g

GER-4213

GE Power Systems

Support for Elimination of Oxidation

Catalyst Requirements
for
GE PG7241FA DLN Combustion Turbines

Brahim Richani, Ph.D.

Manager, Environmental and Acoustic Engineering
GE Power Systems
Joel Chalfin
Manager, GT/CC Environmental Compliance
GE Power Systems
White Paper (August 2001)

SUPPORT FOR ELIMINATION OF OXIDATION CATALYST REQUIREMENTS

FOR GE PG7241FA DLN COMBUSTION TURBINES

Applicability
This position paper applies to GE PG7241FA
combustion turbines with DLN combustors firing natural gas and located in all attainment
areas and ozone non-attainment areas. For all
other GE heavy-duty frame machines, owners
are advised to contact their GE Power Systems
sales representative for information regarding
oxidation catalysts and related requirements.

Abstract
Emissions regulatory requirements have
become more stringent for combustion turbines (CTs), generally requiring installation of
post-combustion controls regardless of uncontrolled emission levels, plant location, costs,
process feasibility, or resulting environmental
impacts. Federal and state regulatory agencies
have sought to justify post-combustion controls
primarily on the grounds that some existing
installations are currently using oxidation catalysts for carbon monoxide (CO) control.
However, a one-size-fits-all approach, where
all units are required to install a particular technology without consideration of individualized
factors, is in direct conflict with the Clean Air
Act (CAA) Best Available Control Technology
(BACT) analysis procedures and requirements.
The BACT analysis for CO (or any criteria pollutant) must weigh a variety of factors including
energy, environmental and economic impacts.
Dry Low NOx (DLN) combustors for GE
PG7241FA combustion turbines are now
demonstrating uncontrolled CO emissions in a
range so low that the requirement to add an
oxidation catalyst on these units will only serve
to reduce efficiency and output; produce negative environmental impacts; and, in light of the
measured data, will not yield detectable CO

emissions reduction benefits under normal

operating conditions.
The comparison with existing installations
using CO catalysts appears to be the primary
factor influencing regulatory agencies to insist
on the installation of oxidation catalysts on all
combustion turbine units. However, two additional factors are also considered in this paper;
the impetus for expedited permitting, and the
anticipated federal regulation for hazardous air
pollutant (HAP) emissions from combustion
turbines.
The objective of this paper is to demonstrate
that the installation of an oxidation catalyst to
achieve lower CO levels from GE PG7241FA
DLN combustion turbines sited in CO attainment areas and ozone non-attainment areas
should not be required by state, local, and/or
federal regulatory agencies. The addition of
oxidation catalysts to these units results in minimal CO emissions reduction, adds unnecessary
costs, and produces negative environmental
impacts.

1.0 Introduction
State and federal regulatory agencies are requiring oxidation catalysts as BACT on combustion
turbines in an attempt to achieve lower CO
emissions. Such requirements are making it difficult for owners to avoid the installation of oxidation catalysts as add-on controls, regardless of
the uncontrolled CO emissions levels. The regulatory-mandated BACT process is being circumvented and U.S. EPAs own BACT guidance
is being ignored. The Clean Air Act clearly
requires that a BACT determination be conducted on a case-by-case basis; however it
appears that in many cases the regulatory agencies are influencing applicants control technol-

GER-4213 GE Power Systems White Paper August 2001

Page 1

SUPPORT FOR ELIMINATION OF OXIDATION CATALYST REQUIREMENTS

FOR GE PG7241FA DLN COMBUSTION TURBINES

ogy choices and their BACT determination

based on the following factors:
Existing installations of various manufacturers units that are using CO catalysts (i.e.,
presumptive BACT)
Applicants demands for an expedited permitting process
Currently nonexistent, but anticipated,
Maximum Achievable Control Technology
(MACT) requirements for HAPS
Consequently, the regulatory agencies appear
to be excluding other important factors in their
BACT determinations, such as:
Cost effectiveness and feasibility of control
Evaluation of collateral environmental
impacts
Evaluation of expected CO emissions on
public health
GE PG7241FA DLN natural gas-fired combustion turbines have consistently demonstrated
uncontrolled CO emissions below 9 parts per
million by volume dry (ppmvd) at base load. A
requirement to add an oxidation catalyst to a
GE PG7241FA DLN combustion turbine with
single digit CO emissions will reduce efficiency
and output, and produce negative environmental consequences while yielding insignificant
(<1 ppm) reduction in CO emissions under
normal operating conditions. For areas designated as attainment for carbon monoxide, it
becomes critical that the BACT analysis for CO
includes environmental, cost effectiveness, and
potential health impacts. The following provides justification of why BACT determinations
for CO emissions for GEs PG7241FA DLN units
should result in a conclusion of No Add-on
Controls.

2.0 Existing Installations

A review of existing CT installations located in
attainment areas which are using oxidation catalysts indicates that uncontrolled CO emission
levels from these units are much higher than
the demonstrated emission levels from GEs
PG7241FA DLN combustion turbines. The
existing installations reviewed have uncontrolled CO emission rates in the range of 15 to
25 ppmvd, while GEs PG7241FA DLNs have
demonstrated uncontrolled CO levels of less
than 5 ppmvd. When post-combustion control,
such as an oxidation catalyst, is added to the
higher emitting units, the resulting CO level
achieved and permitted is approximately
5 ppmvd. This emission rate is consistently
achieved by the GE PG7241FA DLN units, without any add-on controls.
In ozone non-attainment areas, an additional
consideration is Volatile Organic Compounds
(VOC) emissions. Oxidation catalysts can be
used to reduce VOC emissions from CTs.
However, GE PG7241FA DLN units produce no
measurable quantities of VOC emissions, and
the guaranteed VOC emission rate of GE
7241FA is consistent with the lowest achievable
emission rate (LAER) without any add-on controls.
Given these facts, it seems clear that recent EPA
BACT decisions requiring add-on controls for
CO emissions on GE PG7241FA DLN units have
been made without undertaking a case-by-case
BACT analysis as required by the CAA. In addition, it appears that EPAs determination has, in
many cases, ignored the results of cost-effectiveness analyses and collateral environmental
impacts. These will be discussed in the following
sections.

GER-4213 GE Power Systems White Paper August 2001

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SUPPORT FOR ELIMINATION OF OXIDATION CATALYST REQUIREMENTS

FOR GE PG7241FA DLN COMBUSTION TURBINES

3.0 Expedited Permitting Process

The demand to increase electric power supply
availability in the U.S. is at an all-time high. In
2001, some states experienced rotating power
blackouts (e.g., CA) and others (e.g., NY) were
expected to follow suit because of the increased
energy demand and the limited number of new
power plants permitted and built in the deregulated market. As a result of the need for
immediate energy supplies, incomplete or inadequate BACT analyses are conducted in order
to expedite the permitting process. The result is
that BACT has essentially become an automatic
requirement for an oxidation catalyst for CO
emissions reduction for future projects.

4.0 Upcoming MACT Requirements

for HAPS
Some state and local regulatory agencies are
using the soon-to-be-proposed U.S. EPA
Maximum Achievable Control Technology standard intended for the reduction of hazardous
air pollutants (primarily formaldehyde) from
combustion turbines as the basis for requiring
oxidation catalysts. As of August 2001, when this
paper was drafted, the MACT rule for combustion turbines had not yet been proposed.
However, EPA has provided some information
on what the rule would require through industry meetings and communications. According
to the EPA, all new combustion turbines will
likely be required to install an oxidation catalyst
to reduce hazardous air pollutants (HAPs),
unless a formaldehyde emission level of less
than 25 parts per billion by volume, dry
(ppbvd) corrected to 15% O2 is achieved. For
combustion turbines achieving less than 25
ppbvd @ 15% O2 of formaldehyde, the MACT
requirement is expected to be No Additional
Control.

On August 21, 2001, EPA issued a memorandum indicating, HAP emissions from lean premix stationary combustion turbines are equivalent or lower than HAP emissions from diffusion flame stationary combustion turbines
equipped with oxidation catalyst systems. Thus,
lean premix combustion is a comparable technology to oxidation catalyst systems.
Additionally, GE has tested and provided EPA
with formaldehyde emissions data using
California Air Resources Board (CARB)
Method 430 from two GE PG7241FA DLN natural gas-fired turbines. The test results demonstrate that the uncontrolled formaldehyde emissions when blank corrected (corrected for the
background levels associated with the sampling
train) are typically below 25 ppbvd @ 15% O2.
Therefore, based on the blank corrected measurements, GEs PG7241FA DLN units may not
be subject to the upcoming MACT regulation
and an oxidation catalyst would not be required
for MACT compliance.

5.0 Cost Effectiveness

Inconsistent implementation of BACT across
EPA regions will occur if cost of control and the
resulting cost-effectiveness levels are not evaluated. As indicated in Table 1, dollars-per-ton
cost effectiveness analyses as low as $2,055 per
ton (Newington Energy in New Hampshire)
have resulted in a decision that no oxidation
catalyst is required for CO from gas combustors
with emissions of 15 ppmvd. These figures conflict directly with a recent (2000) decision by
EPA Region II that $6,000 per ton (Heritage
Station, 7H project in Oswego, NY) is considered cost effective for CO control in attainment
areas. The lack of uniform EPA guidance
regarding cost effectiveness determinations is
causing inconsistencies in BACT determinations across the country.

GER-4213 GE Power Systems White Paper August 2001

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SUPPORT FOR ELIMINATION OF OXIDATION CATALYST REQUIREMENTS

FOR GE PG7241FA DLN COMBUSTION TURBINES
Final CO
Final
CO
Cost
Catalytic
Catalytic
BACT
BACT
EffectiveOxidation
Oxidation
based on
Based
on
ness
System
Natural
System
Cost
Eff.
Natural
($/ton)
Gas
Required
Required
($/ton)
Gas

Model

Type
of
Type of
Operation
Operation

Westbrook
Pwr/ME

PG7241FA

Combined
Cycle

No

>$3,000

15 ppmv

Newington
Energy/NH
EMI Tiverton/RI

PG7241FA

No

$2,055

15 ppmv

No

$7,400

12 ppmv

2/98

RockGen Energy/
WI
SEI/WI

PG7241FA

No

$15,780

12 ppmv

1/99

No

$14,000

12 ppmv

2/99

Tenaska Georgia
Ptnrs/GA
PeopleGas
People Gasand
and
Light, McDonnell
Energy/IL

PG7241FA

Combined
Cycle
Combined
Cycle
Simple
Cycle
Simple
Cycle
Simple
Cycle
Combined
and Simple
Cycle

No

$2,300

15 ppmv

12/98

No

$3,043
$17,000

0.03
0.03
lb/mmBtu
lb/mm
Btu

1/99

Source/State

Source/State

Model

PG7241FA

PG7241FA

PG7241FA

Issuance

Issuance
Draft Findings
findings of
Draft
of
Fact and Order
(12/98)
4/99

Table 1. Cost Effectiveness Levels for Recently Permitted Sites

GEs data collected to date on GE PG7241FA
DLN combustion turbines indicate CO levels
below 2 ppmvd at various loads. (See Figure 1).
These data suggest that the addition of
oxidation catalysts to GEs PG7241FA DLN
units will result in less than 1 ppm CO reduction on an average basis. Such reductions will
yield unjustifiably high cost per ton of CO controlled.

To demonstrate that GEs PG7241FA DLN units

should not require add-on controls for BACT
determinations, cost effectiveness calculations
are presented in Figure 2.
These cost estimates are based on 1st Quarter,
2001, gathered information from two leading
catalyst manufacturers (Englehard & Johnson
Matthey). As shown in Figure 2, the requirement
for an oxidation catalyst would not be cost effec-

GE PG7241FA CT Units

2.0
1.8

# of Data Sets
Included for:

Max

1.6

50%
60%
75%
80%
85%
90%
Baseload

CO, ppm

1.4
1.2
1.0

7
1
9
4
6
2
12

0.8
0.6

Slope = 0.09

0.4

Min

0.2
0

50

60

70

80

90

100

Load Size (Percent)

Figure 1. Average Raw CO Emissions vs. Load Size (Percent)

GER-4213 GE Power Systems White Paper August 2001

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SUPPORT FOR ELIMINATION OF OXIDATION CATALYST REQUIREMENTS

FOR GE PG7241FA DLN COMBUSTION TURBINES

erations, GE is offering CO guarantees of 5

ppmvd for the GE PG7241FA DLN on a case-bycase basis following a detailed evaluation of the
situationthus validating its position that oxidation catalysts are not economically justified
for CO emissions reduction for the GE
PG7241FA DLN units while firing natural gas.

tive for units with (uncontrolled) CO levels

slightly less than 7 ppmvd, based on the $6,000
per ton identified by EPA-Region II.
GEs CO guarantee is meant to accommodate
operating conditions at all permitted ambient
conditions and has a small margin to account
for measurement error and machine and fuel
variations. Generally for CO, extremely cold
ambient conditions, concurrent with part load
combustion turbine operations, will represent
the worst-case emissions. GEs PG7241FA DLN
turbine is one of the lowest emitting operating
combustion turbines in simple cycle and combined cycle systems. Consequently, GEs analysis
shows that the CO emission levels from these
combustion turbines can be tuned to be below
5 ppmvd. For any emission level below 5 ppmvd,
the cost effectiveness will be greater than $8,000
per ton of CO removed. Based on these consid-

6.0 Other Environmental Impacts

Use of oxidation catalysts to control CO emissions from GE PG7241FA DLN combustion turbines produces collateral impacts that are environmentally detrimental. A BACT analysis, by its
definition, must include consideration of collateral environmental impacts. The EPA must consider the severity and resulting expense of these
impacts when requiring controls for combustion
turbines like GEs PG7241FA DLN machines. In
this case, nitric oxide (NO) and sulfur dioxide

GE PG7241FA CT Units
$20,000
Total Annual Cost estimates based on OAQPS Control
Cost Manual - Fifth Edition (EPA 453/b-96-001) Chapter 2, Cost Estimating Methodology with the
following exceptions:

$18,000
$16,000

Contingencies equal 0.1 x (Total Direct

Cost + Total Indirect Cost) instead of
0.03 x Purchased Equipment Cost
Based on GE Data

$/ton CO removed

$14,000
$12,000

Performance Test Cost equals $5,000

in all cases instead of 0.01 x Purchased
Equipment Cost because the Performance
Test Cost is not dependent on Catalyst Cost

$10,000
$8,000
$6,000

EPA Region II BACT Guidance

$4,000
$2,000
$0
0

10

15

20

25

CO, ppm

Figure 2. Cost Effectiveness of Oxidation Catalysts

GER-4213 GE Power Systems White Paper August 2001

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SUPPORT FOR ELIMINATION OF OXIDATION CATALYST REQUIREMENTS

FOR GE PG7241FA DLN COMBUSTION TURBINES

(SO2) present in the exhaust will be oxidized by

add-on catalysts to nitrogen dioxide (NO2) and
sulfur trioxide (SO3), both of which promote the
formation of acid rain. In addition, if applied in
combination with selective catalytic reduction
(SCR) for the control of nitrogen oxides (NOx),
ammonium salts formed as a result of ammonia
(NH3) slip and SO3 will result in additional generation of PM10 (particulate matter less than 10
microns in diameter) and accelerated corrosion
of the heat recovery steam generator (HRSG).
The EPA identified this issue in its August 4,
2000, draft guidance Consideration of
Collateral Environmental Impacts Associated
with the Use of SCR on Dry Low NOx Combined
Cycle Gas Turbines, by John S. Sietz, Director,
Office of Air Quality Planning and Standards
(OAQPS). Finally, additional carbon dioxide
(CO2) will be generated due to the output and
efficiency losses associated with the pressure
drop of the catalyst.

7.0 CO as a Public Health Concern

According to a health risks study conducted by
toxicologist R.A. Michaels in a May 2001 report
(Carbon Monoxide Catalysis: Assessment of Need to
Mitigate Public Health Risks Posed by Acute and
Chronic Exposure to CO Emitted by Combined Cycle
Natural Gas Turbines; R.A. Michaels, Ph.D.,
C.E.P., RAM TRAC Corporation, May 21, 2001),
Ground level CO concentrations arising from
combined cycle natural gas turbines were found
to be below conservative standards and guidelines limiting human exposure to airborne CO.
CO also was found to be below concentrations
posing acute or chronic exposure risks to public health. These findings support the conclusion in the report that public health concerns do
not justify requiring natural gas power generators to
be equipped with CO catalysis to reduce ground

level CO impacts. The health risks study was

based on analysis of a CO emission rate of 9
ppmvd, which, as stated previously, is significantly higher than the uncontrolled emissions
from GE's PG7241FA DLN combustion turbines
firing natural gas.
The following excerpt from page 23 of the RAM
TRAC report summarizes the important conclusion that CO catalysts do nothing to improve
public health:
Risks posed to public health are quantified
in this report to be zero, with or without CO catalysts. Indeed, this report reveals that ground
level impacts of combined cycle natural gas turbines as modeled by GE are far from impacts
which would be required to elicit adverse public
health effects. Modeled turbine impacts would
have to be increased by over an order of magnitude to elicit adverse effects associated herein
with acute or chronic exposure to CO.
In summary, the CO ground level concentrations (GLCs) resultant from the use of the GE
PG7241FA DLN are insignificant when compared to the National Ambient Air Quality
Standards (NAAQS). The NAAQS are referenced in Appendix A.

8.0 Other Considerations

Use of an oxidation catalyst reduces system efficiency and output. System inefficiencies and
output losses, in turn, will result in an increase
in emissions. Due to the increase in pressure
drop associated with the oxidation catalyst in
the exhaust gas path, output (MW) will
decrease and heat rate (Btu/kWh) will
increase. Since combustion turbines are recognized as the least polluting combustion sources
to generate electricity, any attempt to make up
the energy losses will increase emissions.

GER-4213 GE Power Systems White Paper August 2001

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SUPPORT FOR ELIMINATION OF OXIDATION CATALYST REQUIREMENTS

FOR GE PG7241FA DLN COMBUSTION TURBINES

The installation and use of an oxidation catalyst

will increase the cost of the electricity (COE)
produced. With oxidation catalyst requirements
on a new PG7241FA DLN combustion turbine,
the added capital and operating costs of the
catalyst will be absorbed and paid for by the
consumer. Fewer new combined cycle plants
will be built due to the high COE resulting from
increased capital cost and operation and maintenance costs; and thus less electricity will be
generated from new plants. Therefore, total CO
emissions will not decrease as rapidly, as a result
of the addition of new plants. Emissions of acid
rain pollutants and fine particulate matter,
NOx, SO2, CO2, and mercury emissions will
remain at current levels due to continued operation of existing coal plants.
The use of an oxidation catalyst creates heavy
metal wastes. Oxidation catalyst materials contain heavy metal oxides such as platinum and
palladium, which are considered hazardous
substances by the EPA. Handling, maintenance,
cleaning, and disposal of the spent catalyst ele-

ments are potentially harmful to humans and

the environment. In addition, spent catalyst elements are considered hazardous waste, thus
transferring an air emission issue into a longterm solid waste disposal problem. When
applied in combination with SCR, additional
salt formation will occur. Ammonia salts
cleaned from HRSGs are also wastes, which will
need to be disposed of accordingly.

9.0 Summary
In summary, the use of an oxidation catalyst to
control CO emissions from GEs PG7241FA
DLN combustion turbines will result in insignificant (< 1 ppm) reduction of CO and will not
substantially reduce ambient CO levels since
minimal CO is emitted under normal operating
conditions. The application of an oxidation catalyst on GE PG7241FA DLN combustion turbines firing natural gas in simple cycle and combined cycle plants cannot be justified on a cost
(per ton of CO removed) basis.

GER-4213 GE Power Systems White Paper August 2001

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SUPPORT FOR ELIMINATION OF OXIDATION CATALYST REQUIREMENTS

FOR GE PG7241FA DLN COMBUSTION TURBINES

Appendix A. Summary of National Ambient Air Quality Standards (NAAQS)1

Pollutant
Carbon monoxide

Averaging
Time

NAAQS (mg/m3 )
Primary
Secondary

8-hour
1-hour

10,000
40,000

Calendar quarter

Nitrogen dioxide

ppm

None
None

9
35

1.5

Same as primary

Annual

100

Same as primary

0.053

Ozone 2

1-hour

235

Same as primary

0.12

PM-10

Annual
24-hour

50
150

Same as primary
Same as primary

PM-2.5

Annual
24-hour

15
65

Same as primary
Same as primary

Sulfur dioxide

Annual
24-hour
3-hour

80
365
None

Lead

None
None
1300

0.03
0.14
0.50

1 National standards, other than those based on annual averages, are not to be exceeded more than once a year (except
where noted).

2 The ozone standard is attained when the expected number of days per calendar year in which the maximum hourly
average concentration is above the standard is equal to or less than one.
Source: Code of Federal Regulations, 40 CFR 50.4-50.12.

List of Tables
Table 1. Cost Effectiveness Levels for Recently Permitted Sites

List of Figures
Figure 1. Average Raw CO Emissions vs. Load Size (Percent)
Figure 2. Cost Effectiveness of Oxidation Catalysts

GER-4213 GE Power Systems White Paper August 2001

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