AIR PERMITS OFFICE 

Avenal Energy Project (SJ 08-01) 

DATE: May 26, 2011 

TO: Avenal Energy Project PSD Permit Decision Project File 

FROM: Shirley Rivera (A~R-3) ~\\rc~--Z=

SUBJECT: Final Permit Requirements - Selected Background Information 

;'.ift:::::? 

This memorandum summarizes certain information relevant to several requirements' the final Avenal
 

Energy Project (AEP) PSD permit that differ from those in the proposed permit. T'
 

pertains to the following topics:
 

• Auxiliary Boiler - PM and PM 10 hourly emissions rate 

• Turbines - CO emission limit 

• Turbines - CO hourly emissions rate in Ib/hr 

• Turbines - Limits for startup and shutdown duration 

forma' 

Auxiliary Boiler - PM / PMIO hourly emissions rate 

We inadvertently omitted emissions limits for this emission proposed permit. We made an 

administrative correction by adding· a PM/PM10 emiss!.Qns I 0;0034 grains/dscf(gr/dscr) for the 

unit, consistent with the permit application in the finaFpe~~it. / e have retained the requirement to 

source test the auxiliary boiler through an initial performancy;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 in~tial and subsequent testing was calculated to be 0.0034 

gr/dscfbased on the following application~rJorma,~on and the F-Factor methodology (40 CFR Part 60, 

Appendix A, Method 19). (Assume all PMf()70~M)

7,000 grains/lb 

F-Factor (natural gas) = 8,710 dscflMMBtu 

%02 =3% 

hodology: 

IO/MMBtu) / (F-factor) / (20.9 / (20.9 - %02)) * 7,000 grains/lb = gr PMIO/dscf 

Where 

(0.0050) / (8,710) / (20.9 / (20.9-3)) * 7,000 =0.0034 gr PMIO/dscf 

Turbines - CO emission limit 

The 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, I spoke with representatives of the Connecticut 

Department of Environmental Protection (DEP) regarding the status of the Kleen Energy facility; Le., 
AIR PERMITS OFFICE 

Avenal Energy Project (SJ 08-01) 

DATE: May 26,2011 

TO: Avenal Energy Project PSD Permit Decision Project File 

FROM: Shirley Rivera (AIR-3)	 ~-'\\J--c~---=

SUBJECT: Final Permit Requirements - Selected Background Information 

This memorandum summarizes certain information relevant to several requirements ~n the Hll.:llr-'V"·1J<ll 

Energy Project (AEP) PSD permit that differ from those in the proposed permit. Thls" 

pertains to the following topics: 

• Auxiliary Boiler - PM and PMlO 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 / PMIO hourly emissions rate 

We inadvertently omitted emissions limits for this emission ~rit in t i~ proposed permit. We made an 

administrative correction by adding' a PM/PM10 emissigns limilI:~f O~0034 grains/dscf (gr/dscr) for the 

unit, consistent with the permit application in the finali it. ,We have retained the requirement to 

source test the auxiliary boiler through an initial performa 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/dscffor the al and subsequent testing was calculated to be 0.0034 

gr/dscfbased on the following application n and the F-Factor methodology (40 CFR Part 60, 

Appendix A, Method 19). (Assume all PM ,t.tEPM 

Given:	 Table 6.2-1.2 (Appendix 6 

Boiler, MMBtu/hr 

PM10, Ib/MMBtu 

Conversion factor	 7,000 grains/lb 

F-Factor (natural gas) = 8,710 dscflMMBtu 

%02 =3% 

Calc methodology: 

Muo/MMBtu) / (F-factor) / (20.9 / (20.9 - %02)) * 7,000 grains/lb = gr PMIO/dscf 

Where 

(0.0050) / (8,710) / (20.9 / (20.9-3)) * 7,000 = 0.0034 gr PM1o/dscf 

Turbines - CO emission limit 

The 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, I spoke with representatives of the Connecticut 

Department of Environmental Protection (DEP) regarding the status of the Kleen Energy facility; Le., 
Final Permit Requirements -- Selected Background Information 

Page 3 

PSD permit issued by EPA Region 9 for Colusa Generating Station was limited to 270 minutes (or 4.50 

hours); the shutdown duration was limited to 30 minutes (or 0.50 hour). 

===END=== 

0526EPA AVENAL-MEMO TO FILE PERMIT REVN SR.DOC