# _ SanJoaquin Valley

• AIRPOLLUTION CONTROLDISTRICT
OCT 3 0 

### 2008 Jim Rexroad Avenal Power Center LLC 500 Dallas Street, Level 31 Houston, TX 77002 Re: Notice of Final Determination of Compliance (FDOC) Project Number: C-1080386
- Avenal PowerCenter LLC (08-AFC-01) Dear Mr. Rexroad: Enclosed is the District's final determination of compliance (FDGC) for the installation of a nominal 600 MW combined cycle power plant, located at**NE~** Section 19, T21 S, R18E
- Mount Diablo Base Meridian on Assessor7sParcei Number36-170-032 in Avenal, CA. Notice of the District's prelim.inary decision was published on July 16, 2008. All comments received following the District's preliminary decision on this project were considered. A'summary of the comments received and the District responses to those comments can be found in Attachments J, K, and L ofthe enclosed FDGC package. The changes made to the PDOC were in direct response to comments received from the oversight agencies and other interested parties. It is District practice to require an additional 30-day comment period for a project if changes received during the initial 30- day comment period result in a significant emissions increase that affects or modifies the original basis for approvaL The changes made were minor and did not increase permitted emission levels or trigger addition·al public notification requirements. Therefore, publication of the PDOC for an additional 30-day comment period is not required. Also enclosed is an invoice for the engineering evaluation fees pursuant to District Rule 3010. Please remit the amount owed, along with a copy ofthe attached invoice, within 60 days.

Seyed Sadredin Executive Director/AirPollution Control Officer
Northern Region 4800 EnterpriseWay Modesto, CA95356-8718 Tel: (209) 557-6400 FAX: (209) 557-6475 Central Region (Main Office) 1990 E. Gettysburg Avenue

Fresno, CA93726-0244 Tel: (559) 230-6000 FAX: (559) 230-6061 www.valleyair.org Southern Region 2700 MStreet, Suite 275 Bakersfield, CA93301-2373 Tel: (661) 326-6900 FAX: (661) 326-6985 Printed**onr~~y~iedp~p~~:~**Mr. Jim Rexroad Page 2
Thank you for your cooperation in this matter. If you have any questions, please co·ntact Mr. Jim Swaney ofthe Permit Services Division at (559) 230-5900. Sincerely,



# 1: jfl- David Warner I

## V
. Directorof Permit Services DW:df En"closures
cc: EricWalther, Sierra**Res~arch**

### Fresno Bee

NOTICE OF FINAL DETERMINATIO·NOF COMPLIANCE NOTICE IS HEREBY GIVEN that the San Joaquin Valley Unified Air Pollution Control District has issued a Final Determination ofCompliance (FDOC) to Avenal Power Center LLC for the installation of a nominal 600 MW combined cycle power plant, located at**NE~** 

### Section 19, T21S, R18E Mount Diablo Base Meridian on Assessor's Parcel Number36-170-032 in Avenal, CA. All comments received following the District's preliminary decision on this project were considered. Cha'nges were made to the DOC in direct response to comments received from the oversight agencies and other interested parties. The changes made were minor and did 'not increase permitted emission levels ·or trigger additional public notification requirements. The application reviewfor.project C-1080386 is available for public inspection atthe SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION "CONTROL "DISTRICT, 1990 EAST GETTYSBURG AVENUE, FRESNO, CA 93726.F I:N·

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..··..··,; "jf1"'*\**.:~.** ; : )/""'.. l I" ,/,: 1**'~** Avenal Power Center Project California Energy'Commission Application for Certification Docket#: 08-AFC-01
Facility**~ame:** Mailing Address:
Contact Na'me: Telephone: Fax: Cell: E-Mail: Alternate Contact:

. Telephone: Fax: Cell: E-Mail: Alternate Contact: Telephone: Cell: E-Mail: Engineer: Lead Engineer: Date: Project#: Application #'s: Submitted: Avenal Power Center, LLC 500 Dallas Street, Level 31 Houston, TX 77002 Jim Rexroad (713) 275-6147 (713) 275-6115 -(832) 748-1 060 jim.,Rexroad@macquarie.com Eric Walther (916)444-6666 (916) 444-8373 (916) 883-8774 ewalther@sierraresearch.com Tracey Gilliland (713)275-6148 (512) 217-3002 tracey.gilliland@macquarie.com Derek Fukuda, Air Quality Engineer Joven Refuerzo, Supervising Air Quality Engineer October 28,2008 C-1080386 C-3953-10-0, C-3953-11-0, C-3953-12-0, C-3953-13-0, and C-3953-14-0 February 29, 2008AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386



### Table of Contents Section


### I. Proposal II. Applicable Rules III. Project Location IV. Process Description 

# v. Equipment Listing Page


### 1 1 2 3 5 VI. Emission Control Technology Evaluation 5 VII. General Calculations 

### 9 VIII. Compliance 27 IX. Recommendation 110 ATTACHMENT· A ATTACHMENT B ATTACHMENT C ATTACHMENT D ATTACHMENT 

### E ATTACHMENT F ATTACHMENT G 

# - ATTACHMENT H ATTACHMENT I ATTACHMENT·J ATTACH·MENT K ATTACHMENT L f7DOC Conditions Project Location and Site Plan eTG Commissioning Period Emissions Data CTG Emissions Data SJVAPCD BACT Guidelines 1.1.2,**3~** 1.4, 3.1.8, and 3.4.2 Top Down BACT Analysis (C-3953-10-0, -11-0, -12-0, -13-0, and -14-0) Health Risk Assessment and AmbientAir Quality Analysis SOxfor PM10 Interpollutant OffsetAnalysis Additional Supplemental Information CEC Comments and District Responses EPA Comments and District Responses CURE Comments and District ResponsesAvenalPowerCenter, LLC(08-AFC-01) SJVACPO Determination ofCompliance, C-1080386
I. PROPOSAL: Avenal Power Center, LLC is seeking approval from the San Joaquin Valley Air Pollution Control District (the "District") for the installation of a "merchant" electrical power generation facility (Avenal Energy Project). The Avenal Energy Project will be a combined-cycle power generation facility consisting of two natural gas-fired combustion turbine generators (CT.Gs) each with a heat recovery steam generator (HRSG) and a 564 MMBtu/hr duct burner. Also proposed are a 300' MW steam turbine, a 37.4 MMBtu/hr auxiliary boiler, a 288 hp diesel-fired emergency 

## Ie engine powering a water pump, a 860 hp natural gas-fired emergencylC engine powering a 550 kW generator and associated facilities. The plant will have a nominal rating of 600 MW. During the 30-day public notice period for this project several comments were received by the District from various community and regulatory entities. These comments and the Districts responses can be seen in Attachments J, K, and L. Based on these comments, the only significant change to the DOC was the lowering of the CO emission factor for the two natural gas-fired CTG's from 4.0 ppmvd 

### @ 15% O2 to 2.0**pp~vd** 

### @ 15% O2. 'The Avenal Energy Project is'subject to approval by the California Energy Commission (CEC). Pursuant to SJVAPCD Rule 2201, Section 5.8, the Determination of Compliance (DOC) review is' functionally equivalent to an Authority to Construct (ATC) review. The Determination of Sompliance (DOC) will be issued an.d submitted to the CEC contingent upon SJVAPCD approval ofthe project. The California Energy Commission (CEC) 'is the, lead agency for this project for the requirements ofthe California**E~vironmentalQuality** Act (CEQA). Additionally, the Avenal Energy Project is subject to Prevention of Significant Deterioration requirements by EPA Region IX.
II.

. APPLICABLE RULES: Rule 1080 Rule 1081 Rule 1100 Rule 2010 Rule 2201 Rule 2520 Rule 2540 Rule 2550 Rule 4001
Rule 4002 Stack Monitoring (12/17/92) Source Sampling (12/16/93) Equipment Breakdown (12/17/92) Permits Required (12/17/92) New and Modified Stationary $ource Review Rule (9/21/06) Federally Mandated 'Operating Permits (6/21/01) Acid Rain Program (11/13/97) Federally Mandated Preconstruction Review for Major Sources of Air Toxics (6/18/9.8) , New Source Performance Standards (4/14/99) Subpart GG
- Standards of Performance for Stationary Gas Turbines Subpart 

### KKKK

- Standards of Performance for Stationary Combustion Turbines National Emissions Standards for Hazardous Air Pollutants (5/18/00) 1Rule 4101 Rule 4102 'Rule 4201 RUle 4202 Rule 4301

.Rule 4305

Rule 4306 Rule 4351 Rule 4701 Rule 4702 'Rule 4703 Rule 4801 Rule 8011 Rule 8021 

### AvenalPowerCenter, LLC(08-AFC-01) SJVACPO Determination ofCompliance, C-1080386 Visible, Emissions (2/17/05) Nuisance (12/17/92). Particulate Matter Concentration (12/17/92) Particulate Matter Emission Rate (12/17/92) Fuel Burning Equipment (12/17/92) Boilers, Steam Generators and Process Heaters
- Phase 2 (8/21/03) Boilers, Steam Generators and Process Heaters
- Phase 3 (3/17/05) Boilers, Steam Generators and Process Heaters
- Phase 1 (8/21/03) Stationary Internal Combustion Engines
- Phase 1 (8/21/03) Stationary Internal Combustion Engines
- Phase 2 (1/18/07) Stationary Gas Turbines (8/17/06) Sulfur Compounds (12/17/92)**G~neral** Requirements (8/19/04) Construction, Demolition, Excavation, Extraction and Other Earthmoving Activities (8/19/04) Rule 8031 Bulk Materials (8/19/04) Rule 8041 Carryout and Trackout (8/19/04) Rule 8051 Open Areas (8/19/04) Rule 8061' Paved and Unpaved Roads. (8/19/04) RUle 8071 Unpaved Vehicle/Equipment.TrafficAreas (9/16/04) Rule 8081 Agricultural Sources (9/16/04) California Environmental QualityAct (CEQA) California Code of Regulations (CCR), Section 2423 (Exhaust Emis.sion Standards and Test Procedures, Off-Road Compression-Ignition Engines and Equipment) California Health & Safety Code (CH&S), Sections 2423 (Exhaust Emission Standards and Test Procedures, Off-Road Compression-Ignition Engines and Equipment) 417'00 (Health Risk Analysis), 42301.6 (School Notice), 44300 (Air Toxic "Hot Spots"), and 93115 (Airborne Toxic Control Measure (ATCM) for Stationary.Compression-Ignition (CI) Engines) III. PROJECT LOCATI·ON: The proposed equipment will be located within**NE~** Section 19, Township 21 South, Range 18 East
- Mount Diablo Base Meridian on Assessor's Parcel Number 36-170-032 (8ee Attachment B).. The closest population center is the residential district ofAvenal approximately 6 miles to the southwest. The City of Huron is located approximately· 

### 8 miles to the north, and the City of Coalinga is lo'cated approximately 16 miles to the west. The site is located northeast ofthe city ofAvenal, in Kings County. The proposed location is not within 1,000' ofa K-12 school.

.



### 2AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-10_80386
IV. PROCESS DESCRIPTION: Combined-Cycle Combustion Turbine**Gener~tors** 

### Each natural gas-fired General Electric Frame 7 Model PG7241 FA combined-cycle combustion turbine generator (CTG) will be equipped with Dry Low NO

### x combustors, a selective catalytic reduction (SCR) system with ammonia injection, an oxidation catalyst, a duct burner, and a heat recovery steam generator (HRSG). Each CTG will drive an electrical generator to produce approximately 180 MW of electricity. The plantwill be a "combined-cycle plant," sin<?e the gas turbine and a steam turbine both turn electrical generators and produce power. Each CTG will turn an electrical generator, but will also produce power by directing exhaust heat through its HRSG, which supplies steam to the steam turbine nominally rated at -300 MW, which turns anotherelectrical generator. Since two HRSGs will feed a single steam turbine generator, this design is referred to as a "twoon-one" configuration. The CTGs will utilize Dry Low NO

### x (DLN) combustors, SCR with ammonia injection, and an oxidation catalyst to achieve the foUowing emission rates: 'NOx: 2.0 ppmvd @ 

### 15% 

### O2 

### VOC: 2.0 ppmvd @ 15% 

### O2 

### CO: 2.0 ppmvd @ 150/0 

### 02 SOx: 0.00282Ib/MMBtu (Hourly and Daily Limits; based on 1.0 gr S/100

### dscf) 0.001 Ib/MMBtu (Annual average; based on 0.3,6 gr S/100

### dscf» PM 10: 

### 0.0107 Ib/MMBtu
- ' Continuous emissions monitoring systems (CEMs) will sample, analyze, and record NOx, CO, and 

### 02 concentrations in the exhaust gas ,foreach CTG. He'at Recovery Steam Generators (HRSGs) 

### The HRSGs provide for the transfer of heat from the CTG exhaust gases -to condensate and feedwater to produce stream. Each HRSG will be approximately 90 "feet high and will have an exhaust 'stack approximately 145 feet tall by 19 feet in diameter. The size and shape of the HRSGs, are specific to their intended purpose of high efficiency recycling of waste heat from the CTG.: The HRSGs will be multi-pressure, natural-circulation boilers equipped with transition ducts and duct burners. Pressure components of each HRSG include a low pressure (LP) economizer, LP evaporator, LP deaerator/drum, 

### LP superheater, intermediate pressure (IP) economizer, IP evaporator, IP drum, IP superheaters, high pressure (HP) economizer, HP evaporator, HP drum, and HP superheaters and reheaters.

. Superheated HP steam is produced in the HRSG and flows to the steam turbine throttle inlet. The exhausted cold reheat steam from the steam turbine is mixed with 'IP steam from the HRSG and reintroduced into the HRS'G through the reheaters. The hot reheat steam flows backfrom the HRSG into the STG. The LP superheated steam from the HRSG is admitted to the LP .3

### AvenalPowerCenter, LLC'**(08~AFC-01)** SJVACPO Determination

### ofCompliance, C-1080386


### condenser. The condensate is pumped from the condenser back to the HRSG by condensate pumps. The condensate is preheated by an HRSG feedwater heater. Boiler feedwater pumps send the feedwaterthrough economizers and into the boiler drums ofthe HRSG, where steam is produced, thereby completing the steam cycle. Each HRSG is equipped with a SCR system that Uses aqueous ammonia in conjunction with a catalyst bed to reduce NOx in the CTG exhaust gases. The catalyst bed is contained in a catalyst cham'ber located within each HRSG. Ammonia is injected upstream of the catalyst bed. The subsequent catalytic reaction converts NOx to nitrogen and water, resulting in a reduced concentration of NOx'in the exhaust gases exiting the stack. Duct Burners 

### Duct burners are installed in the HRSG transition duct between the HP superheater and reheat coils. Through the combustion of natural gas, the duct burners heat the CTG·exhaust gases to generate additional steam at 'times when peak power is needed. The duct burners are also used as needed to. control the temperature of steam produced by the HRSGs..

. The duct burners will have a'maximum heat input rating of 562 MMBtu/hr ona higher.heating value (HHV) basis per HRSG, and are expected to operate no more·than hours peryear. Steam Turbine Generator 

### The steam turbine system consists of a 300 MW nominally rated reheat steam turbine**~enerator** 

### (STG), governor system, steam admission system, gland steam system, lubricating oil system, including oil coolers and filters and generator co.olers. Steam from the HP s'uperheater, reheater and IP superheater sections of the HRSG enters the corresponding sections ofthe' STG as described previously. The steam expands through the turbine blading to drive the steam turbine and its generator. Upon exiting' th'e turbine, the steam enters the deaerating condenser, where it is condensed to water. Auxiliary Boiler



### . One 37.4 MMBtu/hr Cleaver Brqoks Model CBL700-900-200#ST natural gas-fired boiler

equipped with an Cleaver Brooks Model ProFire Ultra Low NOx burner, capable of providing up to 25,000 pounds per hour (Ib/hr) of saturated steam. The' boilerwill be used to provide·steam as needed for auxiliary purposes. . ·Diesel-Fired Emergency

## Ie Engine Powering a Fire Pump 

### Emergency firewater will be provided by three pumps (a jockey pump, a main fire pump, and a back-up fire pump); two powered by electric motors and the other powered by a diesel-fired internal combustion engine. Ifthe jockey pump is unable to maintain a set operating pressure in the piping network, the electric motor-driven fire pump will start automatically. If the electric "motor-driven fire pump is unable to maintain a set operating pressure, the diesel engine-driven fire pump will start automatically. The diesel-fired engine will be rated at 

### 288 horsepower. The engine will be limited to no greater than 50 hours per year of non-emergency operation in accordance with the applicant's proposal.



### 4A·vena/PowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386


### Natural Gas-Fired Emergency IC Engine Powering an Electrical Generator One 860 hp Caterpillar Model G3512LE natural gas-fired IC engine generator set w.ill provide powerto the essential·service AC system in the event of grid failure or loss of outside powerto the plant. This engine will be limited to no greater than 50 hours per year of non-emergency operation in accordance with the applicant's proposal.
V. EQUIPMENT LISTING: C-3953-10-0: 180 MWNOMINALLY RATED COMBINED-CYCLE POWER GENERATING SYSTEM #1 CONSISTING OF A GENERAL ELECTRIC FRAME 7 MODEL PG7241FA NATURAL**GAS~FIRED** 

### COMBUSTION TURBINE GENERATOR WITH DRY LOW NO

### x COMBUSTOR, A SELECTIVE CATALYTIC REDUCTION (SCR) SYSTEM, AN OXIDATION CATALYST, HEAT RECOVERY STEAM GENERATOR #1 (HRSG) WITH A 562 MMBTU/HR DUCT BURNER AND A 300 MW NOMINALLY RATED STEAM TURBINE SHARED WITH**C~3953-11** 

### "C-3953-11-0: 180 MW NOMINALLY RATED COMBINED-CYCLE POWER GENERATING SYSTEM #2 CONSISTING OF A GENERAL ELECTRIC FRAME 7 MODEL PG7241FA NATURAL GAS-FIRED COMBUSTION TURBINE GENERATOR WITH DRY LOW NO

### xCOMBUSTOR, A SELECTIVE CATALYTIC REDUCTION (SCR) SYSTEM, AN OXIDATION CATALYST, HEAT RECOVERY STEAM GENERATOR #2 (HRSG) WITH A 562 MMBTU/HR DUCT BURNER AND A 300 MWNOMINALLY RATED STEAM TURBINE SHARED WITH C-3953-10 C-3953-12-0: 37.4 MMBTU/HRCLEAVER BROOKS MODEL CBL-700-900-200#ST

" " 

### NATURAL GAS-FIRED BOILER WITH A CLEAVER BROOKS MODEL PROFIRE, OR DISTRICT APPROVED EQUIVALENT, ULTRA LOW .NOX BURNER C-3953-13-0: 288 BHP C"LARKE MODEL JW6H-UF40 DIESEL-FIRED EMERGENCY IC ENGINE POWERING A FIRE PUMP C-3953-14-0: 860 BHP CATERPILLAR MODEL 3456 NATURAL GAS-FIRED EMERG.ENCY IC ENGINE POWERING" WITH NON-SELECTIVE CATALYTIC REDUCTION (NSCR) POWERING A 500 KW ELECTRICAL GENERATOR
VI. EMISSION CONTROLTECHNOLOGY EVALUATION: 

### i. C-3953-1 0-0·and C-3953-11-0 (Turbines) Each CTG will be equipped w"ith a 

### Dry Low NO

### x combustor and will exhaust into a Selective Catalytic Reduction [SCR] system with ammonia injection, and a CO catalyst. The use of Dry Low NO

### x combustors and a SCR system with ammonia injection can achieve a NO

### x emission rate of 2.0 ppmvd 

### @ 15% O2. 

### CO" emissions of 2.0 ppmvd 

### @
5AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386


### 150/0 O2 

### have been demonstrated with the use ofan oxidation catalyst (1). 

### And the use of DLN combustors and good combustion practices can achieve 

## vac emissions of 

### 2'.0 ppmvd@ 15°A> O2. 

### Emissions from natural gas-fired turbines include NOx, CO, VOC, PM 10, 

### and SOx. NOx is' the major pollutant of concern when combusting natural gas., Virtually all gas turbine NOxemissions originate as NO. This NO is further oxidized in the exhaust system or later in the atmosphere to form the**mor~** 

### stable N02 

### molecule. There are two mechanisms by which NOx 

### is formed in turbine combustors: 1) the oxidation of atmospheric nitrogen found in the combustion air (thermal NO

### x and prompt NO

### x ), and 2) the conversion ofnitrogen chemically bound in the fuel (fuel NOx ). Thermal NOx is formed by a series of chemical reactions in which oxygen and nitrogen present in the combustion air dissociate and subsequently reactto form oxides of nitrogen. Prompt NO

### x, a form of thermal NO

## x , is formed in the proximity of the flame front as intermediate combustion products such as HCN, H, and NH are oxidized to form NOx. Prompt NOx is formed in both fuel-rich flame zones ,and dry low NO

### x ' (DLN) combustion zones. The contribution of prompt NOx to overall NOx emissions is relatively small in conventional near-stoichiometric combustors, but this contribution' is an increasingly ,significant percentage of overall thermal NOx emiss'ions in DLN combustors. For this reason prompt NOxbecomes an important consideration for DLN combustor designs, and**establi~hes** 

### a minimum NO

### xlevel attainable in lean mixtures. Fuel NO

### x is formed when fuels containing nitrogen are burned. Molecular nitrogen, present as N2 

### in some natural gas, does not contribute significantly to fuel NOxformation. With excess air, the degree of fuel NOxformation is, primarily a function of the nitrogen content in the fuel. When compared to thermal NOx, fuel NOx is not currently a major contributorto overall NO

### xemissions from stationarygas turbines firing natural gas. The level of NO

### xformation in a gas turbine, and hence the NOx emissions, is unique (by design factors) to each gas turbine model and operating mode. The primary factors that determine the amount of NOxgenerated are the combustor design, the types offuel being burned, ambient conditions, operating cycles, and, the poweroutput ofthe turbine. The design ofthe combustor is the most importantfactor influencing,the formation of NOx.

Design parameters controlling air/fuel ratio and the introduction of cooling air into the combustorstrongly. influence thermal NOxformation. Thermal NOxformation' is primarily a function of flame temperature and residence time. The extent ,of fuel/air mixing'prior to combustion also affects NOx formation. Simultaneous mixing and combustion results in localized fuel-rich zones that yield high flame temperatures in which substantial, thermal NOx 

### production takes place. Injecting water or steam into a conventional combustor ,provides a heat sink that effectively reduces peak flame temperature, thereby reducing thermalNOx formation. Premixing air and fuel at a lean ratio approaching the lean

'1 Based on information supplied by the CTG manufacturer and information contained in the California Air Resources Board's September 1999 Guidance for Power Plant Siting and BestAvailable Control Technology.document. 

### 6

### AvenalPowerCenter, LLC'(08-AFC-01) SJVACPO Determination ofCompliance, C-1080386 flammability .Iimit (approximately 50% excess air) significantly reduces peak. flame temperature, resulting in minimum NOxformation during combustion. This is known as dry low NOx (DLN) combustion. Selective Catalytic Reduction systems selectively reduce .NOx emissions by. injecti.ng ammonia (NH3) into the exhaust gas stream upstream of a catalyst. Nitrogen oxides, NH3, and O2 react on the surface ofthe catalyst to form molecular nitrogen (N2) and H20. SCR is capable' of over 

### 90 percentNOx reduction. Titanium oxide is the SCR catalyst material most commonly used, though vanadium pentoxide, noble metals, orzeolites are also used. The ideal operating temperature for a conventionalSCR catalyst is 600 to 750 of. Exhaust gas temperatures greater than the upp.er limit (750 OF) will cause NOx and NH3to pass through the catalyst unreacted. Ammonia slip will be limited to 

### 10 ppmvd 

### @15°Jlc> O2. Carbon monoxide is formed during'the combustion process due to incomplete oxidation of the carbon contained in the fuel. 'Carbon monoxide formation can be limited by ensuring complete and efficient combustion of the.fuel.. High combustion temperatures,

.adequate excess air a'nd good airifuel mixing during**combust~on** minimize CO emissions. Therefore, lowering com.bustion**temperatur~s** and staging combustion to limit NOx formation can result in increased 

## GO emissions. Post-combustion CO controls, such as oxidizing catalysts can also be used to reduce CO emissions. An oxidation catalyst utilizes a precious metal catalyst bed to convert carbon monoxide (CO) to carbon dioxide (C02). Inlet air temperature and density directly affects turbine performance. The hotter and 'drier the inlet air temperature, the lower the efficiency and capacity of the turbine. Conversely, colder air improves the efficiency and reduces emissions by reducing the amount of fuel required to achieve the required turbine output. The inlet air cooler will allow the turbine to operate in a more efficient manner than it would withc;>ut it. The increased efficiency will reduce the amount of fuel necessary to ach'ieve the required power output. The reduction in fuel consumption will result in lower combustion contaminant emissions. The inlet airfilterwill remove particulate matterfrom the combustion air stream, reducing the.amount of particulate matteremitted. The lube oil coalescer will result in the merging together of oil mist to form larger droplets. The largerdrop.lets will return to the oil stream instead of being emitted. ii.C-3953-12-0 (Boiler) Emissions from natural gas-fired boilers include NOx, CO, VOC, PM10, and SOx. NOx is the major pollutant of concern when burning natural gas. NOx formation is either due to thermal fixation of atmospheric nitrogen in the combustion air (thermal NOx) or due to conversion of chemically bound nitrogen in the fuel (fuel NOx). Due to the low fu'el nitrogen content of natural gas, nearly .all NOx emissions are thermal NOx. Formation of 

### 7AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
therm'al NO

### x is affected byfourfurnace zone factors: (1) nitrogen concentration, (2) oxygen concentration, (3) peaktemperature, and (4) time ofexposure at peaktemperature. The Cleaver Brooks b'oiler will control the formation 'of thermal NO

### x with an Cleaver 'Brooks ultra low NO

### x burner. Cleaver Brooks burners reduce NO

### x by pre-mixing gaseous fuel and' combustion air in a region near the burner exit, at a stoichiometry that minimizes Prompt NO

### x. This also eliminates the traditional NO

### xversus CO tradeoff. iii. C-3953-13-0 (DiesellC engine powering fire water pump) The diesel-fired emergency ICengine (fire pump) will be equipped with a turbocharger, an intercooler/aftercooler, and will be fired on very low (0.00150/0) sulfurdiesel. The emission control devices/technologies and their effect on diesel engine emissions are detailed below.2

. Theturbocharger.reduces the NO

### xemission rate from. the engine by approximately 100 k by increasing the efficiency and promoting more complete burning ofthe fuel. The intercooler/aftercoolerfunctions in conjunction with the turbochargerto reduce the inlet airtemperature. By reducing the inlet airtemperature, the peak combustion temperature is lowered, which reduces ·the formation of thermal NOx. NOx emissions are reduced by approximately 15% with this control technology. The' use of low sulfur 

### (O.0015°A> by weight sulfur maximum) diesel fuel reduces SOx emissions by approximately

### gg0A> from standard diesel fuel. iv. C-3953-14-0 (Natural gas 

### Ie engine powering electrical generator) The natural gas-fired emergency IC engine (generator) will be equipped with an intercooler/aftercooier,. lean burn technology, and will be fired on PUC-Regulated natural gas. The emission control devices/technologies and their effect on diesel engine emissions are detailed below.3 The intercooler/aftercoolerfunctions in conjunction with the turbochargerto reduce the inlet airtemperature. By red.ucing the inlet airtemperature, the peak combustion temperature is lowered, which reduces the formation of thermal NO

### x. NO

### x emissions are reduced by approximately 150/0 with this control technology. Lean burn technology increases the volume ofair in the combustion process and therefore increases the heat capacity of the mixture. This**t~chnology** also incorporates improved

2 From "Non-catalytic NOx**Con~rol** ofStationary Diesel Engines", by Don Koeberlein, CARB. 3 From "Non-catalytic NOx Control ofStationary Diesel Engines", by Don Koeberlein, CARB. 

### 8

### Avenal**Pow~r** 

### Center, LL·C(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
swirl patterns to promote thorough air/fuel mixing. This in turn lowers the combustion temperature and reduces NO

### xformation.


### VII. 'GENERAL CALCULATIONS: 

### i. C-3953-10-0_and C-3953-11-0'(Turbines)

• Heating value of natural gas is 1,013 Btu/scf (per applicant).·

• Maximum daily emissions for each CTG for VOC, PM 10 and SOx during the commissioning period are estimated assuming ,twenty-four (24) hours operating while firing atfuHload.

• The commissioning period will not exceed 408 hours per CTG 'and the emissions .',emitted during the commissioning period will accrue towards the maximum annual

emissions limit.

• Maximum daily emissions for each CTG for NOx, CO, and VOC are estimated assuming six (6) hours operating in startup and shutdown mode and eighteen (18)

.hours operating while firing atfull load with operation ofthe duct burner.

• Maximum daily emissions for each CTG for 'PM 1o, SOx, and NH3 are estimated assuming twenty-four (24) hours operating while firing at full load with the operation·ofthe duct burner.

• Maximum annual emissions for each eTG for NOx and VOC are estimated assuming the CTG is .operated according to a weekend and weekday hot start**scenario~** The weekend and weekday hot start scenario results in CTG**operatio~** of 547.5 (1.5 hr/hot start x ·365 .hot start/yr) hours operating in startup and shutdown mode, 800 hours operating while firing at full load with the duct burner, and 6,683 hours operating while firing at full load without**th~** ductburner.

• Maximum annual emissions for eachCTG for CO are estimated assuming the CTG is operated· according to a weekend .shutdown and weekday hot start scenario. The weekend shutdown and weekday hot start scenario results in CTG operation of 624 «1.5 hr/hot start x 208 hot startlyr) + (6.0 hr/cold start x 52 cold starts/year)) hours operating in startup and shutdown mode, 800 hours operating while firing at full load with the duct burner, and 3,800 hours operating while firing atfull load withoutthe duct burner.

• Maximum annual emissions for each CTG for PM 10, SOx, and NH3 are estimated assuming the CTG is operated according to a baseload scenario. The baseload scenario results in CTG operation of 800 hours operating while ·firi.ng at full load with the duct burner and 7,960 hours operating while firing 

### atfull load without the duct burner. 9AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance,**C~** 

### 1080386

ii. C-3953-12-0 (Boiler)

• External 

### 02 stack gas concentration is 

### 3%.
• Natural gas F factor is 8,710 dscf/MMBtu (Ref. 40 CFR Part 60, Appendix A, Method 19).
• Heating value of natural gas is 1,013 Btu/scf(perapplicant)

. .• The applicant is**propo~ing** a maximum natural gas usage rate of 37.4 MMBtu/hr.
• Maximum SOx emission factor determined by performing a mass balance assuming a natural gas sulfur content of 1 gr S/1.00 scf. ,Calculation shown below. (1 gf-S/100 GsGf

### x 1 19-5/7000 9f

### x64 Ib SOx/32 19-5

### x 1 SGf/1 013 SW

### x 106 SW/MMBtu)
=0.00282 Ib/MMBtu

• Maximum daily and annual emissions for all pollutants are estimated assuming twelve (12) hours perday and 1,248 hours peryear operating at fullload.4

• Operating schedule of 12 hr/day and 1,248 hrs/year

.

.iii. C-3953-13-0 (DiesellC eng'ine powering fire water pump)

• Diesel Ffactor (adjusted to 60 OF) is 9,051 dscf/MMBtu.

- Density ofdiesel is 7.1 Ib/gal.

- Higher heating value ofdiesel is 137,000 Btu/scf.
• BHP to Btu/hr.conversion is 2,542.5 Btu/hp-hr.
• Thermal efficiency ofthe engine: commonly 350/0.
• .Emissions are. based on 24 hours per day (maximum emergency use) and 50 hours peryear ofoperation (maximum non-emergency use). iV. C-3953-14-0(Natural gas 

### Ie engine powering electrical generator)

• EPA F-factor (adjusted to 60 OF) is 8,578 dscf/MMBtu (40 CFR 60 Appendix B)

- Fuel heating value 1,013 Btu/dscf (per applicant) -Maximum daily SOx emission factor determined by performing a mass balance assuming a natural gas sulfur content of 1 gr S/100 scf. Calculation shown below. (1 gf-S/100 GsGfx 1 19-5/70009f

### x64 Ib SOx/32 19-5

### x 1 SGf/1 013 SW

### x 106 SW/MMBtu)
= 0.00282 Ib/MMBtu '

• BHP to Btu/hrconversion is 2,542.5 Btu/hp
-hr.
• Thermal efficiency ofthe engine: commonly 35%.
• Emissions are based on 24 hours per day (maximum emergency use) and 50 hours·peryear ofoperation (maximum non-emergency use)

.

. 4Applicant has indicated that the unitwill be used a maximum of 12 hours on a startup day. 10

### AvenalPowerCenter, LLC(08-AFC-01) SJVACPO Determination ofCompliance, C-1080386

B. Emission Factors 

### i. C-3953-10-0 and C-3953-11-0 (Turbines) The maximum air .contaminant mass emission rates (Ib/hr) during the commissioning period estimated by the facility (see Attachment C) for the proposed CTGs are summarized below:

Mass Emission Rate (perturbine, Ib/hr) 160 1,000 16 The maximum air contaminant mass emission rates (Ib/hr) with and without duct burner firing, concentrations (ppmvd 

### @ 15% O2), and startup and shutdown emissions rates (Ib/hr) provided by the applicant (see Attachment 

### Dfor applicant proposed emissions) for the proposed CTGs are summarized below. The emission rates from the turbines and duct burners are calculated below: Maximum Emission Rate Without Duct Burner Firing: The worst-case NOx, PM 10, CO, VOC, and NH3 mass emission rates are when each turbine operates at 100% load and an ambient air inlet temperature of 32 

### of. The worstcase 

## sax mass emission rate will be determined assuming a natural gas sulfur content of 1 gr 8/100 scf. The following equation will be· used to calculate the emission rate of the CTG without the duct burnerfiring: Emission Rate (Ib/hr)

# =CTG Max Heat Input (MMBtu/hr) x Emission' Factor (lb/MMBtu)

.NOx Emission Rate (Ib/hr)

# =(1,856.3 MMBtu/hr)x (0.0073 Ib-NOx/MMBtu) 

# =13.55 Ib-NOx/hr CO Emission Rate (Ib/hr)

# =(1,856.3 MMBtu/hr) x (0.0045 Ib-CO/MMBtu) 

# =8.35 Ib

..CO/hr

. VOC Emission Rate (Ib/hr)

# =(1,856.3 MMBtu/hr) x (0.0018 Ib-VOC/MMBtu) 

# =3.34 Ib-VOC/hr PM 10 Emission Rate (Ib/hr)

# =(1,856.3 MMBtu/hr) 

### x (0.0048 Ib·-PM 10 /M.MBtu)


### = 8.91 Ib-PM10 /hr

5 PM10 and SOx emissions during commissioning period are equal to the maximum hourly emissions during baseload facility operation. 11AvenalPowerCenter,·LLC(OB-AFC-01) SJVACPD Determination·ofCompliance, C-10B0386
SOx Emission Rate (Ib/hr) = (1,856.3 MMBtu/hr) x (0.00282 Ib-SOx/MMBtu)


### = 5.23 Ib-SOx/hr NH3 Emission Rate (Ib/hr) = ppm x MW·x (2.64x10-9) x

### ffx HVx FL

## x[20.9/ (20.9 - O2%)] Where: ppm -is the emission concentration in ppmvd @ 150/0 O2 (10 ppmv) MW is the molecularweight ofthe pollutant: (MWNH3 

### = 17 Ib/lb-mol) 2.64 

### x 10-9 is one overthe molar specific·volume (lb-mol/MMscf, at 60 of) ff is the F-factorfor natural gas: (8,578 scf/MMBtu,'at 60 

### OF) HV isthe heating value of natural gas: (1,013 Btu/set) 

### FL is the amount of natural gas each turbine can burn in any given hour: (CTG w/o duct burner 1.832 MMscf/hour, as calculated below) (1 ,856.3 MMBtu/hr) .::- (1,013 MMBtu/MMsct) =1.832 MMscf/hr 

## 92 is the stack oxygen content to which the emission concentrations are corrected:**(15°~)** NH3 Emission Rate (Ib/hr)

# =10 x 17 x (2.64x1·0-9) (lb-mol/MMsct) x 8,.578 (scf/MMBtu) x 1,013 (Btu/set) x 1.832 (MMscf/hr) x [20.9/ (20.9
- 15.0)]


### = 25.31 Ib-NH3/hr

Mass Emission Rates 13.55 8.35 3.34 8.91 5.23 25.31 erturbine, Ib/hr ppmvd 

### @ 15% O2 2.0 2.0 1.4 10.0 limits Ib/MMBtu* 0.0073 0.0045 0.0018 ·0.0048 0.00282

* Emission factors were taken from Table 6.2-1.1 in the ATe application submittal.

Maximum Emission Rate With Duct Burner Firing: The worst-case NOx, SOx, PM 10, CO,VOC, and NH3 mass emission rates are when each turbine operates at 

### tOO% load and an ambient air inlet temperature of 101°F. The worst-case SOx mass emission rate. will be determined assuming a natural gas sulfur content of 1 gr 8/100 scf. The following equation will be**us~d** to calculate the e·mission rate ofthe CTG with the duct burnerfiring: Emission Rate (Ib/hr) :::: [CTG Max Heat Input 

### + Duct Burner Max Heat Input] (MMBtu/hr) x Emission Factor (lb/MMBtu) NOx Emission Rate (Ib/hr)

# =(2,356.5 MMBtu/hr) x (0.0073 Ib-NOxlMMBtu) 

# =17.20 Ib-NOx/hr

12

### AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination

### ofCompliance, C-1080386
CO Emission Rate (Ib/hr) 

### = (2,356.5 MMBtu/hr) x .(0.0045 Ib-CO/MMBtu) 

# =10.60 Ib-CO/hr 

## voe Emission Rate (Ib/hr)

# =(2,356.5 MMBtu/hr) 

### x (0.0025 Ib-VOC/MMBtu) =5.89 Ib-VOC/hr PM 10 Emission Rate (Ib/hr)

# =(2,356.5 MMBtu/hr) 

### x (0.0050 Ib-PM 10/MMBtu) 

# - =11.78 Ib-PM10 /hr SOx Emission Rate (Ib/hr)

# =(2,356.5 MMBtu/hr) 

### x(0.00282 Ib-'SOx/MMBtu) =.6.65Ib-SO

### x /hr NH3 Emission Rate (Ib/hr)

# =ppm 

### x MW x (2.64x10-9) 

### xffx HVxFL

### x [20.9 / (20.9 - O2°/0)] Where: ppm is the emission concentration ,in ppmvd 

### @ 15% O2 (10 ppmv) MW is the molecularweight ofthe pollutant: (MWNH3 

### = 17 Ib/lb-mol) 2.64 x 10-9 is onE? overthe molar specificvolume (lb-mol/MMscf, at 60 of) ff is the F-factorfor natural gas: (8,578 scf/MMBtu, at 60 OF) HV is the heating value of natural gas: (1,013 Btu/set) FL is the amount of natural gas each turbine can burn in any given hour: (CTG w duct burner2.326 MMscf/hour, as calculated below) (2,356.5MMBtu/hr) + (1,013 MMBtu/MMsct)

# =2.326 MMscf/hr O2 is the stack oxygen conte.nt to which the emission concentrations are corrected: (15%) NH3 Emission Rate (Ib/hr) 

### = 10 x17 x (2.64x10-9) (lb-mol/MMsct) x 8.,578 (scf/MMBtu) 

### x 1,013 (Btu/set) x 2.326 (Mrylscf/hr) 

### x [20.9 / (20.9
- 15.0)] 

# =

32.13Ib-NH3/hr

Mass Emission Rates 17.20 10.60 5.89 11.78 6.65 32.13

erturbine, Ib/hr ppmvd @ 150/0 O2 2.0 2.0 2.0 10.0 limits Ib/MMBtu* 0.0074 0.0045 0.0025 0.0050 0.00282

* Emission factors were taken from Table 6.2-1.1 in the ATC application submittal.

13AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination

### ofCompliance, C-1080386

Maximum Mass Emission Rate (per 160 1,000 16 N/A(6) N/A(6) turbine, Ib/hr) Average Mass N/A(6) N/A(6) Emission Rate (per 80 900 16 turbine, Ib/hr) ii. C-3953-12-0 (Boiler) F·or the new boiler, the emissions factors for NOx, CO, VOC, and PM 10 are provided by the applicant. The SOx emission factor is calculated as shown below.

NO

### x 9.0 0.011 CO 50.0 0.037 

## vae 10.0 0.0043 PM 10 0.005 SOx** 0.00282 *Note: Ib/MMBtuequivalent of ppmv values @ 3% O2 as provided by the Applicant ** SOx emission factor based ·on the maxir:num proposed sulfur content of 1 gr/100 dscf. (1 gf-S/1 OO·GsGfx 1 tb-S/7000 9fx 64 Ib SOx/32 tb-S x 1 SGf/1 013 StYx 106 StY/MMBtu) 

## =0.00282 Ib/MMBtu 

### iii. C-3953-13-0 (DiesellC engine powering fire water pump) Forthe new emergency diesel-fired IC engine powering a fire water pump, the emissions factors for NOx, CO,VOC, and PM 10 are provided by the applicant and are guaranteed' by the engine manufacturer. The SOx emission factor is calculated using the sulfur 'content in the diesel fuel 

### (0·.0015°J'c> sulfur).

6 PM10 and SOx emissions during startups and shutdowns are lower than maximum hourly emissions during baseloa'd facility operation. 14

### AvenalPowerCenter, LLC**(08-AFC~01)** SJVACPO Determination ofCompliance, C-1080386



### NOx 3.4 ine Manufacturer 

## eo 0.447 ine Manufacturer 

## voe 0.38 ine Manufacturer PM 10 

### 0.059 En ine Manufacturer *SOx 0.005 Mass Balance Equa ion Below

* 7.1Ib·fuel
. 21b· S02 1gal 1hp input 2,542.5 Btu 453.6 g g SOx

0.0015% x x --- x x x x = 0.005

-- gallon lib· S 137,000Btu 0.35 hp out hp· hr lb hp· hr iv. C-3953-14-0 (Natural gaslC engine powering electrical generator) 

### Forthe new'emergency natural gas-fired 

### Ie engine powering an electrical generator, the emissions factors for NOx, 

## eo, vae, and PM 10 

### are provided by the applicant and are guaranteed by the engine manufacturer. The SOx emission factor is .calculated using the fuel sulfur contentfrom District PolicyAPR 1720.

NO

### x 

# co voe **SOx 0.0094 ineManufacturer ine Manufacturer ine Manufacturer En ine Manufacturer Mass Balance Equation Below **SOx is calculated as follows: Ib-SOx IMMBtu 2.,542.5Btu Ibhpinput 453.6g 0.00285 x x . x x -- = 0.0094 MMBtu 1,000,000Btu bhp

- hr 0.35bhpout lb**C~.** Calculations 1. Pre-Project Potential to Emit (PE1) g-SOx bhp-hr



### Section 3.26 of Rule 2201 defines the potential to emit (PE) as the maximum capacity of an emissions unit to emit a pollutant under its physical and operational design. Since this is a brand new facility, the pre-project potential to emit (PE1) for all the emissions units associated with this project is equal to zero.

15

### AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
2. Post Project Potential to Emit (PE2): 

### i. C-3953-10-0 and C-3953-11-0 (Turbines)


### a. Maximum HourlyPE The maximum hourly potential to emit for NOx, eO,and voe fro·m each CTG will occur when the unit is operating under start-up mode. The maximum hourly PE for both turbines operating together is when both are starting up and firing theirduct burners. The combined startup NOx emissions from the two turbines will be limited .to 240 Ibs/hr [maximum startup emission rate (160 Ibs/hr) + average startup emission rate (80 Ibs/hr)]. Similarly, the combined startup eo emissions from the two turbines will be limited to 1,902 Ibs/hr, [maximum startup emission rate (1,000 Ibs/hr) + average startup emission rate (9'02 Ibs/hr)]-.

. The maximum hourly emissions are summarized in the table below:

NOx 160 17.20 13.55 13.55 240.00 CO 1,000 10.60 8.35 8.35 1,902.00 VOC 16 5.89 3.34 3.34**-~** 32.00 PM 10 N/A 11.78 8.91 8.91 23.56 SOx N/A 6.65 5.23 5.23 13.30 NH3 N/A 32.13 25.31 25.31 64.26 

### b. Maximum DailyPE 'Maximum daily emissions for NOx, eo, and voe occurs when each CTG undergoes six (6) hours operating in startup or shutdown mode, and eighteen (18) hours operating with duct burner firing at full load. The startup and shutdown emissions for PM 10, SOx, and NH3 are will be lower or equivalentto the emissions rate when the unit is fired at 100% load; therefore the maximum daily emissions for PM1o, SOx, and NH3 occurs when each CTG**i~operated** fortwentyfour (24), hours with duct burnerfiring at full load. The results are summarized in the table below:

7 PM10 and SOx emissions during startups and shutdowns are lowerthan maximum hourly emissions. 16AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386

NO

### x 

# eo voe sox

c. MaximumAnnualPE ' 17.201b/hr 10.601b/hr 5.89lb/hr 11.781b/hr 6.65lb/hr 32.131b/hr 13.03 Ib/hr 8.35lb/hr 3.34,lb/hr 8.91 Ib/hr ' 5.23lb/hr 25.31 Ib/hr 789.61b/da 5,590.8 Ib/da

202.01b/da 282.71b/da 159.61b/da 771.1 Ib/da

The facility has indicated that the turbines will be operated in one of three different scenarios: weekend and weekday hot start scenario, weekend shutdown and weekday hot start scenario, and baseload scenario. The SOx emission factors used to calculate the annual potential emissions will be based on the applicant proposed average natural gas sulfur limit 0.36'gr/1'OO dscf. SOx EF

# =(0.36 w:-8/100 

### x(1 tb-S/7000.gr:t

### x (64 Ib SOx/32 

### x (1 SGf/1013

## Bkltx (106 Btu/MMBtu)


### =0.001 Ib-SOx/MMBtu eTG w/o Duct Burner Firing: SOx Emission Rate (Ib/hr)

# =(1,856.3 MMBtu/hr) 

### x (0.001 Ib-SOx/MMBtu) 

# =1.86 Ib-SOx/hr erG wI Duct Burner Firing: SOx Emission Rate (Ib/hr)

# =(2,356.5 MMBtu/hr) 

### x (0.001 Ib-SOx/MMBtu) 

# =2.36 Ib-SOx/hr ' Potential annual emissions for each pollutant will be calculated for each of the three scenarios in the tables below:

17AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
Scenario 1) Weekend and Weekday Hot Start: 

### 547.5 (1.5 hr/hot start 

### x .365 hot start/yr) hours operating in startup and shutdown mode, 800 hours operating while firing at full load with the duct burner, and 6,683 hours operating while firing at full load without the duct burner. Since startup and shutdown emission rates for PM 10, 

### sax, and NH3 are less than the emission rate when the eTG is fired at 100% 

### load w/o 

### the duct burner, the startup and ,shutdown emission rates will be assumed to be equivalent to the CTG fired at 100% load w/o 

### the duct burner. Since the CTGs will be fired throughout the year, the emission factors for the unitwhen fired atthe average ambient temperature (63 0 

### F) will be used to calculate the potential annual emissions.

NOx 80 Ib/hr (avg)**16~34** 

### 'Ib/hr ' 13.031b/hr CO 900 Ib/hr av 10'.60 Ib/hr 8.35 Ib/hr VOC 16 Ib/hr (avg) 5.68 Ib/hr 3.17 Ib/hr PM 10 

### N/A 11.271b/hr 9.001b/hr sax N/A 2.36 Ib/hr 1.86 Ib/hr NH3 

### ,N/A 32.13 Ib/hr 25.31 Ib/hr
* Emission factors were taken from Table 6.2-1.1 in theATC application submittal.

Scenario 2) Weekend Shutdown and Weekday Hot Start: 143,951 Ibl ear 557,0331bl 

### ear 34,489 Ibl ear 

### 74,091 Ibl ear 15,3371bl ear 20'8,708 Ibl 

### ear

624 «1.5 hr/hot start 

### x 208 hot start/yr) + 

### (6.0 hr/cold start 

### x 52 cold starts/year)) 

### hours operating in startup and shutdown mode, 800 hours operating while firing at full load with the duct burner, and 3,800 hours operating while firing at full ·Ioad without the duct burner. Since startup and shutdown emission rates for PM 10, 

### SOx, and NH3 are less than the emission rate when the CTG is fired at 100% load w/o 

### the duct burner, the startup and shutdown emission rates will be assumed to be equivalent to the CTG fired at 100% 

### load w/o 

### the duct burner. Since the CTGs will be fired throughout the year, the ··emission factors for the unit when fired at the ave'rage ambient temperature (63 0 

### F) will be usedto calculate the potential annual emissions.



### 18

### AvenalPowerCenter, LLC(08-AFC-01) SJVACPD Determination of·Compliance, C-10B0386

112,506 Ibl ear 601,810 

### Ibl ear

26,574 Ibl ear 48,832 Ibl ear 10,117 Ibl ear 13·7,675Ibl ear
Scenario 3) Baseload: 80.0 hours operating while firing at full load· with the duct burner, and 7,960 hours operating while firing at full load without the duct burner. Since the CTGs will be fired throughout the year, the emission factors for the unit when fired at the average ambient temperature (630 F) will be used to calculate the potential annual emissions.

116,791 Ibl ear 74,9461bl ear ·29,777 Ibl ear 80,656 

### Ibl ear 16,694 

### Ibl ear 219,972 

### Ibl ear



### 19

### AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
Maximum Annual Potential to Emit: The highest annual potential emissions, for· each pollutant, from the three different scenarios will be taken to determine the maximum annual potential to emit for the CTG. The results are summarized in thetable below:

NO

### x 

## co VOC 

## sax 143,951 Ibl ear 

### 601,8101bl ear 34,489 Ibl ear 

### 80,656 Ibl ear 16,694 Ibl ear 219,972 Ibl ear Scenario 1 Scenario 2 Scenario 2 Scenario 3 Scenario 3 Scenario 3 

### d. Maximum QuarterlyPE Maximum quarterly emissions for each unit will be determined by dividing the maximum annual emissions into 4 quarters:

15 Quarter 2" Quarter 3r Quarter 4 Quarter 35,987'.75**35,987~75** 35,.987.75 35,987.75 150,452.5 8,62,2.25 150,452.5 ,8,622.25 150,452.5 8,622.25 150,452.5 8,622.25. 20,164 20,164 20,164 20,164 4,173.5 4,173.5 4,173.5 4,173

..5 54,993 54,993 54,993 54,993 ii. 

### C.-3953-12-0 (Boiler) The potential to emit for the boiler is calculated 'as follows, and summarized in the'table below. PENOx 

# = (0.011 Ib/MMBtu) 

## * (37.4 MMBtu/hr) 

# = 0.41 Ib NOx/hr



# = (0.011 Ib/MMBtu) 

## * (37.4 MMBtu/hr) 

## * (12 hr/day) 

# = 4.9 Ib NOx/day



### = (0.011 Ib/MMBtu) 

## * (37.4 MMBtu/hr) 

## * (1,248 hr/year) 

# = 513 Ib ,NOx/year



# = (513 IbNOx/year) + (4 qtr/year) 

# = 128 IbNOx/qtr

20AvenalPowerCenter, LLC (OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386


### PEco = (0.037 Ib/MMBtu) 

## * (37.4 MMBtu/hr)


### = 1.38 Ib CO/hr



### = (0.037 Ib/MMBtu) 

## * (37.4 MMBtu/hr) 

## * (12hr/day)


### = 16.6 Ib CO/day



### = (0.037 Ib/MMBtu) 

## * (37.4 MMBtu/hr) 

## * (1,248hr/year)


### = 1,727 Ib CO/year



### = (1,727 Ib COlyear).

## * (4 qtr/year)


### = 432 Ib CO/qtr 

### PEvoc = (0.0043 Ib/MMBtu) 

## * (37.4 MMBtu/hr) 

# = 0.16 Ib VOC/hr



### = (0.0043 Ib/MMBtu)

## * (37.4 MMBtu/hr) 

## * (12 hr/day)


### = 1.9 Ib VOC/day



### = (0.0043 Ib/MMBtu) 

## * (37.4 MMBtu/hr) 

## * (1,248 hr/year)


### = 201 Ib VOC/year



### = (2011:b/year) 

## * (4 qtr/year) 50lbVOC/qtr 

### PEpM10 

### = (0.005 Ib/MMBtu) 

## * (37.4 MMBtu/hr)


### = 0.19 Ib PM10/hr



### = (0.005 Ib/MMBtu) 

## * (37.4 MMBtu/hr) 

## * (12 hr/day)


### = 2.2 Ib PM10 /day



### = (0.005 Ib/MMBtu) 

## * (37.4 MMBtu/hr) 

## * (1,248 hr/year)


### = 233 Ib PM10/year



### = (233 Ib/year) 

## * (4 qtr/year)


### = 58 Ib PM10 /qtr 

### PEsox 

### = (0.00282 Ib/MMBtu) 

## * (37.4 MMBtu/hr)


### = 0.11 Ib SOx/hr



### =**(0~00282** Ib/MMBtu) 

## * (37.4 MMBtu/hr) 

## * (12 hr/day)


### = 1.31b SOx/day



### = (0.00282 Ib/MMBtu) 

## * (37.4 MMBtu/hr) 

## * (1,248 hr/year)


### = 132 Ib SOx/year

21AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386



# = (132 Ib/year) 

## * (4 qtr/year) 

# = 33 Ib SOx/qtr

NO

## x 0.41 4.9 128 513 

## eo 1.38 16.6 432 1,727 

## voe 0.16 1.9 50 201 PM 10 0.19 2.2 58 233 

## sox 0.11 1.3 33 132 iii. C-39'53-13-0 (DiesellC engine powering fire water pump) The emissions for the emergency fire pump engine is calculated as follows, and summarized in the table below: PENOx -- (3.4 g/hp· hr) * (288 hp) ..;- (453.6 glib) 

# = 2.161b NOx/hr



### = (3.4g/hp·hr)* (288 hp) ..;- (453.6 glib) * (24 hr/day)

= 51.8 Ib NOx/day

= (3.4 g/hp·hr) * (288 hp)..;- (453.6 glib) * (12.5 hr/qtr)



### = 27 Ib NOx/qtr

= (3.4 g/hp· hr) * (288 hp) ..;- (453.6 glib) * (50 hr/year)

= 108 Ib NOx/year PEco = (0.447 g/hp· hr) * (288 hp) ..;- (453.6 glib) 

# = 0.28 Ib CO/hr

= (0.447 g/hp· hr) * (288 hp) ..;- (453.6 glib * (24 hr/day)

= 6.8 Ib CO/day

= (0.447 g/hp· hr) * (288 hp) ..;- (453.6 glib) * (12.5 hr/qtr)

= 41b CO/qtr

= (0.447 g/hp· hr) * (288 hp) ..;- (453.6 glib) * (50 hr/year)

= 14 Ib CO/year

22AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386


### PEvoc 

# = (0.38 g/hp· hr) 

## * (288 hp) -;- (453.6 glib)



### = 0.24 Ib VOC/hr



# = (0.38 g/hp
-hr) 

## * (288 hp) -;- (453.6 glib) * (24 hr/day) 

# = 5.8 Ib VOC/day



# = (0.38 g/hp
-hr) 

## * (288 hp) -;- (453.6 glib) * (12.5 hr/qtr) 

# = 31b VOC/qtr



# = (0.38 g/hp hr) * (288 hp) -;- (453.6 glib) * (50 hr/year) 

# = 12lbVOC/year 

### PEpM10

# = (0.059g/hp· hr) * (288 hp) -;- (453.6 glib) 

# = 0.04 Ib PM10 /hr



# = (0'.059 g/hp
-hr) 

## * (288 hp) -;- (453.6 glib) * (24 hr/day) 

# = 0.9 Ib PM10/day



# = (0.059 g/hp hr) 

## * (288 hp) + (453.6 glib) * (12.5 hr/qtr) 

# = 0.51b PM10/qtr



# = (0.059 g/hp-hr) * (288 hp) -;- (453.6 glib) 

## * (50 hr/year) 

# = 1.9 Ib PM10/year 

### PEsox 

# = (0.005 g/hp
-hr) * (288 hp) -;- (453.6 glib) 

# = 0.00 Ib SOx/hr



# = (0.005 g/hp-hr) 

## * (288 hp) + (453.6 glib) 

## * (24 hr/day) 

# = 0.1 Ib SOx/day



# = (0.005 g/hp-hr) *.(288 hp) -;- (453.6 glib) * (12.5 hr/qtr) 

# = oIb SOx/qtr



# = (0.005 g/hp
-hr) * (288 hp) -;- (453.6 glib) * (50 hr/year) 

# = oIb SOx/year

.

NO

### x 2.16 51.8 27 108 CO· 0.28 6.8 4 14 

# voe 0.24 5.8 3 12 PM 10 0.04 0.9 0.5 2 

## sax 0.00 0.1 0 0 23

### AvenalPowerCenter, LLC(08-AFC-01) SJVACPO Determination ofCompliance, C-1080386

iv. C-3953-14-0 (Natural gaslC engine powering electrical generator) The emissions for the emergency 

## Ie engine is calculated as follows, and summarized in the table below: ' 

### PENOx 

### = (1.0 g/hp· hr) 

## * (860 hp) +**(4~3.6g/lb)** 

# = 1.90 Ib NOx/hr



### = (1.0 g/hp· hr) 

## * (860 hp) + (453.6 glib) * (24 hr/day)



### = 45.5 Ib NOx/day



# = (1.0 g/hp· hr) * (860 hp) + (453.6 glib) * (12.5 hr/qtr) 

# = 24 Ib NOx/qtr



### = (1.0 g/hp·hr) * (860 hp)+ (453.6 glib) 

## * (50 hr/year)



### = 95 Ib NOx/year

. 

### PEco 

### = (0.6 g/hp· hr) * (860 hp) + (453.6 glib) 

# = 1.14IbCO/hr



# = (0.6 g/hp· hr) * (860 hp) + (453.6 glib) * (24 hr/day) 

# = 27.3 Ib CO/day



# = (0.6 g/hp· hr) * (860 hp) + (4'53.6 glib) * (12.5 hr/qtr) 

# = 141b CO/qtr



# = (0.6 g/hp· hr) * (860 hp) + (453.6 glib) * (50 hr/year)



### - 57 Ib CO/year 

### PEvoc 

# = (0.33 g/hp·hr).* (860 hp) +**(45~.6** glib) 

# = 0.63 Ib VOC/hr



### = (0.33 g/hp· hr) * (860 hp) + (453.6 glib) * (24 hr/day) 

# = 15.0 Ib VOC/day



### = (0.33 g/hp· hr) 

## * (860 hp) + (453.6 glib) * (12.5 hr/qtr)



### = Sib VOC/qtr



### = (0.33g/hp· hr) * (860 hp) + (453.6 glib) * (50 hr/year)



### = 31 IbVOC/year

24AvenalPowerCenter, LLC(OB-AFC-01) SJVACPD Determination·ofCompliance, C-1080386 PEpM10

# = (0.034 g/hp· hr) 

## * (860 hp) + (453.6 glib) 

# = 0.061b PM10 /hr



# = (0.034g/hp·hr) 

## * (860 hp) + (453.6 glib) 

## * (24 hr/day) 

# = 1.5 Ib PM10/day



# = (0.034 g/hp·hr) 

## * (860 hp) + (453.6 glib) 

## * (12.5 hr/qtr) 

# = 1 Ib PM10/qtr



# = (0.034 g/hp· hr) 

## * (860 hp) + (453.6 glib) 

## * (50 hr/year) 

# = 3 Ib PM10/year PEsox 

# = (0.0094 g/hp· hr) 

## * (860 hp) 

### + (453-.6 glib) 

# = 0.02 Ib SOx/hr



# = (0.0094 g/hp· hr) 

## * (860 hp) +**(453~6** glib) 

## * (24 hr/day) 

# = 0.4 Ib SOx/day



# = (0.0094 g/hp·hr) 

## * (860 hp) + (453.6 glib) 

## * (12.5 hr/qtr) 

# = oIb SOx/qtr



# = (0.0094 g/hp· hr) 

## * (860 hp) + (453.6 glib) 

## * (50 hr/year) 

# = 1 Ib SOx/year

NOx 

## co voe SOx 1.90 1.14 0.63 0.06 0.02 45.5 27.3 15.0 1.5 0.4 24 14 

### 8 1 

# o 95 5-7 31 

### 3 1 3. Pre-Project Stationary Source Potential to Emit (SSPE1) Pursuant to Section 4.9 of DistrictRule 2201, the Pre-project Stationary Source Potential

_ to Emit (SSPE1) is the Potential to Emit (PE) from all units with valid Authorities to Construct (ATG) or Permits to Operate (PTO) at the Stationary Source and the quantity of emission reduction credits (ERG) which have been banked since September 19, 1991 for Actual Emissions Reductions that have occurred at the source, and which have not been uS.ed on-site. Since this is a new facility, there are no valid ATGs, PTOs, or ERGs atthe Stationary Source; therefore, the SSPE1 will be equal to zero.


### 25AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
4. Post-Project Stationary Source Potential to Emit (SSPE2) 

### Pursuant to Section 4.10 of District Rule 2201, 'the Post Project Stationary Source Potential to Emit (SSPE2) is the Potential to Emit (PE) from all units with valid Authorities to Construct (ATC) or P'ermits to Operate (PTa) at the Stationary Source and the quantity of emission reduction credits (ERC) which have been banked since September 19,1991 for Actual Emissions Reductions that have occurred at the source, and which have not been used on-site. '

C-3953-10-0 143,951 601,810 34,489 80,656 16,694 219,972 C,-3953-11-0 ' 143,951 601,810 34,489 80,656 16,694 219,972 C-3953-12-0 513 1,727 201 233 132 ° C-3953-13-0 108 14 12 2 ° 

# ° C-3953-14-0 95 

### 57 31 3 1 

### 0 Post-project SSPE 

### 288,618 1,205,418 69,222 161,550 33,521 439,944 (SSPE2) 

### 5. Major Source Determination 

### Pursuant t9 Section 3.24 of District Rule 22°1, a major source is a stationary source with post-project emissio'ns or a Post-project Stationary Source Potential to Emit (SSPE2), equal to orexceeding one or more, ofthe following threshold-values.

1,205,418 200,000 Yes 6. Annual Baseline Emissions (BE) 

### Per District Rule 2201, Section 3.7, the baseline·emissions, for a given pollutant, shall be equal to the pre-project potential to emitfor:

• Any emission unit located at a non-majorsource, • Any highly 'utilized emission unit, located at a majorsource, • Anyfully-offset**emi~sion** 

### unit, located at a majorsource, or • Any clean emission unitlocated at a majorsource

26AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386 otherwise·, BE 

### = HistoricActual Emissions (HAE), calculated pursuant to Section 3.22 of District Rule 2201 ·Asshown above, this facility will be a major so.urce for NOx, CO, VOC, and PM 10 emissions after this project. However, since the units in this project are all new emissions units, there are no historical actual emissions or pre-project potential to emit. Therefore, the baseline NOx, CO, VOC, PM 10 and sax emissions will be set equal to the following: BE =0 Ib/year 

### 7. Major M·odification Major Modification is defined in 40 CFR Part 51.165 as "any physical change in or change in the method ofoperation of

### a majorstationary source that would result in 

### a

.significantnetemissions increase ofanypollutantsubjectto regulation undertheAct."

. Since this isa n·ewfacility, this project cannot be considered a Major Modification.



### 8. Federal Major Modification As shown above, th·is. project 'does not. constitute a Major Modification. Therefore, in. accordance with District Rule 2201 , Section 3.17, this project does not constitute a Federal Major Modification 'and no further discussion is required.


### VIU. COMPLIANCE: Rule 10BO StackMonitoring This Rule grants.the APGO the authority to request the installation and use of continuous emissions monitors (GEMs), and specifies performance standards for the equipment and administrative requirements for recordkeeping, re.porting, and notification. 

### i. C-3953-10-0 

### and .C-3953-11-0 

### (Turbines) The two GTGs will be equipped with operational GEl\lls for NO

### x, CO, and 

### 02. 'Provisions included in the operating permit are consistent with the requirements of this Rule. Compliance with the requirements ofthis Rule is anticipated.

27AvenalPowerCenter, LLC(08-AFC-01) SJVACPO Determination ofCompliance, C-1080386 ProposedRule 1080 Conditions:



### • The owner or operator shall install, certify, maintain, operate and quality-assure a Continuous Emission M'onitoring System (CEMS) which continuously measures and records the exhaust gas NO

### x, CO and 

### 02 concentrations. Continuous emissions monitor(s) shall be capable of monitoring emi.ssions during normal operating conditionsJ. and during startups and shutdowns., provided the CEMS passes the relative accuracy requirement for startups and s'hutdowns specified herein. If relative accuracy of CEMS cannot be demonstrated during startup' conditions, CEMS results during startup and shutdown events shall'be replaced 'with startup emission rates obtained from source testing to determine compliance with emission limits contained in this document. [District Rules 1080 and 4703

.and 40 CFR 60.4340(b)(1)]

• The CEMS shall complete a minimum of one cycle of operation (sampling, analyzing, and data recording) .foreach successive 15-minute period orshall meet equivalent specifications established by mutual agreement ofthe District, the ARB and the EPA. [District Rule 1080 and 40 CFR 60.4345(b)]

• The NOx, 

### CO and O2 

### CEMS shall meet the requirements. in 40 CFR 60, Appendix F Procedure 1 and Part 60, Appendix. B Performance Specification 2 (PS 2), or shall meet equivalent specifications established by mutual agreement of the District, the ARB, and the EPA. [District Rule' 1080 'and 40' CFR 69.434.5(a)]

• Audits of continuous emission monitors shall be conducted quarterly, except during quarters in which relative accuracy and compliance source testing are both performed, in accordance with EPA guidelines. The District shall be notified prior to completion of the audits. Audit reports shall be submitted along with quarterly compliance reports to the District. [District Rule 1080]

• The owner/operator shall perform a relative accuracy test audit (RATA) for NOx, 

### CO and O2 

### as specified by 40 CFRPart 60, Appendix F, 5.11, at least once every four calendar quarters. The permittee shall comply with the applicable requirements for quality assurance testing and maintenance of the continiJous emission monitor equipment in accordance with the procedures and guidance specified in 40 CFR Part 60, Appendix F. [District Rule 1080]

• APCO or an authorized representative shall be allowed to inspect, as determined to be necessary, the required monitoring devices to ensure that such devices are functioning properly. [District Rule 1080]

• Results of the CEM system shall be**av~raged** 

### over a one hour period for NO

### x emissions and a three hour period for CO emissions using consecutive 15-minute sampling periods in accordance with all applicable requirements of CFR 60.13. [District Rule 4703 and 40 CFR 60.13]



### 28Avena/PowerCenter, LLC(08-AFC-01) SJVACPO Determination ofCompliance, C-1080386



### • Results of continuous emissions monitoring shall. be reduced according to the procedures established in 40 CFR, Part 51, Appendix P, paragraphs 5.0 through 5.3.3, or by other method.s deemed equivalent by mutual agreement with the District, the ARB, and the EPA. [District. Rule 1080]

• ·The owner or operator shall,upon written notice from the APCO, provide a

.summary of the data obtained from the CEM systems. This summary shall be in the form and the manner prescribed bythe APCO. [District Rule 1080]

• The facility shall install and maintain equipment,facilities, and systems compatible with the District's CEM data polling software system and shall make CEM data available to the District's automated polling system on 

# adaily basis. [District Rule 1080]

• Upon notice .by the District that the facility's CEM system is not providing polling data, the facility may continue to operate without providing automated data for a maximum of 30 days per calendar year provided the CEM data is sent to the District by a District-approved alternative method. [District Rule'1 080]

• The permittee shall maintain the following records:' the date, time and .duration of any m·alfunction of the continuous monitoring equipment; dates of performance testi.ng; dates of evaluations., calibrations, checks,

.and adjustments of the continuous monitoring equipment; date and time peri'od which a continuous monitoring system or monitoring device was in,operative. [District Rules 1080 and 2201 and 40 CFR 60.8(9)]

• The owner or operator shall submit a written report of CEM operations for each calendar quarterto the APCO. The report is due on the 30th day following the end of the calendar quarter and shall include the following: Time intervals, data and magnitude of excess NOx emissions, nature and the cause of excess (if known), corrective actions taken and 'preventive measures adopted; Averaging period used. for data reporting corresponding to the averaging period specified in the emission**te~t** 

### period used to determine compliance with an emission standard; Appl,icable time and date of each period during which theCEM was inoperative (monitor downtime), except for zero and span checks, and the nature of system repairs and adjustments; A negative declaration when no excess emissions occurred. [District Rule 1080 and 40 CFR 60.4375(a) and 60.4395] \"



### 29AvenalPowerCenter, LLC(08-AFC';'01) SJVACPD Determination·ofCompliance, C-10B0386


### ii. C-3953-12 (Boiler) The boiler will be equipped with operational CEMs for NO

### x, CO, and 

### 02. Provisions included in the operating permit are consistent with the requirements of this Rule. Compliance with the requirements ofthis Rule is anticipated. ProposedRule 1080 Conditions:

• {1832} The exhaust stack shall be equipped with a continuous emissions monitor (CEM) for NOx., CO, and 02. The CEM shaH meet the requirements of 40 CFR parts 60 and 75 and shall be capable of monitoring emissions during startups and shutdowns as well as during normal operating conditions. [District Rules 2201 and 1080]

• {1833} The' facility shall install and maintain equipment, facilities, and" systems compatible with the District's GEM data polling software system and shall make CEM data available to the District's automated pollin·g system on a daily basis. [District Rule 1080]

• {1834} Upon notice bythe District thatthe facility's CEM system is not providing poUing data, the facility may continue to \ operate" without providing automated data for a maximum of 

### 30 days per·calendaryear provided the GEM data is sent to the District by a I;)istrict-approved alternative method. [District Rule 1080]

• {1836} Results of continuous emissions monitoring shall be reduced according to ·the procedure established in 40 GFR, Part 51, Appendix P,paragraphs 5.0 through**5~3.3,** or by other methods deemed equivalent by mutual agreement with the District, the ARB, and the EPA. [District Rule 1080]

• {1837} Audits of continuous emission monitors shall be conducted quarterly,except during quarters in which relative accuracy and total accuracy testing is performed, in accordance with EPA guidelines. The District shall be notified priorto completion ofthe audits. Audit reports shall be submitted along with quarterly compliance reports to the District. [District Rule 1080]

• {1838} The owner/operator shall perform a relative accuracy test audit (RATA) as specified by 40 CFR Part 60, Appendix F, 5.11, at least once evety four calendar quarters. The permittee" shall comply with the applicable requirements for quality assurance testing and maintenance of the continuous emission monitor equipment in accordance with the procedures and guidance specified in 40 CFR Part 60, Appendix F. [District Rule 1080]

. .

30AvenalPowerCenter, LLC(08-AFC-01) SJVACPO Determination ofCompliance, C-1080386

• {1839} The permittee shall submit a written report to· the APCO for each calendar quarter, within 30 days ·of the end of the quarter, including: time intervals, data and ma'gnitude of excess emissions, nature and cause of excess emissions· (if known), corrective actions taken and preventive measures adopted; averaging period used for data reporting .shall correspond to the .averaging period for each respective emission standard; applicable time and date of each period during which the C.EM was inoperative (except for zero and span checks) and the nature of system repairs and adjustments; and a negative declaration when no excess emissions occurred. [District Rule 1080]
Rule 1081 Source Sampling This RuJe requires adequate 'and safe facilities for use in sampling to determine

. compliance with emissions limits, and specifies methods and .procedures for source

testing and sample collection. 

### i.**C-3~53-1** 0-0 .and C-3953-11-0 (Turbines) The requirements of this Rule will be included in the operating permits. Compliance with this Rule is anticipated. ProposedRule 1081 Conditions:

• The exhaust stack shall be equipped with permanent provisions to allow collection of stack gas samples consistent with EPA test methods and shall be equipped with safe permanent provisions to sample stack gases with a portable NOx, CO, and 

### 02 .analyzer during District inspections. The sampling ports shall be located in accordance with the CARB regulation titled California. Air Resources Board Air Monitoring Quality Assurance Volume VI, Standard Operating Procedures for Stationary Emission Monitoring and Testing. [District Rule 1081]

• Source testing to measure startup NOx, CO, and VOCmass emission rates shall be conducted for one of the gas turbines (C-3953-10 or C-3953-11) pri"or to the end of the commissioning period and at least once every seven'years**thereaft~r.** GEM relative accuracy shall be determined during startup source testing in accordance with 40 CFR 60, Appendix B. [District Rule 1081]

• Source testing (with and without duct burner firing) to measure the NOx, CO, and VaG emission rates (Ib/hr and ppmvd 

### @ 15°1'<> 02) shall be conducted within 60 days after the end of the commissioning period and at least once every twelve months thereafter. [District Rules 1081 and 4703]

31

.AvenalPowerCenter, LLC(OB-AFC-01) SJVACPD Determination ofCompliance, C-10803'86

• Source testing. (with and without duct burnerfiring) to measure the PM10 emission rate (Ib/hr) and the ammonia emission rate shall be conducted within 60 days after the end of the commissioning period and at least once every twelve months thereafter. [District Rule 1081]

• Compliance with natural gas sulfur content limit shall be demonstrated within 60 .days after the end of the commissioning period and weekly thereafter. After demonstrating compliance with the fuel sulfur content limit for 8 consecutive weeks for a fuel source, then the testing frequency shall not be less than monthly.

If a test shows noncompliance with the sulfur content requirement,the source must return to weekly testing until eight- consecutive weeks show compliance. [District Rules 1081,2540, and 4001]

• Demonstration of compliance with the annual average ·sulfurcontent limit shall be demonstrated by a 12 month rolling average of. the sulfur content either· (i) documented in a valid purchase contract, a supplier certification, a tariff sheet or transportation contract or (ii) tested using .ASTM Methods D1072, D3246, 04084, 04468, 0481-0,D6228, 06667 or Gas Processors· Association Standard 2377. [District Rules 1081 and 2201]

• Compliance demonstration (source testing). shall be District witnessed, or authorized and samples shall be collected by a California Air Resources Board certified testing laboratory

.. Source testing shall be conducted using the methods and procedures approved ·by the District. The District must be notified 30 days prior to any compliance source test, and a source test plan must be submitted for approval 15 days prior to testing. The results of each source test shall be submitted to the Districtwithin 60 days thereafter. [District Rule 1081]

• The following test.methods shall ·be used: NO

### x- EPA Method 7E ·or20; CO
- EPA Method 10 or 10B;VOC
- EPA Method 18 or 25; PM10
- EPA Method 5 (front half and back half) or 201 and 202a; ammonia
- BAAQMD ST-1B; and O2 - EPA Method 3·, 3A, or 20. EPA approved alternative test methods as approved by the District may also be used to address the source testing requirements of this permit. [District Rules 1081 and 4703 and 40 CFR 60.4400(1 )(i)]

32AvenalPowerCenter, LLC(08-AFC-01) SJVACPO Determination ofCompliance, C-1080386


### ii. 'C-3953-12-0 (Boiler) The requirements of this Rule will be included in the operating permit. Compliance with this Rule is 'anticipated. ProposedRule 1081 Conditions:

• The exhaust stack shall be equipped with permanent provisions to allow collection of stack gas samples consistent with EPA test methods and shall be equipped with safe permanent provisions to sample stack gases with a portable NOx, CO, and 02 analyzer during District inspections. The sampling ports shall be located in accordance with the CARB regulation titled California Air Resources Board Air, Monitoring Quality Assurance Volume VI, Standard Operating Procedures for**S~ationary** Emission Monitoring and Testing. [District Rul'e 

### 1'081]

• {tOg} Source testing shall be conducted using the methods and procedures approved by the District. The District m,ust be notified at least30 days priorto any compliance source test, and a source test plan must be submitted forapproval at least 15 days priorto testing. [District Rule 1081 ]

• {110} The results of each source test shall be submitted to the District within 60 days thereafter. [District Rule 1081 ]
Rule 1100 EquipmentBreakdown This Rule defines a breakdown condition and the procedures to follow if one occurs. The

.corrective action, the issuance of an emergency-variance, and the reporting requirements

are also specified. 

### i. C-3953-10-0 and.C-3953-11-0 (Turbines) The requirements of this Rule will be included in the operating permits. Compliance with this Rule is anticipated. ProposedRule 1100 Conditions:

• Permittee shall notify the District of any breakdown condition as soon as reasonably possible, but no later than one hour after its detection, unless the owner or operator demonstrates to the District's satisfaction that, the longer reporting period was necessary. [District Rule 1100, 6.1]

33

### AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386

• The District shall be notified in writing within ten days following the correction of any, breakdown condition. The breakdown' notification shall include a description ofthe equipment malfunction orfailure, the date and cause ofthe initial failure, the estimated emissions in excess of those allowed, and the methods utilized to restore normal operations. [District Rule 1100,7.0]


### Rule2010 Permits,Required This Rule requires any person building', altering, or replacing any operation" article, machine, equipment, or other contrivance, the use ofwhich may cause the issuance of air contaminants, to first obtain authorization from the District in the form of an ATC.By the submission of an ATC application, Avenal Power Center, LLC is complying with the**requir~ments** ofthis Rule.


### Rule2201 NewandModifiedStationarySource ReviewRule 

### A. BACT: 1. BACTApplicability BACT requirements are triggered on a**poll~tant-by-pollutant** basis and on an emissions unit-by-emissions unit basis forthe following*:
a. Any new emissions unitwith a potential to emit exceeding two pounds perday, b. The relocation from one Stationary Source to another of an existing emissions unit with a potential to emit exceeding two pounds perday, c. ' Modifications to an existing emissions unitwith a valid Permit to Operate resulting' in an ,AIPE exceeding two pounds perday, and/or d. Any new or modified emissions unit, in a stationary source project, which results in a Major Modification. *Except for CO emission's from a new or modified emissions unit at a Stationary Source with an SSPE2 of less than 200,000 pounds peryearof CO. 

### i. C-3953-10-0 and C-3953-11-0 (Turbines) As seen in Section, VII.C.2.b of this evaluation, the applicant is proposing to install two new combustion turbine generators with PEs greater than 2 Ib/day for NOx, CO, VOC, .PM10, and SOx. BACT is triggered for NOx, CO, VOC, PM 1o, and SOx criteria pollutants since the PEs are greater than 2 Ibs/day, and since the SSPE2 for CO is greater than 200,000 Ibs/year, as demonstrated in Section VII.C.5 ofthis document. The PE of ammonia is greaterthan two pounds per dayforthe two CTGs. However, the ammo,nia emissions are.intrinsic to the operation of,the SCR system, which is BACT for NOx. The emissions from a control device that is determined by the District to be BACT are not subjectto BACT. 34AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
ii.**C~3953-12-0** (Boiler) 

### As seen in Section VII.C.2 of this evaluation, the applicant is proposing to install a new boiler with a PE greater than 2 Ib/day for NOx, CO, 

## voe, PM10, and SOx. BACT is triggered for NOx, 

### CO, VOC, and PM 1

### 0criteria pollutants since the PEs are greaterthan 2 Ibs/day, and si'nce the SSPE2 for CO is greater than 200,000 

### Ibs/year, as demonstrated in Section VII.C.S ofthis document. iii. C-3953-13-0 (DiesellC engine powering fire water pump) 

### As seen in Section VII.C.2 of this evaluation, the applicant is proposing to install a new diesel-fired IC engine (fire pump) with a PE greaterthan 2 Ib/dayfor NOx, CO, and VOC. BACT is triggered for NOx, CO, and. VOC criteria pollutants since the PEs are greater than 2 Ibs/day, and since the SSPE2 for CO is greater than 200,000 Ibs/year," as demonstrated in Section VII.C.S ofthis document. iv. C-3953-14-0 (Natural gas IC engine powering electrical generator) 

### As seen in SectionVILC.2ofthis evaluation, the applicant is proposing to install a new natural gas.-fired IC engine (generator) with a PE greaterthan 2 Ib/dayfor NO

### x, CO, and VQC. BACT is triggered for NOx, CO, and VOC criteria pollutants since the PEs are greaterthan 2 Ibs/day, and since the SSPE2 for CO is greaterthan 200,000 Ibs/year, as demonstrated in Section VII.C.5 ofthis document. 2. BACT Guidance 

### The District BACT Clearinghouse was created to assist applicants in selecting appropriate control technology for new and modified sources, and to assist the District staff in conducting the necessary BACT analysis. The Clearinghouse will include, for various class and category of sources, available control technologies and methods that meet one or more ofthe following conditions:

• Have been achieved in practice for such emissions unit and class ofsource; or
• Are contained in any SIP approved by the EPA for such emissions unit category and class ofsource; or
• 'Are any other emission limitation or control technique, including process and equipment changes of basic or control equipment, found to be technologi·cally feasible for such class orcategory ofsources orfor a specific source. Attachment E will include the BACT Guidelines from the BACT Clearinghouse applicable to the newemissions units associated with this project.



### 35

### AvenalPowerCenter, LLC(08-AFC-01) SJVACPO Determination ofCompliance, C-1080386


### i. C-3953-10-0 and C-3953-11-0 (Turbines) BACT Guideline 3.4.2 is applicable to the two combustion turbine generator installations [Gas Fired Turbi"ne

# =or > 50 MW, Uniform Load, with Heat Recovery]. 

### ii. C-3953-12-0 (Boiler) f3ACT Guideline 1.1.2 is applicable to the 37.4 MMBtu/hr boiler. [Boiler - > 20 MMBtu/hr, Natural gas-fired, base-loaded orwith small load swings.] iii. C-3953-13-0 (DiesellC engine powering fire water pump) BACT Guideline 3.1.4, applies to the diesel-fired emergency IC engine powering a fire pump. [Emergency Diesel 

### Lc. Engine Driving a Fire Pump] 

### iVa C-3953-14-0 (Natural gas IC engine powering electrical generator) BACT Guideline 3.1.8, applies to the natural gas-fired emergency 

## Ie engine powering an electrical generator. [Emergency Gas-Fired I.C. Engine> or

# =250 hp, Lean Burn] 3. Top-Down BestAvailable Control Technology (BACT) Analysis Per Permit Services Policies and Procedures for BACT, a Top-Down BACT analysis shall be performed as a part oftheapplic·ation review for each appli-cationsubject to the BACT requirements pursuantto the District's NSR Rule. For Permit Units C-3953-10-0 and -11-0 see Attachment F. For Permit Unit C-3953-12-0 see Attachment F. For Permit Unit C-3953-13-0 see Attachment F. For Permit Unit C-3953-14-0 see Attachment F. 4. BACT Summary: i. C-3953-10-0 and C-3953-11-0 (Turbines) BACT has been s.atisfied bythe following: NO

### x: 2.0 ppmv 

### @ 15% O2 (1-hour rolling average, except during startup/shutdow.n) with Dry Low NO

### xCombustors, SCR with ammonia injection and natural gas fuel. 

## co: 2.0 ppmv 

### @ 15% 

### 02 (3-hour rolling average,. except during startup/shutdown) with an Oxidation Catalyst and natural gas fuel.AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determinati9n ofCompliance, C-1080386
VOC: 1.5 ppmv 

### @ 15% O2 (without duet burnerfiring;3-hour rolling average). 2.0 ppmv @ 15% O2 (with duct burnerfiring; 3-hr rolling average). PM 10: Air inlet'filter cooler, lube oil vent coalescer, and natural gas fuel 

## sox: 'PUC regulated natural gas with a sulfur content of 1.0 gr/1 00 sefor less 

### ii. C-3953-12-0 (Boiler) BACT has been satisfied bythe following: NO

### x: 9.0 ppmv 

### @ 15°A, O2 with Ultra Low NO

### xburners and'natural gas fuel. 

## co: Natural gas fuel. VOC: Natural gas'fuel. PM 10: Natural gas fuel. 

## sox: Natural gas fuel. 

### iii. C-3953-13-0 (DiesellC engine powering fire water pump) BACT has been satisfied bythe following: NOx: Certified NOxemissions of6.9 g/hp· hr or less 

## co: No CO control. Any add on 

## cq control device would void the Underwriters Laboratory (UL) certification. 

## voc: No' 

## vac control. Any add on VOC control device would void the Underwriters Laboratory (UL) certification. iv. C-3953-14-0 (Natural gas 

### Ie engine powering electrical generator) BACT has been satisfied bythe following: NO

### x: 

# =or < 1.0 g/bhp-hr (lean burn natural gas fired engine, or equal) 

## co: 90% control efficiency (oxidation catalyst, orequal) VOC: 90% control efficiency (oxidation.catalyst, orequal)

37

### AvenalPowerCenter, LLC(08-AFC-01) SJVACPO Determination ofCompliance, C-1080386 

### Therefore, the following condition will be listed on the DOC to ensure compliance:

• {3492} Th"is 

## Ie engine shall be equipped with a three-way catalyst. [District Rule 2201 ]
C. Offsets: 1. OffsetApplicability: 

### Pursuant to Section 4.5.3, offset requirements shall be triggered on a pollutant by pollutant basis and shall be required if the Post-project Stationary Source Potential to Emit (SSPE2) equals to or exceeds emissions of 20,000 Ibs/year for NOx and VOC, 200,000 Ibs/yearfor CO, 54,750 Ibs/yearfor SOx and 29,200 Ibs/yearfor PM10. 

### As seen in the table below, the facility's SSPE2 is greaterthan the" offset threshold"s for NOx,CO, VOC, PM10, 

### and sax emissions. ·Therefore, offset calculations are necessary.

1,205,418 200,000 Yes 2. Quantity ofOffsets Required: 

### Per District Rule 2201, Section 4.6.1, emission offsets shall not be required for increases in carbon mo"noxide in attainment areas if the applicant demonstrates to the satisfaction of the APeD, that the Ambient Air Quality Standards are not violated in the areas to be affected, and such emissions will be consistent with Reasonable Further Progress, and will not cause orcontribute to a violation ofAmbientAir Quality Standards. As shown in section VIII.G below, the increase in CO emissions associated with this stationary source project does not cause or contribute to a violation of Ambient Air Quality Standards. CO emissions are n9t addressed in any Reasonable Further Progress Plans. Therefore, this stationary source project qualifies for the offset exemption listed in Section 4.6.1. Per Sectiqns 4.7.2 and 4.7.3, the quantity Of offsets in pounds per**yearfo~** 

### NOx, CO," 

## vac, and PM10 

### is calculated as follows for sources with an SSPE1 less than the offset threshold levels before implementing the project being evaluated.

38AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination·

### ofCompliance,

.

### C-1080386
Offsets Required (Ib/year) = ([SSPE2 Offset Threshold] + ICCE) x DOR, for all new or modified emissions units in the project, Where, SSPE2 = Post Project Facility Potential to Emit, (Ib/year) ICCE ::: Increase in Cargo Carrier Emissions, (Ib/year) DOR = Distance Offset Ratio, determined pursuant to Section 4.8 Per Section 4.6.2, emergency equipment that is used exclusively as emergency standby equipment for electrical power generation' or any other emergency equip'ment as approved by the APCO that does not operate more than 200 'hours per year of nonemergency purposes and is not used pursuant to voluntary arrangements with a power. supplier to curtail power, is exempt from providing emission offsets. Therefore, permit units**C-3953~** 13-0 and C-3953-14-0 will be exempt from providing offsets, and the emissions associated with these'permit units contributing to the SSPE2 should be removed priorto calculating actual offset amounts.

,Offset

# =([SSPE2
- Emergency Equipment
- Offset Threshold] 

### + ICCE) x DOR, for all new or modified emissions units in the project,**NO~** Offset Calculations: NO

### xSSPE2 = 288,6181b/year C-3953-13-0 (NO

### x ) = 108 Ib/year C-395.3-14-0 (NO

### x ) = 95lb/year NO

### xoffsetthreshold = 20,000 Ib/year Offsets = [288,618
- (108)
- (95)
- 20,000]

= 268,415 Ib/year * DOR Calculating the appropriate quarterly emissions to be offset is as follows: Offsets = (268,415 Ib/year+ 4 qtr/year) * DOR

= 67,103.75Ib/qtr'* DOR PE1stOtr = 67,103.75Ibs of NO

### x* DOR PE2ndOtr= 67,103.75Ibs of NO

### x* DOR PE3rdOtr = 67.,103.75 Ibs of NO

### x* DOR PE4thOtr = 67,103.75 Ibs of NO

### x* DOR Pursuantto Section 4.8 of District Rule 2201" the distance offset ratio shall be 1.0:1 ifthe emission offsets originated at the same Stationary Source as the new or modified emissions unit; 1.2.1 for Non-Major Sources if the emission offsets originated within 15 miles ofthe new or modified emissions unit's Stationary Source; 1.3.1 for Major Sources if the emission offsets originated within 15 miles of the new or modified emissions unit's
39

### AvenalPowerCenter, LLC(08-AFC-01) SJVACPD Determination ofCompliance,**C~1080386** 

### Stationary Source; or 1.5:1 if the**emi~sion** 

### offsets originated 15 miles or more from the newor modified emissions unit's Stationary Source.**Assum~ng** 

### aworst case offset ratio of 1.5:1, the amount of NOx ERG's that need to be withdrawn is: Offsets Required

# =268,415 Ib-NOx/year

### x 1.5 Offsets Required

# =402,623 Ib-NOx/year Ca'iculating the appropriate quarterly emissions to be offset is as follows:

NOx ,Th'e applicant has stated that the facility plans to use ERC certificates C-899-2, C-902-2,**N~720-2,** 

### N-722-2, N-726-2, ,N-728-2, 8-2814-2, and S-2321-2 to offset the increases in NOx emissions associated with this project. The above Certificates have available quarterly NOxcredits as follows:

*ERC certificate splitfrom this ERe. 

### 2,243 8,539

437 1,422 

# o 5,171 11,461 51,000 2,243 1,086 1,255 88,317 4,728 2,487 18,914 51,000 1,166 

## o 3,731 2,243 6,131 

### -9

13,869 51,000 6,121 51,000 

## o 

# o 10,542 2,243 13,879 

# o ERC**#C-899~2** 

### ERC #C-902-2 ERC #N-720-2

ERC #8-2814-2 ERC #S-2321-2* ERC #N-722-2 ERC #N-726-2 ERC #N-728-2

Project**NO~** 

### offset requirements The applicant states that NOx ERC certificates C-899-2, C-902-2, N-720-2, N-722-2, N726-2, N-728-2,S-2814-2, and 8-2321-2 will be utilized to supply the NOx offset requirements. Per Rule 2'201 Section 4.13.8, Actual Emission Reductions (i.e. ERCs) that occurred from April through

### Nove~ber (i.e. 2nd 

### and 3rd 

### Quarter), inclusive, maybe used to offset increases in NOxorVOC during any period ofthe year. 8ince 3rd 

### quarter NOx ERCs will be used to offset NOx emissions, the above applies to the NOx ERCs. 40AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386

1st Quarter 2nd Quarter 3rd Quarter 4th Quarter NOx Emissions to be offset: (at a 100,655 100,656 100,656 100,656 1.5:1 DOR): Available ERCs from certificates C-899-2,C-902-2, N-720-2, N- 83,784 78,147 170,027 80,269 722-2, N-726-2, N-728-2, S2814-2, and 8-2321-2*: 3rd qtr. ERCs applied to 1st qtr. 16,871 0 -16,871 

# ° ERGs: 3rd qtr. ERCs applied to 2nd qtr. 

# ° 22,509 -22,509 

# ° ERGs: 3rd qtr. ERGs applied to 4th qtr. 0 

# ° -20,387 20,387 ERGs: Remaining ERGs from 0 

# ° 9,604 

# ° certificates 8-2321-2: Remaining NO

### xemissions to be 

# ° 0 

# ° 

# ° offset (at a 1.5:1 DOR): As seen above, the facility has sufficient credits to fully offset the quarterly NO

### x

, emissions increases associated with this project.



## voe Offset Calculations: vaG 8SPE2 

# =69,222 Ib/year**G-3953-13~0** (VOG) 

# =12 Ib/year G-3953-14-0 (VOG) 

### = 31 Ib/year VOG offset threshold 

### = 20,000 Ib/year Offsets 

# =[69,222
- (12)
- (31)
- 20,000] 

# =49,179 Ib/year

## * DOR Calculating the appropriate quarterly emissions to be offset is as follows: Offsets 

# =(49,179 Ib/year-:- 4 qtr/year) 

### * DOR 

# =12,294.75 Ib/qtr* offset ratio PE1stQtr

# = 12,294.75 Ibs ofVOG * DOR PE2ndQtr

# = 12,294.75 Ibs ofvoe * DOR PE3rdQtr

# = 12,294.75Ibs ofVOC * DOR PE4thQtr 

### =' 12,294.75Ibs ofVOC * DOR

'41AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386


### Pursuantto Section 4.8 of District Rule 2201, the distance offset ratio shall be 1.0:1 ifthe emission offsets, originated at the same Stationary Source as the new or modified emissions unit; 1.2.1 for Non-Major Sources if the emission offsets originated within 15 miles ofthe new or modified emissions unit's Stationary Source; 1.3.1 for Major Sources ifthe emission· offsets originated within 15 miles ofthe new or modified emissions unit's Stationary Source; or 1.5:1 if the emission offsets originated .15 'miles or more from the new or modified emissions unit's Stationary Source. Assumi,ng aworst case offset ratio of 1.5:1, the amount ofVaG ERG's that need to be withdrawn is: PE 1stQtr

# = 12,294.75 Ibs ofVaG 

## * 1.5

# =18,442 Ibs PE2nd Qtr

# = 12,294.75 Ibs ofvaG 

## * 1.5

# =18,442 Ibs

. PE3rd Qtr

# = 12,294.75 Ibs ofvaG 

## * 1.5 

### = 18,442 Ibs PE4th Qtr 

### = 12,294.75 Ibs ofvae 

## * 1.5= 18,442 Ibs Calculating the appropriate quarterly emissions to be offset is as follows:



## vac The applicant has stated thatthe' facility plans to use ERG certificates G-897-1, C-898-1, N-724-1, N-725-1, S-2812-1, S-2813-1, and**S~2817** 

### -1 to offset the increases inVOC emissions associated with this project. The above Certificates have available quarterly VaG credits as follows:

.

ERC #C-897-1 45 45 45 45 ERG #C-898-1 5,480 6,496 4,696 6,616 ERC #N-724-1 O' 

### 0 241 0 

### ERG #N-725-1 0 0 709 0 ERC#S-2812-1 31,432 31,424 31,417 31,417 ERC #S-2813-1 12,500' 12,500 12,500 12,500 ERC#S-2817-1 11,431 11,424 11,417 11',417

42AvenalPowerCenter, LLC(OB-AFC-01)

, SJVACPD Determination ofCompliance, C-10B0386 Projectvac offset requirements The, applicant states th'at ,Nax ERC certificates C-897-1, C-898-1, N-724-1, N-725-1, 5-2812- 1,5-2813-1, and 8-2817-1 will be utilized to supplytheVOC offset requirements. 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter vac Emissions to be offset: (at a 18,442 18,442 18,442 18,442 1.5:1 DaR): Available ERCs from certificates C-897-1, C-898-1, N-724-1, N- 5,525 6,541 5,691 6,661 725-1, Remaining vac emissions to be 12,917 11,901 12,751 11,781 offset (at a1.5: 1 DaR):
vac Emissions to be offset: (at a 12,917 11 ,901 12,751 11,781 1.5:1 DOR): Available ERCs from certificates 8-2812-1, 8-281'3-1, and 8-2817- 55,363 55,348 55,334 55,334 1 Remaining ERCs from certificate's 8-2812-1, 8-2813-1, 42,446 43;447 42,583 43,553 and 8-2817-1: Remaining vac emissions to be 0 

### 0 0 0 offset (at a 1.5:1 DaR): 'As seen above, the facility has sufficient credits to fully offset the quarterly VOC emissions increases associated with this project.

PM10 Offset Calculations: PM10 88PE2 

# =161 ,545lb/year C-3953-13-,O (PM 10) 

# =2 Ib/year C-3953-14-0 (PM 10) 

# =3 Ib/year PM 10 Offsetthreshold 

# =29,200 Ib/year Offsets 

# =[(161,545
- (2)
- (3)
- 29,200 

### + 0) 

### x DOR] 

# =1.32,340 Ib/year

### x DOR Calculating the appropriate quarterly emissions to be offset is as follows (in Ib/qtr): Offsets 

# =(132,340 Ib/year-;- 4 qtr/year) 

## * DOR 

# =33,085 Ib/qtr

## * offset ratio

43AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386


### PE 1stQtr 

### = 33,085 Ibs of PM 10

## * DOR PE2nd Qtr

### =33,085 Ibs of PM 10 

## * DOR PE3rd Qtr 

### = 33,085 Ibs of PM 10

## * DOR PE4th Qtr 

### = 33,085 Ibs of PM 10

## * DOR

.The applicant is proposing to use ERG Certificates C-894-4, N-721-4, N-723-4,**N~762-5,**



### 8-2788-5, 8-2789-5, 8-2790-5, and 2791-5 which have an original site of reduction .greaterthan 15 miles from the location ofthis project. Therefore, a distance offset ratio of 1.5:1 is applicable and the amount of PM 10 

### ERCs that need to be withdrawn is: Offsets Required (Ib/year) .= 132,3401b/year

### x 1.5
= 198,510 Ib/year 

### Calculating the**appropri~t~** 

### quarterly emissions to be offset is as follows (in Ib/qtr):

The applicant has stated that the facility plans to use ·ERC ce.rtificates C-894-4, N-721-4,

.**N-723~4,** 

### N-762-5, 8-2788-5, 8-2789-5, 8-2790-5, and 2791-5 to offset the increases in

PM 10 

### emissions associated with this project. The. applicant has purchased the following quarterly amounts ofthe above certificates:

ERC**#C~896-4** 

### ERC #N-721-4 ERC #N-723-4 ERC #8-2791-·5 ERC #8-2790-5 ERC #8-2789-5 ERC #8-2788-5 ERC #·N-762-5 80 80 80 80 

# ° ° 3,215 

### 0 

# ° 0 985 0 

### 92,179 23,666 69, 157 96,288 12,862 491 

# a 8,499 6 14 12 

### 8 

### 5 7 3 6 21,000 21 ,000 21,000 21,000

44

### AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO DeterminationofCompliance, C-1080386 

### Project PM 10 

### 0ffset requirements The applicant states either PM10 

### ERC certificates G-894-4, N-721-4;· N-723-4, N-762-5, 8-2788-5, 8-2789-5, ·S-2790-5, and 2791-5 will be utilized to supply the PM10 

### offset· requirements. 1st Quarter 2nd Quarter 3fd Quarter 4th Quarter

. PM 10 Emissions to be offset: (at a

1.5:1 ratio): Available ERCs from certificates C-896-4, N-721-4, and N-723-4: ERCs applied from certificates C-896-4, N-721-4, and N-723-4 fully

. withdrawn as certificates C-896-4,

N-721-4, and N-723-4: Remaining ERCs from certificate C-896-4, N-721-4, and N-723.;.4: Remaining PM 10 emissions to be offset (at a 1.5:1 ratio): 

### 49,630 80
-80



### o 49,550 

### 49,629 80
-80



### a 49,549 4,280 -4,280



## o 45,349 

### 49,630 80
-80



### a 49,550 

### Per Rule 2201 Section 4.13.3.2, interpollutant offsets ·between PM 10 

### a.nd PM 10 

### precursors (i.e. SOx) may be**~lIowed.** 

### The applicant is proposing to use interpollutant offsets SOx 

### for PM 10 

### at an interpollutant ratio of 1.0:1 (see Attachment H). 

### Per Rule 220·1 Section 4.13.7, Actual Emission Reductions (i.e. ERGs) that occurred from October through March (i.e. 1st 

### and 4th 

### Quarter), inclusive, may be used to offset increases inPM during any period of the year. Since the SOx 

### ERC·s are being used to offset PM10 

### emissions, the above applies to the SOx 

### ERGs. In addition, the overall offset ratio is equal to the multiplication of the distance and

. interpollutant ratios (1.5 

### x 1.000

# =1.5).

45·AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386

1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Remaining PM10 Emissions to be 49,550 49,549 45,349 49,550 offset: (at a 1.5:1 ratio):· Remaining PM10 emissions to be offsetwith SOx ERGs (at a 1.5:1 49,550 49,549 45,349 49,550 distance ratio and a 1.000:1 interpollutant SOX:PM10 ratio): Remaining ERGs from certificates N-762-5, 8-2788-5, 8-2789-5,.and 33,873 21,512 21,015 29,513 8-2790-5: Remaining ERGs from certificates N-762-5, 8-2788-5, 8-2789-5, and 

# ° ° 0 

# ° 8-2790-5: Remaining PM10 emissions to be offset (at a 1.5:1 ratio and a 1.000:1 15,677 28,037 24,334 20,037 interpollutant SOX:PM10 ratio): 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Remaining PM10 Emissions to be offset: (at a 1.5:1 distance ratio and 15,677 28,037 24,334 20,037 a 1.000:1 interpollutant 80x:PM10 ratio): Remaining ERGs from certificate 92,179 23,666 69,157 96,288 S-2791-5: 1SLqtr
. ERGs applied to 2nd qtr.

. -4,371 4,371 0 

# ° ERGs: Adjusted Remaining ERGs from 87,808 28,037 69,157 96,288 certificate 8.-2791-5: Remaining PM10 emissions to be offset (at a 1.5:1 ratio and a 1.000:1 15,677 28,037 24,334 20,037 interpollutant SOX:PM10 ratio): ERGs applied from certificate 15,677 28,037 24,334 20,037 8-2791-5 partiallywithdrawn: Remaining ERGs from certificate 72,131 0· 44,823 76,251 8-2791-5: As seen above, the facility has sufficient credits to fully offset the quarterly SOx and PM10 emissions increases associated with this project.



### 46AvenalPowerCenter, LLC(08-AFC-01) SJVACPD Determination ofCompliance, C-10B0386
Offset Conditions: 

### The following conditions will ensure c0rr:'pliance with the offset requirements 9fthis rule:

• Prior to initial operation of C-3953-10-0, C-3953-11-0, and C-3953-12-0, permittee shall provide NOx (as N02) emission reduction credits for the following quantities of emissions: 1st quarter, - 67,103 Ib;2nd quarter - 67,104 Ib; 3rd quarter - 67,104 Ib; and 4th quarter - 67,104 lb. Offsets shall be provided at the a,ppropriate distance ratio specified in Rule 2201. [District Rule 2201]

• Prior to initial operation of C-3953-10-0, C-3953-11-0, and C-3953-12-0, permittee shall provide 

## voe emission reduction credits for the following quantities of emissions: 1st quarter - 12,294 Iq; 

### 2nd quarter - 12,295 Ib; 3rd quarter - 12,295 Ib; and 4th quarter - 12,295 lb. Offsets shall be 'provided at the appropriate distance ratio specified in Rule 2201. [District Rule 2201]

• Prior to initial operation of**C-3953~10-0,** 

### C-3953-11-0, and C-3953-12-0, permittee shall provide PM 10 

### emission reduction credits for the following quantities of emissions: 1st quarter - 3'3,087Ib; 2nd quarter - 33,086 Ib;.3rd quarter - 33,086 Ib;and 4th quarter - 33,086 lb. Offsets shall be provided at the appropriate distance ratio specified in Rule 2201.' 80x ERC's may be used to offset PM10 increases at an interpollutant ratio of 1.0 Ib-80x': 1.0 Ib-PM1 

### O. [District Rule 2201]

• ERC certificate numbers (or any splits from these certificates) C-897-1, C-898-1, N-724-1, N-725-1, 8-2812-1, 8-2813-1, 8-2817-1, C-899-2, ,C-902-2, N-720-2, N722-2, N-726-2, N-728-2, 8-2814-2,8-2321-2, C-896-4, N-721-4,**N~723-4,** 

### 8- 2791-5, 8-2790-5, 8-2789-5, 8-2788-5, or N-762-5 shall be 

### used to s'upply the required 'offsets, unless a revised offsetting proposal is received and approved by the District, upon which this determination of compliance (DOC) shall be reissued, administratively specifying the new offsetting proposal. Original public noti,cing

.requirements, if any, shall be duplicated prior to reissuance of the DOC. [District Rule 2201]

47AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
D. Public Notification: 

### 1. Applicab'ility 

### District Rule 2201, section 5.4, requires a public notification for the affected pollutants from th'e following types of projects:

• New Major Sources
• Major Modifications
• Newemission units with a PE > 

### 100 Ib/day ofanyone pollutant (IPE Notifications)
• Any project which results in the offset thresholds being surpas.sed (Offset Threshold Notification), 'and/or
• Any permitting action with a SSIPE exceeding 20,000 Ib/yr for anyone pollutant. (SSIPE Notice)
a. New Major Source Notice Determination



### .New Major Sources are newfacilities, which are also Major Sources. As shown in Section VII.C.6 above, the SSPE2 is greater**tha~** 

### the Major Source thresh,old for NO

### x, CO, 

## voe., and PM 10. 

### Therefore, public noticing is required for this project for new Major Source purposes because this facility is becoming 

### a new Major Source. 'b. Major Modification 

### As demonstrated .in Section'VII.C.? ab'ove, this project does not constitute a Major 'Modification; therefore, public noticing for Major Modification purposes is not required.
c. PE Notification 

### Applications which include a new emissions unit with a Potential to Emit greater than 100 pounds during anyone day for any pollutant will trigger public noticing requirements. The potential to emitforeach unit is summarized in thetable below.



### 48· . AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination

### ofCompliance, C-1080386



### C-3953-10-0 789.6 5,590.8 202.0 282.7 159.6 771.1 C-3953-11-0 789.6 5,590.8 202.0 282.7 159.6 771.1 C-3953-12-0 4.9 16.6 1.9 2.2 1.3 0 C-3953-13-0 51.8 6.8 5.8 0.9 0.1 0·. C-3953-14-0 45.5 27.3 15.0 1.5 0.4 0 Threshold (Ib/da ) 

### 100 100 100 1.00 100 100
According to the table above, permit units C-3953-10-0 and -11-0 will each have a Potential to Emit greater than 100 Ib/day for NO

### x, CO, VOG, PM 10,**SO~,** 

### or NH3 

### emissions. Therefore, publi.c noticing will be required for PE > 

### 100 Ibs/day purposes. e. OffsetThreshold Public notification is required if the Pre-Project Stationary Source Potential to Emit (SSPE1) is increased from a level below the offset threshold to a level exceeding the emissions 'offsetthreshold, for any pollutant. The following table compares the SSPE1 with the SSPE2 in.order to determine if any offsetthresholds have been surpassed with this project.

NOx 

# ° 288,618 20,000 Ib/year Yes 

## eo 0 1,205,418 200,0001b/year Yes 

## vae 

# ° 69,222 20,000 Ib/year Yes PM 10 

# ° 161,550 29,2001b/year Yes SOx 0 33,521 54,750 Ib/year No As detailed above, offset thresholds were surpassed for NOx, CO, VOG, and PM10 

### em.issions with this project; therefore public noticing is required for offset purposes.

49

### AvenalPowerCenter, LLC(08-AFC-01) SJVACPO 'Determination ofCompliance, C-1080386

f. SSIPE Notification 

### Public notification is required for any permitting action that results in a Stationary Source Increase in Permitted Emissions (SSIPE) of more than 20,000 Ib/year of any affected pollutant. According to District policy, the SSIPE is calculated as the Post Project Stationary Source Potential to Emit (SSPE2) minus the Pre-Project Stationary Source Potential to Emit (SSPE1), Le. SSIPE 

# =SSPE2
- SSPE1. The values for SSPE2 and SSPE1 are calculated according to Rule 2201, Sections 4.9 and 4.10, respectively. The SSIPEis compared to the SSIPE Public Notice thresholds in the following table:

Pollutant ,SSPE2 SSPE1 SSIPE ,SSIPE Public Public Notice (Ibl ear) (Ibl ear) (Ibl ear) Notice Threshol'd Required? 

### NOx 288,618 

# ° 288,618 20,000 Ibl ear Yes GO 1,205,418 

# ° 1,205,418 20,0001bl 

### ear Yes VOG 69,222 

# ° 69,222 20,0001bl ear Yes PM 10 

### 161,550 

# ° 161,550 20,000 Ibl 

### ear Yes SOx ,33,521 

# ° 33,521 20,000 Ibl ear Yes As demonstrated above, the SSIPE's for NOx,GO, VOG, PM 10 

### and SOx emissions were greater than 20,OOOlb/year; therefore public noticing for SSIPE purposes is required. 2. Public Notice Requirements 

### Section 5.5 details the actions taken by the District when pubic noticing is triggered according to the application types above., Since public noticing requirements are triggered for this project (Le. New Major Source, PEls > 

### 100 Ibs/day, offset thresholds being exceeded, and SSIPEs greater than 20,000 Ibs/year), the District shall public notice this project accordin'g to the requirem,ents of Section 5.5.
E. DailyEmission Limits: 

### Daily' emissions limitations (DELs) and other enforceable conditions are required by Section 3.15 to**re~trict** 

### a unit's maximum daily emissions, to' a level at or below the emissions associated with the maximum design capacity. Per Sections 3.15.1 and 3.15.2, the DEL must be contained in the latestATe and contained in or enforced bythe latest PTOand enforceable, ina practicable manner, on a daily basis.

50

### AvenalPowerCenter,LLC(OB-AFC-01) 

### SJVACPO Determination ofCompliance, C-1080386 ProposedRule2201 (DEL) Conditions: 

### i. C-3953-10-0 and C-3953-11-0 (Turbines) For the turbines, the DELs for NOx, CO, VOC, PM10, sax, and NH3 will consist ofIb/day and/oremission factors.

• Emission rates from this unit (with duct burner firi·ng), except during startup and· shutdown periods, shall not exceed any of th.e following limits: NOx (as N02)
- 17.201b/hr and 2.0 ppmvd 

### @ 15% 02; 

## vac (as methane)
- 5.89 Ib/hr and 2.0 ppmvd 

### @ 15°;002; CO
- 10.60 Ib/hr and 2.0 ppmvd 

### @ 15% 02; PM10 -11.78 Ib/hr; or SOx (as S02)
- 6.65 Ib/hr. NOx (as N02) emission .Iimits are one hour rolling averages. All other emission limits 

### are three hour rolling averages. [District Rules 2201,4001, and 4703]

• Emission rates from this unit (without duct burnerfiring), except.during startup and shutdown periods, shall not exceed any of the following limits: NOx (as N02)
- 13.55 Ib/hr and 2.0 ppmvd 

### @ 15°;0 02; 

## voe (as methane) 3.34 Ib/hr and 1.4 ppmvd 

### @ 15°;0 02; CO -8.35Ib/hr and 2.0 ppmvd 

### @ 150/0 02; PM10
- 8.91 Ib/hr; or SOx (as S02)
- .5.23 Ib/hr. NOx (as N02) emission limits are one hour rolling averages. All other emission limits are three hour rolling averages. [District Rules .2201, 4001, and 4.703]

• During start-up and shutdown, CTG exhaust emission rates shall not exceed any of the following limits:NO

### x (as N02 ) - 160 Ib/hr; CO
- 1,000 Ib/hr; VOC (as methane)
- 16 Ib/hr; PM10 - 11.78 Ib/hr; SOx (as S02)
- 6.652 Ib/hr; or NH3
- 32.13 Ib/hr. [District Rules 2201 and 4703]

• Daily emissions from the CTG shall not exceed the following limits: NOx (as N02)

- '412.8 Ib/day; CO
- 254.4 Ib/day; 

## voe - 141.4 Ib/day; PM10 - 282.7 Ib/day; SOx (as 802) -159.6Ib/day, or NH3 -771.1 Ib/day. [District Rule 2201]

• Emissions from this unit, on days when a startup 

### andlor shutdown occurs, shall not exceed the following limits: NOx (as N02)
- 789.6 Ib/day; 

## voe - 202.0 Ib/day; CO
- 5,590.8 Ib/day; PM10
- 282.7 Ib/day; SOx (as S02)
- 159.6 Ib/day, or NH3 - 771.1 Ib/day. [District Rule 2201]

• The ammonia (NH3) emissions shall not exceed 10 ppmvd @ 150/0 02 over a 24 hour rolling average. [District Rule' 2201]

• The CTG shall be fired exclusively on PUC-regulated natural gas with a sulfur content no greater than 1.0 grain of sulfur compounds (as S) per 100 dry sef of natural gas. [District Rule 2201 and 40 CFR 60.4330(a)(2)]

51AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386

• Annual average of the sulfur content of the eTG shall not exceed 0.36 grain of sulfur compounds(as S) per 100 dry scf of natural gas. [District Rule 2201] In addition to the daily emissions limits specified above, the following conditions will also 'be inclu.ded.to ensure continued compliance forthe proposed turbines:
. • Annual emissions from the CTG, calculated on a twelve month rolling basis, shall not exceed any of the following limits: NOx (as N02) - 143,951 

### Ib/year; CO
- 

### 601,810 Ib/year; VOC
- 34,489 

### Ib/year; PM 10 - 80,656 

### Ib/year; or

## sax (as S02)- 

### 16,694Ib/year; or NH3 - 208,708 Ib/year. [District Rule 2201]

• Each one hour period shall commence on the hour. Each one hour period in a

.three hour rolling average will commence on the hour. The ttiree hour average will be compiled from the three most recent one hour periods. Each one hour period in a twenty-four hour average for ammonia slip will commence on the hour. [District Rule 2201]

• Daily emissions will be compiled for a twenty-four hour period starting and ending at twelve·-midnight. Each month in the twelve consecutive month rolling average emissions shall commence at the beginning of the first day of the month. The twelve consecutive month rolling average emissions to determine compliance with annual emissions limitations shall be com.pi.led from the twelve most recent calendar months. [District Rule 2201] 

### ii. C-3953-12-0 (Boiler) The DELs for the boiler will consist of Ib/MMBtu 'and- ppmv emissions I-imits. This will be sufficient to establish a maximum daily potential to emit based on the maximum dailyfuel use limit.

• Emission rates from this unit shall not exceed any of the following limits: NOx (as N02)
- 9.0 ppmvd 

### @ 3% .02 or 0.011 Ib/MMBtu; VOC (as methane) - 1**O~O** ppmvd 

### @ 3% 02; CO
- 50.0 ppmvd 

### @ 3% 02 or 0.037 Ib/MMBtu; PM10
- 0.005 Ib/MMBtu; or SOx (as S02)
- 0.00282 Ib/MMBtu. [District Rules 2201,4305,4306, and 4351] In addition the following permit conditions will appear on the permit:

• {2964} The unit shall only be fired on PUC-regulated natural gas. [District Rule 2201]

52AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
iii. C-3953-13-0 (DiesellC engine fire pump) Forthe emergency IC engine powering afire pump, the DELs will be stated in the form of emission factors, the maximum,engine horsepower rating, and the maximum operational time of24 hours per day.

• Emissions from this IC engine sh,all not exceed any of the following limits: 3.4 gNOx/bhp-hr, 0.447 g-CO/bhp-hr, or 0.38 g-VOC/bhp-hr. [District Rule 2201 and 13 CCR 2423 and 17 CCR 93115]

• Emissions from this IC engine shall not exceed 0.059 g-PM10/bhp-hr based on USEPA certification using ISO 8178 test procedure. [District Rules 2201 and 4102 and 13 CCR 2423 and 17 CCR 93115]

• {3395} Only CARB certified diesel fuel containing not more than 

### 0.0015% sulfur by weight is to be used. [District Rules 2201 and 4801 and 17CCR93115] iv. C-3953-14-0'(Natural gas 

### Ie engine electrical generator) F'or the emergency 

### Ie engine p,owering a generator, the DELs will be stated in the form of emission factors, the maximum engine horsepower rating, and the maximum operational time of24 hours perday.

• Emissions from this IC engine shall not exceed any of the following limits: 1.0 gNOx/bhp-hr, 0.034 g-PM10/bhp-hr, 0.6 g-CO/bhp-hr, or 0.33 g-VOC/bhp-hr. [District Rule 2201]

• {3491} T,his IC engine shall be fired on Public Utility Commission (PUC) regulated natural gas only. [District Rules 2201 and 4801] , 

### F. Compliance Certification: Section 4.1'5.2 of this Rule requires the owner of a new major source or a source undergoing a major modification to demonstrate to the satisfaction of the District that all other major sources owned by such person and operating in California are in compliance with all applicable emission limitations and standards. As discussed above, this facility is , a new major source; therefore this requirement is applicable. Included in Attachment 

### I is

Avenal Power Center's certification forthe Avenal Energy Project.

53

### AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO·Determination ofCompliance, C-1080386


### G. AirQualityImpactAnalysis: Section 

### 4.14.2 of this Rule requires that an air quality impact analysis (AQIA) be conducted for the purpose of determining whether the operation of the proposed equipmentwill cause or m.ake worse a vio.lation ofan airquality standard. The Technical· Services Division ofthe SJVAPCD conducted the required analysis. Referto Attachment G ofthis documentforthe AQIA summary sheet. The AQIA performed for this project was analyzed ba·sed on the facility's preliminary proposal. The facility originally proposed CO emissions from the two CTG's to be limited to 

### 4.0 ppmvd 

### @ 15% O2. 

### However,. due to comments made during the public notice period, the facility limited their CO emissions to 

### 2.0 ppmvd 

### @ 15% 

### 02. Since the new proposed emission .factor is lowerthan the original emission factor and will not result ·in an increase in air pollutants, a newAQID will not be required to be performed forthis project. The proposed location is in an attainment area for NOx, CO, and SOx. As shown by the

. table below, the proposed equipment will not cause a violation of an air quality standard

for NOx, CQ, or SOx.

Pollutant 1 hrAverage 3hrAverage 8 hr**Ave~age** 

### 24 hr Annual Average Average. CO Pass 

## N/A Pass N/A 

## N/A NOx Pass 

## N/A N/A N/A Pass SOx Pass .Pass N/A Pass Pass The proposed location is in a non-attainment area for PM 10. 

### The increase in the ambient PM 10 

### concentration due to the proposed equipment is shown on the table titled· Calculated Contribution. The levels of significance, from 

### 40 CFR Part 51.165· (b)(2), are shown on the table titled Significance Levels.



### 54

### AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance} C-1080386
As shown, the calculated contribution of PM'10 will not exceed the EPA significance level. This project is not expected to cause or make worse a violation of an air quality standard.


### H. ComplianceAssurance: 1. Source Testing 

### i. C-3953-10-0 and C-3953-11-0 District 'Rule 4703 requires NOx and CO emission testing as well as percent turbine efficiency testing on an annual basis. The District Source Test Policy (APR. 1705 10/09/97) requires annual testing for all pollutants controlled by catalysts. The control equipment will include a SCR system and an oxidation catalyst. Ammonia s·lip is an indicator of how well the SCR system is performing and PM10 emissions are a good indicatorof howwell the inlet aircooler/filterare performing. Therefore, source testing for NO

### x ', CO, 

## vac, PM10, and ammonia slip will be required within 

### 60 days after the end of the commissioning period and at least once every 

### 12 months thereafter.

. Also; initial source testing of NOx, CO, and VOC startup emissions will be required for one gas turbine engine initially and not less than every seven years thereafter. This testing will serve two. purposes: to validate the startup emission estimates used in the emission calculations and to verifythat the CEMs accurately measure startup emissions. Each CTG will have a separate exhaust stack. The units will be equipped with CEMs for NO

### x, CO, and O2. Each CTG will be equipped with an individual CEM. Each CEM will have two ranges to allow accurate measurements of NO

### x and CO emissions during startup. The CEMs must meet ·the installation, performance, relative accuracy, and quality assurance requirements specified in 40 CFR 60.13 and Appendix B (referenced in the CEM requirements of Rule 4703) and the acid rain requirements in 40 CFR Part 75. 40 CFR Part 60 subpart, KKKK requires that. fuel sulfur content be documented or monitored. Refer' to the monitoring section of this document for a discussion of the fuel sulfurtesting requirements. 40 CFR Part 60 subpart Db requires NO

### xtesting for the'duct**burners~** The District will acceptthe NO

### xsource testing required by District Rule 4703 as equivalentto NO

### xtesting re'quired by40 CFR 60 subpart Db.



### 55AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
ii. C-3953"712-O This unit is subject to District Rule 4305, Boilers, Steam Generators and Process Heaters, Phase 2, and District Rule 4306, Boilers, Steam Generators and Process Heaters, Phase 3. Source testing requirements,in accordance with District Rules 4305 and 4306, will be discussed in Section VIII, District Rules 4305 and 4306, of this evaluation. iii. C-3953-13-0 and C-3953-14-0 Pursuant to District Policy APR 1705, source testing is not required for emergency standby IC engines to demonstrate compliance with Rule 2201. 

### 2. Monitoring 

### i. C-3953-10-0 and C-3953-11-0 Monitoring of NO

### x emissions is required by District Rule 4703. The applicant has proposed a CEMS for NO

### x. CO monitoring is not specifically required by any applicable Rule or Regulation

.

.Nevertheless; due to erratic CO emission concentrations during start-up and shutdown periods, it is necessary to limit the CO emissions· on a pound per hour basis. Therefore, a CO CEMS is necessary to show compliance with the CO limits of this permit. The applicant has proposed a CO CEMS. 40 CFRPart 60 Subpart KKKK and District Rule 4703 requires monitoring of the fuel consumption. Fuel consumption monitoring will be required. 40CFR Part 60 Subpart KKKK requires monitoring of the fuel sulfur content. The gas supplier, Pacific Gas & Electric (PG&E), may delivergas with a sulfur content of up to 1.0 grlscf. Since the sulfur content of the natural gas would not exceed this value, it is District practice to allow the facility to demonstrate compliance with the limit by providing gas purchase contracts, supplier certification, tariff sheet or transportation contract; or, if these documents cannot be provided, physically monitor the fuel sulfur content weekly for eight ·consecutive weeks and semi-annually thereafter if the fuel sulfur content remains below 1.0 grlscf. Avenal Power Center, LLC will be operating these turbines in complia.nce with the fuel sulfur content monitoring requirements as described in the Rule 4001, Subpart KKKK· discussion below. Therefore, compliance with the monitoring requirements will be satisfied.

56AvenalPowerCenter, LLC(08-AFC-01) 

### SJVACPO Determination ofCompliance, C-1080386


### ii. C-3953-12-0 As required by District Rule 4305, Boilers, Steam Generators and Process Heaters, Phase 2, and District Rule 4306, Boilers, 'Steam Generators andProcess Heaters, Phase 3, this unit is subject to monitoring requirements. Monitoring requirements, in accordance with District Rules 4305 and 4306, will be discussed in Section VIII, District Rules 4305and4306, ofthis ·evaluation. 

### iii

.. C-3953-1'3-0 and C-3953-14-0 No monitoring is required to demonstrate compliance with Rule 2201. 

### 3. Recordkeeping 

### i. C-3953-10-0 and C-3953-11-0 The applicant will be required to keep records of all ofthe parameters that are required to

. be monitored. Refer to section VIII.F.2 of this document for a discussion of the

.parameters that will be monitored.



### ii. C-3953-12-0 As required by District 'Rule 4305, Boilers, Steam Generators and Process Heaters, Phase 2, and District Rule 4306, Boilers, Steam Generators andProcess Heaters, Phase 3, this unit is subject to recordkeeping requirements. Recordkeeping requirements, in accordance with District Rules 4305 and 4306, will be discussed in Section VIII, District Rules 4305and4306, ofthis evaluation. The following permit condition will be listed**~n** permit as follows:

• All records shall be maintained and· retained on-site for a minimum of fi"ve (5) years, and shall be made available for District inspection upon request. [District f3ules 1070, 4305, and 4306] 

### iii. C-3953-13-0 and C-3953-14-0 Recordkeeping is required to' demonstrate compliance with the offset, public notification, and daily emission limit requirements of Rule 2201. As required by District Rule 4702, Stationary Internal Combustion Engines
- Phase 2, these 

## Ie engines are subject to .recordkeeping requirements. Recordkeeping requirements, in accordance with District Rule 4702, will be discussed in Section VIII, DistrictRule 4702, ofthis evaluation.

57"AvenalPowerCenter, LLC(08-AFC-01) SJVACPO Determination ofCompliance, C-10803"86


### 4. Reporting 

### i. C-3953-10-0 and C-3953-11-0 40 CFR Part.60 Subpart KKKK requires that the facility report the use offuel with a sulfur content of morethan 0.8%byweight. Such reporting will be required. 40 CFR Part 60 Subpart KKKK requires the reporting of exceedences of the NOx emission limit ofthe permit. Such reporting will be required. 

### ii. C-3953-12-0 No reporting is required to demonstrate compliance with Rule 2201. 

### iii. C-3953-13-0 and C-3953-14-0 No reporting is required to demonstrate compliance with Rule 2201. Rule"2520 FederallyMandated"OperatingPermits 'This project will be subject to Rule 2520 (Title 

### V) because it will meet the following criteria specified in section 2.0:

• "Section 2.3 states, "Any majorsource." The facilitywill be 

### a majorsource for NO

### x ., CO, VOC, and PM10 afterthis project.

• Section 2.4 states, "Any emissions unit, including an area source, subject to a standard or other requirement promulgated pursuantto section 111 (NSPS) or 112 (HAPs) ofthe CAA

..."The turbines are subjectto NSPS.

• Section 2.5 states "A source with an acid ra'in unit for which application for an acid rain permit is required pursuant to Title IV (Acid Rain Program) of the CAA." The turbines are subjectto the acid rain program.

• Section 2.6 states, "Any source required to have a preconstruction review permit pursuant to the requirements of the prevention of significant deterioration (PSD) program underTitle 

### I ofthe Federal Clean AirAct." This facility is required to obtain a PSD permit from the EPA. Pursuant to Rule 2520 section 5.3.1 Avenal Power Center must submit a Title V application within 1"2 months of commencing operations. No action is required at this time.

.58

### AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386

• Permittee shall submit an. application to comply with SJVUAPCD O·istrict Rule 2520 - Federally Mandated Operating Permits within twelve months of commencing operation. [District Rule 2520]


### Rule2540 AcidRain Program The proposed CTG's are subject to the acid rain program as phase II units, Le. they will be installed after 11/15/90 ·and each has a generator nameplate rating greater than 25 MW. The acid rain program will be implemented through a Title V operating permit. Federal regulations require submission. of an acid rain permit application at least 24 months before the later of 1/1/2000 or the date the unit expects ·to generate electricity. The facility anticipates beginning commercial operation in November of·2011. The acid rain program requirements for this facility are relatively minimal. Monitoring of the NOx and ·SOxemissions and a relatively small quantity of SOx allowances (from a national SOx allowance bank) will be required as well as the use ofa NOx CEM. The following condition will be placed on permits C-3953-10-0,**~11-0** and -14-0 to ensure thatAvenal Power Center, LLC submits an applicati.on to complywith the requirements of the acid rain program within the appropriate timeframe:

.

• Permittee shall submit an application to comply with SJVUAPCO Oistrict Rule 2540 - Acid Rain Program. [District Rule 2540]


### Rule2550 FederallyMandatedPreconstruction ReviewforMajorSources

### ofAir Taxies SeGtion 2.0 states, "The provisions of this rule shallonlyapplyto applications to construct orreconstruct

### a majorairtoxies source with Authorityto Constructissuedon orafterJune 28, 1998."· The applicant has provided the following analysis for Noncriteria pollutants/HAPs. Noncriteria pollutants are compounds that have been identified as pollutants that pose a significant health· hazard. Nine of these pollutants are regulated under the Federal New Source Review program:· lead, asbestos, beryllium, mercury, fluorides, sulfuric acid mist, hydrogen sulfide, total reduced sulfur, and reduced sulfur compounds. 8 In addition to these nine compounds, the federal Clean Air Act lists 189 substances as potential hazardous air pollutants (Clean Air Act Sec. 112(b)(1»). The SJVAPCD has also published a list of compounds it defines as potential toxic air contaminants (Toxics

8 These pollutants are regulated under federal and state air quality programs; however,.they are evaluated as noncriteria pollutants bythe California EnergyCommission (CEC). 59AvenalPo.werCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386 Policy, May 1991; Rule 2-1-316). Any pollutant that may be emitted from the project and is on the federal New Source Review List, the federal Clean ·Air Act list, and/or the SJVAPCD toxic aircontaminant list has been evaluated. Noncriteria pollutantemission factors for the analysis of emissions from the gas turbines were. obtained from AP-42 (Table 3.1-3, 4/00, and Table 3.4-1 of the Background Document for Section 3.1), from the California Air Resources Board's CATEF database for gas turbines, and from source tests on a similar turbine. Specifically, factors for all pollutants except formaldehyde, hexane, propylene, and naphthalene and other PAHs were taken from AP-42.:9 AP-42 did not contain factors for hexane or propylene, and did not include speciated data for PAHs. Factors for these pollutants and for naphthalene were taken from the CATEF database (mean values). The 'emission factor for formaldehyde was taken from the results of·a June 2000 source test on a dry Low NO

### x combustor-equ'ippedlarge frame turbine

.. Hazardous Air Pollutant Emissions (perCATEF) Avenal Energy Project
- GE Frame 7 (with Duct Burners)" CATEF Maximum Hourly Maximum Annual Maximum Annual Hazardous Air Pollutant Emission Factor Emissions per Emissions per Emissions both (lb/MMSCF)(1) Turbine (Ib/hr) (2) Turbine. (tpy) (3) Turbines (tpy)

..



### ·**Aq~!~l~~!l'yq~** 

### .**!!.J~~~**

### __ Q?**9_·9_~ Q:.~~**  

## 9.:?!

_ Acrolein 3.69E-03 0.01

. 0.03 6.04E-02 ._--------------------------------------------------------------------------------------------------------------------------- Benzene 3.33E-03 0.01 0.03 5.45E-02 ._---------------------------------------------------------------------------------------------------------------------------- 

### · 1**!~:~_L!~C!q~~~~ !!·_~~~-_Q1** **~:~?~:Q~ ~_·9_~~~9A** **~:. ~~-_~~**  

### _

·**~!~YJ _~~!1_~~~~** **~._~~~-_Q? 9_·9_~** **Q:.~? 9.:?~**  

## _

· 9!!1)?**J~ ~Y9** **_~ 1·~9**  -_Q

### 1 9_·**~_~** 

### ,. 1:.**~9** 

### ?.:

### !

_ Hexane 2.59E-01 0.55 2.12 4.24

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



### .**~9~~!~?J~~_~ 1~~~~-J!~** **?:~~~:Q~ ~:9_~~~9~** **~:.~~~~~?** 

### _ Polycyqlic aromatic

·**~Y~!9~~~~~n.~ _Q:~}** **~~- ~~~** **-_-~** . _ Anthracene 3.38E-05 7.22E-05 2.77E-04 5.53E-04

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

.**~~_~~9{~)?!!t!!~C!~~~_~ ~~~~~**  __**Q~ 1:~~~:Q9** **~:~_~~~9~ ~:.~~~:~~_.**  

### _

.**~~~~9_(a)~~~~~~ 1~~~~** 

### __**Q~ ?:~?~:Q9** **~:~!!~~9~ ~:.~~~~~~**  

### _

·**~~~_~~9H? )~!J_q~~~!~** **!~n.~** 

### 1·_1**~-_Q~** 

### ?:1**J~:Q9 ~_.** **?_~ ~9_~**  

### !:.**~~ -_~~**  

### _

·**~~_f!~9{~}~!J_~~~I]!~r~!1_~ 1·_1Q~-_Q~** **?:~9~:Q9 ~_·9_Q~~9_~** **~:.~~~-_~~** 

### _

.**~~fY~~~~ ~~~?~** 

## __**Q~ ~:~?~:Q9** **?:9_~~~9~ ~:.~?~~~~**  

### _

·**Rt~~~~@.,h)~~!~~~9~_~~ ~·_~9~-J!~** **~:Q?~:Q9 ~_·~_~~~9~** **~:.~~~-_~~** 

### _

·**l~~~Q9{j .!?.!~~9~)~.Yr-~f]~-** **~._~~~-_Q~ ~:Q?~:Q9** **:~_~~~91 ~:.~~~-_~~**  

### _

·**'='!9.R}!'-~f]~_ ~.?'l~~** **~._~~~-_Q? ~:~?~:Q?** **?_·~_~~~9_1** 

### .**9.:~~** 

### _ Toluene 1.33E-01 0.28 1.09 2.18 ._--------------------------------------------------------------------------------------------------------------------------- Xylenes 6.53E-02 0.14 0.53 1.07

Total 6.01 12.02 (1) From AP-42 and CATEF databases and source tests. (2) Based C?n a maximum hourly turbine fuel use of 2,224.1 MMBtu/hr (with duct burner) and fuel HHV of 1,021 Btu/sef. (2.14 MMscf/hr)

9 Factors for acrolein and benzene reflect the use of an oxidation catalyst and were taken from Table 3.4-1 ofthe Background Documentfor Section 3.1.

. 60

### AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination

### ofCompliance, C-1080386
(3) Based on a maximum annual turbine fuel use of 16,711,728 MMBtu/year (with duct burner) and fuel HHV of 1,021 Btu/sef. (16,368 MMscf/yr) Although. the turbines/HRSGs will be equipped with oxidation· catalyst systems, only the acrolein and benzene emission factors reflect any control effectiveness. As discussed above, these factors are based on test data ratherthan any assumption regarding catalyst control efficiency. Therefore, as emissions of each individual HAP are below 10 tons peryear and total HAP emissions are below .25 tons peryear, the Avenal Power Center, LLC Project will notb'e a majorairtoxics source and the provisions ofthis rule do not apply

.



### .Rule4001 NewSource Performance Standards 40 CFR 60 - Subpart Dc NSPS Subpart Dc appl.iesto steam generating units that are constructed, reconstructed, or modified after 6/9/89 and have 

### a maximum design heat input capacity of 100 MMBtu/hr or less,but greater than or equal to 10 MMBtu/hr.Subpart Dc has standards for

### S9x and

.**·PM10~** 60.42c- Standards for Sulfur Dioxide Since coal is not combusted. by the bo.iler in this project, the requirements of this section are not applicable. 60.43c- Standards for Particulate Matter The boiler is not fired on coal, combusts mixtures of coal with other fuels, combusts wood, combusts mixtured of wood with other fuels, or oil; therefore it will not be subject to the requirements ofthis section. 60.44c - Compliance and Performance Tests Methods and Procedures for Sulfur Dioxide. Since the boiler in this project is not subject to the sulfur dioxide requirements of this subpa.rt, no testing to show compliance is required. Therefore, the requirements of this section are not a·ppHcab·le to the boiler in this project. 60.45c - Compliance an'd Performance Test Methods and Procedures for Particulate Matter
- Since the boiler in this project is not subject to the particulae matter requirements of this subpart, no testing to .show·compliance is required. Therefore, the requirements of this section are not applicable tothe boiler in this project.
61

### AvenalPower**Center~** 

### LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386


### 60.46c-- Emission Monitoring for Sulfur Dioxide Since the boiler,in this project is not subject to the sulfur dioxide requ"irements of t,his subpart, no monitoring i.s required. Therefore, the requirements of this section are not applicable to the boiler in this project. 60.47c- Emission Monitoring for Particulate Matter Since the boiler in this project is notsubject to the particulate matter requirements ofthis subpart, no monitoring is req·uired. Therefore, the requirements of this section are not applicable to the boiler in this project. 60.48c- Reporting and Recordingkeeping Requirements Section 60.48c (a) states that the owner or operator of each affected facility shall submit notification of the date of construction or reconstruction, anticipated startup, and actual startup, as provided by §60.7 ofthis part. This notification shall include: (1) The design heat input capacity ofthe affected facility and identification of fuels to be combusted in the affected facility

.. The design heatinputcapacityand type offuel combustedatthe facility willbe listed on the unit's equipment description. No conditions are required to showcompliance**~ith** 

### this requirement. 

### (2) If applicable, a copy of any Federally enforceable requirement that limits the annual capacityfactorfor anyfuel mixture offuels under§60.42c or§40.43c. This requirement is not applicable since the units are not subject to §60.42c or §40.43c. 

### (3) The annual capacity factor at which the owner or operator anticipates operating the affected facility based on all fuels fired and based on each individual fuel fired. The facility has not proposed an annual capacity factor; therefore one will not be required. 

### (4) Notification if an emerging technology will be used f9r controlling S02,emission.s. The Administrator will examine the**descr~ption** 

### of the control device and will determine whether the technology**qualifi~s** 

### as an emergin'g technology. In making this determination, the Administrator may require the owner or operator of the affected facility to submit additional information concerning the control device. The affected facility is subject to the provisions of §60.42c(a) or (b)(1), unless and until this dete'rmination is made bythe Administrator

62AvenalPowerCenter, LLC**(08-AF~-01)** SJVACPO Determination ofCompliance, C-1080386
This requirement is not applicable since the units will not be equipped with an emerging technologyusedto control

### S02 emissions. Section 60.48 c (g) states that the owner or operator of each affected facility shall record and maintain records of the amounts of each fuel combusted during eac'h da·y. The following conditions will be added to the permitto assure compliance with this section. • A**non-resettable~** totalizing mass or volumetric fuel flow meterto measure the amount offuel combusted in the unit shall be installed, utilized and maintained. [District Rules 2201 and 

### 40 CFR 60.48 (c)(g)]

.• Permittee' shall maintain daily records of the type and .quantity of fuel combusted by the boiler. [District Rules 2201 and 40 CFR 60.48 (c)(g)] Section 60.48 

### c (i) states that all records required underthis section shall be ,maintained by the owner or operator of the affected facility for a period of 

### twe;> 'years following the date· ofsuch record. District Rule 4306'requires thatrecords be kept forfive years.
40 CFR 60 - Subpart GG 40 CFRPart 60 Subpart GG·applies to all stationary gas turbines with a heat input greater than 10.7 gigajoules per hour (10.2 MMBtu/hr), that commence construction, modification, or reconstruction after October 3, 1977. Avenal Power Center, LLC has indicated.that the installation and construction ofthe proposed turbines will be completed in2011. Therefore, these turbines.meetthe applicability requirements ofthis subpart. 40

.CFR 60 Subpart KKKK, Section 60.4305(a), states that this su.bpart applies to all stationary gas turbines with a heat input greater than 10.7 gigajoules (10 MMBtu) per hour, which·commenced construction, modification, or reconstruction after February 18,' 2005. Aven.al .Power Center, LLC' has indicated that the installation and construction of the proposed turbines will be completed in 2011. Therefore, these turbines also meet the applicability requirements ofthis subpart. .: 40 CFR 60 Subpart KKKK, Section 60.4305(b),

... states that stationary combustion turbines regulated underthis subpart are exempt from the requirements of 40 CFR 60 Subpart GG. As discussed above, 40 CFR 60 SubpartKKKK is applicable to these proposed turbines. Therefore, they are exempt from the requirements of 40 CFR 60 Subpart'GGand no further discussion is required.

63AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination 

### ofCompliance, C-1080386
40 CFR 60 - Subpart1111 §60.4200
- Applicability 40 CFR Part 60 Subpart 1111 applies to all owners and operators of statio'nary compression ignited internal combustion engines that commence construction after July 11, 2005, wherethe engines are: 1) Manufactured afterApril 1 ,2006, if not a fire pump engine. 2) Manufactured as a National' Fire Protection Association (NFPA) fire pump engine afterJuly 1, 2006. ' Since the proposed engines will be instaUed after July 11, 2005 and will be 'manufactured, afterApril 1, 2006, this subpart applies. All of the applicable stands of this subpart are less restrictive than current District requirements. This engine will comply with all current District standards so further discussion is required.
40 CFR 60 - Subpart KKKK 40 CFR Part 60 Subpart KKKK applies to all,stationary gas turbines rated at'greaterthan or equal to 10 MMBtu/hr that commence cqnstruction, modification, or reconstruction after February 18, 2005. The proposed gasturbines involved in this project have a rating of 1,794.5 'MMBtu/hr and will be installed after February 18, 2005. Therefore, this subpart applies to these gas turbines. Subpart KKKK established requirements for nitrogen oxide (NOx) and sulfur dioxide (SOx) emissions. Section 60.4320- Standards for Nitrogen Oxides: Paragraph (a) states that NOx emissions shall notexceed the emission limits specified in Table 

### 1 of this subpart. Paragraph, (b) states that if you have two or, more turbines that are connected to a single generator, each turbine must meet the em'ission limits for NOx. Table 

### 1, states that new, modified, or reconstructed turbines firing natural gas with a combustion turbine heat input at peak load of greaterthan 850 MMBtu/hr shall, meet a NOx emissions limit of 

### 15 ppmvd 

### @'15°!'c> O2 or 54 ng/J of useful output (0.43 Ib/MWh). Avenal Power Center is proposing a NOx emission concentration limit of 2.0 ppmvd 

### @ 15% O2 for each turbine. Therefore, the proposed turbines will be ,operating in compliance with the NOx emission requirements of this subpart. The following conditions' will ensure continued compliance with the requirements ofthis section:

64AvenalPowerCenter, LLC(OB-AFC-01) SJVACPD Determination

### ofCompliance, 'C-1080386

• Emission rates from this unit (with duct burner firing), except during startup and shutdown periods, shall not exceed any ofthe foUowing limits: NOx (as N02)
- 17.44 Ib/hr and 2.0 ppmvd 

### @ 

### 15°A> 02; 

# voe (as**meth~ne)** - 6.13 Ib/hr and 2.0 ppmvd 

### @ 15°k 02; CO -10.60 Ib/hrand 2.0 ppmvd 

### @ 15·0/0 02; PM10 -11.78Ib/hr; or SOx (as 802)
- 6.72Ib/hr. ·NOx (as N02) emission limits are one hour rolling averages. All other emission limits are three hour rolling averages. [District Rules 2201, 4001, and 4703]

• Emission rates from this unit (without duct burner firing), except during startup and shutdown periods, shall not exceed any of the following limits: NOx (as N02)
- 13.28 Ib/hr and 2.0 ppmvd @ 150/002; VOC (as methane)
- 3.23 Ib/hr and 1.4 ppmvd @. 150/0 02; CO
- 8.35 Ib/hr and 2.0 ppmvd 

### @ 15% 02; PM10
- 8.97 Ib/hr; or SOx (as 802)
- 5.11 Ib/hr. NOx (as N02) emission limits are one hour rolling averages. All· other emission limits are three hour rolling averages. [District Rules 2201 , 4001, and 4703]

. Section 60.4330 - Standards for Sulfur Dioxide:

Paragraph (a) states that ifyourturbine is located in a continental area, you'must comply with one ofthe following: (1) Operator must not cause to be discharged into the atmosphere from the subject'stationary combustion turbine any gases which containS02 in excess of 110 nanograms per Joule (ng/J) (0.90) pounds per megawatt-hour (lb/MWh)) gross output; or (2) Operator must not burn in the subject stationary combu·stion turbine any fuel which contains total potential sulfur emissions in excess of 26 ng S02/J (0.060 Ib S02/MMBtu) heat input. Avenal Power Center is proposing to burn natural gas fuel in each of these turbines with a maximum sulfur content of 1.0 grain/ 100 scf (0.00285 Ib/MMBtu). Therefore, the proposed turbines will be operating in. compliance with the SOx emission requirements of this section. The following condition will ensure continued compliance with the requirements ofthis section:

• The CTG shall be fired exclusively on PUC-regulated natural gas with a sulfur contentof no greaterthan 1.0 grains of sulfur. compounds (as S) per 100 dry scf of natural gas. [District Rule 2201 and 40 CFR 60.4330(a)(2)] Section 60.4335 - NOx Compliance Demonstration, with Wateror Steam Injection: Paragraph (a) states that when a turb'ine is using water or ste.am injection to reduce NOx emissions, you must install, calibrate, maintain and operate a continuous monitoring system; to monitor and record the fuel consumption and the ratio ofwater orsteam to fuel being fired in the turbine when burning a fuel that requires water or steam injection for compliance. 65AvenalPowerCenter, LLC(OB-AFC-01) 'SJVACPD Determination ofCompliance, C-1080386

Avenal Power Center does not use water or steam injection in their turbines therefore; the requirements ofthis section are not applicab'le to the turbines in this project. Section 60.4340**NO~** Compliance Demonstration,.without Water or Steam Injection: Paragraph (b) states that as an alternative to annual source testing, the facility may install, calibrate, maintain and operate one of the following continuous monitoring systems: (1) Continuous emi.ssion monitoring as described in §§60

..4335(b) and 60.4345, or (2) Continuous parameter monitoring Avenal Power Center has proposed to install a CEMS system as described in §§60.4335(b)

.and 60.4345 therefore; the following condition will ensure continued compliance with the requirements ofthis section:

• The owner or operator shall install, certify, maintain, operate and quality-assure 

### a Continuous Emission Monitoring System (CEMS) which continuously measures

. and records the exhaust gas. NOx, CO and 

### 02 concentrations. Continuous

emissions monitor(s) shall be capable of monitoring emissions during normal operating conditionsJ, and during startups and shutdowns, provided the CEMS passes the relative accuracy requirement for startups and shutdowns specified herein. If relative accuracy of CEMS cannot be demonstrated during .startup conditions, CEMS results during startup and shutdo·wn events shall be**~eplaced** with startup emission rates obtained from source testing to determine compliance with emission limits contained in this document. [District Rules 1080 and 4703 and 

### 40 CFR 60.4340(b)(1)] Section 60.4345 -GEMS Equipment Requirements: Paragraph (a) states that eachNOx diluent CEMS must be installed and certified according to Performance Specification 2 (PS 2) in Appendix B to this part, except the 7- day calibration drift is based on unit operating days, not calendar days. With state approval,' Procedure 1 in Appendix F to this part is not required.. Alternatively, a NOx diluer)t CEMS that is installed and certified according to Appendix 

### A of Part 75 of this chapter is acceptable for use underthis sut;>part. The relative accuracytest audit (RATA)

, ofthe CEMS Shall be performed on a Ib/MMBtu'**basis~**

Paragraph (b) states that as specified in §60.13(e)(2), during eachfuH unit operating hour, both the NO

### x monitor and the**dilu~nt** monitor must complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each 15-minute quadrant ofthe hour, to validate the hour. For partial unit operating hours, at least one valid data point must be obtained with each monitorfor each quadrant ofthe hour in which the unit operates. For unit operating hours in which required quality assurance and maintenance activities are performed on the CEMS·, a minimum oftwo va,lid data points (one in each of 66Avenal**Pow~r** Center, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
two quadrants) are required for each monitor to validate the NO

### x emission rate for the hour. Paragraph (c) states that eac,hfuel flowmeter shall be installed, calibrated, maintained, and operated according to the manufacturer's instructions. Alternatively, with ,state approval, fuel flowmeters that meet the installation, certification, and quality assurance requirements of Appendix D to Part 75 of this chapter are acceptable for use under this subpart. Paragraph (d) states that each watt meter, steam ,flow meter, and each pressure or temperature measurement device shall be installed, calibrated, ma'intained, and operated according to manufacturer's instructions. Paragraph (e) states that the owner or operator shall develop and keep on-site a quality assurance (QA) plan for all of the continuous monitoring equipment described in paragraphs (a), (c), and (p) of this section. For the CEMS and fuel flow meters, the owner or operator may, 'with state approval, satisfy the requirements ofthis paragraph by implementing the QA program and plan described in section 1 of Appendix 

### B to Part 75 ofthis chapter. Avenal Power Center will be**require~** to install and operate 

### a NO

### x CEMS in accordance with the requirements of this section. As discussed above, Avenal Power Center'is not required to install a fuel flow meter, watt meter, steam flow meter, or a pressure or temperature measurement device to comply with the requirements of this subpart. Therefore, the proposed turbines will be operating in compliance with the requirements of this section. ,The following conditions will ensure continued compliance with the requirements ofthis section:

• The NO

### x, CO and O2 CEMS shall meet the requirements in 40 CFR 60, Appendix F Procedure 1 and Part 60, Appendix B Performance Specification 2 (PS 2), or shall meet equivalent specifications established by mutual agreement of the District, the ARB, and the**EPA~** [District Rule 1080 and 40 CFR 60.4345(a)]

• The CEMS shall complete a minimum, of one cycle of operation (sampling, analyzing, and data recording) for each successive 15-'minute period or shall meet equivalent specifications established by mutual agreement ofthe District, the ARB and the EPA. [District Rule 1080 and 40 CFR 60.4345(b)] Section 60.4350 - CEMS Data and Excess NOx Emissions: Section 60.4350 states that forpurposes of identifying excess emissions: (a) All CEMS data must be' reduced to hourly averages as specified in §60.13(h).

67AvenalPowerCenter, LLC(OB-AFC-01) 

### SJVACPO Determination ofCompliance, C-1080386 (b) For each unit -operating hour- in which a valid hourly average, as described in §60.4345(b),is obtained for both NOx and diluent monitors,

_ the data acquisition and

-handling system must calculate and record the hourly NOx emission**r~te** in :units of ppm or Ib/MMBtu, using the appropriate equation from Method 19 in Appendix A of this part. For any hour in which the hourly average O2concentration exceeds 19.0 percent O2 (or the hourly average CO2concentration is less than 1.0 percent CO2), a diluent cap value of 19.0 percent O2 -or 1.0 percent C02 (as applicable) may be used in the emission calculations. (c) -Correction of measured NOxconcentrations to 15 percent O2 is not allowed. (d) If you have installed and certified- a NOx diluent CEMS to meet the requirements of Part 75 ofthis chapter, states can approve that only quality assured data from the CEMS shall be used to identify excess emissions underthis subpart. Periods where the missing data substitution procedures in Subpart D of Part 75 are applied are to be reported as monitor downtim-e in the excess emissions and monitoring performance report required under §60.7(c). (e) All required fuel flow rate, steam flow rate, temperature, pressure, and megawatt data mustbe reduced to houfly averages. (f) Calculate the hourly average NOx emission rates, in units of the emission standards under §60.4320, using either ppm for units comp-Iying with the concentration limit or the equations 1 (simple cycle turbines) or 2 (combined cycle turbines) listed in §60.4350, paragraph 

### (f). Avenal Power Center is proposing to monitor the NOx emissions rates from the turbines with a CEMS. The CEMS system will be used to determine if, and when, any excess NOx emissions are released to the atmosphere.from the turbine exhaust stacks. The CEMS will be operated in accordance with the methods and procedures described above. Therefore, the proposed turbines will be operating in compliance with the requfrements of this section. The following condition will ensure continued compliance with the requirements ofthis section:

• Results of continuous emissions monitoring shall be reduced according to the procedure established in 40 CFR, Part 51, Appendix P, paragraphs 5.0**t~rough** 5.3.3, or by other methods deemed equivalent by mutual agreement with the District, the ARB, and the EPA. [District Rule 1080] Section 60.4355-- Parameter Monitoring Plan: This section sets forth the requirements for operators that elect to continuously monitor parameters in lieu of installing a CEMS for NOx emissions. As discussed above, Avenal Power
- Center is proposing to instaliCEMS on each of these turbines that will directly measure NOx emissions. Therefore, the requirements of this section are not applicable and no further discussion is required. 68· AvenalPowerCenter,LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386


### Sections 60.4360, 60.436_5 and 60.4370 - Monitoring of Fuel Sulfur Content: Section 60.4360 states that an operator must monitor the total sulfur content ofthe fuel being fired in-the turbine, except as provided in §60.4365. The sulfur content ofthe fuel must be determined using total sulfur methods described in §60.4415. Alternatively, if the total sulfur contentofthe gaseous fuel during the most-recent performance test was less than half the- applicable limit, ASTM 04084, 04810, D5504, or 06228, or Gas Processors Association Standard 2377 (all of which are incorporated by reference, see §60.17), which measure the majorsulfur compounds, may be used. Section 60.4365 states that an operator may elect not to monitorthe total sulfur content of the fuel combusted in the turbine, if the fuel is demonstrated not to exceed potential sulfur emissions of 26 ng S02/J (0.060 Ib S02/MMBtu) heat input for units located in continental areas and 180 n-g S02/J (0.42 IbS02 /MMBtu) heat input for units located- in noncontinenta-I areas ora continental area that the Administrator determines does not have access to natural gas and that the removal of sulfur compounds would cause more environmental harm than benefit. You must use one of the following sources of "information to make the required demonstration: (a) The fuel quality characteristics in a current, valid purchase contract, tariff sheet or transportation contract for the fuel, specifying that the maximum total SUlfur content for oil use in continental areas is--0.05 weight percent (500ppmw) or less and 0.4 weight percent (4,000 ppmw) or less for noncontinental areas, the total sulfur content for natural gas use in continental areas is 20 grains of sulfur or less per 100 standard cubic feet and 140 grains of sulfur or less per -100 standard cubic feet for noncontinental areas, has potential sulfur emissions of less than less than 26 ng S02/J (0.060 Ib S02/MMBtu) heat input for continenta-I areas and has potential sulfur emissions of less than less than 180 ng S02/J (0.42 Ib S02/MMBtu) heat inputfor noncontinental areas; or (b) Representative fuel sampling data which show that the sulfur content of the fuel does not exceed 26 ng S02/J 

### (0.060 Ib S02/MMBtu) heat input for continental areas or 180 ng S02/J (0.42 Ib S02/MMBtu) heat input for noncontinental areas. At a minimum, the amount of fuel sampling data specified in section 2.3.1.4 or 2.3.2.4 ofAppendix 0 to Part 75 ofthis chapter is required. Avenal Power Center is proP9sin9 to operate these turbines on natural gas that contains a maximum sulfur content of 1.0 grains/100 scf. Primarily, the natural gas supplier should be able to provide a purchase contract, tariff sheet or transportation contract for

-the fuel that**demonstrate~** 

### compliance with the natural gas sulfur content limit. However,

Avenal Power Center has a_sked-thatthe option ofeither using a purchase contract, tariff sheet or transportation contract or actually physically
-monitoring the sulfur content be incorporated into their permit.



### 69AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386


### Section 60.4370 states that the frequency of determining the sulfur content of the fuel must be as follows: (a) Fuel oil. 

### For fuel oil, use one of the total sulfur sampling options and the

.associated sampling frequency described in sections 2.2.3, 2.2.4.1, 2.2.4.2, and

2.2.4.3 of Appendix D to Part 75 of this chapter (i.e., 

### flow propo·rtional sampling, daily sampling, sampling from the unit's storage tank after each addition offue·1 to the tank, or sampling each delivery priorto combining it with fuel oil already in the intended storage tank). (b) Gaseous fuel. 

### If you elect not to demonstrate sulfur content using options in §60.4365, and the fuel is supplied without intermediate bulk storage, the sulfur content value ofthe gaseous fuel must be determined and recorded once per unit operating day. (c) Custom schedules. 

### ·Notwithstandin.g the requirements of paragraph (b) of this section, operators· or fuel venqors may develop custom schedules for determination ofthe total sulfurcontent ofgaseous fuels, based on the design and operation ofthe affected facility and the characteristics ofthe fuel supply. Except as provided in paragraphs (c)(1) and (c)(2) ofthis section, custom schedules shall be substantiated with data and shall be approved bythe Administrator before they can be used to complywith the standard in §60.4330. When actually required to physically monitorthe sulfur content in the fuel burned in these turbines, Ave.nal Power Center.is proposing a custom monitoring schedule. The District and EPA have previously approved a custom monitoring schedule of at least one per week. Then, if compliance with the fuel sulfur content limit is demonstrated for eight consecutive we"eks, the monito"ring frequency shall be at least once every six months. If any six month monitoring period shows an exceedance, weekly monitoring shall**re~ume.** 

### Avenal Power Center is proposing to follow this same pre-approved fuel sulfur content monitoring scheme for the turbines. The following condition will ensure continued compliance with the requirements ofthis section:

• The sulfur content ofeach fuel source shall be: (i) documented in a valid purchase contract, a supplier certification, a tariff sheet or transportation contract or (ii)" monitored within 60 days of the end of the commission period and weekly thereafter. Ifthe sulfur content is**de~onstrated** 

### to be less than 1·.0 gr/100 scffor eight conse"cutive weeks, then the monitoring frequency shall be every six months.

Ifthe result of any six m·onth monitoring demonstrates thatthe fuel does not meet the fuel sulfur content" limit, weekly monitoring shall resume. [District Rule 2201 and 40 CFR 60.4360, 60.4365(a) and 60.4370(0)]

.



### . 70Avenal

### PowerCenter, LLC(OB-AFC-01) SJVACPO Determination

### ofCompliance, C-1080386
Section 60.4380 - Excess**NO~** Emissions: Section 60.4380 establishes reporting requirements for.periods of excess emissions and monitor downtime. Paragraph (a) lists requirements for operators choosing to monitor para'meters associated with water or steam to fuel' ratios. As discussed above, Avenal Power Center is not proposing to**monito~** parameters associated with water or steam to fuel ratios to predict what the NOx emissions fror:n the turbines will be. Therefore, the requirements ofthis paragraph are not applicable and no further discussion is required. Paragraph (b) states that forturbines' usingCEM's: (1) An excess emissions is any unit operating period.inwhich the 4-hour or 30-day rolling average NOx emission rate exceeds the applicable emission limit in §60.4320. For the purposes of this subpart, a "4-hour rolling average NOx emission rate" is the arithmetic average of the average NOxemission rafe in ppm or 

### ng/J (lb/MWh) measured by the continuous emission monitoring equipment for a given hour and the three unit operating hour average NOx emission rates immediately preceding that unit .operating hour. Calculate the rolling average if a valid NOx emission'rate is'obtained for at least 3 of the 4 hours. Forthe purposes ofthis subpart, a "30-day rolling**averag~** NOx emission rate" is the arithmetic average of all hourly NOx emission data in ppm or 

### ng/J (lb/MWh) measured by the continuous emission monitoring equipment for a given day and the twenty-nine unit operating days ·immediately preceding that unit operating day. A new 30- day average is calculated each unit operating day as the average of all hourly NOx emissions rates for the preceding 30 unit 'operatfng days if a valid NOx emission rate. is obtained for at least 75 percent of all operating hours. (2) A period of monitor downtime is any unit operating hour in which the data for any of the following· para'meters are either missing or invalid: NOx concentration, C02 or O2

.concentration, fuel flow rate, steam flow rate, steam temperature, steam pressure, or

megawatts. The steam flow rate, steam temperature, and steam pressure are only required ifyou will use this information for compliance purposes. (3) For operating periods during whic·h multiple emissions standards apply, the applicable standard is the average of the applicable standards during' each hour. For hours with multiple emissions standards, the applicable limit for that hour is determined based on the condition that corresponded to the highest emissions standard. Paragraph (c) lists requirements for operators who choose to monitor combustion parameters that document proper operation ofthe NOx emission controls. Avenal Power Center is not proposing. to monitor combustion parameters that document proper operation of the NOx emission controls. Therefore, the requirements of this paragraph are not applicable and no furtherdiscussion is required.

71AvenalPowerCenter, LLC(OB-4FC-01) SJVACPO Determination ofCompliance, C-1080386


### The following condition will ensure continued compliance with the requirements of this section:

• Excess emissions shall be defined as any operating hour in which the 4-hour or30- day rolling average NOx concentration exceeds applicable emissions limit and a period of monitordowntime shall be a'ny'unit operating hour in which sufficient data are not obtained to validate the hour for either NOxor 

### 02 (or both). [40CFR 60.4380(b)(1 )] Section 60.4385 - Excess SOx Emissions: Section 60.4385 states that if an op'erator chooses the option to monitor the sulfur contentofthe fuel, excess emissions and monitoring 'downtime are defined as follows: (a) For samples of gaseous fuel and for oil samples obtained using daily sampling, flow proportional sampling, or sampling from the unit's storage tank, an excess emission occurs each unit operating hour included in the period beginning on the date and hourof**~ny** 

### sample for which the sulfur content of the fuel being fired in the combustion turbine**exce~ds** 

### the applicable limit and ending on the date and hour that a subsequent sample is taken that demonstrates compliance with the sulfur·Iimit. (b) If the option to sample .each delivery of fuel oil has been**select~d,** 

### you must immediately switch to one of the other oil sampling options (Le., daily sampling, flow proportional sampling, or sampHng from the unit's storage tank) ifthe s'ulfur content of a delivery e'xceeds 0.05 weight percent. You must continue to use one of the other sampling options until all ofthe oil from the delivery has been combusted, and you must evaluate excess emissions according to paragraph (a) of this section. When all of the fuel from the delivery has been burned, you may resume using the as-delivered sampling option. (c) A period of monitor downtime begins when a required sample is not taken by its due date. A period of. monitor downtime also begins on ·the date and hour of a required sample, if invalid results are obtained. The period of monitordowntime ends on the date and hourofthe nextvalid sample. Avenal Power Center will be following the d.efinitions and procedures specified above for determining periods of excess SOx emissions. Therefore, the proposed turbines will be operating in compliance with the requirements ofthis section.

72AvenalPowerCenter" LLC(08-AFC-01) SJVACPO Determination ofCompliance, C-1080386


### Sections 60.4375. 60.4380.**60~4385** 

### and 60.4395 - Reporting: These sections establish the reporting requirements for each turbine. These requirements include methods and, procedures for submitting reports of monitoring parameters, annual performance tests, excess emissions and periods of monitor downtime. Avenal Power Center is proposing to m'aintain records and submit reports in accordance with the requirements specified in these sections. Therefore, the proposed turbines will be operating in compliance,with the requirements ofthis section. The following condition will ensure continued compliance with**th~** 

### requirements ofthis section:

• The owner or operator shall submit a written report of CEM' 

### operations for each calendar qu'arterto the A-PCO. The report is due on the 30th 

### dayfollowing the end of the calendar quarter and shall include the following: Time intervals, data and magnitude of excess NO

### x emissions, nature and the cause of excess (if known),

,corrective 'actions taken and preventative measures adopted; Averaging period

used for data reporting corre,sponding to the averaging period specified in the emission test period and used to determ'ine compliance with an emissions

- standard; Applicable time and date of each period d'uring which the CEM was

inoperative (monitor downtime), except for zero and span checks, and the nature of system repairs and adjustments; A 

### negative declaration when no excess emissions occurred. [District Rule 1080 and 40 CFR 60.4375(a) and 60.4395] Section 60.4400 - NOx 

### Performance Testing: Section 60.4400, paragraph (a) states that an operator must cond,uct an initial, performance test, as required in §60

..8. Susequent 'NOx 

### performance tests shall be conducted on an annual basis (no more than 14 calendar months following the previous performance test). ' Paragraphs (1), (2) and (3) set fourth the requirements for the methods that are to be used during source testing. Avenal Power Center will be required to source test the exhaust of,these turbines within 120 days of initial startup and at least once every 12 months thereafter. They' will be required to source test in accordance with the methods and procedures specified in paragraphs ,(1), (2), and (3). Therefore, the proposed turbines will be operating in compliance With the requirements of this section. The following conditions will ensure continued compliance with the requirements ofthis section:

• 'Source testing to determine compliance with the NOx, 

# eo and 

# voe emission rates (Ib/hr and ppmvd' 

### @ 15°A> O2), NH3 

### emission rate (ppmvd 

### @ 150/0 O2) 

### and PM 10 

### emission rate (Ib/hr) shall be conducted at least once every 12 months. [District Rules 1081,2201 and 4703 and 40 CFR 60.4400(a)]

73

### AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386



### • The following test methods**sh~1I** 

### be used: NOx - ,EPA Method 7E or 20; CO
- EPA Method 10 or 10B; VOG
- EPA Method 18 or 25; PM10
- EPA Method 5 (front half and back half) or 201 and 202a; ammonia
- BAAQMD ST-1 B; and O2 - EPA Method 3, 3A, or 20. EPA approved alternative test methods as approved by the District may 'also be used to address the source testing requirements of this permit. [District Rules 1081 and 4703 and 40 GFR 60.4400(1 )(i)] Section 60.4405 - Initial GEMS Relative AccuracyTesting: Section 60.4405 states that if you elect to install and certify a NOx-diluent CEMS, then' the initial performance test required under §60.8 may. be performed in the alternative manner describ'ed in paragraphs (a), (b), (c) and· (d). Avenal Power Center has not ,ndicated that they would like to perform th.e initial performance test of theCEMS using the alternative methods described in this section. Therefore, the requirements of this section are not a,pplicable and no further discussion is required. Section 60.4410 - Parameter Monitoring Ranges: Section 60.4410 sets fourth requirements for operators that.elect to monitorcombusti,on parameters or.p·arameters· indicative of proper operation of NOx 

### emission controls. As discussed above, Avenal Power Center is proposing to install a CEMS system to monitor the N'Ox ,emissions from each of these turbines and is not proposing to monitor combustion parameters or ,parameters indicative of proper operation. Therefore, the requirements ofthis section are not applicable and no furtherdiscussion is required. Section 60.4415-**SO~** 

### Performance Testing: Section 60.4415 states that an operator must conduct an initial performance test, as required in §60.8. Subsequent S02 performance tests shall be conducted on an annual basis (no more tha'n 14 calendar months followin,g the previous performance test). There are three methodologies that you may use to conductthe performance tests. (1) It.you choose to periodically determine the sulfur content ofthe fuel combusted in the turbine, a**r~presentative** 

### fuel sample would be collected following ASTM 05287 (incorporated by reference, see §60.17) for natural gas orASTM 04177 (incorporated by reference, see §60.17) for oil. Alternatively, for oil, you may follow the procedures for manual pipeline sampling in section 14 ofASTM 04057 (incorporated by reference, see §60.17). The fuel analyses of this section may be performed either by you, a service contractor retained by you, the fuel' vendor, or any other qualified agency. Analyze the samples forthe total sulfurcontent ofthe fuel using: (i) For liquid fuels, ASTM 0129, or. alternatively 01266, 01552, 02622, 04294, or 05453 (all ofwhich are incorporated by reference, see §60.17); or (ii) For gaseous fuels, ASTM 01072, or alternatively 03246, D4084, 04468, D4810, 06228, 06667, or Gas Processors Association Standard 2377 (all of which are incorporated by reference, see §60.17). 74AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386



### Avenal- Power Center is proposing to periodicaUy determine the sulfur content ofthe fuel combusted in each of these turbines when valid purchase contracts, tariff sheets "or transportation contract is not available. The sulfur content will be determined using the methods specified above. Therefore, t.he proposed turbines will be operating in complian"ce with the requirements of this section. The followin·g condition will ensure continued compliance with the requirements ofthis section:

• Fuel sulfur content shall be monitored using one of the following methods: ASTM Methods 01072, D3246,**D4084,~** 

### 04468, 04810, 06228, 06667 or Gas Processors Association Standard 2377. [40 CFR60.4415(a)(1)(i)] Methodologies (2) .and (3) are applicable to op·erators· that elect to measure the S02 .c.oncentration in the e"xhaust stream. Avenal Power Center is not proposing to measure the S02 in the exhaust stream of the turbines.. Therefore, the requirements of these methodologies are not applicable and no further discussion is required. ·Conclusion: Conditions will be incorporated into these permits in orderto ensure compliance with each applicable section.ofthis subpart. Therefore, compliance with the requirements of Subpart 

### KKKK is expected and n"o furtherdiscussionis required.
Rule4002 NationalEmissions Standards for·HazardousAirPollutants (NESHAP) 

### Pursuant to Section 2.0, "All sources ofhazardous airpollution shall comply with the standards, criteria, andrequirements setforth therein;"

### therefore, the requirements ofthis rule applies to the Avenal PowerCenter. However, there are no applicable requirements for a non-major HAPs source. As discussed above, Avenal Power Center is not a major HAP source; therefore, no actions are necessaryto show compliance with this rule.
Rule4101 Visible Emissions 

### Per Section 5.0, no person shall discharge into the atmosphere emissions of any air contaminant aggregating. more than 

### 3 minutes in any hourwhich is as dark as or darker tha·n Ringelmann 1 (or20% opacity). 

### i.**C~3953-10~O** 

### and C-3953-11-0 (Turbines) The following condition will be listed on the ATe to ensure compliance:

• {15} No air contaminant shall be. discharged into the atmosphere for a period or periods aggregating more than three minutes in anyone hourwhich is as darkas, or darkerthan, Ringelmann 

### 1 or

### 20°A> opacity. [District Rule 4101] 75

### AvenalPowerCenter,**L~C** 

### (OB-AFC-01)

. SJVACPD Determination ofCompliance, C-10B0386



### ii. C-3953-12-0 (Boiler) 

### Based on past experiences with natural gas-fired boilers, no visible emissions are expected to be as dark as or darkerthan Ringelmann 1 (or

### 20°J'c> opacity). The following condition will be placed on the ATC to assure compliance with this rule.

• {15} No air contaminant shall be discharged into the atmosphere for a period or periods aggregating morethan three minutes in anyone hourwhich is as dark as, or darkerthan, Ringelmann 1 or200/0 opacity. [District Rule 4101] iii. C-3953-13-0 (DiesellC engine powering fire water pump) 

### The following condition wHI be listed on the ATC to ensure compliance:

• {15} No air contaminant shall be discharged into the atmosphere for a period or periods aggregating morethan three minutes in anyone hourwhich is as dark as, or darkerthan, Ringelmann 1 or20% opacity. [District Rule 4101] iv. C-3953-14-0 (Natural gas 

### Ie engine electrical generator) 

### The following condition will be listed on theATC to ensure, compliance:

• {15} No air contaminant shallpe' discharged into the atmosphere for a period or periods aggregating morethan three minutes in anyone hourwhich is as dark as, or darkerthan, Ringelmann 1 or200/0 opacity. [District Rule 4101]
Rule

### 4102 Nuisance 

### Section 4.0 prohibits discharge of air contaminants which could cause injury, detrime.nt, nuisance or annoyance to the .public. Public nuisance condition·s are not expected as a result of these operations, provided the equipment is well maintained as required by permit conditions. Therefore, the following condition will be added to the permit to assure compliance with this rule.

• {98} No air contaminant shall be released into the atmosphere which causes 'a public nuisance. [District Rule 41.02] A. California Health & Safety Code 41700 (Health RiskAnalysis) 

### A Health Risk Assessment (HRA) is required for any increase in hourly or annual emissions of hazardous air pollutants (HAPs). HAPs are limited to substances included on the list in CH&SC 44321 and that have an OEHHA approved health risk value. The installation of the permit units for the power plant**result~** 

### in increases in emissions of HAPs. 76AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386

A health risk screening assessment was· performed for the proposed project. The acute and chronic hazard indices were less than 1.0 and the cancer risk was less than one in a million. Under the District's risk management poUcy, Policy APR 1905, TBACT is not required for any proposed emissions unit as shown in the table below:

0.0 0.0 0.02 No 0.0 0.0 0.02 No 0.0 0.0 0.01 No N/A* N/A* 0.01 No 0.2 0.0

. 0.0 No

B. Discussion ofToxics BACT (TBACT) TBACT is triggered ifthe cancer risk exceeds one in one million and if either the chronic or acute hazard index exceeds 1. The results of the health risk assessment show that none ofthe TSACT thresholds are exceeded. TS'ACT is not triggered.
Rule4201 Particulate MatterConcentration Section 3.1 prohibits discharge of dust, fumes, or total particulate. matter into the atmosphere from any single source operation in excess of 0.1 grain per dry standard cubic foot. i. C-3953-10-0 and -11-0 (Turbines) PMCone. (gr/scf) = (pMemission rate) x.C7GGGgr/lb) PM10 emission**~ate** 

# =11.78 Ib/hr

..Assuming 1000 Al of PM is PM10 Exhaust Gas' Flow

# =1,071,653 dscfm PM Conc. (gr/scf)=[(11.78 Ib/hr) 

## * (7,000 gr/lb)] t- [(1,071,653 

### ft3/min) 

## * (60 min/hr)] PM Conc.

# =0.0012 gr/scf

77AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
Calculated emissions are well below the allowable emissions level. It'can be assumed

. that emissions from all theseturbines will notexceed the.allowable 0.1 grlscf. Therefore,

compliance with Rule 4201 is expected.

• {14} Particulate matter emissions shall not exceed 0.1grains/dscf in concentration. [District Rule 4201] 

### ii. C-3953-12-0 (Boiler) Section 3.1 prohibits discharge of dust, fumes, or total particulate matter into the atmosphere.from any single source operation in excess of 0.1 grain per dry standard cubic foot

. 8,578 dscf/MMBtu at 60 OF' 0.005 Ib-PM1 O/MMBtu . F-Factorfor NG:

PM10 Emission Factor: Percentage of PM as PM10 in Exhaust: 

### 100°A> Exhaust Oxygen (02) Concentration: 30/0 Excess Air Correction to F Factor 

# = 20.9 (20.9
- 3) 

### GL=(OoOOS lb-PM x 7,OOOgrain) / 

### (8,S78 ft3 x 

### 1.17J

. MMBtu lb·-PM MMBtu 

# = 1.17

GL= 0.0035 grain/ dscf

### < 0.1 grain/ dscf Therefore, compliance with District Rule 4201 requirements is expected and a permit co.ndition will be listed on the permit as follows:

• {14} Particulate matter e.missions shall not exceed 0.1 grains/dscf in concentration. [District Rule 4201] 

### iii. C-3953-13-0 (DiesellC engine fire pump)

.Particulate matter emissions from the engine will be less than or equal to.the rule limit of 0.1 grain per cubicfoot ofgas at dry standard conditions as shown by the following:

0.059 g-PM10 19-PM lbhp-hr 106Btu 0.35Btuout 15.43grain ---x x x x x--- bhp-hr O.96g-PM10 2,542.5Btu 9,05ldscf 1Btuin g 0.014 grain-PM dscf Since 0.014 grain-PM/dscf is 

### s to 0.1 grain per dscf, comp.liance with Rule 4201 is expected.

78AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386 Therefore, the following condition will be listed on the ATCto ensure compli'ance: '. {14}, Particulate matter emissions' shall not exceed 0.1 grains/dscfin concentration. [District Rule' 4201] , 

### iv. C-3953-14-0 (Natural gas IC engine electrical. generator) Particulate matter emissions from the engine will be less than ,or equal to the rule limit of 0,.1 grain per cubicfoot ofgas at dry standard conditions as shown bythe following:

0.034 g-PM10 19-PM lbhp-hr 106Btu 0.35Btuout 15.43grain -----x x x x x---

bhp-hr O.96g-PM10 2,542.5Btu 9,05ldscf 1Btuin g 0.008 grain-PM dscf Since 0.008 grain-PM/dscf is =:; to 0.1 grain per dscf, complian,ce with Rule 4201 is expected. Therefore, the following conditio.n will be listed on the ATe to ensure compliance:

• {1.4} Particulate matter emissions shall not exceed 0.1 grains/dscf in concentration. [District Rule 4201]
Rule4202 Parliculate MatterEmission Rate Rule 4202 establishes PM emi'ssion limits as a function of process weight rate in tons/hr. Gas and liquid fuels are excluded'from the definition of process weight. Therefore, Rule 4202 does not apply to any of the permit units in this project, and no further discussion is required.
Rule 4301 FuelBurning Equipment Rule 4301 limits, air contaminant emissions from fuel burning equipment as defined in the rule. Section 3.1 defines fuel burning equipment as "any furnace", boiler, apparatus, stack, and all appurtenances thereto, used in the process of burning fuel for the primary purpose of producing heat or power by indirect heattransfer". 

### i. C-3953-10-0 

### and C-3953-11-0 

### (Turbines) The CTG's primarily produce. power mechanically, i.e. the products of combustion pass across the power turbine blades which causes the turbine shaft to rotate. The turbine shaft is coupled. to an electrical generator shaft which is rotated to produce electricity. Because the CTG's primarily produce power by mechanical means, it does not meet the definition of.fuel burning equipment. Therefore, Rule 4301 does Qot applyto the affected equipment and no further discussion is required.

. 

### 79AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386



### ii. C-3953-12-0 (Boiler)



### ATC #C-3953-12-0 (Ib/hr) , Rule Limit (Ib/hr) 0.41 140 0.19 10 0.10 200 The above table indicates compliance with the ,maximum Ib/hr emissions in this rule; therefore, continued compliance is expected. iii. C-3953-13-0 (DiesellC engine fire pump) 

### Rule 4301 does not apply to the affected equipment and no further discussion is required

.. iv. C-3953-14-0 (Natural g'as IC engine electrical generator) 

### Rule 4301 does not apply to the affected equipment and no further discussion is required.
Rule4304 TuningProcedure forBoilers, Steam GeneratorsandProcess**Heater~** 

### 'This rule is onlyapplicable to unit C-3953-12-0. Pursuant to District Rules 4305 and 4306, Section 6.3.1, the boiler is not required to tune since it follows, a Distri9t approved Alternate Monitoring scheme where the applicable emission limits are periodically monitored. Therefore, the unit is not subjectto this rule.
Rule4305 Boilers Steam GeneratorsandProcess Heaters
- Phase

### 2 ' This rule is only applicable to unit C-3953-12-0. The unit is natural gas-fired with a maximum heat input of 37.4 MMBtu/hr. Pursuant to Section 2.0 of District Rule 4305, the unit is subject to District Rule 4305, Boilers, Steam

. .Generators andProcess Heaters
- Phase 2. 

### In addition, the unit is also subject to District- Rule 4306, Boilers, Steam Generators and Process Heaters
- Phase 3. 

### ,Since emissions lim'its of District Rule 4306 and all other requirements are equivalent or more stringent than District Rule 4305 requirements, compliance with District Rule 4306 requirements will**~atisfy** 

### requirements of District Rule 4305. 

### 80

### AvenalPowerCenter, LLC(08-AFC-01) SJVACPO Determination**r~of** Compliance, C-1080386



### Conclusion Therefore, compliance with District Rule 4305 requirements is expected and no further discussion is required.


### Rule 4306 Boilers Steam Generators andProcess Heaters
- Phase 3 This rule is only applicable to unit C-3953-12-0. The unit is natural gas-fired with a maximum heat input of 37.4 MMBtu/hr. Pursuant to Section 2.0 of District Rule 4306, the unit is subjectto District Rule 4306. 

### Section 5.1, NO

### xand CO Emissions Limits Section 5.1.1 requires that except for units subject to Sections 5.2, NOx and carbon monoxide (CO) emissi'ons shall not exceed.the limits specified in the following table. All ppmv emission limits specified in this section are referenced at dry stack gas conditions a'nd 3.00 percent by· volume stack gas oxygen. Emissio.n concentrations shall be corrected to 3.00 percent oxygen in accordance with Section 8.1. With a maximum heat input of 37.4 MMBtu/hr, the applicable emission limit category is listed'in Section 5.1.1, Table 1, Category S, from District Rule 4306.

B. Units with a rated heat input greater than 20.0 MMBtu/hr, exceptfor categories C, D, E, F, G, H, and I units 9 ppmv or 400 ppmv 0.011 Ib/MMBtu 40 ppmv or 0.052 Ib/MMBtu 400 ppmv
Forthe unit:

- the proposed NOxemission factor is 

### 9 ppmvd 

### @**3°~** O2 (0.011 Ib/MMBtu), and

- the proposed CO emission factor is 50 ppmvd 

### @ 3% 

### 02 (0.037 Ib/MMBtu). Therefore, compliance with S'ection 5.1 of District Rule 4306 is expected. A permit condition listing the emissions limits will be listed on permitas shown in the DEL section above.

81"AvenalPowerCenter,'LLC (OB-AFC-01) SJVACPD Determination ofCompliance, C-1080386
Section 5.2, Low Use The unit annua'l heat input will exceed the 9 billion Btu heat input

.per calendar year criteria "limit addressed by this section. Since the unit is not subject to Section 5.2, the requirements ofthis section"do not applyto the unit. Section 5.3, Startup and Shutdown Provisions Section 5.3 states that on and afterthe full compliance schedule specified in Section 7.1, the app'licable emission limits of Sections 5.1, 5.2.2 and 5.2.3 shall not apply during startup or shutdown provided an operator complies with the requirements specified in Sections 5.3.1 through 5.3.4. According to boiler manufacturers, low NOx burners will achieve their rated emissions within. one to two. minutes of initial startup and do not require a special shutdown procedure. Because of the short duration before achie'ving the rated emission factor "following startup, the unit will be subject to the applicable emission limits of Sections 5.1, 5.2.2 and 5.2.3 while in operation. Section 5.4, Monitoring Provisions Section 5.4.2 requires that permit units subject to District Rule 430.6, Section 5.1 emissions limits shall either install and maintain Continuous Emission Monitoring (CEM) equipment for NOx, CO and O2, or install and maintain APCO-approved alternate

.monitoring.

. The facility has proposed to install a CEMS system to satisfy the requirements of this section. The following condition will assure compliance with this section.

• {1832} The'exhaust stack shall be equipped with a continuous emissions monitor (CEM) for NOx, CO, and 02. The CEM shall meet the requirements of 40 CFR parts 60 and 75 and shall be capable of monitoring e·missionsd.uring startups and shutdowns as well as during normal operating conditions. [District Rules 2201 and 

### 1080] Since.the unit is not subject to the requirements listed in Section 5.2.1 or 5.2.2, it is not subjectto Section 5.4.3 requirements

.

.Since the unit is not subject to the requirements of category H (maximum annual heat

input between 9 billion and 30 billion Btu/year)' listed in Section 5.1.1, it is not subject to 'Section 5.4.4 requirements.



### 82

### Avenal**Power~Center,** 

### LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
Section 5.5, Compliance Determination 

### Section 5.5.1 requires that the operator of any unit shall have the option of complying with either the applicable heat input (lb/MMBtu) emission limits or the concentration (ppmv) 'emission limits specified in Section 5.1. The emission limits selected to demonstrate compliance shall b.e specified in the source test proposal pursuant to Rule 1081 (Source Sampling). Therefore, the following condition will be listed on the permit as follows:

• {2976} The source plan 'shall identifywhich basis (ppmv or Ib/MMBtu) will be used to demonstrate compliance. [District Rules 4305 and 4306] Section 5.5.2 requires that all emissions measurements shall be made with the unit operating either'at conditions representative of normal operations or condition.s specified in the Permit to Operate.**~o** 

### determination·ofcompliance shall be established within two

,hours after a continuous period in which fuel flow to the unit is shut offfor 30 minutes or longer, or within 30 minutes after are-ignition asdefiried in Section 3.0. Therefore, the following permit condition will be listed on the permit as follows:

• {2972} All emissions measurements shall be made with the unit operating eitherat co'nditions representative of normal operations or conditions specified in the Permit to Operate. No determination of compliance shall be established within two hours after a continuous period in which fuel flow to the unit is shut off for 30 minutt.?s or longer, orwithin. 30 minutes after a re-ignition as defined in Section 3.0 of District Rule 4306. [District Rules 430,5 and 4306] Section 5.5.4 requires that for emissions monitoring pursuant to Sections 5.4.2, 5.4.2.1, and 6.3.1 using a portable NOx 

### analyzer as part of an 

### A'pea approved Alternate Emissions Monitoring System, emission readings. shall be averaged over a 15 cons,ecutive-minute period by either taking a cumulative 15-consecutive-minute sample reading or bytaking at leastfive (5) readings evenly spaced out overthe 15-consecutiveminute**period~** 

### Since the applicant does not use a portable analyzer to satisfy the monitoring requirements of District Rule 4306 the requirements of Section 5.5.4 do not apply. Section 5.5.5 requires that 'for emissions source testing performed pursuant to Sectio'n 6.3.1 forthe purpose ofdetermining compliance with a'n applicable standard or numerical limitation ofthis rule, the·arithmetic average ofthree (3)**30~consecutive-minute** 

### test runs shall apply. If two (2) of three (3) 

### runs are above an applicable limit the test cannot be used to demonstrate compliance with an applicable .limit. Therefore, the following permit condition will be listed on the permit as follows:

• {2980} For emissions source testing, the arithmetic average of three 30- consecutive-minute test runs shall apply. If two of three runs are above an applicable limit the test cannot be used to demonstrate compliance with an applicable'limit. [District Rules 4305 and 4306] 83A.venalPowerCenter, LLC(08-AFC-01) SJVACPO Determination ofCompliance, C-1080386

Section 6.1, Recordkeeping Section 

### 6.1 requires that the records required by Sections 

### 6.1.1 through 

### 6.1.3 ·shaH be .maintained for five calendar years and shall be made ava·ilable to the APCO upon request. Failure to maintain records or information contained in the records that demonstrate noncompliance with the applicable requirements ofthis rule shall constitute a violation ofthis rule. A permit condition will be listed on the permit.as follows:

• {2983} All records shall be maintained and retained on-site for a minimum of five (5) years, and shall be made available for District inspection upon request. [District Rules 

### 1070, 4305, and 

### 43061 Section 

### 6.1.2 requires that the operator of a unit subject to Section 5.2 shall record the amou.nt of fuel use at' least on a monthly basis. Since the unit is not subject to**th~** requirements listed in Section 5.2, it is not subject to Section 

### 6.1:.2 requirements. Section 

### 6.1.3 requires that the operator of a .unit subject to Section 

### 5.2.1 or 

### 6.3.1 shall maintain records to verify that the required tune-up and the required monitoring of the operational characteristics have been performed. The unit is not subject to Section 

### 6.1.3. Therefore, the requirements ofthis section do not applyto the unit. Section 6.2, Test Methods Section 

### 6.2 identifies the following test methods as. District-approved source testing methods forthe pollutants listed:

NOx ppmv EPA Method7E orARB Method 100 NOx Ib/MMBtu EPA Method 19 CO ppmv EPA Method 10 orARB Method 100

.Stack Gas O2 % EPA Method 3 or3A, orARB Method 100 Stack Gas Velocities ft/min EPA Method 2 Stack Gas Mo'isture Content % EPA Method 4

84AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination 

### ofCompliance, C-1080386
The following permit conditions will be listed on the permit as follows:

• {1 09}Source testing shall be conducted using the methods and procedures approved by the District. The District must be notified at least 3·0 days priorto any compliance source test, and a source test plan must be submitted for approval at least 15 days priorto testing. [District Rule 1081]

• {2977} NO

### x emissions for sourqe test purposes shall be determined using EPA Method 7E or ARB Method 100 on a ppmvbasis, or EPA Method 19 on a heat input basis. [District Rules 4305 and 4306]

• {2978} CO emissions for source test purposes shall be determined using EPA Method 10 orARB Method 1·00. [District Rules 4305 and 4306]

• {2979} Stack gas oxygen (02) shall be determined usi·ng EPA Method 3' or 3Aor ARB Method 100. [District Rules 4305 and 4306] Section 6.3, Compliance Testing Section·6.3.1 requires that this unit be tested to determine compliance with the

.applicable requirements of section 5.1 and 5.2.3 not less than once every 12 months.

Upon demonstrating compliance on two consecutive. compliance source tests, the following source test may be deferred for up to thirty-six months. The following perm.it conditions will be listed on the permit as follows:

• {3467} Source testing to measure NOx and C·O emissions from this unit while fired on natural gas shall be conducted within 60 days of initial start-up. [District Rules '2201, 4305, and 4306]

• {3466} Source**testi~g** to measure NOx and CO emissions from this unit while fired on natural gas shall be conducted at least once every twelve (12) months. After demonstrating compliance on two (2) consecutive annual source tests, the unit shall be tested not less than once every thirty-six (36) months. Ifthe result of the 36-month source test demonstrates that the unit does not meet the applicable emission limits, the source testing frequency shall revert ·to at least once every twelve (12) months. [District Rules 4305 and 4306]
• . {11 

### O} The results of each source test shall be submitted to the District within 60 days thereafter. [District Rule' 1081]

85

### AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination of'Compliance, C-1080386
Section 6.4, Emission Control Plan (ECP) 

### Section 6.4.1 requires that the operatorofany unit shall submitto the APCO for approval an Emissions Control Plan according to 'the compliance schedule in Section 7.0 of District Rule 4306. The proposed modified unit will be in compliance with the emissions limits listed in table 1, Section 5.1 of this rule and wi,th periodic monitoring and source testing requirements. Therefore, this current application forthe new proposed unit satisfies the requirements of the Emission Control Plan, as listed in Section 6.4 of District Rule 4306. No further discussion is required. Section 7.0, Compliance Schedule 

### Section 7.0 indicates that an operator with multiple units at ,a stationary source shall comply with this rule in accordance with the 'schedule specified in Table 2, Section 7.1 of District Rule 4306. ' ' The unit will be in compliance with the emissions limits listed in table 1, Section 5.1 of this rule, and periodic monitoring and source testing as required by District Rule 4306. Therefore, requirements 'ofthe compliance schedule, as listed in Section 7.1 of District' Rule 4306, are satisfied. 'No furtherdiscussion is**required~** Conclusion 

### Conditions will be incorporated into the permit in order to ensure compliance with each section of this rule, see attached draftpermit(s). Therefore, compliance with District Rule 4306 requirements is expected. Rule

### 4351 Boilers Steam GeneratorsandProcess Heaters
- Phase 1 

### This rule is only applicable to unit C-3953-12. This rule applies to boilers, steam generators, and process heaters at NOx 

### Major Sources that are 'not located west of Interstate 5 in Fresno, Kings, or Kern counties. If applicable, the emission limits, monitoring provisions, and testing requirements of this rule are satisfied ,when the unit is operated in compliance With Rule 4306. Therefore, compliance with this rule is expected.



### 86AvenalPowerCenter, LLC·(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
Rule4701 InternalCombustion Engines
- Phase 1 

### This rule is only applicable to units C-3953-13-0 and -14-0. Pursuantto Section 7.5.2.3 of District Rule 4702, as ofJune 1,2006 District Rule 4701 is no longer applicable to diesel-fired emergency standby or emergency IC engines. Therefore, this diesel-fired emergency IC engine will comply with the requirements of District Rule 4702 and no further discussion is required.
Rule 4702 InternalCombustion Engines
- Phase2 

### This rule is only applicable to units C-3953-13-0 and -14-0. The purpose of this rule is to limit the emissions of nitrogen oxides (NO

### x ), carbon monoxide (CO), and volatile' organic compounds (VOC) from internal combustion engines. This rule applies to any internal combustion engine with a rated brake horsepower greaterthan 50 horsepower. Pursuant to Section 4.2, except for the requirements of Sections 5.7 and 6.2.3, the requirements of this rule shall not apply to an internal combustion engine that meets the. following condition: 1) An emergency standby engine as defined in Section 3.0 ofthis rule, and provided that it is operated with a nonresettable elapsed·'operating time meter. In lieu ofa nonresettable time meter,' the owner of an emergency engine may use an alternative device,'method, or technique, in' determining operating time provided that the alternative is approved by the APCO. The owner of the engine shall properly f'Daintain and operate the time meter or alternative device in accordance with the manufacturer's instructions. Section 3.15 defines an "Emergency Standby Engine" as· an internal combustion engine which operates as a temporary replacement for primary. mechanical or electrical power during an unscheduled outage**caus~d** 

### by sudden and reasonably unforeseen natural disasters or sudden and reasonably unforeseen events beyond the control of the operator. An engine shall be considered to be an emergency standby engine if it is used only. for the following purposes: (1) periodic maintenance, periodic readiness testing, or readiness testing during and after'repair work; (2) unscheduled outages, or to supply powerwhile maintenance is performed or repairs are made to the primary power supply; and (3) if it is 'Iimited to operate 100 hours or less per calendar year for non-emergency purposes. An engine shall not be considered to be an emergency standby engine if it is used: 

### (1) to reduce the demand for electrical power when normal electrical power line service has notfailed, or (2) to produce powerforthe ·utility·electrical distribution system, or (3) in conjunction with a .voluntary utility de'mand reduction program or interruptible powercontract. 

### 87

### AvenalPowerCenter, LLC(08-AFC-01) SJVACPO Determination 

### ofCompliance, C-1080386


### Therefore, unit C-3953-14-0, the emergency standby IC engine powering an electrical 9.enerator involved with this project will only have to m.eet the requirements of Sections 5.7 and 6.2.3 ofthis Rule.

. Pursuant to Section 4.3, except forthe requirements of Section 6.2.3, the requirements of this rule shall not apply to. an .internal combustion engine that meets the following conditions: 1) The engine is operated exclusively to preserve or protect property, human life, or public health during a disasterorstate ofemergency, such as afire orflood, and 2) Except for operations associated with Section 4.3.1.1, the engine is limited to operate no more than 100 hours per calendar year as determined by an operational nonresettable elapsed operating time meter, for periodic, maintenance, periodicread.iness ·testing, and readiness testing during and after repair work of the engine, and 3) The engine**i~** 

### operated with a nonresettable elapsed operating time meter. In lieu of installing a nonresettable' time meter, the owner of an engine may use an alternative device, method,or technique, in determining operating time provi'ded that the alternative is approved by the APCO. The owner of the engine' shall properly maintain and operate the time meter or alternative device in accordance with the manufacturer's instru,ctions. Therefore, unit C-3953-13-0, the emergency IC engine powering a firewater pump involved with this project win only have to meet the requirements of Section'6.2.3 ofthis Rule. Sectiqn 5.7 of this Rule requires that the owner of an emergency standby engine shall complywith the**req~irements** 

### specified in Section 5.7.2 through Section 5.7.5 below: 1) Properly operate and maintain each engine as recommended by the engine manufactureroremission control system supplier. 2) Monitor the operational characteristics of ea.ch engine as recommended by the engine I}lanufactureroremission control system supplier. 3) Install and operate a nonresettable elapsed operating time meter. In lieu of installing a nonresettable time meter, the owner of an engine may use an alternative device, method, or technique, in determining operating time provided that the alternative is approved by.the APCO and is allowed by Permit-to-Operate or Stationary Equipment Registration condition. The owner· of the engine shall

.properly maintain and operate the time meter or alternative device in accordance with the manufacturer's instructions. Therefore" the following conditions will be listed on ATe C-3'953-14-0 

### to ensure compliance:

. 

### 88Avenal

### PowerCenter, 

### LLC (O.8-AFC-01) SJVACPO Determination ofCompliance, C-1080386
C-3953-14-0.(Natural Gas Ie**engin~ electric~1**  generator)

• .This engine shall be operated and maintained in proper operating condition as recommended by the engine manufacturer. or emissions control system supplier. [District Rule 4702]

• During periods of operation for maintenance, testing, and required regulatory purposes,**~he** permittee shall monitor the operational characteristics ofthe engine as recommended by the manufacturer or emission control system supplier (for example: check engine fluid levels, battery, cables and connections; change engine oil and filters; replace engine coolant; and/or other operational characteristics' as recommended bythe manufacturer orsupplier). [District Rule 4702]

• This engine shall be equipped with an**op~rational** non-resettable elapsed time meter or otherAPCO approved alternative. [District Rule 4702 and' 17 CCR 93115]

• An emergency situation is an unscheduled electri"cal power outage caused by sudden and reasonably unforeseen natural disasters or sudden and reasonably unforeseen events beyond the control ofthe permittee. [District Rule 4702]

• This engine shall not be used to produce power for the electrical distribution system, as part of**avol~ntary** utility demand reduction program, or for an interruptible power contract. [District Rule 4702]

• This engine shall be operated only for testing and maintenance of the engine, required regulatory purposes, and during emergency situations. Operation of the engine for maintenance, testing, and required regulatory purposes shall not exceed 50 hours percalendaryear. [District Rule 4702] Section 6.2.3 requires that an owner claiming an exemption under Section 4.2 or 'Section 4.3 shall maintain annual operating records. This information ·shall be retained for at least five·years, shall be read'ily available, and submitted to the APCO upon request and at the end of each calendar year in a manner and form approved by the 

### APCO. Therefore, the following conditions will be listed on ATCs C-3953-13-0**~nd** -14-0 to ensure compliance:



### 89AvenalPO,werCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
C-3953-13-0 (Diesel 

### Ie engine fire pump)

• {3816} This en,gine shall be operated only for testing and maintenance ofthe engine, reqUired regulatory purposes, and during emergency situations. For testing purposes, th,e engine shall only be operated the number of hours necessary to comply with the testing requirements of the National Fire Protection Association (NFPA) 25 - UStandard for the Inspection, Testing, and Maintenance of Water-,Based Fire Protection Systems", 1998 edition. Total hours of operation for all maintenance, testing, and required regu'latory purposes shall not exceed '5'0 hours per calendar year. [District Rule 4702 and 17 CCR 93115]

• {3489} The permittee shall maihtain monthly records of emergency and nonemergency operation. Records shall include the number of hours of emergency operation, the date 'and number of hours of all testing and maintenance operations, and the purpose of the operation (for example: load testing, weekly testing, rolling blackout, general area poweroutage, etc.). For units with automated testing systems, the operator may, as an alternative to keeping records of actual operation for testing purposes, maintain a readily accessible written record of the automated testing schedule. [District Rule 4702 and 17 CCR 93115]

• {3475} All records shall be maintained and retained**on~site** for a minimum of five (5) years, and shall be made available for District inspection upon request.**[Distri~t Rul~**  470,2 and 17 CCR 93115] In addition, the follow'ing condition will be listed on the 

### ATe to ensure compliance:

• {3404} This engine shall be equipped with an operational**non~resettableelapsed** time meterorotherAPCO approved alternative. [District Rule 4702]

• {3807} An emergency situation is an unscheduled electrical power outage caused by sudden and reasonably unforeseen natural 'disasters or sudden and reasonably unforeseen events beyond the control ofthe permittee. [District Rule 4702]

• {3808} This engine shall not be used to produge power for the electricaJ distribution system, as part of a voluntary utility demand reduction program, orfor an interruptible power contract. '[District Rule 4702] ,



### 90

### AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance} C-1080386
C-3953-14-0 (Natural Gas 

### Ie engine electrical generator)

• The permittee shall maintain monthly records of emergency and non-emergency operation. Records shall include the number of hours of emergency operation, the date and number of hours of all testing and maintenance operations, the purpose of the operation (for example: load testing, weekly testing, rolling blackout, general area power outage, etc.) and records of operational characteristics monitoring. For units with automated testing systems, the operator may, as an alternative to keeping records of actual operation for testing purposes, maintain a readily accessible written record ofthe automated testing schedule. [District Rule 4702]

• All records shall be maintai.ned and retained on-site for a minimum of five (5) years, and shall be made available for District inspection upon request. [District Rule 4702]


### Rule4703 StationaryGas Turbines This rule is only applicable to units C-3953-10-0 and -11-0

.

.Rule 4703 is applicable to stationary gas turbines with a rating greater than 0.3 megawatts. The facility proposes to install two 180 MW gas turbines.. Therefore the requirements ofthis rule applyto the proposed·turbines. Section 5.1 '- NOx Emission Requirements: Section 5.1.1 (Tier I) of this rule limits the "NO

### x emissions from stationary gas turbine systems greater than 10 MW, and equipped with Selective Catalytic Reduction (SCR). Sinc.e the proposed turbines will meet the more stringent Tier 2 emission equirements in Section 5.1.2, compliance with this section is assured. Section 5.1.2 (Tier 2) of this rule limits the 

### NOx emissions from combined cycle, stationary gas turbine systems rated at greater than 10 MW to 5 ppmv @ 15% O2 (Standard option) and 3 ppmv 

### @ 15°J'c> O2 (Enhanced Option). Section 7.2.1 (Table 7-1) sets a compliance date ofApril 30, 2004 for the Standard Option anq Section 7.2.4 sets a compliance date of April 30, 2008 for the Enhanced Option. As discussed above, the proposed turbines will be limited to 2.0 ppmv 

### @ 15% O2 (based on a 1-h.our average), therefore compliance with this section is expected. The following conditions will ensure continued compliance with the requirements ofthis section:
• . E'mission rates from this unit (with duct burner firing), except during startup and shutdown periods, shall not exceed any of the following limits: NOx (as N02)
- 17.201b/hr and 2.0 ppmvd 

### @ 15% 02; VOC (as methane)
- 5.89 Ib/hr and 2.0 ppmvd 

### @ 15°1'<> 02; CO
- 10.60 Ib/hr and 2.0 ppmvd 

### @ 15°1'<> 02; PM10**~11.78** Ib/hr; or SOx (as 802)
- 6.65 Ib/hr. NOx (as N02) emission limits are one hour rolling averages. All other emission limits are three hour rolling averages. [District Rules 2201,4001, and 4703] 91AvenalPowerCenter,LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386

• Emission rates from this unit (without duct burnerfiring), except during startup and shutdown periods, shall not exceed any of the following limits: NOx (as .N02)
- .13.55 Ib/hr and '2.0 ppmvd @ 15% 02; 

## voe (as methane)
- 3.34 Ib/hr and 1.4

ppmvd @ 150 

### M02; ·CO
- 8.35 Ib/hr and 2.0 ppmvd @ 150/0 02; PM10-**8~91** Ib/hr; or SOx (as S02)
- 5.23 Ib/hr. NOx(as N02) emission limits are one hour rolling averages. All other emission limits are three hour rolling averages. [District Rules 2201, 4001, and 4703] Section 5·.2 - 

### CO Emission Requirements:

, PerTable 5-3 ofsectiqn 5.2, the 

### CO emissions concentration from the proposed turbines (General Electric Frame 7) must be less than 25 ppmvd @ 150 

### MO2. Rule 4703 does not include a specific averaging period requirement for demonstrating compliance with the 

## eo emission**limit~** However, District practice is to have an applicant demonstrate compliance· with the 

### CO emissions on a turbine with three hour averaging periods. Therefore, com·pliance with the 

### CO emission limit shall be demonstrate.d by an average over a three hour period. Avenal Power Center is proposing a 

### CO emission concentration limit of2 ppmvd@ 15% O2 and will demonstrate compliance using three hour averaging periods. Therefore, the proposed turbines will be operating the turbine in compliance with the 

### CO emission requirements of this rule. The DEL conditions shown in the Section 5.1.2 compliance section will ensure continued compliance with the requirements ofthis section. S"ection 5.3 - Startup and Shutdown Requirements: This section states that t.he emission limit requirements of Sections 5.1.1, 5.1.2 or 5.2 shall not apply during startup, shutdown, or a reduced load period provided an operator complies with the requirements specified below:

- The duration of each startup or each shutdown shall not exceed two hours, and

. the duration of each reduced load period shall not exceed one hour, except as

provided below. The emission control system shall be in operation and emissions shall be minimized insofar as technologically feasible during startup, shutdown, or a reduced load period.

- An operator may submit an application to allow more than two hours for each startup or eaQh shutdown or more than one hour for each reduced load period provided the operator**m~ets** all ofthe conditions specified in the" rule.

" 92AvenalPowerCenter, LLC(OB-AFC-01) 

### SJVACPO Determination ofCompliance, C-1080386
Avenal Power Center is proposing to incorporate startup and shutdown provisions into the**operatingrequi~ements** for each of·the proposed turbines. They have proposed that the duration of each startup'or shutdown event will last no more than six hours per day. Since this proposed duration is longerthan what is allowed in Section 5.3.1.1, the facility must meet the requirements of Section 5.3.3.2. Section 5.3.3.2 states that at a minimum, ajustification forthe incre.ased duration shall include the following: A.clear identification ofthe control technologies orstrategies to be utilized; and The facility has identified the following control technologies: 

### •. Dry low-NOx combustors in the turbines;
• Oxidation catalyst in the**HRSG~;** • SCR in theHRSGs;
• Good combustion practices;
• Upon startup, the ammonia injection upstream ofthe SCR catalyst will be started as soon as the catalyst and ammonra injection system warm to their minimum operating temperatures specified bythe SC.R vendor. A description of 'what physical conditions prevail during the period that prevent the controls from being effective; and The combined-cycle equipment startup duration depends on how fast the thick steel walls of the common steam turbine-'can be warmed to operating temperature without generating stress cracks. Steam developed in the HRSG from the heated turbine exhaust is admitted into the steam turbine at a controlled temperature to heat it as ra'pidly as possible without causing stress cracking. The steam**temp~rature** is controlled by limiting the load on the gas turbine. The allowable rate of temperature increase at the steam turbine is the limiting factor determining how quickly the gas turbines can achieve higher loads. This, in turn, limits how quickly the gas turbine combustors can achieve the lowest emitting operating 'mode, and this latter step is necessaryforthe units to be able to complywith the limits of Rule 4703. A reasonably precise estimate as to when the physical conditions will have reached a state that allows forthe effective control ofemissions; and Startup information provided by the turbine and HRSG vendors indicates that for a cold startup, a minimum offour hours is required forthe unit to come into compliance with the limits of Rule 4703. Depending on the temperature of the steam turbine at the time the start is initiated, shorter durations may be possible. A detailed list of activities to be performed during the period and a reasonable explanation forthe length oftime needed to complete'each activity; and The facility has provided the District with a 'detailedlist of activities to be performed during the period and a reasonable explanation for the length .of time needed to complete each activity. 93AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination 

### ofCompliance, C-1080386

A description of the material process flow rates and system operating parameters, etc., the operator .plans to 'evaluate during the :process optimization; and an'explanation of how the activities and process flow affect the ·operation of the emissions control eguipm.ent; and The startup duration depends on the allowable ramp rate ofthe steam temperature to the steam turbine, which depends on the acceptable rate of increase of the metal temperature of the HRH and HP bowls. at the steam turbine inlets. The maximum steam temperature is set by applying an allowable differential above the metal temperature. The differential is determined by the steam turbine supplier, and is imposed by the supplier's control system to avoid damage to the steam turbine from thermal stress. The control system limits gas turbine load to control the steam temperature. Manual override ofthe gas turb.ine load limit by the operator reduces the life expectancy ofthe steam turbine. In addition, the time prior.to initiation of ammonia flow to the SCR system depends on the temperature ofthe SCR catalyst. The catalystbed is warmed by the exhaust flow from the gas turbine. The total mass of metal and water in the HRSG tubes, piping, and drums removes heat from the gas turbine exhaust as it warms. This extends the time required to heat the SCR catalyst to the minimum**t~mperature** .at which ammonia may be injected upstream of the catalyst bed to begin reducingNOx to N2. The steam turbine and SCR catalyst temperatures are all monitored by the plant control system, and the turbine ramp rate and SCR initiation sequence are governed bythe equipment/system manufacturer's recommended procedures. The basis forthe requested additional duration. The startup curve in Attachment I and the description of activities above demonstrate that the minimum time required for a cold startup of the plant as currently configured is approximately'4 hours. This startup time is contingent**upo~** all of the activities being performed in time to support subsequent activities

..Any delay in preparation of the supporting systems will result in a corresponding delay in startup and/or loading of the gas turbines. To be confident that the startup time allowed is adequate and will not be exceeded, one hour is added to the above startup time to account for possible delays. Since' the facility has demonstrated compliance and provided all the information asked for in Section 5.3.3.2, the pr9Posed increase in startup and shutdown emissions is compliant with District Rule 4703. The following conditions will ensure continued compliance with the requirements ofthis section:

• During start-up and shutdown, eTG exhaust emission rates shall not exceed any of the following limits: NO

### x (as N02 ) - 160 Ib/hr; CO
- 1,000 .Ib/hr; 

## vac (as methane)
- 16 Ib/hr; PM 10 - 11.78 Ib/hr; 

## sax (as S02)
- 6.652 Ib/hr; or NH3 - 32.13 Ib/hr. [District Rules 2201 and 4703] 94AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination 

### ofCompliance, C-1080386



### • Startup shall be defined as.the period oftime during which a unit is broughtfrom a shutdown status to its operating temperature and pressure, including the time required by the unit's emission control system to reach full·operations. Shutdown shall be defined as the period of time during which a unit is taken from an operational to a non-operational status by allowing it to cool down from its operating**temperatur~** 

### to ambient temperature as the fuel supply to the unit is completelyturned off. [District Rules 2201 and 4703]

• The duration of each startup or shutdown shall not exceed six hours. Startup and shutdown emissions shall be counted toward' all applicable emission limits. [District Rules 2201 and 4703]

• The emission control systems shall be in operation and emissions shall be minimized insofar as technologicallyfeasible during startup and shutdown. [District Rule 4703]

. Section 6.2 - Monitoring an.d Recordkeeping: Section 6.2.1 requires the owner to operate and maintain continuous emissions monitoring equipment for NOx and oxygen, or install and maintain APCO-approved alternate monitoring. As discussed earlier in this evaluation, the applicant operates, a

,Continuous Emissions Monitoring System (CEMS) that monitors the NOx and oxygen

content of the turbine exhaust. Therefore, the requirements of this' section have been satisfied. The following condition will ensure continued compliance with the requirements ofthis section:

• The owner or operator shall install, certify, maintain, operate and quality-assure a Continuous Emission Monitoring System (CEMS) which continuously measures and records the exhaust g.as, NOx, CO and O2 

### concentrations. Continuous emissions monitor(s) shall be capable of monitoring emissions during normal operating conditionsJ. and during startups and shutdowns, pro'vided the CEMS pass the relative accuracy requirement for startups and shutdowns specified herein. If relative accuracy of CEMS 'cannot be demonstrated during startup conditions, CEMS'results during startup and shutdown events shall be replaced with startup emission rates obta,ined from source testing to determine compliance with emission limits contained in this document. [District Rules 1080 and 4703 and. 40 CFR 60.4335(b)(1)] Section 6.2.2 specifies monitoring requirements for turb·ines without exhaust-gas NOx control device.s. Each of the proposed turbines will be equipped with an SCR system that· is designed to control NOx emissions. Therefore, the requirements of this section are not·applicable and no further discussion is required.



### 95

### . AvenalPowerCenter,**LLC(08~AFC-01)** SJVACPO Determination ofCompliance,C-1080386


### Section 6.2.3 requires that for units 10 MW and greater that operated an average of more than 4,000 hours per year over the last three years before August 18, 1994, the owner or operator shall monitorthe exhaust gas NOx emissions. The proposed turbines have not been**installed~** 

### Therefore, they were not in operation priorto August 18, 1994 and the requirements of this section are not applicable. No further discussionis required. Section 6.2.4 requires the facility to maintain all records for.a period of five years from the date of data entry and shall make such records available to the APCO upon request. Avenal PowerCeriter will be required to maintain all records for at least five years and make them available to the APCO upon request. Therefore, the proposed turbines will be operating in compliance with the five year recordkeeping requirements of this rule. The following condition will ensure continued compliance w·ith the requirements of this section:

• The owner or operator of a stationary gas turbine system shaH maintain all records 'of requiredmon'itoring data and support information for inspection at. a·nytime for a period offive years. [District Rules 2201 and 4703] Section 6.2.5 requires that the owner or operator shall submit to the APCO, before

.issuance of the· Permit to Operate, information ·correlatin·g the control system operating to the associated measure NOx output. This information may be used by the APCO to determine compliance when

.there is no continuous emission monitoring system for NOx available or when the continuous emis'sions monitoring system is not operating properly. Avenal**~ower** 

### Centerwill be**requir~d,** 

### by permit condition, to submit information correlating the NOx control system operating parameters to the associated measured NOx output. Therefore, the proposed turbines will be operating incompliance with the control system operating parameter requirements of this rule. The following condition will ensure continued compliance with the requ·irements ofthis section:

• The permittee shall submit to. the District information correlating the NOx control system operating parameters to the associated measured

.NOx 

### output. The information must be sufficient to allow the District to determine compliance with the NOx emission limits of this permit during times that the CEMS is not functioning properly. [District Rule 4703] Section 6.2.6 requires the facility to maintain a stationary gas turbine system operating log that includes, 00·

### a daily basis, the actual local startup and stop time, length and reason for reduced load periods, total**hours~** 

### of operation, and the type and quantity 'of fuel used. Avenal Power Center\will be required to maintain records of each item listed above. Therefore', the proposed turbines will be operating in compliance with the recordkeeping require.ments of this rule. The following conditions will ensure continued' compliance with the requirements ofthis section:



### 96

### AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination.ofCompliance, C-1080386
.' The permittee shall maintain the following**r~cords:** 

### date and time, duration, and type of any startup, shutdown, or malfunction; performance testing,evaluations, calibrations, checks, adjustments, any period' during which a continuous monitoring ,system or monitoring device was inoperative, and maintenance of any continuous emission monitor. [District Rules 2201 and 4703]

• The permittee shall maintain the following records: hours of operation" fuel consumption (scf/hr and scf/rolling twelve month period), continuous emission monitor measurements, calculated ammonia slip, and, calculated NOx mass emission rates (Ib/hr and Ib/tweIve month rolling period). [District Rules 2201 and 4703] Section 6.2.7 establishes recordkeeping requirements for units thatare exempt pursuantto the requirements' of Section 4.2. Each of the proposed turbines is subject to the requirements of this rule. Therefore, the requirements of this section are not applicable and no furtherdiscussion is required. Section 6.2.8 requires owners or operators performing startups or shutdowns to keep records of the duration of each startup and shutdown. As 'discussed in the Section 6.2.6 discussion above forthis rule, Avenal PowerCenterwill be required, by permit condition, to maintain records ofthe date, time and duration or each startup**~nd ~hutdown.**  

### Therefore, the proposed turbines will be operating in compliance with the recordkeeping requirements ofthis rule. Sections 6.3 and 6.4 - Compliance Testing: Section 6.3.1 states thatthe owneroroperatorofanystationarygas turbine system subject to the provisions of Section 5.0 of this rule shall provide source test**inform~tion** 

### annually regarding the exhaust gas NO

### xand CO concentrations. The turbines operated byAvenal Power Center are .subject to the provisions of Section 5.0 of this rule. Therefore, each turbine is required to test annually to demonstrate compliance with the exhaust gas NOx and CO concentrations. The following condition will ensure continued compliance with the requirements ofthis section:

• Source testing to determine compliance with the NOx, CO and 

## vac ,emission rates (Ib/hr and ppmvd 

### @ 15% O2), 

### NH3 emission rate (ppmvd @ 15% O2) 

### and PM 10 

### emission rate (Ib/hr) shall be conducted at least once every 12 months. [District J:{ules 1081, 2201 and 4703 and 40 CFR 60.4400(a)] ,Section 6.3.2 specifies source testing requirements for units operating less than 877 hours peryear. As discussed above, the proposed turbines will be allowed to operate in excess of 877 hours per year. Therefore, the requirements of this section are not applicable and nofurtherdiscussion is required.



### 97AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
Section 6.3.3 states that units with intermittently operated auxiliary burners shall demonstrate compliance with the auxiliary burner both on and off. The'following condition will ensure continued compliance with the requirements ofthis section:

.• Compliance with the NOx and CO emission limits'shall be demonstrated with the auxiliary burner both· on and off. [District Rule 4703]

, Section 6.4 states that the facility must demonstrate compliance annually with the NO

### x

and CO emission limits using the following test methods, unless otherwise approved by the APeO and EPA:

- Oxides of nitrogen emissions for compliance tests shall be determined by using EPA Method 7E or EPA Method 20.

- Carbon monoxide emissions for compliance tests shall be determined' by using EPATest Methods 10 or 10B.

- Oxygen content of the exhaust gas shall be determined by using EPA Methods 3, 3A, or20. HHV and LHV of gaseous fuels shall be determined by using ASTM 03588-91, ASTM 1826-88, orASTM 1945-81. The following condition will ensure continued compliance with the test method requirements ofthis section:

• The following test methods shall be used: NO

### x- EPA Method 7E or 20; CO
- EPA Method 10 or 10B; VaG
- EPA Method 18 or 25; PM10
- EPA Method 5 (front half and back half) or 201 and 202.a; 'ammonia
- BAAQMO 8T-18; and O2 EPA Method 3, 3A, or 20. EPA approved alternative test methods as approved by the District may also be used to address the source testing requirements of this permit. [District Rules 1081 and 4703 and 40 CFR 60.4400(1 )(i)] Conclusion: Conditions will be incorporated into these permits in orderto ensure compliance with each applicable section of this rule. The'refore, compliance with the requirements of Rule 4703 is expected and no furtherdiscussion is**requir~d.**

98AvenalPowerCenter, LLC(OB-AFC-01) SJVACPD Determination ofCompliance, C-1080386
Rule4801 SulfurCompounds

. Per Section 3.1, a person shall not discharge into the atmosphere sulfur compounds,

which would exist as a liquid or gas at standard conditions, exceeding in concentration at the point of discharge: 0'.2 OJ'<> by volume calculated as S02 on a dry basis averaged over 15 consecutive minutes: 

### i. C-3953-10-0 and -11-0 (Turbines) ·The sulfurofthe natural gas fuel is 1.0 gr/100 dscf. The ratio of the volume of the SOx exhaust to the entire exhaust for one MMBtu of fuel combusted is: Volume of SOx: V=_h_·R_._T 

### P Where:

• i1 

# =numberof moles of SOx prod'uced per MMBtu offuel.

. • Weight of SOx as.S02 is 64 Ib/(Ib-mol) • n = 0.00282 lb x 1 (lb

- mol) = 0.000045 (lb

- mol) MMBtu 64lb • R= 0.7302ft3 ·atm (lb

- mol)OR • T

# =500 oR • P

# =1 atm Thus, volume of SOx per MMBtuis: 

## v = 

### _n_·R_·T_ P 0.000045 (lb

- mol)
. 0.7302 ft3 ·atm . 500 OR V 

### = (lb

- mol) 0R 1 atm 

# v = 0.016 ft3 Since the total volume of exhaust per MMBtu is 8,578. scf, the ratio of SOx volume to exhaustvolume is 0.016
. 

# =-- = 0.0000019 = 1.9 ppmv = 0.00019% by volume 8,578
. g.g

### AvenalPowerCenter, LLC(08-AFC-01) SJVACPO Determination ofCompliance, C-1080386



### 1.9 ppmv ::; 

### 2000 ppmv, therefore the turbines, the boiler, and the gas engine are expected. to comply with Rule 4801. ii. C-3953-12-0 (Boiler) Using the ideal.gas equation and the emission factors presented in Section VII, the sulfur compound emissions are calculated as follows: Volume S02 = n RT p With:

N = moles S02 T (Standard Temperature)

# = 60°F

# = 5200 R P (Standard Pressure) 

### = 14.7 psi

. 10.73ps'i

.ft3 R (Universal Gas Constant) 

### = .. -

. Ib·mol·oR 0.002821b

- SOxx MMBtu x lIb·molx 10.73psi·ft3 x 5200R x 1,000,000·parts 

### =1.97 parts 

### MMBtu 8,578

### dscf 64lb lb·mol·

### oR 14.7

### psi million million parts . SulfurConcentration

## =1.97 < 

### 2,000 ppmv (or 

### 0.2°A» million Therefore, compliance with District Rule 4801 requirements is expected. iii. C-3953-13-0 (DiesellC engine powering a fire water pump) Using the ·ideal gas equation, the sulfur compound emissions are calculated as follows: Volume S02= (n x R x T) + P n = moiesS02 T (standard temperature)

# =60°F or

### 520**~R** R ( . Itt) 10.73psi·ft3

. unlversa gas cons an = ---- Ib·mol·OR

O.OOOOI5Ib

- S 7.llb 64lb

- S02 1MMBtu 1gal
. lb

- mol 10.73 psi

- ft3 5200R x -. x x' x x x x -.-. x 1,000,000 = '1.0 ppmv lb

- fuel gal 32lb - S 9,051scf 0.137 MMBtu 64lb

- S02
. lb

- mol- OR 14.7 pSI



### 100AvenalPowerCenter,LLC(08-AFC-01) SJVACPO Determination ofCompliance, C-1080386
Since 1.0 ppmv is 2,000 ppmv, this engine is expected to comply with Rule 4801. Therefore, the follqwing condition (previously proposed. in this engineering evaluation) will be listed on the ATC to ensure compliance:

• {3395} Only**CAR~** certified diesel fuel containing not more than**O~0015%** sulfur by weight is to be used. [District Rules 2201 and 4801 and 17 CCR 93115] iv. C-3953-14-0 (Natural gas IC engine powering an electrical generator) Volume 502

# =(nx R x T) + P n

# =moles 502 T (standard temperat.ure)

# =60 

### OF or 520 oR

. 10.73p·si.ft3 R (unlversal·gas constant) 

### =. - Ib·mol·OR

2.85 lh

- S Isef

- gas IMMBtu lib
- mol 10.73psi

- ft3 5200R 1**--~-x** x x x - x---xl,OOO,OOO= .97 ppmv MMsef

- gas 1,000Btu 8,578sef 64lh

- S lb

- mol

- OR 14.7psi Since 1.97 ppmv is 2,000 ppmv, this engine is expected to comply' with Rule 4801. Therefore, the following condition (previously proposed in this engineering evaluation) will be listed on the ATC to ensure compliance:

• {3491} This IC engine shall be fired on Public Utility Commission (PUC) regulated natural gas only. [DistriGt Rules 2201 and 4801]
DistrictRule 8011 GeneralRequirements DistrictRule .8021 Construction, Demolition, Excavation, ExtractionAndOther EarthmovingActivities ·DistrictRule 8031 BulkMaterials DistrictRule 8041 CarryoutAndTrackout DistrictRule 8051 OpenAreas DistrictRule 806.1 PavedAnd

.UnpavedRoads DistrictRule 8071 Unpaved Vehicle/Equipment TrafficAreas DistrictRule 8081 AgriculturalSources The construction of this new facility will involve excavation, extraction, construction, demolition, outdoorstorage piles, paved and unpaved roads

.

. The regulations from the 8000 Series District Rules contain requirements for the control of fugitive dust. These requirements apply to' various sources, inc'luding construction, demolition, excavation, extraction, mining activities, outdoor storage piles, paved and unpaved roads. Compliance with these regulations will be**re~uired** by the following permit conditions, which will be listed on each permit as follows: 101AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386

• Disturbances of soil related to any construction, demolition, excavation, extraction, or other earthmoving activities shaH comply with the requirements for fugitive dust co.ntrol in District Rule 8021 unless specifically. exempted under Section 4.0 of Rule 8021 or Rule 8011. [District Rules 8011 and 8021]

• An owner/operator shall submit a Dust Control Plan to the 

### APeO priorto the start of any construction activity on any site that will include 10 acres or more of disturbed surface area for residential developments, or 5 acres or more of disturbed surface ·area for non-residential development, or wiU include moving, depositing, or relocating more than 2,500 cubic yards per day of bulk materials on at leastthree days. [District Rules 8011 and 8021]

• An owner/operator shall prevent or cleanup any carryoutor trackout in accordance with the requirements of District Rule 8041 Section 5.0, unless specifically exempted under Section 4.0 of Rule 8041 (8/19/04) or Rule 8011 (8/19/04). [District Rules 8011 and 8021]

• Whenever open areas are disturbed, orvehicles are used in open areas, the facility shall comply with the requirements of Section 5.0 of District Rule 8051, unless specifically exempted under Section 4.0 of Rule 8051 or Rule 8.011. [District Rules 8011 and 8051]

. .

• Any paved road or unpaved road shall comply with the requirements of District Rule 8061 unless specifically exempted under Section 4.0 of. Rule 8061 or Rule 8011. [District Rules 8011 and 8061]

. "Water, gravel, roadmix,or chemi,cal/organic dust stabilizers/suppressants,. vegetative materials, or other District-approved control measure shall be applied to unpaved vehicle travel areas as required to limit Visible Dust Emissions to 

### 200/0 opacity and comply with the requirements fqr a stabilized unpaved road as defined in Section 3.59 of District Rule 8011. [District Rule 8011 and 8071]

• Where dusting materials are allowed to accumulate on paved surfaces, the accumulation shall be removed daily or water and/or chemical/organic dust stabilizers/suppressants shall be applied to the paved surface as required to maintain continuous compliance with the requirements'for a stabilized unpaved road as defined in 'Section 3.59 of District ·Rule 8011 and limit Visible Dust Emissions (VDE) to 20% opacity. [District Rule 8011 and 8071]

1·02AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386

• On each day that 50 or more Vehicle Daily Trips or 25 or more Vehicle Daily Trips with 3 axles or more will occur on an unpaved vehicle/equipment traffic area, permittee shall apply

.water, gravel, roadmix, or chemical/organic dust stabilizers/suppressants, vegetative materials, or other District-approved control measure as required to limitVisible Dust Emissions to 200/0 opacity and complywith the requirements fora stabilized unpaved road as defined in Secti.on 3.59 of District Rule 8011.**[Distric~** Rule 8011 and 8071]

• Whenever any portion of the site becomes inactive, Permittee shall restrict access and periodically stabilize any disturbed surface to comply with the conditions for a stabilized surface as defined in Section 3.58 of District Rule 8011. [District Rules 8011 and 8071]

• Records and other supporting documentation shall be maintained as required to demonstrate comp.liance with ,the requirements of the rules under Regulation VIII only for those days that a control measure was implemented. Such records shall include the type of control measure(s) used, the location, and extent of coverage, and the date, amount, and frequency of application of dust suppressant, manufacturer's dust suppressant product information sheet that identifiesthe name of the dust suppressant and application instructions. Records shall be kept for,one yearfollowing project completion'that results in thetermination ofall dust generating activities. [District Rules 8011, 8031, and 8071]
California Environmental Quality Act (CEQA) The District determined that the California Energy Commission (CEC) is the public agency having principal responsibility for approving the project, therefore establishing the CEC as the Lead Agency (CEQA Guidelines §15051(b). The District is a Respon'sible Agency for-the project because of its discretionary approval power over.the project via its Permits Rule (Rule 2010) and New Source Review Rule (Rule 2201), (CEQA Guidelines §15381). The District's en,gineering evaluation of the project (this document) demonstrates that 'compliance with District rules and permit conditions would reduce Stationary Source emissions from the project to levels below the District's significance thresholds for criteria pollutants. The District has determined that no additional findings are required (CEQA Guidelines §15096(h»).
California Health &'Safety Code, Section 42301.6 (School Notice) As discussed in Section III ofthis evaluation, this site is not located within 1,000 feet afa school. Therefore, pursuant to California 'Health and Safety Code 42301.6, aschoal notice is not required.

103AvenalPowerCenter, LLC(OB-AFC-01)

. SJVACPD Determination ofCompliance, C-1080386
California Health 

### &Safety'Code, Section 44300 (AirToxic "Hot Spots") Section 44300 of the California Health and**SafetyCod~** requires submittal of an air toxics "Hot' Spot" information and assessment report for sources with criteria pollutant emissions greater than 10 tons per year. H'owever, Section 44344.5 (b) states th'at a new facility shall not be required to submit such a report if all of the following conditions are met: 1. The facility is, subject to a district permit program established pursuant to Section ·42300. 2. The district conducts an assessment ofthe potential emissions ortheir associated risks, and findsthat the emissions will not result in a significant risk. 3. The district issues a permit authorizing construction or operation of the new facility. A health risk screening assessment was performed for the proposed project. The acute and chronic hazard indices are les.s than 1.0 and the cancer risk is less than ten (10) in a million, which are the thresholds of significance for toxic air contaminants. This project qualifies for exemption perthe above exemption criteria. '
Title' 13 California Code of Regulations (CCR), Section 2423 -, Exh'aust Emission Standards and Test Procedures, Off-Road Compression-Ignition Eng,ines and Equipment (Required by Title 17 CCR, Section 93115 for New**E~ergency** Diesel 

### Ie Engines) The requirements ofthis section are only applicable to C-3953-13-0. Particulate Matter and

## vac + NOx, and CO Exhaust Emissions'Standards: This regulation stipulates that off-road**compression~ignition ~ngines**  shall ,not exceed the following applicable emissions standards. Title 13 CCR, Section.2423 lists a'diesel particulate emission standard of 0.15 g/bhp-hr (with 1.341 bhp/kVV, equivalent to 0.20 g/kW-hr) for 2003 - 2005 model year engines with maximum power ratings of 174.3 - 301.6 bhp (equivalent to 130 - 225 kW). The PM standards given in Title 13 CCR, Section 2423 are less stringentthan the PM standards given in Title 17 CCR, Section 93115 (ATCM), thus the ATCM standards are the required standards and wil·1 be discussed in the following section.

104AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
Title 17 CCR, Section 93115, (e)(2)(A)(3)(b) stipulates that new stationary emergency diesel-fueled CI engines (> 50 bhp) must meet the 

## voe + NO

### x, and 

## eo standards for off-road engines of the same model year and maximum rated power as specified in the Off-Road Compression-Ignition Engine Standards (Title ·13 CCR, Section 2423) or the Tier 1 standards for an off-road engine if no standards have been established for an offroad engine ofthe same model year and maximum rated power. In addition, Title 17 CCR, Section 93115, (e)(2)(A)(4)(a)(II) allows new direct-drive emergency fire pump engines to meet the.Tier 2 emission standards specified in the OffRoad Compression Ignition Engine Standards for off-road engines with the same maximum rated power (title 13 CCR, section 2423) until three years after the date the Tier 3 standards .are applicable for off-road engines with the'same maximum rated power. At that time, new direct7'"drive emergency diesel-fueled fire-pump eng.ines (>50 bhp) are required to meet the. Tier 3 emission standards, until three years after the date the Tier 4 standards are applicable for off-road engines with the same ·maximum rated

.power. At that time, new direct-drive emergency diesel-fueled fire-pump engines (>50 bhp) are required to meet the Tier 4 emission sta.ndards; and not operate more than the number of hours necessary to comply with the testing requirements of the National Fire Protection Association (NFPA) 25 - "Standard for the Inspection,Testing, and Maintenance of Water-Based Fire Protection Systems," 1998 edition, which is incorporated herein by reference. In addition, this subsection does not limit engine operation for emergency use and for emission testing to show compliance with (e)(2)(A)4. For this project the proposed emergency diesel IC engine will b'e used to power a firewater pump and is therefore allowed to meet the Tier 2 emission standards specified in the Off-Road Compression Ignition En.gine Standards for off-road engines three years after the applicable dates specified. This additional three-year allowan.ce is reflected in the fOllowing table. The engine involved with this project is a certified 2007 model engine. The following table compares the requirements ofTitle 13 CCR, Section 2423 to the emissions factors for the 288 bhp Cummins Model #CFP83-F40 diesel-fired emergency IC engine as given bythe manufacturer (for, NO

### x+

## vae and PM emissions).

105AvenalPowerCenter, LLC (OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386

Title 13 CCR, 174.3- 301.6 bhp 1996-2002 6.9 g/bhp-hr 1.0 g/bhp-hr 8.5 g/bhp-hr 0.40 g/bhp-hr §2423

. (130
- 225 kW) (Tier 1) (9.2 g/kW-hr) (1

..3 g/kW-hr) (11.4 g/kW-hr) (0.54 g/kW-hr) Title 13·CCR, 174.3 - 301.6 bhp 2003-2005, 

### 4.9 g/bhp-hr 2.6 g/bhp-hr 0.15 g/bhp-hr extended to §2423 (130- 225 kW) 2008 (Tier2) (6.6 g/kW-hr) (3.5 g/kW-hr) (0.20 g/kW-hr) Title 13 CCR, 174.3- 301.6 bhp 2006 and later, 3.0 g/bhp-hr· 2.6 g/bhp-hr 0.15 g/bhp-hr §2423 (130
- 225 kW) extended to (4.0 g/kW-hr) (3.5 g/kW-hr) (0.20 g/kW-hr) 2009 (Tier3) Cummins, 3.8g/bhp-hr 0.447 g/bhp-hr 0.059 g/bhp-hr

Model 288 bhp 2007 (5.1 g/kW-hr) (0.60 g/kW-hr) (0.079 g/kW- #CFP83-F40 hr) N/A N/A Yes Yes Yes 

### As presented in the table above, the proposed engine will satisfythe requirements ofthis section and compliance is expected

.

.The engine manufacturer's data and/9f CARB/EPA ·engine certification for this· engine

lists a Noxemissions factor of 3.4 g/bhp-hr,8 VoCemiss.ionsfactor of0.38 g/bhp-hr, a Nox

### + VOC emission factor of 3.8**g/bhp~hr,** 

### a CO emission factor of**0~447** 

### g/bhp-hr, and a PM 10 

### emissions factor of**0~059** 

### g/bhp-hr, all of which satisfy the requirements of.13 CCR, Section 2423. Therefore, the following conditions (previously proposed in this

. engineering evaluation) will be listed on the ATC to ensure compliance:

• Emissions from this IC engine shall not exceed any of the following limits: 3.4 gNox/bhp-hr, 0.447 g-Co/bhp-hr, or 0.38 g-VoC/bhp-hr. [District Rule 2201 and 13 CCR 2423 and 17 CCR 93115]

• Emissions from this IC engine shall not exceed 0.059 g-PM10/bhp-hr based on USEPA certification using ISO 8178 test procedure. [District Rules 2201 and 4102 and 13 CCR 2423 and 17 CCR 93115] Right ofthe Districtto Establish More Stringent Sta.ndards: This regulation also stipulates that the District: 1. May establish more stringent diesel PM, Nox +. 

### VaG, VaG, NOx, and GO emission rate standards; and 2.· May establish more stringent limits on hours of maintenance and testing on a sitespecific basis; and 3. Shall determine an appropriate limit on the number of hours of operation for demonstrating compliance with other District rules and initial start-up testing The District has not established more stringent stanqards at this time. Therefore, the standards previously established in this Section will be utilized. 

### 106

### AvenalPowerCenter, LLC(08-AFC-01) .SJVACPO Determination ofCompliance, C-1080386



### Title 17 California Code of Regulations (CCR), Section 931'15
- Airborne Toxic Control Measure (ATCM) for Stationary Compression-Ignition (CI) Engines The requirements ofthis section are only applicable to C-3953-13-0. Emergency Operating Requirements: This regulation stipulates that no owner or operator shall operate any new or in-use stationary diesel-fueled compression ignition (CI) emergency standby engine, in response to the notification of an impending rotating outage, unless sp'ecific criteria are met. This section applies to**~mergency** standby IC engines that are permitted to operate during non'-emergency conditions for the purpose of providing electrical power. However, District, Rule 4702 states that emergency standby' IC engines may. only be operated during n'on-emergency conditions forthe purposes' of maintenance and testing. Therefore, this section does not apply and no further discussion is required.

. Fuel an'd Fuel Additive Requirements: This regulation also stipulates that as of January 1, 2006 an owner or operator of a new orin-use stationary diesel-fue·led CI emergency standby engine shall fuel the engine with CARS' Diesel Fuel. Since the engine involved with this project is a new or in-use stationary diesel-fueled CI emergency standby engine, these fuel requirements are app.licable. Therefore, the following condition (previously proposed in this engineering evaluation) will be listed on the ATC to ensure compliance:

• {3395} Only CARS certified diesel fuel containing not more than 0.00150/0 sulfur by weight is to be used. [District Rules 2201 and 4801 and 17 CCR 93115] At-School and Near-School Provisions: This regulation stipulates that no owner or operator shall operate a new stationary emergency diesel-fueled CI engine, with a PM 10 emissio.ns factor> than 0.01 g/bhp-hr, for non-emergency use, including maintenance. and testing, during the following periods: 1. Whenever there is a school sponsored activity, if the engine is located on school grounds, and 2. Between 7:30 a.m. and 3:30 p.m. on days when school is in session, ifthe engine is located within 500**fe~t** ofschool grounds.

107AvenalPowerCenfer , LLC (OB-AFC-01) SJVACPD Determination ofCompliance, C-10B0386

. 

### The District has verified that the engine is not located within 500 feet of a K-12 school. Therefore, conditions prohibiting non-emergency usage of the engine during school hours will not.be placed on the permit. Recordkeeping Requirements: This regulation**stipulat~s** 

### that as of January 1, 2005, each owner or operator of an emergency diesel-fueled CI engi·ne shall keep a monthly log .of usage that shall listand documentthe nature of use for each ofthe following:**a~** 

### Emergency use hours ofoperation; b. Ma·intenance and testing hours ofoperation; c. Hours ofoperation for emission testing; d. Initial start-up hours; and e. If applicable, hours of operation to comply with the testing requirements of National Fire Protection Association (NFPA) 25 - "Standard for the I.nspection, Testing, and Maintenance of**Water~Based** 

### Fire Protection Systems.," 1998 edition; f. Hours ofoperation for all uses otherthan those specified in sections 'a' through cd' above; and g. For in-use emergency diesel-fueled engines, the ·fuel used. The owner or operator shall document fuel use through the retention ,of fuel purch·ase**r~cords** 

### that account for all fuel used in the**~ngine** 

### and all fuel purchased for use in

..the engine, and, at a minimum, contain the following information for each in.dividual fuel purc·hase transaction: I. Identification of the fuel purchased as either CARB Diesel, or an alternative d·iesel fuel that meets the requirements of the Verification Procedure, or an alternative fuel, or CARB Diesel fuel used with additives that meet·the requirements ofthe Verification Procedure, orany combination ofthe above; ·11. 

### Amount offuel purchased; III. Date when the fuel was purchased; IV. Signature of owner or operator or representative of owner or ·operator who received the fuel; and V. Signature offuel provider indicating fuel was delivered. The proposed new emergency diesel Ie engine powering a firewater pump is exempt from the operating hours limitation provided the engine is only operated the amount of hours· necessary to satisfy National Fire Protection Association (NFPA) regulations. Therefore, the following conditions (previously proposed in this engineering evaluation) will be listed on the ATC to ensure compliance:

108AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance,. C-1080386

• {3489} The permittee shall maintain monthly records of emergency and nonemergency operation. Records shall include the number of hours of emergency operation, the date and number of hours of all testing and maintenance operations, and the purpose of the operation (for example: load testing, weekly· testing, rolling blackout, general area power outage, etc.). For units with automated testing systems, the qperator may, as an alternative to keeping records of actual operation for testing purposes, maintain a readily accessible written record ofthe**a~tomated** testing schedule. [District Rule 4702 and 17 CCR 93115]

• {3475} All records shall be maintained and retained on-site for a minimum offive (5) years, and shall be made available for District inspection upon request. [District Rule 4702 and 17 CCR 93115] PM Emissions and Hours of Operation Requirements for New Diesel Engines: This regulation stipulates that as of January 1, 2005, no person shall operate any new stationary emergency diesel-fueled CI engine that has a rated brake horsepower greater than 50, unless it meets all ofthe following applicable emission standards and operating requirements. 1. Emits diesel PM at a rate greater than 0.01 g/bhp-hr or less than or equal to 0.15 g/bhp-hr; or 2. Meets the current model year diesel PM standard specified in the Off-Road· Compression Ignition Engine Standards for**off~road** engi·nes with the**sam~** maximum rated power (Title 13 CCR, Section ·2423), whichever is more stringent; and 3·. Does not operate more than 50· hours per year for maintenance and· testing purposes. Engine operation is not limited during emergency use and during emissions source testing to show compliance with the ATCM. The proposed emergency diesel IC engine powering a firewater pump is exemptfrom the operating hours limitation provided the engine is only operated the amount of 'hours necessary to satisfy National Fire Protection Association (NFPA) regulations. Therefore, the following conditions (previously proposed in this engineering evaluation) will be listed on the ATC to ensure compliance:

• Emissions from this IC engine shall not exceed·0.059g-PM10/bhp-hr based on USEPA certification using ISO 8178 test procedure. [District Rules 2201 and 4102 and 13 CCR 2423 and 17 CCR 93115]

109

### AvenalPowerCenter, LLC(08-AFC-01) SJVACPO. Determination ofCompliance,

.

### C-1080386



### • {3816} This engine.shall be operated only for testing and maintenance of the engine, required regulatory purposes, and during emergency situations. For testing purposes, the engine shall only be .operated the number of hours necessary to comply with the testing requirements of the National Fire Protection Association (NFPA) 25 - "Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems", 1998 edition. Total hours of operation for aU mainte"nance, testing, and required regulatory purposes shall not exceed 50. hours percalendar**year~** 

### [District Rule 4702 and 17 CCR93115]
IX. RECOMMENDATION: 

### Compliance with all applicable prohibitory rules and regulations is expected. Issue the Final Determination of Compliance for the facility subject to the conditions presented in AttachmentA.
X. BILLING INFORMATION:



### C-3953-10-0 C-3953-11-0**C-3953~** 

### 12-0 C-3953-13-0 C-3953-14-0 3020-088-8 3020-088-8 3020-02-H 3020-10-C 3020-10-E 180,000 kW 180,000 kW 37.4 MMBtu/hr boiler

288 bh IC en ine 860 bhp Ie en ine

110 $12,229.00 $12,229.00

$953.00 $222.00 $557.00AvenalPowerCenter, LLC. (OB-AFC-01) SJVACPD Determination ofCompliance, ·C-10B0386**.~**

AttachmentA - 1 

# ATTACHMENT A FDOC CONDITIONSAvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386


### EQUIPMENT DESCRIPTION, UNIT C-3953-10-0: 180 MW NOMINALLY RATED**COMBI~ED-CYCLE** 

### POWER GENERATING SYSTEM #1 CONSISTING OF A GENERAL ELECTRIC FRAME 7 MODEL PG7241 FA NATURAL GASFIRED' COMBUSTION TURBINE GENERATOR WITH DRY LOW NOx COMBUSTOR, A SELECTIVE CATALYTIC REDUCTION (SCR) SYSTEM, AN OXIDATION CATALYST,HEAT R·ECOVERYSTEAI\I1 GENERATOR #1 (HRS·G) WITH A 562 MMBTU/HR DUCT BURNER AND A 300 MW NOMINALLY RATED. STEAM TURBINE SHARED WITH C-3953-11 1. Permittee shall submit an application to comply with' SJVUAPCD District Rule 2520 - Federally Mandated Operating Permits within twelve months of commencing operation. [District Rule 2520] 2. Permittee shall submit an application' to comply with SJVUAPCD District Rule 2540 - Acid Rain Program. [District Rule 2540] 3. Prior to initial operation of C-3953-10-0, C-3953-11-0, and**C~3953-12-0,** 

### permittee shall provideNOx (as 

### N02) emission reduction credits for the following· quantities of emissions: 1st quarter - 67,103 Ib; 2nd quarter- 67,104 .Ib; 3rd quarter- 67,104 Ib; and 4th quarter - 67, 

### 104 lb. Offsets shall be provided at the appropriate distance ratio specified in Rule 2201. [District Rule 2201] 4. Prior to initial operation of C-3953-10-0, C-3953-11-0, and**C-3953-12-0,perm~ttee** 

### shall

.provide 

## voe emission reduction credits for the following quantities of emissions: 1st quarter - 12,294 Ib; 2nd quarter - 12,295 Ib; 3rd q·uarter -12,295 Ib; and 4th quarter - 12,295 lb. Offsets shall be provided at the appropriate distance ratio specified in Rule 2201. [District Rule 2201] 5. Prior to initial operation of C-3953-10-0, C-3953-11-0, and C-3953-12-0, permittee shall provide PM 10 

### emission reduction credits for the following quantities of emissions: 1st 'quarter
- 33,085Ib; 2nd quarter - 33,085 Ib; 3rd quarter - 33,085Ib; and 4th quarter - 33,085 lb. Offsets shall be provided at the appropriate distance ratio specified in' Rule 2201. sax ERC's may .be used to offset PM10 increases at an interpollutant ratio of 1.0 Ib-SOx: 1.0 Ib-PM10. [District Rule 2201] 6. ERC certificate numbers (or any splits from these certificates)**C~897-1,** 

### C-898-1, N-724- 1, N-725-1, 8-2812-1, 8-2813-1, 8-2817-1, C-899-2, C-902-2', N-720-2, N-722-2, N-726- 2, N-728-2, S-2814-2, S-2321-2,C-896-4, N-721-4, N-723-4, S-2791-5, S-2790-5, S2789-5, 8-2788-5, or N-762-5 shall be used to supply the required offsets, unless a revised offsetting proposal is received and approved by the District, upon which this determination of compliance (DOC) shall be reissued, administratively specifying the new offsetting proposal.. Original public noticing requirements, if any, shall be duplicated prior to reissuance ofthe DOC. [District Rule 2201] 7. {15} No air contaminant shall be di$charged into the atmosphere for a period or periods aggregating more than three minutes in· anyone hourwhich'is as dark as, or darkerthan, Ringelmann 1 or20%**opacity.[~istrict** 

### Rule 4101]

AttachmentA - 1 ,AvenalPowerCenter, LLC(OB-AFC-01) SJVACPD Determination ofCompliance, C-1080386


### 8. {98} No air contaminant shall be released into the atmosphere which causes a public

. nuisance. [District Rule 4102] 9. {14} Particulate matter emissions shall not exceed 0.1 grains/dscf in concentration

.

.[District Rul'e 4201] 10. The CTG shall be fired exclusivelyon PUC-regulated n'atural gas with a sulfurcontent of no greaterthan 1.0 grains of sulfur compounds (as S) per 100 dry

### sctof natural gas. [District Rule 2201 and 40 CFR 60.4330(a)(2)] 11. Annual average of the sulfur content of the CTG shall not exceed 0.36 grain, of sulfur compounds (as S) per 100 dry scf of natural gas.. [District Rule 2201] 12. The owner or operator shall install, certify, maintain, operate and quality-assure a Continuous Emission Monitoring System (CEMS) which continu'ously. measures and records the exhaust gas NOx, CO and 

### .02 

### concentrations. Continuous emissions monitor(s) shall be capable of monitoring emissions during normal operating conditionsJ. and during startups and shutdowns, provided the CEMS passes the relative accuracy requirement for startups and shutdowns specified herein. If rela'tive accuracy of CEMS cannot be demonstrated during startup conditions, CEMS results during startup and shutdown events shall be replaced with startup emission rates obtained from source testing ,to determine compliance with emission limits contained in this document. [District Rules 1080 and 4703 and 40 CFR 60.4340(b)(1)] 13. The CEMS shall complete a minimum of one cycle of operation (sampli·ng, analyzing, and data recording) for each successive 15-minute period or shall meet equivalent specifications established by mutual agreement of the District, the ARB and the EPA. [District Rule 1080 and 40 .CFR 60.4345(b)] 14. The NOx, CO and O2 

### CEMS ,shall meet the requirements in 40 CFR 60, Appendix F Procedure 1 and Part 60, Appendix 8 Performance Specification 2 (PS 2), or shall meet equivalent specifications established by mutual agreement of the District, the ARB, and the EPA. [District Rule 1080 and 40 CFR60.4345(a)]· 15. Audits of continuous emission monitors shall be conducted quarterly, except during quarters in which relative accuracy and compliance source testing are both performed, in accordance with EPA guidelines. T'he District sh'all be notified prior to completion of the audits. Audit reports shall be submitted along with quarterly compliance reports to the District. [District Rule 1080] 16. The owner/operator shall perform a relative accuracy test audit (RATA) for NOx, 

### CO and O2 

### as specifie.d by 40 CFR Part 60, Appendix F, 5.11, at least once every four calendar quarters. The permittee shall comply' with the applicable requirements for quality assurance testing and maintenance of the continuous' emission monitor equipment .in accordance with the procedure.s and guidance specified in 40 CFR Part 60, Appendix 

### Fa [District Rule 1080]

AttachmentA - 2AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386


### 17. APCD or an authorized representative. shall be allowed to inspect, as determined to be necessary, the required monitoring devices to ·ensure that such devices are functioning properly. [District Rule 1080] 18.. Results of the CEM system shall be averaged over a one hour. period forNO

### x emissions and athree hourperiod for CO.emissions using consecutive 15-min·ute sampling periods in**a~cordance** 

### with all applicable requirements of CFR 60.13. [D·istrict Rule 4703 and 40 GFR 60.13] 19. Results of continuous emissions monitoring shall be reduced according to the procedures established .in 40 CFR, Part 51, Appendix P, paragraphs 5.0 through 5.3.3, .or by other methods deemed equivalent by mutual agreement with the District, the ARB, and the EPA. [District Rule 1080] 20. The owner or operator shall, upon written notice from the APGO, provide a summary of the data obtained from the CEM systems. This .summary shall be in the form. and the

.manner·prescribed bythe APCO. [District Rule 1080] 21. The facility shall install and maintain equipment, facilities, and systems compatible with the District's CEM data polling software system and shall make CEM data available to the

. District's'automated polling system on a daily basis. [District Rule 1080] 22. Upon notice by the Districtthat the facility's GEM system is not providing polling data, the ·facility may continue to operate without providing automated data for a maximum of 30 days per calendar year provided the CEM data is sent to the District by a Districtapproved alternative method. [District Rule 1080] 23. The owner or operator shall submit a written report of CEM operations for each calendar quarter to the APCO. The rep.ort is due on the 30th day following the. end of the calendar quarterand shall include the following: Time intervals, data.and magnitude of excess NOx emissions, nature and the cause of excess (if known), corrective .actions taken and preventive measures adopted; Averaging period used for data reporting corresponding to the averaging period specified in the emission test period used to determine**compli~nce** 

### with an emission standard; Applicable time and date of each period during which·the ·GEM was inoperative (monitor downtime), except for zero and span checks, and the nature of system repairs and adjustments; A negative declaration when no excess emissions occurred. [District Rule 1080 and 40 CFR 60.4375(a) and 60.4395] 24. Permittee shall notify the District of any breakdown condition as soon as reasonably possible, but no later than one hour after its detection, unless the owner or operator demonstrates to the District's satisfaction that the longer reporting period was necessary. [District Rule 1100, 6.1] 25. The District shall be notified in writing within ten days following the correction of any breakdown condition. The breakdown notification shall include a description.of the equipment. malfunction or failure, the date and cause of·theinitial failure, the estimated emissions in excess of those allowed, and the methods utilized to restore normal operations. [District Rule 1100, 7.0]
Attac.hmentA - 3AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386**~6.** 

### Emission rates from this unit (with duct burnerfiring), except during startup and shutdown periods, shall not exceed any ofth.e following limits: NOx (as N02.)
- 17.20Ib/hr and 2.0 ppmvd @ 150/0 02; voe (as methane)
- 5.89 Ib/hr and 2.0 ppmvd @ 15% 02; CO
- 10.60 Ib/hrand 2.0 ppmvd @ 15% 02; PM10
- 11.78 Ib/hr; or SOx (as 802)
- 6.65Ib/hr. NOx(as N02) emission limits are one hour rolling averag·es. All other emission limits are three hour rolling averages. [District Rules 2201,4001, and 4703] 27. Emission rates from this unit (without duct burner firing), except during startup and shutdown periods, .shall not exceed any ofthe following limits: NOx (as N02)
- 13.55 Ib/hr and 2.0 ppmvd@ 15% 02; VOC (as methane)
- 3.34 Ib/hr and 1.4 ppmvd @**15~/0** 

### 02; eo - 8.35 Ib/hr and 2.0 ppmvd @ 15% 

### 02; PM10
- .8.91 Iblhr; or SOx (as S02)
- 5.23 Ib/hr. NOx (as N02) emission limits are one hour rolling averages. All other emission limits are three h'our rolling averages. [District Rules 2201, 4001, and 4703] 28. During start-up and shutdown, CTG exhaust emission rates shall not exceed any of the following limits: NOx (as N02) - 

### 160 Ib/hr; eo - 1,000 Ib/hr; 

## vae (as 'methane)
- 16 Ib/hr; PM10

- 

### 11.78 Ib/hr; SOx (as 802 ) - 6.652 Ib/hr; or NH3 - 

### 32.13 Ib/hr. [District Rules 2201 and 4703] 29. Daily emissions from theCTG shall not exceed the following limits': NOx(as N02)
- 412.8 Ib/day;' CO
- 254.4 Ib/day; vac - 141.4 Ib/day; PM10 

### 282.7 Ib/day; SOx (as 802 ) - 159.6 Ib/day, orNH3 - 

### 771.1 Ib/daY. [District Rule 2201 ] 30. Emissions 'from t.his un'it, on days when a startup and/or shutdown occurs, shall not exceed the following limits:NOx (as N02)
- 789.6Ib/day; VOC- 202.0 Ib/day; CO
- 5,590.8 Ib/day; PM1.0
- 282.7 Ib/day'; SOx (as S02)
- 159.6 Ib/day·, or NH3 - 

### 771.1 Ib/day. [District Rule 2201] 31. the ammonia (NH3) emissions shall not exceed 10 ppmvd @ 15% 

### 02 over a 24 hour rolling average. [District Rule 2201] 32. The CTG shall be fired exclusively on PUC-regu'lated natural gas with a sulfur'content no greater than 1.0 grain of sulfur compounds (as 8) per 100 dry scf of natural gas. [District Rule 2201 and 40 eFR 60.4330(a)(2)]

. 33. Annual emissions from the CTG, calculated on a twelve month rolling basis, shall not exceed ·anyofthe following limits: NOx (as N02 ) - 143,951 Ib/year; CO
- 601,810 Ib/year;

. VOC
- 34,489 Ib/year; PM 10 - 

### 80,656 Ib/year; or sax (as S02)
- 16,694 Ib/year; or NH3 -



### 208,708 Ib/year. [District Rule 2201] 34. The duration of each startup or shutdown shall not exceed six hours. Startup and shutdown emissions shall be cc;>unted toward all applicable emission limits. [District Rules 2201 and 4703] 35. Each one hour period shall commence on the hour. Each one h'our period in athree hour rolling average will commence on the hour. The three houraverage will be compiled from

.the three most recent one hour periods. Each one· hour .period in a twenty-four hour

.average for ammonia slip will commence on the hour. [District Rule 2201] AttachmentA 4

### Avenal'PowerCenfer, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
36. Daily emissions will be compiled for a twenty-four hour period starting and ending at twelve-midnight. Each month in the twelve consecutive month rolling average·emissions shall com·mence at the beginning of the first day of the month

.. The twelve

.consecutive month rolling average emissions to determine compliance with annual emissions limitations shall be compiled from the twelve most recent calendar months. [District Rule 2201]

. . 37. Startup shall be defined as the period of time during which a unit is brought from a shutdown status to its operating temperature and pressure,**incl~ding** thetime required by the unit's emission control system to reach full operations. Shutdown shall be defined as the period of time during which a unit .is taken from an operational toa non-operational status by allowing it to cool down from its operating temperature to ambient temperature as the fuel supplyto the unit is completelyturned off. [Qistrict Rules 2201 and 4703] 38. The emission control systems shall be in operation and emissions shall be minimized insofar as·technologicallyfeasible during startup and shutdown

.. [District Rule 4703] 39. The exhaust stack shall be equipped with permanent provisions to allow collection of stack gas samples con·sistent with EPA test methods and shall be equipped with safe permanent provisions to sample stack gases with a portable NOx, CO, and 02 analyzer during Di$trict inspections. The sampling ·ports shall be located in 'accordance with the CARB regulation titled California Air Resources Board Air Monitoring Quality Assurance Volume VI, Standard .Operating Procedures for Stationary Emission Monitoring and Testing. [District Rule 1081] 40. Source testing to measure startup, NOx, CO, and 

## vae mass .emission rates shall be conducted for one of the gas turbines (C-3953-10 or C-3953-11) prior to the end of the commissioning period and at least once every seven years thereafter. CEM relative accuracy shall be determined during startup source testing in accordance with40CFR 60,'Ap'pendix 

### B. [District Rule 1081] 41. Source testing (with and without duct burner firing) to measure the NOx, CO, and 

## voe emission rates (Ib/hrand ppmvd 

### @ 15% 02) shall be conducted within 60 days afterthe end of the commissioning period and at least once every twelve months thereafter. [District Rules 1081 and 4703] 42. Source testing (with and without duct burner firing) to measure the PM10 emission rate (Ib/hr) and the ammonia emission rate shall be conducted within 

### 60 days afterthe end of the 'commissioning period and at least once every twelve months thereafter. [District Rule 1081]

. . 43. Com.pliance with natural gas sulfur content limit shall be demonstrated within 60 days after the end of the commissioning period and weekly thereafter. After demonstrating compliance with the fuel' sulfur content limit for 8 consecutive weeks for a fuel source, then the testin.g frequency shall not be less than monthly. If a test shows noncompliance

. with the sulfur content requirement, the source must return to weekly testing until eight

consecutive weeks show compliance. [District Rules 1081, 2540, and 4001].

AttachmentA - 5AvenalPowerCenter, LLC(OB-AFC-01j SJVACPO Determination ofCompliance, C-1080386


### 44. Demonstration of compliance with the annual average sulfur content limit shall be demonstrated by a 12 month rolling average ofthe sulfur content either (i) 'documented in. a valid purchase contract, a**supplierc~rtification,** 

### a tariff sheet ortransportation contract or (ii) tested using ASTM Methods 01072, 03246,04084, 04468, 04810, 06228, D6667 or Gas.ProcessorsAssociation Standard 2377. [District Rules 1081 and 2201] .45. Source testing to determine compliance with the NOx, CO and

## voe emission rates (Ib/hr and ppmvd .@ 

### 15% O2), 

### NH3 emission rate (ppmvd @ 

### 150/0 O2) 

### and PM 10 

### emission rate (Ib/hr) 'shall be conducted at least once every '12 months. [District Rules 1'081, 2201 and 4703 and 40 CFR 60.4400(a)] 46. 'Compliance with the NOx 

### and CO emission limits shall be demonstrated with the auxiliary burner both on and off. [District Rule 4703] 41.. Compli.ance demonstration (source testing) shall be District witnessed, or authorized and samples shall be collected by a California Air Resources Board certified testing laboratory. Source testing shall be conducted using the methods and procedures approved by the District. The District must be notified 30 days prior to any compliance source test, and a source test plan must be submitted for approval 15 days prior to testing. The results of each source test shall be submitted to the District within 60 days

.thereafter. [District Rule 1081] 48. The following test methods shall be used: NOx - 

### EPA Method 7E or 20; CO
- EPA Method.

## to or 10B; VOC
- EPA Method 18 or 25;PM10- EPA Method 5 (front halfand back half) OJ 

### 201 and 202a; ammonia- BAAQMD ST-1 B; and O2 - 

### EPA Method 3, 3A,or

.

. 20. EPA approved alternative test methods as approved .bythe District may also be used to address the source testing requirements of this permit. [District Rules 1081 and 4703 and 40 CFR 60.4400(1 )(i)] ,49. The sulfur content of ea'ch fuel**sou~ce** 

### shall be: (i) documented in a valid purchase contract, a supplier certification, a tariff sheet or transportation contract or (ii) monitored within 60'days 'of the end of the commission period and weekly thereafter. If the SUlfur content is demonstrated to be less than 1.0 grl100 

### sctfor eight consecutive weeks, then the monitoring frequency shall be every six months. If the result of any six month monitoring demonstrates thatthe fuel does not meetthe fuel .sulfur content limit,**we~kly** 

### monitoring shall resume..[District Rule 2201 and. 40 CFR 60.4360, 60.4365(a) and 60.4370(c)]

. 50. Excess emissions shall bedefi'ned as any operating .hour in which the 4-hour or 30-day rolling average NO

### x concentration exceeds applicable emissions limit a.nd 

# a period of monitor downtime shall be any unit'operating hour in which sufficient data are not obtained to validate the hourforeither NO

### xor02 (or both). [40 CFR 

### 60.4380(b)(1)] 51. Fuel sulfur content shall be monitored using one ofthe following methods: ASTM Methods 01072, D3246, 04084, 04468, 04810, 06228, 06667 or 'Gas Processors Association Standard 2377. [40 CFR60.4415(a)(1)(i)] 52. The permittee shall submit to the District information correlating the NOx 

### control system operating parameters to the associated' measured NO

### x output. The information must be

,AttachmentA - 6AvenalPowerCenter, LLC(08-AFC-01) SJVACPO Determination ofCompliance, C-1080386


### sufficient to allowthe Districtto determin.e compliance with the NOx 

### emission limits ofthis permit during times thatthe CEMS is notfunctioning properly. [District Rule 4703] 53. The permittee shall maintain the following records: the date, time and duration of any malfunction ofthe continuous monitoring equipment; dates of performance testing; dates of evaluations, calibrations, checks, and adjustments of the continuous monitoring equipment; date and time period which· a continuous monitoring system or monitoring device was inoperative. [District Rules 1080 and 2201 and 40 CFR 60.8(d)] 54. The permittee shall maintain the following records: date and time, duration, and type of any startup, shutdown, or malfunction;**performanc~** 

### testing, evaluations, calibrations, checks, adjustments, any period during. which a continuous monitoring system or monitoring**devicew~s** 

### inoperative, and maintenance of any continuous emission m'onitor. [District Rules 2201 and 4703] 55. The permittee shall maintain the following records: hours of operati'on, fuel consumption (scf/hr and scf/roll.ing twelve month period), continuous emission monitor measurements, calculated ammonia slip, and calculated NOx mass emission rates (Ib/hr and Ib/twelve .month rolling period). [District Rules 2201 and 4703] 56. The owner or operator of a stationary gas turbine system shall maintain all records of required monitoring data and support information for inspection at anytime for·.a period of five years. [District Rules 2201 and 4703] 57. Disturbances ofsoil related to any construction, demolition, excavation, extraction, or other earthmoving activities shall comply with the requirements for fugitive dust control in District Rule 8021 unless specifically exempted under Section 4.0 of' Rule 8021 or Rule 8011. [District Rules 8011 and 8021] 58. An owner/operator shall submit a Dust Control Plan

### to the APCO prior to the start of any construction activity on any site that will include 10 acres or more·of disturbed' surface area for residential developments, or 5 acres or more'of disturbed .surface area for nonresidential development, or will include moving, depositing, or relocating more than 2,500 cubicyards perdayof bulk materials on at leastthree days. [District Rules 8011 and 8021] 59. An owner/operator shall prevent or cleanup any carryout ortrackout in accordance with the requ.irements of District Rule 8041 Section 5.0, unless specifi'cally exempted under Section 4.0 of Rule 8041 (8/19/04) or Rule 8011(8/19/04). [District Rules 8011 and 8021] 60.

. Whenever open areas are disturbed, orvehicles are used in open areas, the facility shall comply with the requirements of Section 5.0 of District Rule 8051, unless specifically exempted underSection 4.0 of Rule 8051 or Rule 8011. [District Rules 8011 and 8051] 61. Any paved road or unpaved road shall comply with the requirements of District Rule 8061 unless specifically exempted under Section 4.0 of Rule 8061 or Rule 8011. [District Ru.les 8011 and 8061] 62. Water, gravel, roadmix, or chemical/organic dust stabilizers/suppressants, vegetative materials,

.or other District-approyed control measure shall be applied to unpaved vehicle AttachmentA - 7AvenalPowerCenter, LLC(OB-AFC-01)

. SJVACPO Determination ofCompliance, C-10B0386


### travel areas as required to limitVisible Dust Emissions to 20% 

### opacity and comply with the requirements fora stabilized unpaved road as defined in Section 3.59 of District Rule 8011. [District Rule 8011 and 8071] 63. Where dusting materials are allowed 

### to accumulate on paved surfaces, the accumulation shall be removed daily orwaterand/orchemical/organic dust stabilizers/suppressants shall be ap·plied to the paved surface as required to ·maintain continuous compliance with the requirements for a stabilized unpaved road as defined in Section 3.59 of District Rule 8011 and limitVisible Dust Emissions (\IDE)

### to 20% 

### opacity. [District Rule 8011 and 8071] 64. On each day that 50 or more Vehicle Daily Trips. or 25 or more Vehicle Daily Trips with 3 axles or more will occur on an unpaved vehicle/equipment traffic area, permittee shall apply water, gravel, roadmix, or chemical/organic dust stabilizers/suppressants, vegetative materials, or other District-approved control measure as required to limit Visible Dust Emissions to 20% opacity and comply with the requirements for a stabilized unpaved road as defined in Section 3.59 of District Rule 8011. [District Rule 8011 and 8071] 65. Whenever any portion of the site becomes inactive, Permittee shaltjrestrict access and periodically stabilize any .disturbed surface to comply with the conditions for a stabilized surface as defined in Section 3.58 of District Rule 8011. [District Rules 8011 and 8071] 66. Records and other supporting documentation shall be maintained as required to demonstrate compliance with the requirements of the rules under Regulation VIII only for those daysthata control measure was implemented. Such records shall include the type of controlmeasure(s) used, ·the location and. extent of coverage, a.nd the date, amount, and frequency of application of dust suppressant, manufacturer's dust suppressant product information sheet that identifies the name of the dust suppressant and application instructions. Records shall be kept for one year following project completion that results in the termination ofall dustgenerating activities. [District Rules 8011, 8031, and 8071]

AttachmentA - 8AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386



### EQUIPMENT DESCRIPTION, UNIT C-3953-11-0: 180 ·MW NOMINALLY RATED COMBIN·ED-CYCLE POWER GENERATING SYSTEM #2 .CONSISTING ·OF A GENERAL ELECTRIC FRAME 7 MODEL PG7241FA NATURAL GASFIRED COMBUSTION TURBINE GENERATOR WITH DRY LOW NOx 

### COMBUSTOR, A SELECTIVE CATALYTIC REDUCTION (SCR) SYSTEM, AN OXIDATION CATALYST, HEAT RECOVERY STEAM GENERATOR #2· (HRSG) WITH A 562 MMBTU/HR DUCT BURNER AND A 300 MW·NOMINALLY RATED STEAM TURBINE SHARED WITH C-3953-10 1. Permittee shall submit an appli.cation to comply with 8JVUAPCD District Rule 2520 - Federally Mandated Operating Permits within twelve months of commencing operation. [District Rule 2520] 2. Permittee shall**su~mit** 

### an application to comply with 8JVUAPCD District Rule 2540 - Acid Rain Program within 12 months of commencing operation. [District Rule 2540] 3. Prior to initial operation of C-3953-10-0, C-3953-11-0, and C-3953-12-0, permittee shall provide NOx (as N02) emission reduction credits for the following quantities of emissions: ·1 st quarter- 67,103 Ib; 2nd quarter- 67, 104 Ib; 3rd quarter-·67,104 Ib; and 4th quarter- 67,104 lb. Offsets shall be provided at the appropriate distance ratio specified in Rule 2201. [District Rule 2201] Prior to initial ·operation of C-3953-10-0, C-3953-11-0, and C-3953-12-0, permittee shall provide VOC emission reduction credits for the following quantities of emissions: 1st quarter 12,294 Ib; 2nd quarter - 12,295 Ib; 3rd quarter - 12,295 Ib; and 4th quarter - 12,295 lb. Offsets shall be provided at the appropriate distance ratio specified in Rule 2201. [DistrictRule 2201] 5.. Prior to .initial operation of C-3953-10-0, C-3953-11-0, and C-3953-12-0, permittee shall provide PM 10 

### emission**red~ctioncredits** 

### for the following quantities of·emissions: 1st quarter - 33,087 Ib; 2nd quarter - 33,086 Ib; 3rd quarter. - ,33,086 Ib; and 4th quarter - 33,086 lb. Offsets shall be provided at the appropriate distance ratio specified in Rule 2201. SOx ERG's may be used to offset PM10 i·ncreases at an interpollutant ratio of 1.0 Ib-SOx: 1.0 Ib-PM10. [District Rule 2201] 6.

.ERG certificate numbers (or any splits from these certificates) C-897-1,**C~898-1,** 

### N-724-1,**N~725-1,** 

### 8-2812-1, 8-2813-1, S-2817-1, C-899-2, C-902-2, N-720-2, N-722-2, N-726-2, N728-2, 8-2814-2, 8-2321-2, C-896-4, N-721-4, N-723-4, 8-2791-5, S-2790-5, 8-2789-5, S2788-5, or N-762-5 shall be used to supplythe required offsets, unless a revised offsetting proposal is received and approved by the District, upon which this determination· of compliance (DOC) Shall be reissued, administratively specifying the new offsetting proposal. Original public noticing requirements,if any, shall be duplicated prior to reissuance ofthe DOC. [District Rule 2201] {15} No air contaminant shall be disch·arged into the atmosphere for a period or periods aggregating more than three minutes in anyone hour which is as dark as, or darker than·, Ringelmann 1 or200/0 opacity. [District Rule 4101]
AttachmentA - 9AvenalPowerCenter, LLC (OB-AFC-01) SJVACPO Determination 

### ofCompliance,C-1080386 

### {98} No air contaminant shall be released into the atmosphere which causes a public nuisance

..[District Rule 4102] 9. {14} Particulate matter emissions shall not exceed·0.1 grains/dscf in concentration. [District Rule 4201] 10. The CTG shall be fired exclusively on PUC-regulated natural gas with a sulfur content of no greater than 1.0 grains of sulfur compounds (as S) per 100 dry scf'of natural gas. [District Rule 2201 and 40 CFR 60.4330(a)(2)] 11. Annual average of the sulfur content of the CTG shall not excee'd 0.36 grain of sulfur compounds (as .S) per 100

. dry scf of natural gas. [District Rule 2201]

. 12. ·The owner or operator shall' install, certify, maintain, operate and quality-assure a Continuous Emission Monitoring System (CEMS) which continuously measures· and records the exhaust gas NOx, CO .and02 

### concentrations. Continuous emissions'

.monitor(s) shall be capable of monitoring emissions' during normal operating conditionsJ. and during startups and shutdowns, provided the CEMS passes the relative accuracy requirement for startups and shutdowns specified herein. If relative accuracy of CEMS cannot be. demonstrated during startup conditions, CEMS results during startup and shutdown events shall be replaced with startup emission rates obtained from 'source testing· to determine compliance with emission limits contained in this document. [District Rules 1080 and 4703 and 40 CFR 60.4340(b)(1)] 13. The CEMS shall complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15-minute period or shall ·meet equivalent specifications established by mutual agreement of the District, the ARB and the EPA. [District Rule 1080 and 40 CFR 60.4345(b)] 14. 'The NOx, CO and 

### 02 CEMS shall meet the requiremeflts in 40 CFR 60, Appendix F Procedure 1 and Part '60, Appendix B Performance Specification 2 (PS 2),.or shall meet equivalent specifications established by mutual agreement ofthe District, the ARB, and the EPA. [District Rule 1080 and 40 CFR 60.4345(a)] 15. Audits of continuous emission· monitors shall be conducted quarterly, except during quarters in which relative accuracy and compliance source testing are both performed', in a'ccordance with EPA guidelines. The District shall be notified prior to co.mpletionof the aud·its. Audit re.ports shall be submitted along with quarterly compliance reports to the District. [District Rule 1080] 16.· The owner/operator shall perform a, relative accuracy test audit (RATA) for NOx, CO and 

### 02 as specified by 40 CFR Part 60, Appendix F, 5.11, at least once every four calendar quarters. The permittee shall comply with the applicable requirements for quality assurance testing and maintenance of the continuous. emission monitor equipment in accordance with the procedures and guidance specified in 40 CFRPart 60, Appendix F

.. [District Rule 1080]

AttachmentA - 10AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination 

### ofCompliance, C-1080386

7. 

### APCO or an authorized representative shall be allowed to inspect, a.s determined to be necessary, the required monitoring devices to ensure 'that such devices are functioning properly. [District Rule 1080] 18. Results ofthe GEM system shall be averaged overa one hour period for NOx'emissions and a three hour period for CO emissions using consecutive 15-minute sampling periods in accordance with all applicable requirements of CFR 60.13. [District Rule 4703 a.nd 40 CFR 60.13] 19. Results of·continuous emissions monitoring shall be reduced according to the procedures established in 40 GFR, Part 51, Append'ix P, paragraphs 5.0 through 5.3.3, or by other methods deemed equivalent by mutual agreement with the District, the ARB, and the EPA. [District Rule 1080] 20. The owneror operator shall, upon written notice from the APCO, provide a summary ofthe data obtained from the CEM systems. This summary shall·be in the form and the manner prescribed bythe APGO. [District Rule 1080] 21. The facility shall install and maintain equipment, facilities, and systems compatible with the District'sCEM data polling software system and shall make CEM data availa.ble to the District's automated polling system on a daily basis. [District Rule·1 080] 22. Upon notice by the District that the facility's GEM system is not provid.ing polling data, the facility may continue to operate without providing automated data for a maximum of 30 days per calendaryear provided the GEM data is sent to the District by a District-approved .alternative method. [District Rule 1080] 23. The owner or operator shall submit**.~** 

### written report of GEM operations for each calendar quarter to the APCO.The report is due on the 30th day following the end of the calendar quarter and shall include the following: Time**~ntervals,data** 

### and magnitude of excess NOx**~missions,** 

### nature and the cause of excess (if known), corrective actions ta.ken and preventive meas'ures adopted; Averaging period used for data reporting corresponding to the averagi·ng period specified in the emission test period used to determine compliance with an . emis'sion standard; Applicable time and date of each period .during which the GEM was inoperative. (monitor downtime), except for zero and span checks, and the 'nature of system, repairs and adjustments; A negative declaration when no excess emissions occurred. [District Rule 1080 and 40 GFR 60.4375(a) and 60.4395] 24. Permittee shall notify the District of any breakdown condition as soon as reasonably

.possible, but no later than one', hour after its detection, unless the owner or operator

demonstrates to the District's satisfaction that the longer reporting period was necessary.

. [District Rule 1100, 6.1] 25. The District shall be notified in writing within ten days following the correction of any breakdown condition. The breakdown notification shall include a description of the equipment malfunction or failure, the date and cause of the initial failure, the estimated emissions in excess of those aIIowe'd, and the methods utilized to restore normal operations. [District Rule 1100,7.0] AttachmentA - 11AvenalPower'Center, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386


### 1. Emissi'on rates from this unit (with duct burner firing), except during startup and shutdown periods, shall not exceed any of the following limits: NOx (as N02)
- 17.20 Ib/hr and 2.0' ppmvd 

### @ 15% 02; 

## voe (as methane)
- 5.89 Ib/hr and 2.0 ppmvd @ 15% 02; CO -10.60 Ib/hr and 2.0ppmvd 

### @ 150/0 02; Pry110
- 11.78 Ib/hr; or sax**(a~** 802)
- 6.65 Ib/hr. NOx (as N02) emission limits are one hour rolling averages. All other emission limits are three hourrolling averages. [District Rules 2201, 4001, and 4703] 27. Emission rates from this unit (without duct burner firing), except during startup and shutdown periods, shall not exceed any of the following limits: NOx (as N02)- 13.55 Ib/hr and 2.0 ppmvd 

### @ 15% 02; 

### VaG (as methane)
- ,3.34 Ib/hr and 1.4 ppmvd 

### @ 

### 15°/b 02; CO

- 8.35 Ib/hr and 2.0 ppmvd @150/0 02; PM10
- 8.91 Ib/hr; or SOx (as S02) -:- 5.23 Ib/hr. NOx (as N02) emission limits are one hour rolling averages. All other emission limits are three hour rolling averages. [District Rules 2201, 4001, and 4703] 28. During start-up and shutdown, CTG exhaust emission rates shall not exceed any' of the following limits: NOx (as N02 ) -160.lb/hr; CO -1,000 Ib/hr; 

## voe (as methane) -16Ib/hr; ,PM10 - ·11.78Ib/hr; SOx (as 802 ) - 6.652 Ib/hr; orNH3 - 32.13 Ib/hr. [District Rules 2201 and 4703] .' 29. Daily emissions from the eTG shall not exceed the following limits: NOx(asN02) -'412.8 Ib/day; 

# eo- 254.4 Ib/day; 

## voe -141.4 Ib/day; PM 10 - 282.7 Ib/day; sax (as S02)
- 159.6 Ib/day, or NH3 - 771.1 Ib/day. [DistrictRule 2201] J. Emissions from this unit, on days when a startup and/or shutdown occurs, shall not exceed the 'follo,wing limits:NOx (as N02)
- 789.6 Ib/day; 

# voe - 202.0 Ib/day; CO -5,590.8 Ib/day; PM10 '-:- 282.7 Ib/day; sax (as 802)
- 159.6Ib/day, ,or NH3 - 771.1 Ib/day. [District Rule 2201] 31. The ammonia (NH3) emissions shall not e,xceed 10 ppmvd @ 15%02 over a 24 hour rolling average. [District Rule 2201] 32. The eTG shall b'e fired exclus'ively,on PUC-regulated natural gas with. a 'sulfur content no greaterthan 1.0 grain ofsulfurcompounds (as S) per 100 dry scfof natural gas. [District Rule 2201 and 40 CFR 60.4330(a)(2)] 33. Annual emissions from the GTG" calculated on a twelvemonth rolling .basis, shall not exceed any o.f the following limits: NOx (as N02 ) - 143,951 

### Ib/year; .CO
- 601,810 Ib/year; 

## voe - 34,489 Ib/year; PM 10 - 80,656 

### Ib/year; or SOx (as S02)
- 16,694 Ib/year; 

## or NH3 - 208,708 Ib/year. [District Rule 2201]

. 34. The duration of each startup or shutdown shall not exceed six hours. Startup and shutdown emissions shall ,be counted toward all applicabl,e emission limits. [District Rules 2201 and 4703]

,. Each one hour period shall commence on the hour. Each one hour period in a three hour tolling average,will.commence on the hour. The three' houraverage will be compiled from the three most recent one hour periods. Each one. hour period ina twenty-four hour average for ammonia slip will commence on the hour. [District Rule 2201] AttachmentA - 12AvenalPowerCenter, LLC(OB-AFC-01) SJVACPD Determination ofCompliance, C-1080386


### J. Daily emissions will be compiled for a twenty-four hour period starting and ending at " twelve-midnight. Each month in the twelve consecutive month rolling average emissions shall commence at the ,beginning of the first day of the month. The twelve consecutive month rolling average emissions to determine compliance with a'nnual emissions limitations shall be compiled from the twelve most recent calendar months. [District Rule 2201] 37. Startup shall be defined as the period of time during which a unit is brought 'from a shutdown status to its operating temperature and pressure, including the time required by the unit's emission control system to reach full operations. Shutdown 'shall be defined as the period of time during which a unit is taken from an operational to a non-operational status by allowing itto cool down from its operating temperature to ambienttemperature as the fuel supplyto the unit is compl,etelyturned ,off. [District Rules 2201 and 4703] 38. The emission control systems shall be in operation and emissions shall be, minimized insofaras technologicallyfeasible during startup and shutdown. [District Rule 4703] 39. 'The exhaust stack shall be equipped with permanent provisions to allow collection qf stack gas sam'plesconsistent with EPAtest methods and shall be equipped with safe permanent provisions to sample stack gases with a portable NOx, CO, and 02 analyzer during District inspections. The sampling ports shall be located in accordance with the CARB regulation titled California Air Resources Board Air Monitoring Quality Assurance Volume VI, Standard Operating Procedures for Stationary Emission Monitoring and Testing. -[District Rulet081] 40. Source testing to measure startup NOx, CO, andVOC mass emission rates shall be conducted for one of'the gas turbines**(C~39,53-10** 

### or C-3953-11)" prior to the end "of the commissioning period and at least once every seven years thereafter. CEM relative accuracy shall be determined during startup source testing in accordance with 40 CFR 60, Appendix B. [District Rule1 081 ] 41. Source testing (with and without duct,burner firing) to measure the NOx, CO, and"

## voe emission, rates (Ib/hr and ppmvd 

### @ 150/0 02) shall be conducted within 60 days after the end ofthe commissioning period and at least once everytwelve months thereafter. [District Rules 1081 and 4703] 42. Source testing (with and without duct burner firing) to measure the PM10 emission rate (Ib/hr) and the ammonia emission rate shall be conducted within 60 days after the end of the commissioning period and at least once every twelve months thereafter. [District Rule 1081] 43. Compliance with natural gas sulfur content limit shall 'be demonstrated within 60 days after the end" of the commissioning pe"riod and weekly thereafter. After demonstrating compliance with the fuel sulfur content limit for 8 consecutive weeks"for a fuel source, then the testing frequency shall not be less than monthly. If a test shows noncompliance with the sulfur content requirement, the source must return to weekly testing until eight consecutive weeks show compliance. [District Rules 1081,2540, and 4001]. 44. Demonstration of compliance with the annual average sulfur content limit shall be demonstrated by a 12 month rolling'average ofthe sulfurcontent either (i) 

### documented in a Attachment

### A- 13

### AvenalPowerCenter, LLC(08-AFC-01) SJVACPO Determination ofCompliance, C-1080386
valid purchase contract, a supplier certification, a tariff sheet or transportation contract or (ii) tested using. ASTM Methods 01072, 03246,04084,04468,04810,'06228,06667 or Gas Processors Association Standard 2377. [District Rules 1081 and 2201] 4,5. Source testing to determine compliance with the NOx, CO and 

## voe emission rates (Ib/hr and ppmvd @ 150/0 O2), NH3 emission rate (ppmvd @ 15% O2) and PM10 emission rate (Ib/hr) shall be conducted at least once every 12 months. [District Rules 1081, 2201 and 4703 and 40 CFR 60.4400(a)] 46. Compliance with the NOx and CO emission limits shall be demonstrated with the auxiliary burner both on and off. [District Rule 4703] 47. Compliance demonstration (source testing) shall ,be Oistrict witnessed, or authorized and samples shall be collected by a California Air Resources Board. certified testing laboratory. Source testing shall be conducted using th,e methods and procedures approved by the District. The District must be notified 30' days prior to any compliance source test, and a source te'st plan must be submitted for approval 15 days prior to testing. The results of each source test shall b'e SUbmitted to the District within 60 days thereafter. [District Rule 1081] 48. The following test methods shall be u'sed: NOx -.EPA Method 7E or20; CO
- EPA Method 10 or 10B; VOC
- EPA Method 18, or 25; PM10
- EPA Method 5 (front half and back half) or 201 and 202a; ammonia.;. BAAQMD ST-1 B; and O2 - EPA Method 3, 3A, or 20. EPA approved alternative test methods as approved by the District may also be used to address the' source testing requirements of this permit. [District Rules 1081 and 4703 and 40 CFR 60.4400(1 )(i)] 49. The sulfur content of each fuel source shall be: (i) documented in a valid purchase contract, a supplier certification, a tariff sheet or transportation. contract or (ii) monitored within 60 days of the end of the commission period and weekly thereafter. If the sulfur content is demonstrated to be less than 1.0 gr/100 scf for eight consecutive weeks, then the monitoring frequency shall be every six months. If the result of any si'x month monitoring demonstrates that the fuel does not meet the fuel sulfur content limit, weekly monitoring shall resume. [District Rule 2201 and 40 CFR 60.43.60, 60.4365(a) and 60.4370(c)] 50. Exce'ss emissions shall be defined as any operating hou'r 'in which the 4-hour or 30-day rolling average NOxconcentration exceeds applicable emissions ·Iimit and a period of monitor downtime shall be any unit operating hour in which sufficient data. are notobtained to validate the hourfor either NOxor 02 (orboth). [40 CFR 60.4380(b)(1)] 51. Fuel sulfur content shall be monitored using one of the following methods: ASTM Methods 01072, 03246, 04084, 04468,.04810, 06228, 06667 orGas Processors Association Standard 2377. [40 CFR 60.4415(a)(1)(i)] 2. The permittee shall submit to the District information correlating the NOx control system operating parameters to the associated measured NOx output. The information**mustb~** sufficient to allow the District to determine compliance with the NOx emission limits of this 'permit during times thatthe CEMS is notfunctioning properly. [District Rule 4703] AttachmentA -' 14AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination

### ofCompliance, C-1080386



### JJ. The permittee shall· maintain the following records: the date, time and duration of any malfunction ofthe continuous monitoring equipment; dates of performance testing; dates of evaluations, ca·librations, checks, and adjustments ofthe continuous monitoring equipment; date and time period which a continuous monitoring system or monitoring device was . inoperative. [District Rules 1080 and 2201 and 40 CFR 60.8(d)] 54. The permittee .shall maintain the following records: date and time, duration, and type ofany startup, shutdown, or malfunction; performance testing, evaluations, calibrations, checks, adjustments, any period during which a continuous monitoring system or monitoring device was inop.erative, and maintenance of any continuous emission monitor. [District Rules 2201 and 4703] 55. The permittee shall maintain the following records: hours of operation, fuel consumption (scf/hr and scf/rolling twelve month period), continuous emission monitor measurements,

. calculated ammonia slip, and**~alculated** 

### NOx mass emission rates (Ib/hrand Ib/twelve

month rolling period). [District R·ules 2201 and 4703] 56. The owner or operatorofa stationary gas turbine system shall maintain all records of required monitoring data and support information for inspection at any time for a period of five years. [District"Rules 2201 and 4703]

AttachmentA - 15AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386


### EQUIPMENT DESCRIPTION, UNIT C-3953-12-0: 37.4MMBTU/HR CLEAVER' BROOKS MODEL CBL-700-900-200#ST NATURAL GAS-FIRED BOILER WITH A CLEAVER 'BROOKS MO'DEL PROFIRE, OR DISTRICT APPROVED EQUIVALENT, ULTRA LOWNOX BURNER 1. Permittee shall submit an application to comply with 8JVUAPCD District Rule 2520 - Federally Mandated Operating Permits wifhin twelve months of commencing operation. [District Rule 2520] 2. Prior to initial operation. of C-3953-10-0, C-3953-11-0, and C-3953-12-0, permittee shall provide .NOx (as N02) emission reduction credits for the following quantities of emissions: 1st quarter- 67,103 lb.; 2nd quarter- 67,104 Ib; 3rd quarter - 67, 104 Ib; and 4th quarter -67,104 lb. Offsets shall be provided at the appropriate distance ratio specified in Rule 2201. [District Rule 2201] 3.**P~ior** 

### to initial operation of**C-3953~** 

### 10-0, C-3953-11-0, and C-3953-12-0, permittee shall provide VOC emission reduction' credits for the following quantities of emissions: 1st quarter - 12,294 Ib; 2nd q.uarter 12,295 Ib; 3rd quarter - 12,295 Ib; and 4th quarter - 12,295 lb. Offsets shall be provided at the appropriate distance ratio specified in Rule 2201. [District Rule 2201] 4. Prior to initial operation of C-3953-10.-0, ·C-3953-11-0, and C-3953-12-0, permittee shall provide PM 10 

### emission·reduction credits for the foUowing quantities of emissions: 1st quarter -. 33,087 Ib; 2nd quarter - 33,086 Ib; 3rd quarter - 33,086 Ib; and 4th quarter - 33,086 lb. Offsets shall .be provided at the appropriate distance ratio specified in Rule 2201. 80x ERC's m.ay be used to offset PM1

# °increases at an interpollutant ratio of 1.0 Ib-SOx : 1.0 Ib-PM1 

### O. [District Rule 2201] 5. ERC certificate numbers (or any splits from these certificate,S) C-897-1, C-898-1, N-724- 1,**N~725-1,** 

### 8-2812-1, 8-2813-1, 8-2817-1,.C-899-2, C-902-2,**N~720-2,** 

### N-722-2, N-726- 2, N-728-2, 8-2814-2, 8-2321-2, C-896-4,N-721-4, N-723-4, 8-2791-5, 8-2790-5, 8- 2789-5, 8-2788-5, or N-762-5 shall be used to supply the required offsets, unless a revised offsetting proposal is received and approved by the District, upon which this**determina~ion** 

### of compliance (DOC) shall be reissuE3d, administratively specifying the new· offsetting proposal. Original public noticing requirements, if any, shall be duplicated prior to reissuance ofthe DOC. [District Rule 220,1] 6. The permittee shall obtain written District approval forthe use of any equivalent equipment not specifically approved by this Authority to Construct. Approval of the equivalent equipment shall be m.ade only after the District's determination that the submitted desig'n and performance of the proposed alternate equipment is· equivalent to the ,specificaHy· authorized equipment. [District Rule 2201'] 7. The permittee's request for approval of equivalent .equipment shall include the make, model,' manufacturer's maximum rating, manufacturer's guaranteed emission rates, equipmentdrawing(s), and operational characteristics/parameters. [District Rule 2010] 8. Alternate equipment shall be of the same class and category of source as the equipment authorized bythe Authorityto Construct. [District Rule 2201] Attachment A - 16AvenalPowerCenter, LLC.(OB-AFC-01) 

### SJVACPO Determination of

### Compliance, C-1'OB0386

9. No emission factor and no emission shall be greater for the alternate equipment than for the proposed equipment. No changes in the hours of operation, 9perating rate, throughput, or firing rate may be· authorized' for any alternate equipment

.. [District Rule 2201]

. 10. {1407} All**~quipment** 

### shall be maintained in good operating condition and shall be operated in a manner to minimize emissions of air contaminants into the atmosphere. [District Rule 2201]

. 11. {98} No air contaminant shall be released into the atmosphere which causes a public nuisance. [District Rule 4102] 12. {15} No air contaminant s·hall. be discharged into the atmosphere for a period or periods aggregating more than three minutes in anyone hourwhich is as dark as, ordarkerthan, Ringelmann 1 or200/0 opacity. [District Rule 4101] 13. {14} Particulate matter emissions shall not exceed 0.1 grains/dscf in concentration. [District Rule 4201] 14.

. {2964} The unit shall only be fired on PUC-regulated naturaLgas. [District Rule 2201] 15. Emission rates from this unit shall not exceed any ofthe following limits: NOx (as N02)
- 9.0 ppmvd 

### @ 3% 02 or 0.011 Ib/MMBtu; VOC (as methane)
- 10.0ppmvd 

### @ 3% 

### 02; CO

- 50.0 ppmvd 

### @ 3% 02 orO.037 Ib/MMBtu; PM10 -0.005 Ib/MMBtu; or SOx (as S02)
- 0.00285 Ib/MMBtu. [District Rules 2201,4305, and 4306] 16. {2972} All emis.sions· measurements shall be made with the un-it .operating either at conditions representative of normal operations or conditions specified in the Permit to Operate. No determination of complia·nce shall be established within two hours after a .continuous period in which fuel flow to the unit is shut off for 30 minutes or longer, or

.within 30 minutes after a re-ignition as defined in Section' 3.0 of ,District' Rule 4306.

[District Rules 4305 and 4306] 17. {3467} Source testing to measure NOx and CO emissions from this unit while fired on natural gas shall be conducted within 60 days of initial start-up. [District Rules 220·1, 4305, and 4306]

. 18.

.{3466} Source testi.ng to measure NOx and CO emissions from this unit while fired on natu'ral gas shall be conducted at least once every twelve (12) months. After demonstrating compliance on two (2) consecutive annual s'ource tests, the unit shall be tested**~ot** 

### less than once every thirty-six (36) months. If the result of the 36-month

. source test demonstrates that the unit do'es' not meet the 'applicable emission limits, the

.source testing frequency shall revert to at least once every twelve (12) months. [District

Rules 4305 and 4306] 19. {2976} The source test plan shall identifywhich bas.is (ppmv or Ib/MMBtu) will be used to demonstrate compliance. [District Rules 4305 and 4306] AttachmentA - 17AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386**~O.** 

### {109} Source testing shall be conducted using the methods and procedures approved by the District. The District must be notified at least 30 days priorto any compliance source test, and a source test plan must be submitted·. for approval at least 15 days prior to testing. [District Rule 1081] 21. {2977}NOx emissions for source test purposes shall be determined using EPA Method 7E or ARB Method 100 on a ppmv .basis, or EPA Method 19 on a heat input basis. [District Rules 4305 and 4306] 22. {2978} CO emissions for source test purposes shall be determined using EPA Method 10 orARB Method 100. [District Rules 4305 and 4306]

.23. {2979} Stack gas oxygen (02) shall be determined using EPA Method 3 or 3A or ARB. Method 100. [District Rules 4305 and 4306] 24. {2980} For emissions source testi.ng, the arithmetic average of three 30-consecutiveminute test runs shall apply. If two of three runs are above an applicable limit the test cannot be used to demonstrate compliance with an applicable limit. [District Rules 4305 and 4306] 25. {110} The results of each source test shall be submitted to the District within 60 days thereafter.**[Distr~ct** 

### Rule 1081] 26.. A non-resettable, totalizing mass orvolumetric fuel flow meterto measure the amount of fuel combusted in the unit shall be installed, u.tilized and maintained. [District Rules 2201 and 40 CFR 60.48 (c)(g)] 27. Permittee shall maintain daily records of the type and quantity of fuel combusted by the boiler. [District Rules 2201 and 40 CFR 60.48 (c)(g)] 28. {2983} All records· shall be maintained and retained on-site for a minimum of five (5) years, and shall be made available for District inspection upon request. [District Rules 1070, 4305, and 4306] 29. {1832} The exhaust stack shall be equipped with a continuous emissions monitor (CEM) for NOx, CO, and 02. The CEM shall meet the requirements of40GFR parts 60 and 75· and shall be capable of monitoring emissions during startups and shutdowns as well as during normal operating conditions. [District Rules 2201 and 1080] 27. {1833} The facility shall install and maintain equipment, facilities, and systems

.compatible with the District's GEM data polling software system and shall· make CEM data available to the District's automated polling system ona daily basis. [District Rule 1080] 28. {1834} Upon notice by the District that the facility's CEM system is not providing polling data, the facility m·ay continue· to operate without providing automated data for a maximum-of 30 days percalendaryear provided the GEM. data is sentto the District by a District-approved alternative method. [District Rule 1080] AttachmentA - 18AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination 

### ofCompliance, C-1080386


### 29. {1835} The exhaust stack shall be equipped with permanent'provisions to allow collection of stack gas samples consistent with EPA test methods and shall be· equipped with safe permanent provisions to sample stack gases with a portable NO'x, CO, and 02 analyzer during District inspections. The sampling ports shall be located in accordance with the CARB regulation titled California Air Resources Board Air Monitoring Quality Assurance Volume VI, Standard Operating Procedures for Stationary Source Emission Monitoring and Testing. [District Rule1081l 30. {1836} Results of continuous emissions monitoring shall be reduced according to the procedure established in 40 CFR, Part 51, Appendix P, paragraphs 5.0 through 5.3.3, or by other methods deemed equivalent by mutual agreementwith the District,

.the AR.B, and the EPA. [District Rule 1080] 31. {1837} Audits of continuous emission monitors shall· be conducted quarterly, except during quarters in which relative accuracy and total accuracy testing is performed, in accordance with EPA guidelines. The District shall be notified priorto completion ofthe audits. Audit reports shall be submitted along'with quarterly compliance reports to the

. District. [District Rule.1 080] 32. {1838} The owner/operator shall perform a relative accuracy test audit (RATA) as specified by 40 CFR Part 60, Appendix F, 5.11 ,at least. once every four calendar quarters. The permittee shall 'comply with the applicable requirements for quality assurance testing' and maintenance of the continuous emission monitor equipment in accord'ance with the procedures .and guidance specified' in 40 CFR Part 60, Appendix F. [District Rule 10801 33.' {1'839} The permittee shall submit a written report to the APCO for each calendar quarter, within 30 days of the end of the quarter, ·including: time intervals, data and magnitude of excess emissions,nature and c.ause of' excess emissions (if known), corrective actions taken and preventive measures adopted; averaging period used for data ·.reporting shall correspond to the averaging period for each respective emission standard; applicable time and date of each period during which.the CEM was inoperative (except for zero and· span checks) and the nature of system repairs and adjustments; and a negative declaration when no excess emissions occurred. "[District Rule 1080]

AttachmentA - 19AvenalP9werCenter, LLC(OB-AFC-01) SJVACPO Determination 

### ofCompliance, C-1080386**~QUIPMENT** 

### DESCRIPTION, UNIT C-3953-13-0: 288 BHP' CLARKE MODEL JW6H-UF40 DIESEL-FIRED EMERGENCY IC ENGINE POWERING A FIRE PUMP 1. Pe'rmittee shall submit an application to comply with SJVUAPCD District Rule 2520 - Federally Mandated Operating Permits within twelve months of commencing o·peration. [District Rule 2520] 2. {98} No air contaminant shall be released into the atm·osphere which causes a public nuisance. [District Rule 4102]

. 3. {14} Particulate matter emissions shall not exceed 0.1 grains/dscf in concentration. [District Rule 4201] 4. {15} No air contaminant shall be discharged i.nto the atmosphere for a period or periods

. aggregating more than three minutes in anyone hourwhich is as dark as, ordarkerthan,

Ringelmann 1 or20% opacity. [District Rule 4101] , 5. {1898} The exhaust stack shall vent vertically upward. The vertical exhaustflow shall not, be impeded by a rain cap, roof overhang, orany otherobstruction. [District Rule 4102] 6. {3395} Only CARB certified diesel fuel containing not more than 0.0015% sulfur by weight is to be used. [District Rules 2201 and 4801 and 17 CCR 93115] 7. {3403} This engine 'shall be equipped with an operational non-resettable elapsed time meteror otherAPCO approved alternative. [District Rule 4702 .and 17 CCR 93115] 8. Emissions from this IC engine shall not exceed any of the following limits: 3.4 gNOx/bhp-hr, 0.447 g-CO/bhp-hr, or 0.38 g-VOC/bhp-hr. [District Rule 2201 and 13 CCR 2423 and 17 CCR 93115] 9. Emissions from 'this IC engine shall not exceed 0.059 g-PM10/bhp-hr based on USEPA certification using ISO 8178 test procedure. [District Rules 2201 and 4102 and 13 CCR 2423 and, 17 CCR 93115] , 10. This engine shall be operated only for testing and maintenance of the engine, required regulatory purposes, and during emergency situations. Fortesting purposes, the engine' shall only be operated the number of hours necessary to comply with the testing requirements of the National Fire Protection Association (NFPA) 25 - "Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems", 1998 edition. Total hours of operation for all maintenance, testing, and required regulatory purposes shall not exceed 50 hours per calendar year. [District Rule 4702 and 17 CCR 93115] 11. {3807} An emergency situation is an unscheduled electrical power outage caused' by sudden an.d reasonably unforeseen natural disasters or sudden and reasonably unforeseen events beyond the control ofthe permittee. [District Rule 4702]
AttachmentA - 20AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386


### '12. {3489} The permittee shall maintain monthly records of emergency and-**non~emergency** 

### operation. Records shall include the number of hours of emergency operation, the date and number of hours of all testing and mainten-ance operations, and the purpose of the operation (for example: load testing, weekly testing, rolling blackout, general area power outage, etc.).

_ For units with automated testing systems, the operator may, as an alternative to keeping records of actual operation fortesting purposes, maintain a readily -accessible written record 

### Ofthe automated testing schedule. [District Rule 4702 and 17 CCR 93115] 13. {3475} All records shall be maintained a-nd retained on-site for a minimum of five (5) years, and- shall be made available for District inspection upon request. [District Rule 4702 and 17 CCR93115]

Attachm-entA
- 21AvenalPowerCenter, LLC (OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
EQUIPMENT DESCRIPTION, UNIT C-3953-14-0: 860BHP CATERPILLAR MODEL 3456 NATURAL GAS-FIRED EMERGENCY IC ENGINE POWERilNG WITH NON-SELECTIVE CATALYTIC REDUCTION (NSCR) POWERING A 500 KW ELECTRICAL GENERATOR 1. Permittee shall submit an application to comply with' SJVUAPCDDistrict Rule 2520 - Federally Mandated Operating Permits within twelve months of commencing operation. [District Rule 2520] 2. Permittee shall subniitan application to comply with SJVUAPCD District Rule 2540 - . Acid Rain Program within 12 months of commencing operation. [District Rule 2540] 3. {98} No air contaminant**sh~1I** be released into the atmosphere which causes a public nuisance. [District Rule 4102] 4. {14} Particulate matter emissions shall not exceed 0.1 grains/dscfin concentration. [District Rule 4201] 5. {15} No air co·ntaminant shall b'e discharged into the atmosphere for a period or periods**aggreg~ting** more than three minutes in anyone hourwhich is as dark as, or**dark~r** than, Ringelmann 10r20% opacity. [District. Rule 4101] 6. {1898} The exhaust stack shall vent vertically upward. The vertical exhaust flow shall not be impeded by a rain cap, roof overhang, or any other obstruction. [District Rule 41 02]

. 7. {3492} This IC engine shall be equipped with athree-way catalyst. [District Rule 2201.]

. 8. {3404} This engine shall be equipped with an operational non-resettableelapsed time meterorotherAPCO approved alterl'1ative. [District Rule 4702] 9. Emissions from this IC engine shall not exceed· any of the'following limits: 1.0 gNOxlbhp-hr, 0.034 g-PM1 O/bhp-hr, 0

..6 g-CO/bhp-hr, or 0.33 g-VOC/bhp-hr. [District Rule 2201] 10. {3405} This engine shall be operated and maintained in proper operating conditi.on as recommended by the engine manufacturer or emissions control system supplier. [District Rule 4702] 11. {3478} During periods of operation for maintenance, testing, and required regulatory purposes, the permittee shall monitor the operational characteristics of the engine as recommended by the manufacturer or emiss'ion control system supplier (for example: check e'ngine fluid levels, battery, cables and connections; change engine 'oil and filters; replace engine coolant; and/or other operational characteristics as recommended by the manufacturerorsupplier). [District Rule 4702] 12. This engine shall be operated only for testing and maintenance ofthe engine, required regulatory purposes, and' during emergency situations. Operation of the engine for maintenance, testing, and re.quired regulatory' purposes shall not exceed 50 hours per calendaryear. [District Rule 4702] AttachmentA - 22AvenalPowerCenter, 

### LLC, (OB-AFC-01) SJVACPO Determination 

### ofCompliance, C-1080386



### 13. {3807} An emergency situation is an unscheduled electrical power outage caused by sudden and, reasonably unforeseen natural disasters or sudden**~nd** 

### reasonably unforeseen events beyond the control ofthe permittee. [District Rule 4702] 14. {380B} 

### This engine shall not be used to produce power for the electrical distribution syste'm, as part of a voluntary utility demand reduction progra,m, or for an interruptible power contract. [District Rule 4702] 15. {3496} The permittee shall maintain monthly records of emergency and no,n-emergency operation. Records shall include the number of'hours of emergency operation, the date and, number of hours of all testing and maintenance operations, 'the purpose of the operation (for example: load testing, weekly testing, rolling blackout, general area power outage, etc.) and records of operational characteristics monitoring. For, units with automated testing systems, the operator may, as an alternative to keeping records of actual operation for testing purposes, maintain a readily accessible written record ofthe automated testing schedule. [District Rule 4702] 16., {3497} All records shall be maintained and retained on-site for a minimum of five (5) years, and shall be made available for District inspection upon request. [District Rule 4702]

AttachmentA - 23

### AvenalPowerCenter, LLC(08-AFC-01) SJVACPO Determination·ofCompliance, C-1080386



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### o 2,000 4,000 FEET 

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### I S'CALE FEDERAL POWER AVENAL LLC 

### AVENALENERGY I FIGURE 2.1-1A·AvenalPowerCenter, LLC(OB-AFC-01) SJVACPD Determination

### ofCompliance, .C-1080386



# ATTACHMENT C 

# ·crG CommissioningrPeriodEmissions Data

Attachment C - 1SECTION 6.2 AIR QUALITY
rrhe maximumheat inputrates (fuel consumption rates) for the gas turbines, duct burners, and auxiliary boilerare showninTable 6.2-22.

TABL·E 6.2-22 MAXIMUM FACILITY FUEL USE1 (\'{l\'IBTU (HE-IV). GasTurbines and Duct Total Fuel Use Period Burners (eacha) Auxiliary Boiler (aU Units) Per Hour 2,356.5 37.4 4,750 Per O'ay 56,55Sb 449c ll3,llld Per Year 16,I76,OOOe**46~650f 32,353,OO~**  Notes:
a Each oftwo trains. b**Bas~d** on 24 hou'rs perday ofduct firing.
C Based on a'startup day, duringwhich the auxiliarY boiler \vould be used.l2 hours. d The maximum facility fuel useday, during which the turbines run 24 hours vvithduct firing, has no useofthe auxiliary boiler(i.e., no'startup).'
. e Basedonmaximum fueluse of7,960 hours peryear withoutduct firing, and 800 hours peryearwithduct firing, perturbine_ f Basedon 1,248 hours ofoperationper·year.· . g Basedonbaseload scenario (see Footnoted) that includes'no operationofthe auxiliary boiler.
. CTGEmissionsDuringStartup a·ndShutdo.wn Maximumemissionrates expectedto'occurduri·ng a startup or shu.tdownare shownin Table 6.2-23. PM10and SOlemissions have notbeen included inthis table becauseemissions of these pollutants dependonfuel flow, which will be lowerduring a startup periodthanduring. baseload· facility operation.

TABLE 6.2-23 FACILITY STARTUP/SHUTDOWN EMlSSlON RATES4 NOx CO voe Startup/Shutdown, Ib/hour, 80 900 16 average Startup/Shutdov/n,**Ib/~ .It>~'Z-**  160· 1,000 16

. maximum

a Estimatedbased on vendordataand sourcetestdata.. See Appendix6.2-L, Table 6.2
...L6 and -1.7.
The.analysis ofmaximumfacility emissions of**eac~** criteriapoLlutant was basedonthe turbine/HRSG and auxiliary boileremission factors shown inTables 6.2-l9, 6.2-20, and 6.2-21; the startup emissionrates shown inTable 6.2-23; the three operating scenarios**des~ribed** above,**.a~dthe** ambientconditions thatresult.in the highest'emission rates'. The maximumannual, daily, and hourly emissions ofeachcriteriapollutant for the P.rojectare showninTable 6.2-.24 ·andare basedonthe following operatingconditions andscenario parameters:

Avenal EnergyAFC 6.244SECTION 6.2
CTG Efliissions During COlnfflissiofliflg Gas turbine commissioning is the process ofinitial**startup~** tuning and adjustment ofthe new 

## eTas and auxiliary equipmentandofthe emission controlsysterns. ·Thecommissioning process consists ofsequential testoperationofeacllofthe two gas turbines up through increasing load levels, and withsuccessive applicationof the airpollutioncontrol systems. The total setof

. ' commissioningtests will requireapproximately 410operating hours for each eTG. Withthe planned sequentialtesting ofthe two gas turbines, the overall lengthofthe cornmiss.ioning period would

### be approximately 3 months. Commissioning ofthe proposed project may be phased into. two commissioning periods eachapproximately l.5 months long.
Thereare severalcommissioning modes. The first is the periodpriorto SCRsystem"insta.llation, whenthecombustoris beingtuned. "During this mode, the NO" emissions control systemwould notbe functioning andthe combustorwouLd not be tunedforoptimum**perfo~ance.** CO emissions wouldalso beaffectedbecausecombust9rperfonnance would notyet.beoptimized. The secondemissions scenario will occur when the combustorhas beentuned butthe SCR installation 

### is notcomp.fete, andotherparts.ofthegas turbine**op~rating** systemare being checked out. Because thecombustorwouldbe tuned butthe emissioncontrol system**installati~n** wouLd notbecomplete, NO" and COlevels couldagain be affected.

Noncriteria PollutantEmissions Noncriteriapollutants are compounds thathave been identifiedas pollutants thatpose a pote-ntial healthhazard. Nineofthese pollutants are regulated under the·federal Ne\YSource Review

.program: lead, asbestos, beryllium, mercury, fluorides, sulfuric acid mist, hydrogensulfide, total reduced sulfur, andreduced sulfurcompounds.24 Inadditionto these ninecompounds; the federal Clean AirAct listed l87 to 18925 substances atdifferenttimes as potentialhazardous air pollutants (CleanAirActSec. 112(b)(1

## ». The State ofCaliforniadefined a setoftoxic air contaminants throughAssembly Bill (AB) 2588, the AirTaxies "HotSpots" Infonnation and Assessment Act. The SNAPCD publislleda listofcqmpounds itdefinedas.potential toxic air contaminants in its May 1991 Toxics Policy. Any pollutantthat.may be emitted"from the Project and is onthe federal New Source Review list, the.federal CleanAir Act list, the AB2588 listor

24Thesepollutants areregulatedunderfederal andstateairquality programs; however, they areevaluatedas noncriteriapollutants by**t~e** CaliforniaEnergyCommission. 25"

. .

Currently 187 substances are listed. Avenal Energy AFC 6.2-47AvenalPowerCenter, LLC (OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386



### Attachment 0 - 1 

# ATTACHMENT D CTG Emissions Data'1/23/2008 Table a.2-1.1 Eml·sslonsand Operating Parameters for NewTurbines

£\
..... 11
.... _II"'" MI'''' "'
.... Case 1 Case 5 Case 9

. Cae.! 2 Case 6 Case 10 Case 4 Case·8 Case**~2** ·101·F 63'F 3Z'F 101·F 63°F 32'F 101°F 63·F 32'F Full LoadwIDsC1) Full Load wIDg1) ·Full Load wIDS<t) Full Load no D8 Full Load no D8

.Full Load no DB 50% Load 50% L.oad 50% Load AmbientTemp, of 101 . 63 32 101 63 '32 101' 63 '32 G1' Load, % 100% 100% 100% 100:% 100% 100% 50% 50% 50% Both OTs Gross Power, MW 344.8 345.0 359.0 345,.5 '345:6 359.5 144.1 168.6 163.2 sra Gross Power. MW 290.8 273.3 254.7 171.6 176.1**177~7** 118.3 127.6 130.6 Plant Gross PowerOutput, MW 635.8 818.3 613.,.1 517.2 521.7 537.2 262.5 296
..2 313.9 Plant Net PowerOutput, MW 600.0 600.0 600:0 483.7 SOe.5 525.5 250.3 286.3 204.8 OT! Fuel Flow, kpph 156.4 156.4 161..8 156.4 156.4 161.8 87.2 96.2 102.2 08s FuelFlow, kpph 49.0' 39.6 ,31.0 0,0 0.0 0.0· 0.0 0.0 0.0 OTs Heat Input, MM8tu/hr (HHV) 1,794.2 1,794.3 1,855.4 1,795.6 1,795.4 1,856,3 1,001.04 1,104.3 ',171.9 .D88 Heat Input, MMStu/hr (HHV) 562.3 454.4 356.3 0.0 0.0 0.0 0.0 0.0**O~O** Total Heat Input, MM8tulhr (HHV) 2,356.5 2.248.6 2,211.8 1,795.6 1,795.4' 1,856.3 1,001.4 1,104.3 1,111.9 Stack Flow, Ib/hr 3,653,000 3,650,000 3,759,000 3,628,000 3,.830,000 3,743,000 2,23'2,700 2,336,800 2,413,300 StackFlow, tcfm 1,044,365 1,025,495 1,059,836 -1,051,631 1,037,822 1,011,653. 620,528 644,316 666,146 StackTemp, 'F 195.3 184.9 189.0 207.4 198.8 200.9 180.2 175.8 177.4 Stack eXhaust, vol% O

2(dry) 11.40% 11.87% 12.34% 13.76°(0 13.77%
. 13.78% 14.46% 14.11% 13.93% CO2 (dry) 8.42% 5.16% 4.89% 4.0.9%**4~08°(o** 4.08% 3.70% 3.69% 3.99% H2O 10.54% '10.03% 9.12% 8.39%' 8.28% 7.78% 8,01% 7.97% 7.63% Emissions NO., ppm:Vd @, 15% O 2 2.0 2.0 2.0 2.0 2.0 2.0 2.0 2.0 2.0 NO", Ib/hr(2) 17.13 16.34 16.06**13~03** 13.03 13.47 7.26 8.01 8.51 NO", Ib/MMStu (HHV) 0.0073 0.0073 0.0073 0.0073 0.0073 0.0073 0.0073 0.0073
. 0.0073 S02, ppmvd.@ 15% O 2 IJ) 0.139 0
..139 -0.140 0.140 0.140 0.140 0.140 0.140 0.140 S02,**Ib/h~2.3)** '1.66 1.59 1.58 1.27 1.21 1.31 0.71 0.78 0.83 5021 IblMMBtu (HHVi3) 0.0007 0.0007 0.0007 0.00'07 0.0007 0.0007 0.0001 0.0007 0.0007 CO. ppmvd <m 15% O 2 4.0 4,0 4,0
. 4.0 4.0 4.0 4.0 4.0 4.0 CO,lblhr2) 20.86 19.90 19.56 15.86 15.86 1**e~39'** 8.84 9.75 10.36 CO, IblMMBtu (HHV) 0.0089 0.0088 0.0088
. o.ooea o.ooea 0.0088 0.0088 0.0088 0.008a voe, ppmvd @15% O 2(4) 2.0· 2.0 2.0 1.4 1.4 1.4 1.4 1.4 1.4 v.oe. Ib/hr2,,,, 5.96 5.68 5.59 3.17 3.17 3.28 1.77 1.95 2.07 voe, Ib/MMS.tu (HHvjil) 0.0025 0.0025
. 0.0025 0.0018 0.0018 0.00'18 ·0.0018 0.0018 0.0018

. PM,o, tblhr2• O ) 11.81 ·11.27 10.78 ·9.00 9.00 '9.00 9.qo 9.00 9.00 PM,o, IbIMM8tu (HHV)t5) 0.0050 0.0050 0.0049 0.0.050 ' 0.0050
. 0.0,048**0~O090** 0.0081 0.0077 PM,o, grlSCF (dry)(5) 0.00189 0.001'79 0.00"65' 0.0,0142 0.00142**0~00137** 0.00230 0.00220 0.00212 NH3' 'ppmvd 15% O2**10~O** 10.0 10.0 10.0 10.0 10.0 10.0 10.0 10.0 NH3• Ib/hr1)
. 35.39 33.57 32.66 26.28 26.25**2e.9~** 14.60 16.0e 17.02 CO2, Ib/MMBtu (HHVf' 117.0 117.0 . 11i.o 117.0 117.0 117.0 111.0 117.0 117.0**CH~,** Ib/MMStu (HHV)(6) 0.013 0.013 0.013 ' 0.013 '0.013 0.013 0.013 '0.013 0.013 N20, tbIMM8tu (HHVi8) 0.00022 0.0'0022 0.00022 0.00022 0.00022 ' 0.00022 0.00022 0·.00022 0.00022 CO2, Ib/hr (5) 275,599 2a2,984 258,674 210;0.00
. 209;976 21'7,102 117,114 129,153 137,055 CHiI,lbl.tlr(6) 30.7 29.2**2e~a** 23.4 23.4 2'4.1 13.0
. 14.4 15.2 N20, Iblhr (5) 0.52 0.50 0.49 0.40 0.40 0.41 0.22 0.24 0.261/23/2008 ' 1) Includes duct bum'erfiring only up to plant maximum output of eOO'MW. 2) All mass nowvalues reported are on a per staCk basis. Plant total mass flows are double these values. , 3) All oft"'e**assum~d** 0.25 gr S In 100 sc:f ofthe fuel Is assumed to be converted'to**S~** wlthno**S~** conversion. 4) Sased 9n ,an assumption that 20% of reported UHC emissions are VOCs. 5) Includes front-hatf (filterable) portion only. Back-haff'(condensible) portion Is excluded. 8)**CH~** emlss/on factor (kgIMM8.tu) ::**O~0059** ,**A~B.** DraftEmission ractorSfo(MandatoryReportingProgram, Table of Methane and Nitrous Oxide Emission Factors for StatlonarY'Combustion by Sectorand Fuel TYPia, August 10, 2007. 7) CO2emission factor (kg/MMBtu) It S3.05 AR8. DraftEml$$/cn ;:actcrs lorMandatoryReportingProgram,rable of Carbon Dioxide Emission Factors and Oxidation Rates for Stationary Combustion, August 10, 2001. S)N20 emission (actor**(kglM~8tu)** • 0.0001 AR8.DraffEmlss/on rsctors forMandatoryReportingProgram, 'Table of Methane and Nitrous Oxide Emission Factors for Stationary CombustIon by Sectorand Fuel Type, August 10,2007. 'AvenalPowerCenter, LLC (OB-AFC-01J

. SJVACPO Determination ofCompliance, C-1080386



# ATTACHMENT·E SJVA,PCD BACTGuidelines 

## 1.'1.2, 3.1.4, 3.1.,8, and

## 3.4.2

Attachment E - 1

### San Joaquin Valley' 

### Unified Air Pollution 'Control District ,Best Available Control Techn.ology (BACT) Guid.eline 1.1 ;.2* Last Update: 3/14/2002 Boiler: > 20.0 MMBtulhr, Natura'i gas fired, .base-Ioad'ed orwith small load swings.** Pollutant Achieved in Prac'tice or cO'ntaine'd in the SIP CO Natural gas fuel with LPG backup Technologically' Feasible Alternate Basic Equipment

NOx

PM10 

### so
vac 9.0 ppmvd @ 3% 02 (0.0108 Ib/MMBtu/hr) Ultra-Low NOx main burrier system burner system· and a naturalgas or' LPG fired ignitersystem ( ifthe ignitersystem is used to heat the boiler at low fire). Natural gas fuel with LPG backup Natural gas fuel with LPG backup Natural gas fuel with LPG backup 9.0 ppmvd @3% 02 (0.0108 Ib/MMBtu/hr) Selective Catalytic Reduction, LowTemperature**Oxidizer~** or equal and a < 30 ppmv NOx@ 3°k 02 igniter system ('if the ignitersystem**i~** usedto heatthe boilerat low·fire).

U Forthe purpose of this determination, "small loadswings" are defined as normal,operationalload fluctuations which are within the operational response range of an Ultra-Low NOx burner system(s}. BACT is the m·ost stringent control technique forthe emissions unitand class of source. Control techniques that are no.t achieved in practice qrcontained ins a state implementation plan mustbe cost effective as wen as feasible. Economic analysi's to demonstrate cost effectiveness is requried for all determinations that are not achieved in practice orcontained in,an EPA approved State Implementation Plan. *This is 

### aSummary 'Page for this Class ofSource Permit Specific BACT Determinations on (\Iext Page(s)

### San Joaquin Valley Unified Air 

### Pollution Control ,District Best AvaUable Control Technology (BACT) Guideline 3

..1.4*: Last Update: 6/30/2001 Em,ergehcy Diesel I.C.Engi'ne Driving a,Fire Pum'p Pollutant Achieved in Practice or contained 'in the SIP co Technologically Feasible Oxidation Catalyst ,Alternate Basic Equipment

NOx
,PM10

SOx

VOC Certified NOx emissions of 6.9 g/bhp-hr or less 0.1 grams/bhp-hr (if TBACT is triggered) (c<?rrected '7/16/01 ) 0.4 grarns/bhp-hr'(if 1SACT is nottrigg'ered) Low-sulfur diesel fuel (500 ppmw sulfur or less) orVery Low-sulfurdtesel fuel (15 ppmw sulfur or less), where**available~** Positive'crankcase ventilation [unless it voids the Underwriters Laboratories (UL) certification] Catalytic Oxidation

1. Any engine model included in the ARB or EPA**di~sel** engine certification lists and identified as having a PM1 0 emission**~ate** ofo. 149grams/bhp-hror less. based on.,ISO 8178 test procedure. shall be deemed to meetthe 0.1 grams/bhp-hr requirement. 2_ A site-specific Health Risk Analysis is used to determine ifTBACT is triggered. (Clarification added 05/07/01 ) BACT is the most stringent control technique forthe emissions unitand class of source. Control techniques that are not achieved in practice orcontained in s a state implementation plan must be cost effective as well as feasible. Economicanalysis to demonstrate cost effectiveness is requried for all determinations that are not achieved in practice qrcontained in an·EPA approved State Imptementation Plan. *This is a Summary Page forthis Class of'Source -'Permit Specific BACT Determinations on Next Page(s}

### San Joaquin Valley. Unified Air Pollution Control District Best Available Control Technology (BACT) Guideline 3.1.8* lastUpdate: 4/4/2002 Emergency Ga's-Fired 

### Ie .Engine
- > or 

### = 250 hp, Lean**~urn** Pollutant Achieved in.Practi,ce

## or contained in the SIP co = or < 2.75 g/bhp-hr (Lean burn natural gas fired engine, or'equal) Technologically Feasible 90% control efficiency (Oxidation catalyst, or equal) Alternate Basic Equipment
> qr= 800k control efficiency (Rich-burn engine with NSCR, or equal) NOx

. PM10

vae =or < 1.0 g/bhp-hr (Lean burn natural gas fired engine, or equal) Natural gas fuel

=or < 1.0 g/bhp-hr' (Lean burn natural gas fired engine, orequal) 90% control efficiency (Oxidation catalyst, or, equal), ' = or > 90% control

.efficiency (Rich-burn engine'with NSCR, or equal)

= or > 50% control effi'ciency'(Rich-burn**~ngine** with NSCR, or**eq~al)** 'BACT,is the most stringent control technique torthe emissions unit and class of source. Con'trol techniques that are not achieved in practice orcO'ntained ins a**stateitnple~entation** plan must be cost effective as weB as feasible. Economic,analysis todemonstrate cost
.**~ffectivenessis** requriedfor all determinations that are not achieved in practice orcontained in an EPA approved State Implementation Plan.

, ,***'~rhis** is'a Sutnmaty Pag.eforth'isClass of Source
- Permit Specific BACT Determinations on Next Page(s)

### San Joaquin 

### V'alley Unified 

### Ai'r Pollution Control District Best Available Control Technolqgy (BACT) Guideline 3.4.2* Last Update: 10(1/2002 ·Ga·s.Turbine
- 

### =or > 50 MW, Uniform Load, with Heat .Recovery Pollutant Achieved in Practice or**con.tain~d** ·in the**Sl~** Technologically Feasible Alternate Basic Equipment co

. NOx'

PMlO

SOx

VO'C' 6.0 ppmv @ 15% 02 (Oxidation catalyst, or equaf) 2.5 ppmvdry @ 15% 02 (1- hr. average, excluding startup and shutdown), (Selective catalytic reduction, or··equal) Air inlet filter cooler, lube oil' vent coalescer and natural gas '. fuel, orequal 1. PUC-regulated natural gas or 2. Non-PUe-regutated gas with no morethat 0.75

.grams 8/100'dscf, or equal. 2.0 ppmv @ 15% 02 4.0 ppmv @ 15% 02 (Oxidation catalyst, or equal) 2.0.ppmv dry @ 15% 02 (1-hr average, excluding startup and shutdown), (Selective catalytic reduction, or equal)

1.5 ppmv @ 15% 02

*'.* Applicability lowered to> 50 MW pursuant to CARB Guidance for Permitting Electrical Generation**Technologies~** Change effective 10/1/02. Corrected.error in applicabilityto read 50 MW not 50 MMBtu/hr effective 4/1**/O~.** BACT is the most stringent control technique for the emissions unit and class of source. Control techniques that are not achieved in practice orcontained in

### sa state implementation pla'n must be costeffective as well as feasible. Economic analysis to demonstrate cost effectiveness is requried for all determinations that are not achieved in practiceorcontained in an EPAapproved State Implementation PI.an. *This is a·Summary.pag·e forthis Class,of Source
- Permit Specific BACT Determinations on Next 'Page(s)



### '3.4-_-2

### AvenalPowerCenter, LLC(08-AFC-01) , SJVACPO Determination ofCompliance, C-1080386



## ATTACH'MENT F Top Down BACTAnalysis (C-395'3-10-0, -11-0, -12-0, -13-0, 

### and-14-0)

Attachment F - 1

### AvenalPowerCenter, LLC**(08-AFC~01)** SJVACPO Determination ofCompliance, C-1080386
Units C-3953-10-0 and

....11-0 (Turbines) I. ' NO

### xTop-Down BACTAnalysis Step 1 - Ide,ntifyAll Possible Control Technologies SJVAPCD BACT Clearinghouse Guide'line 3.4.2 identifies achieved in practice BACT as the following:

• 2.5 ppmvd 

### @ 15% O2 (1 hr average, excluding startup and shutdown), (Seleqtive catalytic reduction, orequal) SJVAPCD BACT Clearinghouse Guideline 3.4.2 identifies technologically feasible BACT as the following:

• 2.0 ppmvd @15% O2 (1 hr average, excluding startup and shutdown), (Selective catalytic reduction, orequal)' SJVAPCD BACT Clearinghouse Guideline 3.'4.2 does not identify any alternate basic equipment BACTcontrol**altern~tives.** ste,p 2 - Eliminate Technologically Infeasible Options AII'control options listed in step 1 are technologicallyfeasible. Step 3 - Rank Remaining Control Technologies ,by Control Effectiveness The following options are ranked based on theiremission factor: 1. 2.0 ppmvd 

### @ 15% O2 (1 hr average, excluding startup and shutdown), (Selective catalytic reduction, orequal) 2. 2.5 ppmvd @, 15%02 

### (1 hr average, excluding startup a,nd shutdown), (Selective catalytic reduction, orequal) Step 4 - Cost Effective Analysis A cost effective analysis must be peiiormed for all control 'options in the list from step 3 in the order of their ranking to**d~termine** the cost effective option with the lowest emissions. The applicant is proposing the use of a selective catalytic reduction system with NOx emissions of 2.0 ppmv 

### @ 15% 

### 02 (1 'hr average, excluding startup and shutdown), (Selective catalytic reduction, or equal). This is the highest ranking control option listed in Step -3 above. Therefore, in accordance with District policy APR 1305 (BACT), Section IX.D, a cost effective analysis is not necessaryand no furtherdiscussion is required.

Attachment F - 2AvenalPowerCenter, .LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386

. Step 5 - Select BACT BACTforthe emission unit is determined to be the use ofa Selective Catalytic Reduction system with emissions of less than or equal to 2.0 ppmvd 

### @ 

### 150/0 O2 

### (1 hr average, excluding startup and shutdown), (Selective catalytic reduction, or equal). The facility has

. proposed to use an inlet air filtration and cooling system, water.injection, and a Selective

.Catalytic Reduction system on each of these turbines to achieve

.NOx emission.s of less than or equal to 2.0 ppmv 

### @ 15% O2 (1 hr average, excluding startup and .shutdown), (Selective catalyticreduction, or equal). Therefore, BACT is**sati~fied.**

Attachment F - 3AvenalPowerCenter,.LLC (OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
Units C-3953-10-0 and -11-0 (Turbines) II. CO Top-Down BACTAnalysis Step 1 - IdentifyAll Possible Control Technologies SJVAPCD BACT Clearinghouse Guideline 3.4.2 identifies achieved in practice BACT as the following:
•. 6.0 ppmv @ 150/0 O2 (3-hour rolling average, exceptduring startup/shutdown) with**~n** Oxidation

.Catalyst and natural gas.fuel. SJVAPCD BACT Clearinghouse Guideline 3.4.2 identifies technologically feasible BACT as the following:

• 4.0 ppmv @ 15% O2 (3-hourrolling average, except during startup/shutdown) with an Oxidation Catalyst and natural gas fuel. SJVAPCD BACT Clearinghouse Guideline 3.4.2 does 'not identify any alternate basic equipment BACT control alternatives. Step 2 - Eliminate Technologically Infeasible Options All control options listed in step' 1 are technologicallyfeasible. Step 3 - Rank Remaining Control Technologies by Control Effectiveness The following options are ranked based on theiremission factor: 1

..4.0 ppmv @ 15% O2 (3-hour rolling average, except during startup/shutdown) with an Oxidation Catalyst and natural gas fuel. 2. 6.0 ppmv@ 15% O2 (3-hour rolling average, except during sta·rtup/shutdown) with an Oxidation Catalyst and natural.gas fue.1. Step'4
- Cost Effective Analysis A cost effective analysis must.be performed for all cO'ntrol options in the list from step 3 in the order of their ranking to determine the cost effective option with the lowest emissions. The applicant is proposing to limit CO .emissions to 2.0 ppmv @ 15%. O2 (3-hour averag'e, excluding startup and shutdown). This will be achieved with the use of·an oxidation catalyst and firing on**n~tural** gas. fuel. This is higherthan the highest ranking control option listed in Step 3 above. Therefore, in accordance with District policy APR 1305 (BACT), Section IX.O, a cost effective analysis is not necessary and- no further discussion is required.

Attach.ment F - 4AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386 Step 5 -Select BACT 

### BACT for the emission unit is determined

# to be limiting the CO emissions to 2.0ppmv 

### @ .15% O2 

### (3-hour average, .excluding startup and shutdown) using an oxidation catalyst and firing on natural gas fuel. The facility has proposed to use an oxidation catalyst and fire the units on natural gas, to assure these turbines achieve 

### CO emissions of less than or equal- to 2.0 ppmv 

### @ 

### 15°Jb 

### 02 (3-hour average, excluding startup' and shutdown). Therefore, BACT is satisfied.

Attachment F - 5Avena/PowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
Units 

### C-3953-10-0 and 

### -11-0 (Turbines) III. VOC Top-Down BACTAnalysis Step 1 - IdentifyAll Possible Control Technologies SJVAPCO BACT Clearinghouse Guideline 3.4.2 identifies achieved in practice BACT as the following:

• 2.0ppmvd

## vae @ 15% O2 SJVAPCO BACT Clearinghouse Guideline 3.4.2 identifies technologically feasible BACT asthe following:

• 1.5 ppmvd

## vae @ 150/0 O2' SJVAPCD BACT Clearinghouse Guideline' 3.4.2 does not identify any alternate basic equipment BACT control alternatives. Step 2 - Eliminate Technologically Infeasible Options All control options listed in step 1 are technologicallyfeasible. Step 3 - Rank Remaining Control Technologies**~y** Control Effectiveness· 1. 1.5 ppmvd

## vac @ 15% O2 2. 2.0 ppmvd

## vae @15% O2 Step 4 - Cost Effectiveness Analysis A cost effective analysis must be performed for all control option's in the list from step 3 in the order of their ranking to. determine the cost effective option with the lowest emissions. The applicant is proposing

## voe emissions of 1.4 ppmvd @ 15% 

### 02 when the unit is fired

,without the duct burner and 2.0 ppmvd @ 15% O2 when it is fired with the duct burner.

The BACT analysis that established the Technologically Feasible BACT option' of 1.5 ppmvd @ 15% O2 did not take into account emissions from a duct burner. Therefore the applicants proposed 1.4 ppmvd VOC @ 15% 

### 02 emission factorwill .be determ,ine to meet the highest ranking control option listed in Step 3 above. Therefore, in accordance with District policy APR 1305 (BACT), Section IX.O, a cost effective analysis is not necessary and no further discussion is required.

Attachment F - 6AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386 Step 5 - S.elect BACT BACT for the emission unit is determined to be the use of natural gas fuel or LPG with emissions of less than or equal to 2.0 ppmv @ 

### 150/0 O2. The facility has proposed to use natural gas fuel with emissions ,of less than or equal to 2.0 ppmv 

### .@ 

### 15°A> O2; therefore, BACT is satisfied.

Attachment F - 7

### AvenalPowerCenter, LLC(08-AFC-01) SJVACPO Determination ofCompliance, C-1080386
Units**C~3953-1** 0-0 and'-11-0 (Turbines) 

### IV. PM10 Top-Down BACTAnalysis Step 1 - IdentifyAll Possible Control.Tech·nologies General control for PM10 emissio.ns include the following options: 

### SJVAPCD BACT Clearinghouse Guideline 3.4.2 identifies achieved in practice BACT as the following:

• Air inletfilter, lube oil vent coalescerand natural'gas fuel orequal SJVAPCD BACT Clearinghouse Guid.eline 3.4

..2 does not identify anytechnologically feasible BACT control alternatives. SJVAPCD BACT Clearinghouse Guideline 3.4.2 does not identify any alternate basic equipment BACT control alternatives. Step 2 - Eliminate Technologically Infeasible Options 

### All ofthe listed controls are**cQnsider~d** 

### technologicallyfeasible forthis application. Step 3 - Rank Rema.ining Control Technologies by Control Effectiveness. 

### 1. Air inletfilter, lube oil vent coal'escer and natural gas fuel or equ.al Step 4 - Cost Effectiveness Analysis 

### A cost effective analysis must be**perform~.d** 

### for all control options i.n the list from step'3 in the order of the.ir ranking to determine the cost effective option with the lowest emissions. The applicant is proposing to use an air in inlet fi.lter, lube oil'vent coalescer and natural gas fuel or equal. This is the highest ranking control option listed in Step 3 above. -Therefore, in accordance with 'District policy APR 1305 (BACT), Section IX.D, a cost effective analysis is not necessaryan.d no furtherdiscussion is required. Step 5 - Select BACT 

### BACT for the emission unit is determined to be the use of an air inlet filter,. lube oil vent coalescer and natural gas fuel or equal. .Avenal Power Center is proposing to use an air inlet filter, lube oil vent coalescer and**n~tural** 

### gas fuel or**~qual;** 

### therefore, BACT .is satisfied.

.Attachment F - 8AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance,'

### C-1080386
Jnits C-3953-10-0 and -11-0 (Turbines) 

# v. SOxTop-Down BACTAnalysis Step 1 - IdentifyAll Possible CO.ntrol Technologies 

### SJVAPCD BACT Clearinghouse Guideline ·3.4.2 identifies achieved in practice BACT as the following:

• PUC-regulated natura·1 gas fuel; or • Non-PUC-regulated gas with no more than 0.75 grains 8/100 dscf, orequal SJVAPCD BACT Clearinghouse Guideline 3.4.2 does nqt identify any technologically feasible BACT control alternatives. SJVAPCD BACT Clearinghouse Guideline 3.4.2 does not identify any alternate basic equipment BACT control alternatives. Step 2 - Eliminate Technologically Infeasible Options 

### All ofthe listed controls are considered.technologicallyfeasible forthis application. Step 3 - Rank Remaining Control Technologies by Control Effectiveness 

### 1. PUC-regulated natural gas fuel 2. Non-PUC-regulated gas with no more than 0.75 grains S/10'0 dscf, orequal Step 4 - Cost Effectiveness Analysis 

### A cost effective analysis must be performed for all .control option's .in the list from step 3 in

.the order of their ranking to determine the cost effective option with the lowest emissions.

. The applicant is proposing to use PUC-regulated natural gas fuel. This is the highest ranking control option listed in Step 3 above. Therefore, in accordance with District policy APR 1305 (BACT), Section**IX~D,** 

### a cost effective analysis is not**neces~ary** 

### and no further discussion is required. Step 5 - Select BACT 

### BACT for the emission unit is determined to be the use of PUC-regulated natural gas fuel. Avenal Power**Cent~r** 

### has proposed to fire each of the turbines solely on PUCregulated natural gas fuel; therefore, BACT is satisfied.

Attachment F - 9AvenalPowerCenter, LLC(OB-AFC-01) 'SJVACPO Determination ofCompliance, C-1080386
Units C-3953-12-0 (Boiler) 

### I. NO

### xTop-DownBAC'TAnalysis Step 1 -, IdentifyAll Possible Control Technologies SJVAPCD BACT Clearinghouse Guideline 1.1.2 identifies achieved in practice BACT as the following:

• 9.0 ppmvd 

### @ 3% 

### 02 (0.0108 Ib/MMBtu) Ultra-Low NOx main burner system and a natural gas or LPG fired igniter system (ifthe igniter system is used to heatthe boilerat lowfire) SJVAPCD BACT Clearinghouse Guideline 1.1.2 identifies. technologically feasible BACT as the following:

• 9.0ppmvd 

### @ 3% 

### 02 (0.0108 Ib/MMBtu) Selective Catalytic Reduction, Low Temperature .Oxidizer, or equal and a < 30 ppmv NOx 

### @ 3% 

### 02 igniter system (ifthe ignitersystem is used to heatthe boilerat lowfire) SJVAPCD BACT Clearinghouse Guideline 1.1.2 does not identify any alternate basic equipment BACT control alternatives. Step'2- Eliminate 'Technologically Infeasible Options All control options listed in step 1 are techno'iogicallyfeasible. Step 3 - Rank Remaining Control Technologies by Control. Effectiveness .The following options are ranked based on theiremission factor: 1. 9.0 ppmvd 

### @ 3% 

### 02 (0.0108 Ib/MMBtu) Selective Catalytic Reduction, Low Temperature Oxidizer, or equal and a < 30 ppmv NOx 

### @ 3% 

### 02 igniter system (ifthe ignitersystem is use'd to heatthe boilerat lowfire) 

### 2. 9.0 ppmvd 

### @ 30/0 

### 02 (0.0108 Ib/MMBtu) Ultra-Low NOx main burner system and a natural gas or LPG fired igniter system (ifthe igniter system is used to heatthe boilerat lowfire) Step 4 - Cost Effective Analysis A cost effective analysis must be performed for all control options in the list from step 3 in the orde.rof their ranking to determine the cost effective option with the lowest emissions

.. The applicant has proposed the NOxemissions from the boilerwill not exceed 9.0 ppmv 

### @ 

### 3°Jb O2. This is the**~ighest.** ranking control option listed. in Step 3 above. Th'erefore, in accordance with District policyAPR 1305 (BACT), Section IX.D, a cost effective analysis is not necessaryand no furtherdiscussion is required. Attachment F - 10AvenalPower**Cente~** LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
Step 5 - Select BACT BACTforthe ·emission unit is determined to be NO

### xemissions of less than 9.0 ppmvd @. 3% O2. The facility has proposed NOx emissions of less than 9.0 ppmv 

### @ 

### 3°A> O2. Therefore, BACT is satisfied.

AttachmentF
- 11AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination 

### ofCompliance, C-1080386 ) 'Jnits**C-3953-12~O** .(Boiler) 

### II.. CO Top-Down BACTAnalysis Step 1 - IdentifyAll Possible C·ontroITechnologies· General control for CO emissions· include the following options: 

### SJVAPCD BACT Clearinghouse Guideline 1.1.2 identifies achieved in practice BACT as the following: ·.Natural gas fuel with LPG backup SJVAPCD BACT Clearinghouse Guideline 1.1.2 does not identify anytechnologically. feasible BACT control alternatives. SJVAPCD BACT Clearinghouse Guideline 1.1.2 does ·not identify any alternate basic equipment BACT control alternatives.

. Step 2 - Eliminate Technologi.cally Infeasible Options 

### AU ofthe listed controls are considered technologicallyfeasible forthis application. Step 3 - Rank Remaining Control Technologies by Control Effectiven.ess 

### 1. Natural gas fuel with LPG backup Step 4

.. Cost Effectiveness Analysis 

### A cost effective analysis must be performed for all control options in the list from step 3 in the order of their ranking to determine the cost effective option with the lowest emissions. The applicant is proposing to solely use naturai gas fuel. This is the highest ranking control option listed in Step 3· above.**Therefor~,** 

### in accordance with. District policy APR 1305 (BACT), Section IX.D, a cost effective analysis is not necessary and no further discussion is required. ·Step 5 - Select BACT 

### BACT· for the emission unit is determined to be the use of natural· gas fuel. Avenal Power Center is proposing to use natural gas fuel; therefore, BACT is satisfied.

Atta.chment F - 12AvenalP.owerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
Units C-3953-12-0 (Boiler) III. 

## vac Top-Down BACTAnalysis Step 1 - IdentifyAll Possible Control Technologies

.General control for

## vac em·issions include the following options: 

### SJVAPCD BACT Clearinghouse Guideline 1.1.2 identifies achieved in practice BACT as the following:

• Natural gasfuel with LPG backup SJVAPCD BACT Clearinghouse Guideline 1.1.2 does not identify anytechnologically feasible BACT control alternatives. SJVAPCD BACT Clearinghouse Guideline 1.1.2 does not identify any alternate basic equipment BACT control alternatives. Step 2 -Eliminate Technologically Infeasible Options 

### All.ofthe listed controls· are considered technologicallyfeasible forthis application. Step 3 -. Rank Remaining Control Technologies by Control Effectiveness 

### 1. Natural gas fuel with LPG backup Step 4 -Cost Effectiveness Analysis 

### A cost effective analysis mustbe performed for all control options in the list from step 3 in the order of· their ranking to determine the.cost effective option with the lowest emissions. The applicant is proposing to solely use natural gas fuel. This is the highest ranking control option listed in Step 3 above. Therefore, in accordance with District policy APR 1305 (BACT), Section IX.D, a cost effective a·nalysis is not necessary and no further discussion is required.

.

.Step 5 -.Select BACT



### BACT for the emission unit is determined to be the use of natural gas fuel. Avenal Power Center is proposing. to use natural gas fuel; therefore, BACT is satisfied.

Attachment.F
- 13AvenalPowerCenter, LLC'(OB-AFC-01) SJVACPO Determination ofCompliance,C-1080386
'Units C-3953-12-0 (Boiler) 

### IV. PM10 Top-Down BACTAnalysis Step 1 - IdentifyAll Possible Control Technologies General control for PM10 emissions include the following options: 

### SJVAPCD BACT Clearinghouse Guideline 1.1.2 identifies achieved in practice BACT as the following:

• Natural gasfuel with LPG backup SJVAPCD BACT Clearinghouse Guideline 1.1.2 does not identify anytechnologically feasible BACT control alternatives. SJVAPCD BACT 'Clearinghouse Guideline 1.1.2 does not identify a'ny alternate bas'ic equipment BACT control alternatives. 'Step 2 - Eliminate Technologically Infeasible Options 

### All ofthe listed controls are considered**technologi~ally** 

### feasible forthis application. Step 3 - Rank Remaining Control Technologies by Control Effectiveness

. 

### 1. Natural gas fuel with LPG backup Step 4 - Cost Effectivenes.s Analysis 

### A cost effective analysis must be performed for all control options in the list from step 3 in the order of their ranking to determine the cost effe'ctive option with the 'Iowest emissions. The applicant is proposing to solely use natural gas fuel. This is the highest ranking control option listed in Step 3 above. Therefore, in accordance with District policy APR 

### 1305 (BACT), Section IX.D, a cost effective analysis is not. necessary and no further discussion is required. Step 5 - Select BACT 

### BACT for the emission unit is**determi~ed** 

### to be the use of natural gas fuel. Avenal

.Power Center is proposing to use natural gas fuel; therefore, BACT is satisfied.

. Attachment F - 14AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
Units C-3953-13-0 (Diesel IC engine powering fire water pump) 

### I.· NO

### xTop-Down BACTAnalysis Step 1 - IdentifyAll Possible Control Technol.ogies SJVAPCD BACT Clearinghouse Guideline 3.1.4 identifies achieved in practice BACT as the following:

• Certified NOxemissions of6.9.g/bhp-hror less SJVAPCD BACT Clearinghouse Guideline 3.1.4 does not identify any technologically feasible BACT control alternatives. SJVAPCD BACT. Clearinghouse Guideline 3.1.4 does not identify any alternate basic

.. equipment BACT control alternatives.

Step 2 - Eliminate Technologically Infeasible Options All control options listed in step 

### 1 are technologicallyfeasible. Step 3 - Rank Remaining Control Technologies by Control Effectiveness The following options are ranked based on**~heir** emission factor: 1. Certified NOx emissions of6.9·g/bhp-hror less Step 4 - Cost Effective Analysis A cost ·effective analysis must be performed for all contr91 options in the list from step 3 in the order. of their ranking to determine the cost effective option with the lowest emissions. Th·e applicant has proposed the NOx emissions from the engine will not exceed 3.4 g/bhphr. This is the highest ranking control option listed in Step 3 above. Therefore,**i~** accordance with District policyAPR 1305 (BACT), Section IX.D, a cost effective analysis js not necessary and no furtherdiscussion is required. Step 5 - Select BACT BACT for the emission unitis determined to be CertifiedNOx emissions of 6.9.g/bhp-hr or less. The facility has proposed NOx emissions of less than 6.9 g/bhp-hr. Therefore,. BACT· is satisfied.

Attachment F - 15

### AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
Units C-39S3-13-0 (Diesel IC engine powering fire water pump) 

### II. CO Top-Down BACTAna'lysis Step 1 - IdentifyAll Possible Control Technologies .SJVAPCD BACT Clearinghouse Guideline 3.1.4 does not identify.any achieved in practice BACT control alternatives. SJVAPCD BACT' Clearinghouse Guideline 3.1.4 identifies technologically feasible BACT as the following:

• Oxidation Catalyst· SJVAPCDBACT Clearinghouse Guideline 3.1.4 does not
.. identify any alternate basic
l equipment BACT control alternatives. Step 2 - Eliminate Technologically Infeasible Options AII:control options listed in step 1 are technologicallyfeasible

.

. ·Step.3
- Rank Remaining Control Technologies'by Control Effectiveness

The foll.owing options are ranked based on theircontrol efficiency: ·1. Oxidation Catalyst Step 4 - Cost Effective Analysis A cost effective analysis must be performed for all control options in the list from Step 3 in the order of their ranking to determine the cost effective option with the lowest emissions. However, this engine has been UL Certified, and the ULcertification does not include a oxidation catalyst, and the addition of a oxidation catalyst would void the UL certification, which is required forfirewater pump engines. Therefore, the oxidation catalyst oA>ption will not be required.

. Step'S -'Select BACT BACT for the emission unit is satisfied bythe facility's proposeq CO emissions of 0.447 g/bhp-hr. Therefore, BACT is. satisfied.

Attachment F - 16AvenalPowerCenter, LLC(OB-AFC-01) SJVACPD Determination of**Complian~e,** C-10B0386
Units C-3953-13-0 (DiesellC engine powering fire water pump) III. VOC Top-Down BACT'Analysis Step 1 - IdentifyAll Possible Control Technologies SJVAPCD BACT Clearinghouse Guideline 3.1.4 identifies achieved in practice BACT as the following:

• Positive crankcase ventilation [unless it voids the Underwriters Laboratories (UL) certification] SJVAPCD BACT Clearinghouse Guideline 3.1.4 identifies technologically feasible BACT as the following:

• Catalytic Oxidation SJVAPCD BACT Clearinghouse Guideline 3.1.4 does not identify any alternate basic equipment BACT control alternatives. Step 2 - Eliminate Technologically Infeasible Options All control options listed in step 1 are technologicallyfeasible. Step 3 - Rank Rem'a,ining Control Technolo'gies by Control, Effectiveness The following options are ranked, based on theircontrol efficiency: 1. Catalytic Oxidation 2. Pos,itive crankcase ventilation [unless it vOids the Underwriters Laboratories (UL) certification] Step 4 - Cost Effective Analysis A cost effective analysis must be performed for all control options in the listfrom Step 3 in the order of their ranking to determine the cost effective option with the lowest emissions. However, this engine has been UL Certified, and the UL certification does not include a catalytic oxidation system or a positive crankcase ventilation system, and the addition of a catalytic oxidation system or a positive crankcase ventilation system Would void the UL certification, which is required for firewater pump engines. Therefore, both the catalytic 'oxidation**sy~tem** and the positive crankcase ventilation system options will not be

required.

Attachment F - 17

### AvenalPowerCenter,LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
Step 5 - Select BACT BACT for vac emissions from this emergency diesel .IC engine powering a firewater pump is·having no control technology forvae emissions. The applicant has proposed to install a 288 bhp emergency diese·1 IC engine powering 

### afirewater pump with no control technologyforvac emissions; thetefore BACT**forV~e** emiss·ions is satisfied.

Atta·chment F - 18

### AvenalPowerCenter, LLC(08-AFC-01) SJVACPO Determination ofCompliance, C-1080386
Units C-3953-14-0 (Natural gas Ie engine powering electrical generator) I. NOx**T'op-Dow~** BACTAnalysis Step 1 - IdentifyAll Possible Contro'l Technolog'ies SJVAPCD·BACT Clearinghouse Guideline 3.1.8 identifies achieved in practice BACT as the following:

• NO

### xemissions of 1.0 g/bhp-hr (lean-burn n.atural gas fired engine orequal) SJVAPCD BACT Clearinghouse Guideline 3.1.8 does not identify any tec·hnologically feasible BACT control alternatives

.

.SJVAPCD BACT Clearinghouse' Guideline.3.1.8 identifies alternate basic equipment BACT as the following:

• 2:: 90% control efficiency (rich-burn engine w·ith NSCR orequal) Step 2 - Eliminate Technologically Infeasible Options All control options listed in step 1 are technologicallyfeasible. Step 3 - Rank Remaining Control Technologies .byControl Effectiveness The following options are ranked based on their control efficiency: 1. 2:: 90% control efficiency (rich-burn engine with NSCR orequal) 2. NOx emissions of 1.0 g/bhp-hr (lean-burn natural gas fired engine orequal) Step 4 - Cost Effective Analysis A cost effective analysis must be performed for all control options i·n the list from step 3 in the order of their ranking to determine the cost effecti've option with the lowest emissions. 1. 90% cO,ntrol efficiency (rich-burn engine w·ith NSCR orequal) District Policy establishes annual cost thresholds for imposed control based upon the amount of pollutants abated by the controls. If the cost of control ·is at or below the threshold, it is considered a cost effective control. Ifthe cost exceeds the threshold, it is not cost effective and the control is not required. PerDistrict BACT Policy, the maximum cost limitfor NO

### xreduction is '$9,700 perton of NO

### x reduced.

Attachment F'
- 19AvenalPowerCenter, LLC (OB-AFC-01)

. SJVACPO Determination ofCompliance, C-1080386
Based 'upon the fact that there are only a few existing Ie engine installations within this class and category of source that operate with emissions of 1.0 g**NOx/hp~hr,** the

.

. .District will assume that the Industry Standard will be 2.8 g NOx/hp-hr. (lb/MMBtu

converted tog/hp-hr, Attachment I), pursuant to a AP-42 (07/00) values of uncontrolled four-stroke lean burn Ie engines 

### « 90% load). AP-42 publishes an uncontrolled NOx value of 2.21 Ib/MMBtu (90
- 1'05% load), which is approximately 13.4 g NOx/hp-hr. Several major engine manufacturers were surveyed (Cummins, Caterpillar, and Waukesha) and the District found that lean burn engines sold bythese engine manufacturers do not emit emissions close to the uncontrolled value for 90

- 105% load, published in AP-42. Based on the disc.ussions with service representatives ofeach engine manufacturer, emissions were closerto the AP-42 value published forthe < 90% load, which was around 2.5 g NOx/hp-hrthan itwas for the value published forthe 90

- 105% load. Therefore, industry standard for lean burn natural gas-fired emergency IC engine will be 2.8 g NO·x/hp-hr.

.The proposed annual emissions from a lean burn ICengine using industry standard values

can be calculated as: 

### !iQx (annual):

### ~2~._8~9~~_·8~6_0·_~~~~lb~~~50_.~~.~_**2651bNOJ~ar Rp-~**  1 453.6-9 year 

### PENo x

# =265 Ib NOx/year

# =O. 1325.tons NOx/year The proposed annual emissions from a rich burn engine equipped the a Non-Selective Catalytic Reduction system with a NOx control effici.ency of 90% can be calculated as: 

## tillx (annual):

. 7.4 9 (1) I (1
- 0.9) I 860 I . Ib I 50 

### Rp-Rf 

### 1 1 453.6i}··
.year· 

# = 70 Ib NOx/year

. 

### PENo x= 70 Ib NOx/year= 0.035 tons NOx/year' District BACT policy demonstrates how to calculate the cost effectiveness of alternate basic equipment or process: CEalt 

### = (COStalt- Costbasic) + (Emissionbasic- Emissionalt)

1 Pursuanfto AP-42 (07/00) the NOxvalue for.uncontrolled four-stroke rich burn Ie**engine~** @ < 900/0 load. (lb/MMBtu converted·to g/hp-hr, Attachment I) Attachment 

### F"- 20Avena/PowerCenter, LLC(OB-AFC-01) SJVACPD Determination,ofCompliance, C-1080386 where, CEalt**Co~talt** = the cost effectiveness of alternate basic equipment expressed as dollars per ton ofemissions reduced

= the equivalent annual capital cost of the alternate basic equ'ipment plus its annual operating cost COstbasic = the equivalent annual capital cost of the proposed basic equipment, without BACT, plus its annual operating cost Emissionbasic= the emissions from the proposed basic equipment, without BACT. Emissionalt = the emissions from the alternate basic equipment The District conducted research to determine the appropriate cost information for installing a rich burn 

## Ie engine with a Non-Selective Catalytic Reduction System versus the cost information for installing a uncontrolled lean burn IC engine. Based on' information' from various engine manufacturers, the**i~itial** costs for installing an**un~ontrolled** rich burn engine versus an uncontrolled lean burn engine would be minimal. The main difference in cost would be incurred in the installation of the NSCR system and the airto fuel ratio controllerto the rich burn IC engine. According to the guidance document "RACT/BARCT for Stationary Spark-Ignited 

### 10 Engines" (pgs. V-2 

### &V-3), the approximate capital, cost for installing a NSCR system for a 1;000 hpengine would be approximately $28,000, the capital cost for installing an air to fuel ratio controllerwould be $5,300" and the overall installation costwould be $2,500. The CARB RACT/BARCT document also states the annual cost for operating and maintenance is between $8,000
- 10,000, but these values are assuming full time operation. Sincethe

, , ,proposed installation will be limited only to emergency operation and testing and maintenance, a conservative assumption of $1 ,000 per,**y~ar** will be utilized for this evaluation. ' Per District BACT Policy, the equivalent annual capital cost is calculated as follows: A ($/yr) 

# = P x [i x (1 + i)"] + [(1 + i)"
- 1] A = P = 

### i = n = Using a total capital cost of $35,800 in the above equation results in an equivalent 'annual cost of $5,826/year. Adding this equivalent annual cost to the annual operating cost of $1 ,ODD/year, the (CoStalt - Costbasic) is equal to $6,826/year. It should be noted that the operating the rich burn 

## IG engine versus a lean burn IC engine would result in an efficiency loss and would potentially result in higher ann.ual fuel expenses. These costs will be set aside forthe presentand only a partial'cost analysis will be performed. Attachment F - 21AvenalPowerCenter, LLC (OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386

District BACT policy also requires the use of a Multi-Pollutant Cost Effectiveness Threshold' (MCET) fora BACT option controlling more than one pollutant.· The installation of a NSCR system will control NO

### x, CO, and

## vac emissions. ,Therefore, the MCET is calculated as follows: MCET ($/yr) 

# = (ENox

### xTNOx) + (Eeo 

### xTeo) + (Evoe 

### xTvoe) Where: ENox 

### = tons-NO

### xcontrolled/yr Eeo 

# = tons-CO controlled/yr Evoe

# = tons-VQC controlled/yr TNOx 

### = District's cost effectiveness threshold for NOx 

# = $9,700Iton-NOx Teo 

# = District's cost effectiveness threshold for CO


### = $300/ton-CO. Tvae

# = District's cost effectiveness threshold forVOCs $5,OOO/ton-VOCs Since this BACT cost effectiveness analysis is analyzing alternate basic equipment with a control technology which controls multiple pollutants; in order to calculate the cost effectiveness for the alternate basic equipment, the District will take the MCET and compare that value with the (Costalt - CoStbasic), to determine ifthis control tech'nology is cost effective. To determine Eeo, the District has to establish what Industry**~tandard** is for CO emissions. As detailed above, engines with NOx emissions of 2.8 g/hp-hr(per AP-42) were deemed as the industry standard for this class and category of source.**Th~refore,** the District will also take AP-42 values for CO emissions 

### @ < 900/0 load (1.83 g CO/hphr) and deem that value as industry standard forthis class and category ofsource. Therefore, the proposed annual emissions from a lean burn**·I~** engine using industry standard values can be calculated as: CO (a·nnual):

## ~1_.8_3~.9~~I_._86_0_~~.~~_lb~~~50_~~.~_**173IbCO~~r** hp-hf

. 1 453.6-9 year ' , PEeo

# =173 Ib CO/year

# =0.0865 ton CO/year Pursuant to the guidance document "RACT/BARCT for Stationary Spark-Ignited IC Engines" created by CARB (pg. 8-20), the CO control effectiveness from 

### a NSCR system is greater than 80%. Therefore, the proposed 'annual emissions from a rich burn engine equipped the a Non-Selective Catalytic Reduction system with a CO

.control efficiency of 800 

### k can be calculated as:

Attachment F - 22

.AvenalPowerCenter, LLC(OB-AFC-01) SJVACPD Determination ofCo.mpliance, C-1080386

CO (annual):

11.6,

### ,9 ,(2), I (1 -,. 0.8) I 860!!i3 I Ib I 50,Af

Rp-fH: 

### 1 1. 453.6-{}··· 

### year - 220 IbCO/year PEco= 220Ib CO/year= O. 

### 11 ton CO/year As demonstrated above, the CO emissions from the rich burn IC**e~gine** with a NSCR system are higher than the uncontrolled CO emissions from the lean burn IC engine. Therefore, CO will not be included in the MCET calculations. To determine Evoc', the District has to establish what Industry Standard is for VOC

. emissions. Again, as detailed above, engines with NO

### x emissions of·2.8 g/hp-hr (per

AP-42) were deemed as the industry standard for this class and category of source. Therefore, the District will also take AP-42 values for

## voe emissions (0.39 g VQC/hp-hr) and deem thatvalue as industry standard forthis class and category ofsource. Th.erefore, the proposed annual emissions from a· lean burn IC engine using industry standard values can be calculated as: 'VOC (annual):

### ~.0_.3_9~i_,**~1~~_0~!!i3~,'~~lb~~~5_0_Af~_ 37lbVOC~ear**  Rp-hf 1 453.6iJ year PEvoc= 

### 37 Ib VOG/year= 0.0185 ton VaC/year Pursuant to the guidance document "RACT/BARCT for Stationary**Spark~lgriited** IC Engines" created by CARB, the VOC control effectiveness from a NSCR system is greater than 50%. Therefore, the proposed annual emissions from a rich burn engine equipped the a Non-Selective Catalytic Reduction system with a

## vac control efficiency of 50% can be calculated as: VOC (annual):

0.10

### 9 (3) 

### 1,(1,
- 0.5) I 860!!i3 I Ib 

### 1 50 hf



### Rp-lH: 1 1· 453.6-{}· 

### year - 5 

### Ib VOC/year PEvoc= 51b VaG/year

# =0.0025 ton

# vaC/year,

2**P~rsuant** to AP-42 (07/00) the CO value for uncontrolled four-stroke rich burn IC engines @ <'90°J'o load. (lb/MMBtu converted to g/hp-hr" Attachment I)

. 3 Pursuant to AP-42 (07/00) the voe value for uncontrolled four-stroke rich burn IC engines. '(ib/MMBtu converted to g/hp-hr, Attachment I) Attachment F -23AvenalPowerCenter, LLC(OB-AFC-01) SJVACPD Determination ofCompliance, C-10B0386 Calculating forthe MCET derivesthe following: ENOx 

# =0.1325 tpy- 0.035 tpy 

### = 0.0975· tpy Evoc 

# =0.0185 tpy- 0.0025 tpy

# =0.016tpy MCET ($/yr)

# = (0.0975 x $9,700) 

### + (0.016 x·$5,OOO)

# =$1 ,026/year As presented above, (Costalt - Costbasic) is equal to $6,826/year. This value is greaterthan the MCET; therefore, it has been determine that the installation of a rich burn IC engine with a NSCR system as alternate basic equipment is not cost effective using justthe partial cost analysis. 2. NOx emissions of S 1.0 g/bhp-hr (lean-burn natural gas fired engine orequal) The applicant has proposed that the NOx emissions from the engine will not exceed 1.0 g/bhp-hr. This is the highest ranking remaining control option listed in Step 3 above. Therefore, in accordance with District policy APR 1305 (BACT), S'ection IX.D, a cost effective analysis is not necessary and no furtherdiscussion is required. Step 5 - Select BACT BACT for the emission unit is determined to be NOx emissions of 1.0 g/bhp-hr or less. The facility has.pro·posed NOx emissions of less than '1.0 g/bhp-hr. Therefore, BACT is satisfied.

Attachment F - 24AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386
Units C-3953-14-0 (Natural gas IC engine powering electrical gener-ator) II. .CO Top-Down BACTAnalysis Step 1 - Ide.ntifyAll Possible Control Technologies SJVAPCD BACT Clearinghouse Guideline 3.1.8 identifies achieved in practice BACT as the following: (

• S 2.75 g/bhp-hr (Lean burn natural gas fired engine, orequal) SJVAPCD BACT Clearinghouse Guideline 3.1.8 identifies te-chnologically feasible BACT as the following:

• 90% control efficiency (Oxidation catalyst, orequal) SJVAPCD BACT Cleari.nghouse Guideline 3.1.8 identifies alternate basic equipment BACT as the following:

• '800/0 CO control efficiency catalyst (ri'ch-burn engine with NSCR orequal) Step 2 Eliminate Technol,?gically Infeasible Options All control options·listed in step 1 are technologicallyfeasible. Step 3 -Rank Remaining Control Technologies by Control. Effectiveness The following options are ranked based on theircontrol efficiency: 1. 90% control efficiency (Oxidation catalyst, orequal) -2. 800/0 CO control efficiency catalyst (rich-burn engine with NSCR orequal)**3~** S 2.75 g/bhp-hr (Lean burn natural gas fired engine, or equal) Step 4 - Cost Effective Analysis A cost effective analysis must be performed for all control options in the list from step 3 in the order of their ranking to determine the cost effective option with the lowest .emissions. The applicant has proposed the engine will be equipped with an oxidation catalyst that will provide 900/0 control ofCO emissions. This is the highest 'ranking control option listed in Step 

### 3 above. Therefore, in accordance with District policy APR 

### 1305 (BACT), Section IX.O, a cost effective analysis is not necessary and no furtherdiscussion is required.

Attachment 

### F- 25AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386 Step··5 - Select BACT 

### BACT for the emission unit is determined to be the used of**a~** 

### oxidation catalyst with 

### 900 

### /b· control of CO emissions. The facility ha·s proposed to install an·oxidation .catalyst with 

### 900/0 control of CO emissions. Therefore, BACT is satisfied.

Attachment F - 26AvenalPowerCenter, LLC.(OB-AFC-01) SJVACPD Determination ofCompliance, C-1080386
Units· C-3953-14-0 (Natural gas IC engine powering e·lectrical generator) III. 

## vac Top-Down BACTAnalysis Step 1 - IdentifyAll. Possible Control Technologies SJVAPCD BACT Clearinghouse Guideline 3.1.8 identifies achieved in practice BACT as the following:

• 1.0g/bhp-hr(Lean burn natural gas fired engine, orequal) SJVAPCD BACT Clearinghouse Guideline 3.1.8 identifies technologically feasible BACT as the following:

• 90% control efficiency (Oxidation catalyst, orequal) SJVAPCD BACT Clearinghouse Guideline 3.1.8 identifies alternate basic equipment BACT as the following:

• 50% control efficiency catalyst (rich-burn engine'with NSCR orequal) Step 2 -Eliminate Technologically Infeasible Options ,All control options listed in step 1 are technologicallyfeasible. Step 3 - Rank Remaining Control Technologies by Control Effectiveness The·following options are ranked based on theircontrol efficiency: 1. 90% control efficiency (Oxidation catalyst, orequal) 2. 500/0 control efficiency catalyst (rich-burn engine with NSCRorequal) 3. 1.0 g/bhp-hr (Lean burn natural gas fired engine, orequal) Step 4 - Cost Effective Analysis ·A costeffective analysis must be performed for all control options in the list from step 3 in the order of their ranking to· determine the 'cost' effective option with the lowest emissions. The a,pplicanthas proposed the engine will be equipped with an oxidation catalyst with 90% control of VOC emissions. This is the highest ranking control option listed in Step 3 above. Therefore, in accordance with, District policy APR 1305 (BACT), Section IX.D, a cost effective analysis ,is not necessaryand no furtherdiscussion is required.

Attachment F - 27

### Avenal**Pow~r** 

### Center, LLC(08-AFC-01) SJVA.CPD Determination ofCompliance, C-1'080386' Step 5 - Select BACT BACT for the emission unit is determined to be the used of an oxidation catalyst with

. 

### 90% control of

## vac emissions. The facility has proposed to install an oxidation catalyst with 

### 900/0 control ofVOCemission. Therefore,BACT is satisfied.

Attachment F - 28

### AvenalPowerCenter, LLC(OB-AFC-01) SJVACPD Determination ofCompliance, C-1080386



# ATTACHMENT G Health RiskAssessment-andAmbientAirQualityAnalysis

Attachment G - 1To: From: Date: 

## San JO(3:QuinVaUeY'Air POII!UUQIil 

## Control District Risk Management·Review
Derek. Fukuda

.Matthew Cegielski
- Technical Services A.pc-if 28,2008 Facility Name: Location: Application #(s): Project#:



### .**A~** RMR SUMMARY Avenal Power Center Avenal Cutoff Road and San· Luis Canal,**Aven~l,** CA C-3953 10-0,'11-0, 12-0,.13-0, 14-0 (;-1080386

Project' ,Facility Totals Totals Gategories
Prioritization Sco're 'Acute·Hazard In'dex C·hronic·Hazard**Ind~x** " Maximum Individual Ca,ncer,Risk(1**O~6)** T-BACT'Re '**~ir~d?** Special Permit, Conditions? 10-0 CT#1

0.6 0.0
.

, 0.0 0.02 ,No No . 11-0 CT#2

0.6· 0.0 0.0 0.02

No No**12~O** NGAux

Boiler'

0.0 0.0 

### 0.0 0.01

No. No , 13-0 DICE Eme'g

F.ire Pump

NA 'N/A'**N/A~** 0.01

Yes 14-0 NGICE Emeg Gen 0.1 0.2 0.0 0.0

, No 1.3**O~2** 0.0 0.1 1'.3 0.2 '

0.1

1 Prioritizatibn forthis unitwas notconducted s,ince it-has been determined that alldiesel-fired ic**~ngines** will ' result in a prioritization score greaterthan**1.0~** . 2 Acute and Chronic Hazard Indices were notcalculated since there is not riskfactorortheriskfactorisso lowthat ithas been determined to be insignificantforthis type ofunit.

.Proposed Permit Conditions To,ensure that human health risks ,will not exceed District'allowable levels; the following permit conditions must be included for:

. Units 10-0,'11-0,**12~O,** 14-0 N'o**speci~1** conditions required

.. 'Units'13-0 1. The PM10 emission,S rate shall not exceed 0.1'5 g/hp-hr based on' US E.PA certification using ISO 8178 test procedure. [District Rules 2201 and 4102' and 13CCR 2423 and 17 CCR 9311,5]Avenal PowerCenter, C3953, 1080386 Page 2of4 2. {18gB} The exhaust stack .shall vent vertically upward. The vertical exhaust flow shall not be impeded by a rain cap, roof**ov~rhang,orany** other obstruction. [District Rule 4102] N 3. Th.e engine shaH be operated only for 'maintenance, testing,**~nd** required regulatory purposes,and during emergency situations. Operation of**t~e** engine for**maintena~ce,** testing,. and required regulatory' purposes shall not exceed 50 hours per year. [District Rules 2201, and 4702 and 17 CCR 93115.] N 

### B. RMR REPORT I. Project Description Technical Services received a request on April 28, 2008 to perform' a Risk Management Review for'a proposed installation ofa 600 MW. Power Plant. ',11. Analysis Technical Services performed a**prioritizationu~ing** the District's HEARTs.**d~tabase.** Siflce the total facility prioritization score was greater than one, a rE?fined health risk assessment

.·was required. Emissions calculations were calculated for the units as referenced in'the following table. Unit Source Reference Co.mbustion Turbine**tO~O.** HEARTS NG Turbine VCAPCD 'Co'mbustion.Turbi·ne1"1-0 HEARTS.**N~** Turbine VCAPCD HEARTS NG.10-100 NG Auxiliary Boiler**12~O** MMS'TU/Hr External VCAPCD Combustio"tl NG Emergency ICE 14,-0 HEARTS NG Internal VCAPCD Combustion'<1 OOOHP The A·ERMOD model'was used, with the parameters outlined below and meteorological data .' for 2004'frdm Fresno to determine the dispersion'factors (Le.; the predicted' concentration or

X divided by the normalized source' strength or Q) for' a' receptor grid. These dispers.iori factors were input into the Hot Spots Analysis and Reporting Program (HARPY risk assessment mod'ule to' calculate the chronic and acute hazard indices and the carcinog.enic riskfor the project.

. . The following parameters were used forthe review: Analysis Parainete'rs

. Combustion Turbines.' Unit 10-0,11-0 Source Type Stack Height(m) Stack Diameter. (m) .Stack Exit Velocity (m/s) Point Location Type 44.2

. Closest**R~ceptor** (m) 5.78 Type ofReceptor 19.3 Max Hours perYear: ···Rural 1202 Residential 8760 Stack ExitTemp'. (OK) Burner Rating (MMBtu/hr) NGAvenal Power Center, C3953, 1080386 Page 3 of4
Analys'is Parameters NG Auxiliary

..Boiler 12-0 Source Type' sta'ck Height (m) Stack Diameter. (m) Point Location Type 11.3 Closest Receptor (m)

. 0.81 Type of Receptor Rural 1202 Residence Stack Exit Velocity (m/s)

Stack ExitTemp. (OK) 37.4

.Source Type Stack Height (m) Analysis Parameters Diesell'CE Emer enc Fire,P.ump**13~O** Point location·Type 5.49 Closest Receptorem) Rural

. 1202 Stack Diameter. (m) Stack**Ex~tVelocity** (m/s) 0.15' Type ofReceptor" ' 42.2 PM 10 g/hp.-hr

. Residence 0.15 Stack Exit Temp,;**(O~)** Ma'xHours perYear 288



### .**~o~rce** Type Stack Height (m)**Stac~ Diarneter~**  (m) An,alysis ·Parameters NG ,Emer eiic IC'E .Unit14-0.· Point, ,Location Type , 3.05 Closest Receptor,(m)

.. 0.2 Type of Receptor "Rural 1202**R~sidence** Stack Exi't Velocity (m/s)

Stack Exit·Temp. (OK) 71.3 698 Throughput

. (MMBTUI 'r) BHP. ' 355 860 Max Hours perYear AAQA

.. In addition to' the, RMR, Technical Services performed an Ambient Air Quality Analysis (AAQA) on. the proje'ct. Emissions are listed in the table below, ·for concentratiorls referto the AAQA modeling profile.

Stacks 1 and 2 Stack 5 U.nit 14 Unit 10 and 11 Stack 3 U'nit 12 Stack4 Unit 13 NGEmergency Ibs/hr EachCTs 

### Aux Boiler DiesefFire. Pump , Generator NOx 16.4 0.41 2.16 1.9 CO' 72.8 ' 1.38 0.28 1.14' PM10 9.2 0.19 0.04 0.06 SOx 1.9 0.11 0.0 0.02"Avenal Power Center, C3953, 1080386 Page 40f4
Emergency Ibs/yr Each CTs Aux Boiler Diesel Fire Pump Generator hours!yr 8760 1251 50
. 50

NOx 143,95.1 513 108 95 CO 637,788 1727 14 57 PM10 80,656 233 2· 3 SOx 16,694· 132 0 1 Criteria Pollutant Modeling Results*



## co
PM10 X.

. X *Resultswete taken from the**~ttached** PSO·spreadsheet.

. .. 1The predicted ambientair.<ll,ialityimpaGts.forthese criteria pollutants are below EPA 9s level ofsignificance as found ·in 40 CFRPatt51.16S·(b)(2).**Th~** acute and chronicin'di·ces are below 1.0 and the .cancer risk factor associated with each un·it· is less than 1.0 .in a million. In accordance with the District's ·RiskManag·ement Policy, the project i.s. approved without Toxic Best Available Control Te.chn<;>log·y(TBACT). The emissions from theproposedeq·uipment will not cause or contribute significantly to a . violation ofthe State and National AAQS.

. :To ensure that hu·man health risks will not exceed District allowable

.levels; the permit**co~ditions** listed on page 1 ·ofthis report must·be**inclu~~led** fai'th.is ·proposed unit. These conclusions are based on the·. data· provided by the applicant and the project engineer.**The~efo(eJ** this analysis is valid only as long as the proposed data and parameters do not change.

Attachments: A. H·ARP outputfiles &AERMOD dispersion map B. Prioritization sCOre with toxic**em~ssions** summary" AAQA C. RMR requestfram·the project engineer·

.AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination 

### ofCompliance, C-10$0386



# ATTACHMENT H SOxforPM10 

### Interpollutant OffsetAnalysis

Attachment H - 1

## SOXfor PM 10 

## Interpollutant OffsetAnalysis Avenal Power Center, LLC Date: June 12, 2008 Engineer: Derek. Fukuda Lead Engineer: Joven Refuerzo Facility Name: Mailing Address: Contact Person: Telephone: Application 

### #: Project

### #: Location: Complete:
I. Proposal 

### Avenal Power Center, .LLC 500 Dallas Street. Level 31 Houston, TX 77002 Jim Rexroad (713) 275-6147 C-3953-10-0, -11-0, -12-0, -13-0, and -14-0 C-1080386 NE% Section 19, Township 21 South, Range 18 East
- Mount Di.ablo Base Meridian on Assessor's Parcel Number36-170-032 June 12, 2008

Avenal Power Center, LLC is seeking approval from the S,an Joaquin Valley Air Polluti.on Control District (the "District") for the installatio'n of a "merchant" electrical power generation facility (Avenal Energy ProJect). The Avenal Energy Project will bea combined-cycle power'generation facilityconsi.sting oftwo' natural gas-fired combustion turbine generators (CTGs) each with a heat recovery steam generator (HRSG) and 'a 5·62.3MMBtu/hr duct burner. Also proposed ·are a 300

..MW steam turbine, a 37.4 MMBtu/hr auxiliary boiler, a 288 hp diesel-fired emergency ICengine powering a water pump, a 860 hp natural gas-fired emergency IC engine powering a 550 kW generator and associated facilities. The p'lantwill have a nominal rating of600 MW. FacilityC-3953 will become a majorsource for NO

### x,VOC, andPM·

### 1o. There will be a.n

.increase in emissions for all pol.lutants and offsets are required for NO

### x,VOC, and PM 10 

### emissions. II. Applicable Rules Rule '2201 

### New and Modified Stationary Source Review Rule (9/21/06) (Section 3.30 and 4.13.3.2)

.Avenal Power Center Facility C-3953, Project# C-1 080386


### III. Process Description .Combined-Cycle Combustion Turbine Generators 

### Each natural· gas-fired General Electric Frame 7 Model PG7241FA**combined-~ycle** 

### combustion turbine generator (CTG) will be equipped with 

### Dry Low NOx combustors, a selective catalytic reduction (SCR) system with ammonia injection, ·an oxidation catalyst, a ductburner, and a heat recovery steam generator (HRSG)

.. Each CTG will drive an electrical. generator to produce approximately 180 MW of electricity. The plant will be a "combined-cycle plant," since the gas turbine and a steam turbine both turn electrical generatorsand··produce power. Each CTG will turn an electrical generator, but will also produce power by 

### directing exhaust heat through its .HRSG, which supplies steam to the steam turbine nominally, rated at 300 MW, which turns another electrical generator. Since two HRSGs will feed a single steam turbine generator, this desig'n is referred to as a "two-on-one" configuration. The CTGs will utilize Dry Low NOx (DLN) combustors, SCR with ammonia injection,

.and an oxidation catalyst to achieve thefollowing emission rates: NOx: 2.0 ppmvd 

### @ 15% 

### 02 VOC: 2.0 ppmvd @ 

### 15% 

### 02 CO:**4~0** 

### ppmvd 

### @ 1·5% O2 

### SOx: 0.00282 Ib/MMBtu PM 10: 

### 0.005 Ib/MMBtu Continuous emissions monitoring .systems (CEMs) will sample, analyze, and record NOx, CO, and O2 

### concentrations in the exhaust gas for eachCTG. Heat Recovery Steam Generators (HRSGs) 

### The HRSGs provide forthe transfer of heatfrom the CTG exhaust gases to condensate and feedwater to produce stream. Each HRSG will be approximately 90 feet hig'h and will have an exhaust stack approximately 145 feet tall by 19·feet in diameter. The size and shape of the HRSGs are specific to their intended purpose of high efficiency recycling ofwaste heatfrom the CTG. ' TheHRSGs will be multi-pressure, natural-circulation boilers equipped with transition ducts'and duct burners. Pressure components of each HRSG include a low pressure (LP) economizer, LP evaporator, LP deaerator/drum, LP superheater, intermediate pressure (IP) economizer, IP evaporator, I·P drum, IP superheaters, high pressure (HP) economizer, HP evaporator, HP drum, and HP superheaters and reheaters.

Page -2-Avenal PowerCenter Facility C-3953'- Project# C-1080386 

### SuperheatedHP steam is produced in the HR.SG and flows to the steam turbine throttle inlet. The exhausted cold reheat steam from the steam turbine is mixed with IP steam from the HRSG and reintroduced into the HRSG through the reheaters. The hot reheat steam flows back from'the' HRSG into the STG. T.he LP superheated steam from the

.. HRSG is admitted to the 'LP condenser.**Theconden~ate** 

### is pumped from the conc;Jenserback to the HRSG by condensate pumps. The condensate' is preheated by .an HRSG fee"dwater heater. Boiler feedwater pumps send the feedwater throu.gh economizers and into the boiler drums ofthe HRSG, where steam is produced, thereby completing the steam cycle. Each HRSGis equipped with a S'CR system that uses aqueous ammonia in conjunction with a catalyst bed to reduce NO

### x in the CTG exhaust gases. The catalyst bed is contained in a catalyst chamber located within each HRSG. Ammonia is'injected**up~tre'am** 

### of the catalyst bed. The subsequent catalytic reaction 'converts NO

### x'to nitrogen and .water, resulting in a reduced concentration of NO

### x in the exhaustgases exiting the stack. Duct Burners 

### Duct burners are installed in theHRSG transition duct between the HP superheaterand reheat coils. Through the combustion of natural gas, the duct burners heat the CTG exhaust gases to generate additional steam at times when 'peak power is needed. The duct burners are also used as needed to control the temperature of steam produced by the HRSGs. The duct burners will have a maximum heat input rating of 562 MMBtu/hr

.on a higher heating value (HHV) basis per HRSG, and are expected to operate no more than 800 hours petyear. Steam Turbine Generator 

### The steam turbine system consists of a 300 MW nominally rated reheat steam turbine generator (STG), governor system, steam admission system,'gland steam system, lubricating oil system, including oil coolers and filters and generator coolers. Steam from the HP superheater, reheater and IP superheater sections ofthe HRSG enters the correspond'ing sections of the STG as described previously. The. steam expands through the turbine blading to drive the .steam turbine'and its generator. Upon exiting the turbine, the ste'am enters the deaerating condenser, where it is condensedto water. Auxiliary Boiler 

### .One 37.4 MMBtu/hr Cleaver Brooks Model CBL700-900-200#ST natural gas-fired boiler equipped with an Cleaver Brooks Model ProFire Ultra· Low NO

### x burner, capable of providing up to 25,000 pounds per hour (Ib/hr) of saturated steam. The. boiler will be used to provide steam as needed'forauxiliary purposes. Diesel-Fired Emergency ICEngine P<>.wering a Fire Pump 

### .Emergencyfirewaterwill be provided bythree pumps (ajockey pump, a main fire pump, and a back-up fire pump); two powered by electric motors and the other powered by a diesel-fired internal combustion engine. Ifthe jockey pump is'unable to maintain a set operating pressure in the piping network, the electric motor-driven fire pump will start Page -3-Avenal Power Center Facility C-3953, Project# C-1080386 automatically. If the electric motor-driven fire pump is unable to maintain a set operating. pressure, the diesel engine-driven fire pump will start automatically. The diesel-fired engine will be rated at 288**hors~power.** Th.e engine will be limited to no greater than 50 hours per year of**non~emergency** operation in accordance with the applicant's proposal. 

### Natural Gas-Fired Emergency ICEngine Powering an Electrical Generator .One860 hp Caterpillar Model G3512LE natural gas-firedl·C engine generator set will, provide power to the essential servi.ce AC system in the event of grid failure or loss of outside power to the plant. This engine will be limited to no greater than 50 hours per year of non-emergency operation· in accordance with the applicant's proposal.

. 

### IV. Equipment Listing C-3953-10-0: 180 MW NOMINALLY RATED**COMBINED~CYCLE** POWER GENERATING SYSTEM #1 CONSISTING OF A GENERAL ELECTRIC FRAME 7 MODEL PG7241FA NATURAL GAS-FIRED COMBUSTION TURBINE· GENERATOR W·ITH DRY LOW NO

### x COMBUSTOR, A SELECTIVE CATALYTIC REDUCTI.ON (SCR) SYSTEM, AN OXIDATION CATALYST, HEAT RECOVERY STEAM GENERATOR #1 (HRSG) WITH A 562

.MMBTUIHR DUCT BURNER AND A 300 MW NOMINALLY RATED STEAM TURS·INESHARED WITH C-3953-11

.**C-3953~11-0:** 180 MW NOMINALLY· RATED COMBINED-CYCLE POWER GENERATING SYSTEM· #2 CONSISTING OF A GENERAL ELECTRIC FRAME 7 MODEL PG7241FA NATURAL GAS-FIRED COMBUSTION TURBINE GENERATOR WITH DRY LOW NOx**CO~BUSTOR,** A SELECTIVE CATALYTIC REDUCTION (SCR) SYSTEM, AN OXIDATION CATALYST,. HEAT RECOVERY STEAM GENERATOR #2 (HRSG) WIT·H A 562. MMBTUIHR DUCT BURNER'AND 

### A 300MW ·NOMINALLY RATED STEAM TURBINE SHARED WITH C-3953-10 C-3953-12-0: 37.4 MMBTUIHR CLEAVER BROOKS MODEL CBL-700-900-200#ST NATURAL GAS-FIRED BOILER WITH A CLEAVER BROOKS MODEL PROFIRE, OR DISTRICT APPROVED EQUIVALENT, ULTRA LOW NOX BURNER C-3953-13-0: 288 BHP

. CUMMINS MODEL CFP83-F40 ·DIESEL-FIRED .EMERGENCY IC ENGINE POWERING A FIRE PUMP C-3953-14-0: 860BHP CATERp·ILLAR MODEL G3512LE NATURAL .GAS-FIRED EME·RGENCY IC ENGINE POWERING A 500 KW ELECTRICAL GENERATOR

Page -4-Avenal Power Center Facility C-3953, Project# C-1080386


# v. InterpollutantOffset Ratio Proposal SOx for PM10 Rule 2201, New and Modified Stationary Source Review, specifically allows the use of PM 10 precursor ERGs to offset PM 10 increases: 

### 4.13.3 Interpollutant offsets may be approved by the APCO on a case-by-case basis, provided that the applicant demonstrates to the satisfaction ofthe AP'CO; that the emission increasesfrom the new or modifiedsource will not cause or contribute to a violation of anAmbientAir Quality Standard In such cases, theAPeo shall, basedon an airquality-analysis, impose offsetratios equal to orgreater than the**requir~ments** 

### of this rule. 4.13.3.2InterpollutantoffsetsbetweenP M10andP M10precursorsmaybe allowed Based on this language, an· applicant must demonstrate an appropr.iate interpollutant offset ratio, based on an air quality analysis (that is, base'd on the science of the precursor-to-PM 10 relation·ship given the atmospheric Che.mistry and the meteorology of

. the locale). The SOx for PM10 interpollutant ratio of 1.000:1 is based on District analysis (see Appendix A). The originating location of reduction'ofthe proposed ERG certificates are greater than 15 miles from the proposed project. Therefore,a distance offset ratio' of 1.5 applies. Combining the interpollutant and distance offset ratio, an overall SOx for PM10 offset ratio of 1.000 x 1.5

# =1.5:1 is valid for project C-1080386. 

### VI. Project Offset Calcu.lations 

### i. C-3953-10-0 and C-3953-11-0 (Turbines)


### a. Maximum HourlyPE The maximum hourly potential to emit for NOx, CO, ·and

## 'vac from each GTG will occur when the unit is operating**und~r** start-up mode. The maximum hourly PE for both turbines operating together is when both. are starting up and firing their duct burners.

Page -5-Avenal Power Center Facility C-3953, ·Project# C.-1080386 The combined startup NOx emissions from the two turbines will be limited to 240 tbs/hr [maximum startup emission rate (160 Ibs/hr) + average startup emission rate (80 Ibs/hr)]. Similarly, the combined startup 

### CO emissions from the two turbines will be limited to 1,902 Ibs/hr, [maximum startup emission rate (1,000 Ibs/hr) + average startup emission rate (902 Ibs/hr)]

.. The maximum hourly emissions are summarized in the table below:

NOx 160 17.20 13.55 13.55 240.00 CO 1,000 

### 20.97 16.34 16.34

. 1,902.00 

## voe 16 5.89 3.34 3.34 32.00 PM 10 N/A 11.78 8.91 8.91 23.56 'SOx N/A 6.65 5.23 .5.23 13.30 

### NH'3 N/A 32.13 25.31 25.31 64.26 b

.. MaximumAnnualPE The facility has indicated that the turbines will be operated in one ofthree different scenarios: weekend and weekday hot start scenario, weekend shutdown.and weekday hot start scenario, and baseload s·cenario. The sax emission factors used to calculate the annual potential emissions will be based on the applicant proposed average natural gas**sulfu~** limit 0.36gr/100 dscf.

sax EF 

# =(0.36 §f-S/100 x (1 ·lb-S/7000 

### §f1 x (64 Ib SOx/32 tb--S}x (1 SGf/1 013 

## Btut x (1 06 SW /MMBtu)


### = 0.001 Ib-SOx/MMBtu CTG wlo Duct Burner Firing: sax Emission Rate (Iblhr)

# =(1,856.3 MMBtu/hr)x(0.001Ib-SOx/MMBtu) 

# =1.86 Ib-SOx/hr CTG wI Duct Burner Firing: , SOx Emission Rate (Ib/hr)

# =(2,356.5MMBtu/hr) x (0.001 Ib-SOx/MMBtu) 

# =2.36 Ib-SOx/hr Potential annual emissions for each pollutant will be calculated for each ofthe three scenarios in the tables below:

1 PM 10 and SOx emissions during startups and shutdowns are lowerthan maximum hourly emissions'. Page -6-Avenal Power Center Facility C-3953, Project# C-1 080386 Scenario 1) Weekend and Weekday Hot Start: 547.5 (1.5 hr/hot start 

### x 365 hotstartlyr) hours operating in startup and shutdown mode, 800 hours operating while firi·ng at full load with the duct burner, and' 6,683 hours operating while firing at fU'1I load .without the duct burner. Since startup and shutdown emission rates for 

### PM 10, SOx, and NH3 are less than the emission. rate when the CTG is fired at 100% load w/othe duct burner, the startup and shutdown emission rates will be assumed to be equivalentto the CTG fired at 100% load w/o the duct burner. Since the CTGs will be fired throughout the year, the emission factors for the unit when fired at the average ambient**t~mperature** (63 0 F) will be used to calculate·the potential anflual emissions.

NOx 80 Ib/hr (avg) 16.341b/hr 13.03 Ib/hr CO 900 Ib/hr av 19.901b/hr 15.86 Ib/hr VOC 161b/hr (avg) 5·.68Ib/hr 3.171b/hr 

### PM 10 N/A 11.27 Ib/hr 9.00 Ib/hr SOx N1A**2~36** Ib/hr 1.86 Ib/hr NH3 N/A 32.13 Ib/hr 25.31 Ib/hr

* Emission factors were taken from.Table 6.2-1.1 in the ATe application submittal. Scenario 2) Weekend Shutdown and Weekday Hot Start: 143,951 Ibl ear' 614,662 Ibl ear. 34,489 Ibl ear 74,0.91 Ib/ear '15,337 Ibl ear' 208,7081bl ear

624 «(1.5 hr/hot start 

### x 208 hot startlyr) + (6.0 hr/cold start 

### x 52 cold starts/year)) hours operating in startup and shutdown mode, 800 hours operating while firing at full load with the duct burner, and 3,800 hours operating while firing at full load without the duct b·urner. Since startup and shutdown emission rates for 

### PM10, sax, and NH'3 are lessthan the emission rate when the CTG is fired at 100% load w/o the duct burner, the startup and shutdown emission rates will .be assumed to be equivalent to the CTG fi"red at 1000/0 load w/o the duct burner. S,ince the CTGs win be fired throughout the year, the emission factors for the unit when fired at the average ambient temperature (630 F) will be used to calculate the potential annual emissions.

Page -7-**AvenalPowerCe~er** Facility C-3953, Project# C-1080386

NOx 16.341b/hr 13.031b/hr 

## eo**19~90** Ib/hr 15.86 Ib/hr 

## voe 5.68 Ib/hr 3.17 Ib/hr PM 10 11.27 Ib/hr 9.00 Ib/hr 

## sox 2.36 Ib/hr 1.86 Ib/hr NH3 N/A 32.13 Ib/hr 25.31 Ib/hr
* Emission factors**werE~** taken from Table 6.2-1.1 in the ATC application submittal. Scenario 3) Baseload: 112,506 Ibl ear 637,788 

### Ibl 'ear

26,574 Ibl ear 48,8321bl ear 10,117 Ibl ear" 137,675 Ibl ear

800 hours operating while firing at full load with the duct burner, and 7,960 hours operating while firing at full load without the duct burner. Since the CTGs will be fired throug.hout the year, the emission factors for the 'unit**~hen** fired at the average ambienttemperature (63°F) will be used to calculate the potential annual. emissions.

116,791.lb/ear 142,166 Ibl ear 29,77771bl ear 80,656 

### Ibl ear 16,694 

### Ibl ear 219,972 

### Ibl ear

Page -8-Avenal Power Center Facility C-3953, Project# C-1 080386 

### Maximum Annual Potential to Emit: The high'est annual poten.tialemissions, for each pollutant, from the three different scenarios will be taken to determine the maximum annual potenti·al to emitforthe CTG.· The results are summarized in the table below:

NO

### x 

## co· 

## vae SOx 143,951 Ib/year 637,7881.b/ear 34,489 Ibl ear ·80,656Ibl ear

16,694 

### Ibl ear 219,972 Ibl ear Scenario 1 Scenario 

### 2 Scenario 

### 2 Scenario 

### 3 Scenario 

### 3 Scenario 

### 3
ii.. C-3953-12-0 

### (Boiler) The PM10 potential to emit for the boiler is calculated as follows, and summarized· in the table below

..

PEpM10

# = (0.005 Ib/MMBtu) 

## * (37.4 MMBtu/hr) 

### - . 0

..19 Ib 

### PM10/hr



# = (0.005 Ib/MMBtu) 

## * (37.4.MMBtu/hr) 

### *(1-2 hr/day) 

# = 2.2 

### Ib PM

### 10 /day



# = (0.005 Ib/MMBtu) 

## * (37.4 MMBtu/hr) 

## * (1,248 hr/year) 

# = 2331b 

### PM10/year



# = (233 Ib/year) 

## * (4 qtr/year) 

# = 58 Ib PM10/qtr

Page -9-Avenal·Po.werCenter Facility C-3953,.Project# C-1080386 iii. 

### C-3953-13-0 (DiesellC engine powering fire water pump) ThePM10 em.issions forthe emergency fire pump engine is calculated as follows, and summarized in the table below:

PEpM10 

### = .(0.059 g/hp· hr) * (288 hp) -;- (453.6 glib)



### = 0.04 Ib PM10

### 1hr

= (0.059 g/hp· hr) * (288 hp) +**(453~6** glib) * (24 

### hr/day) 

# = 0.9 Ib PM10/day



### = (0.059 g/hp· hr) *(288 hp) -;- (453.6 glib) *(12.5 hr/qtr) 

# = 0.5 Ib PM10/qtr



# = (0.059 g/hp· hr) * (288 hp) -;- (453.6 glib) * (50 

### hr/year)



### = 1.9 Ib PM10/year

iv. 

### C-3953-14-0 (Natura·1 gas 

### Ie engine powering electrical generator) The 

### PM10 emissi.ons for the emergency 

### Ie engine is calculated as**follow~,** and summarized in the table below:

PEpM10 

### = (0.034 g/hp·hr) * (860 hp) -;- (453.6 glib) 

# = 0.06 Ib PM10

### /hr

= (0.034 g/hp· hr) * (860 hp) -;- (453.6 glib) * (24 hr/day) 

# = 1.5 IbPM10/da·y

= (0.034 g/hp· hr)* (860hp) -;- (453.6 glib) * (12.5 hr/qtr) 

# = 1 Ib PM10 /qtr



### = (0.034 g/hp'ehr) * (860hp) -;- (453.6 ·g/tb) * (50 

### hr/year)

. 

# = 3 

### Ib PM10 /year

Page .;.10-Avenal.Power Center Facility 'C-3953, Project# C-1 080386

Post-Project Stationary Source**Pot~ntial** to Emit,(SSPE2) 

### Pursuant to Section 4.10 of District Rule 2201, the Post Project Stationary Source Potential to Emit (SSPE2) is the Potential to Emit (PE) from all units with valid AuthC?rities to Construct (ATC) or Permits to Operate (PTO) at the

.. Stationary Source and the quantity of emission reduction credits (ERC) which have been

. banked since September 19, 1991 for Actu'al Emissions Reductions

.that have

occurred atthe source, and which have not been used on-site.

C-395371 0-0· 143,951 ·637,788 34,489 80,656 16,694 219,972**C-3953~11-0** 

### 143,951 637,788 34,489 80,656 16,694 ·219,972 C-3953-12-0 ·51.3 1,727 201 233 132 

# ° C-3953-13-0 108 14 12 2 0 0 C:"3953-14-0 95 57 31 3 1 0 Post-project.S.SPE 288,618 1,277,374 69,222 161,550 33,521 439,944 

### (SSPE2) Total Emissions to be Offset 

### Pursuant to District Rule 2201, Section 4.6, emission offsets shall not be required for emergency equipment that is used exclusively as emergency standby equipment for electric power generation or any other emergency equipment as approved by the APeO that does not operate more than 200 hours per year for non-emergency purposes and is not used pursuantto voluntary arrangements with a power supplierto curtail power. Therefore the emission from the diesel-fired fire water pump and the natural gas-fired emergency standby generator are not required to be offset.

.

Page -11-Avenal Power Center Facility C-3953,. Project #C-1.080386

C-3953-10-0**C-3953~11-0** C-3953-12-0 Post-project SSPE (SSPE2)


### Offset Calculations: 637,788 637,788

1,727 

### 288,415 1,277,303 69,179161,545 33,520 439,944

SSPE2 (PM10) Offsetthreshold (PM10) ICCE Offsets Required (Ib/year) = 161 ,545lb/year


### = 29,200 Ib/year =Olb/year

= [(161,545-29,200 + 0) x DaR]

= 132,345 Ib/yearx DaR Calculating the appropriate quarterly emissions·to ·be offset is as follows (in Ib/qtr): 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter 33,'087 33,086 33,086 33,086 The applicant is proposing to use ERC Certificates C-894-4, N-721-4, N-723-4, N762-5,**8~2788-5,** 8-2789-5, 8-2790-5, and 2791-5 which have an original site of reduction greater than 15 miles from the location of this project. Therefore, a distance offset ratio of 1.5:1 is applicable and the amount of PM10 ERCs that need to be withdrawn is: Offsets Required (Ib/yeat) = 132,345 Ib/yearx 1.5 198,5181b/year 

# =99.26 ton/yr Calculating the appropriate quarterly emissions to be offset is as follows (in Ib/qtr):

. 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter ·49,630 49,629 49,629 49,630 The a.pplicant has stated that the facility plans to use ERC certificates C-894-4, N721-4, N-723-4, N-762-5,S-2788-5, 8-2789-5, 8-2790-5, .and 2791-5 to offset the increases in PMto emissions associated with this project. The applicant' has purchased the following quarterly amou'nts ofthe above certificates:
Page -12-Avenal Power Center Facility C-3953, Project# C-1080386


### ERC #C-896-4 ERC #N-721-4 ERC#N-723-4 ERe #S-2791-5· ERC' #S-2790-5 ERC #S-2789-5 ERC #S-2788-5 ERe #N-762-5 1st 

### Quarter 80 

## o a 92,179 12,862 

### 6 5 

### 21,000 2nd 

### Quarter 

### 80 

## o o 23,666 491 14 ·7



### 21,000 3rd 

### Quarter 80 3,215 ' 985 69,157 O'

. 

### 12 

### 3 21,000 4th 

### 'Quarter 80 

# a a 96,288 8,499 

### 8 6 21,000 Project PM10 offset requirements The applicant states either PM10 ERC certificates C-894-4, N-721-4,**N-723~4,** N762-5, 8-2788-5, 8-2789-5, 8-2790-5, and 2791-5 

### will be utilized to supply the PM10 offset requirements. 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter PM 10 Emissions to be offset: (at 1.5:1 ratio): Available ERCs from certificates C-896-4, N-721-4,andN-723-4: ERCs applied from certificates C-896-4,**N~721-4,** and N-723-4 fully withdrawn as certificates C-896-4, N-721-4, and N-723-4: RemainingERCs from**ce~ificate** C-896-4, N-721-4, and N-723-4: RemainingPM 10 emissions to be offset (at a 1.5:'1 ratio): 

### ·49,630 80
-80



### o 49',550 

### 49,629 80
-80



### o 49,54.9 

### 49,629 4,280 -4,280



### o 45,349 80

. -80

·0 49,550**Pe~** 

### Rule 2201 Section 4.13.3.2, interpollutant offsets between PM10 .and PM10 precursors (Le. SOx) may be allowed. The' applicant is proposing to use interpollutant offsets SOx for PM10 at an interpollutant ratio of 1.0:1 (see Append·ix A). This interpollutant ratio has been evaluated by the District's modeler, James Sweet, Air Quality Project Planner. Per Rule 2201 Section 4.13.7, Actual Emission Reductions (i.e. ERCs) that occurred from October'through March (i.e. 1st 

### and 4th 

### Quarter), inclusive, may be used to offset increases in PM during any period ofthe year. Since the SO'x ERCs are being used to offset PM10 emissions, the above applies to the SOx ERCs. In addition, the overall offset ratio is equal to the. multiplication ofthe distance and interpollutant ratios (1.5 x 1.000 

### = 1.5).

Page -13-Avenal Power Center Facility C-3953, Project# C-1080386
1st Quarter 2nd Quarter 3rd Quarter .4th Quarter Remaining PM10 Emissions to be 49,550 49,549 45,349 49,550 offset: (at a1.5: 1 ratio): Remaining PM10 emissions to be offsetwith SOx ERCs (at a 1.5:1 .49,550 49,549 45,349 49,550 distance ratio and a 1.000:1 interpollutant SOX:PM10 ratio): Remaining ERCs from certificates N-762-5, 8-2788-5, 8-2789-5, and 33,873. 21,512 21,015 29,513. 8-2790-5: Remaining ERCs from certificates N

..762-5, 8-2788'-5,S-2789-5, and 0 0 0, 0**8~2790-5:** 'Remaining PM10 emissions to be offset (at a 1.5:1 ratio and a 1.000:1 15,677 28,037 24,334 20,037 interpollutant SOX:PM10**r~tio):** 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Remaining PM10 Emissions to be

, offset: (at a1.5:1 distanc'e ratio and 15,677 28,037 24,334 20,037

a 1.000:1 interpollutant '80x:PM10 ratio): Remaining' ERCs from certificate 92,179 23,666 69,157 96,288 8-2791-5: 1st qtr. ERCsapplied to 2nd qtr. -4,371 4,371 0 0 ERCs: Adjusted Remaining ERCs from 87,808 28,037 69,157 96,288 certificate 8-2791-5: Remaining PM10 emissions to be offset (at a 1.5:1 ratio and a 1.000:1 . 15,677 28,037 24,'334 20,037 interpollutant SOX:PM10 ratio): ERCs applied from certificate 15,677 28,037 24,334 20,037 8-2791-5 partiallywithdrawn: Remaining ERCs from certificate 72,131 0 44,823 '76,251 8-2791-5: As ,seen above, the facility has sufficient credits to fully .offset the quarterly SOx and PM 10 emissions increases associated with this project. VII. Conclusion Approve use ofan overall SOxfor PM 10 interpollutant offset ratio of 1.5:1 (1.000 x 1.5).

Page -14-Avenal Power Center FacilityC-3953, Project #**C~1080386** VIII. Recommendation Compliance with all applicable rules and .regulations is expected. Issue Authorities to

.. Construct C-3953-10-0, -11-0,**-12~O, -13~O,**  and -14-0 .with a SOx"for PM 10 interpollutant offset ratio of 

### 1.00.0:1.

Page -15-County Fresno/Madera Kern SOxfor PM10 1.866 1.055 

### PM10 InterpollutantOffsetRatio Analysis* NOxfor PM.1 0 Notes 4.202" Fresno/Madera is a combined evaluation with a shared source"area 2.157 Kings Tulare 1.000 1.000 2.282 2.298 KfngslTulare is aco.mbined evaluation with a shared source area Separate annual evaluations were made forthe SIP, butthe results establish this as one"shared area The KingslTulare area has a small inventory of local SOx sources and is dominated by pollutanttransport from the region; therefore the SOxfor PM1.0 ratio is setto the minimum technical value of 1.000

* Minimum offset ratio before consideration ofdistance orotheradjustmentsNotes for the Kings-Tulare InterpollutantAnalysis Combined emissions·and inventories from Kings and Tulare Counties are used due to the evaluations ofsource interactions. This relationship was established by analysis performed forthe SJVAPCD PM10 SIP. The interpollutant relationship established for Kings County in this analysis would also be applicable to Tulare County. Tons of SOxto Equal Effect of 1 Ton of PM10 See SOxPM10 worksheetfor calculations Tons ofSOxto Equal Effect of 1 Ton of PM10 1.000 See SOxPM1 0 (2) worksheet forcalculations Tulare County A minimum value of 1.000 is established fortechnical reasons. A relationship ofless than one-to-one indicates that regional emissions are more dominantthan local emissions. Tons of NOxto Equal ·Effectof 1 ton Pry110 Tons of NOxto Equal Effect of 1 ton PM10 2·.298 See NOxPM10 worksheet for calculations**l<,'l\""~W;"** See NOxPM10 (2) worksheet for'calculations Tulare County Inputdata forthe interpollutantworksheets are from the Annual and Annual based on Monthlyworksheets These worksheets are data and analyses submitted forthe PM10 SIP The AO.! worksheet provides area of influence evaluations used to analyze specific episodes in the PM10 SIP Episode evaluations reveal a variety ofsource areas fordifferentepisodes. Thisjustifiesthe use ofthe entire county, and in some cases more than one county, as the source area for annual interpollutantevalaution. Episode trajectories revealed mixing between Kings and Tulare counties during episodes. Annual analysis showed·almost identical contributions. The combined emissions inventories ofthe two counties are evaluated in comparison to the annual chemical mass balance modeling for each site, and while the observations are slightly different, the resulting interpollutant relationships are almost identical.PM10 InterpollutantOffset Ratio Analysis Annual PM10· Notes Wnits Estimate Uncertainty 1 J.lg/m3 2 J.lg/m3 1.97 3 J.lg/m3 0.39 J.lg/m3 1.57 4 J.lg/m3

. 0.79 5 ton/day J.lg/m3 perton 0.23 0.30 0.16 "Vegetative Burning" Total Industry Component (300/0) Regional Backg"round (20%) Industry minus Background County Contribution Organic Carbon PM10 Inventory
- Kings and Tulare County County Impact Nitrate 6 J.lg/m3 7 f.!g/m3 1.00 J.lg/m3 14.66 8 f.!g/m3 7.33 9 ton/day J-lg/m3 perton 0.10 0.11- 0.09 10 2.48 2.73 1.74 Tons of NOxtoEqual Effect of 1·ton PM.10 Ammonium Nitrate Regional Background Ammonium Nitrate minus Background County Contribution NOx Inventory
- Kings and Tulare County County Impact

1. Per SJVUAPCD and CARB, PM10 emissions from stationary**industrialcom~ustion** sources are included in the Vegetative Burning category from Chemical Mass Balance modeling performed forthe**SJVUA~CD** 2003 PM1

## oAttainment ·Plan (Kings
- Hanford monitoring.station). 2. Per SJVUAPCD, 30% ofthis category is attributed to stationary industrial combustion ·sources. 3. Per SJVUAPCD, regional background is estimated to be 20% of net**con~entration** after previous adjustment to Vegetative Burning category. 4. Contribution from sources within Kings County is 500 k of net concentration after previous adjustments to Vegetative Burning category. 5. Organic carbon PM10 inventoryfor·Kings County that contributes to this monitoring location; from ·SIP inventorywith updates and adjustments based on CCOS study. 6. Ammonium nitrate category from Chemical Mass. Balance modeling performed for the SJVUAPCD 2003 PM10 Attainment Plan (Kings
- Hanford monitoring station). 7. Per SJVUAPCD, regional background of ammonium nitrate is estimated to b.e 1 f.!g/m3

. 8. Contribution from sources within Kings County IS 500 k of net concentration after previous adjustment to Vegetative Burning category. 9. NOx inventoryfor Kings· County that contributes to this monitoring location; from SIP inventorywith updates and adjustments based on

### ·ceos study. 10. PM10 County Impact divided**~y** Ammonium nitrate County Impact."Annual based on Monthly" speciation worksheet cells G7 and H7 "Kings
- Hanford"worksheetforspeciated rollback analysis

" Required to use baseyearemissions that are related to the observed**sp~ciation**

Annual based on Monthly. speciation worksheetCells M7 and N7 "Kings
- Hanford" worksheetforspeciated rollback analysis

" Required to use base yearemissions that are related to the observed speciation

1. PerSJVUAPCD and CARB. PM10 emissions from stationary industrial combustion SQurces are included in the Vegetative Burning categoryfrom Chemical Mass Balance modeling performed forthe SJVUAPCD 2003 PM10 Attainment Plan (Kings -Hanford monitoring station). 2. PerSJVUAPCD.**~O%** ofthis category is attributed to stationary industrial combustion sources. 3. PerSJVUAPCD. regional background is estimated to be 20% of netconcentration afterprevious adjustmentto Vegetative Burning Category. 4. Contribution from sourceswithin Kings County is 50% of netconcentration afterprevious adjustments to Vegetative Burning**~tegory.** '5. Organiccarbon PM10 inventoryfor Kings Countythat contributes to thi.s monitoring location; from SIP inventory**w~th** updates and adjustments based on CCOS study.

. 6. Ammonium sulfate categoryfrom Chemical Mass Balance modeling performed"forthe SJVUAPCD 2003 PM10 Attainment Plan (Kings
- Hanford monitOring station).

. 7. PerSJVUAPCO. regional background ofammonium sulfate is estimated to be 1 J,lg/m3• 8. Contribution from sourceswithin Kings County is 50% of netconcentration after previous adjustmenttoVegetative Burning category. 9. NOx inventoryfor Kings Countythat contributes to this monitoring location; from SIP inventorywith updates and adjustments based on CCOS study. 10. PM10 County ImpactdividedbyAmmonium Sulfate County Impact.

. TheKingslTulare area has a small inventoryof local SOxsources and is dominated by pollutanttransportfrom the region; therefore the SOx for PM10 ratio is setto the minimum technical value of 1.00060.9543 305.5217 45.81837627 13.44158539

565.1907 4.5846 34.9152 2.96197731 1.704288207

249.4981 1241.6439 91.01532476 277.6758466 34.3569 205.9787**~.87213601** 26.9341378 0.0 0.0 0.4 1.4 1.0

4.0 0.5 1.6 3.2 2.0 0.0 70%PM10 50%PM2.5 70%PM10 50%PM2.5 70%PM10 50%PM2.5 70%PM10 50%PM2.5 ofnet ofnet ofnet ofnet ofnet ofn!!t

2.0 0.4 0.8 1.6 .15%PM10 30%PM2.5 15%PM10 30%PM2.5 15%PM1030%PM2.5 15%PM10 30%PM2.5

1.2 0.1 0.48 1.0 10%PM10 15%PM2.5 10%PM1 0 15%PM2.5 10%PM10 15%PM2.5 10%PM10 15%PM2.5

0.6 0.1
. 0.24 0.5 5%PM10 5%PM2.5 5%PM10 5%PM2.5 5%PM10 5%PM2.5 5%PM10 5%PM2.S

49.32181 2.5364 230.94631 14.9086 10.627264011 0.34354204 39.3104583511.76730805 1.0 PM10 paved roads+ PM10 unpaved roads+ PM10 offroad mobile+ PM10farm operations+ PM10 construction+ PM10 windblown 5.801 1.9 7.781' 4.0

45.221 19.2

10.611 2.9

R=SJV
Sr= Tulare, Kings L1= Area5 L2= Areas 5,6,7,8

L2= Areas 5,6,7,8 L1=AreaS

Sr= Tulare, Kings L2= Areas 5,6,7,8

R=SJV Sr= Tulare, Kings R=SJV L1= Area 5 R=SJV Rolled back againstValleywide emission estimates ·!5%PM1 0 5%PM2.5 episode specific adjustments based on meteorology and episode duration

Sr= Tulare, Kings

L1= Area 5 L2=Areas 5,6,7,8 Netfor Rollback, defaultpercentages adjustablefor episode characteristics, applicableto all columns exceptas indicated.**9.·~** :,.:·.,: :..**,,:~**

## .'i1J~~~:~:ewear~**~at?j~l;!** ii (area ofinfluence emissions inventory, each on a**se~arate** linefor automated**calcuiatio~r** .··;/2/;.···."',;· '0 Rolled backagainstspecified County(ies) emission I10%PM10 15%PM2.5 estimates· episode specific adjustments based on meteorologyand episode duration From CMS monthlyanalysis Feb 2000 to Dec2000,1 From CMS .' adding January2001.episode for chemistry :\:: equivalentto annual designvalue**;~;;** . .. 53.00 23.20 4.00 0.50 1;98**4~62** 15.70. 3.00 0.00 0 I N;' Portion notincluded in rollback analysis, removed see background sheetfor 0, no natural background, 0, no natural background, see background sheetfor numerical see background sheetfor numerical see backgroundsheetfornumerical see background sheetfor 100% because marine 0, backgroundestimatel :.;;ipriorto rollback as notsubjectto local control, numerical estimate and episode transport estimated at 0 transportestimated at0 estimate and episode adjustment estimate and episode adjustment. estimate and episode adjustment numerical estimate and episode salls are anatural at maximum, no ";::l added backto projected future concentrations adjustment Removed priorto
. Removed priorto rollback as not Removed priorto rollback as not Removed priorto rollback as not adjustment. Removed priorto emission additional background rollback as notsubjectto local subjectto local control, added back subjectto local control, added backto SUbjectto local control, added backto rollback as notsubjectto·local estimatefor control, added backto projected to projected future concentrations. projected future concentrations. projectedfuture concentrations control, added backto unexplained mass future concentrations Includes biogenic emissions. Includeswildfires and biogenic. projected future concentrations

= 20% =20% + 10%

<;**~:~~:~::=:~~r:~~a:~:~~~~~~ ~~~~:~e;r~:,17~~~~1**  0 50%PM2.5 .:. includes all PM size emissions in the area· Rolled'**;~;:'** back againstlocal area of influence emission**~if;:;** estimates .:'i.;;:', .' 26.55 13.4**'::,'~;;;** Rolled back againstlocal PM2.5 area of influence 15%PM10 30%PM2.5 :·f:;": emission estimates
- episode specific adjustments**:;.;:;~f.!{** based on meteorology and episode duration

NOx

SOx TOG

\J 120.0 0.0 0.0 0.0

0.0 0.0 0.0

0.0 0.0 0.0

0.0 M 1.7466 33.341

27.083 1.7246 3.49721152

3.453160991 2.537472797 .2.569842275 364.0558 401.6368 52.7948

47.6723089 44.57374446 13.78371425

12.44632963 49.36328821

322.0508

321.5428 1458.6195 1484.1355 354.3705663 112.9643685

112.7861796 353.8115854



## ::1 0.5 0.3 0.1 0.1 0.0 0.0 Q2

0.5 0.1 0.1 0.0 0.0 D.7 0.6 20.4143

0.3 20.4143 111.1259

111.1259 14.8601553

14.8601553 3.40459935

3.40459935

0.9

1.7 0.5 0.5

0.9

0.3 D.1 2.1 3.2

2.6 1.7 Q.9 12.2' 14.8

1.1 4.0 25.2

4.0 21.4 54.7212\ 2.2327

44.87321·2.14909268 255.07941 13.3523

205.83041 12.8523 9.608135471 0.30493694 43.744740241 '1.5914437

35.872138721 1.53184933

=(2010 L211999 L2) * LINE 5 =(2010 L1/1999 L1) * LINE 4 R=SJV Sr=Tulare, Kinas

L2= Areas 5,6,7,8 L2= Areas 5,6,7,8

Sr= Tulare, Kings L2= Areas 5,6,7,8

Sr=Tulare, Kings Sr= Tulare, Kings

R=SJV L2= Areas 5,6,7,8 R=SJV

R=SJV Sr= TUlare, Kings R=SJV R=SJV Sr=Tulare, Kings

L2= Areas 5,6,7,8 R=SJV

R=SJV L2= Areas 5,6,7,8

Sr=Tulare, Kings L2=Areas 5,6,7,8 L2= Areas 5,6,7,8 Sr= Tulare, Kings

SOx2010 EI with newcontrols IL1=Area 5 NOx2010 EI with newcontrols IL 1= Area 5

TOG 2010 Elwith newcontrols IL1= Area 5 PM10 2010 EI with newcontrols IL1=Area 5

SOX2010 EI without newcontrols IL1=Area 5 NOx2010.EI without newcontrols IL 1=Area 5

TOG 2010 EI without newcontrols IL1=Area 5

N22Annual t .J on Monthly

ANN.UAL Average, based on 

### eMS results .for Februarvto December 2000 Dlusthe Jan 2001 EDisode

57:7 3.6 98.5 57.0 55.6 6.3 2.3 3.6 2.4 1.1 1.2 3.0 0.3 14.9 49.5 3.2 98.4 50.0 46.9 7.5 2.4 4.6' 2.8 0.7 0.7 2.6 0.3 12.0 51.5 3.3 104.1 53.0 52.9 4.0 2.3 0.5 0.7 52.5 3.3 99.6 54.0 51.8 4.0 2.5 0.5 1.0;;: This analysis provides aseasonally adjusted annual average, using the Januaryepisodeto reflectthe dominantwinterchemistry.

PageN 12 5.8 FDKERANN 3.3 FOFSDANN**4~2** FDHANANN 3.8 FDVCSANN. Annuall

...d on Monthly

IBGS 11/1/01 

# I 2051 10.31 93.61 1.01 0.91 23.31
. 6.3/ 6.71. 4.71 1.31 1.71 7.01 0.71 95.41 7.81 58.21 9.6

# I~~**~~ --lli=~h~~Jj'-~-=-;~** **~G~:,'_'w, ~w~~w§** **-~.:~~** .

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.**_w"}~~+-_l18·Plw*._,._1·qJ.~,.w,,,,-.9~~_w~~** ..**_W_""~_~~~-"~~~.~~tWff\~~·'~t--_-:-~-~-~--",-:-+",_.,** 

### ...**~-_.-:.-.t~--~-"~Af--_~w~«>W_"** 

### __ '''':'-'1 IBGS'IJun* 41.3 2.7! 102.71 1.01 0.61 0.91 0.41**5.1~ 2.6A~.4tI:\~~~:j>~.>**  3.8j 0.3j 3.11 0.41 29.4! ,6.0l**IBwGS·_·~ti.1****JUi*-~.** 0
...·_·_..**_--w·~·6l-"1·o1·~31-·w·_·_·--O~91.-·~.** 

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### --··----2~6r.--..'-·§7-:-8f.M'·---r.Ol---1.2, -4:fr"--··'---O

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...**~_.~.-,.--~---' ~r--'-_wt.~~~~--+--~~~**  

### ..--r---_.-·""""'i'-«••**~-"""~_l__-.~~-'~'~--_** .•**~_.--~** 

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# -Hr**:~~~~.,,~.r.** 

# HI 

# 6::1**6:~-'-~ ~~:~--+T1** **~IDe_cr~<i.~~.2Qjtj.~4t-** Y2:2j·.·- 

## H
Min Avg Max 22.2 57.7 205.0 1.9 83.9 3.6 98.5 10.3 118.5 0.9 0.4 1.0 0.9 1.0 2.2 0.3 6.3 23.3 0.4 0.2 2.3 3.6 6.3 1.0 1.3 0.5 0.6 2.4 1.1 1.2 4.7 2.4 2.7 1.2 3.0 7.0 0.1 0.3 0.7 2.2 14.9 95.4 0.3 10.9 1.3 26.7 7.8 ·61.9 3.1 5.8 12.5

FSD 1/1/01 186 9.4 87.9 1.0 1.1 40.1 11.3 18.5 9.6 2.5 1.5 5.0 0.7 62.4 5.1 35.1 6.8

# ~~-+-1I~1 

# -**~%'-li~-~:;t_-~:~---HI it-~::I**  

# '**~it-~~-~~f------N ~pr** **1-.24.8~[** ..

# '·~'--1·~Ot.·--Q6 .'

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.

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# :z·W9

# :Sc=ror· ··O.:§

# 0.3~~~_·1.4~**~321~12rl.~ run~**  

# . _34'l

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## ..i:~Lvm .....

## _~~L.N __.....

## ~~_:-~L.~,.**Q:~~?:~~** __. .w••M'_3.8j

# ~L~u-i!=-~ 

# ..**tit~tl=ttDt~~~ ~FS~**  __**~3.~9t** .0.5,
..**~30~3.~ ~~~_"_?:§L~_1:31~~0.~~.?J~** **1.~!:§j lf~£2.~_.lQec.** __..--L,

__".**65.~,** ..**_.~.9i** .....**_w.~~-:.~ ~~~.,,_13.**  7**~,**__**~._4.31_~L_** 3.81

__**Q:~L_._._Q:§J. ~:...?J'_~M_0.3j_,**  __23.41 _._ 2.01**~{)..:~i** __....__.**~~**

. Min

Avg Max 20.0 49.5 186.0 2.1 87.9 3.2 98.4 9.4 116.0 0.9 0.4 1.0 0.9 1.0**.'~** 2.7 0.3 7.5 40.1 0.3**0~9** 2.4 4.6 11.3 18.5 1.3 0.0 0.4 2.8 0.7 0.7 9.6' 2.5 1.5 1.1 2.6 5.0 0.2 0.3 0.7 2.5 12.0 62.4 0.3 6.8 1.1 19.5 5.1 40.6 1.7 3.3 6.8

Page N22Annual'l j on Monthly

HAN 1/7/01 185 9.6 '102.9' 1.0 0.4 27.6 9.7 14.7 7.8 1.7 1.1 7.2 0.7 96.9 7.9 42.4 7.7

### lti!-N~-+_ 

## ..**~10~t-~~1~~** __

### ~-M-**0.9~ 1!L~-l~+-~~.~Q:~J--~L~~~~**  

### •....**?2l~I·3L~_~~_~_~**

## ~~;*+1~:~--}+I~~-+m--%.i-n~--0.35~5H~i·":.:.·'·~·2.4~~.7**i~~g4~1 ~~:h79:J.** 

# ~~-·-~~~.~i~**~~~-~ ~Q~2~** **iRAN'Tur-+~r-2:6f~--0:9-----o.-~-02h7l--s.4~.6~--4:71**

## iHAN~Au-rl-43Y-2]r-1in7t-+~-f]rM_·-1.s!-0.3Io:ar~ OAr

## 33~-_·M_[71.**mA~p*-~0.~~~-o.sr-"2":5i-~~~-or-s]i---"-·(f71~5aar-----·"--8]i**

### t·~FiAN--.1ocr-r.: ...

### '--"~"M-5~8t.**_w-,,-_w·~3:'4t.:-. --~w~90~91.---:rol-~-1-**  ..

### ol'-··'.w_,w"~-",.,,w..o.

### -:-sr--.3i1."--'-'-22~ ..

### ~,**·····_~"o** ..

### 2r-'·-·~6Bt:**~.4(------0:3r-~.61-** 

## 0.81"32.

## 2t----W----.,.-ws

# i**IHAN1Nov-----r--46~1D7."61~~~'3~4.8r----2.9~0.5~-.-1.5[J~**

## ~~t62."8~~=1·L.Q:5t=**1~_3.41_4.41-i.~~L_~0.71-281** Min Avg' Max 20.0 51'.5 185.0 1.8 89.4 3.3 104.1 9.6 120.6 0.9 0.3 1.0 0.4 1.0' 0.7 0
..4 6.6 27.6 0.3 1.4 2.0 4.0 9.7 14.7 1.0 0.0 0.3 2.3 0.5 0.7 7.8 1.7 1.2 1.4 3.0 '7.2 0.2 '0.3 0.7 2.7 15.7 96.9 0.4 4.6 1.4 23.2 7.9 58.8 1.3 4.2 8.8

HAN 1/7/01 185 9.6 102.9 1.0 0.4 27.6 9.7 14.7 7.8.1.7 1.1 7.2 0.7 96.9 7.9 42.4 7.7

# ~~f;~**~!t_ U~~4--=-"** **~:ij=tlt=~-~-= iHi=-~:~tJl=** **-~i ~j** **_2·~~L_ 0.7L-5A,~~:.<.:·.·**  ...

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### 3.9! 

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### 3.71
..... 0.61
..1.81
...**-!1L~~_.** 

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......**~,,_~:~L.~.**

## __**0.~+-.23.7,_** ..**--~**



### __**~L~_1_.~1.6! 9.:.~_~~~2~~** 

## ~~~.**e~~..-** __ ._ ._ 

### 59.*-.

## .~'**~~.5:_~.!w,**.. 'w•.

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.

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## 36.~~.**FS~~I~n- ~~.~~~**  

# __**1~_. ·Q~~-~~·TI** **._-~**

# ~gQ;f==t-·:~:~t-=irdL~ 

# _**;:~t- ~~ok~_-OC** **~=~** Min Avg Max 25.0 52

..5 185.0 2.1 83.6 3.3 99.6 9.6 115.3 0.9 0.4 1.0 0.9 .1.0 1.4 0.8 6.7 27.6 0.4 1.4 2.5 4.0 9.7 14.7 1.3 0.0 0.5 2.5 0.5 1.0 7.8 1.7 1.6 1.1 3.1 7.2 0.1 0.3 0.7 3.8 15.9 96.9 0.5 7.6 1.5 21.7 7.9. 42.4 1.9 3.8 7.7

Page N 32.Annual b, J on Monthly

NOTES: Burning profile wasswitched from wood burning to agricultural burning based on ARB monthly emissions inventory estimates. Astetisk * denotes AgBWheat profile used; ** denotes WBAlmond (some AgBWheatIWBAlmond used in April/May)

Burning Sulfate Nitrate MotorVehicle TirelBrake Geological Source Profiles Jan-May and NovDec 22 WBOakEuc 57 Amsul 60 Amnit 65 CAMV 67 TireBrke 92 FDHANANN 93 FDFREANN 94FDVCSANN 95FDKERANN June-Oct 27 AgBWheat* 57 Amsul 60 Amnit 65 CAMV 67 TireBrke 92 FDHANANN 93 FDFREANN 94 FDVCSANN 95 FDKERANN Note: (not used ifrun came out negative)

Page N 42)1
Rollbackdefaultpercentage, adjust by episode properties Local PM2.5 Sub regional Regional Total Default 2.5-10 I 70 15 10 5 100 Default 2.5 - I 50 30 15 5 100 Note:**distributi~n** of**ant~ropogenic** contribution aftersubtraction of background Mapping of local, PM2.5-local, and sub-regional based on trajectory analysis Areas used 24-hr date ISite Name Value PM2.5 Sub.regional IRegional 

### 1#ofdates 199 159 160 1/12/99 Oildale-3311 Manor Street 156 12 12,13 Kern SJV 1 10/21/99 Corcoran-Patterson Avenue 174 6 5,6,7,8 Kings-Tulare SJV 2 Fresno-Drummond Street 162 3 3,4 Fresno-Madera SJV 3 Turlock-S Minaret Street 157 1 1,2

_ Stanislaus-Merced SJV 4 11/14/991 Bakersfield-Golden State 183 12 6,7,8,10,12 Kings-Tulare-Kern SJV 5 12/17/99 Cotcoran-Patterson Avenue 6 6,8 Kings-Tulare SJV 12/23/99 Street 3 3,4,7 Fresno-Tulare SJV 5 5,6,8 Kings-Tulare SJV 1/1/011 Bakersfield-5558 California Avenue 186 12 9,10,11,12 Kern SJV 9 Bakersfield-Golden State Highway 205 -12 9,10,11,12 Kern SJV 10 Clovis-N Villa Avenue 155 .-3 3,4 Fresno-Madera SJV 11_ Fresno-1st Street 193 3 3,4 Fresno-Madera SJV 12 Fresno-Drummond Street 186 -3- 3,4 Fresno-Madera SJV 13 Oildale-3311 ManorStreet 158 .12 9,10,11,12 Kern SJV 14 1/4/011 Bakersfield-5558 California Avenue 1 12 -**10~12,** 13 Kern SJV 15 Bakersfield-Golden 12 10,12,13 Kern SJV 3 3,4 Fresno-Madera SJV 1 Manor 12 10,12,13 Kern SJV 1/7/011 Bakersfield-5558 Cal.ifornia Avenue 159 12 10,12 Kern SJV 19 Bakersfield-Golden State Highway 174 12 10,12 Kern SJV 20 Corcoran-Patterson Avenue 165 6 6,8,10,12 Kings-Tulare-Kern SJV 21 Hanford-S_Irwin Street 185 5 5,6,7,8,10 Kings-Tulare-Kern SJV 22 Mod-esto-14th Street 158 1 1,2 St-Me':':Ma- Fr-Tu SJV 23 11/9/01 IHanford-S Irwin Street 155 5 5,7,8 Kinas-Tulare SJV 24**Annu~I'** ICounty Kern Value 57 Local 12 . ,vi

Areas used PM2.5 Sup regional

Kern Kern Regional SJV' 

### Pl·M·1·0: SIIPR,sgioin:.s. b:.8SQd, ,g,n 

### 4k CCAQ.S :D:Olm:aiiin (COiunty .inftuencedceUs)Page I of2

Derek"Fukuda From: Jim Rexroad [Jim.Rexroad@macquarie.c·om] Sent: Monday, June 09, 2008 3:"51 PM To: Derek Fukuda Cc: "EricWalther; Tracey Gilliland Subject: Certificates used for Avenal PDOC

" " We are still finishing up the formal table submissions so you can see the actual breakdowns, but here is the list of certificates that we·will be using forthe project. Note that S-2813-1 will**~hortly** have a transaction coming that will reduce the volume to 50 Tons and the· S232"1-2certificate {I have a contract and the ownership change documents will come next**we~k.** We should be able to"send you the formal table tomorrow or by Thursday. Call me ifyou**havequestions~**
ERC Certificate No

.. 

## ·vac C-897-1 C-898-t

. N-724-1 N-725-1" S-2813-1 (derived.·from) NOx" C-899-2 N-722-2 N-720-2 N-726·-2 N-728-2· C·-902-2 8-2814-2 8-2321-2 (derived from)

.. SOx (conversion to PM10.at 1.4:1) S-2791-5 8-2790-5 S-2789-5 S-2788-5 N"-762-5

1/?OORPage 2 of'2
PM10 C-896-4 N-721-4 N-723-4 Jim Rexroad Macquarie Cook'Power Inc.**713-27g~6147** (0) 832-748-1060 (c) 71 3-275**~611** 5 (f) 500 Dallas'**~treet,** Level 31 Houston, TX 77002 USA -jim.rexroad@macquarie.com

EmaiJ disclaimerfor Macquarie Cook Power Inc.: http://wwW

..macquarie.com/us/mcp_disciaimer.htm This. communication has been prepared by MacquarieCook Power Inc., and is confidential andintended for specific recipient(s) only. Ifyou are not the intended recipient, please notifyus by telephone orreturn emaif and delete the communication withoutusing, copying or qisseminating the·information contained therein. ' Any'use, copying ordlssemihation ofthe information, without the express written consent of.Macquarie .Cook Power Inc.• is strictly prohibited and**le~al** proceedings may be commenced against you. .

11 1**I~()()Q**AvenalPower'Center, LLC(OB-AFC-01) SJVACPO Determination ofCompliance, C-1080386



# ATTACHMENT I AdditionalSupplementalInformation

Attachment I - 1Table 3.2-2. UNCONTROLLED ·EMISSION FACTORS FOR4-STROKE LEAN-B.URN ENGINESa 

### (sec 2-02-002-54)

Pollutant Emission Factor (lb/MMBtu)b

(fuel inP':lt)
. Emissionfactor Rating CriteriaPollutants and Greenhouse Gases NOxC 90

- l05°h> Load
c NOx <90% Load " c CO 90

- 105.% Load 

# cac .<90% Load C02d S02e TOCf Methaneg VOCh PM"lO"(filterable)l ·PM2.5 (filterable)i PM Condensabld Trace Organic Compounds 4.08 E+OO B 8.47**E~OI** B 3.17E-OI C 5.57 E-Ol B 1.10 E+02 A 5.88 E-04 A 1.47 E+OO A 1.25 E+OO C l.18 E-Ol C 7.71 E-05 b· 7.71 E-05 D 9.91 E-03 D

k 1;.1,2,2-Tetrachloroethane 1,1,2-Trichloroethanek 1,1-Dichloroethane 1,2,3-Trimethylbenzene 1,2,4-Trimethylbenzene 1,2-0ichlotoethane 1,2-Dichloropropane 1,3,5

-Trirnethylbenzene 1**,3-Butad~ene** k 1,3.:.Dichloropropenek " k 2-Methylnaphthalene 2,2,4-Trimethylpentanek**Acehap~thenek** <4.00**"E~05** <3.18E-05 <2.36 E-05

2,30 E-05 1.43·E-05 <2.36 E-05 <2.69 E-05

3·.38 E-05
. 2.67E-04 <2.64 E-05

3.32 E-05 2.50 E-04 1.25 E-06 E E E 

## o C E E D D E C C CTable 3.2-3. UNCONTROLLED EMIS'SIONFAC'rORS FOR4-STROKE RlCH-BURN ENGINESa**(SC~** 2-02-002-53)
EmissionF'aetor

(lbIMMBtu)b Emission Factor Pollutant (fuel input) Rating Criteria Pollutants and Greenhouse Gases NOx C 90

- 105% Load 2.21E+OO A
C 2.27 E+OO C NOx <90% Load 

### cac 90

- 105% Load 3.72 E+OO' A 

### cac**<90o~** Load 3.51 E+OO C ..

. CO d 1
..1.0E+O.2 A 2 SO e 5
..88E-04 A 2 TOCf 3.58 E-Ol C Methaneg

· 2.30 E-Ol C VOCh 2.96 E-02 C PMI0 (filterable)i,j 9.50 E-03 E

### PM2~5**(filterable~** 9.50 E-03 E

. k . 9.91 E-03 E·

PMCondensable Trace Organic Compounds 1,1,2,2-TetrachloroethaneI 2.53**E~05** C 1, 1,2-TrichloroethaneI <1.53 E-05 E 1,1**~Dichloroethane** <1.13 E-05 E 1,2-Dichloroethane <1.13 E-05 E 1**~2-.Dichloropropane** <1.30 E-05 E . . I 6.63 E-04 D 1,3-Butadiene 1,3-Diehlo.ropropeneI .<1.27 E-05 E

. . 1m 2.79 E-03 C**Acetaldehyd~** , A 1·lm 2.63·E-03 C
. ero etn ' I \ Benzene 1.58 E-03 B Butyr/isobutyraldehyde 4.86 E-05 D Carbon'TetrachlorideI <1.77 E-05 Ebtu=>ppm
SELECTION -# COAL (ANTHRACITE) 0 COAL (BITUMINOU'S) 1 COAL (LIGNITE) , 2 OIL (CRUDE, RESIDUAL', OR DISTILLATE) 3 GAS (NATURAL) 4 GAS (PROPANE) 5 GAS (BUTANE) 6 WOOD 7 WOOD BARK -8 MUNICIPAL SOLID_WASTE_ 9 STANDARD 02 CORRECTION FOR EXTERNAL COMBUSTION IS 3% Type offuel (usetable above) 4 GAS 02**correc~ion (i.e.~**  3%) 15·%

. Enter LB/MMBTUemission factor NOx 0.847 LB/MMBTU CO 0.130- LB/MMBTU 

### voe (as methane) , 0.000 LB/MMBTU
CALCULATED EQUIVALEN.T CONCENTRATIONS

NOx 229.94 ppmv, CO 57.98· pp-mv 

### voe- (as methane) 0.00· ppmv pV.= R*T pressure (p)

. 1 atm universal gas**con~tant** (R*) 0.7302 atm-scf/lbmofe-oR temperature.(of) 60 of calculated

molarspecificvolume (V)- 379.5 scf/lbmole

-.. Molecularweights

NOx 46 Ibllb-mole CO 28 Ib/lb-mole 

### ,vac (as methane) 16 Ib/lb-mole F FACTORS FROM J=PA METHOD 19 @ 68 F COAL (ANTHRACITE)' , COAL (BITUMINOUS). COAL (LIGNITE) ',' OIL{CRUDE,RESIDUAL, OR DISTILLATE) GAS**(~ATURAL).** GAS (PROPANE) GAS (BUTANl=)

. WOOD WOOD BARK MUNICIPAL SOLID**WA~TE** F FACTOR USED IN CALCU-LATIONS

----.---------------,- --- .--6/-2--3t2008 101000'SCP/MMBTU 9780- DSCF/MMBTU 9860 DSCF/MMBTU 9160 OSCF/MMBTU 8710 DSCF/MMBTU 8710 PSCF/MMBTU 871-0 DSCF/NlMBTU 9240 DSCF/MMBTU 9600 DSCF/MMBTU 9570 DSCF/MMBTU 8710 DSCF/MMBTU COAL" C:OAL COAL OIL GAS GAS GAS WOOD ,WOOD BARK

.SOLID WASTE GASVaria.blas: '860lhp 230lppmv Olppmv 

### aIPpmv '(as CH4) 15,1 0 /0 351 % (Assumed) 85781 dscf/MMBtu 

### FuelType I 1 Oil (CRUDE. RESiDUAL, OR DISTillATE) GAS (NATURAL)

. GAS (PROPANE) GAS (BUTANE) 

## o 2 3 Conversion #1 : ··Conversion·#2:

Conversion·#3: iVIVV (NOX). dscf/lb-mol bhp

...hr/MMBtu glib

ppmv F-factor MWpoUutant 1 1**Con~ersion** #3 1 1 1 1 Conversion#1 ' Conversion#2 1 Engine Eff.

46·t9 20.9 11bmql MMBtu 453.59 9 1 

## C::> 1 Ib mol 20.9

- 15 379.5 GSGf**393'~24** bhp-hr lb 35%



# c=::>**o~** 10 W 

### ft8-Ft-s**o~** 1

### a ft8-Ft-s 8578 GsGf MMStY MM24J 453.59g

453.59 9 35%

350/0btu=>ppm
SELECTION # COAL (ANTHRACITE) 0 COAL (BITUMINOUS) 1 COAL (LIGNITE) 2 OIL (CRUDE, R"ESIDUAL, OR DISTILLATE) 3 GAS (NATURAL) 4 GAS**(PROPA~E)** 5 GAS (SUTANE) 6 WOOD 7 WOOD BARK 8 MUNICIPAL·SOLID WASTE 9 STANDARD 02 CORRECTION FOR EXTERNAL CO.MBUSTION IS 3% Type offuel (use tabl.e above) 4 GAS 02 correction (Le.; 3%) 15 % Enter LB/MMBTU emission factor ./

NOx'
.2.270 LB/MMBTU CO 0.130 LB/MMBTU 

### vae (as methane) 0.000 LB/MMS'TU**~CALCULA** TED EQUIVALENTCQ:NCENTRATIONS

NOx 616.25 ppmv 

### GO 57.98 ppmv 

### vac (as methane) 0.00 .ppmv pV

## =R*T pressure (p) 1 atm universal gas constant-(R*) 0.7302 atm-scf/lbmole-oR temperature (oF) 60 of calculated

molarspecificvolume (V)**~79.5** scfllbmole

'., Molecularweights

N"Ox 46 Jb/lb-mofe CO 28 Ib/lb-mote 

### .vae (as methane) 16 Ib/lb,..mole F FACTORS FROM EPA METHOD 19 @ 68 F COAL (ANTHRACITE)

. COAL (BITUMINOUS)

COAL'(LIGNITE)

. '. OIL (CRUDE, RESIDUAL, O'R DISTILLATE)

GAS(NATURAL) GAS (PROPAN·E) GAS (BUTANE)

. WOOD

.

WOOD BARK MUNICIPAL SOLID WASTE F FACTOR USED IN CALCULATIONS 10100 DSCF/MMBTU 9780 DSCF/MMSTU 9860 DSCF'IMMBTU '9160 DSCF/MMBTU 8710 DSCF/MMBTU 87100'SCF/MMBTU 87'10 DSCF/MMBTU 9240 DSCF/MMBTU 9600' DSCF/MMBTU 9570 DSCF/MMBTU 8710 DSCF/MMBTU COAL

. COAL

COAL OIL GAS' GAS GAS WOOD WOOD BARK SOLID WASTE GASIV·arlaQles: Engine. Size: 8.60 

### hp NUx: 616 ppmv CO: 

## oppmv 

### vac: 

## oppmv (as CH4) U2level: 15 0/0 Engine Efficiency: 35_0/0 (ASsumed) F-factor: .8578. dscf/MMBtu· Fuel Type 1 OIL (CRUDE, RESIDUAL, OR**DISTILLAT~)** . 0 GAS (NATURAL) 1 GAS (PROPANE)

. 2 GAS (BUTANE) 3 Conversion #1.: Conversion #2:

..Conversion #3:

Ivlvv -(NOx). dscfllb-mol bhp-hr/MMBtu glib

35% I 35% 1 I Engine Eff.

U3 I 35% 453,'59 9 I 1

453.59 9 453.59 g I 1 Conversion #3 I 1

MMStY 1 Conversion #2 1 .

11bmol

379.5 00sf Conversion#1

tlb mol. 1 I 1**~4M8tu.** I 1 Ib mol F-factor I MWpol1utant

8578 GsGfI 28 fu 8578 GsGf I ·46 U3 ppmv 1**o~ o~** **10V~ 10V:~** **10-~ 616~** 

## Avenal Power 'Center, LLC 500 Dallas Street,Level 31 Houston, TX· 77002' 

# RECEIVED JUl 0j 

## 2008 Pe·rmlts:Srvc**~.l\I.A-rj·nD**

July.1, 2008 

# COpy

RE: CertificationofAvenal Energy, ownedby Avenal PowerCenter, LLC
I, Stuart Zisman, on behalfofAvenal Power**C~nter,** LLC, herebycertifyunderpenaltyof ·perjury.as follows: 1. Iam authorized

### to make this certificationonbehalfofAvenal PowerCenter, LLC. 2
.. This certification is made pursuantto Section4.15.2 ofRule 2201 of theRules and Regulations ofthe SanJo'aquin ValleyUnified AirPollutionControl District. , .3. To the bestoftheundersignedfs knowledge, relative·to Section4.15.2 ofDistrict Rule ·2201-, Avenal Po'werCenter, LLC.do"es notcurrentlyown, operateorcontrol any Major Stationary Sourceor**feder~l** -majormodificationin the StateofCaliforniaother than the proposed Avenal Energy Project. 'Eachofthe'statements herein is made in good faith. Accordingly, it is Avenal' PowerCenter, LLC'sunderstanding insubmitting this certificationthat the SJVUAPCD shall take

## no action against Avenal PowerCenter, LLC or**a~y** ofits employees basedon any**st~tement** made.in

.this certificatiou.

J e 

### Forbes SeniorLawyer . StuartZisman

Vice President Avenal Power**C~nter,** LLC

# ~JIO~ Dated

### AvenalPowerCenter, LLC(08-AFC-01) SJVACPO Determination ofCompliance, C-1080386



# ATTACHMENT 

# J' CEC Comments andDistricts R(3sponses

----------..**-~--~----------.-.------** 

### ....-- ---- ------..--.--.-.--------------..**------Atta-cb-me-nt~j-----**Public Comments 

### I District Respon.se 

### The comments from the California Energy Commission (Keith Golden) regarding

.the proposed Title V Operating Permit for Aven.al Power Genter LLC(District

facility Co-3953) are encapsulated belowfollowed bythe District's response. CEC Comments

## _0Letter Dated August 12, 2008 CEC Comment#1 : 

### Energy Commission staff is concerned that the integrity of the proposed mitigation may be adversely affected by the annual equivalency demonstration required by SJVAPGD Rule 2201, Section 7. This rule requires the District to demonstrate that emission reduction credits (ERGs) used by**th~** 

### project 'as offsets are surplus atthe time of use. Please describe whether District compliance with Rule 2201, Section 7 would require any of the offsets to be subject to discounting.. Please also confirm

.whether the offsets identified for the project·(on PDOCp. 47) are representative

. of real and surplus reductions, taking into account possible discounting under

Rule 2201, Section 7. Additionally, please identifythe original emission reduction site and date, and the method of reduction, for the ERGs that would be used to offsetthis project. Districts Response: Provided the FDOCis issued prior to a finding of failure of the equivalency system, the "attime ofuse"requirements don'tapply.

° In addition, the-Districthas not failed the equivalency demonstration, and does not· expect to fail the demonstration this year. Finally, "at time of use" means at the time of the issuance ofthepermit(which the Districtconsiders to be the FOOG, in this case). Therefore, ifa permit is issued without requiring "surplus at time of use credits", as the District subsequently fails

°to demonstrate equivalency with federal offsetting requirements, there is no affect··on the permit. The "surplus at time·of use"requirements wouldonlykickin onpermits issuedafterthatdate. CEC Comment#2: 

### Staffwould like to verify that using offsets would notdisrupt regional progress in attaining PM10 or PM2.5 standards. The SJVAPCD, in Attachment H of the PDOC incorrectly states that the applicant proposed a one-to-one
.ratio. Please provide the District analysis in "Appendix A" with the Attachment H ofthe PDOC that supports compliance with Rule 2201, Section 4.13.3.Districts Response: The Districts PM10 and PM 2.5 plans both account for the growth in permitted sources in the air district. This growth is compared to the amount ofoffsets available in the Districts ERG bank to assure thatthe increase'in emissions will notinvalidate the Districts PM10 andPM 2.5 plans. Since the growth in permitted sources in the airdistrict and the airdistricts available offsets have been taken into account when determining both the 'PM10 and PM 2.5 attainmentplans, the use ofoffsets in this project will not result in**th~** disruption of the attainment plans. The interpollutant offset ratio for

# sax reductions for PM10 increases will remain the same as stated in the PDOC.The Districts analysis of the interpollutant offset ratio has can be seen in Appendix 

### A, which has been included·in AttachmentHofthe POOG. CEC Comment#3:

. 'Energy Commission staffconcurs with the District that th,e NOx emission limits for the combustion turbines and duct burners 'should apply on one-hour rolling averages during all operating conditions, except startup and shutdown periods (as described in PDOC p. 64 and POOC Condition. 26). However, the one-hour NOx emission limit is not consistently described in the POOC. Please confirm that the value calculated by the District is 17.20 Ib/hr (POOC Condition 26), not 17.44 Ib/hr (as shown onp.64). D'istricts Response: The hourly NOx emission limit is 17.20 Iblhr. The condition on page 64 of the PDOChas been correctedto be consistent with condition

### 126 ofthe**PDOC~** CEC Comment#4: Energy Commission staff recommends limiting ammonia, slip to the extent feasible. Although ammonia slip is intr.insic to operation of the selective catalytic reduction system, staff suggests that the District set a performance. standard for ammonia slip. Guidance from CARB (Guidance for Power Plant Siting and Best Available Control Technology, September 1999) indicates that 

## an ammonia slip limit of 5 parts per million by volume dry basis (ppmvd) should be achievable. Please consider revising th.e ammonia slip limits forthe combustion turbines.Districts Response: 

### Ammonia is an integralpart of 

### the NOx emissions control system when using SCR. The Districthas no regulatorybasis forrestricting ammonia slip to 

### 5 ppmv. Ammonia is nota 

### criteria aircontaminant ora 

### "pre,cursor" as 

### defined in District Rule 2201. The District's BACTClearinghouse does notspecifyan ammonia slip rate for combustion turbines using SCR.**Whi/~** 

### ammonia emissions' may be restricted as part of a**he~/th** 

### risk evaluation that determines an unacceptable health risk from the ammonia to exposedpopulations, this is not the case with Avenal Power Center. The risk due to all toxic air contaminant emissions, including 

### 10ppmvammonia, was foundto be notsignificant. 

### A high ammonia slip from the turbin,e willnotlead to increasedPM10 

### formation in' the atmosphere. The airbasin currentlyhas an excess of 

### ammonia emissions; therefore lowering ammonia' emissions will not reduce PM· formation. This is demonstrated in the Districts PM 2.S 

### plan which does not not rely on ammonia reductions to'reduce PM 2.S , 

### butratherrelies largelyon,NOx

### reductions. Generally, increasedammonia injection rates, and therefore increasedammonia slip rates, are required to maintain NOx BACTperformance levels (2.0ppmv) as 

### the catalyst ages. Allowances foroperation 'at the end ofthe economic life of

### a control te'chnology and for periods of non-steady state operation (including startup andshutdown which can resultin ammonia slip higherthan 

### 5 ppmv) are partof

### a BACTdetermination. CEC Comment#5: The New Source Performance Standard (NSPS) Subpart KKKK applies to stationary combustion turbines and emissions from any associated duct burners, and it replaces earlier requirem.ents in NSPS Subpart Db and Subpart GG. The PDOC (p. 55) shows requirements from NSPS Subpart Db, although the project appears to be exempt. Similarly, the PDOC (p. 63) states that the turbines meet the applicability requirements of Subpart GG when the project appears to be exempt. Please clarify whether' the project is indeed exemptfrom NSPS Subparts Db and GG. Districts Response: 

### The stationarycombustion turbines andductburners in thisprojectare subjectto Subpart KKKK and are therefore exempt from Subparts Db and GG. An additional compliance section was added to state that the duct bu.rners are "exemptfrom SubpartDb. The compliance section forSubpartGG alreadystates thatthe turbines are exemptfrom its requirements.

### AvenalPowerCenter, LLC(08-AFC-01) SJVACPO Determination 

### ofCompliance, C-1080386



# ATTACHMENT K EPA Comments andDistrictResponses

### EPA Comments 

### I District Response The comments (from Shirley Rivera) regarding the proposed Title V Operating Permit fo'r Avenal Power Center LLC(District facility**C-3953)~s** encapsulated belowfollowed bythe District's response. 

### EPA Comments
- Email Dated August 15,2008 EPA Comment#1: For the purposes of EPA's review of the PDOC evaluation and PDOC, although n'ot 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 Districtevaluation also is based. PSD review has been triggered for NOx, CO, and P'M.) 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 ana'lysis/modeling are consistent

.. At this time, we simply would like to make the District aware that th'is evaluation is in process. To the extent that we identify inconsistencies during our review, we will address them as part of our PSD permitprocess.. 

### Districts Response: Thankyou for(h.enotification.
EPA Comment#2: 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% 

### 02. EPA is· aware of CTGs achieving CO emissions less than 4.0 ppmvd @. 15% 

### 02. Therefore,. please provide' confirmation whether the District's evaluation considered achieved in practice CO ppm levels less than 4.0 ppmvd 

### @ 15% 

### 02. If s'o, please provide reasons why a'Iower level was eliminated from consi.deration. 

### Districts Response: The facility hasproposed to lowertheirCO 

### emission limit to 2.0ppmvd 

### @ 15%



### - 02.

### AvenalPowerCenter, LLC(OB-AFC-01) SJVACPO Determination ofCompliance,C-1080386



# ATTACHMENT L CUREComments andDistrictResponses

Attachment - 1Public Com'm'ents 

### I District Response The comments from California Unions for Reliable Energy· (Loulena Miles, attorney at Ad.am Broadwell Joseph & Cardozo) regarding the proposed Title V Operating Permit for Avenal Power Center LLC (District facility C-3953) is encapsulated belowfollowed bythe District's response. Public Comments
- Email Dated August 18, 2008 Public Comment#1 : THE SJVAPCD MUST SET LIMITS FOR GREENHOUSE GAS EMISSIONS The law is now settled that greenhouse gases are pollutants subject to regulation under the Clean Air Act (CAA). Therefore,Air District permits must include a Best Available Control Technology (BACT) analysis and a permit limit for greenho.use gas emissions. The PDOC contains' neither. Accordingly, the PDOC is deficient and must be revised to require BACT· for greenhouse gas emissions. Districts Response: 

### According to the Advanced Notice of Proposed Rulemaking for Regulating Greenhouse Gas Emissions under:the Clean AirAct, Federal"Register Vol. 73, No. 

### 147, pg. 44420 (July30, 2008), "The Supreme'Court's con.clusion that GHGs are "airpollutants" underthe CAA did not automatically make these pollutants subject to the PSD 

### program. A**subst~nce** 

### maybe an "airpollutant"underthe Act without·being regulated under the Act. The Supreme Court directed the EPA Administrator to determine whether GHG emissions from motor vehicles meet the endangerment test of 

### CAA section 202(a). 

### A positive finding of endangerment would require the Administrator to then set"standa'rds applicable to GHG emissions from motor vehicles undertheAct. Thepositive finding itselfwouldnotconstitute a 

### regulation requiring actual controlofemissions. GHGs would become regulatedpollutants underthe Actifand when EPA subjects GHGs to control requirements under

### a CAA·provision otherthan sections 

### 112 and

### 211(0)." EPA has notaddedcontrolrequirements forGHG's 

### in the CAA, therefore GHG's are not regulated airpollutants and are not subject to the PSD program. In addition, the District has**no~** 

### been delegated the PSD program by EPA. Therefore, even if GHGs do become regulated pollutants, the District will

. continue to have no jurisdiction to regulate them until the EPA- decides to delegate the PSD

### program to the District. . - Based on the information discussed in ·the paragraphs above, an evaluation 

### of GHG's 

### is notnecessaryto determine ifthisprojectis apprqvable.Public Comment#2: The PDOC limits CO emiss'ions from the combustio'n turbine generators (CTGs)

.to 4.0 ppm at 15% 

### 02 regardless ofwhetherthe duct burners arefiring based on

the use of an oxidation catalyst. 1 The PDOC',s determination that 4.0 ppm CO emissions are 'BACT is incorrect a.nd fails to recog'nize th'at a number of power pl,ants in the same category and class of source have achieved lower CO emission rates than proposed by'the Applicant. Districts Response: 

### The facilityhas proposed to lowertheirCO 

### emission limit to 2.0ppmvd @ 15% O2
. Public Comment#3: THE PM10 BACT DETERMINATION ,FOR CTGs IS DEFICIENT The PDOC limitsPM 10 emissions'from the combustion turbine generators (CTGs) to 9.0 Ibs/hr without duct firing and 11.8 Ibs/hr with duct firing, using natural gas fuel. The PDOC determined that BACT for PM10 emis.sions from this Project's two 'G,eneral Electric (GE) 7FACTGs wou.ldbe the use of natural gas'fuel with an LPG backup.' This determination is incorrect and fails to recognize that a number of power plants in the same category and class of source that have ach·ieved lower PM10 emission rates than proposed bythe Applicant.
Districts Response: 

### The' District Top-Down BACTAnalysis did not consiqer any 

### PM10 emissions contr()1 otherthan the use of

### an airinletfilter, lube oil ventcoalescerandnatural gas fuel. District BACT Policy, Section. IX.

### 0, states that 

### a cost effective analysis is not necess,aryfor

### a 'projectin which the mosteffective controlalternative is selected. BACT Guideline 3.4.2 

### identifies BACTfor

### PM10 as 

### the use of 

### an airinlet filter, lube airvent coalescerandnatural'gas fuel. Since the applicantproposedthe most effective BACT control alternative, no evaluation of 

### ·other control**t~chnologies** 

### were 'performed.

1 SJVAPCD PDOC Attachment F-5.Furthermore, District BACTPolicy, Section IV, states that BACTDeterminations are to be basedupon the controltechnologies andmethods forthe same·orsimilar source categories, listed in the District's BACT Cle'aringhouse for the calendar

,quarter during which the' application is,**de~med** complete. This application was

deemed complete in the 

### 1st quarter of2008, therefore it 1s $ubject to the BACT Guideline for the source categories contained in the BACTClearinghouse at that time. 'Basedon the completion date ofthis application, the BACTrequirements for ,the units in this project would not change even if the BACT Guidelines were

changedin subsequentquarters. The permitted PM10 emissions limit for each CTG in this project is 

### 11.78 Ib/hr. This emission limit is lower other GE Frame 

### 7 A, combined cycle, turbines with duct burners atpowerplants which have recently been approve(j by the GEC. The Victo/Ville 

### 2 Hybrid Power Plant (approved 7/16/08) was permitted with 

### a PM1 0emission limitof 18.0Ib-PM101hr. The Colusa Generating Station (approved 4/23/08) was permitted with a PM10 emission limit of 20. 

### 1 Ib-PM1 01hr. The Los Medanos Energy Center referenced in 

### yoiJr comment has 

### a permitted PM10 emission limitof

### 16.2 Ib-PM101hr. In addition, the PM10 emission limits forthe two**turbin~s,** at the Cosumne,s Power Plant are not comparable since they are not equippedwith ductburners. Public Comment#4: 

### SJVAPCD's LIMITS ON AMMONIA SLIP ARE NOT BACT The PDOC and attached permit conditions ,propose an unreasonably high ammonia slip limit of 10 ,ppm 

### @ 15°1'<> O2.2 

### This' ammonia slip rate was selected by the Applicant i'n the Application for Certification' (AFC).3 The, PDOC incorporates this rate withoutany BACT analysis. The PDOC dismisses the nee'd, to do a BACT analysis on the basis that "the, ammonia emissions are intrinsic to the operation ofthe SCR system, which is BACTfor NOX. The emissions from a control device**th~t** 

### is determined by the District to be BACT are not subject to BACT'." Districts Response: Ammonia is an integral part of the NOx emissions control system when using SCR. The Districthas no regulatoryba$is forrestricting ammonia slip to 

### 5 ppmv. Ammonia is not

### a criteria aircontaminant or

### a ''precLirsor'' 

### as defined in District
" Rule 2201. The ,District's BACTClearinghouse does notspecifyan ammonia slip

rate for combustion turbines using 

### S'CR. While ammonia emis$ions may be restricted as part ofa health risk evaluation that determines an unacceptable health risk from the ammonia to exposedpopulations, this is**~ot** the case with

2 SJVACPD Avenal PDOC p. 7 and PDOC AttachmentA. ,3Avenal EnergyAFC, p. '6.2-41.

### Avenal Power Center. ·The risk due to ·all· toxic air contaminant emissions, including 10ppmvammonia, ¥Vas foundto be notsignificant. 

### A high ammonia slip from the turbine wil'notleadto increased

### PM10 formation in the atmosphere. The airbasin·currentlyhas an excess of 

### ammonia emissions; therefore lowering ammonia· emissions will not reduce PM 

### formation. This is demonstrated in the Districts PM 2.S 

### plan which does not not rely on ammonia reductions to reduce 

### PM 2.S ,**but.~ather** 

### relies largelyon NO 

### x reductions. You commented that initial ammonia slip rates below 

### 5 ppmv have been observed on some combustion turbines using SCR. 

### Generally, increased ammonia injection. rates, and therefore increased ammonia slip rates, are required to maintain NOx BACTperformance levels 

### (2.5 ppmv) as 

### the catalyst ages. Allowances for operation at the end of the economic life 

### of a control

. technology and forperiods of 

### non-steady state operation (including startup and

shutdown which can result in ammonia slip higher than 5 

### ppmv) are part of a 

### BACTdetermination.