Mojave Desert 

Air Quality Management District 

Final 

Staff Report 

Proposed Amendments to 

Rule 1159 – Stationary Gas Turbines 

Adopted on 

September 28, 2009 

14306 PARK AVE, VICTORVILLE, CA 92392-2310 

PHONE: (760) 245-1661 

FAX: (760) 245-2699 
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MDAQMD Rule 1159 TC-1

Final Staff Report, 01/12/10

STAFF REPORT 

TABLE OF CONTENTS

Rule 1159 – 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 Rules & Regulations ..................................... 4 

a. Necessity..................................................................................................................... 4 

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

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

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

e. Non-duplication .......................................................................................................... 5 

f. Reference .................................................................................................................... 5 

g. Public Notice & Comment, Public Hearing................................................................ 5 

2. Federal Elements (SIP Submittals, Other Federal Submittals)....................................... 5

a. Satisfaction of Underlying Federal Requirements...................................................... 5 

b. Public Notice and Comment ....................................................................................... 6 

c. Availability of Document ........................................................................................... 6 

d. Notice to Specified Entities ........................................................................................ 6 

e. Public Hearing ............................................................................................................ 7 

f. Legal Authority to Adopt and Implement................................................................... 7 

g. Applicable State Laws and Regulations Were Followed............................................ 7 

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS ............................................ 8 

C. ECONOMIC ANALYSIS .................................................................................................. 8 

1. General............................................................................................................................ 8 

2. Incremental Cost Effectiveness....................................................................................... 8 

D. ENVIRONMENTAL ANALYSIS (CEQA)....................................................................... 9 

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS ..................................................... 9 

1. Potential Environmental Impacts.................................................................................... 9 

2. Mitigation of Impacts...................................................................................................... 9 

3. Alternative Methods of Compliance............................................................................... 9 

F. PUBLIC REVIEW............................................................................................................ 10 

VI. TECHNICAL DISCUSSION .............................................................................................. 10 

A. SOURCE DESCRIPTION................................................................................................ 10 

B. EMISSIONS ..................................................................................................................... 10 

C. CONTROL REQUIREMENTS........................................................................................ 10 

D. PROPOSED RULE SUMMARY..................................................................................... 11 

E. SIP HISTORY .................................................................................................................. 12 

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

a. SIP in the San Bernardino County Portion of MDAQMD ....................................... 12 

b. SIP in the Riverside County Portion of the MDAQMD........................................... 13 
TC-2 MDAQMD Rule 1159 

Final Staff Report, 01/12/10

2. SIP Analysis.................................................................................................................. 13 

Appendix A - 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 Documentation ....................................... D-1 

Appendix E - Bibliography..........................................................................................................E-1 

Appendix F – Technical Report...................................................................................................F-1 
MDAQMD Rule 1159 1

Final Staff Report, 01/12/10 

STAFF REPORT 

Rule 1159 – Stationary Gas Turbines

I. PURPOSE OF STAFF REPORT 

A staff report serves several discrete purposes. Its primary purpose is to provide a summary and 

background material to the members of the Governing 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 document. In addition, a staff report 

ensures that the correct procedures and proper documentation for approval or adoption of a 

document have been performed. Finally, the staff report provides evidence for defense against 

legal challenges regarding the propriety of the approval or adoption of the document. 

II. EXECUTIVE SUMMARY 

The Mojave Desert Air Quality Management District (MDAQMD) has the authority pursuant to 

California Health and Safety Code (H&S Code) §40702 to adopt, amend or repeal rules and 

regulations. The MDAQMD is proposing to amend Rule 1159 – Stationary Gas Turbines for 

inclusion in the current rulebook. 

H&S Code §39614(d) requires the MDAQMD to adopt the most readily available, feasible and 

cost-effective local control measures for Particulate Matter (PM) as contained on a list developed 

by CARB. CARB has identified on its list of local control measures several items related to 

stationary gas turbines as potentially feasible. The District has evaluated the availability, 

feasibility and cost-effectiveness of applying those combustion source control measures related 

to stationary gas turbines within the MDAQMD in the Feasibility Analysis for Stationary Gas 

Turbines included in Appendix “F”. This analysis determined that such measures were indeed 

cost effective and therefore MDAQMD staff recommends amending Rule 1159 – Stationary Gas 

Turbines. The proposed amendments include expanding the rule to apply on a District wide 

basis, and to include certain NOX and Carbon Monoxide (CO) limits determined to be feasible. 

The proposed amendments to the rule will also contain several exceptions for certain types of 

sources for specific control measures which were found to be technically infeasible, and noncosteffective. Comments from the California Air Resources Board (CARB), United States 

Environmental Protection Agency (USEPA), and Pacific Gas & Electric have also been 

incorporated into the proposed amendments to the rule. These changes include correcting a 

proposed NOX limit for units smaller than 2 MW with DLN to avoid a State Implementation Plan 

(SIP) relaxation; lowering the time a unit has to come into compliance after losing its exemption 

by operating in excess of its hour per year limit from 24 to 18 months; removing the proposed 

reference to “the most current version” of ASTM test methods; adding a provision for 

compliance of new turbines upon installation; adding a two (2) year time limit in the record 

retention section; adding several definitions for clarification; adding a provision for compliance 

of new turbines upon installation; adding a two (2) year time limit in the record retention section; 

adding several definitions for clarification; adding a provision requiring the minimization of 

emissions during Thermal Stabilization Periods, startup periods and shutdown periods. 
2 MDAQMD Rule 1159 

Final Staff Report, 01/12/10

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, reductions in ozone precursor emissions 

(NOX and VOC) from existing sources through the adoption of Reasonable Available Control 

Technology (RACT)). This rule updates NOX RACT for the Stationary Gas Turbine category. 

The public hearing to consider the amendment of Rule 1159 was originally noticed for the 

06/22/09 Mojave Desert Air Quality Management District (MDAQMD) Governing Board 

meeting. The MDAQMD received substantive comments from the United States Environmental 

Protection Agency (USEPA) on 06/03/09 and 07/09/09, and comments from CARB on 06/15/09 

and 07/21/09 and continued this public hearing since these comments could not be addressed 

prior to the 06/22/09 meeting. The public hearing to consider the amendment of Rule 1159 was 

re-noticed for the 08/24/09 Governing Board meeting. This public hearing was again continued 

to the next regularly scheduled meeting to address additional substantive comments from Pacific 

Gas & Electric received on 08/10/09 

III. STAFF RECOMMENDATION 

Staff and the Technical Advisory Committee recommend that the Governing Board of the 

MDAQMD adopt the proposed amendment of Rule 1159 – Stationary Gas Turbines and approve 

the appropriate CEQA documentation. This action is necessary to satisfy the provisions of H&S 

Code §39614(d) which requires the adoption of readily available, feasible and cost-effective 

control measures for particulate matter from a list of potential local control measures 

promulgated by CARB. The level of control contained in proposed Rule 1159 has been 

determined to be readily available, feasible and cost-effective based upon an analysis and 

recommendations made in the feasibility analysis for stationary gas turbines included in the 

Technical Discussion of the Staff Report. 

The Governing Board of the Mojave Desert Air Quality Management District amended Rule 

1159 – Stationary Gas Turbines on September 28, 2009. 
MDAQMD Rule 1159 3

Final Staff Report, 01/12/10 

IV. LEGAL REQUIREMENTS CHECKLIST 

The findings and analysis as indicated below are required for the procedurally correct 

amendment of Rule 1159 – Stationary Gas Turbines. Each item is discussed, if applicable, in 

Section V. Copies of related documents are included in the appropriate appendices. 

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 Review 
4 MDAQMD Rule 1159 

Final Staff Report, 01/12/10

V. DISCUSSION OF LEGAL REQUIREMENTS 

A. REQUIRED ELEMENTS/FINDINGS 

This section discusses the State of California statutory requirements that apply to the 

amendment of Rule 1159. These are actions that need 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 regulation, the District 

Governing Board is required to make findings of necessity, authority, clarity, 

consistency, non-duplication, and reference based upon relevant information 

presented at the hearing. The information below is provided to assist the Board in 

making these findings. 

a. Necessity: 

The amendment of Rule 1159 was necessary to satisfy the 

provisions of H&S Code §39614(d) which requires the adoption of 

readily available, feasible and cost-effective control measures for 

particulate matter from a list of potential local control measures 

promulgated by CARB. The level of control contained in amended 

Rule 1159 has been determined to be readily available, feasible 

and cost-effective based upon an analysis and recommendations 

made in the feasibility analysis for stationary gas turbines included 

in the Technical Discussion in the Staff Report. The 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: 

The District has the authority pursuant to California Health and 

Safety Code (H & S Code) §40702 to adopt, amend or repeal rules 

and regulations. 

c. Clarity: 

Amended Rule 1159 is clear in that it is written so that the persons 

subject to the rule can easily understand the meaning. 

d. Consistency: 

Amended Rule 1159 is in harmony with, and not in conflict with or 

contradictory to any State law or regulation, Federal law or 

regulation, or court decisions. 
MDAQMD Rule 1159 5

Final Staff Report, 01/12/10

e. Non-duplication: 

Amended Rule 1159 does not impose the same requirements as 

any existing State or Federal law or regulation because the District 

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 Particulate Matter 

from a list of potential local control measures promulgated by 

CARB. In addition, the amendments do not impose the same 

requirements as Federal 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 impose such measures upon 

such facilities. 

f. Reference: 

The District has the authority pursuant to H&S Code §40702 to 

adopt, amend or repeal rules and regulations. 

g. Public Notice & Comment, Public Hearing: 

Notice for the public hearing for the proposed amendment of Rule 

1159 was published 05/15/2009 for the 06/22/09 Governing Board 

meeting. The hearing was continued and re-noticed for the 

08/24/09 Governing Board meeting to address substantive 

comments. The hearing was again continued to the 09/28/09 

Governing Board meeting to address additional substantive 

comments. See Appendix “B” for copies of the public notice. See 

Appendix “C” for copies of comments and District responses. 

2. Federal Elements (SIP Submittals, Other Federal Submittals). 

Submittals to USEPA are required to include various elements depending upon 

the type of document submitted and the underlying Federal law that requires the 

submittal. The information below indicates which elements are required for the 

amendment of Rule 1159 and how they were satisfied.

a. Satisfaction of Underlying Federal Requirements: 

The amendments to Rule 1159 are subject to all the requirements 

for a State Implementation Plan (SIP) submittal because Rule 1159 

is currently included in the MDAQMD SIP. In addition, rules 

imposing RACT requirements enacted to satisfy the requirements 

of 42 U.S.C. 7502(c)(1) are also required to be included in the SIP. 

The criteria for determining completeness of SIP submissions are 

set forth in 40 CFR Part 51, Appendix V, 2.0. 
6 MDAQMD Rule 1159 

Final Staff Report, 01/12/10

b. Public Notice and Comment: 

Notice for the public hearing for the proposed amendment of Rule 

1159 was published 05/15/2009 for the 06/22/09 Governing Board 

meeting. The hearing was continued and re-noticed for the 

08/24/09 Governing Board meeting to address substantive 

comments. The hearing was again continued to the 09/28/09 

Governing Board meeting to address additional substantive 

comments. See Appendix “B” for copies of the public notice. See 

Appendix “C” for copies of comments and District responses. 

c. Availability of Document: 

Copies of the proposed amendment of Rule 1159 and the 

accompanying draft Staff Report were made available to the public 

on 05/11/2009. Substantive comments were received from 

USEPA on 06/03/09 and CARB on 06/15/09. Copies of the 

proposed amendments to Rule 1159 and the accompanying draft 

Staff Report were again made available to the public on or before 

07/10/09 incorporating changes and responses to the substantive 

comments from USEPA and CARB. An additional comment was 

received from USEPA on 07/09/09. An additional provision was 

added to the proposed amended rule as a result of this comment, 

and although not determined to be substantive, this version of the 

proposed revised rule was again made available to all interested 

and affected parties. An additional comment was received from 

CARB 07/21/09. Three definitions were added to the rule as a 

result of this comment. Although again not determined to be 

substantive, this version of the proposed revised rule was again 

made available to affected parties. An additional comment was 

received from Pacific Gas & Electric Company on 08/10/09. 

Three further definitions were added, and one minor clarification 

was included in response to the comment letter. The minor 

clarification reflects the use of the additional definitions. The 

proposed amendments were also reviewed by the Technical 

Advisory Committee, a committee consisting of a variety of 

regulated industry and local governmental entities, on 03/02/2009 

and 09/14/2009. 

d. Notice to Specified Entities: 

Copies of the proposed amendment of Rule 1159 and the 

accompanying draft Staff Report were sent to all affected agencies. 

The proposed amendments were sent to CARB and USEPA on 

05/11/2009. Copies of the proposed amendments to Rule 1159 and 

the accompanying draft Staff Report were again made available to 

all affected agencies on 07/02/09 incorporating changes and 
MDAQMD Rule 1159 7

Final Staff Report, 01/12/10

responses to the substantive comments from USEPA and CARB. 

An additional provision was added to the proposed amended rule 

as a result of an additional comment from USEPA, and although 

not determined to be substantive, the version of the proposed 

revised rule containing this additional provision was again made 

available to all interested and affected parties on 07/09/09. An 

additional comment was received from CARB 07/21/09. Three 

definitions were added to the rule as a result of this comment. 

Although again not determined to be substantive, this version of 

the proposed revised rule was again made available to affected 

parties on 07/23/09. Comments were received from Pacific Gas & 

Electric on 08/10/09. The latest draft Staff Report will be posted 

on the District website for review by any interested parties 

incorporating the most recent changes to the rule. 

e. Public Hearing: 

A public hearing to consider the proposed amendment of Rule 

1159 was set for 06/22/2009. The MDAQMD received substantive 

comments from USEPA and CARB and therefore continued this 

public hearing to 08/24/09. This hearing was again continued to 

the 09/28/09 Governing Board meeting to address additional 

comments received from Pacific Gas & Electric. A public hearing 

to consider the amendment of Rule 1159 was held on 09/28/09. 

f. Legal Authority to Adopt and Implement: 

The District has the authority pursuant to H&S Code §40702 to 

adopt, amend, or repeal rules and regulations and to do such acts as 

may be necessary or proper to execute the duties imposed upon the 

District. 

g. Applicable State Laws and Regulations Were Followed: 

Public notice and hearing procedures pursuant to H&S Code 

§§40725-40728 have been followed. See Section (V)(A)(1) above 

for compliance with state findings required pursuant to H&S Code 

§40727. See Section (V)(B) below for compliance with the 

required analysis of existing requirements pursuant to H&S Code 

§40727.2. See Section (V)(C) for compliance with economic 

analysis requirements pursuant to H&S Code §40920.6. See 

Section (V)(D) below for compliance with provisions of the 

California Environmental Quality Act (CEQA). 
8 MDAQMD Rule 1159 

Final Staff Report, 01/12/10

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 same equipment or source type 

as the rule proposed for modification by the district. 

The FCAA requires areas designated non-attainment for ozone and classified moderate 

and above to adopt and maintain RACT rules to control the emissions of VOCs and NOX

for categories which the USEPA has adopted a Control Techniques Guideline (CTG) or 

Alternative Control Techniques (ACT) and for all categories where there are major 

stationary sources of air pollution (42 U.S.C. §7511a(b)(2), FCAA 182(b)(2)). For 

purposes of the FCAA, portions of the District have been designated non-attainment for 

ozone and classified severe-17. 

The USEPA has promulgated “Alternative Control Techniques Document – NOX

Emissions from Stationary Gas Turbines” (EPA-453/R-93-007) which applies to the 

source category of stationary gas turbines. In addition, the USEPA has also adopted 

“Standards of Performance for Stationary Combustion Turbines” (71 FR 38482, July 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 MDAQMD to adopt the most readily available, 

feasible and cost-effective local control measures for PM as contained on a list developed 

by CARB. CARB has identified on its list of local control measures several items related 

to stationary gas turbines as potentially feasible. The District has evaluated the 

availability, feasibility and cost-effectiveness of applying those combustion source 

control measures related to stationary gas turbines within the MDAQMD in the 

Feasibility Analysis for Stationary Gas Turbines included in Appendix “F”. 

C. ECONOMIC ANALYSIS 

1. General 

The proposed amendments to Rule 1159 will not have an adverse economic 

impact on the current entities 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 effectiveness calculations are 

required for rules and regulations which are adopted or amended to meet the 

California Clean Air Act requirements for Best Available Retrofit Control 

Technology (BARCT) or “all feasible measures” to control volatile compounds, 

oxides of nitrogen or oxides of sulfur. 

The cost-effectiveness analysis contained in the Technical Discussion document 

in Appendix “F” was based upon cost estimates contained in the staff report for 
MDAQMD Rule 1159 9

Final Staff Report, 01/12/10

San Joaquin Valley Air Pollution Control District (SJVAPCD) Rule 4703 as 

adopted 4/25/02. 

D. ENVIRONMENTAL ANALYSIS (CEQA) 

Through the process described below the appropriate CEQA process for the amendment 

of Rule 1159 was determined. 

1. The amendment of Rule 1159 meets the CEQA definition of “project”. 

They are not “ministerial” actions. 

2. The amendment of Rule 1159 is exempt from CEQA review because it 

will not create any adverse impacts on the environment. The requirements in the 

amendments to Rule 1159 are more stringent than the currently existing 

requirements (see more detailed discussion in Rule Summary §(D)) in that: rule 

applicability is expanded to be enforced District wide; definitions are updated to 

make the rule more comprehensive, reflect the current applicability of the rule, 

and provide additional clarity; NOX compliance limits have been tightened and a 

limit for CO has been added; and, the compliance schedule has been strengthened. 

The control measures currently available to allow compliance with the rule do not 

substantially change due to the more stringent requirements so indirect impacts 

will not be caused since the compliance methods contemplated are already in use. 

Therefore, no adverse environmental effects are foreseen from the proposed 

amendments. 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 impacts of compliance with the 

amendment of Rule 1159. Rule 1159 will impose additional requirements on 

NOX, and CO. However, the control measures currently available and 

contemplated to be used to comply with the rule do not substantially change and 

are already in use. Thus, there should be no change in environmental impacts 

since the contemplated control measures are already in use within the District. 

The proposed amendments will also include expanding the applicability of the 

rule to apply on a District wide basis.

2. Mitigation of Impacts 

N/A 

3. Alternative Methods of Compliance 

N/A 
10 MDAQMD Rule 1159 

Final Staff Report, 01/12/10

F. PUBLIC REVIEW 

See Staff Report Section (V)(A)(1)(g) and (2)(b), as well as Appendix “B” 

VI. TECHNICAL DISCUSSION 

A. SOURCE DESCRIPTION 

Gas turbines with power outputs ranging from less than 1 megawatt (MW) to over 200 

MW are used in a broad scope of applications. A gas turbine is an internal combustion 

engine that operates with rotary rather than reciprocating motion. In stationary 

applications, the hot combustion gases are directed through one or more fan-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 both mechanical 

and electrical drive applications. The primary applications for gas turbines can be 

divided into the following categories: the oil and gas industry, stand-by/emergency 

electric power generation, independent electric power producers, electric utilities and 

other industrial applications. 

MDAQMD Rule 1159 currently applies to any existing non-utility combined-cycle, 

commercial, industrial or institutional stationary gas turbine of 0.3 MW and larger unless 

the equipment is exempt from this rule pursuant to Section (D) of the rule or the turbine is 

located outside of the Federal Ozone Nonattainment Area (FONA) of the MDAQMD. 

Several facilities in the MDAQMD have operations potentially affected by this analysis. 

Within the FONA, there is one affected turbine operated by Southern California Gas 

(Adelanto). Outside of the FONA, there is one affected turbine operated by Southern 

California Gas (Kelso), one affected turbine operated by Searles Valley Minerals 

Operations, Inc. (Westend), and two affected turbines (portable HIVAS) operated at the 

NAWS (China Lake). The five permitted turbines total 35.3 MW. 

B. EMISSIONS 

The amendments to Rule 1159 – Stationary Gas Turbines do not cause the release of 

additional air contaminants or create any adverse environmental impacts because all 

existing turbines in the District are subject to alternative federal NOX RACT limits at 

which they are currently permitted. Section (C)(1)(a) Table 1 proposes NOX and CO 

compliance limits which would apply to future installations of only very 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. 

The amendments to Rule 1159 – Stationary Gas Turbines do not cause the release of 

additional air contaminants or create any environmental impacts because all existing 

turbines in the District are subject to alternative federal NOX RACT limits at which they 

are currently permitted. Section (C)(1)(a) Table 1 proposes NOX and CO compliance 
MDAQMD Rule 1159 11

Final Staff Report, 01/12/10

limits which would apply to future installations of only very 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 amendments of Rule 1159. 

Section (A)(2)(a) changes applicability to remove combined cycle turbines which are 

covered by Rule 1158 – Electric Power Generating Facilities, and to allow Rule 1159 to 

be enforced district wide. This makes the rule more stringent than the previous 

amendment because the rule covers the entire District rather than just the Federal Ozone 

Nonattainment Area (FONA). 

Section (B) definitions are updated. Definitions have 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 Control Officer; CEMS; Dry Low 

NOX Combustion Technology; Emission Control Equipment; Predictive Emissions 

Monitoring System (PEMS); Reasonably Available Control Technology (RACT); 

Selective Catalytic Reduction (SCR); Shutdown Period; Startup Period; and, Volatile 

Organic Compound (VOC). Definitions which were removed: Combined Cycle Unit and 

Federal Ozone Non-attainment Area. Definition modified for clarity: Emission Control 

System Operating Parameters. 

Section (C)(1) was clarified to add startup and shutdown periods in addition to those 

startup and shutdown periods included in the thermal stabilization period. 

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 (one value remains the same), and a CO limit has been added. 

There was not a CO limit in the previous rule amendment, thereby increasing the 

stringency of the rule further. 

Section (C)(1)(c) and Section (C)(1)(d) were added to provide an alternative federal 

RACT for existing turbines for which there were no cost-effective control measures 

determined. The age, location, and usage of the turbines were determined to limit the 

availability and feasibility of retrofit technology. 

Section (C)(3) was added in response to USEPA comment requesting a provision stating 

emissions should be minimized insofar as technologically feasible during Thermal 

Stabilization Periods. 

Section (D)(2)(b) was added to address units which are not stationary, industrial units and 

do not meet the applicability of this rule. 

Section (D)(3) no longer applies as the rule applicability has been expanded to apply 

district wide. 
12 MDAQMD Rule 1159 

Final Staff Report, 01/12/10

New section (D)(3) exempts the Frame 3 turbine from monitoring and recordkeeping 

requirements as well as test methods since this type of unit has no stack and therefore 

cannot be tested as specified in the rule. 

Section (F) requires any turbine subject to the limits of Table 1 in section (C)(1)(a) to 

provide continuous measurement and recording of Emission Control Equipment if 

required for compliance with this rule. This is an additional monitoring and 

recordkeeping requirement than in the previous amendment. 

Section (F)(2) has been added to specify the length of time for record retention. This 

clarification will remove any ambiguity that might be perceived by not having a specified 

length of time for record retention. 

Section (G)(1)(a)(ii) has been modified to change the length of time a unit has to come 

into compliance after losing its exemption by operating in excess of its hour per year 

limit from 24 to 18 months. This reduction in compliance time tightens the rule 

requirements. 

Section (I) updates the compliance schedule. A provision for new turbines has also been 

added with compliance required upon adoption of the proposed amendments. This 

removes the loophole for very small turbines (<2MW) which may not be subject to NSR 

to have to comply immediately with the rule upon installation. 

Various format changes were made for consistency with current MDAQMD rule format, 

as well as correction of typographical errors. 

E. SIP HISTORY 

1. SIP History. 

a. SIP in the San Bernardino County Portion of MDAQMD 

On July 1, 1993 the MDAQMD was formed pursuant to statute. 

Pursuant to statute it also retained all the rules and regulations of 

the SBCAPCD until such time as the Governing Board of the 

MDAQMD wished to adopt, amend or rescind such rules. The 

MDAQMD Governing Board, at its very first meeting, reaffirmed 

all the rules and regulations of the SBCAPCD. Rule 1159 – 

Stationary Gas turbines was adopted 02/22/95. Since SIP 

revisions in California are adopted by USEPA as effective in areas 

which happen to be defined by both air basin designations and the 

jurisdictional boundaries of local air districts within those air 

basins, the MDAQMD “inherited” the SBCAPCD SIP which was 

in effect for what is now called the San Bernardino County Portion 

of MDAB. Since there was no equivalent document to Rule 1159 

in the SBCAPCD, the 02/22/95 version of the rule is the rule 

version in the SIP (40 CFR 52.220(c)(216)(i)(A)(3) – 04/09/96 61 

FR 15719).
MDAQMD Rule 1159 13

Final Staff Report, 01/12/10

b. SIP in the Riverside County (Blythe/Palo Verde Valley) Portion of 

the MDAQMD 

One of the provisions of the legislation which created the 

MDAQMD allowed areas contiguous to the MDAQMD 

boundaries and within the same air basin to leave their current air 

district and become a part of the MDAQMD. On July 1, 1994 the 

area commonly known as the Palo Verde Valley in Riverside 

County, including the City of Blythe, left SCAQMD and joined the 

MDAQMD. Since USEPA adopts SIP revisions in California as 

effective within the jurisdictional boundaries of local air districts, 

when the local boundaries change the SIP as approved by USEPA 

for that area up to the date of the change remains as the SIP in that 

particular area. Upon annexation of the Blythe/Palo Verde Valley 

the MDAQMD acquired the SIP prior to July 1, 1994 that was 

effective in the Blythe/Palo Verde Valley. Therefore, the SIP 

history for the Blythe/Palo Verde Valley Portion of the MDAQMD 

is based upon the rules adopted and approved for that portion of 

Riverside County by SCAQMD. 

Rule 1134 – Emissions of Oxides of Nitrogen from Stationary Gas

Turbines was adopted by SCAQMD on 08/04/89. This rule was 

submitted by CARB to USEPA on 12/31/90. The Blythe/Palo 

Verde Valley was annexed by the MDAQMD on 07/01/94 and at 

this time USEPA action on Rule 1134 was still pending. USEPA 

started action on the 08/04/89 version of this rule on 03/23/95 (60 

FR 15271). SCAQMD subsequently amended Rule 1134 on 

12/07/95. This amendment was submitted to USEPA on 03/26/96 

and approved in the SCAQMD SIP on 11/1/96 (61 FR 56470). 

This rule action occurred after the annexation of the Palo Verde 

Valley, and thus, Rule 1134 is not included in the SIP for the Palo 

Verde Valley of Riverside County. 

2. SIP Analysis. 

The District is requesting CARB to submit Rule 1159 to replace the SIP version in 

effect for the San Bernardino County portion of the MDAB and as a new rule for 

the for the Blythe/Palo Verde Valley portion of Riverside County. The 1995 

MDAQMD submission of Rule 1159 is in the SIP for the San Bernardino County 

portion of the MDAB. There is no analogous rule in the Blythe/Palo Verde 

Valley portion of the MDAB in the SIP. 

Since there is a previously existing SIP rule for this category in the San 

Bernardino County section of the District, the District is requesting that it be 

superseded. In order to replace existing SIP rules the District is required to show 

that the proposed amendments are not less stringent than the provisions currently 

in the SIP. 
14 MDAQMD Rule 1159 

Final Staff Report, 01/12/10

Amended MDAQMD Rule 1159 is more stringent than the MDAQMD Rule 1159 

as adopted on 02/22/95. Rule 1159 has increased applicability to be district wide, 

NOX limits have been lowered, and CO limits have been added. 

RACT limits have been modified since Rule 1159 was originally adopted, and 

this rule amendment will update RACT. The alternative federal NOX RACT limit 

for Southern California Gas Company Turbine Model LM 1500 will be continued 

because District staff has determined that there is no additional control technology 

available for this type of unit and this unit it is not feasible to retrofit or modify. 

In expanding the applicability of Rule 1159 to the entire jurisdiction, the District 

is able to include two turbines not previously included. These two units are also 

proposed to have alternative federal RACT limits. District staff has determined 

that there is no additional technology available to retrofit or modify the Southern 

California Gas Company Turbine General Electric Model Frame 3, therefore the 

alternative federal RACT limit of 225 ppmv NOX will apply. District staff has 

proposed the Westend Model PQ 5191 turbine with an alternative federal NOX of 

42 ppmv NOX which is the current permitted limit. 

MDAQMD Rule 1159 as adopted on 02/22/95 is in the MDAQMD SIP 61 FR 

15719 (04/09/96) and was determined by USEPA to meet or exceed RACT. 

Therefore, since the proposed MDAQMD rule is more stringent than current 

version in the MDAQMD SIP, the amended rule can supersede the current SIP 

rule. 
MDAQMD Rule 1159 A-1

Final Staff Report, 01/12/10

Appendix “A”

Rule 1159 – Stationary Gas Turbines Iterated Version 

The iterated version is provided so that the changes to an existing rule may be easily found. The 

manner of differentiating text is as follows: 

1. Underlined text identifies new or revised language. 

2. Lined out text identifies language which is being deleted. 

3. Normal text identifies the current language of the rule which will remain unchanged by 

the adoption of the proposed amendments. 

4. [Bracketed italicized text] is explanatory material that is not part of the proposed 

language. It is removed once the proposed amendments are adopted. 
A-2 MDAQMD Rule 1159 

Final Staff Report, 01/12/10 

This page intentionally left blank. 
(Adopted: 02/22/95; Amended: mm/dd/yy)

MDAQMD Rule 1159 1159-1

Stationary Gas Turbines 

D7, 09/24/2009 

RULE 1159 

Stationary Gas Turbines

(A) General

(1) Purpose: 

(a) The purpose of this Rule rule is to limit the emission of oxides of nitrogen 

from commercial, industrial and institutional stationary Stationary gas Gas 

turbinesTurbines. 

(2) Applicability: 

(a) This rule applies to any new or existing non-utility combined-cycle, 

commercial, industrial or institutional stationary Stationary gas Gas 

turbine Turbine of 0.3 megawatt (MW) and larger unless the equipment is 

exempt from this rule pursuant to Section (D) of this rule. or the turbine is 

located outside of the Federal Ozone Non-attainment Area of the Mojave 

Desert Air Quality Management District (District). [Applicability 

changed to allow rule to be enforced district wide]

(B) Definitions

(1) “Air Pollution Control Officer (APCO)” – The person 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 

MDAQMD Rule 1301] 

(2) “Continuous Emissions Monitoring System (CEMS)” – Continuous Emissions 

Monitoring System All of the equipment that may be required to meet the data 

acquisition and availability requirements of this rule, to sample, condition (if 

applicable), analyze, and provide a record of emissions on a continuous basis. 

[Derived from 40 CFR 51.165(a)(1)(xxxi)]

(3) “Dry Low NOX Combustion Technology (DLN)” – Any turbine combustor design 

which uses multiple staging, air/fuel premixing or other modifications to achieve 

lower levels of NOX emissions as compared to conventional combustors. 

[Derived from SJVUAPCD Rule 4703 §3.7]

(1) "Combined-cycle Unit" - Any stationary gas turbine operated both for the 

production of electrical energy from shaft work and the useful energy produced 

from heat recovered from its exhaust gases. [This rule is not applicable to 

combined cycle units and definition not used] 
1159-2 MDAQMD Rule 1159 

Stationary Gas Turbines 

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(24) “"Emission Control System Operating Parameters” – " - Any operating 

parameter(s) that the District deems necessary to analyze for the determination of 

compliance. Such parameters include, but are not limited to, the ammonia and 

gas flow rates, the exhaust temperature for the Selective Catalytic Reduction

(SCR), humidity, water injection rate, exhaust gas flow rate and the temperature 

for water injection. [Alphabetical order corrected.]

(354) “"Emergency Standby Unit” – " - Any stationary Stationary gas Gas turbine 

Turbine that operates as a mechanical or electrical power source for a facility 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 

voluntary interruptible power supply agreement is not to be considered as an 

emergency loss of primary power. Electricity generated by such a unit cannot be 

sold.

(5) “Emission Control Equipment” – Add-on technologies which control the turbine's 

emissions, including, but not limited to, Selective Catalytic Control (SCR), water 

injection, steam injection, but excluding DLN. [Added in response to public 

comment]

(6) “Emission Control System Operating Parameters” – Any operating parameter(s) 

that the District deems necessary to analyze for the determination of compliance. 

Such parameters include, but are not limited to, the ammonia and gas flow rates, 

the exhaust temperature for the Selective Catalytic Reduction (SCR), humidity, 

water injection rate, exhaust gas flow rate and the temperature for water injection. 

(467) “"Enhanced Emissions Monitoring Device” – " - Any automated data recording 

device or system having both data gathering and retrieval capabilities. Such 

equipment includes, but is not limited to, Continuous Emissions Monitoring 

Systems (CEMS) and Predictive Emissions Monitoring Systems (PEMS). 

(57) "Federal Ozone Non-attainment Area" That portion of San Bernardino County 

that lies within the lines which begin at: (a) the San Bernardino - Riverside 

County boundary, running north along the range line common to Range 3 East 

and Range 2 East; (b) then west along the township line common to Township 2 

North and Township 3 North; (c) then north along the San Bernardino - Los 

Angeles County and San Bernardino - Kern County Boundaries; (d) then east 

along ;latitude 35 degrees, 10 minutes north; (e) then south along longitude 115 

degrees, 45 minutes west and westward along the San Bernardino - Riverside 

Counties boundary.(see Map 1). [Applicability changed to allow rule to be 

enforced district wide, definition no longer used]

(678) “"Higher Heating Value (HHV) ” – " - The higher Higher heating Heating value 

Value of the fuel. 

(789) “"Lower Heating Value (LHV) ” – " - The lower Lower heating Heating value 

Value of the fuel. 
MDAQMD Rule 1159 1159-3

Stationary Gas Turbines 

D7, 09/24/2009 

(8910) “"Measured NOXNOx Emissions Concentration” – " - The concentration of 

oxides of nitrogen corrected to International Standards Organization (ISO) 

standard conditions: 

NOXNOx = (NOXNOx obs)(Pref/Pobs)0.5 (288 K/Tamb)1.53 (e19(Hobs-0.00633)) 

Where: NOXNOx = emissions of NOXNOx at 15 percent oxygen and ISO 

standard conditions on a dry basis, ppm. 

NOXNOx obs = measured NOXNOx emissions corrected to 15 

percent oxygen on a dry basis, ppm. 

Pref = standard reference pressure, (14.696 psia). 

Pobs = measured site ambient absolute pressure, psia. 

Hobs = measured humidity of ambient air, pounds water per pound 

dry air. 

e = transcendental constant (2.718) 

Tamb = measured temperature of ambient air, degrees K. 

or an alternate calculation that corrects to ISO standard conditions 

and is approved by the APCO. 

(10) “PEMS” – Predictive Emissions Monitoring System [Alphabetical order

corrected.]

(91111) “"Power Augmentation” – " - An increase in the gas turbine shaft output 

and/or the decrease in gas turbine fuel consumption by the addition of energy 

recovered from exhaust heat.

(12) “Predictive Emissions Monitoring System (PEMS)” – All of the equipment 

necessary to monitor process and control device operational parameters (for 

example, control device secondary voltages and electric currents) and other 

information (for example, gas flow rate, O2 or CO2 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)]

(101213) "“Public Service Unit” – " - A stationary Stationary gas Gas turbine 

Turbine used to generate electricity for sale or for use in serving the public. 

(14) “Rating” – The continuous megawatt (MW) Rating or mechanical equivalent by a 

manufacturer for gas turbine(s) without Power Augmentation.

(1315) “Reasonably Available Control Technology (RACT)” – The lowest emission

limitation that a particular source is capable of meeting by the application of 

control technology that is reasonably available considering technological and 

economic feasibility. [USEPA definition 44 FR 53761 (Sept. 17, 1979)] 
1159-4 MDAQMD Rule 1159 

Stationary Gas Turbines 

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 (1114)"“Rating” – " - The continuous megawatt (MW) rating or mechanical equivalent 

by a manufacturer for gas turbine(s) without power augmentation. [Alphabetical 

order corrected.]

(1516) “Selective Catalytic Reduction (SCR)” – Selective Catalytic Reduction A 

noncombustion control technology that destroys NOX by injecting a reducing 

agent (e.g., ammonia) into the flue gas that, in the presence of a catalyst (e.g., 

vanadium, titanium, or zeolite), converts NOX into molecular nitrogen and water.

[Derived from 40 CFR 76.2]

(17) “Shutdown Period” – The period of time during which a unit is taken from 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, added in 

response to public comment]

(18) “Startup Period” – The period of time during which a unit is brought from a 

Shutdown status to its operating temperature and pressure, including the time 

required by the unit’s emission control system to reach full operation. [Derived 

from SJVUAPCD Rule 4703 3.29, added in response to public comment]

(121619) "“Stationary Gas Turbine or Unit” – " - Any gas turbine system that is 

gas and/or liquid fueled with or without power Power 

augmentationAugmentation. This unit is either attached to a foundation at a 

facility or is portable equipment operated at a specific facility for more than 90 

days in any 12-month period. Two or more gas turbines powering one shaft shall 

be treated as one unit. 

(131720) "“Thermal Stabilization Period” – " - The start Startup or shut Shutdown 

time Period necessary to bring the heat recovery steam generator to the proper 

operating temperature, not to exceed two hours.

(1821) “Volatile Organic Compound (VOC)” – Any compound of carbon, excluding 

carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, 

and ammonium carbonate, which participates in atmospheric photochemical 

reactions and those compounds listed in 40 CFR 51.100(s)(1). [Derived from 

MDAQMD Rule 1162(b)(48)]

(C) Standards

(1) The owner or operator of any affected stationary Stationary gas Gas turbine 

Turbine unit Unit shall not operate such unit under load conditions, excluding the 

thermal Thermal stabilization Stabilization period Period and Startup and 

Shutdown Periods which results in the mMeasured NOx NOX emissions 
MDAQMD Rule 1159 1159-5

Stationary Gas Turbines 

D7, 09/24/2009 

Emissions cConcentration exceeding the emissions limits set forth below: [Added

“Startup and Shutdown Periods” in response to public comment]

(a) For stationary Stationary gas Gas turbines Turbines which are not subject 

to the alternative federal NOXNOx RACT limits of Subsection (C)(1)(b)

and (c), the following federal NOX and Carbon Monoxide (CO) NOx 

RACT limits in Table 1 apply: [Derived from SJVUAPCD Rule 4703, 

§5.1.2 4/25/02] 

Table 1

NOX and CO Compliance Limits

NOX Compliance Limit, 

ppmv at 15% Oxygen Control 

 

Operating 

hours per 

year 

 

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 

[lowered to 

42 to avoid

relaxation

of previous 

SIP limit]

50 250

SCR or 

DLN < 877 > 10 MW 25 42 200

(i) For gas-fired turbines, 42 ppmv NOx 

(ii) For oil-fired turbines, 65 ppmv NOx

(b) For the Southern California Gas Company Turbine Model LM 1500, the 

following alternative federal NOXNOx RACT limits shall apply: 

(i) 90 ppmv NOXNOx when fired with gaseous fuel.

(c) For the Southern California Gas Company Turbine General Electric

Model Frame 3, the following alternative federal NOX RACT limit shall 

apply: 

(i) 225 ppmv NOX when fired with gaseous fuel, achieved through 

good combustion practices.

(d) For the Westend Model PQ 5191, the following alternative federal NOX

RACT limit shall apply: 
1159-6 MDAQMD Rule 1159 

Stationary Gas Turbines 

D7, 09/24/2009 

 (i) 42 ppmv NOX achieved with an SCR when fired with gaseous fuel.

(ce) For the purposes of these emissions limits the following conventions are 

applicable: 

(i) Gas includes natural, digester and landfill gases. 

(ii) Oil includes kerosene, jet fuel, and distillate. The sulfur content of 

the oil shall be less than 0.05%. 

(iii) NOXNOx = emissions of NOXNOx, in ppmv, corrected to 15 

percent oxygen and ISO standard conditions on a dry basis, 

averaged over any consecutive 15 minute period. 

(2) The owner or operator of any affected stationary Stationary gas Gas turbine

Turbine subject to (C)(1)(a) shall submit to the APCO for approval, an Emission

Control Plan (ECP) for the purpose of establishing an exemption status pursuant 

to Section (D) or to establish compliance with provisions of this rule.

(3) The owner or operator of any sStationary gGas tTurbine subject to (C)(1) shall

minimize emissions insofar as technologically feasible during Thermal 

Stabilization Periods. [Section added in response to USEPA rule review 

comments received 7/9/09]

(D) Exemptions

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

(a) Laboratory units used in research and testing for the advancement of gas 

turbine technology. 

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

(c) Combined-cycle tStationary Gas Turbines operating as an electric utility 

which are subject to Rule 1158.

(2) The provisions of this rule, with the exception of Section (F)(e2), shall not apply 

to the operation of stationary Stationary gas Gas turbines Turbines used under the 

following conditions: 

(a) Emergency standby Standby units Units demonstrated to operate less than 

200 hours per calendar year,.

(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 testing only. [These 

units are not stationary, industrial units and do not meet the applicability]
MDAQMD Rule 1159 1159-7

Stationary Gas Turbines 

D7, 09/24/2009 

(b) Units rated less than 4 MW and operating less than 877 hours per calendar 

year. [requirements in §(C)(1)(a) Table 1 now apply] 

(3) Any facility within the federally designated ozone non-attainment area containing 

an affected stationary gas turbine which is classified as exempt or claiming to be 

exempt under this subsection, shall meet the record keeping requirements of 

Section (F)(e) of this rule to establish the exempt classification or claimed 

exemption. [Section not applicable since rule is being amended to apply district 

wide]

(3) The provisions of section (F)(1) and (H) shall not apply to the Southern California 

Gas Company Turbine General Electric Model Frame 3.

(E) Administrative Requirements

(1) Emission Control Plan The Emission Control Plan (ECP) required pursuant to 

section (C)(2) shall, at a minimum, include the following information if such 

information is applicable: 

(a) A list of all stationary Stationary gas Gas turbines Turbines required to be 

controlled pursuant to this rule. 

(b) For each stationary Stationary gas Gas turbine Turbine listed: 

(i) District identification number, and District Permit 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 ((BTUBtu/KWkW-HRhr), corrected to the HHV) for 

each type of fuel (gas or liquid) for each turbine;

(viii) Monthly fuel consumption for the pervious previous twelve-month 

period (cubic feet for gas; gallons for liquid);

(ix) Monthly hours of operation in the previous twelve-month period.;

(x) The type of NOX NOx emission Emission control Control 

equipmentEquipment, including any auxiliary equipment related to 

the control of emissions, to be applied. ; 

(xi) Documentation showing the current (existing) concentration and 

mass rate of emissions of oxides of nitrogen from the unit.;

(xii) A schedule with specified increments of progress dates for 

construction of emissions Emission control Control 

equipmentEquipment, operational milestones for implementation of 

emissions control and/or installation of monitoring equipment;. and

(xiii) A final compliance date. 
1159-8 MDAQMD Rule 1159 

Stationary Gas Turbines 

D7, 09/24/2009 

(F) Monitoring and Recordkeeping Requirements

(1) The owner or operator of any affected stationary Stationary gas Gas turbine 

Turbine required to install Emissions Control Equipment for compliance with this 

rule shall: 

(a) Install, operate, and maintain in calibration, emissions the following 

monitoring equipment, as approved by the APCO, that continuously 

measures and records the following: 

(i) Continuous measurement and recording of Emissions Control 

System Operating Parameters;, and

(ii) Continuous measurement and recording of Elapsed elapsed time of 

operation; and.

(iii) An Enhanced Emissions Monitoring Device.

(b) notify the APCO, in writing, that the facility has an enhanced emissions 

monitoring device and specify the data gathering and retrieval capacities 

thereof. 

(cb) nNotify the APCO, in writing, before issuance of the Permit To Operate, 

such information which correlates the Emission Control System Operating 

Parameters, and PEMS if present, to the associated measured NOXNOx

emissions output. This information will be used to determine compliance 

with applicable provisions of this rule for non-CEMS-equipped turbines 

and CEMS-equipped units when the CEMS is not operating properly. 

(dc) Provide, on an annual basis, compliance testing data and information 

regarding NOXNOx emissions. The data shall be corrected to ISO 

conditions 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 Turbine shall:

(ea) For each unit and oOn a daily basis, maintain a turbine operating log that 

includes, as a minimum, the following information: 

 (i) the The total hours of operation per day; 

 (ii) the The accumulated hours of operation per calendar month; and 

 (iii) the 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 provided to District or 
MDAQMD Rule 1159 1159-9

Stationary Gas Turbines 

D7, 09/24/2009 

state personnel on request. [Rule retention clarification added pursuant to 

CARB comment]

(G) Notification Requirements for Exempt and Emergency Standby Units 

(1) Any stationary Stationary gas Gas turbine 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 hour-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 application for a 

Permit to Operate to the District. Such application shall including a 

plan detailing actions and a schedule of progress to meet the 

applicable RACT limits and provisions of this rule within 24 18 

months after the date of the notification; an Emission Control Plan 

conforming to the requirements of Section (E) for the emissions 

control equipment. [The time a unit has to come into compliance 

after losing its exemption by operating in excess of its hour per 

year limit has been lowered to 18 months in response to USEPA 

comment].

(2) Notwithstanding the provisions of Sections (F)(2) and (G)(1) above, A public 

Public service Service unit Unit shall not be subject to the hour-per-year threshold

when: 

(a) Such unit is operating during a state of emergency declared by a 

proclamation of the Governor of the State of California; and 

(b) Such unit is located within the specific geographic location identified in the 

state of emergency proclamation. 

(H) Test Methods

(1) Compliance testing shall be subject to the protocols prescribed in the District's 

Compliance Procedural Manual. 

(2) The following test methods shall be used to determine compliance with the 

provisions of this rule. 
1159-10 MDAQMD Rule 1159 

Stationary Gas Turbines 

D7, 09/24/2009 

(a) NOXNOx Emissions emissions shall be determined by EPA Test Method 

20. 

(b) The Higher Heating Value (HHV) and the Lower Heating Value (LHV) 

shall be determined by the appropriate method for the fuel type listed 

below: [Deleted reference to “most current version” of ASTM in response 

to USEPA and CARB comments]

(i) For liquid fuels: 

a. ASTM Test Method D 240-87 (Standard Test Method for 

Heat of Combustion of Liquid Hydrocarbon Fuels by 

Bomb Calorimeter). 

(ii) For distillate fuel: 

a. ASTM Test Method D 2382-88 (Standard Test Method for 

Heat of Combustion of Hydrocarbon Fuels by Bomb 

Calorimeter - High Precision Method); or,

(iii) For gaseous fuels: 

a. ASTM Test Method D 3588-91 (Standard Practice for 

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 

Continuous Recording Calorimeter); or 

c. ASTM Test Method D 1945-81 (Standard Method for 

Analysis of Natural Gas by Gas Chromatography). 

(I) Compliance Schedule

(1) The owner/operator of any existing stationary Stationary gas Gas turbine Turbine 

subject to the provisions of Section (C)(1)(a) above shall comply with the 

following increments of progress: 

(2a) An Emissions Control Plan shall be submitted to the District on of before 

April 15, 1995within 90 days of rule adoption. The District shall approve the 

Plan on or before May 31, 1995within 30 days of submission. 

(3b) On and after May 31, 1995, aAny affected turbine shall be in full 

compliance with all applicable provisions of the rule within 12 months of rule 

adoption. 

(4c) Demonstrate final compliance with all applicable standards and 

requirements of the rule within six months of the installation of the NOx NOX

reduction technology.
MDAQMD Rule 1159 1159-11

Stationary Gas Turbines 

D7, 09/24/2009 

(2) The owner/operator of any new sStationary gGas tTurbine subject to the 

provisions of Section (C) shall comply as of the date of adoption of this rule.

[Provision for new turbines added in response to USEPA comments]

[SIP: Submitted as amended mm/dd/yy on mm/dd/yy; Approved 4/9/96, 61 FR 15719, 40 CFR 

52.220(c)(216)(I)(A)(3)] 
1159-12 MDAQMD Rule 1159 

Stationary Gas Turbines 

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MDAQMD Rule 1159 B-1

Final Staff Report, 01/12/10 

Appendix “B” 

Public Notice Documents 

1. Proof of Publication – Daily Press, 05/15/09 

2. Proof of Publication – Riverside Press Enterprise, 05/15/09 

3. Proof of Publication – Daily Press, 07/10/09 

4. Proof of Publication – Riverside Press Enterprise, 07/10/09 
B-2 MDAQMD Rule 1159 

Final Staff Report, 01/12/10

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MDAQMD Rule 1159 B-3

Final Staff Report, 01/12/10 
B-4 MDAQMD Rule 1159 

Final Staff Report, 01/12/10
MDAQMD Rule 1159 B-5

Final Staff Report, 01/12/10 
B-6 MDAQMD Rule 1159 

Final Staff Report, 01/12/10
MDAQMD Rule 1159 C-1

Final Staff Report, 01/12/10

Appendix “C” 

Public Comments and Responses 

1. USEPA Comment Letter, received 06/03/2009 

2. CARB Comment Letter, received 06/15/2009 

3. USEPA Comment Letter, received 07/09/09 

4. CARB Comment Letter, received 07/21/2009 

5. Pacific Gas & Electric Company Comment Letter, 08/10/09 
C-2 MDAQMD Rule 1159 

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MDAQMD Rule 1159 C-3

Final Staff Report, 01/12/10

United States Environmental Protection Agency

Region IX 

75 Hawthorne Street 

San Francisco, CA 94105-3901

June 03, 2009 

Transmittal of EPA Rule Review Comments 

To: Alan De Salvio, Mojave Desert Air Quality Management District

adesalvio@mdaqmd.ca.gov 

Mike Guzzetta, California Air Resources Board 

mguzzett@arb.ca.gov 

 

From: Andrew Steckel, Rulemaking Office Chief 

steckel.andrew@epa.gov 

 

Re: Proposed Amended Mojave Rule 1159, Gas Turbines, (3/2/2009)

We are providing comments based on our preliminary review of the draft rule identified above. Please 

direct any questions in this regard to me at (415) 947-4115 or to Idalia Perez at (415) 972-3248. 

Section (C)(1)(a) – The NOx limit for units smaller than 2 MW with a DLN should be lowered to 42 ppm to 

avoid a relaxation of the current SIP approved rule. 

Sections (C)(1)(b) through (C)(1)(d) – We understand that the units addressed in these sections cannot

be easily retrofitted to reduce NOx emissions. We recommend that the rule be revised to establish a limit 

on the number of hours per year that these units may operate to minimize emissions. See, for example,

SJVAPCD Rule 4703. 

Section (G)(1)(1)(ii) - The time a unit has to come into compliance after loosing its exemption by operating 

in excess of its hour per year limit should be lowered to 18 months. 

Section (H)(2)(b) – The versions of the ASTM tests that are included in the SIP-approved version of the 

rule should not be changed. 

Section (I) – A provision should be added indicating that new turbines must be in compliance upon 

installation. 

1 

2 

3 

4 

5 

Comment Letter 1 
C-4 MDAQMD Rule 1159 

Final Staff Report, 01/12/10

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MDAQMD Rule 1159 C-5

Final Staff Report, 01/12/10

District response to USEPA 06/03/09 comments 

1. NOX limit for units smaller than 2 MW with a DLN has been lowered to 42 ppm to avoid 

a relaxation of the current SIP approved rule. 

2. The District will address this comment during the upcoming round of ozone attainment 

planning required by the latest revision to the federal 8-hour ozone standard. 

3. The time a unit has to come into compliance after losing its exemption by operating in 

excess of its hour per year limit (section (G)(1)(a)(ii)) has been lowered to 18 months. 

4. Deleted reference to “most current version” of ASTM in response to USEPA and CARB 

comments in section (H)(2)(b). 

5. Section (I) has been modified to clarify the compliance schedule for existing and new 

stationary gas turbines. New gas turbines shall be subject to the provisions of section (C) 

as of the date of adoption of this rule. 
C-6 MDAQMD Rule 1159 

Final Staff Report, 01/12/10

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MDAQMD Rule 1159 C-7

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Comment Letter 2 
C-8 MDAQMD Rule 1159 

Final Staff Report, 01/12/10

1 

2 
MDAQMD Rule 1159 C-9

Final Staff Report, 01/12/10

District response to CARB 06/15/09 comments 

 1. The District has added a record retention requirement in section (F)(2)(b). 

2. Deleted reference to “most current version” of ASTM Method in section 

(H)(2)(b). 
C-10 MDAQMD Rule 1159 

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MDAQMD Rule 1159 C-11

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1 

Comment Letter 3 
C-12 MDAQMD Rule 1159 

Final Staff Report, 01/12/10

District response to USEPA 07/09/09 comment 

1. Provision (C)(3) has been added that states “The owner or operator of any stationary gas 

turbine subject to (C)(1) shall minimize emissions insofar as technologically feasible 

during Thermal Stabilization Periods.” 
MDAQMD Rule 1159 C-13

Final Staff Report, 01/12/10

Comment Letter 4 
C-14 MDAQMD Rule 1159 

Final Staff Report, 01/12/10

1 
MDAQMD Rule 1159 C-15

Final Staff Report, 01/12/10

District response to CARB 07/21/2009 comment 

1. Definitions added for Continuous Emission Monitoring System, Predictive Emissions 

Monitoring System, and Selective Catalytic Reduction as requested for clarification and 

enforceability. 
C-16 MDAQMD Rule 1159 

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MDAQMD Rule 1159 C-17

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1 

3 

2 

Comment Letter 5 
C-18 MDAQMD Rule 1159 

Final Staff Report, 01/12/10
MDAQMD Rule 1159 C-19

Final Staff Report, 01/12/10

District response to PGE comment letter 

1. Definitions for Startup Period, Shutdown Period, and Emission Control Equipment have 

been added to Section (B). 

2. Added “Startup and Shutdown Periods” for clarity. 

3. The District has determined that all three requirements are necessary and does not agree 

that “or” should be included. 
C-20 MDAQMD Rule 1159 

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MDAQMD Rule 1159 D-1

Final Staff Report, 01/12/10 

Appendix “D” 

California Environmental Quality Act 

Documentation 

1. Notice of Exemption – San Bernardino County, posted 10/6/2009 

2. Notice of Exemption – Riverside County, posted 10/14/2009 
D-2 MDAQMD Rule 1159 

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MDAQMD Rule 1159 D-3

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D-4 MDAQMD Rule 1159 

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MDAQMD Rule 1159 E-1

Final Staff Report, 01/12/10

Appendix “E” 

Bibliography

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

1. Sacramento Metropolitan Air Quality Management District Rule 413 – Stationary 

Gas Turbines, amended 05-01-97. 

2. Sacramento Metropolitan Air Quality Management District Rule 413 – Stationary 

Gas Turbines Staff Report, April 6, 1995. 

3. Sacramento Metropolitan Air Quality Management District Agenda Item for Rule 

413 – Stationary Gas Turbines, May 1, 1997. 

4. San Joaquin Valley Air Pollution Control District Rule 4703 – Stationary Gas 

Turbines, amended April 25, 2002. 

5. San Joaquin Valley Air Pollution Control District Rule 4703 – Stationary Gas 

Turbines Final Staff Report, April 25, 2002. 

6. South Coast Air Quality Management District Rule 1134 – Emissions of Oxides of 

Nitrogen from Stationary Gas Turbines, amended August 8, 1997. 

7. South Coast Air Quality Management District Rule 1134 – Emissions of Oxides of 

Nitrogen from Stationary Gas Turbines Final Staff Report, April, 1997. 

8. MDAQMD Rule 1159 – Stationary Gas Turbines, adopted 02/22/95. 

9. MDAQMD Rule 1159 – Stationary Gas Turbines Archive Documents, adopted 

02/22/95. 

10. USEPA Standards of Performance for Stationary Gas Turbines (71 FR 38482, July 6, 

2006). 

11. USEPA Standards of Performance for Stationary Gas Turbines (71 FR 9458, 

February 24, 2006). 

12. USEPA Alternative Control Techniques Document - - NOX Emissions from 

Stationary Gas Turbines (EPA-453/R-93-007), January 1993. 

13. CARB Proposed List of Measures to Reduce Particulate Matter – PM10 and PM2.5 

(Implementation of Senate Bill 656, Sher 2003). 

14. MDAQMD List and Implementation Schedule for District Measures to Reduce PM 

Pursuant to Health and Safety Code §39614(d), adopted June 27, 2005. 
E-2 MDAQMD Rule 1159 

Final Staff Report, 01/12/10

15. CARB Report to the Legislature, Gas Fired Power Plant NOX Emission Controls and 

Related Environmental Impacts, May 2004. 

16. CARB Guidance for Power Plant Siting and Best Available Control Technology, 

approved July 22, 1999. 
MDAQMD Rule 1159 F-1

Final Staff Report, 01/12/10

Appendix “F” 

Technical Report 

1. Health & Safety Code §39614 Feasibility Analysis for Stationary Gas 

Turbines 
F-2 MDAQMD Rule 1159 

Final Staff Report, 01/12/10 

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Mojave Desert 

Air Quality Management District 

Technical Report 

Health & Safety Code §39614 

Feasibility Analysis for 

Stationary Gas Turbines 

January 13, 2009 

14306 PARK AVE, VICTORVILLE, CA 92392-2310 

PHONE: (760) 245-1661 

FAX: (760) 245-2699 
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MDAQMD Feasibility Analysis – Stationary Gas Turbines i

Technical Report d2, 1/13/2009 

TECHNICAL REPORT 

TABLE OF CONTENTS 

I. EXECUTIVE SUMMARY 1 

II. INTRODUCTION 1 

III. TECHNICAL DISCUSSION 3 

A. SOURCE DESCRIPTION 3 

1. Applicability and District Turbine Inventory 3 

2. Currently Available Control Technologies 5 

3. Rule History 7 

B. EMISSIONS 7 

C. BASIS FOR STATIONARY GAS TURBINE ANALYSIS 7 

1. SMAQMD Rule 413 8 

2. SJVAQMD Rule 4703 9 

3. SCAQMD Rule 1134 11 

D. FEASIBILITY OF OPTIONS 13 

IV. STAFF RECOMMENDATION 15 

Appendix A - Calculations and Assumptions for Determining Cost-Effectiveness A-1 
ii MDAQMD Feasibility Analysis – Stationary Gas Turbines 

Technical Report d2, 1/13/2009

Abbreviations 

BACT Best Available Control Technology 

CARB California Air Resources Board 

CO Carbon Monoxide 

DLN Dry Low NOX

FONA Federal Ozone Nonattainment Area 

MDAQMD Mojave Desert Air Quality Management District 

NH3 Ammonia 

NOX Oxides of Nitrogen 

NSR New Source Review 

PM Particulate Matter 

PM2.5 Fine Particulate Matter 

PM10 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 Management District 

SoLoNOX Dry Low NOX burner technology for Solar Turbines 

USEPA United States Environmental Protection Agency
MDAQMD Feasibility Analysis – Stationary Gas Turbines 1

Technical Report d2, 1/13/2009 

I. EXECUTIVE SUMMARY

California Health & Safety (H&S) Code §39614 requires the Mojave Desert Air Quality 

Management District (MDAQMD) to ensure that all feasible particulate control measures are in 

place. To address the full scope of possible PM problems, measures to address both directly 

emitted PM as well as precursor gases were included in the summaries of ARB 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 nitrogen oxides (NOX), sulfur oxides (SOX), 

volatile organic compounds (VOC), and ammonia. NOX, SOX, and ammonia combine to form 

secondary ammonium nitrate and sulfate. VOC can form secondary organic aerosols, as well as 

participate in the production of secondary ammonium nitrate. NOX and VOC are also precursors 

of ambient ozone. Sources of ambient PM include combustion sources such as trucks and 

passenger cars, off-road equipment, industrial processes, residential wood burning, and forest 

and agricultural burning; fugitive dust from paved and unpaved roads, construction, mining and 

agricultural activities; and ammonia from sources such as livestock operations, fertilizer 

application, and motor vehicles. In general, combustion processes form fine particles, whereas 

emissions from dust sources tend to be predominantly coarse particles 

The MDAQMD currently has Rule 1159 – Stationary Gas Turbines in place for limiting the 

emissions of oxides of nitrogen (NOX) from commercial, industrial and institutional stationary 

gas turbines. The California Air Resources Board (ARB) has identified several stationary gas 

turbine control measures as potentially feasible. This document evaluates the feasibility of 

applying those control measures within the MDAQMD, using a cost-effectiveness basis to define 

feasibility. 

MDAQMD staff recommends amending Rule 1159 – Stationary Gas Turbines to be applicable 

District wide, and to include NOX and Carbon Monoxide (CO) limits determined to be feasible in 

the San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) rule analysis. The 

amended rule will contain several exceptions resulting from technical infeasibility, special 

classification, and cost-effectiveness evaluations.

Reviewed turbine control measures for a variety of turbine sizes and control levels found to be 

cost-effective and hence feasible ranged from $5,139 per ton (NOX, 2008 dollars) up to $11,516. 

Not cost-effective and hence not feasible control measures were $18,821 up to $28,225. The 

MDAQMD is therefore establishing $11,516 as cost-effective (and feasible) and$18,821 as not 

cost-effective (and infeasible) for NOX control measures (in 2008 dollars). 

II. INTRODUCTION

This Technical Report is an analysis of the costs and cost-effectiveness for various control 

technologies and levels for reducing NOX emissions from stationary gas turbines. This analysis 

is being made in response to the mandate of H&S Code §39614(d) and the subsequent ARB 

document Proposed List of Measures to Reduce Particulate Matter – PM10 and PM2.5. The 

recommendations in this report are based upon a cost effectiveness threshold of not more than 
2 MDAQMD Feasibility Analysis – Stationary Gas Turbines 

Technical Report d2, 1/13/2009

$11,567 per ton of NOX. These cost effectiveness values now in effect define a feasibility 

threshold for this source category which may be used to aid in evaluation of all subsequent 

particulate control feasibility analyses for NOX. 

Several facilities in the MDAQMD have operations potentially affected by this analysis. Within 

the FONA, there is one turbine operated by Southern California Gas (Adelanto). Outside of the 

FONA, there is one turbine operated by Southern California Gas (Kelso), one turbine operated 

by Searles Valley Minerals Operations, Inc. (Trona), and two High Velocity Air Flow System 

(HIVAS) turbines operated at Naval Air Weapons Station (NAWS) China Lake. 

A. California Law 

In 2003, the Legislature enacted H&S Code §39614 (SB 656, Sher), to reduce public exposure to 

PM10 and PM2.5. H&S Code §39614 requires the CARB in consultation 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, feasible, and cost-effective control measures that could 

be employed by ARB and the air districts to reduce PM10 and PM2.5 (collectively PM). The list 

of proposed control measures was to be based on rules, 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 appropriate measures. Finally, by no later than 

January 1, 2009, ARB must prepare a report describing actions taken to fulfill the requirements 

of the legislation as well as recommendations for further actions to assist in achieving the State 

PM standards. H&S Code §39614 sunsets on January 1, 2011, unless extended. 

On November 18, 2004, ARB adopted Proposed List of Measures to Reduce Particulate Matter 

– PM10 and PM2.5 to satisfy the initial requirements of H&S Code §39614. The ARB adopted 

document contains a table entitled “SB 656 List of Air District Measures that Reduce Particulate 

Matter” (Local PM Measures List). H&S Code §39614(d) requires the MDAQMD to adopt an 

analysis schedule to determine the feasibility of local measures from this list. 

The List and Implementation for District Measures to Reduce PM Pursuant to Health & Safety 

Code §39614(d) was prepared by the MDAQMD to meet the requirements 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 category includes measures that are already being 

implemented by the MDAQMD in its rules and programs. The second category lists measures 

that do not need to be implemented within the MDAQMD 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 MDAQMD New Source Review (NSR) 

regulations. A third category includes those measures 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 MDAQMD. The stationary gas turbine analysis falls into this final 

category. 

District staff has prepared this technical report entitled Health & Safety Code §39614 Feasibility 

Analysis for Stationary Gas Turbines to satisfy the analysis commitment for the turbines 

category contained in the PM Implementation List. 
MDAQMD Feasibility Analysis – Stationary Gas Turbines 3

Technical Report d2, 1/13/2009 

In support of this analysis, staff reviewed the following District Rules and documents referenced 

in the Proposed List of Measures to Reduce Particulate Matter – PM10 and PM2.5: 

1. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 413 – 

Stationary Gas Turbines, amended 05/01/97. 

2. San Joaquin Valley Air Pollution Control District (SJVAPCD) Rule 4703 – Stationary 

Gas Turbines, amended 04/25/02. 

3. South Coast Air Quality Management District (SCAQMD) 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 Power Plant NOX Emission Controls and 

Related Environmental Impacts, May 2004. 

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

1999. 

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

1. EPA’s Alternative Control Techniques Document - - NOX Emissions from Stationary Gas 

Turbines, January 1993, EPA-453/R-93-007. 

2. 40 CFR 60, Subpart KKKK - Standards of Performance for Stationary Combustion 

Turbines, commencing with section 60.4300 

III. TECHNICAL DISCUSSION

A. SOURCE DESCRIPTION 

Gas Turbines are available with power outputs ranging from less than 1 megawatt (MW) to over 

200 MW and are used in a broad scope of applications. A gas turbine is an internal combustion 

engine that operates with rotary rather than reciprocating motion. In stationary applications, the 

hot combustion gases are directed through one or more fan-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 both mechanical and electrical drive 

applications. The primary applications for gas turbines can be divided into the following 

categories: the oil and gas industry, stand-by/emergency electric power generation, independent 

electric power producers, electric utilities and other industrial applications.1

 

1. Applicability and District Turbine Inventory 

MDAQMD Rule 1159 currently applies to any existing non-utility combined-cycle, commercial, 

industrial or institutional stationary gas turbine of 0.3 megawatt (MW) and larger unless the 

 

1

 EPA, Alternate Control Techniques Document - - NOx Emissions from Stationary Gas Turbines, Chapter 3, 

January 1993. 
4 MDAQMD Feasibility Analysis – Stationary Gas Turbines 

Technical Report d2, 1/13/2009

equipment is exempt from this rule pursuant to Section (D) of the rule or the turbine is located 

outside of the Federal Ozone Nonattainment Area (FONA) of the MDAQMD. 

Several facilities in the MDAQMD have operations potentially affected by this analysis. Within 

the FONA, there is one turbine operated by Southern California Gas (Adelanto). Outside of the 

FONA, there is one turbine operated by Southern California Gas (Kelso), one turbine operated 

by Searles Valley Minerals Operations, Inc. (Westend), and two turbines (portable HIVAS) 

operated at the NAWS (China Lake). The five permitted turbines total 35.3 MW. These 

turbines are summarized in Table 1. 

Table 1 

Stationary Gas Turbine NOX Emissions 

Actual Emissions 

Facility Model Output 

(MW) Fuel 

Operation 

2005 & 

2006 avg 

(hr/yr) 

NOX

Control ppmv TPY 

SCG – Kelso GE Frame 

3 6.3 NG 869.9 none unknown 16.0342

SCG – Adelanto GEL 1500 11 NG 3.86 none 90 0.068 

SVM – Westend 

Plant PQ 5191 18 NG 7382.5 SCR 42 278.078 

NAWS – China 

Lake 

Pratt & 

Whitney 

TF30P-6E

N/A JP-8 50 none N/A N/A 

NAWS – China 

Lake 

Nine Pratt 

& 

Whitney 

TF-33 

N/A JP-8 low none N/A N/A 

Total 294.18 

a. Southern California Gas (Kelso): 

A 6.3 MW natural gas Model GE Frame 3 turbine in that drives a single stage natural gas 

compressor with 8,400 brake horsepower. The engine heat input has a rating of 100,000,000 

Btu/hr. This turbine was placed in service in the early 1970’s. This facility is remote, does not 

have adequate water supply or wastewater disposal available, and has no viable cogeneration 

applications. 

 

2

 Data provided in Emission Inventory by SCG. 
MDAQMD Feasibility Analysis – Stationary Gas Turbines 5

Technical Report d2, 1/13/2009 

b. Southern California Gas (Adelanto): 

An 11 MW natural gas fueled Jet Derivative Engine, Model GE LM 1500 that drives a 3 stage 

natural gas compressor with nominal 15,000 shaft horsepower. The engine heat input has a 

nominal rating of 110,000,000 Btu/hr (LHV). This turbine is located in the FONA and by 

current applicability, the only turbine regulated by District Rule 1159. This turbine was placed 

in service in the early 1970’s. This facility has no viable cogeneration applications. 

c. Searles Valley Minerals Operations, Inc (Westend): 

An 18 MW GE Model PQ 5191 gas turbine/waste heat boiler with 14,000 hp. The engine has a 

maximum heat rate input of 295,000,000 Btu/hr. This turbine is permitted to operate with a SCR 

unit. It is not equipped with water/steam injection, or DLN. 

Note: In November 2007 Searles Valley Minerals started up a steam line to transfer process 

steam from their coal fired boilers at the Argus Facility down to the Westend plant (about 

five miles). This allowed Searles Valley Minerals to shut down their turbine. For now they 

will keep the turbine permit for the infrequent times that it may be needed, but for the most 

part it will not be operated. At some time in the future Searles Valley Minerals will cancel 

the turbine permit. Until that time, the turbine will see very limited use. 

d. NAWS (China Lake): 

NAWS China Lake operates 2 test facilities as follows: 

Portable HIVAS – A platform mounted, portable Pratt & Whitney TF30P-6E HIVAS at the 

Weapons Survivability Lab. This unit is a jet engine designed to be moved as needed to 

locations where the necessary positions and conditions relative to aerospace vehicle 

survivability testing can be achieved. This turbine is fueled with JP-8. This turbine is in a 

different classification (portable) than the other units included in this analysis. The control 

technologies discussed in this report are therefore not appropriate for this unit; as a result 

their applicability will not be discussed. This unit will be exempted from provisions of 

amended Rule 1159. 

Weapons Survivability Range HIVAS2 – Nine Pratt & Whitney TF-33 turbofan engines in a 

square cluster with their axes parallel and horizontal. HIVAS is located on a turntable 

allowing it to be used on any of the two adjacent test pads. This facility performs live fire 

survivability or lethality tests, aerodynamic tests, cookoff tests, and remote-controlled runup and operation of aircraft, sea vehicle, land vehicle and/or missile engines. This turbine is 

in a different classification (portable) than the other units included in this analysis. The 

control technologies discussed in this report are therefore not appropriate for this unit; as a 

result their applicability will not be discussed. This unit will be exempted from provisions 

of amended Rule 1159. 

2. Currently Available Control Technologies 
6 MDAQMD Feasibility Analysis – Stationary Gas Turbines 

Technical Report d2, 1/13/2009

Add-on technologies for reducing NOX available for stationary gas turbines include wet controls 

(water and steam injection), combustion controls (Dry low-NOX (DLN)), Selective Catalytic 

Reduction (SCR), a combination of controls, and alternative fuels. 

a. Water or Steam Injection Systems 

In this process, either steam or water is injected into the combustor of the turbine to lower 

combustion temperatures and reduce the production of thermal NOX. This control technique is 

available for new turbine models and can be retrofitted to most existing installations.3 

Controlled NOX emissions range from 25 to 42 ppmv for natural gas and from 42 to 75 ppmv for 

distillate oil fuels. The injected water or steam must be relatively pure to prevent scaling of the 

blades. This usually requires the installation and expense of maintaining a water purification 

system and waste water disposal. 

b. Combustion Controls (Dry Low-NOX (DLN)) 

The DLN system reduces thermal NOX formation without injecting water or steam. DLN uses 

specially designed burner elements to change the turbine’s combustion mechanics, reducing 

flame temperature. Two designs have been developed: lean premixed combustion and 

rich/quench/lean staged combustion. Controlled NOX 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 20 MW.4 Controlled NOX emissions from 

smaller turbines typically range from 25 to 42 ppmv. 

DLN is commonly found on new turbines. Specifically tailored retrofit technology may not be 

commercially available for all turbines. Turbine manufacturers estimate retrofit costs to be 

approximately 40 to 60 percent higher than new equipment costs. As stated by Southern 

California Gas in 1991, Dry Low-NOX combustors are very promising technology for many gas 

turbines and may be well suited to gasline pipeline turbines. However, turbine manufacturers 

have not and will not develop low NOX combustors for obsolete, older models. To do so would 

not be cost effective for the small number of units presently in use. 

c. SCR 

An SCR system treats flue gas using an ammonia (NH3) injection system and a catalytic reactor 

to reduce NOX. An injection grid disperses NH3 in the flue gas upstream of the catalyst and the 

NH3 and NOX are reduced to N2 and water in the catalyst reactor. This control technique reduces 

both thermal NOX and fuel NOX. Most SCR installations use a base-metal catalyst with an 

operating temperature window of 400oF to 800oF. This operating temperature has limited SCR 

to cogeneration or combined cycle applications with reduced flue gas temperatures. Hightemperature zeolyte catalysts which have an operating window of up to 1100oF are now available 

that offer potential for SCR applications with simple cycle gas turbines. 

 

3

 EPA, Alternate Control Techniques Document - - NOx Emissions from Stationary Gas Turbines, Pg. 2-5, January 

1993. 

4

 EPA, Alternate Control Techniques Document - - NOx Emissions from Stationary Gas Turbines, Pg. 2-10, January 

1993. 
MDAQMD Feasibility Analysis – Stationary Gas Turbines 7

Technical Report d2, 1/13/2009 

SCR technology has not proven useful on gasline turbines for several reasons: remote location, 

unmanned operation, and non-steady state operation. Operational swings in turbine loading such 

as encountered by a gas pipeline turbine due to changes in turbine speed and load cause 

significant variation in exhaust temperature and flow. Maintaining proper exhaust temperature 

and controlling NH3 flow rate through operational swings would be difficult and costly, 

especially in an unmanned, remotely operated facility. 

d. Alternative Fuels 

Using fuels with flame temperatures lower than those of natural gas or distillate oils results in 

lower thermal NOX emissions. Coal-derived gas and methanol have demonstrated lower NOX

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 methanol-fueled turbines operating in 1993. 

3. Rule History 

The MDAQMD adopted Rule 1159 – Stationary Gas Turbines on 02/22/95. This is the version 

currently in the MDAQMD Rule Book. 

B. EMISSIONS 

The following emission limits are contained in MDAQMD Rule 1159 and are applicable to 

stationary gas turbines located in the FONA: 

1. For stationary gas turbines which are not subject to the alternative federal NOX

Reasonably Available Control Technology (RACT) limits, the following federal NOX

RACT limits apply: 

a. For gas-fired turbines, 42 ppmv NOX 

b. For oil-fired turbines, 65 ppmv NOX

2. For the Southern California Gas Company Turbine Model LM 1500, the following 

alternative federal NOX RACT limits shall apply: 

a. 90 ppmv NOX when fired with gaseous fuel 

3. For the purposes of these emissions limits the following conventions are applicable: 

a. Gas includes natural, digester and landfill gases. 

b. Oil includes kerosene, jet fuel, and distillate. The sulfur content of the oil shall be 

less than 0.05%. 

c. NOX = emissions of NOX, in ppmv, corrected to 15 percent oxygen and 

International Organization for Standardization (ISO) standard conditions on a dry 

basis, averaged over any consecutive 15 minute period. 

C. BASIS FOR STATIONARY GAS TURBINE ANALYSIS 
8 MDAQMD Feasibility Analysis – Stationary Gas Turbines 

Technical Report d2, 1/13/2009

This analysis examines the cost-effectiveness of implementing certain district rules as required 

by H&S Code §39614 to reduce public exposure to PM10 and PM2.5. These rules were 

determined to be a list of the most readily available, feasible, and cost-effective control measures 

that could be employed by CARB and the air districts to reduce PM10 and PM2.5 (collectively 

PM). Appendix B of the Proposed List of Measures to Reduce Particulate Matter, Strategy D – 

Combustion Sources Measures reduce NOX, SOX, 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 determine their feasibility for stationary gas 

turbines in the MDAQMD: 

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

This amendment of the rule applies to all stationary gas turbines with ratings equal to or greater 

than 0.3 megawatt (MW) output, or 3 MMBTU/hr input and operated on gaseous and/or liquid 

fuel for the purpose of limiting emissions of nitrogen oxides (NOX) to the atmosphere. (This rule 

was subsequently amended 03/24/05). 

Exemption is made for Emergency Standby Units used to provide emergency electrical power, 

emergency water pumping for flood control or firefighting, emergency potable water pumping, 

or emergency sewage pumping providing the following requirements 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 serving utility or distribution on the grid; 

and 

d. Operation for other than maintenance shall be limited to actual interruptions of electrical 

power by the serving utility, emergency water pumping for flood control or firefighting, 

emergency potable water pumping, or emergency sewage pumping. 

Exemptions are also made for units removed from service 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. 
MDAQMD Feasibility Analysis – Stationary Gas Turbines 9

Technical Report d2, 1/13/2009 

Table 2 

Summary of RACT and BARCT requirements contained in SMAQMD Rule 413

NOX 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 

Table 3 

SMAQMD Limits as applicable to MDAQMD turbines 

Turbine NOX Emission Limit (ppmv) 

Adelanto (11 MW) operating < 877 hr/yr 42 

Kelso (6.3 MW) operating >877 hr/yr 25 

Westend (18 MW) operating <877 hr/yr 42 

NAWS Turbines N/A 

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 or greater than 0.3 megawatt (MW) and/or a 

maximum heat input rating of more than 3,000,000 BTU per hour, for the purpose of limiting 

oxides of nitrogen (NOX) emissions 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 requirements are those used as laboratory 

units used in the research and testing for the advancement of gas turbine technology, and units 

limited by permit condition to be operated exclusively for firefighting and/or flood control. The 

provisions of this rule with the exception of the Emission Control Plan and record keeping 
10 MDAQMD Feasibility Analysis – Stationary Gas Turbines 

Technical Report d2, 1/13/2009

provisions do not apply to emergency standby units limited by permit condition to operate less 

than 200 hours per calendar year for maintenance and testing purposes, and units less than 4 MW 

in rating and limited by permit condition to operate less than 877 hours per calendar year. 

Table 4 

Summary of Tier 2 NOX Compliance Limits contained in SJVAPCD Rule 4703

NOX Compliance Limit, ppmvd at 

15% O2

Turbine Classification Rating 

Gas Fuel Liquid Fuel 

a) Less than 2.0 MW Solar Saturn, driving a centrifugal 

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 (Standard5) 25 (Standard) 

d) Greater than 10 MW, Combined cycle. 

3 (Enhanced6

) 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) 

 

5

 Standard Compliance option required compliance with rule limits by dates ranging from 04/25/2002 to 04/25/2005. 

6

 Operators complying with the Enhanced Compliance option had until 04/30/2008 to demonstrate and maintain 

compliance with enhanced limit, or to demonstrate and maintain compliance within 90 days following next major 

overhaul if occurring after 04/30/2004. 
MDAQMD Feasibility Analysis – Stationary Gas Turbines 11

Technical Report d2, 1/13/2009 

Table 5 

Summary of CO Compliance Limits contained in SJVAPCD Rule 4703 

Stationary Gas Turbine CO Compliance Limit, 

ppmv at 15% O2

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 

Table 6 

SJVAQMD Limits as applicable to MDAQMD turbines 

Turbine NOX Emission Limit (ppmv) CO Emission Limit (ppmv) 

Adelanto (11 MW) operating < 

877 hr/yr 25 200 

Kelso (6.3 MW) operating 

>877 hr/yr 

DLN not available 

35 

200 

Kelso (6.3 MW) operating 

>877 hr/yr 

DLN available 

25 

200 

Westend (18 MW) operating 

<877 hr/yr 5 200 

NAWS Turbines N/A N/A 

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 stationary gas turbines, 0.3 megawatt (MW) 

and larger, as of August 4, 1989. 
12 MDAQMD Feasibility Analysis – Stationary Gas Turbines 

Technical Report d2, 1/13/2009

Laboratory gas turbine units used in research and testing, gas turbine units used exclusively for 

firefighting and/or flood control, chemical processing gas turbine units, and all existing pipeline 

gas turbines located in the Southeast Desert Air Basin (SEDAB) are exempt from this rule. 

Emissions limitations, and monitoring and source testing and certain recordkeeping requirements 

do not apply to emergency standby and peaking gas turbine units operating less than 200 hours 

per calendar year, or existing gas turbines units located in the SEDAB as well as on San 

Clemente Island rated below 4 megawatts and operating less than 877 hours per year. 

Compliance Limit = Reference Limit

25%

EFF

×

Where: 

Compliance limit = allowable NOX emissions (ppm by volume) 

Reference Limit = the NOX emission limit (ppm by volume) corrected to 15 percent oxygen on a 

dry basis, and averaged over 15 consecutive minutes. These limits for various 

megawatt ratings (continuous rating by the manufacturer without power 

augmentation) are as follows: 

Table 7 

Reference NOX 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 Average 

25 

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

or, 

EFF = Manufacturer’s stated efficiency at LHV

HHV

LHV

×
MDAQMD Feasibility Analysis – Stationary Gas Turbines 13

Technical Report d2, 1/13/2009 

or, 

EFF = the demonstrated percent efficiency of the gas turbine unit only as calculated without 

consideration of any downstream energy recovery from the actual heat rate, (BTU/KW HR) or 

1.34 BTU/HP; corrected to the HHV of the fuel, as measured at the peak load for that facility; or 

the manufacturer’s continuous rated percent efficiency of the gas turbine unit after correction 

from LHV to the HHV of the fuel, whichever is higher. The value of EFF shall not be less than 

25 percent. Gas turbine units with lower efficiencies will be assigned a 25 percent efficiency for 

this calculation. 

Operators of stationary gas turbines shall be subject to SCAQMD Regulation XIII if carbon 

monoxide (CO) emissions increase as a result of the application of NOX controls. 

Table 8 

SCAQMD Limits as applicable to MDAQMD turbines 

Turbine NOX Emission Limit (ppmv) 

Adelanto (11 MW) operating < 877 hr/yr 

No SCR 

12 

Kelso (6.3 MW) operating >877 hr/yr 

No SCR 

15 

Westend (18 MW) operating <877 hr/yr 

SCR 

9 

NAWS Turbines N/A 

D. FEASIBILITY OF OPTIONS 

1. Adelanto Turbine: 

In a May 16, 1991 letter to the MDAQMD from the Southern California Gas Company regarding 

the turbine operated in Adelanto (GE LM 1500), it was stated that due to the age of this 

equipment and the extremely small number of units in operation, there is no incentive nor any 

plan by the manufacturer to develop the modifications that would allow either the retrofit of this 

turbine for water/steam injection or SCR”. The District received additional correspondence on 

03/14/2008 from Southern California Gas Company regarding the Adelanto turbine stating that 

“Water or steam injection has never been applied to a GE LM 1500 turbine; and GE does not 

advise installation of water or steam injection on the LM 1500 turbine”. Based on this 

information, water or steam injection is not feasible control technology for this turbine”. In 

addition, there is no low-NOX combustor available for the Adelanto turbine according to this 

same correspondence received from Southern California Gas Company. 
14 MDAQMD Feasibility Analysis – Stationary Gas Turbines 

Technical Report d2, 1/13/2009

District staff has determined that there is no technology available and this unit it is not feasible to 

retrofit or modify. The current version of Rule 1159 specifies the alternative federal NOX RACT 

limit of 90 ppmv NOX for the Southern California Gas Company Turbine Model LM 1500 when 

fired with gaseous fuel. Source testing performed in 2005 showed the unit operated between 51-

70 ppm NOX corrected to 15 percent oxygen and ISO standard conditions. CO concentration 

was 78-98 ppm. The District proposes to maintain the alternative federal NOX limit currently in 

Rule 1159. This turbine would be subject to the proposed 200 ppmv CO limit. 

2. Kelso Turbine: 

In a May 16, 1991 letter to the MDAQMD from the Southern California Gas Company regarding 

the turbine operated in Kelso (GE Frame 3), it was stated that “due to the age of this equipment 

and the extremely small number of units in operation, there is no incentive nor any plan by the 

manufacturer to develop the modifications that would allow either the retrofit of these turbines 

for water/steam injection or SCR”. The District received additional correspondence on 

03/14/2008 from Southern California Gas Company regarding the Kelso turbine, stating that 

“Our Kelso facility does not have water available for either water or steam injection. Water 

would have to be trucked to the site creating new mobile source emissions. Therefore, neither 

water or steam injection is feasible at this location”. In addition, there are no low-NOX

combustors available for the Kelso turbine according to correspondence received from Southern 

California Gas Company on 03/14/2008. 

District staff has determined that there is no technology available and this unit it is not feasible to 

retrofit or modify. The current version of Rule 1159 does not apply to this facility since it is 

located outside the FONA, nor does Rule 474 – Fuel Burning Equipment apply as this unit does 

not have a rated heat input of more than 1,775 million Btu per hour. There are currently no NOX

or CO limits applicable to this turbine. The District proposes to limit this turbine to good 

Combustion Controls, estimated as equivalent to 225 ppmv NOX. 

3. SVM Westend Turbine: 

Searles Valley Minerals Operations, Inc. does not use the water or steam injection system in their 

Westend turbine citing concern with the increased maintenance cost and down time. 

Searles Valley Minerals currently operates their Westend turbine in conjunction with a SCR unit. 

This unit reduces NOX emission to the permitted limit of 42 ppm. GE estimated that with DLN 

the NOX emissions could be reduced to 33 ppm, and to 8 ppm when used with the existing SCR 

unit. Searles Valley Minerals has indicated that a low NOX combustion system could be added 

to their turbine for an estimated $7,500,000 (2006 estimate) capital cost with and additional 

$1,000,000 yearly operating cost. The SVM turbine has been retrofitted with SCR, but not DLN. 

GE estimates that adding DLN technology could reduce NOX to 33 ppm, with the SCR then 

reducing NOX to 8 ppm. Based on 2006 pricing information from GE, adding DLN would cost 

approximately 7.5 million dollars, with an additional yearly operation/maintenance cost of 

approximately one million dollars. This unit currently is permitted at 46.3 lb/hr NOX at 15 

percent oxygen (42 ppm) when averaged over a rolling three-hour average. This unit is located 

outside of the FONA, thereby making current Rule 1159 not applicable. The District proposes to 

maintain the alternative federal NOX limit of 42 ppmv NOX for the SVM Westend turbine. The 
MDAQMD Feasibility Analysis – Stationary Gas Turbines 15

Technical Report d2, 1/13/2009 

District has determined that adding DLN to the existing SCR is not cost-effective at $18,821 per 

ton of NOX reduced (2008 dollars). See appendix A for cost effectiveness calculations. This 

turbine would be subject to the proposed 200 ppmv CO limit. Source test results from February, 

2006 provided an emission value of 1.9 ppm CO at 15 percent oxygen which is below the 

proposed rule emission limit. 

4. NAWS turbines 

These turbines are used for testing only and are to be exempted by classification 

(portable) and low usage. 

IV. STAFF RECOMMENDATION 

MDAQMD staff recommends amending Rule 1159 – Stationary Gas Turbines to apply District 

wide, and to include NOX and Carbon Monoxide (CO) limits determined to be feasible in the 

SJVUAPCD rule analysis. The amended rule will contain several exceptions resulting from 

technical infeasibility, special classification, and cost-effectiveness evaluations. 

Table 9 

Proposed Limits in Rule 1159 

NOX 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 50 50 250 

SCR or 

DLN < 877 > 10 MW 25 42 200 

Exemptions to limits in amended Rule 1159 

• Adelanto: No DLN, SCR, or steam/water injection available or feasible. Maintain 90 

ppmv limit of alternative Federal RACT limit in existing rule. Very limited use. 

• Kelso: No DLN, SCR, or steam/water injection available or feasible. Proposed limit of 

225 ppmv NOX (alternative Federal RACT as good combustion practices). 

• Westend: Utilize existing SCR, retrofitting DLN not cost-effective (see appendix A). 

Maintain emission limit at 42 ppm. This unit will most likely have permit cancelled 

soon. 
16 MDAQMD Feasibility Analysis – Stationary Gas Turbines 

Technical Report d2, 1/13/2009

• NAWS: Exempt by classification (portable) and limited usage. 

These recommendations for amending Rule 1159 fulfill the District commitment to analyze and 

implement measures to reduce PM in response to ARB document Proposed List of Measures to 

Reduce Particulate Matter – PM10 and PM2.5. measure 46(a, b, and c). 
MDAQMD Feasibility Analysis – Stationary Gas Turbines A-1

Technical Report d2, 1/13/2009

Appendix “A” 

Calculations and Assumptions for Determining Cost-Effectiveness

Table 1 

SVM Westend Turbine Cost Effectiveness Calculation Summary 

SVM Westend Turbine Existing Control 1 Control 2 

Baseline 

42 ppm 

DLN 

33 ppm 

SCR + DLN 

9 ppm 

Operational Days 365 365 365

Project Term (years) 15 15 15

Sample Project Output (MW) 18 18 18

Sample Project Capital Cost (2006 $) 

 $ 

7,500,000 

 $ 

7,500,000 

Annualized Sample Project Capital Cost (2006 $) $ - 

 $ 

986,053 

 $ 

986,053 

Sample Project O&M (2006 $) 

 $ 

750,000 

 $ 

1,750,000 

Costs 

Equivalent Project Capital Cost (2008 $) 

 $ 

7,956,750 

 $ 

7,956,750 

Equivalent Project O&M (2008 $) $ - 

 $ 

795,675 

 $ 

2,979,258 

Capital Recovery Factor (15@10%) 

 

0.1315 

 

0.1315 

Discounted Cash Flow Factor (15 @ 4%) 11.118 11.118

DCF O&M Costs (2008 $) $ - 

 $ 

8,846,315 

 $ 

33,123,389 

Emissions - Westend Frame 5 

availability factor 0.9 0.9 0.9

activity (hours/year) 8000 8000 8000

NOx (lbs/hr Nox @ 42ppm - baseline) 46.3 46.3 46.3

percent reduction (from 42) 21.4% 78.6%

NOx (lbs/hr Nox - reduction) 9.9 36.4

NOx (lbs/year Nox - reduction) 79376.7 291023.3

NOx (tons/year Nox @ - reduction) 39.7 145.5

Cost Effectiveness 

Average 

NOx Cost Effectiveness ($/ton) n/a

 $ 

28,225 

 $ 

18,821 

 

Notes: 

Real interest rate of 4% at 15 years used for Discounted Cash Flow Factor (SCAQMD method) 

Annual inflation rate of 3% used to adjust to current year (2008 dollars) 

Capital cost annualized by multiplying by CRF based on 15 years at 10% 
A-2 MDAQMD Feasibility Analysis – Stationary Gas Turbines 

Technical Report d2, 1/13/2009

Table 2 

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.