ARCHIVED REPORTS LEC APPLICATION FOR CERTIFICATION

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5.1 AIR QUALITY Data from the Hazelton Avenue monitoring station in Stockton, about 12 miles from the project site,were used to characterize CO and NO2 air quality at the project site. This station was chosen because of its proximity to the site and because data recorded there represent area-wide ambient conditions rather than the localized impacts of any particular facility. Because of the proximity of the monitoring station to the project,the data measured there are believed to be representative of the areas where the maximum project impacts will occur. Further, since ambient CO concentrations are generally driven by motor vehicle emissions and tend to be localized, the use of CO background data collected at Hazelton Avenue, which is in central Stockton near the Interstate 99 freeway, is expected to overpredict CO concentrations in the areas where the proposed project would have significant impacts. PSD Increment Consumption The maximum modeled impacts from the LEC facility are compared with the NO2 and CO significant impact levels in Table 5.1-40. These comparisons show that the maximum modeled NO2 and CO impacts from the proposed project do not exceed the SILs. Therefore, no increments analysis is required for the proposed project. TABLE 5.1-40 PSD Significant Impact Levels(SILs)and Class II Increments Maximum Modeled Pollutant Averaging Time Concentration SILsa Exceeds SIL? NO2 Annual 0.3 Pg/m3 1.0 Ng/m3 No CO 1-hour 324 Pg/m3 2000 Ng/m3 1-Hour 8-hour 111 Pg/m3 500 Pg/m3 8-Hour Air Quality Impacts Analysis Because the maximum modeled NO2 and CO impacts from the project are below the significance thresholds,no additional assessment of the impacts on ambient air quality are required under the PSD program requirements. However, a complete ambient air quality impacts analysis for NO2 and CO was provided in Section 5.1.5 above. The AQIA demonstrated that the project will not cause or contribute to any violations of federal standards for which PSD review applies. Impacts on Growth, Soils, Vegetation, and Sensitive Species PSD requirements include an assessment of the secondary impacts from projects subject to review. These potential secondary impacts include growth, soils and vegetation,and sensitive species. Growth There will be minimal growth associated with the proposed project during the construction phase, due to the relatively short 24-month construction schedule and the broad regional availability of construction labor in the southern Sacramento and northern San Joaquin Valleys. Further,no direct project-related long-term growth is expected to occur in the area because only 21 additional permanent employees will be added as a result of the new plant. 5.1-60 SAC/371322/082410013(LEC_5.1_AIR_QUALITY.DOC)