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Home My WebLink About2010-05-19 PACKET 04.M.REQUEST OF CITY COUNCIL ACTION COUNCIL AGENDA MEETING ITEM 4 DATE 5/19/10 PREPARED BY Community Development Howard Blin ORIGINATING DEPARTMENT STAFF AUTHOR * k W W W W * * * * * * * * W W * W W W W * * * * * * * * * * * * W * W W W W W W W W W * * COUNCIL ACTION REQUEST Receive information on LS Power's proposal to the MPCA to modify the existing air emissions permit to allow a higher level of carbon monoxide to be emitted during start up conditions. STAFF RECOMMENDATION Receive information on LS Power's proposal to the MPCA to modify the existing air emissions permit to allow a higher level of carbon monoxide to be emitted during start up conditions. ADVISORY COMMISSION ACTION DATE ❑ PLANNING ❑ PUBLIC SAFETY ❑ PUBLIC WORKS ❑ PARKS AND RECREATION ❑ HUMAN SERVICES /RIGHTS ❑ ECONOMIC DEV. AUTHORITY ❑ ENVIRONMENTAL 5/12/10 SUPPORTING DOCUMENTS REVIEWED APPROVED DENIED ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ® MEMO /LETTER: Memo from Howard Blin dated 5/14/10 ❑ RESOLUTION: ❑ ORDINANCE: ❑ ENGINEERING RECOMMENDATION: ❑ LEGAL RECOMMENDATION: ® OTHER: Background information ADMINISTRATORS COMMENTS y L2 V City Administrator Date COUNCIL ACTION TAKEN: ❑ APPROVED ❑ DENIED ® OTHER 144�-M,4tmw) CITY OF COTTAGE GROVE MINNESOTA TO: Mayor and Members of the City Council Ryan Schroeder, City Administrator FROM: Howard Blin, Community Development Director DATE: May 14, 2010 RE: Draft Air Permit for LS Power Proposal LS Power has submitted a proposal to the Minnesota Pollution Control Agency (MPCA) to mod- ify their existing air emissions permit to allow a higher level of carbon monoxide to be emitted during start up conditions. The proposal was reviewed by the Environmental Commission. No comments on the permit modification are recommended. Background Cogentrix operates the LS Power facility located on Innovation Road adjacent to 3M Cottage Grove. The facility produces power during times of peak demand for Xcel Energy and also pro- vides steam to the 3M complex. The proposed permit modification would increase LS Power's short -term carbon monoxide emission limit from 1,200 pounds per hour to 1,900 pounds per hour. The permitted level of an- nual emission of 99 tons per year would not change as a result of this proposed modification. As described in the attached Technical Support Document for the permit, the increase limit is re- quested "to avoid periodic accidence of the existing limit during long startup periods during cold weather operation." As a point of comparison, in the most recent 12 -month monitoring period, LS Power emitted 38.3 tons of carbon monoxide, or 39 percent of their maximum allowable emissions. The fol- lowing are12 -month carbon monoxide emissions levels in 2007 for other sources in the area: Source CO Emissions Annually* Flint Hills Refinery 662.87 tons Marathon Refinery 454.17 tons Xcel King Generating Plant (Bayport) 130.42 tons 3M Maplewood Administrative Offices 57.77 tons 3M Cottage Grove Abrasive Systems 8.17 tons 3M Cottage Grove Incinerator 4.57 tons *Source: MPCA Honorable Mayor, City Council, Draft Air Permit for LS Power May 14, 2010 Page 2 of 2 and Ryan Schroeder The city's consulting engineer for air emission permit review, SEH, Inc., has reviewed the pro- posed modification. This resulted in a number of questions that were addressed by the MPCA. The questions and responses are attached. At their May 12 meeting, the Environmental Commission reviewed the proposal. The Commis- sion had the following questions, the answers for which were provided by Cogentrix. What is the duration of the start -up period? It typically takes 20 to 25 minutes to bring the generator up to operating temperature. Once at operating temperature, emissions typi- cally fall from 1, 200-1,900 pounds per hour to approximately 20 pounds per hour. How often are the generators started in a day and how would the permit modification affect the annual emissions limit? The generators are typically started once per day. In the past three years, only once have the generators been started twice in a day. Given this relatively limited number of start ups, annual emission levels can be met. After review of the proposal and the additional information provided, staff recommends that no comments on the permit proposal are necessary from the City. TECHNICAL SUPPORT DOCUMENT For DRAFT/PROPOSED AIR EMISSION PERMIT NO. 16300087 -005 This technical support document (TSD) is intended for all parties interested in the draft/proposed permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the draft /proposed permit. 1. General Information 1.1 Applicant and Stationary Source Location: Table 1. Applicant and Source Address Applicant /Address Stationary Source /Address (SIC Code: 4911) Cogentrix LSP Cottage Grove Cogeneration Facility 9405 Arrowpoint Boulevard 9525 105 "' Street Court South Charlotte, NC 28273 Cottage Grove Charlene Tuck Washington County (651) 459 -8339 ext. 226 CharleneTuck(a Cogentrix.com 1.2 Facility Description The LSP Cottage Grove Cogeneration Facility (facility) is an existing combined cycle steam - electric cogeneration facility. The facility consists of a 245 megawatt Westinghouse 501F combined cycle Combustion Turbine Generator (CTG) designed to provide electrical energy to Xcel Energy and to supply thermal energy as steam to an off -site customer. The CTG can bun either natural gas or distillate fuel oil, and is equipped with a heat recovery steam generator with Duct Burner (DB). There are also two identical natural gas- and distillate oil -fired auxiliary boilers each with a heat input capacity of 114 mmBtu/hr, a distillate oil storage tank, an emergency fire pump diesel engine, an emergency diesel generator, a fuel gas heater, and a cooling tower. An oxidation catalyst and Selective Catalytic Reduction (SCR) are used for the control of CTG/DB carbon monoxide (CO) and nitrogen oxides (NO respectively. The CTG operates in lean pre -mix mode (after startup) when combusting natural gas by using dry low -NO combustion. Water injection into the CTG combustor is used for NOx control when combusting fuel oil. CTG /DB NO and CO emissions are monitored with continuous emissions monitoring systems. Each auxiliary boiler has a NO predictive emissions monitoring system and a continuous opacity monitoring system. The facility was constructed at a time (mid 1990s) when the location was designated nonattainment for CO and SO As a result the facility is subject to a non- expiring Title I federally enforceable 99.0 ton per year Total Facility CO limit to avoid classification as a major source according to 40 CFR pt. 51, Technical Support Document, Permit Action Number: 16300087 -005 Page I of 4 Date: 4/20/2010 Appendix S as well as modeling based limits for S0 to reduce ambient S0 impacts. Even though the area is no longer classified as nonattainment, these limits remain in effect. 1.3 Description of the Activities Allowed by this Permit Action This is a major amendment to the existing title V operating permit. This amendment revises the CTG /DB stack (SV 001) 1 -hour CO limit from 1200 pounds per hour (lb/hr) to 1900 lb /hr. The existing and revised 1 -hour CO limits are based on modeling. Modeling demonstrates that facility CO emissions do not exceed the 1 -hour and 8 -hour CO significant impact levels (SILs). The facility requested the increased limit to avoid periodic exceedance of the existing limit during long startup periods during cold weather operation. This increase does not impact or change the 99.0 tpy CO total facility limit. This permit action also removes the SV 001 annual Acid Rain Certification Report requirement based on Section 72.90 due to recent revision of Section 72.90 which ended the requirement as of 2005. Also added to the permit were total facility New Source Review `reasonable possibility' recordkeeping and reporting requirements, and Minnesota requirements for recordkeeping of emission calculations when the Permittee determines that a change at the facility does not need a permit amendment, for complying with the permit appendices, and for restricting facility changes that may increase ambient impacts of S0 PM CO, and NO Finally, this action revises the facility description listing of the auxiliary boiler 2 COMS (MR 005; re- opening DQ #2472 and corrected by DQ #3031). 1.4. Facility Emissions: Table 2. Facility Classification Classification Major /Affected Synthetic Minor Minor Source PSD (list pollutant) NO PM, PM VOC PM 5, H2SO4 NAAR (list pollutant)* CO, S02 Part 70 Permit Program NO PM Io , PM2.5 VOC, CO, S0 HAPs (list pollutant) *The facility location is no longer designated nonattainment, however, title I CO and S0 limits taken by the facility in the PSD construction permit (to remain synthetic minor for CO and reduce ambient S0 impacts) remain in place. 2. Regulatory and /or Statutory Basis New Source Review 'The facility is an existing major source trader New Source Review, and this permit action does not change this status. The facility is subject to a non - expiring 99.0 ton per year (365 -day rolling sum) title I Total Facility CO limit. LSP agreed to accept the limit to avoid classification as a major source according to 40 CFR pt. 51 Appendix S. Although the area is no longer classified as nonattainment, the CO limit remains in the permit. Part 70 Permit Progra The facility is a major source under the Part 70 permit program. Technical Support Document, Permit Action Number: 16300087 -005 Page 2 of 4 Date: 4/20/2010 New Source Performance Standards (NSPS) This major amendment does not change any applicable New Source Performance Standards. National Emission Standards for Hazardous Air Pollutants (NF.,SHAP) No NESHAPS apply to the facility because the facility is not a major HAP source, and there are no applicable area source NESHAPs. Compliance Assurance Monitoring (CAM) This major amendment does not nigger CAM requirements. Environmental Review & AERA This major amendment does not trigger environmental review or risk assessment requirements. Minnesota State Rules This major amendment does not change any applicable Minnesota Standards of Performance. Table 3. Regulatory Overview of Units Affected by the Modification /Permit Amendment Subject Applicable Regulations Comments: Item 500 SV 001 Title I Condition: to restrict ambient I -hour CO limit is revised from 1200 lb /hr to 1900 2000 concentrations to less than significant lb /hr. Air modeling demonstrates that ambient 2001 levels in 40 CFR Section 51.165(b)(2); concentrations will not exceed the 1 -hour and 8 -hour 2002 Minn. R. 7007.4000 CO SILs (2000 ug m and 500 uglm', res ectively) 3.1 Emissions Calculations There are no potential emission changes authorized by or associated with this permit action. Although the hourly SV 001 CO limit has been increased, the annual total facility 99.0 tpy CO limit still remains effective and has not changed. 3.2 Modelina Results Revised modeling using the inputs in the attached spreadsheet indicated the 1 -hour and 8 -hour CO SILs would not be exceeded. Table 4 contains the results of the CO modeling. Table 4. Carbon Monoxide Modeling Results SIT, ug /m3 1 -hoar 8 -hour 2000 500 Calendar Year 2000 1208.93 323.93 2001 1196.24 305.07 2002 1246.91 340.88 2003 1188.75 297.51 2004 1165.92 369.94 Maximum 1246.91 369.94 % of SIL 62% 74% Technical Support Document, Permit Action Number: 16300087 -005 Page 3 of 4 Date: 4/20/2010 3.3 Periodic Monitoring There are no changes to periodic monitoring requirements associated with this permit action. 3.4 Insignificant Activities There are no changes to insignificant activities authorized by this permit action. 3.5 Comments Received Public Notice Period: April 1.5 — May 14, 2010 EPA 45 -day Review Period: April 15 — June 1, 2010 4. Permit Fee Assessment Attachment 3 to this TSD contains the assessment of Application and Additional Points used to determine the permit application fee for this permit action as required by Minn. R. 7002.0019. There are two components to a permit application fee; a base `application' fee and the `additional points' fee (for additional components that are part of a permit action including but not limited to modeling, BACT determination, NSPS review, etc.). This permit action includes one major amendment permit application and two re- openings. The application was received June 19, 2006 (before the July 1, 2009 rule effective date). Application fees are only charged for applications received after the July 1, 2009 rule effective date, and not for re- openings, and therefore no application fees are assessed for this permit action. However, additional points are assessed for an application based on the scope of the action regardless of the receipt date of the application. The major amendment application included air emissions modeling and as a result an additional points fee for the modeling review was assessed. 5. Conclusion Based on the information provided by Cogentrix, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 16300087 -005, and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. .Staff Members on Permit Team: Marshall Cole (permit writer /engineer) Bob Beresford (enforcement) Trevor Shearen (peer reviewer) Ruth Roberson (model review) AQ File No. 2776A; DQ 1131, 2472/3031 Attachments: 1. Revised Facility Description and CD -01 Forms 2. Modeling memorandum 3. Fee Assessment Worksheet Technical. Support Document, Permit Action Number: 16300087 -005 Page 4 of 4 Date: 4/20/2010 -A SEH MEMORANDUM TO: Jennifer Levitt, PE, City Engineer, City of Cottage Grove Howard Blin, Director — Community Development Department, City of Cottage Grove FROM: Thomas Henning, PE, CHMM DATE: May 14, 2010 RE: Responses to Issues Related to Draft Air Permit for Cogentrix SEH No. 109553 002 SEH reviewed the Minnesota Pollution Control Agency's (MPCA) responses to the City of Cottage Grove's comments on the Draft Air Permit for the Cogentrix facility (Permit Number 16300087 -005). MPCA's responses were included in an email dated May 11, 2010 from Marshall Cole with MPCA to Howard Blin with the City of Cottage Grove. The draft permit would change the facility's allowable short term carbon monoxide (CO) emission rate. MPCA's responses to the City's comments are paraphrased below: 1) As requested by the City, MPCA confirmed air dispersion modeling for the 8 -hour significant impact level was conducted using the maximum allowable emission rates. 2) As requested by the City, MPCA will modify the permit language to limit the short term CO emission increase to periods of startup and shutdown. 3) It is not technically feasible to operate the oxidation catalyst during startup and shutdown. 4) MPCA confirmed Cogentrix has a startup /shutdown plan designed to limit emissions and maintaining safety during these periods of operation. We believe MPCA's responses to the comments adequately address the City's concerns regarding the draft permit. TAH Short Elliott Hendrickson Inc., 3535 Vadnais Center Drive, St. Paul, MN 55110 -5196 SEP is an equal opportunity employer I v .sehinc.com [ 651.490.2000 1 800.325.2055 1 651,490.2150 fax Page 1 of 2 From: Cole, Marshall (MPCA) [Marshall. Cole@state.mn. us] Sent: Tuesday, May 11, 2010 6:05 PM To: Howard Blin Subject: RE: LS Power Permit Howard, thank you for your comments. I have copied them into this email and provided a response to each. 1. We suspect the 8 -hour air dispersion modeling evaluation was conducted at an emission rate somewhat less than 1,900 Whir over the 8 -hour period and request verification from MPCA of the emission rates used in the modeling. All sources at the facility were modeled for the 8 -hr SIL with maximum emissions for the entire 8 -hour period, except for emergency engines. For the emergency engines, the 8 -hour hourly emission input is 1/8 of the hourly emission rate, because the emergency engines only operate 1 hour at a time (for periodic testing), and modeling is not conducted for real emergency situations when the engines may operate somewhat longer than one hour. 2. We request that the 1,900 lb/hr emission rate be allowed only during the two hour startup period and a lower rate be allowed after startup (when the control equipment is operational). The lower emission rate should be used in the air dispersion modeling evaluation I added a sentence to the 1900 lb/hr limit clearly stating that the limit applies only during periods of startup and shutdown. There is no basis for imposing a second limit for normal operation especially considering the modeling results and the fact that the entire facility is limited to 99 tons per year of CO emissions on a 12 -month rolling sum. 3. If technically feasible, we request that the pollution control equipment be required to operate during startup and shutdown periods. Exhaust temperatures are too low to allow the CO control equipment (oxidation catalyst) to function during startup and shutdown, and therefore the permit does not and will not require operation of the CO control equipment during such periods. 4. We would like Cogentrix to prepare a startup /shutdown /malfunction plan to document the steps that Cogentrix will take to minimize the number of unexpected periods of high emission rates (i.e. malfunctions) and to minimize emissions during startup and shutdown periods. A combined cycle gas turbine, such as that at the LSP facility, is usually operated as an intermediate load plant. The combustion turbine undergoes startup and shutdown commonly on a daily basis as frequently as five to seven days a week, for up to 52 weeks each year. So, startup and shutdown are really a part of the routine operation of a combined cycle gas turbine electric generating plant. LSP has a startup /shutdown procedural plan for the combustion turbine. The purpose of the plan is to reduce emissions while ensuring plant safety during these periods of operation. Also, please be advised that this permit action pertains to revising the short term SV 001 CO limit 5/14/2010 Page 2 of 2 intended for startup and shutdown periods. The issue of malfunctions is not in the scope of this permit action. As stated at Minn. R. 7001.0110, subp. 1 (at this link ht #p_s:/ /www. revisor. m n_gov /ru_les / ?. id_ =_7001.01.10), comments must be limited to the portion of the permit that is proposed to be modified. Regardless, the permit already has a requirement to reduce emissions during shutdowns and breakdowns, and a prohibition on a source from operating if it experiences an excessive number of shutdowns (of control equipment) or breakdowns (of process or control equipment). In addition, LSP has economic incentive to not operate in the startup /shutdown mode (or to experience malfunctions) because it is costly and inefficient. Considering these facts and that the facility is not a major HAP source and therefore is not subject to the part 63, subp. YYYY MACT standard for stationary gas turbines, the MPCA does not think that a SSMP requirement is warranted or appropriate for this permit amendment. TIUM rIX n Minnesota Pollution Control Agency 18 Wood Lake Drive SE Rochester, MN 55904 ph. 507 /206 -2653 fax 507/280 -5513 marshap.cole state_mn.us This email has been scanned by the MessageLabs Email Security System. For more information please visit http: / /www.messagetabs.com/email 5/14/2010