Cash Creek Generation, LLC Addendum #2 - CO 2 BACT Analysis Addendum #3 - Revised PMio PIA Modeling & Correction to the Flare BACT Limits

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1 Air Quality Services December 15, 2008 Mr. Philip Jarboe Kentucky Division for Air Quality 200 Fair Oaks Lane First Floor Frankfort, KY DEC RE: Cash Creek Generation, LLC Addendum #2 - CO 2 BACT Analysis Addendum #3 - Revised PMio PIA Modeling & Correction to the Flare BACT Limits Mr. Jarboe: On behalf of Cash Creek Generation, LLC, Air Quality Services, LLC ("AQS") is submitting Addendum #2 and Addendum #3. Addendum #2 contains a Best Available Control Technology ("BACT") analysis for CO2. Addendum #3 addresses an issue with modeling the highest PMio emission rates of wind erosion emissions from the coal storage pile and the slag landfill and addresses a correction to the Ibs/mmBTU BACT limits for the Flare (the proposed Ibs/hr BACT limits do not change). Addendum #3 demonstrates that modeling the highest emission rate from the wind erosion emissions does not result in the High First High ("HFH") 24 hour predicted impacts of PMio to equal or exceed the Significant Impact Limit ("SIL") of 5 ug/m 3. If you have any questions please feel free to contact Mr. Mike Mclnnis at or me at Sincerely, -> Kincaid Senior Consultant P.O. BOX i i 17 * SHELBYVILLE, KY * OFFICE: (502) * FAX: (502)

2 ADDENDUM #2 CO 2 BACT ANALYSIS For: CASH CREEK GENERATING STATION PSD PERMIT APPLICATION AIR QUALITY SERVICES, LLC 425 Main Street Evansville, IN DATED DECEMBER 2008 AQS Project#

3 A2 BEST AVAILABLE CONTROL TECHNOLOGY DEMONSTRATION FOR CO 2 A2-1 OVERVIEW Cash Creek Generation, LLC (CCG) is proposing to modify PSD/Title V Permit V (the Existing Permit ) to construct a coal to natural gas (methane) facility and natural gas combined cycle power plant (Cash Creek Generating Station (CCGS or Facility or Project)) in Henderson County, KY. The proposed modification involves: the addition of shift reaction and natural gas production facilities at the site along with associated ancillary equipment, the installation of carbon dioxide capture, compression, and vent equipment that will enable the Project to capture CO 2 that is produced by the gasification process, and the substitution of a natural gas combined cycle power block for the syngas-fired combined cycle power block that is authorized in the Existing Permit. In addition to CO 2 capture, the proposed modification will result in a dramatic reduction of all priority pollutants as compared to those permitted by the Existing Permit. The previous CCGS application was subject to Prevention of Significant Deterioration (PSD) requirements and issued a PSD construction permit. Therefore, this application for a modification to the existing permit is also subject to PSD permitting requirement and must apply Best Available Control Technology (BACT) for each pollutant that it will emit in significant amounts (40 CFR 52.21(j) and 401 KAR 51: ). Based on the modified design, CCGS will emit Particulate Matter (PM/PM 10 ), sulfur dioxide (SO 2 ), nitrogen oxides (NO X ), and carbon monoxide (CO) in significant amounts, as that term is defined in 40 CFR 52.21(b)(23) and listed in Table 4-1. BACT is defined in 401 KAR 51:001 1(25) as: Best available control technology or "BACT" means an emissions limitation, including a visible emission standard, based on the maximum degree of reduction for each regulated NSR pollutant that will be emitted Cash Creek Generation, L.L.C. 2 Cash Creek Generating Station Addendum #2 CO 2 BACT Analysis December 2008

4 from a proposed major stationary source or major modification that: (a) Is determined by the cabinet on a case-by-case basis after taking into account energy, environmental, and economic impacts and other costs, to be achievable by the source or modification through application of production processes or available methods, systems, and techniques, including fuel cleaning or treatment or innovative fuel combustion techniques for control of that pollutant; (b) Does not result in emissions of a pollutant that would exceed the emissions allowed by an applicable standard of 40 C.F.R. Parts 60 and 61; and (c) Is satisfied by a design, equipment, work practice, or operational standard or combination of standards approved by the cabinet, if: 1. The cabinet determines technological or economic limitations on the application of measurement methodology to a particular emissions unit would make the imposition of an emissions standard infeasible; 2. The standard establishes the emissions reduction achievable by implementation of the design, equipment, work practice or operation; and 3. The standard provides for compliance by means that achieve equivalent results. There are four aspects of this definition that are noteworthy. First, BACT is expressed as an emission limitation based on the maximum degree of reduction of pollutants. Only if the permitting agency decides that it is not feasible to monitor compliance is a design, equipment, work practice or operational standard appropriate as BACT. Second, the use of the term maximum degree of reduction has been interpreted to support the use of a top-down analysis (i.e., consider the most stringent technology first). Third, BACT must be available and applicable. 1 An available technology is one that is commercially available; meaning it has advanced through the initial research and development phase of bench scale testing, lab testing, pilot scale testing, licensing, has fully achieved commercial size demonstration and has established commercial sales without direct government subsidies. Applicability involves not only the commercial availability (as evidenced by past deployment on the same or similar type of emission stream) but also involves consideration of the physical and 1 EPA New Source Review Manual: Prevention of Significant Deterioration and Nonattainement Area Permitting, at B.5 (October 1990) (Draft) (hereinafter Draft NSR Manual Cash Creek Generation, L.L.C. 3 Cash Creek Generating Station Addendum #2 CO 2 BACT Analysis December 2008

5 chemical characteristics of the exhaust stream to be controlled. A control method applicable to one emission source may not be applicable to a similar source depending on the differences in the physical and chemical gas stream characteristics. An applicant should be able to purchase or construct a process or control device that has already been demonstrated in practice. Fourth, the permitting agency is to consider BACT on a case-by-case basis taking into account technological feasibility, energy, environmental and economic impacts to determine whether the given technology is applicable for the project. In other words, one size does not fit all. On November 13, 2008, the Environmental Appeals Board ( EAB ) held that EPA must consider regulating carbon dioxide (CO 2 ) emissions limits as part of a permit review under its Prevention of Significant Deterioration ( PSD ) program (Deseret Power Electric Cooperative, PSD Appeal No (Nov. 13, 2008)). However, because the Board also found that EPA was not necessarily required to regulate CO 2, it refused to mandate that the Region include a BACT determination for CO 2. Rather, the Board simply ordered the Region to evaluate whether it should require BACT for CO 2. As the Board recognized that its decision could have national implications, it further suggested that the Region may wish to seek a national determination from EPA Headquarters. As a result of the EAB decision, CCG is submitting this BACT analysis respecting control of CO 2 emissions from the CCGS and is proposing a voluntary BACT limit for CO 2. Cash Creek Generation, L.L.C. 4 Cash Creek Generating Station Addendum #2 CO 2 BACT Analysis December 2008

6 A2-2 BACT OVERVIEW The BACT analysis is performed based on the Project as submitted (i.e., the gasifiers, combustion turbines, and the remaining ancillary emissions units needed to operate the Facility). The proposed modification emission rates for CO 2 are presented in Table A2-1. Table A2-1: CCGS CO 2 Emissions Subject to BACT Review. Source Gasification AGR Vent Combustion Turbines Thermal Oxidizer Flare Aspirator Vent Auxiliary Boiler Methanation Startup Heater Fire Pump Emergency Generator TOTAL Potential Emissions (tons/year) 6,580,996 ** 1,989,436 13, ,131 8,200 4, ,607,868 * - Not Established as of the date of this submittal. ** - Based on a coal fuel carbon content of 69.38% (dry basis). PSD Significant Emission Rate (tons/year) * * * * * * * * * * Cash Creek Generation, L.L.C. 5 Cash Creek Generating Station Addendum #2 CO 2 BACT Analysis December 2008

7 Sources that must be addressed in the BACT analysis include any new or physically modified equipment that produces a significant increase in the emission of any applicable pollutant. The emission units at CCGS considered in this analysis are listed below and are depicted in the block diagram, shown as Figures 4-1 and 4-2 of the application. the four gasification units and gasifier aspirators including the Acid Gas Removal System (AGR) and vent, the Sulfur Recovery Unit (SRU)/Tail Gas Conditioning Unit (TGCU) with its associated Thermal Oxidizer (TO) and caustic scrubber, the two Combustion Turbines (CT s) with associated Heat Recovery Steam Generators (HRSG), the gasifier flare, the methanation start-up heater, the auxiliary boiler, the emergency fire water pump, and the emergency generator EPA and KYDAQ have stated their preference for a top-down BACT analysis 2 and have established the five basic steps of the review procedure. 3 Step 1 - Identify all control technologies. Step 2 - Eliminate technically infeasible options. Step 3 - Rank remaining control technologies by control effectiveness (highest control to least). Step 4 - Evaluate economic, environmental and energy impacts of the most effective controls and document results. Step 5 - Select BACT. 2 3 EPA Office of Air and Radiation, Memorandum from J.C. Potter to the Regional Administrators (December 1, 1987); Draft NSR Manual at B.6. Draft NSR Manual at B.5. Cash Creek Generation, L.L.C. 6 Cash Creek Generating Station Addendum #2 CO 2 BACT Analysis December 2008

8 The following sections constitute the top-down BACT analysis for the CCGS A2-3 STEP 1 - IDENTIFY ALL CONTROL TECHNOLOGIES The first step in the BACT analysis is to identify all available control options for each source and pollutant subject to BACT. According to EPA, a control option is available if it has a practical potential for application. This includes fuel cleaning or treatment or innovative fuel combustion techniques. 4 Potential control alternatives also include inherently lower-emitting processes/practices, add-on controls or a combination of the two. Lower-emitting processes are considered based on demonstrations made on the basis of manufacturing identical or similar products [natural gas and electricity in this case] from identical or similar raw materials or fuel [coal and natural gas]. 5 Demonstrated and transferable control technologies are considered based on the physical and chemical characteristics of the pollutant-bearing emission stream. 6 A2-3.1 Control Technologies for Coal Gasification and the AGR Vent The only available and demonstrated CO 2 control technology for the gasification process is the use of an Acid Gas Removal (AGR) system to capture CO 2, which is a weak acid gas. The AGR process serves two purposes. First, it separates and recovers sulfur compounds from the synthesis gas (syngas) for the production of molten elemental sulfur as a byproduct. Secondly, CO 2 is removed from the syngas for compression and injection into a CO 2 pipeline for use in Enhanced Oil Recovery (EOR). A BACT analysis respecting AGR systems is set out in Section of the modification application. A2-3.2 Control Technologies for Electric Generation (Combustion Turbines) In the combined cycle (CC) power block, fuel is combusted in two combustion turbines (CT s) to produce electricity. The hot exhaust gases from the CTs are used to superheat the Fuel cleaning, treatment and innovative fuel combustion techniques are mentioned in the definition of BACT. See 40 CFR 52.21(b)(12). Draft NSR Manual, at B.10 Ibid Cash Creek Generation, L.L.C. 7 Cash Creek Generating Station Addendum #2 CO 2 BACT Analysis December 2008

9 saturated steam from the gasification to natural gas process in HRSG s. The superheated steam is then expanded through a steam turbine to produce electric energy. A GE 7FA (or equivalent) CT was selected for the CCGS to provide adequate HRSG capacity with one CT operating to superheat the steam provided from the gasification to natural gas process. There is no commercially available or demonstrated control technology to control the emissions of CO 2 from the combustion of fuel in a CT. However, there is a choice of fuels that can be used to reduce CT CO 2 emissions. Therefore, the only available and demonstrated control technology is the choice of fuel to be used in the CT. The choices of fuel for a CT are limited to natural gas, fuel oil, or any combination thereof. With the selection of CC for electric production, the CCGS exhibits the following emission profile respecting the CO 2 emissions from the HRSG stacks with natural gas fuel: Table A2-2: CCGS CT HRSG CO 2 Emission Rates Emission Rate Based on Pollutant Combustion Turbines Heat Input Control Technology (lbs/mmbtu HHV) CO Natural Gas Combustion Since the carbon density of natural gas is less on a lbs/mmbtu basis than it is for fuel oil, use of natural gas as fuel for a CT will result in lower CO 2 emissions than the use of fuel oil as a CT fuel. A2-3.3 Control Technologies for Thermal Oxidizer The thermal oxidizer is utilized as a control device for H2S emissions from the SRU that result from sulfur compounds (primarily H2S) that could not be captured in an AGR. There is no available and demonstrated control technology for the control of CO 2 from a thermal oxidizer that is used as a control device for an SRU. However, there is a choice of fuels that can be used to reduce thermal oxidizer CO 2 emissions. The fuel choices are fuel oil, and natural gas. Cash Creek Generation, L.L.C. 8 Cash Creek Generating Station Addendum #2 CO 2 BACT Analysis December 2008

10 A2-3.4 Control Technologies for Auxiliary Boiler There is no commercially available or demonstrated control technology to control the emissions of CO 2 from a boiler. However, there is a choice of fuels that can be used to fire the boiler that could result in the reduction in emissions of CO 2. The fuel choices are fuel oil and natural gas. In addition, CCG is proposing to limit the hours of operation of the auxiliary boiler to reduce emissions. A2-3.5 Control Technologies for Flare The Flare is a control device for transient operations of the gasification process. There is no available control technology to capture and/or control the emissions of CO 2 from a flare that is used as a gasification control device. However, there is a method to reduce the amount of CO 2 that will be emitted by the flare as a result of the combustion of natural gas in the flare pilot flames. This method would be to install an ignition device that would light the pilots when they are needed rather than operating the pilots on a continuous basis. However, the use of on-demand flare pilots has consistently been rejected for environmental protection purposes to avoid the risk that the flare pilots would malfunction, when required, resulting in a failure of the control device. In addition to the use of an on-demand intermittent pilot system, there is a choice of fuel that can be used to for the flare pilots that could result in the reduction of emissions of CO 2. The fuel choices are fuel oil and natural gas. A2-3.6 Control Technologies for Aspirators There is no commercially available or demonstrated control technology to control the emissions of CO 2 resulting from natural gas pre-heating activities during start-up of a gasifier. However, there is a choice of fuel that can be used to preheat the gasifier that could result in the reduction of emissions of CO 2. The fuel choices are fuel oil and natural gas. A2-3.7 Control Technologies for Methanation Startup Heater There is no commercially available or demonstrated control technology to control the emissions of CO 2 from a methanation start-up heater. However, there is a choice of fuel that can be used in the methanation start-up heater that could result in the reduction of emissions Cash Creek Generation, L.L.C. 9 Cash Creek Generating Station Addendum #2 CO 2 BACT Analysis December 2008

11 of CO 2. The fuel choices are fuel oil and natural gas. In addition, CCG is proposing to limit the hours of operation of the methanation start-up heater to reduce emissions. A2-3.8 Control Technologies for Fire Pump There is no commercially available or demonstrated control technology to control the emissions of CO 2 from an emergency fire pump. However, there is a choice of fuel that can be used in the fire pump that could result in the reduction of emissions of CO 2. The fuel choices are fuel oil and natural gas. In addition, CCG is proposing to limit the hours of operation of the emergency fire pump to reduce emissions. A2-3.9 Control Technologies for Emergency Generator There is no commercially available or demonstrated control technology to control the emissions of CO 2 from an emergency generator. However, there is a choice of fuel that can be used in the emergency generator that could result in the reduction of emissions of CO 2. The fuel choices are fuel oil and natural gas. In addition, CCG is proposing to limit the hours of operation of the emergency generator to reduce emissions. A2-4 Demonstrated and Transferable Technologies To be demonstrated and thus available, the technology must have been applied to, or permitted for full scale operation. If a technology has not been demonstrated, it does not need to be considered further in the BACT analysis. In determining whether a technology is available for use at the CCGS, several sources of information were considered, including: EPA s RACT/BACT/LAER Clearinghouse and Control Technology Center (the RBLC); 7 recently submitted PSD applications/permits; and information from control technology vendors and engineering/environmental consultants. The database sources did not provide any data for the control of CO 2. 7 The RBLC database provides a listing of recent RACT, BACT, and LAER determinations in the United States. It is maintained by EPA and updated by the individual regulatory agencies. Cash Creek Generation, L.L.C. 10 Cash Creek Generating Station Addendum #2 CO 2 BACT Analysis December 2008

12 A2-5 STEP 2 - TECHNICAL FEASIBILITY ANALYSIS The second step in the BACT analysis is to eliminate any technically infeasible control technologies. Each control technology identified in Step 1 for CO 2 must be evaluated, and those that are clearly technically infeasible may be eliminated from further consideration. EPA states the following with regard to technical feasibility 8 A demonstration of technical infeasibility should be clearly documented and should show, based on physical, chemical and engineering principles, that technical difficulties would preclude the successful use of the control option on the emissions unit under review. For a control technology to be technically feasible, it must be available and applicable. To be available, it must be commercially available. A technology that is in the research and development phase, bench scale or laboratory testing, or pilot scale testing is not available. A technology that is commercially available still may not be technically feasible, however, if it is not applicable. An available technology is applicable if it has been used on the same or a similar type source or if the physical and chemical characteristics of the project s emission streams are similar to the emission streams of a source that uses the technology under consideration. Except for the gasification process CO 2 capture system (AGR), on-demand (ignitor) pilots for the flare, a choice of fuel (natural gas or fuel oil for the CTs, thermal oxidizer, auxiliary boiler, flare, gasifier preheat for the gasifier aspirators, methanation start-up heater, fire pump, and emergency generator) and a limit on the hours of operation for the ancillary processes (auxiliary boiler, fire pump, emergency generator, and methanation startup heater), there are no technically feasible controls for CO 2. 8 (Draft NSR Manual, at B.7). Cash Creek Generation, L.L.C. 11 Cash Creek Generating Station Addendum #2 CO 2 BACT Analysis December 2008

13 A2-6 STEP 3 - RANKING OF THE REMAINING CONTROL TECHNOLOGIES BY EFFECTIVENESS After eliminating technically infeasible control alternatives in Step 2, all remaining control technologies are ranked and listed in order of overall control effectiveness. Table A2-3: Summary of Control Technologies Pollutant Source Most Stringent Emission Limit Control Technology CO 2 Gasifier 0 TPD 1 12,031 TPD Selexol AGR with CO 2 Pipeline in Service Selexol AGR with CO 2 Pipeline out of Service CTs Thermal Oxidizer lbs/mmbtu/1,989,436 tons/yr lbs/mmbtu/2,704,244 tons/yr lbs/mmbtu/13,398 tons/yr lbs/mmbtu/18,139 tons/yr Natural Gas Fuel Oil Natural Gas Fuel Oil Flare 29.4 lbs/mmbtu/9.18 tons/yr lbs/mmbtu/258 tons/yr lbs/mmbtu/ tons/yr Aspirator lbs/mmbtu/11,131 tons/yr lbs/mmbtu/15,070 tons/yr Igniter/Natural Gas/312 hrs/yr Natural Gas Fuel Oil Natural Gas Fuel Oil Auxiliary Boiler Methanation Startup Heater Fire Pump Emergency Generator lbs/mmbtu/8,200 tons/yr lbs/mmbtu/11,102 tons/yr lbs/mmbtu/4,405 tons/yr lbs/mmbtu/5,964 tons/yr 110 lbs/mmbtu/4.75 tons/yr 164 lbs/mmbtu/7.08 tons/yr 110 lbs/mmbtu/39 tons/yr 164 lbs/mmbtu/58 tons/yr Natural Gas/500 hrs/yr Fuel Oil/ 500 hrs/yr Natural Gas/1,872 hrs/yr Fuel Oil/1,872 hrs/yr Natural Gas/36 hrs/yr Fuel Oil/36 hrs/yr Natural Gas/36 hrs/yr Fuel Oil/36 hrs/yr 1 CO 2 leaves the plant in the CO 2 Pipeline. 2 Based on 156 hours per year of flare operation for start-up and 156 hours per year of flare operation during gasifier shut-down. Using the emission information presented in the previous table, the control technologies available and applicable to the CCGS are ranked in order of decreasing effectiveness. Table Cash Creek Generation, L.L.C. 12 Cash Creek Generating Station Addendum #2 CO 2 BACT Analysis December 2008

14 A2-4 presents the technically feasible control technologies for the CCGS and their associated control efficiencies. Table A2-4: Ranking of Control Technologies by Effectiveness Pollutant Source Control Technology Maximum Potential Control Efficiency (%) CO 2 Gasifier Selexol AGR with CO 2 Pipeline in Service Selexol AGR with CO 2 Pipeline out of Service CTs Natural Gas Fuel Oil 100% 33.28% % 0% Thermal Oxidizer Flare Aspirator Auxiliary Boiler Methanation Startup Heater Fire Pump Emergency Generator Natural Gas Fuel Oil Igniter/Natural Gas/312 hrs/yr Natural Gas Fuel Oil Natural Gas Fuel Oil Natural Gas/500 hrs/yr Fuel Oil/ 500 hrs/yr Natural Gas/1,872 hrs/yr Fuel Oil/1,872 hrs/yr Natural Gas/36 hrs/yr Fuel Oil/36 hrs/yr Natural Gas/36 hrs/yr Fuel Oil/36 hrs/yr 26.14% 0% 97.37% 26.14% 0% 26.14% 0% 26.14% 0% 26.14% 0% 32.93% 0% 32.93% 0% % of the CO 2 is bound in the gasifier slag and leaves the process as CO 2 or carbon equivalent with the natural gas produced by the Project. The ranking is based on the highest reported control efficiency or a calculated efficiency (where no control efficiency has been reported) for a piece of equipment. The levels of reduction are not necessarily cumulative. These levels of control may not be achievable in all installations. Cash Creek Generation, L.L.C. 13 Cash Creek Generating Station Addendum #2 CO 2 BACT Analysis December 2008

15 A2-7 STEP 4 - TOP-DOWN EVALUATION OF CONTROL OPTIONS Once technically feasible control technologies have been identified and ranked by effectiveness, the control options must be evaluated to determine the most effective control technology available for the CCGS. Under EPA PSD review policy, if the Applicant selects the most effective control technology for a pollutant, the top-down BACT analysis is complete. If the most effective control technology is not selected as BACT, the remaining control technologies are evaluated on the basis of economic, energy, and environmental considerations. This process continues until a control technology cannot be eliminated. The discussion below is organized on a per facility basis. A2-7.1 Gasification AGR and AGR Vent Table A2-5: AGR Vent CO 2 Control Options Control Technology Selexol AGR with CO 2 Pipeline in Service Selexol AGR with CO 2 Pipeline out of Service Potential Add-On Control Efficiency (%) 100% 33.28% CCG has selected a Selexol AGR CO 2 capture system for the coal gasification process. CCG has executed a contract for the delivery of the captured CO2 to a pipeline for use in EOR. During compressor or pipeline outages and until the pipeline infrastructure is operational; the CO 2 will be routed to the AGR vent. As CCG has selected the most effective control technology as BACT, no further analysis is necessary. The method of determining compliance with the selected BACT will involve two (2) criteria, specifically: the AGR must be in operation whenever a gasifier is operating to ensure CO2 capture, and the AGR vent must be closed whenever the CO2 compression system and pipeline are available to receive CO2. Therefore, records of gasifier operation, AGR operation, CO2 compression system and pipeline availability, and AGR vent operation will serve as the method of determining compliance with the selected BACT. Cash Creek Generation, L.L.C. 14 Cash Creek Generating Station Addendum #2 CO 2 BACT Analysis December 2008

16 A2-7.2 CT/HRSG Units Table A2-6: CT HRSG CO 2 Control Options Control Technology Natural Gas Fuel Oil Potential Control Efficiency (%) 26.43% 0% CCG has selected a fuel restriction for the combustion turbines and has selected natural gas as the fuel to reduce the emissions of CO 2 by 26.43%. As CCG has selected the most effective control technology as BACT, no further analysis is necessary. Since the use of natural gas results in a reduction of CO 2, records of the type of fuel used in the CTs will serve as the method of determining compliance with the selected BACT. A2-7.3 Thermal Oxidizer Table A2-7: Thermal Oxidizer CO 2 Control Options Control Technology Natural Gas Fuel Oil Potential Control Efficiency (%) 26.14% 0% CCG has selected a fuel restriction for the thermal oxidizer and has selected natural gas as the fuel to reduce the emissions of CO 2 by 26.14%. As CCG has selected the most effective control technology as BACT, no further analysis is necessary. Since the use of natural gas results in a reduction of CO 2, records of the type of fuel used in the thermal oxidizer will serve as the method of determining compliance with the selected BACT. Cash Creek Generation, L.L.C. 15 Cash Creek Generating Station Addendum #2 CO 2 BACT Analysis December 2008

17 A2-7.4 Flare Table A2-8: Flare CO 2 Control Options Control Technology Igniter/Natural Gas/156 hrs/yr Natural Gas Fuel Oil Potential Add-On Control Efficiency (%) 97.37% 26.14% 0% The most effective control technology for the flare is use of an igniter to provide intermittent on-demand flare pilot operation. However, environmental considerations preclude CCG s selection of this control technology. Due to the possible environmental ramifications (emissions of a hazardous air pollutant, H2S) associated with igniter failure, CCG believes that the selection of an igniter as the control technology would be imprudent. Instead, CCG has selected a fuel restriction for the flare pilots and has selected natural gas as the fuel to reduce the emissions of CO 2 by 26.14%. Since the use of natural gas results in a reduction of CO 2, records of the type of fuel used in the flare pilots will serve as the method of determining compliance with the selected BACT. A2-7.5 Gasifier Aspirators Table A2-9: Aspirator CO 2 Control Options Control Technology Natural Gas Fuel Oil Potential Control Efficiency (%) 26.14% 0% CCG has selected a fuel restriction for the gasifier aspirators and has selected natural gas as the fuel to reduce the emissions of CO 2 by 26.14%. As CCG has selected the most effective control technology as BACT, no further analysis is necessary. Since the use of natural gas results in a reduction of CO 2, records of the type of fuel used for gasifier pre-heat will serve as the method of determining compliance with the selected BACT. Cash Creek Generation, L.L.C. 16 Cash Creek Generating Station Addendum #2 CO 2 BACT Analysis December 2008

18 A2-7.6 Auxiliary Boiler Table A2-10: Auxiliary Boiler CO 2 Control Options Control Technology Natural Gas/500 hrs/yr Fuel Oil/500 hrs/yr Potential Control Efficiency (%) 26.14% 0% CCG has selected a fuel restriction and limited hours of operation for the Auxiliary Boiler and has selected natural gas as the fuel to reduce the emissions of CO 2 by 26.14%. As CCG has selected the most effective control technology as BACT, no further analysis is necessary. Since the use of natural gas results in a reduction of CO 2, records of auxiliary boiler hours of operation and the type of fuel used in the auxiliary boiler will serve as the method of determining compliance with the selected BACT. A2-7.7 Methanation Startup Heater Table A2-11: Methanation Startup Heater CO 2 Control Options Control Technology Natural Gas/1,872 hrs/yr Fuel Oil/1,872 hrs/yr Potential Control Efficiency (%) 26.14% 0% CCG has selected a fuel restriction and limited hours of operation per year for the Methanation Startup heater and has selected natural gas as the fuel to reduce the emissions of CO 2 by 26.14%. As CCG has selected the most effective control technology as BACT, no further analysis is necessary. Since the use of natural gas results in a reduction of CO 2, records of methanation startup heater hours of operation and the type of fuel used in the methanation startup heater will serve as the method of determining compliance with the selected BACT. Cash Creek Generation, L.L.C. 17 Cash Creek Generating Station Addendum #2 CO 2 BACT Analysis December 2008

19 A2-7.8 Fire Pump Table A2-12: Fire Pump CO 2 Control Options Control Technology Natural Gas/36 hrs/yr Fuel Oil/36 hrs/yr Potential Control Efficiency (%) 32.93% 0% CCG has selected a fuel restriction and limited hours of operation per year for the Fire Pump and has selected natural gas as the fuel to reduce the emissions of CO 2 by 32.93%. As CCG has selected the most effective control technology as BACT, no further analysis is necessary. Since the use of natural gas results in a reduction of CO 2, records of fire pump hours of operation and the type of fuel used in the fire pump will serve as the method of determining compliance with the selected BACT. A2-7.9 Emergency Generator Table A2-13: Emergency Generator CO 2 Control Options Control Technology Natural Gas/36 hrs/yr Fuel Oil/36 hrs/yr Potential Control Efficiency (%) 32.93% 0% CCG has selected a fuel restriction and limited hours of operation per year for the Emergency Generator and has selected natural gas as the fuel to reduce the emissions of CO 2 by 32.93%. As CCG has selected the most effective control technology as BACT, no further analysis is necessary. Since the use of natural gas results in a reduction of CO 2, records of emergency generator hours of operation and the type of fuel used in the emergency generator will serve as the method of determining compliance with the selected BACT. Cash Creek Generation, L.L.C. 18 Cash Creek Generating Station Addendum #2 CO 2 BACT Analysis December 2008

20 A2-8 STEP 5 - SELECT BACT Tables A2-14 to A2-22 summarize the CO 2 BACT determinations for the modified CCGS. Table A2-14: AGR Vent CO 2 Control Options Control Technology Selexol AGR with CO 2 Pipeline in Service Selexol AGR with CO 2 Pipeline out of Service Potential Add-On Control Efficiency (%) 100% 33.28% Since BACT is represented by: AGR operation whenever a gasifier is operating to ensure CO2 capture, and AGR vent closure whenever the CO2 compression system and pipeline are available to receive CO2. Records of gasifier operation, AGR operation, CO2 compression system and pipeline availability, and AGR vent operation will serve as the method of determining compliance with the BACT selection for CO2. Table A2-15: HRSG CO 2 Control Options Control Technology Potential Control Efficiency (%) Natural Gas 26.43% Since BACT is represented by the fuel selection of natural gas, records of the type of fuel used in the CTs will be used to determine compliance with BACT for CO 2. Table A2-16: Thermal Oxidizer CO 2 Control Options Control Technology Potential Control Efficiency (%) Natural Gas 26.14% Since BACT is represented by the fuel selection of natural gas, records of the type of fuel used in the thermal oxidizer will be used to determine compliance with BACT for CO 2. Cash Creek Generation, L.L.C. 19 Cash Creek Generating Station Addendum #2 CO 2 BACT Analysis December 2008

21 Table A2-17: Flare CO 2 Control Options Control Technology Potential Control Efficiency (%) Natural Gas 26.14% Since BACT is represented by the fuel selection of natural gas, records of the type of fuel used in the flare pilots will be used to determine compliance with BACT for CO 2. Table A2-18: Aspirator CO 2 Control Options Control Technology Potential Control Efficiency (%) Natural Gas 26.14% Since BACT is represented by the fuel selection of natural gas, records of the type of fuel used for gasifier preheating will be used to determine compliance with BACT for CO 2. Table A2-19: Auxiliary Boiler CO 2 Control Options Control Technology Potential Control Efficiency (%) Natural Gas/500 hrs/yr 26.14% Since BACT is represented by the fuel selection of natural gas and a limit on hours of operation, records of auxiliary boiler type of fuel used and hours of operation will be used to determine compliance with BACT for CO 2. Table A2-20: Methanation Startup Heater CO 2 Control Options Control Technology Potential Control Efficiency (%) Natural Gas/1,872 hrs/yr 26.14% Since BACT is represented by the fuel selection of natural gas and a limit on hours of operation, records of methanation startup heater type of fuel used and hours of operation will be used to determine compliance with BACT for CO 2. Cash Creek Generation, L.L.C. 20 Cash Creek Generating Station Addendum #2 CO 2 BACT Analysis December 2008

22 Table A2-21: Fire Pump CO 2 Control Options Control Technology Potential Control Efficiency (%) Natural Gas/36 hrs/yr 32.93% Since BACT is represented by the fuel selection of natural gas and a limit on hours of operation, records of fire pump type of fuel used and hours of operation will be used to determine compliance with BACT for CO 2. Table A2-22: Emergency Generator CO 2 Control Options Control Technology Potential Control Efficiency (%) Natural Gas/36 hrs/yr 32.93% Since BACT is represented by the fuel selection of natural gas and a limit on hours of operation, records of emergency generator type of fuel used and hours of operation will be used to determine compliance with BACT for CO 2. Cash Creek Generation, L.L.C. 21 Cash Creek Generating Station Addendum #2 CO 2 BACT Analysis December 2008

23 ADDENDUM #3 PM 10 MODELING REVISION & CORRECTION OF FLARE BACT LIMITS For: CASH CREEK GENERATING STATION PSD PERMIT APPLICATION AIR QUALITY SERVICES, LLC 425 Main Street Evansville, IN DATED DECEMBER 2008

24 A3-1 PM 10 PIA MODELING A review of the PM 10 modeling submitted on October 2, 2008 with the permit application and as amended by Addendum #1 (submitted on November 25, 2008) has indicated that the emission rates modeled for wind erosion from the coal pile and the slag land fill were based on a 24 hour emission rate averaged over a year. For PM 10, the maximum 24 hour average based on the month with the highest PM 10 emissions should have been modeled. A review of tables 5-6 and 5-8 indicated that the PM 10 emission rate modeled was the 24 hour average based on the annual emissions and not the maximum 24 hour average based on the month with the highest PM 10 emissions. Table 5-6 is revised to show the maximum 24 hour average based on the month with the highest PM 10 emissions and is included in Appendix A. Based on the revised Table 5-6, the maximum 24 hour PM 10 average emission rate to be used for modeling purposes only is lbs/hr (controlled). Table 5-8 is revised to show the maximum 24 hr average based on the month with the highest PM 10 emissions and is included in Appendix A. Based on the revised Table 5-8, the maximum 24 hour PM 10 average emission rate to be used for modeling purposes only is lbs/hr (controlled) The previously modeled impacts can be ratioed up based on the ratio of the revised emission rate to the modeled emission rate since the only thing that changed was the emission rate. The PM 10 PIA modeling was set up to show the individual contributions of each emission source. The following table shows the predicted impacts for the coal pile wind erosion (CH23A) and the slag landfill wind erosion (LFWE) for each year modeled and for each set of land use characteristics used. Cash Creek Generation, LLC A3-2 Cash Creek Generating Station Addendum #3 December 2008

25 YEAR AIRPORT LULC CH23A μg/m 3 LFWE μg/m 3 CH23A μg/m 3 SITE LULC LFWE μg/m The Addendum #1 PM10 impact showed ug/m3. This seemed high and it was discovered that the modeled emission rate (1.431E-05 g/s/m2) was incorrect. The correct emission rate was 8.279E-7 g/s/m2. This one year was rerun and this is the result of the rerun. The modeling files are attached for this run. The revised PM 10 modeling submitted in Addendum #1 indicated that for the Airport LULC scenario modeled, the high first high ( HFH ) 24 hour impact was μg/m 3. The revised PM 10 modeling submitted in Addendum #2 indicated that for the Site LULC scenario modeled, the HFH 24 hour impact was μg/m 3. To represent a worst case scenario, the calculated HFH 24 hour impacts for CH23A and LFWE were added to these HFH modeled values for each scenario. The calculated HFH for each facility was calculated by taking the highest HFH predicted impact and multiplying that value by the ratio of the revised emission rate to the original emission rate. The factors were calculated as follows: CH23A 0.098lbs hr = lbs hr LFWE 0.066lbs hr = lbs hr Cash Creek Generation, LLC A3-3 Cash Creek Generating Station Addendum #3 December 2008

26 The calculated highest PM 10 HFH 24 hour impacts for each facility are calculated as follows: AIRPORT LULC SITE LULC FACILITY RATIO Modeled HFH 24 hr Impact μg/m 3 Calculated HFH 24 hr Impact μg/m 3 Modeled HFH 24 hr Impact μg/m 3 Calculated HFH 24 hr Impact μg/m 3 CH23A LFWE These HFH calculated values were then added to the predicted HFH 24 hour impacts from Addendum #1 (without deducting the original contribution from those predicted impacts) to represent a worst case scenario. AIRPORT LULC μg/m μg/m μg/m 3 = μg/m 3 HFH 24 hr PM 10 Impact SITE LULC μg/m μg/m μg/m 3 = μg/m 3 HFH 24 hr PM 10 Impact As demonstrated above on a worst case basis, the HFH 24 impacts for PM 10 do not equal or exceed the SIL of 5.0 μg/m 3. Additionally attached herein (Appendix B) is the rerun of the 1993 PM 10 PIA using the Site LULC data. During the course of this review, it was discovered that an incorrect emission rate (1.431E-05 g/s/m 2 ) had been modeled for the LFWE (Slag Landfill Wind Erosion). The emission rate was corrected to lbs/hr (8.279E-07 g/s/m 2 ) and the model was rerun. The results of this modeling run did not change the predicted HFH 24 hour and Annual impact for the plant as reported in Addendum #1. Cash Creek Generation, LLC A3-4 Cash Creek Generating Station Addendum #3 December 2008

27 A3-2 CORRECTION OF FLARE BACT VALUES A review of the BACT values given in Section 4 of the application has indicated that the lbs/mmbtu values for the criteria pollutants were calculated incorrectly. The flare has seven (7) pilots with a fuel rating of 490 scf/hr of natural gas. Based on a fuel heat value of 1020 btu/scf, the rating of the flare pilots is mmbtu/hr. The BACT values in Section 4 were incorrectly based on a rating of 2 mmbtu/hr. The emission rates in lbs/hr and tons/year do not change since the lbs/mmbtu values were calculated from the lbs/hr values and the fuel rating of the flare pilots. The table below shows the original BACT limits and the corrected BACT limits. POLLUTANT ORIGINAL EMISSION LIMIT CORRECTED EMISSION LIMIT PM/PM 10total lb/mmbtu lb/mmbtu SO lb/mmbtu lb/mmbtu NO X.0995 lb/mmbtu lb/mmbtu CO lb/mmbtu lb/mmbtu As a result of this correction, pages 4-62 and 4-66 in Section 4 have been corrected and are attached in Appendix B Additionally, Table 5-14 on page 5-45 of the application has been revised to reflect the corrected lbs/mmbtu values and is attached in Appendix C. Cash Creek Generation, LLC A3-5 Cash Creek Generating Station Addendum #3 December 2008

28 APPENDIX A REVISED TABLES 5-6 AND 5-8

29 TABLE 5-6: (continued) CALCULATIONS OF COAL PILE WIND EROSION EMISSIONS E = k Σ Pi Where: E = Emissions from pile in grams per square meter per year k = particle size multiplier k = 0.5 for PM-10 Pi = Erosion potential corresponding to the observed (or probable) fastest mile of wind for the ith period between disturbances (g/m2) P = 58 (u* - u t *) (u* - u t *) Where: u* = friction velocity (m/s) NOTE: P = 0 for u* less than or equal to ut* ut* = threshold friction velocity (m/s) * u = u For Coal: ut* = 1.12 m/s Table * 10 Where: u* = friction velocity (m/s) u10+ = fastest mile of reference anemometer for period between disturbances (m/s) Correct Fastest Mile u + from anemometer height z to reference height 10 u + 10 u + = ln u z ln Anemometer Height 6.1 meters Surface Area of Pile = Height of Pile = Minimum Base Length = 9,969 m2 107,302 ft2 125 ft 330 ft 0.38 Height-to-base ratio If the height-to-base ratio is greater than 0.2, it is necessary to divide the pile into sections to represent wind effects on different areas Pile Percent of Pile Surface Area Area of Pile Subarea A B1 B2 B3 A B1 B2 B3 m2 m2 m2 m2 0.2a 5% 5% 3% 3% b 35% 2% 28% 25% 3, , , c 29% - 2, a 48% 26% 29% 28% 4, , , , b 24% 22% 26% - 2, , , % 14% 15% 14% 1, , , , % 4% Area Pile A Average Month Days per Month Fastest Observed u u + 10 u* u* u*-u* t P grams Total mph m/s mph m/s m/s grams 24 hr avg lbs tons January February March April May June July August September October November December Total Modeling Basis for 24 Hr Impact Only Uncontrolled lb/hr Controlled Max lbs/hr based on highest 24 hr Controlled lb/hr Cash Creek Generation, LLC 5-31 Cash Creek Generating Station Addendum #3 December 2008

30 TABLE 5-8: (continued) Calculations of Slag Pile Wind Erosion Emissions E = k Σ Pi Where: E = Emissions from pile in grams per square meter per year k = particle size multiplier Pi = Erosion potential corresponding to the observed (or probable) fastest mile of wind for the ith period between disturbances (g/m2) P = 58 (u* - u t *) (u* - u t *) Where: u* = friction velocity (m/s) ut* = threshold friction velocity (m/s) * u = u * 10 Overburden ut* = 102 cm/s Table Where: u* = friction velocity (m/s) u10+ = fastest mile of reference anemometer for period between disturbances (m/s) Correct Fastest Mile u + from anemometer height z to reference height 10 u + 10 u + = + 10 u 10 ln z ln Anemometer Height 6.1 meters Surface Area of Pile = 4,064 m2 Assuming Flat Area - Use area of base of pile 43,744 ft2 Height of Pile = 40 ft Minimum Base Length = 236 ft 0.17 Height-to-base ratio If the height-to-base ratio is greater than 0.2, it is necessary to divide the pile into sections to represent wind effects on different areas Overburden Wind Erosion Month Days per Month Average Fastest Observed u u + 10 u* P mph m/s mph m/s m/s u* t u*-u* t g/m2 g 24 hr avg lbs/hr lbs January February March April May June July August September October November December Total lbs/yr Uncontrolled For Modeling 24 hr PM10 Impact Only lbs/hr Uncontrolled Maximum 24 hr controlled lbs/hr for modeling % lbs/hr Controlled Total Cash Creek Generation, LLC 5-36 Cash Creek Generating Station Addendum #3 December 2008

31 APPENDIX B 1993 PM10 PIA SITE LULC

32 *** AERMOD - VERSION *** *** CASH CREEK - SITE LULC *** 12/10/08 *** PM RERUN WITH REVISED PM10 RATES *** 12:13:52 **MODELOPTs: PAGE**** CONC DFAULT ELEV *** THE SUMMARY OF MAXIMUM PERIOD ( 8760 HRS) RESULTS *** ** ** CONC OF TSP IN MICROGRAMS/M**3 NETWORK GROUP ID AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE GRID-ID %LOAD 1ST HIGHEST VALUE IS AT ( , , , , 2ND HIGHEST VALUE IS AT ( , , , , 3RD HIGHEST VALUE IS AT ( , , , , 4TH HIGHEST VALUE IS AT ( , , , , 5TH HIGHEST VALUE IS AT ( , , , , 6TH HIGHEST VALUE IS AT ( , , , , 7TH HIGHEST VALUE IS AT ( , , , , 8TH HIGHEST VALUE IS AT ( , , , , 9TH HIGHEST VALUE IS AT ( , , , , 10TH HIGHEST VALUE IS AT ( , , , , 80%LOAD 1ST HIGHEST VALUE IS AT ( , , , ,

33 2ND HIGHEST VALUE IS AT ( , , , , 3RD HIGHEST VALUE IS AT ( , , , , 4TH HIGHEST VALUE IS AT ( , , , , 5TH HIGHEST VALUE IS AT ( , , , , 6TH HIGHEST VALUE IS AT ( , , , , 7TH HIGHEST VALUE IS AT ( , , , , 8TH HIGHEST VALUE IS AT ( , , , , 9TH HIGHEST VALUE IS AT ( , , , , 10TH HIGHEST VALUE IS AT ( , , , , 60%LOAD 1ST HIGHEST VALUE IS AT ( , , , , 2ND HIGHEST VALUE IS AT ( , , , , 3RD HIGHEST VALUE IS AT ( , , , , 4TH HIGHEST VALUE IS AT ( , , , , 5TH HIGHEST VALUE IS AT ( , , , , 6TH HIGHEST VALUE IS AT ( , , , , 7TH HIGHEST VALUE IS AT ( , , , , 8TH HIGHEST VALUE IS AT ( , , , , 9TH HIGHEST VALUE IS AT ( , , , , 10TH HIGHEST VALUE IS AT ( , , , ,