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HomeMy WebLinkAboutAQ_F_1900134_20191022_CMPL_InspRpt Uv J"V NORTH CAROLINA DIVISION OF Raleigh Regional Office AIR QUALITY Duke Energy Progress,LLC-Cape Fear STAR Facility Inspection Report NC Facility ID 1900134 Date: 10/29/2019 County/FIPS: Chatham/037 Facility Data Permit Data Duke Energy Progress,LLC-Cape Fear STAR Facility Permit 10583/R00 500 C P and L Road Issued 6/5/2019 Moncure,NC 27559 Expires 5/31/2027 Lat: 35d 35.2740m Long: 79d 1.9986m 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 Steven Conner Jon Kerin Ann Quillian Senior Environmental VP CCP Gov. &Op. Lead Environmental Specialist Support Specialist (336)597-6213 (919)546-6760 (919)546-6610 Compliance Data Comments: In compliance by—default due to construction. Inspection Date 10/22/2019 Inspector's Name Elisabeth Nystrom Inspector's Signature: Operating Status Operating Compliance Code Compliance-inspection Action Code FCE Date of Signature: 11 j ! On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP No emissions inventory on record.The emissions inventory is due June 30th of every year. *Highest HAP Emitted(in ounds) Five Year Violation History:None Date Letter TVAe Rule Violated Violation Resolution Date Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested (1) DIRECTIONS TO FACILITY: From RRO take I-440 W inner beltline toward US-1 S. Keep left to continue on US-1 S. Continue on US-1 S for 18 miles and take exit 84 towards Old US-1.Turn right onto State Road 1011/Old US-1 and continue straight for 3.5 miles. Turn left onto Corinth Road and continue for 1.5 miles. Turn right onto C P and L road. In 0.2 miles, the destination is on the left. (In FACILITY DESCRIPTION: Duke Energy Progress, LLC— Cape Fear STAR Facility is located at the site of the former Cape Fear Steam Electric Plant in Moncure, Chatham County, North Carolina. The facility is owned by Duke Energy, but low-NOx startup burners controlled by a FGD scrubber(ID No.CD-5A)and a baghouse(ID No.CD-513). 1. 15A NCAC 02D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES: Testing[15A NCAC 02Q.0308(a)] b.Testing shall be performed in accordance with General Condition 17 and with a testing protocol approved by the DAQ. Testing shall be completed within 90 days of initial startup' of the reactor (ID No.ES-5). The final air emission test report shall be submitted to the DAQ not later than 30 days after sample collection,in accordance with 15A NCAC 02D .2602(h). Monitorine/RecordkeeainE[15ANCAC 02Q.0308(a)] c. Particulate matter emissions from this source(ID No.ES-5)shall be controlled by a bagfilter (ID No.CD-5B). To ensure compliance,the Permittee shall perform inspections and maintenance as recommended by the manufacturer. In addition to the manufacturer's inspection and maintenance recommendations,or if there are no manufacturer's inspection and maintenance recommendations,as a minimum,the inspection and maintenance requirement shall include the following: i. a monthly visual inspection of the system ductwork and material collection unit for leaks; ii. a monthly reading of the pressure gauges on the bagfilter(ID Nos.CD-513);and ii. an annual(for each 12-month period following the initial inspection)internal inspection of the bagfilter structural,noting the structural integrity and the condition of the filters. d. The results of inspection and maintenance shall be maintained in a logbook(written or electronic format)on-site and made available to an authorized representative upon request. The logbook shall record the following: i. the date and time of each recorded action; ii. the results of each inspection; iii. the results of any maintenance performed on any control device;and iv. any variance from manufacturer's recommendations,if any,and corrections made. Reporting[15A NCAC 02Q.0308(a)] e. The Permittee shall submit the results of any maintenance performed on any control device within 30 days of a written request by the DAQ. Compliance with these stipulations will be determined when the facility begins operation in 2020. 2. 15A NCAC 02D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES: Monitorina/Recordkeeping[15A NCAC 02Q.0308(a), 15A NCAC 02D .0605, 15A NCAC 02D.0611, 15A NCAC 02D.0613] c.The Permittee shall operate the FGD scrubber(ID No.CD-5A)at any time the reactor is in operation other than during startup,shutdown or malfunction. d.To ensure compliance,the Permittee shall install a sulfur dioxide continuous emissions monitoring(CEM)system including any required diluent monitor system with the following requirements: i.The CEM system shall be installed,calibrated,maintained,tested,and operated in accordance with 40 CFR Part 60,Appendix B. ii.Compliance with the sulfur dioxide emission standard shall be demonstrated based on a three-hour rolling average of the sulfur dioxide exhaust gas concentration measured by the CEM system. iii. Pursuant to 15A NCAC 02D .0613 "Quality Assurance Program,"the Permittee shall develop and implement a written quality assurance program containing information required by 40 CFR Part 60,Appendix F, Section 3,Quality Assurance Procedures. Reporting[15ANCAC 02Q.0308(a)] e.The Permittee shall submit the results of any maintenance performed on any control device within 30 days of a written request by the DAQ. Compliance with these stipulations will be determined when the facility begins operation in 2020. 5. NCGS 143-215.108: CONTROL OF SOURCES OF AIR POLLUTION; PERMITS REQUIRED: Under the provisions of NCGS 143-215.108,the Permittee shall verify the NOx emission factor specified in Permit Application No. 1900134.18A by testing the reactor(ID No.ES-5)for NOx emissions. Testing shall be performed in accordance with General Condition 17 and with a testing protocol approved by the DAQ. Testing shall be completed within 90 days of initial startup'-of the reactor(ID No.ES-5). The final air emission test report shall be submitted to the DAQ not later than 30 days after sample collection,in accordance with 15A NCAC 02D .2602(h). Compliance with these stipulations will be determined when the facility begins operation in 2020. B. FGD byproduct silo(ID No.ES-6)with bin vent filter(ID No.CD-6); FGD hydrate lime silo (ID No.ES- 7)with bin vent filter(ID No.CD-7);Two external heat exchangers A and B(ID Nos.ES-8 and ES-9) with baghouses(ID Nos.CD-8 and CD-9); Product storage dome(ID No.ES-11)with bin vent filter(ID No.CD-11). 1. 15A NCAC 02D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES Testing[15A NCAC 02Q.0308(a)] b .Under the provisions of NCGS 143-215.108,the Permittee shall demonstrate compliance with the emission limit above by testing either external heat exchangers A or B(ID Nos.ES-8 or ES-9)for particulate emissions. Testing shall be performed in accordance with General Condition 17 and with a testing protocol approved by the DAQ. Testing shall be completed within 90 days of initial startup'of either source(ID Nos.ES-8 or ES-9). The final air emission test report shall be submitted to the DAQ not later than 30 days after sample collection,in accordance with 15A NCAC 02D.2602(h). Monitoring/Recordkeeping[15A NCAC 02Q .0308(a)] c.Particulate matter emissions from these sources(ID Nos.ES-6,ES-7,and ES-11)shall each be controlled by a bin vent filter(ID Nos.CD-6,CD-7,and CD-11)and particulate matter emissions from these sources(ID Nos.ES-8 and ES-9)shall each be controlled by a bagfilter(ID Nos.CD- 8 and CD-9)as described above. To ensure compliance,the Permittee shall perform inspections and maintenance as recommended by the manufacturer. In addition to the manufacturer's inspection and maintenance recommendations,or if there are no manufacturer's inspection and maintenance recommendations,as a minimum,the inspection and maintenance requirement shall include the following: i. a monthly visual inspection of the system ductwork and material collection unit for leaks; ii. monthly reading of the pressure gauges on the bagfilters(ID Nos.CD-8 and CD-9);and iii. annual(for each 12-month period following the initial inspection)internal inspection of the bagfilters(ID Nos.CD-8 and CD-9),noting the structural integrity and the condition of filters. d.The results of inspection and maintenance shall be maintained in a logbook(written or electronic format)on-site and made available to an authorized representative upon request. The logbook shall record the following: i. the date and time of each recorded action; ii. the results of each inspection; iii. the results of any maintenance performed on any control device;and iv. any variance from manufacturer's recommendations,if any,and corrections made. Reporting[15A NCAC 02Q .0308(a)] e.The Permittee shall submit the results of any maintenance performed on any control device within 30 days of a written request by the DAQ. Compliance with these stipulations will be determined when the facility begins operation in 2020. Compliance Requirements g.The Permittee shall: i. operate and maintain the engines and control devices according to the manufacturer's emission related-written instructions over the entire life of the engine; ii. change only those emission-related settings that are permitted by the manufacturer;and iii. meet the requirements of 40 CFR 89,94 and/or 1068 as applicable. [40 CFR 60.4206 and 60.4211(a)] h.The Permittee shall comply with the emission standards in Section 2.1 C.3.c by purchasing an engine certified to the emission standards in Section 2.1 C.3.c. The engine shall be installed and configured according to the manufacturer's emission-related specifications. [40 CFR 60.4211(c)] Recordkeeping[15ANCAC 02Q .0308(a)] i.To ensure compliance,the Permittee shall perform inspections and maintenance on the engine as recommended by the manufacturer per 40 CFR 60.4206 and 40 CFR 60.4211(a).The results of inspection and maintenance shall be maintained in a logbook(written or electronic format)on-site and made available to an authorized representative upon request. The logbook shall record the following: i. the date and time of each recorded action; ii. the results of each inspection; iii. the results of any maintenance performed on the engine; iv. any variance from manufacturer's recommendations,if any,and corrections made; v. if a PM filter is used,records of any corrective action taken after the backpressure monitor has notified the owner or operator that the high backpressure limit of the engine is approached[40 CFR 60.4214(c)];and vi. documentation from the manufacturer that the engine is certified to meet the emission standards in Section 2.1 C.3.c. Compliance with these stipulations will be determined when the facility begins operation in 2020. 4. 15A NCAC 02D.1111 MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY Applicability[40 CFR 63.6585,6590(a)(2)(iii)] a.For this source(new stationary RICE located at an area source of HAP emissions),the Permittee shall comply with all applicable provisions,including the monitoring,recordkeeping, and reporting contained in Environmental Management Commission Standard 15A NCAC 02D .I I I I "Maximum Achievable Control Technology" (MACT)as promulgated in 40 CFR 63, Subpart ZZZZ,"National Emission Standards For Hazardous Air Pollutants For Stationary Reciprocating Internal Combustion Engines"and Subpart A"General Provisions." Stationary RICE subject to Regulations under 40 CFR Part 60 b.Pursuant to 40 CFR 63.6590(c)(1),this source must meet the requirements of 40 CFR 63 Subpart ZZZZ and Subpart A by meeting the requirements of 40 CFR 60 Subpart IIII.No further requirements apply for these engines under 40 CFR 63 Subpart ZZZZ and Subpart A. Compliance with these stipulations will be determined when the facility begins operation in 2020. 2.2- Multiple Emission Source(s) A. Facility-wide affected sources 1. 15A NCAC 02D.0535 EXCESS EMISSIONS REPORTING AND MALFUNCTION As required by 15A NCAC 2D.0535,the Permittee of a source of excess emissions that last for more than four hours and that results from a malfunction,a breakdown of process or control equipment or any other abnormal conditions,shall: a. Notify the Director or his designee of any such occurrence by 9:00 a.m.Eastern time of the Division's next business day of becoming aware of the occurrence and describe: i. the name and location of the facility, ii. the nature and cause of the malfunction or breakdown, iii. the time when the malfunction or breakdown is first observed, iv. the expected duration,and 7. 15A NCAC 02Q.0504: OPTION FOR OBTAINING CONSTRUCTION AND OPERATION PERMIT a.The Permittee shall file a Title V Air Quality Permit Application pursuant to 15A NCAC 02Q.0504.to modify the construction and operation permit on or before 12 months after commencing operation of any of the sources listed in this permit. Reporting [15A NCAC 02Q .0504] b.The Permittee shall notify the Regional Office in writing of the date of beginning operation of any of the sources listed in this permit,postmarked no later than 30 days after such date. Compliance with these stipulations will be determined when the facility begins operation in 2020. (V) INSIGNIFICANT/EXEMPT ACTIVITIES: Insignificant Activities per 15A NCAC 02Q.0102(h)(5) Emission Source ID Emission Source Description I-1 Wet ash receiving(transfer to shed and hopper) I-3 Unloading pile I-4 Feed silo with a maximum 125 tons per hour filling rate and maximum 75 tons per hour unloading rate with a bin vent filter 1-10 EHE silo with a maximum 125 tons per hour filling rate and maximum 75 tons per hour unloading rate with a bin vent filter 1-12 Loadout silo with a maximum 75 tons per hour filling rate and maximum 100 tons per hour unloading rate with a bin vent filter I-13,1-14 Two truck loadout spouts,each with a bin vent filter I-15 Ash Basin I-16 Ash Handling I-19 Screener with 165 tons per hour nominal fly ash processing rate I-20 Crusher with 165 tons per hour nominal fly ash processing rate I-21 Haul Roads I-22 Screener diesel-fired engine(91 horsepower) NSPS IIH GACT ZZZZ I-24 Ball mill classifier with a process rate of 10 tons per hour,with a baghouse inherent to the process I-25 Ball mill feed silo with a maximum 15 tons per hour filling rate with a bin vent filter (VI) COMPLIANCE HISTORY: As this is a greenfield facility,no compliance history is on record with the RRO. (VH) SOURCE TEST REVIEW: Source test reviews will be analyzed when the facility begins operation in 2020. (VIM 112(r): No RMP Required—Duke Energy Progress,LLC—Cape Fear STAR Facility,is subject to the general duty clause of the Clean Air Act section 112(r), but does not store chemicals within the threshold quantity necessary to register for a risk management plan. (IX) EMISSIONS INVENTORY: There are no emissions inventories on file for this facility. (X) CONCLUSIONS/RECOMMENDATIONS: At the time of the inspection,Duke Energy Progress,LLC—Cape Fear STAR Facility,was in compliance with their air quality permit by default due to construction.It is recommended that this facility be re-inspected in one year.