# PTRMITTO

OPERATE

GREAT BASIN UNIFIED AIRPOLLUTION CONTROLDISTRICT
157ShortStreet

* Bishop,California93514 * (760)872-8211

* Fax(760)872-6109



## PERMIT IYUMBERZ34

Pursuant o theauthoritygranted

undertheRulesandRegulations for theGreatBasin Unified Air PollutionControlDistrict"the

CosoOperatingComPanY LLC Operatorfor CosoFinancePartners

P.O.Box 1690 fnyokern' CA 93527 35 milesnorth of Ridgecrest on Highway 395 Coso Junction' CA 93542

is herebygranteda Permitto Operateasof April 9, 2001for the following described operations,

associated

equipment

andbuildingslocated

at: Coso OperatingComPanY

LLC Designated

asNarY I' Unit I Section 8,Township22South,Range39 East' Mount DiabloBase

andMeridian. Inyo County,California

This Perrritto Operate

is granted

for oneyearandmayberenewed uponpayment

of
therenewal

feeonor beforetheanniversary date,February

2a @iiling month2)-

EQLIIPMENT DESCRIPTION: Narv I' Unit 1 OneMitsubishi Electric25MVyModular eothermalPower Plant

CONTROL EQIIIPMENT: Sharedby Units 1' 2 and 3

Nashliquid ring vacuumpump andcompressor gasremovafsystem Lo-Cat II HrStreatment Plant Hondo (tVPe)

H2SabatementsYstem

PERMITCONDITIONS:Thisperrrit is zubject totheattached

conditionalapprovalpagesI through7-

Thls Permltdoes not authorlzetho abonepermltbe to vlolate any of the Rutesand Regutatons of the Grcat Baln UnllledAlr

- fion Control D6trlct or DMslon 26,Chapter2,Ardcte 3,of the

n A SafetyGodeof the Stateof Gallfomla' Any modlficadon

ortre equipmentor operaEon,a defined In Dlstrlct Rule2ll0'A'
wifl reqritd a nsw Permtt Thlrs permlt shall be pc'bd as prccribed In Dlstrlct Rute200.D. ON COI{|:fROI, OFFICER



### Dat-e A f ' 'o at, ^oo IPERMIT 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

PERMITCONDITIONS:

GONDITION1 - Best Available Control Technologv |BAGTI BestAvailable Control Technology (BACTI shall be utilized to control Hydrogen Sulfide (HzSl emissionsfrom the power plant. Gurrent BACT consists of the Dow SulFeroxor 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 describingthe emissions associated with all plant operations. The report shall include discussions on technology and costs associated with maintaining H"S emissions at the levels equalto Best Available Control Technology (BACTI during all phases of plant operation. In the event emissionsfrom the power plant contribute to violations of a Federalor Califomia ambient air quality standard or are in violation of a Local, State,
or Federalregulation the Operator will need to cor?ectthe problem immediately or request a variancefrom the GBUAPCDHearingBoard.

GONDITION

2 - Hvdrogen Sulfide Gontent The Hydrogen Sulfide content in the condensate used for cooling tower make-up water may not
causethe cooling tower emissionsto exceed 2.5 lb/hr.

GONDITION

3 - Planfor Testino the Performanceof the Power Plant Everyfour 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 HzStreatment 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 reputablefirm 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 substancesas requiredby the CalifomiaHealth& Safety GodeSection U321. Before performance testing, the Operator or their contractor shall submit a source test ptotocol. The sourcetest protocol shall describe the procedures and methods to be used during source testing. Thesetesting methods shall be approved by the District in advance of their use. The GBUAPCDshall approve, disapprove or modify the plan within 6Odays of receipt, The Operator shall complete the performance testing within 12Odays for the first test or 60 days for the tests after GBUAPGD'sapproval of the plan. A report of the data collected during the performance test shall be submitted to the GBUAPCDwithin 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 GBUAPCDshall 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 equalfyenforceabfe,

GONDITION

5 - Breakdowns Venting from the power plant during breakdown or upset conditions will fotlow guidelinesset in Rule403 of the GBUAPCDBook of Rulesand Regulations. Forthis condition an upset condition shall be defined as any condition ttat requiresventing to maintain tiheintegrity 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 GBUAPCDwithin t hour and advise them of the situation and amount of time requiredto 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, (Rule4O3l

GONDITION

6 - HrS EmissionLimit The Operator shall not discharge into the atmosphere fiom any geothermal power ptant more than 1OO grams/MwHr/Unitof HrS,dudng any continuoushour. Gule 424.81

GONDITION7 - H^S Levels Measured at the Goso Naw EntranceGate lf H2Slevels measuredat the Goso Navy entrance gate are increasing and exceed a one hour averageof 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 KGRAfacilities in excess of 1OO grams/MwHr/Unit. This suspension shall be rescinded

when the HzSlevelsat the gate return to 15 ppbv or less.

GONDITION8 - Dust Abatement Plan Fugitive dust emissionsfrom construction operations, clearedareas, and dirt roads shall be controlled by GBUAPCDapproved methods. Use of waste crankcase oil, or petroleum product is not consideredan approved dust abatement method. The Operator shall submit a written plan to the GBUAPCD, 12Odays prior to construction or clearing of any vegetation, lor approvalby the GBUAPCD. The plan shall describe dust control measuresto bB utilized during the construction operation or clearing process, including roads. Frequencyof application, maintenance, and dust monitoring procedures will be clearly described within the plan. The GBUAPGDshall approve, disapprove, or modify the plan within 6Odays of receipt.

GONDITION9 - Frgitive Dust Goso Operating Company employees and contractors will comply with the posted speed. COCshall conduct safety and compliance training with every employee and contactor that enters the proiect,

GONDITION1O- Safe Access to Sgmple Ports The Operator shall provide safe access to sample ports that enable representatives of theMitsubishi Electric 25 MW Modular Geothermal Power Plant Page 3 of 7

GBUAPCDor GARBto collect samplesfrom 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 H2Streatment 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 availableto 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 samplesfor the District in the presenceof a District representative.

CONDITION11 - PermitSubiectto Goncurrence This permit is subject to concurrence by the Galifomia Afr ResourcesBoard and the Environmental Protection Agency within thirty l3Ol days of receipt.

GoNDlrloN 12 - Permit Does Not Establish Precedentfor Future permh These conditions are for Geothermal Power Plant Unit 1, Permitto Operate Number 234. The Operator agreesthat this permit does not establish a precedent for issuing future permits to the Operator.

GONDITION

13 - lmolementinoReoulations The Operator shall conform with existing Local, State, and Federallaws or statutes and their implementing regulations in the development and operation of the above-specified Geothermal power plant.

GONDITION

14 - RecordKeeoinq 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 availableto the employeesof the District upon request.

GONDITION

15 - NC GasVentino The Operator shall record the pressureand 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-condensablegas to the cooling tower or any other potential emission point. Atl noncondensablegas emissions diverted in excess of 5.5 pounds HrS in any hour, shall be promptly reported to the District, and their records made availableto the District staff upon request. During direct operator diversion or venting of any non-condensablegas 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 Rulesand Regulations. The intentional diverting and venting of non-condensabte gasesto 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 unforeseeableNG gas system failure, the Operator shall comply whh District Rule4O3, Breakdownand Gondhion5.

CONDITION16 - Power PlantOutaoe 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 unscheduledoutage 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 Page4 of 7

than 15 ppbv at the Coso Navy entrance gate. The timeframes for meeting these requirementsare basedon the air quality impacts evaluated in the G&GEreport October 10, 2OOO and may be revised as resource and facility conditions change.

CONDITION17 - Uncontrolled Ventino Shouldthree (31or 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 updatedvented emissionplanfor all previouslyissuedpower plant permits.

GONDITION

18 - CondensateGollection A common closed condensate coflection system shall bEused to dispose of necessary transmission line and power plant fluids through the brineinjectionsystem. NGgas will be disposedthroughthe 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 H2Streatment plant and Hondo (typel HrS abatement system shall be property maintainedto serve as primary, altemate or parallel conttol systems to control HrS emissionsfrom the Navy I, Unit I Power Plant.

CONDITION

21 - EmissionLimits Taking into account all possible HrS emission points, including the Lo-Gat ll H2Streatment 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 Rule424.8.1. HydrogenSulfide (H2Slemissionsfrom the Lo-Catll H2S treatment plant, which treats the non-condensablegas from the combined Navy I, Units 1, i, and 3, shallnot exceedan averageHrS emissionrate of 1.8 poundsper hourfor 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 exceedenceof the emission timit to the District within 96 hoursafter such occurence. (CH&SC g42706l

CONDITION22 - Gontinuous Emission Monitor. Record Keeoinoand 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 H2Streatment plant and Hondo (typel HrS abatement system shall be continuously measuredand 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 describingthe calibration procedures necessary to accutately colfect data and measurethe H.S emission limits.". Mitsubishi Electric 25 MW Modular Geothermal Power Plant Page 6 ol 7

GONDITION23 - GEMsRecordKeepino The Operator shall maintain a records showing when the Lo-Cat ll H2Streatment plants and/or Hondo (typel H.S abatement system were used for H"S control. Emissionsthat may occur during the process of switching to altemate control methods shall be subiect to District Rule424.8 and shall not be considered under Rule4O3 for breakdowns. Recordsshall be maintained for five years.

CONDITION

24 - EmissionUmit At no time shall emissions of any pollutant, for which there is a Federalor State ambient air quality standard, exceed 25O lbs/day during operation of this permitted facility.

CONDITION25 - Monitor and RecordVentino from the Nash Pumo and GomoressorSvstem The Operatorshall monhor and recordany uncontrolledemissionsof non-condensable gasesfrom 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 shallbe equippedwith a recordkeepingdeviceto recordand monitor uncontrolledhourly HzS emissionsor emissionsshall be estimated in a methodapprovedby the APCO.

GONDITION

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

GONDITION27 - 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 Godeof 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, sigmatheta, 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 PSDguidelines,the equipment manufacturer's operating manuals, the EPAOuality AssuranceHandbookfor Air PollutionMeasurementSystems,Vols. l, ll, and lV, andthe Galifomia Air Resources

Board,Air Monitodng OualityAssuranceHandbookVol. I, and ll, includingadditional specifications determined by the District as listed in the permit conditions. The data shall be recordedelectronically 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 CFRPart 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,ualityAssurance/ 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 CFRPart 58, PSDMitsubishi Electric 25 MW Modular Geothermal Power Plant Page6 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 analyzersbased on EPA reference or equivalent method sulfur dioxide analyzers, subject to approval by the District, will be accepted. Only meteorological data collected from sensorsthat comply with 40 GFR,Part 58, PSDGuidelines,and the USEPA'sPSDguidancedocument 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. Onesystem audit, onedata processingaudit, and oneaudit 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 1Oworking 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 3Odays of the audit.

CONDITION32 - HrS Analvzer and Meteoroqical Sensor GalibrationGhecks 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 assuranceperformance audits may not be used in place of any of the aforementioned analyzeror sensor checks. lnstrument checks are not to be conducted during periods of high HrS measurements.

GONDITION

33 - PeriodicAudits and Inspections The Operator shall have personnel availablefor periodic audits conducted by the District or the GalifomiaAir ResourcesBoard. All facilities and monitoring records shall be made availabteto District personnelfor 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, containingthe July data, is to be submittedto 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 Excelformat or an electronic media format as specified by the District. The data reports wil! also includette backupstrip chartsfor the gas analyzerdata, as well as all calibrationand maintenance records, including raw data forms, for the monitoring period.

CONDITION35 - Modem Access to Ambient Air and Meteorological Data The Operator shall provide modem accessto 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 accessibledata shall provide a record of l5-minute averagevalues for H"S. lf H2Slevels 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 PageTof7

GONDITION36 - 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-approvedreference or equivalent method samplers (40CFR, Part 52). The required PM-IO data capture rate ls 75o/o of the third day samples per calendarquarter.

CONDITION37 - Ambient HrS and Meteoroloqical Data Gapture Rates The required data capture tates are 8O7oper month for the continuous HrS analyzer data and 9O% for the meteorological data. Downtime due to normal station checks and calibrations areto be counted against the data capture.

GONDITION

38 - Air Monitor BreakdownReoortino Any breakdownof a continuousemissionmonitor, ambientair monitor, or meteorologicalequipment shallbe reportedwithin one (11hour of detection as requiredunder District Rule4O3.

CONDITION

39 - Riohtof 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.