AQ_F_1300104_20181212_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Concord City Generating Plant#2
NC Facility ID 1300104
Inspection Report County/FIPS: Cabarrus/025
Date: 12/12/2018
Facility Data Permit Data
[211
ncord City Generating Plant#2 Permit 07645/R07
Manor Avenue,SW Issued 12/12/2017
ncord,NC 28026 Expires 11/30/2025
Lat: 35d 23.0154m Long: 80d 33.9504m Class/Status Synthetic Minor
SIC: 4911 /Electric Services Permit Status Active
NAICS: 221122/Electric Power Distribution Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Andrea Cline Bob Pate Andrea Cline
MACT Part 63: Subpart ZZZZ
SCADA/Generation Electric Director SCADA/Generation
Supervisor [phone] Supervisor
[phone] [phone]
i
Compliance Data
Comments:
Inspection Date 12/12/2018
Inspector's Name Ryan Mills
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: Z y/ /y
On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX T-VOC CO PM10 *HAP
*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

Concord City Generating Plant#2
December 12, 2018
Page-2—
Data Date submitted for initial review 1/08/2019 IBEAM WARNING/OB,NOD,NOV,NRE
Tracking: X IBEAM Document
X IBEAM Inspection,list date inspected X IBEAM LAT/LONG,Facility Locked
X IBEAM Inspection, list date draft is submitted X IBEAM LAT/LONG,Coordinates checked
X IBEAM Inspection,pollutants/programs checked IBEAM Complaint
X IBEAM Planning,Next Inspection Date 12/1/2019
Directions:
Travel from Mooresville to Concord via Highway 3 South;turn right on Kannapolis Parkway;turn left on
Poplar Tent Road;turn right on Highway 601/29;turn left on Highway 601 Bypass(Warren C. Coleman
Boulevard)toward Monroe for approximately 3 miles. Turn left at traffic light on to Manor Avenue, SW.
City of Concord Generating Plant No.2 is located approximately''/2 of a mile on right. The street address of
this facility is 211 Manor Avenue,SW. Note:The facility contact is located at the City of Concord—Alfred
M.Brown Operations Center at 850 Warren C. Coleman Blvd. See directions below.
Directions to the office of facility contact and authorized contact:
The generating plant is within a security fence and is typically vacant. The staff is located at 850 Warren C.
Coleman Boulevard(Alfred M. Brown Operations Center). Travel from Mooresville to Concord via
Highway 3 South;turn right on Kannapolis Parkway;turn left on Poplar Tent Road;turn right on Highway
601/29;turn left on Highway 601 Bypass (Warren C. Coleman Blvd)toward Monroe for approximately 3
miles and turn right on Manor Ave into the driveway of the Alfred M.Brown Operations Center for the City
of Concord.
Safety Equipment:
Safety shoes are recommended.Hearing protection is required when engines are operating.
Safety Issues:
None
Lat/Long:
A review of the facility's coordinates on "Maps of DAQ Regulated Facilities" indicates the facility's
latitude and longitude coordinates are accurate.
Email Contacts:
The e-mail address for the facility contacts was confirmed and is correct.
1. The purpose of this site visit was to conduct a routine air quality inspection. Ms.Andrea Cline
escorted me during the inspection. This facility utilizes six No. 2 fuel oil-fired reciprocating
engines to generate electricity to support peak usage for the City of Concord. Duke Energy is the
main supplier. After January 1,2019 the City of Concord will no longer have a contract with Duke
Power.The operational hours of the facility are dependent upon Duke Energy request for additional
power supply. The City of Concord's contract with Duke Energy limits each engine to operate no
more than 100 hours per calendar year.
2. Facility Contact Information:
During the inspection,I verified the facility contact information in IBEAM. There were no changes
needed.

Concord City Generating Plant#2
December 12,2018
Page-3 —
3. Compliance history file review:
A Notice of Deficiency was issued to the permittee on February 12,2015 for submitting late annual
reports. One report was due on January 30, 2015 and the other report was due January 31, 2015.
Both reports were postmarked February 9, 2015.
4. Observations of permitted air emission sources and control devices:
a. Six stationary No. 2 fuel oil-fired reciprocating diesel engines (ID Nos. 1 through 6)with
catalytic oxidizer(CD-1 through CD-6).
Observed.None of the engines were in operation during the inspection. However, five out of
the six did run from 5-1 Oam the morning of this inspection. The engines are typically started
remotely(from the control room at the Alfred Brown Operations Center). Ms.Cline stated that
each engine typically operates around 1600 kilowatts. Each of the six engines has separate
exhaust stacks. All the engines were manufactured in February 1994 and installed May 1994.
The permittee has installed a diesel oxidation catalyst on each engine to comply with NESHAP
Subpart 4Z.
5. Observations of insignificant air emission sources and control devices listed on the current permit:
a. Two No. 2 Fuel Oil Aboveground Storage Tanks(IES-1 and IES-2)
Observed.The facility has two aboveground storage tanks used to store No. 2 diesel fuel.
Each tank has a 10,000-gallon capacity. Fuel trucks deliver fuel to the site and unload into the
tanks. The tanks typically contain 5,000 gallons or less to allow for vapor expansion. The
storage tanks supply the aboveground day tanks listed below.
b. Three No. 2 Fuel Oil Aboveground Day Tanks (IES-3 through IES-5)
Observed.The day tanks are used to supply fuel to the diesel engines (ID Nos. 1 through 6)
and have a capacity of 1,000 gallons, each. Each day tank supplies No. 2 fuel oil to two diesel
engines.
c. Motor Oil Aboveground Tank(IES-6) and Waste Motor Oil Aboveground Tank(IES-7)
Observed.The facility stores motor oil that is used to lubricate the engines in a 1,000-gallon
tank(IES-6). When the engine oil is changed,the waste oil is stored in a 1,000-gallon tank
(IES-7) and is carried off site to be used in waste oil heaters in the City of Concord's Motor
Fleet garage for comfort heat.
6. Observations of air emission sources and control devices not listed on the current permit:
a. The facility has a dip tank(approximately 30 gallons)that uses mineral spirits to clean parts
and tools. The dip tank is used for maintenance purposes and is considered an exempt source.
.Observed.I did not observe this dip tank.

Concord City Generating Plant#2
December 12, 2018
Page-4—,
7. Compliance with specific permit conditions and limitations:
a. Condition A.3 — 15A NCAC 2D .0402"Sulfur Oxides"states that the sulfur content of the No.
2 fuel oil fired in the eight engines must not exceed 0.5 percent by weight. The recordkeeping
and recording requirements for the fuel oil supplier certification in Condition A.12 of the Air
Permit will demonstrate compliance with this condition.
Observed.The permittee has documentation showing the fuel oil delivered to the facility has a
maximum sulfur content of the diesel fuel oil is 15 ppm. Compliance with this permit
condition is indicated.
b. Condition A.4- 15A NCAC 2D.0407"Nitrogen Dioxide"states that to assure compliance with
the National Ambient Air Quality Standard(NAAQS) for nitrogen dioxide of 0.53 ppm(100
micrograms per cubic meter)annual arithmetic mean,the nitrogen dioxide emissions from the
eight No. 2 fuel oil-fired reciprocating engines shall be less than 105 tons per consecutive
12-month period and that the total facility-wide engine hours cannot exceed 4,093 hours per
consecutive 12-month period.
Observed. Ms. Cline keeps records showing the hours each engine operates each month. The
engines operated a combined total of 253.0 hours for calendar year 2017. From January 1,
2018 to the date of this inspection,the engines have operated for a combined total of 266.0
hours. Compliance with this permit condition is indicated.
c. Condition A.5. - 15A NCAC 2D .0516 "Sulfur Dioxide Emissions from Combustion Sources"
limits sulfur dioxide emissions from the combustion sources to 2.3 lbs/mmBtu heat input.
Observed. Compliance is indicated since the facility maintains documentation that the fuel oil
delivered has a sulfur content of 15 ppm or less.
d. Condition A.6 - 15A NCAC 2D .0521, "Control of Visible Emissions" states that the visible
emissions from the six No. 2 fuel oil-fired reciprocating engines (ID Nos. 1 through 6) are
limited to 20 percent opacity when averaged over a six-minute period.
Observed. During the inspection,these six No.2 fuel oil-fired reciprocating engines were not
in operation. Ms. Cline stated there have been no opacity problems. Compliance with this
permit condition is indicated.
e. Condition A.7. 15A NCAC 2D.0535,"Notification Requirement"states that 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 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.
Observed. Based on a records review and conversation with Ms. Cline,no excess emissions
have occurred at the facility. Therefore, compliance with this permit condition is indicated.
f. Condition A.8.- 15A NCAC 2D.0540 "Particulates from Fugitive Non-Process Dust Emission
Sources" states the permittee shall not cause or allow fugitive non-process dust emissions to
cause or contribute to substantive complaints.

Concord City Generating Plant#2
December 12,2018
Page- 5—
Observed. Fugitive dust was not observed at the time of inspection.No complaints have been
received;therefore, compliance with this permit condition is indicated.
g. Condition A.9.— 15A NCAC 2D .0611, "Catalytic Oxidizer Requirements" states that carbon
monoxide emissions shall be controlled as described in the permitted equipment list. The
permittee shall perform periodic inspections and maintenance(I&M) as recommended by the
manufacturer. In addition,the permittee shall perform an annual inspection of the pollution
.control device. Records of all maintenance activities shall be recorded in the logbook.
Observed. The permittee installed and tested the diesel oxidation catalyst for each generator.
The permittee has installed a continuous parametric monitoring system(CPMS)to measure the
exhaust temperature and pressure drop across the catalyst. The pressure drop was established
for each engine during initial stack testing. The temperature and pressure drop is measured
each time the engine comes under load. Records indicate the temperature and pressure drop are
within the proper operating range. Ms. Cline indicated they are using the pressure drop
monitoring as an indication of the structural integrity of the diesel oxidation catalyst.Ms. Cline
indicated that the cost and potential damage to the diesel oxidation catalyst makes an internal
inspection of the diesel oxidation catalyst impractical. If the port to the diesel oxidation
catalyst is opened,then the bolts and gasket will be damaged and would need to be replaced.
Also,a bucket truck must be used to access the port and moving the diesel oxidation catalyst in
this fashion could result in chipping or otherwise damaging the catalyst. Compliance with this
stipulation is indicated.
h. Condition A.10- 15A NCAC 2D .1111 Maximum Achievable Control Technology" states that
the diesel engines(ID Nos. 1 through 6)shall comply with NESHAP Subpart ZZZZ since they
are considered existing, non-emergency,non-black start, compression ignition (CI)
reciprocating internal combustion engines (RICE) greater than 500 brake horsepower. The
permittee shall comply with NESHAP Subpart ZZZZ. Each engine must comply with the CO
emission limit not to exceed 23 ppm or reduce CO by at least 70%. The permittee shall be in
compliance with NESHAP Subpart 4Z by May 3, 2014 (one-year compliance extension
granted). The permittee must demonstrate compliance by conducting a stack test no later than
October 30, 2014 and submit a stack test report within 60 days from the stack test and no later
than December 29, 2014. Each engine must have a closed crankcase ventilation system or
install a filtration system on an open crankcase to reduce oil mist,particulates and metals. The
engine exhaust temperature(4-hr average)must be maintained between 459F and 1350°F and
the pressure drop maintained within 2 inches of water from the pressure drop measured during
the stack test. The permittee must conduct a subsequent stack test every 3 years if then engine
operate 100 hours or more per calendar year or every 5 years if the engines operate less than
100 hours per calendar year.
Observed. The permittee submitted a NESHAP Subpart 4Z initial notification on September
7,2010. The permittee installed a diesel oxidation catalyst(DOC)on each engine prior to May
3, 2014. DAQ approved the stack testing of two engines as a representative sample of the
whole site. The permittee submitted the stack test report on October 23,2014 which also meets
the NOCS report deadline. The Stationary Source Compliance Branch approved the stack test
results on May 22,2015 and indicates compliance. Subsequently,the permittee has conducted
additional stack testing on the remaining engines as shown in the table below.

Concord City,Generating Plant#2
December 12, 2018
Page-6—
Engine# A P - Stack Test Stack Test 2018 CY SSCB Approval
inches of H2O Date Engine Hrs Date
1 3.49 Dec 2,2015 60 Aril 7,2016
2 2.97 Dec 2, 2015 60 Aril 7,2016
3 3.23 Aril 20, 2016 60 August 23, 2016
4 3.16 _ Oct 23,2014 60 May 22, 2015'
5 3.09 Oct 23,2014 20 May 22, 2015
6 2.86 Aril 20, 2016 60 August 23, 2016
Ms. Cline stated the City of Concord has a contract with Duke Energy that states the engines
will not operate more than 100 hours per year. Therefore, it is anticipated the permittee will be
required to conduct subsequent stack testing every 5 years. I informed Ms. Cline that if the
engines operate 100 hours or more than subsequent stack testing must be conducted every 3
years.
The diesel engines(ID Nos. 1 through 6)have open crankcases and the oil mist,particulate,and
metals are reduced by filters. The permittee has installed thermocouples to monitor the exhaust
on each engine to ensure the 4-hour average is between 450 and 1350°F. Pressure drop for
each engine was established during the stack test and is shown in the table above.The permittee
has records of the temperature and pressure drop when each engine is under load. Since the
engines are operated less than 100 hours per year and there are no deviations then the permittee
is only required to submit an annual report. The report was submitted on January 24,2018 and
compliance is indicated.
i. Condition A.11.—Limitation to Avoid 15A NCAC 2D .1402, "Applicability", states that in
accordance with 15A NCAC 2Q .0317,to comply with this permit and avoid the applicability
of 15A NCAC 2D .1402 "Applicability," each engine'cannot exceed 361 hours from May 1
through September 30 of each year. The permittee shall record monthly and total annually the
hours each diesel engine operated. The permittee shall report to DAQ by October 30 of each
year the hours each generator operated from May 1 through September 30.
Observed. This office received the annual report on October 4, 2018 for the for the 2018
ozone season and each engine was not operated during this timeframe. To date in 2018, each
engine has operated less than 60 hours. Compliance with this stipulation is indicated.
j. Condition A.12. Limitation to Avoid 15A NCAC 2Q .0501 "Synthetic Minor Facilities"limits
the facility to 100 tons of S02,NOx, and CO per year. The permittee is required to submit to
DAQ within thirty days after each calendar year,the monthly engine hours of operation,the
monthly nitrogen oxide, carbon monoxide and sulfur dioxide emissions for the previous 12
months. The total engine hours of operation,total nitrogen oxide,carbon monoxide and sulfur
dioxide emissions have to be calculated for each month for the six No. 2 fuel oil-fired engines.
The permittee is also required to maintain fuel certification records on-site.
Observed. The report was received on January 16, 2018. Each engine operated less than 48
hours during calendar year 2017. The total hours of operation for the six engines during
calendar year 2017 were 253.3 hours. The NOx, CO, and S02 emissions for calendar year
2017 were 6.659 tons, 1.641 tons, and 0.362 tons,respectively. The emissions and engine
hours of operation to date in 2018 are shown below:

Concord City Generating Plant 92
December 12, 2018
Page-7—
NOx=7.07 tons; CO= 1.75 tons; S02=0.38 tons
Engine# 2017 Hrs to date
1 60
2 60
3 60
4 60
5 20
6 60
The permittee is maintaining fuel certification records on-site. All fuel certification records
show the No. 2 fuel oil received by the permittee was less 0.5% sulfur. The permittee is also
maintaining monthly records of the engine hours and NOx, S02 and CO emissions.
Compliance with this stipulation is indicated.
k. Condition A.13. Limitation to Avoid 15A NCAC 2Q .0530 "Prevention of Significant
Deterioration" limits the facility to 250 tons of S02,NOx, and CO per year.
Observed.The permittee is complying with the PSD avoidance by adhering to Condition A.12
which limits emissions of S02,NOx, and CO to 100 tons per year. Compliance with this
stipulation is indicated.
8. NSPS/NESHAP:
The facility is subject to NESHAP Subpart 4Z. The permittee has conducted the initial stack test
and appears to be in compliance with NESHAP Subpart 4Z.No gasoline storage tanks are on-site
which could trigger NESHAP 6C.
9. Summary of Changes Needed to the Current Permit:
None
10. Compliance Assistance Offered During the Inspection:
On November 20, 2018 Mr. Joe Foutz and I of this office spoke with Ms. Andrea Cline,
SCADA/Generation Supervisor, and Mr. Bob Pate, Electric Director, about their intent to
dismantle and sell most if not all of these electric generating units.
11. Section 112(r)Applicability:
This facility does not appear to be subject to the requirements of the Chemical Accident Release
Prevention Program, Section 112(r) of the Clean Air Act.
12. Compliance Determination:
Based on my observations during this inspection,this permittee appeared to be in compliance with
the applicable air quality regulations.
RCM:Ihe
C:\Users\lhelledge\State of North Carolina\DAQ Mooresville Regional Office-CABARRUS\00104\INSPECT 20181212.rtf