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### ENGINEERING ANALYSIS / EVALUATION PROCESSED BY: Roy Olivare s REVIEWED BY:



### CPV SENTINEL , LLC; ADDENDUM TO THE DETERMINATION OF COMPLIANCE (DOC) ENGINEERING ANALYSIS
FOR A NEW 8 50 MW SIMPLE CYCLE P OWER PLANT

COMPANY NAME AND ADDRESS EQUIPMENT LOCATION

CPV Sentinel , LLC 62575 Power Line Rd.
55 Second Street Des ert Hot Springs, CA 92440
Suite 525
San Francisco , CA 94105 Contact: Mr. Mark Turner AQMD Facility ID : 152707

EQUIPMENT DESCRIPTION

Section H of the Facility Permit

Equipment ID
No. Connected To RECLAIM Source Type/ Monitoring Unit Emissions
And Re quirements Conditions

Process 1: INTERNAL COMBUSTION
System 1: GAS TURBINES, POWER GENERATION

GAS TURBINE, CTG 1, NATURAL GAS,
GENERAL ELECTRIC MODEL LM S100 PA

, SIMPLE CYCLE, 891.7 MMBTU/HR AT 72 DEGREES F WITH WATER INJECTION

,

WITH A/N 4 72139

GENERATOR, 10 3 MW D 1 C 3 NOX: MAJOR
SOURCE CO: 4 .0 PPMV

N ATURAL GAS (4) [Rule 1703 (a)(2)

- BACT]; CO:
2000 PPMV (5) [Rule 407]

NOX: 15 PPMV NATURAL GAS (8) [40CFR60 Subpart KKKK] ; NOX: 19 LB/MMCF (1) [Rule 2012]
NOX 12.26 LB/MM CF NATURAL GAS ( 1 )[Rule
2012 ] NOX 2.5 PPMV NATURAL GAS (4)[Rule
2005

- BACT

, Rule 1703 (a)(2)

- BACT]

VOC: 2.0 PPMV (4)[Rule 1303(a)(1 )

- BACT]

PM 10 : 0.01 GRAIN/DSCF (5A) [Rule 475]; PM 10 : 0.1 GRAIN/DSCF (5) [Rule 409]; PM 10 : 11 LB/HR (5B) [Rule 475] SOX : .0 6 lb/MMBTU (8) [40 CFR60 Subpart
KKKK ]; SO2 : (9) Acid
Rain Provisions A63.1, A63.2 A99.1, A99. 3

, A99. 5 , A99. 7

, A99.9 A195.1, A195.2, A195.3, A327.1, A443.1, B61.1, C1.1, C1. 3

, C1.6

, D12.1, D29.1, D29.2

, D29.3, D82.1, D82.2, E193.1, H23.1, I296.1, K40.1, K67.1

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### EQUIPMENT DESCRIPTION (continued)

Equipment ID
No. Connected To RECLAIM Source Type/ Monitoring Unit Emissions
And Requirements Conditions

Process 1: INTERNAL COMBUSTION
System 1 : GAS TURBINES POWER GENERATION

CO OXIDATION CATALY ST NO. 1

, BASF

, 150 CUBIC FEET OF TOTAL CATALYST
VOLUME
A/N: 472140 C 3 D1 C 4

SELECTIVE CATALYTIC REDUCTION
NO. 1

, CORMETECH CHMT

- 2

, WITH 812
CUBIC FEET OF TOTAL CATALYST VOLUME, LENGTH 11 FT 1 IN ; WIDTH : 2

FT 2 IN; HEIGHT 4 FT 2 IN;

WITH

NH3 INJECT ION GRID
A/N: 472140 C 4 S 6 C 3 NH3: 5.0 PPMV (4) [Rule 1303(a)(1)

- BACT] A195. 4
D12. 2
D12. 3
D12. 4
E179.1
E179.2

, E193.1

, E193.3

STACK NO. 1 , DIAMETER: 13 FT 6 IN

, HEIGHT: 90 FT

A/N: 472140 S 6 C 4

GAS TURBINE, CTG 2 , NATURAL GAS,
GENERAL ELECTRIC M ODEL LM S100PA

, SIMPLE CYCLE, 8 61.7 MMBTU/HR AT 72 DEGREES F WITH WATER INJECTION,

WITH A/N 472141

GENERATOR, 103 MW D 7 C 9 NOX: MAJOR
SOURCE CO: 4 .0 PPMV

NATURAL GAS (4) [Rule 1703 (a)(2)

- BACT]; CO: 2000
PPMV (5) [Rule 407]

NOX: 1 5 PPMV NATURAL GAS (8) [40CFR60 Subpart KKKK] ; NOX: 19 LB/MMCF (1) [Rule 2012] NOX 12.26 LB/MMCF NATURAL GAS ( 1 )[Rule 2012 ]
NOX 2.5 PPMV NATURAL GAS (4)[Rule
2005

- BACT

, Rule 1703 (a)(2)

- BACT]

VOC: 2.0 PPMV (4)[Rule 1303(a)(1)

- BACT]

PM 10 : 0.01 GRAIN/DSC F (5A) [Rule 475]; PM10 : 0.1 GRAIN/DSCF (5) [Rule 409]; PM 10 : 11 LB/HR (5B) [Rule 475

SOX : .06 lb/MMBTU (8) [40 CFR60 Subpart KKKK]; SO2 : (9) Acid
Rain Provisions A63.1, A63.2

, A99.1, A99.3, A99.5, A99.7,
A99.9 A195.1, A195.2, A195.3, A327.1, A443.1, B61.1, C1.1

, C1.3,
C1.6 , D12.1, D29.1, D29.2

, D29.3, D82.1, D82.2, E193.1, H23.1, I296.1, K40.1, K67.1

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### EQUIPMENT DESCRIPTION (continued)

Equipment ID
No. Connected To RECLAIM Source Type/ Monitoring Unit Emissions
And Requirements Conditions

Process 1 : INTERNAL COMBUSTION
System 1 : GAS TURBINES POWER GENERATION

CO OXIDATION CATALYST NO. 2

, BASF

, 150 CUBIC FEET OF TOTAL CATALYST
VOLUME
A/N: 472142 C 9 D 7 C 10

SELECTIVE CATALYTIC REDUCTION
NO. 2

, CORMETECH CHMT

- 2, WITH 812
CUBIC FEET OF TOTAL CATALYST VOLUME, LENGTH 11 FT 1 IN ; WIDTH : 2 FT 2 IN; HEIGHT 4 FT 2 IN;;

WITH

NH3 INJECTION GRID
A/N: 472142 C10 S12 C9 NH3: 5.0 PPMV (4) [Rule 1303(a)(1)

- BACT] A195. 4
D12. 2
D12. 3
D12. 4
E179.1
E179.2

, E193.1

, E193.3

STACK NO. 2 , DIAMETER: 13 FT 6 IN

, HEIGHT: 90 FT

A/N: 472142 S 12 C 10

GAS TURBINE, CTG

. 3 , NATURAL GAS,
GENERAL ELECTRIC MODEL LM S100PA

, SIMPLE CYCLE, 8 91.7 MMBTU/HR AT 72
DEGREES F WITH WATER INJECTION,

WITH
A/N 472143

GENERATOR, 103 MW D 13 C 14 NOX: MAJOR
S OURCE CO: 4 .0 PPMV

NATURAL GAS (4) [Rule 1703 (a)(2)

- BACT]; CO: 2000
PPMV (5) [Rule 407]

NOX: 15 PPMV NATURAL GAS (8) [40CFR60 Subpart KKKK] ; NOX: 19 LB/MMCF (1) [Rule 2012] NOX 12.26 LB/MMCF NATURAL GAS ( 1 )[Rule 2012 ]
NOX 2.5 PPMV NATURAL GAS (4)[Rul e 2005

- BACT

, Rule 1703 (a)(2)

- BACT]

VOC: 2.0 PPMV (4)[Rule 1303(a)(1)

- BACT]

PM 10 : 0.01 GRAIN/DSCF (5A) [Rule 475]; PM10 : 0.1 GRAIN/DSCF (5) [Rule 409]; PM 10 : 11 LB/HR (5B) [Rule 475]

SOX : .06 lb/MMBTU (8) [40 CFR60 Subpart KKKK]; SO2 : (9) Acid
Rain Pro visions A63.1, A63.2

, A99.1, A99.3, A99.5, A99.7,
A99.9 A195.1, A195.2, A195.3, A327.1, A443.1, B61.1, C1.1, C1.3,
C1.6 , D12.1, D29.1, D29.2

, D29.3, D82.1, D82.2, E193.1, H23.1, I296.1, K40.1, K67.1

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### ENGINEERING ANALYSIS / EVALUATION PROCESSED BY: Roy Olivare s REVIEWED BY:



### Equipment Description (Continued )

Equipment ID
No. Connected To RECLAIM Source Type/ Monitoring Unit Emissions
And Requirements Conditions

Process 1: INTERNAL COMBUSTION
System 1 : GAS TURBINES POWER GENERATION

CO OXIDATION CATALYST NO. 3

, BASF

, 150 CUBIC FEET OF TOTAL CATALYST
VOLUME
A/N: 472145 C 15 D 13 C1 6

SELECTIVE CATALYTIC REDUCTION
NO. 3

, C CORMETECH CHMT

- 2, WITH

812 CUBIC FEET OF TOTAL CATALYST VOLUME, LENGTH 11 FT 1 IN ; WIDTH : 2 FT 2 IN; HEIGHT 4 FT 2 IN;

WITH

NH3 INJECTION GRID
A/N: 472145 C16 S18 C15 NH3: 5.0 PPMV (4) [ Rule 1303(a)(1)

- BACT] A195. 4
D12. 2
D12. 3
D12. 4
E179.1
E179.2

, E193.1

, E193.3

STACK NO. 3 , DIAMETER: 13 FT 6 IN

, HEIGHT: 90 FT

A/N: 472145 S18 C16

GAS TURBINE, CTG 4 , NATURAL GAS,
GENERAL ELECTRIC MODEL LM S100PA

, SIMPLE CYCLE , 8 91.7 MMBTU/HR AT 72
DEGREES F , WITH WATER INJECTION,

WITH
A/N 472147

GENERATOR, 103 MW D 19 C 21 NOX: MAJOR
SOURCE CO: 4 .0 PPMV

NATURAL GAS (4) [Rule 1703 (a)(2)

- BACT]; CO: 2000
PPMV (5) [Rule 407]

NOX: 15 PPMV NATURAL GAS (8) [40CFR60 Subpart KKKK] ; NOX: 19 LB/MMCF (1) [Rule 2012] NOX 12.26 LB/MMCF NATURAL GAS ( 1 )[Rule 2012 ]
NOX 2.5 PPMV NATURAL GAS (4)[Rule
2005

- BACT

, Rule 1703 (a)(2)

- BACT]

VOC: 2.0 PPMV (4)[Rule 1303(a)(1)

- BACT]

PM 10 : 0.01 GRAIN/DSCF (5A) [Rule 475]; PM10 : 0.1 GRAIN/DSCF (5) [Rule 409] ; PM 10 : 11 LB/HR (5B) [Rule 475]

SOX : .06 lb/MMBTU (8) [40 CFR60 Subpart KKKK]; SO2 : (9) Acid
Rain Provisions A63.1, A63.2

, A99.1, A99.3, A99.5, A99.7,
A99.9 A195.1, A195.2, A195.3, A327.1, A443.1, B61.1, C1.1, C1.3,
C1.6 , D12.1, D29.1, D29.2

, D29.3, D82.1,
D82. 2, E193.1, H23.1, I296.1, K40.1, K67.1

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### ENGINEERING ANALYSIS / EVALUATION PROCESSED BY: Roy Olivare s REVIEWED BY:



### Equipment Description (Continued )

Equipment ID
No. Connected To RECLAIM Source Type/ Monitoring Unit Emissions
And Requirements Conditions

Process 1: INTERNAL COMBUSTION
System 1 : GAS TURBIN ES POWER GENERATION

CO OXIDATION CATALYST NO. 4

, BASF

, 150 CUBIC FEET OF TOTAL CATALYST
VOLUME
A/N: 472149 C 21 D 19 C 22

SELECTIVE CATALYTIC REDUCTION
NO. 4

, CORMETECH CHMT

- 2, WITH 812
CUBIC FEET OF TOTAL CATALYST VOLUME, LENGTH 11 FT 1 IN ; WIDTH : 2 FT 2 IN; HEIGHT 4 FT 2 IN;

WITH

NH3 INJECTION GRID
A/N: 472149 C22 S24 C21 NH3: 5.0 PPMV (4) [Rule 1303(a)(1)

- BACT] A195. 4
D12. 2
D12. 3
D12. 4
E179.1
E179.2

, E193.1

, E193.3

STACK NO. 4 , DIAMETER: 13 FT 6 IN

, HEIGHT: 90 FT

A/N: 472149 S 24 C 22

GAS TURBINE, CTG

. 5 , NATURAL GAS,
GENERAL ELECTRIC MODEL LM S100PA

, SIMPLE CYCLE, 8 91.7 MMBTU/HR AT 72
DEGREES F WITH WATER INJECTION,

WITH
A/N 472150

GENERATOR, 103 MW D 25 C 27 NOX: MAJOR
SOURCE CO: 4 .0 PPMV

NATURAL GAS (4) [Rule 1703 (a)(2)

- BACT]; CO: 2000
PPMV (5) [Rule 407]

NOX: 15 PPMV NATURAL GAS (8) [40CFR60 Subpart KKKK] ; NOX: 19 LB/MMCF (1) [Rule 2012] NOX 12.26 LB/MMCF NATURAL GAS ( 1 )[Rule 2012 ]
NOX 2.5 PPMV NATURAL GAS (4)[Rule
2005

- BACT

, Rule 1703 (a)(2)

- BACT]

VOC: 2.0 PPMV (4 )[Rule 1303(a)(1)

- BACT]

PM 10 : 0.01 GRAIN/DSCF (5A) [Rule 475]; PM10 : 0.1 GRAIN/DSCF (5) [Rule 409]; PM 10 : 11 LB/HR (5B) [Rule 475 ]

SOX : .06 lb/MMBTU (8) [40 CFR60 Subpart KKKK]; SO2 : (9) Acid
Rain Provisions A63.1, A63.2

, A99.1, A99.3, A99.5, A99.7,
A99.9 A195. 1, A195.2, A195.3, A327.1, A443.1, B61.1, C1.1, C1.3,
C1.6 , D12.1, D29.1, D29.2

, D29.3, D82.1, D82.2, E193.1, H23.1, I296.1, K40.1, K67.1

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### ENGINEERING ANALYSIS / EVALUATION PROCESSED BY: Roy Olivare s REVIEWED BY:



### Equipment Description (Continued )

Equipment ID
No. Connected To RECLAIM Source Type/ Monitoring Unit Emis sions
And Requirements Conditions

Process 1: INTERNAL COMBUSTION
System 1 : GAS TURBINES, POWER GENERATION

CO OXIDATION CATALYST NO. 5

, BASF

, 150 CUBIC FEET OF TOTAL CATALYST
VOLUME
A/N: 472153 C 27 D 25 C 28

SELECTIVE CATALYTIC REDUCTION
NO. 5

, CORMETECH CHMT

- 2, WITH 812
CUBIC FEET OF TOTAL CATALYST VOLUME, LENGTH 11 FT 1 IN ; WIDTH : 2 FT 2 IN; HEIGHT 4 FT 2 IN;

WITH

NH3 INJECTION GRID
A/N: 472153 C28 S30 C27 NH3: 5.0 PPMV (4) [Rule 1303(a)(1)

- BACT] A195. 4
D12. 2
D12. 3
D12. 4
E179. 1
E179.2

, E193.1

, E193.3

STACK NO. 5 , DIAMETER: 13 FT 6 IN

, HEIGHT: 90 FT

A/N: 472153 S 30 C 28

GAS TURBINE, CTG

. 6 , NATURAL GAS,
GENERAL ELECTRIC MODEL LM S100PA

, SIMPLE CYCLE, 8 91.7 MMBTU/HR AT 72
DEGREES F WITH WATER INJECTION,

WITH
A/N 472154

GENERATOR, 103 MW D 31 C 33 NOX: MAJOR
SOURCE CO: 4 .0 PPMV

NATURAL GAS (4) [Rule 1703 (a)(2)

- BACT]; CO: 2000
PPMV (5) [Rule 407]

NOX: 15 PPMV NATURAL GAS (8) [40CFR60 Subpart KKKK] ; NOX: 19 LB/MMCF (1) [Rule 2012] NOX 12.26 LB/MMCF NATURAL GAS ( 1 )[Rule 2012 ]
NOX 2.5 PPMV NATURAL GAS (4)[Rule
2005

- BACT

, Rule 1703 (a)(2)

- BACT]

VOC: 2.0 PPMV (4)[Rule 1303(a)(1)

- BACT]

PM 10 : 0.01 GRAIN/DSCF (5A) [Rule 475]; PM10 : 0.1 GRAIN/DSCF (5) [Rule 409]; PM 10 : 11 LB/HR (5B) [Rule 475]

SOX : .06 lb/MMBTU (8) [40 CFR60 Subpart KKKK]; SO2 : (9) Acid
Rain Provisions A63.1, A63.2

, A99.1, A99.3, A99.5, A99.7,
A99.9 A195.1, A195.2, A195.3, A327.1, A443.1, B61.1, C1.1, C1.3,
C1.6 , D12.1, D29.1, D29.2

, D29.3, D82.1, D82.2, E193.1, H23.1, I296.1, K40.1, K67.1

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### Equi pment Description (Continued )

Equipment ID
No. Connected To RECLAIM Source Type/ Monitoring Unit Emissions
And Requirements Conditions

Process 1: INTERNAL COMBUSTION
System 1 : GAS TURBINES, POWER GENERATION

CO OXIDATION CATALYST NO. 6

, BA SF

, 150 CUBIC FEET OF TOTAL CATALYST
VOLUME
A/N: 472155 C 33 D 31 C21

SELECTIVE CATALYTIC REDUCTION
NO. 6

, CORMETECH CHMT

- 2, WITH 812
CUBIC FEET OF TOTAL CATALYST VOLUME, LENGTH 11 FT 1 IN ; WIDTH : 2 FT 2 IN; HEIGHT 4 FT 2 IN;;

WITH

NH3 INJECTION GRID
A/N: 472155 C34 S36 C33 NH3: 5.0 PPMV (4) [Rule 1303(a)(1)

- BACT] A195. 4
D12. 2
D12. 3
D12. 4
E179.1
E179.2

, E193.1

, E193.3

STACK NO. 6 , DIAMETER: 13 FT 6 IN

, HEIGHT: 90 FT

A/N: 472155 S 36 C 34

GAS TURBINE, CTG

. 7 , NATURAL GAS,
GENERAL ELECTRIC MOD EL LM S100PA

, SIMPLE CYCLE, 8 91.7 MMBTU/HR AT 72
DEGREES F WITH WATER INJECTION,

WITH
A/N 472156

GENERATOR, 103 MW D 37 C 39 NOX: MAJOR
SOURCE CO: 4 .0 PPMV

NATURAL GAS (4) [Rule 1703 (a)(2)

- BACT]; CO: 2000
PPMV (5) [Rule 407]

NOX: 15 PPMV
NA TURAL GAS (8) [40CFR60 Subpart KKKK] ; NOX: 19 LB/MMCF (1) [Rule 2012] NOX 12.26 LB/MMCF NATURAL GAS ( 1 )[Rule 2012 ]
NOX 2.5 PPMV NATURAL GAS (4)[Rule
2005

- BACT

, Rule 1703 (a)(2)

- BACT]

VOC: 2.0 PPMV (4)[Rule 1303(a)(1)

- BACT]

PM 10 : 0.01 GRAIN/DSCF (5A) [R ule 475]; PM10 : 0.1 GRAIN/DSCF (5) [Rule 409]; PM 10 : 11 LB/HR (5B) [Rule 475]

SOX : .06 lb/MMBTU (8) [40 CFR60 Subpart KKKK]; SO2 : (9) Acid
Rain Provisions A63.1, A63.2

, A99.1, A99.3, A99.5, A99.7,
A99.9 A195.1, A195.2, A195.3, A327.1, A443.1, B61.1, C1.1, C1.3,
C 1.6 , D12.1, D29.1, D29.2

, D29.3, D82.1, D82.2, E193.1, H23.1, I296.1, K40.1, K67.1

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### ENGINEERING ANALYSIS / EVALUATION PROCESSED BY: Roy Olivare s REVIEWED BY:



### Equipment Description (Continued )

Equipment ID
No. Connected To RECLAIM Source Type/ Monitoring Unit Emissions
And Requirements Conditions

Process 1: INT ERNAL COMBUSTION
System 1 : GAS TURBINES, POWER GENERATION

CO OXIDATION CATALYST NO. 7

, BASF

, 150 CUBIC FEET OF TOTAL CATALYST
VOLUME
A/N: 472157 C 39 D 37 C 40

SELECTIVE CATALYTIC REDUCTION
NO. 7

, CORMETECH CHMT

- 2, WITH 812
CUBIC FEET OF TOT AL CATALYST VOLUME, LENGTH 11 FT 1 IN ; WIDTH : 2 FT 2 IN; HEIGHT 4 FT 2 IN

WITH

NH3 INJECTION GRID
A/N: 472157 C40 S42 C39 NH3: 5.0 PPMV (4) [Rule 1303(a)(1)

- BACT] A195. 4
D12. 2
D12. 3
D12. 4
E179.1
E179.2

, E193.1

, E193.3

STACK NO. 7 , DIAMETER: 13 FT 6 IN

, HEIGHT: 90 FT

A/N: 472157 S 42 C 40

GAS TURBINE, CTG

. 8 , NATURAL GAS,
GENERAL ELECTRIC MODEL LM S100PA

, SIMPLE CYCLE, 8 91.7 MMBTU/HR AT 72
DEGREES F WITH WATER INJECTION,

WITH
A/N 472158

GENERATOR, 103 MW D 43 C 45 NOX: MAJOR
SOURCE CO: 4 .0 PPMV

NATURAL GAS (4) [Rule 1703 (a)(2)

- BACT]; CO: 2000
PPMV (5) [Rule 407]

NOX: 15 PPMV NATURAL GAS (8) [40CFR60 Subpart KKKK] ; NOX: 19 LB/MMCF (1) [Rule 2012] NOX 12.26 LB/MMCF NATURAL GAS ( 1 )[Rule 2012 ]
NOX 2.5 PPMV NATURAL GAS (4)[Rule
2005

- BACT

, Rule 1703 (a)(2)

- BACT]

VOC: 2.0 PPMV (4)[Rule 1303(a)(1)

- BACT]

PM 10 : 0.01 GRAIN/DSCF (5A) [Rule 475]; PM10 : 0.1 GRAIN/DSCF (5) [Rule 409]; PM 10 : 11 LB/HR (5B) [Rule 475] SOX : .06 lb/MMBTU (8) [40 CFR60 Subpart KKKK];
SO2 : (9) Acid Rain
Provisions A63.1, A63.2

, A99.1, A99.3, A99.5, A99.7,
A99.9 A195.1, A195.2, A195.3, A327.1, A443.1, B61.1, C1.1, C1.3,
C1.6 , D12.1, D29.1, D29.2

, D29.3, D82.1, D82.2, E193.1, H23.1, I296.1, K40.1, K67.1

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### ENGINEERING ANALYSIS / EVALUATION PROCESSED BY: Roy Olivare s REVIEWED BY:



### Equipment Description (Continued)

Equipment ID
No. Connected To RECLAIM Source Type/ Monitoring Unit Emissions
And Requirements Conditions

Process 1: INTERNAL COMBUSTION
System 1 : GAS TURBINES, POWER GENERATION

CO OXIDATION CATALYST NO. 8

, BASF

, 150 CUBIC FEET OF TOTAL CATALYST
VOLUME
A/N: 4721 6 0 C 45 D 43 C 46

SELECTIVE CATALYTIC REDUCTION
NO. 8

, ICORMETECH CHMT

- 2, WITH

812 CUBIC FEET OF TOTAL CATALYST VOLUME, LENGTH 11 FT 1 IN ; WIDTH : 2 FT 2 IN; HEIGHT4 FT 2

WITH

NH3 INJECTION GRID
A/N: 472160 C46 S48 C45 NH3: 5.0 PPMV (4) [Rule 1303(a)( 1)

- BACT] A195. 4
D12. 2
D12. 3
D12. 4
E179.1
E179.2

, E193.1

, E193.3

STACK NO. 8 , DIAMETER: 13 FT 6 IN

, HEIGHT: 90 FT

A/N: 4721 60 S 48 C 46

System 2 : EMERGENCY ENGINE

INTERNAL COMBUSTION ENGINE, EMERGENCY FIRE, DIESEL FUEL, LEAN BURN, CLARKE, MO DEL JU6H

- UFADTO

, 240 BHP
WITH

AFTERCOOLER, TURBOCHARGER,

A/N: 472165 D 49 NOX: PROCESS
UNIT NOX +NMHC : 3

GM/BHP

- HR DIESEL (4) [RULE 1303; RULE 2005]; NOX: 134 LB/1000 GAL DIESEL (1) [RULE 2012]

CO: 2.6 GM/BHP

- HR DIESEL (4) [RULE 1303]

PM10: 0. 15 GM/BHP

HR DIESEL (4) [RULE 1303]

SOX: 0.0055 GM/BHP

HR DIESEL (4) [RULE 2005]; B61.2, C1. 4

, D12.5, I296. 3

, K67. 3

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### ENGINEERING ANALYSIS / EVALUATION PROCESSED BY: Roy Olivare s REVIEWED BY:



### Equipment Description (Continued)

Equipment ID
No. Connected To RECLAIM Source Type/ Monitoring Unit Emissions
And Requirements Conditio ns

Process 2 : STORAGE TANK

STORAGE TANK, TK

- 1, FIXED ROOF,
29.4 PERCENT AQUEOUS AMMONIA,
DIAMETER: 9 ’

- 4 ”; HEIGHT: 12’

- 0”; 1 2 ,000 GALLONS WITH PRV SET AT 25 PSIG

WITH

A/N: 472161 D 52 C157.1, E144.1,E193.1

STORAGE TANK, TK

- 2, FIXED ROOF,
29.4 PER CENT AQUEOUS AMMONIA,
DIAMETER: 9 ’

- 4 ”; HEIGHT: 12’

- 0”; 1 2 ,000 GALLONS WITH PRV SET AT 25 PSIG

WITH

A/N: 472162 D 53 C157.1, E144.1,E193.1



### Section D of the Facility Permit

Equipment ID
No. Connected To RECLAIM Source Type/ Monitoring Unit Emissions
An d Requirements Conditions

Process 3 : RULE 219 EXEMPT EQUIPMENT SUBJECT TO SOURCE SPECIFIC RULES

RULE 219 EXEMPT EQUIPMENT, COATING EQUIPMENT, PORTABLE,
ARCHITECTURAL COATING E 54 VOC: (9) [Rule 1113], K67

. 5

RULE 219 EXEMPT EQUIPMENT,
EXEMPT HAND WIPING OPERATIONS E 55 VOC: (9) [Rule 1171]



### BACKGROUND

See FDOC dated August 28, 2008 for background information

.

On July 25, 2007 the applicant filed applications with the A QMD for Permit to Construct for the CPV Sentinel Energy Project. The A QMD is sued a PDOC on May 7, 2008 and a FDOC on August 29, 200 8

. The FDOC did not contain information regarding project’s compliance with emissions offset requirements of Rule 1303 (b)(2). On November 3, 2008 the AQMD was ordered by LA Superior Court not to issue permit through Rule 1315, Rule 1304 and 1309.1. Prior to the court ruling the applicant was proposing to obtain ERCs credits fo r SOx and PM10 through Rule 1309.1 as amended on August 3, 2007 (NOx through RE C LAIM system, VOC
with purchase of ERCs)

.

The a pplicant has been working through the California Energy Commission (CEC) to secure a license which incorporates the AQMD Determination of Compliance. On November 3, 2008 the CEC held an evidentiary hearing on the proposed project covering all topics except air quality. The CEC ordered that the evidentiary record on all topics except air quality be closed on December 8, 2008.

With the passage of AB1318 (bec a me effective on 1/1/2010) the applicant proposes to obtain offsets for PM10 and SOx from AQMD’s inte rnal offset bank as allowed under AB1318. On October 15, 2009 the applicant filed an Amendment to Permit to Construct/Operate application for the CPV Sentinel Energy

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### Project: In addition to the revised emissions offset strategy the applicant proposes proje ct design
refinements as listed below:

I Changes requiring AQMD Permits

o Remove blackstart engine (cancel AQMD application no. 472164 )

o Tier 3 engine is now available for the fire pump, the applicant will propose a Tier 3 engine instead of a Tier 2 engin e (BACT for NOx+VOC = 3.0 g/bhp

- hr) under the same AQMD application no. 472165

o Reduce the operating hours from turbines 6 th r ough 8 to equal the operating hours of the first 5
turbines ( this will reduce the overall annual emissions and require less offse ts for PM10, SOx and VOC) under applications for turbines 6 through 8 (AQMD applications nos. 472154, 472156 and 472158).

o Revise the PM10 emissions rate from each turbine from “6 lb/hr” to “5 lb/hr” under applications for turbines 1 through 8 (AQMD appli cations nos. 472139, 472141, 472143, 472147, 472150, 472154, 472156 and 472158)

.

o Revise the CO BACT limit from “6 ppmv” to “4 ppmv” under applications for turbines 1 through 8 and their associated Air Pollution Control systems no 1 through 8 ( AQMD a ppl ications Nos

. 472139, 472141, 472143, 472147, 472150, 472154, 472156, 472158, 472140, 472142,472145, 472149, 472153, 472155, 472157 and 472160).

II Other changes that do not require AQMD Permits

o Remove the two proposed cooling towers, and provide one co oling tower per turbine

o Eliminate the operations buildings

o Remove one warehouse building and relocate another warehouse building

o Relocate the switchgear building

o Relocate the treated water storage tanks, water pumping skids and water treatment trailer parking

Along with the amendments to the Permit to Construct/Operate applications filed on October 15, 2009, CPV
Sentinel also submitted a revised air q uality dispersion modeling analysis and health risk assessment. The primary reason the applicant revise d the modeling analysis was to ensure the proposed changes in locations of buildings and cooling towers would not cause a stack plume downwash conditions that would lead to higher offsite pollutant concentrations than were presented in the previous modelin g evaluation. There is no change
in emissions for short

- term turbine commissioning impacts . At the time the addendum was filed with the District, GE r evis ed the turbine PM10 emissions from 6 lbs/hr to 5 lb s /hr

. T he modeling was revised using the
5 lb/hr PM 10 emissions rate. Planning, Rule Development & Area Sources (PR D A S ) staff reviewed the air quality analysis and the health risk assessment (HRA) for the proposed project provided by CPV Sentinel and results of the review shows compliance with all applicab le ambient concentrations and AQMD rules and regulations threshold standards.

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### S ite Description
The proposed location of CPV Sentinel is on an 37 acre parcel located 8 miles northwest of the center of the city of Palm Springs (62575 Powerline Rd, Desert H ot Springs, 92240 ) . The parcel is undeveloped and is
next to the Dever s substation. CPV Sentinel will be located in an area zoned for industrial uses in the unincorporated area of Riverside County.

The revised site pl an shown above was prepared for CPV Sentinel by URS and shows the general layout of the proposed facility. There will be one cooling tower per turbine and a couple of buildings were moved to different locations on the property. The project site is located in an remote area surrounded by air turbines and an Edison substation to the west. To the southeast is the Indigo Energy Facility (1.8 miles). To the north, east and south are Wind Farms The site locale is an industrial portion of the unincorporated are of Riverside County. The nearest residence is 330 feet east of the Facility and the applicant has an option to acquire the property. The second group of nearest residence is located 2.5 km (8,800 ft) southeast of the Facility.

COMPLIANCE RECORD

No chang e from FDOC

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### PRO CESS DESCRIPTION

No change

GE revised the operating conditions and the condition no. 103 and there is a slight increase in NOx, CO and VOC emissions (in the second decimal point position). GE will revise the PM10 emissions based on 5 lb/hr.

Definition of a Peaking Unit in Rule 2012

No change , from FDOC

Air Pollution Control (APC) System

No change, from FDOC

Selective Catalytic Reduction/CO Catalyst Systems (A/N s 472140 , 4 72142 , 4 72145 , 4 72149, 472153, 472155, 472157 and 472156 )

No change, from FDOC

CO Oxidation Cataly

st

No change, from FDOC

A queous Ammonia Storage Tank (A/N 472161 and 472162 )

No change, from FDOC

Heated Ammonia Vaporization Skid

1 GE Manufactures two versions of the LMS100 CTG. CPV Sentinel plans to install the LMS100PA. The PA model utilizes water injection for NOx abatement while the PB version utilizes dry low emission (DLE) combustors for NOx abatement.

2 PUC is the a cronym for the California Public Utilities Commission

3 Represents the maximum possible fuel consumption of the CTG, based on 875.7 MMBTU/hr heat input and 1,0 18 BTU/scf fuel heat content. However, the emission calculations will be based on a worst

- case o perating scenario as identified by the applicant, which may result in a lower fuel usage depending on the ambient temperature, the employment and rate of intercooling, water injection rates, and electric al load generated. Parameter Specifications

Manufacturer General Electric

Model LMS100PA 1

Fuel Type PUC 2 Quality Natural Gas Natural Gas Heating Value 1,0 18 BTU/scf Operating condition 103 Gas Turbine Heat Input (HHV) 891.7 MMBTU/hr at 72 oF and 4 0 % relative humidity Fuel Consumption 0.8 76 MMSCF/hr 3

Gas Turbine Exhaust Flow 355534 SCFM Gas Turbine Exhaust Temperature 785.1 oF

Exhaust Moisture 6

- 8%

Gas Turbine Power Generation 10 1.279 MW
Net Plant Heat Rate, LHV 7 939 BTU/ kW

- hr

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### No change, from FDOC

Ammonia Distribution Header

No change, from FDOC

P erformance Warranties

No change, from FDOC

Cooling Tower System The applicant proposes to install 8 single cell

- cooling towers mechanical draft evaporative coolings (each for one turbine) and not install the two cooling towers

, both mechanical draft, one of five cells (for the first 5 turbines) an d one with three cells for the final 3 turbines. Th e circulating water rate will be 6

, 9 00 gallons per minute (GPM) for each cooling tower

. The Rule 1401 emissions were determined for this equipment to verify the equipment will be exempt from AQMD permit per Rule 219, see Appendix I for emissions
calculations.

Emergency Fire Pump Engine (A/N 472165 )

Tier 3 engines are now available for this HP range, see Appendix D for revised emissions

Emergency Blackstart Engine (A/N 472164 )

The applicant reques t to cancel the blackstart engine application

CRITERIA POLLUTANT EMISSIONS
The total emissions from the power plant will includ e the summation of all eight CTGs and the emergency fire pump engine

. The emissions from the gas turbines are based on the foll owing formula and assumptions:

GE revised the PM10 emissions from the CTG to 5 lb/hr instead of 6 lb/hr, see guarantee e

- mail dated 10/21/09. GE revised the emission for the various case runs. Case 103 has the highest emissions (minor changes) and will be used to update the emissions. The CO BACT was revised to 4 ppmv and the CO emissions will be revised (lower value).

Emissions for NOx, CO and VOC

where, ppmvd = Uncontrolled (or controlled) concentration at 1 5% O 2 

### , dry ba sis
MW = M olecular weight, lb/lb

- mol
O2 = O2 correction factor = (20.9

- 15)/(20.19

- O2)
H20 =percent water in the exhaust
ER = exhaust mass rate in lb/hr

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### The values for O2, water percentage, mass rate were provided by GE (worst case operati ng scenario)

Emissions for SOx

where,
Sulfur content = 0.25 lb grains/100 scf
Mmbtu/hr =789.8 mm/btu/hr Heating value (LLH) = 918 btu/ft3
MW S = 32 lb/mole
MW SOx = 64

. 2 lb/mole

Emissions for PM 10



### GE guarantees 5 lb/hr at maximum operating conditions

Assumptions:
1. Emissions are based on the worst case operating scenario
2. P M 10 

### emissions are based on 0.00 62 lb/MMBTU (GE guarantee)
3. SO 2 

### to SO 3 

### conversion in APC equipment is accounted for in the PM 10 

### AP

- 42 emissio n factor

4. SOx emissions are based on 0.25 grains S /100 scf

5. 30

- Day Averages are based on 485 hours/month of operation for turbines 1

- 8

. 6. Emissions are based on total fuel consumption rather than total hours of operation

The applicant has identified eleven possible operating scenarios. The eleven scenarios are listed as

o perating conditions (OC) 1 0 0 through 11 0 i n Appendix B in the Amendment to Permit to Construct/Operate application for the CPV Sentinel Energy project :

Table 10

- Operating S c enarios

Ambient Temp oF H 2 O Injection
,

lb/hr Relative Humidity (%) Intercooler (on/off) Compressor I nlet Temp oF

OC100 17 34407 (100%) 8 0 Off 17

OC101 17 2 4526 (7 5 %) 8 0 Off 17

OC102 17 15, 618 ( 50 %) 8 0 Off 17

OC103 72 3 1603 ( 100 ) 40 On 59.3

OC104 72 32072 ( 100 ) 40 Off 72

OC105 72 22056 ( 75 %) 40 Off 72

OC106 72 13838 ( 5 0%) 40 Off 72

OC107 107 28441 ( 100% ) 18 On 7 7.4

OC108 107 27730 ( 100 %) 18 On 107

OC109 107 18956 ( 75 ) 18 On 107

OC110 107 1 1812 ( 50 %) 18 On 107



### Detail of Operating Conditions

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### GE re

- ran the operating scenarios and there were slight changes in emissions. The emissions are based on operating Case 103 reveals that GE ran the tests while varying the water injection rate, and compressor inlet temperature. Ambient temperature was allowed to vary from a minimum of 17 oF to a maximum of

1 07 oF. Note from the table above that for each ambient temperature, the load was varied between
maximum (100%) , average (75%) , and minimum (50%) loads

. The top five cases where fuel flow to the CTGs is the greatest (and therefore yielding the highest emissions) are shown in the table below.

Table 1 1

- Worst Case Operat ing Scenario

Top Operating

Condition

103 Ambient Temperature, oF 72 Ambient Pressure, psia 14.132 Fuel Consumption, MMBTU/hr

LHV 804.1

Fuel Consumption, lb/hr 39034 Exhaust Temperature, oF 785.1
Load, MW 101.279 Water Injection (on/off) On

Wate r Injection, lb/hr 28181 Intercooler (on/off) On



### Of the top five cases, t he worst case scenario occurs during periods of maximum fuel consumption ( 804.1 MMBTU/hr) , LHV at full load (10 1

. 279 MW) , low ambient temperature ( 72 oF)

, with water injection in fu ll

use, and the intercooler not in operation

, as identified in the table above by operating condition no. 10 3

. Therefore, to address the worst case scenario, the facility ’s NSR e missions will be based on the parameters listed in operating condition no. 1 0 3

.

There are essentially four modes of operation for the CTGs. Emissions from the four operating modes are distinctly different and must be calculated independently. The following table gives more detail of the four operating modes.
Table 1 2

- Operati ng Modes of the CTGs

Mode Description

Commissioning The process of fine

- tuning each of the CTG s . Facility follows a systematic approach to optimize performance of each of the CTGs and the associated control equipment. Emissions are expected to be greate r during commissioning than during normal operation. This mode affects only the initial year of operation not to exceed 150 hours per turbine

.

Start

- up The applicant has indicated that there will be up to two start

- ups per day for each CTG, with each s tart

- up lasting 25 minutes. Start up emissions are higher due to the fact that the control equipment has not reached opti m al temperature to begin the chemical reactions needed to convert NOx to elemental nitrogen and water.

Normal Operation Normal oper ation occurs after the CTGs and the control equipment are working optimally, at their designated levels, i.e. NOx emissions are controlled to 2.5 ppmvd at 15% O 2 , CO emissions to 4 .0 ppmv at 15% O 2 (revise CO emissions), and VOC to 2.0 ppmvd at 15% O 2 . Emi ssions may vary due to ambient conditions.

Shutdown Shutdown occurs at the initiation of the turbine shutdown sequence and ends with the cessation of CTG firing
, and will last approximately 1 0 minutes thereafter. Typically, the shutdown process will emit less than the start

- up process but may emit slightly greater than during normal operation because both H 2 O injection into

the CTG s and NH 3 injection into the SCR reactor have ceased operation



### Commissioning Period

No change, except the PM10 emissions rate will be based on 5 lb/hr instead of 6 lb/hr.

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### Table 1 3

- Proposed Commissioning Schedule

Description Power Level Corrected Operating
Hours Estimated

Fuel Rate Total Estimated Emission per Event

NO X CO VOC PM 10 SO X (MMBtu/hr) (lbs) (lbs) (lbs ) (lbs) (lbs)
* First fire the unit & then shutdown to check for leaks, etc

Core/Sync
Idle 23 73.5 257 1049 27 115 1.2 * Synch & Check E

- stop

Sync Idle 17 73.5 192 786 20 87 0.9 * Additional AVR Commissioning

5% 17 92.8 362 524 13 87 1.1

* Break

- in Run

5% 12 92.8 241 349 8 58 0.7 * Dynamic Commissioning of AVR & Commission Water Load Step 1 10.00% 6 166 96 400 30 29 0.7 Load Step 2 20.00% 6 246 142 261 15 29 1.0 Load Step 3 30.00% 6 319 185 261 15 29 1.3 Load Step 4 40.00% 6 389 225 231 15 29 1.6 Load Step 5 50.00% 6 457 265 190 16 29 1.8 Load Step 6 60.00% 6 525 304 260 19 29 2.1 Load Step 7 70.00% 6 591 342 356 24 29 2.4 Load Step 8 80.00% 6 659 382 503 30 29 2.7 Load Step 9 90.00% 6 728 421 744 43 29 2.9 Load Step
10 100.00% 6 798 463 1138 69 29 3.2

Subtoal 58 2826 4344 277 288 20 * Base load AVR Commissioning

100% 23 798 1850 4550 275 115 12.9

COMPLETE

- TOTAL ESTIMATED FIRED HOURS

150 5729 11603 620 749.5 37



### The abov e table, the PM10 emissions were revised

Star t

- up / Shutdown of CTGs

No change, turbines 6

- 8 will have the same number start

- ups/shutdowns as the first five turbines.

Normal Operations The emissions during normal operations are assumed to be fully co ntrolled to Best Available Control Technology (BACT) levels, and exclude emissions due to commissioning, start up and shutdown periods, which are not subject to BACT levels. Hourly , monthly

, and annual emissions as well as the 30

- day

averages are calculat ed and shown in Appendi ces A through E

. The emission calculations for the emergency fire pump are contained in Appendi x D

.

Emissions During A Non

- Commissioning Year

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### The tables below show s the individual and cumulative emissions during a non

- commissioni ng year from all 8 ga s turbines which includes, start

- up, shutdown and normal operation, as well as the emissions from the emergency fire pump which is to operate for the designated maximum of 50 hours per year (permit limit.

A. Emissions per Turbine

Mass Emission Rates , lb/hr ( Non

- Commissioning Year)

Emissions, lb/hr

LMS100PA CTG NOx CO VOC SO 2 PM 10 Normal Operations 7.95 7.74 2.21 0.6 3 5 Start up 59.76 38.15 10.21 0.42 5
Shutdown 34.95 203.88 17.48 0.12 5



### Based on start

- up time of 25 min per day, total time 50 minutes (0.83 hrs) Based on 2 shut downs per day, total time 20 minutes (0.33 hr)

The start

- up and shut down emissions for the purposes of calculations were assume to occur over one hour,

then it makes the emissions calculations in the following tables easier to manage (data provide by GE ) Note, the CO emissions revised to 4 ppmv, based on a recent BACT determination

Turbine Mass Emission Rates per turbine , lb/dy ( Non

- Commissioning Year)

Emissions, lb/dy

LMS100PA CTG NOx CO VOC SO 2 PM 10 Start

- up 50 32 9 0.35 4 Normal operations 119 116 33 9 75
Shutdown 12 67 6 0.040 2
TOTALS 18 1 215 47 9.78 81



### Each t urbines will operate up to 1 5 hours per day (excluding start

- up and shut down times)

Based on 2 start

- ups per day, total time 50 m inutes (0.83 hrs) Based on 2 shut downs per day, total time 20 minutes (0.33 hr)

Turbine Mass Emission Rates per turbine , lb/month ( Non

- Commissioning Year)

Emissions, lb/month

LMS100PA CTG NOx CO VOC SO 2 PM 10 Start

- up 1494 954 255 11 1 25 Normal Operat ions 3578 3484 995 2 82 2250
Shutdown 350 2039 175 1 50
TOTALS 54 21 6447 1424.55 2 93.4 2425



### Turbines will operate up to 1 5 hours per day , every day of the month Up to 2 start

- ups and shut downs per day

Total combines turbine Mass Emission Rates , lb/mo nth ( Non

- Commissioning Year)

Emissions, lb/month

LMS100PA CTG NOx CO VOC SO 2 PM 10 Start

- up 11952 763 2 2064 84 1000 Normal Operations 28624 27872 7992 2599 2256
Shutdown 2800 1631 2 1400 10 400

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TOTALS 43368 51813 1145 6 2347 19400

Mass Emission Rates

, lb/year ( Non

- Commissioning Year )

Emissions, lb/year

LMS100PA CTG NOx CO VOC SO 2 PM 10 Start

- up 59760 38152 10320 424 5000 Normal Operations 167144 162776 46464 13160 105120
Shutdown 13984 81552 6992 48 2000
TOTALS 240881 282475 63 665 13629 112120



### E missions During A Commissioning Year The tables below show the emissions during a commissioning time per each gas turbines which includes commissioning, start

- up, shutdown and normal operation,

Commissioning Emissions rate per Turbine and hours of opera tions per testing phase
Description NOx CO VOC SOx PM10

hrs lb/hr lb/hr lb/hr lb/hr lb/hr

First fire 23 11.17 45.59 1.16 0.05 5 Synch & Check E

- stop 17 11.29 46.24 1.18 0.05 5

Additional AVR 17 21.29 30.80 0.74 0.07 5

Break

- in run 12 20.08 29 .09 0.70 0.06 5 Dynamic AVR 58 48.72 74.90 4.77 0.34 5

Base load AVR 23 80.43 197.85 11.98 0.56 5

total

- lb/hr 150

Turbine emissions lb/hr per turbine, lb/mon and 30 day ave Description NOx CO VOC SOx PM10

lb/mon lb/mon lb/mon lb/mon lb/m on
First fire 257 1048.56 26.68 1.19 115 Synch & Check E

stop 192 786.06 20.05 0.89 85

Additional AVR 362 523.56 12.55 1.12 85

Break

- in run 241 349.04 8.37 0.75 60 Dynamic AVR 2826 4344.23 276.78 19.71 290

Base load AVR 1850 4550.48 275.48 12.90 1 15

total lb/hr ave 38.19 77.35 4.13 0.24 5

totals/mon 5728 11601.92 619.90 36.56 750

30 ave 185 374 20 1 24

Note the commissioning of each turbine will be conducted during one month period and after commissioning is completed for the month, then nor mal operation will not proceed until the following month.

Total Turbine monthly emissions (commissioning month

- lb/month)

CO NOX VOC PM10 SOx

Turbine lb/mon lb/mon lb/mon lb/mon lb/mon

Unit 1 11,602 5,728 620 750 37

Unit 2 11,602 5,728 620 750 37

Uni t 3 11,602 5,728 620 750 37

Unit 4 11,602 5,728 620 750 37

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Unit 5 11,602 5,728 620 750 37

Unit 6 11,602 5,728 620 750 37

Unit 7 11,602 5,728 620 750 37

Unit 8 11,602 5,728 620 750 37

Total 92,815 45,824 4,959 6,000 292

Total combined Turbine (1

- 8) Mass Emission Rates , lb/year (Commissioning Year)

Emissions, lb/year

LMS100PA CTG NOx CO VOC SO 2 PM 10 Start

- up 59760 38152 10 208 424 5000 Normal Operations 167144 162776 46464 13160 105120
Shutdown 13984 81552 6992 48 2000 Commissioning 45832 92824 49 60 296 6000
TOTALS 28672 0 375295 68624 13928 118120



### The only difference between the lb/yr for commissioning year versus a non

- commissioning year, is the additional 150 hrs per turbine of commissioning testing hours.

30

- Day Average s The 30 Day Avera ge emissions are calculated in Appendix B for both a commissioning and non

commissioning year for the worst case operating scenario. The worst case operating scenario was defined
as OC100 in Table 10 above. The values in the tables below are the cumulati ve 30 day averages for the entire facility ( 8 CTGs, the emergency fire pump and the cooling tower).

Cumulative 30

- Day Averages , lb/ day (Commissioning Year)
30 Day Average , lb/ day

Eight LMS100PA CTGs NOx 4 CO VOC SOx PM 10 Commissioning 2994 160 9 194

TOTALS 2994 160 9 194



### The above table assumes all the turbines are commissioned in the same month for the worst case emissions scenario. Once the commissioning is completed for one turbine, then following month the turbine can commence normal operations (permit conditions will address this issue).

Cumulative 30

- Day Averages, lb/day ( Non

- Commissioning Year)

30 Day Average, lb/day

Eight LMS100PA CTGs NOx 6 CO VOC SOx PM 10 Total Operations 1671 367.6 75.68 625.84

TOTALS 1671 367.6 75.68 625.84



### The a bove table assumes all the turbines are in normal operations and providing electricity to the electrical grid in the same month for the worst case emissions scenario.

4 CPV Sentinel has elected to ente r RECLAIM. As such, RECLAIM Trading Credits (RTC) will be used to satisfy the NOx offse tting requirements of Rule 2005, and therefore the 30

- Day Averages for NOx need not be calculated

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### The following is a compar ison of the cumulative 30

- d ay a verage s for the entire facility ( 8

- LMS100 PA gas turbines) for both a commissioning year and a non

- commissioning year . The m aximum 30

- d ay a verage s for each pollutant, shown in bold

.

NOx 6 CO VOC SOx PM 10 Facility 30 Day Average (Commissioning Year) 2994 160 9 94

Facility 30 Day A verage (Non

- Commissioning Year) 1671 367.6 75.68 625.84



### The following table shows the 30

- day averages from one individual LMS100PA gas turbine for both a commissioning year and a non

- commissioning year. The maximum 30

- d ay a verages for each pollutant are shown in bold.

Turbine

NOx 6 CO VOC SOx PM 10 30 Day Average (Commissioning Year) 372 20 1 24
30 Day Average (Non

- Commissioning Year) 209 45.95 9.46 78.23



### Emissions from the Fire pump engine

NOx CO VOC SOx PM 10
Lb /hr 1.545 0.36 0.04 0.0022 0.048
Lb/dy 1.545 0.36 0.04 0.0022 0.048

30

- day ave n/a 0 0 0 0
Lb/yt 77.25 18.02 2.02 0.11 2.38



### Updated emissions applicant proposes to install a Tier 3 fire pump engine

P ROHIBITORY RULE EVALUATION

RULE 212

- Standards for Approving Permits

The facil ity emissions was revised and there is a reduction in emissions for all pollutants . The project was already noticed to the public, with the emissions reductions, the new public notice is not required.

Previous Total Project emissions

Emissions, lb/month

Equipment NOx CO VOC SO 2 PM 10 NH3
LMS100PA CTG 48261 72899 12788 2693 27060 25,403 Fire pump engine 1 3 2 0 0 0 Blackstart engine 18 4 1 0 0
TOTALS 4829 2 72905 12789 2693 27060 25403



### NH3 = 5.86 b/hr

NH3 = ( (450 hr/mon * 5 turbines) + (695 hr/m on * 3 turbines)) * 5.86 lb/hr = 25403

Revised Total Project emissions

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Emissions, lb/month

Equipment NOx CO VOC SO 2 PM 10 NH3
LMS100PA CTG 43368 51813 11396 2347 19400 21202 Fire pump engine 6.44 1.50 0.0 0 0
TOTALS 43374 51815 11396 2347 19400 212 02



### NH3 = 5.86 b/hr

NH3 = ( (450 hr/mon * 8 turbines) * 5.89 lb/hr = 21204 lb/mon

RULE 21 9

- Exempt equipment not requiring permits

The Cooling tower is exempt from AQMD permit per section ( d )(3) . The MICR from this equipment is less
than one in one mill

ion risk (max 0.0 0957 in a million) for the combined eight cooling towers

. MICR reviewed by District modeling staff and MICR is less than the threshold value of this Rule , thus the equipment is exempt from requiring a Permit to Operate

.

RULE 401

- Visible Em issions

No change, from FDOC

RULE 402

- Nuisance

No change, from FDOC

RULE 403

- Fugitive Dust

No change from FDOC

RULE 407

- Liquid and Gaseous Air Contaminants

No change from FDOC

RULE 409

- Combustion Contaminants This rule restricts the discharge of contaminants from the combustion of fuel to 0.1 grain per cubic foot of gas, calculated to 12% CO 2 

### , averaged over 15 minutes. The equipment is expected to meet this limit
based on the calculations shown below:

Estimated exhaust gas 355,534 SCFM = 21. 33 mmscf/hr
Water content 1 2

. 2279 Estimated exhaust gas 355534 SCFM * (1

- 0.122279 ) = 3 12

, 060 Estimated exhaust gas 312

, 060 DSCFM * (60 min/hr) * (1mmcf/1E06 ft3) Estimated exhaust gas 1 8

. 72 mmscf/hr

Maximum PM10 Emissions 5 lb/hr
Estimated CO2 in exha ust 3

. 9964 %

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### Grain Loading = 0.00 612 gr/dscf << 0.1 gr/dscf

The fire pump engine is not subject to this Rule

.

RULE 431.1

- Sulfur Content of Gaseous Fuels

No change

. Historically the sulfur content of the fuel has been less than 4 ppmv for combustion sources and the 16 ppmv sulfur content is the max allowed by the Rule. The applicant provided in the CEC application submittal the sulfur content (table 5.2

- 2) and the range is from 0.051 to 0.119 gr/100 ft3. The applicant for the purposes of offset s will limit the sulfur content to 0.25 gr/100 ft3 (permit condition and also require monthly testing for the sulfur content).

RULE 431. 2

- Sulfur Content of Liquid Fuels

No change from FDOC

R ULE 474

- Fuel Burning Equipment

- Oxides of Nitrogen Superseded by NOx RECLAIM

.

RULE 475

- Electric Power Generating Equipment This rule applies to power generating equipment greater than 10 MW installed after May 7, 1976. Requirements are that the equipment m eet a limit for combustion contaminants of 11 lbs/hr or 0.01 gr/scf. Compliance is achieved if either the mass limit or the concentration limit is met. Mass PM10 emissions
from the turbine are estimated at 5 .0 lbs/hr, and 0.00 38 gr/scf during natural gas f iring at maximum firing load (see calculations below). Therefore, compliance is expected. Compliance will be verified through the initial performance test.

where: Fd: Dry F factor for fuel type, 8710 dscf/MMBtu O2: Rule specific dry oxygen content in the effluent stream, 3% TFD: Total fired duty measured at HHV, 8 91.7 MMBtu/hr

Stack flow = 8710(20.9/17.9)* 897.7 = 9.13 mmscf/hr

Combustion particulate = ( 5 .0/ 9.13 E+06)*7000 = 0.00 38 gr/scf

RULE 1110.2

– Emissions from gaseous

- and liquid fueled engines

No change from FDOC

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### RULE 1134

– Emissions of NOx from Gas Turbines

No change from FDOC

RULE 1135

– Emissions of NOx from Electric Power Generating Systems

No change from FDOC

NEW SOURCE REVIEW (NSR) ANALYSIS

T he following section describes the NSR analysis for CPV Sentinel . The facility can compl y with NSR
either by qualifying for various exemption s from or by demonstrating comp liance with the following rules

, except the emissions offsets requirements for PM10 and S O x is evaluated as specified in Appendix N

. Each piece of equipment at CP V Sentinel is evaluated for compliance with the rules in the table below.

Table 1 4

- Applicable NSR Rules for CPV Sentin e l

Applicable NSR Rules for Non

- RECLAIM Pollutants (CO, VOC, SOx, PM 10 ) Applicable NSR Rules for RECLAIM

P ollutants (NOx)
Rule 1303(a)

– BACT Rule 2005(b)(1)(A)

- BACT

Ru l e 1303(b)(1)

– Modeling Rule 2005(b)(1)(B)

- Modeling
Rule 1303(b)(2)

- Offsets Rule 2005(b)(2)

- Offsets
Rule 1303(b)(3)

- Sensitive Zone Requirem ents Rule 2005(e)

- Trading Zone Restrictions
Rule 1303(b)(4)

- Facilitywide Compliance Rule 2005(g)

- Additional Requirements
Rule 1303(b)(5)

- Major Polluting Facilities Rule 2005(h)

- Public Notice

Rule 170 1 (b)(1) and Rule 1703 (a)(2) BACT

for NOx , SOx and CO Rule 2005(i)

- Rule 1401 Compliance Rule 2005(j)

- Compliance with Fed/State NSR



### RULE 1303(a

)

, Rule 2005(b)(1)(A)

- BACT and Rule s 1701 (b)(1) and 1703 (a)(2)

– LMS100 CTGs
Th ese rule s state that the Executive Officer shall deny the Permit to Construct f or any new source which results in an emission increase of any non

- attainment air contaminant, any ozone depleting compound, or ammonia unless the applicant can demonstrate that BACT is employed for the new source. CPV Sentinel is a new source with a pote ntial for an increase in emissions and therefore, BACT is required. Each of the
LMS100 CTGs proposed for construction by CPV Sentinel will be operated on a simple cycle ( no steam turbine

, HRSG , or secondary electrical generator is associated with simple c ycle configurations ). As of the date of this evaluation, BACT for simple cycle gas turbines is shown in T able 1 5 below:

Table 1 5

- BACT Requirements for Simple Cycle Gas Turbines

NOx CO VOC PM 10 /SOx NH 3 2.5 ppmvd, @ 15%

O 2 , 1

- hour average 4 .0 ppmvd, @ 15% O 2 , 1

- hour average 2.0 ppmvd, @ 15% O 2 , 1

- hour average PUC quality natural gas w/ S
content ≤ 1 grain/100 scf 5.0 ppmvd @ 15%

O 2 , 1

- hour

average



### This information was based on a current BACT standards for this type of equipment . The CO BACT was

rev ised after the FDOC was issued last year. Since the permits to construct has not been issued and the facility is a Major Source, the new BACT requirement applies. The new CO BACT limit is 4 ppmv, ref City of Riverside, Public Utilities Dept

- Riverside Energ y Resource Center, id 139796, a/n 481647 and 481649

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### Table 1 6

- Proposed BACT for CP V Sentinel CTGs

NOx CO VOC PM 10 /SOx NH 3 2.5 ppmvd, @ 15%

O 2 , 1

- hour average 4 .0 ppmvd, @ 15% O 2 , 1

- hour average 2.0 ppmvd, @ 15% O 2 , 1

- hour average PUC quality

natural gas w/ S
content ≤ 1 grain/100 scf 5.0 ppmvd @ 15%

O 2 , 1

- hour

average



### Natural gas provided by the Gas Company is limited to 16 ppmv in the South Coast by Rule 431.1, Generally , the actual sulfur content is 4 (4 ppmv corresponds to 0.25 gr/100 scf). Ac tual gas content for combustion sources in the District is less than 4 ppmv. Rule 431.1 is not an offset rule and the applicant proposes to limit the sulfur content to less than 4 ppmv (permit condition, requires monthly testing for sulfur content)

A NOx CEMS will be used to verify compliance with the NOx BACT limit and a CO CEMS will be used to verify compliance with the CO BACT limit. The proposed control levels in the table above will meet current BACT requirements for all c riteria pollutants including NH 3



### . BACT is satisfied for each of the CTGs

.

During start

- up operations for the turbines (see pages 23 and 24 for more information and see e

- mail dated
6/13/08 for the start

- up emissions profile ) , the control system will not be on line because the c atalyst have a minimum inlet temp in order to reduce the pollutants the required BACT concentration limits. The turbine is equipped with water injection (limited NOx controls) and the NOx emissions during start

- up is reduced to 25 ppmv. Condition A433.1 li mits the NOx emissions during the first hour of operation (includes start

- up emissions with water injection in operation) and limits the number of start

- ups per year and length of each

start

- up. During start

- up it is not practical to require a NOx ppmv li mit, but to limit the emissions during the

start

- up hour as done in condition A433.1 , thus BACT needs to be defined during start

- up to include the following

o Limit start

- up time

- condition, A99.1, A99.2, A99.3, A99.4, A99.9, A99.10, A433.1 and A433.2

o Limi t start

- ups per year

- condition s, A99.1, A99.2, A99.3, A99.4, A99.9, A99.10, A433.1 and
A433.2

o Limit NOx emissions per start

- up hours, requires water injection to be used to comply

- condition
A433.1

RULE 1303(a) and Rule 2005(b)(1)(A)

- BACT

– Emergency Fire Pump Engine

Tier 3 fire pump is available, the applicant will propose a Tier 3 engine, the NOx+VOC will be less than 3 g/bhp

- hr (actual 2.627 g/bhp

- hr) , CO is listed at 0.6 g/bhp

- hr and PM10 is listed at 0.079 g/bhp

- hr

RULE 1303(a)

- BACT

– Cooling Tower Rule 219(e)(3) provides and exemption for water cooling towers and water cooling ponds not used for evaporative cooling of process water or not used for evaporative cooling of water from barometric jets or
from barometric condensers and in which no c hromium compounds are contained. The eight cooling tower being proposed at CPV Sentinel will meet the requirements of Rule 219( s )( 2 ) , Rule 1401 MICR well below
one in one million limits and is therefore exempt from NSR. BACT therefore does not apply.

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### R ULE 1303(a)

- BACT

– Ammonia Storage Tank

No change from FDOC

RULE 1303(b)(1) and Rule 2005(b)(1)(B)

- Modeling

The primary reason for revising the previous air quality impact analysis was then to ensure that proposed changes in the locations of certain project emissions sources and changes to the dimensions and locations of other buildings and structures on the site would not cause stack plume downwash conditions that would lead to higher offsite pollutant concentrations than were presented in the previo us submittals to the District. The applicant has conducted air dispersion modeling using the EPA AERMOD model

. The Tier 4 Health Risk Assessment was conducted in accordance with guidelines set forth by the California Office of
Environmental Health Hazard Assessment (OEHHA) and the California Air Resources Board (CARB). The OEHHA/CARB computer program (HARP) was used to determine the health risk assessment

. The air dispersion model was run at a single normalized emission rate of 1.0 gram/sec. The applic ant has submitted modeling results for both a commissioning and non

- commissioning year which considered building downwash effects through the use of the EPA Building Profile Input Program, a program which is compatible with the ISCST3 model. E ffects of te rrain slope

, aspect ratio, plume height, wind speed, wind direction and temperature were also accounted for in the analysis. The AERMOD model requires both surface and upper air meteorol ogical data in the modeling applications. The National Weather Servic e (NWS) surface data at Dagget

- Barstow station were used with wind data from the Wintec Wind Engery facility . The upper air data were obtained from the Desert Rock station in Nevada because it has the best data coverage for the modeling application. The an alysis further accounted for flat, simple, intermediate, and complex terrain. Terrain features were taken from 1

- second U.S. Geological Survey (USGS) data taken from its Digital Elevation Model (DEM). The DEM data provides terrain elevations with 1

- meter vertical resolution and 10

- meters horizontal resolution based on a UTM coordinate system

. The EPA SCREEN3 model was used to estimate potential impacts due to fumigation. Potential fumigation impacts
were estimated for NO 2 

### , CO, and SO 2



### . Table A

- 2 shown below is found in Rule 1303 and lists the most stringent ambient air quality standards and allowable change in concentration for each air contaminant. The appropriate averaging times are also listed.

Table A

- 2 Most Stringent Ambient Air Quality Standar d and Allowable Change in Concentration For Each Air Contaminant/Averaging Time Combination

Air Contaminant Averaging

Time Most Stringent Air

Quality Standard Significant Change in Air Quality Concentration

Nitrogen Dioxide 1

- hour 25 pphm 338 μg/m 3 1 pp hm 20 μg/m 3

Annual 5.3 pphm 56 μg/m 3 0.05 pphm 1 μg/m 3

Carbon Monoxide 1

- hour 20 ppm 23 μg/m 3 1 pphm 1.1 μg/m 3

8

- hour 9.0 ppm 10 μg/m 3 0.45 pphm 0.50 μg/m 3

Suspended Particulate

Matter < 10μm (PM 10 ) 24

- hour 50 μg/m 3 2.5 μg/m 3

AGM 5 30 μg/m 3 1 μg/ m 3

SO2 24

- hour 25 μg/m 3 1 μg/m 3



### The applicant is required under Rule 1303(b)(1) to demonstrate compliance with one of the following requirements:

(a) The most stringent air quality standard shown in Table A

- 2 above, or

5 AGM is the acronym for Annual Geometric Mean

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### (b) The significant change in air quality concentration standards shown in Table A

- 2 above , if the most stringent air quality standards are exceeded

The applicant has submitted the following modeled maximum project impacts for CPV Sentinel

. The applicant estimated the air quality im pacts for many scenarios which included the commissioning, startup, normal operation, and shutdown phases. The worst

- case scenario was identified for each pollutant and each averaging period. The numbers in the table below are per turbine

.

Maximum i ndividual Turbine Impacts for CPV Sentinel

Pollutant Averaging

Time Turbine

no. Max

Impact (μg/m 3 ) Background

(μg/m 3 ) Total

Impact (μg/m 3 ) Most Stringent

Standard (μg/m 3 ) Significant Change in air quality

concentratio n (ug/m 3 ) Comply

(Yes/No)

NOx 1

- hour NO. 8 22.50 174.8 197.3 338 N/a Yes

Annual No. 6 0.077 24.5 24.58 56 N/a Yes

SO2 24

- hour No. 7 0.38 39.4 39. 78 105 n/a Yes

1

- hour No. 7 1.45 62.5 63.95 655 n/a Yes

3

- hour No. 7 1 41.6 42.6 1300 n/a Yes

Annual No. 8 0.06 10.7 10.76 80 n/a Yes

CO 1

- hour NO. 8 34.04 2645 2679 23,000 N/a Yes

8

- hour NO. 7 10.46 944.4 954.86 10,000 N/a Yes



### Note, for the above values, the entire project impacts is less than concentration standards , see memo dated 11/13/09 by Naveen Barry

Pollutant Averaging

Time T urbine

no. Max

Impact (μg/m 3 ) Significant

Change in air quality

concentratio n (ug/m 3 ) Comply

(Yes/No)

PM 10 24

- hour 8 1.99 2.5 Yes

AGM 8 0.06 1 Yes



### As seen from the table above, both the 24

- hour and AGM air quality standards for PM 10 

### will be comply wit h the Significant Change in Air Concentration limit. The basin is non

- attainment for PM10, the more stringent standard applies

. Therefore, the applicant will be required to show compliance with the significant change in air quality standards for PM 10



### .

The CO and NOx emissions were based on normal operation of the turbines (max hourly emissions) , The short term impacts for the commissioning operations did not change and was not modeled

. The CO BACT limit was revised to 4 ppmv instead of 6 ppmv, the revised CO modeling was based on 6 ppmv, because the consultant did not have enough time to update the modeling based on 4 ppmv for CO. The PM10
emissions were based on 5 lb/hr. Note, CARB adopted new NOx standards of 338 ug/m3 (1 hour) and 56 ug/m3 (annual) and the standards took effect in May 2008. Each turbine will comply with the revised NOx
standards.

AQMD modeling staff review ed t he applicant’s analyses for both air quality modeling and health risk

assessment (HRA)

. Modeling staff provided their comments in a memorandum from M r

. Barry to Mr. Mike
Mills dated November 13 , 200 9 , see Appendix M . A copy of this memorandum is contained in the engineering file. Staff’s review of the modeling and HRA analyses concluded that the applicant used EPA
AERMOD model ( version 07026) along with the appropriate model options in the analysis for NO 2 

### , CO,
PM 10 

### , and SO 2 

### . The applicant modeled both the cumulative and individual permit unit impacts for the

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### project . The memorandum states that the ISCST3 modeling as performed by the applicant conforms to the District’s dispersion modeling requirements. No significant deficiencies in methodology were noted.

Protection of Visibility

. The visibility analysis was not revised. The revisions to the project will result in the
sh ort

- term project emissions to be either at the same level or less than what was previously analyzed. The second largest source of combustion pollutant emissions was the blackstart engine, which has been removed from the project. The PM 10 

### emissions from t he cooling towers are less than the emissions originally included. Therefore, the visibility impacts from the revised project are less than the PLUVUE II impacts c ontained in the original report. Confirmed by District modeling staff, see memo dated 11/13/ 09

.

PSD Analyses The applicant estimated the emissions from the proposed project for NO 2 

### , CO, PM 10 

### , and
SO 2 

### . The emission summary is Appendix C

. Rule 1702 (m) (1) states that a major stationary source includes steam electric plants of more than 250 M MBTU/hr heat input. Although this facility will have a heat input of greater than 250 MMBTU/hr, it only produces electric power through mechanical means and not through a steam process as defined under subsection (1) of the rule. Therefore, the proposed si mple cycle units are subject to subsection (2) which places the Major Stationary Source threshold on emissions of 250 tons per year or more. The maximum NOx potential to emit for these 8 turbines is 143 tons per year, therefore, this project is not conside red a Major Stationary Source and is not subject to the rule 1703 NOx PSD analysis

.

RULE 1303(

b ) (2) and Rule 2005(b)(2)

- Offsets

– LMS100 PA CTGs

Since CPV Sentinel is a new facility with an emissions increase, offset requirements apply

. CPV Sentinel
ha s opted into AQMD’s NOx RECLAIM program and as such, NOx increases will be offset with RTCs at a

1 .0 to 1 ratio. For n on

- RECLAIM non

- attainment (or precursors to non

- attainment) criteria pollutants the
VOC emissions will be offset by the purchase of Emissi on Reduction Credits (ERCs) at a 1.2 to 1 ratio

. Since CO is an attainment pollutant there are no offset requirements for CO. For PM10 and S O x emissions offsets please refer to Appendix N.

I Required Offsets for RECLAIM Pollutants (NOx)

The required RTC s for NOx for the first and second years of operation are shown below. The values
include start

- ups, commissioning (first year only), normal operation, and shutdowns, see Appendix F for details. (The total emissions for the second year excludes commissio ning).

Turbines one through eight

Hours NOx NOx NOx

Operating Condition 10 3 per (lb/hr) (lb/year) (lb/year)

Year per device cumulative

CTGs Startup 125 59.76 7,470.00 59,760

Shutdown 50 34.95 1,747.50 13,980 Normal Operation 2,628 7.9 5 20,8 62.60 167,147.8 Commissioning 150 38.19 5,728. 5 0 45,828

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CTG Totals 2,953 35, 838.60 286,708.80

Hours NOx NOx
Operating Condition 10 3 per (lb/hr) (lb/year)

Year cumulative

CTG 1

- 8 Totals 286,708.8
Emergency Fire Pu mp 50 1.54 77.25 77.25

Total 1st Year Emissions (lb/year) 286,786.05

Offset Ratio 1.00
1st year RTCs (lb/year) 286,786.05
2nd year RTCs (lb/year) 241,958.05



### II Required Offsets for Non

- RECLAIM Pollutants (VOCs, SOx, CO and PM10)

Table 18 shows the facility

- wide 30

- day averages for CO and VOC. Offsets are based upon 30

- day averages from individual permit units. As mentioned above, CPV Sentinel may elect to use ERCs or other

means to provide the required offsets. The amount s in Table 18 are required to fully offset the facility increases and satisfy the requirements of Rule 1303(b)(2):

Table 18

– 30

- Day Averages for the Entire Facility, (lb/day)

NOx CO VOC Maximum 30 Day Average 2994 367.6



### Table 19

- Required Offsets for Non

- RECLAIM Pollutants (for entire facility)

NOx CO VOC Maximum 30 Day Average 2994 367.6

Offset Ratio 1.2 1.2 Required Offsets 441.42
Required Offsets 441



### Table 20

- Required Offsets for Non

- RECLAIM Pollutants (per

- turbine basis lb/d ay)

NOx CO VOC Maximum 30 Day Average 374 45.95

Offset Ratio 1.2 Required Offsets 55.14



### Offsets are not required for CO, since the Salton Sea Air Basin in AQMD is in attainment with CO. The CO emissions are listed for informational purposes onl y in this section, however the analysis for attainment pollutants is disussed under Regulation X V II.

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### The table below shows the total amount of VOC ERC’s that CPV Sentinel has purchased as of February 28, 20 10 . The table consists of two ERC certificate s f or VOC (certificate no. see below ) purchased on
3/27/08 , from Tenaska in the amount of 412 lb/day.

Total Amount of Emission Reduction Credits currently held by CPV Sentinel

Pollutant ERC Certificate No. Date of

Purchase Name of Seller Amount of
ERC (lb /day)

VOC AQ007877 03/27/08 Tenaska 348

VOC AQ007879 03/27/08 Tenaska 64



### CPV Sentinel has indicated that the required amounts of offsets will be provided prior to issuance of the Facility Permit. Compliance with offset requirements of Rules 1303(b)(2) is required prior to issuance of
the Permits to Construct.

The maximum PM10 and S O x emissions occur during a commissioning year and are as follows:

PM10 lb/yr SOX lb/yr

Maximum pounds per year, includes commissioning period 118,120 13,928



### For PM10 and S O x offset evaluation, please refer to Appendix N

AB1318 (California Health & Satety Code Section 40440.14)

AB1318 was enacted by the State Legislature on 9/11/09 and was signed into law by the Governor on
10/11/09 and became effective on 1/1/2010. The bill will add Section 3619.8 to, and to add and repeal 40440.14 of, the Health and Safety Code, and to amend Section 21080 of the Public Resource Code, relating the SCAQMD.

To be eligible for the emissions credits under AB1318 the electrical generating f acility shall meet the requirements pursuant to Health & Safety Code Section 4040.14 (d) as shown in Table 25 below.

Table 25

-

AB1318 Compliance for CPV Sentinel Project

Subject to State Resources conservation and development commission permitting juri sdiction Yes

Have a power purchase agreement prior to 12/31/2008 with a public utility in the LA

basin Yes

Be under jurisdiction the AQMD , but not
located with in the South Coast Air Basin Yes, facility located in the Salton Sea air

basin under AQMD jurisd iction Can not transfer credits until mitigation fees are paid. The fees are set per Rule 1309.1 adopted on Aug 3, 2007 Applicant needs to pay the mitigation fee prior to the issuance of emissions credits, fee calculation in appendix L



### Turbines 1 though 5 will pay mitigations fees per Rule 1309.1 (g)(1)(F) Turbines 6 though 8 will be mitigations fees per Rule 1309.1 (g)(1)(B)

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### See Appendix L for fee determination under AB1318

Fuel limits

The facility’s maximum monthly and annual fuel usage (caps) for the simultaneous operation of the 8 CTGs
will be 3

, 400 mmscf and 19640 mmscf, respectively , based on operating condition 10 3 . The annual fuel

cap w ill be the basis for the facility’s PTE

. The monthly and annual fuel caps will correspond to 485 hours/mon th and 2803 hours/year of operation for each t urbine. These values were selected by CPV
Sentinel

.

The fire pump engine will have hours per year limitations

. The calculations are shown below and a monthly fuel cap (ref Appendix G) will be included on the Facility Permit as a permit condition

.

Commissioning period
CTG fuel/turbine = 301 mmcf

Non commissioning period Turbines 1 through 8 (per turbine)

Monthly : CTGFue l = (485 hr/mon) * 891.7 mmbtu/hr * 1ft3/1018 btu
CTG Fuel = 4 25 mmcf/month

Annually : CTG Fue l = (2803 hr/yr) * 8 91.7 mmbtu/hr * 1ft3/1018 btu
CTGFuel= 2,4 55 .24 mmcf /yr

Non commissioning period Turbines 1 through 8 (total)

Monthly : CTGFue l = 425 mmcf/month * 8 turbines
CTG Fuel = 3 400 mmcf/month

Annually : CTG Fue l = 2455 .24 mmcf/yr * 8 turbines CTGFuel= 19

, 64 2 mmcf /yr

RULE S 1303(b)(3)

- Sensitive Zone Requirements and 2005(e)

- Trading Zone Restrictions
Both rules state that credits must be obtained from the appropriate trading zone. In the case of Rule 1303(b)(3), facilities located in t he South Coast Air Basin are subject to the Sensitive Zone requirements specified in Health & Safety Code Section 40410.5. CPV Sentinel is located in the Coachella Valley and is therefore eligible to obtain its ERCs from either Zone 1 or Zone 2a. Similar ly in the case of Rule 2005(e),
CPV Sentinel , because of its location may obtain RTCs from either Zone 1 or Zone 2, at its choosing. Therefore upon providing the adequate amount of emissions reductions credits or RTCs c ompliance is expected with both rul es.

RULE 1303(b)(4)

- Facility Compliance

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### No change

RULE 1303(b)(

5 )

- Major Polluting Facilities

Rule 1303(b)(5)(A)

– Alternative Analysis No change Rule 1303(b)(5)(B)

– Statewide Compliance No change

Rule 1303(b)(5)(C)

– Protection of Visibility
Model ing is required if the source is within a Class I area and the NOx and PM10 emissions exceed 40 TPY and 15TYP respectively. There are three Class I sites is located within the minimum distances to this facility. Modeling from plume visibility is required, however, the applicant has provided modeling impact data for the Class I areas and the data was reviewed by District’s modeling staff and complies
with this section of the Rule.

Rule 1303(b)(5)(D)

– Compliance through CEQA No change

Rule 1401

– New So urce Review of T oxic Air Contaminants
This rule specifies limits for maximum individual cancer risk (MICR), acute hazard index (HIA), chronic hazard index (HIC) and cancer burden (CB) from new permit units, relocations, or modifications to existing permits wh ich emit toxic air contaminants. Rule 1401 requirements are summarized as follows:

Table 2 2

– Rule 1401 Requirements

Parameters and Specifications Rule 1401 Requirements

MICR, without T

- BACT ≤ 1x10 - 6

MICR, with T

- BACT ≤ 1x10 - 5

Acute Hazard Index ≤ 1.0

Chronic Hazard Index ≤ 1.0

Cancer Burden ≤ 0.5



### The applicant performed a Tier 4 health risk assessment using the Hot Spots Analysis and Reporting Program (HARP, version 1.2a). The applica nt used EPA ISCST3 model (version 99155) in their modeling analysis. (This is the version of ISCST3 used in HARP.) The analysis included an estimate of the MICR for the nearest residential and commercial receptors, the acute and chronic hazard indices for the entire facility. PRA modeling staff reviewed the applicant’s methodology and procedures used, and re

- ran the HARP model and verified the health risk and hazard indices which were presented by the applicant. PRA
staff concluded that each of the hea lth risk values for MICR, HIA and HIC were appropriately estimated (see memorandum in file, dated November 13 , 200 9 from M R

. Naveen Berry to Mr. Mike Mills ). Table 2 4
below is a summary of the modeled health risk assessment results (list largest MICR, HI A and HIC regardless of receptor location)

. The cancer burden is not calculated because the MICR is less than 1 x
10 - 6 

### for both residential and commercial receptors. See Appendix I for TAC emissions calculations

.

Table 2 3

– Rule 1401 Modeled Results

Turbine 1

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Risk Parameter Cancer Risk Rule 1401 Requirements Compliance

(Yes/No)
MICR 0.005 1 4 x 10 - 06 ≤ 1 x 10 - 6 Yes

HIA 0.014 7 ≤ 1.0 Yes
HIC 0.0001 6 ≤ 1.0 Yes Receptor UTMs 53 9411 E / 37 4511 N



### Turbine 2

Risk Parameter Cancer Risk Rule 1401 Requireme nts Compliance

(Yes/No)
MICR 0.0050 9 x 10 - 06 ≤ 1 x 10 - 6 Yes

HIA 0.014 8 ≤ 1.0 Yes
HIC 0.0001 6 ≤ 1.0 Yes Receptor UTMs 53 9411 E / 3745100 N



### Turbine 3

Risk Parameter Cancer Risk Rule 1401 Requirements Compliance

(Yes/No)
MICR 0.0050 5 x 10 - 06 ≤ 1 x 10 - 6 Y es HIA 0.014 9 ≤ 1.0 Yes
HIC 0.00015 ≤ 1.0 Yes Receptor UTMs 53 9411 E / 6745110 N



### Turbine 4

Risk Parameter Cancer Risk Rule 1401 Requirements Compliance

(Yes/No)
MICR 0.005 04 x 10 - 06 ≤ 1 x 10 - 6 Yes

HIA 0.014 8 ≤ 1.0 Yes
HIC 0.0001 5 ≤ 1.0 Yes Receptor UTMs 53 7111 E / 3758610 N



### Turbine 5

Risk Parameter Cancer Risk Rule 1401 Requirements Compliance

(Yes/No)
MICR 0.005 06 x 10 - 0 6 ≤ 1 x 10 - 6 Yes

HIA 0.014 8 ≤ 1.0 Yes
HIC 0.0001 5 ≤ 1.0 Yes Receptor UTMs 53 7211 E / 3758510 N



### Turbine 6

Risk Parameter Cance r Risk Rule 1401 Requirements Compliance

(Yes/No)
MICR 0.00 512 x 10 - 0 6 ≤ 1 x 10 - 6 Yes

HIA 0.014 6 ≤ 1.0 Yes
HIC 0.000 16 ≤ 1.0 Yes Receptor UTMs 5 37311 E / 37 58410 N



### Turbine 7

Risk Parameter Cancer Risk Rule 1401 Requirements Compliance

(Yes/No)
MICR 0.00 51 x 10 - 0 6 ≤ 1 x 10 - 6 Yes

HIA 0.014 6 ≤ 1.0 Yes
HIC 0.000 16 ≤ 1.0 Yes Receptor UTMs 5 37311 E / 3758510 N

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### Turbine 8

Risk Parameter Cancer Risk Rule 1401 Requirements Compliance

(Yes/No)
MICR 0.0 509 x 10 - 0 6 ≤ 1 x 10 - 6 Yes

HIA 0.014 7 ≤ 1.0 Yes
HIC 0 .000 16 ≤ 1.0 Yes Receptor UTMs 5 37211 E / 3758310 N



### Table 2 4 shows that CPV Sentinel will comply with the applicable requirements of Rule 1401. The cancer burden is not computed because the highest MICR is less than 1 x 10 - 6



### . The applicant use EPA ISC ST3 (version 99155) in their modeling analysis (this is the version of ISCST3 used in HARP) The applicant performed the risk assessment with the Hot Spots Analysis and Reporting Program (HARP, version 1.3). Planning reviewed the See Appendix H for the actu al TAC emissions.

The f ire pump are exempt per section (i)(1)(A). The cancer risk was calculated for this equipment and is listed below for informational purposes only.

The peak cancer risks for the total project at all receptors is 0.5 in one million. The peak acute and chronic hazard indices for the total project are 0.1 and 0.008, respectively. These total facility risks are less than
the Rule 1401 cancer and non

- cancer permit limits of 10 in one million and hazard index of 1, respectively.
Confirme d by District modeling staff, see memo dated 11/13/09

The combined risk for all the cooling towers is 0.00957 in a million

Fire pump engine risk is 0.469 9 in a million

The total risk for all the turbines, one fire pump and cooling towers is 0.52016 in a million . The peak

The table below list the MICR/HIA/HIC at the residential and commercial receptor

Table 2 4

– Rule 1401 Modeled Results for nearest residential/commercial receptor

Source Residential Commercial Residential Commercial Residential Comm ercial

MICR MICR HIC HIC HIA HIA

Gas Turbine No. 1 5.44 E

- 06 1.32 E

- 0 4 3.02E

- 0 6 2.08 E

- 0 5 1.30 E

- 0 3 1. 58 E

- 03

Gas Turbine No. 2 9.47 E

- 06 9.66 E

- 0 5 3.67 E

- 0 6 3.25 E

- 0 5 1.14 E

- 0 3 1. 98 E

- 03

Gas Turbine No. 3 1.82 E

- 05 6.95 E

- 0 5 3.73 E

- 0 6 4.77E 0 5 1.27 E

- 0 3 2

. 26 E

- 03

G as Turbine No. 4 3.23 E

- 05 5.31 E

- 0 5 3.31 E

- 0 6 6.27 E

- 0 5 1.53E

- 0 3 2

. 36 E

- 03

Gas Turbine No. 5 4.77 E

- 05 4.79 E

- 0 5 2.73 E

- 0 6 7.14 E

- 0 5 1.44 E

- 0 3 2.25 E

- 03

Gas Turbine No. 6 5.62 E

- 05 4.52 E

- 0 5 2.22 E

- 0 6 7.14 E

- 0 5 1.09 E

- 0 3 1.96 E

- 03

Gas Turbine No. 7 5.62 E

- 05 4.09 E

- 05 1. 89 E

- 0 6 6.29 E

- 0 5 6.88 E

- 04 1. 64 E

- 03

Gas Turbine No. 8 5.13 E

- 05 3.82 E

- 05 1.76 E

- 0 6 5.03 E

- 0 5 3.78 E

- 04 1. 67 E

- 03

Total Project (includes turbines, fire pump, engine & cooling towers) 2.83 E

- 0 1 5.15 E

- 0 2 2.4 5 E

- 0 3 7.03 E

- 03 9.11 E

- 03 1. 64 E

- 02

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Location 30 meters
of eastern fence Devers

substation 230 m east

of the

eastern fence Wintec Wind

farm 230 m east

of the

eastern fence



### R ULE 1470

- Requirements for Stationary Diesel

- Fueled Internal Combustion and Other Compression Ignition Engines

.

No change, Fire pump comp lies with this Rule

R ULE 147

2

- Requirements for Facilities with Multiple Stationary Emergency Standby Diesel

- Fueled
Internal engines

No change

Rule 2005(g)

– Additional Requirements

No change

Rule 2005(h)

– Public Notice

No change

Rule 2005(i)

– Ru le 1401 C ompliance

. CPV Sentinel will comply with Rule 1401 as demonstrated in the Tier 4 analysis and subsequently reviewed and found to be satisfactory by AQMD modeling staff. Compliance is expected.

Rule 2005(j)

– Compliance with State and Federal NSR

.

No change

Rule 2005

– Fire pump

No change

Tier 3 engines are available, the applicant proposes to install a Tier 3 engine, the NOx+VOC are below the 3 g/bhp

- hr limits, see appendix D

RTCs

- Rule 2012(e)(2)(C)

BACT limit = 3 g/bhp

- hr
Fuel r ate = 13.5 gal/hr

EF = 3 g/bhp

- hr *(1 lb/454 g) * (1 hr/ 13.5 gal) * (1000 gal/M gal) *274 HP EF = 134 lb/mgal

Rule 2012

– RECLAIM, Monitoring Recording and Recordkeeping Requirements

No change

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### R EGULATION XVII

- Prevention of Significant Deterioration
Th e applicant estimated the emissions from the proposed project for NO 2 

### , CO, PM 10 

### , and SO 2 

### . The emission summary is Appendix C. Rule 1702 (m) (1) states that a major stationary source includes steam electric plants of more than 250 MMBTU/hr heat input. Alt hough this facility will have a heat input of greater than 250 MMBTU/hr, it only produces electric power through mechanical means and not through a steam process as defined under subsection (1) of the rule. Therefore, the proposed simple cycle units are su bject to subsection (2) which places the Major Stationary Source threshold on emissions of 250 tons per year or more. The maximum NOx potential to emit for these 8 turbines is 143 tons per year, and the maximum CO potential to emit for these 8 turbines is 188 tons per year. T herefore, this project is not considered a Major Stationary Source and is not subject to the rule 1703 NOx and CO PSD analysis

. Rule 170 1 ( b )( 1 ) requires CO BACT be applied to the Turbines. The turbines will be vented to CO control and the CO
emissions will be limited to 4 ppmv (permit condition).

INTERIM PERIOD EMISSION FACTOR S RECLAIM requires a NOx emission factor to be used for reporting emissions during the interim reporting period. The interim period is defined as a period, of no greater than 12 months from initial operation , when the CEMS has not been certified. During this period, the emissions cannot be accurately, monitored, or verified. The emissions during this period are assumed to be at uncontrolled levels. The inter im reporting period can be broken down into the two parts which includes the commissioning period in which an
uncontrolled emission rate is assumed . The emission factor for the commissioning period is an average of for the entire 150 hour period. During t his period, the turbines may be uncontrolled, partially controlled, or 100 percent controlled. T he remaining interim reporting period at which controlled rates at BACT are assumed.

Since CPV Sentinel will be included in NOx RECLAIM, an interim period e mission factor will be
determined. I n the event CEMS data is not available, NOx emissions during the interim period will be calculated using monthly fuel usage and the emission factor s derived below. There will be two interim period emission factors calc ulated for NOx.

The first factor will be for use during commissioning stage when the CTGs are assumed to be operating at uncontrolled levels and the second factor will be for use after commissioning is complete and the CTGs are assumed to operate at BACT levels

. T he specific calculations are shown in Appendix G and the results are
shown in the tables below.

Commissioning Period
Pollutants NOx CO Total emissions (lbs) 5728 11602 Total Fuel (mmscf) 301.48 301.48 Emission Factor (lb/mmscf) 19.0 38.48

Remaining Period (Non

- Commissioning start

- up )
Pollutants NOx CO Total emissions (lbs) 240881 282475 Total Fuel (mmscf) 19642 19642 Emission Factor (lb/mmscf) 12.26 14.38

C ALIFORNIA E

NVIRONMENTAL Q UALITY A CT (CEQA)

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### No change

NSPS for Stationary Gas Turbines

- 40CFR Part 60 Subpart KKKK

No change

NESHAPS for Stationary Gas Turbines

- 40CFR Part 63 Subpart YYYY This regulation applies to gas turbines located at major sources of HAP emissions. A major source is defined as a facility with emissions of 10 tpy or more of a single HAP or 25 tpy or more of a combination of HAPs. The largest single HAP emission from the turbine or engine is formaldehyde from the turbine at 900 lbs/yr, or 0. 4 5 tpy. The total combined HAPs from both sources at CPV Sentinel are less than 25 tpy (reference Appendix I ). Therefore, the CPV Sentinel facility is not a major source, and the requirements of this regulation do not apply. Ammonia is not defined as an HAP pollutant per this Rule.

EPA has indicated there are NESHAPS for a rea sources dated 3/5/2009 (40 CFR Part 63). Per table 2 of the Rule (pg 9703), the fire pump is listed between 5 0 and 500 HP, the following is required:

o Change oil and oil filter every 500 hours of operation

o Inspect air cleaner every 1000 hours

o Inspect a ll hoses and belts every 500 hours of operation

40 CFR Part 64

– Compliance Assurance Monitoring The CAM regulation applies to emission units at major stationary sources required to obtain a Title V permit, which use control equipment to achieve a specifi ed emission limit. The rule is intended to provide “reasonable assurance” that the control systems are operating properly to maintain compliance with the emission limits. Based on the emission calculations shown in Appendix K , the CPV Sentinel facility is a major source of NOx, CO, VOC, and PM10, and the turbines will be subject to an emission limit for each of these pollutants.

NOx
 Emission Limit

– NOx is subject to a 2. 5 ppm 1 hour BACT limit.
 Control Equipment

– NOx is controlled with the SCR

 Requiremen t

- As a NOx Major Source under Reclaim, the turbines are required to have CEMS under Rule 2012. The use of a continuous monitor to show compliance with an emission limit is exempt from CAM under 64.2(b)(vi).

CO
 Emission Limit

– CO is subject to a 4 .0 pp m 1 hour BACT limit (revised CO BACT limit)

.  Control Equipment

– CO is controlled with the oxidation catalyst.

 Requirement

– The turbines will be required to use a CO CEMS under Rule 218. The use of a continuous monitor to show compliance with an emission limit is exempt from CAM under 64.2(b)(vi).

VOC
 Emission Limit

– VOC is subject to a 2.0 ppm 1 hour BACT limit.
 Control Equipment

– VOC is controlled with the oxidation catalyst.
 Uncontrolled emissions

- R1 emissions per turbine s 8 tons/yr (see Appendix K)

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###  The CAM rule applies to each pollutant specific emission units (PSEU) that meets a three

- part test. The PSEU must:

a. be subject to an emission limitation or standard, and
b. use a control device to achieve compliance, and

c. have pre

- control emissions that exceed or are equivalent to the major source
threshold.

VOC emissions are subject to an emissions limit (2 ppmv) The oxidation catalyst will be used to reduce the R1 emissions below the compliance emissions
limit The pre

- control emissions does no t exceed the 10 tons per year emissions threshold per
turbine

. Thus the CAM requirements for VOC does not apply for this equipment.

 Requirement

– The oxidation catalyst is effective at operating temperatures above 300°F. The facility is required to mainta in a temperature gauge in the exhaust (condition D12.3), which will measure the exhaust temperature on a continuous basis and record the readings on an hourly basis. The exhaust temperature is required to be at least 700 °F, (with exceptions for start ups a nd shutdowns). This will insure that the oxidation catalyst is operating properly.

PM10
 Emission Limit

– PM10 is subject to a 5 lbs/hr limit. Also an annual emissions limit based on a 12 month rolling average for PM10 and S O x, see permit condition no. A63.2
 Control Equipment

– PM10 is not controlled by any specific control device.

 Requirement

– Since there is no specific control device for PM10 emissions, there are no CAM requirements.

40CFR Part 72

– Acid Rain Provisions

No change

Federal NSR program for PM 2.5, PSD and 40CFR Part 51 A ppendix S

The proposed facility is located in the Coachella Valley which is part of the Salton Sea Air Basin (SSAB).
The SSAB is in attainment with the National Ambient Air Quality Standard for PM 2.5 , and therefore the project is not subject to Non

- Atta inment NSR requirements such as offsets for PM2.5.

The applications were deemed complete prior to 07/15/08 and the Facility is located in attainment area

. This project is not subject to Appendix S requirements.

The total PM2.5 emissions ( assuming all PM 10 emissions are PM2.5) is 5 6 tons per year is well below the
10 0 ton/yr PSD threshold, and therefore it is not subject to the PSD

.

REGULATION XXX

– Title V

There is a net decrease in emissions (see Rule 212 section) from the draft Title V permit sent t o EPA on May 7, 2009. There is not relaxation of any permit permit conditions. The CO BACT limit has been reduced to 4 ppmv.

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### OVERALL EVALUATION / RECOMMENDATION(S)
Issue a F acility Permit to Construct with the following permit conditions.

PERMIT CONDITI ONS

Facility Permit con di tions

F9.1 Except for open abrasive blasting operations, the operator shall not discharge into the atmosphere from any single source of emissions whatsoever any air contaminant for a period or periods aggregating more than three minutes in any one hour which is:

(a) As dark or darker in shade as that designated No.1 on the Ringelmann Chart, as published by the United States Bureau of Mines; or

(b) Of such opacity as to obscure an observer' s view to a degree equal to or greater than does smoke described in subparagraph (a) of this condition. [RULE 401, 3

- 2

- 1984; RULE 401, 11

- 09

- 2001]

F 14.1 The operator shall maintain a copy of the MSDS on site

[Rule 431.2]

(LM S100PA CTGs ) Devices D1,D7,D13,D19,D25 , D31, D37 and D43

A63.1 The operator shall limit emission from this equipment as follows:

CONTAMINANT EMISSION LIMIT

PM 10 2, 425 LBS IN ANY ONE MONTH

CO 6
, 477 LBS IN ANY ONE MONTH

SOx 2 93 LBS IN ANY ONE MONTH

VOC 14 32 LBS IN ANY ONE MONTH The above emissions are per o ne turbine

. The operator shall calculate the monthly emissions for VOC, PM10 and SOx using the equation below and the following emission

factors: VOC: 2. 5 2 lb/mmcf; PM10: 5.71 l b/mmcf; and SOx: 0.71 lb/mmcf.

Monthly Emissions, lb/mon th = X (E.F.)

Whe re X = monthly fuel usage in mmscf/mon th and E.F. = emission factor indicated

above.

Compliance with the CO emission limit shall be verified through valid CEMS data.

The operator shall calculate the emission limit(s) for the purpose of determining compliance with the monthly CO limit in the absence of valid CEMS data by using the above equation and the following emission factor(s):

(A) During the commissioning period and prior to CO catalyst installation

– 38.48 lbs CO/mmcf

(B) After installation of the CO catalyst but prior to CO CEMS certification testing

– 14.38 lb CO/mmcf. The emission rate shall be recalculated in accordance with Condition D82.1 if the approved CEMS certification test resulted in emission concentration higher than 4 ppmv.

(C) Af ter CO CEMS certification testing

– 14.38 lb/CO mmcf. After CO CEMS certification test is approved by the AQMD, the emissions monitored by the CEMS and

calculated in accordance with condition D 82.1 shall be used to calculate emissions.

For the purposes o f this condition, the limit(s) shall be based on the emissions from a single turbine. During commissioning, the CO emissions shall not exceed 11,602 lbs

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in any one month

. During commissioning, the VOC emissions shall not exceed 620 lbs in any one month.

The operator shall provide the AQMD with written notification of the date of initial CO catalyst use within seven (7) days of this event.

For the purpose of this condition the turbine shall not commence with normal operation until the commissioning proce ss has been completed. The District shall be notified in writing once the commissioning process has been completed. Normal operations may proceed in the same commissioning month provided the operator follows the requirements

listed below.

The operator sh all calculate the commissioning emissions for VOC, SOx and PM10 for the commissioning month (beginning of the month to the last day of commissioning) using the equation below and the following emission factors: VOC: 2.06 lb/mmcf; PM10: 2. 49 lb/mmcf; and SO x: 0.12 lb/mmcf.

Commissioning Emissions, lb/month = X (E.F.)

Where X = commissioning fuel usage in mmscf/month and E.F. = emission factor indicated

above.

The commissioning emissions for VOC, SOx and PM10 shall be subtracted from the monthly

emis sions limits (listed in the table at the top of this condition) and the revised monthly emission limits will be the maximum emissions allowed for the remaining of the

month.

For the purpose of this condition, normal operations is defined as the turbine i s able to supply electrical energy to the power grid as required under contract with SCE or other entity

. [Rule 1303

– Offsets]

Turbines 1

- 5

A63.2 The operator shall limit emission from this equipment as follows:

CONTAMINANT EMISSION LIMI T

PM 10 118,120 LBS IN ANY ONE YEAR

SOx 13,928 LBS IN ANY ONE YEAR

For the purposes of this condition, the annual limit(s) shall be calculate d by using

annual and monthly fuel use data, and the following emission factors: PM 10 5.71 lb/MMSCF; and SOx: 0.25 grains/100 scf.

For the purpose of this condition, the yearly emission limit shall be defined as a period of twelve (12) consecutive months determined on a rolling basis with a new 12 month period beginning on the first day of each calendar month.
[Rule 1303

– Offsets , 40CFR 51 subpart S ]

A99.1 The 2.5 PPM NOx emission limits shall not apply during turbine com m iss i oning, start

up, and shutdown periods . The commissioning period shall not exceed 150 hours

. Start

- up time shall not exceed 25 minute s for each start

- up. Shutdown periods shall

not exceed 10 minutes for each shutdown. The turbine shall be limited to a maximum of

3 0 0 start

- ups per year. Written records of commissioning
, start

- ups and shutdowns shall be maintained and made available upon request from the Executive Officer.

For this condition start

- up shall be defined as the start up process to bring the turbine in full successful operations. If during start

- up the process is aborted and

the start

- up is restarted, then the start

- up and r estart is defined as "one start

- up ”.

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In this case the start

- up time shall not exceed one hour. The NOx emissions limited to

29. 54 pounds per hour as listed in condition A433.1

The operator shall keep records of aborted turbine start

- ups and make the reco rds available to District personnel upon request.

[Rule 2005 ] Turbine 1 through 8

A99. 3 The 4 .0 PPM CO emission limits shall not apply during turbine com m i ssi oning, start

up, and shutdown periods . The commissioning period shall not exceed 1 50 hour s.
Start

- up time shall not exceed 25 minutes for each start

- up. Shutdown periods

shall not exceed 10 minutes for each shutdown. The turbine shall be limited to a

maximum of 3 0 0 start

- ups per year. Written records of commissioning
, start

- ups and

shut downs shall be maintained and made a vailable upon request from the Executive

Officer.

For this condition start

- up shall be defined as the start up process to bring the turbine in full successful operations. If during start

- up the process is aborted and

the start

- up is restarted, then the start

- up and restart is defined as "one start

- up ”.

In this case the start

- up time shall not exceed one hour

. [Rule 1303(a)

– BACT] Turbine 1 through 8

A99. 5 The 19 LBS/MMCF NOx emission limits shall only apply during t he interim reporting

period during initial turbine commissioning to report RECLAIM emissions. The interim reporting period shall not exceed 1 2 months from entry into RECLAIM.
[Rule 2012

– Requirements for Monitoring, Reporting and Recordkeeping for Ox ides of Nitrogen Emissions]

Each Turbine

A99.7 The 12

. 26 LBS/MMCF NOx emission limits shall only apply during the interim reporting

period after initial turbine commissioning to report RECLAIM emissions. The interim reporting period shall not exceed 1 2 months from entry into RECLAIM.
[Rule 2012

– Requirements for Monitoring, Reporting and Recordkeeping for Oxides of Nitrogen Emissions]

Each turbine

A99.9 The 2 .0 PPM VOC emission limits shall not apply during turbine commissioning, start

up, and sh utdown periods. The commissioning period shall not exceed 150 hours.

Start

- up time shall not exceed 25 minutes for each start

- up. Shutdown periods

shall not exceed 10 minutes for each shutdown. The turbine shall be limited to a

maximum of 300 start

- ups per year. Written records of commissioning, start

- ups and

shutdowns shall be maintained and made available upon request from the Executive

Officer.

For this condition start

- up shall be defined as the start up process to bring the

turbine in full su ccessful operations. If during start

- up the process is aborted and

the start

- up is restarted, then the start

- up and restart is defined as "one start

- up ”.

In this case the start

- up time shall not exceed one hour.
[Rule 1303(a)

– BACT] Turbine 1 through 8

A195. 1 The 4 .0 PPMV CO emission limit(s) is averaged over 60 minutes at 15 percent O2, dry.

[Rule 1703(a)(2)

– PSD

- BACT]

Each Turbine

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A195. 2 The 2.5 PPMV NOX emission limit(s) is averaged over 60 minutes at 15 percent O2, dry.

[ Rule 2005
, Rule 1703(a)(2)

– PSD

- BACT ]

Each Turbine

A19 5 .3 The 2.0 ppmv VOC emission limit(s) is averaged over 60 minutes at 15 percent O2, dry.

[Rule 1303(a)

– BACT]

Each Turbine

A327.1 For the purpose of determining compliance with District Rule 475, combustion

contaminants emiss ions may exceed the concentration limit or the mass emission limit listed, but not both limits at the same time.
[Rule 475]

Each Turbine

A433.1 The operator shall comply at all times with the 2.5 ppm 1

- hour BACT limit for NOx,

except as defined in con dition A99.1 and for the following scenario:

Operating Scenario Maximum Hourly

Emission Limit Operational Limit

Start

- up hour 29.5 4 lb/hr NOx emissions not to exceed

29.5 4 lbs total per start

- up per turbine. Each turbine shall be

limited to 300 start

- ups per year, with each start

- up not to
exceed 25 minutes.
[Rule 1703(a)(2)

- PSD

- BACT, Rule 2005] Turbine 1 through 8

B61.1 The operator shall not use natural gas containing the following specified

c ompounds:

Compound Grains per 100 scf

H2S Less tha n 0.25

This concentration limit is an annual average based on monthly sample of natural gas composition or gas supplier documentation. Gaseous fuel samples shall be tested using

District Method 307

- 91 for total sulfur calculated as H2S.
[Rule 1303(b)

– O ffset]

Each Turbine

C1.1 The operator shall limit the fuel usage to no more than 4 25 mmcf in any one calendar

month.

For the purpose of this condition, fuel usage shall be defined as the total natural gas usage of a single turbine during a non

- co mmissioning month

.

The operator shall maintain records in a manner approved by the District to demonstrate compliance with this condition.
[Rule 1303(b)(2)

– Offset]

For turbines 1

- 8

C1.3 The operator shall limit the fuel usage to no m ore than 301 mmcf.

For the purpose of this condition, fuel usage shall be defined as the total natural gas usage of a single turbine during a commissioning period. The max fuel usage shall not exceed 301 mmcf per month

.

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The operator shall maintain re cords in a manner approved by the District to demonstrate compliance with this condition.
[Rule 1303(b)(2)

– Offset]

Each Turbine

C1.6 The operator shall limit the fuel usage to no more than 24 55 mmcf in any one calendar

year

.

For th e purpose of this condition, fuel usage shall be defined as the total natural gas usage of a single turbine during a non

- commissioning year

.

The operator shall maintain records in a manner approved by the District to demonstrate compliance with th is condition.
[Rule 1401, Rule Rule 1701 (b) ]

For turbines 1

- 8

D12.1 The operator shall install and maintain a(n) flow meter to accurately indicate the

fuel usage being supplied to the turbine.

The operator shall also install and maint ain a device to continuously record the parameter being measured
[Rule 1303(b)(2)

– Offset, Rule 2012]

Each Turbine

D29.1 The operator shall conduct source test(s) for the pollutant(s) identified below.

Pollutant to be

tested Required Tes t Method(s) Averaging Time Test Location

NOX emissions District Method

100.1 1 hour Outlet of the SCR

CO emissions District Method

100.1 1 hour Outlet of the SCR

SOX emissions AQMD Laboratory

Method 307

- 91 Not applicable Fuel Sample

VOC emissions Dist rict Method

25.3 1 hour Outlet of the SCR

PM 10 emissions District Method 5 4 Hours Outlet of the SCR

NH3 emissions District method

207.1 and 5.3 or

EPA method 17 1 hour Outlet of the SCR

The test shall be conducted after AQMD approval of the source tes t protocol, but no

later the later of 180 days after initial start

- up or three hundred hours of operations after start

- up . The AQMD shall be notified of the date and time of the test at least 10 days prior to the test.

The test shall be conducted to det ermine the oxygen levels in the exhaust. In addition, the tests shall measure the fuel flow rate (CFH), the flue gas flow rate,

and the turbine generating output in MW.

The test shall be conducted in accordance with AQMD approved test protocol. The protocol shall be submitted to the AQMD engineer no later than 45 days before the proposed test date and shall be approved by the AQMD before the test commences. The test protocol shall include the proposed operating conditions of the turbine during the tests, the identity of the testing lab, a statement from the testing lab certifying that it meets the criteria of R ule 304, and a description of all sampling and analytical procedures.

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### ENGINEERING ANALYSIS / EVALUATION PROCESSED BY: Roy Olivare s REVIEWED BY:

The test shall be conducted when this equipment is operating at maximum, average, and

minimum loads.

The test shall be conducted for compliance verification of the BACT VOC 2.0 ppmv

limit.

For natural gas fired turbines only, VOC compliance shall be demonstrated as follows:
a) Stack gas samples are extracted into Summa canisters maintaining a final canister

pressure between 400

- 500 mm Hg absolute, b) Pressurization of canisters are done

w ith zero gas analyzed/certified to contain less than 0.05 ppmv total hydrocarbon as carbon, and c) Analysis of canister s are per EPA Method TO

- 12 (with pre concentration) and temperature of canisters when extracting samples for analysis is not below 70 deg F.

The use of this alternative method for VOC compliance determination does not mean

that it is more accurate tha n AQMD Method 25.3, nor does it mean that it may be

used in lieu of AQMD Method 25.3 without prior approval except for the determination of compliance with the VOC BACT level of 2.0 ppmv calculated as carbon for natural gas fired turbines.

Because t he VOC BACT level was set using data derived from various source test results, this alternate VOC compliance method provides a fair comparison and represents the best sampling and analysis technique for this purpose at this time.

The test results shall be reported with two significant digits.

For the purpose of this condition, alternative test method may be allowed for each of the above pollutants upon concurrence of AQMD ,EPA and CARB

. [Rule 1303(a)(1)

– BACT, Rule 1303(b)(2)

– Offset, Rule 2005 , Reg 1703(a

- PSD

- BACT ]

Each Turbine

D29.2 The operator shall conduct source test(s) for the pollutant(s) identified below.

Pollutant to be

tested Required Test
Method(s) Averaging Time Test Location

NH3 emissions District method

207.1 and 5.3 or

EPA metho d 17 1 hour Outlet of the SCR

The test shall be conducted and the results submitted to the District within 45 days
after the test date. The AQMD shall be notified of the date and time of the test at least 7 days prior to the test.

The test shall be conducted at least quarterly during the first twelve months of operation and at least annually thereafter. The NOx concentration, as determined by the CEMS, shall be simultaneously recorded during the ammonia slip test. If the CEMS is inoperable, a test shall be conducted to determine the NOx emissions using District Method 100.1 measured over a 60 minute averaging time period.

If the turbine is not in operation during one quarter, then no testing is required during that quarter

The test shall be conducted to demonstrate compliance with the Rule 1303 BACT

concentrat i on limit
[Rule 1303(a)(1)

– BACT]

Each Turbine

D29.3 The operator shall conduct source test(s) for the pollutant(s) identified below.

Pollutant to be

tested Required Test

Meth od(s) Averaging Time Test Location

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### ENGINEERING ANALYSIS / EVALUATION PROCESSED BY: Roy Olivare s REVIEWED BY:

SOX emissions AQMD Laboratory

Method 307

- 91 Not applicable Fuel Sample

VOC emissions District Method

25.3 1 hour Outlet of the SCR

PM10 emissions District Method 5 4 hours Outlet of the SCR

The test shall be cond ucted at least once every three years.

The test shall be conducted to determine the oxygen levels in the exhaust. In addition, the tests shall measure the fuel flow rate (CFH), the flue gas flow rate, and the turbine generating output in MW.

The tes t shall be conducted in accordance with AQMD approved test protocol. The protocol shall be submitted to the AQMD engineer no later than 45 days before the proposed test date and shall be approved by the AQMD before the test commences. The
test protoco l shall include the proposed operating conditions of the turbine during the tests, the identity of the testing lab, a statement from the testing lab certifying that it meets the criteria of Rule 304, and a description of all sampling and analytical pro cedures.

The test shall be conducted when this equipment is operating at maximum, average, and

minimum load.

The test shall be conducted for compliance verification of the BACT VOC 2.0 ppmv

limit.

For natural gas fired turbines only, VOC complianc e shall be demonstrated as follows:
a) Stack gas samples are extracted into Summa canisters maintaining a final canister

pressure between 400

- 500 mm Hg absolute, b) Pressurization of canisters are done with zero gas analyzed/certified to contain less than 0.05 ppmv total hydrocarbon as carbon, and c) Analysis of canisters are per EPA Method TO

- 12 (with pre concentration) and temperature of canisters when extracting samples for analysis is not below 70 deg F.

The use of this alternative method fo r VOC compliance determination does not mean that it is more accurate than AQMD Method 25.3, nor does it mean that it may be used in lieu of AQMD Method 25.3 without prior approval except for the determination of compliance with the VOC BACT level of 2. 0 ppmv calculated as carbon for natural gas

fired turbines.

Because the VOC BACT level was set using data derived from various source test results, this alternate VOC compliance method provides a fair comparison and represents the best sampling and an alysis technique for this purpose at this time.

The test results shall be reported with two significant digits.

For the purpose of this condition, alternative test method may be allowed for each of the above pollutants upon concurrence of AQMD , EPA and CARB

. [Rule 1303(a)(1)

– BACT, Rule 1303(b)(2)

– Offset , Reg 1703(a

- PSD

- BACT ]

Each Turbine

D82.1 The operator shall install and maintain a CEMS to measure the following parameters:

CO concentration in ppmv

Concentrations shall be corrected to 15 p ercent oxygen on a dry basis The CEMS shall be installed and operated no later than 90 days after initial start

up of the turbine, and in accordance with an approved AQMD Rule 218 CEMS plan application. The operator shall not install the CEMS prior to rec eiving initial

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### ENGINEERING ANALYSIS / EVALUATION PROCESSED BY: Roy Olivare s REVIEWED BY:

approval from AQMD. Within two weeks of the turbine start

- up, the operator shall provide written notification to the District of the exact date of start

- up.

The CEMS shall be installed and operated to measure CO concentrations over a 15

mi nute averaging time period.

The CEMS would convert the actual CO concentrations to mass emission rates (lbs/hr) using the equation below and record the hourly emission rates on a continuous

basis.

CO Emission Rate, lbs/hr = K Cco Fd[20.9%

- %O2 d)][(Qg * HHV)/10 6 ], where

K = 7.267 *10 - 8 (lb/scf)/ppm

Cco = Average of four consecutive 15 min. ave. CO concentration, ppm

Fd = 8710 dscf/MMBTU natural gas

%O 2 d = H o urly ave. % by vol. O 2 dry, corresponding to Cco

Qg = Fuel gas usage during the ho ur, scf/hr

HHV = Gross high heating value of fuel gas, BTU/scf
[Rule 1303(a)(1)

– BACT, Rule 218 ]

Each Turbine

D82. 2 The operator shall install and maintain a CEMS to measure the following

parameters:

NOx concentration in ppmv

Concentrations s hall be corrected to 15 percent oxygen on a dry basis

.

The CEMS shall be installed and operating no later than 90 days after initial start

up of the turbine and shall comply with the requirements of Rule 2012. During the interim period between the i nitial start

- up and the provisional certification date of the CEMS, the operator shall comply with the monitoring requirements of Rule 2012(h)(2) and 2012(h)(3). Within two weeks of the turbine start

- up date, the operator shall provide written notifica tion to the District of the exact date of

start

- up.

The CEMS shall be installed and operating (for BACT purposes only) no later than 90 days after initial start up of the turbine.
[Rule 20 05 ; Rule 2012 , Rule 1703 ]

Each Turbine

E193.1 The operator s hall upon completion of construction, operate and maintain this

equipment according to the following specifications:

In accordance with all mitigation measures stipulated in the final California Energy

Commission decision for the 0 7

- AFC

- 3 project.
[CE QA]

H23.1 Th is equipment is subject to the applicable requirements of the following Rules or

Regulations :

Contaminant Rule Rule/Subpart

NOx 40CFR60, SUBPART KKKK

SOX 40CFR60, SUBPART KKKK

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### ENGINEERING ANALYSIS / EVALUATION PROCESSED BY: Roy Olivare s REVIEWED BY:

[ 40CFR 60 SUBPART KKKK ]

Each turbine

I296.1 This equipment shall not be operated unless the operator demonstrates to the

Executive Officer that the facility holds sufficient RTCs to offset the prorated annual emissions increase for the first compliance year of operation. In addition, this equipment shall not be operated un less the operator demonstrates to the Executive Officer that, at the commencement of each compliance year after the first compliance year of operation, the facility holds sufficient RTCs in an amount equal to the annual emission increase.

To comply w ith this condition, the operator shall prior to the 1 st compliance year

hold a minimum NOx RTCs of 35 838 lbs/yr. This condition shall apply during the 1 st
12 months of operation, commencing with the initial operation of the gas turbine

.

To comply w ith this condition, the operator shall, prior to the beginning of all years subsequent to the 1 st compliance year, hold a minimum of 30
, 110 lbs /yr of NOx RTCs for operation of the gas turbine.

In accordance with Rule 2005(f), unused RTC’s may be sold only during the reconciliation period for the fourth quarter of the applicable compliance year

inclusive of the 1 st compliance year.

This condition shall apply to each turbine individually.
[Rule 2005] Turbines 1 though 8

K40.1 The operator shall provide to the District a source test report in accordance with the

following specifications:

Source test results shall be submitted to the District no later than 60 days after

the source test was conducted. Emission data shall be expressed in ter ms of concentration (ppmv) corrected to 15

perc ent oxygen (dry basis), mass rate (lb/hr) , and lb/MMCF. In addition, solid PM emissions, if required to be tested, shall also be reported in terms of grains/DSCF. All exhaust flow rate shall be expr essed in terms of dry standard cubic feet per minute (DSCFM) and dry actual cubic feet per minute (DACFM)

. All moisture concentration shall be expressed in terms of percent corrected to 15
percent oxygen.
Source test results shall also include the ox ygen levels in the exhaust , fuel flow rate (CFH), heating content of the fuel, the flue gas temperature, and the generator power output (MW) under which the test was conducted.
[Rule 1303(a)(1)

– BACT, Rule 1303(b)(2)

– Offset, Rule 1702(a)(2)

- PSD

- BACT, Ru le 2005]

Each Turbine

K67.1 The operator shall keep records in a manner approved by the District, for the

following parameter(s) or item(s):

Natural gas fuel use after CEMS certification Natural gas fuel use during the commissioning period

Natural gas fuel use after the commissioning period and prior to CEMS

certification
[Rule 2012]

Each Turbine

(SCR/CO Catalyst)

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### ENGINEERING ANALYSIS / EVALUATION PROCESSED BY: Roy Olivare s REVIEWED BY:

A195. 4 The 5 ppmv NH3 emission limit is averaged over 60 minutes at 15% O2, dry basis. The

operator shall calculate and continu ously record the NH3 slip concentration using the following:

NH3 (ppmv) = [a

– b*c/1EE+06]*1EE+06/b

where, a = NH3 injection rate (lbs/hr)/17(lb/lb

- mol) b = dry exhaust gas flow rate ( scf /hr)/ 385. 3 scf /lb

- mol) c = change in measured NOx across the SCR (ppmvd at 15% O2)

The operator shall install and maintain a NOx analyzer to measure the SCR inlet NOx ppmv accurate to plus or minus 5 percent calibrated at least once every twelve

months. The NOx analyzer shall be installed and operated w ithin 90 days of initial start

up. The operator shall use the above described method or another alternative method approved by the Executive Officer. The ammonia slip calculation procedures described above shall not be used for compliance determ ination or emission information without corroborative data using an approved reference method for the determination of ammonia.
[Rule 1303(a)(1)

– BACT]

D12. 2 The operator shall install and maintain a(n) flow meter to accurately indicate the

flow rate of the total hourly throughput of injected ammonia.

The operator shall also install and maintain a device to continuously record the parameter being measured. The measuring device or gauge shall be accurate to within plus or minus 5 percent.

I t shal l be calibrated once every twelve months. The records shall be kept on site and made available to AQMD personnel upon request The ammonia injection system shall be placed in full operation as soon as the minimum temperature is reached. The minimum temperat ure is listed as 540 degrees F.

at the i nlet to the SCR reactor

. [Rule 1303(a)(1)

– BACT, Rule 20 05 ]

D12. 3 The operator shall install and maintain a(n) temperature gauge to accurately indicate

the temperature in the exhaust at the inlet to the SCR react or.

The operator shall also install and maintain a device to continuously record the
parameter b eing measured. The measuring device or gauge shall be accurate to within plus or minus 5 percent. It shall be calibrated once every twelve months.

The catalyst temperature range shall be remain between 740 degree F and 8 40 degree

F. The catalyst inlet temperature shall not exceed 8 40 degrees F. The temperature range requirement of this condition does not apply during start

- up operations of the turbine n ot to exceed 25 minutes per start

- up

.

For this condition start

- up shall be defined as the start up process to bring the turbine in full successful operations. If during start

- up the process is aborted

and the start

- up is restarted, then the start

- up an d restart is defined as "one

start

- up ”. In this case the start

- up time shall not exceed one hour

. [Rule 1303(a)(1)

– BACT, Rule 20 05
, 1702 (a)(2)

- PSD

- BACT ]

D12. 4 The operator shall install and maintain a(n) pressure gauge to accurately indicate t he

d ifferential pressure across the SCR catalyst bed in inches of water column.

The operator shall also install and maintain a device to continuously record the
parameter being measured.

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The measuring device or gauge shall be accurate to within plus or minus 5 percent. It shall be calibrated once every twelve months. The pressure drop across the catalyst shall not exceed 12 inches water column
[Rule 1303(a)(1)

– BACT, Rule 20 05 , Rule 1702 (a)(2)

- PSD

- BACT ]

E179.1 For the purpose of t he following co ndition number(s), continuously record shall be

defined as recording at least once every hour and shall be calculated based upon the average of the continuous monitoring for that hour.

Condition Number D12. 2

Condition Number D12. 3
[Rule 1303(a)(1)

– BACT , Rule 2005

- BACT, Rule 1702(a)(2)

- PSD

- BACT ]

E179.2 For the purpose of the following condition numbers, continuous ly record shall be

defined as measuring at least once every month and shall be calculated based upon the average of the continuous mon itoring for that month.

Condition Number: D12. 4
[Rule 1303(a)(1)

– BACT , Rule 1702(a)(2)

- PSD

- BACT ]

E193.1 The operator shall upon completion of construction, operate and maintain this

equipment according to the following specifications:

In accord ance with all mitigation measures stipulated in the final California Energy Commission decision for the 0 7

- AFC

- 3 project.
[CEQA]

(Ammonia Storage Tank)

C157.1 The operator shall install and maintain a pressure relief valve with a minimum

pressure set at 25 psig

. [Rule 1303(a)(1)

– BACT]

E 144.1 The operator shall vent this equipment, during filling, only to the vessel from which

it is being filled.

. [Rule 1303(a)(1)

– BACT]

E193.1 The operator shall upon completion of construction, operate and ma intain this

equipment according to the following specifications:

In accordance with all mitigation measures stipulated in the final California Energy Commission decision for the 0 7

- AFC

- 3 project.
[CEQA]

K67.2 The operator shall keep records in a m anner approved by the Executive Officer, for the

following parameter(s) or item(s):

The operator shall document an inspection each time the tank is filled to insure the vapor recovery equipment is consistently and properly used
[Rule 1303(a)(1)

– BAC T]

( Emergency Fire Pump )

C1. 4 The operator shall limit the operating time to no more than 50 hours in any one year.

For the purposes of this condition, the operating time is inclusive of time

allotted for maintenance and testing
[ Rule 1110.2, Rule 1304, Rule 1470, Rule 2012]

D12.5 The operator shall install and maintain a(n) non

- resettable elapsed meter to accurately

indicate the elapsed operating time of the engine.

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### ENGINEERING ANALYSIS / EVALUATION PROCESSED BY: Roy Olivare s REVIEWED BY:

[Rule 1304, Rule 1470, Rule 2012]

B61. 2 The operator shall only use diesel fuel containing th e following specified compounds:

COMPOUND Range P PM BY WEIGHT

Sulfur Less than or equal to 15

The operator shall maintain a copy of the MSDS on site
[Rule 431.2]

E193.1 The operator shall upon completion of construction, operate and ma intain this

equipment according to the following specifications:

In accordance with all mitigation measures stipulated in the final California Energy Commission decision for the 07

- AFC

- 3 project.

I296. 3 This equipment shall not be operated unless the operator demonstrates to the Executive Officer the facility holds sufficient RTCs to offset the prorated annual emissions increase for the first compliance year of operation. In addition, this equipment shall not be operated unless the operator de monstrates to the Executive Officer that, at the commencement of each compliance year after the first compliance year of operation, the facility holds sufficient RTCs in an amount equal to the annual emissions

increase.

To comply with this conditio n, the operator shall, prior to each compliance year

hold a minimum NOx RTCs of 77 lbs.

In accordance with Rule 2005(f), unused RTCs may be sold only during the reconciliation period for the fourth quarter of the applicable compliance year

inclusive o f the 1 st compliance year.
[Rule 2005]

K67. 3 The operator shall keep records in a manner approved by the Executive Officer, for the

following parameter(s) or item(s):

M anual and automatic operation and shall list all engine operations in each of the following areas:

E mergency use hours of operation

M aintenance and testing hours

O ther operating hours (describe the reason for operation)

I n addition, each time the engine is started manually, the log shall include the date of operation and the ti mer reading in hours at the beginning and end of operation. the log shall be kept for a minimum of five calendar years prior to the current year and made available to district personnel upon request. the total hours of operation for the previous calendar year shall be recorded sometime during the first 15 days of J anuary of each year.
[Rule 1110.2 , Rule 1470 ]

(Section D; Device E 54 )

K67. 5 The operator shall keep records, in a manner approved by the District, for

the following parameter(s) or item(s):

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### ENGINEERING ANALYSIS / EVALUATION PROCESSED BY: Roy Olivare s REVIEWED BY:

For architectural applications where thinners, reducers, or other VOC containing materials are added, maintain daily records for each coating consisting of (a) coating type, (b) VOC content as applied in grams per liter (g/l) of materials used fo r low

- solids coatings, (c) VOC content as applied in g/l of coating, less water and exempt solvent, for other coatings.

For architectural applications where no thinners, reducers, or other VOC containing materials are added, maintain semi

- annual records consisting of (a) coating type, (b) VOC content as applied in grams per liter (g/l) of materials used for low

- solids coatings, (c) VOC content as applied in g/l of coating, less water and exempt solvent, for other coatings.

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### ENGINEERING ANALYSIS / EVALUATION PROCESSED BY: Roy Olivare s REVIEWED BY:



### CPV SENTINEL ENERGY PROJECT List of Appendices

1. Appendix A

– LMS100PA Hourly Emissions

 Normal Operations

 Start

- up Emissions

 Shutdown Emissions

2. Appendix B

– LMS100PA Monthly Emissions

 Commissioning year

 Non

- Commissioning year

 30

- Day Averages (Commissioni ng year)

 30

- Day Averages (Non

- commissioning year)

3. Appendix C

– LMS100PA Annual Emissions

 Commissioning year

 Non

- commissioning year

4. Appendix D

– Emergency Fire Pump Emissions

5. Appendix E

– Commissioning Emissions

6. Appendix F

– NOx RTC calculations

7. Appen dix G

– Interim Period Emission Factors

8. Appendix H

– Interim Period Emission Factors

9. Appendix I

– TAC Emissions

10. Appendix J

– Additional Fees calculations

11. Appendix K

- Uncontrolled VOC emissions for each turbine

12. Appendix L

- A B1318 Mitigation fees and AB 1318 Offset Report

13. Appendix M

- Review of an Air Quality Analysis and a Health Risk Assessment for Amendment to Permit to Construct/Permit to Operate Application for the CPV Sentinel Energy Project (A/N’s 472139 thru 472158 )

14. Appendix N

- Offset Evaluation Se ction152707 DRAFT
March 02, 2010 Date: Facility ID:

Revision #:



## FACILITY PERMIT TO OPERATE Title Page



## NOTICE

IN ACCORDANCE WITH RULE 206

, THIS PERMIT TO OPERATE OR A COPY THEREOF

MUST BE KEPT AT THE LOCATION FOR WHICH IT IS ISSUED.

THIS PERMIT DOES NOT AUTHORIZE THE EMISSION OF AIR CONTAMINANTS IN EXCESS

OF THOSE ALLOWED BY DIVISION 26 OF THE HEALTH AND SAFETY CODE OF THE

STATE OF CALIFORNIA OR THE RULES OF THE SOUTH COAST AIR QUALITY

MANAGEMENT DISTRICT. THIS PERMIT SHALL NOT BE CONSTRUED AS PERMISSION TO

VIOLATE EXISTING LAWS, ORDINANCES, REGULATIONS OR STATUTES OF ANY OTHER
FEDERAL, STATE OR LOCAL GOVERNMENTAL AGENCIES. 

## CPV SENTINEL LLC 62575 POWER LINE RD DESERT HOT SPRINGS, CA 92240

By___________________
Mohsen Nazemi, P.E. Deputy Executive Officer Engineering & Compliance Barry R. Wallerstein, D. Env.

EXECUTIVE OFFICER

## FACILITY PERMIT TO OPERATE

TABLE OF CONTENTS 

## CPV SENTINEL LLC Table of Content

DRAFT 152707

March 02, 2010 Date: Facility ID:

Revision #:



### Date Issued Revision # Description Section

03/02/2010 DRAFT Facility Information A

03/02/2010 DRAFT RECLAIM Annual Emission Allocation B

TO BE DEVELOPED

Facility Plot Plan C

03/02/2010 DRAFT Facility Description and Equipment Specific Conditions D

03/02/2010 DRAFT Administrative Conditions E

03/02/2010 DRAFT RECLAIM Monitoring and Source Testing Requirements F

03/02/2010 DRAFT Recordkeeping and Reporting Requirements for RECLAIM Sources G

03/02/2010 DRAFT Permit To Construct and Temporary Permit to Operate H

03/02/2010 DRAFT Compliance Plans & Schedules I

03/02/2010 DRAFT Air Toxics J

03/02/2010 DRAFT Title V Administration K

Appendix

03/02/2010 DRAFT NOx and SOx Emitting Equipment Exempt
From Written Permit Pursuant to Rule
219 A

03/02/2010 DRAFT Rule Emission Limits B

## SECTION A: FACILITY INFORMATION Page:



## CPV SENTINEL LLC Date: Facility ID: Section A



## FACILITY PERMIT TO OPERATE 1

152707

DRAFT March 02, 2010 Revision #:



### EQUIPMENT LOCATION: LEGAL OWNER &/OR OPERATOR:

LEGAL OPERATOR (if different than owner):

MAILING ADDRESS:

RESPONSIBLE OFFICIAL:

TITLE:

TELEPHONE NUMBER:

CONTACT PERSON:

TITLE: CPV SENTINEL LLC

MARK TURNER

PROJECT MANAGER

(415) 293-1463

MARK TURNER

PROJECT MANAGER



### TELEPHONE NUMBER: (415) 293-1463 62575 POWER LINE RD

DESERT HOT SPRINGS, CA 92240

55 SECOND ST STE 525

SAN FRANCISCO, CA 94105



### INITIAL TITLE V PERMIT ISSUED: March 02, 2010

March 01, 2015 

### TITLE V PERMIT EXPIRATION DATE:



### TITLE V RECLAIM

NOx:

SOx:

CYCLE:

ZONE: YES

NO

0

COASTAL YES

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 Page:

Date: Facility ID: Section B 1

152707

Revision #:



## SECTION B: RECLAIM ANNUAL EMISSION ALLOCATION



## NOT APPLICABLE

## CPV SENTINEL LLC

SECTION C: FACILITY PLOT PLAN 

## FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 Date: Facility ID: 152707

Revision #: Page: Section C 1



## ( TO BE DEVELOPED)March 02, 2010 DRAFT



## CPV SENTINEL LLC

SECTION D: FACILITY DESCRIPTION AND EQUIPMENT SPECIFIC CONDITIONS



## FACILITY PERMIT TO OPERATE Date: Facility ID: 152707

Revision #: Page: Section D 1



### The operator shall comply with the terms and conditions set forth below:

* 

### Emissions
And Requirements RECLAIM
Source Type/
Monitoring

Unit Equipment Connected

To ID

No. Conditions



### Process 3 : 

### RULE 219 EXEMPT EQUIPMENT SUBJECT TO SOURCE SPECIFIC RULES

RULE 219 EXEMPT EQUIPMENT,

COATING EQUIPMENT, PORTABLE,

ARCHITECTURAL COATINGS E54 VOC : (9) [ RULE 1113, 11-8-1996;

RULE 1113, 7-13-2007; RULE

1171, 11-7-2003; RULE 1171,

2-1-2008 ] C3 K67.5

RULE 219 EXEMPT EQUIPMENT,

EXEMPT HAND WIPING

OPERATIONS E55 VOC : (9) [ RULE 1171, 11-7-2003;

RULE 1171, 2-1-2008 ] C3

* (1) (1A) (1B) Denotes RECLAIM emission factor (2) (2A) (2B) Denotes RECLAIM emission rate

(3) Denotes RECLAIM concentration limit (4) Denotes BACT emission limit
(5) (5A) (5B) Denotes command and control emission limit (6) Denotes air toxic control rule limit
(7) Denotes NSR applicability limit (8) (8A) (8B) Denotes 40 CFR limit (e.g. NSPS, NESHAPS, etc.)
(9) See App B for Emission Limits (10) See section J for NESHAP/MACT requirements

** Refer to section F and G of this permit to determine the monitoring, recordkeeping and reporting requirements for this device.

## SECTION D: DEVICE ID INDEX 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 Page: 152707

Date: Facility ID: Section D

Revision #: 2



## The following sub-section provides an index to the devices that make up the facility description sorted by device ID.

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 Page: 152707

Date: Facility ID: Section D

Revision #: 3



## SECTION D: DEVICE ID INDEX

Device Index For Section D

Device ID Section D Page No. Process System



### 3 1 E54 0

3 1 E55 0

## SECTION D: FACILITY DESCRIPTION AND EQUIPMENT SPECIFIC CONDITIONS

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 Page: 152707

Date: Facility ID: Section D

Revision #: 4



### FACILITY CONDITIONS

Except for open abrasive blasting operations, the operator shall not discharge into the atmosphere from any single source of emissions whatsoever any air contaminant for a period or periods aggregating more than three minutes in any one hour which is:

(a ) As dark or darker in shade as that designated No .1 on the Ringelmann Chart, as published by the United States Bureau of Mines; or

(b ) Of such opacity as to obscure an observer's view to a degree equal to or greater than does smoke described in subparagraph (a) of this condition. F9.1

[ RULE 401, 3-2-1984; 

### RULE 401, 11-9-2001]

The operator shall not purchase diesel fuel containing sulfur compounds in excess of 15 ppm by weight as supplied by the supplier. F14.1

The operator shall maintain a copy of the MSDS on site

[ RULE 431.2, 5-4-1990; 

### RULE 431.2, 9-15-2000]



### DEVICE CONDITIONS

Record Keeping/Reporting K.

The operator shall keep records, in a manner approved by the District, for the following parameter(s) or item(s): K67.5

## SECTION D: FACILITY DESCRIPTION AND EQUIPMENT SPECIFIC CONDITIONS

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 Page: 152707

Date: Facility ID: Section D

Revision #: 5



### For architectural applications where no thinners, reducers, or other VOC containing
materials are added, maintain semi

- annual records for all coating consisting of (a) coating type, (b ) VOC content as supplied in grams per liter (g/l ) of materials for
low- solids coatings, (c ) VOC content as supplied in g / l of coating, less water and exempt solvent, for other coatings.

For architectural applications where thinners, reducers, or other VOC containing
materials are added, maintain daily records for each coating consisting of (a ) coating
type, (b ) VOC content as applied in grams per liter (g/l ) of materials used for
low- solids coatings, (c ) VOC content as applied in g / l of coating, less water and exempt solvent, for other coatings.

[ RULE 1113, 11-8-1996; 

### RULE 1113, 7-13-2007]

[Devices subject to this condition : E54]

## FACILITY PERMIT TO OPERATE

CPV SENTINEL LLC

SECTION E: ADMINISTRATIVE CONDITIONS

The operating conditions in this section shall apply to all permitted equipment at this facility unless superseded by condition(s) listed elsewhere in this permit. DRAFT
March 02, 2010

1 Page: 152707

Date: Facility ID: Section E

Revision #:



### 1. The permit shall remain effective unless this permit is suspended, revoked, modified, reissued, denied, or it is expired for nonpayment of permit processing or annual operating fees. [201, 203, 209, 301]

a. The permit must be renewed annually by paying annual operating fees, and the permit shall expire if annual operating fees are not paid pursuant to requirements of Rule 301(d). [301(d)]

b. The Permit to Construct listed in Section H shall expire one year from the Permit to Construct issuance date, unless a Permit to Construct extension has been granted by the Executive Officer or unless the equipment has been constructed and the operator has notified the Executive Officer prior to the operation of the equipment, in which case the Permit to Construct serves as a temporary Permit to Operate. [202, 205]

c. The Title V permit shall expire as specified under Section K of the Title V permit. The permit expiration date of the Title V facility permit does not supercede the requirements of Rule 205. [205, 3004]

2. The operator shall maintain all equipment in such a manner that ensures proper operation of the equipment. [204]

3. This permit does not authorize the emissions of air contaminants in excess of those allowed by Division 26 of the Health and Safety Code of the State of California or the Rules and Regulations of the AQMD. This permit cannot be considered as permission to violate existing laws, ordinances, regulations, or statues of other governmental agencies. [204]

4. The operator shall not use equipment identified in this facility permit as being connected to air pollution control equipment unless they are so vented to the identified air pollution control equipment which is in full use and which has been included in this permit. [204]

## FACILITY PERMIT TO OPERATE

CPV SENTINEL LLC

SECTION E: ADMINISTRATIVE CONDITIONS DRAFT
March 02, 2010

2 Page: 152707

Date: Facility ID: Section E

Revision #:



### 5. The operator shall not use any equipment having air pollution control device(s) incorporated within the equipment unless the air pollution control device is in full operation. [204]

6. The operator shall maintain records to demonstrate compliance with rules or permit conditions that limit equipment operating parameters, or the type or quantity of material processed. These records shall be made available to AQMD personnel upon request and be maintained for at least five years. [204]

7. The operator shall maintain and operate all equipment to ensure compliance with all emission limits as specified in this facility permit. Compliance with emission limits shall be determined according to the following specifications, unless otherwise specified by AQMD rules or permit conditions: [204]

a. For internal combustion engines and gas turbines, measured concentrations shall be corrected to 15 percent stack-gas oxygen content on a dry basis and be averaged over a period of 15 consecutive minutes; [1110.2, 1134]

b. For other combustion devices, measured concentrations shall be corrected to 3 percent stack-gas oxygen content on a dry basis and be averaged over a period of 15 consecutive minutes; [1146, 1146.1, 204]

c. For non-combustion sources, compliance with emission limits shall be determined and averaged over a period of 60 minutes; [204]

d. For the purpose of determining compliance with Rule 407, carbon monoxide (CO) shall be measured on a dry basis and be averaged over 15 consecutive minutes, and sulfur compounds which would exist as liquid or gas at standard conditions shall be calculated as sulfur dioxide (SO2) and be averaged over 15 consecutive minutes; [407]

e. For the purpose of determining compliance with Rule 409, combustion contaminant emission measurements shall be corrected to 12 percent of carbon dioxide (CO2) at standard conditions and averaged over a minimum of 15 consecutive minutes. [409]

## FACILITY PERMIT TO OPERATE

CPV SENTINEL LLC

SECTION E: ADMINISTRATIVE CONDITIONS DRAFT
March 02, 2010

3 Page: 152707

Date: Facility ID: Section E

Revision #:



### f. For the purpose of determining compliance with Rule 475, combustion contaminant emission measurements shall be corrected to 3 percent of oxygen (O2) at standard conditions and averaged over 15 consecutive minutes or any other averaging time specified by the Executive Officer. [475]

8. The operator shall, when a source test is required by AQMD, provide a source test protocol to AQMD no later than 60 days before the proposed test date. The test shall not commence until the protocol is approved by AQMD. The test protocol shall contain the following information: [204, 304]

a. Brief description of the equipment tested.

b. Brief process description, including maximum and normal operating temperatures, pressures, throughput, etc.

c. Operating conditions under which the test will be performed.

d. Method of measuring operating parameters, such as fuel rate and process weight. Process schematic diagram showing the ports and sampling locations, including the dimensions of the ducts and stacks at the sampling locations, and distances of flow disturbances, (e.g. elbows, tees, fans, dampers) from the sampling locations (upstream and downstream).

e. Brief description of sampling and analytical methods used to measure each pollutant, temperature, flow rates, and moisture.

f. Description of calibration and quality assurance procedures.

g. Determination that the testing laboratory qualifies as an "independent testing laboratory" under Rule 304 (conflict of interest).

9. The operator shall submit a report no later than 60 days after conducting a source test, unless otherwise required by AQMD rules or equipment-specific conditions. The report shall contain the following information: [204]

a. The results of the source test.

## FACILITY PERMIT TO OPERATE

CPV SENTINEL LLC

SECTION E: ADMINISTRATIVE CONDITIONS DRAFT
March 02, 2010

4 Page: 152707

Date: Facility ID: Section E

Revision #:



### b. Brief description of the equipment tested.

c. Operating conditions under which the test was performed.

d. Method of measuring operating parameters, such as fuel rate and process weight. Process schematic diagram showing the ports and sampling locations, including the dimensions of the ducts and stacks at the sampling locations, and distances of flow disturbances, (e.g. elbows, tees, fans, dampers) from the sampling locations (upstream and downstream).

e. Field and laboratory data forms, strip charts and analyses.

f. Calculations for volumetric flow rates, emission rates, control efficiency, and overall control efficiency.

10. The operator shall, when a source test is required, provide and maintain facilities for sampling and testing. These facilities shall comply with the requirements of AQMD Source Test Method 1.1 and 1.2. [217]

11. Whenever required to submit a written report, notification or other submittal to the Executive Officer, AQMD, or the District, the operator shall mail or deliver the material to: Deputy Executive Officer, Engineering and Compliance, AQMD, 21865 E. Copley Drive, Diamond Bar, CA 91765-4182. [204]

## SECTION F: RECLAIM MONITORING AND SOURCE TESTING REQUIREMENTS 

## FACILITY PERMIT TO OPERATE

CPV SENTINEL LLC DRAFT March 02, 2010 152707 Page: 1

Date: Facility ID: Section F

Revision #:



## NOT APPLICABLE

## SECTION G: RECORDKEEPING AND REPORTING REQUIREMENTS FOR 

## FACILITY PERMIT TO OPERATE

CPV SENTINEL LLC DRAFT March 02, 2010 152707 Page: 1

Date: Facility ID: Section G

Revision #:



## RECLAIM SOURCES



## NOT APPLICABLEMarch 02, 2010 DRAFT



## FACILITY PERMIT TO OPERATE

SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE 

## CPV SENTINEL LLC 152707 Page: 1

Date: Facility ID: Section H

Revision #:



### The operator shall comply with the terms and conditions set forth below:

Conditions Emissions
And Requirements RECLAIM
Source Type/
Monitoring Unit Connected

To ID

No. Equipment *



### Process 1 : 

### INTERNAL COMBUSTION

System 1 : 

### GAS TURBINES, POWER GENERATION

* (1) (1A) (1B) Denotes RECLAIM emission factor (2) (2A) (2B) Denotes RECLAIM emission rate

(3) Denotes RECLAIM concentration limit (4) Denotes BACT emission limit
(5) (5A) (5B) Denotes command and control emission limit (6) Denotes air toxic control rule limit
(7) Denotes NSR applicability limit (8) (8A) (8B) Denotes 40 CFR limit (e.g. NSPS, NESHAPS, etc.)
(9) See App B for Emission Limits (10) See section J for NESHAP/MACT requirements

** Refer to section F and G of this permit to determine the monitoring, recordkeeping and reporting requirements for this device.March 02, 2010 DRAFT



## FACILITY PERMIT TO OPERATE

SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE 

## CPV SENTINEL LLC 152707 Page: 2

Date: Facility ID: Section H

Revision #:



### The operator shall comply with the terms and conditions set forth below:

Conditions Emissions
And Requirements RECLAIM
Source Type/
Monitoring Unit Connected

To ID

No. Equipment *



### Process 1 : 

### INTERNAL COMBUSTION

GAS TURBINE, CTG-1, NATURAL

GAS, GENERAL ELECTRIC, MODEL

LMS100PA, SIMPLE CYCLE, 891.7

MMBTU/HR AT 72 DEGREES F,

WITH WATER INJECTION WITH

A/N: NOX: MAJOR

SOURCE** D1 CO : 4 PPMV NATURAL
GAS (4) [RULE 1703(a)(2) -

PSD-BACT, 10-7-1988]; CO :

2000 PPMV NATURAL GAS
(5) [ RULE 407, 4-2-1982 ];

NOX : 2.5 PPMV NATURAL
GAS (4) [ RULE 1703 - PSD

Analysis, 10-7-1988; RULE

2005, 4-20-2001 ]; NOX : 12.26
LBS/MMSCF (1) [ RULE

2012, 5-6-2005 ]; NOX : 15
PPMV NATURAL GAS (8)

[ 40CFR 60 Subpart KKKK,

7-6-2006 ]; NOX : 19

LBS/MMSCF NATURAL
GAS (1) [ RULE 2012,

5-6-2005 ]; PM10 : 0.01

GRAINS/SCF NATURAL
GAS (5A) [ RULE 475,

10-8-1976; RULE 475,

8-7-1978 ]; PM10 : 0.1

GRAINS/SCF NATURAL
GAS (5) [ RULE 409,

8-7-1981 ]; PM10 : 11 LBS/HR
NATURAL GAS (5B) [ RULE

475, 10-8-1976; RULE 475,

8-7-1978 ]; SO2 : (9) [ 40CFR

72 - Acid Rain Provisions,

11-24-1997 ]; SOX : 0.06

LBS/MMBTU NATURAL
GAS (8) [ 40CFR 60 Subpart

KKKK, 7-6-2006 ]; VOC : 2
PPMV NATURAL GAS (4)

[ RULE 1303(a)(1)-BACT,

5-10-1996; RULE 1303(a)(1) C3 A63.1, A63.2,

A99.1, A99.3,

A99.5, A99.7,

A99.9,

A195.1,

A195.2,

A195.3,

A327.1,

A433.1,

B61.1, C1.1,

C1.3, C1.6,

D12.1, D29.1,

D29.2, D29.3,

D82.1, D82.2,

E193.1, H23.1,

I296.1, K40.1,

K67.1

* (1) (1A) (1B) Denotes RECLAIM emission factor (2) (2A) (2B) Denotes RECLAIM emission rate

(3) Denotes RECLAIM concentration limit (4) Denotes BACT emission limit
(5) (5A) (5B) Denotes command and control emission limit (6) Denotes air toxic control rule limit
(7) Denotes NSR applicability limit (8) (8A) (8B) Denotes 40 CFR limit (e.g. NSPS, NESHAPS, etc.)
(9) See App B for Emission Limits (10) See section J for NESHAP/MACT requirements

** Refer to section F and G of this permit to determine the monitoring, recordkeeping and reporting requirements for this device.March 02, 2010 DRAFT



## FACILITY PERMIT TO OPERATE

SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE 

## CPV SENTINEL LLC 152707 Page: 3

Date: Facility ID: Section H

Revision #:



### The operator shall comply with the terms and conditions set forth below:

Conditions Emissions
And Requirements RECLAIM
Source Type/
Monitoring Unit Connected

To ID

No. Equipment *



### Process 1 : 

### INTERNAL COMBUSTION

-BACT, 12-6-2002 ]

GENERATOR, 103 MW

CO OXIDATION CATALYST, NO. 1,

BASF, WITH 150 CUBIC FEET OF

TOTAL CATALYST VOLUME.

A/N: C3 D1 C4 E54 E55

SELECTIVE CATALYTIC

REDUCTION, NO. 1, CORMETECH

CHMT-2, 812 CU.FT.; WIDTH: 2 FT

2 IN; HEIGHT: 4 FT 2 IN; LENGTH: 10

FT 11 IN WITH

A/N: C4 NH3 : 5 PPMV NATURAL
GAS (4) [ RULE 1303(a)(1)

-BACT, 5-10-1996; RULE
1303(a)(1)-BACT, 12-6-2002 ] C3 S6 A195.4,

D12.2, D12.3,

D12.4, E179.1,

E179.2,

E179.3,

E193.1

AMMONIA INJECTION, GRID

STACK, NO. 1, HEIGHT: 90 FT ;

DIAMETER: 13 FT 6 IN

A/N: S6 C4

* (1) (1A) (1B) Denotes RECLAIM emission factor (2) (2A) (2B) Denotes RECLAIM emission rate

(3) Denotes RECLAIM concentration limit (4) Denotes BACT emission limit
(5) (5A) (5B) Denotes command and control emission limit (6) Denotes air toxic control rule limit
(7) Denotes NSR applicability limit (8) (8A) (8B) Denotes 40 CFR limit (e.g. NSPS, NESHAPS, etc.)
(9) See App B for Emission Limits (10) See section J for NESHAP/MACT requirements

** Refer to section F and G of this permit to determine the monitoring, recordkeeping and reporting requirements for this device.March 02, 2010 DRAFT



## FACILITY PERMIT TO OPERATE

SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE 

## CPV SENTINEL LLC 152707 Page: 4

Date: Facility ID: Section H

Revision #:



### The operator shall comply with the terms and conditions set forth below:

Conditions Emissions
And Requirements RECLAIM
Source Type/
Monitoring Unit Connected

To ID

No. Equipment *



### Process 1 : 

### INTERNAL COMBUSTION

GAS TURBINE, CTG-2, NATURAL

GAS, GENERAL ELECTRIC, MODEL

LMS100PA, SIMPLE CYCLE, 861.7

MMBTU/HR AT 72 DEGREES F,

WITH WATER INJECTION WITH

A/N: NOX: MAJOR

SOURCE** D7 CO : 4 PPMV NATURAL
GAS (4) [RULE 1703(a)(2) -

PSD-BACT, 10-7-1988]; CO :

2000 PPMV NATURAL GAS
(5) [ RULE 407, 4-2-1982 ];

NOX : 2.5 PPMV NATURAL
GAS (4) [RULE 1703(a)(2) -

PSD-BACT, 10-7-1988; RULE

2005, 5-6-2005 ]; NOX : 12.26
LBS/MMSCF (1) [ RULE

2012, 5-6-2005 ]; NOX : 15
PPMV NATURAL GAS (8)

[ 40CFR 60 Subpart KKKK,

7-6-2006 ]; NOX : 19

LBS/MMSCF NATURAL
GAS (1) [ RULE 2012,

5-6-2005 ]; PM10 : 0.01

GRAINS/SCF NATURAL
GAS (5A) [ RULE 475,

10-8-1976; RULE 475,

8-7-1978 ]; PM10 : 0.1

GRAINS/SCF NATURAL
GAS (5) [ RULE 409,

8-7-1981 ]; PM10 : 11 LBS/HR
NATURAL GAS (5B) [ RULE

475, 10-8-1976; RULE 475,

8-7-1978 ]; SO2 : (9) [ 40CFR

72 - Acid Rain Provisions,

11-24-1997 ]; SOX : 0.06

LBS/MMBTU NATURAL
GAS (8) [ 40CFR 60 Subpart

KKKK, 7-6-2006 ]; VOC : 2
PPMV NATURAL GAS (4)

[ RULE 1303(a)(1)-BACT,

5-10-1996; RULE 1303(a)(1) C9 A63.1, A63.2,

A99.1, A99.3,

A99.5, A99.7,

A99.9,

A195.1,

A195.3,

A327.1,

A433.1,

B61.1, C1.1,

C1.3, C1.6,

D12.1, D29.1,

D29.2, D29.3,

D82.1, D82.2,

E193.1,

I296.1, K40.1,

K67.1

* (1) (1A) (1B) Denotes RECLAIM emission factor (2) (2A) (2B) Denotes RECLAIM emission rate

(3) Denotes RECLAIM concentration limit (4) Denotes BACT emission limit
(5) (5A) (5B) Denotes command and control emission limit (6) Denotes air toxic control rule limit
(7) Denotes NSR applicability limit (8) (8A) (8B) Denotes 40 CFR limit (e.g. NSPS, NESHAPS, etc.)
(9) See App B for Emission Limits (10) See section J for NESHAP/MACT requirements

** Refer to section F and G of this permit to determine the monitoring, recordkeeping and reporting requirements for this device.March 02, 2010 DRAFT



## FACILITY PERMIT TO OPERATE

SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE 

## CPV SENTINEL LLC 152707 Page: 5

Date: Facility ID: Section H

Revision #:



### The operator shall comply with the terms and conditions set forth below:

Conditions Emissions
And Requirements RECLAIM
Source Type/
Monitoring Unit Connected

To ID

No. Equipment *



### Process 1 : 

### INTERNAL COMBUSTION

-BACT, 12-6-2002 ]

GENERATOR, 103 MW

CO OXIDATION CATALYST, NO. 2,

BASF, WITH 150 CUBIC FEET OF

TOTAL CATALYST VOLUME.

A/N: C9 D7 C10

SELECTIVE CATALYTIC

REDUCTION, NO. 2, CORMETECH

CHMT-2, 812 CU.FT.; WIDTH: 2 FT

2 IN; HEIGHT: 4 FT 2 IN; LENGTH: 10

FT 11 IN WITH

A/N: C10 NH3 : 5 PPMV NATURAL
GAS (4) [ RULE 1303(a)(1)

-BACT, 5-10-1996; RULE
1303(a)(1)-BACT, 12-6-2002 ] C9 S12 A195.4,

D12.2, D12.3,

D12.4, E179.1,

E179.2,

E179.3,

E193.1

AMMONIA INJECTION, GRID

STACK, NO. 2, HEIGHT: 90 FT ;

DIAMETER: 13 FT 6 IN

A/N: S12 C10

* (1) (1A) (1B) Denotes RECLAIM emission factor (2) (2A) (2B) Denotes RECLAIM emission rate

(3) Denotes RECLAIM concentration limit (4) Denotes BACT emission limit
(5) (5A) (5B) Denotes command and control emission limit (6) Denotes air toxic control rule limit
(7) Denotes NSR applicability limit (8) (8A) (8B) Denotes 40 CFR limit (e.g. NSPS, NESHAPS, etc.)
(9) See App B for Emission Limits (10) See section J for NESHAP/MACT requirements

** Refer to section F and G of this permit to determine the monitoring, recordkeeping and reporting requirements for this device.March 02, 2010 DRAFT



## FACILITY PERMIT TO OPERATE

SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE 

## CPV SENTINEL LLC 152707 Page: 6

Date: Facility ID: Section H

Revision #:



### The operator shall comply with the terms and conditions set forth below:

Conditions Emissions
And Requirements RECLAIM
Source Type/
Monitoring Unit Connected

To ID

No. Equipment *



### Process 1 : 

### INTERNAL COMBUSTION

GAS TURBINE, GTG 3, NATURAL

GAS, GENERAL ELECTRIC, MODEL

LMS100PA, SIMPLE CYCLE, 891.7

MMBTU/HR AT 72 DEGREES F,

WITH WATER INJECTION WITH

A/N: NOX: MAJOR

SOURCE** D13 CO : 4 PPMV NATURAL
GAS (4) [RULE 1703(a)(2) -

PSD-BACT, 10-7-1988]; CO :

20000 PPMV NATURAL
GAS (5) [ RULE 407,

4-2-1982 ]; NOX : 2.5 PPMV
NATURAL GAS (4) [RULE
1703(a)(2) - PSD-BACT,

10-7-1988; RULE 2005,

5-6-2005 ]; NOX : 12.26

LBS/MMSCF NATURAL
GAS (1) [ RULE 2012,

5-6-2005 ]; NOX : 15 PPMV
NATURAL GAS (8) [ 40CFR

60 Subpart KKKK, 7-6-2006 ];

NOX : 19 LBS/MMSCF (1)

[ RULE 2012, 5-6-2005 ];

PM10 : 0.01 GRAINS/SCF
NATURAL GAS (5A) [ RULE

475, 10-8-1976; RULE 475,

8-7-1978 ]; PM10 : 0.1

GRAINS/SCF NATURAL
GAS (5) [ RULE 409,

8-7-1981 ]; SO2 : (8) [ 40CFR

72 - Acid Rain Provisions,

11-24-1997 ]; SOX : 0.06

LBS/MMSCF NATURAL
GAS (8) [ 40CFR 60 Subpart

KKKK, 7-6-2006 ]; VOC : 2
PPMV NATURAL GAS (4)

[ RULE 1303(a)(1)-BACT,

5-10-1996; RULE 1303(a)(1)

-BACT, 12-6-2002 ] C15 A63.1, A63.2,

A99.1, A99.3,

A99.5, A99.7,

A99.9,

A195.1,

A195.2,

A195.3,

A327.1,

A433.1,

B61.1, C1.1,

C1.3, C1.6,

D12.1, D29.1,

D29.2, D29.3,

D82.1, D82.2,

E193.1, H23.1,

I296.1, K40.1,

K67.1

GENERATOR, 103 MW

* (1) (1A) (1B) Denotes RECLAIM emission factor (2) (2A) (2B) Denotes RECLAIM emission rate

(3) Denotes RECLAIM concentration limit (4) Denotes BACT emission limit
(5) (5A) (5B) Denotes command and control emission limit (6) Denotes air toxic control rule limit
(7) Denotes NSR applicability limit (8) (8A) (8B) Denotes 40 CFR limit (e.g. NSPS, NESHAPS, etc.)
(9) See App B for Emission Limits (10) See section J for NESHAP/MACT requirements

** Refer to section F and G of this permit to determine the monitoring, recordkeeping and reporting requirements for this device.March 02, 2010 DRAFT



## FACILITY PERMIT TO OPERATE

SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE 

## CPV SENTINEL LLC 152707 Page: 7

Date: Facility ID: Section H

Revision #:



### The operator shall comply with the terms and conditions set forth below:

Conditions Emissions
And Requirements RECLAIM
Source Type/
Monitoring Unit Connected

To ID

No. Equipment *



### Process 1 : 

### INTERNAL COMBUSTION

CO OXIDATION CATALYST, NO. 3,

BASF, WITH 150 CUBIC FEET OF

TOTAL CATALYST VOLUME.

A/N: C15 D13 C16

SELECTIVE CATALYTIC

REDUCTION, NO.3, CORMETECH

CHMT-2, 812 CU.FT.; WIDTH: 2 FT

2 IN; HEIGHT: 4 FT 2 IN; LENGTH: 10

FT 11 IN WITH

A/N: C16 NH3 : 5 PPMV NATURAL
GAS (4) [ RULE 1303(a)(1)

-BACT, 5-10-1996; RULE
1303(a)(1)-BACT, 12-6-2002 ] C15 S18 A195.4,

D12.2, D12.3,

D12.4, E179.1,

E179.2,

E179.3,

E193.1

C28 AMMONIA INJECTION, GRID

STACK, NO. 3, HEIGHT: 90 FT ;

DIAMETER: 13 FT 6 IN

A/N: S18 C16

* (1) (1A) (1B) Denotes RECLAIM emission factor (2) (2A) (2B) Denotes RECLAIM emission rate

(3) Denotes RECLAIM concentration limit (4) Denotes BACT emission limit
(5) (5A) (5B) Denotes command and control emission limit (6) Denotes air toxic control rule limit
(7) Denotes NSR applicability limit (8) (8A) (8B) Denotes 40 CFR limit (e.g. NSPS, NESHAPS, etc.)
(9) See App B for Emission Limits (10) See section J for NESHAP/MACT requirements

** Refer to section F and G of this permit to determine the monitoring, recordkeeping and reporting requirements for this device.March 02, 2010 DRAFT



## FACILITY PERMIT TO OPERATE

SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE 

## CPV SENTINEL LLC 152707 Page: 8

Date: Facility ID: Section H

Revision #:



### The operator shall comply with the terms and conditions set forth below:

Conditions Emissions
And Requirements RECLAIM
Source Type/
Monitoring Unit Connected

To ID

No. Equipment *



### Process 1 : 

### INTERNAL COMBUSTION

GAS TURBINE, GTG 4, NATURAL

GAS, GENERAL ELECTRIC, MODEL

LMS100PA, SIMPLE CYCLE, 891.7

MMBTU/HR AT 72 DEGREES F,

WITH WATER INJECTION WITH

A/N: NOX: MAJOR

SOURCE** D19 CO : 4 PPMV NATURAL
GAS (4) [RULE 1703(a)(2) -

PSD-BACT, 10-7-1988]; CO :

2000 PPMV NATURAL GAS
(5) [ RULE 409, 8-7-1981 ];

NOX : 2.5 PPMV (4) [RULE
1703(a)(2) - PSD-BACT,

10-7-1988; RULE 2005,

5-6-2005 ]; NOX : 12.26

LBS/MMSCF NATURAL
GAS (1) [ RULE 2012,

5-6-2005 ]; NOX : 15 PPMV (8)

[ 40CFR 60 Subpart KKKK,

7-6-2006 ]; NOX : 19
LBS/MMSCF (1) ; PM10 :

0.01 GRAINS/SCF
NATURAL GAS (5B) [ RULE

475, 10-8-1976; RULE 475,

8-7-1978 ]; SO2 : (9) [ 40CFR

72 - Acid Rain Provisions,

11-24-1997 ]; SOX : 0.06

LBS/MMBTU NATURAL
GAS (8) [ 40CFR 60 Subpart

KKKK, 7-6-2006 ]; VOC : 2
PPMV NATURAL GAS (4)

[ RULE 1303(a)(1)-BACT,

5-10-1996; RULE 1303(a)(1)

-BACT, 12-6-2002 ] C21 A63.1, A63.2,

A99.1, A99.3,

A99.5, A99.7,

A99.9,

A195.1,

A195.2,

A195.3,

A433.1,

B61.1, C1.1,

C1.3, C1.6,

D12.1, D29.1,

D29.2, D29.3,

D82.1, D82.2,

E193.1, H23.1,

I296.1, K67.1

GENERATOR, 103 MW

CO OXIDATION CATALYST, NO. 4,

BASF, WITH 150 CUBIC FEET OF

TOTAL CATALYST VOLUME.

A/N: C21 D19 C22

* (1) (1A) (1B) Denotes RECLAIM emission factor (2) (2A) (2B) Denotes RECLAIM emission rate

(3) Denotes RECLAIM concentration limit (4) Denotes BACT emission limit
(5) (5A) (5B) Denotes command and control emission limit (6) Denotes air toxic control rule limit
(7) Denotes NSR applicability limit (8) (8A) (8B) Denotes 40 CFR limit (e.g. NSPS, NESHAPS, etc.)
(9) See App B for Emission Limits (10) See section J for NESHAP/MACT requirements

** Refer to section F and G of this permit to determine the monitoring, recordkeeping and reporting requirements for this device.March 02, 2010 DRAFT



## FACILITY PERMIT TO OPERATE

SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE 

## CPV SENTINEL LLC 152707 Page: 9

Date: Facility ID: Section H

Revision #:



### The operator shall comply with the terms and conditions set forth below:

Conditions Emissions
And Requirements RECLAIM
Source Type/
Monitoring Unit Connected

To ID

No. Equipment *



### Process 1 : 

### INTERNAL COMBUSTION

SELECTIVE CATALYTIC

REDUCTION, NO.4, CORMETCH

CHMT-2, 812 CU.FT.; WIDTH: 2 FT

2 IN; HEIGHT: 4 FT 2 IN; LENGTH: 10

FT 11 IN WITH

A/N: C22 NH3 : 5 PPMV NATURAL
GAS (4) [ RULE 1303(a)(1)

-BACT, 5-10-1996; RULE
1303(a)(1)-BACT, 12-6-2002 ] C21 S24 A195.4,

D12.2, D12.3,

D12.4, E179.1,

E179.2,

E179.3,

E193.1

AMMONIA INJECTION, GRID

STACK, NO. 4, HEIGHT: 90 FT ;

DIAMETER: 13 FT 6 IN

A/N: S24 C22

* (1) (1A) (1B) Denotes RECLAIM emission factor (2) (2A) (2B) Denotes RECLAIM emission rate

(3) Denotes RECLAIM concentration limit (4) Denotes BACT emission limit
(5) (5A) (5B) Denotes command and control emission limit (6) Denotes air toxic control rule limit
(7) Denotes NSR applicability limit (8) (8A) (8B) Denotes 40 CFR limit (e.g. NSPS, NESHAPS, etc.)
(9) See App B for Emission Limits (10) See section J for NESHAP/MACT requirements

** Refer to section F and G of this permit to determine the monitoring, recordkeeping and reporting requirements for this device.March 02, 2010 DRAFT



## FACILITY PERMIT TO OPERATE

SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE 

## CPV SENTINEL LLC 152707 Page: 10

Date: Facility ID: Section H

Revision #:



### The operator shall comply with the terms and conditions set forth below:

Conditions Emissions
And Requirements RECLAIM
Source Type/
Monitoring Unit Connected

To ID

No. Equipment *



### Process 1 : 

### INTERNAL COMBUSTION

GAS TURBINE, GTG 5, NATURAL

GAS, GENERAL ELECTRIC, MODEL

LMS100PA, SIMPLE CYCLE, 891.7

MMBTU/HR AT 72 DEGREES F,

WITH WATER INJECTION WITH

A/N: NOX: MAJOR

SOURCE** D25 CO : 4 PPMV NATURAL
GAS (4) [RULE 1703(a)(2) -

PSD-BACT, 10-7-1988]; CO :

2000 PPMM NATURAL
GAS (5) [ RULE 407,

4-2-1982 ]; NOX : 2.5 PPMV
NATURAL GAS (4) [RULE
1703(a)(2) - PSD-BACT,

10-7-1988; RULE 2005,

5-6-2005 ]; NOX : 12.26

LBS/MMSCF NATURAL
GAS (1) [ RULE 2012,

5-6-2005 ]; NOX : 15 PPMV
NATURAL GAS (8) [ 40CFR

60 Subpart KKKK, 7-6-2006 ];

NOX : 19 LBS/MMSCF (1)

[ RULE 2012, 5-6-2005 ];

PM10 : 0.01 GRAINS/SCF
NATURAL GAS (5C) [ RULE

475, 10-8-1976; RULE 475,

8-7-1978 ]; SO2 : (8) [ 40CFR

72 - Acid Rain Provisions,

11-24-1997 ]; SOX : 0.06

LBS/MMBTU NATURAL
GAS (8) [ 40CFR 60 Subpart

KKKK, 7-6-2006 ]; VOC : 2
PPMM NATURAL GAS (4)

[ RULE 1303(a)(1)-BACT,

5-10-1996; RULE 1303(a)(1)

-BACT, 12-6-2002 ] C27 A63.1, A63.2,

A99.1, A99.3,

A99.5, A99.7,

A99.9,

A195.1,

A195.2,

A195.3,

A327.1,

A433.1,

B61.1, C1.1,

C1.3, C1.6,

D12.1, D29.1,

D29.2, D29.3,

D82.1, D82.2,

E193.1, H23.1,

I296.1, K40.1,

K67.1

GENERATOR, 103 MW

* (1) (1A) (1B) Denotes RECLAIM emission factor (2) (2A) (2B) Denotes RECLAIM emission rate

(3) Denotes RECLAIM concentration limit (4) Denotes BACT emission limit
(5) (5A) (5B) Denotes command and control emission limit (6) Denotes air toxic control rule limit
(7) Denotes NSR applicability limit (8) (8A) (8B) Denotes 40 CFR limit (e.g. NSPS, NESHAPS, etc.)
(9) See App B for Emission Limits (10) See section J for NESHAP/MACT requirements

** Refer to section F and G of this permit to determine the monitoring, recordkeeping and reporting requirements for this device.March 02, 2010 DRAFT



## FACILITY PERMIT TO OPERATE

SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE 

## CPV SENTINEL LLC 152707 Page: 11

Date: Facility ID: Section H

Revision #:



### The operator shall comply with the terms and conditions set forth below:

Conditions Emissions
And Requirements RECLAIM
Source Type/
Monitoring Unit Connected

To ID

No. Equipment *



### Process 1 : 

### INTERNAL COMBUSTION

CO OXIDATION CATALYST, NO.5,

BASF, WITH 150 CUBIC FEET OF

TOTAL CATALYST VOLUME.

A/N: C27 D25 C28

SELECTIVE CATALYTIC

REDUCTION, NO.5, CORMETECH

CHMT-2, 812 CU.FT.; WIDTH: 2 FT

2 IN; HEIGHT: 4 FT 2 IN; LENGTH: 10

FT 11 IN WITH

A/N: C28 NH3 : 5 PPMV NATURAL
GAS (4) [ RULE 1303(a)(1)

-BACT, 5-10-1996; RULE
1303(a)(1)-BACT, 12-6-2002 ] B17 C27 S30 A195.4,

D12.2, D12.3,

D12.4, E179.1,

E179.2,

E179.3,

E193.1

AMMONIA INJECTION, GRID

STACK, NO. 5, HEIGHT: 90 FT ;

DIAMETER: 13 FT 6 IN

A/N: S30 C28

* (1) (1A) (1B) Denotes RECLAIM emission factor (2) (2A) (2B) Denotes RECLAIM emission rate

(3) Denotes RECLAIM concentration limit (4) Denotes BACT emission limit
(5) (5A) (5B) Denotes command and control emission limit (6) Denotes air toxic control rule limit
(7) Denotes NSR applicability limit (8) (8A) (8B) Denotes 40 CFR limit (e.g. NSPS, NESHAPS, etc.)
(9) See App B for Emission Limits (10) See section J for NESHAP/MACT requirements

** Refer to section F and G of this permit to determine the monitoring, recordkeeping and reporting requirements for this device.March 02, 2010 DRAFT



## FACILITY PERMIT TO OPERATE

SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE 

## CPV SENTINEL LLC 152707 Page: 12

Date: Facility ID: Section H

Revision #:



### The operator shall comply with the terms and conditions set forth below:

Conditions Emissions
And Requirements RECLAIM
Source Type/
Monitoring Unit Connected

To ID

No. Equipment *



### Process 1 : 

### INTERNAL COMBUSTION

GAS TURBINE, GTG 6, NATURAL

GAS, GENERAL ELECTRIC, MODEL

LMS100PA, SIMPLE CYCLE, 891.7

MMBTU/HR AT 72 DEGREES F,

WITH WATER INJECTION WITH

A/N: NOX: MAJOR

SOURCE** D31 CO : 4 PPMV NATURAL
GAS (4) [RULE 1703(a)(2) -

PSD-BACT, 10-7-1988]; CO :

2000 PPMV NATURAL GAS
(5) [ RULE 407, 4-2-1982 ];

NOX : 12.26 LBS/MMSCF
NATURAL GAS (1) [ RULE

2012, 5-6-2005 ]; NOX : 15
PPMV NATURAL GAS (8)

[ 40CFR 60 Subpart KKKK,

7-6-2006 ]; NOX : 19
LBS/MMSCF (1) [ RULE

2012, 5-6-2005 ]; PM10 : 0.01

GRAINS/SCF NATURAL
GAS (5A) [ RULE 475,

10-8-1976; RULE 475,

8-7-1978 ]; PM10 : 11 LBS/HR
NATURAL GAS (5B) [ RULE

475, 10-8-1976; RULE 475,

8-7-1978 ]; SO2 : (9) [ 40CFR

72 - Acid Rain Provisions,

11-24-1997 ]; SOX : 0.06

LBS/MMBTU NATURAL
GAS (8) [ 40CFR 60 Subpart

KKKK, 7-6-2006 ]; VOC : 2
PPMV NATURAL GAS (4)

[ RULE 1303(a)(1)-BACT,

5-10-1996; RULE 1303(a)(1)

-BACT, 12-6-2002 ] C33 A63.2, A99.1,

A99.3, A99.5,

A99.7, A99.9,

A195.1,

A195.2,

A195.3,

A327.1,

A433.1,

B61.1, C1.1,

C1.3, C1.6,

D12.1, D29.1,

D29.2, D29.3,

D82.1, D82.2,

E193.1, H23.1,

I296.1, K40.1,

K67.1

GENERATOR, 103 MW

* (1) (1A) (1B) Denotes RECLAIM emission factor (2) (2A) (2B) Denotes RECLAIM emission rate

(3) Denotes RECLAIM concentration limit (4) Denotes BACT emission limit
(5) (5A) (5B) Denotes command and control emission limit (6) Denotes air toxic control rule limit
(7) Denotes NSR applicability limit (8) (8A) (8B) Denotes 40 CFR limit (e.g. NSPS, NESHAPS, etc.)
(9) See App B for Emission Limits (10) See section J for NESHAP/MACT requirements

** Refer to section F and G of this permit to determine the monitoring, recordkeeping and reporting requirements for this device.March 02, 2010 DRAFT



## FACILITY PERMIT TO OPERATE

SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE 

## CPV SENTINEL LLC 152707 Page: 13

Date: Facility ID: Section H

Revision #:



### The operator shall comply with the terms and conditions set forth below:

Conditions Emissions
And Requirements RECLAIM
Source Type/
Monitoring Unit Connected

To ID

No. Equipment *



### Process 1 : 

### INTERNAL COMBUSTION

CO OXIDATION CATALYST, NO. 6,

BASF, WITH 150 CUBIC FEET OF

TOTAL CATALYST VOLUME.

A/N: C33 D31 C34

SELECTIVE CATALYTIC

REDUCTION, NO. 6, CORMETECH

CHMT-2, 812 CU.FT.; WIDTH: 2 FT

2 IN; HEIGHT: 4 FT 2 IN; LENGTH: 10

FT 11 IN WITH

A/N: C34 NH3 : 5 PPMV NATURAL
GAS (4) [ RULE 1303(a)(1)

-BACT, 5-10-1996; RULE
1303(a)(1)-BACT, 12-6-2002 ] C33 S36 A195.4,

D12.2, D12.3,

D12.4, E179.1,

E179.2,

E179.3,

E193.1

AMMONIA INJECTION, GRID

STACK, NO.6, HEIGHT: 90 FT ;

DIAMETER: 13 FT 6 IN

A/N: S36 C34

* (1) (1A) (1B) Denotes RECLAIM emission factor (2) (2A) (2B) Denotes RECLAIM emission rate

(3) Denotes RECLAIM concentration limit (4) Denotes BACT emission limit
(5) (5A) (5B) Denotes command and control emission limit (6) Denotes air toxic control rule limit
(7) Denotes NSR applicability limit (8) (8A) (8B) Denotes 40 CFR limit (e.g. NSPS, NESHAPS, etc.)
(9) See App B for Emission Limits (10) See section J for NESHAP/MACT requirements

** Refer to section F and G of this permit to determine the monitoring, recordkeeping and reporting requirements for this device.March 02, 2010 DRAFT



## FACILITY PERMIT TO OPERATE

SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE 

## CPV SENTINEL LLC 152707 Page: 14

Date: Facility ID: Section H

Revision #:



### The operator shall comply with the terms and conditions set forth below:

Conditions Emissions
And Requirements RECLAIM
Source Type/
Monitoring Unit Connected

To ID

No. Equipment *



### Process 1 : 

### INTERNAL COMBUSTION

GAS TURBINE, GTG 7, NATURAL

GAS, GENERAL ELECTRIC, MODEL

LMS100PA, SIMPLE CYCLE, 891.7

MMBTU/HR AT 72 DEGREES F,

WITH WATER INJECTION WITH

A/N: NOX: MAJOR

SOURCE** D37 CO : 4 PPMV NATURAL
GAS (4) [RULE 1703(a)(2) -

PSD-BACT, 10-7-1988]; CO :

2000 PPMV NATURAL GAS
(5) [ RULE 407, 4-2-1982 ];

NOX : 2.5 PPMV NATURAL
GAS (4) [RULE 1703(a)(2) -

PSD-BACT, 10-7-1988; RULE

2005, 5-6-2005 ]; NOX : 12.26

LBS/MMSCF NATURAL
GAS (1) [ RULE 2012,

5-6-2005 ]; NOX : 15 PPMV
NATURAL GAS (8) [ 40CFR

60 Subpart KKKK, 7-6-2006 ];

NOX : 19 LBS/MMSCF (1)

[ RULE 2012, 5-6-2005 ];

PM10 : 0.01 GRAINS/SCF
NATURAL GAS (5A) [ RULE

475, 10-8-1976; RULE 475,

8-7-1978 ]; PM10 : 11 LBS/HR
NATURAL GAS (5B) [ RULE

475, 10-8-1976; RULE 475,

8-7-1978 ]; SO2 : (9) [ 40CFR

72 - Acid Rain Provisions,

11-24-1997 ]; SOX : 0.06

LBS/MMBTU NATURAL
GAS (8) [ 40CFR 60 Subpart

KKKK, 7-6-2006 ]; VOC : 2
PPMV NATURAL GAS (4)

[ RULE 1303(a)(1)-BACT,

5-10-1996; RULE 1303(a)(1)

-BACT, 12-6-2002 ] C39 A63.1, A63.2,

A99.1, A99.3,

A99.5, A99.7,

A99.9,

A195.1,

A195.2,

A195.3,

A327.1,

A433.1,

B61.1, C1.1,

C1.3, C1.6,

D12.1, D29.1,

D29.2, D29.3,

D82.1, D82.2,

E193.1, H23.1,

I296.1, K40.1,

K67.1

GENERATOR, 103 MW

* (1) (1A) (1B) Denotes RECLAIM emission factor (2) (2A) (2B) Denotes RECLAIM emission rate

(3) Denotes RECLAIM concentration limit (4) Denotes BACT emission limit
(5) (5A) (5B) Denotes command and control emission limit (6) Denotes air toxic control rule limit
(7) Denotes NSR applicability limit (8) (8A) (8B) Denotes 40 CFR limit (e.g. NSPS, NESHAPS, etc.)
(9) See App B for Emission Limits (10) See section J for NESHAP/MACT requirements

** Refer to section F and G of this permit to determine the monitoring, recordkeeping and reporting requirements for this device.March 02, 2010 DRAFT



## FACILITY PERMIT TO OPERATE

SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE 

## CPV SENTINEL LLC 152707 Page: 15

Date: Facility ID: Section H

Revision #:



### The operator shall comply with the terms and conditions set forth below:

Conditions Emissions
And Requirements RECLAIM
Source Type/
Monitoring Unit Connected

To ID

No. Equipment *



### Process 1 : 

### INTERNAL COMBUSTION

CO OXIDATION CATALYST, NO. 7,

BASF, WITH 150 CUBIC FEET OF

TOTAL CATALYST VOLUME.

A/N: C39 D37 C40

SELECTIVE CATALYTIC

REDUCTION, NO. 7, CORMETECH

CHMT-2, 812 CU.FT.; WIDTH: 2 FT

2 IN; HEIGHT: 4 FT 2 IN; LENGTH: 10

FT 11 IN WITH

A/N: C40 NH3 : 5 PPMV NATURAL
GAS (4) [ RULE 1303(a)(1)

-BACT, 5-10-1996; RULE
1303(a)(1)-BACT, 12-6-2002 ] C39 S42 A195.4,

D12.2, D12.3,

D12.4, E179.1,

E179.2,

E179.3,

E193.1

AMMONIA INJECTION, GRID

* (1) (1A) (1B) Denotes RECLAIM emission factor (2) (2A) (2B) Denotes RECLAIM emission rate

(3) Denotes RECLAIM concentration limit (4) Denotes BACT emission limit
(5) (5A) (5B) Denotes command and control emission limit (6) Denotes air toxic control rule limit
(7) Denotes NSR applicability limit (8) (8A) (8B) Denotes 40 CFR limit (e.g. NSPS, NESHAPS, etc.)
(9) See App B for Emission Limits (10) See section J for NESHAP/MACT requirements

** Refer to section F and G of this permit to determine the monitoring, recordkeeping and reporting requirements for this device.March 02, 2010 DRAFT



## FACILITY PERMIT TO OPERATE

SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE 

## CPV SENTINEL LLC 152707 Page: 16

Date: Facility ID: Section H

Revision #:



### The operator shall comply with the terms and conditions set forth below:

Conditions Emissions
And Requirements RECLAIM
Source Type/
Monitoring Unit Connected

To ID

No. Equipment *



### Process 1 : 

### INTERNAL COMBUSTION

GAS TURBINE, GTG8, NATURAL

GAS, GENERAL ELECTRIC, MODEL

LMS100PA, SIMPLE CYCLE, 891.7

MMBTU/HR AT 72 DEGREES F,

WITH WATER INJECTION WITH

A/N: NOX: MAJOR

SOURCE** D43 CO : 4 PPMV NATURAL
GAS (4) [RULE 1703(a)(2) -

PSD-BACT, 10-7-1988]; CO :

2000 PPMV NATURAL GAS
(5) [ RULE 407, 4-2-1982 ];

NOX : 2.5 PPMV NATURAL
GAS (4) [RULE 1703(a)(2) -

PSD-BACT, 10-7-1988; RULE

2005, 5-6-2005 ]; NOX : 12.26

LBS/MMSCF NATURAL
GAS (1) [ RULE 2012,

5-6-2005 ]; NOX : 15 PPMV
NATURAL GAS (8) [ 40CFR

60 Subpart KKKK, 7-6-2006 ];

NOX : 19 LBS/MMSCF
NATURAL GAS (1A) [ RULE

2012, 5-6-2005 ]; PM10 : 0.01

GRAINS/SCF NATURAL
GAS (5A) [ RULE 475,

10-8-1976; RULE 475,

8-7-1978 ]; PM10 : 11 LBS/HR
NATURAL GAS (5B) [ RULE

475, 10-8-1976; RULE 475,

8-7-1978 ]; SO2 : (9) [ 40CFR

72 - Acid Rain Provisions,

11-24-1997 ]; SOX : 0.06

LBS/MMBTU NATURAL
GAS (8) [ 40CFR 60 Subpart

KKKK, 7-6-2006 ]; VOC : 2
PPMV NATURAL GAS (4)

[ RULE 1303(a)(1)-BACT,

5-10-1996; RULE 1303(a)(1)

-BACT, 12-6-2002 ] C45 A63.1, A63.2,

A99.1, A99.3,

A99.5, A99.7,

A99.9,

A195.1,

A195.2,

A195.3,

A327.1,

A433.1,

B61.1, C1.1,

C1.3, C1.6,

D12.1, D29.1,

D29.2, D29.3,

D82.1, D82.2,

H23.1, I296.1,

K40.1, K67.1

GENERATOR, 103 MW

* (1) (1A) (1B) Denotes RECLAIM emission factor (2) (2A) (2B) Denotes RECLAIM emission rate

(3) Denotes RECLAIM concentration limit (4) Denotes BACT emission limit
(5) (5A) (5B) Denotes command and control emission limit (6) Denotes air toxic control rule limit
(7) Denotes NSR applicability limit (8) (8A) (8B) Denotes 40 CFR limit (e.g. NSPS, NESHAPS, etc.)
(9) See App B for Emission Limits (10) See section J for NESHAP/MACT requirements

** Refer to section F and G of this permit to determine the monitoring, recordkeeping and reporting requirements for this device.March 02, 2010 DRAFT



## FACILITY PERMIT TO OPERATE

SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE 

## CPV SENTINEL LLC 152707 Page: 17

Date: Facility ID: Section H

Revision #:



### The operator shall comply with the terms and conditions set forth below:

Conditions Emissions
And Requirements RECLAIM
Source Type/
Monitoring Unit Connected

To ID

No. Equipment *



### Process 1 : 

### INTERNAL COMBUSTION

CO OXIDATION CATALYST, NO. 8,

BASF, WITH 150 CUBIC FEET OF

TOTAL CATALYST VOLUME.

A/N: C45 D43 C46

SELECTIVE CATALYTIC

REDUCTION, NO. 8, CORMETECH

CHMT-2, 812 CU.FT.; WIDTH: 2 FT

2 IN; HEIGHT: 4 FT 2 IN; LENGTH: 10

FT 11 IN WITH

A/N: C46 NH3 : 5 PPMV NATURAL
GAS (4) [ RULE 1303(a)(1)

-BACT, 5-10-1996; RULE
1303(a)(1)-BACT, 12-6-2002 ] C45 S48 A195.4,

D12.2, D12.3,

D12.4, E179.1,

E179.2,

E179.3,

E193.1

AMMONIA INJECTION, GRID

STACK, NO.8, HEIGHT: 90 FT ;

DIAMETER: 13 FT 6 IN

A/N: S48 C46



### System 2 : 

### EMERGENCY ENGINES

* (1) (1A) (1B) Denotes RECLAIM emission factor (2) (2A) (2B) Denotes RECLAIM emission rate

(3) Denotes RECLAIM concentration limit (4) Denotes BACT emission limit
(5) (5A) (5B) Denotes command and control emission limit (6) Denotes air toxic control rule limit
(7) Denotes NSR applicability limit (8) (8A) (8B) Denotes 40 CFR limit (e.g. NSPS, NESHAPS, etc.)
(9) See App B for Emission Limits (10) See section J for NESHAP/MACT requirements

** Refer to section F and G of this permit to determine the monitoring, recordkeeping and reporting requirements for this device.March 02, 2010 DRAFT



## FACILITY PERMIT TO OPERATE

SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE 

## CPV SENTINEL LLC 152707 Page: 18

Date: Facility ID: Section H

Revision #:



### The operator shall comply with the terms and conditions set forth below:

Conditions Emissions
And Requirements RECLAIM
Source Type/
Monitoring Unit Connected

To ID

No. Equipment *



### Process 1 : 

### INTERNAL COMBUSTION

INTERNAL COMBUSTION ENGINE,

EMERGENCY FIRE, DIESEL FUEL,

CLARKE, MODEL JU6H-UFADTO,

DRIVING AN FIRE PUMP, WITH

AFTERCOOLER, TURBOCHARGER,

274 HP

A/N: NOX: PROCESS

UNIT** D49 CO : 2.6 GRAM/BHP-HR
DIESEL (4) [RULE 1703(a)(2)

- PSD-BACT, 10-7-1988];

NOX : 134 LBS/1000 GAL
DIESEL (1) [ RULE 2012,

5-6-2005 ]; NOX + ROG : 3
GRAM/BHP-HR DIESEL (4)

[ RULE 1303(a)(1)-BACT,

5-10-1996; RULE 1303(a)(1)

-BACT, 12-6-2002; RULE
1703(a)(2) - PSD-BACT,

10-7-1988; RULE 2005,

5-6-2005 ]; PM10 : 0.15
GRAM/BHP-HR DIESEL (4)

[ RULE 1303(a)(1)-BACT,

5-10-1996; RULE 1303(a)(1)

-BACT, 12-6-2002 ]; SOX :

0.005 GRAM/BHP-HR
DIESEL (4) [ RULE 1303(a)(1)

-BACT, 5-10-1996; RULE
1303(a)(1)-BACT, 12-6-2002 ] B61.2, C1.4,

D12.5, I296.3,

K67.3



### Process 2 : 

### INORGANIC CHEMICAL STORAGE

STORAGE TANK, TK-1, 29.4%

AQUEOUS AMMONIA, WITH PVR

SET AT 25 PSIG, 12000 GALS;

DIAMETER: 9 FT 4 IN; HEIGHT: 12

FT

A/N: D52 C157.1,

E144.1,

E193.1, K67.2

STORAGE TANK, TK-2, 29.4%

AQUEOUS AMMONIA, WITH PVR

SET AT 25 PSIG, 12000 GALS;

DIAMETER: 9 FT 4 IN; HEIGHT: 12

FT

A/N: D53 C157.1,

E144.1,

E193.1, K67.2

* (1) (1A) (1B) Denotes RECLAIM emission factor (2) (2A) (2B) Denotes RECLAIM emission rate

(3) Denotes RECLAIM concentration limit (4) Denotes BACT emission limit
(5) (5A) (5B) Denotes command and control emission limit (6) Denotes air toxic control rule limit
(7) Denotes NSR applicability limit (8) (8A) (8B) Denotes 40 CFR limit (e.g. NSPS, NESHAPS, etc.)
(9) See App B for Emission Limits (10) See section J for NESHAP/MACT requirements

** Refer to section F and G of this permit to determine the monitoring, recordkeeping and reporting requirements for this device.

## SECTION H: DEVICE ID INDEX 

## FACILITY PERMIT TO OPERATE

CPV SENTINEL LLC DRAFT

March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 19



## The following sub-section provides an index to the devices that make up the facility description sorted by device ID.

## SECTION H: DEVICE ID INDEX 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 20



### Device Index For Section H

Device ID Section H Page No. Process System



### D1 3 1 1

C3 3 1 1

C4 3 1 1

S6 3 1 1

D7 5 1 1

C9 5 1 1

C10 5 1 1

S12 5 1 1

D13 6 1 1

C15 7 1 1

C16 7 1 1

S18 7 1 1

D19 8 1 1

C21 8 1 1

C22 9 1 1

S24 9 1 1

D25 10 1 1

C27 11 1 1

C28 11 1 1

S30 11 1 1

D31 12 1 1

C33 13 1 1

C34 13 1 1

S36 13 1 1

D37 14 1 1

C39 15 1 1

C40 15 1 1

D43 16 1 1

C45 17 1 1

C46 17 1 1

S48 17 1 1

D49 18 1 2

D52 18 2 0

D53 18 2 0

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 21



### FACILITY CONDITIONS

Except for open abrasive blasting operations, the operator shall not discharge into the atmosphere from any single source of emissions whatsoever any air contaminant for a period or periods aggregating more than three minutes in any one hour which is:

(a ) As dark or darker in shade as that designated No .1 on the Ringelmann Chart, as published by the United States Bureau of Mines; or

(b ) Of such opacity as to obscure an observer's view to a degree equal to or greater than does smoke described in subparagraph (a) of this condition. F9.1

[ RULE 401, 3-2-1984; 

### RULE 401, 11-9-2001]

The operator shall not purchase diesel fuel containing sulfur compounds in excess of 15 ppm by weight as supplied by the supplier. F14.1

The operator shall maintain a copy of the MSDS on site

[ RULE 431.2, 5-4-1990; 

### RULE 431.2, 9-15-2000]



### DEVICE CONDITIONS

Emission Limits A.

The operator shall limit emissions from this equipment as follows: A63.1

CONTAMINANT EMISSIONS LIMIT

Less than or equal to 2425 LBS IN ANY ONE MONTH PM10

CO Less than or equal to 6477 LBS IN ANY ONE MONTH

Less than or equal to 293 LBS IN ANY ONE MONTH SOX

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 22



### Less than or equal to 1432 LBS IN ANY ONE MONTH VOC

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 23



### The operator shall calculate the monthly emissions for VOC, PM 10 and SOx using the equation below and the following emission factors: VOC : 2.52 lb/mmcf; PM10: 5.71 lb/mmcf; and SOx: 0.71 lb/mmcf.

Monthly Emissions, lb/month = X (E.F.)

Where X = monthly fuel usage in mmscf / month and E .F

. = emission factor
indicated above

Compliance with the CO emission limit shall be verified through valid CEMS data

The operator shall calculate the emission limit (s ) for the purpose of determining compliance with the monthly CO limit in the absence of valid CEMS data by using the above equation and the following emission factor(s):

(A ) During the commissioning period and prior to CO catalyst installation - 38.48
lbs CO/mmcf

(B ) After installation of the CO catalyst but prior to CO CEMS certification testing
- 14.38 lb CO /mmcf

. The emission rate shall be recalculated in
accordance with Condition D 82.1 if the approved CEMS certification test resulted in emission concentration higher than 4 ppmv.

(C ) After CO CEMS certification testing - 14.38 lb/ CO mmcf. After CO CEMS
certification test is approved by the AQMD, the emissions monitored by the

CEMS and calculated in accordance with condition D 82.1 shall be used to
calculate emissions.

For the purposes of this condition, the limit (s ) shall be based on the emissions
from a single turbine. During commissioning, the CO emissions shall not exceed 11,602 lbs in any one month. During commissioning, the VOC emissions shall not exceed 620 lbs in any one month.

The operator shall provide the AQMD with written notification of the date of initial CO catalyst use within seven (7) days of this event.

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 24



### For the purpose of this condition the turbine shall not commence with normal operation until the commissioning process has been completed. The District shall
be notified in writing once the commissioning process has been completed

. Normal operations may proceed in the same commissioning month provided the operator follows the requirements listed below:

The operator shall calculate the commissioning emissions for VOC, SOx and

PM10 for the commissioning month ( beginning of the month to the last day of commissioning ) using the equation below and the following emission factors : VOC: 2.06 lb/mmcf; PM10: 2.49 lb/mmcf; and SOx: 0.12 lb/mmcf

Commissioning Emissions, lb/month = X (E.F.)

Where X = commissioning fuel usage in mmscf / month and E .F

. = emission factor
indicated above.

The commissioning emissions for VOC, SOx and PM 10 shall be subtracted from
the monthly emissions limits ( listed in the table at the top of this condition) and
the revised monthly emission limits will be the maximum emissions allowed for the remaining of the month

For the purpose of this condition, normal operations is defined as the turbine is
able to supply electrical energy to the power grid as required under contract with SCE or other entity.

[ RULE 1303(b)(2)-Offset, 5-10-1996; 

### RULE 1303(b)(2)-Offset, 12-6-2002]

[Devices subject to this condition : D1, D7, D13, D19, D25, D37, D43]

The operator shall limit emissions from this equipment as follows: A63.2

CONTAMINANT EMISSIONS LIMIT

Less than or equal to 118120 LBS IN ANY ONE YEAR PM10

SOX Less than or equal to 13928 LBS IN ANY ONE YEAR

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 25



### For the purposes of this condition, the annual limit (s ) shall be calculated by using
annual and montthly fuel use data, and the following emission factors: PM10 5.71 lb/MMSCF; and SOx: 0.25 grains/100 scf.

For the purpose of this condition, the yearly emission limit shall be defined as a period of twelve (12 ) consecutive months determined on a rolling basis with a new 12 month period beginning on the first day of each calendar month.

[ RULE 1303, 5-10-1996; 

### RULE 1303, 10-20-2000; 40CFR 51 Subpart S, 3-8-2007 

### ]

[Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]

The 2.5 PPM NOX emission limit (s ) shall not apply during turbine commissioning,

start- up, and shutdown periods. The commissioning period shall not exceed 150 hours.

Start- up time shall not exceed 25 minutes for each start -up

. Shutdown periods shall not

exceed 10 minutes for each shutdown. The turbine shall be limited to a maximum of 300

start- ups per year. Written records of commissioning, start

- ups and shutdowns shall be maintained and made available upon request from the Executive Officer. A99.1

For

the purposes of this condition, start

- up shall be defined as start up process to bring the turbine in full successful operations. If during start

- up the process is
aborted and the start

- up is restarted, then the start

- up and restart is defined as "one
start-up " In this case the start

- up time shall not exceed one hour. The NOx emissions limited to 29.54 pounds per hour as listed in condition A433.1.

For the purposes of this condition, the aborted start

- up shall be defined as not to
exceed one hour.

[RULE 1703(a)(2) - PSD-BACT, 10-7-1988; RULE 2005, 5-6-2005 

### ]

[Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 26



### The 4 PPM CO emission limit (s ) shall not apply during turbine commissioning, start -up, and shutdown periods. The commissioning period shall not exceed 150 hours

. Start-up

time shall not exceed 25 minutes for each start -up

. Shutdown periods shall not exceed

10 minutes for each shutdown. The turbine shall be limited to a maximum of 300

start- ups per year. Written records of commissioning, start

- ups and shutdowns shall be maintained and made available upon request from the Executive Officer. A99.3

For

the purposes of this condition, start

- up shall be defined as the start up process

to bring the turbine in full successful operations. If during start

- up the process is
aborted and the start

- up is restarted, then the start

- up and restart is defined as "one start-up". In this case the start-up time shall not exceed one hour.

[RULE 1703(a)(2) - PSD-BACT, 10-7-1988]

[Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]

The 19.0 LBS/ MMCF NOX emission limit (s ) shall only apply the interim reporting period during initial turbine commissioning to report RECLAIM emissions. The interim reporting period shall not exceed 12 months from entry into RECLAIM. A99.5

[ RULE 2012, 5-6-2005 

### ]

[Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]

The 12.26 LBS/ MMCF NOX emission limit (s ) shall only apply during the interim reporting period after initial turbine commissioning to report RECLAIM emissions. The interim reporting period shall not exceed 12 months from entry into RECLAIM. A99.7

[ RULE 2012, 5-6-2005 

### ]

[Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 27



### The 2.0 PPM ROG emission limit (s ) shall not apply during turbine commissioning,

start- up, and shutdown periods. The commissioning period shall not exceed 150 hours.

Start- up time shall not exceed 25 minutes for each start -up

. Shutdown periods shall not

exceed 10 minutes for each shutdown. The turbine shall be limited to a maximum of 300

start- ups per year. Written records of commissioning, start

- ups and shutdowns shall be maintained and made available upon request from the Executive Officer. A99.9

For

the purposes of this condition, start

- up shall be defined as the start up process

to bring the turbine in full successful operations. If during start

- up the process is
aborted and the start

- up is restarted, then the start

- up and restart is defined as "one start-up". In this case the start-up time shall not exceed one hour.

[ RULE 1303(a)(1)-BACT, 5-10-1996; 

### RULE 1303(a)(1)-BACT, 12-6-2002]

[Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]

The 4.0 PPMV CO emission limit(s) is averaged over 60 minutes at 15 percent O2, dry. A195.1

[RULE 1703(a)(2) - PSD-BACT, 10-7-1988]

[Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]

The 2.5 PPMV NOX emission limit (s ) is averaged over 60 minutes at 15 percent O 2, dry. A195.2

[RULE 1703(a)(2) - PSD-BACT, 10-7-1988; RULE 2005, 5-6-2005 

### ]

[Devices subject to this condition : D1, D13, D19, D25, D31, D37, D43]

The 2.0 PPMV ROG emission limit (s ) is averaged over 60 minutes at 15 percent O 2, dry. A195.3

[ RULE 1303(a)(1)-BACT, 5-10-1996; 

### RULE 1303(a)(1)-BACT, 12-6-2002]

[Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 28



### The 5 PPMV NH 3 emission limit (s ) is averaged over 60 minutes at 15 % O2

, dry basis

. The operator shall calculate and continuously record the NH 3 slip concentration using the following. A195.4

NH3 (ppmv) = [a-b*c/1EE+06]*1EE+06/b; where

a = NH3 injection rate (lbs/hr)/17(lb/lb-mol)

b = dry exhaust gas flow rate (scf/hr)/385.3 scf/lb-mol)

c = change in measured NOx across the SCR (ppmvd at 15% O2)

The operator shall install and maintain a NOx analyzer to measure the SCR inlet

NOx ppmv accurate to plus or minus 5 percent calibrated at least once every
twelve months

The NOx analyzer shall be installed and operated within 90 days of initial start-up

The operator shall use the above described method or another alternative method approved by the Executive Officer.

The ammonia slip calculation procedures described above shall not be used for compliance determination or emission information without corroborative data using an approved reference method for the determination of ammonia

[ RULE 1303(a)(1)-BACT, 5-10-1996; 

### RULE 1303(a)(1)-BACT, 12-6-2002]

[Devices subject to this condition : C4, C10, C16, C22, C28, C34, C40, C46]

For the purpose of determining compliance with District Rule 475

, combustion

contaminant

emissions may exceed the concentration limit or the mass emission limit listed, but not both limits at the same time. A327.1

[ RULE 475, 10-8-1976; 

### RULE 475, 8-7-1978]

[Devices subject to this condition : D1, D7, D13, D25, D31, D37, D43]

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 29



### The operator shall comply at all times with the 2.5 ppm 1- hour BACT liimit for NOx, except as defined in condition A99.1 and for the following scenario:: A433.1

Operating

Scenario Maximum Hourly Emissions

Limit Operational Limit

29.54 Start-up hour NOx emissions not to exceed 29.54lbs total per start-up per

turbine. Each turbine shall be limited to 300 start-ups per year, with each start-up not to exceed

25 minutes.

[RULE 1703(a)(2) - PSD-BACT, 10-7-1988; RULE 2005, 4-20-2001 

### ]

[Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]



### Material/Fuel Type Limits B.

The operator shall not use natural gas containing the following specified compounds: B61.1

Compound Grains per 100 scf

greater than 0.25 H2S

This concentration limit is an annual average based on monthly sample of natural

gas composition or gas supplier documentation. Gaseous fuel samples shall be tested using District Method 307-91 for total sulfur calculated as H2S.

[ RULE 1303(b)(2)-Offset, 5-10-1996; 

### RULE 1303(b)(2)-Offset, 12-6-2002]

[Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]

The operator shall only use diesel fuel containing the following specified compounds: B61.2

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 30



### Compound Range ppm by weight

less than or equal to Sulfur 15

The operator shall maintain a copy of the MSDS on site

[ RULE 431.2, 5-4-1990; 

### RULE 431.2, 9-15-2000]

[Devices subject to this condition : D49]



### Throughput or Operating Parameter Limits C.

The operator shall limit the fuel usage to no more than 425 MM cubic feet in any one

calendar month. C1.1

For

the purpose of this condition, fuel usage shall be defined as the total natural gas usage of a single turbine during a non-commissioning month..

The operator shall maintain records in a manner approved by the District, to demonstrate compliance with this condition.

[ RULE 1303(b)(2)-Offset, 5-10-1996; 

### RULE 1303(b)(2)-Offset, 12-6-2002]

[Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]

The operator shall limit the fuel usage to no more than 301 MM cubic feet. C1.3

For

the purpose of this condition, fuel usage shall be defined as the total natural

gas usage of a single turbine during a commissioning period. The max fuel usage shall not exceed 301 mmcf per month.

The operator shall maintain records in a manner approved by the District, to demonstrate compliance with this condition.

[ RULE 1303(b)(2)-Offset, 5-10-1996; 

### RULE 1303(b)(2)-Offset, 12-6-2002]

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 31



### [Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]

The operator shall limit the operating time to no more than 50 hour(s) in any one year. C1.4

For

the purposes of this condition, the operating time is inclusive of time allotted for maintenance and testing.

[RULE 1110.2, 2-1-2008; RULE 1303(b)(2)-Offset, 5-10-1996; 

### RULE 1303(b)(2)
-Offset, 12-6-2002; RULE 1470, 6-1-2007; RULE 2012, 5-6-2005 

### ]

[Devices subject to this condition : D49]

The operator shall limit the fuel usage to no more than 2455 MM cubic feet per year. C1.6

For

the purpose of this condition, fuel usage shall be defined as the total natural gas usage of a single turbine during a non-commissioning year..

The operator shall maintain records in a manner approved by the District, to demonstrate compliance with this condition.

[RULE 1401, 3-4-2005; RULE 1703(a)(3) PSD Analysis, 10-7-1988]

[Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]

The operator shall install and maintain a pressure relief valve with a minimum pressure set at 25 psig. C157.1

[ RULE 1303(a)(1)-BACT, 5-10-1996; 

### RULE 1303(a)(1)-BACT, 12-6-2002]

[Devices subject to this condition : D52, D53]



### Monitoring/Testing Requirements D.

The operator shall install and maintain a (n ) flow meter to accurately indicate the fuel usage being supplied to the turbine. D12.1

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 32



### The operator shall also install and maintain a device to continuously record the parameter being measured

[ RULE 1303(b)(2)-Offset, 5-10-1996; 

### RULE 1303(b)(2)-Offset, 12-6-2002; RULE 2012,

5-6-2005 

### ]

[Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]

The operator shall install and maintain a (n ) flow meter to accurately indicate the flow rate of the total hourly throughput of injected ammonia. D12.2

The operator shall also install and maintain a device to continuously record the

parameter being measured

The measuring device or gauge shall be accurate to within plus or minus 5
percent.

It shall be calibrated once every twelve months. The calibrations records shall be kept on site and made available to AQMD personnel upon request.

The ammonia injection system shall be placed in full operation as soon as the
minimum temperature is reached. The minimum temperature is listed as 540 degrees F. at the inlet to the SCR reactor

[ RULE 1303(a)(1)-BACT, 5-10-1996; 

### RULE 1303(a)(1)-BACT, 12-6-2002]

[Devices subject to this condition : C4, C10, C16, C22, C28, C34, C40, C46]

The operator shall install and maintain a (n ) temperature gauge to accurately indicate the temperature of the at the inlet to the SCR reactor. D12.3

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 33



### The operator shall also install and maintain a device to continuously record the parameter being measured

The measuring device or gauge shall be accurate to within plus or minus 5 percent

It shall be calibrated once every twelve months.

The catalyst temperature range shall remain between 740 degree F and 840 degrees F

The catalyst intlet temperature shall not exceed 840 degrees F.

The temperature range requirement of this condition does not apply during start-up operations of the turbine not to exceed 25 minutes per start-up.

For this condition start

- up shall be defined as the start up process to bring the
turbine in full successful operations. If during start

- up the process is aborted and
the start

- up is restarted, then the start

- up and restart is defined as " one start -up ". In this case the start-up time shall not exceed one hour

[ RULE 1303(a)(1)-BACT, 5-10-1996; 

### RULE 1303(a)(1)-BACT, 12-6-2002; RULE 1703(a)(2) - PSD-BACT, 10-7-1988; RULE 2005, 5-6-2005 

### ]

[Devices subject to this condition : C4, C10, C16, C22, C28, C34, C40, C46]

The operator shall install and maintain a (n ) pressure gauge to accurately indicate the differential pressure across the SCR catalyst bed in inches of water column. D12.4

The operator shall also install and maintain a device to continuously record the

parameter being measured

The measuring device or gauge shall be accurate to within plus or minus 5 percent. It shall be calibrated once every twelve months

It shall be calibrated once every twelve months

The pressure drop across the catalyst shall not exceed 12 inches water column

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 34



### [ RULE 1303(a)(1)-BACT, 5-10-1996; 

### RULE 1303(a)(1)-BACT, 12-6-2002; RULE 1703(a)(2) - PSD-BACT, 10-7-1988; RULE 2005, 5-6-2005 

### ]

[Devices subject to this condition : C4, C10, C16, C22, C28, C34, C40, C46]

The operator shall install and maintain a (n ) non- resettable elapsed time meter to accurately indicate the elapsed operating time from the engine. D12.5

[RULE 1110.2, 2-1-2008; RULE 1303(b)(2)-Offset, 5-10-1996; 

### RULE 1303(b)(2)

-Offset, 12-6-2002; RULE 1470, 6-1-2007; RULE 2012, 5-6-2005 

### ]

[Devices subject to this condition : D49]

The operator shall conduct source test(s) for the pollutant(s) identified below. D29.1

Pollutant(s) to

be tested Required Test Method(s) Averaging Time Test Location

Outlet of the SCR serving this equipment District method 100.1 NOX emissions 1 hour

1 hour CO emissions District method 100.1 Outlet of the SCR serving this equipment Fuel sample AQMD Laboratory

Method 307-91 Not Applicable SOX emissions

Outlet of the SCR serving this equipment District Method 25.3 VOC emissions 1 hour

PM10

emissions Outlet of the SCR serving this equipment District Method 5 4 hours

District method 207.1

and 5.3 or EPA method

17 Outlet of the SCR serving this equipment NH3 emissions 1 hour

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 35



### The test shall be conducted after AQMD approval of the source test protocol, but

no later the later of 180 days after initial start

- up or three hundred hours of operations after start -up

. The AQMD shall be notified of the date and time of the test at least 10 days prior to the test

The test shall be conducted to determine the oxygen levels in the exhaust. In addition, the tests shall measure the fuel flow rate (CFH)

, the flue gas flow rate, and the turbine generating output in MW.

The test shall be conducted in accordance with AQMD approved test protocol

. The protocol shall be submitted to the AQMD engineer no later than 45 days
before the proposed test date and shall be approved by the AQMD before the test

commences

. The test protocol shall include the proposed operating conditions of
the turbine during the tests, the identity of the testing lab, a statement from the testing lab certifying that it meets the criteria of Rule 304

, and a description of all sampling and analyt

The test shall be conducted when this equipment is operating at maximum, average, and minimum loads.

The test shall be conducted for compliance verification of the BACT VOC 2.0 ppmv limit.

For natural gas fired turbines only, VOC compliance shall be demonstrated as
follows : a ) Stack gas samples are extracted into Summa canisters maintaining a
final canister pressure between 400-500 mm Hg absolute, b) Pressurization of
canisters are done with zero gas analyzed / certified to contain less than 0.05 ppmv
total hydrocarbon as carbon, and c) Analysis of canisters are per EPA Method TO-12 ( with pre concentration) and temperature of canisters when extracting samples for analysis is not below 7

The use of this alternative method for VOC compliance determination does not

mean that it is more accurate than AQMD Method 25.3

, nor does it mean that it

may be used in lieu of AQMD Method 25.3 without prior approval except for the
determination of compliance with the VOC BACT level of 2.0 ppmv calculated as carbon for natural gas fired turbines.

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 36



### Because the VOC BACT level was set using data derived from various source test results, this alternate VOC compliance method provides a fair comparison and
represents the best sampling and analysis technique for this purpose at this time

. The test results shall be reported with two significant digits.

For the purpose of this condition, alternative test method may be allowed for each of the above pollutants upon concurrence of AQMD, EPA and CARB.

[ RULE 1303(a)(1)-BACT, 5-10-1996; 

### RULE 1303(a)(1)-BACT, 12-6-2002; RULE
1303(b)(2)-Offset, 5-10-1996; 

### RULE 1303(b)(2)-Offset, 12-6-2002; RULE 1703(a)(2) -
PSD-BACT, 10-7-1988; RULE 2005, 5-6-2005 

### ]

[Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]

The operator shall conduct source test(s) for the pollutant(s) identified below. D29.2

Pollutant(s) to

be tested Required Test Method(s) Averaging Time Test Location

Outlet of the SCR serving this equipment District method 207.1

and 5.3 or EPA method

17 NH3 emissions 1 hour

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 37



### The test shall be conducted and the results submitted to the District within 45 days after the test date. The AQMD shall be notified of the date and time of the test at least 7 days prior to the test.

The test shall be conducted at least quarterly during the first twelve months of operation and at least annually thereafter. The NOx concentration, as determined by the CEMS, shall be simultaneously recorded during the ammonia slip test. If
the CEMS is inoperable, a test shall be conducted to determine the NOx
emissions using District Method 100.1 measured over a 60 minute averaging time period.

If the turbine is not in operation during one quarter, then no testing is required during that quarter

The test shall be conducted to demonstrate compliance with the Rule 1303 BACT
concentration limit

[ RULE 1303(a)(1)-BACT, 5-10-1996; 

### RULE 1303(a)(1)-BACT, 12-6-2002]

[Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]

The operator shall conduct source test(s) for the pollutant(s) identified below. D29.3

Pollutant(s) to

be tested Required Test Method(s) Averaging Time Test Location

Fuel sample AQMD Laboratory

Method 307-91 SOX emissions Not Applicable

1 hour VOC emissions District Method 25.3 Outlet of the SCR serving this equipment

Outlet of the SCR serving this equipment District Method 5 4 hours PM10

emissions

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 38



### The test shall be conducted at least once every three years.

The test shall be conducted to determine the oxygen levels in the exhaust. In addition, the tests shall measure the fuel flow rate (CFH)

, the flue gas flow rate, and the turbine generating output in MW.

The test shall be conducted in accordance with AQMD approved test protocol

. The protocol shall be submitted to the AQMD engineer no later than 45 days
before the proposed test date and shall be approved by the AQMD before the test

commences

. The test protocol shall include the proposed operating conditions of
the turbine during the tests, the identity of the testing lab, a statement from the testing lab certifying that it meets the criteria of Rule 304

, and a description of all sampling and analyt

The test shall be conducted when this equipment is operating at maximum, average, and minimum loads.

The test shall be conducted for compliance verification of the BACT VOC 2.0 ppmv limit.

For natural gas fired turbines only, VOC compliance shall be demonstrated as
follows : a ) Stack gas samples are extracted into Summa canisters maintaining a
final canister pressure between 400-500 mm Hg absolute, b) Pressurization of
canisters are done with zero gas analyzed / certified to contain less than 0.05 ppmv
total hydrocarbon as carbon, and c) Analysis of canisters are per EPA Method TO-12 ( with pre concentration) and temperature of canisters when extracting samples for analysis is not below 7

The use of this alternative method for VOC compliance determination does not

mean that it is more accurate than AQMD Method 25.3

, nor does it mean that it

may be used in lieu of AQMD Method 25.3 without prior approval except for the
determination of compliance with the VOC BACT level of 2.0 ppmv calculated as carbon for natural gas fired turbines.

Because the VOC BACT level was set using data derived from various source test results, this alternate VOC compliance method provides a fair comparison and

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 39



### represents the best sampling and analysis technique for this purpose at this time

. The test results shall be reported with two significant digits.

For the purpose of this condition, alternative test method may be allowed for each of the above pollutants upon concurrence of AQMD, EPA and CARB.

[ RULE 1303(a)(1)-BACT, 5-10-1996; 

### RULE 1303(a)(1)-BACT, 12-6-2002; RULE
1303(b)(2)-Offset, 5-10-1996; 

### RULE 1303(b)(2)-Offset, 12-6-2002; RULE 1703(a)(2) -
PSD-BACT, 10-7-1988]

[Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]

The operator shall install and maintain a CEMS to measure the following parameters: D82.1

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 40



### CO concentration in ppmv

Concentrations shall be corrected to 15 percent oxygen on a dry basis

The CEMS shall be installed and operated to measure CO concentrations over a 15 minute averaging time period.

The CEMS shall be installed and operated to measure CO concentrations over a 15 minute averaging time period.

The CEMS would convert the actual CO concentrations to mass emission rates (lbs/hr ) using the equation below and record the hourly emission rates on a
continuous basis.

The CEMS would convert the actual CO concentrations to mass emission rates (lbs/hr ) using the equation below and record the hourly emission rates on a
continuous basis.

CO Emission Rate, lbs / hr = K Cco Fd [20.9 % - % O2 d)][( Qg * HHV)/1.0^6],
where

K = 7.267 *10^-8 (lb/scf)/ppm

Cco = Average of four consecutive 15 min. ave. CO concentration, ppm

Fd = 8710 dscf/MMBTU natural gas

%O2 d = Hourly ave. % by vol. O2 dry, corresponding to Cco

Qg = Fuel gas usage during the hour, scf/hr

HHV = Gross high heating value of fuel gas, BTU/scf

[RULE 1703(a)(2) - PSD-BACT, 10-7-1988; RULE 218, 8-7-1981; 

### RULE 218,
5-14-1999]

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 41



### [Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]

The operator shall install and maintain a CEMS to measure the following parameters: D82.2

NOx concentration in ppmv

Concentrations shall be corrected to 15 percent oxygen on a dry basis.

The CEMS shall be installed and operating no later than 90 days after initial

start- up of the turbine and shall comply with the requirements of Rule 2012. During the interim period between the initial start

- up and the provisional
certification date of the CEMS, the operator shall comply with the monitoring requirements of Rule 2012(h)(2 ) and 2012(h)(3 ). Within two weeks of the
turbine start

- up date, the operator shall provide written notification to the District of the exact date of start-up

The CEMS shall be installed and operating ( for BACT purposes only) no later than 90 days after initial start up of the turbine.

[RULE 1703(a)(2) - PSD-BACT, 10-7-1988; RULE 2005, 5-6-2005; RULE 2012,

5-6-2005 

### ]

[Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]



### Equipment Operation/Construction Requirements E.

The operator shall vent this equipment, during filling, only to the vessel from which it is being filled. E144.1

[ RULE 1303(a)(1)-BACT, 5-10-1996; 

### RULE 1303(a)(1)-BACT, 12-6-2002]

[Devices subject to this condition : D52, D53]

For the purpose of the following condition number (s)

, condition number (s), continuously record shall be defined as measuring at least once every month and shall be calculated based upon the average of the continuous monitoring for that month. E179.1

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 42



### Condition Number D 12- 4

[ RULE 1303(a)(1)-BACT, 5-10-1996; 

### RULE 1303(a)(1)-BACT, 12-6-2002]

[Devices subject to this condition : C4, C10, C16, C22, C28, C34, C40, C46]

For the purpose of the following condition number (s)

, continuously record shall be

defined as recording at least once every hour and shall be calculated based upon the average of the continuous monitoring for that hour. E179.2

Condition Number D 12- 2

Condition Number D 12- 3

[ RULE 1303(a)(1)-BACT, 5-10-1996; 

### RULE 1303(a)(1)-BACT, 12-6-2002; RULE 1703(a)(2) - PSD-BACT, 10-7-1988; RULE 2005, 5-6-2005 

### ]

[Devices subject to this condition : C4, C10, C16, C22, C28, C34, C40, C46]

For the purpose of the following condition number (s)

, continuously record shall be

defined as measuring at least once every month and shall be calculated based upon the average of the continuous monitoring for that month. E179.3

Condition Number D 12- 2

[ RULE 1303(a)(1)-BACT, 5-10-1996; 

### RULE 1303(a)(1)-BACT, 12-6-2002; RULE 1703(a)(2) - PSD-BACT, 10-7-1988; RULE 2005, 5-6-2005 

### ]

[Devices subject to this condition : C4, C10, C16, C22, C28, C34, C40, C46]

The operator shall upon completion of construction, operate and maintain this equipment according to the following specifications: E193.1

In accordance with all mitigation measures stipulated in the final California

Energy Commission decision for the 07-AFC-3 project

[CA PRC CEQA, 11-23-1970]

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 43



### [ Devices subject to this condition : D1

, C 4

, D 7

, C 10

, D 13

, C 16

, D 19

, C 22

, D 25

, C 28, D31, C34, D37, C40, C46, D52, D53]



### Applicable Rules H.

This equipment is subject to the applicable requirements of the following rules or regulations: H23.1

Contaminant Rule Rule/Subpart

40CFR60, SUBPART NOX KKKK

KKKK SOX 40CFR60, SUBPART

[ 40CFR 60 Subpart KKKK, 7-6-2006 

### ]

[Devices subject to this condition : D1, D13, D19, D25, D31, D37, D43]



### Administrative I.

This equipment shall not be operated unless the operator demonstrates to the Executive

Officer that the facility holds sufficient RTCs to offset the prorated annual emissions

increase for the first compliance year of operation. In addition, this equipment shall not

be operated unless the operator demonstrates to the Executive Officer that, at the

commencement

of each compliance year after the first compliance year of operation, the facility holds sufficient RTCs in an amount equal to the annual emissions increase. I296.1

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 44



### To comply with this condition, the operator shall prior to the 1 st compliance year
hold a minimum NOx RTCs of 35767 lbs/yr

. This condition shall apply during the

1 st 12 months of operation, commencing with the initial operation of the gas
turbine.

To comply with this condition, the operator shall, prior to the beginning of all

years subsequent to the 1 st compliance year, hold a minimum of 30,039 lbs/ yr fo NOx RTCs for operation of the gas turbine

In accordance with Rule 2005(f)

, unused RTC's may be sold only during the
reconciliation period for the fourth quarter of the applicable compliance year inclusive of the 1st compliance year.

This condition shall apply to each turbine individually.

[ RULE 2005, 5-6-2005 

### ]

[Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]

This equipment shall not be operated unless the operator demonstrates to the Executive

Officer that the facility holds sufficient RTCs to offset the prorated annual emissions

increase for the first compliance year of operation. In addition, this equipment shall not

be operated unless the operator demonstrates to the Executive Officer that, at the

commencement

of each compliance year after the first compliance year of operation, the facility holds sufficient RTCs in an amount equal to the annual emissions increase. I296.3

To comply with this condition, the operator shall prior to the 1 st compliance year
hold a minimum NOx RTCs of 77 lbs/yr

. This condition shall apply during the 1st 12 months of operation, commencing with the initial operation of the fire pump

In accordance with Rule 2005(f)

, unused RTC's may be sold only during the
reconciliation period for the fourth quarter of the applicable compliance year inclusive of the 1st compliance year.

[ RULE 2005, 5-6-2005 

### ]

[Devices subject to this condition : D49]

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 45



### Record Keeping/Reporting K.

The operator shall provide to the District a source test report in accordance with the following specifications: K40.1

Source test results shall be submitted to the District no later than 60 days after

the source test was conducted

Emission data shall be expressed in terms of concentration (ppmv ) corrected to

15 percent

oxygen ( dry basis )

, mass rate (lb/hr)

, and lb /MMCF

. In addition, solid

PM emissions, if required to be tested, shall also be reported in terms of grains/DSCF

All exhaust flow rate shall be expressed in terms of dry standard cubic feet per minute (DSCFM) and dry actual cubic feet per minute (DACFM).

All moisture concentration shall be expressed in terms of percent corrected to 15
percent oxygen

Source test results shall also include the oxygen levels in the exhaust, fuel flow

rate (CFH) ,heating content of the fuel, the flue gas temperature, and the generator power output (MW) under which the test was conducted

[ RULE 1303(a)(1)-BACT, 5-10-1996; 

### RULE 1303(a)(1)-BACT, 12-6-2002; RULE
1303(b)(2)-Offset, 5-10-1996; 

### RULE 1303(b)(2)-Offset, 12-6-2002; RULE 1703(a)(2) -
PSD-BACT, 10-7-1988; RULE 2005, 5-6-2005 

### ]

[Devices subject to this condition : D1, D7, D13, D25, D31, D37, D43]

The operator shall keep records, in a manner approved by the District, for the following parameter(s) or item(s): K67.1

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 46



### Natural gas fuel use after CEMS certification

Natural gas fuel use during the commissioning period

Natural gas fuel use after the commissioning period and prior to CEMS
certification

[ RULE 2005, 5-6-2005 

### ]

[Devices subject to this condition : D1, D7, D13, D19, D25, D31, D37, D43]

The operator shall keep records, in a manner approved by the District, for the following parameter(s) or item(s): K67.2

The operator shall document an inspection each time the tank is filled to insure

the vapor recovery equipment is consistently and properly used

[ RULE 1303(a)(1)-BACT, 5-10-1996; 

### RULE 1303(a)(1)-BACT, 12-6-2002]

[Devices subject to this condition : D52, D53]

The operator shall keep records, in a manner approved by the District, for the following parameter(s) or item(s): K67.3

## SECTION H: PERMIT TO CONSTRUCT AND TEMPORARY PERMIT TO OPERATE

The operator shall comply with the terms and conditions set forth below: 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section H

Revision #: 47



### Manual and automatic operation and shall list all engine operations in each of the following areas:

Emergency use hours of operation

Maintenance and testing hours

Other operating hours (describe the reason for operation)

In addition, each time the engine is started manually, the log shall include the date
of operation and the timer reading in hours at the beginning and end of operation

. the log shall be kept for a minimum of five calendar years prior to the current

year and made available to district personnel upon request. the total hours of operation for the previous calendar year shall be recorded sometime during the first 15 days of January of each year.

[RULE 1110.2, 2-1-2008; RULE 1470, 6-1-2007]

[Devices subject to this condition : D49]

## SECTION I: PLANS AND SCHEDULES 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 1 Page:

Date: Facility ID: Section I

Revision #:



### This section lists all plans approved by AQMD for the purposes of meeting the requirements of applicable AQMD rules.



## NONE

NOTE : This section does not list compliance schedules pursuant to the requirements of Regulation XXX - Title

V Permits; Rule 3004(a)(10)(C ). For equipment subject to a variance, order for abatement, or alternative
operating condition granted pursuant to Rule 518.2

, equipment specific conditions are added to the equipment in
Section D or H of the permit.

## FACILITY PERMIT TO OPERATE

SECTION J: AIR TOXICS 

## CPV SENTINEL LLC DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Section J

Revision #: 1



## NOT APPLICABLE

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 1 Page:

Date: Facility ID: Section K

Revision #:



## SECTION K: TITLE V Administration

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 2 Page:

Date: Facility ID: Section K

Revision #:



## SECTION K: TITLE V Administration

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 3 Page:

Date: Facility ID: Section K

Revision #:



## SECTION K: TITLE V Administration

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 4 Page:

Date: Facility ID: Section K

Revision #:



## SECTION K: TITLE V Administration

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 5 Page:

Date: Facility ID: Section K

Revision #:



## SECTION K: TITLE V Administration

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 6 Page:

Date: Facility ID: Section K

Revision #:



## SECTION K: TITLE V Administration

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 7 Page:

Date: Facility ID: Section K

Revision #:



## SECTION K: TITLE V Administration

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT March 02, 2010 152707 8 Page:

Date: Facility ID: Section K

Revision #:



## SECTION K: TITLE V Administration

## SECTION K: TITLE V Administration 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT
March 02, 2010 152707 Page:

Date: Facility ID: Section K

Revision #: 9



### This facility is subject to the following rules and regulations 

### FACILITY RULES

With the exception of Rule 402

, 473

, 477

, 1118 and Rules 1401 through 1420

, the following

rules that are designated as non

- federally enforceable are pending EPA approval as part of the

state implementation plan. Upon the effective date of that approval, the approved rule (s ) will

become federally enforceable, and any earlier versions of those rules will no longer be federally

enforceable.



### RULE SOURCE Adopted/Amended Date FEDERAL Enforceability

RULE 1110.2 2-1-2008 Non federally enforceable

RULE 1113 11-8-1996 Federally enforceable

RULE 1113 7-13-2007 Non federally enforceable

RULE 1171 11-7-2003 Federally enforceable

RULE 1171 2-1-2008 Non federally enforceable

RULE 1303 5-10-1996 Federally enforceable
RULE 1303(a)(1)-BACT 12-6-2002 Non federally enforceable
RULE 1303(a)(1)-BACT 5-10-1996 Federally enforceable
RULE 1303(b)(2)-Offset 12-6-2002 Non federally enforceable
RULE 1303(b)(2)-Offset 5-10-1996 Federally enforceable

RULE 1401 3-4-2005 Non federally enforceable

RULE 1470 6-1-2007 Non federally enforceable
RULE 1703 - PSD Analysis 10-7-1988 Federally enforceable
RULE 1703(a)(2) -

PSD-BACT 10-7-1988 Non federally enforceable

RULE 1703(a)(3) PSD
Analysis 10-7-1988 Non federally enforceable

RULE 2005 4-20-2001 Federally enforceable

RULE 2005 5-6-2005 Federally enforceable

RULE 2012 5-6-2005 Federally enforceable

RULE 218 5-14-1999 Non federally enforceable

RULE 218 8-7-1981 Federally enforceable

## SECTION K: TITLE V Administration 

## CPV SENTINEL LLC FACILITY PERMIT TO OPERATE DRAFT
March 02, 2010 152707 Page:

Date: Facility ID: Section K

Revision #: 10



### RULE SOURCE Adopted/Amended Date FEDERAL Enforceability

RULE 3002 11-14-1997 Federally enforceable

RULE 3003 11-14-1997 Federally enforceable

RULE 3003 3-16-2001 Non federally enforceable

RULE 3004 12-12-1997 Federally enforceable

RULE 3005 11-14-1997 Federally enforceable

RULE 3005 3-16-2001 Non federally enforceable

RULE 3007 10-8-1993 Federally enforceable

RULE 401 11-9-2001 Non federally enforceable

RULE 401 3-2-1984 Federally enforceable

RULE 407 4-2-1982 Federally enforceable

RULE 408 5-7-1976 Federally enforceable

RULE 409 8-7-1981 Federally enforceable

RULE 431.2 5-4-1990 Federally enforceable

RULE 431.2 9-15-2000 Non federally enforceable

RULE 475 10-8-1976 Federally enforceable

RULE 475 8-7-1978 Non federally enforceable

RULE 701 6-13-1997 Federally enforceable
CA PRC CEQA 11-23-1970 Non federally enforceable
40CFR 51 Subpart S 3-8-2007 Federally enforceable
40CFR 60 Subpart KKKK 7-6-2006 Federally enforceable

40CFR 72 - Acid Rain

Provisions 11-24-1997 Federally enforceable

## FACILITY PERMIT TO OPERATE

APPENDIX A: NOX AND SOX EMITTING EQUIPMENT EXEMPT FROM WRITTEN 

## CPV SENTINEL LLC 152707 1 Appendix A Facility ID:
Revision #:

Date: Page:

DRAFT March 02, 2010



## PERMIT PURSUANT TO RULE 219



## NONE

### APPENDIX B: RULE EMISSION LIMITS 

## FACILITY PERMIT TO OPERATE CPV SENTINEL LLC DRAFT March 02, 2010 152707 Page:

Date: Facility ID: Appendix B

Revision #: 1



### [RULE 1113 11-08-1996]

### APPENDIX B: RULE EMISSION LIMITS 

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### 1 | Page 

## APPENDIX N

Emissions Offset Evaluation Prepared for

Addendum to Determination of Compliance Submitted to CEC

CPV Sentinel Energy Project

(March 2, 2010)

This document is being submitted by the South Coast Air Quality Management District (AQMD)

as part of its Determination of Compliance (DOC) for the CPV Sentinel Energy Project (CPV
Sentinel). Under federal, state and local laws, rules and regulations, it is required that emission

increases of specified nonattainment air contaminants and their precursors be offset for the

CPV Sentinel. This evaluation is done pollutant specific for compliance with local, state and

federal laws based on AQMD Regulations XIII (Rule 1303) and XX (Rule 2005); the federal Clean

Air Act and NSR Regulations; and State of California Clean Air Act No Net Increase and Assembly

Bill (AB) 1318 provisions.

Emission offsets for Volatile Organic Compounds (VOCs) will be provided by CPV Sentinel in the

form of Emission Reduction Credits (ERCs) purchased by CPV Sentinel in the open market

pursuant to AQMD Regulation XIII (Rule 1303). Emission offsets for Nitrogen Oxides (NOx) will

also be provided by CPV Sentinel in the form of RECLAIM Trading Credits (RTCs) purchased by

CPV Sentinel in the open market pursuant to AQMD Regulation XX (Rule 2005). Emission

offsets for Sulfur Oxides (SOx) and Particulate Matter

‐ less than 10 micron in diameter ‐ (PM10)

will be provided by AQMD from offset credits pursuant to AB 1318 (Health & Safety Code

Section 40440.14(a)). CPV Sentinel will pay AQMD mitigation fees for SOx and PM10 offsets,

which in turn AQMD will invest in emission reduction projects pursuant to AB 1318. Emission

offsets for Carbon Monoxide (CO) and Particulate Matter

‐ less than 2.5 micron in diameter ‐ (PM2.5) are not required, since the Salton Sea Air Basin (SSAB), where CPV Sentinel is to be

located, is not classified as nonattainment with respect to CO or PM2.5.

The CPV offset evaluation for SOx and PM10, which is provided under this DOC to CEC, pursuant

to AB 1318 (Health & Safety Code Section 40440.14(c)), will also be submitted to the U.S.

Environmental Protection Agency (EPA) for approval and inclusion into the State
Implementation Plan (SIP). Table 1 below shows the CPV Sentinel emissions and the source of

offsets for each air contaminant. Emissions in the first year are higher due to initial

commissioning of the CPV Sentinel power plant.

### 2 | Page 

## Table 1

– Maximum Emissions and Offsets

Pollutant Maximum Emissions Needing Offsets Offset Source

VOC 441 lbs/day* ERCs

– supplied by CPV Sentinel, LLC.

NOx Commissioning Year RTCs

– 286,786.05 lbs/year

Other Years RTCs

– 240,958.05 lbs/year RTCs

– supplied by CPV Sentinel, LLC.

SOx Commissioning Year

– 13,928 lbs/year

Other Years

– 13,560 lbs/year AQMD’s internal offset accounts, per
AB1318. PM10 Commissioning Year –118,120 lbs/year

Other Years

– 112,180 lbs/year

CO Worst case

– 188 tons/year Not Nonattainment pollutant in SSAB.

Offsets not required.**

PM2.5 Worst case***

– 59.06 tons/year Not Nonattainment pollutant in SSAB.

Offsets not required.****

*Includes 1.2

‐ to

‐ 1.0 offset ratio, as per Rule 1303(b)(2)(A.)

** SSAB is not classified as Nonattaiment for federal and state ambient air quality standards for CO. (SSAB is classified as

Attainment for state and is Unclassified/Attainment for federal.) Therefore, no CO offsets are required. The worst case

maximum yearly CO emission of 188 tons/year is below the 250 ton/year threshold for Prevention of Significant Deterioration
(PSD) as specified by Rule 1701(b)(2). Therefore, does not require a PSD permit.
***Assuming all (100%) of PM10 emissions are PM2.5.

****SSAB is not classified as Nonattainment for federal and state ambient air quality standards for PM2.5. (SSAB is Unclassified

for state and Unclassified/Attainment for federal.) Therefore, no PM2.5 offsets are required. The worst case maximum yearly

PM2.5 emission of 59.06 tons/year is below the 250 ton/year threshold for PSD and, therefore, it does not require a PSD

permit.



### VOC Emissions

The CPV Sentinel project complies with all of the VOC offset requirements (at a 1.2

‐ to

‐ 1.0 offset
ratio) through CPV Sentinel providing VOC ERCs prior to issuance of the PC, as specified in

AQMD Rule 1303(b)(2). As shown in Table 2 below, CPV Sentinel has already purchased
adequate amounts of VOC ERCs to offset 412 lbs/day of VOC emissions and will provide an

additional 29 lbs/day of VOC ERCs prior to issuance of the final Title V permit to cover the

maximum offset liability of 441 lbs/day of VOC emissions (see Table 1 above).



## Table 2

– Maximum VOC Emission Rates and Offsets

ERC

Certificate

No. ERC Certificate Registered Owner ERC Certificate Amount (lbs/day)

AQ007877 Tenasko 348

AQ007879 Tenasko 64

Total Amounts of VOC ERCs Provided 412

Additional VOC ERCs to be Provided 29

Total Emissions & VOC ERCs 441

### 3 | Page 

### NOX Emissions

The CPV Sentinel project complies with all of the NOx offset requirements (at a 1.0

‐ to

‐ 1.0 offset
ratio) through requiring CPV Sentinel to hold sufficient NOx RTCs to offset the annual emission

increase for the first year of operation prior to commencement of initial operation, as specified

in Rule 2005(b)(2). AQMD provides a programmatic demonstration, as approved by EPA, in

March of each year in its Annual RECLAIM Audit report to the Governing Board that the 1.2 to

1 offset ratio required by federal law is met on an aggregate basis for RECLAIM new and

modified sources. CPV Sentinel shall also, at the commencement of each subsequent
compliance year, hold NOx RTCs equal to the amount required by permit conditions, as specified in Rule 2005(f)(1).

CO Emissions

The CPV Sentinel project complies with the CO offset requirements on the basis that the SSAB is

not classified as “Nonattainment” for federal and state ambient air quality standards for CO.
(SSAB is classified as Attainment for state and Unclassified/Attainment for federal.) Therefore

offsets are not required. Also the maximum worst case yearly CO emission is 188 tons/year,

which is below the PSD threshold of 250 tons/year. Therefore, no PSD permit is required.

PM2.5 Emissions

The CPV Sentinel project complies with the PM2.5 offset requirements on the basis that the

SSAB is not classified as “Nonattainment” for federal and state ambient air quality standards for

PM2.5. (SSAB is Unclassified for state and Unclassified/Attainment for federal.) Therefore,

offsets are not required. Also the maximum worst case yearly PM2.5 emission, even assuming

that all (100%) of the PM10 emissions are PM2.5, is 59.06 tons/year, which is below the PSD

threshold of 250 tons/year. Therefore, no PSD permit is required.

PM10 and SOx Emissions

Emission Offsets ‐ The SSAB is attainment with both federal and state SO2 and Sulfate ambient

air quality standards, as applicable. However, SO2 is also considered a precursor to PM10.
Presently the SSAB is still designated as “Nonattainment” with both federal and state PM10

ambient air quality standards.

### 4 | Page 

### CPV Sentinel is obtaining offsets for both PM10 and SOx from the AQMD internal bank pursuant

to AB 1318. Under federal law any required PM10 and SOx offsets have to be provided at an

offset ratio of 1.0

‐ to

‐ 1.0. In addition, California state law offset requirements, if applicable to

any project, requires actual (not maximum potential) emissions to be offset at the same 1.0

‐ to

‐
1.0 offset ratio as the actual emissions. Therefore, the maximum amount of offsets that are being provided for the CPV Sentinel project’s emissions in the initial commissioning year 1 

### are
118,120 lbs/year and 13,928 lbs/year of PM10 and SOx, respectively, as shown earlier in Table

1. These amounts of offsets are obtained by CPV Sentinel and provided by AQMD from

AQMD’s internal emission credit accounts pursuant to AB 1318.

In Attachment I, AQMD has provided an internal emission offset account tracking system

pursuant to AB 1318. The amounts of emission offsets presently deposited by AQMD in the AB

1318 tracking system cover the amounts needed by CPV Sentinel (please see Attachment 1). As

indicated earlier, the offset evaluations for PM10 and SOx and the AB 1318 tracking system will

also be submitted to EPA in the form of a SIP revision.

Redesignation & Maintenance Plan

– Although CPV Sentinel is obtaining and AQMD is
providing emission offsets for PM10 and SOx (as precursor to PM10), the AQMD and CARB

Governing Boards have already approved the SSAB PM10 Redesignation and Maintenance Plan
(RMP) for submittal to EPA for inclusion into the SIP. Under federal NSR offsets are required

prior to start of operation. Upon EPA’s approval of this RMP and redesignation of SSAB as

attainment with federal PM10 NAAQS, this project will not be subject to the Nonattainment

federal NSR requirements and will not be required to provide any PM10 or SOx offsets to meet

federal requirements.

In addition, the CPV Sentinel project maximum worst case year (i.e. the initial commissioning
year) PM10 emissions are 118,120 lbs/year (or 59.06 tons/year). The federal Major Source

threshold for PM10 offsets is 70 tons/year, below which no offsets are required under federal

NSR regulations. Although the CPV Sentinel project maximum potential to emit PM10

emissions are below the federal Major Source threshold for offsets, CPV Sentinel is obtaining

offsets for both PM10 and SOx from the AQMD internal bank pursuant to AB 1318.

1 Although the amount of maximum annual emissions after the initial commissioning and start up are 112,180 lbs/year of PM10 and 13,560 lbs/year of SOx, the amount of offsets that are provided from AQMD’s internal offset

account for the CPV Sentinel project are to offset the commissioning year’s emissions of 118,120 lbs/year and

13,928 lbs/year of PM10 and SOx, respectively. This is the maximum worst case, because it assumes that all eight

gas turbines are commissioned and started up in the same year.

### 5 | Page 

# Attachment I

Assembly Bill (AB) 1318

– Tracking System

OBJECTIVES:

AB 1318, which went into effect on January 1, 2010, requires AQMD, upon making a specified finding, to

transfer SOx and PM10 emission offsets from its internal offset accounts to eligible electric generating

facilities. In implementing this emission offset transfer, AB 1318 requires AQMD to rely on the internal

offset tracking system used prior to adoption of Rule 1315 or a new tracking system approved by EPA.
Therefore, this new AB 1318 offset tracking system will be submitted to EPA for approval and inclusion

into the SIP.

AB 1318 PROVISIONS:

The specified findings required to be made in order to determine whether or not an electrical generating
facility is eligible to receive emission offsets from AQMD’s internal offset account are as follows:

• “In order to be eligible for emission reduction credits pursuant to this section, an electrical

generating facility shall meet all of the following requirements:” [Health & Safety Code Section
40440.14(d)]

o “Be subject to the permitting jurisdiction of the State Energy Resources Conservation

and Development Commission.” [Health & Safety Code Section 40440.14(d)(1)]

o “Have a purchase agreement, executed on or before December 31, 2008, to provide
electricity to a public utility, as defined in Section 216 of the Public Utilities Code,
subject to regulation by the Public Utilities Commission, for use within the Los Angeles

Basin Local Reliability Area.” [Health & Safety Code Section 40440.14(d)(2)]

o “Be under the jurisdiction of the south coast district, but not within the South Coast

Air Basin.” [Health & Safety Code Section 40440.14(d)(3)]

AQMD’s requirements for implementation of the emission offset credit transfer from its internal offset

credit account and offset tracking system, as specified in AB1318, are as follows:

• “The executive officer of the south coast district, upon finding that the eligible electrical

generating facility proposed for certification by the State Energy Resources Conservation and
Development Commission meets the requirements of the applicable new source review rule

and all other applicable district regulations that must be met under Section 1744.5 of Title 20

of the California Code of Regulations, shall credit to the south coast district's internal emission

credit accounts and transfer from the south coast district's internal emission credit accounts

to eligible electrical generating facilities emission credits in the full amounts needed to issue

permits for eligible electrical generating facilities to meet requirements for sulfur oxides (SOx)

and particulate matter (PM2.5 and PM10) emissions.” [Health and Safety Code Section
40440.14(a)]

### 6 | Page • In implementing this permitting action, “the south coast district shall rely on the offset tracking

system used prior to the adoption of Rule 1315 of the south coast district until a new tracking

system is approved by the United States Environmental Protection Agency and is in effect, at

which point that new system shall be used by the south coast district.” [Health & Safety Code

Section 40440.14(b)(1)]

• “In addition to using the prior offset tracking system, the district shall also make use of any

emission credits that have resulted from emission reductions and shutdowns from minor

sources since 1990. The district shall make any necessary submissions to the United States

Environmental Protection Agency with regard to the crediting and use of emission reductions

and shutdowns from minor sources.” [Health & Safety Code Section 40440.14(b)(2)]

In addition, AQMD is required to report the emission offsets to CEC as follows:

• “Within 60 days of the effective date of this section, for each eligible electrical generating
facility, the south coast district shall report to the State Energy Resources Conservation and
Development Commission the emission credits to be credited and transferred pursuant to

subdivision (a). The State Energy Resources Conservation and Development Commission shall

determine whether the emission credits to be credited and transferred satisfy all applicable
legal requirements. In the exercise of its regulatory responsibilities under its power facility

and site certification authority, the State Energy Resources Conservation and Development

Commission shall not certify an eligible electrical generation facility if it determines that the

credit and transfer by the south coast district do not satisfy all applicable legal requirements.”

[Health & Safety Code Section 40440.14(c)]

Finally, the transfer of offsets to an electrical generating facility is subject to the following:

• “The executive officer shall not transfer emission reduction credits to an electrical generating
facility pursuant to this section until the receipt of payment of the mitigation fees set forth in

the south coast district's Rule 1309.1, as adopted on August 3, 2007. The mitigation fees shall
only be used for emission reduction purposes. The south coast district shall ensure that at

least 30 percent of the fees are used for emission reductions in areas within close proximity to

the electrical generating facility and at least 30 percent are used for emission reductions in

areas designated as "Environmental Justice Areas" in Rule 1309.1.” [Health & Safety Code

Section 40440.14(e)]

AB 1318 TRACKING SYSTEM:

For the purposes of AB 1318 Tracking System, AQMD has identified a series of emission offsets for PM10

and SOx which have been created as a result of reductions from permitted equipment that permanently

ceased operation in AQMD. These offsets all meet the integrity criteria for qualifying as offsets,

meaning they are all Real, Permanent, Quantifiable, Enforceable and Surplus. These offsets are all result

of emission reductions from permitted equipment that permanently ceased operation in AQMD and the

AQMD has not issued any ERCs to the companies who operated the equipment as a result of the

### 7 | Page reductions. These PM10 and SOx offsets have been removed from the AQMD’s internal offset accounts

and have not been used by any other source permitted by AQMD.

The amounts of emission offsets are based on actual PM10 and SOx emissions reported to AQMD under

AQMD’s Annual Emissions Reporting Program. In addition, for each source of credit, the equipment has

been shutdown and the permits have been inactivated by AQMD. The emission reductions have

occurred during the calendar years 2002 and 2008 for PM10 credits and during the period of calendar

years 2002 through 2006 for SOx credits.

Tables A and B below include a listing of the PM10 and SOx offsets, respectively, deposited in the AB

1318 Tracking System for use by electrical generating facilities eligible to use the offsets pursuant to AB

1318 requirements. Tables A and B below show the PM10 and SOx offsets in the AB 1318 Tracking

System available for use by eligible electric generating facilities. These offsets are available for transfer

to any electrical generating facility which is eligible to obtain offsets from AQMD and upon receipt of

payment of mitigation fees set forth in AQMD’s Rule 1309.1, as adopted on August 3, 2007, pursuant to

AB 1318.

### 8 | Page 

## Table A ‐ PM10 Reductions from Sources Which Ceased Operation

Company Name Location Equipment Description Emission

Credits (lb/year)

AAA GLASS CORP LOS ANGELES GLASS MELTING FURNACE 1,877.8

AES ALAMITOS, LLC LONG BEACH TURBINE ENGINE ‐ NATURAL GAS/OIL 604.8

AES ALAMITOS, LLC LONG BEACH TURBINE ENGINE ‐ NATURAL GAS/OIL 604.8

AES ALAMITOS, LLC LONG BEACH TURBINE ENGINE ‐ NATURAL GAS/OIL 604.8

AES ALAMITOS, LLC LONG BEACH TURBINE ENGINE ‐ NATURAL GAS/OIL 604.8

AES HUNTINGTON BEACH, LLC HUNTINGTON

BEACH TURBINE ENGINE ‐ NATURAL GAS/OIL 1,417.2

AES HUNTINGTON BEACH, LLC HUNTINGTON

BEACH TURBINE ENGINE ‐ NATURAL GAS/OIL 1,417.2

AES HUNTINGTON BEACH, LLC HUNTINGTON

BEACH TURBINE ENGINE ‐ NATURAL GAS/OIL 1,417.2

ANAHEIM MARRIOTT HOTEL ANAHEIM BOILER ‐ NATURAL GAS 20.4

ANAHEIM MARRIOTT HOTEL ANAHEIM BOILER ‐ NATURAL GAS 20.4

ANAHEIM MARRIOTT HOTEL ANAHEIM BOILER ‐ NATURAL GAS 19.3

ANAHEIM MARRIOTT HOTEL ANAHEIM BOILER ‐ NATURAL GAS 19.3

ASSOCIATED READY MIXED CONCRETE

INC CORONA CONCRETE BATCH EQUIPMENT 27.4

ASTECHENGINEEREDPRODUCTSINC. SANTA ANA ABRASIVE BLASTING ‐ OPEN 16.0

AURORA MODULAR INDUSTRIES MORENO VALLEY OPEN SPRAY EQUIPMENT 451.4

AURORA MODULAR INDUSTRIES MORENO VALLEY OPEN SPRAY EQUIPMENT 451.4

AURORA MODULAR INDUSTRIES MORENO VALLEY OPEN SPRAY EQUIPMENT 451.4

AURORA MODULAR INDUSTRIES MORENO VALLEY OPEN SPRAY EQUIPMENT 451.4

AURORA MODULAR INDUSTRIES MORENO VALLEY OPEN SPRAY EQUIPMENT 451.4

BLACKHAWK FURNITURE, INC RIVERSIDE SPRAY BOOTH 604.0

BOCCHI LABORATORIES INC WALNUT BOILER ‐ NATURAL GAS 87.6

CALIFORNIA PORTLAND CEMENT CO SAN JUAN

CAPISTRANO CEMENT STORAGE SILO 12.0

CBS INC LOS ANGELES BOILER ‐ NATURAL GAS/OIL 89.6

CBS INC LOS ANGELES BOILER ‐ NATURAL GAS/OIL 89.6

CENTURY RIM CORP BREA BAKERY OVEN 32.1

CENTURY RIM CORP BREA SPRAY BOOTH 5,272.0

CHANDLER AGGREGATES CORONA AGGREGATE PRODUCTION 1,411.2

CLEAN STEEL INC LONG BEACH MATERIAL SIZE REDUCTION 4,112.5

CMC PRINTED BAG INC WHITTIER AFTERBURNER 29.0

COLOR MASTER PRINTEX, INC VERNON TENTER FRAME OVEN 75.6

COLOR MASTER PRINTEX, INC VERNON BOILER ‐ NATURAL GAS 75.6

### 9 | Page Company Name Location Equipment Description Emission

Credits (lb/year)

COLOR MASTER PRINTEX, INC VERNON BOILER ‐ NATURAL GAS 75.6

COLORGRAPHICS LOS ANGELES PRINTING PRESS ‐ HEAT SET 5.0

COLORGRAPHICS LOS ANGELES PRINTING PRESS ‐ HEAT SET 5.0

COLORGRAPHICS LOS ANGELES PRINTING PRESS ‐ HEAT SET 5.0

COLORGRAPHICS LOS ANGELES AFTERBURNER 5.0

COMMONWEALTH ALUMINUM

CONCAST INC TORRANCE COATING EQUIPMENT WITH

AFTERBURNER 671.7

CREST GRAPHICS INC COMMERCE PRINTING PRESS WITH AFTERBURNER 48.7

CREST GRAPHICS INC COMMERCE DRYING OVEN WITH AFTERBURNER 77.0

DIAMOND PACIFIC PRODUCTS CO PERRIS BOILER ‐ NATURAL GAS 92.8

DOUGLAS FURNITURE OF CALIFORNIA

LLC REDONDO BEACH BOILER ‐ WOOD FIRED WITH

BAGHOUSE 32.5

DYNAMITE INC DIAMOND BAR PORTABLE DIESEL ICE 1,704.0

DYNAMITE INC DIAMOND BAR PORTABLE DIESEL ICE 1,118.0

EL CAMINO COLLEGE TORRANCE BOILER ‐ NATURAL GAS 192.0

ELSINORE READY

‐ MIX CO INC LAKE ELSINORE AGGREGATE SIZE REDUCTION 13.7

EQUITABLE REAL EST/COMPASS MGMT

LEASING IRVINE BOILER ‐ NATURAL GAS 4.9

FALCON FOAM, A DIV OF ATLAS

ROOFING CORP LOS ANGELES BOILER ‐ NATURAL GAS 293.1

FALCON FOAM, A DIV OF ATLAS

ROOFING CORP LOS ANGELES AFTERBURNER 230.2

FORD AUTO BODY INC SAN FERNANDO SPRAY BOOTH 6.0

FS PRECISION TECH LLC COMPTON ABRASIVE BLASTING CABINET 77.2

FS PRECISION TECH LLC COMPTON ABRASIVE BLASTING CABINET 30.3

FS PRECISION TECH LLC COMPTON ABRASIVE BLASTING CABINET 30.3

FS PRECISION TECH LLC COMPTON ABRASIVE BLASTING CABINET 30.3

GREAT AMERICAN PICTURE FRAME CO LOS ANGELES OPEN SPRAY EQUIPMENT 104.5

GREAT AMERICAN PICTURE FRAME CO LOS ANGELES SPRAY BOOTH 104.5

GREAT AMERICAN PICTURE FRAME CO LOS ANGELES OPEN SPRAY EQUIPMENT 104.5

HOLGA INC VAN NUYS PAINT BURNOFF FURNACE 18.6

HONEYWELL INTERNATIONAL INC TORRANCE JET ENGINE TEST EQUIPMENT 59.0

INTERMETRO INDUSTRIES CORP RANCHO

CUCAMONGA HEAT TREATING FURNACE 65.0

INTERMETRO INDUSTRIES CORP RANCHO

CUCAMONGA NICKEL PLATING TANK 17.0

INTERMETRO INDUSTRIES CORP RANCHO

CUCAMONGA BOILER ‐ NATURAL GAS 87.5

INTERSTATE BRANDS CORP/DICARLO SAN PEDRO BAKERY OVEN 131.2

INTERSTATE BRANDS CORP/DICARLO SAN PEDRO BAKERY OVEN 133.5

### 10 | Page Company Name Location Equipment Description Emission

Credits (lb/year)

INTERSTATE BRANDS CORP/DICARLO SAN PEDRO BAKERY OVEN 93.0

INTERSTATE BRANDS CORP/DICARLO SAN PEDRO BOILER ‐ NATURAL GAS 109.0

KMC WHEEL CO INC RIVERSIDE ALUMINUM FURNACE 2,940.8

KRACO ENTERPRISES INC COMPTON BOILER ‐ OIL 429.5

KRAFT FOODS NORTH AMERICA/NABISCO DIV BUENA PARK BAKERY OVEN 110.1

KRAFT FOODS NORTH AMERICA/NABISCO DIV BUENA PARK BAKERY OVEN 110.1

KRAFT FOODS NORTH AMERICA/NABISCO DIV BUENA PARK BAKERY OVEN 110.1

LITHOGRAPHIX INC LOS ANGELES AFTERBURNER 15.0

LITTLE COMPANY OF MARY HOSPITAL TORRANCE BOILER ‐ NATURAL GAS/OIL 404.7

LONG BEACH AQUARIUM OF THE

PACIFIC LONG BEACH HEATER/FURNACE
‐ NATURAL GAS 301.3

MATTHEWS INTERNATIONAL CORP ROMOLAND FOUNDRY SAND STORAGE WITH

BAGHOUSE 9,460.5

MOUNTAINVIEW GENERATING STATION REDLANDS UTILITY BOILER ‐ NATURAL GAS/OIL 3,365.5

MOUNTAINVIEW GENERATING STATION REDLANDS UTILITY BOILER ‐ NATURAL GAS/OIL 3,365.5

NEVILLE CHEM CO ANAHEIM CHEMICAL STORAGE TANK 268.4

NEVILLE CHEM CO ANAHEIM BOILER ‐ NATURAL GAS 239.7

OLDCASTLE WESTILE, INC. CORONA CEMENT SLURRY SYSTEM 2,111.0

ONE WILSHIRE, CARLYLE ONE WILSHIRE,

LLC LOS ANGELES BOILER ‐ NATURAL GAS 19.1

ONTARIO SANDBLASTING CO ONTARIO ABRASIVE BLASTING CABINET 12.8

ONTARIO SANDBLASTING CO ONTARIO ABRASIVE BLASTING CABINET WITH

BAGHOUSE 12.8

ONTARIO SANDBLASTING CO ONTARIO ABRASIVE BLASTING CABINET WITH

BAGHOUSE 12.8

ORTIZ ENTERPRISES INC VARIOUS

LOCATIONS AGGREGATE CRUSHING SYSTEM 1,233.0

PACIFIC SUN CASUAL FURN DIV OF PAC

OUTDO HEMET POWDER COATING SPRAY BOOTH 30.0

PARADISE TEXTILE CO CHINO HEATER/FURNACE
‐ NATURAL GAS 1,109.5

PLASTI PERSONALITIES INC HARBOR CITY BOILER ‐ NATURAL GAS 9.4

POLYCLAD LAMINATES INC SANTA ANA BOILER ‐ NATURAL GAS 291.6

POLYCLAD LAMINATES INC SANTA ANA BOILER ‐ NATURAL GAS 291.6

PRATT & WHITNEY ROCKETDYNE, INC. CANOGA PARK BOILER ‐ NATURAL GAS 30.5

RELIANT ENERGY ETIWANDA, INC. ETIWANDA TURBINE ENGINE ‐ NATURAL GAS/OIL 1,959.1

RELIANT ENERGY ETIWANDA, INC. ETIWANDA TURBINE ENGINE ‐ NATURAL GAS/OIL 1,959.1

RELIANT ENERGY ETIWANDA, INC. ETIWANDA TURBINE ENGINE ‐ NATURAL GAS/OIL 1,959.1

RELIANT ENERGY ETIWANDA, INC. ETIWANDA TURBINE ENGINE ‐ NATURAL GAS/OIL 1,959.1

### 11 | Page Company Name Location Equipment Description Emission

Credits (lb/year)

RELIANT ENERGY ETIWANDA, INC. ETIWANDA UTILITY BOILER ‐ NATURAL GAS/OIL 33,079.3

RELIANT ENERGY ETIWANDA, INC. ETIWANDA UTILITY BOILER ‐ NATURAL GAS/OIL 33,079.3

SCHEU MANUFACTURING COMPANY RANCHO

CUCAMONGA CURING OVEN 13.0

SHAWCOR PIPE PROTECTION LLC. FONTANA ABRASIVE BLASTING ‐ OPEN 7,677.0

SMURFIT

‐ STONE CONTAINER

ENTERPRISES SANTA FE

SPRINGS BOILER ‐ NATURAL GAS/LPG 237.0

STATEWIDE SANDBLASTING VARIOUS

LOCATIONS ABRASIVE BLASTING ‐ OPEN 2,313.0

SUNLAW COGENERATION PARTNERS I VERNON TURBINE ENGINE ‐ NATURAL GAS 1,295.4

SUNLAW COGENERATION PARTNERS I VERNON TURBINE ENGINE ‐ NATURAL GAS 2,467.4

TABC, INC LONG BEACH CURING OVEN 121.5

TELAIR INTERNATIONAL RANCHO

DOMINGUEZ SPRAY BOOTH 69.5

THE BOEING COMPANY SEAL BEACH EMERGENCY ICE ‐ DIESEL FIRE PUMP 868.0

TREND OFFSET PRINTING SERVICES, INC LOS ALAMITOS AFTERBURNER 42.0

UNIVERSAL DIE CASTING CO VERNON BRASS CRUCIBLE 370.5

US POSTAL SERVICE, SANTA CLARITA

CENTER SANTA CLARITA HEATER/FURNACE
‐ NATURAL GAS 66.0

VALMONT COATINGS, CALWEST GALV LONG BEACH PORTABLE DIESEL ICE 2.7

VOUGHT AIRCRAFT INDUSTRIES HAWTHORNE BOILER ‐ NATURAL GAS 51.0

WEBB

‐ MASSEY CO INC ORANGE SPRAY BOOTH 572.7

WEBB

‐ MASSEY CO INC ORANGE SPRAY BOOTH 572.7

WHITEWATER ROCK & SUPPLY CO WHITE WATER ROCK CRUSHING SYSTEM 1,460.0

WINGS WEST INC SANTA ANA SPRAY BOOTH 498.0

WINGS WEST INC SANTA ANA SPRAY BOOTH 498.0

WINGS WEST INC SANTA ANA SPRAY BOOTH 498.0

WOODARD, LLC. ONTARIO POWDER COATING OVEN 10.2

WOODARD, LLC. ONTARIO DRYING OVEN 5.1

Total 148,582.7

### 12 | Page 

## Table B ‐ SOx Reductions from Sources Which Ceased Operation

Company Name Location Equipment Description Emission

Credits (lb/year)

AAA GLASS CORP LOS ANGELES GLASS MELTING FURNACE 6,295.4

AES ALAMITOS, LLC LONG BEACH TURBINE ENGINE ‐ NATURAL GAS/OIL 108.0

AES ALAMITOS, LLC LONG BEACH TURBINE ENGINE ‐ NATURAL GAS/OIL 108.0

AES ALAMITOS, LLC LONG BEACH TURBINE ENGINE ‐ NATURAL GAS/OIL 108.0

AES ALAMITOS, LLC LONG BEACH TURBINE ENGINE ‐ NATURAL GAS/OIL 108.0

CBS INC LOS ANGELES BOILER ‐ NATURAL GAS/OIL 7.1

CBS INC LOS ANGELES BOILER ‐ NATURAL GAS/OIL 7.1

CENTURY RIM CORP BREA BAKERY OVEN 3.5

COLOR AMERICA TEXTILE PROCESSING

INC LOS ANGELES CARPET PROCESSING SYS WITH ESP 3.3

EL CAMINO COLLEGE TORRANCE BOILER ‐ NATURAL GAS 15.2

GATEWAY SANDBLASTING VARIOUS

LOCATIONS OPEN ABRASIVE BLASTING 455.2

HOLGA INC VAN NUYS PAINT BURNOFF FURNACE 2.0

HONEYWELL INTERNATIONAL INC TORRANCE JET ENGINE TEST EQUIPMENT 4.5

MOUNTAINVIEW GENERATING

STATION REDLANDS UTILITY BOILER ‐ NATURAL GAS/OIL 265.5

MOUNTAINVIEW GENERATING

STATION REDLANDS UTILITY BOILER ‐ NATURAL GAS/OIL 265.5

RELIANT ENERGY ETIWANDA, INC. ETIWANDA TURBINE ENGINE ‐ NATURAL GAS/OIL 169.6

RELIANT ENERGY ETIWANDA, INC. ETIWANDA TURBINE ENGINE ‐ NATURAL GAS/OIL 169.6

RELIANT ENERGY ETIWANDA, INC. ETIWANDA TURBINE ENGINE ‐ NATURAL GAS/OIL 169.6

RELIANT ENERGY ETIWANDA, INC. ETIWANDA TURBINE ENGINE ‐ NATURAL GAS/OIL 169.6

RELIANT ENERGY ETIWANDA, INC. ETIWANDA UTILITY BOILER ‐ NATURAL GAS/OIL 2,611.3

RELIANT ENERGY ETIWANDA, INC. ETIWANDA UTILITY BOILER ‐ NATURAL GAS/OIL 2,611.3

SUNLAW COGENERATION PARTNERS I VERNON TURBINE ENGINE ‐ NATURAL GAS 2,506.4

SUNLAW COGENERATION PARTNERS I VERNON TURBINE ENGINE ‐ NATURAL GAS 2,193.5

THE BOEING COMPANY SEAL BEACH EMERGENCY ICE ‐ DIESEL FIRE PUMP 183.5

Total 18,540.6

### 1 B EFORE THE 

### E NERGY 

### R ESOURCES 

### C ONSERVATION AND 

### D EVELOPMENT 

### C OMMISSION OF THE 

### S TATE OF 

### C ALIFORNIA



### 1516 N INTH 

### S TREET 

### , S ACRAMENTO 

### , CA 95814
1-800-822-6228

– WWW



### . ENERGY



### . CA



### . GOV



### A PPLICATION FOR 

### C ERTIFICATION FOR THE 

### D OCKET 

### N O



### . 07-AFC-3
CPV SENTINEL ENERGY PROJECT

BY THE 

### CPV SENTINEL, L.L.C PROOF OF SERVICE (Revised 2/16/2010)



### APPLICANT

CPV Sentinel, LLC Mark O. Turner, Director Competitive Power Ventures, Inc.
55 2 nd



### Street, Suite 525 San Francisco, CA 94105 mturner@cpv.com

APPLICANT’S CONSULTANT

Dale Shileikis - URS Corporation 221 Main Street, Suite 600 San Francisco, CA 94105-1916 dale_shileikis@urscorp.com

COUNSEL FOR APPLICANT

Michael J. Carroll
LATHAM & WATKINS LLP 650 Town Center Drive, 20th Floor Costa Mesa, CA 92626-1925
michael.carroll@lw.com

INTERESTED AGENCIES

California ISO

e-recipient@caiso.com

Mohsen Nazemi, PE
South Coast AQMD 21865 Copley Drive Diamond Bar, CA 91765-4178 mnazemi@aqmd.gov INTERVENORS

Angela Johnson Meszaros CA Communities Against Toxics 1107 Fair Oaks Avenue, #246 South Pasadena, CA 91030 Angela@CleanAirMatters.net

ENERGY COMMISSION

JAMES D. BOYD Vice Chair and Presiding Member jboyd@energy.state.ca.us

Kenneth Celli, Hearing Officer kcelli@energy.state.ca.us

John Kessler, Project Manager jkessler@energy.state.ca.us

Caryn Holmes, Staff Counsel cholmes@energy.state.ca.us

*Jennifer Jennings 

### Public Adviser publicadviser@energy.state.ca.us

### 2 D ECLARATION OF 

### S ERVICE



### I, Maria Santourdjian , declare that on March 4, 2010 , I served and a filed copy of the attached SCAQMD Addendum
to DOC and POC . The original document, filed with the Docket Unit, is accompanied by a copy of the most recent Proof of Service list, located on the web page for this project at: [ http://www.energy.ca.gov/sitingcases/sentinel/index.html ]

The documents has been sent to both the other parties in th is proceeding (as shown on the Proof of Service list) and
to the Commission’s Docket Uni t, in the following manner:

(C heck all that Apply )

For service to all other parties:

x sent electronically to all email addresses on the Proof of Service list;

by personal delivery;

x by delivering on this date, for mailing with the United States Postal Service with first-class postage thereon fully prepaid, to the name and address of the person served, for mailing that same day in the ordinary course of business; that the envelope was sealed and placed for collection and mailing on that date to those
addresses NOT marked “email preferred.”

AND

For filing with the Energy Commission:

x sending an original paper copy and one electronic copy, mailed and emailed respectively, to the address below (preferred method);

OR

_____depositing in the mail an original and 12 paper copies, as follows:

CALIFORNIA ENERGY COMMISSION
Attn: Docket No. 07-AFC-3 1516 Ninth Street, MS-4 Sacramento, CA 95814-5512

docket@energy.state.ca.us

I declare under penalty of perjury that the foregoing is true and correct, that I am employed in the county where this mailing occurred, and that I am over the age of 18 years and not a party to the proceeding.

Originally Signed by Maria Santourdjian