Natural Gas Combustion Turbine
Air Quality Permitting
The client desired to install a natural gas-fired combustion turbine with a heat recovery steam generator (HRSG) to provide onsite electricity for the Pennsylvania manufacturing facility. Because of the timing of the project just prior to implementation of the Prevention of Significant Deterioration (PSD) and Title V Greenhouse Gas (GHG) Tailoring Rule, the client was concerned for major delays in the permitting process. Of specific concern was the potential for unknown issues with regard to addressing the requirement to determine the Best Available Control Technology (BACT) for GHG emissions; an analysis for which there was no regulatory precedent. The client’s goal was to acquire the necessary Plan Approval and begin actual construction prior to the effective date of Step 2 of the Tailoring Rule.
ALL4’s approach was to establish an internal project team that could quickly and effectively compile and submit a complete Plan Approval Application within a very limited timeframe. This involved integrating with the client facility and corporate EHS personnel and engineers as well as the vendors who would be providing the turbine and associated pollution control equipment. ALL4 worked quickly with PADEP to lay the groundwork for permit review, and to make sure that state Best Available Technology (BAT) requirements were met. Subsequent to the submission of the Application, ALL4 worked closely with the PADEP regional personnel to provide all necessary information needed to shorten the review process. ALL4 also provided the necessary support to thoroughly and quickly answer questions from U.S. EPA during their review process. Finally, ALL4 guided the client through the process to ensure that the facility met the criteria for “begin actual construction” prior to the July 1, 2011 deadline.
Through ALL4’s expertise in major source air permitting issues, and through ALL4’s long-standing relationship with PADEP and U.S. EPA Region 3 air permitting personnel, we were able to turn around a complex air permitting project in a short timeframe. This allowed the client to meet their timeline goals, maximize the onsite production of electricity, and improve operational efficiency.