AIR PERMITS OFFICE 

Avenal Energy Project (SJ 08-01) 

0526EPA_AVENAL-MEMO TO FILE_PERMIT REVN_SR.DOC 

DATE: May 26, 2011 

TO: Avenal Energy Project PSD Permit Decision Project File 

FROM: Shirley Rivera (AIR-3) 

SUBJECT: Final Permit Requirements – Selected Background Information 

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

Energy Project (AEP) PSD permit that differ from those in the proposed permit. This information 

pertains to the following topics: 

• Auxiliary Boiler – PM and PM10 hourly emissions rate 

• Turbines – CO emission limit 

• Turbines – CO hourly emissions rate in lb/hr 

• Turbines – Limits for startup and shutdown duration 

Auxiliary Boiler – PM / PM10 hourly emissions rate

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

administrative correction by adding a PM/PM10 emissions limit of 0.0034 grains/dscf (gr/dscr) for the 

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

source test the auxiliary boiler through an initial performance test and revised the permit language to 

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

commensurate emission limit in gr/dscf for the initial and subsequent testing was calculated to be 0.0034 

gr/dscf based on the following application information and the F-Factor methodology (40 CFR Part 60, 

Appendix A, Method 19). (Assume all PM10=PM) 

Given: Table 6.2-1.2 (Appendix 6.2-1), Auxiliary Boiler Specifications 

Boiler, MMBtu/hr (HHV) 37.4

PM10, lb/MMBtu 0.0050

Conversion factor and references: 7,000 grains/lb 

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

 %O2 = 3% 

Calculation methodology: 

(lb PM10/MMBtu) / (F-factor) / (20.9 / (20.9 - %O2)) * 7,000 grains/lb = gr PM10/dscf

Where 

(0.0050) / (8,710) / (20.9 / (20.9-3)) * 7,000 = 0.0034 gr PM10/dscf

Turbines – CO emission limit

The Kleen Energy facility was cited in public comments EPA received in 2009 with respect to CO 

emission limits for the AEP. On Thursday, May 12, 2011, I spoke with representatives of the Connecticut 

Department of Environmental Protection (DEP) regarding the status of the Kleen Energy facility; i.e., 
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whether the facility was operational and attaining its permitted limits. I spoke briefly with the following 

personnel: 

• Ric Pirolli (ric.pirolli@ct.gov), Assistant Director of Permitting 

• Louis “Lou” Corsino (louis.corsino@ct.gov), Permit Engineer (for Kleen Energy permit) 

• Stephen Anderson (stephen.andreson@ct.gov ), Stack Test Supervisor 

Mr. Pirolli directed me to Mr. Corsino regarding the permit status. Mr. Corsino directed me to Mr. 

Anderson regarding the source test status. The information provided is summarized as follows: 

• Mr. Corsino – The CO emission limits remain the same as permitted; Mr. Corsino forwarded a 

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

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

fire on April 21, 2011. 

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

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

presuming that source testing would begin at some time during the Summer of 2011. 

Turbines – CO hourly emissions rate in lb/hr

We have added a CO emission limit (after a demonstration period) of 1.5 ppmvd @ 15% O2 for each gas 

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

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

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

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

 Concentration limit = 1.5 ppm CO @ 15% O2 by volume (dry) 

(or 1.5 ppmvd CO @ 15% O2) 

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

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

 Convert, ppm NOx (for NO2) = 1.194 x 10E-07 lb/scf NOx

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

 % O2 = 15% 

Calculation methodology: 

(CO ppmvd) * (F-factor) * (Convert) * (CO MWt / NO2 MWt) *(20.9 / (20.9 - %O2)) 

[=] lb/MMBtu * (Turbine, MMBtu/hr) 

[=] lb/hr

where 

(1.5) * (8,710) * (1.194 x 10E-07) * (28 / 46) * (20.9 / (20.9-15)) * (1,856.3) 

= ~ 6.27 lb/hr of CO

Turbines – limits for startup and shutdown duration

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

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

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

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

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

Generating Station was the project most similar to the Avenal Energy Project. The startup duration in the 
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PSD permit issued by EPA Region 9 for Colusa Generating Station was limited to 270 minutes (or 4.50 

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

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