Mr. Richard J Payonk
Wabash River Energy Ltd.
444 West Sandford Avenue
West Terre Haute, IN 47885
Re: 167-12145
Second Administrative Amendment to
Part 70 167-7353-00091
Dear Mr. Payonk:
Wabash River Energy Ltd was issued a permit on December 31, 1998 for a stationary coal
gasification system rated at 367,000 pounds of syngas produced per hour including gasification, high and
low temperature heat recovery, sour waste treatment, oxygen unit, and a flare. A letter requesting the use
of petroleum coke as an alternate fuel was received on March 29, 2000. Pursuant to the provisions of
2-7-11 the permit is hereby administratively amended as follows:
Wabash River Energy, Ltd. request the addition of petroleum coke as an alternate fuel. Due to
the cost of processing and transporting coal, it is no longer economical for them to operate on
coal alone. Wabash River Energy, Ltd. will remain in operation with the addition of the alternate
fuel.
All other conditions of the permit shall remain unchanged and in effect. Please attach a copy of
this amendment and the following revised permit pages to the front of the original permit.
This decision is subject to the Indiana Administrative Orders and Procedures Act - IC 4-21.5-3-5.
If you have any questions on this matter, please contact Mr. Darren Woodward, at (812) 462-3433,
extension 15.
Sincerely,
George M. Needham
Director
Vigo County Air Pollution Control
Attachments
DKW
cc: Mindy Hahn - IDEM
Winter Bottum - IDEM
PART 70 OPERATING PERMIT
OFFICE OF AIR MANAGEMENT
and
VIGO COUNTY AIR POLLUTION CONTROL
Wabash River Energy Ltd.
444 West Sandford Avenue
Terre Haute, Indiana 47885
(herein known as the Permittee) is hereby authorized to operate subject to the conditions
contained herein, the source described in Section A (Source Summary) of this permit.
This permit is issued in accordance with 326 IAC 2 and 40 CFR Part 70 Appendix A and contains
the conditions and provisions specified in 326 IAC 2-7 as required by 42 U.S.C. 7401, et. seq.
(Clean Air Act as amended by the 1990 Clean Air Act Amendments), 40 CFR Part 70.6, IC 13-15
and IC 13-17.
Operation Permit No.: T167-7353-00091
Issued by: Issuance Date: December 31, 1998
Janet G. McCabe, Assistant Commissioner
Office of Air Management
First Administrative Amendment 167-11851 Issuance Date: March 1, 2000
Second Administrative Amendment 167-12145 Page(s) Affected: Page 5
Issued by: Issuance Date: August 31, 2000
George M. Needham, Director
Vigo County Air Pollution Control
Gasification Services, Inc. Page 5 of 45
West Terre Haute, Indiana OP No. T167-7353-00091
Permit Reviewer: Rob Harmon
SECTION A SOURCE SUMMARY
This permit is based on information requested by the Indiana Department of Environmental Management
(IDEM), Office of Air Management (OAM) and Vigo County Air Pollution Control (VCAPC). The
information describing the source contained in conditions A.1 through A.3 is descriptive information and
does not constitute enforceable conditions. However, the Permittee should be aware that a physical
change or a change in the method of operation that may render this descriptive information obsolete or
inaccurate may trigger requirements for the Permittee to obtain additional permits or seek modification
of this permit pursuant to 326 IAC 2, or change other applicable requirements presented in the permit
application.
A.1 General Information [326 IAC 2-7-4(c)] [326 IAC 2-7-5(15)]
The Permittee owns and operates a stationary coal gasification system with the capabilities of
operating on coal, petroleum coke, or a blend of coal and petroleum coke. The system is rated
at 367,000 pounds of syngas produced per hour including gasification, high and low temperature
heat recovery, sour waste treatment, oxygen unit, and a flare.
Responsible Official: Richard J Payonk, Director of Operations
Source Address: 444 West Sandford Avenue, West Terre Haute, Indiana 47885
Mailing Address: 444 West Sandford Avenue, West Terre Haute, Indiana 47885
SIC Code: 2869
County Location: Vigo
County Status: Attainment for all criteria pollutants
Source Status: Part 70 Permit Program
Major Source, under PSD or Emission Offset Rules;
A.2 Emission Units and Pollution Control Equipment Summary [326 IAC 2-7-4(c)(3)]
[326 IAC 2-7-5(15)]
This stationary source consists of the following emission units and pollution control devices:
1. An acid gas removal/sulfur recovery unit, identified as unit 1A, using incineration as
control, and exhausting to stack EP-1.
2. A sour water treatment system, identified as unit 1B, using incineration as control, and
exhausting to stack EP-1.
3. A tank venting system, identified as unit 1C, using incineration as control, and
exhausting to stack EP-1.
4. A tail gas incinerator (manufactured by L.D. Duiker, model number XIV), identified as
unit 1, with a maximum heat input capacity of 52 million BTU per hour, which controls
emissions from units 1A, 1B, and 1C, and exhausting to stack EP-1.
5. A flare, identified as Unit 2, with a maximum pilot rate of 1.6 million BTU per hour, and
exhausting to stack EP-2.
6. Fugitive equipment leak emissions.
A.3 Specifically Regulated Insignificant Activities [326 IAC 2-7-1(21)] [326 IAC 2-7-4(c)]
[326 IAC 2-7-5(15)]
This stationary source does not currently have any insignificant activities, as defined in 326 IAC
2-7-1 (21) that have applicable requirements.
Page 1 of 10
Indiana Department of Environmental Management
Office of Air Management
and
Vigo county Air Pollution Control
Technical Support Document (TSD) for a for an Administrative Amendment
to a Part 70 Operating Permit
Source Background and Description
Source Name: Wabash River Energy, Ltd.
Source Location: 444 West Sandford Avenue, West Terre Haute, IN 47885
County: Vigo
SIC Code: 2869
Operation Permit No.: T167-7353-00091
Operation Permit Issuance Date: December 31, 1998
Administrative Amendment No.: AA 167-12145-00091
Permit Reviewer: Darren Woodward
Vigo County Air Pollution Control (VCAPC) has reviewed an Administrative Amendment
application from Wabash River Energy, Ltd. relating to the operation of a stationary gasification
system with the capabilities of operating on coal, petroleum coke, or a blend of coal and
petroleum coke. The system is rated at 367,000 pounds of syngas produced per hour including
gasification, high and low temperature heat recovery, sour waste treatment, oxygen unit, and a
flare.
History
On March 29, 2000, Wabash River Energy, Ltd. submitted an application to the VCAPC
requesting to add petroleum coke as an alternate fuel to their existing plant. Wabash River
Energy, Ltd. was issued a Part 70 permit on December 31, 1998. Wabash River Energy, Ltd.
supplied stack test data demonstrating that there would not be an increase in emissions when
using petroleum coke, or a blend of petroleum coke and coal, compared to coal only. They will be
significantly below their Part 70 permit limitations when using coal, petroleum coke, or a blend of
both. A more detailed explanation of equipment, operations, emissions, etc., can be found at the
end of this TSD in Appendix #1 and Appendix #2.
Source Definition
This power plant consists of a source with an on-site contractor:
(a) Cinergy - Wabash River, the primary operation, is located at 450 Bolton Road, West
Terre Haute, Indiana; and
(b) Wabash River Energy, Ltd., the supporting operation, is located at 444 West Sandford
Road, West Terre Haute, Indiana.
IDEM and VCAPC has determined that Plant 1, Cinergy - Wabash river, and Plant 2, Wabash
River Energy, Ltd. are under the common control of Cinergy - Wabash River. These two plants
are considered one source due to contractural control. Therefore, the term 鈥渟ource鈥? in the Part 70
documents refers to both Cinergy - Wabash River and Wabash River Energy, Ltd. as one source.
Separate Part 70 permits were issued to Cinergy - Wabash River and Wabash River Energy, Ltd.
solely for administrative purposes.
Wabash River Energy, Ltd. Page 2 of 10
Terre Haue, Indiana T167-12145-00091
Permit Reviewer: Darren Woodward
Existing Approvals
Wabash River Energy, Ltd. was issued a Part 70 Operating Permit (T167-7353-00091) on
December 31, 1998. Wabash River Energy, Ltd. has since received the following:
(a) First Administrative Amendment No.: 167-11851, issued on March 1, 2000.
Enforcement Issue
There are no enforcement actions pending.
Recommendation
The staff recommends to the Commissioner that the Administrative Amendment be approved.
This recommendation is based on the following facts and conditions:
Unless otherwise stated, information used in this review was derived from the application and
additional information submitted by the applicant.
An application for the purposes of this review was received on March 29, 2000. Additional
information was last received on May 23, 2000. Wabash River Energy, Ltd. waived the time clock
accountability due to the complex issues concerning petroleum coke.
Emission Calculations
The calculations (stack test data) submitted by the applicant have been verified and found to be
accurate and correct. The data is provided in Appendix A of this document, pages 1 through 14.
Potential To Emit
The potential emissions from the addition of petroleum coke, or a blend of petroleum coke and
coal, as an alternate fuel will be equal to or less than the potential emissions when using coal
only.
County Attainment Status
The source is located in Vigo County.
Pollutant Status
PM-10 Attainment
SO2 Maintenance
NO2 Attainment
Ozone Attainment
CO Attainment
Lead Attainment
(a) Volatile organic compounds (VOC) and oxides of nitrogen (NOx) are precursors for the
formation of ozone. Therefore, VOC and NOX emissions are considered when
evaluating the rule applicability relating to the ozone standards. Vigo County has been
designated as attainment or unclassifiable for ozone.
Federal Rule Applicability
Prevention of Significant Deterioration (PSD) and Emission Offset
The original construction was subject to Prevention of Significant Deterioration. Therefore,
BACT was required for both CO and H2SO4 emission points. This modification will be covered
under the original BACT requirements. This modification does not contain any new BACT
requirements.
Wabash River Energy, Ltd. Page 3 of 10
Terre Haue, Indiana T167-12145-00091
Permit Reviewer: Darren Woodward
State Rule Applicability
326 IAC 2-7-11 (Administrative permit amendments)
Pursuant to 326 IAC 2-7-11, the addition is considered an administrative permit amendment
because the revision does the following:
(6) Incorporates into a Part 70 permit a general permit issued under section 13 of this rule; and
(8) Revises descriptive information where the revision will not trigger a new applicable
requirement or violate a permit term
The addition of petroleum coke, or a petroleum coke and coal blend, as an alternate fuel will not
change the state rule(s) applicability. Therefore, state rule(s) applicable to Part 70 Permit 167-
7353-00091 will remain applicable.
Compliance Requirements
Permits issued under 326 IAC 2-7 are required to ensure that sources can demonstrate
compliance with applicable state and federal rules on a more or less continuous basis. All state
and federal rules contain compliance provisions, however, these provisions do not always fulfill
the requirement for a more or less continuous demonstration. When this occurs IDEM, OAM
and VCAPC, in conjunction with the source, must develop specific conditions to satisfy 326 IAC
2-7-5. As a result, compliance requirements are divided into two sections: Compliance
Determination Requirements and Compliance Monitoring Requirements.
Compliance Determination Requirements in permit Section D are those conditions that are found
more or less directly within state and federal rules and the violation of which serves as grounds
for enforcement action. If these conditions are not sufficient to demonstrate continuous
compliance, they will be supplemented with Compliance Monitoring Requirements, also in permit
Section D. Unlike Compliance Determination Requirements, failure to meet Compliance
Monitoring conditions would serve as a trigger for corrective actions and not grounds for
enforcement action. However, a violation in relation to a compliance monitoring condition will
arise through a source鈥檚 failure to take the appropriate corrective actions within a specific time
period.
Air Toxic Emissions
Indiana presently requests applicants to provide information on emissions of the 188 hazardous
air pollutants (HAPs) set out in the Clean Air Act Amendments of 1990. These pollutants are
either carcinogenic or otherwise considered toxic and are commonly used by industries. They
are listed as air toxics on the Office of Air Management (OAM) Part 70 Application Form GSD-
08.
(a) This source, including this modification, will emit levels of air toxics less than those
which constitute a major source according to Section 112 of the 1990 Clean Air Act
Amendments.
Conclusion
This stationary gasification system has the capabilities of operating on coal, petroleum coke, or a
blend of coal and petroleum coke. The system, rated at 367,000 pounds of syngas produced per
hour including gasification, high and low temperature heat recovery, sour waste treatment, oxygen
unit, and a flare, shall be subject to the conditions of the attached proposed Administrative
Amendment 167-12145-00091.
Wabash River Energy, Ltd. Page 4 of 10
Terre Haue, Indiana T167-12145-00091
Permit Reviewer: Darren Woodward
Background Appendix #1
Background Information for Wabash River Energy
PET Coke Project
General Background:
Wabash River Energy currently processes coal to produce a sweet syngas that is sold to Cinergy -
Wabash River Generating Station and burned in a Combustion Turbine to generate electricity. This
project was a joint venture between the company now called Wabash River Energy and PSI Energy. A
description provided by Wabash River Energy contained the following: 鈥淭he project is designed to
demonstrate a two stage, oxygen blown, entrained flow CGCC technology under the guidelines of the
Department of Energy鈥檚 (DOE) Clean Coal Technology (CCT) IV program. The expected life of the
project is 25 years. As part of the joint venture agreement, PSI owns and operates the coal handling
facilities, combined cycle power unit, and certain support facilities. Gasification Services, Inc. (GSI), a
Destec subsidiary, owns and operates the gasification plant and the air separation unit (ASU).鈥?
The original Construction Permit was issued in 2 parts on May 27, 1993. The first part (167-2609) was
issued to Wabash River Energy (Under the name Gasification Services, Inc.) and contained all the
provisions relating to the syngas production. The second part (167-2610) was issued to PSI Energy, Inc.
- Wabash River Generating Station (PSI and Cincinnati later merged to form Cinergy, but they still own
the name PSI Energy and do some work under that name) and contained all the electric generating
equipment and the coal and slag handling systems. These permits were issued at a time when Vigo
County was still considered nonattainment for SO2. A large part of the reason the permits were issued at
all was the removal of one of the Units from PSI鈥檚 existing generating station which provided a large
actual emission reduction. As a result the permits were only reviewed with regard to PSD for CO and
H2SO4 mist. In order to use those reductions, a condition was placed on Wabash River Energy that any
syngas produced in this process has to be sold to PSI Energy, Inc.
Here is a description of how the syngas production works:
鈥? The coal is made into a slurry by crushing it in a wet rod mill.
鈥? They utilize an Air Separation Unit (ASU) which is composed of an air compression system, an
air purification and cryogenic distillation system, an oxygen compression system and a nitrogen
storage and handling system. The ASU is utilized to take ambient air and split it into 95% pure
oxygen (dry) and liquid nitrogen.
鈥? The gasification system itself consists of 2 stages. The first stage is where the coal slurry and
oxygen are combined in partial combustion quantities (at about 2500 F and 400 psia). The
temperature is carefully controlled to keep it above the ash fusion point, which ensures good
slag removal. The resulting products from this stage are primarily hydrogen, carbon dioxide,
carbon monoxide and water vapor. Any sulfur in the coal is converted primarily to hydrogen
sulfide (H2S) with a portion converted to carbonyl sulfide (COS). The second stage takes this
hot syngas from the first stage and reacts it with more coal slurry. This reduces the temperature
a little (1900 F) and creates additional gas at a higher heating value.
鈥? The gas stream exiting the second stage of the gasification system is passed through a firetube
heat recovery boiler system which produces saturated high pressure steam. The steam is
utilized in power generation. The gas then passes through a barrier filter to remove particulate.
The particulate is recycled back into the first stage of the gasifier.
鈥? The carbonyl sulfide (COS) has to be converted before the Acid Gas Removal (AGR) system
because it is not removed as efficiently. This is accomplished using a conversion system. In
this system the COS is catalytically converted to hydrogen sulfide (H2S).
Wabash River Energy, Ltd. Page 5 of 10
Terre Haue, Indiana T167-12145-00091
Permit Reviewer: Darren Woodward
鈥? In the AGR system the H2S in the 鈥渟our鈥? syngas is selectively removed in an absorber that
utilizes methyl diethanol amine (MDEA) as the solvent. The 鈥渟weet鈥? syngas stream (because
the sulfur has been substantially reduced) is then processed to meet the combustion turbine鈥檚
input specifications. Those include moisture content and temperature. The H2S laden solvent
stream is processed in a reboiled stripper that generates a concentrated H2S steam and a lean
amine stream that is recycled back to the absorber.
鈥? The concentrated H2S stream (along with gasses from a few other streams) are treated in the
Sulfur Recovery Unit (SRU). In the SRU the H2S is stripped out using catalytic reactions and
converted to elemental sulfur. The elemental sulfur is sold as a by-product.
鈥? On the gasification side of the operation there are a few other processes that should be
mentioned. The tail gas incinerator handles whatever amount of tail gas from the sulfur recovery
system that can not be reconditioned and recycled back to the gasifier. It also handles the gas
streams from tank vents and air purge streams. The sour water treatment system removes
dissolved gases from the various water utilizing processes and sends the gas stream on to the
SRU. Most of the water is recycled and utilized again in the operation. The flare is utilized to
minimize emissions from the syngas. During normal production the only gas vented to the flare
is the natural gas fired pilot and purge gas streams. If the combustion turbine is for some
reason unable to accept syngas then some product may be sent to the flare as well. The cooling
tower is utilized to control water temperatures used throughout the plant.
鈥? Cinergy utilizes the sweet syngas in a combined cycle combustion turbine (CT). Exhaust gas
from the CT are used to produce steam in the heat recovery steam generator (HRSG). This
steam, along with steam from the syngas cooler, is used to repower the Unit 1 steam turbine.
This project commenced operation on November 30th, 1995. However, since that time it has never run
for an extended period of time. The problems with operation have been on both the syngas production
side and the power generation side. It is important to remember that both sides of the operation have to
be able to operate for the equipment under Wabash River Energy鈥檚 control to be utilized.
Sometime since the project was brought into operation PSI Energy bought out the remainder of the
contract with the gasification plant. Now the plant is not ensured of being able to sell the syngas unless
they can become cost competitive not with coal, but with natural gas prices. This allowed PSI Energy to
apply for (and receive) approval to switch the CT over to natural gas operation. It has also caused
Wabash River Energy to very aggressively search for ways to reduce the cost of producing syngas.
Operating Permit Status:
Both companies submitted separate Part 70 applications for their respective equipment. The Cinergy
permit has not yet been issued pending resolution of more of the issues that are common to all the electric
utilities. That Part 70 permit will include all of this equipment in addition to 5 other coal-fired utility boilers
and various supporting operations. The gasification side has already been issued a Part 70 permit [167-
7353-00091] on December 31, 1998. This issued Part 70 permit contained the following Source Definition
section in the TSD:
This power plant with gasification operations consists of a source with an on-site contractor:
(1) Plant 1, Cinergy - Wabash River, the primary operation, is located at 450 Bolton Road,
West Terre Haute, Indiana; and
(2) Plant 2, Gasification Services, the supporting operation, is located at 444 West Sandford
Road, West Terre Haute, Indiana.
IDEM and VCAPC has determined that Plant 1, Cinergy - Wabash River, and Plant 2, Gasification
Services are under the common control of Cinergy - Wabash River. These two plants are
considered one source due to contractural control. Therefore, the term 鈥渟ource鈥? in the Part 70
documents refers to both Cinergy - Wabash River and Gasification Services as one source.
Separate Part 70 permits will be issued to Cinergy - Wabash River and Gasification Services
solely for administrative purposes.
Wabash River Energy, Ltd. Page 6 of 10
Terre Haue, Indiana T167-12145-00091
Permit Reviewer: Darren Woodward
Since the Part 70 Permit was issued there has only been one Administrative Amendment issued [167-
11851-00091]. It was for the ownership change that changed the name to Wabash River Energy. They
have also received approval to conduct experimental trials utilizing PET Coke as the raw material instead
of coal.
On the power generation side there has been one modification of note recently. On August 24, 1999, PSI
Energy, Inc. applied for a modification to allow them to burn natural gas in the combustion turbine. In
order to operate the turbine without the gasification plant in operation they also needed to be able to
replace all the steam that currently comes from that process. So the application also included a 397.8
million BTU per hour natural gas fired boiler. The final part of the application was for approval to operate
the turbine in simple cycle mode sometimes instead of only in combined cycle mode. Along the way an
interim approval was issued by IDEM and the Significant Source Modification was issued by VCAPC on
January 27, 2000 [167-11328-00021]. This approval was not major for the purposes of a PSD review. It
was a synthetic minor through both netting and limitations. However, the applicability determination
relating to PSD on this approval may impact the current discussion. The following statement was included
in the TSD Appendix (on Page 5 of 6): 鈥淭he source has asked that for the old equipment (Combustion
Turbine) the allowable emission rates be used for the netting calculation, instead of the past actual
emissions. This is supported by the fact that the project is a DOE demonstration project and is not proven
technology. They simply have not operated up to capacity for any extended period of time and there is no
2 year period where actual emissions would be representative of normal operation.鈥? This petition was
agreed to by both IDEM and VCAPC and that methodology was utilized in the processing of the
modification. This is significant because during the 6 or so months since that determination there still has
not been enough operational time to show 鈥渘ormal鈥? operations over a 2 year period.
Current Permit Review:
The approval currently being reviewed would allow Wabash River Energy to utilize PET Coke as a raw
material in place of coal. The main reason they would like to do this is economics. Right now the
gasification technology is simply not cost competitive with natural gas. PET Coke could be a lower cost
raw material which would work well in the gasification system.
There are several questions which must be considered in order to process this application. The ones that
this department considers to be critical are the following.
1. What data should be used for the past emissions levels during the net emissions increase
calculations?
2. What is the direct effect on emission rates from the Wabash River Energy plant when the raw
material is switched to PET Coke?
3. Are there any indirect emission rate changes from the PSI Energy equipment as a result of the
raw material change?
Obviously the answers to these 3 questions could result in a whole slew of other questions and concerns,
but too many 鈥渨hat ifs鈥? or 鈥渋f thens鈥? at this stage would only further muck up the situation. This office has
some fairly strong opinions about all three of these issues. They are presented below.
First the determination of the past emissions data to use in the calculation must be accomplished.
Normally this would be the default of 鈥減ast actual鈥? emissions, but in this case past allowable may be more
appropriate. The basis for that would be a lack of 2 years of representative emission data. This option is
supported under 326 IAC 2-2-1(b)(2) which states that 鈥淭he department may presume that source-specific
allowable emissions for the unit are equivalent to the actual emissions of the unit.鈥? Also, 326 IAC 2-2-
1(b)(3) states 鈥淔or any emissions unit which has not yet begun normal operations on the particular date,
actual emissions shall equal the potential to emit of the unit on that date.鈥? Because of the experimental
nature of the project, in conjunction with some other unexpected problems, the gasifier has only operated
in short stretches, which is not the intended use for the process. There is emissions data, but not 2 years
worth to satisfy the normal procedure. This would seem to support the position of using the PTE or
allowable emission rates for the past number. Additionally, since this operation is very clearly tied to the
operation of the PSI Energy combustion turbine, and for Part 70 purposes they are considered one source
then the previous determination for PSI Energy that the operation had not yet reached 鈥渘ormal鈥? operation
would be another fact in support of this assertion.
Wabash River Energy, Ltd. Page 7 of 10
Terre Haue, Indiana T167-12145-00091
Permit Reviewer: Darren Woodward
Second the effect on PTE from the fuel switch must be determined. Wabash River Energy provided
summaries of a few stack tests to show the effect on emissions. The main pollutant which seems to be
under consideration is SO2. The SO2 emission rate from the stack test on coal was 14.64 pounds per
hour. The SO2 emission rate from the stack test on PET Coke was 31.58 pounds per hour. This appears
to indicate that the SO2 would increase, but that is not all the data available so a decision should not yet be
made. The allowable SO2 emission rate is 527 pounds per hour, so even though the coal had lower
results the operation was well within its allowable emissions rate in either case. The coal rate was 2.78%
of allowable and the PET Coke rate was 5.99% of the allowable, so clearly the system was working very
well during both tests, if marginally better during the coal test. Another factor that needs to be discussed
is how much weight do you place on a single test? Clearly an average of three one-hour samples is
important, but not so much that we would be expected to go back and automatically redo all the PTE
calculations. Wabash River Energy has also provided hour by hour SO2 emission rate information from
January 1, 1996 through December 31, 1999. Now there are a large number of these hours that are
marked off as DOWN, but there are enough days to see that the day the stack test was run on PET Coke
is not higher than all the days on coal. In fact (without actually doing a statistical analysis) the PET Coke
runs appear to be fairly normal as far as SO2 emission rates. This office is of the opinion that these 2
main points (how much below the allowable both tests were and the review of CEM data) indicate that
there will not be an increase in SO2 emissions from the use of PET Coke as the raw material instead of
coal.
Third the effect on combustion turbine emissions must be analyzed. The following table reiterates data
which was in the draft final report to the DOE from Wabash River Energy. It covers the syngas
composition relative to the raw material used to make it.
Component Typical Coal Petroleum Coke
Nitrogen, (N2), Vol% 1.9 1.9
Argon (Ar), Vol% 0.6 0.6
Carbon Dioxide (CO2), Vol% 15.8 15.4
Carbon Monoxide (CO), Vol% 45.3 48.6
Hydrogen (H2), Vol% 34.4 33.2
Methane (CH4), Vol% 1.9 0.5
Total Sulfur, ppmv 68 69
Higher Heating Value, (HHV) BTU/scf 277 268
This shows that the resulting syngas has very much the same composition as the typical coal based syngas.
That would be a strong indication that the emission rates from the combustion turbine would not be affected
by the raw material conversion.
Wabash River Energy, Ltd. Page 8 of 10
Terre Haue, Indiana T167-12145-00091
Permit Reviewer: Darren Woodward
SUMMARY
In summary VCAPC would like to state that we feel the following with regard to this application:
鈥? The most appropriate number to use for past emissions is the PTE because normal operation has
not yet been reached.
鈥? There would be no increase above the past allowable (PTE) because of the addition of PET Coke as
an allowed raw material.
鈥? There would not be any collateral increases in combustion turbine emissions due to the additional
raw material.
鈥? Therefore, the application would be able to be processed as an administrative amendment like the
draft that was already send over for IDEM review. Most likely with the addition of much of the
background and reasoning provided in this document.
Wabash River Energy, Ltd. Page 9 of 10
Terre Haue, Indiana T167-12145-00091
Permit Reviewer: Darren Woodward
Background Appendix #2
Background Information for Wabash River Energy
PET Coke Project
The main issue of contention is the determination of what numbers to use for past emissions. The baseline has
not been set and therefore, pursuant to the definitions found in 326 IAC 2-2-1(b)(3), the past actual emissions
would be estimated by the potential to emit for the operation. This determination would be consistent with the
one made for a modification on the Cinergy side of the same operation in a Significant Source Modification that
was issued on January 27, 2000 (167-11328-00021). This can also be substantiated by looking at production
records which are already available. The total annual production of Syngas per year from 1996 to 1999 in
MMBTU increased from just under 2500000 MMBTU for 1996 to about 6000000 MMBTU for 1997 and topped
out at about 8000000 MMBTU for 1998. In 1999 there was a failure within the Combustion Turbine (on the
Cinergy side) that brought the whole system down for a significant period of time. That is why the 1999
production drops down to just over 5000000 MMBTU. The Combustion Turbine failure occurred early in March
of 1999 and the plant was not brought back on line until sometime in June of the same year. The production
levels reached in September of 1999 represent the highest monthly syngas production the plant has ever
attained.
From this information the following conclusions can be reached: first, this operation is an emerging technology, it
is not something that has previously been proven to work on the scale of this plant. The continual growth in
production from 1996 through 1998, combined with the fact that they set a production record in September of
1999 (just 3 months after coming back online following the Combustion Turbine failure) indicates two things.
They have in fact been diligently working to make the process reliable. And, they also have proven that the
technology can work on this scale. This further supports our contention that the addition of PET Coke as an
additional raw material is based on economic reasons, not because the project was a failure in any way before.
The second conclusion was that the baseline should not be considered to be set yet for this operation. Looking
at the definition of Actual Emission in the PSD requirements it wants the average rate at which the unit actually
emitted during a two year period prior to the application. But it goes further to say that the emissions should be
representative of normal source operation. While there is emission data for more than a two year period, there
is not that much time available that represents normal operation. This is supported by the continued increase in
production from the time it was first operated and the relatively recent production record To us this is the perfect
example of the situation that results in using the unit鈥檚 potential to emit for the 鈥減ast actual鈥漰art of the net
emission change determination.
After the determination of the appropriate 鈥減ast鈥? emission level the next logical step is to determine the effect
PET Coke has on emissions from the plant鈥檚 operation. There will not be any increase in potential emissions
(from the past potential) as a result of this modification. At a glance, the stack test data that had initially been
supplied to IDEM as background did not support a decrease in emissions. Very often stack test data from a
particular operation would be the best available information on how that operation works. Clearly having site
specific data would be preferable to some industry wide emission factor. It might even be better than some data
provided by manufacturer鈥檚 since it represents 1 piece of equipment instead of representing how that type of
equipment is supposed to act. However, in this case it is imperative to remember that the two stack tests that
were presented only really represent an average of 3 specific hours of operation in each case. This plant is
required to have an SO2 CEMS on the tail gas incinerator stack, and this monitor has been (and is continually
checked to maintain this) RATA certified under the Part 75 requirements. This monitor data should be
considered as an even more reliable measure of plant operation than the stack tests were. The most obvious
reason being that the operation itself has variable emissions and the CEMS data can show trends that the stack
test data is not able to due to an extremely limited scope of time covered.
Wabash River Energy, Ltd. Page 10 of 10
Terre Haue, Indiana T167-12145-00091
Permit Reviewer: Darren Woodward
These results were obtained under certain operating conditions and therefore may not represent the potential to
emit of the operation. However, the data is good for comparing coal and PET Coke as a feedstock and then
extrapolating that comparison to the effect on potential to emit. Monthly data from 1997 through 1999 includes
hours of operation for each month, the average SO2 emission rate in pounds per hour for the month, the
standard deviation in the SO2 emission data, and the average ppm concentration of sulfur in the syngas being
produced during the month. Some months the standard deviation is significantly above the average SO2
emission rate for the entire month. That is a very good indicator that the emission rates are in fact quite variable.
Also of importance is the fact that the standard deviations have a downward trend from the early months of 1997
to the ending months of 1999. That is a strong indication that some of the variability is being reduced as the
company gets more experience with the equipment and has better control of the entire process. Just as the
standard deviations are dropping with time the average monthly emission rates are also dropping. Again that is
probably attributable to a better understanding of the process and learning from experience. But, even though
the process variability is being reduced, it is still significant and this suggests that taking the stack test results out
of context is risky.
In order to more completely understand what the stack test results really mean some of the CEMS data that
covers those time periods should be studied. The first of the two PET Coke trials occurred in November of 1997.
This trial was the one requested by IDEM when the issue of utilizing it as an alternate fuel was first being
discussed. The plant operated on PET Coke as the raw material from November 17th through November 27th.
The highest day during the PET Coke trial was the first day they were on that raw material. They had an
average emission rate of 125.17 pounds per hour for that day. The next highest was only 81.43 pounds per hour
for the daily average. Of the 11 days during the month that coal was the raw material, 4 were above the highest
PET Coke day and 6 (or over 陆) were above the second highest daily average. The average of the 11 days on
PET Coke was 43.64 pounds per hour which was well below the monthly average for November of 79.49
pounds per hour. The days when Pet Coke was the raw material being utilized, the emissions were lower
compared to that of coal. The second PET Coke trial occurred in September of 1999. While Wabash River
Energy is utilizing PET Coke as the raw material they have to increase their recirculation flow rates as well as
the flow rate to the tail gas incinerator. This is because the syngas that is produced utilizing PET Coke as the
raw material has a higher heating value per volume than the syngas produced from coal. This higher heating
value per volume means that the volume (and mass) of syngas fed to the Combustion Turbine for any specific
operation rate drops when they switch to PET Coke based syngas. As a result of this reduction in flow to the
Combustion Turbine the SO2 emissions from syngas combustion can actually drop even when the sulfur
concentration of the syngas remains the same. The highest flowrates through the tail gas incinerator occurred
on the days when PET Coke was the feed stock, but those same three days also had the lowest total emission
rates of SO2. The month of October 1998 was when the coal stack testing was performed. While the stack test
data showed that the coal test had a higher emission rate than the PET Coke test did, that position is not
supported when you try to make a broader comparison. The three daily averages on PET Coke in September of
1999 were 15.42, 22.41, and 28.08 pounds per hour respectively. The averages on the two days before and the
day after were 12.10, 13.61, and 23.72 pounds per hour which would appear to be slightly lower. However, the
total plant emissions during the time period are significantly lower on the PET Coke days. It should be noted that
both the coal emission rates and the PET Coke emission rates from this time period are substantially lower than
the rates were during the November of 1997 testing.
In conclusion, the addition of PET Coke and PET Coke/coal blends as allowable raw materials for this
processing operation will not increase the total emissions from the plant. There might be a reduction even, but
the data is not conclusive enough to support that at this time. If these two interpretations are correct then there
would not be any change in potential emissions from the project and it could be covered in an Administrative
Amendment as proposed.
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