SITE INFORMATION AND CORRESPONDENCE

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5.1 AIR QUALITY 5.1.5.9 Commissioning Impacts Analysis The commissioning period begins when the CTG and HRSG are prepared for first fire and ends upon successful completion of initial performance testing. There are several high- emissions scenarios possible during commissioning. The first is the period prior to SCR system and oxidation catalyst installation,when the gas turbine combustion system is being tuned. Under this scenario,NOX emissions would be high because the NO,,emissions control system would not be functioning and because the gas turbine would not be tuned for optimum performance. CO emissions would also be high because turbine performance would not be optimized and the CO emissions control system would not be functioning. The second high emissions scenario may occur when the gas turbine has been tuned but the SCR and oxidation catalyst installation is not complete.Since the control system installation would not be complete,NO,,and CO levels would again be high. Commissioning activities and expected emissions are shown in more detail in Table 5.0-7,Appendix 5.113. The existing NCPA Lodi generating unit will be in operation during the commissioning of the LEC. An assessment of the air quality impacts of this combined operation have been included in the cumulative impacts analysis,provided in Appendix 5.1G. Air quality impacts during the commissioning period were determined using the emission rates in Table 5.113-7. One-hour average NO2 impacts during commissioning were modeled using AERMOD_OLM and concurrent Stockton ozone data. Modeled impacts are shown in Table 5.1-30. TABLE 5.1-30 Modeled Maximum Impacts During Commissioning of the CTG/HRSG Maximum Total State Federal Facility Impact Background Impact Standard Standard Pollutant Averaging Time (pg/m3) (Ng/m3) (pg/m3) (pg/m3) (pg/m3) NO2 1-hour 36.4 163.6 200 338 — CO 1-hour 718.2 5,500 6,218 23,000 40,000 8-hour 535.0 3,178 3,713 10,000 10,000 5.1.6 Laws, Ordinances, Regulations, and Standards The EPA has responsibility for enforcing, on a national basis,the requirements of many of the country's environmental and hazardous waste laws. California is under the jurisdiction of EPA Region 9,which has its offices in San Francisco. Region 9 is responsible for the local administration of EPA programs for California,Arizona,Nevada,Hawaii,and certain Pacific trust territories. EPA's activities relative to the California air pollution control program focus principally on reviewing California's submittals for the State Implementation Plan (SIP). The SIP is required by the federal Clean Air Act to demonstrate how all areas of the state will meet the national ambient air quality standards within the federally specified deadlines (42 USC§7409, 7411). The CARB was created in 1968 by the Mulford-Carrell Air Resources Act,through the merger of two other state agencies. The CARB's primary responsibilities are to develop, adopt, implement,and enforce the state's motor vehicle pollution control program;to administer and coordinate the state's air pollution research program;to adopt and update as necessary 5.1-42 SAC/371322/082410013(LEC_5.1_AIR_QUALITY.DOC)