U.S. ENVIRONMENTAL PROTECTION AGENCY 

REGION IX 

STATEMENT OF BASIS AND 

AMBIENT AIR QUALITY IMPACT REPORT 

For a Clean Air Act 

Prevention of Significant Deterioration Permit 

High Desert Power Project 

PSD Permit Number SE 98-01 

February 2010 
Statement of Basis and Ambient Air Quality Impact Report 

High Desert Power Project PSD Permit Modification 

(NSR 4-4-4, SE 98-01) 

Table of Contents 

Acronyms & Abbreviations............................................................................................................ 3

I. Applicant............................................................................................................................. 4

II. Project Location.................................................................................................................. 4

III. Facility Description............................................................................................................. 4

IV. PSD Permitting History ...................................................................................................... 5

V. Applicability of the Prevention of Significant Deterioration Regulations.......................... 5

VI. Current Requested Modifications....................................................................................... 6

VII. EPA Evaluation of Requested Modifications to PSD Permit ............................................. 7

VIII. Additional PSD Requirements.......................................................................................... 13

IX. Proposed Action and Conclusion...................................................................................... 13

Appendix 1 

Appendix 2

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Acronyms & Abbreviations 

AAQIR Ambient Air Quality Impact Report 

ATC Approval to Construct 

BACT Best Available Control Technology 

CAA Clean Air Act 

CEMS Continuous Emissions Monitoring System 

CFR Code of Federal Regulations 

CO carbon monoxide 

CT Combustion Turbine 

CTG Combustion Turbine Generator 

EPA United States Environmental Protection Agency 

oF degrees Fahrenheit 

HDPP High Desert Power Project 

HRSG Heat Recovery Steam Generator 

km kilometer 

lb/day pound per day 

lb/event pound per event 

lb/hr pound per hour 

lb/MMBtu pound per Million British Thermal Units 

MDAQMD Mojave Desert Air Quality Management District 

MMBtu/hr Million British Thermal Units per hour 

μg/m3 micrograms per cubic meter 

MW megawatt 

NAAQS National Ambient Air Quality Standard 

NESHAP National Emission Standards for Hazardous Air Pollutants 

NO2 Nitrogen dioxide 

NOx Nitrogen oxide 

NSPS Standard of Performance for New Stationary Sources 

O2 Oxygen 

O3 Ozone 

PM Particulate matter 

PM2.5 Particulate matter with aerodynamic diameter less than 2.5 micrometers 

PM10 Particulate matter with aerodynamic diameter less than 10 micrometers 

ppm parts per million 

ppmv parts per million by volume 

PSD Prevention of Significant Deterioration 

PTE Potential to Emit 

RATA Relative Accuracy Test Audits 

SCR Selective Catalytic Reduction 

scf/MMBtu standard cubic feet per Million British Thermal Units 

SO2 Sulfur dioxide 

S/S Startup/Shutdown 

STG Steam Turbine Generator 

tpy tons per year 

VOC Volatile Organic Compound 

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This document serves as the Statement of Basis and Ambient Air Quality Impact Report for the 

proposed modified PSD permit for the High Desert Power Project. This document sets forth the 

legal and factual basis for permit conditions, including requirements under the PSD regulations 

at 40 CFR 52.21. This document is also serves as the fact sheet to meet the requirements of 40 

CFR Part 124.7 and 124.8. 

I. Applicant 

 High Desert Power Project, LLC 

 19000 Perimeter Road 

 Victorville, CA 92394 

II. Project Location 

The High Desert Power Project (HDPP) is located at 19000 Perimeter Road in the city of 

Victorville, San Bernardino County, California, under the jurisdiction of the Mojave 

Desert Air Quality Management District (MDAQMD, or District). The facility is located 

in an industrial park that is part of the Southern California International Airport, formerly 

George Air Force Base. 

HDPP is located in a portion of the Mojave Desert designated nonattainment with the 

National Ambient Air Quality Standards (NAAQS) for ozone (O3) and particulate matter 

with aerodynamic diameter less than 10 micrometers (PM10); and designated attainment 

with the NAAQS for nitrogen dioxide (NO2), sulfur dioxide (SO2), carbon monoxide 

(CO), and particulate matter with aerodynamic diameter less than 2.5 micrometers 

(PM2.5). The U.S. EPA is the PSD permitting authority for attainment pollutants in San 

Bernardino County where HDPP is located, with exception of the southwestern portion of 

the county. 

III. Facility Description 

High Desert Power Project is a 720 megawatt (MW) natural gas-fired combined cycle 

power generating facility which began commercial operations in April 2003. HDPP 

operates three Siemens Westinghouse natural gas-fired combined cycle combustion 

turbines (CT), each with a dedicated heat recovery steam generator (HRSG). Each 

CT+HRSG unit feeds into one steam turbine generator (STG). Air pollution control 

equipment includes dry low NOx combustors, Selective Catalytic Reduction systems, and 

CO oxidation catalysts. Other equipment includes a cooling tower, emergency diesel 

engine, and a fire water pump engine. 

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IV. PSD Permitting History 

On February 15, 2001, EPA Region IX issued an initial PSD permit and Approval to 

Construct (ATC) to the High Desert Power Project. HDPP was subject to PSD 

requirements for NOx and CO because the facility’s potential to emit (PTE) of NOx and 

CO exceeded the 100 tons per year (tpy) major source threshold. The Ambient Air 

Quality Impact Report (AAQIR) for the PSD permit identified the NOx and CO control 

requirements that were determined to comprise BACT. A NOx emission limit of 2.5 ppmv

(at 15% O2, one hour average), using a combination of dry low NOx combustors and 

selective catalytic reduction (SCR) with a 10 ppmv ammonia slip at 15% O2; and a CO 

emission limit of 4.0 ppm (24 hour average at 15% O2) using good combustion practices 

and an oxidation catalyst were determined to satisfy the BACT requirements for NOx and 

CO. 

HDPP informed EPA, on July 13, 2001, of minor changes to the design of the power 

plant compared to the information presented in its PSD permit application. These changes 

included a modification in the turbine configuration from 3x3x3 (i.e., three combustion 

turbines (CT), three heat recovery steam generators (HRSG), and three steam turbine 

generators (STG)) to a 3x3x1 configuration, reconfiguration of the cooling tower from 

three towers to one, addition of a diesel firewater pump engine, modification of the stack 

location, elevation, and diameter, and modification in the physical dimensions of the 

cooling tower, steam turbine, and HRSG structure. 

In letter dated July 30, 2001, EPA determined that changes specified by HDPP would not 

result in any emissions increases, nor qualify as a major modification under PSD. 

Therefore, the terms and conditions included in the PSD permit issued February 15, 2001, 

and the modeling analyses on which the original determinations were based, remained 

valid and in effect. 

V. Applicability of the Prevention of Significant Deterioration Regulations 

The PSD regulations (40 CFR 52.21) define a “major stationary source” as any stationary 

source belonging to a list of 28 source categories which emits or has the “potential to 

emit” 100 tons per year (tpy) or more of any attainment or unclassified pollutant 

regulated under the Clean Air Act, or any other source type which emits or has the 

potential to emit such pollutants in amounts equal or greater than 250 tpy. HDPP belongs 

to one of the 28 listed source categories (i.e., fossil fuel-fired electric plants with heat 

inputs of more than 250 MMBtu/hr), therefore the 100 tpy major source threshold applies 

to this facility. 

Additionally, under the PSD regulations, modifications at existing major sources are 

deemed “major” if the modification results in a significant net emissions increase greater 

than the threshold prescribed for any pollutant subject to PSD. See 40 CFR 

52.21(a)(2)(iv)(a). The significance thresholds prescribed by the PSD regulations, 40 

CFR 52.21(b)(23)(i), for the subject pollutants are the same PSD significance thresholds 

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listed in Table 1. 40 CFR 52.21(b)(23)(iii) further defines “significant” as any emission 

rate, associated with a major stationary source located within 10 km of a Class I area, that 

has an impact on that Class I area that is equal to or exceeds 1 μg/m3

. 

Table 1: PSD Significance Thresholds 

Pollutant CO NO2 VOC SO2 PM10 PM2.5 Pb 

Threshold (tpy) 100 40 40 40 15 10 0.6 

A PSD review would apply to all pollutants from a major stationary source showing 

significant net increases in emissions for which the applicable federal NAAQS have not 

been exceeded (attainment areas), or areas where the status of the area is uncertain 

(unclassified). The PSD requirements include: 

1. Application of Best Available Control Technology (BACT); 

2. Analysis of ambient air quality impacts from the project; 

3. Analysis of air quality and visibility impacts on Class I areas; and 

4. Analysis of impacts on soils and vegetation. 

In evaluating applications to revise PSD permits, EPA considers whether the change 

triggers new requirements and whether the requested changes to the permit ensure that 

the PSD requirements continue to be met. EPA must also ensure that the revisions do not 

interfere with the source’s obligation or ability to protect ambient air quality and 

increments, or to comply with the requirements of BACT and the Endangered Species 

Act. 

HDPP has requested revisions (listed in Section VI below) to the PSD permit to 

incorporate minor changes. Some of 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 (see Section VII). As discussed 

in Section VII, EPA determined that the requested changes to the permit will not result in 

a major PSD modification, and therefore will be processed as a minor modification. 

VI. Current Requested Modifications 

In a letter dated April 6, 2004, HDPP requested several modifications to their PSD 

permit: 

1. For condition X.E.3.c, combine startup/shutdown (S/S) limits for NOx and 

CO (lb/event) from a “per combustion turbine (CT)” basis to a limit that 

applies to the “power block”, i.e., all three CTs + steam turbine generator 

(STG), by multiplying the per CT limit by three. 

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Draft AAQIR/February 2010 
2. For condition X.E.3.a, replace “equipment” with “facility”. 

3. Remove S/S duration limits in Condition X.E.3.b, and replace with a daily 

emission limit for CO of 8072 lb/day from each CT, consistent with the 

District Title V Operating Permit. 

4. Remove requirement (Condition X.D.1.c) to use a continuous monitoring 

system to measure stack gas volumetric flow and replace with requirement 

to calculate stack gas volumetric flow using an approved method. 

5. Delete NOx and CO emission limits for 2G Configuration option 

(Conditions X.E.1 and X.E.2). 

6. In Condition X.E.3.a, if “baseload” can be interpreted to mean only 100% 

load, replace “baseload” with “normal operating load.” 

7. Revise Condition X.G.2.a to allow use of EPA Test Methods 19 and 20 in 

addition to 1-4 and 7E for NOx emissions. 

8. Revise Condition X.G.2.b to allow use of EPA Test Method 19 and 20 for 

CO emissions. 

9. Delete Conditions I, II, X.D.2 and X.D.3 from the PSD Permit. 

In a letter dated September 20, 2006, HDPP requested an additional modification: 

10. Modify Condition X.G.1 to change the source testing frequency for NOx

and CO from annually to once every five years. 

VII. EPA Evaluation of Requested Modifications to PSD Permit 

Request 1

HDPP has requested that S/S limits for NOx and CO, which are currently permitted on a 

per CT basis (see Table 2), be combined into a power block emission limit, where “power 

block” is defined as the entire 3x3x1 configuration. HDPP stated that combining the 

emission limits into a power block limit would provide flexibility during the startup 

sequence. In a letter dated December 5, 2007 from Larry Carlson (HDPP) to Anita Lee 

(EPA), HDPP stated that using all three turbines to warm the steam-side components can 

cause additional equipment damage and emissions compared to an alterative scenario 

where one combustion turbine generator (CTG) is used to warm the steam-side 

components and the remaining two CTGs are started after the STG has reached 

acceptable temperatures. Because identical emission limits for all three turbines for S/S 

implies all three turbines are started in an identical manner and equally contribute to the 

warming of the STG, HDPP requests the individual emission limits (per CTG) be 

bundled together into a combined power block limit to allow the use of one turbine to 

warm the STG. 

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Table 2: Current and Requested NOx and CO Emission and Duration Limits for S/S 

NOx Emission Limit 

(lb/event) 

CO Emission Limit 

(lb/event) 

S/S Duration Limit 

(hours) 

Current 

Limit 

(per CTG) 

HDPP Request 

 (per power 

block) 

Current 

Limit 

(per CTG) 

HDPP Request 

 (per power 

block) 

Current 

Limit 

(per CTG) 

HDPP Request 

 (per power 

block) 

Cold Start 183 549 3,541 10,623 4.5 no limit 

Warm Start 168 504 3,596 10,788 2.6 no limit 

Hot Start 138 414 3,729 11,187 1.9 no limit 

Shutdown 97 291 239 717 1.0 no limit 

EPA understands that HDPP prefers to ramp up e.g., CTG 1, in stages to Full Speed/No 

Load until the steam-side components reach appropriate temperature and the SCR system 

reaches a uniform minimum temperature of 464 oF. CTGs 2 and 3 will then be brought 

online quickly, without the concerns related to inappropriate steam-side temperature. 

Thus, emissions from CTG 1 would be higher than emissions from CTG 2 and 3, 

however, the sum of all three CTG emissions would remain below the combined “per 

power block” limit (Table 2). 

EPA is concerned that a combined “per power block” limit may allow for an 

inappropriately high emission limit in the event that only one or two CTGs are started 

and operated. Therefore, EPA suggested that HDPP’s preferred startup sequence be 

submitted to EPA as an alternative startup scenario, with emission limits that are 

appropriate for each individual CTG based on the use of one CTG to warm the steamside components. 

In a letter dated July 28, 2008 from Jon Boyer (HDPP) to Anita Lee, HDPP requested the 

opportunity to conduct a demonstration on November 2, 2008 of an alternative cold 

startup scenario by slowly ramping one CTG to heat the steam-side components and SCR 

system, then starting the remaining two CTGs quickly, while maintaining compliance 

with the “combined power block” limits for all three CTGs. In an Administrative Order 

of Consent to HDPP dated October 31, 2008, EPA granted the alternative startup 

demonstration. 

HDPP provided the continuous emissions monitoring system (CEMS) data from the 24-

hour period that included the November 2, 2008 cold startup, as well as other cold 

startups on May 28, 2009, June 7, 2009, and June 30, 2009 (See Appendix 1). The 

November 2, 2008 startup sequence represented the worst-case NOx emissions for the 

turbine used to warm the steam-side components (“warming turbine”). During that 

startup sequence, HDPP used CTG 1 as the warming turbine. CTG 1 reached compliance 

with its CO and NOx limit (in ppm) by 09:00 on 11/2/08 (total startup duration of 9 

hours). At 05:00, CTG 2 was started and quickly reached compliance with the emission 

limits (ppm) by 08:00. At 08:00, CTG 3 was started and then shutdown at 09:00. CTG 3 

was restarted at 10:00 and quickly reached compliance with its CO emission limit at 

12:00 and with its NOx emission limit at hour 13:00. The sum of emissions from all 3 

CTGs over the entire startup period (13 hour duration) was 3402 lbs CO and 396 lbs NOx

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(See Appendix 2), which is lower than the sum of the individual emission and duration 

limits for each turbine (10,623 lbs CO and 549 lbs NOx over 13.5 hours). 

The May 28, 2009 startup sequence represented the worst-case CO emissions from the 

warming turbine. During that startup sequence, HDPP used CTG 2 as the warming 

turbine. CTG 2 reached compliance with its CO and NOx limit (in ppm) by 07:00 on 

5/28/09 (total startup duration of 8 hours). Over the 8 hour cold startup event, the 

warming turbine emitted 3084 lbs CO. Due to other startup factors, CTG 1 and 3 were 

not brought online and HDPP generally remained out of operation until its next startup 

sequence in early June 2009. Therefore, the May 28, 2009 startup sequence for all three 

turbines was incomplete, however, HDPP requested that EPA rely on the May 28, 2009 

startup sequence for the CO cold start emission limit for the warming turbine, and agreed 

to reduce its hot start CO emission limit for the secondary two turbines during the 

alternative startup scenario from 3729 lb CO/event to 2391 lb CO/event. 

Thus, using the worst-case NOx and CO emissions from the warming turbine November 

2008 and May 2009 alternative startup demonstrations (196 lb NOx/event and 3084 lb 

CO/event), EPA corrected the 8 hour May 2008 startup for a 9.5 hour startup and applied 

a 20% compliance margin for both NOx and CO, and determined that cold startup 

emission limits of 235 lb NOx/event and 4394 lb CO/event over a 9.5 hour duration are 

appropriate for the warming turbine under an alternative startup scenario. For the two 

secondary turbines that are not used to warm the steam components, emission limits of 

138 lb NOx/event and 2391 lb CO/event over 1.9 hour duration are appropriate. The 

NOx emission limit for the secondary turbines are equivalent to the hot start NOx limits 

under normal startup conditions, and the CO emission limit is lower than the hot start CO 

limits under normal startup. 

The sum of startup emissions from the three turbines based on this alternative startup 

scenario (511 lb NOx/event and 9176 lb CO/event over a 13.3 hour duration) are lower 

than the currently permitted startup emission limits using all 3 turbines in cold start mode 

(549 lb NOx/event and 10,623 lb CO/event over 13.5 hour duration). Because the total 

emissions and duration from the alternative cold startup scenario are lower than the sum 

of the individual CTG emission and duration limits, EPA has determined that the 

alternative cold startup scenario will not result in an increase in permitted or actual 

emissions from startup. Therefore, no additional modeling to ensure compliance with the 

NAAQS for CO or NO2 is required because modeling included with the initial PSD 

permit application already included the startup/shutdown emissions at the permitted level. 

Therefore, EPA added new Condition X.E.3.d for the alternative cold startup scenario, 

including NOx and CO emission and duration limits. Although EPA will not revise the 

permit as requested by HDPP to create “combined power block” limits, we will revise it 

to provide separate limits for the warming and secondary turbines. The NOx and CO 

emission and duration limits for the turbine used to warm the components of the steam 

turbine generator (“warming turbine”) shall not exceed 235 lb NOx/event, 4394 lb 

CO/event, and 9.5 hours duration. The NOx and CO emission and duration limits for the 

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other two CTGs shall not exceed the 138 lb NOx/event, 2391 lb CO/event, and 1.9 hours 

duration. 

Request 2

HDPP has requested that the term “equipment” in Condition X.E.3.a be changed to 

“facility”. Condition X.E.3.a pertains to startup and shutdown duration limits for each 

turbine train unit. Since the startup/shutdown applies per turbine train, replacing the term 

“equipment” with “facility” is not appropriate, and EPA will not modify Condition 

X.E.3.a. 

Request 3

HDPP requested that the duration limits (see Table 2) for cold, warm, and hot start, and 

shutdown, be deleted from Condition X.E.3.b, and replaced with a daily CO emission 

limit of 8072 lb/day per turbine, consistent with the District Title V Operating Permit. In 

the April 6, 2004 request for permit revisions, HDPP stated that additional time over what 

was assumed in the original permit application is needed to startup the CTGs. 

HDPP has subsequently clarified, in the December 5, 2007 letter to EPA, that occasional 

“turbine trips” during cold start require immediate shutdown of the turbine to avoid 

system damage. These turbine trips occur within minutes of the individual turbine startup, 

and result in the inappropriate re-categorization of the turbine’s startup as a hot start. In 

the existing PSD permit, a cold start is defined as a startup when the CTG has not been in 

operation during the preceding 72 hours. A hot start is defined as a startup when the 

combustion turbine has been in operating during the preceding 8 hours. Note that cold 

starts are permitted for 4.5 hours, whereas hot starts are permitted for 1.9 hours (see 

Table 2). Thus, a turbine trip that occurs within minutes of startup would not have 

contributed significantly to the warming of the STG, however, because the turbine was 

“in operation” within the last 8 hours, the turbine would be limited to the hot start 

duration. 

In the April 7, 2008 letter to EPA, HDPP provided CO and NOx emission summaries and 

S/S durations from two startup sequences – one sequence where CTG 2 tripped during 

startup, and one sequence where no turbines tripped. According to the information 

submitted by HDPP, for both startup scenarios, emissions of CO and NOx remained 

below the PSD permit S/S per turbine limits and within the S/S duration limits, however 

during the turbine trip scenario, CTG 3, which had not tripped, was shutdown and 

restarted in order to comply with its permitted duration limit for a cold start. HDPP 

contends that although no duration of emission limits were exceeded, the variety of load 

changes and additional shutdown caused unnecessary wear and tear to the equipment. 

To our knowledge, EPA has not included allowances for turbine trips into PSD permits. 

Although EPA recognizes HDPP’s concerns regarding turbine trips, EPA believes that 

the S/S durations are components of the original BACT determination for S/S, and 

removal of the duration limits, combined with a maximum daily limit, could indirectly 

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Draft AAQIR/February 2010 
provide an automatic exemption for excess emissions. Per EPA policy, automatic 

exemptions for excess emission during startup and shutdown periods cannot be 

reconciled with the directives of the CAA1

. Therefore, EPA will not revise Condition 

X.E.3.b to replace S/S duration limits with a maximum daily emission limit. However, 

EPA has amended Condition X.E.3.a.i to define cold startup as either when the 

combustion turbine has not been in operation during the preceding 72 hours or the steam 

turbine inner metal temperature ≤ 325 oF. 

Request 4

HDPP requested that Condition X.D.1.c, which requires use of a continuous monitoring 

system to measure stack gas volumetric flow, be replaced with the requirement that stack 

gas volumetric flow be calculated using an approved method. HDPP states that the 

proposed revision is consistent with 40 CFR Part 75 and the calculation method specified 

in the CEMS monitoring plan approved by EPA and the District. Stack volumetric flow is 

not required to confirm compliance with the NOx and CO limits on a ppm basis, but stack 

volumetric flow is required to confirm compliance with the NOx and CO limits on a lb/hr 

basis. Condition X.D.1.c will be modified as follows: 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. 

Request 5

The original PSD permit issued in 2001 provided for flexibility in choosing between two 

plant configurations at the time of construction, due to market uncertainties at the time of 

permit application. The PSD permit allowed a 3F configuration (three F class CTGs) or a 

2G configuration (two G class CTGs). HDPP was constructed using the 3F configuration, 

and is now requesting that permit conditions pertaining to the 2G configuration 

(Conditions X.E.1 and 2) be deleted from the PSD permit. Because the 2G conditions are 

not applicable to HDPP as constructed, EPA will delete the 2G conditions from the PSD 

permit. 

Request 6

For clarification, HDPP requested that Condition X.E.3.a be revised to replace “base 

load” with “normal operating load” if “base load” can be interpreted to mean only 100% 

load. EPA will revise the condition as requested. 

 

1

 See: 1) Rasnic, John B. “Memorandum on Automatic or Blanket Exemptions for Excess Emissions During 

Startups and Shutdowns under PSD.” EPA Policy and Guidance Database, January 28, 1993. 2) Bennett, Kathleen 

M. “Memorandum on Policy on Excess Emissions During Startup, Shutdown, Maintenance, and Malfunctions”. 

EPA Policy and Guidance Database, February 15, 1983. 3) Bennett, Kathleen M. “Memorandum on Policy on 

Excess Emissions During Startup, Shutdown, Maintenance, and Malfunctions”. EPA Policy and Guidance 

Database, September 28, 1982. 

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Request 7

Condition X.G.2.a requires use of EPA Methods 1-4 and 7E for NOx performance tests. 

HDPP has requested that EPA Methods 19 and 20 be added to Condition X.G.2.a. Since 

Methods 19 and 20 require use of Method 7E to determine NOx concentrations in ppm 

(converted to lb/scf for Method 19), and Methods 19 and 20 are EPA Test Methods for 

NOx, EPA will revise Condition X.G.2.a to state that performance tests for NOx

emissions shall be conducted using EPA Methods 1-4, 7E, and EPA Methods 19, and 20 

may be used in addition to, but not as a substitution for, EPA Method 7E. 

Request 8

Condition X.G.2.b requires use of EPA Method 1-4 and 10 for CO performance tests. 

HDPP requested that EPA Methods 19 and 20 be added to Condition X.G.2.b. 

Additionally, page 5 of the April 6, 2004 letter to EPA refers to EPA Method 7E for CO. 

EPA believes this reference is erroneous, as Method 10 is the test method for CO 

(although many of the Method 10 procedures reference procedures from Method 7E). 

EPA Methods 19 and 20 do not specifically discuss CO, however, since these methods 

are calculation methods to convert from measurements in ppmvd to lb/hr emissions, EPA 

Methods 19 and 20 are appropriate for CO, provided they rely on CO measurements 

using EPA Method 10. EPA will revise Condition X.G.2.b to state that performance tests 

for CO emissions shall be conducted using EPA Methods 1-4, 10, and EPA Methods 19, 

and 20 maybe be used in addition to, but not as a substitution for, EPA Method 10. 

 

Request 9

HDPP has requested that Conditions I, II, X.D.2 and X.D.3 be deleted from the PSD 

permit because they relate solely to the construction phase of the project, which has 

already been completed. EPA does not believe that any benefit or improved clarity results 

from deleting the requested conditions. By maintaining all applicable conditions and 

requirements in the PSD permit, the document provides the full Authority to Construct 

permitting history for the facility. Therefore, EPA will retain Conditions I, II, X.D.2 and 

X.D.3. 

Request 10

Conditions X.D.1.a and b of the HDPP PSD permit requires installation, operation, and 

maintenance of CEMS for NOx and CO emissions. The PSD permit requires each CEMS 

to meet the EPA monitoring performance specifications of 40 CFR 60.13 and 40 CFR 

Part 60 Appendix B, requiring annual calibration drift tests and relative accuracy test 

audits (RATA). In addition to annual testing and calibration of the CEMS for NOx and 

CO, Conditions X.G.1 and 2 requires annual performance tests for CO and NOx using 

EPA Test Methods 1-4, and 10 or 7E, for CO and NOx, respectively. HDPP is currently 

requesting that the frequency of the performance test requirement be reduced from 

annually to every five years. HDPP states that the continuous monitoring for NOx and CO 

using CEMS, and the annual CEMS RATAs are sufficient to ensure compliance with the 

NOx and CO emission limits. 

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EPA agrees that the use and annual testing of the NOx and CO CEMS are adequate to 

ensure compliance with the NOx and CO emission limits. Because the CEMS provide 

continuous emission information that are monitored, recorded, and reported to EPA, the 

NOx and CO CEMS provide a more complete compliance indicator than performance 

tests that occur annually. EPA changed Condition X.G.1 to require performance tests 

every five years, but added a statement that should either CEMS fail a RATA, HDPP 

would be required to conduct a performance test when the CEMS were re-tested 

following the failed RATA. 

VIII. Additional PSD Requirements 

Because the proposed project will not result in a significant emissions increase of any 

PSD regulated pollutant, EPA determines that new analyses for best available control 

technology, ambient air quality impacts, and impacts to Class I areas and soils and 

vegetation are not required, pursuant to 40 CFR 52.21. 

Based on review of this project, because the project will not result in a physical 

modification to the facility, EPA has concluded that this project will have no effect on 

listed species or their critical habitat, and thus, EPA has fulfilled its responsibilities under 

Section 7 of the Endangered Species Act. 

IX. Proposed Action and Conclusion 

Based on the information supplied by the applicant, and the evaluation provided above 

which determined this project will not result in a major PSD modification, EPA is 

proposing issuance of a modified PSD permit. 
High Desert Power Project 

AAQIR/February 2010 

Appendix 1 



RECEIVED 

High Desert P JUN 1 5 2009 OWer Project, II 

Permits Ottice Air-3 1044 N 115 St . reet, SUite 400 I 0 

U.S. EPA, Region 9 402- maha, Nebraska 68154-4446 June 11, 2009 

1=i~CEIVEC39526

~s. Deborah Jordan JUN 15 2009
 

D1rector - Region 9
 1'errnif8 Office Air-3 

U.S. Environmental Protection A .
 U.S. EPA, Region 9

75 Hawthorne Street gency - AIr Division
 

San Francisco, CA 94105-3901 

RE: Stea~ !urbine Cold Start Report Overnight Courier ~:g~I~lstratipveOrder on Consent R9-2009-002 

esert ower Project, LLc 

Dear Ms. Jordan: 

In accordance with Section IV ofthe referen ". ced Desert Power Project (HDPP) b . th b AdmInIstrative Order on Consent, the High 

su m1ts e a ove-referenced report. 

On May 28 2009 f( 11 . 3 I ' ,0 owmg a 2-dayoutage, HDPP began a cold start of the three combustion 

turbmes and steam turbine generator. A cold start ofthe steam turbine generator is any start 

where the steam turbine inner metal temperature is 300 degrees Fahrenheit or less prior to startup 

ofthe power block. The Administrative Order on Consent limits the total pounds of CO and 

NOx to 10,623 lbs and 549 lbs, respectively, during a combined 13.5 hour period. Table 1 below 

summarizes the emissions from this cold start event, as required by the Administrative Order of 

Consent. 

Table 1 

I 

Unit Start End Duration 

(hrs) 

CO 

(Ibs) 

NO, 

(Ibs) 

0002 5/28/2009 23:20 5/29/2009 5:21 6.02 3361.0 160.6 

0003 5129/2009 17:56 5/29/2009 17:58 0.05 0.0 0.0 

0003 5/30/2009 10:15 5/30/2009 10:22 0.13 186.1 1.9 

0003 5/30/2009 II :08 5/30/2009 II :08 0.02 5.3 0.5 

0003 5/30/2009 12:17 5/30/2009 13:51 1.58 716.3 101.2 

0001 5/31/2009 II :46 5/3112009 13:06 1:21 441.7 106.9 

Total Emissions for Power Block Startup 9.0 4710.4 371.1 

Cold Start Power Block Emission Limit 13.5 10,623.0 549.0 

Unit 1 and Unit 3 experienced maintenance problems that delayed their startup, and each . 

combustion turbine experienced combustion dynamic issues that prevented sta?le ~nd contmuous 

operation. Unit 1 required several restarts of the combustion turbine due to umt tnps. 
June 11,2009 

Page 2 

The Administrative Order of Consent Requires HDPP to report each combustion turbine's hourly 

emissions of NOx and CO in the units of pounds per hour and average ppm (adjusted to 15% O2) 

for all full-hour periods for 24 hours following the start ofthe cold preheat ofthe steam turbine 

generator. This data is included in the attached Table 2. 

If you have any questions regarding this submittal, please contact Mr. Jon Boyer at 

(760) 530-2303. 

Sincerely, 

HIGH DESERT POWER TRUST, 

a Delaware statutory business trust 

By: High Desert Power Project, LLC, 

a California limited liability company, as agent
 

for the High Desert Power Trust under that certain
 

Amended and Restated Project Supervisory Agreement
 

dated as ofApril 30, 2001
 

By:f~) Todd J't:;( Vice President 

cc:	 Chris Jacobsen - Tenaska Inc. 

Project File: 1.1.2 
Table 2
 

High Desert Power Project
 

Cold Start Hourly Emission Data
 

May 2009
 

Date Hour 

UNITOO01 UNITOO02 UNITOO03 

CO#/HR 

(Ib/hr) 

COCORR 

(ppm) 

CTLOAD 

(MW) 

NOXCORR 

(ppm) 

NOXLBS 

(Ibs) 

UNITOPHR 

(min) 

CO#/HR 

(Ib/hr) 

COCORR 

(ppm) 

CTLOAD 

(mw) 

NOXCORR 

(ppm) 

NOXLBS 

(Ibs) 

UNITOPHR 

(min) 

CO#/HR 

(Iblhr) 

COCORR 

(ppm) 

CTLOAD 

(mw) 

NOXCORR 

(ppm) 

NOXLBS 

(Ibs) 

UNITOPHR 

(min) 

OS/28/09 23:00 0.0 0.0 o.e 0.0 o.e e 333.~ 681. 5.E 29.8 24.0 4C 0.( 0.( o.e o.e 0.0 C 

OS/29/09 00:00 0.0 0.0 0.0 0.0 o.e e 406. 319. 15.C 27.6 57.9 6C O.C 0.0 O.C o.e 0.0 C 

OS/29/09 01:00 0.0 0.0 0.0 0.0 o.e C 470. 321.E 2H 7.5 18. 6e O.C 0.0 o.e o.e 0.0 C 

OS/29/09 02:00 0.0 0.0 0.0 0.0 O.C C 487. 315.E 32.9 6.6 17.2 6C 0.0 0.0 o.e O.C 0.0 C 

OS/29/09 03:00 0.0 0.0 O.C 0.0 0.0 C 488. 316.~ 32.9 7.9 19.9 6C 0.0 0.0 O.C O.C 0.0 C 

05129/09 04:00 0.0 0.0 O.C O. 0.0 C 424.~ 260. 40.9 6.6 17.5 6C 0.0 0.0 O.C O.C 0.0 0 

OS/29/09 05:00 0.0 0.0 O.C 0.( O.C C 343.~ 189.e 53. 5.9 17. 6( 0.( 0.0 O.C o.e 0.0 0 

OS/29/09 06:00 0.0 0.0 O.C 0.( O.C C 129. 50.~ 95. 3.0 12.6 6C O.C 0.0 O.C o.e 0.0 0 

OS/29/09 07:00 0.0 0.0 0.0 0.0 O.C e 0.( O.C 124. 2.4 12.4 6C O.C 0.0 O.C o.e 0.0 0 

05129/09 08:00 0.0 0.0 0.0 0.0 O.C e O.C O.C 131.e 2.4 13.e 6C 0.0 0.0 o.e o.e 0.0 0 

05129/09 09:00 0.0 0.0 O.C 0.0 O.C C O.C O.C 139.C 2.4 13.E 6( 0.0 0.0 O.C O.C 0.0 0 

OS/29109 10:00 0.0 0.0 O.C 0.0 0.0 C O.C o.e 139.1 2.4 13.6 6C 0.0 0.0 O.C O.C 0.0 0 

OS/29/09 11:00 0.0 0.0 O.C D. 0.0 C O.C O. 139. 2.5 13.6 6C 0.0 0.0 O.C O.C 0.0 0 

OS/29/09 12:00 0.0 0.0 O.C 0.( O.C C 0.( O.C 13H 2.4 13.1 6C 0.0 0.0 O.C O.C 0.0 0 

05129/09 13:00 0.0 0.0 O.C 0.( O.C C O.C O.C 119.9 2.4 12. 6C 0.0 0.0 O.C o.e 0.0 0 

OS/29/09 14:00 0.0 0.0 0.0 0.0 O.C e O.C O.C 120.1 2.4 12.< 6C 0.0 0.0 O.C O.C 0.0 0 

05129/09 15:00 0.0 0.0 0.0 0.0 O.C e O.C 0.1 120.E 2.4 12.2 6C 0.0 0.0 o.e O.C 0.0 0 

OS/29/09 16:00 0.0 0.0 0.0 0.0 0.0 e O.C o.e 129.e 2.4 12.9 6C 0.0 O.C O.C 0.( O.C 0 

OS/29/09 17:00 0.0 0.0 O.C 0.0 0.0 C 89.~ 105A 56.9 5.2 7.< 2E 0.0 0.0 O.C O.C O.C 

05129/09 18:00 0.( 0.0 O.C 0.( 0.0 C 0.( O.C O.C 0.0 0.0 C 0.0 0.0 O.C 0.( 0.0 0 

OS/29/09 19:00 O.C 0.0 O.C 0.( 0.0 C 0.( O.C O.C 0.0 0.0 ( 0.0 0.0 O.C O.C 0.0 0 

OS/29/09 20:00 0.( 0.0 O.C 0.( O.C C O.C O.C O.C 0.0 0.0 C 0.0 0.0 O.C O.C O.C 0 

OS/29/09 21:00 0.( 0.0 0.0 0.( O.C e 0.( O.C O.C 0.0 O.C ( 0.0 O.C 0.( O.C O.C 0 

05129/09 22:00 0.( 0.0 0.0 0.0 O.C C 0.( O.C O.C 0.0 O.C C 0.0 O.C O.C O.C o.e 0 

05129/09 23:00 0.0 0.0 0.0 0.0 0.0 C 0.( O.C O.C 0.0 0.0 C 0.0 O.C O.C 0.( o.e 0 

05130/09 00:00 0.0 0.0 0.0 0.0 0.0 C 0.( O.C O.C 0.0 0.0 C 0.0 0.0 O.C 0.( O.C 0 

05130/09 01:00 0.( 0.0 O.C 0.( O.C C 0.( O.C O.C 0.0 0.0 C 0.0 0.0 O.C 0.( O.C 0 

05130/09 02:00 0.( 0.0 O.C 0.( O.C C 0.( O.C O.C 0.0 0.0 C 0.0 O.C O.C 0.0 o.e C 

05130/09 03:00 0.( 0.0 O.C 0.( O.C C 0.( O.C O.C 0.0 O.C ( 0.0 O.C 0.( 0.0 o.e C 

It\ 1'\' +-- I : 3Uf\ e. II - 3'3 (, I 

Page 1 of 3 - h..-s 
Date Hour 

UNITOOOl UNITOO02 UNITOO03 

CO#/HR 

(Ib/hr) 

COCORR 

(ppm) 

CTLOAD 

(MW) 

NOXCORR 

(ppm) 

NOXLBS 

(Ibs) 

UNITOPHR 

(min) 

CO#/HR 

(Ibihr) 

COCORR 

(ppm) 

CTLOAD 

(mw) 

NOXCORR 

(ppm) 

NOXLBS 

(Ibs) 

UNITOPHR 

(min) 

CO#/HR 

(Ibihr) 

COCORR 

(ppm) 

CTLOAD 

(mw) 

NOXCORR 

(ppm) 

NOXLBS 

(Ibs) 

UNITOPHR 

(min) 

05130/09 04:00 O.C O.C 0.( 0.( 0.0 C 0.( O.C O.C 0.0 O.C ( 0.0 O.C 0.0 0.0 0.( C 

05130109 05:00 O.C O.C 0.( 0.( 0.0 C 0.( O.C O.C 0.0 O.C ( 0.0 O.C 0.0 0.0 0.( C 

05130/09 06:00 O.C O.C 0.( 0.( 0.0 C 0.( O.C O.C 0.0 O.C ( 0.0 O.C 0.0 0.0 0.( ( 

05130/09 07:00 O.C O.C 0.( 0.( 0.0 C 0.( O.C O.C 0.0 O.C ( 0.0 O.C 0.0 0.0 0.( ( 

05130/09 08:00 O.C O.C 0.( 0.( 0.0 C 0.( O.C O.C 0.0 O.C ( 0.0 O.C 0.0 0.0 0.( ( 

05130/09 09:00 O.C O.C 0.( 0.( 0.0 C O.C O.C O.C 0.0 O.C ( 0.0 O.C 0.0 0.0 0.( C 

05/30/09 10:00 O.C O.C 0.( 0.( 0.0 C 0.( O.C O.C 0.0 O.C ( 186.1 1,606. 0.0 10.1 1.9 1 

05130/09 11:00 O.C O.C 0.( 0.( 0.0 C 0.( O.C O.C 0.0 O.C ( 5.0 231.6 0.0 13. 0.5 1 

05130/09 12:00 O.C O.C 0.( 0.( 0.0 C 0.( O.C O.C 0.0 O.C ( 425.C 525. 6.9 34.6 45.8 4 

05130/09 13:00 O.C 0.( 0.( 0.( 0.0 C O.C O.C O.C 0.0 O.C ( 185.6 76.• 86.5 13.a 55.4 6( 

05130/09 14:00 O.C O.C 0.( 0.( 0.0 C 0.( O.C O.C 0.0 O.C ( O.C O.C 103. 2.4 11.0 6( 

05130/09 15:00 O.C O.C 0.( 0.( 0.0 C 0.( O.C O.C 0.0 O.C ( 105.5 57.1 66.9 4.a 14.6 52 

05130/09 16:00 O.C O.C 0.( 0.( 0.0 C 0.( O.C O.C 0.0 O.C ( O.C O.C 0.0 O.C 0.0 0 

05130/09 17:00 O.C O.C 0.( 0.( 0.0 C 0.( O.C O.C 0.0 O.C ( O.C 0.( 0.0 O.C 0.0 0 

05130/09 18:00 O.C O.C 0.( 0.( 0.0 C 0.( O.C O.C 0.0 O.C ( O.C 0.( O.C O.C 0.0 0 

05130/09 19:00 O.C O.C 0.( 0.( 0.0 C 0.( O.C O.C 0.0 O.C ( O.C 0.( O.C O.C 0.0 0 

05130/09 20:00 O.C O.C 0.( 0.( 0.0 C O.C O.C O.C 0.0 O.C 0 O.C 0.( O.C O.C 0.0 0 

05130/09 21:00 O.C 0.( 0.( 0.( 0.0 C 0.( 0.( O.C 0.0 O.C 0 O.C O.C O.C O.C 0.0 0 

05130/09 22:00 O.C 0.( 0.( 0.( 0.0 C 0.( O.C O.C 0.0 O.C 0 O.C O.C O.C O.C 0.0 0 

05130/09 23:00 O.C 0.( 0.( 0.( 0.0 C 0.( 0.( O.C 0.0 O.C 0 O.C O.C O.C O.C 0.0 a 

05131/09 00:00 O.C 0.( 0.( 0.( 0.0 C 0.( 0.( O.C 0.0 O.C 0 O.C 0.( O.C 0.( 0.0 a 

05131/09 01:00 O.C 0.( 0.( 0.( 0.0 C 0.( 0.( 0.( 0.0 O.C a O.C 0.( O.C O.C 0.0 a 

05131/09 02:00 O.C 0.( 0.( 0.( 0.0 C 0.( 0.( 0.( O.C O.C a O.C 0.( O.C O.C O.C a 

05131/09 03:00 O.C 0.( 0.( 0.( 0.0 C 0.( 0.( 0.( 0.0 O.C a O.C 0.( O.C O.C O.C a 

05131/09 04:00 O.C 0.( 0.( 0.( 0.0 C 0.( 0.( O.C O.C O.C a O.C 0.( O.C 0.( O.C a 

05131/09 05:00 O.C O.C 0.0 0.( 0.0 C 0.( 0.( O.C O.C O.C a O.C 0.( O.C 0.( O.C a 

05131/09 06:00 O.C O.C 0.0 0.( 0.0 C 0.( O.C O.C O.C 0.( a O.C 0.( O.C 0.( O.C a 

05131/09 07:00 O.C O.C 0.0 0.( 0.0 C 0.( 0.( O.C O.C 0.( a O.C 0.( O.C 0.( O.C a 

05131/09 08:00 0.( 0.( 0.0 0.( 0.0 ( 0.( 0.( O.C O.C O.C a 0.( 0.( O.C 0.( O.C a 

05131/09 09:00 O.C 0.( 0.0 0.( 0.0 ( 0.( 0.( 0.( O.C 0.( a 402.E 356.1 17. 27.1 50A 54 

05131/09 10:00 O.C 0.( 0.0 0.( 0.0 C 0.( O.C 0.( O.C 0.( a 1. O. 111.E 2.! 11.! 6C 

05131/09 11:00 290A 1,407.! 0.5 5.( 7.6 1~ 0.( 0.( O.C O.C 0.( a 0.( 0.( 135.6 2. 13. 6C 

05131/09 12:00 151. 86. 48.3 33. 96.1 6C 0.( 0.( O.C O.C 0.( a 0.( 0.( 141.E 2. 13. 6C 

05131/09 13:00 0.( 0.( 101. 3. 14.2 6C 0.( 0.( O.C O.C 0.( a 0.( 0.( 15H 2. 14. 6C 

05131/09 14:00 0.( O.C 104.9 2. 10.9 6( 0.( 0.( O.C O.C 0.( a 126. 47. 102.6 3. 15.! 5a 

05131/09 15:00 0.( 0.( 116.0 2. 11.7 6( 0.( 0.( O.C O.C 0.( a 0.( 0.0 O.C 0.0 O.C C 

05131/09 16:00 O.C 0.( 141A 2.1 15.:< 6C 0.( 0.( O.C O.C O.C a 0.( 0.0 0.( 0.0 O.C C 

05131/09 17:00 40. 13A 120.6 2.1 13.6 6C 0.( 0.( 0.( O.C 0.( a 0.( 0.0 0.( 0.0 0.( C 

Page 2 of 3 
Date Hour 

UNITOO01 UNITOO02 UNITOO03 

CO#/HR 

(Ib/hr) 

COCORR 

(ppm) 

CTLOAD 

(MW) 

NOXCORR 

(ppm) 

NOXLBS 

(Ibs) 

UNITOPHR 

(min) 

CO#/HR 

(Ib/hr) 

COCORR 

(ppm) 

CTLOAD 

(mw) 

NOXCORR 

(ppm) 

NOXLBS 

(Ibs) 

UNITOPHR 

(min) 

CO#/HR 

(Ib/hr) 

COCORR 

(ppm) 

CTLOAD 

(mw) 

NOXCORR 

(ppm) 

NOXLBS 

(Ibs) 

UNITOPHR 

(min) 

05131/09 18:00 12.f 180.f O.! 9.! 1.1 4 O.C 0.0 0.0 0.0 0.0 C 0.( 0.0 O.C O.C 0.0 0 

05131/09 19:00 O.C O.C 0.( O.C 0.( a O.C 0.0 0.0 0.0 0.0 C 0.( 0.0 O.C O.C 0.0 0 

05131/09 20:00 O.C O.C 0.( O.C 0.( a O.C 0.0 0.0 0.0 0.0 C 0.( 0.0 O.C O.C 0.0 0 

05131/09 21:00 O.C O.C 0.( O.C 0.( a O.C 0.0 0.0 0.0 0.0 C 0.( 0.0 O.C O.C 0.0 0 

05131/09 22:00 0.( O.C 0.( O.C 0.( a O.C 0.0 0.0 0.0 0.0 C 0.( 0.0 O.C O.C 0.0 0 

05131/09 23:00 O.C O.C 0.( O.C 0.( C O.C 0.0 0.0 0.0 0.0 C 0.( 0.0 O.C O.C 0.0 a 

Page 3 of 3 
e - 

FA’ 

HIGH DESERT 

POWER PROJECT, LLC 

June 16.2009 

Ms. Deborah Jordan 

Director - Region 9 

U.S. Environmental Protection Agency - Air Division 

75 Hawthorne Street 

San Francisco, CA 94105-3901 

High Desert Power Project, LLC 

1044 N. 11 5 Street, Suite 400 I Omaha, Nebraska 681 54-4446 

402-691-9500 I FAX: 402-691-9526 

Overnight Courier 

RE: Steam Turbine Cold Start Report 

Administrative Order on Consent R9-2009-002 

High Desert Power Project, LLC 

Dear Ms. Jordan: 

In accordance with Section IV of the referenced Administrative Order on Consent, the High 

Desert Power Project (HDPP) submits the above-referenced report. 

On June 7,2009, after not operating the units for 7 days, HDPP began a cold start of the three 

combustion turbines and steam turbine generator. A cold start of the steam turbine generator is 

any start where the steam turbine inner metal temperature is 300 degrees Fahrenheit or less prior 

to startup of the power block. The Administrative Order on Consent limits the total pounds of 

CO and NOx to 10,623 lbs and 549 Ibs, respectively, during a combined 13.5 hour period. Table 

1 below summarizes the emissions from this cold start event, as required by the Administrative 

Order of Consent. 

Table 1 

Duration co NO, 

(hrs) (Ibs) 

Unit Start End 

The Administrative Order of Consent Requires HDPP to report each combustion turbine’s hourly 

emissions of NO, and CO in the units of pounds per hour and average ppm (adjusted to 15% 02) 

for all full-hour periods for 24 hours following the start of the cold preheat of the steam turbine 

generator. This data is included in the attached Table 2. 
June 16,2009 

Page 2 

If you have any questions regarding this submittal, please contact Mr. Jon Boyer at 

(760) 530-2303. 

Sincerely, 

HIGH DESERT POWER TRUST, 

a Delaware statutory business trust 

By: 

By: 

cc: 

High Desert Power Project, LLC, 

a California limited liability company, as agent 

for the High Desert Power Trust under that certain 

Amended and Restated Project Supervisory Agreement 

dated as of April 30,2001 

Chris Jacobsen - Tenaska Inc. 

Project File: 1.1.2 
Table 2 

High Desert Power Project 

Cold Start Hourly Emission Data 

June 7-8, 2009 
- 

Unit 

0001 

0002 

High Desert Power Project, LLC 

Duration co NO, 

(hrs) (Ibs) (Ibs) 

Start End 

613012009 1:06 613012009 5:35 4.5 1 1 10.0 84.2 

613012009 6:20 613012009 9:25 3.1 72 1.9 95.3 

HIGH DESERT 

POWER PROJECT, LLC 

0003 I 613012009 I 798 I 613012009 I 9:25 

Total Emissions for Power Block Startup 

1044 N. 11 5 Street, Suite 400 I Omaha, Nebraska 681 54-4446 

402-691 -9500 I FAX: 402-691 -9526 

1.9 713.8 81.7 

9.5 2545.7 261.2 

July 13,2009 

Ms. Deborah Jordan 

Director - Region 9 

U.S. Environmental Protection Agency - Air Division 

75 Hawthorne Street 

San Francisco, CA 94105-3901 

Overnight Courier 

RE: Steam Turbine Cold Start Report 

Administrative Order on Consent R9-2009-002 

High Desert Power Project, LLC 

Dear Ms. Jordan: 

In accordance with Section IV of the referenced Administrative Order on Consent, the High 

Desert Power Project (HDPP) submits the above-referenced report. 

On June 30,2009, after not operating the units for 22 days, HDPP began a cold start of the three 

combustion turbines and steam turbine generator. A cold start of the steam turbine generator is 

any start where the steam turbine inner metal temperature is 300 degrees Fahrenheit or less prior 

to startup of the power block. The Administrative Order on Consent limits the total pounds of 

CO and NOx to 10,623 lbs and 549 lbs, respectively, during a combined 13.5 hour period. Table 

1 below summarizes the emissions from this cold start event, as required by the Administrative 

Order of Consent. 

I Cold Start Power Block Emission Limit I 13.5 110,623.0 I 549.0 

The Administrative Order of Consent Requires HDPP to report each combustion turbine’s hourly 

emissions of NO, and CO in the units of pounds per hour and average ppm (adjusted to 15% 02) 

for all full-hour periods for 24 hours following the start of the cold preheat of the steam turbine 

generator. This data is included in the attached Table 2. 
July 13,2009 

Page 2 

If you have any questions regarding this submittal, please contact Mr. Jon Boyer at 

(760) 530-2303. 

Sincerely, 

HIGH DESERT POWER TRUST, 

a Delaware statutory business trust 

By: 

By: 

cc: 

High Desert Power Project, LLC, 

a California limited liability company, as agent 

for the High Desert Power Trust under that certain 

Amended and Restated Project Supervisory Agreement 

dated as of April 30,2001 

(r e.8- /- 

Larry G. Carlson 

Air Program Manager 

Chris Jacobsen - Tenaska Inc. 

Project File: 1.1.2 
Table 2 

High Desert Power Project 

Cold Start Hourly Emission Data 

June 30,2009 

source UNlTMMl UNliODm UNIT0003 I I 

CWMR CWORR CTLOAD NOX#MR NOXCORR UNITOPHR 

(IMr) (wm) (MW WW (PI (nw 

Parameler 

(Unit) cm CDCORR CTLOAD NOM NOXCORR UNVOPHR CW-IR COCORR cnam NOX~WHR NOXCORR UNITOPHR 

uamr) (ppm) (ml (m) mn) (m) (rmhr) (Ppm) (MI Wr) (wm) Im) 

06130m9 MW 
High Desert Power Project 

AAQIR/February 2010 

Appendix 2 
High Desert Cold start on November 2, 2008 - Alternative Startup Demonstration

Steady state emission limits: CO = 4 pm; NOx = 2.5 ppm begins compliance with steady state limit

Unit 1 CT Unit 2 Unit 3

Hour CO lb/hr CO ppm NOx lb/hr NOx ppm MW CO lb/hr CO ppm NOx lb/hr NOx ppm MW CO lb/hr CO ppm NOx lb/hr NOx ppm 

0:00 0.1 8.5 4.8 6.5 0 0 0 0 0 0 180.8 1295.1 6.2 5.9 1:00 280.6 217.5 68.4 32.3 16 0 0 0 0 0 0 0 0 0 

2:00 304.2 196.2 22.1 8.7 32.5 0 0 0 0 0 0 0 0 0 

3:00 297.2 191.4 18 7 32.8 0 0 0 0 0 0 0 0 0 

4:00 300.7 191.2 18.9 7.3 34.4 0 0 0 0 0 0 0 0 0 

5:00 271 165.5 16.8 6.2 39.6 255.5 1996.1 16 11.4 0 0 0 0 0 

6:00 276.9 168.7 19 6.9 40.1 356.7 256 73.3 32.1 23.8 0 0 0 0 

7:00 134.3 69.5 17.2 5.3 62 115.1 47.3 35.8 9.1 90.2 0 0 0 0 

8:00 37 14.1 10.4 2.6 97.5 0 0 11.6 2.4 115.1 170.2 1917.1 14.9 12.2 

9:00 0 0 11.7 2.5 114.7 0 0 11.5 2.3 114.9 0 0 0 0 

10:00 0 0 11.7 2.5 114.7 0 0 11.5 2.4 115 123.9 459.5 25.5 19 

11:00 0 0 11.7 2.4 114.4 0 0 11.5 2.4 114.7 478.3 233 19.2 5.7 

12:00 0 0 11 2.3 123.7 0 0 12.3 2.4 124.4 0 0 16.6 3.4 

13:00 0 0 14.9 2.3 147.5 0 0 14.6 2.4 150.1 0 0 14.8 2.5 

14:00 0 0 14.2 2.4 144.7 0 0 14.1 2.4 146.9 0 0 14.3 2.3 

15:00 0 0 14.4 2.4 147.5 0 0 14.3 2.4 149.9 0 0 14.5 2.4 

16:00 0 0 15.9 2.4 149.6 0 0 15.5 2.4 152.2 0 0 15.3 2.4 

17:00 0 0 16.3 2.4 151.2 0 0 15.8 2.4 154.3 0 0 15.4 2.4 

18:00 0 0 16.3 2.4 152 0 0 15.9 2.4 155.5 0 0 15.1 2.4 

19:00 0 0 16.3 2.4 152.9 0 0 15.8 2.4 156.1 0 0 16 2.4 20:00 0 0 15.8 2.4 153.5 0 0 15.3 2.4 156.8 0 0 15.6 2.4 

21:00 0 0 16 2.4 153.8 0 0 15.5 2.4 157.2 0 0 15.9 2.4 

22:00 0 0 13.2 2.4 130.5 0 0 13.1 2.4 132 0 0 13.3 2.4 

23:00 0 0 11.8 2.4 113.6 0 0 11.6 2.4 113.7 0 0 11.8 2.4 

CO NOx CO NOx CO NOx

sum of emissions until unit complies with limit

1902 195.6 727.3 125.1 772.4 76.2

Sum over 14 

hours for 3 units 3401.7 396.9

Requested 

power block 

limit

10,623 549

limit 235

Alternative Startup Condition? Current per turbine emission limitsCT used to warm STG: 9 hour startup duration; CO lb/event limit: 2290 lb/event, NOx lb/event limit: 235 lb/event Cold start: CO = 3541 lb/event, NOx = 183 lCT2/CT3: 2 hour startup duration; CO lb/event limit: 927 lb/event; NOx lb/event limit: 92 lb/event Hot Start: CO = 3729 lb/event; NOx = 138 lbTotal Cold start time for all 3 turbines not to exceed 14 hours?sum of all 3 CO 4144 lb/event

NOx 419 lb/event

created 8/26/09