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Air Pollution Control employee reports on discussion with applicant's consultant about the state's modeling protocol requirements.

Telephone Memorandum

To: A2 File ^ Southern Vermont Gas
From: Brian Fitzgerald, Engineering Services
Date: March 3, 1999
Subject: Southern Vermont Gas ^ Combined Cycle Power Plants

I spoke with Doug Fulle and two other representatives of Foster Wheeler Environmental, permitting consultants for the two natural gas combined cycle plants proposed for Rutland and Bennington, Vermont. The purpose of the call was to discuss the process which would be used to review the applications.

I explained the general requirements of the review process and discussed the following points. 1. Pre-application modeling protocol submittal: 2. Modeling guidance; 3. Pre-construction monitoring for criteria pollutants and meteorological parameters; 4. Involvement of federal land manager in permit process; 5. MSER "top-down" process; 6. Ozone Transport Region requirements; 7. Status of NOx waiver submittal; and 8. Hazardous air pollutant applicability. I informed the consultants that a pre-application modeling protocol should be submitted for our review and comment. We discussed the need to submit this protocol to the Federal Land Manager and affected states. We all agreed it would be a good idea to obtain feed back from these parties early in the process. The modeling protocol should contain the models which will be used to evaluate criteria pollutant impacts and air quality related values in Class I areas. There was general discussion on how discrete receptors would be identified and on how "sensitive areas" would be assessed.

We then discussed the potential need for pre-construction monitoring of criteria pollutants and/or meteorological parameters. I indicated there would not likely be a need for monitoring of criteria pollutants but was not certain about meteorological data. Pre-construction monitoring is one area which the consultants would like feed back about as soon as possible. I committed to getting back to them on the monitoring issue.

The next general area of discussion involved MSER analysis. I informed them that for NOx and VOC, if emissions were significant then a LAER type of analysis is required. For other significant emissions, a BACT-like top-down approach should be used. I discussed the desire to look at all significant emissions in conjunction with one another to develop the best strategy to keep all emissions as low as possible. I also indicated a desire to look at overall plant efficiency when setting emission standards (lb/MMBTU vs. lb/kw).

Finally, we discussed the evaluation of hazardous air impacts. While our rules exempt HAC review for fuel burning equipment combusting gaseous fuels, it would be a good idea to perform an assessment of air toxic impacts should the issue come up during public review or other permit boards (such as PSB).


Cc: Paul
Pete LaFlamme, Water Quality

Copyright © 1999 by Vermonters for a Clean Environment
Updated: October 4, 1999