Project Overview
NTH assisted Lansing Board of Water & Light (BWL) and its Engineer in securing an air permit for the installation and operation of a new reciprocating internal combustion engine plant (“RICE Plant”) consisting of up to six (6) large natural gas-fired RICE to provided approximately 110 Megawatts (MW) to its customers. The RICE plant is designed and permitted to be able to respond quickly to changes in demand and provide capacity to support the load requirements of BWL’s growing customer based. The RICE will utilize lean burn technology and selective catalytic reduction (SCR) to reduce oxides of nitrogen (NOx) emissions, as well as oxidation catalysts to reduce carbon monoxide (CO) and volatile organic compounds (VOCs).
Project Scope
NTH met with BWL and its Engineer in early 2023 to discuss air permitting requirements for an emergent and critical project to support a large influx of demand to its customer base. NTH provided various analyses including a review of “netting” for the project to identify project feasibility and PSD strategies.
The project was considered to be a major modification at an existing major stationary source in accordance with the Prevention of Significant Deterioration (PSD) regulations as it resulted in a significant emissions increase in NOx, CO, VOC, particulate matter less than or equal to 10 micrometers (PM10), and PM less than 2.5 micrometers (PM2.5).The project required an extensive ambient impact analysis utilizing dispersion modeling and was also subject to best available control technology (BACT) requirements for emissions of greenhouse gases (GHG). NTH developed potential emission estimates based on worst-case vendor data, including startup and shutdown emissions. The permit application also included a detailed review of applicable state and federal air quality regulations, and an extensive air pollution control technology evaluation for NOx, CO, VOC, PM, PM10, PM2.5, and GHG.
NTH’s comprehensive ambient impact analysis using dispersion modeling techniques was used to determine concentrations of regulated air contaminants for comparison to the national ambient air quality standards (NAAQS), PSD Class II increments, and toxic air containment screening levels per Michigan Air Toxics Rules. The analysis also incorporated impacts from the Delta Energy Park (NGCC) and remaining Erickson Station equipment. NTH also developed an additional impact analysis and an assessment for secondary formation of PM2.5 and ozone emissions utilizing U.S. Environmental Protection Agency’s (EPA’s) recently published Guidance on the Development of MERPs as a Tier 1 Demonstration Tool for Ozone and PM2.5 under the PSD Permitting Program. Our analyses were approved by Michigan Department of Environment, Great Lakes, and Energy (EGLE) and U.S. EPA.
NTH worked closely with EGLE during the permit review process to ensure the project was moving forward, including discussing draft permit conditions during various meetings and conference calls. EGLE did not require additional information throughout their review. The application included potential equipment that could be installed, to avoid future re-permitting (i.e., PSD “re-review”) should that ancillary equipment be determined necessary upon final engineering.
Client Benefit
NTH evaluated RBLC to identify similar project BACT limits; however, negotiated with EGLE to demonstrate that the proposed (higher) BACT limits were acceptable because they covered the full range of operations, including ramping up and down in load to meet demand fluctuations. Additionally, NTH’s expertise yielded faster overall timeframe for air permitting to allow BWL to respond to a rapid change in customer base (demand) and meet critical project construction timelines.
