General Information Session: Air Permitting and Proposed Coal-Fired Power Plants

1
Welcome

• General Information SessionAir Permitting and
  Proposed Coal-Fired Power Plants

2
Before we Begin

• Registration
• Handout
• Presentation materials available on website
• Questions
• Note Cards and Microphones
• Discussion Room
• Breaks and Restrooms

3
Vinson Hellwig

• Chief
• Air Quality Division

4
Todays Goals

• Provide information on MDEQ Air Quality
  Divisions responsibilities and role in
  permitting coal-fired power plants
• Listen to concerns and answer questions about
  permitting process

5
Agenda

• Overview Air Quality Division
• Overview of Air Permitting Process
• Human Health Risk Assessment
• Project Overviews
• General Question Session

6
Air Quality Division Overview

• Jim Ostrowski
• MDEQ, Environmental Assistance Program
• 517.241.8057 ostrowskij2_at_michigan.gov

7
Department of Environmental Quality
Air Quality Division
Office of Geological Survey
Environmental Science Services Division
Remediation Redevelopment Division
Land Water Management Division
Waste Hazardous Materials Division
Water Bureau
8
Air Quality Division Overview
Regulatory Authority
Clean Air Act Part 55, of the Natural Resources
and Environmental Protection Act Michigan Air
Pollution Control Rules
9
Air Quality Division Overview
Air Quality Division
Field Operations
Enforcement
Evaluation
Permits
Toxics Air Monitoring Rule Implementation
Evaluate Permit Applications
Conduct Inspections Determine Compliance
10
Air Quality Division Overview

• What is Reviewed When Making a Permit Decision?
• Conduct Technical Review of Application
• Proposed Emissions
• Proposed Control Technology
• Impacts to Public Health Environment

Identified in Fed and state air rules
11
Air Quality Division Overview

• What is NOT Reviewed When Making a Permit
  Decision?
• Zoning Restrictions
• Site Selection
• Traffic Patterns (except dust)
• Light
• Noise
• Consumer Demand/Product Need
• Carbon Dioxide (CO2) Emissions

12
Air Quality Division Overview

• MDEQ has the authority to regulate
• Pollutants with established National Ambient Air
  Quality Standard (NAAQS)
• CO, NOx, SO2, PM, Lead, Ozone (VOC)
• Hazardous Air Pollutants
• 187 pollutants
• Toxic Air Contaminants
• As defined by rule

13
Air Quality Division Overview

• Michigan Climate Action Council
• Created under Executive Order
• Provide Inventory CO2 and other greenhouse gas
  (GHG) emissions
• Identifying policies/strategies Michigan should
  adopt to reduce CO2 and other GHG emissions

www.miclimatechange.us
14
Air Quality Division Overview

• Permit to Install operates as contract
• Contains emission and material limits, operation
  and design restrictions
• Contains monitoring/recordkeeping, testing
  sampling, and reporting requirements
• Allows facility to begin construction or
  installation
• Major sources must also obtain a Renewable
  Operating Permit

15
Air Quality Division Overview
Air Permit

• Source Duties
• Comply with conditions
• Monitor emissions
• Maintain records
• Submit reports
• Apply for new or modified permit if certain
  changes are made

• AQD Duties
• Monitor stack testing
• Conduct inspections
• Review emission reports
• Review compliance certifications
• Certify monitoring systems
• Respond to complaints

16
Air Quality Division Overview

• AQD operates within strict framework of what is
  allowed by law
• Procedures for review of permit application
• Operate openly and transparently
• Opportunities for public comment
• Staff available for questions

17
Air Permitting Process

• Mary Ann Dolehanty
• AQD Permit Section
• 517.373.2098
• dolehantym_at_michigan.gov

18
Rule 201 Permits to Install

• A person shall not install, construct,
  reconstruct, relocate, alter, or modify any
  process or process equipment ... which may emit
  an air contaminant, unless a permit to install
  which authorizes such action is issued by the
  Department

19
Two Types

• Permit To Install (PTI)
• Required Prior to the Construction of a New
  Source or a Modification to an Existing Source.
• Renewable Operating Permit (ROP)
• Required for Major Sources. Incorporates all
  Applicable Requirements at Facility (PTIs and
  State/Federal Rules) Includes Enhanced
  Monitoring, Recordkeeping, Reporting

20
Categories of Permits to Install

• Minor Source
• Proposed emissions below defined thresholds
• Examples Auto Parts Suppliers , crematories,
  etc.
• Major Source
• Large emitting sources that emit above certain
  defined thresholds
• Example Auto Assembly Plants Power Plants

21
Process Steps
Administrative Technical Completeness Check
Technical Review
Development of Draft Permit Conditions
Public Participation Process
Permit Decision
22
Administrative Technical Completeness Check

• What is a complete application?
• Assure the application is both administratively
  and technically complete
• All information needed to begin the review

23
Process Steps
Administrative Technical Completeness Check
Technical Review
Development of Draft Permit Conditions
Public Participation Process
Permit Decision
24
Technical Review

• Type, size and location of source
• Emission calculations/proposed emissions
• Applicable state and federal requirements

25
Technical Review (cont)

• Control Technology review
• BACT (Best Available Control Technology)
• MACT (Maximum Achievable Control Technology)
• TBACT (Best Available Control Technology for
  Toxics)

26
Technical Review (cont)

• Ambient Impact Analysis/Modeling
• Compare impacts of proposed emissions to
  established federal standards (NAAQS) and state
  health based criteria (TACs)

27
Process Steps
Administrative Technical Completeness Check
Technical Review
Development of Draft Permit Conditions
Public Participation Process
Permit Decision
28
Development of Draft Permit Conditions

• AQD Coordination and Agreement on Draft
  Conditions
• Applicant Input on Draft Conditions
• Assurance that all Requirements Met

29
Process Steps
Administrative Technical Completeness Check
Technical Review
Development of Draft Permit Conditions
Public Participation Process
Permit Decision
30
Public Participation Process

• Required by Federal Permitting Rules for major
  sources
• Fact Sheet with Draft Conditions
• 30 Day Public Comment Period
• Public Hearing
• Public notice of comment period/hearing
• Local newspapers, AQD website, Direct mailing
• Notification of EPA, Local Government
  Interested Parties

31
Public Participation Process

• Enhanced Public Participation Process
• Website Posting of Applications and related
  information
• General Information Session
• Public notice of comment period/hearing
• Local newspapers, AQD website, direct mailing,
  press release, public service announcements,
  re-Noticing
• 60 Day Public Comment Period
• Site Specific Information Meetings
• Multiple Public Hearing Times
• Public Comment will be accepted via email

32
Process Steps
Administrative Technical Completeness Check
Technical Review
Development of Draft Permit Conditions
Public Participation Process
Permit Decision
33
Permit Decision

• Decision-making Process
• Review of comments received
• Re-evaluation of application
• May Need Additional Information or Review
• Response to comments document

34
Permit Decision

• Three Possible Outcomes
• Approval
• Approval with Modifications
• Denial
• Notification of Final Decision
• Letters to Interested Parties, EPA, Local
  Government

35
Process Steps
Administrative Technical Completeness Check
Technical Review
Development of Draft Permit Conditions
Public Participation Process
Permit Decision
36
Human Health Risk Assessments for Power Plant
Proposals in Michigan

• Robert Sills
• Toxicologist Specialist
• Michigan Dept. of Environmental Quality
• Air Quality Division
• 517-335-6973
• sillsr_at_michigan.gov
• June 25, 2008

37
Toxicology and Risk Assessment

• Toxicology is the study of harmful effects of
  exposure to substances.
• Risk assessment is the estimation of potential
  adverse health effects from exposure to
  substances. This includes evaluating hazards,
  exposures, and potency, and characterizing the
  potential risk of health effects.

38
Overview of air toxics risk assessment for power
plants

• This talk will briefly cover
• Types of air contaminants
• Cancer and noncancer risks
• Screening levels for inhalation exposure
• Mercury and lead oral exposure
• Cumulative impacts of inhalation exposure to
  complex mixtures

39
Air contaminants regulated

• Criteria pollutants ozone, lead, carbon
  monoxide, sulfur dioxide, nitrogen dioxide,
  particulate matter
• Toxic air contaminants (air toxics)
  non-criteria pollutants, which could be harmful
  at some level in the air.

40
Regulatory standards and criteria to ensure
public health protection

• Criteria pollutants EPA has established National
  Ambient Air Quality Standards which are designed
  to protect the public health.
• Air toxics AQD has developed screening levels
  that are designed to be protective of the public
  health.

41
AQD Screening Levels are

• Air concentrations of substances that are
  protective of the public health
• based on the available toxicity information
• protective for inhalation exposure, for all
  people (including sensitive groups), for a
  lifetime of exposure
• protective for noncancer and cancer effects

42
Noncancer risk

• Includes all types of harmful effects other than
  cancer.
• Irritation, organ toxicity, reproduction and
  development effects, neurological effects, etc.
• There is assumed to be a safe exposure level
  below a threshold for effects.
• Screening levels are designed to be protective,
  taking into account uncertainties.

43
Cancer risk

• Carcinogens are substances that have been shown
  in human or animal studies to increase the
  development of tumors.
• Carcinogens include benzene, dioxins, arsenic,
  etc.
• Carcinogens are assumed to pose some level of
  risk at any air concentration.
• Screening levels are set at a level of protection
  of 1 in 1 million risk or 1 in 100,000 risk, for
  a lifetime of exposure.

44
How screening levels are applied in regulating
air emission sources

• Anticipated emission rates of air toxics are
  determined.
• Computer modeling accounts for the emission
  source characteristics, emission rate, and
  meteorology information, to model the dispersion
  of air toxics.
• The model estimates the impacts to the ambient
  air (the outdoor air that people may breathe).
• The ambient air impacts cannot exceed the
  screening levels.

45
Deposition and oral exposure

• Some air pollutants can deposit out of the air
  and pose concerns for oral exposure.
• Mercury and lead can raise this concern more than
  other substances.

46
Mercury and lead concerns

• Both can pose a risk of affecting neurological
  development in children, among other effects.
• Methylmercury has a very high tendency to
  accumulate in fish tissue, resulting in exposure
  for people eating fish, and fish consumption
  advisories.
• Lead can accumulate in soil and dust it is
  already a public health problem in some areas,
  primarily due to the historical use of lead paint.

47
Assessment of power plant mercury emissions

• For each of the proposed power plants, the local
  mercury deposition is modeled.
• Local water bodies are the focus, because
  relatively more deposition impact is close to the
  source.
• Models account for the environmental fate of
  mercury in the local watersheds.
• 30-year accumulation in fish is estimated.

48
Assessment of power plant mercury emissions,
contd

• People are assumed to eat fish mercury exposure
  and risk are estimated.
• Impacts should be considered in the context of
  background levels, which may already be elevated.

49
Assessment of power plant lead emissions

• Although lead is a criteria pollutant, not an air
  toxic, a detailed assessment is warranted.
• Lead air emissions can deposit and accumulate in
  topsoil, and can affect house dust levels.
• Lead air emissions are modeled for dispersion and
  deposition.

50
Assessment of power plant lead emissions, contd

• Childrens total lead background exposure from
  air, soil, dust, food, and drinking water is
  estimated.
• The facility calculated impact is added, after 30
  years at the point of maximum impact.
• Childrens exposure is estimated, both with and
  without the added impact of the facility.

51
Assessment of power plant mercury and lead
emissions

• The results will be available for public review
  and comment for each power plant, and the results
  will be summarized for the public.
• The permit decision-maker will determine the
  approvability of the facility emissions and
  estimated impacts.

52
Cumulative risk assessment

• Cumulative risk assessment attempts to account
  for the concern that emissions (and exposures)
  involve complex mixtures, and most screening
  levels are only chemical-specific.
• Some air toxics may share a common health effect,
  and can have interactive effects.
• Very limited information is available on
  cumulative effects. Additive risk may be
  assumed.
• The results for each power plant will be
  summarized for the public and decision-maker to
  consider.

53
Summary of human health risk assessments for
power plants

• Criteria pollutants have standards which are
  designed to be health protective.
• AQD applies screening levels for air toxics to
  protect for inhalation exposures.
• Deposition and oral exposure are assessed for
  mercury and lead.
• Cumulative risk assessment involves evaluation of
  complex mixtures.
• Findings will help ensure that the permit
  conditions will be safe for the public health.

54
Project Overviews and Status Report
55
Consumers Energy Essexville, Michigan
56
Physical Location
57
(No Transcript)
58
Consumers Energy Power Plant Description

• Existing Karn-Weadock Station
• - 2,101 Megawatts current capacity
• New Plant will generate 930 Megawatts of
  electricity.
• Enough electricity to power 650,000 homes.

59
Consumers Energy Plant Description

• Coal fired boiler
• Fuels proposed to be combusted
• Western sub-bituminous coal (primary fuel) up
  to 50 eastern bituminous
• The technology proposed is a Advanced super
  critical pulverized coal boiler
• Continuous Monitoring
• SO2, CO, NOx, Mercury, PM or Opacity

60
Consumers Energy Plant Description
Environmental Controls and Performance

• Particulate matter
• Fabric Filter control, 99 to 99.9 reduction
• Lead and other metals controlled
• Sulfur oxides
• Wet FGD, 95 to 98 reduction also, hydrated
  lime injection for acid gases 43 control
• Nitrogen Oxides
• Low NOx burners, over fire air, selective
  catalytic reduction, up to 97 reduction

61
Consumers Energy Plant Description
Environmental Controls and Performance

• Carbon Monoxide
• Efficient Combustion design and operation
• Volatile Organic Compounds
• Efficient Combustion design and operation
• Mercury
• Activated carbon injection benefit of other
  controls, greater than 90 reduction

62
(No Transcript)
63
Wolverine Power Supply Cooperative, Inc. Rogers
City, Michigan
64
(No Transcript)
65
(No Transcript)
66
Wolverine Power Co-Op Plant Description

• Plant will generate 600 Megawatts of electricity.
• Enough electricity to power 423,000 homes.
• (Based upon gross generating capacity, 90
  capacity factor, and an average monthly
  residential consumption of 920 kWh)

67
Wolverine Power Co-Op Plant Description

• 2 solid fuel fired boilers
• The technology proposed is a Circulating
  fluidized bed boiler
• Fuels proposed to be combusted
• Coal (primary fuel)
• Biomass
• Petroleum coke
• Continuous Monitoring
• SO2, CO, NOx, Mercury, Opacity

68
Wolverine Power Co-Op Plant Description
Environmental Controls and Performance

• Particulate matter
• Fabric Filter control, 99 reduction
• Lead and other metals controlled
• Sulfur oxides
• Limestone Injection plus Polishing Scrubber
  (Spray Dryer Absorber, SDA), 95 reduction
• Nitrogen Oxides
• CFB Technology plus Selective Non-Catalytic
  Reduction, 90 reduction

69
Wolverine Power Co-Op Plant Description
Environmental Controls and Performance

• Carbon Monoxide
• Efficient combustion and operation
• Volatile Organic Compounds
• Efficient combustion and operation
• Mercury
• Activated carbon injection benefit of other
  controls, greater than 90 reduction

70
Insert process diagram
71
Mid-Michigan Energy, LLC Midland, Michigan
72
(No Transcript)
73
(No Transcript)
74
Mid-Michigan Energy, LLC Plant Description

• Plant will generate 750 Megawatts of electricity.
• Enough electricity to power 530,000 homes.
• (Based upon gross generating capacity, 90
  capacity factor, and an average monthly
  residential consumption of 920 kWh)

75
Mid-Michigan Energy, LLC Plant Description

• Power Generation and steam production Facility
• The technology proposed is a Super critical
  pulverized coal boiler or Ultra super critical
  pulverized coal boiler
• Fuels proposed to be combusted
• Coal (primary fuel)
• Biomass
• Natural Gas (start up)
• Continuous Monitoring
• SO2, CO, NOx, Mercury, Opacity

76
Mid-Michigan Energy, LLC Plant Description
Environmental Controls and Performance

• Particulate matter
• Fabric filter control, 99 reduction
• Lead and other metals controlled
• Sulfur oxides
• Dry scrubber (flue gas desulfurization) 94
  reduction
• Nitrogen Oxides
• Low NOx burners, over fire air, selective
  catalytic reduction, 90 reduction

77
Mid-Michigan Energy, LLC Plant Description
Environmental Controls and Performance

• Carbon Monoxide
• Efficient Combustion and Design and operation
• Volatile Organic Compounds
• Efficient Combustion and Design and operation
• Mercury
• Activated carbon injection benefit of other
  controls, greater than 90 reduction

78
(No Transcript)
79
Holland Board of Public Works Holland, Michigan
80
Physical Location
81

• Detailed Location Map
• 64 Pine Avenue, Holland, Michigan

82
Holland Board of Public Works Plant Description

• Plant will generate 78 Megawatts of electricity.
• Enough electricity to power 55,000 homes.

83
Holland Board of Public Works Plant Description

• Coal fired boiler
• New unit is replacing an existing smaller
  capacity coal fired boiler
• The technology proposed is a Circulating
  Fluidized Boiler
• Fuels proposed to be combusted
• Coal (primary fuel)
• Sewage sludge, wood waste, petroleum coke, tire
  derived fuel
• Continuous Monitoring
• SO2, CO, NOx, Opacity

84
Holland Board of Public Works Plant Description
Environmental Controls and Performance

• Particulate matter
• Fabric filter control, 99.9 reduction
• Lead and other metals controlled
• Sulfur oxides
• Lime Injection, 98 reduction
• Nitrogen Oxides
• SNCR, 90 reduction

85
Holland Board of Public Works Plant Description
Environmental Controls and Performance

• Carbon Monoxide
• Efficient Combustion and Design and operation
• Volatile Organic Compounds
• Efficient Combustion and Design and operation
• Mercury
• Activated carbon injection benefit of other
  controls, greater than 90 reduction

86
(No Transcript)
87
Summary

• On going permit application process
• No decision has been made
• Public Hearings for each project
• Note cards
• Question and answers after break

88
PanelQuestion and Answer Session