The DOJ said in a notice to be published in the April 29 Federal Register that on April 23, 2014, the consent decree was lodged with the U.S. District Court for the District of the Virgin Islands, St. Croix Division. The agreement covers the Estate Richmond Generating Facility.
The consent decree resolves Clean Air Act violations alleged in an amended complaint filed by the United States on July 9, 2013. The violations alleged concern the authority’s failure to properly operate and/or maintain its water injection systems on its gas turbine units, violation of its PM 10 emissions limits for gas turbine unit 19, failure to perform required audits and maintain required quality data availability, failure to properly operate and calibrate the continuous emission monitoring systems (CEMS) for NOx and carbon monoxide, and failure to properly record emissions and non-compliance.
The consent decree requires VIWAPA to improve its overall operations and maintenance at the St. Croix facility by implementing revised standard operating procedures, a spare parts program to minimize downtime in case of equipment failure, enhanced training and third party and self audits of the water injection system and continuous monitoring systems. The consent decree also requires a $700,000 penalty to be paid within two years of the effective date of the consent Decree. The penalty amount was based upon VIWAPA’s limited financial ability to pay a penalty.
Justice noted that the authority has entered into a contract to modify Units 16, 17, 19 and 20 to have the ability to burn LPG and plans to use LPG as primary fuel at units 16, 17, 19 and 20. Unit 16 is a 21-MW unit (installed in 1981); Unit 17 is a 22-MW unit (installed in 1988); Unit 19 is a 24.5-MW unit (installed in 1994); and Unit 20 is a 24.5-MW unit (installed in 1994).
The facility is permitted, among other things, to operate four oil-fired turbines to generate electricity: Unit 16, Unit 17, Unit 19 and Unit 20. The facility also is permitted, among other things, to operate two heat recovery steam generating (HRSG) units, HRSG Unit 21 and Unit 24, to recover exhaust heat from the oil-fired gas turbines and produce steam. HRSG Unit 21 recovers exhaust heat from Unit 17 to produce steam. HRSG Unit 24 recovers exhaust heat from Unit 16 and/or Unit 20 to produce steam.