APR-08-2008	 15:31 P.01 I A J c. Ut LJ\LU·Vk\'~U\ • I'm I'U:.;)\.JUl\,\.t,C,03 Jo\V,c,'U, I 

CALIFORNIA ENERGY COMMISSION 

ISH, NINTli STREET 

SACRAMENTO.CA 95814.5512 

DATE:	 April 8, 2008 I 

TO:	 Interested Parties 

FROM:	 Steve Munro, Compliance Project Manager 

SUBJECT: High Desert Power Project (97~AFC-1C) I . 

Staff Analysis of Proposed Modifications of ~r Quality Conditions 

Relating to Source Test Intervals and Other ACiministrative Changes 

On August 30, ~006~ High Desert Power Project, LLC flied a Jlition with the CalWomia 

Energy Commission to amend the Energy Commission Decisi6n for the High Desert 

Power Project. Staff prepared an analysis of this proposed ch~nge, and a copy is 

enclosed for your information and review. This analysis was d~1layed due to a lengthy 

federal review process. 

The project is an 830 MW combined cycle power plant located in the city of Victorville iii 

San Bernardino County. The project was certified by the Ener~y Commission on May 3. 

2000, and began cOTmerCial operation on April 22, 2002., II	 . 

The proposed changes, as modified by staff, will allow High Desert Power Project, LLC 

to alter its schedule for source testing its combustion turbines ~nd make other changes 

as follows:· .	 I . 

AQ-16	 Change annual test schedule for oxides 0 nitrogen (NOx), oxides 

of sulfur, (SOx), carbon monoxide (CO), a d ammonia slip (NH3) to 

once every 5 yea~.
 

Change annual test schedule for volatile 0
 ganic compounds (VOC) 

to once every three years. 

Delete the requirement to annually measure opacity. : . I 

AQ-17 Delete the condition as being unnecessa~.. 

. AQ-30 thange wording in first sentence from "thJ power block" to "this 

eqUipment" to correct an inadvertent draftil 9 error in a previous 

amendment of the condition. I . 

Energy Comm ssion staff reviewed the petition and assessed t e impacts of this 

proposal on environmental quality, pUblic health and safety, an proposes revisions to 

the existing conditions of certification described above and in t e enclosed Staff 

Analysis. It is staffs opinion that, with the implementation of rivised conditions, the 

project will remain in compliance with applicable laws, ordinanfes, regulations, and 

standards and rat the proposed modifications will not result in a significant adverse 

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direct or cumulative impact t~ the environment (Title 20, Califomia COd.. e of Regulations, 

Section 1769). I I I 

The petition and staff's ana'fsiS have been posted on the Energy ComlmisSi~n's webpage at http://www.ener~y.ca.gov/sitingcases/highdesert/compliance/index.html.

The Energy Commission's qrder (if approved) will also be posted on the webpage. 

Energy Commission staff int~nds to recommend approval of the petition at the June 4, 

2008 Business Meeting of tlie Energy Commission. If you have comments on this 

proposed modification, please submit them to me at the address below by May 8, 2008. 

. Steve Iii 

Munro, Compliance Project Manager 

californf Energy Commission 

151691 Street, MS-2000 II 

Sacram nto, CA 95814 • 

Comments may be submitte by fax to (916) 654-3882, or bye-mail to 

smunro@energy.state.ca.uJ. If you have any questions, please contact me 

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at (916) 

654-3936. l I 

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Enclosure 
APR-08-2008 P.03 15:32 

I	 'STAFF ANALYSIS 

I : PETITION TO AMEND·	 . 

:THE COMMISSION DECISION F R THE 

THE HIGH DESERT POWER PROJECT (97-AFC-1C) 

i I	 . Tuan Ngo 

INTRODUCTION! 

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On August 20, 2006, the High Desert Power Plant, LLC (HDPRI LLC) filed a request to 

amend Conditions of Certification AQ-16, AQ-17, AQ·20, and Q·30 for the HDPP 

facility. In brief, HD~P, LLC requests the following changes: 

1.	 AQ-16: I I . . I i 

a.	 Reduce the frequency of compliance testing for NO~ from annual to once 

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b.	 Reduce the frequency of compliance testing for voq from annual to once 

every three years,· I 

c.	 Eliminate compliance testing requirement for PM10 and Opacity. I 

2.	 AQ·17: Delete this condition of certification I 

3. AQ-20: Delete the requirement to report the number of start ups. and shut down. 

and their duration. 

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4.	 AQ·30: 'Administrative revision to correct an inadvertent error in wording in this 

condition of certification. I 

LAWS, OR~INANCES, REGULATIONS, AND STAN~ARDS . "	 I 

All applicable Laws, Ordinances, Regulations and Standards (~ORS) are listed below 

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Laws. Ordinances. ReQulations, and Standards {LORS) 

Applicable Law I Description I I

Federal LORS , 

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42 U.S.C. ~7401 et seo. I Federal Clean Air Act I 

State LORS I I 

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Health and Safety Code 

§41700 I I 

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"... no person shall discharge from any source 

whatsoever such quantities of air pontaminants or other 

material which cause injury, detriment, nuisance, or 

annoyance to any considerable n~mber of persons or 

10 the public, or which endanger t comfort, repose, 

health, or safety of any such pers ns or the public. or 

which cause, or have a natural terdency to cause, 

iniurv or damaae to business or oropertY." I I 

CAL.IFORNIA ENERGY COMMISSION 1	 April 4, 2008 

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Exhaust Emissions Standards and Test Procedures, 

lDff-Road Compression-Ionition Engines! I 

CCR Title 13 §2423 

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Local LORS - Mojave Des~rt Air Quality Management District 

Rule 201 Permits to Construct 

Rule 221 Federal Operatina Permit ReQuirement 

Rule 401 isible Emissions 

Rule 402 lJisance 

Rule 403 -ugitive Dust. 

Rule 404 particulate Matter Concentration 

Rule 409 Combustion Contaminates 

RuJe431 Sulfur Content of Fuels 

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STAFF ANALYSIS II I I 

Staff's objectives in complet~ng the air quality analysis for this amendnient rJquest are 

(1) to identify whether there /s a potential for a significant air quality impact; a.nd (2) to 

assure that appropriate mitigation measures have been applied to avoid or mitigate the 

identified potential air qUali~ impacts. . I I

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The HDPP facility was certified in 2000, and has been in commercial operation since 

2003. The facility is require<tl to undergo annual compliance tests for criterie air 

contaminants including oXid~s of nitrogen (NOx), volatile organic compounds (VaC), 

oxides of sulfur (SOx), carb~n monoxide (CO), particulate matter (PM10), and ammonia 

(NH3). In addition, the facili~y is required to continuously monitor the concentrations of 

NOx, NH3 and CO to verify eompliance with their applicable emission limits.I 

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Since the start of commerci~.1 operation, the facility has been undergone four annual 

source tests for the aforementioned air contaminants, and the results of these tests 

indicate that the facility is o~erating within compliance of all applicablei

emission limits. 

In addition, the collected co~tinuous emission monitoring system (CEMS) data for the 

facility also show that the fapility was within compliance limits. For those reasons, 

HDPP, LLC requests modification of annual source test reqUirements.: The following is 

staffs analysis of each speqific amendment request. I! 

REVISION OF AQ..16 I I I 

The applicant requests to rJlax the annual compliance tests for NOx, CO, NH3 and sax 

to once every five (5) years] For voe, the petition requests that the test frequency be 

reduced from an annual ba~is to once every three (3) years, and that the requirement of 

annual compliance tests fori PM10 and opacity be eliminated. i i 

NO", CO and NH3: The fa~i1ity's four (4) consecutive compliance lest resu'ns snow Inal 

the emissions of NOx, CO and NH3 are consistently 'below that of the limits specified in 

other conditions of certifjca~ion for the facility. In addition, staff believes that because 

the turbines are equipped with a CEMS, which measures the concentrations of NOx, 

CO and NH3 on an hourly b6siS, continuing compliance with applicable emission limits l

for these air contaminants nan be reasonably expected. Staff also believes that the 

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CALIFORNIA ENI;RGY COMMISSION 2 ! April 4, 2008 
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change to relax'the annual compliance test to once every five y~ars for NOx, CO and 

NH3 would not ~ause any emission change to the ambient air.fherefore, no significant 

impact to the air quality is expected and no mitigation is neces~ary.

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VQe: The four previous source tests also'showed that the tur~ines comply with 

applicable VOC emission· limits. The vac concentrations are riot being monitored by 

the CEMS. However, voe has a strong relationship to CO emIssions. Thus, 

continuous monitoring of CO emissions by the CEMS on an ho~rly basis can be used 

as a reasonable veri~ing tool for ensuri~gcompliancewith th~lvoe emission limits. 

Therefore, staff does not object to reducing the scheduled test'rg frequency of the 

turbines' voe emissions. Staff also believes that the change to the voe testing 

frequency would not cause any emission changes; therefore, n~ significant impact is 

expected and no mit~gation is needed. J 

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PM10: Althou~h the four previous consecutive tests showed t at the turbines comply 

with the PM10 emis~ion limits, staff is not con'fident thatthe P 110 emission limits can 

be readily verifiable on a long term basis for two reasons: 1) although the turbines are 

relatively new and their emissions are currently low, staff belie\lres that over time. their , , I 

PM10 emissions would likely increase; and 2) source test res~lts from numerous 

turbines that recently started commercial operation showed a 'fide SWing of PM10 

emissions, which in many cases reqUired repeating the tests t~ demonstrate 

compliance. Furthermore, the CEMS does not monitor PM10, and thus without 

compliance tests, staff is left with no means to verify whether t e turbines are operating 

within the PM1 0 emission limits. Staff recommends that annual PM10 emissions testing 

be retained. i I I· 

Opacity: The applicant requests waiving of the testing requir~ment for opacity because 

the facility is using pipeline quality natur.al gas. Because opacity is an indicator of 

incomplete cor:nbustion, and because the turbines are equiPp~d with a CEMS that 

monitors COt staff does not object to removing the annual tes~ng requirement for 

opacity. Staff believes that elimination of opacity testing requi ement will not cause any 

increased emissions, and therefore, no significant impact is e pected and no mitigation 

is needed. I I I 

ELiMINATlbN O~ AQ..17: I 

This condition 10f ce~ification was originally intended to provid, a reliable means to 

verify compliance with the voe emission limits using CO concentrations as a surrogate. 

Four recent compliance tests show that the turbines' vae emIssions were consistently 

below the vae emission limits. In fact the measured vae concentrations were less 

than 10 percent of the vae emission limits; therefore, staff h~s no objection to deleting 

condition AQ-17 and its requirements. Removal of AQ-17 is ryot expected to result in 

increased vae emissions to the atmosphere; therefore, no mItigation is needed. 

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ADMINIST~T'YE CHANGES TO AQ·20 . I 

The applicant requests removal of the requirement to report the number, time and 

duration of startup and shutdown events for each turbine in c9ndition AQ-20. However, 

staff believes that this is the only mechanism to provide verifioation that the facility's 

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quarterly and annual emiSsiots are in compliance with the applicable limits. Therefore, 

staff does not recommend th proposed revisions of condition AQ-20. I I

ADMINISTRATIVE CHA GES TO J:\Q.30	 : : 

HDPP,LLC requests an ad~inistrative change to condition AQ-30 to c?rrectia . 

typographical error in this co~dition. Staff does not object to this change, and beheves 

that the change will not resull in increased air emissions; therefore no mitigation is 

needed. I 1 

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CONCLUSIONS AND RECOMMENDATIONS 1 

Staff recommends approval I. ~f the following proposed changes to condition AQ-16: 1 I 

•	 The revision of comPI~'nee testing frequency for NOx, CO, NH3 ~nd SOx 

specified in condition Q·16 from an annual basis to once ever-) five years would 

result in no significant impact to the environment; therefore, no mitigation is 

reqUired. j	 .. :: . 

•	 The revision of comp~ancetesting frequency for VOC specified in condition
 

AQ-16 from an annual basis to once every three years would result in no .
 

significant impact to tie environment; therefore, no mitigation is :requi~ed.
 

•	 The deletion of compliance testing for opacity specified in condition AQ-16 would 

resu!t in no significan~ impact to the environment; therefore, no r;nitiga~ion is l	 .:

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requIred.	 I 

Staff does not recommend diletion of annual testing requirements in cbndition AQ-16 

for PM10, as this is the only eans for staff to verify compliance with the PM10 

emission limits. I I 

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The deletion of condition Aq-17 would result in no significant impact to 

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the environment, 

and no mitigation is requiredl, thus staff recommends the approval of it~ dele~ion.

Staff does not recommend r~vision of start up and shut down events r~porti~g . 

reqUirements in condition AQ~20, as this is the only means for staff to verify facility's 

compliance wtth the emissio~ limits. I . 

The revision of condition Acl-30 to correct an inadvertent drafting error would result in 1 

no significant impact to the 1nvironment, and no mitigation is required',I thus .staff 

recommends approval of th. requested revision to condition AQ-30. 1 : 

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The folloWing are the recomrended revisions to Conditions of Certification AQ-16, AQ17, AQ-20, and AQ-30. I : 

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CAL.IFORNIA ENERGY COMMISSION 4	 Apri/4.2008 

TOTAL P.06