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Evaluation of Gas Turbine Air Quality Impacts from a Community Perspective

Steven Klafka, PEWingra Engineering, S.C.

2002 Electric Utilities Environmental Conference

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Introduction Recent deregulation of the utility industry

and the increased demand for electricity has resulted in the construction of new gas turbine generation stations throughout the U.S.

Wisconsin has been no exception with 37 new gas turbine stations and 14,990 megawatts of generating capacity proposed from 1998 to 2001.

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Wisconsin Gas Turbine Projects

0

1000

2000

3000

4000

5000

6000

7000

8000

Proposed Turbine Capacity (MW)

1998199920002001

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Community Reaction This has been the first experience of many

communities with new electrical generating facilities.

Some communities have rejected outright the construction of a new turbine station.

Others have accepted new stations after evaluation of the economic and environmental impacts.

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Rejection of New Power Plants

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Background A 1,050 MW combined cycle gas turbine generating

station was proposed for the Village of Pleasant Prairie, Wisconsin.

  Merchant power plant selling electricity wholesale.

On behalf of the village, a review was conducted of the draft air pollution control permit and support documents.

  Based on this review, the Village provided

suggestions to the WDNR for improving the project design.

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Gas Turbine Site

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Review of BACT Analysis Evaluation of Best Available Control

Technology analysis and comparison with control methods for similar turbine stations.

Concluded that the emission control methods and emission limitations proposed for the project represented BACT for recently constructed combined cycle gas turbines.

Recommended reductions in the emission limitations for VOC and H2SO4 to levels approved for a recent gas turbine project.

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Approved Limits and Emissions

Air Pollutan

t

ControlMethod

DischargeLimitation

Emissions

(tons/yr)

NOx Low-NOx burners & SCR

3.5 ppmdv at 15% O2 522

CO Oxidation Catalyst 4.0 ppmdv at 15% O2 1,097

SO2 0.003% Sulfur Nat. Gas

4.5 lbs per hour per combustor

80

PM Natural Gas Fuel 30.5 lbs per hour per combustor

543

VOC Oxidation Catalyst 1.2 ppmdv at 15% O2 62

H2SO4 Same as SO2 2.8 lbs per hour per combustor

49

NH3 None 10.0 ppmdv at 15% O2 478

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Review of Impact Analysis Evaluation of dispersion modeling analysis

used to determine compliance with air quality standards.

Verified modeling assumptions and procedures followed USEPA and WDNR protocols.

While the project complied with the National Ambient Air Quality Standards, it consumed the entire PSD increment for PM10.

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Air Quality Impacts of Turbine Project

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Review of Impact Analysis Recommended reduced emissions or

improved dispersion to allow future growth in the nearby industrial park.

Project proposed downwind VOC emission offsets due to location in ozone nonattainment area.

Recommended that offsets be obtained upwind of the project site to benefit village residents.

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Review of Ambient Monitoring Reviewed proposed monitoring and recordkeeping

requirements.

Project was exempted from pre-construction ambient monitoring requirements based use of background data available from other counties in the state.

Recommended the project include post-construction monitoring to determine background air quality for the project location and surrounding county.

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Review of Compliance Monitoring Recommended that the Village be kept

abreast of facility compliance.

Village should be provided copies of all pertinent air quality testing, monitoring and compliance certification documents.

Recommended compliance testing frequency be increased from every five to every two years.

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Project OutcomeThe final air quality permit for the turbine

project did not incorporate any of the proposed recommendations including:

$ Reduced VOC and H2SO4 limitations.

$ Reduced PM10 increment consumption.$ Purchase of VOC offsets upwind of site.$ Post-construction monitoring.$ Shared monitoring & record keeping.

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Project Outcome None of the Village’s

recommendations were incorporated into the project.

However, the Village concluded the recommendations provided leverage during negotiations for other aspects of the project such as infrastructure improvements and noise control.

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Project Redesign Shortly after receipt of an air

pollution control permit, the project was re-designed from 4 to 3 turbines and 1,050 to 1,080 MW capacity.

The new project design incorporated several of the recommendations made on the original project.

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Project Redesign Stack height was increased from 120 to 150

feet to reduce PM10 increment consumption.

Voluntary notification of Village staff when monitoring reports are submitted to WDNR.

Voluntary development of an industrial park consortium to monitor background air quality.

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Pick Sides or Compromise