting, and mon itoring requirements contained in Environmental Management Commission Standard 15A NCAC 2D .1111, "Maximum Achievable Control Technology" as promulgated in 40 CFR 63, Subpart ZZZZ, "National Emissions Standards for Hazardous Air Pollutants for Station ary Reciprocating Internal Combustion Engines", including Subpart A "General Provisions." Testing and Initial Compliance Demonstration The facility has one existing 2000 KW diesel-fired, peak shaving/emergency generator (2,947 HP, 18.81 Million Btu per hour maximum firing rate) therefore the engine must comply with the emission limit r equirements in 40 CFR 63.6603. For compliance the facility elected to install a diesel oxidation catalyst system with a closed loop crankcase ventilation system and an electronic data logger/ CPMS. Initial testing with the catalytic oxidizer was completed by MEC Entec Services on December 9, 2013. The test was accepted by the Stationary Source Compliance Branch (SSCB) on September 17, 2014. Operating Requirements The facility must minimize the engine’s time spent at idle during startup and minimize the engine’s startup time to a period for appropriate and safe loading of the engine. The engine must be equipped with a closed crankcase ventilation system or approved equivalent. The manufacturer’s maintenance requirements for operating and maintaining the ventilation system must be followed and the diesel fuel used must meet the requirements of 40 CFR 80.510(b). The facility has installed a closed crankcase ventilation system and uses diesel fuel that meet s the applicable requirements. The facility has stated that they will minimize the engine’s time spent at idle and that operation and maintenance of the ventila tion system will be done in accordance with the manufacturer’s requirements. Monitoring Requirements The catalyst must be maintained so that the pressure drop across the catalyst does not change by more than 2 inches of water from the pressure drop that was measured during the initial perf ormance test. Temperature of the exhaust must be maintained so that the inlet temperature is greater than or equal to 450°F and less than or equal to 1350°F. The installation of a CPMS requires the facility to prepare a site-specific monitoring plan that addresses the monitoring system design, data collection, and the quality assurance and quality control elements outlined in 40 CFR 63.6625(b). Records review indicates that the facility collects pressure and temperature data. The site -specific monitoring plan was completed April 1, 2015 and was available for review. Continuous Compliance Demonstration The facility must conduct a performance test to ensure that the emissions remain at or below the CO concentration every 8,760 hours or 3 years, whichever comes first. The inlet temperature data must be collected, reduced to 4-hour rolling averages, and maintained within the operational limits. The pressure drop must be measured once per month and maintained within the operational limits. The CEMS collects and stores the required temperature and pressure data and records review indicates that the facility performs weekly checks of their CEMS, including temperature and pressure drop . The initial performance test was completed on December 9, 2013 and records review shows that the most recent test was done by Environmental Source Samplers, Inc. on September 9, 2022. That test result was reviewed and approved by Stationary Source Compliance Branch (SSCB). Recordkeeping Requirements For a minimum of two years the facility shall maintain records of the total monthly fuel consumption and total monthly operating hours. For a minimum of five years the facility shall maintain the following records: 1. A copy of each notification and report submitted to comply with 40 CFR 63 Subpart ZZZZ 2. Occurrence and duration of each malfunction of operation 3. Performance tests and evaluations 4. All required maintenance performed 5. Actions taken during periods of malfunction to minimize emissions 6. All records to show continuous compliance 7. All records, previous site-specific monitoring plans, and alternative relative accuracy test requests for the CPMS All records are being kept as required and were available for review. The generator ran for 108 operating hours and burned 6,020 gallons of fuel in 2022. Compliance is indicated. Reporting Requirements Within 60 days of a performance test the facility must submit a Notification of Compliance Status (NOCS). They must also submit semi-annual reports by January 31 and July 31 of each calendar year for the preceding six-month period noting malfunctions and deviations from the Permit. The facility is current with semi-annual reporting; the most recent report was received on 7/13/2023. 112(r) APPLICABILITY: The facility does not store applicable volumes of 112(r) materials . 5 YEAR COMPLIANCE HISTORY: The facility received a Notice of Violation (NOV) on January 27, 2021 for a late ZZZZ test report. CONCLUSIONS, COMMENTS AND RECOMMENDATIONS: The facility appeared to operate in compliance with all applicable air quality regulations and permit conditions at the time of inspection.