ARCHIVED REPORTS LEC APPLICATION FOR CERTIFICATION

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5.1 AIR QUALITY emissions from combustion devices has historically been the use of best combustion practices. With the use of the dry low-NO,,combustors and with the duct burner emission level,VOC emissions will be limited to 2.0 ppmvd,corrected to 15 percent oxygen. Without duct firing,VOC emissions will be limited to 1.4 ppmvd,corrected to 15 percent oxygen. This level of emissions is consistent with the SJVAPCD's BACT guidelines for large gas turbines. BACT for VOC emissions for the auxiliary boiler will be achieved by the use of natural gas fuel and good combustion practices.The VOC emissions will be 10.0 ppmvd,corrected to 3 percent 02. SJVAPCD BACT Guideline 1.1.3 indicates that VOC BACT for boilers greater than 20 MMBtu/hr is natural gas fuel and good combustion practices. The low NOX burners are designed to minimize incomplete combustion and therefore minimize VOC emissions. PM10 BACT-For the turbine, duct burner and auxiliary boiler,BACT for PM10 is good combustion practices and the use of natural gas fuel,which will result in minimal particulate emissions. The turbine and HRSG will also utilize an air inlet filter and lube oil vent coalescer to minimize PM10 emissions. For the cooling tower, drift eliminators will be used to keep the drift rate below 0.0005%. This is the drift rate commonly achieved by cooling towers of this type and in combination with the proposed 3000 ppm limit on TDS in the cooling tower water,will minimize PM10 emissions from the cooling tower. SO2 BACT-SO2 emissions will be kept at a minimum by firing clean burning natural gas fuel with a maximum sulfur content of 1.0 gr/100 scf. In addition to the BACT requirements,SJVAPCD Rule 2201 requires the project to provide emission offsets when emissions exceed specified levels on a pollutant-specific basis. Offsets for CO are not required because the air quality impact analysis is expected to demonstrate to the satisfaction of the APCO that the ambient air quality standards for CO are not currently being violated and that the project would not cause or contribute to a violation of the standards (see Table 5.1-29). As shown in Table 5.1-44,the project must provide emission offsets for NO,PM10,SO2,and VOC emissions. TABLE 5.1-44 SJVAPCD Offset Requirements and Project Emissions Emissions from Existing Facility, Emissions from District Offset Pollutant tpy New Facility,tpy Threshold,tpy Offsets Required VOC 25.9 17.5 10.0 Yes NOX 20.4 71.5 10.0 Yes SO2 5.7 24.3 27.4 Yes PM10 8.8 44.0 14.6 Yes The NSR rule requires emission reductions to be provided at an offset ratio of between 1 and 1.5 to 1, depending upon the distance between the source and the offset location. Interpollutant offsets are permitted,at the discretion of the APCO. Appendix 5.1F presents a demonstration of compliance with the offset and mitigation requirements for the proposed project. The demonstration includes a listing of credits owned by the Applicant,a quarterly 5.1-68 SAC/371322/082410013(LEC_5.1_AIR_QUALITY.DOC)