Re: Use of combined cycle for peaking service for PPEC 

Gerardo Rios to: Steve Hill 03/21/2012 04:00 PM

Cc:

Craig Kebodeaux, Dave Jenkins, 

"grchandler@apexpowergroup.com", Gary Rubenstein, "McKinsey, 

John A.", Roger Kohn, Joseph Lapka

Steve,

Thank you for forwarding the letter from Kiewit. While the letter provides interesting information for the 

evaluation of simple cycle and combined cycle turbine configurations, it does not provide the cost and 

other information that we discussed in a conference call on February 13 and the meeting on March 7. To 

reiterate, we discussed, and you agreed to provide:

l Cost data that compares construction and annual operating costs of your proposed simple cycle plant 

with a hypothetical combined cycle plant of similar capacity

l An explanation of the need for a 10 minute turbine start-up time, and why a longer startup time, e.g., 

30 minutes, would not be consistent with the operational needs of the project

Please submit the cost data as soon as possible to avoid delays on the project. Also, please provide us 

with any additional information you may have regarding the purpose of the project, if you feel it will help 

us evaluate whether or not a combined cycle operation is compatible with the type of project being 

proposed.

Also, I would like to note that the letter you emailed on 3/19/2012 regarding GHG BACT does not describe 

the maintenance tasks and associated frequency that PPEC intends to conduct for the LMS100 turbines. 

My staff had asked you to provide us with a detailed description of the tasks that PPEC expects to 

conduct, to allow us to craft maintenance conditions that, combined with a one time heat rate 

demonstration, might constitute GHG BACT for the project. If you still want us to consider this approach 

that you proposed, please provide specific details of the tasks and associated frequencies that would be 

included in the turbine maintenance plans that you referenced in the draft permit condition included in 

your letter. 

Thanks again for your attention to these issues. 

Gerardo C. Rios

Chief, Permits Office

Air Division

PHONE:(415) 972-3974

FAX: (415) 947-3579

Steve Hill As requested by EPA, PPEC is providing the at... 03/16/2012 09:28:50 AM

From: Steve Hill <SHill@sierraresearch.com>

To: Gerardo Rios/R9/USEPA/US@EPA, Roger Kohn/R9/USEPA/US@EPA

Cc: Dave Jenkins <djenkins@apexpowergroup.com>, "grchandler@apexpowergroup.com" 

<grchandler@apexpowergroup.com>, Craig Kebodeaux <Craig.Kebodeaux@kiewit.com>, 

"McKinsey, John A." <JAMCKINSEY@stoel.com>, Gary Rubenstein 

<GRubenstein@sierraresearch.com>

Date: 03/16/2012 09:28 AM

Subject: Use of combined cycle for peaking service for PPEC
As requested by EPA, PPEC is providing the attached letter from Kiewit Power, which provides a 

comparison between PPEC’s proposed turbine configuration and a combined cycle facility of 

comparable capacity. This letter is provided as an addition to the record supporting PPEC’s PSD 

permit application.

Please let me know if you have any questions.

Steve Hill[attachment "Kiewit Power - Mr Gerardo Rios - 3-16-2012 re Pio Pico Energy 

Center.pdf" deleted by Gerardo Rios/R9/USEPA/US]