San Joaquin Valley AIR POLLUTION CONTROL DISTRICT

ang HEALTHY AIR LIVING*

JUN 2 4 2010 Mr. William Fall Chevron USA Inc PO Box 1392 Bakersfield, CA 93302

Re: , Notice of Preliminary Decision - ATC I Certificate of Conformity Facility # S-1129 Project # 110191 6

Dear Mr; Fall:

Enclosed for your review and comment is the District's analysis of an application for Authorities to Construct for Chevron USA Inc at the McKittrick Cogeneration plant within the heavy oil production stationary source in the western Kern County fields, CA. The ATCs authorize installation of two 5.285 MW Solar Taurus gas turbine enginelcogeneration units, each with 40 MMBtulhr duct burner, heat recovery steam generator, a Selective Catalytic Reduction (SCR) System, and an Oxidation Catalyst. These units will replace existing equipment and are being installed to achieve corr~pliance with District Rule 4703.

After addressing all comments made during the 30-day public notice and the 45- day EPA comment periods, the Authorities to Construct will be issued to the facility with Certificates of Conformity. Prior to operating with modifications authorized by the Authorities to Construct, the facility must submit an application to modify'the Title V permit as an administrative amendment, in accordance with District Rule 2520, Section 11.5.

The public notice will be PI-~blished approximately three days from the date of this letter. Please submit your written comments within the 30-day public comment period which begins on the date of publication of the public notice.

If you have any questions, please contact Mr. Leonard Scandura, Permit Services Manager, at (661) 392-5500.

Thank you for your cooperation in this matter.

Director of Permit Services

DW: RElcm

Enclosures

Seyed Sadredin Executive DirectorlAir Pollution Control Officer

Northern Region Central Region (Main Office) Southern Region 4800 Enterprise Way 1990 E. Gettysburg Avenue 34946 Flyaver Caurt

Madesto, CA 95356-8718 Fresna, CA 93726.0244 Bakersf~eld, CA 93308.9725 Tel: 1209) 557.6400 FAX: (209) 557.6475 Tel: (559) 230.6000 FAX: 1559) 230.6061 Tel: 661.392-5500 FAX: 661.392.5585

San Joaquin Valley d AIR POLLUTION CONTROL DISTRICT JUN 2 4 2010 Gerardo C. Rios, Chief Permits Office Air Division U.S. EPA - Region IX 75 Hawthorne St. San Francisco, CA 941 05

Re: Notice of Preliminary Decision - ATC 1 Certificate of Conformity Facility # S-1129 Project # 1101916

Dear Mr. Rios:

Enclosed for your review is the District's engineering evaluation of an application for Authorities to Construct for Chevron USA Inc at the McKittrick Cogeneration plant within the heavy oil production stationary source in the western Kern County fields, CA, which has been issued a Title V permit. Chevron USA Inc is requesting that Certi.ficates of Conformity, with the procedural requirements of 40 CFR Part 70, be issued with this project. The ATCs authorize installation of two 5.285 MW Solar Taurus gas turbine enginelcogeneration units, each with 40 MMBtulhr duct burner, heat recovery steam generator, a Selective Catalytic Reduction (SCR) System, and an Oxidation Catalyst. These units will replace existing equipment and are being installed to achieve compliance with District Rule 4703.

Enclosed is the engineering evaluation of this application and proposed Authorities to Construct # S-1129-868-0 and '-869-0 with Certificates of Conformity. After demonstrating compliance with the Authority to Construct, the conditions will be incorporated into the facility's Title V permit through an administrative amendment.

Please submit your written comments on this project within the 45-day comment period that begins on the date you receive this letter. If you have any questions, please contact Mr. Leonard Scandura, Permit Services Manager, at (661) 392- 5500.

Thank you for your cooperation in this matter.

David Warner Director of Permit Services

DW: REIcm

Enclosures Seyed Sadredin

Executive OirectorlAir Pollution Control Officer

Northern Region Central Region (Main Office) Southern Region 4800 Enterprise Way 1990 E. Gettysburg Avenue 34946 Flyover Court

Modesto, CA 95356.8718 Fresno, CA 93726.0244 Bakersfield, CA 93308-9725 Tel: (209) 557-6400 FAX: 1209) 557.6475 Tel: I5591 230-6000 FAX: 1559) 230-6061 Tel: 661.392-5500 FAX: 661.392-5585

San Joaquin Valley AIR POLLUTION CONTROL DISTRICT HEALTHY AI R LIVING"

Mike Tollstrup, Chief Project Assessment Branch Air Resources Board P 0 Box 2815 Sacramento, CA 9581 2-281 5

Re: Notice of Preliminary Decision - ATC I Certificate of Conformity Facility # S-1129 Project # 11 01 91 6

Dear Mr. Tollstrup:

Enclosed for your review and comment is the District's analysis of an application for Authorities to Construct for Chevron USA Inc at the McKittrick Cogeneration plant within the heavy oil production stationary source in the western Kern County fields, CA. The ATCs authorize installation of two 5.285 MW Solar Taurus gas turbine enginelcogeneration units, each with 40 MMBtuIhr duct burner, heat recovery steam generator, a Selective Catalytic Reduction (SCR) System, and an Oxidation Catalyst. These units will replace existing equipment and are being installed to achieve compliance with District Rule 4703.

The public notice will be published approximately three days from the date of this letter. Please submit your written comments within the 30-day public comment period which begins on the date of publication of the public notice.

Thank you for your cooperation in this matter. If you have any questions, please contact Mr. Leonard Scandura, Permit Services Manager, at (661) 392-5500.

Thank you for your cooperation in this matter

Director of Permit Services

DW: REicm

Enclosures

Seyed Sedredin Executive DirectorlAir Pollution Control Officer

Northern Region Central Region (Main Office) Southern Region 4800 Enterprise Way 1990 E. Gettysburg Avenue 34946 Flyover Court

~odesto. CA 95356-8718 ' . Fresno. CA 93726.0244 Bakersfield, CA,93308.9725 Tel: 1209) 557.6400 FAX: 1209) 557-6475 Tel: 1559) 230-6000 FAX: (559) 230.6061 Tel: 661.392.5500 FAX: 661.392.5585

Bakersfield Californian

NOTICE OF PRELIMINARY DECISION FOR THE PROPOSED ISSUANCE OF

AUTHORITY TO CONSTRUCT

NOTICE IS HEREBY GIVEN that the San Joaquin Valley Air Pollution Control District solicits public comment on the proposed issuance of Authority To Construct to Chevron USA Inc for its McKittrick Cogeneration plant at the McKittrick Cogeneration plant within the heavy oil production stationary source in the western Kern County fields, California. The ATCs authorize installation of two 5.285 MW Solar Taurus gas turbine enginelcogeneration units, each with 40 MMBtuIhr duct burner, heat recovery steam generator, a Selective Catalytic Reduction (SCR) System, and an Oxidation Catalyst. These units will replace existing equipment and are beirrg installed to achieve compliance with District Rule 4703.

The analysis of the regulatory basis for these proposed actions, Project #1101916, IS available for public inspection at http:lhrvww.valleyair.org/notices/public~noti~idx.htm and the District office at the address below. Written comments on the proposed initial permit must be submitted within 30 days of the publication date of this notice to DAVID WARNER, DIRECTOR OF PERMIT SERVICES, SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT, 1990 E. GETTYSBURG AVE, FRESNO, CA 93726-0244.

San Joaquin Valley Air Pollution Control District Authority to Construct Application Review

Two Replacement Gas Turbines with SCR Systems for Rule 4703 Compliance

Facility Name: Chevron USA, Inc. (CUSA) Date: June 21, 201 0

Mailing Address: P.O. Box 1392 Engineer: Richard Edgehill

Bakersfield, CA 93302 Lead Engineer: Richard Karrs

Contact Person: John Gruber Telephone: (661 ) 654-7144

Fax: (661) 654-7606 E-Mail: john.gruber@chevron.com

Application #s: S-1129-868-0 and '-869-0

Project #: S-1101916

Deemed Complete: May 6, 2010

I. Proposal

Chevron USA Inc (CUSA) is requesting is requesting Authorities to Construct (ATCs) for two 5.285 MW Solar Taurus gas turbine enginelcogeneration units, each with 40 MMBtuIhr duct burner, heat recovery steam generator, a selective catalytic reduction (SCR) system, and an oxidation catalyst. The new units will replace three existing gas turbine enginelcogeneration units (S-1129-47, through '-49) and are designed to meet the current Rule 4703 Tier-3 emission standard of 5 ppmvd NOx @ 15% O2 .

Note that outstanding ATCs S-1127-47-14 through '-49-14 authorize the following retrofits for Rule 4703 compliance:

INSTALL A SELECTIVE CATALYrlC REDUCTION (SCR) SYSTEM WlTH AMMONIA INJECTION TO COMPLY WlTH RULE 4703 'TIER 3 EMISSION LIMIT OF 5 PPMVD NOX @ 15% 02; INSTALL A CONTINUOUS EMISSIONS MONITORING SYSTEM (CEMS) TO MEASURE NOX, CO AND 0 2 CONCENTRATIONS; REPLACE STRU-THERS-WELLS HEAT RECOVERY STEAM GENERATOR (HRSG) WlTH ANOTHER HRSG (IF NECESSARY); AND REPLACE THE EXISTING 20.0 MMBTUIHR DUCT BURNER WlTH A NEW 20.0 MMBTUIHR (NOMINAL RATING) DUCT BURNER (IF NECESSARY)

Applicant has requested the option to either implement ATCs S-I 129-47-14 through '-49-14 (Rule 4703 retrofit.ATCs) or implement the proposed ATCs S-1129-868-0 and '-869-0. If the proposed ATCs are implemented, units S-1129-47 through '-49 will be permanently removed from service.

Installation of the proposed gas turbine enginelcogeneration units is exempt from BACT and offsets as stated in Section 5.4 of Rule 4703 which follows:

5.4 For existing facilities, a replacement unit installed for the sole purpose of complying with the requirements of this rule shall be considered to be an emission control technique and may be exempt from the Best Available

CUSA S-1129, #I101916

Control Technology (BACT) and Offsets requirements of District Rule 2201 (New and Modified Stationary Source Review Rule) provided that all other requirements of Rule 2201 are met.

However, as demonstrated in the calculations section, the project requires public notice.

CUSA facility S-1129 has a Title V PTO. This modification can be classified as a Title V minor modification pursuant to Rule 2520, Section 3.20, and can be processed with a Certificate of Conformity (COC). Since the facility has specifically requested that this project be processed in that manner, the 45-day EPA comment period will be satisfied prior to the issuance of the Authority to Construct. CUSA must apply to administratively amend their Title'V Operating Permit to include the requirements of the ATC(s) issued with this project.

Current PTOs S-1129-47-11 through '-49-1 1 are included in Attachment I.

II. Applicable Rules

Rule 2201 New and Modified Stationary Source Review Rule (9121106) Rule 2520 Federally Mandated Operating Permits (6121101) Rule 4001 New Source Performance Standards (4114199) Rule 41 01 Visible Emissions (211 7105) Rule 4 1 02 Nuisance (1 211 7192) Rule 4201 Particulate Matter Concentration (1 211 7192) Rule 4301 Fuel Burning Equipment (12117192) - not applicable - does not apply to

gas turbines Rule 4703 Stationary Gas Turbines (9120107) Rule 4801 Sulfur Compounds (1 2117192) CH&SC 41700 Health Risk Assessment CH&SC 42301.6 School Notice Public Resources Code 21 000-21 177: California Environmental Quality Act (CEQA) California Code of Regulations, Title 14, Division 6, Chapter 3, Sections 15000-15387: CEQA Guidelines

Ill. Project Location

The new cogen units will be located at the Mckittrick Cogeneration plant in the CUSA's heavy oil production stationary source in western Kern County fields, Section 18, T30S, R 22E.

A location map is provided in Attachment II.

IV. Process Description

The existing McKittrick Cogeneration plant units generate electricity for sale to the utility power grid and also generate steam for thermally enhanced oil recovery operations (TEOR). Each cogeneration unit consists of a gas turbine engine, an electrical generator, a heat recovery steam generator (HRSG), duct burner which is used to add more heat to the HRSG and an inlet evaporative air cooler.

CUSA S-1129. #1101916

Replacement Units

CUSA has recently evaluated the feasibility of refitting units S-112947 through ' 49 with SCR (as authorized by ATCs S-112947-14 through '-49-14) and has determined that, for health and safety reasons, all 3 units would be required to be shut down during retrofit of each unit. A more desirable approach, although apparently not feasible, would be to operate two units during retrofit of the third unit. Additionally, the existing facility layout is not designed to accommodate SCR and CEMs equipment.

In lieu of retrofitting the existing units ' 4 7 through '49, CUSA requests the option to replace units '-47 through ' 4 9 with an equivalently rated (MMBtuIhr) facility as an alternative means of meeting the Rule 4703 requirement of 5 ppmv NOx @ 15% 02. The new gas turbines would be located on new foundations adjacent to the existing facility. Simultaneous operation of the two new units '-868 and '-869 and 3 existing units ' 4 7 through '-49 during a 90-day "shakedown period" would ensure that there is no interruption in power and steam supply. After the 90 day shakedown period the existing units '-47 through '-49 would be permanently removed from service.

The ATCs for units '-868 and '-869 will include the following provisions:

1. Establish an ammonia emissions (slip) limit of 21 ppmv @ 15% O2 for each cogen unit. Compliance with the ammonia slip limit will be demonstrated by annual source testing.

2. Incorporate provisions allowing a 90-day "shakedown" period for each replacement cogen in which NOx emissions will be limited to 42 ppmvd @ 15% 0 2 (via water steam injection) and CO emissions to 50 ppmvd @ 15% 0 2 per the manufacturers guarantee. Allow simultaneous operation of the existing units '-47 through ' 4 9 and replacement units '-868 and '-869 during a period not to exceed 90 days (further explanation is provided under Rule 4703 in Section Vlll of the evaluation) in accordance with the definition of a stationary source project as stated in Section 3.38.1 of Rule 2201 which follows:

3.38 Stationary Source Project: a single permitting action involving the modification, addition or shutdown of one or more emissions units. If any increase in emissions from a new or modified emissions unit is permitted based on emission reductions from one or more emissions units included in the stationary source project, the following condition must also be met:

3.38.1 The modification or shutdown resulting in the necessary emission reductions shall occur not later than the date of initial operation of the new or modified emissions unit. If the new or modified emissions unit is, in whole or in part, a replacement for an existing emissions unit at the same stationary source, the APCO may allow a maximum of 90 days as a start up period for simultaneous operation of the existing emissions unit and the replacement emissions unit.

Incorporate a provision, pursuant to Section 5.3.3 of Rule 4703, that allows for a startup period of up to 4 hours for "black start" conditions, when the cogen plant is electrically de- energized and is separated from the utility (PG&E) grid. When a "black start" is performed, each turbine is run at varying outputs (5% to 100%) depending on the field load that the units are supporting. Turbines that run at reduced load tend to have higher emissions (particularly CO, but also NOx). CUSA anticipates having problems meeting the new lower NOx limits, and existing CO limits, during reduced loads since it will take longer to reach the required SCR temperature range to allow ammonia injection to start.

"Black Start" events are relatively rare that may happen once or twice a year. The following condition will be included in each permit:

A black start event is defined as the startup of a unit while the cogen plant is electrically separated from the utility grid. A black start shall not exceed 4.0 hours per event. [District Rules 2201 and 47031 Y

Preliminary diagrams of the proposed replacement cogens and CEMs are included in Attachment Ill.

V. Equipment Listing

Pre-Proiect Equipment Description:

C 4 4 3 4 4 . P 5- - ..a . . . V.

(TO BE DELETED)

Post Proiect Equipment Description:

ATCs S-1129-868 and '-869: 5.285 MW (NOMINAL RATING) GAS TURBINE ENGINE COGENERA1-ION UNIT #2 (MCKITTRICK) EQUIPPED WITH: 63 MMB'TUIHR (NOMINAL) SOLAR TAURUS 60-7901 GAS TURBINE ENGINE (GTE); HEAT RECOVERY STEAM GENERATOR (HRSG) WlTH A 40 MMBTUIHR (NOMINAL) DUCT BURNER; WATER INJECTION SYSTEM FOR INTERMEDIATE NOX CONTROL; SELECTIVE CATALYTIC REDUCTION (SCR) SYSTEM WlTH AMMONIA INJECTION TO COMPLY WlTH RULE 4703 TIER 3 EMISSION LIMIT OF 5 PPMV NOX @ 15% 02; OXIDA-I-ION CATALYST FOR CO CONTROL; AND SHARED CONTINUOUS EMISSIONS MONITORING SYSTEM (CEMS) TO MEASURE NOX, CO, AND 0 2 CONCENTRA~'IONS

VI. Emission Control Technology Evaluation

NOx Control Selective catalytic reduction systems selectively reduce NOx emissions by injecting ammonia (NH3) into the exhaust gas stream upstream of a catalyst. Nitrogen oxides, NH3, and 0 2 react on the surface of the catalyst to form molecular nitrogen (N2) and H20. SCR is capable of over 90 percent NOx reduction. Titanium oxide (TiO2) is the SCR catalyst material most commor~ly used, though vanadium pentoxide (V2O5), noble metals, or zeolites are also used. The ideal operating temperature for a conventional SCR catalyst is 350 to 750 OF. Exhaust gas temperatures greater than the upper limit (750 OF) will cause NOx and NH3 to pass through the catalyst unreacted. The proposed SCR system is designed for a medium temperature range of 350 to 600 OF and will be installed within the cavity of the heat recovery steam generators to ensure the exhaust temperature is maintained at the appropriate range of 450 to 650 OF. The applicant has proposed an ammonia slip of 21 ppmvd @ 15% 0 2 .

CUSA S-1129. #1101916

CO Control The new cogen units will include an oxidation catalyst for CO control.

Manufacturer's information on the SCR system and oxidation catalysts are included in Attachment IV.

VII. General Calculations

A. Assumptions

All calculations and physical constants used are corrected to Standard conditions as defined in District Rule 1020, Section 3.47 (60 OF and 1 atm). Oxygen based F-factor for natural gas fuel is 8,578 dscflMMBtu. Other assumptions will be stated, as they are made. Nominal turbine rating, 63.0 MMBtuIhr ('-868 and '-869) Nominal duct burner rating, 40 MMBtuIhr ('-868 and '-869) Nominal turbine rating, 48.7 MMBtuIhr ('-47 through '-49) Nominal duct burner rating, 20 MMBtuIhr (('-47 through '-49) 3 startups (60 min each) and 3 shutdowns (30 minute each) per day - total 4.5 hrlday 15 startups (60 min each) and 15 shutdowns (30 minute each) per yr - total 22.5 hrlyr Baseload operation - 24 - 4.5 = 19.5 Iblday, 8760 - 22.5 = 8737.5 hrly

B. Emission Factors

1 I MW I MMBtuIhr I IbIMMBtu I

Existing Units S-1129-47 through '-49 (each from' project 1085346)

Permit #

S-1129-47, '- 48, and '-49

Power Rating

Shutdown Emissions

3.5

I blevent 2.3

163.3

Turbine Rating

Source Manufacturer

I Manufacturer 9.5 Manufacturer

Duct Burner Ratin g

48.7

Total neat Input

20.0 0.1 106 68.7 0.0023 0.00885

NOX

0.0654

SOX

0.024

PMio , CO VOC

CUSA S-1129. #I101916

*(5.0 ft3 NOx/10' ft3gas@l 5%02) X (20.95/(20.95-1 5)ft3 aas@15%0~lft3aas@0%02) X (8578 dscf @ 0% 02/MM Btu) (lbmo11379.5 ft3)(46 Ibllbmol) = 0.01831 Ib/MMBtu

Replacement Units S-1129-868 and '-869

(29 ft3 ~0110' ft3 gas@l9%02) X (20.95/(20.95-1 5)ft3 aas@l 5%0~1ft3~as@0%02) X (8578 dscf @ 0% OllMM Btu) (lbmo11379.5 ft3)(28 Ibllbmol) = 0.06463 IblMMBtu

"PM10 EF referenced from other CUSA cogen plants equipped with Solar GTEs (e.g. S-1128-366 through -369)

Permit #

S-1129-868, '- 869

NOX*

1 VOC 19.6 Manufacturer

Power Rating

MW

5.285

Startup Emissions

Ammonia

SOX

NOx CO

(21 ft3 ~ ~ ~ 1 1 o6 fl) gas@15%02) X (20.95/(20.95-1 5)ft3 aas@15%0~lft~aas@0%02) X (8578 dscf @ 0% 02/MM Btu) (lbmo11379.5 ft3)(17 Ibllbmol) = 0.02841 IbIMMBtu

Turbine Rating

IbIMMBtu

0.01831

I blevent 6.3

329.8

VOC Duct

Burner PMl$*

Source Manufacturer Manufacturer

Total Heat CO*

MMBtulhr

0.0023

Ratin

103.0 63.0 0.024 40.0 0.013 0.06463

C. Calculations

1. Pre-Project Potential to Emit (PEI)

S-1129-47 though '-49 (each)

Baseload operation

Baseload + Startu~ And Shutdown Emissions

Daily PE1

Pre Project Potential to Emit (PEI) 1

F[ VOC

0.1 11 0.00230 0.0089 0.065

0.0240

NOx

S-1129-868 and '-869 Since these are new emissions units, PEI = 0 for all pollutants.

Annual PE1 I

PMlo CO

VOC

68.7 68.7 68.7 68.7 68.7

Daily Emissions (I bld a y)

148.2 + 3x5.0 + 3 x

Fi VOC

Annual Emissions (I blyea r)

66,389 + 15x5.0 + 15

14.6 87.6 + 3 x 272.4 + 3

x 163.3 = 1394.7 32.2+ 3 x 16.1 + 3 x

19.5 24 24

19.5 19.5

8,738 8,760 8,760 8,738 8,738

5,326 39,257 + 15 x 272.4 + 15 x 163.3 = 45,793 14,406 + 15 x 16.1 +

148.2 3.8 14.6 87.6 32.2

0.1 11 0.00230 0.0089 0.065

0.0240

66,389 1,384 5,326 39,257 14,406

68.7 68.7 68.7 68.7 68.7

CUSA S-1129, #1101916

2. Post Project Potential to Emit (PE2)

S-1129-857 and '-858 (each)

Baseload operation

0.01 8 0.00233 1 1 03 19.5 36.8

1 03 24 5.8 0.01 30 1 03 24 32.1 0.065 1 03 19.5 129.8

VOC 0.0240 1 03 19.5 48.2

Annual PE2

0.01 8 0.00233 1 1 03 8,738 16,478

1 03 8,760 2,102 0.01 30 1 03 8,760 11,730 0.065 1 03 8,738 58,165

VOC 0.0240 1 03 8,738 21,599

Baseload + Startup And Shutdown Emissions Post Proiect Potential to Emit (PE2)

NOx

SOX

Ammonia Emissions 0.02841 IbIMMBtu x 103 MMBtulhr x 24 hrlday = 70.2 Iblday (25,634 Iblyr)

Daily Emissions (I blday)

36.8 + 3 x 6.3 + 3 x

VOC

Annual Emissions (Iblyear)

16,478 + 15 x 6.3 + 15 2.8 = 64.1

5.8 x 2.8 = 16,615

2.102

3 x 179.9 = 1658.9 4 8 . 2 + 3 x 1 9 . 6 + 3 ~

10.6 = 138.8

15 x 179.9 = 65,811 21,599+15x19.6+ 15 x 10.6 = 22.052

CUSA S-1129. #1101916

Greenhouse Gas Emissions (District Policv APR 201 5) Post Proiect Annual heat input

Excluding shakedown period emissions the post-project annual heat input is calculated as follows*

2 x 103 MMBtuIhr x 24hrlday x 365 dayslyr

= 1,804,560 MMBtuIyr

Pre-proiect annual heat input

3 x 68.7 MMBtuIhr x 8760 hrlyr = 1,805,436 MMBtuIyr

Net change in heat input

1,804,560 MMBtu - 1,805,436 MMBtuIyr = - 876 MMBtuIyr

There is a decrease in annual heat input rating and therefore an annual decrease in GHG emissions.

District Technical Services has determined that project specific GHG emissions which occur consistent with District Rule 2201, section 3.38.1 (shakedown period excess GHG emissions) are short-term in nature and have a less than a significant environmental impact. They are therefore excluded from the GHG (post project) emissions calculation.

Emissions profiles are included in Attachment V.

3. Pre-Project Stationary Source Potential to Emit (SSPEI)

Pursuant to Section 4.9 of District Rule 2201, the Pre-Project Stationary Source Potential to Emit (SSPEI) is the Potential to Emit (PE) from all units with valid Authorities to Construct (ATC) or Permits to Operate (PTO) at the Stationary Source and the quantity of emission reduction credits (ERC) which have been banked since September 19, 1991 for Actual Emissions Reductions that have occurred at the source, and which have not been used on-site.

Facility emissions are already above the Offset and Major Source Thresholds for NOx, SOX, PM10, CO, and VOC emissions; therefore, SSPEl calculations.are not necessary.

4. Post Project Stationary Source Potential to Emit (SSPEZ)

Pursuant to Section 4.10 of District Rule 2201, the Post Project Stationary Source Potential to Emit (SSPE2) is the Potential to Emit (PE) from all units with valid Authorities to Construct (ATC) or Permits to Operate (PTO) at the Stationary Source and the quantity of emission reduction credits (ERC) which have been banked since September 19, 1991 for Actual Emissions Reductions that have occurred at the source, and which have not been used on-site.

Facility emissions are already above the Offset and Major Source -Thresholds for NOx, SOX, PM10, CO, and VOC emissions; therefore, SSPE2 calculations are not necessary.

5. Major Source Determination

Pursuant to Section 3.24 of District Rule 2201, a Major Source is a stationary source with post-project emissions or a Post Project Stationary Source Potential to Emit (SSPE2), equal to or exceeding one or more of ,the following threshold values. However, Section 3.24.2 states, "for the purposes of determinirlg major source status, the SSPE2 shall not include the quantity of emission reduction credits (ERC) which have been banked since September 19, 1991 for A,ctual Emissions Reductions that have occurred at the source, and which have not been used on-site."

This source is an existing Major Source for NOx, SOX, PM10, CO, and VOC emissions and will remain a Major Source for these air contaminants.

6. Baseline Emissions (BE)

The BE calculation (in Iblyear) is performed on a pollutant-by-pollutant basis to determine the amount of offsets required, where necessary, when the SSPEI is greater than the offset threshold. 'This project is exempt from offsets pursuant to Rule 2201, Section 4.6.8. Therefore, BE calculations are not required.

7. Major Modification

Major Modification is defined in 40 CFR Part 51.165 as "any physical change in or change in the method of operation of a major stationary source that would result in a significant net emissions increase of any pollutant subject to regulation under the Act."

As discussed in Section Vll.C.5 above, the facility is an existing Major Source for Major Source for NOx, SOX, PM10, and VOC emissions; however, the project by itself would need to be a significant increase in order to trigger a Major Modification. The emissions unit(s) within this project do(es) not have a total potential to emit which is greater than Major Modification thresholds (see table below). Therefore, the project cannot be a significant increase and the project does not constitute a Major Modification.

CUSA S-1129, #1101916

8. Federal Major Modification

As shown above, this project does not constitute a Major Modification. . Therefore, in accordance with District Rule 2201, Section 3.17, this project does not constitute a Federal Major Modification and no further discussion is required.

9. Quarterly Net Emissions Change (QNEC)

The QNEC is calculated solely to establish emissions that are used to complete the District's PAS emissions profile screen. Detailed QNEC calculations are included below

S-1129-857 and '-858 (each)

QNEC

16,615 1 4 qtrlyear 4,154

2,102 I 4 525

11,730 1 4 2933

65,811 1 4 16,453

VOC 22,052 4 5,513 I

VIII. Compliance

Rule 1080 Stack Monitoring

This rule grants the APCO the authority to request the installation, use, maintenance, and inspection of continuous emissions monitors (CEMs), and specifies performance standards for the equipment and administrative requirements for recordkeeping, reporting, and notification.

Chevron has proposed to monitor NOx, CO and O2 concentrations from each gas turbine systeni using CEMS that meet 'the requirements of applicable District rules and Federal regulations. Therefore, the following conditions will be placed on each permit:

The owner or operator shall install, certify, maintain, operate, and quality-assure a continuous emission monitor system (CEMS) which continuously measures and records the exhaust gas NOx, CO, and 0 2 concentrations. Continuous emissions monitors shall be capable of monitoring emissions during normal operating conditions and during startups and shutdowns, provided that CEMS passes the relative accuracy requirements of 40 CFR Part 60, Appendix B, Performance Specification 2 (PS-2) and District approved protocol for startups. If relative accuracy of CEMS cannot be demonstrated during the startup, CEMS results during startup and shutdown events shall be replaced with startup emission rates obtained from the source test conducted by the facility to determine compliance with emission limits contained in this document. [District Rules 1080, 2201 and 4703, 40 CFR 60.334(b)(l)]

The CEMS shall complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each 15-minute quadrant of the hour or shall meet equivalent specifications established by mutual agreement of the District, the ARB and the EPA. [District Rule 1080 and 40 CFR 60.334(b)(2)]

The NOx, CO and 0 2 CEMS shall meet the requirements in 40 CFR 60, Appendix F Procedure 1 and Part 60, Appendix B Performance Specification 2 (PS 2), or shall meet equivalent specifications established by mutual agreement of the District, the ARB, and the EPA. [District Rule 1080 and 40 CFR 60.334(b)(l)]

In accordance with 40 CFR Part 60, Appendix F, 5.1, the CEMS must be audited at least once each calendar quarter. The District shall be notified prior to completion of the audits. Audit reports shall be submitted along with quarterly compliance reports to the District. [District Rule 10801

APCO or an authorized representative shall be allowed to inspect, as determined to be necessary, the required monitoring devices to ensure that such devices are functioning properly. [District Rule 10801

The CEMS data shall be reduced to hourly averages as specified in'40 CFR 60.13(h), or by other methods deemed equivalent by mutual agreement with the District, the ARB, and the EPA. [District Rule 1080 and 40 CFR 60.334(b)(3)]

Upon written notice from the District, the owner or operator shall provide a summary of the data obtained from the CEMS. This summary shall be in the form and the manner prescribed by the District. [District Rule 10801

The facility shall install and maintain equipment, facilities, and systems compatible with the District's CEMS data polling software system and shall make CEMS data available to the District's automated polling system on a daily basis. Upon notice by the District that the facility's CEMS is not providing polling data, the facility may continue to operate without providing automated data for a maximum of 30 days per calendar year provided the CEMS data is sent to the District by a District-approved alternative method. [District Rule 10801

The permittee shall maintain the following records: the date, time and duration of any malfunction of the continuous monitoring equipment; dates of performance testing; dates of evaluations, calibrations, checks, and adjustments of the continuous monitoring equipment; date and time period which a continuous monitoring system or monitoring device was inoperative. [District Rules 1080 and 2201 and 40 CFR 60.8(d)]

The owner or operator shall submit a written report of CEM operations for each calendar quarter to the District. The report is due on the 30th day following the end of the calendar quarter and shall include the following: Time intervals, data and magnitude of excess NOx emissions, nature and the cause of excess (if known), corrective actions taken and preventive measures adopted; Averaging period used for data reporting corresponding to the averaging period specified in the emission test period used to determine compliance with an emission standard; Applicable time and date of each period diring which the CEM was inoperative, except for zero and span checks, and the nature of system repairs and adjustments; A negative declaration when no excess emissions occurred. [District Rule 1080 and 40 CFR 60.334(j)(5)]

Chevron has requested representative source testing of the new units as stated in the following condition:

The requirements in 40 CFR 60, Appendix F, shall be met through the following EPA and District approved modified procedures: 1) annual RATA testing of at least one gas turbine engine (S-1129-857 and '-858), and rotate the unit tested so that the two units are tested over two years, 2) annual R M testing for the one gas turbine engines for which the annual RATA testing is not performed, 3) if any of the gas turbine engines fail the R M testing, they must have a RATA test within 60 days, and 4) for every quarter that RATA or R M testing is not performed, a CGA is to be performed for each gas turbine engine. [District Rule 10801

CUSA S-1129. #1101916

Rule 1081 Source Sampling

This Rule requires adequate and safe sampling facilities such as sampling ports, sampling platforms, access to the sampling platforms for use in sampling to determine compliance with emissions limits, and specifies methods and procedures for source testing and sample collection. The following conditions will be placed to ensure compliance with the requirements of this rule.

The exhaust stack shall be equipped with permanent provisions to allow collection of stack gas samples consistent with EPA test methods and shall be equipped with safe permanent provisions to sample stack gases with a portable NOx, CO, and 0 2 analyzer during District inspections. The sampling ports shall be located in accordance with the CARB regulation titled California Air Resources Board Air Monitoring Quality Assurance Volume VI, Standard Operating Procedures for Stationary Emission Monitoring and Testing. [District Rule 10811

Source testing shall be conducted using the methods and procedures approved by the District. The District must be notified at least 30 days prior to any compliance source test, and a source test plan must be submitted for approval at least 15 days prior to testing. [District Rule 10811

Source testing shall be witnessed or authorized by District personnel and samples shall be collected by a California Air Resources Board (CARB) certified testing laboratory or a CARB certified source testing firm. [District Rule 10811

For the purpose of determining compliance with the emissions limits (ppmvd @ 15% 02) during normal operation in this permit, the arithmetic mean of three test runs shall apply, unless two of the three results are above an applicable limit. If two of three runs are above the applicable limit the test cannot be used to demonstrate compliance with an applicable limit. [District Rule 10811

The results of each source test shall be submitted to the District within 60 days thereafter. [District Rule 10811

Please note that CUSA has requested initial source testing within 90 days of initial startup which is longer than the standard District practice of source testing within 60 days of initial startup. It has been CUSA's experience in previous projects authorizing SCR that a 60-day commissioning period isn't always sufficient and has resulted in the need t o pursue variances t o allow for more time. The District has approved the request as reflected in the following ATC condition:

Source testing to determine compliance with the NOx, CO and NH3 emission rates (ppmvd @ 15% 02) during normal operation shall be conducted within 90 days of initial startup under this permit and annually thereafter. [District

Rule 2201 New and Modified Stationary Source Review Rule

A. Best Available Control Technology (BACT)

As stated in the proposal section, the project is exempt from BACT as per Section 5.4 of Rule 4703 and Section 4.2.3 of Rule 2201 which stipulates the following:

For existing facilities, the installation or modification of an emission control technique performed solely for the purpose of compliance with the requirements of District, State or Federal air pollution control laws, regulations, or orders, as approved by the APCO, shall be exempt from Best Available Control Technology for all air pollutants, provided all of the following conditions are met:

CUSA S-1129. #1101916

4.2.3.1 There shall be no increase in the physical or operational design of the existing facility, except for those changes to the design needed for the installation or modification of the emission control technique itself;

4.2.3.2 There shall be no increase in the permitted rating or permitted operating schedule of the permitted unit;

4.2.3.3 There shall be no increase in emissions from the stationary source that will cause or contribute to any violation of a National Ambient Air Quality Standard, Prevention of Significant Deterioration increment, or Air Quality Related Value in Class I areas; and

4.2.3.4 The project shall not result in an increase in permitted emissions or potential to emit of more than 25 tons per year of NO" or 25 tons per year of VOC, or 15 tons per year of SO" or 15 tons per year of PMIQ, or 50 tons per year of CO.

4.2.3.5 The project shall not constitute a federal major modification.

The project meets the above BACT exemption criteria.

A higher PMIO emission limit is requested to accommodate the proposed SCR emission control equipment. SCR catalyst has the potential to increase the conversion rate of sulfur dioxide in the exhaust gases to sulfur trioxide, which reacts with ammonia in the exhaust gases to form ammonium salts, a particulate. However, the increase in PMIO emissions is less than 15 tonslyear and does not contribute to any violaton of a National Ambient Air Quality Standard, Prevention of Significant Deterioration increment, Air Quality Related Value in a Class I area, or exceed the federal major modification threshold for PMIO.

B. Offsets

1. Offset Applicability

As stated in the proposal section, the project is exempt from offsets as per Section 5.4 of Rule 4703 and Section 4.6.8 of Rule 2201 which stipulates the following:

For existing facilities, the installation or modification of an emission control technique performed solely for the purpose of compliance with the requirements of District, State or Federal air pollution control laws, regulations, or orders, as approved by the APCO, shall be exempt from offset requirements for all air pollutants provided all of the following conditions are met:

4.6.8.1 There shall be no increase in the physical or operational design of the existing facility, except for those changes to the design needed for the installation or modification of the emission control technique itself;

CUSA S-1129, #1101916

4.6.8.2 There shall. be no increase in the permitted rating or permitted operating schedule of the permitted unit;

4.6.8.3 There shall be no increase in emissions from the stationary source that will cause or contribute to any violation of a National Ambient Air Quality Standard, Prevention of Significant Deterioration increment, or Air Quality Related Value in Class I areas; and

4.6.8.4 The project shall not result in an increase in permitted emissions or potential to emit of more than 25 tons per year of NO" or 25 tons per year of VOC. or 15 tons per year of SO" or 15 tons per year of PM-10, or 50 tons per year of CO.

Since the above-listed criteria are met, offsets are not triggered for any pollutant.

As discussed above, a higher PMlO emission limit is requested to accommodate the proposed SCR emission control equipment. However, the increase in PMlO emissions is less than 15 tonslyear and does not contribute to any violaton of a National Ambient Air Quality Standard, Prevention of Significant Deterioration increment, Air Quality Related Value in a Class I area, or exceed the federal major modification threshold for PM10.

C. Public Notification

1. Applicability

Public noticing is required for: a. Any new Major Source, which is a new facility that is also a Major Source, b. Major Modifications, c. Any new emissions unit with a Potential to Emit greater than 100 pounds during any

one day for any one pollutant, d. Any project which results in the offset thresholds being surpassed, andlor e. Any project with an SSlPE of greater than 20,000 Iblyear for any pollutant.

a. New Major Source

New Major Sources are new facilities, which are also Major Sources. Since this is not a new facility, public noticing is not required for this project for New Major Source purposes.

b. Major Modification

As demonstrated in Vll.C.7, this project does not constitute a Major Modification; therefore, public noticing for Major Modification purposes is not required.

Applications which include a new emissions unit with a Potential to Emit greater than 100 pounds during any one day for any pollqtant will trigger public noticing requirements. As seen in Section Vll.C.2 above, this project includes a new

CUSA S-1129. #1101916

emissions unit which has daily emissions greater than 100 Iblday for CO and VOC, therefore public noticing for PE > 100 Iblday purposes is required.

d. Offset 'Threshold

The following table compares the SSPEl with the SSPE2 in order to determine if any offset thresholds have been surpassed with this project.

LVOC 1 >20,000 lblyear 1 >20,000 lblyear 1 20,000 lblyear I No 1 As detailed above, there were no thresholds surpassed with this project; therefore public noticing is not required for offset purposes.

e. SSIPE > 24,000 Iblyear

Public notification is required for any permitting action that results in a Stationary Source Increase in Permitted Emissions (SSIPE) of more than 20,000 Iblyear of any affected pollutant. According'to District policy, the SSIPE is calci.~lated as the Post Project Stationary Source Potential to Emit (SSPE2) minus the Pre-Project Stationary Source Potelitial to Emit (SSPEI), i.e. SSIPE = SSPE2 - SSPE1. The values for SSPE2 and SSPEl are calculated according to Rule 2201, Sections 4.9 and 4.10, respectively. The SSIPE is compared to the SSIPE Public Notice thresholds in the following table:

Units S-1129-47 through '-49 will be removed upon implementation of the proposed ATCs. The pre-project emissions from these units are listed below.

CUSA S-1129, #1101916

As calculated above, the SSlPEs are not greater than 20,000 Iblyear; therefore public noticing for SSIPE purposes is not required.

Stationary

NOX

sox

PMl0

CO

"OC

2. Public Notice Action

As discussed above, this project will result in emissions which would subject the project to noticing requirements listed above. Therefore, public notice is required for this project.

Source Increase in Permitted Emissions [SSIPE] - Public Notice

D. Daily Emission Limits (DELs)

Daily Emissions Limitations (DELs) and other enforceable conditions are required by Section 3.15 to restrict a unit's maximum daily emissions, to a level at or below the emissions associated with the maximum design capacity. Per Sections 3.15.1 and 3.15.2, the DEL must be contained in the latest ATC and contained in or enforced by the latest PTO and enforceable, in a practicable manner, on a daily basis. DELs are also required to enforce the applicability of BACT.

Public Notice Required,

No

No

No

No

No

Proposed Rule 2201 (DELI Conditions:

SSPE2 (Iblyear)

>20,000 I blyea r

>54,750 I blyea r

>29,200 I blyea r

>2OO,OOO I blyea r

>20,000 Iblyear

10. During an initial shakedown period, the emissions shall not exceed any of the following limits, except during periods of startup, shutdown, and black start: 42 ppmvd NOx @ 15% 0 2 referenced as N02; 50 ppmvd CO @ 15% 02; 0.013 Ib-PMlOIMMBtu; 0.024 Ib-VOClMMBtu referenced as methane; and 0.00233 Ib- SOxIMMBtu referenced as S02. The shakedown period shall not exceed 90 calendar days from the initial startup of the unit under this permit. [District Rule 22011 Y

SSIPE (Iblyear)

33,230-1 99,487 <O

4,204 - 41 52 = 52

23,459 - 15,978 = 71481

131,622 - 137,379 <o

44,104 - 44,370 <o

SSPEI (Iblyear)

>20,000 Iblyear

>54,750 lblyear

>29,200 I blyear

>2OO,OOO I blyear

>20,000 I blyea r

11. Within 90 days of startup, permits S-1127-47, '48, and ' 4 9 shall be canceled. The permittee shall maintain a record of the date of initial operation of this unit, fuel combusted (scflday) on daily basis, and water-to-fuel ratio or results of NOx and CO over 3-hour rolling average period from CEMS (if operational). These records shall be made readily available for District inspection upon request. [District Rule 22011 Y

SSIPE Public Notice

Threshold 20,000 I blyea r 20,000 I blyea r 20,000 I blyea r 20,000 I blyea r 20,000 I blyea r

Upon concluding the initial shakedown period, emissions from the gas turbine system, when startup or shutdown or black start do not occur, shall not exceed any of the following limits: 5 ppmvd NOx @ 15% 0 2 referenced as N02; 29 ppmvd CO @ 15% 02; 0.013 Ib-PMlOIhr; 0.024 Ib-VOClhr referenced as methane; and 0.00233 Ib-SOxIhr referenced as S02. NOx and CO emission limits are based on 3-hour rolling average

CUSA S-1129, #1101916

period. If unit is in either startup, shutdown, or black start mode during any portion of a clock hour, the unit will not be subject to the ppmvd limits for NOx and CO during that clock hour. [District Rules 2201 and 47031 Y

Upon concluding the initial shakedown period, emissions from the gas turbine system, on days when startup, shutdown, or black start occurs, shall not exceed any of the following limits: 64.1 Ib-NOdday referenced as N02; 1,658.9 Ib-COIday; 5.8 Ib-Sodday; 32.1 Ib-PMlOIday; 138.8 Ib-VOCIday referenced as methane; and 70.2 Ib-NH3lday. [District Rule 22011 Y

Ammonia (NH3) emissions shall not exceed 21 ppmvd @ 15% 0 2 over a 24-hour average period. [District Rule 22011 Y

E. Compliance Assurance

1. Source Testing

For source testing, the exhaust from each gas turbine will be routed through its own SCR system to minimize NOx emissions. For an SCR system, ammonia (NH3) slip is an indicator of SCR performance. Therefore, each unit is required to be tested within 60 days of initial startup and annually thereafter for NOx, CO and NH3 emissions.

Source testing to determine compliance with the NOx, CO and NH3 emission rates (ppmvd @ 15% 02) during normal operation shall be conducted within 90 days of initial startup under this permit and annually thereafter. [District Rules 2201 and 4703, CFR 60.335(a)] Y

Note that Rule 4703 (Section 6.3.1 and 6.3.3) requires the gas turbine system to be tested on annual basis for NOx and CO emissions with duct burners "on" and "off' configurations. Therefore the ATC includes the following condition:

Unit shall demonstrate compliance annually with NOx and CO emissions limits with the duct burner in operation and not in operation. An annual demonstration of compliance with the duct burner in operation is not required in any year in which the duct burner is not operated at all in the preceding 12 months, in such case, the unit shall be compliance source tested within 60 days of resumption of operation of the duct burner. An annual demonstration of compliance with the duct burner not in operation is not required in any year in which the duct burner operated continuously in conjunction with the turbine in the preceding 12 months, in such case, the unit shall be compliance source tested within 60 days of shutdown of operation of the duct burner.

2. Monitoring

The permittee has proposed to use a shared continuous emissions monitoring system (CEMS) to monitor NOx, CO and O2 concentrations from each gas turbine system.

Sulfur monitoring is required if fuels other than PUC-regulated. or FERC-regulated natural gas are combusted.

3. Recordkeeping

Recordkeeping is required to demonstrate compliance with the offset, public notification and daily emission limit requirements of Rule 2201. The following condition(s) will appear on the ATCs:

CUSA S-1129. #1101916

The owner or operator shall maintain a stationary gas turbine system operating log that includes, on a daily basis, the actual local startup and stop time, length and reason for reduced load periods, total hours of operation, the type and quantity of fuel used, duration of each start-up (or black start) and each shutdown time period. [District Rule 47031 Y

The owner or operator shall maintain all records of required monitoring data and support information for a period of five years from the date of data entry and shall make such records available to the District upon request. [District Rules 2201 and 47031 Y

4. Reporting

The permittee is required to submit source test results within 60 after each source test.

The owner or operator shall submit to the District information correlating the NOx control system operating parameters to the associated measured NOx output. The information must be sufficient to allow the District to determine compliance with the NOx emission limits of this permit when the CEMS is not operating properly. [District Rule 47031 Y

Compliance is expected with this Rule.

F. Ambient Air Quality Analysis

Section 4.14.1 of this Rule requires that an ambient air quality analysis (AAQA) be conducted for the purpose of determining whether a new or modified Stationary Source will cause or make worse a violation of an air quality standard. The Technical Services Division of the SJVAPCD conducted the required analysis. Refer to Attachment VI of this document for the AAQA summary sheet.

The proposed location is in an attainment area for NOx, CO, and SOx. As shown by the AAQA summary sheet the proposed equipment will not cause a violation of an air quality standard for NOx, CO, or SOx.

The proposed location is in a non attainment area for PMlo. The increase in the ambient PMlo concentration due to the proposed equipment is shown on the table titled Calculated Contribution. The levels of significance, from 40 CFR Part 51 .I65 (b)(2), are shown on the table titled Significance Levels.

The results from the Criteria Pollutant Modeling are as follows:

Criteria Pollutant Modeling Results*

h he criteria pollutants are below EPA's level of significance as found in 40 CFR Part 51 .I65 (b)(2).

Diesel ICE CO NOx SOX P M ~ o

As shown, the calculated contribution of PMIO will not exceed the EPA significance level. This project is not expected to cause or make worse a violation of an air quality standard.

'Results were taken from the attached PSD s~readsheet.

1 Hour Pass Pass Pass

X

3 Hours X X

Pass X

8 Hours. Pass

X X X

24 Hours X X

Pass Pass'

Annual X

Pass Pass Pass7

CUSA S-1129, #1101916

Rule 2520 Federally Mandated Operating Permits

Chevron USA Inc possesses a Title V permit. The proposed are considered "Minor Modification" as defined in this rule. The applicant has proposed to receive the Authorities to Construct with Certificates of Conformity in accordance with the requirements of 40 CFR 70.6(c), 70.7 and 70.8. Therefore, the 45-day EPA notice will be conducted prior to the issuance of the ATCs. The following federally enforceable conditions will be placed on the Authorities to Construct:

{1830) This Authority to Construct serves as a written certificate of conformity with the procedural requirements of '40 CFR 70.7 and 70.8 and with the compliance requirements of 40 CFR 70.6(c). [District NSR Rule]

(1831) Prior to operating with modifications authorized by this Authority to Construct, the facility shall submit an application to modify the Title V permit with an administrative amendment in accordance with District Rule 2520 Section 5.3.4. [District Rule 2520, 5.3.41

Compliance is expected with this Rule.

Rule 4001 New Source Performance Standards (NSPS)

The proposed G-TE are subject to the requirements of this Rule. The applicable subparts are given below:

40 CFR Part 60 Subpart GG - Standards of Performance for Stationary Gas Turbines

40 CFR Part 60 Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

Detailed discussion on the requirements of each subpart is given below for each permit unit. CUSA's proposal meets all the requirements of the applicable subparts. Therefore, compliance is expected with the NSPS.

40 CFR Part 60 Subpart GG - Standards of Performance for Stationary Gas Turbines

40 CFR Part 60 Subpart KKKK, Section 60.4305(b), states that stationary combustion turbines regulated under this subpart are exempt from the requirements of 40 CFR 60 Subpart GG.

CUSA S-1129, #1101916

The proposed replacement GTEs are regulated under 40 CFR Part 60 Subpart KKKK. Therefore the units are exempt from the requirements of 40 CFR Part 60 Subpart GG and no further discussion is required.

40 CFR Part 60 Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

The requirements of the 40 CFR Part 60, Subpart KKKK apply to a stationary combustion turbine with heat input (at peak load) equal to or greater than 10 MMBtuIhr, and that commenced construction, modification or reconstruction after February 18, 2005. This subpart regulates nitrogen oxide (NOx) and sulfur dioxide (SOX) emissions only.

The proposed replacement GTEs are each nominally rated at 63 MMBtuIhr and will be installed after 2fi8105. Therefore, the proposed replacement turbine is subject to the requirements of this subpart.

Section 60.4320 - Standards for Nitrogen Oxides

Paragraph (a) states that NOx emissions shall not exceed the emission limits specified in Table 1 of this subpart. Table 1 states that modified or reconstructed turbines firing natural gas with a heat input at peak load between 50 MMBtuIhr and 850 MMBtuIhr shall meet a NOx emissions lirr~it of 42 ppmvd @ 15% 02. This limit is based on 4-hour rolling average or 30-day rolling average as defined in §60.4380(b)(1).

CUSA has proposed to meet 5.0 ppmvd NOx @ 15% 0 2 on three-hour rolling average period in accordance with Rule 4703. CUSA is expected to meet this limit. Permit condition enforcing this requirement is provided under Rules 2201 (DELs) and 4703.

Section 60.4330 - Standards for Sulfur Dioxide

Paragraph (a) states that if your turbine is located in a continental area, you must comply with one of the following: (1) Operator must not cause to be discharged into the atmosphere from the subject stationary combustion turbine any gases which contain SO2 in excess of 110 nanograms per Joule (ng1J) (0.90) pounds per megawatt-hour (IbIMWh)) gross output; or (2) Operator must not burn in the subject stationary combustion turbine any fuel which contains total potential sulfur emissions in excess of 26 ng S02lJ (0.060 Ib S021MMBtu) heat input.

CUSA has proposed to use PUC-regulated natural gas in the gas turbine and duct burners with a sulfur content of 0.71 grainsA00 scf or less. The following conditions will ensure compliance with the requirements of this section:

The gas turbine system (i.e. gas turbine and duct burner) shall be fired exclusively on PUC- regulated gas or PUC quality natural gas which has a sulfur content less than or equal to 0.017% by weight. [40 CFR 60.4330(a)(2) and District Rule 48011 Federally Enforceable Through Title V Permit

CUSA S-1129, #1101916

The sulfur content in the fuel being combusted shall not exceed 0.71 grains11 00 scf, otherwise, the fuel shall be of PUC-regulated quality. [District Rule 22011 Federally Enforceable Through Title V Permit

Section 60.4335 - NOx Compliance Demonstration, with Water or Steam lnjection

Paragraph (a) states that when a turbine is using water or steam injection to reduce NOx emissions, you must install, calibrate, maintain and operate a continuous monitoring system to monitor and record the fuel consumption and the ratio of water or steam to fuel being fired in the turbine when burning a fuel that requires water or steam injection for compliance.

CUSA is proposing to i ~ jec t water or steam in the GTEs for intermediate NOx control, however, primary NOx control will be achieved via selective catalytic reduction (SCR) with ammonia injection. Therefore, the requirements of this section are not applicable.

Section 60.4340 - NOx Compliance Demonstration, without Water or Steam lnjection

Paragraph (b) states that as an alternative to annual source testing, the facility may install, calibrate, maintain and operate one of the following continuous monitoring systems:

(1) Continuous emission monitoring as described in §60.4335(b) and 60.4345, or (2) Continuous parameter monitoring. CUSA has proposed to install a CEMS system as described in §60.4335(b) and 60.4345. The following condition will ensure compliance with the requirements of this section:

The owner or operator shall install, certify, maintain, operate, and quality-assure a continuous emission monitor system (CEMS) which continuously measures and records the exhaust gas NOx, CO, and 02 concentrations. Continuous emissions monitors shall be capable of monitoring emissions during normal operating conditions and during startups and shutdowns, provided that CEMS passes the relative accuracy requirements of 40 CFR Part 60, Appendix B, Performance Specification 2 (PS-2) and District approved protocol for startups. If relative accuracy of CEMS cannot be demonstrated during the startup, CEMS results during startup and shutdown events shall be replaced with startup emission rates obtained from ,the source test conducted by the facility to determine compliance with emission limits contained in this document. [District Rules 1080, 2201, 4703, and 40 CFR 60.4340(b)(1) and 40 CFR 60.4345(a)0.334(b)(l)] Federally Enforceable Through Title V Permit

Section 60.4345 - CEMS Equipment Requirements *

Paragraph (a) states that each NOx diluent CEMS must be installed and certified according to Performance Specification 2 (PS 2) in Appendix 8 to this part, except the 7 -day calibration drift is based on unit operating days, not calendar days. With state approval, Procedure 1 in Appendix F to this part is not required. Alternatively, a NOx diiuent CEMS that is installed and certified according to Appendix A of Part 75 of this chapter is acceptable for use under this subpart. The relative accuracy test audit (RATA) of the CEMS shall be performed on a ppmvd basis.

CUSA S-1129, #1101916

Paragraph (b) states that as specified in §60.13(e)(2), during each full unit operating hour, both the NOx monitor and the diluent monitor must complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each 15-minute quadrant of the hour, to validate the hour. For partial unit operating hours, at least one valid data point must be obtained with each monitor for each quadrant of the hour in which the unit operates. For unit operating hours in which required quality assurance and maintenance activities are performed on the CEMS, a rr~inimum of two valid data points (one in each of two quadrants) are required for each monitor to validate the NOx emission rate for the hour.

Paragraph (c) states that each fuel flow meter shall be installed, calibrated, maintained, and operated according to the manufacturer's instructions. Alternatively, with state approval, fuel flow meters that meet the installation, certification, and quality assurance requirements of Appendix D to Part 75 of this chapter are acceptable for use under this subpart.

Paragraph (d) states that each watt meter, steam flow meter, and each pressure or temperature measurement device shall be installed, calibrated, maintained, and operated according to manufacturer's instructions.

Paragraph (e) states that the owner or operator shall develop and keep on-site a quality assurance (QA) plan for all of the continuous monitoring equipment described in paragraphs (a), (c), and (d) of this section. For the CEMS and fuel flow meters, the owner or operator may, with state approval, satisfy the requirements of this paragraph by implementing the QA program and plan described in section 1 of Appendix B to Part 75 of this chapter.

CUSA has proposed to install and operate a CEMS to meet the requirements of this section. CUSA is not required to install a fuel flow meter, watt meter, steam flow meter, or a pressure or temperature measurement device to comply with the requirements of this subpart. The following conditions will ensure compliance with the requirements of this section:

The NOx, CO and 02 CEMS shall meet the requirements in 40 CFR 60, Appendix F Procedure 1 and Part 60, Appendix B Performance Specification 2 (PS 2), or shall meet equivalent specifications established by mutual agreement of the District, the ARB, and the EPA. [District Rule 1080 and 40 CFR 60.4345(a)] Federally Enforceable Through Title V Permit

The CEMS shall complete a rr~inimum of one cycle of operation (sampling, analyzing, and data recording) for each 15 minute quadrant of the hour or shall meet equivalent specifications established by mutual agreement of the District, the ARB and the EPA. [District Rule 1080 and 40 CFR 60.4345(b)] Federally Enforceable Through Title V Permit

Section 60.4350 - CEMS Data and Excess NOx Emissions

Section 60.4350 states that for purposes of identifying excess emissions:

(a) All CEMS data must be reduced to hourly averages as specified in §60.13(h).

(b) For each unit operating hour in which a valid hourly average, as described in §60.4345(b), is obtained for both NOx and diluent monitors, the data acquisition and handling system must

CUSA S-1129, #1101916

calculate and record the hourly NOx emission rate in units of ppm or IbIMMBtu, using the appropriate equation from Method 19 in Appendix A of this part. For any hour in which the hourly average 0 2 concentration exceeds 19.0 percent 02 (or the hourly average C02 concentration is less than 1.0 percent C02), a diluent cap value of 19.0 percent 0 2 or 1.0 percent C02 (as applicable) may be used in ,the emission calculations.

(c) Correction of measured NOx concentrations to 15 percent 0 2 is not allowed.

(d) If you have installed and certified a NOx diluent CEMS to meet the requirements of Part 75 of this chapter, states can approve that only quality assured data from the CEMS shall be used to identify excess emissions under this subpart. Periods where the missing data substitution procedures in Subpart D of Part 75 are applied are to be reported as monitor downtime in the excess emissions and monitoring performance report required under §60.7(c).

(e) All required fuel flow rate, steam flow rate, temperature, pressure, and megawatt data must be reduced to hourly averages.

(f) calculate the hourly average NOx emission rates, in units of the emission standards under 560.4320, using either ppm for units complying with the concentration limit or the equations 1 (simple cycle turbines) or 2 (combined cycle turbines) listed in 560.4350, paragraph (f).

CUSA has proposed to monitor the NOx err~issions rate from the turbine with a CEMS. The CEMS system will be used to determine if, and when, any excess NOx emissions are released to the atmosphere. The CEMS is expected to be operated in accordance with the methods and procedures described above. The following condition will ensure compliance with the requirements of this section:

The CEMS data shall be reduced to hourly averages as specified in 40 CFR 60.1 3(h), or by other methods deemed equivalent by mutual agreement with the District, the ARB, and the EPA. [District Rule 1080 and 40 CFR 60.43503 Federally Enforceable Through Title V.Permit

Section 60.4355 - Parameter Monitoring Plan

This section set forth the requirements for operators that elect to continuously monitor parameters in lieu of installirrg a CEMS for NOx emissions. As discussed above, CUSA is proposirrg to install CEMS that will directly measure NOx emissions. Therefore, the requirements of this section are not applicable and no further discussion is required.

Sections 60.4360, 60.4365 and 60.4370 - Monitoring of Fuel Sulfur Content

Section 60.4360 states that an operator must monitor the total sulfur content of the fuel being fired in the turbine, except as provided in S60.4365. The sulfur content of the fuel must be determined using total sulfur methods described in 560.441 5. Alternatively, if the total sulfur content of the gaseous fuel during the most recent performance test was less than half the applicable limit, ASTM D4084, D4810, D5504, or D6228, or Gas Processors Association Standard 2377 (all of which are incorporated by reference, see §60.17), which measure the major sulfur compounds, may be used.

CUSA S-1129, #1101916

Section 60.4365 states that an operator may elect not to monitor the total sulfur content of the fuel combusted in the turbine, if the fuel is demonstrated not to exceed potential sulfur emissions of 26 ng SOY. (0.060 Ib S02IMMBtu) heat input for units located in continental areas and 180 ng SOY. (0.42 Ib S021MMBtu) heat input for units located in no continental areas or a continental area that the Administrator determines does not have access to natural gas and that the removal of sulfur compounds would cause more envirorlmental harm than benefit. You must use one of the following sources of information to make the required demonstration:

(a) The fuel quality characteristics in a current, valid purchase contract, tariff sheet or transportation contract for the fuel, specifying that the maximum total sulfur content for oil use in continental areas is 0.05 weight percent (500 ppmw) or less and 0.4 weight percent (4,000 ppmw) or less for no continental areas, the total sulfur content for natural gas use in continental areas is 20 grains of sulfur or less per 100 standard cubic feet and 140 grains of sulfur or less per 100 standard cubic feet for no continental areas, has potential sulfur emissions of less than less than 26 ng SOYJ (0.060 Ib S021MMBtu) heat input for continental areas and has potential sulfur emissions of less than less than 180 ng SOY. (0.42 Ib S021MMBtu) heat input for no continental areas; or

(b) Representative fuel sampling data which show that the sulfur content of the fuel does not exceed 26 ng SOY. (0.060 Ib S021MMBtu) heat input for continental areas or 180 ng SOYJ (0.42 Ib S021MMBtu) heat input for non-continental areas. At a minimum, the amount of fuel sampling data specified in section 2.3.1.4 or 2.3.2.4 of Appendix D to Part 75 of this chapter is required.

CUSA has proposed to use PUC regulated natural gas that may contain up to 1.0 grainS/700 scf. Primarily, the natural gas suppliers are able to provide a purchase contract, tariff sheet or transportation contract for the fuel that demonstrates compliance with this natural gas sulfur content limit. If the sulfur content information is not available from the gas supplier, then the permittee is required to test fuel sulfur content on weekly basis. Upon successful compliance demonstration on 8 week consecutive tests, the test frequency shall be reduced to every six months. If any six-month test shows noncon-lpliance with the sulfur content requirement, weekly testing will resume until eight consecutive weeks show compliance.

Section 60.4370 states that the frequency of determining the sulfur content of the fuel must be as follows:

(a) Fuel Oil: For fuel oil, use one of the total sulfur sampling options and the associated sampling frequency described in sections 2.2.3, 2.2.4.1, 2.2.4.2, and 2.2.4.3 of Appendix D to Part 75 of this chapter (i.e., flow proportional sampling, daily sampling, sampling from the unit's storage tank after each addition of fuel to the tank, or sampling each delivery prior to combining it with fuel oil already in the intended storage tank).

(b) Gaseous Fuel: If you elect not to demonstrate sulfur content using options in 560.4365, and the fuel is supplied without intermediate bulk storage, the sulfur content value of the gaseous fuel must be determined and recorded once per unit operating day.

CUSA S-1129. #1101916

(c) Custom Schedules: Notwithstanding the requirements of paragraph (b) of this section, operators or fuel vendors may develop custom schedules for determination of the total sulfur content of gaseous fuels, based on the design and operation of the affected facility and the characteristics of the fuel SI-~pply. Except as provided in paragraphs (c)(l) and (c)(2) of this section, custom schedules shall be substantiated with data and shall be approved by the Administrator before they can be used to comply with the standard in $60.4330.

The District and EPA have previously approved a custom monitoring schedule of at least one per week. Then, if compliance with the fuel sulfur content limit is demonstrated for eight consecutive weeks, the monitoring frequency shall be at least once every six months. If any six month monitoring period shows an exceedance, weekly monitoring shall resume. The following condition will ensure continued compliance with the requirements of this section:

If the gas turbine system is not fired on PUC-regulated natural gas, the sulfur content of each fuel source shall be tested weekly except that if compliance with the fuel sulfur content limit has been demonstrated for 8 consecutive weeks for a fuel source, then the testing frequency shall be quarterly. If a test shows noncompliance with the sulfur content requirement, the source must return to weekly testing until eight consecutive weeks show compliance. [District Rule 2210 and 40 CFR 60.4360, 60.4365(a) and 60.4370(c)] Federally Enforceable Through Title V Permit

Section 60.4380 - Excess NOx Emissions and Monitor Downtime

Section 60.4380 establishes reporting requirements for periods of excess emissions and monitor downtime. Paragraph (a) lists requirements for operators choosing to monitor parameters associated with water or steam to fuel ratios. As discussed above, CUSA is not proposing to monitor surrogate parameters associated with water or steam to fuel ratios to predict NOx emissions. Therefore, the requirements of ,this paragraph are not applicable and no further discussion is required.

Paragraph (b) states that for turbines using CEM's:

(1) An excess emissions is any unit operating period in which the 4-hour or 30-day rolling average NOx emission rate exceeds the applicable emission limit in $60.4320. For the purposes of this subpart, a "4-hour rolling average NOx emission rate" is the arithmetic average of the average NOx emission rate in ppm or ngIJ (IbIMWh) measured by the continuous emission monitoring equipment for a given hour and the three unit operating hour average NOx emission rates immediately preceding that unit operating hour. Calculate the rolling average if a valid NOx emission rate is obtained for at least 3 of the 4 hours. For the purposes of this subpart, a "30-day rolling average NOx emission rate" is the arithmetic average of all hourly NOx emission data in ppm or ngIJ (IbIMWh) measured by the continuous emission monitoring equipment for a given day and the 'twenty-nine unit operating days immediately preceding that unit operating day. A new 30-day average is calculated each unit operating day as the average of all hourly NOx emissions rates for the preceding 30 unit operating days if a valid NOx emission rate is obtained for at least 75 percent of all operating hours.

CUSA has proposed to emit less than or equal to 5.0 ppmvd NOx @ 15% 02 on 3-hour rolling average period. Except during startup, shutdown, and black start events, emissions in excess of these standards will constitute a violation of the permitted limits. These emissions standards

CUSA S-1129, #1101916

and the averaging period are more stringent that of the ones listed above in section 40 CFR 60.4380(b)(I). Therefore, compliance with this section will be assured by complying with the permitted limit.

(2) A period of monitor downtime is any unit operating hour.. in which the data for any of the following parameters are either missing or invalid: NOx concentration, C02 or 0 2 concentration, fuel flow rate, steam flow rate, steam temperature, steam pressure, or megawatts. The steam flow rate, steam temperature, and steam pressure are only required if you will use this information for compliance purposes. The following permit condition is placed to assure compliance with this section.

Monitor downtime for NOx shall be any unit operating hour in which sufficient data are not obtained to validate the hour for either NOx concentration or diluent 02 (or both). [40 CFR 60.4380(b)(2)] Federally Enforceable Through Title V Permit

(3) For operating periods during which multiple emissions standards apply, the applicable standard is the average of the applicable standards during each hour. For hours with multiple emissions standards, the applicable limit for that hour is determined based on the condition that corresponded to the highest emissions standard.

Paragraph (c) lists requirements for operators who choose to monitor combustion parameters that document proper operation of the NOx emission controls. CUSA is not proposing to monitor combustion parameters that document proper operation of the NOx emission controls. Therefore, the requirements of this paragraph are not applicable and no further discussion is required.

Section 60.4385 - Excess SOX Emissions and Monitoring Downtime

Section 60.4385 states that if an operator chooses the option to monitor the sulfur content of the fuel, excess emissions and monitoring downtime are defined as follows:

(a) For samples of gaseous fuel and for oil samples obtained using daily sampling, flow proportional sampling, or sampling from the unit's storage tank, an excess emission occurs each unit operating hour included in the period beginning on the date and hour of any sample for which the sulfur content of the fuel being fired in the combustion turbine exceeds the applicable limit and ending on the date and hour that a subsequent sample is taken that demonstrates compliance with the sulfur limit.

(b) If the option to sample each delivery of fuel oil has been selected, you must immediately switch to one of the other oil sampling options (Le., daily sampling, flow proportional sampling, or sampling from the unit's storage tank) if the sulfur content of a delivery exceeds 0.05 weight percent. You must continue to use one of the other sampling options until all of the oil from the delivery has been combusted, and you must evaluate excess emissions according to paragraph (a) of this section. When all of the fuel from the delivery has been burned, you may resume using the as-delivered sampling option.

(c) A period of monitor downtime begins when a required sarr~ple is not taken by its due date. A period of monitor downtime also begins on the date and hour of a required sample, if invalid

CUSA S-1129, #1101916

results are obtained. The period of monitor downtime ends on the date and hour of the next valid sample.

CUSA is expected to follow the definitions and procedures specified above for determinirrg periods of excess SOX emissions. Compliance is expected with this section.

Sections 60.4375 and 60.4395 - Reports Submittal

Section 60.4375(a) states that for each affected unit required to continuously monitor parameters or emissions, or to periodically determine the fuel,sulfur content under this subpart, you must submit reports of excess emissions and monitor downtime, in accordance with §60.7(c). Excess emissions must be reported for all periods of unit operation, including start- up, shutdown, and malfunction.

Section 60.4375(b) states that for each affected unit that performs annual performance tests in accordance with §60.4340(a), you must submit a written report of the results of each performance test before the close of business on the 60th day following the completion of the performance test.

Section 60.4395 states All reports required under §60.7(c) must be postmarked by the 30th day following the end of each 6-month period. CUSA is proposing to maintain records and submit reports in accordance with the requirements specified in these sections. The following condition will ensure compliance with the requirements of this section:

The owner or operator shall submit a written report of CEM operations for each calendar quarter to the District. The report is due on the 30th day following the end of the calendar quarter and shall include the following: Time intervals, data and magnitude of excess NOx emissions, nature and the cause of excess (if known), corrective actions taken and preventive measures adopted; Averaging period used for data reporting corresponding to the averaging period specified in the emission test period used to determine compliance with an emission standard; Applicable time and date of each period during which the CEM was inoperative, except for zero and span checks, and the nature of system repairs and adjustments; A negative declaration when no excess emissions occurred. [District Rule 1080 and 40 CFR 60.4375(a) and 60.43951 Federally Enforceable Through Title V Permit

Section 60.4400 - NOx Performance Testing .. .

Section 60.4400, paragraph (a) states that an operator must conduct an initial performance test, as required in 560.B. Subsequent NOx performance tests shall be conducted on an annual basis (no more than 14 calendar months following the previous performance test).

CUSA will be required to source test before the end of the commissioning period (i.e. 90 days of initial startup) and annually thereafter. They will be required to source test in accordance with the methods and procedures specified in paragraphs (I), (2), and (3). The following conditions will ensure compliance with the requirements of this section:

Source testing to determine compliance with the NOx, CO and NH3 emission rates (ppmvd @ 15% 02) during normal operation shall be conducted within 90 days of initial startup under this permit and annually thereafter. [District Rules 2201 and 4703, 40 CFR 60.4400(a)] Federally Enforceable Through Title V Permit

CUSA S-1129, #1101916

The following test methods shall be used: NOx - EPA Method 7E or 20 or CARB Method 100; CO - EPA Method 10 or 10B or CARB Method 100; VOC - EPA Method 18 or 25; PMl0 - EPA Method 5 (front half and back half) or 201 and 202a; ammonia - BAAQMD ST-1 B; and 02 - EPA Method 3, 3A, or 20 or CARB Method 100. EPA approved alternative test methods as approved by the District may also be used to address the source testing requirements of this permit. [District Rules 1081 ,

and 4703, and 40 CFR 60.4400(1 )(I)] Federally Enforceable Through Title V Permit

Section 60.4405 -Initial CEMS Relative Accuracy Testing

Section 60.4405 states that if you elect to install and certify a NOx-diluent CEMS, then the initial performance test required under s60.8 may be performed in the alternative manner described in paragraphs (a), (b), (c) and (d). CUSA has not indicated that they would like to perform the initial performance test of the CEMS using the alternative methods described in this section. Therefore, the requirements of this section are not applicable and no further discussion is required.

Section 60.4410 - Parameter Monitoring Ranges

Section 60.4410 sets forth requirements for operators that elect to monitor combustion parameters or parameters indicative of proper operation of NOx emission controls. As discussed above, CUSA is proposing to install a CEMS system to monitor the NOx emissions for the GTEs and is not proposing to monitor combustion parameters or parameters indicative of proper operation. Therefore, the requirements of this section are not applicable and no further discussion is required.

Section 60.4415 - SOX Performance Testing

Section 60.4415 states that an operator must conduct an initial performance test, as required in 560.B. Subsequent SO2 performance tests shall be conducted on an annual basis (no more than 14 calendar months following the previous performance test). There are three methodologies that you may use to conduct the performance tests.

(1) If you choose to periodically determine the sulfur content of the fuel combusted in the turbine, a representative fuel sample would be collected following ASTM 05287 (incorporated by reference, see s60.17) for natural gas or ASTM 04177 (incorporated by reference, see s60.17) for oil. Alternatively, for oil, you may follow the procedures for manual pipeline sampling in section 14 of ASTM 04057 (incorporated by reference, see s60.17). The fuel analyses of this section may be performed either by you, a service contractor retained by you, the fuel vendor, or any other qualified agency. Analyze the samples for the total sulfur content of the fuel using:

(i) For liquid fuels, ASTM 0129, or alternatively 01266, 01552, 02622, 04294, or 05453 (all of which are incorporated by reference, see s60.17); or

(ii) For gaseous fuels, ASTM 01072, or alternatively 03246, 04084, 04468, 04810, 06228, 06667, or Gas Processors Association Standard 2377 (all of which are incorporated by reference, see s60.17).

CUSA S-1129, #1101916

CUSA is expected to periodically determine the sulfur content of the fuel combusted in the turbine when valid purchase contracts, tariff sheets or transportation contract are not available. The sulfur content will be determined using the methods specified above. The following condition will ensure compliance with the requirements of this section:

If the gas turbine system is not fired on PUC-regulated or FERC-regulated natural gas, then a fuel sample shall be collected during the source test to determine sulfur content of the fuel combusted in the turbine. The fuel sample shall be analyzed for the total sulfur content using ASTM D 1072; D3246; D4084; D4468; D6228; or D6667; or double GC for H2S and mercaptans. The applicable ranges of some ASTM methods are not adequate to measure the levels of sulfur in some fuel gases. Dilution of samples before analysis (with verification of dilution ratio) may be used after getting a prior approval from the District. [40 CFR 60.4415(a)(l)(i)] Federally Enforceable Through Title V Permit

Methodologies (2) and (3) are applicable to operators that elect to measure the SO2 concentration in the exhaust stream. CUSA is not proposing to measure the SO2 in the exhaust stream of the turbine. Therefore,. the requirements of these methodologies are not applicable and no further discussion is required.

Compliance is expected with this Subpart.

Rule 4102 Nuisance

Section 4.0 prohibits discharge of air contaminants, which could cause injury, detriment, nuisance or annoyance to the public. Public nuisance conditions are not expected as a result of these operations, provided the equipment is well maintained. Therefore, compliance with this rule is expected. The following condition will be placed on each permit:

No air contaminant shall be released into the atmosphere, which causes a public nuisance. [District Rule 41 021

California Health & Safety Code 41700 (Health Risk Assessment)

District Policy APR 1905 - Risk Management Policy for Permitting New and Modified Sources specifies that for an increase in emissions associated with a proposed new source or modification, the District perform an analysis to determine the possible impact to the nearest resident or worksite.

An HRA is not required for a project with a total facility prioritization score of less than one. According to the Technical Services Memo for this project (Attachment VI), the total facility prioritization score including this project was greater than one. Therefore, a health risk assessment was required to determine the short-term acute and long-term chronic exposure from this project.

CUSA S-1129, #1101916

The cancer risk for this project is shown below:

The project is approvable without TBACT. However, the following condition is required.

HRA Summary

The exhaust stack shall vent vertically upward. The vertical exhaust flow shall not be impeded by a rain cap (flapper ok), roof overhang, or any other obstruction. [District Rule 41021

Rule 4201 Particulate Matter Concentration

T-BACT Required

No

Unit S-1129-867 and '-

868

Section 3.0 prohibits discharge of dust, fumes, or total particulate matter into the atmosphere 'from any single source operation in excess of 0.1 grain per dry standard cubic foot.

Cancer Risk

0.827 per million

The new gas turbines combust only natural gas and are expected to comply with the requirements of this Rule. Therefore, continued compliance is expected with this Rule.

Rule 4703 Stationary Gas Turbines

Section 2.0 of this rule states that the provisions of this rule apply to all stationary gas turbine systems, which are subject to District permitting requirements, and with ratings equal to or greater than 0.3 megawatt (MW) or a maximum heat input rating of more than 3 MMBtu per hour, except as provided in Section 4.0.

Each gas turbine is rated at heat input rate greater than 3 MMBtuIhour. Therefore, each turbine is subject to the requirements of this rule.

Section 5.1 - NOx Emission Requirements

Section 5.1.3, Table 5-3, Tier 3 NOx Compliance Limits, requires the owner or operator to achieve less than or equal to 5 ppmvd NOx @ 15% 0 2 to meet Tier-3 compliance schedule listed in Section 7.3.

Chevron has proposed to achieve Tier 3 NOx emission standards of 5 ppmvd NOx @ 15% 0 2

using SCR with ammonia injection systems. Therefore, compliance is expected with this section.

Section 5.2 - CO Emission Requirements

Section 5.2, Table 5-4, CO Compliance Limits, requires the Owner or operator to operate and maintain the gas turbine such that CO emissions must be less than 200 ppmvd @ 15% 02. Rule 4703 does not include a specific averaging period requirement for demonstrating compliance with the CO emission limit. The District practice is to require CO emissions compliance demonstration on 3-hour rolling average period.

CUSA S-1129, #1101916

Each turbine is restricted to emit less or equal to 200 ppmvd CO @ 15% O2 on 3-hour rolling average period. Thus, compliance is expected with this section.

Section 5.3 - Transitional Operation Periods

NOx and CO emission limits (listed above) shall not apply during a transitional operation period, which includes bypass transition period, primary re-ignition period, reduced load period, start-up or shutdown (each term is defined in Section 3.0 of Rule 4703), provided an operator shall meet the following conditions:

The duration of each startup or each shutdown shall not exceed two hours. For each bypass transition period, the requirements specified in Section 3.2 shall be met. For each primary re-ignition period, the requirements specified in Section 3.20 shall be met'. Each reduced load period shall not exceed one hour.

Chevron is expected to complete each startup or shutdown within two hours. However, under "black start", it may take them 4.0 hours to achieve the required NOx and CO emission limits. Chevron has provided a general overview of the "black start" procedure. The following conditions will be placed on each permit:

Except during black start, startup shall not exceed 2.0 hours per event. [District Rule 47031

Shutdown shall not exceed 2.0 hours per event. [District Rule 47031

A black start event is defined as the startup of a unit while the cogen plant is electrically separated from the utility grid. A black start shall not exceed 4.0 hours per event. [District Rules 2201 and 4703)

The emission control systems shall be in operation and emissions shall be minimized insofar as technologically feasible during startup and shutdown. [District Rule 47031

Start-up is defined as the period of time during which a unit is brought from a shutdown status to its operating temperature and pressure, including the time required by the unit's emission control system to reach full operation. [District Rule 47031

Shutdown is defined as the period of time during which a unit is taken from an operational to a non-operational status by allowing it to cool down from its operating temperature to ambient temperature as the fuel supply to the unit is completely turned off. [District Rule 47031

Reduced load period is defined as the time during which a gas turbine is operated at less than rated capacity in order to change the position of the exhaust gas diverter gate. Each reduced load period shall not exceed one hour. [District Rule 47031

Section 5.4 - BACT and Offsets Exemption

Section 5.4 states that "a replacement unit installed for the sole purpose of complying with the requirements of this rule shall be considered to be an emission control technique and may be exempt from the Best Available Control Technology (BACT) and Offsets requirements of District

1 This requirement is applicable to a gas turbine with dry low-NOx combustors. Each turbine under this project is equipped with water injection system. Thus, this requirement is not applicable to these units.

32

CUSA S-1129, #1101916

Rule 2201 (New and Modified Stationary Source'Review Rule) provided that all other requirements of Rule 2201 are met."

Therefore the proposed gas turbine systems are not subject to BACT and offsets.

Section 6.2 - Monitoring and Recordkeepinq

Section 6.2.1 requires the owner to operate and maintain continuous emissions monitoring equipment for NOx and oxygen, or install and maintain APCO-approved alternate monitoring.

Chevron has proposed to install a Continuous Emissions Monitoring System (CEMS) that will monitors NOx, CO and O2 in the exhaust gas. Therefore, the requirements of this section have been satisfied.

Section 6.2.2 specifies monitoring requirements for turbines without exhaust-gas NOx control devices. Each gas turbine will be equipped with an SCR system that is designed to control NOX emissions. Therefore, the requirements of this section are not applicable and no further discussion is required.

Section 6.2.3 requires that for units 10 MW and greater that operated an average of more than 4,000 hours per year over the last three years before August 18, 1994, the owner or operator shall monitor the exhaust gas NOx emissions. The section is not applicable, as each turbine engine is rated at less than 10 MW.

Section 6.2.4 requires the facility to maintain all records for a period of five years from the date of data entry and shall make such records available to the APCO upon request.

Chevron will be required to maintain all records for at least five years and make them available to the APCO upon request. The following condition will placed on each permit:

The owner or operator shall maintain all records of required monitoring data and support information for a period of five years from the date of data entry and shall make such records available to the District upon request. [District Rules 2201 and 47031

Section 6.2.5 requires that the owner or operator shall submit to the APCO, before issuance of the Permit to Operate, information correlating the control system operating to the associated measure NOx output. This information may be used by the APCO to determine compliance when there is no continuous emission monitoring system for NOx available or when the continuous emissions monitoring system is not operating properly. The following condition will be placed on the permit:

The owner or operator shall submit to the District information correlating the NOx control system operating parameters to the associated measured NOx output. The information must be sufficient to allow the District to determine compliance with the NOx emission limits of this permit when the CEMS is not operating properly. [District Rule 47031

Section 6.2.6 requires the owner or operator to maintain a stationary gas turbine system operating log that includes, on a daily basis, the actual local startup and stop time, length and reason for reduced load periods, total hours of operation, and the type and quantity of fuel used.

CUSA S-1129, #1101916

Section 6.2.7 requires the owner or operator shall maintain a stationary gas turbine system log for units exempt under Section 4.2 of this Rule. Chevron's gas turbine system is not exempt under Section 4.2 of this Rule. Therefore, no further discussion is required.

Section 6.2.8 requires the operator performing start-up or shutdown of a unit shall keep records of the duration of start-up or shutdown.

Chevron will be required to maintain records of the items listed in above applicable sections. The following conditions will be placed on each permit:

The owner or operator shall maintain a stationary gas turbine system operating log that includes, on a daily basis, the actual local startup and stop time, length and reason for reduced load periods, total hours of operation, the type and quantity of fuel used, duration of each start-up (or black start) and each shutdown time period. [District Rule 47031

Sections 6.3 and 6.4 - Compliance Testinq

Section 6.3.1 states that the owner or operator of any stationary gas turbine system subject to the provisions of Section 5.0 of this rule shall provide source test information annually regarding the exhaust gas NOx and CO concentrations.

CUSA has requested initial source testing within 90 days of initial startup which is longer than the standard District practice of source testing within 60 days of initial startup. It has been CUSA's experience in previous projects authorizing SCR that a 60-day commissioning period isn't always sufficient and has resulted in the need to pursue variances to allow for more time. -the District has approved the request as reflected in the following ATC condition:

Source testing to determine compliance with the NOx, CO and NH3 emission rates (ppmvd @ 15% 02) during normal operation shall be conducted within 90 days of initial startup under this permit and annually thereafter. [District Rules 2201 and 4703, CFR 60.335(a)]

Section 6.3.2 specifies source testing requirements for units operating less than 877 hours per year. As discussed above, each turbine system will be allowed to operate in excess of 877 hours per year. Therefore, the requirements of this section are not applicable and no further discussion is required.

Section 6.3.3 states .that units with intermittently operated auxiliary burners shall demonstrate compliance with the auxiliary burner in both "on" and "off' configurations. The following ATC condition reflects this requirement:

23. Unit shall demonstrate compliance annually with NOx and CO emissions limits with the duct burner in operation and not in operation. An annual demonstration of compliance with the duct burner in operation is not required in any year in which the duct burner is not operated at all in the preceding 12 months, in such case, the unit shall'be compliance source tested within 60 days of resumption of operation of the duct burner. An annual demonstration of compliance with the duct burner not in operation is not required in any year in which the duct burner operated continuously in conjunction with the turbine in the preceding 12 months, in such case, the unit shall be compliance source tested within 60 days of shutdown of operation of the duct burner. [District Rules 2201 and 47031 Y

CUSA S-1129, #1101916

Section .6.4 states that the facility must demonstrate compliance annually with the NOx and CO emission limits using the following test methods, unless otherwise approved by the APCO and EPA:

- Oxides of nitrogen emissions for compliance tests shall be determined by using EPA Method 7E or EPA Method 20.

- Carbon monoxide emissions for compliance tests shall be determined by using EPA Test Methods 10 or 106.

- Oxygen content of the exhaust gas shall be determined by using EPA Methods 3, 3A, or 20. - HHV and LHV of gaseous fuels shall be determined by using ASTM D3588-91, ASTM 1826-

88, or ASTM 1945-81.

The following condition will ensure continued compliance with the test method requirements of this section:

The following test methods shall be used: NOx - EPA Method 7E or 20 or CARB Method 100; CO - EPA Method 10 or l 0B or CARB Method 100; VOC - EPA Method 18 or 25; PMlO - EPA Method 5 (front half and back half) or 201 and 202a; ammonia - BAAQMD ST-1 B; and 0 2 - EPA Method 3,3A, or 20 or CARB Method 100. EPA approved alternative test methods as approved by the District may also be used to address the source testing requirements of this permit. [District Rules 1081 and 4703, 40 CFR 60.335(a), and 40 CFR 60.335(b)(l)]

Compliance is expected with this Rule.

Rule 4801 Sulfur Compounds

Section 3.1 states that a person shall not discharge into the atmosphere sulfur compounds, which would exist as a liquid or gas at standard conditions, exceeding a concentration of two- tenths (0.2) percent by volume calculated as sulfur dioxide (SO2) at the point of discharge on a dry basis averaged over 15 consecutive minutes.

For the proposed gaseous fuel combustion at a reference state of 60 OF, the Rule 4801 limit of 2,000 ppmvd is equivalent to:

(2000 ppmvd 8,578 dscf )(,, lb - SO,) [ MMBtu Ib - mol I b - SO, z 2.9

(379.5 dsCf )(lo6) MMBtu Ib - mol

Each of the permit units S-1129-868 and '-869 includes a SO, emission factor of 0.0023 IbIMMBtu. Since these emission factors are less than 2.9 Ib-SOxJMMBtu, compliance is expected with this Rule.

CUSA S-1129, # I 101 91 6

California Environmental Quality Act (CEQA)

The California Environmental Quality Act (CEQA) requires each public agency to adopt objectives, criteria, and specific procedures consistent with CEQA Statutes and the CEQA Guidelines for administering its responsibilities under CEQA, including the orderly evaluation of projects and preparation of environmental documents. The San Joaquin Valley Unified Air Pollution Control District (District) adopted its Environmental Review Guidelines (ERG) in 2001. The basic purposes of CEQA are to:

Inform governmental decision-makers and the public about the potential, significant environmental effects of proposed activities. Identify the ways that environmental damage can be avoided or significantly reduced. Prevent significant, avoidable damage to the environment by requiring changes in projects through the use of alternatives or mitigation measures when the governmental agency finds the chaqges to be feasible. Disclose to the public the reasons why a governmental agency approved'the project in the manner the agency chose if significant environmental effects are involved.

Greenhouse Gas (GHG) Significance Determination

It is determined that no other agency has or will prepare an environmental review document for the project. Thus the District is the Lead Agency for this project.

The District's erlgineering evaluation (this document Section VII Calculations) demonstrates that the project would not result in an increase in project specific greenhouse gas emissions. The District therefore concludes that the project would have a less than cumulatively significant impact on global climate change.

District CEQA Findings

'The District is the Lead Agency for this project because there is no other agency with broader statutory authority over this project. The District performed an Engineering Evaluation (this document) for the proposed project and determined that the activity will occur at an existing facility and the project involves negligible expansion of the existing use. Furthermore, the District determined that the activity will not have a significant effect on the environment. The District finds that the activity is categorically exempt from the provisions of CEQA pursuant to CEQA Guideline 5 15031 (Existing Facilities), and finds that the project is exempt per the general rule that CEQA applies only to projects which have the potential for causing a significant effect on the environment (CEQA Guidelines 51 5061 (b)(3)).

IX. RECOMMENDATION

Issue ATCs S-1129-868-0 and '-869-0 after addressing comments from EPA and the applicant. The draft ATCs are included in Attachment VII.

CUSA S-1129, #1101916

X. BILLING INFORMATION

Attachments

Permit # S-1129-868 and '-869

I: Current PTO(s) S-1129-47-11 through '-49-1 1 II: Location Map Ill: Preliminary diagrams of the proposed replacement cogens and CEMs IV: Manufacturer's Information on SCR V: Emissions Profiles VI: HRA and AAQlA Summary VI I: Draft ATCs

Fee Schedule 3020-08A D

Fee Description 5.285 MW

Annual Fee $3062.00

CUSA S-1129, #1101916

ATTACHMENT I Current PTO(s) S-1129-47-11 through '-49-1 1

San Joaquin Valley Air Pollution Control District

PERMIT UNIT: S-1129-47-11 EXPIRATION DATE: 02/28/2007

SECTION: 18 TOWNSHIP: 30s RANGE: 22E

EQUIPMENT DESCRIPTION: 3.5 MW GAS TURBINE ENGINE COGENERATION UNlT #I - MCKllTRlCK

PERMIT UNIT REQUIREMENTS 1. Units shall be fired exclusively on PUC-quality natural gas which has a sulfur content of less than or equal to 0.017%

by weight. [40 CFR 60.333(a) & (b);60.332(a); Kern County Rule 4071 Federally Enforceable Through Title V Permit

2. Operator shall not discharge into the atmosphere combustion contaminants (PM) exceeding in concentration at the point of discharge, 0.1 grldscf . [District Rule 4201; Kern County Rule 4041 Federally Enforceable Through Title V Permit

3. Operator shall be required to conform to the compliance testing procedures described in District Rule 1081. [District Rule 1081; Kern County Rule 108.11 Federally Enforceable Through Title V Permit

4. If the turbine is not fired on PUC-regulated natural gas, then the sulfur content of the natural gas being fired in the turbine shall be determined using ASTM method D 1072, D 303 1, D 4084, D 3246 or Double GC for H2S and Mercaptans. [40 CFR 60.335(d)] Federally Enforceable Through Title V Permit

5. If the turbine is not fired on PUC-regulated natural gas, the sulfur content of each fuel source shall be tested weekly except that if compliance with the fuel sulfur content limit has been demonstrated for 8 consecutive weeks for a fuel source, then the testing frequency shall be quarterly. If a test shows noncompliance with the sulfhi content requirement, the source must return to weekly testing until eight consecutive weeks show compliance. [40 CFR 60.334(b)(2)] Federally Enforceable Through Title V Permit

6. HHV and LHV of the fuel shall be determined using ASTM D3588, ASTM 1826, or ASTM 1945. [40 CFR 60.335(b) and District Rule 4703,6.4.5] Federally Enforceable Through Title V Permit

7. Nitrogen oxides (NOx) concentrations shall be determined using EPA Method 7E or 20, and oxygen (02) concentrations shall be determined using EPA Method 3,3A, or 20. [40 CFR 60.335(b) and District Rule 4703, 6.41 Federally Enforceable Through Title V Permit

8. The operator shall provide source test information annually regarding the exhaust gas NOx concentration corrected to 15% 0 2 (dry). [40 CFR 60.332(a), (b) and District Rule 4703; 5.11 Federally Enforceable Through Title V Permit

9. Unit shall demonstrate compliance annually with NOx and CO emissions limits with the duct burner in operation and not in operation. An annual demonstration of compliance with the duct burner in operation is not required in any year in which the duct burner is not operated at all in the preceding 12 months, in such case, the unit shall be compliance source tested within 60 days of resumption of operation of the duct burner. An annual demonstration of compliance with the duct burner not in operation is not required in any year in which the duct burner operated continuously in conjunction with the turbine in the preceding 12 months, in such case, the unit shall be compliance source tested within 60 days of shutdown of operation of the duct burner. [40 CFR 60.335(b) and District Rule 4703,6.3.2] Federally Enforceable Through Title V Permit

10. If the turbine is fired on PUC-regulated natural gas, then the operator shall maintain a log describing the source of natural gas and the quantity used. [District Rule 2520,9.3.2] Federally Enforceable Through Title V Permit

PERMIT UNlT REQUIREMENTS CONTINUE ON NEXT PAGE These terms and conditions are part of the Facility-wide Permit to Operate.

Facility Name: CHEVRON U S A INC Location: HEAVY OIL WESTERN,CA n . i i ~ ~ ( 7 . i i : M q n 2 o i o 11:14*Y - EWEW

Permit Unit Requirements for S-1129-47-11 (continued) Page 2 of 4

1 1. The operator of a stationary gas turbine system shall maintain all records of required monitoring data and support information for inspection at any time for a period of five years. [District Rule 2520,9.4.2] Federally Enforceable Through Title V Permit

12. Operator shall maintain a stationary gas turbine operating log that includes, on a daily basis, the actual local start-up and stop time, length and reason for reduced load periods, total hours of operation, source(s) of and quantity of fuel used, fuel sulfur content and fuel nitrogen content. [40 CFR 60.332(a),(b); District Rules 2520,9.3.2 and 4703,6.2.4] Federally Enforceable Through Title V Permit

13. The following types of units are not affected units subject to the requirements of the Acid Rain Program: 1) A simple combustion turbine that commenced operation before November 15, 1990,2) Any unit that, during 1985, did not serve a generator that produced electricity for sale and that did not, as of November 15, 1990, and does not currently, serve a generator that produces electricity for sale, 3) A cogeneration facility which for a unit that commenced construction prior to November 15, 1990, was constructed for the purpose of supplying equal to or less than one-third its potential electrical output capacity or equal to or less than 219,000 Mwe-hrs actual electric output on an annual basis to any utility power distribution system for sale. Therefore, the requirements of 40 CFR 72.6 do not apply to this source. A permit shield is granted fiom this requirement. [District Rule 2520, 13.21 Federally Enforceable Through Title V ,

Permit

14. Compliance with permit conditions in the Title V permit shall be deemed in compliance with the following applicable requirements: SJVUAPCD Rule 1081,4201,3.1; Rules 406 (Fresno), 407 (Kings, San Joaquin, Stanislaus, Tulare, Merced, and Kern), and 404(Madera); 40 CFR 60.332(c), (d); 60.334 (b), and (cX2); 60.335(d). A permit shield is granted fiom these requirements. [District Rule 2520, 13.21 Federally Enforceable Through Title V Permit

15. Compliance with permit conditions in the Title V permit shall be deemed compliance with the following subsumed requirements: SJVUAPCD Rule 4703,6.2.2; Rules 108 (Kings), 108.1 (Fresno, Merced, San Joaquin, Tulare, Kern and Stanislaus), and 1 10 (Madera); Rules 402 (Madera) and 404 (Fresno, Kern, Kings, San Joaquin, Merced, Stanislaus, Tulare); 40 CFR 60.332 (a) and (b); 60.333(a) and (b); 60.334 (a); (b), and (c)(l); 60.335 (a), (b), (c), and (e). A permit shield is granted from these requirements. [District Rule 2520, 13.21 Federally Enforceable Through Title V Permit

16. Compliance with the permit conditions in the Title V permit shall be deemed compliance with the following applicable requirements: SJVUAPCD Rule 4703, sections 5.0, 5.1.1, 6.2.1, 6.2.4, 6.3, 6.4.1,6.4.3,6.4.5,6.4.6. A permit shield is granted from these requirements. [District Rule 2520, 13.21 Federally Enforceable Through Title V Permit

17. Permittee shall install, operate and maintain in calibration a predictive emissions monitoring system which continuously measures and records the water-to-fuel ratio and which correlates the water-to-fuel ratio with the NOx concentration in the exhaust by using the method described in 40 CFR 60.335(c). [Rule 4703 and 40 CFR 60.3341 Federally Enforceable Through Title V Permit

18. Permittee shall submit to the APCO the information correlating the control system operating parameters to the associated measured NOx output. [District Rule 4703,6.2.5] Federally Enforceable Through Title V Permit

19. Permittee shall install, operate and maintain in calibration a system which continuously measures and records elapsed time of turbine operation. [40 CFR 60.334 and District Rule 4703,6.2.1] Federally Enforceable Through Title V Permit

20. Permittee shall submit an excess emissions and monitoring systems performance report (excess emissions are defined in applicable subparts) andlor a summary report form to the APCO semiannually, except when more frequent reporting is specifically required by an applicable subpart. All reports shall be postmarked by the 30th day of each calendar half (or quarter, as appropriate). [40 CFR 60.7(c)] Federally Enforceable Through Title V Permit

21. Any one-hour period during which the average water-to-fuel ratio, as measured by the continuous monitoring system, falls below the water-to-fuel ratio determined to demonstrate NSPS NOx compliance shall be reported to the APCO. Each report shall include the average water-to-fuel ratio, average fuel consumption, ambient conditions, turbine gas load and nitrogen content of the fuel during the period of excess emissions. [40 CFR 60.334(c)] Federally Enforceable Through Title V Permit

PERMIT UNIT REQUIREMENTS CONTINUE ON NEXT PAGE These terms and conditions are part of the Facility-wide Permit to Operate.

Facility Name: CHEVRON U S A INC Location: HEAVY OIL WESTERN,CA S l l ~ l . 1 1 : Mw P 2010 11:14AU - EffimlLR

Permit Unit Requirements for S-1129-47-11 (continued) Page 3 of 4

22. Cogeneration unit includes 48.7 MMBtuIhr (nominal rating) Allison, model 501-KB-5, gas fired turbine engine with either pilotless he1 nozzles or conventional fuel nozzles and 20.0 MMBtu/hr (nominal rating) gas fired Fomey duct burner. [District NSR Rule] Federally Enforceable Through Title V Permit

23. Cogeneration unit includes Ideal synchronous electrical generator, Struthers-Wells unfired 22.5 MMBtu/hr steam generator, and an inlet air evaporative cooler. [District NSR Rule] Federally Enforceable Through Title V Permit

24. Turbine lube oil tank shall vent only through CECO Model #SITOR-I0 fiber bed filter system. [District NSR Rule] Federally Enforceable Through Title V Permit

25. Fuel gas sulfur content shall not exceed 14 ppmv as hydrogen sulfide (H2S). [District NSR Rule] Federally Enforceable Through Title V Permit

26. Permittee shall notify the District by fax or in writing prior to or within 4 hours of any turbine nozzle replacement, except for identical replacement. [District NSR Rule] Federally Enforceable Through Title V Permit

27. Except during periods of startuplshutdown, emission rates (3hr average) shall not exceed: PMIO: 0.61 Ibhr; SOX (as S02): 0.16 I b h ; NOx (as N02): 30 ppmvd @ 15% 02; VOC: 1.65 Iblhr; and CO: 29 ppmvd @ 15% 02. [District NSR Rule] Federally Enforceable Through Title V Permit

28. NOx (as N02) and SOX (as S02) emission rates (1 hr average) shall not exceed NSPS standard of 150 ppmv-dry @ 15% 02 , and 150 ppmv-dry @ 15% 02 , respectively. [District Rule 2520,9.3.2; 40 CFR 60.332(c) and 40 CFR 60.333(a)] Federally Enforceable Through Title V Permit

29. Emissions shall not exceed the following: PM10: 14.6 Iblday; SOX (as S02): 3.8 Iblday; NOx (as N02): 182.4 Iblday; VOC: 39.6 Iblday; and CO: 107.8 Iblday. [District NSR Rule] Federally Enforceable Through Title V Permit

30. During days of gas turbine startuplshutdown, permittee shall maintain accurate daily records of natural gas consumption in gas turbine for normal operation and startup1shutdown periods. [District NSR Rule] Federally Enforceable Through Title V Permit

3 1. Generator gearbox lube oil tank shall vent only through CECO Model #SITOR-1 0 fiber bed filter system. [District NSR Rule] Federally Enforceable Through Title V Permit

32. Gas turbine engine shall be equipped with continuously recording k e l gas flow rate monitor. [District NSR Rule] Federally Enforceable Through Title V Permit

33. Gas turbine engine shall be equipped with operational water injection system for NOx control. [District NSR Rule] Federally Enforceable Through Title V Permit

34. Gas turbine engine shall be equipped with continuously recording water injection rate monitor accurate to within 5%. [District NSR Rule] Federally Enforceable Through Title V Permit

35. Waste heat recovery steam generator exhaust shall be equipped with permanent provisions to allow collection of gas samples consistent with EPA methods. [District NSR Rule] Federally Enforceable Through Title V Permit

36. Gas turbine shall be fired exclusively with PUC quality natural gas or equivalent. [District NSR Rule] Federally Enforceable Through Title V Permit

37. Gas turbine engine water injection rate shall be maintained at a water to fuel ratio no less than 0.4811.0 by weight while operating with pilotless fuel nozzles and no less than 0.811.0 by weight while operating with conventional fuel nozzles. [District NSR Rule] Federally Enforceable Through Title V Permit

38. Maximum emission rate of volatile organic compounds (VOC's) from turbine lube oil vent shall not exceed 0.02 lbhr. [District NSR Rule] Federally Enforceable Through Title V Permit

39. Compliance testing of lube oil vent and gearbox vent shall be required if monthly visible emissions checks from either vent exceeds 5% opacity or equivalent Ringelmann 114. If visible emissions are observed, corrective action shall be taken to eliminate visible emissions. If visible emissions cannot be corrected within 24 hours, a visible emissions test using EPA Method 9 shall be conducted. [District Rules 2520,9.3.2 and NSR] Federally Enforceable Through Title V Permit

PERMIT UNIT REQUIREMENTS CONTINUE ON NEXT PAGE These terms and conditions are part of the Facility-wide Permit to Operate.

Facillty Name: CHEVRON U S A INC Location: HEAVY OIL WESTERN.CA 8-lcm.4~.cr: u~natolr:trm-mw~

Permit Unit Requirements for S-1129-47-11 (continued) Page 4 of 4

40. Thermal stabilization period shall be defined as the start-up or shutdown time necessary to bring the heat recovery steam generator to proper temperature, not exceeding two hours. [District NSR Rule] Federally Enforceable Through Title V Permit

41. Startup and shutdown of gas turbine engine, as defined in 40 CFR Subpart A 60.2, shall not exceed a time period of two hours and two hours, respectively, per occurrence. [40 CFR Subpart A 60.2, District NSR Rule] Federally Enforceable Through Title V Permit

42. Permittee shall keep accurate records of fuel sulfur content, and such records shall be made available for District inspection for five years. [40 CFR 60.334(b)(2), District Rule 2520,9.3.2] Federally Enforceable Through Title V Permit

43. Annual compliance with GTEIduct burner NOx and CO emission limits (pursuant to ~ u l e 4703 (10/16/97)) and fuel sulfur limit shall be demonstrated by District witnessed or authorized sample collection by independent laboratory. Test results shall be submitted within 60 days. [District NSR Rule and Rule 47031 Federally Enforceable Through Title V Permit

44. The following test methods shall be used: CO (ppmv) - EPA Method 10 or l0B. [District Rules 2520,9.3.2 and 47031 Federally Enforceable Through Title V Permit

These terms and conditions are part of the Facility-wide Permit to Operate. Facility Name: CHEVRON U S A INC Locatlon: HEAW OIL WESTERN,CA Sll2947.11: M a y P 1 O I O 11:!4AJA-EffiEneA

San Joaquin Valley Air Pollution Control District

PERMIT UNIT: S-1129-48-11

SECTION: 18 TOWNSHIP: 30s RANGE: 22E

EQUIPMENT DESCRIPTION: 3.5 MW GAS TURBINE ENGINE COGENERATION UNlT #2 - MCKllTRlCK

PERMIT UNlT REQUIREMENTS

EXPIRATION DATE: 02/28/2007

I . Units shall be fired exclusively on PUC-quality natural gas which has a sulfur content of less than or equal to 0.01 7% by weight. [40 CFR 60.333(a) & (b);60.332(a); Kern County Rule 4071 Federally Enforceable Through Title V Permit

2. Operator shall not discharge into the atmosphere combustion contaminants (PM) exceeding in concentration at the point of discharge, 0.1 gddscf . [District Rule 4201; Kern County' Rule 4041 Federally Enforceable Through Title V Permit

3. Operator shall be required to.conform to the compliance testing procedures described in District Rule 108 1. [District Rule 108 1 ; Kern County Rule 108.11 Federally Enforceable Through Title V Permit

4. If the turbine is not fired on PUC-regulated natural gas, then the sulfur content of the natural gas being fired in the turbine shall be determined using ASTM method D 1072, D 303 1, D 4084, D 3246 or Double GC for H2S and Mercaptans. [40 CFR 60.335(d)] Federally Enforceable Through Title V Permit

5. If the turbine is not fired on PUC-regulated natural gas, the sulfur content of each fuel source shall be tested weekly except that if compliance with the fuel sulfur content limit has been demonstrated for 8 consecutive weeks for a fuel source, then the testing frequency shall be quarterly. If atest shows noncompliance with the sulfur content requirement, the source must return to weekly testing until eight consecutive weeks show compliance. [40 CFR 60.334(b)(2)] Federally Enforceable Through Title V Permit

6. HHV and LHV of the fuel shall be determined using ASTM D3588, ASTM 1826, or ASTM 1945. [40 CFR 60.335(b) and District Rule 4703,6.4.5] Federally Enforceable Through Title V Permit

7. Nitrogen oxides (NOx) concentrations shall be determined using EPA Method 7E or 20, and oxygen (02) concentrations shall be determined using EPA Method 3,3A, or 20. [40 CFR 60.335(b) and District Rule 4703,6.4] Federally Enforceable Through Title V Permit

8. The operator shall provide source test information annually regarding the exhaust gas NOx concentration corrected to 15% 0 2 (dry). [40 CFR 60.332(a), (b) and District Rule 4703,5.1] Federally Enforceable Through Title V Permit

9. Unit shall demonstrate compliance annually with NOx and CO emissions limits with the duct burner in operation and not in operation. An annual demonstration of compliance with the duct burner in operation is not required in any year in which the duct burner is not operated at all in the preceding 12 months, in such case, the unit shall be compliance source tested within 60 days of resumption of operation of the duct burner. An annual demonstration of compliance with the duct burner not in operation is not required in any year in which the duct burner operated continuously in conjunction with the turbine in the preceding 12 months, in such case, the unit shall be compliance source tested within 60 days of shutdown of operation of the duct burner. [40 CFR 60.335(b) and District Rule 4703,6.3.2] Federally Enforceable Through Title V Permit

10. If the turbine is fired on PUC-regulated natural gas, then the operator shall maintain a log describing the source of natural gas and the quantity used. [District Rule 2520,9.3.2] Federally Enforceable Through Title V Permit

PERMIT UNlT REQUIREMENTS CONTINUE ON NEXT PAGE These terms and conditions are part of the Facility-wide Permit to Operate.

Facility Name: CHEVRON U S A INC Location: HEAVY OIL WESTERN,CA kll2Me-11: M p y P l O l O lI:l4AM-EDOEnlLR

Permit Unit Requirements for S-1129-48-11 (continued) Page 2 of 4

1 1. The operator of a stationary gas turbine system shall maintain all records of required monitoring data and support information for inspection at any time for a period of five years. [District Rule 2520,9.4.2] Federally Enforceable Through Title V Permit

12. Operator shall maintain a stationary gas turbine operating log that includes, on a daily basis, the actual local start-up and stop time, length and reason for reduced load periods, total hours of operation, source(s) of and quantity of fuel used, fuel sulfur content and fuel nitrogen content. [40 CFR 60.332(a),(b); District Rules 2520,9.3.2 and 4703, 6.2.41 Federally Enforceable Through Title V Permit

13. The following types of units are not affected units subject to the requirements of the Acid Rain Program: 1) A simple combustion turbine that commenced operation before November 15, 1990,2) Any unit that, during 1985, did not serve a generator that produced electricity for sale and that did not, as of November 15, 1990, and does not currently, serve a generator that produces electricity for sale, 3) A cogeneration facility which for a unit that commenced construction prior to November 15, 1990, was constructed for the purpose of supplying equal to or less than one-third its potential electrical output capacity or equal to or less than 219,000 Mwe-hrs actual electric output on an annual basis to any utility power distribution system for sale. Therefore, the requirements of 40 CFR 72.6 do not apply to this source. A permit shield is granted fiom this requirement. [District Rule 2520, 13.21 Federally Enforceable Through Title V Permit

14. Compliance with permit conditions in the Title V permit shall be deemed in compliance with the following applicable requirements: SJVUAPCD Rule 1081,4201, 3.1; Rules 406 (Fresno), 407 (Kings, San Joaquin, Stanislaus, Tulare, Merced, and Kern), and 404(Madera); 40 CFR 60.332(c), (d); 60.334 (b), and (c)(2); 60.335(d). A permit shield is granted from these requirements. [District Rule 2520, 13.21 Federally Enforceable Through Title V Permit

15. Compliance with permit conditions in the Title V permit shall be deemed compliance with the following subsumed requirements: SJVUAPCD Rule 4703, 6.2.2; Rules 108 (Kings), 108.1 (Fresno, Merced, San Joaquin, Tulare, Kern and Stanislaus), and 1 10 (Madera); Rules 402 (Madera) and 404 (Fresno, Kern, Kings, San Joaquin, Merced, Stanislaus, Tulare); 40 CFR 60.332 (a) and (b); 60.333(a) and (b); 60.334 (a), (b), and (c)(l); 60.335 (a), (b), (c), and (e). A permit shield is granted from these requirements. [District Rule 2520, 13.21 Federally Enforceable Through Title V Permit

16. Compliance with the permit conditions in the Title V permit shall be deemed compliance with the following applicable requirements: SJVUAPCD Rule 4703, sections 5.0, 5.1.1,6.2.1, 6.2.4,6.3, 6.4.1,6.4.3, 6.4.5, 6.4.6. A permit shield is granted from these requirements. [District Rule 2520, 13.21 Federally Enforceable Through Title V Permit

17. Permittee shall install, operate and maintain in calibration a predictive emissions monitoring system which continuously measures and records the water-to-fuel ratio and which correlates the water-to-fuel ratio with the NOx concentration in the exhaust by using the method described in 40 CFR 60.335(c). p u l e 4703 and 40 CFR 60.3341 Federally Enforceable Through Title V Permit

18. Permittee shall submit to the APCO the information correlating the control system operating parameters to the associated measured NOx output. [District Rule 4703,6.2.5] Federally Enforceable Through Title V Permit '

19. Permittee shall install, operate and maintain in calibration a system which continuously measures and records elapsed time of turbine operation. [40 CFR 60.334 and District Rule 4703,6.2.1] Federally Enforceable Through Title V Permit

20. Permittee shall submit an excess emissions and monitoring systems performance report (excess emissions are defined in applicable subparts) and/or a summary report form to the APCO semiannually, except when more frequent reporting is specifically required by an applicable subpart. All reports shall be postmarked by the 30th day of each calendar half (or quarter, as appropriate). [40 CFR 60.7(c)] Federally Enforceable Through Title V Permit

2 1. Any one-hour period during which the average water-to-fuel ratio, as measured by the continuous monitoring system, falls below the water-to-fuel ratio determined to demonstrate NSPS NOx cgmpliance shall be reported to the APCO. Each report shall include the average water-to-fuel ratio, average fuel consumption, ambient conditions, turbine gas

! load and nitrogen content of the fuel during the period of excess emissions. [40 CFR 60.334(c)] Federally Enforceable Through Title V Permit

PERMIT UNIT REQUIREMENTS CONTINUE ON NEXT PAGE These terms and conditions are part of the Facility-wide Permit to Operate.

Fadllty Name: CHEVRON U S A INC Location: HEAW OIL WESTERN,CA Bll2S4bll: Y~~lOlO11:lW-EDGEHIU

Permit Unit Requirements for S-112948-11 (continued) Page 3 of 4

22. Cogeneration unit includes 48.7 MMBtuIhr Allison (nominal rating), model 501-KB-5, gas fired turbine engine with either pilotless fuel nozzles or conventional fuel nozzles and 20.0 MMBtu/hr (nominal rating) gas fired Forney duct burner. [District NSR Rule] Federally Enforceable Through Title V Permit

23. Cogeneration unit includes Ideal synchronous electrical generator, Struthers-Wells unfired 22.5 MMBtu/hr steam generator, and an inlet air evaporative cooler. [District NSR Rule] Federally Enforceable Through Title V Permit

24. Turbine lube oil tank shall vent only through CECO Model #STTOR-10 fiber bed filter system. [District NSR Rule] Federally Enforceable Through Title V Permit

25. Fuel gas sulfur content shall not exceed 14 ppmv as hydrogen sulfide (H2S). [District NSR Rule] Federally Enforceable Through Title V Permit

26. Permittee shall notify the District by fax or in writing prior to or within 4 hours of any turbine nozzle replacement, except for identical replacement. [District NSR Rule] Federally Enforceable Through Title V Permit

27. Except during periods of startuplshutdown, emission rates (3 hr average) shall not exceed: PM10: 0.61 Iblhr; SOX (as S02): 0.16 I b h , NOx (as N02): 30 ppmvd @ 15% 02; VOC: 1.65 Ibihr; and CO: 29 ppmvd @ 15% 02. [District NSR Rule] Federally Enforceable Through Title V Permit

28. NOx (as N02) and SOX (as S02) emission rates (1 hr average) shall not exceed standard of 150 ppmv-dry @ 15% 02, and 150 ppmvdry @ 15% 02 , respectively. [District Rule 2520,9.3.2; 40 CFR 60.332(c) and 40 CFR 60.333(a)] Federally Enforceable Through Title V Permit

29. Emissions shall not exceed the following: PMIO: 14.6 lblday; SOX (as S02): 3.8 lblday; NOx (as N02): 182.4 Iblday; VOC: 39.6 lblday; and CO: 107.8 lblday. [District NSR Rule] Federally Enforceable Through Title V perkit

30. During days of gas turbine startuplshutdown, permittee shall maintain accurate daily records of natural gas consumption in gas turbine for normal operation and startuplshutdown periods. [District NSR Rule] Federally Enforceable Through Title V Permit

3 1. Generator gearbox lube oil tank shall vent only through CECO Model #STTOR- 10 fiber bed filter system. [District NSR Rule] Federally Enforceable Through Title V Permit

32. Gas turbine engine shall be equipped with continuously'recording fuel gas flow rate monitor. [District NSR Rule] Federally Enforceable Through Title V Permit

33. Gas turbine engine shall be equipped with operational water injection system for NOx control. [District NSR Rule] Federally Enforceable Through Title V Permit

34. Gas turbine engine shall be equipped with continuously recording water injection rate monitor accurate to within 5%. [District NSR Rule] Federally Enforceable Through Title V Permit

35. Waste heat recovery steam generator exhaust shall be equipped with permanent provisions to allow collection of gas samples consistent with EPA methods. [District NSR Rule] Federally Enforceable Through Title V Permit

36. Gas turbine shall be fired exclusively with PUC quality natural gas or equivalent. [District NSR Rule] Federally Enforceable Through Title V Permit

37. Gas turbine engine water injection rate shall be maintained at a water to fuel ratio no less than 0.4811.0 by weight while operating with pilotless fuel nozzles and no less than 0.811.0 by weight while operating with conventional fuel nozzles. [District NSR Rule] Federally Enforceable Through Title V Permit

38. Maximum emission rate of volatile organic compounds (VOC's) from turbine lube oil vent shall not exceed 0.02 Ibihr. [District NSR Rule] Federally Enforceable Through Title V Permit

39. Compliance testing of lube oil vent and gearbox vent shall be required if monthly visible emissions checks from either vent exceeds 5% opacity or equivalent Ringelmann 114. If visible emissions are observed, corrective action shall be taken to eliminate visible emissions. If visible emissions cannot be corrected within 24 hours, a visible emissions test using EPA Method 9 shall be conducted. [District Rules 2520,9.3.2 and NSR] Federally Enforceable Through Title V Permit

PERMIT UNIT REQUIREMENTS CONTINUE ON NEXT PAGE These terms and conditions are part of the Facility-wide Permit to Operate.

Facility Name: CHEVRON U S A INC LocaUon: HEAVY OIL WESTERN,CA 5-112a4bll : Mw212010~1:l~-EWEllW

Permit Unit Requirements for S-1129-46-11 (continued) Page 4 of 4

40. Thermal stabilization period shall be defined as the start-up or shutdown time necessary to bring the heat recovery steam generator to proper temperature, not exceeding two hours. [District NSR Rule] Federally Enforceable Through Title V Permit

41. Startup andshutdown of gas turbine, engine, as defined'in 40 CFR Subpart A 60.2, shall not exceed a time perlbd of two hours and two hours, respectively, per occurrence. [40 CFR Subpart A 60.2, District NSR Rule] Federally Enforceable Through Title V Permit

42. Permittee shall keep accurate records of fuel sulfur content, and such records shall be made available for District inspection for five years. [40 CFR 60.334(b)(2), District Rule 2520,9.3.2] Federally Enforceable Through Title V Permit

43. Annual compliance with GTWduct burner NOx and CO emission limits (pursuant to Rule 4703 (10116197)) and fuel sulfur limit shall be demonstrated by District witnessed or authorized sample collection by independent laboratory. Test results shall be submitted within 60 days. [District NSR Rule and Rule 47031 Federally Enforceable Through Title V Permit

44. The following test methods shall be used: CO (ppmv) - EPAMethod 10 or l0B. [District Rules 2520,9.3.2 and 47031 Federally Enforceable Through Title V Permit

These terms and conditions are part of the Facility-wide Permit to Operate. Facility Name: CHEVRON U S A INC Location: HEAW OIL WESTERN,CA 6112WB.11: May222010 11:14M-EDQEnlLR

San Joaquin Valley Air Pollution Control District

PERMIT UNIT: S-1129-49-11 EXPIRATION DATE: 02/26/2007

SECTION: 18 TOWNSHIP: 30s RANGE: 22E

EQUIPMENT DESCRIPTION: 3.5 MW GAS TURBINE ENGINE COGENERATION UNlT #3 - MCKllTRlCK

PERMIT UNIT REQUIREMENTS 1. Units shall be fired exclusively on PUC-quality natural gas which has a sulfur content of less than or equal to 0.017%

by weight. [40 CFR 60.333(a) & (b);60.332(a); Kern County Rule 4071 Federally Enforceable Through Title V Permit

2. Operator shall not discharge into the atmosphere combustion contaminants (PM) exceeding in concentration at the point of discharge, 0.1 grldscf . [District Rule 4201; Kern County Rule 4041 Federally Enforceable Through Title V Permit

3. Operator shall be required to conform to the compliance testing procedures described in District Rule 108 1. [District Rule 1081; Kern County Rule 108.11 Federally Enforceable Through Title V Permit

4. If the turbine is not fired on PUC-regulated natural gas, then the sulfur content of the natural gas being fired in the turbine shall be determined using ASTM method D 1072, D 303 1, D 4084, D 3246 or Double GC for H2S and Mercaptans. [40 CFR 60.335(d)] Federally Enforceable Through Title V Permit

5. If the turbine is not fired on PUC-regulated natural gas, the sulfur content of each fie1 source shall be tested weekly except that if compliance with the fuel sulfur content limit has been demonstrated for 8 consecutive weeks for a fuel source, then the testing frequency shall be quarterly. If a test shows noncompliance with the sulfur content requirement, the source must return to weekly testing until eight consecutive weeks show compliance. [40 CFR 60.334(b)(2)] Federally Enforceable Through Title V Permit

6. HHV and LHV of the fuel shall be determined using ASTM D3588, ASTM 1826, or ASTM 1945. [40 CFR 60.335@) and District Rule 4703,6.4.5] Federally Enforceable Through Title V Permit

7. Nitrogen oxides @Ox) concentrations shall be determined using EPA ~ e t h o d 7E or 20, and oxygen (02) concentrations shall be determined using EPA Method 3,3A, or 20. [40 CFR 60.335(b) and District Rule 4703, 6.41 Federally Enforceable Through Title V Permit

8. The operator shall provide source test information annually regarding the exhaust gas NOx concentration corrected to 15% 0 2 (dry). [40 CFR 60.332(a), (b) and District Rule 4703, 5.11 Federally Enforceable Through Title V Permit

9. Unit shall demonstrate compliance annually with NOx and CO emissions limits with the duct burner in operation and not in operation. An annual demonstration of compliance with the duct burner in operation is not required in any year I

in which the duct burner is not operated at all in the preceding 12 months, in such case, the unit shall be compliance source tested within 60 days of resumption of operation of the duct burner. An annual demonstration of compliance with the duct burner not in operation is not required in any year in which the duct burner operated continuously in conjunction with the turbine in the preceding 12 months, in such case, the unit shall be compliance source tested within 60 days of shutdown of operation of the duct burner. [40 CFR 60.335@) and District Rule 4703,6.3.2] Federally Enforceable Through Title V Permit

10. If the turbine is fired on PUC-regulated natural gas, then the operator shall maintain a log describing the source of natural gas and the quantity used. [District Rule 2520,9.3.2] Federally Enforceable Through Title V Permit

I

PERMIT UNlT REQUIREMENTS CONTINUE ON NEXT PAGE These t e n s and conditions are part of the Facility-wide Permit to Operate.

Facllity Name: CHEVRON U S A INC LocaUon: HEAW OIL WESTERN,CA 6111WBll ' M q ~ 1 0 1 0 I % l 4 * M - E D G E H l L R

Permit Unit Requirements for S-1129-49-11 (continued) Page 2 of 4

1 1. The operator of a stationary gas turbine system shall maintain all records of required monitoring data and support information for inspection at any time for a period of five years. [District Rule 2520,9.4.2] Federally Enforceable Through Title V Permit

12. Operator shall maintain a stationary gas turbine operating log that includes, on a daily basis, the actual local start-up and stop time, length and reason for reduced load periods, total hours of operation, source(s) of and quantity of fuel used, fuel sulfur content and fuel nitrogen content. [40 CFR 60.332(a),(b); District Rules 2520,9.3.2 and 4703,6.2.4] Federally Enforceable Through Title V Permit

13. The following types of units are not affected units subject to the requirements of the Acid Rain Program: 1) A simple combustion turbine that commenced operation before November 15, 1990,2) Any unit that, during 1985, did not serve a generator that produced electricity for sale and that did not, as of November 15, 1990, and does not currently, serve a generator that produces electricity for sale, 3) A cogeneration facility which for a unit that commenced construction prior to November 15, 1990, was constructed for the purpose of supplying equal to or less than one-third its potential electrical output capacity or equal to or less than 219,000 Mwe-hrs actual electric output on an annual basis to any utility power distribution system for sale. Therefore, the requirements of 40 CFR 72.6 do not apply to this source. A permit shield is granted from this requirement. [District Rule 2520, 13.21 Federally Enforceable Through Title V Permit

14. Compliance with permit conditions in the Title V permit shall be deemed. in compliance with the following applicable requirements: SJVUAPCD Rule 108 1,4201,3.1; Rules 406 (Fresno), 407 (Kings, San Joaquin, Stanislaus, Tulare, Merced, and Kern), and 404(Madera); 40 CFR 60.332(c), (d); 60.334 (b), and (cX2); 60.335(d). A permit shield is granted from these requirements. [District Rule 2520, 13.21 Federally Enforceable Through Title V Permit

15. Compliance with permit conditions in the Title V permit shall be deemed compliance with the following subsumed requirements: SJVUAPCD Rule 4703,6.2.2; Rules 108 (Kings), 108.1 (Fresno, Merced, San Joaquin, Tulare, Kern and Stanislaus), and 110 (Madera); Rules 402 (Madera) and 404 (Fresno, Kern, Kings, San Joaquin, Merced, Stanislaus, Tulare); 40 CFR 60.332 (a) and (b); 60.333(a) and (b); 60.334 (a), (b), and (c)(l); 60.335 (a), (b), (c), and (e). A permit shield is granted from these requirements. [District Rule 2520, 13.21 Federally Enforceable Through Title V Permit

16. Compliance with the permit conditions in the Title V permit shall be deemed compliance with the following applicable requirements: SJVUAPCD Rule 4703, sections 5.0, 5. I . 1,6.2.1, 6.2.4,6.3, 6.4.1,6.4.3,6.4.5,6.4.6. A permit shield is granted from these requirements. [District Rule 2520, 13.21 Federally Enforceable Through Title V Permit

17. Permittee shall install, operate and maintain in,calibration a predictive emissions monitoring system which continuously measures and records the water-to-fuel ratio and which correlates the water-to-fuel ratio with the NOx concentration in the exhaust by using the method described in 40 CFR 60.335(c). [Rule 4703 and 40 CFR 60.3341 Federally Enforceable Through Title V Permit

18. Permittee shall submit to the APCO the information correlating the control system operating parameters to the associated measured NOx output. [District Rule 4703,6.2.5] Federally Enforceable Through Title V Permit

19. Permittee shall install, operate and maintain in calibration a system which continuously measures and records elapsed time of turbine operation. [40 CFR 60.334 and District Rule 4703,6.2.1] Federally Enforceable Through Title V Permit

20. Permittee shall submit an excess emissions and monitoring systems performance report (excess emissions are defined in applicable subparts) andlor a summary report form to the APCO semiannually, except when more frequent reporting is specifically required by an applicable subpart. All reports shall be postmarked by the 30th day of each calendar half (or quarter, as appropriate). [40 CFR 60.7(c)] Federally Enforceable Through Title V Permit

2 1. Any one-hour period during which the average water-to-fuel ratio, as measured by the continuous monitoring system, falls below the water-to-fuel ratio determined to demonstrate NSPS NOx compliance shall be reported to the APCO. Each report shall include the average water-to-fuel ratio, average fuel consumption, ambient conditions, turbine gas load and nitrogen content of the fuel during the period of excess emissions. [40 CFR 60.334(c)] Federally Enforceable Through Title V Permit

PERMIT UNIT REQUIREMENTS CONTINUE ON NEXT PAGE These terms and conditions are part of the Facility-wide Permit to Operate.

Fadlity Name: CHEVRON U S A INC Location: HEAW OIL WESTERN,CA 5-11204911: Yq11?1010 1 I : l W -EDOEnlLR

Permit Unit Requirements for S-1129-49-11 (continued) Page 3 of 4

22. Cogeneration unit includes 48.7 MMBtuhr (nominal rating) Allison, model 501-KB-5, gas fired turbine engine with either pilotless fuel nozzles or conventional fuel nozzles and 20.0 MMBtuIhr (nominal rating) gas fired Forney duct burner. [District NSR Rule] Federally Enforceable Through Title V Permit .

23. Cogeneration unit includes ]:deal synchronous electrical generator, Struthers-Wells unfired 22.5 MMBtuh steam generator, and an inlet air evaporative cooler. [District NSR Rule] Federally Enforceable Through Title V Permit

24. Turbine lube oil tank shall vent only through CECO Model #STTOR-10 fiber bed filter system. [District NSR Rule] Federally Enforceable Through Title V Permit

25. Fuel gas sulhr content shall not exceed 14 ppmv as hydrogen sulfide (H2S). [District NSR Rule] Federally Enforceable Through Title V Permit

26. Permittee shall notify the District by fax or in writing prior to or within 4 hours of any turbine nozzle replacement, except for identical replacement. [District NSR Rule] Federally Enforceable Through Title V Permit

27. Except during periods of startuplshutdown, emission rates (3 hr average) shall not exceed: PM10: 0.61 Ibhr; SOX (as S02): 0.16 lblhr; NOx (as N02): 30 ppmvd @ 15% 02; VOC: 1.65 Ibhr; and CO: 29 ppmvd @ 15% 02. [District NSR Rule] Federally Enforceable Through Title V Permit

28. NOx (as N02) and SOX (as S02) emission rates ( I hr average) shall not exceed NSPS standard of 150 ppmv-dry @ 15% 02, and 150 ppmv-dry @ 15% 02, respectively. [District Rule 2520,9.3.2; 40 CFR 60.332(c) and 40 CFR 60.333(a)] Federally Enforceable Through Title V Permit

29. Emissions shall not exceed the following: PMI 0: 14.6 lblday; SOX (as S02): 3.8 Iblday; NOx (as N02): 182.4 Iblday; VOC: 39.6 Iblday; and CO: 107.8 Iblday. [District NSR Rule] Federally Enforceable Through Title V Permit

30. During days of gas turbine startuplshutdown, permittee shall maintain accurate daily records of natural gas consumption in gas turbine for normal operation and startuplshutdown periods. [District NSR Rule] Federally Enforceable Through Title V Permit

3 1. Generator gearbox lube oil tank shall vent only through CECO Model #STTOR-1 0 fiber bed filter system. [District NSR Rule] Federally Enforceable Through Title V Permit

32. Gas turbine engine shall be equipped with continuously recording fuel gas flow rate monitor. [District NSR Rule] Federally Enforceable Through Title V Permit

33. Gas turbine engine shall be equipped with operational water injection system for NOx control. [District NSR Rule] Federally Enforceable Through Title V Permit

34. Gas turbine engine shall be equipped with continuously recording water injection rate monitor accurate to within 5%. [District NSR Rule] Federally Enforceable Through Title V Permit

35. Waste heat recovery steam generator exhaust shall be equipped with permanent provisions to allow collection of gas . samples consistent with EPA methods. [District NSR Rule] Federally Enforceable Through Title V Permit

36. Gas turbine shall be fired exclusively with PUC quality natural gas or equivalent. [District NSR Rule] Federally Enforceable Through Title V Permit

37. Gas turbine engine water injection rate shall be maintained at a water to fuel ratio no less than 0.4811.0 by weight while operating with pilotless he1 nozzles and no less than 0.811.0 by weight while operating with conventional fuel nozzles. [District NSR Rule] Federally Enforceable Through Title V Permit

38. Maximum emission rate of volatile organic compounds (VOC's) from turbine lube oil vent shall not exceed 0.02 Ib/hr. [District NSR Rule] Federally Enforceable Through Title V Permit

39. Compliance testing of lube oil vent and gearbox vent shall be required if monthly visible emissions checks from either vent exceeds 5% opacity or equivalent Ringelmann 114. If visible emissions are observed, corrective action shall be taken to eliminate visible emissions. If visible emissions cannot be corrected within 24 hours, a visible emissions test using EPA Method 9 shall be conducted. [District Rules 2520,9.3.2 and NSR] Federally Enforceable Through Title V Permit

PERMIT UNIT REQUIREMENTS CONTINUE ON NEXT PAGE These terms and conditions are part of the Facility-wide Permit to Operate.

Facility Name: CHEVRON U S A INC Location: HEAW OIL WESTERN,CA 8-112P(D11:MyU101011:1~-EmEnW

Permit Unit Requirements for S-1129-49-11 (continued) Page 4 of 4

40. Thermal stabilization period shall be defined as the start-up or shutdown time necessary to bring the heat recovery steam generator to proper temperature, not exceeding two hours. [District NSR Rule] Federally Enforceable Through Title V Permit

4 1. Startup and shutdown of gas turbine engine, as defined in 40 CFR Subpart A 60.2, shall not exceed a time period of two hours and two hours, respectively, per occurrence. [40 CFR Subpart A 60.2, District NSR Rule] Federally Enforceable Through Title V Permit

42. Permittee shall keep accurate records of fuel sulfur content, and such records shall be made available for District inspection for five years. [40 CFR 60.334(b)(2), District Rule 2520,9.3.2] Federally Enforceable Through Title V Permit

43. Annual compliance with GTEIduct burner NOx and CO emission limits (pursuant to Rule 4703 (10/16/97)) and fuel sulfur limit shall be demonstrated by District witnessed or authorized sample collection by independent laboratory. Test results shall be submitted within 60 days. [District NSR Rule and Rule 47031 Federally Enforceable Through Title V Permit

44. The following test methods shall be used: CO (ppmv) - EPA Method 10 or 10B. [District Rules 2520,9.3.2 and 47031 Federally Enforceable Through Title V Permit

These terms and conditions are part of the Facility-wide Permit to Operate. Facility Name: CHEVRON U S A INC Location: HEAVY OIL WESTERN.CA 8112e4ClI :UPyZ22OlO lI:l(ALI-EDcEnlLR

CUSA S-1129, #1101916

ATTACHMENT II Location Map

CUSA S-1129, #1101916

ATTACHMENT Ill Preliminary diagrams of the proposed replacement cogens and CEMs

CUSA S-1129, #I101 916

ATTACHMENT IV Manufacturer's Information on SCR

SCR System General Description

Although CUSA is'reviewing bids from several SCR vendors, the SCR systems to be installed on the replacement cogen units will incorporate common design features regardless of the vendor selected. Specifically, the SCR systems will incorporate a medium temperature catalyst (350 OF to 600 OF), such as vanadium pentoxide (V20s) or titanium oxide (Ti02), and will be installed within the cavity of the existing heat recovery steam generators (HRSGs) to ensure the exhaust temperature is maintained at the appropriate range (450 OF to 650 OF). The catalyst grid will likely consist of a honeycomb design and will rely exclusively on aqueous ammonia as the reagent. The chemical equation for a stoichiometric reaction using aqueous ammonia for a selective catalytic reduction process is as follows:

catalyst

catalyst

2N02 + 4NH3 + 0 2 3 3N2 + 6H20

catalyst

NO + NO2 + 2NH3 3 2N2 + 3H20

Oxidation Catalyst General Description

CUSA has not yet selected an oxidation catalyst vendor, but the equipment to be installed on the replacement cogen units will incorporate common design features regardless of the vendor selected. Oxidation catalyst is typically made of a precious metal such as platinum, palladium, or rhodium. The CO catalyst promotes the oxidation of CO and hydrocarbon compounds to carbon dioxide (C02) and water (H20) as the emission stream passes through the catalyst bed. The oxidation process takes place spontaneously, without the requirement for introducing reactants. The performance of these oxidation catalyst systems on combustion turbines results in 90-plus percent control of CO and about 85 to 90 percent control of formaldehyde.

General Listing of Emissions Control Equipment

SCR reactor: includes ceramic honeycomb catalyst and insulated casing

Aqueous ammonia storage: includes tank (-6000 gallons) and associated pumps and piping Aqueous vaporizer and flow control unit: includes ammonia injection grid and associated injection pumps, piping, and nozzles

Oxidation catalyst grid to be installed upstream of the SCR catalyst

Controls and instrumentation: includes electrical wiring and PLC upgrades

Foundations and ductwork

Shared continuous emissions monitoring system: includes sample probes and associated electrical wiring and hardware and PLC.

CUSA S-1129, #1101916

ATTACHMENT V Emis.sions Profiles

SJVUAPCD Application Emissions 611 411 o SOUTHERN 11:51 am

Permit #: S-1129-868-0 Last Updated Facility: CHEVRON U S A 06/14/2010 EDGEHILR I NC

Equipment Pre-Baselined: NO NOX - - SOX PMlO - CO - VOC

I I I 1 I

Quarterly Net Emissions Change I

Potential to Emit (IbNr): I 16615.0

Daily Emis. Limit (IbIDay) I 64.1

Check if offsets are triggered but N N N ---

2102.0

I I I I I 5.8

Quarterly Offset Amounts (IbIQtr) Q1: Q2:

I I I I I

1 1730.0

Offset Ratio I

138.8 32.1

I

6581 1 .O

1658.9

22052.0

SJVUAPCD Application Emissions 611 411 o SOUTHERN 11:51 am

Permit #: S-1129-869-0 . Last Updated Facility: CHEVRON U S A 06/14/2010 EDGEHILR INC

Equipment Pre-Baselined: NO NOX - SOX - - PMlO CO -

Potential to Emit (IbNr): ( 16615.0

Daily Emis. Limit (IblDay)

Quarterly Net Emissions Change

Check if offsets are triggered but exemption applies

I 2102.0

64.1

Offset Ratio

Quarterly Offset Amounts (IblQtr) 0 1 .

N

I

1 1730.0

5.8

N

6581 1 .O

32.1

22052.0

N

1658.9 138.8

N N

CUSA S-1129, # I 101 916

ATTACHMENT VI HRA and AAQlA Summary

San Joaquin Valley Air Pollution Control District Risk Management Review

REVISED

To: Richard Edgehill, AQE - Permit Services

From:

Date:

Jaime Horio, AQS - Technical Services

June 17, 2010

Facility Name: Chevron USA . .

Location: S18, T30S, R22E

Application #(s): S-1129-868-0, -869-0

Project #: S-1101916

A. RMR SUMMARY

Proposed Permit Conditions

RMR Summary

To. ensure that .human health risks will not exceed District allowable levels; the.foll.owing permit. conditions must be included for:

Categories

Prioritization Score Acute Hazard Index

Chronic Hazard Index Maximum Individual Cancer Risk (1 o - ~ ) T-BACT Required?

Speclal Permit Conditions?

Unit # 868-0, -869-0

1. The exhaust stack shall vent vertically upward. The vertical exhaust flow shall not be impeded by a rain cap (flapper ok), roof overhang, or any other obstruction. [District Rule 4 1021

'Facilities S-1128, S-1129, S-1141 and $2592 (And deleted facility S-1549 are all the same facility, and therefore their risk scores will be combined. "These scores were previously calculated on 5120110

103 MMBtulhr NG Turbines

(Units 868-0, -869-0) 0.223

1 .76e-2

1.02e-2

' 0.827

Facility Totals

>1.0

0.1 16

0.0573

0.827

Project Totals

0.223

1.76e-2

. 1.02e-2

0.827

Stationary Source Total' >1.0

0.7591

0.1 149

7.423

No

Yes

. . . . . . . . . . . .. .

. . , . . . . .

. .. . . .

Chevron USA, S-1101916 Page 2 of 2

B. RMR REPORT

I. Project Description , - . .

~echnical Services riceived a request on ~ " n e 16, 2010, to perform a modified Ambient Air Quality Analysis. The modification consisted of increasing the PM10 emissions.

II. Analysis . . . . . . . .

. . .

Technical ~en/ ices performed modeling for criteria pollutants PMlo. The emission rates used for criteria pollutant modeling were 1.3 Iblhr PMlo. The engineer supplied the maximum fuel rate for the IC errgine used during the analysis.

Only PM,o was calculated during this revision. All other pollutants were considered previously on May 20, 2010

The results from the Criteria Pollutant Modeling are as follows:

Criteria Pollutant Modeling Results*

h he criteria pollutants are below EPA's level of significance as found in 40 CFR Part 51.165 (b)(2).

Ill. Conclusion

Diesel ICE CO NOX SOx PMlo

The acute and chronic indices are below 1.0 and the cancer risk factor associated with the turbines is less than 1.0 in a million. In accordance with the District's Risk Management Policy, the project is approved without Toxic Best Available Control Technology (T- BACT).

To ensure that human health risks will not exceed District allowable levels; the permit conditions listed on page 1 of this report must be included for this proposed unit.

'Results were taken from the attached PSD spreadsheet.

1 Hour Pass Pass Pass

X

These conclusions are based on the data provided by the applicant and the project engineer. Therefore, this analysis is valid only as long as the proposed data and parameters do not change.

The emissions from the proposed equipment will not cause or contribute significantly to a violation of the State and National AAQS.

3 Hours X X

Pass X

Attachments:

A. Modified Emissions 0. Ambient Air Quality Analysis Summary

8 Hours. Pass

X X X

24 Hours X X

Pass Pass,, .

Annual X

Pass Pass pass1

CUSA S-1129, #1101916

ATTACHMENT VII Draft ATCs

San Joaquin Valley Air Pollution Control District

AUTHORITY TO CONSTRUCT PERMIT NO: S-1129-868-0

LEGAL OWNER OR OPERATOR: CHEVRON U S A INC MAILING ADDRESS: PO BOX 1392

LOCATION:

BAKERSFIELD, CA 93302

HEAVY OIL WESTERN CA

EQUIPMENT DESCRIPTION: 5.285 MW (NOMINAL RKI'ING) GAS TURBINE ENGINE COGENERATION UNIT # I (MCKITTRICK) EQUIPPED WITH: 63 MMBTUIHR (NOMINAL) SOLAR TAURUS 60-7901 GAS TURBINE ENGINE (GTE); HEAT RECOVERY STEAM GENERATOR (HRSG) WlTH A 40 MMBTUIHR (NOMINAL) DUCT BURNER; WATER INJECTION SYSTEM FOR INTERMEDIATE NOX CONTROL; SELECTIVE CATALYTIC REDUCTION (SCR) SYSTEM WlTH AMMONIA INJEC'rION TO COMPLY WlTH RULE 4703 TIER 3 EMISSION LIMIT OF 5 PPMV NOX @ 15% 02; OXIDATION CATALYST FOR CO CONTROL; AND SHARED CONTINUOUS EMISSIONS MONITORING SYSTEM (CEMS) TO MEASURE NOX, CO, AND 0 2 CONCENTRATIONS

CONDITIONS -

1. (1 830) This Authority to Construct serves as a written certificate of conformity with the procedural requirements of 40 CFR 70.7 and 70.8 and with the compliance requirements of 40 CFR 70.6(c). [District NSR Rule] Federally Enforceable Through Title V Permit

2. (1 83 1) Prior to operating with modifications authorized by this Authority to Construct, the facility shall submit an application to modify the Title V permit with an administrative amendment in accordance with District Rule 2520 Section 5.3.4. [District Rule 2520, 5.3.41 Federally Enforceable Through Title V Permit

3. The exhaust stack shall vent vertically upward. The vertical exhaust flow shall not be impeded by a rain cap (flapper ok), roof overhang, or any other obstruction. [District Rule 4 1021

4. (98) No air contaminant shall be released into the atmosphere which causes a public nuisance. [District Rule 4 1021

5. Particulate matter emissions shall not exceed 0.1 grains/dscf in concentration. [District Rule 42011 Federally Enforceable Through Title V Permit

CONDITIONS CONTINUE ON NEXT PAGE YOU MUST NOTIFY THE DISTRICT COMPLIANCE DIVISION AT (661) 392-5500 WHEN CONSTRUCTION IS COMPLETED AND PRIOR TO OPERATING THE EQUIPMENT OR MODIFICATIONS AUTHORIZED BY THIS AUTHORITY TO CONSTRUCT. This is NOT a PERMIT TO OPERATE. Approval or denial of a PERMIT TO OPERATE will be made after an inspection to verify that the equipment has been constructed in accordance with the approved plans, specifications and conditions of this Authority to Construct, and to determine if the equipment can be operated in compliance with all Rules and Regulations of the San Joaquin Valley Unlfied Air P~l l~t ' ion Control District Unless construction has commenced pursuant to Rule 2050, this Authority to Construct shall expire and application shall be cancelled two years from the date of issuance. The applicant is responsible for complying with all laws, ordinances and r e g u l a t i o n ~ f ~ e r governmental agencies which may pertain to the above equipment.

Southern Regional Office 34946 Flyover Court Bakersfield, CA 93308 rn (661) 392-5500 rn Fax (661) 392-5585

Conditions for S-1129-868-0 (continued) Page 2 of 5

6. The sulfur content in the fuel being combusted shall not exceed 0.7 1 grains1100 scf, otherwise, the fuel shall be of PUC-regulated quality. [District Rule 220 I] Federally Enforceable Through Title V Permit

7. If the gas turbine system is fired on PUC-regulated natural gas, then maintain on file copies of natural gas bills. [District Rule 25201 Federally Enforceable Through Title V Permit

8. If the gas turbine system is not fired on PUC-regulated natural gas, the sulfur content of each fuel source shall be tested weekly except that if compliance with the fuel sulfur content limit has been demonstrated for 8 consecutive weeks for a fuel source, then the testing frequency shall be quarterly. If a test shows noncompliance with the sulfur content requirement, the source must return to weekly testing until eight consecutive weeks show compliance. [40 CFR 60.4360,40 CFR 60.4365(a), 40 CFR 60.4370(c)] Federally Enforceable Through Title V Permit

9. HHV and LHV of the fuel shall be determined by using ASTM D3588, ASTM 1826, or ASTM 1945. [District Rule 47031 Federally Enforceable Through Title V Permit

10. During an initial shakedown period, the emissions shall not exceed any of the following limits, except during periods of startup, shutdown, and black start: 42 ppmvd NOx @ 15% 0 2 referenced as N02; 50 ppmvd CO @ 15% 02 ; 0.0 13 Ib-PMI OMMBtu; 0.024 Ib-VOCMMBtu referenced as methane; and 0.00233 lb-SOxhlMBtu referenced as S02. The shakedown period shall not exceed 90 calendar days from the initial startup of the unit under this permit. [District Rule 220 1 ] Federally Enforceable Through Title V Permit

1 I . Within 90 days of startup, permits S-1127-47, '-48, and '-49 shall be canceled. The permittee shall maintain a record of the date of initial operation of this unit, fuel combusted (scflday) on daily basis, and water-to-fuel ratio or results of NOx and CO over 3-hour rolling average period from CEMS (if operational). These records shall be made readily available for District inspection upon request. [District Rule 22011 Federally Enforceable Through Title V Permit

12. Upon concluding the initial shakedown period, emissions from the gas turbine system, except during periods of startup, shutdown, and black start, shall not exceed any of the following limits: 5 ppmvd NOx @ 15% 0 2 referenced as N02; 29 ppmvd CO @ 15% 02; 0.013 Ib-PM1 O/MMBtu; 0.024 Ib-VOCIMMBtu referenced as methane; and 0.00233 Ib-SOxhlMBtu referenced as S02. NOx and CO emission limits are based on 3-hour rolling average period. If unit is in either startup, shutdown, or black start mode during any portion of a clock hour, the unit will not be subject to the ppmvd limits for NOx and CO during that clock hour. [District Rules 2201 and 47031 Federally Enforceable Through Title V Permit

13. Upon concluding the initial shakedown period, emissions from the gas turbine system shall not exceed any of the following limits: 64.1 Ib-NOdday referenced as N02; 1,658.9 Ib-COIday; 5.8 Ib-SOdday; 32.1 Ib-PMl Olday; 138.8 Ib-VOCIday referenced as methane; and 70.2 Ib-NH31day. pistrict Rule 22011 Federally Enforceable Through Title V Permit

14. Upon concluding the initial shakedown period, the emissions from the gas turbine system shall not exceed any of the following limits: 16,6 15 Ib-NOdyear; 65,8 10 Ib-COIyear; 2,102 Ib-Sodyear; 1 1,730 Ib-PM I Olyear; 22,052 Ib- VOCIyear; 25,637 IbNH3lyear. All annual emission limits are based on 12 consecutive month rolling emissions totals. [District Rule 22011 Federally Enforceable Through Title V Permit

15. Ammonia (NH3) emissions shall not exceed 21 ppmvd @ 15% 0 2 over a 24-hour average period. [District Rule 22011 Federally Enforceable Through Title V Permit

16. Each three hour rolling average will be compiled from the three most recent one hour periods. Each one hour period shall commence on the hour. Each one hour period in a twenty-four hour average for ammonia slip will commence on the hour. The twenty-four hour average will be calculated starting and ending at twelve-midnight. [District Rule 22011 Federally Enforceable Through Title V Permit

17. Daily emissions shall be compiled for a twenty-four hour period starting and ending at twelve-midnight. Each calendar month in a twelve consecutive month rolling emissions total shall commence at the beginning of the first day of the month. The twelve consecutive month rolling emissions totals used to determine compliance with annual emission limits shall be compiled from the twelve most recent calendar months. [District Rule 22011 Federally Enforceable Through Title V Permit

A

Conditions for S-1129-868-0 (continued) Page 3 of 5

18. The exhaust stack shall be equipped with permanent provisions to allow collection of stack gas samples consistent with EPA test methods and shall be equipped with safe permanent provisions to sample stack gases with a portable NOx, COY and 0 2 analyzer during District inspections. The sampling ports shall be located in accordance with the CARB regulation titled California Air Resources Board Air Monitoring Quality Assurance Volume VI, Standard Operating Procedures for Stationary Emission Monitoring and Testing. [District Rule 108 11 Federally Enforceable Through Title V Perhit

19. Source testing shall be conducted using the methods and procedures approved by the District. The District must be notified at least 30 days prior to any compliance source test, and a source test plan must be submitted for approval at least 15 days prior to testing. [District Rule 10811 Federally Enforceable Through Title V Permit

20. Source testing shall be witnessed or authorized by District personnel and samples shall be collected by a California Air Resources Board (CAM) certified testing laboratory or a CARB certified source testing firm. [District Rule 10811 Federally Enforceable Through Title V Permit

2 1. Source testing to measure start-up mass emission rates of NOx, COY and voc shall be conducted for one of the gas turbine systems (S-1129-868, '-869) within 90days of initial startup under this permit and at least once every seven years thereafter. CEMS relative accuracy shall be determined during source testing in accordance with the procedure listed in 40 CFR Part 60, Appendix F with any necessary changes approved by the District. [District Rule 10811 Federally Enforceable Through Title V Permit :

22. Source testing to determine compliance with the NOx, CO and NH3 emission rates (ppmvd @ 15% 02) during normal operation shall be conducted within 90 days of initial startup under this permit and annually thereafter. [District Rules 220 1 and 40 CFR 60.4400(a)] Federally Enforceable Through Title V Permit

23. Unit shall demonstrate compliance annually with NOx and CO emissions limits with the duct burner in operation and not in operation. An annual demonstration of compliance with the duct burner in operation is not required in any year in which the duct burner is not operated at all in the preceding 12 months, in such case, the unit shall be compliance source tested within 60 days of resumption of operation of the duct burner. An annual demonstration of compliance with the duct burner not in operation is not required in any year in which the duct burner operated continuously in conjunction with the turbine in the preceding 12 months, in such case, the unit shall be compliance source tested within 60 days of shutdown of operation of the duct burner. [District Rules 2201 and 47031 Federally Enforceable Through Title V Permit

24. For the purpose of determining compliance with the emissions limits (ppmvd @ 15% 02) during normal operation in this permit, the arithmetic mean of three test runs shall apply, unless two of the three results are above an applicable limit. If two of three runs are above the applicable limit the test cannot be used to demonstrate compliance with an applicable limit. [District Rule 10811 Federally Enforceable Through Title V Permit

25. The following test methods shall be used: NOx - EPA Method 7E or 20 or C A M Method 100; CO - EPA Method 10 or 10B or C A M Method 100; VOC - EPA Method 18 or 25; PMlO - EPA Method 5 (front half and back half) or 201 and 202a; ammonia - BMQMD ST-IB; and 0 2 - EPA Method 3,3A, or 20 or CARB Method 100. EPA approved alternative test methods as approved by the District may also be used to address the source testing requirements of this permit. [District Rules 1081 and 4703, and 40 CFR 60.4400 (l)(i)] Federally Enforceable Through Title V Permit

26. The results of each source test shall be submitted to the District within 60 days thereafter. [District Rule 10811 Federally Enforceable Through Title V Permit

27. The owner or operator shall install, certib, maintain, operate, and quality-assure a continuous emission monitor system (CEMS) which continuously measures and records the exhaust gas NOx, COY and 0 2 concentrations. Continuous emissions monitors shall be capable of monitoring emissions during normal operating conditions and during startups and shutdowns, provided that CEMS passes the relative accuracy requirements of 40 CFR Part 60, Appendix B, Performance Specification 2 (PS-2) and District approved protocol for startups. If relative accuracy of CEMS cannot be demonstrated during the startup, CEMS results during startup and shutdown events shall be replaced with startup emission rates obtained from the source test conducted by the facility to determine compliance with emission limits contained in this document. [District Rules 0 CFR 60.4340(b)(l) and 40 CFR 60.4345(a)] Federally Enforceable Through Title V Permit

CONDITI ON NEXT PAGE E-lll%UMd: Jun 11 1010 1:llPM - EWEnlUI

Conditions for S-1129-868-0 (continued) Page 4 of 5

28. The CEMS shall complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each 15- minute quadrant of the hour or shall meet equivalent ~~ecifications established by mutual agreement of the District, the ARB and the EPA. [District Rule 1080, and 40 CFR 60.4345(b)] Federally Enforceable Through Title V Permit

29. The NOx, CO and 0 2 CEMS shall meet the requirements in 40 CFR 60, Appendix F Procedure 1 and Part 60, ~ppendix B Performance Specification 2 (PS 2), or shall meet equivalent specifications established by mutual agreement of the District, the ARB, and the EPA. [District Rule 1080, and 40 CFR 60.4345(a)] Federally Enforceable Through Title V Permit

30. In accordance with 40 CFR Part 60, Appendix F, 5. I , the CEMS must be audited at least once each calendar quarter. The District shall be notified prior to completion of the audits. Audit reports shall be submitted along with quarterly compliance reports to the District. [District Rule 10801 Federally Enforceable Through Title V Permit

3 1. The requirements in 40 CFR 60, Appendix F, shall be met through the following EPA and District approved modified procedures: 1) annual RATA testing of at least one gas turbine engine (S-1129-868, '-869), and rotate the unit tested so that the two units are tested over two years, 2) annual RAA testing for the one gas turbine engine for which the annual RATA testing is not performed, 3) if any of the gas turbine engines fail the R4A testing, they must have a RATA test within 60 days, and 4) for every quarter that RATA or R4A testing is not performed, a CGA is to be performed for each gas turbine engine. [District Rule 10801 Federally Enforceable Through Title V Permit

32. APCO or an authorized representative shall be allowed to inspect, as determined to be necessary, the required monitoring devices to ensure that such devices are functioning properly. [District Rule 10801 Federally Enforceable Through Title V Permit

33. The CEMS data shall be reduced.to hourly averages as specified in 40 CFR 60.13(h), or by other methods deemed equivalent by mutual agreement with the District, the ARB, and the EPA. [District Rule 1080 and 40 CFR 60.43501 Federally Enforceable Through Title V Permit

34. Upon written notice from the District, the owner or operator shall provide a summary of the data obtained from the CEMS. This summary shall be in the form and the manner prescribed by the District. [District Rule 10801 Federally Enforceable Through Title V Permit

35. The facility shall install and maintain equipment, facilities, and systems compatible with the District's CEMS data polling software system and shall make CEMS data available to the District's automated polling system on a daily basis. Upon notice by the District that the facility's CEMS is not providing polling data, the facility may continue to operate without providing automated data for a maximum of 30 days per calendar year provided the CEMS data is sent to the District by a District-approved alternative method. [District Rule 10801 Federally Enforceable Through Title V Permit

36. The permittee shall maintain the following records: the date, time and duration of any malfunction of the continuous monitoring equipment; dates of performance testing; dates of evaluations, calibrations, checks, and adjustments of the continuous monitoring equipment; date and time period which a continuous monitoring system or monitoring device was inoperative. [District Rules 1080 and 2201 and 40 CFR 60.8(d)] Federally Enforceable Through Title V Permit

37. The owner or operator shall submit a written report of CEM operations for each calendar quarter to the District. The report is due on the 30th day following the end of the calendar quarter and shall include the following: Time intervals, data and magnitude of excess NOx emissions, nature and the cause of excess (if known), corrective actions taken and preventive measures adopted; Averaging period used for data reporting corresponding to the averaging period specified in the emission test period used to determine compliance with an emission standard; Applicable time and date of each period during which the CEM was inoperative, except for zero and span checks, and the nature of system repairs and adjustments; A negative declaration when no excess emissions occurred. [District Rule 1080, 40 CFR 60.4375(a) and 40 CFR 60.43951 Federally Enforceable Through Title V Permit

38. Monitor downtime for NOx shall be any unit operating hour in which sufficient data are not obtained to validate the hour for either NOx concentration or diluent 0 2 (or both). [40 CFR 60.4380(b)(2)] Federally Enforceable Through Title V Permit

Conditions forS-1129-868-0 (continued) , . Page 5 of 5

39. If the gas turbine system is not fired on PUC-regulated or FERC-regulated natural gas, then a fuel sahple shall be collected during the source test to determine sulfur content of the fuel combusted in the turbine. The fuel sample shall be analyzed for the total sulfur content using ASTM D1072; D3246; D4084; D4468; D6228; or D6667; or double GC for H2S and mercaptans. The applicable ranges of some ASTM methods are not adequate to measure the levels of sulfur in some fuel gases. Dilution of samples before analysis (with verification of dilution ratio) may be used after getting a prior approval from the District. [40 CFR 60.441 5(a)(l)(i)] Federally Enforceable Through Title V Permit

40. A totalizing mass or volumetric fuel flow computer shall be utilized and maintained to calculate the amount of natural gas combusted based on measured flow meter parameters (fuel pressure and temperature) and gas composition. [District Rule 47031 Federally Enforceable Through Title V Permit

41. Except during black start, start-up shall not exceed 2.0 hours per event. [District Rule 47031 Federally Enforceable Through Title V Permit

42. Shutdown shall not exceed 2.0 hours per event. [District Rule 47031 Federally Enforceable Through Title V Permit

43. The emission control systems shall be in operation and emissions shall be minimized insofar as technologically feasible during startup (black start) and shutdown. [District Rule 47031 Federally Enforceable Through Title V Permit

44. Start-up is defined as the period of time during which a unit is brought from a shutdown status to its operating temperature and pressure, including the time required by the unit's emission control system to reach full operation. [District Rule 47031 Federally Enforceable Through Title V Permit

45. Shutdown is defined as the period of time during which a unit is taken from an operational to a non-operational status by allowing it to cool down from its operating temperature to ambient temperature as the fuel supply to the unit is completely turned off. [District Rule 47031 Federally Enforceable Through Title V Permit

46. Reduced load period is defined as the time during which a gas turbine is operated at less than rated capacity in order to change the position of the exhaust gas diverter gate. Each reduced load period shall not exceed one hour. [District Rule 47031 Federally Enforceable Through Title V Permit

47. A black start event is defined as the startup of a unit while the cogen plant is electrically separated from the utility grid. A black start shall not exceed 4.0 hours per event. [District Rules 2201 and 47031 Federally Enforceable Through Title V Permit

48. The owner or operator shall submit to the District information correlating the NOx control system operating parameters to the associated measured NOx output. The information must be sufficient to allow the District to determine compliance with the NOx emission limits of this permit when the CEMS is not operating properly. [District Rule 47031 Federally Enforceable Through Title V Permit

49. The owner or operator shall maintain a stationary gas turbine system operating log that includes, on a daily basis, the actual local startup and stop time, length and reason for reduced load periods, total hours of operation, the type and quantity of fuel used, duration of each start-up (or black start) and each shutdown time period. [District Rule 47031 Federally Enforceable Through Title V Permit

50. The owner or operator shall maintain all records of required monitoring data and support information for a period of five years from the date of data entry and shall make such records available to the District upon request. [District Rules 2201 and 47031 Federally Enforceable Through Title V Permit

5 1. Compliance with permit conditions in the Title V permit shall be deemed compliance with the following subsumed requirements: Kern County Rule 407; SJVUAPCD Rule 4703 6.2.1,6.2.4,6.3, 6.4.1,6.4.2,6.4.3, and 6.4.5; 60.4320(a); 40 CFR 60.4330(a)(2); 40 CFR 60.4340(b)(l); 40 CFR 60.4345(a) and (b); 40 CFR 60.4350; 40 CFR 60.4360; 40 CFR 60.4365(a); 40 CFR 60.4370(c); 40 CFR 60.4375(a); 40 CFR 60.4380(b)(2); 40 CFR 60.4395; 40 CFR 60.4400(a); 40 CFR 60.4400(1)(i); and 40 CFR 60.4415(a)(l)(i). A permit shield is granted from these requirements. [District Rule 2520, 13.21 Federally Enforceable Through Title V Permit

San Joaquin Valley Air Pollution Control District

AUTHORITY TO CONSTRUCT PERMIT NO: S-1129-869-0 ISSU

LEGAL OWNER OR OPERATOR: CHEVRON U S A INC MAILING ADDRESS: PO BOX 1392

BAKERSFIELD,' CA 93302

LOCATION: HEAVY OIL WESTERN C A

EQUIPMENT DESCRIPTION: 5.285 MW (NOMINAL RATING) GAS TURBINE ENGINE COGENERATION UNlT#2 (MCKITTRICK) EQUIPPED WITH: 63 MMBTUIHR (NOMINAL) SOLAR TAURUS 60-7901 GAS TURBINE ENGINE (GTE); HEAT RECOVERY STEAM GENERATOR (HRSG) WlTH A 40 MMBTUIHR (NOMINAL) DUCT BURNER; WATER INJECTION SYSTEM FOR INTERMEDIATE NOX CONTROL; SELECTIVE CATALYTIC REDUCTION (SCR) SYSTEM WlTH AMMONIA INJECTION TO COMPLY WlTH RULE 4703 TIER 3 EMISSION LIMIT OF 5 PPMV NOX @ 15% 02; OXIDATION CATALYST FOR CO CONTROL; AND SHARED CONTINUOUS EMISSIONS MONITORING SYSTEM (CEMS) TO MEASURE NOX, CO, AND 0 2 CONCENTRATIONS

CONDITIONS 1. (1 830) This Authority to Construct serves as a written certificate of conformity with the procedural requirements of 40

CFR 70.7 and 70.8 and with the compliance requirements of 40 CFR 70.6(c). [District NSR Rule] Federally Enforceable Through Title V Permit

2. (1 83 1 ) Prior to operating with modifications authorized by this Authority to Construct, the facility shall submit an application to modify the Title V permit with an administrative amendment in accordance with District Rule 2520 Section 5.3.4. [District Rule.2520, 5.3.41 Federally Enforceable Through Title V Permit

3. The exhaust stack shall vent vertically upward. The vertical exhaust flow shall not be impeded by a rain cap (flapper ok), roof overhang, or any other obstruction. [District Rule 4 1021

4. (98) No air contaminant shall be released into the atmosphere which causes a public nuisance. [District Rule 41021

5. Particulate matter emissions shall not exceed 0.1 grainsldscf in concentration. [District Rule 42011 Federally Enforceable Through Title V Permit

CONDITIONS CONTINUE ON NEXT PAGE YOU MUST NOTIFY THE DISTRICT COMPLIANCE DIVISION AT (661) 392-6600 WHEN CONSTRUCTION IS COMPLETED AND PRIOR TO OPERATING THE EQUIPMENT OR MODIFICATIONS AUTHORIZED BY THIS AUTHORITY TO CONSTRUCT. This is NOT a PERMIT TO OPERATE. Approval or denlal of a PERMIT TO OPERATE will be made after an inspection to verify that the equipment has been constructed in accordance with the approved plans, specincations and conditions of this Authority to Construct, and to deternine if the equipment can be operated in compliance with all Rules and Regulations of the San Joaquin Valley Unified Alr Pollution Control District Unless construction has commenced pursuant to Rule 2050, this Authorlty to Constnrct shall explre and application shall be cancelled two years from the date of issuance. The applicant is responsible for complying with all laws, ordinances and r e g u l a t i o n s f m e r governmental agencies which may pertaln to the above equipment.

I - I I I V

DAVID WARNEwiaor of Permit Services 611204694. Jm2l1010 1.n.W -EDGD(ILR : hh! InsplCUon NOTRwLN

Southern Regional Office 34946 Flyover Court Bakersfield, CA 93308 (661) 392-5500 Fax (661) 392-5585

Conditions for S-1129-869-0 (continued) Page 2 of 5

6. The sulfur content in the fuel being combusted shall not exceed 0.71 grains1100 scf, otherwise, the fuel shall be of PUC-regulated quality. [District Rule 220 11 Federally Enforceable Through Title V Permit

7. If the gas turbine system is fired on PUC-regulated natural gas, then maintain on file copies of natural gas bills. [District Rule 25201 Federally Enforceable Through Title V Permit

8. If the gas turbine system is not fired on PUC-regulated natural gas, the sulfur content of each fuel source shall be tested weekly except that if compliance with the fuel sulfur content limit has been demonstrated for 8 consecutive weeks for a fuel source, then the testing frequency shall be quarterly. If a test shows noncompliance with the sulfur content requirement, the source must return to weekly testing until eight consecutive weeks show compliance. [40 CFR 60.4360,40 CFR 60.4365(a), 40 CFR 60.4370(c)] Federally Enforceable Through Title V Permit

9. HHV and LHV of the fuel shall be determined by using ASTM D3588, ASTM 1826, or ASTM 1945. [District Rule 47031 Federally Enforceable Through Title V Permit

10. During an initial shakedown period, the emissions shall not exceed any of the following limits, except during periods of startup, shutdown, and black start: 42 ppmvd NOx @ 15% 0 2 referenced as N02; 50 ppmvd CO @ 15% 02; 0.0 13 Ib-PMlOhIMBtu; 0.024 IbVOChIMBtu referenced as methane; and 0.00233 Ib-SOx/MMBtu referenced as S02. The shakedown period shall not exceed 90 calendar days from the initial startup of the unit under this permit. [District Rule 22011 Federally Enforceable Through Title V Permit

1 1. Within 90 days of startup, permits S-1127-47, '-48, and '-49 shall be canceled. The permittee shall maintain a record of the date of initial operation of this unit, fuel combusted (scflday) on daily basis, and water-to-fuel ratio or results of NOx and CO over 3-hour rolling average period from CEMS (if operational). These records shall be made readily available for District inspection upon request. [District Rule 22011 Federally Enforceable Through Title V Permit

12. Upon concluding the initial shakedown period, emissions from the gas turbine system, except during periods of startup, shutdown, and black start, shall not exceed any of the following limits: 5 ppmvd NOx @ 15% 0 2 referenced as N02; 29 ppmvd CO @ 1 5% 02; 0.0 13 Ib-PM 1 O/MMBtu; 0.024 Ib-VOC/MMBtu referenced as methane; and 0.00233 Ib-SOx/MMBtu referenced as S02. NOx and CO emission limits are based on 3-hour rolling average period. If unit is in either startup, shutdown, or black start mode during any portion of a clock hour, the unit will not be subject to the ppmvd limits for NOx and CO during that clock hour. [District Rules 2201 and 47031 Federally Enforceable Through Title V Permit

13. Upon concluding the initial shakedown period, emissions from the gas turbine system shall not exceed any ofthe following limits: 64.1 Ib-Nodday referenced as N02; 1,658.9 Ib-COIday; 5.8 Ib-SOdday; 32.1 Ib-PMlOIday; 138.8 Ib-VOCIday referenced as methane; and 70.2 Ib-NH3Iday. pistrict Rule 220 I] Federally Enforceable Through Title V Permit

14. Upon concluding the initial shakedown period, the emissions from the gas turbine system shall not exceed any of the following limits: 16,6 15 Ib-Nodyear; 65,8 10 Ib-COIyear; 2,102 IbSOdyear; 1 1,730 lb-PM1 Ofyear;-22,052 l b VOCIyear, 25,637 IbNH3lyear. All annual emission limits are based on 12 consecutive month rolling emissions totals. [District Rule 22011 Federally Enforceable Through Title V Permit

15. Ammonia (NH3) emissions shall not exceed 2 1 ppmvd @ 15% 0 2 over a 24-hour average period. pistrict Rule 220 11 Federally Enforceable Through Title V Permit

16. Each three hour rolling average will be compiled from the three most recent one hour periods. Each one hour period shall commence on the hour. Each one hour period in a twenty-four hour average for ammonia slip will commence on the hour. The twenty-four hour average will be calculated starting and ending at twelve-midnight. [District Rule 22011 Federally Enforceable Through Title V Permit

17. Daily emissions shall be compiled for a twenty-four hour period starting and ending at twelve-midnight. Each calendar month in a twelve consecutive month rolling emissions total shall commence at the beginning of the first day of the month. The twelve consecutive month rolling emissions totals used to determine compliance with annual emission limits shall be compiled from the twelve most recent calendar months. [District Rule 22011 Federally Enforceable Through Title V Permit

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Conditions for S-1129-869-0 (continued) Page 3 of 5

18. The exhaust stack shall be equipped with permanent provisions to allow collection of stack gas samples consistent with EPA test methods and shall be equipped with safe permanent provisions to sample stack gases with a portable NOx, CO, and 0 2 analyzer during District inspections. The sampling ports shall be located in accordance with the CARB regulation titled California Air Resources Board Air Monitoring Quality Assurance Volume VI, Standard Operating Procedures for Stationary Emission Monitoring and Testing. [District Rule 108 11 Federally Enforceable Through Title V Permit

19. Source testing shall be conducted using the methods and procedures approved by the District. The District must be notified at least 30 days prior to any compliance source test, and a source test plan must be submitted for approval at least 15 days prior to testing. [District Rule 10811 Federally Enforceable Through Title V Permit

20. Source testing shall be witnessed or authorized by District personnel and samples shall be collected by a California Air Resources Board (CARB) certified testing laboratory or a CARB certified source testing firm. [District Rule 108 11 Federally Enforceable Through Title V Permit

2 1. Source testing to measure start-up mass emission rates of NOx, COY and VOC shall be conducted for one of the gas turbine systems (S- 1129-868, '-869) within 90-days of initial startup under this permit and at least once every seven years thereafter. CEMS relative accuracy shall be determined during source testing in accordance with the procedure listed in 40 CFR Part 60, Appendix F with any necessary changes approved by the District. [District Rule 1081.1 Federally Enforceable Through Title V Permit

22. Source testing to determine compliance with the NOx, CO and NH3 emission rates (ppmvd @ 15% 02) during normal operation shall be conducted within 90 days of initial startup under this permit and annually thereafter. [District Rules 2201and 40 CFR 60.4400(a)] Federally Enforceable Through Title V Permit

23. Unit shall demonstrate compliance annually with NOx and CO emissions limits with the duct burner in operation and not in operation. An annual demonstration of compliance with the duct burner in operation is not required in any year in which the duct burner is not operated at all in the preceding 12 months, in such case, the unit shall be compliance source tested within 60 days of resumption of operation of the duct burner. An annual demonstration of compliance with the duct burner not in operation is not required in any year in which the duct burner operated continuously in conjunction with the turbine in the preceding 12 months, in such case, the unit shall be compliance source tested within 60 days of shutdown of operation of the duct burner. [District Rules 220 1 and 47031 Federally Enforceable Through Title V Permit

24. For the purpose of determining compliance with the emissions limits (ppmvd @ 15% 02) during normal operation in this permit, the arithmetic mean of three test runs shall apply, unless two of the three results are above an applicable limit. If two of three runs are above the applicable limit the test cannot be used to demonstrate compliance with an applicable limit. [District Rule 108 I] Federally Enforceable Through Title V Permit

25. The following test methods shall be used: NOx - EPA Method 7E or 20 or CARB Method 100; CO - EPA Method 10 or 10B or CARB Method 100; VOC - EPA Method 18 or 25; PMl0 - EPA Method 5 (front half and back half) or 201 and 202a; ammonia - BAAQMD ST-IB; and 0 2 - EPA Method 3,3A, or 20 or CARB Method 100. EPA approved alternative test methods as approved by the District may also be used to address the source testing requirements of this permit. [District Rules 1081 and 4703, and 40 CFR 60.4400 (I)(i)] Federally Enforceable Through Title V Permit

26. The results of each source test shall be submitted to the District within 60 days thereafter. [District Rule 10811 Federally Enforceable Through Title V Permit

27. The owner or operator shall install, certib, maintain, operate, and quality-assure a continuous emission monitor system (CEMS) which continuously measures and records the exhaust gas NOx, CO, and 0 2 concentrations. Continuous emissions monitors shall be capable of monitoring emissions during normal operating conditions and during startups and shutdowns, provided that CEMS passes the relative accuracy requirements of 40 CFR Part 60, Appendix By Performance Specification 2 (PS-2) and District approved protocol for startups. If relative accuracy of CEMS cannot be demonstrated during the startup, CEMS results during startup and shutdowa events shall be replaced with startup emission rates obtained from the source test conducted by the facility to determine compliance with emission limits contained in this document. [District Rules 1080,2201 an 0 CFR 60.4340(b)(l) and 40 CFR 60.4345(a)] Federally Enforceable Through Title V Permit

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Conditions for S-1129-869-0 (continued) Page 4 of 5

28. The CEMS shall complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each 15- minute quadrant of the hour or shall meet equivalent specifications established by mutual agreement of the District, the ARB and the EPA. [District Rule 1080, and 40 CFR 60.4345(b)] Federally Enforceable Through Title V Permit

29. The NOx, CO and 0 2 CEMS shall meet the requirements in 40 CFR 60, Appendix F Procedure 1 and Part 60, Appendix B Performance Specification 2 (PS 2), or shall meet equivalent specifications established by mutual agreement of the District, the ARB, and the EPA. [District Rule 1080, and 40 CFR 60.4345(a)] Federally Enforceable Through Title V Permit

30. In accordance with 40 CFR Part 60, Appendix F, 5.1, the CEMS must be audited at least once each calendar quarter. The District shall be notified prior to completion of the audits. Audit reports shall be submitted along with quarterly compliance reports to the District. [District Rule 10801 Federally Enforceable Through Title V Permit

3 1. The requirements in 40 CFR 60, Appendix F, shall be met through the following EPA and District approved modified procedures: I) annual RATA testing of at least one gas turbine engine (S-1129-868, '-869), and rotate the unit tested so that the two units are tested over two years, 2) annual MA testing for the one gas turbine engine for which the annual RATA testing is not performed, 3) if any of the gas turbine engines fail the MA testing, they must have'a RATA test within 60 days, and 4) for every quarter that RATA or MA testing is not performed, a CGA is to be performed for each gas turbine engine. [District Rule 10801 Federally Enforceable Through Title V Permit

32. APCO or an authorized representative shall be allowed to inspect, as determined to be necessary, the required monitoring devices to ensure that such devices are functioning properly. [District Rule 10801 Federally Enforceable Through Title V Permit

33. The CEMS data shall be reduced to hourly averages as specified in 40 CFR 60.13(h), or by other methods deemed equivalent by mutual agreement with the District, the ARB, and the EPA. [District Rule 1080 and 40 CFR 60.43501 Federally Enforceable Through Title V Permit

34. Upon written notice from the District, the owner or operator shall provide a summary of the data obtained from the CEMS. This summary shall be in the form and the manner prescribed by the District. [District, Rule 10801 Federally Enforceable Through Title V Permit

35. The facility shall install and maintain equipment, facilities, and systems compatible with the District's CEMS data polling software system and shall make CEMS data available to the District's automated polling system on a daily basis. Upon notice by the District that the facility's CEMS is not providing polling data, the facility may continue to operate without providing automated data for a maximum of 30 days per calendar year provided the CEMS data is sent to the District by a District-approved alternative method. [District Rule 1080f Federally Enforceable Through Title V Permit

36. The permittee shall maintain the following records: the date, time and duration of any malfunction of the continuous monitoring equipment; dates of performance testing; dates of evaluations, calibrations, checks, and adjustments of the continuous monitoring equipment; date and time period which a continuous monitoring system or monitoring device was inoperative. [District Rules 1080 and 2201 and 40 CFR 60.8(d)] Federally Enforceable Through Title V Permit

The owner or operator sha1.l submit a written report of CEM operations for each calendar quarter to the District. The report is due on the 30th day following the end of the calendar quarter and shall include the following: Time intervals, data and magnitude of excess NOx emissions, nature and the cause of excess (if known), corrective actions taken and preventive measures adopted; Averaging period used for data reporting corresponding to the averaging period specified in the emission test period used to determine compliance with an emission standard; Applicable time and date of each period during which the CEM was inoperative, except for zero and span checks, and the nature of system repairs and adjustments; A negative declaration when no excess emissions occurred. [District Rule 1080, 40 CFR 60.4375(a) and 40 CFR 60.43951 Federally Enforceable Through Title V Permit

38. Monitor downtime for NOx shall be any unit operating hour in which sufficient data are not obtained to validate the hour for either NOx concentration or diluent 0 2 (or both). [40 CFR 60.4380(b)(2)] Federally Enforceable Through Title V Permit

6.112ta6UM : Jun 21 2010 (:mu - EDOEHILR

Conditions for S-1129-869-0 (continued) Page 5 of 5

39. If the gas turbine system is not fired on PUC-regulated or FERC-regulated natural gas, then a fuel sample shall be collected during the source test to determine sulfur content of the fuel combusted in the turbine. The fuel sample shall be analyzed for the total sulfur content using ASTM D1072; D3246; D4084; D4468; D6228; or D6667; or double GC for H2S and mercaptans. The applicable ranges of some ASTM methods are not adequate to measure the levels of sulfur in some fuel gases. Dilution of samples before analysis (with verification of dilution ratio) may be used after getting a prior approval from the District. [40 CFR 60.44 1 5(a)(l)(i)] Federally Enforceable Through Title V Permit

40. A totalizing mass or volumetric fuel flow computer shall be utilized and maintained to calculate the amount of natural gas combusted based on measured flow meter parameters (fuel pressure and temperature) and gas composition. [District Rule 47031 Federally Enforceable Through Title V Permit

4 1. Except during black start, start-up shall not exceed 2.0 hours per event. [District Rule 47031 Federally Enforceable Through Title V Permit

42. Shutdown shall not exceed 2.0 hours per event. [District Rule 47031 Federally Enforceable Through Title V Permit

43. The emission control systems shall be in operation and emissions shall be minimized insofar as technologically feasible during startup (black start) and shutdown. [District Rule 47031 Federally Enforceable Through Title V Permit

44. Start-up is defined as the period of time during which a unit is brought from a shutdown status to its operating temperature and pressure, including the time required by the unit's emission control system to reach full operation. [District Rule 47031 Federally Enforceable Through Title V Permit

45. Shutdown is defined as the period of time during which a unit is taken from an operational to a non-operational status by allowing it to cool down from its operating temperature to ambient temperature as the fuel supply to the unit is completely turned off. [District Rule 47031 Federally Enforceable Through Title V Permit

46. Reduced load period is defined as the time during which a gas turbine is operated at less than rated capacity in order to change the position of the exhaust gas diverter gate. Each reduced load period shall not exceed one hour. [District Rule 47031 Federally Enforceable Through Title V Permit

47. A black start event is defined as the startup of a unit while the cogen plant is electrically separated from the utility grid. A black start shall not exceed 4.0 hours per event. [District Rules 2201 and 47031 Federally Enforceable Through Title V Permit

48. The owner or operator shall submit to the District information correlating the NOx control system operating parameters to the associated measured NOx output. The information must be sufficient to allow the District to determine compliance with the NOx emission limits of this permit when the CEMS is not operating properly. [District Rule 47031 Federally Enforceable Through Title V Permit

49. The owner or operator shall maintain a stationary gas turbine system operating log that includes, on a daily basis, the actual local startup and stop time, length and reason for reduced load periods,, total hours of operation, the type and quantity of fuel used, duration of each start-up (or black start) and each shutdown time period. [District Rule 47031 Federally Enforceable Through Title V Permit

50. The owner or operator shall maintain all records of required monitoring data and support information for a period of five years from the date of data entry and shall make such records available to the District upon request. [District Rules 220 1 and 47031 Federally Enforceable Through Title V Permit

5 1. Compliance with permit conditions in the Title V permit shall be deemed compliance with the following subsumed requirements: Kern County Rule 407; SJVUAPCD Rule 4703 6.2.1,6.2.4,6.3,6.4.1,6.4.2,6.4.3, and 6.4.5; 60.4320(a); 40 CFR 60.4330(a)(2); 40 CFR 60.4340(b)(l); 40 CFR 60.4345(a) and (b); 40 CFR 60.4350; 40 CFR 60.4360; 40 CFR 60.4365(a); 40 CFR 60.4370(c); 40 CFR 60.4375(a); 40 CFR 60.4380(b)(2); 40 CFR 60.4395; 40 CFR 60.4400(a); 40 CFR 60.4400(1)(i); and 40 CFR 60.441 5(a)(l)(i). A permit shield is granted from these requirements. [District Rule 2520, 13.21 Federally Enforceable Through Title V Permit