Document x1YX4V138ZJ8MV6zymvQ9dE6Q
SUBJECT: FROM: THRU: TO:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5
77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604
CLEAN AIR ACT INSPECTION REPORT Genesee Power Station Limited Partnership, Flint, Michigan
Charles Hall, Environmental Engineer AECAB (MN-OH)
Brian Dickens, Section Chief AECAB (MN-OH)
File, Genesee Power Station Limited Partnership, Flint, Michigan
BASIC INFORMATION
Facility Name: Genesee Power Station Limited Partnership
Facility Location: G-5310 N. Dort Highway, Flint, Michigan
Date of Inspection: 11 April 2022
EPA Inspectors: 1. Charlie Hall 2. Valeria Apolinario
Other Attendees: 1. Julie Brunner, Michigan Department of Energy, Great Lakes, and Energy 2. Thomas Andreski, General Manger 3. Matt Uren, Operations Manager
Contact Email Address: Thomas.Andreski@cmsenergy.com
Purpose of Inspection: boiler inspection
Facility Type: wood fired boiler for electric power generation
Regulations Central to Inspection: 1) Applicable Michigan SIP rules for carbon monoxide, opacity, oxides of nitrogen, particulate matter, and sulfur dioxide; and 2) Applicable provisions of the National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters.
Arrival Time: 13:45 hrs EDT Departure Time: 17:10 hrs EDT
Inspection Type: Unannounced Inspection Announced Inspection
OPENING CONFERENCE
Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet sent by email after inspection Provided CBI warning to facility
The following information was obtained verbally from the facility representatives.
Process Description:
Genesee Power receives shredded wood waste including storm damaged trees and wooden pallets; and burns the shredded wood in a boiler to generate electricity. The boiler is equipped with a selective non-catalytic reduction (SNCR) system, a mechanical multi-cyclone separator (MMS), and an electrostatic precipitator (ESP). The boiler has a spreader-stoker design and is rated at 523 million British thermal units per hour. It is able to produce 345,000 pounds of steam per hour. Genesee Power also burns tire-derived fuel. It burns natural gas for startup only. The boiler has a spreader-stoker design, is rated at 523 million British thermal unit (mmBTU) per hour, and produces 345,000 pounds steam per hour. A selective non-catalytic reduction system, a mechanical multi-cyclone separator, and an electrostatic precipitator control emissions of nitrogen oxides and particulate matter. Genesee Power monitors carbon monoxide (CO), nitrogen oxides (NOx), opacity, and sulfur dioxide (SO2) continuously, and conducts performance tests to measure emissions of acrolein, arsenic, benzo(a)pyrene, beryllium, chromium (total), hydrogen chloride, lead, mercury, particulate matter, and volatile organic compounds. Genesee Power also owns one cold cleaner. See picture 16.
Staff Interview: The boiler was built in 1995. Since 2012, Genesee Power has replaced several sections of the boiler including the sofa panel, superheater, tubular air heater, and generation bank tubes on the hot and cold sides.1 Genesee Power made the repairs to restore or minimize lost generation time and to improve reliability.
TOUR INFORMATION
EPA Tour of the Facility: Yes.
1 According to the ROP, the boiler was installed in 1992 and modified in 2011.
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Data Collected and Observations:
Inspectors visited the boiler control room where the following observations were recorded from the operators' screens:
Pollutant CO
Observed during Inspection
0.241 lb/mmBTU heat input
Limit
0.35 lb/mmBTU heat input
NOx 0.17 lb/mmBTU 0.20 lb/mmBTU heat input heat input
NOx
81 lbs/hr
104.6 lbs/hr
Opacity 1.9%
10%
SO2
9.4 lbs/hr
35.4 lbs/hr
Time Period / Operating Scenario 24-hr rolling average as determined each hour that the boiler operates, excluding periods of startup and shutdown 24-hr rolling average as determined each hour that the boiler operates, excluding periods of startup and shutdown 24-hr rolling average as determined each hour that the boiler operates 6-minute average except one 6-minute average per hour of not more than 20% 24-hour rolling average as determined each hour the boiler operates
Inspectors also viewed the facility's electrostatic precipitator and its associated control panel. See pictures 11 and 12. Although Genesee Power periodically monitors the ESP's primary and secondary voltage and its spark rate, the Renewable Operating Permit (ROP) does not require Genesee Power to establish and comply with specific operating parameter limits for the ESP. The ROP also does not require Genesee Power to establish and comply with operating parameter limits pertaining to the MMS, SNCR, or steam load.
The ROP limits Genesee Power's tire-derived fuel (TDF) usage to 20 tons per calendar day. At the inspector's request, Genesee Power provided TDF records from January 1, 2019, to May 31, 2022. Between January 1, 2019, and June 2, 2022, the daily TDF usage did not exceed 20 tons.
The ROP and 40 C.F.R. 63.7540(a)(10) require Genesee Power to conduct an annual boiler tune-up. At the inspector's request, Genesee Power provided the reports for the 2018 through 2022 boiler tune-up.
The ROP and 40 C.F.R. 63.7521 require Genesee Power to develop a site-specific fuel monitoring plan. At the inspector's request, Genesee Power provided a copy of its fuel monitoring plan.
On May 20 and 21, 2020, Genesee Power measured emission concentrations of particulate matter, mercury, lead, chromium, arsenic, beryllium, acrolein, benzo(a)pyrene, volatile organic compounds, and hydrogen chloride. The follow table summarizes the results and associated permit limits:
Page 3 of 6
Parameter Particulate Matter
Mercury
Lead Chromium Arsenic Beryllium Acrolein Benzo(A)Pyrene Volatile Organic Compounds
Hydrogen Chloride
Average Result 0.0073 1.7 4.5E-7 0.00023 0.00046 0.0017 0.00070 <0.000017 <0.060 <0.0037 5.9
0.011 0.0071 3.8
Permit Limit 00.03 15.7 09.0E-6 00.0047 00.5 00.5 00.0265 00.006 00.053 00.0053 15.7
00.03 00.09 47.1
Unit lb/mmBTU heat input lbs/hr lb/mmBTU heat input lbs/hr lbs/hr lbs/hr lbs/hr lbs/hr lbs/hr lbs/hr lb/mmBTU heat input as carbon lbs/hr lb/mmBTU lbs/hr
Genesee Power has one cold cleaner. See picture 16. The air/vapor interface of the cold cleaner
is less than 10 square feet and is equipped with a cover. The cold cleaner is equipped with a
device for draining cleaned parts. It uses a cleaning solvent with a vapor pressure below 1 millimeter of mercury at 68 degrees Fahrenheit (F).2
Photos were taken during the inspection. They are copied into Appendix A.
Field Measurements were not taken during the inspection.
CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility
Requested documents:
During the inspection, I noted that I would send an e-mail to request the following documents: Results of the most recent performance test for acrolein, arsenic, benzo(a)pyrene, beryllium,
chromium (total), hydrogen chloride, lead, mercury, particulate matter, and volatile organic compounds Fuel Procurement and Monitoring Plan Documentation of the cleaning solvent's vapor pressure
After the inspection, I requested TDF usage records and boiler tune up reports.
After the inspection, Julie Brunner, Michigan EGLE, requested the following documents, which Genesee Power has now provided to Michigan EGLE and to U.S. EPA:
2 The ROP requires the cleaning solution's vapor pressure to be less than 0.3 pounds per square inch absolute at 120F which is 15.5 mm Hg.
Page 4 of 6
EU-BOILER 1. The records of the monthly and 12-month rolling SO2 emissions from January 2020 to February 2022. This record is required to be kept in accordance with Special Condition (SC) VI.5. 2. The records of the daily wood and TDF burnt for October 2021 through March 2022. The records are required to be kept in accordance with SC VI.8 and 9. 3. The records of the monthly and 12-month rolling heat input capacity by fuel type from January 2020 to February 2022. The record is required to be kept in accordance with SC VI.8. 4. For February and March 2022, the following records, kept in accordance with SC VI.2, SC VI.3, SC VI.4, SC VI.6, and SC VI.7: Opacity - Hourly and 24-hour block (calendar day); CO - Hourly and 24-hour rolling average in lb/MMBtu and pph; CO - 30-day rolling average in ppmvd @ 3% O2 NOx - Hourly and 24-hour rolling average in lb/MMBtu and pph; SO2 - Hourly and 24-hour rolling average in pph 5. The records of the Operations Daily Report including MW produced, capacity, and urea usage for February and March 2022.
EUFIREPUMP 1. The record the total hours of operation for the calendar year 2021, recorded through the non-resettable hours meter, including how many hours were spent for emergency operation, what classified the operation as emergency and how many hours are spent for non-emergency operation. The records are required to be kept in accordance with SC VI.6. 2. Records of the maintenance conducted for the calendar year 2021 to demonstrate that the engine and after-treatment control device (if any) were operated and maintained according to the developed maintenance plan per SC VI.5. 3. The record that the fuel oil used meets the NRLM diesel fuel standard per SC II.1.
EUEMERGGEN 1. The record the total hours of operation for the calendar year 2021, recorded through the non-resettable hours meter, including how many hours were spent for emergency operation, what classified the operation as emergency and how many hours are spent for non-emergency operation. The records are required to be kept in accordance with SC VI.4. 2. Records of the maintenance conducted for the calendar year 2021 to prevent malfunction, and records of actions taken during periods of malfunction (if any) to minimize emissions, including corrective actions per SC VI.2 and 3. 3. The record that the fuel oil used meets the NRLM diesel fuel standard per SC II.1.
FG-COLD CLEANER (EUPARTSWASHER) 1. The Safety Data Sheet (SDS) of the solvent used and the service provider for the unit. It was Safety-Kleen at my last inspection.
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Concerns:
In light of the number of boiler projects, I raised a concern that Genesee Power may have reconstructed the boiler. If so, the boiler would become subject to the emission standards for new sources.
DIGITAL SIGNATURES
Digitally signed by CHARLES
CHARLES HALL HALL
Report Author:
Date: 2022.06.06 13:56:09 -05'00'
Brian Dickens Section Chief:
Digitally signed by Brian Dickens Date: 2022.06.06 16:09:18 -05'00'
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Facility Name: Genesee Power Station Limited Partnership Facility Location: G-5310 N. Dort Highway, Flint, Michigan Date of Inspection: 11 April 2022 APPENDIX A: DIGITAL IMAGE LOG
1. Inspector Name: Valeria Apolinario
2. Archival Record Location: https://usepa.sharepoint.com/sites/R5_Work/r5erc/ecad/AECAB%20Library/Forms/ AllItems.aspx?id=%2Fsites%2FR5%5FWork%2Fr5erc%2Fecad%2FAECAB%20Library%2F Enf%5FGenesee%20Power%5FMI%5F22%2FPictures%2FOneDrive%5F2022%2D04%2D15%2F Photos%2DGenesee%204%5F11%5F22&viewid=5f882290%2D049a%2D44b7%2D8ccd%2D595d38b04fcb
3. Camera: #3 Canon 360HS Digital Camera
Image Number
1
Date and Time 04/11/2022
Description of Image Wood shredder for oversize pieces
Photo
Appendices Page 1 of 16
Facility Name: Genesee Power Station Limited Partnership
Facility Location: G-5310 N. Dort Highway, Flint, Michigan
Date of Inspection: 11 April 2022
Image Date and Description Photo
Number Time
of Image
2 04/11/2022 Conveyors
to magnetic
sorter
building
Appendices Page 2 of 16
Facility Name: Genesee Power Station Limited Partnership
Facility Location: G-5310 N. Dort Highway, Flint, Michigan
Date of Inspection: 11 April 2022
Image Date and Description Photo
Number Time
of Image
3 04/11/2022 Portion of
wood pile
with
bulldozer
Appendices Page 3 of 16
Facility Name: Genesee Power Station Limited Partnership
Facility Location: G-5310 N. Dort Highway, Flint, Michigan
Date of Inspection: 11 April 2022
Image Date and Description Photo
Number Time
of Image
4 04/11/2022 Wood feed
Appendices Page 4 of 16
Facility Name: Genesee Power Station Limited Partnership
Facility Location: G-5310 N. Dort Highway, Flint, Michigan
Date of Inspection: 11 April 2022
Image Date and Description Photo
Number Time
of Image
5 04/11/2022 Top section
of boiler
Appendices Page 5 of 16
Facility Name: Genesee Power Station Limited Partnership
Facility Location: G-5310 N. Dort Highway, Flint, Michigan
Date of Inspection: 11 April 2022
Image Date and Description Photo
Number Time
of Image
6 04/11/2022 Urea feed
ports (one is
behind the
hand rail)
Appendices Page 6 of 16
Facility Name: Genesee Power Station Limited Partnership
Facility Location: G-5310 N. Dort Highway, Flint, Michigan
Date of Inspection: 11 April 2022
Image Date and Description Photo
Number Time
of Image
7 04/11/2022 Operator's
15:58
screen with
Hourly
Records for
April 11,
2022
Appendices Page 7 of 16
Facility Name: Genesee Power Station Limited Partnership
Facility Location: G-5310 N. Dort Highway, Flint, Michigan
Date of Inspection: 11 April 2022
Image Date and Description Photo
Number Time
of Image
8 04/11/2022 Operator's
Screen with
CO, NOx,
SO2, and
opacity data
Appendices Page 8 of 16
Facility Name: Genesee Power Station Limited Partnership
Facility Location: G-5310 N. Dort Highway, Flint, Michigan
Date of Inspection: 11 April 2022
Image Date and Description Photo
Number Time
of Image
9 04/11/2022 Operator's
Screen with
Urea Feed
Information
Appendices Page 9 of 16
Facility Name: Genesee Power Station Limited Partnership
Facility Location: G-5310 N. Dort Highway, Flint, Michigan
Date of Inspection: 11 April 2022
Image Date and Description Photo
Number Time
of Image
10 04/11/2022 Boiler's
Construction
Plate
Appendices Page 10 of 16
Facility Name: Genesee Power Station Limited Partnership Facility Location: G-5310 N. Dort Highway, Flint, Michigan Date of Inspection: 11 April 2022
11 04/11/2022 CEM Shack and Duct to ESP Inlet
Appendices Page 11 of 16
Facility Name: Genesee Power Station Limited Partnership
Facility Location: G-5310 N. Dort Highway, Flint, Michigan
Date of Inspection: 11 April 2022
Image Date and Description Photo
Number Time
of Image
12 04/11/2022 Display of
ESP
Operating
Parameters
Appendices Page 12 of 16
Facility Name: Genesee Power Station Limited Partnership
Facility Location: G-5310 N. Dort Highway, Flint, Michigan
Date of Inspection: 11 April 2022
Image Date and Description Photo
Number Time
of Image
13 04/11/2022 CEM Data
Controller
Appendices Page 13 of 16
Facility Name: Genesee Power Station Limited Partnership
Facility Location: G-5310 N. Dort Highway, Flint, Michigan
Date of Inspection: 11 April 2022
Image Date and Description Photo
Number Time
of Image
14 04/11/2022 COM Data
16:15
Controller
Appendices Page 14 of 16
Facility Name: Genesee Power Station Limited Partnership
Facility Location: G-5310 N. Dort Highway, Flint, Michigan
Date of Inspection: 11 April 2022
Image Date and Description Photo
Number Time
of Image
15 04/11/2022 SO2 CEM
Data
Controller
Appendices Page 15 of 16
Facility Name: Genesee Power Station Limited Partnership
Facility Location: G-5310 N. Dort Highway, Flint, Michigan
Date of Inspection: 11 April 2022
Image Date and Description Photo
Number Time
of Image
16 04/11/2022 Cold
Cleaner
Appendices Page 16 of 16