Outage Planning: Did You Consider Your Air Permit?

by Mary Turner – Environmental Specialist, NAES Environmental Services

Your next planned outage is on the horizon, and your outage team has all the right management tools in place to make sure it comes off without a hitch. You started holding pre-planning meetings a year in advance, collaborating with the owner and engineering department to ensure your outage plan would cover all the bases.

You ordered the long-lead parts well ahead of vendor deadlines and lined up an experienced field crew and made sure they have the tools to get your equipment repaired, tuned and operating almost like new. All work orders, purchase requests and job plans are in place – and your owner even approved the extra costs to have the equipment upgraded to achieve nameplate efficiencies.

The plan is working and you are ready to knock this one out of the park…but – did you consider your air permit and how it might factor into outage planning?

NAES Environmental Services (ES) has recently been involved with a number of outage projects that initially seemed to require nothing but routine maintenance and repair. On closer inspection, however, every one of them needed an application to modify the air permit or a regulatory analysis to demonstrate to the permitting agencies that a permit application was not required.

To give you an idea of the broad range of outages that ended up requiring one or another of these air permitting actions, here are some of the more notable projects:

• Cold day optimization and quaternary gas circuit installation project for a 270 MW combined-cycle gas turbine (CCGT) plant.
• Thermal performance upgrade project at an 830 MW CCGT plant.
• Duct-firing capacity increase for a 795 MW CCGT plant.
• Turbine replacement project after catastrophic failure at a 47 MW CCGT plant.
• Increased fuel-oil use for a 286 MW natural gas- or diesel-fired combined-cycle turbine plant.
• Duct-burner installation at a 63 MW CCGT plant.
• Auxiliary boiler installation at a 600 MW CCGT plant.
• Conversion of a natural gas-fired simple-cycle plant to 2200 MW CCGT plant.
• Installation of black-start engine at a 315 MW simple-cycle peaker plant.
• Permit modification application to remove major HAP source conditions from the Permit-to-Construct and Class II operating permit and incorporate new regulatory requirements for new engines at a 102 MW natural gas-fired reciprocating internal combustion engine plant.
• Air permits for temporary operation of portable diesel generators during planned and unplanned outages.

Vendors these days are diligent about marketing their breakthrough technology to improve the efficiency or operational flexibility of the equipment at your plant. They often solicit the owners directly, who can get very enthusiastic about such improvements, especially if they’ve successfully implemented a similar project at another one of their plants.

However, the permitting history of past projects, especially those undertaken in another state, can be misleading. One size does not fit all: the air permit regulations in one state can differ substantially from those in another. Most of these upgrade projects require an air permit modification, regulatory analysis or, at a minimum, advance notification of the permitting agency.

Air permitting can prove to be the longest-lead item on your outage planning list. If you could use permitting support in planning your next outage project, contact us at NAES Environmental Services. We can help ensure that your well-oiled outage planning machine isn’t derailed by any permitting pitfalls.