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01 POWER ISLAND / 04 CO2 capture / FEED Study for Retrofitting the Prairie State Generating Station with an 816 MWe Capture Plant using Mitsubishi Heavy Industries Post-Combustion CO2 Capture Technology.pdf
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emissions in excess of 25 tpy for total HAP and/or potential emissions in excess of 10 tpy for any individual HAP. The National Emissions Standards for Hazardous Air Pollutants (NESHAP) for sources regulated under 40 CFR Part 63, are the emission standards for HAPs applicable to major sources of HAPs and some area sources of HAPs in selected source categories. NESHAP allowable emission limits are established based on a maximum achievable control technology (MACT) determination for a particular source. NESHAP requirements apply to major sources in specifically regulated industrial source categories [Clean Air Act Section 112(d)] or on a case-by-case basis [Section 112(g)] for facilities not regulated as a specific industrial source type. US EPA’s regulations for case-by-case MACT are detailed in 40 CFR Part 63, Subpart B. Industrial carbon capture plants with the primary purpose of removing CO2 from gaseous feedstocks are not a listed NESHAP source category, and therefore, case-by-case MACT requirements would be applicable to the proposed carbon capture plant if potential emissions exceed the HAP major source threshold.

Prevention of Significant Deterioration (PSD) Modeling Overview

High-level air dispersion modeling was completed for the proposed plant to evaluate potential compliance with National Ambient Air Quality Standards (NAAQS) of concern. A Preliminary Modeling analysis prepared by Trinity Consultants provides indications that criteria pollutants of concern fall below the NAAQS thresholds.

A typical Prevention of Significant Deterioration (PSD) modeling analysis will include a Significance Analysis, in which modeled emission rates from the project alone are compared against SILs, a NAAQS analysis, in which modeled emission rates from both the project and nearby sources are compared against the NAAQS, and an increment analysis, in which modeled emission rates from the project and nearby increment-consuming sources are compared against the available increment. For this high-level analysis, modeled results were only compared against the SIL and NAAQS. While not a true SIL or NAAQS analysis, this exercise was intended to provide an approximation of SIL and NAAQS modeling to identify any critical issues for the project.

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