### AMENDED
PREVENTION OF SIGNIFICAN T DETERIORATION PERMIT
ISSUED PURSUANT TO THE REQUIREMENTS AT 40 CFR § 52.21

U.S. ENVIRONMENTAL PROTECTION AGENCY , REGION IX

PSD PERMIT NUMBER: SJ 08-01

PERMITTEE: Avenal Power Center, LLC 500 Dallas Street, Level 31 Houston, TX 77002

FACILITY NAME: Avenal Energy Project

FACILITY LOCATION: 33119 Avenal Cutoff Road Avenal, California 93204

Pursuant to the provisions of the Clean Air Act (CAA), Subchapter I, Part C (42 U.S.C. Section 7470, et. seq. ), and the Code of Federal Regulatio ns (CFR) Title 40, Section 52.21, the United States Environmental Protection Agency Region 9 (EPA) is issuing an amended Prevention of Significant Deterioration (PSD) permit to the Avenal Power Center, LLC (APC). The Permit applies to the construction and operation of a new 600 megawatt (MW, nominal) natural gasfired combined-cycle power plant known as the Avenal Energy Project (AEP) in Avenal,
California. This Amended PSD Permit revises the PSD permit issued to APC on May 27, 2011,
with the revisions a pplicable immediately.

APC is authorized to construct and operate the AEP power plant as described herein, in accordance with the permit application (and plan s submitted with the permit application), the federal PSD regulations at 40 CFR § 52.21, and othe r terms and conditions se t forth in this PSD Permit. Failure to comply with any condition or term set forth in this PSD Permit may result in enforcement action pursuant to Section 113 of the Clean Air Act. This PSD Permit does not relieve APC from the responsibility to comply wi th any other applicable provisions of the Clean Air Act (including applicable implementing regulations in 40 CFR Parts 51, 52, 60, 61, 63, and 72 through 75), or other federal, state, and Sa n Joaquin Valley Air Pollution Control District (District) requirements.

Per 40 CFR § 124.15(b), this PSD Permit becomes effec tive 30 days after the service of notice of
th e is final permit decision on May 27, 2011 unless review is requested on the permit pursuant to 40 CFR § 124.19.

Gina McCarthy Date
Assistant Administrator2 Avenal Energy Project (SJ 08-01)
Amended PSD Permit May June 2011 AVENAL ENERGY PROJECT (SJ 08-01)
PREVENTION OF SIGNIFI CANT DETERIORATION PERMIT
AMENDED FINAL PERMIT CONDITIONS

PROJECT DESCRIPTION

The Facility is a combined-cycle power plant capable of generating up to 600 megawatts (MW, nominal) of net power. Electrical power will be generated from the combustion of natural gas in two 180 MW (nominal) combustion turbine genera tors (CTG). Exhaust from each gas turbine will flow through a dedicated Heat Recovery Steam Generator (HRSG) to produce steam to power a shared 300 MW (nominal) Steam Turb ine Generator (STG). Each HRSG will be equipped with natural gas-fi red duct burners to augment steam production during peaking operation. Each of the CTGs will be equipped with dry low-NOx (DLN) combustors. The Facility will install selective catalytic reducti on (SCR) and oxidation catalyst (Ox-Cat) systems. Additional equipment includes a natural gas-fired auxiliary boiler, which is used to provide steam for auxiliary purposes such as when the pl ant is off-line or during startup, equipped with an ultra low-NOx burner, a natural gas-fire d emergency generator equipped with a postcombustion integrated SCR/oxidation catalyst syst em, and a diesel-fired emergency firewater pump engine with a turbocharger and an intercooler/aftercooler.

The Facility is subject to the Prevention of Significant De terioration (PSD) Program for
emissions of Carbon Monoxide (CO), Nitrogen Dioxide (NO 2 ), Particulate Matter (PM), and
Particulate Matter of less than or equal to 10 micrometers ( μ m) in diameter (PM 10 ).

EQUIPMENT LIST

The following devices are subject to this PSD permit:

Unit ID Description

GEN1 • 180 MW Combustion Turbine Generator (C TG), with a maximum heat input rate of 1,856.3 MMBtu/hr, high heating value (HHV)

• Natural gas-fired General El ectric Model Frame 7FA

• Vented to a dedicated Heat Recovery Steam Generator (HRSG) and a 300 MW Steam Turbine Generator (STG) shared with GEN2

• Emissions of NO

x and CO controlled by Dry Low-NO

x (DLN) Combustors, Selective Catalytic Reduction (SCR), a nd an Oxidation Catalyst (Ox-Cat)

GEN2 • 180 MW CTG, with a maximum heat input rate of 1,856.3 MMBtu/hr (HHV)

• Natural gas-fired General El ectric Model Frame 7FA

• Vented to a dedicated HRSG and a 300 MW STG shared with GEN1

• Emissions of NO

x and CO controlled by DLN combustors, SCR and an Ox-Cat3 Avenal Energy Project (SJ 08-01)
Amended PSD Permit May June 2011

Unit ID Description

DB1 • 562.26 MMBtu/hr (HHV) Duct Burner for GEN1, fired on natural gas

DB2 • 562.26 MMBtu/hr (HHV) Duct Burner for GEN2, fired on natural gas

D1 • 37.4 MMBtu/hr (HHV) Auxiliary Boiler with ultra low-NO

x burner, fired on natural gas

D2 • 550 kW (860 hp) Emergency Internal Combustion (IC) Engine, fired on natural

gas

• Emissions of NO

x and CO controlled by post-combustion integrated SCR/oxidation catalyst system

D3 • 288 hp Emergency Diesel-fired IC Engine Firewater Pump Engine

• Equipped with a turbocharger a nd an intercooler/aftercooler

PERMIT CONDITIONS

I. PERMIT EXPIRATION

As provided in 40 CFR § 52.21(r), this PSD Perm it shall become invalid if construction:

A. is not commenced (as defined in 40 CFR § 52.21(b)(9)) within 18 months after the approval takes effect; or

B. is discontinued for a period of 18 months or more; or

C. is not completed within a reasonable time.

II. PERMIT NOTIFICATION REQUIREMENTS

Permittee shall notify EPA Region IX by le tter or by electronic mail of the:

A. date construction is commenced, postmar ked within 30 days of such date;

B. actual date of initial startup, as de fined in 40 CFR § 60.2, postmarked within 15 days of such date;

C. date upon which initial performance test s will commence, in accordance with the provisions of Condition X.G, postmarked not less than 30 days prior to such date. Notification may be provided with the s ubmittal of the performance test protocol required pursuant to Condition X.G; and

D. date upon which initial performance ev aluation of the continuous emissions monitoring system (CEMS) will commence in accordance with 40 CFR §4 Avenal Energy Project (SJ 08-01)
Amended PSD Permit May June 2011 60.13(c), postmarked not less than 30 days prior to such date . Notification may be provided with the submittal of the CE MS performance test protocol required pursuant to Condition X.F.

III. FACILITY OPERATION

At all times, including periods of star tup, shutdown, shakedown, and malfunction, Permittee shall, to the extent practicable, maintain and operate the Facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the EPA, which may include, but is not limited to, monitoring results, opacity observations, review of operating maintenance pr ocedures and inspection of the Facility.

IV. MALFUNCTION REPORTING

A. Permittee shall notify EP A at R9.AEO@epa.gov within two (2) working days following the discovery of any failure of air pollution control equipment, process equipment, or of a process to operate in a normal manner, which results in an
increase in emissions above the allowabl e emission limits stated in Section X of this permit.

B. In addition, Permittee shall provide an a dditional notification to EPA in writing or electronic mail within fifteen (15) days of any such failure described under
Condition IV.A. This notification sh all include a description of the malfunctioning equipment or abnormal operation, the date of the initial malfunction, the period of time over which emissions were increased due to the failure, the cause of the failure, the estimated resultant emissions in excess of those allowed in Section X, and the met hods utilized to mitigate emissions and restore normal operations.

C. Compliance with this malfunction notif ication provision shall not excuse or otherwise constitute a defense to any violation of this permit or any law or regulation such malfunction may cause.

V. RIGHT OF ENTRY

The EPA Regional Administrator, and/or an authorized representative, upon the presentation of credentials, shall be permitted:

A. to enter the premises where the Facil ity is located or where any records are5 Avenal Energy Project (SJ 08-01)
Amended PSD Permit May June 2011 required to be kept under the terms and conditions of this PSD Permit;

B. during normal business hours, to have access to and to copy any records required to be kept under the terms and conditions of this PSD Permit;

C. to inspect any equipment, operation, or method subject to requirements in this PSD Permit; and

D. to sample materials and emissions from the source(s).

VI. TRANSFER OF OWNERSHIP

In the event of any changes in control or owne rship of the Facility to be constructed, this PSD Permit shall be binding on all subseque nt owners and operators. Permittee shall notify the succeeding owner and operator of th e existence of this PSD Permit and its conditions by letter, a copy of that shall be forwarded to EPA Regi on IX within thirty (30) days.

VII. SEVERABILITY

The provisions of this PSD Permit are severa ble, and, if any provision of the PSD Permit is held invalid, the remainder of th is PSD Permit shall not be affected.

VIII. ADHERENCE TO APPLICATIO N AND COMPLIANCE WITH OTHER
ENVIRONMENTAL LAWS

Permittee shall construct this project in comp liance with this PSD permit, the application on which this permit is based and all other app licable federal, state, and local air quality regulations. This PSD permit does not rel ease the Permittee from any liability for compliance with other applicable federal, state and local environmental laws and regulations, including the Clean Air Act.



### IX. RESERVED6 Avenal Energy Project (SJ 08-01)
Amended PSD Permit May June 2011 

### X. SPECIAL CONDITIONS

A. Annual Facility Emission Limits

1. Annual emissions, in tons per year (tpy) on a 12-month rolling average basis, shall not exceed the following:

NO
x CO PM PM 10

Total Facility 144.3 tpy 602.7 tpy 80.7 tpy 80.7 tpy

2. Only Public Utilities Commission (PUC)-qua lity pipeline natural gas shall be fired at this Facility. PUC-quality pipeline natural gas shall not exceed a sulfur content of 0.36 grains per 100 dry standard cubic feet on a 12-month rolling average basis and shall not exceed a sulfur content of 1.0 grains per 100 dry standard cubic feet, at any time.

B. Air Pollution Control Equipment and Operation

As soon as practicable following initial startup of the power plant (startup as defined in 40 CFR § 60.2) but prior to commencement of commercial operation (as defined in 40 CFR § 72.2), and thereafte r, except as noted below in Condition X.D, the Permittee shall install, continuous ly operate, and maintain: (1) the SCR systems for control of NO

x and the Ox-Cat systems for control of CO for Units GEN1 and GEN2, and (2) the post-combus tion integrated SCR/oxidation catalyst system for control of NO

x and CO for D2. Permittee shall also perform any necessary operations to minimize emissions so that emissions are at or below the emission limits specified in this permit.

C. Combustion Turbine Generator (CTG) Emission Limits

1. Except as noted below under Condition X. D, on and after the date of initial startup, Permittee shall not discharge or cause the discharge of emissions from each CTG Unit (of GEN1 and GEN2) into the atmosphere in excess of the following:7 Avenal Energy Project (SJ 08-01)
Amended PSD Permit May June 2011 Emission Limit (per CTG) (no duct burning) Emission Limit (per CTG) (with duct burning)

NO
x • 13.55 lb/hr

• 1-hr average

• 2.0 ppmvd @ 15% O 2 • 17.20 lb/hr

• 1-hr average

• 2.0 ppmvd @ 15% O 2

CO 3-Year Demonstration Period

• 8.35 lb/hr

• 1-hr average

• 2.0 ppmvd @ 15% O 2

Post-Demonstration Period

• 6.27 lb/hr

• 1-hr average

• 1.5 ppmvd @ 15% O 2

Conditions in X.C.3 may affect the timing and applicability of post-demonstration period
emission limits. • 10.60 lb/hr

• 1-hr average

• 2.0 ppmvd @ 15% O 2

PM / PM10 • 8.91 lb/hr

• 12-month rolling average

• PUC-quality pipeline natural gas • 11.78 lb/hr

• 12-month rolling average

• PUC-quality pipeline natural gas

2. Annual heat input to each duct burner (DB1 and DB2) shall not exceed 449,800 MMBtu per 12-month rolling period. The Permittee shall ensure that the duct burners are not operated unless the associated turbine units are in operation.

3. CO Emissions Limit Demonstration Pe riod – The Demonstration Period is defined as the first 3 years immedi ately following the commencement of commercial operations.

a. The Permittee shall design the gas turbines to achieve a CO emission rate of 1.5 ppmvd @ 15% O 2 and 6.27 lb/hr over a 1-hour period without duct firing. Prior to construction, the Permittee shall submit design specifications to EPA as proof that the gas turbines were designed to achieve such a rate. The Permittee shall also submit a plan to EPA that sets8 Avenal Energy Project (SJ 08-01)
Amended PSD Permit May June 2011 forth the measures that will be taken to maintain the system and optimize its performance.

b. During the Demonstration Period, the Permittee shall operate the gas turbines according to the design sp ecifications, within the design parameters, and consistent with the maintenance and performance optimization plan described above in Condition X.C.3.a. During the
Demonstration Period the Permittee sh all not discharge or cause the discharge of CO emissions from each CTG Unit (GEN1 and GEN2) into the atmosphere in excess of the following amounts over a 1-hour averaging period: 2.0 ppmvd CO @ 15% O 2 and (1) 10.60 lb/hr with duct firing or (2) 8.35 lb/hr with or without duct firing over a 1

- hour averaging period

.

c. Following the Demonstration Period, th e Permittee shall not discharge or cause the discharge of CO emissions from each CTG Unit (GEN1 and GEN2) into the atmosphere in excess of the following amounts over a 1- hour averaging period except as specified in Condition X.C.3.d:

i. 1.5 ppmvd @ 15% O 2 without duct firing;

ii. 2.0 ppmvd @ 15% O 2 with duct firing;

iii. 6.27 lb/hr without duct firing; and

iv. 10.60 8.35 lb/hr with duct firing.

d. If, during the Demonstration Period, th e Permittee determines that the CO limits in Conditions X.C.3.i or X.C.3.iii are not feasible, the Permittee shall submit an application to EPA pr ior to the end of the Demonstration Period requesting a revision of those limits. Such an application must
contain data and information that de monstrates that the Facility was operated according to the design specif ications and parameters, and the maintenance and performance optimization plan, identified above in Condition X.C.3.a, as well as a techni cal justification explaining why the lower limits are not feasible. If, after the applicable review process following such a submission (which w ill include an opportunity for public review and comment), it is determin ed through data and information gathered during the Demonstration Pe riod that different CO limits are necessary, the limits in Condition X.C.3.i and X.C.3.iii will be revised accordingly. Provided that the appli cation specified in this condition is postmarked prior to the end of th e Demonstration Period, the emission
limits in Condition X.C.3.b shall remain in effect until EPA evaluates the application and makes a final decision regarding the revision of the limits9 Avenal Energy Project (SJ 08-01)
Amended PSD Permit May June 2011 in Conditions X.C.3.i or X.C.3.iii.

D. Requirements during Gas Turbine (GEN1 and GEN2) Startup and
Shutdown

1. Startup is defined as the period of time during which a unit is brought from a shutdown status to its operating temper ature and pressure, including the time required by the unit’s emission control system to reach full operations and demonstrate compliance with Conditions X.C.

2. Shutdown is defined as the period be ginning with the lowering of equipment from normal operating load to minimum operating load and lasting until fuel flow is completely off and combustion has ceased.

3. During startup and shutdown periods emissions from each CTG and associated HRSG unit, verified by th e CEMS, shall not exceed the following:

NO
x CO

Each CTG and HRSG Startup / Shutdown 160 lb/hr 1,000 lb/hr

Both CTG and HRSG
Combined Startup / Shutdown 240 lb/hr 1,902 lb/hr

Event
Duration Annual Limit for
Both CTG
Combined

Each CTG and HRSG Startup 4.50 hours
1,248 hours/yr Each CTG and HSRG
Shutdown 0.50 hour

4. The Permittee must operate the CEMS during startups and shutdowns.

5. The Permittee must record the time, da te, and duration of each startup and
shutdown event. The records must include calculations of NO

x and CO emissions during each event based on the CEMS data. These records must be kept for five years following the date of such event.10 Avenal Energy Project (SJ 08-01)
Amended PSD Permit May June 2011 6. During startup, the CTG and HRSG emi ssions shall comply with Condition X.D.3, and the SCR system, including amm onia injection, shall be operated in a manner to minimize emissions, as technol ogically feasible, and not later than when the load reaches 60% of plant net output.

E. Auxiliary Combustion Equipment Emission Limits

1. At all times, including equipment st artup and shutdown, Permittee shall not discharge, or cause the discharge of emissions from each unit into the atmosphere, in excess of the following :

Unit ID NO
x CO PM and PM 10 Restrictions on Usage

Unit D1
37.4 MMBtu/hr (HHV) Boiler • 9 ppmvd @
3% O 2

• 3-hr average • 50 ppmvd @
3% O 2

• 3-hr average • 0.0034 gr/dscf

• PUC-quality pipeline natural gas • 46,675 MMBtu/yr

Unit D2 550 kW (860 hp) engine • 1.0 g/hp-hr • 0.21 g/hp-hr • PUC-quality pipeline natural

gas

• 0.34 g/hp-hr • 50 hrs/yr

Unit D3 288 hp firewater

pump • 3.4 g/hp-hr • 0.447 g/hphr • Use of ultra-low sulfur fuel, not to exceed 15 ppmvd
fuel sulfur • 50 hrs/yr

2. Unit D1 shall not operate during normal operations of GEN1 or GEN2, except during periods of, or immediately follo wing, startup. Unit D1 shall be shut down as soon as practicable after the completion of any startup process as
defined in Condition X.D.1.

3. Unit D2 restrictions on usage shall be lim ited to operation of the engine for all maintenance and testing.

4. Unit D3 restrictions on usage shall be limited to the total hours of operations for all maintenance and testing.

5. Units D2 or D3 shall not operate dur ing startup of GEN1 or GEN2, except when Units D2 or D3 are required for emergency operations.11 Avenal Energy Project (SJ 08-01)
Amended PSD Permit May June 2011 F. Continuous Emissions Monitoring System (CEMS) for GEN1 and GEN2

1. At the earliest feasible opportunity after first fire of GEN1 and GEN2 and
before GEN1 and GEN2 commence co mmercial operation (as defined in 40 CFR § 72.2), in accordance with the recommendations of the equipment
manufacturer and the constr uction contractor, Permittee sh all install, calibrate, and operate a CEMS each for GEN1 and GEN2 that measures stack gas NOx, CO, and O 2 or CO 2 concentrations in ppmv. Th e concentrations shall be
corrected to 15% O 2 on a dry basis. No later than the end of the shakedown period as defined in Condition X.J. or upon commencing commercial operations, whichever comes first, Perm ittee shall also maintain, certify, and quality-assure a CEMS for each CTG that measures stack gas NO

x , CO, and
O 2 concentrations in ppm v, and shall is required to conduct initial certification
of the CEMS in accordance with Condition X.F.6. The concentrations shall be
corrected to 15% O 2 on a dry basis.

2. The NO

x and O 2 CEMS shall meet the appli cable requirements of 40 CFR

Part 75.

3. The CO CEMS shall meet the applic able requirements of 40 CFR Part 60 Appendix B, Performance Specification 4, and 40 CFR Part 60 Appendix F, Procedure 1, except the relative accur acy specified in se ction 13.2 of 40 CFR Part 60 Appendix B, Performance Specifica tion 4 shall not exceed 20 percent.

4. Each CEMS shall complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15-minute clock-hour period.

5. The CEMS shall be tested in accordance with Conditions X.F.2 and X.F.3.

6. The initial certification of the CEMS may either be conducted separately, as specified in 40 CFR § 60.334(b )(1) or as part of the in itial performance test of
each emission unit. CEMS must unde rgo and pass initial performance specification testing on or before the da te of the initial performance test.

7. CEMS shall meet the requirements of 40 CFR § 60.13. Data sampling, analyzing, and recording shall also be adequate to demonstrate compliance with emission limits during startup and shutdown.

8. Not less than 90 days prior to the date of initial startup of the Facility, the Permittee shall submit to the EPA a quality assurance project plan for the certification and operation of the continuous emission monitors. Such a plan12 Avenal Energy Project (SJ 08-01)
Amended PSD Permit May June 2011 shall conform to EPA requirements c ontained in 40 CFR Part 60 Appendix F for CO, 40 CFR Part 75 for NO

x and O 2 or CO 2 , and 40 CFR Part 75 Appendix B for stack flow. The plan shall be updated and resubmitted upon request by EPA. The protocol shall speci fy how emissions during startups and shutdowns will be determined and calculated, including quantifying flow accurately if calculations are used.

9. The gas turbine CEMS shall be audite d quarterly and tested annually in accordance with 40 CFR Part 60 Appendi x F, Procedure 1. Permittee shall perform a full stack traverse during initi al run of annual RATA testing of the CEMS, with testing points selected a ccording to 40 CFR Part 60 Appendix A,
Method 1.

10. Permittee shall submit a CEMS performan ce test protocol to the EPA no later than 30 days prior to the test date to allow review of the test plan and to arrange for an observer to be present at the test. The performance test shall be conducted in accordance with the submitted protocol and any changes required by EPA.

11. Permittee shall furnish the EPA a written report of the results of performance tests within 60 days of completion.

12. The stack gas volumetric flow rates shall be calculated in accordance with the fuel flowmeter requirements of 40 CF R Part 75 Appendix D in combination with the appropriate pa rts of EPA Method 19.

13. Prior to the date of initial startup of GEN1 and GEN2, Permittee shall install, and thereafter maintain and operate, continuous monitoring and recording systems to measure and record the following operational parameters:

a. The ammonia injection rate of the ammonia injection system of the SCR system.

b. The plant output as noted in Condition X.D.6.

G. Performance Tests

1. Stack Tests

a. Within 60 days after achieving norm al operation, but not later than 180 days after the initial star t-up of equipment, and, unless otherwise specified, annually thereafter (within 30 days of the initial performance test13 Avenal Energy Project (SJ 08-01)
Amended PSD Permit May June 2011 anniversary), Permittee shall conduct pe rformance tests (as described in 40 CFR § 60.8) as follows:

i. NO
x , CO, PM, and PM 10 emissions from each gas turbine (Units GEN1/DB1 and GEN2/DB2),

ii. NO
x , and CO emissions from the 37.4 MMBtu/hr boiler (D1); PM and

PM 10 emissions from the 37.4 MMBtu/hr boiler (D1) shall be tested initially and at least every five y ears (within 30 days of the initial performance test anniversary)

iii. NO
x , CO, PM, and PM 10 emissions from the 550 kW (860 hp) internal combustion engine (D2), only upon notification by EPA

iv. NO
x , CO, PM, and PM 10 emissions from the 288 hp firewater pump (D3), only upon notification by EPA

b. Permittee shall submit a performance test protocol to EPA no later than 30 days prior to the test to allow review of the test plan and to arrange for an observer to be present at the test. The performan ce test shall be conducted in accordance with the submitted protocol, and any changes required by
EPA.

c. Performance tests shall be conducted in accordance with the test methods set forth in 40 CFR § 60.8 and 40 CF R Part 60 Appendix A, as modified below. In lieu of the specified test methods, equivalent methods may be used with prior written approval from EPA:

i. EPA Methods 1-4 and 7E for NO

x emissions measured in ppmvd

ii. EPA Methods 1-4, 7E, and 19 for NO

x emissions measured on a heat input basis

iii. EPA Methods 1-4 and 10 for CO emissions

iv. EPA Methods 5 and 202, or Methods 201A and 202, for both PM and

PM 10 , in accordance with the test methods set forth in 40 CFR § 60.8, 40 CFR Part 60 Appendix A, and 40 CFR Part 51 Appendix M. In lieu of Method 202, the Permittee may use EPA Conditional Test Methods for particulate matter: CTM-039.

v. the provisions of 40 CFR § 60.8 (f).

d. The initial performance test conducted af ter initial startup shall use the test procedures for a “high NO 2 emission site,” as specified in San Diego Test Method 100, to measure NO

x emissions. The source shall be classified as either a “low” or “high” NO 2 emission site based on th ese test results. If
the emission source is classified as a:

i. “high NO 2 emission site,“ then each subs equent performance test shall14 Avenal Energy Project (SJ 08-01)
Amended PSD Permit May June 2011 use the test procedures for a “high NO 2 emission site,” as specified in San Diego Test Method 100.

ii. “low NO 2 emission site,” then the test procedures for a “high NO 2 emission site,” as specified in San Diego Test Method 100, shall be performed once every five years to ve rify the source's classification as
a “low NO 2 emission site.”

e. The performance test methods for NO

x emissions specified in Condition X.G.1.c.i and ii., may be modified as follows:

i. Perform a minimum of 9 reference method runs, with a minimum time per run of 21 minutes, at a single load level, between 90 and 100 percent of peak (or the highest physically achievable) load.

ii. Use the test data both to demonstr ate compliance with the applicable
NO
x emission limit and to provide the required reference method data
for the RATA of the CEMS.

f. Upon written request and adequate jus tification from the Permittee, EPA may waive a specific annual test and/or allow for testing to be done at less than maximum operating capacity.

g. For performance test purposes, sampli ng ports, platforms, and access shall be provided on the emission unit exhaust system in accordance with the requirements of 40 CFR § 60.8(e).

h. Permittee shall furnish the EPA a written report of the results of performance tests within 60 days of completion.

2. Fuel Testing

a. Permittee shall take monthly samples of the natural gas combusted. The samples shall be analyzed for sulfur content using an ASTM method. The
sulfur content test results shall be retained on site and taken to ensure compliance with Special Conditions X.C and X.E for Units GEN1/DB1, GEN2/DB2, D1, and D2.

H. Monitoring for Auxiliary Combustion Equipment

1. Permittee shall install and maintain an operational non-resettable totalizing
mass or volumetric flow meter in each fuel line for the 37.4 MMBtu /hr boiler (Unit D1).

2. Permittee shall install and maintain an operational non-resettable elapsed time meter for the 550 kW emergency use engine (Unit D2) and the 288 hp15 Avenal Energy Project (SJ 08-01)
Amended PSD Permit May June 2011 emergency-use firewater pump (Unit D3).

I. Recordkeeping and Reporting

1. Permittee shall maintain a file of all records, data, measurements, reports, and documents related to the operation of the Facility, including, but not limited to, the following: all records or report s pertaining to adjustments and/or maintenance performed on any system or device at the Facility; all records relating to performance tests and monitoring of auxiliary combustion equipment; for each diesel fuel oil deliv ery, documents from the fuel supplier certifying compliance with the fuel su lfur content limit of Special Condition X.E for Unit D3; and all other informati on required by this pe rmit recorded in a permanent form suitable for inspection. The file must be retained for not less than five years following the date of such measurements, maintenance, reports, and/or records.

2. Permittee shall maintain CEMS records that include the following: the occurrence and duration of any startu p, shutdown, shakedown, or malfunction, performance testing, evaluations, ca librations, checks, adjustments, maintenance, duration of any periods during which a continuous monitoring system or monitoring device is i noperative, and corresponding emission

measurements.

3. Permittee shall maintain records of all source tests and monitoring and compliance information required by this permit.

4. Permittee shall maintain records and submit a written report of all excess emissions to EPA semi-annually, except when: more frequent reporting is specifically required by an applicable s ubpart; or the Administrator, on a caseby-case basis, determines that more frequent reporting is necessary to accurately assess the compliance status of the source. The report is due on the

30 th day following the end of each semi -annual period and shall include the following:

a. Time intervals, data and magnit ude of the excess emissions, the nature and cause (if known), corrective actions taken and preventive measures adopted;

b. Applicable time and date of each period during which the CEMS was inoperative (monitor down-time), excep t for zero and span checks, and the nature of CEMS repairs or adjustments;

c. A statement in the report of a nega tive declaration; that is, a statement16 Avenal Energy Project (SJ 08-01)
Amended PSD Permit May June 2011 when no excess emissions occurred or when the CEMS has not been inoperative, repaired, or adjusted;

d. Any failure to conduct any require d source testing, monitoring, or other compliance activities; and

e. Any violation of limitations on operation, including but not limited to restrictions on hours of operation.

5. Excess emissions shall be defined as any period in which the Facility emissions exceed the maximum emission limits set forth in this permit.

6. A period of monitor down-time sha ll be any unit operating clock hour in
which sufficient data are not obtai ned to validate the hour for NO

x , CO or O 2 , while also meeting the requi rements of Condition X.F.7.

7. Excess emissions indicated by the CEM system, source testing, or compliance monitoring shall be considered violations of the applicable emission limit for the purpose of this permit.

8. All records required by this PSD Permit sh all be retained for not less than five years following the date of such meas urements, maintenance, and reports.

J. Shakedown Periods

The combustion turbine emission limits and requirements in Conditions X.C, X.D, and X.E shall not apply during co mbustion shakedown periods. Shakedown is defined as the period beginning with initial startup and ending no later than initial performance testing, during whic h the Permittee conducts operational and contractual testing and tuning to ensure the safe, efficien t and reliable operation of the plant. The shakedown period shall not exceed 90 days. The requirements of Section III of this permit shall apply at all times.17 Avenal Energy Project (SJ 08-01)
Amended PSD Permit May June 2011 XI. ACROYNMS AND ABBREVIATIONS

AEP Avenal Energy Project
APCD Air Pollution Control District ASTM American Society fo r Testing and Materials
Btu British Thermal Unit CEMS Continuous Emissions Monitoring System CFR Code of Federal Regulations
CO Carbon Monoxide
CTG Combustion Turbine Generator District San Joaquin Valley Ai r Pollution Control District DLN Dry Low NOx (d)scf (dry) Standard Cubic Feet EPA Environmental Protection Agency g Grams gr Grains HHV Higher Heating Value HRSG Heat Recovery Steam Generator hp Horsepower
hr Hour
kW Kilowatt
lbs Pounds
MMBtu Million British Thermal Units MW Megawatt
NO 2 Nitrogen Dioxide
NO
x Oxides of Nitrogen NSCR Non-Selective Catalytic Reduction
OTM Other Test Method Ox-Cat Oxidation Catalyst
O 2 Oxygen
PM Total Particulate Matter

PM 10 Particulate Matter with aerodynamic diameter less than 10 micrometers ppmvd Parts Per Million by Volume, Dry basis ppmv Parts Per Million by Volume PSD Prevention of Significant Deterioration
PUC Public Utilities Commission RATA Relative Accuracy Test Audit SCR Selective Catalytic Reduction
STG Steam Turbine Generator tpy Tons Per Year

μ m micrometers yr Year18 Avenal Energy Project (SJ 08-01)
Amended PSD Permit May June 2011 XII. AGENCY NOTIFICATIONS

All correspondence as require d by this Approval to Constr uct must be forwarded to:

A. Director, Air Di vision (Attn: AIR-5) EPA Region IX
75 Hawthorne Street San Francisco, CA 94105-3901

Email: R9.AEO@epa.gov Fax: (415) 947-3579

B. Air Pollution Control Officer San Joaquin Valley Air Pollution Control District 1990 E. Gettysburg Avenue Fresno, CA 93726-0244

Email: sjvapcd@valleyair.org Fax: (559) 230-6061