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Revolution Fuels Coal-to-Liquid Facility
Revolutions Fuel requested a permit from the Division of Air Quality (DAQ) for a new coal-to-liquids facility near Wellington, Utah. The proposed facility is in an attainment area for all criteria pollutants and is classified as a minor source. Its operations will include coal handling, coal gasification, ash handling, syngas treatment, and product upgrading. The facility will produce jet fuel, diesel fuel, liquefied petroleum gas (LPG), and naptha.
DAQ signed the Approval Order for the new facility on June 24, 2016.
DAQ made the Intent to Approve (ITA) available for public comment from November 26, 2015, to December 26, 2015. On January 6, 2016, DAQ held a public hearing at Wellington Elementary School to take oral comments on the ITA. Over 200 people attended the hearing, including DAQ staff, with 38 people providing oral comments on the proposed permit. DAQ subsequently extended the public comment period to January 10, 2016, to allow for additional public comments following the hearing. DAQ considered and evaluated each comment before final issuance of the Approval Order.
DAQ made the following changes to the Approval Order (AO) based on public comments it received on the proposed facility:
- Limitation on startups and shutdowns.
- Requirements for facility-wide Leak Detection and Repair (LDAR) program.
- Removal of redundant flare opacity conditions
Coal-to-liquid fuel technology has been in existence since the 1920s. The process, known as Fischer-Tropsch (FT) Synthesis, uses gasification to convert carbon materials to carbon monoxide and a hydrogen-rich synthetic gas. This synthesis gas, or syngas, is fed into an FT reactor that condenses the gas over a catalyst and converts it to wax and liquid products that can be refined into a variety of synthetic fuels.
Under the proposed permit, coal will be delivered to the facility and stored, then transferred to a crusher by conveyor. The crushed coal will be sent to a pyrolysis and gasification system. Carbon material that is not gasified will be removed and handled in the ash handling system. Syngas produced from the gasification system will be scrubbed to remove contaminants, pressurized, and sent for further processing to remove additional contaminants such as carbon dioxide and sulfur. After passing through the FT reactor, the wax and hydrocarbon condensate will be upgraded to transportation fuels.
The facility will process the following quantities of fuels (in barrels per day (bpd) :
- Liquefied petroleum gas: 104 bpd
- Naphtha: 262 bpd
- Diesel: 573 bpd
- Jet fuel: 556 bpd
- Off-specification diesel and jet fuel: 370 bpd
Best Available Control Technology (BACT)
A Best Available Control Technology (BACT) evaluation provides information on the feasibility of control options for nitrogen oxides, particulates, carbon monoxide, and volatile organic compound emissions. The BACT analyses for the coal-to-liquids facility covers control operations for the following processes:
- Nitrogen oxides (NOx), carbon monoxide (CO), and volatile organic compound (VOC) emissions from combustion devices
- Fugitive PM10/PM2.5 emissions for coal and ash material handling operations
A BACT review was conducted for the following facility operations and process components on the pollutant emissions of interest noted below:
- NOX on the Gasification Burner System
- NOX on the Auxiliary Boiler
- NOX on the Natural Gas Fired Process Heaters
- NOX on the Internal Combustion Engines
- PM10/PM2.5 Emissions from Coal Handling
Review of the selected control technologies showed that BACT requirements were met.
Modeling for NO2, PM10, and PM2.5 Emissions
Increases in individual criteria emissions triggered a requirement to conduct modeling for three pollutants: nitrogen dioxide (NO2), PM10, and PM2.5. The following table provides a comparison of the predicted emissions from the proposed facility and the predicted emissions plus background (total) with the health-based National Ambient Air Quality Standards (NAAQS).
|Pollutant||Average||Predicted Project Emissions
(predicted project emissions plus background)
|NAAQS (ug/m3)||Percent of NAAQS|
|Nitrogen Dioxide (NO2)||1-hour||84.0||148.0||188||78.7%|
|Nitrogen Dioxide (NO2)||Annual||2.9||22.9||100||22.9%|
The predicted total concentrations for each pollutant are less than their respective NAAQS. The modeling demonstrated that emissions from the proposed project combined with background emissions from other sources will not exceed federal health-based air quality standards.
The following table shows the proposed potential-to-emit emissions (PTE) for this facility.
(tons per year)
|Particulate Matter (PM) 10||20.2|
|Particulate Matter (PM) 2.5||20.2|
|Nitrogen Oxides (NOx)||23.3|
|Carbon Monoxide (CO)||83.8|
|Volatile Organic Compounds (VOCs)||9.2|
|Sulfur Dioxide (SO2)||1.9|
|Combined Hazardous Air Pollutants (HAPs)||8.9|
|Carbon Dioxide Equivalent (CO2e)||295,445|