# Antelope Valley Air Quality Management District

Final 

# Staff Report

Proposed Amendment to 

# Rule 1134 – Stationary Gas Turbines

Adopted on 01/19/2010

43301 D IVISION 

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### 93535-4649 P HONE 

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Final Staff Report, 03/17/10 

### STAFF REPORT TABLE OF CONTENTS Rule 1134 – Stationary Gas Turbines

I. PURPOSE OF STAFF REPORT ...................

................................................... .....................1

II. EXECUTIVE SUMMARY.........................

................................................... ........................1

III. STAFF RECOMMENDATION ......................

................................................... ...................2

IV. LEGAL REQUIREMENTS CHECKLIST..............

................................................... ..........3

V. DISCUSSION OF LEGAL REQUIREMENTS ..........

................................................... ......4

A. REQUIRED ELEMENTS/FINDINGS..................

................................................... ......4 1. State Findings Required for Adoption of Rule s & Regulations ......................4 a. Necessity ...................................

................................................... ........4 b. Authority...................................

................................................... ........4 c. Clarity.....................................

................................................... ...........4 d. Consistency.................................

................................................... ......4 e. Non-duplication .............................

................................................... ...4 f. Reference...................................

................................................... ........5 g. Public Notice & Comment, Public Hearing..... ....................................5 2. Federal Elements (SIP Submittals, Other Fede ral Submittals)........................5 a. Satisfaction of Underlying Federal Requireme nts ...............................5 b. Public Notice and Comment................... .............................................5 c. Availability of Document.................... .................................................6 d. Notice to Specified Entities ................ .................................................6 e. Public Hearing..............................

................................................... .....6 f. Legal Authority to Adopt and Implement ...... ......................................6 g. Applicable State Laws and Regulations Were F ollowed.....................6

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS... ......................................7

C. ECONOMIC ANALYSIS ...........................

................................................... ................7 1. General.....................................

................................................... .....................7 2. Incremental Cost Effectiveness.............

................................................... .......7

D. ENVIRONMENTAL ANALYSIS (CEQA) ...............

................................................... 8

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS ......... ........................................8 1. Potential Environmental Impacts.............

................................................... .....8 2. Mitigation of Impacts.......................

................................................... .............8 3. Alternative Methods of Compliance...........

................................................... ..8TC

- 2 AVAQMD Rule 1134 Final Staff Report, 03/17/10 F. PUBLIC REVIEW ...............................

................................................... ........................8

VI. TECHNICAL DISCUSSION ......................

................................................... ......................9

A. SOURCE DESCRIPTION ..........................

................................................... ................9

B. EMISSIONS ...................................

................................................... .............................9

C. CONTROL REQUIREMENTS........................

................................................... ...........9

D. PROPOSED RULE SUMMARY.......................

................................................... .......10

E. SIP HISTORY.................................

................................................... ...........................12 1. SIP History.................................

................................................... .................12 2. SIP Analysis................................

................................................... ................13

Appendix A – Rule 1134 Iterated Version ............

................................................... ...................A-1

Appendix B – Public Notice Documents...............

................................................... ...................B-1

Appendix C – Public Comments and Responses.........

................................................... .............C-1

Appendix D – California Environmental Quality Act D ocumentation ....................................... D-1

Appendix E – Bibliography ..........................

................................................... ............................E-1

Appendix F – Technical Report......................

................................................... .......................... F-1

I. EXECUTIVE SUMMARY...............................

................................................... ...................1

II. INTRODUCTION...................................

................................................... .............................2

III. TECHNICAL DISCUSSION ..........................

................................................... .....................4

A. SOURCE DESCRIPTION..............................

................................................... .............4 1. Applicability and District Turbine Inventory.... ...........................................4 2. Currently Available Control Technologies........ ..........................................5 3. Rule History....................................

................................................... ..........6

B. EMISSIONS.......................................

................................................... ..........................6

C. BASIS FOR STATIONARY GAS TURBINE ANALYSIS ....... ...................................6 1. SMAQMD Rule 413.................................

................................................... 6 2. SJVAQMD Rule 4703............................... ..................................................7AVAQMD Rule 1134 TC

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Final Staff Report, 03/17/10

3. SCAQMD Rule 1134................................ .................................................10

D. FEASIBILITY OF OPTIONS..........................

................................................... ..........11

IV. STAFF RECOMMENDATION...........................

................................................... ..............12

Appendix A - Calculations and Assumptions for Deter mining Cost-Effectiveness....................A-1

Appendix B - Bibliography..........................

................................................... .............................B-1TC

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Final Staff Report, 03/17/10 

### STAFF REPORT Rule 1134 – Stationary Gas Turbines

I. PURPOSE OF STAFF REPORT

A staff report serves several discrete purposes. I ts primary purpose is to provide a summary and background material to the members of the Governing Board (Board). This allows the members of the Governing Board to be fully informed before making any required decision. It also provides the documentation necessary for the Governing Board to make any findings, which are required by law to be made prior to the approval or adoption of a docu ment. In addition, a staff report ensures that the correct procedures and proper documentation for app roval or adoption of a document have been performed. Finally, the staff report provides evid ence for defense against legal challenges regarding the propriety of the approval or adoption of the do cument.

II. EXECUTIVE SUMMARY

The Antelope Valley Air Quality Management District (AVAQMD or “District”) has the authority pursuant to California Health and Safety Code (H&S Code) §40702 to adopt, amend or repeal rules and regulations. The AVAQMD is proposing to adopt Rule 1134 – Stationary Gas Turbines for inclusion in the current rulebook.

California Health & Safety Code §39614(d) (H&S Code ) requires the AVAQMD to adopt the most readily available, feasible and cost-effective loca l control measures for particulate matter (PM) as contained on a list developed by the California Air Resources Board (CARB). CARB has identified on its list of local control measures a stationary gas turbine related measure as potentially feasible. The District has evaluated the availability, feasibilit y and cost-effectiveness of applying those stationa ry gas turbine related control measures within the AVAQMD (PM Measures Requiring Further Evaluation, #46a, b and c). This analysis is included in secti on (V)(C)(2) and Appendix “F” of this staff report. Former rule provisions had very limited applicabili ty to stationary gas turbines in the Southeast Dese rt Air Basin (SEDAB) in which the AVAQMD is located (n ow the Mojave Desert Air Basin (MDAB)), and no turbines in the AVAQMD were subject to the r ule. The proposed amendments will make the rule applicable to the AVAQMD, therefore expanding the applicability to a wider range of sources and will include certain oxides of nitrogen (NO x) and carbon monoxide (CO) limits determined to be feasible. An additional compliance limit has been added for turbines which utilize digester gas which does not change the NO x or CO compliance limit for the size range of turbi nes identified, merely specifies the fuel technology.

Section 172(c)(1) of the Clean Air Act (42 U.S.C. § 7502(c)(1)) requires ozone non-attainment areas to implement, as expeditiously as practicable, reducti ons in ozone precursor emissions (NO x and volatile organic compounds (VOC)) from existing sources thro ugh the adoption of Reasonable Available Control Technology (RACT)). This rule amendment up dates NO x RACT for the stationary gas turbine category.
The public hearing to consider the amendment of Rul e 1159 was originally noticed for the 11/17/09 AVAQMD Governing Board meeting. The AVAQMD receive d substantive comments from the2 AVAQMD Rule 1134 Final Staff Report, 03/17/10 County Sanitation Districts of Los Angeles County o n 11/02/09, and continued this public hearing to the next regularly scheduled meeting of 12/15/09 si nce these comments could not be addressed prior to the 11/17/09 meeting. The 12/15/09 meeting was can celled and all items deferred to the next regularly scheduled meeting of 01/19/10.

III. STAFF RECOMMENDATION

Staff recommends that the Governing Board of the AV AQMD adopt the proposed amendments to Rule 1134 – Stationary Gas Turbines and approve the appropriate CEQA documentation. Th is action is necessary to satisfy the commitment made in the List and Implementation Schedule for District Measures to Reduce PM Pursuant to Health & Safety C ode §39614(d) adopted August 16, 2005 (pg. 26), and to update RACT for the stationary gas turb ine category.

The Governing Board of the Antelope Valley Air Qual ity Management District amended Rule 1134 – Stationary Gas Turbines on January 19, 2010.AVAQMD Rule 1134 3

Final Staff Report, 03/17/10 IV. LEGAL REQUIREMENTS CHECKLIST

The findings and analysis as indicated below are re quired for the procedurally correct amendment of Rule 1134 – Stationary Gas Turbines . Each item is discussed, if applicable, in Sectio n V below. Copies of documents are included in the appropriate Appendix.

FINDINGS REQUIRED FOR RULES & REGULATIONS

X Necessity

X Authority

X Clarity

X Consistency

X Non-duplication

X Reference

X Public Notice & Comment

X Public Hearing

REQUIREMENTS FOR STATE IMPLEMENTATION PLAN SUBMISSION (SIP):

X Public Notice & Comment

X Availability of Document

X Notice to Specified Entities (State, Air Districts, USEPA, Other States)

X Public Hearing

X Legal Authority to adopt and implement the document.

X Applicable State laws and regulations were followed. ELEMENTS OF A FEDERAL SUBMISSION

X Elements as set forth in applicable Federal law or regulations.

CALIFORNIA ENVIRONMENTAL QUALITY ACT REQUIREMENTS (CEQA):

N/A Ministerial Action

X Exemption

N/A Negative Declaration

N/A Environmental Impact Report

X Appropriate findings, if necessary.

X Public Notice & Comment

SUPPLEMENTAL ENVIRONMENTAL ANALYSIS (RULES & REGULATIONS ONLY): X Environmental impacts of compliance.

N/A Mitigation of impacts.

N/A Alternative methods of compliance.

OTHER:

X Written analysis of existing air pollution control requirements

X Economic Analysis

X Public Review4 AVAQMD Rule 1134 Final Staff Report, 03/17/10 V. DISCUSSION OF LEGAL REQUIREMENTS

A. REQUIRED ELEMENTS/FINDINGS

This section discusses the State of California stat utory requirements that apply to the amendment of Rule 1134. These are actions, that ne ed to be performed, and/or information, that must be provided in order to amend the rule in a procedurally correct manner.

1. State Findings Required for Adoption of Rules & Regulations:

Before adopting, amending, or repealing a rule or r egulation, the AVAQMD Governing Board is required to make findings of necessity, au thority, clarity, consistency, nonduplication, and reference based upon relevant info rmation presented at the hearing. The information below is provided to assist the Board i n making these findings.

a. Necessity:

The amendments to Rule 1134 are necessary to satisf y the provisions of H&S Code §39614(d) which requires the adoption of readi ly available, feasible and cost-effective control measures for PM from a list of potential local control measures promulgated by CARB. The level of control contained in the amendments to Rule 1134 have been determined to be readily available, feasible and cost-effective based upon an analysis and recom mendations made in the feasibility analysis for stationary gas turbines in cluded in the Technical Discussion in Appendix “F” of the staff report. Th e amendments also satisfy the 42 U.S.C. 7502(c)(1) requirement for implementation and periodic update of RACT requirements for non-attainment areas.

b. Authority:

AVAQMD has the authority pursuant to H&S Code §4070 2 to adopt, amend or repeal rules and regulations.

c. Clarity:

The amendments are clear in that they are written s o that the persons subject to the rule can easily understand the meaning.

d. Consistency:

The amendments to Rule 1134 are in harmony with, an d not in conflict with or contradictory to, any state law or regulation, fede ral law or regulation, or court decisions.

e. Non-duplication:

The amendments to Rule 1134 do not impose the same requirements as an existing state or federal law or regulation because the District amended this ruleAVAQMD Rule 1134 5

Final Staff Report, 03/17/10

to satisfy the provisions of H&S Code §39614(d) whi ch requires the adoption of readily available, feasible and cost-effective cont rol measures for PM from a list of potential local control measures promulgated by CARB. In addition, the amendments do not impose the same requirements as f ederal law, in that, federal law merely requires the adoption and update of RACT for existing facilities in a particular source category but does not directly im pose such measures upon such facilities.

f. Reference:

AVAQMD has the authority pursuant to H&S Code §4070 2 to adopt, amend or repeal rules and regulations.

g. Public Notice & Comment, Public Hearing:

Notice for the public hearing for the proposed amen dment of Rule 1134 was published 10/16/09 for the 11/17/09 Governing Board meeting. This hearing was continued to the next regularly scheduled meeting o f 12/15/09 to address substantive comments received from the County Sanit ation Districts of Los Angeles County. The 12/15/09 meeting was cancelled and all items deferred to the next regularly scheduled meeting of 01/19/10. See Appendix “B” for a copy of the public notice. See Appendix C for copies of comments and AVAQMD
responses.
2. Federal Elements (SIP Submittals, Other Federal Submittals).

Submittals to the United States Environmental Prote ction Agency (USEPA) are required to include various elements depending upon the type of document submitted and the underlying federal law which requires the submittal . The information below indicates which elements are required for the proposed amendm ent of Rule 1134 and how they were satisfied.

a. Satisfaction of Underlying Federal Requirements:

The amendments to Rule 1134 are subject to all the requirements for a State Implementation Plan (SIP) submittal because Rule 11 34 is currently included in the AVAQMD SIP. In addition, rules imposing RACT r equirements enacted to satisfy the requirements of 42 U.S.C. 7502(c)(1) ar e also required to be included in the SIP. The criteria for determining completen ess of SIP submissions are set forth in 40 CFR Part 51, Appendix V, 2.0.

b. Public Notice and Comment:

Notice for the public hearing for the proposed amen dment of Rule 1134 was published 10/16/09 for the 11/17/09 Governing Board meeting. This hearing was continued to the next regularly scheduled meeting o f 12/15/09 to address6 AVAQMD Rule 1134 Final Staff Report, 03/17/10 substantive comments received from the County Sanit ation Districts of Los Angeles County. The 12/15/09 meeting was cancelled and all items deferred to the next regularly scheduled meeting of 01/19/10. See Appendix “B” for a copy of the public notice. See Appendix C for copies of comments and AVAQMD
responses.
c. Availability of Document:

Copies of the proposed amendments to Rule 1134 and the accompanying draft staff report were made available to the public on 1 0/19/09.

d. Notice to Specified Entities

Copies of the proposed amendment of Rule 1134 and t he accompanying draft staff report were mailed to all affected agencies, including but not limited to CARB and USEPA. The proposed amendments were sent to CARB and USEPA on 10/15/2009.

e. Public Hearing:

A public hearing to consider the proposed amendment of Rule 1134 was set for 11/17/09. This hearing was continued to the next r egularly scheduled hearing on 12/15/09 to address substantive comments were recei ved from the County Sanitation Districts of Los Angeles County. The 12 /15/09 meeting was cancelled and all items deferred to the next regula rly scheduled meeting of 01/19/10.

f. Legal Authority to Adopt and Implement:

The AVAQMD has the authority pursuant to H&S Code § 40702 to adopt, amend, or repeal rules and regulations and to do su ch acts as may be necessary or proper to execute the duties imposed upon the AV AQMD.

g. Applicable State Laws and Regulations Were Follo wed:

Public notice and hearing procedures pursuant to H& S Code §§40725-40728 have been followed. See Section (V)(A)(1) above fo r compliance with state findings required pursuant to H&S Code §40727. See Section (V)(B) below for compliance with the required analysis of existing r equirements pursuant to H&S Code §40727.2. See Section (V)(C) for compliance w ith economic analysis requirements pursuant to H&S Code §40920.6. See Se ction (V)(D) below for compliance with provisions of the California Enviro nmental Quality Act (CEQA).AVAQMD Rule 1134 7

Final Staff Report, 03/17/10 B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS

H&S Code §40727.2 requires air districts to prepare a written analysis of all existing federal air pollution control requirements that apply to the sa me equipment or source type as the rule proposed for modification by the District.

The Federal Clean Air Act (FCAA) requires areas des ignated non-attainment for ozone and classified moderate and above to adopt and maintain RACT rules to control the emissions of VOCs and NO x for categories which the USEPA has adopted a Contr ol Techniques Guideline (CTG) or Alternative Control Techniques (ACT) and f or all categories where there are major stationary sources of air pollution (42 U.S.C. §751 1a(b)(2), FCAA 182(b)(2)). For purposes of the FCAA, the District has been designated non-atta inment for ozone and classified severe-17.

The USEPA has promulgated “Alternative Control Tech niques Document – NO x Emissions from Stationary Gas Turbines” (EPA-453/R-93-007) wh ich applies to the source category of stationary gas turbines. In addition, the USEPA ha s also adopted “Standards of Performance for Stationary Combustion Turbines” (71 FR 38482, J uly 6, 2006) which also applies to this source category. The proposed amendments have been developed to be consistent with the provisions of these two requirements.

H&S Code §39614(d) requires the AVAQMD to adopt the most readily available, feasible and cost-effective local control measures for PM as con tained on a list developed by CARB. CARB has identified on its list of local control measure s several items related to stationary gas turbines as potentially feasible. The District has evaluate d the availability, feasibility and costeffectiveness of applying those combustion source c ontrol measures related to stationary gas turbines within the AVAQMD in the Feasibility Analy sis for Stationary Gas Turbines included in Appendix “F”.

C. ECONOMIC ANALYSIS

1. General

The amendments to Rule 1134 will not have an advers e economic impact on any facilities because there are currently no facilitie s subject to the proposed rule. Please see the incremental cost-effectiveness analysis in the technical report in Appendix “F” for a more detailed analysis of potential economic impact.

2. Incremental Cost Effectiveness

Pursuant to H&S Code §40920.6, incremental cost eff ectiveness calculations are required for rules and regulations which are adopte d or amended to meet the California Clean Air Act requirements for Best Available Retro fit Control Technology (BARCT) or “all feasible measures” to control volatile comp ounds, NO x or oxides of sulfur (SO x ).

The cost-effectiveness analysis contained in the Te chnical Discussion document in Appendix “F” was based upon cost estimates containe d in the staff report for San8 AVAQMD Rule 1134 Final Staff Report, 03/17/10 Joaquin Valley Air Pollution Control District (SJVA PCD) Rule 4703 as adopted 4/25/02, and MDAQMD Rule 1159 Staff Report as adopt ed 09/28/09.

D. ENVIRONMENTAL ANALYSIS (CEQA)

Through the process described below, it was determi ned that a Notice of Exemption would be the appropriate CEQA process for the amendment of R ule 1134.

1. The amendments to Rule 1134 meet the CEQA defini tion of "project." They are not "ministerial" actions.

2. The amendment of Rule 1134 is exempt from CEQA r eview because there is no potential that the amendments might cause the relea se of additional air contaminants or create any adverse environmental im pacts; therefore, a Class 8 categorical exemption (14 Cal. Code Reg. §15308) ap plies. The requirements in the amendments to Rule 1134 are more stringent than the currently existing requirements (see more detailed discussion in rule summary §(D)). In addition, there are no expected indirect impacts caused by po tential compliance with the prohibitory requirements of the rule (see more deta iled explanation in Supplemental Environmental Analysis §(E)). Copies of the documents relating to CEQA can be found in Appendix “D”.

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS

1. Potential Environmental Impacts

There are no potential adverse environmental impact s of compliance with the amendment of Rule 1134. There are no sources in th e AVAQMD that will be subject to the prohibitory requirements of the rule. The Dist rict is amending this rule to satisfy the provisions of H&S Code §39614(d) which requires the adoption of readily available, feasible and cost-effective control measures for PM from a list of potential local control measures promulgated by CARB. In addition, the ame ndments update RACT for existing facilities in a particular source category but since there are no sources within the AVAQMD which are currently subject to the prohi bitory requirements there will be no impacts from RACT compliance.

2. Mitigation of Impacts

N/A

3. Alternative Methods of Compliance

N/A

F. PUBLIC REVIEW

See Staff Report Section (V)(A)(1)(g) and (2)(b), a s well as Appendix B.AVAQMD Rule 1134 9

Final Staff Report, 03/17/10 VI. TECHNICAL DISCUSSION

A. SOURCE DESCRIPTION

Gas turbines with power outputs ranging from less t han 1 megawatt (MW) to over 200 MW are used in a broad scope of applications. A gas turbi ne is an internal combustion engine that operates with rotary rather than reciprocating moti on. In stationary applications, the hot combustion gases are directed through one or more f an-like turbine wheels to generate shaft horsepower. Often the heat from the exhaust gases is recovered through an add-on heat exchanger. Gas turbines are used by industry in bo th mechanical and electrical drive applications. The primary applications for gas tur bines can be divided into the following categories: the oil and gas industry, stand-by/emer gency electric power generation, independent electric power producers, electric utilities and ot her industrial applications.

Former rule provisions did not apply to any station ary gas turbine in the AVAQMD because of a provision that exempted most turbines located in the SEDAB from the requirements of the rule. There is one microturbine, and two proposed combustion turbine generators, currently located or proposed for construction within the dis trict.

Los Angeles County Sanitation District operates a d igester gas microturbine, an Ingersoll-Rand EcoWorks 250 Series microturbine fired on digester gas, rated at 250 kW(e). This microturbine falls below the 0.3 MW lower applicability limit of Rule 1134, and is therefore not subject to the requirements of Rule 1134 (although it is expec ted to operate at a nominal 9 ppmv for NO x , CO and VOC which is in compliance with the proposed requirements in the rule).

The City of Palmdale is proposing to build two comb ustion turbine generators at the Palmdale Hybrid Power Project. Each Turbine is a natural ga s fueled, General Electric, 7FA combustion turbine generator block, producing approximately 25 5 MW(e) with a connected heat recovery steam generator and a steam condensing turbine, wit h maximum turbine heat input of 1736.4 MMBtu/hr. Each turbine has Dry Low NO x (DLN) burners and Selective Catalytic Reduction (SCR) as control measures. These turbines will be permitted in compliance with the proposed requirements of the rule.

B. EMISSIONS

The amendments to Rule 1134 – Stationary Gas Turbines do not cause the release of additional air contaminants or create any adverse environmenta l impacts because all existing turbines in the District are either not subject to the provisio ns of the rule, or are permitted at lower levels than in the amendment of the rule. Section (C)(1)( a) Table 1 contains NO x and CO compliance limits which would apply to future installations of small stationary gas turbines, while larger turbines would be subject to New Source Review.

C. CONTROL REQUIREMENTS

Please see section (C) of the rule (Appendix A) for control requirements.10 AVAQMD Rule 1134 Final Staff Report, 03/17/10 The amendments to Rule 1134 – Stationary Gas Turbines do not cause the release of additional air contaminants or create any environmental impact s because all existing turbines in the District are either not subject to the applicabilit y because of size, or are permitted at lower limits than contained in the proposed requirements. Section (C)(1)(a) Table 1 contains NO x and CO compliance limits which would apply to futur e installations of small stationary gas turbines, while larger turbines would be subject to New Source Review.

D. PROPOSED RULE SUMMARY

This section gives a brief overview of the proposed amendments to Rule 1134. The iterated rule version is contained in Appendix “A” of this s taff report.

Proposed amendments to Rule 1134 were designed to e nable the District to comply with the provisions of H&S Code §39614(d) that requires the adoption of the most readily available, feasible and cost-effective control measures for PM as set forth on a list developed by CARB. 1 This list was developed based on rules, regulations , and programs existing in California as of 01/01/04. There are three rules listed as potentia l local control measures contained in the CARB document: 1) Sacramento Metropolitan Air Qual ity Management District (SMAQMD) Rule 413 (5/1/97); 2) San Joaquin Valley Air Pollut ion Control District (SJVAPCD) Rule 4703 (4/25/02); and 3) South Coast Air Quality Managemen t District (SCAQMD) Rule 1134 (8/8/97). Specifically, Appendix C of the CARB doc ument Proposed List of Measures to Reduce Particulate Matter , Strategy D – Combustion Sources (Measures reduce NO x , SO X , VOC, CO or PM 10 and PM 2.5 ) 46, refers to these stationary gas turbine rules. The District has analyzed these rules to determine if the measures t hey contained were readily available, feasible and cost-effective for implementation within the AV AQMD. The VOC limits contained in the SJVAPCD rule were determined to be cost effective a nd have been incorporated in the proposed amendments to Rule 1134.

Rule 1134 has been reformatted to standard District format.

Section (A) has been amended to be standard Distric t format. Former rule provisions did not apply to stationary gas turbines in SEDAB pursuant to former section (g)(1)(D), therefore, the proposed amendments expand rule applicability to a wider variety of sources.

Section (B) definitions are updated. Definitions h ave been included to make the rule more comprehensive, reflect the current applicability of the rule, and provide additional clarity. Definitions which were added: Air Pollution Contro l Officer; CEMS; Digester Gas; Dry Low NO x Combustion Technology; Emission Control Equipment; Emission Control System Operating Parameters; Enhanced Emissions Monitoring Device; Landfill Gas; Measured NO x Emissions Concentrations; Predictive Emissions Moni toring System (PEMS); Public Service Unit; Reasonably Available Control Technology (RACT ); Selective Catalytic Reduction (SCR); Shutdown Period; and, Startup Period. Definitions which were removed: Cogeneration Cycle

1 A copy of the CARB “Proposed List of Measures to R educe Particulate Matter – PM10 and PM2.5 (Implementation of Senate Bill 656, Sher 2003) and attendant staff report may be found at: http://www.arb.ca.gov/pm/pmmeasures/pmmeasures.htm

.AVAQMD Rule 1134 11

Final Staff Report, 03/17/10 Gas Turbine Unit; Exhaust After Treatment; Peaking Gas Turbine Unit; Pipeline Gas Turbine Unit; Sewage Digester Gas; and, Southeast Desert Ai r Basin (SEDAB).

Section (C)(1)(a) Table 1 has been added to include SJVAPCD compliance limits which were determined to be cost-effective. These limits are all more stringent than the previous rule amendment because former rule provisions did not ap ply to stationary gas turbines in SEDAB pursuant to former section (g)(1)(D). A specific c ategory for digester gas and/or landfill gas fired turbines has been added for those units whose exhaust contains components which are not compatible with selective catalytic reduction. The re is no change in the NO x or CO compliance limit for the size range of turbines identified, me rely a specification of the fuel technology used.

Section (C)(2) requires any owner/operator of a sta tionary gas turbine subject to Table 1 to submit an Emissions Control Plan for approval.

Section (C)(3) requires any owner/operator of a sta tionary gas turbine subject to (C)(1) to minimize emissions insofar as technologically feasi ble during Thermal Stabilization Periods. This section was added in response to MDAQMD Rule 1 159 USEPA rule review comments received 7/9/09.

Section (D) – Exemptions were previously Section (g ). Section relocated to be consistent with current District rule format.

Section (D)(1)(d) (Previous section (g)(1)(D)) exem ption was removed as this provision made the rule inapplicable in the AVAQMD, as the AVAQMD is contained in the SEDAB.

Section (D)(2)(b) was derived from MDAQMD Rule 1159 . This type of equipment was formerly exempt pursuant to Section (g)(1)(D). Thi s provision retains that exemption. Please note that equipment is still required to have a per mit (See Rule 219) and new or modified units will be subject to Regulation XIII.

Section (D)(2)(c) was added because this equipment was formerly exempt pursuant to Section (g)(1)(D). This provision retains that exemption. Please note that equipment is still required to have a permit (See Rule 219) and new or modified un its will be subject to Regulation XIII.

Section (D)(2)(B) (previous Section (g)(2)(B)) is r emoved as this provision makes the rule inapplicable since the District is located in the S EDAB.

Section (D)(2)(C) (previous Section (g)(2)(C)) is r emoved because San Clemente Island is not located within the boundaries of the AVAQMD.

Remaining text in exemption section is restated in new section (G)(1)(a).

Section (E) is derived from MDAQMD Rule 1159. This Section sets forth the requirements for an Emission Control Plan as required in section (C) (2).

Section (F) incorporates recordkeeping from previou s rule version Section (f) for consistency with current District rule format.12 AVAQMD Rule 1134 Final Staff Report, 03/17/10 Deleted provisions from Section (F) (previous secti on (d)) did not apply in the SEDAB pursuant to previous section (g)(1)(D). Therefore the provi sions contained in amended section (F) are more stringent than the provisions contained in the previous rule.

Section (G)(1) restates requirements from previous Section (g).

Section (G)(2) provides provisions for operation du ring a state of emergency.

Section (H) requirements are derived from MDAQMD Ru le 1159.

Section (I) – Compliance Schedule provides incremen ts of progress for complying with the provisions of this rule. The requirements were der ived from MDAQMD Rule 1159.

E. SIP HISTORY

1. SIP History.

Prior to 1975, the original air district for the An telope Valley region was the Los Angeles County APCD that had jurisdiction covering the entire county of Los Angeles. In 1975, the Southern California Air Pollution Cont rol District (So. Cal. APCD) was created. The So. Cal. APCD was created by a Joint Powers Agreement (JPA) between Los Angeles, Orange, Riverside and San Bernardino C ounties to replace the previous countywide air pollution control districts for thos e counties. On 02/01/77, pursuant to statute (Cal. Stats. 1976, Ch 324 p. 815) the South Coast Air Quality Management District (SCAQMD) was created with an initial juris diction that only included areas of Los Angeles, Orange, Riverside and San Bernardino C ounties contained within the South Coast Air Basin (SCAB). Outlying areas remai ned under the So. Cal. APCD (The legislation was thereafter amended to allow no n SCAB areas to “opt in”. Los Angeles County exercised this option, and thus the Antelope Valley became a part of SCAQMD). Also on 02/01/77 the California Air Resou rces Board (CARB) issued Executive Order G-73 (1977) which adopted a “rule b ook” for those non-SCAB areas of Los Angeles, Riverside and San Bernardino Counties. CARB submitted the G-73 rulebook on behalf of the “county” districts.

By its terms Executive Order G-73 (1977) was only e ffective until the non-SCAB areas took other action. On 02/22/77 the JPA forming the So. Cal. APCD was formally dissolved. By the terms of the JPA upon dissolutio n each county would regain its county air pollution control district with a jurisd iction of the non-SCAB areas of the county and the applicable rules being the So. Cal. APCD’s rules in effect upon the date of dissolution. On 07/01/97 the Antelope Valley Ai r Pollution Control District (AVAPCD) replaced the SCAQMD as the agency with jur isdiction over the Los Angeles County portion of the Mojave Desert Air Bas in (MDAB). On 01/01/02 the AVAPCD was replaced by the AVAQMD. Pursuant to bot h statutory changes, the rule and regulations of the predecessor district were re tained until the Governing Board adopted, amended or rescinded them. At the first m eeting of the both the AVAPCD and the AVAQMD, the respective Governing Boards reaffir med all the rules and regulations in effect at the time the agency changed.AVAQMD Rule 1134 13

Final Staff Report, 03/17/10

The jurisdiction of the AVAPCD and the AVAQMD were specified in the statutes as the portion of the Los Angeles County contained wit hin the MDAB. The MDAB was formerly known as the Southeast Desert Air Basin (S EDAB). In 1997 the SEDAB was split into the MDAB and the Salton Sea Air Basin. Descriptions of these air basins can be found in 17 Cal. Code Regs. §§60109 and 60144. Since USEPA adopts SIP revisions in California as effective within jurisdi ctional boundaries of local air districts, when the local air district boundaries change the S IP as approved by USEPA for that area up to the date of the change remains as the SI P in that particular area. Thus, upon creation of the AVAPCD on 07/01/97 the AVAPCD acqui red the SIP applicable to the Antelope Valley portion of the SCAQMD that was effe ctive as of 06/30/97. Likewise the AVAQMD acquired the SIP that was effective in t he jurisdiction of the AVAPCD as of 12/31/01. Therefore, the SIP history for this r egion is based upon the rules adopted, effective, and approved for the Antelope Valley by SCAQMD.

Rule 1134 was originally adopted on 08/04/89 by the SCAQMD. This rule submission was given limited approval and limited disapproval. Rule 1134 was subsequently amended on 12/07/95 and approved into the SIP at 61 FR 56470, 12/7/95. Rule 1134 was subsequently amended on 04/11/97 and it is uncl ear if USEPA took action on this submission. The 12/07/95 version of Rule 1134 is i n the SIP for the AVAQMD.

2. SIP Analysis.

The District is requesting CARB to submit Rule 1134 to replace the SIP version in effect for the AVAQMD.

Since there is a previously existing SIP rule for t his category in the AVAQMD, the District is requesting that it be superseded. In o rder to replace existing SIP rules the District is required to show that the proposed amen dments are not less stringent than the provisions currently in the SIP.

The proposed AVAQMD Rule 1134 is more stringent tha n the SCAQMD Rule 1134 as adopted on 12/07/95. Former Rule 1134 had very lim ited applicability to the AVAQMD due to exemptions, resulting in no AVAQMD tu rbines within the AVAQMD being subject to the rule. The proposed ame ndments will expand the applicability of the rule to all turbines within th e AVAQMD. Please note, however, that the existing turbine in the District is currently o perating within an exemption and thus would not be subject to the prohibitory limits in t he proposed rule.

RACT limits have been modified since Rule 1134 was originally adopted, and this rule amendment will update RACT.14 AVAQMD Rule 1134 Final Staff Report, 03/17/10 This page intentionally left blank.AVAQMD Rule 1134 A

- 1

Final Staff Report, 03/17/10 

### APPENDIX "A" Rule 1134 – Stationary Gas Turbines

Iterated Version

The iterated version is provided so that the change s to an existing rule may be easily found. The man ner of differentiating text is as follows:

1. Shaded text identifies new or revised language.

2. Lined out text identifies language which is bei ng deleted.

3. Normal text identifies the current language of t he current rule which will remain unchanged by the adoption of the proposed amendments.

4. Italicized text

identifies explanatory material that is not part o f the proposed language.A-2 AVAQMD Rule 1134 Final Staff Report, 03/17/10 This page intentionally left blank.( Adopted : 08/04/89; Amended : 12/07/95; Amended : 04/11/97; Amended : mm/dd/yy)

AVAQMD Rule 1134 1134-1 Stationary Gas Turbines D3, 12/14/09 

## RULE 1134

Emissions Of Oxides Of Nitrogen From Stationary Gas Turbines

( a A ) Applicability General

(1) Purpose
(a) The purpose of this rule is to limit the emissi on of oxides of nitrogen (NO X ) and carbon monoxide (CO) from Stationary Gas Turbines.

(2) Applicability

(a) This rule applies to any new or existing Statio nary Gas Turbine of 0.3 megawatt (MW) and larger unless the equipment is exempt from this rule pursuant to Section (D) of this rule. The provisions of this rule shall apply to all exis ting stationary gas turbines, 0.3 megawatt (MW) and larg er, as of August 4, 1989. [Former rule provisions did not apply to stationary gas turbines in SEDAB pursuant to former section (g)(1)(D), therefore, th e proposed amendments expand rule applicability to a wider variety of sou rces.]



### ( b B ) Definitions

(1) “Air Pollution Control Officer (APCO)” – The pe rson appointed to the position of Air Pollution Control Officer of the District pursuant to the provisions of California Health & Safety Code §40750, and his or her designee. [Derived from AVAQMD Rule 1133.]

( 1 2 ) “ Chemical Processing Gas Turbine Unit ” – is a A gas turbine unit that vents its exhaust gases into the operating stream of a chemical proce ss.
(2) Cogeneration Cycle Gas Turbine Unit is a gas turbine unit that operates both for the simultaneous production of shaft work and for the r ecovery of useful thermal energy from the exhaust gases or waste steam a s defined by Section 25134 of the California Public Resources Code. [Definition removed since it is not used in amended version of rule.]

(3) Combined Cycle Gas Turbine Unit is a gas turbine unit that operates both for the production of electrical energy from shaft work and the useful energy produced from1134-2 AVAQMD Rule 1134 Stationary Gas Turbines

D3, 12/14/09 heat recovered from its exhaust gases. [Definition removed since it is not used in amended version of rule.]

(3) “Continuous Emissions Monitoring System (CEMS)” – All of the equipment that may be required to meet the data acquisition and availa bility requirements of this rule, to sample, condition (if applicable), analyze, and pro vide a record of emissions on a continuous basis. [Derived from 40 CFR 51.165(a)(1)(xxxi)]

(4) “Digester Gas” – Fuel containing a minimum of 6 0 percent process gas, derived from a digester, by volume on a daily average. [Derived from previous rule version (C)(1)(a) and SCAQMD Rule 1134 (c)(1).]

(5) “Dry Low NO X Combustion Technology (DLN)” – Any turbine combust or design which uses multiple staging, air/fuel premixing or other modifications to achieve lower levels of NO X emissions as compared to conventional combustors. [Derived from SJVUAPCD Rule 4703 §3.7]

( 4 6 ) “ Emergency Standby Gas Turbine Unit ” – Any Stationary Gas Turbine that operates as a mechanical or electrical power source for a facil ity only when the primary power source has been rendered inoperable due to failure beyond the reasonable control of the operator. A power interruption pursuant to a volun tary interruptible power supply agreement is not to be considered as an emergency l oss of primary power. Electricity generated by such a unit cannot be sold is a gas turbine unit that operates only as a mechanical or electrical power source for a facilit y when the primary p ower source has been rendered inoperable

, except due to power interruption pursuant to an int erruptible power supply agreement. This does not include util ity company electrical power plant units. [Derived from MDAQMD Rule 1159.]

(7) “Emission Control Equipment” – Add-on technolog ies which control the turbine's emissions, including, but not limited to, Selective Catalytic Control (SCR), water injection, steam injection, but excluding DLN. [Derived from MDAQMD Rule 1159.]

( 5 8 ) “ Emission Control Plan (ECP)” – is a A plan that shall contain at a minimum District permit or identification number; name of gas turbin e manufacturer; model designation; rated brake horsepower; heat rate (BTU/KW-HR), corr ected to the HHV for each type of fueling (liquid/gas); type of liquid fuel and/or type of gaseous fuel; hours of operation in the previous one-year period; fuel consumption ( cubic feet of gas or gallons of liquid) for the previous one-year period; and a list of all gas turbine units required to be controlled identifying the type of emission control to be applied to such gas turbine units along with documentation showing existing emissions of NO x and CO.

(9) “Emission Control System Operating Parameters” – Any operating parameter(s) that the District deems necessary to analyze for the determi nation of compliance. Such parameters include, but are not limited to, the amm onia and gas flow rates, the exhaust temperature for the Selective Catalytic Reduction ( SCR), humidity, water injection rate,AVAQMD Rule 1134 1134-3

Stationary Gas Turbines D3, 12/14/09 exhaust gas flow rate and the temperature for water injection. [Derived from MDAQMD Rule 1159.]

(10) “Enhanced Emissions Monitoring Device” – Any a utomated data recording device or system having both data gathering and retrieval cap abilities. Such equipment includes, but is not limited to, Continuous Emissions Monitor ing Systems (CEMS) and Predictive Emissions Monitoring Systems (PEMS). [Derived from MDAQMD Rule 1159.]

( 6 ) Exhaust After

- Treatment means a control method for the post

- combustion reduction of NOx emissions, such as se lective catalytic reduction ( SCR ). [Definition removed since it is not used in amended version of rule.]

( 7 11 ) “ Existing Gas Turbine Unit ” – is a A stationary gas turbine unit that met the following criteria prior to August 4, 1989 (date of amendment) :
( A a ) Had been issued a valid permit to construct or op erate by the District, or

( B b ) Was in operation pursuant to the provisions of Di strict Rule 219 (b)(1). (D)(2)(a)

( 8 12 ) “Higher Heating Value ( HHV )”

- – The higher Higher heating Heating value Value of the fuel.

(13) “Landfill Gas” – Gas derived from a landfill g as extraction system.

( 9 14 ) “Lower Heating Value ( LHV )”

- – The Lower Heating Value Of of the Fuel.

(15) “Measured NO X Emissions Concentration” – The concentration of ox ides of nitrogen corrected to International Standards Organization ( ISO) standard conditions: [Derived from MDAQMD Rule 1159.]

NO X = (NO X obs)(Pref/Pobs) 0.5 (288 K/Tamb) 1.53 (e 19(Hobs-0.00633) )

Where: NO X = emissions of NO X at 15 percent oxygen and ISO standard

conditions on a dry basis, ppm. NO X obs = measured NO X emissions corrected to 15 percent oxygen on a dry basis, ppm. Pref = standard reference pressure, (14.696 psia). Pobs = measured site ambient absolute pressure, psi a. Hobs = measured humidity of ambient air, pounds wat er per pound dry air. e = transcendental constant (2.718) Tamb = measured temperature of ambient air, degrees Kelvin.

or an alternate calculation that corrects to ISO s tandard conditions and is

approved by the APCO.1134-4 AVAQMD Rule 1134 Stationary Gas Turbines

D3, 12/14/09 ( 10 ) Peaking Gas Turbine Unit is a gas turbin e unit that is used intermittently to produce energy on a demand basis. [Definition removed since it is not used in amended version of rule.]

( 11 ) Pipeline Gas Turbine Unit is a stationary gas turbine unit used to transport gase s or liquids in a pipeline. [Definition removed since it is not used in amended version of rule.]

( 12 16 ) “ Power Augmentation ” – is the An increase in the gas turbine shaft output and/or th e decrease in gas turbine fuel consumption by the add ition of energy recovered from exhaust heat.

(17) “Predictive Emissions Monitoring System (PEMS) ” – All of the equipment necessary to monitor process and control device operational para meters (for example, control device secondary voltages and electric currents) and other information (for example, gas flow rate, oxygen or carbon dioxide concentrations), and calculate and record the mass emissions rate (for example, lb/hr) on a continuous basis. [Derived from 40 CFR 51.165(a)(1)(xxxii)]

(18) “Public Service Unit” – A Stationary Gas Turbi ne used to generate electricity for sale or for use in serving the public. [Derived from MDAQMD Rule 1159.]

( 13 19 ) “ Rating Of A Gas Turbine Unit ” – is the The continuous MW (megawatt) rating or mechanical equivalent by a manufacturer for gas tur bine unit(s) without p ower Power augmentation Augmentation

. (20) “Reasonably Available Control Technology (RACT )” – The lowest emission limitation that a particular source is capable of meeting by t he application of control technology that is reasonably available considering technologi cal and economic feasibility. [USEPA definition 44 FR 53761 (Sept. 17, 1979)]

(21) “Selective Catalytic Reduction (SCR)” – A nonc ombustion control technology that destroys NO X by injecting a reducing agent (e.g., ammonia) into the flue gas that, in the presence of a catalyst (e.g., vanadium, titanium, o r zeolite), converts NO X into molecular nitrogen and water. [Derived from 40 CFR 76.2]

(22) “Shutdown Period” – The period of time during which a unit is taken fro m an operational to a non-operational status by allowing it to cool down from its operating temperature to ambient temperature as the fuel supply to the unit is completely turned off. [Derived from SJVUAPCD Rule 4703 3.26]

(23) “Startup Period” – The period of time during w hich a unit is brought from a Shutdown status to its operating temperature and pressure, i ncluding the time required by the unit’s emission control system to reach full operation. [Derived from SJVUAPCD Rule 4703 3.29]AVAQMD Rule 1134 1134-5

Stationary Gas Turbines D3, 12/14/09 (14) Sewage Digester Gas is a ny gas derived from anae robic decomposition of organic
sewage. [Definition removed since it is not used in amended version of rule.]

(15) Southeast Desert Air Basin (SEDAB) means t he portion of the air basin containing specific desert portions of Los Angeles, Riverside and San B ernardino counties, as defined in Title 17, California Code of Regulations , Section 60109, within the jurisdiction of the District. [Definition removed since it is not used in amended version of rule.]

( 16 24 ) “ Stationary Gas Turbine ” or “ Unit ” – is a A ny gas turbine unit that is gas and/or liquid fueled with or without power augmentation. This gas turbine unit is either attached to a foundation at a facility or is portable equipment o perated at a specific facility for more than 90 days in any 12 twelve -month period. Two or more gas turbine s units powering one shaft shall be treated as one gas turbine unit.

( 17 25 ) “ Thermal Stabilization Period ” – The Startup or Shutdown Period necessary to bring t he heat recovery steam generator to the proper operati ng temperature, not to exceed two hours. is t he two

- hour start up time necessary for NOx control purpos es in cogeneration cycle, combined cycle, or any other applicable stat ionary gas turbine units.



### ( c C ) Emissions Limitations Standards

(1) (1) The owner or operator of any affected stationary Stationary gas Gas turbine Turbine unit Unit shall not operate such unit Unit under load conditions, excluding the thermal Thermal stabilization Stabilization period Period and Startup and Shutdown Periods or other time period speci fied in the Permit to Construct or the Permit to Op erate issued prior to August 4, 1989 , which result in the discharge of oxides of Measured nitrogen ( NOx ) emissions Emissions Concentration exceeding the emissions lim its set forth below. , directly or indire ctly, into the atmosphere at concentrations in exce ss of the following as measured pursuant to subdivision (e):

(a) For Stationary Gas Turbines the federal NO X and CO RACT limits in Table 1 apply: [Former Table I provisions did not apply to SEDAB p ursuant to former section (g)(1)(D).]

Compliance e Limit

Limit Referenc EFF 25% = ×

Where: Compliance Limit = allowable NOx emissions (ppm by volume). Reference Limit = the NOx emission limit (ppm by volume) is corrected1134-6 AVAQMD Rule 1134 Stationary Gas Turbines

D3, 12/14/09 to 15 percent oxygen on a dry basis, and averaged o ver 15 cons ecutive minutes. These limits for various megawatt ratings (continuous rating by the manufacturer without power augmentation) are as follows:

REFERENCE NOx LIMITS, PPM

Unit Size Megawatt (MW) Rating Effective 12/31/95 0.3 to Less Than 2.9 MW 25 2.9 t o Less Than 10.0 MW 9 2.9 to Less Than 10.0 MW No SCR 15 10.0 MW and Over 9 10.0 MW and Over No SCR 12 60 MW and Over Combined Cycle no SCR 15 60 MW and Over Combined Cycle 9 Effective 4/11/97 2.9 to Less Than 10.0 MW Utilizing Fuel containing a M inimum of 60% Sewage Digester Gas by volume on a Daily Average 25

And, EFF = 3413 x 100%

Actual Heat Rate at HHV of Fuel (BTU/KW

- HR)

or,

EFF LHV
HHV = × (Manufacturer' s Rated Efficiency at LHV)

or EFF = the demonstrated percent efficiency of the gas turb ine unit only as

calculated without consideration of any downstream energy rec overy from the actual heat rate, (BTU/KW HR) or 1.34 BTU/HP; c orrected to the HHV (higher heating value) of the fuel, as measured at peak load for that facility; or the manufacturer's continuous rated pe rc ent efficiency (manufacturer's rated efficiency) of the gas turbin e unit after correction from LHV (lower heating value) to the HHV of the fu el, whichever efficiency is higher. The value of EFF shall not b e less than 25 percent. Gas turbine units with lo wer efficiencies will be assigned a 25 percent efficiency for this calculation.

Table 1 NO X and CO Compliance Limits

Control Operating

hours per
year Rating NO X Compliance Limit, ppmv at 15% oxygen CO Compliance Limit, ppmv atAVAQMD Rule 1134 1134-7

Stationary Gas Turbines D3, 12/14/09 Gas Fuel Liquid Fuel 15% oxygen

SCR + DLN > 877 > 10 MW 5 25 200 DLN > 877 2 – 10 MW 25 65 200 SCR (no DLN available) > 877 2 – 10 MW 35 65 200

DLN > 877 < 2 MW 42 50 250 SCR or DLN < 877 > 10 MW 25 42 200 Any (fired on Digester Gas and/or Landfill Gas) any 0.3 – 10 MW 25 N/A 200

[Former Table I provisions did not apply to SEDAB p ursuant to former section (g)(1)(D). Therefore, the limits contained in this table are more stringent than the limits contained in the previous Table. A specific catego ry for gas turbines which use digester gas was added to recognize the separate category, a lthough the applicable limits do not change.]

(b) For the purposes of these emissions limits the following conventions are applicable: [Derived from MDAQMD Rule 1159.]

(i) Gas includes natural gas, Digester Gas and Land fill Gas. (ii) Oil includes kerosene, jet fuel, and distillat e. The sulfur content of the oil shall be less than 0.05 percent. (iii) NO X = emissions of NO X , in ppmv, corrected to 15 percent oxygen and ISO standard conditions on a dry basis, averaged ov er any consecutive 15 minute period.

(2) The owner or operator of any Stationary Gas Tur bine subject to (C)(1)(a) shall submit to the APCO for approval, an Emission Control Plan (EC P) for the purpose of establishing compliance with provisions of this rule. [Derived from MDAQMD Rule 1159.]

(3) The owner or operator of any Stationary Gas Tur bine subject to (C)(1) shall minimize emissions insofar as technologically feasible durin g Thermal Stabilization Periods. [Section added in response to MDAQMD Rule 1159 USEP A rule review comments received 7/9/09]

(2) The operator of any existing gas turbine unit subje ct to this rule shall also be subject to Regulation XIII if carbon monoxide (CO) emissions i ncrease as a result of the application of NOx controls.1134-8 AVAQMD Rule 1134 Stationary Gas Turbines

D3, 12/14/09 

### (D) Exemptions [Exemption section relocated from previous section (g) for consistency with AVAQMD rule format.]

(1) The provisions of Section (C) of this rule shal l not apply to the operation of:

(a) Laboratory gas turbine units used in research a nd testing for the advancement of gas turbine technology.

(b) Units operated exclusively for fire fighting an d/or flood control.

(c) Chemical Processing Gas Turbine Units.

(d) All existing pipeline gas turbine units located in the Southeast Desert Air Basin (SEDAB). [AVAQMD is in the SEDAB and this exemption made rul e inapplicable.]

(2) The provisions of subdivisions (c) and (d), and par agraphs (f)(3), (f)(4) and (f)(5) shall not apply to the following: The provisions of this rule, with the exception of Section (F)(2), shall not apply to the operation of Station ary Gas Turbines used under the following conditions:

(a) Emergency Standby Units, and Stationary Gas Tur bine Units demonstrated to operate less than 200 hours per calendar year, whic h have installed and maintained in proper operation a non-resettable eng ine hour meter.

(b) Portable, turntable, or track mounted turbines whose operation generates intermittent, high velocity air flow for live fire sustainability, lethality, aerodynamic, cookoff, or remote control operation t esting only. [Derived from MDAQMD Rule 1159. Equipment was formerly exempt pu rsuant to section (g)(1)(D). This provision retains that exemption. Please note that equipment is still required to have a permit (See Rule 219) and new or modified units will be subject to Reg. XIII.]

(c) Intra facility portable flight-line equipment u sed to support aircraft systems or start up aircraft power plants. [Equipment was formerly exempt pursuant to section (g)(1)(D). This provision retains that exe mption. Please note that equipment is still required to have a permit (See R ule 219) and new or modified units will be subject to Reg. XIII.]

(B) All existing gas turbine units located in the South east Desert Air Basin (SEDAB) which are ra ted below 4 MW and operate less than 877 hours per year. [AVAQMD is in the SEDAB and this exemption made rul e inapplicable.]

(C) All existing gas turbine units located on San Cleme nte Island which are rated below 4 MW and operate less than 877 hours per y ear. [San Clemente Island is not in the AVAQMD. Therefore, this provision is no t applicable.]AVAQMD Rule 1134 1134-9

Stationary Gas Turbines D3, 12/14/09 However, if the hour

- per

- year limit is exceeded, the exemption shall be auto matically

and permanently withdrawn. The operator of any sta tionary gas turbine exe mpt under this subparagraph must notify the Executive Officer within seven days if the hour

- per

year limit is exceeded. Within 30 days after the d ate the hour

- per

- year limit is exceeded, the operator must submit a permit applica tion for modification to eq uipment to meet the applicable compliance limit within 24 m onths of the date the hour

- per

- year limit is exceeded. Included with this permit appli cation, the operator must submit an emission control plan including a schedule of incre ments of progress for t he installation of the required control equipment. This plan and s chedule shall be subject to the review and approval of the Executive Officer. [ Restated from previous section (g)(2)] section (G)

– Notification Requirements for Exempt and Emergency Sta ndby Units .]



### (E) Administrative Requirements [Derived from MDAQMD Rule 1159.]

(1) The ECP required pursuant to section (C)(2) sha ll, at a minimum, include the following information if such information is applicable:

(a) A list of all Stationary Gas Turbines required to be controlled pursuant to this rule.

(b) For each Stationary Gas Turbine listed:

(i) District identification number, and District pe rmit to operate number; (ii) Name of the gas turbine manufacturer; (iii) Equipment model number; (iv) Manufacturer's rated shaft power output (MW); (v) Type of liquid fuel and/or type of gaseous fuel ; (vi) HHV for each fuel; (vii) Heat rate ((Btu/kW-hr), corrected to the HHV) for each type of fuel (gas or liquid) for each turbine; (viii) Monthly fuel consumption for the previous tw elve-month period (cubic feet for gas; gallons for liquid); (ix) Monthly hours of operation in the previous twe lve-month period; (x) The type of NO X Emission Control Equipment, including any auxiliar y equipment related to the control of emissions, to b e applied; (xi) Documentation showing the current (existing) c oncentration and mass rate of emissions of NO x from the unit; (xii) A schedule with specified increments of progr ess dates for construction of Emission Control Equipment, operational mileston es for implementation of emissions control and/or installa tion of monitoring equipment; and (xiii) A final compliance date.1134-10 AVAQMD Rule 1134 Stationary Gas Turbines

D3, 12/14/09 

### ( d F ) Monitoring and Recordkeeping Requirements Source Testing

(1) The owner or operator of any Stationary Gas Tur bine required to install Emission Control Equipment for compliance with this rule sha ll:

(a) Install, operate, and maintain in calibration, the following monitoring equipment, as approved by the APCO:

(i) Continuous measurement and recording of Emissio ns Control System Operating Parameters; (ii) Continuous measurement and recording of elapse d time of operation; and (iii) An Enhanced Emissions Monitoring Device.

(b) Notify the APCO, in writing, before issuance of the permit to operate, such information which correlates the Emission Control S ystem Operating Parameters, and PEMS if present, to the associated measured NO X emissions output. This information will be used to determine compliance with applicable provisions of this rule for non-CEMS-equipped turbi nes and CEMS-equipped units when the CEMS is not operating properly.

(c) Provide, on an annual basis, compliance testing data and information regarding NO X emissions. The data shall be corrected to ISO con ditions and at 15 percent oxygen on a dry basis; and the percent efficiency ( EFF) of each turbine unit.

(2) The owner/operator of any Stationary Gas Turbin e shall:

(a) On a daily basis, maintain a turbine operating log that includes, as a minimum, the following information:

(i) The total hours of operation per day; (ii) The accumulated hours of operation per calenda r month; (iii) The type and quantity of fuel used; and (iv) The nature of operation of the unit (exempt or non-exempt).

(b) The operating log required to be kept pursuant to this rule shall be kept current and on site for a minimum of two years; and provide d to District or state personnel on request.

The operator of any stationary gas turbine unit sub ject to the provisions of this rule shall perform the following actions: [These provisions did not apply to SEDAB pursuant t o former section (g)(1)(D). Therefore, the requirements cont ained in the amended section (F) are more stringent than the provisions contained in the prev ious rule.] (1) Install, operate, and maintain in calibration a con tinuous i n

- stack NOx and oxygen monitoring system which meets the requirements of 4 0 CFR Part 60, Appendix B, Spec. 2, for NOx , Spec 3 for oxygen (except the alternat ive RA procedures for Spec. 2 shallAVAQMD Rule 1134 1134-11

Stationary Gas Turbines D3, 12/14/09 not apply), the 2 and 24

- hour calibration spec. of Rule 218, and 40 CFR Part 60,

Appendix F to demonstrate compliance with the emiss ion limits of this rule. The continuous emissions monitoring system shall have d ata gathering and retrieval capability which meets the reporting requirements o f 40 CFR part 60.7(c), 60 .7(d), and 60.13. This system shall include equipment that me asures and records the following:

( A ) Flow rate of liquids or gases and the ratio of wate r or steam to fuel added to the combustion chamber or to the exhaust for the reduct ion of NOx emissions, as applicable.

( B ) Elapsed time of operation.

(2) Source Testing

( A ) Provide source test information regarding the gas t urbine unit’s exhaust gas NOx concentration, and the demonstrated percent efficie ncy (EFF), or the manufacturer’s rated EFF, if the Exec utive Officer determines that it is representative of the unit’s EFF, and the carbon mo noxide concentration as specified pursuant to paragraph (e)(1). NOx and ca rbon monoxide concentrations shall be in ppm by volume, corrected to 15 percent oxygen on a dr y basis.

( B ) Source Test Frequency

(i) Units emitting 25 tons or more of NOx per calendar year shall be source tested, at least once every 12 months. (ii) All other existing units shall be source tested wit hin 90 days after every 8,400 hours of operation.



### (G) Notification Requirements for Exempt and Emerge ncy Standby Units [Derived from MDAQMD Rule 1159]

(1) Any Stationary Gas Turbine unit which is exempt or claimed to be exempt pursuant to subsection (D)(2) shall:

(a) Notify the APCO within seven (7) days if the ho ur-per-year threshold is exceeded.

(i) If the hour-per-year threshold is exceeded, the exemption pursuant to subsection (D)(2) shall be permanently withdrawn. (ii) If the hour-per-year threshold is exceeded the owner/operator shall, within 30 days of the notification, submit an appli cation for a permit to operate to the District. Such application shall inc luding a plan detailing actions and a schedule of progress to meet the appl icable RACT limits1134-12 AVAQMD Rule 1134 Stationary Gas Turbines

D3, 12/14/09 and provisions of this rule within 18 months after the date of the notification; an ECP conforming to the requirements of Section (E) for the Emission Control Equipment.

(2) Notwithstanding the provisions of Sections (F)( 2) and (G)(1) above, A Public Service Unit shall not be subject to the hour-per-year thre shold when:

(a) Such unit is operating during a state of emerge ncy declared by a proclamation of the Governor of the State of California; and

(b) Such unit is located within the specific geogra phic location identified in the state of emergency proclamation.



### ( e H ) Test Methods

(1) Compliance testing shall be subject to the prot ocols prescribed in the District's Compliance Procedural Manual.

(2) The following test methods shall be used to det ermine compliance with the provisions of this rule.

(a) NO X emissions shall be determined by EPA Test Method 2 0.

(b) The Higher Heating Value (HHV) and the Lower He ating Value (LHV) shall be determined by the appropriate method for the fuel t ype listed below:

(i) For liquid fuels: a. ASTM Test Method D 240-87 (Standard Test Method for Heat of Combustion of Liquid Hydrocarbon Fuels by Bomb Calo rimeter). (ii) For distillate fuel: a. ASTM Test Method D 2382-88 (Standard Test Method for Heat of Combustion of Hydrocarbon Fuels by Bomb Calorime ter - High Precision Method); or , (iii) For gaseous fuels: a. ASTM Test Method D 3588-91 (Standard Practice fo r Calculation Heat Value, Compressibility Factor, and Relative Density (Specific Gravity) of Gaseous Fuels); or b. ASTM Test Method D 1826-88 (Standard test Method for Caloric (Heating) Value of Gases in Natural Gas Range by Co ntinuous Recording Calorimeter); or c. ASTM Test Method D 1945-81 (Standard Method for Analysis of Natural Gas by Gas Chromatography).AVAQMD Rule 1134 1134-13

Stationary Gas Turbines D3, 12/14/09 The following may be used by the Executive Officer to veri fy the concentrations of NOx, CO and oxygen subject to the provisions of this rule. Emissions determined to exceed any limits established by this rule through either of the foll owing shall constitute a violation of this rule.

(1) District Test Methods 3.1 , 7.1, 10.1 and 100.1 and EPA Test Method 10 or any method deemed to be equivalent by the Executive Officer an d approved by CARB and EPA.

(2) Data obtained from a continuous emissions monitorin g system, which is installed and properly operated according to paragraph (d)(1) of this rule and as approved by t he Executive Officer.



### ( f I ) Recordkeeping Compliance Schedule [Recordkeeping requirements in section (F)]

(1) The owner/operator of any Existing Stationary G as Turbine subject to the provisions of

Section (C)(1)(a) above shall comply with the follo wing increments of progress:

(a) An ECP shall be submitted to the District withi n 90 days of rule adoption. The District shall approve the ECP within 30 days of su bmission.

(b) Any affected turbine shall be in full complianc e with all applicable provisions of the rule within twelve months of rule adoption.

(c) Demonstrate final compliance with all applicabl e standards and requirements of the rule within six months of the installation of t he NO X reduction technology.

(2) The owner/operator of any new Stationary Gas Tu rbine subject to the provisions of Section (C) shall comply as of the date of adoption of this rule. Recordkeeping

The facility operator shall comply with the followi ng provisions:

(1) All records sh all be maintained at the facility for a period of t wo years and made available to District staff upon request.

(2) Maintain a gas turbine operating log that includes, on a daily basis, the actual Pacific Standard Time start

- up and stop time, total hours of operation; type and quantity of fuel used (liquid/gas), cumulative hours of operation to date for the calendar year; and if applicable the cumulative hours of operation since the last source test required by subparagraph (d)(2)(A).

(3) A monthly summary o f emissions pursuant to paragraph (d)(1) shall be s ubmitted to the District on or before the last day of the following calendar month.1134-14 AVAQMD Rule 1134 Stationary Gas Turbines

D3, 12/14/09 (4) The results of source tests shall be submitted to t he District in a form and manner as specified by the Executive Off icer within 30 days after testing is completed.

(5) Any person using an emission control system as a me ans of complying with this rule shall maintain daily records of system operation an d maintenance which will demonstrate proper operation and compliance o f the emission control device during periods of emission producing activities.



### ( g ) Exemptions [Relocated to section (D) for consistency]

Any person seeking to qualify for any one of the fo llowing exemptions has the burden of proving its existing gas turbin e unit meets the applicable specified criteria.

(1) All provisions of this rule shall not apply to the following:

( A ) Laboratory gas turbine units used in research and t esting.

( B ) Gas turbine units operated exclusively for fire fig hting and/or flood contr ol.

( C ) Chemical processing gas turbine units.

( D ) All existing pipeline gas turbine units located in the Southeast Desert Air Basin (SEDAB).

(2) The provisions of subdivisions (c) and (d), and par agraphs (f)(3), (f)(4) and (f)(5) shall not apply to the fo llowing:

(A) Emergency standby and peaking gas turbine units dem onstrated to operate less than 200 hours per calendar year, which have instal led and maintained in proper operation a non

- resettable engine hour meter.

(B) All existing gas turbine units locat ed in the Southeast Desert Air Basin (SEDAB) which are rated below 4 MW and operate less than 877 hours per year.

(C) All existing gas turbine units located on San Cleme nte Island which are rated below 4 MW and operate less than 877 hours per year

.
However , if the hour

- per

- year limit is exceeded, the exemption shall be auto matically and permanently withdrawn. The operator of any sta tionary gas turbine exempt under this subparagraph must notify the Executive Officer within seven days if the hour

- per

year li mit is exceeded. Within 30 days after the date the hour

- per

- year limit is exceeded, the operator must submit a permit applica tion for modification to equipment to meet the applicable compliance limit within 24 m onths of the date the hour

- per

- year limit is exceeded. Included with this permit application, the operator must submit an emission control plan including a schedule of incre ments of progress for the installationAVAQMD Rule 1134 1134-15

Stationary Gas Turbines D3, 12/14/09 of the required control equipment. This plan and s chedule shall be subject to the revi ew

and approval of the Executive Officer. [Restated in section (G) – Notification Requirements for Exempt and Emergency Standby Units .]

[SIP: Submitted as amended 01/19/10 on mm/dd/yy; S ubmitted as amended 4/11/97 on 8/1/97; Approved _______, _______, 40 CFR 52.220(c)(230)(i) (B)(1)]1134-16 AVAQMD Rule 1134 Stationary Gas Turbines

D3, 12/14/09 This page intentionally left blank.AVAQMD Rule 1134 B

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Final Staff Report, 03/17/10 

### APPENDIX "B" PUBLIC NOTICE DOCUMENTS

1. Proof of Publication for Notice of Public Hearing – Antelope Valley Press, Published 10/16/09B-2 AVAQMD Rule 1134 Final Staff Report, 03/17/10 This page intentionally left blank.AVAQMD Rule 1134 B

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Final Staff Report, 03/17/10B-4 AVAQMD Rule 1134 Final Staff Report, 03/17/10 This page intentionally left blank.AVAQMD Rule 1134 C

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Final Staff Report, 03/17/10 

### APPENDIX "C"

PUBLIC COMMENTS AND RESPONSES

1. County Sanitation Districts of Los Angeles County ( with attachment), 11/02/2009 2. CARB “No Comment” letter, 11/09/09 3. County Sanitation Districts of Los Angeles County e mail, 11/10/2009C-2 AVAQMD Rule 1134 Final Staff Report, 03/17/10 This page intentionally left blank.AVAQMD Rule 1134 C

- 3

Final Staff Report, 03/17/10 Public Comment Letter 1C-4 AVAQMD Rule 1134 Final Staff Report, 03/17/10 1AVAQMD Rule 1134 C

- 5

Final Staff Report, 03/17/10 2

3

4

5C-6 AVAQMD Rule 1134 Final Staff Report, 03/17/10AVAQMD Rule 1134 C

- 7

Final Staff Report, 03/17/10C-8 AVAQMD Rule 1134 Final Staff Report, 03/17/10AVAQMD Rule 1134 C

- 9

Final Staff Report, 03/17/10C-10 AVAQMD Rule 1134 Final Staff Report, 03/17/10AVAQMD Rule 1134 C

- 11

Final Staff Report, 03/17/10C-12 AVAQMD Rule 1134 Final Staff Report, 03/17/10 This page intentionally left blank.AVAQMD Rule 1134 C

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Final Staff Report, 03/17/10 District response to Public Comment Letter 1

1. Per later email correspondence (See public comme nt #3) regarding potential NO x limits for biogas turbines greater than 10MWs, County Sanitation Dist rict of Los Angeles obtained feedback from Solar Turbines (currently the only biogas turbine manufac turer). Solar Turbines indicated that the largest operational biogas turbine is their 10MW Mars100 ga s turbine. Accordingly, the County Sanitation Districts of Los Angeles was unable to identify any applicable emission data from larger biogas turbines. As a result, the Sanitation Districts re commended utilizing existing rule language for biog as turbines (i.e., a reference NO x limit of 25ppm for 0.3 to 10 MW). An additional c ompliance limit has been added for turbines which utilize digester gas and/or landfill gas which does not change the NO x or CO compliance limit for the size range of turbines identified, merely specifies the fuel technology.

2. If an owner or operator of a stationary gas turb ine is required to install emission control equipment for compliance with the rule (see §(F)(1) ), an enhanced emission monitoring device shall be installed (see §(F)(1)(a)(iii), not limited to CEMS or PEMS, see §(B)(10)).

3. The AVAQMD is not mandating the use of specific control technologies.

4. Table 5 in the Technical Report of the Staff Rep ort (Appendix “F”) has been corrected to reflect the appropriate proposed limit of 42 ppmv.

5. The Staff Report has been amended to discuss the significant difficulties and problems associated with several turbine control technologies (See Appe ndix “F” Technical Report, (III)(A)(2)(b)).

The District appreciates the inclusion of the backg round information on “Siloxanes in biogases from landfills and wastewater digesters.”C-14 AVAQMD Rule 1134 Final Staff Report, 03/17/10 This page intentionally left blank.AVAQMD Rule 1134 C

- 15

Final Staff Report, 03/17/10 Comment Letter 2C-16 AVAQMD Rule 1134 Final Staff Report, 03/17/10 This page intentionally left blank.AVAQMD Rule 1134 C

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Final Staff Report, 03/17/10 District response to Comment Letter 2

No comment required.C-18 AVAQMD Rule 1134 Final Staff Report, 03/17/10 This page intentionally left blank.AVAQMD Rule 1134 C

- 19

Final Staff Report, 03/17/10 Public Comment Letter 3C-20 AVAQMD Rule 1134 Final Staff Report, 03/17/10 This page intentionally left blank.AVAQMD Rule 1134 C

- 21

Final Staff Report, 03/17/10 District response to Public Comment Letter 3

Please see public comment letter #1, response 1.C-22 AVAQMD Rule 1134 Final Staff Report, 03/17/10 This page intentionally left blank.AVAQMD Rule 1134 D

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Final Staff Report, 03/17/10 

### APPENDIX "D"

CALIFORNIA ENVIRONMENTAL QUALITY ACT

DOCUMENTATION

1. Notice of Exemption – Los Angeles CountyD-2 AVAQMD Rule 1134 Final Staff Report, 03/17/10 This page intentionally left blank.AVAQMD Rule 1134 D

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Final Staff Report, 03/17/10D-4 AVAQMD Rule 1134 Final Staff Report, 03/17/10 This page intentionally left blank.AVAQMD Rule 1134 E-1

Final Staff Report, 03/17/10 

### APPENDIX "E" BIBLIOGRAPHY

The following documents were consulted in the prepa ration of this staff report and the proposed amendment of Rule 1134:

The following documents were consulted in the prepa ration of this staff report.

1. Sacramento Metropolitan Air Quality Management Dist rict Rule 413 – Stationary Gas Turbines , amended 05-01-97.

2. Sacramento Metropolitan Air Quality Management Dist rict Rule 413 – Stationary Gas Turbines Staff Report, April 6, 1995.

3. Sacramento Metropolitan Air Quality Management Dist rict Agenda Item for Rule 413 – Stationary Gas Turbines , May 1, 1997.

4. San Joaquin Valley Air Pollution Control District R ule 4703 – Stationary Gas Turbines

, amended April 25, 2002.

5. San Joaquin Valley Air Pollution Control District R ule 4703 – Stationary Gas Turbines Final Staff Report, April 25, 2002.

6. South Coast Air Quality Management District Rule 11 34 – Emissions of Oxides of Nitrogen from Stationary Gas Turbines , amended August 8, 1997.

7. South Coast Air Quality Management District Rule 11 34 – Emissions of Oxides of Nitrogen from Stationary Gas Turbines Final Staff Report, April, 1997.

8. MDAQMD Rule 1159 – Stationary Gas Turbines , amended 09/28/2009 02/22/95.

9. USEPA Standards of Performance for Stationary Gas T urbines (71 FR 38482, July 6, 2006).

10. USEPA Standards of Performance for Stationary Gas T urbines (71 FR 9458, February 24, 2006).

11. USEPA Alternative Control Techniques Document - - NO x Emissions from Stationary Gas Turbines (EPA-453/R-93-007), January 1993.

12. CARB Proposed List of Measures to Reduce Particulat e Matter – PM10 and PM2.5 (Implementation of Senate Bill 656, Sher 2003).

13. AVAQMD List and Implementation Schedule for Distric t Measures to Reduce PM Pursuant to Health and Safety Code §39614(d), adopted August 16, 2005.E-2 AVAQMD Rule 1134 Final Staff Report, 03/17/10 14. CARB Report to the Legislature, Gas Fired Power Plant NO x Emission Controls and Related Environmental Impacts, May 2004.

15. CARB Guidance for Power Plant Siting and Best Avail able Control Technology, approved July 22, 1999.AVAQMD Rule 1134 F-1

Final Staff Report, 03/17/10 

### APPENDIX "F" TECHNICAL REPORT

1. Health & Safety Code §39614 Feasibility Analysis fo r Stationary Gas Turbines, d4 03/17/10F-2 AVAQMD Rule 1134 Final Staff Report, 03/17/10 This page intentionally left blank.

# Antelope Valley Air Quality Management District

Technical Report

Health & Safety Code §39614 Feasibility Analysis for Stationary Gas Turbines

December 14, 2009

43301 D IVISION 

### S T 

### ., S UITE 

### 206, L ANCASTER 

### , C ALIFORNIA 

### 93535-4649 P HONE 

### (661) 723-8070 FAX (661) 723-3450This page intentionally left blank.AVAQMD Feasibility Analysis – Stationary Gas Turbin es i

Technical Report d4, 03/17/2010 

### TECHNICAL REPORT TABLE OF CONTENTS

I. EXECUTIVE SUMMARY ...............................

................................................... ...................1

II. INTRODUCTION ...................................

................................................... .............................2

III. TECHNICAL DISCUSSION ..........................

................................................... .....................4

A. SOURCE DESCRIPTION ..............................

................................................... .............4 1. Applicability and District Turbine Inventory.... ...........................................4 2. Currently Available Control Technologies ........ ..........................................5 3. Rule History....................................

................................................... ..........6

B. EMISSIONS.......................................

................................................... ..........................6

C. BASIS FOR STATIONARY GAS TURBINE ANALYSIS ....... ...................................6 1. SMAQMD Rule 413.................................

................................................... 6 2. SJVAQMD Rule 4703 ............................... ..................................................7 3. SCAQMD Rule 1134................................ .................................................10

D. FEASIBILITY OF OPTIONS ..........................

................................................... ..........11

IV. STAFF RECOMMENDATION...........................

................................................... ..............12

Appendix A - Calculations and Assumptions for Deter mining Cost-Effectiveness................... A-1

Appendix B - Bibliography..........................

................................................... .............................B-1ii AVAQMD Feasibility Analysis – Stationary Gas Turbin es Technical Report d4, 03/17/2010 

# Abbreviations

AVAQMD Antelope Valley Air Quality Management Distr ict BACT Best Available Control Technology CARB California Air Resources Board CO Carbon Monoxide DLN Dry Low NO x MDAQMD Mojave Desert Air Quality Management Distric t NH 3 Ammonia NO x Oxides of Nitrogen NSR New Source Review PM Particulate Matter PM 2.5 Fine Particulate Matter PM 10 Coarse Particulate Matter (Respirable) ppmv Parts Per Million by Volume RACT Reasonably Available Control Technology SCAQMD South Coast Air Quality Management District SCR Selective Catalytic Reduction SJVAPCD San Joaquin Air Pollution Control District SMAQMD Sacramento Metropolitan Air Quality Manageme nt District SoLoNO x Dry Low NO x burner technology for Solar Turbines USEPA United States Environmental Protection AgencyAVAQMD Feasibility Analysis – Stationary Gas Turbin es 1

Technical Report d4, 03/17/2010 I. EXECUTIVE SUMMARY

California Health & Safety (H&S) Code §39614 requir es the Antelope Valley Air Quality Management District (AVAQMD) to ensure that all fea sible particulate control measures are in place. To address the full scope of possible parti culate matter (PM) problems, measures to address both directly emitted PM as well as precurs or gases were included in the summaries of California Air Resources Board (CARB) measures and in the list of measures for air districts.

Ambient PM is comprised of both directly emitted PM such as dust or soot, known as primary PM, as well as PM formed in the atmosphere from the reactions of precursor gases, known as secondary PM. These precursor gases include nitroge n oxides (NO x ), sulfur oxides (SO x ), volatile organic compounds (VOC), and ammonia. NO x , SO x , and ammonia combine to form secondary ammonium nitrate and sulfate. VOC can fo rm secondary organic aerosols, as well as participate in the production of secondary ammonium nitrate. NO x and VOC are also precursors of ambient ozone. Sources of ambient PM include co mbustion sources such as trucks and passenger cars, off-road equipment, industrial proc esses, residential wood burning, and forest and agricultural burning; fugitive dust from paved and unpaved roads, construction, mining and agricultural activities; and ammonia from sources s uch as livestock operations, fertilizer application, and motor vehicles. In general, combu stion processes form fine particles, whereas emissions from dust sources tend to be predominantl y coarse particles

The AVAQMD currently has Rule 1134 – Stationary Gas Turbines in place but the existing version of the rule is not applicable in the AVAQMD . Former rule provisions did not apply to stationary gas turbines in the Southeast Desert Air Basin (SEDAB) in which the AVAQMD is located. The proposed amendments will make the rul e applicable to the AVAQMD, therefore expanding the applicability to a wider range of sou rces and will include certain NO x and Carbon Monoxide (CO) limits determined to be feasible. Th e California Air Resources Board (CARB) has identified several stationary gas turbine contr ol measures as potentially feasible. This document evaluates the feasibility of applying thos e control measures within the AVAQMD, using a cost-effectiveness basis to define feasibil ity.

AVAQMD staff recommends amending Rule 1134 – Stationary Gas Turbines to include NO x and CO limits determined to be feasible in the San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) and the Mojave Desert Air Quali ty Management District (MDAQMD) rule analysis.

Reviewed turbine control measures for a variety of turbine sizes and control levels found to be cost-effective and hence feasible ranged from $5,13 9 per ton (NO x , 2008 dollars) up to $11,516. Not cost-effective and hence not feasible control m easures were $18,821 up to $28,225. The cost effectiveness for turbines utilizing digester gas a nd/or landfill gas was not analyzed. The AVAQMD is therefore establishing $11,516 as the cos t-effective (and feasibility) threshold for NO x control measures (in 2008 dollars).2 AVAQMD Feasibility Analysis – Stationary Gas Turbin es Technical Report d4, 03/17/2010 II. INTRODUCTION
This Technical Report is an analysis of the costs a nd cost-effectiveness for various control technologies and levels for reducing NO x emissions from stationary gas turbines. This anal ysis is being made in response to the mandate of H&S Code § 39614(d) and the subsequent CARB document Proposed List of Measures to Reduce Particulate Mat ter – PM 10 and PM

2.5 . The recommendations in this report are based upon a cos t effectiveness threshold of not more than $11,567 per ton of NO x . These cost effectiveness values now define a fea sibility threshold for all subsequent particulate control feasibility analyses for NO x ; all future analysis with cost effectiveness at or below this level will be feasib le.

Former rule provisions had very limited applicabili ty in the AVAQMD, and no turbines in the AVAQMD were subject to the rule. There is one micr oturbine, and two proposed combustion turbine generators, currently located or proposed f or construction within the AVAQMD.

Los Angeles County Sanitation District operates a d igester gas microturbine, an Ingersoll-Rand EcoWorks 250 Series microturbine fired on digester gas, rated at 250 kW(e). This microturbine falls below the 0.3 MW lower applicability limit of Rule 1134, and is therefore not subject to the requirements of Rule 1134 (although it is expected to operate at a nominal 9 ppmv for NO x , CO and VOC which is in compliance with the proposed re quirements in the rule).

The City of Palmdale is proposing to build two comb ustion turbine generators at the Palmdale Hybrid Power Project. Each proposed Turbine is a n atural gas fueled, General Electric, 7FA combustion turbine generator block producing approx imately 255 MW(e) with a connected heat recovery steam generator and a steam condensing tur bine, with maximum turbine heat input of 1736.4 MMBtu/hr. Each proposed turbine has Dry Low NO x (DLN) burners and Selective Catalytic Reduction (SCR) as control measures. The se turbines will be permitted in compliance with the proposed requirements of the rule.

A. California Law

In 2003, the Legislature enacted H&S Code §39614 (S B 656, Sher), to reduce public exposure to PM 10 and PM 2.5 . H&S Code §39614 requires the CARB in consultatio n with local air pollution control and air quality management districts (“air districts”), to develop and adopt, by January 1, 2005, a list of the most readily available, feasibl e, and cost-effective control measures that could be employed by CARB and the air districts to reduce PM 10 and PM 2.5 (collectively PM). The list of proposed control measures was to be based on rul es, regulations, and programs existing in California as of January 1, 2004. H&S Code §39614 also requires that by July 31, 2005, air districts adopt implementation schedules for approp riate measures. Finally, by no later than January 1, 2009, CARB must prepare a report describ ing actions taken to fulfill the requirements of the legislation as well as recommendations for f urther actions to assist in achieving the State PM standards. H&S Code §39614 sunsets on January 1 , 2011, unless extended.

On November 18, 2004, CARB adopted Proposed List of Measures to Reduce Particulate Mat ter – PM 10 and PM

2.5 to satisfy the initial requirements of H&S Code §3 9614. CARB adopted document contains a table entitled “SB 656 List of Air District Measures that Reduce ParticulateAVAQMD Feasibility Analysis – Stationary Gas Turbin es 3

Technical Report d4, 03/17/2010 Matter” (Local PM Measures List). H&S Code §39614( d) requires the AVAQMD to adopt an analysis schedule to determine the feasibility of l ocal measures from this list.

The List and Implementation Schedule for District Measu res to Reduce PM Pursuant to Health & Safety Code §39614(d) was prepared by the AVAQMD to meet the requirement s of H&S Code §39614(d) by analyzing each control measure on the Local PM Measures List and placing each into one of four categories. The first catego ry includes measures that are already being implemented by the AVAQMD in its rules and programs . The second category lists measures that do not need to be implemented within the AVAQM D because there are no sources of that type currently located within the District and any new sources would be required to install Best Available Control Technology (BACT) pursuant to the AVAQMD New Source Review (NSR) regulations. A third category includes those measu res that are included or could be included in rules scheduled for adoption or modification in the near future. The final category lists those measures that require additional cost-effectiveness analysis to determine if such rules are feasible to implement within the AVAQMD. The stationary gas turbine analysis falls into this final category.
District staff has prepared this technical report e ntitled Health & Safety Code §39614 Feasibility Analysis for Stationary Gas Turbines to satisfy the analysis commitment for the turbine s category contained in the PM Implementation List.

In support of this analysis, staff reviewed the fol lowing District rules and documents referenced in the Proposed List of Measures to Reduce Particulate Mat ter – PM 10 and PM

2.5 :

1. Sacramento Metropolitan Air Quality Management Dist rict (SMAQMD) Rule 413 – Stationary Gas Turbines , amended 05/01/97.

2. San Joaquin Valley Air Pollution Control Distric t (SJVAPCD) Rule 4703 – Stationary Gas Turbines , amended 04/25/02.

3. South Coast Air Quality Management District (SCA QMD) Rule 1134 – Emissions of Oxides of Nitrogen from Stationary Gas Turbines , amended 08/08/97.

4. ARB’s report to the Legislature on Gas-Fired Pow er Plant NO x Emission Controls and Related Environmental Impacts, May 2004.

5. ARB’s Guidance for Power Plant Siting and Best A vailable Control Technology, July 22, 1999.

Additional resources utilized in the preparation of the technical discussion include:

1. EPA’s Alternative Control Techniques Document - - N O x Emissions from Stationary Gas Turbines, January 1993.

2. 40 CFR 60, Standards of Performance for Stationary Combustion Turbines; Final Rule, July 6, 2006.

3. 71 FR 9453, Standards of Performance for Stationary Gas Turbines, February 24, 2006.4 AVAQMD Feasibility Analysis – Stationary Gas Turbin es Technical Report d4, 03/17/2010 III. TECHNICAL DISCUSSION

A. SOURCE DESCRIPTION

Gas turbines are available with power outputs rangi ng from less than 1 MW to over 200 MW and are used in a broad scope of applications. A gas t urbine is an internal combustion engine that operates with rotary rather than reciprocating moti on. In stationary applications, the hot combustion gases are directed through one or more f an-like turbine wheels to generate shaft horsepower. Often the heat from the exhaust gases is recovered through an add-on heat exchanger. Gas turbines are used by industry in bo th mechanical and electrical drive applications. The primary applications for gas tur bines can be divided into the following categories: the oil and gas industry, stand-by/emer gency electric power generation, independent electric power producers, electric utilities and ot her industrial applications. 2

1. Applicability and District Turbine Inventory

AVAQMD Rule 1134 currently applies to all existing stationary gas turbines, 0.3 MW and larger, as of August 4, 1989. Pursuant to Section (g), the current rule does not apply to: all existing pipeline gas turbine units located in the Southeast Desert Air Basin (SEDAB); and, all existing gas turbine units located in the Southeast Desert Air Basin (SEDAB) which are rated below 4 MW and operate less than 877 hours per year . Since the AVAQMD is located within the SEDAB, former rule provisions had very limited applicability in the AVAQMD, and no turbines in the AVAQMD were subject to the rule. T his rule is proposed for amendment to make rule provisions applicable within the AVAQMD.

There is one microturbine and two proposed combusti on turbine generators currently located or proposed for construction within the district.

Los Angeles County Sanitation District operates a d igester gas microturbine, an Ingersoll-Rand, EcoWorks 250 Series, microturbine fired on digester gas, rated at 250 kW(e). This microturbine falls below the 0.3 MW lower applicability limit of Rule 1134, and is therefore not subject to the requirements of Rule 1134 (although it is expected to operate at a nominal 9 ppmv for NO x , CO and VOC which is in compliance with the proposed re quirements in the rule).

The City of Palmdale is proposing to build two comb ustion turbine generators at the Palmdale Hybrid Power Project. Each proposed Turbine is a n atural gas fueled, General Electric, 7FA combustion turbine generator block producing approx imately 255 MW(e) with a connected heat recovery steam generator and a steam condensing tur bine, with maximum turbine heat input of 1736.4 MMBtu/hr. Each proposed Turbine has Dry Low NO x (DLN) burners and Selective Catalytic Reduction (SCR) as control measures. The se turbines will permitted in compliance with the proposed requirements of the rule.

2 EPA, Alternate Control Techniques Document - - NOx Emiss ions from Stationary Gas Turbines, Chapter 3, January 1993.AVAQMD Feasibility Analysis – Stationary Gas Turbin es 5

Technical Report d4, 03/17/2010 2. Currently Available Control Technologies

Add-on technologies for reducing NO x available for stationary gas turbines include comb ustion controls (Dry low-NO x (DLN)), Selective Catalytic Reduction (SCR), or a c ombination of controls, and alternative fuels.

a. Combustion Controls (Dry Low-NO x (DLN))

The DLN system reduces thermal NO x formation without injecting water or steam. DLN u ses specially designed burner elements to change the tu rbine’s combustion mechanics, reducing flame temperature. Two designs have been developed : lean premixed combustion and rich/quench/lean staged combustion. Controlled NO x emission levels using dry lean premixed combustion range from 9 to 42 ppmv for operation on natural gas fuel. The low end of this range (9 to 25 ppmv) has been limited to turbines above 2 0 MW. 3 Controlled NO x emissions from smaller turbines typically range from 25 to 42 ppmv

. DLN is commonly found on new turbines. Specificall y tailored retrofit technology may not be commercially available for all turbines. Turbine m anufacturers estimate retrofit costs to be approximately 40 to 60 percent higher than new equi pment costs. As stated by Southern California Gas in 1991, Dry Low-NO x combustors are very promising technology for many gas turbines. However, turbine manufacturers have not and will not develop low NO x combustors for obsolete, older models.

b. SCR

An SCR system treats flue gas using an ammonia (NH 3 ) injection system and a catalytic reactor to reduce NO x . An injection grid disperses NH 3 in the flue gas upstream of the catalyst and the NH 3 and NO x are reduced to nitrogen (N 2) and water in the catalyst reactor. This control technique reduces both thermal NO x and fuel NO x . Most SCR installations use a base-metal catalyst with an operating temperature window of 40 0oF to 800oF. This operating temperature has limited SCR to cogeneration or combined cycle a pplications with reduced flue gas temperatures. High-temperature zeolyte catalysts w hich have an operating window of up to 1100oF are now available that offer potential for S CR applications with simple cycle gas turbines.

Fouling of add-on air pollution control equipment, such as SCR catalysts, has resulted from the use of biogases. 4 Volatile methylsiloxanes and linear polydimethyls iloxanes (siloxanes), generated as components of biogases from digesters at wastewater treatment plants and solid waste landfills, have been identified as potentiall y causing significant operational problems. South Coast Air Quality Management District (SCAQMD ) noted this issue in their final staff

3 EPA, Alternate Control Techniques Document - - NOx Emiss ions from Stationary Gas Turbines, Pg. 2-10, January 1993. 4 McBean, Edward, Siloxanes in biogases and wastewater digesters , Canadian Journal of Civil Engineering, 35:431-436 (2008).6 AVAQMD Feasibility Analysis – Stationary Gas Turbin es Technical Report d4, 03/17/2010 report for Proposed Amended Rule 1134 – Emissions o f Oxides of Nitrogen from Stationary Gas Turbines, April 1997. 5

c. Alternative Fuels

Using fuels with flame temperatures lower than thos e of natural gas or distillate oils results in lower thermal NO x emissions. Coal-derived gas and methanol have dem onstrated lower NO x emissions than more conventional natural gas or oil fuels. A demonstration facility used coal gas in the early 1980’s but there were no confirmed met hanol-fueled turbines operating in 1993.

3. Rule History

The AVAQMD adopted Rule 1134 – Stationary Gas Turbines on 08/04/89, and amended on 12/07/95 and 04/11/97. The 04/11/97 amendment is t he version currently in the AVAQMD Rule Book, and the 12/07/95 amendment is the version in the SIP.

B. EMISSIONS

The following emission limits contained in AVAQMD R ule 1134 are applicable to stationary gas turbines located in AVAQMD, other than pipeline gas turbine units:

Unit Size Megawatt (MW) Rating and operating at lea st 877 hours per year NO x , ppm

4 MW and Over 9
The AVAQMD has no existing units subject to the emi ssion limits in current Rule 1134.

C. BASIS FOR STATIONARY GAS TURBINE ANALYSIS

This analysis examines the cost-effectiveness of im plementing certain district rules as required by H&S Code §39614 to reduce public exposure to PM 10 and PM 2.5 . These rules were determined to be a list of the most readily availab le, feasible, and cost-effective control measures that could be employed by CARB and the air district s to reduce PM 10 and PM 2.5 (collectively PM). Appendix B of the Proposed List of Measures to Reduce Particulate Mat ter , Strategy D – Combustion Sources Measures reduce NO x , SO x , VOC, CO, or PM10 and PM2.5, item 46(a, b, and c), refer to three rules: SMAQMD Rule 413 – Stationary Gas Turbines (5/1/97), SJVAPCD Rule 4703 – Stationary Gas Turbines (4/25/02), and SCAQMD Rule 1134 – Emissions of Oxides of Nitrogen from Stationary Gas Turbines (8/8/97) on which to base this analysis.

The following rule requirements were analyzed to de termine their feasibility for stationary gas turbines in the AVAQMD:

1. SMAQMD Rule 413 – Stationary Gas Turbines, Amended 05/01/97

5 SCAQMD Final Staff Report for Proposed Amended Rule 1134 – Emissions of Oxides From Stationary Gas Turbines , April 1997, Page I-2.AVAQMD Feasibility Analysis – Stationary Gas Turbin es 7

Technical Report d4, 03/17/2010 This amendment of the rule applies to all stationar y gas turbines with ratings equal to or greater than 0.3 MW output, or 3 MMBTU/hr input and operate d on gaseous and/or liquid fuel for the purpose of limiting emissions of NO x to the atmosphere. (This rule was subsequently am ended 03/24/05).

Exemption is made for emergency standby units used to provide emergency electrical power, emergency water pumping for flood control or firefi ghting, emergency potable water pumping, or emergency sewage pumping providing the following re quirements are met:

a. Operation for maintenance purposes shall be limited to 100 hours and scheduled to limit air quality impact; b. Operation shall be limited to 200 hours per year;

c. Operation shall not be for supplying power to a ser ving utility or distribution on the grid; and d. Operation for other than maintenance shall be limit ed to actual interruptions of electrical power by the serving utility, emergency water pumpi ng for flood control or firefighting, emergency potable water pumping, or emergency sewag e pumping.

Exemptions are also made for units removed from ser vice before May 31, 1997, laboratory gas turbine units used in research and testing for the advancement of gas turbine technology, and for the startup/shutdown period not exceed one hour for startup and one hour for shutdown.

Table 1 Summary of RACT and BARCT requirements contained in SMAQMD Rule 413

NO x Emission Limit (ppmv) Requirements Time of

Operation (hr/yr) Unit Size Rating

(MW) Gaseous Fuel Liquid Fuel

RACT any ≥ 0.3 42.0 65.0

any ≥ 0.3 to <2.9 42.0 65.0

<877 ≥ 2.9 42.0 65.0

≥ 877 ≥ 2.9 to <10 25.0 65.0

≥ 877 ≥ 10 to (no SCR) 15.0 42.0 BARCT

≥ 877 ≥ 10 (w SCR) 9.0 25.0

2. SJVAPCD Rule 4703 – Stationary Gas Turbines, Amended 04/25/02

The provisions of this rule apply to all stationary gas turbines, which are subject to District permitting requirements, and with rating equal to o r greater than 0.3 MW and/or a maximum heat input rating of more than 3,000,000 BTU per hour, f or the purpose of limiting NO x emissions8 AVAQMD Feasibility Analysis – Stationary Gas Turbin es Technical Report d4, 03/17/2010 from stationary gas turbine systems, as of April 25 , 2002. (This rule was subsequently amended 08/17/06 and 09/20/07)

Those units exempted from Emission Control Plan req uirements are those used as laboratory units used in the research and testing for the adva ncement of gas turbine technology, and units limited by permit condition to be operated exclusiv ely for firefighting and/or flood control. The provisions of this rule with the exception of the E mission Control Plan and record keeping provisions do not apply to emergency standby units limited by permit condition to operate less than 200 hours per calendar year for maintenance an d testing purposes, and units less than 4 MW in rating and limited by permit condition to operat e less than 877 hours per calendar year.AVAQMD Feasibility Analysis – Stationary Gas Turbin es 9

Technical Report d4, 03/17/2010 Table 2 Summary of Tier 2 NO x Compliance Limits contained in SJVAPCD Rule 4703

NO x Compliance Limit, ppmvd at

15% O 2 Turbine Classification Rating Gas Fuel Liquid Fuel

a) Less than 2.0 MW Solar Saturn, driving a centrif ugal
compressor 50 50

b) No greater than 10 MW, if a DLN System is commercially available for the specific unit, as of April 30, 2003. 25 65

c) No greater than 10 MW, if a DLN System is not commercially available for the specific unit, as of April 30, 2003. 35 65

5 (Standard 6 ) 25 (Standard) d) Greater than 10 MW, Combined cycle. 3 (Enhanced 7 ) 25 (Enhanced)

5 (Standard) 25 (Standard) e) Greater than 10 MW, Simple cycle, and permit condition for greater than 877 hrs/yr operation 3 (Enhanced) 25 (Enhanced)

25 (Standard) 42 (Standard) f) Greater than 10 MW, Simple cycle, and permit condition for no greater than 877 hrs/yr operation. 5 (Enhanced) 25 (Enhanced)

6 Standard Compliance option required compliance wit h rule limits by dates ranging from 04/25/2002 to 04/25/2005.
7 Operators complying with the Enhanced Compliance o ption had until 04/30/2008 to demonstrate and maintain compliance with enhanced l imit, or to demonstrate and maintain compliance within 90 days following next major over haul if occurring after 04/30/2004.10 AVAQMD Feasibility Analysis – Stationary Gas Turbin es Technical Report d4, 03/17/2010 Table 3 Summary of CO Compliance Limits contained in SJVAPC D Rule 4703

Stationary Gas Turbine CO Compliance Limit, ppmv at 15% O 2

Units not identified below 200

General Electric Frame 7 25

General Electric Frame 7 with Quiet Combustors 52

Less than 2.0 MW Solar Saturn gas turbine powering centrifugal
compressor 250

3. SCAQMD Rule 1134 – Emissions of Oxides of Nitrogen from Stationary Gas Turbines, Amended 08/08/97

The provisions of SCAQMD Rule 1134 apply to all sta tionary gas turbines, 0.3 MW and larger, as of August 4, 1989.

Laboratory gas turbine units used in research and t esting, gas turbine units used exclusively for firefighting and/or flood control, chemical process ing gas turbine units, and all existing pipeline gas turbines located in the Southeast Desert Air Ba sin (SEDAB) are exempt from this rule. Emissions limitations, and monitoring and source te sting and certain recordkeeping requirements do not apply to emergency standby and peaking gas t urbine units operating less than 200 hours per calendar year, or existing gas turbines units l ocated in the SEDAB as well as on San Clemente Island rated below 4 MW and operating less than 877 hours per year.

Compliance Limit

= Reference Limit %

25 EFF ×

Where:

Compliance limit = allowable NO x emissions (ppm by volume) Reference Limit = the NO x emission limit (ppm by volume) corrected to 15 perc ent oxygen on a

dry basis, and averaged over 15 consecutive minutes . These limits for various MW ratings (continuous rating by the manufacturer w ithout power augmentation) are as follows:AVAQMD Feasibility Analysis – Stationary Gas Turbin es 11

Technical Report d4, 03/17/2010 Table 4

Reference NO X Limits, ppm contained in SCAQMD Rule 1134

Unit Size Megawatt (MW) Rating Effective 12/31/1995

0.3 to Less Than 2.9 MW 25

2.9 to Less Than 10.0 MW 9

2.9 to Less Than 10.0 MW No SCR 15

10.0 MW and Over 9

10.0 MW and Over No SCR 12

60 MW and Over Combined Cycle No SCR 15

60 MW and Over Combined Cycle 9

2.9 to Less Than 10.0 MW Utilizing Fuel Containing a Minimum of 60% Sewage Digester Gas by Volume on a Daily Averag e 25

EFF = 3413 × 100% (Actual heat rate at HHV of fuel (BTU/KW-HR))

or,

EFF = Manufacturer’s stated efficiency at LHV HHV LHV ×

or,
EFF = the demonstrated percent efficiency of the ga s turbine unit only as calculated without consideration of any downstream energy recovery fro m the actual heat rate, (BTU/KW HR) or 1.34 BTU/HP; corrected to the HHV of the fuel, as m easured at the peak load for that facility; or the manufacturer’s continuous rated percent efficie ncy of the gas turbine unit after correction from LHV to the HHV of the fuel, whichever is highe r. The value of EFF shall not be less than 25 percent. Gas turbine units with lower efficienc ies will be assigned a 25 percent efficiency for this calculation.

Operators of stationary gas turbines shall be subje ct to SCAQMD Regulation XIII if CO emissions increase as a result of the application o f NO x controls.

D. FEASIBILITY OF OPTIONS

1. Portable Flight-Line Equipment – Exempt by classifi cation (portable) and limited usage. These units were also exempt by definition from the previous version of12 AVAQMD Feasibility Analysis – Stationary Gas Turbin es Technical Report d4, 03/17/2010 the rule. Based on portability the AVAQMD finds th at applying an add-on control technology requirement to these units is not feasib le.

2. Microturbines – Exempt by size (less than 300 kW) b y definition from the previous version of the rule. Based on size the AV AQMD finds that applying an add-on control technology requirement to these unit s is not feasible.

3. Palmdale Hybrid Power Project Combustion Turbines – Subject to the rule but also subject to New Source Review and Best Availabl e Control Technology (BACT). Compliance with BACT will also require com pliance with the proposed rule, and compliance with BACT is not subject to fe asibility analysis.

IV. STAFF RECOMMENDATION

AVAQMD staff recommends amending Rule 1134 – Stationary Gas Turbines to apply District wide, and to include NO x and CO limits determined to be feasible in the SJV UAPCD rule analysis. The amended rule will contain several ex ceptions resulting from special classification.

Table 5 Proposed Limits in Rule 1134

NO x Compliance Limit, ppmv at 15% Oxygen Control Operating

hours per
year Turbine

Rating
Gas Fuel Liquid Fuel CO Compliance Limit, ppmv at 15% Oxygen
SCR + DLN > 877 > 10 MW 5 25 200 DLN > 877 2 – 10 MW 25 65 200

SCR > 877 2 – 10 MW (no DLN available) 35 65 200

DLN > 877 < 2 MW 42 50 250 SCR or DLN < 877 > 10 MW 25 42 200 Any (fired on Digester Gas and/or Landfill Gas) any 0.3 – 10 MW 25 N/A 200

A specific category for digester gas or landfill ga s fired turbines has been added to allow for compliance by units whose exhaust contains componen ts which are not compatible with efficient selective catalytic reduction.AVAQMD Feasibility Analysis – Stationary Gas Turbin es 13

Technical Report d4, 03/17/2010 New or clarified exemptions to limits in amended Ru le 1134 include portable flight-line equipment and microturbines.

These recommendations for amending Rule 1134 fulfil l the District commitment to analyze and implement measures to reduce PM in response to CARB document Proposed List of Measures to Reduce Particulate Matter – PM 10 and PM

2.5 measure 46(a, b, and c).14 AVAQMD Feasibility Analysis – Stationary Gas Turbin es Technical Report d4, 03/17/2010 This page intentionally left blank.AVAQMD Feasibility Analysis – Stationary Gas Turbin es A

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### Appendix “A” Calculations and Assumptions for Determining Cost-E ffectiveness

Table 6 San Joaquin Valley Unified APCD Cost Effectiveness Calculation Summary

Turbine Size (MW) Current

Limit (ppmv) New

Limit (ppmv) Reductions

(tons/year) Annualized

Costs ($/year) Growth

Factor (2002 to 2008 Dollars) Cost

Effectiveness ($/ton/year) Control

Method

3.5 42 35 3.7 33,700 40,240 10,876 Increase WI/SI

3.5 42 25 9 86,800 103,644 11,516 DLN Retrofit

3.5 42 9 17.4 307,840 367,577 21,125 Add SCR

25 42 5 100.1 969,672 1,157,839 11,567 Add SCR

25 12 5 18.9 81,350 97,136 5,139 Increase SCR

50 42 5 184.2 1,204,111 1,437,771 7,805 Add SCR

75 22 5 187.6 1,539,489 1,838,230 9,799 Add SCR

Limited Operation ( ≤ 877 hr/year)

50 42 5 47.2 851,097 1,016,254 21,531 Add SCR

Note: Highlighted values not deemed cost effective by SJVUAPCD and limits not included in their rule.A-2 AVAQMD Feasibility Analysis – Stationary Gas Turbin es Technical Report d4, 03/17/2010 This page intentionally left blank.AVAQMD Feasibility Analysis – Stationary Gas Turbin es B

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### Appendix “B” Bibliography

1. Sacramento Metropolitan Air Quality Management Dist rict Rule 413 – Stationary Gas Turbines , amended 05-01-97.

2. Sacramento Metropolitan Air Quality Management Dist rict Rule 413 – Stationary Gas Turbines Staff Report, April 6, 1995.

3. Sacramento Metropolitan Air Quality Management Dist rict Agenda Item for Rule 413 – Stationary Gas Turbines , May 1, 1997.

4. San Joaquin Valley Air Pollution Control District R ule 4703 – Stationary Gas Turbines

, amended April 25, 2002.

5. San Joaquin Valley Air Pollution Control District R ule 4703 – Stationary Gas Turbines Final Staff Report, April 25, 2002.

6. South Coast Air Quality Management District Rule 11 34 – Emissions of Oxides of Nitrogen from Stationary Gas Turbines , amended August 8, 1997.

7. South Coast Air Quality Management District Rule 11 34 – Emissions of Oxides of Nitrogen from Stationary Gas Turbines Final Staff Report, April, 1997.

8. MDAQMD Rule 1159 – Stationary Gas Turbines , amended 09/28/2009.

9. USEPA Standards of Performance for Stationary Gas T urbines (71 FR 38482, July 6, 2006).

10. USEPA Standards of Performance for Stationary Gas T urbines (71 FR 9458, February 24, 2006).

11. USEPA Alternative Control Techniques Document - - NO x Emissions from Stationary Gas Turbines (EPA-453/R-93-007), January 1993.

12. CARB Proposed List of Measures to Reduce Particulat e Matter – PM10 and PM2.5 (Implementation of Senate Bill 656, Sher 2003).

13. AVAQMD List and Implementation Schedule for Distric t Measures to Reduce PM Pursuant to Health and Safety Code §39614(d), adopted August 16, 2005.

14. CARB Report to the Legislature, Gas Fired Power Plant NO x Emission Controls and Related Environmental Impacts, May 2004.B-2 AVAQMD Feasibility Analysis – Stationary Gas Turbin es Technical Report d4, 03/17/2010 15. CARB Guidance for Power Plant Siting and Best Avail able Control Technology, approved July 22, 1999.