BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
1
1
PROPOSED NEW CAIR SO2, CAIR NOx
1
ANNUAL AND CAIR NOx OZONE SEASON
)
R06-26
TRADING PROGRAMS, 35 ILL. ADM.
1
(Rulemaking- Air)
CODE 225, CONTROL OF EMISSIONS
1
FROM LARGE COMBUSTION SOURCES,
1
SUBPARTS A, C, D and E
1
NOTICE OF FILING
To:
See Attached Certificate of Service
PLEASE TAKE NOTICE that on November 10,2006, we filed with the Clerk of the
Illinois Pollution Control Board the attached Testimony of Jason
M. Goodwin, a copy of which
is attached hereto and hereby served upon you.
Dated: November 10,2006
Steven
J. Murawski
Sasha M. Reyes
BAKER
&
MCKENZIE LLP
One Prudential Plaza, Suite 3500
130 East Randolph Drive
Chicago, IL 60601
+13128618000
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
1
)
PROPOSED NEW CAIR SO2, CAIR NOx
1
ANNUAL AND CAIR NOx OZONE SEASON
)
R06-26
TRADING PROGRAMS, 35 ILL. ADM.
1
(Rulemaking- Air)
CODE 225, CONTROL OF EMISSIONS
1
FROM LARGE COMBUSTION SOURCES,
)
SUBPARTS A, C, D and E
1
TESTIMONY OF JASON M. GOODWIN
My name is Jason M. Goodwin and I am submitting comments in the above-cited
rulemaking on behalf of Zion Energy LLC (Zion). Zion owns and operates a peaking power
electric generating facility called the Zion Energy Center located at 5701 West
91h Street, Zion,
Illinois (Facility). I appreciate the opportunity to provide these comments to the Illinois
Environmental Protection Agency (Illinois EPA) and the Illinois Pollution Control Board
(Board) as part of the state's proposal to develop and implement a state-based Clean Air
Interstate Rule (CAIR), 35 IAC Part 225 (Proposed Rule).
BACKGROUND
I am the Director of Environmental, Health
&
Safety for Calpine Corporation's (Calpine)
Eastern Power Region through its subsidiary Calpine Operating Services Company, Inc.
(COSCI). In that position,
I am responsible for the implementation and management of
environmental, health and safety (EHS) programs for
28 power generating facilities in 1 5 states.
I have more than 13 years of experience in developing and managing EHS compliance programs
that support the needs of a large, geographically diverse operating fleet, new project and business
development opportunities throughout the United States, and coordination of due diligence and
acquisition activities on both the buyer's and seller's side. I have a significant amount of policy
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
and regulatory development experience on the state and federal levels largely focused on air
quality issues, and I currently serve as Calpine's primary technical resource for federal air
quality-related policy matters such as New Source Review, CAIR and similar national and multi-
state regulatory programs.
My relationship with Zion and the Facility is through COSCI. Specifically, Zion holds
a
contract with COSCI for the provision of operations, maintenance and other related support
services. This contract includes my EHS program development support, as well as my
environmental policy development and guidance services.
The Facility
(I.D. No. 0977200ABB) generates electricity using three 160 MW natural
gas-fired turbines with distillate oil as back-up fuel (Turbines). It is a major source of carbon
monoxide (CO) and nitrogen oxides (NO,) for purposes of the Illinois Clean Air Act Permit
Program (CAAPP) and therefore holds a CAAPP permit (No. 02120057). The Facility also
holds an Acid Rain Permit (No. 55392) and is a budget source for purposes of the Illinois EPA7s
NOx Trading Program.
The Turbines at the Facility were constructed between August 2001 and September 2003.
All of the Turbines operate during peak electricity demand periods and are equipped, operated
and maintained with low NO, combustors for natural gas firing and water injection for oil firing.
COMMENTS ABOUT THE PROPOSED CAIR RULE
While Zion endorses many aspects of the Proposed Rule as discussed immediately below,
it maintains serious concerns regarding certain provisions of the proposal that seem to ignore the
Proposed Rule's unreasonable, inequitable and detrimental impacts and constraints on natural
gas-fired simple-cycle combustion turbine generating units like Zion's, which are commonly
used in peaking facilities throughout Illinois.
&
Illinois EPA Statement of Reasons, p. 25.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
In particular, due to technical and operational limitations, large-frame simple cycle
combustion turbines are precluded from making additional reductions in NO, emissions.
Therefore, such facilities face a substantial risk to their ability to consistently generate power
during peak demand due to foreseeable unit curtailments and shutdowns if Illinois EPA reduces
the overall
NOx allowance pool or otherwise retires NOx allowances pursuant to the Proposed
Rule. That is because supplemental NO, reductions from the simple-cycle combustion turbine
generating units will not be possible, the Proposed Rule limits
NOx emission allocations to
natural gas fired units, and the number of remaining
NOx allowances available for purchase on
the market (any time Illinois EPA reduces the
NOx
allowance cap) will likely be severely limited
and cost prohibitive.
Moreover, fuel weighting in favor of fossil fuels other than natural gas will unfairly make
the cost of compliance with the Proposed Rule substantially more expensive on a cost per ton
basis for sources like Zion, that have recently invested a significant amount of capital for
agency-
approved emissions control technology.
-
1.
Positive Elements of the Proposed Rule
Zion supports specific elements of the Proposed Rule as more
hlly described below.
A.
Cap and Trade Program
Zion supports the Illinois
EPA7s choice to propose and implement a cap and trade in its
Proposed Rule. From Zion's perspective, a cap and trade program is better than establishing
unit-specific emission limits for electric generating units
(EGUs) because, if implemented
properly, a cap and trade program offers regulated sources a more equitable, flexible and
economically feasible way to achieve the state's emissions goals.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
B.
Annual Review and Redistribution of Allowances
Zion strongly supports the concept of annual review and redistribution of allowances in
the years 201 2 and beyond, as well as the concept of determining allocations three years in
advance of the compliance year. Such a system appropriately takes into account changes in the
makeup of the affected facility mix within the state, provides for the truest picture of market
conditions and allows for timely incorporation of new sources that begin operation after the
state's CAIR program is implemented. More specifically, frequent redistribution of the
allowance pool provides for the highest level of consistency between actual operation of
EGUs
and the allocation of emission credits, and is the best and most accurate way to reflect the
prevailing conditions of the power market. Furthermore, shorter delays between the time when
allocations are calculated improves the linkage between the data used to apportion allowances
and the expected compliance demands.
C.
Initial Allocation Pool and Operating Baseline
Zion supports the idea of including all units operating prior to January 1,2006 in the
initial allocation pool. Zion also supports the option to consider less than five years of operating
data when establishing the operating baseline. Zion believes that these two elements of the
Proposed Rule will ensure that more units are allocated from the main pool at the start of the
program, which will reduce the potential of diminished allocations for new sources with limited
operating history that have to request allocations from a relatively small new source pool.
D.
New Unit Set Aside (NUSA)
Zion supports the establishment of a
5% new unit set-aside (NUSA) pool in Phase 1 and
Phase
2 of the Proposed Rule's implementation. More importantly, Zion approves of the
exceptional process for integrating new units into the main allowance pool in an expedited
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
fashion. This process provides a clear recognition that companies employing new units have
already made significant control investments that are much more substantial than control
investments likely to be required of older existing units on a cost per ton basis. Furthermore,
without including the Illinois
EPA's proposed timely integration, the rule would require the
newest and cleanest EGUs to inequitably divide a progressively smaller NUSA pool among an
increasing number of EGUs over an extended period of time.
E.
Allocation Baseline
Zion supports the incorporation of steam energy from certain Combined Heat and
Powerlcogeneration facilities (Cogens) when determining the allocation baselines. Cogens offer
an efficient and environmentally benign way of providing both electrical and thermal energy to
end users. Consequently, those units rightly should get credit for electrical output and thermal
output. While such incorporation doesn't directly affect Zion because it doesn't own or operate
such units at the Facility, it is still a good idea.
Cogeneration facilities are commonly based on combined-cycle combustion turbine
generating technology. In general, a combined cycle system operates by harnessing the exhaust
heat
from combustion turbines, converting this heat into steam and then using it to generate
electric power through a steam turbine. Instead of using all of the steam to generate electricity,
cogeneration facilities operate somewhat differently by diverting some of the steam away from
the steam turbine generator and providing it to industrial customers for use in other processes.
Because cogenerators divert some of their steam away from the steam turbine generator, the
electrical generating efficiency is somewhat less compared to a traditional combined-cycle plant.
Zion believes that cogenerators should be rewarded, not penalized, for making beneficial use of
this technology. Except for Illinois
EPA's use of fuel-weighting to assign the steam energy
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
credit, a concept which Zion opposes, the Proposed Rule seems to properly recognize this
concept.
-
11.
Elements of the Proposed Rule that Require Reconsideration and Revision
Zion contends that the Illinois EPA and the Board should reconsider and revise certain
portions of the Proposed Rule as described below.
A.
Fuel Adjustment Factors
The Illinois EPA7s proposed use of fuel adjustment factors to allocate
NOx emission
allowances should be eliminated. Despite the Illinois EPA7s reasons for proposing fuel
adjustment factors, reduction of allocations based on fuel type creates an artificial signal that
shields the true cost of emission reductions
from sources that have the largest proportion of
emissions. TSD, Section 9.2.1
;
Hearing Transcript, October 1 1, 2006 (Morning), 127: 15
-
130:8. By reducing the number of issued allowances to facilities that generate power with
cleaner burning fuels (such as natural gas), fuel adjustment factors effectively require those
facilities to meet emission limits that are more stringent than those faced by coal-fired facilities.
Elimination of fuel adjustment factors will provide a more equitable distribution of NO,
allowances, allow affected sources to meet the same standard, and avoid artificial influences that
would distort the cost of compliance.
See
also
Illinois EPA Exhibit 16, p. 5 (STAPPAIALAPCO
endorsement of fuel neutral allocation).
While it is true that the model federal CAIR rule includes fuel weighting provisions
similar to the ones proposed by the Illinois EPA, those fuel weighting provisions are not
mandatory.
40 CFR
551.123; Illinois EPA Statement of Reasons, p. 30. In fact, the U.S.
EPA states that
"[flor NOx allowances, each state has the flexibility to allocate its allowances
however they choose, so long as certain timing requirements are met." 70 Fed. Reg. 251 62,
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
25278 (May 12,2005). "States also have discretion in determining their CAIR NOx allowance
allocation methodology, as long as they demonstrate they will meet their budget." Illinois EPA
Statement of Reasons, p.
3 1
;
see also
id. at 32-33; TSD, p. 1 1. Such differences between the
federal rule and state rules in allowance allocation methodologies for
NOx allowances "are
possible without jeopardizing the environmental and other goals of the [CAIR] program." 70
Fed. Reg. at 25278.
Because of the unique nature of Illinois7
EGU inventory subject to the CAIR, Illinois
should utilize the flexibility afforded in the federal CAIR rule by eliminating fuel weighting in
the state CAIR rule. Peaking combustion turbine units, which comprise the majority of gas-fired
units affected by CAIR in Illinois, stand to be particularly impacted by fuel-weighting because
they already operate with lower efficiencies that are common to simple-cycle combustion
turbines. While fuel weighting seems to equalize certain considerations, including baseline
emission rates and generating efficiencies, it does not equally apply to peaking combustion
turbine units. Specifically, combined cycle facilities have better efficiencies and lower emission
rates when compared to peakers. Consequently, the fuel weighting issue does not have as
devastating
an impact on those combined cycle sources. However, when fuel weighting is
applied to peakers, the result is much more punitive.
First, as the NO, emission allowances are currently proposed, peaking combustion
turbine units will barely receive enough allowances to cover expected emissions. That limitation
is a curious message to send to the newest and cleanest facilities, especially since most peakers
have been constructed in the last 5-10 years and therefore possess best available control
technology (BACT) emission controls.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
Next, unlike combined-cycle generating facilities, large-frame simple-cycle turbines are
unable to feasibly install and utilize post-combustion NO, controls to reduce emissions to levels
below those achievable by advanced combustion controls. The primary reason for this limitation
is the fact that selective catalytic reduction (SCR), which is the most common, effective and
feasible post-combustion control technology available for combustion sources, depends on a
chemical reaction to reduce NO, emissions. Specifically, a reagent
-
typically ammonia or urea
-
is injected into the combustion exhaust stream, upstream of a catalyst bed. The catalyst
accelerates and promotes the conversion of NO, to water, nitrogen and a limited amount of
unreacted reagent. A key factor in this reaction is temperature
-
SCR is generally effective when
the exhaust temperature is in the range of 600 to 800 degrees Fahrenheit. Temperatures below or
above this temperature range substantially reduce the effectiveness of SCR in reducing NO,
emissions.
While SCR is highly effective and commonly used in combined-cycle applications, high
exhaust temperatures associated with large-frame combustion turbines render SCR mostly
ineffective. The large-frame turbines, in particular the "F-class" turbines that are commonly
used in peaking plants such as the units at the Zion facility, exhibit exhaust temperatures in the
1,150 to 1,200 degree range. Although some catalyst manufacturers claim to have developed
high-temperature catalysts that are effective at higher exhaust temperatures, no such application
has been demonstrated in practice on an F-class combustion turbine. Research of the U.S. EPA7s
RACTIBACTILAER Clearinghouse Database shows that as recently as 2000, lowest achievable
emission rate (LAER) determinations had been issued for facilities similar to Zion's
(i.e., Rock
Springs 680 Megawatt power station in Cecil County, Maryland) confirming that
post-
combustion controls for F-class combustion turbines operating in simple-cycle configuration
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
remain technically infeasible. See Attachment 1. A more recent BACT determination was
issued to Louisville Gas
&
Electric Company (LG&E) in June 2003 for a simple-cycle
generating facility that proposed the same combustion turbine model as that used to generate
power at the Zion facility. As in the case of the Rock Springs facility referenced above,
combustion controls were approved as BACT for the
LG&E peaking facility, and post-
combustion controls were deemed to be infeasible. See Attachment 2. Similarly, when
considering all of the peaker projects constructed in Illinois over the last ten years, the Illinois
EPA has determined that combustion controls
-
and not post combustion control measures
-
represented BACT in every case. Other post-combustion control techniques, such as selective
non-catalytic reduction (SNCR), require exhaust temperatures in the range of 1,600 to 2,000
degrees Fahrenheit, a characteristic that is not achievable by F-class combustion turbines.
Finally, Illinois previously faced the opportunity to include fuel weighting allocations
under the NO, SIP Call and, after an intensive stakeholder process, chose not to incorporate such
fuel weighting into the state-based rule. Therefore, it's puzzling why the Illinois EPA has
proposed to offer fuel weighting in its Proposed Rule since most of the same stakeholders are
directly affected. From Zion's perspective, the Illinois EPA's NO, SIP Call regulation operated
very well on a
fuel neutral basis. Consequently, when considering the basis for Illinois EPA's
previous choice to reject fuel weighted allocations as well as the relative success of the Illinois's
ability to reasonably regulate NO, sources under that rule, Zion fails to see any compelling
reason why fuel-weighting should be introduced or approved at this time.
B.
Clean Air Set Aside (CASA)
Zion opposes Illinois
EPA's proposed set-aside of 25 percent of the NO, emission
allocation pool for projects related to Energy
EfficiencyIRenewable Energy (1
2%)'
Clean
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
Technology (1 1
%)
and Early Adopters (2%) based on the full extent of that proposed set-aside
and the specific nature of the projects included within that set-aside pool. As we understand it,
the proposed CASA would include allocations for demand-side projects, zero and low emission
projects, energy efficiency projects, and early reduction credits.
Zion is not opposed to the Illinois
EPA's establishment of a reasonable and lower
percentage NO, emission allocation set-aside pool for certain renewable energy projects.
However, such lower level set-asides for renewable energy projects should provide some
encouragement to Illinois' regulated community, it should not supplant the potential need to
establish a separate renewable energy regulatory program or detrimentally affect the ability of
certain regulated EGUs
(e.g., peakers) to comply with the state's ultimate CAIR rule.
The Illinois EPA should completely eliminate the other proposed projects included within
the categories of Energy
EfficiencyIRenewable Energy, Clean Technology and Early Adopters
because, inter alia, they will impose artificial influences on the cost of compliance that will
unreasonably drive costs upward for Zion, similar gas-fired EGUs throughout the state and,
ultimately, energy customers. Specifically, the Illinois
EPA's proposal will further remove
available NO, emission allowances from the overall pool that could otherwise have been used by
regulated EGUs that are not coal-fired. It is unclear why the Illinois EPA feels the need to create
such incentives or rewards for those sources since most coal-fired EGUs have already installed
or will soon install NO, controls on much of their affected fleet to comply with the NO, SIP
Call/ NO, Trading Program. Therefore, the Illinois EPA seems to have proposed a rule that will
incentivize and reward sources for projects and reductions that are already required by law to the
clear detriment of other types of EGUs in the state.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
Furthermore, Zion does not concur with the Illinois EPA's proposal to carry-over unused
"special project" pool allowances to supplement those pools in the future. Instead, if "special
project" pool allowances are ultimately included in the final CAIR rule, the unused "special
project" allowances should be redistributed to the main source pool for allocation to main pool
EGUs.
Finally, when the full extent of the proposed set asides is combined with the fuel
weighting impacts on peakers and the complete retirement of the Compliance Supplement Pool,
peakers will have no options to comply aside from buying allowances
from other sources to
which Illinois EPA has granted a variety of compliance options under the Proposed Rule.
Illinois should not propose, and the Board should not approve, a rule that would place such a
substantial constraint on a particular group of Illinois sources' ability to comply with the
Proposed Rule and potential future contingencies
(e.g., reduced state-level emission caps and the
resulting diminishment of source-specific allocations). Approval of such a rule would clearly
impose a substantial economic burden on those particular sources to maintain compliance. These
burdensome costs were clearly not considered in Illinois EPA7s economic reasonableness
justification for the Proposed Rule, but should have been. See TSD, Sections
7.0 and 8.1
-5.6.
C.
Overall Negative Impact on Gas-Fired Peaker Units
As discussed above, natural gas-fired peaker units make up the majority of gas-fired
generating units in Illinois. Because of the technological limitations available to peakers, the
Proposed Rule effectively focuses the incremental cost of control on that portion of the affected
source community that is least able to respond. As their name implies, peakers operate when
electric power demand is at its highest; correspondingly, peakers also operate to provide power
when demand nears the limits of supply, which results in an increase in the cost of power
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
production. For peakers that face allowance shortfalls, the cost of a potentially diminishing pool
of available
NO, allowances will be magnified as owners of peakers will be forced to purchase
allowances from the open emission commodity market, curtail operations in order to stay within
allotted limits, or shutdown particular sources when the economics of operating them is no
longer feasible.
If these sources are forced to purchase allowances, it is important to note that the cost of
such purchases likely will be reflected as increased electric power prices to consumers. When
combined with the significant reduction of
25% of the overall
NOx
emission allocation pool for
"special projects"
(i-e., CASA) and the complete retirement of the Compliance Supplement Pool,
the state has created a situation that foreseeably (and unreasonably) could drive peak power
prices upward even further. This increased cost should be considered by the Illinois EPA in its
development and final implementation of a more equitable final CAIR rule because, as the
Illinois EPA knows, the ability to provide seamless power during peak electrical demands
necessitates the ability to operate natural gas-fired peakers at a reasonable cost to consumers.
Finally, the undue burden placed upon natural gas fired peakers seems to contradict the
Illinois
EPA's "good environmental policy to provide more allowances to sources that operate
more efficiently, install air pollution control equipment, and upgrade their equipment." Illinois
EPA Statement of Reasons, p.
35. Moreover, the above-described potential for increased costs
for peakers and electricity customers seem to have been excluded
from the Integrated Planning
Model used by the Illinois EPA to evaluate the economic impact of the CASA. See Illinois EPA
TSD, Section 7.0. Thus, the true estimated economic impact of those costs on all of Illinois'
EGUs, and in particular peakers, and their customers has not entirely been presented to the Board
to date, but should be prior to any final enactment of the CAIR.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
Conclusion
For the above-described reasons, Zion requests that Illinois Environmental Protection
Agency revise the Proposed Rule as described above. Furthermore, Zion asks that the Pollution
Control Board adopt a rule that reasonably incorporates Zion's comments.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
ATTACHMENT 1
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
RBLC Facility Information
Page
1 of 3
U.S.
E@%rvlmnnrcmtol
Protectl~n Agency
Technology Transfer Network
Clean Air Technology Center
RACTIBACTILAER Clearinghouse
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Facility Information
Date Entered: 1213012004
Date Last Modified: 0310112005
FINAL
--"
---
-----.-----
----
RBLC ID:
MD-0034
CorporatelCompany:
OLD DOMINION ELECTRIC COOPERATIVE
Facility Name:
ROCK SPRINGS
Facility Description:
PROJECT INCLUDES
6
GE 7FA SIMPLE CYCLE COMBUSTION TURBINES RATED 190 MW
EACH
State: MD
County
:
CECIL
EPA Region: 3
Zip Code: 21911
Facility Contact Information:
Name:DAVID SMITH
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
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RBLC Facility Information
Page 3 of 3
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Process Information
-
List of Processes
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FINAL
RBLC ID:
MD-0034
CorporatelCornpany:
OLD DOMINION ELECTRIC COOPERATIVE
Facility Name:
ROCK SPRINGS
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Process Code
Process
Throughput Capacity
15.110
(6) SIMPLE CYCLE GAS COMBUSTION
190.00 MW EACH
TURBINE
19.600
NATURAL GAS FIRED HEATER
9.00
MMBTUIH
17.210
EMERGENCY DIESEL FIREWATER PUMP
200.00 HP
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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
RBLC Facility Information
Page
2 of 2
(NOx)
@15% 02
LAER UNKNOWN
Sulfur Oxides
(SO&
NIA
UNKNOWN
Volatile Organic
Compounds
(VOCJ
NIA
UNKNOWN
9
PPMVD @ BACT- UNKNOWN
Carbon Monoxide
02
PSD
Process Notes:
CAPACITY
RATING @ MAXIMUM LOAD AT ZERO DEGREES F
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ATTACHMENT 2
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RBLC Facility Information
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3
U.S.
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Pmtactiw,
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Facility Information
Date Entered: 03/24/2005
Date Last Modified:
03/30/2005
FINAL
- ".." ----
--
---
RBLC ID: KY-0093
CorporatelCompany: LOUISVILLE GAS AND ELECTRIC COMPANY
Facility Name: LOUISVILLE GAS AND ELECTRIC COMPANY
Facility Description: EXISTING SOURCE
WITH COAL AND NATURAL GAS FIRED PEAKING UNITS.
State: KY
County:
TRIMBLE
EPA
Region: 4
Facility Contact Information:
Zip Code: 40232
Name
:
Phone
:
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
RBLC Facility Information
Page
2 of 3
Agency Contact Information:
.....
.......-....-..
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......................
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Agency: KYOOl
-
KENTUCKY DEP, DIV FOR AIR QUALITY
Contact:
MR. TOM
ADAMS
Address:ENVIRONMENTAL
&
PUBLIC PROT. CABINET
DEPT. OF ENV. PROT. DIV. OF AIR QUALITY
803 SCHENKEL LANE
FRANKFORT, KY 40601
Phone:
(502) 573-3382
Other
AgencyREVIEWED BY BEN MARKIN
Contact Info:
EST/ACT DATE
Permit
Number:V-02-043
Application Accepted Date: ACT 12/19/2002
Permit
Date:ACT 06/06/2003
Permit
Type:C: MODIFY EXISTING PROCESS AT EXISTING FACILITY
FRS
Number: 110017426999
SIC:
4911
NAICS: 221112
Affected Class I I U.S. Border Area:
No affected Class 1 areas identified.
Facility-Wide Emission IncreaselDecrease:
(After prevention/control measures)
Pollutant
Increase
(+)
/Decrease
(-) ,
Tons/Year
.
........-.
..........
....
..................................
-.
....
.......
....
Particulate Matter 499.3000
(PM)
Sulfur Oxides (SOX) 105.1000
Volatile Organic
73.6000
Compounds
(VOC)
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
RBLC Facility Information
Carbon Monoxide
762.0000
Nitrogen Oxides
(NOx) 1524.0000
Other Permitting Information:
- - -. - . .. . .. -. .. - --. .
. . ....
--
FACILITYWIDE EMISSIONS ARE TOTAL PROPOSED POTENTIAL EMISSIONS DUE TO 8760 HOURS PER OPERATION FOR ALL 6
TURBINES. THIS PROJECT WILL
ADD 5 GE PG7241 (FA) NATURAL GAS SIMPLE CYCLE TURBINES, WITH A NOMINAL
CAPACITY OF 160
MW
EACH.
Page 3 of 3
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2006.
URL:
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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
RBLC Facility Information
Page 1 of 2
U.S. Envlcanm8ntsl
Protection
Agency
Technology Transfer Network
Clean Air Technology Center
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Process Information
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FINAL
RBLC ID: KY-0093
CorporatelCompany: LOUISVILLE GAS AND ELECTRIC COMPANY
Facility Name: LOUISVILLE GAS AND ELECTRIC COMPANY
Process:TURBINE, SIMPLE CYCLE, NATURAL GAS (6)
Primary Fuel: NATURAL GAS
Throughput: 160.00
MW
Process Code: 15.1 10
Pollutant Information
-
List of Pollutants
-
Pollutant
Primary
Emission Limit
Basis
Verified
Nitroqen Oxides 12 PPM
@
15% BACT-
UNKNOWN
(NOx)
02
PSD
Sulfur Oxides
BACT- UNKNOWN
PSD
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
RBLC Facility Information
Page
2 of 2
Carbon
9 PPM @ 15%
BACT- UNKNOWN
Monoxide
02
PSD
Particulate
Matter
(PM)
19 LBIH
BACT- UNKNOWN
PS D
Process Notes:
UNITS ARE GE PG7241(FA) PEAKING UNITS. ADDITIONAL THROUGHPUT: 1763
MMBTUIHR MAXIMUM RATED HEAT INPUT CAPACITY (@ -10 DEGREES F),
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Last updated on: Tuesday, September 12,2006.
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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006
CERTIFICATE OF SERVICE
The undersigned certifies that a copy of the foregoing Testimony of Jason M. Goodwin was served on
this
10"' day of November, 2006,
Upon the following electronically:
Dorothy
Gunn
Clerk of the Board
Illinois Pollution Control Board
100 West Randolph Street
Suite 1 1-500
Chicago, IL 60601
John J. Kim
Rachel L. Doctors
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
And upon the following by U.S. First Class Mail:
John C.
Knittle
Katherine D. Hodge
Hearing Officer
N. LaDonna Driver
Illinois Pollution Control
Hodge Dwyer Zeman
Board
3 150 Roland Ave.
2125 S. First St.
P.O. Box 5776
Champaign, IL 61 820
Springfield, IL 62705-5776
Matthew
J. Durn
Sheldon A. Zabel
Office of the Illinois Attorney
Kathleen C. Bassi
General
Stephen
J. Bonebrake
Environmental Bureau
Schiff
Hardin, LLP
1
88 West Randolph St., 20Ih
6600 Sears Tower
Floor
233 S. Wacker Dr.
Chicago, IL 60601
Chicago, IL 60606
Virginia Yang
Illinois Department of
Natural Resources
One Natural Resources Way
Springfield, IL 6270 1-1 271
David Rieser
James T. Harrington
Jeremy R. Hojnicki
McGuire Woods LLP
77
W. Wacker Dr., Ste. 41 00
Chicago, IL 60601
William
A. Murray
Office of Public Utilities
800 E. Monroe
Springfield, IL 62757
Keith Harley
Chicago Legal Clinic,
Inc.
205 W. Monroe St., 4'" Floor
Chicago,
IL 60606
S. David
Farris
Office of Public Utilities
201 E. Lake Shore Dr.
Springfield, IL 62757
Faith
E. Bugel
Environmental Law and
Policy Center
35 East Wacker Drive, Suite
1300
Chicago, IL 60601
Daniel D.
McDevitt
Assistant General Counsel
Midwest Generation, LLC
440 South
LaSalle St., Suite
3500
Chicago, IL 60605
Bruce
E. Nilles
Sierra Club
122
W. Washington Ave.,
Suite 830
Madison, WI 53703
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 10, 2006