ARCHIVED REPORTS LEC APPLICATION FOR CERTIFICATION

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5.1 AIR QUALITY Subpart Dc limits SO2 and PMlo emissions from new small boilers. Because the LEC auxiliary boiler will burn only natural gas,its permitted emissions will be well below any applicable limits in Subpart Dc. 5.1.7.1.3 National Emissions Standards for Hazardous Air Pollutants The NESHAPs are either source-specific or pollutant-specific regulations,limiting the allowable emissions of hazardous air pollutants from the affected sources (40 CFR Part 63). Unlike criteria air pollutants,hazardous air pollutants do not have a national ambient air quality standard but have been identified by EPA as causing or contributing to the adverse health effects of air pollution. NESHAPs are applicable only to major sources of HAPs.The assessment of noncriteria pollutant emissions from the facility in Section 5.1.3.6 included a calculation of total HAP emissions from the new and existing facilities after modification. Since HAP emissions do not exceed 10 tpy for any individual HAP or 25 tpy in total,the project is not a major source of HAPs. Therefore,LEC is not subject to any NESHAP requirements. 5.1.7.1.4 Federal Clean Air Act Amendments of 1990 In November 1990,substantial revisions and updates to the federal Clean Air Act were signed into law. This complex enactment addresses a number of areas that could be relevant to the proposed LEC,such as more extensive permitting requirements and new EPA mandates and deadlines for developing rules to control air toxic emissions. The most significant of the new provisions applicable to this project are the Title IV acid rain and Title V operating permit programs. Title IV—Acid Rain As a Phase II Acid Rain facility,the LEC will be required to provide sufficient allowances for every ton of SO2 emitted during a calendar year. LEC will also be required to install and operate a NO,,CEMS that complies with program requirements. SJVAPCD has been delegated the authority to implement the acid rain permitting program. Compliance with program requirements is discussed below with other local district requirements. Title V—Operating Permits This title establishes a comprehensive operating permit program for major stationary sources (42 USC§7661 et seq.). Under the Title V program,a single permit is required that includes a listing of all the stationary sources, applicable regulations,requirements, and compliance determinations. SJVAPCD's Title V Program(Rule 2520) has been approved by EPA. Consequently, SJVAPCD has received delegation to implement the Title V program. SJVAPCD Title V permit programs applicable to this project are summarized below. 5.1.7.2 Consistency with State Requirements State law sets up local air pollution control districts and air quality management districts with the principal responsibility for regulating emissions from stationary sources. As discussed above, the project is under the local jurisdiction of the SJVAPCD,and compliance with SJVAPCD regulations will assure compliance with state air quality requirements. SAC/371322/082410013(LEC_5.1_AIR_QUALITY.DOC) 5.1-63