PTRMITTO OPERATE

GREAT BASIN UNIFIED AIRPOLLUTION CONTROL DISTRICT

157 Short Street * Bishop, California 93514 * (760) 872-8211 * Fax (760) 872-6109

PERMIT IYUMBERZ34

Pursuanto the authority granted under the Rules and Regulations for the Great Basin

Unified Air Pollution Control District" the

Coso Operating ComPanY LLC

Operator for Coso Finance Partners

P.O. Box 1690

fnyokern' CA 93527

35 miles north of Ridgecrest on Highway 395

Coso Junction' CA 93542

is hereby granted a Permit to Operate as of April 9, 2001 for the following described

operations, associated equipment and buildings located at:

Coso Operating ComPanY LLC

Designated as NarY I' Unit I

Section 8, Township 22 South, Range 39 East'

Mount Diablo Base and Meridian. Inyo County, California

This Perrrit to Operate is granted for one year and may be renewed upon payment of

the renewal fee on or before the anniversary date, February 2a @iiling month 2)-

EQLIIPMENT DESCRIPTION: Narv I' Unit 1

One Mitsubishi Electric 25 MVy Modular

eothermal Power Plant

CONTROL EQIIIPMENT: Shared by Units 1' 2 and 3

Nash liquid ring vacuum pump and compressor gas removaf system

Lo-Cat II HrS treatment Plant

Hondo (tVPe) H2S abatement sYstem

PERMIT CONDITIONS: This perrrit is zubject to the attached conditional approval pages I through 7-

Thls Permlt does not authorlze tho abone permltbe to vlolate any

of the Rutes and Regutatons of the Grcat Baln Unllled Alr- 

fion Control D6trlct or DMslon 26, Chapter 2, Ardcte 3, of the

n A Safety Gode of the State of Gallfomla' Any modlficadon

or tre equipment or operaEon, a defined In Dlstrlct Rule 2ll0'A'

wifl reqritd a nsw Permtt Thlrs permlt shall be pc'bd as

prccribed In Dlstrlct Rute 200.D.

ON COI{|:fROI, OFFICER

Dat-e A f 

' 'o at, ^oo I
PERMIT TO OPERATE CONDITIONAL APPROVAL NO. 234

Goso Operating Company, LLC

Operator for Coso Finance Partners

Navy l, Unit 1

Mitsubishi Electric 25 MW Modular Geothermal Power Plant

Page 1 ol 7

PERMIT CONDITIONS:

GONDITION 1 - Best Available Control Technologv |BAGTI

Best Available Control Technology (BACTI shall be utilized to control Hydrogen Sulfide (HzSl

emissions from the power plant. Gurrent BACT consists of the Dow SulFerox or Lo-Gat ll liquid

redox system. lf future performance within the Coso KGRA indicates that HrS emissions can not

be maintained below that cunently attained at other KGMts within Galifornia, Coso Operating

Gompany, LLC lthe Operatorl shall prepare and submit a report describing the emissions associated

with all plant operations. The report shall include discussions on technology and costs associated

with maintaining H"S emissions at the levels equal to Best Available Control Technology (BACTI

during all phases of plant operation. In the event emissions from the power plant contribute to

violations of a Federal or Califomia ambient air quality standard or are in violation of a Local, State,

or Federal regulation the Operator will need to cor?ect the problem immediately or request a

variance from the GBUAPCD Hearing Board.

GONDITION 2 - Hvdrogen Sulfide Gontent

The Hydrogen Sulfide content in the condensate used for cooling tower make-up water may not

cause the cooling tower emissions to exceed 2.5 lb/hr.

GONDITION 3 - Plan for Testino the Performance of the Power Plant

Every four yearc tha Operator shall submit for approval, a detailed plan tor testing the performance

of the Power Plant and related facilities, including but not limited to cooling tower emissions at

normal full load operation. Normal full load operation is defined as operating the Power Plant at a

minimum ol80o/o of the gloss electricity generating capacity. The plan shall include stack testing

of the H"S exlt gas from the Lo-Cat ll HzS treatment plant, Hondo ttypet HrS abatement system,

cooling tower drift, and condensate used for make up water. The Hondo (typel HrS abatement

system need only be tested if it is in service during the period when a source test is performed for

the power plant and related facilities. Every four years the Operator shall have performed by a

reputable firm the chemical analysis for the appropriate elements, compounds, and substances

listed as toxic which may be emitted to the atmosphere. Toxic air emissions are those listed on the

AB2588list of substances as required by the Califomia Health & Safety Gode Section U321.

Before performance testing, the Operator or their contractor shall submit a source test ptotocol.

The source test protocol shall describe the procedures and methods to be used during source

testing. These testing methods shall be approved by the District in advance of their use. The

GBUAPCD shall approve, disapprove or modify the plan within 6O days of receipt, The Operator

shall complete the performance testing within 12O days for the first test or 60 days for the tests

after GBUAPGD's approval of the plan. A report of the data collected during the performance test

shall be submitted to the GBUAPCD within 6O days from the date of the test.

GONDITION 4 - Venting Plan

As required by the APCO, the Operator shall submit for approval, an updated plan for controlling

vented emissions described in Condition 5. The GBUAPCD shall review the plan and within 6O days

of receipt respond by either approving the plan or retuming it to the Operator lor further

clarification. The vented emissions plan shall be supported by quantification of all atmospheric
:

Mitsubishi Electric 25 MW Modular Geothermal Power Plant

Page 2 ol 7

vented emissions, with emphasis placed on: air quality impacts resulting from cold start up, warm

start up, emergency shutdown/start up and include multiple power plant shutdown, under worst

case meteorological conditions. The plan shall also include cumulative air quality impact modeling

of multiple power plant unit(sl consisting of the Navy l, ll, and BLM projects and other operating

and planned unit(sl. The plan shall also show that the ambient air quality standard will not be

exceeded, Upon approval by the District, the submitted plan and any required revisions shall be

incorporated by reference into this permit and will be equalfy enforceabfe,

GONDITION 5 - Breakdowns

Venting from the power plant during breakdown or upset conditions will fotlow guidelines set in

Rule 403 of the GBUAPCD Book of Rules and Regulations. For this condition an upset condition

shall be defined as any condition ttat requires venting to maintain tihe integrity of the power ptant

equipment. The Operator shall make every possible effort to control the vented emissions within

15 minutes. lf vented emissions cannot be controlled in 15 minutes, the Operator shall immediately

notify the GBUAPCD within t hour and advise them of the situation and amount of time required to

contlof the vented emissions. The Operator shall reduce HrS emissions by 9Oo/o ot more within one

hour by use of the control plan developed under Condition 4, whether or not there is a turbine trip.

During range closuros, ot unattended power pfant operation. any failure of the non-condensable

control system or turbine trip shall trigger an automatic cut back, shut-in or diversion to other units

sufficient to prevent uncontrolled venting, (Rule 4O3l

GONDITION 6 - HrS Emission Limit

The Operator shall not discharge into the atmosphere fiom any geothermal power ptant more than

1OO grams/MwHr/Unit of HrS, dudng any continuous hour. Gule 424.81

GONDITION 7 - H^S Levels Measured at the Goso Naw Entrance Gate

lf H2S levels measured at the Goso Navy entrance gate are increasing and exceed a one hour

average of 15 ppbv {parts per billion by volumel, the Operator must reduce HrS venting within one

hour. lf the ona hour average H.S levels at the Goso Navy entrance gate reach or exceeds 18 ppbv

the Operator shall suspend, within one hour, all venting from its Goso KGRA facilities in excess of

1OO grams/MwHr/Unit. This suspension shall be rescinded when the HzS levels at the gate return

to 15 ppbv or less.

GONDITION 8 - Dust Abatement Plan

Fugitive dust emissions from construction operations, cleared areas, and dirt roads shall be

controlled by GBUAPCD approved methods. Use of waste crankcase oil, or petroleum product is

not considered an approved dust abatement method. The Operator shall submit a written plan to

the GBUAPCD, 12O days prior to construction or clearing of any vegetation, lor approval by the

GBUAPCD. The plan shall describe dust control measures to bB utilized during the construction

operation or clearing process, including roads. Frequency of application, maintenance, and dust

monitoring procedures will be clearly described within the plan. The GBUAPGD shall approve,

disapprove, or modify the plan within 6O days of receipt.

GONDITION 9 - Frgitive Dust

Goso Operating Company employees and contractors will comply with the posted speed. COC shall

conduct safety and compliance training with every employee and contactor that enters the proiect,

GONDITION 1O - Safe Access to Sgmple Ports

The Operator shall provide safe access to sample ports that enable representatives of the
Mitsubishi Electric 25 MW Modular Geothermal Power Plant

Page 3 of 7

GBUAPCD or GARB to collect samples from the condensate or circulating water upstream of the

cooling tower and cooling tower stacks. The Operator shall also provide for safe access to Sample

ports at the outlets of the Lo-Gat ll H2S treatment plant and the Hondo (typel HrS abatement

system. lf deemed necessary by the District to verify eompliance with these condhions, the

Operator shall within Tdays notice be available to open any water well or vapor extraction port for

the purpose of conducting source tests or to collect samples. A qualified representative of GOG

should take requested samples for the District in the presence of a District representative.

CONDITION 11 - Permit Subiect to Goncurrence

This permit is subject to concurrence by the Galifomia Afr Resources Board and the Environmental

Protection Agency within thirty l3Ol days of receipt.

GoNDlrloN 12 - Permit Does Not Establish Precedent for Future permh

These conditions are for Geothermal Power Plant Unit 1, Permit to Operate Number 234. The

Operator agrees that this permit does not establish a precedent for issuing future permits to the

Operator.

GONDITION 13 - lmolementino Reoulations

The Operator shall conform with existing Local, State, and Federal laws or statutes and their

implementing regulations in the development and operation of the above-specified Geothermal

power plant.

GONDITION 14 - Record Keeoinq

A copy of a permanent time records of the total duration of bleeding and venting from the power

plant shall be maintained in the Operator's field office and be made available to the employees of

the District upon request.

GONDITION 15 - NC Gas Ventino

The Operator shall record the pressure and volumetric flow in real time by use of a strip chart, or

other District approved means and by use of electronic data recording, any diversion or venting of

non-condensable gas to the cooling tower or any other potential emission point. Atl noncondensable gas emissions diverted in excess of 5.5 pounds HrS in any hour, shall be promptly

reported to the District, and their records made available to the District staff upon request. During

direct operator diversion or venting of any non-condensable gas to any potential emission point

without a turbine trip or equipment breakdown the Operator shall comply with Rule 424.8 of the

District Book of Rules and Regulations. The intentional diverting and venting of non-condensabte

gases to maintain and protect the generation of electrical power will not be considered a Breakdown

Condition as characterized in Gondition 5. The Operator shall make every effort to utilize the LoGatll liquid Redox HrS treatment pfant and Hondo ltype) HrS abatement system. In the event of

any unforeseeable NG gas system failure, the Operator shall comply whh District Rule 4O3,

Breakdown and Gondhion 5.

CONDITION 16 - Power Plant Outaoe

To minimize emission impacts during power plant start-ups and outages, the Operator shall stagger

and coordinate any scheduled outage and unit start up to comply with Bule 424.E and Condition 7.

Upon an unscheduled outage at Navy I, the Operator shalh 1l within 4 hours or less reduce H2S

emissions by 9oo/o ot more for one unit, or by 650/o or mote if a simultaneous outage of all three

NaW I units occurs, or to not more than 15 kg/hr/unit (33 lbs/hr/unitl, and 2) reduce lacility-wide

emissions within one hour in accordance with Gondition 7 if hourly ambient impacts are greater
:"

Mitsubishi Electric 25 MW Modular Geothermal Power Plant

Page 4 of 7

than 15 ppbv at the Coso Navy entrance gate. The timeframes for meeting these requirements are

based on the air quality impacts evaluated in the G&GE report October 10, 2OOO and may be

revised as resource and facility conditions change.

CONDITION 17 - Uncontrolled Ventino

Should three (31 or mole uncontrolled venting episodes involving all nine power ptants occur during

any one year period, or a violation of an Ambient Air Quality Standard occur, the Operator shall

submit to the District within 9O days plans to reduce emissions describing how the Ambient Air

Ouality Standards will be protected. In addition to the above plan, the Operator will resubmit an

updated vented emission plan for all previously issued power plant permits.

GONDITION 18 - Condensate Gollection

A common closed condensate coflection system shall bE used to dispose of necessary transmission

line and power plant fluids through the brine injection system. NG gas will be disposed through the

Lo-Gat ll Hzs treatment plant and/or Hondo (type) Hrs abatement system.

GONDITION 19 - Toxic Emissions

The Operator shall promptly notify the District in writing should they leam of or encounter

conditions where toxic emissions of concern are emitted and allowed to disperse into the ambient

air. Toxic air emissions are those listed on the AB2588list of substances as required by Califomia

Heafth & Safety Code Section 44321.

CONDITION 2O - Control Svstem Maintenance

The Lo-Gat ll H2S treatment plant and Hondo (typel HrS abatement system shall be property

maintained to serve as primary, altemate or parallel conttol systems to control HrS emissions from

the Navy I, Unit I Power Plant.

CONDITION 21 - Emission Limits

Taking into account all possible HrS emission points, including the Lo-Gat ll H2S treatment system,

Hondo (9pel H"S abatement system, cooling tower, and other facility emission points, tlre

maximum allowable HrS emissions shall be limited to 1OO grams/MwHr of HrS for the Navy I, Unit

1 power plant (District Rule 424.8.1. Hydrogen Sulfide (H2Sl emissions from the Lo-Cat ll H2S

treatment plant, which treats the non-condensable gas from the combined Navy I, Units 1, i, and

3, shall not exceed an average HrS emission rate of 1.8 pounds per hour for the previous 169

hours of operation, excluding hours when the treatment plant emissions exceed the lOO g/MW-hour

emission limh. The Operator shall report any exceedence of the emission timit to the District within

96 hours after such occurence. (CH&SC g42706l

CONDITION 22 - Gontinuous Emission Monitor. Record Keeoino and Maintenance

The HrS concentration and gas flow rate shall be recorded for the outlet of the Lo-Gat ll HzS

treatment plant and Hondo (typel HrS abatement system to continuously monitor the H2S

concentration in parts per million by volume and the HrS emissions rate in pounds per hour. The

sweet gas and exhaust flow rate from the Lo-Gat ll H2S treatment plant and Hondo (typel HrS

abatement system shall be continuously measured and recorded by a District approved continuous

emission monitor, which shall be properly maintained and seMced at least twice monthly. Every

six months the Operator shall check the monitor's accuracy by performing a multi-point precision

calibration. The Operator shall submit for District approval a quality assurance plan describing the

calibration procedures necessary to accutately colfect data and measure the H.S emission limits.
".

Mitsubishi Electric 25 MW Modular Geothermal Power Plant

Page 6 ol 7

GONDITION 23 - GEMs Record Keepino

The Operator shall maintain a records showing when the Lo-Cat ll H2S treatment plants and/or

Hondo (typel H.S abatement system were used for H"S control. Emissions that may occur during

the process of switching to altemate control methods shall be subiect to District Rule 424.8 and

shall not be considered under Rule 4O3 for breakdowns. Records shall be maintained for five years.

CONDITION 24 - Emission Umit

At no time shall emissions of any pollutant, for which there is a Federal or State ambient air quality

standard, exceed 25O lbs/day during operation of this permitted facility.

CONDITION 25 - Monitor and Record Ventino from the Nash Pumo and Gomoressor Svstem

The Operator shall monhor and record any uncontrolled emissions of non-condensable gases from

venting of the Nash liquid ring vacuum pump and compressor gas removal system. Any

uncontrolled vent line from the Nash liquid ring vacuum pump and compressor gas removal system

shall be equipped with a record keeping device to record and monitor uncontrolled hourly HzS

emissions or emissions shall be estimated in a method approved by the APCO.

GONDITION 26 - Pressure Control

tCV-26 valves shall not be used for pressure control.

GONDITION 27 - Air Monitorino Proqram

A state of the art ambient air quality monitoring network, with stations in locations determined by

the District, shall be continuously operated and maintained according to the regulations found in

Title 40 of the Gode of Regulations Part 58, Prevention of Significant Deterioration (PSDI. This

network will include, but not be fimited to, monitors for the following: wind speed, wind direction,

sigma theta, ambient temperature, relative humidity, precipitation, PM-IO, and hydrogen sulfide

(HzSl. All instruments used in the network shall be approved by the District and kept in good

operating condition through continuous maintenance and calibration practices as specified in the

aforementioned PSD guidelines, the equipment manufacturer's operating manuals, the EPA Ouality

Assurance Handbook for Air Pollution Measurement Systems, Vols. l, ll, and lV, and the Galifomia

Air Resources Board, Air Monitodng Ouality Assurance Handbook Vol. I, and ll, including additional

specifications determined by the District as listed in the permit conditions. The data shall be

recorded electronically by a data logger and the H"S information backed up by a continuous strip

chart.

GONDITION 28 - Air Monitorino Plan

The Operator shall submit for approval an ambient air monitoring plan by October 1, 2OOO. The

District shall review the plan and within 45 days of receipt respond by ehher approving the plan or

returning it to the Operator for modifications. The plan shall be wrttten to conform to requirements

contained in 4O CFR Part 58, PSD monitoring guidelines. Upon approval by the Distdct, the

submitted ambient air monitoring plan and any required revisions shall be incorporated by reference

into this permit and will be equally enforceable.

GONDITION 29 - OA/QG Manual

The Operator shall submit for approval a O,uality Assurance/ Ouality Control (OA/OCI Manual by

October 1, 2OOO. The District shall review the OA/OC Manual within 45 days of receipt and

respond by either approving the OA/OC Manual or retuming it to the Operator for modifications,

The OA/OG Manual shall be written to conform to requirements contained in lto CFR Part 58, PSD
Mitsubishi Electric 25 MW Modular Geothermal Power Plant

Page 6 of 7

monitoring guidelines. Upon approval by the District, the submitted OA/OC Manual and any required

revisions shall be incorporated by reference into this permit and will be equally enforceable.

GONDITION 3O - Ambient Monitorino and Meteoroloqical Equipment

Only data collected from ambient hydrogen sulfide analyzers based on EPA reference or equivalent

method sulfur dioxide analyzers, subject to approval by the District, will be accepted. Only

meteorological data collected from sensors that comply with 40 GFR, Part 58, PSD Guidelines, and

the USEPA's PSD guidance document IEPA-45O/4-87-OO7) will be accepted by the District.

CONDITION 31 - Audits

The Operator shall have an independent consultant perform quarterly quality assurance performance

audits of the ambient air monitoring network, and semi-annual levery six monthsl audits of the

meteorological monitoring network. One system audit, one data processing audit, and one audit of

the laboratory processing the PM-IO filters shall be performed annually by an independent

consultant. Audits are to be carried out by a consultant approved by the District. The Operator

shall notify the District of the audit schedule at least 1O working days in advance of the date of the

audit, Audit reports shall be submifted to the Operator and the District at the same time and within

3O days of the audit.

CONDITION 32 - HrS Analvzer and Meteoroqical Sensor Galibration Ghecks

The frequency of ambient H"S analyzer checks shall be, at minimum, as follows: zerolspan checks

once per week; precision checks once every two weeks lalong with the weekly zerolspan checksl;

multipoint calibrations quarterly. Meteorological sensor calibrations shall be performed twice per

year, at minimum. Note: The quarterly quality assurance performance audits may not be used in

place of any of the aforementioned analyzer or sensor checks. lnstrument checks are not to be

conducted during periods of high HrS measurements.

GONDITION 33 - Periodic Audits and Inspections

The Operator shall have personnel available for periodic audits conducted by the District or the

Galifomia Air Resources Board. All facilities and monitoring records shall be made availabte to

District personnel for inspection during normal business hours.

GONDITION 34 - Monitoring Data Reoorts

Monitoring data reports shall be submitted to the District within 30 days of the end of a calendar

month, e,g. the first monthly data report, containing the July data, is to be submitted to the

District by August 31. The District will comment on the report within 3O days of receipt. Data

reports will contain data from the primary data acquisition systems (data loggersl, including two

copies of a complete hard copy report and, in addition, the data tables submitted in a Microsoft

Excel format or an electronic media format as specified by the District. The data reports wil! also

include tte backup strip charts for the gas analyzer data, as well as all calibration and maintenance

records, including raw data forms, for the monitoring period.

CONDITION 35 - Modem Access to Ambient Air and Meteorological Data

The Operator shall provide modem access to real-time ambient hydrogen sulfide and meteorological

data obtained at the Coso NaW Entrance Gate and the Blast Site by October 1, 2OOO. The modem

accessible data shall provide a record of l5-minute average values for H"S. lf H2S levels at these

sites reach or exceed a one hour average of 15 ppbv, the Operator shall notify the District via FAX

transmission within one hour of the event.
Mitsubishi Electric 25 MW Modular Geothermal Power Plant

PageT of7

GONDITION 36 - Ambient PM-IO Data Collection

Ambient PM-IO samples shall be.collected once every third day at the Coso Junction site on tfie

federaf ambient monitor sampling schedule using USEPA-approved reference or equivalent method

samplers (40CFR, Part 52). The required PM-IO data capture rate ls 75o/o of the third day samples

per calendar quarter.

CONDITION 37 - Ambient HrS and Meteoroloqical Data Gapture Rates

The required data capture tates are 8O7o per month for the continuous HrS analyzer data and 9O%

for the meteorological data. Downtime due to normal station checks and calibrations are to be

counted against the data capture.

GONDITION 38 - Air Monitor Breakdown Reoortino

Any breakdown of a continuous emission monitor, ambient air monitor, or meteorological equipment

shall be reported within one (11hour of detection as required under District Rule 4O3.

CONDITION 39 - Rioht of Entrv

The Air Pollution Gontrol Officer, and any other District representative upon presentation of his or

her Distdct credentials, shall have unrestdcted access to the facility in order to obserue or inspect

any eguipment, work practices, air emission related activity or method allowed or required by this

permit, or to inspect or copy any document, or other record in whatever form, required to be made

or kept under this permit, or other applicable rule, regulation, or law relating to air pollution control,

with the sole exception of periods during which the US Navy declares a range closure which affects

all non-military personnel at the facility or the portions of the facility of which inspection is sought.