ARCHIVED REPORTS LEC APPLICATION FOR CERTIFICATION

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5.1 AIR QUALITY Pinnacles Wilderness 180 km Since all of these areas are more than 100 km from the project site,visibility and AQRV analyses should not be required. However, since the Mokelumne Wilderness is only slightly more than 100 km away,an assessment could otherwise be required for that area. The Federal Land Managers (FLMs) have developed a screening methodology for determining whether a proposed project is likely to have a significant impact on a Class I area when located within,or near to,the 100 km threshold. Under this procedure,the estimated sum of maximum NO,SO,and PM10 emissions (in tons per year) from the project is divided by the distance of each Class I areas from the project (in km) (National Park Service,2007). The sum of the NO,SO2,and PM10 emissions from the project is 139.8 tons.31 Using the distance to the closest Class I area, 106 km,the quotient is 1.32. Because this quotient is substantially less than the FLM threshold level of 10,it is expected that even if the project is subject to PSD review it will not be required by the FLMs to evaluate impacts to visibility and other air quality related values at Class I areas. 5.1.7.1.2 Federal New Source Performance Standards The Standards of Performance for New Stationary Sources are source-specific federal regulations,limiting the allowable emissions of criteria pollutants (i.e.,those that have a national ambient air quality standard). These regulations apply to certain sources depending on the equipment size,process rate,and/or the date of construction,modification,or reconstruction of the affected facility. Recordkeeping,reporting,and monitoring requirements are usually necessary for the regulated pollutants from each subject source;the reports must be regularly submitted to the reviewing agency (40 CFR 60.4). This program has been delegated by EPA to the SJVAPCD. Subpart KKKK,the NSPS for Stationary Gas Turbines,and Subpart Dc,the NSPS for small Commercial-Institutional-Industrial Boilers,are applicable to the equipment proposed for this project.Subpart KKKK limits NO,,and SO2 emissions from new gas turbines based on power output. The limits for gas turbines greater than 30 MW are 0.39 lb NO,,per MW-hr and 0.58 lb SO2 per MW-hr. The emission limits of 2.0 ppmc NO,,and 0.56 ppmc SO2 proposed for the LEC turbine and duct burners are well below the Subpart KKKK limits,as shown in Table 5.1-42. TABLE 5.1.42 Compliance With 40 CFR 60 Subpart KKKK Proposed Permit Limits Subpart KKKK Pollutant ppmc Ib/hr Ib/MW-hr(max) Limit, Ib/MW-hr NOx 2.0 15.25 0.05 0.39 SO2 0.57 6.0 0.02 0.58 Compliance with the NSPS limits must be demonstrated through an initial performance test. Because the LEC gas turbine/HRSG will be equipped with a continuous NOx emissions monitor,ongoing annual performance testing will not be required under the NSPS. 31 71.5 tons(NOx)plus 24.3 tons(SO2)plus 44.0 tons(PM1o). 5.1-62 SAC/371322/082410013(LEC_5.1_AIR_QUALITY.DOC)