Document 2qdgkp2epvQB3xm8mMx15ww2r

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY New England Regional Laboratory Laboratory Services and Applied Science Division 11 Technology Drive, North Chelmsford, MA 01863 Report Memorandum Drafted: Finalized: Subject: From: Through: To: September 12, 2021 September 30, 2021 Stack Emission Testing Observations - Hudson Power and Light William Osbahr, Stack Test Coordinator, Field Services Branch /WAO/ Jerry Keefe, Team Leader, Field Services Branch /JCK/ Christine Sansevero, Chief, Air Compliance Section Facility Information A. Facility Name: Hudson Power and Light B. Facility Location: 77 Cherry Street, Hudson, Massachusetts 01749 C. Facility Contact: Brian Choquette D. ICIS-Air #: MA0000002511900904 Background Information A. Date of test: 8/12/2021 B. US EPA Representative: William Osbahr C. Federally Enforceable Requirements Investigated: NSPS Subpart ZZZZ Disclaimer: Page 1 of 3 Unless otherwise noted, this report describes conditions at the facility/property as observed by EPA inspector(s), and/or through records provided to and/or information reported to EPA inspector(s) by facility representatives and as understood by the inspector(s). This report may not capture all operations or activities ongoing at the time of the inspection. This report does not make final determinations on potential areas of concern. Nothing in this report affects EPA's authorities under federal statutes and regulations to pursue further investigation or action. Attendees Name William Osbahr Adam Hopkins Brian Choquette Donna Oehm Ray Oehm Company USEPA Hudson Hudson Power Plant Compliance Power Plant Compliance Role Stack Test Coordinator Plant Superintendent General Manager Lead Consultant Equipment Technician Observations: The purpose of this memorandum is to provide a summary of my observations made during a pretest visit at Hudson Power and Light (Hudson). I arrived at Hudson on August 12, 2021 at 9:30 am. I met with Ms. Oehm, Mr. Hopkins, and Mr. Oehm. Mr. Choquette also attended the group at the start of the visit. I presented my credentials to each representative at the start of the meeting. While on site, we toured the generator building. Ms. Oehm explained the latest QA/QC procedures that she and Mr. Oehm performed on the CPMS. They had recently updated portions of the inlet temperature and delta P systems. They performed calibrations on each of the systems. Ms. Oehm stated that she would provide an addendum via email for the protocol which would explain the latest CPMS improvements and calibrations. We discussed the method by which Hudson would record kw data for the test. Ms. Oehm explained that Hudson does not have a means of electronically recording kw levels of their generators. Ms. Oehm explained that the generators operate at very stable loads. Ms. Oehm stated that Mr. Oehm would be manually recording data for several parameters during the test. She stated that he would log load levels for all runs. We agreed that manual recording of kw load every 10 minutes would be acceptable for all engines during the test. During the visit, we agreed to alter the engine schedule slightly and M. Oehm would include that in the email addendum. Page 2 of 3 Ms. Oehm explained the diesel mix for the dual fired generators. The Hudson's dual fired engines will have a slight amount of diesel burned in the gas mode. During gas operations the engines burn only 4-7% of the capacity from the diesel input. This ratio is internally fixed within the engine operations. It cannot be altered, increased, or shifted in any way. Ms. Oehm stated that she would provide an email with a statement addressing and summarizing items discussed during this visit. Additionally, she would provide an updated schedule for the engine testing. On 8/23/2021 at 6:33 AM, Ms. Oehm provided an email satisfying these last outstanding issues for the test. . Page 3 of 3