ECD General Permit Framework · 0.60 g/bhp-hr, 73 ppmvd @ 15 percent O 2 ROC 0.24 g/bhp-hr, 83.5 ppmvd @ 15 percent O 2 CO 1.80 g/bhp-hr, 359 ppmvd @ 15 percent O 2 Compliance shall

DRAFT

Authority to Construct 13862

Page 1 of 15

EQUIPMENT OWNER:

California Power Partners, Inc. 320400

EQUIPMENT OPERATOR:

California Power Partners, Inc.

EQUIPMENT LOCATION:

520 E. Yanonali Street, Santa Barbara

STATIONARY SOURCE/FACILITY:

AUTHORIZED MODIFICATION:

This permit authorizes the installation of an electrical generation unit consisting of an 896 hp IC

engine and a 650 kW generator fired on digester gas from the El Estero Waste Water Treatment Plant.

EQUIPMENT DESCRIPTION:

The equipment subject to this permit is listed in the table at the end of this permit.

PROJECT/PROCESS DESCRIPTION:

The El Estero Waste Water Treatment Plant is constructing a cogeneration plant at their facility. This

project includes replacing two 300 kW Biogas Fuel Cell Generators (depermitted under Reeval 07649

R7) with one 650 kW Reciprocating Biogas-fired Generator. The replacement generator will be built,

operated, and owned by California Power Partners, Inc. This Martin Machinery MGG-927 generator

is rated to operate between 500 and 650 kW and consists of a modified Guascor IC-G-B-56-034 IC

engine rated at 896 hp. In order to meet electrical demands the engine will run on a maximum of 25

percent natural gas for up to 522 hours during the year. At all other times, the engine will burn

exclusively on digester gas from El Estero Waste Water Treatment Plant. The system is equipped

City of Santa Barbara - El Estero WWTP SSID: 02059

CalPower - El Estero FID: 11391

DRAFT


Page 2 of 15

with continuous emission monitoring systems (CEMS) for NOx and CO which telemeters the

emissions data to the District's centralized Data Acquisition System (DAS).

CONDITIONS:

1. Emission Limitations. The mass emissions from the equipment permitted herein shall not exceed

the values listed in Table 1 and Table 2. Compliance shall be based on the operational, monitoring,

source testing, recordkeeping and reporting conditions of this permit.

a. BACT and NSPS Emissions Limits. Emissions from the generator engine shall not exceed the

BACT limits of:

NOx 1 0.60 g/bhp-hr, 73 ppmvd @ 15 percent O2

ROC 0.24 g/bhp-hr, 83.5 ppmvd @ 15 percent O2

CO 1.80 g/bhp-hr, 359 ppmvd @ 15 percent O2

Compliance shall be based on annual source testing according to Table 3 and 6-minute average

data points through the use of CEMS. Compliance with the BACT limits ensures compliance

with NSPS emission limits.

b. CEMS Emissions Excursions. Excursions of CEMS concentrations (ppmv @ 15% O2) for

NOx or CO that are determined by the District to be directly attributable to digester gas

quality irregularities will not be considered a violation of this condition provided a corrective

action plan is implemented as required by Condition 9.

2. Operational Restrictions. The equipment permitted herein is subject to the following operational

restrictions. Compliance with these requirements ensures compliance with NSPS operational

restrictions.

a. Heat Input Limits. The hourly, daily and annual heat input limits to the engine shall not

exceed the values listed in Table 2.1. These limits are based on the design rating of the

engine. Compliance with the heat input limits shall be based on both fuel meter readings and

the current weekly fuel gas (HHV-based) analysis.

TABLE 2.1 HEAT INPUT LIMITS

IC Engine

Make/Model Device No.

Heat Input Limits

(MMBtu/hr) (MMBtu/day) (MMBtu/yr)

Guascor IC-G-B-56-034 115220 7.639 183.336 66,917.64

1 NOx as NO2

DRAFT


Page 3 of 15

b. Usage Limits – Planned Startup/Shutdown Mode. Planned Startup/Shutdown is defined as

the period of time in which the engine is being taken out of service or brought back into

service after maintenance work has been completed, and the engine is not operating at its

designed temperature and load. Operation of the engine during these periods is limited to:

i. Heat Input Limit. 3.820 MMBtu/day, 26.737 MMBtu/quarter, and

106.948 MMBtu/yr.

ii. Operating Hours. 0.5 hour/day, 3.5 hours/quarter, and 14 hours/year.

c. Digester Gas Fuel Sulfur Limit. The total sulfur content (calculated as H2S at standard

conditions, 60o F and 14.7 psia) of the digester gas fuel combusted in the engine shall not

exceed 0.63 grains per 100 cubic feet (10 ppmvd). Compliance with this condition shall be

based on quarterly sampling in accordance with ASTM-D1072 or a District approved

equivalent method.

d. Fuel Type Limit. The engine may only be fired on natural gas and digester gas. The engine

shall not operate on any other auxiliary fuel.

e. Fuel Meters. The engine fuel flow meters for both the natural gas and digester gas shall be

calibrated according to manufacturer’s specifications and frequencies, or more frequently if

and when anomalous readings occur. Calibration records shall be maintained and made

available for District inspection.

f. Digester Gas Release. Operation of this equipment shall not result in the release of raw

digester gas into the atmosphere. Any breakdown 2 or malfunction which results in emissions

of raw digester gas shall be reported to the District (Attn: Engineering Supervisor) within one

hour of occurrence, and immediate remedial measures shall be undertaken to correct the

problem and prevent further emissions into the atmosphere.

g. Digester Gas Limits. Operation of the engine shall either reduce non-methane organic

compounds (NMOC) by at least 98 percent by weight from the raw digester gas fuel

concentrations, or reduce the outlet NMOC concentration to less than 20 ppm by volume, dry

basis as hexane at 3 % O2 when fired on digester gas.

2 Rule 505 breakdown relief is available for administrative relief from enforcement action for

qualifying breakdowns less than 24 hours in duration. Variance relief is available for longer time

periods.

DRAFT


Page 4 of 15

3. Monitoring. The equipment permitted herein is subject to the following monitoring requirements.

Compliance with these requirements ensures compliance with NSPS monitoring requirements.

a. Hour Meter. The engine shall be equipped with a totalizing non-resettable hour meter. The

hour meter shall be operational at all times the engine is operated.

b. Fuel Usage Metering. The engine shall be equipped with two dedicated non-resettable

temperature and pressure corrected fuel meters (totalizer) to measure the total standard cubic

feet (scf) of both the digester and natural gas fuel delivered to the engine. The fuel meters

shall be accurate to within one percent (1%) of the full scale reading. The fuel meters/gauges

shall be calibrated in accordance with the fuel meters manufacturer’s procedures. The

calibrations shall be performed as specified by the fuel meters manufacturer, but no later than

the date of the next required emissions source test.

c. Engine Inspection and Maintenance Plan. An Engine Inspection and Maintenance Plan shall

be submitted to the District for its review and approval prior to initiating SCDP. The plan

shall list the engine with all applicable control parameters and associated compliance values

identified in this permit as well as engine calibration and maintenance logs. The plan shall

identify the type of fuel meters and hour meters that will be installed for use in monitoring

compliance with permit limits. The plan shall specify inspection frequencies for all emission

control parameters. This Plan shall be fully implemented at all times.

d. Digester Gas Sulfur Data. The permittee shall measure the total sulfur content of the digester

gas on a quarterly basis in accordance with current ASTM-D1072 method or a District

approved equivalent method.

e. Startup/Shutdown Mode. The permittee shall monitor the time the engine operates in the

Startup/Shutdown mode.

f. Continuous Emissions Monitoring System. As specified in the CEMS condition of this

permit, the permittee shall monitor the engine exhaust stack concentration for NOx (as NO2),

CO, and O2 on a dry basis using a CEMS.

4. Recordkeeping. The permittee shall record and maintain the following information. This data

shall be maintained for a minimum of five (5) years from the date of each entry and made available

to the District upon request. Compliance with these requirements ensures compliance with NSPS

recordkeeping requirements.

a. Fuel Gas Use. The total amount of natural gas and digester gas combusted in the engine shall

be recorded on a daily, monthly, and annual basis in units of standard cubic feet and million

Btus (x.xxx format).

b. Operating Hours. An operating hours log shall be maintained that details the number of

operating hours on each day the engine is operated and the cumulative total monthly and

DRAFT


Page 5 of 15

annual hours.

c. Startup/Shutdown Mode Hours. An operating hours log shall specify the time, duration,

reason and type (Planned or Unplanned) of when the engine is in Startup/Shutdown Mode.

The log shall also document the cumulative quarterly and annual hours.

d. Fuel Gas. On a weekly basis, the higher heating value of the natural gas and digester gas

(Btu/Scf) shall be measured and recorded using the District-approved ASTM sampling and

analysis techniques.

e. Engine Calibration and Maintenance Logs. Engine calibration and maintenance logs shall be

maintained, as detailed in the District-approved Engine Inspection & Maintenance Plan.

f. Digester Gas Fuel Sulfur Limit. Sampling results of the quarterly digester gas total sulfur

content shall be maintained.

g. Fuel Meters. The permittee shall keep calibration records for the fuel meters as well as a log

of any errors or problems associated with the fuel meters.

h. Digester Gas Release. A log of all breakdowns or malfunctions which result in emissions of

raw digester gas into the atmosphere shall be maintained. The log shall include the date and

time of the occurrence, a description of the breakdown or malfunction, District contact

method and time, and the remedial measure undertaken to correct the problem and prevent

further emissions into the atmosphere.

i. Digester Gas Limits. Records showing compliance with the digester gas limits specified in

condition 2.g. shall be maintained.

5. Reporting. Twice a year, a written report documenting compliance with the terms and conditions

of this permit for the previous two calendar quarters shall be provided by the permittee to the

District (Attn: Annual Report Coordinator). The first report shall cover January through June and

shall be submitted no later than September 1. The second report shall cover July through December

and shall be submitted no later than March 1. The report shall contain information necessary to

verify compliance with the emission limits and other requirements of this permit. This information

includes, but not limited to, the fuel flow rate and heating values used for both engine fuels in

calculations, operating limits provided in the permit and any deviations from the limit, and any

problems or errors suspected with the meters. The report shall be in a format approved by the

District. Compliance with all limitations and restrictions shall be documented in the submittals.

All logs and other basic source data not included in the report shall be made available to the District

upon request. The report shall include the information required by the Recordkeeping Condition of

this permit and the report required by the District-approved CEMS Plan. Compliance with these

requirements ensures compliance with NSPS reporting requirements.

DRAFT


Page 6 of 15

6. Source Compliance Demonstration Period. Upon completion of items (a) through (d) below and

with District written approval, the permittee may temporarily operate the equipment permitted

herein under a Source Compliance Demonstration Period (“SCDP”) not to exceed 120-days. Initial

SCDP operations of the permitted equipment are defined as the first introduction of fuel gas to the

engine. Within 14 of days of initial operations, the permittee shall provide the District written

notification of the SCDP start date (using the attached yellow SCDP notification card).

Prior to beginning the SCDP, the permittee shall connect the CEMS to the District DAS.

Items (a) through (d) must be completed before the SCDP begins. Items (e) through (i) must be

completed during the term of SCDP. During the SCDP, the permittee shall comply with all

operational, monitoring, recordkeeping and reporting requirements as specified in this permit.

a. CEMS. Submit documentation which identifies the manufacturer and model of the

Continuous Emissions Monitoring System. The documentation should also demonstrate that

the CEMS meets all of the requirements specified in Condition 8 of this permit. Include a

copy of the manufacturer documentation for operation and maintenance of the CEMS.

b. CEMS Plan. Submit a CEMS Plan in accordance with the CEMS condition herein, and

obtain District approval of the Plan;

c. Inspection & Maintenance Plan. Submit an Engine Inspection and Maintenance ("I&M")

Plan in accordance with the Monitoring Condition herein (Engine Inspection and

Maintenance Plan) and obtain District approval of the plan;

d. Source Test Plan. For compliance testing, submit and obtain District approval of a Source

Test Plan for the engine, and arrange a test date in accordance with the Source Testing

Condition herein;

e. Begin recordkeeping as specified in the Recordkeeping Condition herein;

f. Arrange for District inspection not more than thirty (30) calendar days (or other mutually

agreed to time period) after the SCDP begins. A minimum of five (5) calendar days advance

notice shall be given to the District. This inspection is required to verify that the equipment

and its operation are in compliance with Federal, State and District Rules and this permits’

Conditions;

g. Submit the source test results within forty-five (45) calendar days following the date of

source test completion and obtain approval of the results;

h. Submit a Permit to Operate (PTO) application and the appropriate filing fee not more than

90 calendar days after the SCDP begins pursuant to District Rule 201.E.2. Upon the

District’s determination that the permit application is “complete”, the permittee may continue

DRAFT


Page 7 of 15

temporary operations under the SCDP until such time the PTO is issued final or one year

from the date of PTO application completeness, whichever occurs earlier.

i. SCDP extensions of up to 30 days may be granted by the District for good cause. Such

extensions may be subject to conditions. When good cause cannot be demonstrated, no

administrative extension is available and the permittee shall cease operations or the permittee

may submit an application to revise the ATC permit. A written request to extend the SCDP

shall be made by the permittee at least 15 days prior to the SCDP expiration date.

7. BACT. The permittee shall apply emission control technology and plant design measures that

represent Best Available Control Technology (“BACT”) to the operation of the equipment/facilities

as described in this permit and the District’s Permit Evaluation for this permit. Table 4 (BACT

Requirements) and the Emissions Limitations Condition (BACT Emissions Limits) herein define the

specific control technology and performance standard emission limits for BACT. The BACT shall

be in place, and shall be operational at all times, for the life of the project. BACT related

requirements are also defined in the CEM and Source Testing permit conditions herein.

8. Continuous Emission Monitoring System (“CEMS”). The permittee shall implement a CEMS

program for emissions and process parameters as specified in Table 5. The permittee shall

implement the District-approved CEMS Plan and the CEMS monitors shall be in place and

functional for the life of the project. The District shall use the CEMS data alone or in combination

with other data, to verify and enforce project conditions. Excess emissions indicated by the CEMS

systems shall be considered a violation of the applicable emission limits.

a. The continuous emission monitoring system (CEMS) shall be installed and operated to

measure the engine exhaust stack concentration for NOx (as NO2), CO, and O2 on a dry basis.

In addition, the system shall convert the actual NOx and CO concentrations to corrected NOx

and CO concentrations at 15% O2 and continuously record the stack NOx and CO

concentrations, stack O2 concentration, and corrected NOx and CO concentrations at 15% O2.

This monitoring system shall comply with the requirements of Rule 328 and the District

CEMS Protocol (October 22, 1992). Prior to installation, this monitoring system shall be

approved in writing by the District via the submittal of a CEMS Plan that adheres to the

requirements of the District’s CEM Protocol (October 22, 1992).

b. Data Telemetry. The permittee shall telemeter monitoring data to the District as specified in

Table 5. The data telemetry equipment shall be in place and functional for the life of the

project consistent with the above-specified conditions. This telemetry equipment shall be

compatible with the District’s Central Data Acquisition System (DAS).

c. On a semi-annual basis, the permittee shall submit data for CEM downtime and CEM

detected excess emissions in a format approved by the District. This report shall be

submitted for each calendar quarter in accordance with the requirements of Rule 328 and the

District-approved CEMS Plan.

DRAFT


Page 8 of 15

9. Corrective Action Plan. California Power Partners Inc. shall submit a Corrective Action Plan

(CAP) for APCD review and approval if either of the following conditions occur:

a. Three or more CEMS NOx or CO emissions excursions attributed to digester gas quality

irregularities occur in any calendar quarter.

b. Four or more CEMS NOx or CO emissions excursions attributed to digester gas quality

irregularities occur in a calendar year.

The CAP shall be submitted within 30 days after reaching either action level above, and shall be

fully implemented by California Power Partners Inc. within 180 days of submittal. The CAP

submittal shall present options for eliminating or minimizing the number of digester gas quality

induced excursions, and identifies a preferred approach. The options considered shall include a

fuel gas quality (BTU) or oxygen analyzer upstream at the waste water treatment plant, and a

feed/control system to blend or substitute PUC natural gas during periods of digester gas

irregularities.

10. Central Data Acquisition System Operation and Maintenance Fee. The permittee shall connect

the Continuous Emission Monitors (CEM) to the District Central Data Acquisition System (DAS)

prior to the start of the SCDP. In addition, the permittee shall reimburse the District for the cost of

operating and maintaining the DAS. The permittee shall be assessed an annual fee, based on the

District’s fiscal year, collected semi-annually.

a. Pursuant to Rule 210 III.A., the permittee shall pay fees specified in Table A. The District

shall use these fees to operate, maintain, and upgrade the DAS in proper running order. Fees

shall be due and payable pursuant to governing provisions of Rule 210, including CPI

adjustments.

TABLE A FEES FOR DAS OPERATION AND MAINTENANCE

3

FEE DESCRIPTION FEE

Per CEM, ambient or meteorological parameter required by

permit to be transmitted real-time to the District Central Data

Acquisition System

$1,877 annually

b. All ongoing costs and anticipated future capital upgrades will be District’s responsibility and

will be accomplished within the above stated DAS fee. This fee is intended to cover the

annual operating budget and upgrades of the DAS and may be revised during the triennial

permit reevaluation.

3 All fees shall be due and payable pursuant to the governing provisions of Rule 210, including CPI

adjustments.

DRAFT


Page 9 of 15

c. The fees prescribed in this condition shall expire if and when the District Board of Directors

adopts a Data Acquisition System Operation and Maintenance Fee schedule and such fee

becomes effective.

11. Source Testing. The following source testing provisions shall apply:

a. The permittee shall conduct source testing of air emissions and process parameters listed in

Table 3 of this permit. More frequent source testing may be required if the equipment does

not comply with permitted limitations or if other compliance problems, as determined by the

District, occur. Source testing shall be performed on an annual schedule using the initial

source test date (+ 30 days) as the anniversary date.

b. The permittee shall submit a written source test plan to the District for approval at least thirty

(30) days prior to initiation of each source test. The source test plan shall be prepared

consistent with the District's Source Test Procedures Manual (revised May 1990 and any

subsequent revisions). The permittee shall obtain written District approval of the source test

plan prior to commencement of source testing. The District shall be notified at least ten (10)

calendar days prior to the start of source testing activity to arrange for a mutually agreeable

source test date when District personnel may observe the test.

c. Source test results shall be submitted to the District within forty-five (45) calendar days

following the date of source test completion and shall be consistent with the requirements

approved within the source test plan. Source test results shall document the permittee’s

compliance status with BACT requirements, mass emission rates and applicable permit

conditions, rules and NSPS (if applicable). All District costs associated with the review and

approval of all plans and reports and the witnessing of tests shall be paid by the permittee as

provided for by District Rule 210.

d. A source test for an item of equipment shall be performed on the scheduled day of testing (the

test day mutually agreed to) unless circumstances beyond the control of the operator prevent

completion of the test on the scheduled day. Such circumstances include mechanical

malfunction of the equipment to be tested, malfunction of the source test equipment, delays in

source test contractor arrival and/or set-up, or unsafe conditions on site. Except in cases of an

emergency, the operator shall seek and obtain District approval before deferring or

discontinuing a scheduled test, or performing maintenance on the equipment item on the

scheduled test day. If the test cannot be completed on the scheduled day, then the test shall

be rescheduled for another time with prior authorization by the District. Once the sample

probe has been inserted into the exhaust stream of the equipment unit to be tested (or

extraction of the sample has begun), the test shall proceed in accordance with the approved

source test plan. In no case shall a test run be aborted except in the case of an emergency or

unless approval is first obtained from the District. Failing to perform the source test of an

equipment item on the scheduled test day without a valid reason and without District's

authorization shall constitute a violation of this permit. If a test is postponed due to an

DRAFT


Page 10 of 15

emergency, written documentation of the emergency event shall be submitted to the District

by the close of the business day following the scheduled test day.

The timelines in (a), (b), and (c) above may be extended for good cause provided a written

request is submitted to the District at least three (3) days in advance of the deadline, and approval

for the extension is granted by the District.

Compliance with these requirements ensures compliance with NSPS source testing requirements.

12. Documents Incorporated by Reference. The documents listed below, including any District-

approved updates thereof, are incorporated herein by reference and shall have the full force and

effect of a permit condition for this permit. These documents shall be implemented for the life of

the Project and shall be made available to District inspection staff upon request.

a. Engine Inspection and Maintenance Plan (to be submitted).

b. CEMS Plan (to be submitted).

13. Consistency with Analysis. Operation under this permit shall be conducted consistent with all

data, specifications and assumptions included with the application and supplements thereof (as

documented in the District's project file) and the District's analyses under which this permit is

issued as documented in the Permit Analyses prepared for and issued with the permit.

14. Equipment Maintenance. The equipment listed in this permit shall be properly maintained and

kept in good condition at all times. The equipment manufacturer’s maintenance manual,

maintenance procedures and/or maintenance checklists (if any) shall be kept on site.

15. Compliance. Nothing contained within this permit shall be construed as allowing the violation of

any local, state or federal rules, regulations, air quality standards or increments.

16. Conflict Between Permits. The requirements or limits that are more protective of air quality shall

apply if any conflict arises between the requirements and limits of this permit and any other

permitting actions associated with the equipment permitted herein.

17. Access to Records and Facilities. As to any condition that requires for its effective enforcement

the inspection of records or facilities by the District or its agents, the permittee shall make such

records available or provide access to such facilities upon notice from the District. Access shall

mean access consistent with California Health and Safety Code Section 41510 and Clean Air Act

Section 114A.

18. Equipment Identification. Identifying tag(s) or name plate(s) shall be displayed on the equipment

to show manufacturer, model number, and serial number. The tag(s) or plate(s) shall be affixed to

the equipment in a permanent and conspicuous position.

DRAFT


Page 11 of 15

19. Reimbursement of Costs. All reasonable expenses, as defined in District Rule 210, incurred by

the District, District contractors, and legal counsel for the activities listed below that follow the

issuance of this permit, including but not limited to permit condition implementation, compliance

verification and emergency response, directly and necessarily related to enforcement of the permit

shall be reimbursed by the permittee as required by Rule 210. Reimbursable activities include work

involving: permitting, compliance, CEMS, modeling/AQIA, ambient air monitoring and air toxics.

20. Nuisance. Except as otherwise provided in Section 41705 of the California H&SC, no person shall

discharge from any source whatsoever such quantities of air contaminants or other material which

cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the

public, or which endanger the comfort, repose, health, or safety of any such persons or the public,

or which cause, or have a natural tendency to cause, injury or damage to business or property.

21. Grounds for Revocation. Failure to abide by and faithfully comply with this permit or any Rule,

Order, or Regulation may constitute grounds for revocation pursuant to California Health & Safety

Code Section 42307 et seq.

22. Indemnity and Separation Clauses. The Permittee shall defend, indemnify and hold harmless the

District or its agents, officers and employees from any claim, action or proceeding against the

District or its agents, officers or employees, to attack, set aside, void, or annul, in whole or in part,

the approval granted herein. In the event that the District fails promptly to notify the Permittee of

any such claim, action or proceeding, or that the District fails to cooperate fully in the defense of

said claim, this condition shall thereafter be of no force or effect. In the event that any condition

contained herein is determined to be invalid, then all remaining conditions shall remain in force.

AIR POLLUTION CONTROL OFFICER

DATE

DRAFT


Page 12 of 15

Attachments:

- Table 1 – Mass Emission Limits

- Table 2 – Emission Factors

- Table 3 – Source Test Requirements

- Table 4 – Best Available Control Technology Requirements

- Table 5 – CEMS Requirements

- Permit Equipment List

- Permit Evaluation for Authority to Construct 13862

Notes: - This permit is valid for one year from the date stamped above if unused.

\\sbcapcd.org\shares\Groups\ENGR\WP\Landfills & WWT\02059 City of SB - El Estero\FID 11391 CalPower\ATC 13862\ATC 13862 - Draft

Permit - 10-29-2012.doc

DRAFT


Page 13 of 15

TABLE 1. MASS EMISSION LIMITS

Device

ID #

NOx ROC CO SOx PM PM10 lb/day tpy lb/day tpy lb/day tpy lb/day tpy lb/day tpy lb/day tpy

115220 33.56 6.12 13.42 2.45 100.67 18.37 2.37 0.43 1.83 0.33 1.83 0.33

TABLE 2. EMISSION FACTORS (LB/MMBTU)

Device

ID # NOx ROC CO SOx PM PM10

115220 0.183 0.073 0.549 0.023 0.010 0.010

Table Notes: (a) Mass emission limits based on continuous operation 24 hours/day and 8,760 hours/year.

(b) NOx as NO2. SOx as SO2.

(c) Device ID # from permit equipment list.

(d) lb/day = pounds per day. tpy = tons per year

(e) Emission data that round down to 0.00 has been set to a default of 0.01.

(f) Emission factors are based off of calculations which can be seen in the Emission Calculations Attachment.

DRAFT


Page 14 of 15

TABLE 3. SOURCE TEST REQUIREMENTS

Emission &

Limit Test

Points

Pollutants Parameters (b) Test Methods (a),(c),(g) Limit

Concentration

(ppmvd @ 15%

O2)

Mass

Emissions

IC Engine

Exhaust (b)

NOx ppmv, lb/hr,

lb/MMBtu

EPA Method 7E, or

ASTM D6522-00 73

1.398 lb/hr,

0.183

lb/MMBtu

ROC ppmv, lb/hr,

lb/MMBtu

EPA Method 18,

or ASTM D6522-00 83.5

0.559 lb/hr,

0.073

lb/MMBtu

CO ppmv, lb/hr,

lb/MMBtu

EPA Method 10, or

ASTM D6522-00 359

4.194 lb/hr,

0.549

lb/MMBtu

CH4

ppmv (as

hexane),

lb/MMBtu

EPA Method 18 20 @ 3% O2

Sampling Point Det. EPA Method 1

Stack Gas Flow Rate EPA Method 2 or 19

O2 Dry, Mol. Wt EPA Method 3

Generator Output kW Plant Meter

Moisture Content EPA Method 4

Fuel Gas Flow Rate Fuel Gas Meter (f)

Fuel Gas

Higher Heating Value Btu/scf ASTM D 1826-88

Total Sulfur Content (d) ASTM D 1072

IC Engine Setup Ignition Timing Setting used during test

to be documented

Table Notes: (a) Alternative methods may be acceptable on a case-by-case basis.

(b) The emission rates shall be based on EPA Methods 2 and 4, or Method 19 along with the heat input rate. Measured NOx, ROC, and CO

ppmvd shall not exceed the limits specified in the BACT Emissions Limits condition. (c) For NOx, ROC, CO and CH4 and O2 a minimum of three 40-minute runs shall be obtained during each test.

(d) Total sulfur content fuel samples shall be obtained using EPA Method 18 with Tedlar Bags (or equivalent) equipped with Teflon tubing and

fittings. Turnaround time for laboratory analysis of these samples shall be no more than 24 hours from sampling in the field. Reported as H2S.

(e) Source testing shall be performed for the IC engine in an "as found" condition operating at a representative, District-approved, IC engine

load (scf/hr and kW). (f) Fuel meters shall meet the calibration and metered volume corrections specified in Rule 333, §G.3.a.

(g) ARB test methods may not be used to demonstrate compliance with NSPS standards.

DRAFT


Page 15 of 15

TABLE 4. BACT REQUIREMENTS

Emission Unit/Process Control Technology Pollutant Performance Standard Performance Standard

Digester/Natural Gas

Cogeneration Unit

Guascor IC-G-B-56-034

Modified fuel injection

for the IC engine

NOx 0.60 g/bhp-hr 73 ppmvd @ 15% O2

ROC 0.24 g/bhp-hr 83.5 ppmvd @ 15%

O2 CO 1.80 g/bhp-hr 359 ppmvd @ 15% O2

TABLE 5. CEMS REQUIREMENTS

Location

Number

Test Location

Parameter

Monitored

Monitoring Method

1 Exhaust Stack

NOx NOx Analyzer 2, 3, 4, 5

O2 O2 Analyzer 2, 3, 5

CO CO Analyzer 2, 3, 4, 5

Temperature Thermocouple 2, 3

Flow Rate Annubar 2, 3, 5

(or equivalent)

2 Engine Fuel Feed Flow Rate Process Flow Meter 2, 3, 5

3 Electrical Generation Plant Mode Process Monitors 2, 3

Notes:

1 Parameters in addition to those listed must be monitored continuously if deemed necessary by the District.

2 Parameter raw data must be permanently recorded using a computer or data/logger.

3 Parameters must be monitored continuously and reported to the District on a semi-annual basis (submit two

calendar quarter reports). Electronic data files must be provided in a format approved by the District

4 Corrected NOx and CO concentrations must be telemetered to the District. NOx as NO2. ppmvd at 15%

oxygen.

5 Each emissions monitoring instrument must be performance certified annually (or more often if this is

deemed necessary by the District) in accordance with 40 CFR 60 Appendix B and 40 CFR 50 Appendix E,

or equivalent method approved by the District. Flow meter shall be calibrated per the CEMs Plan.

6 Monitoring and reporting frequency per District CEMS Protocol and the permittee’s District-approved

CEMS Plan.

DRAFT

Equipment List for Authority to Construct 13862

Page 1 of 2

PERMIT EQUIPMENT LIST - TABLE A ATC 13862 / FID: 11391 CalPower - El Estero / SSID: 02059

A PERMITTED EQUIPMENT

1 Generator Engine

Device ID # 115220 Device Name Generator Engine Rated Heat Input 7.639 MMBtu/Hour Physical Size 896.00 Horsepower Manufacturer Guascor Operator ID Model IC-G-B-56-034 Serial Number Location Note Device Description

Modified for lower NOx levels, annually limited to operate 522 hrs on 25 percent natural gas, fired on digester and natural gas, has air-fuel controller, Martin Machinery MGG-927 650 kW generator, 1057 bhp

2 Continuous Emissions Monitoring System

Device ID # 115222 Device Name Continuous Emissions

Monitoring System Rated Heat Input Physical Size Manufacturer TBD Operator ID Model TBD Serial Number Location Note El Estero Waste Water Treatment Plant Device Description

TBD

DRAFT

Equipment List for Authority to Construct 13862

Page 2 of 2

B EXEMPT EQUIPMENT

1 Fuel Meter 1

Device ID # 115221 Device Name Fuel Meter 1 Rated Heat Input Physical Size Manufacturer Fluid Components

International LLC Operator ID

Model G90 Serial Number Location Note Device Description

Fuel meter for the digester gas, mass flowmeter

2 Fuel Meter 2

Device ID # 115223 Device Name Fuel Meter 2 Rated Heat Input Physical Size Manufacturer Fox Thermal

Instruments, Inc. Operator ID

Model FT2 Serial Number Location Note Device Description

Fuel meter for the natural gas, thermal mass flowmeter and temperature transmitter

DRAFT

PERMIT EVALUATION FOR

AUTHORITY TO CONSTRUCT 13862

Page 1 of 7

1.0 BACKGROUND

1.1 General: This Authority to Construct authorizes California Power Partners to install and

temporarily operate an internal combustion engine to drive an electrical generator at the El Estero

Waste Water Treatment Plant. The unit will be fueled by natural and digester gas. The natural gas

will be used a maximum of 522 hours annually. Additionally, when the natural gas is used, it will

account for a maximum of 25 percent of the fuel burned in the engine at that time. The digester gas

will be produced from the facility. The engine has been modified in order to reduce the NOx

emissions.

1.2 Permit History: No previous permits.

1.3 Compliance History: The permitted equipment has no compliance history.

2.0 ENGINEERING ANALYSIS

2.1 Equipment/Processes: The Guascor IC-G-B-56-034 IC engine will be connected to the Martin

Machinery MGG-927 electrical generator. This configuration will be used to produce up to 650 kW

of power. During normal operations, the engine will be powered using digester gas from the waste

water treatment plant. When electrical demand increases, the engine may be fired on a maximum of

25 percent natural gas for up to 522 hours annually.

2.2 Emission Controls: The Guascor IC engine has been modified to reduce the NOx emissions to less

than 0.5 g/bhp-hr for generator operation between 500 and 650 kW. The changes to the engine

include modified fuel injection and selected turbos with adequate air volumes to allow for the

reduced NOx emissions.

2.3 Emission Factors: Emission factors for the engine are documented in Table 1 of the Emission

Calculations attachment. Emission factors for NOx, ROC, and CO emissions are based on BACT

values. The emission factor for SOx emissions is based on mass balance using digester gas and a

maximum sulfur content of 10 ppmvd (as H2S). The emission factor for PM is based on the

application.

2.4 Reasonable Worst Case Emission Scenario: The Emission Calculations attachment defines the

operational characteristics that comprise the reasonable worst case-operating scenario for this

permit. The operating scenario is summarized as follows:

DRAFT



Page 2 of 7

(1) Full engine load with ppmv and g/bhp-hr factors from manufacturer’s guarantee

(2) Daily operations of up to 24 hours per day.

(3) Annual operations of up to 8,760 hours per year.

2.5 Emission Calculations: Detailed emission calculation spreadsheets may be found in the Emission

Calculation attachment. These emissions define the Potential to Emit for the permitted equipment.

Emission calculations and emissions factors for the internal combustion engine are provided below:

ER = [ ( EF x HIFPP) 106 ]

Where:

ER = Emission rate (lb/period)

EF = Pollutant specific emission factor (lb/MMBtu)

HIFPP = fuel heat input per operating period (scf/period)

2.6 Special Calculations: The following special calculations were used:

(1) The emission factor for SOx based on the fuel sulfur mass balance for gaseous fuels is

determined as follows:

EFSO2 = ppmv S/106 1/mv MR MWSO2 CF1 1/HHV BSFC

Where:

EFSO2 = oxides of sulfur emission factor (g/bhp-hr)

ppmv S = parts per million sulfur by volume (ft3 S/10

6 ft

3 fuel)

mv = molar volume (379 std ft3 S/lb-mol S -- assumes std temp of 60F)

MR = molar ratio (S + O2 => SO2 -- i.e., MR = 1)

MWSO2 = molecular weight of sulfur dioxide (64 lb/lb-mol)

CF1 = grams to pounds conversion factor (453.6 g/lb)

HHV = fuel higher heating value (Btu/std ft3)

BSFC = engine brake-specific fuel consumption - HHV based (Btu/bhp-hr)

Dimensional Analysis:

[g/bhp-hr] = [ft3 S/10

6 ft

3 fuel] [lb-mol S/std ft

3 S] [lb-mol SO2/lb-mol S] *

[lb SO2/lb-mol SO2] [g SO2/lb SO2] [std ft3 fuel/Btu] [Btu/bhp-hr]

(2) To convert the BACT limits in [g/bhp-hr] to [lb/MMBtu] the following equation was used:

EFlb/MMBtu = EFg/bhp-hr 1/CF1 1/BSFC 106 Btu/MMBtu

Where:

EFlb/MMBtu = emission factor in units of “lb/MMBtu”

DRAFT



Page 3 of 7

EFg/bhp-hr = emission factor in units of “g/bhp-hr”

CF1 = grams to pounds conversion factor (453.6 g/lb)

BSFC = engine brake-specific fuel consumption - HHV based (Btu/bhp-hr)

2.7 BACT Analyses: Best Available Control Technology was required for this project since the

uncontrolled emissions from the IC Engine exceeded the 25 lb/day criteria pollutant threshold for

BACT. Please see Table 4 of the permit for the BACT Requirements, and the BACT

Documentation Attachment for more information.

2.8 Enforceable Operational Limits: The permit has enforceable operating conditions that ensure the

equipment is operated properly.

2.9 Monitoring Requirements: Monitoring of the equipment’s operational limits are required to ensure

that these are enforceable. Hour and fuel meters will be in place to monitor compliance with the

operational limits. A source test will be conducted during the SCDP and annually thereafter to

confirm continued compliance with the operational limits. In addition, a CEMS system with data

telemetry to the District is required for the life of the project.

2.10 Recordkeeping and Reporting Requirements: The permit requires recording and reporting of the

operation, maintenance, and emissions associated with the equipment.

3.0 REEVALUATION REVIEW (not applicable)

4.0 REGULATORY REVIEW

4.1 Partial List of Applicable Rules:

Rule 201. Permits Required

Rule 202. Exemptions to Rule 201

Rule 205. Standards for Granting Permits

Rule 301. Circumvention

Rule 302. Visible Emissions

Rule 303. Nuisance

Rule 311. Sulfur Content of Fuels

Rule 328. Continuous Emission Monitoring

Rule 333. Control of Emissions from Reciprocating Internal Combustion Engines

Rule 801. New Source Review

Rule 802. Nonattainment Review

Rule 803. Prevention of Significant Deterioration

Rule 804. Emission Offsets

40 CFR 60

Subpart JJJJ NSPS for Stationary Spark Ignition Internal Combustion Engines

40 CFR 63

Subpart ZZZZ NESHAP for Stationary Reciprocating Internal Combustion Engines

DRAFT



Page 4 of 7

4.2 Rules Requiring Review:

4.2.1 Rule 311 - Sulfur Content of Fuels: Section B of this rule limits the sulfur content of

gaseous fuel burned in the southern zone to no more than 15 grains per 100 cubic feet

(calculated as H2S at standard conditions) or any liquid or solid fuel having sulfur content

in excess of 0.5 percent by weight.

4.2.2 Rule 328 - Continuous Emissions Monitoring: This rule details the applicability and

standards for the use of continuous emission monitoring systems ("CEMS"). Process

monitoring systems (e.g., fuel use meters) are used to track emissions. CEMS are required

for the Guascor IC-G-B-56-034 engine as outlined in Section 2.8, Table 5, and the CEMS

condition. The permittee will operate the CEMS consistent with a District approved CEMS

Plan.

4.2.3 Rule 333 - Control of Emissions from Reciprocating IC Engines: The Guascor IC engine is

subject to all the requirements of this Rule with the exemption of 333.D. An exemption is

granted for this section because the engine is rated below 1000 bhp. Rule 333.E requires all

engines subject to this rule to be operated per a District-approved inspection and

maintenance plan which includes quarterly NOX emissions monitoring. In addition,

Rule 333.G requires biennial source testing, and Rule 333.H specifies recordkeeping of

engine operations and maintenance including control equipment maintenance.

4.2.4 Rule 802 - Nonattainment Review: The District is currently designated nonattainment for

the state ozone standard and the state PM10 standard. The provisions of this rule apply to

ozone precursor pollutants (NOx and ROC), PM10 and PM10 precursor pollutants (NOx,

ROC and SOx).

BACT - The BACT threshold is exceeded.

The Air Quality Impact Analysis (AQIA) requirements under this rule (§D) were not

triggered.

Emission offsets (§E) are not triggered.

4.2.5 40 CFR Subpart ZZZZ – NESHAP for Stationary Reciprocating Internal Combustion

Engines: New digester gas-fired RICE with a site rating of more than 500 bhp located at a

major source of HAP emissions must meet initial notification, monitoring, recordkeeping,

and reporting requirements. This project is not subject to emission limitations.

Per §63.9(b), the application for an Authority to Construct satisfies the initial notification

requirements of this Subpart.

DRAFT



Page 5 of 7

§63.6625 requires the operator to monitor fuel use daily with a fuel meter and to operate the

engine in a manner which reasonably minimizes HAP emissions. The engine is equipped

with two fuel use meters. By meeting BACT requirements and monitoring emissions with

a CEMs unit, the engine will be operated in a manner which reasonably minimizes HAP

emissions.

§63.6650 requires the operator to submit an annual report with (1) the fuel flow rate and

heating values used in each calculation, (2) the operating limits provided in the permit and

any deviations from the limits, and (3) any problems or errors suspected with the meters.

§63.6655 requires the operator to keep records of daily fuel use.

4.2.6 40 CFG Subpart JJJJ – NSPS for Stationary Spark Ignition Internal Combustion Engines:

Per 60.4233(e) new digester gas-fired SI ICE rated over 500 hp must meet the emission

standards specified in Table 1 of Subpart JJJJ.

NSPS Landfill/Digester Gas Emission Standards – Table 1 to Subpart JJJJ

NOx CO VOC

NSPS Standard 2.0 5.0 1.0

Permit Limit 0.60 1.80 0.24

§60.4243 requires source testing and that the engine be operated and maintained according

to manufacturer specifications and maintenance records must be kept. Condition 4.e of this

permit requires that such records must be kept.

§60.4244 requires that performance tests be conducted within 10 percent of peak load and

according to the requirements of Table 2 of the Subpart. Source test requirements are listed

in Table 3 of this permit. ARB test methods may not be used to demonstrate compliance

with NSPS standards. The procedure in §60.4244 shall be used to convert measured ppmv

exhaust concentrations to g/hp-hr emission rates.

The permit application for this engine satisfies the notification requirements of §60.4245.

4.3 NEI Calculations: The net emission increase calculation is used to determine whether certain

requirements must be applied to a project (e.g., offsets, AQIA, PSD, BACT). For the purposes of

Regulation VIII, this is a new facility at an existing stationary source and therefore the NEI is equal

to the potential to emit (PTE) of this facility’s project plus the NEI from the existing source. Since

the existing NEI from the El Estero Waste Water Treatment Plant stationary source is from a

project required by federal requirements, the existing NEI is excluded from offset trigger

calculations, per CHSC 42301.2. Therefore, only the NEI from this project is considered for the

purpose of offsets. The NEI values for the stationary source are documented in the NEI Tables

(Facility and Stationary Source) Attachment.

DRAFT



Page 6 of 7

5.0 AQIA

The project is not subject to the Air Quality Impact Analysis requirements of Regulation VIII.

6.0 OFFSETS/ERCs

6.1 Offsets: The emission offset thresholds of Regulation VIII are not exceeded.

6.2 ERCs: This source does not generate emission reduction credits.

7.0 AIR TOXICS

In March, 2012, the District conducted an air toxics Health Risk Assessment (HRA) screening for

the proposed installation of a digester gas-fired cogeneration engine at the El Estero Waste Water

Treatment Plant in Santa Barbara, using SCREEN3 software, Version 5.00. Cancer risk and

chronic and acute non-cancer Hazard Index (HI) risk values were calculated and compared to

significance thresholds for cancer and chronic and acute non-cancer risk adopted by the District’s

Board of Directors. The calculated risk values and applicable thresholds are as follows:

Max Risks Significance Threshold

Cancer risk: 9.27 /million >10/million

Chronic non-cancer risk: 0.0389 > 1

Acute non-cancer risk: 0.0556 > 1

Based on these results, the installation of the digester gas-fired cogeneration engine does not

present a significant risk to the offsite and surrounding communities. Please see the Health Risk

Assessment Report attachment of this permit for more information.

This HRA screening included only the proposed cogeneration engine, and did not evaluate the total

facility health risk including existing equipment. The total facility air toxics emissions and health

risk will be reviewed at a later date as part of the AB 2588 Air Toxics “Hot Spots” Program. After

the new engine is installed and operational, an updated Air Toxics Emission Inventory Plan

(ATEIP) and Air Toxics Emission Inventory Report (ATEIR) will be required. These documents

will reflect the entire El Estero Waste Water Treatment Plant Stationary Source, including the new

cogeneration engine. After the ATEIP and ATEIR are approved, a health risk assessment for the

entire facility will be performed in accordance with Air Toxic "Hot Spots" risk procedures.

8.0 CEQA / LEAD AGENCY

The City of Santa Barbara is the CEQA lead agency for this project. The City of Santa Barbara

Planning Division issued a Notice of Exemption for the Cogeneration Facility at El Estero

Wastewater Treatment Plant (City of SB Project Number MST20011-00437) on April 2, 2012. No

further action is necessary.

DRAFT



Page 7 of 7

9.0 SCHOOL NOTIFICATION

A school notice pursuant to the requirements of H&SC §42301.6 was required as the project site is

located within 1,000 feet of a school. A notice to the parents of the students, and residences and

businesses within 1,000 feet of the project will be mailed before the issuance of the final permit.

10.0 PUBLIC and AGENCY NOTFICATION PROCESS/COMMENTS ON DRAFT PERMIT

10.1 This project was subject to public notice.

11.0 FEE DETERMINATION

Fees for this permit are assessed under the cost reimbursement provisions of Rule 210. The project

code is 205632 (Cal Power- El Estero).

12.0 RECOMMENDATION

It is recommended that this permit be granted with the conditions as specified in the permit.

Kevin Brown October 30, 2012

AQ Engineer/Technician Date Supervisor Date

13.0 ATTACHMENT(S)

Emission Calculations

NEI Tables (Facility and Stationary Source)

BACT Documentation

Health Risk Assessment

DRAFT


EMISSION CALCULATIONS

DRAFT


TABLE 1 - EMISSION FACTOR DERIVATION FROM G/BHP-HR DATA

DATA:

Parameter Symbol Value Units Reference

Rich or Lean Burn? EXO2 l "r" or "l" Permit application

4 Stroke or 2 Stroke? STROKE 4 "4" or "2" Permit application

Engine Rating BHP 1,057 (Bhp) Permit application

BSFC {HHV based} BSFCH 7,227 (Btu/bhp-hr) APCD ICE TRD, Table 6

F-Factor (FD) FD 9,100 (dscf/MMBtu) Attach. 2-3 USEPA Combustion Manual Naturally Aspirated 10,500 (Btu/bhp-hr)

Sulfur Content SULF 125 (ppmv as S) Permit application Turbocharged 10,100 (Btu/bhp-hr)

Heat Content HEAT 592 Btu/scf Permit application Turbocharged/Aftercooled 9,600 (Btu/bhp-hr)

Molar Volume of Gasses mv 590.0 (scf/lb-mole) Attach. 5-5 USEPA Combustion Manual

Stack NOx (as NO2) gbhpN 0.60 g/bhp-hr Permit application, Manufacturer Guarantee

Stack ROC (as CH4) gbhpR 0.24 g/bhp-hr Permit application, Manufacturer Guarantee Default F-Factor

Stack CO gbhpC 1.80 g/bhp-hr Permit application, Manufacturer Guarantee (Natural Gas) 8,740 dscf/MMBtu

Molec Weight NOx MWN 46 lb/lbmole NOx as NO2

Molec Weight ROC MWR 16 lb/lbmole ROC as methane PM10 Emission Factor

Molec Weight CO MWC 28 lb/lbmole 2 Stroke Lean Burn 0.0483 lb/MMBtu

Molec Weight SOx MWS 64 lb/lbmole as SO2 4 Stroke Lean Burn 0.0100 lb/MMBtu

4 Stroke Rich Burn 0.0194 lb/MMBtu

ref: AP-42, Section 3.2

CALCULATIONS:

Note: BSFC is typically reported on a lower heating value

Parameter Symbol Value Units Calculation (LHV) basis. If you have engine-specific fuel consumption

Hourly Heat Input QH 7.639 MMBtu/hr QH = (BHP*BSFCH)/10^6 data from the manufacturer, and it is reported on a LHV

Stack Flow (0% O2) S1 69,514 dscf/hr S1 = FD * QH basis, multiply the reported BSFC by 1.1 to determine the

Stack Flow (15% O2): S2 246,246 dscf/hr S2 = S1 * {(20.9-0)/(20.9-15)} BSFC on a HHV basis.

NOx Mass Emissions EN 1.398 lb/hr EN = {(ppmvN/10^6)*S2*MWN/mv}

ROC Mass Emissions ER 0.559 lb/hr ER = {(ppmvR/10^6)*S2*MWR/mv}

CO Mass Emissions EC 4.194 lb/hr EC = {(ppmvC/10^6)*S2*MWC/mv}

SOx Mass Emissions ES 0.099 lb/hr ES = {(QH/1050)*SULF*MWS/mv}

PM10 Mass Emissions EP 0.076 lb/hr EP = {QH*EFPM}

NOx Emission Factor EFNOX 0.183 lb/MMBtu EFNOX = EN/QH

ROC Emission Factor EFROC 0.073 lb/MMBtu EFROC = ER/QH

CO Emission Factor EFCO 0.549 lb/MMBtu EFCO = EC/QH

SOx Emission Factor EFSOX 0.022912 lb/MMBtu EFSOX = SULF/HEAT/mv*MWS

Stack NOx (as NO2) ppmvN 73 (ppmvd @ 15% O2)

Stack ROC (as CH4) ppmvR 84 (ppmvd @ 15% O2)

Stack CO ppmvC 359 (ppmvd @ 15% O2)

NOx Mass Emissions 33.55556 lb/day

ROC Mass Emissions 13.42222 lb/day

CO Mass Emissions 100.6667 lb/day

SOx Mass Emissions 2.367516 lb/day

PM10 Mass Emissions 1.833345 lb/day

NOx Mass Emissions 6.123889 ton/year

ROC Mass Emissions 2.449556 ton/year

CO Mass Emissions 18.37167 ton/year

SOx Mass Emissions 0.432072 ton/year

PM10 Mass Emissions 0.334586 ton/year

Default Fuel Consumption HHV Basis

DRAFT


NEI TABLES

(FACILITY AND STATIONARY SOURCE)

DRAFT


PERMIT POTENTIAL TO EMIT NOx ROC CO SOx PM PM10

lb/day 33.56 13.42 100.67 2.36 1.83 1.83

lb/hr

TPQ

TPY 6.12 2.45 18.37 0.43 0.33 0.33

FACILITY POTENTIAL TO EMIT NOx ROC CO SOx PM PM10

lb/day 33.56 13.42 100.67 2.36 1.83 1.83

lb/hr

TPQ

TPY 6.12 2.45 18.37 0.43 0.33 0.33

FACILITY NEI90 NOx ROC CO SOx PM PM10

lb/day 33.56 13.42 100.67 2.36 1.83 1.83

lb/hr

TPQ

TPY 6.12 2.45 18.37 0.43 0.33 0.33

STATIONARY SOURCE POTENTIAL TO EMIT NOx ROC CO SOx PM PM10

lb/day 184.59 37.58 291.68 18.05 12.92 12.92

lb/hr

TPQ

TPY 10.60 4.40 31.57 3.30 1.08 1.08

STATIONARY SOURCE NEI90 NOx ROC CO SOx PM PM10

lb/day 184.59 37.58 291.68 18.05 12.92 12.92

lb/hr

TPQ

TPY 10.60 4.40 31.57 3.30 1.08 1.08

Notes:

(1) Emissions in these tables are from IDS.

(2) Because of rounding, values in these tables shown as 0.00 are less than 0.005, but greater than zero.

DRAFT


BACT DOCUMENTATION

DRAFT


1. Pollutant(s): NOx

2. Emission Unit: Guascor IC-G-B-56-034 engine (lean burn), 1,057 BHP, 6,570 Btu/Bhp-hr,

Emission Controls: Modified fuel injection and air-fuel ratio, operation of the generator between

500 and 650 kW for leaner burn of the fuel

3. BACT Determination Summary:

Technology: Modified engine with guarantees from Martin Machinery

Performance Standard: 0.60 g/bhp-hr (43 ppmvd at 15 percent oxygen) for NOx

0.24 g/bhp-hr (83.5 ppmvd at 15 percent oxygen) for ROC

1.80 g/bhp-hr (359 ppmvd at 15 percent oxygen) for CO

4. Level of Stringency: [x] Achieved in Practice

[ ] Technologically Feasible

[ ] RACT, BARCT, NSPS, NESHAPS, MACT

5. BACT Selection Process Discussion: Achieved in Practice determination based on test data

provided by Martin Machinery. Test results were conducted by SCEC on November 9, 2009 for a

similar internal combustion located at San Luis Rey Waste Water Treatment Plant located in

Oceanside, California. This plant is located within the San Diego Air Pollution Control District, a

representative from this District was present during the emissions testing.

6. BACT Effectiveness: BACT is expected to be effective over generator operating loads between

500 and 650 kW. BACT is not expected to be effective during generator operation lower than 500

kW and periods of Startup/Shutdown when the decreased engine operating temperature may

reduce engine efficiency and result in higher emissions.

7. BACT During Non-Standard Operations: Non-standard operations were not identified by the

applicant.

8. Operating Constraints: The engine may only operate while fired on digester and natural gas.

9. Continuously Monitored BACT: CEMS are required for this project to monitor emissions of

NOx, CO, and O2 from the outlet stack of the engine. Data is telemetered to the District via the

Data Acquisition System (DAS).

10. Source Testing Requirement: Annual source testing is required. During each test, the setting of

the A/F ratio controller shall be check and reset if necessary.

11. Compliance Averaging Times: The concentration limits shall be enforced based on the approved

source test procedures (the average of three 40-minute runs) and the 6-minute average data points

measured via the CEM system.

12. Multi-Phase Projects: This is not a multi-year project.

DRAFT


13. Referenced Documents: The SDAPCD BACT Guidelines are found online at:

http://www.aqmd.gov/bact/BACTGuidelines.htm and the ARB Guidance for the Permitting of

Electrical Generation Technologies: http://www.arb.ca.gov/energy/dg/documents/guidelines.pdf

14. PSD BACT: Not Applicable.

http://www.aqmd.gov/bact/BACTGuidelines.htm

http://www.arb.ca.gov/energy/dg/documents/guidelines.pdf

DRAFT


HEALTH RISK ASSESSMENT

DRAFT


Santa Barbara County APCD

Health Risk Assessment Screening Report

Facility: El Estero Waste Water Treatment Plant

I. Summary

In March, 2012, the Santa Barbara County Air Pollution Control District (District) conducted an air toxics

Health Risk Assessment (HRA) screening for the proposed installation of a digester gas-fired

cogeneration engine at the El Estero Waste Water Treatment Plant in Santa Barbara, using SCREEN3

software, Version 5.00. Cancer risk and chronic and acute non-cancer Hazard Index (HI) risk values were

calculated and compared to significance thresholds for cancer and chronic and acute non-cancer risk

adopted by the District’s Board of Directors. The calculated risk values and applicable thresholds are as

follows:

El Estero WWTP Max Risks Significance Threshold




Based on these results, the installation of a digester gas-fired cogeneration engine would not present a

significant risk to the offsite and surrounding communities. For this reason, the Authority to Construct

No.13862 for this project will be issued.

II. Background

This permitting action is for the installation of a digester gas-fired cogeneration engine at the El Estero

Waste Water Treatment Plant located at 520 E. Yanonali Street in Santa Barbara. The property

boundary of El Estero WWTP is within 1000 feet of El Puente Community School, where

students and faculty are present. For that reason, a health risk assessment screening was required. The

District conducted an HRA screening based on a residential lifetime exposure duration of 70 years and the

results are shown above.

III. Facility Information

EQUIPMENT OWNER/OPERATOR: California Power Partners Santa Barbara LLC

SOURCE IDENTIFICATION NUMBER: 02059

DRAFT


EQUIPMENT LOCATION: 520 E. Yanonali Street, Santa Barbara

EQUIPMENT DESCRIPTION: One digester gas-fired cogeneration engine. The engine

will be a Guascore Model IC-G-B-56-034 IC spark

ignited lean burn engine rated at 650 Kw.

IV. Stack and Modeling Parameters (a.k.a. Emission Release Points)

The emissions from the digester gas-fired cogeneration engine were modeled as a point source with the

exhaust stack as the exit point. The minimum receptor distance was set to 40 feet as this is the minimum

distance from the exhaust stack to the nearest property boundary. The stack parameter inputs to the

dispersion model are as follows:

Source

Stack

Height

(ft)

Stack

Temperature

(°F)

Stack

Velocity

(fps)

Stack

Flow Rate

(acfm)

Stack

Diameter

(ft)

IC Engine 30.0 350 89.64 2933 0.83

The stack velocity was calculated from the volumetric flow.

V. Emissions

The speciated toxics emissions for digester gas-fired cogeneration engine were based on the

manufacturer’s specified maximum fuel gas consumption for the equipment and the San Joaquin Valley

APCD’s Toxic Emission Factors for Digester Gas-Fired Internal Combustion Engines. These emission

factors are based on the 2002 Reciprocating Internal Combustion Engine (RICE) EPA database.

The resultant emission profile for the facility may be found in the A13862 HRA Screening.xls file

referenced in the Attachment section of this report.

VI. Building Information

The cogeneration engine exhaust stack will be located near a building. The dimensions of this building

were provided by the applicant and included in the health risk assessment screening modeling.

VII. Met Data & DEM Files

Meteorological data used in the dispersion analysis was SCREEN3 screening met data. Screening met

data was used as a worst case assumption for this project. Since the health risk assessment using

screening met data showed the health risk was below the District’s significance thresholds, a refined HRA

was not required.

DRAFT


VIII. Results

Cancer risk and chronic and acute non-cancer Hazard Index (HI) risk values were calculated and

compared to significance thresholds for cancer risk and chronic and acute non-cancer risk adopted by the

District’s Board of Directors. The calculated risk values and applicable thresholds are as follows:

Calculated Max Risks Significance Threshold




IX. Conclusion

Per District guidelines, if a facility’s toxic emissions result in a cancer risk equal to or greater than 10 in a

million, it is considered a significant risk facility. For non-cancer risk, if a facility’s toxic emissions

result in a Hazard Index equal to or greater than 1.0, it is considered a significant risk facility. The HRA

screening results show that the installation of a digester gas-fired cogeneration engine would not present

significant risk to the offsite and surrounding communities. Therefore, based on the results of this HRA,

the Authority to Construct No. 13862 for this project will be issued.

X. References

Risk notification levels were adopted by Santa Barbara Air Pollution Control Board of Directors

on June 1993. The risk notification levels were set at 10 per million for cancer risk and a Hazard

Index of 1.0 for non-cancer risk.

Risk reduction thresholds were adopted by Santa Barbara Air Pollution Control Board of

Directors on September 17, 1998. These risk reduction thresholds were set at the same level as

public notification thresholds, i.e., 10 per million for cancer risk and a Hazard Index of 1.0 for

non-cancer risk.

San Joaquin Valley Air Pollution Control District’s Toxic Emission Factors for Digester Gas-

Fired Internal Combustion Engines

(http://www.valleyair.org/busind/pto/emission_factors/Criteria/Toxics/Internal%20Combustion/D

igesterGasICEngine.xls).

XI. Attachments

Source parameter data and HRA input and output files may be found in the following location:

\\sbcapcd.org\toxics\Sources\El Estero WWTP\A13862 HRA Screening.xls

\\sbcapcd.org\toxics\Sources\El Estero WWTP\ATC 13862 HRA Screening Report.doc

http://www.valleyair.org/busind/pto/emission_factors/Criteria/Toxics/Internal%20Combustion/DigesterGasICEngine.xls

http://www.valleyair.org/busind/pto/emission_factors/Criteria/Toxics/Internal%20Combustion/DigesterGasICEngine.xls