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Or San Joaquin Valley si. AIR POLLUTION CONTROL DISTRICT HEALTHY ,CH• LIVING -

SinciaNly,

Letad Apaud Marjollet Director of Permit Services

APR 2 8 2015 Mr. Brent Winn Aera Energy LLC PO Box 11164 Bakersfield, CA 93389

Re: Proposed ATC / Certificate of Conformity (Significant Mod) District Facility # S-1547 Project # 1150568

Dear Mr. Winn:

Enclosed for your review is the District's analysis of an application for Authorities to Construct for the facility identified above. You requested that Certificates of Conformity with the procedural requirements of 40 CFR Part 70 be issued with this project. The project revises monitoring requirements for three gas turbine engines.

After addressing all comments made during the 30-day public notice and the 45-day EPA comment periods, the District intends to issue the Authorities to Construct with Certificates of Conformity. Please submit your comments within the 30-day public comment period, as specified in the enclosed public notice. Prior to operating with modifications authorized by the Authorities to Construct, the facility must submit an application to modify the Title V permit as an administrative amendment, in accordance with District Rule 2520, Section 11.5.

If you have any questions, please contact Mr. Leonard Scandura, Permit Services Manager, at (661) 392-5500.

Thank you for your cooperation in this matter.

Enclosures

AM/RE/set

cc: Mike Tollstrup, CARB (w/enclosure) via email cc: Gerardo C. Rios, EPA (w/enclosure) via email

Seyed Sadredin

Executive DirectorlAir Pollution Control Officer

Northern Region

4800 Enterprise Way

Modesto, CA 95356-8718

Tel: (209) 557-6400 FAX: 1209) 557-6475

Central Region (Main Office)

19906. Gettysburg Avenue

Fresno, CA 93726-0244

Tel:15591230-6000 FAX: (559) 230-6061

Southern Region

34946 Flyover Court

Bakersfield, CA 93308•9725

Tel: 661-392-5500 FAX: 661-392-5585

vvww.valleyair.org www.healthyairliving.com Printul on renncled [Wu. 0

Aera Energy LLC S1547, 1150568

San Joaquin Valley Air Pollution Control District Authority to Construct Application Review

Change in Gas Turbine Continuous Monitoring Equipment

Facility Name:

Mailing Address:

Contact Person:

Telephone:

Fax:

E-Mail:

Application #(s):

Project #:

Deemed Complete:

Aera Energy LLC

PO Box 11164 Bakersfield, CA 93389

Brent Winn

(661) 665-4363, (661) 747-8963 (cell)

(661) 665-7437

btwinnAaeraenerqy.com

S-1547-148-22, `-149-21, and `-151-22

1150568

February 23, 2015

Date: April 1, 2015

Engineer: Richard Edgehill

Lead Engineer: Richard Karrs

I. Proposal

Aera Energy LLC (Aera) has requested Authorities to Construct (ATCs) permit to modify three existing 21.45 MW natural gas-fired turbines by replacing the existing Continuous Emission Monitoring System (CEMS) with a Predictive Emission Monitoring System (PEMS) for CO and 02.

PEMS correlates unit measurements of operational parameters fuel flow, temperature, etc. with stack measurements of NOx, CO, and 02 through source testing. The correlation relationship is then used to predict NOx, CO, and 02 from the operational parameters.

The District has determined that the change from monitoring by CEMS to PEMS does not lessen the stringency of the NOx and CO emissions limits and therefore the proposed chanqe is not a NSR Modification as it is consistent with FYI — 111 Category 2 as stated below:

ATC ..

"f - re qa appTVlication req'd ?

NSR mod ? Description Comments

2 Yes Yes No modifying monitoring and record keeping requirements, provided the change does not lessen the stringency of an emissions limit

Changes to monitoring or recordkeeping are not changes in the method of "operation" of the emission unit even though monitoring/recordkeeping conditions must be changed.

BACT, offsets, and public notice are not required.

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Disposition of Outstanding ATCs

There are no outstanding ATCs for S-1547-148, '-149, and '-151. Current Permits to Operate 5-1547-148-21, '-149-20, and `-151-20 are included in Attachment I.

Aera facility S-1547 has a Title V PTO. The change in from GEMS to PEMS is a relaxation in monitoring and therefore triggers a Title V Significant Modification pursuant to Rule 2520, and can be processed with a Certificate of Conformity (COC). Since the facility has specifically requested that this project be processed in that manner, the 45-day EPA comment period will be satisfied prior to the issuance of the Authority to Construct. OEHI must apply to administratively amend their Title V permit.

II. Applicable Rules

Rule 2201 New and Modified Stationary Source Review Rule (04/21/11) Rule 2410 Prevention of Significant Deterioration (6/16/11) Rule 2520 Federally Mandated Operating Permits (6/21/01) Rule 4001 New Source Performance Standards (4/14/99)

Subpart GG - Standards of Performance for Stationary Gas Turbines Subpart KKKK — Standards of Performance for Stationary Combustion Turbines — not applicable- units were constructed pre-2005

Rule 4101 Visible Emissions (02/17/05) Rule 4102 Nuisance (12/17/92) Rule 4201 Particulate Matter Concentration (12/17/92) Rule 4703 Stationary Gas Turbines (09/20/07) Rule 4801 Sulfur Compounds (12/17/92) CH&SC 41700 Health Risk Assessment CH&SC 42301.6 School Notice Public Resources Code 21000-21177: California Environmental Quality Act (CEQA) California Code of Regulations, Title 14, Division 6, Chapter 3, Sections 15000-15387: CEQA Guidelines

Ill. Project Location

The equipment is located at Section 32, T28S, R21E in Aera's heavy oil western stationary source. The equipment is not located within 1,000 feet of the outer boundary of a K-12 school. Therefore, the public notification requirement of California Health and Safety Code 42301.6 is not applicable to this project.

IV. Process Description

The subject 21.45 MW gas turbines are equipped with Heat Recovery Steam Generators (HRSGs).

Proposed Modification

The existing GEMS for monitoring NOx, CO, and 02 will be replaced by PEMS monitoring.

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The PEMS must satisfy the requirements of EPA's Performance Specification 16— Specifications and Test Procedures for Predictive Emission Monitoring Systems (PEMS) in Stationary Sources.

A technical justification of PEMS as a replacement of CEMS was provided for project S-2234, 1144001, which also authorized replacement of CEMS with PEMS, is provided below.

PEMS as CEMS Replacement Technical Justification:

In March 2009, EPA published Performance Specification 16— Specifications and Test Procedures for Predictive Emission Monitoring Systems (PEMS) in Stationary Sources. Performance Specification 16 allows for operators with approvals to use a PEMS to show compliance with emission limitations under 40 CFR 60, 61, or 63.

Rockwell's SoftwareCEM® is more accurate and reliable than our current conventional CEM with capability to reach 3% accuracy. The expected maintenance cost of Rockwell's SoftwareCEMO is significantly less than (our) current conventional CEM. SoftwareCEM®'s have never failed a RATA certification (accuracy) test. Rockwell's SoftwareCEM® provides accurate emissions monitoring through both first principle and empirical mathematical modeling. The Software CEM application(s) has successfully passed the initial certification tests as described in US EPA's Performance Specification 16 for PEMS. PEMS are installed in a standard Server workstation and interface with the process control system without any additional field devices or cabinets. This is particularly pertinent in units where space availability is an issue.

The following readings will be available for each unit (list can be customized based on operating envelop, PTO):

• Ambient pressure, temperature, and relative humidity • Delta P Air inlet • Water/steam injection rate • SCR ammonia injection rate • Compressor inlet pressure (air inlet) • Compressor inlet temperature (air inlet) • Compressor discharge pressure • Compressor discharge temperature • Gas generator exhaust temperature • Gas generator • Load • Fuel Flow(s) to turbine and duct burner

PEMS will adhere to EPA Specification 16 and local legislation requirements, including model recalibration and abnormal input values detection and management. PEMS do not need consumables and spare parts, negating the need for warehouse storage and excess expenditures.

EPA Specification 16 Requirements

Periodic performance checks are required to be conducted to ensure long-term quality of the data. These include annual RATA (Source Testing) and quarterly RAA testing (every quarter except when RATA is conducted). The periodic testing must be conducted with established protocol including a fixed number of runs at 3 levels and minimum number of variables for use in the statistical correlations. The PEMS must be designed such that defective sensors can be

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determined manually or automatically on a daily basis. Recertification of the PEMS must be done with failure of annual and/or quarterly performance tests and/or if process operational parameters change significantly since the initial certification.

The District has concluded that replacement of CEMS with PEMS does not result in loss of stringency of an emissions limit. The following conditions specifically referencing the PEMS are included on the ATCs:

The PEMS (Rockwell Automation Software) is described in Attachment II.

V. Equipment Listing

Pre-Project Equipment Descriptions:

S-1547-148-21: 21.45 MW GAS FIRED TURBINE ENGINE COGENERATION FACILITY #1 WITH GENERAL ELECTRIC MODEL LM2500 PE GAS TURBINE AND UNFIRED WASTE HEAT RECOVERY STEAM GENERATOR

S-1547-149-20: 21.45 MW GAS FIRED TURBINE ENGINE COGENERATION FACILITY #2 WITH GENERAL ELECTRIC MODEL LM2500 PE GAS TURBINE, UNFIRED WASTE HEAT RECOVERY STEAM GENERATOR EQUIPPED WITH SCR AND AMMONIA INJECTION, AND BYPASS STACK EQUIPPED WITH SCR AND AMMONIA INJECTION


Proposed Modifications:

S-1547-148-22: MODIFICATION OF 21.45 MW GAS FIRED TURBINE ENGINE COGENERATION FACILITY #1 WITH GENERAL ELECTRIC MODEL LM2500 PE GAS TURBINE AND UNFIRED WASTE HEAT RECOVERY STEAM GENERATOR, (AND BYPASS STACK EQUIPPED WITH SCR AND AMMONIA INJECTION)*: REPLACE EXISTING NOX, CO AND 02 CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) WITH A NEW ROCKWELL AUTOMATION PREDICTIVE EMISSION MONITORING SYSTEM (PEMS)

*words in parentheses deleted from current PTO equipment

S-1547-149-21: MODIFICATION OF 21.45 MW GAS FIRED TURBINE ENGINE COGENERATION FACILITY #2 WITH GENERAL ELECTRIC MODEL LM2500 PE GAS TURBINE, UNFIRED WASTE HEAT RECOVERY STEAM GENERATOR EQUIPPED WITH SCR AND AMMONIA INJECTION, AND BYPASS STACK EQUIPPED WITH SCR AND AMMONIA INJECTION:

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REPLACE EXISTING NOX, CO AND 02 CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) WITH A NEW ROCKWELL AUTOMATION PREDICTIVE EMISSION MONITORING SYSTEM (PEMS)

S-1547-151-22: MODIFICATION OF 21.45 MW GAS FIRED TURBINE ENGINE COGENERATION FACILITY #3 WITH GENERAL ELECTRIC MODEL LM2500 PE GAS TURBINE, UNFIRED WASTE HEAT RECOVERY STEAM GENERATOR EQUIPPED WITH SCR AND AMMONIA INJECTION, AND BYPASS STACK EQUIPPED WITH SCR AND AMMONIA INJECTION: REPLACE EXISTING NOX, CO AND 02 CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) WITH A NEW ROCKWELL AUTOMATION PREDICTIVE EMISSION MONITORING SYSTEM (PEMS)

Post Project Equipment Descriptions:

S-1547-148-22: 21.45 MW GAS FIRED TURBINE ENGINE COGENERATION FACILITY #1 WITH GENERAL ELECTRIC MODEL LM2500 PE GAS TURBINE, UNFIRED WASTE HEAT RECOVERY STEAM GENERATOR, AND BYPASS STACK EQUIPPED WITH SCR AND AMMONIA INJECTION



VI. Emission Control Technology Evaluation

Emissions from gas-fired turbines include NOx, CO, VOC, PM10, and SOx.

The turbine provides electricity for the facility. The turbine exhausts directly out the turbine stack (bypass) or to a waste heat recovery steam generator (HRSG) each equipped with SCR. The waste HRSG provides high quality steam for injection into the heavy crude oil production zone.

There are no proposed changes to any emission control devices in this project.

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VII. General Calculations

A. Assumptions

The project is not a NSR Modification and therefore calculations are not required. PE2 will be restated for inclusion in the PAS emissions profile.

PTO Condition:

Fuel consumption shall not exceed 5,650 MMBtu/day (235.42 MMBtu/hr) of fuel gas. [District Rule 2201] Y

Annual emissions are daily emissions x 365.

B. Post-Project Emission Factors (EF2)

For this unit, post-project emission factors are listed in the table below.

Pollutant Post-Project Emission Factors (EF2) Source

NO 11 lb-N0x/MMscf

0.011 lb-N0x/MMBtu (steady state)

0.147 lb-N0x/MMBtu (startup/shutdown, project 1060924)

3 PPmvd NO (@ 15%02)

(steady state)

Current PTO

SOx 10 lb-S0x/MMscf 0.01 lb-S0x/MMBtu It

PM10 16 lb-PM10/MMscf 0.016 lb-PM10/MMBtu „

CO 76 lb-CO/MMscf 0.076 lb-CO/MMBtu 33.9 ppmvd CO (@15%02)

,.

VOC 8 lb-VOC/MMscf 0.008 lb-VOC/MMBtu ,.

• PE2 = EF (Ib/MMBtu) x Heat Input (MMBtu/hr) x Op. Sched. (hr/day or hr/year)

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C. Calculations

Pollutant

Daily PE2

EF2 (Ib/MMBtu)

Heat Input (MMBtu/hr)

Operating Schedule (hr/day)

Daily PE2 (lb/day)

NO 0.011 235.42 24 see below SO x 0.01000 235.42 24 56.5

PNLio 0.0160 235.42 24 90.4

CO 0.076 235.42 24 429.4

VOC 0.0080 235.42 24 45.2

Pollutant

Annual PE2

EF2 (Ib/MMBtu)

Heat Input (MMBtu/hr)

Operating Schedule (hr/year)

Annual PE2

(lb/year)

NOx 0.011 235.42 8,760 see below SOx 0.01000 235.42 8,760 20,623

PIVlio 0.0160 235.42 8,760 32,996

CO 0.076 235.42 8,760 156,733

VOC 0.0080 235.42 8,760 16,498

PE2 = (0.011 lb-NOMMB u x 235.4 MMBtu/hr x 20 hr/day) + (0.147 lb-N0 x/MMBtu x 235.4 MMBtu/hr x 4 hr/day) = 190.2 lb-N0x/day (69,423 lb/yr)

Emissions profiles are included in Attachment Ill.

Compliance

Rule 2410 Prevention of Significant Deterioration

As shown in Section VII. C. 9. above, this project is not a NSR Modification and results in no emissions increase. Therefore the project does not result in a new PSD major source or PSD major modification. No further discussion is required.

Rule 2520 Federally Mandated Operating Permits

This facility is subject to this Rule, and has received their Title V Operating Permit. A significant permit modification is defined as a "permit amendment that does not qualify as a minor permit modification or administrative amendment."

Minor permit modifications do not relax monitoring, reporting, or recordkeeping requirements in the permit and are not significant changes in existing monitoring permit terms or conditions. The monitoring method change from CEMS to PEMS and is a relaxation in monitoring. As a result, the proposed project constitutes a Significant Modification to the Title V Permit.

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As discussed above, the facility has applied for a Certificate of Conformity (COO); therefore, the facility must apply to modify their Title V permit with an administrative amendment/minor modification, prior to operating with the proposed modifications. Continued compliance with this rule is expected. The facility shall not implement the changes requested until the final permit is issued.

The Title V Compliance Certification form is included in Attachment IV.

Rule 4001 New Source Performance Standards

40 CFR 60— Subpart GG

40 CFR Part 60 Subpart GG applies to all stationary gas turbines with a heat input greater than 10.7 gigajoules per hour (10.2 MMBtu/hr), that commence construction, modification, or reconstruction after 10/03/77. Each of the turbines within this project were installed after 1977 and before 2005 (Subpart KKKK is not applicable). Therefore, this subpart applies to the turbines.

The turbines were shown to be in compliance with the Subpart in project 1060924 and this project is not expected to affect compliance status. Continued compliance is expected.

Rule 4101 Visible Emissions

Per Section 5.0, no person shall discharge into the atmosphere emissions of any air contaminant aggregating more than 3 minutes in any hour which is as dark as or darker than Ringelmann 1 (or 20% opacity). As the turbines are fired solely on natural gas, visible emissions are not expected to exceed Ringelmann 1 or 20% opacity. Also, based on past inspections of the facility continued compliance is expected.

Rule 4102 Nuisance

Section 4.0 prohibits discharge of air contaminants which could cause injury, detriment, nuisance or annoyance to the public. Public nuisance conditions are not expected as a result of these operations, provided the equipment is well maintained. Therefore, compliance with this rule is expected.

California Health & Safety Code 41700 (Health Risk Assessment)

District Policy APR 1905 — Risk Management Policy for Permitting New and Modified Sources specifies that for an increase in emissions associated with a proposed new source or modification, the District perform an analysis to determine the possible impact to the nearest resident or worksite.

As demonstrated above, there are no increases in emissions associated with this project and no changes to the exhaust stack parameters, therefore a health risk assessment is not necessary for this project and continued compliance with the requirements of this rule is expected.

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Rule 4201 Particulate Matter Concentration

Section 3.1 prohibits discharge of dust, fumes, or total particulate matter into the atmosphere from any single source operation in excess of 0.1 grain per dry standard cubic foot. The units are currently operating in compliance and the project is not expected to affect compliance status.

Rule 4703 Stationary Gas Turbines

The purpose of this rule is to limit oxides of nitrogen (N0x) emissions from stationary gas turbine systems.

The provisions of this rule apply to all stationary gas turbine systems, which are subject to District permitting requirements, and with ratings equal to or greater than 0.3 megawatt (MW) or a maximum heat input rating of more than 3 MMBtu per hour.

Each gas turbine is rated at 21.45 MW. Therefore, each turbine is subject to the requirements of this rule.

The subject units include permit conditions ensuring compliance with the rule and the project is not expected to affect compliance status. Continued compliance is expected.

Rule 4801 Sulfur Compounds

Per Section 3.1, a person shall not discharge into the atmosphere sulfur compounds, which would exist as a liquid or gas at standard conditions, exceeding in concentration at the point of discharge: 0.2 % by volume calculated as SO2 on a dry basis averaged over 15 consecutive minutes.

The units were demonstrated to be in compliance with the rule in previous projects (1060924 and 1050823) and the project is not expected to affect compliance status. Continued compliance is expected.

California Health & Safety Code 42301.6 (School Notice)

The District has verified that this site is not located within 1,000 feet of a school. Therefore, pursuant to California Health and Safety Code 42301.6, a school notice is not required.

California Environmental Quality Act (CEQA)

The California Environmental Quality Act (CEQA) requires each public agency to adopt objectives, criteria, and specific procedures consistent with CEQA Statutes and the CEQA Guidelines for administering its responsibilities under CEQA, including the orderly evaluation of projects and preparation of environmental documents. The San Joaquin Valley Unified Air Pollution Control District (District) adopted its Environmental Review Guidelines (ERG) in 2001. The basic purposes of CEQA are to:

• Inform governmental decision-makers and the public about the potential, significant environmental effects of proposed activities.

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• Identify the ways that environmental damage can be avoided or significantly reduced. • Prevent significant, avoidable damage to the environment by requiring changes in

projects through the use of alternatives or mitigation measures when the governmental agency finds the changes to be feasible.

• Disclose to the public the reasons why a governmental agency approved the project in the manner the agency chose if significant environmental effects are involved.

The District performed an Engineering Evaluation (this document) for the proposed project and determined that all project specific emission unit(s) are exempt from Best Available Control Technology (BACT) requirements. Furthermore, the District has determined that potential emission increases would have a less than significant health impact on sensitive receptors. Issuance of permits for emissions units not subject to BACT requirements and with health impact less than significant is a matter of ensuring conformity with applicable District rules and regulations and does not require discretionary judgment or deliberation. Thus, the District concludes that this permitting action constitutes a ministerial approval. Section 21080 of the Public Resources Code exempts from the application of CEQA those projects over which a public agency exercises only ministerial approval. Therefore, the District finds that this project is exempt from the provisions of CEQA.

IX. Recommendation

Compliance with all applicable rules and regulations is expected. Issue ATCs subject to the permit conditions on the attached draft ATCs in Attachment V.

X. Billing Information

Permit Number Annual Permit Fees

Fee Schedule Fee Description Annual Fee

S-1547-148-22, '-149-21, and `-151-22 3020-08-AF

21.45 MW

$8,171.00

Attachments

I: Current PTOs II: Manufacturer's Information of PEMs Software III: Emissions Profiles IV: Title V Compliance Certification Form V: Draft ATCs

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ATTACHMENT I Current PTOs

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San Joaquin Valley Air Pollution Control District

PERMIT UNIT: S-1547-148-21

EXPIRATION DATE: 05/31/2016

SECTION: 32 TOWNSHIP: 28S RANGE: 21E

EQUIPMENT DESCRIPTION: 21.45 MW GAS FIRED TURBINE ENGINE COGENERATION FACILITY #1 WITH GENERAL ELECTRIC MODEL LM2500 PE GAS TURBINE AND UNFIRED WASTE HEAT RECOVERY STEAM GENERATOR

PERMIT UNIT REQUIREMENTS I. Fuel consumption shall not exceed 5,650 MMBtu/day of fuel gas. [District Rule 22011 Federally Enforceable Through

Title V Permit

2. HHV and LHV of the fuel shall be determined using ASTM D3588, ASTM 1826, or ASTM 19451. [District Rule 4703, 6.4.5] Federally Enforceable Through Title V Permit

3. NOx emissions shall not exceed 75 ppmv @ 15% 02 (one-hour rolling average in accordance with 40 CFR 60.13(h)). [40 CFR 60.332(b)] Federally Enforceable Through Title V Permit

4. This is a BARCT Offset emission unit. For the purposes of Actual Emission Reduction calculations only, this unit shall be considered to have NOx emissions of 20.6 ppmv @ 15% oxygen. [District Rule 4501] Federally Enforceable Through Title V Permit

5. Except during startup, shutdown, and stack transitions, emission rates (three-hour rolling average) shall not exceed any of the following: NOx: 0.011 lb/MMBtu or 3 ppmv @ 15% 02; and CO: 0.076 lb/MMBtu or 33.9 ppmvd @15% 02. [District Rule 4703, 5.1, 5.2 and 7.2] Federally Enforceable Through Title V Permit

6. Emission rates from the gas turbine engine shall not exceed any of the following: 0.016 lb-PM10/MMBtu, 0.010 lb-S0x/MMBtu, or 0.008 lb-VOC/MMBtu. [District Rule 2201] Federally Enforceable Through Title V Permit

7. On days of gas turbine engine startup/shutdown, permittee shall demonstrate compliance with NOx daily emission limitation by records of calculations using CEM data, fuel rate data, and daily hours of operation data. [District Rule 1080] Federally Enforceable Through Title V Permit

8. Maximum daily emission limitations (DEL) shall not exceed any of the following: 190.2 lb -NOxiday; 56.5 lb-SOxiday, 90.4 lb-PM 10/day, 429.4 lb-CO/day, or 45.2 lb-VOC/day. [District Rule 2201] Federally Enforceable Through Title V Permit

9. The ammonia injection rate shall not exceed 25 lb/hr. [District Rules 2201 and 4102] Federally Enforceable Through Title V Permit

10. The operator shall monitor the ammonia injection rate during CEM breakdowns to demonstrate NOx emission compliance. [District Rule 4703, 6.2.5] Federally Enforceable Through Title V Permit

11. Startup shall be defined as the period of time, not to exceed two hours, during which a unit is brought from a shutdown status to its operating temperature and pressure, including the time required by the unit's emission control system to reach full operation. [District Rule 4703, 3.29 and 5.3] Federally Enforceable Through Title V Permit

12. Shutdown shall be defined as the period of time, not to exceed two hours, during which a unit is taken from an operational to a non-operational status by allowing it to cool down from its operating temperature to ambient temperature as the fuel supply to the unit is completely turned off. [District Rule 4703, 3.26 and 5.3] Federally Enforceable Through Title V Permit

PERMIT UNIT REQUIREMENTS CONTINUE ON NEXT PAGE These terms and conditions are part of the Facility-wide Permit to Operate.

Facility Name: AERA ENERGY LLC Location: HEAVY OIL WESTERN STATIONARY SOURCE,KERN COUNTY, CA 5-1547-148.21: Mw 31 2015 11:25AM - C00E11101

Permit Unit Requirements for S-1547-148-21 (continued) Page 2 of 4

13. Stack transitions shall comply with the following criteria for HRSG Bypass Transition Period: the duration of time that the turbine's operation transitions between the heat recovery steam generator and bypass exhaust stack, when the selective catalytic reduction catalyst is not within the required temperature range or the required ammonia saturation level has not yet been achieved, the transition period not exceeding two hours, and NOx emissions not exceeding 15 ppmvd, corrected to 15% 02, averaged over 2 hours, and the applicable CO compliance limits not being exceeded. [District Rule 4703] Federally Enforceable Through Title V Permit

14. Permittee shall report the following emission exceedances to the District: NOx emission rate on a three-hour average and daily NOx emissions during days of gas turbine engine startup/shutdown or stack transition. [District Rule 1080] Federally Enforceable Through Title V Permit

15. Permittee shall maintain accurate daily records of fuel gas consumption and such records shall be made readily available for District inspection upon request for a period of five years. [District Rule 1081] Federally Enforceable Through Title V Permit

16. The owner or operator shall certify, maintain, operate and quality-assure a system which continuously measures and records the exhaust gas oxides of nitrogen, carbon monoxide, and oxygen or carbon dioxide. [District Rule 1080, 4.0, 40 CFR 60.334(b), District Rule 4703, 6.2.1, & PSD SJ 85-03] Federally Enforceable Through Title V Permit

17. The CMS shall complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15-minute period or shall meet equivalent specifications established by mutual agreement of the District, the ARB and the EPA. [District Rule 40 CFR 60.334(b)(2) and District Rule 1080, 6.4] Federally Enforceable Through Title V Permit

18. The continuous emissions monitbring system shall meet the performance specification requirements in 40 CFR 60, Appendix -8; and 4-0 -CFR 51, Appendix P, or shall meet equivalent specifications established by mutual agreement of the District, the ARB, and the EPA. [District Rule 1080, 6.5 & PSD SJ 85-03] Federally Enforceable Through Title V Permit

19. Results of continuous emissio ns must be reduced according to the procedure established in 40 CFR, Part 51, Appendix P, paragraphs 5.0 through 5.3.3, or by other methods deemed equivalent by mutual agreement with the District, the ARB, and the EPA. [District Rule 1080, 7.2] Federally Enforceable Through Title V Permit

20. The owner or operator shall maintain CEMS records that contain the following: the occurrence and duration of any start-up, shutdown or malfunction, performance testing, evaluations, calibrations, checks, adjustments, maintenance, duration of any periods during which a continuous monitoring system or monitoring device is inoperative, and emission measurements. [40 CFR 60.7(b), District Rule 1080, 7.3 & PSD SJ 85-03] Federally Enforceable Through Title V Permit

21. Permittee shall submit reports of excess emissions for all periods of unit operation, including startup, shutdown, and malfunction in accordance with 40 CFR 60.344(j). [40 CFR 60.334(j)] Federally Enforceable Through Title V Permit

22. Permittee shall submit a CEMs written report for each calendar quarter to the District. The report is due on the 30th day following the end of the calendar quarter. Quarterly report shall include: time intervals, data and magnitude of excess emissions, nature and cause of excess (if known), corrective actions taken and preventive measures adopted; averaging period used for data reporting corresponding to the averaging period specified in the emission test period used to determine compliance with an emission standard; applicable time and date of each period during which the CEM was inoperative (except for zero and span checks) and the nature of system repairs and adjustments; and a negative declaration when no excess emissions occurred. [40 CFR 60.334(j), (j)(5), District Rule 1080, 8.0 and District Rule 2520, 9.6.1& PSD SJ 85-03] Federally Enforceable Through Title V Permit

23. Excess emissions shall be defined as any consecutive 2-hour period during which the average emissions of NOx and CO, as measured by continuous monitoring system exceeds the concentration emissions limits set forth for these pollutants. Any emisSionS in excess of the limits imposed by conditions in this permit, as measured by the continuous monitoring equipment constitutes a violation of District Rules and Regulations and shall be reported by the operator to the APCO within 96 hours. [District Rule 1080,9.0 & PSD SJ 85-03] Federally Enforceable Through Title V Permit


Facility Name: AERA ENERGY LLC Location: HEAVY OIL WESTERN STATIONARY SOURCE,KERN COUNTY, CA 8.154744621 :Ma, 312015 1115.481 E00E18L11


24. Operator shall notify the District no later than eight hours after the detection of a breakdown of the CE/v1. The operator shall inform the District of the intent to shut down the CEM at least 24 hours prior to the event. [District Rule 1080, 10.0] Federally Enforceable Through Title V Permit

25. The CEMS shall be linked to a data logger which is compatible with the District's Data acquisition system. Upon notice by the District that the facility's CEM system is not providing polling data, the facility may continue to operate without providing automated data for a maximum of 30 days per calendar year provided the CEM data is sent to the District by a District-approved alternative method. [District Rule 2520, 9.4.2] Federally Enforceable Through Title V Permit

26. Gas turbine engine shall be fired exclusively on PUC-regulated or FERC-regulated natural gas or natural gas with sulfur content no greater than 0.8% by weight. [40 CFR 60.333] Federally Enforceable Through Title V Permit

27. If the turbine is not fired on PUC-regulated or FERC-regulated natural gas, the sulfur content of the fuel shall be tested in accordance with 40 CFR 60.344(i). [40 CFR 60.344(i)] Federally Enforceable Through Title V Permit

28. Performance testing to measure exhaust gas NOx and CO concentrations shall be conducted annually. [40 CFR 60.335(b), District Rule 4703, 6.3 & PSD Si 85-03] Federally Enforceable Through Title V Permit

29. The following test methods shall be used: NOx (ppmv) - EPA Methods 7E or 20, or ARB Method 100; CO (ppmv) - EPA Method 10 or 10B, or ARB Method 100; stack gas oxygen - EPA Method 3, 3A or 20, or ARB Method 100; and fuel gas sulfur content - ASTM D3246, fuel gas hhv - ASTM D1826 or D1945 in conjunction with ASTM D3588. [40 CFR 60.335 and District Rules 1081, 4703, 6.4 & PSD SJ 85-03] Federally Enforceable Through Title V Permit

30. The District must be notified 30 days prior to any performance testing and a test plan shall be submitted for District approval 15 days prior to such testing. [District Rule 1081, 7.1] Federally Enforceable Through Title V Permit

31. Performance testing shall be witnessed or authorized by District personnel. Test results must be submitted to the District within 60 day of performance testing. [District Rule 1081, 7.2, 7.3] Federally Enforceable Through Title V Permit

32. Daily records of NOx and CO emission calculations during days of startup/shutdown or stack transitions shall be maintained and such records shall be made readily available for District inspection upon request. [District Rule 2520, 9.4.2] Federally Enforceable Through Title V Permit

33. CO emissions shall not exceed (lbs/hr) (three-hour average) = 38-(0.2)*(ambient air temperature in oFahrenheit) (not to exceed 30 lbs/hr) and (ppmv) = 1.86*(lbs/hr) @ 15% 02 (not to exceed 55.8 ppmv). [PSD Si 85-03] Federally Enforceable Through Title V Permit

34. Permittee shall operate and maintain a continuous, monitoring system to measure the ambient air temperature. [PSD SJ 85-03] Federally Enforceable Through Title V Permit

35. Permittee shall operate and maintain a water injection system and instrumentation to continuously monitor and record levels of consumption of fuel and water. [PSD Si 85-03] Federally Enforceable Through Title V Permit

36. EPA Regional Administrator shall be notified by telephone within 48 hours following any failure of air pollution control equipment, process equipment, or of a process to operate in a normal manner which results in an increase in emissions above any allowable PSD emissions limits. [PSD SJ 85-03] Federally Enforceable Through Title V Permit

37. All equipment, facilities, or systems installed or used to achieve compliance with the terms and conditions of this permit shall at all times be maintained in good working order and be operated as efficiently as possible so as to minimize air pollutant emissions. [PSD SJ 89-02] Federally Enforceable Through Title V Permit

38. All correspondence as required by this permit shall be forwarded to: a) Director, Air Management Division, Compliance Section (Attn: A-3-3), EPA Region IX, 75 Hawthorne Street, San Francisco, CA, 94105; b) Chief, Stationary Source Control Division, California Air Resource Board, P.O. Box 2815, Sacramento, CA, 95814; and c) Director, SNUAPCD, 1990 East Gettysburg, Fresno, CA, 93726. [PSD SJ 89-02] Federally Enforceable Through Title V Permit


Facility Name: AERA ENERGY LLC Location: HEAVY OIL WESTERN STATIONARY SOURCE,KERN COUNTY, CA 5-1547-145-21 . Mar 31 2015 1115MI-- EDGE-MR


39. The owner or operator of a stationary gas turbine system shall maintain all records of required monitoring data and support information for inspection at any time for a period of five years. [District Rule 2520, 9.4.2] Federally Enforceable Through Title V Permit

40, Permittee shall maintain records of the following: 1) the occurrence and duration of any start-up, shutdown, or malfunction in the operation of the permit unit; 2) performance testing, evaluations, calibrations, checks, adjustments, and maintenance of CEMS; and 3) emission measurements. [District Rules 1080, 7.3; 2520, 9.4.2; 4703, 6.2.8] Federally Enforceable Through Title V Permit

41. The owner or operator shall maintain a stationary gas turbine operating log that includes, on a daily basis, the actual local start-up and stop time, length and reason for stack transitions, total hours of operation, and quantity and heat input of fuel used. [District Rule 4703, 6.2.6] Federally Enforceable Through Title V Permit

42. The owner or operator shall monitor the gas turbine exhaust gas NOx emissions using a system that meets EPA requirements as specified in 40 CFR Part 60 App. B, Spec. 3, 40 CFR Part 60 App. F, and 40 CFR Part 60.7 (c), 60.7 (d), and 60.13. [District Rule 4703, 6.2.3] Federally Enforceable Through Title V Permit

These terms and conditions are part of the Facility-wide Permit to Operate. Facility Name: AERA ENERGY LLC Location: HEAVY OIL WESTERN STATIONARY SOURCE,KERN COUNTY, CA 8-1547-140-21: Mar 31 2015 112WA — EDGEHILA


PERMIT UNIT: S- 1547- 149 -20 EXPIRATION DATE: 05/31/2016


EQUIPMENT DESCRIPTION: 21.45 MW GAS FIRED TURBINE ENGINE COGENERATION FACILITY #2 WITH GENERAL ELECTRIC MODEL LM2500 PE GAS TURBINE, UNFIRED WASTE HEAT RECOVERY STEAM GENERATOR EQUIPPED WITH SCR AND AMMONIA INJECTION, AND BYPASS STACK EQUIPPED WITH SCR AND AMMONIA INJECTION

PERMIT UNIT REQUIREMENTS 1. Fuel consumption shall not exceed 5,650 MMBtu/day of fuel gas. [District Rule 2201] Federally Enforceable Through

Title V Permit

2. HHV and LHV of the fuel shall be determined using ASTM D3588, ASTM 1826, OR ASTM 1945. [District Rule 4703, 6.4.5] Federally Enforceable Through Title V Permit

3. Except during periods of gas turbine engine startup/shutdown and stack transition, emission rates (three-hour rolling average) shall not exceed any of the following: 0.0111 lb-N0x/MMBtu or 3 ppmv-NOx @ 15% 02, and 0.076 lb-CO/MMBtu or 200 ppmvd-00 @15% 02. [District Rules 2201 and 4703, 5.1.2, 5.2] Federally Enforceable Through Title V Permit

4. Except during periods of gas turbine engine startup/shutdown and stack transition, emission rates shall not exceed any of the following: 0.016 lb-PM10/MMBtu, 0.010 lb-S0x/MMBtu, 0.008 lb-VOC/MMBtu. [District Rule 22011 Federally Enforceable Through Title V Permit

5. Maximum daily emission limitations (DEL) shall not exceed any of the following: 190.2 lb-N0x/day, 56.5 lb-S0x/day, 90.4 lb-PM 10/day, 429.4 lb-CO/day, and 45.2 lb-VOC/day. [District Rule 2201] Federally Enforceable Through Title V Permit

6. Startup and shutdown of gas turbine engine, as defined in 40 CFR Subpart A 60.2, shall not exceed a time period of two hours and two hours, respectively, per occurrence. [District Rule 4703, 3.25] Federally Enforceable Through Title V Permit

7. Stack transitions shall comply with the following criteria for HRSG Bypass Transition Period: the duration of time that the turbine's operation transitions between the heat recovery steam generator and bypass exhaust stack, when the selective catalytic reduction catalyst is not within the required temperature range or the required ammonia saturation level has not yet been achieved, the transition period not exceeding two hours, and NOx emissions not exceeding 15 ppmvd, corrected to 15% 02, averaged over 2 hours, and the applicable CO compliance limits not being exceeded. [District Rule 4703] Federally Enforceable Through Title V Permit

8. On days of gas turbine engine startup/shutdown and/or stack transition, permittee shall demonstrate compliance with NOx daily emission limitation by records of calculations using CEMS data, fuel rate data, and daily hours of operation data. [District Rule 1080] Federally Enforceable Through Title V Permit

9. Permittee shall report the following emission exceedances to the District: NOx emission rate on a three-hour average, and DEL of NOx during days of gas turbine engine startup/shutdown or stack transition. [District Rule 1080] Federally Enforceable Through Title V Permit

10. Compliance testing shall be conducted annually as required by the District-approved plan. [District Rule 1081] Federally Enforceable Through Title V Permit


Facility Name: AERA ENERGY LLC Location: HEAVY OIL WESTERN STATIONARY SOURCE,KERN COUNTY, CA S-1647.148-20: Mee rI 201$ 11211.41— 80081-110


11. The results of each source test shall be submitted to the District within 60 days thereafter. [District Rule 10811 Federally Enforceable Through Title V Permit

12. Permittee shall maintain accurate daily records of fuel gas consumption and such records shall be made readily available for District inspection upon request for a period of five years. [District Rule 10811 Federally Enforceable Through Title V Permit

13. Compliance with sulfur oxide emission limits shall be demonstrated by fuel gas sulfur analysis by independent testing laboratory annually. [District Rule 1081] Federally Enforceable Through Title V Permit

14. Permittee shall comply in full with Rule 4001 (New Source Performance Standards) requirements, including notification, recordkeeping and monitoring requirements. [District Rule 4001] Federally Enforceable Through Title V Permit

15. Continuous emission monitoring systems shall be calibrated and operated according to EPA guidelines as specified in CFR, Part 60, Appendix B. [District Rule 4001 and 40 CFR 60.334(b)] Federally Enforceable Through Title V Permit

16. The owner or operator shall install, certify, maintain, operate and quality-assure a system which continuously measures and records the exhaust gas oxides of nitrogen, carbon monoxide, and oxygen or carbon dioxide. [District Rule 1080, 4.0, 40 CFR 60.334(a), District Rule 4703, 6.2.1, & PSD SJ 85-03] Federally Enforceable Through Title V Permit

17. The CEMS shall complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15-minute period or shall meet equivalent specifications established by mutual agreement of the District, the ARB and the EPA. [District Rule 40 CFR 60.334(b)(2) and District Rule 1080, 6.4] Federally Enforceable Through Title V Permit

18. The continuous emissions monitoring system shall meet the performance specification requirements in 40 CFR 60, Appendix B; and 40 CFR 51, Appendix P, or shall meet equivalent specifications established by mutual agreement of the District, the ARE, and the EPA. [District Rule 1080, 6.5 & PSD SJ 85-03] Federally Enforceable Through Title V Permit

19. Results of continuous emissions monitoring must be reduced according to the procedure established in 40 CFR, Part 51, Appendix P, paragraphs 5.0 through 5.3.3, or by other methods deemed equivalent by mutual agreement with the District, the ARB, and the EPA. [District Rule 1080, 7.2] Federally Enforceable Through Title V Permit

20. The owner or operator shall maintain CEMS records that contain the following: the occurrence and duration of any start-up, shutdown or malfunction, performance testing, evaluations, calibrations, checks, adjustments, maintenance, duration of any periods during which a continuous monitoring system or monitoring device is inoperative, and emission measurements. [40 CFR 60.7(b), District Rule 1080, 7.3 & PSD Si 85-03] Federally Enforceable Through Title V Permit

21. Permittee shall submit a CEMS written report for each calendar quarter to the District. The report is due on the 30th day following the end of the calendar quarter. Quarterly report shall include: time intervals, data and magnitude of excess emissions, nature and cause of excess (if known), corrective actions taken and preventive measures adopted; averaging period used for data reporting corresponding to the averaging period specified in the emission test period used to determine compliance with an emission standard; applicable time and date of each period during which the CEMS was inoperative (except for zero and span checks) and the nature of system repairs and adjustments; and a negative declaration when no excess emissions occurred. [40 CFR 60.334(j), District Rule 1080, 8.0 and District Rule 2520, 9.3.2 & PSD SJ 85-03] Federally Enforceable Through Title V Permit

22. Excess emissions shall be defined as any consecutive 2-hour period during which the average emissions of NOx and CO, as measured by continuous monitoring system exceeds the concentration emissions limits set forth for these pollutants. Any emissions in excess of the limits imposed by conditions in this permit, as measured by the continuous monitoring equipment constitutes a violation of District Rules and Regulations and shall be reported by the operator to the APCO within 96 hours. [District Rule 1080, 9.0 & PSD Si 85-03] Federally Enforceable Through Title V Permit

23. Operator shall notify the District no later than eight hours after the detection of a breakdown of the CEMS. The operator shall inform the District of the intent to shut down the CEMS at least 24 hours prior to the event. [District Rule 1080, 10.0] Federally Enforceable Through Title V Permit


Facility Name: AERA ENERGY LLC Location: HEAVY OIL WESTERN STATIONARY SOURCE,KERN COUNTY, CA 8-1517-110.20 tiles 311015 11 NAM — EL1GEHIUI


24. The CEMS shall be linked to a data logger which is compatible with the District's Data acquisition system. Upon notice by the District that the facility's CEMS is not providing polling data, the facility may continue to operate without providing automated data for a maximum of 30 days per calendar year provided the CEMS data is sent to the District by a District-approved alternative method. [District Rule 2520, 9.3.2] Federally Enforceable Through Title V Permit

25. Fuel sulfur content for a fuel source shall be measured weekly. Test reports of measured fuel sulfur content shall be maintained. If measured sulfur content is less than 3.5 gr/100 scf for 8 consecutive weeks for a fuel source, then the testing frequency shall be semi-annually. If any semi-annual testing show fuel sulfur content exceeds 3.5 gr/100 scf, weekly testing shall resume and exceedance shall be reported to APCO. [40 CFR 60.334(h) & District Rule 2520, 9.3.2] Federally Enforceable Through Title V Permit


27. The following test methods shall be used: NOx (ppmv) - EPA Methods 7E or 20, or ARE Method 100; CO (ppmv) - EPA Method 10 or 10B, or ARB Method 100; stack gas oxygen - EPA Method 3, 3A or 20, or ARB Method 100; and fuel gas sulfur content - ASTM D3246 or double GC for H2S and mercaptans, fuel gas hhv - ASTM D1826 or D1945 in conjunction with ASTM D3588. [40 CFR 60.335 and District Rules 1081, 4703, & PSD Si 85-03] Federally Enforceable Through Title V Permit


29. Performance testing shall be witnessed or authorized District by personnel. Test results must be submitted to the District within 60 day of performance testing. [District Rule 1081, 7.2 & 7.3] Federally Enforceable Through Title V Permit

30. Daily records of NOx and CO emission calculations during days of startup/shutdown or stack transition shall be maintained and such records shall be made readily available for District inspection upon request. [District Rule 2520, 9.3.2] Federally Enforceable Through Title V Permit

31. Source testing to measure ammonia shall be conducted using test method BAAQMD ST-1B. [District Rules 2201 and 4102] Federally Enforceable Through Title V Permit

32. The permittee shall maintain records of the daily calculated ammonia slip measurements. [District Rules 2201 and 4102] Federally Enforceable Through Title V Permit

33. The operator shall monitor the ammonia injection rate that was established at the time of startup emission testing during CEMS breakdowns to demonstrate NOx emission compliance. [District Rule 4703, 6.2.5] Federally Enforceable Through Title V Permit


35. Perm ittee shall maintain records of the following: 1) the occurrence and duration of any start-up, shutdown, or malfunction in the operation of the permit unit; 2) performance testing, evaluations, calibrations, checks, adjustments, and maintenance of CEMS; and 3) emission measurements. [District Rules 1080, 7.3, 2520, 9.3.2 and 40 CFR 60.7(b)] Federally Enforceable Through Title V Permit

36. The owner or operator shall maintain a stationary gas turbine operating log that includes, on a daily basis, the actual local start-up and stop time, length and reason for stack transition, total hours of operation, and quantity and heat input of fuel used. [District Rules 2520, 9.3.2, 4703, 6.2.6] Federally Enforceable Through Title V Permit


Facility Name: AERA ENERGY LLC Location: HEAVY OIL WESTERN STATIONARY SOURCE,KERN COUNTY, CA 61647-140.20: Mar 31 2016 11.26M— EDGEHILA


37. The owner or operator of any existing stationary gas turbine system (unless exempted because all turbines are under ownership or control and have NOx and CO emissions limits which are shown on the current Permit to Operate and which do not exceed the applicable Compliance Limits in Section 5.0) shall submit to the APCO for approval, an emissions control plan of all actions. The control plan shall include a schedule of increments of progress that will be taken to comply with the requirements of the applicable NOx Compliance Limit in Section 5.0 and Compliance Schedule in Section 7.0 of District Rule 4703 (as amended 9/20/07). [District Rule 4703, 6.1] Federally Enforceable Through Title V Permit


39. CO emissions shall not exceed (lbs/hr) (three-hour average) = 38-(0.2)*(ambient air temperature in 0Fahrenheit) (not to exceed 30 lbs/hr) and (ppmv) = 1.86*(lbs/hr) @ 15% 02 (not to exceed 55.8 ppmv). [PSD SJ 85-03] Federally Enforceable Through Title V Permit

40. Permittee shall operate and maintain a continuous monitoring system to measure the ambient air temperature. [PSD SJ 85-03] Federally Enforceable Through Title V Permit

41. Permittee shall operate and maintain a water injection system and instrumentation to continuously monitor and record levels of consumption of fuel and water. [PSD SJ 85-03] Federally Enforceable Through Title V Permit



44. All correspondence as required by this permit shall be forwarded to: a) Director, Air Management Division, Compliance Section (Attn: A-3-3), EPA Region IX, 75 Hawthorne Street, San Francisco, CA, 94105; b) Chief, Stationary Source Control Division, California Air Resource Board, P.O. Box 2815, Sacramento, CA, 95814; and c) Director, SJVIJAPCD, 1990 East Gettysburg, Fresno, CA, 93726. [PSD SJ 89-02] Federally Enforceable Through Title V Permit

45. The owner or operator of a stationary gas turbine system shall maintain all records of required monitoring data and support information for inspection at any time for a period of five years. [District Rule 2520, 9.4.2] Federally Enforceable Through Title V Permit

These terms and conditions are part of the Facility-wide Permit to Operate. Facility Name: AERA ENERGY LLC Location: HEAVY OIL WESTERN STATIONARY SOURCE,KERN COUNTY, CA 64547440.20 : My 31 2015 11.25AI - MEMO


PERMIT UNIT: S-1547- 151 -20 EXPIRATION DATE: 05/31/2016


EQUIPMENT DESCRIPTION: 21.45 MW GAS FIRED TURBINE ENGINE COGENERATION FACILITY #3 WITH GENERAL ELECTRIC MODEL LM2500 PE GAS TURBINE, UNFIRED WASTE HEAT RECOVERY STEAM GENERATOR EQUIPPED WITH SCR AND AMMONIA INJECTION, AND BYPASS STACK EQUIPPED WITH SCR AND AMMONIA INJECTION

PERMIT UNIT REQUIREMENTS 1. Fuel consumption shall not exceed 5,650 MMBtu/day of fuel gas. [District Rule 22011 Federally Enforceable Through

Title V Permit


3. Except during periods of gas turbine engine startup/shutdown and stack transition, emission rates (three-hour rolling average) shall not exceed any of the following: 0.0111 lb-N0x/MMBtu or 3 ppmv-NOx @ 15% 02, and 0.076 lb-CO/MMBtu or 200 ppmvd-00 @15% 02. [District Rule 4703, 5.1.2, 5.2 and District Rule 2201] Federally Enforceable Through Title V Permit

4. Except during periods of gas turbine engine startup/shutdown and stack transition, emission rates shall not exceed any of the following: 0.016 lb-PM10/MMBtu, 0.010 lb-S0x/MMBtu, or 0.008 lb-VOC/MMBtu. [District Rule 2201] Federally Enforceable Through Title V Permit

5. Maximum daily emission limitations (DEL) shall not exceed any of the following: 190.2 lb-N0x/day, 56.5 lb-S0x/day, 90.4 lb-PM10/day, 429.4 lb-CO/day, and 45.2 lb-VOC/day. [District Rule 2201] Federally Enforceable Through Title V Permit


7. Stack transitions shall comply with the following criteria for FIRSG Bypass Transition Period: the duration of time that the turbine's operation transitions between the heat recovery steam generator and bypass exhaust stack, when the selective catalytic reduction catalyst is not within the required temperature range or the required ammonia saturation level has not yet been achieved, the transition period not exceeding two hours, and NOx emissions not exceeding 15 ppmvd, corrected to 15% 02, averaged over 2 hours, and the applicable CO compliance limits not being exceeded. [District Rule 4703] Federally Enforceable Through Title V Permit

8. On days of gas turbine engine startup/shutdown and/or stack transition, permittee shall demonstrate compliance with NOx daily emission limitation by records of calculations using CEM data, fuel rate data, and daily hours of operation data. [District Rule 1080] Federally Enforceable Through Title V Permit

9. Permittee shall report the following emission exceedances to the District: NOx emission rate on a three-hour average, and DEL of NOx during days of gas turbine engine startup/shutdown. [District Rule 1080] Federally Enforceable Through Title V Permit



Facility Name: AERA ENERGY LLC Location: HEAVY OIL WESTERN STATIONARY SOURCE,KERN COUNTY, CA 6-1547-151-20: Me, 31 2016 11 20W — EDGEHILR


11. The results of each source test shall be submitted to the District within 60 days thereafter. [District Rule 1081] Federally Enforceable Through Title V Permit



14. Permittee shall comply in full with Rule 4001 (New Source Performance Standards) requirements, including notification, recordkeeping and monitoring requirements. [District Rule 40011 Federally Enforceable Through Title V Permit


16. The owner or operator shall install, certify, maintain, operate and quality-assure a system which continuously measures and records the exhaust gas oxides of nitrogen, carbon monoxide, and oxygen or carbon dioxide. [District Rule 1080, 4.0,40 CFR 60.334(b), District Rule 4703, 6.2.1, & PSD SJ 85-03] Federally Enforceable Through Title V Permit

17. The CEMS shall complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15-minute period or shall meet equivalent specifications established by mutual agreement of the District, the ARB and the EPA. [District Rule 40 CFR 60.334(b)(2) and District Rule 1080, 6.4] Federally Enforceable Through Title V Permit

18. The continuous emissions monitoring system shall meet the performance specification requirements in 40 CFR 60, Appendix B; and 40 CFR 51, Appendix P, or shall meet equivalent specifications established by mutual agreement of the District, the ARB, and the EPA. [District Rule 1080, 6.5 & PSD Si 85-03] Federally Enforceable Through Title V Permit

19. Results of continuous emissions monitoring must be reduced according to the procedure established in 40 CFR, Part 51, Appendix P, paragraphs 5.0 through 5.3.3, or by other methods deemed equivalent by mutual agreement with the District, the ARB, and the EPA. [District Rule 1080, 7.2] Federally Enforceable Through Title V Permit

20. The owner or operator shall maintain CEMS records that contain the following: the occurrence and duration of any start-up, shutdown or malfunction, performance testing, evaluations, calibrations, checks, adjustments, maintenance, duration of any periods during which a continuous monitoring system or monitoring device is inoperative, and emission measurements. [40 CFR 60.7(b), District Rule 1080, 7.3 & PSD Si 85-03] Federally Enforceable Through Title V Permit

21. Permittee shall submit a CEMs written report for each calendar quarter to the District. The report is due on the 30th day following the end of the calendar quarter. Quarterly report shall include: time intervals, data and magnitude of excess emissions, nature and cause of excess (if known), corrective actions taken and preventive measures adopted;

averaging period used for data reporting corresponding to the averaging period specified in the emission test period used to determine compliance with an emission standard; applicable time and date of each period during which the CEM was inoperative (except for zero and span checks) and the nature of system repairs and adjustments; and a negative declaration when no excess emissions occurred. [40 CFR 60.334(j), (j)(5), District Rule 1080, 8.0 and District Rule 2520, 9.6.1& PSD SJ 85-03] Federally Enforceable Through Title V Permit

22. The CEMS shall be linked to a data logger which is compatible with the District's Data acquisition system. Upon notice by the District that the facility's CEM system is not providing polling data, the facility may continue to operate without providing automated data for a maximum of 30 days per calendar year provided the CEM data is sent to the District by a District-approved alternative method. [District Rule 2520, 9.4.2] Federally Enforceable Through Title V Permit


Facility Name: AEFtA ENERGY LLC Location: 1-1tAVY OIL WESTERN STATIONARY SOURCE,KERN COUNTY, CA 5-1547.151.20: MIS 31 2055 11:2104/1-E13051-111.5


23. Excess emissions shall be defined as any consecutive 2-hour period during which the average emissions of NOx and CO, as measured by continuous monitoring system exceeds the concentration emissions limits set forth for these pollutants. Any emissions in excess of the limits imposed by conditions in this permit, as measured by the continuous monitoring equipment constitutes a violation of District Rules and Regulations and shall be reported by the operator to the APCO within 96 hours. [District Rule 1080, 9.0 & PSD SJ 85-03] Federally Enforceable Through Title V Permit

24. Operator shall notify the District no later than eight hours after the detection of a breakdown of the CEM. The operator shall inform the District of the intent to shut down the CEM at least 24 hours prior to the event. [District Rule 1080, 10.0] Federally Enforceable Through Title V Permit

25. Fuel sulfur content for a fuel source shall be measured weekly. Test reports of measured fuel sulfur content shall be maintained. If measured sulfur content is less than 3.5 gr/100 scf for 8 consecutive weeks for a fuel source, then the testing frequency shall be semi-annually. If any semi-annual testing show fuel sulfur content exceeds 3.5 gr/100 scf, weekly testing shall resume and exceedance shall be reported to APCO. [40 CFR 60.334(b)(c) & District Rule 2520, 9.4.2] Federally Enforceable Through Title V Permit


27. The following test methods shall be used: NOx (ppmv) - EPA Methods 7E or 20, or ARB Method 100; CO (ppmv) - EPA Method 10 or 10B, or ARB Method 100; stack gas oxygen - EPA Method 3, 3A or 20, or ARB Method 100; and fuel gas sulfur content - ASTM D3246 or double GC for H2S and mercaptans, fuel gas hhv - ASTM D1826 or D1945 in conjunction with ASTM D3588. [40 CFR 60.335(b) and District Rules 1081, 4703, & PSD SJ 85-03] Federally Enforceable Through Title V Permit


29. Performance testing shall be witnessed or authorized District personnel. Test results must be submitted to the District within 60 day of performance testing. [District Rule 1081, 7.2, 7.3] Federally Enforceable Through Title V Permit

30. Daily records of NOx and CO emission calculations during days of startup/shutdown or stack transition shall be maintained and such records shall be made readily available for District inspection upon request. [District Rule 2520, 9.4.21 Federally Enforceable Through Title V Permit

31. CO emissions shall not exceed (lbs/hr) (three-hour average) = 38-(0.2)*(ambient air temperature in oFahrenheit) (not to exceed 30 lbs/hr) and (ppmv) = 1.86*(lbs/hr) @ 15% 02 (not to exceed 55.8 ppmv). [PSD SJ 85-03] Federally Enforceable Through Title V Permit

32. Perrnittee shall operate and maintain a continuous monitoring system to measure the ambient air temperature. [PSD SJ 85-03] Federally Enforceable Through Title V Permit

33. Pennittee shall operate and maintain a water injection system and instrumentation to continuously monitor and record levels of consumption of fuel and water. [PSD Si 85-03] Federally Enforceable Through Title V Permit

34. EPA Regional Administrator shall be notified by telephone within 48 hours following any failure of air pollution control equipment, process equipment, or of a process to operate in a normal manner which results in an increase in emissions above any allowable PSD emissions limits. [PSD St 85-03] Federally Enforceable Through Title V Permit

35. All equipment, facilities, or systems installed or used to achieve compliance with the terms and conditions of this permit shall at all times be maintained in good working order and be operated as efficiently as possible so as to minimize air pollutant emissions. [PSD Si 89-02] Federally Enforceable Through Title V Permit

36. All correspondence as required by this permit shall be forwarded to: a) Director, Air Management Division, Compliance Section (Attn: A-3-3), EPA Region IX, 75 Hawthorne Street, San Francisco, CA, 94105; b) Chief, Stationary Source Control Division, California Air Resource Board, P.O. Box 2815, Sacramento, CA, 95814; and c) Director, SJVUAPCD, 1990 East Gettysburg, Fresno, CA, 93726. [PSD SJ 89-02] Federally Enforceable Through Title V Permit



Facility Name: AERA ENERGY LLC Location: HEAVY OIL WESTERN STATIONARY SOURCE,KERN COUNTY, CA 0-1547.151.20: Mu 31 2016 11111AM- EDGEMILR


38. The permittee shall maintain records of the daily calculated ammonia slip measurements. [District Rules 4102 and 22011 Federally Enforceable Through Title V Permit

39. The operator shall monitor the ammonia injection rate that was established at the time of startup emission testing during CEM breakdowns to demonstrate NOx emission compliance. [District Rule 4703, 6.2.5] Federally Enforceable Through Title V Permit

40. Permittee shall maintain records of the following: 1) the occurrence and duration of any start-up, shutdown, or malfunction in the operation of the permit unit; 2) performance testing, evaluations, calibrations, checks, adjustments, and maintenance of CEMS; 3) emission measurements and 4) all records or required monitoring data and support information. All records shall be maintained for a period of five years and available for District inspection upon request. [District Rules 1080, 7.3, 2520, 9.4.2 and 40 CFR 60.7(b)] Federally Enforceable Through Title V Permit


42. Gas turbine engine shall be fired exclusively on PUC-regulated or FERC-regulated natural gas or natural gas with sulfur content no greater than 0.8% by weight. [40 CFR 60.3331 Federally Enforceable Through Title V Permit

43. The owner or operator of any existing stationary gas turbine system (unless exempted because all turbines are under ownership or control and have NOx and CO emissions limits which are shown on the current Permit to Operate and which do not exceed the applicable Compliance Limits in Section 5.0) shall submit to the APCO for approval, an emissions control plan of all actions. The control plan shall include a schedule of increments of progress that will be taken to comply with the requirements of the applicable NOx Compliance Limit in Section 5.0 and Compliance Schedule in Section 7.0 of District Rule 4703 (as amended 9/20/07). [District Rule 4703, 6.1.51 Federally Enforceable Through Title V Permit


These terms and conditions are part of the Facility-wide Permit to Operate. Facility Name: AERA ENERGY LLC Location: HEAVY OIL WESTERN STATIONARY SOURCE : KERN COUNTY, CA 3.1517.151-20: Mw312015 1125AM - EDGEFOIR


ATTACHMENT II Manufacturer's Information of PEMs Software

12

ATTACHMENT A TO STATEMENT OF WORK 001 AERA ENERGY — BAKERSFIELD, CA

Pavilion8 Software CEM® Installation

1 Rockwell Scope

Provide Pavilion8 Software Continuous Emissions Monitor (Pavilion8 Software CEM) application components as described below for the following sources, emissions and fuels:

Sources Emissions Fuels

3 GE LM2500 Combined Cycle

NOx ppmvd, CO ppmvd, 02 S, and NH3ppmvd

Natural Gas

The appl'cations will meet certain requirements of US EPA Performance Specification 16 for PEMS and 40 CFR Part 60 Subpart GG as of the effective date of this Statement of Work 001,

1.1 Application Features and Capabilities

The applications will have the following features and capabilities:

1. Software CEMapplication components:

1.1. Perform gross error detection on measurements required by the application that are read by the Aera Energy control system to determine if data is available, within expected ranges and not returning static (flat-lined) values and set status of affected inputs as bad if found to be in error;

1.2. If feasible and allowed by Aera Energy's regulatory authority, reconstruct required input measurements that fail gross error detection (up to a maximum of one (1) sensor reconstructions) using Rockwell's sensor reconstruction methodology;

1.3. Perform unit down identification by comparing key measurements such as fuel flow and excess 02 to threshhold values provided by Aera Energy to determine if the emissions source is running and generating emissions. If the source is determined to be down, set unit status to unit down and set in-scope emissions to zero or other appropriate value;

1.4. Calculate in-scope emissions from available process measurements while running inside the operating range tested during Software CEMapplication development. For periods when one or more required process measurement falls outside the tested operating envelope, set the Software CEMapplication status to monitor down;

1.5. Convert and correct emissions to the engineering units and standard conditions listed above; 1.6. Write calculated emissions and unit and application status information to Aera Energy's control system or data

historian on a periodic basis (assumed to be once per minute); 1.7. If uncompressed input measurements are available via OPC-HDA on a once-per-minute basis in a supported

data historian, allow for the re-calculation of past emissions. The ease of use of resulting information is limited by the type and integration of Aera Energy's emissions record-keeping and reporting system;

1.8. Configure approved client software web service (SOAP) access to calculated emissions and status information stored in cache;

ROCKWELL AUTOMATION, INC. Page 2 1/3012015 Confidential and Proprietary Information 14-00059

1.9. Calculate and display the following key performance indicators in real-time: 1.9.1. In-scope emissions, and 1.9.2. Software CEMapplication diagnostic information;

2. Display process information and performance of the Pavilion8 Software CEM applications through the Pavilion8 console website. The Pavition8 console can be accessed by authorized users that have access to the Pavilion8 server on the Aera Energy network;

3. Interface with existing Aera Energy Wonderware InSQL process control system via OPC-liDA to read current process measurements and write calculated emissions when the operator has the Pavilion8 Software CEM applications online;

4. Manage interface status and alarm local operator if communication or network issues prevent normal operation of the Pavilion8 Software GEM application;

1.2 Services

The services to be provided by Rockwell are as follows:

1. Development of the project plan, application functional specification(s), lower-level controls functional specification and design of experiments for required data collection;

2. Evaluation of existing Aera Energy instrumentation and control infrastructure and recommendations of modifications required to support the applications objectives;

3. Procurement of the required weather station for ambient temperature and absolute humidity measurements; 4. Development of Pavilion8 Software CEM application components for the units as described above while operating

within the ranges observed during step testing; 5. Development of Pavilion8 console views to provide visibility, operation and management of the Pavilion8 Software

GEM applications; 6. Systems integration testing of the Aera Energy Wonderware InSQL process control system, Pavilion8 web console,

other required logic and calculations and Pavilion8 Software CEM applications; and 7. Informal training of customer engineering personnel on the use and support of Pavilion8 Software CEM application

components, to be provided ad-hoc during normal onsite application development and commissioning activities.

1.3 Deliverables

The deliverables to be provided by Rockwell are as follows:

1. A project plan to be agreed with Aera Energy prior to beginning work on other deliverables; 2. A functional specification describing the site-specific functionality to be agreed with Aera Energy prior to application

development; 3. A lower-level controls functional specification describing interactions of the Pavilion8 Software CEM application

components with the existing Aera Energy Wonderware InSQL process control system(s) and required modifications to support normal operation;

4. Installed Rockwell software required to support the applications' objectives; 5. Weather station for ambient temperature and absolute humidity measurements (installation not included); 6. Application configurations for Pavilion8 Software GEM application components to support the features and

capabilities described above for in-scope emissions and fuels observed during plant testing; 7. An as-built document describing the Pavilion8 Software GEM applications; and 8. A site guide describing site-specific administrative and end-user procedures.

ROCKWELL AUTOMATION, INC. Page 3 1/30/2015 Confidential and Proprietary Information 14-00059

Varket and Industry Leadership Rockwell Automation was first-to-

market with the introduction of the

patented Software CEM in 1992 and is

an example of its commitment to

innovation. With more than 270

installations, each requiring yearly

certification, Software CEM has

achieved a track record of 100%

compliance. Rockwell Automation

maintains a leadership position in

mandated emissions monitoring with

unparalleled experience, knowledge

and value-based solutions.

The Rockwell Automation engineers

and technical staff have an industry

recognized reputation for meeting

objectives on-time and helping

companies minimize costs in environ-

mental compliance monitoring,

record-keeping and reporting.

Software Solution to a Hardware Challenge The Rockwell Automation Software CEM is a patented,

model-based, Predictive Emissions Monitoring System

(PEMS) that provides a certifiable, cost effective solution

as an alternative to hardware based Continuous

Emissions Monitoring Systems ((EMS). Powered by

the Pavilion8* software platform, Software (EM

provides a highly reliable emissions monitoring

solution to meet or surpass regulatory requirements

world-wide. Software CEM utilizes powerful analytic

models of the emissions source with real-time sensor

validation to provide predictive emission values

with unparalleled accuracy.

Software CEM: A Model-based Approach

Software (EM utilizes the Pavilion8 Model Analytic

Engine to provide highly accurate measurements of

NOR , CO, CO2 , green house gas and other emissions as

an alternative to costly hardware based CEMS. The

Software (EM system continuously monitors emissions

by means of an online model using historical and real-time

source data. The Rockwell Automation hybrid modeling

technology incorporates nonlinear empirical models as well as first principles knowledge to provide the most

accurate emissions prediction available in the compliance

industry. They are executed online to provide real-time predictions of emissions from a wide range of

sources and fuels. These composite models

incorporate the effects of operating and ambient

conditions on emissions to provide a robust

compliance monitoring system for years to come.

The Software CEM is a dynamic system that predicts

emissions even in the extreme operating ranges of

the unit. It can be used for a wide range of different unit

operations including boilers, gas turbines, furnaces,

reciprocating engines , dryers, heaters, regenerative and

conventional thermal oxidizers.

Sensor Validation for Unsurpassed

Accuracy and Reliability

Achieving the regulatory agency-mandated up-time

with a PEMS for demonstration of continuous compliance

requires the ability to continue to operate in the event of

sensor failure.This requires a methodology for detecting

sensor failures and, if possible, compensating for those

failures. This function is easily achieved with the Software

(EM patented sensor validation modeling capabilities.

This capability includes a very accurate model of all of the

sensors as a function of other sensors of the source

operations. For example, in a boiler, the fuel flow, air flow

and steam flow are highly interdependent. Similarly,

modern plants typically have redundant temperature, flow

and pressure measurements, Thus it is possible to estimate

any one of these readings as a function of the other

sensors. In a similar fashion, all sensor values can be

validated by comparing raw values to predicted values as

a function of the "peer" sensor data. A raw sensor value

that is suspect in relation to its peer readings can be irientifiPrl. Software. CEM uses the sensor validation model as a qualifier to detect sensor failures and to set

appropriate alarms. The patented P5-16 compliant

reconstruction routine facilitates continued accurate

prediction of sensor values while the failed sensor is repaired or replaced. This allows for the uninterrupted

reporting of emissions data.

Information Flow

Hen-tirne thsuahinnion

itinl-dore Fmkronnlin Manngnawn4 Reports tOplionan

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171

Cost Effective Monitoring &Compliance Features • Patatod, ntodal-basod. softwase system • Slandardned, software appeationdeveloponent and

doptementnaolhadoingY

ganef% • toperstostaation and maintenance oasts

• • Highef raliatarny

Lawrenarely risks

• Aistordeplornont nuking compfunceand ROI • Not:Untold snatadal cast: associated with operations

and =inure=

Highly Accurate and Reliable Emissions Monitoring and Reporting Features

Patenand Sensor VaidaDon wain:anima Mem • PnwedundantyfOr faCOndtbding irsaid or missing data • Pavilong Model Analytic Engine

Benefrts • Quality assurance of anput dala reduces compliance mondating

and reporting errors • Gast, act:mats faun hwfalg and reduces meantime to rap* PAM) • Ma:Indus maim wane winds eranindlas downdFne penattifis • Moans operational conndencerinh naspart

missions perfonnano

Environmental and Industrial Expertise Features • inovennevairinniventesireu project impleinernalion and

maintanannmalhodologles fineness emission gams and typas • toot Mtn natiorel and global ingulataoy ovations . Opium!. Road-tine Elwin:emeriti Managanontoacorlioaspeg

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Benefits • Fasterdeplownent teducon oasts and dem Gladtanzand

=stain annnlianao • Reduces MOO tisk - Inninbescomphance moricaringoncord-banping

and wonting costs

Pavilion 8 Pavilion8 is a modular software platform and the foundation

for the Rockwell Automation Information Software & Process Business industry-specific solutions. Leveraging a powerful modeling engine at its core, Pavilion8 includes modules to control, analyze, monitor, visualize, warehouse and integrate that are combined into high-value applications. The Pavilion8 platform is implemented in J2EE and based on a modern Service-Oriented Architecture (S0A). The platform's scalability, flexibility and ease of integration with existing business and plant infrastructure provide a lower total cost of ownership than alternative technologies.

About Rockwell Automation Rockwell Automation Inc. (NYSE: ROK) is a leading global

provider of industrial automation power, control and

information solutions that help manufacturers achieve a

competitive advantage for their businesses. The company brings

together leading global brands in industrial automation that

include Allen-Bradley ° controls and services and Rockwell

Software factory management software. Headquartered in

Milwaukee, Wis., the company employs about 20,000 people

serving customers in more than 80 countries.

Pavilions and Software CEM are trademarks of Rockwell Automation Inc. All other trademarks or registered trademarks are the property of their respective owners.

www.rockwellautomatlon.com

Power, Control lusd Information Solmions Headquarters

Americas: Rockwell Automation, 1201 South Second Street. Milwaukee, WI 532042496 USA, TeL (1) 414.382.2000. Fax: (1) 414.382.4444 Europe/Middle East/Africa: Rockwell Automation NV. Pegasus Park, De Kleetlaan 12a, 1831 Diegem, Bdgium, Tel: (32) 2 663 0600, Fax: (32) 2 663 0640 Asia Pacific: Rockwell Automation. Level 14, Core F. Cyberport 3.100 Cyberpott Road, Hong Kong, Tel: (852) 2887 4788, Fax: (852) 2508 1846

Publication RSSREN-APU018-EN-P - January 2011

Copyright 02011 Rockwell Automation, Inc. All Rights Reserved, Printed In USA.


ATTACHMENT III Emissions Profiles

13

SJVUAPCD SOUTHERN

0

Application Emissions 4/1/15 8:44 am

Permit #: S-1547-148-22 Last Updated

Facility: AERA ENERGY LLC 03/31/2015 EDGEHILR

Equipment Pre-Baselined: NO NOX

SOX

PM10

VOC Potential to Emit (Ib/Yr): 69423.0 20623.0 32996.0 156733.0 16498.0

Daily Emis. Limit (lb/Day) 190.2 56.5 90.4 429.4 45.2

Quarterly Net Emissions Change (lb/Qtr)

Q1: 0.0 0.0 0.0 0.0 0.0 Q2: 0.0 0.0 0.0 0.0 0.0 Q3: 0.0 0.0 0.0 0.0 0.0 Q4: 0.0 0.0 0.0 0.0 0.0

Check if offsets are triggered but exemption applies N N N N N

Offset Ratio

Quarterly Offset Amounts (lb/Qtr .) Q1: Q2: Q3: Q4:

SJVUAPCD

Application Emissions 4/1/15 SOUTHERN

8:44 am

Permit #: S-1547-149-21 Last Updated Facility: AERA ENERGY LLC 03/31/2015 EDGEHILR


SOX

PM1 0

CO

VOC Potential to Emit (lbNr): 69423.0 20623.0 32996.0 156733.0 16498.0



01: 0.0 0.0 0.0 0.0 0.0 Q2: 0.0 0.0 0.0 0.0 0.0 Q3: 0.0 0.0 0.0 0.0 0.0 Q4: 0.0 0.0 0.0 0.0 0.0

Check if offsets are triggered but exemption applies N N N N N

Offset Ratio

Quarterly Offset Amounts (lb/Qtr) 1: 2: Q3: Q4:

SJVUAPCD

Application Emissions

4/1/15 SOUTHERN

8:44 am

Permit #: S-1547-151-22 Last Updated

Facility: AERA ENERGY LLC 03/31/2015 EDGEHILR


SOX

PM10

CO

VOC

Potential to Emit (lb/Yr): 69423.0 20623.0 32996.0 156733.0 16498.0



Ql: 0.0 0.0 0.0 0.0 0.0 Q2: 0.0 0.0 0.0 0.0 0.0 03: 0.0 0.0 0.0 0.0 0.0 Q4: 0.0 0.0 0.0 0.0 0.0

Check if offsets are triggered but exemption applies

N N N N N

Offset Ratio

Quarterly Offset Amounts (lb/Qtr) Q1: Q2: Q3: 04:


ATTACHMENT IV Title V Compliance Certification Form

14

San Joaquin Valley Unified Air Pollution Control District

TITLE V COMPLIANCE CERTIFICATION FORM Replace CEM with PEM Cogen 32 (S-1547-148, -149, -151)

I. TYPE OF PERMIT ACTION (Check appropriate box)

[X] SIGNIFICANT PERMIT MODIFICATION

[ 1 ADMINISTRATIVE [ ] MINOR PERMIT MODIFICATION

AMENDMENT

COMPANY NAME: Aera Energy LLC FACILITY ID: S -1547 I. Type of Organization:[ X ] Corporation [ 1 Sole Ownership [ ] Government [ ] Partnership [ ] Utility

2. Owner's Name: Aera Energy LLC

3. Agent to the Owner: N/A

II. CONWLIANCE CERTIFICATION (Read each statement carefully and initial each circle for confirmation):

Based on information and belief formed after reasonable inquiry, the emission units identified in this application will continue to comply with the applicable federal requirement(s) which the emission units are in compliance.

Based on information and belief formed after reasonable inquiry, the emission units identified in this application ill comply with applicable federal requirement(s) that will become effective during the permit term, on a timely

Usis.

porrected information will be provided to the District when I become aware that incorrect or incomplete formation has been submitted.

Based on information and belief formed after reasonable inquiry, information and statements in the submitted application package, including all accompanying reports, and required certifications are true accurate and complete.

I declare, under penalty of perjury under the laws of the state of California, that the forgoing is correct and true:

Date Signature of Respon le Official

E. J. Gonzalez

Name of Responsible Official (please print)

Process Supervisor Title of Responsible Official (please print)


ATTACHMENT V Draft ATCs

15

Seyed Sadredin, EisectIthini e PCO


AUTHORITY TO CONSTRUCT PERMIT NO: S-1547-148-22

LEGAL OWNER OR OPERATOR: AERA ENERGY LLC MAILING ADDRESS: PO BOX 11164

BAKERSFIELD, CA 93389-1164

LOCATION: HEAVY OIL WESTERN STATIONARY SOURCE KERN COUNTY, CA


EQUIPMENT DESCRIPTION: MODIFICATION OF 21.45 MW GAS FIRED TURBINE ENGINE COGENERATION FACILITY #1 WITH GENERAL ELECTRIC MODEL LM2500 PE GAS TURBINE AND UNFIRED WASTE HEAT RECOVERY STEAM GENERATOR, AND BYPASS STACK EQUIPPED WITH SCR AND AMMONIA INJECTION. REPLACE EXISTING NOX, CO AND 02 CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) WITH A NEW ROCKWELL AUTOMATION PREDICTIVE EMISSION MONITORING SYSTEM (PEMS)

CONDITIONS 1. {1830} This Authority to Construct serves as a written certificate of conformity with the procedural requirements of 40

CFR 70.7 and 70.8 and with the compliance requirements of 40 CFR 70.6(c). [District Rule 2201] Federally Enforceable Through Title V Permit

2. {1831} Prior to operating with modifications authorized by this Authority to Construct, the facility shall submit an application to modify the Title V permit with an administrative amendment in accordance with District Rule 2520 Section 5.3.4. [District Rule 2520, 5.3.4] Federally Enforceable Through Title V Permit

3. The owner or operator shall install, certify, maintain, operate and quality-assure a Predictive Emission Monitoring System (PEMS) which continuously predicts and records the exhaust gas NOX, CO and 02 concentrations. Predictive emissions monitor(s) shall be capable of predicting emissions during normal operating conditions, and during startups and shutdowns provided the PEMS passes the relative accuracy requirement for startups and shutdowns specified herein. If relative accuracy of PEMS cannot be demonstrated during startup conditions, PEMS results during startup and shutdown events shall be replaced with startup emission rates obtained from source testing to determine compliance with emission limits contained in this permit. [District Rules 2201 and 4703 and 40 CFR 60.334(b)] Federally Enforceable Through Title V Permit

CONDITIONS CONTINUE ON NEXT PAGE

YOU MUST NOTIFY THE DISTRICT COMPLIANCE DIVISION AT (651) 392-5500 WHEN CONSTRUCTION IS COMPLETED AND PRIOR TO OPERATING THE EQUIPMENT OR MODIFICATIONS AUTHORIZED BY THIS AUTHORITY TO CONSTRUCT. This is NOT a PERMIT TO OPERATE. Approval or denial of a PERMIT TO OPERATE will be made after an inspection to verify that the equipment has been constructed in accordance with the approved plans, specifications and conditions of this Authority to Construct, and to determine If the equipment can be operated in compliance with all Rules and Regulations of the San Joaquin Valley Unified Air Pollution Control District. Unless construction has commenced pursuant to Rule 2050, this Authority to Construct shall expire and application shall be Cancelled two years from the date of issuance. The applicant is responsible for complying with all laws, ordinances and regulations oflLeter governmental agencies which may pertain to the above equipment.

ISSU

Amaud MarjolleteBire-ctor of Permit Services S.1547-148-22: oNu 24 XIS 1_123244 — E00ET111.17 • Jowl IsNymbon NOT Requved

Southern Regional Office • 34946 Flyover Court • Bakersfield, CA 93308 • (661) 392-5500 • Fax (661) 392-5585

Conditions for S-1547-148-22 (continued) Page 2 of 5

4. Prior to disconnecting the CEMs, the PEMS must pass a Relative Accuracy (RA) Test to be acceptable for use in demonstrating compliance with this permit. [District Rules 2201 and 4703 and 40 CFR 60.334(b)] Federally Enforceable Through Title V Permit

5. If PEMS fails to pass a quarterly RAA or yearly RATA test, or if changes are made that could result in a significant change in the emissions rate (e.g. turbine aging, process modification, new process operating modes, or changes to emission controls) the PEMS must be recertified using the test procedures in Section 8.1 of PS16. [District Rules 2201 and 4703 and 40 CFR 60.334(b)] Federally Enforceable Through Title V Permit

6. Source shall provide a PEMS protocol, specific for the source, which is reviewed and approved by the District. [District Rules 2201 and 4703 and 40 CFR 60.334(b) Federally Enforceable Through Title V Permit

7. Source shall maintain a PEMS plan based on RATA testing and to comply with all established operating parameters. [District Rules 2201 and 4703 and 40 CFR 60.334(b)] Federally Enforceable Through Title V Permit

8. Operating envelope must be established to ensure that PEMS is providing accurate data. [District Rules 2201 and 4703 and 40 CFR 60.334(b)] Federally Enforceable Through Title V Permit

9. The NOx, CO, and 02 PEMS shall meet the requirements in 40 CFR 60, Performance Specifications 16 (PS-16), or shall meet equivalent specifications established by mutual agreement of the District, the ARB, and the EPA. [40 CFR 60.334(b)(1) and, District Rule 1080, 6.3, 6.5, 6.6, & 7.2] Federally Enforceable Through Title V Permit

10. The PEMS shall be linked to a data logger which is compatible with the District's Data acquisition system. Upon notice by the District that the facility's PEMS system is not providing polling data, the facility may continue to operate without providing automated data for a maximum of 30 days per calendar year provided the PEMS data is sent to the District by a District-approved alternative method. [District Rule 1080, 7.1] Federally Enforceable Through Title V Permit

11. Fuel consumption shall not exceed 5,650 MMBtu/day of fuel gas. [District Rule 22011 Federally Enforceable Through Title V Permit

12. HHV and LHV of the fuel shall be determined using ASTM D3588, ASTM 1826,01 ASTM 19451. [District Rule 4703, 6.4.5] Federally Enforceable Through Title V Permit

13. NOx emissions shall not exceed 75 ppmv @ 15% 02 (one-hour rolling average in accordance with 40 CFR 60.13(h)). [40 CFR 60.332(b)] Federally Enforceable Through Title V Permit

14. This is a BARCT Offset emission unit. For the purposes of Actual Emission Reduction calculations only, this unit shall be considered to have NOx emissions of 20.6 ppmv @ 15% oxygen. [District Rule 45011 Federally Enforceable Through Title V Permit

15. Except during startup, shutdown, and stack transitions, emission rates (three-hour rolling average) shall not exceed any of the following: NOx: 0.011 lb/MMBtu or 3 ppmv @ 15% 02; and CO: 0.076 lb/MMBtu or 33.9 ppmvd @15% 02. [District Rule 4703, 5.1, 5.2 and 7.2] Federally Enforceable Through Title V Permit

16. Emission rates from the gas turbine engine shall not exceed any of the following: 0.016 lb-PM10/MMBtu, 0.010 lb-S0x/MMBtu, or 0.008 lb-VOC/MMBtu. [District Rule 22011 Federally Enforceable Through Title V Permit

17. On days of gas turbine engine startup/shutdown, permittee shall demonstrate compliance with NOx daily emission limitation by records of calculations using PEMS data, fuel rate data, and daily hours of operation data. [District Rule 1080] Federally Enforceable Through Title V Permit

18. Maximum daily emission limitations (DEL) shall not exceed any of the following: 190.2 lb-N0x/day; 56.5 lb-S0x/clay, 90.4 lb-PM10/day, 429.4 lb-CO/day, or 45.2 lb-VOC/day. [District Rule 2201] Federally Enforceable Through Title V Permit

19. The ammonia injection rate shall not exceed 25 lb/hr. [District Rules 2201 and 4102] Federally Enforceable Through Title V Permit

20. The operator shall monitor the ammonia injection rate duringy S breakdowns to demonstrate NOx emission compliance. [District Rule 4703, 6.2.5] Federally Enfcry0 ugh Title V Permit

CONDITIONS/CONTINUE ON NEXT PAGE 5-1547.145-22: AF 24 2015 1:03M- EOCE1111.17


21. Startup shall be defined as the period of time, not to exceed two hours, during which a unit is brought from a shutdown status to its operating temperature and pressure, including the time required by the unit's emission control system to reach full operation. [District Rule 4703, 3.29 and 5.31 Federally Enforceable Through Title V Permit

22. Shutdown shall be defined as the period of time, not to exceed two hours, during which a unit is taken from an operational to a non-operational status by allowing it to cool down from its operating temperature to ambient temperature as the fuel supply to the unit is completely turned off. [District Rule 4703, 3.26 and 5.3] Federally Enforceable Through Title V Permit

23. Stack transitions shall comply with the following criteria for HRSG Bypass Transition Period: the duration of time that the turbine's operation transitions between the heat recovery steam generator and bypass exhaust stack, when the selective catalytic reduction catalyst is not within the required temperature range or the required ammonia saturation level has not yet been achieved, the transition period not exceeding two hours, and NOx emissions not exceeding 15 ppmvd, corrected to 15% 02, averaged over 2 hours, and the applicable CO compliance limits not being exceeded. [District Rule 47031 Federally Enforceable Through Title V Permit

24. Permittee shall report the following emission exceedances to the District: NOx emission rate on a three-hour average and daily NOx emissions during days of gas turbine engine startup/shutdown or stack transition. [District Rule 1080] Federally Enforceable Through Title V Permit


26. The owner or operator shall certify, maintain, operate and quality-assure a system which continuously measures and records the exhaust gas oxides of nitrogen, carbon monoxide, and oxygen or carbon dioxide. [District Rule 1080, 4.0, 40 CFR 60.334(b), District Rule 4703, 6.2.1, & PSD SJ 85-03] Federally Enforceable Through Title V Permit

27, The PEMS shall complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15-minute period or shall meet equivalent specifications established by mutual agreement of the District, the ARB and the EPA. [District Rule 40 CFR 60.334(b)(2) and District Rule 1080, 6.4] Federally Enforceable Through Title V Permit

28. When operating the continuous emissions monitoring system (CEMs), it shall meet the performance specification requirements in 40 CFR 60, Appendix B; and 40 CFR 51, Appendix P, or shall meet equivalent specifications established by mutual agreement of the District, the ARB, and the EPA. [District Rule 1080, 6.5 & PSD SJ 85-03] Federally Enforceable Through Title V Permit

29. When operating the continuous emissions monitoring system (CEMs), results must be reduced according to the procedure established in 40 CFR, Part 51, Appendix P, paragraphs 5.0 through 5.3.3, or by other methods deemed equivalent by mutual agreement with the District, the ARB, and the EPA. [District Rule 1080, 7.2] Federally Enforceable Through Title V Permit

30. The owner or operator shall maintain PEMS records that contain the following: the occurrence and duration of any start-up, shutdown or malfunction, performance testing, evaluations, calibrations, checks, adjustments, maintenance, duration of any periods during which a continuous monitoring system or monitoring device is inoperative, and emission measurements. [40 CFR 60.7(b), District Rule 1080, 7.3 & PSD SJ 85-03] Federally Enforceable Through Title V Permit

31. Permittee shall submit reports of excess emissions for all periods of unit operation, including startup, shutdown, and malfunction in accordance with 40 CFR 60.344(j). [40 CFR 60.334(j)] Federally Enforceable Through Title V Permit

32. Permittee shall submit a PEMS written report for each calendar quarter to the District. The report is due on the 30th day following the end of the calendar quarter. Quarterly report shall include: time intervals, data and magnitude of excess emissions, nature and cause of excess (if known), corrective actions taken and preventive measures adopted; averaging period used for data reporting corresponding to the averaging period specified in the emission test period used to determine compliance with an emission standard; applicable time and date of each period during which the

PEMS was inoperative (except for zero and span check ) ture of system repairs and adjustments; and a check

declaration when no excess emissicK c'ett ,7 q. 60.334(j), (j)(5), District Rule 1080, 8.0 and District Rule 2520, 9.6.1& PSD SJ 85-03] Federa113 lk g itle V Permit

C0NDITIO11SMNI1NUE ON NEXT PAGE 8-15/7-118 22: Apr 242015 I 03PM- EDGE1111.11

CONDIT1 NUB ON NEXT PAGE

1. (2271) The owner or operator of a stationary gas turbine and support information for inspection at anytirtle -Nrqil Enforceable Through Title V Permit

all maintain all records of required monitoring data we years. [District Rule 2520, 9.4.2] Federally



34. Operator shall notify the District no later than eight hours after the detection of a breakdown of the PEMS. The operator shall inform the District of the intent to shut down the PEMS at least 24 hours prior to the event. [District Rule 1080, 10.01 Federally Enforceable Through Title V Permit


36. If the turbine is not fired on PUC-regulated or FERC-regulated natural gas, the sulfur content of the fuel shall be tested in accordance with 40 CFR 60.344(i). [40 CFR 60.344(i)] Federally Enforceable Through Title V Permit

37. Performance testing to measure exhaust gas NOx and CO concentrations shall be conducted annually. [40 CFR 60.335(b), District Rule 4703, 6.3 & PSD SJ 85-03] Federally Enforceable Through Title V Permit

38. The following test methods shall be used: NOx (ppmv) , EPA Methods 7E or 20, or ARE Method 100; CO (ppmv) - EPA Method 10 or 10B, or ARB Method 100; stack gas oxygen - EPA Method 3, 3A or 20, or ARB Method 100; and fuel gas sulfur content - ASTM D3246, fuel gas hhv - ASTM D1826 or D1945 in conjunction with A STM D3588. [40 CFR 60.335 and District Rules 1081, 4703, 6.4 & PSD SJ 85-03] Federally Enforceable Through Title V Permit


40. Performance testing shall be witnessed or authorized by District personnel. Test results must be submitted to the District within 60 day of performance testing. [District Rule 1081, 7.2, 7.3] Federally Enforceable Through Title V Permit

41. Daily records of NOx and CO emission calculations during days of startup/shutdown or stack transitions shall be maintained and such records shall be made readily available for District inspection upon request. [District Rule 2520, 9.4.2] Federally Enforceable Through Title V Permit

42. CO emissions shall not exceed (lbs/hr) (three-hour average) = 38-(0.2)*(ambient air temperature in eFahrenheit) (not to exceed 30 lbs/hr) and (ppmv) = 1.86*(lbs/hr) @ 15% 02 (not to exceed 55.8 ppmv). [PSD SJ 85-03] Federally Enforceable Through Title V Permit



45. EPA Regional Administrator shall be notified by telephone within 48 hours following any failure of air pollution control equipment, process equipment, or of a process to operate in a normal manner which results in an increase in emissions above any allowable PSD emissions limits. [PSD Si 85-03] Federally Enforceable Through Title V Permit


47. All correspondence as required by this permit shall be forwarded to: a) Director, Air Management Division, Compliance Section (Attn: A-3-3), EPA Region IX, 75 Hawthorne Street, San Francisco, CA, 94105; b) Chief, Stationary Source Control Division, California Air Resource Board, P.O. Box 2815, Sacramento, CA, 95814; and c) Director, SJVUAPCD, 1990 East Gettysburg, Fresno, CA, 93726. [PSD Si 89-02] Federally Enforceable Through Title V Permit

8.1547-148-22. Apt 24 2015 1:03PM - EDGEHILI2


49. Permittee shall maintain records of the following: 1) the occurrence and duration of any start-up, shutdown, or malfunction in the operation of the permit unit; 2) performance testing, evaluations, calibrations, checks, adjustments, and maintenance of PEMS; and 3) emission measurements. [District Rules 1080, 7.3; 2520, 9.4.2; 4703, 6.2.8] Federally Enforceable Through Title V Permit

50. The owner or operator shall maintain a stationary gas turbine operating log that includes, on a daily basis, the actual local start-up and stop time, length and reason for stack transitions, total hours of operation, and quantity and heat input of fuel used. [District Rule 4703, 6.2.6] Federally Enforceable Through Title V Permit


S-1547.140-22 : Apt 24 2015 1.03PM - ECGEHILli

Seyed Sadredin, E PCO



ISSU





EQUIPMENT DESCRIPTION: MODIFICATION OF 21.45 MW GAS FIRED TURBINE ENGINE COGENERATION FACILITY #2 WITH GENERAL ELECTRIC MODEL LM2500 PE GAS TURBINE, UNFIRED WASTE HEAT RECOVERY STEAM GENERATOR EQUIPPED WITH SCR AND AMMONIA INJECTION, AND BYPASS STACK EQUIPPED WITH SCR AND AMMONIA INJECTION. REPLACE EXISTING NOX, CO AND 02 CONTINUOUS EMISSION MONITORING SYSTEM (GEMS) WITH A NEW ROCKWELL AUTOMATION PREDICTIVE EMISSION MONITORING SYSTEM (PEMS)

CONDITIONS 1. {1830} This Authority to Construct serves as a written certificate of conformity with the procedural requirements of 40

CFR 70.7 and 70.8 and with the compliance requirements of 40 CFR 70.6(c). [District Rule 2201] Federally Enforceable Through Title V Permit

2. {1831} Prior to operating with modifications authorized by this Authority to Construct, the facility shall submit an application to modify the Title V permit with an administrative amendment in accordance with District Rule 2520 Section 5.3.4. [District Rule 2520, 5.3.4] Federally Enforceable Through Title V Permit


CONDITIONS CONTINUE ON NEXT PAGE YOU MUST NOTIFY THE DISTRICT COMPLIANCE DIVISION AT (661) 392-5500 WHEN CONSTRUCTION IS COMPLETED AND PRIOR TO OPERATING THE EQUIPMENT OR MODIFICATIONS AUTHORIZED BY THIS AUTHORITY TO CONSTRUCT. This is NOT a PERMIT TO OPERATE. Approval or denial of a PERMIT TO OPERATE will be made after an inspection to verify that the equipment has been constructed in accordance with the approved plans, specifications and conditions of this Authority to Construct, and to determine if the equipment can be operated in compliance with all Rules and Regulations of the San Joaquin Valley Unified Air Pollution Control District. Unless construction has commenced pursuant to Rule 2050, this Authority to Construct shall expire and application shall be cancelled two years from the date of issuance. The applicant is responsible for complying with all laws, ordinances and regulations offtleter governmental agencies which may pertain to the above equipment.

Arnaud Marjolletrairector of Permit Services 8-1547-11901 . AP 242815 1 03PM— EOCEHILR Joint Inspection NOT Required


CONDITI NUE ON NEXT PAGE

1. On days of gas turbine engine startup/shutdown and/or stack t NOx daily emission limitation by records of calculati data. [District Rule 1080] Federally Enforqab3e1(70 cot

tion, permittee shall demonstrate compliance with S data, fuel rate data, and daily hours of operation

ermit


4. Prior to disconnecting the CEMs, the PEMS must pass a Relative Accuracy (RA) Test to be acceptable for use in demonstrating compliance with this permit. [District Rules 2201 and 4703 and 40 CFR 60.334(6)] Federally Enforceable Through Title V Permit

5. If PEMS fails to pass a quarterly RAA or yearly RATA test, or if changes are made that could result in a significant change in the emissions rate (e.g. turbine aging, process modification, new process operating modes, or changes to emission controls) the PEMS must be recertified using the test procedures in Section 8.1 of PS 16. [District Rules 2201 and 4703 and 40 CFR 60.334(b)] Federally Enforceable Through Title V Permit

6. Source shall provide a PEMS protocol, specific for the source, which is reviewed and approved by the District. [District Rules 2201 and 4703 and 40 CFR 60.334(b] Federally Enforceable Through Title V Permit


8. Operating envelope must be established to ensure that PEMS is providing accurate data. [District Rules 2201 and 4703 and 40 CFR 60.334(b)] Federally Enforceable Through Title V Permit

9. The NOx, CO, and 02 PEMS shall meet the requirements in 40 CFR 60, Performance Specifications 16 (PS-16), or shall meet equivalent specifications established by mutual agreement of the District, the ARB, and the EPA. [40 CFR 60.334(b)(1) and, District Rule 1080, 6.3, 6.5, 6.6, & 7.2] Federally Enforceable Through Title V Permit


11. Fuel consumption shall not exceed 5,650 MMBtu/day of fuel gas. [District Rule 2201] Federally Enforceable Through Title V Permit

12. HI-IV and LHV of the fuel shall be determined using ASTM D3588, ASTM 1826, OR ASTM 1945. [District Rule 4703, 6.4.5] Federally Enforceable Through Title V Permit

13. Except during periods of gas turbine engine startup/shutdown and stack transition, emission rates (three-hour rolling average) shall not exceed any of the following: 0.0111 lb-N0x/MMBtu or 3 ppmv-NOx @ 15% 02, and 0.076 lb-CO/MMBtu or 200 ppmvd-00 @15% 02. [District Rules 2201 and 4703, 5.1.2, 5.2] Federally Enforceable Through Title V Permit

14. Except during periods of gas turbine engine startup/shutdown and stack transition, emission rates shall not exceed any of the following: 0.016 lb-PM10/MMBtu, 0.010 lb-S0x/MMBtu, 0.008 lb-VOC/MMBtu. [District Rule 2201] Federally Enforceable Through Title V Permit

15. Maximum daily emission limitations (DEL) shall not exceed any of the following: 190.2 lb-N0x/day, 56.5 lb-S0x/day, 90.4 lb-PM10/day, 429.4 lb-CO/day, and 45.2 lb-VOC/day. [District Rule 2201] Federally Enforceable Through Title V Permit


17. Stack transitions shall comply with the following criteria for HRSG Bypass Transition Period: the duration of time that the turbines operation transitions between the heat recovery steam generator and bypass exhaust stack, when the selective catalytic reduction catalyst is not within the required temperature range or the required ammonia saturation level has not yet been achieved, the transition period not exceeding two hours, and NOx emissions not exceeding 15 ppmvd, corrected to 15% 02, averaged over 2 hours, and the applicable CO compliance limits not being exceeded. [District Rule 4703] Federally Enforceable Through Title V Permit

5-1W-145-21: A140 24 2015 1 . 03P1A - EDGE51151


19. Permittee shall report the following emission exceedances to the District: NOx emission rate on a three-hour average, and DEL of NOx during days of gas turbine engine startup/shutdown or stack transition. [District Rule 1080] Federally Enforceable Through Title V Permit

20. Compliance testing shall be conducted annually as required by the District-approved plan. [District Rule 10811 Federally Enforceable Through Title V Permit






26. The owner or operator shall install, certify, maintain, operate and quality-assure a system which continuously measures and records the exhaust gas oxides of nitrogen, carbon monoxide, and oxygen or carbon dioxide. [District Rule 1080, 4.0, 40 CFR 60.334(a), District Rule 4703, 6.2.1, & PSD Si 85-03] Federally Enforceable Through Title V Permit

27. The PEMS shall complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15-minute period or shall meet equivalent specifications established by mutual agreement of the District, the ARB and the EPA. [District Rule 40 CFR 60.334(b)(2) and District Rule 1080, 6.4] Federally Enforceable Through Title V Permit

28. When operating the continuous emissions monitoring system (CEMs), it shall meet the performance specification requirements in 40 CFR 60, Appendix B; and 40 CFR 51, Appendix P, or shall meet equivalent specifications established by mutual agreement of the District, the ARB, and the EPA. [District Rule 1080, 6.5 & PSD Si 85-03] Federally Enforceable Through Title V Permit



31. Permittee shall submit a PEMS written report for each calendar quarter to the District. The report is due on the 30th day following the end of the calendar quarter. Quarterly report shall include: time intervals, data and magnitude of excess emissions, nature and cause of excess (if known), corrective actions taken and preventive measures adopted; averaging period used for data reporting corresponding to the averaging period specified in the emission test period used to determine compliance with an emission standard; applicable time and date of each period during which the CEMS was inoperative (except for zero and span checks) and the nature of system repairs and adjustments; and a negative declaration when no excess emissions occurred. [40 CFR 60.334(j), District Rule 1080, 8.0 and District Rule 2520, 9.3.2 & PSD Si 85-03] Federally Enforceable Through Title V Permit

CONDITIONTSJOZWINUE ON NEXT PAGE 6-1547-149•21 Apr 24 2015 1:03755 - EDGEHILA



33. Operator shall notify the District no later than eight hours after the detection of a breakdown of the PEMS. The operator shall inform the District of the intent to shut down the PEMS at least 24 hours prior to the event. [District Rule 1080, 10.0] Federally Enforceable Through Title V Permit

34. The PEMS shall be linked to a data logger which is compatible with the District's Data acquisition system. Upon notice by the District that the facility's PEMS is not providing polling data, the facility may continue to operate without providing automated data for a maximum of 30 days per calendar year provided the PEMS data is sent to the District by a District-approved alternative method. [District Rule 2520, 9.3.2] Federally Enforceable Through Title V Permit

35. Fuel sulfur content for a fuel source shall be measured weekly. Test reports of measured fuel sulfur content shall be maintained. If measured sulfur content is less than 3.5 gr/100 scf for 8 consecutive weeks for a fuel source, then the testing frequency shall be semi-annually. If any semi-annual testing show fuel sulfur content exceeds 3.5 gr/100 scf, weekly testing shall resume and exceedance shall be reported to APCO. [40 CFR 60.334(h) & District Rule 2520, 9.3.2] Federally Enforceable Through Title V Permit

36. Performance testing to measure exhaust gas NOx and CO concentrations shall he conducted annually. [40 CFR 60.335(b), District Rule 4703, 6.3 & PSD SJ 85-03] Federally Enforceable Through Title V Permit

37. The following test methods shall be used: NOx (ppmv) - EPA Methods 7E or 20, or ARB Method 100; CO (ppmv) - EPA Method 10 or 10B, or ARB Method 100; stack gas oxygen - EPA Method 3, 3A or 20, or ARB Method 100; and fuel gas sulfur content - ASTM D3246 or double GC for H2S and mercaptans, fuel gas hhv - ASTM Dl 826 or D1945 in conjunction with ASTM D3588. [40 CFR 60.335 and District Rules 1081, 4703, & PSD SJ 85-031 Federally Enforceable Through Title V Permit

38. The District must be notified 30 days prior to any performance testing and a test plan shall be submitted for District approval 15 days prior to such testing. [District Rule 1081, 7.11 Federally Enforceable Through Title V Permit

39. Performance testing shall be witnessed or authorized District by personnel. Test results must be submitted to the District within 60 day of performance testing. [District Rule 1081, 7.2 & 7.3] Federally Enforceable Through Title V Permit

40. Daily records of NOx and CO emission calculations during days of startup/shutdown or stack transition shall be maintained and such records shall be made readily available for District inspection upon request. [District Rule 2520, 9.3.21 Federally Enforceable Through Title V Permit



43. The operator shall monitor the ammonia injection rate that was established at the time of startup emission testing during PEMS breakdowns to demonstrate NOx emission compliance. [District Rule 4703, 6.2.5] Federally Enforceable Through Title V Permit


45. Permittee shall maintain records of the following: 1) the occurrence and duration of any start-up, shutdown, or malfunction in the operation of the permit unit; 2) performance testing, evaluations, calibrations, checks, adjustments, and maintenance of PEMS; and 3) emission measurements. [District Rules 1080, 7.3, 2520, 9.3.2 and 40 CFR 60.7(b)] Federally Enforceable Through Title V Permit

46. The owner or operator shall maintain a stationary a s b n ting log that includes, on a daily basis, the actual local start-up and stop time, length and re total hours of operation, and quantity and heat input of fuel used. [District Rules 2520, 9.3.2, 4a;TA 6 te I E rceable Through Title V Permit

CONDITIMJCIDNI1NUE ON NEXT PAGE 5-1547-145-21 Apr 24 2015 1 OMR EOGOHILR


47. The owner or operator of any existing stationary gas turbine system (unless exempted because all turbines are under ownership or control and have NOx and CO emissions limits which are shown on the current Permit to Operate and which do not exceed the applicable Compliance Limits in Section 5.0) shall submit to the APCO for approval, an emissions control plan of all actions. The control plan shall include a schedule of increments of progress that will be taken to comply with the requirements of the applicable NOx Compliance Limit in Section 5.0 and Compliance Schedule in Section 7.0 of District Rule 4703 (as amended 9/20/07). [District Rule 4703, 6.1] Federally Enforceable Through Title V Permit

48. The owner or operator shall monitor the gas turbine exhaust gas NOx emissions using a system that meets EPA requirements as specified in 40 CFR Part 60 App. B, Spec. 3, 40 CFR Part 60 App. F, and 40 CFR Part 60.7 (c), 60.7 (d), and 60.13. [District Rule 4703, 6.2.31 Federally Enforceable Through Title V Permit

49. CO emissions shall not exceed (lbs/hr) (three-hour average) = 38-(0.2)*(ambient air temperature in oFahrenheit) (not to exceed 30 lbs/hr) and (ppmv) = 1.86*(lbs/hr) @ 15% 02 (not to exceed 55.8 ppmv). [PSD SJ 85-03] Federally Enforceable Through Title V Permit

50. Permittee shall operate and maintain a continuous monitoring system to measure the ambient air temperature. [PSD Si 85-03] Federally Enforceable Through Title V Permit





55. {2271} The owner or operator of a stationary gas turbine system shall maintain all records of required monitoring data and support information for inspection at any time for a period of five years. [District Rule 2520, 9.4.2] Federally Enforceable Through Title V Permit

S-1547-1412.21 Apr 24 2215 1.01P111 - EDGEHIUR

Seyed Sadredin, Exeattil*Vi PCO



ISSU





EQUIPMENT DESCRIPTION: MODIFICATION OF 21.45 MW GAS FIRED TURBINE ENGINE COGENERATION FACILITY #3 WITH GENERAL ELECTRIC MODEL LM2500 PE GAS TURBINE, UNFIRED WASTE HEAT RECOVERY STEAM GENERATOR EQUIPPED WITH SCR AND AMMONIA INJECTION, AND BYPASS STACK EQUIPPED WITH SCR AND AMMONIA INJECTION: REPLACE EXISTING NOX, CO AND 02 CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) WITH A NEW ROCKWELL AUTOMATION PREDICTIVE EMISSION MONITORING SYSTEM (PEMS)

CONDITIONS {1830) This Authority to Construct serves as a written certificate of conformity with the procedural requirements of 40 CFR 70.7 and 70.8 and with the compliance requirements of 40 CFR 70.6(c). [District Rule 2201] Federally Enforceable Through Title V Permit

2. {1831) Prior to operating with modifications authorized by this Authority to Construct, the facility shall submit an application to modify the Title V permit with an administrative amendment in accordance with District Rule 2520 Section 5.3.4. [District Rule 2520, 5.3.4] Federally Enforceable Through Title V Permit


CONDITIONS CONTINUE ON NEXT PAGE

YOU MUST NOTIFY THE DISTRICT COMPLIANCE DIVISION AT (661) 392-5500 WHEN CONSTRUCTION IS COMPLETED AND PRIOR TO OPERATING THE EQUIPMENT OR MODIFICATIONS AUTHORIZED BY THIS AUTHORITY TO CONSTRUCT. This is NOT a PERMIT TO OPERATE. Approval or denial of a PERMIT TO OPERATE will be made after an inspection to verify that the equipment has been constructed in accordance with the approved plans, specifications and conditions of this Authority to Construct, and to determine if the equipment can be operated in compliance with all Rules and Regulations of the San Joaquin Valley Unified Air Pollution Control District. Unless construction has commenced pursuant to Rule 2050, this Authority to Construct shall expire and application shall be cancelled two years from the date of issuance. The applicant is responsible for complying with all laws, ordinances and regulations of er governmental agencies which may pertain to the above equipment.

Arnaud MarjolleirBireCtor of Permit Services S-1517-151.72 : Apr 24 2015 1:03PM - EDGEHILI1 : Joint logyedion NOT Requred


CONDITI NUE ON NEXT PAGE

1. On days of gas turbine engine startup/shutdown and/or stack NOx daily emission limitation by records of calculati data. [District Rule 1080] Federally Enforceable

tion, pennittee shall demonstrate compliance with s data, fuel rate data, and daily hours of operation

ermit


4. Prior to disconnecting the CEMs, the PEMS must pass a Relative Accuracy (RA) Test to be acceptable for use in demonstrating compliance with this permit. [District Rules 2201 and 4703 and 40 CFR 60.334(b)] Federally Enforceable Through Title V Permit

5. If PEMS fails to pass a quarterly RAA or yearly RATA test , or if changes are made that could result in a significant change in the emissions rate (e.g. turbine aging, process modification, new process operating modes, or changes to emission controls) the PEMS must be recertified using the test procedures in Section 8.1 of PS16. [District Rules 2201 and 4703 and 40 CFR 60.334(b)] Federally Enforceable Through Title V Permit

6. Source shall provide a PEMS protocol, specific for the source, which is reviewed and approved by the District. [District Rules 2201 and 4703 and 40 CFR 60.334(b] Federally Enforceable Through Title V Permit


8. Operating envelope must be established to ensure that PEMS is providing accurate data. [District Rules 2201 and 4703 and 40 CFR 60.334(6)] Federally Enforceable Through Title V Permit

9. The NOx, CO, and 02 PEMS shall meet the requirements in 40 CFR 60, Performance Specifications 16 (PS-16), or shall meet equivalent specifications established by mutual agreement of the District, the ARB, and the EPA. [40 CFR 60.334(b)(1) and, District Rule 1080, 6.3, 6.5, 6.6, & 7.21 Federally Enforceable Through Title V Permit


11. Fuel consumption shall not exceed 5,650 MMBtu/day of fuel gas. [District Rule 2201] Federally Enforceable Through Title V Permit


13. Except during periods of gas turbine engine startup/shutdown and stack transition, emission rates (three-hour rolling average) shall not exceed any of the following: 0.0111 lb-N0x/MMBtu or 3 ppmv-NOx @ 15% 02, and 0.076 lb-CO/MMBtu or 200 ppmvd-CO @15% 02. [District Rule 4703, 5.1.2, 5.2 and District Rule 2201] Federally Enforceable Through Title V Permit

14. Except during periods of gas turbine engine startup/shutdown and stack transition, emission rates shall not exceed any of the following: 0.016 lb-PM 10/MMBtu, 0.010 lb-S0x/MMBtu, or 0.008 lb-VOC/MMBtu. [District Rule 2201] Federally Enforceable Through Title V Permit

15. Maximum daily emission limitations (DEL) shall not exceed any of the following: 190.2 lb-NOx/day, 56.5 lb-S0x/day, 90.4 lb-PMIO/day, 429.4 lb-CO/day, and 45.2 lb-VOC/day. [District Rule 2201] Federally Enforceable Through Title V Permit


17. Stack transitions shall comply with the following criteria for HRSG Bypass Transition Period: thc duration of time that the turbine's operation transitions between the heat recovery steam generator and bypass exhaust stack, when the selective catalytic reduction catalyst is not within the required temperature range or the required ammonia saturation level has not yet been achieved, the transition period not exceeding two hours, and NOx emissions not exceeding 15 ppmvd, corrected to 15% 02, averaged over 2 hours, and the applicable CO compliance limits not being exceeded. [District Rule 4703] Federally Enforceable Through Title V Permit

5-1547-151-22 Apt 24 2015 1:010M -EDGEHLR

UE ON NEXT PAGE CONDIT!


19. Permittee shall report the following emission exceedances to the District: NOx emission rate on a three-hour average, and DEL of NOx during days of gas turbine engine startup/shutdown. [District Rule 1080] Federally Enforceable Through Title V Permit




23. Compliance with sulfur oxide emission limits shall be demonstrated by fuel gas sulfur analysis by independent testing laboratory annually. [District Rule 10811 Federally Enforceable Through Title V Permit



26. The owner or operator shall install, certify, maintain, operate and quality-assure a system which continuously measures and records the exhaust gas oxides of nitrogen, carbon monoxide, and oxygen or carbon dioxide. [District Rule 1080, 4.0,40 CFR 60.334(b), District Rule 4703, 6.2.1, & PSD SJ 85-03] Federally Enforceable Through Title V Permit

27. The PEMS shall complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive I5-minute period or shall meet equivalent specifications established by mutual agreement of the District, the ARB and the EPA. [District Rule 40 CFR 60.334(b)(2) and District Rule 1080, 6.4] Federally Enforceable Through Title V Permit

28. When operating the continuous emissions monitoring system (CEMs), it shall meet the performance specification requirements in 40 CFR 60, Appendix B; and 40 CFR 51, Appendix P, or shall meet equivalent specifications established by mutual agreement of the District, the ARB, and the EPA. [District Rule 1080, 6.5 & PSD SJ 85-03] Federally Enforceable Through Title V Permit



31. Permittee shall submit a PEMs written report for each calendar quarter to the District. The report is due on the 30th day following the end of the calendar quarter. Quarterly report shall include: time intervals, data and magnitude of excess emissions, nature and cause of excess (if known), corrective actions taken and preventive measures adopted; averaging period used for data reporting corresponding to the averaging period specified in the emission test period used to determine compliance with an emission standard; applicable time and date of each period during which the CEM was inoperative (except for zero and span checks) and the nature of system repairs and adjustments; and a negative declaration when no excess emissions occurred. [40 CFR 60.334(j), (j)(5), District Rule 1080, 8.0 and District Rule 2520, 9.6.1& PSD SJ 85-03] Federally Enforceable Through Title V Permit

54507451-22 Apr 20 2215 1 MPH - EDGEHILA


32. Excess emissions shall be defined as any consecutive 2-hour period during which the average emissions of NOx and CO, as measured by continuous monitoring system exceeds the concentration emissions limits set forth for these pollutants. Any emissions in excess of the limits imposed by conditions in this permit, as measured by the continuous monitoring equipment constitutes a violation of District Rules and Regulations and shall be reported by the operator to the APCO within 96 hours. [District Rule 1080, 9.0 & PSD SJ 85-03] Federally Enforceable Through Title V Permit

33. Operator shall notify the District no later than eight hours after the detection of a breakdown of the PEMS. The operator shall inform the District of the intent to shut down the PEMS at least 24 hours prior to the event. [District Rule 1080, 10.0] Federally Enforceable Through Title V Permit

34. Fuel sulfur content for a fuel source shall be measured weekly. Test reports of measured fuel sulfur content shall be maintained. If measured sulfur content is less than 3.5 gr/100 scf for 8 consecutive weeks for a fuel source, then the testing frequency shall be semi-annually. If any semi-annual testing show fuel sulfur content exceeds 3.5 gr/100 scf, weekly testing shall resume and exceedance shall be reported to APCO. [40 CFR 60.334(b)(c) & District Rule 2520, 9.4.2] Federally Enforceable Through Title V Permit

35. Performance testing to measure exhaust gas NOx and CO concentrations shall be conducted annually. [40 CFR 60.335(b), District Rule 4703, 6.3 & PSD SJ 85-03] Federally Enforceable Through Title V Permit

36. The following test methods shall be used: NOx (ppmv) - EPA Methods 7E or 20, or ARB Method 100; CO (ppmv) - EPA Method 10 or 10B, or ARB Method 100; stack gas oxygen - EPA Method 3, 3A or 20, or ARB Method 100; and fuel gas sulfur content - ASTM D3246 or double GC for 1-12S and mercaptans, fuel gas hhv - ASTM D1826 or DI 945 in conjunction with ASTM D3588. [40 CFR 60.335(b) and District Rules 1081, 4703, & PSD Si 85-03] Federally Enforceable Through Title V Permit


38. Performance testing shall be witnessed or authorized District personnel. Test results must he submitted to the District within 60 day of performance testing. [District Rule 1081, 7.2, 7.3] Federally Enforceable Through Title V Permit

39. Daily records of NOx and CO emission calculations during days of startup/shutdown or stack transition shall be maintained and such records shall be made readily available for District inspection upon request. [District Rule 2520, 9.4.2] Federally Enforceable Through Title V Permit

40. CO emissions shall not exceed (lbs/hr) (three-hour average) = 38-(0.2)*(ambient air temperature in 0Fahrenheit) (not to exceed 30 lbs/hr) and (ppmv) = 1.86*(lbs/hr) @ 15% 02 (not to exceed 55.8 ppmv). [PSD SJ 85-03] Federally Enforceable Through Title V Permit






46. Source testing to measure ammonia shall be conducted-tis4.*tptethod BAAQMD ST-1B. [District Rules 4102 and 2201] Federally Enforceable Through Title

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48. The operator shall monitor the ammonia injection rate that was established at the time of startup emission testing during PEMS breakdowns to demonstrate NOx emission compliance. [District Rule 4703, 6.2.5] Federally Enforceable Through Title V Permit

49. Permittee shall maintain records of the following: 1) the occurrence and duration of any start-up, shutdown, or malfunction in the operation of the permit unit; 2) performance testing, evaluations, calibrations, checks, adjustments, and maintenance of PEMS; 3) emission measurements and 4) all records or required monitoring data and support information. All records shall be maintained for a period of five years and available for District inspection upon request. [District Rules 1080, 7.3, 2520, 9.4.2 and 40 CFR 60.7(b)] Federally Enforceable Through Title V Permit



52. The owner or operator of any existing stationary gas turbine system (unless exempted because all turbines are under ownership or control and have NOx and CO emissions limits which are shown on the current Permit to Operate and which do not exceed the applicable Compliance Limits in Section 5.0) shall submit to the APCO for approval, an emissions control plan of all actions. The control plan shall include a schedule of increments of progress that will be taken to comply with the requirements of the applicable NOx Compliance Limit in Section 5.0 and Compliance Schedule in Section 7.0 of District Rule 4703 (as amended 9/20/07). [District Rule 4703, 6.1.5] Federally Enforceable Through Title V Permit


S-1547-151.22 Iv 24 2015 1:0201•1 - =EMIL/2

or san joaquin valley si. air pollution control district healthy …s... · 2015-09-03 · or san...

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