March 19, 2012

Mr. Gerardo Rios Chief, Permits Office U.S. EPA Region 9

75 Hawthorne Street San Francisco, CA 94105

Subject: Pio Pico Energy Ce nter PSD Permit Application Response to Supplemental Information Request

Dear Mr. Rios:

As requested by EPA during the Februa ry 13, 2012 conference call between representatives of EPA and Pi o Pico Energy Center, LLC (Applicant), we are submitting this additional information on behalf of Applicant.



### Proposed Language for GHG BACT

Comment: It is known that tu rbine efficiency tends to decrea se over the lifetime of the turbine, even under the best of circumstan ces. If EPA imposed a single numerical limit that would apply to the turbine over its lifetim e, it would either be too low for a new unit, or too high for a unit at the end of its life cycle, or both. EPA is therefore considering defining GHG BACT as an initial demonstrati on of turbine efficie ncy, coupled with ongoing maintenance. Please provide sugge sted language for EPA’s consideration.

Response: Applicant proposes the following language:

1. GHG BACT requirements

a. Performance Test

i. Within 60 days after achieving norm al operation, but not later than 180 days after the ini tial startup of equipment, Permittee shall conduct a performance test to dem onstrate the thermal efficiency (btu hhv /kw-hr net ) of each turbine at maximum capacity. Each

turbine shall meet one of the fo llowing requirements, depending upon the conditions at the time of the test:

1. Less than 8,647 btu/kw-hr below 30oF ambient
temperature; or
2. Less than 8,747 btu/kw-hr betw een 30oF and 63oF ambient
temperature; or
3. Less than 8,929 btu/kw-hr betw een 63oF and 110oF ambient
temperature. 

## sierra research

1801 J Street Sacramento, CA 95811 Tel: (916) 444-6666 Fax: (916) 444-8373

Ann Arbor, MI Tel: (734) 761-6666 Fax: (734) 761-6755Gerardo Rios -2- March 19, 2012

b. Monitoring

i. Permittee shall measure and record, for each turbine, the following:

1. Net energy output (MWh net ) on an hourly basis

2. Fuel consumption (MMSCF of natural gas) on an hourly

basis

c. Maintenance requirements

i. Permittee shall maintain each turbine, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions.

ii. Permittee shall prepare a Maintenanc e Plan for each turbine. The

Maintenance Plan shall follow manuf acturer’s writte n instructions or operator-developed procedures that provide, to the extent practicable, for the maintenance a nd operation of the engine in a manner consistent with good ai r pollution control practice for minimizing emissions.

iii. Permittee shall maintain each turb ine according to the Maintenance

Plan.

d. Recordkeeping requirements

i. Permittee shall maintain a log describing maintenance and repair activities, including the following information:

1. Date of activity

2. Description of activity

3. For scheduled maintenance, the elapsed time, hours of turbine operation, or other applicable measure since the activity was last performed.

4. For scheduled maintenance, the elapsed time, hours of turbine operation, or other applicable measure until the activity should next be performed.

The proposed thermal efficiency limits ar e based on GE performance projections for clean and new equipment at the uppe r end of each temperature range.



### Summary of PM 2.5 

### NAAQS Compliance Calculation

Comment: Please show the calculations and relevant data used to demonstrate compliance with the 24-hour and annual PM 2.5 NAAQS.

Response: The requested calculations are presented in Tables 1 and 2 for the 24-hour and annual average standards, respectively. Compliance with the 24-hour standard is demonstrated using the receptor with the highest five-year average of 98 th percentile of cumulative impacts (project plus nearby sources plus background).Gerardo Rios -3- March 19, 2012

Table 1

24-hr PM 2.5 NAAQS Compliance Calculation (μg/m 3 )

Data are for 98 th percentile day for each year Standard = 35 μg/m 3

Year 2004 2005 2006 2007 2008 Five-Year Average

Date March 20 March 11 Feb. 26 Nov. 8 Jan. 10

Project Impact (μg/m 3 ) 0.2 0.2 0.1 0.3 0.3 0.2

Cumulative Impact (μg/m 3 ) 0.8 0.5 0.5 0.9 0.9 0.7

Regional Background (μg/m 3 ) 30.0 28.0 24.0 27.0 26.0 27.0

Total Impact

with Background 30.8 28.5 24.5 27.9 26.9 27.7

Compliance with the annual standard is dem onstrated using a scr eening approach, where the highest background value in the five-year period is adde d to the highest cumulative impact. Because the result is below the st andard, more refined calculations were not

made.

Table 2

Annual PM 2.5 NAAQS Compliance Calculation (μg/m 3 ) Standard = 15 μg/m 3

Year 2004 2005 2006 2007 2008 Maximum

Background 12.2 11.8 11.2 12.5 12.3 12.5

Cumulative Max 1.4 1.5 1.5 1.6 1.9 1.9

Total 14.4

Sincerely,

Steve Hill

cc: John McKinsey, Stoel Rives LLP David Jenkins, Apex Power Group Steve Moore, SDAPCD