# NSR Engineering Evaluation

CT Department of Energy and Environmental Protection Bureau of Air Management

Administrative Information Date Application Received : 12/3/2012
SIMS No : 201207376

Applicant Information Company Name : Montville Power LLC Equipment Location : 74 Lathrop Road, Montville, CT 06382 Mailing Address : P.O. Box 1001, Middletown,

CT 06106
Contact Person : Ms. Cynthia Karlic
Contact Title : Regional Environmental Director
Contact Phone Number : 860-343-6962
Contact E-mail: cynthia.karlic@nrgenergy.com

Evaluation Information Date Prepared : 1/30/2013 Prepared By: Mr. James Grillo, jag Permit Information
Permit No : 107-0056 Equipment Description : 42 MW biomass; 82
MW fossil fuel fired boiler

Choose a Permit Type :
Single Unit Multi p le Units Multiple Units

New NSR at a Ma j or N ew NSR at a Major

Source Source New NSR at a Minor N ew NSR at a Minor

Source Source

N on-Minor
Modification at a Major Source Non-Minor N on-Minor

Modification at a Modification at a

Minor Source Minor Source

Minor Modification Minor Modification (p re p aid in full ) (prepaid in full) Minor Modification Minor Modification ( a pp fee p aid onl y) (app fee paid only)

Revision at a Ma j or Revision at a Major

Source Source Revision at a Minor Revision at a Minor

Source Source

Update Fields



### Part I. – Annual Emission Review: Tons Per Year

Pollutant Premises PTE Permit PTE New Premises PTE

CO 2 e N/A 590,103 N/A



### Note: There are no emissions increases fo r any pollutants due to this non-minor
modification.

Part II. – Emissions Summary (TPY) for Major Modification Determination (Attachment C)

Pollutant Actual
Emissions (2 yr avg) PTE as limited by

permit Actual
Emissions
Increase/

Decrease Net
Emissions

Change Significance Levels (Table 3a(k)-1 Increase Equal or greater than Table 3a(k)-1?

CO 2 e >100,000 100,000 YesMontville Power LLC Page 2 of 6



### Part III. – Emissions Standards Re view and Regulatory Authority

a. Regulatory Standard Allowable Rate(s) Basis

CO 2 e: RCSA §22a-174-31 590,103 tpy 15,564 Btu/kWh CEM and 40 CFR Part 98

b. Source subject to: NSPS – 40 CFR Part 60 Subpart A and Db NESHAP – 40 CFR Part 61 Subpart NESHAP – 40 CFR Part 63 Subpart

None

Note: Any source subject to NESHAP Part 63 will be subject, in part, to Part 59 General Provisions
as well.

c. Hazardous Air Pollutant Compliance (RCSA §22a-174-29) (Attachment A): N/A



### Part IV. – Ambient Impact Analysis:

Note Additional Ambient Impact Analysis is no t required for this non-minor modification. The original analysis was reviewed a nd approved on December 4, 2009.



### Part V. – PSD Review

Source is subject to PSD Review: Yes Source netted out of PSD Review (Attachment C1) : No

Note: Source is subject to additional PSD rev iew pursuant to RCSA 22a-174-3a(k)(2)(C). There are no additional PSD pre-construction analysis required for CO 2 e.



### Part VI. – Non-attainment Review: N/A

Part VII. – Control Technology Analysis:

a. BACT/MACT Compliance: Yes

b. BACT/MACT Utilized (Attachment C):

Pollutant BACT/MACT

CO 2 e Energy Efficiency measures
Enforceable limit on heat rate
Annual limit on CO 2 e emissions



### Part VIII. Emission Testing Requirements:

No additional stack testing is required due to this modification.Montville Power LLC Page 3 of 6



### Part IX. – Administrative Criteria Review:

a. Air Quality Status:
Ozone: serious non-attainment
PM2.5: attainment

b. Premises size: <15TPY ≥ 15, <100 TPY ≥ 100 TPY

c. Source size: <15TPY ≥ 15, <100 TPY ≥ 100 TPY

d. The source is a new fossil fuel fired unit that serves a generator with a nameplate capacity of 15 MW or greater or is a new fossil fuel fired boiler or indirect heat exchanger with a maximum heat input capacity of 250 MMBTU or more.: Yes; This unit is already identified as a NOx Budget Program Source.

e. Fee (Attachment D): $5,000.00

f. Signatory responsibilities authorized (Attachment E): Yes

g. Source entered in SIMS P&E Tracking system: Yes

h. Source entered in EMIT Permit Tracking System: Yes

i. Source is in the Coastal Boundary: Yes
Source is in the Coastal Area: Yes

j. Source is on federally recognized Indian lands: No

k. Source is in a Natural Diversity DataBase Area: No

l. Source is Subject to conservation/preservation restrictions: No

m. The source to be permitted combusts coal, waste oil, tires, recycled materials, construction/demolition debris, wood products, biological waste or any other non-fossil fuel that may contain or emit toxic air pollutants: Yes

n. The source to be permitted is major for federal HAPs: Yes

o. The source to be permitted is subject to RCSA §22a-174-22: Yes

Note: Parts IX.d through (o), except for (e), ab ove were addressed in the initial permitting of this source and no changes to the project will affect the determinatio n of above requirements



### Part X. – Maps

Not Applicable, see note above.Montville Power LLC Page 4 of 6



### Part XI. – CGS 22a-6 and 22a-186a Compliance:

-6g - Certified Notice of Application: Yes -6p - Posting of Notice Certification: N/A -6m - Compliance Information (Attachment F): Yes



### Part XII. – Summary:

Montville Power LLC submitted a non-minor modifi cation to NSR permit 107-0056 on December 3, 2012. The NSR permit that was issued on April 6, 2010 contained a requirement to submit an updated Best Available Control Technology (BACT) review if construction did not commence within eighteen (18) months from the date of permit issuance. In Ja nuary 2011 the Department finalized new regulations that require Prevention of Significant Deteriorati on (PSD) review and incorporation of greenhouse gas (GHG) BACT limitations for sources that have greater than 100,000 tons/yr of CO 2 e emission.

On August 30, 2011 Montville Power submitted a time ly updated BACT analysis for the applicable criteria pollutants and a new greenhouse gas PSD/BACT review since construction had not been started
before October 2011.

In a letter dated October 9, 2012, the Department in formed Montville Power that the criteria pollutant BACT review was acceptable and that no further act ion was required by Montville Power concerning the BACT for the criteria pollutants. The letter also stat ed that Montville Power’s proposed limits and energy efficiency improvements were BACT for CO 2 e. (see technical analysis memo and notification letter dated 10/05/12 & 10/09/12, respectively)

A review of the RACT/BACT/LAER Clearinghouse, which included the United States, Canada and Mexico, has not found any additional BACT reviews that have been issued since October 2012 .

Based on the review and approval of the BACT an alysis submitted by Montville Power on August 30, 2011 the following changes have been added to the permit:

 A requirement to submit documentation at least 60-days prior to commencement of commercial operation that the approved energy efficiency methods have been incorporated into the plant

processes.

 An enforceable heat rate of 15,564 Btu/kWhr (g ross) with a 12-month rolling averaging period. Heat input will be monitored by CEMS and the me thodology to be used shall be determined during the initial performance test. The methodology sh all be acceptable to the Department and the permittee.

 An enforceable annual CO 2 e limit of 590,104 tons/yr.

 Require the intallation of a CO 2 CEMS to measure actual annual emissions. The default emission
factors found in 40 CFR Part 98 will be used to calculate CH 4 and N 2 O emissions from the combustion process and then added to the CEMS data to calculate the total annual CO 2 e emissions.Montville Power LLC Page 5 of 6

 Included a requirement to estimate fugitive GHG emissions of SF 6 from the insulated electrical equipment and CH 4 emissions from the natural gas pipeline component on site.

 Require preventative measures for fugitive GHG emissions be included in the O&M plan.

 Require the permittee to track and evaluate the h eat rate of the unit, overall efficiency and CO 2 e emissions over the first year of operation for a ll modes of operationand evaluate the need to revise the operating limits, design/operational variables and averaging periods at that time. A requirement to submit a report of the above information.

The compliance record was reviewed in accordance with the Environmen tal Compliance History Policy. The applicant’s submitted compliance information fo rm was reviewed along with agency records, including the SIMS Enforcement database, for informa tion to evaluate the applicant’s compliance history and the relevance of such history to the activity for which authorization is being sought. Additionally, a review of air program compliance was requested from the Enforcement Section and that response forms a part of this record.

Based on the information submitted by the applicant, this engineering evaluation and the compliance history review, the granting of a permit is recommended for Montville Power LLC.

James Grillo, APCE Date

Approvals:

Supervisor’s Name Supervising APCE

Richard A. Pirolli
Assistant DirectorMontville Power LLC Page 6 of 6



### NSR Engineering Evaluation Attachment Coversheet CT Department of Energy and Environmental Protection Bureau of Air Management

For Attachment:

A. Hazardous Air Pollutant (HAP) Review

B. Ambient Impact Analysis B1. Stack Height Review B2. Screening B3. Refined Modeling B3. Increment Consumption Analysis B4. Additional Analysis (soils, visibility, growth, etc.)

C. Premises Non-attainment Pollutant Summary C1. Netting Analysis C2. 5 year aggregation (Deminimis Rule)

D. Best Available Control Technology (BACT) Review; Maximum Achievable Control Technology (MACT) Review

E. Premises Emissions/Fee Calculations

F. Signatory Responsibility Certification

G. CGS 22a-6m: Compliance History

Findings:

Attachment Findings

D BACT for CO 2 e has been determined to be: Energy Efficiency Measures Enforceable Heat Rate = 15,564 Btu/kWhr (gross) Annual emissions limit of 590,104 tpy
Installation of CO 2 CEM Maintenance and preventive measures to limit SF 6 emissions

E Permit fee of $5,000 is required including $1,750 for GHG BACT review.

G There are no compliance issues preventing this modification from moving
forward.