FACT SHEET

FOR

Woodbridge Energy Center 

RIVERSIDE DRIVE, WOODBRIDGE TOWNSHIP 

(MIDDLESEX COUNTY), NEW JERSEY, 07095

Program Interest (PI) Number: 18940 Permit Activity Number: BOP110003

APPLICATION FOR

AIR POLLUTION CONTROL OPERATING PERMIT (TITLE V)

AND

FEDERAL PREVENTION OF SIGNIFICANT DETERIORATION (PSD) OF AIR QUALITY PERMIT

AND

ACID RAIN PERMIT

_______________________ __________________

Yogesh Doshi, Supervisor Bachir Bouzid, Section Chief

Bureau of Air Permits Bureau of Air Permits

Date: May 31, 2012 Date: May 31, 2012

 

 CHRIS CHRISTIE DEPARTMENT of ENVIRONMENTAL PROTECTION BOB MARTIN

 Governor Commissioner

Division of Air Quality

 KIM GUADAGNO Bureau of Air Permits

 Lt. Governor 401 E. State Street, 2nd floor, P.O. Box 420, Mail Code 401-02

Trenton, NJ 08625-0420
Woodbridge Energy Center 2 FACT SHEET

TABLE OF CONTENTS

A. FACILITY AND PROJECT DESCRIPTION 3

B. AIR CONTAMINANT EMISSIONS 3

C. AIR POLLUTION CONTROL TECHNOLOGIES 7

D. APPLICABLE REGULATIONS 17

E. TESTING AND MONITORING REQUIREMENTS 21

F. AIR QUALITY IMPACT ANALYSIS 21

G. ATTACHMENT I 22

Fact Sheet for air dispersion modeling and risk assessment 23
Woodbridge Energy Center 3 FACT SHEET

A. FACILITY AND PROJECT DESCRIPTION

CPV Shore, LLC (CPV) submitted an application on June 14, 2011, for a federal Prevention of 

Significant Deterioration of Air Quality (PSD) permit, a Title V State Operating Permit and an 

Acid Rain permit to construct and operate a new 700 MW facility, Woodbridge Energy Center 

(WEC). WEC will be a combined-cycle power generating facility consisting of two General 

Electric (GE) 207FA.05 combined cycle combustion turbine generators (CTGs), two heat 

recovery steam generators (HRSG) equipped with duct burners, one steam turbine electric 

generator (STG), one 14-cell (2x7 configuration) wet mechanical draft cooling tower, and 

ancillary equipment. WEC will be located at Riverside Drive, Woodbridge Township (Middlesex 

County), New Jersey, 07095.

The CTGs and duct burners will use natural gas as fuel. Each combustion turbine will have a 

maximum rated heat input of 2,307 million British thermal units per hour (MMBtu/hr) at an 

ambient temperature of -80

F, based on higher heating value of fuel (HHV) (not including 

supplemental duct-firing), and a maximum heat input rate of 2,807 MMBtu/hr HHV with 

supplemental duct-firing. The combined maximum hourly electricity generated by the two 

combustion turbines will be 480 MW.

Ancillary equipment will include a 91.6 MMBtu/hr (HHV) auxiliary boiler equipped with low 

NOx burners that will operate on natural gas for 2000 hrs per year or less, one small 9.5 

MMBtu/hr (HHV) natural gas fired fuel gas heater operating for 8760 hrs/yr, a 1500 KW (13.5 

MMBtu/hr HHV) emergency diesel generator, and a 315 HP (2.1 MMBtu/hr HHV) diesel fire 

pump. The emergency diesel generator and fire pump will be operated for 100 hrs per year or 

less, per equipment, and would use ultra low sulfur distillate (ULSD) fuel oil with sulfur content 

of 15 ppm by weight or less. Ancillary equipment will also include storage tanks. 

WEC is situated in close proximity to the Middlesex County Utilities Authority (MCUA) sewage 

treatment plant and will use treated effluent diverted from the MCUA river discharge for noncontact cooling tower makeup. Cooling tower blow down and process wastewater could be 

discharged back into the MCUA.

B. AIR CONTAMINANT EMISSIONS

WEC will be located in Middlesex County which is designated as attainment for National 

Ambient Air Quality Standards (NAAQS) for criteria pollutants i.e. Nitrogen Oxides (NOx), 

Carbon Monoxide (CO), Sulfur Oxides (SO2), Particulate Matter (PM), Particulate Matter less than 10 

microns (PM10), and lead. It is designated as non-attainment for the 8-hour ozone NAAQS and 

Particulate Matter less than 2.5 microns (PM2.5)

Table 1 lists proposed emissions of all criteria pollutants from WEC in pounds per hour (lbs/hr), 

parts per million on dry volume basis at 15% oxygen (ppmdv @ 15% O2), and pounds per 

million British thermal units (lbs/MMBtu). The proposed emission limits from the combustion 

turbines would be achieved after the application of air pollution control technologies that are 

discussed in Section C. 
Woodbridge Energy Center 4 FACT SHEET

TABLE 1

MAXIMUM ALLOWABLE EMISSIONS FOR EACH COMBUSTION TURBINE/HRSG UNIT

(Operating Conditions: 100% load; - 80

F ambient temperature)

(Base load Operations with Supplemental Duct-firing)

Air Contaminant

units

Maximum Allowable Hourly 

Emissions

Natural Gas

Nitrogen Oxides (as NO2)

lbs/hr1

ppmvd @ 15% O2

2

19.8

2.0

Carbon Monoxide (CO)

lbs/hr 

ppmvd @ 15% O2

12.1

2.0

Volatile Organic Compounds (VOCs)3

lbs/hr 

ppmvd @ 15% O2

6.9

2.0

Sulfur Oxides (SO2)

lbs/hr 4.9

Total Suspended Matter (TSP)

lbs/hr 

lbs/MMbtu

8.2

0.0038

Particulate Matter less than 10 microns (PM10)

lbs/hr 

lbs/MMbtu

19.1

0.0084

Particulate Matter less than 2.5 microns (PM2.5)

lbs/hr 

lbs/MMbtu

19.1

0.0084

Ammonia (NH3)

ppmvd @ 15% O2 5.0

CO2e (for Green House Gasses)

 lbs/hr

312,885

NOTES: 1. lbs/hr = Pounds per hour emissions per turbine.

2. ppmvd (@ 15% O2) = parts per million by volume on a dry basis (corrected to 15 percent oxygen).

3. lbs/MMbtu = pounds per million British thermal units
Woodbridge Energy Center 5 FACT SHEET

Table 2 shows the proposed annual emissions of all criteria pollutants in tons per year (tpy) for the 

WEC. The Hazardous Air Pollutant (HAP) emissions from the project are included in Attachment I 

(Fact Sheet of the air dispersion modeling and risk assessment from Bureau of Technical Services).

The applicability threshold for a major PSD of air quality source is equal to or greater than 100 tpy 

of emissions of any criteria pollutant for stationary sources that are one of the 28 named source 

categories in 40 CFR 52.21. WEC is one of the 28 source categories i.e. fossil fuel-fired steam 

electric generating plant of greater than 250 MMBTU/hr heat input. Based on the potential annual 

emissions in Table 2 (given in tons per year), the facility is considered a new major PSD source for 

NOx, CO, PM, PM10, and H2SO4. The facility is also a new major PSD source for Green House

Gases (GHG). The applicability threshold for PSD for GHG emissions is 100,000 tpy of Carbon 

Dioxide equivalent (CO2e) for a new source.

TABLE 2

Facility Potential Emissions, PSD Applicability Thresholds and PSD Applicability 

Air Contaminant Proposed Maximum 

Potential Emissions 

from WEC

(TPY)1

PSD 

Applicability

Threshold 

(TPY)

PSD 

Applicable

(TPY)

NOTES: 1 Maximum potential emission based on the following: 

• Worst case potential to emit calculations are based on 8,760 hours of natural gas-fired combustion turbine 

operation including 356 hours of natural gas-fired start-up/shutdown operation, and 685 hours of natural gasfired duct burning operation. 

• One cooling tower: 8760 hrs per year; 

• Auxiliary boiler: 2,000 hours per year on natural gas, 

• Fuel Gas Fuel heater: 8760 on natural gas

• Limited operation (100 hrs/yr) of emergency diesel fire pump and emergency diesel generator 2 Middlesex County is designated non-attainment for PM2.5. 

According to Table 3, The WEC is subject to Non Attainment New Source review requirements at 

N.J.A.C 7:27-18 (Subchapter 18 Control and Prohibition of Air Pollution from New or Altered 

Sources Affecting Ambient Air Quality (Emission Offset Rules)) for NOx, and VOC. This is 

because the potential emissions of NOx, and VOC which are precursors for ozone, are greater than 

the N.J.A.C 7:27-18 thresholds of 25 tpy. 

Carbon Monoxide (CO) 293.8 100 Yes

Nitrogen Oxides (NOx) 149.4 40 Yes

Sulfur Dioxide (SO2) 33.1 40 No

Particulate Matter (PM/TSP) 55.9 25 Yes

PM10 103.7 15 Yes

2 PM2.5 98.7 N/A N/A

Volatile Organic Compounds (VOC) 33.6 40 No

Lead 0.01 0.6 No

Sulfuric Acid Mist 22.7 7 Yes

Green House Gasses ( CO2e ) 2,073,645 100,000 Yes
Woodbridge Energy Center 6 FACT SHEET

Table 3 also shows that the proposed CO and PM10 emissions from WEC are greater than the 

N.J.A.C 7:27-18 thresholds of 100 tpy. As per N.J.A.C 7:27-18.2(b)2, the facility is required to 

conduct an air quality impact analysis to show that the proposed emissions of NOx, VOC, CO and 

PM10 would not equal or exceed the significant air quality impact level, nor result in a violation of 

an National Ambient Air Quality Standard (NAAQS) and the New Jersey Ambient Air Quality 

Standard (NJAAQS). 

The attached air quality modeling analysis (Section G) shows that the increase in CO, and PM10

emissions would not result in an increase in the ambient concentration of CO and PM10 in an area 

that is attainment for CO and PM10 nor would the ambient concentration of CO or PM10 equal or 

exceed the significant impact levels. 

As mentioned above, WEC is located in Middlesex County which is designated non-attainment 

area for PM2.5. The Department has evaluated the WEC PM2.5 emissions consistent with its 

December 14, 2010 Memorandum of Division of Air Quality “Revised Interim Permitting and 

Modeling Procedures for New or Modified Sources Emitting between less than 100 Tons per Year 

of PM2.5 (Fine Particulate) and Proposing between a 10 – 99 ton per year increase in PM2.5”. 

Based on the guidance outlined in its December 14, 2010 the Department required WEC to 

conduct Air Quality Modeling. The air quality modeling analysis demonstrated that the proposed 

PM2.5 emissions from WEC would not cause or create PM2.5 NAAQS or NJAAQS violations in 

areas designated non-attainment for PM2.5

Table 3: Facility Potential Emissions and Non Attainment New Source Review (N.J.A.C 7:27-18) 

Thresholds and Applicability

Air Contaminant Proposed Maximum 

Potential Emissions 

from WEC

(TPY)1

(N.J.A.C 7:27-18) 

Applicability 

Threshold

(TPY)

N.J.A.C 7:27-18

Applicable

Carbon Monoxide (CO) 293.8 100 Yes

Nitrogen Oxides (NOx) 149.4 25 Yes

Sulfur Dioxide (SO2) 33.1 100 No

Particulate Matter 

(PM/TSP)

55.9 100 No

PM10 103.7 100 Yes

2

PM-2.5 98.7 100 No

Ozone (Volatile 

Organic Compounds)

33.6 25 Yes

NOTES

1. Maximum potential emissions determined using worst case potential to emit calculations are based on the following 

operating scenarios for two turbines and associated duct burners:

• 8,760 hours of natural gas-fired combustion turbine operation which includes up to 356 hours of natural gasfired start-up/shutdown operation, and 685 hours of natural gas-fired duct burning operation. 

• One cooling towers: 8760 hrs per year; 

• Auxiliary boiler: 2,000 hours per year on natural gas;

• Fuel Gas Fuel heater: 8760 on natural gas;

• Limited operation (100 hrs/yr) of emergency diesel fire pump and emergency diesel generator 2 December 14, 2010 Memorandum of Division of Air Quality regarding PM2.5 Permitting and Modeling Procedures.
Woodbridge Energy Center 7 FACT SHEET

The facility is also required to meet State of the Art Control Technology (SOTA) of New Jersey 

Air Pollution Control Regulations (N.J.A.C. 7:27-22.35). SOTA includes performance limits that 

are based on air pollution control technology, pollution prevention methods, and process 

modifications or substitutions that will provide the greatest emission reductions that are 

technologically and economically feasible. Compliance with BACT and LAER requirements also 

satisfies SOTA requirements. 

C. AIR POLLUTION CONTROL TECHNOLOGIES FOR BACT/LAER

Woodbridge Energy Center is subject to federal PSD requirements including evaluation of the Best 

Available Control Technology (BACT) for each PSD affected pollutant (NOx, H2SO4, CO, PM, 

PM10 and GHG). BACT must be applied to control emissions to the maximum degree for each

regulated pollutant taking into account technical feasibility, energy, economics and other 

environmental factors. 

Woodbridge Energy Center is also subject to N.J.A.C.7:27-18 requirements including evaluation 

of Lowest Achievable Emission Rate (LAER) for each non-attainment pollutant (NOx and VOC).

LAER is the most stringent emission limitation contained in the implementation plan of any State 

for a particular source category, or which is achieved in practice by a particular source category, 

whichever is most stringent. 

1. Nitrogen Oxide (NOx) Control Technologies

a. Description of NOx Control Technologies

NOx Control Technologies for Turbines

The two major ways in which NOx is formed in the combustion process are known as fuel NOx 

formation and thermal NOx formation. Fuel NOx is formed when nitrogen and nitrogen 

compounds present in the fuel combine with oxygen present in the combustion zone to form NOx. 

Generally, fuel NOx can be reduced by decreasing the amount of nitrogen in the fuel. Thermal 

NOx is formed when nitrogen from the air in the combustion zone combines with oxygen in the 

combustion zone at high temperature. The rate of formation is proportional to temperature in the 

combustion chamber.

WEC evaluated the following four technologies for controlling NOx emissions from the proposed 

combustion turbines:

1. Selective Catalytic Reduction System (SCR)

Selective catalytic reduction system (SCR) is a process in which ammonia is injected directly into 

the flue gas and then passed over a catalyst to react with NOx, converting the NOx and ammonia to 

nitrogen and water. This reaction normally requires higher temperatures in order to take place. 

However, the insertion of a catalyst into the gas path of the HRSG allows this reaction to take 

place at a lower temperature, within the operating range of the HRSG.

2. Selective Non-Catalytic Reduction (SNCR)

SNCR is another method of post combustion control of NOx emissions. SNCR selectively reduces 

NOx into nitrogen and water vapor by reacting the flue gas with a reagent. The SNCR system is 
Woodbridge Energy Center 8 FACT SHEET

dependent upon the reagent injection location and temperature to achieve proper reagent/flue gas 

mixing for optimum NOx reduction. SNCR systems require a fairly narrow temperature range for 

reagent injection in order to achieve a specific NOx removal efficiency. The optimum temperature 

range for ammonia injection is 1,500° to 1,900°F. The NOx removal efficiency of an SNCR 

system decreases rapidly at temperatures outside the optimum temperature window. Operation 

below this temperature window results in excessive ammonia emissions, also referred to as 

ammonia slip. Operation above the temperature window results in increased NOx emissions. 

3. Dry Low-NOx Combustors

Dry Low-NOx (lean pre-mix) combustors stage fuel combustion, lowering flame temperatures, 

thus reducing the amount of thermal NOx formation without the use of diluents such as steam or 

water.

4. Lean Burn Combustion

Typical gas turbines are designed to operate at a nearly stoichiometric ratio of fuel and in the 

combustion zone, with additional air introduced downstream. This is the point where the highest 

combustion temperature and quickest combustion reactions (including NOx formation) occur. 

Fuel-to-air ratios below stoichiometric are referred to as fuel-lean mixtures (i.e., excess air in the 

combustion chamber). The rate of NOx production falls off dramatically as the flame temperature 

decreases. 

Thus, very lean, dry combustors can be used to control emissions by reducing thermal NOx 

formation within the combustion chamber. The lean combustors typically are two-staged premixed 

combustors designed for use with natural gas fuel. The first stage serves to thoroughly mix the fuel 

and air and to deliver a uniform, lean, unburned fuel-air mixture to the second stage. 

NOx Control Technologies for Auxiliary Boiler

In addition to SCR, and SNCR the following three control technologies for NOx were evaluated by 

WEC for auxiliary boiler: 

1. SCR and SNCR 

SCR emission control technology is not considered technically feasible for the proposed auxiliary 

boiler because the design effectiveness of an SCR is not achieved until the flue gas temperature 

reaches between 400 and 800°F. The proposed auxiliary boiler will be required to supply steam in 

an expedited manner to minimize the duration of the combined cycle unit start-up, which produces 

elevated pollutant emission concentrations from the turbine during each start-up procedure. For 

this same reason, SNCR was also not found to be technically feasible for the auxiliary boiler.

2. Low-NOx Burners

Dry Low NOx Burners reduce NOx through staged combustion. Staging partially delays the 

combustion process, resulting in a cooler flame, which suppresses thermal NOx formation. NOx 

emission reductions of 40 to 85 percent (relative to uncontrolled emission levels) have been 

observed with Low-NOx Burners.

3. Flue Gas Recirculation (FGR)

In an FGR system, a portion of the flue gas is recirculated from the stack to the burner. The 

recirculated gas is mixed with combustion air prior to being fed to the burner. The FGR system 

reduces NOx emissions because the recirculated gas reduces combustion temperatures, thus 

suppressing the thermal NOx mechanism. FGR also reduces NOx formation by lowering the 
Woodbridge Energy Center 9 FACT SHEET

oxygen concentration in the primary flame zone. Together, Low-NOx Burners and FGR are 

capable of reducing NOx emissions by 60 to 90 percent.

b. Technical Review of Proposed NOx Controls

NOx Controls for Combustion Turbines and Duct Burners

WEC has proposed to install a DLN combustion system with SCR on each of the two combustion 

turbines as BACT/LAER to achieve an emission limitation of 2.0 ppmdv, corrected to 15% O2 on 

natural gas for all normal operations. 

The Department reviewed the proposed emission limitation with emission limitation of similar 

sized combustion turbines having SCR and DLN in the RACT/BACT/LAER Clearinghouse 

(RBLC) and found that the proposed emissions are minimal and approvable as both BACT and 

LAER. 

NOx Controls for Auxiliary Boiler

The proposed auxiliary boiler will be limited to natural gas firing only and will be operated for the 

purposes of supplying steam during the start-up of the combined cycle unit. 

WEC has proposed to install Dry Low-NOx Burners along with the use of natural gas to comply 

with BACT and LAER for the auxiliary boiler. The proposed NOx emission limit for the auxiliary 

boiler is 0.010 lbs/MMBtu (equivalent to 0.92 lb/hr or 0.92 TPY). WEC has proposed to take a 

restriction on the amount of natural gas usage for the boiler equal to 180 MMscf/yr, which is 

equivalent to 2000 hours annually, operating at 100 percent load.

The Department has reviewed the proposed NOx emission limitations for auxiliary boiler and 

found them to be BACT and LAER. These proposed NOx emission limitations will also comply 

with SOTA limit of 0.010 lbs/MMBtu for this size boiler firing natural gas.

NOx Controls for Emergency Engines, and Fuel Gas Heater

WEC has proposed NOx emission limitations for the emergency diesel generator, emergency diesel 

fire pump, and Fuel Gas heater to comply with BACT and LAER. 

The emergency diesel generator and emergency diesel fire water pump will operate on ULSD 

exclusively, which is considered a clean fuel with low emissions and will meet the emission limits 

of NSPS IIII. The proposed NOx emission limit for the emergency diesel generator is 21.16 lbs/hr 

or 1.06 TPY and, for the diesel fire water pump, the limit is 1.93 lbs/hr or 0.096 TPY. WEC has 

also proposed to take restrictions on the hours of operation for emergency diesel generator of less 

than or equal to 100 hours per year and for the diesel fire water pump of less than or equal to 100 

hours per year. The Department has reviewed these and found the proposed emission limitations 

to be BACT and LAER.

The Fuel Gas heater will operate on natural gas exclusively. The proposed NOx emission limit for 

the Fuel Gas heater is 0.035 lbs/MMBtu (equivalent to 0.33 lb/hr or 1.46 TPY). This limit meets 

BACT and LAER as well as the State of the Art (SOTA) requirement of New Jersey rules.
Woodbridge Energy Center 10 FACT SHEET

2. VOC Control Technologies

a. Description of Control Technologies

WEC evaluated the following two technologies for controlling VOC emissions from the proposed 

combustion turbines:

1. Combustion Control

The emissions of VOC in a combustion process are a result of the incomplete combustion of 

organic compounds within the fuel. In an ideal combustion process, all carbon and hydrogen 

contained within the fuel are oxidized to form CO2 and H2O. The rate of VOC emissions depends 

on combustion efficiency. VOC emissions are minimized by combustion practices that promote 

high combustion temperatures, long residence times at those temperatures, and turbulent mixing of 

fuel and combustion air. 

2. Oxidation Catalyst:

In an Oxidation catalyst, exhaust gases are passed over a catalyst bed where excess air oxidizes the 

CO to carbon dioxide (CO2). CO reduction efficiencies in the range of 80 to 90 percent can be 

guaranteed. However, at the high temperatures necessary to make the oxidation catalyst optimized 

for VOC reduction, there is the undesirable result of causing substantially more conversion of SO2

to SO3 which may, in turn, react with water and/or ammonia to form sulfuric acid mist and/or 

ammonia salt and PM10 emissions. 

b. Technical Review of Proposed VOC Controls

VOC Controls for Combustion Turbines and Duct Burners

Along with good combustion practices, WEC is proposing the installation of an oxidation catalyst 

for VOC emissions. The oxidation catalyst will reduce VOC emissions to 1.0 ppm without duct 

firing. The proposed VOC emissions limits when burning natural gas are 2.0 ppmdv corrected to 

15% O2 at 100% load with supplemental duct-firing. The Department has searched the RBLC for 

VOC emission limitations of similar sized combustion turbines and found the proposed VOC 

emission limitations to be LAER.

VOC Controls for Auxiliary Boiler

No technically feasible post-combustion control methods have been identified to assure the 

reduction of VOC emissions from auxiliary boilers. VOC emissions are controlled by good 

combustion practices. As discussed in the section for CO controls below, an oxidation catalyst 

used to control CO emissions from a boiler, may also reduce some VOC emissions. 

The proposed VOC emission limit for the auxiliary boiler is 0.0015 lbs/MMBtu (equivalent to 0.14

lb/hr or 0.14 TPY), which meets LAER limitations for boilers of this size firing natural gas. The 

department has found the proposed VOC emission limitations to be SOTA as well.

VOC Controls for Emergency Engines, and Fuel Gas Heater.

WEC has proposed VOC emission limitations for the emergency diesel generator, and emergency 

diesel fire water pump that meet the New Source Performance Standards (NSPS) Subpart IIII 

emission limits for these size emergency engines. The proposed VOC emission limit for the 

emergency diesel generator is 0.036 lbs/MMBtu (equivalent to 0.49 lbs/hr or 0.024 TPY). The 
Woodbridge Energy Center 11 FACT SHEET

proposed VOC emission limitation for the emergency diesel fire pump is 0.074 lbs/MMBtu 

(equivalent to 0.16 lbs/hr or 0.0078 TPY). 

The proposed LAER VOC emission limitation for the Fuel Gas heater is 0.005 lbs/MMBtu 

(equivalent to 0.05 lbs/hr or 0.21 TPY), which also meet the SOTA requirements. The Department 

has reviewed the proposed VOC emission limitations for emergency diesel generator, emergency 

diesel fire pump and Fuel Gas heater and found them to be LAER for VOC.

3. Carbon Monoxide (CO) Control Technologies 

a. Description of Control Technologies

Combustion Control

Carbon Monoxide is usually generated due to the incomplete combustion of fuel. CO emissions 

are minimized by good combustion practices that oxidized all carbon and hydrogen contained 

within the fuel to form CO2 and H2O. Several factors lead to incomplete combustion including 

insufficient O2 availability, poor air/fuel mixing, cold wall flame quenching, reduced combustion 

temperature, decreased combustion residence time and load reduction. By controlling the 

combustion process carefully, CO emissions can be minimized.

Oxidation Catalyst

After combustion control, the only practical control method to reduce CO emissions from 

combustion of fuel is the use of an oxidation catalyst. Exhaust gases from the combustion 

equipment are passed over a catalyst bed where excess air oxidizes the CO to carbon dioxide 

(CO2). CO reduction efficiencies in the range of 80 to 90 percent can be guaranteed, although CO 

reduction may at times be somewhat less than the design value. 

Process Controls

Modern data acquisition and control systems, which optimize combustion performance also 

minimize pollutant emissions, including CO, through a combination of operator and softwaredriven process adjustments and notifications.

b. Technical Review of Proposed CO Controls

CO Controls for Combustion Turbines and Duct Burners

Both turbines at WEC will be equipped with oxidation catalyst to reduce Carbon Monoxide (CO) 

emissions. WEC is proposing the use of oxidation catalyst as BACT for CO emissions along with 

process control and good combustion practices. The oxidation catalyst system will reduce inlet 

CO concentrations over 77% during all steady-state operating modes. The oxidation catalyst will 

be located in an optimum temperature region within the HRSG immediately upstream of the SCR 

ammonia injection grid and downstream of the gas-fired duct burner. The proposed emission 

limitation when firing natural gas is 2.0 ppmvd corrected to 15% O2 at 100% load. 

The Department has reviewed and found the proposed CO emission limitation of 2.0 ppmvd 

corrected to 15% O2 after the application of oxidation catalyst to be BACT for the combustion 

turbines with duct burners.
Woodbridge Energy Center 12 FACT SHEET

CO Controls for Auxiliary Boiler

Although an oxidation catalyst has been used to reduce CO emissions from boilers, it is not 

considered technically feasible to use it with the auxiliary boiler since the auxiliary boiler is 

required to supply steam quickly to the combined cycle units during the startup procedure and the 

oxidation catalyst requires a high flue gas temperature to achieve effective control. A more 

effective method of reducing emissions, including CO, is by good combustion controls and 

restricting operation on an annual basis.

WEC has proposed CO emission limitations for the auxiliary boiler of 0.038 lbs/MMBtu 

(equivalent to 3.44 lb/hr or 3.44 TPY), which meets BACT and the Department’s SOTA

limitations for boilers < 100 MMbtu/hr.

CO Controls for Emergency Engines, and Fuel Gas Heater.

The facility has proposed the CO emission limitation for the emergency diesel generator of 0.45

gms/bhp-hr (1.99 lbs/hr or 0.1 TPY) and the CO emission limitation for the emergency diesel fire 

pump of 2.6 gms/bhp-hr (equivalent to 1.81 lbs/hr or 0.09 TPY) ) and restricted hours of operation 

of 100 hrs/yr as BACT. The proposed CO emission limitation for the Fuel Gas heater is 0.05 

lbs/MMBtu (equivalent to 0.48 lbs/hr or 2.08 TPY). The Department has reviewed these emission 

limitations and found them to be BACT.

4. Sulfuric Acid Mist Control Technologies

a. Description of Sulfuric Acid Control Technologies

Sulfur dioxide emissions are formed from oxidation of sulfur in the fuel. A fraction of the SO2 is 

further oxidized to SO3, which in turn may react with water vapor to form sulfuric acid mist. The 

most practical means for controlling SO2 emissions from combustion equipment is to use low 

sulfur content fuel like natural gas and ultra low sulfur distillate oil. 

So far, add-on controls have not been used for reducing SO2 and sulfuric acid mist from 

combustion turbines, boilers using natural gas, and engines using ULSD. 

b. Technical Review of Proposed Sulfuric Acid Controls 

Sulfuric Acid Controls for Combustion Turbines and Duct Burners

The New Source Performance Standard (NSPS) sulfur content limit for combustion turbines (40 

CFR Subpart KKKK) in natural gas is 20 grains sulfur/100 SCF and 0.06 lb SO2/MMBtu in liquid 

fuel. WEC is proposing natural gas an inherently low sulfur fuel, as the exclusive fuels for the 

combustion turbines and duct burners. The maximum proposed by WEC for fuel sulfur limit for 

natural gas is 0.63 grains S/100 SCF, the maximum was obtained from one of the potential 

suppliers of natural gas to the project, Elizabethtown Gas, based on historical information. This 

maximum limit is well below the NSPS limit. 

Sulfuric acid mist emissions are minimized by use of low sulfur fuels. H2SO4 emissions will be 

limited to 0.001 lb/MMBtu (3.4 lb/hr with duct firing, and 2.8 lb/hr without duct firing) when 

firing natural gas for the combustion turbines. The Department has reviewed the Sulfuric acid mist 

emissions and found them to be BACT.
Woodbridge Energy Center 13 FACT SHEET

Sulfuric Acid Controls for Auxiliary Boiler

The Project proposes to fire natural gas in the auxiliary boiler to meet BACT for sulfuric acid. The 

maximum proposed H2SO4 BACT emission limit is 0.00014 lb/MMBtu or 0.012 lb/hr. The 

proposed H2SO4 emission limit is below the 0.05 lb/hr N.J.A.C. 7:27-22 Appendix, Table A 

“Thresholds for Reporting Emissions of Air Contaminants”

Sulfuric Acid Controls for Emergency Engines, and Fuel Gas Heater.

WEC has proposed to fire only natural gas in the Fuel Gas Heater as BACT for Sulfuric Acid mist 

emission. The emission limitations based on average sulfur content of 0.63 grains/100 scf are 

below the N.J.A.C. 7:27-22 Reporting Thresholds.

For the emergency diesel generator and the emergency diesel fire pump WEC has proposed to use

only ULSD fuel oil with a sulfur content limit of 15 ppm by weight or approximately 0.002 lb 

SO2/MMBtu, which is well below the NSPS limit of 0.06 lb SO2/MMBtu. The Sulfuric Acid mist 

emission limitations for emergency diesel generator and the emergency diesel fire water pump 

based on 15 ppm sulfur content are below the N.J.A.C. 7:27-22 Reporting Thresholds.

5. PM /PM10/PM2.5 Control Technologies

a. Description of Control Technologies

PM, PM10 and PM2.5 emissions from the combustion equipment like combustion turbines, boilers 

and engines may be formed from noncombustible constituents in fuel or combustion air, from 

products of incomplete combustion, or as a result of various chemical reaction, e.g. formation of 

sulfates and nitrates post combustion.

The use of natural gas (or other low ash content fuels like ULSD) is regarded as BACT for PM, 

PM10, and PM2.5.

b. Technical Review of Proposed PM /PM10/PM2.5 Controls

PM /PM10/PM2.5 Controls for Combustion Turbines and Duct Burners

A review of approximately 295 natural gas-fired combined cycle facilities from the USEPA‘s 

RBLC and recently issued air permit searches lists PM/PM 10 emission limits ranging from 0.0013 

to 0.1400 lb/MMBtu. In many instances, the pollutant listed in the RBLC database is TSP or PM. 

TSP and PM typically only includes the filterable portion of particulate matter; therefore, many of 

these limits cannot be compared to the proposed project. Control technologies, good combustion 

practice and low-sulfur, should be considered the driving factor for proposing BACT.

Particulate matter is formed from non-combustible constituents in the fuel or combustion air, or 

from formation of ammonium sulfates post combustion. WEC is not aware of any combustion 

turbine project that has been required to install add on controls for PM, PM10 or PM2.5. Postcombustion controls, such as baghouses, scrubbers and electrostatic precipitators (ESP) are not 

technically feasible for combustion turbines due to the high pressure drops, the large flue gas 

volumes and the low concentrations of PM/ PM10/PM2.5 present in the exhaust gas.
Woodbridge Energy Center 14 FACT SHEET

The combustion of clean burning fuels is the most effective means for controlling PM emissions 

from combustion equipment. WEC is proposing exclusive use of natural gas as the fuel for

turbines and duct burners. 

The proposed emission limits by WEC for PM10/PM2.5 is 0.0075 lb/MMBtu (19.1 lb/hr) and for 

PM/TSP is 0.0032 lb/MMBtu (8.2 lb/hr) when firing natural gas in the combustion turbine with 

duct burners operating. The proposed emission limits by WEC for PM10/PM2.5 is 0.0084

lb/MMBtu (12.1 lb/hr) and for PM/TSP is 0.0038 lb/MMBtu (4.8 lb/hr) when firing natural gas in 

the combustion turbine without duct burner operating. The proposed limits for PM and PM10 have 

been reviewed by the Department, and found to be BACT. The proposed limits of PM2.5 have 

been found by the Department to be SOTA.

PM /PM10/PM2.5Controls for Ancillary Sources

The auxiliary boiler will fire natural gas only. For the emergency diesel generator and the 

emergency diesel fire pump WEC has proposed very low ash, ULSD oil as PM/ PM10/PM2.5

emission control. The use of very low ash fuels such as natural gas and very low ash, ULSD oil is 

regarded as BACT for PM10, PM2.5, and PM.

The Project includes one 14 cell wet mechanical cooling tower with minimum water recirculation 

rate of 178,000 gallons per minute (gpm). Control of airborne emissions particulate matter from 

cooling tower drift is achieved with drift eliminators. WEC has proposed to install very high 

efficiency drift eliminators which will limit the drift to 0.0005% of the re-circulating water rate. 

At a maximum dissolved solids concentration of 6,240 ppm, the total PM10 from drift will be 

limited to an average of 1.806 lb/hr from the cooling tower or 7.91 TPY. The total PM2.5 from 

drift will be limited to 0.667 lb/hr from the cooling tower or 2.92 TPY. The PM from drift will be 

limited to 2.78 lb/hr from the cooling tower or 12.17 TPY. The Department has reviewed the 

proposed drift eliminator efficiency and found it to be BACT.

6. Green House Gases (GHG) Control Technologies

The main sources of GHG emissions for the Woodbridge Energy Center project are the 

combustion turbines, duct burners, auxiliary boiler and fuel gas heater. GHG emissions are also 

generated from the operation of the diesel engines, which are intended for limited operation (black 

start and fire protection). 

On June 3, 2010, EPA issued a final rule that “tailors” the applicability provisions of PSD for 

greenhouse gas (GHG) emissions. Under the tailoring rule, a new source (facility) that commence 

construction after July 1, 2011 is subject to PSD permitting requirements for GHG emissions, if 

the potential GHG emissions from the new source are greater than 100,000 tons/year, or if the

source is otherwise subject to PSD for another pollutant and its GHG potential emissions are equal 

to or greater than 75,000 tpy. 

Because WEC will be a new source and potential GHG emissions from the Woodbridge Energy 

Center will be greater than 100,000 tons/year, the proposed facility is subject to PSD permitting 

requirements for GHG emissions.

For PSD purposes, GHGs are considered a single air pollutant Carbon Dioxide Equivalent (CO2e) 

defined as the aggregate group of the following six gases:

• Carbon dioxide (CO2)
Woodbridge Energy Center 15 FACT SHEET

• Methane (CH4)

• Nitrous oxide (N2O)

• Hydro fluorocarbons (HFCs)

• Perfluorocarbons (PFCs)

• Sulfur hexafluoride (SF6)

a. Description of GHG (CO2e) Control Technologies:

The major constituent of CO2e emissions for combustion sources is CO2, which accounts for over 

95% CO2e emissions, therefore it is necessary to control CO2 emissions.

Carbon Capture and Sequestration (CCS) 

EPA has classified CCS as an add-on pollution control technology that is “available” for large 

CO2-emitting facilities including fossil fuel fired power plants. Carbon sequestration is a geoengineering technique used to remove the CO2 from an exhaust gas stream and store it 

permanently in underground reservoirs (typically depleted oil or gas reservoirs) or other geological 

features. Ideal geological formations for sequestration include depleted oil and gas fields and deep 

ocean masses. The vicinity surrounding the proposed Woodbridge Energy Center does not contain 

saline aquifers, depleted oil or gas reservoirs, or deep coal beds and therefore is not suitable for the 

injection of CO2 underground. 

Alternative sequestration techniques include converting CO2 to baking soda or algae based carbon 

capture. Power plants similar in size to the proposed Woodbridge Energy Center may require a 

significantly larger site area to accommodate the additional process facilities associated with CO2

capture. Such facilities could include CO2 compressors, scrubbers, oxygen production plants or 

other carbon capture equipment. Depending upon the capture technology employed, the site area 

for the capture equipment may approach the size of the site area of the power generating plant 

itself. In addition, capturing, scrubbing and compressing CO2 requires much energy and would 

increase the fuel needs of the plant. The long term storage of CO2 is a relatively new concept and 

has mostly been demonstrated on a pilot-scale. 

While current technologies could be used to capture CO2 from new fossil fuel fired power plants, 

they have not been demonstrated at the scale necessary to establish confidence for power plant 

application.1

 Further, the technology has not been demonstrated as suitable for the proposed site 

location. Therefore, CCS is not considered to be technically feasible for the project.

Thermal Efficiency

The design base load heat rate for GE 20FA.05 turbine is approximately 6,740 Btu/kWhr on a 

higher heating value (HHV) based on new and clean conditions without duct firing at steady state. 

This heat rate reflects the projects net power production which means that the output is net of plant 

auxiliary loads consumed by operation of the plant and is on HHV fuel basis. This heat rate is 

equivalent to a net plant efficiency of 56.2% Lower Heating Value (LHV). The heat rate and 

efficiency is based on the gas turbines at base load without duct firing.

The appropriate heat rate limit for the WEC turbines was determined by applying the following 

compliance margins to the base heat rate, consistent with other recent GHG BACT applications:

 1 See Report of the Interagency Task Force on Carbon Capture and Storage, p.50 

(http://www.epa.gov/climatechange/policy/ccs_task_force.html).
Woodbridge Energy Center 16 FACT SHEET

• A 3.3% design margin reflecting the possibility that the constructed facility will not be able 

to achieve the design heat rate.

• A 6% performance margin reflecting efficiency losses due to equipment degradation prior 

to maintenance overhauls.

• A 3% degradation margin reflecting the variability in operation of auxiliary plant

equipment due to use over time.

Based on the above criteria, Woodbridge Energy Center proposes as BACT net heat rate for

the Project of 7,605 Btu/kWh (HHV), corrected to ISO conditions of:

• Ambient Dry Bulb Temperature: 59oF

• Ambient Relative Humidity: 60%

• Barometric Pressure: 14.69 psia

• Fuel Lower Heating Value: 20,646 Btu/lb LHV

• Fuel HHV/LHV Ratio: 1.109

• Gas Turbines at base load with duct firing off

•

The proposed net heat rate for WEC turbines of 7,605 Btu/kWh (HHV) is consistent with other 

recent GHG BACT determinations for the Calpine Russell City Energy Center in Hayward, 

California, and the Cricket Valley Energy Center in Dover, New York, which contain CO2e limits 

for each facility’s natural gas fired combined cycle power plant, and efficiency limits ranging from 

7,605 to 7,730 Btu/kWh for the natural gas fired combustion turbines (operating at 100% load, ISO 

conditions and without duct firing). 

b. Technical Review of Proposed GHG Controls 

GHG Controls for Combustion Turbines and Duct Burners

Woodbridge Energy Center proposes to operate the combustion turbines in combined cycle mode 

with natural gas as the exclusive fuel and proposes as BACT a heat rate limit of 7,605 Btu/kWh

(57.4% efficiency (LHV)) at full load ISO conditions without duct firing (based on net output). 

In addition to the 7,605 Btu/kWh (HHV) heat rate limit WEC is also proposing, as BACT, an 

emission limit of 925 lb CO2/MW-hr (gross), for each turbine and its associated duct burner. 

WEC is also proposing an annual limit CO2e of 2,057,875 tons per year for the two turbines and 

duct burners. Compliance with the proposed CO2e limit would be demonstrated through the use of 

CO2 CEMS along with fuel usage and emission factors for methane and nitrous oxide. 

The Department has reviewed the proposed BACT limits for WEC turbines and found them to be 

consistent with other recent BACT determinations for similar size turbines.

GHG Controls for Auxiliary Boiler and Fuel Gas Heater

To reduce GHG emissions from the Auxiliary boiler, WEC is proposing to use natural gas which 

has the lowest CO2 emissions compared to other combustion fuels, to limit its operation 2,000 

hours per year and to operate it efficiently. 

The Woodbridge Energy Center Project’s fuel gas heater at WEC will utilize natural gas as it is the 

only feasible option for reducing GHG emissions from the Fuel Gas Heater.
Woodbridge Energy Center 17 FACT SHEET

GHG Controls for Emergency Engines

A search of the RBLC for “carbon dioxide” did not yield any results for emergency diesel engines 

similar to that proposed for the Woodbridge Energy Center Project. The reduction of GHG 

emissions from the emergency diesel generator and fire pump will be achieved by limiting the 

hours of operation.

D. APPLICABLE REGULATIONS

1. Prevention of Significant Deterioration (PSD) of Air Quality

DEP has determined that the proposed facility is subject to all applicable requirements of the 

federal PSD regulations codified at 40 CFR 52.21. The threshold for PSD applicability is 100 tons 

per year of emissions of any regulated pollutant for fossil fuel-fired steam electric plants of greater 

than 250 MMBTU/hr heat input. PSD applicability is determined on an individual pollutant basis. 

Based on the potential annual emissions in Table 2, the WEC was determined to be subject to PSD 

requirements for emissions of nitrogen oxides (NOx), carbon monoxide (CO), particulate matter 

with an aerodynamic diameter less than 10 microns (PM10), PM, H2SO4 and Greenhouse gases 

(CO2e). 

Air Quality Impact Analyses

In addition to the BACT control technology requirements discussed in Section C above, the PSD 

regulations require the facility to conduct an air quality impact analysis to show that the project 

emissions would have no adverse effect on: 

(1) Visibility, soils and vegetation that would occur as a result of the project itself and general 

commercial, residential, industrial and other growth associated with WEC,

(2) Air quality projected for the area as a result of general commercial, residential, industrial and 

other growth associated with it, and,

(3) Endangered species.

WEC has stated that there would be no adverse impacts on visibility, soils and vegetation and 

projected air quality as a result of the project itself, or due to general commercial, residential, 

industrial and other growth associated with it. 

WEC is located within the geographic range of the federally listed (endangered) Indiana bat 

(Myotis sodalis). Because no suitable habitat is on the WEC Project Site, no adverse effects will 

occur to the Indiana bat or its habitat from the proposed Project. No adverse effects are anticipated 

on other federally listed species either.

Environmental Justice (EJ) Analyses 

WEC conducted an Environmental Justice (EJ) analysis to determine whether the construction and 

operation of the WEC would have a significant adverse and disproportionate effects on an 

“environmental justice community.” The EJ analysis is per the Executive Order 12898 (“EO”), 

entitled “Federal Actions to Address Environmental Justice in Minority Populations and Low 

Income populations” (February 11, 1994). The EO requires federal agencies to consider 

disproportionately high adverse human health or environmental effects of their actions on minority 

and low income populations. New Jersey has similar order in Executive Order 131 that requires 

state agencies, including NJDEP, to allow for public participation in decisions that effect 

environmental quality and public health.
Woodbridge Energy Center 18 FACT SHEET

The “USEPA Region 2 Interim Environmental Justice Policy” (USEPA, 2000) (Interim Policy) 

provides guidance in conducting the EJ Analysis. The Interim Policy defines an “EJ Community” 

as:

“A minority and/or low income area suffering a disproportionate and adverse environmental 

burden as a result of the unfair or unequal development, implementation, or enforcement of 

environmental laws, regulations or policies.”

An “adverse environmental burden” is defined by the Interim Policy as:

“When there is an acknowledged health or welfare standard for the burden in question, the burden 

is adverse only when it exceeds that standard. When there is no standard, the decision is based on 

additional site-specific analysis”

WEC utilized the Interim Policy guidelines to develop its EJ Analysis that showed the presence of 

14 census block groups within a two-mile radius of the project which exceeded the USEPA Region 

2 demographic criteria thresholds for minority and/or low-income representation. WEC then 

furthered its EJ Analysis to identify potential environmental impacts within the 14 census block 

groups.

EJ Analysis demonstrated that WEC’s potential air emission concentrations are less than the 

NAAQS within the EJ Study area, and therefore are not adverse.

Air Quality Modeling Analyses

The PSD air quality modeling analyses are discussed in detail in Section E. Briefly, the facility 

has demonstrated that project emissions are in compliance with the NAAQS, NJAAQS, and PSD 

Class I and Class II increments, and will not have an adverse impact on soils, vegetation, and 

endangered species. Furthermore, the maximum modeling air quality impact locations do not fall 

within potential EJ areas, and do not have a disproportionate affect on EJ communities. 

2. N.J.A.C 7:27-18 

The WEC was determined to be subject to N.J.A.C 7:27-18 for emissions of NOx, VOC CO and 

PM10. The WEC is subject to N.J.A.C 7:27-18 for NOx and VOC as the potential emissions of 

these two ozone precursors are greater than 25 tons per year (the threshold for severe ozone nonattainment, which applies to the entire state of New Jersey). The potential emissions of CO and 

PM10 are greater than N.J.A.C 7:27-18 threshold of 100 tpy for these two pollutants.

Middlesex county is non-attainment for Ozone (precursors NOx and VOC) and PM2.5. Applicable 

requirements include application of LAER technology and acquisition of emission offsets. 

The minimum offset ratio is 1.3:1 for both NOx and VOC, per N.J.A.C. 7:27-18.5. The use of 

emission reduction credits (CERs) to offset NOx and VOC emissions must be within 100 miles for 

the 1.3:1 ratios to apply. WEC has expressed its intent to secure the required NOx and VOC 

emission offsets from sources within 100 miles of its site. Therefore, multiplying the potential to 

emit (PTE) by 1.3 results in a requirement for 195 tons per year (tpy) of NOx (PTE = 149.4 tpy) 

offsets, and 44 tons of VOC (PTE = 33.6 tpy) offsets. These offsets must be secured by WEC

before the startup. The facility must also indentify the sources from which these offsets will be 

acquired and provide the Department a letter of intent from these sources agreeing to sell required 

NOx and VOC offsets to the WEC, before the draft permit is issued for public comment.
Woodbridge Energy Center 19 FACT SHEET

Pursuant to N.J.A.C 7:27-18, the facility is required to obtain 195 tons of NOx offsets, at an offset 

ratio of 1.3 tons reduction to 1.0 ton of NOx emission increase, and 44 tons of VOC offsets at an 

offset ratio of 1.3 tons reduction to 1.0 ton of VOC emission increase. 

The applicant has proposed to obtain 44 tons of VOC offsets from:

• General Motors Corporation, Linden, Union County

The applicant has proposed to obtain 195 tons of NOx offsets from one or more of the following 

sources:

Offsets from New Jersey:

a. Chevron USA Products Company, Perth Amboy, Middlesex County

b. Gerdau Ameristeel, Perth Amboy, Middlesex County

Offsets from New York

a. Warbasse Houses and Power Plant, Brooklyn, New York

b. BICC Cables Co. Yonkers, New York

c. National Grid – (formerly KeySpan Gen. LLC), Glennwood Landing, New York

d. Con-Edison – Astoria, Astoria, New York

e. Covanta Babylon, West Babylon, New York

Any offsets from New York would require agreement by New York Department of Environmental 

conservation (NYDEC) that emissions reductions are enforceable. Such an agreement must be 

obtained by NJDEP prior to final approval of offsets. If this permit is approved, all offsets would 

need to be verified and acceptable to NJDEP, and secured and transferred to the applicant prior to 

initiation of operation pursuant to N.J.A.C. 7:27-18.3(f).

Middlesex County is in attainment for CO and PM10. As per N.J.A.C 7:27-18.2(b)2, the facility is 

required to conduct air quality impact analysis to show that the proposed emissions of CO and 

PM10 would not equal or exceed the significant air quality impact level, nor result in a violation of 

an NAAQS or the NJAAQS. 

As mentioned above, WEC would be located in Middlesex county which is non-attainment for 

PM2.5, it is subject to December 14, 2010 Memorandum of Division of Air Quality regarding PM2.5 

Permitting and Modeling Procedures.

In accordance with N.J.A.C. 7:27-18.3(c)2, WEC has conducted an analysis of alternative sites 

within New Jersey and considered alternative sizes, production processes, including pollution 

prevention measures and environmental control techniques, demonstrating that the benefits of the 

newly constructed WEC outweigh the environmental and social costs imposed as a result of the 

location, construction, and operation of the WEC. The Department has found that the benefits of 

the WEC will significantly outweigh the potential environmental and social costs imposed as a 

result of construction and operation of the WEC.
Woodbridge Energy Center 20 FACT SHEET

3. Other Regulatory Requirements

a. Federal Regulations

New Source Performance Standards (NSPS)

In addition to PSD regulations codified at 40 CFR 52.21, the WEC is subject to the following 

subparts of NSPS codified at 40 CFR 60: 

• Subpart A:General Provisions

• Subpart Dc, the NSPS for industrial steam generating units greater than or equal to 10 

MMBTU/hr but less than 100 MMBTU/hr (auxiliary boiler) 

• Subpart IIII, the NSPS for stationary CI internal combustion engine, and 

• Subpart KKKK, the NSPS for stationary gas turbines.

The emission limitations proposed by the WEC as shown in Table 1 and discussed in Section C 

satisfy the NSPS requirements.

Acid Rain Program

The Acid Rain Permit is proposed pursuant to the air pollution control permit provisions of Title 

IV of the federal Clean Air Act, federal rules promulgated at 40 CFR 72, and state regulations 

promulgated at N.J.A.C. 7:27-22. These rules require facilities operating “affected units” that are 

subject to the Acid Rain Program to obtain an Acid Rain Permit for those units. Pursuant to Title 

IV of the Clean Air Act, the United States Environmental Protection Agency (USEPA) has not 

previously approved sulfur dioxide allowances for the two units, Unit 1, and Unit 2, proposed for 

WEC. Each allowance provides authorization to emit up to one ton of sulfur dioxide during a 

specified calendar year. In accordance with USEPA’s rules, WEC may sell or purchase 

allowances on the open market in order to more accurately reflect current operation. The total 

numbers of SO2 allowances allocated to the referenced units are as follows: Unit 1: 6, Unit 2: 6

The representative for WEC is Mark Turner.

National Ambient Air Quality Standards

The National Ambient Air Quality Standards (NAAQS) are codified at 40 CFR 50. The dispersion 

modeling analysis discussed in Section E, demonstrate compliance with the NAAQS 

requirements.

Maximum Achievable Control Technology (MACT)

The MACT standards are codified at 40 CFR 63 (National Emission Standards for Hazardous Air 

Pollutants for Source Categories), and are applicable to sources that emit Hazardous Air Pollutants 

(HAPs).

The combustion turbines along with duct burners, auxiliary boiler and emergency engines are 

sources of HAPs. The MACT rules for these sources are codified at:

Subpart YYYY: for Stationary Combustion Turbines. 

Subpart JJJJJJ: Industrial, Commercial, Institutional (ICI) boilers and process heaters

Subpart ZZZZ: for Stationary Reciprocating Internal Combustion Engines.
Woodbridge Energy Center 21 FACT SHEET

WEC will not be a major source HAP. A source is major for HAPS if the total HAPs from the 

facility are 25 tons per year or greater, or if the emissions of a single HAP is 10 tpy or greater.

The total HAPs from WEC are 5.51 tpy, which are less than 25 tons per year. Formaldehyde would 

be the single HAP emitted from the combustion turbines with highest estimated annual emission 

rate of 2.7 tpy. The HAP emissions from all other equipment at WEC are below the reporting 

thresholds in Table B of Appendix to N.J.A.C. 7:27-22. 

Since the WEC is not a major source of HAPs, the combustion turbines are not subject to MACT 

standards at Subpart YYYY. 

The new auxiliary boiler is not subject to Subpart JJJJJJ as it will be burning natural gas. 

The new emergency engines will comply with Subpart ZZZZ by complying with NSPS IIII, since 

WEC is an area HAPs source (those that are not major HAPs sources). 

b. New Jersey Regulations

The facility is subject to New Jersey Air Pollution Control Regulations, codified in N.J.A.C. 7:27-

1 et seq. for air pollution control, and the New Jersey Ambient Air Quality Standards (NJAAQS). 

The Department is satisfied that the proposed emission rates in Table 1 and Table 2 satisfy the 

New Jersey regulations.

E. TESTING AND MONITORING REQUIREMENTS

The WEC will be required to conduct stack testing for NOx, CO, TSP, PM10, PM2.5, VOC, and 

SO2 to demonstrate the ability of the facility to operate within the approved emission limitations. 

In addition, Continuous Emission Monitors (CEM) and recorders for NOx, CO, O2 and CO2 would

be required. The scope of the stack testing and CEMS is detailed in the draft compliance.

Since the facility is proposing PM2.5 emissions of 98.7 tons per year, which is very close to 100 tpy 

threshold for triggering NSR Rule (40CFR Part51, Appendix S) for PM2.5, the Department is 

requiring that the WEC conduct quarterly stack testing for PM2.5 for the first two years, and then 

based on the stack tests results the facility may apply for relaxing this requirement. 

F. AIR QUALITY IMPACT ANALYSIS

The Department reviewed the ambient air quality impact of the proposed project. Based on the air 

quality modeling analysis, the Department found that air contaminant emissions from the proposed 

Facility will not exceed Federal or New Jersey Ambient Air Quality Standards or PSD increments. 

The source's Class I impacts at the Brigantine National Wildlife Refuge would be less than

allowable EPA Class I increments, and below Class I area Significant Impact Levels (SILs). 

The fact sheet of the air dispersion modeling from Bureau of Technical Services, is attached at 

Section G.

G: ATTACHMENT I

Fact Sheet for air dispersion modeling and risk assessment
Woodbridge Energy Center 22 FACT SHEET

ATTACHMENT I

WOODBRIDGE ENERGY CENTER 

700 MW ELECTRIC GENERATING FACILITY

MAY, 2012

FACT SHEET: AIR QUALITY EFFECTS

Air Quality Analysis Methodology

Emissions of air pollutants from the proposed Woodbridge Energy Center (facility) were 

mathematically modeled in order to predict their effect on ambient air quality levels. Maximum 

predicted concentrations of criteria pollutants were compared with the National and New Jersey 

Ambient Air Quality Standards (NAAQS and NJAAQS). The primary ambient air quality 

standards were established to protect public health with an adequate margin of safety. The 

secondary ambient air quality standards were designed to protect public welfare from adverse 

effects such as soiling, vegetation damage, or material corrosion. Criteria pollutants, which will be 

significantly emitted by the proposed facility, include sulfur dioxide (SO2), nitrogen oxides as 

nitrogen dioxide (NO2), carbon monoxide (CO), and particulate matter (PM-2.5 and PM-10). 

Modeled impacts of SO2, NO2, and PM-10 were also compared to the USEPA’s Prevention of 

Significant Deterioration (PSD) increment levels. A PSD increment is the maximum increase in a 

pollutant’s concentration that is allowed to occur above an earlier established baseline value.

The air quality modeling analysis was performed using the U.S. Environmental Protection 

Agency’s atmospheric dispersion model – AERMOD (version 12060). Basic inputs to the 

dispersion model were the facility’s emissions, stack height, stack diameter, stack exit gas 

temperature and velocity, and the surrounding ground level elevations. Aerodynamic building 

downwash from the heat recovery steam generators (HRSG), evaporative cooling tower and 

significant structures at the facility were included in the modeling. 

The AERMOD model was used with five years (2006-2010) of National Weather Service hourly 

surface meteorological data from Newark International Airport and concurrent upper air data from 

Brookhaven, NY. The Newark International Airport is located approximately 22 kilometers 

northeast of the proposed facility, while Brookhaven National Labs is approximately 127 

kilometers east of the proposed facility. The meteorological data used for the air quality modeling 

analysis is considered representative of the Woodbridge Energy Center site. A land cover 

classification analysis was performed to determine whether the urban source modeling option in 

AERMOD should be used in quantifying ground-level concentrations. The land use classification 

concluded the site should be represented as rural in the model. The AERMOD modeling analysis 

examined the Woodbridge Energy Center’s impact on the ambient air levels of 1-hour and 8-hour 

average CO concentrations; 1-hour, 3-hour, 24-hour, and annual average SO2 concentrations; 1-

hour and annual average NO2 concentrations; 24-hour and annual average PM-10 and PM-2.5 

concentrations. The AERMOD model also was used as a screening tool to simulate long-range 

transport impacts of PSD affected criteria pollutants at the Brigantine Class I Area and to evaluate 

short-term and annual average concentrations of hazardous air pollutant (HAP) emissions from the 

facility. 
Woodbridge Energy Center 23 FACT SHEET

B. Dispersion Modeling Analysis - Single Source Refined Results

The air quality impacts from the proposed Woodbridge Energy Center combustion turbines were 

examined along with ancillary equipment and alternative operating scenarios (duct firing within 

the HRSGs, auxiliary boiler, fuel gas heater, and startup and shutdown conditions). Fourteen 

different combinations of ambient temperatures and varying turbine operating loads were 

evaluated to determine the worst-case turbine operating scenario for use in the modeling analysis. 

The results of the single source modeling indicate that the facility had modeled concentrations 

below the significant impact levels (SILs) for CO, PM-10, annual PM-2.5, SO2, and annual NO2 in 

both Class I and Class II areas. Because impacts were predicted above the SILs, compliance with 

the 1-hour NO2 and 24-hour PM-2.5 NAAQS had to be demonstrated with a multiple major source 

(multisource) modeling analysis. This analysis is discussed in a later section of the fact sheet. 

For the averaging times and pollutants predicted to be below their respective significance levels, 

Table 1 shows that when these impacts are added to background concentrations, the proposed 

emissions increase due to the proposed Woodbridge Energy Center will not cause or contribute to 

a violation of a NAAQS or NJAAQS.

TABLE 1

Proposed Woodbridge Energy Center 

Maximum Predicted Impacts

Pollutant

Avg. 

Time

Max. Pred

Conc.

(ug/m3)

(a)

Significance

Level

(ug/m3)

Location of

Background Air 

Quality (ug/m3)

Total Impact

(ug/m3)

NJAAQS/

NAAQS

(ug/m3) (c)

SO2

1-hour 2.3 7.8 49 (Perth Amboy) 51.3 197

3-hour 2.1 25 47 (Perth Amboy) 49.1 1,300 (e)

24-hour 1.5 5 26 (Perth Amboy) 27.5 260(d)/365

Annual 0.1 1 5.2 (Perth Amboy) 5.3 60(d)/80

NO2

1-hour 51 10 92 (Rutgers) b 188

Annual 0.91 1 20.8 (Rutgers) 21.7 100

CO

1-hour 773 2,000 3,680 (Perth Amboy) 4,453 40,000

8-hour 95 500 1,610 (Perth Amboy) 1,705 10,000

PM-2.5

24-hour 3.3 1.2 23.0 (Rutgers) b 35

Annual 0.2 0.3 8.8 (Rutgers) 9 15

PM-10 24-hour 4.4 5 78 (Jersey City) 82.4 150

a. Values represent maximum predicted block averages. 

b. Multisource modeling conducted to determine the total impact.

c. Unless footnoted, values represent the primary ambient air quality standard.

d. Values represent the secondary New Jersey ambient air quality standard.

e. Values represent the national and New Jersey ambient air quality standard.
Woodbridge Energy Center 24 FACT SHEET

Dispersion Modeling Analysis - Multisource Modeling Emission Inventories

The multisource modeling analysis was conducted for the two pollutants and averaging times 

whose impacts exceeded significance levels, 1-hour NO2 and 24-hour PM-2.5. The multisource 

modeling was performed to assess the impacts of the Woodbridge Energy Center plus other major 

sources of PM-2.5 and NO2 in the surrounding region. Woodbridge Energy Center’s impacts were 

modeled using the worst-case operating scenario identified for the single source modeling. 

A modeling methodology similar to that used in the single-source modeling was used in the 

multisource modeling (AERMOD with the 2006 through 2010 meteorological data). Receptors 

were only placed within the significant impact area of 1.5 kilometers for PM-2.5. Following EPA 

guidance on NO2 modeling, receptors for the NO2 multisource modeling were placed at locations 

where the single source modeling predicted maximum modeled impacts above the significance 

level. The emissions from eighteen nearby major existing or proposed sources were included in the 

multisource modeling analysis. 

Dispersion Modeling Analysis - Multisource Modeling Analysis Results

The results of the multisource modeling analysis are summarized in Table 2. Table 2 demonstrates 

that emissions from the proposed Woodbridge Energy Center when combined with other nearby 

sources and background air quality will not cause or significantly contribute to a violation of a 

NJAAQS or NAAQS. 

TABLE 2

Comparison of Predicted Multisource Impacts to NJAAQS/NAAQS

Pollutant Avg. Time

Predicted

Conc.

(ug/m3)

Background 

Air Quality 

(ug/m3)

Total 

Impact

(ug/m3)

NJAAQS/

NAAQS

(ug/m3)

PM-2.5 24-hour 7.3(a) 23 30.3 35

NO2 1-hour 43(b,c) 92 135 188

a. Based upon maximum of 5-year average 1st highest maximum modeled concentrations.

b. Based upon maximum of 5-year average 8th highest maximum modeled concentrations.

c. Assumed 80% of NOx is NO2 per EPA guidance.

Class I Area Air Quality Impacts

The only PSD Class I area within 300 kilometers of the facility is the Brigantine National Wildlife 

Refuge which is located approximately 108 kilometers to the south of the facility. The Federal 

Land Manager (FLM) for Brigantine was contacted by the facility and the FLM determined that an 

assessment of the facility impacts to air quality related values (AQRVs) such as visibility and 

sulfate and nitrate deposition was not required. Emissions from the proposed project were 

evaluated to assess the consumption of the Class I PSD Increments at the Brigantine National 

Wildlife Refuge Class I area. The Class I impacts were modeled with AERMOD and five years 

(2006-2010) of hourly surface meteorological data from Newark International Airport with 

concurrent upper air data from Brookhaven, NY. Maximum modeled concentrations were then 

compared to both the PSD Class I SILs and increments as presented in Table 3. All were predicted 

to be below their federal SILs and PSD Class I Increments. 
Woodbridge Energy Center 25 FACT SHEET

TABLE 3

Comparison of Maximum Predicted Impacts for Criteria Pollutants to Class I Significant Impact Levels 

and Increment Levels

Pollutant

Averaging 

Time

Maximum 

Predicted 

Impact

(ug/m3)

PSD Class I

Significant

Impact Level

(ug/m3)

PSD Class I 

Increment 

(ug/m3)

SO2 3-hour 0.06 1.0 25

24-hour 0.01 0.2 5

annual 0.0008 0.1 2

PM2.5 24-hour 0.035 0.07 2

annual 0.002 0.06 1

PM10 24-hour 0.04 0.3 8

annual 0.003 0.2 4

NO2 annual 0.003 0.1 2.5

Risk Assessment

A risk assessment was conducted to assess the possible adverse health effects due to inhalation 

exposure to the HAPs emitted from the natural gas fired combustion turbines at the Woodbridge 

Energy Center facility. A total of 9 HAPs were included in this study. Of the 9 pollutants emitted, 

6 are known or suspected to be carcinogenic. The highest 24-hour and annual unit concentrations 

predicted by the single source AERMOD modeling analysis with the 2006-2010 meteorological 

data were used to calculate the maximum ambient pollutant concentrations. Modeling results 

indicate that the long-term cancer risks for individual HAPs are less than one in a million. In 

addition, hazard quotients for all short-term and long-term pollutants with health effects other than 

cancer are predicted to be less than 1.0. Table 4 lists the long-term cancer risk assessment 

performed for the 6 non-criteria pollutants. In summary, the adverse health effects due to HAP 

emissions from the Woodbridge Energy Center are predicted to be negligible.

Table 4

Hazardous Air Pollutant Cancer Risks

Pollutant

70-Year Exposure

Cancer Risk

Level of Concern

Above:

Arsenic (inorganic) 0.018 in a million 1 in a million

Benzene 0.0019 in a million 1 in a million

Benzo(a)pyrene 0.0013 in a million 1 in a million

Cadmium 0.094 in a million 1 in a million

Formaldehyde 0.35 in a million 1 in a million

lead 0.0001 in a million 1 in a million
Woodbridge Energy Center 26 FACT SHEET

CONCLUSIONS

1) Criteria pollutants from the proposed Woodbridge Energy Center will not cause or significantly 

contribute to violations of state or federal ambient air quality standards for SO2, NO2, CO, PM-2.5 

and PM-10 or the applicable Prevention of Significant Deterioration (PSD) Increments. 

2) Impacts at the Brigantine Division of the Edwin B. Forsythe National Wildlife Class I Area were

predicted to be below the Class I Significant Impact Levels and Increments for the 3-hour, 24-hour 

and annual averaging times. Emissions from the facility will not significantly increase regional 

haze at the refuge.

3) Modeled impacts of hazardous air pollutants from the Woodbridge Energy Center were predicted 

to have negligible health risks.