--- -

c 0 ~I PAN Y

November 25,2008

Mr. Richard Edgehill

Air Quality Engineer

San Joaquin Valley Air Pollution Control District

2700 M Street, Suite 275

Bakersfield, CA 93301

RECEIVED

DEC - 3 2008

Air Division, AIR -

U.S. EPA, REGION 9

Subject: Mt. Poso Cogeneration Company; Request to Reduce Annual Potential to

Emit Limits for NOx, S02 and CO; Add Monthly Record Keeping Requirements

Dear Mr. Edgehill:

Thank you for the assistance and guidance you have provided to Wayne Terry and our permitting

consultant, Dr. Ted Guth. Per direction from EPA's Laura Yannayon, Mt. Poso Cogeneration

Company (MPCC) will:

• Agree to a reduction in the annual potential to emit (PTE) levels ofNOx, S02 and CO

(rolling averages) to new limits based on the average of MPCC's 2004 and 2005 annual

emission levels (see below).

• Agree to enforceable monthly recordkeeping to ensure rolling annual limits are met.

Current PTE's for NOx, S02 and CO are 5l3,336lb/year, 255,281lb/year, and 440,628lb/year

respectively. The annual emitted levels for 2004 and 2005 are shown below:

Year 2004

387,278

125,576

173,298

2005

380,890

134,455

171,326

Average

384,084

130,016

172,312
Mr. Richard Edgehill

Air Quality Engineer

San Joaquin Valley Air Pollution Control District

Mt. Paso Cogeneration Company~ Request to Reduce Annual Potential

to Emit Limits for NOx, 802 and CO; Add Monthly Record Keeping Requirements

November 25,2008

Page 2

To have the desired action - addition of biomass as a fuel- MPCC agrees to decrease its current

PTE's in Ollr Permit To Operate/Title V Permit to levels equivalent to the averages ofNOx and

802 from 2004 and 2005 PLUS 39.5 tons (79,000 lbs) and for CO to the average from 2004 and

2005 PLUS 99.5 tons (199,000 lbs). 111US tIle newly proposed PTE levels are as follo\\Ts;

NOx 384,084 + 79,000 = 463,084 pounds/year

802 130,016 + 79,000 = 209,016 pounds/year

CO 172,312 + 199,000 = 371,312 pounds/year

Please refer any questions you have regarding this request during your re,'iew to Dr. Ted Guth at

619-987-1111. Mt. Paso thanks you in advance for the expeditious review ofthis request, as

well as your continued support and guidance.

Sincerely, ... J. 1

o /J/JI! /

! (r(>!-," I

Rogerf~Allred '

Mt. Poso Cogeneration Company

General Manager

Title V Responsible Official

cc: R. Wayne Terry/V.P. Millennium Energy, LLC

Dr. Ted GuthIPermit Consultant

vCaura Yannayon/Environmental Protection Agency Region IX

enclosures
Mtc Poso Cogeneration Compaf1y

For 12 months starting from January 2004

Device:

fVlass Total

Emission, Hours

U.Ss tons

Component: NOx Mass Rate

Units: Ibfhr

Valid Component

Hours Availability, %

rVionth .....---.....---....-.----......-----~ January 2004 17.28: 744; 744; 100.00%

February 2004 ··········1·7·.28;-··· ·····696f-········69·6·f·······100~OOo/;·

March 2004f·········1·8·.·12r········744;·········739·r-·······99~33°}~

April 2004 ············1·.ssT·· ······433f·········429f········99~08°i;

May 2004 ··········1-8·.·03;-········740[····_····131[········99~59o/~

June 2004 ··········17-.7Sr········720f·········71·2·r········98~89o/;

July 2004 ··········1·8·.·391"········742;·········742·r·······10o~oooi~

August 2004 ··········1·7·..88;-··· ·····143f·_·······i3·.:if········99~1·9°i;

September 2004 ··········i·t~72r········71·Eff·········71·8·f······:foo~oooi~

October 2004 ··_·_·····1·S·.0er---·····69S[·········S96·r······-1·0O~OOo/;

November 2004 ··········1·S·.67T········71·4f·········71-4f·······10o~oooi~

December 2004 _·········1·6~77r········71·8f····_····71·8·f-······10O~OOo/;

12MonthsTotall~~1_93_._64~~~~84_0_8~~~_8_3_8_2~;~_9_9_.6_9_~~ol
Mt. Poso Cogeneration Company

For 12 months starting from January 2004

Device:

Mass Total

Emission, Hours

U.S. tons

Component: 502 Mass Rate

Units: Ib/hr

Valid Component

Hours Availability,

%

Month

January 2004p--o-""5-.. ~87~:~-7~4~4~: --'7~4~4~: -1':"'l!0~)0"".. Oo:"'!O~)o/""co

February 2004 ···········5:721""·······6·96T·······6·S)"6;"'·····100·.·0'0'%

Ma rch 2004 ···········6A01"""" '7"44[ ·7"3·9"f"···· "9~3"'-3'3%

April 2004 ···········C5:51·T..··'····4":33T--·····4·;2·gT·'····gg·.-C)S·%

May 2004 ····,···'··S:1'7T·'·'·'··7·40[·'·····'7"3·S'r'······gg·.'7'3'%

June 2004 ·········'·5:921""······f2·0~········7T2";"·--····98·.-S·9·%

July 2004 ···········5:981""····'··.7"42T·····'·74"2"f"····iocCo'o·%

sep~:~~:; ~gg: :::::::::::~~~~I::::::::t:f:~f:::::::}}~:f:::::~~~~:J:~:~~I October 2004 4.93: 696: 696: 100.00%

November 2004 ··,.······,4:62T·,,.··if4T··,···,··i1~r'·'··'foO".'6"6"%

December 2004 ·,········'S:281·········ifst·······'7"fS·f·····1"oO·.·O'6"%

12 Months rotail 62.79; 8408: 8383; 99.70 %!
fV1tr Poso Coger~eratuo'1 Company

For 12 months starting from January 2004

Device:

Mass Total Valid

Emission, Hours Hours

U.S. tons

component CO Mass Rate

Units: Ib/hr

Component

pt.vailability!

0/0

Month

January 2004..---------------~ J.}.:Q~j ?4.4.L J.~.~.L ~~:.1.~.O(o. February 2004 10.51 : 696: 696: 100.000/0 - ., _ -_ -:- -.:- .. .

tJiarch 2004 7.61: 744~ 738: 99.19%

April 2004 .~ ..... r_··O~89r·······4·3·3f·····_··42·9-r··-·--_·_-- ·-99~O·8·oio·

May 2004 ···_·······7~30r-······~·i40·f········7·3·8·f··_·_········99~7·3·oio·

June 2004 ···········4~82r·········i2(5r·-······7·1·2·f····-···-···-98~8·9·%·

J uty 2004 :::::::::::7.;Q~r:::::::i. 4:?1::::::: :Z;~~:r::::::::: j:Q~L9~:cii.~ August 2004 .. _...._...~:~~1. .._.._..?4.~_t ..._.....~.~.7.~._ .. __ .... ~~:_!_~.'Yc:

September 2004 6.66: 718: 718: 100.00%

October 2004 ····-··-··-7~22r·----···6-96~-·--····6·9·5·r--·---_·-·-·-99~8·6-o/~

November 2004 -_a·-·-·-_·7~50·~··_···--··Y1·4·r-··-···-7a14-r----·----·-10o~o·6·o/;

December 2004 --.. _-a-·--9~53T····_···i1·8;··--·-·-7·1-8-f--···---_· -1·00·.-o·o· io·

12MonfusTo~II~~8_6_.6_5~~~_8_4_0~8~~_8_3_7_5~~~~_9_9_.6_1_o_~1
Mtc Poso Cogertierattior~ Company

For 12 months starting from January 2005

Device:

Mass Total

Emission, Hours

U.S. tons

COiTlponent: HOx Mass Rate

lJnits' Ih/hr

Valid Component

Hours Availability, %

f\1lonth ......-~~.....--~ ......-~~--~~~ January 2005 16.92: 724: 724; 100.00%

February 2005 ··········14·.-86;-········651·r·········647·r········99 ~396i~

March 2005 ··········1·5·.·36:-········744:·········743·:········9 9~876i~

April 2005 ··.-.. ····1-1-.·s31···.·····71·9r·.·······71·9·r.·-·.· ·iOO~006i;

May 2005 ············9-.-34r········43ir·········43S·r········99 ~54°i~

June 2005 ··········17·.·06:·········120:·········:j20·:·······1·oo~oooi;

July 2005 ··········1·6-.-621"·······-744r·········739·r········99 ~33°i;

August 2005 ··········1·6·.-5·1r········709~·········7b-9·f···-···1·00~oooi;

September 2005 ··········1·s·.·i·1r········720·f·········72·0·r······10o~oooi;

October 2005 ··········1·1·.23:-········745:·········~l4·cf~········99~336i; _ ..•- ;. .••.. _...•-- r..-......•••••.. a. •••

November 2005 15.63; 675: 675; 100.00°10

December 2005 ···_······1·7·.281"········744[·····_···744·;··_····100 ~oooi~

12MonthsTo~II~~1_9_0._4_5~~~83_3_2~;~_8_3_1_5~: ~_9_9_.8_0_o~~1
r\!ttc P'OSO Coger~eratio,n Company

For 12 months starting from January 2005

Device:

Mass Total

Emission, Hours

U.S~ tons

Component: 802 Mass Rate

Units: tblhr

Valid Component

Hours Availabilit}',

o~

Month...--.-...................-~.....-~.......--------~ January 2005 5.82; 724; 724; 100,000/0

February 2005 ············S·.3Sr········S51·r-········647-r········g9~39°i~

March 2005 ············S·.43r··-·····744[·········743-;······ ··99:87o/~

April 2005 ··········~·6·.25T··_·····71·9f·_·······7f9·r·······ioO~OOo/~

May 2005 ··········_·3·:3·1r··-·····437~·········4·3·5·f·······99~54°i~

June 2005 ············6·.071"·········720[·········720·r-······1·OO~OOo/;

July 2005 ·······_····6·.·071"········/44f·········740·[······ ··99~46o/~

August 2005 ············S·.7Sr········Y09[····· ····7-6-9-f·······100~006i~

September 2005 ············5·.·941"········720[--·······720·r··-····1-OO~OOo/~

October 2005 ············S·.·OSr········74S[·········7·4"O·r········99~33o/~

November 2005 ············5~37r········675f·········6··y3·f········99~70oi~

December 2005 ············S·.·s·1T········744f····· ·····i44-f·······100~OOo;~·

12MonfusTo~II~~_67_._23~;~~83_3_2~;~_8_3_1_4~~~_9_9_.7_8_~_~l
r~t~ P'OSO Coget1eration Company

For 12 months starting from January 2005

Device:

Mass Total

Emission, Hours

U.S. tons

Component: CO Mass Rate

LJnits: fb/hr

Valid Component

Hours Availability,

0/0

Month

January 2005.......---.....--- 9.17; .............. 724;----..--- 724:......---~ 100.00%'

February 2005 ············6·..12;-········651·r·········6·3·9·r······· ·98~1·66i~

March 2005 ············8·.·80;-········744[·········143·r········99~87°i~

April 2005 ··········1·0·..0·1;-··· ·····71·9f····_····if9·f··_··_·100~OOo/~

May 2005 ············5·.·19r········437~·········435f········99~5.4°i~

June 2005 ············5·.·94r········720;··_···_··~l1·9·f········99~86o/;

July 2005 ············1·.·1Sr········744[·········13·3f········g8~52oi~

August 2005 ············1·.42r········709f·········io·Eff········g9~86o/~

September 2005 ··········_·5·.62:· ········720:·········72·6·:·······100~oooi~ *' _ _ - _ -:,_ - - _ - - _ j. _:".10( "" _ _ .

October 2005 6.79: 745: 741: 99.460/0

November 2005 ···········6·.·1S;-········67S-r·········6·.:i2·r········99~56·6i~

December 2005 ············7·.2Sr···-····744f·········743·r········99~87oi~

12MonthsTo~II~·~~8_5._6_6~;~_8_33_2~;~_8_2_9_6~~~_9_9_.5_7_o~~1