Challenges in Licensing New Gas-Fired Combustion Turbine Generation as an Alternative to MATS Compliance

摘要

Existing electric power plants with coal and oil-fired boilers are faced with mercury, acid gas, and hazardous air pollutant (HAP) emission standards and requirements under USEPA's Mercury and Air Toxics Standards (MATS) rule. In this era of relatively inexpensive, abundant natural gas availability, which is expected to continue, many facilities are considering retiring MATS-affected boilers, and repowering or replacing them with natural gas-fired combustion turbines, rather than implementing expensive back-end controls or fuel switches. However, this MATS compliance alternative (or more correctly, alternative to MATS compliance) presents its own set of challenges in the form of ever-changing licensing hurdles. This paper will explore the licensing challenges associated with natural gas combustion turbine combined-cycle based power plants. These challenges include the requirements associated with major source air permitting under the Prevention of Significant Deterioration (PSD) and Non-attainment New Source Review (NNSR) programs. Key among these are the evolving Best Available Control Technology (BACT) requirements for Greenhouse Gas (GHG) emissions, including the requirement to evaluate more efficient combustion turbine technologies and Carbon Capture and Storage (CCS) as a GHG emission control technology, and demonstrating compliance with recently promulgated, more stringent National Ambient Air Quality Standards (NAAQS) for nitrogen dioxide (NO_2), sulfur dioxide (SO_2), and fine particulate matter (PM_(2.5)).