January 7, 2019 - The Illinois Environmental Protection Agency (IEPA) recently issued the final New Source Review (NSR) air permit to CPV Three Rivers, LLC, authorizing the construction and initial operation of the CPV Three Rivers Energy Center. The proposed new 1,200-MW dual-fuel-fired combined-cycle power plant will be located in northeast Illinois. Sargent & Lundy was instrumental in helping CPV achieve important project development milestones by preparing the NSR permit application and working with federal and state regulatory authorities throughout the permit review process.
NSR permitting is a complex process that requires rigorous analysis of numerous technical and environmental aspects of a project. Beyond the typical permitting challenges encountered on such a major project, the proposed location of the CPV Three Rivers Energy Center presented additional and unique issues. The proposed power plant is to be located within an ozone nonattainment area, Chicago-Naperville, Illinois; thus, the permit application had to address both the Prevention of Significant Deterioration (PSD) requirements and the nonattainment area NSR regulations. Detailed evaluations of potential impacts to federal and state protected species and their critical habitat were also required.
Sargent & Lundy’s solutions to overcome the challenges presented by the proposed location of the power plant focused on working collaboratively with CPV’s project team, as well as with state and federal regulators, to develop technical and environmental inputs to the permit application and to integrate environmental limitations into the facility’s design. Close collaboration between Sargent & Lundy and CPV led to a comprehensive, complete, and technically accurate permit application and minimal post-submittal questions and information requests from the reviewing agencies.
Sargent & Lundy applied its comprehensive in-house technical expertise to prepare all components of the permit application and supporting documentation, including:
- Combustion turbine operating parameters;
- Emission calculations for all anticipated modes of operation (i.e., full-load, supplemental duct firing, startup and shutdown, and load-cycling);
- Best available control technology (BACT) analysis for air pollutants subject to PSD permitting;
- Lowest achievable emission rate (LAER) evaluation for air pollutants subject to nonattainment area NSR;
- Analysis of alternative electricity generating technologies; and
- Comprehensive ambient air quality impact modeling to demonstrate compliance with all applicable National Ambient Air Quality Standards (NAAQS).
At the request of the permitting agency, Sargent & Lundy prepared an expanded BACT analysis for the control of the combined-cycle unit’s greenhouse gas (GHG) emissions. The evaluation included an analysis of the technical feasibility and cost-effectiveness of potentially available carbon dioxide (CO2) capture and sequestration technologies, as well as an evaluation of the technical feasibility of integrating renewable generating technologies (i.e., wind, solar, and energy storage) into the project design. Sargent & Lundy drew on its extensive experience with all generating technologies and used in-house subject-matter specialists to prepare these evaluations and integrate the study results into the permit application.
Sargent & Lundy’s environmental specialists worked directly with the U.S. Environmental Protection Agency (EPA) and Illinois Department of Natural Resources (IDNR) to coordinate the required threatened and endangered species consultations. Sargent & Lundy’s environmental specialists prepared a comprehensive evaluation of potential impacts, including nitrate/sulfate deposition modeling and assessment of critical deposition thresholds to the tallgrass prairie ecosystem. Sargent & Lundy was able to demonstrate to the satisfaction of the EPA, U.S. Fish and Wildlife Service, and IDNR that potential impacts of the proposed power plant on species of concern and their natural habitats would be negligible.
The collaborative working relationship between Sargent & Lundy engineers and environmental specialists and CPV’s project team resulted in a permit that provides the operating flexibility needed to deliver baseload power or respond to market-driven fluctuations in energy supply and demand, and includes emission limits achievable under all anticipated operating scenarios. Public review of the draft permit was completed with minimal comment, and the final permit for the project was issued just 60 days after the draft permit. The final permit authorizes CPV to commence construction of the facility once all other project development milestones are met.
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