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5.1C:EVALUATION OF BEST AVAILABLE CONTROL TECHNOLOGY <br /> capacity; or (2) in a manner that is typical of the equipment in order to provide an <br /> expectation of continued reliability of the control technology. <br /> • Effectiveness: The control technology must be verified to perform effectively over the <br /> range of operation expected for that type of equipment. If the control technology will be <br /> allowed to operate at lesser effectiveness during certain modes of operation, then those <br /> modes of operation must be identified. The verification shall be based on a performance <br /> test or tests,when possible, or other performance data. <br /> Each of these criteria is discussed separately below for SCR and for EMx. <br /> SCR Technology-SCR has been achieved in practice at numerous combustion turbine <br /> installations throughout the world. There are several utility-scale combined cycle projects <br /> that limit NOx emissions to 2.0 ppm,including the Mountainview Power Plant in San <br /> Bernardino County;the Inland Empire Energy Center in Riverside County; and the <br /> Cosumnes Power Plant in Sacramento County. An evaluation of the proposed AIP criteria <br /> as applied to the achievement of extremely low NOx levels (2.0 ppm and lower) using SCR <br /> technology is summarized below. <br /> • Commercial Availability: SCR technology is available with standard commercial <br /> guarantees for NOx levels at least as low as 2 ppm. Consequently, this criterion is <br /> satisfied. <br /> • Reliability: SCR technology has been shown to be capable of achieving NOx levels <br /> consistent with a 2.0 ppm permit limit during extended,routine operations at several <br /> commercial power plants. There are no reported adverse effects of operation of the SCR <br /> system at these levels on overall plant operation or reliability. <br /> • Effectiveness: SCR technology has been demonstrated to achieve NOx levels of 2.0 ppm <br /> and less. Short-term excursions have resulted in NOx concentrations above the <br /> permitted level of 2.0 ppm;however,these excursions have not been associated with <br /> diminished effectiveness of the SCR system. Rather,these excursions have been <br /> associated with SCR inlet NOx levels in excess of those for which the SCR system was <br /> designed. <br /> • Conclusion: SCR technology capable of achieving NOx levels of 2.0 ppm is considered <br /> to be achieved in practice. The proposed permit limits for the proposed Lodi Energy <br /> Center CTG/HRSG include a NOx limit of 2.0 ppm. This proposed limit is consistent <br /> with the available data. <br /> EMx Technology-EMx has been demonstrated in service in five applications: the Sunlaw <br /> Federal cogeneration plant,the Wyeth BioPharma cogeneration facility,the Montefiore <br /> Medical Center cogeneration,the University of California San Diego facility, and the <br /> Redding Power Plant. The combustion turbines at these facilities are much smaller than for <br /> the proposed LEC turbine. The largest installation of the EMx system is at the Redding <br /> Power Plant. The Redding Power Plant currently consists of a single combined cycle <br /> 43 MWe Alstom GTX100 combustion turbine with a permitted NOx emission rate of 2.5 <br /> ppm. There is a second 43 MWe unit under construction at the Redding Power Plant,but <br /> that unit has not begun operation. <br /> SAC/371322/082330016(LEC_5.1 C_APPENDIX.DOC) 5.1C 5 <br />