AQ_F_0400050_20181029_ST_RvwLtr

ROY COOPER �qa
Governor
MICHAEL S.REGAN
Secrelary w��r
MICHAEL ABRACZINSKAS
Director
NORTH CAROLINA
Environmental Quality
29 October 2018
Mr.John Cook,Vice President,Asset Management
NCEMC Hamlet
3400 Summer Blvd.
Raleigh,NC 27616
SUBJECT: Central Office Review of Source Test Results—Gas Turbines ES-lA&B—ES-6A&B
North Carolina Electric Membership Corporation
NCEMC -Anson Plant,Air Permit 09492T08
Lilesville,NC Anson County 6/04-00050
Dear Mr. Cook:
The Division has reviewed your source test reports that were received by our Central Office on
9 July 2018. The reports were from the nitrogen oxides and carbon monoxide testing of gas turbines
ES-IA&B, 2A&B, 3A&B, 4A&B, 5A&B, and 6A&B,which were conducted from 10 through
16 May 2018. On 23 October 2018,this Division has determined that the subject testing performed at
your facility on each of those dates were acceptable source tests. The reviews indicate that compliance
with Air Permit No. 09492T08 is indicated for these sources. A copy of the determination memorandum
issued by Mr. James Hammond, of the N.C. Division of Air Quality, Stationary Source Compliance
Branch, is attached.
Should you have any questions regarding this matter, please contact Mr. Jeffrey Cole,
Environmental Engineer, at(910)433-3300, in the Fayetteville Regional Office.
Sincerely,
_ Heather S. Carter
Regional Supervisor
NCDEQ,Division of Air Quality
HSC/jdc
Attachments-DAQ RCO review 23 October 2018 [covering 2018-071 ST,2018-072ST,2018-073 ST,2018-074ST,
2018-075ST and2018-076ST]
cc: ❑ FRO Files(w/attachments)
D North Carolina Department of Environmental Quality I Division of Air Quality
Fayetteville I"lonal Office 1 225 Green Street,Suite 7141 Fayetteville,North Carolina 28301
MTitll CMIY.NA
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DIVISION OF AIR QUALITY
October 23, 2018
MEMORANDUM
To: Heather Carter, Fayetteville Regional Office
From: James E. Hammond, Stationary Source Compliance Branch(SSCB)
Subject: North Caroline Electric Membership Corporation NCEMC—Anson Plant
Lilesville, Anson County, North Carolina
Facility ID 0400050, Permit No. 09492T08
Nitrogen Oxides Emissions Testing of Unit 1 Turbines (ES-1A and ES-11B)
Performed May 15, 2018 by McHale Performance(McHale)
DAQ Tracking No. 2018-071st
McHale performed EPA Method 7E/20 nitrogen oxide (NOx) emissions testing of the Unit 1
turbines on May 15, 2018. The testing was "conducted to re=establish 40 CFR Part 75
Appendix E NOx [emission rate versus heat input correlation] curves for Anson Units 1-6 post
water injection tuning." SSCB has reviewed the test results with respect to the applicable
emissions limits as discussed below.
Unit 1 consists of two Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbines, ESAA and
ESA B, and one generator. Emissions from ES-1A and ES-1 B are controlled by water injection
system CD-1A and CD-1 B respectively. The turbines were tested at four loads for natural gas
firing and four loads for. fuel oil firing.
40 CFR 60 Subpart KKKK Standards of Performance for Stationary Gas Turbines and
15A NCAC 2Q .0317 Avoidance Conditions for 15A NCAC 2D .0530 Prevention of Significant
Deterioration (PSD)apply. 60 Subpart KKKK limits NOx emissions to 25 parts per million
corrected to 15% oxygen (ppm@15% 02)when firing natural gas and 74 ppm@15% 02 while
firing No. 2 fuel oil. In order to avoid the applicability of PSD, the permit limits NOx emissions
from ES-1A and ES-1 B through ES6-A and ES6-B to 245 tons per consecutive 12 months. The
NOx test results and emissions limits for natural gas and oil firing are presented in Tables 1
and 2, respectively.
Table 1: NOx Emissions May„2018—Natural Gas Firin
_ Water to Test Results
Test Fuel Ratio pomp15% 02 60 Subpart KKKK
Date Load 1A 1 113 ES-1A ESAB Limit, m 15%02 Compliance
5-15-18 Base 0.98 `0.98 24 24 Yes
5-15-18 83% 0.93 0.93 23 25 Yes
5-15-18 67% 0.85 0.88 24 24 25 ppm@15% 02 Yes
5-15-18 50% 0.80 0.82 24 24 1

j Heather Carter
October 23, 2018
NCEMC Anson Unit 1 —DAQ Tracking No. 2018-071 st
Page 2
Table 2: NOx Emissions May 2018—No. 2 Fuel Oil Firing
water to Test Results
Test Fuel Ratio m 15% 02 60 Subpart KKKK
Date Load 1A 1 113 ES-1A ES-1B Limit, m 15% 02 Compliance
5-15-18 Base 0.87 0.87 50 53 Yes
5-15-18 83% 0.77 0.80 50 50 74 ppm@15%Oz Yes
5-15-18 67% 0.69 0.72 52 53 Yes
5-15-18 50% 0.61 0.65 52 54 Yes
The test report included the predictive emissions monitoring curve for 40 CFR 75 Appendix E.
SSCB did not review this aspect of the NOx emissions report. Additional information about the
emissions curve data is available in the test report but is not included in this memorandum. If
you have questions regarding the results of this review, please contact me at(919)707-8412 or
[e-mail].
cc: Central Files, Anson County
]BEAM Documents- 0400050

l
DIVISION OF AIR QUALITY
October 23, 2018
MEMORANDUM
To: Heather Carter, Fayetteville Regional Office
From: James E. Hammond, Stationary Source Compliance Branch(SSCB)
Subject: North Carolina Electric Membership Corporation NCEMC—Anson Plant
Lilesville, Anson County, North Carolina
Facility ID 0400050, Permit No. 09492T08
Nitrogen Oxides Emissions Testing of Unit 2 Turbines(ES-2A and ES-28)
Performed May 14, 2018 by McHale Performance(McHale)
DAQ Tracking No. 2018-072st
McHale performed EPA Method 7E/20 nitrogen oxide(NOx)emissions testing of the Unit 2
turbines on May 14, 2018. The testing was "conducted to re-establish 40 CFR Part 75
Appendix E NOx [emission rate versus heat input correlation] curves for Anson Units 1-6 post
water injection tuning." SSCB has reviewed the test results with respect to the applicable
emissions limits as discussed below.
Unit 2 consists of two Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbines, ES-2A and
ES-26, and one generator. Emissions from ES-2A and ES-2B are controlled by water injection
system CD-2A and CD-2B respectively. The turbines were tested at four loads for natural gas
firing and four loads for fuel oil firing.
40 CFR 60 Subpart KKKK Standards of Performance for Stationary Gas Turbines and
15A NCAC 2Q .0317 Avoidance Conditions for 15A NCAC 2D .0530 Prevention of Significant
Deterioration (PSD)apply. 60 Subpart KKKK limits NOx emissions to 25 parts per million
corrected to 15% oxygen (ppm@15% 02)when firing natural gas and 74 ppm@15% 02 while
firing No. 2 fuel oil. In order to avoid the applicability of PSD, the permit limits NOx emissions
from ES-1 A and ES-1 B through ES6-A and ES6-B to 245 tons per consecutive 12 months. The
NOx test results and emissions limits for natural gas and oil firing are presented in Tables 1
and 2, respectively.
Table 1: NOx Emissions Me 2018—Natural Gas Firin
Water to Test Results
Test Fuel Ratio pm@15%02 60 Subpart KKKK
Date Load 2A " 26 ES-2A ES-26 Limit, m 15°{0 02 Com Iiance
5-14-18 Base 0,98 1.05 24 23 Yes
5-14-18 83% 0.96 0.96 24 24 Yes
&-14-18 67% 0.90 0.91 24 24 25 ppm@15% 02 Yes
5-14-18 50% 0.84 0.87 24 24 Yes

i
Heather Carter
October 23, 2018
NCEMC Anson Unit 2—DAQ Tracking No. 2018-072st
Page 2
Table 2: NOx Emissions May 2018—No. 2 Fuel Oil Firing
Water to Test Results
Test Fuel Ratio m 15% 02 60 Subpart KKKK
Date Load 2A I 2B ES-2A ES-213 Limit, m 15%02 Com fiance
5-14-18 Base 0.93 0.95 48 51 Yes
5-14-18 83% 0.90 1 0.86 49 51 Yes
° 74 ppm@15%02
5-14-18 67/0 0.82 0.79 49 52 Yes
5-14-18 50% 0.75 0.72 48 50 Yes
The test report included the predictive emissions monitoring curve for 40 CFR 75 Appendix E.
SSCB did not review this aspect of the NOx emissions report. Additional information about the
emissions curve data is available in the test report but is not included in this memorandum. If
you have questions regarding the results of this review, please contact me at(919)707-8412 or
[e-mail].
cc: Central Files,Anson County
]BEAM Documents- 0400050

DIVISION OF AIR QUALITY
October 23, 2018
MEMORANDUM
To: Heather Carter, Fayetteville Regional Office
From: James E. Hammond, Stationary Source Compliance Branch (SSCB)
Subject: North Carolina Electric Membership Corporation NCEMC—Anson Plant
Lilesville, Anson County, North Carolina
Facility ID 0400050, Permit No. 09492T08
Nitrogen Oxides Emissions Testing of Unit 3 Turbines(ES-3A and ES-36)
Performed May 13, 2018 by McHale Performance(McHale)
DAQ Tracking No. 2018-073st
McHale performed EPA Method 7Ei20 nitrogen oxide(NOx)emissions testing of the Unit 3
turbines on May 13, 2018. The testing was 'conducted to re-establish 40 CFR Part 75
Appendix E NOx [emission rate versus heat input correlation] curves for Anson Units 1-6 post
water injection tuning." SSCB has reviewed the test results with respect to the applicable
emissions limits as discussed below.
Unit 3 consists of two Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbines, ES-3A and
ES-313, and one generator. Emissions from ES-3A and ES-38 are controlled by water injection
system CD-3A and CD-313 respectively. The turbines were tested at four loads for natural gas
firing and four loads for fuel oil firing.
40 CFR 60 Subpart KKKK Standards of Performance for Stationary Gas Turbines and
15A NCAC 2Q .0317 Avoidance Conditions for 15A NCAC 2D .0530 Prevention of Significant
Deterioration(PSD)apply. 60 Subpart KKKK limits NOx emissions to 25 parts per million
corrected to 15% oxygen (ppm@15% 02)when firing natural gas and 74 ppm@15% 02 while
firing No. 2 fuel oil. In order to avoid the applicability of PSD, the permit limits NOx emissions
from ES-1A and ES-1 B through ES6-A and ES6-13 to 245 tons per consecutive 12 months. The
NOx test results and emissions limits for natural gas and oil firing are presented in Tables 1
and 2, respectively.
Table 1: NOx Emissions Ma 12u"'—Natural Gas Firing
Water to Test Results
Test Fuel Ratio m 15%02 60 Subpart KKKK
Date Load 3A 3B ES-3A ES-313 Limit, m 15% 02 Compliance
5-13-18 Base 0.99 1.03 1 23 24 Yes
5-13-18 83% 0.93 1.00 23 24 n Yes
5-13-18 67% 0.87 `0.94 24 24 25 ppm@15/o O2 Yes
5-13-18 50% 0.80 0.87 ` 24 24 Yes

1 Heather Carter
October 23, 2018
NCEMC Anson Unit 3—DAQ Tracking No. 2018-073st
Page 2
Table 2: NOx Emissions May 2018—No. 2 Fuel Oil Firing
Water to Test Results
Test Fuel Ratio m 15°/u 02 60 Subpart KKKK
Date Load 3A 3B ES-3A ES-3B Limit, m 15%02 Compliance
5-13-18 Base 0.92 10.93 48 51 Yes
III 5-13-18 83% 0.84 J 0.88 48 52 Yes
5-13-18 67% 0.77 0.82 50 51 74 ppm@15%02 Yes
5-13-18 1 50% 0.70 0.73 48 50 Yes
The test report included the predictive emissions monitoring curve for 40 CFR 75 Appendix E.
SSCB did not review this aspect of the NOx emissions report. Additional information about the
emissions curve data is available in the test report but is not included in this memorandum. If
you have questions regarding the results of this review, please contact me at(919) 707-8412 or
[e-mail].
cc: Central Files, Anson County
IBEAM Documents- 0400050

{
DIVISION OF AIR QUALITY
October 23, 2018
MEMORANDUM
To: Heather Carter, Fayetteville Regional Office
From: James E. Hammond, Stationary Source Compliance Branch(SSCB)
Subject: North Carolina Electric Membership Corporation NCEMC—Anson Plant
Lilesville, Anson County, North Carolina
Facility ID 0400050, Permit No. 09492T08
Nitrogen Oxides Emissions Testing of Unit 4 Turbines (ES-4A and ES-4B)
Performed May 12, 2018 by McHale Performance(McHale)
DAQ Tracking No. 2018-074st
McHale performed EPA Method 7E/20 nitrogen oxide(NOx)emissions testing of the Unit 4
turbines on May 12, 2018, The testing was "conducted to re-establish 40 CFR Part 75
Appendix E NOx [emission rate versus heat input correlation]curves for Anson Units 1-6 post
water injection tuning." SSCB has reviewed the test results with respect to the applicable
emissions limits as discussed below.
Unit 4 consists of two Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbines, ES-4A and
ES-413, and one generator. Emissions from ES-4A and ES-413 are controlled by water injection
system CD-4A and CD-413 respectively. The turbines were tested at four loads for natural gas
firing and four loads for.fuel oil firing.
40 CFR 60 Subpart KKKK Standards of Performance for Stationary Gas Turbines and
15A NCAC 2Q .0317 Avoidance Conditions for 15A NCAC 2D .0530 Prevention of Significant
Deterioration (PSD)apply. 60 Subpart KKKK limits NOx emissions to 25 parts per million
corrected to 15% oxygen (ppm@15% 02)when firing natural gas and 74 ppm@15% 02 while
firing No. 2 fuel oil. In order to avoid the applicability of PSD, the permit limits NOx emissions
from ES-1 A and ES-1 B through ES6-A and ES6-13 to 245 tons per consecutive 12 months. The
NOx test results and emissions limits for natural gas and oil firing are presented in Tables 1
and 2, respectively.
Table 1: NOx Emissions May 2018—Natural Gas Firing
Waterto Test Results
Test Fuel Ratio m 15% 02 60 Subpart KKKK
Date Load 4A I 4B ES-4A ES-48 Limit m 15%02 Compliance
5-12-18 Base 1.06 J 1.05 25 25 Yes
5-12-18 83% 1.05 11.02 25 24 25 L0 ppm@15°% 02 Yes
5-12- 88 67M, 2 0.98 24 24 Yes
5-12-18 50% 0.96 0.91 25 24 Yes

Heather Carter
October 23, 2018
NCEMC Anson Unit 4—DAQ Tracking No. 2018-074st
Page 2
Table 2: NOx Emissions ay 2018—No. 2 Fuel Oil Firing
water to Test Results
Test Fuel Ratio m ; 15%02 60 Subpart KKKK
Date Load 4A I 4B ES-4A I ES-46 Limit, m 15% 02 Compliance
5-12-18 Base 0.93 0.93 50 51 Yes
5-12-18 83% - 0.83 0.81 50 52 74 ppm@15% 02 Yes
5-12-18 67/0 0,77 0.75 51 52 Yes
5-12-18 50% 0.70 0.68 51 49 Yes
The test report included the predictive emissions monitoring curve for 40 CFR 75 Appendix E.
SSCB did not review this aspect of the NOx emissions report. Additional information about the
emissions curve data is available in the test report but is not included in this memorandum. If
you have questions regarding the results of this review, please contact me at(919)707-8412 or
[e-mail].
cc: Central Files, Anson County
IBEAM Documents - 0400050

DIVISION OF AIR QUALITY
October 23, 2018
MEMORANDUM
� To: Heather Carter, Fayetteville Regional Office
From: James E. Hammond, Stationary Source Compliance Branch (SSCB)
Subject: North Carolina Electric Membership Corporation NCEMC—Anson Plant
Lilesville, Anson County, North Carolina
Facility ID 0400050, Permit No. 09492T08
Nitrogen Oxides Emissions Testing of Unit 5 Turbines(ES-5A and ES-5B)
Performed May 16, 2018 by McHale Performance(McHale)
DAQ Tracking No. 2018-075st
McHale performed EPA Method 7E120 nitrogen oxide (NOx)emissions testing of the Unit 5
turbines on May 16, 2018. The testing was"conducted to re-establish 40 CFR Part 75
Appendix E NOx[emission rate versus heat input correlation] curves for Anson Units 1-6 post
water injection tuning." SSCB has reviewed the test results with respect to the applicable
emissions limits as discussed below.
Unit 5 consists of two Pratt&Whitney FT8 Swift-Pac simple-cycle gas turbines, ES-5A and
ES-513, and one generator. Emissions from ES-5A and ES-5B are controlled by water injection
system CD-5A and CD-513 respectively. The turbines were tested at four loads for natural gas
firing and four loads for. fuel oil firing.
40 CFR 60 Subpart KKKK Standards of Performance for Stationary Gas Turbines and
15A NCAC 2Q .0317 Avoidance Conditions for 15A NCAC 2D .0530 Prevention of Significant
Deterioration(PSD)apply. 60 Subpart KKKK limits NOx emissions to 25 parts per million
corrected to 15% oxygen (ppm@15% 02)when firing natural gas and 74 ppm@15% 02 while
firing No. 2 fuel oil. In order to avoid the applicability of PSD, the permit limits NOx emissions
from ES-1A and ES-1 B through ES6-A and ES6-13 to 246 tons per consecutive 12 months. The
NOx test results and emissions limits for natural gas and oil firing are presented in Tables 1
and 2, respectively.
Table 1: NOx Emissions May 2018—Natural Gas Firing
Water to Test Results
Test Fuel Ratio ppm@15%02 60 Subpart KKKK
Date Load 5A I 5B ES-5A ES-513 Limit, m 15%02 Compliance
5-16-18 Base 0.92 0.89 24 24 Yes
5-16-18 83% 0.87 0.89 24 24 25 ppm@15%02 Yes
5-16-18 67/0 0.86 0.86 24 24 Yes
5-16-18 50% 0.80 0.80 23 25 Yes

Heather Carter
October 23, 2018
NCEMC Anson Unit 5—DAQ Tracking No. 2018-075st
Page 2
Table 2: NOx Emissions May 2018—No. 2 Fuel Oil Firing
Water to Test Results
li Test Fuel Ratio ppm 15% 02 60 Subpart KKKK
Date Load 5A 1 513 ES-5A ES-513 Limit m 15% 02 Compliance
ase 5-16-18 B 0.91 0.89 50 49 Yes
5-16-18 83% 0,83 0.79 46 48 Yes
5-16-18 67% 0.76 0.72 49 48 74 ppm@15%Oz Yes
j
5-16-18 1 50% 0.66 0.62 47 49 Yes
The test report included the predictive emissions monitoring curve for 40 CFR 75 Appendix E.
SSCB did not review this aspect of the NOx emissions report. Additional information about the
emissions curve data is available In the test report but is not included in this memorandum. If
you have questions regarding the results of this review, please contact me at(919) 707-8412 or
[e-mail].
cc: Central Files,Anson County
(BEAM Documents - 0400050

i
DIVISION OF AIR QUALITY
October 23, 2018
MEMORANDUM
To: Heather Carter, Fayetteville Regional Office
From: James E. Hammond, Stationary Source Compliance Branch(SSCB)
Subject: North Carolina Electric Membership Corporation NCEMC—Anson Plant
Lilesville Anson County, North Carolina
Facility ID 0400050, Permit No. 09492T08
Nitrogen Oxides Emissions Testing of Unit 6 Turbines(ES-6A and ES-613)
Performed May 10, 2018 by McHale Performance(McHale)
DAQ Tracking No. 2018-076st
McHale performed EPA Method 7E/20 nitrogen oxide (NOx)emissions testing of the Unit 6
turbines on May 10, 2018. The testing was "conducted to re-establish 40 CFR Part 75
Appendix E NOx[emission rate versus heat input correlation]curves for Anson Units 1-6 post
water injection tuning." SSCB has reviewed the test results with respect to the applicable
emissions limits as discussed below.
Unit 6 consists of two Pratt&Whitney FT8 Swift-Pao simple-cycle gas turbines, ES-6A and
ES-613, and one generator. Emissions from ES-6A and ES-613 are controlled by water injection
system CD-6A and CD-68 respectively. The turbines were tested at four loads for natural gas
firing and four loads for. fuel oil firing.
40 CFR 60 Subpart KKKK Standards of Performance for Stationary Gas Turbines and
15A NCAC 2Q.0317 Avoidance Conditions for 15A NCAC 2D .0530 Prevention of Significant
Deterioration(PSD)apply. 60 Subpart KKKK limits NOx emissions to 25 parts per million
corrected to 15% oxygen (ppm@15% 02)when firing natural gas and 74 ppm@15% 02 while
firing No. 2 fuel oil. In order to avoid the applicability of PSD,the permit limits NOx emissions
from ES-1A and ES-1B through ES6-A and ES6-B to 245 tons per consecutive 12 months. The
NOx test results and emissions limits for natural gas and oil firing are presented in Tables 1
and 2, respectively.
Table 1: NOx Emissions May 2018—Natural Gas Firing
Water to Test Results
Test Fuel Ratio m 15% 02 60 Subpart KKKK
Date Load 6A I 6B ES-6A ES-6B ``Limit, m 15%02 Compliance
5-10-18 Base 1.00 1.04 24 25 Yes
5-10-18 83°% 0.96 0.99 25 24 25 ppm@15% 02 Yes
5-10-18 67/0 0.91 0.93 24 25 Yes
5-1 00-18 509% 0.83 0.90 25 24 Yes

Heather Carter
October 23, 2018
NCEMC Anson Unit 6 —DAQ Tracking No. 2018-076st
Page 2
Table 2: NOx Emissions May 2018—No. 2 Fuel Oil Fidn
Water to Test Results
Test Fuel Ratio PPMV 15% 02 60 Subpart KKKK
Date Load 66 66 ES-6A ES-6B Limit m 15%02 Compliance
5-10-18 Base 0,92 A.94 48 48 Yes
5-10-18 83% 0.85 0.88 48 48 Yes
5-10-18 67% 0.77 0.80 47 49 74 ppm@15%Oz Yes
5-10-18 50% 0.71 0.72 _44 45 1 Yes
The test report included the predictive emissions monitoring curve for 40 CFR 75 Appendix E.
SSCB did not review this aspect of the NOx emissions report. Additional information about the
emissions curve data is available in the test report but is not included in this memorandum. If
you have questions regarding the results of this review, please contact me at(919) 707-8412 or
[e-mail].
cc: Central Files, Anson County
IBEAM Documents-0400050