Permitting and Regulatory Issues in IGCC Project Development

Transcription

1 Permitting and Regulatory Issues in IGCC Project Development Gasification Technologies 2001 San Francisco, California October 7-10, 2001 BY: Dwight N. Lockwood, PE, QEP Manager, Regulatory Affairs Global Energy Inc. Cincinnati, OH & Todd P. Royer, PE Principal Project Manager URS Corporation 325 West Main St., Suite 1200 Louisville, KY GTC-Oct2001.ppt

2 Contents Introduction Background and Technical Description Summary of Key Permit Requirements Air Permitting PSD Permit Process Key Issues Kentucky Pioneer Permit Limits & NOx Municipal Waste Combustor Rule Other Permits DOE - NEPA - EIS Public Utility Siting NPDES & Water & Corp of Engineers Acid Rain & NOx SIP Public Involvement IGCC Future 2

3 BGL IGCC Process 3

4 Kentucky Pioneer Energy

5 5

6 SVZ Sekundarrohstoff Verwertungszentrum Schwarze Pumpe Gmbh World s largest BGL facility New 12 foot system installed in 2000 Europe s largest recycling center Multi fuel operation: coal, MSW, sludge, plastics, wood waste 500MW thermal capacity 70MWe plus Grade AA Methanol 7 Lurgi fixed bed and 2 entrained flow gasifiers extend capability Over 2 Million tons of dry feed processed into clean syngas 6

7 Project - Status Scope 520 MW net Output Coal & RDF Pellet Feed Kentucky Pioneer Energy $78MM DOE Funding Pending NEPA-EIS ROD ~ End 2001 PSD / Title V Permit Issued for Construction June 7 th % Output Sold in Long Term Contract to Host Utility Project Finance 1H02 Lima Energy PSD Permit in Ohio EPA Management Review Expect Public ~ 1 Nov. Ohio Power Siting Board Permit Ready for Public Hearing 2 of 3 Long Term Off-Take Contracts Signed Brownfield Site Dating to 1885 Remedied by City of Lima Commercial Operation Mid

8 Universe of Permits A Hint! USACE General Nationwide Water Discharge & Intake & Sec. 404 Wetlands NPDES & Withdrawal DOE-NEPA-EIS W/ ESA & FLM PSD & Title 5 W/ Subpart Eb W/ NOx BACT & SCR Acid Rain & NOx SIP Call Waste-To-Energy Public Utility Commission Siting & Jurisdiction 8

9 Air Permitting PSD PERMIT PROCESS DESCRIPTION Best Available Control Technology Required (Especially NOx & SO 2 ) Modeling Required to Show No Significant Impacts Identification of Applicable Regulations with Compliance Demonstration Toxic Health Risk Assessment Typically > 1 Year Process for Obtaining a Permit Process Includes Public Hearings States Must Anticipate Nature of Input from USEPA Regions 9

10 Air Permitting SUMMARY - KENTUCKY PIONEER EMISSION LIMITS NOx 15 ppm # / mmbtu CO 15 ppm # / mmbtu SOx 40 ppm (H 2 S in Syngas) # / mmbtu PM # / mmbtu VOC # / mmbtu Beryllium 6.0 E-07 # / mmbtu HCl 0.2 ppmv Hg mg / m 3 Cadmium mg / m 3 Lead 0.20 mg / m 3 Dioxin/Furan 0.01 ng / m 3 Emission on Natural 25 ppmv Annual Usage Limit No SCR but Provide New Source BACT Analysis after 1-1/2 2 years Operation KY & Region 4 Expect TECO-Polk SCR to Resolve Viability of SCR for IGCC 10

11 Air Permitting NOx BACT & SCR ISSUES Low NOx Burners Not Viable for Syngas due to Hydrogen Content USEPA Has Hard Time Accepting That HRSG Fouling is a Big Deal Ammonium Sulfide Fouls HRSG & Resulting Viability & Cost Debate Metals & Other Compounds in Syngas Poison SCR Catalyst PC Boiler SCR Units Manage Exhaust Different No SCR Vendor will Fully Guarantee System with Syngas SCONOX and Others do not have Large Turbine Or Syngas Experience USEPA does not allow Economic Loss During HRSG Cleaning 11

12 Municipal Waste Combustor Rule For Kentucky - USEPA Region 4 Controls Interpretation Phrase in NSPS Subpart Eb is...and gasified waste... Gasifier Creates...gasified waste... Combustion Turbine is Combustor Requires Siting Analysis and Waste Separation Plan Rule Requires Gasifier and Turbine Operator Training & Certification By ASME Specialist As Incinerator Operator Not As Gasifier and Gas Turbine Operator State Also Has Rule that Mirrors Subpart Eb But Also Adds Some Solid Waste Requirements Being Appealed 12

13 IGCC vs. MWC Allowed Emissions Figure 2 Emissions Comparison Conventional MWC and Proposed IGCC Project - Hazardous Air Pollutants - 10 mg/m ppm 1000 ng/m mg/m 3 Relative Concentrat 0.08 mg/m 3 Uncontrolled MWC NSPS Controlled MWC Proposed IGCC 0.02 mg/m mg/m mg/m 3 25 ppm 13 ng/m mg/m mg/m mg/m 3 < 1 ppm < 0.01 ng/m 3 Cd Pb Hg HCl Dioxin Pollutant (at 7% Oxygen on a dry basis) 13

14 IGCC vs. MWC Allowed Emissions Figure 1 Emissions Comparison Conventional MWC and Proposed IGCC Project - Criteria Pollutants ppm 150 ppm 150 ppm 2400 mg/dscm Relative Concentratio 64 ppm 64 ppm Uncontrolled MWC NSPS Controlled MWC Proposed IGCC 30 ppm 39 ppm 24 mg/dscm 15 ppm 15 ppm 8.2 mg/dscm NOx (at 15% oxygen) SO2 (at 7% oxygen) CO (at 7% oxygen) PM (at 7% oxygen) Pollutant (dry basis) 14

15 Other Permits DOE - NEPA - EIS FERC & PUBLIC SEVICE or UTILITY COMMISSION NPDES and WATER and USACE - WATER INTAKE & DISCHARGE WASTE ACID RAIN & NOx SIP - BUDGET 15

16 US DOE US DOE NEPA-EIS Information Volume Submitted July 1999 Public Scope Input Meeting Held May 2000 NEPA Draft EIS Approved October 3 rd, 2001 Draft EIS for Public Comment in Early October 2001 Record of Decision (ROD) Expected End 2001 to Early

17 Generator / Utility Regulators FERC Exempt Wholesale Generator (EWG) Issued in Early 2001 Enables KY-PSC Comfort That Oversight Exists Kentucky Public Service Commission Declaratory Order of Non-Jurisdiction Issued July 2000 Extensive interaction with EKPC Ohio Power Siting Board Rigorous Application Similar to EIS Requires Regional Utility Interconnect Studies Requires Public Input to Application and Hearing on Project Expect Approval - Early

18 Water Permits KPDES Common Discharge with EKPC Independent Compliance before Junction of Lines Diffuser May Be Required Thermal & Mixing Zone Considerations General Nationwide 7 -- (To Install Water Intake) Kentucky River : Corp of Engineers - Louisville Intake for Joint EKPC & KPE Use Withdrawal Kentucky River Use & Allocation Oversight Utilities Exempt From Permit EKPC will Increase Its Volume and Meter Flow to KPE Lima Pre-Treat Waste Water Into City of Lima POTW Purchase Water From City of Lima 18

19 Other Permits Waste To Energy Some View a Kentucky Statute as ALSO Requiring Solid Waste Permit Definitions of RDF and RDF Processing Exclude RDF from MSW Definition and KPE from this Statute KY Legal Opinion & Decision Pending Municipal Solid Waste Incineration Regulation Mirrors Subpart Eb in Air Issues BUT Also has Solid Waste Permit Language We are Appealing This Aspect 19

20 Other Permits NOx SIP Call Budget Its Not Enough to Have a Permit Must ALSO Have Budget Allowance Budget is Share of State Allocation From USEPA All Large Utility and Industrial Generators and Boilers Affected Existing Sources 95% of Budget & New Sources 5% on Ton-For-Ton Basis New Sources Share the 5% on a Pro-Rata Heat Input Basis Ozone Season May to September Annually & USEPA is the Bank Emissions Beyond Share of Budget Bought on NYMEX Current Market $1000 to $7000 Per Ton Varies Yr Used - O & M Budget 20

21 Public Support KENTUCKY PIONEER Very Small Rural Community Economic Value to Community Governor and State & County Leaders Very Supportive Transportation Impact Concern (e.g. Trains Blocking Streets) Actively Sought Dept. of Transportation Input To Help With This LIMA ENERGY Tremendous Community and State Support Mayor in Particular Very Active From Beginning Informational Meetings in Local Neighborhood & Environmental Groups Stay Open with Local Media Too With Frequent Input on Progress 21

22 IGCC Future Policy Change Ideas Carpe Diem Opportunity Cross-Roads With Regulatory and Congressional Initiatives IGCC Has Clear Foothold in National Energy Policy BUT USEPA Needs a BOX For IGCC To Know How to Regulate It GTC & IGCC Community Needs to Help USEPA Define The Box The Question Is How to Craft IGCC & Syngas Friendly Regulations? CONSIDER : NSPS for Modern Slagging Gasification Put a Fence Around Several Initiatives in Form USEPA Can Relate To USEPA-OSW & OAQPS Efforts and Roles in Rule Development Multi-Media and Multi-USEPA Program Solution Is Feasible 22

23 ENVIRONMENTAL TECHNOLOGY