ML020780325
| ML020780325 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/07/2002 |
| From: | Chutima Taylor Dominion Generation |
| To: | Vaughan A Office of Nuclear Reactor Regulation, State of VA |
| References | |
| Download: ML020780325 (5) | |
Text
Dominion Generation 5000 Dominion Boutevard, Glen Allen, VA 23060 Dominion March 7, 2002 Mr. A. Dahlgren Vaughan Environmental Engineer Senior Virginia Department of Environmental Quality Fredericksburg Satellite Office 806 Westwood Office Park Fredericksburg, Virginia 22401 Re: Questions From the Initial Review of the State Operating Permit Application for Dominion's North Anna Power Station
Dear Mr. Vaughan:
This is in response to your March 1, 2002 request for additional information to supplement Dominion's application for a state operating permit that would cover potential sources of air pollution emissions at our North Anna Power Station (North Anna). Our answers to your requests are provided below.
Your first question concerns the use of AP-42 emissions factors to determine actual emissions.
At this time, we believe that the use of AP-42 factors is conservative enough to provide assurance that North Anna is not a major source of air pollution emissions. We reviewed the annual emissions inventory data that we submitted to the Department of Environmental Quality (DEQ) over the most recent five years, which we believe to be a representative period. These data show that our annual emissions of oxides of nitrogen (NOx) from the entire facility (including the station blackout generator) to be only a fraction of the major source threshold of 100 tons per year. NOx is the pollutant of concern for the facility because we burn only distillate fuel oil. The maximum annual emissions of NOx during this five-year period were 12.24 tons in the year 2001. These emissions sources are not in continuous use, and, in fact, are only operated for test purposes to ensure that they are operable in the event of an emergency.
You also requested in your first item that we either 1) provide a guarantee from the manufacturer that the NOx and carbon monoxide (CO) emissions will be less than or equal to AP-42; 2) provide a copy of a stack test conducted on an identical emergency generator that demonstrates that the actual NOx and CO emissions will be less than or equal to AP-42; or 3) accept a permit requirement that would mandate a stack test for one of the units at North Anna to demonstrate that tested emissions are equal to or less than AP-42 values. In light of the low actual emissions calculated using AP-42 values, we believe that any of these steps are excessive and unwarranted.
Even if AP-42 factors were off by 100% on the low side, our calculated annual actual emissions would only be about 20% of the Title V major source thresholds.
To support our assertion that AP-42 is appropriate, we obtained information from the vendor on expected emissions. A guarantee was not obtained from the manufacturer when the engines were built in the 1970's. Using the information provided by the vendor generates lower emissions of
Mr. A. Dahlgren Vaughan March 7, 2002 Page 2 NOx and CO than those submitted in our permit application. Therefore, we believe that the use of AP-42 remains appropriate for this facility. The emission factors used for the engines all came from the October 1996 version of AP-42, which is the most recent revision of this section of AP
- 42. Our calculations and the vendor-supplied emissions factors are enclosed.
Your second request was to provide calculations showing the origin of the numbers used in our permit application as Attachment A. We have sent you an electronic copy of the spreadsheet used to perform these calculations and we are enclosing a printed copy with this letter. As discussed above, all of our emissions calculations (except for the station blackout generator) are based on AP-42 factors.
Finally, you also asked if we intended to be able to run each of the four Fairbanks Morse emergency generators simultaneously. We do wish to retain that capability, with the understanding that the sum of all emissions of criteria air pollutants from this facility will be restricted to less than Title V major source thresholds. We expect this restriction will come in the form of restricted hours of operation.
We believe that the information in this letter and its attachments will satisfy your requests for additional information in your March 1, 2002 letter. Please contact Mr. Andy Gates of Dominion's Electric Environmental Services department at (804) 273-2950 if you need any additional information.
Very truly yours, C~athyvC yo Director - ElecYtricnvironmental Services
Enclosures:
Calculation of hourly emissions using AP-42 factors Calculation of hourly emissions using Fairbanks Morse factors
Mr. A. Dahlgren Vaughan March 7, 2002 Page 3 cc:
U. S. Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303 Docket Nos. 50-338/50-339 License Nos. NPF-4/NPF-7 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Docket Nos. 50-338/50-339 License Nos. NPF-4/NPF-7 Mr. M.J. Morgan NRC Senior Resident Inspector North Anna Power Station
North Anna Power Station Auxiliary Boiler/EmergencyGeneratorEmissions Calculations Potentialto Emit Data 1Txi mu Heat Input Maximum (MBuihr)
Emission Unit Fuel Tone % Sulfur HW.tieo Va.Ie 90.7 0.2 90.7
-S-1 0.2
-ES-2 0.5 36.60 35.11 0.2 140.000 250.8 IEnission Factor Plunt Eission Facto J ný Unconbrolled fabour ES-I t/Kpol 0.001
,b/Kgco 3-11. 5th Edition ES-1 3-1, 5th Edlition 12.957 FS-1 to/Kgol 1.296 3-7, 5th Edition ES-1 AuxBoiler 4 b/Kgo*d 0.700 3-7, 5h Edition ES-i Aux Boiler 4 11o 1.08 lb/Kgd 142 b/Kgo*C%S) 3-1, kth Edition ES-i Aux Boalr 4 0.34 ES-i Au Boaler 4, 5 Ib/Kgol ES-2 ES-2 Aum Boiler 4B t.00151 20 Ib/Kgol ES-2 Aux Boaer 48 2 lo/Kgol ES-2 Aux Boier 48 1.08 lb/Kool P-42. Table 1.3-7. 5th Edition ES-2 Aux Boiler 4B sMo ES-2 Au" Boiler 4B 142 b/Kgoa(%S) AP-42. Table 1 IOC lio(Kcal ES-2 Aux Boiler 48 CO 104 ton/yr ES-3 Blackout Generator 39.3 ton/yr ES-3 Blackout Generator PMoX 1.0 ton/yr ES-3 Blackout Generator 4.Z ton/yr PeFrit (Reg. No. 4 ES-3 Blackout Generator 0.8 i. 40726J)
ES-3 Blackout Generator ES-3 Blackout Generator 0.7 ". q 6-ES-4 Emegency Diesel 0 3.2 ES-4 Emergency Diesel 0 0.0697 E6-4 t 0.0573 IErMMBtJ IAP-42. Table 3.4-2 ES-4 E 1.01 7.093 2.7W ES-s Emergency Diesel C 'MM~tu ES-S Emergency Diesel C ES-5 Emergency Dieuet 2.012 ES-5 Emergency Diesel PMio MBto AP-42, Table 3.4-2
?M02 u S) AFa Table3.4-1 7.093 ES-s Emergency Diesel ES-S Emeruencv Diesel C 800 Tzr 112.358 NOx PM10 2.012 7.093 SDiesel Generator S02 'able 3.4-11
.4-47 2,012 ES-7 I 0.05731 I/MMBto IAP-4 7.093 SO,
North Anna PowerStation Fairbanks Morse Emission Factors Each unit is rated at 3840 hp There are 453.59 grams per pound Emissions F-M Emission Factor F-M F-M AP-42 Pollutant (grams/hp-hr) grams/hr pounds/hr pounds/hr NOx 12.2 46,848 103.28 112.36 CO 2.2 8,448 18.62 29.85 SOx 1.4 5,376 11.85 7.09 THC 0.3 1,152 2.54 2.88 PM 0.3 1,152 2.54 2.45 NOx is the controlling pollutant. Therefore, since AP-42 predicts higher emissions than the vendor, we will continue to use AP-42 to demonstrate compliance.