7-7 Air

Emission Calculations – Emission Factors

7-7       Emission Calculations – Emission Factors

            Emission factors used to calculate estimated emissions and submitted to RIDEM were difficult to verify, as no references were provided.  For emission factors based on US EPA AP-42, please specify Chapter and Table for each emission factor or group of emission factors.

 

            For those emission factors used in the calculations that are not based on AP-42, please provide a copy of the reference document used as source for the emission factor(s).

 

RESPONSE 7-7

 

The criteria pollutant emission rates from all project emissions sources were provided by the equipment manufacturer.  The combustion turbine ammonia and sulfuric acid emission rates were also provided by the equipment manufacturer.  The metals emissions from gas turbine ULSD usage were estimated using Siemens Westinghouse’s Survey of Ultra-Trace Metals in Gas Turbine Fuels (2004), which is attached.  The gas turbine formaldehyde emissions were provided by the equipment manufacturer based on the MACT standard for combustion turbines (91 ppb@15%O2) previously proposed by the EPA, but currently stayed by court order.

All of the other non-criteria pollutant emission rates from each emissions source were estimated using emission factors from the EPA’s AP-42 Compilation of Emission Factors

The following tables from AP-42 were used:

AP-42 Chapter 1.4, Table 1.4-3: Emission Factors for Speciated Organic Compounds from Natural Gas Combustion

AP-42 Chapter 1.4, Table 1.4-4: Emission Factors for Metals from Natural Gas Combustion

AP-42 Chapter 3.1, Table 3.1-3: Emission Factors for Hazardous Air Pollutants from Natural Gas-Fired Stationary Gas Turbines

AP-42 Chapter 3.1, Table 3.1-4: Emission Factors for Hazardous Air Pollutants from Distillate Oil-Fired Stationary Gas Turbines

AP-42 Chapter 3.1, Table 3.1-5: Emission Factors for Metallic Hazardous Air Pollutants from Distillate Oil-Fired Stationary Gas Turbines

AP-42 Chapter 3.3, Table 3.3-2: Speciated Organic Compound Emission Factors for Uncontrolled Diesel Engines

AP-42 Chapter 3.4, Table 3.4-3: Speciated Organic Compound Emission Factors for Large Uncontrolled Stationary Diesel Engines

AP-42 Chapter 3.4, Table 3.4-4: PAH Emission Factors for Large Uncontrolled Stationary Diesel Engines     

RESPONDENT:

 

Michael Feinblatt, ESS Group, Inc.

 

DATE:

May 17, 2016