Summary
of
Teleconference
with
the
Gas
Turbine
Association
Regarding
the
Proposed
New
Source
Performance
Standards
for
Stationary
Combustion
Turbines
March
23,
2005
Attendees
Jaime
Pagán,
EPA
ESD
Combustion
Group
Sims
Roy,
EPA
ESD
Combustion
Group
Bruce
Rising,
Siemens
Westinghouse
Barbara
Bankoff,
Siemens
Westinghouse
Jordan
Haywood,
Siemens
Westinghouse
Leslie
Witherspoon,
Solar
Jennifer
Snyder,
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).
In
particular,
the
discussion
focused
on
the
subject
of
the
Gas
Turbine
Association
(
GTA)
providing
actual
test
data.

The
GTA
understands
that
EPA
is
looking
for
small,
oil
fired
turbine
test
data,
as
the
amount
of
data
gathered
to
date
as
shown
in
the
supporting
documents
is
not
ideal.
Bruce
stated
that
raw,
average,
nominal
field
data
will
not
give
statistical
variations
of
what
is
actually
achievable
for
all
turbines.
Bruce
suggested
a
2.5
to
3
sigma
variability
for
setting
the
standard.

The
subject
of
manufacturer
guarantees
came
up.
The
GTA
pointed
out
that
while
emission
levels
may
differ
between
manufacturers,
it
may
happen
that
they
have
the
same
emission
level
guarantee.
Each
manufacturer
has
a
different
risk
margin
that
it
is
willing
to
bear.
These
risk
margins
are
based
on
manufacturer
test
data,
and
OEM's
are
not
willing
to
let
their
variability
be
known
to
the
general
public.
Therefore,
they
are
hesitant
to
provide
EPA
with
data.
The
EPA
assured
GTA
that
this
data
would
be
treated
as
confidential
business
information
(
CBI).

The
EPA
emphasized
that
stack
test
data
is
what
they
seek,
without
add­
on
controls.
Bruce
replied
that
most
turbines
from
75
to
100
MW
have
SCR.
The
EPA
asked
why
these
turbines
would
be
an
issue
for
them,
as
they
would
easily
meet
EPA's
proposed
NSPS
emission
limits.
Bruce
replied
that
there
are
some
simple
cycle
turbines
without
add­
on
controls.
The
EPA
requested
this
stack
test
data.

Leslie
stated
that
most
Solar
turbines
do
not
have
SCR,
as
it
is
not
cost
effective.
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.

In
regards
to
oil
fired
turbine
test
data,
Leslie
said
that
she
has
asked
many
of
her
customers
for
test
data
on
these,
but
states
do
not
require
testing
on
secondary
fuels,
so
there
are
none.
Therefore,
the
best
data
she
can
provide
on
oil
fired
turbines
are
test
cell
data.
She
said
these
aren't
"
real"
test
reports.
They
meet
the
intent
of
Method
20,
but
are
not
tested
at
4
operating
loads.
In
her
opinion,
test
cell
data
would
need
to
be
treated
as
highly
confidential.
Leslie
mentioned
the
New
Jersey
State
of
the
Art
Manual.
She
convinced
the
state
of
New
Jersey
to
up
their
limit
on
small
turbines
to
65
ppm.
On
occasion,
Solar
has
warrantied
65
ppm
on
their
oil
fired
turbines,
with
specific
restrictions
on
their
operating
conditions.

Regarding
simple
cycle
turbine
emissions,
Leslie
pointed
out
that
at
part
loads,
the
NOx
concentration
is
lower
than
at
full
loads
(
on
a
ppm
or
lb/
hr
basis),
yet
on
an
output
basis,
the
NOx
emissions
seem
to
increase,
due
to
lower
efficiencies
at
lower
loads.
She
claims
that
a
lower
environmental
impact
is
seen
with
the
lower
volume
of
emissions,
yet
partial
load
is
required
in
order
to
meet
65
ppm.

Leslie
said
that
turbine
owners
are
afraid
to
retrofit
their
turbines
with
SoLoNOx
because
they
don't
want
to
trigger
New
Source
Review.
Sims
stated
that
under
the
part
60
provisions,
which
cover
NSPS,
if
emissions
are
reduced
it
is
not
considered
a
modification,
and
would
thus
not
trigger
NSPS.

According
to
Leslie,
the
used
equipment
market
is
a
big
issue
with
regards
to
being
able
to
meet
the
emission
limits
of
the
proposed
NSPS.
Sims
stated
that
even
if
it
is
an
old
turbine
at
a
new
site
(
without
meeting
the
definitions
of
reconstruction
or
modification),
it
is
still
subject
to
subpart
GG,
not
subpart
KKKK.
Change
in
ownership
does
not
change
applicability.
Sims
stated
that
he
was
writing
a
memo
to
OECA
stating
that
this
was
how
he
interpreted
the
rule.

Leslie
stated
that
there
are
instances
when
industry
may
want
to
uprate
a
turbine.
One
example
she
gave
was
when
there
are
three
to
four
turbines
on
an
offshore
platform
that
are
no
longer
running
near
full
load
at
all.
One
solution
to
this
problem
is
to
"
uprate"
two
of
the
units
and
remove
the
others,
so
that
the
two
units
can
cover
the
power
requirements
of
the
previous
number
of
turbines,
running
at
higher
loads
and
thus
more
efficiently.
She
stated
that
though
improvements
would
be
made
to
the
turbine,
which
may
fall
under
the
definitions
of
modification
or
reconstruction,
no
lower
emissions
would
result.
Therefore,
it
is
a
concern
that
these
turbines
might
be
subject
to
NSPS.

The
GTA
stated
that
if
the
NSPS
emission
limits
were
increased
to
42
ppm
instead
of
25,
an
estimated
90%
of
issues
would
diminish;
however,
Solar
Saturn
turbines
would
still
not
be
able
to
meet
this
limit.

Sims
asked
if
refurbished
units
would
be
tested
by
the
turbine
manufacturers;
Leslie
replied
that
she
believed
so,
but
would
check
into
this.

Jaime
encouraged
the
members
of
GTA
to
provide
their
written
comments
on
the
rule,
including
detailed
information
in
the
form
of
source
test
reports
and
permits
on
why
the
limits
are
not
achievable.
