Permit Summary – Construction of a New Combined-Cycle Power Plant 

By Live Oaks Company in Sterling , GA 

Project Description

Construct and operate a combustion turbine combined-cycle power plant. The project 

will generate approximately 600 megawatts (MW) of power. The single power block will 

be fired exclusively with natural gas, and will consist of two combustion turbines, each 

with a nominal power output of 200 MW; two heat recovery steam generators (HRSGs) 

with supplemental firing; and one steam turbine with a nominal output of 200 MW. 

Relevant PSD/BACT Permit Conditions

A. Overall Emission Limits (each combustion turbine and its paired duct burner) 

 NOx – 87 tons during any 12-month period 

 CO – 208 tons during any 12-month period 

B. Authorized Fuels 

 Only pipeline quality natural gas shall be fired in each combustion turbine and its 

paired duct burner, and the sulfur content of the natural gas shall not exceed 0.5 

gr/100 scf. This is BACT for PM10 and SO2. 

 Only pipeline quality natural gas shall be fired in the in the fuel heater, and the 

sulfur content of the natural gas shall not exceed 0.5 gr/100 scf. 

 Only ultra low sulfur diesel fuel shall be fired in the emergency generator and the 

firewater pump. 

C. Technology Requirements 

 Dry low NOx combustors and Selective Catalytic Reduction on each combustion 

turbine and its paired duct burner (BACT for NOx). 

 Catalytic oxidation on each combustion turbine and its paired duct burner (BACT 

for CO and VOC). 

 
D. Emission Limits 

Pollutant Operation Emission Limit 

NOx Each combustion turbine and its 

paired duct burner 

15 ppmvd 

0.43 lb/MW-hr, 30-day 

rolling average 

NOx Each combustion turbine and its 

paired duct burner 

2.5 ppmvd, 3-hour rolling 

average 

SO2 Each combustion turbine and its 

paired duct burner 

0.9 lb/MW-hr 

CO Each combustion turbine and its 

paired duct burner 

3.2 ppmvd, 3-hour rolling 

average while duct 

burner is being fired 

CO Each combustion turbine and its 

paired duct burner 

2.0 ppmvd, 3-hour rolling 

average while duct 

burner is not being fired 

VOC Each combustion turbine and its 

paired duct burner 

2.0 ppmvd, 3-hour rolling 

average 

Opacity Each combustion turbine and its 

paired duct burner 

Less than 40% 
Initial Topics for the Applicant and Regulatory Authority to Consider for Energy 

Efficiency Evaluations in PSD Permit Applications for a Natural Gas Fired Combined 

Cycle Power Plant 

A. Combustion Air Preheat 

 Are opportunities available to use a waste heat stream to preheat the combustion 

air prior to the combustion turbines? Can the steam exhaust from the recovery 

steam generators be used for this purpose? 

 Are any waste heat streams available from existing facilities located near the 

power plant? 

B. Further Use of Steam from the Recovery Steam Generator 

 Is there a nearby off-site use for the steam from the recovery steam generator? 

While this will not reduce the GHG emissions at the power plant, reduced fuel 

consumption could be realized at the off-site facility. 

 Does the facility design incorporate an economizer on the steam boiler to recover 

heat for preheating the boiler water? 

 Does the boiler design include a heat exchanger to recover waste heat from the 

boiler blowdown? 

C. Continuous Excess Air Monitoring and Control 

 Does the power plant design include monitoring and control of the combustion air 

levels, such as an oxygen monitor in the heater stack and controls on the 

combustion air dampers? 

D. Turbine Efficiency 

 Does the turbine design incorporate the highest thermal efficiency available? 

 What tradeoffs have been identified if other turbine designs have been selected? 

E. Combustion Chamber Design 

 Does the combustion chamber incorporate the latest designs to optimize fuel 

burning and mixing of fuel and air? 

 What combustion control options (e.g., combustion/load management software) 

were considered to improve thermal efficiency? 
F. Insulating Materials 

 Does the boiler design incorporate refractory materials that provide the highest 

available insulating capacity? 

 Does the plant design include the use of insulating materials around the outer 

shell of the boiler and exposed steam pipes? 

G. Energy Efficiency Improvements in Facility Operations 

 Does the facility design incorporate high efficiency motors, fans, etc.? 

 If compressed air is used at the plant, has a comprehensive maintenance plan 

been developed for the compressed air system? 

 Does the facility design incorporate energy efficient lighting systems and 

automated lighting controls? 

 Can alternative energy sources such as solar panels be used to supply a portion 

of the plant’s electricity needs? 

 In general, what energy conservation measures were incorporated into the plant 

design?