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Palmdale Hybrid Power Project (SE 09

- 01) August 2011 Summary of the Proposed Permit

On August 11, 2011

, t he United States Environmental Protection Agency (EPA) Region IX provided notice of, and request ed public comment on, action relating to the Prevention of Significant Deterioration (PSD) permit application for the Palmdale Hybrid Power Project (Project). The proposed permit would grant conditional approval, in accordance with the Prevention of Significant Deterioration (PSD) regulations (40 CFR 52.21), to the City of Palmdale to construct and operate a 570 megawatt (MW, nominal) electric generating facilit y. The City of Palmdale is located at 38300 Sierra Highway, Suite A, Palmdale, CA 93550. The public comment period for this proposed permit , which is ongoing, will close

on September 14, 2011.

The proposed Project consists of two General Electric (GE) Frame 7FA natural gas

- fired combustion
turbine

- generators (CTGs) rated at 154 megawatt (MW) each, two heat recovery steam generators (HRSGs), one steam turbine generator (STG) rated at 267 MW, and 251 acres of parabolic solar

- thermal

collectors with associ ated heat

- transfer equipment with the capacity to provide up to 50 MW of supplemental energy . The Project will have an electrical output of 570 MW (nominal) or 563 MW (net). The Project will be located on a parcel of land owned by the city of Palmdale, cu rrently zoned for industrial use, in Los Angeles County. The approximately 333

- acre parcel is west of the northwest corner of Air Force Plant 42, and east of the intersection of Sierra Highway and East Avenue M. The City of

Palmdale is located within the Antelope Valley Air Quality Management District (District)

.

This document is intended to provide a brief , informal summary of information to assist members of the public attending public participation events scheduled for September 14, 2011 for EPA’s proposed PSD permit for the Project. For official permit documents developed in accordance with 40 CFR Part 124 and more details about the permit requirements, refer to EPA’s public notice, the proposed permit, and the Fact Sheet/Ambient Air Qu ality Impact Report (AAQIR) for this proposed permit action, which are linked to the EPA Region 9 permit website: http: // www.epa.gov/region09/air/permit/r9

- permits

issued.html#pubcomment.

What Laws and Regulations Apply to EPA’s Proposed PSD Permit?

W e have prepared this proposed permit based on our Prevention of Significant Deterioration regulations

issued under the Clean Air Act at 40 C ode of F ederal R egulations (CFR) 52.21

. We believe that the proposed project will comply with PSD requirements inclu ding the installation and operation of Best Available Control Technology ( BACT ) , and will not cause or contribute to a violation of the N ational

A mbient Air Quality Standards (NA AQS ) for the pollutants regulated under the permit . We have made

this determin ation based on the information supplied by the applicant, our review of the analyses contained in the permit application, and other relevant information contained in the administrative record for this proposed action. EPA has provided the proposed permit a nd fact sheet/ AAQIR to the public for review, and will make a final decision on the Project’s PSD permit application after considering all public comments on our proposal submitted during the public comment period

.

Environmental requirements from other federal, state, or local laws are not included in this proposed permit unless they are also part of the Clean Air Act Prevention of Significant Deterioration program. The project is required to comply with all other en vironmental requirements. To this end, the City of Palmdale PUBLIC INFORMATION S HEET

~ OVERVIEW ~

PALM D ALE HYBRID POWER PROJECT

PROPOSED CLEAN AIR A CT

PSD PERMIT2

Palmdale Hybrid Power Project (SE 09

- 01) August 2011 also has submitted applications for state and local construction approvals, respectively referred to as an Application for Certification (AFC) submitted to the California Energy Commission (CEC) 1 and an application for a Determination of Compliance (DOC) submitted to the Antelope Valley Air Quality Management District (District ). The emissions of other air pollutants from the proposed Project, including the pollutants for which the area is not mee ting the NAAQS (and precursors that lead to the formation of such pollutants), are regulated by the District, which implements the Nonattainment New Source Review (NA

- NSR) permitting program for this area. The District is designated as a severe non

attain ment area for ozone. The non

- attainment pollutants subject to NA

- NSR permitting by the District

include nitrogen oxides (

NO

x ) and volatile organic compounds ( VOC ) as ozone precursors. On May 13, 2010, the District issued a Final Determination of Complian ce for the Project, which includes the
District’s NA

- NSR permit requirements. For power plants over 50 MW, the CEC must issue a license to

authorize construction

. The CEC issued its Final Commission Decision approving the Project’s Application for Certifi cation on August 10, 2011 (08

- AFC

- 09)

. The District and CEC approval processes are separate from EPA’s PSD permitting process.

The applicant must also apply for and obtain an Acid Rain permit and a Title V operating permit. The applicant will apply for the Title V operating permit, which will incorporate the acid rain permit after the facility is constructed, as these permits are not required prior to construction. The District has jurisdiction to issue the Acid Rain permit and the operating permit for the facility.

What Does EPA’s Proposed PSD Permit Regulate? The PSD program (40 CFR 52.21) applies to “major” new sources of attainment pollutants. The

estimated emissions for t his project show that the f acility will be a major source for nitrogen di o xides (NO 2 ), carbon monoxide (CO), total particulate matter (PM), particulate m atter under 10 micrometers (PM 10 ), particulate m atter under 2.5 ( μ m) in diameter (PM 2.5 ), and greenhouse g ases (GHG). Once a source is considered major for a PSD pollutant, PSD also applies to any other pollutant regulated under the PSD

program that is emitted in a significant amount. The emissions of oxides of sulfur (SOx) will be less than

the m ajor source threshold and less than the significant emission rate. Therefore, PSD does not apply for

SOx. In addition, because the area in which the Project is located is designated non

- attainment for ozone, the PSD program does not apply to ozone and the PSD permit does not address ozone

.

In accordance with 40 CFR 52.21(j), a new major stationary source is required to apply best available control technology (

BACT ) for each PSD pollutant that it has the potential to emit (PTE) in significant

amounts. With respect to the Project, NO 2 , CO, PM, PM 10

, PM 2. 5, and GHG a re emitted in significant

amounts, and therefore the proposed permit requires the Project to apply BACT to all equipment that emits these pollutants.

How Would EPA’s Proposed PSD Permit Affect Air Quality? The PSD regulations require an examination of the impacts of the proposed project on ambient air quality for the pollutants regulated under the PSD permit

. EPA has reviewed the computer modeling analysis that predicts the effect of the proposed project on ambient air quality. Based on the modeling results, and the
technical information that we have reviewed to date

, the project ’s impacts on air quality and visibility are consistent with limits allowed under the Clean Air Act. T he proposed emission limits will protect the NAAQS for NO 2 , CO, PM 10 , and PM 2.5 . There are no NAAQS for PM or GHG

.

T he PSD regulations require that EPA evaluate other potential impacts on 1) soils and vegetation; 2) visibility impairment; and 3) growth. Based on our review of the analyses provided by the applicant and the maximum potential concentrations of the visibil ity

- related criteria pollutants

- - NO 2 , PM 10 , and PM 2.5 --

1 City of Palmdale Hybrid Power Plant Project Licensing Case (08

- AFC

- 09), http://www.energy.ca.gov/sitingcases/palmdale/index.html

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Palmdale Hybrid Power Project (SE 09

- 01) August 2011 we do not expect any adverse impacts on visibility, nor do we expect this project to result in any adverse impacts on plants and soils or significant growth

.

What Other Actions is EPA Taking in Connection with Its Decision making Process ?

EPA has been engaged in consultation with the U.S. Fish and Wildlife Service under section 7 of the federal Endangered Species Act (ESA) to ensure that its proposed PSD permit decision fo r the Project is

not l ikely to jeopardize the continued existence of any federally

- listed endangered or threatened species or result in the destruction or adverse modification of critical habitat for such species. EPA will proceed with issuance of its final PSD permit decision after making a determination that its decision will be consistent with ESA requirements.

In addition, i n accordance with Executive Order 12898

, “Federal Actions to Address Environmental Justice in Minority Populations and Low

- Income Populations

, ” EPA determined that it would be appropriate to prepare an analysis to consider environmental justice issues in connectio n with the issuance

of this federal PSD permit

. In our Environmental Justice A nalysis

, we conclude that th e P roject will not

cause or cont ribute to air quality levels in excess of health standards for the pollutants regulated under the permit, including CO, N O 2 , PM 10

, or PM 2.5

, and that therefore it will not result in disproportionately high and adverse human health or environmental effects with respect to these air pollutants on minority or low

income populations residing near the proposed P roject or the community as a whole . The Environmental Justice Analysis is ava ilable to the public as part of the a dministrative r ecord supporting EPA’s proposed PSD permit for the Project

.