ARCHIVED REPORTS LEC APPLICATION FOR CERTIFICATION

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5.1 AIR QUALITY EPA has retained the authority to issue PSD permits for sources in the SJVAPCD. 5.1.7.1.1 Federal Prevention of Significant Deterioration Program EPA has promulgated PSD regulations for areas that are in compliance with national ambient air quality standards (40 CFR 52.21).The PSD program allows new sources of air pollution to be constructed,or existing sources to be modified,while preserving the existing ambient air quality levels,protecting public health and welfare, and protecting Class I areas (e.g., specific national parks and wilderness areas). The five principal areas of the federal PSD program are as follows: • Applicability • Best available control technology • Pre-construction monitoring • Increments analysis • Air quality impact analysis Each of these elements of the program is discussed individually below. Applicability The PSD program was established to allow emission increases (increments of consumption) that do not result in significant deterioration of ambient air quality in areas where criteria pollutants have not exceeded NAAQS. The federal PSD requirements apply on a pollutant-specific basis to any project that is a new major stationary source or a major modification to an existing stationary source.27 In the SJVAPCD,PSD requirements may be applicable for NO,SOz and CO, since the SJVAPCD is an attainment area for these pollutants. PSD requirements do not apply for VOC or PM1o, since the SJVAPCD is a nonattainment area for ozone and PM1o. The determination of applicability is based on evaluating the NO,SOz, and CO emissions changes associated with the proposed project in addition to all other emissions changes at the same location since the applicable PSD baseline dates (40 CFR 52.21). For the purposes of determining applicability of the PSD program requirements,the following regulatory procedure is used: Emissions from the existing NCPA Lodi facility are compared with major source thresholds to determine whether the existing facility is a major source. This comparison is made in Table 5.1-34. Maximum potential emissions from the LEC are compared with regulatory significance thresholds to determine whether the modification itself is major and thus may be subject to PSD. If the facility emissions exceed these thresholds,the proposed modification is subject to PSD review. The comparison in Table 5.1-35 indicates that the CO emissions from LEC exceed the major source threshold for the applicable source category,28 and thus the project is subject to PSD review. 27 These terms are defined in federal regulations at 40 CFR 52.21. 28 The determination that a combined-cycle gas turbine system is considered a"electric utility steam generating unit'for purposes of determining applicability of PSD requirements was made in an August 6,2001,letter from John Seitz, Director Office of Air Quality Planning and Standards,EPA,to Patrick M.Raher of Hogan&Hartson L.L.P(accessed at www.epa.gov/region07/programs/artd/air/nsr/nsrmemos/cgtsd.pdf. 5.1-56 SAC/371322/082410013(LEC_5.1_AIR_QUALITY.DOC)