AQ_F_0400050_20190529_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: 05/31/2019
Facility Data Permit Data
NCEMC -Anson Plant Permit 09492/T08
749 Blewett Falls Road Issued 12/21/2015
Lilesville,NC 28091 Expires 11/30/2020
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)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Shawn Fowler John Cook Khalil Porter NSPS: Subpart KKKK
Manager,Combustion Vice President,Asset Environmental Scientist
Turbine Generation Management [phone]
[phone] [phone]
Compliance Data
Comments: �lki
Inspection Date 05/29/2019
Inspector's Name Gregory Reeves
Inspector's Signature: Operating Status Operating
Compliance Code Compliance- inspection
Action Code FCE
Date of Signature: D�13��0/J� On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2017 5.16 --- 85.82 11.44 98.41 5.16 1341.98
2016 6.65 --- 112.22 15.56 136.21 6.65 1843.31
2015 4.83 --- 92.12 10.03 82.71 4.83 1163.67
* Highest HAP Emitted(inpounds)
Five 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.
II. 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.
III.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 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.
IV. INSPECTION SUMMARY:
On Wednesday 5/29/19,Abdul Kadir and I, Greg Reeves 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 showed us the
facility's current permit and reviewed the FacFinder,where he found that no changes were
needed. Mr. Fowler provided all records 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.

NCEMC—Anson Plant
Compliance Inspection Report
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After reviewing the records, we proceeded outside and inspected the interior of one of the twelve
turbines which is not usually possible for a state inspector, due to their frequent use. Mr. Fowler
explained the individual components and the operational aspects of the facility.
V. PERMITTED EMISSION SOURCES:
Emission e Control Device
Source ID Description IUD
Control Device Description
Emissions Sourc
No.
ES-IA and ES-1B, CD-IA, CD-1B Twelve Pratt& Whitney FT8 Swift-Pac
ES-2A and ES-213, CD-2A, CD-213 simple-cycle gas turbines(300 million
ES-3A and ES-313, CD-3A, CD-313 Btu per hour nominal heat input capacity
ES-4A and ES-413, CD-4A, CD-4B when firing natural gas, and 281 million
All ES-5A and ES-513, CD-5A, CD-513 Btu per hour nominal heat input capacity
ES-6A and ES-613 CD-6A, CD-613 when firing No. 2 fuel oil (<0.002%
sulfur by wt),each)and one generator per
(NSPS, Subpart KKKK; pair of turbines
PSD) NOT OPERATING
Insignificant Activities per 15A NCAC 2Q .0503(8):
C ID Nos. Emission Source Description
IES 11
NOT One natural gas fired heater for warming up pipeline natural gas used in combustion
OPERATING turbines
IES 12
OPERATING One 500,000 gallon No. 2 fuel oil storage tank
IES-13
OPERATING One 500,000 gallon No. 2 fuel oil storage tank
VI. PERMIT CONDITIONS& LIMITATIONS:
A. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS—Subject sources: twelve
turbines (ID Nos. ES-1 A 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 COMPLIANCE—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% limit. The turbines were not operating during the
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-IA and B through ES-6A and B).
a. The permittee shall comply with the notification,testing,recordkeeping, and monitoring
requirements for SO2.The SO2 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 IN COMPLAINCE—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 sulfur 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 6.5 ppm sulfur in Tank#1 and 6.1 ppm sulfur in Tank 92.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 1/23/19 and appeared complete.
b. The permittee shall comply with the notification,testing, recordkeeping, and monitoring
requirements for NOx.The maximum NOx emission limits are 25 ppm at 15%02 when
firing NG and 74 ppm at 15% 02 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 6.5% during the past year. The highest 1-year
capacity factor of any turbine was 14%. 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 tentatively planned for 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 of NOx 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 1/23/19 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-IA 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(S/=0.002% S)annually,not including
startup/shutdown time.
APPEARED IN COMPLIANCE—The highest 12-month rolling total CO emissions during the
past year was 201.64 tons. The highest 12-month rolling total runtime on natural gas during the past
year was 113.44 hours. The highest 12-month rolling total runtime on No.2 fuel oil during the past
year was 85.25 hours. CO emissions are calculated based on predictive monitoring based on stack
testing of the turbines.
D. 15A NCAC 2Q.0317 PSD AVOIDANCE—Subject sources:twelve turbines(ID Nos. ES-1 A 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 KKKK (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 startup/shutdowns and calculated
daily/monthly/12-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 198.48 tons. The most recent
semi-annual report was received on 01/23/19 and appeared complete.
E. 15A NCAC 2Q.0400:PHASE H ACID RAIN REQUIREMENTS—Subject sources:twelve
turbines(ID Nos. ES-IA 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 IN COMPLIANCE—EPA's Air Markets Program Data website shows the facility
held an allowance of 29 tons of S02 at the beginning of 2018 and reported emissions of"0"tons of
S02 at the end of 2018. They carried over an allowance of 29 tons for 2019.
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.
a. 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 185 tons
NOx at the beginning of 2016 and reported emissions of 178 tons of NOx at the end of 2018.
They carried over an allowance of 7 tons NOx into 2019.

NCEMC—Anson Plant
Compliance Inspection Report
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b. 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.
c. 40 CFR 97 Subpart 5C—GROUP 1 TRADING PROGRAM — S02
APPEARED IN COMPLIANCE — The facility participates in the S02 Group 1 Trading
program. According to EPA's Air Markets Program Data website, "0" S02 allowances were
used in 2018, and the facility had"0" S02 allowances available for trading at the end of 2018.
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
emission/malfunction 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 2/11/19 and
appeared to be complete.
1. PERMIT GENERAL CONDITION X—ANNUAL EMISSION INVENTORY
REQUIREMENTS—Facility shall submit an Annual Emission Inventory postmarked on or
before June 30'of each year.
APPEARED IN COMPLIANCE — The facility's 2017 AQEI was received on 04/26/18 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.

NCEMC—Anson Plant
Compliance Inspection Report
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L. NON-COMPLIANCE HISTORY SINCE 2010:
There have been no instances of non-compliance at this facility since 2010.
M. COMPLIANCE STATEMENT AND RECOMMENDATION:
During the compliance inspection conducted on 05/29/19, NCEMC - Anson Plant APPEARED IN
COMPLIANCE with the requirements outlined in their current air permit
PINK SHEET ITEMS:
No additional comments.
/gwr