## Comparison of the Most Recent BACT/LAER Determinations for Combustion Turbines by State Air Pollution Control Agencies

Paper #: 42752 AWMA Meeting June 2002

Prepared by Nishat H. Hydari, Adeel A. Yousuf and Dr. Howard M. Ellis, QEP Enviroplan Consulting, 81 Two Br idges Road, Fairfield, NJ 07004



### ABSTRACT

A survey was conducted of state air pollution control agencies to determine the most recent Best Available Control Technology (B ACT) and Lowest Achievable Emission Rate (LAER) determinations for natural gas combustion turbines used in electric power generation facilities. BACT and LAER for both simple cycle and combined cycle modes of turbine operation were evaluated.

Any new major stationary source or major modi fication locating in an area attaining the National Ambient Air Quality Standard (NAAQS ) is subject to Prevention of Significant Deterioration (PSD) requirements and must c onduct an analysis to ensure the application of BACT. Also, any new major stationary so urce or major modification locating in an area not attaining the NAAQS is subject to non-attainment new source review permitting requirements and must conduct an analysis to ensure the application of LAER.

Air pollution permitting agency decisions on BACT/LAER determinations weigh heavily on the most recent BACT/LAER determinations. This most recent data is not always readily available in the US EPA BACT/LAER Clearinghouse. This often results in a delay as applicants and state agencies search for the most recent BACT/LAER determinations.

This paper is intended to a ddress the need for current BACT/LAER determinations used by the state air pollution agencies and private industries.

The study involved a survey of 28 state air pollu tion agencies in the eastern half of the United States. Each state was queried on the most recent BACT/LAER analysis for simple and combined cycle combustion turbin es; compliance averaging time applicable to these determinations; different types of control technologies required by each state agency; the cost per ton of pollutant remove d threshold for economic feasibility; and the total number of BACT/LAER determinations made by each state during the last 12 months for this source group. This inve stigation primarily focused on the following pollutants: PM 10 , NOx, CO, SO 2 and hydrocarbons.The data obtained from this study was statisti cally analyzed to pr epare tables showing comparative analyses between states. Conc lusions on regional differences between the states were made based on the BACT /LAER determinations obtained.



### INTRODUCTION

Any new major stationary source or major modi fication locating in an area attaining the National Ambient Air Quality Standard (NAAQS ) is subject to Prevention of Significant Deterioration (PSD) requirements and must c onduct an analysis to ensure the application of BACT. Also, any new major stationary so urce or major modification locating in an area not attaining the NAAQS is subject to non-attainment new source review permitting requirements and must conduct an analysis to ensure the application of LAER.

The regulatory decisions on BA CT and LAER can have significant economic impacts on a proposed project (e.g. emission limits, allo wable operating conditions). Thus, at the time of project development and the decision to proceed with the project, it is important to have timely information on the BACT a nd LAER determinations that will actually apply to the project.

To provide a central clearinghouse for BACT , LAER and Reasonably Available Control Technology (RACT) determinations throughout th e nation; U.S. EPA has established the RACT/BACT/LAER Clearinghouse. As described on its web page, “the RACT/BACT/LAER Clearinghouse ( RBLC) database contains in formation distilled from early notification submittals and air permits received from State and local air pollution control programs in the United States. Th e RBLC Web site also contains summary information on air pollution emission standards. The data assists State/local agency personnel and private companies in determin ing what types of controls and pollution prevention measures have been applied to an d/or are required for va rious sources and the effectiveness of these technologies.” (1)

The challenge is that early in the planni ng process for a new project, the project developer needs access to the most recen t BACT/LAER determinations to make decisions on project design and to fully evalua te the economic feasibil ity of the project.

The time between the state or local regulatory decision on a BACT/LAER determination and the inclusion of that decision in the RBL C varies by state and can be substantial.

The purpose of this paper is to present the results of a survey conducted of recent BACT/LAER determinations in states in the eas tern half of the U.S. for a major source category - - new large combustion turbines form power generation. We compare these determinations state by state and see whether these determinations are, in fact, included in the RBLC database.

### SURVEY PROCEDURES

The survey questions are given in Table 1. Questions addressed included date of permit issuance, combustion turbine type and si ze, pollutants for which BACT or LAER determinations were made and the determination for each pollutant, compliance averaging time in the determination, required control technology and the cost per ton of pollutant removed threshold for economic feasibility in the determination.

Table 1. Survey questions

Questionnaire on State Agency Experience in BACT and LAER Determinations for Three Most Recent Large Combus tion Turbines Permitted State: Person Providing Response: Date: Email: Phone #: Permit #1 Permit #2 Permit #3 Permit # Date Permit Issued Combustion Turbine Type: (Combined Cycle (CC), Simple Cycle (SC)) Size: (Megawatts (MW) output (a) , MMBTU/hour fuel input) Pollutant: (NOx, CO, SO2, PM10, HC) Type of Determination: (BACT, LAER) Emission Standard: (ppm, lbs/MMBTU, % sulfur fuel, etc.) Compliance Averaging Time: (1 hour, rolling 4-hour, etc.) Required Control Technology: (SCR and/or LNB for NOx, catalytic oxidation for CO, etc.)

Cost per ton of pollutant removed threshold for economic feasibility in the determination (dollars/ton) Note: (a) MW output for combined cycle com bustion turbines is upstream of the HRSG.Table 2 lists the 28 states contacted in this su rvey and those states that responded. In each state, we sought to contact the person in char ge of the control tec hnology determinations in the new source review process. Surveys were sent by e-mail with phone call follow up as needed. 10 of the 28 states provided survey responses th at were sufficiently complete to include in the results. A total of 75 BACT determinations and 16 LAER determinations are included in the survey results.

Table 2. States contacted in survey.

State Status State Status Alabama Complete Mississippi Pending Arkansas Complete New Hampshire Complete Connecticut Complete New Jersey Pending Delaware Complete New York Complete Florida Complete North Carolina Pending Georgia Pending Ohio Pending Illinois Pending Pennsylvania Complete Indiana Complete Rhode Island Pending Kentucky Pending South Carolina Pending Louisiana Pending Tennessee Pending Maine Pending Vermont Pending Maryland Pending Virginia Pending Massachusetts Pending West Virginia Pending Michigan Complete Wisconsin Pending



### RESULTS

Survey results are presented in the following five tables.

Table 3 presents the average BACT determination by state for simple cycle, combined cycle and all combustion turbines for up to fi ve air pollutants. Base d on natural gas firing, for NOx, these average BACT determinations vary from a low of 3.5 to 7.67 ppm. For CO they vary from 7.67 to 22.5 ppm. For SO2, they vary from 0.00145 to 0.0055 lbs/MMBTU, for PM10 they vary from 0.0059 to 0.021 lbs/MMBTU and for HC they vary from 2.2 to 6.7 ppm.

Table 4 presents the average LAER determination by state for simple cycle, combined cycle and all combustion turbines for up to fi ve air pollutants. Base d on natural gas firing, for NOx, these average LAER determinations vary from 2.0 to 3.0 ppm. For CO the determination is 3.0 ppm. For PM10 the dete rmination is 0.0155 lb/MMBtu and for HC they vary from 1.3 to 1.56 ppm.Table 5 presents the compliance averagi ng times included in the BACT and LAER determinations. Based on natural gas firing, for NOx, these compliance averaging times vary from one-hour never to be exceeded to four-hour rolling averages never to be exceeded. For CO they vary from one hour to 24 hour rolling never to be exceeded. For SO2, they vary from one hour to 3 hour ne ver to be exceeded. For PM10, they vary from 1 hour to 24 hour rolling and for HC they vary from one hour to 24 hour rolling.Table 3. The average BACT determination by state for simple cycle, combined cycle and all combustion turbines.

State Pollutant Average BACT Determination Simple Cycle Combustion Turbine Combined Cycle Combustion Turbine All Combustion Turbines # Avg. BACT # Avg. BACT # Avg. BACT Alabama NOx 3 5.0 ppm 3 5.0 ppm CO 3 12.0 ppm 3 12.0 ppm PM10 3 0.0059 lb/mmBtu 3 0.0059 lb/mmBtu VOC 3 3.2 ppm 3 3.2 ppm Arkansas NOx 3 3.5 ppm 3 3.5 ppm CO 2 22.5 ppm 2 22.5 ppm PM10 1 0.013 lb/mmBtu 1 0.013 lb/mmBtu VOC 2 6.7 ppmv 2 6.7 ppmv Connecticut SO2 1 .005 lb/mmBtu 1 .005 lb/mmBtu PM10 1 0.011 lb/mmBtu 1 0.011 lb/mmBtu Delaware NOx 1 9 ppm 1 3 ppm 2 6 ppm CO 1 9 ppm 1 9 ppm 2 9 ppm SO2 1 0.003 lb/mmBtu 1 0.003 lb/mmBtu 2 0.003 lb/mmBtu PM10 1 0.02 lb/mmBtu 1 0.021 lb/mmBtu 2 0.0205 lb/mmBtu Florida NOx 1 9 ppm 2 3 ppm 3 6 ppm CO 1 9 ppm 2 8.5 ppm 3 8.75 ppm SO2 1 0.0056 lb/mmBtu 1 0.0052 lb/mmBtu 2 0.0054 lb/mmBtu VOC 1 2.2 ppm 1 2.2 ppm Indiana NOx 1 9 ppm 2 3.0 ppm 3 6.0 ppm CO 1 25 ppm 2 10.6 ppm 3 17.8 ppm SO2 1 0.0052 lb/mmBtu 2 0.0058 lb/mmBtu 3 0.0055 lb/mmBtu PM10 1 0.0095 lb/mmBtu 2 0.0125 lb/mmBtu 3 0.011 lb/mmBtu Michigan NOx 2 12 ppm 3 3.33 ppm 5 7.67 ppm CO 1 25 ppm 3 5.57 ppm 4 15.29 ppm VOC 3 6.47 ppm 3 6.47 ppm New Hampshire CO 2 15 ppm 2 15 ppm

SO2 2 0.00145 lb/mmBtu 2 0.00145 lb/mmBtu PM10 2 0.0095 lb/mmBtu 2 0.0095 lb/mmBtu New York SO2 2 0.0038 lb/mmBtu 2 0.0038 lb/mmBtu PM10 1 0.021 lb/mmBtu 1 0.021 lb/mmBtu Pennsylvania CO 3 7.67 ppm 3 7.67 ppmTable 4. The average LAER determination by state for simple cycle, combined cycle and all combustion turbines.

State Pollutant Average BACT Determination Simple Cycle Combustion Turbine Combined Cycle Combustion Turbine All Combustion Turbines # Avg. LAER # Avg. LAER # Avg. LAER Connecticut NOx 1 2.0 ppm 1 2.0 ppm New Hampshire NOx 2 2.5 ppm 2 2.5 ppm

New York NOx 2 2 ppm 2 2 ppm CO 2 2 ppm 2 2 ppm PM10 1 0.0155 lb/mmBtu 1 0.0155 lb/mmBtu VOC 2 1.3 ppm 2 1.3 ppm Pennsylvania NOx 3 3 ppm 3 3 ppm VOC 3 1.56 ppm 3 1.56 ppmTable 5. Comparison of compliance averaging times in BACT/LAER determinations.

State Pollutant Compliance Averaging Times Used in BACT/LAER Determinations Alabama NOx 3 hour CO 3 hour Arkansas NOx 24 hour; 3 hour CO 24 hour PM10 3 hour VOC 3 hour Connecticut NOx 3 hour CO 1 hour SO2 3 hour Delaware NOx 1 hour CO 1 hour SO2 1 hour PM10 1 hour Florida NOx 24 hour block; 3 hour CO 24 hour block VOC 3 hour Indiana NOx 24 hour operating; 3 hour block CO 24 hour Michigan NOx Day; 24 hour rolling; 3 hour CO 24 hour rolling; day PM10 Day; 24 hour rolling VOC 24 hour rolling New Hampshire NOx 3 hour block average

CO 1 hour block average SO2 3 hour rolling PM10 1 hour block average New York NOx 3 hour rolling average CO 1 hour average SO2 1 hour; continuous PM10 1 hour; 1 hour average VOC 1 hour; 1 hour average Pennsylvania NOx 1 hour average CO 1 hour average SO2 1 hour average PM10 1 hour average VOC 1 hour averageTable 6 presents the required control technologies in the BACT/LAER determinations.

Table 7 presents the average cost per ton of pollutant removed threshold for economic feasibility in the BACT determination and in the LAER determination separately by state. The average cost per ton varies sign ificantly by pollutant and among states.

Finally, Table 8 provides an indication of how up to date the RLBC Clearinghouse data is. For each state, we show how many of the three most recent BACT/LAER determinations are in the RLBC Clearinghouse data. Overall, 14% of the most recent BACT/LAER determinations in this surv ey were in the RLBC Clearinghouse.



### CONCLUSIONS

BACT and LAER determinations for large combustion turbines vary significantly by state. Similarly, the compliance averaging ti mes also vary significantly. However, both the control technologies selected for BACT and LAER and the average cost per ton of pollutant removed threshold for economic f easibility are more consistent among the

states.

Finally, only 14% of the most recent BACT/L AER determinations in this survey were included in the RLBC database. U.S. EPA c ould help states make better BACT and LAER determinations by speeding up the proces s of incorporating the most recent BACT and LAER determinations in the RLBC database.



### REFERENCES

(1) 40 CFR §52.21, Prevention of Significant Deterioration of Air Quality

. (2) 40 CFR Part 51, Appendix S, Emission Offset Interpretive Ruling.

(3) U.S. EPA web page. http://www. epa.gov/ttncatc1/rblc/htm/bl02.cfm



### KEY WORDS

Combustion Turbines PSD BACT LAER RACT/BACT/LAER ClearinghouseTable 6. Required control technologies in the BACT/LAER determinations.

State Pollutant Required Control Technologies in the BACT/LAER Determinations Alabama NOx Dry Low NOx; SCR CO Good Combustion PM10 Good Combustion VOC Good Combustion Arkansas NOx Dry Low NOx w/SCR CO Catalytic Oxidation SO2 Fuel Sulfur limitation VOC Catalytic Oxidation Connecticut NOx SCR CO Catalytic Oxidation Delaware NOx SCR CO Fuel Sulfur limitation Florida NOx Dry Low NOx; SCR; SONOx CO Combustion control; Catalytic Oxidation SO2 Low sulfur fuels Indiana NOx Dry Low NOx Combustors; SCR CO Good design/operation SO2 Low sulfur fuel PM10 Good combustion VOC Good combustion Michigan NOx DLNB, SCR, Catalytic Oxidation CO DLNB, SCR, Catalytic Oxidation PM10 DLNB, SCR, Catalytic Oxidation VOC DLNB, SCR, Catalytic Oxidation New Hampshire NOx LNB with SCR CO Low NOx burner with good combustion practices SO2 Low sulfur fuels, < 0.05% sulfur PM10 Low sulfur fuels New York NOx SCR, LNB CO Catalytic Oxidation SO2 Low sulfur fuel PM10 Fire only natural gas VOC Catalytic Oxidation Pennsylvania NOx DLNC + SCR CO + VOC DLNC, Oxidation Catalyst

SO2 Low sulfur fuel PM10 NGTable 7. Average cost per ton of pollutant remove d threshold for economic feasibility in the BACT/LAER determination.

State Pollutant BACT Determinations Average Cost per Ton LAER Determinations Average Cost per Ton Arkansas CO/VOC 3,373 NOx 5,108 Connecticut NOx 9,000 Florida NOx 2,606 Michigan NOx $22,000 CO $4,944 PM10 $85,000Table 8. BACT/LAER determinations from this survey that are in U.S. EPA’s RACT/LAER/BACT Clearinghouse Database

State Pollutant BACT /LAER Determination s in This Survey BACT/LAER Determinations from Survey that are in U.S. EPA’s RACT/LAER/BACT Clearinghouse Database Percentage of BACT/LAER Determinations from Survey that are in U.S. EPA’s RACT/LAER/BACT Clearinghouse Database Alabama NOx 3 0 0 CO 3 0 0 PM10 3 0 0 VOC 3 0 0 Arkansas NOx 3 2 66.6 CO 3 2 66.6 PM10 3 2 66.6 VOC 3 2 66.6 Connecticut NOx 1 1 100 SO2 1 1 100 PM10 1 1 100 Delaware NOx 2 0 0 CO 2 0 0 SO2 2 0 0 VOC 2 0 0 Florida NOx 3 0 0 CO 3 0 0 SO2 2 0 0 VOC 1 0 0 Indiana NOx 3 1 33.3 CO 3 1 33.3 SO2 3 1 33.3 VOC 3 1 33.3 Michigan NOx 5 0 0 CO 5 0 0 PM10 5 0 0 VOC 5 0 0 New Hampshire NOx 2 0 0

CO 2 0 0 SO2 2 0 0 PM10 2 0 0 New York NOx 2 0 0 CO 2 0 0 SO2 2 0 0 PM10 2 0 0 VOC 2 0 0 Pennsylvania NOx 3 0 0 CO 3 0 0 SO2 3 0 0 PM10 3 0 0 VOC 3 0 0