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Re: Administrative Amendments to Pio Pico Energy Center PSD Permit No. SD 11-01

In conjunction with our final issuance of the revised Pio Pico Energy Center (PPEC) PSD Permit, PermitNo. SD 11-01, following remand by EPA’s Environmental Appeals Board, we are making several

administrative amendments to the permit, in addition to those proposed permit revisions related toour revised BACT analysis for the PPEC’s combustion turbines that were identified in our proposed

revised permit for the PPEC dated November 2013 and accompanying the Fact Sheet Addendum.

These administrative amendments are corrections to the permit that are de minimis in nature, and

are being made simply to correct minor typographical and similar errors or outdated information in

the final permit in order to make the final permit clear and consistent, and do not alter our prior BACT

or ambient air quality impacts analyses or any other substantive analyses supporting our permitdecision.

All of the differences between the final PPEC PSD permit issued in our November 2012 final permit

decision and our current, post-remand final PSD permit for the PPEC to be issued in February 2014,including but not limited to the differences discussed in this memo, are identified in the document“Final Revised PSD Permit for PPEC — track changes”. This unofficial redline/strikeout version of the

final permit is not an official version of the permit, but has been prepared to facilitate understanding

of the changes between the November 2012 final PSD permit for the PPEC and the final, post-remand

PSD permit for the PPEC to be issued in February 2014.Each administrative change is detailed below:

1. Change of Mailing Address — In an email dated January 2, 2014, W. Dave Jenkins with

APEX Power Group, LLC identified the new mailing address for Pio Pico Energy Center, LLC.

(This email is included in the administrative record for this action.) We have included the

new mailing address for PPLLC on the front page of the final PSD permit for the PPEC. We

consider this change to be administrative as it is merely the permittee’s address forcorrespondence, and does not involve any changes to the physical address or location of

the PPEC facility.

2. Update to Reporting Requirements Email Address — The email addressed used by EPA for

reporting in Conditions lV.A and X.A has been updated to reflect the new email address

being used by Region 9’s Enforcement Division - aeo r9@epa.gov.
now been replaced with a period to be consistent with the other conditions in IX.C.

4. Erroneous References to Net Energy Output — Condition IX.H.9 in the Recordkeeping and

Reporting section of the November 2012 permit erroneously contained references to net

energy output rather than gross energy output. As discussed in Region 9’s November 2012

Response to Comments document, we intended to change the permit from using net

energy output to gross energy output for compliance with the GHG BACT requirements in

the permit. See Response to Comment 13 on page 17. We made the appropriate changeto the emission limits in Condition lX.B.1 of the November 2012 permit, but we

inadvertently omitted from the November 2012 final permit the necessary changes to theassociated monitoring and recordkeeping requirements in Condition lX.H.9 as indicated in

our response. Condition IX.H.9 identifies the necessary monitoring and recordkeeping

requirements that will be used to demonstrate compliance with the GHG BACT limit in

Condition IX.B.1. Without these revisions the permit would require the source to meet a

GHG BACT limit on a gross energy output basis, but only require monitoring and

recordkeeping on a net energy output basis. So, we are correcting the language in

Condition lX.H.9 to be consistent with the emission limits in Condition lX.B.1 of the permit

and our stated intent.

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