Compliance at the Coolidge Generating Station Quality News...Compliance at the Coolidge Generating...
Transcript of Compliance at the Coolidge Generating Station Quality News...Compliance at the Coolidge Generating...
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Coolidge Generating Station (CGS)
• CGS is an electric generation facility located 3 miles
south of Coolidge, owned and operated by Coolidge
Power LLC.
• The facility is a natural gas-fired, simple cycle, with a
total of 575 MW of generation from 12 GE LM6000
combustion turbine generators (CTGs).
• Each unit has selective catalytic reduction and CO
catalyst system to reduce NOx and CO.
• Facility also has a diesel-fired emergency fire pump
engine.
• The original air permit was issued in March of 2010.
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Permits
PCAQCD Air Permit
• Subject to Title V requirements due to potential for annual
emissions of NOx, CO, PM10/PM2.5 or VOCs to reach 100
tons.
• As an electric generating facility capable of generating more
than 25 MW the facility is also subject to the Title IV Acid
Rain Program.
• The facility is a synthetic minor with respect to Prevention of
Significant Deterioration and has a cap of 245 tons per 12-
calendar month period per pollutant.
PCAQCD Regulation 4-1-030 - Control of fugitive
emissions from unpaved lots/acreage in nonattainment
area for PM10.
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Permits
ADEQ Aquifer Protection Permit
• Facility is zero discharge; all wastewater generated at the facility is
held in double-lined evaporation ponds with a leak collection and
removal system.
• Covers process wastewater generated at the facility including
reverse osmosis wastewater, multi-media filter backwash and CTG
evaporative cooler blowdown.
Arizona Department of Water Resources
• Permit for two groundwater wells on-site to provide all water for
facility use.
• Limit of 279 acre-feet/year for this permit.
• Reporting - Annual Water Withdrawal and Use Report (Groundwater
Summary)
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Aquifer Permit
Monitoring Requirements • Daily monitoring of the Leak Collection Removal System (LCRS) (manually
or continuous)
• Weekly and after significant storm inspect the evaporation ponds for
freeboard, fluid level, liner integrity, berm integrity, evidence of overtopping,
operational condition of the LCRS and flow meter or other measuring
device.
• Quarterly check the oily water separator for damage or leakage, sludge
accumulation, oil sheen or odor of effluent, and piping, pumps valves and
controls are operating correctly.
Reporting Requirements• Exceeding alert levels for the LCRS: Level 1 – normal liner leakage (417
gpd) or Level 2 – Liner failure (13,124 gpd); discharge of unauthorized
materials; failure of containment structure; over-topping of evaporation
pond; and permit violation.
• Annual Compliance Report
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PCAQCD Air Permit
Monitoring Requirements• Continuous Emissions Monitors (CEMs) installed on each CTG stack
o Monitor NOx and CO emissions - daily
o Determine PM, VOC and SO2 using an emission factor (lbs/MMBtu) based
on annual performance testing - daily
• Inlet and Outlet air temperature - daily
• Fuel consumption (and associated sulfur content through contractual
commitment) - daily
• Opacity screening – semi-annually
• Fire pump fuel – only purchase on-highway diesel fuel (500 ppmv sulfur or
less)
• Hours of operation: start-up, normal and shut-down
• Fuel flow/heat input
Testing Requirements• Annual performance testing for NOx, CO, PM10, SO2, VOCs and opacity
• Annual Relative Accuracy Test Audits on the CEMS
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PCAQCD Air Permit
Recordkeeping Requirements
• Monthly emissions of NOx, CO, PM10, VOC and SO2 (monthly, 12 month
rolling and a monthly emission budget report that compares 10 month
rolling to 12 month rolling ensuring facility does not get close to 245 ton
limit)
• Total natural gas burned
• CTG run times
• Number of start-up and shut-down cycles for each CTG
• Malfunction in operation of facility or any air pollution control equipment
• Diesel shipments received for fire pump engine
• Operational hours of fire pump engine
• Date and duration of water washes
• Projects involving abrasive blasting or spray painting
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PCAQCD Air Permit
Reporting Requirements
• Semi-annual compliance reporting - PCAQCD
• Annual Compliance Report to permit provisions – PCAQCD and EPA
• Annual Emissions Inventory – PCAQCD
• Quarterly Emissions Collection and Monitoring Plan System (ECMPS) used
to submit monitoring plans, QA data, and emission data under the Acid Rain
Program – EPA
• Annual Greenhouse Gas Reporting Program – EPA
• Any deviations from permit requirements – within 15 days to PCAQCD
• Written report for annual Relative Accuracy Test Audits and Performance
tests – PCAQCD
• Excess emissions – verbally within 24 hours, written within 3 working days
to PCAQCD
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PCAQCD Regulation 4-1-030
Article 1 - West Pinal PM10 Moderate Nonattainment Area
Fugitive Dust
• Became effective on January 1, 2016.
• Requires the owner and/or operator of open areas/vacant lots shall
not cause, suffer, allow, or permit fugitive dust emissions which
result in opacity of the dust to exceed twenty percent (20%) as
measured using an opacity method.
• CGS has approximately 60 acres of open area covered under this
regulation.
• We obtained bid from three vendors for dust suppression, which
included graveling areas of high traffic.
• Bid awarded to SoilWorks LLC.
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Dust Palliative
SoilWorks LLC
• Dust palliative used was Gorilla Snot – applied to 60 non-traffic
acres, costing approximately $30,000 including material, application
and removal of containers ($500 per acre).
• The product is a biodegradable, copolymer-based that is primarily
engineered to control dust and erosion.
• For traffic areas CGS opted to have gravel spread 1-1.5 inches thick
to provide roadways for contractor truck or site vehicles, and the site
requirement is a 10 mph speed limit within the site.
• Cost of gravel and spreading was approximately $25,000.
• Project was completed by January 31, 2016.
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Determining Compliance with 4-1-030
The owner and/or operator shall sign up to receive the Pinal County
dust control forecast, and shall ensure the open areas/vacant lots is
stabilized the day leading up to and the day that is forecast to be high
risk for dust emissions.