Document Eqk052Y9xKgpgm8O84X1EQ8qn

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 Date: Finalized Date: 1/29/2021 2/02/2021 Subject: From: Stack Emission Testing Observations - Green Mountain Power William Osbahr, Stack Testing Coordinator /WAO/ Field Services Branch (FSB) Through: Jerry Keefe, Team Leader /JCK/ FSB To: Christine Sansevero, Air Technical Unit Chief Enforcement and Compliance Assurance Division (ECAD) Facility Information A. Facility Name: B. Facility Location: C. Facility Contact: D. ICIS-Air #: Green Mountain Power 2 Mechanic St Vergennes, VT 05491 John Greenan VT0000005000100017 Background Information A. Date of inspection: 7/14/2020 B. US EPA Representative(s): William Osbahr C. Federally Enforceable Requirements Investigated: - 40 CFR Part 63 Subpart ZZZZ D. Units Tested: William Osbahr E. Pollutants Tested: CO Green Mountain Power Test Observations; Page 1 Disclaimer: 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. Test Observation Notes On January 26, 2021, I performed a remote observation of emissions testing at Green Mountain Power. Listed below are the following test observations. Test Participants: Name William Osbahr Sean MacKay Finn MacKay Tony Ferreira Ryan Gray John Greenan Jacob Bent Beth Eliason Company USEPA CEM Services CEM Services CCA Combustion Systems GMP GMP GMP VHB Role Remote Observer Project Director, QSTI Technician Technician Controls/Technician Observer Generator Operator/Mechanic Observer Prior to test day, Mr. Greenan of GMP reached out via email to inform me that GMP had secured a camera system within the plant which could assist in a remote observation. I did not utilize this system for the part of the EPA remote observation. Mr. MacKay of CEM Services and I held a teleconference on January 20, 2021. We agreed to communicate via text, email, videos, and/or facetime on the test day. Consequently, Mr. MacKay acted as the primary test contact throughout the test event. Mr. Greenan stated in an email that he would also remain available on the test day via cell phone should I have any questions or need any information. Mr. Greenan was copied on all correspondence regarding the remote test observation efforts. Throughout the test day, Mr. MacKay provided continuous updates and a steady flow of information regarding testing set up, activities, and results. Green Mountain Power Test Observations; Page 2 Mr. MacKay and I held a teleconference at 10:47 am during the test. During that call, he explained that the test was proceeding on Engine 6. He stated that load had been stable at approximately 91% and that the first 2 runs were completed. Mr. MacKay stated that raw emissions test data appeared to indicate that Engine 6 was meeting the outlet emissions requirements of ZZZZ. While full corrected and final data was not yet available, the Oxidation Catalyst (OC) inlet was in the range of 50-55 ppm for each of the first 2 runs. The OC outlet was approximately 5 ppm for the first 2 runs. During the test day, Mr. MacKay sent a series of videos via email depicting the sample line, sample probe, and sample port location. During our call, I reviewed one of the longer videos several times. I explained to Mr. Mackay that the sampling system appeared to be acceptable for a ZZZZ test. This video also provided a narrative of a walk through from the sample trailer complete through to the inlet sample location. Mr. MacKay provided another video showing the Allen Bradley system, which displayed the Continuous Parameter Monitoring System (CPMS). I noted that the data display panel at 8:30 am revealed that Engine 6 load was at 96%, SCR inlet was 619 Deg F, and an OC Delta P of 1.4 Iwc. Additionally, Mr. MacKay stated that he would send email updates during the test day and that he would be available via cell phone. He further explained that he would call me should any abnormal operations or sample problems occur. Throughout the day Mr. MacKay provided me with a series of 8 emails which included 5 photos, 6 attachments, 3 videos, and a summary spreadsheet of the full test day results. Additionally, Mr. MacKay provided several text messages which included 9 photos of sample run data and final QA/QC calibrations. Attached at the bottom of this document is a copy of the draft emissions data summary for both engines. The final test data will be included in the test report to be submitted to EPA. Green Mountain Power Test Observations; Page 3 Green Moutain Power Test Draft Summary Data. Submitted via email 1/26/2021 4:07 PM 40 CFR 63, SUBPART ZZZZ TEST PLANT: GREEN MOUNTAIN POWER - VERGENNES UNIT: DATE: GENERATOR 6 1/26/2021 RUN # TIME INLET O2 INLET CO % PPM INLET CO PPM @ 15% O2 OUTLET O2 % OUTLET CO PPM OUTLET CO PPM @ 15% O2 DESTRUCTION EFFICIENCY % 1 0900-1000 12.62 49.95 35.59 12.62 3.50 2.49 93.00 2 1010-1110 12.57 54.55 38.63 12.61 5.27 3.75 90.31 3 1120-1220 12.51 56.48 39.74 12.51 4.62 3.25 91.82 AVGERAGE LIMIT 23 70 UNIT: DATE: GENERATOR 5 1/26/2021 RUN # TIME INLET O2 INLTET CO INLET CO % PPM PPM @ 15% O2 OUTLET O2 % OUTLET CO PPM OUTLET CO PPM @ 15% O2 DESTRUCTION EFFICIENCY % 1 1240-1340 12.14 183.42 123.52 12.11 9.89 6.63 94.63 2 1350-1450 12.12 186.90 125.55 12.07 8.10 5.41 95.69 3 1500-1600 12.13 183.03 123.06 12.09 7.71 5.16 95.81 AVGERAGE LIMIT 23 70 Where: CO @ 15% O2 = CO PPM x 5.9/(20.9-O2%) DE = Inlet CO @15% O2 - Outlet CO @15% O2 / Inlet CO @15% O2 Green Mountain Power Test Observations; Page 4