,
 

--

-'­

~@

HIGH DESERT
 

POWER PRO.JECT LLC
 _IJ .... 

April 6. 2004 

Mr. Gerardo Rios 

United States Environmental Proteclion Agency, Region IX 

75 Hawthorne Street 

San Francisco, CA 94105 

Subject:	 Proposed Revisions/Administrative ChangeS 10 Conditions In PSD Pennit NSR 

4-4-4 SE 98-I)f for H]qh Desert Pqwer ProJect. LLC 

Dear Mr. Rios: 

- High Desert Power Project, LLC (KHDPP") is submitting this proposed revision to the Prevention of 

Significant Deterioration (PSO) Permit (No. NSR 4-4-4 SE 98-01)· for the High Desert Power 

Project located in Victorville. California. As detailed in the attached pages, this application 

consists of tI1e foRowing revisions: 

•	 eliminating the duration of startup events and replacing u,e per combustion turbine startup 

and shutdown emission limits with emission limits for the total power block (three 

combustion turbines and one steam turbine) in Condition X-E-3; 

•	 addition of, a daily Hmit for CO in lieu of the startup duration limit; and 

•	 minor administrative, changes to Conditions X-D-1, X-E-1, and X-E-2. . 

As demonstrated in ttis appWcation, the proposed revisions will not result in an increase to the 

current startup emission limits or have an adverse impact on ambient air quality. The proposed 

administrative changes do nat affect compliance with applicable rules and regulations. 

Accordingly, HDPP requests that EPA expedite the review of this appUeation. 

i 

Similar requests to implement the above proposed changes have been submitted under separate 

cover to the CEC and MDAQMD. , 

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In an effort to expedite the revisions. we will contact you next week to make arrangements for a 

phone conference to review and answer any questions you may have on our proposed revisions. 
-. 

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In the meantime, should you have any questions or need additional information regarding this 

submittal, please contact me at (760) 530-2312, Sara Head of ENSR at (805) 388-3775 or Ramiro 

Garcia at (949)425-4755. 'i 

Sincerely, I 

Antonio 

4~,£/ D. Penna Jr. 

Plant Engineer I Envtronmental Manager 

High ,Desert Power Project, LLC 

cc:	 Mr. Alan De Salvio 

Mojave Desert Air QualitY Management District 

14306 Park Avenue I 

Victorville. CA 92392-2310 

M'. Steve Munro
 

Compliance Project Manager
 

California Energy Commission
 

15169th Street. MS 2000
 

Sacramento, CA 95814-5512
 

Ramlro Garcia, Constellation Power 

sara Head, ENSR 

Project File: 1.1.1 (Permit Application) 
" ,

·_··_CJ . ••••••.•••• --~ •• ,•••• , 

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DESCRIPTION OF PROPOSED REVISIONS 

I 

A Proposed Administrative Changes ofConditionX-E-3 Related to Stal'tllR 

The main power producti~n equipment at HDPP consists of three SiemensJWestinghouse 

combustion turbine generators (CTGs) and one Toshiba steam turbine generator (STG). HDPP I 

has determined that addiliQ[lal",time"0Y8f'·whahvBs"8sstJmed"iR-.the·ariginal"pertnit"spplication is 

neededt~ startup . the .eTGs. . In a comblned-cyde system, bringing a power block online is a

complicated process. The startup sequence consists of multiple steps in which the equipment is 

"ramped up" to normal operating conditions. This ramp-up period consists of various gas turbine 

speed and load conditions.1 Durtng the ramp-up period, the heat recovery steam generators 

(HRSGs), steam drums. steam turbine, steam piping and emissions.control equipment are heated 

and brought to stable operating. conditions. During a typical startup, one eTG is started and 

ramped up to low load where it is held until the HRSG and steam system reach a manufacturerspecified temperature to p~vent equipment damage and ensure safe operation according to 

manufacturer's procedures. I Then, the second and third CTGs are started and go through a 

similar process. Additionally, the time needed to bring the units on-line can vary based on site 

conditions,. time elapsed since last operated. and external factors such as CaI-lSO Of, DWR 

restrictions for putting power into the grid. I ' 

The original application material sUbmitted for the project addressed startup and' shutdown 

emissions and durations. These parameters were best engineering estimates at that time and 

were derived from a 2 x 1 configuration assuming generic F-Class eTGs and STG. HDPP was 

aaually built to include three Westinghouse CTGs combined with a Toshiba STG. Limited actual 

operations to date have shown that the as-built configuration results in significantly longer duration 

startup sequenceS from those estimated in the original application. 

I I 

The proposed condition changeS should be processed as administrative permit revisions. The 

changes will not result in any increase in air emissions (or the emission of additional pollutants) 

from what Was presented in HDPP's original permit application or what is allowed in the eXisting 

permit. In addition, the dtanges will not affect the facility's abHity to comply with ambient air 

quality standards, as discussed later in this attachment. I 

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Current Emission and Duration Limits , 

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Table 1 summariZes the startup and shutdown emission limits and durations from HDPP's existing 

PSD permit Note that the. current pennit only pro'IIides the hourty emission limits during normal 

operation on and the startup and shutdown Umits on a pound per event basis for each CTG. 

I 

1 

'., .•.••• _ ;.. ~.:.., ._.1" . 
._-_._.•._-_.._­ '--_._-.' 

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Table 1 II 

Current HDPP Startup and Shutdown Umlts Per eTG 

Event NOIt EmisSions CO Emissions Duration 

(lb/event) (Iblevent) I (hours) : 

Cold Start 183 3,541 I 4.5 I 

Warm start 168 , 3,596 I 2.6 

Hot Start 138 3,729 I 1.9 

Shutdo1Nn 97 239 I 1.0 

I 

, 

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, 

Change from Per CTG Emisslon Limits to Power Block EmiS§ion Limits 

. ,I 

Since the current permit does not limit the number of CTGs that could be started simultaneously, 

and the modeling analysis was.~J1orJl\Eld,,~~ on all three eTGs with maximum hourly 

emission rates, aC&tlbimid':~~r bbCk emiSsion rateYlOUld nOt Change the ambient air 'quality, 

impact analysis performed as part of the original application. COrilbii'ffritrti'i'i)er:'eferITmttS"imo 

~tilbCkii""ls \You'd provide HDPP with needed flexibaity during the actUal startup sequEmce. 

In that manner. the first CTG, 'Which is ramped up the most slowly, might emit slightly more than 

its current IbJevent limit, but then the other twoCTGs would emit less. The combined total would 

never be more than was assumed for the air quality modeung analyses (see impact analysis 

. below). Rather than having duration limits. HDPP proposes to incorporate a daily emission Umit 

for CO of 8,072 IbIday that is consistent with HDPP's Mojave Desert Air Quality Management 

District (MDAQMD) permit. The daily limit will provide additional assurance that HOPI? 'NOuld not 

adversely impact air quaUty, as d~ussed in the air quality impact analysis later in this attad;tment. 

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The pro~d re'Jised startup and shutdown event emission limits for the combined power block . 

are shown in Table 2 (we-'tiave~simpty ITfUttiPIledthe per turbine emission limits .by 'three). As 

indicated in the air quality impact analysis, no durations for these events are considered 

necessary. i I 

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Note that other combined-<;ycle power plant penniis have. been Issued within EPA Region IX. 

which have combined startup emission limits for the power block. Examples include the Sunrise 

and Elk HiUs Power Projects in the San Joaqlin Valley Air Pollution Control District. Also, permits 

for Arlington Valley Energy and 1he Mesquite Gerilratlrg Station. in .Arizona have recently been 

issued which indude a revision from startup emission limits per combUstion turbine tp limits per 

power block. These permits inckJded review and comment by EPA Region IX staff prior to • i ISSuance. I 

2 
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	 ct
 . . .•. •.. . .. . . .. ..J.	 .••.••.. _"~' •.' ... _"." ••••• __ .. \ •. '_ .• __ ""'" r·" • ...........i ..•....;.:.......... _ ....._\_.-.· ......i~c.n:.t.'i~·~
 

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Table 2
 

Proposed Modified HDPP Startup and Shutdown Limit per Power
 

I 

I 

Block1 

I 

Event NO. emissions CO Emissions 

I (Ib/event) (Ible'lent) 

Cold Start I 

I 

Warm Start I 

I 

Hot Start I

I 

I 

I 

Shutdown 

I 549 

I 504 I 

414 

I 291 

10,623 

10,788 

11,187 

I 

717 

1. Power block consists of three combUstion turbines and one steam turbine 

B. ProllO§§9Adminiftr8tlve Changes to Conditions X-D-1.fQ X-E-1 andX-E·2 I I 

The proposed administrative changes to these conditions are described in detail in the next 

sedlon. The changes include deleting the requirement to have a continuous mon~ring system to 

measure stack gas volumetric flow rates and deleting references to the 2G Configuration since the 

3F Configuration was actually buill I 

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Changes to Conditions i "I 

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Proposed changes to the following Conditions are provided with new text shown undertints1 and 

deleted text Is shown as stFiketl'lleYg~. I The reason for the requested changes Is provtded I'"	 . 

foUowing the proposed conditioli language, except the proposed change to startup conditions, 

which was discussed in the previous section. I I I	 I 

1. Administrative Change to Condition X~[)"1.c

X-D-1.c	 A GeRtiAUQY8 ~9RiteFiRS system te measure staGk 8186 voltImetriG tlmol fates. The 

system shall FReet 

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EPA peFfer:manGe speGifisatieA& (40 CFR PaFt 52, AppeAElge ~. " 

3 
'-'1 Q' . . . _ "--'	 ....0 _ .... " __ •• 0 •••_.· ...__._•• ' .... ,'.. .. • .. __.,.~••_ .. 

.

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I II 

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X-E-1. The NOll emissions (calculated as NO:z) from each turbine train unit shall not exceed I	 .. I 

18.0 Iblhr fer the 3F aeRfigl:Jl'atieA er 24.55lS1hF fer tAEr 2G G9A1igYRHiSR (based on 

2.5ppmvd @ 15% ~, averaged over a one hour period).
 \
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X-E-2. The CO emissions from each turbine train unit shan not1exceed 17.53lb1hrfeFtRe 3'; 

I G9F1figYFati9A or 23.91 IQIIv fer the 2G G9RfigYr:atiSR (b~ on 4;0 ppmvd @ 15% ~,

I averaged over a 24hour period). " \ ' 

1 ' ,I 

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This request-wiD maintain consistency With the actual configuration installed at HDPP.
 

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3. Administrative Change to Condition X-E-3 Related to starlup I 

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We Jnderstand the tenn ~base load" to mean any normal operatind load, Which will typically be !	 I 'I 

between 70% and 100%. If there is room to interpret "base load" as meaning only 100% load, we 

suggJst replacing the words abase 1oad" with "nonnaloperating load.' 'I 

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X-E-3 , The emission limits in Condition X-E-1 and X..E-2 shall apply at all times to each 

II turbine train unit, except during startups and shutdowns c;lefined as follows: ,	 'I 1 

I 8. Startup shall be defined as the period begi~ning with ign~on and lasting until the 

8qiJipmeAt facirltv has reached ~ing permit limits. Cold startup means a startup 

I	 when the GeFFllM;tieA tl:lltliAe has not been in opetaoon during the preceding 

72 hours. Hot startup means a startup when the. 6QR'lsLMllien wFbine has been 

in operation dUring the preceding ahourS. Warm startup means a startup that is not 

a hot rx cold startup. Shutdown shalf be defined as the period beginning with the 

~nng of eqblipment the facilitx from ~8e 1_ normal operating load and lasting 

until fuel flow is comPletely off and combustion has ceased. . 

9. ~R81eAt aeA~6 8~all Ret e*eeeEl Jf9llewiAg <ilw18A&; 

i. CelEi &taRYp 4.8 heYF8 I 

ii. Wa~ staftYp 2.6 AeuF6 ! 

iii. H9t &taJtwp 1.9 I:looR;
 

i'.,. &RWl9\\'A 1,0 A9yr
 I 

I 

.be. Emissions dUring startup and shutdown', verified by CEMS, shall not exceed the -	 I

following:	 ' .. 

1 

PollUtant
 

I
 

I
 

NOx
 

!
 

Cold Startup (Ib) Wann Startup (Ib) Hot StartUP (Ib) Shutdown (lb) I I 

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:t&549 463-504 4-38-414 91-291 1 I 

I -,	 I I	 4 

-
«) ..............._ _.r _.
 .._ _ _8 __ _.._- -.'

__C_O 3i_4_1_1~O-,6-23-..-.--3-i-9&-1-0-'7-lH.!"'!"a _J ~1illZ I. J . CeRtigYFatieR 

~lll.Itant Cekt Stal:&Yp Os) ~Fm itaFlYp (19) Iofet itaFtYp ~s) ShYtG9\'~ (~)

NQK I 269 2-t& m 

co I 6890 I 

I W+ I 

288, 

: 

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4. IncorpolBte a Daily Umit , for CO in New Condition in X-E-4. 

X-E-4	 Duling each 24-hour period. beginning and ending at midnight. the GQ·emi§!!onstrom 

§act"turbine·train unit shall not exceed 8.072 Ibslday. 

As explained earlier, in i lieu of startup duration limits, HDPP proposes to incorporate a daily 

emission limit for CO of,8,072 Iblday that is consistent with HDPP's Mojave Desert PtJr Quality 

Management District (MDAQMD) permit. The daily limit will provide additional assurance that 

HDPP would not adverSeJY impad air quality, as discussed in the air quality impad analysis 

later in this attachment. i I 

5. Condition X-G-2-a.	 I I I , 

X-G-2-a Performance tests for the emissions of NOx shall be conduded using EPA ~ethods

1-4 or 19. 7E and/or 20. 

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X-G-2-b Performan~,~ests for the emissions of CO shaU be conctsd8d usirg EPA ~ethods

1-4 .2r...lll.(7E and/ot" 20. I . I 

'-..-. i I I

EPA aUows the use of anyone of the above reference methods. No. that reference methods 

19. 7E were specified as an allowable method in the initial Complianctt Test Protocol 

approved by MDAQMO and EPA. I I • 

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6. Delete Conditions I, II, X-D-2, 3 

Delete these condJ,s since they no longer 

constructionlcommissio':ling phase of the Project). 

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apply (i.e.. only applied d~I 

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the 

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IMPACT ANALYSIS OF PROPOSED REVISIONS 

! 

The Proposed revisions to Condition X-E-3 could potentially change some of the assumptions 

upon which the PSD permit was based. Therefore. an assessment of air quality impacts is 

5	 I
 
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,... -'~-'': ..:.. ... '-...... .;_......-.. .. ............e ..... .R·.. .. __ ..... ..... '-'.~ - 0 _.._,..


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Jed wi1h this ~.This analysis -Lthat J 01 the findings of the PSD 

permit are adVefSely affected by the proposed changes. Since the environmental impads of the 

project remain insignificant, the proposed revisions should be permitted. 

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The Potential air Quality impact implications of eliminating the duration of a startup and revising the 

emission "mits to a power block basis was evaluated. The peak emission rate for CO identified in 

HDPP's supplemental submission titled ·Revised Short Term Air Quality Impact Assessment" 

dated .November 1998 were reviewed. Table 3 summarizeS the emission rate that was modeled in 

that document to demonstrate compliance with the CO 1-hour and 8-hour Califomia Ambient Air 

Quality Standard (CMOS). 'I ' I 

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The 1-hour emission rate in Table 3 is morelhan the permitted Iblevent emission limits in Table 1. I I 

Since: the maximum event emission rates wtll not change, only ithe duration of the event, 

compliance with the 1-hour eo standards will not be affected. With respect to the 8-hoUr CO . , \ 

stand~rd, previous modeling assumed an &-hour average emiSsion rate of 979 Iblhr, or a total of 

7,8321b per a-hour period, for each turbine train unit. This emission rate is also mUch more than 

any worst-case 8-hour emission rate calculated using the current lbJ.event and duration limits In 

Table:1, and permitted ~normal operations" emission rates of 17.531blhr turbine train unit 

i \ I , Table 3 ,_I 

Startup Emission Rates Modeled for HDPP Pennitting I 

Pollutant Emission Rate Modeled Rate for i Modeled Peak 

(Averagfng (Ib1hr/CTG) 3 CTGs (Ib1hr) I Impact of CTGs 

Time) I (J19Im~

I CO (1-hour) I . 4,409 13,227 

I 

7,500 

I CO (8-hour) 979 I 

2,937 

I 

900 

II \ 

Table 4 summarizes the demonstration of compliance with the applicable air quality standards. A.s 

shown ,in Table 4, as long as ead1 eTG is in compliance with the existing Iblevent and proposed 

daily limit, HOPP emissions will remain lower than what was modeled (or purposes of determining 

compliance with ambient air quality standards. The ~mils on startup dkuon do not add any level 

protectiveness and are not a factor in the ambient air qUality impact analyses results modeled for 

HOPP.j \ . II . 

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Table" I I . 

Predicted hnpacts of Startup Emission Rates Modeled for HDPP PennlUing 

i I \ 

Pollutant Modeled Peak Background Total CAAQS NAAQS 

6
 
." " •• -...._:;'Ir..,,~.· .:; •• ;.. _l :. :",.','.•: _,.'..·.a- n.I ..'.'·.:.a. ......u..IItJ: ~~·~....-_..:.....·&,j"' .¥;..,;.:,.)o,I..i...:__~, ·..: ~~~:.x.·I _~:...;.a:r.:..'-I _.,:",·,··_ 10··..•· - ...:. - •.-: •.• ,•. .;: •.•.••• ,: _ ••• ' .•.••.•: ~..:...•.&..I:_•• \i.u.:._.:..~~

't" 

e 

-~

(Averaging 

. Time) . 

Impact of 3 CTGs 

(Jlg/m3) 

(J1SIIrn3) ()JIJ1m3

) (p.gfm3

) (J.LlIIm; 

CO (1-hour)1 7,500 9,200 16,700 . . 23000 , 40,000 

. CO (fHloUr)1 900 8,500 9,400 10,000 10,000 

1) BackgroUnd CO data based on ··1~1997 ambient dahffmrn VldoMll~AmargosaStreet·· 

monitor. . . 

- ···--~D regulations indudett.;reqUirement for an assessment of additional"impacts to air quality 

resulting from the proposed project. These Include impacts to PSD Class I areas. local impacts 

due to population and economic growth resuJtingfrom new construction, and impacts of pollutant 

emissions to soils and vegetation. Since there are no proposed inaeases in permitted emission 

limits, additional impact analySes to air quality should not be required.