Russell Biomass, LLC50 MW Biomass-fired Power Plant
Plan # 1-P-05-046; Trans. # W067535Approval to Construct
Page 1 of 56
December30, 2008
Mr. James M. Ramsey, Manager
Russell Biomass, LLC
52 Dexter Road
Lexington, MA 02421Re: Regulation 310 CMR 7.02(5)(a)
Russell Biomass, LLC
50 MW Biomass Fueled Power Plant
Application #1-P-05-046
Transmission # W067535
Conditional Approval
Dear Mr. Ramsey:
On October 3, 2005, the Department of Environmental Protection, Bureau of Waste Prevention, Western Regional Office (“MassDEP”) received a Major Comprehensive Plan Application from Russell Biomass, LLC, 52 Dexter Road Lexington, Massachusetts (“Russell Biomass”) for the construction and operation of a 50 megawatt (MW) (nominal net output) biomass-fired power plant at the former site of Westfield Paper Co. on Station Road in Russell, MA. A revised plan application addressing the possible use of an advanced stoker design was submitted on April 13, 2007. Additional supplemental information was received on June 16, 2006, July 16, 2007, December 19, 2007, January 24, 2008, November 7, 2008, November 13, 2008 and December 9, 2008.
The plans bear the seal and signature of Michael T. Lannan, Massachusetts Registered Professional Engineer No. 45607.
In accordance with the Massachusetts Environmental Policy Act (MEPA), Russell Biomass submitted an Expanded Environmental Notification Form on September 15, 2005 which was followed by the submission of a Draft Environmental Impact Report and Notice of Project Change to the Executive Office of Energy and Environmental Affairs on June 29, 2007 (EOEEA No. 13635). Russell Biomass submitted a Final Environmental Impact Report on February 15, 2008. The Secretary of Energy and Environmental Affairs certified the Final Environmental Impact Report on March 28, 2008.
This Conditional Approval letter includes the 310 CMR 7.02(5)(a)Comprehensive Plan Approval and the 310 CMR 7.00: APPENDIX A: Emission Offsets and Nonattainment Review analysis. These actions were subject to a public comment period and a public hearing as specified in the Commonwealth’s Air Pollution Control Regulations 310 CMR 7.00: Appendix A. A Notice of Public Comment and Notice of Public Hearing was published in the Westfield Evening News on May 28 and 29, 2008.During the thirty (30) day public comment period, written comments were received. A Public Hearing was held at Westfield State College on June 25, 2008. Oral and written testimony was received at this hearing.
Table Of Contents
I. List of Abbreviations
II. Overview
III.Project Description
A. Biomass Boiler
1. BFB Boiler
2. Stoker Boiler
B. Emergency Generator
C. Cooling Tower
D. Types of Clean Wood Fuel
E. Wood Fuel Storage
F. Fugitive Dust
IV. Source Emissions
V. Regulatory Applicability
A. MassDEP Plan Approval Regulations
B. National Ambient Air Quality Standards (NAAQS)
C. MassDEP Noise Regulations
D. Nonattainment New Source Review (NSR)
E. New Source Performance Standards (NSPS)
F. National Emission Standards for Hazardous Air Pollutants/Case-By-Case Maximum Achievable Control Technology Analysis
VI. Best Available Control Technology (BACT) and Lowest Achievable Emission Rate (LAER) Analysis
A. Boiler NOx BACT/LAER
1. BFB Boiler
2. Vibrating-Grate Stoker Boiler
B. Boiler CO BACT
1. BFB Boiler
2. Vibrating-Grate Stoke Boiler
C. Boiler Volatile Organic Compounds BACT
1. BFB Boiler
2. Vibrating-Grate Stoker Boiler
D. Boiler Particulate Matter and Particulate Matter Less than or equal to 10 Microns BACT
1. BFB Boiler
2. Vibrating-Grate Stoker Boiler
E. Boiler PM2.5 BACT
F. Boiler Sulfur Dioxide BACT
G. Boiler Ammonia BACT
H. Cooling Tower- Particulate Matter and Particulate Matter Less than or equal to 10 Microns BACT
VII. Maximum Achievable Control Technology (MACT) Analysis
VIII. Ambient Air Quality Impact Analysis
A. Type of Model
B. Meteorological Data
C. Selected Air Quality Monitors
D. Background Air Quality
E. GEP Stack Height Analysis
F. Air Dispersion Modeling Results
1. BFB Boiler Criteria Air Pollutant Impacts
2. Stoker Boiler Criteria Air Pollutant Impacts
3. Emergency Generator Criteria Air Pollutant Impacts
4. Conclusion
G. Air Toxics Analysis
IX. Noise Impact Analysis
A. Measurement of Existing Ambient Sound Levels
B. Instrumentation
C. Existing Ambient Sound Level Results
D. Measurements of Future Sound Levels
E. Noise Mitigation Controls
X. Section 61 Findings
XI. Provisions of Approval
I. List of Abbreviations
AALs - Allowable Ambient Limits
ACFM – Actual Cubic Feet Per Minute
AFB - Air Force Base
ANSI – American National Standards Institute
ASTM – American Standard Test Method
BACT – Best Available Control Technology
BFB - Bubbling Fluidized Bed
CAIR - Clean Air Interstate Rule
CEMS – Continuous Emission Monitoring System
CFR – Code of Federal Regulations
CMR- Code of Massachusetts Regulations
CMS - Continuous Monitoring Systems
CO - Carbon Monoxide
CPA –Comprehensive Plan Application
DAHS – Data Acquisition and Handling System
dBA - A-weighted decibels
EENF - Expanded Environmental Notification Form
EIR- Environmental Impact Report
EOEEA -Executive Office of Energy and Environmental Affairs
EPA – Environmental Protection Agency
ERCs - Emission Reduction Credits
ESP - Electrostatic Precipitator
GEP - Good Engineering Practice
GGH - Gas-To-Gas Heat Exchanger
HAPs -Hazardous Air Pollutants
HCl – Hydrogen Chloride
Hg -Mercury
lb/MMBtu – pound per million Btu
kW - Kilowatts
LAER – Lowest Achievable Emission Rate
MACT - Maximum Achievable Control Technology
MEPA – Massachusetts Environmental Policy Act
MMBtu/hr - million Btu per hour
MW -Megawatt
NAAQS - National Ambient Air Quality Standards
NESHAP - National Emission Standards for Hazardous Air Pollutants
NH3 - Ammonia
NH DES – New Hampshire Department of Environmental Services
NIST - National Institute of Standards and Technology
NO2 - Nitrogen Dioxide
NOx- nitrogen oxides
NPDES - National Pollution Discharge Elimination System
NSA –Noise Sensitive Areas
NSPS - New Source Performance Standards
NSR - New Source Review
O3 -Ozone
Pb - Lead
PL 1 – Property Line 1
II. Overview
Russell Biomass is proposing to construct a 50 MW (nominal net output) biomass-fired power plant at the former Westfield Paper Co. on Station Road in Russell. The boiler will burn approximately 510,000 tons per year of wood fuel (as defined in 310 CMR 7.00) in chip form as its primary fuel with B100 biodiesel as a supplemental fuel used for startups, flame stabilization and as flue gas reheat for the regenerative selective catalytic reduction (RSCR) system.
The facility will consist of a complete fuel receiving and handling system, either a 740 million British thermal units (Btu) per hour bubbling fluidized bed (BFB) boiler or a 740 million Btu per hour water-cooled, vibrating-grate stoker fired boiler (stoker) and associated air pollution control devices, a single condensing turbine, a mechanical draft evaporative cooling tower, bottom ash and fly ash handling and storage systems and a 400 kilowatt (536 horsepower) B100 biodiesel-fired emergency generator.
The proposed plant is classified as a “major source” since there is a potential for air emissions to be above the major source thresholds for nitrogen oxides (NOx), carbon monoxide (CO), and Hazardous Air Pollutants (HAPs). Because the plant is classified as a major source for NOx, it is subject to New Source Review (NSR) and the Emission Offset and Nonattainment Review requirements of 310 CMR 7.00, Appendix A. The plant is not subject to the requirements of the Prevention of Significant Deterioration (PSD) regulations as set forth in 40 CFR Part 52.21.
III.Project Description
A. Biomass Boiler
Two boiler designs have been submitted for approval at the Russell Biomass facility. The first design consists of a Babcock and Wilcox, or equivalent, BFB boiler. The second design is a Riley Power, Inc., or equivalent, stoker boiler. Under either design, the facility will generate 50 MW of electricity from a steam turbine generator powered by a maximum 740 million Btu per hour (MMBtu/hr) boiler fueled with only clean wood (chips). B100 biodiesel fuel will be fired in the boiler during cold and hot startups and for flame stabilization during operation with wood fuel. The maximum biodiesel heat input is 300 MMBtu/hr and its usage will be limited to 400 hours in any 12 consecutive month period.
1. BFB Boiler
The exhaust gases from the BFB boiler will be vented to a SP Environmental, Amerair, Dustex, or equivalent, pulse jet type fabric filter collector (or “baghouse”) for particulate matter and metallic HAPs control and a Babcock and Wilcox, or equivalent, selective catalytic reduction (SCR) system for NOx control. The SCR system is located downstream of the fabric filter collector to minimize the blinding effect of dust and alkali metals on the SCR’s reduction catalyst. Due to the location of the SCR system, the flue gas must be re-heated to a minimum temperature of 500F, which is required by the catalyst for optimum NOx removal efficiency. The reheat of flue gases will be accomplished by using a gas-to-gas heat exchanger (GGH) and a steam coil gas heater (SCGH). The ammonia, which serves as the reagent for the SCR system, will be pumped through an electric heater vaporizer and will be injected at the inlet dampers to the SCR system. An ammonia control system is provided to accurately inject the correct stoichiometric amount of ammonia required to achieve a maximum NOx removal rate while minimizing the amount of ammonia that is exhausted from the system (“ammonia slip”). Emissions of CO and volatile organic compounds (VOCs) will be controlled by the use of good combustion practices.
2. Stoker Boiler
The exhaust gases from the stoker boiler will pass through a Process Equipment Inc., or equivalent, multi-cyclone, followed by a Clyde Bergemann EEC Model: 27-16-5x10.5x36, or equivalent, cold-side electrostatic precipitator (ESP) for control of particulate matter and metallic HAPs. Following the particle control devices, the gas will pass through a two-layer RSCR system to minimize NOx and CO emissions since the RSCR will contain both a reduction and an oxidation catalyst. The RSCR system will be comprised of six (6) -canisters that will be placed downstream of the ESP in order to minimize the blinding effect of dust and alkali metals on the RSCR’s reduction catalyst. The ammonia, which serves as the reagent for the RSCR system, will be pumped through an electric heater vaporizer and will be injected at the inlet dampers to each canister. An ammonia control system is provided to accurately inject the correct stoichiometric amount of ammonia required to achieve a maximum NOx removal rate while minimizing the ammonia slip. The exhaust gases will be reheated within the RSCR system to bring the catalyst temperature into the range for reaction. This exhaust gas reheat will be through the use of a 4.6 MMBtu/hr B100 biodiesel-fired duct burner and a regenerative ceramic bed that will heat the exhaust gas to 750ºF to increase the overall pollutants removal efficiency of the control device to 76% for NOx and 70% for CO. The B100 biodiesel being fired in the duct burner of the RSCR system is in addition to the B100 biodiesel being fired in the boiler for cold and hot startups and flame stabilization.
The cleaned exhaust gases from both designs will be emitted to the atmosphere through a steel stack that will have a maximum inside diameter of 13 feet at the point of exhaust, a minimum height of 300 feet above ground level and 167 feet above the nearest building rooftop.
B. Emergency Generator
The proposed emergency generator will be a Caterpillar 3456 ATAAC generator set, or equivalent, equipped with a silencer. The generator will supply electrical power in the event of a power outage to the facility burning only B100 biodiesel. It will have a maximum heat input rate of 4.1 MMBtu/hr and a maximum power output of 400 kilowatts (“kW”). The emergency generator will be limited to operating ≤ 300 hours in any consecutive 12-month period.
C. Cooling Tower
The proposed mechanical draft evaporative cooling tower will have three cells, a maximum water circulation rate of 2,400,000 gallons per hour and will be constructed of structural fiberglass. Each cell will be equipped with a mist/drift eliminator capable of achieving a maximum drift rate per cell of 0.0005% to minimize water drift losses and associated particulate matter (PM) and particulate matter with an aerodynamic diameter equal to or less than 10 microns (PM10) emissions. The cooling tower has been designed for a maximum of 7.4 cycles of concentration and a circulating water maximum total dissolved solids concentration of 1840 parts per million by weight.
D. Types of Clean Wood Fuel
There are four categories of wood fuel which will be purchased by Russell Biomass as defined by 310 CMR 7.00.
In order of volume, the following clean wood fuel sources will be used:
- Whole Tree Fuel
- Municipal Wood Fuel
- Stump Grindings
- Pallet Grindings
Whole tree fuel will consist of standing trees cut from either a portion of forestry operation or a portion of land-clearing operations. Trees are cut for either forestry purposes or land-clearing purposes. The expected total volume of whole tree fuel to be purchased will be 250,000-350,000 tons per year.
Municipal wood fuel consists of clean wood collected from either a municipal transfer facility or a private wood yard facility. In both cases, wood is delivered to these yards from various sources, including utility line crews, tree service companies, small land-clearing companies and homeowners. All of the wood is virgin wood. Private wood yards must be specifically permitted to accept any kind of wood which has been treated in any way. Russell Biomass shall not accept any wood from private wood yards which are permitted to accept treated wood. MassDEP has determined that a municipal transfer facility may qualify as a fuel source only if it receives clean wood and is not co-located with a solid waste transfer station. No other municipal transfer facilities can be qualified as wood fuel sources unless they are first approved as such in writing by MassDEP. Russell Biomass shall conduct unannounced visits to all municipal and private wood yards as part of an ongoing fuel quality assurance program. The visits, along with the results of these inspections, shall be documented via reports maintained on-site and made available to MassDEP personnel upon request. The expected total volume of municipal wood fuel to be purchased will be 100,000-150,000 tons per year.
The process of clearing land includes the disposal of stumps since they cannot be buried. Contractors grind their stumps on site and transport the grindings directly to market. The expected total volume of stump grindings to be purchased will be 75,000-150,000 tons per year.
The pallet recycling industry in New England picks up pallets from many locations, grinds the material and sells it to the marketplace. Russell Biomass shall not purchase pallet grindings from a wood waste facility which accepts treated or contaminated wood. The expected total volume of pallet grindings to be purchased will be 25,000-50,000 tons per year.
All suppliers of wood fuel to the facility must sign a contract with Russell Biomass prohibiting any type of treated wood in the fuel supply it delivers to Russell Biomass.
E. Wood Fuel Storage
Russell Biomass is proposing to utilize three truck unloading stations that will unload directly to the ground. Two of the three unloading stations will have the capacity to unload all of the wood which is to be delivered to the plant, with the third station representing back-up unloading capacity. Each unloading station can unload 5 trucks per hour so there will be no trucks waiting offsite. The plant will require approximately 2,000 tons of fuel per day. Front-end loaders will move the material from the unloaders to either the covered 3-day storage area or into one of two outside long-term storage piles. The long-term storage of the wood will be outside in a wood storage yard on an impermeable surface. The wood storage yard measures approximately 300 feet by 700 feet, sufficient to store about 30 days of fuel. The wood will be stored in two separate piles, each no longer than 300 feet long and 45 feet high. The two piles will be constantly rotated with one pile growing while the other pile is being utilized and drawn down. Two piles will be used to better handle the material and control residence time (average 2-3 months), with no wood being kept on site longer than 6 months without being consumed to prevent material degradation, which could result in decomposition odors or dust.
From the outdoor storage pile, the material that has been onsite the longest will then be moved into the covered 3-day storage area (first-in/first-out) which has an A-Frame design with bottom unloading. Within this 3-day storage building, the material will be mixed and conditioned so that a consistent fuel mix is delivered to the boiler. All conveyors will be enclosed as will thefuel processing building.
F. Fugitive Dust
Russell Biomass shall develop and submit for written MassDEP approval a plan to minimize fugitive dust at the site. This plan, at a minimum, shall include the use of a vacuum truck (or equivalent) on a planned schedule to maintain clean roadways. This plan shall also include a methodology for minimizing the dust generation from the movement of the wood chips on the premises.
IV. Source Emissions
The potential emissions from either boiler design are based on the worst case emissions from the boiler burning: 1) clean wood fuel only for 8,760 hours and 2) burning clean wood fuel for 8,360 hours with B100 biodiesel being co-fired for up to 400 hours each year. The duct burner is also assumed to be burning B100 for 8,760 hours. Also included in the potential emissions calculations are the cooling tower and the emergency generator operating with B100 biodiesel for 300 hours per year. The potential emissions are summarized in Table 1 below: