{In Archive} Avenal - Proj #C-1080386: EPA Comments 

Shirley Rivera to: Derek Fukuda 08/15/2008 02:12 PM

Cc: Katherine Hoag

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Derek,

Thank you for calling back today (and on a day where you all have flex schedule). As discussed, I 

mistakenly had noted that the 30-day comment period ended today, August 15; however, based on our 

conversation, I understand that yesterday, Aug 14, was the closing date. Therefore, I understand and 

acknowledge that the comments below may be considered by your agency, and appreciate the 

consideration. 

That said, below are comments on San Joaquin Valley Air Pollution Control District's ("District") 

Preliminary Determination of Compliance (PDOC) permit and PDOC evaluation for the Avenal Power 

Center LLC (Avenal) proposed project.

1) Prevention of Significant Deterioration (PSD) Application Processing and PDOC 

Cross-Reference/Cross-Check - For the purposes of EPA's review of the PDOC evaluation and PDOC, 

although not required as part of our PSD permit application review/permit development process, we are in 

the process of identifying whether information provided by the Applicant through the PSD permit 

application process is consistent with the information in the District's evaluation. (Note: The Applicant 

provided sections from its CEC AFC that includes the Air Quality and Public Health sections, which 

presumably is information that the District evaluation also is based. PSD review has been triggered for 

NOx, CO, and PM.) 

We would like to ensure that, at a minimum, those data sets and assumptions shared between the PSD 

and PDOC processes that contribute to the determination of the potential-to-emit, BACT, and 

assumptions for the air quality analysis/modeling are consistent. At this time, we simply would like to 

make the District aware that this evaluation is in process. To the extent that we identify inconsistencies 

during our review, we will address them as part of our PSD permit process. 

2) CO emission limits from the CTGs - The emission limits proposed for each combustion turbine 

generator (CTG), Units C-3953-10-0 and C-3953-11-0, are 4.0 ppmvd @ 15% O2. We note these are 

part of the PDOC conditions and is discussed in the PDOC Attachment F's top-down BACT analysis for 

CO. As part of a BACT analysis, EPA considers achieved in practice emissions as part of the BACT 

evaluation. It is unclear whether the District has included this as part of its analysis. EPA is aware of 

CTGs achieving CO emissions less than 4.0 ppmvd @ 15% O2. Therefore, please provide confirmation 

whether the District's evaluation considered achieved in practice CO ppm levels less than 4.0 ppmvd @ 

15% O2. If so, please provide reasons why a lower level was eliminated from consideration. 

Once again, thank you in advance for your consideration of our comments. If you have any questions 

regarding our comments, please feel free to call me or Mr. Gerardo Rios, Chief of the Permits Office, at 

(415) 972-3974. 

Best regards,

Shirley

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

Shirley F. Rivera 

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

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