Abstract: . . .  project should be terminated. Q4 2003 CVBP terminates. Equipment dismantled. decide to terminate decide to continue choose PSD revision process now IDNR amends Title V permit to add switchgrass as an approved alternative fuel. March 1, 2005 Commercial switchgrass cofiring begins at 12.5 tph. 25 tph operation begins by end-of-2005. April 2005 Paths that follow Cofire Test 2, given emissions test outcomes other than the best possible outcome. Page 20 20 If at any point these paths open, the process jumps to here. Construction permits still required. PSD Variance that would allow commercial operation (25 tph) Regulatory action or decision Outcome of cofiring test Action or decision by Alliant or CVBP = = = issues (perhaps < 25 tph) denies Alliant Energy's Proposed Air Permitting Plan for the Chariton Valley Biomass Project (CVBP) Go to E Cofire test 3 data indicate that emissions from commercial operations will not exceed PSD thresholds. IDNR issues or denies PSD revision request. IDNR issues or denies construction permit request. October 1, 2005 Commercial switchgrass cofiring begins at 12.5 tph. 25 tph operation begins in Q3 2006. Q1 2006 Cofire test 3 data indicate that emissions from commercial operations could potentially or definitely would exceed PSD thresholds. Cofire test 2 data indicate that cofire test 3 emissions would not exceed PSD thresholds, but emissions from commercial operations might. CVBP decided to proceed directly to cofire test 3 instead of PSD revision (risks . . .
. . .  translates to a 36-ton increase in NOx emissions (which is less than the 40 tpy PSD threshold). Conclusion: It does not appear that NOx emissions during Cofire Test 2 would exceed the PSD threshold (40 tpy). However, given the limitations of Cofire Test 1, this cannot be said with Page 26 26 100% certainty. Therefore, the CVBP suggests that it keep a running total of NOx emissions during Cofire Test 2, agreeing that the IDNR may terminate Cofire Test 2 prematurely if the NOx PSD threshold is in danger of being exceeded. SO 2 Emissions: Based on the January 2001 CEM data, daily average SO 2 emissions during cofiring were 0.85% lower than during coal-only operation. Cofiring did not occur around the clock (and the switchgrass feed rate varied from 5 tph to 16.5 tph) - given the limitations of the Cofire Test 1 data set, it is not possible to correlate SO 2 emissions increases or decreases with the cofiring rate. Since S emissions in cofiring applications are typically reduced in proportion to the displaced feed S (switchgrass has 68% less S than PRB coal per MMBTU; therefore, for every 1% heat input supplied by switchgrass, SO 2 emissions would be expected to decrease by 0.68%). 1 The observed SO 2 emissions reductions during Cofire Test 1, while small, are expected. For 2000 and 2001, the coal-only average SO 2 emissions factor at OGS was 0.659 lb/MMBTU. A 0.85% decrease would be 0.0056 lb/ MMBTU. Assuming a heat rate of 10,200 BTU/kWh during cofiring (and using the same calculation . . .
--3000,2,750,3162,60065