# 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 Deterior ation 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 Availabl e 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/m 3 

# micrograms per cubic meter MW megawatt NAAQS National Ambient Air Quality Standard NESHAP National Emission Standards for Hazardous Air Pollutants NO 2 

# Nitrogen dioxide NO x 

# Nitrogen oxide NSPS Standard of Performance for New Stationary Sources O 2 

# Oxygen O 3 

# Ozone PM Particulate matter PM 2.5 

# Particulate matter with aerodynamic di ameter less than 2.5 micrometers PM 10 

# Particulate matter with aerodynamic diameter less than 10 micrometers
ppm parts per million
ppm v 

# 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 pe r Million British Thermal Units SO 2 

# 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 Basi s 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 pe rmit conditions, including requirem ents 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 Sout hern 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 (O 3 

# ) and particulate matter with aerodynamic diameter le ss than 10 micrometers (PM 10 

# ); and designated attainment with the NAAQS for nitrogen dioxide (NO 2 

# ), sulfur dioxide (SO 2 

# ), carbon monoxide (CO), and particulate matter with aerodyna mic diameter less than 2.5 micrometers (PM 2.5 

# ). The U.S. EPA is the PSD permitting authority for attainment pollutants in San Bernardino County where HDPP is located, with exception of the southw estern 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 natura l gas-fired combined cycle combustion turbines (CT), each with a dedicated heat recovery steam generator (HRSG). Each CT+HRSG unit feeds into one steam turbin e generator (STG). Air pollution control equipment includes dry low NO x 

# 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 Po wer Project. HDPP was subject to PSD requirements for NO x 

# and CO because the facility’s potential to emit (PTE) of NO x 

# and CO exceeded the 100 tons per year (tpy) major source threshold. The Ambient Air Quality Impact Report (AAQIR) fo r the PSD permit identified the NO x 

# and CO control requirements that were determ ined to comprise BACT. A NO x 

# emission limit of 2.5 ppm v 

# (at 15% O 2 

# , one hour average), using a combination of dry low NO x 

# combustors and selective catalytic redu ction (SCR) with a 10 ppm v 

# ammonia slip at 15% O 2 

# ; and a CO emission limit of 4.0 ppm (24 hour average at 15% O 2 

# ) using good combustion practices and an oxidation catalyst we re determined to satisfy the BACT requirements for NO x 

# and CO.

HDPP informed EPA, on July 13, 2001, of mi nor 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 conf iguration from 3x3x3 (i.e., three combustion turbines (CT), three heat recovery steam generators (HRSG), and three steam turbine generators (STG)) to a 3x3x1 c onfiguration, reconfiguration of the cooling tower from three towers to one, addition of a diesel fire water 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 qua lify as a major modification under PSD. Therefore, the terms and conditions include d in the PSD permit issued February 15, 2001, and the modeling analyses on which the origin al 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 “m ajor stationary source” as any stationary source belonging to a list of 28 source categor ies 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., fo ssil fuel-fired electric plants with heat inputs of more than 250 MMBtu/hr), therefor e 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 modifi cation results in a significant net emissions increase greater than the threshold prescribed for a ny pollutant subject to PSD. See 40 CFR 52.21(a)(2)(iv)(a). The significance threshol ds 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) furt her 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 ar ea that is equal to or exceeds 1 μ g/m 3



# . Table 1: PSD Significance Thresholds Pollutant CO NO 2 

# VOC SO 2 

# PM 10 

# PM 2.5 

# 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 wh ich 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 Availa ble Control Technology (BACT); 2. Analysis of ambient air quality impacts from the project; 3. Analysis of air quality and visi bility 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 re quested changes to th e 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 ab ility to protect ambient air quality and increments, or to comply with the requir ements 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 propos ed changes include adding an alternative startup scenario, revising the continuous mon itoring systems permit language such that it is consistent with the Acid Rain regulati ons (40 CFR Part 75), and allowing additional use of EPA Test Methods. Other minor cha nges are administrative in nature such as deleting obsolete language and cl arifications. The new alterna tive 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 reque sted 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 NO x 

# 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.

6 of 13 High Desert Power Project Draft AAQIR/February 2010

# 2. For condition X.E.3.a, replace “equipment” with “facility”. 3. Remove S/S duration limits in Conditi on 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 volumetri c flow and replace with requirement to calculate stack gas volumetric flow using an approved method. 5. Delete NO x 

# and CO emission limits fo r 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 us e of EPA Test Methods 19 and 20 in addition to 1-4 and 7E for NO x 

# emissions. 8. Revise Condition X.G.2.b to allow us e 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 re quested an additional modification:

10. Modify Condition X.G.1 to change the source testing frequency for NO x 

# 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 NO x 

# 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 confi guration. HDPP stated that combining the emission limits into a power block limit w ould provide flexibility during the startup sequence. In a letter dated December 5, 2007 from Larry Carlson (HDPP) to Anita Lee (EPA), HDPP stated that usi ng 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 emi ssion limits for all three turbines for S/S implies all three turbines are started in an identical manner and equa lly contribute to the warming of the STG, HDPP requests the indi vidual emission limits (per CTG) be bundled together into a combined power block limit to allow the use of one turbine to warm the STG.

7 of 13 High Desert Power Project Draft AAQIR/February 2010

# Table 2: Current and Requested NO x 

# and CO Emission and Duration Limits for S/S

NO x 

# 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 a ppropriate 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 hi gher 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 ev ent that only one or two CTGs are started and operated. Therefore, EPA suggested th at 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 fr om Jon Boyer (HDPP) to Anita Lee, HDPP requested the opportunity to conduct a demonstration on N ovember 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 CT Gs quickly, while maintaining compliance with the “combined power block” limits for a ll 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 NO x 

# emissions for the turbine used to warm the steam-side com ponents (“warming turbine”). During that startup sequence, HDPP used CTG 1 as the warming turbine. CTG 1 reached compliance with its CO and NO x 

# limit (in ppm) by 09:00 on 11/2/08 (total startup duration of 9 hours). At 05:00, CTG 2 was started and quick ly reached compliance with the emission limits (ppm) by 08:00. At 08:00, CTG 3 was st arted 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 NO x 

# 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 NO x



## 8 of 13 High Desert Power Project Draft AAQIR/February 2010

# (See Appendix 2), which is lower than the su m of the individual emission and duration limits for each turbine (10,623 lbs CO and 549 lbs NO x 

# 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 NO x 

# 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 re quested that EPA rely on the May 28, 2009 startup sequence for the CO cold start emissi on 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 NO x 

# and CO emissions from the warming turbine November 2008 and May 2009 alternative startup demons trations (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 NO x 

# and CO, and determined that cold startup emission limits of 235 lb NO x 

# /event and 4394 lb CO/event over a 9.5 hour duration are appropriate for the warming turbine under an alternative startup sc enario. For the two secondary turbines that are not used to warm the steam components, emission limits of 138 lb NO x 

# /event and 2391 lb CO/event over 1.9 hour duration are appropriate. The NOx emission limit for the secondary turbin es are equivalent to the hot start NO x 

# limits under normal startup conditions, and the CO emis sion 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 NO x 

# /event and 9176 lb CO/event ove r a 13.3 hour duration) are lower than the currently permitted startup emission limit s using all 3 turbines in cold start mode (549 lb NO x 

# /event and 10,623 lb CO/event over 13.5 hour duration). Because the total emissions and duration from the alternative co ld startup scenario are lower than the sum of the individual CTG emission and durati on 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 addi tional modeling to ensure compliance with the NAAQS for CO or NO 2 

# is required because modeling in cluded with the initial PSD permit application already included the startu p/shutdown emissions at the permitted level.

Therefore, EPA added new Condition X.E.3.d fo r the alternative cold startup scenario, including NO x 

# 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 NO x 

# and CO emission and duration limits for the turbine used to warm the components of the steam turbine generator (“warming turb ine”) shall not exceed 235 lb NO x 

# /event, 4394 lb CO/event, and 9.5 hours duration. The NO x 

# and CO emission and duration limits for the

9 of 13 High Desert Power Project Draft AAQIR/February 2010

# other two CTGs shall not exceed the 138 lb NO x 

# /event, 2391 lb CO/event, and 1.9 hours duration.

Request 2 HDPP has requested that the term “equipmen t” in Condition X.E.3.a be changed to “facility”. Condition X.E.3.a pertains to st artup and shutdown duration limits for each turbine train unit. Since the st artup/shutdown applie s per turbine train, replacing the term “equipment” with “facility” is not appr opriate, and EPA will not modify Condition X.E.3.a.

Request 3 HDPP requested that the durati on 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 tu rbine, consistent with the Distri ct Title V Operating Permit. In the April 6, 2004 request for permit revisions, HD PP 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 D ecember 5, 2007 letter to EPA, that occasional “turbine trips” during cold start require immediate shutdow n of the turbine to avoid system damage. These turbine trips occur with in minutes of the indi vidual turbine startup, and result in the inappropriate re-categorizati on of the turbine’s start up as a hot start. In the existing PSD permit, a cold start is define d 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 precedin g 8 hours. Note that cold starts are permitted for 4.5 hours, whereas ho t 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 NO x 

# 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 NO x 

# remained below the PSD permit S/S per turbine limits a nd within the S/S dura tion limits, however during the turbine trip scenario, CTG 3, wh ich had not tripped, was shutdown and restarted in order to comply with its pe rmitted 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 unnecessa ry wear and tear to the equipment.

To our knowledge, EPA has not included allowa nces for turbine trips into PSD permits. Although EPA recognizes HDPP’s concerns rega rding turbine trips, EPA believes that the S/S durations are components of the or iginal BACT determination for S/S, and removal of the duration limits, combined w ith a maximum daily limit, could indirectly

10 of 13 High Desert Power Project Draft AAQIR/February 2010

# provide an automatic exemption for excess emissions. Per EPA policy, automatic exemptions for excess emission during st artup and shutdown periods cannot be reconciled with the directives of the CAA 1 

# . 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 defi ne 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 NO x 

# and CO limits on a ppm basis, but stack volumetric flow is required to confirm compliance with the NO x 

# 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 th e appropriate parts of EPA Method 19.

Request 5 The original PSD permit issued in 2001 provi ded 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 conditi ons pertaining to the 2G configuration (Conditions X.E.1 and 2) be deleted from th e 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 Condi tion X.E.3.a be revised to replace “base load” with “normal operating lo ad” 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.

11 of 13 High Desert Power Project Draft AAQIR/February 2010

# Request 7 Condition X.G.2.a requires use of EPA Methods 1-4 and 7E for NO x 

# performance tests. HDPP has requested that EPA Methods 19 a nd 20 be added to Condition X.G.2.a. Since Methods 19 and 20 require use of Method 7E to determine NO x 

# concentrations in ppm (converted to lb/scf for Method 19), and Methods 19 and 20 are EPA Test Methods for NO x 

# , EPA will revise Condition X.G.2.a to state that performance tests for NO x 

# 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 Ap ril 6, 2004 letter to EPA refe rs 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 re ference procedures from Method 7E). EPA Methods 19 and 20 do not specifically discuss CO, however, since these methods are calculation methods to c onvert 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 usi ng 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 th at any benefit or improved clarity results from deleting the requested conditions. By maintaining all applicable conditions and requirements in the PSD permit, the documen t 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 NO x 

# 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 calibrati on drift tests and rela tive accuracy test audits (RATA). In addition to annual te sting and calibration of the CEMS for NO x 

# and CO, Conditions X.G.1 and 2 requires annual performance tests for CO and NO x 

# using EPA Test Methods 1-4, and 10 or 7E, for CO and NO x 

# , respectively. HDPP is currently requesting that the frequency of the perfor mance test requirement be reduced from annually to every five years. HDPP stat es that the continuous monitoring for NO x 

# and CO using CEMS, and the annual CEMS RATAs are sufficient to ensure compliance with the NO x 

# and CO emission limits.

12 of 13 High Desert Power Project Draft AAQIR/February 2010

## 13 of 13 High Desert Power Project Draft AAQIR/February 2010 

# EPA agrees that the use a nd annual testing of the NO x 

# and CO CEMS are adequate to ensure compliance with the NO x 

# and CO emission limits. Because the CEMS provide continuous emission information that are mon itored, recorded, and reported to EPA, the NO x 

# and CO CEMS provide a more complete compliance indicator than performance tests that occur annually. EPA changed Cond ition X.G.1 to require performance tests every five years, but added a statement th at 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 be st 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 proj ect, because the project wi ll not result in a physical modification to the facility, EPA has conclude d that this project wi ll 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 a pplicant, 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

1044 N 115 St 

## Permits Ottice Air-3

. 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. EPA, 

# Region 9 

# U.S. Environmental Protection A . 75 Hawthorne Street gency

- AIr Division
San Francisco, CA 94105-3901



# RE:

# Stea~ !urbine Cold Start Report Overnight Courier

# ~:g~I~lstratipve Order on Consent R9-2009-002 esert ower Project, 

# LLc

Dear Ms. 

# Jordan:

In accordance with Section IV 

## of the 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 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.

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 NO x 

## and CO in the units of pounds per hour and average ppm (adjusted to 15% O 2 ) 

## 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.

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 of April 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..-sDate 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 3Date 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 2High Desert Cold start on November 2, 2008 - Alternative Startup DemonstrationSteady state emission limits: CO = 4 pm; NOx = 2.5 ppmbegins compliance with steady state limitUnit 1 CTUnit 2Unit 3HourCO lb/hrCO ppmNOx lb/hrNOx ppmMWCO lb/hrCO ppmNOx lb/hrNOx ppmMWCO lb/hrCO ppmNOx lb/hrNOx ppmMW0:000.18.54.86.5000000180.81295.16.25.90turbine1:00280.6217.568.432.3160000000000trip?2:00304.2196.222.18.732.500000000003:00297.2191.418732.800000000004:00300.7191.218.97.334.400000000005:00271165.516.86.239.6255.51996.11611.40000006:00276.9168.7196.940.1356.725673.332.123.8000007:00134.369.517.25.362115.147.335.89.190.2000008:003714.110.42.697.50011.62.4115.1170.21917.114.912.20turbine9:000011.72.5114.70011.52.3114.900000trip?10:000011.72.5114.70011.52.4115123.9459.525.5192.211:000011.72.4114.40011.52.4114.7478.323319.25.76612:0000112.3123.70012.32.4124.40016.63.4125.313:000014.92.3147.50014.62.4150.10014.82.5151.214:000014.22.4144.70014.12.4146.90014.32.3148.215:000014.42.4147.50014.32.4149.90014.52.4151.516:000015.92.4149.60015.52.4152.20015.32.4153.717:000016.32.4151.20015.82.4154.30015.42.4156.418:000016.32.41520015.92.4155.50015.12.4157.619:000016.32.4152.90015.82.4156.100162.4158.120:000015.82.4153.50015.32.4156.80015.62.4158.621:0000162.4153.80015.52.4157.20015.92.415922:000013.22.4130.50013.12.41320013.32.4133.923:000011.82.4113.60011.62.4113.70011.82.4116CONOxCONOxCONOxsum ofemissions untilunit complieswith limit1902195.6727.3125.1772.476.2Sum over 14hours for 3 units3401.7396.9Requestedpower blocklimit10,623549limit235Alternative 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/eventCold start: CO = 3541 lb/event, NOx = 183 lb/eventCT2/CT3: 2 hour startup duration; CO lb/event limit: 927 lb/event; NOx lb/event limit: 92 lb/eventHot Start: CO = 3729 lb/event; NOx = 138 lb/eventTotal Cold start time for all 3 turbines not to exceed 14 hours?sum of all 3CO4144lb/eventNOx419lb/eventcreated 8/26/09