SENECA ENERGY LFGTE FACILITY

SENECA ENERGY II LLC
2999 JUDGE RD
OAKFIELD, NY 14125

SENECA ENERGY LFGTE FACILITY
2053 ST RT 414|RENEWABLE RESOURCES PARK
SENECA FALLS, NY 13148

8-4532-00075/00029

Article 19 Air Title V Facility

SENECA FALLS, SENECA COUNTY

The Department has prepared a draft permit and has made a tentative determination, subject to public comment or other information, to approve a renewal and modification of the Title V permit for the Seneca Energy Landfill Gas to Energy (LFGTE) and High BTU facility.

Seneca Energy Landfill Gas to Energy (LFGTE) facility is an existing 17.6 Mega Watt Landfill Gas to Energy Facility which combusts landfill gas purchased from the Seneca Meadows Landfill (a separately owned facility). Emission Unit (EU) 3-STAGE currently includes fourteen CAT G3516 IC Engines and four CAT G3520 IC engines that are fueled by the landfill gas which produces electricity for sale. The facility also includes a 6,000 cubic feet per minute (scfm) High BTU Plant, EU 1-BTUPL, which beneficially recovers the methane portion of landfill gas thereby generating renewable natural gas (RNG) which is sent to the natural gas pipeline running along Route 414. Waste gas from the refining process is controlled by a 3600 scfm thermal oxidizer. Off-spec gas from the treatment system during upset conditions is combusted in the 3300 scfm open flare.

REN 3 includes a major modification which is the construction and operation of a second High BTU facility (EU 2-BTUPL) which will process 9600 scfm of landfill gas. Similar to EU 1-BTUPL, the new High BTU unit will recover the methane portion of the landfill gas to generate RNG which will be sent to the natural gas pipeline running along Route 414. EU 2-BTUPL will also include a 9600 scfm open flare (5KFLR) and a 4800 scfm thermal oxidizer (5KOXD). The facility will also be adding an additional emergency generator.

As part of the construction of the new High BTU unit, four of the CAT 3516 IC Engines and the four CAT 3520 IC engines in EU 3-STAGE (8 of the 18 engines) will be converted from being fueled by landfill gas to natural gas to power the High BTU units. The engine stacks will each have an oxidation catalyst. The oxidation catalysts will allow for the reduction in engine exhaust emissions for Carbon Monoxide (93% reduction), Formaldehyde (80% reduction) and VOCs (75% reduction). The ten remaining CAT 3516 IC engines will be permanently shut down and removed from the facility within one year of start-up of EU 2-BTUPL.  

Additionally, the REN 3 permit incorporates two Operational Flexibility approvals including the addition of a fire pump engine, the elimination of a 2,000 scfm enclosed flare and modification of existing thermal oxidizer (3KOXD).  In addition, the permit includes a minor modification which was the addition of a 3300 scfm open flare (3KFLR) for limited hours for off spec gas.

The applicant was required to do a Screening Analysis to verify the facility remains in compliance with Part 212 AGCs and SGCs and National Ambient Air Quality Standards. 

The REN 3 permit maintains conditions for the facility which were in the REN 2 permit. These involve compliance with 6NYCRR Part 231-6 and Part 231-8 Modification to Existing Major Facilities with the existing limits for Oxides of Nitrogen (214.4 tons per year) and Carbon Monoxide (522.9 tons per year) located under 6NYCRR Part 200.6 for EU 1-BTUPL and EU 3-STAGE (engines running on landfill gas) as well as other miscellaneous sources during the transition period.  The transition period consists of the construction time for the second High BTU unit and up to one year of operation upon commencement of operation of the second High BTU unit. These limits may not exceed one year after commencement of operation of the second High BTU unit. During this transition period, the facility must continue to comply with 6 NYCRR Part 227-2 NOx Reasonably Available Control Technology (RACT) Limits for engines firing on landfill gas.

No later than one year of commencement of operation of 2-BTUPL, a new limit for NOx will be established under 6NYCRR Part 201-7 for less than 99.9 tons per year. This limit caps the facility out of 6NYCRR Part 227 NOx RACT. Once the second High BTU plant is in operation, the facility will be non-major for carbon monoxide in terms of 6NYCRR Part 231; it will be less than 250 tons/year and will not require a CO limit.  The facility will be greater than 100 tons per year CO, thus they will be subject to Title V, but not 6NYCRR Part 231. 

The draft permit does not retain the cap for carbon dioxide equivalents on emission unit 1-BTUPL due to the Supreme Court decision in “Utility Air Regulatory Group vs. EPA (2014)”. 

Pursuant to the requirements of Sections 7(2) and 7(3) of the Climate Leadership and Community Protection Act (CLCPA), the Department has requested and received information regarding the project’s consistency with the CLCPA.

In accordance with 6NYCRR Parts 621.7(b)(9) and 201-6.3(c), the Administrator of the United States Environmental Protection Agency (USEPA) has the authority to bar issuance of any Title V Facility Permit if it is determined not to be in compliance with applicable requirements of the Clean Air Act or 6NYCRR Part 201.

Persons wishing to inspect the subject Title V files, including the application with all relevant supporting materials, the draft permit, and all other materials available to the DEC (the "permitting authority") that are relevant to this permitting decision should contact the DEC representative listed below. The Draft Permit and Permit Review Report may be viewed and printed from the Department web site at: Air Permits and Registrations.

DEC will evaluate the application and the comments received on it to determine whether to hold a public hearing. Comments and requests for a public hearing should be in writing and addressed to the Department representative listed below. A copy of the Department's permit hearing procedures is available upon request or on the Department web site at: http://www.dec.ny.gov/permits/6234.html.

Filed application documents, and Department draft permits where applicable, are available for inspection during normal business hours at the address of the contact person.  To ensure timely service at the time of inspection, it is recommended that an appointment be made with the contact person.

Project is an Unlisted Action and will not have a significant impact on the environment. A Negative Declaration is on file. A coordinated review was performed.

SEQR Lead Agency: Seneca Falls Town Board

Evaluation using a Structural-Archaeological Assessment Form or other information has concluded that the proposed activity will not impact registered, eligible or inventoried archaeological sites or historic structures.

This project is not located in a Coastal Management area and is not subject to the Waterfront Revitalization and Coastal Resources Act.

It has been determined that the proposed action is not subject to CP-29.

Comments on this project must be submitted in writing to the Contact Person no later than Mar 31, 2023.