7-28 HRAP dated June 26, 2015
7-28 Section 1.2 indicates that vendor for combustion turbines will be selected before major source permit finalized, but the major source permit was submitted concurrent with this document (permit also dated June 26, 2015). The turbine equipment is identified in subsequent HRA (dated Jan. 27, 2016), Section 1.2. Please verify that the equipment identified in HRA Section 1.2 is the selected equipment and representative of what is modeled in the air modeling report and the air permit application.
RESPONSE 7-28
| CREC will consist of two General Electric 7HA.02 gas turbines. AERSCREEN was applied to determine the gas turbine and operating condition which resulted in the highest predicted ambient air impact concentrations for each pollutant and averaging period. This screening analysis was applied for each of the three turbines (GE, Siemens, MHI) being considered at the time for the project.
The turbine and operating condition which exhibited the highest modeled impact concentration for each pollutant and averaging period was then modeled using AERMOD for the compliance determinations. The use of the turbine and operating condition with the highest predicted impact concentration for each pollutant and averaging period, which was approved by RIDEM, produced modeling results that were conservative and applicable regardless of which turbine was selected for the project. For any pollutant averaging period for which the Siemens or MHI turbine was used to demonstrate compliance, the modeled impacts from the GE turbine will be lower than the values presented, providing further assurance of compliant operation.
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RESPONDENT:
| Michael Feinblatt, ESS Group, Inc.
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DATE: | May 17, 2016
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