2 Attachments 

Shirley –

Attached is a copy of our PSD Supplement for Palmdale Hybrid Power Project. We will be putting 3 copies of the 

document and 3 DVDs with the modeling files in the overnight mail addressed to Gerardo today. Our modelers 

have been following the EPA guidance from OAQPS closely on the NO2 modeling, but we have not had any 

exchanges directly with Scott. Our document was pretty much complete when I got your email, but we believe 

that we have addressed the points from your email below, including the BACT. We would be happy to discuss 

after EPA has had a chance to review this submittal.

Thanks, 

Sara

Sara J. Head, QEP

Environment

RE: 16_PHPP: PSD Application Supplement 

Head, Sara 

to: 

Shirley Rivera 

07/21/2010 02:56 PM 

Cc: 

Andrew Chew, Manny Aquitania, "Kingsley, Russ" 

Hide Details 

From: "Head, Sara" <Sara.Head@aecom.com>

To: Shirley Rivera/R9/USEPA/US@EPA 

Cc: Andrew Chew/R9/USEPA/US@EPA, Manny Aquitania/R9/USEPA/US@EPA, 

"Kingsley, Russ" <Russ.Kingsley@aecom.com>

History: This message has been replied to. 

PSD Supplement cover letter.pdf Supplemental PSD Submittal 072010.pdf

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file://C:\Documents and Settings\SRIVER02\Local Settings\Temp\notesBAAA25\~web18... 7/11/2011
D 805-388-3775 ext 227 M 805-320-8059

sara.head@aecom.com

AECOM 

1220 Avenida Acaso, Camarillo, CA 93012

T 805-388-3775 F 805-388-3577

www.aecom.com 

From: Rivera.Shirley@epamail.epa.gov [mailto:Rivera.Shirley@epamail.epa.gov] 

Sent: Sunday, July 18, 2010 2:33 PM 

To: Head, Sara 

Cc: Chew.Andrew@epamail.epa.gov; Aquitania.Manny@EPAMAIL.EPA.GOV

Subject: RE: 16_PHPP: PM2.5 guidance

 

Sara, 

You are welcome. I've let Scott and other permit team members know, as well. A few items as FYI for you, just so 

you are aware - 

a) NO2 modeling - Maybe Scott has mentioned to you. We've had some exchanges with one of our other PSD 

permits re: NO2 air quality modeling; the exchanges have been specific to that particular permit (Avenal) and 

therefore specific to what they had provided. Nevertheless, I wanted to make you aware of this so you have a 

sense of the types of things we/EPA considers when evaluating NO2 modeling. Here is the link to a document online (prior to the recent NO2 memo) - 

http://www.regulations.gov/search/Regs/home.html#documentDetail?R=0900006480b07639 

Again, perhaps Scott has forwarded this to you; the point is just as an FYI. 

b) Blthye II / recent data request related to top-down BACT - As an FYI, here is was Gerardo/EPA forwarded 

to Blythe (I've cut/paste the e/m below). Again, I'm sending this as an FYI. This is not to say that you all may 

share similar data needs. Admittedly, I need to go back and look what we had provided you all as a punch list for 

additional clarification. Nevertheless, at a minimum, you can see the references to the "top-down BACT" piece. 

~~~~~~~ BEGIN CUT/PASTE ~~~~~~~~~~~~~ 

----- Forwarded by Shirley Rivera/R9/USEPA/US on 07/18/2010 02:27 PM ----- 

 

Hi David, 

Sorry for the delay in getting you this list. There were a few pieces that needed a little bit of review on my part. 

Here is what I think we need for your permit application. 

l Emergency Gen set - Please either show list of control options and show that proposed control is top 

From: Gerardo Rios/R9/USEPA/US 

To: "'David Wiseman'" <DWiseman@gb-llp.com> 

Cc: 

"Gregory Darvin" <darvin@atmosphericdynamics.com>, Jeanhee Hong/R9/USEPA/US@EPA, Carol Bohnenkamp/R9/USEPA/US@EPA, 

Shirley Rivera/R9/USEPA/US@EPA 

Date: 06/24/2010 11:16 AM 

Subject: Blythe II - List of items that needed for permit application

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option or do a top-down BACT analysis. 

l Auxiliary boilers - The top-down BACT analysis seem appears to eliminate several control options based 

on the incremental cost. For a control option that is technically feasible to be considered to be eliminated, 

the analysis needs to be done for economic, energy, and environmental impacts. The economic analysis 

needs to include a total cost analysis, not just an incremental cost. In addition, the environmental impacts 

should include a review a comparison of toxic emissions from the various control options that can be used 

to weigh the options available. While incremental costs are informative especially when modifying an 

existing piece of equipment, the total cost is more relevant for new facilities or new emissions units or 

processes. 

l Additional Impacts Analysis - We need information as outlined in the June 3, 2010 email from Shirley to 

David Wiseman on soils and vegetation, and on growth. 

l Modeling - As Carol Bohnenkamp has discussed with Greg Darvin, we will be receiving additional 

guidance on modeling for NO2 from our Headquarters (expected this week). Once we get this guidance, 

we will send it to you and we will then need to get the NO2 modeling analysis for our review.

I hope this helps clarify what needs to be submitted to us before we can determine if your application is 

complete. Feel free to give me a call if you have any questions. 

Gerardo C. Rios 

Chief, Permits Office 

Air Division 

PHONE:(415) 972-3974 

FAX: (415) 947-3579 

~~~~~~~ END CUT/PASTE ~~~~~~~~~~~~~ 

 

We can talk this week of the 19th, if needed, else after you all forward your responses. 

- Shirl 

Week of July 12: In office Mon, Wed-Fri; out of office Tues (07/13)

------------------------------------------- 

Shirley F. Rivera 

T: (415) 972-3966 | F: (415) 947-3579 | Rivera.Shirley@epa.gov | Workspace #17114 

U.S. EPA, Region 9, Air Permits Office (AIR-3) | 75 Hawthorne St., San Francisco, CA 94105 

 

Shirley – Thanks for your call yesterday. Our submittal has been floating around getting reviewed by our team the last 

couple of weeks. I am hopeful that we will get it wrapped up and submitted next week. 

Sara 

From: "Head, Sara" <Sara.Head@aecom.com> 

To: Shirley Rivera/R9/USEPA/US@EPA 

Date: 07/16/2010 07:43 PM 

Subject: 

RE: 16_PHPP: PM2.5 guidance

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