ARCHIVED REPORTS LEC APPLICATION FOR CERTIFICATION

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5.1 AIR QUALITY reconciliation of offset requirements and ERCs,and an analysis of interpollutant offset ratios to be used to fulfill the PM10 offset and mitigation requirements for the project. The NSR rule also only allows project approval if air quality modeling results indicate emissions will not cause or exacerbate the violation of the applicable ambient air quality standards,after accounting for mitigation. The modeling analyses in Section 5.1.5 show that with the exception of PM1o,facility emissions will not interfere with the attainment or maintenance of the applicable air quality standards. Because the SJVAB is currently a nonattainment area for state PM10 and federal PM2.5 ambient air quality standards, any increase in PM10 emissions has the potential to exacerbate existing violations. The Applicant will be providing PM10 offsets to mitigate the impact of the emissions increase; as a result, the required finding can be made for PM10 as well. Rule 2520,Federal Part 70 Permits (Title V permit program) applies to major sources on a pollutant-specific basis. The Phase I1 acid rain requirements of Rule 2540 are also applicable to the facility. As a Phase I1 Acid Rain facility,the project will be required to provide sufficient allowances for every ton of SO2 emitted during a calendar year.The applicant will file the appropriate applications for modifications to the existing Title V and acid rain permits, and will obtain any additional offsets, as needed, on the open trade market. The project will also install and operate the required continuous emissions monitoring systems (CEMS). The general prohibitory rules of the SJVAPCD applicable to the project and the determination of compliance follow. Rule 4001 (New Source Performance Standards).Subparts Dc and KKKK of this rule require monitoring of fuel;impose limits on the emissions of NO,PM,and SO2; and require source testing of stack emissions,process monitoring, and data collection and recordkeeping. All of the BACT limits imposed on the facility will be more stringent than the requirements of the NSPS emission limits. Monitoring and recordkeeping requirements for BACT will be more stringent than the requirements in this rule;therefore,the project will comply with the NSPS regulations. Rule 4101 (Visible Emissions).Any visible emissions from the project will not be darker than No. 2 when compared to a Ringlemann Chart for any period(s) aggregating 3 minutes in any hour. Because the facility will burn clean fuels,the opacity standard of not greater than 20 percent for a period or periods aggregating 3 minutes in any hour and the particulate emission concentrations limit of 0.15 grains per standard cubic feet of exhaust gas volume will not be exceeded. Rule 4102 (Public Nuisance).The facility will not emit significant quantities of odorous or visible substances;therefore,the facility will comply with this regulation. Rule 4201 (Particulate Matter Emission Standards).The emission units will have particulate matter emission rates well below the limits of the rule. The maximum grain loading for the turbines and duct burners (from Table 5.1A-1,Appendix 5.1A) is 0.0022 gr/dscf,well below the 0.1 gr/dscf limit of the rule. Rule 4320 (Advanced Emission Reduction Options For Boilers,Steam Generators,And Process Heaters Greater Than 5.0 MMBtu/hr). The auxiliary boiler will comply with the requirements of this proposed rule by limiting NOX emissions to not more than 7 ppmc. The SAC/371322/082410013(LEC_5.1_AIR_QUALITY.DOC) 5.1-69