April 1, 2014

IMPERIAL COUNTY AIR POLLUTION CONTROL DISTRICT

Authority to Construct and Permit to Operate Review

Minor Permit Modification

Permit: 2002I

- 3

Source Name: Ormesa, LLC

Source Type: Geothermal Power Plant

Application for: Removal of Emergency Generators and Modification of Emergency Fire Pump

Mailing Address: Ormesa, LLC

P.O. Box 86
Holtville, CA 92250

Location: GEM 2&3 Electrical Generation Facility 3300 East Evan Hewes Highway Holtville, CA 92250

Responsible Agent/ Facility Contact: Michael Moore, Plant Manager Phone: (760) 356

- 3020 Cell: (760) 457

- 8531

Permit Reviewer: Thomas Brinkerhoff, APC Engineer

Introduction

Ormesa, LLC submitted a permit application on March 19, 2014 to the Air District for the

modification of Air District Permit No. 2002I

- 2. This permit, held by Ormesa, LLC, is for the emission sources within the GEM 2&3 electrical generation/geothermal pla nt, located at 3300 East Evan Hewes Highway in Holtville, CA. The permittee is seeking to remove two (2) existing diesel emergency generators from the permit, since the facility will no longer have the need for backup pow er from these units. Also, Ormesa is requesting to increase the annual limit for the maintenance and testing hours of the onsite emergency fire pump. This review will result in the issuance of a new Authority to

1Construct (ATC) and Permit to Operate (PTO) for Ormesa, which will be number ed

Permit 2002I

- 3.

Project Description

The proposed project involves the removal of two existing diesel

- fueled emergency generator sets, as well as the request to increase the hours of maintenance and testing for the fire pump. The two listed generators which were previously utilized at GEM 2&3 are identical units, each driven by a Cummins Model NTTA85562 diesel engine with a rating of 535 bhp at 1,800 rpm. The generators will be completely disconnected from switchgear, as well as removing the ir batteries and fuel tanks which will render the units inoperable. As stated in the application, Ormesa will notify the Air District once the permanent disconnection is made and in the event that the generators are completed

removed from GEM 2&3.

As p reviously mentioned, Ormesa is also requesting to increase the emergency fire pump’s allotted hours per year for maintenance and testing (M&T) purposes to thirty (30) hours. The fire pump, which is driven by a Caterpillar Model 3306BDI diesel engine. The engine has a rating of 237 bhp at 1,800 rpm. The current annual limit for the unit stands at 20 hours per year, which was originally required per the California Air

Resources Board ’s (ARB) regulation for diesel engines known as the Airborne Toxic

Control Measure for Stationary Compression

- Ignition (CI) Engines (ATCM). In

- use diesel engines, with a diesel PM standard greater than 0.40 g/bhp

- hr, are required to limit M&T operations to 20 hours per year. However, in later version s of the ATCM, the

allowanc e was made for emergency fire pumps to operate more than 20 hours per year for M&T in order to satisfy the testing requirements of the National Fire Protection Association (NFPA) 25 "Standard for the Inspection, Testing, and Maintenance of

Water

- Based Fire Protection Systems," 2002 edition. Therefore, the Air District will accept the new proposed M&T limit of 30 hours per year for the emergency fire pump and ensure that all applicable permit conditions are modified accordingly.

Air Emissions

Emergenc y Combustion Equipment

Emissions will continue to be produced by the existing Caterpillar emergency fire pump, however the potential to emit (PTE) from this source category will decrease, due to the

removal of the two diesel

- fueled emergency generators. Although the permittee has requested to increase the hours allotted for maintenance and testing of the fire pump from 20 to 30 hours in order to comply with NFPA 25 standard, the unit’s PTE will continue to be based on a total operation of 500 hours per year. The 500 hours per year operation rate is a standardized schedule which EPA has for emergency combustion equipment at major and synthetic minor sources. Air emissions were

2calculated for the fire pump using emission factors from U.S. EPA AP

- 42, Ch. 3.3 and the engine specification sheet provided by the permittee :

Caterpillar Fire Pump

Unit N O x CO SOx PM10 VOC Benzene

lb/hr 5.05 2.69 0.59 0.26 0.41 0.0019 lb/yr 2526 1347 2 97 130 205 0.9 5 ton/yr 1. 26 0. 67 0.1 5 0. 07 0.1 0 0.0004

New Facility PTE

With the proposed removal of the two diesel emergency generators, the PTE for the GEM 2&3 geothermal facility will decrease. Below is the new PTE, post

- modification, for GEM 2&3. The table includes both the daily and annual PTE for the facility , with th e daily PTE based on normal operations (with the RTO/Scrubber system online) and one hour of testing of the emergency fire pump . For a detailed analysis of the other emission source categories of GEM 2&3, please refer to the Synthetic Minor Source

review that was carried out in permit review 2002I

- 3 (Note: 2002I

- 3 incorrectly listed VOC emissions as 38.48 tons/yr, actually was 28.48 tons/yr)

.

HAP and Regulated Air Pollutant Yearly Emissions

Pollutant *Daily (lbs/day) Yearly (Tons/Yr)

Benzene 49.3 9.94

VOC(non

- benzene) * 148.08 28.29

Hydrogen Sulfide 117.1 22.0

PM10 ** 173.41 31.68

Sulfur Dioxide 3.65 0.71

Nitrogen Oxides 18.8 3.77

*Includes Isopentane Emissions from OEC Units (142.9 lbs/day; 26.08 tons/yr) **Includes PM10 Emissions from Cooling Towers (116.5 lbs/day; 29.42 tons/yr)

Benzene and hydrogen sulfide emissions are based on 8

, 400 hours per year of RTO operation and 360 hours of maintenance per year. PM10, sulfur dioxide, nitrogen

oxides emissions are based on 8

, 760 hours of RTO operati on.

Applicable Rules Compliance Status

108 Inspections In Compliance

109 Source Sampling In Compliance

3111 Equipment Breakdown In Compliance

201a Authority to Construct In Compliance

201b Permit to Operate In Compliance

204 Applications In Compliance

206 Processing of Applications In Compliance

207 New and Modified Stationary In Compliance

Sources

400.3 Internal Combustion Engines In Compliance

401 Opacity of Emissions In Compliance

403 General Limi tations on the In Compliance Discharge of Air Contaminants

405 Sulfur Compounds Emission Standards In Compliance
Standards, Limitations and Prohibitions

407 Nuisance Rule In Compliance

900 Procedures for Issuing Permits In Compliance for Sources Subject to Title V

of the Federal Clean Air Act

Amendments of 1990

1002 California Airborne Toxic Control In Compliance

CONDIT IONS FOR AUTHORITY TO CONSTRUCT

AND PERMIT TO OPERATE No. 2002I

- 4 Synthetic Minor Source

A. Gen eral Conditions

1. The facility shall be constructed and operated in complian ce with the project description and operating parameters of the following applications, except as may be modified by more stringent requirements of law or these conditions: (FR# 31750), dated March 23 rd , 1988; (FR#240364), dated January 12 th , 1997; (FR#522563

- 522565), dated January 23 rd , 2006; (FR#527237), dated October

10 th , 2006; (FR# 549046) dated August 22, 2007; (FR# 2011635910) dated February 9 th , 2011; (FR#2011636) dated Ap ril 21 st 2011; (FR#2012639920)
dated March 19, 2014.

2. Operation of all equipment shall be in compliance with applicable APCD Rules and Regulations.

3. This permit does not authorize the emissions of air contaminants in excess of those allowed by the U

. S

. EPA (title 40 of the Code of Federal Regulation), the State of California Division 26, Part 4, Chapter 3 of the Health and Safety Code, or the APCD (Rules and Regulations).

44. This permit cannot be considered permission to violate applicable existing laws,

reg ulations, rules or statues of other governmental agencies.

5. No air contaminant shall be released into the atmosphere which causes a public nuisance. (Rule 407).

6. The Permittee shall not release or discharge into the atmosphere from any single

source of em ission, any air contaminant as dark or darker as designated as No. 1 on the Ringlemann Chart (20% opacity) for a period or periods aggregating more than three (3) minutes in any hour.

7. The Permittee shall comply with the general requirements for control of fine particulate matter (PM10); construction and earthmoving activities; bulk materials; carry

- out and track

- out; open areas; paved and unpaved roads; and conservation management practices.

8. The emissions of any regulated pollutant, as defined pursuant to 40CFR70.2, shall be less than the major source threshold values of Rule 900

. B.20, of the Imperial County APCD, for the facility.

9. The emission of any single hazardous air pollutant, as defined pursuant to Section 112(b) of the 1990 Clean Air Act and Rule 900

. B.20, shall be less than 10 tons per year, for the facility. Total combined emissions of all hazardous air pollutants, as defined pursuant to Section 112(b) of the 1990 Clean Air Act and

Rule 900

. B.20, shall be less than 25 tons per year, for the facility.

10. Total facility wide benzene emissions shall not exceed 9.93 tons per year.

11. Any unpaved roads, paved road s , and open areas subject to be disturbed by vehicles traffic shall comply with the require ments for fugitive dust control (Rule 805).

12. The Permittee shall prevent or cleanup any car ry

- out or track

- out (Rule 803).

13. All equipment shall be maintained in good operating conditions and shall be operated in a manner to minimize emissions of air contaminants into the atmosphere.

B. Isopenta ne Emissions

1. Under normal operating conditions: maintenance, Vapor Recovery Unit (VRU) purging and fugitive daily emissions, the total isopentane emissions shall not exceed a quarterly average of 142.9 lbs/day from the entire facility, as determined by i nventory and mass balance procedures.

a. All noncondensable ga s (NCG) purging of any OEC Unit shall be

5conducted through the facility’s Vapor Recovery Unit (VRU). The purging of gases through the VRU to the atmosphere shall be conducted only after the sepa ration cycle of NCG and isopentane gases is completed. Purging of NCG to the atmosphere shall be conducted in a manner to minimize entrainment of isopentane gases with the NCG.

b. Isopentane emissions occurring during normal purging events shall be

considere d part of the daily average isopentane emissions for the total isopentane loss for the reporting quarter.

2. Isopentane emissions occurring during normal repair and maintenance shall not be considered a breakdown and shall be considered part of the daily ave rage isopentane emissions for the total isopentane loss for the reporting quarter.

3. Prior to conducting maintenance, repairs or modifications on the portions of the OEC isopentane system that cannot be independently isolated, and the OEC isopentane system has to be open and exposed to air, the Permittee shall control the isopentane emissions by doing all the following:

a. Empty the OEC unit of Isopentane by pumping it to the Maintenance

tanks.

b. Purge Isopentane Vapors from the OEC unit using nitrogen gas and condensing the Vapors through the portable VRU system equipped with a chiller. The liquefied Isopentane collected in the portable VRU tank shall be pumped to the storage tank.

c. The Portable VRU shall achieve a minimum 95% Isopentane vapor

recovery e fficiency during the purging of the emptied OEC before

maintenance.

4. The Permittee shall install and maintain, in good working order, an in

- line flow meter (cfm) at the inlet of the VRU . The flow meter shall be equipped with a

totalizer.

5. Venting isopentane from an OEC Unit to the atmosphere for the sole purpose of evacuation is prohibited.

6. Any breakdown, malfunction, or upset occurrence which constitutes a breakdown condition resulting in the emission of any air pollutant to the atmosph ere, sh all be reported to the APCD as soon as reasonably possible but no later than two (2) hours after its detection, and should identify the time, specific location, equipment
involved, and to the extent known the cause of the occurrence, and immediate

remedial measures shall be undertaken to correct the problem and prevent further emissions into the atmosphere. The completion of corrective measures or the shutdown of emitting equipment is required within twenty four (24) hours of

occurrence of a breakdown condi tion.

67. If the breakdown condition will require more than twenty four (24) hours to correct, the Permittee, in lieu of shutdown, shall submit a variance application to the Air Pollution Control Officer (APCO) requesting to commence the varia nce procedure se t forth in the APCD Hearing Board Procedures.

8. Within ten (10) days after a breakdown occurrence has been corrected; the owner or operator shall submit a written report to the APCO which includes:

a. A statement that the occurrence has been corrected, along with the date of correction and proof of compliance.

b. A specific statement of the reason(s) or cause(s) of the occurrence so that

the APCO can determine whether the occurrence was a breakdown

condition.

c. A description of the corrective measures u ndertaken and/or to be

undertaken to avoid such an occurrence in the future.

d. An estimate of the emissions caused by the occurrence.

e. Pictures of the equipment or controls which failed, if available.

9. Failure to comply, or comply in a timely manner, wi th the reporting requirements

shall constitute cause for enforcement action.

10. Isopentane breakdown emissions and losses shall be deducted from the total isopentane loss for the reporting quarter before calculating the daily average

emissions.

C. Regenerativ e Thermal Oxidizer/Scrubber Unit

1. T he Permittee shall install, operate, and maintain the RTO/Scrubber system during all times the production wells are in use , except as provided below:

a. Maintenance activities (operation of wells without the RTO/Scrubber system) shall be restricted to a maximum of 360 hours per year.

b. The ICAPCD shall be notified at least 24 hours in advanced via fax or telephone before any scheduled maintenance is performed on the

RTO/Scrubber system

.

2. For normal RTO/Scrubber operations, the following emission limits from the

controlled NCG scrubber stack shall not be exceeded:

a. Benzene emissions 5.2 pounds per day.

b. Hydrogen sulfide emissions 1.66 pounds per day.

c. Sulfur dioxide emissions 3.06 pounds per day.

d. Nitrogen oxide emissions 13.75 pounds per day.

e. PM 10 emissions 12.0 pounds per day.

f. VOC (not including Benzene) emissions 4.77 pounds per day

73. The following emission limits from the condensate line (condenser hot

well/cooling tower) shall not be exceeded:

a. Benzene emissions 44.10 pounds per day.

b. Hydrogen sulfide emissions 115.44 lb/day.

4. During periods of operation without the abatement system (RTO/Scrubber) being

online due to repairs and regular maintenance

, including rock muffler venting

events , which shall not exceed 15 days per year, emissions from the uncontrolled

NCG stack and co ndensate line shall not exceed the following :

a. Benzene emissions 174.00 pounds per day.

b. Hydrogen sulfide emissions 198.48 lb/day.

c. VOC (not inc luding Benzene) emissions 170.52 pounds per day.

5. Except during maintenance activities, the RTO combustion chamber temperatures shall maintain an operating temperature of at least 1,500° Fahrenheit. Propane shall be used during cold start

- ups to pre

- heat the RTO until the target temperature is reached.

6. The operating temperature of the RTO Combustion Chamber shall be monitored continuously; the data shall be logged and shall be available to the APCD inspectors to demonstrate compliance.

7. The Permittee shal l continuously monitor noncondensable gas flow into the RTO, RTO combustion bed and chamber temperature, and RTO exhaust temperature.

8. A log shall be maintained on the premises showing weekly hours of operation and routine repairs of the RTO/Scrubber system. This log shall be made

available to the APCD for inspection upon request.

9. The operating scrubber water re

- circulation rate and scru b water pH shall be

continuous ly monitored and maintained in a daily log. The records shall be made

available to the APCD for inspection upon request.

.

10. The RTO/Scrubber system shall count with an electronic log in its PLC (Programmable Logic Controller) or DCS (Direct Control System) and shall be available for the APCD Inspectors showing hours of operation, shutdown hours for routine repairs and combustion chamber operating temperature.

D. Monitoring and Testing

1. Th e APCD may at any time monitor emissions from any source within the facility

2. The APCD may at any time, but no more than twice per year, authorize third

party air emissions testing and/or an inventory of the air emission s of the facility.

8The cost of the air emissions testing shall b e borne by the Permittee. The APCD shall give advance notification to the Permittee prior to any air emissions testing

or a ir emissions inventory required.

3. The Permittee shall conduct a source test of the facility every six months

pe rforming the following analyses :

a. Of turbine condenser condensate for: hydrogen sulfide, benzene, ammonia arsenic, beryllium, cadmium, chromium, copper, lead, manganese, mercury, nickel, radon, selenium, and zinc.

b. Of cooling tower blow

- down for: hydrogen sulfide, benzene, ammonia, arsenic, beryllium, cadmium, chromium, copper, lead, manganese, mercury, nickel, radon, selenium, and zinc.

c. Of the non

- condensable gas line for before the RTO/Scrubber system (uncontrolled) for hydrogen sulfide, ammonia, benzene, arsenic, merc ury, radon, toluene, and xylene.

d. Of the RTO/Scrubber Stack gas exhaust for: hydrogen sulfide, benzene,
ammonia, SOx, NOx, and PM 10.

e. Testing protocol shall be submitted to the District for approval prior to source test being conducted.

f. All source test analysis shall use U.S. EPA/ARB approved methods and/or ICAPCD approved equivalent.

g. During the source test the steam and the non

- condensable gases mass flow rate shall be determined and the results submitted into the report in pounds per hour, per day and tons per semester for every pollutant. All analysis results shall be available at the facility for inspection.

h. The source test report shall include the results in pounds per hour, per day and tons per Semester of hydrogen sulfide, benzene and am monia before and after BACT (RTO/Scrubber). SOx, NOx and PM 10 emissions after

BACT shall be included as well

. i. All official source tests shall be witnessed by an ICAPCD official. This condition may be waived upon ICAPCD written authorization.

4. The Permi ttee shall monitor through the sight glass the volume of the Isopentane in the working tank and storage tank on a weekly basis and every time in which the following occurs:

a. maintenance is conducted and the OEC system has to be emptied and

vapors recup erated through the VRU portable system.

b. a new load of Isopentane is added to the system.

5. The Permittee shall calculate all isopentane and reactive organic compounds daily emissions of pounds per day based on a quarterly average.

6. Each performance test protocol shall be submitted to the APCO for ap proval 30 days prior to testing and should include the following:

9a. Emission unit identification and description

b. Sampling and analysis procedures

c. Test schedule

7. Performanc e tests for criteria p ollutants, H 2 S and benzene shall be conducted in

accordance w ith approved CARB or US EPA stationary sou rce test methods (or

alternate methods with prior written approval by the ICAPCD ):

a. US EPA Method s 1

- 4 Sampling , Volumetric flow, Mw and %moisture

b. CARB Method 100 NOx, VOC, CO, CO 2 and O 2

c. SCAQMD Method 307 H 2 S

d. US EPA Method 6 SO 2

e. CARB Method 410A Benzene

8. The Permittee shall conduct a Source Test of the portable VRU. The Source Test shall be conducted three months after the commissioning of the VRU; and every year thereafter, or sooner if requested by the APCO. The source tes ting

shall use EPA methods or APCD approved equivalent. The source testing shall be witnessed by APCD staff. All analytical results shall be available at the facility for inspect ion. Source test shall be conducted for the following:

a. Of the non

- condensable gases vented for: VOC’s, N 2 , O 2 , CO 2

.

9. The Permittee shall inspect, on a yearly basis, during the turnaround or plant shut down the Cooling Tower Drift Eliminators to ensure tha t every Cooling Tower Cell have the complete set of panels of Drift Eliminators and replace those that are damaged.

10. The Permittee shall monitor, on a monthly basis, the cooling tower water chemistry including Total Dissolved Solids.

11. The Permitte e shall provide records, collect samples or gather other required

information to demonstrate compliance with APCD Rules and Regulation s as requested by the APCO.

10. All required source testing, sampling, analysis and reporting cost s shall be borne by the Permittee.

11. Upon proper notification, the APCD or its designee shall have the right to enter, inspect and take samples within the permitted facility.

E. Reporting

1. The Permittee shall submit to the ICAPCD a report containing source test results conducted pursuant to the requirements of Condition D.3 (NCG, condensate,

10cooling tower water and RTO/Scrubber) above, expressed in pounds per hour. The partial report shall b e submitted to the APCD within 60 days of the preceding month and the annual report by the end of February of each operating year.

2. The Permittee shall submit to the ICAPCD a report containing the portable VRU source testing results pursuant to Conditio n D.8

. The report shall be submitted within 60 days of the test.

a. Analysis conducted pursuant to the requirements of Condition D. 8 above.

b. Based on the analyses conducted in Condition D. 8, the emissions derived from the analyses, an emission inventory for the facility showing compliance with permit limits.

3. Permittee shall submit to the ICAPCD a quarterly report 30 day s after the end of the quarter which consists of the following:

a. The Permittee shall submit an Isopentane inventory and mass balance

, including the changes in volume

, for the working Isopentane tank and the used Isopentane tank. The Permittee shall calculate the Isopentane expended per day, week, month and year pursuant to the requirements of

Conditions D.4 and D.5

. b. The total amount of isopentane renewals brought to the facility during the reporting quarter and the previous quarters of that calendar year. The facility shall include the isopentane supplier’s name and address.

c. The total amount of isopentane present at the facility befo re renewals.

d. The number of isopentane withdrawals from OEC units for maintenance.

e. The number of rotating seals replaced or installed

, or any other OEC seal or gasket failure

, that occurred during the reporting quarter.

f. The number of pressure relief rupture discs removed and replaced during the reporting quarter.

g. The total flow, in cubic feet, through the VRU during the reporting quarter.

h. The Permittee shall report to the APCD by telephone all non

- normal (upset) releases of isopentane or geothermal gases to the atmosphere

within 24 hours of the release occurrence.

4. The Permittee shall submit to the ICAPCD an annual report by the end of February of each operating year. This report shall include the following:

a. Total tons of H 2 S, Benzene, SOx, NOx and PM10 emissions for the reporting year.

b. Types and quantities of cooling water additives.

c. The status of all active wells associated with this facility used for production or injection during the report ing year. For each well include the total days of rig activity (wo rk over, clean out or drilling) and the total hours of venting to the atmosphere (from test units).

d

. Gross and Net electrical megawat t

- hours produced for the reporting year.

11e

. The total volume and pounds of Isopentane expended (purchased) during the year.

f. The number of times that the OEC system was opened for repairs,

maintenance or modifications.

g

. The isopentane emissions report by month, by quarter and by year.

5. Within 10 days after a breakdown occurrence has been corre cted, the Permittee shall submit a written report to the APCO which includes the following :

a. A statement that the occurrence has been corrected.

b. The reason(s) or cause(s) of the occurrence.

c. A description of the corrective measures undertaken.

d. The type of emission and estimated quantity of the emissions caused by

the occurrence.

F. Emergency Fire Pump

1. The listed diesel emergency fire pump shall be restricted to operate a total of thirty (3 0) hours per year for maintenance and testing purposes.

2. The listed emergency fire pump shall not discharge into the atmosphere any visible air contaminant other than uncombined water vapor, for a period or periods aggregating more than three minutes in any one hour, which is 20% opacity or greater.

3. The listed emergency fire pump shall be equipped with a non

- resettable hour meter which must be kept in proper working condition at all times.

4. The diesel engine of the listed emergency fire pump shall be fueled only with one

or a combinati on of the following:

a. CARB diesel fuel; or

b. an alternative diesel fuel, such as biodiesel or a biodiesel blend that
does meet the definition of CARB diesel fuel; or

c. any alternative diesel fuel that meets the requirements of the

Verification Proce dure; or

d. CARB diesel fuel used with fuel additives that meets the requirements of the Verification Procedure.

5. The permittee shall maintain an engine operating daily log onsite for every month or any part of a month that the listed emergency fire pump operated. The Permittee shall maintain all required records required for a minimum of two (2) calendar years and make them available to the District upon request. The log shall include the following for each emergency unit:

12a. Engine manufacturer name, model number, brake horsepower output rating, and type of fuel combusted;

b. A manual of recommended maintenance as provided by the engine manufacturer or other maintenance procedure as approved in writing by
the APCO;

c. Record of rout ine engine maintenance, including date(s) and type of maintenance performed;

d. A specific emission inspection procedure, with an inspection schedule, to ensure that the engine is operated in continual compliance with Air District Rule 400.3. Inspections shall be conducted every quarter or after every 2,000 hours of engine operation. In no event shall the frequency of inspections be less than once per year.

e. Total daily recorded hours of operation for maintenance and testing

purposes.
f. Total daily rec orded hours of operation for emergency events.

6. The Permittee shall submit to the APCD an annual report by the end of February of each operating year which contains the following information for the listed emergency fire pump:

a. Monthly fuel consumpti on
b. Monthly hours of operation for maintenance and testing purposes.

c. Monthly hours of operation for emergency events.

Equipment List

1. Geothermal Production and Injection Wells

Following is the list of production and injection wells associated with GEM Resources, LLC, GEM 2&3 Geothermal Power Plant facility:

No. of Wells PRODUCTION

WELLS INJECTION WELLS

1 P/W 88

- 7 I/W 83

- 7

2 P/W 24

- 8 I/W 63

- 7

3 P/W 54

- 7 I/W 27

- 7

4 P/W 41

- 7 I/W 33

- 7

5 P/W 71

- 7 I/W 53

- 17

6 P/W 82RD

- 7 I/W 61

- 7

7 P/W 61

- 12 I/W 81

- 7

8 P/W 54

- 12 I/W 8

- 1

139 P/W 81

- 12 I/W 27

- 8

10 P/W 21

- 7 I/W 84

- 7

11 P/W 25

- 7 I/W 32

- 17

12 P/W 74

- 12 I/W 56RD

- 7

13 P/W 65

- 7 I/W 53

- 12

14 P/W 61

- 18 I/W 13

- 7

15 P/W 26

- 7 I/W 44

- 7

16 P/W 72

- 13 I/W 44A

- 7

17 I/W 44B

- 7

18 I/W 42

- 18

19 I/W 85

- 12

20 I/W 28

- 7

21 I/W 16

- 7

22 I/W 78

- 12

23 I/W 25A

- 7

24 I/W 49

- 7

2. Emergency Fire Pump

One (1) Emergency Fire Pump, Caterpillar Diesel Engine, Model 3306BDI, with a rating of 231 hp at 1,800 rpm.

3. Gems 2&3 Dual Flash Geothermal Power Generating Units (47MW).

4. Two Thermodynamic Cycle

- ORMAT ENERGY CONVERTER (OEC) (10 MW).

a. Turbo generator skid

b. Lubricating and seal oil system skid

c. Heat exchangers Water

- cooled condenser

d. Organic motive fluid and geothermal brine pipin g system.

e. Control and power system

f. Two Turbines: two stages, rated power at 1,800 rpm of 5,000 kW.

g. Synchronous type Generator, output rating 10,000 kV.

h. OEC Motive Fluid: Isopentane, charge 369,446.3 lbs

i. Isopentane storage tank j. Isopentane working tank

145. One (1) Vapor Recovery Unit (VRU), designated as VRU#2:

The VRU#2 is truck mounted, equipped with a 300 gallon heat exchanger, a 10

- ton R22 refrigeration units, a 200 gallon chilled water tank, and other ancillary equipment (VRU # 2 serves the O rmesa Geothermal II power plant; Ormesa Geothermal IH power plant ; and the GEM 2&3 power plant).

6. Regenerative Thermal Oxidizer

a. Adwest Technologies RETOX dual

- chamber RTO unit.

b Wet scrubber Envitech Packed Bed caustic scrubber.

7. Three (3) Cooling Towers

a For the flash plant two (2) Marley cooling towers counter flow; capacity of 41,800 gal/min re

- circulation rate each.

b For the Ormat System one (1) Marley cooling tower counter flow; capacity of 34, 700 gal/min re

- circulation rate.

Recommendations

Staff has carried out a full review of the permit application and has determined that the proposed project is a minor modification to GEM 2&3, resulting in no increase in the Potential to Emit for the geothermal power plant facility. Ther efore, Staff recommends

that an Authority to Construct (ATC) and Permit to Operate (PTO) be issued to Ormesa,

LLC for the equipment and operations described herein. Please prepare and issue to the client the permit conditions and equipment list of this pe rmit review along with the

ATC and PTO.

Permit Fees

Rule 302, Schedule 6

– Geothermal Schedule:

Geothermal Resource Production/Utilization Facility

Capacity: 37.0 MW

– GEM 2&3 Power Plant.

$ 296.00 per MW (for each subsequent year ) x 37.0 MW = $ 10,952.00

Ormat Energy Converters (OECs)

Capacity: 10.0 MW

$ 296.00 per MW (for each subsequent year ) x 10.0 MW = $ 2,960.00

15Rule 302, Schedule 9

– Miscellaneous Schedule:

RTO and Scrubber System

2014 Fee: ($ 177.50 x 1 RTO/scrubber system ) = $ 177.50

Standby Combustion Equipment

2014 Fee: ($177.50 x 1 emergency unit ) = $ 177.50

Evacuation Skid System

- Vapor Recovery Unit (VRU)

2014 Fee: ($177.50 x 1 VRU ) = $ 177.50

Total Operating Fee: ($ 10,952.00 + $2

, 960.00 + $ 177.50 + $ 177.50 + $ 177.50 ) = $ 14, 444.50

2014 Operating Fee = $ 14, 444.50 (Previously Paid)

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