Proposal:

Amend Rule 1134 - Emissions of Oxides of Nitrogen from Stationary Gas Turbines

Synopsis:

The proposed amendment to Rule 1134 subdivision (d) clarifies that CEMS are required only on cogeneration and combined cycle units, 2.9 megawatts and larger. This clarification is needed to make the rule language consistent with AQMD practice and the intent stated in the Rule 1134 Administrative Record. The proposed amendment to paragraph (f)(5) addresses EPA’s requirement that a person operating an emission control system maintain a daily record of continuous system operation and maintenance to demonstrate proper operation and compliance.

Committee:

None.

Recommended Action:

1. Certify the Notice of Exemption for Proposed Amended Rule 1134 - Emissions of Oxides of Nitrogen from Stationary Gas Turbines; and

2. Amend Rule 1134 - Emissions of Oxides of Nitrogen from Stationary Gas Turbines, as proposed in accordance with the attached Resolution.

Barry R. Wallerstein, D.Env.
Interim Executive Officer

Background

Rule 1134 was adopted August 4, 1989 and subsequently amended December 7, 1995 and April 11, 1997. The 1995 amendments exempted gas turbine units rated below four megawatts (MW) and operating less than 877 hours located both in the South East Desert Air Basin and on San Clemente Island. In addition, the requirement to continuously correct the reference NOx emission limits to the International Standards Organization (ISO) standard to account for variations in ambient temperature, pressure and humidity changes was removed. The 1997 amendments increased the NOx emission limit for 2.9 to less than 10.0 MW turbines utilizing sewage digester gas from 9 to 25 ppm. This amendment only affected one facility.

The purpose of the current Rule 1134 is to limit NOx emissions from existing gas turbine units rated at 0.3 MW and larger in size which, prior to August 4, 1989, were issued a valid Permit to Construct or Permit to Operate by AQMD, or were in operation pursuant to the provisions of AQMD Rule 219(b)(1). The rule requires each engine to meet specific NOx emission limits based on unit size. If those limits cannot be met without controls, then controls must be applied, which usually consists of selective catalytic reduction (SCR). A correction for thermal efficiency is also applied to the limit. All of the existing gas turbine units have met the requirements of the rule.

Proposal

This rule amendment proposes language in subdivision (d) clarifying that only cogeneration and combined cycle gas turbine units 2.9 MW and larger are required to install, operate, and maintain an in-stack CEMS for NOx and oxygen. This was the original intent of the rule as clearly stated in the original staff report .

In addition, the proposal includes a SIP-required change by U.S. EPA, to amend paragraph (f)(5) to include daily records to be kept that demonstrate continuous system operation and maintenance of emission control systems.

AQMP and Legal Mandates

The proposed amendments were placed on the Board agenda with a 30-day public notice. No public workshop is necessary because the proposed amendments will not significantly affect air quality or emission limitations.

Policy Issues

The current rule clearly states that all stationary gas turbine units subject to this rule need to install, operate, and maintain a CEMS. However, the original intent stated in the Rule 1134 Administrative Record and AQMD practice has been to require CEMS on only cogeneration and combined cycle gas turbine units 2.9 MW and larger. The rule language must be modified to meet this practice.

CEQA & Socioeconomic Analysis

The proposed amendments to Rule 1134 are a "project" pursuant to CEQA. Staff has reviewed the proposed project in accordance with state CEQA Guidelines Section 15002 (k)(1) to determine whether it is subject to CEQA at all. Staff has determined that proposed amendments to Rule 1134 are exempt from the provisions of CEQA pursuant to state CEQA Guidelines Section 15061 (b)(3) because it can be seen with certainty that there is no possibility that the proposed project will have a significant adverse effect on the environment. A Notice of Exemption will be prepared pursuant to state CEQA Guidelines Section 15062 and filed with the county clerks immediately upon adoption of the proposed amendments.

Implementation Plan

No implementation plan is expected since the proposed amendments do not affect any applicable facilities.

Resource Impacts

Not applicable.

Attachments

A- Summary of Proposed Amendments
Resolution
Proposed Rule Language
Letter of Exemption and Notice Exemption

/ / /

ATTACHMENT A

Summary of Proposed Amendments to Rule 1134 - Emissions of Oxides of Nitrogen from Stationary Gas Turbines

· To limit the requirement to install, operate and maintain an in-stack CEMS for NOx and oxygen for cogeneration and combined cycle stationary gas turbine units 2.9 MW and larger.

· To require daily records of system operation and maintenance which will demonstrate continuous operation and compliance of the emission control device.