ARCHIVED REPORTS LEC APPLICATION FOR CERTIFICATION

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5.1 AIR QUALITY 5.1.4 Best Available Control Technology Evaluation 5.1.4.1 Current Facility Control Technologies The existing NCPA gas turbine is an aeroderivative LM5000 STIG unit that uses steam injection for NO,,control and power augmentation. The gas turbine also uses selective catalytic reduction(SCR) and an oxidation catalyst to achieve additional NOX control and to control CO emissions,respectively. NOX emissions are limited to 3.0 ppmvd and CO emissions are limited to 200 ppmvd,both corrected to 15% 02 on a 3-hour rolling average basis. 5.1.4.2 Proposed Facility Best Available Control Technology BACT is defined in 40 CFR 52.210) as: "an emissions limitation...based on the maximum degree of reduction for each pollutant subject to regulation under the Clean Air Act which would be emitted from any proposed major stationary source or major modification which the Administrator, on a case-by-case basis,taking into account energy,environmental, and economic impacts and other costs, determines is achievable for such source or modification through application of production processes or available methods,systems,and techniques,including fuel cleaning or treatment or innovative fuel combustion techniques for control of such pollutant..." The SJVAPCD defines BACT as the most stringent emission limitation or control technique that: "Has been achieved in practice for such emissions unit and class of source; or Is contained in any SIP approved by the EPA for such emissions unit category and class of source. A specific limitation or control technique shall not apply if the owner or operator of the proposed emissions unit demonstrates to the satisfaction of the Air Pollution Control Officer (APCO) that such limitation or control technique is not presently achievable; or Is any other emission limitation or control technique,including process and equipment changes of basic and control equipment,found by the APCO to be technologically feasible for such class or category of sources or for a specific source, and cost-effective as determined by the APCO." A top-down BACT analysis is required for each pollutant that is subject to PSD review or that exceeds the SJVAPCD BACT thresholds. BACT applicability is discussed in Section 5.1.7.3. The required top-down BACT analysis is provided in Appendix 5.1C, and concludes that BACT for the proposed project is as shown in Table 5.1-25. SAC/371322/082410013(LEC_5.1_AIR_QUALITY.DOC) 5.1-31