The NAES Way

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Plains End Generating Station

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Plains End Overview cont…

• Plains End, LLC (Commercial May 2002)20 Wartsila 18VG 34SG, Lean Burn, Reciprocating Engines, 5.65 MW/Engine; 54.2 MMBtu/hr natural gas fuel input

• Plains End II, LLC (Commercial May 2008)14 Wartsila 20VG 34SG, Lean Burn, Reciprocating Engines, 8.25 MW/Engine; 73.6 MMBtu/hr natural gas fuel input

• Common Pipeline Natural Gas• Peaking plant• Plains End II, LLC is a black start facility

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Plains End Overview cont…

• Plains End, LLC• Siemens Catalytic Emission Control System

• Oxidation Catalyst first• SCR Catalyst second (40% urea injection)• Separate chambers

• Plains End II, LLC• Hug Catalytic Emission Control System

• SCR Catalyst first (40% urea injection)• ROM Catalyst (ammonia slip) second• Oxidation Catalyst last• Combined chamber

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• 2010 Title V Air Permit (combined for both facilities)• Basis of permit primarily “manufacturer guaranties”• Major source of priority pollutants; minor source of HAP’s

• No CEMS or PEMS at either facility• NOx monitors installed solely as primary devices for

controlling urea injection.• Six (6) hour compliance tests for all priority pollutants

required every 3-5 years for each engine• Semi-annual 21-minute compliance tests required semi-

annually for NOx and CO for all engines (other than those undergoing full compliance tests)

• No NPDES or Stormwater Permits required; conditionally exempt small quantity generator of hazardous wastes

Plains End Overview cont…

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• Based on our experience, Plains End has several “lessons learned” we’d like to share

• This presentation will focus on many of these in the areas of:• Construction development;• Operations and maintenance considerations;• Safety and security; and• Environmental compliance.

Introduction

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Lessons Learned: Construction Development

• Consider major maintenance (costs, manufacturer support, logistics) from initial design basis- not down the road.

• Consider if your initial investment takes advantage of all current manufacturer recommendations; avoid surprises and/or costly retrofits

• Consider if you will be able to operate and maintain the plant that you’re handed following construction, with full accessibility (e.g. catalyst maintenance); flexibility (e.g., fall protection); adaptability to local conditions (wind, rain/snow, temperatures, e.g., cooling water/glycol system)

• Consider options to manage parasitic load (e.g., solar)• Consider your location/operation and adjacent areas (now

and in 10 years); neighbors, schools, etc. How will you be viewed/accepted? Are you glad you avoided things like ammonia and chlorine?

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Lessons Learned: Operations/Maintenance Considerations

• Consider your ability to capture meaningful history/trends, and to manage run hour versus time-based maintenance. How prepared is the plant to forecast and schedule major maintenance.

• Consider your manning. What if you are challenged with reductions? Do you have data to support your recommendations that support both safety/risks and potential/hidden costs? Have you reached out to experts to prepare?

• Consider your current systems (e.g., DCS)-are you prepared for obsolescence?

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Lessons Learned: Safety/Security

• Plains End is a VPP Star Site. It is a mature safety management system that mandates team work, sets the tone for operations, and puts safety at the forefront where it belongs.

• Consider plant and cyber security. As an example for cyber security, consider necessity for remote access to DCS and potential security risks; consider robustness of all firewalls; and consider any and all links between business and control networks and how security is maintained. Do not rely solely on “read-only” capability as a means of maintaining security!!

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Lessons Learned: Environmental Compliance

• Pay attention to language in environmental permits (Plains End only has a Title V Air Permit)

• Pay attention to “manufacturer’s guaranties” or realistic operating parameters relative to environmental limits, when developing initial permits

• Be proactive in managing wastes! Try to eliminate hazardous wastes with equivalent substitutions; aim toward waste minimization.

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Questions????????

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NAES Corporation1180 NW Maple StreetSuite 200Issaquah, WA 98027

425.961.4700

www.naes.com