7-8 Air

Please provide rationale for selecting the stayed MACT Standard as the emission factor source during firing of natural gas described in Section 5.3.10, but not ULSD.

7-8       The partial-stayed EPA MACT Standard for Combustion Turbines (40 CFR 63, Subpart YYYY) published on March 5, 2004 limited formaldehyde emissions to 91 ppbvd @ 15% O2 when firing natural gas, as well as during the firing of oil.  Please provide rationale for selecting the stayed MACT Standard as the emission factor source during firing of natural gas described in Section 5.3.10, but not ULSD.

RESPONSE 7-8

 

The combustion turbine formaldehyde emission factor, which was provided by the equipment manufacturer, utilized the stayed MACT Standard as the emission factor source during both natural gas firing and ULSD firing.

 

RESPONDENT:

 

Michael Feinblatt, ESS Group, Inc.

 

DATE:

May 17, 2016