the future of electric generating units under the epa’s ... · thank you! • ken weiss, erm +1...
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The Future of Electric Generating Units Under the EPA’s New NSRRules Cross State Air Pollution Rules, Cross-State Air Pollution Rules, and New Clean Air Act Regulations
Brought to you by Winston & Strawn LLP and lEnvironmental Resources Management.
Today’s Speakers
Jay HollowayKen WeissLiz WilliamsonPeter BelmontePeter BelmonteGeorge Holder
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Ken Weiss, ERMLiz Williamson Winston & StrawnLiz Williamson, Winston & StrawnGeorge Holder, ERM
12:00 p.m. – 1:15 p.m. (PST)
1:00 p.m. – 2:15 p.m. (MST)
2:00 p.m. – 3:15 p.m. (CST)
3:00 p.m. – 4:15 p.m. (EST)3 p 4 5 p ( )
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Ken Weiss, ERM
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NSR Reform—Regulatory Scorecard
Scorecard in Effect
10 yr Baseline Emissions Look back NA for Utilities
Actual to Future Actual Methodology Netting a New Issue
Actual PALS
Clean Unit Test Abandoned, Stayed, or Revoked
Pollution Control Project Exclusion Abandoned, Stayed, or Revoked
Flexible Permitting and NSR Green Groups Abandoned, Stayed ,or Revoked
RMRR Bright-Line Test Abandoned, Stayed, or Revoked
Aggregation Rule Abandoned, Stayed, or Revoked
Hourly Test for EGU’s Abandoned, Stayed, or Revoked
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Utility Impacts
• RMRR remains a WEPCO Test• Pollution Control Projects (i.e., SCR) may be
bj Ssubject to NSR• NSR Reform was no help
GHG i th i• GHGs are in the mix
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PSD Applicability Calculations and Title V ConsiderationsConsiderations
Liz Williamson, Winston & Strawn
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New Source Review ProgramNew Source Review ProgramSignificant Emission Rates • Once a source is determined to be major the significance of the • Once a source is determined to be major, the significance of the
emission increase must be evaluated.• The CAA establishes Significant Emission Rates for the six original
criteria pollutants plus any pollutant with a NAAQS standard The criteria pollutants plus any pollutant with a NAAQS standard. The SERs for the six criteria pollutants are as follows:▫ Carbon monoxide (CO): 100 tons/year▫ Nitrogen oxides (NOx): 40 tons/yearNitrogen oxides (NOx): 40 tons/year▫ Sulfur dioxide (SO2): 40 tons/year▫ Ozone: 40 tons of volatile organic compounds (VOCs)/year▫ Lead: 0.6 tons/year/y▫ PM10: 25 tons/year
• Other Pollutants that must be considered in an NSR analysis: H2SO4, H2S, Municipal Waste organics and metals, Municipal Solid 2 4 2 p g pWaste emissions, GHGs (Defined in 40 CFR 52.21 as “significant”).
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NSR Emissions Increases at New NSR Emissions Increases at New Sources• At a new source, if the potential to emit for
any one of the six criteria pollutants is at a rate l t hi h th th l t Si ifi t equal to or higher than the relevant Significant
Emissions Rate threshold specified in the CAAfor that pollutant the control of that pollutant is for that pollutant, the control of that pollutant is subject to NSR.
• Potential to emit is calculated as the Potential to emit is calculated as the emissions that would occur if the source operated 24 hours a day for 365 days a year (8760 hours).
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NSR Emissions Increases at Existing NSR Emissions Increases at Existing Sources• An existing source will not be evaluated under NSR
unless there is a major modification at the source.
• A modification is a physical or operational change• A modification is a physical or operational change.
• A modification is major if the proposed physical or operational change results in a significant emissions operational change results in a significant emissions increase and a significant net increase.▫ Whether an emissions increase is significant is
determined by comparing the baseline actual determined by comparing the baseline actual emissions of the pollutant to the projected actual emissions of the pollutant. “Netting” takes into account contemporaneous increases and account contemporaneous increases and decreases in emissions.
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PSD NSR Permits
• If the project results in a significant net emissions increase at an existing source of a criteria pollutant, the source is subject to PSD and must obtain a the source is subject to PSD and must obtain a permit for the project.
• The PSD permit will require the following:The PSD permit will require the following:▫ Installation of Best Available Control Technology
(BACT)
▫ Air Quality Analysis
▫ Additional Impacts Analysis
P bli I l▫ Public Involvement
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Performing an Emissions Analysis Under Performing an Emissions Analysis Under the Reasonable Possibility Rule• Analyze high two of five-year baseline compared to
conservative projection of five years following the project
• If projection shows more than 50% of the significance • If projection shows more than 50% of the significance threshold for an NSR pollutant, analyze whether the increase is as a result of emissions that could have been accommodated in the baseline period and that are accommodated in the baseline period and that are unrelated to the particular change
• If reasonable possibility (50%) threshold is triggered, then pre-project emissions submission required
• EGUs must follow up with five years of annual emissions data non-EUSGUs only report significant post-project data, non-EUSGUs only report significant post-project annual actual emissions increases
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The Final Tailoring Rule
• Issued on May 13, 2010 – Published in Federal Register on June 3, 2010
• “Tailors” the requirements to focus PSD and Title V • Tailors the requirements to focus PSD and Title V permit requirements on the largest emitting facilities
• Subjects facilities responsible for nearly 70% of the national GHG emissions from stationary sources to CAApermitting requirements
▫ This includes the nation’s largest GHG emitters—power This includes the nation s largest GHG emitters power plants, refineries, and cement production facilities
▫ Small farms, restaurants, and commercial facilities are shielded by this ruleshielded by this rule
Source: EPA
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Pollutants Covered• Sets thresholds for GHG emissions addressing • Sets thresholds for GHG emissions, addressing
emissions from six GHGs:▫ Carbon dioxide (CO2)▫ Methane (CH4)▫ Nitrous oxide (N2O)▫ Hydrofluorocarbons (HFCs)y b ( )▫ Perfluorocarbons (PFCs)▫ Sulfur hexafluoride (SF6)
• The aggregate sum of these six GHGs is the • The aggregate sum of these six GHGs is the identified air pollutant in EPA’s Light-Duty Vehicle Rule, and the associated Endangerment Finding and C C ib Fi diCause or Contribute Finding
Source: EPA15
GHG Pollutants Covered
• To determine applicability, a source’s GHG emissions are calculated as the sum of the six
CO i l t (CO ) b i d gases on a CO2 equivalent (CO2e) basis and compared against the relevant threshold
Source: EPA16
Phase-In Steps: Step 1• January 2 2011 to June 30 2011• January 2, 2011 to June 30, 2011• No new permitting actions due solely to GHG emissions during this
time period; only sources undertaking permitting actions anyway for other pollutants will need to address GHGfor other pollutants will need to address GHG▫ PSD permitting applicability:
“Anyway” sources will be subject to the PSD requirements only if they increase GHG emissions by 75,000 tpy CO2e or morey py 2
▫ Title V permitting applicability: Only those sources currently with Title V permits will address GHGs, and
only when applying for, renewing, or revising their permits
ill b bj i i i b d• No sources will be subject to CAA permitting requirements based solely on GHG emissions
• Covers sources responsible for 65% of total national stationary GHG i isource GHG emissions
Source: EPA17
Phase-In Steps: Step 2• July 1 2011 to June 30 2013• July 1, 2011 to June 30, 2013• Sources subject to GHG permitting requirements under step 1 will
continue to be subject to GHG permitting requirements• In addition sources that emit or have the potential to emit GHGs at • In addition, sources that emit or have the potential to emit GHGs at
or above 100,000 tpy CO2e will also be subject to GHG permitting requirements as follows
• PSD permitting applicability – triggered with construction that • PSD permitting applicability – triggered with construction that increases emissions▫ A newly constructed source (which is not major for another pollutant)
will not be subject to PSD unless it emits 100,000 tpy or more on a CO2ej , py 2
basis ▫ A modification project at a major stationary source will not be subject to
PSD unless it results in a net GHG emissions increase of 75,000 tpy or CO b imore on a CO2e basis
Source: EPA18
Phase-In Steps: Step 2 (cont’d.)• Title V permitting applicability• Title V permitting applicability▫ A GHG emission source (which is not already subject
to Title V) will not be subject to Title V unless it emits t CO b i100,000 tpy or more on a CO2e basis
▫ These newly subject sources must apply within one year after becoming subject to the program, unless the
i i h i li d dlipermitting authority sets an earlier deadline▫ This means that newly subject sources must apply for
a Title V permit on or before July 1, 2012 (which is one p yyear from July 1, 2011)
• Covers sources responsible for nearly 70% of total national stationary source GHG emissionsnational stationary source GHG emissions
Source: EPA19
Phase-In Steps: Step 3• The rule establishes an enforceable commitment to complete The rule establishes an enforceable commitment to complete
another rulemaking no later than July 1, 2012
• We will propose or solicit comment on a possible step 3 of the phase-in plan ▫ EPA will consider, during the implementation of step 2, whether it will
be possible to administer GHG permitting programs for additional sources.
▫ EPA will establish that step 3 would take effect on July 1, 2013, so that EPA will establish that step 3 would take effect on July 1, 2013, so that permitting authorities and sources can prepare for any additional GHGpermitting action.
• Step 3, if different from step 2, will not require permitting of sources with GHG emissions below 50 000 tpy CO ewith GHG emissions below 50,000 tpy CO2e
• We also commit to explore a wide range of streamlining options on which we plan to take comment in the step 3 proposal
• In addition we plan to solicit comment on a permanent exclusion of • In addition, we plan to solicit comment on a permanent exclusion of certain sources from PSD, Title V, or both
Source: EPA20
Phase-in Steps: Further ActionA ill i i f ll il A il • EPA will not require permits for smaller sources until April
30, 2016, or later • The rule establishes an enforceable commitment for EPA to
complete a stud ithin fi e ears projecting the complete a study within five years projecting the administrative burdens that remain for small sources after EPA has had time to develop (and states have had time to adopt) streamlining measures to reduce the permitting p ) g p gburden for such sources
• We will use this study to serve as the basis for an additional rulemaking that would take further action to address small
i t W ki f bl sources, as appropriate. We are making an enforceable commitment to complete this rulemaking by April 30, 2016
• We plan to solicit comment on a permanent exclusion of certain sources from PSD Title V or bothcertain sources from PSD, Title V, or both
Source: EPA21
Permitting Steps Under the Tailoring Rule 2011 2012 2013 2014 2015
• Step 1: Source already subject to PSD “anyway”
2016
(tpy CO2e) New source: 75,000 tpyCO2e and 100/250 tpy GHGs on a mass basisModification: 75,000
• Step 2: Continue step 1 sources plus other large GHG emissions sources New source: 100,000 tpyCO2e and 100/250 tpy GHGs on a mass basis Modification: 75,000
• Step 3: Implementation f t ti l dditi lof potential additional phase‐in and streamlining options
• 5year study: To examine GHG permitting
Study Completeexamine GHG permitting for smaller sources
• Implementation of rule based on 5‐year study
Source: EPA
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Biogenic Sources
• CO2 emissions from biomass-fired and other biogenic sources are generated during the combustion or decomposition of biologically based materialdecomposition of biologically based material▫ Includes facilities that emit CO2 as a result of burning forest
or agricultural products for energy, wastewater treatment and livestock management facilities landfills and and livestock management facilities, landfills, and fermentation processes for ethanol production
• EPA will complete a rulemaking that will defer f b f d d hpermitting requirements for biomass fired and other
biogenic CO2 emissions for three years• (This was to be completed in July, but has been delayed.)(This was to be completed in July, but has been delayed.)
Source: EPA22
New Source Review Summary
• Analyze Projects Critically to Avoid NSRLiability
j hi h fil ? • Is my project high profile? • Is project routine?
D I d t f i i l i ?• Do I need to perform an emissions analysis?• Is my emissions increase due to demand
growth? growth? • How do I add GHGs to my NSR emissions
analysis?analysis?
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Reasonable Possibility Analyses for Reasonable Possibility Analyses for GHGs• Challenge: Need to develop five year baseline
GHGs and CO2e PTE for all existing units C id • Issues to Consider:
▫ Analyze causes of GHG fluctuations▫ Focus on potential new sources of GHGs like ▫ Focus on potential new sources of GHGs like
chemical processes such as FGDs (CO2) and new transmission equipment (SF6)q p ( 6)
▫ Analyze efficiency increases and potential contemporaneous creditable reductions in GHGs
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Reasonable Possibility Analyses for Reasonable Possibility Analyses for GHGs: Closer Look• Baseline is not one size fits all• Options to develop baseline:▫ Is there any direct emissions data for the GHG at the Is there any direct emissions data for the GHG at the
plant▫ Formulas used in GHG Reporting Rule
AP 42 Factors for GHGs▫ AP-42 Factors for GHGs▫ Adjustments due to control equipment on unit▫ Leak rates of GHGs that are held in containers at plant
• Essential to develop a baseline using calculations that will be used in future projections (Apples to Apples comparison)Apples comparison)
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Reasonable Possibility Analyses for Reasonable Possibility Analyses for GHGs: Closer Look
Carbon Dioxide COCarbon Dioxide CO22
• Good news: Many plants have CEMS data, easy d l b lito develop a baseline
• Bad news: The top GHG constituent of concernE l S bb d (CO t d d • Example: Scrubber upgrades (CO2 created due to limestone use in scrubber)
• Result: Must perform actual to projected actual • Result: Must perform actual to projected actual analysis and carefully consider CO2 significant net emissions increases
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Reasonable Possibility Analyses for Reasonable Possibility Analyses for GHGs: Closer Look
Nitrous Oxide (Nitrous Oxide (NN22OO))• Unlikely to have actual emissions data• Evaluate how to calculate – GHG Reporting Rule
formula, AP-42C id SCR SNCR d l t f l t • Consider SCR, SNCR, and apply to formula to show impact of NOx reduction
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Reasonable Possibility Analyses for Reasonable Possibility Analyses for GHGs: Closer Look
Methane (Methane (CHCH44))• Unlikely to have actual emissions data• Evaluate how to calculate – GHG Reporting Rule
formula, AP-42P b bl t i f l fi d b ti • Probably not an issue for coal-fired combustion units
• Requires consideration of other projects at the • Requires consideration of other projects at the major stationary source, e.g., landfill expansions
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Reasonable Possibility Analyses for Reasonable Possibility Analyses for GHGs: Closer Look
Sulfur Hexafluoride (SFSulfur Hexafluoride (SF--6)6)• Unlikely to have actual emissions data
Issue for transmission system Is there • Issue for transmission system – Is there equipment at the stationary source that contains SF-6?
• Probably not an issue for coal-fired combustion unitsR i id ti f l k t f thi • Requires consideration of leak rate of this gas and whether it can be measured
• Isolate as unaffected by the project being Isolate as unaffected by the project being evaluated at the plant
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Reasonable Possibility Analyses for Reasonable Possibility Analyses for GHGs: Closer Look
The Fluorocarbons (The Fluorocarbons (HFCsHFCs and and PFCsPFCs))• Unlikely to have actual emissions data
I d i f l i i d • Industries of concern are not electric power industry (chemical processing, air conditioners, fire fighting)
• Is there equipment at the stationary source that Is there equipment at the stationary source that contains HFCs or PFCs?
• Not an issue for coal-fired combustion units• Requires consideration of leak rate if any is found on
site• Isolate as unaffected by the project being evaluated at • Isolate as unaffected by the project being evaluated at
the plant31
Sample Typical NSR Actual to Projected Actual Analysis Formatp yp j y
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How do GHGs fit into the Typical NSR Actual How do GHGs fit into the Typical NSR Actual to Projected Actual Analysis Format?
• Some GHG pollutants fit (actual or calculated) and some do notO h i f h h d fi• Other options for those that do not fit:▫ In written NSR analysis, explain lack of
relationship to the project in accompanying relationship to the project in accompanying memorandum
▫ To do this, must have enough facts about those , ggases to make this case
▫ Calculate your COe based on numbers only for th th t t l l l t dthose that are actual or calculated
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Title V Under GHG Tailoring Rule
• EPA’s guidance takes the position that GHGReporting Rule Requirements should not be i l d d Titl V it ditiincluded as Title V permit conditions
• Title V Petitions to Object Potential to accelerate BACT sooner than July • Potential to accelerate BACT sooner than July 2011 NSPS proposal deadline
• State GHG requirements are a wild card• State GHG requirements are a wild card• Potential impact of EPA’s delay on biomass
rules?
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GHG BACT ReviewMore than a case study…what the limit should look likeMore than a case study…what the limit should look like
George Holder, ERM
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BACT Definition“ i i li i i (i l di i ibl i i “an emissions limitation (including a visible emission
standard) based on the maximum degree of reduction for each pollutant subject to regulation under the Clean Air Act which would be emitted from any proposed major
i j difi i hi h h stationary source or major modification which the Administrator, on a case-by-case basis, taking into account energy, environmental, and economic impacts and other costs, determines is achievable for such facility through
li i f d i d il bl application of production processes and available methods, systems, and techniques, including fuel cleaning, clean fuels, or treatment or innovative fuel combustion techniques for control of each such pollutant….”
37
Guidance
• EPA guidance document “PSD and Title V Permitting Guidance for Greenhouse Gases” released November 2010; Revised March 2011released November 2010; Revised March 2011▫ Heavy reliance on energy efficiency▫ Add-on controls must be considered including CCS▫ No “Redefining” the source▫ No Redefining the source
• Additional EPA guidance documents also released for seven sectors, including coal-fired EGU with more specific discussions of how to address BACT▫ Documents focus on techniques to be considered as
opposed to defining BACT (i.e., information source)pp g ( , )
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Experience to Date
EPA Comment Letters on Proposed GHGPermitting Actions at: ghttp://www.epa.gov/nsr/ghgcomment.html
As of December 2011 – 24 permits issuedAs of December 2011 24 permits issued
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GHG BACT Issues
• Need a TPY limit?• What averaging time? • How do you demonstrate compliance?• What does efficiency really mean?
Wh i h ld d d i h S d • What in the world do we do with Startup and Shutdown efficiency?What happens to efficiency over time?• What happens to efficiency over time?
• If I perform maintenance on my unit to keep the efficiency up is that RMRR?efficiency up, is that RMRR?
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Project Purpose
• “Provide reliable and affordable power”• Defined power generation modes (Baseload, Core Load
Following, Seasonal Load, Peaking, Reserve)g, , g, )• Must maintain flexibility - A highly efficient unit that may be
fully utilized, but operational capability to perform in a load following mannerfollowing manner
“The business case for this unit depends on the flexibility to be bl t d t b th i Th f th itti able to respond to both scenarios. Therefore, the permitting
case must account for the most conservative scenario for the deployment of the unit which includes the less efficient core l d f ll i d d l d d f i ”load following or reduced load mode of operation”
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Project Overview• Entergy Ninemile Point Unit 6• Entergy Ninemile Point Unit 6• Combined Cycle, Gas Turbine• 2 x 1, 7FA Class• Duct Firing• Supplemental ULSD Firing• Other GHG Sources:• Other GHG Sources:▫ Natural Gas Auxiliary Boiler▫ Diesel Emergency Generator▫ Diesel Emergency Firewater Pump
• Decommissioned two existing natural gas fired boilersboilers
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BACT Overview
• CCS considered, available, technically infeasible, eliminated Step 2 (Note EPA has made clear that CCS is now considered feasible)
• Initially used Step 4 to further argue against CCS using other adverse environmental impacts, logistical issues, and relative expense but that approach was rejected without a cost expense, but that approach was rejected without a cost effectiveness number. Today – that is the path forward. Note – Wolverine Power used $5/ton
E Effi i• Energy Efficiency▫ Because of 2 x 1 configuration, power from steam turbine
generator cannot be individually attributed to either GT – capped h dapproach used.
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… And, The Limit
7,630 BTU/kWHr7,630 BTU/kWHr
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The Actual Permit Language
• From the PSD Permit:
“BACT for control of Greenhouse Gas emissions from the Ninemile CCGT project shall be to properly operate and perform necessary routine maintenance repair and replacement routine maintenance, repair, and replacement at Unit 6 to maintain heat efficiency so that the gross heat rate shall be at or below 7,630 gross heat rate shall be at or below 7,630 BTU/kWHr (HHV) based on an annual average.”
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Monitoring?
• For mass based limits, CO2 CEMS doesn’t address other pollutants.
d h l ll f i d • Need the long term average to allow for periods of less efficient operation – core load following, maybe wintertime operationmaybe wintertime operation.
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The TV Monitoring Language“Permittee shall measure and record both the total fuel input of Natural Gas and ultra low sulfur diesel (ULSD) (0.0015 wt%) fed to RLP025, CCGT-6A– Combined Cycle Unit 6A, and RLP026 CCGT-6B – Combined Cycle Unit 6B using fuel flow meters certified in accordance with 40 CFR Part 75 The 6B, using fuel flow meters certified in accordance with 40 CFR Part 75. The total gross power generation shall be directly measured at the units, RLP025 and RLP026. The total gross heat rate shall be determined by dividing the total gross power generation by the total fuel input. Total gross heat rate, gross power generation, and the fuel input data recordkeeping by electronic or hard copy monthly. Keep records of the total gross heat rate, gross power generation, and the fuel input each month, as well as the total gross heat rate, gross power generation, and the fuel input for the last gross heat rate, gross power generation, and the fuel input for the last twelve months. Submit report: Due annually, by the 31st of March. Report the total annual gross heat rate for the preceding calendar year.”
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How We Got There…Gross Heat Annual
Design Heat Balance Operating Case
Gross Power (kW)
Gross Heat Rate
(Btu/kWHr) (HHV) 1
Annual Operating
Time (Hours) 2
Annual Fuel Input
(MMBtu)Annual Gross
Power (kW-Hr)Gas Fired Operation w/Gas Fired Operation w/ HRSG Duct Firing 564,103 6,766 3,500 13,357,747 1,974,360,500Oil Fired Operation 575,878 7,079 500 2,038,311 287,939,000Reduced Load Gas Fired Operation 3 303 160 7 949 4 237 10 209 423 1 284 397 972Operation 303,160 7,949 4,237 10,209,423 1,284,397,972Startup and Shutdown 4 0 - 523 165,559 0Subtotal - - 8,760 25,771,059 3,546,697,472Total Annual Gross Heat Rate (Btu/kWHr) (HHV) 7,266Degradation Penalty (5%) 5 363Total Annual Gross Heat Rate (Btu/kWHr) (HHV) 7,630
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Footnotes/Assumptions
1. Gross Heat Rate Preliminary2. DB Operation is inconsistent between this calcuation and
the criteria pollutant calculation; Hours are not a limitationp ;3. Reduced load is greater than 60% operation but less and
full load4 SU/SD from typical vendor supplied curves and includes SU 4. SU/SD from typical vendor supplied curves and includes SU
hold times5. “The degradation penalty envisions a natural decrease in
it ffi i ti ” I l d d id d d t unit efficiency over time.” Includes vendor provided data on the GT and engineering judgment for other equipment including the HRSG and steam generator
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Wh t SWhat Says…
59345934
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How We Got There…G
Gross Heat Rate
Annual Operating A l l
Design Heat Balance Operating Case
Gross Power (kW)
Rate (Btu/kWHr)
(HHV) 1
Operating Time
(Hours) 2
Annual Fuel Input
(MMBtu)Annual Gross
Power (kW-Hr)Gas Fired Operation w/ HRSG Duct Firing 564 103 6 766 3 500 13 357 747 1 974 360 500HRSG Duct Firing 564,103 6,766 3,500 13,357,747 1,974,360,500Oil Fired Operation 575,878 7,079 500 2,038,311 287,939,000Reduced Load Gas Fired Operation 3 303,160 7,949 4,237 10,209,423 1,284,397,972
4Startup and Shutdown 4 0 - 523 165,559 0Subtotal - - 8,760 25,771,059 3,546,697,472Total Annual Gross Heat Rate (Btu/kWHr) (HHV) 7,266Degradation Penalty (5%) 5 363g y ( ) 363Total Annual Gross Heat Rate (Btu/kWHr) (HHV) 7,630
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BACT for Other Sources40 CFR Part 98 Tables C-1 and C-2
Source CO2 (lb/MMBtu) CH4 (lb/MMBtu) N2O (lb/MMBtu)
Aux Boiler 117 0.0022 0.0002
E Gen 163 0.0061 0.0014
FW Pump 163 0.0061 0.0014p 3 4
• Avoids a TPY limit• Natural Gas fired Auxiliary Boiler – “Proper operation and good combustion
i d ff Th fi i i i i l f l practices produces two effects. The first is to minimize natural gas fuel consumption by reducing energy waste as much as possible. The second is to lower the GWP effect by converting more CH4 into CO2.”
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EPA’s Comments
EPA Comment Letters on GHG Permitting Actionshttp://www.epa.gov/nsr/ghgcomment.html
It’s not there…
08/10/2011 Crawford Renewable Energy (PDF) (2pp 70k)08/10/2011 Crawford Renewable Energy (PDF) (2pp, 70k)08/16/2011 Showa Denko (PDF) (2pp, 87k)
09/12/2011 Abengoa Bioenergy (PDF) (8pp, 402k)09/12/2011 Abengoa Bioenergy (PDF) (8pp, 402k)
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Why it worked?
• Collaboration▫ Team with LDEQ with EPA
Q i h d i h d kfl ▫ Two LDEQ meetings; hand-in-hand workflow through the approval process
• Preplanning• Preplanning• Managing expectations• Educating the Project Team• Educating the Project Team• Inherently green project• Early?Early?
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Takeaways — Universal Comments
• EPA except in very unusual circumstances will insist on CO2eemissions limits
• Averaging time for GHG should be 12-month rolling averageg g g g• The Agency will require consideration of CO2 continuous
emission monitors and documented approach to other GHGs• Don’t forget to specify test methods for all pollutants • Don t forget to specify test methods for all pollutants
including GHGs• Address emissions during startup and shutdown
S b id d b i lik l i l• CCS must be considered but is likely not economical• EPA must have a check-list for review
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Takeaways (2) — The Unusual• NSCR may be preferable to SCR due to N2O reductions – See U.S. Nitrogen
Permit• Don’t forget non-traditional sources such as:
Fi d t S C f d R bl E▫ Fire pumps and emergency generators – See Crawford Renewable Energy▫ Circuit Breakers which may be fugitive source of SF6 - See Hoosier Energy and
TEC (draft IDEM permit)
• For uncertain GHG emissions, include a “conservative” emissions limit as ,BACT and adjust downwards based on stack testing – See Elizabethtown Energy
• Permits should have ton per year and ton/megawatt-hour limits – See K tt R i P j tKennecott Repowering Project
• Carbon Capture is commercially available for low concentration streams (8 to 12%, such as gas turbines) – See University of Wisconsin
56
Hopeful Recommendations
• Don’t accept everything you hear• With a little planning you can negotiate• A good technical argument helps• Work with your regulators (hopefully )
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