CONSTRUCT / RECONSTRUCT / MODIFY AN AIR CONTAMINANT SOURCE
Lincoln-Lancaster County Health Department
Judith A. Halstead, MSHealth Director Environmental Public Health Division
Scott E. Holmes, REHS, MS Air Quality Program
Environmental Public Health
3140 N Street Division Manager
Lincoln, Nebraska 68510
Chris Schroeder, MCRP Phone: (402) 441-8040 Fax: (402) 441-3890 Air Quality Program Supervisor
LLCHD Air Quality Program Source Number: 00005
LLCHD Air Quality Program Construction Permit Number: 158
Permit Issuance Date: May XX, 2013
The Lincoln-Lancaster County Health Department (LLCHD) has made the preliminary
determination to issue a permit to construct/reconstruct/modify to the following source:
Permit Holder Name: Nebraska Public Power District (NPPD)
Address: 1414 15th Street
City, County, State, ZIP: Columbus, Platte County, Nebraska 68602
The proposed permit allows for operation of the following source:
Facility Site Name: NPPD Sheldon Station
Facility Address: 4500 West Pella Road
City, County, State, ZIP: Hallam, Lancaster County, Nebraska 68368
Facility NAICS: 221112: Electric Power Generation, Fossil Fuel
In accordance with requirements set forth under Article 2, Section 14 of the Lincoln-Lancaster County Air Pollution Control Program Regulations and Standards (LLCAPCPRS), the LLCHD may not issue a construction permit until the public has been given the opportunity to comment on the draft permit.
Within the 30-day public comment period, any interested person, agency, group, or affected state may request or petition the Director of the LLCHD for a public hearing. All requests for public hearing must be made in writing, and must state the nature of the issues to be raised and all arguments and factual
Table of Contents
Section 1 – Introduction ... 3
Section 2 – Proposed Construction/Reconstruction/Modification ... 3
Section 3 – Source Characterization ... 4
Section 4 – Emission Characterization ... 7
Section 5 – Applicable and Non-Applicable Regulations & Requirements ... 9
Section 6 – Construction Permit Application Approval ... 10
Section 7 – Best Available Control Technology (BACT) Analysis ... 10
Section 8 – Air Dispersion Modeling Analysis ... 10
Section 9 – Discussion of Proposed Permit Conditions, Monitoring, Reporting,
Notification and Record Keeping Requirements ... 10
Section 10 – Summary of Permit Conditions Enforceable by Agency... 12
Section 11 – Pollution Prevention Opportunities ... 12
Section 12 – Air Quality Program Recommendation... 12
Section 1 – Introduction
The Nebraska Public Power District (referred to hereinafter as “NPPD”) Sheldon Station is a fossil fuel fired steam electric plant located at 4500 W. Pella Road, Hallam, Nebraska. This facility has a potential to emit (PTE) several criteria pollutants at levels that are greater than major source thresholds.
Article 2, Section 17, paragraph (A) of the LLCAPCPRS requires that sources of air pollutants apply for permits if construction, reconstruction, or modification of a facility results in pollutant emission increases that meet or exceed the thresholds set forth under Article 2, Section 17 paragraph (A)(1) of the LLCAPCPRS. Article 2, Section 19 of the LLCAPCPRS requires that sources that are major sources for the purposes of Prevention of Significant Deterioration (PSD) of air quality apply Best Available Control Technology (BACT) to major modifications.
NPPD Sheldon Station currently operates as a major source for the purposes of PSD, and as a result, must apply BACT for all major modifications at the facility.
Section 2 – Proposed Construction/Reconstruction/Modification
NPPD has submitted an application to obtain a construction permit to install an ‘over-fire-air’ (OFA) system on Sheldon Station Unit #1 (referred to in permit as ‘Emission Unit 1’ or ‘EU-1’). This modification is being performed in an effort to reduce emissions of nitrogen oxides (NOx), though doing so will result in increased emissions of carbon monoxide (CO).
This document serves as the factual and legal basis for the proposed issuance of a construction permit to NPPD. The sections that follow provide more information on the source, the nature of emissions from the source, evaluation of the potential to emit, and a discussion of conditions set forth in the draft permit.
Section 3 – Source Characterization 3.1 – Source Description
The Nebraska Public Power District (NPPD) Sheldon Station, located at 4500 West Pella Road, Hallam, Nebraska is an electricity generating station. The emission units associated with this facility are provided in Section 3.2, below.
3.2 – Existing Sources of Air Pollution
The NPPD Sheldon Station consists of the following emission units:
Emission Unit SCC Code Emission Point Description Emission Segment
Description 2‐1 1‐01‐002‐23 Unit #2 – External Combustion Boiler and Associated
Equipment Coal
2‐2 1‐01‐006‐01 Unit #2 – External Combustion Boiler and Associated
Equipment Natural Gas
2‐3 N/A Unit #2 – External Combustion Boiler and Associated
Equipment Coal/TDF/Scrap Rubber
3‐1 2‐01‐002‐01 Unit #3 – Combustion Turbine A and Associated
Equipment Natural Gas
3‐2 2‐01‐001‐01 Unit #3 – Combustion Turbine A and Associated
Equipment Fuel Oil
4‐1 2‐01‐002‐01 Unit #4 – Combustion Turbine B and Associated
Equipment Natural Gas
4‐2 2‐01‐001‐01 Unit #4 – Combustion Turbine B and Associated
Equipment Fuel Oil
11‐1 3‐05‐010‐08 Track Hopper Building Coal Unloading
12‐1 3‐05‐010‐11 Track Hopper to Belt Conveyor #1 Coal Transfer 13‐1 3‐05‐010‐11 Belt Conveyor #1 to Belt Conveyor #2 Coal Transfer 14‐1 3‐05‐010‐11 Belt Conveyor #2 to Active Coal Pile Coal Transfer 14a‐1 3‐05‐010‐11 Low‐BTU Coal Pile to Reclaim Hoppers #1‐4 Coal Transfer 15‐1 3‐05‐010‐11 Reclaim Hoppers #1‐4 to Belt Conveyor #3 Coal Transfer 16‐1 3‐05‐010‐11 High BTU Coal Pile to Reclaim Hopper #5 Coal Transfer 17‐1 3‐05‐010‐11 Reclaim Hopper #5 to Belt Conveyor #6 Coal Transfer 18‐1 3‐05‐010‐11 Belt Conveyor #6 to Crusher House Coal Transfer 19‐1 3‐05‐010‐11 Belt Conveyor #3 to Crusher House Coal Transfer
20‐1 3‐05‐010‐10 Crusher House Coal Crushing
21‐1 3‐05‐010‐11 Crusher House to Belt Conveyor #4 Coal Transfer 22‐1 3‐05‐010‐11 Belt Conveyor #4 to Belt Conveyor #5 Coal Transfer 23‐1 3‐05‐010‐11 Belt Conveyor #5 to Boiler #1 Coal Silos Coal Transfer 24‐1 3‐05‐010‐11 Belt Conveyor #5 to Boiler #2 Coal Silos Coal Transfer 25‐1 3‐05‐101‐99 Fuel Additives Silo – Load/Unload Fuel Additive Transfer
26‐1 3‐05‐101‐99 Lime Silo – Loading Lime Transfer
27‐1 3‐05‐101‐99 Fly Ash from Boilers to Silo
Emission Unit SCC Code Emission Point Description Emission Segment
Description 27 a‐1 3‐05‐101‐99 Fly Ash Handling Vacuum Pump Exhaust Fly Ash Transfer 27 b‐1 3‐05‐101‐99 Fly Ash Handling Vacuum Pump Exhaust Fly Ash Transfer 27 c‐1 3‐05‐101‐99 Fly Ash Handling Vacuum Pump Exhaust Fly Ash Transfer 28‐1 3‐05‐101‐99 Fly Ash from Silo & Precipitator to Truck Fly Ash Transfer 29‐1 3‐05‐101‐99 Fly/Bottom Ash from Truck to Ash Landfill Fly/Bottom Ash Transfer
30‐1 3‐05‐010‐43 Coal Storage Pile – Live Coal Storage
31‐1 3‐05‐010‐43 Coal Storage Pile – Standby Coal Storage
32‐1 3‐05‐010‐43 Ash Landfill Bottom Ash
33‐1 3‐05‐020‐11 Haul Roads – Unpaved Roadway Traffic
34‐1 3‐05‐020‐11 Haul Roads – Paved Roadway Traffic
43‐1 3‐85‐001‐01 Cooling Tower #1 Cooling Tower
44‐1 3‐85‐001‐01 Cooling Tower #2 Cooling Tower
45‐1 N/A Unit 1 Slag Tank Tank Vent
46‐1 2‐02‐003‐01 Honda GX 240 (Air Compressor) in Emergency
Generator Building Gasoline
47‐1 2‐02‐001‐02 Emergency Generator (4.55 MMBtu/hr) Diesel
48‐1 2‐02‐001‐02 Fire Pump 1 (0.96 MMBtu/hr) Diesel
49‐1 2‐02‐001‐02 Fire Pump 1 (0.96 MMBtu/hr) Diesel
3.3 – New/Modified/Reconstructed Sources of Air Pollution
This permit allows the owner/operator to construct/reconstruct/modify Sheldon Station Unit #1. This unit consists of the following:
Emission Unit SCC Code Emission Point Description Emission Segment
Description 1‐1 1‐01‐002‐23 Unit #1 – External Combustion Boiler
and Associated Equipment Coal
1‐2 1‐01‐006‐01 Unit #1 – External Combustion Boiler
3.4 – Source Aerial View
Section 4 – Emission Characterization
The procedures for performing pre- and post-modification carbon monoxide emission calculations are provided in the construction permit application, and are also shown below.
4.2 – Maximum Potential to Emit – Permit Threshold Evaluation
The following table summarizes the increase in potential to emit, and compares it to applicable construction permit and PSD permit thresholds:
Criteria Pollutant Emissions
(tpy)
Construction Permit
Threshold Meet or Exceed?
PSD Construction Permit
Threshold Meet or Exceed?
PM10 0 ≥ 15 tpy No ≥ 15 tpy No PM2.5 0 ≥ 10 tpy No ≥ 10 tpy No NOx 0 ≥ 40 tpy No ≥ 40 tpy No SOx 0 ≥ 40 tpy No ≥ 40 tpy No VOC 0 ≥ 40 tpy No ≥ 40 tpy No CO 7,467 ≥
50 tpy Yes ≥ 100 tpy Yes
Lead 0
≥
0.6 tpy No
≥
5 tpy No
CO2e 0 N/A N/A 75,000 tpy No
Hazardous Air Pollutant Emissions
(tpy)
Construction Permit &
T‐BACT Threshold Meet or Exceed?
Major Source
Threshold Meet or Exceed?
Greatest Single HAP 0
≥
2.5 tpy No
≥
10.0 tpy No
Total Combined HAPs 0
≥
10.0 tpy No
≥
25.0 tpy No
4.3 – Permit Threshold Evaluation
As reflected in the table in Section 4.2, the increased potential to emit from this proposed modification is in excess of PSD permitting thresholds, and the proposed modification will be subject to PSD permitting requirements.
Section 5 – Applicable and Non-Applicable Regulations & Requirements 5.1 – Applicable Regulations under the LLCAPCPRS
(A) The following Lincoln-Lancaster County Air Pollution Control Program Regulations and Standards (LLCAPCPRS) are applicable requirements of this construction permit:
(1) Article 1, Section 1: Intent
(2) Article 1, Section 2: Unlawful Acts – Permits Required (3) Article 1, Section 3: Violations – Hearings – Orders (4) Article 1, Section 4: Appeal Procedure
(5) Article 1, Section 5: Variance (6) Article 1, Section 6: Annual Fees
(7) Article 1, Section 7: Compliance – Actions to Enforce – Penalties for Non-Compliance
(8) Article 1, Section 8: Procedure for Abatement (9) Article 1, Section 9: Severability
(10) Article 2, Section 1: Definitions
(11) Article 2, Section 2: Major Sources Defined
(12) Article 2, Section 4: Ambient Air Quality Standards
(13) Article 2, Section 6: Emissions Reporting – When Required (14) Article 2, Section 14: Permits – Public Participation
(15) Article 2, Section 16: Stack Heights – Good Engineering Practice (GEP) (16) Article 2, Section 17: Construction Permits – When Required
(17) Article 2, Section 18: New Source Performance Standards (NSPS)
(18) Article 2, Section 19: Prevention of Significant Deterioration (PSD) of Air Quality (19) Article 2, Section 20: Particulate Emissions – Limitations and Standards
(20) Article 2, Section 23: Hazardous Air Pollutants – Emission Standards
(21) Article 2, Section 24: Sulfur Compound Emissions – Existing Sources – Emission Standards
(22) Article 2, Section 26: Acid Rain
(23) Article 2, Section 28: Hazardous Air Pollutants – MACT Emission Standards (24) Article 2, Section 30: Construction Permit Fee
(25) Article 2, Section 32: Dust – Duty to Prevent Escape of (26) Article 2, Section 33: Compliance – Time Schedule For
(27) Article 2, Section 34: Emission Sources – Testing – Monitoring
(28) Article 2, Section 35: Compliance – Exceptions Due to Startup Shutdown or Malfunction
(29) Article 2, Section 36: Control Regulations – Circumvention – When Excepted (30) Article 2, Section 37: Compliance – Responsibility of Owner/Operator Pending
Review by Director
(31) Article 2, Section 38: Emergency Episodes – Occurrence and Control – Contingency Plans
(32) Appendix I: Emergency Emission Reduction Regulations (33) Appendix II: Hazardous Air Pollutants
(34) Appendix III: Reporting Levels of Hazardous Air Pollutants for Emission Inventory
5.2 – Applicable Regulations under the Lincoln Municipal Code
5.3 – Applicable Federal Regulations
(C) The following Federal Regulations, including those not currently delegated to the Lancaster County Health Department (LLCHD) or not yet included in the Lincoln-Lancaster County Air Pollution Control Program Regulations and Standards (LLCAPCPRS), apply to this source:
(1) New Source Performance Standards at 40 CFR Part 60: (a) Subpart A: General Provisions
Section 6 – Construction Permit Application Approval
The Department has reviewed the construction permit application, signed February 21, 2013, and has found that the application is complete. As a result, the Department has approved the permit application.
Section 7 – Best Available Control Technology (BACT) Analysis
The Department has reviewed the BACT Analysis submitted with the construction permit application, and agrees with the applicant’s proposal to utilize good combustion practices as BACT for carbon monoxide (CO). The Department further agrees that oxidation catalysts, while effective at reducing carbon monoxide, are not technically feasible controls for a boiler like Sheldon Station Unit 1. The Department has incorporated the proposed BACT emission limit for carbon monoxide into the draft permit. This emission limit can be found in Condition XXXI(B)(1).
Section 8 – Air Dispersion Modeling Analysis
The Department has reviewed air dispersion modeling analysis submitted with the construction permit application, and has not identified any issues with the modeling procedures, parameters, or results. As such, the Department accepts the modeling results, and agrees that the proposed modification will not result in a significant impact on the ambient air, soils, and vegetation, and will not result in any significant additional air pollution from incremental growth.
Section 9 – Discussion of Proposed Permit Conditions, Monitoring, Reporting, Notification and Record Keeping Requirements
The following conditions of the proposed permit contain monitoring, reporting, and record keeping requirements, a brief description of the condition is provided:
9.1 – General Conditions
Conditions II through XXXIX are general conditions that are applicable to all Class I sources. There will not be an in-depth discussion of these requirements, except to note the following General Conditions specifically related to monitoring, reporting, notification, and record-keeping:
VII – Fees
XIV – Annual Emission Reporting XXII – ‘Credible Evidence Rule’
XXIII – Startup, Shutdown, and Malfunction (SSM) Provisions XXVIII – Notification of Anticipated and Actual Start-Up
9.2 – Specific Conditions
The following are specific conditions of the proposed construction permit:
XXXI – These conditions apply to emission unit 1 (Sheldon Station Unit 1, also referred to as EU-1).
(A)(1) – This condition serves provide an enforceable requirement to operate the boiler combustion controls, which are established as Best Available Control Technology (BACT).
(B)(1) – The emission limit set forth under this condition is established pursuant to the Prevention of Significant Deterioration (PSD) of air quality requirements.
(B)(2)-(3) – These condition serve to reference particulate and sulfur oxide emission limits set forth under Conditions XVIII and XIX of the proposed permit, respectively.
(C)(1) – This condition serves to identify the test methods and procedures to be used for performing Relative Accuracy Test Audits (RATAs) of the continuous emission monitoring system.
(C)(2)-(4) – These conditions serve to reference other conditions in the permit that pertain to emission testing requirements.
(D)(1) – The requirements set forth under this condition establish the methods to be used to collect data and calculate CO emission rates for a variety of time-based averages. These requirements set forth a means by which the owner/operator will demonstrate ongoing compliance with the emission limit set forth in Condition XXXI(B)(1). (D)(2) – The requirements set forth under this condition establish a time
frame that the owner/operator must follow to demonstrate initial compliance with the emission limit set forth in Condition XXXI(B)(1), and also the performance specifications and standards that the CEMS must comply with.
(D)(3)-(4) – The requirements set forth under these conditions are meant to provide alternative means of emission monitoring due to the uncertainty regarding the impact on CO emissions from the OFA project. While CO monitoring data from Sheldon Station Unit 2, which has already been equipped with an OFA system, has shown actual emissions that are consistently lower than the emission limit for that boiler (same as the emission limit in Condition XXXI(B)(1)), it is not known if similar results will be achieved for Unit 1. The Department believes that a less stringent CEMS certification program is appropriate, so long as actual emissions are less than 90% of the emission limit. In the event that actual emissions equal or exceed 90% of the emission limit, the Department believes that more stringent CEMS certification requirements would be appropriate, and these conditions specify procedures and deadlines that the owner/operator must follow in such an event.
(E)(1) – This condition references applicable record keeping requirements set forth in NSPS Subpart A (General Provisions).
(E)(2) – These record keeping requirements are intended to ensure that all records are complete and contain verifiable information, and that such records are maintained on-site for a period of no less than 5 years.
(F)(3) – The requirement set forth under this condition provides the Department information, with which the Department can assess whether the CEMS must meet the requirements set forth under Condition XXXI(D)(4).
(F)(4) – This condition reinforces the requirement that the owner/operator report emissions to the Department annually, as specified in General Condition XIV.
(F)(5)-(6) – This condition serves to ensure that the Department receives notification of the all performance tests, as well as the results of all required performance testing. The notification requirement provides the Department time to ensure an observer can be present during the emission testing.
Section 10 – Summary of Permit Conditions Enforceable by Agency (1) LLCHD (Local) – All conditions indicated in this permit.
(2) EPA (Federal) – All conditions indicated in this permit with the exceptions of General Condition I(B)(2) (odor and air pollution nuisance codes).
Section 11 – Pollution Prevention Opportunities
The Department encourages NPPD to continually examine its operations for pollution prevention opportunities. The Department’s Technical Assistance Program can provide resources to aid the facility in exploring available pollution prevention options.
Section 12 – Air Quality Program Recommendation
The Department proposes approval of a Construction Permit for this facility. Enforceable permit conditions have been provided in the draft permit. A final determination on this permit will be made following the opportunity of the public and the Environmental Protection Agency (EPA) to comment on the draft permit, and comments received from all parties have been addressed.
Section 13 – Public Participation
The following notice is scheduled for publication in the April 15, 2013 edition of the Lincoln Journal Star, which is a newspaper of general circulation in Lancaster County, Nebraska.
This notice will also be made available on the Lincoln-Lancaster County Health Department (LLCHD) Air Quality Program website at the following url:
http://www.lincoln.ne.gov/city/health/environ/pollu/pubnot.htm
In accordance with Article 2, Section 14 of the Lincoln-Lancaster County Air Pollution Control Program Regulations and Standards (LLCAPCPRS), notice is given for the following proposed actions:
1. The preliminary determination by the LLCHD to approve the issuance of a Prevention of Significant Deterioration (PSD) construction permit for the Nebraska Public Power District (NPPD) Sheldon Station.
In accordance with Article 2, Section 14, paragraph (J) of the LLCAPCPRS, notice of the draft permit shall be given to the U.S. Environmental Protection Agency, the Iowa Department of Natural
Resources, and the Kansas Department of Health and Environment. Iowa and Kansas will be notified because they are affected states, i.e., a contiguous State within 50 miles of the permitted source. In addition to these agencies, notice will also be provided to the Nebraska Department of Environmental Quality and the Omaha Public Works Department.
A. Issuance of the proposed permits allows for continued operation of the subject emission source within Federal, State and Local requirements. Provided below are the name, address, and the
North America Industry Classification System (NAICS) code describing the nature of business at the subject emission source:
1. Source Name: NPPD Sheldon Station
2. Source Address: 4500 W. Pella Road, Hallam, NE 68368 3. NAICS Code(s): 221112 (Electric Power Generation, Fossil Fuel)
B. This source currently holds a Class I (Title V) operating permit from the Department, and is a major source of air pollution for the purposes of Title V and for the purposes of Prevention of Significant Deterioration of Air Quality (PSD).
C. This permitting action is subject to PSD requirements because it will increase the potential to emit carbon monoxide (CO) by more than 100 tons per year. After project completion,
emissions of other air pollutants are expect to remain unchanged, with the possibility of reduced emissions of some pollutants. Based on the results of air dispersion modeling, the increase in carbon monoxide emissions will not jeopardize Lancaster County’s current classification as an ‘attainment’ area for carbon monoxide.
D. The proposed permit is available for inspection during business hours at the office of the LLCHD at 3140 N Street, Lincoln, NE 68510. A copy of this public notice document may also be obtained online at: http://lincoln.ne.gov, keyword search “air”. Telephone inquiries regarding this public notice may be directed to Gary Bergstrom, Senior Environmental Health Specialist, at (402) 441-6202. If alternate formats of materials are needed, please notify the Department by calling (402) 441-8040 or (402) 441-6284 for TDD users.
E. The 30-day public comment period commences April 15, 2013 and ends on May 15, 2013. Within the 30-day public comment period, any interested person, agency, or group may request or petition the Director of the LLCHD for a public hearing. All requests for public hearing must be made in writing, and must state the nature of the issues to be raised and all arguments and factual grounds supporting their position. If a public hearing is granted by the Director, the hearing will be advertised by public notice at least 30 days prior to its occurrence. Comments on the proposed permits should be mailed to:
Chris Schroeder, Air Quality Program Supervisor Lincoln-Lancaster County Health Department Environmental Public Health Division
3140 "N" Street
