Wingra Engineering, S.C.1 Evaluation of Gas Turbine Air Quality Impacts from a Community Perspective Steven Klafka, PE Wingra Engineering, S.C Electric Utilities Environmental Conference

Wingra Engineering, S.C.2 Introduction Recent deregulation of the utility industry and the increased demand for electricity has resulted in the construction of new gas turbine generation stations throughout the U.S. Wisconsin has been no exception with 37 new gas turbine stations and 14,990 megawatts of generating capacity proposed from 1998 to 2001.

Wingra Engineering, S.C.3 Wisconsin Gas Turbine Projects

Wingra Engineering, S.C.4 Community Reaction This has been the first experience of many communities with new electrical generating facilities. Some communities have rejected outright the construction of a new turbine station. Others have accepted new stations after evaluation of the economic and environmental impacts.

Wingra Engineering, S.C.5 Rejection of New Power Plants

Wingra Engineering, S.C.6 Background A 1,050 MW combined cycle gas turbine generating station was proposed for the Village of Pleasant Prairie, Wisconsin. Merchant power plant selling electricity wholesale. On behalf of the village, a review was conducted of the draft air pollution control permit and support documents. Based on this review, the Village provided suggestions to the WDNR for improving the project design.

Wingra Engineering, S.C.7 Gas Turbine Site

Wingra Engineering, S.C.8 Review of BACT Analysis Evaluation of Best Available Control Technology analysis and comparison with control methods for similar turbine stations. Concluded that the emission control methods and emission limitations proposed for the project represented BACT for recently constructed combined cycle gas turbines. Recommended reductions in the emission limitations for VOC and H 2 SO 4 to levels approved for a recent gas turbine project.

Wingra Engineering, S.C.9 Approved Limits and Emissions Air Pollutant Control Method Discharge Limitation Emissions (tons/yr) NO x Low-NOx burners & SCR3.5 ppmdv at 15% O COOxidation Catalyst4.0 ppmdv at 15% O 2 1,097 SO % Sulfur Nat. Gas4.5 lbs per hour per combustor80 PMNatural Gas Fuel30.5 lbs per hour per combustor543 VOCOxidation Catalyst1.2 ppmdv at 15% O 2 62 H 2 SO 4 Same as SO lbs per hour per combustor49 NH 3 None10.0 ppmdv at 15% O 2 478

Wingra Engineering, S.C.10 Review of Impact Analysis Evaluation of dispersion modeling analysis used to determine compliance with air quality standards. Verified modeling assumptions and procedures followed USEPA and WDNR protocols. While the project complied with the National Ambient Air Quality Standards, it consumed the entire PSD increment for PM 10.

Wingra Engineering, S.C.11 Air Quality Impacts of Turbine Project

Wingra Engineering, S.C.12 Review of Impact Analysis Recommended reduced emissions or improved dispersion to allow future growth in the nearby industrial park. Project proposed downwind VOC emission offsets due to location in ozone nonattainment area. Recommended that offsets be obtained upwind of the project site to benefit village residents.

Wingra Engineering, S.C.13 Review of Ambient Monitoring Reviewed proposed monitoring and recordkeeping requirements. Project was exempted from pre-construction ambient monitoring requirements based use of background data available from other counties in the state. Recommended the project include post-construction monitoring to determine background air quality for the project location and surrounding county.

Wingra Engineering, S.C.14 Review of Compliance Monitoring Recommended that the Village be kept abreast of facility compliance. Village should be provided copies of all pertinent air quality testing, monitoring and compliance certification documents. Recommended compliance testing frequency be increased from every five to every two years.

Wingra Engineering, S.C.15 Project Outcome The final air quality permit for the turbine project did not incorporate any of the proposed recommendations including: $ Reduced VOC and H 2 SO 4 limitations. $ Reduced PM 10 increment consumption. $ Purchase of VOC offsets upwind of site. $ Post-construction monitoring. $ Shared monitoring & record keeping.

Wingra Engineering, S.C.16 Project Outcome None of the Village’s recommendations were incorporated into the project. However, the Village concluded the recommendations provided leverage during negotiations for other aspects of the project such as infrastructure improvements and noise control.

Wingra Engineering, S.C.17 Project Redesign Shortly after receipt of an air pollution control permit, the project was re- designed from 4 to 3 turbines and 1,050 to 1,080 MW capacity. The new project design incorporated several of the recommendations made on the original project.

Wingra Engineering, S.C.18 Project Redesign Stack height was increased from 120 to 150 feet to reduce PM 10 increment consumption. Voluntary notification of Village staff when monitoring reports are submitted to WDNR. Voluntary development of an industrial park consortium to monitor background air quality.

Wingra Engineering, S.C.19 Pick Sides or Compromise