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Home My WebLink About20060630MVP to Staff 1-7 Part II.pdfCUP05-,00126 / Appeal 9605 S. Eisenman Road Page '5 of 10 Necessary public infrastructure is nearby and will be extended to the site to serve the property. A natural gas pipeline is approximately 2 000' to the east. Idaho Power owns 230kv transmission lines nearby the site. These lines will be used to transmit electricity toward Caldwell and the Boise bench. Water and sewer lines will be extended to the subject property to serve the project. A proposal for natural gas power plants at this location supports policies of the Boise City Comprehensive Plan. Elements of the Plan that are relevant to this project include: Public Facilities (Chapter 2): Population growth in surrounding municipalities is also steadily increasing. Current and future population of the city and region will need to be served by adequate public infrastructure to protect the quality oflife enjoyed in the area. Environmental Quality (Chapter 3): Air quality is an issue of health, aesthetics and economics linked with land use. The applicant has proposed low Nox burners that will reduce the emissions generated by the plant. DEQ has evaluated the impact of emissions and it has been determined that these are sufficiently low to enable this project. Community Quality (Chapter 7): The project is located far from residential and commercial developments. The appearance of the power plant is an important consideration as it will be visible from the Interstate. Conditions of approval direct the Design Review Committee to evaluate the architectural design treatment of the buildings, parking, landscaping, and outdoor storage areas. Land Use (Chapter 8): The Boise Comprehensive Plan encourages heavy industries and industrial uses that generate unusual noises and/or odors to be located within the industrial districts (Policy 8.1). The grouping ofIndustrial uses facilitates manufacturing clusters supports the economic base, and protects neighborhoods. The noises and emissions from the plant will be mitigated due to the location to the east of the Boise Airport and on the fringe of the city. Economic Development (Chapter 9): Plant one ofthe power plant will provide necessary infiastructure for natural population growth and business expansion in the Treasure Valley. TheComprehensive Plan indicates that if a designated area cannot be feasibly served by necessary infiastructure the city should consider redesignating it for less intensive uses and concentrating economic development efforts elsewhere (Policy 9.1). The inability to provide necessary services for industry and the reclassification of industrial zoning to zones which do not require electrical generation would be a tremendous opportunity cost for the city. Growth Management (Chapter 10): The Boise City Comprehensive Plan anticipates a projected population of253 000 within the Boise Planning Area by the year 2015 (Objective 1). Public infiastructure should be developed in a way to keep up with development of residential, commercial, and industrial areas. Necessary infrastructure such as electricity will need to be provided to accommodate that growth. The goal for electricity in the Boise City CUP05-00126 Appeal 9605 S. Eisenman Road Page 6 of Comprehensive Plan is to ensure an adequate, safe, and orderly supply of electrical energy is available to support existing and future land uses in the city (Goal 10.0). Conditions of Approval Site Specific: Construction, use and property development shall be in compliance with plans and specifications on file with the Boise City Planning and Development Services Department date stamped received on September 27 2005 except as may be modified by the Boise City Design Review Committee or Staff or expressly modified by the following conditions. The energy production facility shall be limited to a maximum of250 megawatts for plant one plant. Mountain View Power shall secure an air quality Permit to Construct (PTC) fiom DEQ that is consistent with the design information and emissions rates provided in the Gateway Power Plant Air Quality Modeling Analysis prepared by Greystone Environmental Consultants, Inc. and submitted in December 2005, for Mountain View Power. Best management practices shall be adhered to. The emissions stack shall implement insulation and silencing equipment to baffle noise pollution. The applicant shall submit an air permit application with the Idaho Department of Environmental Quality that will limit the continuous emission rate for proposed power plant # 1 to 10 parts per million nitrogen oxides and 10 parts per million carbon monoxide as measured by a continuous emissions monitoring system (CEMS) at the plant, exclusive oftime periods when the plant is in start-up or shut-down mode and operating below installed 70% capacity. Power Plant #2 has not been approved. Approval of any future power plants shall require a Conditional Use Permit. The applicant shall comply with the conditions of the Idaho Department of Environmental Quality (DEQ) per Department comments dated October 31 , 2005. Requirements include, but are not limited to, the following: a. The applicant shall contact Michael McGown for an applicability determination. b. The applicant shall contact June Ramsdell, Air Quality Manager. Compliance with DEQ requirements for air quality shall be required. c. The applicant shall contact Chris Ariss, Engineering Manager. Compliance with DEQ requirements for wastewater shall be required. d. The applicant shall contact Tiffany Floyd, Drinking Water Manager. Compliance with DEQ requirements for drinking water shall be required. CUP05-00126 Appeal 9605 S. Eisenman Road Page 7 of 10 e. The applicant shall contact Craig Shepard, Water Quality Manager. Compliance with DEQ requirel:'1ents for water quality shall be required. The applicant shall contact Ron Lane, Remediation Manager. Compliance with DEQ requirements for hazardous waste and ground water contamination shall be required. g. If required a Permit to Construct shall be obtained. h. A National Pollution Discharge Elimination System (NPDES) Permit is required. If construction disturbs more than one acre of land the applicant shall obtain permit coverage fiom EP A. 1. To obtain a construction General Permit, operators must develop a site-specific Storm Water Pollution Prevention Plan. J. No trash or other solid waste should be buried, burned or otherwise disposed at the site. k. Injection wells are regulated by the Idaho Department of Water Resources (IDWR). The applicant shall comply with the following requirements prior to submittal of building permit applications: a. The applicant shall retain an independent engineering consultant to prepare a report which shall: 1. Address the impacts of stack and thermal plume on safe flight. 11. The report shall be submitted to the Planning and Development Services Department, the Boise Airport Director and the Boise Airport Commission for review and comment. The Boise Airport Director may further distribute the report as deemed necessary. 111. Once the report is finalized by the Planning and Development Services Department, a final condition of approval shall be prepared and brought back to the Mayor and City Council for approval. iv. All expenses associated with the preparation of the engineering report shall be borne by Mountain View Power (MVP). b. A wildlife mitigation plan shall be approved and implemented if required by the Boise Airport.c. File Form 7460-Notification of Proposed Construction or Alteration with the Federal Aviation Administration, in accordance with FAA procedures. Obtain a determination fiom the FAA that the power plant structure either: i. Does not pose an unacceptable hazard to navigation, or ii. Poses a hazard that can be mitigated. Comply with all mitigation measures identified by the FAA. Prepare and submit an avigation easement. The Boise Airport Director shall review the avigation easement and may circulate it for review and comment to other necessary entities. 111. The applicant has proposed phasing of the project. Only phase I of this project is approved by this Conditional Use Permit. All infiastructure required for phase I shall be constructed prior to the development of the phase. The development authorized by this 13. 14. CUP05-00126 Appeal 9605 S. Eisenman Road PageS of Conditional Use approval must be completed within 5 years (60 months) :trom the date the Commission s approval or the applicant will be required to submit a new conditional use application. Prior to the expiration of this conditional use, the Commission may, upon written request by the holder, grant a one-year time extension. A maximum of three (3) extensions may be granted. 10.Prior to application for a building permit, the applicant shall provide documentation to the Boise City Planning and Development Services Departments that the site has a minimum of 30 feet of :trontage on a public street or a permanent access easement to a public street which was 0 f record prior to August 16, 1966 or prior to annexation by the City of Boise. 11.This project is in a Design Review District and shall be subject to review and approval by the Design Review Committee. The Committee shall specifically address the following: Landscaping and berming around the perimeter of the site provide a sight break :trom the Interstate a.lld mitigate any impacts for future development. Landscaping that shall reduce the impact of carbon monoxide generated on-site. Fencing to restrict unauthorized access to the site. Outdoor storage shall be screened :trom public view. Colors and compatibility of buildings. The Design Review Committee shall also review and approve any exterior lighting for compatibility with future development. 12.The applicant shall comply with the requirements of the Boise City Public Works Department (BCPW) for sewers per Department comments dated October 7 2005. Please contact BCPW at 384-3900. All items required by BCPW shall be included on the planslspecifications that are submitted for a Building Permit. Please note that any changes or modifications by the owner to the approved plans must be submitted to the Public Works Department for approval. Comply with all conditions of the Ada County Highway District report, date stamped received October 3, 2005. Proof of legal access shall be provided. Comply with all conditions ofthe Boise Fire Department report PRE05-00361. Any deviation :trom this plan is subject to fire department approval. For additional information, contact David S. Miller at 384-3827. General: 18. 19. 20. 21. 22. 23. 24. 25. CUP05-00126 Appeal 9605 S. Eisenman Road Page 9 of 10 15.All parking areas and driveways shall be paved, and shall be designed and laid out to conform to the minimum standards required by the Boise City Zoning Ordinance. The applicant shall provide at least one (1) ADA parking space for each phase. 16.No change in the terms fuld conditions of this approval shall be valid unless in writing and signed by the applicant or his authorized representative, and an authorized representative of the City of Boise. The burden shall be upon the applicant to obtain the written confirmation of any change and not upon the City of Boise. 17.Any change by the applicant in the planned use of the property which is the subject of this application, shall require the applicant to comply with all rules, regulations ordinances, plans, or other regulatory and legal restrictions in force at the time the applicant or its successors in interest advises the City of its intent to change the planned use ofthe property described herein unless a variance in said requirements or other legal relief is granted pursuant to the law in effect at the time the change in use is sought. Prior to issuance of a Building Permit and prior to any construction on the site, an Erosion and Sediment Control Permit must be obtained :trom the Building Division of the Planning and Development Services Department. An Occupancy Permit will not be issued by the Building Department until all of these condition(s) have been complied with. In the event a condition(s) cannot be met by desired date of occupancy, the Planning Director will determine whether the condition(s) is bondable or should be completed, and if determined to be bondable, a bond will be required in the amount of 110% of the value of the condition(s) which are incomplete. Vision Triangles as defined in Section 11-01-03 and Section 11-10-04.4G. of the Boise City Zoning Ordinance shall remain clear of all sight obstructions. A detailed grading and drainage plan shall be submitted for review and approval by the Ada County Highway District and Boise City Public Works Department before a Building Permit is issued. The applicant or hislher contractor shall obtain a Right-of-Way Permit :trom the Ada County Highway District prior to any construction in the public right-of-way. Hook-up to wet line sewers shall be required prior to issuance of an Occupancy Permit. Utility services shall be provided underground. This approval does not include approval of any signage. A separate Sign Permit will be required :trom the Boise City Planning and Development Services Department prior to installation 0 f sign( s). 30. 31. 32. 33. CUP05-00126 Appeal 9605 S. Eisenman Road Page 10 of 10 26.All landscaping shall be maintained in a healthy and attractive condition. 27.Landscaped areas shall be irrigated by an appropriate underground irrigation system. 28.Exterior lighting fixtures must be designed and located so as to prevent glare or direct light from falling onto adjoining properties or streets. 29.Any future division of this parcel into individual lots or parcels, for the purpose of selling the separate lots to individual owners, will be required to comply with all provisions of Boise City Code, Title 9, Chapter 20, including lot :trontage on a public or approved private street, and all requirements for preliminary and final platting. Construction, use and property development shall be in conformance with all applicable requirements of the Boise City Code. The applicant shall obtain Building Permits prior to any work commencing on the property. Specific building constmction requirements of the 2000 International Building Code and Uniform Fire Code will apply. However, these provisions are best addressed at Building Permit application. Failure to abide by any condition of this Conditional Use Permit shall be grounds for revocation by the Boise City Planning and Zoning Commission. Page 1 of 1 Ronald Williams From: Frisbie, Gordon (GFrisbie(IDarcadis-us.com)Sent: Tuesday, June 13, 20064:19 PM To: Shawnee.Chen(IDdeq.idaho.gov Cc: Schroeder, Randy; Tom Cameron; rlooper(IDspellc.com; Ronald Williams Subject: RE: Mountain View Power, Inc. - facility draft Attachments: P-060005 FD PTC rev-mvp1 pdf; P-060005 FD PTC(rev-mvp1 ).doc; fuel-heater.xls Shawnee, Here are Mountain View Power's comments and markups for the draft PTC. I I ve also included the fuel dew point heater spreadsheet as a backup to the emission limits forthis unit. These represent the emissions that were used in the dispersion modeling. Thanks for the opportunity for this review.Let me know if you have any questions. Gordon Frisbie Greystone - An Arcadis Company 5231 South Quebec Street Greenwood Village, CO 80111 Phone: 3 03 - 850 - 093 0 Fax: 303-721-9298 From: Shawnee.Chen(Q:jdeq.idaho.gov (mailto:Shawnee.Chen(Qjdeq.idaho.govJ Sent: Monday, June 05 2006 1:53 PM To: Frisbie, Gordon Cc: Shawnee.Chen(Q:jdeq.idaho.gov Subject: Mountain View Power, Inc. - facility draft Here you go. 6/2812006 Mountain VIew Power Mar un PERMIT No.060005 Air Quality FACILITY ID No.001-00215PERMIT TO CONSTRUCT AQCR: 64 CLASS: "":i-~~c /.:;/' State of Idaho SIC: 4911 ZONE: Department of Environmental Quality UTM COORDINATE (kIn): 567.4818 1. PERMITTEE Mountain View Power, Inc. 2. PROJECT Gateway Power Plant - Initial PTC 3. MAILING ADDRESS CITY STATE ZIP 1015 West Hays Boise Idaho 83702 4. FACILITY CONTACT TITLE TELEPHONE Robert Looper President 208-331-1898 5. RESPONSIBLE OFFICIAL TITLE TELEPHONE I Ronald Wi11iam~(sclJ Vice President & General Counsel 208-331-1898 6. EXACT PLANT LOCATION COUNTY Approximately 0.7 mile west ofInterstate 84 at the South Eisenman road exit Ada 7. GENERAL NATURE OF BUSINESS & KINDS OF PRODUCTS Electric power generation 8. GENERAL CONDITIONS This pennit is issued according to IDAP A 58.01.01.200, Rules for the Control of Air Pollution in Idaho, and pertains only to emissions of air contaminants regulated by the state of Idaho and to the sources specifically allowed to be constructed or modified by this permit. This permit (a) does not affect the title of the premises upon which the equipment is to be located; (b) does not release the permittee ITom any liability for any loss due to damage to person or property caused by, resulting ITom, or arising out of the design, installation, maintenance, or operation of the proposed equipment; (c) does not release the permittee from compliance with other applicable federal, state, tribal, or local laws, regulations, or ordinances; (d) in no manner implies or suggests that the Department of Environmental Quality (DEQ) or its officers, agents, or employees, assume any liability, directly or indirectly, for any loss due to damage to person or property caused by, resulting from, or arising out of design, installation, maintenance, or operation of the proposed equipment. This pennit will expire if construction has not begun within two years of its issue date or if construction is suspended for one year. This pennit has been granted on the basis of design infonnation presented with its application. Changes of design or equipment may require DEQ approval pursuant to the Rules for the Control of Air Pollution in Idaho, IDAPA 58.01.01.200, et seq. TONI HARDESTY, DIRECTOR DATE ISSUED:FACILITY DRAFT DEPARTMENT OF ENVIRONMENTAL QUALITY THlSYCfbf Pennit No. P-O60005 G:\Air Quality\Stationary Source\SS Ltd\PTC\Mtn. View Power\P-O60005\Facility Draft\P-O60005 FD PTC.doc Table of Contents 1. PERMIT TO CONSTRUCT SCOPE ............................................................................................................... 2. FACILITY-WIDE CONDITIONS ....................... .............. ...... ............................. ....... ...................... ......... ..... 3. SIEMENS 50IF SIMPLE CYCLE NATURAL GAS-FIRED COMBUSTION TURBINE (CTOI)............. 4. FUEL DEW POINT HEATER (FHOI) ......................................................................................................I5H 5. PERMIT TO CONSTRUCT GENERAL PROVISIONS........................................................................... Page 2 Acronyms, Units, and Chemical Nomenclature acfm actual cubic feet per minute AQCR CEMS Air Quality Control Region Continuous Emissions Monitoring System CFR Code of Federal Regulations carbon monoxide CT01 Siemens 501 F natural gas-fIred simple cycle combustion turbine DEQ dscf Idaho Department of Environmental Quality dry standard cubic feet EPA u.S. Environmental Protection Agency FH01 fuel dew point heater grain (lIb = 7 000 grains) a numbering designation for all administrative rules in Idaho promulgated in accordance with the Idaho Administrative Procedures Act IDAP A Ian lb/hr kilometer MMB tu/hr pound per hour million British thennal units per hour megawatt NOx nitrogen oxides NSPS New Source Perfonnance Standards particulate matter PMIO particulate matter with an aerodynamic diameter less than or equal to a nominal 10 micrometers ppmv parts per million by volume PTC pennit to construct RATA Relative Accuracy Test Audit SIC Standard Industrial Classification S02 sulfur dioxide T/yr UTM tons per year Universal Transverse Mercator VOC volatile organic compound Page 3 AIR QUALITY PERMIT TO CONSTRUCT NUMBER: P-O60005 Permittee:Mountain View Power Inc. - Gateway Power Plant Facility ID No. 001-00215 Date Issued:FACILITY DRAFT Location:Boise, Idaho PERMIT TO CONSTRUCT SCOPE Purpose 1.1 This is the initial Permit to Construct (PTC) for a new natural gas-fired, simple cycle combustion turbine. Regulated Sources Table 1.1 lists all sources of regulated emissions in this PTC. Permit Section Source Description Emissions Control(s) Facility-wide ilia Simple cycle Siemens Westinghouse 50 IF combustion Ultra Dry Low NO turbine (CTOI)(DLN++) combustors Fuel dew point heater (FHOI)None Table 1.1 REGULATED EMISSIONS SOURCES Page 4 AIR QUALITY PERMIT TO CONSTRUCT NUMBER: P-O6000S Permittee:Mountain View Power Inc. - Gateway Power Plant Facility ID No. 001-00215 Date Issued:FACILITY DRAFT Location:Boise, Idaho FACILITY-WIDE CONDITIONS The following requirements generally apply to all emissions units and/or sources at the facility. Emissions Limits/Operating Requirements Reasonable Control of Fu2itive Emissions All reasonable precautions shall be taken to prevent particulate matter (PM) from becoming airborne as required in IDAPA 58.01.01.651. In determining what is reasonable, considerations will be given to factors such as the proximity of dust-emitting operations to human habitations and/or activities and atmospheric conditions that might affect the movement of PM. Some of the reasonable precautions include, but are not limited to, the following: Use, where practical, of water or chemicals for control of dust in the demolition of existing buildings or structures, construction operations, the grading of roads, or the clearing of lands. Application, where practical, of asphalt, water or suitable chemicals to, or covering of dirt roads material stockpiles, and other surfaces which can create dust. Installation and use, where practical, of hoods, fans and fabric filters or equivalent systems to enclose and vent the handling of dusty materials. Adequate containment methods should be employed during sandblasting or other operations. Covering, where practical, of open-bodied trucks transporting materials likely to give rise to airborne dusts. Paving of roadways and their maintenance in a clean condition, where practical. Prompt removal of earth or other stored material from streets, where practical. Opacitv Limit The permittee shall not discharge any air pollutant into the atmosphere from any point of emission for a period or periods aggregating more than three minutes in any 60-minute period which exceeds 20% opacity, as required by IDAPA 58.01.01.625. Opacity shall be determined by the procedures contained in IDAPA 58.01.01.625. Odors The permittee shall not allow, suffer, cause, or permit the emission of odorous gases, liquids, or solids to the atmosphere in such quantities as to cause air pollution. Air Pollution Emer2encv Rule The permittee shall comply with the Air Pollution Emergency Rule in IDAPA 58.01.01.550-562. fThis condition should not be included. As a natural !!as fired nlant. Sta!!es 1 throu!!h 3 will not be ann Ii cable. Since Page 5 AIR QUALITY PERMIT TO CONSTRUCT NUMBER: P-O60005 Permittee:Mountain View Power Inc. - Gateway Power Plant Facility ID No. 001-00215 Date Issued:FACILITY DRAFT Location:Boise, Idaho this D1ant is a "utility" - not a "commercial or manufacturinl!" establishment - it would not be aDD1icab1e under Stal!e 4 either Page 6 AIR QUALITY PERMIT TO CONSTRUCT NUMBER: P-O60005 Permittee:Mountain View Power Inc. - Gateway Power Plant Facility ID No. 001-00215 Date Issued:FACILITY DRAFT Location:Boise, Idaho Monitoring and Recordkeeping Requirements Fu2:itive Emissions Monitorin2: ReQuirement The permittee shall monitor and maintain records ofthe frequency and the methodes) used (i. water, chemical dust suppressants, etc.) to reasonably control fugitive dust. The permittee shall maintain records of all fugitive dust complaints received. The permittee shall take appropriate corrective action as expeditiously as practicable after receipt of a valid complaint. The records shall include, at a minimum, the date each complaint was received and a description of the following: the complaint, the permittee s assessment of the validity of the complaint, any corrective action taken, and the date the corrective action was taken. Reporting Requirements Excess Emissions The permittee shall submit a report of any and all exceedances of any emission rate, visible emission, or operating requirement listed in the emissions limits and operating requirements sections of this permit to DEQ in accordance with IDAPA 58.01.01.130-136. Reports and Certifications All periodic reports and certifications required by this permit shall be submitted to DEQ within 30 days of the end of each specified reporting period unless specified otherwise in this permit. Excess emissions reports and notifications shall be submitted in accordance with Permit Condition 2.6. Reports certifications and notifications shall be submitted to the following: Air Quality Permit Compliance Department of Environmental Quality Boise Regional Office 1445 N Orchard St. Boise, ID 83706-2239 Telephone: (208) 373-0550 Facsimile: (208) 373-0287 In accordance with 40 CFR 60.4, all requests, reports, applications, submittals, and other communications to the EP A Administrator pursuant to 40 CFR 60 shall be submitted in duplicate to EPA Region 10 to the attention of the Director of the Office of Air Quality at the following address. Copies of all information required to be submitted to EP A for applicable NSPS requirements, shall also be submitted to DEQ at the preceding address. EPA Region 10 Air Operating Permits, OAQ-107 1200 Sixth Ave. Seattle, W A 98101 Page 7 AIR QUALITY PERMIT TO CONSTRUCT NUMBER: P-060005 Permittee:Mountain View Power Inc. - Gateway Power Plant Facility ID No. 001-00215 Date Issued:FACILITY DRAFT Location:Boise, Idaho Permit Application ReQuirements The permittee shall submit a complete application to DEQ for an initial Tier I operating permit within 12 months of operational startup of the combustion turbine. The permittee shall comply with the Acid Rain permit application requirements in accordance with 40 CFR 72.9(a) and 40 CFR Part 72, Subpart C. New Regulatory Requirements 40 CFR 60. Subpart KKKK The permittee shall comply with 40 CFR 60, Subpart KKKK as applicable and as required. Page 8 AIR QUALITY PERMIT TO CONSTRUCT NUMBER: P-O60005 Permittee:Mountain View Power Inc. - Gateway Power Plant Facility ID No. 001-00215 Date Issued:FACILITY DRAFT Location:Boise, Idaho SIEMENS 501F SIMPLE CYCLE NATURAL GAS-FIRED COMBUSTION TURBINE (CTO1 ) Process Description This combustion turbine (CTOl) has a nominal rating of 180 MWe and is used to generate electrical power to meet peak system load requirements. Emissions Control Description Emissions of NO x from CTOI are controlled by Ultra Dry Low NOx (DLN++) combustors. Emissions Unit(s) Process(es)Emissions Control Device Emissions Point Simple cycle Siemens Westinghouse 50lF U1tra Dry Low NOx (DLN++)Turbine stackcombustion turbine (CTOl) Table 3.1 COMBUSTION TURBINE DESCRIPTION Emissions Limits Nitro2en Oxides Emissions Standard - New Source Performance Standard In accordance with 40 CFR 60, Subpart GG, the permittee shall not discharge into the atmosphere from CTOl , any gases that contain nitrogen oxides (NOx) in excess of: STD = 0.0075 (14.4) where: STD - allowable NOx emissions (percent by volume at 15% oxygen and on a dry basis) Y - manufacturer s rated heat rate at manufacturer s rated load (kilojoules per watt hour) or, actual, measured heat rate based on lower heating value of fuel as measured as actual peak load for the facility. The value ofY shall not exceed 14.4 kilojoules per watt hour. = NOx emissions allowance for fuel-bound nitrogen as defined in 40 CFR 60.332(a)(3). Criteria Pollutant Emissions Limits Emissions of nitrogen oxide (NOx), sulfur dioxide (802), and carbon monoxide (CO) from the CTOI stack shall not exceed any corresponding emissions rate limits listed in Table 3. Table 3.2 COMBUSTION TURBINE EMISSIONS LIMITS' NOx S02Source Description T/yr T/yr T/yr Combustion Turbine CTOl 247.248.247. The pennittee shall not exceed the T/yr listed based on any consecutive 12-month period. Page 9 AIR QUALITY PERMIT TO CONSTRUCT NUMBER: P-060005 Permittee:Mountain View Power Inc. - Gateway Power Plant Facility ID No. 001-00215 Date Issued:FACILITY DRAFT Location:Boise, Idaho Operating Requirements Fuel Restrictions CTO 1 shall be fired by natural gas exclusively. Fuel Sulfur Content Limit The natural gas burned in CTO 1 shall not contain sulfur in excess of 0.2 gr/ dscf (20 grll 00 dscf) of natural gas. Nitro2:en Oxide Emissions Monitorin2: EQuipment ReQuirements - Installation and Operation The permittee shall install, certify, operate, and maintain in accordance with the requirements of 40 CFR , a NOx continuous emissions monitoring system (CEMS), consisting of a NOx pollutant concentration monitor and an oxygen or carbon dioxide diluent gas monitor, with automated data acquisition and handling system for measuring and recording the NOx concentration, in parts per million by volume (ppmv), and NOx emission rate, in pounds per hour (lblhr), discharged to the atmosphere from the CT01 stack. The permittee shall fully comply with all requirements set forth in 40 CFR 75 Subpart F and 40 CFR 60 , Appendices Band F. Carbon Monoxide Emissions Monitorin2: EQuipment ReQuirements - Installation and Operation The permittee shall install, certify, operate, and maintain a CEMS consisting of a CO pollutant concentration monitor and an oxygen diluent gas monitor. The CEMS shall be equipped with an automated data acquisition and handling system for measuring and recording the CO concentration (in ppmv) and CO emissions rate (in lblhr) discharged to the atmosphere from the CT01 stack. The permittee shall fully comply with all requirements set forth in 40 CFR 60, Appendices Band F. Turbine Exhaust Flowrate Quantification ReQuirement The permittee shall use the methodologies prescribed by Method 19 in 40 CFR 60, Appendix A, to quantify the CTO 1-'- exhaust gas flowrate. Turbine Startup Restriction The permittee shall under no circumstance commence initial startup of CT01 without prior, written DEQ-approval of the protocol required by Permit Condition 3.16. Page 10 AIR QUALITY PERMIT TO CONSTRUCT NUMBER: P-O60005 Permittee:Mountain View Power Inc. - Gateway Power Plant Facility ID No. 001-00215 Date Issued:FACILITY DRAFT Location:Boise, Idaho Monitoring and Recordkeeping Requirements Fuel Consumption Monitorin!! ReQuirement The permittee shall monitor and record the amount of natural gas combusted in CTO 1 on an hourly basis. The amount shall be recorded as cubic feet per hour. All records shall be kept onsite for a minimum of five years and shall be made available to DEQ representatives upon request. Nitro!!en Oxides Monitorin!! ReQuirement The permittee shall fully comply with all monitoring requirements established by 40 CFR 72.9(b). The permittee shall fully comply with all monitoring and recordkeeping requirements set forth in 40 CFR 75 Subpart F and 40 CFR 60, Appendix F. All records shall be kept onsite for a minimum of five years and shall be made available to DEQ representatives upon request. Carbon Monoxide Relative Accuracv Test Audit ReQuirement Within 60 days after achieving the maximum production rate at which CTO 1 will operate, but not later than 180 days after initial start-up of CTO 1, the permittee shall perform a relative accuracy test audit (RATA) on the CO CEMS. The initial RATA, and any subsequent RAT As conducted to demonstrate compliance, shall be performed in accordance with 40 CFR 60, Appendix F. All records shall be kept onsite for a minimum of five years and shall be made available to DEQ representatives upon request. Nitro!!en Oxides Performance Test ReQuirements - New Source Performance Standard Within 60 days after achieving the maximum production rate at which CT01 will operate, but not later than 180 days after initial start-up, the permittee shall conduct a performance test to measure NOx emissions from the CT01 stack, in accordance with the test methods and procedures in 40 CFR 60.335 and 40 CFR 60., to demonstrate compliance with the emissions standard in Permit Condition 3.3. The initial performance test, and any subsequent performance tests conducted to demonstrate compliance shall be performed in accordance with IDAPA 58.01.01.157 and General Provision 6 of this permit, or in accordance with an EP A-approved alternative. Visible emissions shall be observed and recorded during each performance test run using the methods specified in IDAPA 58.01.01.625. During the performance test, the amount of natural gas combusted by CTO 1 shall be recorded. Fuel Monitorin!! - New Source Performance Standard The permitee shall comply with the fuel sulfur and nitrogen monitoring provisions of 40 CFR Part 60.334(h) and 40 CFR Part 75, Appendix D. All data shall be kept onsite for a minimum of five years and shall be made available to DEQ representatives upon request. The permittee may, upon EPA approval and DEQ notification, use a single uiueline sampling location to monitor fuel for Gateway Power Plant. Page 11 AIR QUALITY PERMIT TO CONSTRUCT NUMBER: P-060005 Permittee:Mountain View Power Inc. - Gateway Power Plant Facility ID No. 001-00215 Date Issued:FACILITY DRAFT Location:Boise, Idaho Emissions Rate Quantification Protocol ReQuirement Within 60 days of permit issuance, the permittee shall submit a protocol addressing the methodology to be used to quantify NOx, CO, and S02 emissions rates from CT01 to DEQ for approval. The protocol shall explicitly describe and discuss the manner by which the permittee will utilize the data collected and/or derived in accordance with Permit Conditions 3.6 through 3., to quantify emissions rates of NOx, CO, and S02. The protocol shall include or identify, at a minimum, the source of all data to be used in the emissions rate quantification. The protocol must be sufficiently detailed to allow DEQ to reproduce and/or verify emissions rate estimates for purposes of determining compliance with Permit Condition 3.4. Nitro!!en Oxides. Carbon Monoxide. and Sulfur Dioxide Emissions Rate ReQuirements The permittee shall monitor and record the information listed below. The information shall be compiled in accordance with the DEQ-approved protocol required by Permit Condition 3.16. All data shall be kept onsite for a minimum of five years and shall be made available to DEQ representatives upon request. The total NOx emissions rate in tons per each calendar month after turbine initial startup. The total, cumulative NOx emissions rate in tons per each consecutive 12-month period. The total CO emissions rate in tons per each calendar month after turbine initial startup. The total, cumulative CO emissions rate in tons per each consecutive 12-month period. The total S02 emissions rate in tons per each calendar month after turbine initial startup. The total, cumulative S02 emissions rate in tons per each consecutive 12-month period. General Provisions ReQuirements - New Source Performance Standard The permittee shall comply with the applicable NSPS General Provisions specified in 40 CFR Part 60 Subpart A. Reporting Requirements Test Protocols for Continuous Emissions Monitorin!! System Certification/Recertification Tests The permittee shall submit a test protocol to DEQ for each certification and recertification of the NOx and CO CEMS required by Permit Conditions 3.7 and 3.8 for approval. Each test protocol shall be submitted to DEQ for approval at least 30 days prior to the respective test date. Continuous Emissions Monitorin!! System Quality Assurance Procedures ReQuirement All CEMS data submitted to EP A or DEQ shall meet the quality assurance procedures in 40 CFR 60 Appendix F. Page 12 AIR QUALITY PERMIT TO CONSTRUCT NUMBER: P-O60005 Permittee:Mountain View Power Inc. - Gateway Power Plant Facility ID No. 001-00215 Date Issued:FACILITY DRAFT Location:Boise, Idaho ReQuired Relative Accuracv Test Audit Information The results of any RAT As conducted for compliance shall be submitted to DEQ within 60 days of the completion of the test. Nitro2en Oxides Continuous Emissions Monitorin2 System Information The permittee shall fully comply with the reporting requirements set forth in 40 CFR 75 , Subpart G. In accordance with 40 CFR 75.60(b)(2), copies of all certification or recertification notifications certification or recertification applications, and monitoring plans shall be submitted to DEQ. The copies shall be submitted to DEQ no later than the respective date specified in 40 CFR 75 , Subpart G, for submission to the EP A Administrator. In addition, the permittee shall submit a written report (including all raw field data, etc.) to DEQ for each certification or recertification test required in accordance with Permit Condition 3.12. Each report shall be submitted to DEQ within 60 days of the date on which the respective test was completed. Performance Test Protocols The permittee shall submit a test protocol, for each performance test required in the monitoring section of this permit, to DEQ for approval at least 30 days prior to the test date. Performance Test Reports The permittee shall submit a written report of the performance test results, as required in the monitoring section of this permit, to DEQ within ;~O days rBennett Mtn Dermit has 60 davs lof performing each respective test. Excess Nitro2en Oxides Emissions - New Source Performance Standard An hour of excess emissions shall be anv unit oDeratin2: hour in which the 4-hour rollin2: avera2:e NOX concentration exceeds the aDDlicable emission limit in 40 CFR 60.332(a)(l) or (2) rSee 40 CFR 60. 334(j)(l )(iii). Also. under 40 CFR 334(h )(2), fuel bound nitro2:en monitorin2: is onlv necessary if an allowance for fuel bound nitro2:en is claimed - which is not the case here llFor the purpose of reports required under 10 CPR 60.7(c), periods ofexcess emissions of NO that shall be reported are defined as any period during which the fuel bound nitrogen of the fuel is greater than the maximum nitrogen content allowed by the fuel bound nitrogen allowance used during the performance test required in 10 CPR 60.8. Each report shall include the a'lerage fuel consumption, ambient conditions, gas turbine load nitrogen content of the fuel during the period of excess emissions, and the graphs or figures de'leloped under 10 CPR 60.335(a). Excess Sulfur Dioxide Emissions New Source Performance Standard The permittee shall submit a report of all excess emissions of S02 to DEQ in accordance with 40 CFR 60.7(b) through (d). For this report, excess S02 emissions are defined in 40 CFR 60.~333(eJV and 40 CFR 60.334(h)(3)as any €laHy-fuel samDlin2: period during which the sulfur content of the fuel being fired in the gas turbine exceeds 0.8% by weight. rSee SubDart GG revisions Julv. 8 20041 Page 13 AIR QUALITY PERMIT TO CONSTRUCT NUMBER: P-O60005 Permittee:Mountain View Power Inc. - Gateway Power Plant Facility ID No. 001-00215 Date Issued:FACILITY DRAFT Location:Boise, Idaho Page 14 AIR QUALITY PERMIT TO CONSTRUCT NUMBER: P-O60005 Permittee:Mountain View Power Inc. - Gateway Power Plant Facility ID No. 001-00215 Date Issued:FACILITY DRAFT Location:Boise, Idaho FUEL DEW POINT HEATER (FHO1) Process Description The fuel dew point heater is used to heat the incoming fuel to CTO 1 to optimize performance. Emissions Control Description Emissions from the fuel heater are uncontrolled. Emissions Limits Criteria Pollutant Emissions Limits The NOx, SO2, and CO emissions from the fuel heater stack shall not exceed any corresponding emissions rate limits listed in Table 4. Table 4.1 FUEL HEATER EMISSIONS LIMITS' Source NOx S02 Description T/yr T/yr T/yr Fuel Heater -h691.91 -l-:42, L6.Q The pennittee shall not exceed the T/yr listed based on any consecutive 12- month period. Fuel Burnine Equipment Emissions Standard Emissions of PM from the fuel heater shall not exceed 0.015 gr/dscf of effluent gas corrected to 3% oxygen by volume when fired with natural gas, as required by IDAPA 58.01.01.676. Operating Requirements Fuel Restriction The fuel heater shall be fired exclusively by natural gas. Fuel Sulfur Content Limit The natural gas burned in the fuel heater shall not contain sulfur in excess of 0.2 gr/ dscf (20 grll 00 dscf) of natural gas. Fuel Firine Restriction The volume of natural gas combusted in the fuel heater shall not ~xcee~(Sc2J 33 700 000 cubic feet in any consecutive 12-month period. Page 15 AIR QUALITY PERMIT TO CONSTRUCT NUMBER: P-O60005 Permittee:Mountain View Power Inc. - Gateway Power Plant Facility ID No. 001-00215 Date Issued:FACILITY DRAFT Location:Boise, Idaho Monitoring and Recordkeeping Requirements Operational Monitorinl! Requirement The permittee shall monitor and record the following information. All records shall be kept onsite for a minimum of five years and shall be made available to DEQ representatives upon request. The total volume of natural gas combusted in the fuel heater in standard cubic feet per calendar month. The total volume of natural gas combusted in the fuel heater in standard cubic feet per any consecutive 12-month period. Page 16 AIR QUALITY PERMIT TO CONSTRUCT NUMBER: P-O60005 Permittee:Mountain View Power Inc. - Gateway Power Plant Facility ID No. 001-00215 Date Issued:FACILITY DRAFT Location:Boise, Idaho PERMIT TO CONSTRUCT GENERAL PROVISIONS The permittee has a continuing duty to comply with all terms and conditions of this permit. All emissions authorized herein shall be consistent with the terms and conditions of this permit and the Rules for the Control of Air Pollution in Idaho. The emissions of any pollutant in excess of the limitations specified herein, or noncompliance with any other condition or limitation contained in this permit, shall constitute a violation of this permit and the Rules for the Control of Air Pollution in Idaho and the Environmental Protection and Health Act, Idaho Code 939-101 , et seq. The permittee shall at all times (except as provided in the Rules for the Control of Air Pollution in Idaho) maintain in good working order and operate as efficiently as practicable, all treatment or control facilities or systems installed or used to achieve compliance with the terms and conditions ofthis permit and other applicable Idaho laws for the control of air pollution. The permittee shall allow the Director, and/or the authorized representative(s), upon the presentation of credentials: To enter, at reasonable times, upon the premises where an emissions source is located, or in which any records are required to be kept under the terms and conditions of this permit. At reasonable times, to have access to and copy any records required to be kept under the terms and conditions of this permit, to inspect any monitoring methods required in this permit, and require stack compliance testing in conformance with IDAPA 58.01.01.157 when deemed appropriate by the Director. Nothing in this permit is intended to relieve or exempt the permittee from compliance with any applicable federal, state, or local law or regulation, except as specifically provided herein. The permittee shall furnish DEQ written notifications as follows in accordance with IDAP A 58.01.01.211.01 and 211.03: A notification of the date of initiation of construction, within five working days after occurrence; A notification of the date of completion/cessation of construction, within five working days after occurrence; A notification of the anticipated date of initial start-up of the stationary source or facility not more than sixty days or less than thirty days prior to such date; A notification of the actual date of initial start-up of the stationary source or facility within fifteen days after such date; and A notification of the initial date of achieving the maximum production rate, within five working days after occurrence - production rate and date If performance testing (air emissions source test) is required by this permit, the permittee shall provide notice of intent to test to DEQ at least 15 days prior to the scheduled test date or shorter time period as approved by DEQ. DEQ may, at its option, have an observer present at any emissions tests conducted on a source. DEQ requests that such testing not be performed on weekends or state holidays. Page 17 AIR QUALITY PERMIT TO CONSTRUCT NUMBER: P-O60005 Permittee:Mountain View Power Inc. - Gateway Power Plant Facility ID No. 001-00215 Date Issued:FACILITY DRAFT Location:Boise, Idaho All performance testing shall be conducted in accordance with the procedures in IDAPA 58.01.01.157. Without prior DEQ approval, any alternative testing is conducted solely at the permittee s risk. If the permittee fails to obtain prior written approval by DEQ for any testing deviations, DEQ may determine that the testing does not satisfy the testing requirements. Therefore, at least 30 days prior to conducting any performance test, the permittee is encouraged to submit a performance test protocol to DEQ for approval. The written protocol shall include a description of the test methodes) to be used, an explanation of any or unusual circumstances regarding the proposed test, and the proposed test schedule for conducting and reporting the test. Within 30 days following the date in which a performance test required by this permit is concluded, the permittee shall submit to DEQ a performance test report. The written report shall include a description of the process, identification of the test methodes) used, equipment used, all process operating data collected during the test period, and test results, as well as raw test data and associated documentation including any approved test protocol. The provisions of this permit are severable, and if any provision of this permit to any circumstance is held invalid, the application of such provision to other circumstances, and the remainder of this permit shall not be affected thereby. In accordance with IDAP A 58.01.01.123, all documents submitted to DEQ, including, but not limited , ' records, monitoring data, supporting information, requests for confidential treatment, testing reports or compliance certification shall contain a certification by a responsible official. The certification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the document(s) are true, accurate, and complete. Page 18 Fu e l H e a t e r D a t a Op e r a t i n g H o u r s Fu e l H e a t c o n t e n t Fu e l H e a t c o n t e n t Fu e l 8 C o n t e n t Fu e l H e a t e r H e a t Fu e l H e a t e r F u e l (H H V ) (L H V ) In p u t In p u t NO x ( l b / M M s c f ) CO ( l b / M M s c f ) VO C ( l b / M M s c f ) 80 x ( a s 80 2 ) (l b / M M s c f ) PM 1 0 (f r o n t a n d b a c k ) (l b / M M s c f ) Ga t e w a y P o w e r P l a n t Op e r a t i n g D a t a 87 6 0 12 0 0 B t u / s c f 93 5 B t u / s c f 20 g r / 1 0 0 d s c f 6 M M B T U / h r 00 3 9 M M s c f / h r 33 , 72 8 , 34 2 s c f / y r Em i s s i o n s D a t a 28 . 57 1 4 2 9 l b / M M d s c f Em i s s i o n Fa c t o r (l b / M M s c f ) Em i s s i o n s (l b / h r ) 43 5 7 36 6 0 04 7 9 22 0 0 03 3 1 (g m / s ) 05 4 9 04 6 2 00 6 0 02 7 7 00 4 2 (t o n / y r ) 90 8 4 1. 6 0 3 1 20 9 8 96 3 7 14 5 0 No t e : NO x , C O , V O C , a n d P M b a s e d o n m a n u f a c t u r e r da t a . St a c k D a t a 80 2 b a s e d o n f u e l s u l f u r c o n c e n Ex h a u s t Ex h a u s t Ex h a u s t Ex h a u s t Ex h a u s t Te m p e r a t u r e Ga s F l o w Di a m e t e r Ve l o c i t y He i g h t A b o v e Gr o u n d 10 0 0 F 23 6 9 a c f m 00 f t 12 . 57 f t / s 18 . 0 f t fu e l - he a t e r . xl s , H e a t e r , 6 / 2 8 / 2 0 0 6 , G. F r i s b i e 81 1 K 67 . 09 a c m m 61 m 3 . 8 3 m / s 49 m 'to~. ~ ,~ .;:... ' ~A1.,,~ ~L GREYSTONEO1) Environmental Consultants, Inc. December 19, 2005 Bill Rogers Regional Pennit Program Coordinator Idaho Department of Environmental Quality 1410 N. Hilton Boise. Idaho 83706 Dear Mr. Rogers: Attached is the air quality dispersion modeling summary for the Gateway power Plant. Electronic copies oftiles used for this analysis have also been included on a compact disk. If you have any questions please contact me at 303.850-0930. or email me at GFrisbie~adis.us.com. Sincerely, ~~. Gordon Frisbie Air QuaJity Specialist Attachment cc: Bob Loopert Mountain View Power an ARCADIS company ReceIVED lEe 2 0 ~~:;; .., MAt 5231 South Quebec Street. Greenwood Village. Colorado 8O111 Tel 303.850.0930 . Fax 303.721.9298 . www.grcystone.u5 .. www.arcadis-us.com co. DElAFSlSF C-' .. \ II 'I:;~~lV'\" AIR MODEUNG SUMMARY '-'-"'\ Co GATEWAY POWER PLANT AIR. QUALITY MODELING ANALYSIS Submitted to: Idaho Department ofEnviromnenta1 Quality Boise, Idaho Submitted for: Mountain View Power, Inc.Bo~ Idaho Prepared by: RECEIVED DEt 2 0 2116 at &.a..1IMIIII1QuIIy S1ItI HI PftQIIII Greystone Environmental Consoltants, Inc. December 2005 . an ARCADIS company Gateway Power Plant Air Modeli"g Summary TABLE OF CONTENTS ,.. '..4 0 Introduction....... ..... ............................................................... ............ ...... ............. ......... ................ 0 SoW"Ce Descriptions ......................................... ................................. ...... ...................................... 1 Combustion Turbine ................................................................................................................. 2 2 Fuel Dew Point Heater .......................................................:........................... ........................... 2 0 Project Emissions and Source Data """""""""""""""""""""""""""""""""""""""""""""" 1 Emission Controls........ ............ ........ ................ .............. ................................ ........................... 3 0 Project Emissions and SoW"Ce Data .............................................................................................. 4 1 NolDlal Operation Emission Rates............................................................................................ 4 2 Startup and Shutdown Emission Rates """"""""",,"""""""""""""""""""""""""""""""'" 4 0 IJnpact Analysis ..... ..... ..... ....... ............ ....... ........... ..... ....... ............ ..... ...... ............ ... ...... ................ 6 1 Ambient Air Quality Standards """""""""""""""""""""""""""""""""""""""""""""...... 6 2 Background Pollutant Concentrations """""""""""""""""""""""""""""""""""""'"......... 6 3 Criteria Pollutant Impact Analysis............................................................................................ 7 4 Toxic Air Pollutant (1'AP) IJnpact Analysis ............................................................................. 7 5 Fuel Dew Point Heater Cavity Analysis ................................................................................... 8 6 Model Results """"""" ........... ....... ................. ............. ..... ........... ........... ........... .......... ....... ...... 8 1 Estilnated IJnpacts - Criteria Pollutants ............................................................................. 8 6.2 Estimated IJnpacts - tAPs """"""""""""""""""""""",,""""""""""""""""""""'"...... 3 Fuel Fuel Dew Point Heater Cavity IJnpacts ........................................................~.......... 10 TABLES Table 3-1 Range of Ambient Conditions and Operating Parameters ................................................. 3 Table 4-1 Maximum NOID1al Operation Emission Rates ................................................................... 4 Table 4-2 Startup and Shutdown Emission Rates............................................................................... 5 Table 4-3 Startup Schedules """""""""""""""""""""""""""""""""""......................................... 5 Table 5-1 Summary Of Regu1atory Ambient Air Concentrations .....................................~................ 6 Table 5-2 Default Criteria Pollutant Concentrations .......................................................................... 7 Table 5-3 Screen3 Averaging Period Factors """""""""""""""""""""""""""""""""""""""""'" 8 Table 5-4 Modeled Air Quality IJnpacts """""""""""""""""""""""""""""""""""""""""""""" Table 5-5 Maximum TAP IJnpacts ............................................................................... .................... 10 Table 5-6 Maximum Dew Point Heater Cavity Impacts .................................................................. 10 FIGURES ,.,......-'"".- ON .....,-,~"""'~"""'~""'--"'" .,.~ Figure I Nitrogen Oxides - Annual Impacts..................................................................................... Figure 2 Carbon Monoxide - I-Hour Impacts .................................................................................. 12 Figure 3 Carbon Monoxide - 8-Hour Impacts .................................................................................. 13 Figure 4 Particulate Matter (pMI0IPM2.5) - 24-Hour IJnpacts ....................................................... 14 Figure 5 ParticuJate Matter (PM 1 0IPM2.5) - AnnuallJnpacts ............... ........................ .................. 15 II tewa Y -mode I-summary. doc - 1 - Gateway Power Plant Air Modeling Summary Figure 6 SuJfur Dioxide - 3-Hour Impacts........................................................................................ 16 Figure 7 Sulfur Dioxide - 24-Hour Impacts.................................................................................... Figure 8 Sulfur Dioxide - AnnuaJlmpacts ....................................................................................... 18 gateway-model-summary .doc - ii - Gateway Power Plant Air Modeling Summary 0 Introduction "... Mounwn View Power, Inc. proposes to construct and operate the Gateway Power Plant (OPP) (previously refen-ed to as the East Boise Power Plant). OPP will generate electricity using clean burning combustion turbine (CT) technology. The CT will be a Siemens-Westinghouse 501F (SW 501 F) with a nominal rating of 180 MW at 59OF (greater than 200 MW at -200F). The cr will operate in simple cycle mode and will be fired on natural gas. The power plant will comply with federally enforceable restrictions to limit emissions of criteria pollutants to less than 250 tons per year (ton/yr) as a synthetic minor source. This document summarizes the air quality dispersion modeling analysis that was performed according to the modeling protocol submitted to Idaho Department ofBnvironmenta1 Quality (IDEQ) in September 2005. This summary also addresses IDEQ's comments on the modeling protocol that were received on December 14, 2005. gateway -model-summary. doc - 1 - Gateway Power Plant Air Modeling Summary ,,- 0 Source Descriptions There were two emission sources included in the dispersion modeling analysis: The combustion turbine (CTOJ) Fuel Dew Point Heater 1 Combustion Turbine cro 1 wiJl be a simple cycle combustion turbine, and will primarily be used to generate electric power to meet peak system load requirements. The SW SOl F combustion turbine is capable of rapid start-up thus permitting the plant to" quickly respond to system demand. CTOI will have a nominal rating of 180 MW at 59OP (greater than 200MW at -20 Of). CTO 1 will also be equipped with an evaporative cooler to improve power generation during periodsof hot weather. 2 Fuel Dew Point Heater A 2.0 MMBTU/hr fuel dew point heater will also be added at the GPP site. The dew point heater will treat incoming fuel to optimize CT performance. This heater will be fired with natural gas. gateway-model-summary .doc - 2- Gateway Power Plant Air Modeling Summary -'.......... 0 Project Emissions and Source Data Emissions rates were evaluated over the range of expected ambient temperatures and range of CT operating loads. These also included emissions occuning during startup and shutdown operations. Startup and shutdown operations covered the load range &om 0 to 60 percent load, and normal operations included the loads ftom 60 to 00 percent. Table 3-1 presents the range of operating and ambient parameters that were included in the modeling analysis. Table 3-1 Range of Ambient Conditions and Operating Parameters 20 0 50, 100 110 1000,4 600/0, 10% Startu Ishutdo 60% 70%, 80010 90% 100% Operating and emissions data for the range of ambient and operating conditions presented in Table 3-1 were provided by Siemens-Westinghouse. 1 Emission Controls Ultra Dry Low NO)! (UDLN) combustors willlimit emissions of nitrogen oxides (NO)!) to 10 parts per million dry volume basis corrected to 15 percent oxygen (ppmvd (S 15% Ch) at operating loads above 70 percent. NO)! concentrations at normal operating loads between 60 and 70 percent are expected to be 12.5 ppmvd (S 15% Ch. These higher concentrations were acco\U1ted for in the modeling analysis. Emissions of carbon monoxide (CO), non-methane-ethane volatile organic compo\U1ds (VOC), toxic air pollutants (TAP) and particulate matter with a nominal aerodynamic diameter less than 10 and 2.5 micrometers (PMI0 and PM2.S respectively) will be controlled with efficient combustion. Emissions of sulfur dioxide (S~) will be controlled through the use of low sulfur natural gas. gateway. model.summary. doc - 3 - Galeway Power Plant Air Modeling Summary Table 4-2 Startup and Shutdown Emission Rates EmissioD Rates uuds r hour DurationOperating Scenario Shutdown PMIO and PM2oS 1 1. NOs 83. 101. 1514. 1811. VOC 146. 174. 802 8.19 Depending on the averaging period, emissions corresponding to a conservative schedule of startups were combined with normal operation (60 to 100 percent load) emissions. These averages were compared to continuous norma) operation emissions and the maxi:mwn of these two values were used in the dispersion modeling analysis. Table 4-3 presents the startup and shutdown schedulesused in this analysis. Table 4-3 Startup Schedules . Averaging Period Number of Startu s 400 To maintain conservatism in the emission estimates, no downtime was assmned to occur between a shutdown and startup for the multiple startup schedules. In addition, because shutdown emissions are slightly greater than startups, these schedules also account for multiple power trips during the 1, 3 , and 8-hour averaging periods. During a startup power trip, the load will drop back to zero percent and the grid synchronization process must be repeated. The result is an extended period of startup. The schedules presented above assume the CT will always be in startup or shutdown during the 1, 3 or hour period. gatcwa y-model-summary .doc - 5- , - Gateway Power Plant Air Modeling Summary 0 Impact Analysis This section describes the air pollutant dispersion modeling results. 1 Ambient Air Qu~lity Standards Table 5-1 presents the ambient air quality criteria that were used to assess the results oftbe dispersion modeling. The ambient air quality concentrations are presented in units of micrograms per cubic meter (Jiglm Table 5.1 Summary Of Regulatory Ambient Air Concentrations PoDutant A ver82in2 Period NMOS (uelm~ N(h Annual 100 hour 40,000 hour 10.000 24-hour ISO PMIO Annual 24-hour PM2.Annual hour 300 24-hour 365 Annual 78. 2 Background Pollutant Concentrations IDEQ provided default criteria pollutant background concentrations (Table 5-2) that were used in the modeling analysis. These values were added to the estimated maximwn GPP impacts to assess any potential cmnulative impact. gltewa y- model-summary .doc - 6- Gateway Powe" Plant Ai,. Modeli"g Summary .., Table 5-2 Default Criteria Pollutant Concentrations PoUutaDt A vera2iD2 Period Baek2round Cone. (1&2Im~ NCh Annual Hour 10,200 Hour 400 24-Hour PMlo Annual 24-Hour Undefined PM2.Annual Undefined Hour 24-Hour S(h Annual . 5.3 Criteria Pollutant Impact Analysis The load analysis evaluated impacts ftom all criteria pollutant emissions. For each load and ambient condition, the nonnal emissions were combined with startup and shutdown emissions and compared to normal emissions without startup or shutdown events. For each operating scenario, the CT emissions were represented as source groups that reflect each operating scenario. Plot files for each source group were generated for each pollutant and averaging period. These plot files were post-processed to determine the maximum impacts and worst-case operating scenarios. 4 Toxic Air Pollutant (TAP) Impact Analysis ecause it was necessary to evaluate impacts for 11 different TAPs, these were evaluated using exhaust parameters for a single operating scenario. The operating scenario that resulted in the maximum I-hour CO impact was used as the worst-caSe scenario for the TAP analysis. In other words, the exhaust parameters associated with the maximwn I-hour CO impact were used to model each of the TAP impacts. A single run with unit emissions (1.0 grams per second (gmls)) for each source were perfonned for each meteorologica1 year. Because only a single source was modeled, scaling the impacts with the ratio of actual emissions over unit emissions produces an accurate result. To ensure the conservatism of this analysis, the maximum TAP emission rates over aU operating scenarios were used in the dispersion modeling post-processing. To demonstrate the accuracy of the post-processing, a sample run using actual emissions for a specific TAP was also evaluated. gatewa y- model-summary. doc - 7- Gtlleway Power Plant Air Modeling Summtuy 5 Fuel Dew Point Heater Cavity Analysis Cavity influences of the CTO I structure on emissions from the fuel dew point heater were evaluatedusing the SCREEN3 dispersion model. ModeJ inputs included stack and exhaust data for the dew point heater and dimensions of the CTO I structure. ecause only a single stack was modeled, an emission rate of 1.0 gmls was used in the SCREEN3 run. The resulting impact was then be apportiQned by the estimated dew point heater emission rates for each criteria pollutant. The impacts estimated by SCREEN3 represent a I-hour averaging period. For other averaging periods, the factors on Table 5-3 from the SCREEN3 Users Guide (USEP A 1995) were used. Table 5-3 Screen3 Averaging Period Factors A veral!ine: Period Factor HoW' Hour 24-Hour 0.4 Annual 6 Model Results 1 Estimated Impacts - Criteria Pollutants The resulting estimated ambient concentrations ftom the GPP facility are shown on Table 5-4. These results represent the maximum impacts from all operating scenarios. These also include impacts from the fuel heater. For NAAQS impacts, the background concentrations presented in Section 5.2 have been added to the faci1ity impacts. Figures 1 through 8 present estimated the facility impacts over the Boise region. These figures show contours of estimated impacts from GPP without background air quality included. These - contours show that the general air quality impact will be insignificant. Electronic copies of the calculations and input and output dispersion modeling files have been provided on a CD that accompanies this summary. gateway- model- swnmary .doc - 8- GaIeWay Power Plont Air Mode/ing Summary Table 5-4 Modeled Air Quality Impacts Ooeratin2 Scenario Maximum Ambient Fadllty Impact with Percent A veragiDg CT Load Temperature Impact Background PoUutaDt Period (oercent)(OF)(Jielm3)(pglm3)NAAOS NCh Annual 36.1 36. Hour 110 1227.11427.28. Hour 110 200.3600.36.0010 24-Hour 86.57. PM 10 Annual 27.54. 24-Hour PM2.5 Annual Hour 45. 24-Hour 26. Annual 10. 2 Estimated Impacts . TAPs TAP emissions were estimated using USEP A emission factors from AP-42 Tables 3.3 for the CT and Table 1.4-3 for the fuel heater. Because the cr emissions are much greater than those from the fuel heater, only the pollutants included in AP-42 Table 3.3 were included in this analysis. The emission factors for each TAP were used to estimate emissions using the maximum fueling rates for each configuration. Table S-S presents the estimated TAP emissions and impacts, and how these relate to DEQ emission and impact standards (IDAPA 58.01.01.585 and 586). The TAP emission rates and impacts assume continuous operations and no emission controls. gateway-model-summary .doc 9 - Galeway Pawer Plant Air Modeling Summary Annual AACC 60E-O3 4. 50E-O 1 1.20E- 70&-02 00E-04 25E+Ol 18E+04 50E+O3 40E+O3 J .88E+04 2. 18E+04 3 Fuel Fuel Dew Point Heater Cavity Impacts Table s..6 presents the maximum impacts from the dew point heater SCREEN3 cavity analysis. These impacts were estimated to occur 16 meters ftom the source. Although these impacts are not predicted to occur in ambient air (i.e. beyond the facility fence line), all estimated impacts were below the NAAQS. Table 5-6 Maximum Dew Point Heater Cavity Impacts Pollutant Avera Period Cavi actNOz Annual 10.Hour 112.Hour 78.24-Hour 4.Annual 0.Hour 2.24-Hour 1.15Annual 0. PM1o S02 gateway-model-summary .doc - 10- Attachment 2 COpy c.: . ""-'--'- AlN VEW ....... INC. October 1 0, 2005 Bill Rogers Idaho DEQ 1410 North Hilton Boise, ID 83706-1255 RECEIVED OCT 1 \ 2005 Re: Gateway Power Plant - Modeling Protocol Depa/1m8rJ1 of Environmental Quaily SII8 ,. PragIUl Dear Bill, Please find enclosed two copies of the Air Pollutant Dispersion Modeling Protocol for a Synthetic Minor Source for the East Boise (Gateway) Power Plant. Mountain View Powert Inc. (MVP) is proposing to develop a 180 MW natural gas fired peaking facility in the City of Boise Gateway Industrial Park located in East Boise off Eisemnan Road. MVP has submitted this project to Idaho Power as part of their Request for Proposals for new generating resources to be constructed by June of 2007. This facility will be very similar to the Bennett Mountain Power Plant using Siemens 501 F technology. If you have any questions you can give Gordon Frisbie at Greystone (303-850-0930) or myself a call. /0/5 West Hays Street Boise, JdDho 83702 Telephone (208) 331-/898 Facsimile (208) 343-/2/8 .., RECEIVED OCT 1 ~ . Deparment of EnWonmenIaI Quaity SI&1e AjJ Program PROTOCOL EAST BOISE POWER PLANT AIR POLLUTANT DISPERSION MODELING PROTOCOL FOR A SYNTHETIC MINOR SOURCE SJdmtitted to: Idaho Department of Enviromnental Quality Boise, ID Submitted for: Mountain View Power, Inc. Boise, PreptJretl by: Gt'cyBtone Environmental Consultants. IDe. Denver, CO September 2005 TABLE OF CONTENTS 1.0 TABLES IN'TR.ODUC1'ION ........................ ....... .......... ............. ..... .... .... ..... .................. ........... ....... ......... ... PROJECT LOCA nON ............. ............................ ................. ... .... .............. ... ....... ....... ......... ....... s()URCE DESCRIPTIONS................ .... ... .................... ...... .......... ........... ...... .... ......... ....... .......... PROJECT EMISSIONS AND SOURCE DATA .........................................................................4-1 Emission Controls..... .... ..... .......... ................ ........... ..... .... .......... .............. ........ ......... ....... 4-1 4.2 CT Startup E'missions ............................................................. :.......... .............................. 4-1 IMPACT ANALYSIS. ........ .... ........ ........ ............... ....... ..... ........... ...... ............ .... ........... ..,............ 5- Combustion TUlbiDe ........ .... ........ ........... ...... ......... ... .............. ........ ... ...,........................ .. 3-1 Fuel Dew Pomt Heater .............................................................................. .......................3-1 5.1 5.2 Ambient Air Quality Standards ..... ...... ........ ........ ..... ................. ......... ..... .... ... .......... ....... Background Pollutant Concentrations .............. ........ ........ ......... .... ............... .......... ......... 5- Local T crrain........ .............. .... ... ... .. ........ . ... ............ ...... .......... .............. ....... ...... ... ..... ....... 5- Model Se1ection aDd Setup .............................................................................................. 1. Model Setup.... ...... ........ ...... ............ ............ ........ ................. .... ....... .................... 5-2. Building Downwash aDd Good Engineering Practice ........................................5-33. Class U Receptor Grid........................................................................................ Meteorologi&:al Data .... .... ....... ..... ............. .................... ......... .... ........ ......... ............... ...... 5-4 1. Data Selection-.............. .............................. .... .... .... .......... ............. ....... ... ........ ... 5-4 5.2. Data Processing .... .......... ................. ......... ... ............. ............... ...... ............... ...... 5-4 CT Load Analysis ..... .... ....... ........... ..... ................. ................. ............... ...... ........ .......... ... 5-41. Criteria Pollutam bDpact Analysis .....................................................................5-4 6.2. Toxic Air Pollutant (TAP) lIDpaet Analysis.......................................................5-4 Fuel Dew Point Heater Cavity Analysis .......................................................................... Table 4-1 Table 4-2 Table 5- Table 5- Table 5- Table 5-4 Table 5- FIGURES Range of Ambient aDd Operating ParaaLeters......... ......... ....... ........... ................ ........... ... 4-1 EBPP Emission Rates ........ ............. ................... ....... .......... ........... ................ .... ... ........... 4-1 S1.IIIUD8ry ofRegulatoI)' Ambient Air Coneentrations ... :................................................ I)efauJt Criteria Pollutant Concentrat:ioDs. ~... ;;'-...;;. .-;..~; .... ;;..... ;............. ......... ....... ....... .... 5.;.1" Building Dimensions ......... ................ .... ...... ... .... ...... ...... .... ......... ......... ......... ... .;... ....... .... 5- Ambient Receptor Locations ........................................................................................... SCREEN3 Averaging Period Factors .............................................................................. Fig\R 2- Fig\R 3- Site Location Map............ ......... ... ........... ..... ......... ............. ................... ...... ... ....... ........... Site Layout. ................... ..... .......... .... ............ ... ... ... .......... ... ..... ....... ................ ....... ........... P1833-EBPP Madel PIotDc:oU9.27.o5).doc INTRODUCTION MoUntain View Power,lDe. proposes to construct and operate die East Boise Power Plant (lmPP). BBPP will genemte electricity using clean burning combustion tuJbine (CT) technology. The CT win be a Siemens-Westinghouse SOIF (SW SOIF) with a nominal rating of 180 MW at S~F (greater than 200 MW at -20oF). The CT will operate in simple cycle mode and will be fired on natura1 gas. The power plant will comply with federally enforceable restrictions to limit emissions of criteria pollutants to less than 250 tons per year (tonlyr) as a synthetic minor SOU11:e. This document outlines the air quality dispersion modeling protocol for the air quality analysis that will be conducted for the air quality Permit to Construct (PTC) appli~on for EBPP. PI833.EBPP Model PrcIfIxoU9.27.05).doc PROJECT LOCATION EBPP is located approximately 0.7 miles west of Interstate 84 at the South EiMnlnan Road exit (FIpre 2-1). This location is designated as a Class n aimhed under federal and state air quality regulations. The air quality at this location is m IftsI;ftment for all federal and state Class D air quality standards. The nearest federal Class I airsheds to project site would mclude: The Sawtooth Wilderness (9S kID) Craters of the Moon National Monument (204 kID) , "'.. -" P1833-EBPP Model PrOfocoU9.27.05).dac FIGURE 2-1 SITE LOCA T1ON MAP (1)8l1li 1...~V8IS MEk lOA COWiTY'.1IWtO D88I: 04I28U FIe: P183I8I1'E.cIIIg Dr-. By. JU 0 SOURCE DESCRIPTIONS 1'btn will be two emission sour=s included in the dispersion IJtOdeln,g aoalysis: The combustion tUlbinc (CTOl) Fuel Dew Point Heater FIgure 3-1 presents the layout of the emission points and sources relative to the property boundaries. COMBUSTION TURBINE CTOl will be a simple cycle combustion twbinc, and will primarily be used to generate electric power to meet peak system load requirements. The SW SO IF combustion tUJbine is capable ofmpid start-up thus permitting the plant to quickly respond to system denumd"CfOl will have a nominal rating of 180 MW at S9DF (greater than 200MW at -20 Of") The cr will be a singJe-abaft lDBt'.hiIJ e of single casing design. The and tulbine have a common rotor supported by two bearings: one located at the inlet side of the compressor and the second located at the exhaust side of the tmbine. The rotor is an assembly of discs. each cmyiDg ODe row of blades. and hollow shaft section, all held together by a pre-stressed central through bolt. The turbine rotoris intema))y air-cooled. An air inlet system provides filtered air to the CT compressor. The system will be equipped with multi- stage, static filters. and an evaporative cooler to enhance performance at ambient temperatures greater than SOOF. Following the COInIbeasor, a ring combustor is connected to the common outer casing of the tulbine. Natural gas is injected into the combustion chamber and ignited. The hot combustion gases expand through the turbine section of the CT, causing the main abaft to rotate and drive the electric geoeratoIs and cr compresSO!S. A u.nifomt exhaust gas temperature field is distributed over the full cross sectional area of the diffuser that directs the combustion gases to the tmbinc blades. FUEL DEW POINT HEATER .- -,- "... , ".. -.... u , .,_. ....- ---.",' .. .. u_.. -..--'-.---"'-."."--.--. A 2.0 MMBTIJIbr fuel dew point heater will also be added at the EBPP site. The dew point beater will tIeat incoming fuel to optimize cr performance. Th.i$ heater will be fired with natural gas. P '833-ESPP Model PIUIOGoU9.27.05).doc ~------ 1_- . -..-.....,...---.---....----- t ------ .--.. ------ II -----....-- " -I'M .. --... --. 567_E~817.'27 N Zon811 .". LA~ Cl) ----_.... -- -... oLI 0 PROJECT EMISSIONS AND SOURCE DATA Emissions rates will be evaluated over the rage of expected ambient temperatures aDd rage ofCf operating loads. These will also include emissions occurring during startup and shutdown operations. Startup aDd abutdown operations will cover the load nnge from 0 to 60 pen:cnt load, and nmmal operations will mclude the loads from 60 to 100 percenL Table 4-1 presents the range of operating and ambient parameters that will be included in the modeHng analysis. TABLE..1 RANGE OF AMBIENT AND OPERATING PARAMETERS Ambient T OF) -20. O. SO. 100. 110Ambient Relative HumiditY l000A;: 6()O/o. 10%Loads shutdown. 60%. 70%. 80%. 90%. 1000-" Operating and emissions data for the nmge of ambient and operating conditions presented in Table 4-1will be provided by Siemens- Westingbouse. Pre1;mnul1')'estimates for the mSly;mllm facility emissions are presented in Table 4-2. Annual emissions that were estimated to be greater than 249 tons per year have been 8Ibitrarily set to 249 tons per year. These emissions reflect operations over the entire range of loads and conditions. Pollutant.Iblhr tonlyr No..161 249 645 249 Vex:159 119.so, PM1O 136 TABLE 4-2 EBPP EMISSION RATES .. ....- ------. .----_u..---..-....---.. EMISSION CONTROLS Dry low NOs (DLN) combustors will limit emissions of nitrogen oxides (NOs) to 20 parts per million dry volume basis corrected to 15 percent oxygen (ppmvd (!) 15% 02) at operating lodda above 70 pm:cnt. NOIt concentrations at nonna1 operating loads between 60 and 70 percent are expected to be greater 1han 20 ppmvd (!) 15% 02. These higher concentrations will be accounted for in the modeling BDBlysis. P.m;"ions of carbon monoxide (CO), DOO-metbane-ethane volatile organic compounds (Voc). toxic air pollutants (TAP) and particulate matter with a nominal aerodynamic diameter less than 10 micrometers (PM1o) will be controlled with efficient combustion. Emissions of sulfur dioxide (80.z) will be controlled tbroush the WIe of low sulfur natural gas. CT STARTUP EMISSIONS During the Startup and shutdown of a cr, short term elevated emissions of NOllo CO, and VOC may exceed the hourly values shown in Table 4-2. Because emissions of PM1o and are related to fueling rata and operating loads, these emissions would typically be lower than normal operation emissiODS during startup and shutdown events. Pl833-EBPP Model Protooot(9.27.05).doc 0 Propt &.iuitMu IIIId Data Startup and shutdown events are expected to be Jess than O.S hours, and, as a preliminary estimate, there may be as many as stanup events per day and 200 startup events per year. A schedule of stanup fiequencies used for each averaging period win be included in the PTC applicati~ Depending on the averaging period, emissions corresponding to a conservative schedule of startup& will be combined with normal operation (60 to 100 percent load) emjssions. For example, hours ofslartup and shutdown emissions may be combined with 19 hours of normal emissions to calculate a 24 hour average. These averages will be compared to continuous normIJ operation emissions and the maximum of these two values will be used in the dispersion modeling analysis. -- ".... ----'-.. - u - - -..----- --- ---"------ PlI3J-EBPP ModI:I prucocoU9.27.0S).d0c 4-2 0 IMPACT ANALYSIS This section describes the air poUutant dispersion ~1"'a setup for the EBPP PTC application. Thefollowing modeling and analysis methods for the air quality impact assessment will be discussed: Ambient air quality standards Background pollutant concentrations Local terrain Model selection. setup. and default parameters Meteorological data selection and processing . cr load analysis AMBIENT AIR QUALI1Y STANDARDS Table 5-1 presents the ambient air quality criteria that will be used to assess the results oftbe dispersion modeling. The significant impact levels (SILa) will be used to determine whether it will be necessary assess cumulative impacts to the National Ambient Air Quality Standards (NAAQS) for any pollutant andavenging period. TABLE 5-1 SUMMARY OF REGULATORY AMBIENT AIR CONCENTRATIONS Pollutant Averaging Period aiLs (JI9Im NAAQS (lCllma NO2 Annual Mean 100 Hour 000 40.000 8-Hour SOO 10.000 PMIR 24-Hour 150 Annual Mean 1.0 Hour 300 24-Hour 365 Annual Mean 1.0 BACKGROUND POLLUTANT CONCENTRATIONS Table 5-2 presents the DEQ default criteria pollutant background conceutratioas that are proposed for this modeling analysis. These values will be added to the esrimated EBPP impacts to assess any potential cumulative impact. TABLE 5-2 DEFAULT CRITERIA POLLUTANT CONCENTRATIONS Pollutant Averaging Period Background Cone. (lIglm~ NO2 Annual CO -Hour 10.200 8-Hour 3 .400 PMlo 24-Hour ADnual Hour 24- Hour ADnual P1833-EBPP Model ProIDcoU9.27.o5).doc brtptIct Alllll)/l1I LOCAL TERRAIN Tbe tenain in the yjcinity of the proposed site includes simple. intermediate. and complex temin. The terrain to the north. east. and west of the Dci1ity site is primarily simple terrain. The terrain to the south is a combination of simple and complex terrain. The nearest complex terrain (terrain with elevations above stack height) exists approximately I Ian to the south of the facility site. MODEL SELECTION AND SETUP The Industrial Source Complex Short Tam model (ISCST3. version 02035) will be used for the EBPPambient impact analyses. The ISCST3 model is a steady-state. multiplo-source. Gaussian dispersion model designed for use with stack emission sources situated in terrain where ground-level elevations can exceed the stack heights of the emission sources. 1. Model Setup The fol1owing regulatmy defiwlt options will be used: Final plume rise Stack tip downwash Buoyancy ;oduced dispersion Calm proceu,jng Missing data routine not used Defiwltwind profile exponents (mral) = 0.07. 0.. 0.10. 0.15.35. 0. . DeWt vertical temperature gradients = 0.02. 0.035 . " Upper Bound" values used for supersquat buildings . No exponential decay for R.ura1 Mode The ISCST3 modeling will employ the final plume rise option, as recommended in the USEP A Modeling Guidelines. Buoyancy-induced dispersion. which accounts for the buoyant growth of a plume. caused bynm~Qf &J;Dbiept. air.. . win. a1!!O .be .iDcluded. in .tbemodeJiPa beta.use. of..the xelatively 'W.I11JLcxiL temperature and subsequent buoyant nature of the exhaust plumes. As recnmmended by the USEP Modeling Guidelines. stack tip downwash will be included. Based on the land use c1assi1ication procedure of Auer (1978). land use in the region SUI'I'OUDding the project site is greater than 50 percent nua1. Therefore. mral dispersion coefficients will be assigned. The calm processing option allows the user to direct the program to exclude hours with persistent cabn . winds in the ca1cuJation of concentratioas for each averaging period. 'Ibis option is generallyrecommendedby the USEP A Modeling Guidelines for regulatory applications. The ISCST3 modelrecogoizes a calm wind condition as a wind speed of 0 meters per second (if ASCn data are input) and a wind direction equal to that of the previous hour. The calm processing option in ISCST3 will then exclude these hours ftom the calculation of CODCentratioas for the various averaging periods. PI83J-EBPP Model PIoIocoI..(9.27.O5).doc IlfIptIet Alurlpu 2. Building Downwash and Good Engineering Practice Building wake effects will be included for both point sources and all structures and buildings at the propoMci facility. The ISCST3 wake eft'Cct inputs will be genemted using the Building Profile Input Program (BPIP). Figure 3-2 shows the source and building locations to be iIu:ludcd in the analysis. BPIP will also be used to analyze Good Engineering Pnlctice (GEP) stack heights (.fig) = H + I.S (L) forthe point sources. The purpose of this will be to demonsarate that the modeled stack beigbls do not exceed GEP limits. Table 5-3 presents the dimensiODS of the buildings and structures associated with the EBPP. Although the combustion twbiDt:s win not have a rectangular structure, the dimensions presented below provide a consenrative approximation for air dispersion modeling. North-south East-West Length Length Height Building/Structure (m)(m)(m) Combustion Turbine cr Stack 18. Administration Bld2 ~aintf!nsmce B1d2 Gas Heater 1.8 Gas Filter Inlet Filter 15. Transformer 19 TABLE 5-3 BUILDING DIMENSIONS 3. Class II Receptor Grid Receptors at 2S-meter interva1s will be placed around the fiIcility's fence line. Outside this fonce line, receptors will be pJaeed aocordingtothe eriteriashewn in Tahle.5-4. .. . .. -. - .. .. TABLE 5-4 AMBIENT RECEPTOR LOCATIONS From Receptor SpacIng (m) Fence Line 0 km 100 0 km 0 km 250 Okm 10.0 km 500 If preliminary modeling shows dift'enmces between concenttations at neighboring m:eptors that are largerthan half the difference between the modeled concentrations and the applicable NAAQS, grids with a so- meter spacing will be placed around those receptors out to a distance of 1 kilometer. The receptor elevation values will be obtained by importing the UTM casting and northing coordinates of the dispersion modeling grid into Microimages' TNT Mips image ~.;~g software. These grid pomwill be overlaid on 30 meter USGS digital elevation models (DEM) to extract the elevation value at each location. Each 30 meter digital elevation model is coincident with (or bas the same extent as) the 8I8OCiated 7.5 minute USGS quadrangle. Pl8J3-EBPP MocI8l ProtocoU9.27.0S)..doc:5-3 iMpact ~11 METEOROLOGICAL DATA 1. Data Selection Five years of sur&cc aDd mixing height data (1986 through 1990) will be used for . the dispersion modeling. The surface data will be obtained from the National Climatic Data Center (NCDC) SAMSON data colDpICt disc for Boise Airport, and concurrent twice daily mixmg height data will be obtamed &om the USEP A SCRAM website for the same monitoring location. 2. Data Processing Surface and mixing height data will be processed by PCRAMMET into an ISCSn meteorological data set. A stability class for each hour of data will be calculated as part of this processing. CT LOAD ANAL Y$IS The CT load analysis will include all normal operating emissions and exhaust data over the expected nmge of operating loads aDd ambient conditions. Appeadh A presents the range of exhaust data that is proposed for this analysis. 1. Criteria Pollutant Impact Analysis The load analysis will evaluate impacts &om all criteria pollutant emissions. For each load and ambient condition, the normal emissions will be combined with startup and shutdown emissions aDd compared to normal emissions without startup or shutdown events. For each operating scenario. the CT emissions will be rqne&ented as source groups that reflect each operating sceaario. Plot files for each source group will be generated for each pollutant aDd averaging period. These plot files will, subsequently. be post-processed to determine the. maYimnm impacts aad~~~~~os. . ....-._.._-----_.._-~-_.. If preliminary modeling for EBPP shows impacts that are greater than the SIL for any criteria pollutant, dispersion modeling will be performed to determine potential cuo:llllative impacts relative to the NAAQS. 2. Toxic Air Pollutant (TAP) Impact Analysis ~'1Se it will be necessary to evaluate impacts for as many as 11 different T API, it is being proposed that TAPs will be evaluated using exhauat parameters for a single operating scenario. To identify which scenario will be selected, the load analysis described above will also be used to identify the operating scenario that would result in the maY11T1"1U CO impacts. The exhaust parameters associated with this operating scenario will be used to model each of the TAP impacts. A single nul with unit emissions (1.0 grams per second (smIsj) for each source will be performed for each meteorologic:al year. Because only a single source will be modeled, scaling the impacts with the ratio of actual emissions .over unit emissions will produce an accurate result P1833-EBPP Model PratocoU9.27 .o5)..doc S-4 llllptlet .41141yW To 'ensure the conservatism of this analysis, the maximum TAP emission rates over all operatingscenarios will be used in the dispersion mcdeling postMprocessing. To demonstrate the accuracy of the po8t1Jl'OCCS8:ins. a sample run usingactual emissions for a specific TAP will also be included. FUEL DEW POINT HEATER CAVITY ANAL VSIS Cavity influences of the cro 1 structure on emissions &om the fuel dew point heater will be evaluated using the SCREEN3 dispersion model. Model inputs will include stack and exhaust data for the dew point heater and dimensions of the crol structure. Because only a single stack will be modeled, an emission rate of 1.0 gmJs will used in the SCREEN3 nm. The resulting impact will then be apportioned by the estimated dew point heater emission rates for each criteria pollutant. The impacts estimated by SCREENJ represent a 1 Mhour averaging period. For other averaging peri.the factors on Table 5-5 from the SCREEN3 Users Guide (USBPA 1995) were used. TABLE 5-5 SCREEN3 AVERAGING PERIOD FACTORS Averaging Period Factor Hour Hour 2+Hour Annual """....- .... ...,......-------------.. ""-""-----" Pl833--EBPP M.ocI8l Praroco1-t9.27.o5).doc APPENDIX A - EXHAUST DATA .f p p e I w l a A &1 u I 1 I & I D t l I / I Ea s t B o i s e P o w e r P l a n t Co m b U i d o n T u r b i n e E x h a u s t P a r a m e t e n En R I I s h U n i t s Am b l e D t Am b i e n t Ev a p o n t l v e Ex h a u s t Ex h a u s t Es t t Es t t Op e r a t i n g Te m p Co o l e r Fl o w Te m p Dl a m He I g h t Co d e Lo a d (O F ) (% ) Oo e r a t l o n (a e f m ) (O F ) (f e e t ) (f e e t ) WO 6 O N I 60 % 10 0 % OF F 10 8 . 91 5 03 2 W0 6 0 N 2 60 % 10 0 % OF F 06 7 . 71 6 04 3 WO 6 O N 3 60 % 60 % OF F 96 2 . 13 4 07 4 WO 6 O N 4 60 % 60 % OF F 93 8 , 2 2 9 08 1 W0 6 0 N 6 60 % 10 0 10 % OF F 81 0 7 0 0 11 7 WO 6 O N 7 60 % 11 0 1 o o A , OF F 78 4 . 16 8 12 7 W0 7 0 N I 70 % .1 0 0 % OF F 2. 3 0 6 . 54 9 03 2 W0 7 O N 2 70 % 10 0 % OF F 25 8 . 2 2 1 04 3 W0 7 0 N 3 70 % 60 % OF F 13 6 . 59 9 07 4 W0 7 0 N 6 70 % 10 0 10 % OF F 1. 9 5 5 . 46 1 11 7 W0 7 0 N 7 70 % 11 0 10 % OF F 92 2 . 77 3 12 7 WO 8 O N 2 80 % 10 0 % OF F 44 8 . 98 5 10 4 3 WO 8 O N 3 8o o A . 60 % OF F 23 1 5 . 65 4 07 4 W0 8 O N 6 80 % 10 0 10 % OF F 10 5 . 42 6 11 7 W0 9 0 N 2 90 % '1 0 0 % OF F 2 6 3 3 ~ 9 6 04 3 W0 9 0 N 3 90 % 60 % OF F 24 8 8 . 48 2 07 4 WO 9 O N 6 90 % 10 0 10 % OF F 22 5 6 . 40 3 1. 1 1 7 Wl 0 0 N I 95 % 10 0 % OF F 79 3 . 89 9 03 2 Wl O O N 2 10 0 % 10 0 % OF F 28 3 6 . 67 0 04 3 Wl O O N 3 10 0 % 60 % OF F 2 6 7 6 . 4 4 5 1. 0 7 4 Wl O O Y 4 10 0 % '6 0 % 85 % 26 7 0 . 57 2 07 7 Wl 0 0 N 5 10 0 % 20 % OF F 2 4 8 5 . 47 0 10 9 Wl O O Y 5 10 0 % ;2 0 % 85 % 60 9 ~ 0 2 09 0 Wl O O N 6 l0 0 0 A . 10 0 10 % OF F 2 4 3 5 . 00 6 11 1 7 Wl O O Y 6 10 0 % 10 0 !1 0 % 85 % 57 1 . 60 5 09 8 Wl 0 0 N 7 10 0 0 1 0 11 0 : I o o A . OF F 2, 3 8 7 . 17 6 11 2 7 1 R e c l 8 n g u l a r S t i c k : = 2 7 f e e t b y 2 2 f e e t = 2 8 f e e t e q u i v a l m i t d i a m e t e r PI 8 3 3 - E B P P M o d e l P 8 G b I c o t ( 9 . 2 7 . 05 ) . d o c -- - a .f p p a d i z A - 1l 1 t A t M u t Da l l i r Ea t B o b e P o w e r P l o t Co m b u s t i o n T u r b i n e Em . u s t P . r a m e t e n Me t r i e U n i t s Am b i e n t Am b i e n t Ev s p o r a t i v e Ex i t Ex i t Ex i t Ex i t Op e r a t i n g Te m p Co o l e r He i g h t Te m p Ve l Di a m e t e r Co d e Lo a d (O F ) i ( % ) Oo e r a t i o n (m e t e r ) (K ) (m I s ) (i n e t e r ) WO 6 O N I 60 % 10 0 % OF F 18 . 82 8 . 18 . 8. 3 8 2 WO 6 O N 2 60 % :1 0 0 % OF F 18 . 83 4 . 17 . 38 2 WO 6 O N 3 60 % . & ) G A l OF F 18 . 2 9 85 1 . 6 16 . 38 2 WO 6 O N 4 60 % 60 % OF F 18 . 85 5 . 16 . 38 2 W0 6 0 N 6 60 % 10 0 .1 0 % OF F 18 . 87 5 . 15 . 8. 3 8 2 WO 6 O N 7 60 % 11 0 \1 0 % OF F 18 . 2 9 88 1 . 4 15 . 38 2 W0 7 0 N I 70 % 11 0 0 % OF F 18 . 82 8 . 19 . 38 2 W0 7 O N 2 70 % 10 0 % OF F 18 . 83 4 . 19 . 38 2 W0 7 0 N 3 7o - A I 60 % OF F 18 . 85 1 . 18 . 38 2 WO 7 0 N 6 70 % 10 0 10 % OF F 18 . 87 5 . 16 . 8. 3 8 2 W0 7 O N 7 70 % 11 0 :1 0 % OF F 18 . 88 1 . 4 16 . 8. 3 8 2 WO 8 0 N 2 8o - A i 10 0 % OF F 18 . 2 9 83 4 . 20 . 38 2 WO S O N 3 80 0 " ' :6 0 % OF F 18 . 2 9 85 1 . 6 19 . 38 2 WO S O N 6 80 % 10 0 :1 0 % OF F 18 . 87 5 . 18 . 8. 3 8 2 WO 9 O N 2 90 % 11 0 0 % OF F 18 . 83 4 . 22 . 38 2 W0 9 0 N 3 9o - A i '6 0 % OF F 18 . 2 9 85 1 . 6 21 . 8. 3 8 2 W0 9 0 N 6 90 % 10 0 10 % OF F 18 . 2 9 87 5 . 19 . 8. 3 8 2 WI O O N I 95 % :1 0 0 % OF F 18 . 82 8 . 23 . 8. 3 8 2 Wl O O N 2 10 0 % !1 0 0 % OF F 18 . 2 9 83 4 . 24 . 2 6 8. 3 8 2 Wl 0 0 N 3 10 0 % j 6 ( ) D A i OF F 18 . 2 9 85 1 . 22 . 8. 3 8 2 Wl O O Y 4 10 0 % :6 0 % 18 . 85 3 . 22 . 8. 3 8 2 Wl O O N S 10 0 % 20 % OF F 18 . 87 1 . 21 . 8. 3 8 2 Wl O O Y S 10 0 % 20 % 18 . 86 0 . 22 . &. 3 8 2 Wl O O N 6 10 0 % 10 0 10 % OF F 18 . 87 5 . 20 . 8 2 38 2 Wl O O Y 6 10 0 % 10 0 . i l O % 18 . 86 5 . 21 . 8. 3 8 2 Wl O O N 7 10 0 % 11 0 !1 0 % OF F 18 . 88 1 . 20 . 8. 3 8 2 P I s n . ER P p M o d e l P r o I D c o U 9 . 2 7 . 0 5 ) . d o c .. . . . a ~ IECm!DWlEfO) JAN 0 ~ 2006 PLANNING & DEVELOPMENT SERVICES Summary and Evaluation of Air Quality Impacts Associated with The Mountain View Power, Inc. Gateway Power Plant Provided by the Idaho Department of Environmental Quality Executive Summary The following are important considerations/findings from air quality analyses conducted for operation of the Gateway Power Plant (GPP) proposed for southeast Boise: Air quality impact analyses were conducted only for. operations of Plant 1 (the larger turbine). Impacts from Plant 2 (the smaller plant) were not assessed. Impacts of directly-emitted criteria pollutants, including fine particulate (PM1o and PM2.s). nitrogen dioxide (N02), sulfur dioxide (502), and carbon monoxide (CO) are well below applicable federal standards when combined with monitored background concentrations. DEQ conducted an analysis for both primary (filterable and condensable) and secondary (fonned through atmospheric chemistry) fine particulate. Impacts were well below applicable federal standards when combined with monitored background concentrations. An accurate impact analysis for ozone, resulting from atmospheric chemical reactions involving emissions of oxides of nitrogen (NOx) and volatile organic compounds (VOCs), was not conducted. Appropriate ozone models for the Treasure Valley, with site-specific data, are not yet available. DEQ staff calculated an upper bound ozone impact from very conservative screening tables, using maximum daily NOx and VOC emissions rates. These tables indicated a maximum 1-hour impact of about 18 ppb to 23 ppb. Impacts for an 8-hour averaging period, for comparison to the federal 8-hour ozone standard of 80 ppb, would be substantially less. Mountain View Power claimed the plume from the plant would break up winter inversions in the area around the plant. While this may be an accurate statement for lower-level relatively weak inversions, there is no evidence that this may be the case for stronger deep layer inversions that may be several thousand feet deep. DEQ did not evaluate whether the low NOx burners constitute Best Available Control Technology (BACT) for the GPP, with estimated NOx effluent concentrations at 10 ppm; however, DEQ research revealed BACT determinations in California for simple cycle gas turbines at 5 ppm NOx. Introduction Mountain View Power Inc. (MVP) proposes to construct and operate the Gateway Power Plant (GPP), located in southeast Boise, Idaho. This report summarizes estimated air quality impacts that may result from operation of the power plant. Project Description The GPP will generate electricity using a simple cycle combustion turbine fired on natural gas. The proposed turbine is a Siemens.Westinghouse 501F, with a rating of 180 MW at 59OF and greater than 200 MW at .20oF. MVP has indicated the plant will operate as a .Peaking Plant,. operating periodically to provide electricity during periods of high demand. MVP also indicated a smaller power plant (Plant 2), between 25 and 100 MW. is planned for the site. This plant would service other facilities in the immediate area. Typical Scope of DEQ Air Quality Analyses for New Facilities DEQ normally only conducts or reviews an air quality assessment for a proposed new industrial facility when that facility applies for an air quality permit to construct (PTC). A permit is issued, in accordance with Idaho state regulations, if the analysis demonstrates the air pollutant emissions will not cause or significantly contribute to a violation of a federal air quality standard. Within this process. DEQ does not have authority to consider whether the facility is located in an appropriate location with regard to nearby housing, schools, etc. DEQ also evaluates, during the permitting process, the accuracy of methods used to estimate emissions and the effectiveness of any proposed emissions control measures. The type of controls used and the level of emissions control are not prescribed by DEa, beyond what is needed to meet specific requirements within the rules (New Source Perfonnance Standards and other specific requirements as established in state and federal law). DEQ cannot impose a level of emissions control beyond that needed to meet federal air quality standards. DEQ-issued permits establish emissions limits, operational conditions and restrictions, monitoring requirements, and reporting requirements. The permit serves to assure DEQ that the facility is operating as was proposed in their application. DEQ Review of Air Quality Analyses for the Gateway Power Plant Boise Planning and Zoning Commission (Planning and Zoning) requested MVP to submit air quality impact analyses to be used for evaluating the conditional use permit application. Planning and Zoning then requested DEQ to review the analyses submitted by MVP and provide comments back to the Commission. The scope of this review is outside of the established DEQ air permitting process. The evaluation and comments provided are from a technical perspective only. Comments will focus on the assessment of air quality impacts rather than providing recommendations on specific terms of the land use permit that can be issued by Planning and Zoning. DEQ has no authority to request provisions in the land use permit. General Description of Submitted Analyses To assess potential air quality impacts resulting from operation of the GPP, MVP's consultant, Greystone Environmental Consultants, Inc. (Greystone), used the readily available atmospheric dispersion modeIISCST3. This model is typically used for air quality permitting of industrial facilities. The atmospheric dispersion model utilizes actual hourly meteorological data collected at the Boise Airport. Attachment A provides a report submitted by Greystone on the air quality impacts. Attachment B provides a protocol for modeling analyses proposed by Greystone for the DEO minor source Permit to Construct (PTC). The protocol was submitted prior to MVP' proposed ctiange to lower NOx emitting technology (10 ppm NOx), and it does not address the10 ppm NOx reduction. Pollutants Assessed The analyses submitted assessed direct impacts of emissions from the following pollutants: Particulate with an aerodynamic diameter of less that 10 micrometers (PM,o) Oxides of nitrogen (NOx) Sulfur dioxide (S02) Carbon monoxide (CO) Current EPA dispersion modeling guidance for industrial facilities does not address fine particulate (PM2.s). Secondary formation of PM2.s from emissions of NOx and S02 are not accounted for in readily available dispersion models for near-source impacts. Current EPA guidance states that, until specific regulations and procedures for PM2.s are developed, analyses demonstrating compliance with PM,o will be used as a surrogate for PM2.s. This method may not be appropriate for a power plant in the Treasure Valley for the following reasons: Existing concentrations of PM2.5 are much closer to the PM2.5 standard (65 ~gIm3 for a 24- hour averaging period) than concentrations of PM1o are to the PM1o standard (150 ~glm for a 24-hour averaging period). . A very large portion of primary PM,o emissions from natural gas combustion (emitted directly to the atmosphere) are composed of PM2.5. Large emissions of NOx from the power plant, compared to emissions of PM1o. suggest that secondary PM2.5 formation could be an important mechanism. DEO directed Greystone to address primary PM2.5 in their analyses. This was done by conservatively assuming that all PM,o was PM2.5. A screening-level assessment of total PM2. impacts, including secondary formation from emissions of NOx and S02, was conducted by DEO staff using a more complex model that accounts for atmospheric aerosol chemistry. Accurately estimating contributions of the GPP emissions to summer ozone levels is very difficult. Very complex airshed models, utilizing a comprehensive site-specific emissions inventory of volatile organic compounds (VOCs), oxides of nitrogen (NOx), and other photochemically active compounds, are used to simulate the atmospheric chemistry and estimate location-specific ozone concentrations. An airshed model to estimate ozone impacts in the Treasure Valley is not yet available. DEO staff used a simplistic ozone screening technique developed by Richard D. Scheffe (VOC/NOx Point Source Screening Tables. By Richard D. Scheffe. September 1988. USEPA. Office of Air Quality Planning and Standards. Technical Support Division. Source Receptor Analysis Branch. Operational Conditions Assessed The air quality analyses submitted by MVP only assessed impacts from the main GPP; impacts from Plant 2 were not assessed. Without knowing the size, operational characteristics, and exact location of Plant 2, DEQ could not estimate combined impacts of both plants. All analyses discussed in this report refer only to impacts associated with the main GPP. Gre)'S.tone assessed impacts from emissions associated with a wide range of operational scenarios of the GPP. These scenarios involved differing loads under differing atmospheric conditions. Other Claimed Effects/Impacts from the Plant MVP has made several statements, at public meetings and within materials provided at such meetings, regarding operations and effects the plant will have on air quality in the Treasure Valley. These statements are as follows: There are two Gateway power plants proposed to be located on 25 acres in the Gateway Industrial Park which is being developed by the City to encourage and consolidate industrial uses in the area. Dominant wind patterns are from the West and away from Boise population centers. Most plant emissions will move southeast, into the desert" Both power plants will use Best Available Control Technology (BACT) to control NOx emissions. The proposed technology will control NOx emissions to an effluent concentration of 10 ppm. If the power plant operates during a winter inversion. the plume from the plants will work to "break up. the inversion in the vicinity of the plant because the high volume of hot gases will "pierce through the layer of cold air that traps pollution in the valley." This summary report will provide comments on the above statements. Emissions Quantification and Assessment Operational Level MVP has estimated the plant will run less than 1 000 houl'&per year. The atmospheric dispersion modeling conducted was based on a maximum annual average NOx emissions rate of 80 Iblhr for continuous operation. To remain below emissions levels that would trigger the Prevention of Significant Deterioration (PSD) permitting program (250 tonslyr), the GPP could still operate for a minimum of 6,250 hours per year. Level of Emissions Control DEQ cannot impose a specific level of emissions control beyond what is required by an established emissions standard or what may be needed to comply with air quality standard. However, if a facility proposes to use a specific technology to attain a claimed level of emissions control, DEQ will incorporate appropriate operating, monitoring, and reporting requirements into the air quality construction permit to assure compliance with the claimed equipment performance. MVP indicated the GPP will utilize ultra dry low NOx combustors, which represent "state of the art" NOx control for simple cycle natural gas turbines. MVP stated these combustors achieve a NOx concentration in the effluent of 10 ppm dry volume basis corrected to 15 percent oxygen at loads above 70 percent. Levels at loads between 60 and 70 percent were estimated at 12.5 ppm. Incorporating MVP's agreement to use the low NOx technology into the conditional use permit could be accomplished by several different methods. The following are two methods DEQ would suggest 1. The conditional use permit could specifically state the low NOx combustor technology is required, and specify attaining the 10 ppm effluent concentration and the 92 IbJhr emissions rate. 2. The conditional use permit could require Mountain View to secure an air quality Permit to Construct (PTC) from DEQ that is consistent with the design information and emissions rates provided in the Gateway Power Plant Air Quality Modeling Analysis, prepared by Greystone Environmental Consultants, Inc. and submitted in December 2005, forMountain VieW Power. Emissions Factors Emissions testing data obtained from Siemens was used to calculate emissions for the GPP. Greystone conducted a detailed and conservative assessment of emissions quantities, using numerous operational scenarios to account for different ambient air temperatures and different load levels. The emissions also accounted for emissions during start-up and shut-down periods. with 24-hour emissions accounting for 10 start-up and shut-down cycles. Emissions calculation spreadsheets used by Greystone were reviewed by DEQ engineers, although time did not allow for a comprehensive review. The methodology, calculations, and obtained values appear reasonable and correct. Mr. Gordon Frisbie of Greystone indicated that emissions estimates of S~ may change slightly with refined design. Such a change will not likely change the conclusions of this report, since impacts of S02 are well below levels of concern and may essentially be considered as negligible. .., Primary Air Quality Impacts Primary air quality impacts are those resulting from pollutants emitted directly into the atmosphere, rather than pollutants formed through atmospheric chemistry. Greystone used readily available and EPA-approved dispersion models to assess maximum potential impacts. The submitted report in Attachment A provides a good description of the methods and results. Impacts of all directly emitted air pollutants (N02, CO, 5021 PM1o, and PM2.s) were well below applicable air quality standards, even when combined with background concentrations based on air monitoring data collected in the Boise area. The impact levels of CO, PM1o and 502 are sufficiently low to be allowed in non-attainment areas, which are areas not meeting federal air quality standards for those pollutants. The Treasure Valley is considered to be in attainment of the federal standards for all regulated air pollutants. Table 1 provides a summary of maximum primary impacts. Greystone conservatively assumed that PM2.s impacts are equal to PM1o impacts. Actual PM2.s impacts will be somewhat less than PM1o, although the PM2.5 contribution to PM1o emissions for combustion sources is relatively high (likely to be above 80 percent). Maximum direct PM2. impacts from the GPP were estimated at 2.~glm for the 24-hour averaging period and 0. IJg/m for the annual averaging period. These are maximum concentrations based on the location where the maximum 24-hour concentration is the highest - i.e. the maximum of Iocation- specific maximum 24-hour concentrations. Impacts for the Boise area are nearly all below 0. IJglm3 for the 24-hour averaging period. Existing background PM2.5 concentrations are substantially lower than PM1o concentrations. The th percentile PM2.5 24-hour averaged concentration in the Boise area ranged from 17 ~g/m 51 ~m3 during year 2000 through 2004, and values in Garden City ranged from 22 ~g/m3 to 63 IJ9/m . The current PM2.5 air quality standard is 65 IJg/m , based on the three-year average of the9~ percentile monitored value. On December 20, 2005, EPA proposed a revision to the PM2.5 standard. The new standard would be 35 ~g/m based on the three-year average of the 98 percentile monitored value. It is not certain what the promulgated standard will be upon completion of public comment and issuance of the final rule. Table 1. Modeled Impacts of Directly Emitted Pollutants Maximum Averaging Impact Background Impact +Standard Pollutant Period from ~~.Level Background (pglm') lua/m 8 Iga/m lualm3 PM1O 24-hour 86.150 Annual 27. PM2.24-hour 51Q 53. Annual 10. 5ulfur dioxide (502)hour 45.300 24-hour 26.365 Annual 78. Carbon monoxide (CO)hour 1228 10,200 11428 40,000 hour 201 3.400 3601 10 000 NitrOQen dioxide (NO,)annual 36.100 Micrograms per cubic meter Particulate matter with an aerodynamic particle diameter less than or equal to a nominal 10 micrometers Co.Particulate matter with an aerodynamic particle diameter less than or equal to a nominal 5 micrometers Based on the maximum 98th percentile value from each of five annual data sets. Secondary Pollutant Formation Emissions of NOx, S~, and VOCs can react with other chemicals in the atmosphere to produce fine aerosol particulate and ozone. Secondary PM2. NOx and S02 emitted from a source can react in the atmosphere to form fine particulates, mainly ammonium nitrate NH4NQ, and ammonium sulfate (NH4hS04. The actual conversion rates are complex, heavily affected by temperature, humidity, sunlight, and the concentration of other compounds in the atmosphere, such as ammonia (NH3). Dispersion models typically used for minor source air permitting, which is applicable to facilities with annual allowable emissions less than 250 tons per year, do not address the formation of secondary particulate. DEQ staff assessed the formation of secondary particulate by using the CALPUFF model. CALPUFF is a more complex dispersion model that is primarily used to assess visibility impacts on Class I areas (national parks, national monuments, and other identified pristine areas) from major sources (allowable emissions over 250 tons per year). The model has algorithms that estimate the formation and dispersion of secondary particulates. CALPUFF is also capable of estimating impacts during calm conditions, unlike the dispersion models that are typically used for assessing near-field impacts, also known as "fencelineD impacts, from industrial facilities. The model was used in a screening mode, using the same meteorological data as were used for the primary impact analyses. The maximum 2"d high PM2.sconcentration, resulting from both primary emitted PMuand secondary PM2.s formed through atmospheric chemistry, was modeled at 0.7jJglm3 for a 24-hour averaping period. At most locations throughout the Boise area concentrations were below 0. jJg/m. The maximum 2'111 h~h value was plotted because compliance with the standard is based on the 3 year average of 98 percentile 24-hour concentrations. The maximum 181 high 24-hour PM2.5 modeled result was 5.6 lJg/m3 and most receptors in the Boise area were well below 1 jJg/m . Figure 1 provides a contour plot of maximum modeled PM2.s concentrations. Ozone The ozone impact screening method, involving the use of VOCINOx tables developed by Richard D. Scheffe, is a very conservative screening analysis. Maximum daily NOx and non-methane VOC emissions, projected to annual emissions rates, and the VOC/NOx ratio, are used to calculate maximum 1-hour ozone impacts from impact tables for either rural or urban areas. The impact tables were generated from conservative models utilizing atmospheric chemistry algorithms. This method tends to substantially over estimate ozone impacts, especially since the 80 ppb ozone federal standard is pased on an a-hour averaging period and the tables provide maximum 1-hour impact values. If results from this screening-level analysis are considered unacceptable, then more refined location-specific airshed modeling should be performed to moreaccurately assess impacts. Maximum daily emissions rates of 9.6 gIsec NOx and 11.g/sec VOC for the GPP were obtained from the analyses performed by Greystone, using only emissions associated with ambient temperatures over 500 F. Emissions during cooler periods were not considered because ozone is primarily a concern in the Treasure Valley during summer conditions. Projecting these to annual rates (using a continuous operation rate) results in NOx emissions of 334 tonslyr and VOC emissions of 388 tonslyr, and the VOC/NOx ratio was calculated at 1.2. The VOC emissions do not include methane or ethane, which are both much less reactive than other VOCs and do not measurably contribute to ozone formation. Table 2 provides ozone impacts as calculated from the tables in the Scheffe paper. This ozone impact analysis is very conservative because of the following: .., Concentration values in the tables are for maximum 1-hour averaged impacts. Maximum impacts for an a-hour averaging period are likely to be substantially less because of plume meander, variability in emissions, and periods of decreased solar radiation intensity (chemical reactions forming ozone are heavily dependent on the intensity of solar radiation). Values in the impact tables represent maximum impacts for any location under worst- case conditions such as very low winds, intense solar radiation, and highly reactive vac emissions from facilities. Although the Treasure Valley has low winds during strong high- pressure systems in summer, typical afternoon wind flows partially ventilate the valley and effectively lower monitored ozone levels. Also, solar radiation intensity, the key driving force for ozone formation, is less at northerly latitudes than in southern latitudes. Finally, much of the VOCs emitted in the exhaust from natural gas combustion are less photoreactive than vacs emitted from other combustion sources or evaporative sources. The maximum daily emissions were estimated by assuming a series of 10 start-up and shut-down cycles occur during a 24-hour period. Emissions are substantially greater during such start-up and shut-down periods, and it is extremely unlikely that such a high number of start-up and shut-down cycles will actually occur during a day. Table 2. Maximum Ozone 1m acts Predicted b usin Scheffe Tables a.HourHou,. Deelgn Impact Value23 18 ears 2003, 2004, 2005 Method Used Discussion on Stated Operational Conditions and Other Effects of the Plant Two Plants Proposed MVP has indicated in public meetings and in materials provided that two power plants are proposed. The conditional land use permit application also discusses both plants. However. the air quality analyses submitted only assessed impacts from the main, larger power plant referred to as Plant 1. DEQ staff consulted with Greystone regarding the exclusion of Plant 2 from the air quality analyses. Mr. Gordon Frisbie of Greystone indicated that MVP stated the plant was not confirmed as a reality" at this point. No design data or information were available for Plant The air quality impact analyses only address Plant 1. Without additional information or data, DEQ staff cannot comment on the potential impacts of Plant 2 or the combined impacts of Plant 1 and Plant 2. Dominant Wind Patterns are from the West As stated by MVP, winds in the Boise area are predominantly from the northwest and southeast. Below is a wind rose showing the directions from which winds are blowing. Although the predominant winds may carry the plume away from the larger population centers, calm conditions during either winter inversions or summer stagnation periods could result in the plume transported in any direction. WIND SPEED (Knlltw) -22 . 17- 11-17 . 7.III .. - 7.1. Cllmw: 7.81" The GPP will utilize BACT for NOx Control MVP indicated the GPP will utilize ultra dry low NOx combustors, as stated in Section 3. Materials given during public meetings also claimed that use of this control represented BestAvailable Control Technology (BACT). A BACT analysis was not submitted with the air impact analyses. DEQ did not have resources to verify whether the proposed technology represents BACT. Minimal research by DEQ revealed that NOx BACT for simple cycle gas turbine projects has historically varied from 2.5 ppm to 25 ppm. California has effectively "suggested" BACT as 5 ppm, which is attained by using dry low NOx burners with selective catalytic reduction (SCR). Outside of California, it appears that most BACT determinations were at about 9 ppm NOx. BACT is not required for the GPP to obtain an air quality Permit to 9onstruct (PTC) from DEQ, nor is a 10 ppm NOx effluent concentration or the r~uJting 92 Iblhr NOx emission rate. Plume will Pierce Through WInter Inversion Layer The statement made by MVP indicating the hot plume would pierce through winter inversions was based on information provided by Greystone. Mr. Gordon Frisbie of Greystone stated the claim was supported by a 1959 research paper in Journal of Meteorology (G. Spurr. The Penetration of Atmospheric Inversions by Hot Plumes. Journal of Meteorology. Volume 16, February 1959). DEQ staff members have not had an opportunity to fully evaluate the paper and its relevance to deep winter season inversions experienced within the Treasure Valley. This issue is irrelevant to conditions during the summer ozone season. DEQ staff used plume rise equations that are present within AERMOD, the recently promulgated EPA-approved dispersion model for evaluating near-field impacts from industrial sources. At an air temperature of 200 F and inversion conditions (20 C per 1000 meters), a plume rise of between 500 meters and 600 meters (1640 feet and 1969 feet) was calculated for the GPP. This causes a high degree of thermal turbulence in the immediate area and the plume may break out of inversion layers that are less than 500 meters thick; However, strong winter inversions within the Treasure Valley can periodically be 500 to 1 000 meters thick. DEQ staff members are not confident that the plume from the GPP will have sufficient plume rise to break through such a deep stable layer associated with the strongest Treasure Valley inversions. .., Figure 1 .. Primary and Secondary PM2. Contours of 2nd High Modeled Concentrations at Each Receptor 4845 4840 4835 4830 4825 4820 4815 4810 4805 4800 545 Micrograms of PM2.5 per Cubic Meter of Air 550 555 560 565 570 ki lometers 580 585575 Attachment 1 PE R M I T S / A P P R C I V A L S RE Q U I R E D F O R T H E BO I S E C I T Y PO W E R PL A ~ . . 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POUVER O. BOX 70~ BOISE, ID 83707An IDACORP Company (208) 388-2506 (208) 388-6689 (FAX) F. Gregory Hall Principal Engineer, Power Production January 6, 2006 Robert D. Looper President Mountain View Power Company 1015 West Hays Street Boise, ID 83702 Re: Idaho Power 2005 Peaking Resource RFP Dear Mr. Looper: Thank you for your interest and participation in the Idaho Power 2005 Peaking Resource RFP. I regret to inform you that Idaho Power Company has decided not to conduct any additional review of your proposal. Idaho Power Company is in the process of negotiating a contract with Siemens Westinghouse for a 501FD3 turnkey project at the Evander Andrews Power Complex. A press release will be issued on Monday, January 9, 2006 and we very much appreciate that this selection remains confidential until then. Should you have any questions with respect to this selection, please contact me in writing and we will respond following the completion of the contract with our chosen supplier. Again, thank you for your interest in this project. Sincerely, Page 1 of 1 Ronald Williams From: Robert Looper Sent: Tuesday, June 27, 2006 6:06 PM To: Ronald Williams Subject: FW: RFP Q&A From: Robert Looper (mailto:rlooper(Q)spellc.comJ Sent: Wednesday, October OS, 2005 5:01 To: Hall, Greg Cc: 'Thomas Cameron (E-mail)'; Ronald Williams Subject: RFP Q&A Greg, We are working on the Q&A responses but are not likely to completed by tomorrow. We can send most of the responses by end of day Friday, October 7 2005. There will still be outstanding pricing and possibly schedule issues which will take longer and are dependent upon responses from GE and Siemens. These would likely be available for the presentation on the 18th Let me know how you would like us to proceed. Thanks Bob Robert Looper 1015 W. Hays Boise , 10 83702 208-331-1898 (Office Phone) 208-343-1218 (Fax) 208-870-5371 (cell) rlooper~spellc.com 6/2812006 Ronald Williams From: Sent: To: Subject: Robert Looper (rlooper~spellc.com) Tuesday, June 27, 2006 6:04 PM Ronald Williams FW: 2005 Peaking Resource RFP Attachments:RFP Schedule.doc RFP Schedule.doc (68 KB) Robert Looper 1015 W. Hays Boise , ID 83702 208-331-1898 (Office 208-343-1218 (Fax) 208-870-5371 (cell) rlooper~spellc. com Phone) - - - - - Original Message- - - -- From: Hall Greg (mailto:FGregHall~idahopower.comJ Sent: Wednesday, November 30, 2005 11:53 AMTo: I Thomas Cameron (E-mail) (E-mail) Ronald WilliamsCc: I Bob Looper (E-mail) (E-mail) Subject: FW: 2005 Peaking Resource RFP (E-mail) FYI.I sent this to Bob and thought I would copy you too. ~ ----- Original Message----- From: Hall, Greg~ Sent: Tuesday, November 29 , 2005~ To: I Bob Looper (E-mail) I (E-mail)~ Subject: 2005 Peaking Resource RFP 4: 52 ~ Bob:this letter is going out to you today. Thanks. ~ ~ ~~RFP Schedule. doc~~ This transmission may contain information that is privileged, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of the information contained herein (including any reliance thereon) is STRICTLY PROHIBITED. If you received this transmission in error, please immediately contact the sender and destroy the material in its entirety, whether in electronic or hard copy format. Thank you. A1. PQWE DAHO IDAHO POWER COMPANY O. BOX 70 An IDACORP Company BOISE, ID 83707 (208) 388-2506 (208) 388-6689 (FAX)F. Gregory Hall Principal Engineer, Power Production Robert D. Looper President Mountain View Power Company 1015 West Hays Street Boise, ID 83702 September 27, 2005 Re: Idaho Power 2005 Peaking Resource RFP Dear Mr. Looper: On behalf of Idaho Power Company, thank you for submitting a response to the Company s 2005 Peaking Resource RFP, We were pleased to receive your proposal and are continuing to evaluate your offer. To complete our evaluation of your proposal, Idaho Power requests that you provide the additional infonnation summarized in Attachment A to this correspondence. That Attachment summarizes the details that we need in order to further our evaluation. Please note that the table is organized in a manner that correlates with the RFP. Carefully review the attached infonnation request and take care to provide a complete answer as part of your responses. Please provide this information in writing by October 6, 2005. Also, the Company would like to schedule a presentation of your proposal by your team. Please call me at your earliest convenience to determine when, during the week of October 10-14, it would be convenient for your representatives to make their presentation to the Company. Weare allowing one day for your presentation. Please review Attachment B to guide the preparation of your presentation. Finally, please consider that we are anticipating signing a contract with a successful bidder by December 1 , 2005 with a Notice to Proceed given by March 15 , 2006. Our current projection is to receive Provisional Acceptance by June 1, 2007. However, we may consider a schedule with a Provisional Acceptance by October 1 , 2007. At the time of your presentation, please provide two schedules and any updated pricing that may result in the event the original schedule is modified. - 1 - Should you have any questions with respect to this clarification process or the intent of any of the questions, please contact me in writing and we will be happy to provide any clarifications that we can. Again, thank you for your interest in this project and we look forward to receiving your responses. Sincerely, ~,~ #td F. Gr~g ~all - 2 - Robert Looper letter. pdt (29 K... Robert Looper lO15 W. HaysBoise, ID 83702 208-331-1898 (Office 208-343-l218 (Fax) 208-870-5371 (cell) rlooper~spellc. com Phone) --- Original Message----- From: Hall, Greg (mailto:FGregHall~idahopower.com) Sent: Friday, January 06, 2006 l2:23 PM To: I Bob Looper (E-mail) (E-mail) I Thomas Cameron (E-mail) Subject: 2005 Peaking Resource RFP (E-mail)(E-mail) Ronald Williams Gentleman:this letter is being mailed to you today. ~~Robert Looper letter .pdf~~ (INFO) -- Access Manager: This transmission may contain information that is privileged, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY PROHIBITED. If you received this transmission in error, please immediately contact the sender and destroy the material its entirety I whether in electronic or hard copy format. Thank you. ::~ PQWE DAHO IDAHO POWER COMPANY~ P.o. BOX 70 BOISE, ID 83707An IDACORP Company (208) 388-2506 (208) 388-6689 (FAX) F. Gregory Hall Principal Engineer, Power Production November 29 2005 Robert D. Looper President Mountain View Power Company 1015 West Hays Street Boise, ill 83702 Re: Idaho Power 2005 Peaking Resource RFP Dear Mr. Looper: As mentioned at your Company s presentation last month, Idaho Power Company is evaluating the impact of a proposed PURP A project that may affect the size and schedule of the Idaho Power s 2005 Peaking Resource RFP. At this time, the Company has not made a determination of the impact that this proposed PURPA project would have on the RFP. Depending on the outcome of the PURP A project, we may still consider your current proposal pricing and a scheduled Provisional Acceptance Date of June 1 , 2007. I However, weJequest that you provide additional pricing for your proposals based on a schedule of signing a contract in March 2006 with a notice to proceed by June 1 , 2006 and Provisional Acceptance by April 1 , 2008. Please provide this information by Dec. 2005. On behalf of Idaho Power Company, thank you for the time and patience as we continue to evaluate your offer. Should you have any questions with respect to this request, please contact me in writing. Sincerely, F. Gregory Hall - 1 - --- From: Robert Looper (mailto:rlooper(Q)spellc,com) Sent: Monday, October 10, 2005 10:42 AM To: Hall, Greg Subject: East Boise Site Conditional Use permit Application & Air Modeling Protocol For your information Robert Looper 1015 W. Hays Boise. ID 83702 208-331-1898 (Office Phone) 208-343-1218 (Fax) 208-870-5371 (cell) rlooper~spellc.com 6/28/2006 PROTOCOL EAST BOISE POWER PLANT AIR POLLUTANT DISPERSION MODELING PROTOCOL FOR A SYNTHETIC MINOR SOURCE Submitted to: Idaho Department of Environmental Quality Boise, ID Submitted for: Mountain View Power, Inc. Boise, ID Prepared by: Greystone Environmental Consultants, Inc. Denver, CO September 2005 INTRODUCTION ........................................................................................................................ PROJECT LOCATION ................................................................................................................ SOURCE DESCRIPTIONS.......................................................................................................... Combustion Turbine ........................................................................................................ Fuel Dew Point Heater..................................................................................................... 3- PROJECT EMISSIONS AND SOURCE DATA .........................................................................4- Emission Controls ............................................................................................................ CT Startup Emissions ...................................................................................................... IMPACT ANAL YSIS................................................................................................................... Ambient Air Quality Standards ............ .............. .......................... ................................... Background Pollutant Concentrations ............................................................................. Local Terrain....................................................................................................................Model Selection and Setup - .............................................................................................. 1. Model Setup........................................................................................................ 5.4.2. Building Downwash and Good Engineering Practice ........................................3. Class II Receptor Grid........................................................................................ Meteorological Data ........................................................................................................ 1. Data Selection..................................................................................................... 2. Data Processing .................................................................................................. CT Load Analysis ....................................................... ..................................................... 1. Criteria Pollutant Impact Analysis .....................................................................2. Toxic Air Pollutant (TAP) Impact Analysis....................................................... Fuel Dew Point Heater Cavity Analysis .......................................................................... 1.0 TABLES TABLE OF CONTENTS Table 4- Table 4- Table 5- Table 5- Table 5- Table 5- Table 5- FIGURES Range of Ambient and Operating Parameters..................................................................4- EBPP Emission Rates ............. ........................ ....... ........................ ............ ................. ..... Summary of Regulatory Ambient Air Concentrations .................................................... Default Criteria Pollutant Concentrations........................................................................ Building Dimensions ....................................................................................................... Ambient Receptor Locations ........................................................................................... SCREEN3 Averaging Period Factors .............................................................................. Site Layout.......................................................................................................................Figure 3- PI833-EBPP Model ProtocoU9.27.05) INTRODUCTION Mountain View Power, Inc. proposes to construct and operate the East Boise Power Plant (EBPP). EBPP will generate electricity using clean burning combustion turbine (CT) technology. The CT will be a Siemens-Westinghouse 50 IF (SW 501F) with a nominal rating of 170 MW. The CT will operate in simple cycle mode and will be fired on natural gas. The power plant will comply with federally enforceable restrictions to limit emissions of criteria pollutants to less than 250 tons per year (ton/yr) as a synthetic minor source. This document outlines the air quality dispersion modeling protocol for the air quality analysis that will be conducted for the air quality Permit to Construct (pTC) application for EBPP. P1833-EBPP Model ProtocoU9.27.05) PROJECT LOCATION EBPP is located approximately 0.7 miles west of Interstate 84 at the South Eisenman Road exit (Figure 1). This location is designated as a Class II airshed under federal and state air quality regulations. The air quality at this location is in attainment for all federal and state Class II air quality standards. The nearest federal Class I airsheds to the project site would include: The Sawtooth Wilderness (95 Ian) Craters of the Moon National Monument (204 Ian) P1833-EBPP Model ProtocoU9.27.05) " 0 (f) NORTH 500 500 1000 Feet COUNTY IDAHOREA- ADA ANALYSIS A P1833 SITE.dwgFile:Date: 04/28/05 LayoutFIG2- Drawn By: JLJ SOURCE DESCRIPTIONS There will be two emission sources included in the dispersion modeling analysis: The combustion turbine (CTOl) Fuel Dew Point Heater Figure 3-1 presents the layout of the emission points and sources relative to the property boundaries. COMBUSTION TURBINE CTOI will be a nominal 170 MW simple cycle combustion turbine, and will primarily be used to generate electric power to meet peak system load requirements. The SW 50 IF combustion turbine is capable of rapid start-up thus permitting the plant to quickly respond to system demand. The CT will be a single-shaft machine of single casing design. The compressor and turbine have a common rotor supported by two bearings: one located at the inlet side of the compressor and the second located at the exhaust side of the turbine. The rotor is an assembly of discs, each carrying one row of blades, and hollow shaft section, all held together by a pre-stressed central through bolt. The turbine rotor is intemally air-cooled. An air inlet system provides filtered air to the CT compressor. The system will be equipped with multi- stage, static filters. Following the compressor, a ring combustor is connected to the common outer casing of the turbine. Natural gas is injected into the combustion chamber and ignited. The hot combustion gases expand through the turbine section of the CT, causing the main shaft to rotate and drive the electric generators and CT compressors. A uniform exhaust gas temperature field is distributed over the full cross sectional area of the diffuser that directs the combustion gases to the turbine blades. FUEL DEW POINT HEATER A 2.0 MMBTU/hr fuel dew point heater will also be added at the EBPP site. The dew point heater will treat incoming fuel to optimize CT performance. This heater will be fired with natural gas. PI833-EBPP Model ProtocoU9.27.05) LEGEND~stion T""'ioo Eod~"" 2 Oo",..OOoT"""oolol"FUt" 3 Exh,"" S..ok 4 Ro""",Co,"",(F.FooT,,,.) 5 Ge",",I~","""B"sk" 6 A","is" T"osfonn" 7 M.o Sot Up T""fonn" 8 M"'"m Volta,. Sw"""" , O'~JW""S.,.,.,o' 10 CEMS Endo,"" 11 F""GasDowP~OIH..,",12 F"" G" Cood.on'o, S'" 13 P.ol Roads14 C,,", Pod 15 Admioi"'sOOo B"'Oio, 16 M.o,"ooooo B""., 17 Foooowoo 567 666 E 817 927 N Zone 11 Landscape Areas . ?--. \. '!--'-'-'-'-'-'-'-'-'- ---.---. -.-.---.---.--, i115 17: 16 L______---- --- -------------. -------- (f)NORTH lOOF,. EAST BOISE POWER PLANT FIGURE SITE LAYOUT ANALYSIS AREk ADA COUNTY, IDAHO Dot" 09127/05 FlI" PI833 SITE.dwgD",~ ByoJW Loyo",FIG3-1 PROJECT EMISSIONS AND SOURCE DATA Emissions rates will be evaluated over the range of expected ambient temperatures and range of CT operating loads. These will also include emissions occurring during startup and shutdown operations. Startup and shutdown operations will cover the load range from 0 to 60 percent load, and normal operations will include the loads from 60 to 100 percent. Table 4-1 presents the range of operating and ambient parameters that will be included in the modeling analysis. TABLE 4-RANGE OF AMBIENT AND OPERATING PARAMETERS Ambient Temperatures (O , 100, 110 Ambient Relative Humidity 100%, 60%, 10% Operating Loads Startup/shutdown, 60%, 70%, 80%, 90%, 100% Operating and emissions data for the range of ambient and operating conditions presented in Table 4- will be provided by Siemens-Westinghouse. Preliminary estimates for the maximum facility emissions are presented in Table 4-2. Annual emissions that were estimated to be greater than 249 tons per year have been arbitrarily set to 249 tons per year. These emissions reflect operations over the entire range of loads and conditions. TABLE 4-2 EBPP EMISSION RATES Pollutant Ib/hr ton/yr NOx 161 249 645 249 VOC 159 119. S02 PMlO 136 EMISSION CONTROLS Dry low NOx (DLN) combustors will limit emissions of nitrogen oxides (NOx) to 20 parts per million dry volume basis corrected to 15 percent oxygen (ppmvd ~ 15% 02) at operating loads above 70 percent. NOx concentrations at normal operating loads between 60 and 70 percent are expected to be greater than 20 ppmvd ~ 15% 02. These higher concentrations will be accounted for in the modeling analysis. Emissions of carbon monoxide (CO), non-methane-ethane volatile organic compounds (VOC), toxic air pollutants (TAP) and particulate matter with a nominal aerodynamic diameter less than 10 micrometers (PMlO) will be controlled with efficient combustion. Emissions of sulfur dioxide (S02) will be controlled through the use of low sulfur natural gas. CT STARTUP EMISSIONS During the startup and shutdown of a CT, short term elevated emissions of NOx, CO, and VOC may exceed the hourly values shown in Table 4-2. Because emissions of PMlO and S02 are related to fueling rates and operating loads, these emissions would typically be lower than normal operation emissions during startup and shutdown events. Pl833-EBPP Model ProtocoU9.27.05) Project Emissions and Source Data Startup and shutdown events are expected to be less than 0.5 hours, and, as a preliminary estimate, there may be as many as 5 startup events per day and 200 startup events per year. A schedule of startup frequencies used for each averaging period will be included in the PTC application. Depending on the averaging period, emissions corresponding to a conservative schedule of startups will be combined with normal operation (60 to 100 percent load) emissions. For example, 5 hours of startup and shutdown emissions may be combined with 19 hours of normal emissions to calculate a 24 hour average. These averages will be compared to continuous normal operation emissions and the maximum ofthese two values will be used in the dispersion modeling analysis. PI 833-EBPP Model ProtocoU9.27.05) IMPACT ANALYSIS This section describes the air pollutant dispersion modeling setup for the EBPP PTC application. The following modeling and analysis methods for the air quality impact assessment will be discussed: Ambient air quality standards Background pollutant concentrations Local terrain Model selection, setup, and default parameters Meteorological data selection and processing CT load analysis AMBIENT AIR QUALITY STANDARDS Table 5-presents the ambient air quality criteria that will be used to assess the results of the dispersion modeling. The significant impact levels (SILs) will be used to determine whether it will be necessary to assess cumulative impacts to the National Ambient Air Quality Standards (NAAQS) for any pollutant and averaging period. TABLE 5-1 SUMMARY OF REGULATORY AMBIENT AIR CONCENTRATIONS Pollutant Averaging Period SILs (lJg/m NAAQS (lJg/m N02 Annual Mean 1.0 100 Hour 000 000 Hour 500 000 PMIO 24-Hour 150 Annual Mean 1.0 S02 Hour 300 24-Hour 365 Annual Mean 1.0 BACKGROUND POLLUTANT CONCENTRATIONS Table 5-presents the DEQ default criteria pollutant background concentrations that are proposed for this modeling analysis. These values will be added to the estimated EBPP impacts to assess any potential cumulative impact. TABLE 5-2 DEFAULT CRITERIA POLLUTANT CONCENTRATIONS Pollutant Averaging Period Background Cone. (lJg/m N02 Annual Hour 200 Hour 3,400 PMIO 24-Hour Annual S02 Hour 24-Hour Annual P1833-EBPP Model ProtocoU9.27.05) Impact Analysis LOCAL TERRAIN The terrain in the vicinity of the proposed site includes simple, intermediate, and complex terrain. The terrain to the north, east, and west of the facility site is primarily simple terrain. The terrain to the south is a combination of simple and complex terrain. The nearest complex terrain (terrain with elevations above stack height) exists approximately 1 Ian to the south of the facility site. MODEL SELECTION AND SETUP The Industrial Source Complex Short Term model (ISCST3, version 02035) will be used for the EBPP ambient impact analyses. The ISCST3 model is a steady-state, multiple-source, Gaussian dispersion model designed for use with stack emission sources situated in terrain where ground-level elevations can exceed the stack heights of the emission sources. 1. Model Setup The following regulatory default options will be used: Final plume rise Stack tip downwash Buoyancy induced dispersion Calm processing Missing data routine not used Default wind profile exponents (rural) = 0. Default vertical temperature gradients = 0., 0.035 Upper Bound" values used for supersquat buildings No exponential decay for Rural Mode The ISCST3 modeling will employ the final plume rise option, as recommended in the USEP A Modeling Guidelines. Buoyancy-induced dispersion, which accounts for the buoyant growth of a plume, caused by entrainment of ambient air, will also be included in the modeling because of the relatively warm exit temperature and subsequent buoyant nature of the exhaust plumes. As recommended by the USEP Modeling Guidelines, stack tip downwash will be included. Based on the land use classification procedure of Auer (1978), land use in the region surrounding the project site is greater than 50 percent rural. Therefore, rural dispersion coefficients will be assigned. The calm processing option allows the user to direct the program to exclude hours with persistent calm winds in the calculation of concentrations for each averaging period. This option is generally recommended by the USEP A Modeling Guidelines for regulatory applications. The ISCST3 model recognizes a calm wind condition as a wind speed of 0 meters per second (if ASCII data are input) and a wind direction equal to that of the previous hour. The calm processing option in ISCST3 will then exclude these hours from the calculation of concentrations for the various averaging periods. PI 833-EBPP Model ProtocoU9.27.05) Impact Analysis 2. Building Downwash and Good Engineering Practice Building wake effects will be included for both point sources and all structures and buildings at the proposed facility. The ISCST3 wake effect inputs will be generated using the Building Profile Input Program (BPIP). Figure 3-shows the source and building locations to be included in the analysis. BPIP will also be used to analyze Good Engineering Practice (GEP) stack heights (Hg) = H + 1.5 (L) for the point sources. The purpose of this will be to demonstrate that the modeled stack heights do not exceed GEP limits. Table 5-presents the dimensions of the buildings and structures associated with the EBPP. Although the combustion turbines will not have a rectangular structure, the dimensions presented below provide a conservative approximation for air dispersion modeling. TABLE 5-BUILDING DIMENSIONS North-South East-West Length Length Height Building/Structure (m)(m)(m) Combustion Turbine CT Stack 18. Administration Bldg Maintenance Bldg Gas Heater 1.8 Gas Filter 1.8 Inlet Filter 15. Transformer 3. Class II Receptor Grid Receptors at 25-meter intervals will be placed around the facility's fence line. Outside this fence line receptors will be placed according to the criteria shown in Table 5- TABLE 5-4 AMBIENT RECEPTOR LOCATIONS From Receptor Spacing (m) Fence Line 0km 100 0km 0km 250 0km 10.0 km 500 If preliminary modeling shows differences between concentrations at neighboring receptors that are larger than half the difference between the modeled concentrations and the applicable NAAQS, grids with a 50- meter spacing will be placed around those receptors out to a distance of I kilometer. The receptor elevation values will be obtained by importing the UTM easting and northing coordinates of the dispersion modeling grid into Microimages' TNT Mips image processing software. These grid points will be overlaid on 30 meter USGS digital elevation models (DEM) to extract the elevation value at each location. Each 30 meter digital elevation model is coincident with (or has the same extent as) the associated 7.5 minute USGS quadrangle. PI 833-EBPP Model ProtocoU9.27.05) Impact Analysis METEOROLOGICAL DATA 1. Data Selection Five years of surface and mixing height data (1986 through 1990) will be used for the dispersion modeling. The surface data will be obtained from the National Climatic Data Center (NCDC) SAMSON data compact disc for Boise Airport, and concurrent twice daily mixing height data will be obtained from the USEP A SCRAM website for the same monitoring location. 2. Data Processing Surface and mixing height data will be processed by PCRAMMET into an ISCST3 meteorological data set. A stability class for each hour of data will be calculated as part of this processing. CT LOAD ANALYSIS The CT load analysis will include all normal operating emissions and exhaust data over the expected range of operating loads and ambient conditions. Appendix A presents the range of exhaust data that is proposed for this analysis. 1. Criteria Pollutant Impact Analysis The load analysis will evaluate impacts from all criteria pollutant emissions. For each load and ambient condition, the normal emissions will be combined with startup and shutdown emissions and compared to normal emissions without startup or shutdown events. For each operating scenario, the CT emissions will be represented as source groups that reflect each operating scenario. Plot files for each source group will be generated for each pollutant and averaging period. These plot files will, subsequently, be post-processed to determine the maximum impacts and worst-case operating scenarios. If preliminary modeling for EBPP shows impacts that are greater than the SIL for any criteria pollutant dispersion modeling will be performed to determine potential cumulative impacts relative to the NAAQS. 2. Toxic Air Pollutant (TAP) Impact Analysis Because it will be necessary to evaluate impacts for as many as 11 different TAPs, it is being proposed that TAPs will be evaluated using exhaust parameters for a single operating scenario. To identify which scenario will be selected, the load analysis described above will also be used to identify the operating scenario that would result in the maximum CO impacts. The exhaust parameters associated with this operating scenario will be used to model each of the TAP impacts. A single run with unit emissions (1.0 grams per second (gmlsD for each source will be performed for each meteorological year. Because only a single source will be modeled, scaling the impacts with the ratio of actual emissions over unit emissions will produce an accurate result. P1833-EBPP Model ProtocoU9.27.05) Impact Analysis To ensure the conservatism of this analysis, the maximum TAP emission rates over all operating scenarios will be used in the dispersion modeling post-processing. To demonstrate the accuracy of the post-processing, a sample run using actual emissions for a specific TAP will also be included. FUEL DEW POINT HEATER CAVITY ANALYSIS Cavity influences of the CTO I structure on emissions from the fuel dew point heater will be evaluated using the SCREEN3 dispersion model. Model inputs will include stack and exhaust data for the dew point heater and dimensions of the CTOI structure. Because only a single stack will be modeled, an emission rate of 1.0 gm/s will used in the SCREEN3 run. The resulting impact will then be apportioned by the estimated dew point heater emission rates for each criteria pollutant. The impacts estimated by SCREEN3 represent a I-hour averaging period. For other averaging periods the factors on Table 5-from the SCREEN3 Users Guide (USEPA 1995) were used. TABLE 5-5 SCREEN3 AVERAGING PERIOD FACTORS Averaging Period Factor Hour Hour 24-Hour 0.4 Annual P1833-EBPP Model ProtocoU9.27.05) APPENDIX A EXHAUST DATA Ap p e n d i x A Ex h a u s t D a t a Ea s t B o i s e P o w e r P l a n t Co m b u s t i o n T u r b i n e E x h a u s t P a r a m e t e r s En l ! l i s h U n i t s Am b i e n t Am b i e n t Ev a p o r a t i v e Ex h a u s t Ex h a u s t Ex i t Ex i t Op e r a t i n g Te m p Co o l e r Fl o w Te m p Di a m He i g h t Co d e Lo a d (O F ) (% ) Op e r a t i o n (a c f m ) (O F ) (f e e t ) (f e e t ) W0 6 0 N l 60 % 10 0 % OF F 10 8 91 5 03 2 W0 6 0 N 2 60 % 10 0 % OF F 06 7 71 6 04 3 W0 6 0 N 3 60 % 60 % OF F 96 2 13 4 07 4 W0 6 0 N 4 60 % 60 % OF F 93 8 22 9 08 1 W0 6 0 N 6 60 % 10 0 10 % OF F 81 0 70 0 11 7 W0 6 0 N 7 60 % 11 0 10 % OF F 78 4 16 8 12 7 W0 7 0 N l 70 % 10 0 % OF F 30 6 54 9 03 2 W0 7 0 N 2 70 % 10 0 % OF F 25 8 22 1 04 3 W0 7 0 N 3 70 % 60 % OF F 13 6 59 9 07 4 W0 7 0 N 6 70 % 10 0 10 % OF F 95 5 46 1 11 7 W0 7 0 N 7 70 % 11 0 10 % OF F 92 2 77 3 12 7 W0 8 0 N 2 80 % 10 0 % OF F 44 8 98 5 04 3 W0 8 0 N 3 80 % 60 % OF F 31 5 65 4 07 4 W0 8 0 N 6 80 % 10 0 10 % OF F 10 5 42 6 11 7 W0 9 0 N 2 90 % 10 0 % OF F 63 3 29 6 04 3 W0 9 0 N 3 90 % 60 % OF F 48 8 48 2 07 4 W0 9 0 N 6 90 % 10 0 10 % OF F 25 6 40 3 11 7 Wl O O N I 95 % 10 0 % OF F 79 3 89 9 03 2 Wl O O N 2 10 0 % 10 0 % OF F 83 6 67 0 04 3 Wl O O N 3 10 0 % 60 % OF F 67 6 44 5 07 4 Wl O O Y 4 10 0 % 60 % 85 % 67 0 57 2 07 7 WI 0 0 N 5 10 0 % 20 % OF F 48 5 47 0 10 9 Wl O O Y 5 10 0 % 20 % 85 % 60 9 80 2 09 0 Wl O O N 6 10 0 % 10 0 10 % OF F 43 5 00 6 11 7 Wl O O Y 6 10 0 % 10 0 10 % 85 % 57 1 60 5 09 8 Wl O O N 7 10 0 % 11 0 10 % OF F 38 7 17 6 12 7 1 R e c t a n g u l a r S t a c k = 2 7 f e e t b y 2 2 f e e t = 2 8 f e e t e q u i v a l e n t d i a m e t e r PI 8 3 3 - EB P P M o d e l P r o t o c o U 9 . 27 . 05 ) Ap p e n d i x A Ex h a u s t D a t a Ea s t B o i s e P o w e r P l a n t Co m b u s t i o n T u r b i n e E x h a u s t P a r a m e t e r s Me t r i c U n i t s Am b i e n t Am b i e n t I E v a p o r a t i v e Ex i t Ex i t Ex i t Ex i t Op e r a t i n g Te m p Co o l e r He i g h t Te m p Ve l Di a m e t e r Co d e Lo a d (% ) Op e r a t i o n (m e t e r ) (K ) (r n I s ) (m e t e r ) W0 6 0 N l 60 % 10 0 % OF F 18 . 82 8 . 18 . 8. 3 8 2 W0 6 0 N 2 60 % 10 0 % OF F 18 . 83 4 . 4 17 . 8. 3 8 2 W0 6 0 N 3 60 % 60 % OF F 18 . 85 1 . 16 . 38 2 W0 6 0 N 4 60 % 60 % OF F 18 . 85 5 . 16 . 38 2 W0 6 0 N 6 60 % 10 0 10 % OF F 18 . 87 5 . 15 . 4 9 8. 3 8 2 W0 6 0 N 7 60 % 11 0 10 % OF F 18 . 88 1 . 4 15 . 38 2 W0 7 0 N l 70 % 10 0 % OF F 18 . 82 8 . 19 . 8. 3 8 2 W0 7 0 N 2 70 % 10 0 % OF F 18 . 83 4 . 4 19 . 3 1 8. 3 8 2 W0 7 0 N 3 70 % 60 % OF F 18 . 85 1 . 6 18 . 8. 3 8 2 W0 7 0 N 6 70 % 10 0 10 % OF F 18 . 87 5 . 16 . 8. 3 8 2 W0 7 0 N 7 70 % 11 0 10 % OF F 18 . 88 1 . 4 16 . 8. 3 8 2 W0 8 0 N 2 80 % 10 0 % OF F 18 . 83 4 . 4 20 . 8. 3 8 2 W0 8 0 N 3 80 % 60 % OF F 18 . 85 1 . 19 . 8. 3 8 2 W0 8 0 N 6 80 % 10 0 10 % OF F 18 . 87 5 . 18 . 38 2 W0 9 0 N 2 90 % 10 0 % OF F 18 . 83 4 . 4 22 . 38 2 W0 9 0 N 3 90 % 60 % OF F 18 . 85 1 . 6 21 . 2 8 38 2 W0 9 0 N 6 90 % 10 0 10 % OF F 18 . 87 5 . 19 . 3 0 8. 3 8 2 WI 0 0 N l 95 % 10 0 % OF F 18 . 82 8 . 23 . 38 2 WI 0 0 N 2 10 0 % 10 0 % OF F 18 . 83 4 . 4 24 . 38 2 WI 0 0 N 3 10 0 % 60 % OF F 18 . 85 1 . 6 22 . 38 2 WI 0 0 Y 4 10 0 % 60 % 18 . 85 3 . 5 22 . 8. 3 8 2 WI 0 0 N 5 10 0 % 20 % OF F 18 . 87 1 . 5 21 . 2 6 8. 3 8 2 WI 0 0 Y 5 10 0 % 20 % 18 . 86 0 . 22 . 3 2 38 2 WI 0 0 N 6 10 0 % 10 0 10 % OF F 18 . 87 5 . 20 . 8. 3 8 2 W1 O 0 Y 6 10 0 % 10 0 10 % 18 . 86 5 . 21 . 9 9 38 2 W1 O 0 N 7 10 0 % 11 0 10 % OF F 18 . 88 1 . 4 20 . 4 2 8. 3 8 2 PI 8 3 3 - EB P P M o d e l P r o t o c o U 9 . 27 . 05 )