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5.1C:EVALUATION OF BEST AVAILABLE CONTROL TECHNOLOGY <br /> A summary of recent VOC BACT determinations for large,combined-cycle gas turbines is <br /> shown in Table 5.1C-3. Similar facilities using oxidation catalysts have been permitted at <br /> between 1.4 and 2.0 ppm VOC. Although several facilities are shown as having been <br /> permitted below these levels,compliance with these 1.0 ppm limits has not been achieved in <br /> practice because neither the Blythe II nor the Turner plants has been constructed or <br /> operated. Further,the Crescent City limit of 1.1 ppm is not comparable to the limits imposed <br /> for the other plants cited because it is an annual average limit and not a short-term limit. <br /> 5.1C.1.3.1.1 Conclusions <br /> BACT must be at least as stringent as the most stringent achieved in practice,required in a <br /> federal NSPS or district prohibitory rule, or considered technologically feasible. Based upon <br /> the results of this analysis,the VOC emission limits of 1.4 and 2.0 ppmv @ 15% 02 are <br /> considered to be BACT for the proposed project. <br /> 5.1C.1.4 PM10/PM2.5 Emissions <br /> 5.1C.1.4.1 Achievable Controlled Levels and Available Control Options <br /> PM emissions from natural gas-fired turbines and HRSGs primarily result from carryover of <br /> noncombustible trace constituents in the fuel. PM emissions are minimized by using clean <br /> burning pipeline quality natural gas with low sulfur content. <br /> The CARB BACT Clearinghouse, as well as the BAAQMD and SJVAPCD BACT guidelines, <br /> identify the use of natural gas as the primary fuel as"achieved in practice" for the control of <br /> PM10 for combustion gas turbines. The SJVAPCD also requires the use of an air inlet filter <br /> cooler and a lube oil vent coalescer to remove ambient particulate matter from the inlet air <br /> and to minimize the formation of lube oil mists. <br /> The CARB's BACT guidance document for stationary gas turbines used for combined-cycle <br /> and cogeneration power plant configurations6 indicates that BACT for the control of PM <br /> emissions is an emission limit corresponding to natural gas with fuel sulfur content of no <br /> more than 1 grain/100 standard cubic foot. <br /> Title 40 CFR Part 60 Subpart KKKK contains the applicable NSPS for combustion gas <br /> turbines. Subpart KKKK does not regulate PM10 emissions. <br /> Published prohibitory rules from the District,SCAQMD,SJVAPCD,SMAQMD, and <br /> SDCAPCD were reviewed to identify the PM10 standards that govern natural gas-fired <br /> combustion gas turbines. These prohibitory rules do not regulate PM10 emissions. The <br /> applicable NSPS (40 CFR 60 Subpart KKKK) limits SOx emissions to 0.56 lb/MWh,well <br /> above permitted limits for natural gas-fired turbines. <br /> Recent PM10 BACT determinations for similarly-sized gas turbines/HRSGs are summarized <br /> in Table 5.1C-4. <br /> 6 Ibid,Table 1-2. <br /> SAC/371322/082330016(LEC_5.1C_APPENDIKI)OC) 5.1C 10 <br />