United States Environmental Protection Agency

September 2016

 

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
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1. Introduction – Summary of the Formal Public Participation Process

On July 29, 2016, the 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 this proposed action

(Proposed Renewal Permit)1 closed on August 29, 2016. 

Region 9 announced the 2016 public comment period through the public notice published in 

Banning Record Gazette Newspapers on July 29, 2016. Region 9 also distributed notices to the 

necessary parties, including notices sent by mail and email on July 29, 2016. 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 notification 

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 Renewal 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 Renewal 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 power to the Morongo Casino. The EPA issued the initial title 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 nitrogen (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

Section 3.1 of this Response to Comments document summarizes the public comments 

received by the 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.
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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 comments are addressed. Documents 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-2016-0443).

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 O2 as measured during the annual performance 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 underlying 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 performance 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 

should be adjusted for moisture (ppmvd). 

Condition V.A.3 states the NOx concentration, as measured by a portable analyzer shall not 

exceed 12.0 ppmv at 15% O2. Upon review of this comment and the underlying applicable 

requirement, the EPA determined this is also a work practice and operational requirement 

instead of an emission limit. The exceedance of 12 ppmvd at 15 percent O2 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 levels 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).
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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

After 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 Part 71 permit renewal to Morongo Reservation for MCC.