This memorandum summarizes certain information relevant to several requirements in the fihal Avenal

Energy Project (AEP) PSD permit that differ from those in the proposed permit. This informtionpertams to the following topics

• Auxiliary Boiler — PM and PM1 0 hourly emissions rate

• Turbines — CO emission limit• Turbines — CO hourly emissions rate in lb/hr• Turbines — Limits for startup and shutdown duration

Auxiliary Boiler — PM / PM1O hourly emissions rate

We inadvertently omitted emissions limits for this emission unit in the proposed permit. We made anadministrative correction by adding a PWPM1 0 emissions limit of 0.0034 grains/dscf (gr/dscr) for the

unit, consistent with the permit application in the final permit. We have retained the requirement tosource test the auxiliary boiler through an initial performance test and revised the permit language to

require testing every five years following the initial performance test, rather than annually. The

commensurate emission limit in gr/dscf for the initial and subsequent testing was calculated to be 0.0034r/dscf based on the following application information and the F-Factor methodology (40 CFR Part 60,Appendix A, Method 19). (Assume all PM10=PM)

Given: Table 6.2-1.2 (Appendix -1), liary Biler Specifications

Boiler, MMBtu/hr 37 4

PM10,lb/MMBtu 0.0050

Conversion factor and references: 7,000 grains/lb

F-Factor (natural gas) = 8,710 dscf tMMBtu

%O2=3%

Calculation methodology:

(1bPM10/MMBtu) / (F-factor) / (20.9 / (20.9 - %O2)) * 7,000 grains/lb = r PM/dscf

Where

(0.0050) / (8,710) / (20.9 / (20.9-3)) * 7,000 = 0.0034 ar PMçf

Turbines — CO emission limitThe Kleen Energy facility was cited in public comments EPA received in 2009 with respect to CO

emission limits for the AEP. On Thursday, May 12, 2011, 1 spoke with representatives of the ConnecticutDepartment of Environmental Protection (DEP) regarding the status of the Kleen Energy facility; i.e.,

0526EPA_AVENAL-MEMO TO FILE PERMIT REVN_SR.DOC
• Mr. Corsino — The CO emission limits remain the same as permitted; Mr. Corsino forwarded a

copy ofthe permits. Unit #1 began commercial operations on May 3, 2011 (after first fire on

April 13, 2011). Unit #2 had not yet begun commercial operations; however, it did undergo first

fireonApril21,2011.

• Mr. Anderson— Neither Unit #1 nor Unit #2 was scheduled to be source tested. Mr. Anderson

estimated that it would not be until Fall 2011 before source test results would be available,

presuming that source testing would begin at some time during the Simmer of 201 1 ‘

Turbines — CO hourly emissions rate in lb/hr

We have added a CO emission limit (after a demonstration period) of 1.5 pprvd @ 15% 02 for each gas

turbine when operating without duct firing. The commensurate emission limit in pounds per hour (lb/hr)

was calculated to be 6.27 lb/hr based on the following application information and the F-Factor

methodology (40 CFR Part 60, Appendix A, Method 19): j

Given: Turbine, MMBtu!hr (HFIV), without duct burner = 1,856.3 MMBtu/hr

Concentration limit = 1.5 ppm CO @ 15% 02 by volume (dry)

(or 1.5 ppmvd CO @ 15% 02)

Conversion factor and references: Molecular weight (MWt), NO2 46 Ib/Ib-mol

Molecular weight (MWt), CO 28 lb/lb-mol

J Convert, ppm N0 (for NO2) 1.194 x I OE-07 lb/scf N0

F-Factor (natural gas) 8,710 dscV’MMBtu

Calculation methodology: .

(CO ppmvd) ‘ (F-factor) * (Convert) * (CO MWt / NO2 MWt) *(209 / (20.9 - %02))

[=1 lb/MMBtu * (Turbine, MMBtuIhr)

[=1 lb/hr

where

(1.5) * (8,710) * (1.194 x IOE-07) * (28 / 46) * (20.9 / (20.9-1 5)) * (1,856.3)

=

- 6.27 lb/hr of CO

Turbines limits for startup and shutdown duration

I reviewed the PSD permits recently issued by Region 9 for natural gas-fired combined cycle power

plants similar to the AEP to identify the duration of startup and shutdown limits (in minutes or hours).

Other permits included separate startup duration times depending on whether the startup was

characterized as a cold, warm, or hot start; several plants had a shutdown limit of 30 minutes. After

review of this information and follow-up with the permit applicant, I concluded that the Colusa

Generating Station was the project most similar to the Avênal Energy Project. The startup duration in the

O52BEPAAVENAL-MEMO TO FILE_PERMIT REVNSR.DOC
O526EPAAVENAL-MEMO TO FILE_PERMIT REVNSR.DOC

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