UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF JUN 21 2011 AI R AND RADIATION 

Mr. Jim Rexroad 

Avenal Power Center, LLC 

500 Dallas Street, Level 31 

Houston, Texas 77022 

Dear Mr. Rexroad: 

This letter responds to A venal Power Center's, LLC (APC) request for technical corrections to the final 

Prevention of Significant Deterioration (PSD) permit issued by the U.S. Environmental Protection 

Agency to APC on May 27, 2011, for the construction and operation of the Avenal Energy Project 

(AEP) in the City of Avenal, Kings County, California. APC's request was conveyed by Gary 

Rubenstein, Sierra Research, Inc., in a telephone voice mail message of June 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 of the 

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 of the 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 of the permit, in order to make the 

emissions limit at issue clear and consistent in all sections of the permit and to correct this typographical 

error. 

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We 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 of the final permit, although it 

was included in the emissions summary table in Condition X.C.l of the final permit. Second, we are 

deleting the phrase "Region IX" from the heading on the first page of the permit and the phrase "Region 

9" from the first paragraph of the first page of the 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 of the amended permit that shows the 

differences between the amended permit issued today and the final permit issued on May 27, 20 II. 

If you have any questions, please contact Shirley Rivera of our 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 of Amended 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)