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Home My WebLink About20120601 STATE l 4 RADO John W. Hickenlooper, Governor 1011 MAR I A In. O� of•oo�o Christopher E.Urbina,MD, MPH L ft h� RJ: 4, Executive Director and Chief Medical Officer tie -� Dedicated to protecting and improving the health and environment of the people of ColorD ; � . ECEIVED .4300 Cherry Creek Dr. S. Laboratory Services Division •taus. Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health http://www.cdphe.state.co.us and Environment February 24, 2012 Mr. Steve Moreno Weld County Clerk 1402 N. 17th Ave. Greeley, CO 80631 Dear Mr. Moreno: On February 29, 2012,the Air Pollution Control Division will publish a public notice for Public Service Company of Colorado in The Greeley Tribune. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty(30)days from the date the public notice is published. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health & Environment APCD-SS-B1 1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Ellen Evans Regards, Eller4Eva Public NotYYce Coordinator Stationary Sources Program Air Pollution Control Division Enclosure ----R,&\\c 'E-)SlQ)`1° e./C' P , iii- 2012-0601 3-1- 1 'a 3 -i,/a NOTICE OF A PROPOSED RENEWAL TITLE V OPERATING PERMIT WARRANTING PUBLIC COMMENT NOTICE is hereby given that an 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 , Suite 1300 Denver, Colorado 80202 Facility: Public Service Company of Colorado-Rocky Mountain Energy Center 6211 Weld County Road 51 Keenesburg, CO 80643 Public Service Company of Colorado has applied for a Renewal Operating Permit for their facility in Weld, County, CO. This facility consists of two natural gas-fired combustion turbines used to generate electricity. Each turbine is equipped with a heat recovery steam generator and natural gas-fired duct burners. A copy of the applications, including supplemental information, the Division analysis, and a draft of the Renewal Operating Permit 05OPWE279 has been filed with the Weld County Clerk's office. Based on the information submitted by the applicant, the Division has prepared the draft renewal operating permit for approval. Any interested person may contact Jackie Joyce at 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). If requested,the hearing will be held before the Commission at their regularly scheduled meeting 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 phone number, and 3) state the reason(s) for the request, the manner in which the person is affected by the proceedings, and an explanation of why the person's interests are not already adequately represented. The Division will receive and consider the written public comments and requests for any hearing for thirty calendar days after the date of this Notice. RELEASED TO: The Greeley Tribune on PUBLISHED: February 29, 2012 February 24, 2012 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION OPERATING PERMIT RENEWAL SUMMARY PERMIT NUMBER: 05OPWE279 AIRS ID#: 1231342 DATE: February 24, 2012 APPLICANT: Public Service Company of Colorado— Rocky Mountain Energy Center REVIEW ENGINEER: Jacqueline Joyce SOURCE DESCRIPTION Public Service Company of Colorado (PSCo) has applied for renewal of the Operating Permit issued for the Rocky Mountain Energy Center located at 6211 Weld County Road 51 in Keenesburg, Colorado in Weld County. This facility consists of two combustion turbines, each equipped with a heat recovery steam generator(HRGS) and duct burner used to generate electricity and is classified under SIC 4911. Natural gas is the only fuel used in these turbines and duct burners. 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 this facility. Rocky Mountain National Park, a Federal Class I designated area, is within 100 km of this facility. This source is subject to the Accidental Release provisions of section 112(r) of the Federal Clean Air Act. The turbines are subject to the compliance assurance monitoring (CAM) requirements in 40 CFR Part 64 with respect to NOx, CO and VOC emissions. FACILITY EMISSION SUMMARY Potential To Emit Emission Unit PM PM10 SO2 NOx CO VOC HAPS Turbines/HRSGs 126.8 126.8 11.8 240.4 782.2 50.6 12.11 Aux. Boiler' 2.28 2.28 0.07 4.7 4.75 0.64 2.82E-03 Emergency 0.40 0.40 0.16 6.88 8.48 1.00 8.51E-04 Generator Fire Water Pump3 0.02 0.02 0.02 0.60 0.36 0.07 8.26E-03 Cooling Tower4 19.3 19.3 0.89 0.89 Total 148.8 148.8 12.06 252.58 795.79 53.20 13.01 'S02 and V0C emissions are based on the permitted fuel limit and AP-42 emissions factors (Section 1.4,dated 3/98, Table 1.4-2). 2Emissions based on 500 hours/year of operation (per September 6, 1995 EPA Memo, "Calculating Potential to Emit(PTE)for Emergency Generators"), maximum hp and for all but S02 manufacturer's emission factors, S02 based on sulfur content of 0.05 wt% (fuel density 7.05 lb/gal). Emissions based on 500 hours/year of operation, maximum hp and for all but S02 manufacturer's emission factors, S02 based on sulfur content of 0.05 wt% (fuel density 7.05 lb/gal). 500 hours per year of operation was used in accordance with EPA's September 6, 1995 memo. Although that memo addresses emergency generators only, the Division considers the memo is appropriate to use for emergency fire pump engines. 4V0C emissions are based on the permitted water circulation rate and the emission factor from"Locating and Estimating Air Emissions from Sources of Chloroform", EPA-450/4-84-007c,March 1984, for re-circulating units. All V0C is chloroform. 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. General—This facility was previously owned by Rocky Mountain Energy Center, LLC, which was purchased by PSCo in December 2010. The transfer of ownership is reflected in the revised permit. Turbines, HRSGs and Duct Burners (Section 11.1)—The performance test requirements for PM were revised to specify a test frequency of every 5 years. An alternate BACT limit was included for periods of combustion tuning and testing. This limit may be used for 60 hours per calendar year for both units (turbine/HRSG/duct burner) combined. Revisions were made to the monitoring language for NOx and CO to indicate that replaced and bias-adjusted data are not used to assess compliance with the short-term limits (i.e., BACT limits) but are used to assess compliance with the annual limitations. TECHNICAL REVIEW DOCUMENT For RENEWAL/MODIFICATION of OPERATING PERMIT 05OPWE279 Public Service Company of Colorado — Rocky Mountain Energy Center Weld County Source ID 1231342 Prepared by Jacqueline Joyce August and September 2011 Revised December 2011 and February 2012 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 original Operating Permit was issued July 1, 2007. The expiration date for the permit is July 1, 2012. The source submitted a renewal application on May 10, 2011. Prior to and after submittal of the renewal application, the source submitted applications on December 20, 2010, March 23 and September 16, 2011 to modify the permit for this facility. The December 20, 2010 submittal indicated that Public Service Company of Colorado (PSCo) purchased Rocky Mountain Energy Center, LLC and its assets from Calpine Operating Services Corporation and PSCo subsequently dissolved Rocky Mountain Energy Center, LLC. The December 20, 2010 submittal also requested an administrative amendment to revise the permit to reflect the change in ownership of the facility. The March 23, 2011 application requests a minor modification of the permit to update the list of insignificant activities in Appendix A and to include a cold cleaner solvent vat and a 500 gallon gasoline storage tank in Section II of the permit. The September 14, 2011 application requests a minor modification of the permit to address the operational status of the boiler. 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 on May 10, 2011, modification applications submitted on December 20, 2010, March 23 and September 16, 2011, comments on the draft permit and technical review document receive on February 6, 2012, 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.cdphe.state.co.us/apiTitlev.html. Page 1 Any revisions made to the underlying construction permits associated with this facility made in conjunction with the processing of this operating permit application have been reviewed in accordance with the requirements of Regulation No. 3, Part B, Construction Permits, and have been found to meet all applicable substantive and procedural requirements. This operating permit incorporates and shall be considered to be a combined construction/operating permit for any such revision, and the permittee shall be allowed to operate under the revised conditions upon issuance of this operating permit without applying for a revision to this permit or for an additional or revised construction permit. II. Description of Source The facility consists of two natural gas fired combustion turbines, two heat recovery steam generators (HRSG), each equipped with natural gas fired duct burners, a steam turbine, cooling tower and auxiliary boiler. There are two diesel fired engines, one driving an emergency generator and one driving a fire pump. There is also a cold cleaner solvent vat and a gasoline storage tank that are included in Section II of the permit. The RMEC has the capacity to generate up to 630 MW of electricity. Each combustion turbine can generate approximately 152 MW, with an additional 326 MW (at peak capacity) from the steam turbine. The turbines are not equipped with a by-pass stack, therefore, the turbines only operate in combined cycle mode (i.e. turbine plus HRSG). The facility is located at 6211 Weld County Road 51, just east of the town of Hudson, in Weld County Colorado (bounded by CR 49 to the west, CR 16 to the north and CR 51 to the east). The area in which the plant operates is designated as attainment for all criteria 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 this facility. Rocky Mountain National Park, a federal class I designated area is within 100 km of this facility. Based on the information provided in the renewal application, no changes have been made to any of the significant emission units. The summary of emissions that was presented in the Technical Review Document (TRD) for the original permit has been reproduced here. Since there have been no changes to permitted emission and/or fuel consumption limitations and no new emission units have been added to the facility, the potential to emit (PTE) has not changed. Potential emissions (in tons per year) at the facility are as follows: Page 2 Potential To Emit Emission Unit PM PM-lo SO2 NOx CO VOC HAPS - - Turbines/HRSGs 126.8 126.8 11.8 240.4 782.2 50.6 See Table on Page 16 Aux. Boiler' 2.28 2.28 0.07 4.7 4.75 0.64 Emergency 0.40 0.40 0.16 6.88 8.48 1.00 Generator Fire Water 0.02 0.02 0.02 0.60 0.36 0.07 Pump3 Cooling Tower" 19.3 19.3 0.89 -it-4.- :. . ,G.— air 4' .a h - Y. '`y w Ale.,a Total 148.8 148.8 12.06 _ 252.58 795.79 53.20 13.01 TSO2 and VOC emissions are based on the permitted fuel limit and AP-42 emissions factors (Section 1.4, dated 3/98, Table 1.4-2). 2Emissions based on 500 hours/year of operation (per September 6, 1995 EPA Memo, "Calculating Potential to Emit(PTE) for Emergency Generators"), maximum hp and for all but SO2 manufacturer's emission factors, SO2 based on sulfur content of 0.05 wt % (fuel density 7.05 lb/gal). 3Emissions based on 500 hours/year of operation, maximum hp and for all but SO2 manufacturer's emission factors, SO2 based on sulfur content of 0.05 wt % (fuel density 7.05 lb/gal). 500 hours per year of operation was used in accordance with EPA's September 6, 1995 memo. Although that memo addresses emergency generators only, the Division considers the memo is appropriate to use for emergency fire pump engines. 4VOC emissions are based on the permitted water circulation rate and the emission factor from "Locating and Estimating Air Emissions from Sources of Chloroform", EPA-450/4-84-007c,March 1984, for re- circulating units. All VOC is chloroform. Except as indicated in the footnotes in the above table, the potential to emit of criteria pollutants and total HAPs is based on permitted emission limits. In general, actual emissions have not been reported for the emission units at this facility and fees have generally been paid on potential to emit. However, PSCo reported actual emissions for the turbine/HRSGs for calendar year 2010. Actual emissions from the turbine HRSGs are shown in the table below: Emission Unit PM PKo SO2 NOx CO VOC HAPS - CT-01 5.6 5.6 3.5 40.5 14.6 4.08 2.78 CT-02 5.4 5.4 3,2 40 11.9 0.8 2.49 Total 11 11 6.7 80.5 26.5 4.88 5.27 i The breakdown of HAP emissions by emission unit and individual HAP is provided on page 16 of this document. The method of estimating HAP emissions is indicated in the footnotes on this table. Page 3 MACT Requirements Although the facility is not a major source for HAPS, the EPA has been promulgating rules for area sources (sources that are not major), 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) The final rules for paint stripping and miscellaneous surface coating were published in the Federal Register on January 9, 2008 and apply to area sources that perform paint stripping operations using methylene chloride, spray application of coatings to motor vehicles and mobile equipment and spray application of coatings that contain the target HAPS (chromium, lead, manganese, nickel or cadmium). As indicated in 40 CFR Part 63 § 63.11170(a)(2) and (3), spray applications (to motor vehicles and using coatings that contain the target HAPS) that meet the definition of facility maintenance are not subject to the requirements in this rule. 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 (RICE) (40 CFR Part 63 Subpart ZZZZ) Final revisions to the RICE MACT were published in the Federal Register on March 3, 2010 and these revisions address existing (commenced construction prior to June 12, 2006) compression ignition engines at area sources. An emergency generator is included in Section II of the permit and the insignificant activity list indicates that there is a diesel-fired engine driving a fire pump at the facility. Both engines are considered emergency engines. Since the equipment at this facility commenced operation in March 2004, these engines are considered existing engines and are subject to requirements in MACT ZZZZ. Since the engines are considered emergency engines they are only subject to management standards (oil and filter change and inspect air cleaners, hoses and belts). The source is required to comply with these requirements by May 3, 2013. The appropriate applicable requirements will be included in the permit. Industrial, Commercial and Institutional Boilers at Area Sources (40 CFR Part 63 Subpart JJJJJJ) EPA promulgated National Emission Standards for Hazardous Air Pollutants for Area Sources: Industrial, Commercial, and Institutional Boilers on March 21, 2011. Unlike the Boiler MACT for major source (40 CFR Part 63 Subpart DDDDD), this rule only applies to boilers, not process heaters. In addition, in accordance with § 63.11195(e) Page 4 gas fired boilers are not subject to the requirements in 40 CFR Part 63 Subpart JJJJJJ. Therefore, these requirements do no apply to the equipment at this facility. Compliance Assurance Monitoring (CAM) Applicability CAM applies to any emission unit that is subject to an emission limitation, uses a control device to achieve compliance with that emission limitation and has potential pre-control emissions greater than major source levels. CAM typically applies during renewal, except in situations where controlled emissions are above the major source level and the initial Title V application was submitted after April 20, 1998. Since the initial Title V permit application was submitted on March 14, 2005 and controlled emissions of NOx and CO were over the major source level, CAM was included in the initial Title V permit with respect to those pollutants. No revisions to CAM for NOx and CO are necessary. However, since the oxidation catalyst control VOC emissions, as well as CO emissions, and uncontrolled emissions of VOC exceed the major source level, CAM also applies to the turbines with respect to VOC emissions. Therefore, CAM with respect to VOC emissions must be addressed in the renewal permit. Greenhouse Gases The potential to emit of greenhouse gases from this facility exceeds 100,000 tons/yr CO2e. Future modifications at this facility will have to be evaluated to determine if GHG emissions are subject to regulation. III. Discussion of Modifications Made Source Requested Modifications December 20, 2010 Administrative Amendment The December 20, 2010 modification request was to reflect that PSCo purchased Rocky Mountain Energy Center, LLC from Calpine Operating Services Corporation. As specified in Colorado Regulation No. 3, Part A, Section l.B.1.a.(iv) a transfer of ownership is considered an administrative amendment. The following revisions were made to address the December 20, 2010 modification request: • PSCo was indicated as the owner on the page following the cover page, the headers and footers and in Appendices B and C. • Section I, Condition 1.3 was revised to indicate that the construction permit was formerly issued to Rocky Mountain Energy Center, LLC. • The responsible official and permit contacts were revised (page following cover page) and the designated representative and the alternate designated representative (Section III) were revised. Page 5 March 23, 2011 Minor Modification In the March 23, 2011 minor modification application PSCo identified equipment at the facility that is not included in the current permit. All the equipment that is not identified in the current permit is exempt from both APEN reporting and construction permit requirements and as a result most of the requested changes are to the insignificant activity list in Appendix A of the permit. The Division considers that changes to the permit to update the insignificant activity list may be processed as an administrative amendment, since the appendices are intended for information purposes only and are not considered state or federally enforceable. In accordance with the "catch-all" in Colorado Regulation No. 3, Part C, Section II.E, sources that are subject to any federal or state applicable requirements such as National Emission Standards for Hazardous Air Pollutants (NESHAP) or Colorado Regulation No. 7 cannot be considered insignificant activities. Since the cold cleaner solvent vat and the gasoline storage tank are subject to requirements in Colorado Regulation No. 7 and 40 CFR Part 63, Subpart CCCCCC, respectively, they cannot be considered insignificant activities. Colorado Regulation No. 3, Part C, Section X.A identifies those modifications that can be processed under the minor permit modification procedures. Specifically, minor permit modifications "are not otherwise required by the Division to be processed as a significant modification" (Colorado Regulation No. 3, Part C, Section X.A.6). The Division requires that "any change that causes a significant increase in emissions" be processed as a significant modification (Colorado Regulation No. 3, Part C, Section I.A.7.a). Since both of these emission units have emissions below the APEN de minimis level (1 ton/year of VOC), they do not cause a "significant increase in emissions" and the modification to incorporate the cold cleaner solvent vat and gasoline storage tank can be processed as a minor modification. Colorado Regulation No. 3, Part C, Section I.A.7.b specifies that "any change that is considered a modification under Title I of the Federal Act" be processed as a significant permit modification. Colorado Regulation No. 3, Part G, Section I.L (revisions adopted July 15, 1993, Subsection I.G for modifications) describes more specifically what constitutes a modification under Title I of the Federal Act and Part G indicates that a modification which triggers 112 requirements (e.g. NESHAP requirements, such maximum achievable control technology (MACT) requirements for major sources and generally achievable control technology (GACT) requirements for area sources) is considered a Title I modification. Since the gasoline storage tank has a monthly throughput less than 10,000 gallons it is subject to work practice requirements. In accordance with Division policy (PS Memo 99-06, revised February 27, 2008) the Division considers that public comment would not be required for area sources that are subject to non-substantive MACT requirements, such as recordkeeping or work practice requirements. Therefore, since public comment would not be required if this gasoline storage tank were processed as a construction permit and because the GACT requirements are not substantive (i.e. not an emission limitation, control requirement or Page 6 design restriction), the Division considers that incorporating these provisions for the gasoline storage tank into the Title V permit qualifies as a minor modification. The following changes were made to the permit to address the March 23, 2011 modification request: • The insignificant activity list in Appendix A was revised as requested, except that the category for the condensate tank was revised to Reg 3, Part C, Section I I.E.3.fff. Note that unlike the 500 gallon gasoline storage tank, the 100 gal portable gasoline storage tank is not subject to the requirements in 40 CFR Part 63 Subpart CCCCCC (National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities). Subpart CCCCCC defines a gasoline dispensing facility as "any stationary facility which dispenses gasoline into the fuel tank of a motor vehicle, motor vehicle engine, nonroad vehicle, or nonroad engine, including a nonroad vehicle or nonroad engine used solely for competition." Since the tank is mounted in the back of a facility vehicle, it is not considered stationary and therefore is not subject to the requirements in Subpart CCCCCC. • The 500 gallon gasoline storage tank and the cold cleaner solvent vat were included in the tables in Section I, Condition 6.1 and Appendices B and C. • Provisions for the gasoline storage tank and the cold cleaner solvent vat were included in "new" Section 11.7 and 11.8, respectively. May 20, 2011 Renewal Application The source did not request any specific changes to the permit as part of the renewal but did address CAM as it applies to VOC emissions from the turbine/HRSGs. The current permit only addresses CAM with respect to the NOx and CO emission limitations. The source proposed the use of CO as a surrogate indicator for VOC emissions as CAM. Since the oxidation catalyst reduces both CO and VOC emissions and since CO emissions are continuously monitored, the Division considers that CO is an appropriate indicator to monitor in order to assess whether the control device is operating properly. With respect to the VOC emissions limitations, exceedances of the short-term and annual CO emission limitations shall be indicators that the oxidation catalyst is not functioning properly and shall be reported as excursions. The permit was revised as follows to address the CAM requirements for VOC: • Condition 1.13.1 was revised and reformatted to indicate that CAM applies with respect to VOC emissions and to identify excursions with respect to the VOC emission limitations. Page 7 Note that the current permit does not include a CAM plan since CAM for CO and NOx relies on the CEMS and measures direct compliance with those emission limitations. 40 CFR Part 64 § 64.3(d)(2) specifies that CEMS that meet the requirements of 40 CFR Part 60 § 60.13 and Appendix D and 40 CFR Part 75 shall be deemed to satisfy the general design criteria in 40 CFR Part 64 § 64.3(a) and (b); therefore, a CAM plan was not included. Since the indicator for VOC is the CO emission limitations, which are monitored by the CO GEMS, for the same reason a CAM plan is not included in the permit for CAM with respect to the VOC emission limitations. September 16, 2011 Minor Modification In their September 16, 2011 modification application, PSCo indicated that the Rentech boiler has not been operated since 2006 due to severe boiler tube damage. PSCo is unsure at this point with respect to future operation of the boiler and does not currently plan to repair and return the boiler to service. The current permit requires that a performance test be conducted on the boiler within the last 18 months of the permit term to monitor compliance with the CO BACT limit. PSCo has requested that the performance test for this boiler be triggered upon the re-start of the boiler and that future performance tests be based on the actual operation of the boiler rather than a set time period. Colorado Regulation No. 3, Part C, Section X.A.2 specifies that minor permit modifications may be used for modifications that do not involve significant changes to existing monitoring, reporting, or recordkeeping requirements in a permit. The Division considers that since the request is not a change in the frequency of performance testing but a change to the date by which the performance tests are to be conducted, it is not a significant change in existing monitoring. Therefore, the Division agrees that this modification can be processed as a minor modification. The following changes were made to the permit to address the September 16, 2011 modification request: • Condition 3.4.1.2 was revised to specify that the performance test be conducted within 60 days of re-starting the boiler and that testing thereafter will be based on hours of operation. February 6, 2012 Comments on the Draft Permit and Technical Review Document In their February 6, 2012 comments on the draft permit and technical review document, the draft permit, the source requested the following changes: Section 11.1 - Turbines The source requested that alternative NOx and CO BACT limits be included in the permit for periods of combustion tuning and testing. The Division has generally included alternative BACT and/or RACT limits during periods of combustion tuning and Page 8 testing for other turbines. The alternative BACT and/or RACT limits have typically been set at the alternative startup/shutdown limits, with limitations on the number of hours that these limits can be utilized. In their February 6, 2012 comments, PSCo asked that the alternative limits for combustion tuning and testing be limited to 60 hours per calendar year for both units combined. The permit was revised to include combustion tuning and testing limits for these units with the limits set at the level of the startup and shutdown BACT limits. The averaging time for the combustion tuning and testing will be set at an hourly average. Section 11.3 —Auxiliary Boiler In their September 16, 2011 modification application, the source requested that a performance test be conducted within "sixty (60) days of re-starting the boiler". In their comments on the draft permit, PSCo requested that this language be revised to specify "boiler operating days" to a address the situation when the repairs to the boiler do not succeed and repairs extend beyond 60 days. The permit language was revised as requested. Section 11.6 — Continuous Emissions Monitoring Requirements • PSCo requested that the RATA frequency for the CO CEMS (Condition 6.1.1.2.c) be revised to specify 40 CFR Part 60 Appendix F, rather than 40 CFR Part 75 Appendix B. This change was made as requested. • PSCo requested that the QA/QC plan requirements for the CO CEMS (Condition 6.1.2.2) be based on 40 CFR Part 75, Appendix B, rather than 40 CFR Part 60, Appendix F. This change has been made as requested. In addition, the Division removed the phrase regarding CGA testing as this is addressed in 40 CFR Part 75, Appendix B. Other Modifications In addition to the modifications requested by the source, 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 Rocky Mountain Energy Center Renewal Operating Permit with the source's requested modifications. These changes are as follows: Page Following Cover Page • The monitoring and compliance periods and report and certification due dates are shown as examples. The appropriate monitoring and compliance periods Page 9 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). Section l — General Activities and Summary • Revised the language in Condition 1.1 to address attainment status of the area in which the facility is located and corrected the citation for the definition of 8-hr ozone control area. • Made minor revisions to the language in Condition 3 (prevention of significant deterioration) to be more consistent with other permits. In addition, revised this condition to address the attainment status of the area in which the facility is located. • Removed the third column labeled "Facility ID" from the Table in Condition 6.1. The first column was relabeled "Emission Unit No./Facility ID" • Added a column to the Table in Condition 6.1 for the startup date of the equipment. In addition, the diesel-fired fire pump engine was included in the table. Section 11.1 —Turbines • Revised the stack test requirement in Condition 1.2.2.2 to specify that performance tests be conducted every five years, rather than within 18 months of expiration of the permit term as this provides a more definitive time frame for the tests. The current permit requires a stack test within the last 18 months of the permit term to monitor compliance with the PM BACT limit. Testing was conducted on September 9, 2011 for Unit 1 (CT-01) and September 8, 2011 for Unit 2 (CT-02). The average test results for Unit 1 were 0.00361 Ib/MMBtu and 0.00449 lb/MMBtu for Unit 2, which is 49 and 61% of the standard respectively. Frequency of tests hereafter will be every five years. • Revised Condition 1.2.1 to include the PM and PKo emission factors from the most recent performance test. • Revised the monitoring language for the NOx and CO BACT limits (Conditions 1.5.1.5, 1.5.1.6, 1.6.1.5 and 1.6.1.6) to indicate that replaced and bias-adjusted data are not used in assessing compliance with BACT limits. Page 10 • Revised the monitoring language for the NOx and CO annual emission limitations (Condition 1.5.2 and 1.6.2) to specify how lbs/hr emission rates are calculated and to indicate that replaced data is used to assess compliance with the annual limitations. Section 11.2 — Emergency Compression Ignition Engines Emergency Generator As discussed previously, with the March 3, 2010 revisions to the RICE MACT (40 CFR Part 63 Subpart ZZZZ), the emergency generator is subject to requirements under the RICE MACT. Therefore, the following revisions were made: • Added the appropriate 40 CFR Part 63 Subpart ZZZZ requirements— management practices (oil and filter change, inspect air cleaner and inspect hoses and belts). • Added the appropriate 40 CFR Part 63 Subpart A requirements Since this engine is not subject to any emission limitations, monitoring requirements, notification and reporting requirements the requirements in §§ 63.7. 63.8, 63.9 and 63.10 do not apply. In addition, since this emission unit is an existing unit the requirements in § 63.5 (preconstruction review and notification requirements) do not apply. Finally, Table 8 of Subpart ZZZZ indicates that operation and maintenance requirements in 63.6(e) do not apply. Therefore, the permit will only include the prohibition and circumvention requirements in § 63.4. The following additional changes were made to the permit conditions related to this engine: • The fuel sampling requirement (Condition 2.4) was removed. The purpose of the fuel analyses was to determine the sulfur content of the fuel. Based on the AP- 42 emission factor for SO2 emissions noted in the current permit, compliance with the Reg 1 SO2 limit is met as long as the fuel sulfur is below 0.79 weight percent (the current permit indicates 0.5 weight percent, but at that sulfur content SO2 emissions are 0.505 lb/mmBtu, well below the 0.8 Ib/mmBtu limit). However, since diesel fuel with a sulfur content at or above 0.79 weight percent is not available, the Division considers that the fuel sampling requirement is not necessary. • The Division included the Reg 1 30% opacity limit in the permit. The opacity limit applies during certain special conditions and in the technical review document for the original permit (issued July 1, 2007), the Division considered that none of those special conditions apply. Although the Division considers that startup may be short (i.e. less than 6 minutes) and thus the 30% opacity limit would not apply, after further review the Division has opted to include the 30% opacity Page 11 requirement in the permit. This is consistent with the opacity requirements typically included for diesel fuel-fired engines. • The opacity monitoring has been revised to require an additional opacity observation if the engine is operated for more than 250 hours in any calendar year period. Emergency Fire Pump Engine In addition, as discussed previously, there is an emergency fire pump engine that is subject to the March 3, 2010 revisions to the RICE MACT. This engine is currently included in the insignificant activity list and is considered insignificant under the provisions in Colorado Regulation No. 3, Part C, Sections II.E.3.xxx (stationary internal combustion engines). However, under the "catch-all" provisions in Regulation No. 3, Part C, Section II.E, sources that are subject to any federal or state applicable requirement, such as National Emission Standards for Hazardous Air Pollutants (NESHAPs), may not be considered insignificant activities. Since this engine is subject to RICE MACT requirements it can no longer be considered an insignificant activity. Although the unit cannot be considered an insignificant activity, since the Division has not adopted either the January 18, 2008, March 3, 2010 or August 20, 2010 revisions to the RICE MACT, all of which address area sources, the engine is still exempt from APEN reporting and minor source construction permit requirements. Therefore the emergency fire pump engine and the appropriate applicability requirements have been included in Section 11.2 of the permit. The engine description is as follows: John Deere, Model No. 6081AF001, Diesel Fuel-Fired Internal Combustion Engine, Serial No. RG6081A159985, rated at 182 hp, with a heat input rate of 1.28 mm8tu/hr (9.3 gal/hr based on a diesl fuel heat content of 137,000 Btu/gal). The appropriate applicable requirements for this engine are as follows: • Except as provided for below, visible emissions shall not exceed 20% opacity (Reg 1, Section II.A.1) • Visible emissions shall not exceed 30% opacity, for a period or periods aggregating more than six (6) minutes in any sixty (60) minute period, during fire building, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment, when burning coal (Reg 1, Section II.A.4) Based on engineering judgment, the Division believes that the operational activities of fire building, cleaning of fire boxes and soot blowing do not apply to diesel engines. In addition, since this engine is not equipped with control equipment the operational activities of adjustment or occasional cleaning of control equipment also do not apply to this engine. Finally, based on engineering Page 12 judgment, it is unlikely that process modifications will occur with this emergency engine. Therefore, for this unit the 30% opacity provision only applies during startup. • SO2 emission shall not exceed 0.8 lbs/mmBtu (Reg 1, Section VI.B.4.b.(i)). • 40 CFR Part 63 Subpart ZZZZ requirements— management practices (oil and filter change, inspect air cleaner and inspect hoses and belts) • 40 CFR Part 63 Subpart A requirements Since this engine is not subject to any emission limitations, monitoring requirements, notification and reporting requirements the requirements in §§ 63.7. 63.8, 63.9 and 63.10 do not apply. In addition, since this emission unit is an existing unit the requirement in § 63.5 (preconstruction review and notification requirements) do not apply. Finally, Table 8 of Subpart Z777 indicates that operation and maintenance requirements in 63.6(e) do not apply. Therefore, the permit will only include the prohibition and circumvention requirements in § 63.4. Since this unit is not subject to APEN reporting or minor source construction permit requirements, the permit will not include any requirements for calculating emissions. Section 11.3 — Boiler • The language in Condition 3.8 was revised to more closely match the language in the regulation. In the current permit, this condition does not include the requirement for the diluents CEMS (O2 or CO2) which is specified in NSPS Subpart D § 60.48b(b)(1). • Revised the language in Condition 3.3.2 to indicate how lb/hr emission rates are calculated. Section 11.6 — Continuous Emission Monitoring Requirements • Removed the statement in Condition 6 indicating that the permittee shall have 60 days following the initial permit issuance for software revisions and testing since this deadline has passed. • Removed the phrase "and the traceability protocols of Appendix H" from Condition 6.1.1.3, since Appendix H of the current version of 40 CFR Part 75 is "reserved". Note that this condition specifies that the continuous emission monitoring systems are subject to the requirements of 40 CFR Part 75 and that would include any applicable appendices, regardless of whether or not they are specifically called out in this condition. • Added language ("new" Condition 6.1.1.4) to clarify that the data acquisition and handling system (DAHS) shall be able to manipulate data in the units of all Page 13 emission limitations and to require that relative accuracy test audits (RATAs) be conducted in units of all emission limitations. • Added language to Condition 6.3 (data replacement requirements) to make it clear that replaced and bias-adjusted data are used to monitor compliance with the annual limitations. • Revised the reporting frequency in condition 6.5 to semi-annual. Section III —Acid Rain Requirements • Revised the table in Section 2 to include calendar years corresponding to the relevant permit term for the renewal. • Minor changes were made to the standard requirements (Section 3), based on changes made to 40 CFR Part 72 § 72.9. • Removed the sentence at the beginning of Section 4 indicating that reports will be sent to the addresses in Appendix D, since reports are submitted electronically. • Removed the requirement in Section 4 (Reporting Requirements) to submit a copy of any revised certificate of representation to the Division. Submitting a copy of the certificate of representation to the permitting authority is not required under the regulations. Section IV— Permit Shield • The table for streamlined requirements (Section IV.3) was corrected to address NSPS Db requirements related to the auxiliary boiler, as follows: o Corrected the citation for the NSPS Db NOx limit (60.44b(a)(1)) and included 63.44b(h) and (i), which describe the NSPS Db NOx limit. o Corrected the description for the 60.44b(e)(2). This requirement is not the NOx emissions limitation but specifies the span value requirement for the NOx CEMS, not the NOx limit). o Corrected the description for 60.44b(g), (h) and (i). These requirements are related to recordkeeping and reporting under NSPS Db, not the NOx span value. In addition, included 60.49b(v) and (w) with these requirements as they are all related to reporting. Section V— General Conditions • Added a version date to the General Conditions. Page 14 • 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". • General Condition 29 was revised by reformatting and adding the provisions in Reg 7, Section III.C as paragraph e. Appendices • As discussed previously, the diesel fire pump was removed from the insignificant activity list in Appendix A and is included in Section II of the permit. • Changed the name of the Division contact for reports. 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ISSUED TO: PLANT SITE LOCATION: Public Service Company of Colorado 6211 Weld County Road 51 1800 Larimer Street Keenesburg, CO 80643 Denver, CO 80202 Weld County INFORMATION RELIED UPON Operating Permit Application Received: May 10, 2011 And Additional Information Received: December 20, 2010, March 23 and September 16, 2011 Nature of Business: Electrical Power Generation Primary SIC: 4911 RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON Name: George Hess Name: Quinn Kilty Title: General Manager—Power Title: Manager, Air and Water (303) 571-7282 Quality Phone: George Hess Phone: (303) 294-2165 SUBMITTAL DEADLINES Semi-Annual Monitoring Period: EXAMPLE (July 1 —December 31, January 1 —June 30) Semi-Annual Monitoring Report: EXAMPLE (Due on Feb.1, 2008 & August 1, 2008 & subsequent years) Annual Compliance Period: EXAMPLE (July 1 —June 30) Annual Compliance Certification: EXAMPLE (Due on August 1, 2008 and 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. FOR ACID RAIN SUBMITTAL DEADLINES SEE SECTION III.4 OF THIS PERMIT 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 (PSD) 2 4. Accidental Release Prevention Program (112(r)) 2 5. Compliance Assurance Monitoring (CAM) 2 6. Summary of Emission Units 3 SECTION II - Specific Permit Terms 4 1. Units S001 & S002 —Two (2)Natural Gas Fired Combustion Turbines Each Equipped with a HRSG and Duct Burner 4 2. Diesel Fuel Fired Emergency Engines 23 S005- Emergency Generator Rated at 1,810 hp 23 M003- Emergency Fire Pump Engine Rated at 182 hp 23 3. S004—Rentech Natural Gas Fired Boiler Rated at 129 MMBtulr 31 4. S006—Marley Cooling Water Tower 37 5. Facility Wide HAP Limits 39 6. Continuous Emission Monitoring Requirements 40 7. M001 - Gasoline Storage Tank, 500 gallons aboveground 45 8. M002—Cold Cleaner Solvent Vat 46 SECTION III - Acid Rain Requirements 47 1. Designated Representative and Alternate Designated Representative 47 2. Sulfur Dioxide Emission Allowances and Nitrogen Oxide Emission Limitations 47 3. Standard Requirements 47 4. Reporting Requirements 51 5. Comments,Notes and Justifications 51 SECTION IV - Permit Shield 52 1. Specific Non-Applicable Requirements 52 2. General Conditions 52 3. Streamlined Conditions 52 SECTION V- General Permit Conditions 54 1. Administrative Changes 54 2. Certification Requirements 54 3. Common Provisions 54 4. Compliance Requirements 58 5. Emergency Provisions 59 6. Emission Controls for Asbestos 59 7. Emissions Trading, Marketable Permits, Economic Incentives 59 8. Fee Payment 59 9. Fugitive Particulate Emissions 60 10. Inspection and Entry 60 11. Minor Permit Modifications 60 12. New Source Review 60 13. No Property Rights Conveyed 60 • Table of Contents: 14. Odor 61 15. Off-Permit Changes to the Source 61 16. Opacity 61 17. Open Burning 61 18. Ozone Depleting Compounds 61 19. Permit Expiration and Renewal 61 20. Portable Sources 62 21. Prompt Deviation Reporting 62 22. Record Keeping and Reporting Requirements 62 23. Reopenings for Cause 63 24. Section 502(b)(10) Changes 64 25. Severability Clause 64 26. Significant Permit Modifications 64 27. Special Provisions Concerning the Acid Rain Program 64 28. Transfer or Assignment of Ownership 64 29. Volatile Organic Compounds 65 30. Wood Stoves and Wood burning Appliances 65 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 Definitiotis 1 Monitoring and Permit Deviation Report - Part I 5 Monitoring and Permit Deviation Report- Part II 7 Monitoring and Permit Deviation Report- Part III 9 APPENDIX C 1 Required Format for Annual Compliance Certification Report 1 APPENDIX D 1 Notification Addresses 1 APPENDIX E 1 Permit Acronyms 1 APPENDIX F 1 Permit Modifications 1 - Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 1 SECTION I - General Activities and Summary 1. Permitted Activities 1.1 The Rocky Mountain Energy Center (RMEC) is an electric generating facility as defined under Standard Industrial Classification 4911. The facility consists of two natural gas fired combustion turbines, two heat recovery steam generators (HRSG), each equipped with natural gas fired duct burners, a steam turbine, cooling tower and auxiliary boiler. There are two diesel fired engines, one driving an emergency generator and one driving a fire pump. There is also a cold cleaner solvent vat and a gasoline storage tank that are included in Section II of the permit. The RMEC has the capacity to generate up to 630 MW of electricity. Each combustion turbine can generate approximately 152 MW, with an additional 326 MW (at peak capacity) from the steam turbine. The turbines are not equipped with a by-pass stack, therefore, the turbines only operate in combined cycle mode (i.e. turbine plus HRSG). The facility is located at 6211 Weld County Road 51,just east of the town of Hudson, in Weld County Colorado (bounded by CR 49 to the west, CR 16 to the north and CR 51 to the east). The area in which the plant operates is designated as attainment for all criteria 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 this facility. Rocky Mountain National Park, a federal class I designated area is within 100 km of this facility. 1.2 Until such time as this permit expires or is modified or revoked, the permittee is allowed to discharge air pollutants from this facility in accordance with the requirements, limitations, and conditions of this permit. 1.3 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 revisions made using the provisions of Regulation No. 3, Part C shall become new applicable requirements for purposes of this operating permit and shall survive reissuance. This permit incorporates the applicable requirements (except as noted in Section II) from the following construction permit (formerly issued to Rocky Mountain Energy Center, LLC): 02WE0228. 1.4 All conditions in this permit are enforceable by US Environmental Protection Agency, Colorado Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless otherwise specified. State-only enforceable conditions are: Permit Condition Number(s): Section II, Conditions 1.12.1 and 3.11 (opacity) and Section V - Conditions 3.d, 3.g (last paragraph), 14 and 18 (as noted) Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center " Permit# 05OPWE279 Page 2 1.5 All information gathered pursuant to the requirements of this permit is subject to the Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions in Section V of this permit. 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. 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, PMal, NOx and CO > 100 tons/year). Future modifications at this facility resulting in a significant net emissions increase (see Colorado Regulation No. 3, Part D, Sections II.A.26 and 42) or a modification which is major by itself(Potential to Emit > 100 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 Prevention of Significant Deterioration regulations. 4. Accidental Release Prevention Program (112(r)) 4.1 Based on the information provided by the applicant, this facility is 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: Units S001 and S002— Combustion Turbines/HRSGs/Duct Burners See Section II, Condition 1.13 for compliance assurance monitoring requirements. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT • - Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 3 6. Summary of Emission Units 6.1 The emissions units regulated by this permit are the following: Emission AIRS Description Startup Date Pollution Control Unit Stack Device No./ Number Facility ID S001 /CT- 001 One(1)Westinghouse, Model No. 501 FD,Natural Gas- March 2004 Dry Low NOx 01 Fired Combustion Turbine, Serial No. 37A8191. The (DLN) Combustion Turbine is Rated at 1785 MMBtu/hr(HHV at ISO Systems and conditions). The turbine is operated in combined cycle Selective Catalytic mode only and the heat recovery steam generator(I-IRSG) Reduction(SCR) is equipped with a duct burner rated at 675 MMBtu/hr. for NOx and The turbine drives a generator capable of generating 152 Oxidation Catalyst MW of power and the HRSG drives a steam generator for CO and VOC. rated at 326 MW(at peak capacity). S002/CT- 002 One(1)Westinghouse, Model No. 501FD,Natural Gas- March 2004 Dry Low NOx 02 Fired Combustion Turbine, Serial No. 37A8196. The (DLN)Combustion Turbine is Rated at 1785 MMBtu/hr(MTV at ISO Systems and conditions). The turbine is operated in combined cycle Selective Catalytic mode only and the heat recovery steam generator(HRSG) Reduction(SCR) is equipped with a duct burner rated at 675 MMBtu/hr. for NOx and The turbine drives a generator capable of generating 152 Oxidation Catalyst MW of power and the HRSG drives a steam generator for CO and VOC. rated at 326 MW(at peak capacity). S005 005 Caterpillar,Model No. 3512B,Diesel Fired Internal March 2004 Uncontrolled Combustion Engine Driving an Emergency Generator, Serial No. 1GZ01360. The Engine is Diesel Fuel-Fired and rated at 1810 hp and 12.2 MMBtu/hr. S004 004 Rentech,Natural Gas Fired Boiler,Rated at 129 February 2004 Low NOx Burners MMBtu/hr, Serial No. 2002-49. S006 006 Marley, Model No. F4910, 12 Cell Cooling Water Tower, March 2004 Drift Eliminators Rated at 176,000 gal/min. M001 N/A Cold Cleaner Solvent Vat Uncontrolled M002 N/A Gasoline Storage Tank, 500 gallons,aboveground Uncontrolled M003 N/A John Deere,Model No. 6081AF001, Serial No. March 2004 Uncontrolled RG6081A159985,Diesel Fired Internal Combustion Engine Driving an Emergency Fire Pump Engine, Rated at 182 hp and 1.26 MMBtu/hr. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado - Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 4 SECTION II - Specific Permit Terms 1. Units S001 & S002 —Two (2) Natural Gas Fired Combustion Turbines Each Equipped with a HRSG and Duct Burner Unless Otherwise Specified Limits are for Both Turbines/HRSGs/Duct Burners Parameter Permit Limitations Compliance Monitoring Condition Emission Number Short Term Long Term Factor Method Interval BACT 1.1 See Condition 1.1. N/A See Condition 1.1. Requirements PM/PM10 1.2. N/A 126.8 tons/yr CT-01: Recordkeeping Monthly PM 0.0036 and Calculation lb/MMBtu PM10 0.0036 lb/MMBtu CT-02: PM 0.0045 lb/MMBtu PM10 0.0045 lb/MMBtu For Each Turbine/HRSG/duct N/A See Condition 1.2. burner: 0.00735 lbs/MMBtu,the average of three(3)test runs VOC 1.3. N/A 50.6 tons/yr Unit 1 -7.3 x Recordkeeping Monthly 10'lb/MMBtu and Calculation Unit 2- 1.5x 104 lb/MMBtu For Each Turbine/HRSG/duct N/A See Condition 1.3. burner: 0.00293 Ibs/MMBtu,the average of three(3), 1-hr tests Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 5 Parameter Permit Limitations Compliance Monitoring Condition Emission Number Short Term Long Term Factor Method Interval SO2 1.4. N/A 11.8 tons/yr N/A 40 CFR Part 75, As specified in Appendix D 40 CFR Part 75, Appendix D For Each Turbine: N/A Fuel Restriction Only Pipeline 150 ppmvd @ 15%O2 OR Use of Quality Natural Fuel Which Contains Less than 0.8 Gas is Used as Weight%Sulfur Fuel For Each Turbine: 0.35 lbs/MMBtu, on a 3-hour rolling average For Each Duct Burner: 0.20 lbs/MMBtu, on a 30-Day Rolling Average NOx 1.5. For Each Turbine/HRSG/Duct N/A Continuous Continuously Burner: Emission 3 ppmvd @ 15%O2 on a 1-hr Monitoring average, except as provided for System below During Startup and Shutdown: 300 ppmvd @ 15%O2 averaged over the startup and/or shutdown period. During Combustion Tuning and Testing(not to exceed 60 hrs/yr per for both turbines/HRSGs/Duct Burners combined): 300 ppmvd @ 15%O2 on a 1-hr average. N/A 240.4 tons/yr Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 6 Parameter Permit Limitations Compliance Monitoring Condition Emission Number Short Term Long Term Factor Method Interval CO 1.6. For Each Turbine/HRSG/Duct N/A Continuous Continuously Burner: Emission 9 ppmvd @ 15%O2 on a 1-hr Monitoring average, except as provided for System below During Startup and Shutdown: 1,000 ppmvd @ 15%O2 averaged over the startup and/or shutdown period During Combustion Tuning and Testing(not to exceed 60 hrs/yr per for both turbines/HRSGs/Duct Burners combined): 1,000 ppmvd @ 15%O2 on a 1-hr average. N/A 782.2 tons/yr Natural Gas 1.7. N/A 32,625 MMscf/yr N/A Recordkeeping Monthly Consumption Continuous 1.8. N/A N/A N/A See Condition 1.8. Emission Monitoring System Requirements Fuel Flow Meter 1.9. N/A N/A N/A See Condition 1.9. Sulfur Content of 1.10. Pipeline Quality Natural Gas (total N/A See Condition 1.10. Fuel sulfur content not to exceed 0.5 grains/100 SCF) NSPS General 1.11. N/A N/A N/A As Required by Subject to Provisions NSPS General NSPS General Provisions Provisions Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT - Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 7 Parameter Permit Limitations Compliance Monitoring Condition Emission Number Short Term Long Term Factor Method Interval Opacity 1.12. State Only Requirement: Not to N/A Fuel Restriction Only Natural Exceed 20% Gas is Used as Fuel Not to Exceed 20%(6-minute average), Except for One Six Minute Average Not to Exceed 27%Per Hour Not to Exceed 20%Except as Provided for Below For Certain Operational Activities - Not to Exceed 30%,for a Period or Periods Aggregating More than Six (6)Minutes in any 60 Consecutive Minutes Compliance 1.13. N/A N/A N/A See Condition 1.13. Assurance Monitoring Requirements - Acid Rain 1.14. See Section III of this Permit Certification Annually Requirements 1.1 The turbines/HRSGs/duct burners are subject to the requirements of the prevention of Significant Deterioration (PSD) Program. Best Available Control Technology (BACT) shall be applied for control of Nitrogen Oxides (NOx), Carbon Monoxide (CO), Particulate Matter (PM and PM1o) and Volatile Organic Compounds. BACT has been determined as follows: 1.1.1 BACT for NOx has been determined to be dry low NOx(DLN) combustion system and selective catalytic reduction (SCF) with the emission limits identified in Condition 1.5.1 (Colorado Construction Permit 02WE0228). 1.1.2 BACT for CO has been determined to be good combustion practices and an oxidation catalyst with the emission limits identified in Condition 1.6.1 (Colorado Construction Permit 02WE0228). 1.1.3 BACT for PM and PMio has been determined to be use of pipeline quality natural gas as fuel, good combustion practices with the emission limitations identified in Condition 1.2.2 (Colorado Construction Permit 02WE0228). 1.1.4 BACT for VOC has been determined to be use of pipeline quality natural gas as fuel, good combustion practices and an oxidation catalyst with the emission limitations identified in Condition 1.3.2 (Colorado Construction Permit 02WE0228). Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 8 1.2 PM and PMio emissions are subject to the following requirements: 1.2.1 Total Annual emissions of PM and PMto from both turbines/HRSGs/duct burners together shall not exceed 126.8 tons/yr(Colorado Construction Permit 02WE0228, as modified under the provisions of Section I, Condition 3.1 to set emission units for individual equipment instead of a facility wide total). Monthly emissions from each turbine/HRSG/duct burner shall be calculated by the end of the subsequent month using the above emission factors (from performance tests conducted September 8 and 9, 2011) and the heat input for the month as recorded on the data acquisition and handling system (DAHS) for the continuous emission monitoring system (required by Condition 1.8) in the following equation: tons/mo=(EF, Ibs/MMBtu)x heat input(MMBtu/mo) 2000 lbs/ton Monthly emissions from each turbine/HRSG/duct burner shall be summed together and used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 1.2.2 For purposes of BACT, Total (filterable plus condensable) Particulate Matter(PM) and Particulate Matter less than 10 microns (PMio) emissions from each turbine/HRSG/duct burner shall not exceed 0.00735 lbs/MMBtu, based on the average of three (3) one-hour test runs (Colorado Construction Permit 02WE0228, as modified under the provisions of Section I, Condition 1.3 to specify the averaging time). Compliance with the PM and PKo BACT limits shall be monitored as follows: 1.2.2.1 In the absence of credible evidence to the contrary, compliance with the particulate matter emission limits is presumed since only pipeline quality natural gas that meets the requirements in Condition 1.10 is permitted to be used as fuel in the turbines and duct burners. 1.2.2.2 Performance tests shall be conducted every five (5) years to monitor compliance with the PM and PM10 emission limitations. Performance test shall be conducted in accordance with the requirements of 40 CFR Part 60 Subpart A § 60.8 using EPA Test Methods 5 and 202. Note that previous performance tests for these units were conducted on September 8 and 9, 2011. A stack testing protocol shall be submitted for Division approval at least thirty (30) calendar days prior to performance of the test required under this condition. No stack test required herein shall be performed without prior written approval of the protocol by the Division. The Division reserves the right to witness the test. In order to facilitate the Division's ability to make plans to witness the test, notice of the date (s) for the stack Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT - Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 9 test shall be submitted to the Division at least thirty (30) calendar days prior to the test. The Division may for good cause shown, waive this thirty (30) day notice requirement. In instances when a scheduling conflict is presented,the Division shall immediately contact the permittee in order to explore the possibility of making modifications to the stack test schedule. The required number of copies of the compliance test results shall be submitted to the Division within forty-five (45) calendar days of the completion of the test unless a longer period is approved by the Division. 1.3 VOC emissions are subject to the following requirements: 1.3.1 Total Annual emissions of VOC from both turbines/HRSGS/duct burners together shall not exceed 50.6 tons/yr(Colorado Construction Permit 02WE0228, as modified under the provisions of Section I, Condition 1.3 to set emission units for individual equipment instead of a facility wide total). Monthly emissions from each turbine/HRSG/duct burner shall be calculated by the end of the subsequent month using the above emission factors (from performance tests conducted May and September 2004) and the heat input for the month as recorded on the DAHS for the continuous emission monitoring system (required by Condition 1.8) in the following equation: tons/mo=(EF, lbs/MMBtu)x heat input(MMBtu/mo) 2000 lbs/ton Monthly emissions from each turbine/HRSG/duct burner shall be summed together and used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 1.3.2 For purposes of BACT, VOC emissions from each turbine/HRSG/duct burner shall not exceed 0.00293 lb/MMBtu, based on the average of three (3) one-hour test runs (Colorado Construction Permit 02WE0228, as modified under the provisions of Section I, Condition 1.3 to specify the averaging time). In the absence of credible evidence to the contrary, compliance with the VOC BACT emission limit is presumed provided the requirements in Condition 1.6.1 (CO BACT limits) are met. 1.4 Sulfur Dioxide (SO2) emissions shall not exceed the following limitations: 1.4.1 Total Annual Sulfur Dioxide (SO2) emissions from both turbines/HRSGs/Duct Burner together shall not exceed 11.8 tons/yr (Colorado Construction Permit 02WE0228, as modified under the provisions of Section I, Condition 1.3 to set emission units for individual equipment instead of a facility wide total). Compliance with the annual SO2 emission limitations shall be monitored using the monitoring method specified in 40 CFR Part 75 Appendix D. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 10 Monthly emissions from each turbine/HRSG/duct burner shall be summed together and used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 1.4.2 Each turbine shall meet one of the following requirements: 1.4.2.1 Sulfur Dioxide (SO2) emissions from each turbine shall not exceed 150 ppmvd at 15% O2 OR 1.4.2.2 No fuel, which contains sulfur in excess of 0.8 percent by weight, shall be used in these combustion turbines (40 CFR Part 60 Subpart GG §§ 60.333(a) & (b), as adopted by reference in Colorado Regulation No. 6, Part A). Compliance with the above requirements is presumed, in the absence of evidence to the contrary, since only pipeline quality natural gas that meets the requirements in Condition 1.10 is permitted to be used as fuel in these turbines. 1.4.3 Sulfur Dioxide (SO2) emissions from each turbine shall not exceed 0.35 lbs/MMBtu, on a 3-hr rolling average (Colorado Regulation No. 1, Section VI.B.4.c.(ii) and VI.B.2). In the absence of credible evidence to the contrary, compliance with the SO2 limitations is presumed since only pipeline quality natural gas that meets the requirements in Condition 1.10 is permitted to be used as fuel in these turbines. 1.4.4 Sulfur Dioxide (SO2) emissions from each duct burner shall not exceed 0.20 lbs/MMBtu on a 30-day rolling average (40 CFR Part 60 Subpart Da § 60.43a(b)(2), as adopted by reference in Colorado Regulation No. 6, Part A). In the absence of credible evidence to the contrary, compliance with the sulfur dioxide limitations is presumed, since only pipeline quality natural gas that meets the requirements in Condition 1.10 is permitted to be used as fuel in these duct burners. 1.5 Emissions of Nitrogen Oxides (NOx) shall not exceed the following limitations: 1.5.1 For purposes of BACT, Nitrogen Oxide (NOx) emissions from each turbine/HRSG/duct burner shall not exceed the following limitations (Colorado Construction Permit 02WE0228, as modified under the provisions of Section I, Condition 1.3 to revise the definitions of startup and shutdown): 1.5.1.1 Except as provided for below, emissions of NOx shall not exceed 3 ppmvd at 15% O2, on a 1-hour average. 1.5.1.2 During periods of startup and shutdown, emissions of NOx shall not exceed 300 ppmvd at 15% O2, as averaged over the duration of the startup and/or shutdown period. •Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 11 1.5.1.3 During periods of combustion tuning and testing, emissions of NOx shall not exceed 300 ppmvd at 15% O2, on a 1-hour average. Use of this NOx emission limit for purposes of combustion tuning and/or testing shall not exceed 60 hours in any calendar year for both turbines/HRSGs/duct burners combined. Records of the number of hours each turbine/HRSG/duct burner undergoes combustion tuning and/or testing shall be recorded and maintained and made available to the Division upon request. 1.5.1.4 "Startup"means the setting in operation of any air pollution source for any purpose. Setting in operation for these turbines begins when flame is detected in the turbine. Setting in operation for these turbines ends 30 minutes after the turbine reaches Stage-C operation. 1.5.1.5 "Shutdown" means the cessation of operation of any air pollution source for any purpose. The cessation of operation for these turbines begins when the command signal is initiated to shutdown the unit and ends when fuel is no longer being fired in the turbine. 1.5.1.6 "Combustion Tuning and Testing"means the operation of the unit for the purpose of performing combustion tuning and testing operations after a unit overhaul or as part of routine maintenance operations. Combustion tuning and testing can occur throughout the range of the operating conditions. Compliance with the NOx BACT emission limitations shall be monitored using the continuous emission monitoring systems (CEMS) required by Condition 1.8, as follows: 1.5.1.7 Except as provided for in Condition 1.5.1.6, all the CEMS concentration (ppm) data points, excluding startup and shutdown data points shall, at the end of each clock hour, be summarized to generate the one-hour average NOx concentration in accordance with the requirements in 40 CFR Part 75. Data used to generate the one-hour average NOx concentration shall not include replaced data, nor shall the data be bias-adjusted. Replaced data shall be reported as monitor down time in the semi-annual reports required by Condition 6.5. Each clock hour average NOx concentration shall be compared to the limitations in Conditions 1.5.1.1 or 1.5.1.3, as appropriate. 1.5.1.8 All concentration data points within the startup and/or shutdown period shall be averaged together to generate the average NOx concentration for a given startup and/or shutdown period. Data used to generate the average NOx concentration during the startup and/or shutdown period shall not include replaced data, nor shall the data be bias-adjusted. Replaced data shall be reported as monitor down time in the semi-annual reports required Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 12 by Condition 6.5. The average NOx concentration for each startup and shutdown period shall be compared to the limitation in Condition 1.5.1.2. In the event that the startup ends within a clock hour or the shutdown begins within a clock hour, all non-startup and/or non-shutdown concentration(ppm) data points within that clock hour shall be averaged together to generate the average NOx concentration in accordance with the requirements in 40 CFR Part 75 and that average concentration shall be compared to the limitations in Conditions 1.5.1.1 or 1.5.1.3, as appropriate. 1.5.1.9 The emission limitation in Condition 1.5.1.3 applies to any clock hour in which combustion tuning and testing activities occur. 1.5.2 Total Annual emissions of NOx from both turbines/HRSGs/duct burners together shall not exceed 126.8 tons/year (Colorado Construction Permit 02WE0228, as modified under the provisions of Section I, Condition 1.3 to set emission units for individual equipment instead of a facility wide total). For any hour in which fuel is combusted in the turbines/HRSGs/duct burners, the permittee shall program the DAHs to calculate lb/hr NOx emissions in accordance with the requirements in Condition 6.1.1.4.b of this permit and 40 CFR Part 75, including any replaced data and the data shall be bias-adjusted, if warranted. Specifically hourly mass NOx emissions (in lb/hr) shall be calculated by multiplying the hourly NOx lb/MMBtu value (which includes replaced or bias-adjusted data, as applicable) by the hourly heat input value (MMBtu/hr) (which includes replaced data from the fuel flow measurement, as applicable). The hourly NOx lb/MMBtu and heat input values shall be determined using equations F-5 and F-20 in Appendix F of 40 CFR Part 75. The resulting NOx lb/hr value is then multiplied by the unit operating time for that hour to produce a NOx lbs value. Hourly NOx mass emissions (lbs) shall be summed and divided by 2000 lb/ton to determine monthly NOx emissions (in tons). Monthly emissions (in tons) from each turbine/HRSG/duct burner shall be summed together and used in a twelve month rolling total to monitor compliance with the annual emission limitation. Each month a new twelve month total shall be calculated using the previous twelve months total. 1.6 Emissions of Carbon Monoxide (CO) shall not exceed the following limitations: 1.6.1 For purposes of BACT, Carbon Monoxide (CO) emissions from each turbine/HRSG/duct burner shall not exceed the following limitations (Colorado Construction Permit 02WE0228, as modified under the provisions of Section I, Condition 1.3 to revise the definition of startup and shutdown and to remove the limit for CO during the ls`hour of a cold startup): Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit # 05OPWE279 Page 13 1.6.1.1 Except as provided for below, emissions of CO shall not exceed 9 ppmvd at 15% O2, on a 1-hour average. 1.6.1.2 During periods of startup and shutdown, emissions of CO shall not exceed 1,000 ppmvd at 15% O2, as averaged over the duration of the startup and/or shutdown period. 1.6.1.3 During periods of combustion tuning and testing, emissions of CO shall not exceed 1,000 ppmvd at 15% O2, on a 1-hour average. Use of this CO emission limit for purposes of combustion tuning and/or testing shall not exceed 60 hours in any calendar year for both turbines/HRSGs/duct burners combined. Records of the number of hours each turbine/HRSG/duct burner undergoes combustion tuning and/or testing shall be recorded and maintained and made available to the Division upon request. 1.6.1.4 "Startup" shall have the same definition as in Condition 1.5.1.3. 1.6.1.5 "Shutdown" shall have the same definition as in Condition 1.5.1.4. 1.6.1.6 "Combustion Tuning and Testing" shall have the same definition as provided for in Condition 1.5.1.6. Compliance with the CO BACT emission limitations shall be monitored the CEMS required by Condition 1.8, as follows: 1.6.1.7 Except as provided for in Condition 1.6.1.6, all the CEMS concentration (ppm) data points, excluding startup and shutdown data points shall, at the end of each clock hour, be summarized to generate the one-hour average CO concentration in accordance with the requirements in 40 CFR Part 75. Data used to generate the one-hour average CO concentration shall not include replaced data, nor shall the data be bias-adjusted. Replaced data shall be reported as monitor down time in the semi-annual reports required by Condition 6.5. Each clock hour average CO concentration shall be compared to the limitations in Conditions 1.6.1.1 or 1.6.1.3, as appropriate. 1.6.1.8 All concentration (ppm) data points within the startup and/or shutdown period shall be averaged together to generate the average CO concentration for a given startup and/or shutdown period. Data used to generate the average CO concentration during the startup and/or shutdown period shall not include replaced data, nor shall the data be bias-adjusted. Replaced data shall be reported as monitor down time in the semi-annual reports required by Condition 6.5. The average CO concentration for each startup and shutdown period shall be compared to the limitation in Condition 1.6.1.2. In the event that the startup ends within a clock hour or the shutdown begins within a clock hour, all non-startup and/or non-shutdown Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 14 concentration(ppm) data points within that clock hour shall be averaged together to generate the average CO concentration in accordance with the requirements in 40 CFR Part 75 and that average concentration shall be compared to the limitations in Conditions 1.6.1.1 or 1.6.1.3, as appropriate. 1.6.1.9 The emission limitation in Condition 1.6.1.3 applies to any clock hour in which combustion turning and testing activities occur. 1.6.2 Total Annual emissions of CO from both turbines/HRSGs/duct burners together shall not exceed 782.2 tons/yr(Colorado Construction Permit 02WE0228, as modified under the provisions of Section I, Condition 1.3, to set emission units for individual equipment instead of a facility wide total). For any hour in which fuel is combusted in the turbines/HRSGs/duct burners, the permittee shall program the DAHs to calculate lb/hr CO emissions in accordance with the requirements in Condition 6.1.1.4.b of this permit and 40 CFR Part 75, including any replaced data, if warranted. Specifically hourly mass CO emissions (in lb/hr) shall be calculated by multiplying the hourly CO lb/MMBtu value (which includes replaced date in accordance with the provisions in Part 75 for NOx replacement, as applicable) by the hourly heat input value (MMBtu/hr) (which includes replaced data from the stack flow measurement, as applicable). The hourly CO lb/MMBtu and heat input values shall be determined using equations F-5 (for NOx) and F-20 in Appendix F of 40 CFR Part 75. The resulted CO lb/hr value is then multiplied by the unit operating time for that hour to produce a CO lbs value. Hourly CO mass emissions (lbs) shall be summed and divided by 2000 lb/ton to determine monthly CO emissions (in tons). Monthly emissions (in tons) from each turbine/HRSG/duct burner shall be summed together and used in a twelve month rolling total of emissions to monitor compliance with the annual emission limitation. Each month a new twelve month total shall be calculated using the previous twelve months total. 1.7 Total natural gas consumption for both turbines/HRSGs/duct burners together shall not exceed the above limitations (Colorado Construction Permit 02WE0228). The natural gas consumption for each turbine/HRGS/duct burner shall be monitored and recorded monthly using the fuel flow meters required by Condition 1.9. Monthly natural gas fuel consumption for each turbine/HRSG/duct burner shall be summed together and used in a rolling twelve month total to monitor compliance with the annual limitation. Each month a new twelve month rolling total shall be calculated using the previous twelve months data. 1.8 Each of the turbine/HRSG/duct burner exhaust stacks shall be equipped with a continuous emission monitoring system to measure and record the following: 1.8.1 Concentration of Oxides of Nitrogen; ppmvd corrected to 15 % O2, hourly average; Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 15 1.8.2 Emissions of Oxides of Nitrogen; pounds per hour, tons per month; 1.8.3 Concentration of Carbon Monoxide; ppmvd corrected to 15% O2, hourly average; 1.8.4 Emissions of Carbon Monoxide, pounds per hour,tons per month; 1.8.5 Concentration of Oxygen, percent hourly average; 1.8.6 Operating mode— startup, shutdown and/or standard operation; and The continuous emission monitoring systems shall meet the requirements in Condition 6 of this permit. Monthly emissions of NOx and CO from the continuous emission monitoring system shall be used as specified by Conditions 1.5.2 and 1.6.2 to monitor compliance with the annual NOx and CO emission limitations. 1.9 Each turbine/HRSG/duct burner shall be equipped with an in-line fuel flow meter that meets the requirements in 40 CFR Part 75 Appendix D to measure fuel combusted in each turbine. Fuel flow data shall be recorded on a data acquisition and handling system as specified in 40 CFR Part 75 Appendix D (Colorado Construction Permit 02WE0228). 1.10 The permittee shall maintain records demonstrating that the natural gas burned meets the definition of pipeline quality natural gas as defined in 40 CFR Part 72. Specifically, the permittee shall demonstrate that the natural gas burned has a total sulfur content less than 0.5 grains/100 SCF. The demonstration shall be made using any of the methods identified in 40 CFR Part 75 Appendix D, Section 2.3.1.4. These records shall be made available to the Division upon request. 1.11 Regulation No. 6, Part A, Subpart A, General Provisions apply as follows: 1.11.1 No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gasses discharged to the atmosphere. (Colorado Construction Permit 01AD0575 and 40 CFR Part 60 Subpart A § 60.12, as adopted by reference in Colorado Regulation No. 6, Part A) 1.11.2 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Division which may include, but is not limited to monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source (Colorado Construction Permit 01AD0575 and 40 CFR Part 60 Subpart A § 60.11(d), as adopted by Regulation No. 6, Part A). Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 16 1.12 The turbines/HRSGs/duct burners are subject to the following opacity requirements: 1.12.1 State-Only Requirement: No owner or operator may discharge, or cause the discharge into the atmosphere of any particulate matter which is greater than 20% opacity (Colorado Regulation No. 6, Part B, Section II.C.3). This opacity standard applies to each turbine/HRGS/duct burner. This opacity standard applies at all times except during periods of startup, shutdown and malfunction(40 CFR Part 60 Subpart A § 60.11(c), as adopted by reference in Colorado Regulation No. 6, Part B, Section I.A). Note that this opacity requirement is more stringent than the opacity requirement in Conditions 1.12.2 and 1.12.4 during periods of building of a new fire, cleaning of fire boxes, soot blowing, process modifications and adjustment or occasional cleaning of control equipment. 1.12.2 No owner or operator of a source shall cause to be discharged into the atmosphere from any affected facility any gases which exhibit greater than 20 percent opacity (6- minute average), except for one 6-minute period per hour of not more than 27 percent opacity ((40 CFR Part 60 Subpart Da § 60.42a(b), as adopted by reference in Colorado Regulation No. 6, Part A and Colorado Construction Permit 99WE0762 PSD). This opacity standard applies to each duct burner. This opacity standard applies at all times except during periods of startup, shutdown and malfunction (40 CFR Part 60 Subpart A § 60.11(c), as adopted by reference in Colorado Regulation No. 6, Part A). Note that this opacity requirement is more stringent than the opacity requirement in Condition 1.12.4 during periods of building of a new fire, cleaning of fire boxes, soot blowing, process modifications and adjustment or occasional cleaning of control equipment. 1.12.3 Except as provided for in Condition 1.12.4 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Construction Permit 02WE0228 and Colorado Regulation No. 1, Section II.A.1). This opacity standard applies to each turbine/HRGS/duct burner. 1.12.4 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment which is in excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Construction Permit 02WE0228 and Colorado Regulation No. 1, Section II.A.4). This opacity standard applies to each turbine/HRGS/duct burner. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT " Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 17 In the absence of credible evidence to the contrary, each turbine shall be presumed to be in compliance with the above opacity requirements whenever natural gas is used as fuel. 1.13 The Compliance Assurance Monitoring (CAM) requirements in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV, apply with respect to the VOC, NOx and CO emission limitations identified in Conditions 1.3, 1.5 and 1.6 as follows: 1.13.1 The permittee shall monitor the exhaust gas NOx and CO concentration (ppmvd at 15% O2) and mass (lbs/hr) emissions using the continuous emission monitoring system required by Condition 1.8. 1.13.1.1 With respect to the NOx and CO emission limitations, exceedances, for purposes of CAM, shall be a. Any 1-hr period that the NOx and/or CO concentration exceeds the limits identified in Condition 1.5.1.1 and 1.6.1.1; b. Any NOx and/or CO concentration average over either a startup and/or shutdown period that exceeds the limits identified in Conditions 1.5.1.2 and 1.6.1.2; and c. Any twelve month period that NOx and/or CO emissions (tons/yr) exceeds the limits identified in Condition 1.5.2 and 1.6.2. 1.13.1.2 With respect to the VOC emissions limitations, excursions for the purposes of CAM, shall be: a. Any 1-hr period that the CO concentration exceeds the limit identified in Condition 1.6.1.1; b. Any CO concentration average over either a startup and/or shutdown period that exceeds the limit identified in Condition 1.6.1.2; and c. Any twelve month period that CO emissions (tons/yr) exceed the limit identified in Condition 1.6.2. 1.13.1.3 Exceedances and/or excursions shall be reported as required by Section II, Condition 6.5 and Section V, Conditions 21 and 22.d of this permit. 1.13.2 Operation of Approved Monitoring 1.13.2.1 At all times, the owner or operator shall maintain the monitoring, including but not limited to, maintaining necessary parts for routine repairs of the monitoring equipment(40 CFR Part 64 § 64.7(b), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.13.2.2 Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), the owner or operator shall conduct all monitoring in continuous operation (or shall Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division ' Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 18 collect data at all required intervals) at all times that the pollutant-specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of these CAM requirements, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. The owner or operator shall use all the data collected during all other periods in assessing the operation of the control device and associated control system. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions (40 CFR Part 64 § 64.7(c), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.13.2.3 Response to excursions or exceedances a. Upon detecting an excursion or exceedance, the owner or operator shall restore operation of the pollutant-specific emissions unit (including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion or exceedance (other than those caused by excused startup or shutdown conditions). Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow-up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable (40 CFR Part 64 § 64.7(d)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). b. Determination of whether the owner of operator has used acceptable procedures in response to an excursion or exceedance will be based on information available, which may include but is not limited to, monitoring results, review of operation and maintenance procedures and records, and inspection of the control device, associated capture system, and the process (40 CFR Part 64 § 64.7(d)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.13.2.4 After approval of the monitoring required under the CAM requirements, if the owner or operator identifies a failure to achieve compliance with an emission limitation or standard for which the approved monitoring did not Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT • Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 19 provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing indicator ranges or designated conditions, the owner or operator shall promptly notify the Division and, if necessary submit a proposed modification for this permit to address the necessary monitoring changes. Such a modification may include, but is not limited to, reestablishing indicator ranges or designated conditions, modifying the frequency of conducting monitoring and collecting data, or the monitoring of additional parameters (40 CFR Part 64 § 64.7(e), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.13.3 Quality Improvement Plan(QIP) Requirements 1.13.3.1 Based on the results of a determination made under the provisions of Condition 1.13.2.3.b, the Division may require the owner or operator to develop and implement a QIP (40 CFR Part 64 § 64.8(a), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.13.3.2 The owner or operator shall maintain a written QIP, if required, and have it available for inspection (40 CFR Part 64 § 64.8(b)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.13.3.3 The QIP initially shall include procedures for evaluating the control performance problems and, based on the results of the evaluation procedures, the owner or operator shall modify the plan to include procedures for conducting one or more of the following actions, as appropriate: a. Improved preventative maintenance practices (40 CFR Part 64 § 64.8(b)(2)(i), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). b. Process operation changes (40 CFR Part 64 § 64.8(b)(2)(ii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). c. Appropriate improvements to control methods (40 CFR Part 64 § 64.8(b)(2)(iii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). d. Other steps appropriate to correct control performance (40 CFR Part 64 § 64.8(b)(2)(iv), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). e. More frequent or improved monitoring (only in conjunction with one or more steps under Conditions 2.9.3.3.a through d above) (40 CFR Part 64 § 64.8(b)(2)(v), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 20 1.13.3.4 If a QIP is required, the owner or operator shall develop and implement a QIP as expeditiously as practicable and shall notify the Division if the period for completing the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined (40 CFR Part 64 § 64.8(c), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.13.3.5 Following implementation of a QIP, upon any subsequent determination pursuant to Condition 1.13.2.3.b, the Division or the U.S. EPA may require that an owner or operator make reasonable changes to the QIP if the QIP is found to have: a. Failed to address the cause of the control device performance problems (40 CFR Part 64 § 64.8(d)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV); or b. Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions (40 CFR Part 64 § 64.8(d)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.13.3.6 Implementation of a QIP shall not excuse the owner or operator of a source from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply under federal, state, or local law, or any other applicable requirements under the federal clean air act (40 CFR Part 64 § 64.8(e), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.13.4 Reporting and Recordkeeping Requirements 1.13.4.1 Reporting Requirements: The reports required by Section V, Condition 22.d, shall contain the information specified in Appendix B of the permit and the following information, as applicable: a. Summary information on the number, duration and cause (including unknown cause, if applicable), for monitor downtime incidents (other than downtime associated with zero and span or other daily calibration checks, if applicable) ((40 CFR Part 64 § 64.9(a)(2)(ii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV); and b. The owner or operator shall submit, if necessary, a description of the actions taken to implement a QIP during the reporting period as specified in Condition 1.13.3 of this permit. Upon completion of a QIP, the owner or operator shall include in the next summary report documentation that the implementation of the plan has been completed and reduced the likelihood of similar levels of Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT • Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 21 excursions or exceedances occurring (40 CFR Part 64 § 64.9(a)(2)(iii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.13.4.2 General Recordkeeping Requirements: In addition to the recordkeeping requirements in Section V, Condition 22.a through c. a. The owner or operator shall maintain records of any written QIP required pursuant to Condition 1.13.3 and any activities undertaken to implement a QIP, and any supporting information required to be maintained under these CAM requirements (such as data used to document the adequacy of monitoring, or records of monitoring maintenance or corrective actions) (40 CFR Part 64 § 64.9(b)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). b. Instead of paper records, the owner or operator may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements (40 CFR Part 64 § 64.9(b)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.13.5 Savings Provisions 1.13.5.1 Nothing in these CAM requirements shall excuse the owner or operator of a source from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply under federal, state, or local law, or any other applicable requirements under the federal clean air act. These CAM requirements shall not be used to justify the approval of monitoring less stringent than the monitoring which is required under separate legal authority and are not intended to establish minimum requirements for the purposes of determining the monitoring to be imposed under separate authority under the federal clean air act, including monitoring in permits issued pursuant to title I of the federal clean air act. The purpose of the CAM requirements is to require, as part of the issuance of this Title V operating permit, improved or new monitoring at those emissions units where monitoring requirements do not exist or are inadequate to meet the requirements of CAM (40 CFR Part 64 § 64.10(a)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.13.5.2 Nothing in these CAM requirements shall restrict or abrogate the authority of the U.S. EPA or the Division to impose additional or more stringent monitoring, recordkeeping, testing or reporting requirements on any owner or operator of a source under any provision of the federal clean air act, Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado - Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 22 including but not limited to sections 114(a)(1) and 504(b), or state law, as applicable (40 CFR Part 64 § 64.10(a)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.13.5.3 Nothing in these CAM requirements shall restrict or abrogate the authority of the U.S. EPA or the Division to take any enforcement action under the federal clean air act for any violation of an applicable requirement or of any person to take action under section 304 of the federal clean air act (40 CFR Part 64 § 64.10(a)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.14 These units are subject to the Title IV Acid Rain Requirements. As specified in 40 CFR Part 72.72(b)(1)(viii), the acid rain permit requirements shall be complete and segregable portion of the Operating Permit. As such the requirements are found in Section III of this permit. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 23 2. Diesel Fuel Fired Emergency Engines S005-Emergency Generator Rated at 1,810 hp Parameter Permit Limitations Compliance Monitoring Condition Emission Factor Number Short Term Long Term Method Interval NOx 2.1. N/A N/A 6.9 g/hp-hr Recordkeeping Annually, if and Calculation Hours of Operation CO N/A N/A 8.5 g/hp-hr Exceed 100 Hours of 2.2. N/A N/A N/A Recordkeeping Annually Operation SO2 2.3. 0.8 lbs/MMBtu N/A Fuel Restriction Only Diesel Fuel is Used as Fuel Opacity 2.4. Not to Exceed 20%Except as N/A EPA Method 9 See Condition Provided for Below 2.4 For Startup—Not to Exceed 30%, for a Period or Periods Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes MACT ZZZZ 2.5. Change Oil and Filter N/A See Condition 2.5 Requirements Inspect Air Cleaner Inspect all Hoses and Belts MACT General 2.6. N/A N/A N/A See Condition 2.6 Provisions M003- Emergency Fire Pump Engine Rated at 182 hp Parameter Permit Limitations Compliance Monitoring Condition Emission Factor Number Short Term Long Term Method Interval SO2 2.3 0.8 lbs/MMBtu N/A Fuel Restriction Only Diesel Fuel is Used as Fuel Opacity 2.4 Not to Exceed 20%Except as N/A EPA Method 9 See Condition Provided for Below 2.4 For Startup—Not to Exceed 30%, for a Period or Periods Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit # 05OPWE279 Page 24 Parameter Permit Limitations Compliance Monitoring Condition Emission Factor Number Short Term Long Term Method Interval MACT ZZZZ 2.5. Change Oil and Filter N/A See Condition 2.5 Requirements Inspect Air Cleaner Inspect all Hoses and Belts MACT General 2.6 N/A N/A N/A See Condition 2.6 Provisions Note that this emission unit is exempt from the APEN reporting requirements in Regulation No. 3, Part A and the construction permit requirements in Regulation No. 3,Part B. 2.1 The emission factors listed above (from the manufacturer) have been approved by the Division and shall be used to calculate emissions from the emergency generator. If hours of operation for this engine exceed 100 hours in any calendar year, annual emissions of Nitrogen Oxide (NOx) and Carbon Monoxide (CO) emissions for purposes of APEN reporting and payment of annual fees shall be determined using the above emission factors, the maximum horsepower (1,810 hp) and the hours of operation (as required by Condition 2.2) the following equation: Tons/yr= [EF(g/hp-hr)x hour of operation(hrs/yr)x maximum hpl [(453.6 g/lb)x(2000 lbs/ton)] 2.2 Hours of operation for the emergency generator shall be monitored annually and recorded in a log to be made available to the Division upon request. Recorded data shall be used to calculate emissions as required by Condition 2.1. Note that if annual hours of operation exceed 250 hours in any year, the engine is no longer exempt from the permitting requirements in Colorado Regulation No. 3, Part B and the permittee shall submit an application to revise this permit within 30 days in order to include the appropriate applicable requirements. 2.3 Sulfur Dioxide (SO2) emissions from each engine shall not exceed 0.8 lbs/MMBtu (Colorado Regulation No. 1, Section VI.B.4.b.(i)). In the absence of credible evidence to the contrary, compliance with the SO2 emission limitation shall be presumed since only diesel fuel is permitted to be used as fuel in these engines. The permittee shall maintain records that verify that only diesel fuel is used as fuel in these engines. 2.4 Opacity of emissions from each engine shall not exceed the following: 2.4.1 Except as provided for in Condition 2.4.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 2.4.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from startup which is in excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 25 Compliance with these limitations shall be monitored by conducting opacity observations in accordance with EPA Reference Method 9 as follows: 2.4.3 As specified in Conditions 2.5.2.4 and 2.5.7 engine startup shall not exceed 30 minutes. An engine startup period of less than 30 minutes shall not require an opacity observation to monitor compliance with the opacity limit in Condition 2.4.2. A . record shall be kept of the date and time each engine was started and when it was shutdown. 2.4.4 An opacity observation shall be conducted annually (calendar year period) on each engine to monitor compliance with the opacity limit in Condition 2.4.1. If an engine is operated more than 250 hours in any calendar year period, a second opacity observation shall be conducted. If two opacity readings are conducted in the annual (calendar year) period, such readings shall be conducted at least thirty days apart. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. 2.4.5 All opacity observations shall be performed by an observer with current and valid Method 9 certification. Results of Method 9 readings and a copy of the certified Method 9 reader's certificate shall be kept on site and made available to the Division upon request. 2.5 Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", as follows: These requirements included in this Condition 2.5 are only federally enforceable. As of the date of renewal permit issuance [DATE], the requirements in 40 CFR Part 63 Subpart ZZZZ promulgated on March 3, 2010 have not been adopted into Colorado Regulation No. 8, Part E by the Division and are therefore not state-enforceable. In the event that the Division adopts these requirements the emergency fire pump engine will be subject to the APEN reporting and minor source permitting requirements and these requirements will be state-enforceable. When do I have to comply with this subpart (' 60.6595) 2.5.1 If you have an existing stationary CI RICE with a site rating of less than or equal to 500 brake HP located a major source of HAP emissions, you must comply with the applicable emission limitations and operating limitations no later than May 3, 2013. (§ 63.6595(a)(1)) What emission limitations must I meet if I own or operate an existing stationary RICE with a site rating of equal to or less than 500 brake HP located at a major source of HAP emissions (¢ 63.6602) Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 26 2.5.2 If you own or operate an existing stationary RICE with a site rating of equal to or less than 500 brake HP located at a major source of HAP emissions, you must comply with the emission limitations in Table 2c of 40 CFR Part 63 Subpart ZZZZ which apply to you. Compliance with the numerical emission limitations established of 40 CFR Part 63 Subpart ZZZZ is based on the results of testing the average of three 1- hour runs using the testing requirements and procedures in §63.6620 and Table 4 of 40 CFR Part 63 Subpart ZZZZ. (§ 63.6602) Note that this engine is not subject to emission limitations but is subject to work practice standards. The requirements in Table 2c of 40 CFR Part 63 Subpart ZZZZ that apply to this engine, except during periods of startup are as follows: 2.5.2.1 Change oil and filter every 500 hours of operation or annually whichever comes first. (40 CFR Part 63 Subpart ZZZZ, Table 2c, item 1.a) 2.5.2.2 Inspect air cleaner every 1,000 hours of operation or annually whichever comes first. (40 CFR Part 63 Subpart ZZZZ ,Table 2c, item 1.b) 2.5.2.3 Inspect all hoses and belts every 500 hours of operation or annually whichever comes first, and replace as necessary. (40 CFR Part 63 Subpart ZZZZ Table 2c, item 1.c) The requirements in Table 2c of 40 CFR Part 63 Subpart ZZZZ that apply to this engine during periods of startup are as follows: 2.5.2.4 Minimize the engine's time spent at idle and minimize the engine's startup time at startup to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the non-startup emission limitations apply. (40 CFR Part 63 Subpart ZZZZ Table 2c, item 1) Notwithstanding the above requirements, the following applies: 2.5.2.5 If an emergency engine is operating during an emergency and it is not possible to shut down the engine in order to perform the management practice requirements on the schedule required in Conditions 2.5.2.1 through 2.5.2.3, or if performing the management practice on the required schedule would otherwise pose an unacceptable risk under Federal, State, or local law,the management practice can be delayed until the emergency is over or the unacceptable risk under Federal, State, or local law has abated. The management practice should be performed as soon as practicable after the emergency has ended or the unacceptable risk under Federal, State, or local law has abated. Sources must report any failure to perform the management practice on the schedule required and the Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 27 Federal, State or local law under which the risk was deemed unacceptable. (40 CFR Part 63 Subpart ZZZZ, Table 2c, footnote 1) 2.5.2.6 Sources have the option to utilize an oil analysis program as described in Condition 2.5.8 in order to extend the specified oil change requirement in Condition 2.5.2.1. (40 CFR Part 63 Subpart ZZZZ, Table 2c, footnote 2) 2.5.2.7 Sources can petition the Administrator pursuant to the requirements of 40 CFR 63.6(g) for alternative work practices. (40 CFR Part 63 Subpart ZZZZ, Table 2c, footnote 3) What are my general requirements for complying with this subpart? (§ 63.6605) 2.5.3 You must be in compliance with the emission limitations and operating limitations in this subpart that apply to you at all times. (§ 63.6605(a)) 2.5.4 At all times you must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Division which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. (§ 63.6605(b)) What are my monitoring, installation, collection, operation, and maintenance requirements? (§ 63.6625) 2.5.5 If you own or operate an existing emergency or black start stationary RICE with a site rating of less than or equal to 500 HP located at a major source of HAP emissions, you must operate and maintain the stationary RICE and after-treatment control device (if any) according to the manufacturer's emission-related written instructions or develop your own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. (§ 63.6625(e)(2)) 2.5.6 If you own or operate an existing emergency stationary RICE with a site rating of less than or equal to 500 brake HP located at a major source of HAP emissions or an existing emergency stationary RICE located at an area source of HAP emissions, you must install a non-resettable hour meter if one is not already installed. (§ 63.6625(f)) 2.5.7 If you operate a new or existing stationary engine, you must minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 28 which time the emission standards applicable to all times other than startup in Tables 1 a, 2a, 2c, and 2d of 40 CFR Part 63 Subpart ZZZZ apply. (§ 63.6625(h)) 2.5.8 If you own or operate a stationary engine that is subject to the work, operation or management practices in Condition 2.5.2.1, you have the option of utilizing an oil analysis program in order to extend the specified oil change requirement in Condition 2.5.2.1. The oil analysis must be performed at the same frequency specified for changing the oil in Condition 2.5.2.1. The analysis program must at a minimum analyze the following three parameters: Total Base Number, viscosity, and percent water content. The condemning limits for these parameters are as follows: Total Base Number is less than 30 percent of the Total Base Number of the oil when new; viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or percent water content (by volume) is greater than 0.5. If all of these condemning limits are not exceeded, the engine owner or operator is not required to change the oil. If any of the limits are exceeded, the engine owner or operator must change the oil before continuing to use the engine. The owner or operator must keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes for the engine. The analysis program must be part of the maintenance plan for the engine. (§ 63.6625(i)) How do I demonstrate continuous compliance with the emission limitations and operating limitations? (§63.6640) 2.5.9 You must demonstrate continuous compliance with each emission limitation and operating limitation in Tables la and ib, Tables 2a and 2b, Table 2c, and Table 2d [Conditions 2.5.2.1 through 2.5.2.3] to this subpart that apply to you according to methods specified in Table 6 to this subpart. (§ 63.6640(a)) The methods specified in Table 6 of Subpart ZZZZ are as follows: 2.5.9.1 Operating and maintaining the stationary RICE according to the manufacturer's emission-related operation and maintenance instructions (Subpart ZZZZ, Table 6, item 9.a.i); or 2.5.9.2 Develop and follow your own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. (Subpart ZZZZ, Table 6, item 9.a.ii) 2.5.10 If you own or operate an existing emergency stationary RICE with a site rating of less than or equal to 500 brake HP located at a major source of HAP emissions, a new or reconstructed emergency stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions that was installed on or after June 12, 2006, or an existing emergency stationary RICE located at an area source of HAP emissions, you must operate the emergency stationary RICE according to the requirements Conditions 2.5.10.1 through 2.5.10.3. Any operation other than emergency operation, maintenance and testing, and operation in non-emergency Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 29 situations for 50 hours per year, as described in Conditions 2.5.10.1 through 2.5.10.3, is prohibited. If you do not operate the engine according to the requirements in Conditions 2.5.10.1 through 2.5.10.3, the engine will not be considered an emergency engine under this subpart and will need to meet all requirements for non-emergency engines. (§ 63.6640(O(1)) 2.5.10.1 There is no time limit on the use of emergency stationary RICE in emergency situations. (§ 63.6640(O(1)(i)) 2.5.10.2 You may operate your emergency stationary RICE for the purpose of maintenance checks and readiness testing, provided that the tests are recommended by Federal, State or local government, the manufacturer, the vendor, or the insurance company associated with the engine. Maintenance checks and readiness testing of such units is limited to 100 hours per year. The owner or operator may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the owner or operator maintains records indicating that Federal, State, or local standards require maintenance and testing of emergency RICE beyond 100 hours per year. (§ 63.6640(f)(1)(ii)) 2.5.10.3 You may operate your emergency stationary RICE up to 50 hours per year in non-emergency situations, but those 50 hours are counted towards the 100 hours per year provided for maintenance and testing. The 50 hours per year for non-emergency situations cannot be used for peak shaving or to generate income for a facility to supply power to an electric grid or otherwise supply power as part of a financial arrangement with another entity; except that owners and operators may operate the emergency engine for a maximum of 15 hours per year as part of a demand response program if the regional transmission organization or equivalent balancing authority and transmission operator has determined there are emergency conditions that could lead to a potential electrical blackout, such as unusually low frequency, equipment overload, capacity or energy deficiency, or unacceptable voltage level. The engine may not be operated for more than 30 minutes prior to the time when the emergency condition is expected to occur, and the engine operation must be terminated immediately after the facility is notified that the emergency condition is no longer imminent. The 15 hours per year of demand response operation are counted as part of the 50 hours of operation per year provided for non- emergency situations. The supply of emergency power to another entity or entities pursuant to financial arrangement is not limited by this paragraph Condition 15.1.9.3, as long as the power provided by the financial arrangement is limited to emergency power. (§ 63.6640(f)(1)(iii)) What records must I keep? (¢ 63.6655) Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 30 2.5.11 You must keep records of the maintenance conducted on the stationary RICE in order to demonstrate that you operated and maintained the stationary RICE and after- treatment control device (if any) according to your own maintenance plan if you own or operate an existing stationary emergency RICE. (§ 63.6655(e) and § 63.6655(e)(2)) 2.5.12 If you own or operate an existing emergency stationary CI RICE with a site rating of less than or equal to 500 brake Hp located at major source of HAP emissions that does not meet the standards applicable to non-emergency engines, you must keep records of the hours of operation of the engine that is recorded through the non- resettable hour meter. The owner or operator must document how many hours are spent for emergency operation, including what classified the operation as emergency and how many hours are spent for non-emergency operation. If the engines are used for demand response operation, the owner or operator must keep records of the notification of the emergency situation, and the time the engine was operated as part of demand response. (§ 63.6655(f) and § 63.6655(f)(1)) 2.6 These engines are subject to the requirements in 40 CFR part 63 Subpart A "General Provisions", as adopted by reference in Colorado Regulation No. 8, Part E, Section I as specified in 40 CFR Part 63 Subpart ZZZZ § 63.6665. These requirements include, but are not limited to the following: 2.6.1 Prohibited activities in § 63.4(a). 2.6.2 Circumvention in § 63.4(b) Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT - Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 31 3. S004—Rentech Natural Gas Fired Boiler Rated at 129 MMBtu/hr Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number BACT 3.1. See Condition 3.1 N/A See Condition 3.1 Requirements ' PM 3.2. 0.164 lbs/MMBtu N/A Fuel Restriction Only Natural Gas is Used as Fuel N/A 2.28 tons/yr 0.0186 lb/MMBtu Recordkeeping Monthly PM1p N/A 2.28 tons/yr 0.0186 lb/MMBtu and Calculation NOx 3.3. 0.038 lb/MMBtu,on a 3-hr N/A Continuous Continuously rolling average Emission N/A 4.7 tons/yr Monitoring System CO 3.4. 0.039 lb/MMBtu,based on the N/A See Condition 3.4. average of three(3)test runs N/A 4.75 tons/yr 0.039 lb/MMBtu Recordkeeping Monthly and Calculation Natural Gas 3.5 N/A 231.9 Fuel Meter Recordkeeping Daily Consumption MMscf/yr NSPS General 3.6 N/A N/A N/A As required in the NSPS General Provisions Provisions NSPS 3.7. Determination of Annual N/A Daily Recording 12-Month Recordkeeping Capacity Factor of Fuel Rolling Requirement Average Continuous 3.8 N/A N/A N/A See Condition 3.8 Emission Monitoring Requirements Opacity 3.9. Not to Exceed 20%, Except as N/A Fuel Restriction Only Natural Provided for in 3.10 Gas is Used Opacity 3.10. For Certain Operational N/A as Fuel Activities-Not to Exceed 30%, for a Period or Periods Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes Opacity—State- 3.11. Not to Exceed 20% N/A Only 3.1 The auxiliary boiler is subject to the requirements of the prevention of Significant Deterioration (PSD) Program. Best Available Control Technology (BACT) shall be applied for control of Nitrogen Oxides (NOx), Carbon Monoxide (CO), Particulate Matter (PM and PM10) and Volatile Organic Compounds. BACT has been determined as follows: Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 32 3.1.1 BACT for NOx has been determined to be Low NOx burners with the emission limit identified in Condition 3.3.1 (Colorado Construction Permit 02WE0228). 3.1.2 BACT for CO has been determined to be good combustion practices with the emission limit identified in Condition 3.4.1 (Colorado Construction Permit 02WE0228). 3.1.3 BACT for PM and PMi° has been determined to be use of pipeline quality natural gas as fuel. 3.1.4 BACT for VOC has been determined to be use of pipeline quality natural gas as fuel and good combustion practices. 3.2 Particulate Matter (PM and PM10) emissions from the boiler are subject to the following requirements: 3.2.1 PM emissions shall not exceed 0.164 lb/MMBtu (Colorado Construction Permit 02WE0228 and Colorado Regulation No. 1, Section III.A.1.b). In the absence of credible evidence to the contrary, compliance with the particulate matter emission limits is presumed is natural gas is the only fuel permitted for use as fuel in the boiler. Note that the numeric PM standard was determined using the design heat input for the boiler (129 MMBtu/hr) in the following equation: PE = 0.5 x (FI)"°26, where: PE=particulate standard in lbs/MMBtu FI = fuel input in MMBtu/hr 3.2.2 Emissions of PM and PMi° shall not exceed the annual limitations listed above (Colorado Construction Permit 02WE0228, as modified under the provisions of Section I, Condition 1.3 to add the annual PM and PMi° emission limitations based on requested emissions on the APEN submitted March 21, 2007). Monthly emissions from the boiler shall be calculated by the end of the subsequent month using the above emission factors (from manufacturer), the monthly natural gas consumption and the heat content of the natural gas for the month as indicated in the DAHS in the following equation: Tons/mo=EF(lb/MMBtu)x natural gas use(MMscf/mo)x heat content of gas(MMBtu/MMscf) 2000 Ibs/ton Monthly emissions shall be used in a rolling twelve month total to monitor compliance with the annual limitations. Each month a new twelve month total shall calculated using the previous twelve months' data. 3.3 Nitrogen Oxide (NOx) emissions from the boiler are subject to the following requirements: Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 33 3.3.1 For purposes of BACT,NOx emissions from the boiler shall not exceed 0.038 lb/MMBtu, on a 3-hour rolling average (Colorado Construction Permit 02WE0228, as modified under the provisions of Section I, Condition 1.3 to specify the averaging time). Compliance with the BACT NOx limit shall be monitored using the NOx CEMS required by Condition 3.9. For any hour in which fuel is combusted in the unit the permittee shall calculate the hourly average NOx concentration in units of lb/MMBtu in accordance with the requirements in 40 CFR Part 60 and Condition 6.4 of this permit. Hourly averages shall be used in a 3-hr rolling average to monitor compliance with the NOx BACT limit. 3.3.2 Annual emissions of NOx from the boiler shall not exceed the above limitations (Colorado Construction Permit 02WE0228). For any hour in which fuel is combusted in the boiler, the permittee shall program the DAHs to calculate lb/hr NOx emissions in accordance with the requirements in Condition 6.1.1.4.b of this permit and 40 CFR Part 60. Specifically hourly mass NOx emissions (in lb/hr) shall be calculated by multiplying the hourly NOx lb/MMBtu value by the hourly heat input value (MMBtu/hr). The hourly NOx lb/MMBtu and heat input values shall be determined using the appropriate equations in Method 19 of 40 CFR Part 60. Hourly emissions shall be summed to determine monthly emissions (in tons). Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months' data. 3.4 Carbon Monoxide (CO) emissions from the boiler are subject to the following requirements: 3.4.1 For purposes of BACT, CO emissions from the boiler shall not exceed 0.039 lb/MMBtu, based on the average of three (3)test runs (Colorado Construction Permit 02WE0228, as modified under the provisions of Section I, Condition 1.3 to specify the averaging time). Compliance with the CO BACT limit shall be monitored as follows: 3.4.1.1 Compliance with the CO BACT emission limitation shall be presumed, in the absence of credible evidence to the contrary, provided the boiler is operated in accordance with manufacturer's recommendations and good engineering practices. 3.4.1.2 A performance test shall be conducted within sixty (60) boiler operating days of re-starting the boiler. A boiler operating day is defined as any calendar day in which fuel is combusted in the boiler for any period of time. Thereafter, a performance test shall be conducted whenever hours of operation for the boiler reaches 1,200 hours in any two consecutive years. This test shall be conducted within 60 days of reaching 1,200 hours. Performance tests shall be conducted using the appropriate EPA methods. A stack testing protocol shall be submitted for Division approval at least thirty (30) calendar days prior to performance of the test required under Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 34 this condition. No stack test required herein shall be performed without prior written approval of the protocol by the Division. The Division reserves the right to witness the test. In order to facilitate the Division's ability to make plans to witness the test, notice of the date (s) for the stack test shall be submitted to the Division at least thirty (30) calendar days prior to the test. The Division may for good cause shown, waive this thirty (30) day notice requirement. In instances when a scheduling conflict is presented, the Division shall immediately contact the permittee in order to explore the possibility of making modifications to the stack test schedule. The required number of copies of the compliance test results shall be submitted to the Division within forty-five (45) calendar days of the completion of the test unless a longer period is approved by the Division. 3.4.2 Annual emissions CO from the boiler shall not exceed the limitation stated above (Colorado Construction Permit 02WE0228, as modified under the provision of Section I, Condition 1.3 to increase CO emissions to level requested on the APEN received March 21, 2007). Monthly emissions from the boiler shall be calculated by the end of the subsequent month using the emission factor above (from the manufacturer), the monthly natural gas consumption and the heat content of the natural gas for the month as indicated in the DAHS in the following equation: Tons/mo=EF(lb/MMBtu)x natural gas use(MMscf/mo)x heat content of gas(MMBtu/MMscf) 2000 lbs/ton Monthly emissions shall be used in a rolling twelve month total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months' data. 3.5 Natural gas consumption from the boiler shall not exceed the limitation stated above (Construction Permit 02WE0228). Natural gas consumed in the boiler shall be recorded daily, as required by 40 CFR Part 60 Subpart Db § 60.49(d), as adopted by reference in Colorado Regulation No. 6, Part A. Daily quantities of natural gas consumed shall be summed to determine the monthly natural gas consumption. Monthly quantities of natural gas consumption for the boiler shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months data. 3.6 Regulation No. 6, Part A, Subpart A, General Provisions applies as follows: 3.6.1 No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gasses discharged to the atmosphere (§ 60.12) Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT • Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 35 3.6.2 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Division which may include, but is not limited to monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source (Colorado Construction Permit 91MR933, initial approval, modification 4, dated October 26, 1999 and 40 CFR Subpart A § 60.11(d)). 3.7 The owner of operator of an affected facility shall record and maintain records of the amounts of each fuel combusted during each day and calculate the annual capacity factor individually for coal, distillate oil, residual, oil, natural gas, wood, and municipal-type solid waste for the reporting period. The annual capacity factor is determined on a 12-month rolling average basis with a new annual capacity factor calculated at the end of each calendar month (40 CFR Part 60 Subpart Db § 60.49b(d), as adopted by reference in Colorado Regulation No. 6, Part A). 3.8 The owner or operator of an affected facility subject to a NOx standard under 40 CFR Part 60 Subpart Db § 60.44b shall install, calibrate, maintain, and operate continuous emission monitoring systems (CEMS) for measuring NOx and O2 (or CO2), and shall record the output of the system (40 CFR Part 60 Subpart Db § 60.48b(b)(1), as adopted by reference in Colorado Regulation No. 6, Part A). The NOx CEMS shall meet the requirements in Condition 6 of this permit. In addition, to recording the NOx concentration (lb/MMBtu), as required by Condition 6.4.2, the CEMS shall also record the NOx mass emission rate in lbs/hr and tons/month. Monthly NOx emissions from the CEMS shall be used as specified by Condition 3.3.2 to monitor compliance with the annual NOx emission limitation. 3.9 Except as provided for in Condition 3.10 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Construction Permit 02WE0228 and Colorado Regulation No.1, Section II.A.1). In the absence of credible evidence to the contrary, compliance with the opacity standard shall be presumed since only natural gas is permitted to be used as fuel for this boiler. 3.10 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment which is in excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). In the absence of credible evidence to the contrary, compliance with the opacity standard shall be presumed since only natural gas is permitted to be used as fuel for this boiler. 3.11 State-Only Requirement: No owner or operator may discharge, or cause the discharge into the atmosphere of any particulate matter which is greater than 20% opacity (Colorado Regulation No. 6, Part B, Section II.C.3). In the absence of credible evidence to the contrary, compliance Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 36 with the opacity standard shall be presumed since only natural gas is permitted to be used as fuel for this boiler. Note that this opacity standard applies at all times except during periods of startup, shutdown and malfunction (40 CFR Part 60 Subpart A § 60.11(c), as adopted by reference in Colorado Regulation No. 6, Part B, Section I.A). Note that this opacity requirement is more stringent than the opacity requirement in Condition 3.10 during periods of building of a new fire, cleaning of fire boxes, soot blowing, process modifications and adjustment or occasional cleaning of control equipment. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 37 4. S006—Marley Cooling Water Tower Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number BACT 4.1. N/A N/A N/A See Condition 4.1. Requirements PM 4.2. N/A 19.3 tons/yr See Condition 4.2 Recordkeeping Monthly and Calculation PM10 N/A 19.3 tons/yr Water Circulated 4.2 N/A 92,505.6 N/A Recordkeeping Monthly mmgal/yr Total Solids 4.3 N/A N/A N/A Laboratory Quarterly Concentration Analysis Opacity 4.4 Not to Exceed 20% N/A See Condition 4.4. 4.1 The cooling water tower is subject to the requirements of the prevention of Significant Deterioration (PSD) Program. Best Available Control Technology (BACT) shall be applied for control of Particulate Matter (PM and PM1o). BACT has been determined to be the use of drift eliminators to achieve drift levels of 0.0005% (Colorado Construction Permit 02WE0228). 4.2 Particulate Matter (PM and PM10) emissions shall not exceed the limitations above (Colorado Construction Permit 02WE0228, as modified under the provisions of Section I, Condition 1.3, to include the requested PM and PM10 emissions indicated on the APEN submitted on March 21, 2007). Emissions shall be calculated monthly using the following equations: PM=PM10(tons/month)=O x d x%drift x x total solids concentration 2000 lbs/ton Where: Q=water circulated,gal/month d=density of water,lbs/gal(from T5 application d= 8.34 lbs/gal) %drift=0.0005%(BACT limitation) Total solids=in ppm(lbs solids/106 lbs water)-to be determined by Condition 4.3. The most recent analysis shall be used in the monthly calculation. Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months data. 4.3 The Water Circulated through the cooling water tower shall not exceed the limitation above (Colorado Construction Permit 02WE0228, as modified under the provisions of Section I, Condition 1.3, to include the requested water circulation limit indicated on the APEN submitted on March 21, 2007). The quantity of water circulated shall be determined each month by multiplying the hours of operation of each pump (two pumps, each pump 88,000 gal/min) by the design flow rate of each pump as follows: Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 38 Water Circulation Rate =hours of operation (hrs/mo)x Design Flow Rate (Gal/min) x 60 min/hr Monthly quantities of water shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months data. 4.4 Samples of water circulated through the tower shall be taken and analyzed quarterly. Calculations of monthly emissions shall be made using the total solids concentration determined from the most recent required analysis. A copy of the procedures used to obtain and to analyze samples shall be maintained and made available to the Division upon request. 4.5 Opacity of emissions from the cooling water tower shall not exceed 20% (Colorado Regulation No. 1, Section II.A.1). In the absence of credible evidence to the contrary, compliance with the opacity standard shall be presumed, provided the drift eliminators on the tower are operated and maintained in accordance with the manufacturers= recommendations and good engineering practices. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 39 5. Facility Wide HAP Limits Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number Facility Wide 5.1 N/A 2.44 tons/yr See Condition 5.1 Recordkeeping and Monthly Formaldehyde Calculation Emissions Facility Wide N/A 13.1 tons/yr See Condition 5.1 Total HAPs 5.1 Emissions of HAPs shall not exceed the limitations stated above (Colorado Construction Permit 02WE0228, as modified under the provisions of Section I, Condition 1.3 to reflect requested emissions on the APENS submitted on March 21, 2007). Emissions shall be calculated by the end of the subsequent month using actual throughputs and the following compliance emission factors. Emission Unit I Pollutant I Emission Factor I Emission Factor Source Turbines/HRSG/Duct Formaldehyde Unit 1 — 1.5 x le lb/MMBtu From performance tests Burners Unit 2— 1.3 x 10'4 lb/MMBtu conducted May 8, 11, 12, 20 and September 16, 2004. Acetaldehyde 1.37 x 10 ' lb/MMscf From California Air Acrolein 1.89 x 10-2 Ib/MMscf Toxics Emission Factor Benzene 1.33 x 1012 lb/MMscf (databases)for natural gas-fired turbines with Ethylbenzene 1.79 x 1(12 Ib/MMscf COC and SCR. Hexane 2.59 x 10"1 Ib/MMscf Propylene Oxide 4.78 x 10"2 lb/MMscf Toluene 7.10 x 10"2 lb/MMscf Xylene 2.61 x 10-2 lb/MMscf Cooling Water Tower Chloroform 2.3 kg/109 liters from"Locating and Estimating Air Emissions from Sources of Chloroform",EPA-450/4- 84-007c, March 1984, for re-circulating units. A twelve-month rolling total shall be maintained for demonstration of compliance with annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. Records of calculations shall be maintained for Division inspection upon request. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 40 6. Continuous Emission Monitoring Requirements Note that the continuous emission monitoring requirements identified in this Condition for each turbine/HRSG/duct burner, are in addition to the continuous emission monitoring requirements required by the Acid Rain Program, which are identified in Section III of this permit. 6.1 Equipment and QA/QC Requirements 6.1.1 The Continuous Emission Monitoring Systems (CEMS) are subject to the following requirements: 6.1.1.1 The NOx (and diluent) monitors for the auxiliary boiler is subject to the applicable requirements of 40 CFR Part 60. The monitoring systems shall meet the equipment, installation and performance specifications of 40 CFR Part 60 Appendix B, Performance Specifications 2 and 3. These CEMS are subject to the quality assurance/quality control requirements in 40 CFR Part 60 Appendix F and Subpart A § 60.13 and Condition 6.1.1.4 of this permit. 6.1.1.2 Except as provided for below, the CO monitors for the turbines/HRSGS/duct burners are subject to the applicable requirements of 40 CFR Part 60 (Colorado Construction Permit 02WE0228). The monitoring systems shall meet the equipment, installation and performance specifications of 40 CFR Part 60 Appendix B, Performance Specification 4/4A. These CEMS are subject to the quality assurance/quality control requirements in 40 CFR Part 60 Appendix F and Subpart A § 60.13 and Condition 6.1.1.4 of this permit. a. The CO CEMS data shall meet the applicable "primary equipment hourly operating requirements" for hourly average calculation methodology specified in 40 CFR Part 75 Subpart B § 75.10(d). b. Annual CO monitor relative accuracy (RA) testing will be performed in ppm @ 15 % O2 measurement units, and will be performed according to 40 CFR Part 60, Appendix B, Performance Specification 4A. c. Relative accuracy test audit(RATA) frequency will be determined according to 40 CFR Part 60 Appendix F. 6.1.1.3 The NOx (and diluent) monitors for the turbines/HRSGs/duct burners are subject to the applicable requirements of 40 CFR Part 75 (Colorado Construction Permit 02WE0228). The monitoring systems shall meet the equipment, installation and performance specification requirements in 40 CFR Part 75, Appendix A. These CEMS shall meet the quality assurance/quality control requirements in 40 CFR Part 75, Appendix B Operating Permit Number: 05OPWE279 • OFirst Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 41 and the conversion procedures of Appendix F and Condition 6.1.1.4 of this • permit. 6.1.1.4 The NOx and CO CEMS for the turbines/HRSGs/duct burners and the NOx CEMS for the auxiliary boiler are subject to the following requirements: a. Relative Accuracy Test Audits (RATAs): RATAs shall be conducted in the units (e.g., lb/MMBtu, ppm) of the emission limitation for all of the emission limitations that are applicable to the emissions unit. The RATAs for emissions units that have annual emission limitations (tons/yr) will be conducted in terms of pounds per hour(lb/hr). b. The DAHS shall be able to record and manipulate the data in the units (e.g., lb/MMBtu, ppm) of the emission limitation and meet the reporting requriements for all for the emissions limitations that are applicable to the emissions unit. 6.1.2 Quality assurance/quality control plans shall be prepared for the continuous emission monitoring systems as follows: 6.1.2.1 The quality assurance/quality control plan for the NOx(and diluent) monitors for the auxiliary boiler shall be prepared in accordance with the applicable requirements in 40 CFR Part 60, Appendix F. 6.1.2.2 The quality assurance/quality control plan for the CO monitors for the turbines/HRSG/duct burners shall be prepared in accordance with the applicable requirements in 40 CFR Part 75, Appendix B. 6.1.2.3 The quality assurance /quality control plan for the NOx (and diluent) monitors for the turbines/HRSG/duct burners shall be prepared in accordance with the applicable requirements in 40 CFR Part 75, Appendix B. The quality assurance/quality control plans shall be made available to the Division upon request. Revisions shall be made to the plans at the request of the Division. 6.2 General Provisions 6.2.1 CO monitors for turbines/HRSGs/duct burners and NOx(and diluent) monitors for auxiliary boiler: The permittee shall ensure that all continuous emission monitoring systems required are in operation and monitoring unit emissions at all times except for monitoring system breakdowns, repairs, calibration checks and zero and span adjustments required under 40 CFR Part 60 Subpart A § 60.13(d) (40 CFR Part 60 Subpart A § 60.13(e)). 6.2.2 NOx (and diluent) monitors for turbines/HRSGs/duct burners: The permittee shall ensure that all continuous emission monitoring systems required are in operation Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit # 05OPWE279 Page 42 and monitoring unit emissions at all times that the affected unit combusts any fuel except as provided in 40 CFR § 75.11(e) and during periods of calibration, quality assurance, or preventative maintenance performed pursuant to 40 CFR Part 75, § 75.21 and Appendix B, periods of repair, periods of backups of data from the data acquisition and handling system or recertification performed pursuant to 40 CFR § 75.20 (40 CFR Part 75 § 75.10(d)). 6.2.3 Alternative monitoring systems, alternative reference methods, or any other alternatives for the required continuous emission monitoring systems shall not be used without having obtained prior written approval from the appropriate agency, either the Division or the U. S. EPA, depending on which agency is authorized to approve such alternative under applicable law. Any alternative continuous emission monitoring systems or continuous opacity monitoring systems must be certified in accordance with the applicable requirements of 40 CFR Part 60 or 40 CFR Part 75 prior to use. 6.2.4 All test and monitoring equipment, methods, procedures and reporting shall be subject to the review and approval by the appropriate agency, either the Division or the U. S. EPA, depending on which agency is authorized to approve such item under applicable law, prior to any official use. The Division shall have the right to inspect such equipment, methods and procedures and data obtained at any time. The Division may provide a witness(s) for any and all tests as Division resources permit. 6.2.5 A file suitable for inspection shall be maintained of all measurements, including continuous monitoring system, monitoring device, and performance testing measurements; all continuous monitoring system performance evaluations; all continuous monitoring system or monitoring device calibration checks; adjustments and maintenance performed on these systems or devices; and all other information required by applicable portions of 40 CFR Part 60 Subpart A and Appendices B and F and 40 CFR Part 75. 6.2.6 Records shall be maintained of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the source; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative (40 CFR Part 60 Subpart A § 60.7(b) and Colorado Construction Permit 02WE0228). 6.3 Data Replacement Requirements for each Turbine/HRSG/Duct Burner CEMS For periods when quality assured data is not available from the continuous emission monitoring systems the data replacement procedures in 40 CFR Part 75 Subpart D shall be used for determining the total (annual) emissions. Although CO emissions are not specifically referenced in the Subpart D procedures, the CEMS data acquisition system is programmed to substitute CO emissions using the same procedures specified for NOx. For purposes of monitoring compliance with the annual emission limitations (tons/yr) replaced and bias-adjusted data shall be included Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT • Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 43 when assessing compliance with the annual limitations. Note that since CO emissions are not subject to requirements in 40 CFR Part 75 the CO emission data is not required to be bias- adjusted. 6.4 NSPS Subpart Db Provisions for the Auxiliary Boiler NOx CEMS 6.4.1 The continuous emission monitoring system required by Section II, Condition 3.9 of this permit shall be operated and data recorded during all periods of operation of the affected facility except for continuous monitoring system breakdowns and repairs. Data is recorded during calibration checks, and zero and span adjustments (40 CFR Part 60 Subpart Db § 60.48b(c)). 6.4.2 The 1-hour average nitrogen oxides emission rates measured by the continuous nitrogen oxides monitor required by Section II, Condition 3.8 of the permit and required under § 60.13(h) shall be expressed in ng/J or lb/MMBtu heat input and shall be used to calculate the average emission rates. The 1-hour averages shall be calculated using the data points required under § 60.13(h)(3) (40 CFR Part 60 Subpart Db § 60.48b(d)). 6.4.3 The procedures under § 60.13 shall be followed for installation, evaluation and operation of the continuous monitoring systems (40 CFR Part 60 Subpart Db § 60.48b(e)). The span value for nitrogen oxides is 100 ppm. 6.5 Recordkeeping and Reporting Requirements 6.5.1 The owner or operator of a facility required to install, maintain, and calibrate continuous monitoring equipment shall submit to the Division, by the end of the calendar month following the end of each semi-annual period (i.e., January—June, July - December), a report of excess emissions for all pollutants monitored for that quarter (40 CFR Part 60 Subpart A § 60.7(c)). Reports shall consist of the following information for all pollutants monitored for the semi-annual period and all applicable limits: 6.5.1.1 The magnitude of excess emissions computed in accordance with 40 CFR Part 60 Subpart A § 60.13(h), any conversion factor(s) used, and the date and time of commencement and completion of each time period of excess emissions and the process operating time during the reporting period (40 CFR Part 60 Subpart A § 60.7(c)(1)). 6.5.1.2 Specific identification of each period of excess emissions that occurs during startups, shutdowns, and malfunctions of the affected facility. The nature and cause of any malfunction(if known),the corrective action taken or preventative measures adopted (40 CFR Part 60 Subpart A § 60.7(c)(2)). 6.5.1.3 The date and time identifying each period during which the continuous monitoring system was inoperative except for zero and span checks and Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit # 05OPWE279 Page 44 the nature of the system repairs or adjustments (40 CFR Part 60 Subpart A § 60.7(c)(3)). 6.5.1.4 When no excess emissions have occurred or the continuous monitoring system(s) have not been inoperative, repaired, or adjusted, such information shall be stated in the report (40 CFR Part 60 Subpart A § 60.7(c)(4)). 6.5.2 The owner or operator of a facility required to install, maintain, and calibrate continuous monitoring equipment shall submit to the Division, by the end of the calendar month following the end of each semi-annual period (i.e., January—June, July - December), a summary report for that semi-annual period (40 CFR Part 60 Subpart A § 60.7(c)). One summary report form shall be submitted for each pollutant monitored and all applicable limits. This report shall contain the information and be presented in a format approved by the Division. If the total duration of excess emissions for the reporting period is less than 1 percent of the total operating time for the reporting period and continuous monitoring system (CMS) downtime is less than 5 percent of the total operating time for the reporting period, only the summary report form shall be submitted and the excess emission report described in Condition 6.5.1 need not be submitted unless required by the Division (40 CFR Part 60 Subpart A § 60.7(d)(1)). If the total duration of excess emissions for the reporting period is 1 percent or greater of the total operating time for the reporting period or the total CMS downtime for the reporting period is 5 percent or greater of the total operating time for the reporting period, the summary report form and the excess emission report described in Condition 6.5.1 shall both be submitted (40 CFR Part 60 Subpart A § 60.7(d)(1)). Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 45 7. M001 - Gasoline Storage Tank, 500 gallons aboveground Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number Gasoline 7.1 N/A N/A N/A Recordkeeping Monthly Throughput 40 CFR Pat 63 7.2. Work Practice Standards N/A See Condition 7.2 Subpart CCCCCC Requirements Note that this emission units is exempt from the APEN reporting requirements in Regulation No. 3,Part A and the construction permit requirements in Regulation No. 3, Part B. These requirements included in this Section II.7 are only federally enforceable. As of the date of renewal permit issuance [DATE], the requirements in 40 CFR Part 63 Subpart CCCCCC have not been adopted into Colorado Regulation No. 8, Part E by the Division and are therefore not state-enforceable. In the event that the Division adopts these requirements this tank will be subject to the APEN reporting and minor source permitting requirements and these requirements will be state-enforceable. 7.1 The quantity of gasoline processed through this tank shall be monitored and recorded monthly. Monthly records of gasoline processed shall be retained as required by Condition 7.2.1. 7.2 This tank is subject to the requirements in 40 CFR Part 63 Subpart CCCCCC, "National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities", as follows: 7.2.1 An affected source shall, upon request by the division, demonstrate that their average monthly throughput is less than the 10,000-gallon or the 100,000-gallon threshold level, as applicable (40 CFR Part 63 Subpart CCCCCC § 63.11111(e)). 7.2.2 You must not allow gasoline to be handled in a manner that would result in vapor releases to the atmosphere for extended periods of time. Measures to be taken include, but are not limited to, the following (40 CFR Part 63 Subpart CCCCCC § 63.11116(a)): 7.2.2.1 Minimize gasoline spills; 7.2.2.2 Clean up spills as expeditiously as practicable; 7.2.2.3 Cover all open gasoline containers and all gasoline storage tank fill-pipes with a gasketed seal when not in use; 7.2.2.4 Minimize gasoline sent to open waste collection systems that collect and transport gasoline to reclamation and recycling devices, such as oil/water separators; Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 46 7.2.3 You are not required to submit notifications or reports, but you must have records available within 24 hours of a request by the Division to document your gasoline throughput (40 CFR Part 63 Subpart CCCCCC § 63.11116(b)). 7.2.4 You must comply with the requirements of this subpart by the applicable date specified in Condition 6.2.2 (40 CFR Part 63 Subpart CCCCCC § 63.11116(c)). 8. M002-Cold Cleaner Solvent Vat Parameter Permit Limitations Compliance Emission Monitoring Condition Factor Number Short Term Long Term Method Interval Work Practice 8.1 N/A N/A N/A Internal Audit Annually Standards Transfer and 8.2 N/A N/A N/A Certification Annually Storage of Waste/Used Solvents Note that this emission unit is exempt from the APEN reporting requirements in Regulation No. 3, Part A and the construction permit requirements in Regulation No. 3,Part B. 8.1 Operation of the cold cleaner solvent vat shall meet the standards defined in Colorado Regulation 7, Section X.B. Compliance shall be monitored by following the work practices defined in Public Service Company's Policy Manual regarding operation, maintenance and design of the cold cleaner solvent vats. The Policy Manual shall include, at a minimum the requirements defined in Colorado Regulation 7, Section X.B and shall be available to the inspector upon request. Audits of the vat operations and/or the policy manual shall be performed annually to ensure that operations are performed within the requirements of the policy manual and that the policy manual incorporates the requirements of Regulation 7, Section X.B. Audit reports are to be maintained and made available to the Division upon request. 8.2 The transfer and storage of waste and used solvents from the cold cleaner solvent vats are subject to the following requirements (Colorado Regulation No. 7, Section X.A.3 and 4): 8.2.1 In any disposal or transfer of waste or used solvent, at least 80 percent by weight of the solvent/waste liquid shall be retained (i.e., no more than 20 percent of the liquid solvent/solute mixture shall evaporate or otherwise be lost during transfers). 8.2.2 Waste or used solvents shall be stored in closed containers unless otherwise required by law. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT • Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 47 SECTION III - Acid Rain Requirements 1. Designated Representative and Alternate Designated Representative Designated Representative: Alternate Designated Representative: Name: George Hess Name: Quinn Kilty Title: General Manager, Power Title: Manager, Air and Water Quality Generation, CO Phone: (303) 751-7282 Phone: (303) 294-2165 2. Sulfur Dioxide Emission Allowances and Nitrogen Oxide Emission Limitations Combustion Turbine 2012 2013 2014 2015 2016 2017 No. CT-01 SO2 Allowances,per 0* 0* 0* 0* 0* 0* 40 CFR Part 73.10(6), Table 2 NOx Limits This Unit Has No NOx Limits (See Section 5) * Under the provisions of§ 72.84(a)any allowance allocations to,transfers to and deductions from an affected unit's Allowance Tracking System account is considered an automatic permit amendment and as such no revision to the permit is necessary.Numerical allowances shown in this table are from the 1996 edition of the CFR. Combustion Turbine 2012 2013 2014 2015 2016 2017 No. CT-02 SO2 Allowances,per 0* 0* 0* 0* 0* 0* 40 CFR Part 73.10(b), Table 2 NOx Limits This Unit Has No NOx Limits(See Section 5) * Under the provisions of§ 72.84(a)any allowance allocations to,transfers to and deductions from an affected unit's Allowance Tracking System account is considered an automatic permit amendment and as such no revision to the permit is necessary.Numerical allowances shown in this table are from the 1996 edition of the CFR. 3. Standard Requirements Combustion Turbines CT-01 and CT-02 of this facility are subject to and the source has certified that they will comply with the following standard conditions (per Acid Rain Permit application, revised 12/2009). Permit Requirements. (1) The designated representative of each affected source and each affected unit at the source shall: i) Submit a complete Acid Rain permit application (including a compliance plan) under 40 CFR part 72 in accordance with the deadlines specified in 40 CFR 72.30; and ii) Submit in a timely manner any supplemental information that the Division determines is necessary in order to review an Acid Rain permit application and issue or deny an Acid Rain permit; Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit#05OPWE279 Page 48 (2) The owners and operators of each affected source and each affected unit at the source shall: i) Operate the unit in compliance with a complete Acid Rain permit application or a superseding Acid Rain permit issued by the Division; and ii) Have an Acid Rain Permit. Monitoring Requirements. (1) The owners and operators and, to the extent applicable, designated representative of each affected source and each affected unit at the source shall comply with the monitoring requirements as provided in 40 CFR part 75. (2) The emissions measurements recorded and reported in accordance with 40 CFR part 75 shall be used to determine compliance by the source or unit, as appropriate, with the Acid Rain emissions limitations and emissions reduction requirements for sulfur dioxide and nitrogen oxides under the Acid Rain Program. (3) The requirements of 40 CFR part 75 shall not affect the responsibility of the owners and operators to monitor emissions of other pollutants or other emissions characteristics at the unit under other applicable requirements of the Federal Clean Air Act and other provisions of the operating permit for the source. Sulfur Dioxide Requirements. (1) The owners and operators of each source and each affected unit at the source shall: i) Hold allowances, as of the allowance transfer deadline, in the source's compliance account (after deductions under 40 CFR 73.34(c)) not less than the total annual emissions of sulfur dioxide for the previous calendar year from the unit; and ii) Comply with the applicable Acid Rain emissions limitations for sulfur dioxide. (2) Each ton of sulfur dioxide emitted in excess of the Acid Rain emissions limitations for sulfur dioxide shall constitute a separate violation of the Federal Clean Air Act. (3) An affected unit shall be subject to the requirements under paragraph (1) of the sulfur dioxide requirements as follows: i) Starting January 1, 2000, an affected unit under 40 CFR 72.6(a)(2); or ii) Starting on the later of January 1, 2000 or the deadline for monitor certification under 40 CFR part 75, an affected unit under 40 CFR 72.6(a)(3). (4) Allowances shall be held in, deducted from, or transferred among Allowance Tracking System accounts in accordance with the Acid Rain Program. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 49 (5) An allowance shall not be deducted in order to comply with the requirements under paragraph (1) of the sulfur dioxide requirements prior to the calendar year for which the allowance was allocated. (6) An allowance allocated by the Administrator under the Acid Rain Program is a limited authorization to emit sulfur dioxide in accordance with the Acid Rain Program. No provision of the Acid Rain Program, the Acid Rain permit application, the Acid Rain permit, or an exemption under 40 CFR 72.7 or 72.8 and no provision of law shall be construed to limit the authority of the United States to terminate or limit such authorization. (7) An allowance allocated by the Administrator under the Acid Rain Program does not constitute a property right. Nitrogen Oxides Requirements. The owners and operators of the source and each affected unit at the source shall comply with the applicable Acid Rain emissions limitation for nitrogen oxides. Excess Emissions Requirements. (1) The designated representative of an affected source that has excess emissions in any calendar year shall submit a proposed offset plan to the Administrator of the U. S. EPA, as required under 40 CFR part 77. (2) The owners and operators of an affected unit that has excess emissions in any calendar year shall: i) Pay without demand, to the Administrator of the U. S. EPA, the penalty required, and pay upon demand the interest on that penalty, as required by 40 CFR part 77; and ii) Comply with the terms of an approved offset plan, as required by 40 CFR part 77. Recordkeeping and Reporting Requirements. (1) Unless otherwise provided, the owners and operators of the source and each affected unit at the source shall keep on site at the source each of the following documents for a period of 5 years from the date the document is created. This period may be extended for cause, at any time prior to the end of 5 years, in writing by the Administrator or the Division: i) The certificate of representation for the designated representative for the source and each affected unit at the source and all documents that demonstrate the truth of the statements in the certificate of representation, in accordance with 40 CFR 72.24; provided that the certificate and documents shall be retained on site at the source beyond such 5-year period until such documents are superseded because of the submission of a new certificate of representation changing the designated representative; ii) All emissions monitoring information, in accordance with 40 CFR part 75, provided that to the extent that 40 CFR part 75 provides for a 3-year period for recordkeeping, the 3-year period shall apply. iii) Copies of all reports, compliance certifications, and other submissions and all records made or required under the Acid Rain Program; and, Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado • Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 50 iv) Copies of all documents used to complete an Acid Rain permit application and any other submission under the Acid Rain Program or to demonstrate compliance with the requirements of the Acid Rain Program. (2) The designated representative of an affected source and each affected unit at the source shall submit the reports and compliance certifications required under the Acid Rain Program, including those under 40 CFR part 72 subpart I and 40 CFR part 75. Liability. (1) Any person who knowingly violates any requirement or prohibition of the Acid Rain Program, a complete Acid Rain permit application, an Acid Rain permit, or an exemption under 40 CFR 72.7 or 72:8, including any requirement for the payment of any penalty owed to the United States, shall be subject to enforcement pursuant to section 113(c) of the Federal Clean Air Act. (2) Any person who knowingly makes a false, material statement in any record, submission, or report under the Acid Rain Program shall be subject to criminal enforcement pursuant to section 113(c) of the Federal Clean Air Act and 18 U.S.C. 1001. (3) No permit revision shall excuse any violation of the requirements of the Acid Rain Program that occurs prior to the date that the revision takes effect. (4) Each affected source and each affected unit shall meet the requirements of the Acid Rain Program. (5) Any provision of the Acid Rain Program that applies to an affected source (including a provision applicable to the designated representative of an affected source) shall also apply to the owners and operators of such source and of the affected units at the source. (6) Any provision of the Acid Rain Program that applies to an affected unit (including a provision applicable to the designated representative of an affected unit) shall also apply to the owners and operators of such unit. (7) Each violation of a provision of 40 CFR parts 72, 73, 74, 75, 76, 77, and 78 by an affected source or affected unit, or by an owner or operator or designated representative of such source or unit, shall be a separate violation of the Federal Clean Air Act. Effect on Other Authorities. No provision of the Acid Rain Program, an Acid Rain permit application, an Acid Rain permit, or an exemption under 40 CFR 72.7 or 72.8 shall be construed as: (I) Except as expressly provided in title IV of the Federal Clean Air Act, exempting or excluding the owners and operators and, to the extent applicable, the designated representative of an affected source or affected unit from compliance with any other provision of the Federal Clean Air Act, including the provisions of title I of the Federal Clean Air Act relating to applicable National Ambient Air Quality Standards or State Implementation Plans; Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 51 (2) Limiting the number of allowances a unit can hold;provided, that the number of allowances held by the source shall not affect the source's obligation to comply with any other provisions of the Federal Clean Air Act; (3) Requiring a change of any kind in any State law regulating electric utility rates and charges, affecting any State law regarding such State regulation, or limiting such State regulation, including any prudence review requirements under such State law; (4) Modifying the Federal Power Act or affecting the authority of the Federal Energy Regulatory Commission under the Federal Power Act; or, (5) Interfering with or impairing any program for competitive bidding for power supply in a State in which such program is established. 4. Reporting Requirements Pursuant to 40 CFR Part 75.64 quarterly reports and compliance certification requirements shall be submitted to the Administrator within 30 days after the end of the calendar quarter. The contents of these reports shall meet the requirements of 40 CFR 75.64. Revisions to this permit shall be made in accordance with 40 CFR Part 72, Subpart H, §§ 72.80 through 72.85 (as adopted by reference in Colorado Regulation 18). Permit modification requests shall be submitted to the Division at the address identified in Appendix D. Changes to the Designated Representative or Alternate Designated Representative shall be made in accordance with 40 CFR 72.23. 5. Comments,Notes and Justifications Combustion Turbines CT-01 and CT-02 bum natural gas as fuel. The NOx limitations in 40 CFR Part 76 are only applicable to coal-fired utility units and thus do not apply to CT-01 and CT-02. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 52 SECTION IV- Permit Shield Regulation No. 3, 5 CCR 1001-5, Part C, && I.A.4, V.D., &XIII.B and $ 25-7-114.4(3)(a), C.R.S. 1. Specific Non-Applicable Requirements Based on the information available to the Division and supplied by the applicant, the following parameters and requirements have been specifically identified as non-applicable to the facility to which this permit has been issued. This shield does not protect the source from any violations that occurred prior to or at the time of permit issuance. In addition, this shield does not protect the source from any violations that occur as a result of any modifications or reconstruction on which construction commenced prior to permit issuance. The source did not specifically identify and justify any non-applicable requirements to be included in the permit shield. 2. General Conditions Compliance with this Operating Permit shall be deemed compliance with all applicable requirements specifically identified in the permit and other requirements specifically identified in the permit as not applicable to the source. This permit shield shall not alter or affect the following: 2.1 The provisions of §§ 25-7-112 and 25-7-113, C.R.S., or § 303 of the federal act, concerning enforcement in cases of emergency; 2.2 The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance; 2.3 The applicable requirements of the federal Acid Rain Program, consistent with § 408(a) of the federal act; 2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to § 25-7-111(2)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 Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 53 listed permit conditions will also serve as a compliance demonstration for purposes of the associated subsumed requirements. Permit Condition I Streamlined(Subsumed)Requirements Turbines/HRSGs/Duct Burners Section II, Condition Regulation No. 1, Section II.A.1.c [PM emissions shall not exceed 0.1 lb/MMBtu,based on the 1.2.2. average of three(3) I-hr tests] Section II,Condition 40 CFR Part 60 Subpart Da§60.42a(a)(1),as adopted by reference in Colorado Regulation No. 1.2.2 6, Part A [PM emissions shall not exceed 0.03 lb/MMBtu,based on the average of three(3)2-hr tests]] Section II, Condition 40 CFR Part 60 Subpart Da §60.44a(d)(1), as adopted by reference in Colorado Regulation No. 1.5.1.1. 6,Part A[NOx emissions shall not exceed 1.6 lbs/MW-hr] Section II,Condition 40 CFR Part 60, Subpart GG § 60.332(b),as adopted by reference in Colorado Regulation NO. 6, 1.5.1.1 Part A [NOx emissions shall not exceed 102 ppmvd at 15%O2 and ISO standard ambient conditions] Section II, Condition 40 CFR Part 60 Subpart GG §§60.334(h)(3), as adopted by reference in Colorado Regulation No. 1,10 6,Part A [monitor sulfur content of fuel] Section II, Condition Regulation No. 6, Part B, Section II.D.3.b [SO2 emissions not to exceed 0.35 lbs/MMBtu] - 1.4.3 State-only Requirement Section II, Condition Regulation No. 6, Part B, Section 1 [general provisions] -State-only Requirement 1.11 Auxiliary Boiler Section II,Condition 40 CFR Part 60 Subpart Db §60.44b(a)(1),(h)and(i) [NOx emissions not to exceed 0.20 3.3.1 lb/MMBtu, limit applies at all times, including s/s/m and limit is on a 30-day rolling average]. Section II, Condition 40 CFR Part 60 Subpart Db § 60.48b(e)(2) [NOx CEMS span value shall be 500 ppm]. 6.5.1 Section II, Condition 40 CFR Part 60 Subpart Db §§ 60.49b(g), (h),(i), (v)and(w) [NOx records, excess emission 6.4.3 reports,CEMS reports, option to submit electronic reports and frequency for submitting reports]. Section V, 40 CFR Part 60 Subpart Db §60.49b(o) [retain records for 2 yrs] Conditions 22.b&c Section II,Condition Regulation No. 6,Part B, Section I [general provisions] -State-only Requirement 3.7 Section II,Condition Regulation No. 6,Part B, Section 1I.C.2 [particulate matter standard]-State-only Requirement 3.2.1 Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit' Rocky Mountain Energy Center Permit# 05OPWE279 Page 54 SECTION V- General Permit Conditions 11/16/10 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.1. The permittee may immediately make the change upon submission of the application to the Division. 2. Certification Requirements Regulation No. 3, 5 CCR 1001-5,Part C, ¢¢ III.B.9., V.C.16.a.&e. and V.C.17. a. Any application,report, document and compliance certification submitted to the Air Pollution Control Division pursuant to Regulation No. 3 or the Operating Permit shall contain a certification by a responsible official of the truth, accuracy and completeness of such form,report or certification stating that,based on information and belief formed after reasonable inquiry,the statements and information in the document are true,accurate and complete. b. All compliance certifications for terms and conditions in the Operating Permit shall be submitted to the Air Pollution Control Division at least annually unless a more frequent period is specified in the applicable requirement or by the Division in the Operating Permit. c. Compliance certifications shall contain: (i) the identification of each permit term and condition that is the basis of the certification; (ii) the compliance status of the source; (iii) whether compliance was continuous or intermittent; (iv) method(s)used for determining the compliance status of the source, currently and over the reporting period; and (v) such other facts as the Air Pollution Control Division may require to determine the compliance status of the source. d. All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. e. If the permittee is required to develop and register a risk management plan pursuant to § 112(r)of the federal act, the permittee shall certify its compliance with that requirement; the Operating Permit shall not incorporate the contents of the risk management plan as a permit term or condition. 3. Common Provisions Common Provisions Regulation, 5 CCR 1001-2 ¢¢ ILA.,ILB.,ILC.,II,.E., ILF., II.I, and II.I a. To Control Emissions Leaving Colorado When emissions generated from sources in Colorado cross the State boundary line,such emissions shall not cause the air quality standards of the receiving State to be exceeded,provided reciprocal action is taken by the receiving State. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 55 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 circumstances beyond the owner or operator's control,compliance may,upon the Division's approval,be determined using the arithmetic mean of the results of the two other runs. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado • Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 56 Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s)if so warranted. d. Affirmative Defense Provision for Excess Emissions during Malfunctions Note that until such time as the U.S.EPA approves this provision into the Colorado State Implementation Plan (SIP), it shall be enforceable only by the State. An affirmative defense to a claim of violation under these regulations is provided to owners and operators for civil penalty actions for excess emissions during periods of malfunction. To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement,the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of evidence that: (i) The excess emissions were caused by a sudden, unavoidable breakdown of equipment,or a sudden, unavoidable failure of a process to operate in the normal or usual manner,beyond the reasonable control of the owner or operator; (ii) The excess emissions did not stem from any activity or event that could have reasonably been foreseen and avoided,or planned for,and could not have been avoided by better operation and maintenance practices; (iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being exceeded; (iv) The amount and duration of the excess emissions(including any bypass)were minimized to the maximum extent practicable during periods of such emissions; (v) All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation(if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed,contemporaneous operating logs or other relevant evidence; (viii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation, or maintenance; (ix) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions. This section is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator,and shall not constitute an additional applicable requirement; and (x) During the period of excess emissions,there were no exceedances of the relevant ambient air quality standards established in the Commissions' Regulations that could be attributed to the emitting source. The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division verbally as soon as possible, but no later than noon of the Division's next working day, and shall submit written notification following the initial occurrence of the excess emissions by the end of the source's next reporting period. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief The Affirmative Defense Provision does not apply to failures to meet federally promulgated performance standards or emission limits, including, but not limited to,new source performance standards and national emission standards for hazardous air pollutants.The affirmative defense provision does not apply to state implementation plan(sip) limits or permit limits that have been set taking into account potential emissions during malfunctions, including,but not necessarily limited to, certain limits with 30-day or longer averaging times, limits that indicate they apply during malfunctions, and limits that indicate they apply at all times or without exception. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 57 e. Circumvention Clause A person shall not build, erect,install,or use any article,machine, equipment,condition, or any contrivance,the use of which,without resulting in a reduction in the total release of air pollutants to the atmosphere,reduces or conceals an emission which would otherwise constitute a violation of this regulation.No person shall circumvent this regulation by using more openings than is considered normal practice by the industry or activity in question. 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. S. 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 subparagraph is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator, and shall not constitute an additional applicable requirement. The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the Division verbally as soon as possible,but no later than two(2)hours after the start of the next working day, and shall submit written quarterly notification following the initial occurrence of the excess emissions. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 58 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, 66 III.C.9.,V.C.11. & 16.d., 6 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 may be modified, revoked,reopened, and reissued,or terminated for cause. The filing of any request by the permittee for a permit modification,revocation and reissuance, or termination, or any notification of planned changes or anticipated noncompliance does not stay any permit condition,except as provided in §§X. and XI. of Regulation No. 3,Part C. d. The permittee shall furnish to the Air Pollution Control Division,within a reasonable time as specified by the Division,any information that the Division may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit or to determine compliance with the permit. Upon request,the permittee shall also furnish to the Division copies of records required to be kept by the permittee, including information claimed to be confidential. Any information subject to a claim of confidentiality shall be specifically identified and submitted separately from information not subject to the claim. e. Any schedule for compliance for applicable requirements with which the source is not in compliance at the time of permit issuance shall be supplemental, and shall not sanction noncompliance with,the applicable requirements on which it is based. f. For any compliance schedule for applicable requirements with which the source is not in compliance at the time of permit issuance, the permittee shall submit,at least every 6 months unless a more frequent period is specified in the applicable requirement or by the Air Pollution Control Division,progress reports which contain the following: (i) dates for achieving the activities,milestones,or compliance required in the schedule for compliance, and dates when such activities,milestones, or compliance were achieved; and (ii) an explanation of why any dates in the schedule of compliance were not or will not be met, and any preventive or corrective measures adopted. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 59 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 permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards,or other requirements in the permit;and d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the next working day following the emergency, and followed by written notice within one month of the time when emissions limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement. 6. Emission Controls for Asbestos Regulation No. 8, 5 CCR 1001-10, Part B The permittee shall not conduct any asbestos abatement activities except in accordance with the provisions of Regulation No. 8, Part B,"asbestos control." 7. Emissions Trading,Marketable Permits,Economic Incentives Regulation No. 3, 5 CCR 1001-5, Part C, 6 V.C.13. No permit revision shall be required under any approved economic incentives, marketable permits, emissions trading and other similar programs or processes for changes that are specifically provided for in the permit. 8. Fee Payment C.R.S. 66 25-7-114.1(6)and 25-7-114.7 a. The permittee shall pay an annual emissions fee in accordance with the provisions of§ 25-7-114.7. A 1%per month late payment fee shall be assessed against any invoice amounts not paid in full on the 91st day after the date of invoice,unless a permittee has filed a timely protest to the invoice amount. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 60 b. The permittee shall pay a permit processing fee in accordance with the provisions of§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§25-7-114.1(6)for each APEN or revised APEN filed. 9. Fugitive Particulate Emissions Regulation No. 1, 5 CCR 1001-3, § III.D.1. The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate emissions into the atmosphere, in accordance with the provisions of Regulation No. 1, § III.D.1. 10. Inspection and Entry Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.16.b. Upon presentation of credentials and other documents as may be required by law, the permittee shall allow the Air Pollution Control Division,or any authorized representative,to perform the following: a. enter upon the permittee's premises where an Operating Permit source is located,or emissions-related activity is conducted,or where records must be kept under the terms of 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. 11. Minor Permit Modifications Regulation No. 3, 5 CCR 1001-5,Part C, §§ X. &XI. The permittee shall submit an application for a minor permit modification before making the change requested in the application. The permit shield shall not extend to minor permit modifications. 12. New Source Review Regulation No. 3, 5 CCR 1001-5,Part B The permittee shall not commence construction or modification of a source required to be reviewed under the New Source Review provisions of Regulation No. 3,Part B,without first receiving a construction permit. 13. No Property Rights Conveyed Regulation No. 3, 5 CCR 1001-5, Part C, §V.C.I I.d. This permit does not convey any property rights of any sort, or any exclusive privilege. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 61 14. Odor Regulation No.2, 5 CCR 1001-4,Part A As a matter of state law only, the permittee shall comply with the provisions of Regulation No. 2 concerning odorous emissions. 15. Off-Permit Changes to the Source Regulation No. 3, 5 CCR 1001-5, Part C, ¢ XII.B. The permittee shall record any off-permit change to the source that causes the emissions of a regulated pollutant subject to an applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from the change, including any other data necessary to show compliance with applicable ambient air quality standards. The permittee shall provide contemporaneous notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permit shield shall not apply to any off-permit change. 16. Opacity Regulation No. 1, 5 CCR 1001-3, ¢¢ 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-I1 The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions of Regulation No. 9. 18. Ozone Depleting Compounds Regulation No. 15, 5 CCR 1001-17 The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds. Sections I.,II.C., II.D., III. IV., and V. of Regulation No. 15 shall be enforced as a matter of state law only. 19. Permit Expiration and Renewal Regulation No.3, 5 CCR 1001-5, Part C, ¢¢ 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: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 62 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, 5 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 sped 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 permittee shall maintain compliance monitoring records that include the following information: (i) date,place as defined in the Operating Permit, and time of sampling or measurements; (ii) date(s)on which analyses were performed; Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT ' Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 63 (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. Permittees submitting revised APENs to inform the Division of a change in actual emission rates must do so by April 30 of the following year. Where a permit revision is required,the revised APEN must be filed along with a request for permit revision. APENs for changes in control equipment must be submitted before the change occurs. Annual fees are based on the most recent APEN on file with the Division. 23. Reopenings for Cause Regulation No. 3, 5 CCR 1001-5, Part C, §XIII. a. The Air Pollution Control Division shall reopen,revise, and reissue Operating Permits;permit reopenings and reissuance shall be processed using the procedures set forth in Regulation No. 3,Part C, § III., except that proceedings to reopen and reissue permits affect only those parts of the permit for which cause to reopen exists. 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: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit# 05OPWE279 Page 64 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, § 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.1.b. & 8 a. Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations promulgated under Title IV of the federal act,40 Code of Federal Regulations(CFR) Part 72, both provisions shall be incorporated into the permit and shall be federally enforceable. b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal act or the regulations promulgated thereunder,40 CFR Part 72, are expressly prohibited. 28. Transfer or Assignment of Ownership Regulation No. 3,5 CCR 1001-5,Part C, ¢II.C. No transfer or assignment of ownership of the Operating Permit source will be effective unless the prospective owner or operator applies to the Air Pollution Control Division on Division-supplied Administrative Permit Amendment forms, for reissuance of the existing Operating Permit. No administrative permit shall be complete until a written agreement containing a specific date for transfer of permit, responsibility, coverage, and liability between the permittee and the prospective owner or operator has been submitted to the Division. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Rocky Mountain Energy Center Permit ft 05OPWE279 Page 65 29. Volatile Organic Compounds Regulation No. 7, 5 CCR 1001-9, §§III&V. The requirements in paragraphs a, b and e apply to sources located in an ozone non-attainment area or the Denver 1-hour ozone attainment/maintenance area. The requirements in paragraphs c and d apply statewide. a. All storage tank gauging devices, anti-rotation devices, accesses, seals,hatches,roof drainage systems,support structures, and pressure relief valves shall be maintained and operated to prevent detectable vapor loss except when opened,actuated,or used for necessary and proper activities(e.g. maintenance). Such opening,actuation,or use shall be limited so as to minimize vapor loss. Detectable vapor loss 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 permittee shall comply with the provisions of Regulation No. 4 concerning the advertisement, sale, installation, and use of wood stoves and wood burning appliances. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 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: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT • Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 1 APPENDIX A - Inspection Information Directions to Plant The facility is located at 6211 Weld County Road 51 (between Hudson and Keenesburg, east of I-76, accessible from the Kersey Rd exit). Safety Equipment Required Eye Protection, Hard Hat, Safety Shoes and Hearing Protection Facility Plot Plan Figure 1 (following page) shows the plot plan as submitted on March 14, 2005 with the source's Title V 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.. Insignificant activities and/or sources of emissions as identified in the Title V permit application: Units with emissions less than APEN de minims—non-criteria reportable pollutants (Reg 3, Part C.II.E.3.b) Two (2) 14,200 gal anhydrous ammonia storage tanks Fuel (gaseous) burning equipment < 5 MMBtu/hr (Reg 3, Part C.II.E.3.k) Water bath fuel heater Landscaping and site housekeeping devices < 10 hp (Reg 3, Part C.II.E.3.bb) Garden tractor Fuel storage and dispensing equipment in ozone attainment areas throughput <400 gal/day averaged over 30 days (Reg 3 Part C.II.E.3.ccc) 100 gallon portable diesel fuel tank mounted in the back of a facility vehicle Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division • Colorado Operating Permit Appendix A Inspection Information Page 2 Storage tanks with annual throughput less than 400,000 gal and meeting content specifications (Reg 3, Part C.II.E.3.fff) 500 gallon above ground diesel fuel tank 8,400 gallon gas condensate tank Forklifts (Reg 3, Part C.II.E.3.kkk) Forklift Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT • Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 3 1 N N a) r.- r N o o. II II I Cif Z e - -^�—�'4 I irx r., e3,-Kr 12. gi I 4 '"' l'Ole-4)67'' - — . 6. _____ , , 4 ;al " .:,,s. ,:„ ,...:. 01 0 to _ !!y 11 • ' k ' 'p3 L --1.p:- t.h 1 1 1I 1 R • p �I Qgrt .a• 1. C I ____ ---j\ ,00.00 L Z „C0,9Z.00 N _------ ___-- .------ Figure 1: Facility Plot Plan Rocky Mountain Energy Center Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division • Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report 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 requirements, including those attributable to malfunctions as defined in this Appendix, the probable cause of Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 2 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: (1) A situation where emissions exceed an emission limitation or standard contained in the permit; (2) A situation where process or control device parameter values demonstrate that an emission limitation or standard contained in the permit has not been met; • (3) A situation in which observations or data collected demonstrates noncompliance with an emission limitation or standard or any work practice or operating condition required by the permit; or, (4) A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule)has occurred. (only if the emission point is subject to CAM) For reporting purposes, the Division has combined the Monitoring Deviation Report with the Permit Deviation Report. All deviations shall be reported using the following codes: 1 = Standard: 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 40CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. 9=Other: When the deviation is not covered by any of the above categories Report#3: Compliance Certification (annually, as defined in the permit) Submission of compliance certifications with terms and conditions in the permit, including emission limitations, standards, or work practices, is required not less than annually. Compliance Certifications are intended to state the compliance status of each requirement of the permit over the certification period. They must be based, at a minimum, on the testing and monitoring methods specified in the Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division • Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 3 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.1 • 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 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 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: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 4 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: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division • Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 5 Monitoring and Permit Deviation 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 - Rocky Mountain Energy Center OPERATING PERMIT NO: 05OPWE279 • REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) Deviations Noted Deviation Malfunction/ During Period?' Code2 Emergency Operating Condition Reported Permit Unit During Period? ID Unit Description YES NO YES NO CT-0l One(1)Westinghouse, Model No. 501FD, Natural Gas-Fired Combustion Turbine, Serial No.37A8191. The Turbine is Rated at 1785 MMBtu/hr(HHV at ISO conditions). The turbine is operated in combined cycle mode only and the heat recovery steam generator(HRSG)is equipped with a duct burner rated at 675 MMBtu/hr. The turbine drives a generator capable of generating 152 MW of power and the HRSG drives a steam generator rated at 326 MW (at peak capacity). CT-02 One(1)Westinghouse, Model No. 501FD, Natural Gas-Fired Combustion Turbine, Serial No. 37A8196. The Turbine is Rated at 1785 MMBtu/hr(HHV at ISO conditions). The turbine is operated in combined cycle mode only and the heat recovery steam generator(HRSG)is equipped with a duct burner rated at 675 MMBtu/hr. The turbine drives a generator capable of generating 152 MW of power and the HRSG drives a steam generator rated at 326 MW (at peak capacity). S005 Caterpillar, Model No. 3512B,Internal Combustion Engine Driving an Emergency Generator, Serial No. IGZ01360. The Engine is Diesel Fuel-Fired and rated at 1810 hp and 12.2 MMBtu/hr. Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 6 Deviations Noted Deviation Malfunction/ During Period?' Code2 Emergency Operating • CCondition Reported During Period? Permit Unit ID Unit Description YES NO tt YES NO S004 Rentech,Natural Gas Fired Boiler,Rated at 129 MMBtu/hr, Serial No.2002-49. S006 Marley,Model No. F4910, 12 Cell Cooling Water Tower,Rated at 176,000 gal/min. M001 Gasoline Storage Tank, 500 gallons, aboveground M002 Cold Cleaner Solvent Vat M003 John Deere, Model No.608IAF00l, Serial No. RG608IA159985,Diesel Fired Internal Combustion Engine Driving an Emergency Fire Pump Engine,Rated at 182 hp and 1.26 MMBtu/hr. General Conditions Insignificant Activities 1 See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation has occurred shall be based on a reasonable inquiry using readily available information. 2 Use the following entries,as appropriate: 1 =Standard: 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 40CFR 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: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 7 Monitoring and Permit Deviation Report- Part II FACILITY NAME: Public Service Company of Colorado - Rocky Mountain Energy Center OPERATING PERMIT NO: 05OPWE279 REPORTING PERIOD: Is the deviation being claimed as an: Emergency Malfunction N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction 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 Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 8 EXAMPLE FACILITY NAME: Acme Corp. OPERATING PERMIT NO: 96OPZZXXX REPORTING PERIOD: 1/1/04 - 6/30/06 Is the deviation being claimed as an: 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: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 9 Monitoring and Permit Deviation Report- Part III REPORT CERTIFICATION SOURCE NAME: Public Service Company of Colorado - Rocky Mountain Energy Center FACILITY IDENTIFICATION NUMBER: 1231342 • PERMIT NUMBER: 05OPWE279 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: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT ' Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 1 APPENDIX C Required Format for Annual Compliance Certification Report with codes 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 - Rocky Mountain Energy Center OPERATING PERMIT NO: 05OPWE279 REPORTING PERIOD: L 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 rUnit Description Deviations Monitoring Was Compliance Permit Reported I Method per Continuous or Unit ID Permit?Z Intermittent?3 Previous Current YES NO Continuous Intermittent CT-01 One(1)Westinghouse, Model No. 501FD, Natural Gas-Fired Combustion Turbine, Serial No. 37A8191. The Turbine is Rated at 1785 MMBtu/hr(HHV at ISO conditions). The turbine is operated in combined cycle mode only and the heat recovery steam generator(HRSG)is equipped with a duct burner rated at 675 MMBtu/hr. The turbine drives a generator capable of generating 152 MW of power and the HRSG drives a steam generator rated at 326 MW(at peak capacity). Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division • Colorado Operating Permit Appendix C Compliance Certification Report Page 2 Operating Unit Description Deviations Monitoring Was Compliance Permit Reported I Method per Continuous or Unit ID Permit?2 Intermittent?3 Previous Current YES NO Continuous Intermittent CT-02 One(I) Westinghouse, Model No. 501FD, Natural Gas-Fired Combustion Turbine, Serial No. 37A8196. The Turbine is Rated at 1785 MMBtu/hr(HHV at ISO conditions). The turbine is operated in combined cycle mode only and the heat recovery steam generator(HRSG) is equipped with a duct burner rated at 675 MMBtu/hr. The turbine drives a generator capable of generating 152 MW of power and the HRSG drives a steam generator rated at 326 MW(at peak capacity). S005 Caterpillar,Model No. 3512B, Internal Combustion Engine Driving an Emergency Generator, Serial No. 1 GZ01360. The Engine is Diesel Fuel-Fired and rated at 1810 hp and 12.2 MMBtu/hr. S004 Rentech,Natural Gas Fired Boiler, Rated at 129 MMBtu/hr, Serial No.2002-49. S006 Marley,Model No. F4910, 12 Cell Cooling Water Tower,Rated at 176,000 gal/min. M001 Gasoline Storage Tank, 500 gallons, aboveground M002 Cold Cleaner Solvent Vat M003 John Deere,Model No. 608IAF001, Serial No. RG6081A159985,Diesel Fired Internal Combustion Engine Driving an Emergency Fire Pump Engine,Rated at 182 hp and 1.26 MMBtu/hr. General Conditions Insignificant Activities 4 If deviations were noted in a previous deviation report , put an "X" under "previous". If deviations were noted in the current deviation report(i.e. for the last six months of the annual reporting period), put an "X" under"current". Mark both columns if both apply. 2 Note whether the method(s)used to determine the compliance status with each term and condition was the method(s)specified in the permit. If it was not, mark "no"and attach additional information/explanation. 3 Note whether the compliance status with 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 Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 3 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: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 4 II. Status for Accidental Release Prevention Program: A. This facility is subject is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act) B. If subject: The facility is is not in compliance with all the requirements of section 112(r). 1. A Risk Management Plan will be has been submitted to the appropriate authority and/or the designated central location by the required date. III. Certification All information for the Annual Compliance Certification must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B.38. This signed certification document must be packaged with the documents being submitted. 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: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT ' Air Pollution Control Division Colorado Operating Permit Appendix D Notification Addresses Page 1 APPENDIX D Notification Addresses 1. Air Pollution Control Division Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit APCD-SS-B 1 4300 Cherry Creek Drive S. Denver, CO 80246-1530 ATTN: 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: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix E Permit Acronyms 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 EF - Emission Factor EPA - Environmental Protection Agency FI - Fuel Input Rate in MMBtu/hr FR- Federal Register G - Grams Gal - Gallon GPM - Gallons per Minute HAPs - Hazardous Air Pollutants HP- • Horsepower HP-HR - Horsepower Hour (G/HP-HR= Grams per Horsepower Hour) LAER - Lowest Achievable Emission Rate LBS - Pounds M - Thousand MM - Million MMscf- Million Standard Cubic Feet MMscfd - Million Standard Cubic Feet per Day N - Normal Operation, as referenced in permit limitation table in Section II.1 N/A or NA - Not Applicable NOx - Nitrogen Oxides NESHAP - National Emission Standards for Hazardous Air Pollutants NSPS - New Source Performance Standards P - Process Weight Rate in Tons/Hr PE - Particulate Emissions PM- Particulate Matter • Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix E Permit Acronyms Page 2 PM10 - Particulate Matter Under 10 Microns PPM - Parts Per Million PPMV - Parts Per Million, by Volume PPMVD - Parts per Million, by Volume, Dry PSD - Prevention of Significant Deterioration PTE - Potential To Emit RACT - Reasonably Available Control Technology SCC - Source Classification Code SCF - Standard Cubic Feet SD - Shutdown, as referenced in permit limitation table in Section II.1 SIC - Standard Industrial Classification SO2 - Sulfur Dioxide SU - Start-Up, as referenced in permit limitation table in Section II.1 TPY - Tons Per Year TSP - Total Suspended Particulate VOC - Volatile Organic Compounds Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix F Permit Modifications Page 1 APPENDIX F Permit Modifications DATE OF MODIFICATION SECTION NUMBER, DESCRIPTION OF REVISION REVISION TYPE CONDITION NUMBER Operating Permit Number: 05OPWE279 First Issued: 7/1/07 Renewed: DRAFT • STATE OF COLORADO John W.Hickenlooper,Governor e'co Christopher E.Urbina,MD,MPH �ti R o t o� Executive Director and Chief Medical Officer /F3� Dedicated to protecting and improving the health and environment of the people of Colorado 01 4300 Cherry Creek Dr.S. Laboratory Services Division r rave+; Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health http://www.cdphe.state.co.us and Environment February 13, 2012 Mr. Chad Campbell Environmental Services Xcel Energy 1800 Larimer Street Suite 1300 Denver, CO 80202 REF: Public Service Company of Colorado—Rocky Mountain Energy Center, FID # 1231342 OP # 05OPWE279 SUBJECT: Response to Comments on Draft Operating Permit Dear Mr. Campbell: The comments you provided on the draft revised Operating Permit (05OPWE279) and Technical Review Document for your facility were received via e-mail on February 2, 2012, with a hard copy received on February 6, 2012. The Division has reviewed and addressed your comments as follows: Draft Permit Issuance Cover Letter Comment: In the draft permit issuance cover letter, the Division requested that PSCo indicate whether any paint stripping chemicals used at the Rocky Mountain Energy Center (RMEC)facility include methylene chloride. PSCo's response to that inquiry is that methylene chloride is not used as a chemical in paint stripping activities at RMEC. Response: Thank you for providing this information. No changes to the permit or technical review document are necessary. Section II— Specific Permit Terms Comment Condition 1 (Page 4)In the summary of limitations table for Units S001 and 5002, there is a typographical error in the PM and PM10 compliance emission factors listed for CT- 01. The co`rrect compliance emission factor for this unit for both the PM and PM10 parameters are 0.0036 lb/MMBtu. The value is correctly written on page 9 in the Technical Review Document. Mr. Chad Campbell, Xcel Energy February 13, 2012 Response to Comments on Draft Permit Page 2 Response: The change has been made as requested. Comment: Conditions 1.5.1 and 1.6.1 (Pages 10 and 11) Conditions 1.5.1 and 1.6.1 summarize the NOx and CO emission limitation requirements. PSCo requests that a condition be added under these requirements to address the required operation of the units for the purpose of performing routine combustion tuning, testing and maintenance. A "Combustion Tuning and Testing"provision is included in several other operating permits for sources similar to these for the purpose of allowing the sources to conduct combustion tuning, testing and maintenance activities required for proper operation of the turbines. PSCo proposes that the use of the provision be limited to 60 hours in any calendar year for both turbines combined Response: The Division has added alternative BACT limits for NOx and CO limits for periods of combustion tuning and testing. The alternative BACT limits were set at the level for the startup and shutdown BACT limits, based on an hourly average and a limitation on the use of these alternative limits was set at 60 hours per calendar year for both turbines combined. Comment: Conditions 1.5.1.4 (Page 10) Condition 1.5.1.4 defines the term "Shutdown"for the purposes of this permit. PSCo requests that the last sentence be revised as follows so that it more accurately describes the process. "The cessation of operation for these turbines begins when the command signal is initiated by the turbine operator to shutdown the unit and ends when fuel is no longer being fired in the turbine. " Response: The change has been made as requested. Comment: Condition 1.5.2 (Page 11) Condition 1.5.2 addresses the method for determining lb/hr NOx emissions for the purpose of showing compliance with mass emissions limits. PSCo does not believe that the section as currently written is incorrect. However, PSCo would like to identify some clarifying points in how the total amount of NOx emissions in tons is calculated Under the Part 75 program NOx emissions are not logged in lb/hr, but rather in ppm and lb/mmbtu. The Acid Rain Program does quantify NOx mass emissions in annual summaries but that is done using the hourly NOx lb/mmbtu, heat input and hours of operation values. Part 75 requires NOx lb/mmbtu to be determined on an hourly basis using the hourly values for NOx ppm, a fuel specific F-factor, and CO2 or O2 diluent. Data substitution and application of a bias adjustment factor (BAF) are done at the hourly average level on the NOx lb/mmbtu channel. The application of a BAF is not done on a NOx lb/hr channel. As such, PSCo's DAHS systems have been setup with a NOx lb/hr minute channel that is calculated from the minute NOx lb/mmbtu and heat input channel values. This channel is used by plant operations for informational purposes ' and can be RATA tested, but the official NOx tonnage comes from summing the hourly NOx lb/hr channel that was built using the hourly NOx lb/mmbtu and heat input channels. In order to properly apply all bias adjustment factors and data substitution routines and be consistent with Part 75 requirements this is the method that must be followed I Mr. Chad Campbell, Xcel Energy February 13, 2012 Response to Comments on Draft Permit Page 3 Again, PSCo does not believe that the section as currently written is incorrect. However, if the Division wishes to identify steps in the process for determining the total NOx mass emission in tons,perhaps the following information could be considered for inclusion into the permit condition. NOx Tons will be determined by taking the hourly Part 75 NOx lb/mmbtu value (which includes substituted and bias adjusted data) and multiplying it by the hourly Part 75 Heat Input value (which accounts for substituted data where appropriate from the fuel flow measurement). The resulting NOx lb/hr value is then multiplied by the unit operating time for the hour to produce a NOx lbs value. These values are summed and then divided by 2000 for total NOx tons on a rolling 12 month basis. The NOx lb/mmbtu value is calculated using equation F-5 in Part 75 and the Heat Input value is calculated using equation F-20 from Part 75. This method is consistent with EPA's Acid Rain Program Response: The changes have been made as requested. Comment: Condition 1.6.2 (Page 12) Condition 1.6.2 addresses the method for determining CO lb/hr emissions for the purpose of showing compliance with mass emissions limits. PSCo would like to identify some clarifying points in how the total amount of CO emissions in tons is calculated. CO emissions and CO CEMS are not subject to the requirements of Part 75 and as such the CO mass emission determination is based on the procedures contained in Part 75 for NOx in order to be able to be able to perform data substitution during periods in which the CO CEMS is unavailable. Under Part 75 the NOx mass emissions are determined using the hourly NOx lb/mmbtu, heat input and hours of operation values. Part 75 requires NOx lb/mmbtu to be determined on an hourly basis using the hourly values for NOx ppm, a fuel specific F-factor, and CO2 or O2 diluent. Data substitution and application of a bias adjustment factor (BAF) are done at the hourly average level on the NOx lb/mmbtu channel. The method for determining CO mass emissions follows the same protocols as described here except for the application of a BAF. The standards for CO are established in 40 CFR Part 60 and as such the regulations and EPA test method(Method 10) used to certify the accuracy of the CO CEMdo not require the determination of an analyzer bias adjustment factor. In addition, the purpose of the BAF implemented under the Part 75 rules is to ensure that pollutants with a monetary trading value on the open market (NOX tons and SO2 tons) are treated equally regardless of where the emissions are generated within the country. Because CO tons are not a traded commodity, PSCo does not believe that applying a BAF to this pollutant is appropriate PSCo believes that applying the missing data procedure is sufficient to ensure that the CO tons are accurately reported and that all periods of operation are accounted for. The DAHS system has been programmed with a CO lb/hr minute channel that is calculated from the minute CO lb/mmbtu and heat input channel values. This channel is used by plant operations for informational purposes and can be RATA tested, but the official CO tonnage comes from summing the hourly CO lb/hr channel that was built using the hourly CO lb/mmbtu and heat input channels. In order to properly apply data • Mr. Chad Campbell, Xcel Energy February 13, 2012 Response to Comments on Draft Permit Page 4 substitution routines and be consistent with Part 75 requirements this is the method that must be followed. If the Division wishes to identify steps in the process for determining the total CO mass emission in tons,perhaps the following information could be considered for inclusion into the permit condition. CO Tons will be determined by taking the hourly CO lb/mmbtu value (which includes substituted data using Part 75 rules) and multiplying it by the hourly Part 75 Heat Input value (which accounts for substituted data where appropriate from the stack flow measurements). The resulting CO lb/hr value is then multiplied by the unit operating time for the hour to produce a CO lbs value. These values are summed and then divided by 2000 for total CO tons on a rolling 12 month basis. The CO lb/mmbtu value is calculated using equation F-5 in Part 75 for NOx lb/mmbtu since CO lb/mmbtu is not a parameter reported under the Acid Rain Program. The Heat Input value is calculated using equation F-20 from Part 75. Response: The changes have been made as requested. Comment: Conditions 1.52 1.62 and 3.3.2 (Pages 11, 12 and 31) There is an error in the paragraphs under Conditions 1.5.2, 1.6.2, and 3.3.2. There is a sentence that refers to programming the DAHS to calculate lb/hr emissions in accordance with the requirements in Condition 8.1.7.2. There does not appear to be a Condition 8.1.7.2 in the permit. Response: The references to "Condition 8.1.7.2" in Conditions 1.5.2, 1.6.2 and 3.3.2 have been changed to "Condition 6.1.1.4.b". Comment: Conditions 1.5.1.5 and 1.61.5 (Pages 10 and 12) Conditions 1.5.1.5 and 1.6.1.5 have a discussion on the method for creating valid hourly averages. PSCo requests that this condition specify that Part 75 hour validation criteria will be used in the calculation of hourly NOx and CO concentration averages. Part 75 uses the most conservative validation criteria and is inline with the validation requirements in Part 60, section 60.13. Response: The Division added language to Conditions 1.5.1.5 and 1.6.1.5 to indicate that hourly averages are calculated in accordance with 40 CFR Part 75. In addition, the Division also revised the language in Conditions 1.5.1.6 and 1.6.1.6 regarding the calculation of partial hours to specify that partial hours shall be calculated in accordance with the requirements in 40 CFR Part 75. Note that Conditions 1.5.1.5, 1.6.1.5, 1.5.1.6 and 1.6.1.6 were renumbered due to the addition of conditions that were added to address combustion tuning and testing. Comment: Condition 3.3.1 (Page 31) There is a typographical error in the third sentence in Condition 3.3.1. Mr. Chad Campbell,Xcel Energy February 13, 2012 Response to Comments on Draft Permit Page 5 "Specifically hourly mass CO[replace with "NOx emissions (in lb/hr) shall be calculated by multiplying the hourly NOx lb/MMBtu value by the hourly heat input value (MMBtu/hr). " Response: The change has been made as requested. Comment: Condition 3.4.1.2 (Page 31) Condition 3.4.1.2 addresses the requirement to conduct routine performance testing on the auxiliary boiler. PSCo requests that the deadline for testing the boiler be based on sixty (60) boiler operating days, where a boiler operating day is defined as any calendar day in which fuel is combusted for any period of time, rather than sixty (60) calendar days. Setting the deadline for testing in this manner will eliminate concerns of meeting a calendar day deadline under a scenario in which the boiler becomes inoperable and repairs extend testing past the deadline. Response: The change has been made as requested. Comment: Condition 3.5 (Page 32) There is a typographical error in the second sentence in Condition 3.5. "Natural gas consumed in each[replace with "the'J boiler shall be recorded daily, as required by 40 CFR Part 60 Db, 60.49(d), as adopted by reference in Colorado Regulation No. 6, Part A. Response: The change has been made as requested. Comment: Condition 6.1.1.2 (Page 38) Condition 6.1.1.2 states that the relative accuracy test audit (RATA)frequency for the CO CEMS will be determined according to 40 CFR Part 75 Appendix B. The CO CEM is subject to 40 CFR Part 60 Appendix F and as such the pass/fail criteria that is applied to the CO CEMS is from 40 CFR Part 60 Appendix F. Therefore the RATA frequency must also be based on Part 60 Appendix F. The pass/fail criteria and testingfrequency requirements established in Part 75 are different than those established in Part 60. Condition 6.1.1.2 should be revised to state that the RATA frequency for the CO CEMS will be determined according to 40 CFR Part 60 Appendix F, as it is not appropriate to apply a Part 75 RATA frequency. Response: The change has been made as requested. Comment: Condition 6.1.2.2 (Page 39) Condition 6.1.2.2 states that the quality assurance/quality control plan for the CO monitors on the turbines/HRSG/duct burners shall be prepared in accordance with the applicable requirements in Part 60, Appendix F. PSCo requests the ability to utilize the quality assurance/quality control plan required under Part 75 Appendix B as the requirements for the plan go above and beyond the requirements of the plan under Part 60. Mr. Chad Campbell, Xcel Energy February 13, 2012 Response to Comments on Draft Permit Page 6 Response: The change has been made as requested. In addition, the Division removed the phrase that addressed cylinder gas audits (CGA) since this is addressed in 40 CFR Part 75, Appendix B. Comment: Condition 6.3 (Page 41) Condition 6.3 addresses the data replacement requirements in the determination of total annual emissions. The last sentence of the condition states that bias-adjusted data shall be included when assessing compliance with the annual limitations, For the same reasons that PSCo has identified in the comment submitted for Condition 1.6Z this sentence should be revised to exclude CO from requiring the application of a bias adjustment factor. Response: The Division has added language to the permit to indicate that CO data is not bias- adjusted. Appendix A—Inspection Information Comment: List of Insignificant Activities (Page 1) Under "Fuel storage and dispensing equipment in ozone attainment areas throughput < 400 gal/day averaged over 30 days (Reg 3 Part C.11.E.3.ccc)" the source listed as a "100 gallon portable gasoline fuel tank mounted in the back of a facility vehicle" should be revised to reflect that it is a portable diesel fuel tank. Response: The change was made as requested. The next step for this draft renewal permit will be to put it out for a 30-day Public Comment period. After that, the proposed permit will go to EPA Region VIII for a 45-day review period. The regulations also require that the applicant receive written notice of their right to a formal hearing before the Air Quality Control Commission at the same time that the Public Comment packet goes out. You will receive a separate letter containing that information. We appreciate that you took the time to thoroughly review this draft. Please feel free to call me at(303) 692-3267 if you have any further questions. Sincerely, Jacqueline Joyce Operating Permit Unit Stationary Sources Program Air Pollution Control Division Xcel Energy- ( _E --62012 Environmental Services Department 1800 Larimer Street,Suite 1300 Denver,CO 80202 February 2,2012 Ms.Jacqueline Joyce Operating Permit Unit Air Pollution Control Division,APCD-SS-B 1 Colorado Department of Public Health&Environment 4300 Cherry Creek Drive South Denver,CO 80246-1530 Re: Rocky Mountain Energy Center Permit#05OPWE279 Draft Operating Permit Comments Dear Ms.Joyce: Public Service Company of Colorado(PSCo)has reviewed the initial draft renewal operating permit, #05OPWE279,for Rocky Mountain Energy Center located in Weld County,Colorado. The draft permit was issued for our review and comment on December 16,2011. The following are PSCo's comments on the draft permit. Draft Permit Issuance Cover Letter In the draft permit issuance cover letter,the Division requested that PSCo indicate whether any paint stripping chemicals used at the Rocky Mountain Energy Center(RMEC)facility include methylene chloride. PSCo's response to that inquiry is that methylene chloride is not used as a chemical in paint stripping activities at RMEC. Section II—Specific Permit Terms Condition 1 (Page 4) In the summary of limitations table for Units S001 and 5002,there is a typographical error in the PM and PM10 compliance emission factors listed for CT-01. The correct compliance emission factor for this unit for both the PM and PM10 parameters are 0.0036 lb/MMBtu. The value is correctly written on page 9 in the Technical Review Document. Conditions 1.5.1 and 1.6.1 (Pages 10 and 11) Conditions 1.5.1 and 1.6.1 summarize the NOx and CO emission limitation requirements. PSCo requests that a condition be added under these requirements to address the required operation of the units for the purpose of performing routine combustion tuning,testing and maintenance. A"Combustion Tuning and Testing"provision is included in several other operating permits for sources similar to these for the purpose of allowing the sources to conduct combustion tuning,testing and maintenance activities required for proper operation of the turbines. PSCo proposes that the use of the provision be limited to 60 hours in any calendar year for both turbines combined. Conditions 1.5.1.4 (Page 10) Condition 1.5.1.4 defines the term"Shutdown"for the purposes of this permit. PSCo requests that the last sentence be revised as follows so that it more accurately describes the process. "The cessation of operation for these turbines begins when the command signal is initiated by the turbine operator to shutdown the unit and ends when fuel is no longer being fired in the turbine." Condition 1.5.2(Page 11) Condition 1.5.2 addresses the method for determining lb/hr NOx emissions for the purpose of showing compliance with mass emissions limits. PSCo does not believe that the section as currently written is incorrect. However,PSCo would like to identify some clarifying points in how the total amount of NOx emissions in tons is calculated. Under the Part 75 program NOx emissions are not logged in lb/hr,but rather in ppm and lb/mmbtu. The Acid Rain Program does quantify NOx mass emissions in annual summaries but that is done using the hourly NOx lb/mmbtu,heat input and hours of operation values. Part 75 requires NOx lb/mmbtu to be determined on an hourly basis using the hourly values for NOx ppm,a fuel specific F-factor, and CO2 or 02 diluent. Data substitution and application of a bias adjustment factor (BAF)are done at the hourly average level on the NOx lb/mmbtu channel. The application of a BAF is not done on a NOx lb/hr channel. As such,PSCo's DAHS systems have been setup with a NOx lb/hr minute channel that is calculated from the minute NOx lb/mmbtu and heat input channel values. This channel is used by plant operations for informational purposes and can be RATA tested,but the official NOx tonnage comes from summing the hourly NOx lb/hr channel that was built using the hourly NOx lb/mmbtu and heat input channels. In order to properly apply all bias adjustment factors and data substitution routines and be consistent with Part 75 requirements this is the method that must be followed. Again,PSCo does not believe that the section as currently written is incorrect. However,if the Division wishes to identify steps in the process for determining the total NOx mass emission in tons,perhaps the following information could be considered for inclusion into the permit condition. NOx Tons will be determined by taking the hourly Part 75 NOx lb/mmbtu value(which includes substituted and bias adjusted data)and multiplying it by the hourly Part 75 Heat Input value(which accounts for substituted data where appropriate from the fuel flow measurement). The resulting NOx lb/hr value is then multiplied by the unit operating time for the hour to produce a NOx lbs value. These values are summed and then divided by 2000 for total NOx tons on a rolling 12 month basis. The NOx lb/mmbtu value is calculated using equation F-5 in Part 75 and the Heat Input value is calculated using equation F-20 from Part 75. This method is consistent with EPA's Acid Rain Program. Condition 1.6.2(Page 12) Condition 1.6.2 addresses the method for determining CO lb/hr emissions for the purpose of showing compliance with mass emissions limits. PSCo would like to identify some clarifying points in how the total amount of CO emissions in tons is calculated. CO emissions and CO CEMS are not subject to the requirements of Part 75 and as such the CO mass emission determination is based on the procedures contained in Part 75 for NOx in order to be able to be able to perform data substitution during periods in which the CO CEMS is unavailable. Under Part 75 the NOx mass emissions are determined using the hourly NOx lb/mmbtu,heat input and hours of operation values. Part 75 requires NOx lb/mmbtu to be determined on an hourly basis using the hourly values for NOx ppm,a fuel specific F-factor, and CO2 or 02 diluent. Data substitution and application of a bias adjustment factor(BAF)are done at the hourly average level on the NOx lb/mmbtu channel. The method for determining CO mass emissions follows the same protocols as described here except for the application of a BAF. The standards for CO are established in 40 CFR Part 60 and as such the regulations and EPA test method(Method 10)used to certify the accuracy of the CO CEM do not require the determination of an analyzer bias adjustment factor. In addition,the purpose of the BAF implemented under the Part 75 rules is to ensure that pollutants with a monetary trading value on the open market(NOX tons and SO2 tons)are treated equally regardless of where the emissions are generated within the country. Because CO tons are not a traded commodity,PSCo does not believe that applying a BAF to this pollutant is appropriate. PSCo believes that applying the missing data procedure is sufficient to ensure that the CO tons are accurately reported and that all periods of operation are accounted for. The DAHS system has been programmed with a CO lb/hr minute channel that is calculated from the minute CO lb/mmbtu and heat input channel values.This channel is used by plant operations for informational purposes and can be RATA tested,but the official CO tonnage comes from summing the hourly CO lb/hr channel that was built using the hourly CO lb/mmbtu and heat input channels. In order to properly apply data substitution routines and be consistent with Part 75 requirements this is the method that must be followed. If the Division wishes to identify steps in the process for determining the total CO mass emission in tons, perhaps the following information could be considered for inclusion into the permit condition. CO Tons will be determined by taking the hourly CO lb/mmbtu value(which includes substituted data using Part 75 rules)and multiplying it by the hourly Part 75 Heat Input value(which accounts for substituted data where appropriate from the stack flow measurements). The resulting CO lb/hr value is then multiplied by the unit operating time for the hour to produce a CO lbs value. These values are summed and then divided by 2000 for total CO tons on a rolling 12 month basis. The CO lb/mmbtu value is calculated using equation F-5 in Part 75 for NOx lb/mmbtu since CO lb/mmbtu is not a parameter reported under the Acid Rain Program. The Heat Input value is calculated using equation F-20 from Part 75. Conditions 1.5.2, 1.6.2 and 3.3.2(Pages 11, 12 and 31) There is an error in the paragraphs under Conditions 1.5.2, 1.6.2,and 3.3.2. There is a sentence that refers to programming the DAHS to calculate lb/hr emissions in accordance with the requirements in Condition 8.1.7.2. There does not appear to be a Condition 8.1.7.2 in the permit. Conditions 1.5.1.5 and 1.6.1.5 (Pages 10 and 12) Conditions 1.5.1.5 and 1.6.1.5 have a discussion on the method for creating valid hourly averages. PSCo requests that this condition specify that Part 75 hour validation criteria will be used in the calculation of hourly NOx and CO concentration averages. Part 75 uses the most conservative validation criteria and is inline with the validation requirements in Part 60,section 60.13. Condition 3.3.1 (Page 31) There is a typographical error in the third sentence in Condition 3.3.1. "Specifically hourly mass CO[replace with"NOx"]emissions(in lb/hr)shall be calculated by multiplying the hourly NOx lb/MMBtu value by the hourly heat input value(MMBtu/hr)." Condition 3.4.1.2(Page 31) Condition 3.4.1.2 addresses the requirement to conduct routine performance testing on the auxiliary boiler. PSCo requests that the deadline for testing the boiler be based on sixty(60)boiler operating days,where a boiler operating day is defined as any calendar day in which fuel is combusted for any period of time,rather than sixty(60)calendar days. Setting the deadline for testing in this manner will eliminate concerns of meeting a calendar day deadline under a scenario in which the boiler becomes inoperable and repairs extend testing past the deadline. Condition 3.5(Page 32) There is a typographical error in the second sentence in Condition 3.5. "Natural gas consumed in each[replace with"the"]boiler shall be recorded daily, as required by 40 CFR Part 60 Db,60.49(d),as adopted by reference in Colorado Regulation No. 6,Part A. Condition 6.1.1.2(Page 38) Condition 6.1.1.2 states that the relative accuracy test audit(RATA)frequency for the CO CEMS will be determined according to 40 CFR Part 75 Appendix B. The CO CEM is subject to 40 CFR Part 60 Appendix F and as such the pass/fail criteria that is applied to the CO CEMS is from 40 CFR Part 60 Appendix F. Therefore the RATA frequency must also be based on Part 60 Appendix F. The pass/fail criteria and testing frequency requirements established in Part 75 are different than those established in Part 60. Condition 6.1.1.2 should be revised to state that the RATA frequency for the CO CEMS will be determined according to 40 CFR Part 60 Appendix F,as it is not appropriate to apply a Part 75 RATA frequency. Condition 6.1.2.2(Page 39) Condition 6.1.2.2 states that the quality assurance/quality control plan for the CO monitors on the turbines/RRSO/duct burners shall be prepared in accordance with the applicable requirements in Part 60, Appendix F. PSCo requests the ability to utilize the quality assurance/quality control plan required under Part 75 Appendix B as the requirements for the plan go above and beyond the requirements of the plan under Part 60. Condition 6.3 (Page 41) Condition 6.3 addresses the data replacement requirements in the determination of total annual emissions. The last sentence of the condition states that bias-adjusted data shall be included when assessing compliance with the annual limitations. For the same reasons that PSCo has identified in the comment submitted for Condition 1.6.2,this sentence should be revised to exclude CO from requiring the application of a bias adjustment factor. Appendix A—Inspection Information List of Insignificant Activities(Page 1) Under"Fuel storage and dispensing equipment in ozone attainment areas throughput<400 gal/day averaged over 30 days(Reg 3 Part C.II.E.3.ccc)"the source listed as a"100 gallon portable gasoline fuel tank mounted in the back of a facility vehicle"should be revised to reflect that it is a portable diesel fuel tank. PSCo appreciates this opportunity to review the draft modified operating permit for Rocky Mountain Energy Center prior to the permit being published for public comment. Please contact me at 303-294-2111 if you have any questions concerning the information provide above. Sincerely, 77z: Chad Campbell Environmental Services cc: Nathan Parker,RMEC ES File • P r 620 Xcel Ener 9Y'" Sccri Environmental Services Department 1800 Larimer Street,Suite 1300 Denver,CO 80202 September 14, 2011 Ms. Jacqueline Joyce Colorado Department of Public Health & Environment Air Pollution Control Division, APCD-SS-B1 Operating Permit Unit 4300 Cherry Creek Drive South Denver, CO 80246-1530 RE: Rocky Mountain Energy Center Operating Permit No. 05OPWE279 Minor Permit Modification Dear Ms. Joyce: In accordance with the requirements of Colorado Air Quality Control Commission Regulation No. 3, Part C.X, Public Service Company of Colorado (PSCo) is hereby submitting this application for a minor modification to our Rocky Mountain Energy Center(RMEC) Title V operating permit no. 05OPWE279. This modification request is being submitted in order to address the operational status of the Rentech Auxiliary Boiler(AIRS ID 123.1342.004). Permit Condition 3.4.1.2 (in Colorado Operating Permit#05OPWE279) requires that a compliance demonstration with the BACT CO limit be conducted on the Rentech Auxiliary Boiler within 18 months of expiration of the current operating permit. The current permit will expire on July 1, 2012. PSCo is concerned about meeting this testing deadline given that the boiler is inoperable and has not operated since 2006 due to severe boiler tube damage. PSCo continues to weigh its options with respect to future operation of the boiler and currently does not have any plans to repair and return the boiler to service. As such, PSCo is requesting a revision to the permit language so that the requirement to test is based on actual operation of the source rather than a defined period of time. Through this modification request PSCo is proposing that Condition 3.4.1.2 be revised to contain the following: A performance test shall be conducted within 18 months of expiration of this permit, or within sixty(60) days of re-starting the boiler if the boiler is inoperable at the time the test is due. Thereafter, a performance test shall be conducted whenever hours of operation for the boiler reaches 1,200 hours in any two consecutive years. This test shall be conducted within 60 days of reaching 1,200 hours. Performance tests shall be conducted using the appropriate EPA methods. • Per the requirements of Colorado Air Quality Control Commission Regulation No. 3, Part C.X.D, attached is a copy of the Rocky Mountain Energy Center Title V permit section that will require changes resulting from this modification request. By way of my signature below as the responsible official for this facility, I certify that the proposed modifications meet the criteria of a minor permit modification and request that the procedures set forth in Colorado Air Quality Control Commission Regulation No. 3, Part C.X be used to process this minor permit modification. If you have any questions concerning this request, please contact Chad Campbell of Xcel Energy's Environmental Services staff, at 303-294-2111. Sincerely, r George Hess General Manager— Power Generation, Colorado Attachments: As Stated cc: M. Block— RMEC N. Parker—RMEC ES File 3.4 Carbon Monoxide (CO) emissions from the boiler are subject to the following requirements: 3.4.1 For purposes of BACT, CO emissions from the boiler shall not exceed 0.039 lb/mmBtu, based on the average of three (3) test runs (Colorado Construction Permit 02WE0228, as modified under the provisions of Section I, Condition 1.3 to specify the averaging time). Compliance with the CO BACT limit shall be monitored as follows: 3.4.1.1 Compliance with the CO BACT emission limitation shall be presumed, in the absence of credible evidence to the contrary, provided the boiler is operated in accordance with manufacturer's recommendations and good engineering practices. 3.4.1.2 A performance test shall be conducted within the 18 months of expiration of this permit, or within sixty (60) days of re-starting the boiler if the boiler is inoperable at the time the test is due. Thereafter, a performance test shall be conducted whenever hours of operation for the boiler reaches 1,200 hours in any two consecutive years. This test shall be conducted within 60 days of reaching 1,200 hours. Performance tests shall be conducted using the appropriate EPA methods. A stack testing protocol shall be submitted for Division approval at least thirty (30) calendar days prior to performance of the test required under this condition. No stack test required herein shall be performed without prior written approval of the protocol by the Division. The Division reserves the right to witness the test. In order to facilitate the Division's ability to make plans to witness the test, notice of the date (s) for the stack test shall be submitted to the Division at least thirty (30) calendar days prior to the test. The Division may for good cause shown, waive this thirty (30) day notice requirement. In instances when a scheduling conflict is presented, the Division shall immediately contact the permittee in order to explore the possibility of making modifications to the stack test schedule. The required number of copies of the compliance test results shall be submitted to the Division within forty-five (45) calendar days of the completion of the test unless a longer period is approved by the Division. 9 Catsi Xcel Energy- o, o CI -Sovv..* Environmental Department-ESG Facility 4653 Table Mountain Drive Golden,Co 80403-1636 May 10,2011 Ms.Jacqueline Joyce Colorado Department of Public Health&Environment Air Pollution Control Division,APCD-SS-B 1 Operating Permit Unit 4300 Cherry Creek Drive South Denver,CO 80246-1530 Re: Rocky Mountain Energy Center Permit#050PWE279 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 Rocky Mountain Energy Center Title V Operating Permit#050PWE279. Attached are the completed permit application and certification forms required for this operating permit renewal. This submittal includes a required assessment of applicability of the Federal Compliance Assurance Monitoring (CAM)rule to the emission sources at Rocky Mountain Energy Center,a renewal application for the facility's two Acid Rain Program affected sources, and the required Colorado operating permit application forms. Compliance Assurance Monitoring Assessment Each emission source at Rocky Mountain Energy Center was evaluated for CAM applicability as part of the initial July 1,2007 permit issuance. The evaluation during that process identified the two combined cycle combustion turbines as being CAM affected for NOx and CO emissions because their permitted emission limits exceed the major source level. VOC emissions were not considered for CAM applicability during the initial process because the permitted VOC emissions are below the major source level. During this renewal process the two combustion turbines were to be evaluated for CAM applicability with regards to VOC emissions. The two sources were evaluated for VOC emissions and CAM was found to apply. As such,the two combustion turbines will require a CAM plan for assuring compliance with their permitted VOC emission limits. PSCo proposes the use of CO as a surrogate for assuring compliance with the VOC emission limits since both constituents utilize the same oxidation catalyst emission control and CO emissions are directly measured by a certified continuous emissions monitoring system. Compliance with VOC emission limits would be presumed as long as the CO BACT limits are met. This method would be inline with the current permit condition 1.3.2,which allows compliance with the VOC BACT emission limit to be presumed provided the CO BACT emission limits are met. If you have any questions concerning the attached permit application forms or information,please contact Chad Campbell of Xcel Energy's Environmental Services staff,at(303)294-2111. Sincere! , Georg Hess Genera anager—Power Generation,Colorado Attachments: As Stated cc: M.Block-FSV N.Parker-FSV ES Electronic File-Rocky Mountain\Current Permit Documentation\2011 Renewal Documentation I\TBD\ MAY102011 United States APCL Environmental Protection Agency \ St3tlp(18I'j OMB No.2060-0258 taEpA Acid Rain Program \ SO fs Acid Rain Permit Application For more information,see instructions and 40 CFR 72.30 and 72.31. This submission is: • ttew • tevlsed •3tor Acid Rain permit renewal STEP 1 Identify the facility name, Rocky Mountain Energy Center 55835 State,and plant(ORIS) Facility(Source)Name State CO Plant Code code. STEP 2 a b Enter the unit ID# Unit ID# Unit Will Hold Allowances for every affected in Accordance with 40 CFR 72.9(c)(1) unit at the affected source in column"a." 1 Yes 2 Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes EPA Form 7610-16(rev.07-08) Rocky Mountain Energy Center Acid Rain - Page 2 Facility(Source)Name(from STEP 1) Permit Requirements STEP 3 (1)The designated representative of each affected source and each affected unit at the source shall: Read the standard (i) Submit a complete Acid Rain permit application (including a compliance requirements. plan) under 40 CFR part 72 in accordance with the deadlines specified in 40 CFR 72.30; and (ii) Submit in a timely manner any supplemental information that the permitting authority determines is necessary in order to review an Acid Rain permit application and issue or deny an Acid Rain permit; (2)The owners and operators of each affected source and each affected unit at the source shall: (i) Operate the unit in compliance with a complete Acid Rain permit application or a superseding Acid Rain permit issued by the permitting authority; and (H) Have an Acid Rain Permit. Monitoring Requirements (1) The owners and operators and, to the extent applicable, designated representative of each affected source and each affected unit at the source shall comply with the monitoring requirements as provided in 40 CFR part 75. (2) The emissions measurements recorded and reported in accordance with 40 CFR part 75 shall be used to determine compliance by the source or unit, as appropriate, with the Acid Rain emissions limitations and emissions reduction requirements for sulfur dioxide and nitrogen oxides under the Acid Rain Program. (3) The requirements of 40 CFR part 75 shall not affect the responsibility of the owners and operators to monitor emissions of other pollutants or other emissions characteristics at the unit under other applicable requirements of the Act and other provisions of the operating permit for the source. Sulfur Dioxide Requirements (1) The owners and operators of each source and each affected unit at the source shall: (i) Hold allowances, as of the allowance transfer deadline, in the source's compliance account (after deductions under 40 CFR 73.34(c)), not less than the total annual emissions of sulfur dioxide for the previous calendar year from the affected units at the source; and (H) Comply with the applicable Acid Rain emissions limitations for sulfur dioxide. (2) Each ton of sulfur dioxide emitted in excess of the Acid Rain emissions limitations for sulfur dioxide shall constitute a separate violation of the Act. (3) An affected unit shall be subject to the requirements under paragraph (1) of the sulfur dioxide requirements as follows: (i) Starting January 1, 2000, an affected unit under 40 CFR 72.6(a)(2); or (ii) Starting on the later of January 1, 2000 or the deadline for monitor certification under 40 CFR part 75, an affected unit under 40 CFR 72.6(a)(3). EPA Form 7610-16(rev.07-08) Rocky Mountain Energy Center Acid Rain - Page 3 Facility(Source)Name(from STEP 1) Sulfur Dioxide Requirements, Cont'd. STEP 3, Cont'd. (4) Allowances shall be held in, deducted from, or transferred among Allowance Tracking System accounts in accordance with the Acid Rain Program. (5) An allowance shall not be deducted in order to comply with the requirements under paragraph (1) of the sulfur dioxide requirements prior to the calendar year for which the allowance was allocated. (6)An allowance allocated by the Administrator under the Acid Rain Program is a limited authorization to emit sulfur dioxide in accordance with the Acid Rain Program. No provision of the Acid Rain Program, the Acid Rain permit application, the Acid Rain permit, or an exemption under 40 CFR 72.7 or 72.8 and no provision of law shall be construed to limit the authority of the United States to terminate or limit such authorization. (7)An allowance allocated by the Administrator under the Acid Rain Program does not constitute a property right. Nitrogen Oxides Requirements The owners and operators of the source and each affected unit at the source shall comply with the applicable Acid Rain emissions limitation for nitrogen oxides. Excess Emissions Requirements (1) The designated representative of an affected source that has excess emissions in any calendar year shall submit a proposed offset plan, as required under 40 CFR part 77. (2)The owners and operators of an affected source that has excess emissions in any calendar year shall: - - (i) Pay without demand the penalty required, and pay upon demand the interest on that penalty, as required by 40 CFR part 77; and (ii) Comply with the terms of an approved offset plan, as required by 40 CFR part 77. Recordkeepinq and Reporting Requirements (1) Unless otherwise provided, the owners and operators of the source and each affected unit at the source shall keep on site at the source each of the following documents for a period of 5 years from the date the document is created. This period may be extended for cause, at any time prior to the end of 5 years, in writing by the Administrator or permitting authority: (i)The certificate of representation for the designated representative for the source and each affected unit at the source and all documents that demonstrate the truth of the statements in the certificate of representation, in accordance with 40 CFR 72.24; provided that the certificate and documents shall be retained on site at the source beyond such 5-year period until such documents are superseded because of the submission of a new certificate of representation changing the designated representative; EPA Form 7610-16(rev.07-08) Rocky Mountain Energy Center Acid Rain - Page 4 Facility(Source)Name(from STEP 1) Recordkeepinq and Reporting Requirements, Cont'd. STEP 3, Cont'd. (H) All emissions monitoring information, in accordance with 40 CFR part 75, provided that to the extent that 40 CFR part 75 provides for a 3-year period for recordkeeping, the 3-year period shall apply. (Hi) Copies of all reports, compliance certifications, and other submissions and all records made or required under the Acid Rain Program; and, (iv) Copies of all documents used to complete an Acid Rain permit application and any other submission under the Acid Rain Program or to demonstrate compliance with the requirements of the Acid Rain Program. (2)The designated representative of an affected source and each affected unit at the source shall submit the reports and compliance certifications required under the Acid Rain Program, including those under 40 CFR part 72 subpart I and 40 CFR part 75. Liability (1) Any person who knowingly violates any requirement or prohibition of the Acid Rain Program, a complete Acid Rain permit application, an Acid Rain permit,or an exemption under 40 CFR 72.7 or 72.8, including any requirement for the payment of any penalty owed to the United States, shall be subject to enforcement pursuant to section 113(c) of the Act. (2) Any person who knowingly makes a false, material statement in any record, submission, or report under the Acid Rain Program shall be subject to criminal enforcement pursuant to section 113(c) of the Act and 18 U.S.C. 1001. (3) No permit revision shall excuse any violation of the requirements of the Acid Rain Program that occurs prior to the date that the revision takes effect. (4) Each affected source and each affected unit shall meet the requirements of the Acid Rain Program. (5)Any provision of the Acid Rain Program that applies to an affected source (including a provision applicable to the designated representative of an affected source) shall also apply to the owners and operators of such source and of the affected units at the source. (6) Any provision of the Acid Rain Program that applies to an affected unit (including a provision applicable to the designated representative of an affected unit) shall also apply to the owners and operators of such unit. (7) Each violation of a provision of 40 CFR parts 72, 73, 74, 75, 76, 77, and 78 by an affected source or affected unit, or by an owner or operator or designated representative of such source or unit, shall be a separate violation of the Act. Effect on Other Authorities No provision of the Acid Rain Program, an Acid Rain permit application, an Acid Rain permit, or an exemption under 40 CFR 72.7 or 72.8 shall be construed as: (1) Except as expressly provided in title IV of the Act, exempting or excluding the owners and operators and, to the extent applicable, the designated representative of an affected source or affected unit from compliance with any other provision of the Act, including the provisions of title I of the Act relating EPA Form 7610-16(rev.07-08) Rocky Mountain Energy Center Acid Rain - Page 5 Facility(Source)Name(from STEP 1) Effect on Other Authorities, Cont'd. to applicable National Ambient Air Quality Standards or State Implementation STEP 3, Cont'd. Plans; (2) Limiting the number of allowances a source can hold; provided, that the number of allowances held by the source shall not affect the source's obligation to comply with any other provisions of the Act; (3) Requiring a change of any kind in any State law regulating electric utility rates and charges, affecting any State law regarding such State regulation, or limiting such State regulation, including any prudence review requirements under such State law; (4) Modifying the Federal Power Act or affecting the authority of the Federal Energy Regulatory Commission under the Federal Power Act; or, (5) Interfering with or impairing any program for competitive bidding for power supply in a State in which such program is established. Certification STEP 4 I am authorized to make this submission on behalf of the owners and Read the operators of the affected source or affected units for which the submission is certification made. I certify under penalty of law that I have personally examined, and am statement, familiar with, the statements and information submitted in this document and sign, and date. all its attachments. Based on my inquiry of those individuals with primary responsibility for obtaining the information, I certify that the statements and information are to the best of my knowledge and belief true, accurate, and complete. I am aware that there are significant penalties for submitting false statements and information or omitting required statements and information, including the possibility of fine or imprisonment. George Hess Designated Representative Name Signature I Date b -9 - k1 EPA Form 7610-16(rev.07-08) Operating Permit Application FACILITY IDENTIFICATION FORM 2000-100 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name and Name Rocky Mountain Energy Center mailing address Street or Route 6211 Weld County Road 51 City, State,Zip Code Keenesburg, CO 80643 2. Facility location Street Address 6211 Weld County Road 51 (No P.O.Box) City, County,Zip Code Keenesburg,CO 80643 3. Parent corporation Name Public Service Company of Colorado Street or Route 1800 Larimer Street City, State,Zip Code Denver,CO 80802 Country(if not U.S.) 4. Responsible Name George Hess official Title General Manager—Power Generation, Colorado Telephone (303)571-7282 5. Permit contact person Name Dean Metcalf Title Director,Air and Water (If Different than 4) Telephone (303)294-2007 6. Facility SIC code: 4911 7. Facility identification code: CO 1231342 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 ❑New ❑Modified L l Renewal 11. Is the facility located in a"nonattainment"area: O Yes ❑D No If"Yes", check the designated"non-attainment"pollutant(s): ❑ Carbon Monoxide O Ozone O PMI0 O 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 unit/process 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 09-94 Air Pollution Control Division Facility Name: Rocky Mountain Energy Center Facility Identification Code: CO 1231342 1. ADMINISTRATION This application contains the following forms: ❑x Form 2000-I00,Facility Identification ❑ Form 2000-101,Facility Plot Plan ❑ Forms 2000-102,-102A,and-102B,Source and Site Descriptions II. EMISSIONS SOURCE Total Number DESCRIPTION of This Form This application contains the following forms ❑ Form 2000-200,Stack Identification (one form for each facility boiler.Printing O 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 ❑ Form 2000-306,Miscellaneous Processes ❑ Form 2000-307,Glycol Dehydration Unit III. AIR POLLUTION CONTROL Total Number SYSTEM of This Form This application contains the following forms: O Form 2000400,Miscellaneous ❑ Form 2000-401,Condensers ❑ Form 2000-402,Adsorbers ❑ Form 2000403,Catalytic or Thermal Oxidation ❑ Form 2000-404,Cyclones/Settling Chambers ❑ Form 2000-405,Electrostatic Precipitators ❑ Form 2000-406,Wet Collection Systems O Form 2000-407,Baghouses/Fabric Filters IV. COMPLIANCE Total Number DEMONSTRATION of This Form This application contains the following forms O Form 2000-500,Compliance Certification-Monitoring and Reporting (one for each facility boiler.Printing operation. ❑ Form 2000-501,Continuous Emission Monitoring ❑ Form 2000-502,Periodic Emission Monitoring Using Portable Monitors ❑ 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 ❑ Form 2000-507,Recordkeeping ❑ Form 2000-508,Other Methods 2 • V. EMISSION SUMMARY AND Total Number COMPLIANCE CERTIFICATION of This Form This application contains the following forms ❑ Form 2000-600,Emission Unit Hazardous Air Pollutants quantifying emissions,certifying compliance with applicable requirements,and developing a compliance plan ❑ 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 ❑ 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 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 -FEDERAL/STATE CONDITIONS(check one box only) 0 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 Title George Hess General Manager—Power Generation, Colorado Signature / Date Signed--3/41\A 3 Operating Permit Application CERTIFICATION FOR STATE-ONLY CONDITIONS FORM 2000-800 Colorado Department of Health 09-94 Air Pollution Control Division Facility Name: Rocky Mountain Energy Center Facility Identification Code: CO 1231342 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. O 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 Title George Hess 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 Xcel Energy- oR 2.3'°1 stori SC1 A' Environmental Services Department 1800 Larimer Street,Suite 1300 Denver,CO 80202 March 21, 2011 Ms. Jacqueline Joyce Colorado Department of Public Health & Environment Air Pollution Control Division, APCD-SS-B1 Operating Permit Unit 4300 Cherry Creek Drive South Denver, CO 80246-1530 RE: Rocky Mountain Energy Center Operating Permit No. 05OPWE279 Minor Permit Modification Dear Ms. Joyce: In accordance with the requirements of Colorado Air duality Control Commission Regulation No. 3, Part C.X, Public Service Company of Colorado (PSCo) is hereby submitting this application for a minor modification to our Rocky Mountain Energy Center(RMEC)Title V operating permit no. 05OPWE279. This modification request is being submitted in order to correct the omission of a cold cleaner solvent vat and 500 gallon above ground gasoline fuel tank from the list of facility emission sources and several activities from the"List of Insignificant Activities" that is contained in Appendix A of the permit. A recent review of operations at the facility showed that RMEC utilizes a cold cleaner solvent vat and a 500 gallon above ground gasoline fuel tank as part of their routine operations. Both items are existing sources that are not identified in the facility's current Title V permit. In order to correct the omissions PSCo is requesting that the cold cleaner solvent vat and gasoline tank be added to the facility's list of emission sources along with the appropriate permit requirements. The solvent vat will be regulated under Colorado Regulation No. 7 and will require prescribed operating practices. The tank will be regulated under Part 63 Subpart CCCCCC and will require fuel throughput tracking and prescribed operating practices. The same review of operations at RMEC identified several insignificant activities that are not . included in Appendix A of the current Title V permit. The following is a list of activities that should be added. o (1) 500 gallon above ground diesel fuel tank. This insignificant activity has an exemption under the Reg. 3 Part C.II.E.3.fff. o The(2) 12,000 gallon ammonia tanks already listed under the Reg. 3 Part C.II.E.3.b should be corrected to be listed as (2) 14,200 gallon tanks o (1) 8,400 gallon gas condensate tank. This insignificant activity has an exemption under the Reg. 3 Part C.II.E.3.gggg. o (1) 100 gallon portable gasoline fuel tank mounted in the back of a facility vehicle. This insignificant activity has an exemption under the Reg. 3 Part C.I I.D.1.ccc. o (1) Forklift. This insignificant activity has an exemption under the Reg. 3 Part C.I I.D.1.kkk. Per the requirements of Colorado Air Quality Control Commission Regulation No. 3, Part C.X.D, attached are copies of the Rocky Mountain Energy Center Title V permit sections that will require changes resulting from this modification request. By way of my signature below as the responsible official for this facility, I certify that the proposed modifications meet the criteria of a minor permit modification and request that the procedures set forth in Colorado Air Quality Control Commission Regulation No. 3, Part C.X be used to process this minor permit modification. If you have any questions concerning this request, please contact Chad Campbell of Xcel Energy's Environmental Services staff, at 303-294-2111. Sincerely, George Hess GeneYal Manager— Power Generation, Colorado Attachments: As Stated cc: M. Block—RMEC N. Parker— RMEC ES File 6. Summary of Emission Units 6.1 The emissions units regulated by this permit are the following: Emission AIRS Facility Description Pollution Control Unit Stack Identifier Device Number Number S001 001 CT-01 One(1)Westinghouse,Model No. 501FD,Natural Gas-Fired Dry Low NOx Combustion Turbine, Serial No. 37A8191. The Turbine is Rated (DLN)Combustion at 1785 mmBtu/hr(HHV at ISO conditions). The turbine is Systems and operated in combined cycle mode only and the heat recovery Selective Catalytic steam generator(HRSG)is equipped with a duct burner rated at Reduction(SCR) 675 mmBtu/hr. The turbine drives a generator capable of for NOx and generating 152 MW of power and the I-IRSG drives a steam Oxidation Catalyst generator rated at 326 MW(at peak capacity). for CO and VOC. S002 002 CT-02 One(1)Westinghouse,Model No. 501FD,Natural Gas-Fired Dry Low NOx Combustion Turbine, Serial No. 37A8196. The Turbine is Rated (DLN)Combustion at 1785 mmBtu/hr(HHV at ISO conditions). The turbine is Systems and operated in combined cycle mode only and the heat recovery Selective Catalytic steam generator(HRSG)is equipped with a duct burner rated at Reduction(SCR) 675 mmBtu/hr. The turbine drives a generator capable of for NOx and generating 152 MW of power and the HRSG drives a steam Oxidation Catalyst generator rated at 326 MW(at peak capacity). for CO and VOC. S005 005 S005 Caterpillar,Model No.3512B,Internal Combustion Engine Uncontrolled Driving an Emergency Generator, Serial No. 1GZ01360. The Engine is Diesel Fuel-Fired and rated at 1810 hp and 12.2 mmBtu/lr. S004 004 S004 Rentech,Natural Gas Fired Boiler,Rated at 129 mmBtu/hr, Serial Low NOx Burners No.2002-49. S006 006 S006 Marley,Model No.F4910, 12 Cell Cooling Water Tower,Rated at Drift Eliminators 176,000 gal/min. M001 N/A Cold Cleaner Solvent Vats Uncontrolled M002 N/A Gasoline Storage Tank, 500 gallons, aboveground Uncontrolled „S; Ma�232p11 6. M001 —Cold Cleaner Solvent Vats Parameter Permit Limitations Compliance Monitoring Condition Emission Factor Number Short Term Long Term Method Interval Work Practice 7.1 N/A N/A N/A Internal Audit Annually Standards Transfer and 7.2 N/A N/A N/A Certification Annually Storage of Waste/Used Solvents Note that these emission units are exempt from the APEN reporting requirements in Regulation No. 3,Part A and the construction permit requirements in Regulation No. 3,Part B. 1.1 Operation of the cold cleaner solvent vats shall meet the standards defined in Colorado Regulation 7, Section X.B. Compliance shall be monitored by following the work practices defined in Public Service Company's Policy Manual regarding operation, maintenance and design of the cold cleaner solvent vats. The Policy Manual shall include, at a minimum the requirements defined in Colorado Regulation 7, Section X.B and shall be available to the inspector upon request. Audits of the vat operations and/or the policy manual shall be performed annually to ensure that operations are performed within the requirements of the policy manual and that the policy manual incorporates the requirements of Regulation 7, Section X.B. Audit reports are to be maintained and made available to the Division upon request. 1.2 The transfer and storage of waste and used solvents from the cold cleaner solvent vats are subject to the following requirements (Colorado Regulation No. 7, Section X.A.3 and 4): 1.2.1 In any disposal or transfer of waste or used solvent, at least 80 percent by weight of the solvent/waste liquid shall be retained (i.e., no more than 20 percent of the liquid solvent/solute mixture shall evaporate or otherwise be lost during transfers). 1.2.2 Waste or used solvents shall be stored in closed containers unless otherwise required by law. 7. M002 - Gasoline Storage Tank, 500 gallons aboveground Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number Gasoline 6.1 N/A N/A N/A Recordkeeping Monthly Throughput 40 CFR Pat 63 6.2. Work Practice Standards N/A See Condition 6.2 Subpart CCCCCC Requirements 1.1 Note that these emission units are exempt from the APEN reporting requirements in Regulation No. 3,Part A and the construction permit requirements in Regulation No. 3,Part B. 1.2 1.3 These requirements included in this Section II.6 are only federally enforceable. As of the date of revised permit issuance [August 12, 2008], the requirements in 40 CFR Part 63 Subpart CCCCCC have not been adopted into Colorado Regulation No. 8, Part E by the Division and are therefore not state- enforceable. In the event that the Division adopts these requirements this tank will be subject to the APEN reporting and minor source permitting requirements and these requirements will be state-enforceable. 1.4 1.3 The quantity of gasoline processed through this tank shall be monitored and recorded monthly. Monthly records of gasoline processed shall be retained as required by Condition 6.2.1. 1.4 This tank is subject to the requirements in 40 CFR Part 63 Subpart CCCCCC, "National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities", as follows: 1.4.1 An affected source shall, upon request by the division, demonstrate that their average monthly throughput is less than the 10,000-gallon or the 100,000-gallon threshold level, as applicable (40 CFR Part 63 Subpart CCCCCC § 63.11111(e)). 1.4.2 If you have an existing affected source, you must comply with the standard in this subpart no later than January 10, 2011 (40 CFR Part 63 Subpart CCCCCC § 63.11113(b)). 1.4.3 You must not allow gasoline to be handled in a manner that would result in vapor releases to the atmosphere for extended periods of time. Measures to be taken include, but are not limited to, the following (40 CFR Part 63 Subpart CCCCCC § 63.11116(a)): 1.4.3.1 Minimize gasoline spills; 1.4.3.2 Clean up spills as expeditiously as practicable; 1.4.3.3 Cover all open gasoline containers and all gasoline storage tank fill-pipes with a gasketed seal when not in use; 1.4.3.4 Minimize gasoline sent to open waste collection systems that collect and transport gasoline to reclamation and recycling devices, such as oil/water separators; 1.4.4 You are not required to submit notifications or reports, but you must have records available within 24 hours of a request by the Division to document your gasoline throughput (40 CFR Part 63 Subpart CCCCCC § 63.11116(b)). 1.4.5 You must comply with the requirements of this subpart by the applicable date specified in Condition 6.2.2 (40 CFR Part 63 Subpart CCCCCC § 63.11116(c)). APPENDIX A-Inspection Information Directions to Plant The facility is located at 6211 Weld County Road 51 (between Hudson and Keenesburg, east of I-76, accessible from the Kersey Rd exit). Safety Equipment Required Eye Protection, Hard Hat, Safety Shoes and Hearing Protection Facility Plot Plan Figure 1 (following page) shows the plot plan as submitted on March 14, 2005 with the source's Title V 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. Insignificant activities and/or sources of emissions as identified in the Title V permit application: Units with emissions less than APEN de minims—non-criteria reportable pollutants (Reg 3, Part C.II.E.3.b) Two (2) 12,000 14,200 gal anhydrous ammonia storage tanks Fuel (gaseous) burning equipment< 5 mmBtu/hr(Reg 3, Part C.II.E.3.k) Water bath fuel heater Landscaping and site housekeeping devices < 10 hp (Reg 3, Part C.II.E.3.bb) Garden tractor Stationary Internal Combustion Engines - limited size or hours (Reg 3, Part C.II.E.3.xxx.(ii)) Diesel-fired emergency fire water pump (182 hp) Storage Tanks—Diesel Fuel annual throughput less than four hundred thousand gallons (Rea 3. Part C.II.E.3.fff. 500 gallon above ground diesel fuel tank. Condensate Tanks—Production rate of 730 barrels per year or less (Reg 3. Part C.ILE.3.gggg. 8,400 gallon gas condensate tank. Fuel storage and dispensing equipment annual throughput less than four hundred gallons per day (Reg 3. Part C.II.D.1.ccc. 100 gallon portable gasoline fuel tank mounted in back of a facility vehicle Forklift (Rea 3, Part C.II.D.1.kkk. Forklift • 4 l�otc �U`CoS Xcel Energy- Environmental Services Department 1800 Larimer Street,Suite 1300 Denver,CO 80202 December 17,2010 Ms.Jacqueline Joyce Colorado Department of Public Health&Environment Air Pollution Control Division,APCD-SS-B1 Operating Permit Unit 4300 Cherry Creek Drive South Denver,CO 80246-1530 RE: Transfer of Ownership Agreement—Rocky Mountain Energy Center,LLC Dear Ms.Joyce, This notice is to inform the Colorado Department of Public Health and Environment(CDPHE)that Public Service Company of Colorado(PSCo)d/b/a Xcel Energy has purchased Rocky Mountain Energy Center LLC from Calpine Operating Services Corporation. The purchase was finalized on December 6,2010. Included with this notice is the information required to process the change of ownership and responsible official designations listed in the facility's operating permit(Permit No.05OPWE279). Also through this submittal PSCo is changing the facility name from the now defunct Rocky Mountain Energy Center LLC to Rocky Mountain Energy Center. As part of this administrative change,PSCo is including with this notice a Transfer of Ownership Agreement form,Title V Forms 2000-100 and 2000-800,updated Air Pollutant Emission Notices(APEN)for each qualifying emissions source located at Rocky Mountain Energy Center, and a check in the amount of$764.50 for five(5)APEN filing fees. If you have any questions concerning this notification,please contact me at(303)294-2111. Sincerely Chad Campbell Environmental Services Xcel Energy Attachments: Transfer of Ownership Agreement Form Title V Form 2000-100 Title V Form 2000-800 APEN Form for RMEC Unit 1 APEN Form for RMEC Unit 2 APEN Form for RMEC Emergency Boiler APEN Form for RMEC Auxiliary Boiler APEN Form for RMEC Cooling Water Tower Check#0000533901 STATE OF COLORADO Bill Ritter,Jr.,Governor 02 co_ Martha E.Rudolph,Executive Director /,�$ Dedicated to protecting and improving the health and environment of the people of Colorado ye0o) 4300 Cherry Creek Dr.S. Laboratory Services Division J Denver,Colorado 80246-1530 8100 Lowry Blvd. J �*is?a Phone(303)692-2000 Denver,Colorado 80230-6928 TDD Line(303)691-7700 (303)692-3090 Colorado Department ..tl Located in Glendale,Colorado ;cif, of Public Health http://www.cdphe.state.co.us Y, and Environment S atO'': TRANSFER OF OWNERSHIP AGREEMENT Construction Permits and/or Air Pollution Emission Notices This agreement must be submitted to the Colorado Department of Public Health and Environment Air Pollution Control Division along with anAdministrative Permit Amendment Form for the facility and anAir Pollution Emission Notice (APEN) for each individual emission point to be transferred. (former permit holder) [Rocky Mountain Energy Center LLC]*,the responsible party for emission source: (facility name)Rocky Mountain Energy Center, located at: (address)6211 Weld County Road 51 (city)Keenesburg,Colorado 80643 and operated under Construction(or Emission)Permit(s)#05OPWE279, has sold the business associated with the construction permit(s). On behalf of the former permit holder, I hereby agree to transfer said permit(s)to: (new permit holder)Public Service Company of Colorado d/b/a Xcel Energy. The transfer of the Permit(s) is effective as of(date):December 6, 2010. Transfer of the Permit(s)conveys to the new owner all responsibility,coverage and liability associated with the permit(s).Submission of the Transfer of Ownership Agreement without a request for permit modification implies that no change is contemplated which would constitute a new or modified air pollution source. Signed(former permit holder) -Ja * date: I?/I 7//b Signed(new permit holder _ date: /47/1 cD * [Rocky Mountain Energy Center LLC], the former holder of the permit for the facility,was purchased by Xcel Energy and dissolved on [December 6,2010]. Xcel Energy acquired ownership of all [Rocky Mountain Energy Center LLC]'s assets at that time, and thus has the authority to request this permit change on behalf of both itself and the now defunct [Rocky Mountain Energy LLC]. Please see the attached signature page from the [Purchase and Sale Agreement], confirming Xcel Energy's purchase of [ ] and its assets from Calpine Operating Services Company. 7 fiat Moo-via:4- y ("erie, "Lc K:\Forms\Notice—transferownership.doc • Operating Permit Application FACILITY IDENTIFICATION FORM 2000400 - Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name and Name Rocky Mountain Energy Center mailing address Street or Route 6211 Weld County Road 51 City, State,Zip Code Keenesburg, CO 80643 2. Facility location Street Address - 6211 Weld County Road 51 (No P.O.Box) City,County,Zip Code Keenesburg, CO 80643 3. Parent corporation Name Public Service Company of Colorado Street or Route 1800 Larimer Street City, State,Zip Code Denver, CO 80202 Country(if not U.S.) 4. Responsible Name George Hess official Title General Manager - Power Generation, Colorado Telephone 303-571-7282 5. Permit contact person Name Chad Campbell Title Environmental Analyst V (If Different than 4) Telephone 303-294-2111 6. Facility SIC code: 4911 7. Facility identification code: CO 1231342 8. Federal Tax I.D.Number:84-6015506 9. Primary activity of the operating establishment: Coal-fired Electric Generating Station 10. Type of operating permit ❑New X Modified ❑Renewal 11. Is the facility located in a"nonattainment"area: 0 Yes X No If"Yes",check the designated"non-attainment"pollutant(s): ❑ Carbon Monoxide ❑ Ozone ❑ PM10 ❑ 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 unit/process is covered by each permit. For a Modified Operating Permit,do not complete this item. RECET F DEC 242010 Ar State. Sn Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 Colorado Department of Health 09-94 Air Pollution Control Division Facility Name:Rocky Mountain Energy Center Facility Identification Code: CO 1231342 I. ADMINISTRATION This application contains the following forms: x Form 2000-100,Facility Identification ❑ Form 2000-101,Facility Plot Plan ❑ Forms 2000-102,-I02A,and-102B,Source and Site Descriptions H. EMISSIONS SOURCE Total Number DESCRIPTION of This Form This application contains the following forms ❑ Form 2000-200,Stack Identification (one form for each facility boiler,printing ❑ Form 2000-300,Boiler or Furnace Operation ❑ Form 2000-301,Storage Tanks ❑ Form 2000-302,Internal Combustion Engine ❑ Form 2000-303,Incineration ❑ Form 2000-304,Printing Operations ❑ Form 2000-305,Painting and Coating Operations ❑ Form 2000-306,Miscellaneous Processes ❑ Form 2000-307,Glycol Dehydration Unit III. AIR POLLUTION CONTROL Total Number SYSTEM of This Form This application contains the following forms: ❑ Form 2000400,Miscellaneous ❑ Form 2000-401,Condensers ❑ Form 2000402,Adsorbers ❑ Form 2000403,Catalytic or Thermal Oxidation ❑ Form 2000-404,Cyclones/Settling Chambers • ❑ Form 2000-405,Electrostatic Precipitators ❑ Form 2000406,Wet Collection Systems ❑ Form 2000-407,Baghouses/Fabric Filters IV. COMPLIANCE Total Number DEMONSTRATION of This Form This application contains the following forms ❑ Form 2000-500,Compliance Certification-Monitoring and (one for each facility boiler,printing operation, R enorting ❑ Form 2000-501,Continuous Emission Monitoring ❑ Form 2000-502,Periodic Emission Monitoring Using Portable Monitors ❑ Form 2000.503,Control System Parameters or Operation Parameters of a Promevs ❑ Form 2000-504,Monitoring Maintenance Procedures ❑ Form 2000-505,Stack Testing ❑ Form 2000-506,Fuel Sampling and Analysis ❑ Form 2000-507,Recordkeeping ❑ Form 2000-508,Other Methods 146 Operating Permit Application CERTIFICATION FOR STATE-ONLY CONDITIONS FORM 2000-800 Colorado Department of Health 09-94 Air Pollution Control Division Facility Name:Rocky Mountain Energy Center Facility Identification Code: CO 1231342 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) X 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. 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C N a) ..Pa O >1 A) P2 To a) c o N CO a a O 2 a) U (.0 w C 7 CCO v co o L O o O E E O 3 �a)ai _ o a) — a. — a) C) n ,o O — 0 c o I) U Z. a V ' > - N J 4-1 o c E U J o a E UU a.o c 0- O a) c U . U > d a) N • J ❑ C • U > cp U «' _ mac `a) _ W a)• 00 z o LU I c rn e v a ) o C N - c ay• w 'Q. > Tel c a chi U 0 d a) Q. 0. ). yU o c0.02 m c c 02 Cl) 0 a o o u U co J i i EXECUTION VERSION ASSIGNMENT AGREEMENT This ASSIGNMENT AGREEMENT (this "Assignment"), dated as of December 6 2010, is made and entered into by and between Riverside Energy Center, LLC, a Wisconsin limited liability company ("Assignor") and Public Service Company of Colorado, a Colorado corporation("Assignee", and collectively with Assignor,the"Parties"). WHEREAS, the Parties have entered into that certain Purchase and Sale Agreement, dated as of April 2; 2010 (the"Purchase Agreement"), under which Assignor has agreed to sell and transfer, and Assignee has agreed to purchase, 100% of the limited liability company interests in Rocky Mountain Energy Center, LLC, a Delaware limited liability company (the "Interests"). NOW THEREFORE,for good and valuable consideration,the receipt and sufficiency of which are hereby acknowledged,the Patties hereby agree as follows: • 1. Definitions. Capitalized terms used and not otherwise defined herein shall have the meanings assigned to them in the Purchase Agreement. 2. Assignment of Interests. Assignor hereby sells, assigns, transfers, conveys and delivers to Assignee all of Assignor's rights, title and interests in and to the Interests, free and clear of any and all Liens,except Permitted Liens. 3. Purchase Agreement. This Assignment is subject to, in all respects,the terms and conditions of the Purchase Agreement, and to Assignment the and the Agreement,the terms of thePurchase Agreement shall this control. 4. Counterparts. This Assignment may be executed in one or more counterparts, and by facsimile, all of which,taken together, shall be considered one and the same agreement, and shall become effective when one or more counterparts have been signed by each of the Parties and delivered to the other Parties. 5. Governing Law. This Assignment shall be governed by and construed in accordance with the laws of the state of New York, applicable to agreements made and to be performed entirely within such State, without regard to the conflict of laws principles thereof. Any disputes or claims arising out of or in connection with this Agreement and the transactions contemplated or documents required hereby shall be submitted to the exclusive jurisdiction of the courts of the State of New York and the federal courts of the United States of America • located in the State of New York, County of New York, and appropriate appellate courts therefrom. JREMAINDER OF PAGE IN tENTIONALLY LEFT BLANK] NE\W0RX7N1639(%X) IN WITNESS WHEREOF, the Parties hereto have executed this Assignment as of the date first above written. ASSIGNOR: RIVERS I ENERGY CENTER,LLC By: ame:A.Ieyatpave .9• aloe Title: !lathy t Si jnotki ASSIGNEE: PUBLIC SERVICE COMPANY OF • COLORADO By: Name: Title: • • • • Signature Page to Assignment Agreement(Riverside) NC\YORK7505639(Rq (REVERSE OF CERTIFICATE) •• ASSIGNMENT OF LLC INTEREST • • FOR VALUE RECEIVED, the undersigned (the "Assignor") hereby assigns, conveys,sells and transfers unto PoMte. Su \I Cu. CA Q kpavvy bQ Co 10 ccao lb •5i-ceeA , 60,1•1-e._�1•1-e 3oao `VA t)2 (o (oO p vox, Cc1c (Lab `b 3 L6'L (Please insert taxpayer identification (Please print name and address) • number of Assignee) • • all rights and interest of the Assignor in ROCKY MOUNTAIN ENERGY CEN I'ER,•LLC represented by the within Certificate and irrevocably constitutes and appoints as its attorney-in-fact with full power of substitution in the premises to transfer • the same on-the books of the Company. - Dated: • By, �G a- e • • • I . • • • THIS SECURITY HAS NOT BEEN REGISTERED OR QUALIFIED PURSUANT TO THE SECURITIES.ACT OF 1933 OR THE SECURITIES LAWS OF ANY STATE AND MAY BE OFFERED AND SOLD ONLY IF SO REGISTERED AND QUALIFIED OR • IF AN EXEMPTION FROM SUCH REGISTRATION AND QUALIFICATION EXISTS. t _ • LLC INTEREST CERTIFICATE ROCKY MOUNTAIN ENERGY CENTER,LLC • • a Delaware limited liability company No.2 THIS CERTIFIES THAT RIVERSIDE ENERGY CENTER,LLC is the owner of a fully paid and non-assessable 100% LLC Interest (as defined in the Agreement referred to herein) of Rocky Mountain Energy Center, LLC (the "Company") and certain other rights in. connection therewith in the Company, as set forth in the Third Amended and Restated Limited Liability Company Operating Agreement, dated as of June -24, 2004, of the Company, as amended, modified and supplemented from time to time (the "LLC Agreement"). Such LLC Interest is not transferable except as provided in the LLC Agreement and is otherwise subject to the terms and conditions of the LLC Agreement. THIS CERTIFICATE is not negotiable or transferable except in connection with the transfer of the limited liability company interest evidenced hereby as provided in the LLC Agreement; provided,however, that this Certificate, when coupled with an assignment in the form set forth on the reverse hereof or otherwise sufficient to convey an interest in the Company, duly executed in blank or assigned to the named assignee, may be deposited with the Secretary and shall constitute direction by the registered owner of this Certificate to such Secretary to • register the change of ownership of the limited liability company interest evidenced hereby to such assignee and to issue a new Certificate reflecting such change of ownership to such assignee. The LLC Interests in the Company shall constitute"securities" within the meaning of (i) Article 8 of the Uniform Commercial Code (including Section 8-102(a)(15) thereof) as in effect from time to time in the State of Delaware and in the State of New York and(ii)the law of any other applicable jurisdiction that presently or hereafter is substantially similar to such Article 8. . IN WITNESS'WHEREOF,the Company has caused this Certificate to be signed by the duly authorized officers of its sole Member and the issuance recorded in its limited liability company books this 7 0 day orpceeo-hx 2009. • By: G t-A°Pv e: Jack A.Fusco Title. President f/. By: e G(Lta— Name: W.Thaddeus Miller Title: Corporate Secretary THIS SECURITY HAS NOT BEEN REGISTERED OR QUALIFIED PURSUANT TO THE SECURITIES ACT OF 1933 OR THE SECURITIES LAWS OF ANY STATE AND MAY BE OFFERED AND SOLD ONLY IF SO REGIS!BRED AND QUALIFIED OR IF AN EXEMPTION FROM SUCH REGISTRATION AND QUALIFICATION EXISTS. Public Service Company of Colorado Wells Fargo Bank, N A. ql 0000533901 S Xcel Ene 115 Hospital Drive , 1225a/ �R.:n X Energy 1225 17th tre,gE a i Van Wert, OH 45891 � ss�aea/uy _ 1 Y * Denver 'CO 8020Z. ' 1 I o- I 3D3 626 2644 ` Date 12/03/10 9600014703a x $764 .50USD Pay SEVEN HUNDRED SIXTY FOUR & 50/100*************************** DOLLARS VOID IF NOT CASHED IN90 DAYS To The COLORADO DEPT OF PUBLIC HEALTH AND ENVIRONMENT Order APCD-SS-B1 Of 4300 CHERRY CREEK DRIVE SOUTH DENVER CO 80246-1530 C/"7 : v-2 r; fin: °akyi. 'ner Eq,L 1 00,Gl tagfaccnkelo'sgC3.P4,oN it`ON Viiorci l?APEwANtemnog.W.b1SE sEtop patcp jG1 rrolWIENH u'0❑0063390 loll t:04 L 2,038 2L0:96000 L 270 21I' Payee COLORADO DEPT ;OF PUBLIC HEALTH AND ENVIRONMENT Vendor ID Employee # Check No. Date COLORDEPPU 04 - 0000533901 12/03/10 ( Payment Ref Invoice No. PO/Contract Disc/Wth ( Pay Amount 082829300000 CALPINE1 . 2APENAP , . . 00 $764 . 50 Pymt Comments : APEN CALPINE INV CALPINE 1.2 APEN HOLD CHECK FOR PICK UP r C I ) / r N / / ) * I �, 000136 358913 Hello