This document provides an overview and agenda for a presentation on air permitting for energy project developers. It discusses the objectives of energy project permitting, the typical 5-step permitting process, common permitting issues and hurdles during project planning, potential things that can go wrong, permitting examples from energy projects, and concludes with a summary. The presentation aims to help those involved in energy projects, such as cogeneration, diesel engines, power plants and refineries, to better understand the air permitting process and objectives.
BlueScape Get the Air Permit for Energy Projects Webinar 9-10-13
1. Get the Permit!
Air Permitting for Energy
Project Developers
September 10, 2013
James A. Westbrook
jwestbrook@bluescapeinc.com
858-774-2009 mobile
2. 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
3. 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
4. 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
7. 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
!!
8. The
Permi2ng
Team
Host Facility
Project Developers
Permitting ConsultantEnergy Equipment
Vendor
Reviewing Agency
Attorneys
Air Pollution
Equipment Vendor Public Relations
Monitoring
Equipment Vendor
12. 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
13. 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
14. 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
16. 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?
17. 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
18. 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
19. 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
21. 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
23. 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?
25. 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
26. 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!
27. 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
28. 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!
29. Contact
Informa5on
James
Westbrook
BlueScape
Environmental
Mobile:
858-‐774-‐2009
jwestbrook@bluescapeinc.com
www.bluescapeinc.com
Connect
with
me
on
Linkedin!
The
webinar
presenta.on
will
be
posted
on
Slideshare
(search
for
BlueScape)