UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D

.C

. 20460

OFFICE OF AI R AND RAD IATION 

# JUN 21 

# 2011 Mr. Jim Rexroad Avenal Power Center, LLC 500 Dallas Street, Level 31 Houston, Texas 77022
Dear Mr. Rexroad:
This letter responds to Avenal Power Center's, LLC (APC) request for technical corrections to the final Prevention ofSignificant Deterioration (PSD) permit issued by the U.S. Environmental Protection Agency to APC on May 27, 2011, for the construction and operation ofthe Avenal Energy Project (AEP) in the City ofAvenal, Kings County, California. APC's request was conveyed by Gary Rubenstein, Sierra Research, Inc., in a telephone voice mail message ofJune 6, 2011. Mr. Rubenstein noted that while the final permit's hourly mass emission rate for gas turbine operations with duct firing is correctly shown as 10.60 lb/hr over a I-hour averaging period in the emissions summary table in Condition X.C.3.a, there appears to be a typographical error in Conditions X.C.3.b and X.C.3.c ofthe permit, where the hourly mass emission rate for gas turbine operations with duct firing is shown instead as 8.35 lb/hr

. As background, APC had commented on our proposed PSD permit for the AEP, stating that the proposed permit's hourly mass emission rate for gas turbine operations with duct firing, shown as 13.55 lb/hr, should be 10.60 lb/hr. In our May 2011 Response to Comments document for the AEP PSD permit, we stated that "[w]ith respect to the CO emissions limits, we first note that the 13.55 lb/hr limit reflects a typographical error and we have made the correction requested by the Applicant." (See the EPA's May 2011, Responses to Public Comments on the Proposed PSD Permit for the AEP, Comment and Response 38 in Section ILA.1 , pp. 40-41.) In the final permit for the AEP issued by the Agency on May 27, 2011, we made this correction as requested by APC in the emissions summary table in Condition X.C.l, but erroneously stated in Conditions X.C.3.b and X.C.3.c (which relate to the demonstration period and post-demonstration period limits for gas turbine operations without duct firing) that the same limit was 8.35 lb/hr. As we made clear in Condition X.C.3.a ofthe final permit for the AEP issued on May 27, 2011, and as reflected in our response to comments as described above, our intention was to require a CO emissions limit for gas turbine operations with duct firing equal to 2.0 ppmvd 

### @ 15% 02 and 10.60 lb/hr over a I-hour averaging period at all relevant times (including the period during and after the 3-year demonstration period for gas turbine operations without duct firing). Therefore, we have amended Conditions X.C.3.b and X.C.3.c ofthe permit, in order to make the emissions limit at issue clear and consistent in all sections ofthe permit and to correct this typographical error.

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. Printed with Vegetable Oil8ased Inks on 100% Postconsumer. Process Chlo rine Free Recycled PaperWe also note that we are correcting two additional typographical errors for clarity and consistency in the permit. First, we have added the words "over a I-hour averaging period" to Condition X.C.3.c to reflect the applicable averaging period; in reviewing APC's request to correct the error described above, we noted that this language had been inadvertently omitted from this section ofthe final permit, although it was included in the emissions summary table in Condition X.C.l ofthe final permit. Second, we are deleting the phrase "Region IX" from the heading on the first page ofthe permit and the phrase "Region 9" from the first paragraph ofthe first page ofthe permit to more accurately reflect the permit issuing authority for the final PSD permit for the AEP. In addition, we have made a few minor revisions to the permit to reflect the fact that the permit is being amended.
Because these corrections are de minimis in nature and are being made simply to correct minor typographical errors in the final permit in order to make the final permit clear and consistent, and do not alter our prior BACT or ambient air quality impacts analyses, we are processing the corrections that APC requested, and the other corrections described above, as administrative amendments to the PSD permit for AEP, applicable immediately. We have attached the amended permit. For your convenience, we have also attached an unofficial redline/strikeout version ofthe amended permit that shows the differences between the amended permit issued today and the final permit issued on May 27, 20 II.
Ifyou have any questions, please contact Shirley Rivera ofour EPA Region 9's Air Permits Office at (415) 972-3966 or rivera.shirley@epa.gov.

Gina McCarthy Assistant Administrator
Enclosures: Amended PSD Permit for the AEP Unofficial redline/strikeout version ofAmended PSD Permit for the AEP

cc: Deborah Jordan, U. S. Environmental Protection Agency, Region 9 Seyed Sadredin, San Joaquin Valley Air Pollution Control District David Warner, San Joaquin Valley Air Pollution Control District (via email) Robert Fletcher, California Air Resources Board Michael Tollstrup, California Air Resources Board (via email) Christine Stora, California Energy Commission (via email) Jeffrey R. Holmstead, Bracewell & Giuliani LLP (via email) Gary Rubenstein, Sierra Research (via email)