TECHNICAL FACT SHEET November 9, 2018

Transcription

1 Lansing Bard f Water and Light Page 1 PROPOSED Permit t Install N Nvember 9, 2018 Purpse and Summary TECHNICAL FACT SHEET Nvember 9, 2018 The Michigan Department f Envirnmental Quality (MDEQ), Air Quality Divisin (AQD), is prpsing t act n Permit t Install (PTI) applicatin N frm Lansing Bard f Water and Light (BWL). The permit applicatin is fr the prpsed installatin and peratin f a new natural gas-fired cmbined-cycle (NGCC) pwer plant. The prpsed prject is subject t permitting requirements f the MDEQ s Rules fr Air Pllutin Cntrl and state and federal Preventin f Significant Deteriratin (PSD) regulatins. Prir t acting n this applicatin, the AQD is hlding a public cmment perid and a public hearing, if requested in writing, t allw all interested parties the pprtunity t cmment n the prpsed PTI. All relevant infrmatin received during the cmment perid and hearing, if held, will be cnsidered by the decisin maker prir t taking final actin n the applicatin. Backgrund Infrmatin BWL is a municipally-wned public utility which prvides utility services t the greater Lansing regin in Michigan. Currently, BWL generates electricity frm tw cal-fired pwer plants, Eckert and Ericksn, bth lcated in the Lansing area. The new NGCC pwer plant is prpsed t be lcated adjacent t the Ericksn plant at 3725 Suth Canal Rad, Lansing, Ingham Cunty, Michigan. Fr regulatry purpses the tw plants will be cnsidered a single statinary surce. The Ericksn plant is currently authrized t perate under Renewable Operating Permit (ROP) N. MI-ROP-B The new plant will supplement BWL s renewable energy resurces and allw BWL t retire the existing Eckert and Ericksn plants. It will have a capacity f 250 megawatts (MW) f electricity t meet baselad and cycling generatin needs in the Greater Lansing regin. Prpsed Facility and Present Air Quality BWL is prpsing t install tw (2) cmbustin turbine generatrs (CTG). Each CTG is cnnected t a heat recvery steam generatr (HRSG), creating a single emissin unit, which is referred t as a CTG/HRSG train. T reduce emissins f nitrgen xides (NO x), the high efficiency CTG/HRSG trains will be equipped with dry lw-no x burners (DLNB) and selective catalytic reductin (SCR), and t reduce the emissins f carbn mnxide (CO) and vlatile rganic cmpunds (VOCs), each train will be equipped with an xidatin catalyst. The new NGCC plant will cnsist f the fllwing equipment: Tw (2) natural gas-fired CTGs rated at 667 millin British thermal units per hur (MMBtu/hr) each, capable f perating in cmbined-cycle r simple-cycle cnfiguratin; Tw (2) HRSGs equipped with duct burners rated at 204 MMBtu/hr each; One (1) steam turbine generatr (nn-emissive); One (1) natural gas-fired simple-cycle CTG rated at 667 MMBtu/hr fr peratin during perids f high demand and cycled t supprt intermittent renewable generatin; One (1) natural gas-fired auxiliary biler rated at 99 MMBtu/hr;

2 Lansing Bard f Water and Light Page 2 PROPOSED Permit t Install N Nvember 9, 2018 Tw (2) emergency reciprcating internal cmbustin engines (RICE) serving generatrs rated at 1 MW and 4 MW, respectively; One (1) diesel-fueled fire pump RICE rated at 315 hrsepwer (hp); One (1) wet mechanical draft cling twer equipped with drift eliminatrs; and Varius strage tanks fr diesel fuel and SCR reagent. The mechanics f a CTG requires inlet air t enter the CTG where it is cmpressed, mixed with natural gas, and ignited. This prcess causes the air t expand, creating pressure that turns the CTG blades. The spinning blades are attached t a shaft, which turns a generatr and creates electricity. When perating the CTG/HRSG trains in cmbined-cycle mde, the ht exhaust frm each turbine (in excess f 800 degrees Fahrenheit ( F)) is discharged int its respective HRSG where the heat is used t generate steam. Each HRSG will be equipped with a natural gas-fired duct burner t prvide additinal steam prductin fr delivery t the steam turbine generatr (STG). The CTG/HRSG trains will be cnsidered a 2 x 1 cnfiguratin, meaning there are tw (2) CTG/HRSG trains that exhaust steam t a single STG. The natural gas-fired auxiliary biler will facilitate startup f the CTG/HRSG trains and prvide steam t the STG seals. It will nt prduce high pressure steam fr use in electric generatin. The tw (2) emergency RICE units will be used in the event f an emergency situatin when electric service is interrupted. They will perate t facilitate safe shutdwns, during lss f electric grid events, and during rutine maintenance checks and readiness testing. The applicatin prpsed fur (4) emergency RICE units, tw (2) natural gas-fired and tw (2) diesel-fired. BWL nly intends t install tw units, hwever at this time, they are nt sure which type will be utilized. A diesel-fired RICE driven fire pump which will prvide fire suppressin during an emergency event will als be installed. The wet mechanical draft cling twer will be used t cl recirculating water frm the prpsed equipment and will cnsist f five (5) cells. Water frm the cling twer will circulate thrugh the STG cndenser t cndense steam that is exhausted frm the STG. Additinally, water frm the cling twer will circulate thrugh a heat exchanger t cl the plant s clsed cycle cling water system. The tw warmed streams f cling water will be cmbined and flw back t the cling twer. At the cling twer, the warmed circulating water will reject heat t the atmsphere thrugh the prcess f evapratin f a prtin f the warmed water. The prpsed NGCC plant will be lcated in Eatn Cunty which is currently meeting all f the Natinal Ambient Air Quality Standards (NAAQS) set by the United States Envirnmental Prtectin Agency (USEPA). The air quality standards are fr CO, nitrgen dixide (NO 2), zne, particulate matter equal t r less than 10 micrns in diameter (PM10), particulate matter equal t r less than 2.5 micrns in diameter (PM2.5), sulfur dixide (SO 2), and lead. All f the standards are set at levels designed t prtect public health. Pllutant Emissins The prpsed NGCC plant will be lcated at the same statinary surce as the existing BWL Ericksn plant. As the existing statinary surce is cnsidered majr under the PSD regulatins fr several pllutants, the new NGCC plant will be subject t PSD fr each regulated pllutant whse ptential emissins exceed the significant emissin rate (SER). The fllwing table prvides the estimated emissins fr each regulated pllutant frm the prpsed prject and their respective SER:

3 Lansing Bard f Water and Light Page 3 PROPOSED Permit t Install N Nvember 9, 2018 Pllutant Table 1: Prject Ptential Emissins Summary Estimated Emissins Tns per Year (tpy)* PSD Significant Emissin Rate (SER) (tpy) Subject t PSD Review? NO x Yes CO Yes Particulate Matter N (PM) PM Yes PM Yes SO N Lead N VOCs Yes Sulfuric acid mist (H 2SO 4) Greenhuse Gases (GHGs) as carbn dixide equivalents (CO 2e)** ,254 75,000 * These values include start-up and shutdwn emissins frm the tw CTG/HRSG trains. ** A recent decisin by the Supreme Curt (Utility Air Regulatry Grup v. U.S. EPA), N (June 23, 2014) determined that PSD review fr GHGs is nly required if ne r mre f the ther regulated new surce review pllutants exceeds a PSD threshld. During startup, the shrt-term emissin rate f sme pllutants may increase. One item that affects these emissins is the length f time the CTG is shut dwn. The lnger the shutdwn perid, the lnger the startup perid. T calculate emissins frm the prpsed cmbined-cycle plant, CTG startups were divided int three categries: a cld startup when the CTG has been shut dwn fr mre than 72 hurs; a warm startup when the CTG has been shut dwn fr a perid f 8 t 72 hurs; and a ht startup when the CTG has been shut dwn fr less than 8 hurs. Ptential emissins assciated with startup and shutdwn f the CTGs were develped using vendr-supplied infrmatin. In additin t emissins, the vendr infrmatin prvides the event duratin and dwntimes assciated with startup events (e.g., the minimum number f hurs the CTG wuld be ff befre a startup). With the exceptin f CO emissins, during warm and ht starts, emissins frm these events are self-crrecting n an annual basis. Self-crrecting means that the emissins fr each startup and shutdwn sequence, incrprating the minimum dwntime required t define that type f startup, are less than the crrespnding full lad steadystate emissin rate. PM/PM10/PM2.5 and SO 2 emissins are driven by fuel cnsumptin and, because fuel cnsumptin during startup and shutdwn is less than full lad steady-state peratin, startup and shutdwn emissins fr these tw pllutants are self-crrecting fr all types f startups. In ther wrds, when startup and shutdwn is self-crrecting steady-state peratins becme the wrst-case perating scenari. The emissins values shwn in the abve Table 1 include startup and shutdwn as discussed in this paragraph. N Yes

4 Lansing Bard f Water and Light Page 4 PROPOSED Permit t Install N Nvember 9, 2018 Key Permit Review Issues Staff evaluated the prpsed prject t identify all state rules and federal regulatins which are, r may be, applicable. The tables in Appendix 1 summarize these rules and regulatins. Preventin f Significant Deteriratin (PSD) Regulatins Based n the ptential emissins, the prject is subject t PSD review fr NO x, CO, PM10, PM2.5, VOCs, and GHGs. Review under the PSD regulatins requires Best Available Cntrl Technlgy (BACT), a surce impact analysis, an air quality impact analysis, and an additinal impact analysis fr each regulated air pllutant fr which the prject will result in significant emissins. The PSD majr surce threshld is 250 tpy fr each f the regulated pllutants unless the surce is ne f 28 surce categries listed in the PSD regulatins, then the PSD majr surce threshld is 100 tpy. Once a surce is majr fr a single regulated new surce review pllutant, it is majr fr ther regulated new surce review pllutants when the emissins are abve their SER. The emissins assciated with the prpsed prject are summarized in Table 1 abve. The BACT review determined bth specific emissin limits and add-n air pllutin cntrl equipment requirements. A summary f the BACT analysis and the specific BACT emissin limits and add-n air pllutin cntrl equipment requirements is addressed in Appendix 2. Minr/Majr Mdificatin Determinatin fr Attainment Pllutants The facility is an existing PSD majr statinary surce. A mdificatin at the facility where the emissins f any regulated pllutant will increase by mre than the significant level fr that pllutant results in the mdificatin being subject t PSD requirements fr that pllutant. BWL is lcated in Eatn Cunty which is currently in attainment fr all pllutants. The prpsed prject is subject t PSD because the emissin increase fr NO x, CO, PM10, PM2.5, VOCs, and GHGs are each mre than their respective significant level. Please refer t Table 1 abve fr a summary f the prpsed emissins f each regulated pllutant. Federal NSPS Regulatins New Surce Perfrmance Standards (NSPS) were established under Title 40 f the Cde f Federal Regulatins (40 CFR) Part 60. Several pieces f equipment fr the prpsed NGCC plant will be subject t the varius NSPS standards. The CTG/HRSG trains are subject t: 40 CFR Part 60, Subpart KKKK, Standards f Perfrmance fr Statinary Cmbustin Turbines. Subpart KKKK cntains a NO x emissin limit, a sulfur fuel cntent restrictin, and assciated cmpliance requirements. If the CTG is assciated with HRSGs r duct burners, then the entire CTG/HRSG train must cmply with the NO x emissin limit. 40 CFR Part 60, Subpart TTTT, Standards f Perfrmance fr Greenhuse Gas Emissins fr Electric Generating Units. Subpart TTTT cntains a carbn dixide (CO 2) emissin standard and an assciated calculatin methd.

5 Lansing Bard f Water and Light Page 5 PROPOSED Permit t Install N Nvember 9, 2018 The auxiliary biler is subject t: 40 CFR Part 60, Subpart Dc, Standards f Perfrmance fr Small Industrial- Cmmercial-Institutinal Steam Generating Units. Subpart Dc requires fuel usage mnitring. The diesel-fired emergency RICE and fire pump RICE are each subject t: 40 CFR Part 60, Subpart IIII, Standards f Perfrmance fr Statinary Cmpressin Ignitin Internal Cmbustin Engines. Subpart IIII cntains nn-methane hydrcarbn (NMHC) + NO x, CO, and PM emissin limits and assciated cmpliance requirements. The natural gas-fired emergency RICE are each subject t: 40 CFR Part 60, Subpart JJJJ Standards f Perfrmance fr Statinary Spark Ignitin Internal Cmbustin Engines. Subpart JJJJ cntains NO x, CO, and VOC emissin standards and assciated cmpliance requirements. Federal NESHAP Regulatins Natinal Emissin Standards fr Hazardus Air Pllutants (NESHAP) were established under 40 CFR Part 63. A majr surce under the NESHAP is defined as having ptential emissins f 10 tpy fr a single hazardus air pllutant (HAP) r 25 tpy fr all HAPs cmbined. An area surce has ptential HAP emissins belw the majr surce values. The ptential HAP emissins frm the entire prpsed facility will be belw the majr surce values fr bth the single HAP and ttal HAP threshlds. The Ericksn Statin facility is cnsidered an existing surce f HAPs. Therefre, the new prpsed NGCC plant will als be a majr surce f HAP emissins. Sme f the equipment at the prpsed NGCC plant will be subject t the varius NESHAP standards. The CTG/HRSG trains and the simple-cycle CTG are subject t: 40 CFR Part 63 Subpart YYYY, Natinal Emissin Standards fr Hazardus Air Pllutants fr Statinary Cmbustin Turbines at majr surces f HAPs. BWL is nly required t cmply with the initial ntificatin requirements f 40 CFR until U.S. EPA takes final actin t require cmpliance; the ther requirements f NESHAP Subpart YYYY d nt apply under the stay f the rule. The auxiliary biler is subject t: 40 CFR Part 63 Subpart DDDDD, Natinal Emissin Standards fr Hazardus Air Pllutants fr Industrial, Cmmercial, and Institutinal Bilers and Prcess Heaters. Subpart DDDDD requires that tune-ups be perfrmed n the unit. The diesel-fueled emergency RICE and fire pump RICE are subject t: 40 CFR Part 63 Subpart ZZZZ, Natinal Emissins Standards fr Hazardus Air Pllutants fr Statinary Reciprcating Internal Cmbustin Engines. Subpart ZZZZ applies t bth majr and area surces. The nly requirement fr the engines is t cmply with NSPS Subpart IIII (fr cmpressin ignitin engines) r NSPS Subpart JJJJ (fr spark ignitin engines).

6 Lansing Bard f Water and Light Page 6 PROPOSED Permit t Install N Nvember 9, 2018 Rule 224 TBACT Analysis Michigan Air Pllutin Cntrl Rule R requires Best Available Cntrl Technlgy fr txics (TBACT). Hwever, the requirements f Rule 224 d nt apply t any prcess subject t a federal NESHAP. In additin, the requirements f Rule 224 d nt apply t txic air cntainments (TACs) that are particulates r VOCs and are in cmpliance with BACT. As the prpsed RICE and bilers NESHAPs, Subparts ZZZZ and DDDDD, respectively they are nt subject t TBACT. Each ther piece f prpsed equipment underwent a tp-dwn BACT analysis fr VOC and PM10/PM2.5, and the nly TACs that are nt cvered thrugh the PSD BACT review were ammnia and H 2SO 4. Ammnia is released during ptential ammnia slip frm the SCR prcess utilized fr NO x cntrl n the CTG/HRSG trains. BWL stated that TBACT fr reductin f ammnia slip is an efficiently designed and managed SCR system, and the AQD cncurred with this determinatin. H 2SO 4 is frmed as a result f the reactin f sulfur trixide (SO 3) with water, either in the flue gas stream r in the atmsphere after discharge. SO 3 is frmed as a result f the thermal xidatin f sulfur cmpunds in the fuel. Cntrl technlgies used t cntrl sulfur cmpunds will als cntrl H 2SO 4. Hwever, natural gas usually cntains trace amunts f sulfur and sulfur cntrl is nt cst effective based n the lw mass emissins. A TBACT cst analysis fr H 2SO 4 was perfrmed and BWL determined that additinal cntrl was nt cst effective. TBACT fr H 2SO 4 is a material limit f 1 gr/100 scf f sulfur in the natural gas. The AQD cncurred with this determinatin. Rule 225 Txics Analysis The Michigan Air Pllutin Cntrl Rules require the ambient air cncentratin f TACs be cmpared against health-based screening levels. The AQD staff reviewed BWL s air quality mdeling and evaluatin f TAC impacts. The review fund that all TACs shw impacts less than 67 percent f their respective established health-based screening levels and will cmply with the requirements f Rule 225. Rule 702 VOC Emissins This rule requires an evaluatin f the fllwing fur items t determine what will result in the lwest maximum allwable emissin rate f VOCs: a. BACT r a limit listed by the department n its wn initiative b. New Surce Perfrmance Standards (NSPS) c. VOC emissin rate specified in anther permit d. VOC emissin rate specified in the Part 6 rules fr existing surces The VOC emissins are als subject t PSD review fr this prject. A tp dwn BACT analysis was perfrmed under the PSD regulatins fr all VOC surces. Specific VOC emissin limits and cntrl equipment requirements were determined t represent BACT under this review. The PSD BACT determinatins satisfy the BACT requirements per Rule 702(a). The RICE units have limits f nnmethane hydrcarbns (NMHC) + NOx frm the NSPS. NMHC are VOCs and VOCs have upper limits determined by the NSPS fr the RICE units. These values cincide with the PSD BACT determinatin fr VOCs fr the RICE units.

7 Lansing Bard f Water and Light Page 7 PROPOSED Permit t Install N Nvember 9, 2018 Criteria Pllutants Mdeling Analysis Cmputer dispersin mdeling was perfrmed t predict the impacts f air emissins frm NO x, CO, PM10, PM2.5, and SO 2. NO x refers specifically t nitrgen xide and NO 2, with the larger prtin being NO 2. NO 2 is a highly reactive gas and is the pllutant fr which the USEPA established a NAAQS. Emissins frm the prpsed facility were evaluated against bth the NAAQS and the PSD Increments. The NAAQS are intended t prtect public health. The PSD Increments are intended t allw industrial grwth in an area, while ensuring that the area will cntinue t meet the NAAQS. T determine the predicted impacts, the dispersin mdeling cmpared the wrst-case impact fr each criteria pllutant, fr each averaging time, t the maximum levels allwed. The wrstcase estimated emissins frm startup and shutdwn at the CTG/HRSG trains were used fr NO x and CO. The emergency RICE units and the fire pump RICE unit have prpsed peratinal restrictins f 500 and 100 hurs per year, respectively. Each RICE unit als has daily perating hurs restrictins f 4 hurs per day, except during emergency cnditins and perfrmance testing. The first step in this evaluatin is t determine the predicted impacts frm the prpsed prject. After the impacts are determined, they are cmpared t the applicable PSD Significant Impact Levels (SILs). If the prject impacts are less than the SIL, then n further review is required. The fllwing table cnsiders the ptential emissins frm the prpsed prject fr NO x, CO, PM10, PM2.5, and SO 2 and cmpares them t their respective SILs. Table 2: Significant Impact Levels (SIL) Pllutant Averaging Perid SIL (ug/m 3 ) Ttal Maximum Impact Belw SIL? (ug/m 3 ) 1-Hur N NO 2 Annual N CO 1-Hur 2,000 1,434 Yes 8-Hur N 1-Hur Yes SO 2 3-Hur N 24-Hur 5 13 N Annual Yes PM10 24-Hur N Annual N PM Hur N Annual N As the mdeled impacts fr NO x, CO (8-hur average), SO 2 (3-hur and 24-hur averages), PM10 and PM2.5 exceeded their respective SILs, facility-wide NAAQS and PSD Increment mdeling analysis was required fr thse pllutants. The PSD Increments are cmpared against the ttal facility impact plus ther increment cnsuming facilities nearby. In the NAAQS analysis, the ttal facility impact includes additinal nearby facilities, r ffsite surces. The ttal facility impact and the backgrund

8 Lansing Bard f Water and Light Page 8 PROPOSED Permit t Install N Nvember 9, 2018 cncentratins, which is data frm ambient air mnitrs, are summed and cmpared t the NAAQS. As the fllwing tables shw, the emissins f NO x, CO, SO 2, PM10, and PM2.5 frm the prpsed prject will meet their respective PSD Increments and NAAQS. Table 3: PSD Increment Mdeling Impacts Pllutant Averaging Time PSD Increment (µg/m 3 ) Predicted Impact (µg/m 3 ) Percent f Increment (%) NO 2 Annual PM10 24-Hur Annual PM Hur Annual SO 2 3-hur hur Please nte, there is nt a PSD Increment fr NO 2 n a 1-hur average. Table 4: NAAQS Mdeling Impacts Pllutant Averaging Time NAAQS Predicted Percent f (µg/m 3 ) Impact (µg/m 3 )* NAAQS (%) NO x 1-Hur Annual CO 8-Hur 10,000 2, PM10 24-Hur PM Hur Annual SO 2 3-Hur 1, *Includes backgrund data. Please nte, there is nt a NAAQS fr PM10 n an annual average r fr SO 2 n a 24-hur average. A secndary frmatin assessment f PM2.5 was perfrmed as required by the USEPA fr PSD applicatins. Secndary frmatin f PM2.5 can ccur frm emissins f SO 2 and NO x, as these criteria pllutants are cnsidered precursrs. The secndary analysis fllwed prpsed methdlgy presented t the USEPA during the 2017 Reginal, State, and Lcal (RSL) Mdelers Wrkshp. The Tier 1 methdlgy used in this assessment added the calculated secndary PM2.5 impact caused by emissins f SO 2 and NO x t the primary PM2.5 NAAQS mdeled impact. This ensures the cmbinatin f primary and secndary impacts still meet the NAAQS standard. There is an 8-hur NAAQS fr zne, but n PSD Increment. Grund-level zne cncentratins are the result f phtchemical reactins amng varius chemical species. The chemical species that cntribute t zne frmatin, referred t as zne precursrs, include NO x and VOC emissins frm bth anthrpgenic (e.g., mbile and statinary surces) and natural surces (e.g., vegetatin). The facility will emit NO x at levels greater

9 Lansing Bard f Water and Light Page 9 PROPOSED Permit t Install N Nvember 9, 2018 than 100 tpy, thus triggering the zne ambient impact analysis requirements f R and 40 CFR The secndary frmatin f zne, r cnversin f the precursrs, is nt instantaneus; it happens ver time and is highly dependent upn weather cnditins. Therefre, the cnversin is ften cmpleted after the precursrs have been dispersed away frm the immediate area. Because f this, zne frmatin is recgnized as a lng-range transprt issue. As a result, there are n effective mdeling methds fr zne fr single surces: the zne mdeling prgrams address larger areas f land and air mvements and therefre must include many surces. T address if a prject may cause r cntribute t a vilatin f the zne NAAQS, the zne precursrs, NO x and VOC are evaluated. BWL fllwed guidance defined in the USEPA guidelines n Air Quality Mdels fr addressing single surce impacts f secndary pllutants. Specifically, BWL used the methdlgy prvided in the USEPA guidance mem, Guidance n the Develpment f Mdeled Emissin Rates fr Precursrs (MERPs) as a Tier 1 Demnstratin Tl fr Ozne and PM2.5 under the PSD Permitting Prgram (12/2/16), t determine the secndary pllutant impact resulting frm their prpsed prject. The zne impact, resulting frm the prpsed prject, was less than the 1.0 parts per billin SIL and is therefre nt expected t cause r cntribute t any vilatin f the zne NAAQS standard. Precnstructin mnitring is required fr at least ne year fr each criteria pllutant prpsed t be emitted that triggers PSD review. Thrugh guidance, the USEPA allws the use f existing reginal data, if representative, as an alternative t the precnstructin mnitring. BWL requested t use existing data and t receive a waiver frm precnstructin mnitring. The AQD determined that the data is representative and granted the waiver request. Additinal Impact Analysis An additinal impact analysis is required fr new majr surces pursuant t 40 CFR 52.21() and Michigan Air Pllutin Cntrl Rule This analysis is necessary t evaluate the impacts frm the prpsed prject n sils, vegetatin, visibility and grwth. The prpsed prject emissins are nt anticipated t have a negative impact n sils, vegetatin, wildlife, r visibility, and t have minimal impact n grwth nce cnstructin is cmpleted. Sils, Vegetatin, and Wildlife The secndary NAAQS have been determined by the USEPA t be prtective f sils, vegetatin, and wildlife. BWL evaluated the secndary NAAQS using dispersin mdeling. All PSD pllutants with secndary NAAQS were belw their respective standards. VOCs and H2SO4 were evaluated thrugh the TAC analysis required in Michigan Air Pllutin Cntrl Rule This evaluatin shwed that the impacts frm the prject are belw their respective health-based screening levels. Visibility Assessments fr visibility impacts are required nly fr Class I areas. The nearest PSD Class I areas t the prpsed plant are 400 km r mre away. Seney Natinal Wildlife Refuge, in Michigan, is apprximately 400 km t the nrth-nrthwest. Mammth Cave Natinal Park in Kentucky is apprximately 630 km t the suth-suthwest. Otter Creek Natinal Wilderness Area and Dlly Sds Natinal Wilderness Area, bth in West Virginia, are apprximately 608

10 Lansing Bard f Water and Light Page 10 PROPOSED Permit t Install N Nvember 9, 2018 km and 603 km t the sutheast. The surce is sufficiently far away that the USEPA des nt require further analysis as n impairment t visibility in the Class I areas is expected t ccur. Grwth The grwth analysis is a prjectin f the cmmercial, residential, industrial, and ther grwth that will ccur in the area due t the cnstructin and peratin f the prpsed surce. Emissins frm cnstructin are expected t be minimal and have limited impact beynd the site bundaries. Emplyment due t cnstructin will be temprary, and the number f permanent jbs will be small. It is predicted t have a minimal effect n area ppulatin and cmmercial grwth. Key Aspects f the Prpsed Permit Cnditins Emissin Limits (By Pllutant) The prpsed permit includes emissin limits fr varius pllutants t make the permit enfrceable and t prtect the air quality standards. Included are PSD BACT emissin limits, as apprpriate, fr NO x, CO, PM10, PM2.5, VOCs, and GHGs as CO 2e. A summary f the BACT analysis is included in Appendix 2. Emissin Cntrl Device Requirements The prpsed permit includes the fllwing emissin cntrl device requirements: Each CTG: Dry lw NO x burners (DLNB) Each CTG/HRSG train: DLNB and SCR fr NO x cntrl. An xidatin catalyst fr CO and VOC cntrl. Auxiliary biler: Lw NOx burners (LNB) and flue gas recirculatin (FGR) fr NO x cntrl. Diesel Fuel Tanks: Submerged fill pipes fr VOC cntrl. Cling Twer: Drift eliminatrs with a maximum drift rate f percent. Usage Limits The prpsed permit nly allws the cmbustin f pipeline quality natural gas in the CTG, HRSG duct burner, auxiliary biler, and the natural gas burning emergency RICE units. The pipeline quality natural gas is required t have a sulfur cntent f n greater than 1 grain per 100 standard cubic feet. The prpsed permit als limits the fuel t ultra-lw sulfur diesel fuel with the maximum sulfur cntent f 15 parts per millin (ppm) ( percent) by weight fr the diesel-fired emergency RICE units and the RICE fire pump unit. Prcess/Operatinal Restrictins The prpsed permit requires BWL t develp a Malfunctin Abatement Plan fr the CTG/HRSG trains, simple-cycle CTG, the auxiliary biler, and emergency RICE units. The plan must include a preventative maintenance prgram and crrective prcedures in the event f an equipment malfunctin r failure. Als, the prpsed permit requires BWL t develp an additinal plan that describes hw emissins will be minimized during startup and shutdwn fr the CTG/HRSG trains, simple-

11 Lansing Bard f Water and Light Page 11 PROPOSED Permit t Install N Nvember 9, 2018 cycle CTG, and the auxiliary biler. The plan must incrprate prcedures recmmended by the equipment manufacturer as well as incrprate standard industry practices. The prpsed permit includes restrictins that limit the peratin f equipment, as fllws: 2,000 hurs per year f HRSG Bypass at each CTG/HRSG train 2,000 hurs per year f peratin fr the simple-cycle CTG 500 hurs per year f peratin fr each emergency RICE unit 100 hurs per year f peratin fr the fire pump RICE unit Als, the emergency RICE unit and the fire pump RICE unit are limited t 4 hurs per day except during emergency cnditins and required stack testing. Testing, Mnitring, and Recrdkeeping Requirements The prpsed permits include emissins testing, mnitring, and recrdkeeping requirements fr all emissin units. CTG/HRSG Trains: The maximum design heat input capacity, n a fuel heat input basis, fr each CTG shall nt exceed 667 MMBTU/hr (higher heating value [HHV]) and fr each duct burner shall nt exceed 204 MMBTU/hr (HHV) at internatinal standards rganizatin (ISO) cnditins. Cntinuus Emissin Mnitring System (CEMS) devices t mnitr and recrd NO x and CO emissins frm each CTG/HRSG train are required. As part f CEMS, a mnitr fr either xygen r CO 2 is als required. Fr HRSG bypass: Stack testing fr NO x and CO frm each CTG are required. Testing fr PM10, PM2.5, and VOC emissin rates are required. Emissins recrds fr NO x, CO, CO 2, and CO 2e fr each CTG/HRSG train are required. Recrds f the fuel usage n an hurly and mnthly basis are required. Recrds f the hurs f peratin in HRSG bypass mde fr each CTG are required. Simple-cycle CTG: The maximum design heat input capacity, n a fuel heat input basis, fr the CTG shall nt exceed 667 MMBTU/hr (HHV) at ISO cnditins. Testing fr NO x, CO, PM10, PM2.5, and VOC emissin rates are required. Emissins recrds fr NO x and CO 2e are required. Recrds f the fuel usage n an hurly and mnthly basis are required. Recrds f the hurs f peratin are required.

12 Lansing Bard f Water and Light Page 12 PROPOSED Permit t Install N Nvember 9, 2018 Auxiliary Biler: The maximum design heat input capacity shall nt exceed 99 MMBTU/hr (HHV) n a fuel heat input basis. Testing fr NO x, CO, PM10, PM2.5, and VOC emissin rates are required. Emissins recrds fr CO 2e fr are required. Recrds f the fuel usage n a mnthly basis are required. Diesel-fired Emergency RICE Units and Fire Pump RICE Unit: Fr the emergency RICE units: The nameplate capacity f the tw RICE generatrs shall nt exceed 1,500 HP and 6,000 HP, respectively. Fr the fire pump RICE unit: The nameplate capacity shall nt exceed 315 brake HP. The fllwing requirements apply t all diesel-fired RICE units: Emissins testing r manufacturer certificatin dcumentatin is required fr NMHC + NO x, CO, and PM emissin rates. Wrk practice standards are required fr PM10 and PM2.5 emissins. Recrds f maintenance activity are required. Recrds f the ttal hurs f peratin and the hurs f peratin during nnemergencies are required. Recrds indicating that the fuel meets the prper NSPS Subpart IIII specificatins. Natural gas-fired Emergency RICE: The nameplate capacity f the tw RICE generatrs shall nt exceed 1,500 HP and 6,000 HP, respectively. Emissins testing r manufacturer certificatin dcumentatin is required fr NO x, CO, and VOC emissin rates. Wrk practice standards are required fr PM10 and PM2.5 emissins. Recrds f maintenance activity are required. Recrds f the ttal hurs f peratin and the hurs f peratin during nnemergencies are required. Cling Twer: Recrds f drift lss frm the cling twer thrugh vendr certificatin. Implementatin f an inspectin and maintenance prgram t ensure prper peratin f the mist/drift eliminatrs is required. Cling Twer: Drift eliminatrs with a maximum drift rate f percent.

13 Lansing Bard f Water and Light Page 13 PROPOSED Permit t Install N Nvember 9, 2018 Federal Regulatins The prpsed permit specifies that cmpliance with certain permit cnditins will cnstitute cmpliance with the respective NSPS and NESHAP fr each emissin unit thrugh required emissin limits, prcess/peratinal restrictins, testing r certificatin, mnitring/recrdkeeping, ntificatins, and reprting. CTG/HRSG Trains and Simple-cycle CTG: 40 CFR Part 60 Subpart KKKK - NSPS fr Statinary Cmbustin Turbines; 40 CFR Part 60 Subpart TTTT - NSPS fr Greenhuse Gas Emissins fr Electric Generating Units; 40 CFR Part 63, Subpart YYYY - NESHAP fr Statinary Cmbustin Turbines. Auxiliary Biler: 40 CFR Part 60 Subpart Dc - NSPS fr Industrial-Cmmercial-Institutinal Steam Generating Units; 40 CFR Part 63, Subpart DDDDD - NESHAP fr Majr Surces: Industrial, Cmmercial, and Institutinal Bilers and Prcess Heaters. Diesel-fired Emergency RICE Units and Fire Pump RICE Unit: 40 CFR Part 60 Subpart IIII - NSPS fr Statinary Cmpressin Ignitin Internal Cmbustin Engines; 40 CFR Part 63, Subpart ZZZZ - NESHAP fr Statinary Reciprcating Internal Cmbustin Engines. Natural gas-fired Emergency RICE Units: 40 CFR Part 60 Subpart JJJJ - NSPS fr Statinary Spark Ignitin Internal Cmbustin Engines; 40 CFR Part 63, Subpart ZZZZ - NESHAP fr Statinary Reciprcating Internal Cmbustin Engines. Cnclusin Based n the analyses cnducted t date, the AQD staff cncludes that the prpsed prject wuld cmply with all applicable state and federal air quality requirements. The AQD staff als cncludes that this prject, as prpsed, wuld nt vilate the federal NAAQS r the federal PSD Increments. Based n these cnclusins, the AQD staff has develped prpsed permit terms and cnditins which wuld ensure that the prpsed facility design and peratin are enfrceable, and that sufficient mnitring, recrdkeeping, and reprting wuld be perfrmed by the applicant t determine cmpliance with these terms and cnditins. If the permit applicatin is deemed apprvable, the delegated decisin maker may determine a need fr additinal r revised cnditins t address issues raised during the public participatin prcess. If yu wuld like additinal infrmatin abut this prpsal, please cntact Ms. Melissa Byrnes, AQD, at

14 Lansing Bard f Water and Light Page 14 PROPOSED Permit N Nvember 9, 2018 State Rule R R R R t R R t R R R R R and R R t R R R R R Appendix 1 STATE AIR REGULATIONS Descriptin f State Air Regulatins Requires an Air Use Permit fr new r mdified equipment that emits, r culd emit, an air pllutant r cntaminant. Hwever, there are ther rules that allw smaller emissin surces t be installed withut a permit (see Rules thrugh belw). Rule als states that the Department can add cnditins t a permit t assure the air laws are met. Outlines the permit cnditins that are required by the federal Preventin f Significant Deteriratin (PSD) Regulatins and/r Sectin 112 f the Clean Air Act. Als, the same types f cnditins are added t their permit when a plant is limiting their air emissins t legally avid these federal requirements. (See the Federal Regulatins table fr mre details n PSD.) New r mdified equipment that emits txic air cntaminants must use the Best Available Cntrl Technlgy fr Txics (T-BACT). The T-BACT review determines what cntrl technlgy must be applied t the equipment. A T-BACT review cnsiders energy needs, envirnmental and ecnmic impacts, and ther csts. T-BACT may include a change in the raw materials used, the design f the prcess, r add-n air pllutin cntrl equipment. This rule als includes a list f instances where ther regulatins apply and T-BACT is nt required. The ambient air cncentratin f each txic air cntaminant emitted frm the prject must nt exceed health-based screening levels. Initial Risk Screening Levels (IRSL) apply t cancer-causing effects f air cntaminants and Initial Threshld Screening Levels (ITSL) apply t nn-cancer effects f air cntaminants. These screening levels, designed t prtect public health and the envirnment, are develped by Air Quality Divisin txiclgists fllwing methds in the rules and U.S. EPA risk assessment guidance. These rules list equipment t prcesses that have very lw emissins and d nt need t get an Air Use permit. Hwever, these surces must meet all requirements identified in the specific rule and ther rules that apply. Limits hw air emissins are allwed t lk at the end f a stack. The clr and intensity f the clr f the emissins is called pacity. The particulate emissin limits fr certain surces are listed. These limits apply t bth new and existing equipment. Material cllected by air pllutin cntrl equipment, such as dust, must be dispsed f in a manner, which des nt cause mre air emissins. Limit the sulfur dixide emissins frm pwer plants and ther fuel burning equipment. Vlatile rganic cmpunds (VOCs) are a grup f chemicals fund in such things as paint slvents, degreasing materials, and gasline. VOCs cntribute t the frmatin f smg. The rules set VOC limits r wrk practice standards fr existing equipment. The limits are based upn Reasnably Available Cntrl Technlgy (RACT). RACT is required fr all equipment listed in Rules thrugh New equipment that emits VOCs is required t install the Best Available Cntrl Technlgy (BACT). The technlgy is reviewed n a case-by-case basis. The VOC limits and/r wrk practice standards set fr a particular piece f new equipment cannt be less restrictive than the Reasnably Available Cntrl Technlgy limits fr existing equipment utlined in Rules thrugh Nitrgen xide emissin limits fr larger bilers and statinary internal cmbustin engines are listed. Prhibits the emissin f an air cntaminant in quantities that cause injurius effects t human health and welfare, r prevent the cmfrtable enjyment f life and prperty. As an example, a vilatin may be cited if excessive amunts f dr emissins were fund t be preventing residents frm enjying utdr activities. Air pllutin cntrl equipment must be installed, maintained, and perated prperly.

15 Lansing Bard f Water and Light Page 15 PROPOSED Permit N Nvember 9, 2018 State Rule R R R t R R t R Preventin f Significant Deteriratin (PSD) Regulatins Best Available Cntrl Technlgy (BACT) R t R and R STATE AIR REGULATIONS Descriptin f State Air Regulatins When requested by the Department, a facility must develp and submit a malfunctin abatement plan (MAP). This plan is t prevent, detect, and crrect malfunctins and equipment failures. A facility is required t ntify the Department if a cnditin arises which causes emissins that exceed the allwable emissin rate in a rule and/r permit. Allw the Department t request that a facility test its emissins and t apprve the prtcl used fr these tests. The PSD rules allw the installatin and peratin f large, new surces and the mdificatin f existing large surces in areas that are meeting the Natinal Ambient Air Quality Standards (NAAQS). The regulatins define what is cnsidered a large r significant surce, r mdificatin. In rder t assure that the area will cntinue t meet the NAAQS, the permit applicant must demnstrate that it is installing the BACT. By law, BACT must cnsider the ecnmic, envirnmental, and energy impacts f each installatin n a case-by-case basis. As a result, BACT can be different fr similar facilities. In its permit applicatin, the applicant identifies all air pllutin cntrl ptins available, the feasibility f these ptins, the effectiveness f each ptin, and why the ptin prpsed represents BACT. As part f its evaluatin, the Air Quality Divisin verifies the applicant s determinatin and reviews BACT determinatins made fr similar facilities in Michigan and thrughut the natin. Applies t new majr statinary surces and majr mdificatins as defined in R These rules cntain the permitting requirements fr surces lcated in nnattainment areas that have the ptential t emit large amunts f air pllutants. T help the area meet the NAAQS, the applicant must install equipment that achieves the Lwest Achievable Emissin Rate (LAER). LAER is the lwest emissin rate required by a federal rule, state rule, r by a previusly issued cnstructin permit. The applicant must als prvide emissin ffsets, which means the applicant must remve mre pllutants frm the air than the prpsed equipment will emit. This can be dne by reducing emissins at ther existing facilities. As part f its evaluatin, the AQD verifies that n ther similar equipment thrughut the natin is required t meet a lwer emissin rate and verifies that prpsed emissin ffsets are permanent and enfrceable. Citatin Sectin 109 f the Clean Air Act Natinal Ambient Air Quality Standards (NAAQS) FEDERAL AIR REGULATIONS Descriptin f Federal Air Regulatins r Requirements The United States Envirnmental Prtectin Agency has set maximum permissible levels fr seven pllutants. These NAAQS are designed t prtect the public health f everyne, including the mst susceptible individuals, children, the elderly, and thse with chrnic respiratry ailments. The seven pllutants, called the criteria pllutants, are carbn mnxide, lead, nitrgen dixide, zne, particulate matter less than 10 micrns (PM10), particulate matter less than 2.5 micrns (PM2.5), and sulfur dixide. Prtins f Michigan are currently nn-attainment fr either sulfur dixide r zne. Further, in Michigan, State Rules t are used t ensure the public health is prtected frm ther cmpunds.

16 Lansing Bard f Water and Light Page 16 PROPOSED Permit N Nvember 9, 2018 Citatin 40 CFR Preventin f Significant Deteriratin (PSD) Regulatins Best Available Cntrl Technlgy (BACT) 40 CFR 60 New Surce Perfrmance Standards (NSPS) 40 CFR 63 Natinal Emissins Standards fr Hazardus Air Pllutants (NESHAP) Sectin 112 f the Clean Air Act Maximum Achievable Cntrl Technlgy (MACT) Sectin 112g FEDERAL AIR REGULATIONS Descriptin f Federal Air Regulatins r Requirements The PSD regulatins allw the installatin and peratin f large, new surces and the mdificatin f existing large surces in areas that are meeting the NAAQS. The regulatins define what is cnsidered a large r significant surce, r mdificatin. In rder t assure that the area will cntinue t meet the NAAQS, the permit applicant must demnstrate that it is installing BACT. By law, BACT must cnsider the ecnmic, envirnmental, and energy impacts f each installatin n a case-by-case basis. As a result, BACT can be different fr similar facilities. In its permit applicatin, the applicant identifies all air pllutin cntrl ptins available, the feasibility f these ptins, the effectiveness f each ptin, and why the ptin prpsed represents BACT. As part f its evaluatin, the Air Quality Divisin verifies the applicant s determinatin and reviews BACT determinatins made fr similar facilities in Michigan and thrughut the natin. The United States Envirnmental Prtectin Agency has set natinal standards fr specific surces f pllutants. These New Surce Perfrmance Standards (NSPS) apply t new r mdified equipment in a particular industrial categry. These NSPS set emissin limits r wrk practice standards fr ver 60 categries f surces. The United States Envirnmental Prtectin Agency has set natinal standards fr specific surces f pllutants. The Natinal Emissins Standards fr Hazardus Air Pllutants (NESHAP) (a.k.a. Maximum Achievable Cntrl Technlgy (MACT) standards) apply t new r mdified equipment in a particular industrial categry. These NESHAPs set emissin limits r wrk practice standards fr ver 100 categries f surces. In the Clean Air Act, Cngress listed 189 cmpunds as Hazardus Air Pllutants (HAPS). Fr facilities which emit, r culd emit, HAPS abve a certain level, ne f the fllwing tw requirements must be met: 1) The United States Envirnmental Prtectin Agency has established standards fr specific types f surces. These Maximum Achievable Cntrl Technlgy (MACT) standards are based upn the best-demnstrated cntrl technlgy r practices fund in similar surces. 2) Fr surces where a MACT standard has nt been established, the level f cntrl technlgy required is determined n a case-by-case basis. Ntes: An Air Use Permit, smetimes called a Permit t Install, prvides permissin t emit air cntaminants up t certain specified levels. These levels are set by state and federal law, and are set t prtect health and welfare. By staying within the levels set by the permit, a facility is perating lawfully, and public health and air quality are prtected. The Air Quality Divisin des nt have the authrity t regulate nise, lcal zning, prperty values, ffsite truck traffic, r lighting. These tables list the mst frequently applied state and federal regulatins. Nt all regulatins listed may be applicable in each case. Please refer t the prpsed permit cnditins prvided t determine which regulatins apply.

17 Lansing Bard f Water and Light Page 17 PROPOSED Permit N Nvember 9, 2018 Appendix 2 Best Available Cntrl Technlgy Analysis (Michigan Rule and 40 CFR 52.21(j)) A requirement f PSD New Surce Review is a BACT analysis. The tp-dwn BACT apprach per the USEPA DRAFT New Surce Review Wrkshp Manual (Octber 1990) was utilized by BWL. The tpdwn apprach cnsiders all available emissin reductin ptins and prceeds in a five-step prcess as fllws: 1. Identify all cntrl technlgies; 2. Eliminate technically infeasible ptins; 3. Rank the remaining cntrl technlgies by cntrl effectiveness; 4. Evaluate the mst effective cntrls and dcument the results; 5. Select BACT (e.g., the mst effective ptin nt rejected is BACT). The prpsed prject is subject t a BACT analysis fr NO x, CO, VOCs, PM10, PM2.5, and GHGs as CO 2e. The fllwing is a summary f the BACT analysis fr each f the different pieces f equipment prpsed t be installed. Tw Cmbined-Cycle CTG/HRSG Trains and One Simple-cycle CTG: Natural gas-fired CTG with a HRSG equipped with a duct burner fr supplemental firing r perating in HRSG bypass mde, and ne simple-cycle natural gas-fired CTG BACT fr NO x NO x is generated thermally when nitrgen reacts with xygen in the cmbustin air in a high temperature envirnment, and frm xidatin f rganic nitrgen cmpunds in the fuel (fuel NO x). Fuel prperties have a significant impact n NO x frmatin. Pipeline quality natural gas cntains free nitrgen, but n fuel bund nitrgen. BWL identified several cmbustin and pst cmbustin cntrl technlgies fr the cntrl f NO x emissins frm each CTG/HRSG train, CTG perating in HRSG bypass mde, and simple-cycle CTG. The fllwing technlgies were identified and evaluated: Cmbustin and Pst Cmbustin Cntrls Clean Fuels and Gd Cmbustin Practices Dry Lw-NO x Burners (DLNB) Water r steam injectin Selective Nn-Catalytic Reductin (SNCR) Nn-Selective Catalytic Reductin (NSCR) Selective Catalytic Reductin (SCR) TM TM EM x (Frmerly SCONO x ) Xnn Cl Cmbustin The review f each f these technlgies is summarized belw. Clean fuel is a reference t fuels with little t n fuel bund NO x. In this regard, natural gas is a cleaner fuel than cal. Gd cmbustin practices cnsist f preventative measures that minimize the release f pllutants int the envirnment and reduce the amunt f fuel burned. This includes prper design in accrdance with gd engineering practices, prper maintenance f equipment

18 Lansing Bard f Water and Light Page 18 PROPOSED Permit N Nvember 9, 2018 and perating practices which ensure gd cmbustin. Clean fuel and gd cmbustin practices are cnsidered t be technically feasible fr BWL s prpsed prject. DLNB are cmmnly cmbined with pst cmbustin cntrls t achieve the lwest NO x emissin rates. DLNB cntrl fuel and air mixing ratis in the burner f the turbine in rder t reduce flame temperature and reduce thermal NO x frmatin. This technlgy is cnsidered a technically feasible cntrl alternative and will be the baseline scenari since the prpsed turbines will be designed with DLNB. Water r steam is injected int the cmbustin air f the turbine t increase the thermal mass f the cmbustin flame by dilutin. Heat is dissipated and the thermal NO x prduced is reduced. Water r steam injectin and DLNB are nt cmpatible, and water r steam injectin is a less prficient technlgy; therefre, since DLNB are prpsed fr these turbines, this technlgy is nt cnsidered a technically feasible cntrl alternative. SNCR is a pst cmbustin system that injects ammnia r urea int cmbustin flue gases t frm mlecular nitrgen and water. This reactin ccurs at flue gas temperatures f 1,600 F t 2,100 F as the technlgy des nt utilize a catalyst t prmte the reactin. The NO x reductin reactins are driven by the thermal decmpsitin f urea r ammnia and the subsequent chemical reactin reductin f NO x. The technlgy is less effective at lwer levels f uncntrlled NO x. The exhaust gases frm the CTG/HRSG train typically range frm 800 F t 1,100 F. This technlgy is nt cnsidered a technically feasible cntrl alternative because there is nt an apprpriate temperature windw fr ammnia injectin and adequate reductin f NO x in the exhaust gases. NSCR is a pst cmbustin system that utilizes a three-way catalytic cnverter t reduce emissins f NO x, CO, and VOCs frm the flue gas. N chemical injectin is necessary; unburned hydrcarbns are the NO x reducing agent. The reactins ccur at flue gas temperatures f 800 F t 1,200 F and minimal xygen cntent. This technlgy can be used in cnjunctin with an xidatin catalyst fr further CO and VOC cntrl. The exhaust gases frm the CTG/HRSG trains will be t high in xygen cntent fr this cntrl technlgy t be effective. This technlgy is nt cnsidered a technically feasible cntrl alternative. SCR is a pst cmbustin system that cnsists f an ammnia injectin system and a catalytic reactr. Ammnia is injected int the flue gas where it reacts with NO x in the presence f the catalyst t frm mlecular nitrgen and water. This reactin ccurs at flue gas temperatures f 400 F t 800 F. The efficiency f the SCR system peratin depends n catalyst reactivity, rutine replacement f the catalyst, and maintaining a prper ammnia injectin rate. This technlgy is cnsidered a technically feasible cntrl alternative. EMx TM is similar t SCR, except that NO x in the exhaust stream with ptassium carbnate (K 2CO 3) t frm ptassium nitrate (KNO 3). This cmpund is reacted with hydrgen t frm gaseus nitrgen, and regenerate the K 2CO 3. Due t the temperature sensitivity f the catalyst beds, the lwer exhaust temperature required fr the reactins in the EMx TM t take place is less than that f SCR. The EMx TM system als prvides reductins in CO emissins and t a lesser degree, reductins in VOC emissins by xidatin. This technlgy has nt been demnstrated in practice n a larger utility CTG. Therefre, EMx TM is nt cnsidered a technically feasible cntrl alternative fr this prject. Xnn Cl Cmbustin uses a catalyst instead f a flame in the cmbustin prcess, enabling cmbustin at temperatures belw the threshld at which thermal NO x frms. This technlgy has nt been demnstrated in practice n a larger utility CTG. Therefre, Xnn Cl Cmbustin is nt cnsidered a technically feasible cntrl alternative fr this prject.