ARCHIVED REPORTS LEC APPLICATION FOR CERTIFICATION

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5.1 AIR QUALITY TABLE 5.1-37 PSD Significant Impact Levels(SILs)and Class II Increments Maximum Allowable Class II Pollutant Averaging Time SILsa Increments" NO2 Annual 1.0 Ng/m3 25 Ng/m3 CO 1-hour 2000 pg/m3 n/a° 8-hour 500 pg/m3 n/a a40 CFR 51.165 "40 CFR 52.21 °No increments have been established for CO. Table 5.1-34 shows that the existing NCPA Lodi turbine plant is not a major source under the PSD regulations. Table 5.1-35 shows that CO emissions from LEC will exceed the 100 ton major source threshold, so the project will be a major modification and thus subject to PSD review. Table 5.1-36 above shows that the NOX emissions from the project will above the PSD significance threshold while the SO,,emissions will be below the threshold,so the project is subject to PSD review for NOX and CO. If the significant impact levels (SILs) are exceeded, an analysis is required to demonstrate that the allowable increments will not be exceeded,on a pollutant-specific basis. Increments are the maximum increases in concentration that are allowed to occur above the baseline concentration. These PSD increments are also shown in Table 5.1-37. There are no increments for CO. We note that annual NOX emissions impacts from the project are below the SIL,as indicated in Table 5.1-27. 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..." A top-down BACT analysis is required for each pollutant subject to PSD review: that is,NO,, and CO. 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 5.1-38. TABLE 5.1-38 BACT Required Under Federal PSD for LEC Pollutant Controlled Emission Rate Control Technique NO, 2.0 ppmvd @ 15%02 Dry low-NO.combustion with selective catalytic reduction CO 3.0 ppmvd @ 15% 02 Oxidation catalyst 5.1-58 SAC/371322/082410013(LEC_5.1_AIR_QUALITY.DOC)