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Home My WebLink About20130851.tiffSTATE OF COLORADO John W. Hickenlooper, Governor Christopher E. Urbina, MD, MPH 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 http://www.cdphe.state.co.us Weld County Clerk & Recorder 1402 N 17th Ave Greeley, CO 80631 March 26, 2013 Dear Sir or Madam: Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230- (303) 692-3090 WELD COUNTY COMMISSIONERS Colorado Department of Public Health and Environment On March 29, 2013, the Air Pollution Control Division will publish a public notice for Public Service Company of Colorado — Ft. Lupton Combustion Turbines, in the The Greeley Turbine. 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 PuiaGV 12e* q_8-43 ex' 2013-0851 NOTICE OF A PROPOSED RENEWAL TITLE V OPERATING PERMIT WARRANTING PUBLIC COMMENT Website Title: Public Service Company of Colorado — Ft. Lupton Combustion Turbines — Weld County NOTICE is hereby given that an Operating Permit application to renew an Operating Permit 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: Public Service Company of Colorado 1800 Larimer Street Denver, CO 80202 Facility: Ft. Lupton Combustion Turbines 15002 Weld County Road 16 Ft. Lupton, CO 80621 Public Service Company of Colorado has applied for a Renewal Operating Permit for the Ft. Lupton Combustion Turbines in Weld County, CO. This facility is an unmanned electric power generating station that consists of 2 simple cycle combustion turbines. A copy of the application, including supplemental information, the Division's analysis, and a draft of the Renewal Operating Permit 96OPWE154 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.qov/cdphe/AirPublicNotices. Based on the information submitted by the applicant, the Division has prepared the draft renewal operating permit for approval. Any interested person may contact Jacqueline Joyce of the Division at (303) 692-3267 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: I) identify the individual or group requesting the hearing, 2) state his or her address and phonenumber, 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 Turbine on PUBLISHED: March 29, 2013 March 26, 2013 Colorado Department of Public Health and Environment OPERATING PERMIT Public Service Company of Colorado - Ft. Lupton Combustion Turbines First Issued: May 20, 1997 Renewed: DRAFT AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: Ft. Lupton Combustion Turbines FACILITY ID: 1230014 RENEWED: EXPIRATION DATE: MODIFICATIONS: See Appendix F of Permit OPERATING PERMIT NUMBER 96OPWE154 Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et sue. and applicable rules and regulations. ISSUED TO: Public Service Company of Colorado 1800 Larimer Street Denver, CO 80202 PLANT SITE LOCATION: 15002 Weld County Road 16 Ft. Lupton, CO 80621 Weld County INFORMATION RELIED UPON Operating Permit Renewal Application Received: And Additional Information Received: October 30, 2012 Nature of Business: Power Generation Primary SIC: 4911 RESPONSIBLE OFFICIAL Name: Gary Magno Title: Manager, Environmental Services Air Quality Compliance Phone: (303) 294-2177 FACILITY CONTACT PERSON Name: Gary Magno Title: Manager, Environmental Quality Compliance Phone: (303) 294-2177 Services — Air SUBMITTAL DEADLINES Semi -Annual Monitoring Periods: EXAMPLE (December 1 — May 31, June 1 — November 30) Semi -Annual Monitoring Report:. EXAMPLE (July 1, 2009 & Jan. 1, 2010 & subsequent years) First Annual Compliance Period: EXAMPLE (December 1 — May 31) Subsequent Annual Compliance Periods: EXAMPLE (June 1 — May 31) Annual Compliance Certification: EXAMPLE (July 1, 2009 & subsequent years) Note that the Semi -Annual Monitoring Reports and Annual Compliance Certifications 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/certifications. TABLE OF CONTENTS: SECTION I - General Activities and Summary 1 1. Permitted Activities 1 2. Alternative Operating Scenarios 2 3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant Deterioration (P SD) 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. T001 & T002 - General Electric Combustion Turbines - Natural Gas Fired 4 2. T001 & T002 - General Electric Combustion Turbines - Nos. 1 and/or 2 Fuel Oil Fired. 6 3. T001 & T002 - General Electric Combustion Turbines - Natural Gas and Nos. 1 and/or 2 Fuel Oil Fired. 7 SECTION III - Permit Shield 8 1. Specific Non -Applicable Requirements 8 2. General. Conditions 8 3. Streamlined Conditions 9 SECTION IV - General Permit Conditions 10 1. Administrative Changes 10 2. Certification Requirements 10 3. Common Provisions 10 4. Compliance Requirements 14 5. Emergency Provisions 15 6. Emission Controls for Asbestos I5 7. Emissions Trading, Marketable Permits, Economic Incentives 15 8. Fee Payment 16 9. Fugitive Particulate Emissions 16 10. Inspection and Entry 16 11. Minor Permit Modifications 16 12. New Source Review 16 13. No Property Rights Conveyed 17 14. Odor 17 15. Off -Permit Changes to the Source 17 16. Opacity 17 17. Open Burning 17 18. Ozone Depleting Compounds 17 19. Permit Expiration and Renewal 17 20. Portable Sources 18 21. Prompt Deviation Reporting 18 22. Record Keeping and Reporting Requirements 18 23. Reopenings for Cause 19 24. Section 502(b)(10) Changes 20 25. Severability Clause 20 26. Significant Permit Modifications 20 27. Special Provisions Concerning the Acid Rain Program 20 TABLE OF CONTENTS: 28. Transfer or Assignment of Ownership 20 29. Volatile Organic Compounds 21 30. Wood Stoves and Wood burning Appliances 21 APPENDIX A - Inspection Information 1 Directions to Plant: 1 Safety Equipment Required: 1 Facility Plot Plan 1 List of Insignificant Activities: 1 APPENDIX B 1 Reporting Requirements and Definitions 1 Format for Compliance Monitoring Report - Part I 5 Format for Compliance Monitoring Report - Part II 6 Format for Compliance Monitoring Report - Part III 8 APPENDIX C 1 Required Format for Annual Compliance Certification Reports 1 APPENDIX D 1 Notification Addresses 1 APPENDIX E 1 Permit Acronyms 1 APPENDIX F 1 Permit Modifications Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE154 Public Service Company of Colorado Ft. Lupton Combustion Turbines Page 1 1. Permitted Activities 1.1 SECTION I - General Activities and Summary This facility is an unmanned electric power generating station that consists of two (2) simple cycle combustion turbines nameplate rated at 100 megawatts of power on a gross basis. These turbines are fueled by natural gas, Nos. 1 and/or 2 fuel oil or combination. The facility is located approximately 2 miles east of Ft. Lupton in Weld county. This facility is located in an area classified as attainment for all pollutants except ozone. It is classified as non - attainment for ozone and is part of the 8 -hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1. There are no affected states within 50 miles of the plant. Rocky Mountain National Park and Rawah National Wilderness Area, both Federal Class I designated areas, are within 100 kilometers of the plant. 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 This 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 revision 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: P-10,779. 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 IV — Conditions 3.g (last paragraph), 14 and 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 IV of this permit, unless otherwise specified. All records required by General Condition 22 are to be retained at Public Service Company's Ft. St. Vrain Station. Either electronic or hard copy records are acceptable. Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE154 Public Service Company of Colorado Ft. Lupton Combustion Turbines Page 2 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). 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 PSD major stationary source (potential to emit of PM, PMio, SO2 NOx and CO > 250 tons/year). Future modifications at this facility resulting in a. significant net emissions increase (see Colorado Regulation No. 3, Part D, Sections II.B.26 and 42) or a modification which is major by itself (Potential to Emit> 250 tons/year) for any pollutant listed in Colorado Regulation 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. 3.2 This source 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 Regulation No. 3, Part D, Sections II.A.26 and 42) for VOC or NOx or a modification which is major by itself (Potential to Emit > 100 tons/year of either VOC or NOx) may result in the application of the NANSR review requirements. 3.3 There are no other Operating Permits associated with this facility for purposes of determining applicability of NANSR and PSD review 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: None. Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE 154 Public Service Company of Colorado Ft. Lupton Combustion Turbines Page 3 6. Summary of Emission Units 6.1 The emissions units regulated by this permit are the following: Emission Unit Number . AIRS Point Number Facility Identifier Description Startup Date Pollution Control Device T001 001 TOOT General Electric Combustion Turbine, Model MS7000B, Serial No. 217708, rated at 662.6 MMBtu/hr (NG) and 656 MMBtu/hr (F0). Fueled by Natural Gas, Nos. I and/or 2 Fuel Oil, or Combination. April 1972, Modified 1975 to Bum NG and Distillate Oil Uncontrolled 1002 002 T002 General Electric Combustion Turbine, Model MS7000C, Serial No. 217709, rated at 662.6 MMBtu/hr (NG) and 656 MMBtu/hr (FO). Fueled by Natural Gas, Nos. 1 and/or 2 Fuel Oil, or Combination. April 1972, Modified 1975 to Burn NG and Distillate Oil Uncontrolled Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE154 Public Service Company of Colorado Ft. Lupton Combustion Turbines Page 4 SECTION II - Specific Permit Terms 1. T001 & T002 - General Electric Combustion Turbines Natural Gas Fired. Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor (lbs/MMBtu) Monitoring Method Interval Emission Calculation 1.1 N/A N/A PM — 2.1 x 10 -3 PMio — 2.1 x 10 -3 SO2-3.8x103 NOx - 0.35 CO -0.091 VOC-2.3x10-3 Recordkeeping and Calculation Annually Natural Gas Usage 1.2. N/A N/A N/A Recordkeeping Annually Particulate Matter (PM) 1.3. 0.1 lbs/MMBtu N/A Fuel Restriction Whenever Natural Gas is Used as Fuel SO2 1.4. 0.8 lbs/MMBtu N/A Opacity 1.5. Not to Exceed 20% N/A Btu Content of Natural Gas 1.6 N/A N/A N/A ASTM Methods Annually The emission factors listed above have been approved by the Division and shall be used to calculate emissions from these turbines (from AP -42, April 2000, Section 3.1, corrected to a lower heating value basis) when natural gas is used as fuel. Annual emissions, from each turbine, for the purposes of APEN reporting and the payment of annual fees, shall be calculated using the above emission factors, the annual natural gas consumption (as determined by Condition 1.2), and the heat content of the gas (as determined by Condition 1.6) in the following equation: Tons/yr = f EF (lbs/MMBtu) x annual natural gas use (MMscf/vr) x heat content of fuel (MMBtu/MMscf)I 2,000 lbs/ton 1.2 Natural Gas Usage, for each unit, shall be monitored annually and recorded and maintained to be available to the Division upon request. Annual natural gas usage will be used to calculate annual emissions as required by Condition 1.1. 1.3 Particulate matter (PM) emissions from each turbine shall not exceed 0.1 .lbs/MMBtu (Colorado Construction Permit P-10,779). In the absence of credible evidence to the contrary, compliance with the particulate matter limitation is presumed whenever natural gas is used as fuel in the turbines. Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE154 Public Service Company of Colorado Ft. Lupton Combustion Turbines Page 5 1.4 Sulfur Dioxide emissions from each turbine shall not exceed 0.8 lbs/MMBtu (Colorado Regulation 1, Section VI.A.3.c.(ii)). In the absence of credible evidence to the contrary, compliance with the sulfur dioxide limitation is presumed whenever natural gas is used as fuel in the turbines. 1.5 Opacity of emissions from each turbine shall not exceed 20% (Colorado Construction Permit P- 10,779). In the absence of credible evidence to the contrary, compliance with the opacity limitation is presumed whenever natural gas is used as fuel in the turbines. 1.6 The Btu Content of the natural .gas burned shall be determined annually using ASTM Methods or equivalent, as approved by the Division in advance. Calculation of annual emissions outlined under Condition 1.1 shall be based on the most recent Btu analysis. The Btu content shall be based on the lower heating value of the fuel. Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air. Pollution Control Division Colorado Operating Permit Permit # 96OPWE154 . Public Service Company of Colorado Ft. Lupton. Combustion Turbines Page 6 2. T001 & T002 - General Electric Combustion Turbines - Nos. 1 and/or 2 Fuel Oil Fired. Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor' (lbs/MMBtu) Monitoring Method Interval Emission Calculations 2.1 N/A N/A PM 4.3 x 10-3 PMio 4.3 x 10"3 SO2 1.01S NOx 0.88 CO 3.3 x 10-3 VOC 4.1 x 10-4 Recordkeeping and Calculation Annually Nos. 1 and/or 2 Fuel Oil Usage 2.2. N/A N/A N/A Recordkeeping Annually Particulate . Matter (PM) 2.3. 0.1 lbs/MMBtu N/A Fuel Restriction Whenever Nos. 1 and/or 2 Fuel Oil is Used as Fuel SO2 2.4. 0.8 lbs/MMBtu N/A Opacity 2.5. Not to Exceed 20% . N/A EPA Reference Method 9 See Condition 2.5. Btu Content of Nos. 1 and/or 2 Fuel Oil 2.6. N/A N/A N/A ASTM Methods Annually 'S = weight percent sulfur in the fuel. 2.1 The emission factors listed above have been approved by the Division and shall be used to calculate emissions from these turbines (from AP -42, April 2000, Section 3.1) when either Nos.1 and/or 2 fuel oil are used as fuel. Annual emissions, from each turbine, for the purposes of ADEN reporting and the payment of annual fees, shall be calculated using the above emission factors the annual Nos. 1 and/or 2 fuel oil consumption (as determined by Condition 2.2) and the heat content of the fuel oil (as determined by Condition 2.6) in the following equation: Tons/yr = JEF (lbs/MMBtu) x annual Nos. land/or 2 fuel oil use (gal/yr) x heat content of fuel (Btu/gal)1 2,000 lbs/ton x 106 Btu/MMBtu Operating Permit Number: 96OPWE 154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE154 Public Service Company of Colorado Ft. Lupton Combustion Turbines Page 7 2.2 Nos. 1 and/or 2 Fuel Oil Usage, for each unit, shall be monitored annually and recorded and maintained to be available to the Division upon request. Annual Nos. 1 and/or 2 fuel oil usage will be used to calculate annual emissions as required by Condition 2.1. 2.3 Particulate matter (PM) emissions from each turbine shall not exceed 0.1 lbs/MMBtu (Colorado Construction Permit P-10,779). In the absence of credible evidence to the contrary, compliance with the particulate matter limitation is presumed whenever Nos. 1 and/or 2 fuel oil is used as fuel in the turbines. 2.4 Sulfur Dioxide emissions from each turbine shall not exceed 0.8 lbs/MMBtu (Colorado Regulation No.1, Section VI.A.3.c.(ii)). In the absence of credible evidence to the contrary, compliance with the sulfur dioxide limitation is presumed whenever Nos. 1 and/or 2 fuel oil is used as fuel in the turbines. Note that this presumption is based on Nos. 1 and/or 2 fuel oil having a sulfur content no greater than 0.5 weight percent and a heat content no less than 88,125 Btu/gallon. 2.5 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 Construction Permit P-10,779), This opacity standard applies to each turbine. Compliance with this standard shall be determined by conducting visual emissions observations, in accordance with EPA Reference Method 9. Readings shall be conducted annually. 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. 2.6 The Btu Content of the fuel oil burned shall be determined annually using ASTM Methods or equivalent, as approved by the Division in advance. Calculation of annual emissions outlined under Condition 2.1 shall be based on the most recent Btu analysis. The Btu content shall be based on the lowest gross heating value of the fuel. If no fuel oil is delivered to the facility in the annual period, no fuel sampling is required. 3. T001 & T002 - General Electric Combustion Turbines - Natural Gas and Nos. 1 and/or 2 Fuel Oil Fired. 3.1 Any combination of the fuels identified in this permit (natural gas and/or Nos. 1 and/or 2 fuel oil) may be burned in the turbine provided the most stringent requirements and periodic monitoring shall be followed for the combination of fuels burned. The most stringent periodic monitoring requirements are for Nos. 1 and/or 2 fuel oil, followed by natural gas. Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE154 Public Service Company of Colorado Ft. Lupton Combustion Turbines Page 8 SECTION III - 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 upon 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 modification or reconstruction on which construction commenced prior to permit issuance. Emission Unit Description & Number Applicable Requirement Justification Facility Colorado Regulation 7, Subsection V.B This regulation does not apply as the source does not store or dispense gasoline. Facility Colorado Regulation 7, Paragraphs VI.B. I and 2 This regulation is not applicable as the source stores Nos. 1 and/or 2 fuel oil and is exempt (per VI.B.l.a.(ii)) from these requirements. Facility Colorado Regulation 7, Subsection VII.C This regulation does not apply as the source does not store crude oil. Facility 40 CFR Part 60, Subpart GG (as adopted by reference in Colorado Regulation 6) This regulation is not applicable as the turbines were constructed prior to October 3, 1977. Facility Prevention of Significant Deterioration Requirements - Colorado Regulation 3, Part D, Section VI These requirements are not applicable as the facility was constructed prior to August 7, 1977. 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; Operating Permit Number: 96OP WE 154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Al 96OPWE154 Public Service Company of Colorado Ft. Lupton Combustion Turbines Page 9 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)O), 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. Streamlined 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. No conditions have been streamlined. Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWEI54 Public Service Company of Colorado Ft. Lupton Combustion Turbines Page 10 SECTION IV - General Permit Conditions 5/22/12 version 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, § I.B.I. 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, 56 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 6S ILA., ILB., ILC., II,.E., II.F., II.I, and II.J 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 Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE154 Public Service Company of Colorado Ft. Lupton Combustion Turbines Page 11 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 any air 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: (i) Sampling ports adequate for test methods applicable to such facility; (ii) Safe sampling platform(s); (iii) Safe access to sampling platform(s); and (iv) 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 Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE154 Public Service Company of Colorado Ft. Lupton Combustion Turbines Page 12 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. Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s) if so warranted. 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 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. (x) 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 Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE154 Public Service Company of Colorado Ft. Lupton Combustion Turbines Page 13 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 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 isconsiderednormal practice by the industry or activity in question. f. 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. g. 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: (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 subparagraphis 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 Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE154 Public Service Company of Colorado Ft. Lupton Combustion Turbines Page 14 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. 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 review of 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, §§ III.C.9., V.C.11. & 16.d. and § 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. b. 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 that it 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 maybe 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. 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 which contain the following: Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE154 Public Service Company of Colorado Ft. Lupton Combustion Turbines Page 15 (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. 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, 6 VII 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 permitiee 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. Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE154 Public Service Company of Colorado Ft. Lupton Combustion Turbines Page 16 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 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 pennittee 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. 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. I. 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.I. 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 the permit; 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. II. Minor Permit Modifications Regulation No. 3, 5 CCR 1001-5, Part C, §§ X. & Xl. 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 pennittee 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. Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE154 Public Service Company of Colorado Ft. Lupton Combustion Turbines Page 17 13. No Property Rights Conveyed Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.1I.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 pennittee shall comply with the provisions of Regulation No. 2 concerning odorous emissions. 15. Off -Permit Changes to the Source Regulation No. 3, 5 CCR 1001-5, Part C, § XILB. 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, §§ 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 pennittee 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., I11.VI. 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, §§ 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. Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE154 Public Service Company of Colorado Ft. Lupton Combustion Turbines Page 18 20. Portable Sources Regulation No. 3, 5 CCR 1001-5, Part C, § 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, § 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: 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. c. 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 specify 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, ¢§ V.C.6., V.C.7. a. Unless otherwise provided in the source specific conditions of this Operating Permit, the pennittee 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; Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE154 Public Service Company of Colorado Ft. Lupton Combustion Turbines Page 19 (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. 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 APEN 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. Pennittees 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, 6 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. b. 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. Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE154 Public Service Company of Colorado Ft. Lupton Combustion Turbines Page 20 c. The Division shall provide 30 days' advance notice to the permittee of its intent to reopen the permit, except that a shorter notice may be 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(b)(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. 25. Severability Clause Regulation No. 3,5 CCR 1001-5, Part C, 6 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, & III.B.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.I.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 actor 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. Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE154 Public Service Company of Colorado Ft. Lupton Combustion Turbines Page 21 29. Volatile Organic Compounds Regulation No. 7, 5 CCR 1001-9, §§ III & V. The requirements in paragraphs 1, 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 shall be 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. b. 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 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 pennittee shall comply with the provisions of Regulation No. 4 concerning the advertisement, sale, installation, and use of wood stoves and wood burning appliances. End of Permit Requirements Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT 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 Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page 1 APPENDIX A - Inspection Information Directions to Plant: From Interstate 76, take highway 85 north past Fort Lupton to Weld County Road 16. Turn east on Road 16 and travel 2 miles to the substation, on the south side of Road 16. Safety Equipment Required: Eye Protection Hard Hat Safety Shoes Hearing Protection Facility Plot Plan: Figure 1 (following page) shows the plot plan as submitted on October 30, 2012 with the source's Title V Renewal Operating Permit Application. 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. The asterisk (*) denotes an insignificant activity source category based on the size of the activity, emissions levels from the activity or the production. rate of the activity. The owner or operator of individual emission points in insignificant activity source categories marked with an asterisk (*) must maintain sufficient record keeping verifying that the exemption applies. Such records shall be made available for Division review upon request. (Colorado Regulation No. 3, Part C, Section II.E) Insignificant activities and/or sources of emissions identified by the permittee are as follows: Units with emission less than APEN de minimis (Reg 3, Part C.II.E.3.al* Natural gas venting and equipment leaks (VOC emissions < 1 ton/yr) Use of cleaners and solvents in equipment maintenance (VOC emissions < 1 ton/yr) Fugitive emissions from roads (PM emissions < 1 ton/yr) Fuel burning equipment less than 10 MMBtu/hr - for heating (Reg 3, Part C.II.E.3.ggg) Office space heater Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page 2 Storage tanks with annual throughput less than 400,000 gal (Reg 3 Part C.II.E.3.fff)* Diesel fuel storage tank (216,000 gal aboveground) Not an emission source and/or not a source of regulated/reportable emissions Three (3) spill containment underground tanks (1,000 gal each) Two (2) water tanks (approx. 20,000 gal aboveground, each) Turbine lube oil vents Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page 3 Figure 1: Facility Plot Plan Ft. Lupton Combust on Turbines OBIIN S=o Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 1 APPENDIX B Reporting Requirements and Definitions with codes ver 2/20/07 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 Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 2 requirements, including those attributable to malfunctions as defined in this Appendix, the probable cause of 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. 1, 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: (I) 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; 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: (3) 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. Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 3 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 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. 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 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 Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 4 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 Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 5 Format for Compliance Monitoring Report - Part I 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: Public Service Company of Colorado — Ft. Lupton Combustion Turbines OPERATING PERMIT NO: 96OP WE 154 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) Operating Permit Unit ID Unit Description Deviations noted During Period?' Deviation Code2 Malfunction/Emergency Condition Reported During Period? YES NO . - YES NO T001 General Electric Combustion Turbine, Model MS7000B, Serial No. 217708, rated at 662.6 MMBtu/hr (NG) and 656 MMBtu/hr (FO). Fueled by Natural Gas, Nos. I and/or 2 Fuel Oil, or Combination. 1002 General Electric Combustion Turbine, Model MS7000C, Serial No. 217709, rated at 662.6 MMBtu/hr (NG) and 656 MMBtu/hr (FO). Fueled by Natural Gas, Nos. 1 and/or 2 Fuel Oil, or Combination. General Conditions Insignificant Activities See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation has occurre hall be based on a reasonable inquiry using readily available information. Use the following entries as appropriate: I = Standard: When the requirement is an emission limit or standard 2= Process: When the requirement is a production/process limit 3 = Monitor: When the requirement is monitoring 4 = Test: When the requirement is testing 5 = Maintenance: When required maintenance is not performed 6 = Record: When the requirement is recordkeeping 7 = Report: When the requirement is reporting 8 = CAM: A situation in which an excursion or exceedance as defined in 40 CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. 9 = Other: When the deviation is not covered by any of the above categories Operating Permit Number: 96OP WE 154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 6 Format for Compliance Monitoring Report - Part II FACILITY NAME: Public Service Company of Colorado — Ft. Lupton Combustion Turbines OPERATING PERMIT NO: 96OPWE154 REPORTING PERIOD: Is the deviation being claimed as an: Emergency Malfunction N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Operating Permit Condition Number Citation Explanation of Period of Deviation Duration (start/stop date & time) 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: SEE EXAMPLE ON THE NEXT PAGE Malfunction Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 7 FACILITY NAME: Acme Corp. OPERATING PERMIT NO: 96OPZZXXX REPORTING PERIOD: 1/1/04 - 6/30/06 Is the deviation being claimed as an: 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- 1730 4/10/06 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 A. Einstein, APCD Deviation Code Division Code QA: Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Format for Compliance Monitoring Report - Part III REPORT CERTIFICATION SOURCE NAME: Public Service Company of Colorado — Ft. Lupton Combustion Turbines Appendix B Page 8 FACILITY IDENTIFICATION NUMBER: 1230014 PERMIT NUMBER: 96OP WE 154 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 Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Appendix C Page 1 APPENDIX C Required Format for Annual Compliance Certification Reports ver 2/20/07 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: Public Service Company of Colorado — Ft. Lupton Combustion Turbines OPERATING PERMIT NO: 96OPWE154 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 Permit Unit ID Unit Description Deviations Reported 1 Monitoring Method per Permit?2 Was Compliance Continuous or Intennittent?3 Previous Current YES NO Continuous Intermittent T001 General Electric Combustion Turbine, Model MS7000B, Serial No. 217708, rated at 662.6 MMBtu/hr (NG) and 656 MMBtu/hr (FO). Fueled by Natural Gas, Nos. 1 and/or 2 Fuel Oil, or Combination. T002 General Electric Combustion Turbine, Model MS7000C, Serial No. 217709, rated at 662.6 MMBtu/hr (NG) and 656 MMBtu/hr (FO). Fueled by Natural Gas, Nos. 1 and/or 2 Fuel Oil, or Combination. Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Appendix C Page 2 Operating Permit Unit ID Unit Description Deviations Reported 1 Monitoring Method per Perm t?z Was Compliance Continuous or Intermittent?3 Previous Current YES NO Continuous Intermittent General Conditions Insignificant Activities 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. ' Note whether the compliance status with of 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. "Compliance status for these sources shall be based on a reasonable inquiry using readily available information. Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Appendix C Page 3 IL 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. 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 Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix D Page 1 APPENDIX D Notification Addresses Air Pollution Control Division Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit APCD-SS-B1 1 4300 Cherry Creek Drive S. Denver, CO 80246-1530 ATTN: Matt 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, CO 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, CO 80202-1129 Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Acronyms Appendix E Page 1 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 EPA - Environmental Protection Agency FR - Federal Register G - Grams Gal - Gallon 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 PM - Particulate Matter PMI() - Particulate Matter Under 10 Microns PSD - Prevention of Significant Deterioration PTE - Potential To Emit RACT - Reasonably Available Control Technology SCC - Source Classification Code Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Acronyms Appendix E Page 2 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 Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix F Page 1 APPENDIX F Permit Modifications FATE OF REVISION TYPE OF REVISION SECTION NUMBER, CONDITION NUMBER DESCRIPTION OF REVISION Operating Permit Number: 96OPWE154 First Issued: 5/20/97 Renewed: DRAFT TECHNICAL REVIEW DOCUMENT for RENEWAL TO OPERATING PERMIT 96OPWE154 Public Service Company of Colorado — Ft. Lupton Combustion Turbines Weld County Source ID 1230014 Prepared by Jacqueline Joyce December 2012 Revised February and March 2013 I. Purpose: This document will establish the basis for decisions made regarding the applicable requirements, emission factors, monitoring plan and compliance status of emission units covered by the renewed operating permit proposed for this site. The current Operating Permit was issued December 1, 2008. The expiration date for the permit is December 1, 2013. This document is designed for reference during the review of the proposed permit by the EPA, the public, and other interested parties. The conclusions made in this report are based on information provided in the renewal application submitted October 30, 2012, comments on the draft permit and technical review document received on March 17, 2013, previous inspection reports and various e-mail correspondence, as well as telephone conversations with the applicant. Please note that copies of the Technical Review Document for the original permit and any Technical Review Documents associated with subsequent modifications of the original Operating Permit may be found in the Division files as well as on the Division website at http://www.cdphastate.co.usiap/Titlev.html. 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 This facility is classified as an electric services facility under the Standard Industrial Classification 4911. This facility is an unmanned electric power generating station that consists of 2 simple cycle combustion turbines that can generate up to 100 MW of Page 1 power. Typically this facility is used to service peak electrical load demands. The turbines are capable of burning natural gas, Nos. 1 and/or 2 fuel oil or combination. The facility is located approx. 2 miles east of Ft. Lupton in Weld County. This facility is located in an area classified as attainment for all pollutants except ozone. It is classified as non -attainment for ozone and is part of the 8 -hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1. Rocky Mountain National Park and Rawah National Wilderness Area, both federal class I designated areas, are within 100 km of this facility. The summary of emissions that was presented in the Technical Review Document (TRD) for the previous renewal permit issuance has been modified to update actual emissions. The emissions in the table below represent emissions from both turbines together. Pollutant Potential to Emit — 100% Natural Gas Potential to Emit — 100% Nos. 1 and/or 2 Fuel Oil Actual Emissions — Combination3 PM' 580 575 0.2 PM101 580 575 0.2 SO22 4,644 4,597 1.2 NOx 2,032 5,057 21.4 CO 528 19 4.5 VOC 13.4 2.4 0.2 Total HAPS 5.94 2.13 Highest Single HAP4 4.12 1.61 PTE, when burning any fuel, is based on the PM limit (0.1 lbs/mmBtu) x design heat rate x 8760 hrs/yr. PM,() is assumed to equal PM. Heat input when burning NG is 662.6 mmBtu/hr and when burning DO is 656 mmBtu/hr. 2PTE, when burning any fuel, is based on the Reg 1 SO2 limit (0.8 lbs/mmBtu) x design heat rate x 8760 hrs/yr. 3Actual emissions identified in the table are for both turbines together and include both natural gas and fuel oil combustion. 4Highest single HAP is formaldehyde. Potential to emit for the turbines is based on the information identified in the table and the maximum hourly fuel consumption rate, AP -42 emission factors and 8760 hrs/yr of operation. Actual emissions are based on APENs submitted on April 30, 2008 (2007 data). In the above table, the breakdown of HAP emissions by fuel burned and individual HAPs is provided on page 7 of this document. HAP emissions are based on the maximum hourly fuel consumption rate, 8760 hrs/yr of operation and AP -42 emission factors (Section 3.1, dated 4/00, Tables 3.1-3 and 3.1-4). Page 2 National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source Categories As indicated in the above table summarizing potential to emit, the facility is not a major source for HAPS and is an area source (minor source) for HAPs. As indicated in the technical review document to support the second renewal permit (issued December 1, 2008), EPA has been promulgating NESHAPS (also referred to as "MACT requirements") for area sources, and those requirements that could potentially apply to this facility are discussed below. Paint Stripping and Miscellaneous Surface Coating at Area Sources (40 CFR Part 63 Subpart HHHHHH) As indicated in the technical review document to support the second renewal (issued December 1, 2008), the Division considers that any spray coatings of motor vehicles and mobile equipment and spray application of coatings that contain the target HAP at this facility would meet the definition of facility maintenance. The source indicated that none of the paint stripping chemicals used at the facility contain methylene chloride; therefore, the provisions in 40 CFR Part 63 Subpart HHHHHH do not apply. Reciprocating Internal Combustion Engines (40 CFR Part 63 Subpart ZZZZ) The reciprocating internal combustion engine (RICE) MACT was signed as final on February 26, 2004 and was published in the Federal Register on June 15, 2004. Under this rulemaking only RICE that were > 500 hp and located at major sources of HAPS were subject to the requirements. Subsequent revisions were made to the RICE MACT to address new engines < 500 hp located at major sources and new engines of all sizes at area sources (final rule published January 18, 2008), existing compression ignition engines < 500 hp at major sources and all sizes at area sources (final rule published March 3, 2010) and existing spark ignition engines < 500 hp at major sources and all sizes at area sources (final rule published August 20, 2010). There are no reciprocating internal combustion engines located at this facility; therefore, the requirements in 40 CFR Part 63 Subpart ZZZZ do not apply. Industrial, Commercial and Institutional Boilers located at Area Sources (40 CFR Part 63 Subpart JJJJJJ) Unlike the NESHAP for major sources (40 CFR Part 63 Subpart DDDDD), these requirements only apply to boilers, not process heaters. There is no boilers located at this facility, therefore the requirements in 40 CFR Part 63 Subpart JJJJJJ do not apply. New Source Performance Standards (NSPS) Page 3 EPA has promulgated NSPS requirements for new source categories since the issuance of the second renewal permit for this facility. NSPS requirements generally only apply to new or modified equipment and the Divisions is not aware of any modifications to existing equipment or additions of new equipment that would render equipment at this facility subject to NSPS requirements. However, because the recently promulgated NSPS requirements address equipment that may not be subject to APEN reporting or minor source construction permit requirements, the applicability of some of the newly promulgated requirements are being addressed here. NSPS Subpart JJJJ — Stationary Spark Ignition Engines NSPS Subpart JJJJ applies to stationary spark ignition engines that commenced construction, reconstruction or modification after June 12, 2006 and were manufactured after specified dates. The date the engine commenced construction is the date the engine was ordered by the owner/operator. As indicated previously, there are no engines located at this facility. Therefore, the requirements in NSPS Subpart JJJJ do not apply. NSPS Subpart IIII — Stationary Compression Ignition Engines NSPS Subpart IIII applies to stationary compression ignition engines that commenced construction, reconstruction or modification after July 11, 2005 and were manufactured after specified dates. The date the engine commenced construction is the date the engine was ordered by the owner/operator. As indicated previously there are no engines located at this facility. Therefore, the requirements in NSPS Subpart 1111 do not apply. Regulation No. 7 Requirements The area in which the facility is located was designated nonattainment for the 8 -hour ozone standard in November 2007. In December 2008 Regulation No. 7 was revised to apply to any ozone nonattainment area (the regulation had previously only applied to the 1 -hour Denver Metro ozone attainment/maintenance area or any nonattainment area for the 1 -hour ozone standard). Since this facility is outside of the 1 -hour Denver Metro ozone attainment area but is within the 8 -hour ozone nonattainment area, this facility would potentially be subject to Regulation No. 7 requirements. The applicability of the requirements in Sections XII (oil and gas operations) and XVI (internal combustion engines) were discussed in the technical review document prepared for the second renewal permit (issued December 1, 2008). Specifically these requirements do not apply because the facility is not involved in oil and gas operations and there are no internal combustion engines at the facility. The equipment at this facility is not subject to any of the specific requirements in Regulation No. 7. The diesel storage tank included in the insignificant activity list is exempt from the tank requirements in Sections VI.B.2 and 3 under the provisions of Section Vl.B.1.a. Page 4 Although there is no equipment at this facility subject to any of the specific requirements in Regulation No. 7, existing sources (as defined in Section I.B.2) are subject to RACT requirements in Section II.C.1 if the VOC potential to emit exceeds 100 tons/yr. Since the VOC potential to emit at this facility is below 100 tons/yr the general RACT requirement for existing sources in Section II.C.1 does not apply. Compliance Assurance Monitoring (CAM) Requirements Because neither turbine is equipped with a control device the Compliance Assurance Monitoring (CAM) requirements do not apply to these units. Greenhouse Gas Emissions 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). Repealed APEN Exemptions Since the second Title V renewal permit was processed (issued December 1, 2008) the APEN exemptions for engines — limited size and hours (Reg 3, Part A, Section II.D.1.sss) and emergency generators - limited size and hours (Reg 3, Part A, Section II.D.1.ttt) was repealed. Since there are no engines at this facility, the repealed APEN exemptions do not affect this facility. Ill. Discussion of Modifications Made Source Requested Modifications The source's requested modifications were addressed as follows: October 30, 2012 Renewal Application Page following cover page The source requested that the permit contact be revised. The change has been made as requested. In their comments on the draft permit submitted March 17, 2013 via e- mail, the source requested that the responsible official be changes also. Appendix A The source requested that the plot plan in Appendix A be replaced. The plot plan submitted with the renewal application has been included in the permit. Other Modifications Page 5 In addition to the source requested modifications, the Division has included changes to make the permit more consistent with recently issued permits, include comments made by EPA on other Operating Permits, as well as correct errors or omissions identified during inspections and/or discrepancies identified during review of this renewal. The Division has made the following revisions, based on recent internal permit processing decisions and EPA comments to the Ft. Lupton Combustion Turbines Renewal Operating Permit. These changes are as follows: Page Following Cover Page • Monitoring and compliance periods and report and certification due dates are shown as examples. The appropriate monitoring and compliance periods and report and certification due dates will be filled in after permit issuance and will be based on permit issuance date. Note that the source may request to keep the same monitoring and compliance periods and report and certification due dates as were provided in the original permit. However, it should be noted that with this option, depending on the permit issuance date, the first monitoring period and compliance period may be short (i.e. less than 6 months and less than 1 year). • Under "issued to" revised the address and included the full company name (i.e., "Public Service Company of Colorado", rather than "Public Service Company") General • Revised the headers to include the full company name (i.e., "Public Service Company of Colorado", rather than "Public Service Company"). Section l— General Activities and Summary • Revised the description in Condition 1.1 to indicate that Rawah National Wilderness Area (a federal class I area) is within 100 km of the facility and to correct the citation for the definition of the 8 -hour ozone control area. • Condition 1.4 was revised to remove Section IV, Condition 3.d as a state -only requirement, since EPA approved these provisions into Colorado's SIP effective October 6, 2008. • Revised the title of the second column in Condition 6.1 to state "AIRS Point Number" as this is more appropriate. Section III — Permit Shield • Removed the Colorado Regulation No. 7 requirements (with listed exceptions) from the table in Section 111.1 (specific non -applicable requirements). The Regulation No. 7 requirements now apply to sources located in any ozone nonattainment area. If the source wished to include other specific sections of Reg. 7 in the table in Section III.1 the requirements must be specifically identified and a justification provided. Page 6 Section IV — General Conditions • A version date was added. • The paragraph in Condition 3.d indicating that the requirements are state -only has been removed, since EPA approved these provisions into Colorado's SIP effective October 6, 2008. • The title for Condition 6 was changed from "Emission Standards for Asbestos" to "Emission Controls for Asbestos" and in the text the phrase "emission standards for asbestos" was changed to "asbestos control". • Condition 29 (VOC) was revised primarily to add the provisions in Reg 7, Section III.C as paragraph e although other minor language and format changes were made. Appendices • Language was added to the insignificant activity list in Appendix A to indicate those insignificant activity categories for which records should be available to verify insignificant activity status. • Revised the reports in Appendices B and C to include the full company name (i.e., "Public Service Company of Colorado", rather than "Public Service Company"). • Changed the name of the Division contact for reports in Appendix D. Hazardous Air Pollutant Emissions AP -42 Emission Factors' Pollutant Natural Gas Emission Emissions Factor (tons/yr) (lb/mmBtu) Distillate Fuel Emission Emissions Factor (tons/yr) (lb/mmBtu) Acetaldehyde Acrolein Benzene Ethylbenzene Formaldehyde Naphthalene Propylene Oxide Toluene Xylenes Total 4.00E-05 6.40E-06 1.20E-05 3.20E-05 7.10E-04 2.90E-05 1.30E-04 6.40E-05 2.32E-01 3.71 E-02 6.97E-02 1.86E-01 4,12E-1)0 1.68E-01 7.55E-01 3.71E-01 5.50E-05 2.80E-04 3.50E-05 3.16E-01 1-.61E441 2.01E-01 5.94E-00 2.13E-00 'from AP -42, Section 3.1 (dated 4/00), Tables 3.1-3 and 3.1-4 Page 7 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION OPERATING PERMIT RENEWAL SUMMARY PERMIT NUMBER: 96OPWE154 AIRS ID #: 1230014 DATE: March 19, 2013 APPLICANT: Public Service Company of Colorado — Ft. Lupton Combustion Turbines REVIEW ENGINEER: Jacqueline Joyce SOURCE DESCRIPTION Public Service Company of Colorado (PSCo) has applied for renewal of their Operating Permit issued for the Ft. Lupton Combustion Turbines, located at 15002 Weld County Road 16, Ft. Lupton, CO in Weld County. This facility is an electric power generating station that consists of two (2) simple cycle combustion turbines nameplate rated at 100 MW of power, each, on a gross basis and is classified under SIC 4911. These turbines burn natural gas, Nos. 1 and/or 2 fuel oil or combination. The area in which the plant operates is classified as attainment for all criteria pollutants except for ozone. It is classified as non -attainment for ozone and is part of the 8 -hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1. This source is categorized as a major stationary source for purposes of Prevention of Significant Deterioration (PSD) review requirements (potential to emit 250 tons/yr). This source is categorized as a major stationary source for purposes of non -attainment area new source review requirements (potential to emit of NOx> 100 tons/yr). Rocky Mountain National Park and Rawah National Wilderness Area, both Federal Class I designated areas, are within 100 km of this facility. This source is not subject to the Accidental Release provisions of section 112(r) of the Federal Clean Air Act. Neither turbine is equipped with a control device, therefore, the compliance assurance monitoring (CAM) requirements do not apply. FACILITY EMISSION SUMMARY Pollutant Potential to Emit — 100% Natural Gas Potential to Emit — 100% Nos. 1 and/or 2 Fuel Oil Actual Emissions — Combination3 PM' 580 ' 575 0.2 PM1a 580 575 0.2 SO22 4,644 4,597 1.2 NOx 2,032 5,057 21.4 CO 528 19 4.5 VOC 13.4 2.4 0.2 Total HAPS 5.94 2.13 Highest Single HAP4 4.12 1,61 'PTE, when burning any fuel, is based on the PM limit (0.1 Ibs/mmBtu) x design heat rate x 8760 hrs/yr. Heat input when burning NG is 662.6 mmBtu/hr and when burning DO is 656 mmBtu/hr. 2PTE, when burning Nos. 1 and/or 2 fuel oil, is based on the Reg 1 5O2 limit (0.8 Ibs/mmBtu) x design heat rate x 8760 hrs/yr. 3Actual emissions identified in the table are for both turbines together and include both natural gas and fuel oil combustion. °Highest single HAP is formaldehyde. EMISSION SOURCES The following discussion identifies the more significant changes that were made in the renewal permit. Other minor language changes were made to other permit conditions. Insignificant Activity List — Language was added to the insignificant activity list in Appendix A to indicate those insignificant activity categories for which records should be available to verify insignificant activity status. Permit Shield - Removed the Colorado Regulation No. 7 requirements (with listed exceptions) from the table in Section 111.1 (specific non -applicable requirements). The Regulation No. 7 requirements now apply to sources located in any ozone nonattainment area. 3/19/13 State.co.us E ecutiee Branch Mail - Re: Ft. Lupton State of Colorado Re: Ft. Lupton Joyce - CDPHE,, Jackie <jackie.joyce@state.co.us> To: "Campbell, Chad E" <Chad.Campbell@xcelenergy.com> Chad, Mon, Mar 18, 2013 at 7:38 AM I will just list Gary as the Responsible Official for now. I can pretty much change the RO anytime before the permit is issued. I'll make a note to use the previous reporting periods when I issue this permit. Jackie Joyce Permit Engineer, Operating Permit Unit Colorado Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, CO 80246 Phone: (303) 692-3267 Fax: (303) 782-0278 Jackie.Joyce@state.co.us On Sun, Mar 17, 2013 at 3:46 PM, Campbell, Chad E <Chad.Campbell@xcelenergy.com> wrote: Jackie, I reviewed the draft renewal for Ft. Lupton. I have just a couple items to note. • George Hess has left our company. We have been using Gary as the Responsible Official in his absence. I'm not sure of the company's schedule to name George's replacement. I guess I'm not sure what we should do here. My suggestion is to change Gary over to the RO for this particular permit renewal and then change it later on once George's replacement is named. I'd say that we can wait but I have no idea how long"this may drag out. • Let's go ahead and keep the same reporting periods that we have historically been using for this facility. • I see the new requirement to keep records for those sources listed in the insignificant activity list in order to demonstrate their qualification under the insignificant activity qualification. We will track the qualifications as required. That's it! Thanks again for letting us take a look at the draft permit. Chad Chad Campbell https://mail.g oog le.cornimai l/u/0/?ui=2&ik=4cf2986dc4&view= pt&search=sent&th= 13d7db8d3d551824 1/3 3/19/13 State.co.us Executke Branch Mail - Re: Ft. Lupton Xcel Energy I Responsible By Nature Team Lead - Consulting Bench, Environmental Policy & Services 1800 Ladner Street, Denver, CO 80202, Suite 1300 P: 303.294.2111 F: 303.294.2859 E: chad.campbell@xcelenergy.com XCELENERGY.COM Please consider the environment before printing this email This e-mail, and any attachments, may contain confidential or private material for the sole use of the intended recipient(s). If you are not the intended recipient, please contact the sender by reply mail and delete all copies of this message and any attachments. From: Joyce - CDPHE, Jackie [mailto:jackie.joyce@state.co.us] Sent: Wednesday, February 27, 2013 12:23 PM To: Campbell, Chad E Subject: Ft. Lupton Chad, I just put a hard copy in the mail of the draft permit for Ft. Lupton. I am also providing you with an electronic copy. We are asking for comments by March 29, 2013. Jackie Joyce Permit Engineer, Operating Permit Unit Colorado Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, CO 80246 Phone: (303) 692-3267 Fax: (303) 782-0278 https://mail.g oog le.com/mail/u/0/?ui=2&ik=4cf2986dc4&uew=pt&search=sent&th= 13d7db8d3d551824 2/3 STATE OF COLORADO John W. Hickenlooper, Governor Christopher E. Urbina, MD, MPH 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. • Laboratory Services Division Denver, Colorado 80246-1530 8100 Lowry Blvd. Phone (303) 692-2000 Denver, Colorado 80230-6928 Located in Glendale, Colorado (303) 692-8090 http://www.cdphe.state.co.us Colorado Department of Public Health and Environment February 27, 2013 - Mr. Chad Campbell Environmental Services Xcel Energy 1800 Larimer Street Suite 1300 Denver, CO 80202 SUBJECT: Draft Renewal Operating Permit for Public Service Company — Ft. Lupton Combustion Turbines Dear Mr. Campbell: Enclosed please find a draft of the renewal operating permit for your facility as well as a copy of the technical review summary document. Please review and submit any comments you may have concerning the modified draft operating permit. Following our review of your comments, we will send the draft permit out for a 30 -day Public Comment period and then to EPA for their 45 -day review period. The regulations also require that the applicant receive written notice of their right to a formal hearing before the Colorado Air Quality Control Commission at the same time that the Public Comment packet goes out. You will receive a separate letter containing that information. This draft renewal permit contains the modifications that you requested in your renewal application received on October 30, 2012. The permit was also revised to be more consistent with recently issued permits, correct errors, omissions and discrepancies identified during inspections and/or review of the renewal application and incorporate EPA comments made on other operating permits for similar sources. The changes are summarized in the technical review document for the renewal permit. We would like you to review this permit by March 29, 2013. Feel free to give me a call at (303) 692- 3267 if you have any questions or concerns. - Sincerely, Jacqueline Joyce, Permit Engineer. Operating Permit Unit Stationary Sources Program Air Pollution Control Division Enclosures 1/2/13 State.co.us Executive Branch Mall - RE: Ft. Lupton State of Colorado RE: Ft. Lupton Campbell, Chad E <Chad.Campbell@xcelenergy.com> To: "Joyce - CDPHE, Jackie" <jackie,joyce@state.co.us> Wed, Jan 2, 2013 at 9:30 AM Jackie, Okay, back from vacation and getting back into the swing of things here. See comments below. Chad Chad Campbell Xcel Energy I Responsible By Nature Environmental Services 1800 Larimer Street, Denver, CO 80202, Suite 1300 P: 303.294.2111 F: 303.294.2859 E: chad.campbell@xcelenergy.com XCELENERGY.COM Please consider the environment before printing this email This e-mail, and any attachments, may contain confidential or private material for the sole use of the intended recipient(s). if you are not the intended recipient, please contact the sender by reply mail and delete all copies of this message and any attachments. From: Joyce - CDPHE, Jackie[mailto:jackie.joyce@state.co.us] Sent: Friday, December 28, 2012 10:46 AM To: Campbell, Chad E Subject: Ft. Lupton Ittos:!lmail.a000le.comlmail!?ui=2&ik=4cf2986dc4&view pt&search=inbox&th=13bfc193815a3fc8 1/2 112/13 State.co.us Executive Branch Mail - RE: Ft. Lupton Chad, I was going to start the renewal for Ft. Lupton (it looks so easy and I want to work on something easy). Anyway, I had just a couple of questions. 1. There aren't any engines listed in the insignificant activity list. Is it correct that there are no engines at the facility? If there is an engine (or engines), can you provide me with the engine model and serial no., size (hp), fuel used for the engine (diesel or NG), fuel consumption rate and the date the engine commenced operation. If the engine commenced operation prior to July 1, 2005 then I don't need the manufacture date, otherwise I would like that information also. There are no engines located at Ft. Lupton. I confirmed that the startup engines used on both of the turbines are electric.' 2. The insignificant activity list includes "use of cleaners and solvents in equipment maintenance". Are there any parts cleaners at the facility that would be subject to Reg 7 requirements? There is not a parts cleaner at Ft. Lupton. Hope you had a good Christmas! Jackie Joyce Permit Engineer, Operating Petnul Unit Colorado Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, CO 80246 Phone: (303) 692-3267 Fax: (303) 782-0278 Jackie.JoyceAstate.co.us dtos:/Imail.nooale.com/mail/?ui=2&ik=4cf 2986dc4&v iew=ot&search=inbox&th=13bf c 193815a3f c8 2/2 (� Xcel Energy - Environmental Policy & Services 1800 Larimer Street, Suite 1300 Denver, CO 80202 October 30, 2012 Ms. Jacqueline Joyce Colorado Department of Public Health & Environment Air Pollution Control Division, APCD-SS-B 1 Operating Pennit Unit 4300 Cherry Creels Drive South Denver, CO 80246-1530 Re: Fort Lupton Combustion Turbines Permit #96OPWE154 Operating Permit Renewal Application Dear Ms. Joyce: In accordance with the requirements of Colorado Air Quality Control Commission Regulation No. 3, Part C, Section III.B.6, Public Service Company of Colorado (PSCo) is hereby submitting a renewal application for the PSCo Fort Lupton Combustion Turbines Title V Operating Permit #96OPWE154. This submittal includes an identification of the facility's status as a major source for greenhouse (GHG) emissions, a required assessment of applicability of the Federal Compliance Assurance Monitoring (CAM) rule to the emission sources at the Fort Lupton Combustion Turbines facility, and the required Colorado operating permit application forms (Form 2000-100 and Form 2000-800). Greenhouse Gas Status Assessment An evaluation of the emission sources at the Fort Lupton Combustion Turbine facility was done to assess the potential to emit (PTE) for greenhouse gases (GHG). Based on the analysis this facility is major for GHG emissions. The PTE was calculated according to rules and equations found in Title 40 Part 98 Subpart C, and an assumption that both turbines are running at their max design rate for 8,760 hours per year. A detailed summary of the calculationsare included as an attachment with this submittal. Compliance Assurance Monitoring Assessment Each emission source at the Fort Lupton Combustion Turbine facility was evaluated for CAM applicability as part of the December 1, 2008 permit renewal. The evaluation during that process identified that there are no emission sources at the facility that use a control device to achieve compliance with an emission limitation or standard and thus the provisions of CAM do not apply. That same evaluation and conclusion are valid for this renewal as there have been no new sources added to the facility. Requested Changes PSCo requests that the permit be updated to show Gary Magno as the "Facility Contact Person" for this facility. The contact information for Mr. Magno should be listed as: Tide: Manager, Environmental Services — Air Quality Compliance Phone: (303)294-2177 This change in information has been reflected on Form 2000-100 that is included with this submittal. PSCo requests that the attached updated Facility Plot Plan be added to Appendix A of the renewal. If you have any questions concerning the attached permit application forms or infoiivation, please contact Chad Campbell of Xcel Energy's Environmental Services staff, at (303) 294-2111. Sincerely, Geotge Hess General Manager — Power Generation, Colorado Attachments: As Stated cc: M. Maes — Fort Lupton J. Martinez — Fort Lupton B. Heston — Fort Lupton ES Electronic File r Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division FACILITY IDENTIFICATION SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name and Name . Fort Lupton Combustion Turbines ?p FORM 2000-100 �• %? Rev 06-95 mailing address Street or Route 15002 Weld County Road 16 City, State, Zip Code Ft. Lupton, CO 80621 2. - Facility location Street Address 15002 Weld County Road 16 (No P.O. Box) City, County, Zip Code Ft. Lupton, CO 80621 3. Parent corporation Name Street or Route City, State, Zip Code Country (if not U.S.) Public Service Company of Colorado 1800 Larimer Street Denver, CO 80802 Responsible official Name Title Telephone 'George Hess General Manager — Power Generation, Colorado (303) 628-2679 5. Permit contact person Name Title (If Different than 4) Telephone Gary Magno Manager, Environmental Services — Air Quality Compliance (303) 294-2177 6. Facility SIC code: 4911 7. Facility identification code: CO 1230014 8. Federal Tax I. D. Number 84-6015506 9. Primary activity of the operating establishment: Natural Gas -Fired Electric Generating Station 10. Type of operating permit O New O Modified ® Renewal 11. Is the facility located in a "nonattainment" area: M Yes O No If "Yes", check the designated "non -attainment" pollutant(s): O Carbon Monoxide _ 0 Ozone O PM10 0 Other (specify)_ 12. List all (Federal and State) air pollution permits (including grandfathered units),plan approvals and exemptions issued to this facility. List the number, date and what unitlprocess is covered by each permit. For a Modified Operating Permit, do not complete this item. Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 Colorado Department of Health Air Pollution Control Division Facility Name: Fort Lupton Combustion Turbines Facility Identification Code: CO 1230014 I. ADMINISTRATION 09-94 . This application contains the following forms: ❑D Form 2000-100, Facility Identification ❑ Form 2000-101, Facility Plot Plan ❑ Forms 2000-102, -102A, and -102B, Source and Site Descriptions II. EMISSIONS SOURCE DESCRIPTION Total Number of This Form This application contains the following forms ' (one form for each facility boiler. Printing O Form 2000-200, Stack Identification ❑ Form 2000-300, Boiler or Furnace Operation ❑ Form 2000-301, Storage Tanks ❑ Form 2000-302, Internal Combustion Engine ❑ Form 2000-303, incineration O Form 2000-304, Printing Operations ❑ Form 2000-305, Painting and Coating Operations O Form 2000-306, Miscellaneous Processes O Form 2000-307, Glycol Dehydration Unit ❑. AIR POLLUTION CONTROL SYSTEM _ Total Number of This Form This application contains the following forms: O Form 2000400, Miscellaneous O Form 2000-401, Condensers O Form 2000402, Adsorbers O Form 2000-403, Catalytic or Thermal Oxidation O Form 2000-404, Cyclones/Settling Chambers ❑ Form 2000-405, Electrostatic Precipitators ❑ Form 2000-406, Wet Collection Systems ❑ Form 2000407, Baghouses/Fabric Filters IV. COMPLIANCE DEMONSTRATION Total Number of This Form This application contains the following forms (one for each facility boiler. Printing operation. ❑ Form 2000-500, Compliance Certification - Monitoring and Reporting - ❑ Form 2000-501, Continuous Emission Monitoring O Form 2000-502, Periodic Emission Monitoring Using Portable Monitors O Form 2000-503, Control System Parameters or Operation Parameters of a Process • Form 2000-504, Monitoring Maintenance Procedures ❑ Form 2000-505, Stack Testing ❑ Form 2000-506, Fuel Sampling and Analysis O Form 2000-507, Recordkeeping ❑ Form 2000-508, Other Methods 2 Total Number of This Form V. EMISSION SUMMARY AND COMPLIANCE CERTIFICATION This application contains the following forms quantifying emissions, certifying compliance with applicable requirements, and developing a compliance plan ❑ Form 2000-600, Emission Unit Hazardous Air Pollutants - .Form 2000-601, Emission Unit Criteria Air Pollutants • - Form 2000-602, Facility Hazardous Air Pollutants ■ ❑ Form 2000-603, Facility Criteria Air Pollutants ❑ Form 2000-604, Applicable Requirements and Status of Emission Unit ❑ Form 2000-605, Permit Shield Protection Identification ❑ Form 2000-606, Emission Unit Compliance Plan - Commitments and Schedule 0 Form 2000-607, Plant -Wide Applicable Requirements Form 2000-608, Plant -Wide Compliance Plan - Commitments and Schedule ■ VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief the statements and information contained in this application are true, accurate and B. CERTIFICATION OF FACILITY COMPLIANCE STATUS - FEDERAL/STATE formed after reasonable inquiry, I certify that complete. CONDITIONS (check one box only) is fully in compliance with all applicable is fully in compliance with all applicable any false material statement, representation, misdemeanor and may be punished in © I certify that the facility described in this air pollution permit application requirements. 0 I certify that the facility described in this air pollution permit application requirements, except for the following emissions unit(s): (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes or certification in, or omits material information from this application is guilty of a accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name George Hess Title General Manager — Power Generation, Colorado Signature Date Signed 1` Operating Permit Application Colorado Department of Health Air Pollution Control Division CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 2000-800 09-94 Facility Name: Fort Lupton Combustion Turbines Facility Identification Code: CO 1230014 VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this application are true, accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE -ONLY CONDITIONS (check one box only) I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements, except for the following emissions unit(s): (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in, or omits material information from this application 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 George Hess Title General Manager — Power Generation, Colorado Signature Date Signed SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B 1 4300 CHERRY CREEK DRIVE SOUTH DENVER, .CO 80246-1530 , 4 Subpart C -General Stationary Fuel Combustion - Tier f Calculation Methodology Using Equations C -lb and C -8b - OPTIONAL SPREADSHEET FOR FACILITY AC LC0R01NG PURPOSES VersionITYRT.R PI Todays date 10/1012012 Use one spreadsheet for each fuel. Make additional copies as needed. s nd This spreadsheet is protected and contains locked cells to ensure that you do not inadvertently alter any of the included formulas an lcr calcalculations. To removeand click protection n an natter this spreadsheet, right -click the "worksheet' tab nearthe bottom eathe screen and select"Unpretect Sheet" When prompted for the d, type' that making changes to. an unprotected sheet could result in incorrect calculations and that you are responsible forthe accuracy of the data you report to EPA For additional help. visit the Microsoft Excel Support website (hftimlioffice.microsoftcomfen-ustexcel-help). Equation C-tb: Equation C-Sb: CO 2 = 1 x 10 -3 * Gas * EF CH4 or N2O =1 x10-3 * Fuel * EF F eldyNem r.-iRr "T Rod N pt halorGmupNam?J110 x%"i C tit mtl Typ t —" y+ 56611 FITal ReonNnp Perotl.+._: t'. Unit Tyriep:.'-.. Fuel Input Data Fort Lupton Combustionn Turbines Based on Units 1 &2 both running for8760 hours/year. Each turbine is rated at662.6 mmetulhrwhen firing on natural has IG ] rIF 8 A o'a(n t� f Beat Npul(mmElu)�". to kor Annual CO2 Mass Emissions For the Specific Fuel Type (metric tons) from Equation C -7b 615495.0310400 Enter this value in a-GGRT Annual CH, Mass Emissions For the Specific Fuel Type (metric tons) from Equation C -Bb Note: If you are reporting CH4 emissions from a pulp mill lime kiln located at a 'craft or soda facility under subpart At, you are required to use the emission factors in Table PA -2 per 98.273(c)(2). 11.608]528 Enter this value ine GGRT Annual N00 Mass Emissions For the Specific Fuel Type (metric tons) from Equation C-Sb Note: tryou are reporting N20 emissions from a pulp mill lime kiln located ate kraft or soda facility under subpart AA, you are required to use the emission factors in Table AA -2 per 95173101121. Enter this value in a-GGRT INFORMATION ONLY: Annual CH, Mass Emissions For the Specific Fuel Type Converted to Carbon Dioxide Equivalent (metric tons CO2e) INFORMATION ONLY: Annual N1O Mass Emissions For the Specific Fuel Type Converted to Carbon Dioxide Equivalent (metric tons CO2e) OT Letr`-Y Tll ngR Tale VThreshold 100TPY (TOTAL MeTons GHGs No GWPs A••lietl (TOTAL Metric I vas GWPS A••lied �,i'7 iJJ TailodngRl Title VThreshold = 100,000 TPY 1 I J iUsing Natu2l Gas asaluelsou¢e antlrunntng boN combustion turb_nes fo�8,)60 bourstyearlhese spumes emeetlhoN tM1e NO GWPS Applietlantl GWPS ApplretltbrvsM1olds_ _ _-_-_ _ Subpart C - General Stationary Fuel Combustion-Tier'I Calculation Methodology Using Equations C -lb and C -8b OPTIONAL SPREADSHEET FOR FACILITY RECORDKEEPING PURPOSES Version e-GGRT RY2c1LR.01 Tndays date 10/10/2012 Use one spreadsheet for each fuel. Make additional copies as needed. This spreadsheet is protected and contains locked cells to ensure that you do not inadvertently alter any of the included formulas andlor calculations. To remove this protection and alter this spreadsheet, right -click the "worksheer tab near the bottom of the screen and select "Unprotec1 Sheet. When prompted for the password, type "ONG" and click "OK." Please note that making changes to an unprotected sheet could result in incorrect calculations and that you are responsible for the accuracy of the data you report to EPA. For additional help, visit the Microsoft Excel Support webste(http,Ilofhce.micrasoRcamlen-uslexcel-help). Equation C-1 b: Equation C -Bb: CO , =1 x 10 —3 * Gas * EF CH4 or N2O = 1 x 10-3 * Fuel * EF F6202/ N e RanatieriNginnTTIDDIDIDT2DIDTIDMI U h G uo`Nemellni? ;.FTlSlC,1 OnnfigfiratiEnTnieDDIDDD.IfinDeTa F IIF ITyp TUTi - RengingfilEdegdEID222 CYthifeenfilliaDDIDCuTruniangifiiiii ii UnsType: Trutt. Combustion Turbine :' wetGUNa2) T.Fx ° .0/"3., a -. .35+4.3. +:'iv , -K, - 3- "n., , ,eYAT^; Fuel Input Data Based on Units 162 bath running for 8760 hours/year. Each turbine is rated at 656 mmritu/hr when fidng on fuel ol. Annual CO2 Mass Emissions For the Specific Fuel Type (metric tons) from Equation C -lb 858031.1552000 Enter this value in e-GGRT Annual CH4 Mass Emissions For the Specific Fuel Type (metric tans) from Equation C -Bb Note: If you are reporting CH4 emissions from a pulp mill lime kiln located at a kraft or soda facility under subpart AA, you are required to use the emission factors in Table AA -2 per 98.272(c)(2). 34.4793600 IS Ig Enter this value in e-GGRT Annual N20 Mass Emissions For the Specific Fuel Type (metric tons) from Equation C -Bb Note If you are reporting N20 emissions from a pulp mill lime kiln (( F e1SP f,rdl£ 5 ni located at a Draft or soda facility under subpartAA yoinare FbdeO5,NO h_nlTbitOfkg 00006 : required to use the emissionfactors in Table AA -2 per 98.273(0)(2). 6.8958720 n'(mglc ion Enter this value in e-GGRT INFORMATION ONLY: Annual CH, Mass Emissions For the Specific Fuel Type Converted to Carbon Dioxide Equivalent (metric tons CO2e) INFORMATION ONLY: Annual N20 Mass Emissions For the Specific Fuel Type Converted to Carbon Dioxide Equivalent (metric tons CO2e) 'TOTAL Metric Tons GHGs No GD/R A••lied 'rlt l};: Tailoring Rule TO V Threshold Po TPY Tailoring Rule Tale V Threshold P100.000 TPY (TOTAL Metric Tons CO2e GWPs A. •lied I I IUSFutl oil asaluelao— andru n both combussUulbinestor 8.76'0 hpsuUnrrbesesoumeserceedb.SeP No GWP ead.2nd OWPsA led Nresbolds. 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