Lansing Board of Water and Light

Transcription

1 RESPONSE TO COMMENTS DOCUMENT PERMIT No Rick Snyder, Governor Air Quality Division Michigan Department of Environmental Quality INTERNET: Mary Ann Dolehanty, Director Air Quality Division Constitution Hall, 2 nd Floor, South Tower 525 West Allegan Street P.O. Box Lansing, Michigan Phone: Fax:

2 Page 1 of 4 Table of Contents Section Page Public Participation Process... 2 Summary of Significant Comments... 2 Best Available Control Technology (BACT) Review... 2

3 Page 2 of 4 I. PUBLIC PARTICIPATION PROCESS Permit to Install application No , for Lansing Board of Water and Light (BWL), is for a new natural gas-fired combined-cycle plant to be located at 3725 South Canal Road, Lansing, Michigan. The public participation process involved providing information for public review including a Technical Fact Sheet, a Proposed Project Summary, proposed permit terms and conditions and a public comment period. It also included the receipt of written comments on staff s analysis of the application and the proposed permit. On November 9, 2018, copies of the Notice of Air Pollution Comment Period and Public Hearing, the Technical Fact Sheet, the Proposed Project Summary, and the proposed terms and conditions were placed on the Michigan Department of Environmental Quality (MDEQ or Department), Air Quality Division (AQD) Home Page ( In addition, a notice announcing the Public Comment Period and, if requested, an Informational Session and Public Hearing was placed in the Lansing State Journal. The notice provided pertinent information regarding the proposed action; the locations of available information; a telephone number to request additional information; the date, time, and location of the Informational Session and Public Hearing, if requested; the closing date of the Public Comment Period; and the address where written comments or hearing request were being received. An Informational Session and Public Hearing were not requested; therefore, they were not held. One written comment was received from the United States Environmental Protection Agency (USEPA) during the Public Comment Period. The remainder of this document discusses the AQD s response to that comment which did not result in changes to the final permit. II. SUMMARY OF SIGNIFICANT COMMENTS A. Best Available Control Technology (BACT) Review Comment A review of recent entries in the Environmental Protection Agency s (EPA s) Reasonable Available Control Technology/Best Available Control Technology/Lowest Archivable Emission Rate (RACT/BACT/LAER) Clearinghouse for large combined cycle natural gas fired combustion turbines includes PSD permit actions with BACT emission limits generally at 2.0 ppm for NO x, 2.0 ppm for CO, and 2.0 ppm for VOC. Per the BACT top-down process analysis policy, please provide MDEQ s rationale for why lower BACT emission limits are not achievable for this proposed project. Below are some examples from a recent search conducted on the RBLC for other large natural gas fired combined cycle projects: MI-0435 DTE Electric Co. Belle River Combined Cycle Power Plant NO x limit at 2.0 ppmvd MI-0433 Marshall Energy Center MEC North and MEC South NO x limit at 2.0 ppmvd MI-0431 Indeck Niles NO x limit at 2.0 ppm VA-0323 Novi Energy C4GT NO x limit at 2.0 Ox, VOC at 0.7 ppmvd, CO at 1.0 ppmvd at 15% O2 TX-0834 Entergy Texas Montgomery County Power Station at 2.0 ppmvd for NO x, CO, and VOC.

4 Page 3 of 4 AQD Response The Best Available Control Technology (BACT) emission limits were selected based on criteria which looked at similar sized combined-cycle combustion turbine generators (CTGs) to those proposed by BWL. Each of the BWL proposed CTGs has a heat input of 667 million British Thermal Units per hour () and are equipped with duct-fired heat recovery steam generators (HRSGs) with a heat input of 204 (total equals 871 or 100 MW). In establishing BACT, the most comparable CTGs/HRSGs to BWL s proposed units were identified as those with a total heat input less than or equal to 871. The comparable CTCs/HRSGs are shown in the following table: RBLC ID Company Size Nitrogen Oxide (NO x) Carbon Monoxide (CO) Volatile Organic Compounds (VOC) MI-0424 Holland Board of Public Works ppmvd based on a 3- hr average TX-0710 Victoria Power 197 MW 3.5 TX-0698 Bayport Complex 90 MW 5 15 time not specified 4 ppmvd based on a 3-hr NA CO-0075 Pueblo Airport pph (about 6 ) 38 pph (about 45 ) based on a 4-hr rolling average WY-0070 Cheyenne Prairie 40 MW 3 3 ppmvd In addition to those listed above, the following shows that BWL s proposed limit is comparable to those of a facility twice its size:

5 Page 4 of 4 RBLC ID Company Size NO x CO VOC MI-0427 Filer City Station NA All of the units the USEPA compared to are 2,600 to 4,100 in size, a minimum of at least three times larger than what BWL is proposing. BWL will be installing smaller, industrial gas turbines as opposed to much larger heavy-duty units at other facilities. The larger turbines are a completely different class turbine and operate at a higher exhaust gas temperature and with greater efficiency. Typically, units with greater operational efficiency have lower NO x, CO, and VOC emissions. Also, smaller units typically have a more difficult time of maintaining consistent emission rates over their lifespan. Thus, even if BWL s units can meet the lower values during their first few years of operation, there is uncertainty as to if they could continue to meet those values throughout their entire lifespan. Based upon what was determined to be BACT for the facilities similar in size to BWL and that fact that BACT must apply throughout the life of the units, the values proposed by BWL and included in the proposed permit represent BACT for this project. Prepared by: Melissa Byrnes