DIVISION OF AIR QUALITY AIR QUALITY, ENERGY, AND SUSTAINABILITY NATURAL GAS COMBINED CYCLE PROJECTS AND CO 2 BACT EMISSION LIMITS IN NEW JERSEY

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1 DIVISION OF AIR QUALITY AIR QUALITY, ENERGY, AND SUSTAINABILITY NATURAL GAS COMBINED CYCLE PROJECTS AND CO 2 BACT EMISSION LIMITS IN NEW JERSEY Energy Air Quality MARAMA WORKSHOP FEBRUARY 22, 2018 DAVID OWEN Sustainability

2 TOPICS New Jersey High Electric Demand Day (HEDD) Rule Shutdowns and New Unit Construction Natural Gas Combined Cycle (NGCC) Turbines Best Available Control Technology (BACT) Emission Limits for CO 2 Slide 2 of 23

3 NEW JERSEY HEDD RULE FOR NITROGEN OXIDES Amendment to New Jersey NO x RACT rule (N.J.A.C. 7:27-19), adopted 3/20/2009, effective 5/1/2015 Six years to comply with emission limits 0.75 lb/mw-hour for natural gas fired combined-cycle (NGCC) turbines 1.0 lb/mw-hour for natural gas fired simple-cycle (NGSC) turbines 1.5 lb/mw-hour for coal-fired boilers 1.0 lb/mw-hour for natural-gas fired boilers 2/26/2018 Division of Air Quality NJDEP Presented by: David Owen Slide 3 of 23

4 SHUTDOWN AND CONSTRUCTION ACTIVITY SINCE HEDD RULE 135 electric generating units (5,212 MW total, including boilers and older gas turbines) have been shut down since Six NGCC turbines (2,138 MW total) and 17 NGSC turbines(1,051 megawatts total) have been constructed since One NGCC turbine (585 MW) and two NGSC turbines (128 MW total) are currently under construction/shakedown. Slide 4 of 23

5 SHUTDOWN AND CONSTRUCTION ACTIVITY SINCE HEDD RULE (CONTINUED) Two NGCC turbines (948 MW total) are approved but not yet under construction. Five NGCC turbines (2,515 MW total) are under permit review. 15 existing turbines added selective catalytic reduction (SCR) or made other changes to meet HEDD limits. 2/26/2018 Division of Air Quality NJDEP Presented by: David Owen Slide 5 of 23

6 NGCC PLANT Slide 6 of 23

7 MODEL OF GE 7FA GAS TURBINE 2/26/2018 Division of Air Quality NJDEP Presented by: David Owen Slide 7 of 23

8 MANUFACTURE OF A GAS TURBINE 2/26/2018 Division of Air Quality NJDEP Presented by: David Owen Slide 8 of 23

9 RENDERING OF A COMBINED-CYCLE PLANT Slide 9 of 23

10 REGULATION OF GREENHOUSE GASES (GHG) FOR NEW NGCC TURBINES In New Jersey, new NGCC turbines are usually subject to nonattainment NSR (NNSR) for NO x and VOC, and Prevention of Significant Deterioration (PSD) for NO x and certain other pollutants, such as CO, PM-10, and PM-2.5. NGCC units subject to PSD are anyway sources, and are thus subject to Best Available Control Technology (BACT) for greenhouse gases if CO 2 (e) emissions are over 75,000 tons/year. NSPS TTTT for greenhouse gas emissions applies to NGCC turbines that began construction or reconstruction after January 8, /26/2018 Division of Air Quality NJDEP Presented by: David Owen Slide 10 of 23

11 NGCC TURBINES SUBJECT TO GHG BACT IN NEW JERSEY Woodbridge Energy Center Two GE 7FA.05 Turbines with Duct Burners (700 MW total) Newark Energy Center Two GE 7FA.05 Turbines with Duct Burners (655 MW total) PSEG Sewaren Generating Station One GE 7HA.02 Turbine with Duct Burner (585 MW, under construction) Middlesex Energy Center One GE 7HA.02 Turbine, no Duct Burner (498 MW, permitted but not yet under construction, first PSD extension granted) Slide 11 of 23

12 NSPS TTTT (GREENHOUSE GASES) For a natural gas combined cycle turbine, the NSPS limit is 1,000 lb of CO 2 per MW-hour (gross), or 1,030 lb of CO2 per MW-hour (net), on a 12-operating-month rolling average basis. This is a ceiling for PSD BACT determinations. Newark Energy Center and Woodbridge Energy Center predated NSPS TTTT. The PSEG Sewaren and Middlesex Energy Center facilities are subject to NSPS TTTT. Slide 12 of 23

13 TOP-DOWN ANALYSIS FOR GHG BACT CO 2 is the primary GHG emitted at NGCC facilities. BACT analysis must include CO 2 capture and sequestration (CCS) as the top control measure. CCS is generally eliminated as being economically infeasible. BACT is generally determined to be high efficiency, or low heat rate. Efficiency, or heat rate, corresponds to a lb/mw-hour emission rate for CO 2. Slide 13 of 23

14 FACTORS THAT DETERMINE PERMITTED CO 2 EMISSION RATE Heat Rate given by manufacturer Multiply heat rate, after adjustments discussed below, by emission factor, such as the 40 CFR 98 factor of 117 lb/million BTU, high heat value (HHV), for natural gas, to obtain an emission rate in lb/mwhour. For example, a heat rate of 7.5 million BTU/MW-hour (HHV, gross output), or 7,500 BTU/kW-hour (HHV, gross output), results in a CO 2 emission rate of lb/mw-hour (gross output). Slide 14 of 23

15 FACTORS THAT DETERMINE CO 2 EMISSION RATE (CONTINUED) Compliance Margins Some applications have used margins from Russell City Energy Center in California (Bay Area Air Quality Management District): 3.3% design margin reflecting the possibility that the constructed facility will not be able to achieve the design heat rate 6% performance margin reflecting efficiency losses due to equipment degradation prior to maintenance overhauls 3% degradation margin reflecting the variability in operation of auxiliary plant equipment due to use over time Total margin of 12.8% 2/26/2018 Division of Air Quality NJDEP Presented by: David Owen Slide 15 of 23

16 FACTORS THAT DETERMINE CO 2 EMISSION RATE (CONTINUED) Compliance Margins Other applications have used margins from an April 2012 EPA memo: 11% margin added to heat rate/co 2 emission rate to account for: Non-design ambient temperatures Normal degradation of gas turbine components Operation at part load Add an additional 125 BTU/kW-hour to heat rate to account for post-combustion controls, such as SCR and oxidation catalyst. This would add about 14.6 lb/mwhour to the CO2 emission rate. This has been removed in recent analyses. Slide 16 of 23

17 FACTORS THAT DETERMINE CO 2 EMISSION RATE (CONTINUED) Operating Profile Idle time, startups and shutdowns, and steady state operation affect the lb/mw-hour CO 2 emission rate. Startups and shutdowns produce CO 2, but the electricity production is much lower than at steady state. Slide 17 of 23

18 FACTORS THAT DETERMINE CO 2 EMISSION RATE (CONTINUED) Fuel Type Natural Gas has lower CO 2 emissions (117 lb/million BTU, HHV) than distillate fuel oil (163 lb/million BTU, HHV). Recent Projects have fuel oil backup (usually 720 hours), in case natural gas is curtailed. 2/26/2018 Division of Air Quality NJDEP Presented by: David Owen Slide 18 of 23

19 FACTORS THAT DETERMINE CO 2 EMISSION RATE (CONTINUED) Duct burner usage Duct burners enable the steam turbine to generate more electricity during peak demand at the cost of lowering the overall efficiency (or increasing the heat rate) of the NGCC plant. 2/26/2018 Division of Air Quality NJDEP Presented by: David Owen Slide 19 of 23

20 ASSUMPTIONS ABOUT OPERATION AFFECT THE CO 2 EMISSION RATE Operating Profile A turbine that operates for 12 hours per day will have a higher lb/mw-hour CO 2 emission rate than one that operates for several days at a time between shutdowns. Duct Burner Usage Higher assumed/permitted duct burner usage will result in a higher lb/mw-hour CO 2 emission rate. Fuel Oil Usage Higher assumed/permitted fuel oil usage will result in a higher lb/mw-hour CO 2 emission rate. 2/22/2018 Division of Air Quality NJDEP Presented by: David Owen Slide 20 of 23

21 ESTABLISHED CO 2 LIMITS Woodbridge Energy Center (2 GE 7FA.05 with Duct Burners) 925 lb/mw-hour (gross) Newark Energy Center (2 GE 7FA.05 with Duct Burners) 897 lb/mw-hour (gross) PSEG Sewaren Generating Station (1 GE 7HA.02 with Duct Burner) 888 lb/mw-hour (gross) Middlesex Energy Center (1 GE7HA.02 without Duct Burner) 866 lb/mw-hour (gross) All limits are on based on a 12-consecutive month period (rolling 1-month basis) Slide 21 of 23

22 ACTUAL 2016 EMISSION RATES Newark Energy Center Unit 1 (GE 7FA.05 with Duct Burner) 784 lb/mw-hour (gross) Unit 2 (GE 7FA.05 with Duct Burner) 787 lb/mw-hour (gross) Woodbridge Energy Center Unit 1 (GE 7FA.05 with Duct Burner) 737 lb/mw-hour (gross) Unit 2 (GE 7FA.05 with Duct Burner) 734 lb/mw-hour (gross) West Deptford Energy Station (Permit predates inclusion of GHG in PSD Permits) Unit 1 (Siemens STG6-5000F(5) with Duct Burner) 815 lb/mw-hour (gross) Unit 2 (Siemens STG6-5000F(5) with Duct Burner) 812 lb/mw-hour (gross) All of these use natural gas only Slide 22 of 23

23 QUESTIONS/DISCUSSION Slide 23 of 23