7-5 Air
7-5 Emission Calculations – General
Please explain why the Combustion Turbine potential emissions for Criteria Pollutants are estimated using Annual Operation (per Unit) values of 8020-hours/year for Natural Gas and 740-hours/year for ULSD, but potential emissions for Non-Criteria Pollutant are estimated using 8040-hours/year for Natural Gas and 720-hours for ULSD.
RESPONSE 7-5
| The criteria pollutant potential emissions were estimated for each combustion turbine based on 7,865 hours per year firing natural gas at steady-state, 720 hours per year firing ULSD at steady-state, 155 hours per year firing natural gas during startup and shutdown, and 20 hours per year firing ULSD during startup and shutdown. The criteria potential emission rates during steady state operation and during startup and shutdown periods on both fuels were provided by the turbine manufacturer.
The non-criteria pollutant potential emissions were estimated for each combustion turbine based on 8,040 total hours per year firing natural gas and 720 total hours per year firing ULSD during steady-state operation only. Based on the available emission factors, the non-criteria pollutant emissions from the combustion turbines will be proportional to fuel usage, and will therefore be lower during startup and shutdown periods, because less fuel is being burned. To be conservative, the non-criteria pollutant potential emissions were estimated assuming steady-state operations only, which would include up to 8,040 hours firing natural gas and up to 720 hours of firing ULSD per turbine per year.
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RESPONDENT:
| Michael Feinblatt, ESS Group, Inc.
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DATE: | May 17, 2016
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