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 would like to offer for your consideration.

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

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

Board (CARB). In our experience, CARB has little use for such correspondence, as they are not responsible for 

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

responsibility has been delegated to the Mojave Desert Air Quality Management District at the State level. 

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 to Section XI, with bolding and strikeouts noting the 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 always, 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@epamail.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 QA/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 utility overestimated emissions. The utility is configured to tell me 

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

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 do a simple correction to account for 9.5 hour startup + a 20% 

compliance margin, I get 4394 lbs CO/event. Perhaps we are accounting for the extra 1.5 hours differently? 

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>, "Balcazar, Ali" <ABalcazar@TENASKA.com>, "Carelli, Frank"

<FCarelli@TENASKA.com>, "Barron, Victor" <VBarron@TENASKA.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 Project (HDPP) has reviewed your proposed limits for a cold start.

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

inner metal temperature is below 325 degrees Fahrenheit. For purposes of documentation, I have attached the 

pertinent page from our California Department of Water Resources contract which stipulates the power dispatch 

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 and 1.9 hours for the secondary units is acceptable to HDPP 

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

as long as it is accompanied by the 138 lbs limit for the two secondary units, which is equal to the limit in the hot 

start. This approach would reduce the fenceline permitted 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 are

more evenly spread throughout the startup event than NOx, where most of the emissions are accounted for early 

in the startup event before the SCR reaches operating 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, resulting in no 

increase in emissions.

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

listed below.

Jon Boyer

Environmental Manager

High Desert Power Project

(760) 530-2303 (office)

(760) 912-3007 (cell)

 

[attachment "SKMBT_C45009090911150.pdf" deleted by Anita Lee/R9/USEPA/US]

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