1
Summary
of
Meeting
with
the
American
Petroleum
Institute
Representatives
Regarding
the
Combustion
Turbine
New
Source
Performance
Standards
April
7,
2005
Attendees
Jaime
Pagán,
EPA
ESD
Combustion
Group
Sims
Roy,
EPA
ESD
Combustion
Group
Christian
Fellner,
EPA
ESD
Combustion
Group
Bob
Wayland,
EPA
ESD
Combustion
Group
Terry
Harrison,
EPA
EMC
Dick
Karp,
API
Terry
Twyman,
API
Randy
Poteet,
ConocoPhillips
Jim
Pfeiffer,
BP
Exploration
John
Klein,
Rotor­
Therm
Bob
Morehouse,
ExxonMobil
Jennifer
Snyder,
AGTI
by
telephone:
Clay
Freeberg,
ChevronTexaco
John
Cain,
ChevronTexaco
Bill
Priebe,
Exxon
Mobil
Erik
Milito,
API
Stuart
Sessions,
Environomics
Purpose
of
Meeting
The
purpose
of
this
meeting
was
to
discuss
the
key
issues
identified
by
the
American
Petroleum
Institute
(
API)
regarding
the
proposed
Combustion
Turbine
New
Source
Performance
Standards
(
NSPS).
This
list
of
key
issues
was
provided
in
the
agenda,
and
includes
the
following:
applicability
to
various
sized
units,
modification
and
reconstruction,
NOx
emission
limit,
SO
2
emission
limit,
NOx
monitoring,
SO
2
monitoring,
and
definitions.

Issues
Discussed
Applicability
to
Various
Sized
Units
The
API
is
concerned
that
turbines
in
the
1
to
3
megawatt
(
MW)
size
range
may
not
be
able
to
comply
with
the
proposed
emission
limitations.
Dry
low
NOx
(
DLN)
technology
may
not
be
achievable
for
turbines
in
this
size
range.
The
API
suggested
moving
the
applicability
threshold
to
3
MW,
because
of
the
ability
to
apply
DLN.
They
noted
that
not
much
information
on
these
very
small
turbines
is
in
the
docket.
They
gave
examples
of
the
Solar
Saturn,
at
1.2
MW,
with
no
DLN
capability,
and
the
Centaur
40,
at
3.5
MW,
as
being
the
smallest
turbine
they
know
of
with
DLN
capability.
Jaime
asked
for
specific
emissions
data
from
small
turbines,
to
back
up
their
position.
Jim
Pfeiffer
stated
that
his
group
tested
a
Saturn
last
fall,
used
for
gas
compression,
at
one
load
point
(
70
or
80%),
and
he
would
look
into
providing
that
test
report
to
the
EPA.

Jaime
asked
if
other
manufacturers
made
turbines
in
this
size
range
which
would
not
be
able
to
meet
the
limit.
John
Klein
said
he
knew
of
no
other
manufacturer
in
this
size
range
which
would
make
turbines
applicable
to
the
gas
transmission/
compression
industry.
In
addition,
the
EPA
brought
up
that
Solar
said
that
no
new
Saturns
were
sold
in
the
US
at
this
time.
John
said
2
that
they
had
the
ability
to
buy
new
Saturns.

Bob
Wayland
stated
that
the
EPA
by
no
means
was
trying
to
exclude
any
turbine
manufacturers
from
the
marketplace,
but
it
was
apparent
that
Solar
had
made
no
strides
in
reducing
its
emissions
from
these
turbines
over
the
last
10
years
or
so.
He
noted
that
the
goal
of
the
NSPS
is
to
force
improvement
of
emissions.

Sims
pointed
out
that
Capstone,
a
microturbine
manufacturer,
has
a
0.5
MW
turbine
with
a
9
ppm
guarantee
on
their
NOx
emissions.
John
Klein
stated
that
these
turbines
are
for
generators,
and
are
not
suitable
for
mechanical
drive
units
due
to
their
compression
ratio.

John
Klein
stated
that
manufacturers'
guarantees
are
often
depended
on
when
writing
permit
limits.
Manufacturers
base
their
guarantees
on
fuel
type
and
location.
Sims
stated
that
when
comparing
actual
data
to
manufacturer
guarantees,
the
guarantees
are
higher
than
the
actual
emissions.
He
gave
an
example
that
GE
used
to
have
a
guarantee
of
30
ppm
on
CO
emissions,
with
actual
emissions
under
1
ppm.
When
pressured,
they
lowered
their
guarantee
to
10
ppm.
Sims
said
that
permit
information
would
be
good
to
examine
in
conjunction
with
actual
emissions
data.
John
stated
that
the
main
concern
was
the
margin
of
compliance.

Bob
Wayland
went
over
the
tentative
schedule:
late
July
or
early
August,
2005
for
finalizing
the
rule,
and
May
or
June,
2005
for
accepting
data.

Modification
and
Reconstruction
The
API
asked
whether
it
was
possible
to
not
cover
modified
or
reconstructed
turbines
in
the
NSPS.
The
EPA's
response
was
that
the
provisions
that
cover
the
aspects
of
modification
and
reconstruction
are
in
the
General
Provisions,
and
it
is
an
aspect
that
must
be
covered
by
each
NSPS.
The
API's
concern
is
that
some
turbines
which
currently
comply
with
subpart
GG
may
trigger
subpart
KKKK
through
modification,
and
that
they
would
have
to
go
through
extensive
and
expensive
measures
in
order
to
comply.
One
example
they
gave
was
space
limitations
on
offshore
platforms;
additional
controls
such
as
selective
catalytic
reduction
(
SCR)
or
even
the
conversion
to
DLN
(
which
may
incorporate
larger
control
panels
or
the
addition
of
fuel
analyzers)
may
exceed
the
space
limitations
on
these
platforms.
Arctic
locations
would
have
the
same
issues.

Even
despite
costs,
the
API
stated
that
the
achievability
was
an
issue
in
itself.
Old
turbines
with
minor
modifications
which
still
trigger
subpart
KKKK
may
be
able
to
meet
the
old
subpart
GG
limits,
but
may
never
be
able
to
get
as
low
as
a
brand
new
turbine.

One
question
the
API
brought
up
was
that
a
modification
may
be
applicable
to
the
sulfur
part
of
the
rule
(
i.
e.,
sulfur
dioxide
emissions
increase),
but
not
to
the
NOx
portion.
Would
they
then
be
subject
to
the
entire
subpart
KKKK?
The
EPA
acknowledged
that
this
is
an
issue
of
concern
that
needs
to
be
clarified
in
the
rule.
3
NOx
Emissions
The
primary
concern
of
the
API
regarding
NOx
emissions
is
part
load
operations.
In
particular,
they
brought
up
the
example
of
a
mechanical
drive
application
at
a
remote
site
in
the
oil
and
gas
industry,
that
takes
several
years
to
come
to
full
production.
During
the
startup
time,
there
is
continuous
drilling
and
thus
the
need
for
power;
however,
the
turbines
have
been
sized
for
full
production,
and
during
the
first
years
of
operation,
electrical
generators
at
these
sites
are
often
only
partially
loaded
because
the
site
has
not
yet
geared
up
to
full
production.
Ideally,
these
turbines
are
properly
sized
for
full
production,
and
the
hope
is
that
they
will
eventually
run
at
full
loads;
however,
sometimes,
this
is
not
the
case,
and
the
generators
continue
operation
at
substantially
lower
loads.
Notwithstanding,
even
if
the
turbine
is
properly
sized,
when
the
production
starts
to
decline,
the
turbines
will
run
at
lower
loads
than
ideal.
This
leads
to
decreased
efficiency,
and
thus
a
higher
output­
based
emission.
When
running
at
low
loads,
it
is
hard
to
keep
SOLONOx
running.
Some
applications
have
added
load
banks
to
increase
the
load
artificially,
so
that
SOLONOx
would
kick
in;
however,
this
does
not
make
sense
on
a
mass
emissions
basis.

Ambient
temperature
was
another
issue
raised.
Lean
premix
(
LPM)
technology
has
difficulties
in
cold
weather,
and
emissions
for
several
manufacturers
are
not
guaranteed
below
0
degrees
F.
Winter
temperatures
on
the
North
Slope
in
Alaska
can
average
­
18
degrees
F,
and
can
go
down
to
­
50
degrees
F.

The
API
pointed
out
a
North
Slope
turbine
in
the
docket,
a
Solar
Centaur
50,
where
they
had
graphed
efficiency,
load,
and
ppm.
The
EPA
stated
that
they
had
also
done
some
similar
graphs,
and
acknowledged
that
efficiency
at
lower
loads
is
an
issue.
The
API
suggested
defining
a
load
range
where
the
limit
is
applicable.
The
EPA
suggested
more
use
of
load
banks.
The
API
said
this
wouldn't
be
feasible
with
mechanical
drive
units.
They
added
that
this
isn't
an
issue
for
GG
units,
since
it
requires
testing
at
the
maximum
achievable
load.

Bob
Wayland
asked
for
their
suggestions.
They
gave
the
following
alternatives:
1.
A
limitation
on
compliance
(
only
need
to
comply
at
or
near
full
load).
2.
Defer
the
performance
test
until
LPM
can
be
demonstrated.
3.
Change
the
standard
to
a
concentration
basis,
which
would
remove
efficiency
from
the
equation.

Regarding
the
second
suggestion,
the
EPA
asked
the
API
to
expand
on
their
typical
schedule
from
startup
of
the
field
drilling
to
the
maximum
achievable
load.
They
gave
an
example
of
a
25
MW
turbine,
operating
10
MW
in
the
first
year,
15
MW
in
the
second
year,
and
22
MW
in
the
third
year.
Jaime
said
that
one
concern
is
that
waiting
3
to
5
years
before
demonstrating
compliance
is
not
really
feasible
on
the
EPA's
schedule.
The
API
stated
that
the
State
of
Alaska,
when
requiring
the
demonstration
of
BACT,
would
ask
them
to
"
project"
emissions
at
full
load,
4
using
emission
curves
generated
by
the
manufacturer,
specific
to
the
turbine
model.

SO
2
Emission
Limit
The
API
stated
that
they
have
an
issue
with
the
proposed
sulfur
limit
in
subpart
KKKK
that
is
largely
specific
to
Alaska.
At
this
point,
there
are
no
restrictions
on
the
sulfur
levels
on
their
existing
fuels.
To
their
knowledge,
there
are
no
500
ppm
sulfur
fuels
available,
and
there
won't
be
until
2008.
Alaska
falls
under
an
exemption
from
the
OTAQ
Federal
requirements
for
low
sulfur
diesel
fuel.
In
the
next
few
years
(
2007),
it
is
projected
that
a
few
plants
will
be
producing
15
ppmw
(
those
that
were
exempted
from
the
500
ppmw
rule
are
expected
to
catch
up
when
the
rest
of
the
country
meets
their
15
ppm
requirements.)
Currently,
however,
the
sulfur
levels
range
between
1000
and
2500
ppm.
The
API
requested
that
the
EPA
delay
the
SO
2
emission
limitation
for
Alaska
until
January
of
2008.

NOx
Monitoring
The
API
believes
that
the
EPA's
cost
estimates
of
$
4,000
to
$
7,000
for
annual
source
testing
(
one
and
two
fuels,
respectively)
is
an
underestimate.
In
their
experience,
$
15­
20,000
is
more
accurate,
and
this
number
only
reflects
the
test
itself.
They
believe
there
should
be
an
additional
cost
considered­­
that
of
administrative
expenses,
downtime,
and
production
impacts.
John
Klein
added
that
somewhere
in
the
docket
or
preamble
he
believes
there's
a
mistake;
that
instead
of
using
the
$
4,000
or
$
7,000
multiplier,
the
EPA
used
$
1,000
inadvertently.
By
his
estimates,
the
total
for
performance
costs
would
be
more
on
the
order
of
$
8
million.
He
stated
that
these
numbers
would
be
more
detailed
in
the
formal
written
comments,
to
be
submitted
during
the
comment
period
for
the
proposed
rule.

The
EPA
suggested
that
the
API
come
up
with
some
alternatives
that
would
be
suitable
to
them
to
reduce
costs.
One
option
would
be
to
reduce
the
frequency
of
compliance
demonstration
if
compliance
is
shown
consistently
year
to
year.

Another
issue
raised
was
the
requirement
for
4
parameters
to
monitor
when
setting
up
parametric
monitoring
with
a
diffusion
flame
turbine.
The
API
felt
that
there
may
not
always
be
4
parameters
that
are
valid
to
monitor
in
order
to
determine
proper
operation,
and
that
when
writing
a
monitoring
plan,
the
operator
should
be
allowed
to
explain
what
is
needed
to
demonstrate
compliance,
and
should
be
able
to
determine
his
own
number
of
parameters
to
monitor
in
order
to
achieve
this.
They
suggested
that
the
EPA
specify
a
relative
accuracy
to
meet,
rather
than
a
specific
number
of
parameters.

SO
2
Monitoring
The
API
requested
that
some
additional
test
methods
for
sulfur
and
sulfur
dioxide
monitoring
be
included
in
subpart
KKKK.
Terry
Harrison
of
the
Emission
Measurement
Center
of
EPA
suggested
that
copies
of
the
methods
be
sent,
so
that
the
EPA
could
review
and
5
potentially
approve
these
methods.
In
addition,
they
felt
that
the
cutoff
for
allowing
no
daily
testing
of
300
ppm
was
unreasonable.
They
asked
why,
for
example,
a
350
ppm
S
fuel
might
not
be
exempt
as
well,
as
long
as
there
were
a
sufficient
confidence
interval
(
i.
e.
99%).
The
EPA
pointed
out
that
alternative
monitoring
schedules
are
included
in
the
rule.
They
also
pointed
out
that
most
of
their
tariff
sheets
specify
20
grains
per
100
scf,
which
is
the
equivalent
of
680
ppm.
It
was
also
noted
that
other
tariff
sheets
offer
5,
10
and
15
grains
per
100
scf.

Definitions
According
to
the
API,
the
definitions
given
in
the
proposed
subpart
KKKK
for
base
load
and
peak
load
are
confusing,
and
do
not
agree
with
standard
industry
definitions.
Gas
Turbine
World
cites
"
base
load"
when
specifying
the
ratings
of
simple
cycle
turbines,
which
is
essentially
the
same
as
"
continuous
load,"
according
to
the
API.
For
peaking
turbines,
which
do
not
have
to
hold
a
load
consistently,
and
thus
can
handle
more
stressed
intense
conditions
for
a
short
amount
of
time,
the
specified
"
peak
load"
allows
the
turbine
to
operate
at
a
higher
power
level
than
the
base
load
rating.
The
API
suggested
that
the
EPA
change
these
definitions
in
order
to
be
consistent
with
those
used
in
standard
industry
practice.

The
definition
of
"
excess
emissions"
also
was
a
point
of
contention.
The
API
believes
that
this
term
is
confusing,
since
other
rules
refer
to
these
as
"
excursions,"
to
avoid
the
implication
that
any
"
excess
emission"
is
a
period
of
non­
compliance.
They
would
like
to
see
the
term
"
excess
emission"
refer
to
only
a
point
in
time
where
emissions
are
greater
than
those
allowed
by
emission
limitations,
rather
than
including
periods
when
monitored
parameters
are
outside
their
range.
The
EPA
pointed
out
that
an
"
excess
emission"
is
not
necessarily
a
violation
or
a
period
of
non­
compliance,
and
that
it
is
merely
terminology.
The
API
stated
that
in
other
rules,
such
as
the
Miscellaneous
Organic
Chemical
Manufacturing
(
MON)
MACT,
the
term
"
excess
emissions"
was
restricted
to
only
"
emissions
greater
than
those
allowed
by
the
emission
limit."
