Prevention of Significant Deterioration Air Construction Permit Application

Transcription

1 Report on the Prevention of Significant Deterioration Air Construction Permit Application Abengoa Bioenergy Biomass of Kansas Source Project No Updated January 2014

2 Prevention of Significant Deterioration Air Construction Permit Application prepared for Abengoa Bioenergy Biomass of Kansas Source Hugoton, Kansas Updated January 2014 Project No prepared by Burns & McDonnell Engineering Company, Inc. Kansas City, Missouri COPYRIGHT 2014 BURNS & McDONNELL ENGINEERING COMPANY, INC.

3 PSD Air Construction Permit Application Table of Contents TABLE OF CONTENTS Page No. 1.0 EXECUTIVE SUMMARY HAP Emissions Project NAAQS Impact Analysis BACT for Reciprocating Internal Combustion Engines BACT Analysis for Other Equipment Additional Impacts Analysis Modifications to Thermal Oxidizer in Current Permit Modifications to Emission Points in Current Permit Modifications to Boiler in Current Permit INTRODUCTION PROJECT OVERVIEW AND OBJECTIVES ABBK Facility Project Emission Unit Descriptions EMISSIONS ESTIMATES Introduction Emission Sources Engine Emissions RICE Start-Up Emissions Emergency Diesel-fired Fire Pump Emissions Biomass Boiler and Reheat Burner Methanol Tank Emissions Ethanol Load-out Thermal Oxidizer Emissions Material Handling Fugitive Emissions Biomass Storage Pile Emissions Facility Berm Construction Emissions HAP Emissions REGULATORY REVIEW PSD Regulations New Source Performance Standards CFR Part 60, Subpart IIII CFR Part 60, Subpart JJJJ National Emission Standards for Hazardous Air Pollutants (NESHAP) and Maximum Achievable Control Technology (MACT) Subpart ZZZZ Subpart DDDDD ABBK Energy, Inc. TOC-1 Burns & McDonnell

4 PSD Air Construction Permit Application Table of Contents Kansas Air Quality Standards and Regulations K.A.R to 304 Construction Permits and Approvals; Applicability K.A.R Prevention of Significant Deterioration of Air Quality K.A.R to 518 Operating Permit; Applicability K.A.R Opening Burning Prohibited K.A.R Emissions Opacity Limits Mandatory Reporting of Greenhouse Gases 40 CFR Part NAAQS Other Ambient Air Quality Standards Additional Impact Analysis Acid Rain (40 CFR Part 75) New Unit Utility Exemption BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS PSD BACT Process The Top-Down Process General Principles GHG BACT Process BACT Technology and Emission Limitations for Similar Units New Source Performance Standards Subpart JJJJ BACT For Nitrogen Oxides (NO x ) Non-Emergency RICE Step 1. Identify All Potential Control Technologies Step 2. Identify Technically Feasible Control Technologies Step 3. Rank the Technically Feasible Control Technologies Step 4. Evaluate the Most Effective Controls Step 5. Select NO x BACT Emission Limitation BACT For Carbon Monoxide (CO) Non-Emergency RICE Step 1. Identify Potential Control Strategies Step 2. Identify Technically Feasible Control Technologies Step 3. Rank the Technically Feasible Control Technologies Step 4. Evaluate the Most Effective Control Technologies Step 5. Select CO BACT Emission Limitation BACT For Sulfur Dioxide (SO 2 ) Non-Emergency RICE Step 1. Identify Potential Control Strategies Step 2. Identify Technically Feasible Control Technologies Step 3. Rank the Technically Feasible Control Technologies Step 4. Evaluate the Most Effective Control Technologies Step 5. Select SO 2 BACT Emission Limitation BACT for Volatile Organic Compounds (VOC) Non-Emergency RICE Step 1. Identify Potential Control Strategies Step 2. Identify Technically Feasible Control Technologies Step 3. Rank the Technically Feasible Control Technologies Step 4. Evaluate the Most Effective Control Technologies Step 5. Select VOC BACT Emission Limitation ABBK Energy, Inc. TOC-2 Burns & McDonnell

5 PSD Air Construction Permit Application Table of Contents BACT for Particulate Matter (PM/PM 10 /PM 2.5 ) Non-Emergency RICE Step 1. Identify Potential Control Strategies Step 2. Identify Technically Feasible Control Technologies Step 3. Rank the Technically Feasible Control Technologies Step 4 & 5. Evaluate and Select PM/PM 10 /PM 2.5 BACT Emission Limitation BACT for Greenhouse Gases (GHG) Non-Emergency RICE Introduction Step 1 and Step 2. Identify Potential Control Strategies and Eliminate Technologically Infeasible Options Step 3. Rank the Technically Feasible Control Technologies Step 4. Evaluate the Most Effective Control Technologies Step 5. Select GHG BACT Emission Limitation BACT for Emergency Diesel Fire Pump BACT for Nitrogen Oxides Emergency Diesel Fire Pump BACT for Carbon Monoxide Emergency Diesel Fire Pump BACT for Sulfur Dioxide Emergency Diesel Fire Pump BACT for Volatile Organic Compounds Emergency Diesel Fire Pump BACT for Particulate Matter (PM/PM 10 /PM 2.5 ) Emergency Diesel Fire Pump BACT for Greenhouse Gases Emergency Diesel Fire Pump BACT for Biomass-Fired Stoker Boiler and Biomass Boiler Reheat Burner BACT for Nitrogen Oxides (NO x ) Biomass-Fired Stoker Boiler and Biomass Boiler Reheat Burner BACT for Carbon Monoxide (CO) Biomass-Fired Stoker Boiler and Biomass Boiler Reheat Burner BACT for Sulfur Oxides (SO 2 ) Biomass-Fired Stoker Boiler and Biomass Boiler Reheat Burner BACT for Volatile Organic Compounds (VOC) Biomass-Fired Stoker Boiler and Biomass Boiler Reheat Burner BACT for Particulate Matter (PM/PM 10 /PM 2.5 ) Biomass-Fired Stoker Boiler and Biomass Boiler Reheat Burner BACT for Greenhouse Gases Biomass-Fired Stoker Boiler and Biomass Boiler Reheat Burner BACT for Volatile Organic Compounds (VOC) Methanol Tank Introduction BACT for Ethanol Load Out Thermal Oxidizer (EP-02100) Introduction BACT for Nitrogen Oxides Thermal Oxidizer BACT for Carbon Monoxide Thermal Oxidizer BACT for Sulfur Dioxide Thermal Oxidizer BACT for Volatile Organic Compounds Thermal Oxidizer BACT for Particulate Matter (PM/PM 10 /PM 2.5 ) Thermal Oxidizer BACT for Greenhouse Gases (GHG) Thermal Oxidizer BACT for Biogas/NCG Process Vent Thermal Oxidizer (EP-09100) ABBK Energy, Inc. TOC-3 Burns & McDonnell

6 PSD Air Construction Permit Application Table of Contents Introduction BACT for Volatile Organic Compounds Thermal Oxidizer BACT for Particulate Matter (PM/PM 10 /PM 2.5 ) Material Handling Fugitives Introduction BACT for Facility Berm BACT for Biomass Storage Piles BACT for Material Handling Transfer Points BACT for Particulate Matter (PM/PM 10 /PM 2.5 ) Ash Load-Out Points Introduction Step 1. Identify Potential Control Technologies Step 2. Identify Technically Feasible Control Technologies Step 3. Rank the Technically Feasible Control Technologies Step 4. Evaluate the Technically Feasible Control Technologies Step 5. Select Ash Load-Out Points BACT BACT for Particulate Matter (PM/PM 10 /PM 2.5 ) Fly Ash Silo Bin Vent Step 1. Identify Potential Control Technologies Step 2. Identify Technically Feasible Control Technologies Step 3. Rank the Technically Feasible Control Technologies Step 4. Evaluate the Technically Feasible Control Technologies Step 5. Select Fly Ash Silo Bin Vent BACT BACT for Volatile Organic Compounds (VOC) Storage Tanks Introduction Step 1 and Step 2. Identify Potential Control Strategies and Eliminate Technologically Infeasible Options Step 3. Rank the Technically Feasible Control Technologies Steps 4 and 5. Evaluate the Most Effective Control Technologies and Proposed BACT for VOC Emissions BACT for Volatile Organic Compounds (VOC) Fugitive Leaks and Loading Losses Introduction Step 1. Identify Potential Control Strategies Step 2. Identify Technically Feasible Control Technologies Step 3. Rank the Technically Feasible Control Technologies Step 4 & 5. Evaluate and Select Fugitive Leaks and Loading Losses BACT BACT for Volatile Organic Compounds (VOC) Lignin-Rich Stillage Storage Introduction Step 1. Identify Potential Control Strategies Step 2. Identify Technically Feasible Control Technologies Step 3. Rank the Technically Feasible Control Technologies Step 4 & 5. Evaluate and Select Lignin-Rich Stillage Storage BACT BACT for Volatile Organic Compounds (VOC) EH Fermentation Process Introduction ABBK Energy, Inc. TOC-4 Burns & McDonnell

7 PSD Air Construction Permit Application Table of Contents Step 1. Identify Potential Control Strategies Step 2. Identify Technically Feasible Control Technologies Step 3. Rank the Technically Feasible Control Technologies Step 4 & 5. Evaluate and Select EH Fermentation CO 2 Scrubber BACT AIR DISPERSION MODELING Air Dispersion Model Model Parameters Good Engineering Practice Haul Roads Storage Piles Flares Inventory of Neighboring Sources Modeling Methodology and Parameters Receptor Grid Meteorological Data Model Parameters Significant Impact Area Determination NAAQS and PSD Class II Increment Consumption Analysis Ambient Monitoring NO 2 Modeling Multi-Tiered Screening Approach Significance Model Results NO 2 Results CO Results PM 2.5 /PM 10 Results SO 2 Results PSD Class II Increment Modeling NAAQS Modeling PSD Class I Analysis Conclusion Analysis of Secondary PM 2.5 Formation Scheffe Ozone Analysis Representative Monitors Monitor Location Data Quality Currentness of Data Monitor Recommendations ADDITIONAL IMPACT ANALYSIS Construction Impacts Vegetation Impacts Nitrogen Oxides Synergistic Effects of Pollutants Particulate Matter ABBK Energy, Inc. TOC-5 Burns & McDonnell

8 PSD Air Construction Permit Application Table of Contents Carbon Monoxide Carbon Dioxide Soil Impacts Industrial, Residential, and Commercial Growth Impacts Visibility and Deposition Analysis Class I Area Analysis Visual Impairment Screening Assessment Conclusion REFERENCES APPENDIX A - FORMS APPENDIX B - LAYOUTS APPENDIX C - EMISSION CALCULATIONS APPENDIX D - RBLC APPENDIX E - MODELING PROTOCOL APPENDIX F - FIGURES APPENDIX G - MODELING FILES LIST OF TABLES Page No. Table 1-1: Project Potential Emissions and PSD Significance Levels Table 1-2: Summary of BACT Results: RICE Table 1-3: Summary of BACT Results: Other Equipment and Emission Points Table 1-4: Additional Emission Points at Enzymatic Hydrolysis Plant Table 2-1. Facility Potential Emissions and PSD Significance Levels Table 4-1: Non-Emergency RICE Maximum Expected Hourly Emission Rates Table 6-1: Summary of BACT Results: Non-Emergency RICE Table 6-2: Summary of BACT Results: Auxiliary Equipment Table 6-3: Summary of BACT Results: Material Handling Transfer Points Table 6-4: Table 6-5: Table 6-6: Table 6-7: Emission Rates for Engines Similar to Project Engines at Full Load (g/bhp-hr) Summary of Technically Feasible NO x Control Technologies for the Non- Emergency RICE Ranking of Technically Feasible NO x Control Technologies for the Non- Emergency RICE Summary of Technically Feasible CO Control Technologies for the Non- Emergency RICE ABBK Energy, Inc. TOC-6 Burns & McDonnell

9 PSD Air Construction Permit Application Table of Contents Table 6-8: Ranking of Technically Feasible CO Control Technologies for the Non- Emergency RICE Table 6-9: Summary of Technically Feasible VOC Control Technologies for the Non-Emergency RICE Table 6-10: Ranking of Technically Feasible VOC Control Technologies for the Non- Emergency RICE Table 6-11: Summary of Potential GHG Control Technologies Table 6-12: CO 2 Emission Factors for Various Fuels Table 6-13: Ranking of Potential Generating Technologies by Heat Rate Table 6-14: Power Plant Heat Rates and GHG Performance Table 6-15: Power Supply Sample Scenarios Table 6-16: GHG Technology Ranking for the Project Table 6-17: Summary of Potential NO x Control Technologies Table 6-18: Ranking of SO 2 Control Technologies for the Boiler Table 6-19: Ranking of PM Control Technologies for the Boiler Table 6-20: Ranking of GHG Control Technologies for the Boiler and Reheat Burner Table 6-21: Fly Ash Load-Out Technically Feasible Control Options Table 6-22: Bottoms Ash Load-Out Technically Feasible Control Options Table 6-23: Ash Load-Out Points BACT Emission Rates Table 6-24: Grain Handling Technically Feasible Control Options Table 6-25: Fly Ash Silo Bin Vent BACT Emission Rates Table 7-1: Combustion Engine Emissions and Modeling Parameters A Table 7-2. Emergency Fire Pump and Thermal Oxidizer Modeling Parameters Table 7-3: Fence Line Coordinates (Zone 14) Table 7-4: Background Level Table 7-5: NAAQS, Significance, and Monitoring Levels and PSD Class II Increment (μg/m 3 ) Table 7-6: In Stack Ratios Table 7-7: Maximum Modeled Concentrations Table 7-8: Increment Modeling Results Table 7-9: NAAQS Modeling Results Table 7-10: Modeled Highs Table 7-11: EPA s Cross-State Air Pollution Rule Emission Summary for Kansas Table 7-12: EPA s Cross-State Air Pollution Rule Modeling Results & Estimated Project Impact Table 7-13: EPA s Cross-State Air Pollution Rule Annual PM 2.5 Modeling Results & Estimated Project Impact ABBK Energy, Inc. TOC-7 Burns & McDonnell

10 PSD Air Construction Permit Application Table of Contents Table 7-14: Selected Monitors for Background Concentrations Table 8-1: Location of Class II Sensitive Areas Table 8-2: Distance to Class II Sensitive Areas and Flow Vectors Table 8-3: Joint Frequency Distribution Analysis Meteorological Conditions Table 8-4: Joint Frequency Distribution Analysis Meteorological Conditions Table 8-5: Table 8-6: Table 8-7: Table 8-8: Worst-Case Meteorological Conditions for Plume Visual Impact Calculations at the Cimarron National Grasslands WSW Wind Direction Sector Only Worst-Case Meteorological Conditions for Plume Visual Impact Calculations at the Cimarron National Grasslands W Wind Direction Sector Only Worst-Case Meteorological Conditions for Plume Visual Impact Calculations at the Hugoton Municipal Airport SSE Wind Direction Sector Only Worst-Case Meteorological Conditions for Plume Visual Impact Calculations at the Hugoton Municipal Airport S Wind Direction Sector Only Table 8-9: Level 2 VISCREEN Results for Cimarron National Grasslands Table 8-10: Level 2 VISCREEN Results for Hugoton Municipal Airport ABBK Energy, Inc. TOC-8 Burns & McDonnell

11 PSD Air Construction Permit Application Table of Contents LIST OF FIGURES Page No. Figure 3-1: Site Location... APPENDIX B Figure 3-2: Site Layout... APPENDIX B Figure 3-3: Fence Line... APPENDIX B Figure 3-4: Storage Pile Arrangement Figure 4-1: Process Flow Diagram...APPENDIX F Figure 7-1: 10 kilometer by 10 kilometer Cartesian Grid...APPENDIX F Figure 7-2: 50 kilometer by 50 kilometer Cartesian Grid...APPENDIX F Figure 7-3: Wind Speed and Wind Direction for Years APPENDIX F Figure 7-4: PSD NO 2 Annual Significance...APPENDIX F Figure 7-5: PSD NO 2 1-hour Significance...APPENDIX F Figure 7-6: PSD CO 1-hour Significance...APPENDIX F Figure 7-7: PSD CO 8-hour Significance...APPENDIX F Figure 7-8: PSD PM 10 Annual Significance...APPENDIX F Figure 7-9: PSD PM hour Significance...APPENDIX F Figure 7-10: PSD SO 2 Annual Significance...APPENDIX F Figure 7-11: PSD SO 2 24-hour Significance...APPENDIX F Figure 7-12: PSD SO 2 3-hour Significance...APPENDIX F Figure 7-13: PSD SO 2 1-hour Significance...APPENDIX F Figure 7-14: PSD PM 2.5 Annual Significance...APPENDIX F Figure 7-15: PSD PM hour Significance...APPENDIX F Figure 7-16: Increment NO 2 Annual...APPENDIX F Figure 7-17: Increment PM hour...APPENDIX F Figure 7-18 Increment PM 10 Annual...APPENDIX F Figure 7-19: Increment PM 2.5 Annual...APPENDIX F Figure 7-20: Increment PM hour...APPENDIX F Figure 7-21: Increment SO 2 Annual...APPENDIX F Figure 7-22: Increment SO 2 24-hour...APPENDIX F Figure 7-23: NAAQS NO 2 Annual...APPENDIX F Figure 7-24: NAAQS NO 2 1-hour...APPENDIX F Figure 7-25: NAAQS PM hour...APPENDIX F Figure 7-26: NAAQS PM 2.5 Annual...APPENDIX F Figure 7-27: NAAQS PM hour...APPENDIX F Figure 7-28: NAAQS SO 2 1-hour...APPENDIX F ABBK Energy, Inc. TOC-9 Burns & McDonnell

12 PSD Air Construction Permit Application Table of Contents Figure 7-29: Counties in Kansas... Page 7-19 Figure 7-30: Monitor Locations...APPENDIX F Figure 7-31: Primary Land Use ABBK...APPENDIX F Figure 7-32: Primary Land Use Dodge City, KS...APPENDIX F Figure 7-33: Primary Land Use Cedar Bluff, KS...APPENDIX F Figure 7-34: PM 10 Sources Surrounding ABBK...APPENDIX F Figure 7-35: PM 10 Sources Surrounding Dodge City Monitor...APPENDIX F Figure 7-36: PM 2.5 Sources Surrounding ABBK...APPENDIX F Figure 7-37: PM 2.5 Sources Surrounding Cedar Bluff Monitor...APPENDIX F Figure State of Kansas Population Density Map and the Location of PM 2.5 Monitors Compared to Project Site.... Page 7-23 ABBK Energy, Inc. TOC-10 Burns & McDonnell

13 PSD Air Construction Permit Application Version Date Remove for Final List of Abbreviations LIST OF ABBREVIATIONS Abbreviation Term/Phrase/Name a* color hue AERMOD AERMAP AMS/EPA Regulatory Model AERMOD s terrain pre-processor b* saturation BACT BPIP-PRIME CAA CCS CEM CFR CO CO 2 CO 2 e DEM EGU EPA Best Available Control Technology Building Profile Input Program-Plume Rise Model Enhancements Clean Air Act Carbon Capture and Sequestration Continuous Emission Monitor Code of Federal Regulations carbon monoxide carbon dioxide carbon dioxide equivalent (greenhouse gases) Digital Elevation Model Electric Generating Unit U.S. Environmental Protection Agency F degrees Fahrenheit FLAG FLM ft/s GEP g/cm 3 g/bhp-hr g/hp-hr H 2 SO 4 HAPs hp Federal Land Managers' Air Quality Related Values Work Group Federal Land Manager feet per second Good Engineering Practice gram per cubic centimeter gram per brake horsepower hour gram per horsepower hour sulfuric acid hazardous air pollutants horsepower ABBK Energy, Inc. i Burns & McDonnell

14 PSD Air Construction Permit Application Version Date Remove for Final List of Abbreviations Abbreviation K.A.R KDHE kpa kw LAER Term/Phrase/Name Kansas Administrative Regulations Kansas Department of Health and Environment kilopascals kilowatt Lowest Achievable Emission Rate L* brightness lb/hr lb/mmbtu MACT CH 4 MMBtu/hr MW NAAQS NAD NED NESHAP NSPS NO NO x NO 2 N 2 O NMHC OAQPS OLM PANs PBL PM PM 2.5 pound per hour pound per million British thermal units Maximum Achievable Control Technology methane million British thermal units per hour megawatt National Ambient Air Quality Standards North American Datum National Elevation Dataset National Emission Standard for Hazardous Air Pollutants New Source Performance Standards nitrogen oxide nitrogen oxides nitrogen dioxide nitrous oxide non-methane hydrocarbons Office of Air Quality Planning and Standards Ozone Limiting Method peroxyacetyl nitrates Planetary boundary layer particulate matter particulate matter of 2.5 microns in diameter or smaller ABBK Energy, Inc. ii Burns & McDonnell

15 PSD Air Construction Permit Application Version Date Remove for Final List of Abbreviations Abbreviation PM 10 ppm ppmvd PRIME PSD PVMRM RBLC RICE RMP ROI SCR SO 2 SO 4 TPY USGS UTM VOC μg/m 3 μm 4SLB Term/Phrase/Name particulate matter of 10 microns in diameter or smaller parts per million parts per million by volume, dry plume rise model enhancements Prevention of Significant Deterioration Plume Volume Molar Ratio Method RACT/BACT/LAER Clearinghouse reciprocating internal combustion engines risk management plan radius of impact selective catalytic reduction sulfur dioxide sulfate tons per year U.S. Geological Survey Universal Transverse Mercator volatile organic compounds micrograms per cubic meter micrometer 4 stroke lean burn ABBK Energy, Inc. iii Burns & McDonnell

16 PSD Air Construction Permit Application Executive Summary 1.0 EXECUTIVE SUMMARY Pursuant to the requirements specified in the Kansas Administrative Regulations (K.A.R) , Abengoa Bioenergy Biomass of Kansas, LLC (ABBK) submits this Prevention of Significant Deterioration (PSD) construction permit application for several changes to the existing facility (hereinafter referred to as the Project) located in Stevens County, Kansas, approximately 1.5 miles west of Hugoton, Kansas. On September 16, 2011, ABBK was issued a PSD permit for construction of this biomass-to-ethanol and biomass-to-energy production facility. On January 22, 2013, the PSD permit was amended for the construction of four natural gas-fired spark ignition emergency engines. This application amends the PSD permit once more to allow the emergency engines to operate in an unrestricted manner and for several other plant modifications. Even though the emissions increase associated with this application are below the PSD major project at a major source thresholds, for permitting purposes this project is considered a continuation of the previous PSD project and as such is subject to PSD review for PM, PM 10, PM 2.5, NO x, CO, VOC, SO 2, and CO 2 e. The requested modifications are as follows: 1. The ability to operate two of the four natural gas-fired emergency generators for 8,760 hours per year and the ability to sell excess generated electricity to the grid (but at an amount less than that which would trigger regulation under the Acid Rain regulations of 40 CFR Part 72) 2. Larger size for the emergency fire pump (617 hp instead of 460 hp) 3. The addition of a methanol tank to provide a carbon source to waste water treatment 4. An additional thermal oxidizer for ethanol load-out and clarification that the existing thermal oxidizer will be exclusive to the biogas waste treatment plant 5. Miscellaneous material handling fugitive emissions Building onsite berms made out of ash, dirt, and sand Increase in capacity of ground storage of biomass Miscellaneous transfer point for material handling 6. The addition of a 25 MMBtu/hr natural gas/biogas-fired reheat burner to the biomass boiler. The reheat burner will not change the BACT emission rates. 7. Reconfiguration of the biomass storage pile area 8. Reconfiguration of the ash handling system Abengoa Bioenergy Biomass of Kansas, LLC 1-1 Burns & McDonnell

17 PSD Air Construction Permit Application Executive Summary As required by the above-referenced rules, this permit application contains the following analyses/assessments regarding the emission of regulated pollutants associated with the construction and operation of the Project: Evaluation of ambient air quality in the area for each regulated pollutant for which the Project will cause a significant increase in net emissions Demonstration by air dispersion analysis that emissions from the Project will not cause or contribute to any exceedance of a National Ambient Air Quality Standard (NAAQS) Demonstration by air dispersion analysis that emissions from the Project will not exceed the remaining available PSD Class II increment consumption allowances Assessment of any adverse impacts on soils, vegetation, visibility, or growth in the area A Best Available Control Technology (BACT) analysis for each regulated pollutant for which the potential-to-emit (PTE) for the Project will result in a significant increase in net emissions PTE from the Project are shown in Table 1-1. Potential start-up emissions have not been included since they have been deemed negligible based on manufacturer s information. Total start-up time is expected to take less than two minutes, considerably less than the 30 minutes typically permitted for larger Wärtsilä or Caterpillar engines. A full description of equipment associated with the Project is provided in Part 3 of the application. Abengoa Bioenergy Biomass of Kansas, LLC 1-2 Burns & McDonnell

18 PSD Air Construction Permit Application Executive Summary Table 1-1: Project Potential Emissions and PSD Significance Levels Pollutant A September 16, 2011 Permit January 22, 2013 Permit- Changes due to this Application Total Facility Emissions After This Application PSD Significance Levels (TPY) PM C PM C PM NO x CO SO VOC Lead Sulfuric Acid (H 2 SO 4 ) CO 2 e 590, ,444 35, ,000 75,000 Total HAPs N/A Largest Single HAP N/A A NO x = nitrogen oxides; CO = carbon monoxide; SO 2 = sulfur dioxide; VOC = volatile organic compounds; PM= total particulate matter; PM 10 = particulate matter less than 10 microns in diameter; PM 2.5 = particulate matter less than 2.5 microns in diameter; CO 2 e = carbon dioxide equivalent (greenhouse gases); H 2 SO 4 Mist = sulfuric acid mist B Numbers in bold indicate the PSD significance level is exceeded 1.1 C Filterable plus condensable HAP Emissions The Project will be a major source of hazardous air pollutants (HAPs) (greater than 25 tons per year of total HAPs and greater than 10 tons per year of any single HAP). 1 Therefore sections of 40 CFR Part 63- National Emission Standards for Hazardous Air Pollutants (NESHAP) will apply to the Project. 1.2 Project NAAQS Impact Analysis The existing air quality in the Stevens County area is designated as attainment or unclassifiable with regard to the NAAQS for all criteria pollutants. A Project air dispersion modeling analysis was performed for the pollutants subject to PSD review to assess potential impacts on the NAAQS. The modeling was performed in accordance with relevant Kansas Department of Health and Environment (KDHE) and U.S. Environmental Protection Agency (EPA) modeling guidance. The air dispersion modeling protocol and Ozone Limiting Method (OLM) modeling protocol were submitted to both KDHE and EPA Region 7 for their review in June All sources of HAPs that are not major sources are categorized as area sources. Abengoa Bioenergy Biomass of Kansas, LLC 1-3 Burns & McDonnell

19 PSD Air Construction Permit Application Executive Summary The modeling analysis results (included in Part 7 of this application) demonstrate that the Project will not cause or contribute to a violation of any NAAQS. Further, the PSD Class II increment analysis demonstrates that Project impacts are less than the increment consumption allowances established for the area. Recent Federal Land Manager (FLM) guidance advises that a proposed major source, in the course of a PSD application, must perform an assessment of air quality impacts at Class I areas if these areas are located within approximately 300 kilometers of the proposed facility. As there are no Class I areas that are within 300 kilometers of the Project, an assessment of air quality impacts at Class I areas was not performed. 1.3 BACT for Reciprocating Internal Combustion Engines Two of the four reciprocating engines will be permitted for 8,760 hours per year operation. The other two engines will remain classified for emergency use only. A top-down BACT analysis was performed for each of the pollutants in Table 1-1 in which the PTE was above the associated PSD significance level: PM, PM 10, PM 2.5, NO x, CO, VOC, SO 2, and CO 2 e (greenhouse gases). Pre-combustion and controlled combustion systems coupled with state-of-the-art pollution control equipment and consistently achievable emission limitations have been selected as BACT for this Project. Emissions of NO x from the RICE will be limited by lean-burn combustion and further reduced and controlled by selective catalytic reduction (SCR) systems. Emissions of CO and VOC will be limited by good combustion practices and further reduced by oxidation catalysts (also referenced to as a CO catalyst). Use of clean fuels and good combustion practices will control emissions of PM/PM 10 /PM 2.5. Greenhouse gas emissions will be limited by the use of efficient lean-burn engines, and by use of natural gas as a fuel. Table 1-2 displays the BACT results. Abengoa Bioenergy Biomass of Kansas, LLC 1-4 Burns & McDonnell

20 PSD Air Construction Permit Application Executive Summary Table 1-2: Summary of BACT Results: RICE. A B C Pollutant NO x CO VOC Control Technology Selective Catalytic Reduction (SCR) System Good Combustion Practices, Oxidation Catalyst Good Combustion Practices, Oxidation Catalyst BACT Emission Limitation (lb/hr) A Equivalent Emissions B Averaging Time g/bhp-hr 30-day g/bhp-hr 30-day g/bhp-hr 30-day SO 2 Low sulfur fuels lb/mmbtu 30-day PM 10 /PM/ PM 2.5 CO 2 e Combustion Controls and Low Ash Fuels Use of Efficient Lean-Burn Engines, Use of Natural Gas, and Maintain Efficiency of Engines Through Maintenance Procedures NA 3-hr 2, lb/mmbtu Annual Maximum engine emission rate under steady state conditions unless otherwise noted. Equivalent emissions in gram per brake horsepower hour (g/bhp-hr) for loads of 50% and higher are shown for comparison to the RBLC emission rates purposes only. These are not proposed as BACT emission limitations. Due to the testing methods and sources of PM in the emission exhaust, PM is only expressed in lb/hr and it is not appropriate to determine an equivalent g/bhp-hr. In addition, the RBLC emission limitations are primarily expressed in lb/hr. 1.4 BACT Analysis for Other Equipment The other equipment to be permitted with this Project consists of a larger size fire pump engine than in the original permit, a methanol tank, a second thermal oxidizer, and miscellaneous material handling fugitives. A BACT analysis was performed for the pollutants in Table 1-1 that are emitted in total Project quantities above the PSD significance levels for the each of the auxiliary equipment. The following precombustion, combustion and pollution control equipment and operational practices have been established as applicable BACT requirements for the auxiliary equipment as shown in Table 1-3. Abengoa Bioenergy Biomass of Kansas, LLC 1-5 Burns & McDonnell

21 PSD Air Construction Permit Application Executive Summary Table 1-3: Summary of BACT Results: Other Equipment and Emission Points. Pollutant Emissions Unit Limiting Systems and Controls BACT Emission Limitation Emergency Fire Pump Combustion Control lb/hp-hr NO x CO Ethanol Load Out Thermal Oxidizer Low NO x Burner 0.55 lb/hr Reheat Burner SCR 0.3 lb/mmbtu Emergency Fire Pump Combustion Control lb/hp-hr Ethanol Load Out Thermal Oxidizer Good Combustion Practices 1.35 lb/hr Reheat Burner Oxidation Catalyst 0.22 lb/mmbtu Emergency Fire Pump Combustion Control lb/hp-hr VOC SO 2 PM/PM 10 /PM 2.5 Methanol Storage Tank Submerged Fill Pipe 0.12 tpy Ethanol Load Out Thermal Good Combustion Oxidizer Practices 7.95 lb/hr Biogas/NCG Process Vent Good Combustion Thermal Oxidizer Practices 0.14 lb/hr Reheat Burner Oxidation Catalyst lb/mmbtu Storage Tanks See Section Fugitive Leaks and Loading Losses LDAR program Lignin-Rich Stillage Storage Temperature Control 0.39 lb/hr EH Fermentation Process Packed-Tower Wet Scrubber 2.71 lb/hr Emergency Fire Pump Low Sulfur Fuels lb/hp-hr Ethanol Load Out Thermal Oxidizer Reheat Burner Emergency Fire Pump Ethanol Load Out Thermal Oxidizer Facility Berm Biomass Storage Pile Treated Biogas and Pipeline Grade Natural Gas Only Good Combustion Practices and Use of Low Sulfur Fuel Combustion Controls and Low Ash Fuels 1.17E-07 lb/hr lb/mmbtu lb/hp-hr Smokeless Design lb/hr Wet Suppression, Fugitive Dust Management Plan Compaction of Material in Bales and Fugitive Dust Management Plan tpy PM tpy PM tpy PM tpy Abengoa Bioenergy Biomass of Kansas, LLC 1-6 Burns & McDonnell

22 PSD Air Construction Permit Application Executive Summary Pollutant CO 2 e Emissions Unit Reheat Burner Material Handling Transfer Points Limiting Systems and Controls Good Combustion Practices and Use of Low Ash Fuel Fugitive Dust Management Plan Ash Load-Out Points See Section BACT Emission Limitation 0.01 lb/mmbtu Fly Ash Silo Bin Ven See Section Selection of the Most Emergency Fire Pump Efficient Engines that Meet the Applicant s Project lb/mmbtu Needs Ethanol Load Out Thermal Good Combustion Oxidizer Practices 1,808 lb/hr Biogas Boiler and Reheat Burner Energy-Efficient Design 112,925 lb CO 2 e/hr N/A 1.5 Additional Impacts Analysis The potential impacts of the Project on visibility, soils, vegetation, and growth are discussed in Part 8 of this application. As shown by the analysis, the addition of the Project will not have a significant impact on visibility, soils, growth, or vegetation in the surrounding area. 1.6 Modifications to Thermal Oxidizer in Current Permit It has been determined that two thermal oxidizers will be required for the facility. The already permitted product load-out vapor recovery/biogas thermal oxidizer (EP-09001) will now only control biogas. A new thermal oxidizer will be installed (EP-02100) to control the product load-out vapor recovery emissions. Emissions estimates and design details for the new thermal oxidizer are included in this permit application. The current permit will need to be changed as follows: Section III G. Ethanol Load-out One (1) Truck/Railcar Loading Terminal for the purpose of transferring denatured ethanol to trucks and railcar for shipment offsite. Truck and railcar loading shall be equipped with a vapor collection system that is routed to either the biomass-fired stoker boiler or thermal oxidizer for destruction of collected load-out vapors. 1. One (1) product load-out thermal oxidizer (EP-09001EP-02100): with maximum design heat input rate of 51 MMBtu/hr 12 MMBtu/hr for emissions control of vapor Abengoa Bioenergy Biomass of Kansas, LLC 1-7 Burns & McDonnell

23 PSD Air Construction Permit Application Executive Summary recovery during product load-out. as well as for back-up destruction of biogas and NCG process vent flow normally combusted in the biomass-fired stoker boiler. Section IV E. One (1) Product Load-out Vapor Recovery/ Biogas Thermal Oxidizer (EP-09001) 1. The BACT limit for the product load-out vapor recovery/biogas thermal oxidizer shall be 20,166 short tons CO 2 e/yr during any twelve (12) consecutive month period. The hours of thermal oxidizer operation shall be limited to no more than 3,960 hours per consecutive 12 month period. 2. GHG BACT for the product load-out vapor recovery/biogas thermal oxidizer (EP-09001) is the installation/implementation of: Section VI. Table 2 Summary of Emission Units Subject to GHG PSD BACT Limits The forth row, second column needs to read Biogas Thermal Oxidizer. Section VI K. Product Load-out Vapor Recovery/Biogas Thermal Oxidizer (EP-09001) 1.7 Modifications to Emission Points in Current Permit It has been determined that several pieces of equipment in the Enzymatic Hydrolysis Plant will need to be removed or changed in the current permit, due to a better understanding of the plant and a numbering system that more accurately follows the process. ABBK is requesting that these changes be made to the existing permit. The emission points listed below are the same as the units permitted, but will need their emission point numbers and some of their descriptions changed: EP Floor Sweep System DC changed to EP Floor Sweep System DC EP Classifier Cyclone #1 DC changed to EP EH Storage Bin #1 DC EP Classifier Cyclone #2 DC changed to EP EH Storage Bin #2 DC EP Boiler Feed System DC changed to EP Boiler Feed System DC The emission point listed below will need to be removed from the permit, due to different units being installed in its place: EP Bale Grinder DC Abengoa Bioenergy Biomass of Kansas, LLC 1-8 Burns & McDonnell

24 PSD Air Construction Permit Application Executive Summary The emission points listed below will need to be added to the permit, as ABBK s understanding of the process now requires these additional control devices. Table 1-4: Additional Emission Points at Enzymatic Hydrolysis Plant Unit PM (lb/hr) PM 10 (lb/hr) PM 2.5 (lb/hr) PM (tpy) PM 10 (tpy) PM 2.5 (tpy) EP Dirt/Fines Silo Vent EP Biomass Boiler Storage Bin DC EP Dust Collection System DC # EP Dust Collection System DC # Modifications to Boiler in Current Permit According to the vendor, the emissions limits provided in the original permit could not be met without additional equipment. Therefore, ABBK has added a 25 MMBtu/hr natural gas/biogas-fired reheat burner. The biomass boiler reheat burner will be a part of the biomass-fired stoker boiler, and will vent through the same stack as the boiler. The addition of the reheat burner will not increase the BACT emission rates for NO 2, CO, or VOC of the boiler, as it acts as a control device for the boiler. The annual natural gas capacity factor of less than 10% will now apply to both the boiler and the reheat burner. The emission limits provided in the original permit will now cover both the boiler and reheat burner. The emission limits will be met by the modified unit. Abengoa Bioenergy Biomass of Kansas, LLC 1-9 Burns & McDonnell

25 PSD Air Construction Permit Application Introduction 2.0 INTRODUCTION Abengoa Bioenergy Biomass of Kansas, LLC (ABBK) submits this Prevention of Significant Deterioration (PSD) construction permit application for several changes to the existing facility (hereinafter referred to as the Project) located in Stevens County, Kansas, approximately 1.5 miles west of Hugoton, Kansas. On September 16, 2011, ABBK was issued a PSD permit for construction of this biomass-to-ethanol and biomass-to-energy production facility. On January 22, 2013, the PSD permit was amended for the construction of four emergency, 10-C1750 N6C Cummins natural gas-fired spark ignition reciprocating internal combustion engines (RICE). This application amends the PSD permit once more to allow two of the four emergency engines to operate in an unrestricted manner and for several other plant modifications. Even though the emissions increase associated with this application are below the PSD major source thresholds, for permitting purposes this project is considered a continuation of the previous PSD project and as such is subject to PSD review for PM, PM 10, PM 2.5, NO x, CO, VOC, SO 2, and CO 2 e. The Project is located in Stevens County, Kansas, which is designated as attainment or unclassifiable with regard to the National Ambient Air Quality Standards (NAAQS) for all criteria pollutants. A Project air dispersion modeling analysis was performed for the pollutants subject to PSD review to assess potential impacts on the NAAQS. The modeling analysis results (included in Part 7 of this application) demonstrate that the Project will not cause or contribute to a violation of any NAAQS. Further, the PSD Class II increment analysis demonstrates that Project impacts are less than the increment consumption allowances established for the area. Table 2-1 identifies the PTE of the facility after implementation of the Project. The potential air emissions are based on unrestricted operation of the four engines and also include emissions from the auxiliary equipment proposed as part of this Project. Potential start-up emissions have not been included since they have been deemed negligible based on manufacturer s information. Total start-up time is expected to take less than two minutes, considerably less than the 30 minutes typically permitted for larger Wärtsilä or Caterpillar engines. A full description of equipment associated with the Project is provided in Part 3 of the application. Abengoa Bioenergy Biomass of Kansas, LLC 2-1 Burns & McDonnell

26 PSD Air Construction Permit Application Introduction Table 2-1. Facility Potential Emissions and PSD Significance Levels Pollutant A Preliminary Estimated Potential Emissions (Tons per Year [TPY]) B PSD Significance Levels (TPY) NO x SO CO PM C PM C PM VOC Lead H 2 SO 4 Mist CO 2 e 626, ,000 A NO x = nitrogen oxides; CO = carbon monoxide; SO 2 = sulfur dioxide; VOC = volatile organic compound; PM= total particulate matter; PM 10 = particulate matter less than 10 microns in diameter; PM 2.5 = particulate matter less than 2.5 microns in diameter; CO 2 e = carbon dioxide equivalent (greenhouse gases); H 2 SO 4 Mist = sulfuric acid mist B Numbers in bold indicate the PSD significance level is exceeded C Filterable plus condensable As shown by the above table, the Project will result in emission increases above the significance level for PM, PM 10, PM 2.5, NO x, CO, VOC, SO 2, and CO 2 e. (greenhouse gases or GHG). Therefore, these pollutants will be subject to PSD review. The Project will be a major source of HAPs (greater than 25 tons per year of total HAPs and greater than 10 tons per year of any single HAP) and will be subject to National Emission Standards for Hazardous Air Pollutants (NESHAP) (40 CFR Part 63) to the degree they are applicable to the Project. This construction permit application is divided into the following sections: Part 1 Executive Summary Part 2 Introduction Part 3 Project Description Part 4 Emissions Estimates (this section provides estimates of emissions associated with the Project) Part 5 Regulatory Review (this section identifies applicable state and federal air quality regulations) Part 6 Best Available Control Technology (BACT) Analysis Abengoa Bioenergy Biomass of Kansas, LLC 2-2 Burns & McDonnell

27 PSD Air Construction Permit Application Introduction Part 7 Air Dispersion Modeling (this section provides model descriptions and data requirements for the air quality impact assessment as well as interpretation, analysis, and comparison of the modeling results with applicable air quality regulations) Part 8 Additional Impact Analysis (this section addresses other potential air quality-related impacts (i.e., growth, soil, vegetation, and visibility)) Construction permit application forms required by the Kansas Department of Health and Environment (KDHE) are included in Appendix A of this application. Abengoa Bioenergy Biomass of Kansas, LLC 2-3 Burns & McDonnell

28 PSD Air Construction Permit Application Project Overview and Objectives 3.0 PROJECT OVERVIEW AND OBJECTIVES ABBK s facility will be located approximately 1.5 miles west of Hugoton, Kansas. Stevens County is currently designated as an attainment/unclassified area for all criteria pollutants. See 40 CFR Part 81 for more information on attainment status designations. The location of ABBK facility is shown in Figure 3-1 (Appendix B). A scaled site layout showing the existing plant and equipment is shown in Figure 3-2 (Appendix B). A second scaled site layout showing the existing plant and fence line is shown in Figure 3-3 (Appendix B). 3.1 ABBK Facility Project The Project will consist of unrestricting the hours of operation of two of the four existing RICE, increasing the size of the emergency fire pump, adding a methanol tank, adding a thermal oxidizer for ethanol load-out, and miscellaneous material handling resulting in an increase of fugitive emissions. The emergency fire pump is still proposed to be permitted to operate up to 100 annual hours and its use will be limited primarily to testing and maintenance. Maximum potential annual emissions from the Project are presented in Table Emission Unit Descriptions The following subsections briefly describe the emission units that will be constructed as part of the Project RICE Engines and Emission Controls The four existing RICE are natural gas-fired C1750 N6C Cummins engines. Each engine was originally permitted as an emergency engine, but two of the four engines will now be amended for unrestricted hours of operation to meet the projected energy and capacity demands of ABBK. To control emissions of NO x, each unrestricted engine will be equipped with selective catalytic reduction (SCR) systems and lean-burn combustion systems. To minimize the emissions of SO 2, H 2 SO 4 mist and PM/PM 10 /PM 2.5, the engines will be controlled through the use of low-sulfur/low ash fuels and good combustion practices. Emissions of CO and VOC will be controlled through the use of good combustion practices as well as an oxidation catalyst (also referred to as a CO catalyst). Greenhouse gas (GHG) emissions will be minimized with the use of efficient lean-burn engines and the use of natural gas fuel Emergency Diesel Fire Pump An emergency diesel-fired fire pump was previously permitted, but as part of this application it will be increased from 460 hp to 617 hp. The fire pump will be used for emergency purposes to pump water in Abengoa Bioenergy Biomass of Kansas, LLC 3-1 Burns & McDonnell

29 PSD Air Construction Permit Application Project Overview and Objectives the event of a fire and will be limited to 100 hours per year of operation for testing and maintenance. It will be fired solely by low-sulfur diesel/number 2 fuel oil (ULSD) with a maximum sulfur content of 15 ppm Biomass Boiler and Reheat Burner A Biomass Boiler and Reheat Burner will be installed with a combined heat input of 525 MMBtu/hr. The boiler will fire different types of biomass and can fire natural gas as an alternative fuel. The 25 MMBtu/hr Reheat burner will fire natural gas and biogas exclusively to raise the temperature of the biomass boiler s exhaust stream to the optimum temperature for the SCR and oxidation catalyst to operate Methanol Tank A methanol tank with approximately 41,000 gallons capacity will be installed at ABBK facility to provide a carbon source to waste water treatment. The tank will be equipped with an internal floating roof system that minimizes vapor discharge to the atmosphere Ethanol Load-out Thermal Oxidizer One thermal oxidizer with a maximum design heat input rate of 12 MMBtu/hr will be installed at ABBK facility for ethanol emissions control during product load-out. The thermal oxidizer will combust ethanol vapors recovered from load-out as well as natural gas pilot gas Material Handling Eight additional fugitive loading and conveying emission points will be added to the process of transferring biomass. These eight points are as follows: Bottom ash load-out roll-off dumpster Fly ash production silo entrance Fly ash offloading Wet cake production filter press and conveyor Wet cake emergency pad (used for emergency events only) and reclaim conveyors Washed sand load-out roll-off dumpster Dirt production grinding lines Dirt offloading Abengoa Bioenergy Biomass of Kansas, LLC 3-2 Burns & McDonnell

30 PSD Air Construction Permit Application Project Overview and Objectives Biomass Storage Agricultural residues and energy crops (biomass) will be delivered in tightly bound bales primarily on flatbed/module/custom trucks. On a 150 acre section at the west side of the property, 12 storage divisions will be arranged. Each division will consist of four stacks of 600 tons each. Each stack will be six bales high (18 feet) by five bales wide (40 ft) by 40 bales long (160 feet). The total biomass storage will be 28,800 tons. See Figure 3-4. Figure 3-4: Storage Pile Arrangement Facility Berm ABBK will build a berm around the existing facility with by products from the biomass-to-ethanol and biomass-to-energy production facility. The dirt and sand removed from the biomass before it is processed along with a small amount of fly ash will be used to construct the berm. ABBK estimates that the berm will be continuously constructed at a rate of approximately 1,500 linear feet per year. The berm will be 15 feet tall and have an approximate base width of 150 feet. Abengoa Bioenergy Biomass of Kansas, LLC 3-3 Burns & McDonnell