Summary
of
Teleconference
with
the
Gas
Turbine
Association
Regarding
the
Proposed
New
Source
Performance
Standards
for
Stationary
Combustion
Turbines
March
2,
2005
Attendees
Jaime
Pagán,
EPA
ESD
Combustion
Group
Christian
Fellner,
EPA
ESD
Combustion
Group
Sims
Roy,
EPA
ESD
Combustion
Group
Bob
Wayland,
EPA
ESD
Combustion
Group
Bruce
Rising,
Siemens
Westinghouse
Barbara
Bankoff,
Siemens
Westinghouse
Joel
Chalfin,
General
Electric
Jeanne
Beres,
General
Electric
Sonia
Adshead­
Farey,
Rolls
Royce
Tony
Brough,
Rolls
Royce
Rob
Wallace,
Rolls
Royce
Paul
Wiecek,
Alstom
Leslie
Witherspoon,
Solar
Jennifer
Snyder,
AGTI
Melanie
Taylor,
AGTI
Summary
of
Teleconference
The
purpose
of
the
teleconference
was
to
discuss
the
standards
of
performance
for
new
stationary
combustion
turbines
that
were
proposed
by
the
EPA
on
February
18,
2005
(
70
FR
8314).
During
the
telconference,
many
members
of
GTA
expressed
the
opinion
that
the
emission
levels
proposed
by
EPA
are
not
achievable
for
today's
turbines
without
the
use
of
add­
on
control
such
as
SCR.
Bruce
stated
that
not
that
many
turbines
emit
less
than
15
ppm
NOx,
especially
smaller
and
dual
fuel
turbines.
Bruce
remarked
that
GTA
had
sent
information
to
EPA
on
the
range
of
emissions
from
turbines.
For
frame
natural
gas
turbines,
the
range
is
9­
40
ppm
NOx
(
0.32­
1.24
lb/
MW­
hr).
For
aeroderivative
natural
gas
turbines,
the
range
is
25­
42
ppm
NOx.
Bruce
stated
that
the
emission
levels
proposed
by
EPA
deviate
substantially
from
the
levels
recommended
by
GTA.

Tony
said
that
he
believed
the
proposed
emission
levels
would
force
people
to
buy
either
large
combined
cycle
units,
or
inefficient
smaller
units.
Several
members
of
GTA
felt
that
midsize
turbines
(
30­
150
MW)
would
especially
have
trouble
meeting
the
proposed
limits.
According
to
GTA,
these
turbines
routinely
emit
around
25
ppm
NOx
and
some
emit
as
much
as
40­
50
ppm
NOx.
Paul
said
that
there
was
not
much
experience
using
high­
temperature
SCR
on
simple
cycle
turbines.
A
GTA
member
also
stated
that
most
new
aeroderivative
turbines
are
being
installed
with
SCR,
so
they
do
not
have
much
information
on
the
performance
of
the
turbines
without
SCR.
Bruce
stated
that
he
felt
the
projected
$
2
million
impact
of
the
proposed
rule
is
an
underestimate.

Leslie
Witherspoon
said
that
she
had
significant
concerns
with
the
1
lb/
MW­
hr
limit
for
small
turbines,
and
that
none
of
Solar's
turbines
would
meet
that
limit,
even
at
full
load.
Leslie
said
that
the
limit
for
oil­
fired
turbines
also
could
not
be
achieved.
Without
water
injection,
Solar's
turbines
emit
96
ppm
NOx
on
oil,
although
on
occasion
they
have
guaranteed
65
ppm
with
certain
operating
restrictions.
She
said
that
people
will
be
forced
to
use
reciprocating
engines
instead
of
turbines,
and
pointed
out
that
those
engines
emit
three
to
four
times
as
much
as
turbines.
Leslie
said
that
turbine
owners
are
afraid
to
retrofit
their
turbines
with
SoLoNOx
because
they
don't
want
to
trigger
NSR.
Leslie
also
noted
that
New
Jersey's
State
of
the
Art
Manual
for
turbines,
which
came
out
in
January,
had
NOx
limits
of
65
ppm
for
liquid
fuel.

Christian
said
that
EPA
had
looked
at
NOx
emission
data
from
the
Clean
Air
Markets
Division
(
CAMD)
and
the
data
showed
that
more
than
75
percent
of
the
units
were
achieving
0.39
lb/
MW­
hr.
Bruce
stated
that
the
data
may
be
misleading
because
it
may
be
mainly
for
large
units
equipped
with
emission
controls.
Jaime
said
that
EPA
looked
at
data
for
turbines
that
did
not
have
add­
on
control.
Bob
also
pointed
out
that
turbine
manufacturers
had
not
objected
to
the
the
limits
proposed
for
turbines
by
the
Clear
Skies
Act
of
2003,
and
that
the
limits
in
the
proposed
NSPS
were
not
as
stringent
as
the
Clear
Skies
limits.

Jaime
stated
that
EPA
feels
that
the
limits
are
achievable
according
to
the
data
obtained
by
EPA.
The
limit
was
set
at
a
level
that
EPA
felt
would
not
require
the
use
of
SCR.
Jaime
acknowledged
that
EPA
has
some
gaps
in
its
data
and
noted
that
EPA
requested
data
in
the
proposal
preamble.
Jaime
encouraged
the
members
of
GTA
to
provide
their
comments
on
the
rule,
including
detailed
information
in
the
form
of
source
test
reports
and
permits
on
why
the
limits
are
not
achievable.
After
EPA
receives
the
comments,
EPA
can
set
up
another
meeting
with
GTA
to
discuss
their
comments
and
concerns.
