Get the Permit! Air Permitting for Energy Project Developers September 10, 2013 James A. Westbrook mobile

Transcription

1 Get the Permit! Air Permitting for Energy Project Developers September 10, 2013 James A. Westbrook mobile

2 Agenda Energy Project Permi2ng Objec5ves The 5 Air Permi2ng Process Steps Permit planning - common issues and hurdles What Can Go Wrong Permi2ng Examples from Energy Projects Summary

3 If you are involved with energy projects what kind?* Energy Project Type % Cogenera5on gas engines, boilers, turbines 20% Diesel Engines 16% U5lity Scale Power Plants 18% Refinery, Oil & Gas Projects 22% Other 24% *As of Sep 7, 2013

4 About the Presenter 25 years experience with air permits on energy projects Power genera5on, industrial cogen, LNG facili5es, transmission lines, u5li5es, refinery, oil & gas processing Na5onal Experience CA to East Coast Solve tough air permi2ng issues and get the permit: - Develop permi2ng strategy, rapidly obtain permits - Reduce impacts on opera5onal flexibility - Excel in technical analysis, emission controls and modeling - Develop workable monitoring, recordkeeping and repor5ng - Established agency rela5onships, lead nego5a5ons

5 Air Permi2ng is like Ra_ing..

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7 What are your Permi2ng Objec5ves? Get the permit, move project development forward Quick, smooth, hassle- free process Save money on equipment and emission controls Avoid mistakes in equipment selec5on Minimize regulatory limita5ons and constraints Maximize opera5onal flexibility Get ahead of changing, stricter requirements Allow for future plant expansion if needed An air permit is a cri-cal piece of business insurance!!

8 The Permi2ng Team Host Facility Project Developers Energy Equipment Vendor Air Pollution Equipment Vendor Monitoring Equipment Vendor Reviewing Agency Permitting Consultant Attorneys Public Relations

9 Air Permi2ng Process - Summary

10 Development Timeline Air Permi:ng Schedule Pre- Project Planning Feasibility Analysis Applica5on Permit Review & Nego5a5on Permit Opera5ons Project Development Schedule Project Start 30% Design 80% Design Construc5on Start Opera5on Start 0 3 months 6 months 12 months 24 months

11 Pre- Project Planning

12 Pre- Project Planning Start early at the drawing board Hire an energy project permi2ng expert, sit at design table Review the Project lay of the land - Region, aiainment or non- aiainment area - Agencies involved, local, state and federal - stringency - Exis5ng facility air permit status, major or minor source - Equipment ownership - Other approvals dependent on the air permit issuance

13 Pre- Project Planning (con t) Determine the kind of project - New, modified, replacement - Opera5onal mode - baseload, peaking, backup or prime - Applicable rules, exemp5ons, permits by rule, and trigger thresholds Design Review Issues Equipment, fuels and expected emission controls Emission limita5ons and other constraints Recent projects and agency requirements Project op5ons and alterna5ves Manufacturer guarantees Develop a Permi2ng Strategy and Workplan

14 Rules & Emission Limits Drive Design Best Available Control Technology (BACT) Local or state prohibitory or source- specific standards, exemp5ons EPA New Source Performance Standards (NSPS) EPA Na5onal Emission Standards for Hazardous Air Pollutants (NESHAP of MACT controls) Limits forced by Air Quality Impact Analysis

15 Feasibility Analysis

16 Feasibility Analysis Technical Issues review fatal- flaw analysis Data development projects, vendors, geography Issues List: Best Available Control Technology (BACT), by unit Prohibitory Rules exemp5ons, limits, monitoring, recordkeeping and repor5ng requirements Startup and Shutdown Emissions, Varying Condi5ons Emission Offsets, by facility / project Title V and PSD permi2ng, by facility / project Air Quality Impacts by project Ambient Standards Health Risk Assessment Poten5al to develop Emission Credits for sale Community Support and Involvement How feasible is this project, what must happen?

17 BACT for NOx Emissions Equipment Type Applica=on Size BACT for NOx Gas Engine, NG Cogen 1,000 hp g/bhp- hr Gas Turbine, NG Cogen 5.0 MWe % O2 Gas Turbine, NG U5lity 100 MWe O2 Boiler, NG Process Heat 100 MMBtu/hr lb/mmbtu Diesel Engine Backup 2,000 hp 6.4 g/kw- hr* (EPA Tier 2) Diesel Engine Prime 2,000 hp 0.67 g/kw- hr* (EPA Tier 4) *NOx + NMHC

18 Emission Offsets, Title V and PSD Emissions Offsets Nonaiainment Areas Federal Opera5ng Permits (Title V) major sources of criteria pollutants Process to add or modify units different for major sources Preven5on of Significant Deteriora5on (PSD) major source new source review in aiainment areas

19 Air Quality Impact Analysis Na5onal and state ambient air quality standards NO 2, PM 10, PM 2.5, SO 2, CO and VOC (ozone) Health Risk Assessment for Air Toxics Cancer risk: 1 in one million to 10 in one million cases Noncancer chronic or acute risk Agency will run an independent analysis Must show compliance to get the permit

20 Applica5on

21 Applica5on Process Pre- applica5on Mee5ng with Agency Hear what they want, tell em what you want Find out about and file for Expedited Permi2ng Complete Applica5on Package Fees Cover Leier Forms general, equipment- specific Technical Report emissions, BACT, applicable rules Air Quality Impact Analysis Equipment Specifica5ons Manufacturer Guarantees Site plans and area maps Applica5on Mee5ng Agency Completeness Determina5on Period Agency Applica5on Review Period

22 Permit Review & Nego5a5on

23 Permit Review and Nego5a5on A dra_ Authority to Construct (ATC) permit will be issued Carefully review and meet with the agency Much can be nego5ated to allow flexibility Public Review and Comment period, if applicable add days Final permit issuance for construc5on 1-2 years to complete project construc5on Do I need the ATC permit before I can start any construc5on?

24 Permit Opera5ons

25 Permit Opera5ons Start opera5ons and show compliance With the permit and applicable rules and regula5ons Monitoring, recordkeeping, and repor5ng procedures in place, track, track! No5fica5ons and protocols to agency Emissions source tes5ng Agency ini5al inspec5on show all permit condi5ons are met Upon compliance, permit to operate (PTO) Addi5onal permit fees for the PTO

26 What Can Go Wrong? Problem Construc5on delay without air permit Last minute or frequent design changes Changing regulatory requirements or BACT Expensive equipment or emission control required Can t meet emission limits a_er opera5on Onerous permit monitoring condi5ons Triggering emission offsets or Title V Exceeding ambient health standards Permit does not match what will actually be installed Viola5on of permit or rule condi5ons All of the above and more How to Avoid Start the applica5on process early Strategize submiial 5ming Watch for and plan for these changes Review equipment, design, opera5onal alterna5ves Beier engineering design Nego5ate appropriate condi5ons Structure emission limits or opera5ng condi5ons to avoid triggers Refined air dispersion modeling Contact agency to revise and reissue the permit before installa5on Manufacture guarantees, design, good opera5ons management Hire an experience permi2ng lead consultant!

27 Example Permi2ng Cases Project 1: 580 MMBtu/hr Hydrogen Plant replacement at a Refinery Issue 1: Developer did not know emission offsets may be needed Issue 2: CO emissions at startup exceeding 2,000 ppmv Issue 3: Tight scheduling Project 2: Commercial Cogen Facility, 200 kw gas engine Issue 1: Permit Moratorium requiring market emission offsets Issue 2: First implementa5on of a output based standard lb/mw- hr, VOC emissions Issue 3: Permit cancelled for non- fee payment Project 3: Diesel Backup Project, 2 x 2 MW engines Issue: Health Risk Assessment not passing cancer risk threshold for mul5ple engines, filters required

28 Summary - Air Permi2ng for Energy Projects Hire an experienced air permi2ng guide to navigate the process Start early, strategic planning will make a difference Understand your energy project defini5on and alterna5ves that can be considered Know air permi2ng will impact project design, spend money Plan for the what can go wrong, you will be more prepared Understand the 5 permi2ng steps, don t skip the feasibility review step Work closely with agency staff through the applica5on stage understand requirements, nego5ate permit condi5ons Be sure you are in compliance with all condi5ons at start and during opera5on Go get the Permit!

29 Contact Informa5on James Westbrook BlueScape Environmental Mobile: Connect with me on Linkedin! The webinar presenta.on will be posted on Slideshare (search for BlueScape)