AVAQMD Rule 1134 C

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Final Staff Report, 03/17/10 

### APPENDIX "C"

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

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

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Final Staff Report, 03/17/10 2 3 4 5C-6 AVAQMD Rule 1134 Final Staff Report, 03/17/10AVAQMD Rule 1134 C

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

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

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

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Final Staff Report, 03/17/10 District response to Public Comment Letter 1 1. Per later email correspondence (See public comme nt #3) regarding potential NO x limits for biogas turbines greater than 10MWs, County Sanitation Dist rict of Los Angeles obtained feedback from Solar Turbines (currently the only biogas turbine manufac turer). Solar Turbines indicated that the largest operational biogas turbine is their 10MW Mars100 ga s turbine. Accordingly, the County Sanitation Districts of Los Angeles was unable to identify any applicable emission data from larger biogas turbines. As a result, the Sanitation Districts re commended utilizing existing rule language for biog as turbines (i.e., a reference NO x limit of 25ppm for 0.3 to 10 MW). An additional c ompliance limit has been added for turbines which utilize digester gas and/or landfill gas which does not change the NO x or CO compliance limit for the size range of turbines identified, merely specifies the fuel technology. 2. If an owner or operator of a stationary gas turb ine is required to install emission control equipment for compliance with the rule (see §(F)(1) ), an enhanced emission monitoring device shall be installed (see §(F)(1)(a)(iii), not limited to CEMS or PEMS, see §(B)(10)). 3. The AVAQMD is not mandating the use of specific control technologies. 4. Table 5 in the Technical Report of the Staff Rep ort (Appendix “F”) has been corrected to reflect the appropriate proposed limit of 42 ppmv. 5. The Staff Report has been amended to discuss the significant difficulties and problems associated with several turbine control technologies (See Appe ndix “F” Technical Report, (III)(A)(2)(b)). The District appreciates the inclusion of the backg round information on “Siloxanes in biogases from landfills and wastewater digesters.”C-14 AVAQMD Rule 1134 Final Staff Report, 03/17/10 This page intentionally left blank.AVAQMD Rule 1134 C

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

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Final Staff Report, 03/17/10 District response to Comment Letter 2 No comment required.C-18 AVAQMD Rule 1134 Final Staff Report, 03/17/10 This page intentionally left blank.AVAQMD Rule 1134 C

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

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Final Staff Report, 03/17/10 District response to Public Comment Letter 3 Please see public comment letter #1, response 1.