APPENDIX C SCAQMD PERMIT APPLICATION

Transcription

1 APPENDIX C SCAQMD PERMIT APPLICATION

2 Application to the South Coast Air Quality Management District for a Permit to Construct and Permit to Operate for the Natural Gas-Fired Long Beach Emergency Repowering Project at the Long Beach Generating Station Submitted to: South Coast Air Quality Management District November 2006 prepared by: Sierra Research, Inc J Street Sacramento, California (916)

3 APPLICATION TO THE SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT for a PERMIT TO CONSTRUCT and PERMIT TO OPERATE for THE NATURAL GAS-FIRED LONG BEACH EMERGENCY REPOWERING PROJECT at the LONG BEACH GENERATING STATION Submitted by: Long Beach Generation LLC November 2006 Prepared by: Sierra Research, Inc J Street Sacramento, CA (916)

4 SUMMARY Long Beach Generation LLC requests a Permit to Construct (PTC) and a Permit to Operate (PTO) for the natural gas-fired Long Beach Emergency Repowering Project (LBERP or Project) at the existing Long Beach Generating Station (LBGS) located on Terminal Island in the City of Long Beach, in Los Angeles County. The new emitting equipment will be located in the existing LBGS powerhouse building. The Project will consist of repowering four of the seven retired Alstom 1 Model 11D5 natural gas-fired combustion turbine generator units (CTGs), each to be nominally rated at 65 MWs and operating in simple cycle mode. Each unit consists of a combustion turbine and generator, equipped with water injection, selective catalytic reduction (SCR), and an oxidation catalyst. In addition to the CTGs, the project will include one 8,000- gallon aqueous ammonia storage tank. In accordance with South Coast Air Quality Management District (SCAQMD or District) Regulations XIII (New Source Review) and XX (RECLAIM), Best Available Control Technology (BACT) will be applied to the turbines to reduce emissions of carbon monoxide (CO), nitrogen oxides (NOx), ammonia (NH 3 ), particulate matter with nominal aerodynamic diameter less than 10 microns (PM-10), particulate matter with nominal aerodynamic diameter less than 2.5 microns (PM-2.5) sulfur oxides (SOx), and reactive organic gases (ROG)/volatile organic compound (VOC) emissions. Long Beach Generation LLC will provide emission reduction credits (ERCs) for emissions increases of VOC, and PM 10, RECLAIM trading credits (RTCs) for emissions increases in NOx, and voluntarily surrender the CO and SOx ERCs created by the shutdown of the seven original CTG units. Emissions from the proposed peaking plant will not cause a significant increase in ambient air contaminant concentrations, adverse impacts on visibility in nearby Class I areas, or health risks in excess of District health risk thresholds. The proposed project is also not subject to federal prevention of significant deterioration (PSD) requirements. 1 Previously ABB, and originally Brown Boveri-Sulzer in i-

5 APPLICATION FOR PERMIT TO CONSTRUCT AND PERMIT TO OPERATE for THE NATURAL GAS-FIRED LONG BEACH EMERGENCY REPOWERING PROJECT at the LONG BEACH GENERATING STATION TABLE OF CONTENTS SUMMARY Page PART I. PROJECT DESCRIPTION...1 PART II. EMISSION ASSESSMENT...3 PART III. COMPLIANCE WITH APPLICABLE RULES AND REGULATIONS...9 PART IV. AIR QUALITY ANALYSIS...11 PART V. HEALTH RISK ASSESSMENT...12 PART VI. PUBLIC NOTICE...14 ATTACHMENT A Emission Calculations ATTACHMENT B Screening Health Risk Calculations FORMS Required 400 and 500 series application forms -i-

6 APPLICATION FOR PERMIT TO CONSTRUCT AND PERMIT TO OPERATE for THE NATURAL GAS-FIRED LONG BEACH EMERGENCY REPOWERING PROJECT at the LONG BEACH GENERATING STATION I. PROJECT DESCRIPTION A. Applicant s Name and Business Description Name of Applicant: Mailing Address: Facility Address: General Business: Submitting Officer: Air Quality Consultant: Long Beach Generation LLC 301 Vista Del Mar El Segundo, CA W. Seaside Blvd. Long Beach, CA Generation of electrical power David Lloyd Secretary Long Beach Generation, LLC (760) Sierra Research, Inc J Street Sacramento, California Contact: Eric Walther (916) Estimated Construction Date: May 1,

7 B. Type of Application This is an original application for a Permit to Construct and Permit to Operate for repowered equipment at the existing LBGS. C. Description of Facility Four of the existing seven CTGs will be repowered at their current location in the existing powerhouse building at the LBGS on Terminal Island in the City of Long Beach, Los Angeles County. D. Equipment and Process Description The Long Beach Emergency Repowering Project will consist of four repowered Alstom 2 Model 11D5 natural gas-fired combustion turbine generator units (CTGs), each nominally rated at 65 MW, and operating in simple cycle mode. Each unit consists of a combustion turbine and generator, equipped with water injection, inlet air filter, inlet aircooling system, and exhaust stack. A selective catalytic reduction (SCR) system will be provided to further reduce NOx emissions. An oxidation catalyst system will also be incorporated into the system to control CO emissions. The catalyst beds will be located in the ductwork upstream of the exhaust stack. Each unit also includes a control system and separate skid-mounted systems for the electrical, mechanical, lube oil cooling, and hydraulic auxiliary systems. The equipment specifications for the CTGs are summarized in Table 1. Table 1 Combustion Turbine Generator Design Specifications Manufacturer - Original (rebuilder) Brown Boveri-Sulzer (Alstom) Model 11D5 Fuel Natural Gas Maximum Heat Input Rate MMBtu/hr (HHV) Nominal Power Generation Rate 65,000 KW Emission Controls Water injection, SCR, and Oxidation Catalyst In addition to the CTGs, the project will include one 8,000-gallon aqueous ammonia storage tank. 2 ABB (originally Brown Boveri-Sulzer) -2-

8 E. Operating Schedule Table 2 summarizes the maximum expected daily and annual operation of the combustion turbines. Turbine operation in both startup and base load modes is shown. Actual operating hours for the units may vary over days, months, and years, however, in all cases, maximum hourly, daily and annual emissions will not exceed the values shown in this application. Table 2 Expected Equipment Maximum Operating Schedule Maximum Operation Equipment/Operating Mode (hrs/day) (hrs/yr) Gas Turbine #1 Startup/Shutdown 1 50 Gas Turbine #2 Startup/Shutdown 1 50 Gas Turbine #3 Startup/Shutdown 1 50 Gas Turbine #4 Startup/Shutdown 1 50 Gas Turbine #1 Base Load 24 1,500 (1) Gas Turbine #2 Base Load 24 1,500 (1) Gas Turbine #3 Base Load 24 1,500 (1) Gas Turbine #4 Base Load 24 1,500 (1) 1) Total hours per year, including up to 50 startup/shutdown hours for approximately 100 startups/shutdowns per year. II. EMISSION ASSESSMENT A. Emissions from Retired Equipment The LBGS, which was officially shutdown January 1, 2005, contains seven (7) identical combustion turbines which operated before retirement with a nominal rating of 61 megawatts each. The turbines were capable of firing either natural gas or distillate fuel, but will operate on only natural gas after they are repowered for this project. The retired equipment also included seven (7) waste heat recovery boilers and two (2) steam turbines. Steam turbine #8 is rated at 86 MW and Steam turbine #9 is rated at 64 MW. The total plant rating is 577 MW. The equipment listed above was shut down on January 1, The maximum potential emissions from the project are below PSD applicability levels regardless of whether the project is treated as a new stationary source, or as a modification to an existing stationary source, under federal PSD rules. As shown in Table 9, below, maximum annual emissions for all four units are well below the PSD major source thresholds. If the project is treated as a modification to an existing stationary source, maximum potential emissions from the proposed project would be compared with the actual historic emissions from the LBGS for the purposes of determining the applicability of federal PSD requirements, since the shutdown of the -3-

9 units fall within the contemporaneous period under federal PSD regulations. 3 District rules define historic emissions as the average emissions during the two most recent years of operation; a similar definition applies under the federal PSD regulations. In cases where the two most recent years are not representative of normal operations, District rules allow the use of an alternative baseline period. The period from October 26, 2002, through October 25, 2004, was used to calculate the baseline emissions for the LBGS for the purpose of establishing emission reduction credits from the shutdown, and the same baseline is proposed for use here for PSD applicability purposes. These baseline emissions are summarized in Table 3. Table 3 Baseline Emissions from Existing Equipment Long Beach Generating Station Pollutant (ton/year) NOx 65.3 CO 25.3 VOC 1.7 SOx 2.9 PM The ERCs issued by the District for the shutdown equipment are listed in Table 4. Table 4 Emission Reduction Credits (ERCs) Certified from Shutdown of the Long Beach Generating Station Pollutant (lbs/day) CO 146 VOC 45 SOx 12 PM Pursuant to AQMD CEQA guidelines, the maximum daily emissions of the Project must be compared with the maximum historical daily emissions of the LBGS to determine if the AQMD CEQA thresholds will be exceeded. The required comparisons are shown in Table 5, indicating that Project operational emissions will not exceed the AQMD CEQA significance thresholds. 3 Responsibility for the federal PSD program in the South Coast Air Basin lies with EPA Region 9, with some exceptions covered by project-specific delegations. -4-

10 Table 5 Maximum Daily Potential to Emit Compared with Historical Maximum Daily Emissions from the LBGS Maximum Daily Emissions (lbs/day) Parameter NOx CO VOC SOx PM 10/2.5 Project 1,657 1, LBGS Historical Maximum 4, Net Emission Increase -2, AQMD CEQA Threshold /55 Significant Increase? No No No No No B. Emissions from New Equipment As discussed in Section I, the new equipment for the Project will consist of four repowered Alstom Model 11D5 natural gas-fired combustion turbines. Each turbine will be equipped with water injection, SCR for post-combustion NOx control, and an oxidation catalyst to control CO emissions. Emissions from the gas turbines during normal operations, startup and shutdown, and commissioning are discussed below. 1. Emissions During Normal Gas Turbine Operations The gas turbine emission rates have been estimated from vendor data, facility design criteria, established emission calculation procedures, and BACT levels described in Table 11 below (unless otherwise indicated). Emissions were estimated on an hourly, daily, and annual basis and are based on 1,500 total hours of operation per year, including startups and shutdowns. Maximum turbine emissions are shown in Table 6. Table 6 Maximum Emissions from Repowered Turbines During Normal Operation (each unit) Pollutant (lb/hr) (lb/day) (ton/yr) NOx CO VOC SOx PM Notes: 1 Maximum hourly, daily and annual NOx emissions are based on 3.5 ppmc, which is the District s current BACT level for simple cycle combustion turbines. 2 Maximum hourly CO emissions are based on 6.0 ppmc, which is the District s current BACT level for simple cycle combustion turbines. Plant operations and emissions will be managed to achieve the daily and annual CO levels shown for CO, which reflect an expected lower emission rate. 3 Maximum hourly, daily and annual VOC emissions are based on the proposed BACT level of 1.4 ppmc, which is below the District s BACT level of 2 ppmc for simple cycle combustion turbines. -5-

11 NOx emission rates reflect the use of water injection with SCR for post-combustion control. CO emission rates reflect the use of an oxidation catalyst for post-combustion control. The VOC emission rates reflect the use of good combustion practices. SOx emissions were calculated from the heat input (in MMBtu/hour) and a SOx emission factor (in lb/mmbtu). The SOx emission factor of lb/mmbtu was derived from a typical fuel sulfur content of 0.25 grains per 100 standard cubic feet (gr/100scf), and is used to calculate long-term SOx emissions. Short-term SOx emissions are based on a natural gas maximum sulfur content 4 of 0.75 gr/100scf (emission factor of lbs SO 2 /MMBtu). The PM 10/2.5 emission rate of 4.48 lbs/hr is based on Alstom information and is consistent with other gas turbine projects proposed in the AQMD. 2. Emissions during Gas Turbine Startup and Shutdown Maximum emission rates expected to occur during startups/shutdowns are shown in Table 7, for which the worst hour would include startup conditions for one hour. PM 10 and SOx emissions are not included in this table because emissions of these pollutants will not be higher during startup or shutdown than during normal turbine operation. Table 7 Emission Rates During Startups/Shutdowns of One Turbine Operating Mode NOx CO VOC Startups/Shutdowns, lb/hr Emissions During Gas Turbine Commissioning NO 2 and CO air quality impacts could be higher during commissioning than under other operating conditions already evaluated, especially under the assumption of simultaneous commissioning of all four turbines. Commissioning activities are expected to take place over a period of several days, and will include approximately 120 hours of combined turbine operation. The expected emissions during commissioning activities are shown in Table 8. Table 8 Expected Emissions During Commissioning Maximum Emissions, per Turbine Total Emissions, 4 Turbines Pollutant (lb/hr) (lbs) NOx ,712 CO 122 6,804 VOC SOx PM 10/ Southern California Gas Company Rule 30 tariff limit. -6-

12 4. Potential to Emit for New Equipment The potential to emit for the combustion turbines is summarized in Table 9. Emission calculations are included as Attachment A. Table 9 Potential to Emit for New Equipment Maximum Emissions Equipment NOx CO VOC SOx PM 10/2.5 Hourly Emissions (lbs/hr) Gas Turbines, all Daily Emissions (lbs/day) Gas Turbines, all 4 1,657 1, Annual Emissions (tons/yr) Gas Turbines, all Notes: 1 Maximum hourly emissions reflect operation of all four gas turbines in simultaneous one-hour startups/shutdowns. 2 Maximum daily emissions reflect operation of four gas turbines in startup/shutdown mode for 1 hour each, and operation of the 4 gas turbines at base load for 23 hours each. 3 Maximum annual emissions reflect operation of four gas turbines in startup/shutdown mode for 50 hours each, and operation of the four gas turbines for 1,450 hours each at base load. 4 The operator will manage operations to achieve the maximum daily and annual CO emission rates shown above, which reflect an expected greater degree of control than the maximum hourly emissions. -7-

13 C. TAC Emissions from New Equipment Maximum hourly and annual toxic air contaminant (TAC) emissions were estimated for the proposed turbines. The ammonia emission factor for the turbines was derived from an ammonia slip limit of 5 15% O 2. Other emission factors were obtained from AP-42 5 and from the California Air Resources Board s California Air Toxics Emission Factors (CATEF) database. TAC emissions from the turbines are summarized in Table 10. Emission calculations for TACs are provided in Attachment B. Table 10 Maximum Proposed TAC Emissions from All Four Turbines Emission Factor Maximum Proposed Emissions Compound (lb/mmcf) (lb/hr) (tpy) Ammonia (1) Propylene 7.71 x Hazardous Air Pollutants Acetaldehyde 4.08 x x Acrolein 3.69 x x E-03 Benzene 3.33 x x E-03 1,3-Butadiene 4.39 x x E-03 Ethylbenzene 3.26 x x E-02 Formaldehyde 3.67 x Hexane 2.59 x Naphthalene 1.66 x x E-03 PAHs 1.12 x x E-04 Propylene Oxide 2.96 x x E-02 Toluene 1.33 x x Xylene 6.53 x x Total HAPs Notes: 1 Based on an SCR ammonia slip level of 5 15% O 2. 5 USEPA. Compilation of Air Pollutant Emission Factors, Volume 1- Stationary Point and Area Sources, (AP-42). -8-

14 III. COMPLIANCE WITH BASIC NEW SOURCE REVIEW REQUIREMENTS The four principal requirements of New Source Review are as follows: BACT Offsets Ambient air quality impact analysis Health risk assessment A. BACT Requirements The BACT limits for the proposed four natural gas-fired combustion gas turbines are summarized in Table 11 along with the proposed emission limits for the Project. Table 11 Comparison of Project Emission Limits and BACT for Simple-Cycle Turbines 15% O2) Pollutant Project SCAQMD BACT NOx CO VOC NH PM lbs/hr Use of clean burning fuels B. Offset Requirements In addition to the BACT requirements, District Regulation XIII requires Long Beach Generation LLC to provide emission reduction credits (ERCs) for all net facility emission increases for CO, VOC, SOx, and PM 10 if the annual PTE exceeds the offset thresholds shown in Table 12. Only offsets for the emission increases of VOC and PM 10 will be required. VOC and PM 10 emission offsets are based on expected 30-day average emissions for the gas turbines. Regulation XIII requires offsets to be provided at an offset ratio of 1.2:1 for PM 10, VOC, SOx, and CO. The ERC requirements for the project are summarized in Table 12. Emission offset calculations are included in Attachment A. -9-

15 Table 12 Summary of ERC Requirements Parameter CO (tpy) VOC (tpy) SOx (tpy) PM 10 (tpy) Annual Emissions Offset Threshold Offsets Required? No Yes No Yes Unit CO (lbs/day) VOC (lbs/day) SOx (lbs/day) PM 10 (lbs/day) Net Increase from Gas Turbines NA 33.6 NA 91.9 Offset Ratio 1.2:1 1.2:1 1.2:1 1.2:1 Offsets Required None 40.3 None LBGS Shutdown ERCs ERCs Adequate? NA Yes NA Yes NA = Not applicable District Regulation XX requires Long Beach Generation LLC to provide RECLAIM trading credits (RTCs) for all net facility increases for NOx. The District s RECLAIM regulations require that a facility hold sufficient NOx RTCs during the first 12 months of operation to offset the maximum annual potential to emit for the new or modified equipment based on an offset ratio of 1.0:1. The amount of NOx RTCs required for the Project is based on expected annual average NOx emissions for the gas turbines. Emissions during the first 12 months of operation include estimated emissions during turbine commissioning activities. The calculation of required RTCs for the first 12 months of operation and during subsequent years is shown in Table 13. RTC calculations are included in Attachment A. Table 13 Summary of RTC Requirements Commissioning Unit (lbs) Permit Limit Operating Year 1 (lbs/yr) Net Increase from Gas Turbines 12,712 95,423 Offset Ratio 1.0:1 1.0:1 RTCs Required 12,712 95,423 1 This net increase, and the associated RTC requirement, is applicable to each calendar year, including the first year when the repowered turbines are commissioned. -10-

16 IV. AIR QUALITY ANALYSIS A modeling protocol prepared for an air quality impact analysis at this facility was submitted to the District modeling staff on July 13, 2005, and was approved in the July 25, 2005 letter from Yi-Hui Huang. The same protocol was used for the current application. Following the protocol, the highest modeled turbine impacts under baseload conditions, startups/shutdowns or atmospheric fumigation conditions were added to the highest background concentration measured at nearby air quality monitoring stations during the past three years to demonstrate that the combination of the new project with existing background pollutant concentrations will not cause any standards to be exceeded (see Table 14). TABLE 14 MODELED MAXIMUM PROJECT IMPACTS (µg/m 3 ) Pollutant Averaging Time Maximum Project Impact Background Concentrations 1 Total Impact State Standard Federal Standard NO 2 SO 2 CO PM 10 PM hour Annual 1-hour 24-hour Annual 1-hour 8-hour hour 0.44 AAM hour 0.44 AAM A , , ,608 5, ,000 10, , ,000 10,000 1 ARB. ADAM air monitoring database, 1A AQMD Air Quality, 2 AQMD. CEQA Handbook webpage, Table 2, Long Beach monitoring location, interpolated 1-hour CO concentration projected for 2005, accessed November 17, Annual Arithmetic Mean The PM 10 and PM 2.5 standards, except for the national 24-hour standard for PM 10, are already exceeded by the background levels in Long Beach. -11-

17 V. HEALTH RISK ASSESSMENT SCAQMD Rule 1401, Toxics New Source Review, requires an assessment of the potential impacts of the Project on public health and a demonstration that the potential emissions of toxic air contaminants (TACs) from the project will not pose a health hazard to sensitive subpopulations. This demonstration was made using a screening health risk assessment. In a screening health risk assessment, the potential cancer risk and noncancer short-term (acute) and long-term (chronic) noncancer health hazards of exposures to the ambient levels of the TACs emitted by the Project are compared with AQMD risk criteria to show that the project is safe. The screening health risk assessment is carried out in three steps: Estimate emissions of toxic, or noncriteria pollutants, from each source; Use dispersion modeling to calculate the ground-level concentration of each pollutant; and Use scientifically derived cancer unit risk factors and acute and chronic reference exposure levels (levels below which no harmful effects are observed) to evaluate carcinogenic risk and chronic and acute noncancer health hazards. A screening health risk assessment was performed for the TAC emissions from the proposed turbines. Toxic air contaminant emissions were calculated using ARB-approved emission factors and emissions measurements. The dispersion modeling used the same EPA-approved ISCST3 model and District-supplied meteorological data that were used in modeling criteria pollutant impacts, plus health risk parameters taken from HARP Version 1.3. The results of the screening health risk assessment are compared with the limits of District Rule 1401 in Table 15. The screening health risk calculations are included in Attachment B. -12-

18 TABLE 15 HEALTH RISK ASSESSMENT RESULTS Cancer Risk to Maximally Exposed Individual (w/o T-BACT) Cancer Risk to Maximally Exposed Individual (w/ T-BACT) Acute Noncancer Health Hazard Index Chronic Noncancer Health Hazard Index Project Significance Threshold Not applicable to Project 1 in one million in one million 10 in one million

19 VI. PUBLIC NOTICE District Rule 3306 requires public notice for the following permit actions at Title V facilities: Initial permit issuance; Significant permit revisions; Establishment of general permits; and Permit renewals. The notice must provide at least 30 days for public comments and give at least 30 days notice if any proposed permit hearing is proposed. Although the Project is a repowering of emission units located at a previously permitted Title V facility, a new or revised Title V Permit will be required, and hence, public notice is required. -14-