DRAFT
OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION
MEMORANDUM May 12, 2005
TO: Dawson Lasseter, P.E., Chief Engineer, Air Quality Division
THROUGH: Grover Campbell, P.E., Existing Source Permits Section
Jian Yue, P.E., Engineering Section
THROUGH: Peer Review
FROM: Ing Yang, P.E., New Source Permits Section
SUBJECT: Evaluation of Permit Application No. 2000-273-TV
WFEC GENCO L.L.C.
Two Natural Gas Peaking Turbines and Associated Equipment
NW/4 of Section 14, T7N, R10W, Caddo County
Located 1 mile north of SH 62 and 7th Street in Anadarko
SECTION I. INTRODUCTION
WFEC GENCO L.L.C. has requested a Title V permit application for their power plant located in Anadarko, Oklahoma. GENCO is a wholly-owned subsidiary of WFEC ENERGYCO, LLC, and ENERGYCO is a wholly-owned subsidiary of WFEC. The GENCO Facility and the WFEC Facility are maintained as separate and distinct facilities. A construction permit No. 2000-273-C (PSD) was issued in November 2000 to address the installation of two General Electric (GE) LM6000 SprintTM simple cycle turbines, which had potential NOx emissions greater than the PSD significance level of 40 tons per year. Each turbine is nominally rated at approximately 47 megawatts (MW) with water injection for pollution control. The permit went through full PSD review.
The facility emits more than 100 TPY of a regulated pollutant and is subject to Title V permitting requirements. Emission units (EUs) have been arranged into Emission Unit Groups (EUGs) in the following outline. Commercial-grade natural gas is the primary fuel with each turbine limited to 4,000 operating hours per year.
SECTION II. EQUIPMENT
EUG 1 Facility WideEU ID# / Point ID# / EU Name/Model / Construction Date
None / None / Facility / 2001
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EU ID# / Point ID# / EU Name/Model / Installation Date
1A / 1A /
GE LM6000 Sprint Turbine
/ 20011B / 1B /
GE LM6000 Sprint Turbine
/ 2001SECTION III. EMISSIONS
The basis for the turbine emissions calculations is vendor supplied data. Hourly emissions for NOx, CO, and VOC are based on operations at a worst-case ambient temperature of 20 degrees Fahrenheit. Annual emissions are based on the vendor’s hourly value and on the approximate annual average temperature for the region, 59 degrees Fahrenheit. Each turbine is rated at 452 MMBtu/hr. Since the water injection rate varies to hold NOx emissions at or below 25 ppm, a factor of 2.5 has been applied to the hourly CO and VOC emission rate as suggested by the manufacturer. In addition, a 0.20 factor for VOC emissions has been applied to the total hydrocarbon factor to estimate VOC emissions. PM10 emissions are based on manufacturers data. SO2 emissions are based on AP-42, Section 3.1 (4/00), Table 3.1-2a. The turbines and cooling tower emissions assume 4,000 operating hours per year while the emergency generator is calculated to operate 500 hours per year. Emissions from the 5.17 MMBTUH emergency black-start generator are due to the combustion of diesel fuel. Emissions data is provided by the manufacturer based on the load of the generator. The worst case emission factors regardless of load were used to determine the hourly and annual emissions.
Emissions from the wet cooling towers are based on emission factors presented in U.S. EPA’s AP-42 (1/95), Table 13.4-1 for particulate matter less than 10 microns in diameter (PM10). Toxic contaminant emissions are also calculated using a mass balance of compounds added to the cooling water. The water circulation rate in the cooling system will be 60 gallons per minute and the unit will only operate during the hours of turbine operation.
Facility Emissions*Unit / NOx / CO / PM10 / SO2 / VOC
lb/hr / TPY / lb/hr / TPY / lb/hr / TPY / lb/hr / TPY / lb/hr / TPY
Turbine #1 / 41.00 / 79.64 / 122.50 / 45.50 / 3.00 / 6.00 / 1.56 / 3.08 / 2.10 / 0.60
Turbine #2 / 41.00 / 79.64 / 122.50 / 45.50 / 3.00 / 6.00 / 1.56 / 3.08 / 2.10 / 0.60
Emerg Gen. / 7.42 / 1.86 / 1.19 / 0.30 / 0.40 / 0.10 / 2.68 / 0.67 / 0.22 / 0.06
Cooling Twr. / - / - / - / - / 0.70 / 0.14 / - / - / - / -
TOTAL / 89.42 / 161.14 / 246.19 / 91.30 / 7.10 / 12.24 / 5.80 / 6.83 / 4.42 / 1.26
* Facility will also have emissions of Lead at 0.01 lb/hr and 0.02 TPY and H2SO4 at 0.09 lb/hr and 0.18 TPY
The facility will also have HAP/toxic emissions. Turbine emissions are based on AP-42 (4/00) Section 3.1, Table 3.1-3. Cooling tower emissions are based on anticipated daily usage rates of cooling water additives; five gallons per day of bleach, one gallon per day for Performax 4021, and one gallon per day of Dioltech 414, and 100% evaporation.
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Pollutant / Emission Factor (lb/MMBTU) / lb/hr / TPY
1,3-Butadiene / <4.3 E-07 / 0.0004 / 0.0008
Acetaldehyde / 4.0 E-05 / 0.036 / 0.072
Acrolein / 6.4 E-06 / 0.006 / 0.012
Benzene / 1.2 E-05 / 0.010 / 0.020
Ethylbenzene / 3.2 E-05 / 0.030 / 0.060
Formaldehyde / 7.1 E-04 / 0.650 / 1.300
Naphthalene / 1.3 E-06 / 0.0012 / 0.0024
PAH / 2.2 E-06 / 0.002 / 0.004
Propylene Oxide / <2.9 E-05 / 0.026 / 0.052
Toluene / 1.3 E-04 / 0.118 / 0.236
Xylenes / 6.4 E-05 / 0.058 / 0.116
Total HAPs / - / 0.938 / 1.875
Toxic Emissions From The Cooling Tower
Pollutant / % Content / lb/hr / TPY
Bleach
Sodium Hypochlorite
Sodum Chloride
Sodium Hydroxide / 15
11
2.5 / 0.33
0.24
0.05 / 0.66
0.48
0.11
Dioltech
Polyethylene Glycol / 10 / 0.04 / 0.07
Performax 4021
Tetrapotassium Pyrophosphate
Potassium Bisphosphonate
Sodium Tolyltriazone / 36
14
7 / 0.18
0.07
0.03 / 0.36
0.14
0.07
SECTION V. INSIGNIFICANT ACTIVITIES
The insignificant activities identified and justified in the application are duplicated below. Appropriate recordkeeping of activities indicated below with “*” is specified in the Specific Conditions.
- *Stationary reciprocating engines burning natural gas, gasoline, aircraft fuels, or diesel fuel which are either used exclusively for emergency power generation or for peaking power service not exceeding 500 hours per year. There is an emergency pump powered by a diesel engine. Records of operational time or fuel purchases will be maintained as documentation.
2. Cold degreasing operations utilizing solvents that are denser than air.
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- Welding and soldering operations utilizing less than 100 pounds of solder and 53 tons per year of electrodes. These activities are conducted as part of plant maintenance, which is a “trivial activity,” therefore recordkeeping will not be required.
4. Torch cutting and welding of under 200,000 tons of steel fabricated.
5. Surface coating operations which do not exceed a combined total usage of more than 60 gallons/month of coatings, thinners, and clean-up solvents at any one emission unit. Surface coating is conducted at the facility as part of routine maintenance.
6. Hand wiping and spraying of solvents from containers with less than 1 liter capacity used for spot cleaning and/or degreasing in ozone attainment areas. Small amounts of solvent used for degreasing are applied to facility components using a rag.
7. * Activities that have the potential to emit no more than 5 TPY (actual) of any criteria pollutant. The facility has not identified any other activities that have the potential to emit more than 5 TPY (actual) of any criteria pollutant but it may have some in the future.
SECTION VI. OKLAHOMA AIR POLLUTION CONTROL RULES
OAC 252:100-1 (General Provisions) [Applicable]
Subchapter 1 includes definitions but there are no regulatory requirements.
OAC 252:100-3 (Air Quality Standards and Increments) [Applicable]
Primary Standards are in Appendix E and Secondary Standards are in Appendix F of the Air Pollution Control Rules. At this time, all of Oklahoma is in attainment of these standards.
OAC 252:100-4 (New Source Performance Standards) [Applicable]
Federal regulations in 40 CFR Part 60 are incorporated by reference as they exist on July 1, 2002, except for the following: Subpart A (Sections 60.4, 60.9, 60.10, and 60.16), Subpart B, Subpart C, Subpart Ca, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, and Appendix G. These requirements are addressed in the “Federal Regulations” section.
OAC 252:100-5 (Registration, Emission Inventory, and Annual Operating Fees) [Applicable]
Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission inventories annually, and pay annual operating fees based upon total annual emissions of regulated pollutants. Emission inventories have been submitted and fees paid for the past years.
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OAC 252:100-8 (Permits for Part 70 Sources) [Applicable]
Part 5 includes the general administrative requirements for part 70 permits. Any planned changes in the operation of the facility which result in emissions not authorized in the permit and which exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior notification to AQD and may require a permit modification. Insignificant activities mean individual emission units that either are on the list in Appendix I (OAC 252:100) or whose actual calendar year emissions do not exceed the following limits:
· 5 TPY of any one criteria pollutant
· 2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20% of any threshold less than 10 TPY for a HAP that the EPA may establish by rule
· 0.6 TPY of any one Category A toxic substance
· 1.2 TPY of any one Category B toxic substance
· 6.0 TPY of any one Category C toxic substance
Emission limits for the facility are based on Permit No. 2000-273-C (PSD).
OAC 252:100-9 (Excess Emissions Reporting Requirements) [Applicable]
In the event of any release which results in excess emissions, the owner or operator of such facility shall notify the Air Quality Division as soon as the owner or operator of the facility has knowledge of such emissions, but no later than 4:30 p.m. the next working day. Within ten (10) working days after the immediate notice is given, the owner operator shall submit a written report describing the extent of the excess emissions and response actions taken by the facility. Part 70/Title V sources must report any exceedance that poses an imminent and substantial danger to public health, safety, or the environment as soon as is practicable. Under no circumstances shall notification be more than 24 hours after the exceedance.
OAC 252:100-13 (Open Burning) [Applicable]
Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the conditions listed in this subchapter.
OAC 252:100-19 (Particulate Matter) [Applicable]
This subchapter specifies a particulate matter (PM) emission limitation of 0.6 lb/MMBtu from fuel-burning equipment with a rated heat input of 10 MMBtu/hr or less. For fuel-burning equipment greater than 10 MMBtu/hr, this subchapter specifies a PM emission limitation based upon the heat input of the equipment. Each turbine is rated at 452 MMBtu/hr. The turbines are to be fired with pipeline natural gas with an emission limit of 3 lb/hr per unit. Based on these requirements, the turbines will have PM emissions of 0.0066 lb/MMBtu which is below the lowest limit of 0.20 lb/MMBtu for units with a heat input ranging between 100 and 1,000 MMBtu/hr.
Based on manufacturer’s data, the diesel emergency black-start generator (5.17 MMBtu/hr) will have emissions of 0.08 lb/MMBtu. Therefore, this fuel burning equipment will be in compliance with the limit of 0.6 lb/MMBtu.
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OAC 252:100-25 (Visible Emissions and Particulates) [Applicable]
No discharge of greater than 20% opacity is allowed except for short-term occurrences which consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours. In no case shall the average of any six-minute period exceed 60% opacity. When burning natural gas, there is very little possibility of exceeding the opacity standards, therefore no periodic observation is necessary.
OAC 252:100-29 (Fugitive Dust) [Applicable]
No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the property line on which the emissions originate in such a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or interfere with the maintenance of air quality standards. Under normal operating conditions, this facility will not cause a problem in this area, therefore it is not necessary to require specific precautions to be taken.
OAC 252:100-31 (Sulfur Compounds) [Applicable]
Part 5 limits sulfur dioxide emissions from new equipment (constructed after July 1, 1972). For gaseous fuels the limit is 0.2 lb/MMBtu heat input, three-hour average. Based on AP-42 (4/00), Section 3.1, Table 3.1-2, maximum SO2 emissions will be 0.0034 lb/MMBtu, which is in compliance. For liquid fuels the limit is 0.8 lb/MMBtu heat input, three-hour average. The diesel emergency black-start generator will have emissions of 2.68 lb/hr based on manufacturer’s data. At a heat input rate of 5.17 MMBtu/hr, emissions will be 0.52 lb/MMBtu, which is in compliance with the limitation.