1 

Palmdale Hybrid Power Project (SE 09-01) 

Proposed PSD Permit 

August 2011 

PALMDALE HYBRID POWER PROJECT (SE 09-01)

PREVENTION OF SIGNIFICANT DETERIORATION PERMIT 

PROPOSED PERMIT CONDITIONS 

PROJECT DESCRIPTION 

The proposed Palmdale Hybrid Power Project (Project) consists of two General Electric (GE) 

Frame 7FA natural gas-fired combustion turbine-generators (CTGs) rated at 154 megawatt (MW, 

gross) each, two heat recovery steam generators (HRSGs), one steam turbine generator (STG) 

rated at 267 MW, and 251 acres of parabolic solar-thermal collectors with associated heattransfer equipment. The Project will have an electrical output of 570 MW (nominal) or 563 MW 

(net). The Project will be located on a parcel of land owned by the city of Palmdale, currently 

zoned for industrial use, in Los Angeles County. The approximately 333-acre parcel is west of 

the northwest corner of Air Force Plant 42, and east of the intersection of Sierra Highway and 

East Avenue M. The City of Palmdale is located within the Antelope Valley Air Quality 

Management District (District). 

 

This proposed Prevention of Significant Deterioration (PSD) permit for the Project requires the 

use of Best Available Control Technology (BACT) to limit emissions of nitrogen oxides (NOX), 

carbon monoxide (CO), total particulate matter (PM), particulate matter under 10 micrometers 

(μm) in diameter (PM10), particulate matter under 2.5 (μm) in diameter (PM2.5), and greenhouse 

gases (GHG), to the greatest extent feasible. Air pollution emissions from the Project would not 

cause or contribute to violations of any National Ambient Air Quality Standards (NAAQS) or 

any applicable PSD increments for the pollutants regulated under the PSD permit. 

Additional equipment includes auxiliary equipment including a natural gas heater and boiler, a 

diesel-fired emergency generator and emergency firewater pump engine, cooler towers, and 

circuit breakers. 

EQUIPMENT LIST 

The following devices and activities are subject to this PSD permit: 
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Palmdale Hybrid Power Project (SE 09-01) 

Proposed PSD Permit 

August 2011 

Unit ID Description 

GEN1 • 154 MW (gross) combustion turbine generator (CTG), with a maximum heat 

input rate of 1,736 MMBtu/hr (HHV) 

• Natural gas-fired GE Model Frame 7FA Rapid Start Process CTG 

• Vented to a dedicated Heat Recovery Steam Generator (HRSG) and a 267 MW 

Steam Turbine Generator (STG) shared with GEN2 

• Emissions of NOX and CO controlled by Dry Low-NOX (DLN) Combustors, 

Selective Catalytic Reduction (SCR), and an Oxidation Catalyst (Ox-Cat) 

GEN2 • 154 MW (gross) combustion turbine generator (CTG), with a maximum heat 

input rate of 1,736 MMBtu/hr (HHV) 

• Natural gas-fired GE Model Frame 7FA Rapid Start Process CTG 

• Vented to a dedicated Heat Recovery Steam Generator (HRSG) and a 267 MW 

Steam Turbine Generator (STG) shared with GEN2 

• Emissions of NOX and CO controlled by Dry Low-NOX (DLN) Combustors, 

Selective Catalytic Reduction (SCR), and an Oxidation Catalyst (Ox-Cat) 

DB1 • 500 MMBtu/hr (HHV) Duct Burner for GEN1, fired on natural gas 

DB2 • 500 MMBtu/hr (HHV) Duct Burner for GEN2, fired on natural gas 

D1 • 110 MMBtu/hr (HHV) Auxiliary Boiler with ultra low-NOX burner, fired on 

natural gas 

D2 

• 2,000 kW (2,683 hp) Emergency Internal Combustion (IC) Engine, fired on 

Diesel fuel 

• 40 CFR Part 60, Subpart IIII emission standards 

• California Air Resources Board Tier 2 emission standards 

D3 

• 182 hp (135 kW) Emergency Diesel-fired IC Engine Firewater Pump Engine 

• 40 CFR Part 60, Subpart IIII emission standards 

• California Air Resources Board Tier 3 emission standards 

D4 • 40 MMbtu/hr (HHV) Auxiliary Heater with ultra low-NOX burner, fired on 

natural gas 

D5 • Cooling tower with 130,000 gallons per minute maximum circulation rate 

• Total dissolved solids (TDS) concentration in makeup water of 5,000 ppm (531 

mg/L) 

• Drift eliminator with drift losses less than or equal to 0.0005 percent based on 

circulation rate 

CB • Enclosed-pressure SF6 Circuit Breakers 

• 0.5% (by weight) annual leakage rate 

• 10% (by weight) leak detection system 

MV • Maintenance vehicles generating fugitive road dust when traveling on paved 

and unpaved roadways in the solar field for the Project 

• Project Fugitive Dust Control Plan 
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Palmdale Hybrid Power Project (SE 09-01) 

Proposed PSD Permit 

August 2011 

PERMIT CONDITIONS 

I. PERMIT EXPIRATION

As provided in 40 CFR § 52.21(r), this PSD Permit shall become invalid if construction: 

A. is not commenced (as defined in 40 CFR § 52.21(b)(9)) within 18 months after 

the approval takes effect; or 

B. is discontinued for a period of 18 months or more; or 

C. is not completed within a reasonable time. 

II. PERMIT NOTIFICATION REQUIREMENTS

Permittee shall notify EPA Region IX by letter or by electronic mail of the: 

A. date construction is commenced, postmarked within 30 days of such date; 

B. actual date of initial startup, as defined in 40 CFR § 60.2, postmarked within 15 

days of such date; 

C. date upon which initial performance tests will commence, in accordance with the 

provisions of Condition X.G, postmarked not less than 30 days prior to such date. 

Notification may be provided with the submittal of the performance test protocol 

required pursuant to Condition X.G; and 

D. date upon which initial performance evaluation of the continuous emissions 

monitoring system (CEMS) will commence in accordance with 40 CFR § 

60.13(c), postmarked not less than 30 days prior to such date. Notification may 

be provided with the submittal of the CEMS performance test protocol required 

pursuant to Condition X.F. 

III. FACILITY OPERATION

At all times, including periods of startup, shutdown, shakedown, and malfunction, 

Permittee shall, to the extent practicable, maintain and operate the Facility, including 

associated air pollution control equipment, in a manner consistent with good air pollution 

control practice for minimizing emissions. Determination of whether acceptable 

operating and maintenance procedures are being used will be based on information 

available to EPA, which may include, but is not limited to, monitoring results, opacity 

observations, review of operating maintenance procedures and inspection of the Facility. 
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Palmdale Hybrid Power Project (SE 09-01) 

Proposed PSD Permit 

August 2011 

IV. MALFUNCTION REPORTING

A. Permittee shall notify EPA at R9.AEO@epa.gov within two (2) working days 

following the discovery of any failure of air pollution control equipment or 

process equipment, or failure of a process to operate in a normal manner, which 

results in an increase in emissions above the allowable emission limits stated in 

Section X of this permit. 

B. In addition, Permittee shall provide an additional notification to EPA in writing or 

electronic mail within fifteen (15) days of any such failure described under 

Condition IV.A. This notification shall include a description of the 

malfunctioning equipment or abnormal operation, the date of the initial 

malfunction, the period of time over which emissions were increased due to the 

failure, the cause of the failure, the estimated resultant emissions in excess of 

those allowed in Section X, and the methods utilized to mitigate emissions and 

restore normal operations. 

C. Compliance with this malfunction notification provision shall not excuse or 

otherwise constitute a defense to any violation of this permit or any law or 

regulation such malfunction may cause. 

V. RIGHT OF ENTRY

The EPA Regional Administrator, and/or an authorized representative, upon the 

presentation of credentials, shall be permitted: 

A. to enter the premises where the Facility is located or where any records are 

required to be kept under the terms and conditions of this PSD Permit; 

B. during normal business hours, to have access to and to copy any records required 

to be kept under the terms and conditions of this PSD Permit; 

C. to inspect any equipment, operation, or method subject to requirements in this 

PSD Permit; and 

D. to sample materials and emissions from the source(s). 

VI. TRANSFER OF OWNERSHIP

In the event of any changes in control or ownership of the Facility, this PSD Permit shall 

be binding on all subsequent owners and operators. Within 14 days of any such change 
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Palmdale Hybrid Power Project (SE 09-01) 

Proposed PSD Permit 

August 2011 

in control or ownership, Permittee shall notify the succeeding owner and operator of the 

existence of this PSD Permit and its conditions by letter. Permittee shall send a copy of 

this letter to EPA Region IX within thirty (30) days of its issuance. 

VII. SEVERABILITY

The provisions of this PSD Permit are severable, and, if any provision of the PSD Permit 

is held invalid, the remainder of this PSD Permit shall not be affected. 

VIII. ADHERENCE TO APPLICATION AND COMPLIANCE WITH OTHER 

ENVIRONMENTAL LAWS

Permittee shall construct the Project in compliance with this PSD permit, the application 

on which this permit is based, and all other applicable federal, state, and local air quality 

regulations. This PSD permit does not release the Permittee from any liability for 

compliance with other applicable federal, state and local environmental laws and 

regulations, including the Clean Air Act. 

IX. RESERVED 
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Palmdale Hybrid Power Project (SE 09-01) 

Proposed PSD Permit 

August 2011 

X. SPECIAL CONDITIONS 

A. Annual Facility Emission Limits 

1. Annual emissions, in tons per year (tpy) on a 12-month rolling average basis, 

shall not exceed the following: 

NOX CO PM PM10 PM2.5

Total 

Facility 

114.9 tpy 250.2 tpy 79.1 tpy 62.5 tpy 56.0 

CO2e 

Total Facility 1,913,000 tpy 

2. Only Public Utilities Commission (PUC)-quality pipeline natural gas shall be 

fired at this Facility. PUC-quality pipeline natural gas shall not exceed a 

sulfur content of 0.20 grains per 100 dry standard cubic feet on a 12-month 

rolling average basis and shall not exceed a sulfur content of 1.0 grains per 

100 dry standard cubic feet, at any time. 

B. Air Pollution Control Equipment and Operation 

As soon as practicable following initial startup of the power plant (startup as 

defined in 40 CFR § 60.2) but prior to commencement of commercial operation 

(as defined in 40 CFR § 72.2), and thereafter, except as noted below in Condition 

X.D, Permittee shall install, continuously operate, and maintain the SCR systems 

for control of NOX and the Ox-Cat systems for control of CO for Units GEN1 and 

GEN2. Permittee shall also perform any necessary operations to minimize 

emissions so that emissions are at or below the emission limits specified in this 

permit. 

C. Combustion Turbine Generator (CTG) Emission Limits 

1. Except as noted below under Condition X.D, on and after the date of initial 

startup, Permittee shall not discharge or cause the discharge of emissions from 

each CTG Unit (of GEN1 and GEN2) into the atmosphere in excess of the 

following: 
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Palmdale Hybrid Power Project (SE 09-01) 

Proposed PSD Permit 

August 2011 

Emission Limit (per CTG) 

(no duct burning) 

Emission Limit (per CTG) 

(with duct burning) 

NOX

• 11.55 lb/hr 

• 1-hr average 

• 2.0 ppmvd @ 15% O2

• 14.60 lb/hr 

• 1-hr average 

• 2.0 ppmvd @ 15% O2

CO 

3-Year Demonstration Period 

• 7.65 lb/hr 

• 1-hr average 

• 2.0 ppmvd @ 15% O2

Post-Demonstration Period 

• 5.74 lb/hr 

• 1-hr average 

• 1.5 ppmvd @ 15% O2

Conditions in X.C.3 may affect 

the timing and applicability of 

post-demonstration period 

emission limits. 

• 8.90 lb/hr 

• 1-hr average 

• 2.0 ppmvd @ 15% O2

PM, PM10, 

PM2.5

• 0.0027 lb/MMBtu 

• 4.7 lb/hr 

• 3-hr average 

• PUC-quality natural gas 

(Sulfur content of no 

greater than 0.20 grains per 

100 dscf on a 12-month 

average and not greater 

than 1.0 gr/dscf at any 

time) 

• 0.0035 lb/MMBtu 

• 8.0 lb/hr 

• 3-hr average 

• PUC-quality natural gas 

(Sulfur content of no greater 

than 0.20 grains per 100 

dscf on a 12-month average 

and not greater than 1.0 

gr/dscf at any time) 

GHG 

• 774 lb CO2/MWh source-wide net output 

• 117 lb CO2/MMBtu heat input, each GEN1/DB1 and 

GEN2/DB2 

• 30-day rolling average 

2. Combined hours of operation for both duct burners (DB1 and DB2) shall not 

exceed 2,000 hours per 12-month rolling average. Permittee shall ensure that 

the duct burners are not operated unless the associated turbine units are in 

operation. 
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Palmdale Hybrid Power Project (SE 09-01) 

Proposed PSD Permit 

August 2011 

3. CO Emissions Limit Demonstration Period – The Demonstration Period is 

defined as the first 3 years immediately following the commencement of 

commercial operations (as defined in 40 CFR § 72.2). 

a. Permittee shall design the gas turbines to achieve a CO emission rate of 

1.5 ppmvd @ 15% O2 and 5.74 lb/hr over a 1-hour period without duct 

firing. Prior to construction, Permittee shall submit design specifications 

to EPA as proof that the gas turbines were designed to achieve such a rate, 

and a plan that sets forth the measures that will be taken to maintain the 

system and optimize its performance. 

b. During the Demonstration Period, Permittee shall operate the gas turbines 

according to the design specifications, within the design parameters, and 

consistent with the maintenance and performance optimization plan 

described above in Condition X.C.3.a. During the Demonstration Period, 

Permittee shall not discharge or cause the discharge of CO emissions from 

each CTG Unit (GEN1 and GEN2) into the atmosphere in excess of the 

following amounts over a 1-hour averaging period: 2.0 ppmvd CO @ 15% 

O2 and (1) 8.90 lb/hr with duct firing or (2) 7.65 lb/hr without duct firing. 

c. Following the Demonstration Period, Permittee shall not discharge or 

cause the discharge of CO emissions from each CTG Unit (GEN1 and 

GEN2) into the atmosphere in excess of the following amounts over a 1-

hour averaging period except as specified in Condition X.C.3.d: 

i. 1.5 ppmvd @ 15% O2 without duct firing; 

ii. 2.0 ppmvd @ 15% O2 with duct firing; 

iii. 5.74 lb/hr without duct firing; and 

iv. 8.90 lb/hr with duct firing. 

d. If, during the Demonstration Period, Permittee determines that the CO 

limits in Conditions X.C.3.i or X.C.3.iii are not feasible, Permittee shall 

submit an application to EPA prior to the end of the Demonstration Period 

requesting a revision of those limits. Such an application must contain 

data and information that demonstrates that the Facility was operated 

according to the design specifications and parameters, and the 

maintenance and performance optimization plan, identified above in 

Condition X.C.3.a, as well as a technical justification explaining why the 

lower limits are not feasible. If, after the applicable review process 

following such a submission (which will include an opportunity for public 
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Palmdale Hybrid Power Project (SE 09-01) 

Proposed PSD Permit 

August 2011 

review and comment), it is determined through data and information 

gathered during the Demonstration Period that different CO limits are 

necessary, the limits in Condition X.C.3.i and X.C.3.iii will be revised 

accordingly. Provided that the application specified in this condition is 

postmarked prior to the end of the Demonstration Period, the emission 

limits in Condition X.C.3.b shall remain in effect until EPA evaluates the 

application and makes a final decision regarding the revision of the limits 

in Conditions X.C.3.i or X.C.3.iii. 

D. Requirements during Gas Turbine (GEN1 and GEN2) Startup and 

Shutdown 

1. Startup is defined as the period beginning with ignition and lasting until either 

the equipment complies with all operating permit limits for two consecutive 

15-minute averaging periods or the maximum time allowed for the event after 

ignition, whichever occurs first; and the period of time during which a unit is 

brought from a shutdown status to its operating temperature and pressure, 

including the time required by the unit’s emission control system to reach full 

operations and demonstrate compliance with Condition X.C. 

a. A cold startup means a startup when the CTG has not been in operation 

during the preceding 48 hours. 

b. Warm and hot start-ups include all startups that are not a cold startup. 

2. Shutdown is defined as the period beginning with the lowering of equipment 

from normal operating load and lasting until fuel flow is completely off and 

combustion has ceased. 

3. The duration of startup and shutdown periods and emissions of NOX and CO 

shall not exceed the following, for each CTG (GEN1 and GEN2) and 

associated HRSG unit, as verified by the CEMS: 

NOX CO Duration 

Cold Startup 

52.4 lb/hr 

96 lb/event 

224 lb/hr 

410 lb/event 110 minutes 

Warm and Hot 

Startup 

30 lb/hr 

40 lb/event 

247 lb/hr 

329 lb/event 

80 minutes 

Shutdown 

114 lb/hr 

57 lb/event 

674 lb/hr 

337 lb/event 30 minutes 
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Palmdale Hybrid Power Project (SE 09-01) 

Proposed PSD Permit 

August 2011 

4. Permittee must operate the CEMS during startup and shutdown periods. 

5. Permittee must record the time, date, and duration of each startup and 

shutdown event. The records must include calculations of NOX and CO 

emissions during each event based on the CEMS data. These records must be 

kept for five years following the date of such event. 

6. During startup, the SCR system, including ammonia injection, shall be 

operated as soon as the SCR reaches an operating temperature of 550 degrees 

Fahrenheit. 

E. Auxiliary Combustion Equipment Emission Limits and Work Practices 

1. At all times, including equipment startup and shutdown, Permittee shall not 

discharge or cause the discharge of emissions from each unit into the 

atmosphere in excess of the following, and shall otherwise comply with the 

following specifications: 

Unit ID NOX CO PM / PM10 PM2.5 GHG 

Unit D1 

110 MMBtu/hr 

(HHV) Boiler 

• 9 ppmvd @ 

3% O2

• 3-hr average 

• 50 ppmvd @ 

3% O2

• 3-hr average 

• 0.8 lb/hr 

• PUC-quality 

pipeline natural gas 

Annual boiler 

tune-ups 

Unit D2 

2,000 kW 

(2,683 hp) engine 

• 6.4 g/kW-hr, 

(4.8 g/hp-hr), 

includes 

NMHC 

• 3-hr average 

• 3.5 g/KW-hr, 

(2.6 g/hp-hr) 

• 0.20 g/kW-hr, 

(0.15 g/hp-hr ) 

• Use of ultra-low 

sulfur fuel, not to 

exceed 15 ppmvd 

fuel sulfur 

• Fuel supplier 

certification 

Not applicable 

Unit D3

182 hp firewater 

pump 

• 4.0 g/KW-hr, 

(3.0 g/hp-hr), 

includes 

NMHC 

• 3-hr average 

Not applicable 

Unit D4 

40 MMBtu/hr 

(HHV) Heater

• 9 ppmvd @ 

3% O2

• 3-hr average 

• 50 ppmvd @ 

3% O2

• 3-hr average 

• 0.3 lb/hr 

• PUC-quality 

pipeline natural 

gas 

Annual boiler 

tune-ups 
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Palmdale Hybrid Power Project (SE 09-01) 

Proposed PSD Permit 

August 2011 

Unit D5 

130,000 gpm 

Cooling Tower

Not applicable Not applicable 

• 1.6 lb/hr (as total 

PM) 

• < 0.0005% drift 

• < 5,000 ppm total 

dissolved solids 

Not applicable 

CB 

SF6 Circuit 

Breakers 

Not applicable Not applicable Not applicable 

• 9.56 tpy CO2e 

• 12-month 

rolling total 

MV 

Maintenance 

Vehicles 

Not applicable Not applicable 

Conditions in X.E.9 

including a Fugitive 

Dust Control Plan 

Not applicable 

2. Unit D1 shall not operate during normal operations of GEN1 or GEN2, except 

during periods of, or immediately following, startup. Unit D1 shall be shut 

down as soon as practicable after the completion of any startup process as 

defined in Condition X.D.1. Annual hours of operation for Unit D1 shall not 

exceed 500 hours per 12-month rolling average. 

3. Except during an emergency, Unit D2 shall be limited to operation of the 

engine for maintenance and testing purposes. Annual hours of operation for 

Unit D2, for maintenance and testing, shall not exceed 50 hours per 12-month 

rolling average. 

4. Except during an emergency, Unit D3 shall be limited to operation of the 

engine for maintenance and testing purposes, including as required for fire 

safety testing. Annual hours of operation for Unit D3, for maintenance and 

testing, shall not exceed 50 hours per 12-month rolling average. 

5. Units D2 and D3 shall not operate during startup of GEN1 or GEN2, except 

when Units D2 or D3 are required for emergency operations. 

6. Unit D4 restrictions on usage shall be limited to annual hours of operation of 

not to exceed 1,000 hours per 12-month rolling average. 

7. Unit D5 cooling tower emission limits shall not exceed the following: 

a. drift rate shall not exceed 0.0005% with a maximum circulation rate of 

130,000 gallons per minute (gpm). The maximum total dissolved solids 

(TDS) shall not exceed 5,000 ppm. 

b. The maximum hourly total PM emission rate from the cooling tower and 
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Palmdale Hybrid Power Project (SE 09-01) 

Proposed PSD Permit 

August 2011 

the evaporative condenser combined shall not exceed 1.6 lb/hr. 

8. Unit CB enclosed-pressure SF6 circuit breakers: 

a. Emissions shall not exceed an annual leakage rate of 0.5% by weight; 

and 

b. Shall be equipped with a 10% by weight leak detection system. 

9. For Unit MV, maintenance vehicles that travel on paved and unpaved 

roadways in the solar field associated with the Project, Permittee shall 

complete the following prior to the commencement of commercial operation 

(as defined in 40 CFR § 72.2): 

a. Pave the main access road into the plant site; 

b. Submit a Project Fugitive Dust Control Plan to EPA that includes 

fugitive road dust control measures for unpaved and paved roads, 

including, but not limited to: 

i. use of a durable non-toxic soil stabilizer applied throughout the solar 

field for dust control; 

ii. use of a durable non-toxic soil stabilizer to treat unpaved roads 

within the solar field used by wash trucks that spray and clean the 

mirrors; 

iii. inspection and maintenance procedures to ensure that the unpaved 

roads remain stabilized; 

iv. use of water trucks applying water on disturbed areas where soil 

stabilizers are not as effective; 

v. use of water in the mirror washing for incidental dust control; and 

vi. limiting vehicle speeds to no more than 10 miles per hour on 

unpaved roadways, with the exception that vehicles may travel up to 

25 miles per hour on stabilized unpaved roads as long as such speeds 

do not create visible dust emissions. 

10. Units D1 and D4 shall undergo annual tune-ups and meet the associated 

requirements of Condition X.I.9 as follows (if the unit is not operating on the 

required date for a tune-up, the tune-up must be conducted within one week of 

startup): 

a. Inspect the burner, and clean or replace any components of the burner as 

necessary (you may delay the burner inspection until the next scheduled 

unit shutdown, but you must inspect each burner at least once every 18 

months). 

b. Inspect the flame pattern, and adjust the burner as necessary to optimize 

the flame pattern. The adjustment should be consistent with the 

manufacturer's specifications. 

c. Inspect the system controlling the air-to-fuel ratio, and ensure that it is 
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Palmdale Hybrid Power Project (SE 09-01) 

Proposed PSD Permit 

August 2011 

correctly calibrated and functioning properly. 

d. Optimize total emissions of carbon monoxide. This optimization should 

be consistent with the manufacturer's specifications. 

e. Measure the concentrations in the effluent stream of carbon monoxide in 

parts per million, by volume, and oxygen in volume percent, before and 

after the adjustments are made (measurements may be either on a dry or 

wet basis, as long as it is the same basis before and after the adjustments 

are made). 

F. Continuous Emissions Monitoring System (CEMS) for GEN1 and GEN2 

1. At the earliest feasible opportunity after first fire of GEN1 and GEN2 and 

before GEN1 and GEN2 commence commercial operation (as defined in 40 

CFR § 72.2), in accordance with the recommendations of the equipment 

manufacturer and the construction contractor: 

a. Permittee shall install, calibrate, and operate a CEMS each for GEN1 

and GEN2 that measures stack gas NOX, CO, and CO2 concentrations in 

ppmv. The concentrations shall be corrected to 15% O2 on a dry basis. 

No later than the end of the shakedown period as defined in Condition 

X.J. or upon commencing commercial operations, whichever comes 

first, Permittee shall also maintain, certify, and quality-assure a CEMS 

for each CTG that measures stack gas NOX, CO, and CO2 concentrations 

in ppmv, and shall conduct initial certification of the CEMS in 

accordance with Condition X.F.6. The concentrations shall be corrected 

to 15% O2 on a dry basis. 

b. If Permittee chooses to install an O2 CEMS, it shall be installed, 

calibrated and operated to measure O2 concentrations in ppmv. No later 

than the end of the shakedown period as defined in Condition X.J. or 

upon commencing commercial operations, whichever comes first, 

Permittee shall also maintain, certify, and quality-assure the CEMS for 

each CTG that measures O2 concentrations in ppmv, and shall conduct 

initial certification of the CEMS in accordance with Condition X.F.6. 

Permittee may not install an O2 CEMS in lieu of the CO2 CEMS in 

Condition X.F.1.a. 

2. The NOX, CO2, and O2 CEMS shall meet the applicable requirements of 40 

CFR Part 75. 

3. The CO CEMS shall meet the applicable requirements of 40 CFR Part 60 

Appendix B, Performance Specification 4, and 40 CFR Part 60 Appendix F, 

Procedure 1, except the relative accuracy specified in section 13.2 of 40 CFR 
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Palmdale Hybrid Power Project (SE 09-01) 

Proposed PSD Permit 

August 2011 

Part 60 Appendix B, Performance Specification 4 shall not exceed 20 percent. 

4. Each CEMS shall complete a minimum of one cycle of operation (sampling, 

analyzing, and data recording) for each successive 15-minute clock-hour 

period. 

5. The CEMS shall be tested in accordance with Conditions X.F.2 and X.F.3. 

6. The initial certification of the CEMS may either be conducted separately, as 

specified in 40 CFR § 60.334(b)(1), or as part of the initial performance test of 

each emission unit. The CEMS must undergo and pass initial performance 

specification testing on or before the date of the initial performance test. 

7. The CEMS shall meet the requirements of 40 CFR § 60.13. Data sampling, 

analyzing, and recording shall also be adequate to demonstrate compliance 

with emission limits during startup and shutdown. 

8. Not less than 90 days prior to the date of initial startup of the Facility, the 

Permittee shall submit to the EPA a quality assurance project plan for the 

certification and operation of the CEMS. Such a plan shall conform to EPA 

requirements contained in 40 CFR Part 60 Appendix F for CO, 40 CFR Part 

75 for NOX and O2 or CO2, and 40 CFR Part 75 Appendix B for stack flow. 

The plan shall be updated and resubmitted upon request by EPA. The protocol 

shall specify how emissions during startups and shutdowns will be determined 

and calculated, including quantifying flow accurately if calculations are used. 

9. The gas turbine CEMS shall be audited quarterly and tested annually in 

accordance with 40 CFR Part 60 Appendix F, Procedure 1. Permittee shall 

perform a full stack traverse during initial run of annual RATA testing of the 

CEMS, with testing points selected according to 40 CFR Part 60 Appendix A, 

Method 1. 

10. Permittee shall submit a CEMS performance test protocol to the EPA no later 

than 30 days prior to the test date to allow review of the test plan and to 

arrange for an observer to be present at the test. The performance test shall be 

conducted in accordance with the submitted protocol and any changes 

required by EPA. 

11. Permittee shall furnish the EPA a written report of the results of performance 

tests within 60 days of completion. 

12. The stack gas volumetric flow rates shall be calculated in accordance with the 
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Palmdale Hybrid Power Project (SE 09-01) 

Proposed PSD Permit 

August 2011 

fuel flowmeter requirements of 40 CFR Part 75 Appendix D in combination 

with the appropriate parts of EPA Method 19. 

13. Prior to the date of initial startup of GEN1 and GEN2, Permittee shall install, 

and thereafter maintain and operate, continuous monitoring and recording 

systems to measure and record the following operational parameters: 

a. The ammonia injection rate of the ammonia injection system of the 

SCR system. 

b. Exhaust gas temperature at the inlet to the SCR reactor. 

14. Permittee shall measure and record, for each Unit GEN1/DB1 and Unit 

GEN2/DB2, the following: 

a. The actual heat input and the heat input corrected to ISO standard day 

conditions (288 degrees Kelvin, 60 percent relative humidity, and 101.3 

kPal pressure) on an hourly basis; 

b. The pounds of CO2 per heat input (lb CO2/MMBtu) corrected to ISO 

standard day conditions on an hourly basis; and 

c. The 30-day rolling average emission rate lb CO2/MMBtu (at ISO 

standard day conditions). The 30-day rolling average shall be based on 

the average hourly lb/MMBtu recordings. 

15. Permittee shall measure and record, for the entire facility, the following: 

a. Net energy output (MWhnet) on an hourly basis;

b. Pounds of CO2 per net energy output (lb CO2/MWhnet) on an hourly 

basis;

c. The 30-day rolling average emission rates for lb CO2/MWhnet. The 30-

day rolling average shall be based on the average hourly lb 

CO2/MWhnet recordings. 

G. Performance Tests

1. Stack Tests 

a. Within 60 days after achieving normal operation, but not later than 180 

days after the initial startup of equipment, and, unless otherwise specified, 

annually thereafter (within 30 days of the initial performance test 

anniversary), Permittee shall conduct performance tests (as described in 40 

CFR § 60.8) as follows: 

i. NOX, CO, CO2, PM, PM10, and PM2.5 emissions from each gas turbine 
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Palmdale Hybrid Power Project (SE 09-01) 

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(Units GEN1/DB1 and GEN2/DB2); 

ii. NOX and CO emissions from the 110 MMBtu/hr boiler (D1) and the 

40 MMBtu/hr heater (D4); PM, PM10, and PM2.5 emissions from the 

110 MMBtu/hr boiler (D1) and the 40 MMBtu/hr heater (D4) shall be 

tested initially and at least every five years (within 30 days of the 

initial performance test anniversary); 

iii. NOX, CO, PM, PM10, and PM2.5 emissions from the 2,000 kW (2,683 

hp) internal combustion engine (D2), initial performance test only; 

iv. NOX, CO, PM, PM10, and PM2.5 emissions from the 182 hp firewater 

pump (D3), initial performance test only; and 

v. PM, PM10, and PM2.5 emissions from the cooling tower (D5). 

b. Permittee shall submit a performance test protocol to EPA no later than 30 

days prior to the test to allow review of the test plan and to arrange for an 

observer to be present at the test. The performance test shall be conducted 

in accordance with the submitted protocol, and any changes required by 

EPA. 

c. Performance tests shall be conducted in accordance with the test methods 

set forth in 40 CFR § 60.8 and 40 CFR Part 60 Appendix A, as modified 

below. In lieu of the specified test methods, equivalent methods may be 

used with prior written approval from EPA: 

i. EPA Methods 1-4 and 7E for NOX emissions measured in ppmvd 

ii. EPA Methods 1-4, 7E, and 19 for NOX emissions measured on a heat 

input basis 

iii. EPA Methods 1-4 and 10 for CO emissions 

iv. EPA Methods 1-4 and 3B for CO2 emissions 

v. EPA Methods 5 and 202, or Methods 201A and 202, for PM, PM10, 

and PM2.5, in accordance with the test methods set forth in 40 CFR § 

60.8, 40 CFR Part 60 Appendix A, and 40 CFR Part 51 Appendix M; 

in lieu of Method 202, Permittee may use EPA Conditional Test 

Methods for particulate matter CTM-039 

vi. Modified Method 306 or the Cooling Tower Institute’s heated bead 

test method for PM emissions from the cooling tower, and 

vii. the provisions of 40 CFR § 60.8 (f). 

d. The initial performance test conducted after initial startup shall use the test 

procedures for a “high NO2 emission site,” as specified in San Diego Test 

Method 100, to measure NOX emissions. The source shall be classified as 
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Palmdale Hybrid Power Project (SE 09-01) 

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either a “low” or “high” NO2 emission site based on these test results. If 

the emission source is classified as a: 

i. “high NO2 emission site,“ then each subsequent performance test shall 

use the test procedures for a “high NO2 emission site,” as specified in 

San Diego Test Method 100. 

ii. “low NO2 emission site,” then the test procedures for a “high NO2

emission site,” as specified in San Diego Test Method 100, shall be 

performed once every five years to verify the source's classification as 

a “low NO2 emission site.” 

e. The performance test methods for NOX emissions specified in Condition 

X.G.1.c.i and ii., may be modified as follows: 

i. Perform a minimum of 9 reference method runs, with a minimum time 

per run of 21 minutes, at a single load level, between 90 and 100 

percent of peak (or the highest physically achievable) load, and 

ii. Use the test data both to demonstrate compliance with the applicable 

NOX emission limit and to provide the required reference method data 

for the RATA of the CEMS. 

f. Upon written request and adequate justification from the Permittee, EPA 

may waive a specific annual test and/or allow for testing to be done at less 

than maximum operating capacity. 

g. For performance test purposes, sampling ports, platforms, and access shall 

be provided on the emission unit exhaust system in accordance with the 

requirements of 40 CFR § 60.8(e). 

h. Permittee shall furnish the EPA a written report of the results of 

performance tests within 60 days of completion. 

2. Cooling Tower Total Dissolved Solids Testing 

a. Permittee shall perform weekly tests of the blow-down water quality using 

an EPA-approved method. The operator shall maintain a log that contains 

the date and result of each blow-down water quality test, and the resulting 

mass emission rate. This log shall be maintained onsite for a minimum of 

five years and shall be provided to EPA and District personnel upon 

request. 

b. Permittee shall calculate PM, PM10, and PM2.5 emission rate using an 

EPA-approved calculation based on the TDS and water circulation rate. 

c. The operator shall conduct all required cooling tower water quality tests in 

accordance with an EPA-approved test and emissions calculation protocol. 

Thirty (30) days prior to the first such test, the operator shall provide a 
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Palmdale Hybrid Power Project (SE 09-01) 

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written test and emissions calculation protocol for EPA review and 

approval, with a copy to the District as specified in Condition XII below. 

d. A maintenance procedure shall be established that states how often and 

what procedures will be used to ensure the integrity of the drift 

eliminators, to ensure that the TDS limits are not exceeded, and to ensure 

compliance with recirculation rates. This procedure is to be kept onsite 

and made available to EPA and District personnel upon request. Permittee 

shall promptly report any deviations from this procedure. 

3. Fuel Testing 

a. Permittee shall take monthly samples of the natural gas combusted. The 

samples shall be analyzed for sulfur content using an ASTM method. The 

sulfur content test results shall be retained onsite and taken to ensure 

compliance with Special Conditions X.C and X.E for Units GEN1/DB1, 

GEN2/DB2, D1, and D4. 

H. Monitoring for Auxiliary Equipment 

1. Permittee shall install and maintain an operational non-resettable totalizing 

mass or volumetric flow meter in each fuel line for the 110 MMBtu/hr boiler 

(Unit D1) and the 40 MMBtu/hr heater (Unit D4). 

2. Permittee shall install and maintain an operational non-resettable elapsed time 

meter for the 110 MMBtu /hr boiler (Unit D1), 2,000 kW emergency use 

engine (Unit D2), the 182 hp emergency-use firewater pump (Unit D3), and 

the 40 MMBtu/hr heater (Unit D4). 

3. Permittee shall install and maintain a leak detection system on the circuit 

breakers that signals an alarm in the facility’s control room in the event that 

any circuit breaker loses more than 10% of its dielectric fluid. The 

owner/operator shall promptly respond to any alarm, investigate the circuit 

breaker involved, and fix any leak-tightness problems that caused the alarm. 

I. Recordkeeping and Reporting 

1. Permittee shall maintain a file of all records, data, measurements, reports, and 

documents related to the operation of the Facility, including, but not limited 

to, the following: all records or reports pertaining to adjustments and/or 

maintenance performed on any system or device at the Facility; all records 

relating to performance tests and monitoring of auxiliary combustion 

equipment; for each diesel fuel oil delivery, documents from the fuel supplier 

certifying compliance with the fuel sulfur content limit of Condition X.E; and 
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Palmdale Hybrid Power Project (SE 09-01) 

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all other information required by this permit recorded in a permanent form 

suitable for inspection. 

2. Permittee shall maintain CEMS records that include the following: the 

occurrence and duration of any startup, shutdown, shakedown, or malfunction, 

performance testing, evaluations, calibrations, checks, adjustments, 

maintenance, duration of any periods during which a continuous monitoring 

system or monitoring device is inoperative, and corresponding emission 

measurements. 

3. Permittee shall maintain records of all source tests and monitoring and 

compliance information required by this permit. 

4. Permittee shall maintain records and submit a written report of all excess 

emissions to EPA semi-annually, except when: more frequent reporting is 

specifically required by an applicable subpart; or the Administrator, on a caseby-case basis, determines that more frequent reporting is necessary to 

accurately assess the compliance status of the source. The report is due on the 

30th day following the end of each semi-annual period and shall include the 

following: 

a. Time intervals, data and magnitude of the excess emissions, the nature 

and cause (if known), corrective actions taken and preventive 

measures adopted; 

b. Applicable time and date of each period during which the CEMS was 

inoperative (monitor down-time), except for zero and span checks, and 

the nature of CEMS repairs or adjustments; 

c. A statement in the report of a negative declaration; that is, a statement 

when no excess emissions occurred or when the CEMS has not been 

inoperative, repaired, or adjusted; 

d. Any failure to conduct any required source testing, monitoring, or 

other compliance activities; and 

e. Any violation of limitations on operation, including but not limited to 

restrictions on hours of operation. 

5. Excess emissions shall be defined as any period in which the Facility 

emissions exceed the maximum emission limits set forth in this permit. 

6. A period of monitor down-time shall be any unit operating clock hour in 

which sufficient data are not obtained by the CEMS to validate the hour for 
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Palmdale Hybrid Power Project (SE 09-01) 

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NOX, CO, CO2, or O2, while the CEMS is also meeting the requirements of 

Condition X.F.7. 

7. Excess emissions indicated by the CEM system, source testing, or compliance 

monitoring shall be considered violations of the applicable emission limit for 

the purpose of this permit. 

8. Permittee shall maintain the Fugitive Dust Control Plan on-site, which shall 

include all documentation related to demonstrating compliance with Condition 

X.E.9 for Unit MV, in a permanent form suitable for inspection. 

9. Permittee shall conduct annual tune-ups as required by Condition X.E.10 for 

Units D1 and D4 and maintain onsite, and submit if requested by the 

Administrator, a biennial report containing the information in paragraphs (a) 

through (c) below: 

a. The concentrations of CO in the effluent stream in parts per million, by 

volume, and oxygen in volume percent, measured before and after the 

tune-up of the boiler. 

b. A description of any corrective actions taken as a part of the tune-up of 

the boiler. 

c. The type and amount of fuel used over the 12 months prior to the 

biennial tune-up of the boiler. 

10. Permittee shall record the pounds of dielectric fluid added to the circuit 

breakers each month. 

11. All records required by this PSD Permit shall be retained for not less than five 

years following the date of such measurements, maintenance, reports, and/or 

records. 

J. Shakedown Periods 

The combustion turbine emission limits and requirements in Conditions X.C, 

X.D, and X.E shall not apply during combustion shakedown periods. Shakedown 

is defined as the period beginning with initial startup and ending no later than 

initial performance testing, during which the Permittee conducts operational and 

contractual testing and tuning to ensure the safe, efficient and reliable operation of 

the plant. The shakedown period shall not exceed 90 days. The requirements of 

Section III of this permit shall apply at all times. 
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Palmdale Hybrid Power Project (SE 09-01) 

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XI. ACROYNMS AND ABBREVIATIONS

AQMD Air Quality Management District 

ASTM American Society for Testing and Materials 

BACT Best Available Control Technology 

BTU British Thermal Unit 

CAA Clean Air Act 

CEMS Continuous Emissions Monitoring System 

CFR Code of Federal Regulations 

CO Carbon Monoxide 

CO2e Carbon Dioxide Equivalent 

CTG Combustion Turbine Generator 

CTM Conditional Test Method 

District Antelope Valley Air Quality Management District 

DLN Dry Low NOX

(d)scf (dry) Standard Cubic Feet 

EPA Environmental Protection Agency 

FDOC Final Determination of Compliance 

g grams 

GE General Electric 

GHG Greenhouse Gas 

gpm Gallons Per Minute 

gr grains 

HHV Higher Heating Value 

HRSG Heat Recovery Steam Generator 

hp Horsepower 

hr Hour 

IC Internal Combustion 

kPa kilopascals 

kW Kilowatt 

lb Pounds 

lbs Pounds 

MMBtu Million British Thermal Units 

MW Megawatt 

NAAQS National Ambient Air Quality Standards 

NNSR Nonattainment New Source Review 

NO2 Nitrogen Dioxide 

NOX Oxides of Nitrogen 

NSPS New Source Performance Standards 

O2 Oxygen 

Ox-Cat Oxidation Catalyst 

PHPP Palmdale Hybrid Power Project 
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Palmdale Hybrid Power Project (SE 09-01) 

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August 2011 

PM Total Particulate Matter 

PM2.5 Particulate Matter with aerodynamic diameter less than 2.5 micrometers 

PM10 Particulate Matter with aerodynamic diameter less than 10 micrometers 

ppm Parts Per Million 

ppmvd Parts Per Million by Volume, Dry basis 

ppmv Parts Per Million by Volume 

PSD Prevention of Significant Deterioration 

PUC Public Utilities Commission 

RATA Relative Accuracy Test Audit 

SCR Selective Catalytic Reduction 

SF6 Sulfur Hexafluoride 

SO2 Sulfur Dioxide 

SOX Oxides of Sulfur 

STG Steam Turbine Generator 

TDS Total Dissolved Solids 

tpy Tons Per Year 

yr Year 

XII. AGENCY NOTIFICATIONS

All correspondence as required by this Approval to Construct must be sent to: 

A. Director, Air Division (Attn: AIR-5) 

EPA Region IX 

75 Hawthorne Street 

San Francisco, CA 94105-3901 

Email: R9.AEO@epa.gov

Fax: (415) 947-3579 

With a copy to: 

B. Air Pollution Control Officer 

Antelope Valley Air Quality Management District 

43301 Division Street, Suite 206 

Lancaster, CA 93535 

Fax: (661) 723-3450