PERMIT HANDBOOK

2.4.1 MicroTurbines (25-500 KW)

by M.K. Carol Lee
August 6, 2008
Process Description
This chapter is limited to microturbines firing natural gas. Microturbines are small combustion turbines
that produce between 25 kW and 500 kW of power.
A thorough explanation of general turbine technology is available from Chapter 3.1 (Stationary Gas
Turbines) of AP-42 (Fifth Edition, Volume I). In addition, explanation of microturbine technology is
available from the California Energy Commissions California Distributed Energy Resource Guide.
Any turbine with a maximum output rating greater than 50 hp is subject to permitting requirements per
Regulation 2-1-114.2.1. However, if the turbine is used solely for instructional purposes at research,
teaching, or educational facilities, they may be exempt for Regulation 2-1-114.2.2.
Completeness Determination
The following District forms should be completed and fees provided for the microturbines. Use the
Completeness Determination Checklist to verify completeness. Use the Data Form Guidance to ensure that
the forms are completed correctly. Use the Fee Calculation Guidance to ensure that the fees are calculated
accurately.
1. Form 101-B (one for facility).
4. If Health Risk Screening is triggered, Form
2. Form C (one per source).
HRSA (one per source).
3. If combustion products exhaust into add-on
5. Fees, calculated per Regulation 3 (Schedule B).
abatement device, Form A (one per device).
Emission Calculations
The ideal hydrocarbon products of combustion in which a fossil fuel is burned are water vapor and carbon
dioxide. All other products are considered pollutants, consisting mainly of NOx (Nitrogen Oxides), CO
(Carbon Monoxide), POC (Precursor Organic Compounds in the form of unburned hydrocarbons), SOx
(Sulfur Dioxide), and PM10 (Particulate Matter).
Emission factors of criteria pollutants from turbines are usually based on California Air Resources Board
(CARB) certified data for Distributed Generation for nitrogen oxides (NOx), carbon monoxide (CO), and
precursor organic carbons (POC). Based on maximum Pacific Gas & Electric Natural Gas Specification
for Sulfur of 1 grain per 100 standard cubic feet, PM10 (as (NH4)2SO4) and SO2 emission factors are
calculated. The NPOC emission factor is based on Table 3.1-2a of AP-42.

Compound
NOx
CO
POC
PM10
SO2
NPOC

Emission
Factor
***
***
***
5.78E-03
2.80E-03
8.90E-03

Unit
lb/MW-hr
lb/MW-hr
lb/MW-hr
lb/MMBtu
lb/MMBtu
lb/MMBtu

Reference
Distributed Generation Certification (ARB Executive Order DG-###)
Distributed Generation Certification (ARB Executive Order DG-###)
Distributed Generation Certification (ARB Executive Order DG-###)
Based on Max PG&E Natural Gas Specification for Sulfur of 1 gr/100 scf
Based on Max PG&E Natural Gas Specification for Sulfur of 1 gr/100 scf
AP-42 Table 3.1-2a (April, 2000)

Note:
*** = Based on Distributed Generation Certification data
PM10 = (1 gr/100 scf)(lb/7000 gr)(1/1020 BTU/scf)(1x10E6BTU/MMBTU)(132 lb (NH4)2SO4/32 lb S)
PM10 = 0.00578 lb/MMBTU
SO2 = (1 gr/100 scf)(lb/7000 gr)(1/1020 BTU/scf)(1x10E6BTU/MMBTU)(64 lb (NH4)2SO4/32 lb S)
SO2 = 0.00280

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Toxic Air Contaminant emissions from microturbines may be calculated using AP-42 Emission Factors
from Table 3.1 for Uncontrolled Emission Factors for Stationary Natural Gas Turbines, unless there is
actual source test data available.

Compound
1,3-Butadiene
Acetaldehyde
Acrolein
Benzene
Ethylbenzene
Formaldehyde
Naphthalene
PAH
Propylene Oxide
Toluene
Xylene

Emission
Factor
4.30E-07
4.00E-05
6.40E-06
1.20E-05
3.20E-05
7.1E-04
1.30E-06
2.20E-06
2.90E-05
1.30E-04
6.40E-05

Unit
Lb/MMBtu
Lb/MMBtu
Lb/MMBtu
Lb/MMBtu
Lb/MMBtu
Lb/MMBtu
Lb/MMBtu
Lb/MMBtu
Lb/MMBtu
Lb/MMBtu
Lb/MMBtu

Acute
Trigger
Level
(lb/hr)
None
None
4.2E-04
2.9E+00
None
2.1E-01
None
None
6.8E+00
8.2E+01
4.9E+01

Chronic
Trigger
Level
(lb/yr)
1.10E+00
6.40E+01
2.30E+00
6.40E+00
7.70E+04
3.00E+01
None
1.10E-02
4.90E+01
1.20E+04
2.70E+04

Applicable Requirements
District Rules and Regulations
A microturbine is not subject to the requirements of Regulation 9-9, per Regulation 9-9-110, because it
will typically have a power output less than 0.3 MW. A microturbine will be subject to and is expected to
comply with the SO2 ground level concentration and general emission limitations of Regulation 9-1,
because it will be fired on natural gas with a maximum sulfur content of 1 grain per 100 scf, which is the
maximum PG&E natural gas specification for sulfur.
New Source Performance Standards (NSPS)
All stationary gas turbines with a heat input at peak load equal to or greater than 10.7 gigajoules (10 million
Btu) per hour, based on the lower heating value of the fuel fired is subject to the Subpart GG of Part 60.
However, a microturbine will typically not have that high a heat input to subject it to NSPS requirements.
The permit engineer should review the microturbine application to confirm that the proposed microturbine
is exempt from the NSPS.
Best Available Control Technology (BACT)
In general, a microturbine which has a CARB Distributed Generation certification (i.e., Executive Order
DG-###) will not trigger a BACT review because criteria pollutant emissions will be less than 10 pounds
per operating day. The permit engineer should review the microturbine application to ensure that the
proposed microturbine does not trigger BACT review. If BACT is triggered, the permit engineer should
conduct a BACT determination to ensure that the source meets BACT requirements.
California Environmental Quality Act (CEQA)
Permit applications which are reviewed following the specific procedures, fixed standards and objective
measurements set forth in this chapter (2.4.1) are classified as ministerial and will accordingly be exempt
from CEQA review per Regulation 2-1-311.
In addition to the above-mentioned source-specific applicable requirements, other requirements may also
be applicable depending on the facility, its application emissions, and its source location:
Offsets
School Notification
Prevention of Significant Deterioration
Risk Screening Analysis

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Permit Conditions
As long as the microturbine has a CARB Distributed Generation certification (i.e., Executive Order DG###), there are no permit conditions required. Because emission calculations for each microturbine are
based upon 24 hour per day, 365 day per year operation, the permit will not require permit conditions to
limit fuel use or specify recordkeeping.

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