Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-01282-JJF

Document 59-9

Filed 12/06/2005

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Case 1:04-cv-01282-JJF CORPORATION 59-9 Document 16=26 THE RES

Filed 12/06/2005

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The AES Corporation
JOOl North 19th Street, 20* Floor ' Arlington, VA 22209 tel (703) 522-1315 fax (703) 528-4510

Date: November 6, 2001
To: Trif Fax: (787) 866-8139

From: Paula Salguero
Pages: 28 (including cover page)

Paula Salguero The AES Corporation (703) 358-0521 direct [email protected]

AESPR 076015

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Case 1:04-cv-01282-JJF
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Document 59-9

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 2 290 BROADWAY NEW YORK, NY 10007-1866

OCT 2 9 20W1
Certified Mail - Return Receipt Requested Ms. Sarah Slusser, Vice President AES Puerto Rico, L.P. 1001 North 19th Street Arlington, Virginia 22209 Re: Prevention of Significant Deterioration of Air Quality (PSD) Permit for the Proposed AES Puerto Rico Cogeneration Plant (AES-PRCP) Administrative Permit Modification

Dear Ms. Slusser: On September 18,1998, the Region 2 Office of the U.S. Environmental Protection Agency (EPA) issued a final PSD permit to the AES Puerto Rico, L.P. company for the construction and operation of a 454 megawatt (net) coal-fired steam electric cogeneration facility known as the AES Puerto Rico Cogeneration Plant (AES-PRCP) in Guayama, Puerto Rico, The PSD permit consisted of a project description and summary of the control technologies provided in an Attachment I. The permit conditions were found in an Attachment II. An Attachment III contained the project's air quality impacts and an Attachment IV contained EPA's response to comments on the initial draft permit. Subsequently, the PSD permit was administratively appealed with the EPA's Environmental Appeals Board. All appeals were ultimately dismissed and the final PSD permit became effective on May 27, 1999. On July 11, 2000, AES requested EPA to make certain corrections in the AES's PSD permit due to a mathematical error in calculating parts per million (ppm) equivalencies of mass emission rates for the pollutant emissions from the circulating fluidized boiler. This request only affected the ppm values in the permit. Emissions in Ib/hr, Ib/MMBTU, and tons/year will not change. On September 11, 2000, at the request of EPA, AES provided the specific reasons (and a demonstration) as to why there was a need to make the requested changes. That is, the original ppm, Ib/hr, and Jb/MMBtu values were based on the "environmentally worst-case coal" allowed by the permit of 1 % sulfur content with a heating value of 11,000 Btu/lb. However, the worst ppm values actually occurs at the design coal of 0.76% sulfur content with a heating value of 11,600 Btu/lb with no effect on the worst Ib/hr and Ib/MMBru values.

AESPR 076016
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Page 1 of4 Attachment I AES Puerto Rico Cogeneration Project Project Description General Project Description: AES Puerto Rico, L.P. (AES-PRLP) proposes to construct and operate a 454 megawatt (net) coal-fired steam electric cogeneration facility located in Guayama, Puerto Rico. The AES Puerto Rico Cogeneration Project (AES-PRCP) will generate electricity for sale to the Puerto Rico Electric Power Authority (PREPA) and steam for the process and/or heating needs of one or more industries in the vicinity of the site. This cogeneration facility will consist of two bituminous coal-fired circulating fluidized bed (CFB) boilers which together will have a maximum heat input rate of 4,922.7 million British Thermal Units per hour (MMBTU/hr) at 105% maximum continuous rating (MCR). In addition, each CFB will be capable of generating approximately 1.8 million Ib/hr of steam at 2,400 psig and 1,000'F at the superheater outlet. These boilers will supply superheated steam to two extraction/condensing turbines to drive electric generators and supply process steam flow to industrial facilities of up to 290,000 Ib/hr. Emissions will be controlled through the use of CFB boiler and scrubber designs with limestone and lime injection, respectively, an electrostatic precipitator and a selective non-catalytic reduction system, in conjunction with the use of low sulfur coal. No. 2 fuel oil will be used as a start-up fuel. In addition, the facility will include one limestone dryer with a maximum heat input rate of 13 MMBTU/hr. The limestone dryer will consist of a crusher, in which a stream of heated air both classifies (separates by size fraction) the ground limestone, and dries the material. The limestone dryer will use propane and combustion controls to minimize emissions. The applicant also proposes to include a diesel generator, a diesel-engine driven boiler feed water pump and a diesel-engine driven fire water pump to ensure the safe operation and shutdown of the cogeneration facility in the unlikely event of a complete loss of off-site power.

The exhaust steam coming from the turbines is fed to a cooling tower. Circulating water flow in the tower will be 225,000 gallons per minute (gpm). The cooling tower will have a drift eliminator which will reduce drift to 0.001% of circulating water flow. Coal and Limestone Receiving and Handling Systems: In order to minimize fugitive paniculate emissions during unloading and to meet physical requirements of docking and unloading, gravity-feed belt conveyor and self-unloading ships will

AESPR 076017

Case 1:04-cv-01282-JJF

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Attachment I (confd) AES Puerto Rico Cogeneration Project Project Description

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be employed for delivering coal to the facility. The coal will be transported by overland conveyor approximately 3,800 feet to the site and stored in on-site stockpiles. The overland conveyor between the facility and the harbor will be capable of supplying coal and limestone delivered by ship to the facility's coal and limestone stockpiles. Lime Receiving and Handling System: The lime handling system includes equipment for storing lime delivered to the site by truck and discharging lime to the circulating dry scrubber reactant preparation system. Trucks delivering lime to the site will be equipped with a pneumatic transport to convey lime to the storage silo. A baghouse design vent filter and vent fan located on the silo roof will .filter the air from the trucks unloading transport air and displaced air from the silo. Solid Waste Handling and Processing: The facility will process fly ash and scrubber residue, bed ash, and sludge from the cooling tower sidestream treatment system thickener into manufactured aggregate. The facility will include a system to receive the solid waste streams and process them into conditioned by-product by gravimetrically controlled mixing of the waste stream with water. The conditioned by-product will be trucked or conveyed by belt conveyor to the by-product processing yard. Ash in its dry form will be fully contained during removal from the CFB boilers and air emission control systems, handling, and storage. Two ash storage silos are proposed to be located at the facility: one for bed ash and one for fly ash, Two full-capacity mechanical exhausters will be provided for conveying ash to the silos. Coal Storage: Coal will be stored at the facility in two outdoor piles. The inactive storage pile contains a nominal 30-day supply and is intended for use in the event of a coal delivery interruption. This pile will be created when the plant is built, and will be covered with soil and grass except in the event that access to this supply is needed. A 20-day active storage pile, compacted to prevent weathering, will be created by the stacking rubes. Each of the two coal storage piles onsite will be lined with a geosynthetic liner. Any stormwater run-off from the coal pile areas will be collected in a lined pond. The water collected will be recycled and utilized within the facility as part of the zero-water-discharge design.

AESPR 076018

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Page 3 of4 Attachment I (cont'd) AES Puerto Rico Cogeneration Project Project Description

Limestone Storage: A 150-day active supply of limestone will be stored in an enclosed storage area. Dust Control Systems: Dust control and collection systems will be installed at all material transfer points. The dust collection system will be either induced-draft filter bag units or insertible cartridge-type filters designed to be inserted directly into a conveyor head chute or conveyor loading skirt, as appropriate. PSD-Affected Pollutants Emitted_at the AES Puerto Rico Cogeneration Project and Their Potential to Emit: The AES-PRCP will have as constituents in the combustion by-products, the PSD-affected. pollutants listed below which are formed in the following ways: Nitrogen Oxides (NOJ - formed from the high-temperature oxidation of nitrogen contained in the combustion air (thermal NOJ and from the oxidation of nitrogen that is bound in the fuel (fuel NOJ. The relative amounts of thermal and fuel NOX formed depend primarily on the flame temperature and the fuel nitrogen content, respectively. The potential to emit forNOx is 2,058 tons/year. Sulfur Dioxide (SOj) - formed from the oxidation of organic sulfur contained in the fuel. Approximately 98% of the sulfur in bituminous coal is emitted as sulfur dioxides. The remaining 2% of fuel-bound sulfur is taken out as sulfate salts in the bottom ash or in the boiler itself. The potential to emit for SO2 is 453 tons/year. Partkulate Matter (PM), Participate Matter Under 10 Microns (PM10) - consist of coal ash, unreacted limestone and reaction products of the SO2 removal process (calcium sujfate or gypsum). The potential to emit for PMIO is 316 tons/year. Volatile Organic Compounds (VOCs) - due to incomplete combustion of organic compounds in the fuel. The potential to emit for VOC is 99.5 tons/year.

AESPR 076019

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Page 4 of4 Attachment I (cont'd) AES Puerto Rico Cogeneration Project Project Description

Carbon Monoxide (CO) - formed as a result of the incomplete combustion of the carbon contained in the fiiel. Incomplete combustion can be caused mainly by fuel-rich conditions, insufficient combustion oxygen, and/or low combustion temperatures. The potential to emit for CO is 2,055 tons/year. Fluorides and Sulfuric Acid Mist - released in trace amounts from the combustion of coal. Fluoride emissions vary depending on the fluorine content of the fuel. The potential to emit for fluorides is 9.8 tons/year. Similarly, sulfuric acid mist depend primarily upon the sulfur content of the fuel and the degree of emission control. The potential to emit for sulfuric acid mist is 50 tons/year. Fugitive Dust Emissions - derived from the material handling systems (coal, limestone and ash systems) including the following activities: - unloading or loading of ships or trucks; - material transfer points; and - exposure of materials to wind (in open storage piles).

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AESPR 076020

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Page 1 of20 Attachment II AES Puerto Rico (Regeneration Project PSD Permit Conditions The AES-PRCP as described in Attachment I is subject to the following conditions:
I.

This PSD Permit shall become invalid if construction: a. has not commenced (as defined in 40 CFR Part 52.21(b)(9)) within 18 months after the approval takes effect;

b.
c. II.

is discontinued for a period of 18 months or more; or
is not completed within a reasonable time.

Notification of Commencement of Construction and Startup The EPA Regional Administrator (RA) shall be notified in writing of the anticipated date of initial startup (as defined in 40 CFR Part 60.2) of each facility of the source not more than sixty (60) days nor less than thirty (30) days prior to such date. The RA shall be notified in writing of the actual date of commencement of construction and startup within fifteen (15) days after such date.

III. Plant Operations All equipment, facilities, and systems installed or used to achieve compliance with the terms and conditions of this PSD Permit shall at all times be maintained in good working order and be operated as efficiently as possible so as to minimize air pollutant emissions. The continuous emission monitoring systems required by this permit shall be on-line and in operation 95% of the time when boilers are operating. IV. Ripht to Entry The Regional Administrator and/or her authorized representatives, upon the presentation of credentials shall be permitted: 1. 2. 3. to enter at any time upon the premises where the source is located or in which any records are required to be kept under the terms and conditions of this PSD Permit; at reasonable times to have access to and copy any records required to be kept under the terms and conditions of this PSD Permit; to inspect any equipment, operation, or method required in this PSD Permit; and

AESPR 076021

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Page 2 of20 Attachment II (cont'd) AES Puerto Rico degeneration Project PSD Permit Conditions 4. V. to sample emissions from the source.

Transfer of Ownership In the event of any changes in control or ownership of facilities to be constructed or modified, this PSD Permit shall be binding on all subsequent owners and operators. The applicant shall notify the succeeding owner and operator of the existence of this PSD Permit and its conditions by letter, a copy of which shall be forwarded to the Regional Administrator.

VI.

Types of Fuel AES-PRCP shall combust the following fuels: 1) 2) 3) Low sulfur coal with a maximum sulfur content of 1.0% by weight. Distillate oil with a maximum sulfur content of 0.05% sulfur by weight (startup and emergency equipment fuel). Propane.

VII.

Pollution Control Equipment AES-PRCP shall install and shall continuously operate the following air pollution controls: 1) 2) 3) 4) 5) A Selective Non-Catalytic Reduction (SNCR) system (urea injection) for the control of NOX at the CFBs; A limestone injection system and circulating dry scrubber, which uses lime, for the control of SO2 at the CFBs; An Electrostatic Precipitator (ESP) for the control of PM and PM,0 at the CFBs; Baghouses for the control of PM and PM10 emissions at the limestone dryer. Drift eliminators for the control of particulates from the cooling tower.

VIII.

Best Available Control Technology fBACT) and Emission Limitations for Each of the Two Circulating Fluidized Boilers (CFBs^ Particulate Matter (PM), Particulate Matter Under 10 Microns (PM,0) Emissions of PM shall not exceed 0.015 Ib/MMBTU or 36.9 Jb/hour, whichever is more stringent.

1 -CFB. a. 1

AESPR 076022

NOU-06-2001

16:28

THE PIES CORPORATION

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Page 3 of20 Attachment II (cont'd) AES Puerto Rico Cogeneration Project PSD Permit Conditions

a.2

Emissions of PM10 (condensible and noncondensible) shall not exceed 0.015 Ib/MMBTU or 36.9 Ib/hour, whichever is more stringent. Because condensible PM,0 emissions from fluidized bed boilers have not been widely quantified, there is a possibility that the actual condensible portion of PM,0 would cause the above emission rate to be exceeded. In the event that AESPRCP cannot meet the above limit because of condensible PM10, EPA may adjust the PMIO emission rate to a level not to exceed 0.05 lb/MMBTU, pending EPA's review of the stack test results. This change in the permit will be accomplished administratively. Opacity of emissions shall not exceed 20 percent (six-minute average) except for one six-minute set per hour which shall not exceed 27 percent. The control efficiency of particulate matter emissions shall be established during all particulate performance testing and shall be a minimum of 99% at all times of normal operation (daily average). Nitrogen Oxides (NOJ Emissions of nitrogen oxides shall not exceed on a 24-hour rolling average basis 57 parts per million dry volume (ppm^) corrected to 7% oxygen, or 0.10 Ib/million British thermal units (BTU), or 246.1 Ib/hour, whichever is more stringent. Carbon Monoxide (CO) Emissions of CO shall not exceed 0.10 lb/MMBTU on an eight-hour average basis, 94 ppm^ corrected to 7% oxygen, or 246.1 Ib/hour, whichever is more stringent. Sulfur Dioxide (SOj) Emissions of sulfur dioxide shall not exceed on a 3-hour average basis 9.00 ppm^, corrected to 7% oxygen, or 0.022 lb/MMBTU, or 54.1 Ib/hour, whichever is more stringent. The maximum sulfur content of the coal shall be 1.0% S by weight. The maximum sulfur content of the No. 2 ftiel oil shall be 0.05% suite by weight.

a.3

b.

c.

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3-CFB. a.

4-CFB. a.

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AESPR 076023

NOU-06-2001

1S=28

THE OES CORPORRTION

P-10

Case 1:04-cv-01282-JJF

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Page 4 of20 Attachment II (cont'd) AES Puerto Rico Cogeneration Project PSD Permit Conditions

5-CFB.
a.

Sulfuric Acid Mist
Emissions of sulfuric acid mist shall not exceed based on the average of three 1hour slack performance tests 0.64 ppm^ corrected to 7% oxygen, or 0.0024 Ib/MMBTU, or 5.9 Ib/hour, whichever is more stringent.

6-CFB.
a.

Fluorides (as Hydrogen Fluoride)
Emissions of fluorides shall not exceed 4.78 x 10"1 Ib/MMBTU or 1.18 Ib/hour, whichever is more stringent.

7-CFB.
a.

Volatile Organic Compounds (VOCs)
Emissions of VOCs shall not exceed based on the average of three 1 -hour stack performance tests 7.70 ppm^ corrected to 7% oxygen, 0.0047 Ib/MMBTU, or 11.6 Ib/hour, whichever is more stringent. Ammonia (NH3) The ammonia slip associated with the urea injection shall not exceed 10 ppm^, corrected to 7% oxygen.

8-CFB. a.

IX.

Best Available Control Technology (BACT) and Emission Limitations for the Limestone k r eri The limestone dryer operation shall be limited to a 50% capacity factor, calculated on a calendar year basis or 4,380 hours per calendar year. The limestone dryer shall only bum propane. The limestone dryer shall utilize combustion controls to minimize air emissions. Particulate Matter (PM), Participate Matter Under 10 Microns (PM10) Emissions of PM shall not exceed 0.095 Ib/MMBTU or 1.24 Ib/hour, whichever is more stringent.

1-LD.

2-LD. 3-LD. 4-LD. a. 1

AESPR 076024