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7-3 Air

Please clarify the proposed permit operation limit(s) proposed for the combustion turbines when using ULSD.

7-3       Proposed Air Permit Limits for use of ULSD in the Combustion Turbines

            Please clarify the proposed permit operation limit(s) proposed for the combustion turbines when using ULSD.  

  • How is “the equivalent total ULSD fuel usage of up to 60 days per year at base load” calculated? 
  • What is the basis for calculating daily ULSD fuel usage? 
  • Does the facility propose an annual ULSD operation limit of 720-hours per year at steady state for each combustion turbine?
  • Does the facility propose an annual ULSD startup & shutdown operation limit of 20-hours per year for each combustion turbine?  

            Table 1 shows estimated annual emissions from each combustion turbine when using ULSD based upon using an Annual Operation value of 720-hours/year.  An annual operating rate of 720-hours is equivalent to 30-days (720-hours * (1-day/24-hours) = 30-days).  An annual operating rate of 60-days is equivalent to 1440-hours (60-days * (24-hrs/1-day) = 1440-hours).  Is the facility proposing to limit ULSD operation on an individual combustion turbine basis at 30-days/year or on an aggregate basis of 60-days/year to be split between the two combustion turbines on not necessarily a 50:50 basis?

RESPONSE 7-3

 

Invenergy is not proposing an annual limit on the number of days of combustion turbine ULSD usage per year nor is Invenergy proposing individual ULSD usage limits for each turbine.  Invenergy is proposing to limit total ULSD usage by both combustion turbines to the equivalent usage of 60 days at base load.  This will be calculated by multiplying the maximum single turbine ULSD usage rate at base load (gallons per hour) times 24 hours per day (gallons per day) times 60 days (gallons per 60 days).

 

Invenergy is not proposing a limit on the number of hours of ULSD startup and shutdown time per year.  Invenergy is proposing that the annual emissions from the facility during startup and shutdown periods be limited to the total potential emissions presented in the air permit application for startup and shutdown periods.     

 

RESPONDENT:

 

Michael Feinblatt, ESS Group, Inc.

 

DATE:

May 17, 2016