AUTHORITY TO CONSTRUCT / MODIFY 

PREVENTION OF SIGNIFICANT DETERIORATION PERMIT 

ISSUED PURSUANT TO THE REQUIREMENTS AT 40 CFR § 52.21

U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION IX 

PSD PERMIT NUMBER: SE 98-01 

PERMITTEE: High Desert Power Project, LLC 

FACILITY LOCATION: 19000 Perimeter Road, Victorville, CA 92394 

This Permit is issued pursuant to the Prevention of Significant Deterioration (PSD) requirements 

of the Clean Air Act, as amended, 42 U.S.C. §§ 7401 - 7671, et. seq.), and the Code of Federal 

Regulations (CFR) Title 40, Section 52.21. The United States Environmental Protection Agency 

Region IX (EPA) is issuing an approval to construct/modify operation to the High Desert Power 

Project (HDPP), an existing 720 megawatt power generating facility located in the city of 

Victorville, California, as described herein, in accordance with the permit application (and plans 

submitted with the permit application), the federal PSD regulations at 40 CFR § 52.21, and other 

terms and conditions set forth in this PSD Permit. 

Failure to comply with any condition or term set forth in this PSD Permit is subject to 

enforcement action pursuant to Section 113 of the Clean Air Act. This Permit does not relieve 

the Permittee from the obligation to comply with any other applicable provisions of the Clean 

Air Act (including 40 CFR Parts 51, 52, 60, 61, 63, and 72 through 75), federal, state, or Mojave 

Desert Air Quality Management District rules and regulations. 

This PSD Permit becomes effective on the date of issuance pursuant to 40 CFR §124.15(b)(3).

 

Deborah Jordan Date 

Director, Air Division 
HIGH DESERT POWER PROJECT 

PREVENTION OF SIGNIFICANT DETERIORATION PERMIT SE 98-01 

PROPOSED REVISIONS TO PERMIT CONDITIONS 

PROJECT DESCRIPTION 

The High Desert Power Project (HDPP) has a power generating capacity of 720 megawatts and 

consists of three existing natural gas-fired combined cycle combustion turbines (CT) each with 

dedicated heat recovery steam generators (HRSG), associated air pollution control devices, and 

auxiliary equipment. EPA Region IX issued an initial PSD permit for the construction and 

operation of HDPP on February 15, 2001. The facility began commercial operations in April 

2003 and is located at 19000 Perimeter Road, Victorville, California. 

For this permit revision, HDPP has requested revisions to the initial PSD permit to incorporate 

minor changes. The proposed changes include adding an alternative startup scenario, revising the 

continuous monitoring systems permit language such that it is consistent with the Acid Rain 

regulations (40 CFR Part 75), and allowing additional use of EPA Test Methods. Other minor 

changes are administrative in nature such as deleting obsolete language and clarifications. The 

new alternative startup scenario will give HDPP more flexibility for startup while also reducing 

the existing permitted startup emission limits for carbon monoxide and nitrogen oxide. The 

equipment affected by these revisions is listed below. 

EQUIPMENT DESCRIPTION 

Unit ID Equipment Description 

CT1 Siemens Westinghouse 501F natural gas turbine (190 MW) equipped with a HRSG 

and duct burner (160 MMBtu/hr); dry low NOx burners; CO oxidation catalyst; and 

a Selective Catalytic Reduction system. Steam turbine generator shared with units 

CT2 and CT3. 

CT2 Siemens Westinghouse 501F natural gas turbine (190 MW) equipped with a HRSG 

and duct burner (160 MMBtu/hr); dry low NOx burners; CO oxidation catalyst; and 

a Selective Catalytic Reduction system. Steam turbine generator shared with units 

CT1 and CT3. 

CT3 Siemens Westinghouse 501F natural gas turbine (190 MW) equipped with a HRSG 

and duct burner (160 MMBtu/hr); dry low NOx burners; CO oxidation catalyst; and 

a Selective Catalytic Reduction system. Steam turbine generator shared with units 

CT1 and CT2. 

STG Toshiba TCDF steam turbine generator (330 MW) 
PERMIT CONDITIONS 

I. Permit Expiration 

This Authority to Construct shall become invalid (1) if construction is not commenced 

(as defined in 40 CFR 52.21(b)(8)) within 18 months after the approval takes effect, (2) if 

construction is discontinued for a period of 18 months or more, or (3) if construction is 

not completed within a reasonable time. 

II. Notification of Commencement of Construction and Startup 

The Regional Administrator shall be notified in writing of the anticipated date of 

initial startup (as defined in 40 CFR 60.2(o)) of each facility of the source not more 

than sixty (60) days nor less than thirty (30) days prior to such date and shall be 

notified in writing of the actual data of commencement of construction and startup 

within fifteen (15) days of such date. 

III. Facilities Operation 

All equipment, facilities, and systems installed or used to achieve compliance with 

the terms and conditions of this Authority to Construct shall at all times be 

maintained in good working order and be operated as efficiently as possible so as to 

minimize air pollutant emissions. 

IV. Malfunction Reporting 

A. Reporting 

The EPA Regional Administrator shall be notified by telephone, facsimile, or 

electronic mail transmission within two (2) working days following the discovery

any failure of air pollution control equipment, process equipment, or of a process 

to operate in a normal manner, which results in an increase in emissions above 

any allowable emission limit stated in Condition X-E of this Authority to 

Construct. In addition, the Regional Administrator shall be notified in writing 

within fifteen (15) days of any such failure. The notification shall include a 

description of the malfunctioning equipment or abnormal operation, the date of 

the initial malfunction, the period of time over which emissions were increased 

due to the failure, the cause of the failure, the estimated resultant emissions in 

excess of those allowed under Condition X-E of these conditions, and the 

methods utilized to mitigate emissions and restore normal operations. Compliance 

with this malfunction notification provision shall not excuse or otherwise 

constitute a defense to any violation of this permit or of any law or regulation that 

such malfunction may cause, except as provided for in Condition IV-B of this 

permit. 

High Desert Power Project Proposed PSD Permit (SE 98-01) 2 

February 2010 
B. Treatment of Emissions 

1. Definition of malfunction: A malfunction means a sudden and unavoidable 

breakdown of equipment or of a process beyond the reasonable control of the 

source. 

2. Emissions in excess of the limits in Condition X-E of this permit shall 

constitute a violation and may be the subject of enforcement proceedings. 

3. Affirmative defense: In the context of an enforcement proceeding, emissions 

which are below the limits set forth in Condition IV(B)(3)(ii) shall not be 

subject to penalty if the Permittee retains properly signed, contemporaneous 

operating logs or other relevant evidence and can demonstrate all of the 

following: 

i. A malfunction caused the emissions in excess of the limits in Condition XE; 

ii. The emissions did not exceed the following levels: 

16 ppm NOx (1-hour average, corrected to 15% O2) 

6 ppm CO (24-hour average, corrected to 15% O2); 

iii. The permitted facility, including the air pollution control equipment and 

process equipment, was being properly operated at the time of the 

malfunction; 

iv. Preventative maintenance was regularly performed in a manner consistent 

with good practice for minimizing emissions; 

v. The excess emissions were not part of a recurring pattern indicative of 

inadequate design, operation, or maintenance; 

vi. During the period of the malfunction the Permittee took all reasonable 

steps to minimize the amount and duration of emissions (including any 

bypass) that exceeded the emission standards in Condition X-E. 

Reasonable steps to minimize emissions could include, but are not limited 

to, reducing production to the lowest level practical; reducing the material 

feed that results in the increased emissions, and switching to alternative, 

less polluting fuels. Where repairs were required, repairs were made in an 

expeditious fashion when the operator knew or should have known that 

applicable emission limitations were being exceeded. Off-shift labor and 

overtime must have been utilized, to the extent practicable, to ensure that 

such repairs were made as expeditiously as possible; and 

High Desert Power Project Proposed PSD Permit (SE 98-01) 3 

February 2010 
vii. The Permittee complied with the malfunction reporting requirements of 

Condition IV-A of this permit. 

4. All emissions, including those associated with a malfunction which may be 

eligible for an affirmative defense, must be included in all emissions 

calculations and demonstrations of compliance with mass emission limits in 

Condition X-E (e.g., daily, monthly, and annual emission limits). 

5. This provision is in addition to any emergency or malfunction provision 

contained in any applicable requirement or elsewhere in this permit. 

V. Right to Entry 

The Regional Administrator, the head of the State Air Pollution Control Agency, the head 

of the responsible local Air Pollution Control Agency, and/or their authorized 

representative, upon the presentation of credentials, shall be permitted: 

A. to enter the premises where the source is located or where any records are 

required to be kept under the terms and conditions of this Authority to Construct; 

and 

B. at reasonable times to have access to and to copy any records required to be kept 

under the terms and conditions of this Authority to Construct; and 

C. to inspect any equipment, operation, or method required in this Authority to 

Construct; and 

D. to sample emissions from the source. 

VI. Transfer of Ownership 

In the event of any changes in control or ownership of the facilities to be constructed or 

modified, this Authority to Construct shall be binding on all subsequent owners and 

operators. The applicant shall notify the succeeding owner and operator of the existence 

of this Authority to Construct and its conditions by letter, a copy of which shall be 

forwarded to the Regional Administrator and the State and local Air Pollution Control 

Agency. 

VII. Severability 

The provisions of this Authority to Construct are severable, and, if any provision of the 

Authority to Construct is held invalid, the remainder of this Authority to Construct 

shall not be affected. 

High Desert Power Project Proposed PSD Permit (SE 98-01) 4 

February 2010 
VIII. Other Applicable Regulations 

The owner and operator of the proposed project shall construct and operate the 

proposed stationary source in compliance with all other applicable provisions of 40 

CFR Parts 52, 60 and 61 and all other applicable federal, state and local air quality 

regulations. 

IX. Paperwork Reduction Act 

Any requirements established by this permit for the gathering and reporting of 

information are not subject to review by the Office of Management and Budget (“OMB”) 

under the Paperwork Reduction Act because this permit is not an “information collection 

request” within the meaning of 44 U.S.C. §§ 3502(4) & (11), 3507, 3512, and 3518. 

Furthermore, this permit and any information gathering and reporting requirements 

established by this permit are exempt from OMB review under the Paperwork Reduction 

Act because it is directed to fewer than ten persons. 44 U.S.C. § 3502(4), (11); 5 C.F.R. § 

1320.5(a). 

X. Special Conditions 

A. Certification 

HDPP shall notify the EPA in writing of compliance with Special Conditions XB and X-D and shall make such notification within (15) days of such compliance. 

This letter must be signed by the Responsible Official of HDPP. 

B. Air Pollution Control Equipment 

On or before the date of startup of the facility, and thereafter (as defined in 40 

CFR 60.2), HDPP shall install, continuously operate and maintain the following 

air pollution controls to minimize emissions at or below the levels specified in 

Condition X-E of this Authority to Contruct. The aforementioned “continuous” 

periods of operation do not include periods of startup and shutdown, as defined in 

Condition X-E-3, or periods of malfunction as defined in Condition IV-B-1 of this 

Authority to Construct. 

1. A Selective Catalytic Reduction (SCR) system on each turbine train unit for 

control of NOx. 

2. An oxidation catalyst on each turbine unit for control of CO. 

C. Operating Limitations 

High Desert Power Project Proposed PSD Permit (SE 98-01) 5 

February 2010 
1. HDPP shall restrict fuel use for the operation of the combustion turbines and 

supplemental duct firing to Public Utility Commission-quality natural gas 

with a sulfur content of 0.2 grains/100 dscf or less on a twelve month rolling 

average basis. 

2. The duct burners shall not be operated unless the associated turbine units are 

in operation. 

D. Continuous Emission Monitoring 

1. Prior to the date of startup and thereafter, HDPP shall install, maintain and 

operate the following continuous emission monitoring systems (CEMS) on 

each of the combustion turbine train exhaust stack: 

a. A continuous monitoring system to measure stack gas NOx concentrations. 

The system shall meet EPA monitoring performance specification (40 

CFR 60.13 and 40 CFR 60, Appendix B). 

b. A continuous monitoring system to measure stack gas CO concentrations. 

The system shall meet EPA monitoring performance specifications (40 

CFR 60.13 and 40 CFR 60, Appendix B). 

c. A continuous monitoring system to measure stack gas volumetric flow 

rates. The stack gas volumetric flow rates shall be calculated in 

accordance with the fuel flowmeter requirements of 40 CFR Part 75 

Appendix D in combination with the appropriate parts of EPA Method 19.

The system shall meet EPA performance specifications (40 CFR Part 52, 

Appendix E). 

2. HDPP shall notify EPA (Attn: AIR-5) of the date on which demonstration for 

the continuous monitoring system performance commences (40 CFR 60.13). 

This date shall be no later than 60 days after startup. 

3. Not less than 90 days prior to the date of startup of the facility, HDPP shall 

have a quality assurance (QA) project plan developed for the certification and 

operation of the CEMS. Such a plan shall conform to the EPA document 

“Guidelines for developing a Quality Assurance Project Plan” (QAMS 

005/80). The QA project plan must be maintained on-site and be available to 

EPA upon request. 

E. Emission Limits 

1. The NOx emissions (calculated as NO2) from each turbine train unit shall not 

exceed 18.0 lb/hr for the 3F configuration or 24.55 lb/hr for the 2G 

High Desert Power Project Proposed PSD Permit (SE 98-01) 6 

February 2010 
configuration (based on 2.5 ppmvd @ 15% O2, averaged over a one hour 

period). 

2. The CO emissions from each turbine train unit shall not exceed 17.53 lb/hr for 

the 3F configuration or 23.91 lb/hr for the 2G configuration (based on 4.0 

ppmvd @ 15% O2, averaged over a 24 hour period). 

3. The emission limits in Conditions X-E-l and X-E-2 shall apply at all times to 

each turbine train unit, except during startups and shutdowns defined as 

follows: 

a. Startup shall be defined as the period beginning with ignition and lasting 

until the equipment has reached a continuous operating level and operating 

permit limits. 

i. Cold startup means a startup when the combustion turbine has not 

been in operation during the preceding 72 hours or the steam turbine 

inner metal temperature ≤ 325 oF. 

ii. Hot startup means a startup when the combustion turbine has been in 

operation during the preceding 8 hours. 

iii. Warm startup means a startup that is not a hot or cold startup. 

iv. Shutdown shall be defined as the period beginning with the lowering 

of equipment from normal operating load base load and lasting until 

fuel flow is completely off and combustion has ceased. 

 

b. Transient conditions shall not exceed the following durations: 

i. Cold startup: 4.5 hours 

ii. Warm startup: 2.6 hours 

iii. Hot startup: 1.9 hours 

iv. Shutdown: 1 hour 

 

c. Emissions during startup and shutdown, verified by CEMS, shall not 

exceed the following: 

3 F Configuration 

Pollutant Cold Startup (lb) Warm Startup (lb) Hot Startup (lb) Shutdown (lb) 

NOx 183 168 138 97 

CO 3541 3596 3729 239 

2G Configuration

Pollutant Cold Startup (lb) Warm Startup (lb) Hot Startup (lb) Shutdown (lb) 

High Desert Power Project Proposed PSD Permit (SE 98-01) 7 

February 2010 
NOx 561 269 215 133 

CO 6890 3177 2711 288 

d. Alternative Cold Startup Scenario 

The Permittee may use the following alternative startup scenario for cold 

starts: one combustion turbine (“warming turbine”) is used to warm the 

components of the steam turbine generator and to bring the SCR online. 

The remaining two combustion turbines are then brought online quickly. 

Emissions during the alternative cold startup scenario shall not exceed the 

following: 

Unit NOx (lb/event) CO (lb/event) Startup Duration 

“Warming turbine” 235 4394 9.5 hours 

Combustion Turbine 2 138 2391 1.9 hours 

Combustion Turbine 3 138 2391 1.9 hours 

 

F.G. Performance Test 

1. Pursuant to 40 CFR 60.8, within 60 days of achieving the maximum 

production rate of the proposed equipment but not later than 180 days after 

initial startup of the equipment as defined in 40 CFR 60.2, and at such other 

times as specified by the EPA, HDPP shall conduct performance tests for NOx

and CO and furnish the EPA (Attn: AIR-5) with a written report of the results 

of such tests. The tests for NOx and CO shall be conducted once every five 

years, prior to the submission of the renewal application for each five year 

Title V permit term, on an annual basis and at the maximum operating 

capacity of the facilities being tested. In the event of a failed annual CEMS 

performance specification test (Condition X-D-1), HDPP shall conduct a 

performance test concurrent with the re-testing of the annual CEMS 

performance specification. Upon written request (Attn: AIR-5) from HDPP, 

EPA may approve the conducting of performance test atas a lower specified 

production rate. After initial performance tests and upon written request and 

adequate justification from HDPP, EPA may waive a specified annual test for 

the facility. 

2. Performance tests for the emissions of NOx and CO shall be conducted and 

the results reported in accordance with the test methods set forth in 40 CFR 

60, Part 60.8 and Appendix A. The following test methods shall be used: 

a. Performance tests for the emissions of NOx shall be conducted using EPA 

Methods 1-4 and 7E. EPA Methods 19, and 20 may be used in addition to, 

but not as a substitution for, EPA Method 7E.

High Desert Power Project Proposed PSD Permit (SE 98-01) 8 

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b. Performance tests for the emissions of CO shall be conducted using EPA 

Methods 1-4 and 10. EPA Methods 19, and 20 maybe be used in addition 

to, but not as a substitution for, EPA Method 10.

3. The EPA (Attn: AIR-5) shall be notified in writing at least 30 days prior to 

such test to allow time for the development of an approvable performance test 

plan and to arrange for an observer to be present at the test. Such prior 

approval shall minimize the possibility of EPA rejection of test results for 

procedural deficiencies. In lieu of the above-mentioned test methods, 

equivalent methods may be used with prior written approval from the EPA. 

4. For performance test purposes, sampling ports, platforms and access shall be 

provided by HDPP on the exhaust stack in accordance with 40 CFR 60.8(e). 

G.H. Recordkeeping and Reporting 

1. HDPP shall maintain records of all measurements, including continuous 

monitoring systems evaluations; all continuous monitoring systems or 

monitoring device calibration checks; adjustments and maintenance 

performed on these systems or devices; performance and all other information 

required by 40 CFR 60 or 40 CFR 75 recorded in a permanent form suitable 

for inspection. The file shall be retained for at least five (5) years following 

the date of such measurements, maintenance, reports and records. 

2. HDPP shall submit a written report of all excess emissions to EPA (Attn: 

AIR-5) for every calendar quarter. The report shall include the following: 

a. The magnitude of the excess emissions computed in accordance with 40 

CFR 60.13(h), any conversion factors used, and the date and time of 

commencement and compilation of each time period of excess emissions. 

b. Specific identification of each period of excess emissions that occurs 

during startups, shutdowns, and malfunctions of the engine exhaust 

systems. The nature and cause of any malfunction (if known) and the 

corrective action taken or preventative measures adopted shall also be 

reported. 

c. The date and time identifying each period during which the CEMS was 

inoperative except for zero and span checks, and the nature of the system 

repairs or adjustments. 

d. When no excess emissions have occurred or the CEMS has not been 

inoperative, repaired, or adjusted, such information shall be stated in the 

report. 
e. Excess emissions shall be defined as any one-hour period during which 

the average emissions of NOx as measured by the CEMS exceeds the 

maximum emission limits set forth in Condition X-E. 

Excess emissions shall be defined as any 24-hour period during which the 

average emissions of CO, as measured by the CEMS exceeds the 

maximum emission limits set forth in Condition X-E. 

3. Excess emissions indicted by the CEMS system shall be considered violations 

of the applicable emission limit for the purpose of this permit. 

4. The quality assurance project plan used by HDPP for the certification and 

operation of the continuous emissions monitors, which meets the requirements 

of 40 CFR Part 60, Appendix F, shall be available upon request to EPA. 

H.I. New Source Performance Standards 

The facility’s combustion turbines are subject to the New Source Performance 

Standards (NSPS), 40 CFR 60, Subpart GG, as well as the general provisions of 

Subpart A. The owner/operator shall meet all applicable requirements of the 

aforementioned NSPS Subparts. 

XI. Agency Notifications 

A. Unless otherwise directed by EPA or this permit, the Permittee shall submit a 

copy of all test plans, reports, certifications, notifications, and other information 

pertaining to compliance with this permit to: 

 Director, Air Division (Attn: AIR-5) 

U.S. Environmental Protection Agency, Region 9 

75 Hawthorne Street 

San Francisco, CA 94105 

 E-mail: R9.AEO@epa.gov 

 Fax: (415) 947-3579 

B. The Permittee shall submit permit applications, permit amendments, and other 

applicable permit information, which includes but not limited to installation of 

control equipment, replacement of an emissions unit, and changes that contravene 

permit terms to: 

 Director, Air Division (Attn: AIR-3) 

U.S. Environmental Protection Agency, Region 9 

75 Hawthorne Street 

San Francisco, CA 94105 

High Desert Power Project Proposed PSD Permit (SE 98-01) 10 

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High Desert Power Project Proposed PSD Permit (SE 98-01) 11 

February 2010 

 E-mail: R9AirPermits@epa.gov 

 Fax: (415) 947-3579 

C. Copies of all correspondence required by this PSD Permit shall be forwarded to: 

 Air Pollution Control Officer 

Mojave Desert Air Quality Management District 

14306 Park Avenue 

Victorville, CA 92392 

 All correspondence as required by this 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

B. Chief, Stationary Source Division

California Air Resources Board

P.O. Box 2815

Sacramento, CA 95812