1-18 Please identify any study or other information the company has regarding the expected impact of air emissions on the air quality in the homes in the immediate neighborhood of the proposed facility.
4-44 Please explain the air pollutant trading allowance program generally. Explain the cost of allowances, amount paid by Invenergy and the amount of pollution being purchased above regulatory limits. Please explain this for each pollutant type. Please explain what is the flow of the money for such purchases (i.e., does it get deposited to a State or Federal Agency or traded to another project in the U.S.)?
4-46 What has been Ocean State Power’s air emissions, by pollutant type as reported to the EPA, over the past ten years and how does that compare to what Invenergy projects for the Clear River Energy Center during its first ten years of operation?
6-13 Please identify the anticipated combined air pollution levels in the immediate area when considering this proposed power plant, the emissions generated by the adjacent gas plant, and Ocean State Power.
7-1 Property Line and Fence Line Location
Please provide a legal description of the property line and fence line used in the model results submitted to and approved by RIDEM as demonstrating compliance with applicable standards and the basis for issuing the proposed facility’s air quality construction permit.
7-2 Proposed use of Ultra-Low Sulfur Diesel (ULSD) as a Secondary Fuel in the Combustion Turbines
Please clarify when the facility will use ULSD in the combustion turbines as a fuel. Specifically, please identify whether the use ULSD will be a contractual obligation or a choice presented to facility operators on any given day.
7-4 Please clarify the number of tanks, capacity of each tank, and size/dimensions of each tank proposed for storage of ULSD at the site. Conflicting values are present in the document submissions, including, but not limited to, the following:
7-5 Emission Calculations – General
Please explain why the Combustion Turbine potential emissions for Criteria Pollutants are estimated using Annual Operation (per Unit) values of 8020-hours/year for Natural Gas and 740-hours/year for ULSD, but potential emissions for Non-Criteria Pollutant are estimated using 8040-hours/year for Natural Gas and 720-hours for ULSD.
7-6 Please provide a calculation showing the equivalent steady-state emission rate in lb/hr at full-load during typical operational conditions the “Proposed Emissions” values listed in Table 1 for the Combustion Turbine, specifically:
NOx 2.0-ppmvd @ 15% O2 for Natural Gas and 5.0-ppmvd @ 15% O2 for Diesel
CO 2.0-ppmvd @ 15% O2 for Natural Gas and 5.0-ppmvd @ 15% O2 for Diesel
VOC 1.7-ppmvd @ 15% O2 for Natural Gas and 5.0-ppmvd @ 15% O2 for Diesel
7-8 The partial-stayed EPA MACT Standard for Combustion Turbines (40 CFR 63, Subpart YYYY) published on March 5, 2004 limited formaldehyde emissions to 91 ppbvd @ 15% O2 when firing natural gas, as well as during the firing of oil. Please provide rationale for selecting the stayed MACT Standard as the emission factor source during firing of natural gas described in Section 5.3.10, but not ULSD.
7-9 It is unclear how the EPA MACT Standard limit for formaldehyde of 91 ppbvd @ 15% O2 relates to the Combustion Turbine natural gas uncontrolled formaldehyde emission factor. Please provide calculation showing the method of determining the 2.2-lb/MMBtu formaldehyde emission factor listed in Table A-2.
7-10 For sources using an oxidation catalyst, the EPA MACT Standard for formaldehyde of 91 ppbvd @ 15% O2 is the limit for controlled emissions. Since the proposed facility intends to use an oxidation catalyst as a control device, please provide rationale for basing the uncontrolled formaldehyde emission factor on the MACT Standard’s limit for controlled formaldehyde emissions.
7-11 It is unclear how the CO2 emission rates were calculated for the combustion turbines. Please provide the calculation methodology for the natural gas 814-lb/MW-hr and the ULSD 1227-lb/MW-hr values listed in Section 4.4.3.
7-14 Please clarify whether a control device is proposed for installation on the Emergency Generator, since the estimated Benzene emission rate calculated using the method shown above is an order of magnitude less than the values contained in Table 2.