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FUTURE NATURAL GAS POWER PRODUCTION RELIABILITY AND DEP PERMITTING INFLUENCES. Massachusetts Electric Restructuring Roundtable. 16 February 2001 Edward P. Kunce Deputy Commissioner Department of Environmental Protection. FUEL AS BACT. NESCAUM & EPA Guidance Pollution Prevention theme
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FUTURE NATURAL GAS POWER PRODUCTION RELIABILITY AND DEP PERMITTING INFLUENCES Massachusetts Electric Restructuring Roundtable 16 February 2001 Edward P. Kunce Deputy Commissioner Department of Environmental Protection
FUEL AS BACT • NESCAUM & EPA Guidance • Pollution Prevention theme • Examples of Application • low sulfur fuels • consider NG as “Top” BACT • more NG use at dual fuel facilities • Typical Conditions • 11/1 or 10/2 (NG/Oil months) • set by NG availability • set by “$/ton” impact
SINGLE FUEL (NG) FACILITIES • NOT driven by DEP permit process • More common at “greenfield” facilities • Secure NG contract available • Avoid fuel oil handling and storage costs • NIMBY’s influence??
RELATED PERMIT ISSUES • Handling Emergency Situations • Use of Emergency Regulations • New Boston Station Model (ISO driven emergency condition) • Clean Coal & Bio Mass Can Be Permitted • subject to Top/Down BACT • NG not Top BACT • Can EFSB or ISO Require Dual Fuel Capability? Not a DEP Role • NG Pipeline Permitting Issues e.g. Hubline Project • Study Suggests Only One Problem Scenario in Ten Caused by Permit Limitations
BOTTOM LINE • DEP will work with Agencies to “Keep The Lights On”