APR-08-2008 15:31 P.01 I A Jc. 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

. 

### StaffAnalysis 

### of Proposed Modifications of**~r** 

### Quality Conditions Relating to Source Test Intervals and OtherACiministrative Changes



### On August 30,

# ~006~ High Desert Power Project, 

### LLC 

### flied a Jlitionwith the CalWomia Energy Commission to amend the Energy Commission Decisi6n for the High Desert Power Project. Staff prepared an analysis ofthis proposed

### ch~nge, and a copy is enclosed for your information and review. This analysis was

## d~1 layed due to a lengthy federal review process.
The project is an 830 MW combined cycle power plant located in the city ofVictorville 

### 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 drafti l 9 error in a previous amendment ofthe condition.
I

. Energy Comm ssion staff reviewed the petition and assessed 

### t e impacts ofthis 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 ratthe proposed modifications will not result in a significant adverse
lP.02 I 

### r APR-08-2008 15:32 

### Page 2

,. I r 

### 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. Ifyou have comments on this proposed modification, please submit them to 

### me at the address below 

### by May 

### 8, 2008.

. Iii Steve 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.u

## J

. Ifyou have any questions, please contact me i 

### at (916) 654-3936. 

## l

I I 

### EnclosureP.03 APR-08-2008 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

. I I 

# 1

INTRODUCTION! I

# ' f I 

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

### 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

## ~~~~~ I 

### 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.

I I i I 

### 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

I I I

. 

### Laws. Ordinances. ReQulations, and Standards {LORS) Applicable Law 

## I Description I I 

### Federal 

### LORS

, I 

### 42 U.S.C.**~7401** 

### et seo. 

## I Federal Clean Air Act I 

### State LORS I I I 

### Health and Safety Code 

### §41700 I I

I ,
I

I ,

I
I I I 

### "

... no person shall discharge from any source whatsoever such quantities ofair 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

I IP.04 I , I ( APR-08-2008 15:33

! 

### Exhaust Emissions Standards and Test Procedures, lDff-Road Compression-Ionition Engines! I 

### CCR Title 13 

### §2423

I I I
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I
I

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:
I 

### 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

I 

### 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 I I . 

### 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

I I 

### Since the start of

### commerci~.1 operation, the facility has been undergone four annual source tests for the aforementioned air contaminants, and the results ofthese tests indicate that the facility is

## o~erating within compliance of all applicable i 

### 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 ofthe 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 b

### 6siS, continuing compliance with applicable emission limits l 

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

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! I CALIFORNIA ENI;RGY COMMISSION 2 ! April 4, 2008I APR-08-2008 15:33 I I P.05

I I

. i 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 impactto the air quality is expected and no mitigation is**neces~ary.**
I I I 

### 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~gcompliance with

### th~lvoe emission limits. Therefore, staff does not object to reducing the scheduled test'rg frequency ofthe turbines' voe emissions. Staff also believes thatthe 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

i 

### PM10:

# Althou~h the four previous consecutive tests showed 

### t atthe 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 ofthe 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 ofthe 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.

I I

# 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



# . I! .[

CALIFORNIA ENERGY COMMISSION 3 April 4, 2008 IP.06 . [ APR-08-2008 15:34

I quarterly and annual emiSsiots are in compliance with the applicable limits. Therefore, staffdoes 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 i 1 I 

### CONCLUSIONS AND RECOMMENDATIONS

1 Staff recommends approval

# ~f the following proposed changes to condition AQ-16: 

### I.

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~ance testing 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 .: I :
requIred. I Staffdoes not recommend diletion of annual testing requirements in cbndition AQ-16 for PM10, as this is the only eans for staffto verify compliance with the PM10 emission limits. I I I I
I The deletion of condition Aq-17 would result in no significant impact to 1 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

# 1 nvironment, and no mitigation 

### is required ',I thus .staff recommends approval ofth. requested revision to condition AQ-30.

1 :

. I I 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