## AIR PERMITS OFFICE AvenalEnergy 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 PM10 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/PM 10 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/dscffor the**in~tial** and subsequent testing was calculated to be 0.0034 gr/dscfbased onthe 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 ofthe Connecticut Department ofEnvironmental Protection (DEP) regarding the status ofthe Kleen Energy facility; Le.,

## AIRPERMITS OFFICE AvenalEnergyProject (SJ08-01) 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/PM 10 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/dscfforthe 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 PM 10, 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 ofthe Connecticut Department ofEnvironmental Protection (DEP) regarding the status ofthe Kleen Energy facility; Le.,FinalPermitRequirements -- SelectedBackgroundInformation 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