AQ_F_0400050_20200825_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY NCEMC-Anson Plant
NC Facility ID 0400050
Inspection Report County/FIPS:Anson/007
Date: 09/08/2020
Facility Data Permit Data
NCEMC-Anson Plant Permit 09492/T09
749 Blewett Falls Road Issued 7/14/2020
Lilesville,NC 28091 Expires 6/30/2025
Lat: 34d 58.0837m Long:79d 55.3361m Class/Status Title V
SIC: 4911 /Electric Services Permit Status Active
NAICS: 221112/Fossil Fuel Electric Power Generation Current Permit Application(s)TV-Reopen for
Cause
Contact Data
Facility Contact Authorized Contact Technical Contact Program.Applicability
Shawn Fowler John Cook Khalil Porter SIP/Title V
NSPS: Subpart KKKK
Manager,Combustion VP,Asset Management Environmental Scientist
Turbine Generation [phone] [phone]
[phone]
Compliance Data
Comments:
Inspection Date 08/25/2020
Inspector's Name Evangelyn Lowery-Jacobs
Inspector's Signature, Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: 0?10E3 f-7vLo On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2019 2.70 --- 48.86 6.98 59.21 2.70 750.92
2018 11.04 --- 177.02 22.70 195.99 11.04 2767.89
2017 5.16 --- 85.82 11.44 98.41 5.16 1341.98
*HjEjiest HAP Emitted(inpounds)
Fsve Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

NCEMC—Anson Plant
Compliance Inspection Report
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I. DIRECTIONS-
From FRO take 401 S.to Wagram. Turn right on Old Wire Road(NC 144)just south of Wagram.
Drive approximately 12.2 miles,then turn right onto Highway 74. Drive approximately 23.5 miles.
Just after crossing the Pee Dee River,turn right onto Power Plant Road. Drive approximately 2
miles,then turn left onto Blewett Falls Road. Drive approximately 2.5 miles. The facility will be on
the right.
H. SAFETY CONSIDERATIONS:
Typical FRO safety gear is required, including safety shoes, safety glasses,hardhat, and hearing
protection. Do not open any doors and do not touch any plumbing while the turbine is in operation.
111. FACILITY/PROCESS DESCRIPTION:
This facility has six simple-cycle,natural gas-fired(low sulfur No.2 fuel oil backup)Pratt and
Whitney FT-8 Swift-Pac 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. Each of the six units consists of two turbines,each equipped with water
injection,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 control is demineralized water injection to control NOx. "Simple cycle gas turbine"
means any stationary gas turbine that 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 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 chooses to use a predictive emission monitor system(PEM)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.
1V. INSPECTION SUMMARY:
On Tuesday 08/25/2020,I,Evangelyn Lowery-Jacobs of DAQ FRO,met with Mr. Shawn Fowler,
plant manager at the Anson facility to conduct an air quality compliance inspection,consisting of a
records review. The facility was not operating at the time of the inspection but was expected to be
operating later in the day as the temperatures rose. Mr.Fowler proposed a tour of the facility to get
an overview of operations. We proceeded outside and inspected the interior of one of the twelve
turbines,while not in use. Mr. Fowler explained the individual components and the operational
aspects of the facility,before returning to the office building for records review.

NCEMC-Anson Plant
Compliance Inspection Report
Page 3 of 7
Mr.Fowler provided a copy of the facility's current permit and reviewed the FacFinder,which was
accurate and required no changes. All records were readily available for review,as required by the
permit. Note that all twelve turbines(six gen sets)are under contract with Duke/Progress Energy and
are all run as close to equal time as possible,in order to maintain their"peaking" status for federal
rule applicability.
V. PERMITTED EMISSION SOURCES:
Emission - 1 Control Device -
Source Emissions Source Description ID No. Control Device Description
ID No.
-y - -
ES-tA and ES-1B, CD-lA,CD-IB Twelve Pratt& Whitne FT8 Swift-Pac
ES-2A and ES-2B, CD-2A, CD-2" simple-cycle gas turbines(300 million Btu j
ES-3A and ES-3B, CD-3A,CD-3B i per hour nominal heat input capacitywhen 1
ES-4A and ES-413, CD-4A,CD-4B firing natural gas, and 281 million Btu per
All j ES-5A and ES-511, CD-5A,CD-5B hour nominal heat input capacity when
ES-6A and ES-6B CD-6A,CB-6B firing No.2 fuel oil(5 0.002% sulfur by
wt), each)and one generator per pair of
(NSPS,Subpart KKKK;PSD) turbines
NOT OPERATING
Insignificant Activities per 15A NCAC 2Q.0503(8):
ID Nos Emission Source Description
-. _ - - --- -- gas-fired- - - - -- PPP g ._. _ _.
IES-f l j One natural heater for warmingu pipeline natural as used in
NOT OPERATING combustion turbines
OPERATING One 500,000 gallon No 2 fuel oil storage tank
----- ------ _:--
I
OPERATING One 500,000 gallon No. 2 fuel oil storage tank
Vt. PERMIT CONDITIONS&LIMITATIONS:
A. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS-Subject sources:twelve
turbines(ID Nos.ES-IA and B through ES-6A and B). VE is limited to 20%opacity for each
turbine when averaged over a six-minute period,except during startup, shutdown and
malfunctions.However, six-minute averaging periods may exceed 20 percent not more than once
in any hour and not more than four times in any 24-hour period. In no event shall the six-minute
average exceed 87 percent opacity.
APPEARED IN COMPLL4NCE-The facility combusts primarily natural gas, and it combusts
No. 2 fuel oil only as a backup. Both of these fuels are clean burning, so the opacity should
always be in compliance with the 20%opacity limit The turbines were not operating during the
time of inspection.

NCEMC—Anson Plant
Compliance Inspection Report
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B. 15A NCAC 2D.0524: NSPS,40 CFR PART 60,SUBPART KKKK—Subject sources: twelve
turbines(ID Nos.ES-lA and B through ES-6A and B).
i. The permittee shall comply with the notification,testing,recordkeeping, and monitoring
requirements for S02.The SOZ emission limit can be met by demonstrating that the sulfur
content is less than 0.05%in the No.2 fuel oil used and less than 20 grains per 100 scf in the
natural gas.A semi-annual summary report is required, including deviation report and
excess emission/monitor downtime/startup, shutdown,and malfunction report.
APPEARED INCOMPLAINCE—The facility initially demonstrated compliance with the
NSPS limits based on source tests that were reviewed and approved by the Raleigh Central
Office. Fuel oil suour content is determined by representative sampling after adding loads
to the storage tank, in accordance with 40 CFR Part 75 Appendix D Section 2.2.4.2. In
addition, quarterly sampling is conducted whether fuel oil has been received or not. The
most recent analysis shows 6.7 ppm su fux in Tank#1 and 9.9 ppm suer in Tank Q. The
NG sulfur content is guaranteed to be less than 20 grains per 100 scf by the current contract
with Piedmont Natural Gas. The most recent semi-annual and excess emissions/monitor
downtime report was received on 0712312020 and appeared complete.
I The permittee shall comply with the notification,testing,recordkeeping,and monitoring
requirements for NOx. The maximum NOx emission limits are 25 ppm at 15%OZ when
firing NG and 74 ppm at 15%OZ when firing No.2 fuel oil;The permittee can demonstrate
compliance using the NOx emission estimation following 40 CFR Part 75 Appendix E,
including re-certifying NOx emissions rate versus heat input rate correlation curve every 5
years.The permittee must demonstrate"peaking"status using the average capacity factor of
no more than 10%during three previous calendar years and no more than 20%during each
of those individual years. The permittee must keep records for the following: hourly records
of time, load to unit, fuel flow rate, heat input,and hourly calculated NOx emissions. The
permittee shall submit semi-annual excess emissions/monitor downtime reports for all
periods including startup, shutdown,and malfunction.
APPEARED IN COMPLIANCE—The facility was not operating during the inspection.
Records show that each turbine is maintaining its `peaking"status with the highest three-
year average capacity factor of any turbine being 5.9%during the past year. The highest 1-
year capacity factor of any turbine was 1.9916. The facility chooses to use a Predictive
Emissions Monitoring System (PEMS) that uses a water-to-fuel ratio curve, which is
established via testing at least every 5 years (last test was conducted in 2018) to predict
hourly NOx emissions. The fuel and water flow meters were last calibrated in September
2015 and are re-calibrated at least every 5 years (depending on capacity used per turbine,
quarterly)so the next calibration is scheduled for mid-September 2020. The PEMS
activates an alarm if NOx emissions exceed 25/74 ppm(gas/oil)for more than 60 seconds
(once water flow is established) and if at 720 seconds the emissions still exceed then the unit
automatically shuts down in order to avoid exceeding the NOx limit for the rolling 240-
minute period. There have been no periods ofNOx emissions exceeding the established
limits since the last inspection. The most recent semi-annual summary/deviation report and
excess emission/monitor downtime report was received on 0712312020 and appeared
complete.

NCEMC—Anson Plant
Compliance Inspection Report
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C. 15A NCAC 2D.0530 PREVENTION OF SIGNIFICANT DETERIORATION—Subject
sources:twelve turbines(ID Nos.ES-lA and B through ES-6A and B). CO total emissions shall
not exceed 405.5 tons per consecutive 12-month period. Each unit shall not exceed 1,230 hrs run
time on natural gas or 710 hrs run time on No. 2 fuel oil(d=0.002% S)annually,not including
startup/shutdown time. Semi-annual reporting of hours of operation when firing natural gas and
No.2 fuel oil on a monthly and rolling 12-month total is required.
APPEARED IN COMPLIANCE—The highest 12-month rolling total CO emissions during the past
year was 183.96 tons. The highest 12-month rolling total runtime on natural gas during the past
year was 614.43 hours, which was due to extremely cold temperatures in early 2019. The highest
12-month rolling total runtime on No. 2 fuel oil during the past year was 4.06 hours. CO emissions
are calculated based on predictive monitoring based on stack testing of the turbines. The most
recent semi-annual report was received on 0712312020 and appeared complete.
D. 15A NCAC 2Q.0317 PSD AVOIDANCE—Subject sources:twelve turbines(ID Nos.ES-lA and
B through ES-6A and B). The NOx limit is 245 tons per consecutive 12-month period. The
permittee must record the number of startup/shutdowns per day and monitor NOx emissions in
accordance with 40 CFR Part 60 Subpart IW"K(item B,above). The permittee must calculate
NOx emissions from each turbine daily(including start-up and shut-down and daily load),and
calculate combined NOx emissions from all turbines monthly and on a 12-month rolling basis.
Semi-annual reporting of monthly and 12-month rolling total NOx emissions is required.
APPEARED IN COMPLIANCE—Daily records of startuplshutdowns and calculated
daily/monthly112-month rolling total NOx emissions per turbine appeared valid and complete. NOx
emissions are calculated using predictive monitoring based on stack testing of the turbines. The
highest 12-month rolling total NOx emissions during the past year was 113.41 tons. The mast recent
semi-annual report was received on 0712312020 and appeared complete.
E. 15A NCAC 2Q.0400:PHASE 11 ACID RAIN REQUIREMENTS—Subject sources: twelve
turbines(ID Nos.ES-1A and B through ES-6A and B). There are no specified S02 Allowance
Allocations under this rule. The DAQ allocates tons of S02 allowances from a general fund for
new sources.
APPEARED 17V COMPLIANCE—EPA's Air Markets Program Data website shows the facility
held an allowance of"0"tons of SO2 at the beginning of 2019 and reported emissions of"0"tons of
S02 at the end of 2019. They carried over an allowance of"0"tons for 2020.
F. CROSS STATE AIR POLLUTION RULES(CSAPR)PERMIT REQUIREMENTS—The
permittee shall comply with all applicable requirements of 40 CFR 97 Subparts 5A, 513,and 5C.
i. 40 CFR 97 Subpart 5A—ANNUAL TRADING PROGRAM—NOx
APPEARED IN COMPLIANCE—The facility participates in the NOx Trading program.
According to EPA's Air Markets Program Data website, they held an allowance of 155 tons
NOx at the beginning of 2019 and reported emissions of 22 tons of NOx at the end of 2019.
They carried over an allowance of 133 tons NOx into 2020.

NCEMC—Anson Plant
Compliance Inspection Report
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ii. 40 CFR 97 Subpart 5B—OZONE SEASON TRADING PROGRAM—NOx
APPEARED IN COMPLIANCE—The facility no longer participates in NOx trading
during ozone season as the entire State is now listed as in attainment.
iii. 40 CFR 97 Subpart 5C—GROUP 1 TRADING PROGRAM—SOz
APPEARED IN COMPLIANCE—The facility participates in the SOz Group I Trading
program. According to EPA's Air Markets Program Data website, "0"SOz allowances
were used in 2019, and the facility had "0"SOz allowances available for trading at the
end of 2019.
G. PERMIT GENERAL CONDITION LA and LB REPORTING REQUIREMENTS FOR
EXCESS EMISSIONS AND PERMIT DEVIATIONS—The facility is required to report excess
emission events and malfunctions that last more than 4 hours per the requirements of 15A NCAC
2D .0535.
APPEARED IN COMPLIANCE—Mr. Fowler indicated that the facility has had no excess
emissionlmalfunction events and therefore no notification has been required.
H. PERMIT GENERAL CONDITION P—COMPLIANCE CERTIFICATION
REQUIREMENT: The facility is required to submit an Annual Compliance Certification
(ACC) report postmarked before March 1 of each year,stating compliance with all permit
conditions or noting any deviations during the previous calendar year.
APPEARED IN COMPLIANCE—The most recent ACC report was received on 211712020 and
appeared to be complete.
L PERMIT GENERAL CONDITION X—ANNUAL EMISSION INVENTORY
REQUIREMENTS Facility shall submit an Annual Emission Inventory postmarked on or
before June 30th of each year.
APPEARED IN COMPLIANCE—The facility's 2019 AQEI was received on 0 413 012 02 0 and
appeared to be complete and accurate.
J. PERMIT GENERAL CONDITION DD—PREVENTION OF ACCIDENTAL RELEASES—
SECTION 112(r)-The facility does not store any of the listed chemicals in amounts that exceed
the threshold quantities. Therefore,they are not required to maintain a written Risk Management
Plan(RMP).
K. PERMIT GENERAL CONDITION MM—FUGITIVE DUST CONTROL
REQUIREMENT—The Permittee shall not cause of allow fugitive dust emissions to cause or
contribute to substantive complaints or excess visible emissions beyond the property boundary.
APPEARED IN COMPLIANCE—Mr. Fowler stated that no dust complaints had been received
by the facility, and FRO has not received any dust complaints.
VI. NON-COMPLLANCE HISTORY SINCE 2010:
There have been no instances of non-compliance at this facility since 2010.

NCEMC—Anson Plant
Compliance Inspection Report
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VIII. COMPLIANCE STATEMENT AND RECOMMENDATION:
The NCEMC -Anson Plant appeared to be operating IN COMPLIANCE with their air quality
permit at the time of inspection on 08/25/2020.
IX. PINK SHEET ITEMS:
No additional comments.
/elj