BlueScape Get the Air Permit for Energy Projects Webinar 9-10-13
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Get the Permit! Air Permitting for Energy Project Developers September 10, 2013 James A. Westbrook [email protected] 858-774-2009 mobile
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This webinar by James Westbrook at BlueScape describes the air permitting process for energy projects, from early planning and technical feasibility review to application submittal and permit negotiation. The webinar presents tips to avoid delays and move quickly, save money, and address issues and hurdles that can impact the project. Issues such as emission limits and BACT emission controls, offsets, Title V permitting, and modeling impacts are discussed. The presenter provides tips on how to conduct the permitting process to be successful, and maximize operational flexibility. Mr. Westbrook can be reached at 858-774-2009 for more information. For a video presentation go to youtube.com/watch?v=AB84GQORp2w. Also see www.bluescapeinc.com.
Transcript of BlueScape Get the Air Permit for Energy Projects Webinar 9-10-13
Get the Permit!
Air Permitting for Energy Project Developers
September 10, 2013 James A. Westbrook
[email protected] 858-774-2009 mobile
Agenda • Energy Project Permi2ng Objec5ves • The 5 Air Permi2ng Process Steps • Permit planning -‐ common issues and hurdles
• What Can Go Wrong • Permi2ng Examples from Energy Projects • Summary
If you are involved with energy projects … what kind?*
Energy Project Type % Cogenera5on – gas engines, boilers, turbines
20%
Diesel Engines 16% U5lity Scale Power Plants 18% Refinery, Oil & Gas Projects 22% Other 24%
*As of Sep 7, 2013
About the Presenter • 25 years experience with air permits on energy
projects • Power genera5on, industrial cogen, LNG facili5es,
transmission lines, u5li5es, refinery, oil & gas processing
• Na5onal Experience – CA to East Coast • Solve tough air permi2ng issues and get the permit:
-‐ Develop permi2ng strategy, rapidly obtain permits -‐ Reduce impacts on opera5onal flexibility -‐ Excel in technical analysis, emission controls and modeling -‐ Develop workable monitoring, recordkeeping and repor5ng -‐ Established agency rela5onships, lead nego5a5ons
Air Permi2ng is like Ra_ing …..
What are your Permi2ng Objec5ves? • Get the permit, move project development forward
– Quick, smooth, hassle-‐free process
• Save money on equipment and emission controls • Avoid mistakes in equipment selec5on • Minimize regulatory limita5ons and constraints • Maximize opera5onal flexibility • Get ahead of changing, stricter requirements • Allow for future plant expansion if needed
An air permit is a cri-cal piece of business insurance !!
The Permi2ng Team Host Facility
Project Developers
Permitting Consultant Energy Equipment Vendor
Reviewing Agency
Attorneys Air Pollution Equipment Vendor Public Relations
Monitoring Equipment Vendor
Air Permi2ng Process -‐ Summary
Development Timeline Pre-‐
Project Planning
Feasibility Analysis
Applica5on
Permit Review & Nego5a5on
Permit Opera5ons
Project Start
30% Design
80% Design
Construc5on Start
Opera5on Start
3 months 6 months 12 months 24 months
Project Development Schedule
Air Permi:ng Schedule
0
Pre-‐Project Planning
Pre-‐Project Planning
• Start early at the drawing board • Hire an energy project permi2ng expert, sit at design table
• Review the Project “lay of the land” -‐ Region, aiainment or non-‐aiainment area -‐ Agencies involved, local, state and federal -‐ stringency -‐ Exis5ng facility air permit status, major or minor source -‐ Equipment ownership -‐ Other approvals dependent on the air permit issuance
Pre-‐Project Planning (con’t) • Determine the kind of project
-‐ New, modified, replacement -‐ Opera5onal mode -‐ baseload, peaking, backup or prime -‐ Applicable rules, exemp5ons, permits by rule, and trigger
thresholds • Design Review Issues
– Equipment, fuels and expected emission controls – Emission limita5ons and other constraints – Recent projects and agency requirements – Project op5ons and alterna5ves – Manufacturer guarantees
• Develop a Permi2ng Strategy and Workplan
Rules & Emission Limits Drive Design
• Best Available Control Technology (BACT) • Local or state prohibitory or source-‐specific standards, exemp5ons
• EPA New Source Performance Standards (NSPS) • EPA Na5onal Emission Standards for Hazardous Air Pollutants (NESHAP of MACT controls)
• Limits forced by Air Quality Impact Analysis
Feasibility Analysis
Feasibility Analysis • Technical Issues review – “fatal-‐flaw” analysis • Data development – projects, vendors, geography • Issues List:
– Best Available Control Technology (BACT), by unit – Prohibitory Rules – exemp5ons, limits, monitoring, recordkeeping and
repor5ng requirements – Startup and Shutdown Emissions, Varying Condi5ons – Emission Offsets, by facility / project – Title V and PSD permi2ng, by facility / project – Air Quality Impacts by project
• Ambient Standards • Health Risk Assessment
– Poten5al to develop Emission Credits for sale • Community Support and Involvement • How feasible is this project, what must happen?
BACT for NOx Emissions
Equipment Type Applica=on Size BACT for NOx Gas Engine, NG Cogen 1,000 hp 0.1 -‐ 0.15 g/bhp-‐hr Gas Turbine, NG Cogen 5.0 MWe 2.5 – 5.0 ppmv @ 15% O2 Gas Turbine, NG U5lity 100 MWe 1.0 – 2.5 ppmv @15% O2 Boiler, NG Process Heat 100
MMBtu/hr 0.01 – 0.04 lb/MMBtu
Diesel Engine Backup 2,000 hp 6.4 g/kW-‐hr* (EPA Tier 2) Diesel Engine Prime 2,000 hp 0.67 g/kW-‐hr* (EPA Tier 4) *NOx + NMHC
Emission Offsets, Title V and PSD
• Emissions Offsets – Nonaiainment Areas • Federal Opera5ng Permits (Title V) – major sources of criteria pollutants – Process to add or modify units different for major sources
• Preven5on of Significant Deteriora5on (PSD) – major source new source review in aiainment areas
Air Quality Impact Analysis • Na5onal and state ambient air quality standards – NO2, PM10, PM2.5, SO2, CO and VOC (ozone)
• Health Risk Assessment for Air Toxics – Cancer risk: 1 in one million to 10 in one million cases
– Noncancer chronic or acute risk • Agency will run an independent analysis • Must show compliance to get the permit
Applica5on
Applica5on Process • Pre-‐applica5on Mee5ng with Agency
– Hear what they want, tell ‘em what you want • Find out about and file for Expedited Permi2ng • Complete Applica5on Package
– Fees – Cover Leier – Forms – general, equipment-‐specific – Technical Report – emissions, BACT, applicable rules – Air Quality Impact Analysis – Equipment Specifica5ons – Manufacturer Guarantees – Site plans and area maps
• Applica5on Mee5ng • Agency Completeness Determina5on Period • Agency Applica5on Review Period
Permit Review & Nego5a5on
Permit Review and Nego5a5on • A dra_ “Authority to Construct” (ATC) permit will be issued
• Carefully review and meet with the agency – Much can be nego5ated to allow flexibility
• Public Review and Comment period, if applicable – add 30-‐45 days
• Final permit issuance for construc5on • 1-‐2 years to complete project construc5on • Do I need the ATC permit before I can start any construc5on?
Permit Opera5ons
Permit Opera5ons • Start opera5ons and show compliance
– With the permit and applicable rules and regula5ons • Monitoring, recordkeeping, and repor5ng procedures – in place, track, track!
• No5fica5ons and protocols to agency • Emissions source tes5ng • Agency ini5al inspec5on – show all permit condi5ons are met
• Upon compliance, permit to operate (PTO) • Addi5onal permit fees for the PTO
What Can Go Wrong? Problem How to Avoid
Construc5on delay without air permit Start the applica5on process early
Last minute or frequent design changes Strategize submiial 5ming
Changing regulatory requirements or BACT Watch for and plan for these changes
Expensive equipment or emission control required
Review equipment, design, opera5onal alterna5ves
Can’t meet emission limits a_er opera5on Beier engineering design
Onerous permit monitoring condi5ons Nego5ate appropriate condi5ons
Triggering emission offsets or Title V Structure emission limits or opera5ng condi5ons to avoid triggers
Exceeding ambient health standards Refined air dispersion modeling
Permit does not match what will actually be installed
Contact agency to revise and reissue the permit before installa5on
Viola5on of permit or rule condi5ons Manufacture guarantees, design, good opera5ons management
All of the above and more Hire an experience permi2ng lead consultant!
Example Permi2ng Cases • Project 1: 580 MMBtu/hr Hydrogen Plant replacement at a
Refinery – Issue 1: Developer did not know emission offsets may be needed – Issue 2: CO emissions at startup exceeding 2,000 ppmv – Issue 3: Tight scheduling
• Project 2: Commercial Cogen Facility, 200 kW gas engine – Issue 1: Permit Moratorium requiring market emission offsets – Issue 2: First implementa5on of a output based standard lb/MW-‐hr,
VOC emissions – Issue 3: Permit cancelled for non-‐fee payment
• Project 3: Diesel Backup Project, 2 x 2 MW engines – Issue: Health Risk Assessment not passing cancer risk threshold for
mul5ple engines, filters required
Summary -‐ Air Permi2ng for Energy Projects
• Hire an experienced air permi2ng guide to navigate the process
• Start early, strategic planning will make a difference – Understand your energy project defini5on and alterna5ves that
can be considered – Know air permi2ng will impact project design, spend money
• Plan for the what can go wrong, you will be more prepared • Understand the 5 permi2ng steps, don’t skip the feasibility
review step • Work closely with agency staff through the applica5on stage
– understand requirements, nego5ate permit condi5ons • Be sure you are in compliance with all condi5ons at start and
during opera5on • Go get the Permit!
Contact Informa5on
James Westbrook BlueScape Environmental Mobile: 858-‐774-‐2009
[email protected] www.bluescapeinc.com
Connect with me on Linkedin!
The webinar presenta.on will be posted on Slideshare (search for BlueScape)
