### RE: Proposed PSD Permit Limits

Boyer, Jon

to:

Anita Lee

09/25/2009 10:33 AM

Cc:

"Wilton, Benjamin J.", "Carlson, Larry"

Show Details

History: This message has been replied to.

Anita,

Thank you for the update.

I have one more minor administrative edit that I wo uld like to offer for your consideration.

Condition XI, Agency Correspondence, states “all correspondence required by the Authority to Co nstruct should

be forwarded to” EPA, the Mojave Desert Air Quality Management Distr ict, and to the California Air Resources

Board (CARB). In our experience, CARB has little u se for such correspondence, as they are not respons ible for

enforcement of malfunctions or other permit conditi ons of the Prevention of Significant Deterioration Permit. That

responsibility has been delegated to the Mojave Des ert Air Quality Management District at the State le vel.

As such, High Desert Power Project (HDPP) proposes to eliminate CARB from the required correspondence list

under Section XI of the PSD Permit.

Also, the reference to the “Authority to Construct” in Section XI is confusing, and should be revised for clarity of

intent. HDPP suggests that the following changes t o Section XI, with bolding and strikeouts noting th e proposed

changes:

“All correspondence as required by this Prevention of Significant Deterioration Permit Authority to

Construct shall be forwarded to:”

A. Director, Air Division (Attn: AIR-3)

U.S. Environmental Protection Agency

75 Hawthorne Street

San Francisco, CA 94105 

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...B. Chief, Stationary Source Division

California Air Resources Board

P.O. Box 2815

Sacramento

, CA 95812

B. Air Pollution Control Officer

Mojave Desert Air Quality Management District

15428 Civic Drive, Suite 200

Victorville, CA 92392-2383

If you require a formal letter be written to review these edits, please respond to this email. As alw ays, please

contact me if you have any questions as well.

Jon Boyer

Environmental Manager

High Desert Power Project

(760) 530-2303 (office)

(760) 912-3007 (cell)

From: Lee.Anita@epamail.epa.gov [mailto:Lee.Anita@epamai l.epa.gov]

Sent: Monday, September 21, 2009 11:37 AM

To: Boyer, Jon

Subject: RE: Proposed PSD Permit Limits

Yes, the 3083 is based on the hourly data you sent me. Glad to hear 4394 should work.

thanks,

anita

* * * * * * * * * * * * * * * * * * * *

Anita Lee, PhD

ph: (415) 972-3958

fax: (415) 947-3579

US EPA, Region 9

Air Permits Office

75 Hawthorne Street (AIR-3)

San Francisco, CA 94105

* * * * * * * * * * * * * * * * * * * *

Are you getting the 3083 from the hourly data? If so, yes, that works out about right.

The hourly CO readings are configured for Part 60 Q A/QC and calculating protocols, so that will be the most From: "Boyer, Jon" <JBoyer@TENASKA.com>

To: Anita Lee/R9/USEPA/US@EPA

Date: 09/18/2009 03:24 PM

Subject: RE: Proposed PSD Permit Limits 

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...accurate.

I need to figure out why my startup/shutdown utilit y overestimated emissions. The utility is configur ed to tell me

when the startup event is over based on emissions, and thus calculates the duration accordingly. It t hen

calculates emissions based on those readings.

Based on the hourly data, go ahead and propose 4394 . I think its doable.

Jon Boyer

Environmental Manager

High Desert Power Project

(760) 530-2303 (office)

(760) 912-3007 (cell)

From: Lee.Anita@epamail.epa.gov [ mailto:Lee.Anita@epamail.epa.gov ]

Sent: Friday, September 18, 2009 2:53 PM

To: Boyer, Jon

Subject: Re: Proposed PSD Permit Limits

hi Jon,

When I look at the data from May 28, it seems 4394 lbs CO is more appropriate for the warming turbine. Over the

8 hour startup, CO emissions were 3083 lbs. If I d o a simple correction to account for 9.5 hour start up + a 20%

compliance margin, I get 4394 lbs CO/event. Perhap s we are accounting for the extra 1.5 hours differe ntly?

Does that sound workable?

thanks!

anita

* * * * * * * * * * * * * * * * * * * *

Anita Lee, PhD

ph: (415) 972-3958

fax: (415) 947-3579

US EPA, Region 9

Air Permits Office

75 Hawthorne Street (AIR-3)

San Francisco, CA 94105

* * * * * * * * * * * * * * * * * * * *

From: "Boyer, Jon" <JBoyer@TENASKA.com>

To: Anita Lee/R9/USEPA/US@EPA

Cc: "Wilton, Benjamin J." <BWilton@TENASKA.com>, "Balca zar, Ali" <ABalcazar@TENASKA.com>, "Carelli, Frank"

<FCarelli@TENASKA.com>, "Barron, Victor" <VBarron@T ENASKA.com>, "Carlson, Larry" <LCarlson@TENASKA.com >

Date: 09/09/2009 02:51 PM

Subject: Proposed PSD Permit Limits 

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...Anita,

Per our conversation today, High Desert Power Proje ct (HDPP) has reviewed your proposed limits for a c old start.

We believe that the following limits are achievabl e to warm the Steam Turbine Generator (STG) when th e STG

inner metal temperature is below 325 degrees Fahren heit. For purposes of documentation, I have attache d the

pertinent page from our California Department of Wa ter Resources contract which stipulates the power d ispatch

profile for a cold start of HDPP when the STG inner metal inner metal temperature is below 325 degrees

Fahrenheit.

Duration limits of 9.5 hours for one warming unit a nd 1.9 hours for the secondary units is acceptable to HDPP

during a STG cold start, as defined above. The pro posed NOx limits of 238 lbs for the warming unit is acceptable,

as long as it is accompanied by the 138 lbs limit f or the two secondary units, which is equal to the l imit in the hot

start. This approach would reduce the fenceline pe rmitted limits of a cold start by 38 lbs of NOx.

For CO emissions, HDPP proposes a limit of 5841 lbs for the warming unit. This number was taken from the

worst case demonstrated on May 28, and expanded to 9.5 hours with a 10 percent buffer. CO emissions a re

more evenly spread throughout the startup event tha n NOx, where most of the emissions are accounted fo r early

in the startup event before the SCR reaches operati ng temperatures. However, emissions from the two

secondary units can be decreased accordingly. HDPP proposes a CO limit of 2391 for the two secondary units.

This approach would keep the fenceline limits for CO at the currently permitted limit of 10,623, resu lting in no

increase in emissions.

Let me know if this approach is acceptable to you. If you have any questions, please contact me at th e numbers

listed below.

Jon Boyer

Environmental Manager

High Desert Power Project

(760) 530-2303 (office)

(760) 912-3007 (cell)



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