Avenal #08-SJ-01: Call reguarding initial/prelim observations 

Katherine Hoag to: ewalther 03/11/2008 08:54 AM

Cc: Shirley Rivera

SendDaerte Subject

Shirley03/07/2008Avenal #08-SJ-01: Info in PSD application & some initial/prelim observations Shirley Rivera 03/10/2008 10:04 AM Re: Avenal #08-SJ-01: Info in PSD application & som

Katherine Hoag 03/11/2008 08:54 AM Avenal #08-SJ-01: Call reguarding initial/prelim 

Hi Eric,

Here is a recap of our phone call yesterday, I will be keeping Shirley up to date on the issues we talked 

about.

First, you wanted us to be aware that you feel the key objective of the completeness determination should 

be focusing on finding the correct type of information we need for the permit, not the 'correctness' of the 

information

l CEC Data adequacy worksheets - You mentioned that you would send these once they were 

prepared. Could you let me know when you expect them to be completed?

l BACT - You and I didn't discuss the details of this point yesterday, and Shirley is still reviewing this 

with other Permit engineers to ensure consistency.

l PSD pollutant review/observation - You stated that the portion on page 6.2-20 that indicates that the 

project emissions are above the threshold for PM10 is from a previous submittal and no longer 

correct.

l SO2 (and SIL) - You and I discussed that the the 0.36 gr/100 scf S for the annual is a judgement call 

on your part based on previous projects in the San Joaquin Valley. We did not discuss what time 

perios this is based on.

l Fuel firing - You confirmed that the fire pump engine is the only thing running on diesel.

Natural gas specs and heat value - You mentioned that the values for the natural gas heat content 

of 1020 and 1060 Btu/scf were included in the project description as "wholistic" information and that 

the value of 1013 Btu/scf is the correct number derived from actual analyses.

Natural gas fired equipment - We didn't discuss this.

Diesel fuel-fired equipment - You mentioned that this emission factor was only used for the GHG 

emission calculations, and that the value of 139,000 Btu/gal may change by 2012.

l Startup/Shutdown (S/S) - You let us know that the startup emission values are larger than the 

expected shutdown emission values, so that it is a conservative upper bound to use the startup 

emission factors for both startup and shutdown. We also discussed that the values listed in Table 

6.2-1.6 and used in the calculations are from experience and not vendor data. 

l Transient load and short-term NOx emissions excursions - You confirmed that the "...proposed 
language for NOx emissions excursion language in the conditions of certification" ( p. 6.2-46) is for

the CEC's conditions for certifications, but also asked for the same language to be considered if we 

will be writing similar conditions for the PSD permit.

l VOC limit - You stated that the 1.5 ppmvd value (w/o duct firing) in Section 2 (p. 2-23) is not the 

correct and that the correct value is listed in section 6 as 1.4 ppmvd (e.g., p. 6.2-43, Table 6.2-19). 

You also mentioned that there might be other items in section 2 that are out of date.

Kate

_________________________

Katherine Hoag

U.S. EPA, Region 9, Air Permits Office (AIR-3)

75 Hawthorne St., San Francisco, CA 94105

Hoag.Katherine@epa.gov

(415) 972-3970

Shirley Rivera/R9/USEPA/US

Shirley 

Rivera/R9/USEPA/US

03/10/2008 09:04 AM

To ewalther@sierraresearch.com

cc Katherine Hoag/R9/USEPA/US@EPA

Subject Re: Avenal #08-SJ-01: Info in PSD application & some 

initial/prelim observations

Eric, 

Got your v/m msg earlier this morning. I would normally give you a quick call back but I've got to prepare 

for a conference call and a few other meetings/activities this morning. So for now, in response to your 

coall - 

a - Observations - At this point, there is **no need** to respond to each observation. They are **not** 

formal comments; they represent our on-going "once-through" page turn of the application, e.g., a quick 

review of info in the sections provided. Also, some are intended to be a "heads up", such as the 

observations regarding:

- BACT

- Startup/Shutdown

- Transient ops

At this point, we have not formally formulated or determined completeness; however, as mentioned, one 

of our objectives is to ensure consistency with other permit activities (past and present).

b - Follow-up today - Kate will give you a call back (916-444-6666). To some extent, she may be able to 

provide you with feedback. At this point, given she is supporting on project management and 

completeness review, at a minimum, she can provide you with some of the basis for our initial 

observations.

c - Going forward for completeness determination - We will continue to conduct our page turn. So you 

know, we have completed the once-through of the following sections and associated appendices:

- project description

- air quality

- public health

Therefore, the remaining sections that we are interpreting as you all's intent to support PSD application 
requirements for:

- Endangered Species Act, Section 7 (Section L of PSD app guidelines)

- Additional impacts analysis (Section H of PSD app guidelines)

. soils, vegetation, visibility

. general comercial, residential, industrial and other growth

- Additional information (Section M of PSD app guidelines)

. For other info provided, we will be identifying any items that we may want clarification 

for its inclusion

========

- Shirl

-------------------------------------------

Shirley F. Rivera

U.S. EPA, Region 9, Air Permits Office (AIR-3) | 75 Hawthorne St., San Francisco, CA 94105

T: (415) 972-3966 | F: (415) 947-3579 | Rivera.Shirley@epa.gov

Shirley Rivera/R9/USEPA/US

Shirley 

Rivera/R9/USEPA/US

03/07/2008 09:18 AM

To Eric Walther

cc Katherine Hoag/R9/USEPA/US@EPA

Subject Avenal #08-SJ-01: Info in PSD application & some 

initial/prelim observations

Eric,

Figured I'd just send a poke on a few things so far. And the below are just prelim/initial 

**OBSERVATIONS** as Kate and I go through our page turn.

l CEC Data adequacy worksheets: Although we did speak about there not being a formal/submitted 

filled-out data adequacy worksheet for the CEC sections you all provided as the PSD submittal, 

please do see if there is even a 'working copy' that is available for each of the sections submitted. For 

various reasons, this would make our review process. 

I've not sent this e/m request to Jim Rexroad given you are the project manager for the our PSD 

permit (i.e., air quality related issues in the CEC filing); I understand that TRC provided the balance of 

the CEC AFC, so if you determine it may be useful to check with Jim one last time, that would be 

great. We would use the worksheet for our streamlining our internal review process and would **not** 

distribute to others. 

And just as a reminder, this (attached) is our current application guideline.

[attachment "PSD Application Guidelines - October 2007.pdf" deleted by Shirley Rivera/R9/USEPA/US] 

Kate is establishing an in-house (for our in-use) review checklist based on this Oct 2007 document, as 

well as our potential "gap filling" for PSD project such has power plants - and in this case, as we 

discussed, those applications that are submitted from sections of a CEC AFC. 

l BACT - As I had mentioned, the last most recent application submittal for a combined-cycle facility is 

Kings River. The proposed limits in Kings River are "2-2-2" ppmvd for NOx, CO, and VOC (@ 15% 
O2. I am in discussions with the permit engineer for that application; as you and I have discussed, I

will be ensuring that my review is consistent with her review.

l PSD pollutant review/observation - Avenal's application states (p. 6.2-20, top section) that PSD 

thresholds exceeded for pollutants NO2, CO and PM10. However, on Page 6.2-69 (top section), there 

is reference that project "emissions of ... PM10 do not trigger PSD review." Table 6.2-32 on p. 6.2-27 

summarizes the TPY.

l SO2 (and SIL) - We see from the application the 1 gr/100 scf S content (tariff) referenced for 

short-term, while 0.36 gr/100 scf S for the annual. The natural gas properties are noted in Table 

6.2-18 (p. 6.2-42). On page 6.2-68, Table 6.2-34, there is reference to the comparison of modeled 

max and the SIL; it is noted that the table shoes SO2 values below the SIL. At this point, for my 

understanding regarding the natural gas properties (PG&E info), what is the time period of the 

"average" based, e.g., calendar year 2007, "xyz" month/year to month/year? (And I have reviewed 

Table 6.2-1.5 of the Appendix.) 

l Fuel firing - We note that both pipeline natural gas and Diesel fuel will be fired on equipment at the 

facility. 

Natural gas specs and heat value - In the project description (Section 2), there is a discussion of the 

natural gas supply (pp. 2-32, 2-33). Values (Btu/scf, HHV) presented include 1,060, 1,020, and 1,013. 

It is noted that "... supply will be from the "redundant sources of supply through the PG&E pipeline 

system" with the proposed properties (e.g., Tables 2.3-3, 6.2-18, and 6.2-1.5 (of Appendix 6.2).

Natural gas fired equipment - At this stage, we've not yet started a detailed review of the emission 

calculations. As a general comment, please ensure that the emission estimates are adjusted 

accordingly for the project Btu/scf (HHV), particularly if emission factors or vendor 

guarantees/estimates (or both) are based on a different natural gas heat value assumption.

Diesel fuel-fired equipment - There is reference to 139,000 Btu/gal, per the AP-42 emission factor. 

Similar to the comment re: natural gas fired equipment, if there is specifics regarding the potential 

Diesel fuel supplier and fuel specifications, please ensure that emission estimates are adjusted, if 

needed.

l Startup/Shutdown (S/S) - Other recent PSD applications for combined-cycle projects have included 

S/S information provided by the applicant to assist in our review and drafting of the technical support 

document (e.g., ambient air quality impact report, statement of basis) and permit. I note that p. 6.2-44 

presents a summary of the S/S emissions. I have been/am in discussions with other permit engineers 

regarding sufficiency of S/S information; as you and I have discussed, I will be ensuring that my 

review is consistent with others' reviews.

l Transient load and short-term NOx emissions excursions - It is noted that p. 6.2-46 includes 

"...proposed language for NOx emissions excursion language in the conditions of certification"; given 

this italicized section refers to a proposal for the CEC's conditions for certification, please confirm if 

this also is proposed for the EPA PSD permit application. 

l VOC - Although VOC is not a PSD pollutant, we noted that there was reference to a 1.5 ppmvd VOC 

limit (w/o duct firing) in Section 2 (p. 2-23); however, references in the Section 6.2 notes a 1.4 ppmvd 

VOC limit (e.g., p. 6.2-43, Table 6.2-19).

O.K. - as we continue along, I'll forward additional **observations**, which are, at this time, observations 

that may (or may not) be related to the upcoming comments. They are not intended to be formal 

comments. We will provide formal comments as part of the letter regarding our application completeness 

determination.

================
- Shirl

-------------------------------------------

Shirley F. Rivera

U.S. EPA, Region 9, Air Permits Office (AIR-3) | 75 Hawthorne St., San Francisco, CA 94105

T: (415) 972-3966 | F: (415) 947-3579 | Rivera.Shirley@epa.gov
Avenal #08-SJ-01: Call reguarding initial/prelim observations 

Katherine Hoag to: ewalther 03/11/2008 08:54 AM

Cc: Shirley Rivera

Shirley Rivera Avenal #08-SJ-01: Info in PSD application & some initial/prelim observations

Shirley Rivera Re: Avenal #08-SJ-01: Info in PSD application & some initial/prelim observations

Katherine Hoag Avenal #08-SJ-01: Call reguarding initial/prelim observations

Hi Eric,

Here is a recap of our phone call yesterday, I will be keeping Shirley up to date on the issues we talked 

about.

First, you wanted us to be aware that you feel the key objective of the completeness determination should 

be focusing on finding the correct type of information we need for the permit, not the 'correctness' of the 

information

l CEC Data adequacy worksheets - You mentioned that you would send these once they were 

prepared. Could you let me know when you expect them to be completed?

l BACT - You and I didn't discuss the details of this point yesterday, and Shirley is still reviewing this 

with other Permit engineers to ensure consistency.

l PSD pollutant review/observation - You stated that the portion on page 6.2-20 that indicates that the 

project emissions are above the threshold for PM10 is from a previous submittal and no longer 

correct.

l SO2 (and SIL) - You and I discussed that the the 0.36 gr/100 scf S for the annual is a judgement call 

on your part based on previous projects in the San Joaquin Valley. We did not discuss what time 

perios this is based on.

l Fuel firing - You confirmed that the fire pump engine is the only thing running on diesel.

Natural gas specs and heat value - You mentioned that the values for the natural gas heat content 

of 1020 and 1060 Btu/scf were included in the project description as "wholistic" information and that 

the value of 1013 Btu/scf is the correct number derived from actual analyses.

Natural gas fired equipment - We didn't discuss this.

Diesel fuel-fired equipment - You mentioned that this emission factor was only used for the GHG 

emission calculations, and that the value of 139,000 Btu/gal may change by 2012.

l Startup/Shutdown (S/S) - You let us know that the startup emission values are larger than the 

expected shutdown emission values, so that it is a conservative upper bound to use the startup 

emission factors for both startup and shutdown. We also discussed that the values listed in Table 

6.2-1.6 and used in the calculations are from experience and not vendor data. 

l Transient load and short-term NOx emissions excursions - You confirmed that the "...proposed 
language for NOx emissions excursion language in the conditions of certification" ( p. 6.2-46) is for

the CEC's conditions for certifications, but also asked for the same language to be considered if we 

will be writing similar conditions for the PSD permit.

l VOC limit - You stated that the 1.5 ppmvd value (w/o duct firing) in Section 2 (p. 2-23) is not the 

correct and that the correct value is listed in section 6 as 1.4 ppmvd (e.g., p. 6.2-43, Table 6.2-19). 

You also mentioned that there might be other items in section 2 that are out of date.

Kate

_________________________

Katherine Hoag

U.S. EPA, Region 9, Air Permits Office (AIR-3)

75 Hawthorne St., San Francisco, CA 94105

Hoag.Katherine@epa.gov

(415) 972-3970

Shirley Rivera/R9/USEPA/US

Shirley 

Rivera/R9/USEPA/US

03/10/2008 09:04 AM

To ewalther@sierraresearch.com

cc Katherine Hoag/R9/USEPA/US@EPA

Subject Re: Avenal #08-SJ-01: Info in PSD application & some 

initial/prelim observations

Eric, 

Got your v/m msg earlier this morning. I would normally give you a quick call back but I've got to prepare 

for a conference call and a few other meetings/activities this morning. So for now, in response to your 

coall - 

a - Observations - At this point, there is **no need** to respond to each observation. They are **not** 

formal comments; they represent our on-going "once-through" page turn of the application, e.g., a quick 

review of info in the sections provided. Also, some are intended to be a "heads up", such as the 

observations regarding:

- BACT

- Startup/Shutdown

- Transient ops

At this point, we have not formally formulated or determined completeness; however, as mentioned, one 

of our objectives is to ensure consistency with other permit activities (past and present).

b - Follow-up today - Kate will give you a call back (916-444-6666). To some extent, she may be able to 

provide you with feedback. At this point, given she is supporting on project management and 

completeness review, at a minimum, she can provide you with some of the basis for our initial 

observations.

c - Going forward for completeness determination - We will continue to conduct our page turn. So you 

know, we have completed the once-through of the following sections and associated appendices:

- project description

- air quality

- public health

Therefore, the remaining sections that we are interpreting as you all's intent to support PSD application 
requirements for:

- Endangered Species Act, Section 7 (Section L of PSD app guidelines)

- Additional impacts analysis (Section H of PSD app guidelines)

. soils, vegetation, visibility

. general comercial, residential, industrial and other growth

- Additional information (Section M of PSD app guidelines)

. For other info provided, we will be identifying any items that we may want clarification 

for its inclusion

========

- Shirl

-------------------------------------------

Shirley F. Rivera

U.S. EPA, Region 9, Air Permits Office (AIR-3) | 75 Hawthorne St., San Francisco, CA 94105

T: (415) 972-3966 | F: (415) 947-3579 | Rivera.Shirley@epa.gov

Shirley Rivera/R9/USEPA/US