Estate Richmond is a power plant in St. Croix, USVI. The facility has four oil-fired gas turbines subject to PSD, NSPS, USVI SIP, and Title V. The facility must continually inject water into the turbines to control NOx emissions. For the past five years, Respondent has failed to continuously inject water, resulting in numerous hours of NOx excess emissions. To resolve these violations, this administrative order requires Respondent to hire a third party to evaluate their water injection system and determine the causes of any faults. After the third party audit, Respondent must implement a capital improvement plan to rectify the problems with the water injection system.