Below are a few profiles of projects we have recently conducted. As you read through them you’ll see how we work with our clients, for instance, we strive to do more than just get a permit but rather to think holistically about our client’s operations and look for ways to give them maximum operational flexibility.
Future Power PA
OES was retained by Future Power PA to permit a 196.9 MW Integrated Gas Combined Cycle (IGCC) power plant using anthracite coal in a TPRI gasifier using a single shift process. This was the first modern coal gasification plant permitted in Pennsylvania and one of the first in the country. The process consisted of an air separation unit, the gasifier, the shift unit, a gas cooling unit, an acid gas removal system, a sulfur recovery unit, followed by the combined cycle unit for power generation. The front end of the project involved permitting a complete coal handling operation. The turbines were controlled by SCR and a catalytic oxidizer.
The application was submitted for the facility in late August 2009 and the permit was issued April 2, 2010, in approximately 7 months. After the permit was acquired Future Power PA decided to build a larger unit. In mid-August 2010, a new permit application was submitted for a 336 MW IGCC Plant. That permit was issued on November 2, 2010, in about two and a half months.
Due to the poor power market and the descending price of natural gas, Future Power PA decided to convert this project to an NGCC facility of 300 MW. Because of the Greenhouse Gas Tailoring Rule, this application triggered PSD for GHG’s and then for PM10, PM2.5, and NOX since these three were above significance levels.
The permit for this facility was issued in early 2014 and construction is expected to start in Spring 2014.
Evergreen Community Power (482 MMBTU/hr Waste Biomass Power Plant)
OES was retained by Evergreen Community Power to rehabilitate an existing construction permit that was difficult to comply with. The prior consultant had convinced the facility to propose short term limits that were directly derived from the long term (i.e. running 12 months limits), and these limits were difficult to achieve in practice.
The facility is a newly constructed circulating fluidized bed (CFB) boiler with a heat input capacity of 482 MMBTU/hr controlled by a hot Electrostatic Precipitator (ESP), Trona®, and selective catalytic reduction (SCR). OES was able to effect the following changes in the construction permit:
- Raise CO emission limit from 0.047 lb/MMBTU (3-hr average) to 0.1 lb/MMBTU (4-hour average)
- Raise VOC emission limit from 0.008 lb/MMBTU (3-hr average) to 0.017 lb/MMBTU (3-hour average)
- Raise HCl emission limit from 0.005 lb/MMBTU (3-hr average) to 0.012 lb/MMBTU (24-hour average)
- Raise HF emission limit from 0.0005 lb/MMBTU (3-hr average) to 0.0012 lb/MMBTU (3-hour average)
Additionally, in reviewing the permit, OES found a number of fugitive particulate sources that had not previously been permitted. These were added to the construction permit, a filterable particulate matter limit was removed as an applicable condition, and a lower PM10 limit was negotiated to maintain minor source status for the facility. This lowered the PM10 limit from 0.046 lb/MMBTU to 0.042 lb/MMBTU but removed a potentially problematic filterable limit of 0.029 lb/MMBTU.
A number of other changes were also negotiated in the permit that were important from a compliance standpoint:
- Correction of incorrect burner capacities for auxiliary gas burners in the CFB
- Correction of vent filters in permit from design to construction
- Negotiations on startup shutdown language
- Removing limitations on natural gas usage
- Inclusion of additional permitted fuels to the boiler
- Removal of fuel limits on Cl, N, and S
- Removal of requirement to test maximum heat input to the boiler
- Removal of a 3-hour NOX compliance time from the permit conditions.
- Removal of semiannual compliance report requirement due to quarterly CEMS submittals.
- Agreement to allow conductivity testing in lieu of TDS measurement in cooling water
- Negotiation of a higher cooling water TDS limit.