Document xOe2N1GNjOJmL15qgDyNmZgG

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Walleye Power, Oregon, OH FROM: Gunnar Brown, Environmental Scientist/Engineer AECAB (MI/WI) THRU: Sarah Marshall, Section Supervisor AECAB (MI/WI) TO: File BASIC INFORMATION Facility Name: Walleye Power Facility Location: 4701 Bay Shore Rd, Oregon, OH 43616 Date of Inspection: July 18, 2024 EPA Inspector(s): 1. Gunnar Brown, Environmental Scientist/Engineer 2. Jacob Herbers, Environmental Engineer Other Attendees: 1. Frederick Kraemer, Walleye Power, Plant Manager, Walleye Power, LLC. 2. Ray Circle, Walleye Power, Operations Manager, Walleye Power, LLC. 3. Cody Magann, Environmental Manager, Walleye Power, LLC. (Closing Conference only) Contact Email Address: cmagann@bayshore-opo.com Purpose of Inspection: To evaluate compliance with the CAA and the facility's permits Facility Type: Petroleum Coke Power Plant Facility Name: Walleye Power Facility Location: 4701 Bay Shore Rd, Oregon, OH 43616 Date of Inspection: July 18, 2024 Regulations Central to Inspection: The facility's operation and construction permits, and the National Emission Standards for Hazardous Air Pollutants (NESHAP) Subparts Da and UUUUU for the Circulating fluidized bed boiler (B006), and Subpart OOO for the Limestone Crushing and Sizing Operation (P901). Arrival Time: 08:40 EDT Departure Time: 10:30 EDT Inspection Type: Unannounced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Provided CBI warning to facility The following information was obtained verbally from Fred Kraemer, Ray Circle, and Cody Magann unless otherwise noted. Process Description: Walleye Power's plant at Bay Shore (the Facility) uses petroleum coke (pet coke) to generate heat which is converted into electrical power. Pet coke is received and transported via conveyer to the pet coke piles (Images 2-3, 10). The pet coke is then moved from the piles by a bulldozer onto a conveyer and transported to a mechanical crusher. The pet coke is crushed for improved burning and injected into the boiler (Image 11). Limestone is crushed and injected into the boiler during the burning process to capture SO2. Unburnt bed ash containing limestone is recycled back into the boiler with the bed ash reinjection system. Secondary air is also introduced during the burning to help control the burn and temperature in the system. Flue gas generated from the burning process is cooled from 1650 to 250 with water (Image 7). Cooled flue gas is sent through cyclones and fluidized coolers, and to an 8-compartment baghouse (Image 12) where fly ash is captured and stored in one silo (Image 8) and taken away by truck daily. Staff Interview: There are currently 72 employees at the facility. The Facility operates 24 hours per day, seven days per week with two shutdowns per year (spring and fall), lasting 10-14 days. The facility burns 42,000 - 43,000 tons/month of pet coke during normal operations. Only one stack is currently active with its corresponding power unit (Image 4), which was converted from coal to pet coke around 2000-2001. The other stacks were decommissioned before Walleye Power purchased the Facility in August 2018. The only modification since then was the installation of a bed ash reinjection system to recycle limestone back into the boiler. The next Mercury and Air Toxics Standards (MATS) stack test is scheduled for August 2024. Facility Name: Walleye Power Facility Location: 4701 Bay Shore Rd, Oregon, OH 43616 Date of Inspection: July 18, 2024 The baghouse operates within a pressure differential of 4.0 - 6.2 in. H2O (Image 9), with a "high alarm" at 12 in. H2O, and a "high high alarm" at 22 in. H2O. They change the bags during every Fall shutdown, and as needed. The boiler trips if multiple baghouse compartments are not operational. The Facility has CO, CO2, NOx, and SO2 Continuous Emissions Monitoring Systems (CEMS) Fuel oil is only used during startups for a period of approximately 16-18 hours. A combustion turbine that burns fuel oil is used as backup but has only been used four times in the past 18 years. Coal is not used as a backup fuel. The Facility waters the gravel roads, and sprays the pet coke piles as needed, which is usually only during periods of high winds. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: EPA inspectors toured the grounds of the Facility around the pet coke piles, inside the building containing the boiler, the top of the baghouse system, and the fly ash silo. On the tour, EPA inspectors observed emissions from a small stack (Image 3), the staff stated that the emissions were steam from a blowdown tank. EPA inspectors observed emissions information readouts from the active stack, including 0.07 lb/MMBtu NOx 30-day rolling average, 0.35 lb/MMBtu SO2 30-day rolling average, and a negative opacity reading. Staff informed EPA inspectors that the opacity detector was undergoing its daily calibration at the time of inspection. Photos and/or Videos: were taken during the inspection and are listed in Appendix A. Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Current standard operating procedures (SOPs), and/or operations and maintenance (O&M) plans for the boiler and baghouse Current process flow diagram(s) Summary, diagram, and financial documentation of the recent bed ash reinjection system addition Annual fuel oil use since 2020 Spreadsheet or table of 30-day rolling average SO2 and NOx emissions rate data for each day since 01/01/20 Visible emission inspections documentation for all emission units from the most recent month Facility Name: Walleye Power Facility Location: 4701 Bay Shore Rd, Oregon, OH 43616 Date of Inspection: July 18, 2024 Documentation of sulfur content in pet coke and diesel since 2020 DIGITAL SIGNATURES GUNNAR Digitally signed by GUNNAR BROWN BROWN Date: 2024.08.05 06:39:13 -05'00' Report Author: _________________________________ SARAH Digitally signed by SARAH MARSHALL Section Supervisor: _M_A__R_S__H_A_L__L_______D_ate_: _20_24_.0_8._05_0_7:2_1_:0_8 -_05_'0_0'_ Facility Name: Walleye Power Facility Location: 4701 Bay Shore Rd, Oregon, OH 43616 Date of Inspection: July 18, 2024 APPENDIX A: DIGITAL IMAGE LOG AND DIGITAL VIDEO LOG Inspector Name: Gunnar Brown Archival Record Location: EPA Electronic Files Image # File Name 1 P7180062.PNG 2 P7180063.PNG 3 P7180064.PNG 4 P7180065.PNG 5 P7180066.PNG 6 P7180067.PNG 7 P7180068.PNG 8 P7180069.PNG 9 P7180070.PNG 10 P7180071.PNG 11 P7180072.PNG 12 P7180073.PNG 13 P7180074.PNG 14 P7180075.PNG CAA-0000367 15 CBI-Walleye- 76.PNG Date & Time (CDT) 07/18/2024 08:14 07/18/2024 08:16 07/18/2024 08:23 07/18/2024 08:38 07/18/2024 08:41 07/18/2024 08:42 07/18/2024 08:45 07/18/2024 08:47 07/18/2024 08:51 07/18/2024 08:52 07/18/2024 08:55 07/18/2024 09:06 07/18/2024 09:08 07/18/2024 09:11 07/18/2024 09:19 Image Description Limestone pit to the left of the building and tower containing crushing equipment for limestone Pet coke pile with conveyer to mechanical coke crusher on the right View from the south of the pet coke pile. Visible emission from facility which Fred said was steam blow down. View of facility with only active stack visible (silver top) CFB overview in elevator Filter system for silo loading Path for flue gas Fly ash collector and silo Fly ash collector differential pressure gauge Pet coke pile from top of bed ash silo Fuel feeders Top of baghouse Induced draft fan CEMS equipment duct Photo of TV Screen Claimed as CBI