The First Year of Greenhouse Gas Permitting under the Prevention of Significant Deterioration Program
More than a year has now passed since greenhouse gas (GHG) regulation under the Prevention of Significant Deterioration (PSD) preconstruction air quality permitting program became effective on January 2, 2012.
As of the one-year anniversary date, 11 states and the EPA had issued at least 18 permits. During the first year, Michigan and EPA each issued the most permits, 3, while Iowa, and Utah have each issued two permits. The remaining states of California, Kansas, Louisiana, Minnesota, New York, Pennsylvania, South Dakota, and Wisconsin, have each issued one permit. With dozens of applications still in the pipeline, more of the remaining states are expected to join the neophyte list and issue their first GHG PSD permit. The extent to which GHG permitting is causing delays, increasing expense, and resulting in material GHG emission reductions is still undetermined.
Thus far, PSD permits for GHGs have included a wide variety of regulatory requirements including efficiency limits (net or gross); direct versus the indirect limit of CO 2e; work practice standards versus numeric limits; limitations for new plant construction versus modifications; and specific control requirements. The permits have also varied in the types of gases controlled CH 4, SF 6, N 2O, and CO 2e and there are several permits with entirely unique permit conditions.
The table below summarizes various conditions in some permits.
Facility (State) |
Type of Facility |
GHG Limits |
Emission Units Subject to GHG PSD BACT Limits |
Other Requirements |
Palmdale Hybrid Power Project (California) |
570 MW natural gas combined cycle (“CC”) with 50 MW solar. |
CO2e - 1,913,000 tpy (overall facility). |
Combustion Turbine – 774 lb CO 2/MWh net; 7,319 Btu/kWh net heat rate; 365-day rolling average. Auxiliary Boiler and auxiliary heater – annual boiler tune-ups. SF6 Circuit Breakers – 9.56 tpy CO 2e; 12-mth rolling total. |
SF 6 Circuit Breakers must be equipped with a 10% by weight leak detection system. |
MidAmerican Energy George Neal North Plant (Iowa) |
|
CO2e – 5,535,152 tpy (overall facility 12-mth rolling total). CO2 – 2,347 lb/MWhr-net (30-day rolling average). CH4 and N2O – calculated from stack tests. |
N/A |
N/A |
MidAmerican Energy George Neal South Plant (Iowa) |
644 MW coal-fired unit with SNCR, dry FGD, baghouse, ACI control technologies. |
CO2e – 6,807,782 tpy (overall facility 12-mth rolling total). CO2 – 2,588 lb/MWhr-net (30-day rolling average). CH4 and N2O – calculated from stack tests. |
N/A |
N/A |
Abengoa Bioenergy Biomass (Kansas) |
A biomass to ethanol manufacturing and biomass to power co-generation facility. |
N/A |
SF6 Circuit Breaker – 4.9 short ton CO 2e/yr. Stoker Boiler – 0.34 lb CO 2e/lb steam produced, 30-day rolling period. CO2 Scrubber – 5.89 lb CO 2e/gal anhydrous ethanol produced, 30-day rolling average. Vapor Recovery Flare – 20,166 short tons CO 2e/yr during any 12 consecutive month period. Firewater Pump Engine – 24 tpy CO 2e during any 12 consecutive month period. |
Track lost SF 6 (lbs). Install SF 6 density monitor alarm. Flare fuel type restricted to biogas and natural gas. Use most efficient flare of the facility’s process. Fuel-efficient firewater pump engine (20.3±5% gal/hr fuel consumption limit for a 460 Hp engine, 1760 rpm and EPA Tier 3 emission rating). |
Wolverine Power Supply Sumpter Power Plant (Michigan) |
Modification to a CC and the installation of a diesel fuel-fired reciprocating internal combustion engine (“RICE”). |
N/A |
RICE – 716.6 CO 2e/lbs per hr CC – 954 lb/MW-hr gross energy output 12-month rolling average as determined at the end of each calendar month. |
The RICE shall not operate for more than 100 hours per year on a 12-month rolling period and the nameplate capacity shall not exceed 732 hp. The CC shall not combust more than 3,976 MMscf of natural gas per 12-month rolling time period. |
Wolverine Power Supply Rogers City (Michigan) |
Development of a base load 600 MW coal and biomass fuel fired steam electric power plant with two circulating fluidized bed (“CFB”) boilers. |
N/A |
CFB – 2.1 lb/KW-hr gross output and 6,024,107 tons per year CO 2e both on a 12-mth rolling average. |
Each boiler included in FGCFB shall not exceed a maximum heat input rating of 3,030 million Btu per hour. Incorporate energy efficient equipment wherever practical. No requirements for firewater pump engine. |
U.S. Steel Keetac (Minnesota) |
Increase of taconite pellet production by 3.6 million tpy. |
N/A |
Induration Furnace –
|
RICE – operate in a manner consistent with safety and good air-pollution control practices for minimizing emissions. |
LaFarge Building Materials (New York) |
Ravena Cement Plant replacement of two long “wet” kilns with a Preheater / precalciner tower / stack structure, kiln and clinker cooler operation. |
N/A |
Kiln – emissions shall not exceed 1900 pounds (or .95 tons) of CO 2 equivalent per ton of clinker, rolling 12-mth average. |
N/A |
Hyperion Energy Center (South Dakota) |
400,000 barrels per day crude oil petroleum refinery and a 532 MW Integrated Gasification Combined Cycle (“IGCC”) power plant. |
N/A |
Process heaters – 33.0 tons of CO 2e per thousand barrels crude oil received. Power island acid gas removal system – 58.6 tons of CO 2e per thousand barrels crude oil received. Combined cycle gas turbines – 23.9 tons of carbon dioxide equivalent per thousand barrels crude oil received. Delayed Coker #1 and #2 – 9,320 pounds of carbon dioxide equivalent per drum per cycle and permit condition 5.12. Small combustion sources (gasifier start-up burners, flares, thermal oxidizers) – 0.2 tons of CO 2e per thousand barrels, crude oil received. |
Limit the total number of coke drum venting events to not more than 2,190 times per 12-month rolling period. All emission limits are on a 365-day rolling average including periods of startup and shutdown. |
Lower Colorado River Authority (Texas) |
Replacement of 440 MW steam boiler with two new natural gas fired combined cycle combustion turbines (“CTs”) and heat recovery steam generators (“HRSGs”) with 590 MW total capacity |
Detailed requirements. |
|
|
PacificCorp Lake Side (Utah) |
629 MW block of two natural gas fired CTs with HRSGs, auxiliary boiler, emergency generator and cooling tower |
N/A |
CT/HRSG – total CO 2e emissions shall not exceed 950 lb/MWh(g) on a 12-mth rolling average basis. Hourly heat input for each turbine and the HSRG will be obtained from the data submitted to the Acid Rain database and summed over the appropriate 12-mth period. This total heat input will then be multiplied by an emission factor of 121.723 lb CO 2e / MMBtu to obtain the total CO 2 e emissions during the 12-mth period. The 12-mth gross generation for each turbine and HSRG will be obtained from the data reported to the Acid Rain database. This hourly generation will be summed over the 12-mth period to obtain the total gross generation. The CO 2e per MWh(g) value is calculated by dividing the 12-mth total CO 2e emissions by the 12-mth total gross generation. |
N/A |
Kennecott Utah Copper (Utah) |
Replacement of coal fired boilers with a CC natural gas fired CT and HRSG generating 275 MW |
N/A |
CT/HRSG – shall not exceed 1,090,736 short tons of CO 2e per rolling 12-mth period. |
N/A |
WE Energies (Wisconsin) |
Biomass Fueled Cogeneration Facility |
N/A |
Biomass and natural gas fired boiler - 3,050 pounds of CO2 per MWh of gross output, averaged over any consecutive 12-month period. 350 MMBTU/hour natural gas boiler – 185 lb CO 2 per 1,000 pounds of steam produced, or 508 lb CO 2 per MWh of steam produced per month, averaged over any consecutive 12-month period. |
N/A |
© TROUTMAN SANDERS LLP. ADVERTISING MATERIAL. These materials are to inform you of developments that may affect your business and are not to be considered legal advice, nor do they create a lawyer-client relationship. Information on previous case results does not guarantee a similar future result.