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 Multiple Units Multiple Units

NNew NSR at a Ma ew NSR at a Major jor 

Source Source

NNew NSR at a Minor ew NSR at a Minor 

Source Source

Non-Minor 

Modification at a 

Major Source

NNon-Minor on-Minor 

Modification at a Modification at a 

Minor Source Minor Source

Minor Modification Minor Modification 

(prepaid in full) (prepaid in full)

Minor Modification Minor Modification 

(app fee paid only) (app fee paid only)

Revision at a Major 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 

CO2e N/A 590,103 N/A 

Note: There are no emissions increases for 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? 

CO2e >100,000 100,000 Yes 
Montville Power LLC Page 2 of 6 

Part III. – Emissions Standards Review and Regulatory Authority 

a. 

Regulatory Standard Allowable Rate(s) Basis 

CO2e: 

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 not required for this non-minor modification. The 

original analysis was reviewed and 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 review pursuant to RCSA 22a-174-3a(k)(2)(C). There are 

no additional PSD pre-construction analysis required for CO2e. 

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

 CO2e Energy Efficiency measures 

 Enforceable limit on heat rate 

 Annual limit on CO2e 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), above were addressed in the initial permitting of 

this source and no changes to the project will affect the determination 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 modification 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 January 2011 the Department finalized new regulations 

that require Prevention of Significant Deterioration (PSD) review and incorporation of greenhouse gas 

(GHG) BACT limitations for sources that have greater than 100,000 tons/yr of CO2e emission. 

On August 30, 2011 Montville Power submitted a timely 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 informed Montville Power that the criteria pollutant 

BACT review was acceptable and that no further action was required by Montville Power concerning the 

BACT for the criteria pollutants. The letter also stated that Montville Power’s proposed limits and energy 

efficiency improvements were BACT for CO2e. (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 analysis 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 (gross) with a 12-month rolling averaging period. 

Heat input will be monitored by CEMS and the methodology to be used shall be determined during 

the initial performance test. The methodology shall be acceptable to the Department and the 

permittee. 

 An enforceable annual CO2e limit of 590,104 tons/yr. 

 Require the intallation of a CO2 CEMS to measure actual annual emissions. The default emission 

factors found in 40 CFR Part 98 will be used to calculate CH4 and N2O emissions from the 

combustion process and then added to the CEMS data to calculate the total annual CO2e emissions. 
Montville Power LLC Page 5 of 6 

 Included a requirement to estimate fugitive GHG emissions of SF6 from the insulated electrical 

equipment and CH4 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 heat rate of the unit, overall efficiency and CO2e 

emissions over the first year of operation for all 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 Environmental Compliance History Policy. 

The applicant’s submitted compliance information form was reviewed along with agency records, 

including the SIMS Enforcement database, for information 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 Director 

 
Montville 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 CO2e 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 CO2 CEM 

 Maintenance and preventive measures to limit SF6 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.