ARCHIVED REPORTS LEC APPLICATION FOR CERTIFICATION

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5.1 AIR QUALITY BACT for the applicable pollutants was determined by reviewing the SJVAPCD BACT Clearinghouse,34 the South Coast Air Quality Management District (SCAQMD) BACT Guidelines,35 the CARB BACT Determinations,36 and EPA's Reasonably Available Control Technology (BACT)/BACT/LAER Clearinghouse (RBLC).37 A summary of the review is provided in Appendix 5.1C. NOX BACT-BACT for NOX emissions from the gas turbine will be the use of low NOX emitting equipment and add-on controls. The Applicant has selected a gas turbine equipped with dry low-NOX combustors. The gas turbines will generate approximately 9 ppmvd NO, corrected to 15 percent 02, at the entry to the HRSGs. In addition,the turbines will be equipped with an SCR system to further reduce NOX emissions to 2.0 ppmvd NO,corrected to 15 percent 02. Hourly average NOX emissions will not exceed 2.0 ppmvd @ 15% 02 (excluding startups and shutdowns).The duct burner will also be exhausted to the SCR system;therefore, BACT for the duct burner is the same 2.0 ppmvd NOX level,corrected to 15 percent 02. A review of recent BACT determinations for NOX from gas turbines is shown in Appendix 5.1C. BACT for NOX emissions from the auxiliary boiler will be the use of low NOx emitting equipment. The project has selected a boiler equipped with ultra low-NOX burners. The boiler with low NOX burners will generate less than 7 ppmvd NO ,corrected to 3 percent 02. The SJVAPCD BACT guidelines indicated that BACT from a boiler (> 20 MMBtu/hr heat input) with highly variable loads or high turndown ratios is a NO,,exhaust concentration not to exceed 15 ppmvd,corrected to 3 percent 02;therefore,the project will meet or exceed the BACT requirements for NO, A review of recent BACT determinations for NO,,from boilers is shown in Appendix 5.1C. CO BACT-BACT for CO emissions will be achieved by use of a gas turbine equipped with a dry low-NOX combustor and an oxidation catalyst. Dry low-NO,,combustors emit low levels of combustion CO while still maintaining low-NOX formation. In addition,the project will use an oxidation catalyst system to further reduce CO emissions to 3.0 ppmvd,corrected to 15 percent 02 (excluding startup and shutdown periods). SJVAPCD BACT Guideline 3.4.2 C indicates that BACT from a large gas turbine with heat recovery is 4.0 ppmvd CO,corrected to 15 percent 02. CO emissions from the proposed gas turbines will meet this BACT requirement. A review of recent BACT determinations for CO from gas turbines is provided in Appendix 5.1C. The auxiliary boiler will achieve a CO emission rate of 50 ppmvd,corrected to 3 percent 02. While the SJVAPCD BACT guidelines do not include a specific BACT level for CO, guidelines in other districts (e.g.,SCAQMD,BAAQMD) indicate that BACT for boilers is 50 ppmvd at 3 percent 02. The proposed CO emission rate is consistent with these BACT determinations. VOC BACT-BACT for VOC emissions will be achieved by use of the gas turbine dry low- NOX combustor. As in the case of CO emission formation, dry low-NOX combustors that result in low combustion VOC while still maintaining low NOX levels. BACT for VOC 34 SJVAPCD.BACT Clearinghouse,http://www.valleyair.org/busind/pto/bact/bactchidx.htm. 35 SCAQMD.BACT Guidelines,http://www.aqmd.gov/bact/BACTGuidelines.htm. 36 CARB.Statewide BACT,http://www.arb.ca.gov/bact/bact.htm. 37 EPA.RBLC,hftp://cfpub.epa.gov/rblc/htm/bIO2.cfm. SAC/371322/082410013(LEC_5.1_AIR_QUALITY.DOC) 5.1-67