20181119PAC to Monsanto Envvironmental Final Approval Order.PDF

State of Utah
Department of
Environmental Quality
OLENE S WALKER
GOIJCI nor
May 17,2004
Robert Van Engelenhoven
PacifiCorp
20 1 South Main, Suite 2200
Salt Lake City, Utah 84 1 11
Dear Mr. Engelenhoven:
Re: Approval Order: Approval Order for 525 MW Natural Gas Turbine Power Plant Near Mona
Reservoir, Juab County - CDS A; ATT; NSPS, HAPS, TITLE IV MAJOR, TITLE V MAJOR
Project Code: N2524-002
The attached docunient is the Approval Order (AO) for the above-referenced project
Future correspondence on this Approval Order should itlclude tile engineer's name as well as the DAVE
number as shown on the upper right-hand corner of this letter. Please direct any technical questions you
may have on this pro-ject to Mr. John D. Jenks. He may be reached at [phone].
lJtah Air ~uaqity Board
cc : Central Utah Public I-lealth Department
Mike Owens, EPA Region VIII
I50 North I950 We\t - P O 13ox 144820 - \‘lit Lake C'lty, ll r 841 14 4820 plkonc [phone]. iax [phone] 0
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality
APPROVAL ORDER: APPROVAL ORDER FOR 525 MW
NATURAL, GAS TURBINE POWER
Prepared By: ,John D. Jenks, Engineer
[phone]
Email: [e-mail]
APPROVAL ORDER NUMBER
Date: May 17,2004
PacifiCorp
Source Contact
Gene Marshall
[phone]
Kichard W. Sprott
Executive Secretary
Utah Air Quality Board
A bstract
PaciJiCorp subinitten a Notice of Intent (NOI) to install and operate the Currant Creek Power Plant in
Juab County near Mona, Utah. The power plant ~ v o ~ ~ l d consist of two natural gas-fired turbine
generators with heat recovery steam generators with duct burning and a steam turbine. The plant will
be capable of producing 525 MW of electricity in combined cycle inode. Emissions from the plant will
be controlled through good combustion practices, a Selective Catalytic Reduction (SCR) system and an
oxidation catalyst. Additional eqrsipinent would include a wet cooling tower, emergency generator, an
auxiliary boiler, fire pump, amrnonia storage and handling equipment and water treatment and storage.
The source is allowed 10 months of simple cycle operation after initial installation, with a requirement
to convert to combined cycle operations by the end of that 10-month period. Startup and Shutdown
periods will be limited to 1000 hours per year, and a nzaxitnum of 8 hours per day. Jzcab County is an
attainment area of the National Ambient Air Quality Standards (NAAQS) for all pollutants. New
Source Performance Standards (NSPS) Slcbparts A, Da, Dc, and GG, applies to this source. National
Emission Standards for Hazardous Air Pollutants (NESHAP) and Maximum Available Control
Technology (MACT) regulations do not apply to this source. Title IV of the Clean Air Act applies to this
source. Title V of the 1990 Clean Air Act applies to this source, with the requirement that the source
submit a Title V application within one year of comnzencing operation. The emissions, in tons per year,
will be as follo~vs: PMlo 101.6, NO, 344.3, SO2 9.2, CO 277.6, VOC 50.9, IIAPs 8.8 (including 4.1 tons
per year of Formaldehyde) and 1.0 tons per year of N2S04.
The project has been evaluated and found to be consistent with the requirements of the Utah
Administrative Code Rule 307 (UAC 11307). A public cornrnent period and a public hearing were held in
accordance with UAC R307-401-4 and all comments received were evaluated. This air quality Approval
Order (AO) authorizes the project with the following conditions, and failure to comply with any of the
conditions nlay constitute a violation of this order.
General Conditions:
1. This Approval Order (AO) applies to the following company:
Corporate Office Location
PacifiCorp
Attn: Environmental Services Depal-tlnent
1407 West North Temple, Suite 330
Salt Lake City, Utah 841 16
Phone Number [phone]
Fax Number [phone]
The equipment listed in this A 0 shall be operated at the following location:
PacifiCorp - Curran1 Creek Plant
Attn: Plant Manager
2096 West 300 Norlh
Mona, IJT 84645
Universal Transverse Mercator (UTM) Coordinate System: 1I'TM Datuin NAD27
4,408.1 kilometers Northing, 423.6 kilometers Easting, Zone 12
DAQE-AN2524002-04
Page 3
2. All definitions. terms. abbreviations, and references used in this A 0 confor~n to those used
in the Utah Administrative Code (UAC) Rule 307 (fi307) and Title 40 of the Code of
Federal Regulations (40 CFR). Unless noted otherwise, references cited in these A 0
conditions refer to those rules.
3. The li~nits set forth in this A 0 shall not be exceeded without prior approval in accordance
with R307-401.
4. Modifications to the equipment or processes approved by this A 0 that co~~ld affect the
emissions covered by this A 0 must be reviewed and approved in accordance witti
R307-40 1 - 1.
5. All records referenced in this A 0 or in applicable NSPS andlor NESHAP and/or MACT
standards, which are required to be kept by tlie ownerloperator, shall be made available to
the Executive Secretary or Executive Secretary's representative upon request, and the
records shall include the five-year period prior to the date of the request. Records shall be
kept for the following minimum periods:
A. Emission inventories Five years from the due date of each emission statement
or i~ntil the next inventory is due, whichever is longer-.
B. All other records Five years
6. PacifiCorp shall install and operate the Currant Creek Power Project and shall conduct its
operations of the same in accordance with the terms and conditions of this AO, which was
written pursuant to PacifiCorp's Notice of Intent submitted to the Division of Air Quality
(DAQ) on August 6, 2003 and additional information submitted to the DAQ on September
26, 2003; October 20, 3003; October 29, 2003; December 2, 2003; December 16, 2003;
and February 3, 2004.
7. The approved installations shall consist of the following equipment or equivalent*:
A. Two (2) <<enera1 Electric Frame 7FA natural gas-fired turbine generator sets (140
MW nominal capacity each in si~nple cycle mode)
140' simple cycle bypass stacks (as measured from the base of the stack)
13. Two (2) heat recovery steal11 generators (HRSGs) each equipped with 500
MMBtuIhr (HMV) duct burners
165' HRSG main stacks (as measured from the base of the stack)
Selective Catalytic Reduction (SClI) system with amnlonia injection
Oxidation Catalyst system
C. One (1) stearn turbine (250 MW nominal capacity in combined cycle
D. One ( I ) natural gas-fired 66 MMBtuIhr anxiliar-y boiler
50' boiler stack (as measured from the b x e of tlie stack)
E. Two (2) natural gas-fired f~iel heaters
F. 800 kW diesel-fired einergency generator
DAQE-AN2524002-04
Page 4
. One (1) 250 hp diesel-fired fire purnp
H. One (1) air-cooled ~ondenser"::~:
1. One (1) mechanical draft cooling tower with drift elimination
J. Water treatment and storage facilities*'"
K. Aqueous ammonia storage and handling equipment*"
:* Equivalency shall be determined by the Executive Secretary.
*:* These items are listed for informational put-poses only, there are no emissions from
these itenls.
8. The SCR and Oxidation Catalyst systems shall be operated at all times that the combustion
turbines are operated in combined cycle mode. All emissions from the con~bustion
turbines shall be passed through the SCR and Oxidation Catalyst systems during combined
cycle operation.
9. PacifiCorp shall notify the Executive Secretary in writing when the installation of the
equipment listed in Condition #7 has bee11 completed and is operational, as an initial
compliance inspection is required. To insure proper credit when notifying the Executive
Secretary, send your correspondence to the Executive Secretary, rtttn: Compliance Section.
If construction andlor installation has not been completed within eighteen months from the
date of this AO, the Executive Secretary shall be notitied in writing on the status of the
construction andlor installation. At that time, the Executive Secretary shall require
documentation of the continuous construction andlor installation of the operation and may
I-evoke the A 0 in accordance with R307-401-11.
Limitations and Tests Procedures
10. Emissions to the atmosphere from the indicated emission point(s) shall not exceed the
a tons: following rates and concentr t'
Source: Each Bypass Stack (when operating in simple cycle mode)
Pollutant Limitations at 15% 02 Averaging Period
PM/PMlo ......................................... 0.066 IbIMMBtu HHV (10.8 lb/hour)l8-hour
................................................ NO , 9.0 ppmvd (54.0 Iblhr) 18-hour
............................................. CO 7 . 8 pprnvd (28.0 lblhr) 24-hour
Source: Each HRSG Stack (when operating in combined cycle mode)
I'ollutant Limitations at 15% O?: Avera,~inr Period
PM/13Ml o... ..................................... 0.066 lblMMRt~1 HHV (13.3 Ib/ho~r)24-hour*:~
............................................... NO , 2 . 2 5 pp~livd (17.0 lblhr) 3-hour
................................................. CO 3 . 0 ppmvd (1 1.6 Iblhr) 3-hour
I>AQE-AN2524002-04
Page 5
Excluding startups, shutdowns and shol-t-tern1 excilrsions as defined in the
Conditions #12 and #13
4: :* Based on a 24-hour test run or any method approved by the Executive Secretary,
which will provide 24-hour data
1 I. Stack testing to show co~npliance with the emission limitations stated in the above
condition shall be perfortned as specified below:
A. Testing Test
Emissions Point Pollutant Status Frequency
C Bypass Stacks or PMIPM ....................................... $
HRSG Stacks NO, .............................................. % .#
-(c CO.. .............................................. .#
B. Testing Status (To be applied to the source listed above)
* Initial cornpliance testing is required. The initial test date shall be
performed as soon as possible and in no case later than 180 days after the
start up of a new emission source, an existing source without an AO, or
the granting of an A 0 to an existing emission source that has not had an
initial co~lipliance test performed. If an existing source is modified, a
compliance test is required on the modified emission point that has an
emission rate limit.
$ Test annually
# Compliance shall be demonstrated through use of a Continuous E~nissions
Monitoring System (CEM) as outlined in Conditions #15.A and #22
below. The Executive Secretary inay require testing at any time.
C. Notification
The Executive Secretary shall be notified at least 30 days prior to conducting any
required emission testing. A source test protocol shall be submitted to DAQ when
the testing notification is submitted to the Executive Secretary.
The source test protocol shall be approved by the Executive Secretary prior to
performing the test(s). The source test protocol shall outline the proposed test
~~lethodologies, stack to be tested, and procedures to be used. A pretest conference
shall be held, if directed by the Executive Secretary.
D. Sample Location
The emission point shall be designed to conform to the reqnirements of 40 CFII
60, Appendix A, Method 1, or other neth hods as approved by the Executive
Secretary. An Occupational Safety and Wealth Administration (OSHA) or Mine
Safety and Health Administration (MSHA) approved access shall be provided to
the test location.
DAQE-AN2524002-04
Page 6
E. Volumetric Flow Kate
40 CFR 60, Appendix A, Method 2 or EPA Test Method No. 19 "SO? Removal RL
PM, SOz, NO, Rates from Electric IJtility Steam Generators" or other testing
methods approved by the Executive Secretary.
For stacks in which no liquid drops are present, the following methods shall be
used: 40 CFK 51, Appendix M, Methods 201, 201a and 202 or other testing
methods approved by EPA. All particulate captured shall be considered PMIO, -
The back half condeilsibles shall be used for coinpliance deinonstration as well as
for inventory purposes.
For stacks in which licluid drops are present, nlethods to eliminate the liquid drops
should be explored. If no reasonable rnethod to eliminate the drops exists, then the
following methods shall be used: 40 CFli 60, Appendix A, Method 5, 5a, Sd, or
5e as appropriate, or other testing inethods approved by EPA. The back half
condensibles shall also be tested using the rnethod specified by EPA. The portion
of the front half of the catch considered PMIo shall be based on information in
Appendix H of the fifth edition of the EPA document, AP-42, or other data
acceptable to the Executive Secretary.
G. Nitrogen Oxides (NO&)
40 CFR 60, Appendix A, Method 7, 7A, 7H, 7C, 711, 7E, or other testing inethods
approved by the Executive Secretary.
H. Carbon Monoxide (CO)
40 CFR 60, Appendix A, Method 10, or other testing rnethods approved by the
Executive Secretary.
To determine mass emission rates (lblhr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the
volumetric flow rate and any necessary conversion factors determined by the
Executive Secretary, to give the results in the specified units of the emission
limitation.
J. New Source Operation
For a new so~irceleinission point, the prod~ictioil rate during all colvpliance testing
shall be no less than 90% of the production rate listed in this AO. If the maximum
A 0 allowable production rate has not been achieved at the time of the test, the
following procedure shall be followed:
1 > Testing shall be at no less than 90% of the production rate achieved to
date.
2) If the test is passed, the new ~i~axi~iium allowable production rate shall be
110% of the tested achieved rate. but not more than the maxirnuni
allowable production rate. This new allowable maxin~um production rate
shall remain in effect ilntil successfully tested at a higher rate.
3) The ownerloperator shall request a higher production I-ate when necessary.
Testing at no less than 90% of the higher rate shall be conducted. A new
maximum production rate (1 10% of the new rate) will then be allowed if
the test is successfi~l. This process may be repeated until the rnaxirnuln
AO production rate is achieved.
K. Existing; Source Operatio11
For an existing sourcelemission point, the production rate during all compliance
testing shall be no less than 90% of the maximum production achieved in the
previous three (3) years.
12. During combined cycle operation, compliance with 3-hour NOx and CO emission
limitations specified in Condition #10 shall not be required during short-term excursions,
limited to a cumulative total of 160 hours annually. Short-term excursions are defined as
15-minute periods designated by the OwnerIOperator that are the direct result of transient
load conditions, not to exceed four consecutive 15-minute periods, when the 15-minute
average CO or NOx concentration exceeds 3.0 and 2.25 ppmv, dry @ 15% 0 2 ,
respectfillly. Transient load conditions include the following:
( I) Initiation/shutdown of cornbustion turbine inlet air cooling
(2) Rapid colnbustion turbine load changes
(3) Initiationlshutdown of HRSG duct burners
(4) Provision of Ancillary Services and Automatic Generation Control.
During periods of transient load conditions, ernissions of NOx shall not exceed 25 ppmv,
dry @ 15% 0 2 .
13. Startup is defined as the period beginning with turbine initial firing until the unit meets the
ppmvd e~nission limits in Condition #10 for steady state operation. Shutdown is defined
as the period beginning with the initiation of turbine shutdown sequence and ending with
the cessation of firing of the gas turbine engine. Startup and shutdown events shall not
exceed 1000 hours per turbine per calendar year. The cum~~lative startup and shutdown
period shall not exceed 8-hours in any one day, commencing at midnight.
14. Visible ernissions from the following e~nission points shall not exceed the followi~ig
values:
A. All natural gas colnbustion exhaust stacks - 10% opacity
D. All other points - 20% opacity
Opacity observations of ernissions from stationary sources shall be conducted according to
40 CFR 60, Appendix A, Method 9.
DAQE-AN2524002-04
Page 8
15. PacifiCorp shall operate the Currant Creek Plant according to the following schedule:
A. For the period through 10 months following comn~encing of initial operation. the
plant can be operated in simple cycle mode. While operating in simple cycle
mode the plant shall not exceed 18 hours of operation per day per turbine
generator set. During the other 6 hours of that day there shall be no e~nissions
from the Bypass Stack associated with that turbine generator set. I-fours of
operation shall be determined by supervisor monitoring and the daily maintaining
of an operations log. During this period, compliance with the NO, and CO
limitations expressed in Condition #10 shall be monitored through use of a
Continuous Elnissions Monitoring System (CEM) as outli~ied in Condition #22.
B. Beginning no later than 10 months after initial operation, the plant shall only be
operated in combined cycle mode. The Bypass Stacks shall only be used for
periods of upset or breakdown conditions.
16. Emergency generators shall be used for electricity producing operation only during the
periods when electric power from the public utilities is interrupted, or for regular
maintenance of the generators. Records documenting generator usage shall be kept in a
log and they shall show the date the generator was used, the duration in hours of the
generator usage, and the reason for each generator usage
Fuels
17. The ownerloperator shall use natural gas as f~tel in the combustion turbines, duct burners,
fuel heaters and auxiliary boiler.
18. The ownerloperator shall use #1, #2 or a combination of # I and #2 diesel fuel in the
emergency generators and fire pump.
19. The sulfur content of any fuel oil or diesel burned shall not exceed 0.50 percent by weight.
The sulfur content shall be determined by ASTM Method D-4294-89 or approved
equivalent. Certification of used oil shall be either by PacifiCorp's own testing or test
reports from the used oil fuel marketer. Certification of other fuels shall be either by
PacifiCorp's own testing or test reports froin the fuel marketer.
Federal Lir~litations and Reyuirernents
20. In addition to the requirements of this AO, all applicable provisiorls of 40 CFII 60, New
Source Performance Standards (NSPS) Subpart A, 40 CFK 60. 1 to 60.18 and Subpart GG,
40 CFII 60.330 to 60.334 (Standards of Perforinance for Stationary Gas Turbines) and
Subpart Da, 40 CFR 60.40a to 60.49a (Standards of Perforrllance for Electric Utility Stearn
Generating Units for Which Constriiction is Commenced After September 18, 1978), and
Subpart Dc, 40 CFR 60.40~ to 60.4% (Standards of Perforrnance for Small Industrial-
Commercial-Institutional Steam Generating Units), apply to thls installation.
21. In addition to the requirements of this AO, all applicable provisions of 40 CFK Part 72, 73,
75, 76, 77 and 78, Federal Regulations for the Acid Rain Program under Clean Air Act
Title 1V apply to this installation.
DAQE-AN2524002-04
Page 9
Iklonitoring - Continuous Enlissions Rilonitoring
22. PacifiCorp shall install, calibrate, maintain, and operate a continuous emissions monitoring
system on the HliSG stacks. PacifiCorp shall record the output of tlie system. for
measuring the NO, emissions and the CO emissions. 'The inonitol-ing system shall comply
with all applicable sections of R307-170; 40 CFR 60.13; 40 CFR 60, Appendix R; and 40
C'FR 75.
All continuous emissions monitoring devices as required in federal regulations and state
rules shall be installed and operational prior to placing the affected source in operation.
Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) 40 CFR 60.13, the ownerloperator of an affected source shall
continuously operate all required continuous monitoring systems and shall meet minimum
frequency of operation requirements as outlined in 40 CFR 60.13 and Section R307- 170.
liecords & Miscellaneous
23. At a11 times, including periods of startup, shutdown, and malfunction, owners and
operators shall, to the extent practicable, maintain and operate any eq~liptne~it approved
~tnder this Approval Order including associated air pollution control equipment in a
manner consistent with good air pollution control practice for minimizing emissio~ls.
Determination of whether acceptable operating and maintenance proced~tres are being used
will be based on infortnation available to the Executive Secretary which may include, but
is not li~nited to, monitoring results, opacity observations, review of operating and
niaintenance procedures, and inspection of the source. All maintenance performed on
ecluipment authorized by this A 0 shall be recorded.
24. The ownerloperator shall comply with K307-150 Series. Inventories, Testing and
Monitoring.
25. 'The ownerloper-ator shall coniply with R307-107. General Requirements: Unavoidable
Breakdowns.
The Executive Secretary shall be notified in writing if the company is sold or changes its name.
This A 0 in no way releases the owner or operator from any liability for compliance with all other
applicable federal, state, and local regulations including K307.
A copy of the rules, regulations and/or attachments addressed in this A 0 tnay be obtained by contacting the
Division of Air Quality. The Utah Administrative Code R307 rules used by DAQ, the Notice of Intent
(NOI) guide, and other air quality docuriients and forms inay also be obtained on tlie Internet at the
following web site:
http://airquality.utah.gov/ilqql~o~ne.ht~n
The annual emissions estimations below are for the purpose of delerinining the applicability of Prevention
of Significant Deterioration, non-attainment area, maintenance area, and Title V source requirements of the
R307. They are not to be used for determining compliance.
The Potential To Einit (FTE) elnissio~is for this source are cu-rently calculated at the following valucs:
DAQE-AN2524002-04
Page 10
Pollutant Tonslyr
A . PMlo ........................................................... 101.6
B . SO2 ................................................................ 9.2
C . NO , ............................................................. 344.3
...................... D . NO, (combined cycle mode) 140.3
E . CO ........................................................... 100.0
F . VOC ............................................................. 26.7
G . FI1sOJ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.0
H . HAPS
Formaldehyde .................................... 4.1
Total HAPS ........................................... 8.8
Utah Air ~ualit)(/Board