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 ,'

1

I I III 

### • 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

### ~~:flvailable for each of the sections subnlitted. For various reasons, this would make our

### revi~wll: ,process.

I: ;, 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 I 

### l great. We would use the worksheet for our streamlining our internall 

### ,' f8view process and would **not** distribute to others. iii

I

IIIII 

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

# I~t IIII!I

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 TVii w 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 ',II

i: i II if I i I II1 1 I • 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?,!~,tl h/year? (And I have reviewed Table 6.2-1.5 of the APprr X .) 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 : IIII I 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

I

I\ I '

I

I, 

### I 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 

# b detailed 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~nk There 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

'll • 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
,! \ I 

### 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 ! 1 : I 

### ------------------------------------------' IShirley 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) 

# ,y l 3579 

## I Rivera.Shirley@epa.gov 

# I I

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