# Mojave Desert Air Quality Management District

Final 

# Staff Report Proposed Amendments to Rule 1159 – Stationary Gas Turbines

Adopted on September 28, 2009

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P HONE 

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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 Follo wed............................................ 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 MDAQ MD ....................................... 12 b. SIP in the Riverside County Portion of the MDAQM D........................................... 13TC-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 D ocumentation ....................................... D-1 Appendix E - Bibliography..........................

................................................... .............................E-1 Appendix F – Technical Report......................

................................................... ..........................F-1MDAQMD 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. I ts 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 docu mentation for approval or adoption of a document have been performed. Finally, the staff r eport provides evidence for defense against legal challenges regarding the propriety of the app roval 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 Particula te 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. T he District has evaluated the availability, feasibility and cost-effectiveness of applying thos e 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 determine d that such measures were indeed cost effective and therefore MDAQMD staff recommend s amending Rule 1159 – Stationary Gas Turbines. The proposed amendments include expanding the rul e to apply on a District wide basis, and to include certain NO X and Carbon Monoxide (CO) limits determined to be f easible. The proposed amendments to the rule will also conta in several exceptions for certain types of sources for specific control measures which were fo und to be technically infeasible, and noncosteffective. Comments from the California Air Resour ces Board (CARB), United States Environmental Protection Agency (USEPA), and Pacifi c Gas & Electric have also been incorporated into the proposed amendments to the ru le. These changes include correcting a proposed NO X limit for units smaller than 2 MW with DLN to avoi d a State Implementation Plan (SIP) relaxation; lowering the time a unit has to c ome into compliance after losing its exemption by operating in excess of its hour per year limit f rom 24 to 18 months; removing the proposed reference to “the most current version” of ASTM tes t methods; adding a provision for compliance of new turbines upon installation; addin g a two (2) year time limit in the record retention section; adding several definitions for c larification; 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; addin g a provision requiring the minimization of emissions during Thermal Stabilization Periods, sta rtup 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 (NO X and VOC) from existing sources through the adoptio n of Reasonable Available Control Technology (RACT)). This rule updates NO X RACT for the Stationary Gas Turbine category.

The public hearing to consider the amendment of Rul e 1159 was originally noticed for the 06/22/09 Mojave Desert Air Quality Management Distr ict (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 sinc e 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 recommen d 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 readi ly 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 containe d in proposed Rule 1159 has been determined to be readily available, feasible and co st-effective based upon an analysis and recommendations made in the feasibility analysis fo r stationary gas turbines included in the Technical Discussion of the Staff Report.

The Governing Board of the Mojave Desert Air Qualit y 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 re quired 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 include d 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 Review4 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 stat utory requirements that apply to the amendment of Rule 1159. These are actions that nee d to be performed and/or information that must be provided in order to amend the rule in a procedurally correct

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

Before adopting, amending, or repealing a rule or r egulation, the District Governing Board is required to make findings of nec essity, authority, clarity, consistency, non-duplication, and reference based u pon 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 cont rol measures for particulate matter from a list of potential local c ontrol measures promulgated by CARB. The level of control containe d in amended Rule 1159 has been determined to be readily availab le, feasible and cost-effective based upon an analysis and recom mendations made in the feasibility analysis for stationary gas turbines included in the Technical Discussion in the Staff Report. T he amendments also satisfy the 42 U.S.C. 7502(c)(1) requirement f or implementation and periodic update of RACT requirem ents for non-attainment areas.

b. Authority:

The District has the authority pursuant to Californ ia 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 meani ng.
d. Consistency:

Amended Rule 1159 is in harmony with, and not in co nflict with or contradictory to any State law or regulation, Feder al 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 requirem ents as any existing State or Federal law or regulation bec ause the District is amending this rule to satisfy the provisions of H&S Code §39614(d) which requires the adoption of readily av ailable, feasible and cost-effective control measures for Pa rticulate Matter from a list of potential local control measures pro mulgated by CARB. In addition, the amendments do not impose th e same requirements as Federal law in that Federal law mer ely requires the adoption and update of RACT for existing facilities in a particular source category but does not directly impose such m easures 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 amen dment of Rule 1159 was published 05/15/2009 for the 06/22/09 Gove rning Board meeting. The hearing was continued and re-noticed for the 08/24/09 Governing Board meeting to address substan tive comments. The hearing was again continued to the 0 9/28/09 Governing Board meeting to address additional subst antive comments. See Appendix “B” for copies of the publi c notice. See Appendix “C” for copies of comments and District re sponses.
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 F ederal law that requires the submittal. The information below indicates which e lements 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 bec ause Rule 1159 is currently included in the MDAQMD SIP. In additi on, rules imposing RACT requirements enacted to satisfy the r equirements of 42 U.S.C. 7502(c)(1) are also required to be inc luded in the SIP. The criteria for determining completeness of SIP su bmissions 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 amen dment of Rule 1159 was published 05/15/2009 for the 06/22/09 Gove rning Board meeting. The hearing was continued and re-noticed for the 08/24/09 Governing Board meeting to address substan tive comments. The hearing was again continued to the 0 9/28/09 Governing Board meeting to address additional subst antive comments. See Appendix “B” for copies of the publi c notice. See Appendix “C” for copies of comments and District re sponses.
c. Availability of Document:

Copies of the proposed amendment of Rule 1159 and t he 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 accompanyi ng draft Staff Report were again made available to the publi c on or before 07/10/09 incorporating changes and responses to the substantive comments from USEPA and CARB. An additional commen t was received from USEPA on 07/09/09. An additional pro vision was added to the proposed amended rule as a result of t his comment, and although not determined to be substantive, this version of the proposed revised rule was again made available to a ll interested and affected parties. An additional comment was re ceived from CARB 07/21/09. Three definitions were added to the rule as a result of this comment. Although again not determi ned to be substantive, this version of the proposed revised r ule 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. Th e minor clarification reflects the use of the additional de finitions. The proposed amendments were also reviewed by the Techn ical Advisory Committee, a committee consisting of a var iety 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 t he accompanying draft Staff Report were sent to all af fected agencies. The proposed amendments were sent to CARB and USEPA on 05/11/2009. Copies of the proposed amendments to R ule 1159 and the accompanying draft Staff Report were again made available to all affected agencies on 07/02/09 incorporating cha nges andMDAQMD Rule 1159 7

Final Staff Report, 01/12/10 responses to the substantive comments from USEPA an d CARB. An additional provision was added to the proposed a mended rule as a result of an additional comment from USEPA, an d although not determined to be substantive, the version of th e proposed revised rule containing this additional provision w as 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 t his comment. Although again not determined to be substantive, th is version of the proposed revised rule was again made available to affected parties on 07/23/09. Comments were received from P acific Gas & Electric on 08/10/09. The latest draft Staff Repor t will be posted on the District website for review by any intereste d 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 s ubstantive comments from USEPA and CARB and therefore continue d this public hearing to 08/24/09. This hearing was again continued to the 09/28/09 Governing Board meeting to address add itional comments received from Pacific Gas & Electric. A p ublic 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 t o do such acts as may be necessary or proper to execute the duties im posed upon the District.

g. Applicable State Laws and Regulations Were Follo wed:

Public notice and hearing procedures pursuant to H& S Code §§40725-40728 have been followed. See Section (V)( A)(1) above for compliance with state findings required pursuan t to H&S Code §40727. See Section (V)(B) below for compliance wi th the required analysis of existing requirements pursuant to H&S Code §40727.2. See Section (V)(C) for compliance with e conomic 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 app ly to the same equipment or source type as the rule proposed for modification by the distri ct.
The FCAA requires areas designated non-attainment f or ozone and classified moderate and above to adopt and maintain RACT rules to contr ol the emissions of VOCs and NO X for categories which the USEPA has adopted a Contro l Techniques Guideline (CTG) or Alternative Control Techniques (ACT) and for all ca tegories where there are major stationary sources of air pollution (42 U.S.C. §751 1a(b)(2), FCAA 182(b)(2)). For purposes of the FCAA, portions of the District have been designated non-attainment for ozone and classified severe-17.

The USEPA has promulgated “Alternative Control Tech niques Document – NO X Emissions from Stationary Gas Turbines” (EPA-453/R- 93-007) which applies to the source category of stationary gas turbines. In add ition, 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 t hese 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 in cluded 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 propo sed rule. Please see the incremental cost-effectiveness analysis in the Tech nical Report in Appendix “F” for a more detailed analysis of potential economic impact.

2. Incremental Cost Effectiveness

Pursuant to H&S Code §40920.6, incremental cost eff ectiveness calculations are required for rules and regulations which are adopte d or amended to meet the California Clean Air Act requirements for Best Avai lable Retrofit Control Technology (BARCT) or “all feasible measures” to co ntrol volatile compounds, oxides of nitrogen or oxides of sulfur.

The cost-effectiveness analysis contained in the Te chnical Discussion document in Appendix “F” was based upon cost estimates conta ined in the staff report forMDAQMD 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 defini tion of “project”. They are not “ministerial” actions.

2. The amendment of Rule 1159 is exempt from CEQA r eview because it will not create any adverse impacts on the environm ent. 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 w ide; definitions are updated to make the rule more comprehensive, reflect the curre nt applicability of the rule, and provide additional clarity; NO X compliance limits have been tightened and a limit for CO has been added; and, the compliance sc hedule has been strengthened. The control measures currently available to allow c ompliance with the rule do not substantially change due to the more stringent requ irements so indirect impacts will not be caused since the compliance methods con templated are already in use. Therefore, no adverse environmental effects are for eseen from the proposed amendments. Copies of the documents relating to CE QA can be found in Appendix “D”.

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS

1. Potential Environmental Impacts

There are no potential adverse environmental impact s of compliance with the amendment of Rule 1159. Rule 1159 will impose addi tional requirements on NO X , 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 chang e 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/A10 MDAQMD Rule 1159 Final Staff Report, 01/12/10 F. PUBLIC REVIEW

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

VI. TECHNICAL DISCUSSION

A. SOURCE DESCRIPTION

Gas turbines with power outputs ranging from less t han 1 megawatt (MW) to over 200 MW are used in a broad scope of applications. A ga s turbine is an internal combustion engine that operates with rotary rather than recipr ocating motion. In stationary applications, the hot combustion gases are directed through one or more fan-like turbine wheels to generate shaft horsepower. Often the hea t 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 app lications for gas turbines can be divided into the following categories: the oil and gas industry, stand-by/emergency electric power generation, independent electric pow er 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 po tentially affected by this analysis. Within the FONA, there is one affected turbine oper ated by Southern California Gas (Adelanto). Outside of the FONA, there is one affe cted turbine operated by Southern California Gas (Kelso), one affected turbine operat ed by Searles Valley Minerals Operations, Inc. (Westend), and two affected turbin es (portable HIVAS) operated at the NAWS (China Lake). The five permitted turbines tot al 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 e nvironmental impacts because all existing turbines in the District are subject to al ternative federal NO X RACT limits at which they are currently permitted. Section (C)(1) (a) Table 1 proposes NO X and CO compliance limits which would apply to future insta llations of only very small stationary gas turbines, while larger turbines would be subjec t 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 environme ntal impacts because all existing turbines in the District are subject to alternative federal NO X RACT limits at which they are currently permitted. Section (C)(1)(a) Table 1 proposes NO X and CO complianceMDAQMD 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 Sourc e Review.

D. PROPOSED RULE SUMMARY

This section gives a brief overview of the amendmen ts of Rule 1159.

Section (A)(2)(a) changes applicability to remove c ombined 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 mor e stringent than the previous amendment because the rule covers the entire Distri ct rather than just the Federal Ozone Nonattainment Area (FONA).

Section (B) definitions are updated. Definitions h ave been included to make the rule more comprehensive, reflect the current applicabili ty of the rule, and provide additional clarity. Definitions which were added: Air Pollut ion Control Officer; CEMS; Dry Low NO X Combustion Technology; Emission Control Equipment; Predictive Emissions Monitoring System (PEMS); Reasonably Available Cont rol Technology (RACT); Selective Catalytic Reduction (SCR); Shutdown Perio d; Startup Period; and, Volatile Organic Compound (VOC). Definitions which were rem oved: Combined Cycle Unit and Federal Ozone Non-attainment Area. Definition modi fied for clarity: Emission Control System Operating Parameters.

Section (C)(1) was clarified to add startup and shu tdown periods in addition to those startup and shutdown periods included in the therma l 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 amend ment, 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 tu rbines were determined to limit the availability and feasibility of retrofit technology

. Section (C)(3) was added in response to USEPA comme nt requesting a provision stating emissions should be minimized insofar as technologi cally 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 applic ability 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 typ e of unit has no stack and therefore cannot be tested as specified in the rule.

Section (F) requires any turbine subject to the lim its of Table 1 in section (C)(1)(a) to provide continuous measurement and recording of Emi ssion Control Equipment if required for compliance with this rule. This is an additional monitoring and recordkeeping requirement than in the previous amen dment.

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 t he length of time a unit has to come into compliance after losing its exemption by opera ting in excess of its hour per year limit from 24 to 18 months. This reduction in comp liance time tightens the rule requirements.

Section (I) updates the compliance schedule. A pro vision 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 in stallation.

Various format changes were made for consistency wi th 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 MDAQ MD

On July 1, 1993 the MDAQMD was formed pursuant to s tatute. 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 eff ective in areas which happen to be defined by both air basin design ations and the jurisdictional boundaries of local air districts wi thin those air basins, the MDAQMD “inherited” the SBCAPCD SIP whic h 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 V alley) Portion of the MDAQMD

One of the provisions of the legislation which crea ted the MDAQMD allowed areas contiguous to the MDAQMD boundaries and within the same air basin to leave t heir current air district and become a part of the MDAQMD. On July 1, 1994 the area commonly known as the Palo Verde Valley in Riv erside County, including the City of Blythe, left SCAQMD a nd joined the MDAQMD. Since USEPA adopts SIP revisions in Califo rnia as effective within the jurisdictional boundaries of l ocal air districts, when the local boundaries change the SIP as approve d 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/Pal o Verde Valley the MDAQMD acquired the SIP prior to July 1, 1994 t hat was effective in the Blythe/Palo Verde Valley. Therefo re, the SIP history for the Blythe/Palo Verde Valley Portion of the MDAQMD is based upon the rules adopted and approved for th at 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 pendi ng. USEPA started action on the 08/04/89 version of this rule on 03/23/95 (60 FR 15271). SCAQMD subsequently amended Rule 1134 o n 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 56 470). This rule action occurred after the annexation of t he 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 Riv erside County. The 1995 MDAQMD submission of Rule 1159 is in the SIP for th e 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 t his category in the San Bernardino County section of the District, the Dist rict 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 ap plicability to be district wide, NO X 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 alternat ive federal NO X RACT limit for Southern California Gas Company Turbine Model L M 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 incl uded. 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 Mod el Frame 3, therefore the alternative federal RACT limit of 225 ppmv NO X will apply. District staff has proposed the Westend Model PQ 5191 turbine with an alternative federal NO X of 42 ppmv NO X which is the current permitted limit.

MDAQMD Rule 1159 as adopted on 02/22/95 is in the M DAQMD SIP 61 FR 15719 (04/09/96) and was determined by USEPA to mee t or exceed RACT. Therefore, since the proposed MDAQMD rule is more s tringent than current version in the MDAQMD SIP, the amended rule can sup ersede 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 change s 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 t he 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 pr oposed language. It is removed once the proposed amendmen ts 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 turbines Turbines

. (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 equipmen t is exempt from this rule pursuant to Section (D) of th is rule

. or the turbine is located outside of the Federal Ozone Non

- attainment Area of the Mo jave 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 pe rson appointed to the position of Air Pollution Control Officer of the District pursu ant 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 r ule, to sample, condition (if applicable), analyze, and provide a record of emiss ions on a continuous basis. [Derived from 40 CFR 51.165(a)(1)(xxxi)]

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

(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 D7, 09/24/2009 ( 2 4 ) “ " Emission Control System Operating Parameters ”

– "

- Any operating parameter(s) that the District deems necessary to a nalyze for the determination of compliance. Such parameters include, but are not l imited to, the ammon ia and gas flow rates, the exhaust temperature for the Selective Cataly tic Reduction ( SCR ) , humidity, water injection rate, exhaust gas flow rate and the temperature for water injection. [Alphabetical order corrected.]

( 3 5 4 ) “" Emergency Standby Unit ” – "

- Any stationary Stationary gas Gas turbine Turbine that operates as a mechanical or electrical power s ource for a facility only when the primary power source has been rendered ino perable due to failure beyond the reasonable control of the operator. A p ower interruption pursuant to a voluntary interruptible power supply agreement is n ot to be considered as an emergency loss of primary power. Electricity gener ated by such a unit cannot be sold.

(5) “Emission Control Equipment” – Add-on technolog ies which control the turbine's emissions, including, but not limited to, Selective Catalytic Control (SCR), water injection, steam injection, but excluding DLN. [Added in response to public comment]

(6) “Emission Control System Operating Parameters” – Any operating parameter(s) that the District deems necessary to analyze for th e determination of compliance. Such parameters include, but are not limited to, th e 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.

( 4 6 7 ) “" Enhanced Emissions Monitoring Device ” – "

- Any automated data recording device or system having both data gathering and ret rieval capabilities. Such equipment includes, but is not limited to, Continuo us Emissions Monitoring Systems (CEMS) and Predictive Emissions Monitoring Systems (PEMS).

( 5 7 ) " 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 t he San Bernar dino

- 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 boun dary.(see Map 1). [Applicability changed to allow rule to be enforced district wide, definition no longer used]

( 6 7 8 ) “" Higher Heating Value (HHV) ” – "

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

( 7 8 9 ) “" 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 ( 8 9 10 ) “" Measured NO X NOx Emissions Concentration ” – "

- The concentration of oxides of nitrogen corrected to International Stand ards Organization (ISO) standard conditions:

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

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

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

or an alternate calculation that corrects to ISO st andard conditions and is approved by the APCO.

( 10 ) “PEMS”

– Predictive Emissions Monitoring System [Alphabetical order corrected.]

( 9 11 11 ) “" 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 ope rational parameters (for example, control device secondary voltages and elec tric currents) and other information (for example, gas flow rate, O 2 or CO 2 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)]

( 10 12 13 ) " “ 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 Augme ntation.

( 1 3 15 ) “Reasonably Available Control Technology (RACT)” – The lowest emission limitation that a particular source is capable of m eeting by the application of control technology that is reasonably available con sidering technological and economic feasibility. [USEPA definition 44 FR 53761 (Sept. 17, 1979)]1159-4 MDAQMD Rule 1159 Stationary Gas Turbines D7, 09/24/2009 ( 11 1 4 ) " “ Rating ”

– "

- The continuous megawatt (MW) rating or mechanical equivalent by a manufac turer for gas turbine(s) without power augmentation

. [Alphabetical order corrected. ]

( 15 16 ) “ Selective Catalytic Reduction ( SCR ) ” – Selective Catalytic Reduction A noncombustion control technology that destroys NO X by injecting a reducing agent (e.g., ammonia) into the flue gas that, in th e presence of a catalyst (e.g., vanadium, titanium, or zeolite), converts NO X 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 w hich a unit is brought from a Shutdown status to its operating temperature and pr essure, including the time required by the unit’s emission control system to r each full operation. [Derived from SJVUAPCD Rule 4703 3.29, added in response to public comment]

( 12 1 6 19 ) " “ Stationary Gas Turbine or Unit ” – "

- Any gas turbine system that is gas and/or liquid fueled with or without power Power augmentation Augmentation . This unit is either attached to a foundation at a facility or is portable equipment operated at a spe cific facility for more than 90 days in any 12-month period. Two or more gas turbi nes powering one shaft shall be treated as one unit.

( 13 1 7 20 ) " “ Thermal Stabilization Period ” – "

- The start Start up or shut Shut down time Period necessary to bring the heat recovery steam generato r to the proper operating temperature, not to exceed two hours.

( 1 8 21 ) “Volatile Organic Compound (VOC)” – Any compound of carbon, excluding carbon monoxide, carbon dioxide, carbonic acid, met allic carbides or carbonates, and ammonium carbonate, which participates in atmos pheric photochemical reactions and those compounds listed in 40 CFR 51.1 00(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 m M easured NOx NO X emissionsMDAQMD Rule 1159 1159-5

Stationary Gas Turbines D7, 09/24/2009 Emissions c C oncentration exceeding the emissions limits set forth below: [Added

“Startup and Shutdown Periods” in response to publi c comment]

(a) For stationary Stationary gas Gas turbines Turbines which are not subject to the alternative federal NO X NOx RACT limits of Subsection (C)(1)(b) and (c) , the following federal NO X and Carbon Monoxide (CO) NOx RACT limits in Table 1 apply: [Derived from SJVUAPCD Rule 4703, §5.1.2 4/25/02]

Table 1

NO X and CO Compliance Limits

NO X 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 NO x (ii) For oil

- fired turbines, 65 ppmv NO x (b) For the Southern California Gas Company Turbine Model LM 1500, the following alternative federal NO X NOx RACT limit s shall apply:

(i) 90 ppmv NO X NOx when fired with gaseous fuel

. (c) For the Southern California Gas Company Turbine General Electric Model Frame 3, the following alternative federal NO X RACT limit shall apply:

(i) 225 ppmv NO X when fired with gaseous fuel, achieved through good combustion practices.

(d) For the Westend Model PQ 5191, the following al ternative federal NO X RACT limit shall apply:1159-6 MDAQMD Rule 1159 Stationary Gas Turbines D7, 09/24/2009 (i) 42 ppmv NO X achieved with an SCR when fired with gaseous fuel.

( c e ) For the purposes of these emissions limits the fo llowing conventions are applicable:

(i) Gas includes natural, digester and landfill gas es. (ii) Oil includes kerosene, jet fuel, and distillat e. The sulfur content of the oil shall be less than 0.05%. (iii) NO X NOx = emissions of NO X NOx , 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 statio nary 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 s S tationary g G as t T urbine subject to (C)(1) shall minimize emissions insofar as technologically feasi ble 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 shal l not apply to the operation of:

(a) Laboratory units used in research and testing f or the advancement of gas turbine technology.

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

(c) Combined

- cycle t Stationary Gas T urbines operating as an electric utility which are subject to Rule 1158.

(2) The provisions of this rule, with the exception of Section (F)( e 2 ), 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 t esting only. [These units are not stationary, industrial units and do n ot meet the applicability]MDAQMD Rule 1159 1159-7

Stationary Gas Turbines D7, 09/24/2009 (b) Units rated less than 4 MW an d 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 classif ied as exempt or cl aiming 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 E mission C ontrol P lan (ECP) required pursuant to section (C)(2) shall, at a minimum, include the fol lowing 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 Pe rmit to Operate number

, ; (ii) Name of the gas turbine manufacturer

, ; (iii) Equipment model number

, ; (iv) Manufacturer's rated shaft power output (MW ), ); (v) Type of liquid fuel and/or type of gaseous fuel

, ; (vi) HHV for each fuel

, ; (vii) Heat rate (( BTU Btu / KW kW

- HR hr ), 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 twe lve-month period

. ; (x) The type of NO X NO x emission Emission control Control equipment Equipment , including any auxiliary equipment related to the control of emissions, to be applied

. ; (xi) Documentation showing the current (existing) c oncentration and mass rate of emissions of oxides of nitrogen from t he unit

. ; (xii) A schedule with specified increments of progr ess dates for construction of emissions Emission cont rol Control equipment Equipment , 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 enha nced emissions monitoring device and specify the data gathering an d retrieval capacities thereof

.
( c b ) n N otify the APCO, in writing, before issuance of the Permit To Operate, such information which correlates the Emission Cont rol System Operating Parameters , and PEMS if present, to the associated measured NO X NOx emissions output. This information will be used to determine compliance with applicable provisions of this rule for non-CEM S-equipped turbines and CEMS-equipped units when the CEMS is not operat ing properly.

( d c ) Provide, on an annual basis, compliance testing d ata and information regarding NO X NOx 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 Turbin e shall:

( e a ) For each unit and o O n a daily basis, maintain a turbine operating log t hat 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 o r non-exempt).

(b) The operating log required to be kept pursuant to this rule shall b e kept current and on site for a minimum of two years; and provided to District orMDAQMD 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 Emerge ncy 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 appli cation for a Permit to Operate to the District. Such application shall including a plan detailing actions and a schedule of progress t o meet the applicable RACT limits and provisions of this rule within 24 18 months after the date of the notification; an Emiss ion Control Plan conforming to the requirements of Section (E) for t he emissions control equipment. [The time a unit has to come into compliance after losing its exemption by operating in excess o f its hour per year limit has been lowered to 18 months in respons e 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 emerge ncy declared by a proclamation of the Governor of the State of Califo rnia; and

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



### (H) Test Methods

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

(2) The following test methods shall be used to det ermine compliance with the provisions of this rule.1159-10 MDAQMD Rule 1159 Stationary Gas Turbines D7, 09/24/2009 (a) NO X NOx Emissions emissions shall be determined by EPA Test Method 20.

(b) The Higher Heating Value (HHV) and the Lower He ating Value (LHV) shall be determined by the appropriate method for t he fuel type listed below: [Deleted reference to “most current version” of AST M 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 fo r Calculation Heat Value, Compressibility Factor, and Relative Density (Specific Gravity) of Gaseous Fuel s); or b. ASTM Test Method D 1826-88 (Standard test Method for Caloric (Heating) Value of Gases in Natural Gas Ran ge 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 an y 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:

( 2 a ) An Emissions Control Plan shall be submitted to t he District on of before April 15, 1995 within 90 days of rule adoption . The District shall approve the Plan on or before May 31, 1995 within 30 days of submission.

( 3 b ) On and after May 31, 1995, a A ny affected turbine shall be in full compliance with all applicable provisions of the ru le within 12 months of rule adoption

.
( 4 c ) Demonstrate final compliance with all applicable standards and requirements of the rule within six months of the i nstallation of the NOx NO X reduction technology.MDAQMD Rule 1159 1159-11

Stationary Gas Turbines D7, 09/24/2009 (2) The owner/operator of any new s S tationary g G as t T urbine subject to the provisions of Section (C) shall comply as of the da te of adoption of this rule. [Provision for new turbines added in response to US EPA comments]

[SIP: Submitted as amended mm/dd/yy on mm/dd/yy; Ap proved 4/9/96, 61 FR 15719, 40 CFR 52.220(c)(216)(I)(A)(3)]1159-12 MDAQMD Rule 1159 Stationary Gas Turbines D7, 09/24/2009 This page intentionally left blank.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 Enterpris e, 05/15/09 3. Proof of Publication – Daily Press, 07/10/09 4. Proof of Publication – Riverside Press Enterpris e, 07/10/09B-2 MDAQMD Rule 1159 Final Staff Report, 01/12/10 This page intentionally left blank.MDAQMD Rule 1159 B-3

Final Staff Report, 01/12/10B-4 MDAQMD Rule 1159 Final Staff Report, 01/12/10MDAQMD Rule 1159 B-5

Final Staff Report, 01/12/10B-6 MDAQMD Rule 1159 Final Staff Report, 01/12/10MDAQMD 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, 0 8/10/09C-2 MDAQMD Rule 1159 Final Staff Report, 01/12/10 This page intentionally left blank.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 t o avoid a relaxation of the current SIP approved rule

.
Sections (C)(1)(b) through (C)(1)(d) – We understan d that the units addressed in these sections cannot be easily retrofitted to reduce NOx emissions. We r ecommend that the rule be revised to establish a li mit on the number of hours per year that these units ma y 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 ope rating in excess of its hour per year limit should be lowe red to 18 months.

Section (H)(2)(b) – The versions of the ASTM tests that are included in the SIP-approved version of th e rule should not be changed.

Section (I) – A provision should be added indicatin g that new turbines must be in compliance upon installation. 1

2

3

4

5 Comment Letter 1C-4 MDAQMD Rule 1159 Final Staff Report, 01/12/10 This page intentionally left blank.MDAQMD Rule 1159 C-5

Final Staff Report, 01/12/10 District response to USEPA 06/03/09 comments

1. NO X limit for units smaller than 2 MW with a DLN has b een lowered to 42 ppm to avoid a relaxation of the current SIP approved rule. 2. The District will address this comment during th e upcoming round of ozone attainment planning required by the latest revision to the fed eral 8-hour ozone standard. 3. The time a unit has to come into compliance afte r 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 A STM in response to USEPA and CARB comments in section (H)(2)(b). 5. Section (I) has been modified to clarify the com pliance 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 This page intentionally left blank.MDAQMD Rule 1159 C-7

Final Staff Report, 01/12/10 Comment Letter 2C-8 MDAQMD Rule 1159 Final Staff Report, 01/12/10 1

2MDAQMD 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 requi rement in section (F)(2)(b). 2. Deleted reference to “most current version” of A STM Method in section (H)(2)(b).C-10 MDAQMD Rule 1159 Final Staff Report, 01/12/10 This page intentionally left blank.MDAQMD Rule 1159 C-11

Final Staff Report, 01/12/10 1 Comment Letter 3C-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 4C-14 MDAQMD Rule 1159 Final Staff Report, 01/12/10 1MDAQMD Rule 1159 C-15

Final Staff Report, 01/12/10 District response to CARB 07/21/2009 comment

1. Definitions added for Continuous Emission Monito ring System, Predictive Emissions Monitoring System, and Selective Catalytic Reductio n as requested for clarification and enforceability.C-16 MDAQMD Rule 1159 Final Staff Report, 01/12/10 This page intentionally left blank.MDAQMD Rule 1159 C-17

Final Staff Report, 01/12/10 1

3 2 Comment Letter 5C-18 MDAQMD Rule 1159 Final Staff Report, 01/12/10MDAQMD Rule 1159 C-19

Final Staff Report, 01/12/10 District response to PGE comment letter

1. Definitions for Startup Period, Shutdown Period, an d 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 requirem ents are necessary and does not agree that “or” should be included.C-20 MDAQMD Rule 1159 Final Staff Report, 01/12/10 This page intentionally left blank.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 10/1 4/2009D-2 MDAQMD Rule 1159 Final Staff Report, 01/12/10 This page intentionally left blank.MDAQMD Rule 1159 D-3

Final Staff Report, 01/12/10D-4 MDAQMD Rule 1159 Final Staff Report, 01/12/10MDAQMD Rule 1159 E-1

Final Staff Report, 01/12/10 

### Appendix “E” Bibliography

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

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

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

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

4. San Joaquin Valley Air Pollution Control District R ule 4703 – Stationary Gas Turbines , amended April 25, 2002.

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

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

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

8. MDAQMD Rule 1159 – Stationary Gas Turbines , 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 T urbines (71 FR 38482, July 6, 2006).

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

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

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

14. MDAQMD List and Implementation Schedule for Distric t Measures to Reduce PM Pursuant to Health and Safety Code §39614(d), adopt ed June 27, 2005.E-2 MDAQMD Rule 1159 Final Staff Report, 01/12/10 15. CARB Report to the Legislature, Gas Fired Power Plant NO X Emission Controls and Related Environmental Impacts, May 2004.

16. CARB Guidance for Power Plant Siting and Best Avail able 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 TurbinesF-2 MDAQMD Rule 1159 Final Staff Report, 01/12/10 This page intentionally left blank.

# Mojave Desert Air Quality Management District

Technical Report

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

January 13, 2009

14306 P ARK 

### A VE 

### , V ICTORVILLE 

### , CA 92392-2310

P HONE 

### : (760) 245-1661 F AX 

### : (760) 245-2699This page intentionally left blank.MDAQMD Feasibility Analysis – Stationary Gas Turbin es 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 Deter mining Cost-Effectiveness A-1ii MDAQMD Feasibility Analysis – Stationary Gas Turbin es Technical Report d2, 1/13/2009 

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

Technical Report d2, 1/13/2009 I. EXECUTIVE SUMMARY

California Health & Safety (H&S) Code §39614 requir es the Mojave Desert Air Quality Management District (MDAQMD) to ensure that all fea sible particulate control measures are in place. To address the full scope of possible PM pr oblems, 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 nitroge n oxides (NO X ), sulfur oxides (SO X ), volatile organic compounds (VOC), and ammonia. NO X , SO X , and ammonia combine to form secondary ammonium nitrate and sulfate. VOC can fo rm secondary organic aerosols, as well as participate in the production of secondary ammonium nitrate. NO X and VOC are also precursors of ambient ozone. Sources of ambient PM include co mbustion sources such as trucks and passenger cars, off-road equipment, industrial proc esses, residential wood burning, and forest and agricultural burning; fugitive dust from paved and unpaved roads, construction, mining and agricultural activities; and ammonia from sources s uch as livestock operations, fertilizer application, and motor vehicles. In general, combu stion processes form fine particles, whereas emissions from dust sources tend to be predominantl y coarse particles

The MDAQMD currently has Rule 1159 – Stationary Gas Turbines in place for limiting the emissions of oxides of nitrogen (NO X ) from commercial, industrial and institutional sta tionary 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 NO X and Carbon Monoxide (CO) limits determined to be f easible in the San Joaquin Valley Unified Air Pollution Contro l District (SJVUAPCD) rule analysis. The amended rule will contain several exceptions result ing 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 $5,13 9 per ton (NO X , 2008 dollars) up to $11,516. Not cost-effective and hence not feasible control m easures were $18,821 up to $28,225. The MDAQMD is therefore establishing $11,516 as cost-ef fective (and feasible) and$18,821 as not cost-effective (and infeasible) for NO X control measures (in 2008 dollars).

II. INTRODUCTION

This Technical Report is an analysis of the costs a nd cost-effectiveness for various control technologies and levels for reducing NO X emissions from stationary gas turbines. This anal ysis is being made in response to the mandate of H&S Cod e §39614(d) and the subsequent ARB document Proposed List of Measures to Reduce Particulate Mat ter – PM 10 and PM

2.5 . The recommendations in this report are based upon a cos t effectiveness threshold of not more than2 MDAQMD Feasibility Analysis – Stationary Gas Turbin es Technical Report d2, 1/13/2009 $11,567 per ton of NO X . These cost effectiveness values now in effect de fine a feasibility threshold for this source category which may be use d to aid in evaluation of all subsequent particulate control feasibility analyses for NO X . Several facilities in the MDAQMD have operations po tentially 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 Cal ifornia 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 Stat ion (NAWS) China Lake.

A. California Law

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

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

2.5 to satisfy the initial requirements of H&S Code §3 9614. 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 l ocal measures from this list.

The List and Implementation for District Measures to Re duce PM Pursuant to Health & Safety Code §39614(d) was prepared by the MDAQMD to meet the requirement s of H&S Code §39614(d) by analyzing each control measure on the Local PM Measures List and placing each into one of four categories. The first category in cludes 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 MDAQM D because there are no sources of that type currently located within the District and any new sources would be required to install Best Available Control Technology (BACT) pursuant to the MDAQMD New Source Review (NSR) regulations. A third category includes those measu res that are included or could be included in rules scheduled for adoption or modification in the near future. The final category lists those measures that require additional cost-effectiveness analysis to determine if such rules are feasible to implement within the MDAQMD. The stationary gas turbine analysis falls into this final category.
District staff has prepared this technical report e ntitled Health & Safety Code §39614 Feasibility Analysis for Stationary Gas Turbines to satisfy the analysis commitment for the turbine s category contained in the PM Implementation List.MDAQMD Feasibility Analysis – Stationary Gas Turbin es 3

Technical Report d2, 1/13/2009 In support of this analysis, staff reviewed the fol lowing District Rules and documents referenced in the Proposed List of Measures to Reduce Particulate Mat ter – PM 10 and PM

2.5 :

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

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

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

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

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

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

1. EPA’s Alternative Control Techniques Document - - N O X Emissions from Stationary Gas Turbines, January 1993, EPA-453/R-93-007.

2. 40 CFR 60, Subpart KKKK - Standards of Performan ce for Stationary Combustion Turbines, commencing with section 60.4300

III. TECHNICAL DISCUSSION

A. SOURCE DESCRIPTION

Gas Turbines are available with power outputs rangi ng from less than 1 megawatt (MW) to over 200 MW and are used in a broad scope of application s. A gas turbine is an internal combustion engine that operates with rotary rather than recipr ocating motion. In stationary applications, the hot combustion gases are directed through one or mo re 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 bo th mechanical and electrical drive applications. The primary applications for gas tur bines can be divided into the following categories: the oil and gas industry, stand-by/emer gency electric power generation, independent electric power producers, electric utilities and ot her industrial applications. 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 Emiss ions from Stationary Gas Turbines, Chapter 3, January 1993.4 MDAQMD Feasibility Analysis – Stationary Gas Turbin es Technical Report d2, 1/13/2009 equipment is exempt from this rule pursuant to Sect ion (D) of the rule or the turbine is located outside of the Federal Ozone Nonattainment Area (FO NA) of the MDAQMD.

Several facilities in the MDAQMD have operations po tentially 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 Cal ifornia Gas (Kelso), one turbine operated by Searles Valley Minerals Operations, Inc. (Westen d), and two turbines (portable HIVAS) operated at the NAWS (China Lake). The five permit ted turbines total 35.3 MW. These turbines are summarized in Table 1.

Table 1 Stationary Gas Turbine NO X Emissions

Actual Emissions Facility Model Output (MW) Fuel Operation

2005 & 2006 avg (hr/yr) NO X

Control ppmv TPY

SCG – Kelso GE Frame

3 6.3 NG 869.9 none unknown 16.034 2

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 th at 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 a vailable, and has no viable cogeneration applications.

2 Data provided in Emission Inventory by SCG.MDAQMD Feasibility Analysis – Stationary Gas Turbin es 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 ho rsepower. The engine heat input has a nominal rating of 110,000,000 Btu/hr (LHV). This t urbine is located in the FONA and by current applicability, the only turbine regulated b y 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 bo iler with 14,000 hp. The engine has a maximum heat rate input of 295,000,000 Btu/hr. Thi s turbine is permitted to operate with a SCR unit. It is not equipped with water/steam injectio n, or DLN.

Note: In November 2007 Searles Valley Minerals sta rted up a steam line to transfer process steam from their coal fired boilers at the Argus Fa cility 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 tim es 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 w ill see very limited use.

d. NAWS (China Lake):

NAWS China Lake operates 2 test facilities as follo ws:
Portable HIVAS – A platform mounted, portable Pratt & Whitney TF30P-6E HIVAS at the Weapons Survivability Lab. This unit is a jet engi ne designed to be moved as needed to locations where the necessary positions and conditi ons relative to aerospace vehicle survivability testing can be achieved. This turbin e 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 un it will be exempted from provisions of amended Rule 1159.

Weapons Survivability Range HIVAS2 – Nine Pratt & W hitney TF-33 turbofan engines in a square cluster with their axes parallel and horizon tal. HIVAS is located on a turntable allowing it to be used on any of the two adjacent t est 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 veh icle and/or missile engines. This turbine is in a different classification (portable) than the o ther units included in this analysis. The control technologies discussed in this report are t herefore 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 Technologies6 MDAQMD Feasibility Analysis – Stationary Gas Turbin es Technical Report d2, 1/13/2009 Add-on technologies for reducing NO X available for stationary gas turbines include wet controls (water and steam injection), combustion controls (D ry low-NO X (DLN)), Selective Catalytic Reduction (SCR), a combination of controls, and alt ernative 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 o f thermal NO X . This control technique is available for new turbine models and can be retrofi tted to most existing installations. 3
Controlled NO X 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-NO X (DLN))

The DLN system reduces thermal NO X formation without injecting water or steam. DLN u ses specially designed burner elements to change the tu rbine’s combustion mechanics, reducing flame temperature. Two designs have been developed : lean premixed combustion and rich/quench/lean staged combustion. Controlled NO X emission levels using dry lean premixed combustion range from 9 to 42 ppmv for operation on natural gas fuel. The low end of this range (9 to 25 ppmv) has been limited to turbines above 2 0 MW. 4 Controlled NO X emissions from smaller turbines typically range from 25 to 42 ppmv

. DLN is commonly found on new turbines. Specificall y tailored retrofit technology may not be commercially available for all turbines. Turbine m anufacturers estimate retrofit costs to be approximately 40 to 60 percent higher than new equi pment costs. As stated by Southern California Gas in 1991, Dry Low-NO X combustors are very promising technology for many gas turbines and may be well suited to gasline pipeline turbines. However, turbine manufacturers have not and will not develop low NO X combustors for obsolete, older models. To do so w ould not be cost effective for the small number of units presently in use.

c. SCR

An SCR system treats flue gas using an ammonia (NH 3 ) injection system and a catalytic reactor to reduce NO X . An injection grid disperses NH 3 in the flue gas upstream of the catalyst and the NH 3 and NO X are reduced to N 2 and water in the catalyst reactor. This control t echnique reduces both thermal NO X and fuel NO X . Most SCR installations use a base-metal catalyst with an operating temperature window of 400oF to 800oF. Th is operating temperature has limited SCR to cogeneration or combined cycle applications with reduced flue gas temperatures. Hightemperature zeolyte catalysts which have an operati ng window of up to 1100oF are now available that offer potential for SCR applications with simp le cycle gas turbines.

3 EPA, Alternate Control Techniques Document - - NOx Emiss ions from Stationary Gas Turbines, Pg. 2-5, January 1993.
4 EPA, Alternate Control Techniques Document - - NOx Emiss ions from Stationary Gas Turbines, Pg. 2-10, January 1993.MDAQMD Feasibility Analysis – Stationary Gas Turbin es 7

Technical Report d2, 1/13/2009 SCR technology has not proven useful on gasline tur bines 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 cha nges in turbine speed and load cause significant variation in exhaust temperature and fl ow. Maintaining proper exhaust temperature and controlling NH 3 flow rate through operational swings would be diff icult and costly, especially in an unmanned, remotely operated facili ty.

d. Alternative Fuels

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

3. Rule History

The 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 MDAQ MD Rule 1159 and are applicable to stationary gas turbines located in the FONA:

1. For stationary gas turbines which are not subjec t to the alternative federal NO X Reasonably Available Control Technology (RACT) limi ts, the following federal NO X RACT limits apply:

a. For gas-fired turbines, 42 ppmv NO X b. For oil-fired turbines, 65 ppmv NO X
2. For the Southern California Gas Company Turbine Model LM 1500, the following alternative federal NO X RACT limits shall apply:

a. 90 ppmv NO X when fired with gaseous fuel

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

a. Gas includes natural, digester and landfill gase s. b. Oil includes kerosene, jet fuel, and distillate. The sulfur content of the oil shall be less than 0.05%. c. NO X = emissions of NO X , 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 peri od.

C. BASIS FOR STATIONARY GAS TURBINE ANALYSIS8 MDAQMD Feasibility Analysis – Stationary Gas Turbin es Technical Report d2, 1/13/2009 This analysis examines the cost-effectiveness of im plementing certain district rules as required by H&S Code §39614 to reduce public exposure to PM 10 and PM 2.5 . These rules were determined to be a list of the most readily availab le, feasible, and cost-effective control measures that could be employed by CARB and the air district s to reduce PM 10 and PM 2.5 (collectively PM). Appendix B of the Proposed List of Measures to Reduce Particulate Mat ter , Strategy D – Combustion Sources Measures reduce NO X , SO X , VOC, CO, or PM10 and PM2.5, item 46(a, b, and c), refer to three rules: SMAQMD Rule 413 – Stationary Gas Turbines (5/1/97), SJVAPCD Rule 4703 – Stationary Gas Turbines (4/25/02), and SCAQMD Rule 1134 – Emissions of Oxides of Nitrogen from Stationary Gas Turbines (8/8/97) on which to base this analysis.

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

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

This amendment of the rule applies to all stationar y 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 nitro gen oxides (NO X ) 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 firefi ghting, 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 ser ving utility or distribution on the grid; and d. Operation for other than maintenance shall be limit ed to actual interruptions of electrical power by the serving utility, emergency water pumpi ng for flood control or firefighting, emergency potable water pumping, or emergency sewag e pumping.

Exemptions are also made for units removed from ser vice before May 31, 1997, laboratory gas turbine units used in research and testing for the advancement of gas turbine technology, and for the startup/shutdown period not exceed one hour for startup and one hour for shutdown.MDAQMD Feasibility Analysis – Stationary Gas Turbin es 9

Technical Report d2, 1/13/2009 Table 2 Summary of RACT and BARCT requirements contained in SMAQMD Rule 413

NO X Emission Limit (ppmv) Requirements Time of

Operation (hr/yr) Unit Size Rating

(MW) Gaseous Fuel Liquid Fuel

RACT any ≥ 0.3 42.0 65.0

any ≥ 0.3 to <2.9 42.0 65.0

<877 ≥ 2.9 42.0 65.0

≥ 877 ≥ 2.9 to <10 25.0 65.0

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

≥ 877 ≥ 10 (w SCR) 9.0 25.0

Table 3 SMAQMD Limits as applicable to MDAQMD turbines

Turbine NO X 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 o r greater than 0.3 megawatt (MW) and/or a maximum heat input rating of more than 3,000,000 BT U per hour, for the purpose of limiting oxides of nitrogen (NO X ) 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 req uirements are those used as laboratory units used in the research and testing for the adva ncement of gas turbine technology, and units limited by permit condition to be operated exclusiv ely for firefighting and/or flood control. The provisions of this rule with the exception of the E mission Control Plan and record keeping10 MDAQMD Feasibility Analysis – Stationary Gas Turbin es 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 an d testing purposes, and units less than 4 MW in rating and limited by permit condition to operat e less than 877 hours per calendar year.

Table 4 Summary of Tier 2 NO X Compliance Limits contained in SJVAPCD Rule 4703

NO X Compliance Limit, ppmvd at

15% O 2 Turbine Classification Rating Gas Fuel Liquid Fuel

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

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

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

5 (Standard 5 ) 25 (Standard) d) Greater than 10 MW, Combined cycle. 3 (Enhanced 6 ) 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 wit h rule limits by dates ranging from 04/25/2002 to 0 4/25/2005.
6 Operators complying with the Enhanced Compliance o ption had until 04/30/2008 to demonstrate and maint ain compliance with enhanced limit, or to demonstrate a nd maintain compliance within 90 days following nex t major overhaul if occurring after 04/30/2004.MDAQMD Feasibility Analysis – Stationary Gas Turbin es 11

Technical Report d2, 1/13/2009 Table 5

Summary of CO Compliance Limits contained in SJVAPC D Rule 4703

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

Units not identified below 200

General Electric Frame 7 25

General Electric Frame 7 with Quiet Combustors 52

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

Table 6 SJVAQMD Limits as applicable to MDAQMD turbines

Turbine NO X 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 sta tionary gas turbines, 0.3 megawatt (MW) and larger, as of August 4, 1989.12 MDAQMD Feasibility Analysis – Stationary Gas Turbin es Technical Report d2, 1/13/2009 Laboratory gas turbine units used in research and t esting, gas turbine units used exclusively for firefighting and/or flood control, chemical process ing gas turbine units, and all existing pipeline gas turbines located in the Southeast Desert Air Ba sin (SEDAB) are exempt from this rule. Emissions limitations, and monitoring and source te sting and certain recordkeeping requirements do not apply to emergency standby and peaking gas t urbine units operating less than 200 hours per calendar year, or existing gas turbines units l ocated in the SEDAB as well as on San Clemente Island rated below 4 megawatts and operati ng less than 877 hours per year.

Compliance Limit

= Reference Limit %

25 EFF ×

Where:

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

dry basis, and averaged over 15 consecutive minutes . These limits for various megawatt ratings (continuous rating by the manufact urer without power augmentation) are as follows:

Table 7 Reference NO X Limits, ppm contained in SCAQMD Rule 1134

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

0.3 to Less Than 2.9 MW 25

2.9 to Less Than 10.0 MW 9

2.9 to Less Than 10.0 MW No SCR 15

10.0 MW and Over 9

10.0 MW and Over No SCR 12

60 MW and Over Combined Cycle No SCR 15

60 MW and Over Combined Cycle 9

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

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

or,

EFF = Manufacturer’s stated efficiency at LHV HHV LHV ×MDAQMD Feasibility Analysis – Stationary Gas Turbin es 13

Technical Report d2, 1/13/2009 or,
EFF = the demonstrated percent efficiency of the ga s turbine unit only as calculated without consideration of any downstream energy recovery fro m the actual heat rate, (BTU/KW HR) or 1.34 BTU/HP; corrected to the HHV of the fuel, as m easured at the peak load for that facility; or the manufacturer’s continuous rated percent efficie ncy of the gas turbine unit after correction from LHV to the HHV of the fuel, whichever is highe r. The value of EFF shall not be less than 25 percent. Gas turbine units with lower efficienc ies will be assigned a 25 percent efficiency for this calculation.

Operators of stationary gas turbines shall be subje ct to SCAQMD Regulation XIII if carbon monoxide (CO) emissions increase as a result of the application of NO X controls.

Table 8 SCAQMD Limits as applicable to MDAQMD turbines

Turbine NO X 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 Sou thern California Gas Company regarding the turbine operated in Adelanto (GE LM 1500), it w as stated that due to the age of this equipment and the extremely small number of units i n operation, there is no incentive nor any plan by the manufacturer to develop the modificatio ns that would allow either the retrofit of this turbine for water/steam injection or SCR”. The Dis trict received additional correspondence on 03/14/2008 from Southern California Gas Company reg arding 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 feasib le control technology for this turbine”. In addition, there is no low-NO X combustor available for the Adelanto turbine accor ding to this same correspondence received from Southern Californ ia Gas Company.14 MDAQMD Feasibility Analysis – Stationary Gas Turbin es Technical Report d2, 1/13/2009 District staff has determined that there is no tech nology available and this unit it is not feasible t o retrofit or modify. The current version of Rule 11 59 specifies the alternative federal NO X RACT limit of 90 ppmv NO X for the Southern California Gas Company Turbine Mod el LM 1500 when fired with gaseous fuel. Source testing performed in 2005 showed the unit operated between 51- 70 ppm NO X corrected to 15 percent oxygen and ISO standard co nditions. CO concentration was 78-98 ppm. The District proposes to maintain t he alternative federal NO X limit currently in Rule 1159. This turbine would be subject to the pr oposed 200 ppmv CO limit.

2. Kelso Turbine:

In a May 16, 1991 letter to the MDAQMD from the Sou thern 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 operatio n, there is no incentive nor any plan by the manufacturer to develop the modifications that woul d allow either the retrofit of these turbines for water/steam injection or SCR”. The District re ceived additional correspondence on 03/14/2008 from Southern California Gas Company reg arding the Kelso turbine, stating that “Our Kelso facility does not have water available f or either water or steam injection. Water would have to be trucked to the site creating new m obile source emissions. Therefore, neither water or steam injection is feasible at this locati on”. In addition, there are no low-NO X combustors available for the Kelso turbine accordin g to correspondence received from Southern California Gas Company on 03/14/2008.

District staff has determined that there is no tech nology available and this unit it is not feasible t o retrofit or modify. The current version of Rule 11 59 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 mill ion Btu per hour. There are currently no NO X or CO limits applicable to this turbine. The Distr ict proposes to limit this turbine to good Combustion Controls, estimated as equivalent to 225 ppmv NO X .

3. SVM Westend Turbine:

Searles Valley Minerals Operations, Inc. does not u se the water or steam injection system in their Westend turbine citing concern with the increased m aintenance cost and down time.

Searles Valley Minerals currently operates their We stend turbine in conjunction with a SCR unit. This unit reduces NO X emission to the permitted limit of 42 ppm. GE est imated that with DLN the NO X 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 NO X 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 reduc e NO X to 33 ppm, with the SCR then reducing NO X to 8 ppm. Based on 2006 pricing information from GE, adding DLN would cost approximately 7.5 million dollars, with an addition al yearly operation/maintenance cost of approximately one million dollars. This unit curre ntly is permitted at 46.3 lb/hr NOX at 15 percent oxygen (42 ppm) when averaged over a rollin g three-hour average. This unit is located outside of the FONA, thereby making current Rule 11 59 not applicable. The District proposes to maintain the alternative federal NO X limit of 42 ppmv NO X for the SVM Westend turbine. TheMDAQMD Feasibility Analysis – Stationary Gas Turbin es 15

Technical Report d2, 1/13/2009 District has determined that adding DLN to the exis ting SCR is not cost-effective at $18,821 per ton of NO X reduced (2008 dollars). See appendix A for cost e ffectiveness calculations. This turbine would be subject to the proposed 200 ppmv C O 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 NO X and Carbon Monoxide (CO) limits determined to be f easible in the SJVUAPCD rule analysis. The amended rule will cont ain several exceptions resulting from technical infeasibility, special classification, an d cost-effectiveness evaluations.

Table 9 Proposed Limits in Rule 1159

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

hours per
year Turbine

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

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

DLN > 877 < 2 MW 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 ava ilable or feasible. Maintain 90 ppmv limit of alternative Federal RACT limit in exi sting rule. Very limited use.

• Kelso: No DLN, SCR, or steam/water injection availa ble or feasible. Proposed limit of 225 ppmv NO X (alternative Federal RACT as good combustion practi ces).

• 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 Turbin es Technical Report d2, 1/13/2009 • NAWS: Exempt by classification (portable) and limi ted usage.

These recommendations for amending Rule 1159 fulfil l the District commitment to analyze and implement measures to reduce PM in response to ARB document Proposed List of Measures to Reduce Particulate Matter – PM 10 and PM

2.5 . measure 46(a, b, and c).MDAQMD Feasibility Analysis – Stationary Gas Turbin es A

- 1

Technical Report d2, 1/13/2009 

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

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 Disco unted Cash Flow Factor (SCAQMD method) Annual inflation rate of 3% used to adjust to curre nt year (2008 dollars) Capital cost annualized by multiplying by CRF base d on 15 years at 10%A-2 MDAQMD Feasibility Analysis – Stationary Gas Turbin es 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.