Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
B6527
RENEWABLE OPERATING PERMIT
STAFF REPORT
ROP Number
MI-ROP-B6527-2014
MIDLAND COGENERATION VENTURE
SRN: B6527
Located at
100 Progress Place, Midland, Midland County, Michigan 48640
Permit Number: MI-ROP-B6527-2014
Staff Report Date: June 16, 2014
This Staff Report is published in accordance with Sections 5506 and 5511 of Part 55, Air Pollution
Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act
451). Specifically, Rule 214(1) requires that the Michigan Department of Environmental Quality (MDEQ),
Air Quality Division (AQD), prepare a report that sets forth the factual basis for the terms and conditions
of the Renewable Operating Permit (ROP).
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TABLE OF CONTENTS
JUNE 16, 2014 STAFF REPORT
3
JULY 28, 2014 STAFF REPORT ADDENDUM
9
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Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
B6527
RENEWABLE OPERATING PERMIT
JUNE 16, 2014 STAFF REPORT
ROP Number
MI-ROP-B6527-2014a
Purpose
Major stationary sources of air pollutants, and some non-major sources, are required to obtain and
operate in compliance with a ROP pursuant to Title V of the federal Clean Air Act of 1990 and Michigan’s
Administrative Rules for air pollution control pursuant to Section 5506(1) of Act 451. Sources subject to
the ROP program are defined by criteria in Rule 211(1). The ROP is intended to simplify and clarify a
stationary source’s applicable requirements and compliance with them by consolidating all state and
federal air quality requirements into one document.
This report, as required by Rule 214(1), sets forth the applicable requirements and factual basis for the
draft permit terms and conditions including citations of the underlying applicable requirements, an
explanation of any equivalent requirements included in the draft permit pursuant to Rule 212(5), and any
determination made pursuant to Rule 213(6)(a)(ii) regarding requirements that are not applicable to the
stationary source.
General Information
Stationary Source Mailing Address:
Midland Cogeneration Venture
100 Progress Place
Midland, Michigan 48640
B6527
221112
Source Registration Number (SRN):
North American Industry Classification System
(NAICS) Code:
Number of Stationary Source Sections:
Is Application for a Renewal or Initial Issuance?
Application Number:
Responsible Official:
AQD Contact:
Date Permit Application Received:
Date Application Was Administratively Complete:
Is Application Shield In Effect?
Date Public Comment Begins:
Deadline for Public Comment:
1
Renewal
201200081
Brian Vokal
Vice President of Operation, Maintenance &
Engineering
989-633-7840
Kathy Brewer
Environmental Quality Analyst
989-894-6214
May 16, 2012
May 16, 2012
Yes
June 16, 2014
July 16, 2014
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Source Description
Midland Cogeneration Venture Limited Partnership owns and operates the Midland Cogeneration
Venture (MCV) facility in Midland Michigan. The MCV facility consists of 12 natural gas fueled combined
cycle turbines, with a net facility electrical output of greater than 1,550 megawatts (MW). The twelve gas
turbines are equipped with heat recovery steam generators (GT/HRSGs) with a combined steam
capacity of 1,200,000 lbs/hr. Six of the units (Turbines 9 through 14) are equipped with duct burners
(DB) for supplemental firing, each with a maximum heat input capacity of 249 million British thermal units
per hour (MMBtu/hr). Twelve turbines (EU-T03 through EU-14) are equipped with a fogging system to
reduce inlet air temperature during the warm weather season. Nitrogen oxide (NOx) emissions from
each of eleven turbines is controlled via steam injection. NOx emissions from the remaining turbine is
controlled via a dry low NOx burner. In addition to the 12 combined cycle turbines, the facility consists of
6 natural gas fired boilers, each with a heat input capacity of 370 MMBtu/hr, capable of supplying
250,000 pounds per hour (lb/hr) of steam. Part of the steam generated by the boilers is utilized to
generate electricity and the remaining steam is utilized by process steam customers adjacent to the
facility.
On April 23, 2013, the facility was issued a Permit to Install for two additional natural gas fired
combustion turbine generators (CTG) each with a HRSG and one condensing steam generator (STG)
with steam extraction for export to the existing facilities. The CTGs will be equipped with evaporative
cooling units and the HRSGs will be equipped with DBs. The CTGs will each have a maximum heat
input capacity of 2237.4 MMBtu/hr and the DBs will each have a maximum capacity of 249 MMBtu/hr.
The following table lists stationary source emission information as reported to the Michigan Air Emissions
Reporting System in the 2012 submittal.
TOTAL STATIONARY SOURCE EMISSIONS
Pollutant
Carbon Monoxide (CO)
Ammonia
Tons per Year
769
2.8
Nitrogen Oxides (NOx)
Particulate Matter (PM)
Sulfur Dioxide (SO2)
Volatile Organic Compounds (VOCs)
**As listed pursuant to Section 112(b) of the federal Clean Air Act.
3105.7
197.7
3.9
65.6
In addition to the pollutants listed above that have been reported in MAERS, the potential to emit of
Greenhouse Gases in tons per year 7547447 short tons of CO2e. CO2e is a calculation of the combined
global warming potentials of six Greenhouse Gases (carbon dioxide, methane, nitrous oxide,
hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride).
See Parts C and D in the draft ROP for summary tables of all processes at the stationary source that are
subject to process-specific emission limits or standards.
Regulatory Analysis
The following is a general description and history of the source. Any determinations of regulatory nonapplicability for this source are explained below in the Non-Applicable Requirement part of the Staff
Report and identified in Part E of the ROP.
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The stationary source is located in Midland County, which is currently designated by the U.S.
Environmental Protection Agency (USEPA) as attainment/unclassified for all criteria pollutants.
The facility is considered a major Title V 40 CFR Part 70 source due to the potential to emit nitrogen
oxides, carbon monoxide, sulfur dioxide and particulate matter in excess of 100 tons per year, and the
potential to emit of Greenhouse Gases is 100,000 tons per year or more calculated as carbon dioxide
equivalents (CO2e) and 100 tons per year or more on a mass basis. In addition, the stationary source is
considered a major source of Hazardous Air Pollutant (HAP) emissions because the potential to emit any
single HAP regulated by the federal Clean Air Act, Section 112 is greater than 10 tons per year and the
potential to emit of all HAPs combined is greater than 25 tons per year.
The facility is subject to the Standards of Performance for New Stationary Sources (40 CFR 60),
including 40 CFR 60, Subpart A - General Provisions. Specifically, the existing and proposed natural gas
fired stationary gas turbines and the duct burners are subject to 40 CFR 60, Subparts GG (Stationary
Gas Turbines), Db (Industrial-Commercial-Institutional Steam Generating Units and KKKK (Stationary
Combustion Turbines). The boilers are subject to 40 CFR 60, Subparts Da (Electrical Utility Steam
Generating Units) .
The stationary source is subject to the National Emission Standard for Hazardous Air Pollutants
promulgated in 40 CFR, Part 63, Subparts A, DDDDD (Industrial-Commercial and Institutional Boilers
and Process Heaters), and ZZZZ (Stationary Reciprocating Combustion Engines). The proposed CTGs
are also subject to 40 CFR, Part 63, Subpart YYYY (Stationary Combustion Turbines). The existing
turbines were installed prior to January 14, 2003 and are not subject to 40 CFR, Part 63, Subpart YYYY.
FG-BOILERS1-6 at the stationary source are subject to the Maximum Achievable Control Technology
(MACT) standards under the National Emission Standard for Hazardous Air Pollutants for Major Sources
for Industrial, Commercial and Institutional Boilers and Process Heaters, 40 CFR, Part 63 Subpart
DDDDD. Due to a January 9, 2012 D.C. Circuit Court decision, the Boiler MACT, promulgated on March
21, 2011, is in effect. The Boiler MACT has been cited as an applicable requirement in FG-BOILER1-6
Emission Limits table.
EU-DIESELGEN is a diesel fired emergency generator with maximum hourly rated capacity of 47 million
Btu/hr (7000 horsepower), installed August 1979 used during power failures to provide power for lighting
and other vital plant systems and equipment. The generator is operated less than 100 hours per year for
nonemergency purposes such as maintenance checks and readiness testing. EU-DIESELGEN is
subject to the requirements of 40 CFR, Part 63, Subpart ZZZZ for emergency combustion ignition
engines over 500 horsepower at a major source of HAPs. The performance testing, emission limitations,
operation and maintenance requirements of 40 CFR, Part 63, Subpart ZZZZ for nonemergency
combustion ignition engines are not applicable as long as the facility operates EU-DIESELGEN in
compliance with the conditions contained in the ROP and 40 CFR, Part 63, Subpart ZZZZ.
The facility is subject to review under the Prevention of Significant Deterioration regulations of 40 CFR,
PART 52.21, because at the time of New Source Review permitting the potential to emit of carbon
monoxide, nitrogen oxides and particulate matter was greater than 100 tons per year.
At this time, there are no GHG applicable requirements to include in the ROP. The mandatory
Greenhouse Gas Reporting Rule under 40 CFR, Part 98 is not an ROP applicable requirement and is not
included in the ROP.
The six existing boilers and twelve turbines at the stationary source are subject to the Clean Air Interstate
Rule NOx annual trading program pursuant to Rules 802a, 803, 821, and 830 through 834.
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The six existing boilers and twelve turbines at the stationary source are subject to the Clean Air Interstate
Rule NOx ozone season trading program pursuant to Rules 802a, 803 and 821 through 826.
The six existing boilers and twelve turbines at the stationary source are subject to the Clean Air Interstate
Rule SO2 annual trading program pursuant to Rule 420.
The monitoring conditions contained in the ROP are necessary to demonstrate compliance with all
applicable requirements and are consistent with the "Procedure for Evaluating Periodic Monitoring
Submittals."
The emission limitation(s) or standard(s) for Nitrogen Oxides and Carbon Monoxide from existing and
proposed natural gas fired stationary gas turbines and duct burners, and, from the boilers at the
stationary source, are exempt from the federal Compliance Assurance Monitoring (CAM) regulation
under 40 CFR, Part 64 because the required continuous emission monitoring meet(s) the CAM
exemption for a continuous compliance determination method. Therefore, existing and proposed natural
gas fired stationary gas turbines, duct burners and boilers are exempt from CAM requirements for
Nitrogen Oxides and Carbon Monoxide .
Please refer to Parts B, C and D in the draft ROP for detailed regulatory citations for the stationary
source. Part A contains regulatory citations for general conditions.
Source-wide Permit to Install (PTI)
Rule 214a requires the issuance of a Source-wide PTI within the ROP for conditions established
pursuant to Rule 201. All terms and conditions that were initially established in a PTI are identified with a
footnote designation in the integrated ROP/PTI document.
The following table lists all individual PTIs that were incorporated into previous ROPs. PTIs issued after
the effective date of ROP No. MI-ROP-B6527-2008 are identified in Appendix 6 of the ROP.
351-07
759-87B
316-05B
311-79
PTI Number
576-92
1001-90
759-87
Streamlined/Subsumed Requirements
The following table lists explanations of any streamlined/subsumed requirements included in the ROP
pursuant to Rules 213(2) and 213(6). All subsumed requirements are enforceable under the streamlined
requirement that subsumes them.
Emission
Unit/Flexible
Group ID
EUTURBINE12
Condition
Number
I.1
Streamlined
Limit/
Requirement
NOx, 98 pph,
1 hour average
Subsumed Limit/
Requirement
40 CFR 60.332(a)(1),
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Stringency Analysis
The pound per hour limit
determined through NSR
and PSD BACT is more
stringent than the
calculated NOx emission
limit contained in 40 CFR
Part 60 Subpart GG
which is based on heat
load rate
FGSITURBINES
I.1
NOx, 159 pph,
1 hour average
each turbine
40 CFR 60.332(a)(1),
The pound per hour limit
determined through NSR
and PSD BACT is more
stringent than the
calculated NOx emission
limit contained in 40 CFR
Part 60 Subpart GG
which is based on heat
load rate
Non-applicable Requirements
Part E of the draft ROP lists requirements that are not applicable to this source as determined by the
AQD, if any were proposed in the application. These determinations are incorporated into the permit
shield provision set forth in Part A (General Conditions 26 through 29) of the draft ROP pursuant to
Rule 213(6)(a)(ii).
Processes in Application Not Identified in Draft ROP
The following table lists processes that were included in the ROP application as exempt devices under
Rule 212(4). These processes are not subject to any process-specific emission limits or standards in
any applicable requirement.
Exempt
Emission Unit ID
DVSPHTR1
DVSPHTR2
DVSPHTR3
DVSPHTR4
DVGASTANK1
DVGASTANK2
DVFGASSEP
DV99T809
DVM&RHTR
Description of
Exempt Emission Unit
Natural gas fired space heater no. 1
Natural gas fired space heater no. 2
Natural gas fired space heater no. 3
Natural gas fired space heater no. 4
Above ground gasoline storage tank
#1
Above ground gasoline storage tank
#2
Fuel gas filter/separator slop tank
Fuel gas knockout drum
M&R natural gas fired fuel gas heater
ROP
Exemption
R 336.1212(3)(b)
R 336.1212(3)(b)
R 336.1212(3)(b)
R 336.1212(3)(b)
R 336.1212(3)(c)
NSR Permit
Exemption
R 336.1282(b)(i)
R 336.1282(b)(i)
R 336.1282(b)(i)
R 336.1282(b)(i)
R 336.1284(g)(i)
R 336.1212(3)(c)
R 336.1284(g)(i)
R 336.1212(3)(c)
R 336.1212(3)(c)
R 336.1212(3)(b)
R 336.1284(e)
R 336.1284(e)
R 336.1282(b)(i)
This permit does not contain any terms and/or conditions that the AQD and the applicant did not agree
upon pursuant to Rule 214(2).
Compliance Status
The AQD finds that the stationary source is expected to be in compliance with all applicable
requirements as of the effective date of this ROP.
Action taken by the DEQ
The AQD proposes to approve this permit. A final decision on the ROP will not be made until the public
and affected states have had an opportunity to comment on the AQD’s proposed action and draft permit.
In addition, the U.S. Environmental Protection Agency (USEPA) is allowed up to 45 days to review the
draft permit and related material. The AQD is not required to accept recommendations that are not
based on applicable requirements. The delegated decision maker for the AQD is Chris Hare, Saginaw
Bay District Supervisor. The final determination for ROP approval/disapproval will be based on the
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contents of the permit application, a judgment that the stationary source will be able to comply with
applicable emission limits and other terms and conditions, and resolution of any objections by the
USEPA.
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Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
RENEWABLE OPERATING PERMIT
ROP Number
B6527
JULY 28, 2014 STAFF REPORT ADDENDUM
MI-ROP-B6527-2014
Purpose
A Staff Report dated June 16, 2014, was developed in order to set forth the applicable requirements and
factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as required by
R 336.1214(1). The purpose of this Staff Report Addendum is to summarize any significant comments
received on the draft ROP during the 30-day public comment period as described in R 336.1214(3). In
addition, this addendum describes any changes to the draft ROP resulting from these pertinent
comments.
General Information
Responsible Official:
AQD Contact:
Brian Vokal
Vice President of Operation, Maintenance & Engineering
989-633-7840
Kathy Brewer
Environmental Quality Analyst
(989) 894-6214
Summary of Pertinent Comments
No pertinent comments were received during the 30-day public comment period.
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