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I DEC 1 8 2014

Mr. Juan Campos Occidental of Elk Hills Inc PO Box 1001 Tupman, CA

Re: Proposed ATC / Certificate of Conformity (Significant Mod) District Facility # S-2234 Project # 1144001

Dear Mr. Campos:

Enclosed for your review is the District's analysis of an application for Authority to Construct for the facility identified above. You requested that a Certificate of Conformity with the procedural requirements of 40 CFR Part 70 be issued with this project. The project revises monitoring requirements for two 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 Authority to Construct with a Certificate 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 Authority 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.

Sincxely,

Arhaud Marjollet Ditector of Permit Serviles

AM:RE/st

Enclosures

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 953568718 Tel:12091557-6400 FAX:12091557.6475

Central Region (Mein office) 1990 E. Gettysburg Avenue

Fresno, CA 937260244

Tel:15591230.6000 FAX: 1559123N6061

Southern Region

34946 Flyover Court

Bakersfield, CA 93308.9725

Tel: 661-392•5500 FAX: 661-392-5585

www :valleyair.otg www.healthyairliving.com hilted fltld10 Pie- 0

OEHI S2234, 1144001

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:

Occidental of Elk Hills Inc PO Box 1001 Tupman, CA 93276

Juan Campos (661) 763-6354 (661) 763-6681 Juan_campos©oxy.com S-2234-52-10, '-53-8 1144001 October 30, 2014

Date: December 8, 2014 Engineer: Richard Edgehill

Lead Engineer: Richard Karrs

I. Proposal

Occidental of Elk Hills Inc (OEHI) has requested Authorities to Construct (ATCs) permit to modify two existing 24.5 MW natural gas-fired turbines by replacing the existing Continuous Emission Monitoring System (CEMs) with a Predictive Emission Monitoring System (PEMs) for NOR, CO and 02.

Note that the proposed change is not a NSR Modification as it is consistent with FYI — 111 Category 2 as stated below:

ATC reqd ? ''

TV appl ication

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.

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. Applicant has provided the following technical justification of PEMs (as a replacement of) or CEMs:

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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. SoftwareCEMO'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 Rockwell application will interface to OEHI's Metso DCS via OSI Pl. 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 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.

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Additionally, note that the following obsolete condition from the current PTOs was not included on the ATCs:

If NOx CEM data & source testing results show compliance at lower NOx emission than 3.75 ppmvd @ 15% 02, District may adjust permitted NOx emission rate 12 months after complete implementation of this approval according to CEM data & testing results. (District Rule 2201) Y OEHI facility 8-2234 operates under a Title V PTO.

The above condition was included on the initial ATC and was never implemented.

Additionally, during review of the draft ATCs, applicant requested (11-24-14 email) that brand names listed in Condition #40 of PTOs S-2234-52-9 and '-53-7 not be included on the ATCs. The condition with strikeout text was replaced with the underlined condition following it.

Gas turbine shall be mimed with turbine combustor steam iniection system. selective catalytic reduction (SCR1 with ammonia iniection, and oxidation catalyst system. 1District Rule 22011Y

The change in monitoring 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.

Current Permits to Operate S-2234-53-9 and '-54-7 are included in Attachment I.

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

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III. Project Location

The project is located at Section 35, T306, R23E in the Gas Plant 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

35R Cogeneration is a gas-fired 50 MW facility, generating power and steam. The subject 25.5 MW gas turbines were installed pre-2005 and are equipped with duct burners and Heat Recovery Steam Generators (HRSGs).

Proposed Modification

The existing CEMs for monitoring NOx, CO, and 02 will be replaced by PEMs monitoring.

Applicant has provided the following description of the PEMs methodology (12-1-14 email):

The PEMs solution is a regression model with unit measurements (fuel flow, temperature, etc.) correlated to stack measurements (N0x/C0/02). This means that existing unit measurements that are required for operation are collected and time-stamped while a stack testing trailer measures the stack gasses. The model is built by using neural network software to regress over dataset of unit measurements and stack measurements to form the correlations. The results will be linear and non-linear correlations between the turbine measurements (inputs) and stack measurements (outputs). An example model would have a correlation where increased fuel-flow would cause an increase in NOx and CO (positive correlation) while an increase in inlet air temperature would result in an increase in NOx (positive correlation) and decrease in CO (negative correlation).

A software block diagram is included in Attachment II.

V. Equipment Listing

Pre-Project Equipment Descriptions:

S-2234-52-9: ONE 24.5 MW NATURAL GAS-FIRED GAS TURBINE COGENERATION SYSTEM, INCLUDING 250 MMBTU/HR GENERAL ELECTRIC MODEL LM-2500 GAS TURBINE, 103 MMBTU/HR DUCT BURNER ASSEMBLY, 150,000 LB/HR HEAT RECOVERY STEAM GENERATOR, AND 6 MW STEAM TURBINE SERVING S-2234-52 AND S-2234-53

8-2234-53-7: ONE 24.5 MW NATURAL GAS-FIRED GAS TURBINE COGENERATION SYSTEM, INCLUDING 250 MMBTU/HR GENERAL ELECTRIC MODEL LM-

• 2500 GAS TURBINE, 103 MMBTU/HR DUCT BURNER ASSEMBLY, AND 150,000 LB/HR HEAT RECOVERY STEAM GENERATOR

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Proposed Modifications:

S-2234-52-10: MODIFICATION OF ONE 24.5 MW NATURAL GAS-FIRED GAS TURBINE COGENERATION SYSTEM, INCLUDING 250 MMBTU/HR GENERAL ELECTRIC MODEL LM-2500 GAS TURBINE, 103 MMBTU/HR DUCT BURNER ASSEMBLY, 150,000 LB/HR HEAT RECOVERY STEAM GENERATOR, AND 6 MW STEAM TURBINE SERVING S-2234-52 AND 5-2234-53: REPLACE EXISTING NOX, CO AND 02 CONTINUOUS EMISSION MONITORING SYSTEM (CEMS) WITH A NEW ROCKWELL AUTOMATION PREDICTIVE EMISSION MONITORING SYSTEM (PEMS)

S-2234-53-8: MODIFICATION OF ONE 24.5 MW NATURAL GAS-FIRED GAS TURBINE COGENERATION SYSTEM, INCLUDING 250 MMBTU/HR GENERAL ELECTRIC MODEL LM-2500 GAS TURBINE, 103 MMBTU/HR DUCT BURNER ASSEMBLY, AND 150,000 LB/HR HEAT RECOVERY STEAM GENERATOR: 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-2234-52-10: ONE 24.5 MW NATURAL GAS-FIRED GAS TURBINE COGENERATION SYSTEM, INCLUDING 250 MMBTU/HR GENERAL ELECTRIC MODEL LM-2500 GAS TURBINE, 103 MMBTU/HR DUCT BURNER ASSEMBLY, 150,000 LB/HR HEAT RECOVERY STEAM GENERATOR, AND 6 MW STEAM TURBINE SERVING S-2234-52 AND S-2234-53, AND A PREDICTIVE EMISSION MONITORING SYSTEM (PEMS)

S-2234-53-8: ONE 24.5 MW NATURAL GAS-FIRED GAS TURBINE COGENERATION SYSTEM, INCLUDING 250 MMBTU/HR GENERAL ELECTRIC MODEL LM-2500 GAS TURBINE, 103 MMBTU/HR DUCT BURNER ASSEMBLY, AND 150,000 LB/HR HEAT RECOVERY STEAM GENERATOR, AND A PREDICTIVE EMISSION MONITORING SYSTEM (PEMS)

From Proiect 930090

S-2234-52-0 & S-2234-53-0

Cogeneration turbine/generator set, including:

A. General Electric Model LM-2500, 250 MMBtu/hr nominal (LHV) heat input natural gas fired gas turbine with 103 MMBtu/hr duct burner assembly,

B. Turbine combustor steam injection system for NO. control, C. 24.5 MW electrical generator, D. 150,000 lb/hr capacity fired heat recovery steam generator, E. Johnson Matthey (or equivalent) selective catalytic reduction NO control system with

ammonia injection, F. Johnson Matthey (or equivalent) oxidation catalyst system,

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OEHI S2234, 1144001

G. Continuous emission monitors (CEM) for fuel consumption and ratio of water to fuel in turbine (currently NOx. CO. and 02 are also monitored)

H. Exhaust stack with EPA reference methods stack sampling provisions.

VI. Emission Control Technology Evaluation

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

From project 930090 • Gas turbine and duct burner exhaust is treated by SCR and oxidizing catalyst • VOC and CO emissions are controlled by a catalytic oxidizer with expected emissions

reductions of 50% and 90%, respectively. • Synthetic lube oil system is equipped with mist eliminator.

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

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.

S-2234-52 and '-53 (each PE2

Daily Emissions (lb/day) Annual Emissions (Ib/year)*** NOx 98.6 35,989 SOx 24.1* 8,797 Klio 25.3 9,235 CO 272.3 99,390

VOC 25.7 9,381 *Previously calculated using 0.75 gr 8/100scf

0.00285 lb/MMBtu x (250 +103 MMBtu/hr) x 24 hr/day = 24.1Ib/day *** daily emissions x 365

Emissions profiles are included in Attachment III.

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.

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OEHI S2234, 1144001

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 will be changing from a CEMS to a PEMs which is considered a relaxation. As a result, the proposed project constitutes a Significant Modification to the Title V Permit.

As discussed above, the facility has applied for a Certificate of Conformity (COC); 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 1993 (project 930090 EE date) and before 2005. Therefore, this subpart applies to the turbines.

§60.332: Standards for Nitrogen Oxides

The provisions of subpart GG are applicable to stationary gas turbines with a heat input at peak load equal to or greater than 107.2 Gj/hr (100 MMBtu/hr) based on the lower heating value of the fuel. The natural gas fired turbine is subject to the nitrogen oxide and sulfur oxide standards of this subpart. The applicable NOx limit specified in section 60.332 (a) (1), one hour average, is as follows:

NOx % by volume © 15% 02 = 0.0075 *14.4/Y + F

Y = manufacturers rated heat rate at rated peak load (kJ/watt hour), or actual measured heat rate at lhv and peak load. Y shall not exceed 14.4 kJ/watt hour.

F = NOx emission allowance for fuel bound nitrogen. Natural gas typically has no fuel bound nitrogen, so F is set equal to 0.

Please note that the minimum NSPS NOx standard occurs at the maximum heat rate (depending on ambient temperature) at full load.

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OEHI S2234, 1144001

NSPS NOx limit for Pratt & Whitney CTG:

Y = max heat rate = 250 x 106 Btu/hr/24,500 kW = 10,204 Btu/kW hr (est. @ ISO for hhv)

= 10.2 BtuNV hr* 1.0542 kJ/Btu Y = 10.8 kJ/W hr (less than 14.4 kJ/W hour)

NOx % by vol @ 15% 02= 0.0075 *14.4/10.8 + 0 = 0.01= 100 ppmv @ 15% 02

The gas turbine cogeneration system has a permitted NOx limit of 3.75 ppmvd © 15% 02, except during startup and shutdown, on a three-hour rolling average

§60.333: Standards for Sulfur Dioxide

Paragraphs (a) and (b) define the applicable SOx limits as follows:

SOx in exhaust gas = 0.015% by vol © 15% 02 = 150 ppmv @ 15% 02

or fuel Sulfur content of < 0.8% by weight (8000 ppmw).

The turbines are currently permitted to fire only on natural gas containing no more that 1 gr S/100scf and therefore compliance is expected.

The applicable SOx limits specified in section 60.333 are as follows:

SOx = 0.015% by vol © 15% 02 = 150 ppmv © 15% 02

or fuel S < 0.8% by weight.

The unit is fired on PUC quality natural gas with a maximum S content of 1.0 gr/100 scf. This is equivalent to

Pre-Pro'ect 0.75 gr/100 scf x 379 scf/lbmol x Ibmo1/16 lb x 1b17000 gr x 100 = 0.0025% by wt

Post-proiect 1.0 gr/100 scf x 379 scf/Ibmol x Ibmo1/16 lb x 1b17000 gr x 100 = 0.0034 % by wt

This fuel sulfur content is less than that required by Subpart GG.

§60.334: Monitoring of Operations

Paragraph (a) requires the owner/operator of any stationary gas turbine using water injection to control NOx to install and operate continuous emissions monitoring system (CEM) to

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OEHI S2234, 1144001

monitor and record fuel consumption and ratio to water to fuel fired. The following condition (from the current PTO) will assure continued compliance:

Gas turbine engine combustor steam injection system shall be equipped with continuously recording steam-to-fuel injection rate monitoring system accurate to within +/- 5%. [District Rule 2201] Y

Except during periods of gas turbine engine startup/shutdown, gas turbine engine steam injection rate shall be maintained at steam-to-fuel ratio range documented to result in compliance with emission limits. [District Rule 2201] Y

Paragraph (b) specifies requirements for any turbine that commenced construction, reconstruction, or modification after October 3, 1977, but before July 8, 2004, and which uses water or steam injection to control NOx emissions. The turbines operated at this facility are equipped with water injection for NOx emission control. Therefore, the requirements of this section are applicable.

From proiect C-535. C-1130261(refer to Appendix C)

OEHI is proposing to replace the currently installed CEMS with a Predictive Emission Monitoring System (PEMS). USEPA has approved the use of the proposed Rockwell Automation Company's PEMS using Pavilion Software CEM on a case by case basis (see Attachment C for specific predictive emission monitoring system details). EPA has stated Rockwell Automation's PEMS offers an excellent sensor validation system that constantly monitors for faulty sensor data. The system also appears capable of generating valid substitution data in many, if not most, cases. However, due to the makeup of each sensor validation system and the specifics of each application and its underlying rule requirements, we believe the merits of each system should be assessed on a case-by-case basis.

The proposed site specific PEMS will indirectly measure NOx, CO, and oxygen through correlation with operational parameters. As long as the system is installed with trained, experienced practitioners working with good tools and utilizes recommended manufacturer requirements for validation subsystems for PEMS, the Rockwell Automation's method of generating substitution data for the Pavilion Software CEM under current PEMS application is approvable. The following condition will assure continued compliance with this section:

The owner or operator shall install, certify, maintain, operate and quality-assure a Predictive Emission Monitoring System (PEMS) which continuously monitors and records the exhaust gas NOR, CO and 02 concentrations. Predictive emissions monitor(s) shall be capable of monitoring 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)]

Paragraph (c) states that any turbine that commenced construction, reconstruction or modification after October 3, 1977, but before July 8, 2004, and which does not use steam or water injection to control NOx emissions, the owner or operator may, but is not required to, for purposes of determining excess emissions, use a CEMS that meets the requirements of paragraph (b) of this section. As shown above, both turbines operated at this facility use water

(3) See Appendix C of application review performed under project C-1112835 for additional predictive emission monitoring system details including EPA's evaluation and approval of Rockwell Automation's predictive emission monitoring system.

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OEHI S2234, 1144001

injection to assist with NOx emission control. Therefore, the requirements of this section are not applicable.

Paragraphs (d), (e), and (f) all specify requirements for turbines constructed after July 8, 2004. As discussed above, these turbines were installed in the early 1990s. Therefore, the requirements of these sections are not applicable.

Paragraph (g) specifies requirements for parameters that are continuously monitored for steam or water to fuel ratios in accordance with the NOx emission controls specified in paragraphs (a), (d) or (f) of this section. The turbines are currently operating in compliance with paragraph (a) and this section.

Paragraph (h)(1) states that the operator shall monitor the total sulfur content of the fuel being fired in the turbine, except as provided in paragraph (h)(3) of this section. Paragraph (h)(3) states that the owner may elect not to monitor the total sulfur content of the gaseous fuel combusted in the turbine, if the gaseous fuel is demonstrated to meet the definition of natural gas in section 60.331(u). The owner or operator shall use one of the following sources of information to make the required demonstration:

(i) The gas quality characteristics in a current, valid purchase contract, tariff sheet, or transportation contract for the gaseous fuel, specifying that the maximum total sulfur content of the fuel is 20.0 grains/100 scf or less; or

(ii) Representative fuel sampling data which show that the sulfur content of the gaseous fuel does not exceed 20.0 grains/100 scf or less. At a minimum, the amount of fuel sampling data specified in section 2.3.1.4 or 2.3.2.4 of appendix D to part 75 of this chapter is required.

Each of these turbines is limited by permit condition to be fired solely on natural gas limited to have a sulfur content not exceeding 1.0 grains S/100 scf. The facility is currently required to document and/or test the sulfur contents of the fuels burned in these turbines. The following condition assures continued compliance with the requirements of this section:

If the turbine is fired on PUC-regulated natural gas, then maintain on file copies of natural gas bills. (District Rule 2520, 9.4.2] Y

Paragraph (h)(2) states that the owner shall monitor the nitrogen content of the fuel combusted in each turbine, if the owner or operator claims an allowance for fuel bound nitrogen (i.e. if an F-value greater than zero is being or will be used by the owner or operator to calculate STD in section 60.332). As shown in section 60.332, for the natural gas combusted in the turbines at this facility, the F-value was set equal to zero and there were no allowances given for fuel bound nitrogen contents. Therefore, the owner is not required to monitor the fuel bound nitrogen content and the requirements of this section are not applicable.

Therefore, compliance with this rule is expected.

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OEHI S2234, 1144001

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.

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 3,000,000 Btu per hour.

Each gas turbine is rated at 24.5 MW. Therefore, each turbine is subject to the requirements of this rule.

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OEHI S2234, 1144001

Section 5.1.3, Tier 3 NOx Compliance Limits

Section 7.3.1 states operators with no more than two (2) units subject to Section 5.1.3 on September 20, 2007 shall demonstrate and maintain compliance by the earlier of either of the following dates (the compliance date for any particular unit shall be determined independently of any other unit): October 1, 2011, or within 90 days following the next Major Overhaul on or after July 1, 2009.

The 24.5 MW gas turbines involved with this project currently meet the Tier 3 NO standard of 5 PPmvd NOx © 15% 02. The following condition will assure continued compliance:

Except during periods of startup/shutdown, emission rates (3-hr rolling average) from gas turbine combustion shall not exceed: PM10: 0.004 lb/MMBtu, NOx as NO2: 0.013 lb/MMBtu & 3.75 ppmvd © 15% 02, VOC: 0.004 lb/MMEtu, and CO: 0.043 lb/MMBtu. [District Rules 2201 and 4703) Y

Section 5.2, CO Emission Requirements

Section 5.2 limits the CO emissions from stationary gas turbine systems to 200 ppmvd CO © 15% 02. The turbines are limited to a maximum of 20 ppmvd CO © 15% 02; therefore, compliance is expected. The condition listed in Section 5.1 above will• assure continued compliance.

Section 5.3, Transitional Operation Periods

Section 5.3 states that on or after the compliance due date the applicable emission limits of Sections 5.1.3 or 5.2 will not be applicable during a transitional operational period. Section 3.33 defines the transitional operational period as any of the bypass transition period; primary re-ignition period, reduced load period, startup, or shutdown provided an operator complies with the requirements specified below:

The duration of each startup or each shutdown shall not exceed two hours, and the duration of each reduced load period shall not exceed one hour, except as provided below. The emission control system shall be in operation and emissions shall be minimized insofar as technologically feasible during startup, shutdown, or a reduced load period. An operator may submit an application to allow more than two hours for each startup or each shutdown or more than one hour for each reduced load period provided the operator meets all of the conditions specified in the rule.

Section 5.3.3 states notwithstanding the requirement of Section 5.3.1, an operator may submit an application for a Permit to Operate condition to allow more than the duration of time specified in Section 5.3.1 for each transitional operation period provided the operator meets all of the conditions specified in Section 5.3.3.1 through Section 5.3.3.2.

OEHI currently has startup and shutdown provisions incorporated in their existing permit requirements for each of the turbines. The duration of each startup or shutdown event will last no more than two hours. In addition, there are no transitional operational period requirements contained within the current permits. Therefore, the turbines will be operating in compliance

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OEHI• S2234, 1144001

with the requirements of this section. The following conditions will assure continued compliance:

6. Startup and shutdown of gas turbine engine, as defined in 40 CFR Subpart A 60.2, shall not exceed a time period of one hour and one hour, respectively, per occurrence. [District Rules 2201 and 4703, 5.3.1] Y

17. Transitional Operation Period shall be defined as any of following periods: bypass transition period, primary re-ignition period, reduced load period, start-up or shutdown. [District Rule 4703, 3.33] Y

18. Bypass Transition Period shall be defined as the duration of time that a gas turbine's operation transitions between the heat recovery steam generator and bypass exhaust stacks, provided all of the following conditions are met: a) The selective catalytic reduction catalyst is not within the required temperature range or the required ammonia saturation level has not yet been achieved; b) The duration of a bypass transition period shall not exceed two hours; c) NOx emissions shall not exceed 15 ppmvd, corrected to 15% 02, averaged over two (2) hours; and d) The applicable CO compliance limit shall not be exceeded. [District Rule 4703, 3.2] Y

19. Primary Re-ignition Period shall be defined as the duration of time during which a gas turbine is operated at less than rated capacity in order to reset the DLN combustion system following a primary re-Ignition, provided all of the following conditions are met: a) The duration of a primary re-ignition period shall not exceed one hour; b) NOx emissions shall not exceed 15 ppmvd, corrected at 15% 02, averaged over one (1) hour; and c) CO emissions shall not exceed 25 ppmvd, corrected at 15% 02. [District Rule 4703, 3.20] Y

20. Reduced Load Period shall be defined as the time during which a gas turbine is operated at less than rated capacity in order to change the position of the exhaust gas diverter gate, not to exceed one hour. [District Rule , 4703, 3.23] Y

32. Except during periods of startup/shutdown, emission rates (3-hr rolling average) from gas turbine combustion shall not exceed: PM10: 0.004 lb/MMBtu, NOx as NO2: 0.013 lb/MMBtu & 3.75 ppmvd © 15% 02, VOC: 0.004 lb/MMBtu, and CO: 0.043 lb/MMBtu. [District Rules 2201 and 4703] Y

Section 6.1, Emission Control Plan (ECP)

Section 6.1 requires that the owner or operator of any existing stationary gas turbine system, unless exempted in Section 6.1.5, shall submit, to the APCO for approval, an emissions control plan of all actions, including a schedule of increments of progress, which 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.

Section 7.0 requires that the owners or operators of all stationary gas turbine systems subject to Section 5.1.3 (Tier 3) shall submit the emission control plan required by Section 6.1 to the District by January 1, 2009.

The applicant has previously submitted the ECP for these two gas turbines and both turbines are operating in compliance with the latest requirements of this rule. Therefore, compliance with this section has been already been demonstrated and no further discussion is required.

Section 6.2, Monitoring and Recordkeeping

Section - 6.2.1 requires the owner to operate and maintain continuous emissions monitoring equipment for NOx and oxygen, as defined in Rule 1080 (Stack Monitoring), or install and maintain one or more of the following APCO-approved alternate monitoring plans:

13

OEHI S2234, 1144001

6.2.1.1 periodic NOx emission concentrations. 6.2.1.2 turbine exhaust oxygen concentration, 6.2.1.3 air-to-fuel ratio, 6.2.1.4 flow rate of reducing agents added to turbine exhaust, 6.2.1.5 catalyst inlet and exhaust temperature, 6.2.1.6 catalyst inlet and exhaust oxygen concentration, 6.2.1.7 other operational characteristics.

The facility currently operates a continuous emission monitoring system (CEMS) for NOx and oxygen. This CEMS will be replaced with a predictive emission monitoring system (PEMS) for NO and oxygen. The Rockwell Automation PEMS, known as Software CEM, is a system that continuously monitors emissions by developing an online model using historical and real-time data from existing plant sensors. The model predicts emissions in real-time based on typical process measurements such as fuel flow, air flow, and flue gas re-circulation settings. These models are trained using process and emissions data gathered during the execution of designed experiment created specifically for the unit to be monitored. Software CEM applications are certified in much the same manner a traditional hardware-based emission monitor would be certified. Therefore, compliance with the requirements of this section is expected. The following condition will ensure compliance with the requirements of this section:

The owner or operator shall install, certify, maintain, operate and quality-assure a Predictive Emission Monitoring System (PEMS) which continuously measures and records the exhaust gas N0x, CO, and 02 concentrations. Predictive emissions monitor(s) shall be capable of monitoring 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 emisiion rates obtained from source testing to determine compliance with emission limits contained in this permit. [District Rules 1080, 2201 and 4703 and 40 CFR 80.334(b)]

Section 6.2.2 specifies monitoring requirements for turbines without exhaust-gas NOx control devices. Each gas turbine will be equipped with an SCR system that is designed to control NOx emissions. Therefore, the requirements of this section are not applicable.

Section 6.2.3 requires that for units 10 MW and greater that operated an average of more than 4,000 hours per year over the last three years before August 18, 1994, the owner or operator shall monitor the exhaust gas NOx emissions. The units comply with this requirement.

Section 6.2.4 requires the owner or operator to maintain all records for a period of five year from the date of data entry and shall make such records available to the APCO upon request. The following condition has been added to the ATC:

All records required to be maintained by this permit shall be maintained for a period of at least five years and shall be made readily available for District inspection upon request. [District Rules 2201 and 47031

Section 6.2.6 requires the facility to maintain a stationary gas turbine system operating log that includes, on a daily basis, the actual local startup and stop time, length and reason for reduced load periods, total hours of operation, and the type and quantity of fuel used. The following condition was added to the ATCs:

14

OEHI S2234, 1144001

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 reduced load periods, total hours of operation and quantity of fuel used. (District Rule 4703]

Section 6.2.7 establishes recordkeeping requirements for units that are exempt pursuant to the requirements of Section 4.2. Each of the turbines being modified under this project is subject to the requirements of this rule. Therefore, the requirements of this section are not applicable.

Section 6.2.8 requires owners or operators performing startups or shutdowns to keep records of the duration of each startup and shutdown. In addition, Section 6.2.11 requires the owner or operator to keep records of the date, time and duration of each primary re-ignition period. The following condition was added to the ATCs:

The owner or operator shall maintain records that contain the following: the occurrence and duration of any start-up, shutdown or malfunction, performance testing, evaluations, calibrations, checks, adjustments, any periods during which a continuous monitoring system or monitoring device is Inoperative, maintenance of any PEM system that has been installed pursuant to District Rule 1080, and emission measurements. [District Rules 1080 and 4703 and 40 CFR 60.8(d)]

Section 6.2.9 specifies recordkeeping requirements for units to subject to Section 5.1.3.3. The turbines in this project are not subject to the requirements of Section 5.1.3.3. Therefore, the requirements of this section are not applicable.

Section 6.2.10 specifies recordkeeping requirements for emergency turbines that are subject to Section 6.5.2. These turbines are not emergency turbines. Therefore, the requirements of this section are not applicable.

Section 6.2.12 specifies recordkeeping requirements for turbines fired on pipeline quality gas. These turbines are fired on PUC-regulated natural gas and are not fired on pipeline quality gas. Therefore, the requirements of this section are not applicable.

Section 6.3, Compliance Testing

Section 6.3.1 states that the owner or operator of any stationary gas turbine system subject to the provisions of Section 5.0 of this rule shall provide source test information annually regarding the exhaust gas NOx and CO concentrations. The turbines are subject to the provisions of Section 5.0 of this rule. Therefore, each turbine is required to test annually to demonstrate compliance with the exhaust gas NOx and CO concentrations. The following condition is included on the current PTO and ATC:

NOx, VOC, CO, and ammonia emissions shall be measured by source testing annually 60 days prior to permit anniversary. (District Rule 2201] Y

Section 6.3.2 specifies source testing requirements for units operating less than 877 hours per year. As discussed above, each turbine system will be allowed to operate in excess of 877 hours per year. Therefore, the requirements of this section are not applicable.

Section 6.3.3 specifies source testing requirements for units that are equipped with intermittently operated auxiliary burners.

15

OEHI S2234, 1144001

Section 6.3.3 The owner or operator of any unit with an intermittently operated auxiliary burner shall demonstrate compliance with the auxiliary burner both on and off.

The ATC includes a condition satisfying this requirement.

Section 6.4, Test Methods

Section 6.4 states that the facility must demonstrate compliance annually with the NOx and CO emission limits using the following test methods, unless otherwise approved by the APCO and EPA:

Oxides of nitrogen emissions for compliance tests shall be determined by using EPA Method 7E or EPA Method 20. Carbon monoxide emissions for compliance tests shall be determined by using EPA Test Methods 10 or 10B. Oxygen content of the exhaust gas shall be determined by using EPA Methods 3, 3A, or 20.

• HHV and LLV of gaseous fuels shall be determined using ASTM 03588, ASTM 1826 or ASTM 1945.

The following conditions will ensure continued compliance with the test method requirements of this section:

The HHV and LHV of the fuel shall be determined using ASTM D3588-91, ASTM 1826-88, OR ASTM 1945-81. [40 CFR 60.332(a),(b) and District Rule 4703, 6.4.5] Y

Performance testing shall be conducted annually to measure NOx and CO emission concentrations using the following test methods: EPA Methods 7E or 20 for NOx emissions, EPA Methods 10 or 10B for CO emissions, EPA Methods 3, 3A, or 20 for Oxygen content of the exhaust gas. The 9-run tests shall be performed at highest physically achievable load of the gas turbine. [40 CFR 60.335(a), (b)(7) and District Rule 4703, 6.3.1, 6.4.1, 6.4.2, & 6.4.3] Y

Conclusion:

Conditions will be incorporated into these permits in order to ensure compliance with each applicable section of this rule. Therefore, compliance with the requirements of Rule 4703 is expected and no further discussion is required.

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 are fired on gas containing no more than 1 gr S/100 scf. 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.

16

OEHI S2234, 1144001

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.

• 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 Authority to Construct permits 8-2234-52-10 and '-53-8 subject to the permit conditions on the attached draft Authority to Construct permits in Attachment V.

X. BIIIinq Information Annual Permit Fees

Permit Number Fee Schedule Fee Description Annual Fee S-2234-52 and '-53

3020-08-F 24.5 MW* $8,171.00

`'-53 PTO erroneously lists 30.5 MW in Fee Description

Attachments

I: Current PTOs II: Software Bock Diagram III: Emissions Profiles IV: Title V Compliance Certification Form V: Draft ATCs

17

OEHI S2234, 1144001

ATTACHMENT I Current PTOs

18

San Joaquin Valley Air Pollution Control District

PERMIT UNIT: S -2234-52 -9

EXPIRATION DATE: 10/31/2016

SECTION: NE35 TOWNSHIP: 30S RANGE: 23E

EQUIPMENT DESCRIPTION: ONE 24.5 MW NATURAL GAS-FIRED GAS TURBINE COGENERATION SYSTEM, INCLUDING 250 MMBTU/HR GENERAL ELECTRIC MODEL LM-2500 GAS TURBINE, 103 MMBTU/HR DUCT BURNER ASSEMBLY, 150,000 LB/HR HEAT RECOVERY STEAM GENERATOR, AND 6 MW STEAM TURBINE SERVING S-2234-52 AND S-2234-53

PERMIT UNIT REQUIREMENTS 1. All equipment shall be maintained and operated according to manufacturers' recommendations. [District Rule 2201]

Federally Enforceable Through Title V Permit

2. Circular cross section exhaust stack shall be equipped with permanent provisions to allow collection of stack gas samples consistent with EPA test methods and equipped with flow straighteners, if necessary, to minimize turbulence. [District Rule 2201] Federally Enforceable Through Title V Permit

3. Gas turbine engine and duct burner assembly shall be equipped with continuously recording fuel gas flowmeters. [District Rule 2201] Federally Enforceable Through Title V Permit

4. Gas turbine engine shall be equipped with continuously recording NOx and 02 monitors for engine exhaust gas stream after duct burners and catalyst beds. [District Rules 2201 and 4703, 6.2.1] Federally Enforceable Through Title V Permit

5. Startup and shutdown of gas turbine engine, as defined in 40 CFR Subpart A 60.2, shall not exceed a time period of one hour and one hour, respectively, per occurrence. [District Rules 2201 and 4703, 5.3.1] Federally Enforceable Through Title V Permit

6. Gas turbine engine combustor steam injection system shall be equipped with continuously recording steam-to-fuel injection rate monitoring system accurate to within +/- 5%. [District Rule 2201] Federally Enforceable Through Title V Permit

7. Except during periods of gas turbine.engine startup/shutdown, gas turbine engine steam injection rate•shall be maintained at steam-to-fuel ratio range documented to result in compliance with emission limits. [District Rule 2201] Federally Enforceable Through Title V Permit

8. All exhaust from gas turbine , engine and duct burners shall flow through both SCR and oxidation catalyst beds. [District Rule 2201] Federally Enforceable Through Title V Permit

9. Gas temperatures at SCR and oxidation catalyst inlets shall bmonitored by operational temperature indicators. [District Rule 2201] Federally Enforceable Through Title V Permit

10. Except during periods of gas turbine engine startup/shutdown, inlet gas temperatures of SCR and oxidation catalyst beds shall be maintained within ranges recommended by the catalyst manufacturers. [District Rule 2201] Federally Enforceable Through Title V Permit

II. Ammonia injection grid shall be equipped with operational ammonia flowmeter and injection pressure indicator. [District Rule 2201] Federally Enforceable Through Title V Permit

12. Installed SCR and oxidation catalyst beds shall provide space for additional catalyst if source operation cannot achieve emission sampling limits of NOx, VOC, and CO. [District Rule 2201] 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: OCCIDENTAL OF ELK HILLS INC Location: GAS PLANT,SECTION 8E-95, T-30S, R-23E,TUPMAN, CA 41-2224414 • Nov 12014 1212PM— EC4:011.R

Permit Unit Requirements for S-2234-52-9 (continued) Page 2 of 5

13. Except during periods of gas turbine engine startup/shutdown, gas turbine engine shall be shut down if steam injection or SCR system is inoperative. [District Rule 2201] Federally Enforceable Through Title V Permit

14. Ammonia injection rate shall be controlled to maintain ammonia "breakthrough" to less than 20 ppmv (3-hr rolling average) from gas turbine exhaust. [District Rule 4102]

15. Excess emissions shall be defined as any operating hour in which 4-hour rolling average NOx concentration exceeds applicable emissions limit and a period of monitor downtime shall be any unit operating hour in which sufficient data are not obtained to validate the hour for either NOx or 02 (or both). [40 CFR 60.334(J)(1)(iii)] Federally Enforceable Through Title V Permit

16. Transitional Operation Period shall be defined as any of following periods: bypass transition period, primary re-ignition period, reduced load period, start-up or shutdown. [District Rule 4703, 3.33] Federally Enforceable Through Title V Permit

17. Bypass Transition Period shall be defined as the duration of time that a gas turbine's operation transitions between the heat recovery steam generator and bypass exhaust stacks, provided all of the following conditions are met: a) The selective catalytic reduction catalyst is not within the required temperature range or the required ammonia saturation level has not yet been achieved; b) The duration of a bypass transition period shall not exceed two hours; c) NOx emissions shall not exceed 15 ppmvd, corrected to 15% 02, averaged over two (2) hours; and d) The applicable CO compliance limit shall not be exceeded. [District Rule 4703, 3.2] Federally Enforceable Through Title V Permit

18. Primary Re-ignition Period shall be defined as the duration of time during which a gas turbine is operated at less than rated capacity in order to reset the DLN combustion system following a primary re-ignition, provided all of the following conditions are met: a) The duration of a primary re-ignition period shall not exceed one hour; b) NOx emissions shall not exceed 15 ppmvd, corrected at 15% 02, averaged over one (I) hour; and c) CO emissions shall not exceed 25 ppmvd, corrected at 15% 02. [District Rule 4703, 3.20] Federally Enforceable Through Title V Permit

19. Reduced Load Period shall be defined as the time during which a gas turbine is operated at less than rated capacity in order to change the position of the exhaust gas diverter gate, not to exceed one hour. [District Rule 4703, 3.23] Federally Enforceable Through Title V Permit

20. The emission control system shall be in operation and emissions shall be minimized insofar as technologically feasible during each transitional operation period. [District Rule 4703, 5.3.2] Federally Enforceable Through Title V Permit

21. No more than 6.00 MMscf/day of natural gas shall be consumed by gas turbine and no more than 2.47 MMscf/day of natural gas shall be consumed by duct burners. [District Rule 2201] Federally Enforceable Through Title V Permit

22. Maximum emissions from turbines S-2234-52 & -53 and standby boilers/heaters S-2234-I & -3 shall not exceed the following daily emission limitations (DEL): PM10: 50.6 lb/day, NOx (as NO2): 245.7 lb/day, VOC: 51.4 lb/day, and CO: 544.6 lb/day. [District Rule 2201] Federally Enforceable Through Title V Permit

23. During days of gas turbine startup/shutdown, daily NO2 and CO emissions shall be calculated by natural gas consumption rates, CEM results, and emission factors for standby boilers/heaters. [District Rule 2201] Federally Enforceable Through Title V Permit

24. During days of gas turbine startup/shutdown, permittee shall maintain accurate daily records of natural gas consumption in gas turbines for normal operation and startup/shutdown periods, and in LTS-1 & LTS-2 gas plant standby boilers/heaters. [District Rule 2201] Federally Enforceable Through Title V Permit

25. Permittee shall maintain daily records of NO2 and CO emission calculations during days of gas turbine startup/shutdown, and such records shall be made readily available for District inspection upon request. [District Rule 2201] Federally Enforceable Through Title V Permit

26. Permittee shall maintain accurate records of CEM printouts, and daily natural gas consumption in gas turbine & duct burners, and shall make such records readily available for District inspection upon request. [District Rule 2201] Federally Enforceable Through Title V Permit

27. Permittee shall report the following emission exceedances to the District: emission rates of NOx and CO on a 3-hr rolling average, NSPS NOx emission rate on one hour average, and DEL of NOx & CO during days of gas turbine engine startup/shutdown. [District Rule 2201] Federally Enforceable Through Title V Permit


Facility Name OCCIDENTAL OF ELK HILLS INC Location: GAS PLANT,SECTION SE45, T-305, R-23E,TUPMAN, CA I-2214624. W/12014 It - EOGReali


28. Gas turbine tube oil system atmospheric vent shall be equipped with aerosol/smoke control provisions. [District Rule 2201] Federally Enforceable Through Title V Permit

29. Emission rates from gas turbine lube oil vent shall not exceed the following: PM10: 0.02 lb/hr and VOC: 0.00 lb/hr. [District Rule 2201] Federally Enforceable Through Title V Permit

30. PMIO and VOC emissions from lube oil vent shall be measured by source testing within 60 days upon detection of visible emissions in excess of 5% opacity or Ringelmann 1/4 from gas turbine lube oil vent. [District Rule 2201] Federally Enforceable Through Title V Permit

31. Except during periods of startup/shutdown, emission rates (3-hr rolling average) from gas turbine combustion shall not exceed: PM10; 0.004 lb/MMBtu, NOx as NO2: 0.013 lb/MMBtu & 3.75 ppmvd @ 15% 02, VOC: 0.004 lb/MMBtu, and CO: 0.043 lb/MMBtu. [District Rules 2201 and 4703] Federally Enforceable Through Title V Permit

32. Except during periods of startup/shutdown, emission rates (3-hr rolling average) from duct burner combustion shall not exceed: PM 1 0: 0.001 lb/MMBtu, NOx as NO2: 0.008 lb/MMBtu, VOC: 0.001 lb/MMBtu, and CO: 0.007 lb/MMBtu. [District Rule 2201] Federally Enforceable Through Title V Permit

33. If NOx CEM data & source testing results show compliance.at lower NOx emission than 3.75 ppmvd @ 15% 02, District may adjust permitted NOx emission rate 12 months after complete implementation of this approval according to CEM data & testing results. [District Rule 2201] Federally Enforceable Through Title V Permit

34. NOx, VOC, CO, and ammonia emissions shall be measured by source testing annually 60 days prior to permit anniversary. [District Rule 2201] Federally Enforceable Through Title V Permit

35. Permittee , shall maintain steam to fuel ratio during annual compliance testing to within +/- 5% of the average daily values recorded during the 60 day period prior to annual testing. [District Rule 2201] Federally Enforceable Through Title V Permit

36. Permittee shall maintain exhaust gas temperatures at SCR and oxidation catalyst inlets to within +/- 5% of the average daily values recorded during the 60 day period prior to annual testing. [District Rule 2201] Federally Enforceable Through Title V Permit

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

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

39. LTS-1 and LTS-2 gas plants (S-2234-3 & '1) standby boilers/heaters shall only be used when one or both gas turbines (S-2234-52 & '53) are inoperative. [District Rule 2201] Federally Enforceable Through Title V Permit

40. Gas turbine engine shall be equipped with G.E. Steward Stevenson turbine combustor steam injection system, Mitsubishi/Applied Thermal Systems selective catalytic reduction (SCR) with ammonia injection, and Grace oxidation catalyst system. [District Rule 2201] Federally Enforceable Through Title V Permit

41. Unit shall be fired exclusively on PUC-quality natural gas which has a sulfur content of less than or equal to 0.0026% by weight. [40 CFR 60.333(a) & (b); 60.332(a)] Federally Enforceable Through Title V Permit

42. Operator shall not discharge into the atmosphere combustion contaminants (PM) exceeding in concentration at the point of discharge, 0.1 gr/dscf. [District Rule 4201] Federally Enforceable Through Title V Permit

43. APCO or an authorized representative shall be allowed to inspect, as determined to be necessary, the monitoring devices required by this rule to ensure that such devices are functioning properly. [District Rule 1080, 11.0] Federally Enforceable Through Title V Permit

44: Operator shall be required to conform to the compliance testing procedures described in District Rule 1081. [District Rule 1081] 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: OCCIDENTAL OF ELK HILLS INC Location: GAS PLANT,SECTION SE-35, T-30S, R-23E,TUPMAN, CA 0-T234624. Mor 1 2014 12 IVY —MONA

Permit Unit Requirements for S-2234-52-9 (continued) Page 4 of 5 45. lithe turbine is not fired on PUC-regulated natural gas, then the sulfur content (as hydrogen sulfide) of the natural gas

being fired in the turbine shall be calculated using a continuous monitor averaged over a daily basis in accordance with SCAQMD Rule 431.1 Attachment A (as amended June 12, 1998). [District Rule 2520, 9.3.2, 40 CFR 60.335(d)] Federally Enforceable Through Title V Permit

46. If the turbine is not fired on PUC-regulated natural gas, the sulfur content (as hydrogen sulfide) of each fuel source shall be tested. [40 CFR 60.334(b)(2)] Federally Enforceable Through Title V Permit

47. The HHV and LHV of the fuel shall be determined using ASTM D3588-91, ASTM 1826-88, OR ASTM 1945-81. [40 CFR 60.332(a),(b) and District Rule 4703, 6.4.5] Federally Enforceable Through Title V Permit

48. Performance testing shall be conducted annually to measure NOx and CO emission concentrations using the following test methods: EPA Methods 7E or 20 for NOx emissions, EPA Methods 10 or 10B for CO emissions, EPA Methods 3, 3A, or 20 for Oxygen content of the exhaust gas. The 9-run tests shall be performed at highest physically achievable load of the gas turbine. [40 CFR 60.335(a), (b)(7) and District Rule 4703, 6.3.1, 6.4.1, 6.4.2, & 6.4.3] Federally Enforceable Through Title V Permit

49. The CEMS shall complete a minimum of one cycle of operation (sampling, analyzing, and date recording) for each successive 15-minute period or shall meet equivalent specifications established by mutual agreement of the District, the ARE, and the EPA. [40 CFR 60.334(b)FSand District Rule 1081, 6.4] Federally Enforceable Through Title V Permit

50. Results of the CEM system shall be averaged over a three hour period, using consecutive 15-minute sampling periods in accordance with all applicable requirements of CFR 60.13. [40 CFR 60.13 and District Rule 4703, 5.1, 6.4] Federally Enforceable Through Title V Permit

51. Any gas turbine with an intermittently operated auxiliary burner shall demonstrate compliance with the auxiliary burner both on and off. [40 CFR 60.335(b) and District Rule 4703, 6.3.3] Federally Enforceable Through Title V Permit

52. The NOx and 02 CEMS shall meet the requirements in 40 CFR 60, Appendix F Procedure 1 and Part 60, Appendix B Performance Specifications 2 and 3, or shall meet equivalent specifications established by mutual agreement of the District, the ARE, 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

53. 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 1080, 7.11 Federally Enforceable Through Title V Permit

54. Records shall be maintained and shall contain: the occurrence and duration of any start-up, shutdown, performance testing, evaluations, calibrations, checks, adjustments, any periods during which a continuous monitoring system or monitoring device is inoperative, maintenance of any CEMS that have been installed pursuant to District Rule 1080, and emission measurements. [District Rules 1080, 7.3, and 4703, 6.2.8, and 40 CFR 60.7 (b)] Federally Enforceable Through Title V Permit

55. If the turbine is fired on PUC-regulated natural gas, then maintain on file copies of natural gas bills. [District Rule 2520, 9.4.2] Federally Enforceable Through Title V Permit

56. The operator of a stationary gas turbine system shall maintain records of the date, time and duration of each bypass transition period and each primary re-ignition period. [District Rule 4703, 6.2.11] Federally Enforceable Through Title V Permit

57. The operator of a stationary gas turbine system shall provide source test information annually regarding the exhaust gas NOx and CO concentrations and the control efficiency of the emission control device. [District Rule 4703, 6.3.1] Federally Enforceable Through Title V Permit

58. Results of continuous emission monitoring must be averaged in accordance with the requirements of 40 CFR 60.13. [40 CFR 60.334(a),(b),(c) and District Rule 4703, 5.0] Federally Enforceable Through Title V Permit


Facility Name: OCCIDENTAL OF ELK HILLS INC Location: GAS PLANT,SECTION SE-35, T•30S, R-23E,TUPAAAN, CA 11-22N-04: Mg I 2014 IMP61- EMMA


59. 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 reduced load periods, total hours of operation and quantity of fuel used. [40 CFR 60.332(a),(b) and District Rule 4703, 6.2.4] Federally Enforceable Through Title V Permit

60. Compliance with permit conditions in the Title V permit shall be deemed compliance with the following subsumed requirements: 40 CFR 60.333 (a) and (b); 60.334(a),(b), and (c)(1); SJVUAPCD Rule 4703, Section 6.2.2 and 1080, 7.3. A permit shield is granted from these requirements. [District Rule 2520, 13.2] Federally Enforceable Through Title V Permit

61. Compliance with permit conditions in the Title V permit shall be deemed compliance with the following applicable requirements: SJVUAPCD Rule 4201, 1081 and 1080, Sections 6.5, 7.2, 8.0, 9.0, and 10.0; 40 CFR 60.332(c) and (d); 60.334(b) and (c)(2); 60.335(d). A permit shield is granted from these requirements. [District Rule 2520, 13.2] Federally Enforceable Through Title V Permit

62. Compliance with permit conditions in the Title V permit shall be deemed compliance with the following applicable requirements: SJVUAPCD Rule 4703, sections 5.0, 5.1.1, 6.2.1, 6.2.4, 6.3, 6.4.1, 6.4.3, 6.4.5, and 6.4.6. A permit shield is granted from these requirements. [District Rule 2520, 13.2] Federally Enforceable Through Title V Permit

63. Compliance with permit conditions in the Title V permit shall be deemed compliance with the following subsumed requirements: 40 CFR 60.332(a), (b); 60.335(a), (b), (c), and (e). A permit shield is granted from these requirements. [District Rule 2520, 13.2] Federally Enforceable Through Title V Permit

64. Operator shall install, operate and maintain in calibration a system which continuously measures and records: control system operating parameters, elapsed time of operation, the exhaust gas NOx and 02 concentrations. [40 CFR 60.334(a),(b)] Federally Enforceable Through Title V Permit

65. A violation of NOx emission standards indicated by the NOx CEM shall be reported by the operator to the APCO within 96 hours. [District Rule 1080, 9.0] Federally Enforceable Through Title V Permit

66. Operator shall submit a semiannual report listing any daily period during which the sulfur content of the fuel being fired in the gas turbine exceeds-0.8% by weight. [40 CFR 60.334(c)(2)] Federally Enforceable Through Title V Permit

67. Operator shall notify the APCO no later than eight hours after the detection of a breakdown of the CEM. Operator shall inform the APCO 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

68. Operators of CEM's installed at the direction of the APCO shall submit a written report for each calendar quarter to the APCO. The report is due on the 30th day following the end of the calendar quarter and shall include: A. time intervals, data and magnitude of excess emissions, nature and cause of excess (if known), corrective actions taken and preventive measures adopted; B. 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; C. 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; D. a negative declaration when no excess emissions occurred. [District Rule 1080, 8,0] Federally Enforceable Through Title V Permit

69. NOx and carbon monoxide daily emissionsshall be measured by use of CEM data, fuel rate data, and daily hours of operation data. A written record of the required compliance demonstrations shall be maintained and made available for District inspection for a period of five years. [District Rule 22011 Federally Enforceable Through Title V Permit

These terms and conditions are part of the Facility-wide Permit to Operate. Facility Name: OCCIDENTAL OF ELK HILLS INC

' Location: GAS PLANT,SECTION SE-35, T•30S, R-23E :TUPMAN, CA 111-22344241: Wm 1 ZOM 12121.4- (00011LR


PERMIT UNIT: S-2234-53-7

EXPIRATION DATE: 10/31/2016


EQUIPMENT DESCRIPTION: ONE 24.5 MW NATURAL GAS-FIRED GAS TURBINE COGENERATION SYSTEM, INCLUDING 250 MMBTU/HR GENERAL ELECTRIC MODEL LM-2500 GAS TURBINE, 103 MMBTU/HR DUCT BURNER ASSEMBLY, AND 150,000 LB/HR HEAT RECOVERY STEAM GENERATOR

PERMIT UNIT REQUIREMENTS I. All equipment shall be maintained and operated according to manufacturers' recommendations. [District Rule 2201]

Federally Enforceable Through Title V Permit






7. Except during periods of gas turbine engine startup/shutdown, gas turbine engine.steam injection rate shall be maintained at steam-to-fuel ratio range documented to result in compliance with emission limits. [District Rule 2201] Federally Enforceable Through Title V Permit

8. All exhaust from gas turbine engine and duct bumers.shall flow through both SCR and oxidation catalyst beds. [District Rule 2201] Federally Enforceable Through Title V Permit

9. Gas temperatures at SCR and oxidation catalyst inlets shall be monitored by operational temperature indicators. [District Rule 2201] Federally Enforceable Through Title V Permit

10. Except during periods.of gas turbine engine startup/shutdown, inlet gas temperatures of SCR and oxidation catalyst beds shall be maintained within ranges recommended by the catalyst manufacturers. [District Rule 2201] Federally Enforceable Through Title V Permit

11. Ammonia injection grid shall be equipped with operational ammonia flowmeter and injection pressure indicator. [District Rule 2201] Federally Enforceable Through Title V Permit

12. Installed SCR and oxidation catalyst beds shall provide space for additional catalyst if source operation cannot achieve emission sampling limits.of NOx, VOC, and CO. [District Rule 2201] Federally Enforceable Through Title V Permit


Facility Name: OCCIDENTAL OF ELK HILLS INC Location: GAS PLANT,SECTION SE-35, T-30S, R-23E,TUPiAAN, CA 0.273443-7 Not

• TIM 1211M - MENU,

Permit Unit Requirements for S-2234-53-7 (continued) Page 2 of 5 13. Except during periods of gas turbine engine startup/shutdown, gas turbine engine shall be shut down if steam injection

or SCR system is inoperative. [District Rule 2201] Federally Enforceable Through Title V Permit 14. Ammonia injection rate shall be controlled to maintain ammonia "breakthrough" to less than 20 ppmv (3-hr rolling

average) from gas turbine exhaust. [District Rule 4102]

15. Excess emissions shall be defined as any operating hour in which 4-hour rolling average NOx concentration exceeds applicable emissions limit and a period of monitor downtime shall be any unit operating hour in which sufficient data are not obtained to validate the hour for either NOx or 02 (or both). [40 CFR 60.334(J)(I)(iii)] Federally Enforceable Through Title V Permit



18. Primary Re-ignition Period shall be defined as the duration of time during which a gas turbine is operated at less than rated capacity in order to reset the DLN combustion system following a primary re-ignition, provided all of the following conditions are met: a) The duration of a primary re-ignition period shall not exceed one hour; b) NOx emissions shall not exceed 15 ppmvd, corrected at 15% 02, averaged over one (1) hour; and c) CO emissions shall not exceed 25 ppmvd, corrected at 15% 02. [District Rule 4703, 3.20] Federally Enforceable Through Title V Permit


•20. The emission control system shall be in operation and emissions shall be minimized insofar as technologically feasible during each transitional operation period. [District Rule 4703, 5.3.2] Federally Enforceable Through Title V Permit


22. Maximum emissions from turbines S-2234-52 & -53 and standby boilers/heaters S-2234-I & -3 shall not exceed the following daily emission limitations (DEL): PM10: 50.6 lb/day, NOx (as NO2): 245.7 lb/day, VOC: 51.4 lb/day, and CO: 544.6 lb/day. [District Rule 2201] Federally Enforceable Through Title V Permit

23. During days of gas turbine startup/shutdown, daily NO2 and CO emissions shall be calculated by natural gas consumption rates, CEM results, and emission factors for standby boilers/heaters. [District Rule 2201] Federally Enforceable Through Title V Permit



26. Permittee shall maintain accurate records of CEM printouts, and daily natural gas consumption in gas turbine & duct burners, and shall make such records readily available for District inspection upon request. [District Rule 2201] Federally Enforceable Through Title V Permit



Facility Name: OCCIDENTAL OF ELK HILLS INC Location: GAS PLANT,SECT1ON SE-35, T-30S, R-23E,TUPIVIAN, CA 52214434. Pew 12314 1212PLI - ECCIFICLA

Permit Unit Requirements for S-2234-53-7 (continued)

Page 3 of 5

28. Gas turbine lube oil system atmospheric vent shall be equipped with aerosol/smoke control provisions. [District Rule 2201] Federally Enforceable Through Title V Permit


30. PM 10 and VOC emissions from lube oil vent shall be measured by source testing within 60 days upon detection of visible emissions in excess of 5% opacity or Ringelmann 1/4 from gas turbine lube oil vent. [District Rule 2201] Federally Enforceable Through Title V Permit

31. Except during periods of startup/shutdown, emission rates (3-hr rolling average) from gas turbine combustion shall not exceed: PM10: 0.004 lb/MMBtu, NOx as NO2: 0.013 lb/MMBtu & 3.75 ppmvd @ 15% 02, VOC: 0.004 lb/MMBtu, and CO: 0.043 lb/MMBtu. [District Rules 2201 and 4703] Federally Enforceable Through Title V Permit

32. Except during periods of startup/shutdown, emission rates (3-hr rolling average) from duct burner combustion shall not exceed: PM10: 0,001 lb/MMBtu, NOx as NO2: 0.008 lb/MMBtu, VOC: 0.001 lb/MMBtu, and CO: 0.007 lb/MMBtu. [District Rule 2201] Federally Enforceable Through Title V Permit

33. If NOx CEM data & source testing results show compliance at lower NOx emission than 3.75 ppmvd @ 15% 02, District may adjust permitted NOx emission rate 12 months after complete implementation of this approval according to CEM data & testing results. [District Rule 2201] Federally Enforceable Through Title V Permit

34. NOx, VOC, CO, and ammonia emissions shall be measured by source testing annually 60 days prior to permit anniversary. [District Rule 2201] Federally Enforceable Through Title V Permit

35. Permittee shall maintain steam to fuel ratio during annual compliance testing to within +/- 5% of the average daily values recorded during the 60 day period prior to annual testing. [District Rule 2201] Federally Enforceable Through Title V Permit



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

39. LTS-1 and LTS-2 gas plants (S-2234-3 & 'I) standby boilers/heaters shall only be used when one or both gas turbines (S-2234-52 & '53) are inoperative. [District Rule 2201] Federally Enforceable Through Title V Permit

40. Gas turbine engine shall be equipped with G.E. Steward Stevenson turbine combustor steam injection system, Mitsubishi/Applied Thermal Systemsselective catalytic reduction (SCR) with ammonia injection, and Grace oxidation catalyst system. [District Rule 2201] Federally Enforceable Through Title V Permit

41. Unit shall be fired exclusively on PUC-quality natural gas which has a sulfur content of less than or equal to 0.0026% by weight. [40 CFR 60.333(a) & (b); 60.332(a)] Federally Enforceable Through Title V Permit



44. Operator shall be required to conform to the compliance testing procedures described in District Rule 1081. [District Rule 1081] Federally Enforceable Through Title V Permit


Facility Name: OCCIDENTAL OF ELK HILLS INC Location: GAS PLANT,SECTION 8E-35, T-30S, R-23E,TUPMAN, CA 0-27)443-7:10w I 7014 1212PIII,EGGEHILA

Permit Unit Requirements for S-2234-53-7 (continued) Page 4 of 5 45. If the turbine is not fired on PUC-regulated natural gas, then the sulfur content (as hydrogen sulfide) of the natural gas

being fired in the turbine shall be calculated using a continuous monitor averaged over a daily basis in accordance with SCAQMD Rule 431.1 Attachment A (as amended June 12, 1998). [District Rule 2520, 9.3.2, 40 CFR 60.335(d)] Federally Enforceable Through Title V Permit




49. The CEMS shall complete a minimum of one cycle of operation (sampling, analyzing, and date recording) for each successive 15-minute period or shall meet equivalent specifications established by mutual agreement of the District, the ARB, and the EPA. [40 CFR 60.334(b)(2) and District Rule 1081, 6.4] Federally Enforceable Through Title V Permit

50. Results of the CEM system shall be averaged over a three hour period, using consecutive 15-minute sampling periods in accordance with all applicable requirements of CFR 60.13. [40 CFR•60.13 and District Rule 4703, 5.1,6.4] Federally Enforceable Through Title V Permit


52. The NOx and 02 CEMS shall meet the requirements in 40 CFR 60, Appendix F Procedure I and Part 60, Appendix B Performance Specifications 2 and 3, 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

53. The CEMS shall be linked to a data logger which is compatible with the Districts 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 1080, 7.1] Federally Enforceable Through Title V Permit

54. Records shall be maintained and shall contain: the occurrence and duration of any start-up, shutdown, performance testing, evaluations, calibrations, checks, adjustments, any periods during which a continuous monitoring system or monitoring device is inoperative, maintenance of any CEMS that have been installed pursuant to District Rule 1080, and emission measurements. [District Rules 1080, 7.3, and 4703, 6.2.8, and 40 CFR 60.7 (b)] Federally Enforceable Through Title V Permit




58. Results of continuous emission monitoring must be averaged in accordance with the requirements of 40 CFR 60.13. [40 CFR 60.334(a),(b),(c) and District Rule 4703, 5.0] Federally Enforceable Through Title V Permit


Facility Name: OCCIDENTAL OF ELK HILLS INC Location: GAS PLANT,SECTION SE-35, T-30S, R-23E,TUPMAN, CA 11421443-7 Nor 2014 iti291A-6001i:NIR






63. Compliance with permit conditions in the Title V permit shall be deemed compliance with the following subsumed requirements: 40 CFR 60.332(a), (b); 60.335(a), (b), (c), and (e). A permit shield is granted from these requirements. [District Rule 2520, 13.2] Federally Enforceable Through Title V Permit

64. Operator shall install, operate and maintain in calibration a system which continuously measures and records: control system operating parameters, elapsed time of operation, the exhaust gas NOx and 02 concentrations. [40 CFR 60.334(a),(b)] Federally Enforceable Through Title V Permit

65. A violation of NOx emission standards indicated by the NOx CEM shall be reported by the operator to the APCO within 96 hours. [District Rule 1080, 9.0] Federally Enforceable Through Title V Permit

66. Operator shall submit a semiannual report listing any daily period during which the sulfur content of the fuel being fired in the gas turbine exceeds 0.8% by weight. [40 CFR 60.334(c)(2)] Federally Enforceable Through Title V Permit

67. Operator shall notify the APCO no later than eight hours after the detection of a breakdown of the CEM. Operator shall inform the APCO 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

68. Operators of CEM's installed at the direction of the APCO shall submit a written report for each calendar quarter to the APCO. The report is due on the 30th day following the end of the calendar quarter and shall include: A. time intervals, data and magnitude of excess emissions, nature and cause of excess (if known), corrective actions taken and preventive.measures.adopted; B. 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; C. 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; D. a negative declaration when no excess emissions occurred. [District Rule 1080, 8.0] Federally Enforceable Through Title V Permit

69. NOx and carbon monoxide daily emissions shall be measured by use of CEM data, fuel rate data, and daily hours of operation data. A written record of the required compliance demonstrations shall be maintained and made available for District inspection for a period of five years. [District Rule 2201] Federally Enforceable Through Title V Permit

These terms and conditions are part of the Facility-wide Permit to Operate. Facility Name: OCCIDENTAL OF ELK HILLS INC Location: OAS PLANT,SECTION SE-35, T-30S, R-23E,TUPMAN, CA 42214434 : Nur 1 2014 12 Oft - EDGENSLA

OEHI S2234, 1144001

ATTACHMENT II Software Block Diagram

19

Control System or Process

Data Historian

/ - — itTa-s-

V,

Emissions Model

Supplemental Information

6. Process Weight Not applicable

7. Fuels and Burners used No change to the current configuration is proposed.

8. Process and Instrumentation Diagram No change in the process and instrumentation is proposed.

9. Equipment Drawings No change in operational equipment is proposed.

10. Block Diagram

SoftwareCEM Block Diagram The diagram below uses a block diagram to depict the data movement of a SoftwareCEM system. 1) The data will be pulled from the control system and/or data historian.

2) The Sensor Validation Models are used to validate that the raw data coming from the control system and/or data historian is accurate or what we refer to as "good" data. 3) Once the data is validated, or reconstructed, this data is used as the inputs into the emissions model. 4) The outputs of the emissions model are the emissions calculations that will be supplied to the reporting system.

Sensor Validation Models

(Possible) Substitution of

Reconstructed Values

1

VI

Cogen PEMS ATC Application October 15, 2014

OEHI S2234, 1144001

ATTACHMENT III Emissions profiles

20

SJVUAPCD SOUTHERN

Application Emissions 11/1/14 12:10 pm

Permit ft; S-2234-52-10 Last Updated Facility: OCCIDENTAL OF 10/31/2014 EDGEHILR ELK HILLS INC

Equipment Pre-Baselined: NO NOX

CO

VOC Potential to Emit (Ib/Yr): 35989.0 8797.0 9235.0 99390.0 9381.0

Daily Emis. Limit (lb/Day) 98.6 24.1 25.3 272.3 25.7

Quarterly Net Emissions Change (lb/Qtr)

Ql: 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 04: 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

11/1/14 SOUTHERN

12:10 pm

Permit #: S-2234-53-8 Last Updated Facility: OCCIDENTAL OF 10/31/2014 EDGEHILR ELK HILLS INC

Equipment Pre-Baselined: NO NOX .311X

PM1 0

CO

VOC Potential to Emit (1b/Yr): 35989.0 8797.0 9236.0 99390.0 9381.0

Daily Emis. Limit (lb/Day) 98.8 24.1 25.3 272.3 25.7

Quarterly Net Emissions Change (lb/Qtr)

1: 0.0 0.0 0.0 0.0 0.0 2: 0.0 0.0 0.0 0.0 0.0 3: 0.0 0.0 0.0 0.0 0.0 4: 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: 3: 4:

OEHI S2234, 1144001

ATTACHMENT IV. Title V Compliance Certification Form

21

San Joaquin Valley Unified Air Pollution Control District RaceIvec,

OCT 1 6 2014 _ sJvApCD

TITLE V MODIFICATION - COMPLIANCE CERTIFICATION FORM

I. TYPE OF PERMIT ACTION (Cheek appropriate box)

( ] SIGNIFICANT PERMIT MODIFICATION

[ ] ADMINISTRATIVE AMENDMENT [X ] MINOR PERMIT MODIFICATION

COMPANY NAME: Occidental of Elk Hills, Inc FACILITY ID: S .— 2234 1. Type of Organization:[ x 1 Corporation [ ] Sole Ownership .[_ ] Government [ ] Partnership [ ] Utility 2. Owner's Name: Occidental of Elk Hills, Inc _

3. Agent to the Owner:, Occidental of Elk Hills, Inc.

IL COMPLIANCE CERTIFICATION (Read each statement carefully and initial all circles for confirmation):

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

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

Corrected information will be provided tolhe District when I become aware that incorrect or incomplete information has been;submitted.

Based on information and belief formediafter 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:

Signature of Responsible Official ,71/1 Date

Richard Garcia

Name of Responsible Official (please print)

Environmental Team Lead

Title of Responsible Official (please print)

OEHI S2234, 1144001

ATTACHMENT V DRAFT ATCs

22

Seyed Sadredln, Epos:4141A PCO


AUTHORITY TO CONSTRUCT PERMIT NO: S-2234-52-10 ISSU LEGAL OWNER OR OPERATOR: CALIFORNIA RESOURCES ELK HILLS, LLC MAILING ADDRESS: PO BOX 1001

TUPMAN, CA 93276

LOCATION: GAS PLANT SECTION SE-35, T-30S, R-23E TUPMAN, CA


EQUIPMENT DESCRIPTION: MODIFICATION OF ONE 24.5 MW NATURAL GAS-FIRED GAS TURBINE COGENERATION SYSTEM, INCLUDING 250 MMBTU/HR GENERAL ELECTRIC MODEL LM-2500 GAS TURBINE, 103 MMBTU/HR DUCT BURNER ASSEMBLY, 150,000 LB/HR HEAT RECOVERY STEAM GENERATOR, AND 6 MW STEAM TURBINE SERVING S-2234-52 AND S-2234-53: REPLACE CEMS WITH PEMS

CONDITIONS 1. (18301 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 22011 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. All equipment shall be maintained and operated according to manufacturers' recommendations. [District Rule 2201] Federally Enforceable Through Title V Permit


CONDITIONS CONTINUE ON NEXT PAGE YOU MUST NOTIFY THE DISTRICT COMPLIANCE DIVISION AT (661) 392-5600 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 ha° 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 ,nll..ettler governmental agencies which may pertain to the above equipment.

Arnaud Marjolletrefrector of Permit Services 11-223462.10: 0662 TM AVM — EDODICIA : 401 hopedlen MDT Rewind

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

Conditions for S-2234-52-10 (continued) Page 2 of 6 5. 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)]





10. Except during periods of gas turbine engine startup/shutdown, gas turbine engine steam injection rate shall be maintained at steam-to-fuel ratio range documented to result in compliance with emission limits. [District Rule 2201] Federally Enforceable Through Title V Permit

11. All exhaust from gas turbine engine and duct burners shall flow through both SCR and oxidation catalyst beds. [District Rule 2201] Federally Enforceable Through Title V Permit





16. Except during periods of gas turbine engine•startup/shutdown, gas turbine engine shall be shut down if steam injection or SCR system is inoperative. [District Rule 2201] Federally Enforceable Through Title V Permit


18. Excess emissions shall be defined as any operating hour in which 4-hour rolling average NOx concentration exceeds applicable emissions limit and a period of monitor downtime shall be any unit operating hour in which sufficient data are not obtained to validate the hour for either NOx or 02 (or both). [40 CFR 60.334(J)(1)(iii)] Federally Enforceable Through Title' V Permit


CONDIT likikE ON NEXT PAGE 642346242: Me 2 32I4 •.3001.1 - EIVEHILA

CONDITI

Conditions for S-2234-52-10 (continued) Page 3 of 6 20. Bypass Transition Period shall be defined as the duration of time that a gas turbine's operation transitions between the

heat recovery steam generator and bypass exhaust stacks, provided all of the following conditions are met: a) The selective catalytic reduction catalyst is not within the required temperature range or the required ammonia saturation level has not yet been achieved; b) The duration of a bypass transition period shall not exceed two hours; c)NOx emissions shall not exceed 15 ppmvd, corrected to 15% 02, averaged over two (2) hours; and d) The applicable CO compliance limit shall not be exceeded. [District Rule 4703, 3.2] Federally Enforceable Through Title V Permit

21. Primary Re-ignition Period shall be defined as the duration of time during which a gas turbine is operated at less than rated capacity in order to reset the DLN combustion system following a primary re-ignition, provided all of the following conditions are met: a) The duration of a primary re-ignition period shall not exceed one hour, b) NOx emissions shall not exceed 15 ppmvd, corrected at 15% 02, averaged over one (I) hour; and c) CO emissions shall not exceed 25 ppmvd, corrected at 15% 02. [District Rule 4703, 3.20] Federally Enforceable Through Title V Permit

22. Reduced Load Period shall be defined as the time during which a gas turbihe is operated at less than rated capacity in order to change the position of the exhaust gas diverter gate, not to exceed one hour. [District Rule 4703, 3.23] Federally Enforceable Through Title V Permit



25. Maximum emissions from turbines S-2234-52 & -53 and standby boilers/heaters S-22344 & -3 shall not exceed the following daily emission limitations (DEL): PM10: 50.6 lb/day, NOx (as NO2): 245.7 lb/day, VOC: 51.4 lb/day, and CO: 544.6 lb/day. [District Rule 2201] Federally Enforceable Through Title V Permit

26. During days of gas turbine startup/shutdown, daily NO2 and CO emissions shall be calculated by natural gas consumption rates, PEMS results, and emission factors for standby boilers/heaters. [District Rule 2201] Federally Enforceable Through Title V Permit

27. During days of gas turbine startup/shutdown, permittee.shall maintain accurate daily records of natural gas consumption in gas turbines for normal operation and startup/shutdown periods, and in LTS-1 & LTS-2 gas plant standby boilers/heaters. [District Rule 2201] Federally Enforceable Through Title V Permit


29. Permittee shall maintain accurate records of PEMS predicted NOx and CO emissions, and daily natural gas consumption in gas turbine & duct burners, and shall make such records readily available for District inspection upon request. [District Rule 2201] Federally Enforceable Through Title V Permit




33. PM10 and VOC emissions from lube oil vent shall be measured by source testing within 60 days upon detection of visible emissions in excess of 5% opacity or Ringelmann 1/4 from gas turbine lube oil vent. [District Rule 2201] Federally Enforceable Through Title V Permit

34. Except during periods of startup/shutdown, emission rates (3-hr rolling average) from gas turbine combustion shall not exceed: PM10: 0.004 lb/MMBtu, NOx as NO2: 0.013 lb/M 3.75 ppmvd @ 15% 02, VOC: 0.004 lb/MMBtu, and CO: 0.043 lb/MMBtu. [District Rules 2201 an_§,47 ] y Enforceable Through Title V Permit

UE ON NEXT PAGE UMW12.I0:CW220141110W-EDGENCR

E ON NEXT PAGE

Conditions for S-2234-52-10 (continued) Page 4 of 6

35. Except during periods of startup/shutdown, emission rates (3-hr rolling average) from duct burner combustion shall not exceed: PM10: 0.001 lb/MMBtu, NOx as NO2: 0.008 lb/IvIMBtu, VOC: 0.001 lb/MMBtu, and CO: 0.007 lb/MMBtu. [District Rule 2201] Federally Enforceable Through Title V Permit

36. NOx, VOC, CO, and ammonia emissions shall be measured by source testing annually. [District Rule 2201] Federally Enforceable Through Title V Permit






42. Gas turbine shall be equipped with turbine combustor steam injection system, selective catalytic reduction (SCR) with ammonia injection, and oxidation catalyst system. [District Rule 2201] Federally Enforceable Through Title V Permit

43. Unit shall be fired exclusively on PUC-quality natural gas which has a sulfur content of less than or equal to 0.0034% by weight. [40 CFR 60.333(a) & (b)] Federally Enforceable Through Title V Permit




47. If the turbine is not fired on PUC-regulated natural gas, then the sulfur content (as hydrogen sulfide) of the natural gas being fired in the turbine shall be calculated using a continuous monitor averaged over a daily basis in accordance with SCAQMD Rule 431.1 Attachment A (as amended June 12, 1998). [District Rule 2520, 9.3.2, 40 CFR 60.335(d)] Federally Enforceable Through Title V Permit




51. The PEMS shall complete a minimum of one cycle of operation (sampling, analyzing, and date recording) for each successive 15-minute period or shall meet equivalent specifications established by mutual agreement of the District, the ARB, and the EPA. [40 CFR 60.334(b)FSand District Rulg..1.0f 1, 6.4] Federally Enforceable Through Title V Permit

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52. Results of the PEMS system shall be averaged over a three hour period, using consecutive 15-minute sampling periods in accordance with all applicable requirements of CFR 60.13. [40 CFR 60.13 and District Rule 4703, 5.1, 6.4] Federally Enforceable Through Title V Permit


54. The NOx 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

55. 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

56. Records shall be maintained and shall contain: the occurrence and duration of any start-up, shutdown, performance testing, evaluations, calibrations, checks, adjustments, any periods during which a continuous monitoring system or monitoring device is inoperative, maintenance of any PEMS that have been installed pursuant to District Rule 1080, and emission measurements. [District Rules 1080, 7.3, and 4703, 6.2.8, and 40 CFR 60.7 (b)] Federally Enforceable Through Title V Permit




60. Results of PEMs must be averaged in accordance with the requirements of 40 CFR 60.13. [40 CFR 60.334(a),(b),(c) and District Rule 4703, 5.0] Federally Enforceable Through Title V Permit





65. Compliance with permit conditions in the Title V permit shall be deemed compliance with the following subsumed requirements: 40 CFR 60.332(a), (b); 60.335(a), (b), (c), and (e). A permit shield is granted from these requirements. [District Rule 2520, 13.2] Federally Enforceable Through ermit

CONDIT' 11-273442-10: Owl 2Z14 leVONI.E00EXILR

Conditions for S-2234-52-10 (continued) Page 6 of 6 66. Operator shall install, operate and maintain in calibration a system which continuously measures and records: control

system operating parameters, elapsed time of operation, the exhaust gas NOx and 02 concentrations. [40 CFR 60.334(a),(b)] Federally Enforceable Through Title V Permit

67. A violation of NOx emission standards indicated by the NOx PEMS shall be.reported by the operator to the APCO within 96 hours. [District Rule 1080, 9.0] Federally Enforceable Through Title V Permit


69. Operator shall notify the APCO no later than eight hours after the detection of a breakdown of the PEMS. Operator shall inform the APCO 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

70. Operators of PEMS installed at the direction of the APCO shall submit a written report for each calendar quarter to the APCO. The report is due on the 30th day following the end of the calendar quarter and shall include: A. time intervals, data and magnitude of excess emissions, nature and cause of excess.(if known), corrective.actions taken and preventive measures adopted; B. 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; C. applicable time.and date of each period during which the PEMS was inoperative (except for zero and span checks) and the nature of system repairs and adjustments; D. a negative declaration when no excess emissions occurred. [District Rule 1080, 8.0] Federally Enforceable Through Title V Permit

71. NOx and carbon monoxide daily emissions shall be measured by use of PEM data, fuel rate data, and daily hours of operation data. A written record.of the required compliance.demonstrations shall be maintained and made available for District inspection for a period of five years. [District Rule 2201] Federally Enforceable Through Title V Permit

72. 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 reduced loadperiods, total hours of operation and quantity of fuel used. [District Rule 4703] Federally Enforceable Through Title V Permit

73. The owner or operator shall maintain records that contain the following: the occurrence and duration of any start-up, shutdown or malfunction, performance testing, evaluations, calibrations, checks, adjustments, any periods during which a continuous monitoring system or monitoring device is inoperative, maintenance of any PEM system that has been installed pursuant to District Rule 1080, and emission measurements. [District Rules 1080 and 4703 and 40 CFR 60:8(d)] Federally Enforceable Through Title V Permit

74. All records required to be maintained by this permit shall be maintained for a period of at least five years and shall be made readily available for District inspection upon request. [District Rules 2201 and 4703] Federally Enforceable Through Title V Permit

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AUTHORITY TO CONSTRUCT PERMIT NO: S-2234-53-8 ISSU LEGAL OWNER OR OPERATOR: CALIFORNIA RESOURCES ELK HILLS, LLC MAILING ADDRESS: PO BOX 1001

TUPMAN, CA 93276 LOCATION: GAS PLANT

SECTION SE-35, T-30S, R-23E TUPMAN, CA


EQUIPMENT DESCRIPTION: MODIFICATION OF ONE 24.5 MW NATURAL GAS-FIRED GAS TURBINE COGENERATION SYSTEM, INCLUDING 250 MMBTU/HR GENERAL ELECTRIC MODEL LM-2500 GAS TURBINE, 103 MMBTU/HR DUCT BURNER ASSEMBLY, AND 150,000 LB/HR HEAT RECOVERY STEAM GENERATOR: REPLACE CEMS WITH 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. All equipment shall be maintained and operated according to manufacturers' recommendations. [District Rule 2201] Federally Enforceable Through Title V Permit


CONDITIONS CONTINUE ON NEXT PAGE YOU MUS7 NOTIFY THE DISTRICT COMPLIANCE DIVISION AT (601) 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 deterrnlne 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.

Seyed Sadredin, Exsai4iv0111 PCO

Arnaud Madolletr0Inictor of Permit Services II-2234434: CM 2 2011 111/41—EDOEHLR Jolot Impede.. PAT Mowry.,

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

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Conditions for S-2234-53-8 (continued) Page 2 of 6 5. 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)]

6. Gas turbine engine and duct burner assembly shall be equipped with continuously recording fuel gas flowmeters. [District Rule 22011 Federally Enforceable Through Title V Permit




10. Except during periods of gas turbine engine startup/shutdown, gas turbine engine steam injection rate shall be maintained at steam-to-fuel ratio range documented to result in compliance with emission limits. [District Rule 2201] Federally Enforceable Through Title V Permit

11. All exhaust from gas turbine engine and duct burners shall flow through both SCR and oxidation catalyst beds. [District Rule 2201] Federally Enforceable Through Title V Permit





16. Except during periods of gas turbine engine•startup/shutdown, gas turbine engine shall be shut down if steam injection or SCR system is inoperative. [District Rule 2201] Federally Enforceable Through Title V Permit


18. Excess emissions shall be defined as any operating hour in which 4-hour rolling average NOx concentration exceeds applicable emissions limit and a period of monitor downtime shall be any unit operating hour in which sufficient data are not obtained to validate the hour for either NOx or 02 (or both). [40 CFR 60.334(J)(1)(iii)] Federally Enforceable Through Title V Permit


et2346141 Des 2 2014 111AM - EDOEHLIt



21. Primary Re-ignition Period shall be defined as the duration of time during which a gas turbine is operated at less than rated capacity in order to reset the DLN combustion system following a primary re-ignition, provided all of the following conditions are met: a) The duration of a primary re-ignition period shall not exceed one hour; b) NOx emissions shall not exceed 15 ppmvd, corrected at 15% 02, averaged over one (1) hour; and c) CO emissions shall not exceed 25 ppmvd, corrected at 15% 02. [District Rule 4703, 3.20] Federally Enforceable Through Title V Permit




25. Maximum emissions from turbines S-2234-52 & -53 and standby boilers/heaters S-2234-1 & -3 shall not exceed the following daily emission limitations (DEL): PM10: 50.6 lb/day, NOx (as NO2): 245.7 lb/day, VOC: 51.4 lb/day, and CO: 544.6 lb/day. [District Rule 22011 Federally Enforceable Through Title V Permit

26. During days of gas turbine startup/shutdown, daily NO2 and CO emissions shall be calculated by natural gas consumption rates, PEMS results, and emission factors for standby boilers/heaters. [District Rule 2201] Federally Enforceable Through Title V Permit



29. Permittee shall maintain accurate records of PEMS predicted NOx and CO emissions, and daily natural gas consumption in gas turbine & duct burners, and shall make such records readily available for District inspection upon request. [District Rule 2201] Federally Enforceable Through Title V Permit




33. PM10 and VOC emissions from lube oil vent shall be measured by source testing within 60 days upon detection of visible emissions in excess of 5% opacity or Ringeimann 1/4 from gas turbine lube oil vent. [District Rule 2201] Federally Enforceable Through Title V Permit

34. Except during periods of startup/shutdown, emission rates (3-hr rolling average) from gas turbine combustion shall not exceed: PM10: 0.004 lb/MMBtu, NOx as NO2: 0.013 lb/M Btiq& 3.75 ppmvd ® 15% 02, VOC: 0.004 lb/MMBtu, and CO: 0.043 lb/MMBtu. [District Rules 2201 alisk47 ] y Enforceable Through Title V Permit

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Conditions for S-2234-53-8 (continued) Page 4 of 8 35. Except during periods of startup/shutdown, emission rates (3-hr rolling average) from duct burner combustion shall not

exceed: PM10: 0.001 lb/MMBtu, NOx as NO2: 0.008 lb/MMBtu, VOC: 0.001 lb/MMBtu, and CO: 0.007 lb/MMBtu. [District Rule 2201] Federally Enforceable Through Title V Permit

36. NOx, VOC, CO, and ammonia emissions shall be measured by source testing annually. [District Rule 2201] Federally Enforceable Through Title V Permit






42. Gas turbine.shall be equipped with turbine combustor steam injection system, selective catalytic reduction (SCR) with ammonia injection, and oxidation catalyst system. [District Rule 2201] Federally Enforceable Through Title V Permit

43. Unit shall be fired exclusively on PUC-quality natural gas which has a sulfur content of less than or equal to 0.0034% by weight. [40 CFR 60.333(a) & (b)] Federally Enforceable Through Title V Permit




47. If the turbine is not fired on PUC-regulated natural gas, then the sulfur content (as hydrogen sulfide) of the natural gas being fired in the turbine shall be calculated using a continuous monitor averaged over a daily basis in accordance with SCAQMD Rule 431.1 Attachment A (as amended June 12, 1998). [District Rule 2520, 9.3.2,40 CFR 60.335(d)] Federally Enforceable Through Title V Permit


49. The 1-IHV and L1-IV of the fuel shall be determined using ASTM D3588-91, ASTM 1826-88, OR ASTM 1945-81. [40 CFR 60.332(a),(b) and District Rule 4703, 6.4.5] Federally Enforceable Through Title V Permit


51. The PEMS shall complete a minimum of one cycle of operation (sampling, analyzing, and date recording) for each successive 15-minute period or shall meet equivalent specifications established by mutual agreement of the District, the ARB, and the EPA. [40 CFR 60.334(b)FSand District Ru19.18131, 6.4] Federally Enforceable Through Title V Permit

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52. Results of the PEMS system shall be averaged over a three hour period, using consecutive 15-minute sampling periods in accordance with all applicable requirements of CFR 60.13. [40 CFR 60.13 and District Rule 4703, 5.1, 6.4] Federally Enforceable Through Title V Permit


54. The NOx 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

55. 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

56. Records shall be maintained and shall contain: the occurrence and duration of any start-up, shutdown, performance testing, evaluations, calibrations, checks, adjustments, any periods during which a continuous monitoring system or monitoring device is inoperative, maintenance of any PEMS that have been installed pursuant to District Rule 1080, and emission measurements. [District Rules 1080, 7.3, and 4703, 6.2.8, and 40 CFR 60.7 (b)] Federally Enforceable Through Title V Permit




60. Results of PEMs must be averaged in accordance with the requirements of 40 CFR 60.13. [40 CFR 60.334(a),(b),(c) and District Rule 4703, 5.0] Federally Enforceable Through Title V Permit



• 63. Compliance with permit conditions in the Title V permit shall be deemed compliance with the following applicable requirements: SJVUAPCD Rule 4201, 1081 and 1080, Sections 6.5, 7.2, 8.0, 9.0, and 10.0; 40 CFR 60.332(c) and (d); 60.334(b) and (c)(2); 60.335(d). A permit shield is granted from these requirements. [District Rule 2520, 13.2] Federally Enforceable Through Title V Permit


65. Compliance with permit conditions in the Title V permit shall be deemed compliance with the following subsumed requirements: 40 CFR 60.332(a), (b); 60.335(a), (b), (c), and (e). A permit shield is granted from these requirements. [District Rule 2520, 13.2] Federally Enforceable Through ermit

CONDITI 0-fl3434 : 003 231.1 - EOGENLA

Conditions for S-2234-53-8 (continued) Page 6 of 6 66. Operator shall install, operate and maintain in calibration a system which continuously measures and records: control

system operating parameters, elapsed time of operation, the exhaust gas NOx and 02 concentrations. [40 CFR 60.334(a),(b)] Federally Enforceable Through Title V Permit

67. A violation of NOx emission standards indicated by the NOx PEMS shall be reported by the operator to the APCO within 96 hours. [District Rule 1080, 9.0] Federally Enforceable Through Title V Permit


69. Operator shall notify the APCO no later than eight hours after the detection of a breakdown of the PEMS. Operator shall inform the APCO 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

70. Operators of PEMS installed at the direction of the APCO shall submit a written report for each calendar quarter to the APCO. The report is due on the 30th day following the end of the calendar quarter and shall include: A. time intervals, data and magnitude of excess emissions, nature and cause of excess (if known), corrective actions taken and preventive measures adopted; B. 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; C. applicable time and date of each period during which the PEMS was inoperative (except for zero and span checks) and the nature of system repairs and adjustments; D. a negative declaration when no excess emissions occurred. [District Rule 1080, 8.0] Federally Enforceable Through Title V Permit

71. NOx and carbon monoxide daily emissions shall be measured by use of PEM data, fuel rate data, and daily hours of operation data. A written record of the required compliance demonstrations shall be maintained and made available for District inspection for a period of five years. [District Rule 2201] Federally Enforceable Through Title V Permit

72. 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 reduced load periods, total hours of operation and quantity of fuel used. [District Rule 4703] Federally Enforceable Through Title V Permit

73. The owner or operator shall maintain records that contain the following: the occurrence and duration of any start-up, shutdown or malfunction, performance testing, evaluations, calibrations, checks, adjustments, any periods during which a continuous monitoring system or monitoring device is inoperative, maintenance of any PEM system that has been installed pursuant to District Rule 1080, and emission measurements. [District Rules 1080 and 4703 and 40 CFR 60.8(d)] Federally Enforceable Through Title V Permit

74. All records required to be maintained by this permit shall be maintained for a period of at least five years and shall be made readily available for District inspection upon request. [District Rules 2201 and 4703] Federally Enforceable Through Title V Permit

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