ARCHIVED REPORTS LEC APPLICATION FOR CERTIFICATION

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APPENDIX 5.1F Offsets and Interpollutant Offset Ratio Analysis Under District Rule 2201,LEC must provide offsets for the portion of the facility emissions after modification that exceed the SJVAPCD offset thresholds. Because the proposed project is a modification to an existing stationary source,the calculation of the offset requirements must account for the emissions from the existing NCPA Lodi facility. Table 5.1F-1 shows annual proposed potential to emit from the new LEC units, the annual potential to emit for the existing units,and the total emissions from the combined facility after modification,and compares these totals with the offset thresholds to determine the offsets required for the project. TABLE 5.1 F-1 Offset Requirements for the LEC Annual Emissions, tons NOx sox VOC PM10 LEC Project Emissions 71.5 24.3 17.5 44.0 Pre-Existing PTE 20.4 5.7 25.9 8.8 Rule 2201 Offset Threshold 10.0 27.4 10.0 14.6 Emissions Required to be Offset 71.5 2.7 17.5 38.2 District Rule 2201 allows the APCO to approve interpollutant offsets on a case-by-case basis. LEC proposes to use the excess SO2 ERCs as offsets for Mo. The interpolllutant offset ratio analysis in Attachment 5.1F-1 demonstrates that ratio of 1.11 tons of SO2 for 1 ton of PMlo will provide equivalent air quality benefits as required under the NSR rules. The required quarterly calculation of offsets is provided in Table 5.1F-2. This calculation demonstrates that more than sufficient offsets are being provided to achieve the no net increase provision of the District NSR rule (Rule 2201 §1.0). Table 5.1F-3 provides a demonstration that sufficient mitigation is being provided under CEQA. Table 5.1F-4 provides documentation regarding the location and method of reduction for each ERC certificate proposed to be used for the project.