FGD and DeNOx
NEWSLETTER       

                                                                                                                    February  2002
                                                                                                                          No. 286

Air Permitting for New Coal-fired Plants

With air permitting being one of the critical path items for a new coal-fired power plant, it is imperative that this phase of the project be completed as quickly as possible. Some agencies have been flexible in their approach to allow permits to be issued quickly. The applicant needs to deal closely with the permitting agency to define the critical path items (typically monitoring and/or modeling) necessary for the construction permit to be issued. 

Block Andrews of Burns & McDonnell reports that obtaining a Prevention of Significant Deterioration (PSD) air permit could require from 9-18 months. A year of ambient air monitoring or meteorological data may be required for this permit. An applicant is also required to perform air dispersion modeling. The modeling must show that the proposed source will not cause or contribute to a violation of the National Ambient Air Quality Standards and PSD Class I and II increments.

A full BACT, or Lowest Achievable Emissions Rate (LEAR) in non-attainment areas, analysis will be required. In non-attainment areas offsets need to be provided.

Proximity to Class I areas (national parks or national forests/wilderness regions) is important also.  Construction near a Class I area would require performing a CALPUFF screen analysis. Depending on the results from this analysis, a full CALPUFF model may have to be run. The results of the modeling can impact the project in at least three ways. First, the new unit may be expected to meet emissions standards that are stricter than any existing emission standard. Second, if the emissions standard is too low to feasibly obtain, then an existing unit at an existing site may require additional controls as mitigation. Finally, the worst case scenario would be denial of the permit and the new boiler could not be installed. It is very unlikely that the new boiler permit will be denied if the site is located at a distance great enough from a Class I area.

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