HomeMy WebLinkAbout20132864.tiffSTATE OF COLORADO
John W. Hickenlooper, Governor
Larry Wolk, MD, MSPH
Executive Director and Chief Medical Officer
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
, Located in Glendale, Colorado
www.colorado.gov/cdphe
Weld County Clerk & Recorder
1402 N 17th Ave
Greeley, CO 80631
October 2, 2013
Dear Sir or Madam:
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Colorado Department
of Public Health
and Environment
On October 5, 2013, the Air Pollution Control Division will publish a public notice for Spindle Hill Energy,
LLC — Spindle Hill Energy Center, in the The Greeley Tribune. A copy of this public notice and the public
comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public
copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet
must be available for public inspection for a period of thirty (30) days from the date the public notice is
published. Please send any comment regarding this public notice to the address below.
Colorado Dept. of Public Health & Environment
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
R (eou
j13
CC R L Rua
I ON
2013-2864
NOTICE OF A PROPOSED TITLE V OPERATING
PERMIT WARRANTING PUBLIC COMMENT
Website Title: Spindle Hill Energy, LLC — Spindle Hill Energy Center — Weld County
NOTICE is hereby given that an Operating Permit application has been submitted to the Colorado Air Pollution Control
Division, 4300 Cherry Creek Drive South, Denver, Colorado 80246-1530, for the following source of air pollution:
Applicant: Spindle Hill Energy, LLC
6335 County Road 19
Fort Lupton, CO 80621
Facility: Spindle Hill Energy Center
6335 County Road 19
Fort Lupton, CO 80621
Spindle Hill Energy, LLC has applied for an Operating Permit for the Spindle Hill Energy Center in Weld County,
CO. This facility is a peaking utility electric power generation facility. A copy of the application, including
supplemental information, the Division's analysis, and a draft of Operating Permit 08OPWE311 have been filed with
the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's
website at www.colorado.gov/cdphe/AirPublicNotices. Based on the information submitted by the applicant, the Division
has prepared the draft operating permit for approval. Any interested person may contact Joshua Jones of the Division
at 303-692-3207 to obtain additional information. Any interested person may submit written comments to the
Division concerning 1) the sufficiency of the preliminary analysis, 2) whether the permit application should be
approved or denied, 3) the ability of the proposed activity to comply with applicable requirements, 4) the air quality
impacts of, alternatives to, and control technology required on the source or modification, and 5) any other
appropriate air quality considerations. Any interested person may submit a written request to the Division for a public
comment hearing before the Colorado Air Quality Control Commission (Commission) to receive comments regarding
the concerns listed above as well as the sufficiency of the preliminary analysis and whether the Division should
approve or deny the permit application. If requested, the hearing will be held before the Commission within 60 days
of its receipt of the request for a hearing unless a longer time period is agreed upon by the Division and the applicant.
The hearing request must: 1) identify the individual or group requesting the hearing, 2) state his or her address and
phone number, and 3) state the reason(s) for the request, the manner in which the person is affected by the
proceedings, and an explanation of why the person's interests are not already adequately represented. The Division
will receive and consider the written public comments and requests for any hearing for thirty calendar days after the
date of this Notice.
RELEASED TO: The Greeley Tribune on PUBLISHED: October 5, 2013
October 2, 2013
Colorado Department
of Public Health
and Environment
OPERATING PERMIT
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Issued: DATE
AIR POLLUTION CONTROL DIVISION
COLORADO OPERATING PERMIT
FACILITY NAME: Spindle Hill Energy
Center
FACILITY ID: 123/5468
ISSUED:
EXPIRATION DATE:
MODIFICATIONS:
DATE
DATE
See Appendix F of Permit
OPERATING PERMIT NUMBER
08OPWE311
Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et
sec . and applicable rules and regulations.
ISSUED TO: PLANT SITE LOCATION:
Spindle Hill Energy, LLC Spindle Hill Energy, LLC
6335 County Road 19 6335 County Road 19
Fort Lupton, CO 80621 Fort Lupton, CO 80621
INFORMATION RELIED UPON
Operating Permit Application Received:
And Additional Information Received:
Nature of Business:
Primary SIC:
April 8, 2008
September 6, 2012; September 17, 2012; December 17,
2012: December 19.2012
Electric Power Generation
4911
RESPONSIBLE OFFICIAL
Name: Robert Rooney
Title: O&M Manager
Phone: 303-833-5135
FACILITY CONTACT PERSON
Name: Robert Rooney
Title: O&M Manager
Phone: 303-833-5135
SUBMITTAL DEADLINES —
First Semi -Annual Monitoring Period:
Subsequent Semi -Annual Monitoring Periods:
Semi -Annual Monitoring Reports:
First Annual Compliance Period:
Subsequent Annual Compliance Periods:
Annual Compliance Certification:
Note that the Semi -Annual Monitoring Reports and Annual Compliance report must be received at the Division
office by 5:00 p.m. on the due date. Postmarked dates will not be accepted for the purposes of determining the
timely receipt of those reports.
FOR ACID RAIN SUBMITTAL DEADLINES SEE SECTION 1II.4 OF THIS PERMIT
TB.D based on issuance date
January 1 — June 30, July 1 — December 31
Due February 1, 2014 & August 1, 2014 & subsequent years
TBD based on issuance date
January 1 — December 31
Due February 1, 2014 & subsequent years
TABLE OF CONTENTS:
SECTION I - General Activities and Summary 1
1. Permitted Activities 1
2. Alternative Operating Scenarios 1
3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant
Deterioration (PSD) 2
4. Accidental Release Prevention Program (112(r)) 2
5. Compliance Assurance Monitoring (CAM) 2
6.. Summary of Emission Units 3
SECTION II Specific Permit Terms 4
1. CT -01 & CT -02: Two (2) GE 7FA Simple Cycle Combustion Turbines 4
2. Continuous Emission Monitoring Requirements 18
3. EU 003: One (1) GTS Energy Natural Gas Fired Water Bath Gas Heater 23
4. Fire Pump Engine: One (1) Clarke VMFP-T6HT Fire Pump Engine, Rated at 145 HP 26
5. Facility Wide Requirements 33
SECTION III - Acid Rain Requirements 35
1. Designated Representative and Alternative Designated Representative 35
2. Sulfur Dioxide Emission Allowances and Nitrogen Oxide Emission Limitations 35
3. Standard Requirements 35
4. Reporting Requirements 38
5. Comments, Notes and Justifications 39
SECTION IV - Permit Shield 40
1. Specific Non -Applicable Requirements 40
2. General Conditions 40
3. Stream -lined Conditions 40
SECTION V - General Permit Conditions (ver 5/22/2012) 42
1. Administrative Changes 42
2. Certification Requirements 42
3. Common Provisions 42
4. Compliance Requirements 46
5. Emergency Provisions 47
6. Emission Controls for Asbestos 47
7. Emissions Trading, Marketable Permits, Economic Incentives 47
8. Fee Payment 47
9. Fugitive Particulate Emissions 48
10. Inspection and Entry 48
11. Minor Permit Modifications 48
12. New Source Review 48
13. No Property Rights Conveyed 48
14. Odor 48
15. Off -Permit Changes to the Source 49
16. Opacity 49
17. Open Burning 49
18. Ozone Depleting Compounds 49
19. Permit Expiration and Renewal 49
TABLE OF CONTENTS:
20. Portable Sources 49
21. Prompt Deviation Reporting 49
22. Record Keeping and Reporting Requirements 50
23. Reopenings for Cause 51
24. Section 502(b)(10) Changes 51
25. Severability Clause 52
26. Significant Permit Modifications 52
27. Special Provisions Concerning the Acid Rain Program 52
28. Transfer or Assignment of Ownership 52
29. Volatile Organic Compounds 52
30. Wood Stoves and Wood burning Appliances 53
APPENDIX A - Inspection Information 55
1. Directions to Plant: 55
2. Safety Equipment Required: 55
3. Facility Plot Plan: 55
4. List of Insignificant Activities. 55
APPENDIX B 58
Reporting Requirements and Definitions 58
Monitoring and Permit Deviation Report - Part I 62
Monitoring and Permit Deviation Report - Part II 64
Monitoring and Permit Deviation Report - Part III 66
APPENDIX C 67
Required Format for Annual Compliance Certification Reports 67
APPENDIX D 70
Notification Addresses 70
APPENDIX E 71
Permit Acronyms 71
APPENDIX F 73
Permit Modifications 73
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
SECTION I - General Activities and Summary
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 1
1. Permitted Activities
1.1 The Spindle Hill Energy Center is a peaking utility electric power generation facility classified
under Standard Industrial Classification code 4911. The significant emissions units at the facility
include two (2) GE 7FA 145 MW simple -cycle combustion turbines capable of running on either
natural gas or fuel oil, a natural gas fired water bath gas heater used to heat natural gas before
firing, a fuel oil storage tank, and an emergency fire pump engine.
This facility is located approximately 4 miles west of Ft Lupton, Colorado at 6335 County Road
19 (West of Co Rd 19 and North of Co Rd 14), in Weld County. This area is classified as non -
attainment for ozone and is located in the 8 -hr Ozone Control Area as defined in Colorado
Regulation No.7, Section II.A.1.
There are no affected states within 50 miles of the facility. Rocky Mountain National Park and
the Rawah Wilderness Area are Federal Class I designated areas within 100 kilometers of the
facility.
1.2 Until such time as this permit expires or is modified or revoked, the permittee is allowed to
discharge air pollutants from this facility in accordance with the requirements, limitations, and
conditions of this permit.
1.3 The Operating Permit incorporates the applicable requirements contained in the underlying
construction permits, and does not affect those applicable requirements, except as modified
during review of the application or as modified subsequent to permit issuance using the
modification procedures found in Regulation No. 3, Part C. These Part C procedures meet all
applicable substantive New Source Review requirements of Part B. Any revisions made using
the provisions of Regulation No. 3, Part C shall become new applicable requirements for
purposes of this Operating Permit and shall survive reissuance. This permit incorporates the
applicable requirements (except as noted in Section II) from the following construction permits:
05WE0274
1.4 All conditions in this permit are enforceable by US Environmental Protection Agency, Colorado
Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless
otherwise specified. State -only enforceable conditions are: Permit Condition Number(s):
Section II — Condition 1.11.3; Section IV - Conditions 3.g (last paragraph), 14 & 18 (as noted).
1.5 All information gathered pursuant to the requirements of this permit is subject to the
Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions
in Section V of this permit. Either electronic or hard copy records are acceptable.
2. Alternative Operating Scenarios
2.1 The permittee shall be allowed to make the following changes to its method of operation without
applying for a revision of this permit (Regulation 3, Part A, Section IV.A).
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 2
2.1.1 No separate operating scenarios have been specified.
3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant Deterioration
(PSD)
3.1 This facility is categorized as a NANSR major stationary source (Potential to Emit of NOx > 100
Tons/Year). Future modifications at this facility resulting in a significant net emissions increase
(see Reg 3, Part D, Sections II.A.26 and 42) for VOC or NOx or a modification which is major
by itself (Potential to Emit of > 100 TPY of either VOC or NOx) may result in the application of
the NANSR review requirements.
3.2 Based on the information provided by the applicant, this source iscategorized as a minor
stationary source for PSD as of the issuance date of this permit. Any future modification which
is major by itself (Potential to Emit of > 250 TPY) for any pollutant listed in Regulation No. 3,
Part D, Section II.A.42 for which the area is in attainment or attainment/maintenance may result
in the application of the PSD review requirements.
3.3 There are no other Operating Permits associated with this facility for purposes of determining
applicability of Prevention of Significant Deterioration regulations.
4. Accidental Release Prevention Program (112(r))
4.1 Based on the information provided by the applicant, this facility is not subject to the provisions
of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act).
5. Compliance Assurance Monitoring (CAM)
5.1 The following emission points at this facility use a control device to achieve compliance with an
emission limitation or standard to which they are subject and have pre -control emissions that
exceed or are equivalent to the major source threshold.. They are therefore subject to the
provisions of the CAM program as set forth in 40 CFR Part 64, as adopted by reference in
Colorado Regulation No. 3, Part C, Section XIV:
The turbines are not subject to CAM since this Title V operating permit establishes a
continuous compliance determination method. (40 CFR Part 64 § 64.2(b)(1)(vi), as
adopted by reference in Colorado Regulation No. 3, Part C, Section XIV)
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
6. Summary of Emission Units
6.1 The emissions units regulated by this permit are the following:
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 3
Facilit\ 11)
AIRS ID Tescription
1 Pollution Control
CT -01
001
General Electric simple -cycle combustion turbine, Model
GE 7FA, Serial No. 297986, heat input rated at 1353.6
MMBtu/hr for natural gas and 1527 MMBtu/hr for fuel oil
(for ambient temperature of 50°F). This unit runs an
electric power generator and has a site -rated gross power
output of 145 megawatts.
Dry Low NOx
(DLN) Combustion
System and Water
Injection during fuel
oil firing for NOx
control
CT -02
002
General Electric simple -cycle combustion turbine, Model
GE 7FA, Serial No. 297987, heat input rated at 1353.6
MMBtu/hr for natural gas and 1527 MMBtu/hr for fuel oil
(for ambient temperature of 50°F). This unit runs an
electric power generator and has a site -rated gross power
output of 145 megawatts.
Dry Low NOx
(DLN) Combustion
System and Water
Injection during fuel
oil firing for NOx
control.
EU 0t)3
003
One (1) GTS Energy natural gas fired Water Bath Gas
Heater, Model ISNG-HWB8.3s5x, Serial No. PC06035,
• heat input rated at 11.1 MMBtu/hr. •
' NA
Tire Pump
Engine
005
One (1) Clarke, Model VFMP-T6HT, Serial No.
91B02978, distillate fuel oil fired internal combustion
engine, site -rated at 145 HP and 1.96 MMBtu/hr
NA
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
SECTION II - Specific Permit Terms
1. CT -01 & CT -02: Two (2) GE 7FA Simple Cycle Combustion Turbines
Unless otherwise specified, limits are for both turbines.
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 4
Parameter
Permit
Condition
Limitations
Compliance Emission
Factor(Ib/MMBtu)
Monitoring '
Number _,
CT -01 " 1,.: ` CT -02
' Method Interval
PM
1.1
PM1p
For each turbine:
0.1 lb/MMBtu
NA
Fuel Restriction
See Condition
1.1.1
70.0 tons/yr
70.0 tons/yr
Natural
gas:
0.002,
Fuel Oil:
0.007
Natural
gas:
0.004,
Fuel Oil:
0.008
Record Keeping
and Calculation
Monthly
Record Keeping
and Calculation
Monthly
VOC
1.2
17.7 tons/yr
Natural
gas:
0.0007,
fuel oil
0.0004
Natural
gas:
0.0004,
fuel oil
0,0004
Record Keeping
and Calculation
Monthly
SO2
1.3
37.50 tons/yr
See Condition 1.3
40 CFR Part 75,
Appendix D
As specified in 40
CFR Part 75,
Appendix D
For each turbine:
Use of fuel with ≤
0.060 lb/MMBtu
potential sulfur
emissions
NA
Fuel Restriction
See Condition 1.3
H2SO4
1.4
5.0 tons/yr
Fuel oil:
0.0006
lb/MMBtu
Fuel oil:
0.0009
lb/MMBtu
Record Keeping
and Calculation
Monthly
NOx
1.5
223.3 tons/yr
For each turbine,
when firing natural
gas: 15 ppmvd at
15% O2, on a 4 -hour
rolling average
Note: doesn't apply
during
Startup/Shutdown/
Malfunction
For each turbine
when firing fuel oil:
42 ppmvd at 15% O2,
on a 4 -hour rolling
average
Note: doesn't apply
during
Startup/Shutdown/
Malfunction
NA
NA
Continuous
Emission
Monitoring System
Continuously
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 5
� rN
Monitoring
_; -
Parameter
Permit ..
Condition '�
a
LimtCattons
Compliance Einissiom,
`Factor (lb/LV MBtu i
)
z
Number :
CT -01 ;'
CT -02
,Method
Interval :.,..
CO
1.6
223.4 tons/yr
NA
Continuous
Emission
Monitoring System
Continuously
Fuel Consumption
1.7
For both turbines
combined:
Natural gas —11,328
MMscf/yr
Distillate fuel oil —
11,110,743 gal/yr
(natural gas
consumption limits
shall be reduced with
fuel oil use according
to Condition 1.7)
NA
Recordkeeping and
Calculation
Monthly
Continuous Emission
Monitoring System
Requirements
1.8
NA
NA
NA
See Condition 1.8
Sulfur Content of Fuel
1.9
For Natural Gas:
total sulfur content
not to exceed 20
gramsll00scf
For Fuel Oil: total
sulfur content not to
exceed 0.05 % by
weight
NA
See Condition 1.9
NSPS General
Provisions
1.10
NA
NA
As Required by
NSPS General
Provisions
Subject to NSPS
General
Provisions
Not to Exceed 20%
Except as Provided
for Below
See Condition 1.12
Opacity
1.11
For Certain
Operational
Activities - Not to
Exceed 30%, for a
Period or Periods
Aggregating More
than Six (6) Minutes
in any 60
Consecutive Minutes
NA
State Only
Requirement: Not
to Exceed 20%
NSPS Subpart KKKK
1.12
See Condition 1.12
Acid Rain Program
Requirements
1.13
See Section III of this Permit
Certification
Annually
Operating Permit 08OPWE311
Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
1.1 PM and PM10 emissions are subject to the following requirements.
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 6
1.1.1 Particulate Matter (PM) emissions from each turbine shall not exceed 0.1 lbs/mmBtu
(Colorado Regulation No. 1, Section IILA.1.c). In the absence of credible evidence to
the contrary, compliance with the particulate matter emission limits is presumed
whenever natural gas or distillate fuel oil that meets the requirements in Condition 1.9
is used as fuel in the turbines.
1.1.2 Total annual emissions of PM and PKo from both turbines together shall not exceed
the limitations in the summary table above (Construction Permit 05WE0274, as
modified under the provisions of Section I, Condition 1.3 to set emission limits for
individual equipment instead of a facility wide total). Monthly emissions from each
turbine shall be calculated by the end of the subsequent month using the above
emission factors (from performance tests conducted in April and May 2007) and the
heat input for the month as recorded on the data acquisition and handling system
(DAHS) for the continuous emission monitoring system (required by Condition 1.8) in
the following equation:
tons/mo = (EF, Ibs/mmBtu) x heat input (mmBtu/mo)
2000 lbs/ton
Monthly emissions from each turbine shall be summed together and used in a twelve
month rolling total to monitor compliance with the annual limitations. Each month a
new twelve month total shall be calculated using the previous twelve months data.
1.1.3 When burning distillate fuel oil: A performance test shall be conducted on each
turbine to monitor compliance with the PM/PMto annual emissions whenever the hours
of operation on distillate fuel oil for both turbines combined reaches 1,000 hours in
any two consecutive calendar years. These performance tests shall be conducted
within 60 days, or within 100 distillate fuel oil -fired operating hours, whichever occurs
later, of reaching 1,000 hours and shall be conducted in accordance with the
requirements of 40 CFR Part 60 Subpart A § 60.8 using EPA Test Methods 5 and 202.
A stack testing protocol shall be submitted for Division approval at least thirty (30)
calendar days prior to performance of the tests required under this condition. No stack
test required herein shall be performed without prior written approval of the protocol
by the Division. The Division reserves the right to witness the tests. In order to
facilitate the Division's ability to make plans to witness the tests, notice of the date (s)
for the stack tests shall be submitted to the Division at least thirty (30) calendar days
prior to the tests. The Division may for good cause shown, waive this thirty (30) day
notice requirement. In instances when a scheduling conflict is presented, the Division
shall immediately contact the permittee in order to explore the possibility of making
modifications to the stack test schedule. The required number of copies of the
compliance test results shall be submitted to the Division within forty-five (45)
calendar days of the completion of the test unless a longer period is approved by the
Division.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 7
1.2 Total Annual emissions of VOC from both turbines together shall not exceed the limitations in
the summary table above (Colorado Construction Permit 05WE0274, as modified under the
provisions of Section I, Condition 1.3 to set emission limits for individual equipment instead of a
facility wide total). Monthly emissions from each turbine shall be calculated by the end of the
subsequent month using the above emission factors (from performance tests conducted in April
and May 2007) and the heat input for the month as recorded on the data acquisition and handling
system (DAHS) for the continuous emission monitoring system (required by Condition 1.8) in
the following equation:
tons/mo = (EF, lbs/mmBtu) x heat input (mmBtu/mo)
2000 lbs/ton
Monthly emissions from each turbine shall be summed together and used in a twelve month
rolling total to monitor compliance with the annual limitations. Each month a new twelve month
total shall be calculated using the previous twelve months data.
1.3 Sulfur Dioxide (SO2) emissions shall not exceed the following limitations:
1.3.1 Total Annual Sulfur Dioxide (SO2) emissions from both turbines together shall not
exceed the limitations in the summary table above (Colorado Construction Permit
05WE0274, as modified under the provisions of Section I, Condition 1.3 to set
emission limits for individual equipment instead of a facility wide total). Compliance
with the annual SO2 emission limitations shall be monitored using the protocol
specified in 40 CFR Part 75 Appendix D.
Monthly emissions from each turbine shall be summed together and used in a twelve
month rolling total to monitor compliance with the annual limitations. Each month a
new twelve month total shall be calculated using the previous twelve months data.
1.3.2 Each turbine shall meet the following fuel use requirement:
1.3.2.1 You must not burn in the subject stationary combustion turbine any fuel
which contains total potential sulfur emissions in excess of 0.060 lb
SO2/MMBtu heat input. If your turbine simultaneously fires multiple fuels,
each fuel must meet this requirement (40 CFR 60 Subpart KKKK,
(§60.4330(a)(2), as adopted by reference in Colorado Regulation No. 6, Part
A)
Compliance with the above fuel sulfur content limitation shall be
determined according to the requirements of Conditions 1.12.9, 1.12.10, and
1.12.11.
1.4 Total annual emissions of sulfuric acid (H25O4) from both turbines together shall not exceed
the limitations in the summary table above (Colorado Construction Permit 05WE0274, as
modified under the provisions of Section I, Condition 1.3 to set emission limits for individual
equipment instead of a facility wide total). Monthly emissions from each turbine shall be
calculated by the end of the subsequent month using the above emission factors (from
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 8
performance tests conducted in April and May 2007) and the heat input for the month as
recorded on the data acquisition and handling system (DAHS) for the continuous emission
monitoring system (required by Condition 1.8) in the following equation:
tons/mo = (EF, lbs/mmBtul x heat input (mmRtu/mol
2000 lbs/ton
Monthly emissions from each turbine shall be summed together and used in a twelve month
rolling total to monitor compliance with the annual limitations. Each month a new twelve month
total shall be calculated using the previous twelve months data.
1.5 Emissions of Nitrogen Oxides (NOx) shall not exceed the following limitations:
1.5.1 Total annual emissions of NOx from both turbines together shall not exceed the
limitation in the summary table above (Colorado Construction Permit 05WE0274, as
modified under the provisions of Section I, Condition 1.3 to set emission limits for
individual equipment instead of a facility wide total). Monthly emissions from each
turbine shall be determined using the continuous emission monitoring system required
by Condition 1.8. For any hour in which fuel is combusted in the turbines, the
permittee shall program the DAHs to calculate lb/hr NOx emissions in accordance with
the requirements in 40 CFR Part 75, including any replaced data and bias -adjusted
data, as warranted.
Specifically hourly mass NOx emissions (in lb/hr) shall be calculated by multiplying
the hourly NOx lb/MMBtu value (which includes replaced or bias -adjusted data, as
applicable) by the hourly heat input value (MMBtu/hr) (which includes replaced data
from the fuel flow measurement, as applicable). The hourly NOx lb/MMBtu and heat
input values shall be determined using equation F-5 and equation F-19 (fuel oil) or F-
20 (natural gas) in Appendix F of 40 CFR Part 75. The resulting NOx lb/hr value is
then multiplied by the unit operating time for that hour to produce a NOx lbs value.
Hourly NOx mass emissions (lbs) shall be summed and divided by 2000 lb/ton to
determine monthly NOx emissions (in tons).
Monthly emissions from each turbine shall be summed together and used in a twelve
month rolling total to monitor compliance with the annual emission limitation. Each
month a new twelve month total shall be calculated using the previous twelve months
total.
1.5.2 Nitrogen Oxide (NOx) emissions from each turbine shall not exceed the following
limitations (40 CFR 60 Subpart KKKK, §60.4320(a) and Table 1 to Subpart KKKK, as
adopted by reference in Colorado Regulation No. 6, Part A):
1.5.2.1 When firing natural gas, NOx emissions shall not exceed 15 ppmvd at 15%
O2, on a 4 -hour rolling average;
1.5.2.2 When firing fuels other than natural gas, NOx emissions shall not exceed 42
ppmvd at 15% O2, on a 4 -hour rolling average.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 9
1.6
1.5.2.3 The emission limitation above does not apply during periods of startup,
shutdown, or malfunction; however, emissions during startup, shutdown,
and malfunction shall be included in determining compliance with the
annual limitation in Condition 1.5.1.
Compliance with the above limitations shall be monitored using the continuous
emission monitoring system required by Condition 1.8. As specified in Condition
1.12.8.3, the missing data substitution methodology specified in 40 CFR Part 75
Subpart D, is not required for purposes of identifying excess emissions. Instead,
periods of missing CEMS data are to be reported as monitor downtime in the excess
emissions and monitoring performance report required by Condition 2.5. -
Total annual emissions of CO from both turbines together shall not exceed the limitations in
the summary table above (Colorado Construction Permit 05WE0274, as modified under the
provisions of Section I, Condition 1.3 to set emission limits for individual equipment instead of a
facility wide total). Monthly emissions from each turbine shall be determined using the
continuous emission monitoring system required by Condition 1.8. When quality assured data is
not available for CO, the missing data substitution procedures of 40 CFR Part 75 Subpart D, as
specified for NOx, shall be applied to CO. For any hour in which fuel is combusted in the
turbines, the permittee shall program the DAHS to calculate lb/hr CO emissions in accordance
with the requirements in 40 CFR Part 75, including any replaced data, if warranted.
Specifically, hourly mass CO emissions (in lb/hr) shall be calculated by multiplying the hourly
CO lb/MMBtu value (which includes replaced data in accordance with the provisions in Part 75
for NOx replacement, as applicable) by the hourly heat input value (MMBtu/hr) (which includes
replaced data from the fuel flow measurement, as applicable). The hourly CO lb/MMBtu and
heat input values shall be determined using equations F-5 (except that the value of K is 7.25 x
10"s for carbon monoxide) and F-19 (for fuel oil) or F-20 (for natural gas) in Appendix F of 40
CFR Part 75. The resulting CO lb/hr value is then multiplied by the unit operating time for that
hour to produce a CO lbs value. Hourly CO mass emissions (lbs) shall be summed and divided
by 2000 lb/ton to determine monthly CO emissions (in tons).
Monthly emissions from each turbine shall be summed together and used in a twelve month
rolling total to monitor compliance with the annual emission limitation. Each month a new
twelve month total shall be calculated using the previous twelve months total.
1.7 Total fuel consumption for both turbines together shall not exceed the above limitations
(Colorado Construction Permit 05WE0274, as modified under the provisions of Section I,
Condition 1.3). The fuel consumption for each turbine shall be monitored and recorded monthly
using the fuel flow meter required by Condition 1.8. Monthly natural gas fuel consumption for
each turbine shall be summed together and used in a rolling twelve month total to monitor
compliance with the annual limitation. Monthly distillate fuel oil consumption for each turbine
shall be summed together and used in a rolling twelve month total to monitor compliance with
the annual limitation. Each month new twelve month rolling totals for each fuel shall be
calculated using the previous twelve months data for that fuel.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 10
1.7.1 For a combination of natural gas and fuel oil, for each gallon of fuel oil burned in the
turbines, the consumption limit of natural gas shall be reduced by 1,040.614 standard
cubic feet. (Colorado Construction Permit 05WE0274)
1.8 Each of the turbine exhaust stacks shall be equipped with a continuous emission monitoring
system to measure and record the following (Colorado Construction Permit 05WE0274, as
modified under the provisions of Section I, Condition 1.3):
1.8.1 Combustion fuel flow rate for natural gas and distillate fuel oil;
1.8.2 Concentration of NOx, ppmvd hourly average, in the exhaust, corrected to 15% O2;
1.8.3 Emissions of NOx, pounds per hour, tons per month, and tons per rolling 12 months;
1.8.4 Concentration of Carbon Monoxide, ppmvd hourly average, in the exhaust, corrected
to 15% O2;
1.8.5 Emissions of Carbon Monoxide, pounds per hour, tons per month and tons per rolling
12 months;
1.8.6 Concentration of Oxygen, percent hourly average, in the exhaust;
1.8.7 Commencement and end of startup events;
1.8.8 Rate of water injection during distillate fuel oil firing, and water -to -fuel oil ratio.
The continuous emission monitoring systems shall meet the requirements in Condition 2 of this
permit. Data from the continuous emission monitoring system shall be used to determine
compliance with the NOx emission limitations as specified by Conditions 1.5 and Condition
1.12, and to determine compliance with the CO emission limitation as specified by Condition
1.6.
1.9 The sulfur content of the fuels burned in the turbines shall meet the following requirements:
1.9.1 The permittee shall maintain records demonstrating that the natural gas burned meets
the definition of natural gas as defined in 40 CFR Part 72. Specifically, the permittee
shall demonstrate that the natural gas burned has a total sulfur content of 20 grains/100
SCF or less.
1.9.2 The annual average sulfur content of the distillate fuel oil burned shall not exceed 0.05
% by weight (Colorado Construction Permit 05WE0274). If fuel sampling is used to
demonstrate compliance with this requirement all sampling data for the annual period
shall be used to calculate the annual average sulfur content of the distillate fuel.
Compliance with the fuel sulfur content limits above shall be monitored using the methods
identified in Conditions 1.12.9, 1.12.10, and 1.12.11.
Operating Permit 08OPWE311 Issued: DA].
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 11
1.10 Regulation No. 6, Part A, Subpart A, General Provisions apply as follows:
1.10.1 At all times, including periods of start-up, shutdown, and malfunction, the facility and
control equipment shall, to the extent practicable, be maintained and operated in a
manner consistent with good air pollution control practices for minimizing emissions.
Determination of whether or not acceptable operating and maintenance procedures are
being used will be based on information available to the Division, which may include,
but is not limited to, monitoring results, opacity observations, review of operating and
maintenance procedures, and inspection of the source. (Colorado Construction Permit
05WE0274 and 40 CFR 60 Subpart A §60.11(d), as adopted by reference in Colorado
Regulation No. 6, Part A)
1.10.2 No article, machine, equipment or process shall be used to conceal an emission that
would otherwise constitute a violation of an applicable standard. Such concealment
includes, but is not limited to, the use of gaseous diluents to achieve compliance with
an opacity standard or with a standard that is based on the concentration of a pollutant
in the gases discharged to the atmosphere. (Colorado Construction Permit 05WE0274
and 40 CFR 60 Subpart A §60.12, as adopted by reference in Colorado Regulation No.
6, Part A)
1.10.3 Records of startups, shutdowns, and malfunctions shall be maintained, as required
under§60.7.
1.10.4 Written notification of continuous monitoring system demonstrations shall be
submitted to the Division as required under §60.7.
1.10.5 Excess Emission and Monitoring System Performance Reports shall be submitted as
required under §60.7.
1.10.6 Performance tests shall be conducted as required under §60.8.
1.10.7 Continuous monitoring systems shall be maintained and operated as required under
§60.13.
1.11 The turbines at this facility are subject to the following opacity requirements:
1.11.1 Except as provided for in Condition 1.11.2 below, no owner or operator of a source
shall allow or cause the emission into the atmosphere of any air pollutant which is in
excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). This opacity
standard applies to each turbine.
1.1 1.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere
any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot
blowing, start-up, any process modification, or adjustment or occasional cleaning of
control equipment, which is in excess of 30% opacity for a period or periods
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 12
aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado
Regulation No. 1, Section II.A.4). This opacity standard applies to each turbine.
1.11.3 State -Only Requirement: No owner or operator may discharge, or cause the
discharge into the atmosphere of any particulate matter which is greater than 20%
opacity (Colorado Regulation No. 6, Part B, Section II.C.3). This opacity standard
applies to each turbine.
This opacity standard applies at all times except during periods of startup, shutdown
and malfunction (40 CFR Part 60 Subpart A § 60.11(c), as adopted by reference in
Colorado Regulation No. 6, Part B, Section I.A).
Note that this opacity requirement is more stringent than the opacity requirement in
Condition 1.11.2 during periods of building of a new fire, cleaning of fire boxes, soot
blowing, process modifications and adjustment or occasional cleaning of control
equipment.
Compliance with the opacity requirements shall be monitored as follows:
1.11.4 When Burning Natural Gas as Fuel: In the absence of credible evidence to the
contrary, each turbine shall be presumed to be in compliance with the above opacity
requirements whenever natural gas is used as fuel.
1.11.5 When Burning Distillate Fuel Oil compliance with the opacity requirements shall be
monitored as follows:
1.11.5.1 Compliance with the opacity standard in Condition 1.11.1 shall be
monitored by conducting annual visible emission observations in
accordance with EPA Method 9.
A visible emissions observation is not required for any annual period where
no distillate fuel oil is burned, or where no events of distillate fuel oil runs
lasting at least one hour occur.
1.11.5.2 Compliance with the opacity standard in Condition 1.11.2 shall be
monitored by conducting visible emission observations in accordance with
EPA Method 9, semi-annually. This opacity observation shall be taken
within one (1) hour of the commencement of any of the specific activities
identified in Condition 1.11.2 and every 24 hours thereafter until that
activity is completed.
A visible emissions observation is not required for any semi-annual period
where no distillate fuel oil is burned. In addition, a visible emission
observation is not required for any semi-annual period where no specific
activities identified in Condition 1.11.2 have occurred when distillate fuel
oil is burned.
Operating Permit 08OPWE311 Issued: DATI.t
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 13
1.11.5.3 Compliance with the opacity standard in Condition 1.11.3 is presumed, in
the absence of credible evidence to the contrary, provided the visible
emission observations conducted under the provisions of Condition 1.11.5.1
and 1.11.5.2 indicate compliance.
Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of
credible evidence to the contrary, exceedance of the opacity limit shall be
considered to exist from the time a Method 9 reading is taken that shows an
exceedance of the opacity limit until a Method 9 reading is taken that shows
the opacity is less than the opacity limit.
1.11.5.4
1.11.5.5 Results of Method 9 readings and a copy of the certified Method 9 reader's
certification shall be made available to the Division upon request.
1.12 These turbines are subject to the requirements in 40 CFR Part 60 Subpart KKKK, "Standards of
Performance for Stationary Combustion Turbines" (as adopted by Colorado Regulation No. 6,
Part A, Subpart KKKK), including, but not limited to, the following:
[The requirements below reflect the current rule language as of the revisions to 40 CFR Part 60
Subpart KKKK published in the Federal Register on March 20, 2009 (74 FR 11861). However,
if revisions to this Subpart are published at a later date, the owner or operator is subject to the
requirements contained in the revised version of 40 CFR Part 60 Subpart KKKK.]
[Please note that proposed revisions to 40 CFR Part 60 Subpart KKKK were published in the
Federal Register on August 29, 2012 (77 FR 52553). Therefore, the requirements below may
change in the future.]
Emission Limits
1.12.1 The pollutants regulated by this subpart are nitrogen oxide (NOx) and sulfur dioxide
(SO2). (§60.4315)
1.12.2 You must meet the emission limits for NOx specified in Table 1 to Subpart KKICK.
(§60.4320(a))
1.12.2.1 Reference Condition 1.5.2 for NOx emission limits from Table 1 to Subpart
KKKK.
1.12.3 You must meet the emission limits specified in Table 1 to Subpart ICKICK. If your total
heat input is greater than or equal to 50 percent natural gas, you must meet the
corresponding limit for a natural gas -fired turbine when you are burning that fuel.
Similarly, when your total heat input is greater than 50 percent distillate oil and fuels
other than natural gas, you must meet the corresponding limit for distillate oil and fuels
other than natural gas for the duration of the time that you burn that particular fuel.
(§60.4325)
1.12.4 For turbines located in a continental area, you must not burn in the subject stationary
combustion turbine any fuel which contains total potential sulfur emissions in excess of
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 14
0.060 lb SO2/MMBtu heat input. If your turbine simultaneously fires multiple fuels,
each fuel must meet this requirement. (§60.4330(a)(2))
General Compliance Requirements
1.12.5 You must operate and maintain your stationary combustion turbine, air pollution
control equipment, and monitoring equipment in a manner consistent with good air
pollution control practices for minimizing emissions at all times including during
startup, shutdown, and malfunction. (§60.4333(a))
Monitoring
1.12.6 If you are using water or steam injection to control NOx emissions:
1.12.6.1 You must install, calibrate, maintain and operate a continuous monitoring
system to monitor and record the fuel consumption and the ratio of water or
steam to fuel being fired in the turbine when burning a fuel that requires
water or steam injection for compliance (§60.4335(a)); or
1.12.6.2 You may install, certify, maintain, and operate a continuous emission
monitoring system (CEMS) consisting of a NOx monitor and a diluent gas
(oxygen (O2)) monitor, to determine the hourly NOx emission rate in parts
per million (ppm) or pounds per million British thermal units (lb/MMBtu)
(§60.4335(b)(1))
1.12.7 If the option to use a NOx CEMS is chosen:
1.12.7.1 Each NOx/diluent CEMS must be installed and certified according to
Performance Specification 2 (PS 2) in appendix B to this part, except the 7 -
day calibration drift is based on unit operating days, not calendar days.
Alternatively, a NOx/diluent CEMS that is installed and certified according
to appendix A of part 75 of this chapter is acceptable for use under this
subpart. The relative accuracy test audit (RATA) of the CEMS shall be
performed on a Ib/MMBtu basis. (§60.4345(a))
1.12.7.2 As specified in §60.13(e)(2), during each full unit operating hour, both the
NOx monitor and the diluent monitor must complete a minimum of one
cycle of operation (sampling, analyzing, and data recording) for each 15 -
minute quadrant of the hour, to validate the hour. For partial unit operating
hours, at least one valid data point must be obtained with each monitor for
each quadrant of the hour in which the unit operates. For unit operating
hours in which required quality assurance and maintenance activities are
performed on the CEMS, a minimum of two valid data points (one in each
of two quadrants) are required for each monitor to validate the NOx
emission rate for the hour. (§60.4345(b))
1.12.7.3 Each fuel flowmeter.shall be installed, calibrated, maintained, and operated
according to the manufacturer's instructions. Alternatively, fuel flowmeters
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 15
that meet the installation, certification, and quality assurance requirements
of appendix D to part 75 of this chapter are acceptable for use under this
subpart. (§60.4345(c))
1.12.7.4 Each watt meter, steam flow meter, and each pressure or temperature
measurement device shall be installed, calibrated, maintained, and operated
according to manufacturer's instructions. (§60.4345(d))
1.12.7.5 The owner or operator shall develop and keep on -site a quality assurance
(QA) plan for all of the continuous monitoring equipment described in
Conditions 1.12.7.1, 1.12.7.3, and 1.12.7.4. For the CEMS and fuel flow
meters, the owner or operator may satisfy the requirements of this
paragraph by implementing the QA program and plan described in section 1
of appendix B to part 75 of this chapter. (§60.4345(e))
1.12.8 For purposes of identifying excess emissions:
1.12.8.1 All CEMS data must be reduced to hourly averages as specified in
§60.13(h). (§60.435o(a))
1.12.8.2 For each unit operating hour in which a valid hourly average, as described
in Condition 1.12.7.2, is obtained for both NOx and diluent monitors, the
data acquisition and handling system must calculate and record the hourly
NOx emission rate in units of ppm or lb/MMBtu, using the appropriate
equation from method 19 in appendix A of this part. For any hour in which
the hourly average O2 concentration exceeds 19.0 percent O2, a diluent cap
value of 19.0 percent O2 may be used in the emission calculations.
(§60.4350(b))
1.12.8.3 If you have installed and certified a NOx diluent CEMS to meet the
requirements of part 75 of this chapter, only quality assured data from the
CEMS shall be used to identify excess emissions under this subpart. Periods
where the missing data substitution procedures in subpart D of part 75 are
applied are to be reported as monitor downtime in the excess emissions and
monitoring performance report required under Condition 2.5. (§60.4350(d))
1.12.8.4 All required fuel flow rate, steam flow rate, temperature, pressure, and
megawatt data must be reduced to hourly averages. (§60.4350(e))
1.12.8.5 Calculate the hourly average NOx emission rates, in units of the emission
standards under §60.4320, using ppm for units complying with the
concentration limit. (§60.4350(f))
1.12.8.6 For simple cycle units without heat recovery, use the calculated hourly
average emission rates from paragraph (f) (Condition 1.12.8.5) of this
section to assess excess emissions on a 4 -hour rolling average basis, as
described in §60.4380(b)(1) (Condition 1.12.13.1). (§60.4350(g))
1.12.9 You must monitor the total sulfur content of the fuel being fired in the turbine, except
as provided in Condition 1.12.10. The sulfur content of the fuel must be determined
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 16
using total sulfur methods described in Condition 1.12.16. Alternatively, if the total
sulfur content of the gaseous fuel during the most recent performance test was less than
half the applicable limit, ASTM D4084, D4810, D5504, or D6228, or Gas Processors
Association Standard 2377 (all of which are incorporated by reference, see §60.17),
which measure the major sulfur compounds, may be used. (§60.4360)
1.12.10 You may elect not to monitor the total sulfur content of the fuel combusted in the
turbine, if the fuel is demonstrated not to exceed potential sulfur emissions of 26 ng
SO2/J (0.060 lb SO2/MMBtu) heat input for units located in continental areas. You
must use one of the following sources of information to make the required
demonstration:
1.12.10.1 The fuel quality characteristics in a current, valid purchase contract, tariff
sheet or transportation contract for the fuel, specifying that the maximum
total sulfur content for oil use in continental areas is 0.05 weight percent
(500 ppmw) or less, the total sulfur content for natural gas use in
continental areas is 20 grains of sulfur or less per 100 standard cubic feet,
has potential sulfur emissions of less than less than 26 ng SO2/J (0.060 lb
SO2/MMBtu) heat input for continental areas (§60.4365(a)); or
1.12.10.2 Representative fuel sampling data which show that the sulfur content of the
fuel does not exceed 26 ng SO2/J (0.060 lb SO2/MMBtu) heat input for
continental areas. At a minimum, the amount of fuel sampling data
specified in section 2.3.1.4 or 2.3.2.4 of appendix D to part 75 of this
chapter is required.. (§60.4365(b))
1.12.11 The frequency of determining the sulfur content of the fuel must be as follows:
1.12.11.1 Fuel Oil: For fuel oil, use one of the total sulfur sampling options and the
associated sampling frequency described in sections 2.2.3, 2.2.4.1, 2.2.4.2,
and 2.2.4.3 of appendix D to part 75 of this chapter ( i.e. , flow proportional
sampling, daily sampling, sampling from the unit's storage tank after each
addition of fuel to the tank, or sampling each delivery prior to combining it
with fuel oil already in the intended storage tank). (§60.4370(a))
1.12.11.2 Gaseous Fuel: If you elect not to demonstrate sulfur content using options
in §60.4365, and the fuel is supplied without intermediate bulk storage, the
sulfur content value of the gaseous fuel must be determined and recorded
once per unit operating day. (§60.4370(b))
1.12.11.3 Custom Schedules: Notwithstanding the requirements of Condition
1.12.11.2, operators or fuel vendors may develop custom schedules for
determination of the total sulfur content of gaseous fuels, based on the
design and operation of the affected facility and the characteristics of the
fuel supply. Except as provided in paragraphs (c)(1) and (c)(2) of §60.4370
of Subpart KKKK, custom schedules shall be substantiated with data and
shall be approved by the Administrator before they can be used to comply
with the standard in Condition 1.12.4. The two custom sulfur monitoring
Operating Permit 08OPWE311 Issued: DA"fl
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 17
schedules set forth in paragraphs (c)(1)(i) through (iv) and in paragraph
(c)(2) of §60.4370 of Subpart KKK"( are acceptable, without prior
Administrator approval. (§60.4370(c) and §60.4370(c)(1))
Reporting
1.12.12 For each affected unit required to continuously monitor parameters or emissions, or to
periodically determine the fuel sulfur content under this subpart, you must submit
reports of excess emissions and monitor downtime, in accordance with §60.7(c).
Excess emissions must be reported for all periods of unit operation, including start-up,
shutdown, and malfunction. (§60.4375(a))
1.12.13 For the purpose of reports required under §60.7(c), periods of excess emissions and
monitor downtime that must be reported are defined as follows for turbines using
continuous emission monitoring, as described in §§60.4335(b) and 60.4345
(§60.4380(b)):
1.12.13.1 An excess emissions is any unit operating period in which the 4 -hour rolling
average NOx emission rate exceeds the applicable emission limit in
§60.4320. For the purposes of this subpart, a "4 -hour rolling average NOx
emission rate" is the arithmetic average of the average NOx emission rate in
ppm or ng/J (lb/MWh) measured by the continuous emission monitoring
equipment for a given hour and the three unit operating hour average NOx
emission rates immediately preceding that unit operating hour. Calculate the
rolling average if a valid NOx emission rate is obtained for at least 3 of the
4 hours. (§60.4380(b)(1))
1.12.13.2 A period of monitor downtime is any unit operating hour in which the data
for any of the following parameters are either missing or invalid: NOx
concentration, CO2 or O2concentration, fuel flow rate, steam flow rate,
steam temperature, steam pressure, or megawatts: The steam flow rate,
steam temperature, and steam pressure are only required if you will use this
information for compliance purposes. (§60.4380(b)(2))
1.12.14 If you choose the option to monitor the sulfur content of the fuel, excess emissions and
monitoring downtime are defined as follows:
1.12.14.1 For samples of gaseous fuel and for oil samples obtained using daily
sampling, flow proportional sampling, or sampling from the unit's storage
tank, an excess emission occurs each unit operating hour included in the
period beginning on the date and hour of any sample for which the sulfur
content of the fuel being fired in the combustion turbine exceeds the
applicable limit and ending on the date and hour that a subsequent sample is
taken that demonstrates compliance with the sulfur limit. (§60.4385(a))
1.12.14.2 If the option to sample each delivery of fuel oil has been selected, you must
immediately switch to one of the other oil sampling options (i.e., daily
sampling, flow proportional sampling, or sampling from the unit's storage
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 18
tank) if the sulfur content of a delivery exceeds 0.05 weight percent. You
must continue to use one of the other sampling options until all of the oil
from the delivery has been combusted, and you must evaluate excess
emissions according to Condition 1.12.14.1. When all of the fuel from the
delivery has been burned, you may resume using the as -delivered sampling
option. (§60.4385(b))
1.12.14.3 A period of monitor downtime begins when a required sample is not taken
by its due date. A period of monitor downtime also begins on the date and
hour of a required sample, if invalid results are obtained. The period of
monitor downtime ends on the date and hour of the next valid sample.
(§60.4385(c))
1.12.15 All reports required under §60.7(c) must be postmarked by the 30th day following the
end of each 6 -month period. (§60.4395)
Performance Tests
1.12.16 You must conduct initial and subsequent performance tests for sulfur according to
§60.4415 of Subpart KKKK. (§60.4415)
1.13 These units are subject to the Title IV Acid Rain Requirements. As specified in 40 CFR Part
72.72(b)(1)(viii), the acid rain permit requirements shall be complete and segregable portion of
the Operating Permit. As such the requirements are found in Section III of this permit.
2. Continuous Emission Monitoring Requirements
Note that the continuous emission monitoring requirements identified in this Condition are in addition to
the continuous emission monitoring requirements required by the Acid Rain Program, which are
identified in Section III of this permit.
2.1 Equipment and QA/QC Requirements
2.1.1 The Continuous Emission Monitoring Systems (CEMS) are subject to the following
requirements:
2.1.1.1 Except as provided for in Conditions 2.1.1.1(a), (c), and Condition 2.1.2.1,
the CO monitors are subject to the applicable requirements of 40 CFR Part
60 (Colorado Construction Permit 05WE0274). The monitoring systems
shall meet the equipment, installation and performance specifications of 40
CFR Part 60 Appendix B, Performance Specification 4/4A. These CEMS
are subject to the quality assurance/quality control requirements in 40 CFR
Part 60 Appendix F and Subpart A § 60.13.
a. The CO CEMS data shall meet the applicable "primary equipment
hourly operating requirements" for hourly average calculation
methodology specified in 40 CFR Part 75 Subpart B § 75.10(d).
Operating Permit 08OPWE311 Issued: DATI.t
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 19
b. CO monitor relative accuracy (RA) testing will be performed in ppm @
15 % O2 measurement units, and will be performed according to 40
CFR Part 60, Appendix B, Performance Specification 4/4A.
c. Relative accuracy test audit (RATA) frequency will be determined
according to the frequency applicable to NOx in 40 CFR Part 75,
Appendix B.
2.1.1.2 The NOx (and diluent) monitors are subject to the applicable requirements
of 40 CFR Part 75. The monitoring systems shall meet the equipment,
installation and performance specification requirements in 40 CFR Part 75,
Appendix A. These CEMS shall meet the quality assurance/quality control
requirements in 40 CFR Part 75, Appendix B and the conversion procedures
of Appendix F.
2.1.1.3 The NOx and CO GEMS for the turbines are subject to the following
requirements:
a. Relative Accuracy Test Audits (RATAs): RATAs shall be conducted in
the units (e.g., lb/MMBtu, ppm) of the emission limitation for all of the
emission limitations that are applicable to the emissions unit. The
RATAs for emissions units that have annual emission limitations
(tons/yr) will be conducted in terms of pounds per hour (lb/hr).
b. The DAHS for the CEMS shall be able to record and manipulate the
data in the units (e.g., lb/MMBtu) of the emission limitation and meet
the reporting requirements for all the emissions limitations that are
applicable to the emissions unit.
2.1.2 Quality assurance/quality control plans shall be prepared for the continuous emission
monitoring systems as follows:
2.1.2.1 The quality assurance/quality control plan for the CO monitors shall be
prepared in accordance with the applicable requirements in 40 CFR Part 60,
Appendix F, except that cylinder gas audit (CGA) testing is not required
during quarters with less than 168 hours of operating time.
2.1.2.2 The quality assurance /quality control plan for the NOx (and diluent)
monitors shall be prepared in accordance with the applicable requirements
in 40 CFR Part 75, Appendix B.
The quality assurance/quality control plans shall be made available to the Division
upon request. Revisions shall be made to the plans at the request of the Division.
2.2 General Provisions
2.2.1 CO monitors: The permittee shall ensure that all continuous emission monitoring
systems required are in operation and monitoring unit emissions at all times except for
monitoring system breakdowns, repairs, calibration checks and zero and span
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 20
adjustments required under 40 CFR Part 60 Subpart A § 60.13(d) (40 CFR Part 60
Subpart A § 60.13(e)).
2.2.2 $iOx (and diluent) monitors: The permittee shall ensure that all continuous emission
monitoring systems required are in operation and monitoring unit emissions at all times
that the affected unit combusts any fuel except as provided in 40 CFR § 75.11(e) and
during periods of calibration, quality assurance, or preventative maintenance performed
pursuant to 40 CFR Part 75, § 75.21 and Appendix B, periods of repair, periods of
backups of data from the data acquisition and handling system or recertification
performed pursuant to 40 CFR § 75.20 (40 CFR Part 75 § 75.10(d)).
2.2.3 Alternative monitoring systems, alternative reference methods, or any other
alternatives for the required continuous emission monitoring systems shall not be used
without having obtained prior written approval from the appropriate agency, either the
Division or the U.S. EPA, depending on which agency is authorized to approve such
alternative under applicable law. Any alternative continuous emission monitoring
systems or continuous opacity monitoring systems must be certified in accordance with
the applicable requirements of 40 CFR Part 60 or 40 CFR Part 75 prior to use.
2.2.4 All test and monitoring equipment, methods, procedures and reporting shall be subject
to the review and approval by the appropriate agency, either the Division or the U. S.
EPA, depending on which agency is authorized to approve such item under applicable
law, prior to any official use. The Division shall have the right to inspect such
equipment, methods and procedures and data obtained at any time. The Division may
provide a witness(s) for any and all tests as Division resources permit.
2.2.5 A file suitable for inspection shall be maintained of all measurements, including
continuous monitoring system, monitoring device, and performance testing
measurements; all continuous monitoring system performance evaluations; all
continuous monitoring system or monitoring device calibration checks; adjustments
and maintenance performed on these systems or devices; and all other information
required by applicable portions of 40 CFR Part 60 Subpart A and Appendices B and F
and 40 CFR Part 75.
2.2.6 Records shall be maintained of the occurrence and duration of any startup, shutdown,
or malfunction in the operation of the source; any malfunction of the air pollution
control equipment; or any periods during which a continuous monitoring system or
monitoring device is inoperative (40 CFR Part 60 Subpart A § 60.7(b) and Colorado
Construction Permit 05WE0274).
2.3 Data Replacement Requirements
For periods when quality assured data is not available from the continuous emission monitoring
systems the data replacement procedures in 40 CFR Part 75 Subpart D shall be used for
determining the total (annual) emissions. Although CO emissions are not specifically referenced
in the Subpart D procedures, the CEMS data acquisition system shall be programmed to
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 21
substitute CO emissions using the same procedures specified for NOx. For purposes of
monitoring compliance with the annual emission limitations (tons/yr), replaced and bias -adjusted
data, shall be included when assessing compliance with the annual limitations. Note that since
CO emissions are not subject to requirements in 40 CFR Part 75, the CO emission data is not
required to be bias -adjusted.
2.4 Reference Condition 1.12.7 for NSPS Subpart KKKK NOx CEMS provisions.
2.5 Recordkeeping and Reporting Requirements
2.5.1 The owner or operator of a facility required to install, maintain, and calibrate
continuous monitoring equipment shall submit to the Division, by the end of the
calendar month following the end of each semi-annual period, a report of excess
emissions for all pollutants monitored for that quarter (40 CFR Part 60 Subpart A §
60.7(c)). This report shall consist of the following information and/or reporting
requirements as specified by the Division:
2.5.1.1 The magnitude of excess emissions computed in accordance with 40 CFR
Part 60 Subpart A § 60.13(h), any conversion factor(s) used, and the date
and time of commencement and completion of each time period of excess
emissions and the process operating time during the reporting period (40
CFR Part 60 Subpart A § 60.7(c)(1)).
2.5.1.2 Specific identification of each period of excess emissions that occurs during
startups, shutdowns, and malfunctions of the affected facility. The nature
and cause of any malfunction (if known), the corrective action taken or
preventative measures adopted (40 CFR Part 60 Subpart A § 60.7(c)(2)).
2.5.1.3 The date and time identifying each period during which the continuous
monitoring system was inoperative except for zero and span checks and the
nature of the system repairs or adjustments (40 CFR Part 60 Subpart A §
60.7(c)(3)).
2.5.1.4 When no excess emissions have occurred or the continuous monitoring
system(s) have not been inoperative, repaired, or adjusted, such information
shall be stated in the report (40 CFR Part 60 Subpart A § 60.7(c)(4)).
2.5.2 The owner or operator of a facility required to install,, maintain, and calibrate
continuous monitoring equipment shall submit to the Division, by the end of the month
following the end of each semi-annual period, a summary report for that semi-annual
period (40 CFR Part 60 Subpart A § 60.7(c)). One summary report form shall be
submitted for each pollutant monitored. This report shall contain the information and
be presented in a format approved by the Division.
If the total duration of excess emissions for the reporting period is less than 1 percent
of the total operating time for the reporting period and continuous monitoring system
(CMS) downtime is less than 5 percent of the total operating time for the reporting
period, only the summary report form shall be submitted and the excess emission
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 22
report described in Condition 2.5.1 need not be submitted unless required by the
Division (40 CFR Part 60 Subpart A § 60.7(d)(1)).
If the total duration of excess emissions for the reporting period is 1 percent or greater
of the total operating time for the reporting period or the total CMS downtime for the
reporting period is 5 percent or greater of the total operating time for the reporting
period, the summary report form and the excess emission report described in Condition
2.5.1 shall both be submitted (40 CFR Part 60 Subpart A § 60.7(d)(1)).
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 23
3. EU 003: One (1) GTS Energy Natural Gas Fired Water Bath Gas Heater
x Parameter
Permit '
Condition
Number
. Limitation
Compliance Emission
Factor (lb/MMscf)
Momtonng
Method
Interval
I'M
3.1
0.267 lb/MMBtu
NA
See Condition 3.1
SO_
3.2
2 tons/day
NA
See Condition 3.2
NO
3'3
7.5 tons/yr
l 56.06
Recordkeeping
and Calculation
Monthly
CO
4.6 tons/yr
95.88
Recordkeeping
and Calculation
Monthly
Natural Gas
Consumption
3.4
95.33 MMscf/yr
NA
Recordkeeping
and Calculation
Monthly
NSPS Subpart Dc
3.5
NA
NA
See Condition 3.6
Opacity
3.6
Not to Exceed 20%,
Except as Provided
forin3.7.2 '
NA
Fuel Restriction
only Natural
Gas is to be used
as fuel
For Startup - Not to
Exceed 30%, for a
Period or Periods
Aggregating More
than Six (6) Minutes
in any 60
Consecutive Minutes
NA
3.1 PM emissions shall not exceed 0.267 lb/MMBtu (Colorado Regulation No. 1, Section HI.A.1.b).
In the absence of credible evidence to the contrary, compliance with the particulate matter
emission limit is presumed since natural gas is the only fuel permitted for use in the water bath
gas heater.
Note that the numeric PM standard was determined using the design heat input for the water bath
gas heater (11.1 MMBtu/hr) in the following equation:
PE = 0.5 x (FI)-0126' where: PE = particulate standard in lbs/MMBtu
FI = fuel input in MMBtu/hr
3.2 Sulfur Dioxide (SO2) emissions shall not exceed two (2) tons per day (Colorado Regulation No.
1, Section VI.B.5.a). In the absence of credible evidence to the contrary, compliance with the
sulfur dioxide emission limit is presumed since natural gas is the only fuel permitted for use in
the water bath gas heater.
3.3 Annual emissions of NOx and CO from the water bath gas heater shall not exceed the limitations
in the summary table above (Construction Permit 05WE0274, as modified under the provisions
of Section I, Condition 1.3 to set emission limits for individual equipment instead of a facility
wide total). Monthly emissions shall be calculated by the end of the subsequent month using the
Operating Permit 0$OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 24
emission factors above (from the vendor) and the monthly natural gas consumption (required by
Condition 3.4) in the following equation:
ton/mo = JEF (Ib/MMscf) x monthly natural gas consumption (MMscf/mo)J
2000 lb/ton
Monthly emissions shall be used in a rolling twelve month total to monitor compliance with the
annual limitations. Each month a new twelve month total shall calculated using the previous
twelve months' data.
3.4 Natural gas consumption shall not exceed the limitation in the summary table above
(Construction Permit 05WE0274, as modified under the provisions of Section I, Condition 1.3).
The fuel consumption for the water bath gas heater shall be monitored and recorded monthly
using a fuel meter, and used in a rolling twelve month total to monitor compliance with the
annual limitation. Each month new twelve month rolling total shall be calculated using the
previous twelve months data.
3.5 The water bath gas heater is subject to the requirements in 40 CFR 60 Subpart Dc, "Standards of
Performance for Small Industrial -Commercial -Institutional Steam Generating Units" (as adopted
by reference in Colorado Regulation No. 6, Part A), including, but not limited to the following
requirements:
3.5.1 The owner or operator of each affected facility shall submit notification of the date of
construction or reconstruction and actual startup, as provided by §60.7 of 40 CFR Part
60. This notification shall include:
3.5.1.1 The design heat input capacity of the affected facility and identification of
fuels to be combusted in the affected facility. (§60.48c(a)(1))
3.5.1.2 The annual capacity factor at which the owner or operator anticipates
operating the affected facility based on all fuels fired and based on each
individual fuel fired. (§60.48c(a)(2))
3.5.2 The owner or operator of an affected facility that combusts only natural gas shall
record and maintain records of the amount of fuel combusted during each calendar
month. (§60.48c(g))
3.5.3 Records of fuel combusted that are required under Condition 3.5.2 shall be maintained
by the owner or operator of the affected facility for a period of two years following the
date of such record. (§60.48c(i))
3.6 Opacity of emissions from the Water Bath Gas Heater shall not exceed the following:
3.6.1 Except as provided for in Condition 3.7.2 below, no owner or operator of a source shall
allow or cause the emission into the atmosphere of any air pollutant which is in excess
of 20% opacity (Colorado Regulation No.1, Section II.A.1).
Operating Permit 08OPWE311 Issued: D.ATI>
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 25
3.6.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere
any air pollutant resulting from start-up which is in excess of 30% opacity for a period
or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes
(Colorado Regulation No. 1, Section II.A.4).
In the absence of credible evidence to the contrary, compliance with the above opacity standards
shall be presumed since only natural gas is permitted to be used as fuel for this heater.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 26
4. Fire Pump Engine: One (1) Clarke VMFP-T6HT Fire Pump Engine, Rated at 145 HP
Parameter
Permit
Condition
Number.
.'„-,..
' " Limitation,
Compliance
Emission Factor
,,
Monitoring
;-
Method
Fnterval
Opacity
4.1
Not to exceed 20%, except
as provided for below
NA
Method 9
See Condition
4.1
For startup, not to exceed
30% for a period or periods
aggregating more than six
(6) minutes in any sixty
(60) consecutive minutes..
NESHAP Subpart
ZZZZ
4.2
NA
NA
See Condition 4.2
NSPS Subpart II1I
4.3
NOx + NMITC: 7.8 g/hp-hr
CO: 3.7 g/hp-hr
PM: 0.60 g/hp-hr
NA
See Condition 4.3
flours of Operation
4.4
500 hours/yr
NA
Recordkeeping
Monthly
RACY— VOC
emissions
4.5
Compliance with the NSPS
Subpart IIII Requirements
is Determined to be RACT
NA
Certification
Annually
4.1 Opacity of emissions from the engine shall not exceed the following:
4.1.1 Except as provided for in Condition 4.1.2 below, no owner or operator of a source shall
allow or cause the emission into the atmosphere of any air pollutant which is in excess
of 20% opacity (Colorado Regulation No. 1, Section II.A.1).
4.1.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere
any air pollutant resulting from startup which is in excess of 30% opacity for a period
or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes
(Colorado Regulation No. 1, Section II.A.4).
Compliance with these limitations shall be monitored by conducting opacity observations in
accordance with EPA Reference Method 9 as follows:
4.1.3 Engine startup shall not exceed 30 minutes. An engine startup period of less than 30
minutes shall not require an opacity observation to monitor compliance with the
opacity limit in Condition 4.1.2. A record shall be kept of the date and time the engine
started and when it was shutdown.
4.1.4 An opacity observation shall be conducted annually (calendar year period) to monitor
compliance with the opacity limit in Condition 4.1.1. If the engine is operated more
than 250 hours in any calendar year period, a second opacity observation shall be
conducted. If two opacity readings are conducted in the annual (calendar year) period,
such readings shall be conducted at least thirty days apart.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 27
4.1.5 If the engine is not operated during the annual (calendar year) period, then no opacity
observations are required.
4.1.6 Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence
to the contrary, exceedance of the opacity limit shall be considered to exist from the
time a Method 9 reading is taken that shows an exceedance of the opacity limit until a
Method 9 reading is taken that shows the opacity is less than the opacity limit.
4.1.7 All Method 9 opacity observations shall be performed by an observer with current and
valid Method 9 certification. Results of Method 9 readings and a copy of the certified
Method 9 reader's certificate shall be kept on site and made available to the Division
upon request.
4.2 [Federal -Only] This engine is subject to the requirements in 40 CFR Part 63 Subpart ZZZZ,
"National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines", including, but not limited to, the following:
[The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63
Subpart ZZZZ published in the Federal Register on 1/30/2013. However, if revisions to this
Subpart are published at a later date, the owner or operator is subject to the requirements
contained in the revised version of 40 CFR Part 63 Subpart ZZZZ.]
[Note that as of the date of permit issuance [DATE], the requirements in 40 CFR Part 63 Subpart
ZZZZ promulgated on January 18, 2008 have not been adopted into Colorado Regulation No. 8,
Part E by the Division and are therefore not state -enforceable. In the event that the Division
adopts these requirements, they will become both state and federally enforceable.]
Stationary RICE subject to Regulations under 40 CFR Part 60
4.2.1 If you own or operate a new or reconstructed stationary RICE located at an area source
of HAP emissions, you must meet the requirements of this part by meeting the
requirements of 40 CFR part 60 Subpart IIII, for compression ignition engines or 40
CFR part 60 subpart JJJJ, for spark ignition engines. No further requirements apply for
such engines under this part. (§63.6590(c)(1))
4.3 This engine is subject to the requirements in 40 CFR Part 60 Subpart IIII, "Standards of
Performance for Stationary Compression Ignition Internal Combustion Engines", as adopted by
reference in Colorado Regulation No. 6, Part A, including, but not limited to, the following
requirements:
[The requirements below reflect the current rule language as of the revisions to 40 CFR Part 60
Subpart IIII published in the Federal Register on 1/30/2013. However, if revisions to this
Subpart are published at a later date, the owner or operator is subject to the requirements
contained in the revised version of 40 CFR Part 60 Subpart IIII.]
Emission Standards for Owners and Operators
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 28
4.3.1 Owners and operators of fire pump engines with a displacement of less than 30 liters
per cylinder must comply with the emission standards in table 4 to Subpart IIII, for all
pollutants. (§60.4205(c))
The specific emission limitations in table 4 that apply to this engine are as follows:
Maximum Engine Power 100 < hp < 175
Model Year 2009 and earlier
Emission Standards (g/hp-hr)
NMHC+NOx
CO
PM
7.8
3.7
0.60
Compliance with the above emission limitations shall be demonstrated according to
Condition 4.3.5.
4.3.2 Owners and operators of stationary CI ICE must operate and maintain stationary CI
ICE that achieve the emission standards as required in Condition 4.3.1 over the entire
life of the engine. (§60.4206)
Fuel Requirements for Owners and Operators
4.3.3 Beginning October 1, 2010, owners and operators of stationary CI ICE subject to this
subpart with a displacement of less than 30 liters per cylinder that use diesel fuel must
use diesel fuel that meets the requirements of 40 CFR 80.510(b) for nonroad diesel
fuel, except that any existing diesel fuel purchased (or otherwise obtained) prior to
October 1, 2010, may be used until depleted. (§60.4207(b))
The fuel requirements for nomad diesel fuel listed in 40 CFR 80.510(b) are as
follows:
4.3.3.1 Sulfur content of 15 ppm maximum (§80.510(b)(1)(i))
4.3.3.2 A minimum cetane index of 40 or maximum aromatic content of 35 volume
percent ((§80.510(b)(2)(i), (ii))
Compliance with the above fuel use limitations shall be demonstrated by maintaining
records from thevendor indicating the diesel fuel purchased for use in the engine has
been tested according to the appropriate ASTM methods, and meets the sulfur content
and cetane index/aromatic content as described.
Compliance Requirements
4.3.4 If you are an owner or operator and must comply with the emission standards specified
in this subpart, you must do all of the following, except as permitted under Condition
4.3.7:
4.3.4.1 Operate and maintain the stationary CI internal combustion engine and
Operating Permit 08OPWE311 Issued: DA'L'E
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 29
control device according to the manufacturer's emission -related written
instructions (§60.4211(a)(1));
4.3.4.2 Change only those emission -related settings that are permitted by the
manufacturer (§60.4211(a)(2); and
4.3.4.3 Meet the requirements of 40 CFR parts 89, 94 and/or 1068, as they apply to
you (§60.4211(a)(3)).
4.3.5 If you are an owner or operator of a CI fire pump engine that is manufactured prior to
the model years in table 3 to Subpart IIII and must comply with the emission standards
specified in Condition 4.3.1, you must demonstrate compliance according to one of the
methods specified in Conditions 4.3.5.1 through 4.3.5.5. (§60.4211(b))
4.3.5.1 Purchasing an engine certified according to 40 CFR part 89 or 40 CFR part
94, as applicable, for the same model year and maximum engine power. The
engine must be installed and configured according to the manufacturer's
specifications. (§60.4211(b)(1))
4.3.5.2 Keeping records of performance test results for each pollutant for a test
conducted on a similar engine. The test must have been conducted using the
same methods specified in this subpart and these methods must have been
followed correctly. (§60.4211(b)(2))
4.3.5.3 Keeping records of engine manufacturer data indicating compliance with
the standards. (§60.4211(b)(3))
4.3.5.4 Keeping records of control device vendor data indicating compliance with
the standards. (§60.4211(b)(4))
4.3.5.5 Conducting an initial performance test to demonstrate compliance with the
emission standards according to the requirements specified in §60.4212, as
applicable. (§60.4211(b)(5))
4.3.6 If you own or operate an emergency stationary ICE, you must operate the emergency
stationary ICE according to the requirements in Conditions 4.3.6.1 through 4.3.6.3. In
order for the engine to be considered an emergency stationary ICE under this subpart,
any operation other than emergency operation, maintenance and testing, emergency
demand response, and operation in non -emergency situations for 50 hours per year, as
described in Conditions 4.3.6.1 through 4.3.6.3, is prohibited. If you do not operate the
engine according to the requirements in Conditions 4.3.6.1 through 4.3.6.3, the engine
will not be considered an emergency engine under Subpart IIII and must meet all
requirements for non -emergency engines. (§60.4211(1))
4.3.6.1 There is no time limit on the use of emergency stationary ICE in emergency
situations. (§60.4211(f)(1))
4.3.6.2 You may operate your emergency stationary ICE for any combination of the
purposes specified in Conditions 4.3.6.2(a) through 4.3.6.2(c) for a
maximum of 100 hours per calendar year. Any operation for non -
Operating Permit 08OPWE311 Issued: DATi:
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 30
emergency situations as allowed by Condition 4.3.6.3 counts as part of the
100 hours per calendar year allowed by this Condition 4.3.6.2.
(§60.4211(f)(2))
a. Emergency stationary ICE may be operated for maintenance checks and
readiness testing, provided that the tests are recommended by federal,
state or local government, the manufacturer, the vendor, the regional
transmission organization or equivalent balancing authority and
transmission operator, or the insurance company associated with the
engine. The owner or operator may petition the Administrator for
approval of additional hours to be used for maintenance checks and
readiness testing, but a petition is not required if the owner or operator
maintains records indicating that federal, state, or local standards require
maintenance and testing of emergency ICE beyond 100 hours per
calendar year. (§60.4211(f)(2)(i))
b. Emergency stationary ICE may be operated for emergency demand
response for periods in which the Reliability Coordinator under the
North American Electric Reliability Corporation (NERC) Reliability
Standard EOP-002-3, Capacity and Energy Emergencies (incorporated
by reference, see § 60.17), or other authorized entity as determined by
the Reliability Coordinator, has declared an Energy Emergency Alert
Level 2 as defined in the NERC Reliability Standard EOP-002-3.
(§60.4211(f)(2)(ii))
c. Emergency stationary ICE may be operated for periods where there is a
deviation of voltage or frequency of 5 percent or greater below standard
voltage or frequency. (§60.4211(f)(2)(iii))
4.3.6.3 Emergency stationary ICE may be operated for up to 50 hours per calendar
year in non -emergency situations. The 50 hours of operation in non -
emergency situations are counted as part of the 100 hours per calendar year
for maintenance and testing and emergency demand response provided in
Condition 4.3.6.2. Except as provided in Condition 4.3.6.3(a), the 50 hours
per calendar year for non -emergency situations cannot be used for peak
shaving or non -emergency demand response, or to generate income for a
facility to an electric grid or otherwise supply power as part of a financial
arrangement with another entity. (§60.4211(O(3))
a. The 50 hours per year for non -emergency situations can be used to
supply power as part of a financial arrangement with another entity if all
of the following conditions are met: (§60.4211(f)(3)(0)
(i) The engine is dispatched by the local balancing authority or local
transmission and distribution system operator;
(§60.4211(f)(3)(i)(A))
(ii) The dispatch is intended to mitigate local transmission and/or
distribution limitations so as to avert potential voltage collapse or
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 31
line overloads that could lead to the interruption of power supply in
a local area or region. (§60.4211(f)(3)(0(B))
(iii) The dispatch follows reliability, emergency operation or similar
protocols that follow specific NERC, regional, state, public utility
commission or local standards or guidelines. (§60.4211(f)(3)(i)(C))
(iv) The power is provided only to the facility itself or to support the
local transmission and distribution system. (§60.42l 1(f)(3)(i)(D))
(v) The owner or operator identifies and records the entity that
dispatches the engine and the specific NERC, regional, state, public
utility commission or local standards or guidelines that are being
followed for dispatching the engine. The local balancing authority
or local transmission and distribution system operator may keep
these records on behalf of the engine owner or operator.
(§60.4211(f)(3)(i)(E))
4.3.7 If you do not install, configure, operate, and maintain your engine and control device
according to the manufacturer's emission -related written instructions, or you change
emission -related settings in a way that is not permitted by the manufacturer, you must
demonstrate compliance as follows (§60.4211(g)):
4.3.7.1 If you are an owner or operator of a stationary CI internal combustion
engine greater than or equal to 100 HP and less than or equal to 500 HP,
you must keep a maintenance plan and records of conducted maintenance
and must, to the extent practicable, maintain and operate the engine in a
manner consistent with good air pollution control practice for minimizing
emissions. In addition, you must conduct an initial performance test to
demonstrate compliance with the applicable emission standards within 1
year of startup, or within 1 year after an engine and control device is no
longer installed, configured, operated, and maintained in accordance with
the manufacturer's emission -related written instructions, or within 1 year
after you change emission -related settings in a way that is not permitted by
the manufacturer. (§60.4211(g)(2))
Testing Requirements for Owners and Operators
4.3.8 Reference §60.4212 for testing requirements for owners and operators who conduct
performance tests pursuant to Subpart IIII.
Notification, Reports, and Records for Owners and Operators
4.3.9 If the stationary CI internal combustion engine is an emergency stationary internal
combustion engine, the owner or operator is not required to submit an initial
notification. (§60.4214(b))
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 32
4.3.10 If you own or operate an emergency stationary CI ICE with a maximum engine power
more than 100 HP that operates or is contractually obligated to be available for more
than 15 hours per calendar year for the purposes specified in Conditions 4.3.6.2(b) and
4.3.6.2(c) or that operates for the purposes specified in Condition 4.3.6.3(a), you must
submit an annual report according to the requirements in §60.4214(d)(1) through (3) of
Subpart IIII.
General Provisions
4.3.11 Table 8 to Subpart IIII shows which parts of the General Provisions in §§60.1 through
60.19 apply to you. 060.4218)
4.4 Hours of operation shall not exceed 500 hours per year (as provided for under the provisions in
Section I, Condition 1.3, and in accordance with the emission limits requested on the APEN
received on December 19, 2012). Compliance with the annual limitation shall be monitored by
recording the hours of operation monthly. Monthly hours of operation shall be used in a rolling
twelve month total to monitor compliance with the annual limitation. Each month a new twelve
month rolling total shall be calculated using the permit twelve month's data.
4.5 This engine is subject to RACT requirements for VOC emissions (Colorado Regulation No. 3,
Part B, Section III.D.2.a and Colorado Regulation No. 7, Section II.C.2). RACT for VOC shall
be met by complying with the requirements in 40 CFR Part 60 Subpart IIII (Condition 4.3 of this
permit).
Operating Permit 08OPWE311 Issued: DATE;
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 33
5. Facility Wide Requirements
ParaXneter
Permit
Condition
Number .
Limitation
Compliance Emission
Factor
Monitoring
Method
Interval ,
HAP Emissions
5.1
8.0 tons/yr single
15.0 tons/yr total
See Condition 5.1
Recordkeeping
and Calculation
Monthly
Insignificant Activities
5.2
NOx: 18.7 tons/yr
See Condition 5.2
Recordkeeping
and Calculation
One-time
CO: < 21.9 tons/yr
5.1 Facility -wide HAP emissions shall not exceed the limits in the summary table above (Colorado
Construction permit 05WE0274). HAP emissions for the turbines shall be calculated by the end
of the subsequent month using actual throughputs and the following compliance emission
factors.
Emission Unit ,
Pollutant. -
Emission Factor
Emission Factor Source
Cr-01 '
CT -02
Turbines
Formaldehyde
Natural Gas:
0.0001
lb/MMBtu,
Fuel Oil:
0.0003
lb/MMBtu
Natural Gas:
0.0005
lb/MMBtu,
Fuel Oil:
0.0003
lb/MMBtu
Natural gas emission factors from
performance tests conducted on
November 5, 2009 (CT -01) and in
April/May 2007 (CT -02); Fuel oil
emission factors from AP -42, Table
3.1-4.
Manganese
Fuel Oil:
0.0008
Fuel Oil:
0.0008
AP -42, Table 3.1-5
Total other HAPs
Emission Factor ratios:
During Natural Gas firing,
0.4469;
During Fuel Oil Firing,
0.7783.
Developed from AP -42, Chapter 3.1
5.1.1 Total HAP emissions, for each turbine, shall be calculated by using the emission factor
ratio above (according to the type of fuel fired) and the calculated emissions for
formaldehyde and manganese, according to the following:
During natural gas firing:
Total HAP = [EF ratio x calculated formaldehyde emissions] +
calculated formaldehyde emissions
During fuel oil firing:
Total HAP = [EF ratio x calculated formaldehyde emissions] +
calculated formaldehyde emissions +
calculated manganese emissions
Operating Permit 08OPWE311
Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 34
HAP emissions from other significant emissions units at this facility that are determined to be
above the de minimis levels, according to the method in Colorado Regulation No. 3, Appendix
A, shall be included with the facility wide HAP emissions calculated to demonstrate compliance
with the facility wide limits in this condition.
A twelve-month rolling total shall be maintained for demonstration of compliance with annual
HAP limitations. Each month, a new twelve month total shall be calculated using the previous
twelve months data. Records of calculations shall be maintained for Division inspection upon
request.
5.2 NOx and CO emissions from insignificant activities at the facility shall not exceed the limitations
in the summary table above. Compliance with the limitation shall be monitored by conducting a
potential to emit (PTE) of NOx and CO from insignificant activities that demonstrates that the
emissions are below the levels listed above. The analysis, as well as the calculations and any
supporting documentation, shall be retained on site and made available to the Division upon
request.
The above analysis shall be updated if any new insignificant activities that can potentially emit
NOx and/or CO emissions are added to the facility.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 0SOPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 35
SECTION III - Acid Rain Requirements
1. Designated Representative and Alternative Designated Representative
DESIGNATED REPRESENTATIVE ALTERNATE DESIGNATED REPRESENTATIVE
Name: Ralph E. Randall
Title: Invenergy Services, LLC
Regional Plant Director
Phone: (863) 375-3266 x 225
Name: Robert Rooney
Title: Invenergy Services LLC
O & M Manager
Phone: (303) 833-5135
2. Sulfur Dioxide Emission Allowances and Nitrogen Oxide Emission Limitations
Combustion Turbine 1
2007
2008
2009
2010
2011
2012
SO2 Allowances, per 40
CFR Part 73.10(b), Table 2
0*
0*
0*
0*
0*
0*
NOx Limits
This Unit Has No Acid Rain Program NOx Limits (See Section 5)
* Under the provisions of § 72.84(a) any allowance allocations to, transfers to and deductions from an affected unit's
Allowance Tracking System account is considered an automatic permit amendment and as such no revision to the permit is
necessary. Numerical allowances shown in this table are from the 1996 edition of the CFR.
Combustion Turbine 2
2007
2008
2009
2010
2011
2012
SO2 Allowances, per 40
CFR Part 73.10(b), Table 2
0*
0*
0*
0*
0*
0*
NOx Limits
This Unit Has No Acid Rain Program NOx Limits (See Section 5)
* Under the provisions of § 72.84(a) any allowance allocations to, transfers to and deductions from an affected unit's
Allowance Tracking System account is considered an automatic permit amendment and as such no revision to the permit is
necessary. Numerical allowances shown in this table are from the 1996 edition of the CFR.
3. Standard Requirements
Combustion Turbines CT -01 and CT -02 of this facility are subject to and the source has certified that they will
comply with the following standard conditions.
Permit Requirements
(1)
The designated representative of each affected source and each affected unit at the source shall:
(i) Submit a complete Acid Rain permit application (including a compliance plan) under 40 CFR part
72 in accordance with the deadlines specified in 40 CFR 72.30; and
(ii) Submit in a timely manner any supplemental information that the Division determines is necessary
in order to review an Acid Rain permit application and issue or deny an Acid Rain permit;
(2) The owners and operators of each affected source and each affected unit at the source shall:
Operating Permit 08OPWE311 Issued: DA'Z'E
(7)
(3)
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 36
(i) Operate the unit in compliance with a complete Acid Rain permit application or a superseding Acid
Rain permit issued by the Division; and
(ii) Have an Acid Rain Permit.
Monitoring Requirements
(I)
The owners and operators and, to the extent applicable, designated representative of each affected source
and each affected unit at the source shall comply with the monitoring requirements as provided in 40
CFR part 75.
(2) The emissions measurements recorded and reported in accordance with 40 CFR part 75 shall be used to
determine compliance by the source or unit, as appropriate, with the Acid Rain emissions limitations and
emissions reduction requirements for sulfur dioxide and nitrogen oxides under the Acid Rain Program.
The requirements of 40 CFR part 75 shall not affect the responsibility of the owners and operators to
monitor emissions of other pollutants or other emissions characteristics at the unit under other applicable
requirements of the Federal Clean Air Act and other provisions of the operating permit for the source.
Sulfur Dioxide Requirements
(1)
The owners and operators of each source and each affected unit at the source shall:
(i) Hold allowances, as of the allowance transfer deadline, in the source's compliance account (after
deductions under 40 CFR 73.34(c)) not less than the total annual emissions of sulfur dioxide for the
previous calendar year from the unit; and
(ii) Comply with the applicable Acid Rain emissions limitations for sulfur dioxide.
(2) Each ton of sulfur dioxide emitted in excess of the Acid Rain emissions limitations for sulfur dioxide
shall constitute a separate violation of the Federal Clean Air Act.
(3) An affected unit shall be subject to the requirements under paragraph (1) of the sulfur dioxide
requirements as follows:
(i) Starting January 1, 2000, an affected unit under 40 CFR 72.6(a)(2); or
(ii) Starting on the later of January 1, 2000 or the deadline for monitor certification under 40 CFR part
75, an affected unit under 40 CFR 72.6(a)(3).
(4) Allowances shall be held in, deducted from, or transferred among Allowance Tracking System accounts
in accordance with the Acid Rain Program.
(5) An allowance shall not be deducted in order to comply with the requirements under paragraph (1) of the
sulfur dioxide requirements prior to the calendar year for which the allowance was allocated.
(6) An allowance allocated by the Administrator under the Acid Rain Program is a limited authorization to
emit sulfur dioxide in accordance with the Acid Rain Program. No provision of the Acid Rain Program,
the Acid Rain permit application, the Acid Rain permit, or an exemption under 40 CFR 72.7 or 72.8 and
no provision of law shall be construed to limit the authority of the United States to terminate or limit
such authorization.
An allowance allocated by the Administrator under the Acid Rain Program does not constitute a
property right.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 37
Nitrogen Oxides Requirements
The owners and operators of the source and each affected unit at the source shall comply with the applicable
Acid Rain emissions limitation for nitrogen oxides.
Excess Emissions Requirements
(1) The designated representative of an affected unit that has excess emissions in any calendar year shall
submit a proposed offset plan to the Administrator of the U. S. EPA, as required under 40 CFR part 77.
(2) The owners and operators of an affected unit that has excess emissions in any calendar year shall:
(i) Pay without demand, to the Administrator of the U. S. EPA, the penalty required, and pay upon
demand the interest on that penalty, as required by 40 CFR part 77; and
(ii) Comply with the terms of an approved offset plan, as required by 40 CFR part 77.
Recordkeeping and Reporting Requirements
(1) Unless otherwise provided, the owners and operators of the source and each affected unit at the source
shall keep on site at the source each of the following documents for a period of 5 years from the date the
document is created. This period may be extended for cause, at any time prior to the end of 5 years, in
writing by the Administrator or the Division:
(i) The certificate of representation for the designated representative for the source and each affected
unit at the source and all documents that demonstrate the truth of the statements in the certificate of
representation, in accordance with 40 CFR 72.24; provided that the certificate and documents shall
be retained on site at the source beyond such 5 -year period until such documents are superseded
because of the submission of a new certificate of representation changing the designated
representative;
(ii) All emissions monitoring information, in accordance with 40 CFR part 75, provided that to the
extent that 40 CFR part 75 provides for a 3 -year period for recordkeeping, the 3 -year period shall
apply.
(iii) Copies of all reports, compliance certifications, and other submissions and all records made or
required under the Acid Rain Program; and,
(iv) Copies of all documents used to complete an Acid Rain permit application and any other
submission under the Acid Rain Program or to demonstrate compliance with the requirements of the
Acid Rain Program.
(2) The designated representative of an affected source and each affected unit at the source shall submit the
reports and compliance certifications required under the Acid Rain Program, including those under 40
CFR part 72 subpart I and 40 CFR part 75.
Liability
(1) Any person who knowingly violates any requirement or prohibition of the Acid Rain Program, a
complete Acid Rain permit application, an Acid Rain permit, or an exemption under 40 CFR 72.7 or
72.8, including any requirement for the payment of any penalty owed to the United States, shall be
subject to enforcement pursuant to section 113(c) of the Federal Clean Air Act.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 38
(2) Any person who knowingly makes a false, material statement in any record, submission, or report under
the Acid Rain Program shall be subject to criminal enforcement pursuant to section 113(c) of the Federal
Clean Air Act and 18 U.S.C. 1001.
No permit revision shall excuse any violation of the requirements of the Acid Rain Program that occurs
prior to the date that the revision takes effect.
Each affected source and each affected unit shall meet the requirements of the Acid Rain Program.
Any provision of the Acid Rain Program that applies to an affected source (including a provision
applicable to the designated representative of an affected source) shall also apply to the owners and
operators of such source and of the affected units at the source.
(6) Any provision of the Acid Rain Program that applies to an affected unit (including a provision
applicable to the designated representative of an affected unit) shall also apply to the owners and
operators of such unit.
Each violation of a provision of 40 CFR parts 72, 73, 74, 75, 76, 77, and 78 by an affected source or
affected unit, or by an owner or operator or designated representative of such source or unit, shall be a
separate violation of the Federal Clean Air Act.
Effect on Other Authorities
No provision of the Acid Rain Program, an Acid Rain permit application, an Acid Rain permit, or an exemption
under 40 CFR 72.7, 72.8 or 72.14 shall be construed as:
(1) Except as expressly provided in title IV of the Federal Clean Air Act, exempting or excluding the
owners and operators and, to the extent applicable, the designated representative of an affected source or
affected unit from compliance with any other provision of the Federal Clean Air Act, including the
provisions of title I of the Federal Clean Air Act relating to applicable National Ambient Air Quality
Standards or State Implementation Plans;
(2) Limiting the number of allowances a unit can hold; provided, that the number of allowances held by the
unit shall not affect the source's obligation to comply with any other provisions of the Federal Clean Air
Act;
Requiring a change of any kind in any State law regulating electric utility rates and charges, affecting
any State law regarding such State regulation, or limiting such State regulation, including any prudence
review requirements under such State law;
(4) Modifying the Federal Power Act or affecting the authority of the Federal Energy Regulatory
Commission under the Federal Power Act; or,
(5) Interfering with or impairing any program for competitive bidding for power supply in a State in which
such program is established.
4. Reporting Requirements
Pursuant to 40 CFR Part 75.64 quarterly reports and compliance certification requirements shall be submitted to
the Administrator within 30 days after the end of the calendar quarter. The contents of these reports shall meet
the requirements of 40 CFR 75.64.
(7)
(3)
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 39
Revisions to this permit shall be made in accordance with 40 CFR Part 72, Subpart H, §§ 72.80 through 72.85
(as adopted by reference in Colorado Regulation 18). Permit modification requests shall be submitted to the
Division at the address identified in Appendix D.
Changes to the Designated Representative or Alternate Designated Representative shall be made in accordance
with 40 CFR 72.23.
5. Comments, Notes and Justifications
Combustion Turbines CT -01 and CT -02 burn natural gas as the primary fuel, with distillate oil used as back-up.
The NOx limitations in 40 CFR Part 76 are only applicable to coal-fired utility units and thus do not apply to
CT -01 and CT -02.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 40
SECTION IV - Permit Shield
Regulation No. 3, 5 CCR 1001-5, Part C, §§ I.A.4, V.D. & XIII.B; § 25-7-114.4(3)(a), C.R.S.
1. Specific Non -Applicable Requirements
Based on the information available to the Division and supplied by the applicant, the following
parameters and requirements have been specifically identified as non -applicable to the facility to which
this permit has been issued. This shield does not protect the source from any violations that occurred
prior to or at the time of permit issuance. In addition, this shield does not protect the source from any
violations that occur as a result of any modifications or reconstruction on which construction
commenced prior to permit issuance.
No requirements have been specifically identified as non -applicable to this facility.
2. General Conditions
Compliance with this Operating Permit shall be deemed compliance with all applicable requirements
specifically identified in the permit and other requirements specifically identified in the permit as not
applicable to the source. This permit shield shall not alter or affect the following:
2.1 The provisions of §§ 25-7-112 and 25-7-113, C.R.S., or § 303 of the federal act, concerning
enforcement in cases of emergency;
2.2 The liability of an owner or operator of a source for any violation of applicable requirements
prior to or at the time, of permit issuance;
2.3 The applicable requirements of the federal Acid Rain Program, consistent with § 408(a) of the
federal act;
2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to
§25-7-111(2)(I), C.R.S.; or the ability of the Administrator to obtain information pursuant to §
114 of the federal act;
2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit for cause
pursuant to Regulation No. 3, Part C, § XIII.
2.6 Sources are not shielded from terms and conditions that become applicable to the source
subsequent to permit issuance.
3. Stream -lined Conditions
The following applicable requirements have been subsumed within this operating permit using the
pertinent streamlining procedures approved by the U.S. EPA. For purposes of the permit shield,
compliance with the listed permit conditions will also serve as a compliance demonstration for purposes
of the associated subsumed requirements.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 41
Permit Condition '` "[Streamlined (Subsiinied) Requirements ','
Turbines
Section II, Condition 1.3.2
Regulation No. 1, Section VI.B.4.c.(ii) [5O2 emissions not to exceed 0.35 lb/MMBtu]
Section II, Condition 1.3.2
Regulation No. 6, Part B, Section II.D.3.b [5O2 emissions not to exceed 0.35 lb/MMBtu],
State -only Requirement
Water Bath Gas Heater (WBGH)
Section 11, Condition 3.1
Colorado Regulation No. 6, Part B, Section II.C.2 [Particulate matter emissions not to exceed
0.5(FI)-°26 where FI = fuel input in MMBtu/hr], State -only Requirement
Section II, Condition 3.6
Colorado Regulation No. 6, Part B, Section II.C.3 [Emissions of particulate matter shall not
exceed 20% opacity], State -only Requirement
Emergency Fire Pump Engine
Section II, Condition 4.3.3
Colorado Regulation No.1, Section VI.B.4.b.(i) [SO2 emissions shall not exceed 0.8 lb/MMBtu
of heat input.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 42
SECTION V - General Permit Conditions (ver 5/22/2012)
1. Administrative Changes
Regulation No. 3,'5 CCR 1001-5, Part A, § III.
The permittee shall submit an application for an administrative permit amendment to the Division for those permit changes
that are described in Regulation No. 3, Part A, § 1.8.1. The permittee may immediately make the change upon submission of
the application to the Division.
2. Certification Requirements
Regulation No. 3, 5 CCR 1001-5, Part C, §§ III.B.9., V.C.16.a.& e. and V.C.17.
a. Any application, report, document and compliance certification submitted to the Air Pollution Control Division
pursuant to Regulation No. 3 or the Operating Permit shall contain a certification by a responsible official of the
truth, accuracy and completeness of such form, report or certification stating that, based on information and belief
formed after reasonable inquiry, the statements and information in the document are true, accurate and complete.
b. All compliance certifications for terms and conditions in the Operating Permit shall be submitted to the Air Pollution
Control Division at least annually unless a more frequent period is specified in the applicable requirement or by the
Division in the Operating Permit.
c. Compliance certifications shall contain:
(i) the identification of each permit term and condition that is the basis of the certification;
(ii) the compliance status of the source;
(iii) whether compliance was continuous or intermittent;
(iv) method(s) used for determining the compliance status of the source, currently and over the reporting
period; and
(v) such other facts as the Air Pollution Control Division may require to determine the compliance status of the
source.
d. All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental
Protection Agency at the addresses listed in Appendix D of this Permit.
e. If the permittee is required to develop and register a risk management plan pursuant to § 112(r) of the federal act, the
permittee shall certify its compliance with that requirement; the Operating Permit shall not incorporate the contents
of the risk management plan as a permit term or condition.
3. Common Provisions
Common Provisions Regulation, 5 CCR 1001-2 §§ ILA., ILB., ILC., II.E., II.F., II.I, and II.I
a. To Control Emissions Leaving Colorado
When emissions generated from sources in Colorado cross the State boundary line, such emissions shall not cause
the air quality standards of the receiving State to be exceeded, provided reciprocal action is taken by the receiving
State.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 43
b. Emission Monitoring Requirements
The Division may require owners or operators of stationary air pollution sources to install, maintain, and use
instrumentation to monitor and record emission data as a basis for periodic reports to the Division.
c.
Performance Testing.
The owner or operator of anyair pollution source shall, upon request of the Division, conduct performance test(s)
and furnish the Division a written report of the results of such test(s) in order to determine compliance with
applicable emission control regulations.
Performance test(s) shall be conducted and the data reduced in accordance with the applicable reference test
methods unless the Division:
(i) specifies or approves, in specific cases, the use of a test method with minor changes in methodology;
(ii) approves the use of an equivalent method;
(iii) approves the use of an alternative method the results of which the Division has determined to be adequate
for indicating where a specific source is in compliance; or
•
(iv) waives the requirement for performance test(s) because the owner or operator of a source has demonstrated
by other means to the Division's satisfaction that the affected facility is in compliance with the standard.
Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to
require testing under the Colorado Revised Statutes, Title 25, Article 7, and pursuant to regulations
promulgated by the Commission.
Compliance test(s) shall be conducted under such conditions as the Division shall specify to the plant operator based
on representative performance of the affected facility. The owner or operator shall make available to the Division
such records as may be necessary to determine the conditions of the performance test(s). Operations during period of
startup, shutdown, and malfunction shall not constitute representative conditions of performance test(s) unless
otherwise specified in the applicable standard.
The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance
test to afford the Division the opportunity to have an observer present. The Division may waive the thirty day notice
requirement provided that arrangements satisfactory to the Division are made for earlier testing.
The owner or operator of an affected facility shall provide, or cause to be provided, performance testing facilities as
follows:
Sampling ports adequate for test methods applicable to such facility;
Safe sampling platform(s);
Safe access to sampling platform(s); and
Utilities for sampling and testing equipment.
Each performance test shall consist of at least three separate runs using the applicable test method. Each run shall be
conducted for the time and under the conditions specified in the applicable standard. For the purpose of determining
compliance with an applicable standard, the arithmetic mean of results of at least three runs shall apply. In the event
that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of
forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other
circumstances beyond the owner or operator's control, compliance may, upon the Division's approval, be
determined using the arithmetic mean of the results of the two other runs.
Operating Permit 08OPWE311 Issued: DA'It
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 44
Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s) if so warranted.
d. Affirmative Defense Provision for Excess Emissions during Malfunctions
An affirmative defense to a claim of violation under these regulations is provided to owners and operators for civil
penalty actions for excess emissions during periods of malfunction. To establish the affirmative defense and to be
relieved of a civil penalty in any action to enforce an applicable requirement, the owner or operator of the facility
must meet the notification requirements below in a timely manner and prove by a preponderance of evidence that:
(i)
The excess emissions were caused by a sudden, unavoidable breakdown of equipment, or a sudden,
unavoidable failure of a process to operate in the normal or usual manner, beyond the reasonable control of
the owner or operator;
(ii) The excess emissions did not stem from any activity or event that could have reasonably been foreseen and
avoided, or planned for, and could not have been avoided by better operation and maintenance practices;
(iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being
exceeded;
(iv) The amount and duration of the excess emissions (including any bypass) were minimized to the maximum
extent practicable during periods of such emissions;
(v) All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air
quality;
(vi) All emissions monitoring systems were kept in operation (if at all possible);
(vii) The owner or operator's actions during the period of excess emissions were documented by properly
signed, contemporaneous operating logs or other relevant evidence;
(viii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation, or
maintenance;
(ix) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions.
This section is intended solely to be a factor in determining whether an affirmative defense is available to
an owner or operator, and shall not constitute an additional applicable requirement; and
(x) During the period of excess emissions, there were no exceedances of the relevant ambient air quality
standards established in the Commissions' Regulations that could be attributed to the emitting source.
The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division
verbally as soon as possible, but no later than noon of the Division's next working day, and shall submit written
notification following the initial occurrence of the excess emissions by the end of the source's next reporting period.
The notification shall address the criteria set forth above.
The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief.
The Affirmative Defense Provision does not apply to failures to meet federally promulgated performance standards
or emission limits, including, but not limited to, new source performance standards and national emission standards
for hazardous air pollutants. The affirmative defense provision does not apply to state implementation plan (sip)
limits or permit limits that have been set taking into account potential emissions during malfunctions, including, but
not necessarily limited to, certain limits with 30 -day or longer averaging times, limits that indicate they apply during
malfunctions, and limits that indicate they apply at all times or without exception.
Operating Permit 08OPWE311 Issued: DATE;
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 45
e. Circumvention Clause
A person shall not build, erect, install, or use any article, machine, equipment, condition, or any contrivance, the use
of which, without resulting in a reduction in the total release of air pollutants to the atmosphere, reduces or conceals.
an emission which would otherwise constitute a violation of this regulation. No person shall circumvent this
regulation by using more openings than is considered normal practice by the industry or activity in question.
Compliance Certifications
For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in
violation of any standard in the Colorado State Implementation Plan, nothing in the Colorado State Implementation
Plan shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether
a source would have been in compliance with applicable requirements if the appropriate performance or compliance
test or procedure had been performed. Evidence that has the effect of making any relevant standard or permit term
more stringent shall not be credible for proving a violation of the standard or permit term.
When compliance or non-compliance is demonstrated by a test or procedure provided by permit or other applicable
requirement, the owner or operator shall be presumed to be in compliance or non-compliance unless other relevant
credible evidence overcomes that presumption.
Affirmative Defense Provision for Excess Emissions During Startup and Shutdown
An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during
periods of startup and shutdown. To establish the affirmative defense and to be relieved of a civil penalty in any
action to enforce an applicable requirement, the owner or operator of the facility must meet the notification
requirements below in a timely manner and prove by a preponderance of the evidence that:
g
(i)
The periods of excess emissions that occurred during startup and shutdown were short and infrequent and
could not have been prevented through careful planning and design;
(ii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation or
maintenance;
(iii) If the excess emissions were caused by a bypass (an intentional diversion of control equipment), then the
bypass was unavoidable to prevent loss of life, personal injury, or severe property damage;
(iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum
extent practicable;
(v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality;•
(vi) All emissions monitoring systems were kept in operation (if at all possible);
(vii) The owner or operator's actions during the period of excess emissions were documented by properly
signed, contemporaneous operating logs or other relevant evidence; and,
(viii) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions.
This subparagraph is intended solely to be a factor in determining whether an affirmative defense is
available to an owner or operator, and shall not constitute an additional applicable requirement.
The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the
Division verbally as soon as possible, but no later than two (2) hours after the start of the next working day, and shall
submit written quarterly notification following the initial occurrence of the excess emissions. The notification shall
address the criteria set forth above.
The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief.
Operating Permit 08OPWE311
Issued: DATE •
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 46
The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements
that derive from new source performance standards or national emissions standards for hazardous air pollutants, or
any other federally enforceable performance standard or emission limit with an averaging time greater than twenty-
four hours. In addition, an affirmative defense cannot be used by a single source or small group of sources where
the excess emissions have the potential to cause an exceedance of the ambient air quality standards or Prevention of
Significant Deterioration (PSD) increments.
In making any determination whether a source established an affirmative defense, the Division shall consider the
information within the notification required above and any other information the Division deems necessary, which
may include, but is not limited to, physical inspection of the facility and reviewof documentation pertaining to the
maintenance and operation of process and air pollution control equipment.
4. Compliance Requirements
Regulation No. 3, 5 CCR 1001-5, Part C 55 III.C.9. V.C.11. & 16.d. and 5 25-7-122.1(2), C.R.S.
a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to
federally -enforceable terms or conditions constitutes a violation of the federal act, as well as the state act and
Regulation No. 3. Any permit noncompliance relating to state -only terms or conditions constitutes a violation of the
state act and Regulation No. 3, shall be enforceable pursuant to state law, and shall not be enforceable by citizens
under § 304 of the federal act. Any such violation of the federal act, the state act or regulations implementing either
statute is grounds for enforcement action, for permit termination, revocation and reissuance or modification or for
denial of a permit renewal application.
6. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a
permit termination, revocation or modification action or action denying a permit renewal application thatit would
have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of
the permit.
c. The permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of any request by
the permittee for a permit modification, revocation and reissuance, or termination, or any notification of planned
changes or anticipated noncompliance does not stay any permit condition, except as provided in §§ X. and XI. of
Regulation No. 3, Part C.
d. The permittee shall furnish to the Air Pollution Control Division, within a reasonable time as specified by the
Division, any information that the Division may request in writing to determine whether cause exists for modifying,
revoking and reissuing, or terminating the permit or to determine compliance with the permit. Upon request, the
permittee shall also furnish to the Division copies of records required to be kept by the permittee, including
information claimed to be confidential. Any information subject to a claim of confidentiality shall be specifically
identified and submitted separately from information not subject to the claim.
e. Any schedule for compliance for applicable requirements with which the source is not in compliance at the time of
permit issuance shall be supplemental, and shall not sanction noncompliance with, the applicable requirements on
which it is based.
f. For any compliance schedule for applicable requirements with which the source is not in compliance at the time of
permit issuance, the permittee shall submit, at least every 6 months unless a more frequent period is specified in the
applicable requirement or by the Air Pollution Control Division, progress reports whichcontain the following:
(i)
dates for achieving the activities, milestones, or compliance required in the schedule for compliance, and
dates when such activities, milestones, or compliance were achieved; and
(ii) an explanation of why any dates in the schedule of compliance were not or will not be met, and any
preventive or corrective measures adopted.
Operating Permit 08OPWE311 Issued: DATIl
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 47
g. The permittee shall not knowingly falsify, tamper with, or render inaccurate any monitoring device or method
required to be maintained or followed under the terms and conditions of the Operating Permit.
5. Emergency Provisions
Regulation No. 3, 5 CCR 1001-5, Part C, & VII.E
An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the
source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that
causes the source to exceed the technology -based emission limitation under the permit due to unavoidable increases in
emissions attributable to the emergency. "Emergency" does not include noncompliance to the extent caused by improperly
designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. An emergency
constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology -based emission
limitation if the permittee demonstrates, through properly signed, contemporaneous operating logs, or other relevant evidence
that:
a. an emergency occurred and that the permittee can identify the cause(s) of the emergency;
b. the permitted facility was at the time being properly operated;
c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that
exceeded the emission standards, or other requirements in the permit; and
d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the
next working day following the emergency, and followed by written notice within one month of the time when
emissions limitations were exceeded due to the emergency. This notice must contain a description of the
emergency, any steps taken to mitigate emissions, and corrective actions taken.
This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement.
6. Emission Controls for Asbestos
Regulation No. 8, 5 CCR 1001-10, Part B
The permittee shall not conduct any asbestos abatement activities except in accordance with the provisions of Regulation No.
8, Part B, "asbestos control."
7. Emissions Trading, Marketable Permits, Economic Incentives
Regulation No. 3, 5 CCR 1001-5, Part C, & V.C.13.
No permit revision shall be required under any approved economic incentives, marketable permits, emissions trading and
other similar programs or processes for changes that are specifically provided for in the permit.
8. Fee Payment
C.R.S $& 25-7-114.1(6) and 25-7-114.7
a. The permittee shall pay an annual emissions fee in accordance with the provisions of C.R.S. § 25-7-114.7. A 1%
per month late payment fee shall be assessed against any invoice amounts not paid in full on the 91st day after the
date of invoice, unless a permittee has filed a timely protest to the invoice amount.
b. The permittee shall pay a permit processing fee in accordance with the provisions of C.R.S. § 25-7-114.7. If the
Division estimates that processing of the permit will take more than 30 hours, it will notify the permittee of its
estimate of what the actual charges may be prior to commencing any work exceeding the 30 hour limit.
Operating Permit 08OPWE311 Issued: DAT"F
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 48
c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S. § 25-7-114.1(6) for each APEN or
revised APEN filed.
9. Fugitive Particulate Emissions
Regulation No. 1, 5 CCR 1001-3, § III.D.1.
The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate
emissions into the atmosphere, in accordance with the provisions of Regulation No. 1, § III.D.1.
10. Inspection and Entry
Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.16.b.
Upon presentation of credentials and other documents as may be required by law, the permittee shall allow the Air Pollution
Control Division, or any authorized representative, to perform the following:
a. enter upon the permittee's premises where an Operating Permit source is located, or emissions -related activity is
conducted, or where records must be kept under the terms of thepermit;
b. have access to, and copy, at reasonable times, any records that must be kept under the conditions of the permit;
c. inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment),
practices, or operations regulated or required under the Operating Permit;
d. sample or monitor at reasonable times, for the purposes of assuring compliance with the Operating Permit or
applicable requirements, any substances or parameters.
11. Minor Permit Modifications
Regulation No. 3, 5 CCR 1001-5, Part C, §§ X. & XI.
The permittee shall submit an application for a minor permit modification before making the change requested in the
application. The permit shield shall not extend to minor permit modifications.
12. New Source Review
Regulation No. 3, 5 CCR 1001-5, Part B
The permittee shall not commence construction or modification of a source required to be reviewed under the New Source
Review provisions of Regulation No. 3, Part B, without first receiving a construction permit.
13. No Property Rights Conveyed
Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.1 l.d.
This permit does not convey any property rights of any sort, or any exclusive privilege.
14. Odor
Regulation No. 2, 5 CCR. 1001-4, Part A
As a matter of state law only, the permittee shall comply with the provisions of Regulation No. 2 concerning odorous
emissions.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 49
15. Off -Permit Changes to the Source
Regulation No. 3, 5 CCR 1001-5, Part C, XII.B.
The permittee shall record any off -permit change to the source that causes the emissions of a regulated pollutant subject to an
applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from the change, including
any other data necessary to show compliance with applicable ambient air quality standards. The permittee shall provide
contemporaneous notification to the Air Pollution Control Division and to the Environmental Protection Agency at the
addresses listed in Appendix D of this Permit. The permit shield shall not apply to any off -permit change.
16. Opacity
Regulation No. 1, 5 CCR 1001-3. 66 I.; II.
The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1, §§ I.- II.
17. Open Burning
Regulation No. 9, 5 CCR 1001-11
The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions
of Regulation No. 9.
18. Ozone Depleting Compounds
Regulation No. 15, 5 CCR 1001-17
The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds.
Sections I., II.C., lID., III. IV., and V. of Regulation No. 15 shall be enforced as a matter of state law only.
19. Permit Expiration and Renewal
Regulation No. 3, 5 CCR 1001-5, Part C, 66 III.B.6., IV.C., V.C.2.
a. The permit term shall be five (5) years. The permit shall expire at the end of its term. Permit expiration terminates
the permittee's right to operate unless a timely and complete renewal application is submitted.
b. Applications for renewal shall be submitted at least twelve months, but not more than 18 months, prior to the
expiration of the Operating Permit. An application for permit renewal may address only those portions of the permit
that require revision, supplementing, or deletion, incorporating the remaining permit terms by reference from the
previous permit. A copy of any materials incorporated by reference must be included with the application.
20. Portable Sources
Regulation No. 3, 5 CCR 1001-5, Part C, 6 II.D.
Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in
location.
21. Prompt Deviation Reporting
Regulation No. 3, 5 CCR 1001-5, Part C, 6 V.C.7.b.
The permittee shall promptly report any deviation from permit requirements, including those attributable to malfunction
conditions as defined in the permit, the probable cause of such deviations, and any corrective actions or preventive measures
taken.
"Prompt" is defined as follows:
Operating Permit 08OPWE311 Issued: DATI:i.
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 50
a. Any definition of "prompt" or a specific timeframe for reporting deviations provided in an underlying applicable
requirement as identified in this permit; or
b. Where the underlying applicable requirement fails to address the time frame for reporting deviations, reports of
deviations will be submitted based on the following schedule:
(i)
For emissions of a hazardous air pollutant or a toxic air pollutant (as identified in the applicable regulation)
that continue for more than an hour in excess of permit requirements, the report shall be made within 24
hours of the occurrence;
(ii) For emissions of any regulated air pollutant, excluding a hazardous air pollutant or a toxic air pollutant that
continue for more than two hours in excess of permit requirements, the report shall be made within 48
hours; and
(iii) For all other deviations from permit requirements, the report shall be submitted every six (6) months,
except as otherwise specified by the Division in the permit in accordance with paragraph 22.d. below.
If any of the conditions in paragraphs b.i or b.ii above are met, the source shall notify the Division by telephone
(303-692-3155) or facsimile (303-782-0278) based on the timetables listed above. [Explanatory note: Notification
by telephone or facsimile must speck that this notification is a deviation report for an Operating Permit] A
written notice, certified consistent with General Condition 2.a. above (Certification Requirements), shall be
submitted within 10 working days of the occurrence. All deviations reported under this section shall also be
identified in the 6 -month report required above.
"Prompt reporting" does not constitute an exception to the requirements of "Emergency Provisions" for the purpose of
avoiding enforcement actions.,
22. Record Keeping and Reporting Requirements
Regulation No. 3, 5 CCR 1001-5, Part A, & II.; Part C, 5&. V.C.6., V.C.7.
a. Unless otherwise provided in the source specific conditions of this Operating Permit, the permittee shall maintain
compliance monitoring records that include the following information:
(i) date, place as defined in the Operating Permit, and time of sampling or measurements;
(ii) date(s) on which analyses were performed;
(iii) the company or entity that performed the analysis;
(iv) the analytical techniques or methods used;
(v) the results of such analysis; and
(vi) the operating conditions at the time of sampling or measurement.
b. The permittee shall retain records of all required monitoring data and support information for a period of at least five
(5) years from the date of the monitoring sample, measurement, report or application. Support information, for this
purpose, includes all calibration and maintenance records and all original strip -chart recordings for continuous
monitoring instrumentation, and copies of all reports required by the Operating Permit. With prior approval of the
Air Pollution Control Division, the permittee may maintain any of the above records in a computerized form.
c. Permittees must retain records of all required monitoring data and support information for the most recent twelve
(12) month period, as well as compliance certifications for the past five (5) years on -site at all times. A permittee
shall make available for the Air Pollution Control Division's review all other records of required monitoring data
and support information required to be retained by the permittee upon 48 hours advance notice by the Division.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 51
d. The permittee shall submit to the Air Pollution Control Division all reports of any required monitoring at least every
six (6) months, unless an applicable requirement, the compliance assurance monitoring rule, or the Division requires
submission on a more frequent basis. All instances of deviations from any permit requirements must be clearly
identified in such reports.
e. The permittee shall file an Air Pollutant Emissions Notice ("APEN") prior to constructing, modifying, or altering
any facility, process, activity which constitutes a stationary source from which air pollutants are or are to be emitted,
unless such source is exempt from the APEN filing requirements of Regulation No. 3, Part A, § II.D. A revised
APEN shall be filed annually whenever a significant change in emissions; as defined in Regulation No. 3, Part A, §
II.C.2., occurs; whenever there is a change in owner or operator of any facility, process, or activity; whenever new
control equipment is installed; whenever a different type of control equipment replaces an existing type of control
equipment; whenever a permit limitation must be modified; or before the APEN expires. An MEN is valid for a
period of five years. The five-year period recommences when a revised APEN is received by the Air Pollution
Control Division. Revised APENs shall be submitted no later than 30 days before the five-year term expires.
Permittees submitting revised APENs to inform the Division of a change in actual emission rates must do so by
April 30 of the following year. Where a permit revision is required, the revised APEN must be filed along with a
request for permit revision. APENs for changes in control equipment must be submitted before the change occurs.
Annual fees are based on the most recent APEN on file with the Division.
23. Reopenings for Cause
Regulation No. 3, 5 CCR 1001-5, Part C, § XIII.
a. The Air Pollution Control Division shall reopen, revise, and reissue Operating Permits; permit reopenings and
reissuance shall be processed using the procedures set forth in Regulation No. 3, Part C, § III., except that
proceedings to reopen and reissue permits affect only those parts of the permit for which cause to reopen exists.
6. The Division shall reopen a permit whenever additional applicable requirements become applicable to a major
source with a remaining permit term of three or more years, unless the effective date of the requirements is later than
the date on which the permit expires, or unless a general permit is obtained to address the new requirements;
whenever additional requirements (including excess emissions requirements) become applicable to an affected
source under the acid rain program; whenever the Division determines the permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other terms or conditions of the permit;
or whenever the Division determines that the permit must be revised or revoked to assure compliance with an
applicable requirement.
c. The Division shall provide 30 days' advance notice to the permittee of its intent to reopen the permit, except that a
shorter notice maybe provided in the case of an emergency.
d. The permit shield shall extend to those parts of the permit that have been changed pursuant to the reopening and
reissuance procedure.
24. Section 502(6)(10) Changes
Regulation No. 3, 5 CCR 1001-5, Part C, § XII.A.
The permittee shall provide a minimum 7 -day advance notification to the Air Pollution Control Division and to the
Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permittee shall attach a copy of
each such notice given to its Operating Permit.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 52
25. Severability Clause
Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.10.
In the event of a challenge to any portion of the permit, all emissions limits, specific and general conditions, monitoring,
record keeping and reporting requirements of the permit, except those being challenged, remain valid and enforceable.
26. Significant Permit Modifications
Regulation No. 3, 5 CCR 1001-5, Part C, § I1I.8.2.
The permittee shall not make a significant modification required to be reviewed under Regulation No. 3, Part B
("Construction Permit" requirements) without first receiving a construction permit. The permittee shall submit a complete
Operating Permit application or application for an Operating Permit revision for any new or modified source within twelve
months of commencing operation, to the address listed in Item 1 in Appendix D of this permit. If the permittee chooses to
use the "Combined Construction/Operating Permit" application procedures of Regulation No. 3, Part C, then the Operating
Permit must be received prior to commencing construction of the new or modified source.
27. Special Provisions Concerning the Acid Rain Program
Regulation No. 3, 5 CCR 1001-5, Part C, §§ V.C.1.b. & 8
a. Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations
promulgated under Title IV of the federal act, 40 Code of Federal Regulations (CFR) Part 72, both provisions shall
be incorporated into the permit and shall be federally enforceable.
b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal act or the
regulations promulgated thereunder, 40 CFR Part 72, are expressly prohibited.
28. Transfer or Assignment of Ownership
Regulation No. 3, 5 CCR 1001-5, Part C. § II.C.
No transfer or assignment of ownership of the Operating Permit source will be effective unless the prospective owner or
operator applies to the Air Pollution Control Division on Division -supplied Administrative Permit Amendment forms, for
reissuance of the existing Operating Permit. No administrative permit shall be complete until a written agreement containing
a specific date for transfer of permit, responsibility, coverage, and liability between the permittee and the prospective owner
or operator has been submitted to the Division.
29. Volatile Organic Compounds
Regulation No. 7, 5 CCR 1001-9, §§ III & V.
The requirements in paragraphs a, b and e apply to sources located in an ozone non -attainment area or the Denver 1 -hour
ozone attainment/maintenance area. The requirements in paragraphs c and d apply statewide.
a. All storage tank gauging devices, anti -rotation devices, accesses, seals, hatches, roof drainage systems, support
structures, and pressure relief valves shall be maintained and operated to prevent detectable vapor loss except when
opened, actuated, or used for necessary and proper activities (e.g. maintenance). Such opening, actuation, or use
shall be limited so as to minimize vapor loss.
Detectable vapor loss shallbe determined visually, by touch, by presence of odor, or using a portable hydrocarbon
analyzer. When an analyzer is used, detectable vapor loss means a VOC concentration exceeding 10,000 ppm.
Testing shall be conducted as in Regulation No. 7, Section VIII.C.3.
Except when otherwise provided by Regulation No. 7, all volatile organic compounds, excluding petroleum liquids,
transferred to any tank, container, or vehicle compartment with a capacity exceeding 212 liters (56 gallons), shall be
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 08OPWE311
Spindle Hill Energy, LLC
Spindle Hill Energy Center
Page 53
transferred using submerged or bottom filling equipment. For top loading, the fill tube shall reach within six inches
of the bottom of the tank compartment. For bottom -fill operations, the inlet shall be flush with the tank bottom.
c. The permittee shall not dispose of volatile organic compounds by evaporation or spillage unless Reasonably
Available Control Technology (RACT) is utilized.
d. No owner or operator of a bulk gasoline terminal, bulk gasoline plant, or gasoline dispensing facility as defined in
Colorado Regulation No. 7, Section VI, shall permit gasoline to be intentionally spilled, discarded in sewers, stored
in open containers, or disposed of in any other manner that would result in evaporation.
e. Beer production and associated beer container storage and transfer operations involving volatile organic compounds
with a true vapor pressure of less than 1.5 PSIA actual conditions are exempt from the provisions of paragraph b,
above.
30. Wood Stoves and Wood burning Appliances
Regulation No. 4, 5 CCR 1001-6
The permittee shall comply with the provisions of Regulation No. 4 concerning the advertisement, sale, installation, and use
of wood stoves and wood burning appliances.
Operating Permit08OPWE3ii Issued: DATE;
Air Pollution Control Division
Colorado Operating Permit
Appendices
OPERATING PERMIT APPENDICES
A - INSPECTION INFORMATION
B - MONITORING AND PERMIT DEVIATION REPORT
C - COMPLIANCE CERTIFICATION REPORT
D - NOTIFICATION ADDRESSES
E - PERMIT ACRONYMS
F - PERMIT MODIFICATIONS
*DISCLAIMER:
None of the information found in these Appendices shall be considered to be State or
Federally enforceable, except as otherwise provided in the permit, and is presented to assist
the source, permitting authority, inspectors, and citizens.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Inspection Information
APPENDIX A - Inspection Information
1. Directions to Plant:
Take I-25 north to exit 235 (Ft Lupton/Hwy 52).
Exit highway and go east on Hwy 52 for 5.2 miles.
Turn north (left) on County Road 19.
Drive north 3/4 mile. Spindle Hill is on the left.
Appendix A
Page 55
2. Safety Equipment Required:
Eye Protection; Hard Hat; Safety Shoes; Hearing Protection
3. Facility Plot Plan:
Figure 1 and 2 on the following pages show the plot plan and facility layout as submitted in the April 9,
2008 Title V Operating Permit Application.
4. List of Insignificant Activities:
The following list of insignificant activities was provided by the source to assist in the understanding of
the facility layout. Since there is no requirement to update such a list, activities may have changed
since the last filing.
Small amounts of chemical storage in chemical lockers in O&M Building Warehouse.
Storage Tanks:
Description Size (gallons)
Fuel Oil Storage Tank - 750,000
Raw Water Tank 310,000
Demineralized Water Tank 750,000
Diesel Fire Pump Fuel Tank 240
Equipment Fuel Tank 240
Fuel Gas Drains Tank 300
Coalescing Filter Drains Tank A 150
Coalescing Filter Drains Tank B 150
Turbine Lube Oil Reservoir A 6,200
Turbine Lube Oil Reservoir B 6,200
Water Wash Drains Tank A 2,500
Water Wash Drains Tank B 2,500
False Start Drains Tank A 715
False Start Drains Tank B 715
Turbine Lube Oil Drums 6-55
Firewater Pump Engine (no longer insignificant activity).
Equipment Leaks.
Fuel Oil Loading.
Landscaping and Housekeeping Equipment.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Inspection Information
59
c
FIGURE I
FACILnV PLOT PUN
SPINDLE HILL ENERGY CENTER
FORT WPTON. COLORADO
Appendix A
Page 56
Air Pollution Control Division
Colorado Operating Permit
Inspection Information
FIGURE 2
FACILITY LAYOUT AND HEIGHTS
X=5092e9,42, Y = 443143539 (UTA7 NAD 83 Zorie'i3 North),
Description
Turbine Inlet
Turbine Inlet Building
Turbine Stack Building
O & M Building
O&M(2)
M & E Builtirg.
iF.O. Tank
D.W. Tank
Raw Water Tahiti
Turbine.(Unit 1 p
Turbine (Unit 2)
Gas Heater
Fire Pump
Label In Drawing
a
b
c
0 & M.Built)irt
o & M (2)
M & E Building
F.O. Tank
D.W. Tank
Raw Water Tank
Turbine_Unit_t
Turbine_Unit_2
Gas_Heater
Fire_Pump
150
Height (aql - meters)
20.73
14.02
10.06
6.096
10.868
5,486
14.3'
9.144
9.144
22.86
22.86
4,57
4.57
eo
Appendix A
Page 57
E
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
APPENDIX B
Reporting Requirements and Definitions
with codes ver 2/20/07
Appendix B
Page 58
Please note that, pursuant to 113(c)(2) of the federal Clean Air Act, any person who knowingly:
(A) makes any false material statement, representation, or certification in, or omits material information
from, or knowingly alters, conceals, or fails to file or maintain any notice, application, record, report,
plan, or other document required pursuant to the Act to be either filed or maintained (whether with
respect to the requirements imposed by the Administrator or by a State);
(B) fails to notify or report as required under the Act; or
(C) falsifies, tampers with, renders inaccurate, or fails to install any monitoring device or method
required to be maintained or followed under the Act shall, upon conviction, be punished by a fine
pursuant to title 18 of the United States Code, or by imprisonment for not more than 2 years, or both.
If a conviction of any person under this paragraph is for a violation committed after a first conviction
of such person under this paragraph, the maximum punishment shall be doubled with respect to both
the fine and imprisonment.
The permittee must comply with all conditions of this operating permit. Any permit noncompliance constitutes
a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance,
or modification; or for denial of a permit renewal application.
The Part 70 Operating Permit program requires three types of reports to be filed for all permits.
All required reports must be certified by a responsible official.
Report #1: Monitoring Deviation Report (due at least every six months)
For purposes of this operating permit, the Division is requiring that the monitoring reports are due every six
months unless otherwise noted in the permit. All instances of deviations from permit monitoring requirements
must be clearly identified in such reports.
For purposes of this operating permit, monitoring means any condition determined by observation, by data from
any monitoring protocol, or by any other monitoring which is required by the permit as well as the
recordkeeping associated with that monitoring. This would include, for example, fuel use or process rate
monitoring, fuel analyses, and operational or control device parameter monitoring.
Report #2: Permit Deviation Report (must be reported "promptly")
In addition to the monitoring requirements set forth in the permits as discussed above, each and every
requirement of the permit is subject to deviation reporting. The reports must address deviations from permit
requirements, including those attributable to malfunctions as defined in this Appendix, the probable cause of
Operating Permit 08OPWE311 Issued: DATI.
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Appendix B
Page 59
such deviations, and any corrective actions or preventive measures taken. All deviations from any term or
condition of the permit are required to be summarized or referenced in the annual compliance certification.
For purposes of this operating permit, "malfunction" shall refer to both emergency conditions and malfunctions.
Additional discussion on these conditions is provided later in this Appendix.
For purposes of this operating permit, the Division is requiring that the permit deviation reports are due as set
forth in General Condition 21. Where the underlying applicable requirement contains a definition of prompt or
otherwise specifies a time frame for reporting deviations, that definition or time frame shall govern. For
example, quarterly Excess Emission Reports required by an NSPS or Regulation No. I, Section IV.
In addition to the monitoring deviations discussed above, included in the meaning of deviation for the purposes
of this operating permit are any of, the following:
(1) A situation where emissions exceed an emission limitation or standard contained in the permit;
(2) A situation where process or control device parameter values demonstrate that an emission limitation or
standard contained in the permit has not been met;
(3) A situation in which observations or data collected demonstrates noncompliance with an emission
limitation or standard or any work practice or operating condition required by the permit; or,
(4) A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance
Assurance Monitoring (CAM) Rule) has occurred. (only if the emission point is subject to CAM)
For reporting purposes, the Division has combined the Monitoring Deviation Report with the Permit Deviation
Report. All deviations shall be reported using the following codes:
1 = Standard:
2 = Process:
3 = Monitor:
4 = Test:
5 = Maintenance:
6 = Record:
7 = Report:
8=CAM:
9 = Other:
When the requirement is an emission limit or standard
When the requirement is a production/process limit
When the requirement is monitoring
When the requirement is testing
When required maintenance is not performed
When the requirement is recordkeeping
When the requirement is reporting
A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the
Compliance Assurance Monitoring (CAM) Rule) has occurred.
When the deviation is not covered by any of the above categories
Report #3: Compliance Certification (annually, as defined in the permit)
Submission of compliance certifications with terms and conditions in the permit, including emission limitations,
standards, or work practices, is required not less than annually.
Compliance Certifications are intended to state the compliance status of each requirement of the permit over the
certification period. They must be based, at a minimum, on the testing and monitoring methods specified in the
Operating Permit 08OPWE311 Issued: DA fl
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Appendix B
Page 60
permit that were conducted during the relevant time period. In addition, if the owner or operator knows of other
material information (i.e. information beyond required monitoring that has been specifically assessed in relation
to how the information potentially affects compliance status), that information must be identified and addressed
in the compliance certification. The compliance certification must include the following:
• The identification of each term or condition of the permit that is the basis of the certification;
• Whether or not the method(s) used by the owner or operator for determining the compliance status with
each permit term and condition during the certification period was the method(s) specified in the permit.
Such methods and other means shall include, at a minimum, the methods and means required in the
permit. If necessary, the owner or operator also shall identify any other material information that must
be included in the certification to comply with section 113(c)(2) of the Federal Clean Air Act, which
prohibits knowingly making a false certification or omitting material information;
• The status of compliance with the terms and conditions of the permit, and whether compliance was
continuous or intermittent. The certification shall identify each deviation and take it into account in the
compliance certification. Note that not all deviations are considered violations.
• Such other facts as the Division may require, consistent with the applicable requirements to which the
source is subject, to determine the compliance status of the source.
The Certification shall also identify as possible exceptions to compliance any periods during which compliance
is required and in which an excursion or exceedance as defined under 40 CFR Part 64 (the Compliance
Assurance Monitoring (CAM) Rule) has occurred. (only for emission points subject to CAM)
Note the requirement that the certification shall identify each deviation and take it into account in the
compliance certification. Previously submitted deviation reports, including the deviation report submitted at the
time of the annual certification, may be referenced in the compliance certification.
For example, given the various emissions limitations and monitoring requirements to which a source may be
subject, a deviation from one requirement may not be a deviation under another requirement which recognizes
an exception and/or special circumstances relating to that same event.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Appendix B
Page 61
Startup, Shutdown, Malfunctions and Emergencies
Understanding the application of Startup, Shutdown, Malfunctions and Emergency Provisions, is very important
in both the deviation reports and the annual compliance certifications.
Startup, Shutdown, and Malfunctions
Please note that exceedances of some New Source Performance Standards (NSPS) and Maximum Achievable
Control Technology (MACT) standards that occur during Startup, Shutdown or Malfunctions may not be
considered to be non-compliance since emission limits or standards often do not apply unless specifically stated
in the NSPS. Such exceedances must, however, be reported as excess emissions per the NSPS/MACT rules and
would still be noted in the deviation report. In regard to compliance certifications, the permittee should be
confident of the information related to those deviations when making compliance determinations since they are
subject to Division review. The concepts of Startup, Shutdown and Malfunctions also exist for Best Available
Control Technology (BACT) sources, but are not applied in the same fashion as for NSPS and MACT sources.
Emergency Provisions
Under the Emergency provisions of Part 70 certain operational conditions may act as an affirmative defense
against enforcement action if they are properly reported.
DEFINITIONS
Malfunction (NSPS) means any sudden, infrequent, and not reasonably preventable failure of air pollution
control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are
caused in part by poor maintenance or careless operation are not malfunctions.
Malfunction (SIP) means any sudden and unavoidable failure of air pollution control equipment or process
equipment or unintended failure of a process to operate in a normal or usual manner. Failures that are primarily
caused by poor maintenance, careless operation, or any other preventable upset condition or preventable
equipment breakdown shall not be considered malfunctions.
Emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of
the source, including acts of God, which situation requires immediate corrective action to restore normal
operation, and that causes the source to exceed a technology -based emission limitation under the permit, due to
unavoidable increases in emissions attributable to the emergency. An emergency shall not include
noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance,
careless or improper operation, or operator error.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Monitoring and Permit Deviation Report - Part I
Appendix B
Page 62
1. Following is the required format for the Monitoring and Permit Deviation report to be submitted to the
Division as set forth in General Condition 21. The Table below must be completed for all equipment or
processes for which specific Operating Permit terms exist.
2. Part II of this Appendix B shows the format and information the Division will require for describing
periods of monitoring and permit deviations, or malfunction or emergency conditions as indicated in the
Table below. One Part II Form must be completed for each Deviation. Previously submitted reports
(e.g. EER's or malfunctions) may be referenced and the form need not be filled out in its entirety.
FACILITY NAME: Spindle Hill Energy, LLC - Spindle Hill Energy Center
OPERATING PERMIT NO: 08OP W E311
REPORTING PERIOD: (see first page of the permit for specific reporting period and dates)
Operating Permit Unit
ID
Unit Description
Deviations not
During Periode
Deviation Code 2
Malfunction/Emergenc
y Condition Reported
During Period?
YES
NO
-
YES
NO
CT -01
General Electric simple -cycle
combustion turbine, Model GE 7FA,
Serial No. 297986, driving a 145 MW
electric power generator.
CT -02
General Electric simple -cycle
combustion turbine, Model GE 7FA,
Serial No. 297987, driving a 145 MW
electric power generator.
EU 003
One (I) GTS Energy natural gas fired
Water Bath Gas Heater, Model ISNG-
HWB8.3s5x, Serial No. PC06035, heat
input rated at 11.1 MMBtu/hr.
Fire Pump Engine
One (I) Clarke, Model VFMP-T6HT,
Serial No. 91B02978, distillate fuel oil
fired internal combustion engine, site -
rated at 145 HP and 1.96 MMBtu/hr
General Conditions
a.s
Insignificant Activities
See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation has occurred
shall be based on a reasonable inquiry using readily available information.
2 Use the following entries, as appropriate
1 = Standard:
2 = Process:
When the requirement is an emission limit or standard
When the requirement is a production/process limit
Operating Permit 08OPWE311
Issued: DATI
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
3 = Monitor:
4 = Test:
5 = Maintenance:
6 = Record:
7 = Report:
8 = CAM:
9 = Other:
Appendix B
Page 63
When the requirement is monitoring
When the requirement is testing
When required maintenance is not performed
When the requirement is recordkeeping
When the requirement is reporting
A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the
Compliance Assurance Monitoring (CAM) Rule) has occurred.
When the deviation is not covered by any of the above categories
Operating Permit 08OPWE311 Issued: DAIL
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Monitoring and Permit Deviation Report - Part II
FACILITY NAME: Spindle Hill Energy, LLC - Spindle Hill Energy Center
OPERATING PERMIT NO: 08OP WE311
REPORTING PERIOD:
Appendix B
Page 64
Is the deviation being claimed as an: Emergency Malfunction N/A
(For NSPS/MACT) Did the deviation occur during: Startup
OPERATING PERMIT UNIT IDENTIFICATION:
Operating Permit Condition Number Citation
Explanation of Period of Deviation
Duration (start/stop date & time)
Normal Operation
Action Taken to Correct the Problem
Measures Taken to Prevent a Reoccurrence of the Problem
Dates of Malfunctions/Emergencies Reported (if applicable)
Deviation Code Division Code QA:
Shutdown Malfunction
SEE EXAMPLE ON THE NEXT PAGE
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
FACILITY NAME: Acme Corp.
OPERATING PERMIT NO: 96OPZZXXX
REPORTING PERIOD: 1/1/04 - 6/30/06
Is the deviation being claimed as an:
Appendix B
Page 65
EXAMPLE
Emergency Malfunction XX N/A
(For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction
Normal Operation
OPERATING PERMIT UNIT IDENTIFICATION:
Asphalt Plant with a Scrubber for Particulate Control - Unit XXX
Operating Permit Condition Number Citation
Section II, Condition 3.1 - Opacity Limitation
Explanation of Period of Deviation
Slurry Line Feed Plugged
Duration
START- 17304/10/06
END- 1800 4/10/06
Action Taken to Correct the Problem
Line Blown Out
Measures Taken to Prevent Reoccurrence of the Problem
Replaced Line Filter
Dates of Malfunction/Emergencies Reported (if applicable)
5/30/06 to J. Garcia, APCD
Deviation Code Division Code QA:
Operating Permit 08OPWE311 Issued: DATI..
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Monitoring and Permit Deviation Report - Part III
Appendix B
Page 66
REPORT CERTIFICATION
SOURCE NAME: Spindle Hill Energy, LLC - Spindle Hill Energy Center
FACILITY IDENTIFICATION NUMBER: 123/5468
PERMIT NUMBER: 08OPWE311
REPORTING PERIOD: (see first page of the permit for specific reporting period and dates)
All information for the Title V Semi -Annual Deviation Reports must be certified by a responsible official as
defined in Colorado Regulation No. 3, Part A, Section I.B.38. This signed certification document must be
packaged with the documents being submitted.
STATEMENT OF COMPLETENESS
I have reviewed the information being submitted in its entirety and, based on information and belief
formed after reasonable inquiry, I certify that the statements and information contained in this submittal
are true, accurate and complete.
Please note that the Colorado Statutes state that any person who knowingly, as defined in Sub -Section 18-
1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is
guilty of a misdemeanor and may be punished in accordance with the provisions of Sub -Section 25-7
122.1, C.R.S.
Printed or Typed Name Title
Signature of Responsible Official Date Signed
Note: Deviation reports shall be submitted to the Division at the address given in Appendix D of this
permit. No copies need be sent to the U.S. EPA.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix C
Page 67
APPENDIX C
Required Format for Annual Compliance Certification Reports
Following is the format for the Compliance Certification report to be submitted to the Division and the U.S.
EPA annually based on the effective date of the permit. The Table below must be completed for all equipment
or processes for which specific Operating Permit terms exist.
FACILITY NAME: Spindle Hill Energy, LLC - Spindle Hill Energy Center
OPERATING PERMIT NO: 08OP WE311
REPORTING PERIOD:
I. Facility Status
_ During the entire reporting period, this source was in compliance with ALL terms and conditions contained
in the Permit, each term and condition of which is identified and included by this reference. The method(s)
used to determine compliance is/are the method(s) specified in the Permit.
With the possible exception of the deviations identified in the table below, this source was in compliance
with all terms and conditions contained in the Permit, each term and condition of which is identified and
included by this reference, during the entire reporting period. The method used to determine compliance for
each term and condition is the method specified in the Permit, unless otherwise indicated and described in the
deviation report(s). Note that not all deviations are considered violations.
Operating
p g
Permit
Unit ID
Unit Description
Deviations
Reported
Monitoring
Method per
Permit?z
Was compliance continuous or
intermittent?'
Previous
Current
YES
NO
Continuous
Intermittent
CT -01
General Electric simple -cycle
combustion turbine, Model
GE 7FA, Serial No. 297986,
driving a 145 MW electric
power generator.
CT -02
General Electric simple -cycle
combustion turbine, Model
GE 7FA, Serial No. 297987,
driving a 145 MW electric
power generator. •
EU 003
One (I) GTS Energy natural
gas fired Water Bath Gas
Heater, Model ISNG-
HWB8.3s5x, Serial No.
PC06035, heat input rated at
11.1 MMBtu/hr..
Fire
Pump
Engine
One (1) Clarke, Model
VFMP-T6HT, Serial No.
91B02978, distillate fuel oil
fired internal combustion
Operating Permit 08OPWE311
Issued: )Art.
Air Pollution Control Division
Colorado Operating Permit ,
Compliance Certification Report
Appendix C
Page 68
Operating
Permit
Unit ID
Unit Description
Deviations
Reported
Monitoring
Methodzper
Permit
was compliance continuous or
intermittent?3
Previous
Current
YES
NO
Continuous
Intermittent
engine, site -rated at 145 HP
and 1.96 MMBtu/hr
General Conditions
Insignificant Activities 4
If deviations were noted in a previous deviation report , put an "X" under "previous". If deviations were noted in the current
deviation report (i.e. for the last six months of the annual reporting period), put an "X" under "current". Mark both columns if both
apply.
2 Note whether the method(s) used to determine the compliance status with each term and condition was the method(s) specified in the
permit. If it was not, mark "no" and attach additional information/explanation.
3 Note whether the compliance status with each term and condition provided was continuous or intermittent. "Intermittent
Compliance" can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance
only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance
has occurred.
NOTE:
The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the
absence of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance
for the duration of the reporting period. Therefore, if a source 1) conducts all of the monitoring and recordkeeping required in its
permit, even if such activities are done periodically and not continuously, and if 2) such monitoring and recordkeeping does not
indicate non-compliance, and if 3) the Responsible Official is not aware of any credible evidence that indicates non-compliance, then
the Responsible Official can certify that the emission point(s) in question were in continuous compliance during the applicable time
period.
4 Compliance status for these sources shall be based on a reasonable inquiry using readily available information.
II. Status for Accidental Release Prevention Program:
A. This facility is subject is not subject to the provisions of the Accidental
Release Prevention Program (Section 112(r) of the Federal Clean Air Act)
B. If subject: The facility . is is not in compliance with all the
requirements of section 112(r).
1. A Risk Management Plan will be has been submitted to the
appropriate authority and/or the designated central location by the required date.
III. Certification
All information for the Annual Compliance Certification must be certified by a responsible official as defined in
Colorado Regulation No. 3, Part A, Section I.B.38. This signed certification document must be packaged with
the documents being submitted.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix C
Page 69
I have reviewed this certification in its entirety and, based on information and belief formed after
reasonable inquiry, I certify that the statements and information contained in this certification are true,
accurate and complete.
Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1-501(6),
C.R.S., makes any false material statement, representation, or certification in this document is guilty of a
misdemeanor and may be punished in accordance with the provisions of § 25-7 122.1, C.R.S.
Printed or Typed Name Title
Signature Date Signed
NOTE: All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection
Agency at the addresses listed in Appendix D of this Permit.
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Notification Addresses
Appendix D
Page 70
APPENDIX D
Notification Addresses
1. Air Pollution Control Division
Colorado Depattutent of Public Health and Environment
Air Pollution Control Division
Operating Permits Unit
APCD-SS-B 1
4300 Cherry Creek Drive S.
Denver, CO 80246-1530
ATTN: Man Burgett
2. United States Environmental Protection Agency
Compliance Notifications:
Office of Enforcement, Compliance and Environmental Justice
Mail Code 8ENF-T
U.S. Environmental Protection Agency, Region VIII
1595 Wynkoop Street
Denver, Colorado 80202-1129
Permit Modifications, Off Permit Changes:
Office of Partnerships and Regulatory Assistance
Air and Radiation Programs, 8P -AR
U.S. Environmental Protection Agency, Region VIII
1595 Wynkoop Street
Denver, Colorado 80202-1129
Operating Permit 08OPWE311 Issued: DATIi.
Air Pollution Control Division
Colorado Operating Permit
Permit Acronyms
Appendix E
Page 71
APPENDIX E
Permit Acronyms
Listed Alphabetically:
AIRS - Aerometric Information Retrieval System
AP -42 - EPA Document Compiling Air Pollutant Emission Factors
APEN - Air Pollution Emission Notice (State of Colorado)
APCD - Air Pollution Control Division (State of Colorado)
ASTM - American Society for Testing and Materials
BACT - Best Available Control Technology
BTU - British Thermal Unit
CAA - Clean Air Act (CAAA = Clean Air Act Amendments)
CCR - Colorado Code of Regulations
CEM - Continuous Emissions Monitor
CF - Cubic Feet (SCF = Standard Cubic Feet)
CFR - Code of Federal Regulations
CO - Carbon Monoxide
COM - Continuous Opacity Monitor
CRS - Colorado Revised Statute
EF - Emission Factor
EPA - Environmental Protection Agency
FI - Fuel Input Rate in Lbs/mmBtu
FR - Federal Register
G - Grams
Gal - Gallon
GPM - Gallons per Minute
HAPs - Hazardous Air Pollutants
HP - Horsepower
HP -HR - Horsepower Hour (G/HP-HR = Grams per Horsepower Hour)
LAER - Lowest Achievable Emission Rate
LBS - Pounds
M - Thousand
MM - Million
MMscf - Million Standard Cubic Feet
MMscfd - Million Standard Cubic Feet per Day
N/A or NA - Not Applicable
NOx - Nitrogen Oxides
NESHAP - . National Emission Standards for Hazardous Air Pollutants
NSPS - New Source Performance Standards
P - Process Weight Rate in Tons/Hr
PE - Particulate Emissions
PM - Particulate Matter
PM10 - Particulate Matter Under 10 Microns
Operating Permit 08OPWE311 Issued: DATL.
Air Pollution Control Division
Colorado Operating Permit
Permit Acronyms
Appendix E
Page 72
PSD - Prevention of Significant Deterioration
PTE - Potential To Emit
RACT - Reasonably Available Control Technology
SCC - Source Classification Code
SCF - Standard Cubic Feet
SIC - Standard Industrial Classification
SO2 - Sulfur Dioxide
TPY - Tons Per Year
TSP - Total Suspended Particulate
VOC - Volatile Organic Compounds
Operating Permit 08OPWE311 Issued: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit Modifications
Appendix H
Page 73
APPENDIX F
Permit Modifications
DATE OF
REVISION
TYPE OF
REVISION
SECTION NUMBER,
CONDITION NUMBER
DESCRIPTION OF REVISION
Operating Permit 08OPWE311
Issued: DATE
TECHNICAL REVIEW DOCUMENT
For
PROPOSED DRAFT OPERATING PERMIT 08OPWE311
Spindle Hill Energy, LLC
Weld County
Source ID 1235468
March 2012 — August 2013
Operating Permit Engineer:
Operating Permit Supervisor review:
Field Services (or Oil and Gas) Unit review:
Joshua Jones
Mathew Burgett
Jeremy Neustifter
Purpose
This document establishes the basis for decisions made regarding the Applicable
Requirements, Emission Factors, Monitoring Plan and Compliance Status of Emission
Units covered within the Operating Permit proposed for Spindle Hill Energy, LLC. This
document is designed for reference during the review of the proposed permit by the
EPA, the public, and other interested parties.
Conclusions made in this report are based on information provided by the applicant in
the Title V permit application submitted on April 8, 2008, comments on the draft permit
submitted on [DATE], previous inspection reports and various email correspondence, as
well as review of Division files. This narrative is intended only as an adjunct for the
reviewer and has no legal standing.
Any revisions made to the underlying construction permits associated with this facility,
made in conjunction with the processing of this operating permit application, have been
reviewed in accordance with the requirements of Regulation No. 3, Part B, Construction
Permits, and have been found to meet all applicable substantive and procedural
requirements. This operating permit incorporates and shall be considered to be a
combined construction/operating permit for any such revision, and the permittee shall
be allowed to operate under the revised conditions upon issuance of this operating
permit without applying for a revision to this permit or for an additional or revised
construction permit.
II. Description of Source
The Spindle Hill Energy Center is a peaking utility electric power generation facility
classified under Standard Industrial Classification code 4911. The significant emission
units at the facility include two (2) GE 7FA simple -cycle combustion turbines, a natural
gas fired water bath gas heater (WBGH) used to heat natural gas before firing in the
turbines, a fuel oil storage tank, and an emergency fire pump engine. Each turbine has
an electrical gross power output of 145 MW and is capable of running on either natural
gas or fuel oil.
This facility is located approximately 4 miles west of Ft Lupton, Colorado at 6335
County Road 19 (West of Co Rd 19 and North of Co Rd 14), in Weld County, This area
123/5468 Page 1 of 21
Spindle Hill Energy, LLC
Operating Permit No. 080PW E311
Technical Review Document — Initial Operating Permit
is classified as non -attainment for ozone and is located in the 8 -hr Ozone Control Area
as defined in Colorado Regulation No.7, Section II.A.1.
There are no affected states within 50 miles of the facility. Rocky Mountain National
Park and the Rawah Wilderness Area are Federal Class I designated areas within 100
kilometers of the facility.
Based on information provided by the applicant, this facility is categorized as a NANSR
major stationary source (Potential to Emit of NOx >100 tons/year in a non -attainment
area for ozone) and a PSD minor stationary source (Potential to Emit < 250 tons/year
for all criteria pollutants).
An analysis of the potential to emit (PTE) of NOx and CO emissions from insignificant
activities was required to be completed because the facility -wide potential to emit for
permitted sources at this facility for these pollutants is within 10% of the limit for PSD
major source status.
Based on information provided by the applicant, this facility is not subject to the
provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal
Clean Air Act).
Potential emissions (in tons/yr) at the facility are as follows:
WBGH-01
111.65
111.65
7.44
8.85 111.7
8.85 111.7
8.00
single/
15.00
total
The single largest HAP emitted during natural gas firing is formaldehyde. The single largest HAP
emitted during fuel oil firing is Manganese.
2Emissions based on manufacturer emission factors submitted with application, except SO2 emission
factors based on 0.8 gr/100 scf and assuming 92% of S converted to SO2. H2S04 are estimated to be
13.3% of SO2 emission rate. Emissions are based on fuel heating values of 1020 Btu/scf for natural gas
and 140,000 Btu/gal for fuel oil.
3Emissions based on permitted (maximum potential) fuel limit and emission factors from the vendor. All
emission factors are more conservative than AP -42, except PM/PM12.
4Emissions based on permitted throughput and EPA Tanks 4.0 run.
5Emissions based on vendor emission factors and 500 hours operating time.
123/5468
Page 2 of 21
Spindle Hill Energy, LLC
Operating Permit No. 08OPW E311
Technical Review Document — Initial Operating Permit
A breakdown of individual HAP emissions for the turbines and the WBGH is given on
page 21 of this document. All HAP emissions for the fuel oil storage tank and the
firewater pump engine are below de minimus levels.
The startup dates for the turbines at this facility are as follows:
CT -01 — Initial Startup 4/6/2007, Commercial Operation 4/8/2007
CT -02 —Initial Startup 4/20/2007, Commercial Operation 4/21/2007
Actual emissions for the turbines for 2010 were reported with an APEN submitted in
April 2011 and are as shown in the table below:
VI
58.34
15.15
3.15
3.15
0.96
1.1
56.72
0.56
13.7
5.64
5.64
0.85
115.06
1.66
28.85
8.79
8.79
1.81
III. Applicable Requirements
40 CFR 60 Subpart Dc — Standards of Performance for Small Industrial -Commercial -
Institutional Steam Generating Units
A new APEN was submitted for the WBGH on September 17, 2012 that revised the
heat input rate from 9.0 MMBtu/hr to 11.1 MMBtu/hr. NSPS Subpart Dc applies to each
steam generating unit that commenced construction, modification, or reconstruction
after June 9, 1989 and has a maximum design heat input capacity of 100 MMBtu/hr or
less, but greater than or equal to 10 MMBtu/hr (40 CFR 60, §60.40c(a)). As defined in
this subpart, a steam generating unit is a device that combusts any fuel and produces
steam or heats water or heats any heat transfer medium. The WBGH uses water as a
heat transfer medium that in turn heats the gas lines feeding into the turbines. The
WBGH is therefore subject to NSPS Subpart Dc. This heater will only be subject to
recordkeeping and notification requirements since it burns only natural gas.
40 CFR 60 Subpart Kb — Standards of Performance for Volatile Organic Liquid Storage
Vessels (including Petroleum Liquid Storage Vessels) for Which Construction
Reconstruction, or Modification Commenced After July 23, 1984
The distillate fuel oil storage tank at this facility has a capacity of 750,000 gallons and a
vapor pressure of 0.0031 psia as determined by the EPA Tanks 4.0 run submitted with
the Operating Permit application. Therefore, this tank is exempt from this subpart per
§60.110b(b) as the tank total capacity is ≥ 150 m3 (approximately 39,600 gallons) and it
is used to store a liquid with a maximum true vapor pressure < 3.5 kPa (approximately
0.5 psia).
40 CFR 60 Subpart IIII — Standards of Performance for Stationary Compression Ignition
Internal Combustion Engines
123/5468 Page 3 of 21
Spindle Hill Energy, LLC
Operating Permit No. 08OPWE311
Technical Review Document — Initial Operating Permit
A firewater pump engine was included in Attachment A (equipment details) of the initial
approval construction permit issued on March 23, 2006 and is included in the
insignificant activity list submitted with the operating permit application. In an email
correspondence received September 6, 2012, the source stated that the firewater pump
engine at this facility was ordered from the manufacturer (i.e. commenced construction)
on August 2, 2006 and was manufactured after July 1, 2006; therefore it is subject to
NSPS Subpart 1111 (per §60.4200(a)(2)(ii)). With the promulgation of Subpart 1111 on July
11, 2006, this engine could no longer be considered an insignificant activity according to
Colorado Regulation No. 3, Part C, Section II.E. In addition, with the adoption of
Subpart 1111 into Colorado Regulation No. 6, Part A, on October 18, 2007, this engine
became subject to APEN reporting and minor source permitting requirements according
to Colorado Regulation No. 3, Section II.D. Since this engine can no longer be
considered an insignificant activity, the applicable requirements have been included in
Section II of the operating permit. Subpart IIII requirements include emission limitations
for NOx, CO and particulate matter, as well as fuel requirements for sulfur content.
Final revisions to NSPS Subpart IIII have been published in the Federal Register on
January 30, 2013, and will become effective 60 days after publishing. The revisions
applicable to this facility are related to the fuel use requirements of §60.4207(b) and the
emergency engine provisions of §60.4211(f). These revisions were made to make
NSPS Subpart IIII consistent with the RICE MACT, and do not change the fundamental
requirements of these provisions as related to this facility. The conditions associated
with these provisions will be updated before issuance of the operating permit if the
published rule becomes effective prior to the date of permit issuance.
40 CFR 60 Subpart KKKK - Standards of Performance for Stationary Combustion
Turbines
The stationary combustion turbines at this facility were constructed after February 18,
2005 and have a heat input rate at peak load greater than 10 MMBtu/hr. These turbines
are therefore subject to Subpart KKKK. These turbines are exempt from the
requirements of 40 CFR Subpart GG because they are regulated under Subpart KKKK
(40 CFR 60, §60.4305). §60.4350(c) was not included in the operating permit
requirements for Subpart KKKK. This condition specifies that correction of measured
NOx concentrations to 15% 02 is not allowed, however, the standards for the turbines in
Table 1 are for NOx concentrations (in ppm) at 15% 02. This was apparently an error
that has been corrected in the proposed revision of Subpart KKKK published in the
Federal Register on August 29, 2012 (77 FR 52554) that specifies that correction of
NOx concentration to 15% 02 is only allowed if you elect to comply with the ppm
standard in Table 1. The requirements of Subpart KKKK will be updated according to
the current promulgated version before issuance if the operating permit is issued after
the effective date of the revised version of the regulation, or upon renewal of the
operating permit, if the permit is issued before the effective date.
Although not specifically indicated in the NSPS Subpart KKKK provisions, the Division
has determined that the NSPS standards are not applicable during startup, shutdown,
and malfunction, although any excess emissions during these periods must be reported
with the semi-annual excess emission reports. The preamble to the final rule (71 FR
38497, published July 6, 2006) indicates that the limitations are not applicable during
startup, shutdown and malfunction; "While continuous compliance is not required,
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Technical Review Document — Initial Operating. Permit
excess emissions during startup, shutdown, and malfunction must be reported" (page
38488). In addition, according to §60.8(c) of the General Provisions (40 CFR 60
Subpart A), "Operations during periods of startup, shutdown, and malfunction shall not
constitute representative conditions for the purpose of a performance test nor shall
emissions in excess of the level of the applicable emission limit during periods of
startup, shutdown, and malfunction be considered a violation of the applicable emission
limit unless otherwise specified in the applicable standard". Therefore, the Division has
added notes to the permit to specify that the NOx limits of NSPS KKKK do not apply
during startup, shutdown, and malfunction; however, exceedances during those periods
must be reported in the excess emissions monitoring report as specified in §60.4375(a).
40 CFR 63 Subpart ZZZZ — National Emissions Standards for Hazardous Air Pollutants
for Stationary Reciprocating Internal Combustion. Engines
The firewater pump engine at this facility is subject to the requirements for new
stationary compression ignition RICE (commenced construction after June 12, 2006)
located at area sources of HAP emissions. New and reconstructed stationary
compression ignition RICE at area sources must meet the requirements of Subpart
ZZZZ by meeting the requirements of 40 CFR 60 Subpart 1111 (40 CFR 63
§63.6590(c)(1)).
40 CFR 63 Subpart JJJJJJ -National Emission Standards for Hazardous Air Pollutants
for Industrial, Commercial, and Institutional Boilers at Area Sources
The WBGH at this facility is exempt from the requirements of Subpart JJJJJJ per
§63.11195(e), since it is a gas -fired boiler, as defined in §63.11237.
40 CFR 72 Acid Rain Program (ARP)
This facility is subject to the Acid Rain Program since it is a new utility unit per
§73.6(a)(3)(i), and does not meet the exemption of paragraph §73.6(b)(1) (commenced
commercial operation after November 15, 1990).
Compliance Assurance Monitoring (CAM) Applicability
CAM applies to any emission unit that is subject to an emission limitation, uses a control
device to achieve compliance with that emission limitation and has potential pre -control
emissions greater than major source levels. The turbines are equipped with dry low
NOx (DLN) combustion systems and when burning distillate oil, the turbines utilize water
injection to reduce NOx emissions. DLN combustion systems are considered inherent
process equipment and therefore are not control devices as defined in 40 CFR Part 64
§ 64.1, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV.
However, the Division considers that water injection is a control device. Nevertheless
because the Title V permit specifies a continuous monitoring method for NOx the
turbines are not subject to the CAM requirements as provided for in 40 CFR Part 64
§64.2(b)(vi), as adopted by reference in 'Colorado Regulation No. 3, Part C, Section
XIV.
Greenhouse Gases
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The potential -to -emit of greenhouse gas (GHG) emissions from this facility is greater
than 100,000 TPY CO2e. Future modifications greater than 75,000 tons per year CO2e
may be subject to regulation (Regulation No. 3, Part A, l.B.44).
Colorado Regulation No. 1 (5 CCR 1001-3) — Emission Control for Particulate Matter,
Smoke, Carbon Monoxide, and Sulfur Dioxides
The stationary combustion turbines at this facility are subject to Section III Particulate
Matter process based standards for fuel burning equipment. Particulate matter shall not
exceed 0.1 lb/MMBtu of heat input (Reg 1, Section III.A.1.c). These turbines are also
subject to the Section VI Sulfur Dioxide process based standards for new combustion
turbines. Sulfur Dioxide shall not be emitted in excess of 0.35 lb/MMBtu of heat input
(Reg 1, Section VI.B.4.c.(ii)).
The Water Bath Gas Heater (WBGH) at this facility is subject to the Section III
Particulate Matter process based standards for fuel burning equipment. Particulate
matter emissions shall not exceed 0.5(FI)-°26 where Fl = fuel input in MMBtu/hr (Reg
No. 1, Section III.A.1.b). The WBGH is also subject to the Part B, Section VI Sulfur
Dioxide process based standards. The source shall limit emissions of sulfur dioxide to
not more than two (2) tons per day (Reg No. 1, Section VI.B.5.a).
The Fire Pump Engine at this facility is subject to the process based standard of Section
VI.B.4.b.(i) for new oil fired operations. Oil fired units with a heat input of less than 250
MMBtu/hr shall reduce SO2 emissions to 0.8 lb/MMBtu of heat input.
Colorado Regulation No. 6 (5 CCR 1001-8) - Standards of Performance for New
Stationary Sources
The stationary combustion turbines at this facility are subject to the state -only Part B,
Section II standards for new fuel -burning equipment. Particulate matter emissions shall
not exceed 20% opacity (Reg 6, Part B, Section II.C.3). There are no process based
emission standards for particulate matter specified for sources with a fuel input capacity
of greater than 250 MMBtu/hr. Also, emissions of sulfur dioxide shall not exceed 0.35
lb/MMBtu of heat input (Reg 6, Part B, Section II.D.3.b).
The Water Bath Gas Heater is subject to the Part B, Section II process based emission
standards for new fuel -burning equipment: emissions of particulate matter shall not
exceed 0.5(FI)-°'26 where Fl = fuel input in MMBtu/hr (Reg 6, Part B, Section II.C.2);
emissions of particulate matter shall not exceed 20% opacity (Reg 6, Part B, Section
II.C.3).
IV. Emission Sources
Colorado Construction Permit 05WE0274 was issued as a facility -wide, initial approval
permit on March 23, 2006. A final approval correction construction permit was issued for
these emissions units on September 1, 2010. The final approval correction construction
permit is a facility -wide permit covering all equipment/activities at this facility.
A. Facility Wide Conditions
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Technical Review Document — Initial Operating Permit
1. Applicable Requirements: The appropriate provisions from the final approval
correction construction permit have been incorporated into the Title V Operating Permit
as follows:
• All previous versions of this permit are canceled upon issuance of this permit.
(Condition 1)
This condition is not a specific requirement and pertains only to the construction
permit; therefore, it was not included in the operating permit.
• AIRS Point ID numbers shall be marked on the subject equipment for ease of
identification. (Condition 2)
This condition is specific to construction permits, and has been completed as part
of the self -certification process. This condition was not included in the operating
permit.
• PSD requirements shall apply to this source at any such time that this source
becomes major for PSD solely by virtue of a relaxation in any permit condition.
(Condition 3)
This condition was not included in the operating permit since there are no actual
requirements that apply. The PSD status of the source is discussed in Section I,
Condition 3 of the operating permit.
• The applicant shall follow the most current operating and maintenance plan and
recordkeeping format approved by the Division in order to demonstrate
compliance on an ongoing basis with the requirements of this permit. (Condition
4)
The specific requirement to follow an operating and maintenance (O&M) plan is
not included in the operating permit. The components of the current O&M plan
include the operation of the GEMS to calculate and record emissions, fuel flow
rate, and operating parameters, the provision to follow 40 CFR Part 60, Subpart
A for notification, recordkeeping, and monitoring, and emissions calculation
methodologies for pollutants not directly monitored by the CEMS. These
components of the O&M plan are included in their respective portions of the
operating permit.
• Regulation No. 6, Part A, Subpart A — General Provisions apply (adopted by
reference) (part of Condition 5):
o At all times, the facility and control equipment shall, to the extent possible,
be maintained and operated in a manner consistent with good air pollution
control practices for minimizing emissions. Determination of whether or
not acceptable operating and maintenance procedures are being used will
be based on information available to the Division, which may include, but
is not limited to, monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection of the source.
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Operating Permit No. 08OPWE311
Technical Review Document - Initial Operating Permit
(Colorado Construction Permit 05WE0274 and 40 CFR 60 Subpart A
§60.11(d), as adopted by reference in Colorado Regulation No. 6, Part A)
o No article, machine, equipment or process shall be used to conceal an
emission that would otherwise constitute a violation of an applicable
standard. Such concealment includes, but is not limited to, the use of
gaseous diluents to achieve compliance with an opacity standard or with a
standard that is based on the concentration of a pollutant in the gases
discharged to the atmosphere. (§60.12)
o Written notification of construction and initial startup dates shall be
submitted to the Division as required under §60.7.
Notifications of construction and initial startup dates have already been
submitted to the Division. This portion of the General Provisions is not
included in the operating permit.
o Records of startups, shutdowns, and malfunctions shall be maintained, as
required under §60.7.
o Written notification of continuous monitoring system demonstrations shall
be submitted to the Division as required under §60.7.
o Excess Emission and Monitoring System Performance Reports shall be
submitted as required under §60.7.
o Performance tests shall be conducted as required under §60.8.
o Continuous monitoring systems shall be maintained and operated as
required under §60.13.
The applicable requirements from the NSPS General Provisions that have not
been fulfilled are included in the operating permit.
• This facilities fuel (natural gas and fuel oil) use rate and electric power generation
shall be limited by the emission limit/s specified in this permit (details in the
Applicable Requirements sections of the respective emission units below).
Compliance with the yearly consumption limits shall be determined on a rolling
twelve (12) month total. Monthly records of the actual fuel use rate/s and electric
power generation activities shall be maintained by the applicant and made
available to the Division for inspection upon request. After the first twelve (12)
months of operation, compliance with only the yearly limitation shall be required.
(Condition 6)
The current construction permit for this facility only specifies yearly fuel
consumption limitations, as this facility has been in operation for more than
twelve months. The facility has no specific designated limit on the amount of
electric power that can be generated, though it is implied through the fuel use
limit. The fuel limit requirements of this condition have been included in the
operating permit.
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Technical Review Document — Initial Operating Permit
• Total facility emissions of air pollutants shall not exceed the following limitations.
Compliance with the annual limits shall be determined on a rolling twelve (12)
month total. The permit holder shall calculate monthly emissions and keep a
compliance record on site for Division review (Condition 7):
o PM 70.00 tons/yr
o PMio 70.00 tons/yr
o NOx 223.30 tons/yr
o CO 223.40 tons/yr
o SO2 37.50 tons/yr
o VOC 17.70 tons/yr
o Sulfuric acid 5.00 tons/yr
o Any single HAP 8.00 tons/yr
o Total HAPs 15.00 tons/yr
The facility -wide emission limitations identified in the Final Approval Correction
Construction Permit (05WE0274) were initially based only on the requested fuel
throughput and corresponding emissions from the turbines. Additionally, recent
APEN updates for the WBGH requested increases in annual fuel throughput and
emissions, though the facility -wide emission limits remained the same. The
Division does not consider that an overall facility limit is appropriate or necessary
for this facility; therefore, separate criteria pollutant emission limits were set
(using the modification procedures in Regulation No. 3, Part C) for the turbines
(as a group) and the WBGH in order to more accurately characterize the facility's
emissions. The facility -wide potential to emit increased by the amounts
attributable to the WBGH and the fuel oil storage tank, due to the fact that these
were not originally included in the facility -wide emission limits. The criteria
pollutant emission limits established for individual units have been included in the
operating permit.
HAP emission limits were left as facility wide limits and have been included in the
operating permit under a facility wide section. '
• APEN reporting requirements. (Condition 9)
The APEN reporting requirements are included in Section IV (General
Conditions), Condition 22.e of the operating permit.
2. Emission Factors: The emission factors associated with the specified emission units
are included in their respective sections.
3. Monitoring: The monitoring requirements associated with the specified emission units
are included in their respective sections.
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4. Compliance Status: In the Title V permit application, the source indicated that the
facility was in compliance with all current applicable facility wide requirements.
B. CT -01: One (1) General Electric simple -cycle combustion turbine, Model GE 7FA,
Serial No. 297986, heat input rated at 1353.6 MMBtu/hr for natural gas and 1527
MMBtu/hr for fuel oil (for an ambient temperature of 50°F). This unit runs an
electric power generator and has a gross power output of 145 megawatts. This
unit is equipped with an advanced (4th generation) Dry Low NOx (DLN)
combustion system for minimization of emissions of NOx. NOx emissions are
controlled by water injection during fuel oil firing.
CT -02: One (1) General Electric simple -cycle combustion turbine, Model GE 7FA,
Serial No. 297987, heat input rated at 1353.6 MMBtu/hr for natural gas and 1527
MMBtu/hr for fuel oil (for an ambient temperature of 50°F). This unit runs an
electric power generator and has a gross power output of 145 megawatts. This
unit is equipped with an advanced (4th generation) Dry Low NOx (DLN)
combustion system for minimization of emissions of NOx. NOx emissions are
controlled by water injection during fuel oil firing.
1. Applicable Requirements: The appropriate provisions from the final approval
correction construction permit have been incorporated into the Title V Operating Permit
as follows:
• Regulation No. 6 — Standards of Performance for New Stationary Sources
(Condition 5):
o Part A, Subpart GG Standards of Performance for Stationary Gas
Turbines.
• Concentration of NOx shall not exceed 110 ppmvd at 15% O2 when
combusting natural gas, and shall not exceed 102 ppmvd at15°/0 O2
when combusting fuel oil
• Concentration of SO2 shall not exceed 150 ppmvd at 15% O2 or
sulfur content in fuel not to exceed 0.8% by weight
With the promulgation of 40 CFR Subpart KKKK on July 6, 2006 the
turbines at this facility became exempt from the requirements of Subpart
GG; therefore, Subpart GG requirements are not included in the operating
permit.
o Part A, Subpart KKKK — Standards of Performance for Stationary Gas
Turbines
No specific requirements from Subpart KKKK were included in the
construction permit, since at the time of permit issuance the Subpart had
not been promulgated. The appropriate requirements from Subpart KKKK
are included in the operating permit.
o Part B, Section II— Standards of Performance for New Fuel -Burning
Equipment (These are State -Only requirements)
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• D.3 - Combustion Turbines: Sulfur Dioxide discharged into the
atmosphere shall not be in excess of 0.35 pounds per MMBtu heat
input.
This requirement was streamlined with the NSPS KKKK limit on
sulfur content of fuel that is burned in the turbines of 0.06
lb/MMBtu. The record of the streamlined condition is included in
Section III of the operating permit.
Although not included in the construction permit, the turbines at this facility
are subject to the following requirements from Part B, Section II:
• Particulate matter emissions shall not exceed 20% opacity (Reg 6,
Part B, Section II.C.3)
• For each combustion turbine, a continuous emission monitoring system (GEMS)
shall be installed, maintained/calibrated, and operated to determine and record
the following (Condition 8):
o Combustion fuel (natural gas and fuel oil) flow rate.
o Concentration of NOx, ppmvd hourly average, in the exhaust, corrected to
15% Oxygen.
o Emissions of NOx (tons/month and tons/rolling 12 months).
o Concentration of carbon monoxide, ppmv hourly, in the exhaust.
o Emissions of carbon monoxide (tons/month and tons/rolling 12 months).
o Concentration of oxygen, percent, hourly average, in the exhaust.
o Commencement and end of startup events.
o Rate of water injection during fuel oil firing, and water -to -fuel oil ratio.
Quality assurance, quality control, and excess emission reporting shall conform
to the Division Document, "Guidelines for State -Only Required Continuous
Monitoring Systems in the State of Colorado". Provisions of 40 CFR 60, Subpart
A -General Provisions shall be followed for notification, recordkeeping, and
monitoring. The CEMS data shall be used to determine compliance with the
emissions limits for NOx and CO.
The references to quality assurance/quality control activities for the GEMS and
excess emission reporting have been changed to refer to portions of the federal
regulations specific to the pollutants being monitored, as opposed to the
Colorado state -only guidelines. This condition has been included in the
operating permit under the requirements for continuous emission monitoring.
• Fuel Consumption Limits (from Attachment A of the construction permit)
o Fuel consumption limits for both turbines together are as follows:
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Technical Review Document - Initial Operating Permit
11,328 MMscf/yr for natural gas (based on a heat value of 1020
Btu/scf)
11,110,743 gallons/yr of distillate fuel oil (based on a fuel oil
heating value of 140,000 Btu/gal)
• For a combination of natural gas and fuel oil: for each 1,000,000
gallons of fuel oil, consumption of natural gas shall be reduced by
1,040.614 MMscf.
The requirement to reduce the natural gas consumption limit when
burning fuel oil was changed to reflect that this reduction should be
done on a per gallon basis.
Sulfur content of fuel oil shall not exceed 0.05% by weight.
Although not specifically indentified in Colorado Construction Permit 05WE0274, the
turbines at this facility are subject to the following applicable requirements:
• Colorado Regulation No.1
o Except as provided in [Reg 1, Section II.A.4] below, no owner or operator
of a source should allow or cause the emission into the atmosphere of any
air pollutant that is in excess of 20% opacity. (Reg 1, Section II.A.1)
o No owner or operator of a source shall allow or cause to be emitted into
the atmosphere any air pollutant resulting from the building of a new fire,
cleaning of fire boxes, soot blowing, start-up, any process modification, or
adjustment or occasional cleaning of control equipment, which is in excess
of 30% opacity for a period or periods aggregating more than six minutes
in any sixty consecutive minutes. (Reg 1, Section II.A.4)
o Particulate matter emissions shall not exceed 0.1 lb/MMBtu of heat input
(Reg 1, Section III.A.1.c)
o Sulfur Dioxide shall not be emitted in excess of 0.35 lb/MMBtu of heat
input (Reg 1, Section VI.B.4.c.(ii)), calculated on a 3 -hour rolling average
(Reg 1, Section VI.B.2)
• Each turbine is also subject to the Acid Rain Program as follows:
o Acid rain permitting requirements per 40 CFR Part 72.
o Continuous emission monitoring requirements per 40 CFR Part 75.
o The sulfur dioxide allowance system (40 CFR Part 73) and excess
emissions (40 CFR Part 77).
o Allocated SO2 allowances are listed in 40 CFR Part 73.10(b), however,
since these are new units, no allowances were allocated. SO2 allowances
must be obtained per 40 CFR Part 73 to cover SO2 emissions for the
particular calendar year.
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o There are no NOx emission limitations since these units are not coal-fired
boilers.
Streamlining of Applicable Requirements
SO,
Regulation No. 1 (Section VI.B.4.c.(ii)) and Regulation No. 6 (Part B, Section II.D.3.b)
contain the same SO2 requirements; emissions of SO2 shall not exceed 0.35 lb/MMBtu.
The Regulation No. 6, Part B requirement is a state -only requirement. The NSPS
general provisions of 40 CFR Part 60, Subpart A are adopted by reference in Reg 6,
Part B, Section I.A.. 40 CFR 60 Subpart KKKK places a limit on the sulfur content of
fuel burned in the turbines of 0.060 lb/MMBtu (§60.4330(a)(2)). This limit is applicable
whether natural gas or fuel oil is burned in the turbines. Since this sulfur limit on fuel is
more stringent than both the Reg 1 and Reg 6 SO2 limits at all times, the Regulation No.
1 and Regulation No. 6, Part B SO2 requirements have been streamlined out of the
operating permit.
Opacity
The turbines at this facility are subject to the Reg 1 opacity requirements of 30% (Reg 1,
Section II.A.4), during certain operational activities, and 20% at all other times (Reg 1,
Section II.A.1). The turbines are also subject to the state -only Reg 6, Part B 20%
opacity requirement for particulate matter. The Reg 6 opacity requirement is not
applicable during periods of startup, shutdown, and malfunction, per 40 CFR 60 Subpart
A, §60.11(c) (adopted by reference in Reg 6, Part B, Section I.A). The Reg 1 20%130%
opacity requirements are more stringent than the Reg 6, Part B 20% opacity
requirement during periods of startup, shutdown, and malfunction, while the Reg 6
opacity requirement is more stringent during the operational activities of fire building,
cleaning of fire boxes, soot blowing, process modifications and adjustment or
occasional cleaning of control equipment. Therefore, since no one opacity requirement
is more stringent than any other at all times, all the opacity requirements are included in
the operating permit.
It should be noted that when the turbines burn natural gas as fuel, the Division will
presume, in the absence of credible evidence to the contrary, that these units are in
compliance with all of the opacity requirements. When the turbines are using fuel oil as
fuel: semi-annual opacity readings are required when any of the specific activities listed
in the Reg 1 Section II.A.4 provision (30% limit) are performed during the semi-annual
period; annual opacity readings are required to demonstrate compliance with the Reg 1,
Section II.A.1 provision (20% limit) for any annual period in which fuel oil is burned in
the turbines.
Note: In comments on the draft permit, received during source review, the source requested
that these opacity readings be required only after fuel oil runs lasting at least one hour, since
most runs on fuel oil are very brief, and would not allow for enough time to conduct a Method
9 observation. The Division concluded that this would suffice for the 20% opacity limit, since
this limit applies during normal operation of the source (i.e. not during events described in
Regulation No. 1, Section II.A.4) and opacity observations taken an hour into a fuel oil run
would still be representative of these operating conditions. However, the 30% opacity limit is
applicable during startup conditions for these units, so opacity observations taken to
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demonstrate compliance with this provision cannot be limited to those fuel oil runs lasting at
least one hour.
2. Emission Factors: NOx and CO emissions shall be determined using the continuous
emission monitoring system required by the construction permit. SO2 emissions shall
be determined using monitoring methods required by 40 CFR Part 75, Appendix D.
Emission factors to be used for PM/PM10, VOC, sulfuric acid, formaldehyde, and
manganese are listed in the table below.
NaturallGas
(Ib/MMBtu) ;<aw
0.002
0.002
0.0007
Fuel Oil,
..,...(Ib/MMBtu)
0.007
0.007
0.0004
0.0006
0.0003
0.0008
, Natural " s
bWMMBiu)
0.004
0.008
uel,Oii
0.004
0.0004
0.008
0.0004
0.0009
0.0003
0.0008
Formal
0.0001
0.0005
feganes '
Notes:
1) Fuel oil formaldehyde emission rate from AP -42, Table 3.1-4
2) Fuel of manganese emission rate from AP -42, Table 3.1-5
3) Unit 1 natural gas formaldehyde emission rate from November 5, 2009 Compliance test
4) All other emission rates from April 18 — May 9, 2007 Compliance Test
In order to calculate Total HAPs, emission factor ratios were developed from the AP -42
Tables 3.1-3, 3.1-4, and 3.1-5 emission factors to be applied to the calculated
formaldehyde emissions. These ratios were developed by taking the ratio of each
pollutant specific emission factor to that of formaldehyde (both from AP -42, for either
natural gas or fuel oil firing, as appropriate) and adding these together (according to
their respective fuel type) to represent the total amount of other HAPs emitted during
either natural gas or fuel oil firing. These emission factor ratios will be multiplied by the
emissions calculated for formaldehyde (using the emission factors above, either from
testing or AP -42), depending on what fuel the turbines are firing, in order to calculate
the total amount of other HAPs emitted. In this methodology, the ratio of HAPs emitted
during natural gas firing is the same as that according to the AP -42 emission factors,
but the mass of pollutants emitted is based on the unit specific formaldehyde emission
rate demonstrated by the compliance tests. The HAP emissions during fuel oil firing are
all calculated according to AP -42 emission rates.
Spindle Hill is still required to report individual HAPs over the de minimis levels for
APEN reporting and fee purposes.
3. Monitoring Plan: The source will be required to monitor compliance with the NOx
exhaust gas concentration limits of 40 CFR 60, Subpart KKKK (as well as the O2
concentration of the exhaust gases, to correct NOx emissions to 15% O2), the annual
NOx and CO emission limits, and the fuel consumption limits using the CEMS.
Compliance with the annual SO2 emission limit and the limit on the sulfur content of fuel
burned in the turbine will be monitored using the methods of 40 CFR 75, Appendix D.
Compliance with the PM, PM10, VOC, H2SO4, and HAPs emission limits will be
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monitored using the emission factors above and the fuel consumption from the turbines
as monitored using the GEMS.
Compliance with the opacity limits will be presumed, in absence of credible evidence to
the contrary, when natural gas is burned in the turbines. During fuel oil burning,
compliance with the opacity limits will be determined semi-annually using Method 9
readings for periods when fuel oil is burned and when specific activities subject to the
30% requirement are performed.
4. Compliance Status: In the Title V permit application, the source indicated that the
turbines were in compliance with all applicable requirements.
C. EU 003: One (1) GTS Energy natural gas fired Water Bath Gas Heater, Model
ISNG-HWB8.3s5x, Serial No. PC06035, heat input rated at 11.1 MMBtu/hr.
1. Applicable Requirements: The appropriate provisions from the final approval
correction construction permit have been incorporated into the Title V Operating Permit
as follows:
• Fuel Consumption Limits (from Attachment A of the construction permit)
o Natural gas throughput for the WBGH is limited to 34.94 MMscf/yr. This is
based on a natural gas heating value of 1020 Btu/scf.
An APEN was submitted, with the Title V permit application, on April 8, 2008 that
requested the annual fuel consumption be increased to 77.29 MMscf/yr. This
was to represent the maximum potential fuel use of the heater, however, further
information was provided by the supplier that demonstratedthe heat input rate of
the heater was actually 11.1 MMBtu/hr, as opposed to 9.0 MMBtu/hr. An
additional APEN was submitted on September 17, 2012 to account for the new
heat input rate and a new maximum potential fuel use of 95.33 MMscf/yr. This is
based on a fuel heating value of 1020 Btu/scf. This new fuel consumption limit
will be incorporated into the operating permit.
Although not specifically indentified in Colorado Construction Permit 05WE0274, the
WBGH at this facility is subject to the following applicable requirements:
• Colorado Regulation No. 1
o Except as provided in [Reg 1, Section II.A.4] below, no owner or operator
of a source should allow or cause the emission into the atmosphere of any
air pollutant that is in excess of 20% opacity. (Reg 1, Section II.A.1)
o No owner or operator of a source shall allow or cause to be emitted into
the atmosphere any air pollutant resulting from the building of a new fire,
cleaning of fire boxes, soot blowing, start-up, any process modification, or
adjustment or occasional cleaning of control equipment, which is in excess
of 30% opacity for a period or periods aggregating more than six minutes
in any sixty consecutive minutes. (Reg 1, Section II.A.4)
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Operating Permit No. 08OPWE311
Technical Review Document — Initial Operating Permit
Based on engineering judgment, the Division believes that the operational
activities of fire building, cleaning of fire boxes, and soot blowing do not
apply to the water bath gas heater, and process modifications are not
likely to occur with this unit. In addition, since this heater is not equipped
with control equipment, the operational activities of adjustment or
occasional cleaning of control equipment also do not apply. Therefore, for
this unit, the 30% opacity provision only applies during startup.
o Particulate matter emissions shall not exceed 0.5(FI)-°zs where Fl = fuel
input in MMBtu/hr (Section III.A.1.b)
o The source shall limit emissions of sulfur dioxide to not more than two (2)
tons per day (Section VI.B.5.a)
• Colorado Regulation No. 6
o 40 CFR 60 Subpart Dc — Standards of Performance for Small Industrial -
Commercial -Institutional Steam Generating Units (As adopted by
reference in Colorado Regulation No. 6, Part A)
This heater is only subject to reporting and recordkeeping requirements of
§60.48C since it burns only natural gas as a fuel.
o (State -only) Emissions of particulate matter shall not exceed 0.5(F0-026
where Fl = fuel input in MMBtu/hr. (Part B, Section II.C.2)
o (State -only) Emissions of particulate matter shall not exceed 20% opacity.
(Part B, Section II.C.3)
Streamlining of Applicable Requirements
PM
Regulation No. 1 (Section III.A.1.b) and Regulation No. 6 (Part B, Section II.C.2) contain
the same particulate matter emission requirements: emissions of particulate matter shall
not exceed 0.5(FI)-°'26 where Fl = fuel input in MMBtu/hr. The Regulation No. 6, Part B
requirement is a state -only requirement. Regulation No. 6, Part B, Section I.A, adopts,
by reference, the 40 CFR Part 60 Subpart A general provisions. Although not
specifically stated in the general provisions, the Division has concluded, after reviewing
EPA determinations, that the NSPS standards are not applicable during startup,
shutdown and malfunction, although any excess emissions during these periods must
be reported in the excess emission reports. Therefore, the Division considers that the
Regulation No. 6, Part B particulate matter requirements do not apply during periods of
startup, shutdown, and malfunction. The Regulation No. 1 requirements are therefore
more stringent than the Regulation No. 6 requirements, and the Regulation No. 6
requirements have been streamlined out of the permit.
Opacity
The WBGH at this facility is subject to the Reg 1 opacity requirements of 30% during
certain operational activities (Reg 1, Section II.A.4) and 20% at all other times (Reg 1,
Section II.A.1). The WBGH is also subject to the state -only Reg 6, Part B 20% opacity
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Spindle Hill Energy, LLC
Operating Permit No. O8OPWE311
Technical Review Document — Initial Operating Permit
requirement for particulate matter. Since the Reg 6 opacity requirement is not
applicable during periods of startup, shutdown, and malfunction (per 40 CFR 60 Subpart
A, §60.11(c), adopted by reference in Reg 6, Part B, Section 1.A), and the Division has
determined that startup is the only operational activity of the Reg 1 30% opacity
requirement that applies, the Reg 1 opacity requirements are always equal to or more
stringent than the Reg 6 requirements, and the Reg 6 requirements will be streamlined
out of the permit.
2. Emission Factors: The following emission factors were provided for calculating
emissions for the water bath gas heater. NOx and CO emissions from the WBGH shall
be determined using the emission factors listed below. Emissions for all other pollutants
are below APEN reporting thresholds.
Pollutant
Emission Factor (lb/MMscf)
NOx
156.06
CO
95.88
VOC
6.12
SO2
1.73
PM10
6.12
Note: Emission factors are from vendor specifications and based on a fuel heating value of 1020
Btu/scf. All emission factors, except PM/PM,o, are more conservative than AP -42 Section 1.4
factors for Natural Gas Combustion.
Emissions of all HAPs are below de-minimus levels, and are based on emission factors
from AP -42, Table 1.4-3.
3. Monitoring Plan: The source will be required to record and maintain records of the fuel
use for this heater on a monthly basis to demonstrate compliance with the annual fuel
use limits. The recorded fuel consumption will be used with emission factors from the
vendor to calculate emissions of NOx and CO to demonstrate compliance with these
annual limitations.
4. Compliance Status: In the Title V permit application, the source indicated that the
Water Bath Gas Heater was in compliance with all applicable requirements.
D. TANK -1: One (1) 750,000 gallon Pittsburg Tank vertical fixed roof storage tank, for
storage of distillate fuel oil. There is no model or serial number associated with
this tank.
The only applicable requirement in the final approval correction construction permit for
the fuel oil tank was a fuel oil throughput limit of 11,110,743 gallons/year.
This fuel oil tank is actually exempt from APEN reporting and construction permitting
requirements per Colorado Regulation No. 3, Part A, Section II.D.1.a, since uncontrolled
actual emissions from this unit are less than one (1) ton per year. This unit can also be
considered an insignificant activity for operating permit purposes per Reg 3, Part C,
Section II.E.3.a
123/5468 Page 17 of 21
Spindle Hill Energy, LLC
Operating Permit No. 08OPWE311
Technical Review Document -Initial Operating Permit
Therefore, since the fuel oil tank is exempt from APEN reporting and construction
permitting requirements as stated above, and there are no other applicable
requirements that would make this exemption non -applicable, the fuel oil throughput
limit has not been included in the operating permit. This emission unit will now be
considered an insignificant activity for purposes of this operating permit, and will be
listed in the insignificant activity list included in Appendix A.
E. Fire Pump Engine: One (1) Clarke, Firewater Pump Engine, Model VMFP-T6HT,
Serial No. 91B02978, site -rated at 145 HP, heat input rated at 1.96 MMBtu/hr
1. Applicable Requirements: Since, at the time of the initial permit issuance, this engine
was exempt from APEN reporting and minor source construction permit requirements
(before Colorado's adoption of 40 CFR 60 Subpart 1111; see Subpart 1111 section in
Applicable Requirements, above), no applicable requirements were included in the
construction permit. The following appropriate applicable requirements for this engine
are included in the operating permit:
• Colorado Regulation No. 1
o Except as provided in [Reg 1, Section II.A.41 below, no owner or operator
of a source should allow or cause the emission into the atmosphere of any
air pollutant that is in excess of 20% opacity. (Reg 1, Section II.A.1)
o No owner or operator of a source shall allow or cause to be emitted into
the atmosphere any air pollutant resulting from the building of a new fire,
cleaning of fire boxes, soot blowing, start-up, any process modification, or
adjustment or occasional cleaning of control equipment, which is in excess
of 30% opacity for a period or periods aggregating more than six minutes
in any sixty consecutive minutes. (Reg 1, Section II.A.4)
Based on engineering judgment, the Division believes that the operational
activities of fire building, cleaning of fire boxes, and soot blowing do not
apply to diesel engines, and process modifications are not likely to occur
with this emergency engine. In addition, since this engine is not equipped
with control equipment, the operational activities of adjustment or
occasional cleaning of control equipment also do not apply to this engine.
Therefore, for this unit, the 30% opacity provision only applies during
startup.
o SO2 emission shall not exceed 0.8 lbs/mmBtu (Reg 1, Section VI.B.4.b.(i)).
Note that since the requirements of NSPS 1111 for this engine limit the sulfur
content of the diesel fuel to 15 ppm, which is well below the Reg 1 limit (15
ppm equates to approximately 7.5E-04 lb/MMBtu, assuming a density of 7
lb/gal), the Reg 1 limit will be streamlined out of the permit.
• RACT for VOC shall be met by complying with the NSPS Subpart IIII
requirements. (Colorado Regulation No. 3, Part B, Section III.D.2.a and
Regulation No. 7, Section II.C.2)
123/5468 Page 18 of 21
Spindle Hill Energy, LLC
Operating Permit No. 08OPWE311
Technical Review Document — Initial Operating Permit
• 40 CFR 60 Subpart MI — Standards of Performance for Stationary Compression
Ignition Internal Combustion Engines; emission limitations for NOx, CO, and
particulate matter as well as fuel limitations.
According to the manufacturer's emission factors provided below, this engine
meets the emission limitations for non -emergency engines. The only emission
limitation for non -emergency engines in the same category as this engine is 6.9
g/hp-hr for NOx. Therefore the Subpart 1111 requirement to install a non-resettable
hour meter for engine that do not meet the standards of non -emergency engines
will not be included in the permit.
• 40 CFR Part 63 Subpart ZZZZ requirements — new engines must meet the
requirements of 40 CFR 60 Subpart MI.
Streamlining of Applicable Requirements
SO,
The Fire Pump Engine is subject to Colorado Regulation No. 1, Section Vl.B.4.b.(i),
which requires SO2 emissions from new oil fired operations with an oil heat input of less
than 250 MMBtu/hr be limited to 0.8 lb/MMBtu. This Fire Pump Engine is also subject
to the requirements of NSPS Subpart 1111, which limit the sulfur content of diesel fuel
purchased for use in the engines to 15 ppm by weight. Since the NSPS IIII limit is
always more stringent than the Reg 1 limit (see notes in Applicable Requirements
section above), and is applicable at all times, the Reg 1 limit will be streamlined out of
the permit for the NSPS 1111 limit.
Emission Factors
Emissions from the Fire Pump Engine were calculated based on the following emission
factors provided by the manufacturer.
Pollutant
(Emission Factor (g/hp-hr)
NOx
6.57
CO
0.99
VOC
0.12
2S02
0.8
PM/PMto/PM2.5
0.19
Formaldehyde
1.18E-08 (Ib/MMBtu)
'All emission factors are less than AP -42 factors.
2Based on 0.2% sulfur content of fuel by weight.
All emissions from the emergency Fire Pump Engine are below APEN de minimus
reporting levels (based on 500 hours per year of operation), therefore no emission or
throughput limits have been included in the operating permit.
2. Monitoring Plan
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Spindle Hill Energy, LLC
Operating Permit No. 0SOPWE311
Technical Review Document —Initial Operating Permit
The source shall be required to monitor hours of operation on a rolling 12 month total.
Compliance with the opacity limits shall be monitored using EPA Method 9
observations. The NSPS Subpart 1111 limitations on emissions and sulfur content of fuel
shall be monitored by keeping records demonstrating compliance with these limits.
3. Compliance Status
This engine has not had any previous applicable requirements for which to demonstrate
compliance.
V. Ambient Impacts Analysis
Modeling of emissions was conducted for this facility in 2005 for the Initial Approval
construction permit. The modeling analysis demonstrated that the construction of the
facility would not cause or contribute to a violation of ambient air quality standards for
any of the pollutants and averaging times analyzed.
VI. Insignificant Activities
The Title V permit application indicated that insignificant activities at the facility were
included in the following general categories: landscaping and site housekeeping devices
equal to or less than 10 HP in size, chemical storage areas (where chemical are stored
in closed containers) where total storage capacity does not exceed 5000 gallons,
storage tanks of lubricating oils with capacity less than 40,000 gallons, storage tanks
with annual throughput less than 400,000 gallons (with limited contents), stationary
internal combustion engines (limited hours of operation, horsepower, or emissions), and
air pollution emission units with emissions less than appropriate de minimis levels. A
list of the specific insignificant activities associated with this facility is included in the
operating permit. As mentioned above, the firewater pump engine was previously listed
as an insignificant activity, but can no longer be considered insignificant because it is
now subject to Federal NSPS and NESHAP standards.
VII. Alternative Operating Scenarios
No alternative operating scenarios were requested for this facility.
VIII. Permit Shield
No permit shield was requested for this facility.
123/5468 Page 20 of 21
Spindle Hill Energy, LLC
Operating Permit No. 08OPWE311
Technical Review Document — Initial Operating Permit
Facility Wide Potential HAP Emissions (Ib/yr)
1Turbin
temperature, 98% of permitted fuel limits). Emissions factors used to calculate HAPs are from AP -42
section 3.1, except the emission factor for formaldehyde is from the October 25-26 2007 Unit 1
formaldehyde compliance test, with a 25% safety factor.
Pohl tan .,{
Turbines
z WBGH
t I
QT tat tt®y)=
1,3 Butadiene=
29.2
29.2
0.015
Acetaldehyde
453
453
0.227
Acrolein
72.4
72.4
0.036
Arsenic.
16.8
16.8
0.008
Benzene
219.6
0,2
219.8
0.110
,Beryllium
0.4
- 0.4
0.000
Cadmium
7.4
7.4
0.004
:Chromium ,
16.8
16.8
0.008
Dichlorobehz e
'.
0.1
0.1
0.000
Ethylbenzejie
362.4
362.4
0.181
Formaldehy"d'e',
13165.8
7.1
13172.9
6.586
k_`=texane
171.6
171.6
0.086
Lead `. f
21.4
,.- _
21.4
0.010
Manganese
1204.2
1204.2
0.602
;Mercury
1.8
1.8
0.000
'Napthalene
68.2
68.2
0.034
NickelAra
7
0.004
PAHs '1t2
85.4
�F„
a„ _ ,,
85.8
0.04
;Propylene Oxide '''.
328.4
328.4
0.164
FSel2ttidtii.'.
38.2
,�,�,
38.2
0.019
;Tor uxe5ne.'
1472
0.3
1472.3
0.736
Xylen
724.8
';;.
724.8
0.36
2The WBGH HAP emissions are those given in a revised APEN received on September 17, 2012.
All HAP emissions from the fuel oil storage tank and the Firewater Pump Engine are below de minimus
levels.
Actual HAP emissions from the turbines will be calculated according to the method specified in the turbine
section above.
123/5468 Page 21 of 21
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
OPERATING PERMIT SUMMARY
PERMIT NUMBER: 08OPWE311 AIRS ID #: 1235468 DATE: October 2, 2013
APPLICANT: Spindle Hill Energy, LLC — Spindle Hill Energy Center REVIEW ENGINEER: Joshua Jones
SOURCE DESCRIPTION
Spindle Hill Energy, LLC has applied for an Operating Permit for the Spindle Hill Energy Center located at 6335 County
Road 19, Fort Lupton, 80621, in Weld County. This facility is a peaking utility electric power generation facility classified
under SIC code 4911. The significant emissions units at the facility include two (2) 145 MW simple -cycle combustion
turbines, a natural gas fired water bath gas heater, and an emergency fire pump engine.
This facility is located in the 8 -hr Ozone Control Area (non -attainment area) as defined in Colorado Regulation No. 7,
Section II.A.1. This source is classified as a NANSR major stationary source (Potential to Emit of NOx > 100 tpy) and a
minor stationary source with respect to Prevention of Significant Deterioration (PSD) requirements. There are no states
within 50 miles of this facility. The following Federal Class I designated areas are within 100 kilometers of the plant: Rocky
Mountain National Park and the Rawah Wilderness Area. This source is not subject to the Accidental Release provisions
of section 112(r) of the Federal Clean Air Act. Compliance Assurance Monitoring (CAM) requirements do not apply to any
of the emission units at this facility since a continuous compliance determination method is specified in the permit for NOx
emissions potentially subject to CAM requirements during fuel oil firing.
FACILITY EMISSION SUMMARY
Pollutant
Potential to Emit (tons/yr)
NOx
230.7
CO
228.0
VOC
17.7
Individual HAPs
6.6
Total HAPs
8.1
EMISSION SOURCES
Turbines (CT -01, CT -02): Both of these turbines are subject to NSPS KKKK, Reg 1 opacity requirements, annual emission
limits (for NOx, CO, VOC, PM/PM10, SO2; and sulfuric acid), fuel consumption limits, limits on the sulfur content of fuel,
and the requirements of the Acid Rain Program (ARP). Both turbines are permitted to run on either natural gas or fuel oil,
with the limit for fuel oil use being reduced with corresponding natural gas use. These turbines are required to have
Continuous Emission Monitoring Systems (CEMS) to demonstrate compliance with annual NOx and CO emission
limitations, the NOx emission limits of NSPS KKKK, and fuel consumption limits. Compliance with emission limits for
VOC, PM/PM10, and sulfuric acid are demonstrated using emission factors from stack testing. Compliance with SO2
emission limits are demonstrated using 40 CFR Part 75, Appendix D. All annual limits are based on rolling 12 month
totals. Compliance with the opacity standards is presumed during natural gas firing, but requires EPA Method 9 readings
during fuel oil firing (under specified circumstances).
Water Bath Gas Heater (EU 003): The Water Bath Gas Heater is subject to NSPS Dc (recordkeeping requirements), Reg
1 limits (opacity, PM, and SO2), annual emission limitations for NOx and CO, and fuel consumption limits. The permit
requires the recording of natural gas consumption monthly. Compliance with annual emission and fuel consumption limits
are based on rolling 12 month totals. Compliance with the opacity limits is presumed since only natural gas is permitted
for use in this heater.
Emergency Fire Pump Engine: This engine is subject to NSPS 1111, Reg 1 opacity requirements, NESHAP ZZZZ, Reg 3
RACT requirements, and a limit on operating hours. Compliance with NSPS 1111 is demonstrated by maintaining
documentation on manufacturer emissions specifications. Compliance with NESHAP ZZZZ and Reg 3 RACT
requirements are determined according to the NSPS 1111 provisions. Compliance with Reg 1 opacity requirements are
determined using EPA Method 9 readings, scheduled to be taken based on operating hours.
Facility Wide Conditions: This facility has annual emission limits for HAPs (single and individual), and annual emission
limits on NOx and CO emissions from insignificant activities. Compliance with annual HAP emission limits are based on
emission factors for formaldehyde and manganese obtained during stack tests for the turbines, and AP -42 factors for other
HAPS emitted by the turbines as well as those emitted by the water bath gas heater. Compliance with annual NOx and
CO emissions limits from insignificant activities are demonstrated by conducting annual accounting of the potential to emit
for these sources.
INSIGNIFICANT ACTIVITIES
A list of insignificant activities is included in the draft Operating Permit.
ALTERNATIVE OPERATING SCENARIOS
No alternative operating scenarios for these turbines has been specified.
Hello