### United States Environmental Protection Agency September 201 6



### Morongo Casino Cogeneration Facility
**Title V Permit No.**  **MO**

**- ROP 15** 

**- 01** 

**Response to Public Comments on the Proposed Title V**  **Permit Renewal**  **for the Morongo Casino Cogeneration Facility** 2 

### 1. **Introduction**

**– S**  **ummary of the Formal Public Participation Process** 

On July 29 , 201 6 , t he U.S. Environmental Protection Agency (EPA), Region 9 (Region 9) provided notice of, and requested public comment on the Title V Permit Renewal for the Morongo Casino Cogeneration Facility ( MCC ). MCC is owned and operated by the Morongo Band of
Mission Indians (Morongo Reservation)

. The public comment period on th is propos ed action (Proposed R enewal Permit) 1 closed on August 29 , 201 6

.

Region 9 announced the 201 6 public comment period through the public notice published in Banning Record Gazette Newspaper s on July 29 , 201 6

. Region 9 also distributed notices to the necessary parties

, including notices sent by mail and email on July 29 , 201 6 . Parties notified by Region 9 included agencies, organizations, and public members for whom contact information was obtained through a number of different methods, including requests made directly to Region 9 through Region 9’s website (or through other means) from parties seeking not ification regarding permit actions in Region 9, California

, and within the South Coast Air Quality Management District ( SCAQMD or District).

The administrative record for our Proposed Re newal Permit was made available at the EPA Region 9’s office in San Francisco, California and copies of the draft documents were available

at the offices of the Morongo Reservation located in Banning, California

. Region 9 also made the Proposed Re newal Permit and other supporting documents available on Region 9’s website

.



### 2. Background Information

The Morongo Reservation owns and operates MCC

, an 8.4 megawatt cogeneration facility consisting of four 4

- stroke, lean

- burn CAT G3520 natural gas

- fired engines, and three 4

- stroke CAT 3516 backup diesel

- fired generators. The four CAT G3520 natural gas

- fired engines are controlled by Selective Catalytic Reduction (SCR) units and oxidation catalysts with automatic shutdown system before the catalyst inlet temperature exceeds 1350°F. MCC was constructed

in 2004 to provide pow er to the Morongo Casino

. The EPA issued the initial t itle V permit for the facility on August 2, 2005 and renewed it on September 29, 2010. The permit limits the facility’s potential to emit for oxides of nitrog en (NOx ) and volatile organic compounds (VOC ) to less than 18.7 tons per year (tpy) of each pollutant. MCC has made no modifications since the
initial construction.



### 3. **Region 9 ’s Response to Public Comments** 

S ection 3 .1 of this Response to Comments document summarizes the public comments received by t he EPA during the 30

- day public comment period

. This document also provides our
responses to all significant public comments made during the public comment period , including

1 We note that EPA’s permitting regulations at 40 CFR Part 124 refer to proposed permits as “draft permits.” See

40 CFR 124.6.3 an explanation of what changes have been made, if any, in the Final Permit as a result of those

comments. Region 9 only received comments from MCC and SCAQMD during the public comment period.

Individual c omments are addressed

. D ocuments relevant to the permit are available through a link at our website, www.epa.gov/region09/air/permit/r9

- permits

- issued.html#psd , or at www.regulations.gov ( Docket ID # EPA

- R09

- OAR

- 20 1 6

- 0 443 )

.

**3.1 Comments and Responses on**  **the Proposed**  **Title V Permit Renewal for MCC** 

**SCAQMD Comment #1**  For Conditions V.A.2 and 3. There are no averaging times for these concentration levels nor is there any mention of whether these concentration levels are “ as measured ” or if these should be adjusted for moisture, i.e. dry basis.

**EPA Response**  **# 1:**  Condition V.A.2 states that the natural gas

- fired engines’ annual average CO concentration shall not exceed 47 ppmvd at 15 percent O 2 as measured during the annual performanc e test. Upon review of this comment and the underlying applicable requirement, EPA determined that this
condition is actually a work practice and operational requirement instead of an emission limit requiring an averaging time. To be consistent with the un derlying applicable requirement, 40 CFR 63 Subpart ZZZZ Table 6, Item 14.a.i, the EPA changed the term “annual performance test” to “annual compliance demonstration”. Related to and consistent with this change, Condition V.C.6’s “annual compliance performa nce test” was also revised to “annual compliance demonstration” to be consistent with the term used in the permit. Condition V.A.2 did specify it

s hould be adjusted for moisture (ppmvd)

.

Condition V.A.3 states the NO x concentration, as measure d by a portable analyzer shall not exceed 12.0 ppmv at 15 % O 2

. Upon review of this comment and the underlying applicable requirement, t he EPA determined this is also a work practice and operational requirement
instead of an emission limit. The exceedance of 12 pp mvd at 15 percent O 2 does not result in a
violation and is used to monitor the control equipment. Condition V.A.3 is rephrased to be
consistent with Condition V.B.2. The EPA also changed all related 12.0 ppmv to 12 ppmvd to clarify that the concentration l evels should be adjusted for moisture.

Finally , Condition V.A.2 and V.A.3 are moved to Section V.B. Work Practice and Operational Requirements as Condition V.B.2 and V.B.3 , respectively

.

**MCC Comment #2:**  In Attachment A for the calculation of the emissions, the expression for “G” (monthly natural gas engine emissions) the numerator should be tons, rather than the listed pounds (lbs).4 **EPA Response**  **# 2**  **:** EPA agrees. The unit expression for “G” (monthly natural gas engine emission) in Attachment A is changed from lbs to tons.



### 4. **Final Revised Title V**  **Permit No**

**. MO** 

**- ROP 15** 

**- 01** 

A fter careful review of the comments submitted by the SCAQMD, the MCC, and the pertinent Federal statutes and regulations, Region 9 is issuing a decision pursuant to 40 CFR 71.7 to issue
a final P art 7 1 permit renewal to Morongo Reservation for MCC

.