Free Exhibits - District Court of California - California

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EXHIBIT C

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BAY AREA

AIRQJJALITY
MANAGEMENT

D

ISTRICT

Final Determination of Compliance San Francisco Electric Reliability Project

Application 12344 Engineering Division Bay Area Air Quality Management District

Revised and Reissued January 19, 2006

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Table of Contents
Introduction A. Background B. Project Descnption 1. 2. 3. ii. IlL Process Eqwpment Equipment Operating Scenario Air Pollution Control Strategies and Equipment Facility Emissions Statement of Compliance
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j

1 2 2 2 3 4 9 9 9 13 14 15 18 18 30

A. District Regulation 2, Rule 2: New Source Review 1. 2. District Regulation 2-2-301: BACT Detentinations District Regulation 2-2-302: Offset Requirements, POCs and NO 1
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B. Health Risk Screening Analysis C. Other Applicable District Rules and Regulations D. CEQA IV. Permit Conditions

V. Recommendation

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List of Tables
Table
1 Maximum Hourly, Daily and Annual Regulated Air Pollutant Emissions for theSFERP Maximum Facility Toxic Air Contaminant (TAC) Emissions Maximum Annual Facility Regulated Air Pollutant Emissio Facility Offset Requirements Health Risk Screening Analysis Results 14 14

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I.

Introduction

This report is the Bay Area Air Quality Management District (BAAQMD, or "District") Final Determination of Compliance (FDOC) for the San Francisco E]ectric Reliability Project (SPERP), a natural gas-fred, simple cycle power plant proposed by the City and County of San Francisco. This facility is to be located at the corner of Maryland Street and 25th Street in the Potrero area of San Francisco, on a 4-acre site of city-owned land. The SFERP will consist of three natural gasfired General Electric LM6000PC simple cycle combustion turbine generators (CTGs) with associated equipment and two-cell wet cooling towers. The proposed facility will be capable of generating a nominal output of 145 megawatts (MW). The SFERP is currently undergoing review by the California Energy Commission (CEC) for certification pursuant to the Warren-Aiquist Act (Public Resources Code §25500 et seq.). In accordance with BAAQMD Regulation 2, Rule 2, Best Available Control Technology (BACT) requirements must be applied to the CTGs to minimize emissions of precursor organic compounds (POCs), oxides of nitrogen (N0J, sulfur dioxide (802), particulate matter with an aerodynamic diameter less than or equal to 10 microns (PM and carbon monoxide (CO). hi addition, the ), 10 applicant must provide emission oflets for NOR. Emissions of all regulated air pollutants will be less than 100 tons per year; therefore, the SEER? is not a Major Facility under District regulations and is not subject to Prevention of Significant Deterioration (PSD) requirements.
A. Background

pursuant to BAAQMD Regulation 2, Rule 3. Section 405, this document serves as the FDOC for the SFERP. It will also serve as the engineering evaluation report for the BAAQMD Authority to Construct under Application #12344. The FDOC describes how the proposed facility will comply with applicable federal, state, and BAAQMD regulations, including the BACT and emission offset requirements specified in the District's New Source Review Regulation 2, Rule 2. In accordance with Regulation 2-3-405, the District will not issue an Authority to Construct until after the CEC issues a final certification for the SFERP. Air pollutant emission calculations and permit conditions necessary to assure compliance with applicable rules and regulations are included in this FDOC. The document also includes a summary of the Health Risk Screening Analysis (HRSA) completed by the District to estimate the maximum public health risks that will result from the project's toxic air contaminant (TALC) emissions. In accordance with BAAQMD Regulation 2, Rule 3, Section 404, the Preliminary Deteimination of Compliance (PDOC) for this project was subject to the public notice, public inspection, and 30-day public comment period requirements of District Regulation 2, Rule 2, Sections 406 and 407. The District has considered public comments submitted, and has a number of appropriate changes into this FDOC.

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B. 1.

Project Description Process Equipment

The applicant is proposing a simple-cycle combustion turbine facility with a nominal net electrical output of 145 MW. The SFERP will consist of the following proposed equipment: S-I Combustion Turbine Generator (CTG) #1, General Electric LM-6000PC Sprint, 487.3 M.MBtuihr maximum rated capacity, natural gas fired only, Abated by A-I Selective Catalytic Reduction (5CR) System and A-2 Oxidation Catalyst. Combustion Turbine Generator (CTG) #2, General Electric IM-6000PC Sprint, 487.3 MMBtnJbr maximum rated capacity, natural gas fired only, Abated by A-3 Selective Catalytic Reduction (SCR) System and A4 Oxidation Catalyst. Combustion Turbine Generator (Cr0) #3, General Electric LM-6000PC Sprint, 487.3 MMBtuJhr maximum rated capacity, natural gas fired onlyç Abated by A-S Selective Catalytic Reduction (5CR) System and A-6 Oxidation Catalyst. Cooling Tower System, Two-cell, 40' H x 50' Lx 14' W, 52,000 gpd (exempt from permit requirements per District Regulation 2-1-103) Aqueous Ammonia Storage Taut 29% H1, 8' cia. x 30' L, 11,300 gallon capacity (exempt from permit requirements per District Regulation 2-1-123)

5-2

5-3

S-4

S-S

10 The facility will include two smafl two-cell cooling towers for turbine cooling (5-4). PM from these cooling towers are estimated to be less than 0.2 lb/day. The cooling towers emissions are exempt from District permit requirements under Regulation 2-1-103. The facility also will include a tank for storage of aqueous ammonia to be used in the 5CR systems to reduce NO emissions (5-5). The tank is exempt from District permit requirements under Regulation 2-1-123. 2. Equipment Operating Scenario

Maximum hourly, daily, and annual emissions from the LM-Ô000PC combustion turbines were estimated based on expected peaking operation and proposed annual operating limitations. As proposed, each natural gas fired C'rG will have a maximum heat input of 487.3 MMBTU per hour, 11,700 MMBTU per day, and 4,268,750 MMBTTJ per year. Annual Emissions Total annual emissions for all three turbines were calculated based on 12,000 combined operating hours per year at 60°F ambient temperature and full load conditions. Actual annual emissions are expected to be less than the calculated values, as actual operation is projected to be less than 12,000 hours per year, the facility will operate at times at reduced load, and higher ambient temperatures are expected. The ofThets provided will be based on the calculated annual emissions, and permit conditions will be imposed to limit annual emissions to the amount of offsets provided. Emissions of NO and CO, the pollutants of greatest concern, will be continuously monitored, as will fuel usage. Any or all of
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the combustion turbines may be operated up to 24 hours per day, 7 days per week, with total plantwide heat input not to exceed the equivalent of 12,000 hours of full-load operation per year or the mass emissions limits. Each combustion gas turbine may have a total 250 hours per year of startup/shutdown activity.

Daily Emissions Maximum hourly emissions from the CTGs are expected to occur during a startup or shutdown. Each CTG will be limited to the daily maximum emission rates listed below. The maximum emissions for each turbine are summarized as follows. Maximum Emission Rates for each Combustion Gas Turbine Operating Mode Startup/Shutdown (lb/br) Full Load Gb/br) Daily Maximum Gb/day) 3. 1 NO 40 4.4 283

J

CO 10 4.3 132

POC 2 1.2 34

PMio 2.5 2.5 60

Air Pollution Control Strategies and Equipment

The proposed SFERP triggers the BACT requirements of New Source Review in District . 10 , 1 Regulation 2, Rule 2 for emissions of NO CO, POC, S02, and PM The applicant has proposed following controls: the Selective Catalytic Reduction with Ammonia Injection for the Control of NOT The S-i, S-2, and 5-3 gas turbines will be equipped with evaporative inter-cooling and water 1 injection to minimize NO emissions. NO emissions will be further reduced through the use of a reduction (SCR) system using ammonia injection. The CTGs will achieve the selective catalytic 1 BACT-level NO emissions of 2.5 ppmvd @ 15% 02 (one hour average) and will be subject to an combined emission cap of 39.8 tons per year, which is equivalent to an annual average of annual 1 2.5 ppmvd @15 % 02 at 12,000 hours per year of operation. SCR can typically achieve NO emission reductions in the range of about 80 to 95 percent without exceeding the applicable ammonia limit. Ammonia emissions will be limited to 10 ppmvd @ 15 % 02 and a total of 39.8 tons per year. NOx catalytic control equipment operates properly only within a specific temperature window. Control efficiencies will drop if temperatures are outside of this defined temperature range (i.e., either too hot or cool). Hot temperatures associated with uncooled exhaust may cause sintering of Conversely, low the catalysts, reducing catalyst surface area and thus reducing activity. 1 temperatures can result in higher NO emissions and unreacted ammonia because the catalyst temperature to become chemically active. requires a minimum Emission control system inlet temperatures are higher for simple-cycle gas turbines than for combined-cycle turbines. Gas turbines may have exhaust temperatures ranging up to 1000 °F. In
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combined-cycle gas turbines, heat is removed from exhaust gases with a Heat Recovery Steam Generator (HSRG), resulting in a decrease in gas temperatures entering the emission control system. In simple-cycle systems, the turbine exhaust gas goes to the emission control system without being cooled. Catalysts used for selective catalytic reduction are not as reliable in controlling N0 at the higher temperatures with uncooled exhaust of simple cycle gas turbine. The higher operating temperature resifits in catalyst deactivation, reducing the catalyst efficiency. As a result, gas turbine emissions from combined-cycle operations can be readily controlled with consistently higher efficiency. Oxidation Catalyst to Minimize CO and POC Emissions The proposed gas turbines S-i, 5-2, and 5-3, also trigger BACT for CO and POC emissions. A CO oxidation catalyst is designed to catalytically oxidize the CO and POC to achieve BACT-level CO emissions of 4 ppmvd @ 15 % 02 (three hour average) and will be subject to an annual facility emission limit of 28 tons of CO per year. The POC emission level will be limited to 2.0 ppmvd 15% 02 andwill be subject to an annual limit of 7.7 tonsper year. 10 Exclusive Use of Clean-burDinE Natural as to Minimize 802 and PM Emissions 10 use commercial natural gas as a fuel to minimize 802 and PM The gas turbines will exclusively 2 emissions. Because the emission rate of SO depends on the sulIbr content of the fuel burned and is the burner type or other combustion characteristics, the use of natural gas will not dependent upon . 2 10 result in the lowest possible emissions of SO PM emissions will be minimized through the use practices and "clean burning" natural gas. of best combustion

II.

Facifity Emissions

N0, CO, POC and ammonia will be all limited to BACT levels by enforceable permit conditions, 10 , 2 including certain maximum outlet emission concentrations. BACT for SO and PM control is the exclusive use of clean-burning natural gas. The outlet concentration, in ppm by volume and dry , 10 (ppmvd), is not specifically limited for 502 and PM so the hourly emission rate will be taken to those values calculated using the natural gas sulfbr content and the rate provided by General be Electric, the turbine manufacturer, respectively. Calculated annual 502 emissions are based on utility natural gas containing an average of 0.33 grains of sulfur per 100 scf. Daily and hourly emissions are based on the content of 1 grain of 10 sulfur per 100 scf. PM emissions are based on the Los Esteros Critical Energy Center turbine 10 manufacturer guaranteed emission rate of 2.5 pounds PM per hour. The facility regulated air pollutant emissions, and TAC emissions, are presented in the following sections. Detailed emission calculations, including the derivations of emission factors are presented below.

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l3aseload Emissions Baseload emissions are the maximum hourly emissions under baseload conditions. A summary of the baseload hourly emissions from each turbine is given below, followed by detailed emission calculations for each pollutant. Summary of Baseload Hourly Emission Estimates, lb/hour-turbine POC 10 PM 2 SO 3 NH CO 1.2 2.5 4.3 1.37 6.48

NO,, (as NOi) 4.4

NO,, emissions: The applicant has proposed a NO,, limit of 2.5 ppmvd @ 15 % 02 (averaged over one hour), which complies with BACT requirements for these gas turbines. The NO,, emissions 15 % 02. This from the turbines will be limited by permit conditions to 2.5 ppmvd ) 2 concentration is converted to mass NO,, emissions (as NO as follows: S-l 9 O. 2 (2.5 ppmvd20.95-0)/( 5) = 8.65 ppinvd @ 0 % 0 z (8.65/1,000,000)(1 mo11385.3 dscf)(46.0l lb NOx/lb-molX8lO0 dscUMl4Btu) = 0.0090 lb NOr/MMBtu The hourly NO,, (as NO2) mass emissions rate based on the maximum firing rate of each turbine is calculated as follows: (0.0090 lb NO,,/MMBtu)(487.3 MMBtu/hr) = 4.39 lb NOx/hr CO emissions: The hourly CO emissions from the turbines will be limited by permit condition to 4 ppmvd @ 15 % 02. The hourly CO mass emission rate based on the maximum firing rate of each turbine is calculated as follows based on 4 ppmvd @ 15 % 02: -lS) 95 O. 2 (4 ppmvd)(20.95-0)/( = 14.08 ppmvd @0% 02 (14.08/l,000,000)(1mol1385.3)(28 lb C0/lb-mol)/lb-mol)(8700 dscflMMBtu) = 0.0089 lb CO/MMBtu (0.0089 lb CO MMBtuX487.3 MMBtu/hr) = 4.31 lb CO/hr POC emissions: The POC emission from the turbines will be limited by permit condition to 2.0 ppmvd 15 % 02. The hourly POC mass emission rate based on the maximum firing rate of each turbine is calculated as follows assuming the POC is methane (CH.,) and based on 2.0 ppmvd @ 15 %02.
-lS) 95 . 120 (2 ppmvd)(20.95-0) = 7.04 ppmvd @ % 02 /lb-mol)/lb-mol)(8700 4 (7.0411,000,000)(lrnolJ38S.3)(l6 lb CH dscflMMBtu) CHJF'.4MBtuX487.3 MMBtu/hr) = 1.24 lb POC/hr (0.00254 lb 0.0025 lb POC/MNBtu

) 3 Ammonia emissions: The ammonia (NH emission from the turbines will be limited by permit condition to 10 ppmvd @ 15 % 02. The hourly mass emission rate based on the maximum firing 15 % 02. rate of each turbine is calculated as follows based on 10 ppmvd -lS) 95 . 20 (10 ppmvd)(20.95-O)/ = 35.21 ppmvd @ % 0 /MMBtu 3 385.3)(17 /lb-mol)/lb.molXS700 1 3 (35.21/l,000,000)(11n01 lb NH dscflMlvlBtu) = 0.0133 lb NH
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/hr 3 (0.0133 lb NH,/M1'.4BtuX4S7.3 MMBtu/hr)= 6.48 IbNH

) 2 Sulfur Dioxide emissions: The sulfur dioxide (SO emission factor is based upon a maximum expected average natural gas sulfur content grains per 100 scf and a higher heating value of 1017 Btu/scf. The expected annual average sulfur content (used to calculate annual emissions) is 0.33 grain per 100 scf. /lb 2 6 (1.0 grain/I Ooscf)(10 Btu/MMBtu) (2 lb S0 S)I[7000 grain/lbl017 Btu/scflj
=

0.0028 SO lb/MMBtu 2

/hr 2 (0.00281b SO'Mlv1Btu)(487.3 MMBtu/hr) = 1.37 lb S0 (annual limit based on expected average of 0.33 grain per 100 scf) 10 10 PM emissions: The PM emission factor is based upon the BACT-required level of 2.5 lb/hr based on similar installations. Emissions Durine Startut, and Shutdown Each CTG may operate up to 24 hours per day, with a typical two 2-hour startups per day and two 2-half-hour shutdowns per day totaling 5 hours of. startup/shutdown activity per turbine. Maximum emission rates expected to occur during the startup and shutdown of each CTG are shown as follows.

The startup/shutdown hourly emission estimates are based on the emission estimates provided by the consultant for the SFERP. Startup/Shutdown Hourly Emission Estimates, lb/hour-turbine NO(as.NOj; 40

ti H:. POC
10 2 2.5

Maximum Daily Emissions: A summary of the maximum daily emissions from each turbine is given below, followed by detailed emission calculations for each pollutant. Maximum Daily Emission Estimates, lb/day-turbine

E

NO ) 2 (as NO 283

POC 34

10 PM 60

CO 132

502 33

1

3 NB 156

Maximum daily emissions are estimated based on 24 hours of worst-case emission rates. The worst-case daily emission rate is either a day, including a startup/shutdown, with the balance of the daily operations based on 100% load (60 °F ambient temperature); or a day with operation at 100% load for 24 hours. The baseload hourly emission estimates are based on aflowable BACT concentration emission limits at 100% load, in those cases in which the startup/shutdown emissions are less than the baseline, the baseline number was used for the entire 24 hours.
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): 2 NO (as NO (40 Lb/hr-startup/stop)(5 bouts) + (4.39 lb/hr-baseload)(l9hours) or (4.39 lb/hr. x 24 hours/day) = 105.4 lb/day CO: (10 Lb/hr-startup/stopX5hours) + (4.31 lb/hr-baseload)(19 hours) or (4.31 lb/hr. x 24 hours/thy) = 103.4 lb/day

=

283.4 lb/thy NO (as NO ) 2

=

131.9 lb/day CO

POC: (2 lb/hr-startup/sbutdown)(S hours) + (1.24 ]b/hr-base]oad)(19 hours) or (1.24 lb/hr x 24 hours/day) = 29.8 lb/day POC : 10 PM (2.5 lb/br-startup/shutdoWn)(Shours) + (2.5 ]b/hour)(19 hours)

33.56 lb/thy POC

=

10 60 lb/thy PM

: 2 SO 2 (1.37 lb/hr-startup/shutdown)(5 hours) + (1.37 lb/hourxl9 hours) = 33 lb/day SO Ammonia: (6.48 lb/hr. x 24 hours/day) 156 lb/day

=

Maximum Annual Emissions: Annual emissions for each (lEG are based on 4000 hours per year of operation. For pollutants for which emissions are higher during startup/shutdown periods, annual emissions are based on 3750 hr/yr at baseload operation, and 250 hr/yr at startup/shutdown operation. Table I is a summary of the hourly, daily and annual maximum regulated air pollutant emissions for all three gas turbines including startup and shutdown. Table 1 Maximum Hourly, Daily and Annual Regulated Air Pollutant Emissions for the SJERP Lb/hr 120 30 6.0 7.5 4.11 (a) includes startup/shutdown emissions Pollutant NO(asNO2) CO POC o 3 PM 2 SO Lb/day 850 396 101 180 99 Tons/yr 39.8 27.9 7.7 15 2.7(c)

(S) includes S hours day of startup/shutdown 2 (c) Annual SO emissioz are based on expected fuel sulfur content of 0.33 /l 00 scf

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Table 2 is a summary of the maximum TAC emissions from the project. These emissions are used as input data for air pollutant dispersion models used to assess the maximum increased health risk to the public resulting from the project. The ammonia emissions shown are based upon a wontcase ammonia emission concentration of 10 ppmvd @ 15% 02 due to ammonia slip from the A-I, A-2 and A-3 SCR systems. Table 2 Maximum Facility Toxic Air Contaminant (TAC) Emissions Toxic Air Contaminant Acetaldehy& Acrolein Ammoniac Benzeneb 1,3_Butadieneb Ethylbenzene Formaldehydeb Hexane Naphthalefie pMjsb Propylene Propylene Oxideb Toluene Xylenes
I

Maximum Facility Emissions lbs/year 234.6 21.2 78,480 19.1 2.5 187.5 2,110.3 1489.3 9.5 1 4,433.3 170.2 764.8 375.5
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Risk Screening Trigger Level,' lb/yr 72 3.9 1,930 6.7 1.1 19,300 33 8,300 270 0.043 N/A 52.0 3,860 57,900
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The SFERP does not trigger PS]) requirements. Table 3 is a summary of the annual regulated air pollutant emission limits for the facility and the PS]) trigger levels. Table 3 Annual Facility Regulated Air Pollutant Emissions Maximum PoUutant Cumulative Increase in Emissionsttb (tons/year) 39.8 27.9 7.7 15 2.7
only; does not mchde emissions from
COOImg to'c

PSD Trigget (tonsiyeax) 100 100 NA 100 100

) 2 Nitrogen Oxides (as NO Carbon Monoxide Precursor Organic Compounds ) 10 Particulate Matter (PM Sulfurflioxide
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d

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) 4 S0 2 The suifliric acid mist (H emissions will be less than the PSD threshold of 7 tons per year. all the sulfur were to be converted to sulfuric acid, the sulfuric acid mist emissions Even assuming would be less than 7 tons per year. The non-criteria pollutant analysis requirements of District Regulation 2-2-306 do not apply because SFERP is not a Major Facility, and the emissions of these pollutants (i.e., lead, asbestos, beryllium, mercury, fluorides, sulfuric acid mist, hydrogen sulfide, and total reduced sulfur and reduced sulfur compounds) will not exceed the specified emission thresholds. However, an URSA has been conducted for potential emissions of TACs. Regulation 2-2-3 08 requires applicants to demonstrate that emissions from a project located within 10 km of a PSD Class I area will not cause or contribute to exceed any national ambient air quality or any applicable Class I increment. Because the closest Class I area (it., the Point Reycs National Seashore) is more than 10 1cm from the SFERP, this requirement does not apply to the proposed facility.

ifi. Statement of Compliance
The fcsilowing section summarizes the applicable District rules and regulations and describes how the proposed SFEP.P will comply with those requirements. District Regulation 2, Rule 2: New Source Review The primary requirements of the District's New Source Review rule that apply to the proposed SFERP facility are Section 2-2-301, Best Available Control Technology Requirement, and Section 2-2-302, Offset Requirements, Precursor Organic Compounds and Nitrogen Oxides. A. District Regulation 2-2-301: BACT Determinations District Regulation 2-2-206, defines BACT as the more stringent of: (a) The most effective control device or technique which has been successfully utilized for the type of equipment comprising such a source; or (b) The most stringent emission limitation achieved by an emission control device or technique for the type of equipment comprising such a source; or (c) Any emission control device or technique determined to be technologically feasible and cost effectivebytheAPCO; or (d) The most effective emission control limitation for the type of equipment comprising such a source which the EPA states, prior to or during the public comment period, is contained in an approved implementation plan of any state, unless the applicant demonstrates to the satisfaction of the APCO that such limitations are not achievable. Under no circumstances shall the emission control required be less stringent than the emission control required by any applicable provision of federal, state or District laws, rules or regulations. 1. The type of BACT described in definitions (a) and (b) must have been demonstrated in practice and approved by a local Air Pollution Control District CARB, or the EPA and is refen'ed to as "BACT
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described in 2." This type of BACT is also tenned "achieved in practice." The BACT category definition (c) is referred to as "technologically feasible/cost-effective" and must have been demonstrated to be effective and reliable on a flail-scale unit and shown to be cost-effective on the s basis of dollars per ton of pollutant abated. This is referred to as "BACT 1." BACT specification feasible/cost-effective" categories have for both the "achieved in practice" and "technologically been compiled in the BAAQMD BACT Guideline for various source categories. Nitrogen Oxides (NO,) The District's BACT Guideline Section 29.1.3 for Gas Turbine Simple Cycle greater than 40 Megawatts Heat Input (dated 7/18/03) specifies BACT1 (Technologically Feasible/Cost Effective) use of 5CR for NO, is 2.5 ppmvd NO, @ 15% 02. This BACT determination was based upon the and water injection (as applied in the most recent Application #5412, issued 10/15/2002) or a has SCONOx System. The EPA has accepted this BACT determination as Fedei-aj LA3R. CARB Power Plant Siting and Best also cited these levels as BACT in its document "Guidance for Available Control Technology," June 1999. 5CR lowers NO, emissions by using a reducing agent (ammonia or urea) to reduce NO, molecules of a to elemental nitrogen and water. The ammonia is injected into the flue gas stream upstream catalyst, which is used to reduce the required temperature for NO, reduction to less than 800°F. many SCR has been widely and successfully used in combustion turbine and boiler applications for years. The District is unaware of any simple cycle turbine system, in the size range being proposed here, that has consistently achieved a lower NOx level than 2.5 ppmvd @15% 02. Thus the District does not consider a lower NOx control level to be technically feasible for the purposes of a top-down BACT analysis. Environmental Impacts The use of SCR will result in ammonia emissions due to an allowable ammonia slip limit of 10 ppmvd @ 15 % 02. An HRSA using air dispersion modeling showed a chronic hazard index of 0.001 resulting from the ammonia slip emissions for three turbines. Tn accordance with the District's Toxic Risk Management Policy and cunently accepted practice, a hazard index less than 1.0 is not considered significant. Therefore, the toxic impact of the ammonia slip resulting from the use of SCR is deemed to be not significant and is not a sufficient reason to eliminate 5CR as a control alternative. al The ammonia emissions resulting from the use of SCR may have another environment impact matter emissions, such as arnmonium nitrate. through potential formation of secondary particulate Because of the complex nature of the chemical reactions and dynamics involved in the formation of secondary particulates, it is difficult to estimate the amount of secondary particulate matter that will be formed from the emission of a given amount of ammonia. However, the District believes that the formation of animonium nitrate in the Bay Area air basin is limited by the formation of nitric acid and not driven by the amount of ammonia in the atmosphere. Therefore, ammonia emissions to the formation of from the proposed SCR system are not expected to contribute significantly considered significant secondary particulate matter. This potential envixorimentai impact is not enough to justify the elimination of SCR as a control alternative.
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involves the storage and tratisport of One other potential environmental impact from the use of SCR and can initate or burn the skin, ammonia. Although ammonia is toxic if swallowed or inhaled ly handled safely and without eyes, nose, or throat, it is a commonly used material that is typical Management Plan (RMP) and incident. The SFERP facility will be required to maintain a Risk ntal releases. The RMP provides implement a Risk Management Program to prevent accide and the programs in place to infonnation on the hazards of the substances handled at the facility tion and emergency response prevent and respond to accidental releases. The accident preven y safety codes and standards. In requirements reflect existing safety regulations and sound industr catastrophic release of aqueous addition, the CEC has modeled the health impacts arising from a SPERP and found that the impact ammonia due to spontaneous storage tank failure at the proposed impact due to aqueous ammonia would not be significant. Therefore, the potential environmental 5CR as a control alternative. storage at the SFERP facility does not justi the elimination of Conclusion tration limit of 2.5 ppmvd NO Each combustion gas turbine will meet a N0 emission concen ng modes except gas turbine start-ups 15% 02, averaged over a one hour period, during all operati emission limitation through the use and shutdowns. The applicant has proposed to comply with this iance will be verified by a Cat of water injection and SCR with ammonia injection. Compl cause significant energy, economic, or located in the stack for each gas turbine. SCR will not meet the Distiict's BACT standard envirmiental impacts. The applicant's proposed use of 5CR to for NO is therefore acceptable. Carbon Monoxide (CO) operating range from mmmium to BACT for CO will be analyzed over the turbines' entire temperature thereby allowing an maximum load. Water injection lowers the combustor flame flame temperature steam or water increased fuel use rate. However, lowering the combustor injection can increaseCO production. Simple Cycle for greater than 40 The District's BACT Guideline Section 89.1.3 for Gas Turbine 15% Oz with an averaging period Megawatts Heat Input (dated 7/18/03) specifies 6 ppmvd CO. @ t Effective). This BACT determination of three hours as BACT1 (Technologically Feasible/Cos also cited these levels as was based upon the use of CO Catalyst and water injection. CARB has Best Available Control Technology," June BACT in their "Guidance for Power Plant Siting and 1999. CO @15% 02, averaged over three The District has permitted at least five facilities at 4.0 ppmvd ce Document, two consecutive years of hours. Per the June 1999 CARE Power Plant Siting Guidan 0.16 to 0.62 ppmvd CO @15% 02. source testing indicate CO emission concentrations vary from than 1.5 ppm CO @15% 02. The The District's source test results have measured emissions of less conclude that a CO emissions level at District therefore believes there is sufficient justification to limit will apply during all operating 4.0 ppmdv@l 5% 02 has been achieved in practice. The CO applies to the exhaust from the gas modes except for gas turbine start-up and shutdown. This limit turbine.

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pmvd @ 15% C), that will apply to all The SEER? has agreed to meet a CO emission limit of 4.0 stan-up and shutdown. The SFERP will gas turbines operating modes except for gas turbine oxidation catalysts. comply with this BACT specification though the use of Precursor Organic Compounds (POCs) Turbine Simple Cycle for greater than 40 The District's BACT Guideline Section 89.1.3 for Gas 15% 0, with an averaging period Megawatts Heat Input (dated 7/18/03) specifies 2 ppmvd POC based upon the use of an Oxidation Catalyst of one hour as BACT. This BACT determination was BAAQMI) permits issued for power plants. or Dry Low NO combustors and is based on recent "Guidance for Power Plant Siting and Best CARB has also cited these levels as BACT in their has proposed to meet this POC stack Available Control Technology," June 1999. The applicant concentration of 2 ppmvd @ 15% 02. ) 2 Sulfur Dioxide (SO e Simple Cycle for greater than 40 The District's BACT Guideline Section 89.1.3 for Gas Turbin of PUC-regulated natural gas as Megawatts Heat Input (dated 7/18/03) specifies the exclusive use PUC natural gas exclusively, which BACT for SO, emissions. The proposed turbines will utilize the sulfur content of the natural gas will be will result in minimal SO, emissions. Accordingly, e concsponds to an SC), emission factor limited by permit condition to 1 grain/100 scf. This averag cation oft grain per 100 scf is deemed of 0.0028 lb./MMBtu. The natural gas sulfur content specifi for SO,. ) 30 Particulate Matter (PM e Simple Cycle for greater than 40 The District's BACT Guideline Section 89.1.3 for Gas Turbin ive use of PUC-regulated natural gas as Megawatts Heat Input (dated 7/18/03) specifies the exclus burners will utilize PUC natural gas 10 BACT for PM emissions. The proposed turbines and duct 10 emissions and minimal formation of exclusively, which will result in mixuirnal direct PM content of the natural gas will be limited 10 secondary PM such as sulfates. Accordingly, the sulfur by pennit condition to I grainJloo scf. low. The District has, in the past, utilized PM emissions from gas-fired gas turbines are inherently Best Available Control Technology for the BACT definition in Section 2-2-206.1 to determine that ted grade natural gas" to minimize fbel PM for gas turbines was "exclusive use of CPUC-regula turbines. Unlike NOx and CO contaminant and sulfate contributions to PM emissions from gas y be reduced using combustion feasibl emissions, PM emissions from gas turbines cannot on control technology. modifications or add-on emissi limitation of 2.5 lb/hr. and the emission An identical turbine at Los Esteros has an emission SFER.P turbines will be used less limitation has been consistently achieved. Although the a greater fraction of its operation frequently than the Los Esteros turbines, and will spend ined that the Los Esteros turbines are the transitioning between load levels, the District has determ lb/hr is more stringent than the 3.0 lb/hr same type of equipment. The Los Esteros limitation of 2.5 . originally proposed for SFERP, and therefore comprises BACT for PM. The applicant has agreed to accept a limitation of 2.5 lb/hr

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put. For air chilling is necessary to maintain turbine out cooling tower will operate when inlet The hours per year. assumed to operate 24 hours per day, 8760 this evaluation, the cooling tower is ssions from with a drift rate of 0.0010%. Maximum emi RP is proposing a cooling tower SFE olved solids of imum drift rate and maximum total diss cooling tower are calculated from the max nds per hour and ing towers will emit a maximum of 0.04 pou the make-up water. The two-cell cool less than 10 pounds maximum emissions from the tower are . 10 0.2 tons per year of PM Since the ments and is tower is exempt from District permit require day and S tons per year, the cooling per requirements. not subject to either BACT or offset Cooling Tower Emissions Data 0.0010% Drift rate: 3912 gpm WaterFlow: 19.55 Drift, ibm water/hr: 2000 TDS level, ppm: Results: 0.04 lb/hr and 0.17 tons/year 10 PM Emission 2. 1 Requirements, POCs and NO District Regulation 2-2-302: Offset General Requirements facility that will be that for new or modified sources at a District Regulation 2-2-302 requires basis, the total POCs or NO or more on a pollutant specific pennitted to emit 35 tons per year of issued a `request for proposals to emission sions must be offset. The applicant project emis uirements for this obtain sufficient ERCs to meet the oaet req It reduction credit (ERC) holders to offsets locally within the San Francisco area. The applicant has committed to obtain project do not require 1 POC and NO offsets, District regulations should be noted that in the case of emission reduction credits relative to the location tion of the location of the source of the considera of the proposed emission increases. Timing for Provision of Offsets d valid emission 11, the applicant must provide the require Pursuant to District Regulation 2-2-3 for the facility prior to the issuance of the credits to mitigate the emission increases reduction ts, the Authority to to District Regulation 2, Rule 3: Power Plan Authority to Construct. Pursuant issues their Certificate for the power plant. Construct will be issued after the CEC Offset Requirements by Pollutant POC and enforceable emission ofiets are required for Pursuant to Regulation 2-2-3 02, federally s per year or more ton mitted sources at facilities, that will emit 10 1 NO emission increases from per emit greater than 35 tons per year of ause the SFERP facility will on a pollutant-specific basis. Bec R.P will emit offset at a ratio of 1.15 to 1.0. Since the SFE 1 the project NO emissions must be , 1 NO ssion offsets. applicant is not required to provide POC emi less than 10 tons/year of POC, the re sources are less than 100 tons per year, therefo 10 ed PM emissions from the proposed The project 10 PM offets are t requirement of Regulation 2-2-303 and no 10 RP does not trigger the PM offse SFE reduction credits are not required for the Pursuant to Regulation 2-2-303, emission required. 2 emissions will ciated with this project since the facility SO proposed SOz emission increases asso allows a facility that emits less than 100 tons of 100 tons per year. Regulation 2-2-303 not exceed FOOC
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. The applicant will provide mitigation fbr these pollutants to voJuntariJy provide emission offsets required by the CEC. 5 . 2 19 PM and PM emissions from the project as Interpollutant Offset Ratios 2.2, the applicant has the option to substitute Pursuant to District Regulations 2-2-302 and 2-2-30 ed emissions of NO at a ratio of 1.0 to 1.0. ERCs for precursor organic compounds to offset increas Current Proposed Offset Package of the SFERP and the quantity of valid emission Table 5 summarizes the current offset obligation reduction credits (ERCs) that are required. valid emission reduction credits to offset the The applicant has committed to secure sufficient proposed for the SFERP. In March 2005, the emission increases from the permitted sources purchase of ERCs represented by Certificate No. applicant has signed an option agreement for the reduction achieved at the nearby Mirant Point 896 which were created through NOx emissions of NOx ERCs will be provided. POC offsets power plant. The table below shows that 47.5 tons the trigger levels for offsets under District are not required because POC emissions do not exceed regulations. Table 4 y Offset Requirements Facilit

Health Risk Screening Analysis B. ure, a Health Risk Screening Analysis must be Pursuant to the BAAQMD Risk Evaluation Proced health resulting from the emissions of TACs prepared to determine the potential impact on public (both carcinogenic and non-carcinogenic) from the from the SFERP. The potential TAC emissions In accordance with the requirements of the SPERP were previously summarized in Table 2. public health due to the emission of these BAAQMI) Risk Evaluation Procedure, the impact on ion models. The results are summarized in cothpounds was assessed utilizing air pollutant dispers Table 6. Table 5 Health Risk Screening Analysis Results Multi-pathway Non-carcinogenic Carcinogenic Risk Chronic Hazard Index (Risk in One Million) Source a 0.001 0.01 Gas Turbines 0.00002 0.004 Cooling Tower numbers represent combined risk from all sources `

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The health risk assessment performed by the applicant has been reviewed by the District's Toxies EvaJuation Section and found to be in accordance with guidelines adopted by Cal/EPA's Office of Environmental Health Hazard Assessment (OEHHA), the California Air Resources Board (CARE), and the California Air Pollution Control Officers Association (CAPCOA). Pursuant to the BAAQMD Risk Management Policy, the increased carcinogenic risk attributed to this project is considered to be not significant because it is less than 1.0 in one million. The chronic hazard index attributed to the emission of non-carcinogenic air contaminants is considered to be not significant because it is less than 1.0. Therefore, the SFERP facility is deemed to be in compliance with the BAAQMD Toxic Risk Management Policy. C. Other Applicable District Rules and Regulations

Regulation 1, Section 301: Public Nuisance This project is not expected to cause injury, detriment, nuisance or annoyance to any considerable number of persons or the public with respect to any impacts resulting from the emission of air contaminants regulated by the District. Air contaminants from this proposed power plant are highly unlikely to cause a public health nuisance and annoyance to the neighboring community. It is also unlikely to contribute significantly to injury from air contaminants. The plant will not contribute significantly to ozone, carbon monoxide (CO), and particulate matter (PM and PM levels in the air. 10 ) 2 Regulation 2, Rule 1, Sections 301 and 302: Authority to Construct and Permit to Operate pursuant to District Regulation 2-1-301 and 2-1-302, the SF.ER.P has submitted an application to the District to obtain an Authority to Construct and Permit to Operate for the proposed S-i, 5-2 & S-3 Gas Turbines. Because the proposed cooling tower will not be used for the evaporative cooling of process water, it is exempt from District permit requirements (Regulations 2-1-301 and 2-1-302) pursuant to Regulation 2, Rule 1, Section 128.4. The wont-case emission projections indicate that the cooling tower will not emit air contaminants at rates above the risk management screening trigger levels as specified in Table 2-1-3 16 of Regulation 2, Rule 1. The applicant has also demonstrated that the cooling tower emissions have passed an HRSA in accordance with the District Risk Evaluation Procedure. Therefore, the cooling tower remains exempt from District permit requirements per Regulation 2-1-3 16. Regulation 2, Rule 3: Power Plants Pursuant to Regulation 2-3403, this FDOC serves as the APCO's preliminary decision that the proposed power plant will meet the requirements of all applicable BAAQMD, state, and federal regulations. The FDOC contains proposed permit conditions to ensure compliance with those regulations. Pursuant to Regulation 2-3-304, the PDOC was subject to the public notice, public comment, and public inspection requirements contained in Regulations 2-2-406 and 407. Regulation 2, Rule 6: Major Facility Review Pursuant to Regulation 2, Rule 6, Section 404.1, the owner/operator of the SFERP must submit an application to the BAAQMD for a major facility review permit within 12 months after the facility
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becomes subject to Regulation 2, Rule 6. Pursuant to Regulation 2-6-212.1, the SFERP will become subject to Regulation 2, Rule 6 upon initial firing of any of the gas turbines (S-I, 5-2, or 53). However, because the Acid Rain requirements are also contained in the MFR pennit, the application must be submitted much earlier (see below). Regulation 2, Rule 7: Acid Rain The SFERP gas turbine units will be subject to the requirements of Title lv of the federal Clean Air Act. The requirements of the Acid Rain Program are outlined in 40 CFR Part 72. The specifications for the type and operation of continuous emission monitors (CEMs) for pollutants that contribute to the fomiation of acid rain are given in 40 CFR Part 75. District Regulation 2, Rule 7 incorporates by reference the provisions of 40 CFR Part 72. Pursuant to 40 CFR Part 72.30(b)(2Xii), SFERP must submit an Acid Rain Permit Application to the District at least 24 months prior to the date on which each unit commences operation. Pmsuant to 40 CFR Part 72.2, "commence operation" includes the start-up of the unit's combustion chamber. The applicant filed an Acid Rain permit application for the project on August 23, 2005. SFERP cannot operate either of the gas turbines until either; 1) a Title IV Operating Permit has been issued; or 2) 24 months after the Tide IV Operating Permit application has been submitted to the District, whichever is earlier. Regulation 6: Particulate Matter and Visible Emissions Through the use of low-NOr burner technology and proper combustion practices, the combustion of natural gas at the proposed gas turbines is not expected to result in visible emissions. Specifically, the faciliWs combustion sources are expected to comply with Regulation 6, including Sections 301 (Ringelmann No. 1 Limitation), 302 (Opacity Limitation) with visible emissions not to exceed 20% opacity, and 310 (Particulate Weight Limitation) with particulate matter emissions of less than 0.15 gains per dry standard cubic foot of exhaust gas volume. As calculated in accordance with Regulation 6-310.3, the grain loading resulting from the simultaneous operation of each power train is 0.0025 gr/dscf 6% 02. With maximum total dissolved solids content of 2000 mg/l, flow rate and corresponding maximum 1 PMio emission rate of 0.04 lb/hr the proposed 2-cell cooling towers are also expected to comply with the requirements of Regulation 6. Particulate matter emissions associated with the construction of the facility are exempt from District permit requirements but are subject to Regulation 6. It is expected that the Calithmia Energy Commission will consider conditions on construction activities, and may require the use of 10 water and/or chemical dust suppressants to minimize PM emissions and prevent visible particulate emissions. Regulation 7: Odorous Substances Regulation 7-302 prohibits the discharge of odorous substances, which remain odorous beyond the facility property line after dilution with four parts odor-free air. Regulation 7-302 limits ammonia emissions to 5000 ppm. Since the ammonia emissions from the three proposed CTG power trains 15% 02, the applicant is expected to will each be limited by permit condition to 10 ppmvd comply with the requirements of Regulation 7.

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Regulation 8: Organic Compounds This facility is exempt from Regulation 8, Rule 2, "Miscellaneous Operations" per Regulation 8-2110, since natural gas will be fired exclusively at the SFERP. The use of solvents for cleaning and maintenance at the SFERP is expected to comply with Regulation 8, Rule 4, "General Solvent and Surface Coating Operations" Section 302.1 by emitting less than 5 tons per year of volatile organic compounds. Regulation 9, Rule 1: Inorganic Gaseous Pollutants, Sulfur Dioxide This regulation establishes emission limits for sulfur dioxide from all sources and applies to the combustion sources at this facility. Section 301: Limitations on Ground Level Concentrations, prohibits emissions that would result in ground level 502 concentrations in excess of 0.5 ppm continuously for 3 consecutive minutes, 0.25 ppm averaged over 60 consecutive minutes, or 0.05 2 ppm averaged over 24 hours. Section 302: General Emission Limitations, prohibits SO emissions 300 ppmv (dry). With maximum projected 502 emissions of less than 1 ppmv, the gas in excess of turbines are not expected to exceed the ground level 502 concentration limit in Section 301 and easily complies with Section 302. Regulation 9, Rule 3: Inorganic Gaseous Pollutants, Nitrogen Oxides from Heat Transfer Operations The proposed combustion gas turbines (each rated at 487.3 MM Btulhr, HHV) will comply with the Regulation 9-3-303 N0 limit of 125 ppm by complying with a permit condition nitrogen oxide emission limit of 2.5 ppmvd @ 15% 02. Regulation 9, Rule 9: Inorganic Gaseous Pollutants, Nitrogen Oxides from Stationary Gas Turbines Because each of the proposed combustion gas turbines will be limited by permit conditions to N0 emissions of 2.5 ppmvd @ 15% 02, they are expected to comply with the Regulation 9-9-301.3 N0 limitation of 9 ppmvd @ 15% 02. In addition, the continuous emission monitoring (CEM) system will be installed to satisfy the monitoring and recordkeeping requirements of this rule. Regulation 10: 40 CFR 60, Subpart GG- Standards of Performance for Stationary Gas Turbines Regulation 10(40 (YR 60, Subpart GO) was adopted by reference from the federal New Source Performance Standards (NSPS) for stationary gas turbines. This regulation requires monitoring of fuel; imposes limits on the emissions of N0, SOz, and PM; requires source testing of the stack emissions; process monitoring and data collection and recordkeeping. All of the BACT limits imposed on the combustion turbines are more stringent than the requirements of the NSPS emissions limits. The SFBRP will comply with the NSPS. New gas turbines may be subject to, and if subject, would be in compliance with, the proposed new Subpart K.K.KK when it is finalized by EPA. If Subpart KKKK is ultimately adopted and is determined to be applicable to the proposed SFERP gas turbines, Subpart GO would not apply.

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40 CFR 63, Subpart YYYY-National Emissions Standards for Hazardous Air Pollutants for Stationary Combustion Turbines. 40 CFR 63, Subpart YYYY for hazardous air pollutant emissions requires that a facility emitting more than 10 tons per year of single HAP or more than 25 tons per year for any combination of HAPs will be subject to this requirement. Since, this facility will not emit more than 10 tons for single HAP or 25 tons for any combination, it is not subject to 40 CFR Part 63, Subpart YYYY. D. CEQA

The CEQA requirements of Districts Regulation 2-1-426 are met since the CEC is the lead agency on this project. The CEC is thus responsible for conducting the CEQA review and preparing the CEQA document for this project. The CEC's final certification and licensure will serve as the ER equivalent pursuant to the CEC's certified regulatory program (as specified in CEQA Guidelines Section 15253(b) and Public Resources Code Sections 21080.5 and 25523).

IV. Permit Conditions
The following permit conditions will be imposed to assure that the proposed project complies with all applicable District, State, and Federal regulations. The conditions limit operating parameters such as fuel use, stack gas emission concentrations, and mass emission rates. Permit conditions will also specify abatement device operation and performance levels. To aid enforcement efforts, conditions specffing emission monitoring, source testin& and record keeping requirements are included. Furthermore, pollutant mass emission limits (in units of lb/hr and Ib/MMBtu of natural gas fired) will ensure that daily and annual emission rate limitations are not exceeded. Compliance with CO and NO limits will be verified by continuous emission monitors (CEMs) that will be in operation during all turbine operating modes, including start-up and shutdowm If the CO and NOx CEMs are not capable of accurately assessing gas turbine start-up and shutdown mass emission rates due to variable gas content and the differing response times of the gas monitors, then start-up and shutdown mass emission rates will be based upon annual source test results. , 2 10 Compliance with POC, SO and PM mass emission limits will be verified by annual source testing. In addition to permit conditions that apply to the designed operation of each CTG power train, conditions will be imposed that govern equipment operation during the initial commissioning period when the CTGs will operate without their 5CR systems and oxidation catalysts fully operational. During this commissioning period, the gas turbines will be tested, control systems will be adjusted, and ducts leading to the stack tubes will be cleaned. Permit Conditions I through 12 apply to this commissioning period and are intended to minimize emissions and insure that those emissions will not contribute to the exceedence of any short-term applicable ambient air quality standard.

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San Francisco Electric Reliability Project Permit Conditions Definitions: Any continuous 60-minute period beginning on the hour. Any continuous 24-hour period beginning at 12:00 AM or 0000 hours. Any consecutive twelve-month period of time All heat inputs refer to the heat input at the higher heating value Heat Input: (NHV) of the fuel, in Btu/scf. Any three-hour period that begins on the hour atd does not include Rolling 3-hour period: start-up or shutdown periods. Period of time during which fuel is flowing to a unit, measured in Firing Hours: fifteen-minute increments. million British thennal units MM Btu: The lesser of the first 120 minutes of continuous fuel flow to the Gas Gas Turbine Start-up Mode: Turbine after fuel flow is initiated or the period of time from Gas Turbine fuel flow initiation until the Gas Twbine achieves two consecutive CEM data points in compliance with the emission concentration limits of conditions 18(b) and 18(d). Turbine Shutdown Mode: The lesser of the 30 minute period immediately prior to the Gas termination of fuel flow to the Gas Turbine or the period of time from non-compliance with any requirement listed in Conditions 18(b) through 18(d) until termination of fbel flow to the Gas Turbine. The polycycic aromatic hydrocarbons listed below shall be Specified PAHs: considered to Specified PAHs for these permit conditions. Any emission limits for Specified PANs refer to the sum of the emissions for all six of the following compounds. Benzo{aJantbracene Benzo[b]fluoranthene Benzo[k)fluoranthene Benzo[a]pyrene Dibenzo[a,hjanthracene Jndenol 1 ,2,3-cd]pyrene The concentration of any pollutant (generally NOR, CO. or NH Concentration: ) 3 Corrected corrected to a standard stack gas oxygen concentration. For emission point P-i (exhaust stack of S-i Gas Turbine), emission point P-2 (exhaust stack of S-2 Gas Turbine) and P-3 (exhaust stack of S-3 Gas Turbine) the standard stack gas oxygen concentration is 15% 02 by volume on a thy basis. All testing, adjustment, tuning, and calibration activities Activities: Commissioning recommended by the equipment manufacturers and the SFERP construction contractor to insure safe and reliable steady state operation of the gas turbines, heat recovery steam generators, steam turbine, and associated electrical delivery systems. Clock Hour Calendar Day.
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Commissioning Period:

The Period shall commence when all mechanical, electrical, and control systems are installed and individual system start-up has been completed, or when a gas turbine is first fired, whichever occurs first. The period shall terminate when the plant has completed performance testing, is available for commercial operation, and has initiated sales to the power exchange.
My compound of carbon, excluding methane, ethane, carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate California Energy Commission Compliance Program Manager San Francisco Electric Reliability Project Not Federally Enforceable

Precursor Organic Compounds (POCs):

CEC CPM: SFERP:
*

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Conditions for the Commissioning Period The owner/operator of the SFERP shall minimize emissions of carbon monoxide and nitrogen oxides from S-i, 5-2, and 5-3, Gas Turbine Combustors to the max mum extent possible during the commissioning period. Parts 1 through 11 will only apply during the commissioning period as defined above. Unless otherwise indicated, Parts 13 through 42 will apply after the commissioning period has ended. 2. At the earliest feasible opportunity, in accordance with the recommendations of the equipment manufacturers and the construction contractor, the owner/operator shall ensure that S-i, 5-2, and 5-3, Gas Turbine Combustors are tuned to minimize the emissions ofcarton monoxide and nitrogen oxides. At the earliest feasible opportunity, in accordance with the recommendations of the equipment manufacturers and the construction contractor, the own a/operator shall install, adjusl and operate A-i through A-6, SCR and Oxidation Systems, to minimize the emissions of carton monoxide and nitrogen oxides from S-i, S-2, and 5-3, Gas Turbine Combustors. Coincident with the as-designed operation of A-i thru 46, SCR and Oxidation Systems, pursuant to Parts 3, 8, 9 and 10 of this condition, the owner/operator shall ensure that the Gas Turbine Combustors (5-i, 5-2, and 5-3) comply with the NO and CO emission limitations specified in Parts 18(a) through 18(d) of this condition. The owner/operator of the SFERP shall prepare a plan describing the procedures to be followed during the commissioning of the gas turbines. The plan shall be submitted the District Engineering Division and the CEC CPM at least four weeks prior to first firing of S-i, 5-2, or 5-3, Gas Turbine Coinbustom. The plan shall include a description of each commissioning activity, the anticipated duration of each activity in hours, and the purpose of the activity. The activities described shall include, but not be limited to, the tuning of the Water Injection system, the installation and operation of the 5CR systems and oxidation catalysts, the installation, calibration, and testing of the CO and NO continuous emission monitors, and any activities requiting the firing of the Gas Turbine Combustors (S-i, 5-2, and S-3) without abatement by their respective SCR and Oxidation Systems. No Gas Turbine Combustor (S-i, S-2, or 5-3) shall be fired sooner than 28 days after the District receives the commissioning plan. During the commissioning period, the owner/operator of the SFERP shall demonstrate compliance with Parts 8 through ii of this condition through the use of properly operated and maintained continuous emission monitors and data recorders for the following parameters: firing hours for each gas turbine (S-I, S-2, and S-3) fuel flow rates to each train stack gas nitrogen oxide emission concentrations at P-i, P-2, and P-3 stack gas carbon monoxide emission concentrations P-l, P-2, and P-3 stack gas oxygen or carbon dioxide concentrations P-i, P-2, and P-3 The owner/operator shall monitor the parameters and record at least once every 15 minutes (excluding normal calibration periods or when the monitor source is not in operation) for the Gas
21

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Turbine Combustors (5-1, 5-2, and 5-3). The owner/operator shall use District-approved ) 2 methods to calculate heat input rates, NO,, (as NO mass emission rates, carbon monoxide ma and NO,, and CO emission concentrations, summarized for each clock hour and emission rates, each calendar day. All records shall be retained on site for at least 5 years from the date of entry and made available to District personnel upon request. 7. The owner/operator shall install, calibrate, and properly operate District-approved continuous emission monitors specified in Part 6 prior to the first firing of the Gas Turbine Combustors (51, 5-2, and S-3). After first firing of the turbines, the detection range of these continuous emission monitors must be adjusted as necessary to accurately measure the resulting range of CO and NO,, emission concentrations. The type, specifications, and location of these monitors shall be subject to District review and approval (by the District's Source Test Section). The owner/operator shall not exceed 100 hours of firing during the commissioning period of 51, Gas Turbine Combustor without abatement of nitrogen oxide emissions by A-I, 5CR System. Such operation of S-i, Gas Turbine Combustor without abatement shall be limited to discrete commissioning activities that can only be properly executed without the SCR or Oxidation Catalyst Systems filly operational. Upon completion of these activities, the owner/operator shall pm'ide written notice to the District's Engineering and Enforcement Divisions, and the unused balance of the 100 firing hours without abatement shall expire. The owner/operator shall not exceed 100 hours of firing during the commissioning period of 52, Gas Turbine Combustor without abatement of nitrogen oxide emissions by A-3, 3CR System. Such operation of S-2, Gas Turbine Combustor without abatement shall be limited to discrete commissioning activities that can only be properly executed without the 5CR or Oxidation Catalyst Systems fhlly operational. Upon completion of these activities, the owner/operator shall provide written notice to the District's Engineering and Enforcement Divisions, and the unused balance of the 100 firing hours without abatement shall expire. The owner/operator shall not exceed 100 hours of firing during the commissioning period of 53, Gas Turbine Combustor without abatement of nitrogen oxide emissions by A-5, 5CR System. Such operation of 5-3, Gas Turbine Combustor without abatement shall be limited to discrete commissioning activities that can only be properly executed without the 5CR or Oxidation Catalyst Systems fully operational. Upon completion of these activities, the owner/operator shall provide written notice to the District Engineering and Enforcement Divisions, and the unused balance of the 100 firing hours without abatement shall expire. The owner/operator shall calculate the total mass emissions of nitrogen oxides, carbon , 10 monoxide, precursor organic compounds, PM and sulfhr dioxide that are emitted by each Gas Combustor (5-1, S-2, and S-3) during the commissioning period. These emissions Turbine count towards the consecutive twelve-month emission limitations specified in Part 21 of this condition.

8.

9.

10.

11.

12. Prior to the end of the Commissioning Period, the owner/operator shall conduct a District- and CEC-approved source test using external continuous emission monitors to determine compliance with Part 18 of this condition. The source test shall detennine NO,,, CO. and POC emissions
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during start-up and shutdown of the gas turbines. The POC emissions shall be analyzed for methane and ethane to account for the presence of unburned natural gas. The source test shall include a minimum of three start-up and three shutdown periods. No later than twenty working days before the execution of the source tests, the owner/operator shall submit to the District and the CEC Compliance Program Manager (CPM) a detailed source test plan designed to satisfy the requirements of this condition. The District and the CEC CPM will notify the owner/operator of any necessary modifications to the plan within 20 working days of receipt of the plan; otherwise, the plan shall be deemed approved. The owner/operator shall incorporate the District and CEC CPM comments into the test plan. The owner/operator shall notify the District and the CEC CPM within seven (7) working days prior to the planned source testing date. Source test results shall be submitted to the District and the CRC CPM within 30 days of the source testing date.

Conditions for the Gas Turbine Combustors (S-I, 5-2, and S-3) 13. The owner/operator shall ensure that S-i, 5-2 and 5-3, gas turbine combustors are fired on PUC ) 10 2 natural gas exclusively. (Basis: BACT for SO and PM The owneiioperator shall ensure that heat input rate to each Gas Turbine Combustor (S-i, S-2, or S-3) does not exceed 487.3 MM Btu per hour, averaged over one hour period. (Basis: 2-1-234) Except during the commissioning period, the owner/operator of S-I, Gas Turbine Combustor shall properly operate and properly maintain A-i, Selective Catalytic Reduction (SCR) and A-2, Oxidation Catalyst Systems whenever fuel is combusted at the source and the A-I catalyst bed has reached minimum operating temperature. (Basis: BACT for NO and CO) Except during the coniniissioning period, the owner/operator of 5-2, Gas Turbine Combustor shall properly operate and properly maintain A-3, Selective Catalytic Reduction (5CR) and A-4, Oxidation Catalyst Systems whenever thel is combusted at those sources and the A-3 catalyst bed has reached minimum operating temperature. (Basis: BACT for NO and CO) Except during the commissioning period, the owner/operator of 5-3, Gas Turbine Combustor shall properly operate and properly maintain A-5, Selective Catalytic Reduction (5CR) and A-6, Oxidation Catalyst Systems whenever fhel is combusted at the source and the A-5 catalyst bed has reached minitnuin operating temperature. (Basis: BACK for NO and CC)) The owner/operator of the Gas Turbine Combustors (S-I, S-2, and S-3) shall comply with requirements (a) through (h) below under all operating scenarios, except requirements (a) though (h) do not apply during a gas turbine start-up or shutdown. (Basis: BACT and Toxic Risk Management Policy) (a) Nitrogen oxide mass emissions (calculated in accordance with District-approved methods) at each P-i, P-2, and P-3 (the exhaust point for each