ProEnergy Final Copy - DNR · 2020-04-15 · A copy of the permit application and this permit and...
Transcript of ProEnergy Final Copy - DNR · 2020-04-15 · A copy of the permit application and this permit and...
DEC 3 1 2019
Mr Matt Lydon Director of Regulatory Compliance ProEnergy Services 8303 McHard Road Houston TX 77053
RE New Source Review Permit-Project Number 2019-10-027
Dear Mr Lydon
Enclosed with this letter is your permit to construct Please study it carefully and refer to Appendix A for a list of common abbreviations and acronyms used in the permit Also note the special conditions on the accompanying pages The document entitled Review of Application for Authority to Construct is part of the permit and should be kept with this permit in your files Operation in accordance with these conditions and your new source review permit application is necessary for continued compliance The reverse side of your permit certificate has important information concerning standard permit conditions and your rights and obligations under the laws and regulations of the State ofMissouri
This permit may include requirements with which you may not be familiar If you would like the department to meet with you to discuss how to understand and satisfy the requirements contained in this permit an appointment referred to as a Compliance Assistance Visit (CAV) can be set up with you To request a CAV please contact your local regional office or fill out an online request The regional office contact information can be found at the following website httpdnrmo12ovretdons The online CAV request can be found at httpdnrmorrovcavcornpliancehtm
If you were adversely affected by this permit decision you may be entitled to pursue an appeal before the administrative hearing commission pursuant to Sections 621250 and 6430756 RSMo To appeal you must file a petition with the administrative hearing commission within thirty days after the date this decision was mailed or the date it was delivered whichever date was earlier Ifany such petition is sent by registered mail or certified mail it will be deemed filed on the date it is mailed if it is sent by any method other than registered mail or certified mail it will be deemed filed on the date it is received by the administrative hearing commission whose contact information is Administrative Hearing Commission United States Post Office Building 131 West High Street Third Floor PO Box 1557 Jefferson City Missouri 65102 phone 573-751-2422 fax 573-751-5018 website VWWoamo govahc
0 Recycled paper
Mr Matt Lydon Page Two
If you have any questions regarding this permit please contact the Air Pollution Control Program at PO Box 176 Jefferson City MO 65102 or at (573) 751-4817 Thank you for your attention to this matter
Sincerely
AIR POLLUTION CONTROL PROGRAM
Susan Heckenkamp New Source Review Unit Chief
SHrsa
Enclosures
c Northeast Regional Office P AMS File 2019-10-027
Permit Number 12 2 01 9 - 0 l 0
~[sectj MISSOURI Ii 11 amp IDEPARTMENT OF ~ tf NATURALRESOURCES
MISSOURI AIR CONSERVATION COMMISSION
PERMIT TO CONSTRUCT bull
Under the authority of RSMo 643 and the Federal Clean Air Act the applicant is authorized to construct the air contaminant source(s) described below in accordance with the laws rules and conditions as set forth herein
Permit Number 12201 9 -0 l 0 Project Number 2019-10-027 Installation Number 159-0063
Parent Company ProEnergy Services
Parent Company Address 2001 ProEnergy Boulevard Sedalia MO 65301
Installation Name ProEnergy Services
Installation Address 2001 ProEnergy Boulevard Building 9 Sedalia MO 65301
Location Information Pettis County (S32 T46N R21W)
Application for Authority to Construct was made for The installation of a combustion turbine test cellstand This review was conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 Construction Permits Required
D Standard Conditions (on reverse) are applicable to this permit
Standard Conditions (on reverse) and Special Conditions are applicable to this permit
Dire~ Department of Natural Resources
DEC 3 1 2019 Effective Date
STANDARD CONDITIONS
Permission to construct may be revoked if you fail to begin construction or modification within two years from the effective date of this permit Permittee should notify the Enforcement and Compliance Section of the Air Pollution Control Program if construction or modification is not started within two years after the effective date of this permit or if construction or modification is suspended for one year or more
You will be in violation of 10 CSR 10-6060 if you fail to adhere to the specifications and conditions listed in your application this permit and the project review In the event that there is a discrepancy between the permit application and this permit the conditions of this permit shall take precedence Specifically all air contaminant control devices shall be operated and maintained as specified in the application associated plans and specifications
You must notify the Enforcement and Compliance Section of the Departments Air Pollution Control Program of the anticipated date of startup of this (these) air contaminant source(s) The information must be made available within 30 days of actual startup Also you must notify the Departments regional office responsible for the area within which you are located within 15 days after the actual startup of this (these) air contaminant source(s)
A copy of the permit application and this permit and permit review shall be kept at the installation address and shall be made available to Departments personnel upon request
You may appeal this permit or any of the listed special conditions to the Administrative Hearing Commission (AHC) PO Box 1557 Jefferson City MO 65102 as provided in RSMo 6430756 and 6212503 If you choose to appeal you must file a petition with the AHC within 30 days after the date this decision was mailed or the date it was delivered whichever date was earlier If any such petition is sent by registered mail or certified mail it will be deemed filed on the date it is mailed If it is sent by any method other than registered mail or certified mail it will be deemed filed on the date it is received by the AHC
If you choose not to appeal this certificate the project review and your application and associated correspondence constitutes your permit to construct The permit allows you to construct and operate your air contaminant source(s but in no way relieves you of your obligation to comply with all applicable provisions of the Missouri Air Conservation Law regulations of the Missouri Department of Natural Resources and other applicable federal state and local laws and ordinances
The Air Pollution Control Program invites your questions regarding this air pollution permit Please contact the Construction Permit Unit using the contact information below
Contact Information Missouri Department of Natural Resources
Air Pollution Control Program PO Box 176
Jefferson City MO 65102-0176 (573) 751-4817
The regional office information can be found at the following website httpdnrmogovreqions
- 2 -
Project No 2019-10-027
Permit No 1 2 2 0 1 9 - 0 1 0 SPECIAL CONDITIONS The permittee is authorized to construct and operate subject to the following special conditions
The special conditions listed in this permit were included based on the authority granted to the Missouri Air Pollution Control Program by the Missouri Air Conservation Law (specifically 643075) and by the Missouri Rules listed in Title 10 Division 10 of the Code of State Regulations (specifically 10 CSR 10-6060) For specific details regarding conditions see 10 CSR 10-6060 paragraph (3)(E) Conditions required by permitting authority
ProEnergy Services Pettis County (S32 T46N R21W)
1 Control Device Requirement - NOx Water Injection amp Low-NOx Burners A ProEnergy Services shall control emissions from the combustion turbine
test cellstand using NOx water injection andor low-NOx burners as specified in the permit application
B The control devices shall be operated and maintained in accordance with the manufacturers specifications which shall be kept on site
C ProEnergy Services shall maintain an operating and maintenance log for the control devices which shall include the following 1) Incidents of malfunction with impact on emissions date and
duration of event probable cause corrective actions etc 2) Maintenance activities with inspection schedule repair actions
replacements etc
2 Fuel Requirement - Generator Sets A ProEnergy Services shall burn exclusively ultra-low sulfur diesel fuel with
a sulfur content less than or equal to 15 parts per million in the generator sets (EP-02 amp EP-03)
B ProEnergy Services shall demonstrate compliance with Special Condition 2A by obtaining records of the fuels sulfur content from the vendor for each shipment of fuel received or by testing each shipment of fuel for the sulfur content in accordance with the method described in 10 CSR 10-6 040 Reference Methods
3 Record Keeping and Reporting Requirements ProEnergy Services shall maintain all records required by this permit for not less than five years and shall make them available immediately to any Missouri Department of Natural Resources personnel upon request
- 3 -
REVIEW OF APPLICATION FOR AUTHORITY TO CONSTRUCT AND OPERATE SECTION (5) REVIEW
Project Number 2019-10-027 Installation ID Number 159-0063
Permit Number 12 2 O l 9 _ 01 O
Installation Address Parent Company ProEnergy Services ProEnergy Services 2001 ProEnergy Boulevard Building 9 2001 ProEnergy Boulevard Sedalia MO 65301 Sedalia MO 65301 Pettis County (S32 T46N R21W)
REVIEW SUMMARY
bull ProEnergy Services has applied for authority to install a combustion turbine test cellstand
bull The application was deemed complete on November 12 2019
bull HAP emissions from this project include the products of diesel and natural gas combustion All individual HAP emissions are expected to be bel9w the screening model action levels and total HAP emissions are expected to be below the major source level middot
bull None of the New Source Performance Standards (NSPS) apply to the installation 40 CFR 60 Subpart 1111- Standards of Performance for Stationary
Compression Ignition (Cl) Internal Combustion Engines (ICE) sect604200 (b) The provisions of this subpart are not applicable to stationary Cl ICE being tested at a stationary Cl ICE test cellstand
40 CFR 60 Subpart KKKK - Standards of Performance for Stationary Combustion Turbines sect604310 (d) Combustion turbine test cellsstands are exempt from this subpart
bull None of the MACT regulations apply to the equipment 40 CFR 63 Subpart YYYY - National Emission Standards for Hazardous Air
Pollutants for Stationary Combustion Turbines sect636090 (b)(5) Combustion turbine engine test cellsstands do not have to meet the requirements of this subpart
40 CFR 60 Subpart PPPPP - National Emission Standards for Hazardous Air Pollutants for Engine Test CellsStands sect639285 You are subject to this subpart if you own or operate an engine test cellstand that is located at a major source of HAP emissions
bull NOx water injection andor low-NOx burners will be used to control NOx emissions from the equipment
-4-
bull This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels
bull This installation is-located in Pettis County an attainmentunclassifiable area for all criteria pollutants
bull This installation is not on the List of Named Installations found in 1OCSR 10-6020(3)(8) Table 2 The installations major source level is 250 tons per year and fugitive emissions are not counted toward major source applicability
bull Emissions testing is not required for the equipment as a part of this permit Testing may be required as part of other state federal or applicable rules
bull No Operating Permit is required for this installation
bull Approval of this permit is recommended with special conditions
INSTALLATIONPROJECT DESCRIPTION
ProEnergy Services is an energy consulting and equipment servicing facility located in Sedalia MissouriTfle installation currently operates a combustion turbine test cellstand (EP-01) on site which does not require a construction permit as it is not considered an emission unit however a temporary construction permit (062018-007) was issued in June 2018 for the testing of a natural gas-fired turbine and generator package Another temporary construction permit (102018-015) was issued in October 2018 for the operation of two diesel-fired generators to balance operation of testing equipment Due to future business needs which require the equipment to operate for longer than the temporary construction permits allow ProEnergy Services is proposing to permanently permit the testing of combustion turbines at the test cellstand and the associated generators
Various combustion turbine configurations will be tested in the cellstand however the combustion turbines will primarily be natural gas-fired aero-derivative and nominallyshyrated at 50 MW with a 474 MMBtuhr heat input NOx emissions will be controlled by the utilization of NOx water injection andor low-NOx burners
Two nominally-rated 2 MW portable diesel-fired generator sets (EP-02 amp EP-03) will be required for startup which will provide power to a natural gas compressor The compressor will increase the pressure of the incoming natural gas from approximately 230 psi to 675 psi for combustion in the turbine
Power generated from the test cellstand will be directed into a load bank The electricity will neither be sold nor provided to the Transmission or Distribution Grid
- 5 -
EMISSIONSCONTROLS EVALUATION
Potential emissions from the combustion turbines being tested in the test cellstand were calculated using emission factors obtained from manufacturers data and the results of previous turbine tests performed on site Separate emission factors were given for startup shutdown and normal operations Emission factors taken from AP-42 Section 31 Stationary Gas Turbines (April 2000) were used in place of any incomplete data Although the testing period is variable it was conservatively estimated that 50 turbines will be tested per year (about 1 per week) This is overly-conservative because it assumes continuous adjacent testing at a rate which has yet to be realistically attained using the equipment Each unit is expected to have four starts each lasting 30 minutes and requiring 125 MMBtu of natural gas The turbine will run for 4 hours after each startup Shutdowns are expected to last 15 minutes and require 50 MMBtu of natural gas This yields a total firing time of 950 hours per year which consumes 4063 MMcf of natural gas All combustion turbines tested at the cellstand will be operated with NOx water injection andor low-NOx burners to reduce emissions Reduced NOx emissions were accounted for in the noted emission factors
Potential emissions from the two 193 MMBtuhr diesel-fired generators were calculated using emission factors obtained from manufacturers data Separate emission factors were given for full load and 50 load operations Emission factors taken from AP-42 Section 34 Large Stationary Diesel and All Stationary Dual-Fired Engines (October 1996) were used in place of any incomplete data Generator operation was adjusted to the assumed combustion turbine testing schedule Both generator sets will start up in tandem and during combustion turbine startup they will operate at full load for approximately 15 minutes until one of them is ramped down to 50 load At the completion of combustion turbine startup the generator set still at full load will also ramp down to 50 load Both generator sets will operate at 50 load for the remainder of the combustion turbine run
Table 1 provides an emissions summary for this project Because this installation has never previously received a construction permit existing potential emissions and existing actual emissions are unknown The two previous temporary permits issued to ProEnergy Services only included emissions from the limited testing periods which were calculated using conservative emission factors from AP-42 Potential emissions of the project represent the potential of the combustion turbines being tested at the test cellstand and the two generators using the estimated maximum operating rates
- 6 -
Table 1 Emissions Summary (tons per year)
PoUutant Regulatory DeMinimis
Levels
Existing Potential
Emissions
Existing Actual
Emissions
Potential Emissions of the middotProject
Conditioned Potential
Emissions of the Project
PM 250 N0 N0 226 NA
PM10 150 N0 ND 226 NA
PM2s 100 N0 ND 226 NIA
SOx 400 N0 ND 014 NA
NOx 400 ND ND 3427 NA
voe 400 ND N0 192 NA
co 1000 ND ND 1439 NA
Total HAPS 250 ND ND 023 NA ND = Not Determined
PERMIT RULE APPLICABILITY
This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels
APPLICABLE REQUIREMENTS
ProEnergy Services shall comply with the following applicable requirements The Missouri Air Conservation Laws and Regulations should be consulted for specific record keeping monitoring and reporting requirements Compliance with these emission standards based on information submitted in the application has been verified at the time this application was approved
GENERAL REQUIREMENTS
bull Start-Up Shutdown and Malfunction Conditions 1 0 CSR 10-6050
bull Submission of Emission Data Emission Fees and Process Information 10 CSR 10-6110 Per 10 CSR 10-6110(4)(8)1 and (4)(8)2C(II) a full EIQ is required for the
first full calendar year the equipment is in operation
bull Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin 10 CSR 10-6170
bull Restriction of Emission of Visible Air Contaminants 10 CSR 10-6220
bull Restriction of Emission of Odors 1 0 CSR 10-6165
-7-
STAFF RECOMMENDATION
On the basis of this review conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 Construction Permits Required it is recommended that this permit be granted with special conditions
PERMIT DOCUMENTS
The following documents are incorporated by reference into this permit
bull The Application for Authority to Construct form dated October 16 2019 received October 17 2019 designating ProEnergy Services as the owner and operator of the installation
- 8 -
APPENDIX A Abbreviations and Acronyms
percent
degF degrees Fahrenheit
acfm actual cubic feet per minute
BACT Best Available Control Technology
BMPs Best Management Practices
Btu British thermal unit
CAM Compliance Assurance Monitoring
CAS Chemical Abstracts Service
CEMS Continuous Emission Monitor System
CFR Code of Federal Regulations
CO carbon monoxide
C02carbon dioxide
C02e carbon dioxide equivalent
COMS Continuous Opacity Monitoring System
CSR Code of State Regulations
dscf dry standard cubic feet
EIQEmission Inventory Questionnaire
EP Emission Point
EPA Environmental Protection Agency
EU Emission Unit
fps feet per second
ft feet
GACT Generally Available Control Technology
GHG Greenhouse Gas
gpm gallons per minute
gr grains
GWP Global Warming Potential
HAPHazardous Air Pollutant
hr hour
hp horsepower
lb pound
lbshr pounds per hour
MACT Maximum Achievable Control Technology
microgm3 bull micrograms per cubic meter
mis meters per second
Mgal 1000 gallons
MW megawatt
MHDR maximum hourly design rate
MMBtu Million British thermal units
MMCF million cubic feet
MSDS Material Safety Data Sheet
NAAQS National Ambient Air Quality Standards
NESHAPs National Emissions Standards for Hazardous Air Pollutants
NOx nitrogen oxides
NSPS New Source Performance Standards
NSR New Source Review
PM particulate matter
PM2s particulate matter less than 25 microns in aerodynamic diameter
PM10 particulate matter less than IO microns in aerodynamic diameter
ppm parts per million
PSD Prevention of Significant Deterioration
PTE potential to em it
RACT Reasonable Available Control Technology
RAL Risk Assessment Level
SCC Source Classification Code
scfm standard cubic feet per minute
SDS Safety Data Sheet
SIC Standard Industrial Classification
SIP State Implementation Plan
SMAL Screening Model Action Levels
SOx sulfur oxides
S02 sulfur dioxide
SSM Startup Shutdown amp Malfunction
tph tons per hour
tpy tons per year
VMT vehicle miles traveled
VOC Volatile Organic Compound
- 9 -
Mr Matt Lydon Page Two
If you have any questions regarding this permit please contact the Air Pollution Control Program at PO Box 176 Jefferson City MO 65102 or at (573) 751-4817 Thank you for your attention to this matter
Sincerely
AIR POLLUTION CONTROL PROGRAM
Susan Heckenkamp New Source Review Unit Chief
SHrsa
Enclosures
c Northeast Regional Office P AMS File 2019-10-027
Permit Number 12 2 01 9 - 0 l 0
~[sectj MISSOURI Ii 11 amp IDEPARTMENT OF ~ tf NATURALRESOURCES
MISSOURI AIR CONSERVATION COMMISSION
PERMIT TO CONSTRUCT bull
Under the authority of RSMo 643 and the Federal Clean Air Act the applicant is authorized to construct the air contaminant source(s) described below in accordance with the laws rules and conditions as set forth herein
Permit Number 12201 9 -0 l 0 Project Number 2019-10-027 Installation Number 159-0063
Parent Company ProEnergy Services
Parent Company Address 2001 ProEnergy Boulevard Sedalia MO 65301
Installation Name ProEnergy Services
Installation Address 2001 ProEnergy Boulevard Building 9 Sedalia MO 65301
Location Information Pettis County (S32 T46N R21W)
Application for Authority to Construct was made for The installation of a combustion turbine test cellstand This review was conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 Construction Permits Required
D Standard Conditions (on reverse) are applicable to this permit
Standard Conditions (on reverse) and Special Conditions are applicable to this permit
Dire~ Department of Natural Resources
DEC 3 1 2019 Effective Date
STANDARD CONDITIONS
Permission to construct may be revoked if you fail to begin construction or modification within two years from the effective date of this permit Permittee should notify the Enforcement and Compliance Section of the Air Pollution Control Program if construction or modification is not started within two years after the effective date of this permit or if construction or modification is suspended for one year or more
You will be in violation of 10 CSR 10-6060 if you fail to adhere to the specifications and conditions listed in your application this permit and the project review In the event that there is a discrepancy between the permit application and this permit the conditions of this permit shall take precedence Specifically all air contaminant control devices shall be operated and maintained as specified in the application associated plans and specifications
You must notify the Enforcement and Compliance Section of the Departments Air Pollution Control Program of the anticipated date of startup of this (these) air contaminant source(s) The information must be made available within 30 days of actual startup Also you must notify the Departments regional office responsible for the area within which you are located within 15 days after the actual startup of this (these) air contaminant source(s)
A copy of the permit application and this permit and permit review shall be kept at the installation address and shall be made available to Departments personnel upon request
You may appeal this permit or any of the listed special conditions to the Administrative Hearing Commission (AHC) PO Box 1557 Jefferson City MO 65102 as provided in RSMo 6430756 and 6212503 If you choose to appeal you must file a petition with the AHC within 30 days after the date this decision was mailed or the date it was delivered whichever date was earlier If any such petition is sent by registered mail or certified mail it will be deemed filed on the date it is mailed If it is sent by any method other than registered mail or certified mail it will be deemed filed on the date it is received by the AHC
If you choose not to appeal this certificate the project review and your application and associated correspondence constitutes your permit to construct The permit allows you to construct and operate your air contaminant source(s but in no way relieves you of your obligation to comply with all applicable provisions of the Missouri Air Conservation Law regulations of the Missouri Department of Natural Resources and other applicable federal state and local laws and ordinances
The Air Pollution Control Program invites your questions regarding this air pollution permit Please contact the Construction Permit Unit using the contact information below
Contact Information Missouri Department of Natural Resources
Air Pollution Control Program PO Box 176
Jefferson City MO 65102-0176 (573) 751-4817
The regional office information can be found at the following website httpdnrmogovreqions
- 2 -
Project No 2019-10-027
Permit No 1 2 2 0 1 9 - 0 1 0 SPECIAL CONDITIONS The permittee is authorized to construct and operate subject to the following special conditions
The special conditions listed in this permit were included based on the authority granted to the Missouri Air Pollution Control Program by the Missouri Air Conservation Law (specifically 643075) and by the Missouri Rules listed in Title 10 Division 10 of the Code of State Regulations (specifically 10 CSR 10-6060) For specific details regarding conditions see 10 CSR 10-6060 paragraph (3)(E) Conditions required by permitting authority
ProEnergy Services Pettis County (S32 T46N R21W)
1 Control Device Requirement - NOx Water Injection amp Low-NOx Burners A ProEnergy Services shall control emissions from the combustion turbine
test cellstand using NOx water injection andor low-NOx burners as specified in the permit application
B The control devices shall be operated and maintained in accordance with the manufacturers specifications which shall be kept on site
C ProEnergy Services shall maintain an operating and maintenance log for the control devices which shall include the following 1) Incidents of malfunction with impact on emissions date and
duration of event probable cause corrective actions etc 2) Maintenance activities with inspection schedule repair actions
replacements etc
2 Fuel Requirement - Generator Sets A ProEnergy Services shall burn exclusively ultra-low sulfur diesel fuel with
a sulfur content less than or equal to 15 parts per million in the generator sets (EP-02 amp EP-03)
B ProEnergy Services shall demonstrate compliance with Special Condition 2A by obtaining records of the fuels sulfur content from the vendor for each shipment of fuel received or by testing each shipment of fuel for the sulfur content in accordance with the method described in 10 CSR 10-6 040 Reference Methods
3 Record Keeping and Reporting Requirements ProEnergy Services shall maintain all records required by this permit for not less than five years and shall make them available immediately to any Missouri Department of Natural Resources personnel upon request
- 3 -
REVIEW OF APPLICATION FOR AUTHORITY TO CONSTRUCT AND OPERATE SECTION (5) REVIEW
Project Number 2019-10-027 Installation ID Number 159-0063
Permit Number 12 2 O l 9 _ 01 O
Installation Address Parent Company ProEnergy Services ProEnergy Services 2001 ProEnergy Boulevard Building 9 2001 ProEnergy Boulevard Sedalia MO 65301 Sedalia MO 65301 Pettis County (S32 T46N R21W)
REVIEW SUMMARY
bull ProEnergy Services has applied for authority to install a combustion turbine test cellstand
bull The application was deemed complete on November 12 2019
bull HAP emissions from this project include the products of diesel and natural gas combustion All individual HAP emissions are expected to be bel9w the screening model action levels and total HAP emissions are expected to be below the major source level middot
bull None of the New Source Performance Standards (NSPS) apply to the installation 40 CFR 60 Subpart 1111- Standards of Performance for Stationary
Compression Ignition (Cl) Internal Combustion Engines (ICE) sect604200 (b) The provisions of this subpart are not applicable to stationary Cl ICE being tested at a stationary Cl ICE test cellstand
40 CFR 60 Subpart KKKK - Standards of Performance for Stationary Combustion Turbines sect604310 (d) Combustion turbine test cellsstands are exempt from this subpart
bull None of the MACT regulations apply to the equipment 40 CFR 63 Subpart YYYY - National Emission Standards for Hazardous Air
Pollutants for Stationary Combustion Turbines sect636090 (b)(5) Combustion turbine engine test cellsstands do not have to meet the requirements of this subpart
40 CFR 60 Subpart PPPPP - National Emission Standards for Hazardous Air Pollutants for Engine Test CellsStands sect639285 You are subject to this subpart if you own or operate an engine test cellstand that is located at a major source of HAP emissions
bull NOx water injection andor low-NOx burners will be used to control NOx emissions from the equipment
-4-
bull This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels
bull This installation is-located in Pettis County an attainmentunclassifiable area for all criteria pollutants
bull This installation is not on the List of Named Installations found in 1OCSR 10-6020(3)(8) Table 2 The installations major source level is 250 tons per year and fugitive emissions are not counted toward major source applicability
bull Emissions testing is not required for the equipment as a part of this permit Testing may be required as part of other state federal or applicable rules
bull No Operating Permit is required for this installation
bull Approval of this permit is recommended with special conditions
INSTALLATIONPROJECT DESCRIPTION
ProEnergy Services is an energy consulting and equipment servicing facility located in Sedalia MissouriTfle installation currently operates a combustion turbine test cellstand (EP-01) on site which does not require a construction permit as it is not considered an emission unit however a temporary construction permit (062018-007) was issued in June 2018 for the testing of a natural gas-fired turbine and generator package Another temporary construction permit (102018-015) was issued in October 2018 for the operation of two diesel-fired generators to balance operation of testing equipment Due to future business needs which require the equipment to operate for longer than the temporary construction permits allow ProEnergy Services is proposing to permanently permit the testing of combustion turbines at the test cellstand and the associated generators
Various combustion turbine configurations will be tested in the cellstand however the combustion turbines will primarily be natural gas-fired aero-derivative and nominallyshyrated at 50 MW with a 474 MMBtuhr heat input NOx emissions will be controlled by the utilization of NOx water injection andor low-NOx burners
Two nominally-rated 2 MW portable diesel-fired generator sets (EP-02 amp EP-03) will be required for startup which will provide power to a natural gas compressor The compressor will increase the pressure of the incoming natural gas from approximately 230 psi to 675 psi for combustion in the turbine
Power generated from the test cellstand will be directed into a load bank The electricity will neither be sold nor provided to the Transmission or Distribution Grid
- 5 -
EMISSIONSCONTROLS EVALUATION
Potential emissions from the combustion turbines being tested in the test cellstand were calculated using emission factors obtained from manufacturers data and the results of previous turbine tests performed on site Separate emission factors were given for startup shutdown and normal operations Emission factors taken from AP-42 Section 31 Stationary Gas Turbines (April 2000) were used in place of any incomplete data Although the testing period is variable it was conservatively estimated that 50 turbines will be tested per year (about 1 per week) This is overly-conservative because it assumes continuous adjacent testing at a rate which has yet to be realistically attained using the equipment Each unit is expected to have four starts each lasting 30 minutes and requiring 125 MMBtu of natural gas The turbine will run for 4 hours after each startup Shutdowns are expected to last 15 minutes and require 50 MMBtu of natural gas This yields a total firing time of 950 hours per year which consumes 4063 MMcf of natural gas All combustion turbines tested at the cellstand will be operated with NOx water injection andor low-NOx burners to reduce emissions Reduced NOx emissions were accounted for in the noted emission factors
Potential emissions from the two 193 MMBtuhr diesel-fired generators were calculated using emission factors obtained from manufacturers data Separate emission factors were given for full load and 50 load operations Emission factors taken from AP-42 Section 34 Large Stationary Diesel and All Stationary Dual-Fired Engines (October 1996) were used in place of any incomplete data Generator operation was adjusted to the assumed combustion turbine testing schedule Both generator sets will start up in tandem and during combustion turbine startup they will operate at full load for approximately 15 minutes until one of them is ramped down to 50 load At the completion of combustion turbine startup the generator set still at full load will also ramp down to 50 load Both generator sets will operate at 50 load for the remainder of the combustion turbine run
Table 1 provides an emissions summary for this project Because this installation has never previously received a construction permit existing potential emissions and existing actual emissions are unknown The two previous temporary permits issued to ProEnergy Services only included emissions from the limited testing periods which were calculated using conservative emission factors from AP-42 Potential emissions of the project represent the potential of the combustion turbines being tested at the test cellstand and the two generators using the estimated maximum operating rates
- 6 -
Table 1 Emissions Summary (tons per year)
PoUutant Regulatory DeMinimis
Levels
Existing Potential
Emissions
Existing Actual
Emissions
Potential Emissions of the middotProject
Conditioned Potential
Emissions of the Project
PM 250 N0 N0 226 NA
PM10 150 N0 ND 226 NA
PM2s 100 N0 ND 226 NIA
SOx 400 N0 ND 014 NA
NOx 400 ND ND 3427 NA
voe 400 ND N0 192 NA
co 1000 ND ND 1439 NA
Total HAPS 250 ND ND 023 NA ND = Not Determined
PERMIT RULE APPLICABILITY
This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels
APPLICABLE REQUIREMENTS
ProEnergy Services shall comply with the following applicable requirements The Missouri Air Conservation Laws and Regulations should be consulted for specific record keeping monitoring and reporting requirements Compliance with these emission standards based on information submitted in the application has been verified at the time this application was approved
GENERAL REQUIREMENTS
bull Start-Up Shutdown and Malfunction Conditions 1 0 CSR 10-6050
bull Submission of Emission Data Emission Fees and Process Information 10 CSR 10-6110 Per 10 CSR 10-6110(4)(8)1 and (4)(8)2C(II) a full EIQ is required for the
first full calendar year the equipment is in operation
bull Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin 10 CSR 10-6170
bull Restriction of Emission of Visible Air Contaminants 10 CSR 10-6220
bull Restriction of Emission of Odors 1 0 CSR 10-6165
-7-
STAFF RECOMMENDATION
On the basis of this review conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 Construction Permits Required it is recommended that this permit be granted with special conditions
PERMIT DOCUMENTS
The following documents are incorporated by reference into this permit
bull The Application for Authority to Construct form dated October 16 2019 received October 17 2019 designating ProEnergy Services as the owner and operator of the installation
- 8 -
APPENDIX A Abbreviations and Acronyms
percent
degF degrees Fahrenheit
acfm actual cubic feet per minute
BACT Best Available Control Technology
BMPs Best Management Practices
Btu British thermal unit
CAM Compliance Assurance Monitoring
CAS Chemical Abstracts Service
CEMS Continuous Emission Monitor System
CFR Code of Federal Regulations
CO carbon monoxide
C02carbon dioxide
C02e carbon dioxide equivalent
COMS Continuous Opacity Monitoring System
CSR Code of State Regulations
dscf dry standard cubic feet
EIQEmission Inventory Questionnaire
EP Emission Point
EPA Environmental Protection Agency
EU Emission Unit
fps feet per second
ft feet
GACT Generally Available Control Technology
GHG Greenhouse Gas
gpm gallons per minute
gr grains
GWP Global Warming Potential
HAPHazardous Air Pollutant
hr hour
hp horsepower
lb pound
lbshr pounds per hour
MACT Maximum Achievable Control Technology
microgm3 bull micrograms per cubic meter
mis meters per second
Mgal 1000 gallons
MW megawatt
MHDR maximum hourly design rate
MMBtu Million British thermal units
MMCF million cubic feet
MSDS Material Safety Data Sheet
NAAQS National Ambient Air Quality Standards
NESHAPs National Emissions Standards for Hazardous Air Pollutants
NOx nitrogen oxides
NSPS New Source Performance Standards
NSR New Source Review
PM particulate matter
PM2s particulate matter less than 25 microns in aerodynamic diameter
PM10 particulate matter less than IO microns in aerodynamic diameter
ppm parts per million
PSD Prevention of Significant Deterioration
PTE potential to em it
RACT Reasonable Available Control Technology
RAL Risk Assessment Level
SCC Source Classification Code
scfm standard cubic feet per minute
SDS Safety Data Sheet
SIC Standard Industrial Classification
SIP State Implementation Plan
SMAL Screening Model Action Levels
SOx sulfur oxides
S02 sulfur dioxide
SSM Startup Shutdown amp Malfunction
tph tons per hour
tpy tons per year
VMT vehicle miles traveled
VOC Volatile Organic Compound
- 9 -
~[sectj MISSOURI Ii 11 amp IDEPARTMENT OF ~ tf NATURALRESOURCES
MISSOURI AIR CONSERVATION COMMISSION
PERMIT TO CONSTRUCT bull
Under the authority of RSMo 643 and the Federal Clean Air Act the applicant is authorized to construct the air contaminant source(s) described below in accordance with the laws rules and conditions as set forth herein
Permit Number 12201 9 -0 l 0 Project Number 2019-10-027 Installation Number 159-0063
Parent Company ProEnergy Services
Parent Company Address 2001 ProEnergy Boulevard Sedalia MO 65301
Installation Name ProEnergy Services
Installation Address 2001 ProEnergy Boulevard Building 9 Sedalia MO 65301
Location Information Pettis County (S32 T46N R21W)
Application for Authority to Construct was made for The installation of a combustion turbine test cellstand This review was conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 Construction Permits Required
D Standard Conditions (on reverse) are applicable to this permit
Standard Conditions (on reverse) and Special Conditions are applicable to this permit
Dire~ Department of Natural Resources
DEC 3 1 2019 Effective Date
STANDARD CONDITIONS
Permission to construct may be revoked if you fail to begin construction or modification within two years from the effective date of this permit Permittee should notify the Enforcement and Compliance Section of the Air Pollution Control Program if construction or modification is not started within two years after the effective date of this permit or if construction or modification is suspended for one year or more
You will be in violation of 10 CSR 10-6060 if you fail to adhere to the specifications and conditions listed in your application this permit and the project review In the event that there is a discrepancy between the permit application and this permit the conditions of this permit shall take precedence Specifically all air contaminant control devices shall be operated and maintained as specified in the application associated plans and specifications
You must notify the Enforcement and Compliance Section of the Departments Air Pollution Control Program of the anticipated date of startup of this (these) air contaminant source(s) The information must be made available within 30 days of actual startup Also you must notify the Departments regional office responsible for the area within which you are located within 15 days after the actual startup of this (these) air contaminant source(s)
A copy of the permit application and this permit and permit review shall be kept at the installation address and shall be made available to Departments personnel upon request
You may appeal this permit or any of the listed special conditions to the Administrative Hearing Commission (AHC) PO Box 1557 Jefferson City MO 65102 as provided in RSMo 6430756 and 6212503 If you choose to appeal you must file a petition with the AHC within 30 days after the date this decision was mailed or the date it was delivered whichever date was earlier If any such petition is sent by registered mail or certified mail it will be deemed filed on the date it is mailed If it is sent by any method other than registered mail or certified mail it will be deemed filed on the date it is received by the AHC
If you choose not to appeal this certificate the project review and your application and associated correspondence constitutes your permit to construct The permit allows you to construct and operate your air contaminant source(s but in no way relieves you of your obligation to comply with all applicable provisions of the Missouri Air Conservation Law regulations of the Missouri Department of Natural Resources and other applicable federal state and local laws and ordinances
The Air Pollution Control Program invites your questions regarding this air pollution permit Please contact the Construction Permit Unit using the contact information below
Contact Information Missouri Department of Natural Resources
Air Pollution Control Program PO Box 176
Jefferson City MO 65102-0176 (573) 751-4817
The regional office information can be found at the following website httpdnrmogovreqions
- 2 -
Project No 2019-10-027
Permit No 1 2 2 0 1 9 - 0 1 0 SPECIAL CONDITIONS The permittee is authorized to construct and operate subject to the following special conditions
The special conditions listed in this permit were included based on the authority granted to the Missouri Air Pollution Control Program by the Missouri Air Conservation Law (specifically 643075) and by the Missouri Rules listed in Title 10 Division 10 of the Code of State Regulations (specifically 10 CSR 10-6060) For specific details regarding conditions see 10 CSR 10-6060 paragraph (3)(E) Conditions required by permitting authority
ProEnergy Services Pettis County (S32 T46N R21W)
1 Control Device Requirement - NOx Water Injection amp Low-NOx Burners A ProEnergy Services shall control emissions from the combustion turbine
test cellstand using NOx water injection andor low-NOx burners as specified in the permit application
B The control devices shall be operated and maintained in accordance with the manufacturers specifications which shall be kept on site
C ProEnergy Services shall maintain an operating and maintenance log for the control devices which shall include the following 1) Incidents of malfunction with impact on emissions date and
duration of event probable cause corrective actions etc 2) Maintenance activities with inspection schedule repair actions
replacements etc
2 Fuel Requirement - Generator Sets A ProEnergy Services shall burn exclusively ultra-low sulfur diesel fuel with
a sulfur content less than or equal to 15 parts per million in the generator sets (EP-02 amp EP-03)
B ProEnergy Services shall demonstrate compliance with Special Condition 2A by obtaining records of the fuels sulfur content from the vendor for each shipment of fuel received or by testing each shipment of fuel for the sulfur content in accordance with the method described in 10 CSR 10-6 040 Reference Methods
3 Record Keeping and Reporting Requirements ProEnergy Services shall maintain all records required by this permit for not less than five years and shall make them available immediately to any Missouri Department of Natural Resources personnel upon request
- 3 -
REVIEW OF APPLICATION FOR AUTHORITY TO CONSTRUCT AND OPERATE SECTION (5) REVIEW
Project Number 2019-10-027 Installation ID Number 159-0063
Permit Number 12 2 O l 9 _ 01 O
Installation Address Parent Company ProEnergy Services ProEnergy Services 2001 ProEnergy Boulevard Building 9 2001 ProEnergy Boulevard Sedalia MO 65301 Sedalia MO 65301 Pettis County (S32 T46N R21W)
REVIEW SUMMARY
bull ProEnergy Services has applied for authority to install a combustion turbine test cellstand
bull The application was deemed complete on November 12 2019
bull HAP emissions from this project include the products of diesel and natural gas combustion All individual HAP emissions are expected to be bel9w the screening model action levels and total HAP emissions are expected to be below the major source level middot
bull None of the New Source Performance Standards (NSPS) apply to the installation 40 CFR 60 Subpart 1111- Standards of Performance for Stationary
Compression Ignition (Cl) Internal Combustion Engines (ICE) sect604200 (b) The provisions of this subpart are not applicable to stationary Cl ICE being tested at a stationary Cl ICE test cellstand
40 CFR 60 Subpart KKKK - Standards of Performance for Stationary Combustion Turbines sect604310 (d) Combustion turbine test cellsstands are exempt from this subpart
bull None of the MACT regulations apply to the equipment 40 CFR 63 Subpart YYYY - National Emission Standards for Hazardous Air
Pollutants for Stationary Combustion Turbines sect636090 (b)(5) Combustion turbine engine test cellsstands do not have to meet the requirements of this subpart
40 CFR 60 Subpart PPPPP - National Emission Standards for Hazardous Air Pollutants for Engine Test CellsStands sect639285 You are subject to this subpart if you own or operate an engine test cellstand that is located at a major source of HAP emissions
bull NOx water injection andor low-NOx burners will be used to control NOx emissions from the equipment
-4-
bull This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels
bull This installation is-located in Pettis County an attainmentunclassifiable area for all criteria pollutants
bull This installation is not on the List of Named Installations found in 1OCSR 10-6020(3)(8) Table 2 The installations major source level is 250 tons per year and fugitive emissions are not counted toward major source applicability
bull Emissions testing is not required for the equipment as a part of this permit Testing may be required as part of other state federal or applicable rules
bull No Operating Permit is required for this installation
bull Approval of this permit is recommended with special conditions
INSTALLATIONPROJECT DESCRIPTION
ProEnergy Services is an energy consulting and equipment servicing facility located in Sedalia MissouriTfle installation currently operates a combustion turbine test cellstand (EP-01) on site which does not require a construction permit as it is not considered an emission unit however a temporary construction permit (062018-007) was issued in June 2018 for the testing of a natural gas-fired turbine and generator package Another temporary construction permit (102018-015) was issued in October 2018 for the operation of two diesel-fired generators to balance operation of testing equipment Due to future business needs which require the equipment to operate for longer than the temporary construction permits allow ProEnergy Services is proposing to permanently permit the testing of combustion turbines at the test cellstand and the associated generators
Various combustion turbine configurations will be tested in the cellstand however the combustion turbines will primarily be natural gas-fired aero-derivative and nominallyshyrated at 50 MW with a 474 MMBtuhr heat input NOx emissions will be controlled by the utilization of NOx water injection andor low-NOx burners
Two nominally-rated 2 MW portable diesel-fired generator sets (EP-02 amp EP-03) will be required for startup which will provide power to a natural gas compressor The compressor will increase the pressure of the incoming natural gas from approximately 230 psi to 675 psi for combustion in the turbine
Power generated from the test cellstand will be directed into a load bank The electricity will neither be sold nor provided to the Transmission or Distribution Grid
- 5 -
EMISSIONSCONTROLS EVALUATION
Potential emissions from the combustion turbines being tested in the test cellstand were calculated using emission factors obtained from manufacturers data and the results of previous turbine tests performed on site Separate emission factors were given for startup shutdown and normal operations Emission factors taken from AP-42 Section 31 Stationary Gas Turbines (April 2000) were used in place of any incomplete data Although the testing period is variable it was conservatively estimated that 50 turbines will be tested per year (about 1 per week) This is overly-conservative because it assumes continuous adjacent testing at a rate which has yet to be realistically attained using the equipment Each unit is expected to have four starts each lasting 30 minutes and requiring 125 MMBtu of natural gas The turbine will run for 4 hours after each startup Shutdowns are expected to last 15 minutes and require 50 MMBtu of natural gas This yields a total firing time of 950 hours per year which consumes 4063 MMcf of natural gas All combustion turbines tested at the cellstand will be operated with NOx water injection andor low-NOx burners to reduce emissions Reduced NOx emissions were accounted for in the noted emission factors
Potential emissions from the two 193 MMBtuhr diesel-fired generators were calculated using emission factors obtained from manufacturers data Separate emission factors were given for full load and 50 load operations Emission factors taken from AP-42 Section 34 Large Stationary Diesel and All Stationary Dual-Fired Engines (October 1996) were used in place of any incomplete data Generator operation was adjusted to the assumed combustion turbine testing schedule Both generator sets will start up in tandem and during combustion turbine startup they will operate at full load for approximately 15 minutes until one of them is ramped down to 50 load At the completion of combustion turbine startup the generator set still at full load will also ramp down to 50 load Both generator sets will operate at 50 load for the remainder of the combustion turbine run
Table 1 provides an emissions summary for this project Because this installation has never previously received a construction permit existing potential emissions and existing actual emissions are unknown The two previous temporary permits issued to ProEnergy Services only included emissions from the limited testing periods which were calculated using conservative emission factors from AP-42 Potential emissions of the project represent the potential of the combustion turbines being tested at the test cellstand and the two generators using the estimated maximum operating rates
- 6 -
Table 1 Emissions Summary (tons per year)
PoUutant Regulatory DeMinimis
Levels
Existing Potential
Emissions
Existing Actual
Emissions
Potential Emissions of the middotProject
Conditioned Potential
Emissions of the Project
PM 250 N0 N0 226 NA
PM10 150 N0 ND 226 NA
PM2s 100 N0 ND 226 NIA
SOx 400 N0 ND 014 NA
NOx 400 ND ND 3427 NA
voe 400 ND N0 192 NA
co 1000 ND ND 1439 NA
Total HAPS 250 ND ND 023 NA ND = Not Determined
PERMIT RULE APPLICABILITY
This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels
APPLICABLE REQUIREMENTS
ProEnergy Services shall comply with the following applicable requirements The Missouri Air Conservation Laws and Regulations should be consulted for specific record keeping monitoring and reporting requirements Compliance with these emission standards based on information submitted in the application has been verified at the time this application was approved
GENERAL REQUIREMENTS
bull Start-Up Shutdown and Malfunction Conditions 1 0 CSR 10-6050
bull Submission of Emission Data Emission Fees and Process Information 10 CSR 10-6110 Per 10 CSR 10-6110(4)(8)1 and (4)(8)2C(II) a full EIQ is required for the
first full calendar year the equipment is in operation
bull Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin 10 CSR 10-6170
bull Restriction of Emission of Visible Air Contaminants 10 CSR 10-6220
bull Restriction of Emission of Odors 1 0 CSR 10-6165
-7-
STAFF RECOMMENDATION
On the basis of this review conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 Construction Permits Required it is recommended that this permit be granted with special conditions
PERMIT DOCUMENTS
The following documents are incorporated by reference into this permit
bull The Application for Authority to Construct form dated October 16 2019 received October 17 2019 designating ProEnergy Services as the owner and operator of the installation
- 8 -
APPENDIX A Abbreviations and Acronyms
percent
degF degrees Fahrenheit
acfm actual cubic feet per minute
BACT Best Available Control Technology
BMPs Best Management Practices
Btu British thermal unit
CAM Compliance Assurance Monitoring
CAS Chemical Abstracts Service
CEMS Continuous Emission Monitor System
CFR Code of Federal Regulations
CO carbon monoxide
C02carbon dioxide
C02e carbon dioxide equivalent
COMS Continuous Opacity Monitoring System
CSR Code of State Regulations
dscf dry standard cubic feet
EIQEmission Inventory Questionnaire
EP Emission Point
EPA Environmental Protection Agency
EU Emission Unit
fps feet per second
ft feet
GACT Generally Available Control Technology
GHG Greenhouse Gas
gpm gallons per minute
gr grains
GWP Global Warming Potential
HAPHazardous Air Pollutant
hr hour
hp horsepower
lb pound
lbshr pounds per hour
MACT Maximum Achievable Control Technology
microgm3 bull micrograms per cubic meter
mis meters per second
Mgal 1000 gallons
MW megawatt
MHDR maximum hourly design rate
MMBtu Million British thermal units
MMCF million cubic feet
MSDS Material Safety Data Sheet
NAAQS National Ambient Air Quality Standards
NESHAPs National Emissions Standards for Hazardous Air Pollutants
NOx nitrogen oxides
NSPS New Source Performance Standards
NSR New Source Review
PM particulate matter
PM2s particulate matter less than 25 microns in aerodynamic diameter
PM10 particulate matter less than IO microns in aerodynamic diameter
ppm parts per million
PSD Prevention of Significant Deterioration
PTE potential to em it
RACT Reasonable Available Control Technology
RAL Risk Assessment Level
SCC Source Classification Code
scfm standard cubic feet per minute
SDS Safety Data Sheet
SIC Standard Industrial Classification
SIP State Implementation Plan
SMAL Screening Model Action Levels
SOx sulfur oxides
S02 sulfur dioxide
SSM Startup Shutdown amp Malfunction
tph tons per hour
tpy tons per year
VMT vehicle miles traveled
VOC Volatile Organic Compound
- 9 -
STANDARD CONDITIONS
Permission to construct may be revoked if you fail to begin construction or modification within two years from the effective date of this permit Permittee should notify the Enforcement and Compliance Section of the Air Pollution Control Program if construction or modification is not started within two years after the effective date of this permit or if construction or modification is suspended for one year or more
You will be in violation of 10 CSR 10-6060 if you fail to adhere to the specifications and conditions listed in your application this permit and the project review In the event that there is a discrepancy between the permit application and this permit the conditions of this permit shall take precedence Specifically all air contaminant control devices shall be operated and maintained as specified in the application associated plans and specifications
You must notify the Enforcement and Compliance Section of the Departments Air Pollution Control Program of the anticipated date of startup of this (these) air contaminant source(s) The information must be made available within 30 days of actual startup Also you must notify the Departments regional office responsible for the area within which you are located within 15 days after the actual startup of this (these) air contaminant source(s)
A copy of the permit application and this permit and permit review shall be kept at the installation address and shall be made available to Departments personnel upon request
You may appeal this permit or any of the listed special conditions to the Administrative Hearing Commission (AHC) PO Box 1557 Jefferson City MO 65102 as provided in RSMo 6430756 and 6212503 If you choose to appeal you must file a petition with the AHC within 30 days after the date this decision was mailed or the date it was delivered whichever date was earlier If any such petition is sent by registered mail or certified mail it will be deemed filed on the date it is mailed If it is sent by any method other than registered mail or certified mail it will be deemed filed on the date it is received by the AHC
If you choose not to appeal this certificate the project review and your application and associated correspondence constitutes your permit to construct The permit allows you to construct and operate your air contaminant source(s but in no way relieves you of your obligation to comply with all applicable provisions of the Missouri Air Conservation Law regulations of the Missouri Department of Natural Resources and other applicable federal state and local laws and ordinances
The Air Pollution Control Program invites your questions regarding this air pollution permit Please contact the Construction Permit Unit using the contact information below
Contact Information Missouri Department of Natural Resources
Air Pollution Control Program PO Box 176
Jefferson City MO 65102-0176 (573) 751-4817
The regional office information can be found at the following website httpdnrmogovreqions
- 2 -
Project No 2019-10-027
Permit No 1 2 2 0 1 9 - 0 1 0 SPECIAL CONDITIONS The permittee is authorized to construct and operate subject to the following special conditions
The special conditions listed in this permit were included based on the authority granted to the Missouri Air Pollution Control Program by the Missouri Air Conservation Law (specifically 643075) and by the Missouri Rules listed in Title 10 Division 10 of the Code of State Regulations (specifically 10 CSR 10-6060) For specific details regarding conditions see 10 CSR 10-6060 paragraph (3)(E) Conditions required by permitting authority
ProEnergy Services Pettis County (S32 T46N R21W)
1 Control Device Requirement - NOx Water Injection amp Low-NOx Burners A ProEnergy Services shall control emissions from the combustion turbine
test cellstand using NOx water injection andor low-NOx burners as specified in the permit application
B The control devices shall be operated and maintained in accordance with the manufacturers specifications which shall be kept on site
C ProEnergy Services shall maintain an operating and maintenance log for the control devices which shall include the following 1) Incidents of malfunction with impact on emissions date and
duration of event probable cause corrective actions etc 2) Maintenance activities with inspection schedule repair actions
replacements etc
2 Fuel Requirement - Generator Sets A ProEnergy Services shall burn exclusively ultra-low sulfur diesel fuel with
a sulfur content less than or equal to 15 parts per million in the generator sets (EP-02 amp EP-03)
B ProEnergy Services shall demonstrate compliance with Special Condition 2A by obtaining records of the fuels sulfur content from the vendor for each shipment of fuel received or by testing each shipment of fuel for the sulfur content in accordance with the method described in 10 CSR 10-6 040 Reference Methods
3 Record Keeping and Reporting Requirements ProEnergy Services shall maintain all records required by this permit for not less than five years and shall make them available immediately to any Missouri Department of Natural Resources personnel upon request
- 3 -
REVIEW OF APPLICATION FOR AUTHORITY TO CONSTRUCT AND OPERATE SECTION (5) REVIEW
Project Number 2019-10-027 Installation ID Number 159-0063
Permit Number 12 2 O l 9 _ 01 O
Installation Address Parent Company ProEnergy Services ProEnergy Services 2001 ProEnergy Boulevard Building 9 2001 ProEnergy Boulevard Sedalia MO 65301 Sedalia MO 65301 Pettis County (S32 T46N R21W)
REVIEW SUMMARY
bull ProEnergy Services has applied for authority to install a combustion turbine test cellstand
bull The application was deemed complete on November 12 2019
bull HAP emissions from this project include the products of diesel and natural gas combustion All individual HAP emissions are expected to be bel9w the screening model action levels and total HAP emissions are expected to be below the major source level middot
bull None of the New Source Performance Standards (NSPS) apply to the installation 40 CFR 60 Subpart 1111- Standards of Performance for Stationary
Compression Ignition (Cl) Internal Combustion Engines (ICE) sect604200 (b) The provisions of this subpart are not applicable to stationary Cl ICE being tested at a stationary Cl ICE test cellstand
40 CFR 60 Subpart KKKK - Standards of Performance for Stationary Combustion Turbines sect604310 (d) Combustion turbine test cellsstands are exempt from this subpart
bull None of the MACT regulations apply to the equipment 40 CFR 63 Subpart YYYY - National Emission Standards for Hazardous Air
Pollutants for Stationary Combustion Turbines sect636090 (b)(5) Combustion turbine engine test cellsstands do not have to meet the requirements of this subpart
40 CFR 60 Subpart PPPPP - National Emission Standards for Hazardous Air Pollutants for Engine Test CellsStands sect639285 You are subject to this subpart if you own or operate an engine test cellstand that is located at a major source of HAP emissions
bull NOx water injection andor low-NOx burners will be used to control NOx emissions from the equipment
-4-
bull This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels
bull This installation is-located in Pettis County an attainmentunclassifiable area for all criteria pollutants
bull This installation is not on the List of Named Installations found in 1OCSR 10-6020(3)(8) Table 2 The installations major source level is 250 tons per year and fugitive emissions are not counted toward major source applicability
bull Emissions testing is not required for the equipment as a part of this permit Testing may be required as part of other state federal or applicable rules
bull No Operating Permit is required for this installation
bull Approval of this permit is recommended with special conditions
INSTALLATIONPROJECT DESCRIPTION
ProEnergy Services is an energy consulting and equipment servicing facility located in Sedalia MissouriTfle installation currently operates a combustion turbine test cellstand (EP-01) on site which does not require a construction permit as it is not considered an emission unit however a temporary construction permit (062018-007) was issued in June 2018 for the testing of a natural gas-fired turbine and generator package Another temporary construction permit (102018-015) was issued in October 2018 for the operation of two diesel-fired generators to balance operation of testing equipment Due to future business needs which require the equipment to operate for longer than the temporary construction permits allow ProEnergy Services is proposing to permanently permit the testing of combustion turbines at the test cellstand and the associated generators
Various combustion turbine configurations will be tested in the cellstand however the combustion turbines will primarily be natural gas-fired aero-derivative and nominallyshyrated at 50 MW with a 474 MMBtuhr heat input NOx emissions will be controlled by the utilization of NOx water injection andor low-NOx burners
Two nominally-rated 2 MW portable diesel-fired generator sets (EP-02 amp EP-03) will be required for startup which will provide power to a natural gas compressor The compressor will increase the pressure of the incoming natural gas from approximately 230 psi to 675 psi for combustion in the turbine
Power generated from the test cellstand will be directed into a load bank The electricity will neither be sold nor provided to the Transmission or Distribution Grid
- 5 -
EMISSIONSCONTROLS EVALUATION
Potential emissions from the combustion turbines being tested in the test cellstand were calculated using emission factors obtained from manufacturers data and the results of previous turbine tests performed on site Separate emission factors were given for startup shutdown and normal operations Emission factors taken from AP-42 Section 31 Stationary Gas Turbines (April 2000) were used in place of any incomplete data Although the testing period is variable it was conservatively estimated that 50 turbines will be tested per year (about 1 per week) This is overly-conservative because it assumes continuous adjacent testing at a rate which has yet to be realistically attained using the equipment Each unit is expected to have four starts each lasting 30 minutes and requiring 125 MMBtu of natural gas The turbine will run for 4 hours after each startup Shutdowns are expected to last 15 minutes and require 50 MMBtu of natural gas This yields a total firing time of 950 hours per year which consumes 4063 MMcf of natural gas All combustion turbines tested at the cellstand will be operated with NOx water injection andor low-NOx burners to reduce emissions Reduced NOx emissions were accounted for in the noted emission factors
Potential emissions from the two 193 MMBtuhr diesel-fired generators were calculated using emission factors obtained from manufacturers data Separate emission factors were given for full load and 50 load operations Emission factors taken from AP-42 Section 34 Large Stationary Diesel and All Stationary Dual-Fired Engines (October 1996) were used in place of any incomplete data Generator operation was adjusted to the assumed combustion turbine testing schedule Both generator sets will start up in tandem and during combustion turbine startup they will operate at full load for approximately 15 minutes until one of them is ramped down to 50 load At the completion of combustion turbine startup the generator set still at full load will also ramp down to 50 load Both generator sets will operate at 50 load for the remainder of the combustion turbine run
Table 1 provides an emissions summary for this project Because this installation has never previously received a construction permit existing potential emissions and existing actual emissions are unknown The two previous temporary permits issued to ProEnergy Services only included emissions from the limited testing periods which were calculated using conservative emission factors from AP-42 Potential emissions of the project represent the potential of the combustion turbines being tested at the test cellstand and the two generators using the estimated maximum operating rates
- 6 -
Table 1 Emissions Summary (tons per year)
PoUutant Regulatory DeMinimis
Levels
Existing Potential
Emissions
Existing Actual
Emissions
Potential Emissions of the middotProject
Conditioned Potential
Emissions of the Project
PM 250 N0 N0 226 NA
PM10 150 N0 ND 226 NA
PM2s 100 N0 ND 226 NIA
SOx 400 N0 ND 014 NA
NOx 400 ND ND 3427 NA
voe 400 ND N0 192 NA
co 1000 ND ND 1439 NA
Total HAPS 250 ND ND 023 NA ND = Not Determined
PERMIT RULE APPLICABILITY
This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels
APPLICABLE REQUIREMENTS
ProEnergy Services shall comply with the following applicable requirements The Missouri Air Conservation Laws and Regulations should be consulted for specific record keeping monitoring and reporting requirements Compliance with these emission standards based on information submitted in the application has been verified at the time this application was approved
GENERAL REQUIREMENTS
bull Start-Up Shutdown and Malfunction Conditions 1 0 CSR 10-6050
bull Submission of Emission Data Emission Fees and Process Information 10 CSR 10-6110 Per 10 CSR 10-6110(4)(8)1 and (4)(8)2C(II) a full EIQ is required for the
first full calendar year the equipment is in operation
bull Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin 10 CSR 10-6170
bull Restriction of Emission of Visible Air Contaminants 10 CSR 10-6220
bull Restriction of Emission of Odors 1 0 CSR 10-6165
-7-
STAFF RECOMMENDATION
On the basis of this review conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 Construction Permits Required it is recommended that this permit be granted with special conditions
PERMIT DOCUMENTS
The following documents are incorporated by reference into this permit
bull The Application for Authority to Construct form dated October 16 2019 received October 17 2019 designating ProEnergy Services as the owner and operator of the installation
- 8 -
APPENDIX A Abbreviations and Acronyms
percent
degF degrees Fahrenheit
acfm actual cubic feet per minute
BACT Best Available Control Technology
BMPs Best Management Practices
Btu British thermal unit
CAM Compliance Assurance Monitoring
CAS Chemical Abstracts Service
CEMS Continuous Emission Monitor System
CFR Code of Federal Regulations
CO carbon monoxide
C02carbon dioxide
C02e carbon dioxide equivalent
COMS Continuous Opacity Monitoring System
CSR Code of State Regulations
dscf dry standard cubic feet
EIQEmission Inventory Questionnaire
EP Emission Point
EPA Environmental Protection Agency
EU Emission Unit
fps feet per second
ft feet
GACT Generally Available Control Technology
GHG Greenhouse Gas
gpm gallons per minute
gr grains
GWP Global Warming Potential
HAPHazardous Air Pollutant
hr hour
hp horsepower
lb pound
lbshr pounds per hour
MACT Maximum Achievable Control Technology
microgm3 bull micrograms per cubic meter
mis meters per second
Mgal 1000 gallons
MW megawatt
MHDR maximum hourly design rate
MMBtu Million British thermal units
MMCF million cubic feet
MSDS Material Safety Data Sheet
NAAQS National Ambient Air Quality Standards
NESHAPs National Emissions Standards for Hazardous Air Pollutants
NOx nitrogen oxides
NSPS New Source Performance Standards
NSR New Source Review
PM particulate matter
PM2s particulate matter less than 25 microns in aerodynamic diameter
PM10 particulate matter less than IO microns in aerodynamic diameter
ppm parts per million
PSD Prevention of Significant Deterioration
PTE potential to em it
RACT Reasonable Available Control Technology
RAL Risk Assessment Level
SCC Source Classification Code
scfm standard cubic feet per minute
SDS Safety Data Sheet
SIC Standard Industrial Classification
SIP State Implementation Plan
SMAL Screening Model Action Levels
SOx sulfur oxides
S02 sulfur dioxide
SSM Startup Shutdown amp Malfunction
tph tons per hour
tpy tons per year
VMT vehicle miles traveled
VOC Volatile Organic Compound
- 9 -
Project No 2019-10-027
Permit No 1 2 2 0 1 9 - 0 1 0 SPECIAL CONDITIONS The permittee is authorized to construct and operate subject to the following special conditions
The special conditions listed in this permit were included based on the authority granted to the Missouri Air Pollution Control Program by the Missouri Air Conservation Law (specifically 643075) and by the Missouri Rules listed in Title 10 Division 10 of the Code of State Regulations (specifically 10 CSR 10-6060) For specific details regarding conditions see 10 CSR 10-6060 paragraph (3)(E) Conditions required by permitting authority
ProEnergy Services Pettis County (S32 T46N R21W)
1 Control Device Requirement - NOx Water Injection amp Low-NOx Burners A ProEnergy Services shall control emissions from the combustion turbine
test cellstand using NOx water injection andor low-NOx burners as specified in the permit application
B The control devices shall be operated and maintained in accordance with the manufacturers specifications which shall be kept on site
C ProEnergy Services shall maintain an operating and maintenance log for the control devices which shall include the following 1) Incidents of malfunction with impact on emissions date and
duration of event probable cause corrective actions etc 2) Maintenance activities with inspection schedule repair actions
replacements etc
2 Fuel Requirement - Generator Sets A ProEnergy Services shall burn exclusively ultra-low sulfur diesel fuel with
a sulfur content less than or equal to 15 parts per million in the generator sets (EP-02 amp EP-03)
B ProEnergy Services shall demonstrate compliance with Special Condition 2A by obtaining records of the fuels sulfur content from the vendor for each shipment of fuel received or by testing each shipment of fuel for the sulfur content in accordance with the method described in 10 CSR 10-6 040 Reference Methods
3 Record Keeping and Reporting Requirements ProEnergy Services shall maintain all records required by this permit for not less than five years and shall make them available immediately to any Missouri Department of Natural Resources personnel upon request
- 3 -
REVIEW OF APPLICATION FOR AUTHORITY TO CONSTRUCT AND OPERATE SECTION (5) REVIEW
Project Number 2019-10-027 Installation ID Number 159-0063
Permit Number 12 2 O l 9 _ 01 O
Installation Address Parent Company ProEnergy Services ProEnergy Services 2001 ProEnergy Boulevard Building 9 2001 ProEnergy Boulevard Sedalia MO 65301 Sedalia MO 65301 Pettis County (S32 T46N R21W)
REVIEW SUMMARY
bull ProEnergy Services has applied for authority to install a combustion turbine test cellstand
bull The application was deemed complete on November 12 2019
bull HAP emissions from this project include the products of diesel and natural gas combustion All individual HAP emissions are expected to be bel9w the screening model action levels and total HAP emissions are expected to be below the major source level middot
bull None of the New Source Performance Standards (NSPS) apply to the installation 40 CFR 60 Subpart 1111- Standards of Performance for Stationary
Compression Ignition (Cl) Internal Combustion Engines (ICE) sect604200 (b) The provisions of this subpart are not applicable to stationary Cl ICE being tested at a stationary Cl ICE test cellstand
40 CFR 60 Subpart KKKK - Standards of Performance for Stationary Combustion Turbines sect604310 (d) Combustion turbine test cellsstands are exempt from this subpart
bull None of the MACT regulations apply to the equipment 40 CFR 63 Subpart YYYY - National Emission Standards for Hazardous Air
Pollutants for Stationary Combustion Turbines sect636090 (b)(5) Combustion turbine engine test cellsstands do not have to meet the requirements of this subpart
40 CFR 60 Subpart PPPPP - National Emission Standards for Hazardous Air Pollutants for Engine Test CellsStands sect639285 You are subject to this subpart if you own or operate an engine test cellstand that is located at a major source of HAP emissions
bull NOx water injection andor low-NOx burners will be used to control NOx emissions from the equipment
-4-
bull This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels
bull This installation is-located in Pettis County an attainmentunclassifiable area for all criteria pollutants
bull This installation is not on the List of Named Installations found in 1OCSR 10-6020(3)(8) Table 2 The installations major source level is 250 tons per year and fugitive emissions are not counted toward major source applicability
bull Emissions testing is not required for the equipment as a part of this permit Testing may be required as part of other state federal or applicable rules
bull No Operating Permit is required for this installation
bull Approval of this permit is recommended with special conditions
INSTALLATIONPROJECT DESCRIPTION
ProEnergy Services is an energy consulting and equipment servicing facility located in Sedalia MissouriTfle installation currently operates a combustion turbine test cellstand (EP-01) on site which does not require a construction permit as it is not considered an emission unit however a temporary construction permit (062018-007) was issued in June 2018 for the testing of a natural gas-fired turbine and generator package Another temporary construction permit (102018-015) was issued in October 2018 for the operation of two diesel-fired generators to balance operation of testing equipment Due to future business needs which require the equipment to operate for longer than the temporary construction permits allow ProEnergy Services is proposing to permanently permit the testing of combustion turbines at the test cellstand and the associated generators
Various combustion turbine configurations will be tested in the cellstand however the combustion turbines will primarily be natural gas-fired aero-derivative and nominallyshyrated at 50 MW with a 474 MMBtuhr heat input NOx emissions will be controlled by the utilization of NOx water injection andor low-NOx burners
Two nominally-rated 2 MW portable diesel-fired generator sets (EP-02 amp EP-03) will be required for startup which will provide power to a natural gas compressor The compressor will increase the pressure of the incoming natural gas from approximately 230 psi to 675 psi for combustion in the turbine
Power generated from the test cellstand will be directed into a load bank The electricity will neither be sold nor provided to the Transmission or Distribution Grid
- 5 -
EMISSIONSCONTROLS EVALUATION
Potential emissions from the combustion turbines being tested in the test cellstand were calculated using emission factors obtained from manufacturers data and the results of previous turbine tests performed on site Separate emission factors were given for startup shutdown and normal operations Emission factors taken from AP-42 Section 31 Stationary Gas Turbines (April 2000) were used in place of any incomplete data Although the testing period is variable it was conservatively estimated that 50 turbines will be tested per year (about 1 per week) This is overly-conservative because it assumes continuous adjacent testing at a rate which has yet to be realistically attained using the equipment Each unit is expected to have four starts each lasting 30 minutes and requiring 125 MMBtu of natural gas The turbine will run for 4 hours after each startup Shutdowns are expected to last 15 minutes and require 50 MMBtu of natural gas This yields a total firing time of 950 hours per year which consumes 4063 MMcf of natural gas All combustion turbines tested at the cellstand will be operated with NOx water injection andor low-NOx burners to reduce emissions Reduced NOx emissions were accounted for in the noted emission factors
Potential emissions from the two 193 MMBtuhr diesel-fired generators were calculated using emission factors obtained from manufacturers data Separate emission factors were given for full load and 50 load operations Emission factors taken from AP-42 Section 34 Large Stationary Diesel and All Stationary Dual-Fired Engines (October 1996) were used in place of any incomplete data Generator operation was adjusted to the assumed combustion turbine testing schedule Both generator sets will start up in tandem and during combustion turbine startup they will operate at full load for approximately 15 minutes until one of them is ramped down to 50 load At the completion of combustion turbine startup the generator set still at full load will also ramp down to 50 load Both generator sets will operate at 50 load for the remainder of the combustion turbine run
Table 1 provides an emissions summary for this project Because this installation has never previously received a construction permit existing potential emissions and existing actual emissions are unknown The two previous temporary permits issued to ProEnergy Services only included emissions from the limited testing periods which were calculated using conservative emission factors from AP-42 Potential emissions of the project represent the potential of the combustion turbines being tested at the test cellstand and the two generators using the estimated maximum operating rates
- 6 -
Table 1 Emissions Summary (tons per year)
PoUutant Regulatory DeMinimis
Levels
Existing Potential
Emissions
Existing Actual
Emissions
Potential Emissions of the middotProject
Conditioned Potential
Emissions of the Project
PM 250 N0 N0 226 NA
PM10 150 N0 ND 226 NA
PM2s 100 N0 ND 226 NIA
SOx 400 N0 ND 014 NA
NOx 400 ND ND 3427 NA
voe 400 ND N0 192 NA
co 1000 ND ND 1439 NA
Total HAPS 250 ND ND 023 NA ND = Not Determined
PERMIT RULE APPLICABILITY
This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels
APPLICABLE REQUIREMENTS
ProEnergy Services shall comply with the following applicable requirements The Missouri Air Conservation Laws and Regulations should be consulted for specific record keeping monitoring and reporting requirements Compliance with these emission standards based on information submitted in the application has been verified at the time this application was approved
GENERAL REQUIREMENTS
bull Start-Up Shutdown and Malfunction Conditions 1 0 CSR 10-6050
bull Submission of Emission Data Emission Fees and Process Information 10 CSR 10-6110 Per 10 CSR 10-6110(4)(8)1 and (4)(8)2C(II) a full EIQ is required for the
first full calendar year the equipment is in operation
bull Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin 10 CSR 10-6170
bull Restriction of Emission of Visible Air Contaminants 10 CSR 10-6220
bull Restriction of Emission of Odors 1 0 CSR 10-6165
-7-
STAFF RECOMMENDATION
On the basis of this review conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 Construction Permits Required it is recommended that this permit be granted with special conditions
PERMIT DOCUMENTS
The following documents are incorporated by reference into this permit
bull The Application for Authority to Construct form dated October 16 2019 received October 17 2019 designating ProEnergy Services as the owner and operator of the installation
- 8 -
APPENDIX A Abbreviations and Acronyms
percent
degF degrees Fahrenheit
acfm actual cubic feet per minute
BACT Best Available Control Technology
BMPs Best Management Practices
Btu British thermal unit
CAM Compliance Assurance Monitoring
CAS Chemical Abstracts Service
CEMS Continuous Emission Monitor System
CFR Code of Federal Regulations
CO carbon monoxide
C02carbon dioxide
C02e carbon dioxide equivalent
COMS Continuous Opacity Monitoring System
CSR Code of State Regulations
dscf dry standard cubic feet
EIQEmission Inventory Questionnaire
EP Emission Point
EPA Environmental Protection Agency
EU Emission Unit
fps feet per second
ft feet
GACT Generally Available Control Technology
GHG Greenhouse Gas
gpm gallons per minute
gr grains
GWP Global Warming Potential
HAPHazardous Air Pollutant
hr hour
hp horsepower
lb pound
lbshr pounds per hour
MACT Maximum Achievable Control Technology
microgm3 bull micrograms per cubic meter
mis meters per second
Mgal 1000 gallons
MW megawatt
MHDR maximum hourly design rate
MMBtu Million British thermal units
MMCF million cubic feet
MSDS Material Safety Data Sheet
NAAQS National Ambient Air Quality Standards
NESHAPs National Emissions Standards for Hazardous Air Pollutants
NOx nitrogen oxides
NSPS New Source Performance Standards
NSR New Source Review
PM particulate matter
PM2s particulate matter less than 25 microns in aerodynamic diameter
PM10 particulate matter less than IO microns in aerodynamic diameter
ppm parts per million
PSD Prevention of Significant Deterioration
PTE potential to em it
RACT Reasonable Available Control Technology
RAL Risk Assessment Level
SCC Source Classification Code
scfm standard cubic feet per minute
SDS Safety Data Sheet
SIC Standard Industrial Classification
SIP State Implementation Plan
SMAL Screening Model Action Levels
SOx sulfur oxides
S02 sulfur dioxide
SSM Startup Shutdown amp Malfunction
tph tons per hour
tpy tons per year
VMT vehicle miles traveled
VOC Volatile Organic Compound
- 9 -
REVIEW OF APPLICATION FOR AUTHORITY TO CONSTRUCT AND OPERATE SECTION (5) REVIEW
Project Number 2019-10-027 Installation ID Number 159-0063
Permit Number 12 2 O l 9 _ 01 O
Installation Address Parent Company ProEnergy Services ProEnergy Services 2001 ProEnergy Boulevard Building 9 2001 ProEnergy Boulevard Sedalia MO 65301 Sedalia MO 65301 Pettis County (S32 T46N R21W)
REVIEW SUMMARY
bull ProEnergy Services has applied for authority to install a combustion turbine test cellstand
bull The application was deemed complete on November 12 2019
bull HAP emissions from this project include the products of diesel and natural gas combustion All individual HAP emissions are expected to be bel9w the screening model action levels and total HAP emissions are expected to be below the major source level middot
bull None of the New Source Performance Standards (NSPS) apply to the installation 40 CFR 60 Subpart 1111- Standards of Performance for Stationary
Compression Ignition (Cl) Internal Combustion Engines (ICE) sect604200 (b) The provisions of this subpart are not applicable to stationary Cl ICE being tested at a stationary Cl ICE test cellstand
40 CFR 60 Subpart KKKK - Standards of Performance for Stationary Combustion Turbines sect604310 (d) Combustion turbine test cellsstands are exempt from this subpart
bull None of the MACT regulations apply to the equipment 40 CFR 63 Subpart YYYY - National Emission Standards for Hazardous Air
Pollutants for Stationary Combustion Turbines sect636090 (b)(5) Combustion turbine engine test cellsstands do not have to meet the requirements of this subpart
40 CFR 60 Subpart PPPPP - National Emission Standards for Hazardous Air Pollutants for Engine Test CellsStands sect639285 You are subject to this subpart if you own or operate an engine test cellstand that is located at a major source of HAP emissions
bull NOx water injection andor low-NOx burners will be used to control NOx emissions from the equipment
-4-
bull This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels
bull This installation is-located in Pettis County an attainmentunclassifiable area for all criteria pollutants
bull This installation is not on the List of Named Installations found in 1OCSR 10-6020(3)(8) Table 2 The installations major source level is 250 tons per year and fugitive emissions are not counted toward major source applicability
bull Emissions testing is not required for the equipment as a part of this permit Testing may be required as part of other state federal or applicable rules
bull No Operating Permit is required for this installation
bull Approval of this permit is recommended with special conditions
INSTALLATIONPROJECT DESCRIPTION
ProEnergy Services is an energy consulting and equipment servicing facility located in Sedalia MissouriTfle installation currently operates a combustion turbine test cellstand (EP-01) on site which does not require a construction permit as it is not considered an emission unit however a temporary construction permit (062018-007) was issued in June 2018 for the testing of a natural gas-fired turbine and generator package Another temporary construction permit (102018-015) was issued in October 2018 for the operation of two diesel-fired generators to balance operation of testing equipment Due to future business needs which require the equipment to operate for longer than the temporary construction permits allow ProEnergy Services is proposing to permanently permit the testing of combustion turbines at the test cellstand and the associated generators
Various combustion turbine configurations will be tested in the cellstand however the combustion turbines will primarily be natural gas-fired aero-derivative and nominallyshyrated at 50 MW with a 474 MMBtuhr heat input NOx emissions will be controlled by the utilization of NOx water injection andor low-NOx burners
Two nominally-rated 2 MW portable diesel-fired generator sets (EP-02 amp EP-03) will be required for startup which will provide power to a natural gas compressor The compressor will increase the pressure of the incoming natural gas from approximately 230 psi to 675 psi for combustion in the turbine
Power generated from the test cellstand will be directed into a load bank The electricity will neither be sold nor provided to the Transmission or Distribution Grid
- 5 -
EMISSIONSCONTROLS EVALUATION
Potential emissions from the combustion turbines being tested in the test cellstand were calculated using emission factors obtained from manufacturers data and the results of previous turbine tests performed on site Separate emission factors were given for startup shutdown and normal operations Emission factors taken from AP-42 Section 31 Stationary Gas Turbines (April 2000) were used in place of any incomplete data Although the testing period is variable it was conservatively estimated that 50 turbines will be tested per year (about 1 per week) This is overly-conservative because it assumes continuous adjacent testing at a rate which has yet to be realistically attained using the equipment Each unit is expected to have four starts each lasting 30 minutes and requiring 125 MMBtu of natural gas The turbine will run for 4 hours after each startup Shutdowns are expected to last 15 minutes and require 50 MMBtu of natural gas This yields a total firing time of 950 hours per year which consumes 4063 MMcf of natural gas All combustion turbines tested at the cellstand will be operated with NOx water injection andor low-NOx burners to reduce emissions Reduced NOx emissions were accounted for in the noted emission factors
Potential emissions from the two 193 MMBtuhr diesel-fired generators were calculated using emission factors obtained from manufacturers data Separate emission factors were given for full load and 50 load operations Emission factors taken from AP-42 Section 34 Large Stationary Diesel and All Stationary Dual-Fired Engines (October 1996) were used in place of any incomplete data Generator operation was adjusted to the assumed combustion turbine testing schedule Both generator sets will start up in tandem and during combustion turbine startup they will operate at full load for approximately 15 minutes until one of them is ramped down to 50 load At the completion of combustion turbine startup the generator set still at full load will also ramp down to 50 load Both generator sets will operate at 50 load for the remainder of the combustion turbine run
Table 1 provides an emissions summary for this project Because this installation has never previously received a construction permit existing potential emissions and existing actual emissions are unknown The two previous temporary permits issued to ProEnergy Services only included emissions from the limited testing periods which were calculated using conservative emission factors from AP-42 Potential emissions of the project represent the potential of the combustion turbines being tested at the test cellstand and the two generators using the estimated maximum operating rates
- 6 -
Table 1 Emissions Summary (tons per year)
PoUutant Regulatory DeMinimis
Levels
Existing Potential
Emissions
Existing Actual
Emissions
Potential Emissions of the middotProject
Conditioned Potential
Emissions of the Project
PM 250 N0 N0 226 NA
PM10 150 N0 ND 226 NA
PM2s 100 N0 ND 226 NIA
SOx 400 N0 ND 014 NA
NOx 400 ND ND 3427 NA
voe 400 ND N0 192 NA
co 1000 ND ND 1439 NA
Total HAPS 250 ND ND 023 NA ND = Not Determined
PERMIT RULE APPLICABILITY
This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels
APPLICABLE REQUIREMENTS
ProEnergy Services shall comply with the following applicable requirements The Missouri Air Conservation Laws and Regulations should be consulted for specific record keeping monitoring and reporting requirements Compliance with these emission standards based on information submitted in the application has been verified at the time this application was approved
GENERAL REQUIREMENTS
bull Start-Up Shutdown and Malfunction Conditions 1 0 CSR 10-6050
bull Submission of Emission Data Emission Fees and Process Information 10 CSR 10-6110 Per 10 CSR 10-6110(4)(8)1 and (4)(8)2C(II) a full EIQ is required for the
first full calendar year the equipment is in operation
bull Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin 10 CSR 10-6170
bull Restriction of Emission of Visible Air Contaminants 10 CSR 10-6220
bull Restriction of Emission of Odors 1 0 CSR 10-6165
-7-
STAFF RECOMMENDATION
On the basis of this review conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 Construction Permits Required it is recommended that this permit be granted with special conditions
PERMIT DOCUMENTS
The following documents are incorporated by reference into this permit
bull The Application for Authority to Construct form dated October 16 2019 received October 17 2019 designating ProEnergy Services as the owner and operator of the installation
- 8 -
APPENDIX A Abbreviations and Acronyms
percent
degF degrees Fahrenheit
acfm actual cubic feet per minute
BACT Best Available Control Technology
BMPs Best Management Practices
Btu British thermal unit
CAM Compliance Assurance Monitoring
CAS Chemical Abstracts Service
CEMS Continuous Emission Monitor System
CFR Code of Federal Regulations
CO carbon monoxide
C02carbon dioxide
C02e carbon dioxide equivalent
COMS Continuous Opacity Monitoring System
CSR Code of State Regulations
dscf dry standard cubic feet
EIQEmission Inventory Questionnaire
EP Emission Point
EPA Environmental Protection Agency
EU Emission Unit
fps feet per second
ft feet
GACT Generally Available Control Technology
GHG Greenhouse Gas
gpm gallons per minute
gr grains
GWP Global Warming Potential
HAPHazardous Air Pollutant
hr hour
hp horsepower
lb pound
lbshr pounds per hour
MACT Maximum Achievable Control Technology
microgm3 bull micrograms per cubic meter
mis meters per second
Mgal 1000 gallons
MW megawatt
MHDR maximum hourly design rate
MMBtu Million British thermal units
MMCF million cubic feet
MSDS Material Safety Data Sheet
NAAQS National Ambient Air Quality Standards
NESHAPs National Emissions Standards for Hazardous Air Pollutants
NOx nitrogen oxides
NSPS New Source Performance Standards
NSR New Source Review
PM particulate matter
PM2s particulate matter less than 25 microns in aerodynamic diameter
PM10 particulate matter less than IO microns in aerodynamic diameter
ppm parts per million
PSD Prevention of Significant Deterioration
PTE potential to em it
RACT Reasonable Available Control Technology
RAL Risk Assessment Level
SCC Source Classification Code
scfm standard cubic feet per minute
SDS Safety Data Sheet
SIC Standard Industrial Classification
SIP State Implementation Plan
SMAL Screening Model Action Levels
SOx sulfur oxides
S02 sulfur dioxide
SSM Startup Shutdown amp Malfunction
tph tons per hour
tpy tons per year
VMT vehicle miles traveled
VOC Volatile Organic Compound
- 9 -
bull This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels
bull This installation is-located in Pettis County an attainmentunclassifiable area for all criteria pollutants
bull This installation is not on the List of Named Installations found in 1OCSR 10-6020(3)(8) Table 2 The installations major source level is 250 tons per year and fugitive emissions are not counted toward major source applicability
bull Emissions testing is not required for the equipment as a part of this permit Testing may be required as part of other state federal or applicable rules
bull No Operating Permit is required for this installation
bull Approval of this permit is recommended with special conditions
INSTALLATIONPROJECT DESCRIPTION
ProEnergy Services is an energy consulting and equipment servicing facility located in Sedalia MissouriTfle installation currently operates a combustion turbine test cellstand (EP-01) on site which does not require a construction permit as it is not considered an emission unit however a temporary construction permit (062018-007) was issued in June 2018 for the testing of a natural gas-fired turbine and generator package Another temporary construction permit (102018-015) was issued in October 2018 for the operation of two diesel-fired generators to balance operation of testing equipment Due to future business needs which require the equipment to operate for longer than the temporary construction permits allow ProEnergy Services is proposing to permanently permit the testing of combustion turbines at the test cellstand and the associated generators
Various combustion turbine configurations will be tested in the cellstand however the combustion turbines will primarily be natural gas-fired aero-derivative and nominallyshyrated at 50 MW with a 474 MMBtuhr heat input NOx emissions will be controlled by the utilization of NOx water injection andor low-NOx burners
Two nominally-rated 2 MW portable diesel-fired generator sets (EP-02 amp EP-03) will be required for startup which will provide power to a natural gas compressor The compressor will increase the pressure of the incoming natural gas from approximately 230 psi to 675 psi for combustion in the turbine
Power generated from the test cellstand will be directed into a load bank The electricity will neither be sold nor provided to the Transmission or Distribution Grid
- 5 -
EMISSIONSCONTROLS EVALUATION
Potential emissions from the combustion turbines being tested in the test cellstand were calculated using emission factors obtained from manufacturers data and the results of previous turbine tests performed on site Separate emission factors were given for startup shutdown and normal operations Emission factors taken from AP-42 Section 31 Stationary Gas Turbines (April 2000) were used in place of any incomplete data Although the testing period is variable it was conservatively estimated that 50 turbines will be tested per year (about 1 per week) This is overly-conservative because it assumes continuous adjacent testing at a rate which has yet to be realistically attained using the equipment Each unit is expected to have four starts each lasting 30 minutes and requiring 125 MMBtu of natural gas The turbine will run for 4 hours after each startup Shutdowns are expected to last 15 minutes and require 50 MMBtu of natural gas This yields a total firing time of 950 hours per year which consumes 4063 MMcf of natural gas All combustion turbines tested at the cellstand will be operated with NOx water injection andor low-NOx burners to reduce emissions Reduced NOx emissions were accounted for in the noted emission factors
Potential emissions from the two 193 MMBtuhr diesel-fired generators were calculated using emission factors obtained from manufacturers data Separate emission factors were given for full load and 50 load operations Emission factors taken from AP-42 Section 34 Large Stationary Diesel and All Stationary Dual-Fired Engines (October 1996) were used in place of any incomplete data Generator operation was adjusted to the assumed combustion turbine testing schedule Both generator sets will start up in tandem and during combustion turbine startup they will operate at full load for approximately 15 minutes until one of them is ramped down to 50 load At the completion of combustion turbine startup the generator set still at full load will also ramp down to 50 load Both generator sets will operate at 50 load for the remainder of the combustion turbine run
Table 1 provides an emissions summary for this project Because this installation has never previously received a construction permit existing potential emissions and existing actual emissions are unknown The two previous temporary permits issued to ProEnergy Services only included emissions from the limited testing periods which were calculated using conservative emission factors from AP-42 Potential emissions of the project represent the potential of the combustion turbines being tested at the test cellstand and the two generators using the estimated maximum operating rates
- 6 -
Table 1 Emissions Summary (tons per year)
PoUutant Regulatory DeMinimis
Levels
Existing Potential
Emissions
Existing Actual
Emissions
Potential Emissions of the middotProject
Conditioned Potential
Emissions of the Project
PM 250 N0 N0 226 NA
PM10 150 N0 ND 226 NA
PM2s 100 N0 ND 226 NIA
SOx 400 N0 ND 014 NA
NOx 400 ND ND 3427 NA
voe 400 ND N0 192 NA
co 1000 ND ND 1439 NA
Total HAPS 250 ND ND 023 NA ND = Not Determined
PERMIT RULE APPLICABILITY
This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels
APPLICABLE REQUIREMENTS
ProEnergy Services shall comply with the following applicable requirements The Missouri Air Conservation Laws and Regulations should be consulted for specific record keeping monitoring and reporting requirements Compliance with these emission standards based on information submitted in the application has been verified at the time this application was approved
GENERAL REQUIREMENTS
bull Start-Up Shutdown and Malfunction Conditions 1 0 CSR 10-6050
bull Submission of Emission Data Emission Fees and Process Information 10 CSR 10-6110 Per 10 CSR 10-6110(4)(8)1 and (4)(8)2C(II) a full EIQ is required for the
first full calendar year the equipment is in operation
bull Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin 10 CSR 10-6170
bull Restriction of Emission of Visible Air Contaminants 10 CSR 10-6220
bull Restriction of Emission of Odors 1 0 CSR 10-6165
-7-
STAFF RECOMMENDATION
On the basis of this review conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 Construction Permits Required it is recommended that this permit be granted with special conditions
PERMIT DOCUMENTS
The following documents are incorporated by reference into this permit
bull The Application for Authority to Construct form dated October 16 2019 received October 17 2019 designating ProEnergy Services as the owner and operator of the installation
- 8 -
APPENDIX A Abbreviations and Acronyms
percent
degF degrees Fahrenheit
acfm actual cubic feet per minute
BACT Best Available Control Technology
BMPs Best Management Practices
Btu British thermal unit
CAM Compliance Assurance Monitoring
CAS Chemical Abstracts Service
CEMS Continuous Emission Monitor System
CFR Code of Federal Regulations
CO carbon monoxide
C02carbon dioxide
C02e carbon dioxide equivalent
COMS Continuous Opacity Monitoring System
CSR Code of State Regulations
dscf dry standard cubic feet
EIQEmission Inventory Questionnaire
EP Emission Point
EPA Environmental Protection Agency
EU Emission Unit
fps feet per second
ft feet
GACT Generally Available Control Technology
GHG Greenhouse Gas
gpm gallons per minute
gr grains
GWP Global Warming Potential
HAPHazardous Air Pollutant
hr hour
hp horsepower
lb pound
lbshr pounds per hour
MACT Maximum Achievable Control Technology
microgm3 bull micrograms per cubic meter
mis meters per second
Mgal 1000 gallons
MW megawatt
MHDR maximum hourly design rate
MMBtu Million British thermal units
MMCF million cubic feet
MSDS Material Safety Data Sheet
NAAQS National Ambient Air Quality Standards
NESHAPs National Emissions Standards for Hazardous Air Pollutants
NOx nitrogen oxides
NSPS New Source Performance Standards
NSR New Source Review
PM particulate matter
PM2s particulate matter less than 25 microns in aerodynamic diameter
PM10 particulate matter less than IO microns in aerodynamic diameter
ppm parts per million
PSD Prevention of Significant Deterioration
PTE potential to em it
RACT Reasonable Available Control Technology
RAL Risk Assessment Level
SCC Source Classification Code
scfm standard cubic feet per minute
SDS Safety Data Sheet
SIC Standard Industrial Classification
SIP State Implementation Plan
SMAL Screening Model Action Levels
SOx sulfur oxides
S02 sulfur dioxide
SSM Startup Shutdown amp Malfunction
tph tons per hour
tpy tons per year
VMT vehicle miles traveled
VOC Volatile Organic Compound
- 9 -
EMISSIONSCONTROLS EVALUATION
Potential emissions from the combustion turbines being tested in the test cellstand were calculated using emission factors obtained from manufacturers data and the results of previous turbine tests performed on site Separate emission factors were given for startup shutdown and normal operations Emission factors taken from AP-42 Section 31 Stationary Gas Turbines (April 2000) were used in place of any incomplete data Although the testing period is variable it was conservatively estimated that 50 turbines will be tested per year (about 1 per week) This is overly-conservative because it assumes continuous adjacent testing at a rate which has yet to be realistically attained using the equipment Each unit is expected to have four starts each lasting 30 minutes and requiring 125 MMBtu of natural gas The turbine will run for 4 hours after each startup Shutdowns are expected to last 15 minutes and require 50 MMBtu of natural gas This yields a total firing time of 950 hours per year which consumes 4063 MMcf of natural gas All combustion turbines tested at the cellstand will be operated with NOx water injection andor low-NOx burners to reduce emissions Reduced NOx emissions were accounted for in the noted emission factors
Potential emissions from the two 193 MMBtuhr diesel-fired generators were calculated using emission factors obtained from manufacturers data Separate emission factors were given for full load and 50 load operations Emission factors taken from AP-42 Section 34 Large Stationary Diesel and All Stationary Dual-Fired Engines (October 1996) were used in place of any incomplete data Generator operation was adjusted to the assumed combustion turbine testing schedule Both generator sets will start up in tandem and during combustion turbine startup they will operate at full load for approximately 15 minutes until one of them is ramped down to 50 load At the completion of combustion turbine startup the generator set still at full load will also ramp down to 50 load Both generator sets will operate at 50 load for the remainder of the combustion turbine run
Table 1 provides an emissions summary for this project Because this installation has never previously received a construction permit existing potential emissions and existing actual emissions are unknown The two previous temporary permits issued to ProEnergy Services only included emissions from the limited testing periods which were calculated using conservative emission factors from AP-42 Potential emissions of the project represent the potential of the combustion turbines being tested at the test cellstand and the two generators using the estimated maximum operating rates
- 6 -
Table 1 Emissions Summary (tons per year)
PoUutant Regulatory DeMinimis
Levels
Existing Potential
Emissions
Existing Actual
Emissions
Potential Emissions of the middotProject
Conditioned Potential
Emissions of the Project
PM 250 N0 N0 226 NA
PM10 150 N0 ND 226 NA
PM2s 100 N0 ND 226 NIA
SOx 400 N0 ND 014 NA
NOx 400 ND ND 3427 NA
voe 400 ND N0 192 NA
co 1000 ND ND 1439 NA
Total HAPS 250 ND ND 023 NA ND = Not Determined
PERMIT RULE APPLICABILITY
This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels
APPLICABLE REQUIREMENTS
ProEnergy Services shall comply with the following applicable requirements The Missouri Air Conservation Laws and Regulations should be consulted for specific record keeping monitoring and reporting requirements Compliance with these emission standards based on information submitted in the application has been verified at the time this application was approved
GENERAL REQUIREMENTS
bull Start-Up Shutdown and Malfunction Conditions 1 0 CSR 10-6050
bull Submission of Emission Data Emission Fees and Process Information 10 CSR 10-6110 Per 10 CSR 10-6110(4)(8)1 and (4)(8)2C(II) a full EIQ is required for the
first full calendar year the equipment is in operation
bull Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin 10 CSR 10-6170
bull Restriction of Emission of Visible Air Contaminants 10 CSR 10-6220
bull Restriction of Emission of Odors 1 0 CSR 10-6165
-7-
STAFF RECOMMENDATION
On the basis of this review conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 Construction Permits Required it is recommended that this permit be granted with special conditions
PERMIT DOCUMENTS
The following documents are incorporated by reference into this permit
bull The Application for Authority to Construct form dated October 16 2019 received October 17 2019 designating ProEnergy Services as the owner and operator of the installation
- 8 -
APPENDIX A Abbreviations and Acronyms
percent
degF degrees Fahrenheit
acfm actual cubic feet per minute
BACT Best Available Control Technology
BMPs Best Management Practices
Btu British thermal unit
CAM Compliance Assurance Monitoring
CAS Chemical Abstracts Service
CEMS Continuous Emission Monitor System
CFR Code of Federal Regulations
CO carbon monoxide
C02carbon dioxide
C02e carbon dioxide equivalent
COMS Continuous Opacity Monitoring System
CSR Code of State Regulations
dscf dry standard cubic feet
EIQEmission Inventory Questionnaire
EP Emission Point
EPA Environmental Protection Agency
EU Emission Unit
fps feet per second
ft feet
GACT Generally Available Control Technology
GHG Greenhouse Gas
gpm gallons per minute
gr grains
GWP Global Warming Potential
HAPHazardous Air Pollutant
hr hour
hp horsepower
lb pound
lbshr pounds per hour
MACT Maximum Achievable Control Technology
microgm3 bull micrograms per cubic meter
mis meters per second
Mgal 1000 gallons
MW megawatt
MHDR maximum hourly design rate
MMBtu Million British thermal units
MMCF million cubic feet
MSDS Material Safety Data Sheet
NAAQS National Ambient Air Quality Standards
NESHAPs National Emissions Standards for Hazardous Air Pollutants
NOx nitrogen oxides
NSPS New Source Performance Standards
NSR New Source Review
PM particulate matter
PM2s particulate matter less than 25 microns in aerodynamic diameter
PM10 particulate matter less than IO microns in aerodynamic diameter
ppm parts per million
PSD Prevention of Significant Deterioration
PTE potential to em it
RACT Reasonable Available Control Technology
RAL Risk Assessment Level
SCC Source Classification Code
scfm standard cubic feet per minute
SDS Safety Data Sheet
SIC Standard Industrial Classification
SIP State Implementation Plan
SMAL Screening Model Action Levels
SOx sulfur oxides
S02 sulfur dioxide
SSM Startup Shutdown amp Malfunction
tph tons per hour
tpy tons per year
VMT vehicle miles traveled
VOC Volatile Organic Compound
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Table 1 Emissions Summary (tons per year)
PoUutant Regulatory DeMinimis
Levels
Existing Potential
Emissions
Existing Actual
Emissions
Potential Emissions of the middotProject
Conditioned Potential
Emissions of the Project
PM 250 N0 N0 226 NA
PM10 150 N0 ND 226 NA
PM2s 100 N0 ND 226 NIA
SOx 400 N0 ND 014 NA
NOx 400 ND ND 3427 NA
voe 400 ND N0 192 NA
co 1000 ND ND 1439 NA
Total HAPS 250 ND ND 023 NA ND = Not Determined
PERMIT RULE APPLICABILITY
This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6060 Construction Permits Required Controlled potential emissions of all pollutants are below the de minimis levels
APPLICABLE REQUIREMENTS
ProEnergy Services shall comply with the following applicable requirements The Missouri Air Conservation Laws and Regulations should be consulted for specific record keeping monitoring and reporting requirements Compliance with these emission standards based on information submitted in the application has been verified at the time this application was approved
GENERAL REQUIREMENTS
bull Start-Up Shutdown and Malfunction Conditions 1 0 CSR 10-6050
bull Submission of Emission Data Emission Fees and Process Information 10 CSR 10-6110 Per 10 CSR 10-6110(4)(8)1 and (4)(8)2C(II) a full EIQ is required for the
first full calendar year the equipment is in operation
bull Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin 10 CSR 10-6170
bull Restriction of Emission of Visible Air Contaminants 10 CSR 10-6220
bull Restriction of Emission of Odors 1 0 CSR 10-6165
-7-
STAFF RECOMMENDATION
On the basis of this review conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 Construction Permits Required it is recommended that this permit be granted with special conditions
PERMIT DOCUMENTS
The following documents are incorporated by reference into this permit
bull The Application for Authority to Construct form dated October 16 2019 received October 17 2019 designating ProEnergy Services as the owner and operator of the installation
- 8 -
APPENDIX A Abbreviations and Acronyms
percent
degF degrees Fahrenheit
acfm actual cubic feet per minute
BACT Best Available Control Technology
BMPs Best Management Practices
Btu British thermal unit
CAM Compliance Assurance Monitoring
CAS Chemical Abstracts Service
CEMS Continuous Emission Monitor System
CFR Code of Federal Regulations
CO carbon monoxide
C02carbon dioxide
C02e carbon dioxide equivalent
COMS Continuous Opacity Monitoring System
CSR Code of State Regulations
dscf dry standard cubic feet
EIQEmission Inventory Questionnaire
EP Emission Point
EPA Environmental Protection Agency
EU Emission Unit
fps feet per second
ft feet
GACT Generally Available Control Technology
GHG Greenhouse Gas
gpm gallons per minute
gr grains
GWP Global Warming Potential
HAPHazardous Air Pollutant
hr hour
hp horsepower
lb pound
lbshr pounds per hour
MACT Maximum Achievable Control Technology
microgm3 bull micrograms per cubic meter
mis meters per second
Mgal 1000 gallons
MW megawatt
MHDR maximum hourly design rate
MMBtu Million British thermal units
MMCF million cubic feet
MSDS Material Safety Data Sheet
NAAQS National Ambient Air Quality Standards
NESHAPs National Emissions Standards for Hazardous Air Pollutants
NOx nitrogen oxides
NSPS New Source Performance Standards
NSR New Source Review
PM particulate matter
PM2s particulate matter less than 25 microns in aerodynamic diameter
PM10 particulate matter less than IO microns in aerodynamic diameter
ppm parts per million
PSD Prevention of Significant Deterioration
PTE potential to em it
RACT Reasonable Available Control Technology
RAL Risk Assessment Level
SCC Source Classification Code
scfm standard cubic feet per minute
SDS Safety Data Sheet
SIC Standard Industrial Classification
SIP State Implementation Plan
SMAL Screening Model Action Levels
SOx sulfur oxides
S02 sulfur dioxide
SSM Startup Shutdown amp Malfunction
tph tons per hour
tpy tons per year
VMT vehicle miles traveled
VOC Volatile Organic Compound
- 9 -
STAFF RECOMMENDATION
On the basis of this review conducted in accordance with Section (5) Missouri State Rule 10 CSR 10-6060 Construction Permits Required it is recommended that this permit be granted with special conditions
PERMIT DOCUMENTS
The following documents are incorporated by reference into this permit
bull The Application for Authority to Construct form dated October 16 2019 received October 17 2019 designating ProEnergy Services as the owner and operator of the installation
- 8 -
APPENDIX A Abbreviations and Acronyms
percent
degF degrees Fahrenheit
acfm actual cubic feet per minute
BACT Best Available Control Technology
BMPs Best Management Practices
Btu British thermal unit
CAM Compliance Assurance Monitoring
CAS Chemical Abstracts Service
CEMS Continuous Emission Monitor System
CFR Code of Federal Regulations
CO carbon monoxide
C02carbon dioxide
C02e carbon dioxide equivalent
COMS Continuous Opacity Monitoring System
CSR Code of State Regulations
dscf dry standard cubic feet
EIQEmission Inventory Questionnaire
EP Emission Point
EPA Environmental Protection Agency
EU Emission Unit
fps feet per second
ft feet
GACT Generally Available Control Technology
GHG Greenhouse Gas
gpm gallons per minute
gr grains
GWP Global Warming Potential
HAPHazardous Air Pollutant
hr hour
hp horsepower
lb pound
lbshr pounds per hour
MACT Maximum Achievable Control Technology
microgm3 bull micrograms per cubic meter
mis meters per second
Mgal 1000 gallons
MW megawatt
MHDR maximum hourly design rate
MMBtu Million British thermal units
MMCF million cubic feet
MSDS Material Safety Data Sheet
NAAQS National Ambient Air Quality Standards
NESHAPs National Emissions Standards for Hazardous Air Pollutants
NOx nitrogen oxides
NSPS New Source Performance Standards
NSR New Source Review
PM particulate matter
PM2s particulate matter less than 25 microns in aerodynamic diameter
PM10 particulate matter less than IO microns in aerodynamic diameter
ppm parts per million
PSD Prevention of Significant Deterioration
PTE potential to em it
RACT Reasonable Available Control Technology
RAL Risk Assessment Level
SCC Source Classification Code
scfm standard cubic feet per minute
SDS Safety Data Sheet
SIC Standard Industrial Classification
SIP State Implementation Plan
SMAL Screening Model Action Levels
SOx sulfur oxides
S02 sulfur dioxide
SSM Startup Shutdown amp Malfunction
tph tons per hour
tpy tons per year
VMT vehicle miles traveled
VOC Volatile Organic Compound
- 9 -
APPENDIX A Abbreviations and Acronyms
percent
degF degrees Fahrenheit
acfm actual cubic feet per minute
BACT Best Available Control Technology
BMPs Best Management Practices
Btu British thermal unit
CAM Compliance Assurance Monitoring
CAS Chemical Abstracts Service
CEMS Continuous Emission Monitor System
CFR Code of Federal Regulations
CO carbon monoxide
C02carbon dioxide
C02e carbon dioxide equivalent
COMS Continuous Opacity Monitoring System
CSR Code of State Regulations
dscf dry standard cubic feet
EIQEmission Inventory Questionnaire
EP Emission Point
EPA Environmental Protection Agency
EU Emission Unit
fps feet per second
ft feet
GACT Generally Available Control Technology
GHG Greenhouse Gas
gpm gallons per minute
gr grains
GWP Global Warming Potential
HAPHazardous Air Pollutant
hr hour
hp horsepower
lb pound
lbshr pounds per hour
MACT Maximum Achievable Control Technology
microgm3 bull micrograms per cubic meter
mis meters per second
Mgal 1000 gallons
MW megawatt
MHDR maximum hourly design rate
MMBtu Million British thermal units
MMCF million cubic feet
MSDS Material Safety Data Sheet
NAAQS National Ambient Air Quality Standards
NESHAPs National Emissions Standards for Hazardous Air Pollutants
NOx nitrogen oxides
NSPS New Source Performance Standards
NSR New Source Review
PM particulate matter
PM2s particulate matter less than 25 microns in aerodynamic diameter
PM10 particulate matter less than IO microns in aerodynamic diameter
ppm parts per million
PSD Prevention of Significant Deterioration
PTE potential to em it
RACT Reasonable Available Control Technology
RAL Risk Assessment Level
SCC Source Classification Code
scfm standard cubic feet per minute
SDS Safety Data Sheet
SIC Standard Industrial Classification
SIP State Implementation Plan
SMAL Screening Model Action Levels
SOx sulfur oxides
S02 sulfur dioxide
SSM Startup Shutdown amp Malfunction
tph tons per hour
tpy tons per year
VMT vehicle miles traveled
VOC Volatile Organic Compound
- 9 -