HomeMy WebLinkAbout20102224.tiff STATE OF COLORADO
Bill Ritter,Jr.,Governor --
Ned Calonge,M.D., Interim Executive Director of cotoR.
Dedicated to protecting and improving the health and environment of the people of Colorado yet ��`
4300 Cherry Creek Dr.S. Laboratory Services Division
Denver,Colorado 80246-1530 8100 Lowry Blvd. Nt j g ,//
Phone(303)692-2000 Denver,Colorado 80230-6928
TDD Line(303)691-7700 (303)692-3090 Colorado Department
Located in Glendale,Colorado of Public Health
http://www.cdphe.state.co.us and Environment
September 14, 2010
Mr. Steve Moreno
Weld County Clerk
1402 N. 17th Ave.
Greeley, CO 80631
Dear Mr. Moreno:
On September 18, 2010,the Air Pollution Control Division will publish a public notice for Thermo Cogeneration
Partnership in the Fort Lupton Press. A copy of this public notice and the public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies
of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be
available for public inspection for a period of thirty(30) days from the date the public notice is published. Please
send any comment regarding this public notice to the address below.
Colorado Dept. of Public Health& Environment
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Jacquie N. Barela
Regards,
Da 2et'e,
7
Jacqueline N. Barela
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
p b b c R?vi ems: 2010-2224
- 1 1-IL
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: Thermo Cogeneration Partnership
1735 Nineteenth Street
Denver, CO 80202
Facility: Ft. Lupton Cogeneration Facility
6811 Weld County Road 31
Ft. Lupton, CO 80621
Thermo Cogeneration Partnership has applied for an Renewal Operating Permit for their facility in Weld County, CO. This
facility consists of five combustion turbines and associated duct burners used to generate steam and electricity for sale. A copy of
the applications, including supplemental information, the Division analysis, and a draft of the Renewal Operating Permit
95OPWE096 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 Blue Parish at the
Division at 303-692-3194 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: 1) identify the individual or group requesting the hearing, 2) state his or her address and phone number, and
3) state the reason(s) for the request, the manner in which the person is affected by the proceedings, and an explanation of why the
person's interests are not already adequately represented. The Division will receive and consider the written public comments and
requests for any hearing for thirty calendar days after the date of this Notice.
RELEASED TO: Fort Lupton Press on PUBLISHED: September 18, 2010
September 14, 2010
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
OPERATING PERMIT RENEWAL SUMMARY
PERMIT NUMBER: 95OPWE096 AIRS ID#: 1230250 DATE: September 14, 2010
APPLICANT: Thermo Cogeneration Partnership, L. P., A Delaware Limited Partnership—Thermo Cogeneration Facility
REVIEW ENGINEER: Jacqueline Joyce
SOURCE DESCRIPTION
Thermo Cogeneration Partnership, L. P. has applied for renewal of their Operating Permit issued for the Ft. Lupton
Cogeneration facility located at 6811 Weld County Road 31 in Ft. Lupton, Colorado in Weld County. This facility consists
of five combustion turbines and associated duct burners, which are used to generate steam and produce electricity for sale
and is classified under SIC 4911. 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. This source is a major stationary source with respect to Prevention of Significant Deterioration (PSD)
review and non-attainment area new source review(NANSR) requirements. 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 not subject to the Accidental Release provisions of section 112(r) of the Federal Clean Air Act. In addition,
although the combustion turbines are equipped with steam injection to control NOx emissions they are exempt from the
compliance assurance monitoring (CAM) requirements in 40 CFR Part 64 because at the time the CAM plan was required
the Title V permit specified a continuous compliance determination method (§ 64.2(b)(1)(vi)).
FACILITY EMISSION SUMMARY
Potential to Emit(tons/yr)
Emission Unit PM l PM10 SO2 NOxl CO VOC HAPS
Turbine/Duct 16.81 16.81 2 90.51 9.64 All turbines
Burner 1 (S001) —5.09
Turbine/Duct 16.81 16.81 2 589. 90.51 9.64 All duct
Burner 2 (S002) burners—
Turbine/Duct 16.81 16.81 2 90.51 9.64 4.22
Burner 3 (S003)
Turbine/Duct 16.81 16.81 2 90.51 9.64
Burner 4 (S004)
Turbine/Duct 16.81 16.81 2 90.51 9.64
Burner 5 (S005)
Emergency Gen. 0.27 0.26 0.59 3.81 1.49 0.26 6.95E-03
(S006)2
Fire-Pump (S007)2 0.07 0.07 0.14 1.52 0.25 0.07 1.85E-03
Cooling Tower 9.5 9.5 1.23 1.23
(S011)
Total _ 93.89 93.88 10.73 __ 594.33 454.29 49.76 10.55
Each turbine/duct burner has individual N0x limits, however,the total N0x limits for all units is more restrictive, so the total limit is
shown in the table.
2Emissions shown are from the original construction permits. Permitted emissions that were below the de minimis level (2 tons/yr)
were not included in the original Title V permit and the subsequent renewal permit.
3 V0C emissions are based on an emission factor of 0.0527 lb/mmgal for chloroform. Since V0C emissions are below the APEN de
minimis level (2 tons/yr), the V0C emission limit is not included in the permit.
EMISSION SOURCES
The following discussion identifies the changes that were made in the renewal permit.
Emergency Generator and Emergency Fire Pump Engine-These engines will be subject to work practice requirements in
40 CFR Part 63 Subpart Z777 (National Performance Standards for Hazardous Air Pollutants for Stationary Reciprocating
Internal Combustion Engines) beginning May 3, 2010. The appropriate applicable requirements from 40 CFR Part 63
Subpart Z777 have been included in the permit.
ALTERNATIVE OPERATING SCENARIOS
Minor language change was made to the first paragraph under Condition 2 of the Alternative Operating Scenario.
INSIGNIFICANT ACTIVITY LIST
No changes were made to the insignificant activity list.
PERMIT SHIELD
No additional non-applicable requirements were included in the permit shield.
f
TECHNICAL REVIEW DOCUMENT
For
RENEWAL of OPERATING PERMIT 95OPWE096
Thermo Cogeneration Partnership, L. P., a Delaware Limited Partnership
Ft. Lupton Cogeneration Facility
Weld County
Source ID 1230250
Prepared by Jacqueline Joyce
June 2010
Revised September 2010
I. Purpose:
This document will establish the basis for decisions made regarding the applicable
requirements, emission factors, monitoring plan and compliance status of emission units
covered by the renewed operating permit proposed for this site. The current Operating
Permit was issued October 1, 2006. The expiration date for the permit is October 1,
2011. 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 May
17, 2010, comments on the draft permit and technical review document received
September 8, 2010 via e-mail, 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.
Any revisions made to the underlying construction permits associated with this facility
made in conjunction with the processing of this operating permit application have been
reviewed in accordance with the requirements of Regulation No. 3, Part B, Construction
Permits, and have been found to meet all applicable substantive and procedural
requirements. This operating permit incorporates and shall be considered to be a
combined construction/operating permit for any such revision, and the permittee shall
be allowed to operate under the revised conditions upon issuance of this operating
permit without applying for a revision to this permit or for an additional or revised
construction permit.
II. Description of Source
This facility consists of a cogeneration facility defined under Standard Industrial
Classification 4931. Electricity for sale is produced by five (5) combustion turbines,
equipped with duct burners. Each combustion turbine serves a generator rated at
57.412 MW (name-plate). Exhaust gas from the combustion turbine, which may be
Page 1
heated further by duct burners, is used to either generate electricity or to heat a nearby
tomato greenhouse. There are two steam turbines, each rated at 52.220 MW (name-
plate). Other significant emission units at the facility are a cooling tower, emergency
back-up generator and fire pump.
The facility is located in Weld County at 6811 Weld County Road 31, in Ft. Lupton, CO.
This facility is located in an area classified as attainment for all pollutants except ozone.
It is classified as non-attainment for ozone and is part of the 8-hr Ozone Control Area as
defined in Regulation No. 7, Section II.A.1.
There are no affected states within 50 miles of the facility. Rocky Mountain National
Park, a federal Class I 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 renewal 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. Both
potential and actual emissions (in tons per year) at the facility are as follows:
Potential to Emit(tons/yr)
Emission Unit PM PM10 SO2 NO; CO VOC HAPS _
Turbine/Duct 16.81 16.81 2 90.51 9.64 See
Burner 1 (S001) Table on
Turbine/Duct 16.81 16.81 2 589. 90.51 9.64 Page 7
Burner 2 (S002)
Turbine/Duct 16.81 16.81 2 90.51 9.64
Burner 3 (S003)
Turbine/Duct 16.81 16.81 2 90.51 9.64
Burner 4 (S004)
Turbine/Duct 16.81 16.81 2 90.51 9.64
Burner 5 (5005)
Emergency Gen. 0.27 0.26 0.59 3.81 1.49 0.26
(S006)2
Fire-Pump 0.07 0.07 0.14 1.52 0.25 0.07
(S007)2
Cooling Tower 9.5 9.5 1.23
(S011)
Total 93.89 93.88 10.73 594.33 454.29 49.76 1O55
'Each turbine/duct burner has individual NOx limits, however, the total NOx limits for all units is more
restrictive, so the total limit is shown in the table.
2Emissions shown are from the original construction permits. Permitted emissions that were below the de
minimis level (2 tons/yr) were not included in the original Title V permit and the subsequent renewal
permit.
Page 2
I
3 VOC emissions are based on an emission factor of 0.0527 lb/mmgal for chloroform. Since VOC
emissions are below the APEN de minimis level (2 tons/yr), the VOC emission limit is not included in the
permit.
The criteria pollutant PTE shown above is based on permitted emission limits for the
turbines, duct burners, engines and cooling tower. The breakdown of HAP emissions
by emission unit and individual HAP is provided on page 7 of this document. The PTE
of HAP emissions is based on AP-42 emission factors, permitted fuel consumption limits
and heat values of 1020 Btu/SCF for natural gas and 137,000 Btu/gal for diesel fuel.
Actual Emissions (tons/yr)
Emission Unit PM PM10 SO2 NOx CO VOC HAPS _
Turbine/Duct 5.40 5.40 0.98 72.05 14.92 4.65 0.58
Burner 1
(S001)
Turbine/Duct 5.16 5.16 0.90 67.63 25.30 4.44 0.56
Burner 2
(S002)
Turbine/Duct 5.35 5.35 0.93 69.28 29.65 4.64 0.58
Burner 3
(S003)
Turbine/Duct 5.42 5.42 0.95 63.45 24.87 4.69 0.59
Burner 4
(S004)
Turbine/Duct 5.05 5.05 0.92 61.46 25.32 4.36 0.55
Burner 5
(S005)
Emergency 0.42
Gen. (S006)
Cooling Tower 5.4 5.4
(S011)
I
Total 31.78 31.78 4.68 334.29 120.06 22.78 2.86
Actual emissions are based on the APENS submitted on March 31, 2010 (2009 data).
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
Page 3
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. There are diesel-fired engines
driving an emergency generator and fire pump included in Section II of the permit. Both
engines are considered emergency engines. According to the current permit, these
engines commenced operation in May 1994, so they are existing engines and are
subject to requirements in MACT ZZZZ. Since these engines are considered
emergency engines they are 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 renewal permit.
Compliance Assurance Monitoring (CAM) Applicability
CAM was reviewed for this facility during the first renewal (issued October 1, 2006). At
that time it was determined that CAM did not apply to the turbines, since the Title V
permit specified a continuous monitoring method for NOx (per 40 CFR Part 64 §
64.2(b)(1)(vi)) and there were no other emission units equipped with a control device.
Since there have been no physical changes to the existing emissions units and no new
units added since the first renewal, there is no change to the CAM applicability at this
facility.
III. Discussion of Modifications Made
Source Requested Modifications
The source submitted their renewal application on May 17, 2010. In their renewal
application, the source did not request any changes to their permit.
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
Page 4
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 Thermo Ft. Lupton Cogeneration
Facility 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
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
• Changed the citation for the definition of 8-hour ozone control area in Condition
1.1.
• Condition 2 (alternative operating scenario for turbine replacement) was revised
to clarify that only temporary turbine replacement is allowed (the phrase "and
permanent" was removed from the first line in the first paragraph under Condition
2).
Section 11.2 — Emergency Generator
• Added the appropriate 40 CFR Part 63 Subpart ZZZZ requirements —
management practices (oil and filter change, inspect air cleaner and inspect
hoses and belts). Note that the Subpart ZZZZ requirements are included in
"new" Section 11.6.
• 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.
Page 5
Section 11.3 — Diesel Fired Emergency Fire Pump
• Corrected the references to other condition numbers in Conditions 3.4.1 and
3.4.5.
• Added the appropriate 40 CFR Part 63 Subpart ZZZZ requirements —
management practices (oil and filter change, inspect air cleaner and inspect
hoses and belts). Note that the Subpart ZZZZ requirements are included in
"new" Section 11.6.
• Added the appropriate 40 CFR Part 63 Subpart A requirements
As indicated above for the emergency generator, only the prohibition and
circumvention requirements in § 63.4 will be included in the permit.
Section III —Acid Rain Requirements
• Revised the table in Section 2 to include calendar years corresponding to the
relevant permit term for the renewal.
Section V— General Conditions
• Revised the version date.
• Labeled the 3rd paragraph of General Condition 29.a as 29.b and added the
provisions in Reg 7, Section III.C as paragraph e.
Appendices
• Corrected minor typos in the tables in Appendices B and C
Page 6
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Colorado Department
of Public Health
and Environment
OPERATING PERMIT
Thermo Cogeneration Partnership, L. P., a Delaware
Limited Partnership - Ft. Lupton Cogeneration Facility
First Issued: January 1 , 1999
Renewed: DRAFT
AIR POLLUTION CONTROL DIVISION
COLORADO OPERATING PERMIT
FACILITY NAME: Ft. Lupton OPERATING PERMIT NUMBER
Cogeneration Facility
FACILITY ID: 1230250 95OPWE096
RENEWED:
EXPIRATION DATE:
MODIFICATIONS: See Appendix F of Permit
Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et
sec. and applicable rules and regulations.
ISSUED TO: PLANT SITE LOCATION:
Thermo Cogeneration Partnership, L. P., 6811 Weld County Road 31
A Delaware Limited Partnership Ft. Lupton, CO 80621
1735 Nineteenth Street Weld County
Denver, CO 80202
INFORMATION RELIED UPON
Operating Permit Renewal Application
Received: May 17, 2010
And Additional Information Received: September 8, 2010
Nature of Business: Cogeneration
Primary SIC: 4911
RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON
Name: Paul Steinway Name: Richard Rhoads
Title: Managing Director Title: Facility Manager
Phone: (303) 857-8050 Phone: (303) 857-8052
SUBMITTAL DEADLINES
First Semi-Annual Monitoring Period: EXAMPLE (October 1 —December 31)
Subsequent Semi-Annual Monitoring Periods: EXAMPLE (January 1 —June 30, July 1 — December 31)
Semi-Annual Monitoring Reports: EXAMPLE (Feb. 1, 2007 & Aug. 1, 2007 & subsequent years)
First Annual Compliance Period: EXAMPLE (October 1 —December 31)
Subsequent Annual Compliance Periods: EXAMPLE (January 1 - December 31)
Annual Compliance Certification: EXAMPLE (February 1, 2007 & subsequent years)
Note that the Semi-Annual Monitoring Reports and Annual Compliance Certifications must be received
at the Division office by 5:00 p.m. on the due date. Postmarked dates will not be accepted for the
purposes of determining the timely receipt of those reports/certifications.
TABLE OF CONTENTS:
SECTION I - General Activities and Summary 1
1. Permitted Activities 1
2. Alternative Operating Scenarios (10/1/05 version) 2
3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant
Deterioration (PSD) 4
4. Accidental Release Prevention Program (112(r)) 4
5. Compliance Assurance Monitoring (CAM) 4
6. Summary of Emission Units 5
SECTION II - Specific Permit Terms 6
1. S001-S005 - Five (5) Natural Gas Fired Turbines (400 MMBtu/hr (HHV) each) W/ Duct
Burners (2 @ 240 MMBtu/hr (HHV) and 3 @ 180 MMBtu/hr (HHV)) 6
2. S006 - One (1) Diesel Fired Emergency Generator (8.57 MMBtu/hr) 18
3. S007 - One(1) Diesel Fired Emergency Fire Pump (2.28 MMBtu/hr) 21
4. S011 - One (1) Forced Draft Water Cooling Tower w/ Drift Eliminators 23
5. Continuous Emission Monitoring Requirements 24
6. National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating
Internal Combustion Engines (40 CFR Part 63 Subpart ZZZZ) 28
SECTION III - Acid Rain Requirements 33
1. Designated Representative and Alternate Designated Representative 33
2. Sulfur Dioxide Emission Allowances and Nitrogen Oxide Emission Limitations 33
3. Standard Requirements 34
4. Reporting Requirements 37
5. Comments, Notes and Justifications 38
SECTION IV - Permit Shield 39
1. Specific Non-Applicable Requirements 39
2. General Conditions 39
3. Streamlined Conditions 40
SECTION V - General Permit Conditions 41
1. Administrative Changes 41
2. Certification Requirements 41
3. Common Provisions 41
4. Compliance Requirements 45
5. Emergency Provisions 46
6. Emission Controls for Asbestos 46
7. Emissions Trading, Marketable Permits, Economic Incentives 46
8. Fee Payment 47
9. Fugitive Particulate Emissions 47
10. Inspection and Entry 47
11. Minor Permit Modifications 47
12. New Source Review 47
13. No Property Rights Conveyed 48
14. Odor 48
15. Off-Permit Changes to the Source 48
16. Opacity 48
TABLE OF CONTENTS:
17. Open Burning 48
18. Ozone Depleting Compounds 48
19. Permit Expiration and Renewal 48
20. Portable Sources 49
21. Prompt Deviation Reporting 49
22. Record Keeping and Reporting Requirements 49
23. Reopenings for Cause 50
24. Section 502(6)(10) Changes 51
25. Severability Clause 51
26. Significant Permit Modifications 51
27. Special Provisions Concerning the Acid Rain Program 51
28. Transfer or Assignment of Ownership 51
29. Volatile Organic Compounds 52
30. Wood Stoves and Wood burning Appliances 52
APPENDIX A - Inspection Information 1
Directions to Plant: 1
Safety Equipment Required 1
Facility Plot Plan: 1
List of Insignificant Activities 1
APPENDIX B 1
Reporting Requirements and Definitions 1
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
Format for Annual Compliance Certification Reports 1
APPENDIX D 1
Notification Addresses 1
APPENDIX E 1
Permit Acronyms 1
APPENDIX F 1
Permit Modifications
•
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 1
SECTION I - General Activities and Summary
1. Permitted Activities
1.1 This facility consists of a cogeneration facility defined under Standard Industrial Classification
4911. Electricity for sale is produced by five (5) combustion turbines, equipped with duct
burners. Each combustion turbine serves a generator rated at 57.412 MW (name-plate),
however, each turbine only generates enough horsepower to produce about 37 MW. Exhaust gas
from the combustion turbine, which may be heated further by duct burners, is used to either
generate electricity or to heat a nearby tomato greenhouse. There are two steam turbines, each
rated at 52.220 MW (name-plate). Other significant emission units at this facility are a cooling
tower, emergency back-up generator and fire pump.
The facility is located in Weld County at 6811 Weld County Road 31, in Ft. Lupton, CO. 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-hour Ozone Control Area
as defined in Colorado Regulation No. 7, Section II.A.1.
There are no affected states within 50 miles of the plant. The following Federal Class I
designated areas are within 100 kilometers of the plant: Rocky Mountain National Park.
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 the
purposes of this operating permit and shall survive reissuance. This permit incorporates the
applicable requirements (except as noted in Section II) from the following construction permits:
91WE667, 92WE1488-1, 92WE1488-2 and 96WE075.
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 11 - Condition 1.13.1 (opacity), Section V - Conditions 3.d, 3.g (last paragraph), 14 and
18 (as noted).
1.5 All information gathered pursuant to the requirements of this permit is subject to the
Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions
in Section V of this permit.
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit# 95OPWE096 Page 2
2. Alternative Operating Scenarios (10/1/05 version)
The following Alternative Operating Scenario (AOS) for temporary combustion turbine replacement and
turbine component replacement has been reviewed in accordance with the requirements of Regulation
No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios, and Regulation
No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source Non-
Attainment Area New Source Review and Prevention of Significant Deterioration (NANSR) and has
been found to meet all applicable substantive and procedural requirements. This permit incorporates
and shall be considered a Construction Permit for any combustion turbine replacement performed in
accordance with this AOS, and the permittee shall be allowed to perform such turbine or turbine
component replacement without applying for a revision to this permit or obtaining a new Construction
Permit.
2.1 Routine Turbine Component Replacements
2.1.1 The following physical or operational changes to the turbines in this permit are not
considered a modification for purposes of NSPS GG, NANSR/PSD, or Regulation
No. 3:
2.1.1.1 Replacement of stator blades, turbine nozzles, turbine buckets, fuel
nozzles, combustion chambers, seals, and shaft packings, provided that
they are of the same design as the original.
2.1.1.2 Changes in the type or grade of fuel used, if the original gas turbine
installation, fuel nozzles, etc. were designed for its use.
2.1.1.3 An increase in the hours of operation (unless limited by a permit
condition).
2.1.1.4 Variations in operating loads within the turbine design specification.
2.1.1.5 Any physical change constituting routine maintenance, repair or
replacement.
2.1.2 Turbines undergoing any of the above changes are subject to all federally applicable
and state-only requirements set forth in this permit (including monitoring and record
keeping), and shall be subject to any shield afforded by this permit. If replacement of
any of the components listed in Conditions 2.1.1.1 or 2.1.1.5 above results in a
change in serial number for the turbine, a letter explaining the action as well as a
revised APEN and appropriate filing fee shall be submitted to the Division within 30
days of the replacement.
2.1.3 Note that the repair or replacement must be genuinely the same design. Except in
accordance with the Alternative Operating Scenario set forth below, the Division does
not consider that this allows for the entire replacement (or reconstruction) of an
existing turbine with an identical new one or one similar in design or function.
Rather, the Division considers the repair or replacements to encompass the repair or
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
•
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 3
replacement of components at a turbine with the same (or functionally similar)
components.
2.2 Temporary Turbine Replacement
The following AOS is incorporated into this permit in order to deal with a turbine breakdown or
periodic routine maintenance and repair of an existing onsite turbine that requires the use of a
temporary replacement turbine. "Temporary" is defined as in the same service for 270 operating
days or less in any 12 month period. The 270 days is the total number of days that the turbine is
in operation. If the turbine operates only part of a day, that day counts towards the 270 day total.
Note that the compliance demonstrations made as part of this AOS are in addition to any
compliance demonstrations required by this permit.
2.2.1 The permittee may temporarily replace an existing permitted turbine provided such
replacement turbines are General Electric, Model No. LM6000 combustion turbines
without modifying this permit, so long as the emissions from the temporary
replacement turbine comply with the emission limitations for the existing permitted
turbine as determined below.
In the absence of credible evidence to the contrary, data from the continuous emission
monitoring systems (CEMS) shall be evidence of enforceable compliance or
noncompliance of the replacement turbine with any short-term NOx and CO
emissions limitations of the original turbine.
For comparison with an annual NOx and CO emissions limit, data from the CEMS
shall be used to calculate the actual NOx and CO emissions as set forth in this permit.
If the data from the CEMS indicates compliance with both the NOx and CO emission
limitations, in the absence of credible evidence to the contrary, the source may certify
that the turbine is in compliance with both the NOx and CO emission limitations for
the relevant time period.
If the CEMS data fails to demonstrate compliance with any of the NOx or CO
emission limitations, and in the absence of credible evidence to the contrary, the
turbine will be considered to be out of compliance for the relevant time periods(s).
All data that indicates noncompliance shall be submitted to the Division within 14
calendar days after the data is collected.
2.2.2 Temporary replacement turbines are subject to all federally applicable and state-only
requirements set forth in this permit (including monitoring and record keeping), and
shall be subject to any shield afforded by this permit.
2.2.3 The permittee shall maintain a log on-site to contemporaneously record the start and
stop date of any temporary turbine replacement, the manufacturer and serial number
of the turbine(s) that are temporarily replaced during the term of this permit, and the
manufacturer and serial number of the replacement turbine.
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit# 95OPWE096 Page 4
2.3 Additional Sources
The replacement of an existing turbine with a new turbine is viewed by the Division as the
installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is
therefore essentially an advanced construction permit review. The AOS cannot be used for
additional new emission points for any site; a turbine that is being installed as an entirely new
emission point and not as part of an AOS-approved replacement of an existing onsite turbine has
to go through the appropriate Construction/Operating permitting process prior to installation.
3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant Deterioration
(PSD)
3.1 This facility is categorized as a NANSR major stationary source (Potential to Emit of NOx >100
tons/year). Future modifications at this facility resulting in a significant net emissions increase
(see 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 or either VOC or NOx) may result in the
application of the NANSR review requirements.
3.2 This facility is categorized as a PSD major stationary source (Potential to Emit > 100 tons/yr) for
NOx and CO. Future modifications at this facility resulting in a significant net emissions
increase (see Regulation 3, Part D, Section II.A.26 and 42) for any pollutant as listed in
Regulation No. 3, Part D, Section II.A.42 for which the area is in attainment or
attainment/maintenance or a modification which is major by itself may result in the application
of the PSD review requirements.
3.3 There are no other Operating Permits associated with this facility for purposes of determining
applicability of NANSR and PSD review regulations.
4. Accidental Release Prevention Program (112(r))
4.1 Based on the information provided by the applicant, this facility is not subject to the provisions
of the Accidental Release Prevention Program (section 112(r) of the Federal Clean Air Act).
5. Compliance Assurance Monitoring (CAM)
5.1 The following emission points at this facility use a control device to achieve compliance with an
emission limitation or standard to which they are subject and have pre-control emissions that
exceed or are equivalent to the major source threshold. They are therefore subject to the
provisions of the CAM program as set forth in 40 CFR Part 64, as adopted by reference in
Colorado Regulation No. 3, Part C, Section XIV:
The turbines are not subject to CAM since at the time the CAM plan was required the Title V
permit specified a continuous compliance determination method (40 CFR Part 64 §
64.2(b)(1)(vi), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV).
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
•
' Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit# 95OPWE096 Page 5
6. Summary of Emission Units
6.1 The emissions units regulated by this permit are the following:
Emission AIRS Facility Description Startup Date Pollution
Unit Stack Identifier Control Device
Number Number
SOOT- 001-005 G001- Five (5) General Electric LM6000 Natural Gas May 1994 Steam Injection
S005 G005 Combustion Turbines, Rated at 400 MMBtu/hr Technology
(HHV) Each, SN's: 185-130, 185-126, 185-135, (Turbines)
185-136 and 185-137, Equipped with Five (5) Coen
12408-1 Duct Burners, Two (2) Rated at 240
MMBtu/hr (HHV) and Three (3) Rated at 180
MMBtu/hr(HHV).
S006 006 P006 One Detroit Diesel 8163-7416 Emergency Back-up May 1994 Uncontrolled
Engine, Rated at 8.57 MMBtu/hr, SN: Unknown.
S007 007 P007 One Clark DDFP-T6AT Emergency Diesel Fired May 1994 Uncontrolled
Fire Pump, Rated at 2.28 MMBtu/hr, SN: Unknown
S011 009 P011 One Custom Forced Draft Industrial Cooling Tower May 1994 Drift
Equipped with Munters D15 Drift Eliminators. Eliminators
Operating Permit Number: 95OPWF096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit# 95OPWE096 Page 6
SECTION II - Specific Permit Terms
1. S001-S005 - Five (5) Natural Gas Fired Turbines (400 MMBtu/hr (HHV) each) W/ Duct Burners
(2 @ 240 MMBtu/hr (HHV) and 3 @ 180 MMBtu/hr (HHV))
Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
BACT 1.1 N/A N/A N/A See Condition 1.1.
Requirements
PM 1.2 N/A Each Unit Turbine: Recordkeeping Monthly
(turbine plus 0.0066 lb/MMBtu and Calculations
duct burner): Duct Burner:
16.81 tons/year 0.005 Ib/MMBtu
All Units
Combined:
84.05 tons/year
Each Turbine: 0.105 lb/mmBtu N/A Fuel Restriction Only Pipeline
Each Turbine/Duct Burner(240 Natural Gas
mmBtu/hr): 0.1 1 1 lb/mmBtu is Used as
Each Turbine/Duct Burner(ISO Fuel
mmBtu/hr): 0.113 lb/mmBtu
PM10 N/A Each Unit Turbine: Recordkeeping Monthly
(turbine plus 0.0066 lb/MMBtu and Calculation
duct burner): Duct Burner:
16.81 tons/year 0.005 lb/MMBtu
All Units
Combined:
84.05 tons/year
SO2 1.3 NA Each Unit N/A 40 CFR Part 75, As specified
(turbine plus Appendix D in 40 CFR
duct burner): Part 75,
2.00 tons/year Appendix D
All Units
Combined:
10.00 tons/year
Each Turbine: N/A Fuel Restriction See
150 ppmvd @ 15%O2 OR Use of Condition
Fuel Which Contains Less than 0.8 1.3.
Weight%Sulfur
Each Turbine: N/A
0.35 lbs/MMBtu
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
• Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 7
Parameter Permit Limitations Compliance Monitoring
Condition short Term Long Term Emission Factor Method Interval
Number
NOx 1.4. NA Each Unit N/A Continuous Continuously
(turbine plus Emission
duct burner): Monitoring
146.5 tons/year System
All Units
Combined:
589.0 tons/year
25 ppmvd @ 15%O2, on a daily
average, except as provided for
below:
During Startup and Shutdown: 38
lbs per event
Each Turbine Only:
126.9 ppmvd at 15%O2
CO 1.5. NA Each Unit N/A Continuous Continuously
(turbine plus Emissions
duct burner): Monitoring
90.51 tons/year System
All Units
Combined:
452.55 tons/year
25 ppmvd @ 15%O2, on a daily
average, except as provided for
below:
During Startup and Shutdown: 25
lbs per event
VOC 1.6 Each Unit Each Unit Turbine: See Condition 1.6.
(turbine plus (turbine plus 0.00564
duct burner): duct burner): lb/MMBtu
3.63 lbs/hr 9.64 tons/year Duct Burner:
All Units 0.00564
Combined: lb/MMBtu
48.2 tons/year
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit# 95OPWE096 Page 8
Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
Natural Gas 1.7 N/A All Turbines N/A Fuel Meters Duct
Consumption Combined: Burners:
10,375 Daily
MMscf/year Turbines:
All Duct Monthly
Burners
Combined:
4,575
MMscf/year
Continuous I.S. N/A N/A N/A See Condition 1.8.
Emission
Monitoring
System
Requirements
Duct Burners: 1.9. Determination of Annual Capacity N/A Monthly Monthly
NSPS Factor
Recordkeeping
Requirements
Sulfur Content 1.10. N/A N/A NA See Condition 1.10.
of Fuel
Btu Content of 1.11. NA NA NA ASTM Analysis Semi-
Fuel Method Annually
NSPS General 1.12. NA NA NA As required in the Subject to
Provisions NSPS General NSPS
Provisions General
Provisions
Opacity 1.13 State Only Requirement: Not to N/A See Condition 1.13.
Exceed 20%
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
Acid Rain 1.14 See Section Ill of this Permit Certification Annually
Requirements
1.1 The combustion turbines and 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
Emissions (PM and PMio) and Volatile Organic Compounds (VOC). BACT has been
determined as follows:
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
•
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 9
1.1.1 BACT for NOx has been determined to be enhanced steam injection technology and
emission limits as identified in Condition 1.4.2 (Colorado Construction Permit
91WE667).
1.1.2 BACT for CO has been determined to be use of good combustion practices and the
emission limits as identified in Condition 1.5.2 (Colorado Construction Permit
91 WE667).
1.1.3 BACT for PM and PMio has been determined to be use of pipeline natural gas as fuel,
as defined in Condition 1.10 (Colorado Construction Permit 91WE667).
1.1.4 BACT for VOC has been determined to be use of good combustion practices, use of
pipeline natural gas as fuel, as defined in Condition 1.10, and the emission limits
identified in Condition 1.6.2 (Colorado Construction Permit 91WE667, as modified
under the provisions of Section I, Condition 1.3 to identify VOC BACT
determination).
1.2 Particulate Matter Emissions are subject to the following requirements:
1.2.1 Annual emissions of PM and PMio from each turbine/duct burner combination
AND from all turbine/duct burner combinations combined shall not exceed the
limitations stated above (Colorado Construction Permit 91WE667). Emissions from
each emission unit shall be calculated by the end of the subsequent month using the
above emission factors (for turbine, from AP-42, Section 3.1 (dated April 2000),
Table 3.1-2a, for duct burners, from manufacturer, as indicated in September 13,
1991 memo from Nooter/Eriksen Cogeneration Systems, Inc.), the monthly natural
gas consumption and the higher heating value of the fuel (see Condition 1.11) in the
following equations:
Turbine:
tons/month=(EF, lbs/MMBtu)x(Fuel Use, MMSCF/mo) x(Heat Content of Fuel, MMBtu/MMSCF)
2000 lbs/ton
Duct Burner:
tons/month=(EF, lbs/MMBtu)x(Fuel Use,MMSCF/mo)x(Heat Content of Fuel, MMBtu/MMSCF)
2000 lbs/ton
Monthly emissions from each turbine and duct burner will be summed together and
used in a twelve month rolling total to monitor compliance with the individual unit
annual emission limitation. Each month a new twelve month rolling total shall be
calculated using the previous twelve months' data.
Monthly emissions from each turbine and duct burner combination will be summed
together and used in a twelve month rolling total to monitor compliance with the
annual emission limitation for all units combined. Each month a new twelve month
rolling total shall be calculated using the previous twelve months' data.
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit# 95OPWE096 Page 10
1.2.2 Particulate Matter (PM) emissions from each turbine and each turbine/duct
burner combination shall not exceed the above limitations (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 since only
pipeline natural gas that meets the requirements in Condition 1.10 is permitted to be
used as fuel in the turbines and the duct burners.
The numeric PM standards were determined as follows:
For simple cycle operation or combined cycle operation without supplemental fuel
(turbine only) the standard was determined using the design heat input for the turbine
(400 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
For combined cycle operation with supplemental fuel (turbine and duct burner), the
standard was determined using the design heat input for the turbine (400 mmBtu/hr)
and the duct burner(240 mmBtu/hr or 180 mmBtu/hr) in the following equation:
PE (turbine/duct burner) = PET x FIT + PEN) x FINE
FIT + FIoB
1.3 Sulfur Dioxide (SO2) emissions shall not exceed the following limitations:
1.3.1 Annual emissions of SO2 from each turbine/duct burner combination AND from
all turbine/duct burner combinations combined shall not exceed the limitations
stated above (Colorado Construction Permit 91WE667). Compliance with the annual
SO2 emission limitations shall be monitored using the monitoring method specified in
40 CFR Part 75 Appendix D.
Monthly emissions from each turbine and duct burner will be summed together and
used in a twelve month rolling total to monitor compliance with the individual unit
annual emission limitation. Each month a new twelve month rolling total shall be
calculated using the previous twelve months' data.
Monthly emissions from each turbine/duct burner combination will be summed
together and used in a twelve month rolling total to monitor compliance with the
annual emission limitation for all units combined. Each month a new twelve month
rolling total shall be calculated using the previous twelve months' data.
1.3.2 Each turbine shall meet one of the following requirements:
1.3.2.1 Sulfur Dioxide (SO2) emissions from the turbine shall not exceed 150
ppmvd at 15% O2,
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit# 95OPWE096 Page 11
OR
1.3.2.2 No fuel, which contains sulfur in excess of 0.8 percent by weight, shall be
used in this combustion turbine (40 CFR Part 60 Subpart GG §§ 60.333(a)
& (b), as adopted by reference in Colorado Regulation No. 6, Part A).
In the absence of credible evidence to the contrary, compliance with the above
requirements is presumed since only pipeline natural gas is permitted to be used as
fuel. The pipeline natural gas used as fuel shall meet the requirements in Condition
1.10.
1.3.3 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 natural gas that
meets the requirements in Condition 1.10 is permitted to be used as fuel in each
turbine.
1.4 Nitrogen Oxide (NOx) emissions shall not exceed the following:
1.4.1 Annual emissions of NOx from each turbine/duct burner combination AND from
all turbine/duct burner combinations combined shall not exceed the limitations
stated above (Colorado Construction Permit 91 WE667). Monthly emissions from
each turbine/duct burner combination shall be determined using the continuous
emission monitoring system required by Condition 1.8.
Monthly emissions from each turbine/duct burner combination shall be used in a
twelve month rolling total to monitor compliance with the individual unit annual
emission limitation. Each month a new twelve month rolling total shall be calculated
using the previous twelve months' data.
Monthly emissions from each turbine/duct burner combination will be summed
together and used in a twelve month rolling total to monitor compliance with the
annual emission limitation for all units combined. Each month a new twelve month
rolling total shall be calculated using the previous twelve months' data.
1.4.2 For BACT purposes, NOx emissions from each turbine/duct burner combination
shall not exceed the following limitations (Colorado Construction Permit 91WE667,
as modified under the provisions of Section I, Condition 1.3 and Colorado Regulation
No. 3, Part C, Sections I.A.7 and III.B.7 to include alternate BACT limits for periods
of startup and shutdown):
1.4.2.1 Except as provided for in Condition 1.4.2.2, NOx emissions shall not
exceed 25 ppmvd at 15% O2, on a daily average. Compliance with the
NOx BACT limit shall be monitored using the CEMS required by
Condition 1.8. Except as provided for in Condition 1.4.2.2, the daily
average shall be determined using all operating hours during every
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit# 95OPWE096 Page 12
midnight to midnight period. This includes any partial hours as described
in Condition 1.4.2.2 below.
1.4.2.2 During periods of startup and shutdown, NOx emissions shall not exceed
38 lbs during each startup and/or shutdown event. Compliance with the
startup and shutdown NOx BACT limits shall be monitored using the
CEMS required by Condition 1.8. All CEMS data points within the
startup and/or shutdown period shall be summed together to determine the
NOx emissions for each startup and/or shutdown event.
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 data
points within that clock hour shall be included in the daily average
required by Condition 1.4.2.1.
1.4.2.3 "Startup" means the setting in operation of any air pollution source for any
purpose. Setting in operation for these turbines begins when fuel is
injected into the turbine. Setting in operation for these turbines ends when
the turbine reaches 15 MW or steam injection is initiated, whichever
comes first.
1.4.2.4 "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 by the turbine operator to shutdown
the unit and ends when fuel is no longer being fired in the turbine.
1.4.3 Nitrogen Oxide (NOx) Emissions from each turbine shall not exceed 126.9 ppmvd
at 15% O2, on a 4-hour rolling average (40 CFR Part 60 Subparts GG §§ 60.332(a)(1)
and 60.334(j)(1)(iii)(A), as adopted by reference in Colorado Regulation No. 6, Part
A). Compliance with the NOx limitation shall be monitored using the continuous
emission monitoring system required by Condition 1.8. The permittee has elected to
not correct emissions to International Organization for Standardization (ISO) standard
day conditions as allowed in Condition 5.3.
Note that the NOx emission limitations are not applicable during times of startup,
shutdown and malfunction. However, those instances during startup, shutdown and
malfunction when the NOx limitation is exceeded shall be identified in the Excess
Emission Report required in Condition 5.4.
For purposes of the reports required by Condition 5.4, the following applies:
1.4.3.1 Excess emissions shall be reported for all periods of unit operation,
including startup, shutdown and malfunction (40 CFR Part 60 Subpart GG
§ 60.334(j)).
1.4.3.2 An hour of excess emissions shall be any unit operating hour (any clock
hour during which fuel is combusted) in which the 4-hour rolling average
NOx concentration exceeds the applicable emission limit in Condition
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit# 95OPWE096 Page 13
1.4.3. For the purposes of 40 CFR Part 60 Subpart GG, a "4-hour rolling
average NOx concentration" is the arithmetic average of the average NOx
concentration measured by the CEMS for a given hour (corrected to 15
percent O2) and the three unit operating hour average NOx concentrations
immediately preceding that unit operating hour (40 CFR Part 60 Subpart
GG § 60.334(j)(1)(iii)(A)).
1.4.3.3 A period of monitor downtime shall be any unit operating hour in which
sufficient data are not obtained to validate the hour, for either NOx
concentration or diluent (or both) (40 CFR Part 60 Subpart GG §
60.334(j)(1)(iii)(B)).
Note that since the permittee has elected to not correct emissions to ISO standard
ambient conditions, as allowed in Condition 5.3.3.1, ambient conditions at the time of
the excess emission period do not have to be reported as specified in 40 CFR Part 60
Subpart GG § 60.334(j)(1)(iii)(C).
1.5 Emissions of Carbon Monoxide (CO) shall not exceed the following limitations:
1.5.1 Annual emissions of CO from each turbine/duct burner combination AND from
all turbine/duct burner combinations combined shall not exceed the limitations
stated above (Colorado Construction Permit 91 WE667). Monthly emissions from
each turbine/duct burner combination shall be determined using the continuous
emission monitoring system required by Condition 1.8.
Monthly emissions from each turbine/duct burner combination shall be used in a
twelve month rolling total to monitor compliance with the individual unit annual
emission limitation. Each month a new twelve month rolling total shall be calculated
using the previous twelve months' data.
Monthly emissions from each turbine/duct burner combination will be summed
together and used in a twelve month rolling total to monitor compliance with the
annual emission limitation for all units combined. Each month a new twelve month
rolling total shall be calculated using the previous twelve months' data.
1.5.2 For BACT purposes, CO emissions from each turbine/duct burner combination
shall not exceed the following (Colorado Construction Permit 91 WE667, as provided
for under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3,
Part C, Sections I.A.7 and III.B.7 to include alternate BACT limits for periods of
startup and shutdown):
1.5.2.1 Except as provided for in Condition 1.5.2.2, CO emissions shall not
exceed 25 ppmvd at 15% O2, on a daily average. Compliance with the CO
BACT limit shall be monitored using the continuous emission monitoring
system required by Condition 1.8. Except as provided for in Condition
1.5.2.2, the daily average shall be determined using all operating hours
during every midnight-to-midnight period. This includes any partial hours
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 14
as described in Condition 1.5.2.2 below.
1.5.2.2 During periods of startup and shutdown, CO emissions shall not exceed 25
lbs during each startup and/or shutdown event. Compliance with the
startup and shutdown CO BACT limits shall be monitored using the
CEMS required by Condition 1.8. All CEMS data points within the
startup and/or shutdown period shall be summed together to determine the
CO emissions for each startup and/or shutdown event.
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 data
points within that clock hour shall be included in the daily average
required by Condition 1.5.2.1.
1.5.2.3 "Startup" shall have the same definition as provided for in Condition
1.4.2.3.
1.5.2.4 "Shutdown" shall have the same definition as provided for in Condition
1.4.2.4.
1.6 Volatile Organic Compound (VOC) emissions shall not exceed the following limitations:
1.6.1 Annual emissions of VOC from each turbine/duct burner combination AND from
all turbine/duct burner combinations combined shall not exceed the limitations
stated above (Colorado Construction Permit 91WE667). Emissions from each
emission unit shall be calculated by the end of the subsequent month using the above
emission factors (for turbines and duct burners, from turbine manufacturer, the
November 1997 performance test indicates emissions from both the turbine alone and
the turbine and duct burner together are well below this emission factor), the monthly
natural gas consumption and the higher heating value of the fuel (see Condition 1.11)
in the equations in Condition 1.2.1 of this permit.
Monthly emissions from each turbine and duct burner will be summed together and
used in a twelve month rolling total to monitor compliance with the individual unit
annual emission limitation. Each month a new twelve month rolling total shall be
calculated using the previous twelve months' data.
Monthly emissions from each turbine/duct burner combination will be summed
together and used in a twelve month rolling total to monitor compliance with the
annual emission limitation for all units combined. Each month a new twelve month
rolling total shall be calculated using the previous twelve months' data.
1.6.2 For BACT purposes, VOC emissions from each turbine/duct burner combination
shall not exceed 3.63 lbs/hr (Colorado Construction Permit 91WE667). In the
absence of credible evidence to the contrary, compliance with the VOC BACT limit
is presumed provided that the turbines and duct burners are operated and maintained
in accordance with manufacturer's recommendations and good engineering practices
and that the natural gas used as fuel meets the requirement in Condition 1.10.
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
•
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit# 95OPWE096 Page 15
1.7 Natural Gas consumption for the turbines and duct burners shall not exceed the limitations stated
above (Colorado Construction Permit 91WE667). Natural gas consumed by the turbines will be
monitored and recorded monthly using fuel meters and other records as necessary. Natural gas
consumed by the duct burners shall be recorded daily, as required by 40 CFR Part 60 Subpart Db
§ 60.49b(d), as adopted by reference in Colorado Regulation No. 6, Part A. Monthly quantities
of natural gas consumed by the turbines and duct burners shall be used in rolling twelve month
totals to monitor compliance with the annual limitations. Each month a new twelve month
rolling total shall be calculated using the previous twelve months' data.
1.8 Each exhaust stack shall be equipped with a continuous emission monitoring system to measure
and record the following:
1.8.1 Concentration of Oxides of Nitrogen corrected to 15 % oxygen, hourly average, 4-hr
rolling average (including periods of startup, shutdown and malfunction), daily
average (excluding startup and shutdown periods);
1.8.2 Emission rate of Oxides of Nitrogen, pounds per hour, pounds per startup, pounds per
shutdown, tons per month;
1.8.3 Concentration of Carbon Monoxide corrected to 15 % oxygen, hourly average, daily
average (excluding startup and shutdown periods);
1.8.4 Emission rate of Carbon Monoxide, pounds per hour, pounds per startup, pounds per
shutdown, tons per month;
1.8.5 Gross Turbine Output, in MW; and
1.8.6 Operating mode— startup, shutdown and/or standard operation.
The continuous emission monitoring systems shall meet the requirements in Condition 5 of this
permit. Monthly emissions of NOx and CO from the continuous emission monitoring system
shall be used as specified in Conditions 1.4.1 and 1.5,1 to monitor compliance with the annual
NOx and CO limitations.
1.9 Daily natural gas consumption records (Condition 1.7) shall be used to calculate the annual
capacity factor of each duct burner for each calendar month. 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). The annual capacity factor will be calculated
as the ratio between the actual heat input(HHV) to each duct burner for the preceding 12 months
and the potential heat input (HHV) to each duct burner calculated as 8,760 hours multiplied by
the duct burner heat input rates identified in Section I, Condition 6.1 (40 CFR Part 60 Subpart
Db §60.41, as adopted by reference in Colorado Regulation No. 6, Part A).
1.10 The permittee shall maintain records demonstrating that the natural gas burned has a total sulfur
content less than 0.5 grains/100 SCF. Natural gas that meets this sulfur limitation is considered
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 16
pipeline natural gas as defined in 40 CFR Part 72. The demonstration shall be made using any of
the methods identified in 40 CFR Part 75 Appendix D, Section 2.3.1.4.(a). These records shall
be made available to the Division upon request.
1.11 The Btu content of natural gas used to fuel the turbines and duct burners shall be determined
semi-annually using the appropriate ASTM Methods or equivalent, if approved by the Division
in advance. Calculation of annual emissions outlined under Conditions 1.2.1, 1.3.1 and 1.6.1
shall be based on the most recent Btu analysis. The Btu content shall be based on the higher
heating value (HHV) of the fuel. In lieu of semi-annual sampling and analysis, the Btu content
of the gas may be determined based on the monthly average of the supplier's analyses, provided
that the analyses were conducted using the appropriate ASTM Methods, or equivalent, if
approved by the Division in advance.
1.12 Regulation No. 6, Part A, Subpart A, General Provisions apply as follows:
1.12.1 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. (40 CFR Part 60 Subpart A §
60.12, as adopted by reference in Colorado Regulation No. 6, Part A).
1.12.2 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 (40 CFR Part 60 Subpart A § 60.11(d), as
adopted by reference in Colorado Regulation No. 6, Part A).
1.13 The turbines and duct burners are subject to the following opacity requirements:
1.13.1 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 and 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
Condition 1.13.3 during periods of building of a new fire, cleaning of fire boxes, soot
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 17
blowing, process modifications and adjustment or occasional cleaning of control
equipment.
1.13.2 Except as provided for in Condition 1.13.3 below, no owner or operator of a source
shall allow or cause the emission into the atmosphere of any air pollutant which is in
excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). This opacity
standard applies to each turbine and duct burner.
1.13.3 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). This opacity standard applies to each
turbine and duct burner
In the absence of credible evidence to the contrary, each turbine and duct burner shall be
presumed to be in compliance with the above opacity requirements since only pipeline natural
gas is permitted to be used as fuel.
1.14 Each turbine/duct burner combination is 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 a complete
and segregable portion of the Operating Permit. As such the requirements are found in Section
III of this permit.
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 18
2. S006 - One (1) Diesel Fired Emergency Generator(8.57 MMBtu/hr)
Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
NOx 2.1 NA 3.81 tons/yr 0.42 lb/gallon Recordkeeping Monthly
and Calculations
No. 2 Diesel 2.2 NA 16,250 N/A Fuel Log Monthly
Fuel gal Ions/yr
Consumption
SO2 2.3 Not to Exceed 0.8 lbs/mmBtu N/A Fuel Restriction See
Condition
2.3.
Fuel Sampling 2.4 N/A I N/A N/A ASTM Methods Annually
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
Opacity 2.7 Not to Exceed 20%Except as N/A EPA Method 9 See
Provided for Below Condition 2.7
For Startup—Not to Exceed 30%,
for a Period or Periods
Aggregating More than Six(6)
Minutes in any 60 Consecutive
Minutes
2.1 NOx emissions from the engine shall not exceed the limitations stated above (Colorado
Construction Permit 91 WE1488-1, as modified under the provisions of Section I, Condition 1.3
to remove short-term (lbs/hr) emission limits). Monthly emissions shall be calculated by the end
of the subsequent month using the above emission factor (AP-42, Section 3.4 (dated 10/96),
Table 3.4-1, converted to lb/gal based on a diesel fuel heat content of 131,890 Btu/gal) and the
monthly fuel consumption in the equation below:
tons/month=EF(1b/gallon) x Monthly Usage (gallons/month)
2000 lbs/ton
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.
2.2 Number 2 diesel fuel consumption shall not exceed the limitations above (Colorado Construction
Permit 91 WE1488-1, as modified under the provisions of Section I, Condition 1.3 to specify No.
2 diesel fuel as opposed to No. 1 diesel fuel as indicated in the construction permit). Each time
fuel is added to the generator service tank the amount shall be recorded in a log. This log shall
be left on site and made available to the Division upon request. On the first day of the month,
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 19
monthly fuel consumption for the previous month shall be determined using the aforementioned
log. Monthly quantities of fuel consumed shall be used in a twelve month rolling 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.
2.3 Emissions of SO2 from the engine shall not exceed the limitation stated above (Colorado
Regulation No. 1, Section VI.B.4.b.(i)). In the absence of credible evidence to the contrary,
compliance with the above SO2 limitation shall be presumed provided the fuel sampling required
by Condition 2.4 demonstrates that the fuel has a sulfur content no greater than 0.79 % sulfur.
Note that this presumption is based on calculation using an emission factor of 1.01 S lbs/mmBtu.
The emission factor is from AP-42, Section 3.4, dated October 1996, Table 3.4-1.
2.4 Diesel fuel shall be sampled and analyzed annually, using the appropriate ASTM Methods, or
equivalent, if approved in advance by the Division to determine the weight percent sulfur of the
fuel. In lieu of sampling, vendor data may be used to determine the weight percent sulfur
provided sampling and analysis was performed using the appropriate ASTM methods.
2.5 This engine is subject to the requirements in 40 CF Part 63 Subpart ZZZZ, "National Emissions
Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion
Engines." The specific applicable requirements are included in Section II, Condition 6 of this
permit.
2.6 This engine is 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 1 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)
2.7 Opacity of emissions from this engine shall not exceed the following
2.7.1 Except as provided for in Condition 2.7.2 below, no owner or operator of a source
shall allow or cause the emission into the atmosphere of any air pollutant which is in
excess of 20% opacity (Colorado Regulation No. 1, Section I1.A.I).
2.7.2 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. I, Section II.A.4).
Compliance with these limitations shall be determined by conducting visual emission
observations in accordance with EPA Reference Method 9 as follows:
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 20
2.7.3 An engine startup period of less than 60 minutes shall not require a startup opacity
observation. If the engine startup period is greater than 60 minutes, one opacity
observation shall be made for each consecutive 4 hour period of startup during
daylight hours. In addition, a record shall be kept of the date and time the engine
started and when it was shutdown.
2.7.4 Continued operation of the engine after the completion of the startup period shall
require monthly opacity observations. If the startup and operation of the engine lasts
less than a total of 4 hours from engine start to engine stop, in any one day no opacity
observations are required for that day.
2.7.5 If no opacity observations are made pursuant to Conditions 2.7.3 and 2.7.4 above,
then an opacity observation shall be conducted annually.
2.7.6 All opacity observations shall be performed by an observer with current and valid
Method 9 certification.
2.8 This engine shall be operated and maintained in accordance with internal operating and
maintenance standards, which shall consider manufacturer's recommendations and industry
standard practices, at all times, including periods of start-up, shutdown, and malfunction. Such
internal operating and maintenance standards shall be kept on site and made available to the
Division upon request.
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 21
3. S007 - One (1) Diesel Fired Emergency Fire Pump (2.28 MMBtu/hr)
Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
No. 2 Diesel 3.I N/A 4,325 N/A Fuel Log Monthly
Fuel gal Ions/yr
Consumption
SO2 3.2 Not to Exceed 0.8 lbs/mmBtu NA Fuel Restriction See
Condition
3.2.
Fuel Sampling 3.3 N/A I N/A N/A ASTM Methods Annually
MACT ZZZZ 3.4 Change Oil and Filter N/A See Condition 3.4.
Requirements Inspect Air Cleaner
Inspect all Hoses and Belts
MACT General 3.5 N/A N/A N/A See Condition 3.5.
Provisions
Opacity 3.6 Not to Exceed 20%Except as N/A EPA Method 9 See
Provided for Below Condition
For Startup—Not to Exceed 30%, 3.6.
for a Period or Periods
Aggregating More than Six(6)
Minutes in any 60 Consecutive
Minutes
3.1 Number 2 diesel fuel consumption shall not exceed the limitations above (Colorado Construction
Permit 91WE1488-2, as modified under the provisions of Section I, Condition 1.3 to specify No.
2 diesel fuel as opposed to No. 1 diesel fuel as indicated in the construction permit). Each time
fuel is added to the fire pump service tank the amount shall be recorded in a log. This log shall
be left on site and made available to the Division upon request. On the first day of the month,
the monthly usage for the previous month shall be determined from the aforementioned log.
Monthly quantities of fuel consumed shall be used in a twelve month rolling 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.
3.2 Emissions of SO2 from the engine shall not exceed the limitation stated above (Colorado
Regulation No. 1, Section VI.B.4.b.(i)). In the absence of credible evidence to the contrary,
compliance with the above SO2 limitation shall be presumed provided the fuel sampling required
by Condition 2.4 demonstrates that the fuel has a sulfur content no greater than 0.79 % sulfur.
Note that this presumption is based on calculation using an emission factor of 1.01 S lbs/mmBtu.
The emission factor is from AP-42, Section 3.4, dated October 1996, Table 3.4-1.
3.3 Diesel fuel shall be sampled and analyzed annually, using the appropriate ASTM Methods, or
equivalent, if approved in advance by the Division to determine the weight percent sulfur of the
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit# 95OPWE096 Page 22
fuel. In lieu of sampling, vendor data may be used to determine the weight percent sulfur
provided sampling and analysis was performed using the appropriate ASTM methods.
3.4 This engine is subject to the requirements in 40 CF Part 63 Subpart ZZZZ, "National Emissions
Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion
Engines." The specific applicable requirements are included in Section II, Condition 6 of this
permit.
3.5 This engine is 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:
3.5.1 Prohibited activities in § 63.4(a).
3.5.2 Circumvention in § 63.4(b)
3.6 Opacity of emissions from this engine shall not exceed the following
3.6.1 Except as provided for in Condition 3.6.2 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).
3.6.2 No owner or operator of a source shall allow or cause to be emitted into the
atmosphere any air pollutant resulting from 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. I, Section II.A.4).
Compliance with these limitations shall be determined by conducting visual emission
observations in accordance with EPA Reference Method 9 as follows:
3.6.3 An engine startup period of less than 60 minutes shall not require a startup opacity
observation. If the engine startup period is greater than 60 minutes, one opacity
observation shall be made for each consecutive 4 hour period of startup during
daylight hours. In addition, a record shall be kept of the date and time the engine
started and when it was shutdown.
3.6.4 Continued operation of the engine after the completion of the startup period shall
require monthly opacity observations. If the startup and operation of the engine lasts
less than a total of 4 hours from engine start to engine stop, in any one day no opacity
observations are required for that day.
3.6.5 If no opacity observations are made pursuant to Conditions 3.6.3 and 3.6.4 above,
then an opacity observation shall be conducted annually.
3.6.6 All opacity observations shall be performed by an observer with current and valid
Method 9 certification.
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 23
3.7 This engine shall be operated and maintained in accordance with internal operating and
maintenance standards, which shall consider manufacturer's recommendations and industry
standard practices, at all times, including periods of start-up, shutdown, and malfunction. Such
internal operating and maintenance standards shall be kept on site and made available to the
Division upon request.
4. SD!! - One (1) Forced Draft Water Cooling Tower w/ Drift Eliminators
Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
PM 4.1 N/A 9.5 tons/yr See Condition 4.1. Recordkeeping Monthly
PM1p N/A 9.5 tons/yr and Calculations
Water 4.2 N/A 46,680 N/A Pump Run Time Monthly
Circulation MMgal/yr
Total Dissolved 4.3 N/A NA N/A Laboratory Monthly
Solids Analysis Analysis
Opacity 4.4 Not to Exceed 20% N/A See Condition 4.4.
4.1 PM and PMte emissions the cooling tower shall not exceed the limitations stated above
(Colorado Construction Permit 96WE075, as modified under the provisions of Section I,
Condition 1.3 to remove short-term (lbs/hr) emission limits). Monthly emissions shall be
calculated by the end of the subsequent month using the following equation:
PM=PM11,(Tons/mo)=Q x d x%drift x 31.3%drift dispersed x Total Solids Concentration
2000 lbs/ton
Where: Q=water circulated, gal/yr-to be determined by Condition 4.2
d=density of water, lbs/gal(from APCD preliminary analysis for const. permit d= 8.34 lbs/gal)
%drift=0.003 %(from APCD preliminary analysis for const. permit)
31.3% drift dispersed (from EPA-600/7-79-251a, November 1979, AEffects of Pathogenic and
Toxic Materials Transported Via Cooling Device Drift - Volumel -Technical Report, Page 63)
Total Solids Concentration = total solids concentration, in ppm (lbs solids/106 lbs water) - to be
determined by Condition 4.3.
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.
4.2 Circulation of water shall not exceed the limitations above (Colorado Construction Permit
96WE075 as modified under the provisions of Section I, Condition 1.3 to remove short-term
(gal/hr) throughput limits). Water circulation shall be determined each month by multiplying the
hours of operation of each pump by the design flow rate of each pump as follows:
Water Circulation Rate =hours of operation (hrs/yr) x Design Flow Rate (Gal/min) x 60 min/hr
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 24
Monthly quantities of water circulated shall be used in a twelve month rolling total to monitor
compliance with the annual limitations. Each month a new twelve month rolling total shall be
calculated using the previous twelve months data.
4.3 Samples of water circulated through the tower shall be taken and analyzed monthly to determine
the total solids concentration (Colorado Construction Permit 96WE075). Calculation of
emissions outlined under Condition 4.1 shall be based on the most recent total solids
concentration analysis. A copy of the procedures used to obtain and analyze samples shall be
maintained and made available to the Division upon request.
4.4 Opacity of emissions from the cooling 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 towers are operated and
maintained in accordance with the manufacturers' recommendations and good engineering
practices.
4.5 The cooling tower shall be operated and maintained in accordance with manufacturer's
recommendations at all times, including periods of start-up, shutdown and malfunction.
5. Continuous Emission Monitoring Requirements
Note that the continuous emission monitoring requirements identified in this Condition are in addition to
the continuous emission monitoring requirements required by the Acid Rain Program, which are
identified in Section III of this permit.
5.1 Equipment and QA/QC Requirements
5.1.1 The continuous emission monitoring systems are subject to the following
requirements:
5.1.1.1 Except as provided for below, the CO monitors are subject to the
applicable requirements of 40 CFR Part 60 (Colorado Construction Permit
91 WE667). The monitoring systems shall meet the equipment,
installation and performance specifications of 40 CFR Part 60 Appendix
B, Performance Specification 4/4A. These CEMS are subject to the
quality assurance/quality control requirements in 40 CFR Part 60
Appendix F and Subpart A § 60.13.
a. The CO CEMS data shall meet the applicable "primary equipment
hourly operating requirements" for hourly average calculation
methodology specified in 40 CFR Subpart B § 75.10(d)(1).
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.
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
• Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 25
c. Relative accuracy test audit (RATA) frequency will be determined
according to 40 CFR Part 75 Appendix B.
5.1.1.2 The NOx (and diluents) monitors are subject to the applicable
requirements of 40 CFR Part 75. The monitoring systems shall meet the
equipment, installation and performance specification requirements in 40
CFR Part 75, Appendix A. These CEMS shall meet the quality
assurance/quality control requirements in 40 CFR Part 75, Appendix B
and the conversion procedures of Appendix F. In addition, annual NOx
monitor RA testing will be performed in ppm @ 15% O2 measurement
units, and will be performed according to 40 CFR Part 60, Appendix B,
Specification 2. RATA testing frequency will be determined according to
40 CFR part 75, Appendix B.
5.1.2 Quality assurance/quality control plans shall be prepared for the continuous emission
monitoring systems as follows:
5.1.2.1 The quality assurance/quality control plan for the CO monitors shall be
prepared in accordance with the applicable requirements in 40 CFR Part
60, Appendix F.
5.1.2.2 The quality assurance/quality control plan for the NOx (and diluents)
monitors shall be prepared in accordance with the applicable requirements
in 40 CFR Part 75, Appendix B.
The quality assurance quality control plans shall be made available to the Division
upon request. Revisions shall be made to the plans at the requests of the Division.
5.2 General Provisions
5.2.1 CO monitors: The permittee shall ensure that all continuous emission monitoring
systems required are in operation and monitoring unit emissions or opacity 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) and shall
meet the minimum frequency of operation requirements as set forth in 40 CFR Part
60 Subpart A § 60.13(e) (2) (40 CFR Part 60 Subpart A § 60.13(e), as adopted by
reference in Colorado Regulation No. 6, Part A).
5.2.2 NOx (and diluents) monitors: The permittee shall ensure that all continuous
emission monitoring systems required are in operation and monitoring unit emissions
at all times that the affected units combusts any fuel except as provided for 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)).
5.2.3 Alternative monitoring systems, alternative reference methods, or any other
alternatives for the required continuous emission monitoring systems shall not be
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
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Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 26
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 requirements of 40 CFR Part 60 or 40 CFR Part 75 prior to use.
5.2.4 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.
5.2.5 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.
5.2.6 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), as adopted by
reference in Colorado Regulation No. 6, Part A).
5.3 Specific Provisions for NSPS Subpart GG
If the owner or operator has installed a NOx CEMS to meet the requirements of part 75 of this
chapter, and is continuing to meet the ongoing requirements of part 75 of this chapter, the CEMS
may be used to meet the requirements of this section (40 CFR Part 60 Subpart GG), except that
the missing data substitution methodology provided for at 40 CFR part 75, subpart D, is not
required for purposes of identifying excess emissions. Instead, periods of missing CEMS data are
to be reported as monitor downtime in the excess emissions and monitoring performance report ;
required in Condition 5.4 (40 CFR Part 60 Subpart GG § 60.334(b)(3)(iii).
Use of the ISO correction equation is optional for units used in association with heat recovery
steam generators equipped with duct burners (40 CFR Part 60 Subpart GG § 60.335(b)(1)). The
permittee has elected to not correct emissions to ISO standard ambient conditions.
5.4 Recordkeeping and Reporting Requirements
5.4.1 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 calendar quarter, a report of excess
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
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Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 27
emissions for all pollutants monitored for that quarter (40 CFR Part 60 Subpart A §
60.7(c), as adopted by reference in Colorado Regulation No. 6, Part A). This report
shall consist of the following information and/or reporting requirements as specified
by the Division:
5.4.1.1 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)).
5.4.1.2 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)).
5.4.1.3 The date and time identifying each period during which the continuous
monitoring system was inoperative except for zero and span checks and
the nature of the system repairs or adjustments (40 CFR Part 60 Subpart A
§ 60.7(c)(3)).
5.4.1.4 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)).
5.4.2 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 calendar quarter, a summary report for that
quarter (40 CFR Part 60 Subpart A § 60.7(c), as adopted by reference in Colorado
Regulation No. 6, Part A). One summary report form shall be submitted for each
pollutant monitored. This report shall contain the information and be presented in a
format approved by the Division.
If the total duration of excess emissions for the reporting period is less than 1 percent
of the total operating time for the reporting period and continuous monitoring system
(CMS) downtime is less than 5 percent of the total operating time for the reporting
period, only the summary report form shall be submitted and the excess emission
report described in Condition 5.4.1 need not be submitted unless required by the
Division (40 CFR Part 60 Subpart A § 60.7(d)(1), as adopted by reference in
Colorado Regulation No. 6, Part A).
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
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit# 95OPWE096 Page 28
Condition 5.4.1 shall both be submitted (40 CFR Part 60 Subpart A § 60.7(d)(2), as
adopted by reference in Colorado Regulation No. 6, Part A).
5.5 Data Replacement Requirements
For periods when quality assured data is not available from the continuous emission monitoring
systems the following data replacement procedures shall be used for determining the total
(annual) emissions:
5.5.1 For NOx, the procedures in 40 CFR Part 75 Subpart D shall be used.
5.5.2 For CO, the highest reading recorded during the previous 30-day period shall be used
(Colorado Construction Permit 91 WE667).
Note that the replaced data shall be used to monitor compliance with the NOx and CO annual
emission limitations.
6. National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines (40 CFR Part 63 Subpart ZZZZ)
6.1 The diesel-fired emergency generator and fire pump engines are subject to the requirements in 40
CFR Part 63 Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines", as follows:
These requirements included in this Condition 6.1 are only federally enforceable. As of the date
of revised 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 these engines 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 (5C 60.6595)
6.1.1 If you have an existing stationary CI RICE located at an area source of HAP
emissions, you must comply with the applicable emission limitations and operating
limitations no later than May 3, 2013. (§ 63.6595(a)(I))
What emission limitations and operating limitations must I meet if I own or operate an existing
CI RICE located at an area source of HAP emissions (§ 63.6603)
6.1.2 If you own or operate an existing stationary CI RICE located at an area source of
HAP emissions, you must comply with the requirements in Table 2d to this subpart
and the operating limitations in Table 2b to this subpart which apply to you. (§
63.6603(a)) The requirements in Table 2d that apply to these emergency CI RICE are
as follows:
6.1.2.1 Change oil and filter every 500 hours of operation or annually whichever
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
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• Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
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comes first. (Table 2d, item 4.a)
6.1.2.2 Inspect air cleaner every 1,000 hours of operation or annually whichever
comes first. (Table 2d, item 4.b)
6.1.2.3 Inspect all hoses and belts every 500 hours of operation or annually
whichever comes first, and replace as necessary. (Table 2d, item 4.c)
Notwithstanding the above requirements, the following applies:
6.1.2.4 Sources have the option to utilize an oil analysis program as described in
Condition 6.1.8 in order to extend the specified oil change requirement in
Condition 6.1.2.1. (Table 2d, footnote I)
6.1.2.5 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 6.1.2.1
through 6.1.2.3, 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
Federal, State or local law under which the risk was deemed unacceptable.
(Table 2d, footnote 2)
What are my general requirements for complying with this subpart? (§ 63.6605)
6.1.3 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))
6.1.4 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)
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 30
6.1.5 If you own or operate an existing stationary RICE with a site rating of less than 100
brake HP located at a major source of HAP emissions, an existing stationary
emergency RICE, or an existing stationary RICE located at an area source of HAP
emissions not subject to any numerical emission standards shown in Table 2d to this
subpart, 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))
6.1.6 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(O)
6.1.7 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
which time the emission standards applicable to all times other than startup in Tables
la, 2a, 2c, and 2d to this subpart apply. (§ 63.6625(h))
6.1.8 If you own or operate a stationary engine that is subject to the work, operation or
management practices in Condition 6.1.2.1, you have the option of utilizing an oil
analysis program in order to extend the specified oil change requirement in Condition
6.1.2.1. The oil analysis must be performed at the same frequency specified for
changing the oil in Condition 6.1.2.1. 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(O)
How do I demonstrate continuous compliance with the emission limitations and operating
limitations? 63.6640)
6.1.9 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
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
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
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• Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 31
existing emergency stationary RICE located at an area source of HAP emissions, you
must operate the engine according to the conditions described below. (§ 63.6640(O)
6.1.9.1 For owners and operators of emergency engines, any operation other than
emergency operation, maintenance and testing, and operation in non-
emergency situations for 50 hours per year, as permitted in this section, is
prohibited. (§ 63.6640(O(1))
6.1.9.2 There is no time limit on the use of emergency stationary RICE in
emergency situations. (§ 63.6640(O(2))
6.1.9.3 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(O(3))
6.1.9.4 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 Condition
6.1.9.4, as long as the power provided by the financial arrangement is
limited to emergency power. (§ 63.6640(t)(4))
What records must I keep? (( 63.6655)
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 32
6.1.10 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 CI RICE located at an area source of HAP emissions
subject to management practices as shown in Conditions 6.1.2.1 through 6.1.2.3. (§
63.6655(e) and § 63.6655(e)(3))
6.1.11 If you own or operate an existing emergency stationary CI RICE located at an area
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(0 and §
63.6655(0(2))
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
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• Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
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SECTION III - Acid Rain Requirements
1. Designated Representative and Alternate Designated Representative
Designated Representative: Alternate Designated Representative:
Name: Paul Paxson Name: Richard Rhoads
Title: Director , Asset Manager Title: Facility Manager
Phone: (303) 857-8053 Phone: (720) 857-8052
2. Sulfur Dioxide Emission Allowances and Nitrogen Oxide Emission Limitations
•
UnitS001 2011 2012 2013 2014 2015
SO2 Allowances, 0* 0* 0* 0*
per 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.
UnitS002 2011 2012 2013 2014 2015
SO2 Allowances, 0* 0* 0* 0*
per 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.
Unit S003 2011 2012 2013 2014 2015
SO2 Allowances, 0* 0* 0* 0*
per 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.
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit# 95OPWE096 Page 34
Unit S004 2011 2012 2013 2014 2015
SO2 Allowances, 0* 0* 0* 0*
per 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.
UnitS005 2011 2012 2013 2014 2015
SO2 Allowances, 0* 0* 0* 0*
per 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
Units S001 through S005 of this facility are subject to and the source has certified that they will comply
with the following standard conditions.
Permit Requirements.
(I) 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 Colorado Air Pollution
Control Division determines is necessary in order to review an Acid Rain permit
application and issue or deny an Acid Rain permit;
(2) The owners and operators of each affected source and each affected unit at the source shall:
(i) Operate the unit in compliance with a complete Acid Rain permit application or a
superseding Acid Rain permit issued by the Division; and
(ii) Have an Acid Rain Permit.
Monitoring Requirements.
(I) The owners and operators and, to the extent applicable, designated representative of each
affected source and each affected unit at the source shall comply with the monitoring
requirements as provided in 40 CFR part 75.
(2) The emissions measurements recorded and reported in accordance with 40 CFR part 75 shall be
used to determine compliance by the source or unit, as appropriate, with the Acid Rain emissions
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
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• Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 35
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 affected units at the source; and
(ii) Comply with the applicable Acid Rain emissions limitations for sulfur dioxide.
(2) Each ton of sulfur dioxide emitted in excess of the Acid Rain emissions limitations for sulfur
dioxide shall constitute a separate violation of the Federal Clean Air Act.
(3) An affected unit shall be subject to the requirements under paragraph (1) of the sulfur dioxide
requirements as follows:
(i) Starting January 1, 2000, an affected unit under 40 CFR 72.6(a)(2); or
(ii) Starting on the later of January 1, 2000 or the deadline for monitor certification under 40
CFR part 75, an affected unit under 40 CFR 72.6(a)(3).
(4) Allowances shall be held in, deducted from, or transferred among Allowance Tracking System
accounts in accordance with the Acid Rain Program.
(5) An allowance shall not be deducted in order to comply with the requirements under paragraph
(1) of the sulfur dioxide requirements prior to the calendar year for which the allowance was
allocated.
(6) An allowance allocated by the Administrator under the Acid Rain Program is a limited
authorization to emit sulfur dioxide in accordance with the Acid Rain Program. No provision of
the Acid Rain Program, the Acid Rain permit application, the Acid Rain permit, or an exemption
under 40 CFR 72.7 or 72.8 and no provision of law shall be construed to limit the authority of
the United States to terminate or limit such authorization.
(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.
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit# 95OPWE096 Page 36
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 source that has excess emissions in any calendar year
shall:
(i) Pay without demand, to the Administrator of the U. S. EPA, the penalty required, and pay
upon demand the interest on that penalty, as required by 40 CFR part 77; and
(ii) Comply with the terms of an approved offset plan, as required by 40 CFR part 77.
Recordkeeping and Reporting Requirements.
(1) Unless otherwise provided, the owners and operators of the source and each affected unit at the
source shall keep on site at the source each of the following documents for a period of 5 years
from the date the document is created. This period may be extended for cause, at any time prior
to the end of 5 years, in writing by the Administrator or the Division:
(i) The certificate of representation for the designated representative for the source and each
affected unit at the source and all documents that demonstrate the truth of the statements
in the certificate of representation, in accordance with 40 CFR 72.24; provided that the
certificate and documents shall be retained on site at the source beyond such 5-year
period until such documents are superseded because of the submission of a new
certificate of representation changing the designated representative;
(ii) All emissions monitoring information, in accordance with 40 CFR part 75; provided that
to the extent that 40 CFR part 75 provides for a 3-year period for recordkeeping, the 3-
year period shall apply.
(iii) Copies of all reports, compliance certifications, and other submissions and all records
made or required under the Acid Rain Program; and,
(iv) Copies of all documents used to complete an Acid Rain permit application and any other
submission under the Acid Rain Program or to demonstrate compliance with the
requirements of the Acid Rain Program.
(2) The designated representative of an affected source and each affected unit at the source shall
submit the reports and compliance certifications required under the Acid Rain Program,
including those under 40 CFR part 72 subpart I and 40 CFR part 75.
Liability.
(1) Any person who knowingly violates any requirement or prohibition of the Acid Rain Program, a
complete Acid Rain permit application, an Acid Rain permit, or an exemption under 40 CFR
72.7 or 72.8, including any requirement for the payment of any penalty owed to the United
States, shall be subject to enforcement pursuant to section 113(c) of the Federal Clean Air Act.
(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.
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
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Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 37
(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;
(2) Limiting the number of allowances a unit can hold;provided, that the number of allowances held
by the unit shall not affect the source's obligation to comply with any other provisions of the
Federal Clean Air Act;
(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
Reports shall be submitted to the addresses identified in Appendix D.
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.
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit ti 95OPWE096 Page 38
Pursuant to 40 CFR Part 75.65 excess emissions of opacity shall be reported to the Division. These reports
shall be submitted in a format approved by the Division.
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
Units S001 through S005 are not subject to the NOx limitations since they burn natural gas. The NOx
limitations in 40 CFR Part 76 are only applicable to coal-fired units.
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
• Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 39
SECTION IV- Permit Shield
Regulation No. 3, 5 CCR 1001-5, Part C, §§ I.A.4, V.D., & XIILB 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
modification or reconstruction on which construction commenced prior to permit issuance.
Emission Unit Non-Applicable Requirement Justification
Description&
Number
S011 40 CFR 63, Subpart Q (Adopted by The cooling tower does not operate with chromium-based water
Reference,Colorado Regulation No. 8) treatment chemicals.
Facility 40 CFR 60, Subparts K, Ka, Kb (Colorado All tanks at the facility are smaller than the threshold limits in
Regulation No. 6, Part A, Subpart K, Ka, these subparts.
Kb)
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)0), 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.
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 40
3. Streamlined Conditions
The following applicable requirements have been subsumed within this operating permit using the pertinent
streamlining procedures approved by the U.S. EPA. For purposes of the permit shield, compliance with the
listed permit conditions will also serve as a compliance demonstration for purposes of the associated subsumed
requirements.
Permit Condition Streamlined(Subsumed) Requirements
Section II,Condition Regulation No. 6, Part B, Section II.C.2 (particulate matter standard)
1.2.2
Section II, Condition Regulation No. 6, Part B, Section II.D.3.b(sulfur dioxide standard)
1.3.3
Section II, Condition 40 CFR Part 60 Subpart Db §§ 60.44b(a)(4)(i), (h) & (i), as adopted by reference in Colorado
1.4.2 Regulation No. 6, Part A [NOx emissions shall not exceed 0.20 lb/mmBtu, on a 30-day rolling
average,applies at all times, including periods of startup, shutdown and malfunction]
Section V, 40 CFR Part 60 Subpart Db § 60.48c(i)(retain records for 2 yrs)
Conditions 22.b&c
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
' Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 41
SECTION V - General Permit Conditions
3/23/10 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.I. The permittee may immediately make the change upon submission of
the application to the Division.
2. Certification Requirements
Regulation No. 3, 5 CCR 1001-5, Part C, §§ 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., JI B., ILC., II .E., II.F., 11.1, and Il.J
a. To Control Emissions Leaving Colorado
When emissions generated from sources in Colorado cross the State boundary line, such emissions shall not cause
the air quality standards of the receiving State to be exceeded, provided reciprocal action is taken by the receiving
State.
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit# 95OPWE096 Page 42
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 maybe 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: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
' Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 43
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: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit# 95OPWE096 Page 44
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.
g. Affirmative Defense Provision for Excess Emissions During Startup and Shutdown
An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during
periods of startup and shutdown. To establish the affirmative defense and to be relieved of a civil penalty in any
action to enforce an applicable requirement, the owner or operator of the facility must meet the notification
requirements below in a timely manner and prove by a preponderance of the evidence that:
(i) The periods of excess emissions that occurred during startup and shutdown were short and infrequent and
could not have been prevented through careful planning and design;
(ii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation or
maintenance;
(iii) If the excess emissions were caused by a bypass(an intentional diversion of control equipment), then the
bypass was unavoidable to prevent loss of life,personal injury, or severe property damage;
(iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum
extent practicable;
(v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality;
(vi) All emissions monitoring systems were kept in operation(if at all possible);
(vii) The owner or operator's actions during the period of excess emissions were documented by properly
signed, contemporaneous operating logs or other relevant evidence; and,
(viii) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions.
This 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: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
•
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 45
The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements
that derive from new source performance standards or national emissions standards for hazardous air pollutants, or
any other federally enforceable performance standard or emission limit with an averaging time greater than twenty-
four hours. In addition, an affirmative defense cannot be used by a single source or small group of sources where
the excess emissions have the potential to cause an exceedance of the ambient air quality standards or Prevention of
Significant Deterioration(PSD) increments.
In making any determination whether a source established an affirmative defense,the Division shall consider the
information within the notification required above and any other information the Division deems necessary,which
may include, but is not limited to,physical inspection of the facility and review of documentation pertaining to the
maintenance and operation of process and air pollution control equipment.
4. Compliance Requirements
Regulation No. 3, 5 CCR 1001-5, Part C. §§ III.C.9.,V.C.I I. & 16.d. and § 25-7-122.1(2), C.R.S.
a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to
federally-enforceable terms or conditions constitutes a violation of the federal act, as well as the state act and
Regulation No. 3. Any permit noncompliance relating to state-only terms or conditions constitutes a violation of the
state act and Regulation No. 3, shall be enforceable pursuant to state law, and shall not be enforceable by citizens
under § 304 of the federal act. Any such violation of the federal act,the state act or regulations implementing either
statute is grounds for enforcement action, for permit termination, revocation and reissuance or modification or for
denial of a permit renewal application.
b. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a
permit termination,revocation or modification action or action denying a permit renewal application that it would
have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of
the permit.
c. The permit 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 Xl.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: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 46
g. The permittee shall not knowingly falsify,tamper with, or render inaccurate any monitoring device or method
required to be maintained or followed under the terms and conditions of the Operating Permit.
5. Emergency Provisions
Regulation No. 3, 5 CCR 1001-5, Part C, & VII.
An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the
source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that
causes the source to exceed the technology-based emission limitation under the permit due to unavoidable increases in
emissions attributable to the emergency. "Emergency" does not include noncompliance to the extent caused by improperly
designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. An emergency
constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology-based emission
limitation if the permittee demonstrates,through properly signed, contemporaneous operating logs,or other relevant evidence
that:
a. an emergency occurred and that the permittee can identify the cause(s)of the emergency;
b. the permitted facility was at the time being properly operated;
c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that
exceeded the emission standards, or other requirements in the permit; and
d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the
next working day following the emergency, and followed by written notice within one month of the time when
emissions limitations were exceeded due to the emergency. This notice must contain a description of the
emergency, any steps taken to mitigate emissions, and corrective actions taken.
This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement.
6. Emission Controls for Asbestos
Regulation No. 8, 5 CCR 1001-10, Part B
The permittee shall not conduct any asbestos abatement activities except in accordance with the provisions of Regulation No.
8,Part B, "asbestos control."
7. Emissions Trading, Marketable Permits, Economic Incentives
Regulation No. 3, 5 CCR 1001-5, Part C, & V.C.13.
No permit revision shall be required under any approved economic incentives, marketable permits, emissions trading and
other similar programs or processes for changes that are specifically provided for in the permit.
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
•
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit# 95OPWE096 Page 47
8. Fee Payment
C.R.S. §§ 25-7-114.1(6)and 25-7-114.7
a. The permittee shall pay an annual emissions fee in accordance with the provisions of C.R.S. §25-7-114.7. A 1%
per month late payment fee shall be assessed against any invoice amounts not paid in full on the 91st day after the
date of invoice, unless a permittee has filed a timely protest to the invoice amount.
b. The permittee shall pay a permit processing fee in accordance with the provisions of C.R.S. § 25-7-114.7. If the
Division estimates that processing of the permit will take more than 30 hours, it will notify the permittee of its
estimate of what the actual charges may be prior to commencing any work exceeding the 30 hour limit.
c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S. § 25-7-115.1(6)for each APEN or
revised APEN filed.
9. Fugitive Particulate Emissions
Regulation No. 1,5 CCR 1001-3, § III.D.I.
The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate
emissions into the atmosphere, in accordance with the provisions of Regulation No. 1, § III.D.I.
10. Inspection and Entry
Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.16.b.
Upon presentation of credentials and other documents as may be required by law, the permittee shall allow the Air Pollution
Control Division, or any authorized representative, to perform the following:
a. enter upon the permittee's premises where an Operating Permit source is located, or emissions-related activity is
conducted, or where records must be kept under the terms of the permit;
b. have access to, and copy, at reasonable times, any records that must be kept under the conditions of the permit;
c. inspect at reasonable times any facilities, equipment(including monitoring and air pollution control equipment),
practices, or operations regulated or required under the Operating Permit;
d. sample or monitor at reasonable times, for the purposes of assuring compliance with the Operating Permit or
applicable requirements, any substances or parameters.
l 1. Minor Permit Modifications
Regulation No. 3, 5 CCR 1001-5, Part C, §§ X. & Xl.
The permittee shall submit an application for a minor permit modification before making the change requested in the
application. The permit shield shall not extend to minor permit modifications.
12. New Source Review
Regulation No. 3, 5 CCR 1001-5, Part B
The 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.
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 48
13. No Property Rights Conveyed
Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.I l.d.
This permit does not convey any property rights of any sort, or any exclusive privilege.
14. Odor
Regulation No.2, 5 CCR 1001-4, Part A
As a matter of state law only, the permittee shall comply with the provisions of Regulation No. 2 concerning odorous
emissions.
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, §§ 1., II.
The permittee shall comply with the opacity emissions limitation set forth in Regulation No. I, §§ I.-II.
17. Open Burning
Regulation No. 9, 5 CCR 1001-11
The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions
of Regulation No. 9.
18. Ozone Depleting Compounds
Regulation No. 15, 5 CCR 1001-17
The permittee shall comply with the provisions of Regulation No. IS concerning emissions of ozone depleting compounds.
Sections I., II.C., II.D., Ill. 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, §§ 1I1.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: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
•
- Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 49
20. Portable Sources
Regulation No. 3, 5 CCR 1001-5, Part C, § II.D.
Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in
location.
21. Prompt Deviation Reporting
Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.7.b.
The permittee shall promptly report any deviation from permit requirements, including those attributable to malfunction
conditions as defined in the permit, the probable cause of such deviations, and any corrective actions or preventive measures
taken.
"Prompt" is defined as follows:
a. Any definition of"prompt"or a specific timeframe for reporting deviations provided in an underlying applicable
requirement as identified in this permit; or
b. Where the underlying applicable requirement fails to address the time frame for reporting deviations, reports of
deviations will be submitted based on the following schedule:
(i) For emissions of a hazardous air pollutant or a toxic air pollutant(as identified in the applicable regulation)
that continue for more than an hour in excess of permit requirements, the report shall be made within 24
hours of the occurrence;
(ii) For emissions of any regulated air pollutant, excluding a hazardous air pollutant or a toxic air pollutant that
continue for more than two hours in excess of permit requirements,the report shall be made within 48
hours; and
(iii) For all other deviations from permit requirements, the report shall be submitted every six(6)months,
except as otherwise specified by the Division in the permit in accordance with paragraph 22.d. below.
c. If any of the conditions in paragraphs b.i or b.ii above are met,the source shall notify the Division by telephone
(303-692-3155)or facsimile(303-782-0278)based on the timetables listed above. [Explanatory note: Notification
by telephone or facsimile must specify that this notification is a deviation report far 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;
(iii) the company or entity that performed the analysis;
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit# 95OPWE096 Page 50
(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.
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.
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
•
' Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit # 95OPWE096 Page 51
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 I in Appendix D of this permit. If the permittee chooses to
use the "Combined Construction/Operating Permit" application procedures of Regulation No. 3, Part C, then the Operating
Permit must be received prior to commencing construction of the new or modified source.
27. Special Provisions Concerning the Acid Rain Program
Regulation No. 3, 5 CCR 1001-5, Part C, §§ V.C.I.b. & 8
a. Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations
promulgated under Title IV of the federal act, 40 Code of Federal Regulations(CFR)Part 72, both provisions shall
be incorporated into the permit and shall be federally enforceable.
b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal 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, Pan 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: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division Thermo Cogeneration Partnership, L.P., A Delaware Limited Partnership
Colorado Operating Permit Ft. Lupton Cogeneration Facility
Permit# 95OPWE096 Page 52
29. Volatile Organic Compounds
Regulation No. 7, 5 CCR 1001-9, 55 III &V.
a. For sources located in an ozone non-attainment area or the Denver Metro Attainment Maintenance Area, 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: 95OPWE096 First Issued: 1/1/99
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: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix A
Compliance Monitoring Report Page 1
APPENDIX A - Inspection Information
Directions to Plant:
The plant is located at 6501 Weld County Road 31 in the town of Fort Lupton.
Safety Equipment Required:
Eye Protection,
Hard Hat,
Safety Shoes,
Hearing Protection
Gloves
Facility Plot Plan:
Figure 1 (following page) shows the plot plan as submitted on December 8, 1995 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 submitted in the application are as follows:
Generator lube oil service tanks, < 3,000 gallons
#2 diesel fuel oil service tanks, < 500 gallons
Waste oil storage tank, 300 gallons
Temporary waste oil storage drums, 55 gallon
Portable propane heating units, < 1 MMBtu/hr
Sodium hypochlorite storage tank, 2,500 gallon
Aqueous sulfuric acid storage tank, 1,500 gallon
Forklift
Gasoline powered pressurized water parts washer, < 5 HP
Natural Gas space heaters, combined total heat < 6 MMBtu/hr
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
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• 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: 95OPWE096 First Issued: 1/1/99
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: 95OPWE096 First Issued: I/1/99
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.'
• 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
would still be noted in the deviation report. In regard to compliance certifications, the permittee should be
' For example, given the various emissions limitations and monitoring requirements to which a source may be
subject, a deviation from one requirement may not be a deviation under another requirement which recognizes
an exception and/or special circumstances relating to that same event.
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 4
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: 95OPWE096 First Issued: 1/1/99
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: Thermo Cogeneration Partnership, L.P., a Delaware Limited partnership — Ft. Lupton
Cogeneration Facility
OPERATING PERMIT NO: 95OPWE096
REPORTING PERIOD: (see first page of the permit for specific reporting period and dates)
Deviations Noted Deviation Malfunction/
During Period?' Code2 Emergency Condition
Operating Reported During
Permit Unit Period?
ID Unit Description YES NO YES NO
S001 -S005 Five (5)General Electric LM6000 Natural Gas
Combustion Turbines, Each Rated at 296
MMBtu/hr, Serial Nos. 185-130, 185-126, 185-135,
185-136 and 185-137 and Five(5) Coen 12408-I
Duct Burners, Two(2) Rated at 240 MMBtu/hr,
Each and Three (3) Rated at 180 MMBtu/hr, Each.
The Turbines are Equipped with Steam Injection for
NOX Control,
S006 One(1)Detroit Diesel, Diesel Fired Internal
Combustion Engine, Model No. 8163-7416, Rated at
8.57 MMBtu/hr, Serial No. Unknown. Emergency
Generator.
S007 One(1)Clark, Model No. DDFP-T6At, Diesel Fired
Internal Combustion Engine, Rated at 2.28
MMBtu/hr, Serial No. Unknown. Emergency Fire
Pump.
S011 One Custom Forced Draft Industrial Cooling Tower
Equipped with Munters D15 Drift Eliminators.
General Conditions
Insignificant Activities
See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation has occurred
shall be based on a reasonable inquiry using readily available information.
2Use the following entries as appropriate:
I =Standard: When the requirement is an emission limit or standard
2= Process: When the requirement is a production/process limit
3=Monitor: When the requirement is monitoring
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 6
4=Test: When the requirement is testing
5=Maintenance: When required maintenance is not performed
6=Record: When the requirement is recordkeeping
7=Report: When the requirement is reporting
8=CAM: A situation in which an excursion or exceedance as defined in 40 CFR Part 64 (the Compliance Assurance
Monitoring(CAM)Rule)has occurred.
9=Other: When the deviation is not covered by any of the above categories
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
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: Thermo Cogeneration Partnership, L.P., a Delaware Limited Partnership — Ft.
Lupton Cogeneration Facility
OPERATING PERMIT NO: 95OPWE096
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: 95OPWE096 First Issued: 1/1/99
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: 95OPWE096 E096 First Issued: 1/1/99
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: Thermo Cogeneration Partnership, L.P., a Delaware Limited Partnership — Ft. Lupton
Cogeneration Facility
FACILITY IDENTIFICATION NUMBER: 1230250
PERMIT NUMBER: 95OPWE096
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: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix C
Compliance Certification Report Page 1
APPENDIX C
Format for Annual Compliance Certification Reports
ver 2/20/07
Following is the format for the Compliance Certification report to be submitted to the Division and the U.S.
EPA annually based on the effective date of the permit. The Table below must be completed for all equipment
or processes for which specific Operating Permit terms exist.
FACILITY NAME: Thermo Cogeneration Partnership, L.P., a Delaware Limited Partnership — Ft. Lupton
Cogeneration Facility
OPERATING PERMIT NO: 95OPWE096
REPORTING PERIOD:
I. Facility Status
During the entire reporting period, this source was in compliance with ALL terms and conditions contained
in the Permit, each term and condition of which is identified and included by this reference. The method(s)
used to determine compliance is/are the method(s) specified in the Permit.
With the possible exception of the deviations identified in the table below, this source was in compliance
with all terms and conditions contained in the Permit, each term and condition of which is identified and
included by this reference, during the entire reporting period. The method used to determine compliance for
each term and condition is the method specified in the Permit, unless otherwise indicated and described in the
deviation report(s). Note that not all deviations are considered violations.
Operating Unit Description Deviations Monitoring Was compliance continuous
Permit Reported I Method per or intermittent?3
Unit ID Permit?2
Previous I Current YES I NO Continuous I Intermittent
S001 — Five(5)General Electric LM6000
S005 Natural Gas Combustion Turbines, Each
Rated at 296 MMBtu/hr, Serial Nos. 185-
130, 185-126, 185-135, 185-136 and 185-
137 and Five (5)Coen 12408-1 Duct
Burners,Two(2) Rated at 240
MMBtu/hr, Each and Three (3) Rated at
180 MMBtu/hr, Each.The Turbines are
Equipped with Steam Injection for NOx
Control,
S006 One(I) Detroit Diesel, Diesel Fired
Internal Combustion Engine, Model No.
8163-7416, Rated at 8.57 MMBtu/hr,
Serial No. Unknown. Emergency
Generator.
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
' Air Pollution Control Division
Colorado Operating Permit Appendix C
Compliance Certification Report Page 2
Operating Unit Description Deviations Monitoring Was compliance continuous
Permit Reported I Method per or intermittent?3
Unit ID Permit?2
Previous I Current YES I NO Continuous I Intermittent
S007 One(I)Clark, Model No. DDFP-T6At,
Diesel Fired Internal Combustion Engine,
Rated at 2.28 MMBtu/hr, Serial No.
Unknown. Emergency Fire Pump.
S008, Two(2)Trane, Model ABDL 110,
S009 Natural Gas Fired Water Chillers, Each
Rated at 13.67 MMBtu/hr, Serial Nos.
Unknown.
S011 One Custom Forced Draft Industrial
Cooling Tower Equipped with Munters
DI.5 Drift Eliminators.
General Conditions
Insignificant Activities"
If deviations were noted in a previous deviation report , put an "X" under "previous". If deviations were noted in the current
deviation report (i.e. for the last six months of the annual reporting period), put an "X" under"current". Mark both columns if both
apply.
2 Note whether the method(s) used to determine the compliance status with each term and condition was the method(s)specified in the
permit. If it was not, mark "no"and attach additional information/explanation.
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
for the duration of the reporting period. Therefore, if a source I) 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: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix C
Compliance Certification Report Page 3
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: 95OPWE096 First Issued: 1/1/99
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: Jim King
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: 95OPWE096 First Issued: 1/1/99
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/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
PMio - Particulate Matter Under 10 Microns
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix E
Permit Acronyms Page 2
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
SIC - Standard Industrial Classification
SO2 - Sulfur Dioxide
TPY - Tons Per Year
TSP - Total Suspended Particulate
VOC - Volatile Organic Compounds
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix F
Permit Modifications Page 1
APPENDIX F
Permit Modifications
DATE OF TYPE OFSECTION DESCRIPTION OF REVISION
REVISION MODIFICATION NUMBER,
CONDITION
ww R NUMBER
Operating Permit Number: 95OPWE096 First Issued: 1/1/99
Renewed: DRAFT
(9/13/2010) Jackie Joyce - Re: Ft. Lupton Page 1j
From: Kevin Lewis <klewis@airsci.com>
To: Jackie Joyce <JEJOYCE@cdphe.state.co.us>
Date: 9/12/2010 6:39 PM
Subject: Re: Ft. Lupton
No new engines and no MeCl2.
Kevin Lewis
720-389-4213 direct work
303-638-2892 mobile
On Sep 12, 2010, at 2:20 PM, "Jackie Joyce" <JEJOYCE@cdphe.state.co.us> wrote:
> Kevin,
>• I've made the change as requested. There were also a couple of
> questions in the cover letter
> do you have any NEW engines subject to either NSPS JJJJ or MACT ZZZZ?
> is methylene chloride used as a paint stripper?
> Can you let me know the answers to those questions.
>>>> "Kevin Lewis" <klewis@airsci.com> 9/8/2010 12:24 PM >>>
> The draft permit looks good. I only found one small reference typo.
> See
> below. Thanks.
> 6.1.6 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(gf))
> Kevin Lewis
> 720-389-4213 Office
> 303-638-2892 Mobile
> 303-484-5030 Fax
> Air Sciences Inc.
(9/13/2010) Jackie Joyce - Re: Ft. Lupton Page 2H
> 1301 Washington Avenue, Suite 200
> Golden, CO 80401-1915
> <pre-draft renewal transmittal.pdf>
STATE OF COLORADO
Bill Ritter,Jr.,Governor
Martha E. Rudolph,Executive Director pFco7
Xf`:.:, k\
Dedicated to protecting and improving the health and environment of the people of Colorado IINe
airs of
4300 Cherry Creek Dr.S. Laboratory Services Division
Denver,Colorado 80246-1530 8100 Lowry Blvd. \
Phone (303)692-2000 Denver,Colorado 80230-6928
TDD Line(303)691-7700 (303)692-3090
Located in Glendale,Colorado Colorado Department
of Public Health
http://www.cdphe.state.co.us and Environment
August 4, 2010
Mr. Richard Rhoads
Facility Manager
Thermo Cogeneration Partnership, LP
P. O. Box 208
Ft. Lupton, CO 80621
SUBJECT: Draft Renewal Operating Permit for Public Service Company— Ft. Lupton Cogeneration
Facility
Dear Mr. Rhoads:
Enclosed please find a draft of the renewal operating permit for your facility as well as a copy of the
technical review summary document. Please review and submit any comments you may have
concerning the modified draft operating permit. Following our review of your comments, we will send
the draft permit out for a 30-day Public Comment period and then to EPA for their 45-day review period.
The regulations also require that the applicant receive written notice of their right to a formal hearing
before the Colorado Air Quality Control Commission at the same time that the Public Comment packet
goes out. You will receive a separate letter containing that information.
This draft renewal permit contains the modifications that you requested in your renewal application
received on May 17, 2010. The permit was also revised to be more consistent with recently issued
permits, correct errors, omissions and discrepancies identified during inspections and/or review of the
renewal application and incorporate EPA comments made on other operating permits for similar
sources. The changes are summarized in the technical review document for the renewal permit.
While you are reviewing this permit, please be aware of the following:
1. Since the original issuance of this permit, EPA has promulgated National Emission Standards
for Hazardous Air Pollutant Emissions (NESHAP) for reciprocating internal combustion engines
(RICE) located at area sources and Standards of Performance (NSPS) for both compression
ignition and spark ignition engines. These requirements apply to both new and existing engines
and apply to any size engine, many of which could otherwise be considered insignificant
activities. The appropriate requirements for existing engines have been incorporated into the
draft renewal permit. However, the Division must determine if there are any new engines
located at your facility that could be subject to these new requirements and would have to be
included in Section II of the permit. Please indicate whether you have any engines that would
meet the following requirements:
Mr. Richard Rhoads, Facility Manager August 4, 2010
Draft Renewal Operating Permit Page 2
Requirements Applicability Date Engine Type/Size H
40 CFR Part 63 Subpart ZZZZ Constructed and/or reconstructed Both Compression Ignition and
after 6/12/06 Spark Ignition, all sizes
40 CFR Part 60 Subpart IIII Construction commenced(engine Compression ignition, all sizes
ordered)after 7/11/05,engine
manufactured after 4/1/06.
40 CFR Part 60 Subpart JJJJ Construction commenced(engine Spark Ignition, all sizes
ordered)after 6/12/06, engine
manufactured after 7/1/07*
*7/1/07 is the earliest manufactured date for which NSPS requirements apply,the manufactured date varies
depending on size and type of engine.
2. EPA promulgated National Emission Standards for Hazardous Air Pollutants for Paint Stripping and
Miscellaneous Surface Coating Operations at Area Sources (40 CFR Part 63 Subpart HHHHHH) on
January 9, 2008. Since the Ft. Lupton Cogeneration Facility is not a major source of hazardous air
pollutant(HAP) emissions, these rules potentially apply. The Division believes that any spray coating of
motor vehicles and mobile equipment and spray application of coatings that contain target HAPS that
may occur at this facility would meet the definition of facility maintenance and would therefore, not be
subject to the requirements in 40 CFR Part 63 Subpart HHHHHH. However, we cannot determine
whether any paint stripping activities at this facility would be subject to these requirements. Please
indicate whether any paint stripping chemicals used at your facility include methylene chloride.
We would like you to review this permit and respond to the items identified above by September 9,
2010. Feel free to call me at (303) 692-3267 if you have any further questions.
Sincerely,
Jacqueline Joyce,
Permit Engineer
Operating Permit Unit
Stationary Sources Program
Air Pollution Control Division
Enclosures
cc: Kevin Lewis, Air Sciences, Inc., via e-mail
THERMO COGENERATION PARTNERSHIP, L.P.
6811 WELD COUNTY ROAD 31 P.O. BOX 208 FORT LUPTON, CO 80621
VOICE: (303) 857-8040 FAX: (303) 857-8058
May 14, 2010 NA1 11
Ms. Jacqueline Joyce
Colorado Department of Public Health and Environmental
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Re: Operating Permit Renewal for Ft. Lupton Facility: 95OPWE096
Dear Ms. Joyce
Enclosed please find the original plus three copes of the Operating Permit Renewal forms for the
Ft. Lupton Cogeneration facility.
No changes are being requested for the operating permit in effect under Operating Permit No.
95OPWE096, First Issued January 1, 1999, Renewed October 1, 2006, and Last Revised
November 20, 2009. Therefore, only form 2000-800, signed by the Responsible Official is
submitted. In addition, revised annual APENs were submitted February 25, 2010 and are not
required at this time. Finally, in accordance with Regulation No. 3, Part C, Section II.B.6, there
are no materials incorporated by reference required to be included with this renewal application.
If you have any questions, please feel free to call me at 303-857-8052.
Sincerely,
Richard Rhoads
Facility Manager
Enclosure
Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000400
Colorado Department of Health 09-94
Air Pollution Control Division
Facility Name: Ft.Lupton Cotenention Facility Facility Identification Code:CO 1230250
I. ADMINISTRATION
This application contains the following forms: • Form 2000.100,Facility Identification
• Form 2000-101,Facility Plot Plan
• Forms 2000-102,-102A,and-1028,Source and Site Descriptions
D. 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.minting
• Form 2000-300,Boiler or Furnace Operation
• Form 2000-301,Storage Tanks
• Form 2000-302,Internal Combustion Engine
• Form 2000-303,Incineration
• Fonn 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 2000-402,Adsorbers
• Form 2000-403,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 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
1
•
V. EMISSION SUMMARY AND Total Number
COMPLIANCE CERTIFICATION ofThis 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 21x10.603,Facility Criteria Air Pollutants
• Form 2000-604,Applicable Requirements and Status of Emission Unit
• Form 2000-605,Permit Shield Protection Identification
• Form 2000606,Emission Unit Compliance Plan-Commitments and Schedule
• Form 2000607,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)
® I certify that the facility described in this air pollution permit application is fully in compliance with all applicable
requirements. (This certification is based on the monitoring,record keeping,and reporting procedures required
under Operating Permit#95OPWE096,renewed October 1,2006.)
• 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§25-7122.1,C.R.S.
Printed or Typed Name Title
Paul Steinway Managing Director
Signature Date Sign 07/
2
Operating Permit Application CERTIFICATION FOR STATE-ONLY CONDITIONS FORM 2000-800
Colorado Department of Health 09-94
Air Pollution Control Division
Facility Name: Ft.Lupton Cogeneration Facility Facility Identification Code:CO 1230250
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. (This certification is based on the monitoring,record keeping,and reporting procedures required
under Operating Permit#95OPWE096,renewed October 1,2006.)
• 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§25-7122.1,C.R.S.
Printed or Typed Name Title
Paul Steinw Managing Director
Signature Date Sigmedy7 id
,i/,C' e4
SEND ALL MATERIALS TO:
COLORADO DEPARTMENT OF HEALTH
APCD-SS-B1
4300 CHERRY CREEK DRIVE SOUTH
DENVER,CO 80246-1530
3
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