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Inspection:
On September 29, 2005, I, Sally McKinney met with Mr. Reggie Wallace, Power Plant Supervisor and authorized contact. Mr. John Ezzelle was in the hospital on this date and unable to be present. Mr. Reggie Wallace (authorized contact) walked me through the facility. On this date two of the eight turbine generators were operating on natural gas. Visible emissions from these units were 0% opacity.
On October 4, 2005, a follow-up inspection was conducted, enabling Mr. Ezzelle to be present. No turbine generators were operating on this date. Records were reviewed and indicate compliance with all applicable conditions.
New Issues are the CAIR rule (Clean Air Interstate Rule). PWC will be scheduling maintenance on their units between October and Christmas. Any pollution control upgrades needed to comply with CAIR will probably be installed during this scheduled maintenance period.
Description:
The Butler-Warner Generation Plant for the Public Works Commission (PWC) of Fayetteville, NC is designed to provide electric generation to Progress Energy Carolinas (previously CP&L) during peak loading situations. This facility can supply power to the grid within 10 minutes of request. The facility is staffed 24 hours per day, 7 days per week, 52 weeks per year.
This is a 280 Megawatt maximum capacity plant. There are eight (8) turbine generators available for electric generation (ID Nos. GT-1 through GT-8). Each turbine generator produces approximately 26-29 megawatts of power, each, for a total of 208 megawatts. The additional 72 megawatts is produced from one (1) steam turbine that emits no criteria pollutants into the air and is therefore not required to be listed as permitted equipment. This turbine takes the exhaust from GT-1, 2, and 3 and generates steam.
Under most situations the facility will operate only three turbines. There are three (3) heat recovery steam generators that are used to maximize plant efficiency by powering a common electric generator. Each heat recovery steam generator is fed by waste heat from two (2) turbine generators. When utilizing the heat recovery steam generators, the emissions from the turbine generators will exit from the heat recovery steam generator emission points. Therefore, the heat recovery steam generators are listed as permitted sources.
The facility operates on natural gas unless there is a curtailment by the supplier, Piedmont Natural Gas. This often happens in the winter. An interesting note about these turbines is that they can operate on any specified ratio of fuels (50% NG / 50% Oil, for example).
The turbine generators utilize a water-injection system for the reduction of adiabatic flame temperatures and resulting thermal NOx (nitrogen oxides) generation. The water injection system does not begin immediately when the turbine generators start up. Water injection is designed to kick-in at a certain load so that it does not interfere with operation during start-up / ramp-up. For natural gas combustion, the water injection system comes on at 15 megawatts.
A water-demineralization plant provides water for this process. The used resins generated from this process are taken off-site, regenerated, and sold to a customer with less stringent resin specifications.
TURBINE GENERATOR CONTROL ROOMS: One staff member is assigned to walk through and monitor each of the turbine generator control rooms. Each turbine generator control room is equipped with a control panel that has real-time data for the fuel consumption and ratio of water to fuel. PWC has installed software to use the water injection/fuel injection ratio.
FACILITY CONTROL ROOM: The facility stores this computer data (approximately 1 month of data per storage tape) in a small room located adjacent to the facility control room. This data can be accessed for recordkeeping and informational purposes. The facility control room also has a logbook where all activities are recorded, including deviations from the water injection protocol. This logbook is kept directly in front of the control panel/computer screen. If the system injects more or less water than is acceptable an alarm goes off in the turbine generator control room and the facility control room. In the facility control room a red light flashes on the wall and a red message flashes on the control room computer. Personnel respond to this alarm by first checking the water pump to the turbine generator. If the problem cannot be identified and solved immediately (usually within 4 to 10 minutes of notification), the unit will be shut down to prevent excess emissions. Mr. Ezzelle stated that Progress Energy Carolinas support the facility if the shut down of the generator is necessary. The facility can also use one of the other turbine generators to replace the NSPS affected turbine generator (ID No. GT-8).
Background/Research:
Background/Research: The State of North Carolina is participating in the Ozone Transport Commission (OTC) NOX Budget Program (NBP) to transition to a larger regional NOX trading program developed under a NOX SIP Call and in response to section 126 petitions filed by a number of Northeastern States. This emission reduction program began in 1999. Under the OTC program sources use monitoring requires developed under an OTC monitoring guidance document. Under the new Federal NOX Budget Trading Program (Federal NBP) sources must follow procedures set out in 40 CFR Part 75, Subpart H.
PWC has been designated as a low mass emission unit (LME) – as defined in d75.19 and d75.74(c)(10). LME units are oil- and gas-fired units that meet an actual and calculated emission threshold (< 50 tpy NOX or < 25 tpy SO2.) Units qualifing as LMEs, can use unit specific/ fuel specific or generic defaults can be used to determine the NOX emission rates, and either maximum rated hourly heat input (in mmBTU) or heat input calculated from a long term fuel flow method. The LME methodology must account for all emissions during an ozone season. A unit cannot switch between a different methodology and the LME method during the ozone season.
To demonstrate that a facility qualifies as a LME, a demonstration using default emission rates or fuel-and-unit-specific emission rates are used. PWC will be using the default values for CO2 and SO2 emissions. Fuel-and-unit-specific emission rates will be used for NOx emissions.
Currently, Part 75 requires that a Unit-specific NOX rate be determined from a 4-load Appendix E test and that a multiplier of 1.15 be applied to the resulting maximum tested emission rate – for controlled or uncontrolled units, or using a default rate of 0.15 lb/mmBtu for controlled units (whichever is higher). Proposed revisions would change both of these requirements. Applicable references are d75.19 (c)(1)(iv)(A) and Part 75, Appendix E, Section 2.1. The facility must submit 3 years of historical data supporting that the NOX and SO2 emissions are under the threshold quantities. Mass emission rate testing is required every 5 years. Retesting is required when there are changes in the fuel supply, physical changes to the unit, changes in the manner of unit operation, or changes to the emission controls which may cause a significant increase in the action NOx emission rate. A LME must submit annual reports that demonstrate each unit emits less than the threshold quantity for each calendar quarter for any calendar year.
5-Year Compliance History:
Notice of Violation was issued to Fayetteville Public Works Commission, Cross Creek Reclamation Facility on November 6, 2001 for open burning during a burning ban.
Conclusion:
At the time of inspection, this facility appeared to be in compliance with permit requirements.