SJATEOFCALIFORNIA -THE RESOURCES AGENC- ARNOLDSCHWARZENEGGER, Gov~nor

============ 

CALIFORNIA ENERGY COMMISSION 

1516 NINTH STREET 

SACRAMENTO, CA 95814-5512 RECEIVED 

NOV . 1 2007 

October 26,2007 Permits 0lhl:e Air-3 

U.S. EPA, Region 9 

Ms. Deborah Jordan, Director 

USEPA, Region 9 

Air Programs Division 

75 Hawthorne Street 

San Francisco, CA 94105 

Dear Ms. Jordan: 

REQUEST FOR USEPA CONCURRENCE REGARDING TWO AIR QUALITY AMENDMENT 

REQUESTS - HIGH DESERT POWER PRO..IECT (97-AFC-1C) 

The purpose of this letter is to request your concurrence with one approved and one proposed 

amendment to the air quality conditions of certification for the High Desert Power Project 

(HDPP). Energy Commission staff have been working with Gerardo Rios and his staff for 

several months to obtain concurrence with these proposed changes. 

The first amendment was approved by the Energy Commission on October 20, 2004, 

eliminating durational limits on startups while leaving all emission limits unchanged. This 

modification was also approved by the Mojave Desert Air Quality Management District 

(MDAQMD). The reason for approving the amendment is that Energy Commission and 

MDAQMD staff determined that this would allow HDPP to ~tartup their turbines sequentially in 

order to minimize thermal stress on both the combustion turbines and the steam turbine 

generator while maintaining emissions at or below the pre-existing limits. The end result is 

improved plant reliability with no negative environmental consequences. 

The second amendment petition from HDPP is dated August 30, 2006. This petition requests 

that the interval for source testing for nitrous oxide (NOx) and carbon monoxide (CO) be 

extended from every year to every five years, and other changes not covered in the Prevention 

of Significant Deterioration (PSD) permit. The reason for this request is that HDPP believes that 

the eXisting Continuous Emissions Monitoring System (CEMS), in combination with an annual 

Relative Accuracy Test Audit (RATA) of the CEMS is reliable and is sufficient to ensure that the 

facility will remain within its emission limits for these pollutants. The second amendment petition 

also requests other technical changes, including correction of a typographical error in the 

drafting of condition AQ-30 in the October 20, 2004 amendment Order that erroneously placed 

limits on the power block instead of individual equipment. This change was not intentional. 

MDAQMD has already incorporated these changes in the HDPP Title V Permit under their 

delegated authority. Although we were informed by your staff in a conversation on June 20, 

2007, that corresponding approval of these changes in HDPP's PSD permit would be 

forthcoming in the near future, at this time it has not yet occurred. We understand that you have 

had some staff turnover, and your office has a full agenda of project applications and other 

matters. However, given the prolonged period of time the HDPP requests have been under 

review, we ask you to place a higher priority on the processing of these requested changes. 

Without the PSD permit changes, HDPP cannot implement these modifications. 
Ms. Deborah Jordan 

October 26, 2007 

Page 2 

If you have any questions or need additional information, you may contact me at (916) 654­

3933, or your staff may contact Tuan Ngo of the Energy Commission air quality staff at (916) 

654-3852, or Compliance Project Manager Steve Munro at (916) 654-3936. I appreciate your 

assistance with this matter. 

Sincerely, 

TERRENCE O'BRIEN 

Deputy Director for Energy Facilities Siting 

cc: Jon Boyer, High Desert Power Project, LLC