Avenal #08-SJ-01: Info in PSD application & so~~ initial/prelim 

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Eric,	 II11I 

Figured I'd just send a poke on a few things so far. And the below are jj~ prelim/initial 

**OBSERVATIONS** as Kate ,and I go through our page turn. ,111 ,' II

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•	 CEC Data adequacy worksheets: Although we did speak about tH~re not being a 

formal/submitted filled-out data adequacy worksheet for the CEC s~c~ions you all provided as the 

PSD submittal, please do see if there is even a 'working copy' that ~~:flvailablefor each of the 

sections subnlitted. For various reasons, this would make our revi~wll: ,process. 

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I've not sent this elm request to Jim Rexroad given you are the proJtf~t manager for the our PSD
 

permit (i.e., air quality related issues in the CEC filing); I understant1 I 

,' Ithat TRC provided the balance
 

at the CEC AFC, so it you determine it may be useful to check Withl ~ifn one last time, that would be
 Il great. We would use the worksheet for our streamlining our internall ,' f8view process and would
 

**not** distribute to others. I iii


IIIII l And just as a reminder, this (attached) is our current application gUideli~ne.

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PSD Application GUid~':s. October ~OO7.pdf II i:
 

Kate is establishing an in-ho~sel (for our in-use) review checklist baseJ Idn this Oct 2007 document, as
 

well as our potential"gap filling" for PSD project such has power plant~li -:-jand in this case, as we
 

discussed, those applications that are submitted from sections of a C6~ IAFC.
 

•	 BACT - As I had mentioned, the last most recent application sUbj\~1 for a combined-cycle facility 

is Kings River. The proposed limits in Kings River are "2-2-2" ppm~~lfor NOx, CO, and vac (@ 15% 

02. I am in discussions with the permit engineer for that apPlicati911 as you and I have discussed, I
 

will be ensuring that my TViiw is consistent with her review. ,IIII
 

•	 PSD pollutant review/observation - Avenal's application states (IP. 6.2-20, top section) that PSD 

thresholds exceeded for pollutants N02, CO and PM10. However,1 ~n Page 6.2-69 (top section), 

there is reference that project "emissions of ... PM 10 do nottrigger ;~SD review." Table 6.2-32 on p. 

6.2-27 summarizes the TPY.	 ',II i: II

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•	 S02 (and SIL) - We see from the application the 1 gr/100 scf S cep'ntent (tariff) referenced for 

short-term, while 0.36 gr~100 set S for the annual. The natural ga~1 ~lltoperties are noted in Table 

6.2-18 (p. 6.2-42). On page 6.2-68, Table 6.2-34, there is referenge1to the comparison of modeled 

max and the SIL; it is noted that the table shoes S02 values belo~ the SIL. At this point, for my 

understanding regarding the natural gas properties (PG&E info), 'fh~t is the time period of the 

"average" based, e.g., calen,.dar year 2007, "xyz" month/year to m?,!~,tlh/year? (And I have reviewed 

Table 6.2-1.5 of the APprrX.) I 

•	 Fuel firing - We note that b,oth pipeline natural gas and Diesel fU,~III"'.WI ill be fired on eqUipment at the 

facility. I	 I : IIII I

Natural gas specs and heat value - In the project description (~eftion 2), there is a discussion of
 

the natural gas supply (pp. 2-32, 2-33). Values (Btu/set, HHV) prel~e~nted include 1,060, 1,020, and
 

1,013. It is noted that" SUrPIY will be from the "redundant sourc~~ of supply through the PG&E
 

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pipeline system" with the proposed properties (e.g., Tables 2.3-3, 6.2-18, and 6.2-1.5 (of Appendix 

6.2). III I' I I 

Natural gas fired eqUiPJ~~t- At this stage, we've not yet started bdetailed review of the emission 

calculations. As a general]¢9mment, please ensure that the emission estimates are adjusted 

accordingly for the project ~t~/SCf (HHV), particularly if emission factors or vendor 

guarantees/estimates (or b1t~) are based on a different natural ga~ heat value assumption. 

Diesel fuel-fired! equiPm~nkThere is reference to 139,000 Btu/g1al, !per the AP-42 emission 

factor. Similar to the comni~~t re: natural gas fired equipment, if there!is specifics regarding the 

potential Diesel fuel SUPPli!le~l,and fuel specifications, please ensure that emission estimates are 

adjusted, if needed. II !i \' I 

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• Startup/Shutdown (S/S) ;

I (i):ther recent PSD applications for combined-cycle projects have 

included SIS information p~dtided by the applicant to assist in our review and drafting of the 

technical support documehtl~e.g., ambient air quality impact report, statement of basis) and permit. 

I note that p. 6.2-44 preserlfs\\a summary of the SIS emissions. I have been/am in discussions with 

other permit engineers regM~ctIing sufficiency of SIS information; as you and I have discussed, I will 

be ensuring that my revie~, lir\I., consistent with others' reviews. ' III . ! 

• Transient load and shortlt~llrm NOx emissions excursions - It is noted that p. 6.2-46 includes 

.....proposed language for r\j~IX emissions excursion language in th~ conditions of certification"; 

given this italicized section!lrrfers to a proposal for the CEC's conditi0'1S for certification, please 

confirm if this also is propos~~ for the EPA PSD permit application. I I 

i I II: ! I • vac -Although vac is nO~1 ali PSD pollutant, we noted that there was reference to a 1.5 ppmvd 

vae limit (w/o duct firing) in \~ection 2 (p. 2-23); however, references in the Section 6.2 notes a 1.4 

ppmvd vee limit (e.g., p. 611·~1Il43, Table 6.2-19). Ii I 

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OK - as we continue along, 1'"lt?l~rward additit?nal-observations**, which .~lfe, at this time, observations 

that may (or may not) be related tp the upcoming comments. They are not Intended to be formal 

comments. We will provide fornhlll~1 comments as part of the letter regarding: our application 

completeness determination. ! \ I, I, ' 

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- Shirl I I

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Shirley F. Rivera I, I

U.S. EPA, Region 9, Air permits: ~ffice (AIR-3) I 75 Hawthorne St., San Francisco, CA 94105 

T: (415) 972-3966 I F: (415) ,yl3579 I Rivera.Shirley@epa.gov I I 

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