MATEP LP
PSD Fact Sheet
July 1, 2016
Page 30 of 30
Prevention of Significant Deterioration Permit Fact Sheet
July 1, 2016
MATEP LP
474 Brookline Avenue
Boston, MA 02215
MATEP LP’s 14.4 MW Combined Heat and Power Project
Transmittal No. X259947
Application No. NE-14-013
TABLE OF CONTENTS
I. General Information 3
II. Project Location 4
III. Proposed Project 4
IV. PSD Program Applicability and Review 6
V. PSD Applicability 7
VI. BACT Analysis 9
VII. Monitoring and Testing 16
VIII. Impact Analysis Based on Modeling 16
IX. Mass Based Emission Limits 23
X. Environmental Justice 24
XI. National Historic Preservation Act, Endangered Species Act,
Tribal Consultation 26
XII. Comment Period, Hearings and Procedures for Final Decision 28
XIII. MassDEP Contacts 29
APPENDIX A – Federal Land Manager Consultation 30
I. General Information
Name of Source: Medical Area Total Energy Plant - Combined Heat and Power Facility Upgrade Project
Location: Boston, Massachusetts
Applicant’s Name and Address: MATEP Limited Partnership (MATEP LP)
474 Brookline Avenue
Boston, MA 02215
Application Prepared By: Epsilon Associates, Inc.
3 Clock Tower Place, Suite 250
Maynard, MA 01754
Prevention of Significant
Deterioration/Major Comprehensive
Plan Application
Transmittal Number: X259947
Application Number: NE-14-013
Massachusetts Department of
Environmental Protection (MassDEP)
MassDEP Contact: Edward J. Braczyk
MassDEP Northeast Regional Office
205B Lowell Street
Wilmington, MA 01887
(978) 694-3200
On August 26, 2014, MATEP Limited Partnership (MATEP LP or Applicant or Permittee) submitted an initial Application to MassDEP requesting a Prevention of Significant Deterioration (PSD) Permit and a 310 Code of Massachusetts Regulations (CMR) 7.02 Major Comprehensive Plan Application Approval (Plan Approval) for a new 14.4 megawatt (MW) combined heat and power (CHP) unit (Project), which will combust natural gas as a primary fuel and ultra low sulfur diesel (ULSD) as a back-up fuel, designated CTG-3/HRSG-3000. This unit will be located at the existing Medical Area Total Energy Plant (MATEP or Facility), 474 Brookline Avenue in Boston Massachusetts. On September 11, 2015, MassDEP issued a Technical Deficiency Letter upon completing a preliminary review of MATEP LP’s major Comprehensive Plan Application. On October 1, 2015, MATEP submitted additional information to address the deficient items that are outlined in the technical deficiency letter. Beginning on November 3, 2015 and on various subsequent dates, the Applicant submitted letters with supplemental technical information addressing the technical deficiency letter including start-up and shutdown values for PM2.5, while firing natural gas and ULSD, and the use of clean fuels. These submittals constitute amendments to the Application, and MassDEP is treating them as such.
Based on all submittals, MassDEP has concluded that the Permittee’s PSD Application is complete and provides the necessary information showing that the Project meets federal PSD regulations. The Permittee’s supplemental technical Project information is part of the official record for this Fact Sheet and the PSD Permit. After reviewing the August 26, 2014 Application and all of the additional information, MassDEP prepared a Draft Fact Sheet and Draft PSD Permit and issued those draft documents for a 30 day public comment period as required by the PSD Delegation Agreement and 40 CFR Part 124 – Procedures for Decision Making. After consideration of comments received during the public hearing and public comment period and supplemental information, MassDEP is issuing both this PSD Fact Sheet and PSD Permit together with a Response to Comments (RTC) document.
The Project is also subject to the MassDEP Plan Approval and Emission Limitations requirements under 310 CMR 7.02. MassDEP is concurrently issuing the Plan Approval and the PSD Permit. The Plan Approval regulates all pollutants emitted by the Project, including those Criteria Pollutants that triggered PSD review and are regulated under the PSD Permit. MATEP LP must ensure that its Project complies with the federal PSD Permit and MassDEP’s Plan Approval, as well as other applicable federal and state requirements.
II. Project Location
The Project is located in an urban area at 474 Brookline Avenue in Boston, Massachusetts, where the existing MATEP Combined Heat and Power Plant is operating to generate electricity and steam for the medical area facilities such as the Dana-Farber Cancer Institute, Joslin Diabetes Center, and Boston Children’s Hospital. The Project location is classified as either “attainment” or “unclassifiable” with respect to the National Ambient Air Quality Standards (NAAQS) for sulfur dioxide (SO2), nitrogen dioxide (NO2), carbon monoxide (CO), particulate matter with diameters less than 10 microns (PM10) and 2.5 microns (PM2.5) and lead. Therefore, the Project may be subject to PSD review for these pollutants.
III. Proposed Project
MATEP LP currently operates two combustion turbine generators with HRSGs (CHP units). The Project consists of a third CHP unit, a 14.4 MW electric power output-rated Solar Titan 130 combustion turbine generator (CTG-3), with natural gas as the primary fuel and ultra low sulfur diesel (ULSD) as backup fuel. Combustion turbine exhaust gases will pass through a heat recovery steam generator (HRSG-300) equipped with a natural gas fired duct burner rated at 38.8 million Btu per hour (mmBtu/hr) maximum fuel input rate. The combustion turbine will feature a Dry Low NOx (DLN) combustor for natural gas and ULSD. The HRSG exhaust will be equipped with a selective catalytic reduction (SCR) system and an oxidation catalyst for post-combustion control of NOx and CO, respectively. CTG-3/HRSG-300 will be housed entirely within the existing Facility.
MATEP LP has requested, based upon a review of Best Available Control Technology (BACT) for Clean Fuels, that the proposed turbine be permitted for year-round operation on natural gas with ultra low sulfur distillate (ULSD) to be used as a backup fuel for up to 720 hours per
12-month rolling period, when natural gas is not available or as stipulated in the Special Conditions section of the PSD Permit.
The Facility currently houses several heat and power generating emission units identified in Table 1 below:
Table 1. Existing Emission Units at Facility /EU# / Description of EU / EU Design Capacity /
PSG-1 / Victory Energy Type O Boiler / 214 mmBtu/hr (gas)
205 mmBtu/hr (oil)
PSG-2 / Riley Boiler No. 2 / 244 mmBtu/hr
PSG-3 / Riley Boiler No. 3 / 244 mmBtu/hr
Zurn-1 / Zurn Afterburner and HRSG No. 1 / 225 mmBtu/hr
Zurn-2 / Zurn Afterburner and HRSG No. 2 / 225 mmBtu/hr
DEG-1 / Mirrlees Diesel Engine Generator No. 1 / 63.8 mmBtu/hr
DEG-2 / Mirrlees Diesel Engine Generator No. 2 / 63.8 mmBtu/hr
DEG-3 / Mirrlees Diesel Engine Generator No. 3 / 63.8 mmBtu/hr
DEG-4 / Mirrlees Diesel Engine Generator No. 4 / 63.8 mmBtu/hr
DEG-5 / Mirrlees Diesel Engine Generator No. 5 / 63.8 mmBtu/hr
DEG-6 / Mirrlees Diesel Engine Generator No. 6 / 63.8 mmBtu/hr
CTG-1 / Alstom Gas Combustion Turbine No. 1 / 152.6 mmBtu/hr
CTG-2 / Alstom Gas Combustion Turbine No. 2 / 152.6 mmBtu/hr
HRSG-100 / ERI HRSG No. 1 serving CTG-1 / 75 mmBtu/hr
HRSG-200 / ERI HRSG No. 2 serving CTG-2 / 75 mmBtu/hr
EDG-1 / 210 KW Emergency Diesel Generator / 2.94 mmBtu/hr
EDG-2 / 410 KW Emergency Diesel Generator / 5.47 mmBtu/hr
Table 1 Key:
EU = emission unit
HRSG= heat recovery steam generator
DEG = diesel engine generator
CTG = combustion turbine generator
EDG = emergency diesel generator
PSG = pressure steam generator
mmBtu/hr = million Btu per hour
KW = kilowatt
No. = number
IV. PSD Program Applicability and Review
MassDEP administers the PSD program in accordance with the provisions of the April 11, 2011 PSD Delegation Agreement between MassDEP and EPA which states that MassDEP agrees to implement and enforce the federal PSD regulations as found in 40 CFR 52.21 and 40 CFR Part 124 regarding permit issuance, modification and appeals.
The PSD regulations at 40 CFR 52.21 require that a major new stationary source of a regulated New Source Review (NSR) pollutant, or a major modification with respect to a regulated NSR pollutant, undergo a PSD review and that a PSD Permit be granted before commencement of construction, except with respect to a project located in a nonattainment area for the particular pollutant.
40 CFR 52.21(b)(1) of the federal PSD regulations defines a “major stationary source” as either (a) any of 28 designated stationary source categories with potential emissions of 100 tons per year (tpy) or more of any regulated NSR pollutant, or (b) any other stationary source with potential emissions of 250 tpy or more of any regulated NSR pollutant. MATEP is an existing major stationary source as defined by source category and emission thresholds.
In addition, a project at an existing major stationary source is subject to PSD review if the Project would result in a significant emissions increase and a significant net emissions increase of a regulated NSR pollutant.
The Project will result in a significant emissions increase and a significant net emissions increase for PM10 and PM2.5. Therefore, the project is subject to PSD review as a major modification.
If a project is subject to the PSD program, the owner or operator must apply for and obtain a PSD Permit that meets regulatory requirements including:
· Best Available Control Technology (BACT) requiring sources to minimize emissions to the greatest extent practical;
· An ambient air quality analysis to ensure that the emission increases do not cause or contribute to a violation of any applicable PSD increments or NAAQS;
· An additional impact analysis to determine direct and indirect effects of the proposed source on industrial growth in the area, soil, vegetation and visibility; and
· Public comment including an opportunity for a public hearing.
Since potential greenhouse gas (GHG) emissions from the project will exceed 75,000 tpy, GHG emissions must also be included in the determination of Best Available Control Technology (BACT).
V. PSD Applicability
The existing Facility includes fossil-fuel boilers totaling more than 250 million Btu per hour heat input and has potential emissions of CO, NOx and SO2 each greater than 100 tons per year. Therefore, it is considered a major stationary source, as defined pursuant to 40 CFR Part 52, section 52.21(b)(1).
The Project is a major modification as defined pursuant to 40 CFR Part 52, section 52.21(b)(2). Potential emissions from the proposed CHP equipment are significant for three different PSD pollutants: PM10, PM2.5 and GHG. Table 2 shows potential emissions from the proposed new equipment at the site relative to the PSD significance thresholds.
The emissions from the Project are compared to the PSD thresholds in Table 2 below:
Table 2Project Potential to Emit /
Pollutant / Project Potential to Emit (in tpy) / PSD Significant Emission Rate
(in tpy) / PSD Review Applies? /
NOx / 7.79 / 40 / No
CO / 5.84 / 100 / No
VOC / 2.5 / 40 / No
PM / 18.8 / 25 / No
PM10 / 18.81 / 15 / Yes3
PM2.5 / 18.81 / 10 / Yes3
SO2 / 2.56 / 40 / No
GHG as CO2e2 / 108,500 / 75,000 / Yes3
Lead / 0.1 / 0.6 / No
Fluorides / Negligible / 3 / No
Sulfuric Acid Mist / 2.55 / 7 / No
Hydrogen Sulfide / None expected / 10 / No
Total reduced sulfur / None expected / 10 / No
Reduced sulfur compounds / None expected / 10 / No
Table 2 Notes:
1The projected annual emissions of PM10 and PM2.5 have been calculated based on worst case conditions. The worst case assumption for projected annual emissions for PM2.5 is that all particulate matter emitted is PM2.5. The worst case assumption for projected annual emissions for PM10 is that all particulate matter emitted is PM10.
2GHG emissions are expressed in terms of CO2 equivalent emissions (CO2e).
3 The proposed project exceeds the PSD significance thresholds for PM10, PM2.5.and GHG as CO2e. As such, the PSD permit will address these pollutants.
Table 2 Key:
CT = Combustion Turbine
tpy = tons per year
NOx = Nitrogen Oxides
CO = Carbon Monoxide
VOC = Volatile Organic Compounds
SO2 = Sulfur Dioxide
PM10 = Particulate Matter less than or equal to 10 microns in diameter
PM2.5 = Particulate Matter less than or equal to 2.5 microns in diameter
H2SO4 = Sulfuric Acid
Pb = Lead
GHG = Greenhouse Gases
CO2e = Greenhouse Gases expressed as Carbon Dioxide equivalent and calculated by multiplying each of the six greenhouse gases (Carbon Dioxide, Nitrous Oxide, methane, Hydrofluorocarbons, Perfluorocarbons, Sulfur Hexafluoride) mass amount of emissions, in tons per year, by the gas’s associated global warming potential published at Table A-1 of 40 CFR Part98, Subpart A and summing the six resultant values.
VI. BACT Analysis
Pursuant to 40 CF R 52.21(j)(3), the Project is required to comply with BACT for the pollutants PM10, PM2.5 and GHG emitted from the new combustion turbine and duct burner.
BACT is defined as, “an emissions limitation ... based on the maximum degree of reduction for each pollutant subject to regulation under [the Clean Air] Act which would be emitted from any proposed major stationary source or major modification which the Administrator, on a case-by-case basis, taking into account energy, environmental, and economic impacts and other costs, determines is achievable for such source or modification through application of production processes or available methods, systems and techniques … for control of such pollutant.” 40 CFR 52.21(b)(12); Clean Air Act (CAA) 169(3).
BACT determinations under PSD review must follow the following five step “top-down” methodology as outlined in several EPA policy memoranda.
1. Identify all control technologies. Identify all possible control options, including inherently lower emitting processes and practices, add-on control equipment, or combination of inherently lower emitting processes and practices and add-on control equipment.
2. Eliminate technically infeasible options. Eliminate technically infeasible options based on physical, chemical and engineering principles.
3. Rank remaining control technologies by control effectiveness. Rank the remaining control options by control effectiveness, expected emission reduction energy impacts, environmental impacts, and economic impacts.
4. Evaluate most effective controls and document results. Determine the economic, energy and environmental impacts of the control technology on a case-by-case basis.