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5.1C:EVALUATION OF BEST AVAILABLE CONTROL TECHNOLOGY <br /> 5.1C.1.4.1.1 Conclusions <br /> Based upon the results of this analysis,the SJVAPCD BACT guideline reflects the most stringent <br /> PMlo emission limit. The District established a requirement for the use of natural gas as the <br /> primary fuel to control PM10 emissions from combustion gas turbines. Therefore,the use of <br /> natural gas as the primary fuel source constitutes BACT for PMlo emissions from combustion gas <br /> turbines. Through the use of natural gas,the turbine is expected to be able to meet the proposed <br /> emission limit of 9.0 lb/hr without duct firing and 11.0 lb/hr with duct firing. These limits are <br /> consistent with or lower than the limits shown in the summary table,with the exception of the <br /> Blythe II project. Since the Blythe II project has not yet been constructed or operated and no <br /> performance data are available, this permit limit is not considered achieved in practice. <br /> 5.1C.1.5 SOx Emissions <br /> 5.1C.1.5.1 Achievable Controlled Levels and Available Control Options <br /> The CARB BACT Clearinghouse,as well as the BAAQMD and SJVAPCD BACT guidelines, <br /> identifies the use of PUC-quality natural gas or natural gas with a limit on the sulfur content <br /> (i.e.,1 grain/100 scf) as the primary fuel as"achieved in practice' for the control of SOx for <br /> combustion gas turbines. The two most recent BACT determinations in the SCAQMD did not <br /> indicate BACT for SOx. <br /> 5.1C.1.5.1.1 Federal NSPS <br /> Title 40 CFR Part 60 Subpart KKKK contains the applicable NSPS for combustion gas turbines. <br /> A combustion gas turbine is subject to a SO2 emission limit of 0.56 lb/MWh. <br /> 5.1C.1.5.1.2 District Prohibitory Rules <br /> Published prohibitory rules from the BAAQMD,SJVAPCD, and SCAQMD were reviewed to <br /> identify the SO2 standards that govern existing gas turbines. <br /> • BAAQMD Rule 9-9 (Nitrogen Oxides from Stationary Gas Turbines) is the BAAQMD's <br /> only prohibitory rule that specifically addresses gas turbines but does not limit SO2 <br /> emissions. The BAAQMD adopted Rule 9-1 (Sulfur Dioxide) to limit SO2 emissions from <br /> all sources. Rule 9-1 prohibits SO2 emissions in excess of 300 ppm. No other BAAQMD <br /> Rule or Regulation contains a relevant prohibitory rule regulating either the sulfur content <br /> in the fuel or the emission of SO2 from gas turbines. <br /> • SJVAPCD Rule 4703 (Stationary Gas Turbines) is the SJVAPCD's only prohibitory rule that <br /> specifically addresses gas turbines but does not limit SO2 emissions. The SJVAPCD <br /> adopted Rule 4301 (Fuel Burning Equipment) to limit SO2 emissions from these devices. <br /> Rule 4301 specifies a SO2 emission limit of 200 pounds per hour. The SJVAPCD also <br /> adopted Rule 4801 (Sulfur Compounds) to limit emissions of sulfur compounds. Rule 4801 <br /> specifies a SO2 emission limit of 0.2%, or 2,000 ppm. <br /> • SCAQMD Rule 1134 (Emissions of Oxides of Nitrogen from Stationary Gas Turbines) is the <br /> SCAQMD's only prohibitory rule that specifically addresses gas turbines;however,it does <br /> not limit SO2 emissions. The SCAQMD adopted Rule 431.1 (Sulfur Content of Gaseous <br /> Fuels) to reduce SOx emissions from the burning of gaseous fuels in stationary equipment. <br /> Rule 431.1 specifies a sulfur limit of 16 grains/100 scf(as H2S) in natural gas sold within <br /> the SCAQMD. The SCAQMD also adopted Rule 407 (Liquid and Gaseous Air <br /> Contaminants) to limit SO2 emissions from all sources. Rule 407 specifies an emission limit <br /> of 2,000 ppm for sulfur compounds (calculated as SO2). <br /> SAC/371322/082330016(LEC_5.1C_APPENDIX.DOC) 5.1C 12 <br />