HomeMy WebLinkAbout20102325.tiff NOTICE OF A PROPOSED RENEWAL TITLE V OPERATING
PERMIT WARRANTING PUBLIC COMMENT
NOTICE is hereby given that an application to renew an Operating Permit has been submitted to the Colorado Air
Pollution Control Division, 4300 Cherry Creek Drive South, Denver, Colorado 80246-1530, for the following source
of air pollution:
Applicant: Public Service Company
1800 Larimer St. Suite 1300
Denver, CO 80202
Facility: Public Service Company-Ft. St. Vrain Station
16805 County Road 19 '/s
Platteville, CO 80651
Public Service Company has applied for an Renewal Operating Permit for their facility in Weld County, CO. This facility is an
electric generating station, consisting of five (5)natural gas-fired combustion turbines,three of which are each equipped with duct
burners. The primary fuel for these units is natural gas, with distillate fuel oil used as a back-up fuel. A copy of the applications,
including supplemental information, the Division analysis, and a draft of the Renewal Operating Permit 97OPWE180 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 Jacqueline Joyce at the Division at 303-692-3267
to obtain additional information. Any interested person may submit written comments to the Division concerning 1)the
sufficiency of the preliminary analysis, 2) whether the permit application should be approved or denied, 3)the ability of the
proposed activity to comply with applicable requirements, 4)the air quality impacts of, alternatives to, and control technology
required on the source or modification, and 5) any other appropriate air quality considerations. Any interested person may submit
a written request to the Division for a public comment hearing before the Colorado Air Quality Control Commission
(Commission). If requested, the hearing will be held before the Commission at their regularly scheduled meeting within 60 days
of its receipt of the request for a hearing unless a longer time period is agreed upon by the Division and the applicant. The
hearing request must: 1) identify the individual or group requesting the hearing, 2)state his or her address and phone number, and
3) state the reason(s) for the request,the manner in which the person is affected by the proceedings, and an explanation of why the
person's interests are not already adequately represented. The Division will receive and consider the written public comments and
requests for any hearing for thirty calendar days after the date of this Notice.
RELEASED TO: The Greeley Tribune on PUBLISHED: September 30, 2010
September 23, 2010
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
OPERATING PERMIT RENEWAL SUMMARY
PERMIT NUMBER: 97OPWE180 AIRS ID#: 1230023 DATE: September 23, 2010
APPLICANT: Public Service Co— Ft. St. Vrain Station REVIEW ENGINEER: Jacqueline Joyce
SOURCE DESCRIPTION
Public Service Co has applied for renewal of their Operating Permit issued for Ft. St. Vrain Station, located at 16805
County Road 19 % in Weld County. This facility classified as an electric services facility under Standard Industrial
Classification 4911. This facility consists of five (5) natural gas fired combustion turbines and three (3) heat recovery
steam generators (HRSG). The capacity of the steam turbine is 330 megawatts (MW). The output rating of the entire
plant varies based on ambient temperature with more generation in the winter and less generation in the summer. The
facility generates approximately 965 MW (summer rating) of electricity. 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. Rocky
Mountain National Park and Eagles Nest and Rawah National Wilderness Areas, all Federal Class I designated areas, are
within 100 km of this facility. This source is not subject to the Accidental Release provisions of section 112(r) of the
Federal Clean Air Act. Turbine 4 is equipped with non-selective catalytic reduction to reduce NOx emissions and is subject
the Compliance Assurance Monitoring (CAM) requirements in 40 CFR Part 64.
FACILITY EMISSION SUMMARY
Potential to Emit(PTE)
Emission Unit PM PKo SO2 NOx CO VOC HAPS
Turbine (T002) 39.4 39.4 4.7 496.1 465.4 21.4 5.02
Turbine (T003) 39.4 39.4 4.7 496.1 465.4 21.4 4.50
Turbine (T004) 54 54 4.7 199.1 237.9 33.1 5.45
Turbine (T005)* 4.45 4.45 1.85 19.95 10 1.15 0.67
Turbine (T006)* 4.45 4.45 1.85 19.95 10 1.15 0.67
Auxiliary Boiler(B001) 0.6 0.6 0.2 32.6 27.4 1.8 0.14
Cooling/Service Water 14.9 14.9 2.4 2.37
Towers (M001)
Total 157.2 157.2 18 1,263.8 1,216.1 82.4 18.82
*permitted emission limits are for both turbines together, emissions are assumed to be split between the 2 units.
EMISSION SOURCES
The following discussion identifies the more significant changes that were made in the renewal permit. Other minor
language changes were made to other permit conditions.
Three (3) combustion turbines, each with heat recovery steam generators—The compliance demonstration method for the
NOx and CO BACT emission limitations was revised to be more consistent with other permits. Previously, the permit had
allowed the source to compare any clock hour with any startup and/or shutdown time to be compared with the startup
and/or shutdown BACT limits but this revision requires that only startup and/or shutdown time shall be compared to the
startup and/or shutdown BACT limits. In addition, minor changes to the definition of startup and shutdown were made.
The performance test requirement for Turbines T002 and T003 was revised to specify that performance tests be
conducted every five years. In addition, the opacity monitoring provisions in NSPS Subpart Da were included in the permit.
Two (2) combustion turbines—The construction permit (07WE1100)for the two simple cycle turbines (T005 and T006) was
incorporated into the Title V permit with this renewal. These turbines are subject to reasonably available control
technology (RACT) requirements for NOx, which was determined to be advanced dry low NOx combustion systems. The
turbines are subject to a NOx RACT emission limitation and to requirements in NSPS Subpart KKKK (NOx limits and limits
on the sulfur content of the fuel), as well as the Acid Rain requirements. In addition, the units are subject to annual fuel
consumption and emission limitations, as well as Reg 1 limits for opacity, PM and SO2 and Reg 6 limits for opacity and
SO2. Streamlining of less stringent requirements has been done as appropriate. Compliance with the annual NOx and CO
limits are monitored using the continuous emission monitoring systems. Annual SO2 emissions are monitored using the
continuous monitoring system required by Acid Rain. Compliance with the annual fuel consumption and PM, PKo and
VOC emission limitations is monitored by recording fuel use and calculating emissions monthly. In the absence of credible
evidence to the contrary, compliance with the NSPS KKKK fuel sulfur limits and the Reg 1 PM and opacity limitations is
presumed since only pipeline quality natural gas is permitted to be used as fuel in these turbines.
Cold Cleaner Solvent Vats—Solvent cold cleaners were included in the list of insignificant activities provided by the
source. Since the area in which the facility is located has been designated as non-attainment for ozone and Reg 7 was
revised to include all ozone non-attainment areas, these units are subject to requirements in Colorado Regulation No. 7,
Section X and can no longer be considered insignificant activities. As a result they have been included in Section II of the
permit.
Emergency Generator Engines and Emergency Fire Puma Engine-The diesel fired engines driving an emergency
generator(two engines drive the generator) and an emergency fire pump had previously been included in the insignificant
activity list in Appendix A of the permit. However due to recent revisions to the requirements in 40 CFR Part 63 Subpart
ZZZZ (National Performance Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion
Engines) these engines are now subject to requirements in 40 CFR Part 63 Subpart 7777 and can no longer be
considered insignificant activities. The engines must comply with work practice standards in 40 CFR Part 63 Subpart
ZZZZ beginning May 3, 2013. The engines and the appropriate applicable requirements for these engines have been
included in Section 11.5 of the permit.
ALTERNATIVE OPERATING SCENARIOS
No new alternative operating scenarios or revisions to existing alternative operating scenarios were requested with the
renewal permit.
INSIGNIFICANT ACTIVITY LIST
- The emergency generator engines, emergency fire pump engines and cold cleaner solvent vats were removed from the
insignificant activity list. They are now included in Section II of the permit. In addition, tanks T-7802 (500 gal security day
tank) and T-8403 (20,000 gal underground diesel fuel storage tank).
PERMIT SHIELD
No additional non-applicable requirements were included in the permit shield.
at
TECHNICAL REVIEW DOCUMENT
For
RENEWAL TO OPERATING PERMIT 97OPWE180
Public Service Company — Ft. St. Vrain Station
Weld County
Source ID 1230023
Prepared by Jacqueline Joyce
May and June 2010
Revised August and 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 July 1, 2005. The expiration
date for the permit is July 1, 2010. 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 19, 2009, additional
information submitted on June 2, 2009 and August 12, 2010, a modification
application submitted on March 23, 2010, comments on the draft permit and
technical review document submitted on September 16, 2010, 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/ap/Titlev.html. This narrative is intended only as an
adjunct for the reviewer and has no legal standing.
Any revisions made to the underlying construction permits associated with this
facility made in conjunction with the processing of this operating permit
application have been reviewed in accordance with the requirements of
Regulation No. 3, Part B, Construction Permits, and have been found to meet all
applicable substantive and procedural requirements. This operating permit
incorporates and shall be considered to be a combined construction/operating
permit for any such revision, and the permittee shall be allowed to operate under
the revised conditions upon issuance of this operating permit without applying for
a revision to this permit or for an additional or revised construction permit.
Page 1
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II. Description of Source
This facility classified as an electric services facility under Standard Industrial
Classification 4911. This facility consists of five (5) natural gas fired combustion
turbines and three (3) heat recovery steam generators (HRSG). The capacity of
the steam turbine is 330 megawatts (MW). The output rating of the entire plant
varies based on ambient temperature with more generation in the winter and less
generation in the summer. The facility generates approximately 965 MW
(summer rating) of electricity. The turbines are numbered as follows: T001
(turbine No.1) is the steam turbine, T002 (turbine No. 2) is the No. 1
combustion turbine, 1003 (turbine No. 3) is the No. 2 combustion turbine,
1004 (turbine No. 4) is the No. 3 combustion turbine, 1005 (turbine No. 5) is
the No. 4 combustion turbine and 1006 (turbine No. 6) is the No. 5
combustion turbine. Combustion turbines 2 and 3 each generate
approximately 135 MW of electricity and each HSRG, which includes duct
burners for supplemental firing, will add approximately 100 MW of electrical
capacity. Combustion turbine 4, which commenced operation in April 2001,
generates approximately 135 MW of electricity and the HRSG, which includes a
duct burner for supplemental firing, will add approximately 100 MW of electrical
capacity. These combustion turbines and HRSG combinations can be run in
three modes: simple cycle (combustion turbine only), combined cycle
(combustion turbine with HRSG) with no fuel fired in the duct burners and
combined cycle (combustion turbine with HRSG) with fuel fired in the duct
burners. In simple cycle operation, exhaust from the combustion turbine is
discharged through the bypass stack. In combined cycle mode, the exhaust gas
from the turbine passes through the HRSG first and then exits out the HRSG
stack. Combustion turbines No. 5 and 6, which commenced operation in April
2009, each generate approximately 146 MW. Turbines 5 and 6 can only operate
in simple system mode. In addition to the combustion turbines, significant
emission units at this facility consist of an auxiliary boiler fueled by natural gas,
one cooling water tower, one service water tower, a 500 gallon gasoline tank and
cold cleaner solvent vats.
Based on the information available to the Division and provided by the applicant,
it appears that no modifications to the significant emission units have occurred
since the original issuance of the operating permit.
The facility is located approximately three miles north and west of Platteville,
Colorado. This facility is located in an area classified as attainment for all
pollutants except ozone. It is classified as non-attainment for ozone and is part
of the 8-hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1.
There are no affected states within 50 miles of the plant. Rocky Mountain
National Park, Eagle's Nest National Wilderness Area and Rawah National
Wilderness Area, Federal Class I designated areas, are within 100 kilometers of
the plant.
Page 2
The summary of emissions that was presented in the Technical Review
Document (TRD) for the original permit issuance has been modified to more
appropriately identify the potential to emit (PTE) with the addition of turbines 5
and 6. Emissions (in tons/yr) at the facility are as follows:
Potential to Emit (PTE)
Emission Unit PM PM10 SO2 NOx F CO VOC HAPS
Turbine (T002) 39.4 39.4 4.7 496.1 465.4 21.4 See 1
Turbine (T003) 39.4 39.4 4.7 496.1 465.4 21.4 Table on
Turbine (T004) 54 54 4.7 199.1 237.9 33.1 Page 19
Turbine (T005)* 4.45 4.45 1.85 19.95 10 1.15
Turbine (T006)" 4.45 4.45 1.85 19.95 10 1.15
Auxiliary Boiler 0.6 0.6 0.2 32.6 27.4 1.8
(B001)
Cooling/Service 14.9 14.9 2.4
Water Towers
(M001)
Total 157.2 157.2 18 1,263.8 1,216.1 82.4 18.82
*permitted emission limits are for both turbines together, emissions are assumed to be split
between the 2 units.
Potential to emit for criteria pollutants is based on permitted emission limits.
The breakdown of HAP emissions for each emission unit is provided for in the
table on page 19 of this document. HAPs were estimated as follows:
Turbines 2 and 3: Formaldehyde emissions from the turbines and duct burners
are based on emission factors determined from performance tests conducted on
these units (performance test results were multiplied by 1.7), the design heat
input rate (turbine plus duct burner) and 8760 hours per year of operation. The
test results were conducted while the units were in combined cycle mode with the
duct burners on. Emissions of other pollutants from the turbines are based on
AP-42 emission factors (Section 3.1 (dated 4/00), Table 3.1-4), except that the
acetaldehyde emission factor is from the ICCR and the manganese and nickel
emission factors are from FIRE, the design heat input rate of the turbine and
8760 hours per year of operation. Emissions of other pollutants from the duct
burners are based on AP-42 emission factors (Section 1 .4 (dated 3/98), Tables
1.4-3 and 1.4-4), except that the formaldehyde emission factor is from EPRI
handbook (4/02) and the hexane emission factor is from an EPRI paper (5/00),
the design heat input rate and 8760 hours per year of operation.
Turbine 4: Formaldehyde emissions from the turbine and duct burner are based
on the Turbine 2 performance test (test results were multiplied by 1.7) and the
permitted heat input rates for the turbine and duct burner. Emissions of other
pollutants from the turbine are based on AP-42 emission factors (Section 3.1
Page 3
(dated 4/00), Table 3.1-4), except that the acetaldehyde emission factor is from
the ICCR and the manganese and nickel emission factors are from FIRE and the
permitted heat input rate for the turbine. Emissions of other pollutants from the
duct burner are based on AP-42 emission factors (Section 1.4 (dated 3/98),
Tables 1.4-3 and 1.4-4), except that the formaldehyde emission factor is from
EPRI handbook (4/02) and the hexane emission factor is from an EPRI paper
(5/00), and the permitted heat input rate for the duct burner.
Turbines 5 and 6: HAP emissions are based on AP-42 emission factors (Section
3.1 (dated 4/00), Table 3.1-4), except that the acetaldehyde emission factor is
from the ICCR and the manganese and nickel emission factors are from FIRE,
the permitted fuel consumption rate and an assumed natural gas heat content of
1020 Btu/scf.
Auxiliary Boiler: HAP emissions are based on AP-42 emission factors (Section
1.4 (dated 3/98), Tables 1.4-3 and 1.4-4), except that the formaldehyde emission
factor is from EPRI handbook (4/02) and the hexane emission factor is from an
EPRI paper (5/00), the permitted fuel consumption rate and an assumed natural
gas heat content of 1020 Btu/scf.
Cooling and Service Water Towers: HAP emissions are based on a chloroform
emission factor of 0.05 lb/mmgal (from letter from Wayne C. Micheletti to Ed
Lasnic, dated November 11, 1992) and the permitted water circulation rate
Note that actual emissions are typically less than potential emissions and actual
emissions are shown on page 20 of this document.
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)
As discussed in the technical review document for the August 12, 2008 revised
Title V permit, these requirements do not apply for the following reasons. 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 and none of the paint
stripping chemicals used at the facility contain methylene chloride.
Gasoline Dispensing Facilities (40 CFR Part 63 Subpart CCCCCC)
Page 4
These requirements apply to the 500 gal gasoline storage tank at the facility and
are included in the current Title V permit.
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. The
insignificant activity list indicates that there are two emergency generators (one
generator is powered by two diesel engines) and an emergency fire pump engine
at the facility. Since these engines were in the July 1, 2005 Title V renewal
permit, these engines 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.
In their September 16, 2010 comments on the draft permit, the source indicated
that the security generator (driven by one diesel-fired engine) has been removed
from service. Therefore, only the station's emergency generator (driven by two
diesel-fired engines) will be addressed in the permit.
Industrial, Commercial and Institutional Boilers at Area Sources (40 CFR Part 63
Subpart JJJJJJ)
EPA has signed off on proposed rules for industrial, commercial and institutional
boilers located at area sources (the proposed rule has not been published yet in
the Federal Register). Under the proposed rule gas fired boilers are not subject
to the requirements in 40 CFR Part 63 Subpart JJJJJJ in accordance with §
63.11195(e)
Compliance Assurance Monitoring (CAM) requirements
The current Title V permit includes CAM requirements for Turbine 4. As
indicated in the technical review document to support the first renewal of the Title
V permit (issued July 1, 2005), Turbines 2 and 3 were not subject to CAM
because they are not equipped with a control device (dry low NOx combustion
systems are considered inherent process equipment). Turbines 5 and 6 are also
equipped with dry low NOx combustion systems and as such they are not
equipped with control devices and CAM does not apply to those turbines.
Page 5
Ill. Discussion of Modifications Made
Source Requested Modifications
The source's requested modifications were addressed as follows:
Addition of Turbines 5 and 6 - "New" Section 11.8
The turbines are General Electric, Model No. 7FA, natural gas-fired combustion
turbines with serial numbers 298106 and 298107. Each unit has a rated heat
input of 1,467 mmBtu/hr and output of 174 MW (design) and 146 MW (site -
annual average at 48.5 °F). The turbines are equipped with advanced dry low
NOx (DLN) combustion systems to reduce NOx emissions.
Applicable Requirements: Initial approval construction permit 07WE1100 was
issued for these units on February 6, 2008. A revised construction permit
(07WE1100) was issued on July 24, 2008 to revise the particulate matter
emission limitations. These units commenced operation in April 2009. According
to the Division's database a self-certification was received on September 23,
2009. Therefore, under the provisions of Colorado Regulation No. 3, Part C,
Section V.A.3, the Division will not issue a final approval construction permit and
is allowing the initial approval construction permit to continue in full force and
effect. A revised construction permit (07WE1100) was issued on January 28,
2010 to change the definition of startup. The appropriate applicable
requirements from the initial approval construction permit have been incorporated
into the permit as follows:
• This permit will expire if construction does not commence within 18
months of permit issuance (condition 1)
These units commenced operation in April 2009, therefore, this
requirement will not be included in the Title V permit.
• The permittee shall notify the Division 30 days prior to startup (condition 2)
As previously stated the units commenced operation in April 2009 and a
startup notice was submitted on March 4, 2009, with a revised notice
submitted May 27, 2009.
• Manufacturer, model and serial number shall be provided prior to final
approval (condition 3)
The self-certification submitted on September 23, 2009 supplied this
information; therefore, this requirement will not be included in the permit.
Page 6
• PSD requirements shall apply to this source at any such time that this
source becomes a major modification solely by virtue of relaxation of any
permit condition (condition 5)
• Major stationary source requirements for non-attainment area review shall
apply to this source at any such time that this source becomes a major
modification solely by virtue of relaxation of any permit condition (condition
6)
These conditions will not be included in the operating permit, since no
actual requirements apply, unless certain modifications to the permit
conditions for these turbines are made. Although this requirement will not
be included in the permit, future modifications that allow emissions from
these units to exceed the significance levels will result in the application of
PSD review and/or non-attainment area review.
• Except as provided for below, opacity emissions shall not exceed 20%
(condition 7, Reg 1, Section II.A.1)
• Under certain conditions, opacity emissions shall not exceed 30%
(condition 8, Reg 1, Section II.A.4)
• RACT requirements for NOx emissions (condition 9):
Note that as indicated in the preliminary analysis for the original
construction permit, RACT does not apply for VOC because at the time of
initial construction permit issuance, VOC was not listed in Reg 3, Part B,
Section III.D.2.a and Reg 7 was only applicable to the Denver 1-hr ozone
attainment/maintenance area and any nonattainment area for the 1-hr
ozone standard.
• Both turbines together are subject to the following fuel use limits (condition
10)
Natural Gas consumption, in mmscf, shall not exceed the following
limitations:
Period 1st Month of 1st 2 Months 1st 3 Months 1st 12 Annual
Operation of Operation of Operation Months of (12-Month
Operation Rolling
Total)
1089 1,633.5 2,178 2,178 2,178
The monthly limits apply for the first twelve months of operation. Since the
turbines have been operating for more than one year, the monthly limits
will not be included in the permit.
Page 7
• Both turbines together are subject to the following emission limitations
(condition 11)
Period/ 1s' Month of 1st 2 Months 1s`3 Months 1st 12 Annual
Pollutant Operation of Operation of Operation Months of (12-Month
Operation Rolling
Total)
PM 4.45 6.68 8.9 8.9 8.9
PM10 4.45 6.68 8.9 8.9 8.9
SO2 1.85 2.77 3.7 3.7 3.7
NOx 19.95 29.93 39.9 39.9 39.9
CO 10.0 15.0 20.0 20.0 20.0
VOC 1.15 1.73 2.3 2.3 2.3
The monthly limits apply for the first twelve months of operation. Since the
turbines have been operating for more than one year, the monthly limits
will not be included in the permit.
• NOx emissions from any insignificant activities associated with the two
new turbines shall be included in assessing compliance with the NOx limit
of 39.9 tons/yr (condition 12)
• Particulate matter emissions shall not exceed 0.1 lb/mmBtu (condition 13,
Reg 1, Section III.A.1.c)
• State-only requirement: new source performance standards for fuel
• burning equipment in Reg 6, Part B, Section II — includes opacity (20%)
and SO2 requirements (0.35 lb/mmBtu) (Condition 14):
• The turbines are subject to the requirements in NSPS Subpart KKKK
(Standards of Performance for Stationary Gas Combustion Turbines for
Which Construction is Commenced After February 18, 2005) and NSPS
Subpart A (General Provisions) (condition 16)
NSPS KKKK requirements include NOx emission and fuel sulfur
limitations, as well as monitoring requirements.
With respect to the monitoring requirements, NSPS KKKK allows sources
to monitor compliance with the NOx limits using a NOx CEMS. The CEMS
can either meet the requirements in 40 CFR Part 60 or 40 CFR Part 75
and since the turbines are subject to the Acid Rain requirements, the NOx
CEMS are required to meet the requirements in Part 75. Therefore the
source will follow the Part 75 requirements. To that end, the Division has
not included the requirements in § 60.4345(b) (valid hour definition under
Part 60), § 60.4350(a) (reduce to hourly averages per § 60.13(h)) and §
60.4350(b) (calculating hourly emissions). In addition, since the source is
required to use a Part 75 NOx CEMS under the Acid Rain Program and
Page 8
the construction permit requires the use of a Pad 75 NOx CEMS, the
requirements in §§ 60.4345(a) (CEMS), (c) (fuel flowmeter) and (e)
(QA/QC plan) will not be included; however, the permit will note that the
RATA will be conducted on a lb/mmBtu basis in accordance with §
60.4345(a). In addition, the Division will include the language in §
60.4350(d), which states that only quality assured data shall be used to
identify excess emissions.
Note that the general provision for notification of construction, initial
startup and CEMS demonstration, as well as the performance test
requirements, will not be included in the permit as these requirements
have been completed.
• Continuous emission monitoring system (CEMS) requirements for NOx
and CO emissions (condition 17)
• Performance tests shall be conducted for PM, NOx, CO and VOC
(condition 17)
Performance tests were conducted on these units on May 20-21, 2009.
Therefore this requirement will not be included in the permit.
• Within 180 days after issuance of this permit, compliance with these
conditions shall be demonstrated (condition 18)
A self-certification was submitted on September 23, 2009; therefore, this
requirement will not be included in the permit.
• Prior to issuance of final approval, the applicant shall submit an operating
and maintenance plan and shall follow the Division-approved operating
and maintenance plan (condition 19)
An operating and maintenance plan was submitted with the self-
certification on September 23, 2009. The appropriate requirements from
the operating and maintenance plan will be incorporated into the Title V
permit.
• An application to modify the Title V permit shall be submitted within one
year of commencing operation (condition 20).
The Title V renewal application (submitted on May 19, 2009) requested
that the provisions for construction permit 07WE1100 be incorporated into
the Title V permit and a modification application was submitted on March
23, 2010 requesting that construction permit 07WE1100 be incorporated
into the Title V permit. Since this requirement has been completed, it will
not be included in the construction permit.
• APEN reporting requirements (condition 21)
Page 9
The APEN reporting requirements will not be identified in the permit as a
specific condition but are included in Section V (General Conditions) of the
permit, condition 22.e.
Although not specifically identified in Colorado Construction Permit 07WE1100,
these turbines are subject to the following applicable requirements:
• Sulfur dioxide emissions shall not exceed 0.35 lbs/mmBtu, on a 3-hour
rolling average (Reg 1, Section VI.B.4.c.(ii) and VI.B.2)
• These units are subject to the Acid Rain requirements as follows:
o Allocated SO2 allowances are listed in 40 CFR Part 73.10(b), however,
since this is a new unit, no allowances were allocated. SO2 allowances
must be obtained per 40 CFR Part 73 to cover SO2 emissions for the
particular calendar year.
o There are no NOx emission limitations since this unit is not a coal-fired
boiler.
o Acid rain permitting requirements per 40 CFR Part 72.
o Continuous emission monitoring requirements per 40 CFR Part 75.
o This source is also subject to the sulfur dioxide allowance system (40
CFR Part 73) and excess emissions (40 CFR Part 77).
Streamlining of Applicable Requirements
Opacity
The turbines are subject to the Reg 1 20% opacity requirement and the Reg 1
30% opacity requirement for certain specific operational activities. The Reg 1
20% opacity requirement applies at all times, except for certain specific operating
conditions under which the Reg 1 30% opacity requirement applies. The turbines
are also subject to the state-only Reg 6, Part B 20% opacity requirement. Reg 6,
Part B, Section I.A, adopts, by reference, the 40 CFR Part 60 Subpart A general
provisions. 40 CFR Part 60 Subpart A § 60.11(c) specifies that the opacity
requirements are not applicable during periods of startup, shutdown and
malfunction. The Reg 1 20%/30% requirements are more stringent than the Reg
6 Part B opacity requirements during periods of startup, shutdown and
malfunction. While the Reg 6, Part B 20% opacity requirement is more stringent
during fire building, cleaning of fire boxes, soot blowing, process modifications
and adjustment or occasional cleaning of control equipment. Therefore, since no
one opacity requirement is more stringent than the other at all times, all three
opacity requirements are included in the operating permit. See the grid on page
21 for a clarified view on the opacity requirements and their relative stringency.
SO2
Page 10
The turbines are subject to the Regulation No. 1 and No. 6, Part B SO2
standards. The SO2 requirements in both Reg 1 and Reg 6, Part B are the same
standard (0.35 lb/MMBtu). The Regulation No. 6, Part B requirement is a state-
only requirement. The turbines are also subject to SO2 requirements in NSPS
Subpart KKKK. Under the NSPS, the source may choose to meet either an
outlet emission limitation or a limitation on the potential SO2 emissions in the fuel.
The limit on the potential SO2 emissions in the fuel is 0.060 lb/MMBtu, which is
lower than the Reg 1 and Reg 6 SO2 limit of 0.35 lb/MMBtu. Therefore, the Reg
1 SO2 limit will be streamlined in favor of the NSPS Subpart KKKK limit on
potential SO2 emissions in the fuel.
These turbines are also subject to the Acid Rain SO2 requirements. Sources
subject to Acid Rain must hold adequate SO2 allowances to cover annual
emissions of SO2 (1 allowance = 1 ton per year of SO2) for a given unit in a given
year. The number of allowances can increase or decrease for a unit depending
on allowance availability. Allowances are obtained through EPA, other units
operated by the utility or the allowance trading market and compliance
information is submitted (electronically) to EPA. Pursuant to Regulation No. 3,
Part C, Section V.C.1.b, if a federal requirement is more stringent than an Acid
Rain requirement, both the federal requirement and the Acid Rain requirement
shall be incorporated into the permit and shall be federally enforceable. For
these reasons, the Acid Rain SO2 requirements have not been streamlined out of
the permit. The source will have to demonstrate compliance with the Acid Rain
SO2 requirements and the NSPS KKKK SO2 requirements. Note that the Acid
Rain SO2 allowances appear only in Section III (Acid Rain Requirements) of the
permit.
NOx
The turbines are subject to a NOx RACT limit of 9 ppm at 15% O2, on a 1-hr
average, except that during periods of combustion tuning and testing, NOx is
limited to 100 ppmvd @ 15% O2, on a 1-hr average and an NSPS KKKK limit of
15 ppmvd at 15% O2, on a 4-hr rolling average. Neither the NOx RACT limit, nor
the NSPS KKKK NOx limit apply during periods of startup and shutdown,
however, those periods of excess emissions during periods of startup, shutdown
and malfunctions under which the NSPS KKKK limits are exceeded must be
identified in the excess emission reports. The NOx RACT limit is more stringent
than the NSPS KKKK limit, except during periods of combustion tuning and
testing when the NSPS KKKK limit may be more stringent. Given the difference
in averaging times (4-hr for NSPS and 1-hr for RACT) it is not clear which is
more stringent. Therefore, since the relative stringency cannot be determined
both the RACT and NSPS KKKK limits will be included in the permit.
NOx Monitoring Requirements
Page 11
The turbines are subject to several types of monitoring requirements. The
construction permit requires that the stacks be equipped with CEMS to monitor
and record NOx emissions and the construction permit requires that the Wax
CEMS meet the requirements in 40 CFR Part 75. The turbines are also subject
to the Acid Rain requirements and as such are required to monitor NOx
emissions in accordance with the requirements in 40 CFR Part 75. Finally, the
turbines are subject to NSPS KKKK which allows sources to monitor compliance
with the NOx limits using a NOx CEMS and NSPS KKKK allows sources to use a
CEMS and fuel flowmeter that meets the requirements in Part 75. Therefore,
since all of the CEMS requirements specify that the NOx CEMS meet the
requirements of Part 75, no streamlining of requirements is necessary.
SO2 Monitoring Requirements
The source has opted to follow the limit of potential SO2 emissions in the fuel and
with respect to that limitation the NSPS does not require SO2 monitoring,
provided that the source makes that determination in accordance with the
procedures in § 60.4365. The procedures in this section specify the use of a
current valid purchase contract, tariff sheet or transportation contract or
representative sampling consistent with the requirements in section 2.3.1.4 of
Part 75 Appendix D. Since these provisions are consistent with the Part 75
requirements (section 2.3.1.4 allows the pipeline quality natural gas
demonstration to be based on the purchase contract or tariff sheet), to which
these units are already subject to no streamlining is required.
Emission Factors
The source will be monitoring compliance with the NOx, CO and SO2 emission
limitations using their continuous monitoring systems. NOx and CO are
measured using CEMS and SO2 is monitored using the continuous monitoring
system required by 40 CFR Part 75 Appendix D, which requires an in-line fuel
flow meter to measure the hourly consumption of natural gas and bases
emissions on the heat input and a default emission factor of 0.0006 lbs/mmBtu.
The emission limits in the construction permit are based on manufacturer's
estimates for PM and PMlo and AP-42 (Section 3.1 (dated 4/00), Table 3.1-2a)
for VOC. However, stack tests were conducted for PM (including condensibles)
and VOC emissions and the permit will specify that the emission factors from
those tests be used to estimate emissions.
Monitoring Plan
The source will be required to monitor compliance with the NOx and CO annual
and NOx RACT emission limitations using the CEMS. Compliance with the
annual SO2 emission limits will be monitored using the continuous monitoring
system required by 40 CFR Part 75 Appendix D. Compliance with the annual
Page 12
PM, PM10 and VOC emission limitations shall be monitored using emission
factors and the heat input to the turbines.
Compliance with the various short term PM and SO2 requirements and the
opacity requirements shall be presumed, in the absence of credible evidence to
the contrary, since only natural gas is used as fuel in the turbines.
Other Modifications
In addition to the source requested modifications, the Division has included
changes to make the permit more consistent with recently issued permits, include
comments made by EPA on other Operating Permits, as well as correct errors or
omissions identified during inspections and/or discrepancies identified during
review of this renewal.
The Division has made the following revisions, based on recent internal permit
processing decisions and EPA comments to the Ft. St. Vrain Renewal Operating
Permit. 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 I — General Activities and Summary
• The description in Condition 1.1 was revised to include turbines 5 and 6,
as well as the 500 gal gasoline storage tank, the cold cleaner solvent vats
and three diesel fired engines.
• Changed the citation for the definition of 8-hour ozone control area in
Condition 1.1.
• Added construction permit number 07WE1100 to the list in Condition 1.3.
• Condition 4.1 (Accidental Release Prevention Program (112(r)) was
revised to indicated that the facility was not subject to the 112(r)
provisions. In their September 16, 2010 comments and in a September
Page 13
16, 2010 follow-up e-mail, the source indicated that the requirements no
longer applied.
• Removed the third column labeled "Facility ID" from the Table in Condition
6.1, as the ID number is the same as that in the first column. The first
column was relabeled "Emission Unit No./Facility ID".
• Added a column to the Table in Condition 6.1 for the startup date of the
equipment. In addition, turbines 5 and 6 and the cold cleaner solvent vats
were added to the table.
Section 11.1 & 2
• Revised the monitoring requirements for the NSPS Da opacity limits
(Conditions 1.16 and 2.15) to include the specific opacity monitoring
requirements in NSPS Da. Revisions were made to NSPS Da on January
28, 2009 to allow alternatives for using a COMS. Previous versions of
NSPS Da did not require sources that burned only natural gas as fuel to
install and operate a COMS; however, this exception was removed in the
January 28, 2009 revisions. Under the January 28, 2009 revisions
sources that are subject to NSPS Da and burn natural gas as fuel must
either install a COMS or use the alternative methods provided (i.e. Method
9 observations). Frequency of Method 9 observations are annual when no
visible emissions are observed and as such it is expected that frequency
of Method 9 observations would be annually.
• The compliance demonstration methods for the NOx and CO BACT limits
in Condition 1.2.1, 1.3.1, 2.5.1 and 2.6.1 have been revised in order to be
consistent with current permits. At the time these units were permitted,
the Division allowed any clock hour that included any startup or shutdown
time to be compared to the startup and/or shutdown BACT limit. However,
since the CEMS can be programmed to average only startup and/or
shutdown time together the Division has moved away from this practice.
Therefore the permit has been revised to allow only startup and/or
shutdown time to be averaged together and compared to the startup
and/or shutdown BACT limits.
• The definition of startup in Condition 1.2.1.6 was revised to specify that
startup begins when fuel is first fired in the turbines and ends when the
turbine reaches Mode 6 operation plus 15 minutes. In their September 16,
2010 comments on the draft permit and technical review document, the
source requested the change to allow for the CEMS to settle after Mode 6
operation is initially reached. In addition, the September 16, 2010
comments requested changes to the startup definition with regards to how
the end of startup (Mode 6 operation) is documented and stored.
Page 14
• Removed the paragraph in Condition 2.5.1 that specified that the data
acquisition and handling system would be revised within 30 days of
revised permit issuance [August 12, 2008] since this action has been
completed.
• Revised the language in Condition 1.12 to specify that performance tests
be conducted every five years, rather than within 18 months of expiration
of the permit term as this provides a more definitive time frame for the
tests.
• Condition 1.6.4.1 was revised to include the PM and PM10 emission
factors from the latest performance test in the permit. The source
requested this change in their September 16, 2010 comments on the draft
permit.
Section 11.5 — Continuous Emission Monitoring Systems (GEMS)
• Revised conditions 5.1.1 and 5.1.3 to indicate that ppmvd values shall be
corrected to 15% O2.
• Removed the last sentence in Condition 5.2.1.1, since this relates to
COMS and since the units burn natural gas as fuel a COMS is not
required as specified in § 75.14(c)
• Condition 5.3 will be revised to be more consistent with more recently
issued Title V permits for natural gas fired combustion turbine electric
generating stations.
Section 11.6 — Gasoline Storage Tank
Colorado Regulation No. 7 was revised on December 12, 2008 (effective January
30, 2009) to cover all ozone nonattainment areas (previously Reg 7 applied to
the Denver 1-hr ozone attainment maintenance area and to any non-attainment
area for the 1-hr ozone standard) and as a result the requirements in Colorado
Regulation No. 7, Section VI.B.3 potentially apply to the gasoline storage tank.
However, since the storage tank is less than 550 gallons the tank is exempt from
the requirements in Section VI.B.3 as specified in Section IV.B.3.b.(i).
In addition, the following note was added under the summary table "Note that this
emission unit is exempt from the APEN reporting requirements in Regulation
No.3, Part A and the construction permit requirements in Regulation No. 3, Part
B."
"New" Section 11.7 — Cold Cleaner Solvent Vats
Solvent cold cleaners are included in the insignificant activity list in the current
Title V permit. However, as discussed previously, Colorado Regulation No. 7
was revised to cover all ozone nonattainment areas and as such the solvent cold
Page 15
cleaners are subject to requirements in Colorado Regulation No. 7, Section X.
Although emissions from the solvent vats are below the APEN de minimis level
and therefore exempt from both APEN reporting and construction permit
requirements, under the "catch-all" provisions in Regulation No. 3, Part C,
Section II.E (2nd paragraph) the solvent vats cannot be considered insignificant
activities because they are subject to specific requirements in Regulation No. 7.
Since the solvent vats cannot be considered insignificant activities, they will be
included in the Operating Permit as significant emission units.
The applicable requirements from Regulation No. 7 for these units are as follows:
• Transfer and storage of waste solvent and used solvent (Reg 7, Sections
X.A.3 and 4)
• Solvent Cold Cleaner Requirements (Reg 7, Section X.B)
o Control Equipment - covers, drainage, labeling and spray apparatus
requirements (Reg 7, Section X.B.1)
o Operating Requirements (Reg 7, Section X.B.2)
"New" Section 11.9 — Emergency Compression Ignition Engines
There are three engines included in the insignificant activity list that are
considered insignificant under either the provisions in Colorado Regulation No. 3,
Part C, Sections II.E.3.nnn (emergency generators) or xxx (stationary internal
combustion engines). However, under the "catch-all" provisions in Regulation
No. 3, Part C, Section II.E, sources that are subject to any federal or state
applicable requirement, such as National Emission Standards for Hazardous Air
Pollutants (NESHAPs), may not be considered insignificant activities. EPA
promulgated National Emission Standards for Hazardous Air Pollutants for
Reciprocating Internal Combustion Engines on March 3, 2010 which apply to
these engines; therefore, they can no longer be considered insignificant
activities. Although the units cannot be considered insignificant activities, since
the Division has not adopted either the January 18, 2008 or March 3, 2010
revisions to the RICE MACT, both of which address area sources, the engines
are still exempt from APEN reporting and minor source construction permit
requirements.
Engine descriptions are as follows:
Two (2) Caterpillar, Model No. SP321P00, Serial No. 126906 and 126907,
diesel-fired engines, each Rated at 1,800 hp, with a combined fuel rate of
200 gallhr (27.4 mmBtu/hr, based on a diesel fuel heat content of 137,000
Btu/gal). The engines are run together to drive an emergency generator.
The engines must run together, they cannot run independent of each other.
Page 16
One (1) Cummins, Model No. 6BTA5.963, Serial No. 46927201, diesel-fired
engine, Rated at 255, with a fuel rate of 3 gal/hr (0.41 mmBtu/hr, based on a
diesel fuel heat content of 137,000 Btu/gal)
The appropriate applicable requirements for these engines are as follows:
• Except as provided for below, visible emissions shall not exceed 20%
opacity (Reg 1, Section II.A.1)
• Visible emissions shall not exceed 30% opacity, for a period or periods
aggregating more than six (6) minutes in any sixty (60) minute period,
during fire building, cleaning of fire boxes, soot blowing, start-up, process
modifications, or adjustment or occasional cleaning of control equipment,
when burning coal (Reg 1, Section II.A.4)
Based on engineering judgment, the Division believes that the operational
activities of fire building, cleaning of fire boxes and soot blowing do not
apply to diesel engines. In addition, since these engines are not equipped
with control equipment the operational activities of adjustment or
occasional cleaning of control equipment also do not apply to the engines.
Finally, based on engineering judgment, it is unlikely that process
modifications will occur with these emergency engines. Therefore, for
these units the 30% opacity provision only applies during startup.
• SO2 emission shall not exceed 0.8 lbs/mmBtu (Reg 1, Section VI.B.4.b.(i)).
• 40 CFR Part 63 Subpart ZZZZ requirements — management practices (oil
and filter change, inspect air cleaner and inspect hoses and belts)
• 40 CFR Part 63 Subpart A requirements
Since these engines are 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 these emission units are existing the requirement 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.
Since these units are not subject to APEN reporting or minor source construction
permit requirements, the permit will not include any requirements for calculating
emissions.
Section III —Acid Rain Permit
• Turbines 5 and 6 were added.
Page 17
• Revised the table to include calendar years corresponding to the relevant
permit term for the renewal. Note that all tables were included into one
table.
• Removed the statement indicating that the source is not required to hold
allowances until 2000 for Turbines 2 and 3 as this is no longer relevant. In
addition, the first footnote under the table for Turbine 4 was removed as it
is no longer relevant.
• Minor changes were made to the standard requirements, based on
changes made to 40 CFR Part 72 § 72.9.
Section IV— Permit Shield
• Removed Colorado Regulation No. 7 (except for Section V, Paragraphs
VI.B.1 & 2 and Subsection VII.C) from the permit shield as a non-
applicable requirement (Section 111.1). Colorado Regulation No. 7 has
been revised to apply to any nonattainment area for the 8-hr ozone
standard.
Section V— General Conditions
• Added a version date to the General Conditions.
• The title for Condition 6 was changed from "Emission Standards for
Asbestos" to "Emission Controls for Asbestos" and in the text the phrase
"emission standards for asbestos" was changed to "asbestos control".
• 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
• As discussed previously, the solvent cold cleaners, emergency generators
and emergency fire water pump were removed from the insignificant
activity list in Appendix A and are included in Section II of the permit.
• In their September 16, 2010 comments on the draft permit, the source
indicated that tanks T-7802 (500 gal security day tank) and T-8403
(20,000 gal underground tank storing diesel fuel) had been removed from
service; therefore, these tanks were removed from the insignificant activity
list in Appendix A.
• Included Turbines 5 and 6 and the cold cleaner solvent vats in the tables
in Appendices B and C.
Page 18
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Colorado Department
of Public Health
and Environment
OPERATING PERMIT
Ft. St. Vrain Station
First Issued: January 1 , 2000
Renewed: DRAFT
AIR POLLUTION CONTROL DIVISION
COLORADO OPERATING PERMIT
FACILITY NAME: Ft. St. Vrain Station OPERATING PERMIT NUMBER
FACILITY ID: 1230023 97OPWE 180
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:
Public Service Company 16805 County Road 19'/2
P. O. Box 840 Platteville, CO 80651
Denver, CO 80201-0840 Weld County
INFORMATION RELIED UPON
Operating Permit Renewal Application
Received: May 19, 2009
And Additional Information Received: June 2, 2009, March 23, August 12 and September 16, 2010
Nature of Business: Combustion Gas Turbine Electric Generating Station
Primary SIC: 4911
RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON
Name: Steve Mills Name: Dean Metcalf
Title: General Manager—Power Title: Director, Air and Water
Generation, Colorado
Phone: (303) 628-2679 Phone: (720) 497-2007
SUBMITTAL DEADLINES
Semi-Annual Monitoring Period: EXAMPLE (July 1 - December 31, January 1 —June 30)
Semi-Annual Monitoring Report: EXAMPLE (Due Feb. 1, 2006 & Aug. 1, 2006 & subsequent years)
First Annual Compliance Period: EXAMPLE (July 1 — December 31)
Subsequent Annual Compliance Periods: EXAMPLE (January 1 — December 31)
Annual Compliance Certification: EXAMPLET (Due February 1, 2006 & subsequent years)
Note that the Semi-Annual Monitoring Reports and Annual Compliance Certifications must be received
at the Division office by 5:00 p.m. on the due date. Postmarked dates will not be accepted for the
purposes of determining the timely receipt of those reports/certifications.
FOR ACID RAIN SUBMITTAL DEADLINES SEE SECTION III.4 OF THIS PERMIT
TABLE OF CONTENTS:
SECTION I - General Activities and Summary 1
1. Permitted Activities 1
2. Alternative Operating Scenarios 2
3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant
Deterioration (PSD) 3
4. Accidental Release Prevention Program (112(r)) 3
5. Compliance Assurance Monitoring (CAM) 3
6. Summary of Emission Units 4
SECTION II - Specific Permit Terms 6
1. T002 & T003 — Two (2) Combustion Turbines Capable of Simple or Combined Cycle
Operation 6
2. T004 —Combustion Turbine Capable of Simple or Combined Cycle Operation 21
3. B001 - Auxiliary Boiler 39
4. M001 - Cooling Water and Service Water Towers 41
5. Continuous Emission Monitoring Systems (CEMS) 42
6. M002 - Gasoline Storage Tank, 500 gallons aboveground 47
7. M002 —Cold Cleaner Solvent Vats 48
8. T005 & T006—Two (2) Simple Cycle Combustion Turbines 49
9. M004 - Diesel Fuel Fired Internal Combustion Engines 57
SECTION III - Acid Rain Requirements 63
1. Designated Representative and Alternate Designated Representative 63
2. Sulfur Dioxide Emission Allowances and Nitrogen Oxide Emission Limitations 63
3. Standard Requirements 64
4. Reporting Requirements 67
5. Comments,Notes and Justifications 68
SECTION IV -Permit Shield 69
1. Specific Non-Applicable Requirements 69
2. General Conditions 69
3. Streamlined Conditions 70
SECTION V - General Permit Conditions 71
1. Administrative Changes 71
2. Certification Requirements 71
3. Common Provisions 71
4. Compliance Requirements 75
5. Emergency Provisions 76
6. Emission Controls for Asbestos 76
7. Emissions Trading, Marketable Permits, Economic Incentives 76
8. Fee Payment 76
9. Fugitive Particulate Emissions 77
10. Inspection and Entry 77
11. Minor Permit Modifications 77
12. New Source Review 77
13. No Property Rights Conveyed 77
14. Odor 77
TABLE OF CONTENTS:
15. Off-Permit Changes to the Source 78
16. Opacity 78
17. Open Burning 78
18. Ozone Depleting Compounds 78
19. Permit Expiration and Renewal 78
20. Portable Sources 78
21. Prompt Deviation Reporting 78
22. Record Keeping and Reporting Requirements 79
23. Reopenings for Cause 80
24. Section 502(b)(10) Changes 80
25. Severability Clause 81
26. Significant Permit Modifications 81
27. Special Provisions Concerning the Acid Rain Program 81
28. Transfer or Assignment of Ownership 81
29. Volatile Organic Compounds 81
30. Wood Stoves and Wood burning Appliances 82
APPENDIX A- Inspection Information 1
Directions to Plant: 1
Safety Equipment Required. 1
Facility Plot Plan: 1
List of Insignificant Activities- 1
APPENDIX B I
Reporting Requirements and Definitions 1
Monitoring and Permit Deviation Report - Part I 5
Monitoring and Permit Deviation Report - Part II 8
Monitoring and Permit Deviation Report - Part III 10
APPENDIX C 1
Required Format for Annual Compliance Certification Reports 1
APPENDIX D 1
Notification Addresses 1
APPENDIX E 1
Permit Acronyms 1
APPENDIX F 1
Permit Modifications 1
APPENDIX G 1
Bypass Stack CEMS QA/QC Requirements 1
APPENDIX H 1
VOC Correlation Equations 1
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit #97OPWE180 Page 1
SECTION I - General Activities and Summary
1. Permitted Activities
1.1 This facility is a decommissioned nuclear power generating facility. Nuclear operations ceased
at this facility in 1989 and decommissioning was completed in 1996. The repowering of this
facility utilized a large portion of the non-nuclear assets such as the steam turbine, the cooling
water system, condensate and feed water system, water treatment systems, and a substation. This
facility consists of five (5) natural gas fired combustion turbines and three (3) heat recovery
steam generators (HRSG).. The capacity of the steam turbine is 330 megawatts (MW). The
output rating of the entire plant varies based on ambient temperature with more generation in the
winter and less generation in the summer. The facility generates approximately 965 MW
(summer rating) of electricity. The turbines are numbered as follows: T001 (turbine No.1) is
the steam turbine, T002 (turbine No. 2) is the No. 1 combustion turbine, T003 (turbine No.
3) is the No. 2 combustion turbine, T004 (turbine No. 4) is the No. 3 combustion turbine,
T005 (turbine No. 5) is the No. 4 combustion turbine and T006 (turbine No. 6) is the No. 5
combustion turbine. Combustion turbines 2 and 3 each generate approximately 135 MW of
electricity and each HSRG, which includes duct burners for supplemental firing, will add
approximately 100 MW of electrical capacity. Combustion turbine 4, which commenced
operation in April 2001, generates approximately 135 MW of electricity and the HRSG, which
includes a duct burner for supplemental firing, will add approximately 100 MW of electrical
capacity. These combustion turbines and HRSG combinations can be run in three modes:
simple cycle (combustion turbine only), combined cycle (combustion turbine with HRSG) with
no fuel fired in the duct burners and combined cycle (combustion turbine with HRSG) with fuel
fired in the duct burners. In simple cycle operation, exhaust from the combustion turbine is
discharged through the bypass stack. In combined cycle operation, the exhaust gas from the
turbine passes through the HRSG first and then exits out the HRSG stack. Combustion turbines
No. 5 and 6, which commenced operation in April 2009, each generate approximately 146 MW.
Turbines 5 and 6 can only operate in simple cycle mode. In addition to the combustion turbines,
significant emission units at this facility consist of an auxiliary boiler fueled by natural gas, one
cooling water tower, one service water tower, a 500 gal gasoline tank, cold cleaner solvent vats,
two (2) diesel-fired engines driving an emergency generator and one (1) diesel-fired engine
driving an emergency fire pump.
The facility is located approximately three miles north and west of Platteville, Colorado. The
area in which the plant operates is designated as attainment for all criteria pollutants except
ozone. It is classified as non-attainment for ozone and is part of the 8-hr Ozone Control Area as
defined in Regulation No. 7, Section II.A.1.
There are no affected states within 50 miles of the plant. Rocky Mountain National Park,
Eagle's Nest National Wilderness Area and Rawah National Wilderness Area, Federal Class I
designated areas, are within 100 kilometers of the plant.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 2
1.2 Until such time as this permit expires or is modified or revoked, the permittee is allowed to
discharge air pollutants from this facility in accordance with the requirements, limitations, and
conditions of this permit.
1.3 This Operating Permit incorporates the applicable requirements contained in the underlying
construction permits, and does not affect those applicable requirements, except as modified
during review of the application or as modified subsequent to permit issuance using the
modification procedures found in Regulation No. 3, Part C. These Part C procedures meet all
applicable substantive New Source Review requirements of Part B. Any revisions made using
the provisions of Regulation No. 3, Part C shall become new applicable requirements for
purposes of this Operating Permit and shall survive reissuance. This Operating Permit
incorporates the applicable requirements (except as noted in Section II) from the following
Colorado Construction Permits: 94WE609 (PSD), 97WE0189, 99WE0762 PSD and 07AD1100.
1.4 All conditions in this permit are enforceable by US Environmental Protection Agency, Colorado
Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless
otherwise specified. State-only enforceable conditions are: Permit Condition Number(s):
Section II - Conditions 1.13, 2.14 and 8.14 (Opacity) and 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.
2. Alternative Operating Scenarios
2.1 The permittee shall be allowed to make the following changes to its method of operation without
applying for a revision of this permit.
2.1.1 Turbines No. 2, 3 and 4 may be operated as follows:
2.1.1.1 The combustion turbines may be operated as simple cycle combustion
turbines as specified under Section II.
2.1.1.2 The combustion turbines may be operated as combined cycle combustion
turbines with no supplemental fuel being fired in the duct burners as
specified under Section II.
2.1.1.3 The combustion turbines may be operated as combined cycle combustion
turbines with supplemental fuel being fired in the duct burners as specified
under Section II.
2.2 The facility must contemporaneously with making a change from one operating scenario to
another, maintain records at the facility of the scenario under which it is operating (Colorado
Regulation No. 3, Part A, Section IV.A.1).
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 3
3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant Deterioration
(PSD)
3.1 This facility is categorized as a PSD major stationary source (potential to emit of PM, PM10,
NOx and CO > 100 tons/year). Future modifications at this facility resulting in a significant net
emissions increase (see Colorado Regulation No. 3, Part D, Sections II.A.26 and 42) or a
modification which is major by itself(Potential to Emit > 100 tons/year) for any pollutant listed
in Colorado Regulation 3, Part D, Section II.A.42 for which the area is in attainment or
attainment/maintenance may result in the application of the PSD review requirements.
3.2 This source is categorized as a NANSR major stationary source (Potential to Emit of NOx >100
tons/year). Future modifications at this facility resulting in a significant net emissions increase
(see Regulation No. 3, Part D, Sections II.A.26 and 42) for VOC or NOx or a modification which
is major by itself (Potential to Emit > 100 tons/year of either VOC or NOx) may result in the
application of the NANSR review requirements.
3.3 There are no other Operating Permits associated with this facility for purposes of determining
applicability of 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:
Unit T004—Combustion Turbine
See Section 11, Condition 2.9 for compliance assurance monitoring requirements.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 4
6. Summary of Emission Units
6.1 The emissions units regulated by this permit are the following:
Emission AIRS Description Startup Date Pollution Control
Unit No./ Stack Device
Facility Number
ID.
T002 004 General Electric Combustion Turbine, Model No. GE February 1996 Dry Low NOx
Frame 7FA, Serial No. 296677, rated at 1773 mmBtu/hr (simple cycle Burners
(turbine 1,223 mmBtu/hr and duct burner 450 mmBtu/hr), operation)
Natural Gas Fired. Turbine May be Operated in March 1998
Conjunction with a HRSG(combined cycle operation) (combined cycle
Equipped with Natural Gas Fired Duct Burners. operation)
T003 005 General Electric Combustion Turbine, Model No. GE January 1999 Dry Low NOx
Frame 7FA, Serial No. 297096, rated at 1823 mmBtu/hr (simple cycle Burners
(turbine 1,373 mmBtu/hr and duct burner 450 mmBtu/hr), operation)
Natural Gas Fired. Turbine May be Operated in April 1999
Conjunction with a HRSG(combined cycle operation) (combined cycle
Equipped with Natural Gas Fired Duct Burners. operation)
T004 008 General Electric Combustion Turbine, Model PG7241 April 2001 Turbine-Dry
(FA), Serial No. 297457,rated at 1953 mmBtu/hr(turbine Low NOx
1,531 mmBtu/hr and duct burner 422 mmBtu/hr),Natural HRSG—
Gas Fired. Turbine May be Operated in Conjunction with a Selective
HRSG(combined cycle operation) Equipped with One(1) Catalytic
Vogt-NEM Natural Gas Fired Duct Burner. Reduction(SCR)
B001 001 Babcock and Wilcox, Model FM-1656, External 1969,modified Uncontrolled
Combustion Auxiliary Boiler, Serial No. NB22845, Rated September 1997 to
at 70.23 mmBtu/hr. Natural Gas Fired. burn only natural
gas
M001 006 One(1) Marley Cooling Water Tower, Model No. Cross- 1976 Drift Eliminators
Flow DF-664, Design Rate of 156,000 gpm and One(1)
Marley Service Water Tower, Model No. 6-48-3-02,
Design Rate of 15,000 gpm.
M002 N/A Gasoline Storage Tank, 500 gallons,aboveground Uncontrolled
M003 N/A Cold Cleaner Solvent Vats Uncontrolled
T005 010 General Electric Combustion Turbine, Model No. 7FA, April 2009 Advanced Dry
Serial Number 298106,rated at 1,467 mmBtu/hr,Natural Low NOx
Gas Fired. Combustion
System
T006 011 General Electric Combustion Turbine, Model No. 7FA, April 2009 Advanced Dry
Serial Number 298107, rated at 1,467 mmBtu/hr,Natural Low NOx
Gas Fired. Combustion
System
Operating Permit Number: 97OPWEI80 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 5
Emission AIRS Description Startup Date Pollution Control
Unit No./ Stack Device
Facility Number
ID.
M004 N/A Two(2)Caterpillar, Model No. SP321 P00, Serial Nos. Uncontrolled
126906 and 126907,diesel-fired engines,each rated at
1,800 hp, with a combined fuel rate of 200 gal/hr. The
engines are run together to drive an emergency generator.
One(1)Cummins, Model No. 6BTA5.963, Serial No.
46927201,rated at 255 hp with fuel rate of 3 gal/hr. The
engine runs an emergency fire pump.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 6
SECTION II - Specific Permit Terms
1. T002 & T003 —Two (2) Combustion Turbines Capable of Simple or Combined Cycle Operation
Simple Cycle - Two (2) Combustion Turbines
Combined Cycle (No Supplemental Fuel) - Two (2) Combustion Turbines & Two (2) Heat
Recovery Steam Generators (HRSG)with No Fuel Fired in Duct Burners
Combined Cycle (With Supplemental Fuel)—Two (2) Combustion Turbines & Two (2) Heat
Recovery Steam Generators (HRSG) with Fuel Fired in Duct Burners
Unless otherwise specified, the limitations identified are per combustion turbine/HRSG
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
NOx 1.2. Simple Cycle Mode or Combined N/A Continuous Continuously
Cycle Mode—No Supplemental Emission
Fuel: Monitoring
15 ppmvd @ 15%O2 on a 1-hr System
average, except as provided for below
During Startup and Shutdown:
100 ppmvd @ 15%O2 on a I-hr
average
During Combustion Tuning and
Testing(not to exceed 90 hrs/yr per
for all three turbines combined):
100 ppmvd @ 15%O2 on a 1-hr
average
Combined Cycle Mode—With
Supplemental Fuel:
17 ppmvd @ 15%O2 on a 1-hr
average, except as provided for below
During Startup and Shutdown:
100 ppmvd @ 15%O2 on a I-hr
average
During Combustion Tuning and
Testing(not to exceed 90 hrs/yr per
for all three turbines combined):
100 ppmvd @ 15%O,on a 1-hr
average
N/A I 496.1 tons/yr
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 7
Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
CO 1.3. Simple Cycle Mode or Combined N/A Continuous Continuously
Cycle Mode—No Supplemental Emission
Fuel: Monitoring
15 ppmvd @ 15%O2 on a 1-hr System
average, except as provided for below
During Startup and Shutdown:
1000 ppmvd @ 15%O2 on a 1-hr
average and 2,060 lbs/hr
During Combustion Tuning and
Testing(not to exceed 90 hrs/yr per
for all three turbines combined):
1000 ppmvd @ 15%O2 on a 1-hr
average and 2,060 lbs/hr
Combined Cycle Mode—With
Supplemental Fuel:
48 ppmvd @ 15%O2 on a I-hr
average, except as provided for below
During Startup and Shutdown:
1000 ppmvd @ 15%O2 on a 1-hr
average and 2,060 lbs/hr
During Combustion Tuning and
Testing(not to exceed 90 hrs/yr per
for all three turbines combined):
1000 ppmvd @ 15%O2 on a 1-hr
average and 2,060 lbs/hr
N/A I 465.4 tons/yr
SO2 1.4. For Each Combustion Turbine: N/A Fuel Restriction Only Pipeline
0.35 lbs/mmBtu,on a 3-Flour Rolling Quality Natural
Average Gas is Used as
Fuel
For Each Combustion Turbine:
150 ppmvd @ 15%O2 or Use of Fuel
Which Contains Less than 0.8 Weight
%Sulfur
For Each Duct Burner:
0.20 lbs/mmBtu, on a 30-Day Rolling
Average
N/A 4.7 tons/yr Continuous Continuously
Monitoring
System
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWEl80 Page 8
Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
VOC 1.5. Simple Cycle and Combined Cycle N/A Continuous Continuously
—No Supplemental Fuel: Monitoring
1.4 ppmvd @ 15%O2, on a 1-Hour System
Average
Combined Cycle—With
Supplemental Fuel:
1.7 ppmvd @ 15%O2, on a 1-Hour
Average
N/A I 21.4 tons/yr
PM 1.6. For Each Combustion Turbine: N/A Fuel Restriction Only Pipeline
0.1 Ibs/mmBtu,the average of three Quality Natural
(3) 1-hr tests Gas is Used as
For Each Combustion Turbine and Fuel
Duct Burner Together:
0.1 lbs/mmBtu,the average of three
(3) 1-hr tests
For Each Duct Burner:
0.03 lbs/mmBtu, the average of three
(3)2-hr tests
N/A 39.4 tons/yr See Condition Recordkeeping, Monthly, Every
1.6. Calculation and Five (5)Years
Performance
Testing
PM 10 1.7. 9 lbs/hr 39.4 tons/yr See Condition Recordkeeping, Monthly, Once
1.7. Calculation and per Permit
Performance Term
Testing
Natural Gas 1.8. N/A Simple Cycle N/A Recordkeeping Monthly
Usage and/or Combined
Cycle Without
Supplemental
Fuel:
12,507 mmSCF/yr
Combined Cycle
With
Supplemental
Fuel:
16,090 mmSCF/yr
Sulfur Content 1.9. N/A N/A N/A See Condition 1.9.
of Natural Gas
Continuous 1.10. N/A N/A N/A See Condition 1.10
Emission
Monitoring
System
Requirements
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
•
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 9
Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
NSPS General 1.11. N/A N/A N/A As Required by Subject to
Provisions NSPS General NSPS General
Provisions Provisions
Performance 1.12. N/A N/A N/A EPA Reference See Condition
Test Methods 1.12.
Requirements
Opacity-State 1.13. Not to Exceed 20% N/A Fuel Restriction Only Pipeline
Only Quality Natural
Gas is Used as
Fuel
Opacity 1.14. Not to Exceed 20%Except as N/A
Provided for in 1.15 Below
Opacity 1.15. For Certain Operational Activities- N/A
Not to Exceed 30%, for a Period or
Periods Aggregating More than Six
(6)Minutes in any 60 Consecutive
Minutes
NSPS Opacity 1.16. Not to Exceed 20%(6-minute N/A See Condition 1.16
Applies to Duct average), Except for One Six Minute
Burner Only Average Not to Exceed 27%Per Hour
Acid Rain 1.17. See Section III of this Permit Certification Annually
Requirements
1.1 These combustion turbines/HRSGs/duct burners are subject to the requirements of the
Prevention of Significant Deterioration (PSD) Program.
1.1.1 Best Available Control Technology (BACT) shall be applied for control of Nitrogen
Oxides (NOx), Carbon Monoxide (CO), Volatile Organic Compounds (VOC) and
Particulate Matter (PM and PM10). BACT has been determined as follows:
1.1.1.1 BACT for NOx has been determined to be Dry Low NOx (DLN)
Combustion Systems with emission limits as identified in Condition 1.2.1
(Colorado Construction Permit 94WE609 PSD, as modified under the
provisions of Section I, Condition 1.3). The DLN combustion systems
shall be operated and maintained in accordance with manufacturer's
recommendations and good engineering practices.
1.1.1.2 BACT for CO has been determined to be good combustion
practices/monitoring systems capable of meeting the emission limitations
in Condition 1.3.1 (Colorado Construction Permit 94WE609 PSD).
1.1.1.3 BACT for VOC has been determined to be good combustion
practices/monitoring systems capable of meeting the emission limitations
in Condition 1.5.1 (Colorado Construction Permit 94WE609 PSD).
1.1.1.4 BACT for PM and PM lo has been determined to be use of pipeline quality
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWEI80 Page 10
natural gas (Colorado Construction Permit 94WE609 PSD).
1.2 Nitrogen Oxide (NOx) emissions shall not exceed the following limitations:
1.2.1 The BACT emission limits for each combustion turbine/HRSG/duct burner are as
follows (Colorado Construction Permit 94WE609 PSD, as modified under the
provisions of Section I, Condition 1.3):
1.2.1.1 Except as provided for in Conditions 1.2.1.3 and 1.2.1.4 below, emissions
of NOx shall not exceed 15 ppmvd at 15 % O2, on a 1-hour average. This
standard applies when operating in either simple cycle mode or
combined cycle mode without supplemental fuel.
1.2.1.2 Except as provided for in Conditions 1.2.1.3 and 1.2.1.4 below, emissions
of NOx shall not exceed 17 ppmvd at 15 % O2, on a 1-hour average. This
standard applies when operating in combined cycle mode with
supplemental fuel.
1.2.1.3 During periods of startup and shutdown emissions of NOx shall not
exceed 100 ppmvd at 15% O2, on a 1-hr average.
1.2.1.4 During periods of combustion tuning and testing emissions of NOx shall
not exceed 100 ppmvd at 15% O2, on a 1-hour average. Use of this NOx
emission limit for purposes of combustion tuning and testing shall not
exceed 90 hours in any calendar year for all three turbines combined.
Records of the number of hours each turbine undergoes combustion tuning
and testing shall be recorded and maintained and made available to the
Division upon request.
1.2.1.5 "Startup" means the setting in operation of any air pollution source for any
purpose. Setting in operation for these turbines begins when fuel is first
combusted in the turbine and ends 15 minutes after the turbine reaches
Mode 6 operation. Mode 6 refers to the condition when all six burner
nozzles are being fired. The station control system and each unit's data
acquisition and handling system (DAHS) utilized by the continuous
emission monitoring systems indicates which Mode the turbine is
operating in. A record of when Mode 6 combustion configuration plus 15
minutes is achieved is stored in each unit's DAHS.
1.2.1.6 "Shutdown" means the cessation of operation of any air pollution source
for any purpose. The cessation of operation for these turbines begins
when the command signal is initiated to shutdown the unit and ends when
fuel is no longer being fired in the turbine.
1.2.1.7 "Combustion Tuning and Testing" means the operation of the unit for the
purpose of performing combustion tuning and testing operations after a
unit overhaul or as part of routine maintenance operations. Combustion
tuning and testing can occur throughout the range of the operating
conditions.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 11
Compliance with these NOx limitations shall be monitored using the continuous
emission monitoring system (CEMS) required by Condition 1.10, as follows:
1.2.1.8 Except as provided for in Condition 1.2.1.9, all valid CEMS concentration
(ppm) data points, excluding startup and shutdown data points shall, at the
end of each clock hour be summarized to generate the average NOx
concentration. Each clock hour average NOx concentration shall be
compared to the limitations in Conditions 1.2.1.1, 1.2.1.2 or 1.2.1.4, as
appropriate.
1.2.1.9 All valid CEMS concentration (ppm) data points, excluding non-startup
and non-shutdown data points shall, at the end of each clock hour be
summarized to generate the average NOx concentration. Each clock hour
average NOx concentration shall be compared to the limitation in
Condition 1.2.1.3.
In the event that a startup ends within a clock hour or shutdown begins
within a clock hour, all non-startup and/or non-shutdown concentration
(ppm) data points within that clock hour shall be averaged together to
generate the average NOx concentration and that average concentration
shall be compared to the limitations in Conditions 1.2.1.1, 1.2.1.2 or
1.2.1.4, as appropriate.
1.2.1.10 The emission limitation in Condition 1.2.1.4 applies to any clock hour in
which combustion tuning and testing activities occur.
1.2.2 Nitrogen Oxide (NOx) emissions from each combustion turbine/HRSG/duct
burner shall not exceed 496.1 tons/yr(Colorado Construction Permit 94WE609 PSD,
as modified under the provisions of Section I, Condition 1.3). Compliance with this
requirement shall be monitored using the Continuous Emission Monitoring System
(CEMS) required by Condition 1.10.
A twelve month rolling total of emissions will be maintained to monitor compliance
with the annual emission limitation. Each month a new twelve month total shall be
calculated using the previous twelve months data.
1.3 Carbon Monoxide (CO) emissions shall not exceed the following limitations:
1.3.1 The BACT Carbon Monoxide (CO) emission limit for each combustion
turbine/HRSG/duct burner is as follows (94WE609 PSD, as modified under the
provisions of Section I, Condition 1.3):
1.3.1.1 Except as provided for in Conditions 1.3.1.3 and 1.3.1.4 below, emissions
of CO shall not exceed 15 ppmvd at 15% O2, on a 1-hour average. This
standard applies when operating in either simple cycle mode or
combined cycle mode without supplemental fuel.
1.3.1.2 Except as provided for in Conditions 1.3.1.3 and 1.3.1.4 below, emissions
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 12
of CO shall not exceed 48 ppmvd at 15% O2, on a 1-hour average. This
standard applies when operating in combined cycle mode with
supplemental fuel.
1.3.1.3 During periods of startup and shutdown emissions of CO shall not exceed
1,000 ppmvd at 15% O2, on a 1-hr average and 2,060 lbs/hr. In the event
that emissions of CO exceed 1,000 ppmvd at 15% O2, it shall be
considered a violation of the CO BACT emission limit if CO emissions
exceed 2,060 lbs/hr and not a violation if emissions are less than or equal
to 2,060 lbs/hr.
1.3.1.4 During periods of combustion tuning and testing emissions of CO shall
not exceed 1,000 ppmvd at 15% O2, on a 1-hour average and 2,060 lbs/hr.
In the event that emissions of CO exceed 1,000 ppmvd at 15% O2, it shall
be considered a violation of the CO BACT emission limit if CO emissions
exceed 2,060 lbs/hr and not a violation if emissions are less than or equal
to 2,060 lbs/hr. Use of this CO emission limit for purposes of combustion
tuning and testing shall not exceed 90 hours in any calendar year for all
three turbines combined. Records of the number of hours each turbine
undergoes combustion tuning and testing shall be recorded and maintained
and made available to the Division upon request.
1.3.1.5 "Startup" shall have the same definition as provided for in Condition
1.2.1.5.
1.3.1.6 "Shutdown" shall have the same definition as provided for in Condition
1.2.1.6.
1.3.1.7 "Combustion Tuning and Testing" shall have the same definition as
provided for in Condition 1.2.1.7.
Compliance with these CO limitations shall be monitored using the continuous
emission monitoring system (CEMS) required by Condition 1.10, as follows:
1.3.1.8 Except as provided for in Condition 1.3.1.9, all valid CEMS concentration
(ppm) data points, excluding startup and shutdown data points shall, at the
end of each clock hour be summarized to generate the average CO
concentration. Each clock hour average CO concentration shall be
compared to the limitations in Conditions 1.3.1.1, 1.3.1.2 or 1.3.1.4, as
appropriate.
1.3.1.9 All valid CEMS concentration (ppm) data points, excluding non-startup
and non-shutdown data points shall, at the end of each clock hour be
summarized to generate the average CO concentration. Each clock hour
average CO concentration shall be compared to the limit in Condition
1.3.1.3.
In the event that a startup ends within a clock hour or shutdown begins
within a clock hour, all non-startup and/or non-shutdown concentration
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
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Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 13
(ppm) data points within that clock hour shall be averaged together to
generate the average CO concentration and that average concentration
shall be compared to the limitations in Conditions 1.3.1.1, 1.3.1.2 or
1.3.1.4, as appropriate.
1.3.1.10 The emission limitation in Condition 1.3.1.4 applies to any clock hour in
which combustion tuning and testing activities occur.
1.3.2 Carbon Monoxide (CO) emissions from each combustion turbine/HRSG/duct
burner shall not exceed 465.4 tons/yr (Colorado Construction Permit 94WE609 PSD,
as modified under the provisions of Section I, Condition 1.3). Compliance with this
requirement shall be monitored using the Continuous Emission Monitoring System
(CEMS) required by Condition 1.10.
A twelve month rolling total of emissions will be maintained to monitor compliance
with the annual emission limitation. Each month a new twelve month total shall be
calculated using the previous twelve months data.
1.4 Sulfur Dioxide (SO2) emissions shall not exceed the following limitations:
1.4.1 Sulfur Dioxide (SO2) emissions from each combustion turbine shall not exceed
0.35 lbs/mmBtu, on a 3-hour 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 sulfur dioxide limitation is presumed since only pipeline quality
natural gas is permitted to be used as fuel in the turbines.
1.4.2 Each combustion turbine shall meet one of the following requirements:
1.4.2.1 Sulfur Dioxide (SO2) emissions from each combustion turbine shall not
exceed 150 ppmvd at 15% O2 measured at ISO Standard Ambient
Conditions (Colorado Construction Permit 94WE609 PSD) OR
1.4.2.2 No fuel, which contains sulfur in excess of 0.8 percent by weight, shall be
used in these combustion turbines (40 CFR Part 60, Subpart GG §
60.333(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 quality natural gas is permitted to be
used as fuel. The natural gas used as fuel shall meet the requirements in Condition
1.9.
1.4.3 Sulfur Dioxide (SO2) emissions from each duct burner shall not exceed 0.20
lbs/mmBtu on a 30-day rolling average (40 CFR Part 60 Subpart Da § 60.43Da(b)(2),
as adopted by reference in Colorado Regulation No. 6, Part A). In the absence of
credible evidence to the contrary, compliance with the sulfur dioxide limitations is
presumed since only pipeline quality natural gas is permitted to be used as fuel in the
duct burners.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 14
1.4.4 Sulfur Dioxide (SO2) emissions from each combustion turbine/HRSG/duct burner
shall not exceed 4.7 tons/yr (Colorado Construction Permit 94WE609 PSD, as
modified under the provisions of Section I, Condition 1.3). Compliance with the
annual limitation shall be monitored using the continuous monitoring system required
by 40 CFR Part 75, as adopted by reference in Colorado Regulation No. 18
A twelve month rolling total of emissions will be maintained to monitor compliance
with the annual emission limitation. Each month a new twelve month total shall be
calculated using the previous twelve months data.
1.5 Volatile Organic Compound (VOC) emissions shall not exceed the following limitations:
1.5.1 The BACT Volatile Organic Compound (VOC) emission limit for each combustion
turbine/HRSG/duct burner is as follows (Colorado Construction Permit 94WE609
PSD, as modified under the provisions of Section I, Condition 1.3):
1.5.1.1 Emissions of VOC shall not exceed 1.4 ppmvd at 15% O2, on a 1-hour
average. This standard applies when operating in either simple cycle
mode or combined cycle mode without supplemental fuel.
1.5.1.2 Emissions of VOC shall not exceed 1.7 ppmvd at 15% O2, on a 1-hour
average. This standard applies when operating in combined cycle
mode with supplemental fuel.
Compliance with the VOC limitations shall be monitored using the VOC correlation
(VOC emissions vs. heat input) that has been approved by the Division and
programmed into the data acquisition and handling system (DAHS). The data in the
DAHS shall at the end of each hour, be summarized to generate the average VOC
concentration. The equations used in the VOC correlation are included in Appendix
I I of this permit.
1.5.2 Volatile Organic Compounds emissions from each combustion turbine/HRSG/duct
burner shall not exceed 21.4 tons/yr (Colorado Construction Permit 94WE609
PSD). Compliance with the VOC limitation shall be monitored using the VOC
correlation (VOC emissions vs. heat input) that has been approved by the Division
and programmed into the data acquisition and handling system (DAHS). The
equations used in the VOC correlation are included in Appendix H of this permit.
A twelve month rolling total of emissions will be maintained to monitor compliance ,
with the annual emission limitations. Each month a new twelve month total shall be
calculated using the previous twelve months data.
1.6 Particulate Matter (PM) emissions shall not exceed the following limitations:
1.6.1 Particulate Matter (PM) emissions from each combustion turbine shall not exceed
0.1 lbs/mmBtu, the average of three (3) 1-hr tests (Colorado Regulation No. 1,
Section III.A.1.c). In the absence of credible evidence to the contrary, compliance
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 15
with the particulate matter limitation is presumed since only pipeline quality natural
gas is permitted to be used as fuel in the turbines.
1.6.2 Particulate Matter (PM) emissions from each combustion turbine and duct burner
together shall not exceed 0.1 lbs/mmBtu, the average of three (3) 1-hr tests
(Colorado Regulation No. 1, Sections II.A.1.b, c and d). In the absence of credible
evidence to the contrary, compliance with the particulate matter limitation is
presumed since only pipeline quality natural gas is permitted to be used as fuel in the
turbines and duct burners.
Note that the numeric PM standards for combined cycle operation were determined
using the design heat input for the turbines (1,323 mmBtu/hr for Turbine 2 and 1,373
mmBtu/hr for Turbine 3) and duct burners (each 450 mmBtu) in the following
equation:
PE (turbine + duct burner) =PET x FIT + PEDB x Him
FIT+ FIDB
Where PE = particulate standard in lbs/mmBtu
PEDB= 0.5 x (FI)-°26 lbs/mmBtu
PET= 0.1 lbs/mmBtu
Fl= fuel input in mmBtu/hr
1.6.3 Particulate Matter (PM) emissions from each duct burner shall not exceed 0.03
lbs/mmBtu, average of three (3) 2-hr tests (Colorado Construction Permit 94WE609
PSD). In the absence of credible evidence to the contrary, compliance with the
particulate matter limitation is presumed since only pipeline quality natural gas is
permitted to be used as fuel in the duct burners.
The PM emission limits are not applicable during times of startup, shutdown and
malfunction (40 CFR Part 60 Subpart Da § 60.46Da(c), as adopted by reference in
Colorado Regulation No. 6, Part A).
1.6.4 Particulate Matter (PM) emissions from each combustion turbine/HRSG/duct
burner shall not exceed 39.4 tons/yr (Colorado Construction Permit 94WE609 PSD,
as modified under the provisions of Section I, Condition 1.3). Compliance with this
limitation shall be monitored as follows:
1.6.4.1 Monthly emissions of PM shall be calculated using the emission factors
identified in the table below in the following equation:
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 16
Emission Factor Source of Emission Factor
(lb/mmBtu)
Unit PM I PM Jo
Unit 2—Simple Cycle 0.004 0.004 April 28,2010
Unit 2—Combined Cycle 0.004 0.004 November 17& 18, 2009
Unit 3—Simple Cycle 0.003 0.003 October 28 and 29,2009
Unit 3—Combined Cycle 0.004 0.004 June 9, 2010
Tons/month=JEF(lbs/mmBtu)x monthly heat input to turbine(mmBtu/mo)1
2000 lbs/ton
The monthly heat input to the turbine/HRSG/duct burner shall be
determined using the data acquisition and handling system (DAHS) for the
CEMS required by Condition 1.10. A twelve month rolling total of
emissions will be maintained to monitor compliance with the annual
emission limitation. Each month a new twelve month total shall be
calculated using the previous twelve months data.
1.6.4.2 Performance testing shall be conducted in accordance with the
requirements in Condition 1.12.
1.7 Particulate Matter less than 10 microns (PM10) emissions from each combustion
turbine/HRSG/duct burner shall not exceed 9 lbs/hr and 39.4 tons/yr (Colorado Construction
Permit 94WE609 PSD, as modified under the provisions of Section I, Condition 1.3).
Compliance with these limitations shall be monitored as follows:
1.7.1 Monthly emissions of PMio shall be calculated using the emission factors identified in
the table in Condition 1.6.4.1 in the following equation:
Tons/month=JEF(lbs/mmBtu)x monthly heat input to turbine(mmBtu/mo)1
2000 lbs/ton
The monthly heat input to the turbine/duct burner shall be determined using the data
acquisition and handling systems (DAHS) for the CEMS required by Condition 1.10.
A twelve month rolling total of emissions will be maintained to monitor compliance
with the annual emission limitations. Each month a new twelve month total shall be
calculated using the previous twelve months data. Compliance with the hourly
limitation shall be monitored by dividing the monthly emissions by the number of
hours operated each month.
1.7.2 Performance testing shall be conducted in accordance with the requirements in
Condition 1.12.
1.8 Natural Gas Consumption for each combustion turbine/HRSG/duct burner shall not exceed
the following limitations:
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 17
1.8.1 When operating in either simple cycle mode or combined cycle mode without
supplemental fuel natural gas consumption shall not exceed 12,507 mmSCF/yr
(Colorado Construction Permit 94WE609 PSD, as modified under the provisions of
Section I, Condition 1.3).
1.8.2 When operating in combined cycle mode with supplemental fuel natural gas
consumption shall not exceed 16,090 mmSCF/yr (Colorado Construction Permit
94WE609 PSD, as modified under the provisions of Section I, Condition 1.3).
The natural gas consumption for each combustion turbine/duct burners shall be monitored using
the data acquisition and handling systems (DAHS) for the continuous emission monitoring
system (CEMS) required by Condition 1.10. Monthly natural gas consumption from each
turbine/duct burner shall be used in rolling twelve month total to monitor compliance with the
annual natural gas consumption limitations. Each month a new twelve month total shall be
calculated using the previous twelve months data.
Note that if any time during the 12-month rolling period natural gas has been fired in the duct
burners, the 16,090 mmSCF/yr natural gas consumption limit shall apply. The permitteee shall
maintain records of the operating mode (simple cycle or combined cycle without fuel fired in the
duct burners versus combined cycle with fuel fired in the duct burners) of each
turbine/HRSG/duct burner.
1.9 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
pipeline quality 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.
1.10 For each combustion turbine/HRSG/duct burner, continuous emission monitoring systems
(CEMS) shall be installed, calibrated, maintained and operated (Colorado Construction Permit
94WE609 PSD, as modified under the provisions of Section I, Condition 1.3 and 40 CFR Part
75). The CEMS shall meet the following requirements:
1.10.1 The Monitoring Requirements identified in Condition 5.1.
1.10.2 The General Provisions identified in Condition 5.2.
1.10.3 The Equipment and QA/QC Requirements identified in Condition 5.3.
1.10.4 The Data Substitution Requirements identified in Condition 5.4.
1.10.5 The Recordkeeping and Reporting Requirements identified in Condition 5.5.
1.11 These combustion turbines/HRSGs/duct burners are subject to 40 CFR Part 60, Subpart A -
General Provisions, as adopted by reference in Colorado Regulation No. 6, Part A. Specifically,
these units are subject to the following requirements:
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 18
1.11.1 No article, machine, equipment or process shall be used to conceal an emission which
would otherwise constitute a violation of an applicable standard. Such concealment
includes, but is not limited to, the use of gaseous diluents to achieve compliance with
an opacity standard or with a standard which is based on the concentration of a
pollutant in the gasses discharged to the atmosphere (Colorado Construction Permit
94WE609 PSD and 40 CFR Part 60 Subpart A § 60.12)
1.11.2 At all times, including periods of startup, shutdown, and malfunction owners and
operators shall to the extent practicable, maintain and operate any affected facility
including associated air pollution control equipment in a manner consistent with good
air pollution control practice for minimizing emissions. Determination of whether
acceptable operating and maintenance procedures are being used will be based on
information available to the Division which may include, but is not limited to
monitoring results, opacity observations, review of operating and maintenance
procedures, and inspection of the source (Colorado Construction Permit 94WE609
PSD and 40 CFR Subpart A § 60.11(d)).
1.12 The source shall conduct performance tests for each combustion turbine/HRSG/duct burner,
when operating in simple cycle mode and combined cycle mode with supplemental fuel every
five (5) years to monitor compliance with the PM and PKo emission limitations. This
performance test shall be conducted in accordance with the requirements of 40 CFR Part 60
Subpart A § 60.8 using EPA Test Methods 5 and 202.
Note that the previous performance tests for these units were completed as follows:
Unit Performance Test Date
Unit 2—Simple Cycle April 28, 2010
Unit 2—Combined Cycle November 17& 18, 2009
Unit 3 —Simple Cycle October 28 and 29,2009
Unit 3 —Combined Cycle June 9,2010
A stack testing protocol shall be submitted for Division approval at least thirty (30) calendar
days prior to any performance of the test required under this condition. No stack test required
herein shall be performed without prior written approval of the protocol by the Division. The
Division reserves the right to witness the test. In order to facilitate the Division's ability to make
plans to witness the test, notice of the date (s) for the stack test shall be submitted to the Division
at least thirty (30) calendar days prior to the test. The Division may for good cause shown,
waive this thirty (30) day notice requirement. In instances when a scheduling conflict is
presented, the Division shall immediately contact the permittee in order to explore the possibility
of making modifications to the stack test schedule. The required number of copies of the
compliance test results shall be submitted to the Division within forty-five (45) calendar days of
the completion of the test unless a longer period is approved by the Division.
1.13 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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 19
No. 6, Part B, Section II.C.3). This opacity standard applies to each combustion
turbine/HRSG/duct burner. In the absence of credible evidence to the contrary, compliance
with the opacity limitation shall be presumed since only pipeline quality natural gas is permitted
to be used as fuel in the turbines and duct burners.
1.14 Except as provided for in Condition 1.15 below, no owner or operator of a source shall allow or
cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity
(Colorado Construction Permit 94WE609 PSD and Colorado Regulation No. 1, Section II.A.1).
This opacity standard applies to each combustion turbine/HRSG/duct burner. In the absence
of credible evidence to the contrary, compliance with the opacity limitation shall be presumed
since only pipeline quality natural gas is permitted to be used as fuel in the turbines and duct
burners.
1.15 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 combustion turbine/HRSG/duct burner. In the absence of credible evidence
to the contrary, compliance with the opacity limitation shall be presumed since only pipeline
quality natural gas is permitted to be used as fuel in the turbines and duct burners.
1.16 No owner or operator of a source shall cause to be discharged into the atmosphere from any
affected facility any gases which exhibit greater than 20 percent opacity (6-minute average),
except for one 6-minute period per hour of not more than 27 percent opacity ((40 CFR Part 60
Subpart Da § 60.42Da(b), as adopted by reference in Colorado Regulation No. 6, Part A). This
opacity standard applies to each duct burner.
This opacity standard applies at all times except during periods of startup, shutdown and
malfunction (40 CFR Part 60 Subpart A § 60.11(c), as adopted by reference in Colorado
Regulation No. 6, Part A).
The owner or operators of an affected facility that meets the conditions in 40 CFR Part 60
Subpart Da § 60.49Da(a)(2) may, as an alternative to COMS, elect to monitor visible emissions
using the applicable procedures specified in § 60.49Da(a)(3)(i) through (iv) ((40 CFR Part 60
Subpart Da § 60.42Da(a)(3), as adopted by reference in Colorado Regulation No. 6, Part A).
Specifically, compliance with the opacity limits shall be monitored as follows:
1.16.1 The owner or operator shall conduct a performance test using Method 9 of appendix
A-4 of this part and the procedures in §60.11. If during the initial 60 minutes of the
observation all the 6-minute averages are less than 10 percent and all the individual
15-second observations are less than or equal to 20 percent, then the observation
period may be reduced from 3 hours to 60 minutes. (§ 60.49Da(a)(3)(i))
1.16.2 Except as provided in paragraph (a)(3)(iii) or (iv) of this section, the owner or
operator shall conduct subsequent Method 9 of appendix A-4 of this part
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 20
performance tests using the procedures in paragraph (a)(3)(i) of this section according
to the applicable schedule in paragraphs (a)(3)(ii)(A) through (a)(3)(ii)(D) of this
section, as determined by the most recent Method 9 of appendix A-4 of this part
performance test results. (§ 60.49Da(a)(3)(ii))
1.16.2.1 If no visible emissions are observed, a subsequent Method 9 of appendix
A-A of this part performance test must be completed within 12 calendar
months from the date that the most recent performance test was conducted
(§ 60.49Da(a)(3)(ii)(A));
1.16.2.2 If visible emissions are observed but the maximum 6-minute average
opacity is less than or equal to 5 percent, a subsequent Method 9 of
appendix A-4 of this part performance test must be completed within 6
calendar months from the date that the most recent performance test was
conducted (§ 60.49Da(a)(3)(ii)(B));
1.16.2.3 If the maximum 6-minute average opacity is greater than 5 percent but less
than or equal to 10 percent, a subsequent Method 9 of appendix A-4 of
this part performance test must be completed within 3 calendar months
from the date that the most recent performance test was conducted ((§
60.49Da(a)(3)(ii)(C)); or
1.16.2.4 If the maximum 6-minute average opacity is greater than 10 percent, a
subsequent Method 9 of appendix A-4 of this part performance test must
be completed within 30 calendar days from the date that the most recent
performance test was conducted (§ 60.49Da(a)(3)(ii)(D)).
1.16.3 If the maximum 6-minute opacity average is less than 10 percent during the most
recent Method 9, as an alternative to performing subsequent Method 9s, the permittee
may conduct Method 22 observations, as provided for in § 60.49Da(a)(3)(iii) or
perform subsequent monitoring using digital opacity compliance system as provided
for in § 60.49Da(a)(3)(iv).
1.17 These units are subject to the Title IV Acid Rain Requirements. As specified in 40 CFR Part
72.72(b)(1)(viii), the acid rain permit requirements shall be a complete and segregable portion of
the Operating Permit. As such the requirements are found in Section III of this permit.
Operating Permit Number: 97OPWEI80 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit ti 97OPWE180 Page 21
2. T004—Combustion Turbine Capable of Simple or Combined Cycle Operation
Simple Cycle - Combustion Turbine Only
Combined Cycle (No Supplemental Fuel) - Combustion Turbine & Heat Recovery Steam
Generator (HRSG)with No Fuel Fired in Duct Burner
Combined Cycle (With Supplemental Fuel)—Combustion Turbine & Heat Recovery Steam
Generator (HRSG) with Fuel Fired in Duct Burner
Parameter Permit Limitations Compliance Monitoring
Condition Emission
Number Short Term Long Term Factor Method Interval
BACT 2.1 N/A N/A N/A See Condition 2.1.
Requirements
PM 2.2. N/A 54 tons/yr 0.005 Recordkeeping Monthly
Ibs/mmBtu and Calculation
Combustion Turbine: N/A Fuel Restriction Only Pipeline
0.1 lbs/mmBtu,the average of three Quality Natural
(3), 1-hr tests Gas is Used as
Fuel
Combustion Turbine and Duct
Burner Together:
0.1 lbs/mmBtu,the average of three
(3), 1-hr tests
Duct Burner:
0.03 lbs/mmBtu,the average of
three (3),2-hr tests
PM IQ N/A 54 tons/yr 0.005 Recordkeeping Monthly
lbs/mmBtu and Calculation
VOC 2.3. N/A 33.1 tons/yr N/A Continuous Continuously
Monitoring
System
Operating Permit Number: 97OP W E 180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 22
Parameter Permit Limitations Compliance Monitoring
Condition Emission
Number Short Term Long Term Factor Method Interval
SO2 2.4. N/A 4.7 tons/yr N/A Continuous Continuously
Monitoring
System
Combustion Turbine: N/A Fuel Restriction See Condition
150 ppmvd @ 15%O2 OR Use of 2.4.
Fuel Which Contains Less than 0.8
Weight% Sulfur
Combustion Turbine:
0.35 lbs/mmBtu, on a 3-hour rolling
average
Duct Burner:
0.20 lbs/mmBtu on a 30-day rolling
average
NOx 2,5. Simple Cycle Mode N/A Continuous Continuously
9 ppmvd @ 15%O2 on a 24-hr Emission
rolling average, except as provided Monitoring
for below System
During Startup and Shutdown:
100 ppmvd @ 15%O2 on a 1-hr
average
During Combustion Tuning and
Testing(not to exceed 90 hrs/yr per
for all three turbines combined):
100 ppmvd @ 15%O2 on a 1-hr
average
Combined Cycle Mode
4 ppmvd @ 15%O2 on a 24-hr
rolling average, except as provided
for below
During Startup and Shutdown:
100 ppmvd @ 15%O2 on a 1-hr
average
During Combustion Tuning and
Testing(not to exceed 90 hrs/yr per
for all three turbines combined):
100 ppmvd @ 15%O2 on a I-hr
average
N/A 199.1 tons/yr
Operating Permit Number: 97OPWEI80 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 23
Parameter Permit Limitations Compliance Monitoring
Condition Emission
Number Short Term Long Term Factor Method Interval
CO 2.6. Simple Cycle Mode or Combined N/A Continuous Continuously
Cycle Mode—No Supplemental Emission
Fuel: Monitoring
9 ppmvd @ 15%O2 on a 1-hr System
average,except as provided for
below
During Startup and Shutdown:
1000 ppmvd @ 15%O2 on a I-hr
average and 2,060 lbs/hr
During Combustion Tuning and
Testing(not to exceed 90 hrs/yr per
for all three turbines combined):
1000 ppmvd @ 15%O2 on a 1-hr
average and 2,060 lbs/hr
Combined Cycle Mode—With
Supplemental Fuel:
20 ppmvd @ 15%O2 on a 1-hr
average, except as provided for
below
During Startup and Shutdown:
1000 ppmvd @ 15%O2 on a I-hr
average and 2,060 lbs/hr
During Combustion Tuning and
Testing(not to exceed 90 hrs/yr per
for all three turbines combined):
1000 ppmvd @ 15%O2 on a I-hr
average and 2,060 lbs/hr
N/A 237.9 tons/yr
Heat Input from 2.7. N/A Combustion N/A Recordkeeping Monthly
Natural Gas Turbine:
12,066,462
mmBtu/yr
Duct Burner:
3,157,702
mmBtu/yr
Continuous 2.8. N/A N/A N/A See Condition 2.8.
Emission
Monitoring
System
Requirements
Operating Permit Number: 97OP W E 180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 24
Parameter Permit Limitations Compliance Monitoring
Condition Emission
Number Short Term Long Term Factor Method Interval
Compliance 2.9. N/A N/A N/A See Condition 2.9.
Assurance
Monitoring
Requirements—
For Combined
Cycle Operation
Sulfur Content of 2.10. N/A N/A N/A See Condition 2.10.
Natural Gas
NSPS General 2.11. N/A N/A N/A As required by Subject to NSPS
Provisions NSPS General General
Provisions Provisions
Opacity 2.12. Not to Exceed 20%Except as N/A Fuel Restriction Only Pipeline
Provided for in 2.13 Quality Natural
Gas is Used as
Fuel
Opacity 2.13. For Certain Operational Activities- N/A
Not to Exceed 30%, for a Period or
Periods Aggregating More than Six
(6)Minutes in any 60 Consecutive
Minutes
State-Only 2.14. Not to Exceed 20% N/A
Opacity
NSPS Opacity — 2.15. Not to Exceed 20%(6-minute N/A See Condition 2.15.
Applies to Duct average), Except for One Six
Burner Only Minute Average Not to Exceed
27%Per Hour
Acid Rain 2.16. See Section Ill of this Permit Certification Annually
Requirements
2.1 The combustion turbine/HRSG/duct burner is subject to the requirements of the Prevention of
Significant Deterioration (PSD)Program.
2.1.1 Best Available Control Technology (BACT) shall be applied for control of Nitrogen
Oxides (NOx), Carbon Monoxide (CO) and Particulate Matter Emissions (PM and
PM10). BACT has been determined as follows:
2.1.1.1 BACT for NOx has been determined to be Dry Low NOx combustion
system for the turbine and Selective Catalytic Reduction (SCR) for the
HRSG with the emission limits as identified in Condition 2.5.1 (Colorado
Construction Permit 99WE0762 PSD).
2.1.1.2 BACT for CO has been determined to be good combustion
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 25
practices/monitoring systems capable of meeting the emission limits
identified in Condition 2.6.1 (Colorado Construction Permit 99WE0762
PSD).
2.1.1.3 BACT for PM and PMio has been determined to be use of pipeline quality
natural gas (Colorado Construction Permit 99WE0762 PSD).
2.2 PM and PM10 emissions are subject to the following requirements:
2.2.1 Emissions of PM and PMto from the combustion turbine /HRSG/duct burner shall
not exceed 54 tons/yr (Colorado Construction Permit 99WE0762 PSD). Monthly
emissions from the combustion turbine/HRSG/duct burner shall be calculated by the
end of the subsequent month using the emission factors (EF) identified in the above
table (from performance test conducted May 10-12, 2001) in the following equation:
tons/month=(EF, lbs/mmBtu)x(Fuel Use,mmSCF/mo)x heat content of gas(mmBtu/mmSCF)
2000 lbs/ton
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.
2.2.2 Particulate Matter(PM) emissions from the combustion turbine shall not exceed 0.1
lbs/mmBtu, the average of three (3) 1-hr tests (Colorado Regulation No. 1, Section
III.A.1.c). In the absence of credible evidence to the contrary, compliance with the
particulate matter emission limitation is presumed since only pipeline quality natural
gas is permitted to be used as fuel in the turbine.
2.2.3 Particulate Matter (PM) emissions from the combustion turbine and duct burner
together shall not exceed 0.1 lbs/mmBtu, the average of three (3) 1-hr tests
(Colorado Regulation No. 1, Sections III.A.1.b,c and d). In the absence of credible
evidence to the contrary, compliance with the particulate matter emission limitation is
presumed since only pipeline quality natural gas is permitted by be used as fuel in the
turbine and duct burner.
Note that the numeric PM standards for combined cycle operation were determined
using the design heat input for the turbine (1,531 mmBtu/hr) and the duct burner
(each 422 mmBtu) in the following equation:
PE (turbine + duct burner)=PEI x FIT + PEDB x Flom
FIT + Hon
Where PE=particulate standard in lbs/mmBtu
PEDB = 0.5 x (FI)-°26 lbs/mmBtu
PET= 0.1 lbs/mmBtu
FI = fuel input in mmBtu/hr
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2.2.4 Particulate Matter (PM) emissions from the duct burner shall not exceed 0.03
lbs/mmBtu, the average of three (3) 2-hr tests (Colorado Construction Permit
99MR0762 PSD). In the absence of credible evidence to the contrary, compliance
with the particulate matter limitations shall be presumed since only pipeline quality
natural gas is permitted to be used as fuel in the duct burner.
The PM emission limits are not applicable during times of startup, shutdown and
malfunction (40 CFR Part 60 Subpart Da § 60.46Da(c), as adopted by reference in
Colorado Regulation No. 6, Part A).
2.3 Volatile Organic Compound emissions from the combustion turbine/HRSG/duct burner shall
not exceed 33.1 tons/yr (Colorado Construction Permit 99WE0762 PSD). Compliance with the
VOC limitations shall be monitored using the VOC correlation (VOC emissions vs. heat input)
that has been approved by the Division and programmed into the data acquisition and handling
system (DAHS). The VOC correlation was approved by the Division on February 6, 2002, with
written approval provided in the Division's letter dated March 26, 2008 to the permittee. The
equations used in the VOC correlation are included in Appendix H of this permit.
A twelve month rolling total of emissions will be maintained to monitor compliance with the
annual emission limitations. Each month a new twelve month total shall be calculated using the
previous twelve months data.
2.4 Sulfur Dioxide (SO2) emissions shall not exceed the following limitations:
2.4.1 Sulfur Dioxide (SO2) emissions from the combustion turbine/HRSG/duct burner
shall not exceed 4.7 tons/yr (Colorado Construction Permit 99WE0762 PSD, as
modified under the provisions of Section I, Condition 1.3, based on the requested SO2
limits identified on the APEN received on February 27, 2002). Compliance with the
annual SO2 emission limitations shall be monitored using the monitoring method
specified in 40 CFR Part 75 Appendix D.
A twelve month rolling total of emissions shall be maintained to monitor compliance
with the annual emission limitations. Each month a new twelve month total shall be
calculated using the previous twelve months data.
2.4.2 The combustion turbine shall meet one of the following requirements:
2.4.2.1 Sulfur Dioxide (SO2) emissions shall not exceed 150 ppmvd at 15% O2
OR
2.4.2.2 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 §§ 60.33(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 quality natural gas is permitted to be
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used as fuel in the turbine. The natural gas used as fuel shall meet the requirements in
Condition 2.10.
2.4.3 Sulfur Dioxide (SO2) emissions from the combustion turbine shall not exceed 0.35
lbs/mmBtu, on a 3-hr rolling average (Colorado Regulation No. 1, Section
VI.B.4.c.(ii) and VI.B.2). In the absence of credible evidence to the contrary,
compliance with the SO2 limitations is presumed since only pipeline quality natural
gas is permitted to be used as fuel in the turbine.
2.4.4 Sulfur Dioxide (SO2) emissions from the duct burner shall not exceed 0.20
lbs/mmBtu, on a 30-day rolling average (Colorado Construction Permit 99WE0762
PSD). In the absence of credible evidence to the contrary, compliance with the SO2
limitations is presumed since only pipeline quality natural gas is permitted to be used
as fuel in the duct burner.
2.5 Emissions of Nitrogen Oxides (NOx) shall not exceed the following limitations:
2.5.1 The BACT emission limits for the combustion turbine/HRSG/duct burner are as
follows (Colorado Construction Permit 99WE0762 PSD, as modified under the
provisions of Section I, Condition 1.3):
2.5.1.1 Except as provided for in Conditions 2.5.1.3 and 2.5.1.4 below, emissions
of NOx shall not exceed 9 ppmvd at 15 % O2, on a 24-hour average. This
standard applies when operating in simple cycle mode.
2.5.1.2 Except as provided for in Conditions 2.5.1.3 and 2.5.1.4 below, emissions
of NOx shall not exceed 4 ppmvd at 15 % O2, on a 24-hour average. This
standard applies when operating in combined cycle mode.
2.5.1.3 During periods of startup and shutdown emissions of NOx shall not
exceed 100 ppmvd at 15% O2, on a 1-hr average.
2.5.1.4 During periods of combustion tuning and testing emissions of NOx shall
not exceed 100 ppmvd at 15% O2, on a 1-hour average. Use of this NOx
emission limit for purposes of combustion tuning and testing shall not
exceed 90 hours in any calendar year for all three turbines combined.
Records of the number of hours the turbine undergoes combustion tuning
and testing shall be recorded and maintained and made available to the
Division upon request.
2.5.1.5 "Startup" shall have the same definition as provided for in Condition
1.2.1.5.
2.5.1.6 "Shutdown" shall have the same definition as provided for in Condition
1.2.1.6.
2.5.1.7 "Combustion Tuning and Testing" shall have the same definition as
provided for in Condition 1.2.1.7.
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Colorado Operating Permit Ft. St. Vrain Station
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Compliance with these NOx limitations shall be monitored using the continuous
emission monitoring system (CEMS) required by Condition 2.8, as follows:
2.5.1.8 Except as provided for in Condition 2.5.1.9, all valid CEMS concentration
(ppm) data points, excluding startup and shutdown data points shall, at the
end of each clock hour be summarized to generate the average NOx
concentration. Compliance with the limitations in Conditions 2.5.1.1 and
2.5.1.2 shall be based on a 24-hour rolling average, except that compliance
with the limitations cannot be assessed until 24 hours of operation have
occurred. It is not necessary for hours of operation to be consecutive (i.e.
the rolling 24-hour average would resume after the unit has shutdown and
is re-started and/or between switches in operating mode (simple cycle to
combined cycle)) in order for those hours to be included in the 24-hour
rolling averages.
2.5.1.9 All valid CEMS concentration (ppm) data points, excluding non-startup
and non-shutdown data points shall, at the end of each clock hour be
summarized to generate the average NOx concentration. Each clock hour
average NOx concentration shall be compared to the limitation in
Condition 2.5.1.3.
In the event that a startup ends within a clock hour or shutdown begins
within a clock hour, all non-startup and/or non-shutdown concentration
(ppm) data points within that clock hour shall be averaged together to
generate the average NOx concentration and that average concentration
shall be included in the 24-hour rolling averages to monitor compliance
with the limitations in either Conditions 2.5.1.1 or 2.5.1.2 or compared to
the limitation in Condition 2.5.1.4, as appropriate.
2.5.1.10 The emission limitation in Condition 2.5.1.4 applies to any clock hour in
which combustion tuning and testing activities occur.
2.5.2 Nitrogen Oxides (NOx) emissions from the combustion turbine/HRSG/duct
burner shall not exceed 199.1 tons/yr (Colorado Construction Permit 99WE0762
PSD). Compliance with the annual limitation shall be monitored using the CEMS
required by Condition 2.8.
A twelve month rolling total of emissions shall be maintained to monitor compliance
with the annual emission limitation. Each month a new twelve month total shall be
calculated using the previous twelve months total.
2.6 Emissions of Carbon Monoxide (CO) shall not exceed the following limitations:
2.6.1 The BACT CO emission limits for the combustion turbine/HRSG/duct burner are
as follows (Colorado Construction Permit 99WE0762, as modified under the
provisions of Section I, Condition 1.3):
2.6.1.1 Except as provided for in Conditions 2.6.1.3 and 2.6.1.4 below, emissions
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of CO shall not exceed 9 ppmvd at 15% O2, on a I-hour average. This
standard applies when operating in either simple cycle mode or
combined cycle mode without supplemental fuel.
2.6.1.2 Except as provided for in Conditions 2.6.1.3 and 2.6.1.4 below, emissions
of CO shall not exceed 20 ppmvd at 15% O2, on a 1-hour average. This
standard applies when operating in combined cycle mode with
supplemental fuel.
2.6.1.3 During periods of startup and shutdown emissions of CO shall not exceed
1,000 ppmvd at 15% O2, on a 1-hr average and 2,060 lbs/hr. In the event
that CO emissions exceed 1,000 ppmvd at 15% O2, it shall be considered a
violation if CO emissions exceed 2,060 lbs/hr and not a violation if
emissions are less than or equal to 2,060 lbs/hr.
2.6.1.4 During periods of combustion tuning and testing emissions of CO shall
not exceed 1,000 ppmvd at 15% O2, on a 1-hour average. In the event that
CO emissions exceed 1,000 ppmvd at 15% O2, it shall be considered a
violation if CO emissions exceed 2,060 lbs/hr and not a violation if
emissions are less than or equal to 2,060 lbs/hr. Use of this CO emission
limit for purposes of combustion tuning and testing shall not exceed 90
hours in any calendar year for all three turbines combined. Records of
the number of hours the turbine undergoes combustion tuning and testing
shall be recorded and maintained and made available to the Division upon
request.
2.6.1.5 "Startup" shall have the same definition as provided for in Condition
1.2.1.5.
2.6.1.6 "Shutdown" shall have the same definition as provided for in Condition
1.2.1.6.
2.6.1.7 "Combustion Tuning and Testing" shall have the same definition as
provided for in Condition 1.2.1.7.
Compliance with these CO limitations shall be monitored using the continuous
emission monitoring system (CEMS) required by Condition 2.8, as follows:
2.6.1.8 Except as provided for in Condition 2.6.1.9, all valid CEMS concentration
(ppm) data points, excluding startup and shutdown data points shall, at the
end of each clock hour be summarized to generate the average CO
concentration. Each clock hour average CO concentration shall be
compared to the limitations in Conditions 2.6.1.1, 2.6.1.2 or 2.6.1.4, as
appropriate.
2.6.1.9 All valid CEMS concentration (ppm) data points, excluding non-startup
and non-shutdown data points shall, at the end of each clock hour be
summarized to generate the average CO concentration. Each clock hour
average CO concentration shall be compared to the limitation in Condition
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Colorado Operating Permit Ft. St. Vrain Station
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2.6.1.3.
In the event that a startup ends within a clock hour or shutdown begins
within a clock hour, all non-startup and/or non-shutdown concentration
(ppm) data points within that clock hour shall be averaged together to
generate the average CO concentration and that average concentration
shall be compared to the limitations in Conditions 2.6.1.1, 2.6.1.2 or
2.6.1.4, as appropriate.
2.6.1.10 The emission limitation in Condition 2.6.1.4 applies to any clock hour in
which combustion tuning and testing activities occur.
2.6.2 Carbon Monoxide (CO) emissions from the combustion turbine/HRSG/duct
burner shall not exceed 237.9 tons/yr (Colorado Construction Permit 99WE0762
PSD). Compliance with the annual limitation shall be monitored using the CEMS
required by Condition 2.8.
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.
2.7 The Heat Input from Natural Gas to the combustion turbine and duct burner shall not exceed
the following limitations:
2.7.1 The heat input to the combustion turbine shall not exceed 12,066,462 mmBtu/yr
(Colorado Construction Permit 99WE0762 PSD, as modified under the provisions of
Section I, Condition 1.3, based on the requested turbine gas consumption limits
identified on the APEN received on February 27, 2002).
2.7.2 The heat input to the duct burner shall not exceed 3,157,702 mmBty/yr (Colorado
Construction Permit 99WE0762 PSD).
The heat input for the combustion turbine and the duct burner shall be monitored using the data
acquisition and handling systems (DAHS) for the continuous emission monitoring system
(CEMS) required by Condition 2.8.
Monthly heat input 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.
2.8 Continuous emission monitoring systems (CEMS) shall be installed, calibrated, maintained and
operated on the combustion turbine/HRSG (Colorado Construction Permit 99WE762 PSD, as
modified under the provisions of Section I, Condition 1.3 and 40 CFR Part 75). The continuous
emission monitoring systems shall meet the following requirements:
2.8.1 The Monitoring Requirements identified in Condition 5.1.
2.8.2 The General Provisions identified in Condition 5.2.
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2.8.3 The Equipment and QA/QC Requirements identified in Condition 5.3.
2.8.4 The Data Substitution Requirements identified in Condition 5.4.
2.8.5 The Recordkeeping and Reporting Requirements identified in Condition 5.5.
2.9 The Compliance Assurance Monitoring (CAM) requirements in 40 CFR Part 64, as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV, apply to when operating in
combined cycle mode, with respect to the NOx limitations identified in Conditions 2.5.1.2 as
follows:
2.9.1 The permittee shall monitor the exhaust gas NOx concentration (ppmvd at 15% O2)
using the continuous emission monitoring system required by Condition 2.8. The
NOx concentrations will be reduced to hourly averages and used to calculate 24-hour
averages. Exceedances, for purposes of CAM, shall be any 24-hour period that the
NOx concentration exceeds the limit identified in Condition 2.5.1.2. Exceedances of
these limitations shall be reported as required by Section II, Condition 5.5 and
Section V, Conditions 21 and 22.d of this permit.
2.9.2 Operation of Approved Monitoring
2.9.2.1 At all times, the owner or operator shall maintain the monitoring,
including but not limited to, maintaining necessary parts for routine
repairs of the monitoring equipment (40 CFR Part 64 § 64.7(b), as adopted
by reference in Colorado Regulation No. 3, Part C, Section XIV).
2.9.2.2 Except for, as applicable, monitoring malfunctions, associated repairs, and
required quality assurance or control activities (including, as applicable,
calibration checks and required zero and span adjustments), the owner or
operator shall conduct all monitoring in continuous operation (or shall
collect data at all required intervals) at all times that the pollutant-specific
emissions unit is operating. Data recorded during monitoring
malfunctions, associated repairs, and required quality assurance or control
activities shall not be used for purposes of these CAM requirements,
including data averages and calculations, or fulfilling a minimum data
availability requirement, if applicable. The owner or operator shall use all
the data collected during all other periods in assessing the operation of the
control device and associated control system. A monitoring malfunction
is any sudden, infrequent, not reasonably preventable failure of the
monitoring to provide valid data. Monitoring failures that are caused in
part by poor maintenance or careless operation are not malfunctions (40
CFR Part 64 § 64.7(c), as adopted by reference in Colorado Regulation
No. 3, Part C, Section XIV).
2.9.2.3 Response to excursions or exceedances
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a. Upon detecting an excursion or exceedance, the owner or operator
shall restore operation of the pollutant-specific emissions unit
(including the control device and associated capture system) to its
normal or usual manner of operation as expeditiously as
practicable in accordance with good air pollution control practices
for minimizing emissions. The response shall include minimizing
the period of any startup, shutdown or malfunction and taking any
necessary corrective actions to restore normal operation and
prevent the likely recurrence of the cause of an excursion or
exceedance (other than those caused by excused startup or
shutdown conditions). Such actions may include initial inspection
and evaluation, recording that operations returned to normal
without operator action (such as through response by a
computerized distribution control system), or any necessary
follow-up actions to return operation to within the indicator range,
designated condition, or below the applicable emission limitation
or standard, as applicable (40 CFR Part 64 § 64.7(d)(1), as adopted
by reference in Colorado Regulation No. 3, Part C, Section XIV).
b. Determination of whether the owner of operator has used
acceptable procedures in response to an excursion or exceedance
will be based on information available, which may include but is
not limited to, monitoring results, review of operation and
maintenance procedures and records, and inspection of the control
device, associated capture system, and the process (40 CFR Part 64
§ 64.7(d)(2), as adopted by reference in Colorado Regulation No.
3, Part C, Section XIV).
2.9.2.4 After approval of the monitoring required under the CAM requirements, if
the owner or operator identifies a failure to achieve compliance with an
emission limitation or standard for which the approved monitoring did not
provide an indication of an excursion or exceedance while providing valid
data, or the results of compliance or performance testing document a need
to modify the existing indicator ranges or designated conditions, the owner
or operator shall promptly notify the Division and, if necessary submit a
proposed modification for this permit to address the necessary monitoring
changes. Such a modification may include, but is not limited to,
reestablishing indicator ranges or designated conditions, modifying the
frequency of conducting monitoring and collecting data, or the monitoring
of additional parameters (40 CFR Part 64 § 64.7(e), as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV).
2.9.3 Quality Improvement Plan (QIP) Requirements
2.9.3.1 Based on the results of a determination made under the provisions of
Condition 2.9.2.3.b, the Division may require the owner or operator to
develop and implement a QIP (40 CFR Part 64 § 64.8(a), as adopted by
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reference in Colorado Regulation No. 3, Part C, Section XIV).
2.9.3.2 The owner or operator shall maintain a written QIP, if required, and have
it available for inspection (40 CFR Part 64 § 64.8(b)(l), as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV).
2.9.3.3 The QIP initially shall include procedures for evaluating the control
performance problems and, based on the results of the evaluation
procedures, the owner or operator shall modify the plan to include
procedures for conducting one or more of the following actions, as
appropriate:
a. Improved preventative maintenance practices (40 CFR Part 64 §
64.8(b)(2)(i), as adopted by reference in Colorado Regulation No.
3, Part C, Section XIV).
b. Process operation changes (40 CFR Part 64 § 64.8(b)(2)(ii), as
adopted by reference in Colorado Regulation No. 3, Part C,
Section XIV).
c. Appropriate improvements to control methods (40 CFR Part 64 §
64.8(b)(2)(iii), as adopted by reference in Colorado Regulation No.
3, Part C, Section XIV).
d. Other steps appropriate to correct control performance (40 CFR
Part 64 § 64.8(b)(2)(iv), as adopted by reference in Colorado
Regulation No. 3, Part C, Section XIV).
e. More frequent or improved monitoring (only in conjunction with
one or more steps under Conditions 2.9.3.3.a through d above) (40
CFR Part 64 § 64.8(b)(2)(v), as adopted by reference in Colorado
Regulation No. 3, Part C, Section XIV).
2.9.3.4 If a QIP is required, the owner or operator shall develop and implement a
QIP as expeditiously as practicable and shall notify the Division if the
period for completing the improvements contained in the QIP exceeds 180
days from the date on which the need to implement the QIP was
determined (40 CFR Part 64 § 64.8(c), as adopted by reference in
Colorado Regulation No. 3, Part C, Section XIV).
2.9.3.5 Following implementation of a QIP, upon any subsequent determination
pursuant to Condition 2.9.2.3.6, the Division or the U.S. EPA may require
that an owner or operator make reasonable changes to the QIP if the QIP is
found to have:
a. Failed to address the cause of the control device performance
problems (40 CFR Part 64 § 64.8(d)(1), as adopted by reference in
Colorado Regulation No. 3, Part C, Section XIV); or
b. Failed to provide adequate procedures for correcting control device
performance problems as expeditiously as practicable in
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accordance with good air pollution control practices for
minimizing emissions (40 CFR Part 64 § 64.8(d)(2), as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV).
2.9.3.6 Implementation of a QIP shall not excuse the owner or operator of a
source from compliance with any existing emission limitation or standard,
or any existing monitoring, testing, reporting or recordkeeping
requirement that may apply under federal, state, or local law, or any other
applicable requirements under the federal clean air act (40 CFR Part 64 §
64.8(e), as adopted by reference in Colorado Regulation No. 3, Part C,
Section XIV).
2.9.4 Reporting and Recordkeeping Requirements
2.9.4.1 Reporting Requirements: The reports required by Section V, Condition
22.d, shall contain the information specified in Appendix B of the permit
and the following information, as applicable:
a. Summary information on the number, duration and cause
(including unknown cause, if applicable), for monitor downtime
incidents (other than downtime associated with zero and span or
other daily calibration checks, if applicable) ((40 CFR Part 64 §
64.9(a)(2)(ii), as adopted by reference in Colorado Regulation No.
3, Part C, Section XIV); and
b. The owner or operator shall submit, if necessary, a description of
the actions taken to implement a QIP during the reporting period as
specified in Condition 2.9.3 of this permit. Upon completion of a
QIP, the owner or operator shall include in the next summary
report documentation that the implementation of the plan has been
completed and reduced the likelihood of similar levels of
excursions or exceedances occurring (40 CFR Part 64 §
64.9(a)(2)(iii), as adopted by reference in Colorado Regulation No.
3, Part C, Section XIV).
2.9.4.2 General Recordkeeping Requirements: In addition to the recordkeeping
requirements in Section V, Condition 22.a through c.
a. The owner or operator shall maintain records of any written QIP
required pursuant to Condition 2.9.3 and any activities undertaken
to implement a QIP, and any supporting information required to be
maintained under these CAM requirements (such as data used to
document the adequacy of monitoring, or records of monitoring
maintenance or corrective actions) (40 CFR Part 64 § 64.9(b)(1),
as adopted by reference in Colorado Regulation No. 3, Part C,
Section XIV).
b. Instead of paper records, the owner or operator may maintain
records on alternative media, such as microfilm, computer files,
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magnetic tape disks, or microfiche, provided that the use of such
alternative media allows for expeditious inspection and review,
and does not conflict with other applicable recordkeeping
requirements (40 CFR Part 64 § 64.9(b)(2), as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV).
2.9.5 Savings Provisions
2.9.5.1 Nothing in these CAM requirements shall excuse the owner or operator of
a source from compliance with any existing emission limitation or
standard, or any existing monitoring, testing, reporting or recordkeeping
requirement that may apply under federal, state, or local law, or any other
applicable requirements under the federal clean air act. These CAM
requirements shall not be used to justify the approval of monitoring less
stringent than the monitoring which is required under separate legal
authority and are not intended to establish minimum requirements for the
purposes of determining the monitoring to be imposed under separate
authority under the federal clean air act; including monitoring in permits
issued pursuant to title I of the federal clean air act. The purpose of the
CAM requirements is to require, as part of the issuance of this Title V
operating permit, improved or new monitoring at those emissions units
where monitoring requirements do not exist or are inadequate to meet the
requirements of CAM (40 CFR Part 64 § 64.10(a)(I), as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV).
2.9.5.2 Nothing in these CAM requirements shall restrict or abrogate the authority
of the U.S. EPA or the Division to impose additional or more stringent
monitoring, recordkeeping, testing or reporting requirements on any owner
or operator of a source under any provision of the federal clean air act,
including but not limited to sections 114(a)(1) and 504(b), or state law, as
applicable (40 CFR Part 64 § 64.10(a)(2), as adopted by reference in
Colorado Regulation No. 3, Part C, Section XIV).
2.9.5.3 Nothing in these CAM requirements shall restrict or abrogate the authority
of the U.S. EPA or the Division to take any enforcement action under the
federal clean air act for any violation of an applicable requirement or of
any person to take action under section 304 of the federal clean air act (40
CFR Part 64 § 64.10(a)(2), as adopted by reference in Colorado
Regulation No. 3, Part C, Section XIV).
2.10 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
pipeline quality 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.
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2.11 These combustion turbine/HRSG/duct burner is subject to 40 CFR Part 60, Subpart A -
General Provisions, as adopted by reference in Colorado Regulation No. 6, Part A. Specifically,
these units are subject to the following requirements:
2.11.1 No article, machine, equipment or process shall be used to conceal an emission which
would otherwise constitute a violation of an applicable standard. Such concealment
includes, but is not limited to, the use of gaseous diluents to achieve compliance with
an opacity standard or with a standard which is based on the concentration of a
pollutant in the gasses discharged to the atmosphere. (40 CFR Part 60 Subpart A §
60.12, as adopted in Colorado Regulation No. 6, Part A)
2.11.2 At all times, including periods of startup, shutdown, and malfunction, owners and
operators shall to the extent practicable, maintain and operate any affected facility
including associated air pollution control equipment in a manner consistent with good
air pollution control practice for minimizing emissions. Determination of whether
acceptable operating and maintenance procedures are being used will be based on
information available to the Division which may include, but is not limited to
monitoring results, opacity observations, review of operating and maintenance
procedures, and inspection of the source (40 CFR Subpart A § 60.11(d), as adopted
by reference in Colorado Regulation N. 6, Part A).
2.12 Except as provided for in Condition 2.13 below, no owner or operator of a source shall allow or
cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity
(Colorado Construction Permit 99WE0762 PSD and Colorado Regulation No. 1, Section II.A.1).
This opacity standard applies to the combustion turbine/HRSG/duct burner. In the absence of
credible evidence to the contrary, compliance with the 20% opacity limit shall be presumed since
only pipeline quality natural gas is permitted to be used as fuel in the turbine and duct burner.
2.13 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air
pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up,
process modifications, or adjustment or occasional cleaning of control equipment which is in
excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty
(60) consecutive minutes (Colorado Construction Permit 99WE0762 PSD and Colorado
Regulation No. I, Section II.A.4). This opacity standard applies to the combustion
turbine/HRSG/duct burner. In the absence of credible evidence to the contrary, compliance
with the 30% opacity limit shall be presumed since only pipeline quality natural gas is permitted
to be used as fuel in the turbine and duct burner.
2.14 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 the combustion
turbine/HRSG/duct burner. In the absence of credible evidence to the contrary, compliance
with the 20% opacity requirement is presumed since only pipeline quality natural gas is
permitted to be used as fuel in the turbine and duct burner.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWEI80 Page 37
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).
2.15 No owner or operator of a source shall cause to be discharged into the atmosphere from any
affected facility any gases which exhibit greater than 20 percent opacity (6-minute average),
except for one 6-minute period per hour of not more than 27 percent opacity ((40 CFR Part 60
Subpart Da § 60.42Da(b), as adopted by reference in Colorado Regulation No. 6, Part A and
Colorado Construction Permit 99WE0762 PSD). This opacity standard applies to the duct
burner.
This opacity standard applies at all times except during periods of startup, shutdown and
malfunction (40 CFR Part 60 Subpart A § 60.11(c), as adopted by reference in Colorado
Regulation No. 6, Part A).
The owner or operators of an affected facility that meets the conditions in 40 CFR Part 60
Subpart Da § 60.49Da(a)(2) may, as an alternative to COMS, elect to monitor visible emissions
using the applicable procedures specified in § 60.49Da(a)(3)(i) through (iv) ((40 CFR Part 60
Subpart Da § 60.42Da(a)(3), as adopted by reference in Colorado Regulation No. 6, Part A).
Specifically, compliance with the opacity limits shall be monitored as follows:
2.15.1 The owner or operator shall conduct a performance test using Method 9 of appendix
A-4 of this part and the procedures in §60.11. If during the initial 60 minutes of the
observation all the 6-minute averages are less than 10 percent and all the individual
15-second observations are less than or equal to 20 percent, then the observation
period may be reduced from 3 hours to 60 minutes. (§ 60.49Da(a)(3)(i))
2.15.2 Except as provided in paragraph (a)(3)(iii) or (iv) of this section, the owner or
operator shall conduct subsequent Method 9 of appendix A-4 of this part
performance tests using the procedures in paragraph (a)(3)(i) of this section according
to the applicable schedule in paragraphs (a)(3)(ii)(A) through (a)(3)(ii)(D) of this
section, as determined by the most recent Method 9 of appendix A-4 of this part
performance test results. (§ 60.49Da(a)(3)(ii))
2.15.2.1 If no visible emissions are observed, a subsequent Method 9 of appendix
A-4 of this part performance test must be completed within 12 calendar
months from the date that the most recent performance test was conducted
(§ 60.49Da(a)(3)(ii)(A));
2.15.2.2 If visible emissions are observed but the maximum 6-minute average
opacity is less than or equal to 5 percent, a subsequent Method 9 of
appendix A-4 of this part performance test must be completed within 6
calendar months from the date that the most recent performance test was
conducted (§ 60.49Da(a)(3)(ii)(B));
2.15.2.3 If the maximum 6-minute average opacity is greater than 5 percent but less
than or equal to 10 percent, a subsequent Method 9 of appendix A-4 of
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 38
this part performance test must be completed within 3 calendar months
from the date that the most recent performance test was conducted ((§
60.49Da(a)(3)(ii)(C)); or
2.15.2.4 If the maximum 6-minute average opacity is greater than 10 percent, a
subsequent Method 9 of appendix A-4 of this part performance test must
be completed within 30 calendar days from the date that the most recent
performance test was conducted (§ 60.49Da(a)(3)(ii)(D)).
2.15.3 If the maximum 6-minute opacity average is less than 10 percent during the most
recent Method 9, as an alternative to performing subsequent Method 9s, the permittee
may conduct Method 22 observations, as provided for in § 60.49Da(a)(3)(iii) or
perform subsequent monitoring using digital opacity compliance system as provided
for in § 60.49Da(a)(3)(iv).
2.16 This unit 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 complete and segregable portion of
the Operating Permit. As such the requirements are found in Section III of this permit.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 39
3. B001 - Auxiliary Boiler
Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
NOx 3.1 N/A 32.6 tons/yr 100 Ibs/mmSCF Recordkeeping Monthly
CO N/A 27.4 tons/yr 84 lbs/mmSCF and Calculation
Natural Gas 3.2 N/A 651.7 N/A Fuel Meter and Monthly
Usage mmSCF/yr Recordkeeping
Particulate 3.3. 0.166 lbs/mmBtu N/A Fuel Restriction Only Natural
Matter(PM) Gas is Used
as Fuel
Opacity 3.4. Not to 20%Except as Provided N/A Fuel Restriction Only Natural
for in 3.5 Below Gas is Used
as Fuel
Opacity 3.5. Special Conditions-Not to N/A Fuel Restriction Only Natural
Exceed 30%for a Period or Gas is Used
Periods Aggregating More than as Fuel
Six(6) Minutes in Any Sixty
Consecutive Minutes
3.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) shall not exceed the above
limitations (as provided for under the provisions of Section I, condition 1.3, with as requested on
the APEN submitted 4/23/99). Monthly emissions shall be calculated by the end of the
subsequent month using the above emission factors (EPA's Compilation of Emission Factors,
dated March 1998, Section 1.4) in the following equation:
tons/month=f EF (lbs/mmSCF) x monthly fuel usage (mmSCF/month)]
2000 lbs/ton
A twelve month rolling total of emissions will be maintained to monitor compliance with the
annual emission limitations. Each month a new twelve month total shall be calculated using the
previous twelve months data.
3.2 Natural Gas Usage for this boiler shall not exceed the limitation stated above (as provided for
under the provisions of Section 1, condition 1.3, with natural gas consumption as requested in the
source's comments on the draft permit submitted 5/25/99). On the first working day of each
month natural gas usage shall be recorded using the boiler fuel meter. Monthly natural gas use
shall be used in a twelve month rolling total to monitor compliance with annual limitations.
Each month a new twelve month total shall be calculated using the previous months data.
3.3 Particulate Matter (PM) emissions shall not exceed the limitation above (Colorado Regulation
No. 1, Section II.A.I.b). In the absence of credible evidence to the contrary, compliance with the
particulate matter limitations is presumed since only natural gas is permitted to be used as fuel in
the boiler.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 40
Note that the numeric PM standard was determined using the design heat input for the boiler (70
mmBtu/hr) in the following equation:
PE= 0.5 x (FI) °26' where: PE =particulate standard in lbs/mmBtu
FI = fuel input in mmBtu/hr
3.4 Except as provided for in Condition 3.5 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). In the absence of credible evidence to the
contrary, compliance with the opacity limitation is presumed since only natural gas is permitted
to be used as fuel in the boiler.
3.5 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air
pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up,
process modifications, or adjustment or occasional cleaning of control equipment which is in
excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty
(60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). In the absence of
credible evidence to the contrary, compliance with the opacity limitation is presumed since only
natural gas is permitted to be used as fuel in the boiler.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 41
4. M001 - Cooling Water and Service Water Towers
Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
PM 4.1 N/A 14.9 tons/yr See Condition 4.1 Recordkeeping Monthly
PM10 N/A 14.9 tons/yr and Calculation
VOC N/A 2.4 tons/yr 0.0527 lbs/mmgal (as
CHCI3)
Water Circulated 4.2 N/A 89,878 N/A Recordkeeping Monthly
mmgal/yr
Total Solids 4.3 N/A N/A N/A Laboratory Semi-
Concentration Analysis Annually
Opacity 4.4 Not to Exceed 20% N/A See Condition 4.4.
4.1 Particulate Matter (PM and PM16) and Volatile Organic Compound (VOC) emissions shall not
exceed the limitations above (Colorado Construction Permit 97WE0189, as modified under the
provisions of Section I, Condition 1.3). Emissions shall be calculated monthly for each tower
using the following equations:
PM =PM10(tons/month)= Q x d x%drift x 31.3%drift dispersed x total solids
2000 lbs/ton
Where: Q= water circulated, gal/month
d=density of water, lbs/gal(from T5 application d=8.34 lbs/gal)
%drift=0.001%(from T5 application)
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 = in ppm (lbs solids/I0° lbs water) - to be determined by Condition 4.3. The most
recent analysis shall be used in the monthly calculation.
VOC =CHCI3 (tons/month)=Q x EF x(I mmgal/10°gal)
2000 lbs/ton
Where: Q= water circulated, gal/month
EF =0.0527 lbs/mmgal (from letter from Wayne C. Micheletti to Ed Lasnic, dated November 11,
1992)
Monthly emissions from each tower shall be summed together and used in a twelve month
rolling total to monitor compliance with the annual limitation. Each month a new twelve month
total shall be calculated using the previous twelve months data.
4.2 The Water Circulated through both the service water tower and the cooling water tower shall
not exceed the limitation above (Colorado Construction Permit 97WE0189, as modified under
the provisions of Section I, Condition 1.3). The quantity of water circulated in each tower shall
be monitored and recorded monthly. Monthly quantities of water from each tower shall be
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 970PWE180 Page 42
summed together and used in a twelve month rolling total to monitor compliance with the annual
limitation. Each month a new twelve month total shall be calculated using the previous twelve
months data.
4.3 Samples of water circulated from each tower shall be taken and analyzed semi-annually to
determine the total solids concentration. The total solids concentration shall be used to calculate
particulate matter emissions as required by Condition 4.1. A copy of the procedures used to
obtain and to analyze samples shall be maintained and made available to the Division upon
request.
4.4 Opacity of emissions from the cooling water tower shall not exceed 20% (Colorado Regulation
No. 1, Section II.A.1). In the absence of credible evidence to the contrary, compliance with the
opacity standard shall be presumed, provided the drift eliminators on the tower are operated and
maintained in accordance with the manufacturers' recommendations and good engineering
practices.
5. Continuous Emission Monitoring Systems (CEMS)
5.1 Monitoring Requirements
For each turbine, a continuous emission monitoring system shall be installed, calibrated, and
operated on the exhaust stack to determine and record the following (Colorado Construction
Permits 94WE609 PSD, 99WE0762 PSD and 07WE1100, as modified under the provisions of
Section I, Condition 1.3):
5.1.1 Concentration of Oxides of Nitrogen; ppmvd corrected to 15% O2, hourly average
and 24-hour average (Turbine 4 only), in the exhaust;
5.1.2 Emissions of Oxides of Nitrogen; tons/month, rolling twelve month;
5.1.3 Concentration of Carbon Monoxide; ppmvd corrected to 15% O2, hourly average, in
the exhaust;
5.1.4 Emissions of Carbon Monoxide; lbs/hr, tons/month, rolling twelve month;
5.1.5 Average combustion turbine load;
5.1.6 Load at which steam turbine is operating;
5.1.7 Flow rate of pipe line quality natural gas;
5.2 General Provisions
5.2.1 The permittee shall operate the continuous emission monitoring systems as follows:
5.2.1.1 NOx (and diluent) monitors: The permittee shall ensure that all
continuous emission and opacity monitoring systems required are in
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 43
operation and monitoring unit emissions or opacity at all times that the
unit combusts any fuel except as provided in 40 CFR Part 75 § 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 a data acquisition and
handling system or recertification performed pursuant to 40 CFR Part 75 §
75.20. (40 CFR Part 75 § 75.10(d)).
5.2.1.2 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) (40 CFR Part 60
Subpart A § 60.13(e)).
5.2.2 Alternative monitoring systems, alternative reference methods, or any other
alternatives for the required continuous emission monitoring systems shall not be
used without having obtained prior written approval from the appropriate agency,
either the Division or the U.S. EPA, depending on which agency is authorized to
approve such alternative under applicable law. Any alternative continuous emission
monitoring systems must be certified in accordance with the requirements of 40 CFR
Part 75 prior to use.
5.2.3 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 alternative
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.
5.2.4 A file 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 75 recorded in a permanent form suitable for inspection.
5.2.5 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 Equipment and QA/QC Requirements
5.3.1 Except as provided for below, the CO monitors are subject to the applicable
requirements of 40 CFR Part 60 (94WE609 PSD and 07WE1100). The monitoring
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 44
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.
5.3.1.1 The CO CEMS data shall meet the applicable "primary equipment hourly
operating requirements" for hourly average calculation methodology
specified in 40 CFR Part 75 Subpart B § 75.10(d).
5.3.1.2 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.
5.3.1.3 Relative accuracy test audit (RATA) frequency will be determined
according to 40 CFR Part 75 Appendix B.
5.3.1.4 The CEMS on the bypass system shall meet the quality assurance/quality
control requirements in Appendix G of this permit.
5.3.2 Except as provided for below, the NOx (and diluent) monitors are subject to the
applicable requirements of 40 CFR Part 75. The monitoring systems shall meet the
equipment, installation and performance specification requirements in 40 CFR Part
75, Appendix A. These CEMS shall meet the quality assurance/quality control
requirements in 40 CFR Part 75, Appendix B, the conversion procedures of Appendix
F and the traceability protocols of Appendix H.
5.3.2.1 The CEMS on the bypass system shall meet the quality assurance/quality
control requirements in Appendix G of this permit.
5.3.3 Quality assurance/quality control plans shall be prepared for the continuous emission
monitoring systems as follows:
5.3.3.1 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.
5.3.3.2 The quality assurance /quality control plan for the NOx (and diluent)
monitors shall be prepared in accordance with the applicable
requirements in 40 CFR Part 75, Appendix B.
The quality assurance/quality control plans shall be made available to the Division
upon request. Revisions shall be made to the plans at the request of the Division.
5.4 Data Substitution Requirements
When quality assured data is not available for oxides of nitrogen (NOx) and carbon monoxide
(CO), the missing data substitution procedures set forth in 40 CFR Part 75 Subpart D shall be
followed. Although carbon monoxide emissions are not specifically referenced in the Subpart D
procedures, the CEM data acquisition system will be programmed to substitute carbon monoxide
emissions using the same procedures specified for oxides of nitrogen (Colorado Construction
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 45
Permit 94WE609 PSD, as modified under the provisions of Section I, Condition 1.3, as requested
by letter received June 23, 1999 and Colorado Construction Permit 07WE1100).
Replaced data shall be used to monitor compliance with the annual NOx and CO limitations.
5.5 Recordkeeping and Reporting Requirements
5.5.1 The owner or operator of a facility required to install, maintain, and calibrate
continuous monitoring equipment shall submit to the Division, by the end of the
calendar month following the end of each calendar quarter, a report of excess
emissions for all pollutants monitored for that quarter (40 CFR Part 60 Subpart §
60.7(c)). This report shall consist of the following information and/or reporting
requirements as specified by the Division:
5.5.1.1 The magnitude of excess emissions computed in accordance with 40 CFR
Part 60 Subpart A § 60.13(h), any conversion factor(s) used, and the date
and time of commencement and completion of each time period of excess
emissions and the process operating time during the reporting period (40
CFR Part 60 Subpart A § 60.7(c)(1)).
5.5.1.2 Specific identification of each period of excess emissions that occurs
during startups, shutdowns, and malfunctions of the affected facility. The
nature and cause of any malfunction (if known), the corrective action
taken or preventative measures adopted (40 CFR Part 60 Subpart A §
60.7(c)(2)).
5.5.1.3 The date and time identifying each period during which the continuous
monitoring system was inoperative except for zero and span checks and
the nature of the system repairs or adjustments (40 CFR Part 60 Subpart A
§ 60.7(c)(3)).
5.5.1.4 When no excess emissions have occurred or the continuous monitoring
system(s) have not been inoperative, repaired, or adjusted, such
information shall be stated in the report (40 CFR Part 60 Subpart A §
60.7(c)(4)).
5.5.2 The owner or operator of a facility required to install, maintain, and calibrate
continuous monitoring equipment shall submit to the Division, by the end of the
calendar month following the end of each calendar quarter, a summary report for that
quarter (40 CFR Part 60 Subpart A § 60.7(c)). One summary report form shall be
submitted for each pollutant monitored. This report shall contain the information and
be presented in a format approved by the Division.
If the total duration of excess emissions for the reporting period is less than 1 percent
of the total operating time for the reporting period and continuous monitoring system
(CMS) downtime is less than 5 percent of the total operating time for the reporting
period, only the summary report form shall be submitted and the excess emission
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 46
report described in Condition 5.5.1. need not be submitted unless required by the
Division(40 CFR Part 60 Subpart A § 60.7(d)(1)).
If the total duration of excess emissions for the reporting period is 1 percent or greater
of the total operating time for the reporting period or the total CMS downtime for the
reporting period is 5 percent or greater of the total operating time for the reporting
period, the summary report form and the excess emission report described in
Condition 5.5.1 shall both be submitted (40 CFR Part 60 Subpart A § 60.7(d)(1)).
5.6 Specific Provisions for NSPS Subpart KKKK
The following requirements apply to Turbines 5 and 6 only.
5.6.1 As specified in 40 CFR Part 60 Subpart KKKK § 60.4345(a), if a Part 75 NOx CEMS
is used, the RATA shall be performed on a lb/mmBtu basis.
5.6.2 As specified in 40 CFR Part 60 Subpart KKKK § 60.4350(d) and approved by the
Division, only quality assured data from the CEMS shall be used to identified excess
emissions. Periods where the missing data substitution procedures in Subpart D of
Part 75 are applied are to be reported as monitor downtime in the excess emission
reports specified in Condition 5.5.
5.6.3 For the purpose of reports required under Condition 5.5, periods of excess emissions
and monitor downtime that must be reported are defined as follows:
5.6.3.1 Excess emissions is any unit operating period in which the 4-hour rolling
average NOx emission rate exceeds the applicable emission limit in
§60.4320. For the purposes of this subpart, a "4-hour rolling average
NOxe mission rate" is the arithmetic average of the average NOx emission
rate in ppm or ng/J (lb/MWh) measured by the continuous emission
monitoring equipment for a given hour and the three unit operating hour
average NOx emission rates immediately preceding that unit operating
hour. Calculate the rolling average if a valid NOx mission rate is obtained
for at least 3 of the 4 hours. (40 CFR Part 60 Subpart KKKK §
60.4380(b)(1))
5.6.3.2 A period of monitor downtime is any unit operating hour in which the data
for any of the following parameters are either missing or invalid: NOx
concentration, CO2 or O2 concentration, fuel flow rate, steam flow rate,
steam temperature, steam pressure, or megawatts. The steam flow rate,
steam temperature, and steam pressure are only required if you will use
this information for compliance purposes. (40 CFR Part 60 Subpart
KKKK § 60.4380(b)(2))
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWEI 80 Page 47
6. M002 - Gasoline Storage Tank, 500 gallons aboveground
Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
Gasoline 6.1 N/A N/A N/A Recordkeeping Monthly
Throughput
40 CFR Pat 63 6.2. Work Practice Standards N/A See Condition 6.2
Subpart
CCCCCC
Requirements
Note that these emission units are exempt from the APEN reporting requirements in Regulation No. 3, Part A and the construction
permit requirements in Regulation No. 3, Part B.
These requirements included in this Section II.6 are only federally enforceable. As of the date of revised
permit issuance [August 12, 2008], the requirements in 40 CFR Part 63 Subpart CCCCCC have not been
adopted into Colorado Regulation No. 8, Part E by the Division and are therefore not state-enforceable.
In the event that the Division adopts these requirements this tank will be subject to the APEN reporting
and minor source permitting requirements and these requirements will be state-enforceable.
6.1 The quantity of gasoline processed through this tank shall be monitored and recorded monthly.
Monthly records of gasoline processed shall be retained as required by Condition 6.2.1.
6.2 This tank is subject to the requirements in 40 CFR Part 63 Subpart CCCCCC, "National
Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing
Facilities", as follows:
6.2.1 An affected source shall, upon request by the division, demonstrate that their average
monthly throughput is less than the 10,000-gallon or the 100,000-gallon threshold
level, as applicable (40 CFR Part 63 Subpart CCCCCC § 63.1111 I(e)).
6.2.2 If you have an existing affected source, you must comply with the standard in this
subpart no later than January 10, 2011 (40 CFR Part 63 Subpart CCCCCC §
63.11113(b)).
6.2.3 You must not allow gasoline to be handled in a manner that would result in vapor
releases to the atmosphere for extended periods of time. Measures to be taken
include, but are not limited to, the following (40 CFR Part 63 Subpart CCCCCC §
63.11116(a)):
6.2.3.1 Minimize gasoline spills;
6.2.3.2 Clean up spills as expeditiously as practicable;
6.2.3.3 Cover all open gasoline containers and all gasoline storage tank fill-pipes
with a gasketed seal when not in use;
6.2,3.4 Minimize gasoline sent to open waste collection systems that collect and
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWEI80 Page 48
transport gasoline to reclamation and recycling devices, such as oil/water
separators;
6.2.4 You are not required to submit notifications or reports, but you must have records
available within 24 hours of a request by the Division to document your gasoline
throughput (40 CFR Part 63 Subpart CCCCCC § 63.11116(b)).
6.2.5 You must comply with the requirements of this subpart by the applicable date
specified in Condition 6.2.2 (40 CFR Part 63 Subpart CCCCCC § 63.11116(c)).
7. M002 —Cold Cleaner Solvent Vats
Parameter Permit Limitations Compliance Emission Monitoring
Condition Factor
Number Short Term Long Term Method Interval
Work Practice 7.1 N/A N/A N/A Internal Audit Annually
Standards
Transfer and 7.2 N/A N/A N/A Certification Annually
Storage of
Waste/Used
Solvents
Note that these emission units are exempt from the APEN reporting requirements in Regulation No. 3, Part A and the construction
permit requirements in Regulation No. 3, Part B.
7.1 Operation of the cold cleaner solvent vats shall meet the standards defined in Colorado
Regulation 7, Section X.B. Compliance shall be monitored by following the work practices
defined in Public Service Company's Policy Manual regarding operation, maintenance and
design of the cold cleaner solvent vats. The Policy Manual shall include, at a minimum the
requirements defined in Colorado Regulation 7, Section X.B and shall be available to the
inspector upon request. Audits of the vat operations and/or the policy manual shall be performed
annually to ensure that operations are performed within the requirements of the policy manual
and that the policy manual incorporates the requirements of Regulation 7, Section X.B. Audit
reports are to be maintained and made available to the Division upon request.
7.2 The transfer and storage of waste and used solvents from the cold cleaner solvent vats are subject
to the following requirements (Colorado Regulation No. 7, Section X.A.3 and 4):
7.2.1 In any disposal or transfer of waste or used solvent, at least 80 percent by weight of
the solvent/waste liquid shall be retained (i.e., no more than 20 percent of the liquid
solvent/solute mixture shall evaporate or otherwise be lost during transfers).
7.2.2 Waste or used solvents shall be stored in closed containers unless otherwise required
by law.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 49
8. T005 & T006—Two (2) Simple Cycle Combustion Turbines
Unless otherwise specified, the limitations apply to both turbines together
Parameter I Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
RACT 8.1 N/A N/A N/A See Condition 8.1
Requirements
NOx 8.2. For Each Combustion Turbine: N/A Continuous Continuously
9 ppmvd @ 15%O2 on a 1-hr Emission
average, except as provided for Monitoring
below System
During Combustion Tuning and
Testing(not to exceed 60 hrs/yr per
for both turbines combined):
100 ppmvd @ 15%O2 on a 1-hr
average
Note that the above limits do not
apply during periods of startup and
shutdown.
For Each Combustion Turbine:
15 ppmvd @ 15%O,,on a 4-hr
rolling average
N/A 39.9 tons/yr
CO 8.3. N/A 20 tons/yr N/A Continuous Continuously
Emission
Monitoring
System
SO2 8.4. For Each Combustion Turbine: N/A See Condition 8.4
0.06 lb/mmBtu
N/A 3.7 tons/yr Continuous Continuously
Monitoring
System
VOC 8.5. N/A 2.3 tons/yr T005: Recordkeeping Monthly
0.0002 lb/mmBtu and
T006: Calculation
0.0001 lb/mmBtu
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 50
Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
PM 8.6. For Each Combustion Turbine: N/A Fuel Only Pipeline
0.1 Ib/mmBtu, the average of three Restriction Quality Natural
(3) I-hr tests Gas is Used as
Fuel
N/A 8.9 tons/yr T005: Recordkeeping Monthly
0.004 lb/mmBtu and
T006: Calculation
0.003 lb/mmBtu
PMia 8.7. N/A 8.9 tons/yr T005: Recordkeeping Monthly
0.004 lb/mmBtu and
T006: Calculation
0.003 lb/mmBtu
Natural Gas 8.8. N/A 2,178 mmSCF/yr N/A Recordkeeping Monthly
Usage
Sulfur Content 8.9. N/A N/A N/A See Condition 8.9.
of Natural Gas
Continuous 8.10. N/A N/A N/A See Condition 8.10
Emission
Monitoring
System
Requirements
NSPS Subpart 8.11 N/A N/A N/A See Condition 8.11.
KKKK General
Requirements
NSPS General 8.12. N/A N/A N/A As Required by Subject to
Provisions NSPS General NSPS General
Provisions Provisions
NOx Emissions 8.13. N/A N/A N/A See Condition 8.13
from
Insignificant
Activities
Opacity-State 8.14. Not to Exceed 20% N/A Fuel Only Pipeline
Only Restriction Quality Natural
Opacity 8.15. Not to Exceed 20% Except as N/A Gas is Used as
Provided for in 8.16 Below Fuel
Opacity 8.16. For Certain Operational Activities- N/A
Not to Exceed 30%, for a Period or
Periods Aggregating More than Six
(6)Minutes in any 60 Consecutive
Minutes
Acid Rain 8.17. See Section III of this Permit Certification Annually
Requirements
8.1 The combustion turbines are subject to the Reasonably Available Control Technology
Requirements (RACT) for NOx (Colorado Construction Permit 07WE1100 and Colorado
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 51
Regulation No. 3, Part B, Section III.D.2.a). RACT has been determined to be advanced dry low
NOx (DLN) combustion systems with the emission limitations specified in Condition 8.2.1.
8.2 Emissions of Nitrogen Oxides (NOx) shall not exceed the following limitations:
8.2.1 For purposes of RACT, Nitrogen Oxide (NOx) emissions from each turbine shall
not exceed the following limitations (Colorado Construction Permit 07WE1100):
8.2.1.1 Except as provided for below, emissions of NOx shall not exceed 9 ppmvd
at 15% O2, on a I-hour average.
8.2.1.2 During periods of combustion tuning and testing, emissions of NOx shall
not exceed 100 ppmvd at 15% O2, on a 1-hour average. Use of this NOx
emission limit for purposes of combustion tuning and testing shall not
exceed 60 hours in any calendar year for both turbines combined.
Records of the number of hours each turbine undergoes combustion tuning
and/or testing shall be recorded and maintained and made available to the
Division upon request.
8.2.1.3 The emission limitations above do not apply during periods of startup and
shutdown; however, emissions during startup and shutdown shall be
included in determining compliance with the annual limitation in
Condition 8.2.3.
8.2.1.4 "Startup" shall have the same definition as provided for in Condition
1.2.1.5.
8.2.1.5 "Shutdown" shall have the same definition as provided for in Condition
1.2.1.6.
8.2.1.6 "Combustion Tuning and Testing" shall have the same definition as
provided for in Condition 1.2.1.7.
Compliance with the NOx RACT emission limitations in Conditions 8.2.1.1 and
8.2.1.2 shall be monitored using the continuous emission monitoring systems
(CEMS) required by Condition 8.10. All the CEMS concentration (ppm) data points,
excluding startup and shutdown data points, shall at the end of each clock hour, be
summarized to generate the one-hour average NOx concentration. Each clock hour
average NOx concentration shall be compared to the limitations in Conditions 8.2.1.1
and 8.2.1.2 as appropriate.
In the event that the startup ends within a clock hour or the shutdown begins within a
clock hour, all non-startup and/or non-shutdown concentration (ppm) data points
within that clock hour shall be averaged together to generate the average NOx
concentration and that average concentration shall be compared to the limitations in
Conditions 8.2.1.1 and 8.2.1.2 as appropriate.
The emission limits in Condition 8.2.1.2 apply to any clock hour in which combustion
tuning and testing activities occur.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 52
8.2.2 NOx emissions shall not exceed 15 ppm at 15 % O2, on a 4-hr rolling average
(Colorado Construction Permit 07WE1100 and 40 CFR Part 60 Subpart KKKK §§
60.4320(a) 69.4350(g)). Compliance with the NOx emission limitations shall be
monitored using the CEMS required by Condition 8.10.
Note that the NOx emission limits 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 reports required by Condition 5.5.
8.2.3 Annual emissions of NOx from both turbines together shall not exceed the above
limitation (Colorado Construction Permit 07WE1100, as modified under the
provisions of Section I, Condition 1.3 to remove the monthly limitations). Monthly
emissions from each turbine shall be determined using the continuous emission
monitoring system required by Condition 8.10. Monthly emissions from each turbine
shall be summed together and used in a twelve month rolling total to monitor
compliance with the annual emission limitation. Each month a new twelve month
total shall be calculated using the previous twelve months total.
For purposes of determining compliance with the annual limitation, mass emissions
shall be recorded during all periods when a unit is in operation and burning fuel,
including periods of startup and shutdown.
8.3 Annual emissions for CO from both turbines together shall not exceed the above limitation
(Colorado Construction Permit 07WE1100, as modified under the provisions of Section I,
Condition 1.3 to remove the monthly limitations). Monthly emissions from each turbine shall be
determined using the continuous emission monitoring system required by Condition 8.10.
Monthly emissions from each turbine shall be summed together and used in a twelve month
rolling total to monitor compliance with the annual emission limitation. Each month a new
twelve month total shall be calculated using the previous twelve months total.
For purposes of determining compliance with the annual limitation, mass emissions shall be
recorded during all periods when a unit is in operation and burning fuel, including periods of
startup and shutdown.
8.4 Sulfur Dioxide (SO2) emissions shall not exceed the following limitations:
8.4.1 You must not bum in the subject stationary combustion turbine any fuel which
contains total potential sulfur emissions in excess of 26 ng 5O2/J (0.060 lb
SO2/MMBtu) heat input. (40 CFR Part 60 Subpart KKKK § 60.4330(a)(2)) In the
absence of credible evidence to the contrary, compliance with the fuel gas sulfur limit
is presumed since only pipeline quality natural gas is used as fuel in these turbines.
The natural gas used as fuel shall meet the requirements in Condition 8.9.
8.4.2 Annual Sulfur Dioxide (SO2) emissions from both turbines together shall not
exceed the above limitations (Colorado Construction Permit 07WE1100, as modified
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 53
under the provisions of Section I, Condition 1.3 to remove the monthly limitations).
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 shall be summed together and used in a twelve
month rolling total to monitor compliance with the annual limitations. Each month a
new twelve month total shall be calculated using the previous twelve months data.
8.5 Annual VOC emissions from both turbines together shall not exceed the above limitations
(Colorado Construction Permit 07WE1100, as modified under the provisions of Section I,
Condition 1.3 to remove the monthly limitations). Monthly emissions from each turbine shall be
calculated by the end of the subsequent month using the emission factors in the above table
(from performance tests conducted May 20 & 21, 2009) and the heat input for the month as
recorded on the data acquisition and handling system (DAHS) for the continuous emission
monitoring system (required by Condition 8.10) in the following equation:
tons/mo=(EF, lbs/mmBtu)x heat input(mmBtu/mo)
2000 lbs/ton
Monthly emissions from each turbine shall be summed together and used in a twelve month
rolling total to monitor compliance with the annual limitations. Each month a new twelve month
total shall be calculated using the previous twelve months data.
8.6 Particulate matter (PM) emissions shall not exceed the following limitations:
8.6.1 Particulate Matter (PM) emissions from each turbine shall not exceed 0.1
lbs/mmBtu (Colorado Construction Permit 07WE1100 and Colorado Regulation No.
1, Section III.A.I.c). In the absence of credible evidence to the contrary, compliance
with the particulate matter emission limits is presumed since only pipeline natural gas
is permitted to be used as fuel in the turbines.
8.6.2 Annual PM emissions from both turbines together shall not exceed the above
limitations (Colorado Construction Permit 07WE1100, as modified under the
provisions of Section I, Condition 1.3 to remove the monthly limitations). Monthly
emissions from each turbine shall be calculated by the end of the subsequent month
using the emission factors in the above table (from performance tests conducted May
20 & 21, 2009) and the heat input for the month as recorded on the data acquisition
and handling system (DAHS) for the continuous emission monitoring system
(required by Condition 8.10) in the equation in condition 8.5 Monthly emissions
from each turbine shall be summed together and used in a twelve month rolling total
to monitor compliance with the annual limitations. Each month a new twelve month
total shall be calculated using the previous twelve months data.
8.7 Annual PKo emissions from both turbines together shall not exceed the above limitations
(Colorado Construction Permit 07WE1100, as modified under the provisions of Section I,
Condition 1.3 to remove the monthly limitations). Monthly emissions from each turbine shall be
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 54
calculated by the end of the subsequent month using the emission factors in the above table
(from performance tests conducted May 20 & 21, 2009) and the heat input for the month as
recorded on the data acquisition and handling system (DAHS) for the continuous emission
monitoring system (required by Condition 8.10) in the equation in condition 8.5 Monthly
emissions from each turbine shall be summed together and used in a twelve month rolling total to
monitor compliance with the annual limitations. Each month a new twelve month total shall be
calculated using the previous twelve months data.
8.8 Natural gas consumption for both turbines together shall not exceed the above limitations
(Colorado Construction Permit 07WE1100, as modified under the provisions of Section I,
Condition 1.3 to remove the monthly limitations). The natural gas consumption for each
combustion turbine shall be monitored using the data acquisition and handling systems (DAHS)
for the continuous emission monitoring system (CEMS) required by Condition 8.10. Monthly
natural gas fuel consumption for each turbine shall be summed together and used in a rolling
twelve month total to monitor compliance with the annual limitation. Each month new twelve
month rolling total shall be calculated using the previous twelve months data for that fuel.
8.9 The permittee shall maintain records demonstrating that the natural gas burned has a total sulfur
content less than 0.5 grains/I 00 SCF. Natural gas that meets this sulfur limitation is considered
pipeline quality 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. These
records shall be made available to the Division upon request.
8.10 For each combustion turbine, continuous emission monitoring systems (CEMS) shall be
installed, calibrated, maintained and operated (Colorado Construction Permit 07WEI 100 and 40
CFR Part 75). The CEMS shall meet the following requirements:
8.10.1 The Monitoring Requirements identified in Condition 5.1.
8.10.2 The General Provisions identified in Condition 5.2.
8.10.3 The Equipment and QA/QC Requirements identified in Condition 5.3.
8.10.4 The Data Substitution Requirements identified in Condition 5.4.
8.10.5 The Recordkeeping and Reporting Requirements identified in Condition 5.5.
8.10.6 The Specific Provisions for NSPS Subpart KKKK in Condition 5.6.
•
8.11 You must operate and maintain your stationary combustion turbine, air pollution control
equipment, and monitoring equipment in a manner consistent with good air pollution control
practices for minimizing emissions at all times including during startup, shutdown, and
malfunction. (40 CFR Part 60 Subpart KKKK § 60.4333(a))
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 55
8.12 Each turbine is subject to the NSPS Subpart A, General Provisions requirements (Colorado
Regulation No. 6, Part A, Federal 40 CFR 60.1 through 60.19). Specifically, these units are
subject to the following:
8.12.1 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 § 60.12)
8.12.2 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 Administrator 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 § 60.11(d)).
8.13 NOx emissions from all insignificant activities associated with these turbines shall be included in
monitoring compliance with the annual NOx emission limitation in Condition 8.2.3 (Colorado
Construction Permit 07WE1100). The permittee shall track emissions from all NOx emitting
insignificant activities associated with these turbines on a monthly basis and include those
emissions in the annual emission calculations specified in Condition 8.2.3. This information
shall be kept on site and made available to the Division upon request. For the purposes of this
condition, insignificant activities shall be defined as any activity or equipment, which emits any
amount but does not require an Air Pollution Emission Notice (APEN).
Based on the information available as of permit issuance [DATE] there are no insignificant
activities associated with turbines 5 and 6 that are a source of NOx emissions.
8.14 Except as provided for in Condition 8.15 below, no owner or operator of a source shall allow or
cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity
(Colorado Construction Permit 07WE1100 and Colorado Regulation No. 1, Section II.A.1). This
opacity standard applies to each combustion turbine. In the absence of credible evidence to the
contrary, compliance with the 20% opacity limit shall be presumed since only pipeline quality
natural gas is permitted to be used as fuel in the turbines.
8.15 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air
pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up,
process modifications, or adjustment or occasional cleaning of control equipment which is in
excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty
(60) consecutive minutes (Colorado Construction Permit 07WE1100 and Colorado Regulation
No. 1, Section II.A.4). This opacity standard applies to each combustion turbine. In the
absence of credible evidence to the contrary, compliance with the 30% opacity limit shall be
presumed since only pipeline quality natural gas is permitted to be used as fuel in the turbines.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 56
8.16 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 combustion turbine. In the
absence of credible evidence to the contrary, compliance with the 20% opacity requirement is
presumed since only pipeline quality natural gas is permitted to be used as fuel in the turbines.
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).
8.17 This unit 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 complete and segregable portion of
the Operating Permit. As such the requirements are found in Section III of this permit.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 57
9. M004 - Diesel Fuel Fired Internal Combustion Engines
Emergency Generator (2 engines, each 1,800 hp) and Emergency Fire Pump (255 hp)
Unless otherwise specified, the requirements apply to each engine
Parameter Permit Limitations Compliance Monitoring
Condition Emission Factor
Number Short Term Long Term Method Interval
MACT ZZZZ 9.1. ' Change Oil and Filter N/A See Condition 9.1.
Requirements Inspect Air Cleaner
Inspect all Hoses and Belts
SO2 9.2. 0.8 Ibs/mmBtu N/A Fuel Restriction Only Diesel
Fuel is Used
as Fuel
Opacity 9.3 Not to Exceed 20%Except as N/A EPA Method 9 See Condition
Provided for Below 9.3
For Startup—Not to Exceed
30%, for a Period or Periods
Aggregating More than Six(6)
Minutes in any 60 Consecutive
Minutes
MACT General 5.4. N/A N/A N/A See Condition 9.4
Provisions
Note that these emission units are exempt from the APEN reporting requirements in Regulation No. 3, Part A and the construction
permit requirements in Regulation No. 3,Pan B.
9.1 These 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 9.1 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 (§ 60.6595)
9.1.1 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)(1))
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)
Operating Permit Number: 97OPWE 180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 58
9.1.2 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:
9.1.2.1 Change oil and filter every 500 hours of operation or annually whichever
comes first. (Table 2d, item 4.a)
9.1.2.2 Inspect air cleaner every 1,000 hours of operation or annually whichever
comes first. (Table 2d, item 4.b)
9.1.2.3 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:
9.1.2.4 Sources have the option to utilize an oil analysis program as described in
Condition 9.1.8 in order to extend the specified oil change requirement in
Condition 9.1.2.1. (Table 2d, footnote 1)
9.1.2.5 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 9.1.2.1
through 9.1.2.3, 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)
9.1.3 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))
9.1.4 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,
Operating Permit Number: 97OP WE 180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWEI80 Page 59
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)
9.1.5 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))
9.1.6 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(g))
9.1.7 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))
9.1.8 If you own or operate a stationary engine that is subject to the work, operation or
management practices in Condition 9.1.2.1, you have the option of utilizing an oil
analysis program in order to extend the specified oil change requirement in Condition
9.1.2.1. The oil analysis must be performed at the same frequency specified for
changing the oil in Condition 9.1.2.1. 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. (§ 63.66250))
flow do I demonstrate continuous compliance with the emission limitations and operating
limitations? (§ 63.6640)
Operating Permit Number: 97OPWEI80 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 60
9.1.9 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
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)
9.1.9.1 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))
9.1.9.2 There is no time limit on the use of emergency stationary RICE in
emergency situations. (§ 63.6640(O(2))
9.1.9.3 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))
9.1.9.4 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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 61
9.1.9.4, as long as the power provided by the financial arrangement is
limited to emergency power. (§ 63.6640(0(4))
What records must I keep? (¢ 63.6655)
9.1.10 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 9.1.2.1 through 9.1.2.3. (§
63.6655(e) and § 63.6655(e)(3))
9.1.11 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(f) and §
63.6655(0(2))
9.2 Sulfur Dioxide (SO2) emissions shall not exceed 0.8 lbs/mmBtu (Colorado Regulation No. 1,
Section VI.B.4.b.(i)). In the absence of credible evidence to the contrary, compliance with the
SO2 emission limitation shall be presumed since only diesel fuel is permitted to be used as fuel in
these engines.
9.3 Opacity of emissions from the engine shall not exceed the following:
9.3.1 Except as provided for in Condition 9.3 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).
9.3.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere
any air pollutant resulting from startup which is in excess of 30% opacity for a period or
periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes
(Colorado Regulation No. 1, Section II.A.4).
Compliance with these limitations shall be monitored by conducting opacity observations in
accordance with EPA Reference Method 9 as follows:
9.3.3 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
Operating Permit Number: 97OPWEI80 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 62
hours. In addition, a record shall be kept of the date and time the engine started and when
it was shutdown.
9.3.4 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.
9.3.5 If no opacity observations are made pursuant to Conditions 9.3.3 and 9.3.4 above, then an
opacity observation shall be conducted annually.
9.3.6 All opacity observations shall be performed by an observer with current and valid
Method 9 certification. Results of Method 9 readings and a copy of the certified Method
9 reader's certificate shall be kept on site and made available to the Division upon
request.
9.4 These engines are subject to the requirements in 40 CFR part 63 Subpart A "General
Provisions", as adopted by reference in Colorado Regulation No. 8, Part E, Section I as specified
in 40 CFR Part 63 Subpart ZZZZ § 63.6665. These requirements include, but are not limited to
the following:
9.4.1 Prohibited activities in § 63.4(a).
9.4.2 Circumvention in § 63.4(b)
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE1 80 Page 63
SECTION III - Acid Rain Requirements
1. Designated Representative and Alternate Designated Representative
Designated Representative:
Name: Steve Mills
Title: General Manager—Power Generation, Colorado
Phone: (303)628-2679
Alternate Designated Representative:
Name: Dean Metcalf
Title: Director,Air and Water
Phone: (720)497-2007
2. Sulfur Dioxide Emission Allowances and Nitrogen Oxide Emission Limitations
2010 -1 2011 2012 2013 2014 ] 2015
Turbine No. 2
SO2 0* 0* 0* 0* 0* 0*
Allowances,per
40 CFR Part
73.10(b),Table
2
NOx Limits This Unit Has No Title IV NOx Limits(see Section 5)
Turbine No.3
SO2 0* 0* 0* 0* 0* 0*
Allowances,per
40 CFR Part
' 73.10(b),Table
2
NOx Limits This Unit Has No Title IV NOx Limits(see Section 5)
Turbine No.4
SO2 0* 0" 0" 0* 0* 0*
Allowances,per
40 CFR Part
73.10(b),Table
2
NOx Limits This Unit I-las No Title IV NOx Limits(see Section 5)
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 64
2010 2011 2012 2013 2014 2015
Turbine No. 5
SO2 0* 0* 0* 0* 0* 0*,
Allowances, per
40 CFR Part
73.10(6),Table
2
NOx Limits This Unit Has No Title IV NOx Limits(see Section 5)
Turbine No.6
SO2 0* 0* 0* 0* 0* 0*
Allowances, per
40 CFR Part
73.10(6),Table
2
NOx Limits This Unit Has No Title IV 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. This is a
new unit and allowances were not included in 40 CFR Part 73,Table 2(1997 version of CFR).
3. Standard Requirements
Units T002, T003, T004, T005 and T006 of this facility are subject to and the source has certified that
they will comply with the following standard conditions.
Permit Requirements.
(1) The designated representative of each affected source and each affected unit at the source shall:
(i) Submit a complete Acid Rain permit application (including a compliance plan) under 40
CFR part 72 in accordance with the deadlines specified in 40 CFR 72.30; and
(ii) Submit in a timely manner any supplemental information that the Division determines is
necessary in order to review an Acid Rain permit application and issue or deny an Acid
Rain permit;
(2) The owners and operators of each affected source and each affected unit at the source shall:
(i) Operate the unit in compliance with a complete Acid Rain permit application or a
superseding Acid Rain permit issued by the Division; and
(ii) Have an Acid Rain Permit.
Monitoring Requirements.
(1) The owners and operators and, to the extent applicable, designated representative of each
affected source and each affected unit at the source shall comply with the monitoring
requirements as provided in 40 CFR part 75.
(2) The emissions measurements recorded and reported in accordance with 40 CFR part 75 shall be
used to determine compliance by source or the unit with the Acid Rain emissions limitations and
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 65
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: 97OP WE 180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 66
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: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 67
(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:
(1) Except as expressly provided in title IV of the Federal Clean Air Act, exempting or excluding the
owners and operators and, to the extent applicable, the designated representative of an affected
source or affected unit from compliance with any other provision of the Federal Clean Air Act,
including the provisions of title I of the Federal Clean Air Act relating to applicable National
Ambient Air Quality Standards or State Implementation Plans;
(2) Limiting the number of allowances a unit can hold;provided, that the number of allowances held
by the unit shall not affect the source's obligation to comply with any other provisions of the
Federal Clean Air Act;
(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: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 68
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.
5. Comments, Notes and Justifications
Combustion Turbines No. 2, 3, 4, 5 and 6 burn only natural gas as fuel. The NOx limitations in 40 CFR Part 76
are only applicable to coal-fired utility units.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 69
SECTION IV - Permit Shield
Regulation No. 3, 5 CCR 1001-5, Part C, §§ I.A.4, V.D., & XIII.B and § 25-7-114.4(3)(a), C.R.S.
1. Specific Non-Applicable Requirements
Based upon the information available to the Division and supplied by the applicant, the following
parameters and requirements have been specifically identified as non-applicable to the facility to which
this permit has been issued. This shield does not protect the source from any violations that occurred
prior to or at the time of permit issuance. In addition, this shield does not protect the source from any
violations that occur as a result of any modification or reconstruction on which construction commenced
prior to permit issuance.
Emission Unit Applicable Requirement Justification
Description&
Number
Facility Colorado Regulation No. 7, Section V.B This requirement is not applicable since the facility is not a bulk
gasoline terminal, bulk gasoline plant or gas dispensing facility.
Facility Colorado Regulation No. 7, Sections These requirements are not applicable as the petroleum liquids at this
VI.B.I &2 facility are stored in tanks that are less than 40,000 gallons.
Facility Colorado Regulation No.7, Section VII.C This requirement is not applicable as crude oil is not stored in tanks
exceeding 40,000 gallons.
Cooling 40 CFR Part 63, Subpart Q(as adopted by These requirements are not applicable because the cooling towers do
Towers reference in Colorado Regulation No. 8, not use chromium-based water treatment chemicals.
Section E)
2. General Conditions
Compliance with this Operating Permit shall be deemed compliance with all applicable requirements
specifically identified in the permit and other requirements specifically identified in the permit as not
applicable to the source. This permit shield shall not alter or affect the following:
2.1 The provisions of §§ 25-7-112 and 25-7-113, C.R.S., or § 303 of the federal act, concerning
enforcement in cases of emergency;
2.2 The liability of an owner or operator of a source for any violation of applicable requirements
prior to or at the time of permit issuance;
2.3 The applicable requirements of the federal Acid Rain Program, consistent with § 408(a) of the
federal act;
2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to
§ 25-7-111(2)(I), C.R.S., or the ability of the Administrator to obtain information pursuant to §
114 of the federal act;
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 70
2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit for cause
pursuant to Regulation No. 3, Part C, § XIII.
2.6 Sources are not shielded from terms and conditions that become applicable to the source
subsequent to permit issuance.
3. Streamlined Conditions
•
The following applicable requirements have been subsumed within this operating permit using the
pertinent streamlining procedures approved by the U.S. EPA. For purposes of the permit shield,
compliance with the listed permit conditions will also serve as a compliance demonstration for purposes
of the associated subsumed requirements.
Permit Condition(s) Streamlined(Subsumed)Requirements
Section II, Conditions Colorado Regulation No. 6, Part B, Section ILD.3.b [SO2 emissions shall not exceed 0.35 Ibs/mmBtu]
1.4.1,2.4.3 and 8.4.1. -State-only requirement
Section II, Condition 40 CFR Part 60 Subpart Da § 60.44Da(a)(2), as adopted by reference in Colorado Regulation No. 6,
1.2.1.2 Part A [NOx emissions shall be reduced by 25 percent of the potential combustion concentration]
Section II, Condition 40 CFR Part 60 Subpart Da § 60.44Da(a)(1), as adopted by reference in Colorado Regulation No. 6,
1.2.1.2 Part A [NOx emissions shall not exceed 0.20 lbs/mmBtu]
Section II, Conditions 40 CFR Part 60 Subpart GG § 60.332(a), as adopted by reference in Colorado Regulation No. 6, Part A
1.2.1 (Turbines 2 and 3) [NOx emissions shall not exceed 105.4 ppmvd (for Turbines 2 and 3) and 112 ppmvd (for Turbine 4),
and 2.5.1 (Turbine 4) each at 15%O2 and ISO standard ambient conditions]
Section II,Conditions 40 CFR Part 60 Subpart GG § 60.334(h)(3), as adopted by reference in Colorado Regulation No. 6,
1.9 and 2.10 Part A [source shall monitor the sulfur content of the fuel]
Section II,Conditions 40 CFR Part 60 Subpart GG § 60.334(j)(1)(iii), as adopted by reference in Colorado Regulation No. 6,
1.10 and 2.8 Part A[NOx excess emission reporting]
Section II,Condition 1.9 Colorado Construction Permit 94WE609 PSD, only the following portion of Condition 9"an automatic
natural gas sampler shall be installed in the gas supply line that automatically samples each 40
mmSCF, and shall be analyzed monthly"
Section 11, Conditions Colorado Construction Permit 99WE0762 PSD, Conditions 7.d & i and 4 [continuous emission
5.2 and 5.3 monitoring systems shall meet the requirements in 40 CFR Part 60] for the NOx and diluent
continuous emission monitoring systems only.
Section II, Conditions Colorado Construction Permit 94WE609 PSD, Conditions 3.i & n [Notification of demonstration of
5.2 and 5.3 continuous emission monitoring system (CEMS) and CEMS quality assurance and quality control
requirements] for the NOx and diluent continuous emission monitoring systems only.
Section II, Conditions 40 CFR Part 60 Subpart Da § 60.44Da(d)(I), as adopted by reference in Colorado Regulation No. 6,
2.5.1.2 and 2.9 Part A [NOx emissions shall not exceed 1.6 lbs/MW-hr]
Section 11, Condition Colorado Regulation No. I, Section VI.B.4.c.(ii) and VI.B.2 (SO2 emissions shall not exceed 0.35
8.4.1 Ibs/mmBtu on a 3-hr rolling average]
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 71
SECTION V - General Permit Conditions
3/23/10 version
1. Administrative Changes
Regulation No. 3, 5 CCR 1001-5, Part A, § Ill.
The permittee shall submit an application for an administrative permit amendment to the Division for those permit changes
that are described in Regulation No. 3, Part A, § 1.13.1. The permittee may immediately make the change upon submission of
the application to the Division.
2. Certification Requirements
Regulation No. 3, 5 CCR 1001-5, Part C, §§ 111.8.9., V.C.16.a.&e. and V.C.17.
a. Any application, report, document and compliance certification submitted to the Air Pollution Control Division
pursuant to Regulation No. 3 or the Operating Permit shall contain a certification by a responsible official of the
truth, accuracy and completeness of such form, report or certification stating that,based on information and belief
formed after reasonable inquiry,the statements and information in the document are true,accurate and complete.
b. All compliance certifications for terms and conditions in the Operating Permit shall be submitted to the Air Pollution
Control Division at least annually unless a more frequent period is specified in the applicable requirement or by the
Division in the Operating Permit.
c. Compliance certifications shall contain:
(i) the identification of each permit term and condition that is the basis of the certification;
(ii) the compliance status of the source;
(iii) whether compliance was continuous or intermittent;
(iv) method(s) used for determining the compliance status of the source, currently and over the reporting
period; and
(v) such other facts as the Air Pollution Control Division may require to determine the compliance status of the
source.
d. All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental
Protection Agency at the addresses listed in Appendix D of this Permit.
e. If the permittee is required to develop and register a risk management plan pursuant to § 112(r)of the federal act, the
permittee shall certify its compliance with that requirement; the Operating Permit shall not incorporate the contents
of the risk management plan as a permit term or condition.
3. Common Provisions
Common Provisions Regulation, 5 CCR 1001-2 §§ ILA., ILB., 11.C.,11,.E., 11.F., 11.1,and 11.1
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: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 72
b. Emission Monitoring Requirements
The Division may require owners or operators of stationary air pollution sources to install, maintain, and use
instrumentation to monitor and record emission data as a basis for periodic reports to the Division.
c. Performance Testing
The owner or operator of any air pollution source shall, upon request of the Division, conduct performance test(s)
and furnish the Division a written report of the results of such test(s) in order to determine compliance with
applicable emission control regulations.
Performance test(s)shall be conducted and the data reduced in accordance with the applicable reference test
methods unless the Division:
(i) specifies or approves, in specific cases,the use of a test method with minor changes in methodology;
(ii) approves the use of an equivalent method;
(iii) approves the use of an alternative method the results of which the Division has determined to be adequate
for indicating where a specific source is in compliance;or
(iv) waives the requirement for performance test(s)because the owner or operator of a source has demonstrated
by other means to the Division's satisfaction that the affected facility is in compliance with the standard.
Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to
require testing under the Colorado Revised Statutes, Title 25,Article 7, and pursuant to regulations
promulgated by the Commission.
Compliance test(s)shall be conducted under such conditions as the Division shall specify to the plant operator based
on representative performance of the affected facility. The owner or operator shall make available to the Division
such records as may be necessary to determine the conditions of the performance test(s). Operations during period of
startup, shutdown, and malfunction shall not constitute representative conditions of performance test(s)unless
otherwise specified in the applicable standard.
The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance
test to afford the Division the opportunity to have an observer present. The Division may waive the thirty day notice
requirement provided that arrangements satisfactory to the Division are made for earlier testing.
The owner or operator of an affected facility shall provide, or cause to be provided, performance testing facilities as
follows:
(i) Sampling ports adequate for test methods applicable to such facility;
(ii) Safe sampling platform(s);
(iii) Safe access to sampling platform(s);and
(iv) Utilities for sampling and testing equipment.
Each performance test shall consist of at least three separate runs using the applicable test method. Each run shall be
conducted for the time and under the conditions specified in the applicable standard. For the purpose of determining
compliance with an applicable standard, the arithmetic mean of results of at least three runs shall apply. In the event
that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of
forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other
circumstances beyond the owner or operator's control, compliance may, upon the Division's approval, be
dctennined using the arithmetic mean of the results of the two other runs.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
•
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 73
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: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 74
e. Circumvention Clause
A person shall not build,erect, install,or use any article, machine,equipment,condition, or any contrivance,the use
of which, without resulting in a reduction in the total release of air pollutants to the atmosphere,reduces or conceals
an emission which would otherwise constitute a violation of this regulation. No person shall circumvent this
regulation by using more openings than is considered normal practice by the industry or activity in question.
Compliance Certifications
For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in
violation of any standard in the Colorado State Implementation Plan,nothing in the Colorado State Implementation
Plan shall preclude the use, including the exclusive use, of any credible evidence or information,relevant to whether
a source would have been in compliance with applicable requirements if the appropriate performance or compliance
test or procedure had been performed. Evidence that has the effect of making any relevant standard or permit term
more stringent shall not be credible for proving a violation of the standard or permit term.
When compliance or non-compliance is demonstrated by a test or procedure provided by permit or other applicable
requirement,the owner or operator shall be presumed to be in compliance or non-compliance unless other relevant
credible evidence overcomes that presumption.
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: 97OP WE 180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 75
The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements
that derive from new source performance standards or national emissions standards for hazardous air pollutants, or
any other federally enforceable performance standard or emission limit with an averaging time greater than twenty-
four hours. In addition, an affirmative defense cannot be used by a single source or small group of sources where
the excess emissions have the potential to cause an exceedance of the ambient air quality standards or Prevention of
Significant Deterioration (PSD) increments.
In making any determination whether a source established an affirmative defense,the Division shall consider the
information within the notification required above and any other information the Division deems necessary, which
may include,but is not limited to,physical inspection of the facility and review of documentation pertaining to the
maintenance and operation of process and air pollution control equipment.
4. Compliance Requirements
Regulation No. 3, 5 CCR 1001-5, Part C, §§ III.C.9., V.C.11. & I6.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: 97OPWEI80 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 76
g. The permittee shall not knowingly falsify,tamper with, or render inaccurate any monitoring device or method
required to be maintained or followed under the terms and conditions of the Operating Permit.
5. Emergency Provisions
Regulation No. 3, 5 CCR 1001-5, Part C, 6 VII.
An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the
source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that
causes the source to exceed the technology-based emission limitation under the permit due to unavoidable increases in
emissions attributable to the emergency. "Emergency" does not include noncompliance to the extent caused by improperly
designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. An emergency
constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology-based emission
limitation if the permittee demonstrates, through properly signed,contemporaneous operating logs, or other relevant evidence
that:
a. an emergency occurred and that the permittee can identify the cause(s)of the emergency;
b. the permitted facility was at the time being properly operated;
c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that
exceeded the emission standards, or other requirements in the permit;and
d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the
next working day following the emergency, and followed by written notice within one month of the time when
emissions limitations were exceeded due to the emergency. This notice must contain a description of the
emergency,any steps taken to mitigate emissions, and corrective actions taken.
This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement.
6. Emission Controls for Asbestos
Regulation No. 8, 5 CCR 1001-10, Part B
The permittee shall not conduct any asbestos abatement activities except in accordance with the provisions of Regulation No.
8, Part B, "asbestos control."
7. Emissions Trading, Marketable Permits, Economic Incentives
Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.I3.
No permit revision shall be required under any approved economic incentives, marketable permits, emissions trading and
other similar programs or processes for changes that are specifically provided for in the permit.
8. Fee Payment
C.R.S. &&25-7-114.1(6)and 25-7-114.7
a. The permittee shall pay an annual emissions fee in accordance with the provisions of C.R.S. §25-7-114.7. A 1%
per month late payment fee shall be assessed against any invoice amounts not paid in full on the 91st day after the
date of invoice, unless a permittee has filed a timely protest to the invoice amount.
b. The permittee shall pay a permit processing fee in accordance with the provisions of C.R.S. § 25-7-114.7. If the
Division estimates that processing of the permit will take more than 30 hours, it will notify the permittee of its
estimate of what the actual charges may be prior to commencing any work exceeding the 30 hour limit.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 77
c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S. § 25-7-114.1(6)for each APEN or
revised APEN filed.
9. Fugitive Particulate Emissions
Regulation No. 1, 5 CCR 1001-3, § III.D.1.
The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate
emissions into the atmosphere, in accordance with the provisions of Regulation No. I, § III.D.1.
10. Inspection and Entry
Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.16.b.
Upon presentation of credentials and other documents as may be required by law, the permittee shall allow the Air Pollution
Control Division,or any authorized representative,to perform the following:
a. enter upon the permittee's premises where an Operating Permit source is located, or emissions-related activity is
conducted, or where records must be kept under the terms of the permit;
b. have access to, and copy,at reasonable times, any records that must be kept under the conditions of the permit;
c. inspect at reasonable times any facilities, equipment(including monitoring and air pollution control equipment),
practices, or operations regulated or required under the Operating Permit;
d. sample or monitor at reasonable times, for the purposes of assuring compliance with the Operating Permit or
applicable requirements, any substances or parameters.
11. Minor Permit Modifications
Regulation No. 3,5 CCR 1001-5,Part C, §§ X. & 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.
13. No Property Rights Conveyed
Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.1 l.d.
This permit does not convey any property rights of any sort, or any exclusive privilege.
14. Odor
Regulation No. 2, 5 CCR 1001-4, Part A
As a matter of state law only, the permittee shall comply with the provisions of Regulation No. 2 concerning odorous
emissions.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 78
15. Off-Permit Changes to the Source
Regulation No. 3, 5 CCR 1001-5, Part C,§XII.B.
The permittee shall record any off-permit change to the source that causes the emissions of a regulated pollutant subject to an
applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from the change, including
any other data necessary to show compliance with applicable ambient air quality standards. The permittee shall provide
contemporaneous notification to the Air Pollution Control Division and to the Environmental Protection Agency at the
addresses listed in Appendix D of this Permit. The permit shield shall not apply to any off-permit change.
16. Opacity
Regulation No. 1, 5 CCR 1001-3, §§ I., II.
The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1, §§ 1.11.
17. Open Burning
Regulation No. 9, 5 CCR 1001-11
The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions
of Regulation No. 9.
18. Ozone Depleting Compounds
Regulation No. 15, 5 CCR 1001-17
The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds.
Sections I., ILC., lI D., III. IV., and V. of Regulation No. 15 shall be enforced as a matter of state law only.
19. Permit Expiration and Renewal
Regulation No. 3,5 CCR 1001-5, Part C, §§ III.B.6., IV.C., V.C.2.
a. The permit term shall be five(5)years. The permit shall expire at the end of its term. Permit expiration terminates
the permittee's right to operate unless a timely and complete renewal application is submitted.
b. Applications for renewal shall be submitted at least twelve months, but not more than IS months, prior to the
expiration of the Operating Permit. An application for permit renewal may address only those portions of the permit
that require revision, supplementing, or deletion, incorporating the remaining permit terms by reference from the
previous permit. A copy of any materials incorporated by reference must be included with the application.
20. Portable Sources
Regulation No. 3, 5 CCR 1001-5, Part C, § 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.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
•
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 79
"Prompt" is defined as follows:
a. Any definition of"prompt"or a specific timeframe for reporting deviations provided in an underlying applicable
requirement as identified in this permit;or
b. Where the underlying applicable requirement fails to address the time frame for reporting deviations,reports of
deviations will be submitted based on the following schedule:
(i) For emissions of a hazardous air pollutant or a toxic air pollutant(as identified in the applicable regulation)
that continue for more than an hour in excess of permit requirements,the report shall be made within 24
hours of the occurrence;
(ii) For emissions of any regulated air pollutant,excluding a hazardous air pollutant or a toxic air pollutant that
continue for more than two hours in excess of permit requirements, the report shall be made within 48
hours; and
(iii) For all other deviations from permit requirements,the report shall be submitted every six(6)months,
except as otherwise specified by the Division in the permit in accordance with paragraph 22.d. below.
c. If any of the conditions in paragraphs b.i or b.ii above are met, the source shall notify the Division by telephone
(303-692-3155)or facsimile(303-782-0278)based on the timetables listed above. [Explanatory note: Notification
by telephone or facsimile must sped that this notification is a deviation report for an Operating Permit.) A
written notice,certified consistent with General Condition 2.a. above(Certification Requirements), shall be
submitted within 10 working days of the occurrence. All deviations reported under this section shall also be
identified in the 6-month report required above.
"Prompt reporting" does not constitute an exception to the requirements of "Emergency Provisions" for the purpose of
avoiding enforcement actions.
22. Record Keeping and Reporting Requirements
Regulation No. 3, 5 CCR 1001-5, Part A, $ II.;Part C, 65 V.C.6., V.C.7.
a. Unless otherwise provided in the source specific conditions of this Operating Permit, the permittee shall maintain
compliance monitoring records that include the following information:
(i) date, place as defined in the Operating Permit, and time of sampling or measurements;
(ii) date(s)on which analyses were performed;
(iii) the company or entity that performed the analysis;
(iv) the analytical techniques or methods used;
(v) the results of such analysis; and
(vi) the operating conditions at the time of sampling or measurement.
b. The permittee shall retain records of all required monitoring data and support information for a period of at least five
(5)years from the date of the monitoring sample, measurement, report or application. Support information, for this
purpose, includes all calibration and maintenance records and all original strip-chart recordings for continuous
monitoring instrumentation, and copies of all reports required by the Operating Permit. With prior approval of the
Air Pollution Control Division, the permittee may maintain any of the above records in a computerized form.
c. Permittees must retain records of all required monitoring data and support information for the most recent twelve
(12)month period, as well as compliance certifications for the past five(5)years on-site at all times. A permittee
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 80
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, §
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.
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.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 81
25. Severability Clause
Regulation No. 3, 5 CCR 1001-5, Part C, $ V.C.10.
In the event of a challenge to any portion of the permit, all emissions limits, specific and general conditions, monitoring,
record keeping and reporting requirements of the permit, except those being challenged,remain valid and enforceable.
26. Significant Permit Modifications
Regulation No. 3, 5 CCR 1001-5, Part C $ III.B.2.
The permittee shall not make a significant modification required to be reviewed under Regulation No. 3, Part B
("Construction Permit" requirements) without first receiving a construction permit. The permittee shall submit a complete
Operating Permit application or application for an Operating Permit revision for any new or modified source within twelve
months of commencing operation, to the address listed in Item 1 in Appendix D of this permit. If the permittee chooses to
use the "Combined Construction/Operating Permit" application procedures of Regulation No. 3, Part C, then the Operating
Permit must be received prior to commencing construction of the new or modified source.
27. Special Provisions Concerning the Acid Rain Program
Regulation No. 3, 5 CCR 1001-5, Part C, §5 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, Part C, § II.C.
No transfer or assignment of ownership of the Operating Permit source will be effective unless the prospective owner or
operator applies to the Air Pollution Control Division on Division-supplied Administrative Permit Amendment forms, for
reissuance of the existing Operating Permit. No administrative permit shall be complete until a written agreement containing
a specific date for transfer of permit, responsibility, coverage, and liability between the permittee and the prospective owner
or operator has been submitted to the Division.
29. Volatile Organic Compounds
Regulation No. 7, 5 CCR 1001-9, §§ Ill & 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
Operating Permit Number: 97OP W E 180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company
Colorado Operating Permit Ft. St. Vrain Station
Permit # 97OPWE180 Page 82
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: 97OPWE180 First Issued: 1/1/2000
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
G - BYPASS STACK CEMS QA/QC REQUIREMENTS
H - VOC CORRELATION EQUATIONS
*DISCLAIMER:
None of the information found in these Appendices shall be considered to be State or
Federally enforceable, except as provided for in the permit, and is presented to assist the
source, permitting authority, inspectors, and citizens.
Operating Permit Number: 97OP W E 180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit
Appendices
APPENDIX A - Inspection Information
Directions to Plant:
Traveling north on Interstate 25 exit at Highway 66 (exit 243) and head east. Turn left (north) on county
road 19. Turn right (east) on County road 34 and then left (north) on county road 192. The facility
address is 16805 County Road 192.
Safety Equipment Required:
Eye Protection
Hard Hat
Safety Shoes
Hearing Protection
Facility Plot Plan:
Figure I (following page) shows the plot plan as submitted on August 12, 2010 to support the source's
Title V Renewal Operating Permit (second renewal, issued [DATE]).
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.
Units with emissions less than APEN de minimis - criteria pollutants (Reg 3, Part C.II.E.3.a)
Venting of natural gas and leaks (emissions less than 1 tpy VOC)
Cooling water blowdown cooling tower(emissions less than 2 tpy PM/PMto)
Units with emissions less than APEN de minimis - non-criteria pollutants (Reg 3, Part C.II.E.3.b)
Two (2) sulfuric acid storage tanks, 20,000 gal and 750 gal above ground (emissions less than 500
Ibs/yr)
Air conditioning or ventilation systems not designed to remove air pollutants (Reg 3, Part C.II.E.3.c)
Plant air conditioning and ventilation system
Agricultural operations (Reg 3, Part C.I1.E.3.g)
Operating Permit Number: 97OP W E180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix A
Inspection Information Page 2
In-house experimental and analytical laboratory equipment (Reg 3, Part C.II.E.3.i)
Plant laboratory
Fuel (gaseous) burning equipment < 5 mmBtu/hr (Reg 3, Part C.II.E.3.k)
Propane portable heaters
Two (2) gas line heaters (4.6 mmBtu/hr, each)
Welding, soldering, and brazing operations using no lead-based compounds (Reg 3, Part C.II.E.3.r)
Maintenance welding machine
Chemical storage tanks or containers (Reg 3, Part C.II.E.3.n)
Small chemical tanks/containers
Unpaved public and private roads - not haul roads (Reg 3, Part C.II.E.3.o)
Battery recharging areas (Reg 3, Part C.II.E.3.t)
Battery storage area
Landscaping and site housekeepingdevices < 10 hp (Reg 3, Part C.II.E.3.bb)
Mowers, snowblowers, etc..
Fugitive emissions from landscaping activities (Reg 3, Part C.II.E.3.cc)
Emergency events such as accidental fires (Reg 3, Part C.II.E.3.ff)
Operations involving acetylene_ butane, propane, or other flame cutting torches (Reg 3, Part C.II.E.3.kk)
Portable welding torches
Chemical storage areas < 5,000 gal capacity (Reg 3, Part C.II.E.3.mm)
Oil drum storage area
Emissions of air pollutants which are not criteria or non-criteria reportable pollutants (Reg 3, Part
C.II.E.3.00)
Wastewater treatment operations (no VOC emissions)
Calgon 403 (4,000 gal) above ground tank
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix A
Inspection Information Page 3
Salt tank (5,000 gal) above ground tank
Bleach tank (5,000 gal) above ground tank
Janitorial activities and products (Reg 3, Part C.II.E.3.pp)
Office emissions including cleaning, copying, and restrooms (Reg 3, Part C.II.E.3.tt)
Lubricating oil storage tanks <40,000 gal (Reg 3, Part C.II.E.3.aaa)
T-5401, Turbine lube oil dual compartment storage tank (8,000 gal per compartment, above ground)
T-5401X, Turbine lube oil reservoir (6,000 gal above ground)
55106X, Turbine generator EHC lube oil tank (650 gal above ground)
Three (3) combustion turbine lube oil tanks
Storage tanks with annual throughput less than 400,000 gal and meeting content specifications (Reg 3,
Part C.II.E.3.fff)
T-4503, Emergency diesel fire pump tank, 850 gal, above ground
Emergency diesel generator tank (System 92EDG), 550 gal above ground
Diesel fuel tank for refueling captive vehicles (warehouse), 500 gal above ground
Sandblast equipment where blast media is recycled and blasted material is collected (Reg 3, Part
C.II.E.3.www)
Sandblasting machine
Not Sources of Emissions
Aqueous ammonia (29% mixture) storage tank (14,230 gal, above ground) and associated piping (closed
system)
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
.11
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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: 97OPWE180 First Issued: 1/1/2000
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: 97OPWE180 First Issued: 1/1/2000
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: 97OPWE180 First Issued: 1/1/2000
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: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 5
Monitoring and Permit Deviation Report - Part I
1. Following is the required format for the Monitoring and Permit Deviation report to be submitted to the
Division as set forth in General Condition 21. The Table below must be completed for all equipment or
processes for which specific Operating Permit terms exist.
2. Part II of this Appendix B shows the format and information the Division will require for describing
periods of monitoring and permit deviations, or malfunction or emergency conditions as indicated in the
Table below. One Part II Form must be completed for each Deviation. Previously submitted reports
(e.g. EER's or malfunctions) may be referenced and the form need not be filled out in its entirety.
FACILITY NAME: Public Service Company—Ft. St. Vrain Station
OPERATING PERMIT NO: 97OP W E 180
REPORTING PERIOD: (see first page of the permit for specific reporting period and dates)
Deviations noted Deviation Malfunction/Emergency
During Period?' Code2 Condition Reported
During Period?
Operating
Permit Unit ID Unit Description YES NO 22., YES NO
T002 General Electric Combustion Turbine, Model
No. GE Frame 7FA, Serial No.296677,rated
at 1773 mmBtu/hr(turbine 1,223 mmBtu/hr
and duct burner 450 mmBtu/hr),Natural Gas
Fired. Turbine May be Operated in
Conjunction with a HRSG (combined cycle
operation) Equipped with Natural Gas Fired
Duct Burners.
T003 General Electric Combustion Turbine, Model
No. GE Frame 7FA, Serial No. 297096,rated
at 1823 mmBtu/hr(turbine 1,373 mmBtu/hr
and duct burner 450 mmBtu/hr),Natural Gas
Fired. Turbine May be Operated in
Conjunction with a HRSG (combined cycle
operation)Equipped with Natural Gas Fired
Duct Burners.
T004 General Electric Combustion Turbine, Model
PG7241 (FA), Serial No. 297457, rated at 1953
mmBtu/hr(turbine 1,531 mmBtu/hr and duct
burner 422 mmBtu/hr), Natural Gas Fired.
Turbine May be Operated in Conjunction with
a HRSG (combined cycle operation)Equipped
with One(I) Vogt-NEM Natural Gas Fired
Duct Burner.
Operating Permit Number: 97OPWEI80 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 6
Deviations noted Deviation Malfunction/Emergency
During Period?' Code2 Condition Reported
During Period?
Operating
Permit Unit ID Unit Description YES NO YES NO
BOW Babcock and Wilcox, Model FM-1656,
External Combustion Auxiliary Boiler, Serial
No.NB22845, Rated at 70.23 mmBtu/hr.
Natural Gas Fired.
M001 One(1) Marley Cooling Water Tower, Model
no. Cross-Flow DF-664, Design Rate of
156,000 gpm and One(I)Marley Service
Water Tower, Model NO. 6-48-3-02, Design
Rate of 14,000 gpm.
M002 Gasoline Storage Tank, 500 gallons
aboveground
M003 Cold Cleaner Solvent Vats
T005 General Electric Combustion Turbine, Model
No. 7FA, Serial Number 298106,rate at 1,467
mmBtu/hr,Natural Gas Fired.
T006 General Electric Combustion Turbine, Model
No. 7FA, Serial Number 298107, rate at 1,467
mmBtu/hr,Natural Gas Fired.
M004 Two(2)Caterpillar, Model No. SP321P00,
Serial Nos. 126906 and 126907,diesel-fired
engines, each rated at 1,800 hp,with a
combined fuel rate of 200 gal/hr. The engines
are run together to drive an emergency
generator.
One (1)Cummins, Model No. 6BTA5.963,
Serial No. 46927201,rated at 255 hp with fuel
rate of 3 gal/hr. The engine runs an emergency
fire pump.
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:
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 40 CFR Part 64 (the Compliance Assurance
Monitoring(CAM) Rule)has occurred.
Operating Permit Number: 97OP W E 180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 7
9=Other: When the deviation is not covered by any of the above categories
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 8
Monitoring and Permit Deviation Report - Part II
FACILITY NAME: Public Service Company— Ft. St. Vrain Station
OPERATING PERMIT NO: 97OPWE 180
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: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 9
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: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 10
Monitoring and Permit Deviation Report - Part III
REPORT CERTIFICATION
SOURCE NAME: Public Service Company—Ft. St. Vrain Station
FACILITY IDENTIFICATION NUMBER: 1230023
PERMIT NUMBER: 97OPWE180
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: 97OP W E 180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix C
Compliance Certification Report Page 1
APPENDIX C
Required Format for Annual Compliance Certification Reports
ver 2/20/07
Following is the format for the Compliance Certification report to be submitted to the Division and the U.S.
EPA annually based on the effective date of the permit. The Table below must be completed for all equipment
or processes for which specific Operating Permit terms exist.
FACILITY NAME: Public Service Company— Ft. St. Vrain Station
OPERATING PERMIT NO: 97OPWE180
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?'
Unit ID Permit?2
Previous Current YES NO Continuous Intermittent
T002 General Electric Combustion
Turbine, Model No. GE Frame 7FA,
Serial No. 296677,rated at 1773
mmBtu/hr(turbine 1,223 mmBtu/hr
and duct burner 450 mmBtu/hr),
Natural Gas Fired. Turbine May be
Operated in Conjunction with a
HRSG (combined cycle operation)
Equipped with Natural Gas Fired
Duct Burners.
Operating Permit Number: 97OP WE 180 First Issued: 1/1/2000
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 ' Method per or Intermittent?3
Unit ID Permit?2
Previous Current YES NO Continuous Intermittent
1003 General Electric Combustion
Turbine, Model No, GE Frame 7FA,
Serial No. 297096,rated at 1823
mmBtu/hr(turbine 1,373 mmBtu/hr
and duct burner 450 mmBtu/hr),
Natural Gas Fired. Turbine May be
Operated in Conjunction with a
HRSG (combined cycle operation)
Equipped with Natural Gas Fired
Duct Burners.
T004 General Electric Combustion
Turbine, Model PG7241 (FA), Serial
No. 297457,rated at 1953 mmBtu/hr
(turbine 1,531 mmBtu/hr and duct
burner 422 mmBtu/hr),Natural Gas
Fired. Turbine May be Operated in
Conjunction with a HRSG
(combined cycle operation)Equipped
with One(1)Vogt-NEM Natural Gas
Fired Duct Burner.
B001 Babcock and Wilcox, Model FM-
1656, External Combustion
Auxiliary Boiler, Serial No.
NB22845, Rated at 70.23 mmBtu/hr.
Natural Gas Fired.
M001 One(I)Marley Cooling Water
Tower, Model no. Cross-Flow DF-
664, Design Rate of 156,000 gpm
and One(I)Marley Service Water
Tower,Model NO. 6-48-3-02,
Design Rate of 14,000 gpm.
M002 Gasoline Storage Tank, 500 gallons
aboveground
M003 Cold Cleaner Solvent Vats
T005 General Electric Combustion
Turbine, Model No. 7FA, Serial
Number 298106,rate at 1,467
mmBtu/hr,Natural Gas Fired.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
•
Air Pollution Control Division
Colorado Operating Permit Appendix C
Compliance Certification Report Page 3
Operating Unit Description Deviations Monitoring Was Compliance Continuous
Permit Reported Method per or Intermittent?3
Unit ID Permit?'
Previous Current YES NO Continuous Intermittent
T006 General Electric Combustion
Turbine,Model No.7FA, Serial
Number 298107,rate at 1,467
mmBtu/hr,Natural Gas Fired.
M004 Two(2)Caterpillar, Model No.
SP321P00, Serial Nos. 126906 and
126907,diesel-fired engines, each
rated at 1,800 hp,with a combined
fuel rate of 200 gal/hr. The engines
are run together to drive an
emergency generator.
One(1)Cummins,Model No.
6BTA5.963, Serial No. 46927201,
rated at 255 hp with fuel rate of 3
gal/hr. The engine runs an
emergency fire pump.
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 1) conducts all of the monitoring and recordkeeping required in its
permit, even if such activities are done periodically and not continuously, and if 2) such monitoring and recordkeeping does not
indicate non-compliance, and if 3) the Responsible Official is not aware of any credible evidence that indicates non-compliance, then
the Responsible Official can certify that the emission point(s) in question were in continuous compliance during the applicable time
period.
°Compliance status for these sources shall be based on a reasonable inquiry using readily available information.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix C
Compliance Certification Report Page 4
II. Status for Accidental Release Prevention Program:
A. This facility is subject is not subject to the provisions of the Accidental
Release Prevention Program (Section 112(r) of the Federal Clean Air Act)
B. If subject: The facility is is not in compliance with all the
requirements of section 112(r).
1. A Risk Management Plan will be has been submitted to the
appropriate authority and/or the designated central location by the required date.
III. Certification
All information for the Annual Compliance Certification must be certified by a responsible official as defined in
Colorado Regulation No. 3, Part A, Section I.B.38. This signed certification document must be packaged with
the documents being submitted.
I have reviewed this certification in its entirety and, based on information and belief formed after
reasonable inquiry, I certify that the statements and information contained in this certification are true,
accurate and complete.
Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1-501(6),
C.R.S., makes any false material statement, representation, or certification in this document is guilty of a
misdemeanor and may be punished in accordance with the provisions of§ 25-7 122.1, C.R.S.
Printed or Typed Name Title
Signature Date Signed
NOTE: All compliance certifications shall be submitted to the Air Pollution Control Division and to the
Environmental Protection Agency at the addresses listed in Appendix D of this Permit.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
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-B1
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: 97OPWE180 First Issued: 1/1/2000
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: 97OPWE180 First Issued: 1/1/2000
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: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix F
Permit Modifications Page 1
APPENDIX F
Permit Modifications
DATE OF TYPE OF SECTION DESCRIPTION OF REVISION
REVISION REVISION NUMBER,
CONDITION
NUMBER
Operating Permit Number: 97OPWEI80 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix G
Bypass Stack CEMS QA/QC Requirements Page 1
APPENDIX G
Bypass Stack CEMS QA/QC Requirements
The required QA/QC demonstration for the bypass stack has been revised since under the provisions of 40 CFR
Part 75 § 75.17(d), any unit that has a main stack and a bypass stack need only install, operate and maintain a
NOx and diluent CEMS on the main stack. However, since the bypass stack is subject to a BACT concentration
limit, the permittee must maintain a CEMS on the bypass stack to monitor compliance with the BACT emission
limit. Since the bypass stack is used so infrequently and since 40 CFR Part 75 does not require a CEMS on the
bypass stack, the permittee has proposed and the Division has approved less rigorous QA/QC requirements for
the bypass stack CO, NOx and diluent CEMS systems.
The analyzers used to measure NOx and CO emission are common to both the bypass and HRSG (main) stacks.
Each unit has a single NOx and CO analyzer that pulls a sample from either the bypass or HRSG stack,
dependent upon which is in operation. In actuality, the analyzer itself will continue to be validated according to
the requirements of 40 CFR Part 75. The only thing unique to the two stacks (main and bypass) is the sample
line and stack probe.
The following QA tests shall be performed for the bypass stack:
• A calibration error test will be performed on the bypass stack within 24-hours of simple cycle operation.
The demonstration can be performed either while the unit is online or offline.
• An additional calibration error test will be performed on the bypass stack immediately following repair
or corrective maintenance that could affect the monitor's ability to accurately measure and record
emissions. The demonstration can be performed either while the unit is online or offline.
• A calibration gas analysis (CGA or Linearity) will be performed on the bypass stack the earlier of 1,000
stack operating hours or 3 calendar years. The demonstration will be performed while the unit is online
and will be completed in the operating quarter subsequent to the quarter in which the unit triggers the
need to test.
• A relative accuracy test audit (RATA) will be performed on the bypass stack the earlier of 1,000 stack
operating hours or 3 calendar years. The demonstration will be performed while the unit is online and
will be completed in the operating quarter subsequent to the quarter in which the unit triggers the need to
test.
Operating Permit Number: 97OPWE180 180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix H
VOC Correlation Equations Page 1
APPENDIX H
VOC Correlation Equations
Turbine 2
For all Turbine 2 Equations:
y= VOC (lb/hr or ppm)
x=Heat Input(mmBtu, CT: simple cycle, Duct Burners :combined cycle)
Simple Cycle, ppm
Richards Model: y=a/(1+exp(b-cx)^(1/d))
Coefficient Data:
a = 0.73510718
b = 10.847591
c = 0.021720968
d = 0.00049594823
Simple Cycle, lbs/hr
MMF Model: y=(a*b+c*x^d)/(b+x^d)
Coefficient Data:
a = -19262.18
b= 1103.9061
c = 6.7824045
d = 2.2625074
Combined Cycle, ppm
Harris Model: y=1/(a+bx^c)
Coefficient Data:
a = -4.3185514
b = 4.7661959
c = 0.024745224
Combined Cycle, lbs/br
Harris Model: y=1/(a+bx^c)
Coefficient Data:
a = 0.51214517
b = -3.0173965e-005
c = 1.2477207
Operating Permit Number: 97OP WE 180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix H
VOC Correlation Equations Page 2
Turbine 3
For all Turbine 3 equations:
y= VOC (lb/hr or ppm)
x=Heat Input(mmBtu, CT: simple cycle, Duct Burners :combined cycle)
Simple Cycle, ppm
Richards Model: y=a/(1+exp(b-cx)^(1/d))
Coefficient Data:
a= 0.59193186
b = 3.0423976
c = -0.0062019763
d = 25.571185
Simple Cycle, lbs/hr
MMF Model: y=(a*b+c*x^d)/(b+x^d)
Coefficient Data:
a = -422.11339
b = 147.68633
c = 2.7062421
d = 1.6733667
Combined Cycle, ppm
Richards Model: y=a/(1+exp(b-cx)^(1/d))
Coefficient Data:
a = 11.343527
b = 10.181344
c = -0.019786659
d = 4.7085579
Combined Cycle, lbs/hr
Richards Model: y=a/(1+exp(b-cx)^(1/d))
Coefficient Data:
a= 116.59523
b = 10.784553
c = -0.01652158
d = 4.3548636
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix H
VOC Correlation Equations Page 3
Turbine 4
For all Turbine 4 equations
y= VOC (lb/hr or ppm)
x= Heat Input (mmBtu, CT: simple cycle, Duct Burners :combined cycle)
Simple Cycle, lbs/hr
y = ax^2-bx+c
Coefficient Data:
a= 8 x 10-6
b = 0.0156
c = 9.5178
Combined Cycle, lbs/hr
y = ax^2-bx+c
Coefficient Data:
a = 5 x 10-5
b = 0.0235
c = 5.0518
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
STATE OF COLORADO
Bill Ritter,Jr.,Governor
Martha E. Rudolph,Executive Director <ci c6o
Ra
Dedicated to protecting and improving the health and environment of the people of Colorado tev e
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 Colorado Department
Located in Glendale,Colorado
of Public Health
http://www.cdphe.state.co.us and Environment
September 22, 2010
Mr. Chad Campbell
Environmental Services
Xcel Energy
1800 Larimer Street
Suite 1300
Denver, CO 80202
REF: Public Service Company—Ft. St. Vrain Station, FID # 1230023, OP # 97OPWE180
SUBJECT: Response to Comments on Draft Operating Permit
Dear Mr. Campbell:
The comments you provided on the draft renewal Operating Permit (97OPWE180) and Technical
Review Document for your facility were received on September 16, 2010. The Division has reviewed
and addressed your comments as follows:
Draft Operating Permit Cover Letter Document:
Comment: In the cover letter the Division asked PSCo to indicate whether there are any engines that
would meet the requirements of 40 CFR Part 63 Subpart ZZZZ, 40 CFR Part 60 Subpart
1111, or 40 CFR Part 60 Subpart JJJJ. After a review of the stationary engines located at
Fort St. Vrain Station there are no new engines located at the facility that have not been
already accounted for in this permitting process.
Response: Thank you for providing this information. No changes to the permit or technical review
document are necessary.
Comment: Affected existing engines at this facility include two (2) 1,800 horsepower Caterpillar
engines that are used to power an emergency generator, and one (1) 255 horsepower
Cummins engine used to power an emergency fire pump. All three engines have been
identified in the permit renewal and will be covered under Condition No. 9. There are
mentions of a Security Diesel Generator in the permit and technical review document
however that piece of equipment has been removed from service. The only engines in
operation at this facility are the three engines discussed above.
Mr. Chad Campbell September 22, 2010
Response to Comments on Draft Permit Page 2
Response: While the technical review document and draft permit does not specifically mention the
security generator, both the draft permit and technical review document identify two
generators and three diesel fired engines driving generators (the generator driven by two
engines and the security generator). Since the security generator has been removed from
service, the Division will revise the permit to reflect only one emergency generator and
two diesel-fire engines driving that generator. The Division had also removed the
security generator from the insignificant activity list in Appendix A and as a result no
changes to the insignificant activity list are necessary.
Item 2: In addition, the Division requested that PSCo provide the make, model, serial number
and hourly fuel or heat input rate for the affected engines.
1,800 hp Caterpillar Engine: Model SP321P00, Serial Number 126906 and Fuel
Rate *200 gal/hr.
1,800 hp Caterpillar Engine: Model SP321P00, Serial Number 126907 and Fuel
Rate *200 gal/hr.
*The two engines must run together and cannot operate independently of each other.
They share a common fuel line and burn a total of 200 gal/hr.
255 hp Cummins Engine: Model 6BTAS.963, Serial Number 46927201 and Fuel
Rate 3 gal/hr.
Response Thank you for providing this information. The information provided for these engines
will be included in the permit and technical review document.
Technical Review Document
Comment: (page 2). The description contained in the Technical Review Document on the output
ratings of the various units should be revised to show that Units 2, 3 and 4 all have an
average maximum output of 135 MW. The text as currently written singles Unit 4 out as
being a different rating than Units 2 and 3, which is not accurate.
Response: The change will be made as requested.
Section I—General Activities and Summary
Comment: Condition 6, Page 4. The descriptions of Emissions Unit M004 should be corrected to
reflect that there are only two (2) diesel fired engines that drive an emergency generator
and one (1) diesel fired engine drives an emergency fire pump. This may impact
descriptions of these sources in other areas of the permit and technical review document
as well.
Response: The changes will be made as requested.
Section II-Specific Permit Terms
Comment: Conditions 1.2.19, 1.3.1.9, 2.5.1.9 and 2.6.1.9 (Pages 10, 11, 26 & 28).: The Division
revised the compliance determination method for the NOx and CO BACT limits for
Turbines 2, 3 and 4 in the draft permit. The Division revised the permit to allow only
Mr. Chad Campbell September 22, 2010
Response to Comments on Draft Permit Page 3
startup and/or shutdown time to be averaged together and compared to the startup
and/or shutdown NOx and CO BACT limits. In addition, the Division has revised the
averaging period for showing compliance with the BACT limit from a 1-hour
concentration and mass limit to solely a concentration limit with an averaging period of
the duration of the event or 3-hours whichever is shorter. While PSCo can see the benefit
of changing the averaging time to be the duration of the event or 3-hours whichever is
shorter, it believes that an associated mass standard is critical to the CO compliance
demonstration. The Division states as its basis for removing the mass portion from the
CO standard as being "because the startup and shutdown BACT limit averaging time
may be based on the duration of the event, an lbs/hr limit is no longer appropriate". The
duration of the event has no impact on the fact that when concentration levels of CO are
elevated and the unit is operating at low levels such as is the case during startup and
shutdown conditions, the CO emissions can be in excess of the concentration limit but the
actual amount of mass emissions being emitted can be well below the threshold standard
that was used in the BACT determination for these units. In order to remain consistent
with the modeling and BACT determination that has been set for these units, the Division
must keep an associated mass limit in place for CO emissions during startup and
shutdown conditions. PSCo proposes that that the lb/hr standard remains as an hourly
standard and remains set at 2,060 lb/hr. A lb/hr average will be calculated for each
clock hour in which a startup or shutdown activity occurs. The mass hourly averages
will be calculated using Part 75 validation criteria and the average will be based on all
minutes in which a startup or shutdown activity occurs during a clock hour. In order for
there to be an exceedance of the CO startup/shutdown standard both the concentration
and mass emissions limits will have to be exceeded. For each concentration average
based on the duration of the startup or shutdown event or 3-hours whichever is shorter,
there will be an associated mass average for each clock hour in which the events
occurred in.
In addition to preserving the mass portion of the limit for periods of startup and
shutdown, it also needs to remain part of the CO BACT limit for periods of combustion
tuning and testing.
Response: The Division considered that with the increased averaging time for the concentration
(ppmvd) based CO startup and shutdown BACT limits that spikes in emissions would be
reduced and that the mass based (lb/hr) CO startup and shutdown BACT limits would not
be necessary. However, since PSCo considers that the mass-based startup and shutdown
BACT limits are still necessary, the Division has reconsidered revising the averaging
period for the startup and shutdown BACT limits. The permit has been revised to retain
the hourly averaging period for the startup and shutdown BACT limits. In addition, the
mass-based CO startup and shutdown BACT limit has been restored.
The Division removed the CO mass-based (lb/hr) combustion tuning and testing BACT
limits in order to be consistent with the startup and shutdown CO BACT limits. Since the
Division has restored the CO mass-based startup and shutdown BACT limits, the
Division has also restored the CO mass-based combustion tuning and testing limits.
Comment: Condition 1.6.4.1 (Page 15). Condition 1.6.4.1 requires that monthly emissions of PM be
calculated using the emission factors identified in the table contained within that section.
Mr. Chad Campbell September 22, 2010
Response to Comments on Draft Permit Page 4
The table should be updated to reflect the results of the most recent particulate matter
emissions testing. As required by Condition 1.12 of the facility's Title V permit (Renewal
date July 1, 2005), performance testing was conducted on Units 2 and 3 within 18 months
of expiration of the permit. Testing was conducted on Unit 2 while operating in Simple
Cycle mode on April 28, 2010. The results of the testing yielded a particulate matter
emission rate of 0.00421 lb/mmbtu. Testing was conducted on Unit 2 while operating in
Combined Cycle mode on November 17 and 18, 2009. The results of the testing yielded a
particulate matter emission rate of 0.004 lb/mmbtu. Testing was conducted on Unit 3
while operating in Simple Cycle mode on October 28 and 29, 2010[sic]. The results of
the testing yielded a particulate matter emission rate of 0.003 lb/mmbtu. Testing was
conducted on Unit 3 while operating in Combined Cycle mode on June 9, 2010. The
results of the testing yielded a particulate matter emission rate of 0.004 lb/mmbtu.
Response: The Division will revise the emission factors included in Condition 1.6.4.1 to reflect the
emission factors determined from recent performance tests.
Comment: Condition 1.16 (page 18). Condition 1.16 details the opacity requirements that apply to
each duct burner. Details are given on the applicable opacity standards but the
discussion goes into little detail on how compliance is to be demonstrated other than
referencing 40 CFR Part 60 Section 60.49 Da(a)(3). PSCo is requesting that the
discussion on monitoring requirements be expanded to list the details of what the exact
monitoring requirements will be for the affected sources.
Response: The Division has revised Condition 1.16 to include the specific opacity monitoring
requirements in 40 CFR part 60 Subpart Da § 60.49Da(a)(3).
Comment: Condition 1.2.1.5 (Page9). Condition 1.2.1.5 defines "Startup"for Units 2, 3 and 4.
PSCo is requesting that this definition be revised in order to make it in line with the
definition of startup that is given in Condition 8.2.1.4 for Units 5 and 6. On September
30, 2009 a modification request was submitted to the Division requesting that the
definition of startup in Construction Permit No. 07WE1100 for Units 5 and 6 be revised
to account for a settling time that is inherent to the Continuous Emissions Monitoring
Systems (GEMS). The previous definition of"startup" did not account for a CEMS
settling time and therefore allowed periods of the startup process to be included in the
averaging period for non-startup operations. The Division approved the request and
issued a revised construction permit on January 28, 2010. PSCo is requesting that the
same definition be applied to Units 2, 3 and 4 based on the same justification that was
submitted for Units 5 and 6. Doing so would also allow there to be one definition
contained in Condition 1.2.1.5 for all.five ve of the units rather than having a separate
definition in Condition 8.2.1.4.
In addition, PSCo is requesting that the definition be revised to reflect that the startup
event begins when fuel is being combusted in the turbine rather than when fuel is being
injected into the turbine as it is currently described. And to add language that clarifies
how the mode of operation and the 15 minutes of affected data are being documented and
stored.
Mr. Chad Campbell September 22, 2010
Response to Comments on Draft Permit Page 5
"Startup" means the setting in operation of any air pollution source for any purpose.
Setting in operation for these turbines begins when fuel is being combusted in the turbine
and ends 15 minutes after the turbine reaches Mode 6 operation. Mode 6 refers to the
condition when all six burner nozzles are being fired. The station control system and
each unit's Data Acquisition and Handling Systems (DAHS) utilized by the continuous
emissions monitors indicates which Mode the turbine is operating in. A record of when
Mode 6 combustion configuration plus 15 minutes is achieved is stored in each unit's
DAHS.
Response: The Division has revised the definition of"startup" in Condition 1.2.1.6. Except for
minor changes, the startup definition is as requested. In addition, the Division revised
Condition 8.2.1.4 to indicate that the definition of"startup"is in condition 1.2.1.5.
Comment: Condition 8.2.1.5 (Page 48). Condition 8.2.1.5 defines "Shutdown"for Units 5 and 6.
PSCo is requesting that this definition be revised in order to make it in line with the
definition of shutdown that is given in Condition 1.2.1.6 for Units 2, 3 and 4. The
difference in the definitions is that Condition 1.2.1.6 states that the "Shutdown" begins
when the command signal is initiated to shutdown the unit and Condition 8.2.1.5 states
that the "Shutdown" begins when the command signal is initiated by the turbine operator
to shutdown the unit. Doing so would also allow there to be one definition contained in
Condition 1.2.1.6 for all five of the units rather than having a separate definition in
Condition 8.2.1.5.
Response: The Division revised Condition 8.2.1.5 to indicate that the definition of shutdown is in
Condition 1.2.1.6. Note that the Division made a similar change to the definition of
"combustion tuning and testing" in Condition 8.2.1.6 (refers to the definition in
Condition 1.2.1.7),
Comment: Condition 1.2.1.3, 2.5, 2.6, and 8.2 (Pages 5, 6, 20, 21 and 46). Each of these conditions
contains a provision for emission limits during periods of"combustion tuning and
testing". The use of this provision is limited to 90 hours per year for Units 2, 3 and 4
combined and to 60 hours per year for Units 5 and 6 combined On a per unit basis that
works out to be a total of 30 hours per year. PSCo is requesting that the limit on the
number of hours in which this provision can be applied be based on an allocation of 50
hours per year per unit. Units 2, 3 and 4 would be limited to a combined total of 150
hours per year and Units 5 and 6 would be limited to a combined total of 100 hours per
year. This would better support the ongoing maintenance and upkeep required on these
turbines and brings the Fort St. Vrain permit more in line with how this provision is
written in other Title V permits with combustion turbines of similar make and model.
Response: While there are some Title V permits that allow for 50 hours per year per turbine for
combustion tuning and testing, there are also a number of Title V permits that allow for
30 hours per year per turbine for combustion tuning and testing. The Division's intent in
including alternative limits is to provide sufficient time to conduct any required turbine
tuning and testing in order to keep the turbines running probably. It is not clear whether
PSCo is running close to the time limitations set for combustion tuning and testing and
thus is in need of additional time. Therefore, no changes have been made based on this
comment. Please be aware that the Division is willing to consider requests to increase the
Mr. Chad Campbell September 22, 2010
Response to Comments on Draft Permit Page 6
number of hours allowed for combustion tuning and testing provided that such a request
is accompanied by documentation supporting the need for an increase.
Comment: Condition 4.1 (Page 3). Condition 4.1 needs to be revised to show that this facility no
longer maintains a stock of chlorine gas. The facility has replaced the use of chlorine
gas with bleach. The facility does still store aqueous ammonia at levels that exceed
threshold levels and is still therefore subject to the requirements of the Accidental
Release Prevention Program.
Response: Based on this comment and the additional information provided in a September 16, 2010
e-mail, the Division has revised Section I, Condition 4.1 to indicate that the facility is not
subject to the Accidental Release Prevention Program.
Comment: Condition 8.2.1 (Page 49). The last paragraph in Condition 8.2.1 states "The emission
limits in Condition 8.2.1.2 apply to any clock hour in which combustion tuning and
testing and/or fuel switching activities occur. " These sources only have the capability to
combust natural gas. The reference to fuel switching can be removed
Response: The change will be made as requested.
Appendix A—Inspection Information
Comment: List of Insignificant Activities. Under the category for "Storage tanks with annual
throughput less than 400,000 gal and meeting content specifications", the "T-7802,
Security day tank, diesel, 500 gal above ground" and "T-8403, Diesel fuel tank for EDG,
20,000 gal underground" have both been removed from service.
Response: The Division has removed the two tanks from the insignificant activity list.
The next step for this draft renewal permit will be to put it out for a 30-day Public Comment period.
After that, the proposed permit will go to EPA Region VIII for a 45-day review period. The regulations
also require that the applicant receive written notice of their right to a formal hearing before the Air
Quality Control Commission at the same time that the Public Comment packet goes out. You will
receive a separate letter containing that information.
We appreciate that you took the time to thoroughly review this draft. Please feel free to call me at (303)
692-3267 if you have any further questions.
Sincerely, o�
Jacqueline Joyce
Operating Permit Unit
Stationary Sources Program
Air Pollution Control Division
(9/1 rr[ul U) Jackie Joyce - RE: FSV Draft Comments Page 1
From: "Campbell, Chad E" <Chad.Campbell@XCELENERGY.COM>
To: "'Jackie Joyce"' <JEJOYCE@cdphe.state.co.us>
Date: 9/16/2010 2:09 PM
Subject: RE: FSV Draft Comments
Attachments: FSV draft permit comments (09-10).doc
Sure here is the electronic copy.
As a result of the requirements that a source has to meet when they have quantities above TQ levels we
evaluated FSV's situation and found that what they were store was in excess of what they actually needed
to run those controls. The kept a large surplus of ammonia because they could. It turns out that by
keeping just the amount of ammonia that is needed that we are below the TQ. So it was an easy decision.
Chad Campbell
Xcel Energy j Responsible By Nature
Environmental Services
1800 Larimer Street, Denver, CO 80202, Suite 1300
P: 303.294.2111 F: 303.294.2859
E: chad.campbell@xcelenergy.com
XCELENERGY.COM
Please consider the environment before printing this email
Original Message
From: Jackie Joyce [mailto:JEJOYCE@cdphe.state.co.us]
Sent: Thursday, September 16, 2010 1:58 PM
To: Campbell, Chad E
Subject: Re: FSV Draft Comments
I did get your comments -do you have an electronic version that you could send to me (its easier in my
comment response)?
I will consider this new information for Section I, Condition 4.1. Just curious, is turbine 4 running less-
hence less aqueous ammonia needed for SCR?
>>> "Campbell, Chad E" <Chad.Campbell@XCELENERGY.COM> 9/16/2010 1:55 PM >>>
Jackie,
I submitted comments to you on the draft FSV permit today. There is an item on there that I need to
expand on because I received some more info after sending out the comments. On page 4 of the letter I
talk about Permit Condition 4.1 and the fact that the facility no longer stores chlorine but still stores
aqueous ammonia and therefore is still subject to ARPP. I have since learned that the amount of
ammonium hydroxide solution inventoried at FSV is below the RMP threshold quantity. As such, FSV is
- - - - __ -(9/17/2010) Jackie Joyce - RE:
FSV Draft Comments Page 2 ,
now exempt from RMP requirements. Condition 4.1 needs to be revised to account for this.
Thanks,
Chad
Chad Campbell
Xcel Energy I Responsible By Nature
Environmental Services
1800 Larimer Street, Denver, CO 80202, Suite 1300
P: 303.294.2111 F: 303.294.2859
E: chad.campbell@xcelenergy.com<mailto:chad.campbell@xcelenergy.com>
<blocked::blocked::http://www.xcelenergy.com/>XCELENERGY.COM<http://www.xcelenergy.com/>
Please consider the environment before printing this email
ECEIVE
APCD
XcelEnergy-
Environmental Services Department
1800 Larimer Street,Suite 1300
Denver,CO 80202
September 16,2010
Ms. Jacqueline Joyce
Colorado Department of Public Health&Environment
Air Pollution Control Division,APCD-SS-B1
Operating Permit Unit
4300 Cherry Creek Drive South
Denver,CO 80246-1530
Re: Fort St. Vrain Station
Permit#97OP WE 180
Draft Operating Permit Comments
Dear Ms.Joyce:
Public Service Company of Colorado(PSCo)has reviewed the initial draft renewal operating permit,
#97OPWE180, for Fort St. Vrain Station located in Weld County,Colorado. The draft permit was issued
for our review and comment on August 5,2010. The following are PSCo's comments on the draft permit.
Draft Operating Permit Cover Letter Document
In the cover letter the Division asked PSCo to indicate whether there are any engines that would meet the
requirements of 40 CFR Part 63 Subpart ZZZZ,40 CFR Part 60 Subpart IIII,or 40 CFR Part 60 Subpart
JJJJ. After a review of the stationary engines located at Fort St. Vrain Station there are no new engines
located at the facility that have not been already accounted for in this permitting process. Affected existing
engines at this facility include two(2) 1,800 horsepower Caterpillar engines that are used to power an
emergency generator, and one(1)255 horsepower Cummins engine used to power an emergency fife pump.
All three engines have been identified in the permit renewal and will be covered under Condition No.9.
There are mentions of a Security Diesel Generator in the permit and technical review document however
that piece of equipment has been removed from service. The only engines in operation at this facility are
the three engines discussed above.
In addition,the Division requested that PSCo provide the make,model,serial number and hourly fuel or
heat input rate for the affected engines.
1,800 hp Caterpillar Engine: Model SP321P00, Serial Number 126906 and Fuel Rate*200 ga/hr.
1,800 hp Caterpillar Engine: Model SP321P00,Serial Number 126907 and Fuel Rate *200 gal/hr.
*The two engines must run together and cannot operate independently of each other. They share
a common fuel line and burn a total of200 gal/hr.
255 hp Cummins Engine: Model 6BTA5.963, Serial Number 46927201 and Fuel Rate 3 gal/hr.
Technical Review Document
(Page 2)
The description contained in the Technical Review Document on the output ratings of the various units
should be revised to show that Units 2,3 and 4 all have an average maximum output of 135 MW. The text
as currently written singles Unit 4 out as being a different rating than Units 2 and 3,which is not accurate.
Section I—General Activities and Summary
Condition 6 (Page 4)
The descriptions of Emissions Unit M004 should be corrected to reflect that there are only two(2)diesel
fired engines that drive an emergency generator and one(1)diesel fired engine drives an emergency fire
pump. This may impact descriptions of these sources in other areas of the permit and technical review
document as well.
Section 11—Specific Permit Terms
Conditions 1.2.1.9, 1.3.1.9,2.5.1.9&2.6.1.9 (Pages 10, 11,26&28)
The Division revised the compliance determination method for the NOx and CO BACT limits for Turbines
2, 3 and 4 in the draft permit. The Division revised the permit to allow only startup and/or shutdown time
to be averaged together and compared to the startup and/or shutdown NOx and CO BACT limits. In
addition,the Division has revised the averaging period for showing compliance with the BACT limit from a
1-hour concentration and mass limit to solely a concentration limit with an averaging period of the duration
of the event or 3-hours whichever is shorter. While PSCo can see the benefit of changing the averaging
time to be the duration of the event or 3-hours whichever is shorter, it believes that an associated mass
standard is critical to the CO compliance demonstration. The Division states as its basis for removing the
mass portion from the CO standard as being"because the startup and shutdown BACT limit averaging time
may be based on the duration of the event,an lbs/hr limit is no longer appropriate". The duration of the
event has no impact on the fact that when concentration levels of CO are elevated and the unit is operating
at low levels such as is the case during startup and shutdown conditions,the CO emissions can be in excess
of the concentration limit but the actual amount of mass emissions being emitted can be well below the
threshold standard that was used in the BACT determination for these units. In order to remain consistent
with the modeling and BACT determination that has been set for these units,the Division must keep an
associated mass limit in place for CO emissions during startup and shutdown conditions. PSCo proposes
that that the lb/hr standard remains as an hourly standard and remains set at 2,060 lb/hr. A lb/hr average
will be calculated for each clock hour in which a startup or shutdown activity occurs. The mass hourly
averages will be calculated using Part 75 validation criteria and the average will be based on all minutes in
which a startup or shutdown activity occurs during a clock hour. In order for there to be an exceedance of
the CO startup/shutdown standard both the concentration and mass emissions limits will have to be
exceeded. For each concentration average based on the duration of the startup or shutdown event or 3-
hours whichever is shorter,there will be an associated mass average for each clock hour in which the events
occurred in.
In addition to preserving the mass portion of the limit for periods of startup and shutdown, it also needs to
remain part of the CO BACT limit for periods of combustion tuning and testing.
Condition 1.6.4.1 (Page 15)
Condition 1.6.4.1 requires that monthly emissions of PM be calculated using the emission factors identified
in the table contained within that section. The table should be updated to reflect the results of the most
recent particulate matter emissions testing. As required by Condition 1.12 of the facility's Title V permit
(Renewal date July 1,2005),performance testing was conducted on Units 2 and 3 within 18 months of
expiration of the permit. Testing was conducted on Unit 2 while operating in Simple Cycle mode on April
28,2010. The results of the testing yielded a particulate matter emission rate of 0.00421 lb/mmbtu.
Testing was conducted on Unit 2 while operating in Combined Cycle mode on November 17 and 18,2009.
The results of the testing yielded a particulate matter emission rate of 0.004 lb/mmbtu. Testing was
conducted on Unit 3 while operating in Simple Cycle mode on October 28 and 29,2010. The results of the
testing yielded a particulate matter emission rate of 0.003 lb/mmbtu. Testing was conducted on Unit 3
while operating in Combined Cycle mode on June 9, 2010. The results of the testing yielded a particulate
matter emission rate of 0.004 lb/mmbtu.
Condition 1.16(Page 18)
Condition 1.16 details the opacity requirements that apply to each duct burner. Details are given on the
applicable opacity standards but the discussion goes into little detail on how compliance is to be
demonstrated other than referencing 40 CFR Part 60 Section 60.49 Da(a)(3). PSCo is requesting that the
discussion on monitoring requirements be expanded to list the details of what the exact monitoring
requirements will be for the affected sources.
Condition 1.2.1.5 (Page 9)
Condition 1.2.1.5 defines"Startup"for Units 2,3 and 4. PSCo is requesting that this definition be revised
in order to make it in line with the definition of startup that is given in Condition 8.2.1.4 for Units 5 and 6.
On September 30,2009 a modification request was submitted to the Division requesting that the definition
of startup in Construction Permit No. 07WE1100 for Units 5 and 6 be revised to account for a settling time
that is inherent to the Continuous Emissions Monitoring Systems(CEMS). The previous definition of
"startup"did not account for a CEMS sealing time and therefore allowed periods of the startup process to
be included in the averaging period for non-startup operations. The Division approved the request and
issued a revised construction permit on January 28,2010. PSCo is requesting that the same definition be
applied to Units 2,3 and 4 based on the same justification that was submitted for Units 5 and 6. Doing so
would also allow there to be one definition contained in Condition 1.2.1.5 for all five of the units rather than
having a separate definition in Condition 8.2.1.4.
In addition,PSCo is requesting that the definition be revised to reflect that the startup event begins when
fuel is being combusted in the turbine rather than when fuel is being injected into the turbine as it is
currently described. And to add language that clarifies how the mode of operation and the 15 minutes of
affected data are being documented and stored.
"Startup"means the setting in operation of any air pollution source for any purpose. Setting in operation
for these turbines begins when fuel is being combusted in the turbine and ends 15 minutes after the turbine
reaches Mode 6 operation. Mode 6 refers to the condition when all six burner nozzles are being fired The
station control system and each unit's Data Acquisition and Handling Systems (DAHS) utilized by the
continuous emissions monitors indicates which Mode the turbine is operating in. A record of when Mode 6
combustion configuration plus 15 minutes is achieved is stored in each unit's DAHS.
Condition 8.2.1.5 (Page 48)
Condition 8.2.1.5 defines"Shutdown"for Units 5 and 6. PSCo is requesting that this definition be revised
in order to make it in line with the definition of shutdown that is given in Condition 1.2.1.6 for Units 2,3
and 4. The difference in the definitions is that Condition 1.2.1.6 states that the"Shutdown"begins when the
command signal is initiated to shutdown the unit and Condition 8.2.1.5 states that the"Shutdown"begins
when the command signal is initiated by the turbine operator to shutdown the unit. Doing so would also
allow there to be one definition contained in Condition 1.2.1.6 for all five of the units rather than having a
separate definition in Condition 8.2.1.5.
Conditions 1.2, 1.3,2.5,2.6,and 8.2(Paees 5,6,20,21 and 46)
Each of these conditions contains a provision for emission limits during periods of"combustion tuning and
testing". The use of this provision is limited to 90 hours per year for Units 2,3 and 4 combined and to 60
hours per year for Units 5 and 6 combined. On a per unit basis that works out to be a total of 30 hours per
year. PSCo is requesting that the limit on the number of hours in which this provision can be applied be
based on an allocation of 50 hours per year per unit. Units 2,3 and 4 would be limited to a combined total
of 150 hours per year and Units 5 and 6 would be limited to a combined total of 100 hours per year. This
would better support the ongoing maintenance and upkeep required on these turbines and brings the Fort St.
Vrain permit more in line with how this provision is written in other Title V permits with combustion
turbines of similar make and model.
Condition 4.1 (Page 3)
Condition 4.1 needs to be revised to show that this facility no longer maintains a stock of chlorine gas. The
facility has replaced the use of chlorine gas with bleach. The facility does still store aqueous ammonia at
levels that exceed threshold levels and is still therefore subject to the requirements of the Accidental
Release Prevention Program.
Condition 8.2.1 (Page 49)
The last paragraph in Condition 8.2.1 states"The emission limits in Condition 8.2.1.2 apply to any clock
hour in which combustion tuning and testing and/or fuel switching activities occur." These sources only
have the capability to combust natural gas. The reference to fuel switching can be removed.
Appendix A—Inspection Information
List of Insignificant Activities
Under the category for"Storage tanks with annual throughput less than 400,000 gal and meeting content
specifications",the"T-7802, Security day tank, diesel,500 gal above ground"and"T-8403,Diesel fuel
tank for EDG, 20,000 gal underground"have both been removed from service.
PSCo appreciates this opportunity to review the draft modified operating permit for Fort St. Vrain Station
prior to the permit being published for public comment. Please contact me at 303-294-2111 if you have any
questions concerning the information provide above.
Sincerely,
Chad Campbell
Environmental Services
Xcel Energy
cc:
Joe Pinner,FSV Station
ES File
STATE OF COLORADO
Bill Ritter,Jr.,Governor
Martha E. Rudolph, Executive Director cc, , qp
Dedicated to protecting and improving the health and environment of the people of Colorado /Nc -o
4300 Cherry Creek Dr-S. Laboratory Services Division * j,
Denver,Colorado 80246-1530 8100 Lowry Blvd. reps
Phone(303)692-2000 Denver,Colorado 80230-6928
TDD Line(303)691-7700 (303)692-3090 Colorado Department
Located in Glendale,Colorado P
of Public Health
http://www.cdphe.state.co.us and Environment
August 5, 2010
Mr. Chad Campbell
Environmental Services
Xcel Energy
1800 Larimer Street
Suite 1300
Denver, CO 80202
SUBJECT: Draft Renewal Operating Permit for Public Service Company — Ft. St. Vrain Station
Dear Mr. Campbell:
Enclosed please find a draft of the renewal operating permit for your facility as well as a copy of the
technical review summary document. Please review and submit any comments you may have
concerning the modified draft operating permit. Following our review of your comments, we will send
the draft permit out for a 30-day Public Comment period and then to EPA for their 45-day review period.
The regulations also require that the applicant receive written notice of their right to a formal hearing
before the Colorado Air Quality Control Commission at the same time that the Public Comment packet
goes out. You will receive a separate letter containing that information.
This draft renewal permit contains the modifications that you requested in your renewal application
received on May 19, 2009. 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. The Division has revised the compliance determination method for the NOx and CO BACT limits
for Turbines 2, 3 and 4 (Section II, Conditions 1.2.1, 1.3.1, 2.5.1 and 2.6.1). In order to be
consistent with more recent permits, the Division has revised the permit to allow only startup
and/or shutdown time to be averaged together and compared to the startup and shutdown NOx
and CO BACT limits. In addition, at the direction of the Division's Field Services Unit, the
averaging time for the NOx and CO startup and shutdown BACT limits has been revised. The
Divisions' Field Services Unit prefers that for startup and shutdown periods, all data during the
startup and shutdown period be averaged together, unless the startup and/or shutdown period
occurs over an extended period of time. The Division considers that these units may have
extended startup and/or shutdown periods and as a result, has set the averaging period as the
duration of the event or three hours whichever is shorter. However, if you consider that an
alternate averaging time is more appropriate, please indicate and justify the averaging time you
believe is appropriate.
Mr. Chad Campbell, Xcel Energy August 5, 2010
Draft Renewal Operating Permit Page 2
2. Please be aware that based on the revisions made to the startup and shutdown BACT limit
averaging times, the Division revised the CO startup and shutdown BACT limit to 1,000 ppmvd
@ 15% O2. Because the startup and shutdown BACT limit averaging time may be based on the
duration of the event, a lbs/hr limit is no longer appropriate and so it was removed. In addition,
although the averaging period for the combustion tuning and testing BACT limit was not revised
the Division revised the CO BACT limit for combustion tuning and testing to 1,000 ppmvd @
15% O2 to be consistent with the startup and shutdown CO BACT limit.
3. 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. Therefore please address the following issues related to these requirements:
a.) Existing Engines. The insignificant activity list in your current permit indicates that there
are three (3) diesel-fired engines driving emergency generators and one (1) diesel-fired
engine driving a fire pump. Revisions to the RICE MACT were published on March 3, 2010
which apply to existing (commenced construction or reconstruction before June 12, 2006)
compression ignition engines (all sizes) located at area sources and therefore, these
engines are subject to the RICE MACT. Under the "catch-all" provisions in Colorado
Regulation No. 3, Part C, Section II.E, sources that are subject to any federal or state
applicable requirement such as a MACT standard cannot be considered an insignificant
activity. As a result, these engines have been removed from the insignificant activity list in
Appendix A of the permit and are now included in Section II of the permit. Please provide
the make, model, serial number and hourly fuel or heat input rate (e.g., gal/hr or mmBtu/hr)
for these engines.
b.) New Engines. Please indicate whether you have any engines that would meet the following
requirements:
Requirements Applicability Date Engine Type/Size
40 CFR Part 63 Subpart 7777 Constructed and/or reconstructed Both Compression Ignition and
after 6/12/06 Spark Ignition, all sizes
40 CFR Part 60 Subpart 1111 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.
We would like you to review this permit and respond to the items identified above by September 10,
2010. Feel free to call me at (303) 692-3267 if you have any further questions.
Sincerely,
Jacque ine Joyce,
Permit Engineer
Operating Permit Unit
Stationary Sources Program
Air Pollution Control.Division
Enclosures
(8/12/2010) Jackie Joyce - FSV Site Plan Page
From: "Campbell, Chad E" <Chad.Campbell@XCELENERGY.COM>
To: Jackie Joyce -APCD <Jackie.Joyce@state.co.us>
CC: "Pinner, R.S. Joe" <Joe.Pinner@XCELENERGY.COM>, "Heston, William R" <Wi...
Date: 8/12/2010 8:44 AM
Subject: FSV Site Plan
Attachments: FortStVrainSitePlan2010.pdf
Jackie,
Here is an updated site plan for FSV that you requested.
Chad
Chad Campbell
Xcel Energy l Responsible By Nature
Environmental Services
1800 Larimer Street, Denver, CO 80202, Suite 1300
P: 303.294.2111 F: 303.294.2859
E: chad.campbell@xcelenergy.com<mailto:chad.campbell@xcelenergy.com>
blocked::blocked::http://www.xcelenergy.com/robert.ki ng@xcelenergy.com<mailto:fistname.lastna me@xc
elenergy.com>
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Environmental Department-ESG Facility
4653 Table Mountain Drive
Golden,Co 80403-1636
March 24,2010
Ms.Jacqueline Joyce
Colorado Department of Public Health&Environment
Air Pollution Control Division,APCD-SS-B 1
Al.
Operating Permit Unit
4300 Cherry Creek Drive South
Denver,CO 8 0246-1 53 0
Re: Fort Saint Vrain Station
Operating Permit No. 97OPWE180
Dear Jackie:
In accordance with the requirements of Colorado Air Quality Control Commission Regulation No. 3,Part
C. III.B.2,Public Service Company of Colorado(PSCo)is hereby submitting this application for a major
modification to our Fort Saint Vrain Station Title V Operating Permit No. 97OPWE180. This modification
is necessary to add combustion turbines no. 5 and no.4,which went into operation on March 31,2009 and
April 24,2009 respectively,to the Fort Saint Vrain Station operating permit. Attached are the completed
permit applications forms and associated documentation necessary to process this permit modification.
Also,as part of this permit modification,PSCo must assess the applicability of the Compliance Assurance
Monitoring(CAM)requirements found in 40 CFR Part 64 to this source. The three criteria for CAM
applicability are that the unit have an emission limit or standard,that a control device be used to achieve
compliance and that the unit have pre-controlled emissions greater than major source threshold amounts.
Fort Saint Vrain Units 5 &6 are not subject to the CAM requirements for its permitted emissions because
the units do not use a control device to achieve compliance. Therefore,no additional information is
necessary as part of this submittal to satisfy the CAM plan requirements for Units 5&6.
In the process of adding Units 5 &6 to the Fort Saint Vrain Title V permit, PSCo would also like to request
a change to the defmition of"Startup"as it is currently written in condition 1.2.1 of the Fort Saint Vrain
Station Title V operating permit(No. 97OPWE180). This change would make the definition consistent
with the definition of unit startup as it is written in the Fort Saint Vrain Units 5&6 Construction Permit
(07 WE 1100). Based on a request made by PSCo and sufficient supporting documentation,the Units 5 &6
Construction Permit was revised to include a definition of startup that is more representative of actual
operation of these combustion turbines. The same justification and definition is applicable to Units 2,3 and
4. As such, PSCo is requesting that the following definition of unit startup be included in the Fort St. Vrain
Title V operating permit.
"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 and ends 15 minutes after
the turbine reaches Mode 6 operation. Mode 6 refers to the condition when all six burner nozzles
are being fired. The station control system indicates which Mode the turbine is operating in. A
record of when Mode 6 combustion configuration plus 15 minutes is achieved is stored in the
station control system."
If you have any questions concerning the information provided above or the attached permit application
forms,please contact me at(720)497-2111.
Sincerely,
Chad Campbell
Environmental Services
Xcel Energy
Attachments:
As Stated
cc:
J. Pinner
M. Block
ES File
Operating Permit Application BOILER OR FURNACE OPERATION FORM 2000-300
Colorado Department of Public I lealth and Environment 09-94
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
1. Facility name: Fort Saint Vrain 2. Facility identification code: CO 1230023
3. Stack identification code: S008 4. Unit code: T005
5. Unit description: Combustion Turbine Unit 5, Simple Cycle Turbine.
6. Seasonal Fuel Dec-Feb:20 Mar-May: 0 Jun-Aug: 80 Sep-Nov: 0
Usage(%)
7.Normal Operation Hours/Day: 12 Days/Week: NA Hours/Year: 740 8. Space Heat(%)0
of Unit
9. Indicate the boiler/furnace control technology status. x Uncontrolled Controlled
Unit only equipped with combustion controls for NOx. The unit utilizes dry low NOx burners.
If the boiler/furnace is controlled, enter the control device number(s) from the appropriate forms:
2000-400 2000-401 2000-402 2000-403
2000-404 2000-405 2000-406 2000-407
10. Furnace type: Combustion Turbine Max continuous rating(mmBTU/hr): 1467
12. Manufacturer: General Electric 13. Model& Serial#: GE Model 7FA,#298106
14. Date first placed in service: March 31,2009 Date of last modification: N/A
15. Fuels and firing conditions:
Primary fuel Backup fuel#1 Backup fuel#2
Fuel name Natural Gas
Higher heating value(with units) 995 Btu/scf
Maximum sulfur content(Wt.%) <0.006%
Maximum ash content(Wt.%) Negligible
Excess CvmbustmnAtr;OR.°laOz(carele 41iii .
aat content(as f4telY (�.�o ast°
s
Maximum hourly fuel usage(units/hr.) 1.47 mmscf/hr @ 60°F
***** For this emissions unit,identify the method of compliance demonstration by completing Form 2000-500, *****
DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500
and its attachment(s)to this form.
***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. *****
1
Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604
Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
1. Facility name: Fort Saint Vrain 2. Facility identification code: CO 1230023
3. Stack identification code: S008 4. Unit identification code: T005
5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance
Regulations State Status
or Only IN OUT
Construction Permit Number
NON,CO, SO2, VOC,PM,and Construction Permit# See attached permit x
PM-10 07 WE 1100
10.Other requirements(e.g.,malfunction reporting,special operating conditions from an State Only Compliance
existing permit such as material usage,hours of operation,etc.) Status
IN OUT
Rolling 12-month gas usage limit for the turbine(see attached permit#07 WE 1100) x
**** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE
WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT****
2
Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606
Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
1. Facility name: Fort Saint Vrain 2. Facility identification code: CO 1230023
3. Stack identification code: S008 4. Unit identification code: T005
5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance
certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments
are part of the application for operating permits.
x We will continue to operate and maintain this Unit in compliance with all applicable requirements.
❑ Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will
meet such requirements on a timely basis.
6. For Units not presently fully in compliance, complete the following.
❑ This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve
compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700):
Applicable
Requirement Corrective Actions Deadline
1.
2.
3.
Progress reports will be submitted:
Start date: and every six (6) months thereafter
3
•
Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800
Colorado Department of Health 09-94
Air Pollution Control Division
Facility Name: Fort Saint Vrain Facility Identification Code: CO 1230023
I. ADMINISTRATION
This application contains the following forms: ❑ Form 2000-100,Facility Identification
❑ Form 2000-101,Facility Plot Plan
❑ Forms 2000-102,-102A,and-102B,Source and Site Descriptions
IL EMISSIONS SOURCE Total Number
DESCRIPTION of This Form
❑ Form 2000-200,Stack Identification
x Form 2000-300,Boiler or Furnace Operation 1
❑ Form 2000-301,Storage Tanks
❑ Form 2000-302,Internal Combustion Engine
❑ Form 2000-303,Incineration
❑ Form 2000-304,Printing Operations
❑ Form 2000-305,Painting and Coating Operations
❑ Form 2000-306,Miscellaneous Processes
❑ Form 2000-307,Glycol Dehydration Unit
m. AIR POLLUTION CONTROL Total Number
SYSTEM of This Form
This application contains the following forms: ❑ Form 2000-400,Miscellaneous
❑ Form 2000-401,Condensers
❑ Form 2000-402,Absorbers
❑ Form 2000-403,Catalytic or Thermal Oxidation
❑ Form 2000-404,Cyclones/Settling Chambers
❑ Form 2000-405,Electrostatic Precipitators
❑ Form 2000-406,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.in-infirm 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
4
V. EMISSION SUMMARY AND Total Number
COMPLIANCE CERTIFICATION of This Form
This application contains the following forms ❑ Form 2000-600,Emission Unit Hazardous Air Pollutants
quantifying emissions_certifying compliance
with applicable requirements,and developing a
compliance plan
❑ Form 2000-601,Emission Unit Criteria Air Pollutants
❑ Form 2000-602,Facility Hazardous Air Pollutants
❑ Form 2000-603,Facility Criteria Air Pollutants
z Form 2000-604,Applicable Requirements and Status of Emission Unit 1
❑ Form 2000-605,Permit Shield Protection Identification
x Form 2000-606,Emission Unit Compliance Plan-Commitments and Schedule 1 •
❑ Form 2000-607,Plant-Wide Applicable Requirements
❑ Form 2000-608,Plant-Wide Compliance Plan-Commitments and Schedule
VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS
A. STATEMENT OF COMPLETENESS
I have reviewed this application in its entirety and, based on information and belief formed after reasonable inquiry, I certify that
the statements and information contained in this application are true,accurate and complete.
B. CERTIFICATION OF FACILITY COMPLIANCE STATUS-FEDERAL/STATE CONDITIONS(check one box only)
x I certify that the facility described in this air pollution permit application is fully in compliance with all applicable
requirements.
❑ I certify that the facility described in this air pollution permit application is fully in compliance with all applicable
requirements,except for the following emissions unit(s):
(list all non-complying units)
WARNING: Any person who knowingly,as defined in § 18-1-501(6),C.R.S., makes any false material statement, representation,
or certification in,or omits material information from this application is guilty of a misdemeanor and may be punished in
accordance with the provisions of§25-7 122.1,C.R.S.
Printed or Typed Name Title
Steve Mills General Manager—Power Generation, Colorado
Signature � Date Signed
3/Z3//D
5
Operating Permit Application CONTROL EQUIPMENT-MISCELLANEOUS FORM 2000-400
Colorado Department of Public Health and Environment Rev 06-95
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
1. Facility name: Fort Saint Vrain 2. Facility identification code: CO 1230023
3. Stack identification code: S008 4. Unit identification code: 1005
5. Control device code:
6. Manufacturer and model number:
7. Date placed in service: Date of last modification:
8. Describe the device being used.
9. List the pollutants to be controlled by this equipment and the expected control efficiency for each pollutant on the table
below. ❑Documentation attached EITHER the outlet pollutant concentration OR the control efficiency must be
provided.
Pollutant Inlet pollutant .Emission"capture Outlet pollutant Control Efficiency(%)
concentration efficiency(94) concentration
grlacf ppmv gr/acf ppmv
y 37 'g4M1 s bgw thevollected material w$1 be handled£or reuse ur4isposai °
r h Ly _ s hu t as i iri ta.
r 3a sE a"-`a v x"ytli s Sr +'t `p`#T.b •
tt41 � f fl
g.t ,h}''
z"ftr'tri .r ear raktentton attd atem nt planT T ' Ai ,aceiltrb wear . Th ei
�.shs.F .y, •
y+r rS aft me e+ t¢ r.itt, i eplan in tot'1.r ri .0 ``` �.� hr i' '`
�� 4
a at t"ks a ! r=
e "ir trgaial
ti spnrtas �.' —e. .r�'q,`, e s Y ea. t - cr+,„+”,r�� ly
• _ 3es4$nd et3d dest�}h4 Pd&intftl Eti
}� a ai 1LEk aas.. b5"'ti �;tg�,,w� 3"t^� L c '',yam tt, xlEy irt4 t � z
5 ^""�i d- 'ya•fh,� ¢ -0 1 .�"�.5- 4°'r f
� pment11 peed s��ressticM � 4 r»a
'a'I :2a ,ye nee :?4; 4rt'Pmc D7 GUndttiCltt tltak 5+1 114.4V14r.iVIPP4u ts ;r .r.yo i>a'r „a, ali
£a'k c i � tan alai1 a review 4 T. 4 m` `� 9 '. w
4,N+ ,,�. a� s�fg44,,
� r n � m
��v gc s @fi3wr c5 m ,at r��'a
t#'a „an. s*�;Ea"ys«. �., y" ..,, . r,:. U r"t ia 'kria +i+ ''�s.i' r� ifl §vP . A '^ia v, �:$'
,, .M, ,x..,. .r i. .�. aE ,. x r...fl.... _tf_„ir 2
NOTE: COMPLETION OF INFORMATION IN SHADED AREA OF THIS FORM IS OPTIONAL
6
Operating Permit Application SUPPLEMENTAL INFORMATION FORM 2000-700
Colorado Department of Public Health and Environment 09-94
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
1. Facility name: Fort Saint Vrain 2. Facility identification code: CO 1230023
3. This form supplements Form 2000 -604 for Emission Unit(e.g. B001, P001,etc.): T005
Additional Information, Diagrams Item Number
Compliance with the NOx, SO2 and CO emission limits of construction permit#07 WE 1100 are based on data
from the continuous emission monitoring(CEM)system. Data from the CEM system is reported to the Air
Pollution Control Division in the quarterly Excess Emission Reports. Compliance with the VOC and
particulate emission limits in permit#07WEI 100 are based on fuel usage,heat content of the fuel and emission
factors from the permit. Rolling 12-month total emissions for NOx, VOC,CO, particulate and SO2 along with
gas usage are tracked in an environmental management database system. Attached is a report containing the
12-month total emissions and heat input for Unit 5 for the period April 2009—March 2010.
7
Operating Permit Application BOILER OR FURNACE OPERATION FORM 2000-300
Colorado Department of Public Health and Environment 09-94
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
1. Facility name: Fort Saint Vrain 2. Facility identification code: CO 1230023
3. Stack identification code: S009 4. Unit code: T006
5. Unit description: Combustion Turbine Unit 6, Simple Cycle Turbine.
6. Seasonal Fuel Dec-Feb: 20 Mar-May: 0 Jun-Aug: 80 Sep-Nov: 0
Usage(%)
7.Normal Operation Hours/Day: 12 Days/Week: NA Hours/Year: 740 8. Space Heat(%)0
of Unit
9. Indicate the boiler/furnace control technology status. x Uncontrolled Controlled
Unit only equipped with combustion controls for NOx. The unit utilizes dry low NOx burners.
If the boiler/furnace is controlled,enter the control device number(s)from the appropriate forms:
2000-400 _ 2000-401 2000-402 2000-403
2000-404 2000-405 2000-406 2000-407
10. Fumace type: Combustion Turbine Max continuous rating(mmBTU/hr): 1467
12. Manufacturer: General Electric 13. Model& Serial#: GE Model 7FA,#298107
14. Date first placed in service: April 24,2009 Date of last modification: N/A
15. Fuels and firing conditions:
Primary fuel Backup fuel#1 Backup fuel#2
Fuel name Natural Gas
Higher heating value(with units) 995 Btu/scf
Maximum sulfur content(Wt.%) <0.006%
Maximum ash content(Wt%) Negligible
Faccess CpmbusttanXir R ''oOj(Crrciethgi )
Rid" ,. : f s eeoi _ t smno .^', 'tSa r.• �,
��'-�-'�` t........�"�!�, {C.-+v..n_ .....ice, .. .._a. ._ ct � N.-. - _••_ .. .. t
Maximum hourly fuel usage(units/hr.) 1.47 tttmscf/hr @ 60°F
, f 'al• riitlt �q.'iLag fur '_, c "s 's - at{ f iR,.
***** For this emissions unit,identify the method of compliance demonstration by completing Form 2000-500, *****
DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500
and its attachment(s)to this form.
***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. *****
1
Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604
Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
1. Facility name: Fort Saint Vrain 2. Facility identification code: CO 1230023
3. Stack identification code: S009 4. Unit identification code: T006
5. Pollutant 6. Colorado Air Quality 7. 8.Limitation 9. Compliance
Regulations State Status
or Only IN OUT
Construction Permit Number
NON, CO, SO2, VOC,PM,and Construction Permit# See attached permit x
PM-10 07 W E 1100
10. Other requirements(e.g.,malfunction reporting, special operating conditions from an State Only Compliance
existing permit such as material usage,hours of operation,etc.) Status
IN OUT
Rolling 12-month gas usage limit for the turbine(see attached permit#07WE 1100) x
**** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE
WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT****
2
•
Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606
Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
1. Facility name: Fort Saint Vrain 2. Facility identification code: CO 1230023
3. Stack identification code: S009 4. Unit identification code: T006
5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance
certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments
are part of the application for operating permits.
x We will continue to operate and maintain this Unit in compliance with all applicable requirements.
❑ Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will
meet such requirements on a timely basis.
6. For Units not presently fully in compliance, complete the following.
❑ This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve
compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700):
Applicable
Requirement Corrective Actions Deadline
1.
2.
3.
Progress reports will be submitted:
Start date: and every six (6) months thereafter
3
Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800
Colorado Department of Health 09-94
Air Pollution Control Division
Facility Name: Fort Saint Vrain Facility Identification Code: CO_1230023
I. ADMINISTRATION
This application contains the following forms: ❑ Form 2000-100,Facility Identification
❑ Form 2000-101,Facility Plot Plan
❑ Forms 2000-102,-102A,and-102B,Source and Site Descriptions
H. EMISSIONS SOURCE Total Number
DESCRIPTION of This Form
• Form 2000-200,Stack Identification
z Form 2000-300,Boiler or Furnace Operation 1
❑ Form 2000-301,Storage Tanks
❑ Form 2000-302,Internal Combustion Engine
❑ Form 2000-303,Incineration
❑ Form 2000-304,Printing Operations
❑ Form 2000-305,Painting and Coating Operations
❑ Form 2000-306,Miscellaneous Processes
❑ Form 2000-307,Glycol Dehydration Unit
I0. 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,Absorbers
❑ Form 2000403,Catalytic or Thermal Oxidation
❑ Form 2000404,Cyclones/Settling Chambers
❑ Form 2000-405,Electrostatic Precipitators
❑ Form 2000406,Wet Collection Systems
❑ Form 2000407,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.orintine 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
4
V. EMISSION SUMMARY AND Total Number
COMPLIANCE CERTIFICATION of This Form
This application contains the following forms ❑ Form 2000-600,Emission Unit Hazardous Air Pollutants
quantifying emissions,certifying compliance
with applicable requirements,and developing a
compliance plan
❑ Form 2000-601,Emission Unit Criteria Air Pollutants
❑ Form 2000-602,Facility Hazardous Air Pollutants
❑ Form 2000-603,Facility Criteria Air Pollutants
x Form 2000-604,Applicable Requirements and Status of Emission Unit 1
❑ Form 2000-605,Permit Shield Protection Identification
x Form 2000-606,Emission Unit Compliance Plan-Commitments and Schedule 1
❑ Form 2000-607,Plant-Wide Applicable Requirements
❑ Form 2000-608,Plant-Wide Compliance Plan-Commitments and Schedule
VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS
A. STATEMENT OF COMPLETENESS
I have reviewed this application in its entirety and,based on information and belief formed after reasonable inquiry, I certify that
the statements and information contained in this application are true, accurate and complete.
B. CERTIFICATION OF FACILITY COMPLIANCE STATUS-FEDERAL/STATE CONDITIONS(check one box only)
X I certify that the facility described in this air pollution permit application is fully in compliance with all applicable
requirements.
❑ I certify that the facility described in this air pollution permit application is fully in compliance with all applicable
requirements,except for the following emissions unit(s):
(list all non-complying units)
WARNING: Any person who knowingly,as defined in§ 18-1-501(6),C.R.S., makes any false material statement, representation,
or certification in,or omits material information from this application is guilty of a misdemeanor and may be punished in
accordance with the provisions of§25-7 122.1,C.R.S.
Printed or Typed Name Title
Steve Mills General Manager—Power Generation,Colorado
Signature Date Signed
-3 23 /tD
•
Operating Permit Application CONTROL EQUIPMENT- MISCELLANEOUS FORM 2000-400
Colorado Department of Public Health and Environment Rev 06-95
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
I. Facility name: Fort Saint Vrain 2. Facility identification code: CO 1230023
3. Stack identification code: S009 4. Unit identification code: T006
5. Control device code:
6. Manufacturer and model number:
7. Date placed in service: Date of last modification:
8. Describe the device being used.
9. List the pollutants to be controlled by this equipment and the expected control effciency for each pollutant on the table
below. ❑Documentation attached EITHER the outlet pollutant concentration OR the control efficiency must be
provided.
jiy
Pollutant Inlet pollutant EmtssiDn capture Outlet pollutant Control Efficiency(%)
concentration effiotenr ("loj concentration
grfaef, ppmv. gr/acf ppmv
, i?:MI3'e "4hS
n
T
f
�tttrx thet7ctad matenat wdl be bandied£or rdnse orposaL E �A.�Y�"} Rhi F `5 x�'�F `r1 frr a i a k. —' r �a 6� � P �a C�
:itb1 ¢ :� . r gitakal
IL g�e i� SP 1 Ham@ uP.npr eht!ot�ab it { pf`^'°"tP 1 £6 Ius9 alit 6 S i. i, .'`d
PIPE it( �F IIP£ P 6 C E S 1 t "'`e&4 .(�1 P 4'Hato ! itfite� 6 Ii(^5 i r£ :ij:
it
" rx d t ayt f`t �. ., „it i i�" ° .. ,9 -et.^^ .,;,-...,..1O,,,u e� s
{ �'i' IE Y LId
';' Ili 'Ha ,..4,
�2k�'.r P 1 '(t r*TYd 5 k I4 it.: 4. ' t4�{}(3 • .fttF .txS c m . -�' xrt ,��. "S�aTM`�"r't g.n ug .4 av `'-3, sty't'3ffi'a aT+t �•gy„₹1
s,6r ro.ct'" ' .'41.,
��Et4MIIte e, "1' �'t' 'J-"
' l ewe ikegw0I�s-Hr t),ltLLltt 1 � �. Y �rzt
r r t a}q 1 t.A �� vis?.�1 � zt � : �
'• '" a '45,"' If a ai ,'efbt'I'evie 'rn sq _ seyq i..................................................
iaxz £ t'; a.
��& sq' � ," ,ya ys a fi�� i Aux '9' 3Tt 'tee�� °� � �. ¢ rl;c
@ Y �. S {"`d FR i t I t i • y
z � v'�'�. ,�q �, N V,A 3 -'a,•!'° a � , .r.a � iltp.i. i�tu..
'ursm:: �'a`+' rPox x.� IdP &Ca r� aM a � +L. ksa ''' f''T6
NOTE: COMPLETION OF INFORMATION IN SHADED AREA OF THIS FORM IS OPTIONAL
6
Operating Permit Application SUPPLEMENTAL INFORMATION FORM 2000-700
Colorado Department of Public Health and Environment 09-94
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
Facility name: Fort Saint Vrain 2. Facility identification code: CO 1230023
3. This form supplements Form 2000-604 for Emission Unit(e.g. B001, P001, etc.): T006
Additional Information, Diagrams Item Number
Compliance with the NOx, SO2 and CO emission limits of construction permit#07WE1100 are based on data
from the continuous emission monitoring(CEM)system. Data from the CEM system is reported to the Air
Pollution Control Division in the quarterly Excess Emission Reports. Compliance with the VOC and
particulate emission limits in permit#07WE1100 are based on fuel usage,heat content of the fuel and emission
factors from the permit. Rolling 12-month total emissions for NOx,VOC,CO, particulate and SO2 along with
gas usage are tracked in an environmental management database system. Attached is a report containing the
12-month total emissions and heat input for Unit 5 for the period April 2009—March 2010.
7
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FSV Units 5 & 6 As of: 3/22/2010
Emission Balances
Vas Usage PM PM10 VOG SO2 NOx CO
Annual Limits (mmSCF) (Tons) (Tons) (Tons) (Tons) (Tons) (Tons)
Permit Limits 2178 8.9 8.9 2.3 3.7 39.9 20.0
Monthly Emission History
Month Gas Usage PM PM10 VOC SO2 NOx CO
(mmSCF) Tons Tons Tons Tons Tons Tons
April-09 106 0.4 0.4 0.1 0.0 2.8 4.8
May-09 114 0.5 0.5 0.1 0.0 2.1 1.3
June-09 0 0.0 0.0 0.0 0.0 0.0 0.1
July-09 59 0.2 0.2 0.1 0.0 1.3 1.1
August-09 393 1.6 1.6 0.4 0.1 5.9 2.7
September-09 416 1.7 1.7 0.4 0.1 6.0 2.3
October-09 451 1.8 1.8 0.5 0.1 6.9 2.3
November-09 357 1.4 1.4 0.4 0.1 5.1 1.3
December-09 2 0.0 0.0 0.0 0.0 0.1 0.3
January-10 3 0.0 0.0 0.0 0.0 0.2 0.2
February-10 0 0.0 0.0 0.0 0.0 0.0 0.0
March-10 0 0.0 0.0 0.0 0.0 0.0 0.0
12-Month Rolling"
Total 1900= 7 -30.4 ' 16.4
Amount
Remaining 278 1 1 0 3 9 4
lof imit ::'.. . 873t.w_., . 86'4 '..._ 6.4 859 ..... ..157 7S2 .,-.. 81.9
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT �
C
AIR POLLUTION CONTROL DIVISION Ne.
TELEPHONE: (303) 692-3150 `. „`
*1876•
CONSTRUCTION PERMIT
PERMIT NO: 07WE1100
INITIAL APPROVAL
Modification No. 2
DATE ISSUED: January 28, 2010
ISSUED TO: Public Service Company of Colorado
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Utilities power plant known as the Fort Saint Vrain Station, located at 16805 County Road 19
1/2, approximately 1.5 miles northwest of Platteville, Weld County, Colorado
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Two (2) General Electric Simple Cycle Combustion Turbines, Model 7FA, Rated at 1467
mmBtu/hr. Natural Gas Fired.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
1. This permit shall expire if the owner or operator does not commence construction within 18
months after either the date of issuance of the permit or the date on which such construction or
activity was scheduled to commence as set forth in the permit, whichever is later; discontinues
construction for a period of eighteen months or more; or does not complete construction within a
reasonable time of the estimated completion date. (Reference: Colorado Regulation No. 3,Part
B, III.F.4.a)
Upon showing of good cause by the permittee,the Division may grant extensions of the permit not to
exceed eighteen months per extension. (Reference: Colorado Regulation No. 3, Pad B, III.F.4.b)
2. The permittee shall notify the Division 30 days prior to startup. (Reference: Colorado Regulation
No. 3, Part B, III.G.1).
3. The manufacturer, model number and serial number of the subject equipment shall be provided to
the Division prior to Final Approval. (Reference: Colorado Regulation No. 3, Part B, III.E.).
4. The permit number shall be marked on the subject equipment for ease of identification.
(Reference: Regulation No. 3, Part B, III.E.) (State only enforceable)
123/0023/010 & 011 ver. 2/00
Public Service Company of Colorado
Permit No. 07WE1100
Initial Approval, Modification No. 2 Colorado Department of Public Health and Environment
page 2 Air Pollution Control Division
5. Prevention of Significant Deterioration (PSD) requirements shall apply to this source at any such
time that this source becomes a major modification for PSD solely by virtue of a relaxation in any
permit condition. Any relaxation that increases the potential to emit above the PSD significance
level will require a full PSD review of the source as though construction had not yet commenced
on the source. The source shall not exceed the PSD significance level until a PSD permit is
granted. (Reference: Regulation No. 3, Part D, Section Vl.B.4.)
6. Major stationary source requirements for non-attainment areas shall apply to this source at any
such time that this source becomes a major modification for NOx or VOC by virtue of a relaxation
in any permit condition. Any relaxation that increases the potential to emit above the significance
level for NOx or VOC will result in these sources being subject to the major stationary source
requirements in Regulation No. 3, Part D, Section V. The source shall not exceed the significance
level until compliance with Regulation No. 3, Part D, Section V is achieved. (Reference:
Regulation No. 3, Part D, Section V.A.7.b.)
7. Except as provided for in Condition 8, 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.
EPA Method 9 shall be used to measure opacity. (Reference: Colorado Regulation No. 1, Section
II.A.1).
8. 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 (Reference: Colorado Regulation No. 1, Section II.A.4).
9. This source is subject to the requirements of Reasonably Available Control Technology (RACT).
The following emission limitations shall be complied with (Reference: Regulation No. 3, Part B,
Section III.D.2.a.(i))
Nitrogen Oxides (NOd
RACT for NOx has been determined to be Advanced Dry Low NOx (DLN) Combustion Systems
with the following emission limits:
Except as provided for below, emissions of NOx shall not exceed 9 ppmvd at 15 % O2, on
a 1-hr average.
During periods of combustion tuning and testing, emissions of NOx shall not exceed 100
ppmvd at 15% O2, on a 1-hr average.
Use of this NOx emission limit for purposes of combustion tuning and testing shall not
exceed 60 hours in any calendar year for both turbines combined. Records of the
number of hours each turbine undergoes combustion tuning and testing shall be recorded
and maintained and made available to the Division upon request.
Compliance with the RACT limit shall be monitored using the continuous emission monitoring
system required by Condition 16.
Startup and Shutdown Exemption for NOx Emission Limitations
Pollutant concentration limits are not applicable during startup and shutdown. However, the
emissions during startup and shutdown must be included for determination of compliance with
quarterly/yearly limits specified in Condition 11.
123/0023/010 & 011 ver. 2/00
•
Public Service Company of Colorado
Permit No. 07WE1100
Initial Approval, Modification No. 2 Colorado Department of Public Health and Environment
page 3 Air Pollution Control Division
"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 and ends 15 minutes after
the turbine reaches Mode 6 operation. Mode 6 refers to the condition when all six burner nozzles
are being fired. The station control system indicates which Mode the turbine is operating in. A
record of when Mode 6 combustion configuration plus 15 minutes is achieved is stored in the
station control system.
"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.
"Combustion Tuning and Testing" means the operation of the unit for the purpose of performing
combustion tuning and testing operations after a unit overhaul or as part of routine maintenance
operations. Combustion tuning and testing can occur throughout the range of the operating
conditions.
10. Both turbines together shall be limited to the fuel use rates as listed below and all other
activities, operational rates and numbers of equipment as stated in the application. Monthly
records of the actual consumption rate shall be maintained by the applicant and made available to
the Division for inspection upon request. (Reference: Colorado Regulation No. 3, Part B, II.A.4)
Natural Gas consumption, in mmscf, shall not exceed the following limitations:
Period 151 Month of 1s'2 Months of 1s' 3 Months 15112 Months Annual
Operation Operation of Operation of Operation (12-Month
Rolling Total)
1089 1,633.5 2,178 2,178 2,178
During the first twelve (12) months of operation, compliance with both the periodic and annual
consumption limitations shall be required. After the first twelve(12) months of operation,compliance
with only the annual limitation shall be required. Compliance with the annual consumption limits shall
be determined on a rolling twelve (12) month total.
11. Emissions of air pollutants from both turbines together shall not exceed the following limitations
(as calculated in the Division's preliminary analysis). Compliance with the annual limits shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
monthly emissions and keep a compliance record on site for Division review. (Reference:
Colorado Regulation No. 3, Part B, II.A.4)
Emissions of air pollutants, in tons, shall not exceed the following limitations:
Period/ 1st Month of 1st 2 Months 1st 3 Months 1st 12 Months Annual
Pollutant Operation of Operation of Operation of Operation (12-Month
Rolling Total)
PM 4.45 6.68 8.9 8.9 8.9
PKo 4.45 6.68 8.9 8.9 8.9
SO2 1.85 2.77 3.7 3.7 3.7
NOx 19.95 29.93 39.9 39.9 39.9
CO 10.0 15.0 20.0 20.0 20.0
123/0023/010 & 011 ver. 2/00
Public Service Company of Colorado
Permit No. 07WE1100
Initial Approval, Modification No. 2 Colorado Department of Public Health and Environment
page 4 Air Pollution Control Division
Period/ 1s` Month of 15t 2 Months 1513 Months 1st 12 Months Annual
Pollutant Operation of Operation of Operation of Operation (12-Month
Rolling Total)
VOC 1.15 1.73 2.3 2.3 2.3
NOx and CO emission shall be determined using the CEMS required by Condition 16. SO2
emissions shall be determined using the continuous monitoring system required by 40 CFR Part 75,
as adopted by reference in Colorado Regulation No. 18. PM, PA/110, and VOC emissions shall be
determined using the emission factors indicated in the permit notes. During the first twelve (12)
months of operation, compliance with both the periodic and annual emission limitations shall be
required. After the first twelve (12) months of operation, compliance with only the annual limitation
shall be required.
12. NOx emissions from all insignificant activities associated with these turbines shall be included
in monitoring compliance with the 39.9 tons/year emission limit in Condition 11 of this permit. The
applicant shall track emissions from all NO,emitting insignificant activities associated with these
turbines on a monthly basis and include those emissions in the daily(or periodic) and annual
emission calculations specified in Condition 11. This information shall be kept on site and made
available to the Division upon request. For the purposes of this condition, insignificant activities
shall be defined as any activity or equipment, which emits any amount but does not require an Air
Pollution Emission Notice (APEN). (Reference: Colorado Regulation No. 3, Part B Part B, II.A.4)
13. Particulate matter emissions from each turbine shall not exceed 0.1 lb/mmBtu (Reference:
Colorado Regulation No. 1, Section III. A.1.c).
14. Each turbine is subject to Colorado Regulation No. 6 - Standards of Performance for New
Stationary Sources, Part B -Specific Facilities and Sources, Non-Federal NSPS, II - Standards of
Performance for New Fuel-Burning Equipment, as follows (State-only enforceable):
a. Opacity of emissions from this unit shall not exceed 20%
b. Sulfur dioxide emissions not exceed 0.35 lbs/mmBtu
15. The turbines are subject to the provisions in 40 CFR Part 60 Subpart KKKK, "Standards of
Performance for Stationary Gas Turbines for Which Construction is Commenced After February
18, 2005", as adopted by reference in Colorado Regulation No. 6, Part A, including, but not limited
to, the following.
a. Nitrogen Oxides
Concentration of Nitrogen Oxides in the turbine exhaust shall not exceed 15 ppmvd at 15
% O2, on a 4-hr rolling average(40 CFR Part 60 Subpart KKKK§60.4325)
Note that the NOx emission limits 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 reports
required by Condition 15.1.
Compliance with the NOx emission limits shall be monitored using the NOx continuous
emission monitoring system required by 40 CFR Part 60 Subpart KKKK §60.4340(b)(1).
b. Sulfur Dioxide
123/0023/010 & 011 ver. 2/00
•
Public Service Company of Colorado
Permit No. 07WE1100
Initial Approval, Modification No. 2 Colorado Department of Public Health and Environment
page 5 Air Pollution Control Division
The permittee must not burn in the subject stationary combustion turbine any fuel which
contains total potential sulfur emissions in excess of 0.060 lb SO2/MMBtu heat input. If
the turbine simultaneously fires multiple fuels, each fuel must meet this requirement(40
CFR Part 60 Subpart KKKK§60.4330(a)(2)).
Compliance with the fuel sulfur content limit shall be presumed when burning natural gas.
The methods specified in 40 CFR Part 60 Subpart KKKK§60.4365 shall be used to
demonstrate the natural gas meets the definition of natural gas.
c. General Requirements
The permittee must operate and maintain the stationary combustion turbine, air pollution
control equipment, and monitoring equipment in a manner consistent with good air
pollution control practices for minimizing emissions at all times including during startup,
shutdown, and malfunction (40 CFR Part 60 Subpart KKKK§60.4333(a)).
d. Continuous Emission System Monitoring Requirements
(i) The continuous emission monitoring system (CEMS) shall meet the requirements
in § 60.4345.
(ii) Data from the CEMS shall be used to identify excess emissions as specified in §
60.4350.
e. Performance Testing Requirements
(i) An initial performance test shall be conducted in accordance with the provisions
in 40 CFR Part 60 Subpart KKKK§ 60.4400.
(ii) As an alternative to the initial performance test methodology specified in 40 CFR
Part 60 Subpart KKKK§60.4400, you may conduct the initial performance test as
specified in §60.4405.
f. Reporting Requirements
(i) For each affected unit required to continuously monitoring parameters or
emissions, or to periodically determine the fuel sulfur content under this subpart,
you must submit reports of excess emissions and monitor downtime in
accordance with 40 CFR Part 60 Subpart A, § 60.7(c). Excess emissions must
be reported for all periods of unit operation, including start-up, shutdown and
malfunction (40 CFR Part 60 Subpart KKKK§ 60.4375(a)).
Note that the source is exempted from monitoring the sulfur content of the fuel as
provided for in 40 CFR Part 60 Subpart KKKK§ 60.4365.
Excess emissions and monitor downtime for NOx are defined in 40 CFR Part 60
Subpart KKKK§60.4380(b).
In addition, the following requirements of Colorado Regulation No. 6, Part A, Subpart A, General
Provisions, apply to this unit.
g. At all times, including periods of start-up, shutdown, and malfunction, the facility and
control equipment shall, to the extent practicable, be maintained and operated in a
manner consistent with good air pollution control practices for minimizing emissions.
Determination of whether or not acceptable operating and maintenance procedures are
being used will be based on information available to the Division, which may include, but
is not limited to, monitoring results, opacity observations, review of operating and
123/0023/010 & 011 ver. 2/00
Public Service Company of Colorado
Permit No. 07WE1100
Initial Approval, Modification No. 2 Colorado Department of Public Health and Environment
page 6 Air Pollution Control Division
maintenance procedures, and inspection of the source. (§ 60.11(d))
h. 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 gases discharged to the atmosphere. (§ 60.12)
Written notification of construction and initial startup dates shall be submitted to the
Division as required under§§ 60.7(a)(1) and (3).
j. Records of startups, shutdowns, and malfunctions shall be maintained, as required under
§ 60.7(b).
k. Written notification of continuous monitoring system demonstrations shall be submitted to
the Division as required under§ 60.7(a)(5).
Excess Emission and Monitoring System Performance Reports shall be submitted as
required under§§ 60.7(c) and (d). Note that excess emission reports shall be
submitted quarterly.
m. Performance tests shall be conducted as required under§ 60.8.
16. For each turbine, continuous emission monitoring systems (CEMs) shall be installed, calibrated,
and operated to determine and record:
a. Concentration of Oxides of Nitrogen, ppmvd hourly average, corrected to 15% O2
b. Emissions of Oxides of Nitrogen, Ibs/hr, tons/month.
c. Concentration of Carbon Monoxide, ppmvd hourly average, corrected to 15% O2.
d. Emissions of Carbon Monoxide, tons/month.
e. Operating mode- startup, shutdown and/or standard operation
f. Load, in MW, at which turbine is operating
Monthly emissions from the GEMS shall be used in twelve month rolling totals, as specified in
Condition 11, to monitor compliance with the annual emission limitations in Condition 11.
Except where noted below, the NOx and diluent(either O2 or CO2) CEMS shall meet the
applicable requirements in 40 CFR Part 75, the performance specification requirements in 40
CFR Part 75 Appendix A and the quality assurance quality control requirements in 40 CFR Part 75
Appendix B.
Except where noted blow, the CO CEMS shall meet the applicable requirements in 40 CFR Part
60 Subpart A§60.13, the performance specification requirements in 40 CFR Part 60 Appendix A
and the quality assurance/quality control requirements in 40 CFR Part 60 Appendix F.
NOx and CO CEMS data shall meet the applicable"primary equipment hourly operating
requirements" for hourly average calculation methodology specified in 40 CFR Part 75 Subpart B
§ 75.10(d).
123/0023/010 & 011 ver. 2/00
•
Public Service Company of Colorado
Permit No. 07WE1100
Initial Approval, Modification No. 2 Colorado Department of Public Health and Environment
page 7 Air Pollution Control Division
For periods when quality assured data is not available from the continuous emission monitoring
systems the data replacement procedures in 40 CFR Part 75 Subpart D shall be used for
determining the total (annual) emissions. Although CO emissions are not specifically referenced
in the Subpart D procedures, the CEMS data acquisition system is programmed to substitute CO
emissions using the same procedures specified for NOx.
Note that the replaced data shall be used to monitor compliance with the NOx and CO annual
emission limitations.
17. In addition to the performance test required by Condition 15, performance tests shall be
conducted to measure the emission rate(s)for the pollutants listed below in order to demonstrate
compliance with the emission and pollutant concentration limits in the turbine exhaust.
(Reference: Regulation 3, Part B.III.G.3)
Particulate Matter(filterable and condensable) using EPA approved Methods
Oxides of Nitrogen using EPA approved methods.
Carbon Monoxide using EPA approved methods
Volatile Organic Compounds using EPA approved methods
A stack testing protocol shall be submitted for Division approval at least thirty (30) calendar days
prior to any performance of the test required under this condition. No stack test required herein
shall be performed without prior written approval of the protocol by the Division. The Division
reserves the right to witness the test. In order to facilitate the Division's ability to make plans to
witness the test, notice of the date (s) for the stack test shall be submitted to the Division at least
thirty (30) calendar days prior to the test. The Division may for good cause shown, waive this
thirty (30) day notice requirement. In instances when a scheduling conflict is presented, the
Division shall immediately contact the permittee in order to explore the possibility of making
modifications to the stack test schedule. The required number of copies of the compliance test
results shall be submitted to the Division within forty-five (45)calendar days of the completion of
the test unless a longer period is approved by the Division.
Any stack test conducted to show compliance with a quarterly or annual emission limitation shall
have the results projected up to the quarterly or annual averaging time by multiplying the test
results by the allowable number of operating hours for that averaging time.
NOTE: The emission limitations in this permit are based on each turbine operating for 738.5
hours per year at 100% load.
18. This source is subject to the provisions of Regulation No. 3. Part C, Operating Permits (Title V of
the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be
incorporated into the operating permit: The application for the modification to the Operating
Permit is due within one year of commencing operation of the equipment covered by this permit.
(Reference: Colorado Regulation No. 3, Part C, 111.6.2).
19. Prior to issuance of final approval, the applicant shall submit to the Division for approval an
operating and maintenance plan for all control equipment and control practices and a proposed
recordkeeping format for demonstrating compliance on an ongoing basis. The applicant shall then
follow the current Division—approved Operating and Maintenance Plan. (Reference: Colorado
Regulation No. 3, Part B, III.G.7)
20. Within one hundred and eighty days (180) after commencement of operation, compliance with the
conditions contained on this permit shall be demonstrated to the Division. It is the permittee's
responsibility to self certify compliance with the conditions. Failure to demonstrate compliance
123/0023/010 & 011 ver. 2/00
Public Service Company of Colorado
Permit No. 07WE1100
Initial Approval, Modification No. 2 Colorado Department of Public Health and Environment
page 8 Air Pollution Control Division
within 180 days may result in revocation of the permit(Reference: Colorado Regulation No. 3,
Part B, III.G.2). Information on how to certify compliance was mailed with the permit or can be
obtained from the Division at 303-692-3209. •
21. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Reg.3, Part A,II.C)
a. Annually whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five tons
per year or more, above the level reported on the last APEN; or
For volatile organic compound and nitrogen oxides sources in ozone non-attainment
areas emitting less than 100 tons of VOC per year, a change in actual emissions of one
ton per year or more or five percent, whichever is greater, above the level reported on the
last APEN submitted; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the last
APEN submitted; or
A change in actual emissions, above the level reported on the last APEN submitted, of 50
pounds of lead.
For any non-criteria reportable pollutant:
If the emissions increase by 50%or five (5)tons per year,whichever is less, above the level
reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or activity; or
c. Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
Jacqueline Joyce R"C�Hancock, Ill, P.E.
Permit Reviewer Construction Permit Unit Supervisor
Stationary Sources Program
Air Pollution Control Division
Permit History:
Date Action Description
This issuance IA, Modification 2 Revised the definition of startup in Condition 9.
July 24, 2008 IA Modification 1 Revise PM and PM,()emission limitations in Condition 11.
Revised PM and PM,,,emission factors in permit notes.
February 6, 2008 IA Initial Approval.
123/0023/010 & 011 ver. 2/00
•
Public Service Company of Colorado
Permit No. 07WE1100
Initial Approval, Modification No. 2 Colorado Department of Public Health and Environment
page 9 Air Pollution Control Division
Notes to Permit Holder:
1) The production or raw material processing limits and emission limits contained in this permit are
based on the production/processing rates requested in the permit application. These limits may
be revised upon request of the permittee providing there is no exceedance of any specific
emission control regulation or any ambient air quality standard. A revised air pollution emission
notice (APEN) and application form must be submitted with a request for a permit revision.
2) These emission units are classified as a: Synthetic minor source for Title V applicability
True minor source for HAPs
Synthetic minor for a major modification with
respect to PSD and NANSR
The facility is classified as: Major source for Title V applicability
Synthetic minor source for HAPS
Major stationary source for PSD applicability
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The permittee shall notify the
Division of any malfunction condition which causes a violation of any emission limit or limits stated
in this permit as soon as possible, but no later than two (2) hours after the start of the next
working day, followed by written notice to the Division explaining the cause of the occurrence and
that proper action has been or is being taken to correct the conditions causing said violation and
to prevent such excess emission in the future.
4) The emission levels contained in this permit are based on the following emission factors:
Pollutant Emission Factor Emission Factor Source
NOx 54 lbs/hr Manufacturer's data, at 5°F, 100% load (9 ppmvd
@ 15% O2 converted to lbs/hr)
CO 27 lbs/hr Manufacturer's data at 5°F, 100% load (9 ppmvd
@ 15% O2 converted to lbs/hr).
VOC 2.1 x 10-3 lb/mmBtu AP-42, Section 3.1 (dated 4/00),Table 3.1-2a(for
SO2 3.4 x 10-31b/mmBtu SO2 per footnote h)
PM/PM10(includes 12 lbs/hr Manufacturer's data sheet for filterable (9 lbs/hr),
condensables) at all loads and temperatures. Total PM and PM10
emission rate requested by source. Testing for
the same model turbines indicate that this
emission rate can be met.
5) The following emissions of non-criteria reportable air pollutants are established based upon the
activities as indicated in this permit and exceed the threshold for APEN reporting. This
information is listed to inform the operator of the Division's analysis of the specific compounds.
This information is listed on the Division's emission inventory system.
Pollutant CAS No. Emission Factors (lb/mmBtu) Emissions2 (lbs/yr)
Formaldehyde 50-00-0 1.30 x 10"3 1538.6
Emission factors are from AP-42 (Section 3.10, dated April 2000, Table 3.1-3.
2Emissions are based on the above emission factors, the permitted fuel consumption limit of 1089
mmscf/yr and a natural gas heat content of 995 Btu/scf.
123/0023/010 & 011 ver. 2/00
Public Service Company of Colorado
Permit No. 07WE1100
Initial Approval, Modification No. 2 Colorado Department of Public Health and Environment
page 10 Air Pollution Control Division
6) In accordance with C.R.S. 25-7-115.1, the Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years. The five-year term for this APEN expires on November
7, 2012. A revised APEN shall be submitted no later than 30 days before the five-year term
expires.
123/0023/010 & 011 ver. 2/00
Public Service Company of Colorado
Permit No. 07WE1100
Initial Approval, Modification No. 2 Colorado Department of Public Health and Environment
page 11 Air Pollution Control Division
GENERAL TERMS AND CONDITIONS: (IMPORTANT! READ ITEMS 5,6,7 AND 8)
This permit is issued in reliance upon the accuracy and completeness of information supplied by the
applicant and is conditioned upon conduct of the activity,or construction, installation and operation of the
source, in accordance with this information and with representations made by the applicant or applicant's
agents. It is valid only for the equipment and operations or activity specifically identified on the permit.
2. Unless specifically stated otherwise,the general and specific conditions contained in this permit have been
determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-
114.5(7)(a), C.R.S.
3. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or
appeal of,a condition hereof shall constitute a rejection of the entire permit and upon such occurrence,this
permit shall be deemed denied ab initio. This permit may be revoked at any time prior to final approval by
the Air Pollution Control Division(APCD)on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission(AQCC), including failure to meet any express term or
condition of the permit. If the Division denies a permit,conditions imposed upon a permit are contested by
the applicant,or the Division revokes a permit,the applicant or owner or operator of a source may request
a hearing before the AQCC for review of the Division's action.
4. This permit and any required attachments must be retained and made available for inspection upon
request at the location set forth herein. With respect to a portable source that is moved to a new location,
a copy of the Relocation Notice(required by law to be submitted to the APCD whenever a portable source
is relocated)should be attached to this permit. The permit may be reissued to a new owner by the APCD
as provided in AQCC Regulation No. 3, Part B,Section II.B. upon a request for transfer of ownership and
the submittal of a revised APEN and the required fee.
5. Issuance (initial approval) of an emission permit does not provide "final" authority for this activity or
operation of this source. Final approval of the permit must be secured from the APCD in writing in
accordance with the provisions of 25-7-114.5(12)(a)C.R.S.and AQCC Regulation No.3, Part B, Section
III.G. Final approval cannot be granted until the operation or activity commences and has been verified by
the APCD as conforming in all respects with the conditions of the permit. If the APCD so determines,it will
provide written documentation of such final approval, which does constitute"final" authority to operate.
Compliance with the permit conditions must be demonstrated within 180 days after commencement
of operation.
6. THIS PERMIT AUTOMATICALLY EXPIRES IF you(1)do not commence construction or operation within
18 months after either the date of issuance of this permit or the date on which such construction or activity
was scheduled to commence as set forth in the permit,whichever is later;(2)discontinue construction for a
period of 18 months or more;or(3)do not complete construction within a reasonable time of the estimated
completion date. Extensions of the expiration date may be granted by the APCD upon a showing of good
cause by the permittee prior to the expiration date.
7. YOU MUST notify the APCD at least thirty days (fifteen days for portable sources) prior to
commencement of the permitted operation or activity. Failure to do so is a violation of Section 25-7-
114.5(12)(a),C.R.S.and AQCC Regulation No.3,Part B,Section III.G.1.,and can result in the revocation
of the permit. You must demonstrate compliance with the permit conditions within 180 days after
commencement of operation as stated in condition 5.
8. Section 25-7-114.7(2)(a),C.R.S.requires that all sources required to file an Air Pollution Emission Notice
(APEN)must pay an annual fee to cover the costs of inspections and administration. If a source or activity
is to be discontinued,the owner must notify the Division in writing requesting a cancellation of the permit.
Upon notification, annual fee billing will terminate.
9. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and control
Act or the regulations of the AQCC may result in administrative,civil or criminal enforcement actions under
Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties),
C.R.S.
123/0023/010 & 011 ver. 2/00
7 Xcel Energy-
Environmental Department-ESG Facility
4653 Table Mountain Drive
Golden,Co 80403-1636
May 28, 2009
Ms. Jacqueline Joyce
Colorado Department of Public Health & Environment
Air Pollution Control Division, APCD-SS-B1
Operating Permit Unit
4300 Cherry Creek Drive South
Denver, CO 80246-1530
RE: Acid Rain Permit Renewal Application Form for Fort Saint Vrain Station Units 2, 3, &4
(ORIS 006112)
Dear Ms. Joyce,
Attached please find an Acid Rain Permit Renewal Application Form for Public Service Company
of Colorado's (PSCo) Fort Saint Vrain Station. This form is being submitted to the Title V
permitting authority in conjunction with the operating permit renewal application (submitted to the
Division on May 18, 2009)for this facility as required under 40 CFR Parts 72.30 and 72.31.
Please note that this Acid Rain renewal application is for Units 2, 3 and 4. The Acid Rain Permit
application for Fort Saint Vrain Units 5 & 6, the two new generating units that began operation in
April 2009, was submitted on November 27, 2007. Note that all future renewal applications for
this facility will be done for the entire facility, Units 2 through 6.
If you have any questions concerning the attached forms, please contact me at(720)497-2111.
Sincerely,
s//fG//
Chad Campbell
Environmental Services
Xcel Energy
Attachments: r`
Certification of Representation Form
cc:
A. Carlson, USEPA
FSV Station
ES FSV 2009 Operating Permit Renewal File
ES DR File
United States
Environmental Protection Agency OMB No.2060-0258
Acid Rain Program
sEpA
Acid Rain Permit Application
For more information,see instructions and 40 CFR 72.30 and 72.31.
This submission is: ❑new revised X for Acid Rain permit renewal
STEP 7
Identify the facility name,
State, and plant(ORIS) Facility(Source) Name: Fort Saint Vrain State: CO Plant Code: 006112
code.
STEP 2
a b
Enter the unit ID# Unit ID# Unit Will Hold Allowances
for every affected in Accordance with 40 CFR 72.9(c)(1)
unit at the affected
source in column "a." 2 Yes
3 Yes
4 Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
EPA Form 7610-16(rev.07-08)
Acid Rain - Page
Facility(Source) Name(from STEP 1): Fort Saint Vrain
Permit Requirements
STEP 3 (1)The designated representative of each affected source and each affected
unit at the source shall:
Read the standard (i) Submit a complete Acid Rain permit application (including a compliance
requirements. plan) under 40 CFR part 72 in accordance with the deadlines specified in
40 CFR 72.30; and
(ii) Submit in a timely manner any supplemental information that the
permitting authority determines is necessary in order to review an Acid Rain
permit application and issue or deny an Acid Rain permit;
(2) The owners and operators of each affected source and each affected unit
at the source shall:
(i) Operate the unit in compliance with a complete Acid Rain permit
application or a superseding Acid Rain permit issued by the permitting
authority; and
(ii) Have an Acid Rain Permit.
Monitoring Requirements
(1) The owners and operators and, to the extent applicable, designated
representative of each affected source and each affected unit at the source
shall comply with the monitoring requirements as provided in 40 CFR part 75.
(2) The emissions measurements recorded and reported in accordance with
40 CFR part 75 shall be used to determine compliance by the source or unit,
as appropriate, with the Acid Rain emissions limitations and emissions
reduction requirements for sulfur dioxide and nitrogen oxides under the Acid
Rain Program.
(3) The requirements of 40 CFR part 75 shall not affect the responsibility of
the owners and operators to monitor emissions of other pollutants or other
emissions characteristics at the unit under other applicable requirements of
the 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 Act.
(3) An affected unit shall be subject to the requirements under paragraph (1)
of the sulfur dioxide requirements as follows:
(i) Starting January 1, 2000, an affected unit under 40 CFR 72.6(a)(2); or
(ii) Starting on the later of January 1, 2000 or the deadline for monitor
certification under 40 CFR part 75, an affected unit under 40 CFR
72.6(a)(3).
EPA Form 7610-16(rev.07-08)
Acid Rain - Page
Facility(Source) Name(from STEP 1): Fort Saint Vrain
Sulfur Dioxide Requirements, Cont'd.
STEP 3, Cont'd. (4) Allowances shall be held in, deducted from, or transferred among
Allowance Tracking System accounts in accordance with the Acid Rain
Program.
(5) An allowance shall not be deducted in order to comply with the
requirements under paragraph (1) of the sulfur dioxide requirements prior to
the calendar year for which the allowance was allocated.
(6)An allowance allocated by the Administrator under the Acid Rain Program
is a limited authorization to emit sulfur dioxide in accordance with the Acid
Rain Program. No provision of the Acid Rain Program, the Acid Rain permit
application, the Acid Rain permit, or an exemption under 40 CFR 72.7 or 72.8
and no provision of law shall be construed to limit the authority of the United
States to terminate or limit such authorization.
(7)An allowance allocated by the Administrator under the Acid Rain Program
does not constitute a property right.
Nitrogen Oxides Requirements
The owners and operators of the source and each affected unit at the source
shall comply with the applicable Acid Rain emissions limitation for nitrogen
oxides.
Excess Emissions Requirements
(1) The designated representative of an affected source that has excess
emissions in any calendar year shall submit a proposed offset plan, as
required under 40 CFR part 77.
(2) The owners and operators of an affected source that has excess
emissions in any calendar year shall:
(i) Pay without demand the penalty required, and pay upon demand the
interest on that penalty, as required by 40 CFR part 77; and
(ii) Comply with the terms of an approved offset plan, as required by 40
CFR part 77.
Recordkeepinq and Reporting Requirements
(1) Unless otherwise provided, the owners and operators of the source and
each affected unit at the source shall keep on site at the source each of the
following documents for a period of 5 years from the date the document is
created. This period may be extended for cause, at any time prior to the end
of 5 years, in writing by the Administrator or permitting
authority:
(i) The certificate of representation for the designated representative for the
source and each affected unit at the source and all documents that
demonstrate the truth of the statements in the certificate of representation,
in accordance with 40 CFR 72.24; provided that the certificate and
documents shall be retained on site at the source beyond such 5-year
period until such documents are superseded because of the submission of
a new certificate of representation changing the designated representative;
EPA Form 7610-16(rev.07-08)
Acid Rain - Page
Facility(Source) Name (from STEP 1): Fort Saint Vrain
Recordkeepinq and Reporting Requirements, Cont'd.
STEP 3, Cont'd. (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 Act.
(2) Any person who knowingly makes a false, material statement in any
record, submission, or report under the Acid Rain Program shall be subject to
criminal enforcement pursuant to section 113(c) of the Act and 18 U.S.C.
1001.
(3) No permit revision shall excuse any violation of the requirements of the
Acid Rain Program that occurs prior to the date that the revision takes effect.
(4) Each affected source and each affected unit shall meet the requirements
of the Acid Rain Program.
(5)Any provision of the Acid Rain Program that applies to an affected source
(including a provision applicable to the designated representative of an
affected source) shall also apply to the owners and operators of such source
and of the affected units at the source.
(6) Any provision of the Acid Rain Program that applies to an affected unit
(including a provision applicable to the designated representative of an
affected unit) shall also apply to the owners and operators of such unit.
(7) Each violation of a provision of 40 CFR parts 72, 73, 74, 75, 76, 77, and
78 by an affected source or affected unit, or by an owner or operator or
designated representative of such source or unit, shall be a separate violation
of the Act.
Effect on Other Authorities
No provision of the Acid Rain Program, an Acid Rain permit application, an
Acid Rain permit, or an exemption under 40 CFR 72.7 or 72.8 shall be
construed as:
(1) Except as expressly provided in title IV of the Act, exempting or excluding
the owners and operators and, to the extent applicable, the designated
representative of an affected source or affected unit from compliance with any
other provision of the Act, including the provisions of title I of the Act relating
EPA Form 7610-16(rev.07-08)
Acid Rain - Page
Facility(Source) Name(from STEP 1): Fort Saint Vrain
Effect on Other Authorities, Cont'd.
to applicable National Ambient Air Quality Standards or State Implementation
Plans;
STEP 3, Cont'd. (2) Limiting the number of allowances a source can hold; provided, that the
number of allowances held by the source shall not affect the source's
obligation to comply with any other provisions of the Act;
(3) Requiring a change of any kind in any State law regulating electric utility
rates and charges, affecting any State law regarding such State regulation, or
limiting such State regulation, including any prudence review requirements
under such State law;
(4) Modifying the Federal Power Act or affecting the authority of the Federal
Energy Regulatory Commission under the Federal Power Act; or,
(5) Interfering with or impairing any program for competitive bidding for power
supply in a State in which such program is established.
Certification
I am authorized to make this submission on behalf of the owners and
operators of the affected source or affected units for which the submission is
STEP 4 made. I certify under penalty of law that I have personally examined, and am
Read the familiar with, the statements and information submitted in this document and
certification all its attachments. Based on my inquiry of those individuals with primary
statement, responsibility for obtaining the information, I certify that the statements and
sign, and date. information are to the best of my knowledge and belief true, accurate, and
complete. I am aware that there are significant penalties for submitting false
statements and information or omitting required statements and information,
including the possibility of fine or imprisonment.
Name: Steve Mills, Designated Representative
Signature Date -3 45 �}
EPA Form 7610-16(rev.07-08)
Xcel Energy- , �
Environmental Department-ESG Facility
4653 Table Mountain Drive
Golden,Co 80403-1636
May 18,2009
Ms.Jacqueline Joyce
Colorado Department of Public Health& Environment
Air Pollution Control Division,APCD-SS-BI
Operating Permit Unit
4300 Cherry Creek Drive South
Denver,CO 80246-1530
Re: Fort Saint Vrain Station
Permit#97OPWE180
Operating Permit Renewal Application
Dear Ms. Joyce:
In accordance with the requirements of Colorado Air Quality Control Commission Regulation No.3,Part
C, Section III.B.6,Public Service Company of Colorado(PSCo)is hereby submitting a renewal application
for the PSCo Fort Saint Vrain Station Title V Operating Permit#97OPWR180. Attached are the completed
permit application and certification forms required for this operating permit renewal. This includes the
forms required to add the newly constructed Ft. Saint Vrain Units 5 and 6 as emission sources under this
facility's operating permit and the required assessment of applicability of the Federal Compliance
Assurance Monitoring(CAM)rule to the emission sources at Fort Saint Vrain Station.
On February 6,2008,the Division issued Construction Permit No. 07WE1 100 for Fort Saint Vrain Units 5
and 6. Construction of these units is complete and operation began on both in April 2009. As required by
Regulation No.3 and Condition 18 of the construction permit,the provisions of the construction permit
must be incorporated into the operating permit. The requirement to apply for a modification to the
operating permit to include these new sources is being done in conjunction with this renewal process. All of
the required forms and information are included with this submittal.
This permit renewal also assessed the applicability of the Federal Compliance Assurance Monitoring rule to
the emission sources at Fort Saint Vrain Station. A summary of the evaluations performed for each
emission source is identified and discussed below.
Compliance Assurance Monitoring Assessment
46ch emission source at Fort Saint Vrain Station was evaluated for CAM applicability. The evaluation
identified no sources as being CAM affected. The following table details the fmal CAM determination for
each emissions source at Fort Saint Vrain Station.
CAM Applicability Determination—Fort Saint Vrain Emission Sources
Emission Source CAM Affected(Y/N) Comments
Turbine No.2(T002) N Does not use control device to achieve
compliance.
Turbine No.3 (T003) N Does not use control device to achieve
compliance.
Turbine No.4(T004) N Does use a control device to achieve
compliance,however emissions are
measured directly using a continuous
emissions monitoring system.
Turbine No.5 N Does not use control device to achieve
compliance.
Turbine No.6 N Does not use control device to achieve
compliance.
Auxiliary Boiler(B002) N Does not use control device to achieve
compliance. Compliance through type of
fuel bumed in source.
Cooling Tower(M001) N PTE is less than threshold.
If you have any questions concerning the attached permit application forms or information,please contact
Chad Campbell of Xcel Energy's Environmental Services staff, at(720)497-2111.
Sincerely,
Steve Mills
General Manager—Power Generation,Colorado
Attachments:
As Stated
cc:
M. Block-FSV
J. Pinner-FSV
ES File
•
i\')
Operating Permit Application FACILITY IDENTIFICATION �e(,�7 FORM 2000-100
Colorado Department of Public Health and Environment Rev 06-95
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
1. Facility name and Name Fort Saint Vrain Station
mailing address Street or Route 16805 County Road 19 t
City, State,Zip Code Platteville, CO 80651
2. Facility location Street Address 16805 County Road 19
(No P.O. Box) City,County,Zip Code Platteville, Weld County 80651
3. Parent corporation Name Public Service Company of Colorado
Street or Route P.O. Box 840
City, State,Zip Code Denver, CO 80201-0840
Country(if not U.S.)
4. Responsible Name Steve Mills
official Title General Manager-Power Generation, Colorado
Telephone 303-628-2679
5. Permit contact person Name Dean Metcalf
Title Director, Air and Water
(If Different than 4) Telephone 720-497-2007
6. Facility SIC code:4911 7. Facility identification code: CO 1010003
8. Federal Tax I. D.Number: 84-6015506
9. Primary activity of the operating establishment: Combustion Gas Turbine Electric Generating Station
10. Type of operating permit Li New X Modified X Renewal
11. Is the facility located in a"nonattainment"area: X Yes ❑No
If"Yes", check the designated "non-attainment"pollutant(s):
❑ Carbon Monoxide X Ozone ❑ PM10 ❑ Other(specify)
12. List all(Federal and State)air pollution permits(including grandfathered units),plan approvals and exemptions issued to
this facility. List the number,date and what unit/process is covered by each permit. For a Modified Operating Permit,do not
complete this item.
97OPWE180 August 12,2008 Operating Permit Ft. St.Vrain Station
07WE1100 February 6,2008 Construction Permit Ft. St. Vrain Station Units 5 and 6
August 1,2008 Phase II Acid Rain Permit Ft. St. Vrain Station Units 5 and 6
Operating Permit Application BOILER OR FURNACE OPERATION FORM 2000-300
Colorado Department of Public Health and Environment 09-94
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
1. Facility name: Fort St. Vrain Station 2. Facility identification code: CO 1230023
3. Stack identification code: S010 4. Unit code:.CT004
5. Unit description:
Combustion Turbine Unit 5, GE Frame 7FA, Simple Cycle Turbine
6. Seasonal Fuel Dec-Feb: 25 Mar-May: Jun-Aug:75 Sep-Nov:
Usage(%)
7.Normal Operation Hours/Day: 10 Days/Week: Hours/Year: 740 8. Space Heat(%)
of Unit
9. Indicate the boiler/furnace control technology status. ❑Uncontrolled X Controlled
If the boiler/furnace is controlled,enter the control device number(s) from the appropriate forms:
2000-400 C004 2000-401 2000-402 2000-403
2000-404 2000-405 2000-406 2000-407
10. Furnace type: Combustion Turbine II. Max continuous rating(mmBTU/hr): 1467 mmBtu/hr
12. Manufacturer: General Electric 13. Model&Serial#: GE Frame 7FA
14. Date first placed in service: April 1,2009 Date of last modification:April 1,2009
15. Fuels and firing conditions:
Primary fuel Backup fuel#1 Backup fuel#2
Fuel name Natural Gas
Higher heating value(with units) 995 BTU/scf
Maximum sulfur content(Wt.%) <0.06%
Maximum ash content(Wt.%) Negligible
EXeess Co G* Ois %O2(Cn4 th Ice) NAB ,>{l#t�,r ' q has s
'MM^��O62tr}2'B'•r€oflt kt a4 �x>r z,24 Yth ESw s �....��} t�A c. ,irzyr,`%„>z k .� s i ..s sx r
Maximum hourly fuel usage(units/hr.) 1. 47 rams cf/hr
liaWaral*IfiSiSktlnaDliff=1121111nlaglidi';l:tiMal:H.WiiM
***** For this emissions unit, identify the method of compliance demonstration by completing Form 2000-500, *****
DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500
and its attachment(s)to this form.
***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. *****
Operating Permit Application BOILER OR FURNACE OPERATION FORM 2000-300
Colorado Department of Public Health and Environment 09-94
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
1. Facility name: Fort St. Vrain Station 2. Facility identification code:CO 1230023
3. Stack identification code: S011 4. Unit code:CT005
5. Unit description:
Combustion Turbine Unit 6,GE Frame 7FA, Simple Cycle Turbine
6.Seasonal Fuel Dec-Feb:25 Mar-May: Jun-Aug: 75 Sep-Nov:
Usage(%)
7.Normal Operation Hours/Day: 10 Days/Week: Hours/Year: 740 8. Space Heat(%)
of Unit
9. Indicate the boiler/furnace control technology status. n Uncontrolled X Controlled
If the boiler/furnace is controlled,enter the control device number(s)from the appropriate forms:
2000-400 C005 2000-401 2000-402 2000-403
2000-404 2000-405 2000-406 2000-407
10. Furnace type:Combustion Turbine 1 I. Max continuous rating(mmBTU/hr): 1467 mmBtu/hr
12. Manufacturer:General Electric 13. Model&Serial#:GE Frame 7FA
14. Date first placed in service:April 24,2009 Date of last modification:April 24,2009
15. Fuels and firing conditions:
Primary fuel Backup fuel#1 Backup fuel#2
Fuel name Natural Gas
Higher heating value(with units) 995 BTU/scf
Maximum sulfur content(Wt.%) <0.006%
Maximum ash content(Wt.%) Negligible
Excess Combustion Air OR 0/0O2(Circle choice) NIA
Moisture content(as fired)(%) NA7-1
Maximum hourly fuel usage(units/hr.) 1.47 mmscf/hr
Actual annual fuel usage for 20 F
***** For this emissions unit,identify the method of compliance demonstration by completing Form 2000-500, *****
DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500
and its attachment(s)to this form.
***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. *****
Operating Permit Application CONTROL EQUIPMENT-MISCELLANEOUS FORM 2000-400
Colorado Department of Public Health and Environment Rev 06-95
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
1. Facility name:Fort St. Vrain Station 2. Facility identification code: CO 1230023
3. Stack identification code: S010 4. Unit identification code:CT004
5. Control device code: C004
6. Manufacturer and model number:General Electric GE Frame 7FA
7. Date placed in service: April I,2009 Date of last modification: April 1,2009
8. Describe the device being used. Attach a diagram of the system.
Dry Low NOx Combustion System;Manufacturer Guaranteed Emissions meet all requirements as demonstrated by compliance
testing.
9. List the pollutants to be controlled by this equipment and the expected control efficiency for each pollutant on the table
below. 17 Documentation attached EITHER the outlet pollutant concentration OR the control efficiency must be
provided.
Pollutant Inlet pollutant ;Emission capture: • Outlet pollutant Control Efficiency(%)
concentration cien concentration
g/acf ppmv ppmv
NOX �z :: :::..........: a4F;:.... Approx. 85%
v 3 f' l
10. Discuss how the collected material will be handled for reuse or disposal,-; `'
3y+• x xsa a t -t -.»?P t ,, t f �a . : . xt .d ,ey.�ea 7 a•t -uS
�E 9lr
. -"•ter •E. ..Sr :'c:t`. cra:ri?xu"s.�' —:'r�r.
.••_'i_ :sYay. .t'! 7 i car:.: p, .;!'::
x •.SF' f • �S;'a's`ii ,:: ₹.
11. Prepare a malfunction prevention and.abatement plan for this pollution control system. The plan does not have to be:
submitted with the application: It is suggested the plan include,but not be limited to the following-
a Identification of the individuals
individual(s),by title,responsible for inspecting,.maintaining and repairing this device
b Operation variables-such as temperature that will be monitored in order to detect a malfunction or breakthrough,the
correct operating range of these variables,and a detailed description of monitoring or surveillance procedures that will be used to
show compliance. .... '
f �.. .;
c. What type of monitoring equipment will be provided{temperature sensors,pressure sensors,CEMs):
. fit•.::•.
d.•'' An inspection schedule and items or conditions that will be inspected
f Where is this plan available for review? ,r 3 tr= r sil I 4: 4. l'g
' .-F ;_ J > t nv.:r_.:•.r 'L % "fs 1 ' F:�•8
.._... ._..,..... ... _..-..... .. ... .�. ,:.::..._ ..:_....• s..x s::a:..:.:..: '_-_=Y:�.'.! stiESE cam.—._'•-..
..r:�
....... • ..a•",`t.J-. �� • "^r.<•:':•.t iT. :'tCL•"::;aE':::li.................................................fkctb,.!n t
• e
NOTE: COMPLETION OF INFORMATION IN SHADED AREA OF THIS FORM IS OPTIONAL
39
Operating Permit Application CONTROL EQUIPMENT- MISCELLANEOUS FORM 2000-400
Colorado Department of Public Health and Environment Rev(16-95
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
1. Facility name: Fort St. Vrain Station 2. Facility identification code: CO 1230023
3. Stack identification code: S011 4. Unit identification code: CT005
5. Control device code: C005
6. Manufacturer and model number:General Electric GE Frame 7FA
7. Date placed in service: April 24,2009 Date of last modification: April 24, 2009
8. Describe the device being used. Attach a diagram of the system.
Dry Low NOx Combustion System; Manufacturer Guaranteed Emissions meet all requirements as demonstrated by compliance
testing.
9. List the pollutants to be controlled by this equipment and the expected control efficiency for each pollutant on the table
below. C Documentation attached EITHER the outlet pollutant concentration OR the control efficiency must be
provided.
Pollutant Inlet pollutant Emission;capture:> Outlet pollutant Control Efficiency(%)
concentration efficiency(°/a),.. : concentration
glacf ppmv gr/acf ppmv
NOx Approx. 850
1D. Discuss how the collected material will be handy for rettse of disposal - '71:46.4,nepare ittalfwtction prevention and abatement planfortb ]utton c�atnol system plar does not have tube
wiih the application It is suggested#heplan tnt lode,lrufnot he limited fo foIfowtn "
": s attonpftbG bdtvtd (s byx#ide;res nslbk for ass rp ` e ma`ttai t nt and repatnng this device
W able*such ' tpeSte1ha4WiH" Storedl �ttt et da lfianctionorbreakthrbugl;tbb
orre&. " ge ofthese vb d4Sid edtlarstipii4>a4 rn g +ra Uta11,cpp dui thatwtll b sed to . =:
show compliance y f. h
ipment"Jr-417
k beprovided{tem r re sensors pressu a Sensors, EMs)
d- t �cn schedule and items orpondmons that wt be petted.
#` inhere is this plan available far review?
NOTE: COMPLETION OF INFORMATION IN SHADED AREA OF THIS FORM IS OPTIONAL
39
Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604
Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
1. Facility name: Fort St. Vrain Station 2. Facility identification code: CO 1230023
3. Stack identification code: S010 4. Unit identification code: CT004
5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance
Regulations State Status
or Only IN OUT
Construction Permit Number
See attached permit
10. Other requirements(e.g.,malfunction reporting,special operating conditions from an State Only Compliance
existing permit such as material usage,hours of operation,etc.) Status
IN OUT
****USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE
WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT****
81
Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604
Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
1. Facility name: Fort St. Vrain Station 2-Facility identification code: CO 1230023
3. Stack identification code: S011 4. Unit identification code: CT005
5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance
Regulations State Status
or Only IN OUT
Construction Permit Number
See attached permit
10. Other requirements(e.g.,malfunction reporting, special operating conditions from an State Only Compliance
existing permit such as material usage,hours of operation,etc.) Status
IN OUT
**** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE
WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT****
81
•
STATE OF COLORADO
pc CO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT 'r ��
`' o
AIR POLLUTION CONTROL DIVISION o t
TELEPHONE: (303) 692-3150 , *
•I8T6 x
CONSTRUCTION PERMIT
PERMIT NO: 07WE1100
INITIAL APPROVAL
Modification No. 1
DATE ISSUED: JULY 24, 2008
ISSUED TO: Public Service Company of Colorado
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Utilities power plant known as the Fort Saint Vrain Station,located at 16805 County Road 19
'A, approximately 1.5 miles northwest of Platteville, Weld County, Colorado
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Two (2) General Electric Simple Cycle Combustion Turbines, Model 7FA, Rated at 1467
mmBtu/hr. Natural Gas Fired.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S.(25.7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
1. This permit shall expire if the owner or operator does not commence construction within 18
months after either the date of issuance of the permit or the date on which such construction or
activity was scheduled to commence as set forth in the permit,whichever is later;discontinues
construction for a period of eighteen months or more; or does not complete construction within a
reasonable time of the estimated completion date. (Reference: Colorado Regulation No. 3,Part
B, III.F.4.a)
Upon showing of good cause by the permittee,the Division may grant extensions of the permit not to
exceed eighteen months per extension. (Reference: Colorado Regulation No. 3, Part B, III.F.4,b)
2. The permittee shall notify the Division 30 days prior to startup. (Reference: Colorado Regulation
No. 3, Part B, III.G.1).
3. The manufacturer, model number and serial number of the subject equipment shall be provided to
the Division prior to Final Approval. (Reference: Colorado Regulation No. 3, Part B, III.E.).
4. The permit number shall be marked on the subject equipment for ease of identification.
(Reference: Regulation No. 3, Part B, III.E.) (State only enforceable)
123/0023/010&011 ver. 2/00
Public Service Company of Colorado
Permit No. 07WE1100
Initial Approval, Modification No. 1 Colorado Department of Public Health and Environment
page 2 Air Pollution Control Division
5. Prevention of Significant Deterioration (PSD) requirements shall apply to this source at any such
time that this source becomes a major modification for PSD solely by virtue of a relaxation in any
permit condition. Any relaxation that increases the potential to emit above the PSD significance
level will require a full PSD review of the source as though construction had not yet commenced
on the source. The source shall not exceed the PSD significance level until a PSD permit is
granted. (Reference: Regulation No. 3, Part D, Section VI.B.4.)
6. Major stationary source requirements for non-attainment areas shall apply to this source at any
such time that this source becomes a major modification for NOx or VOC by virtue of a relaxation
in any permit condition. Any relaxation that increases the potential to emit above the significance
level for NOx or VOC will result in these sources being subject to the major stationary source
requirements in Regulation No. 3, Part D, Section V. The source shall not exceed the significance
level until compliance with Regulation No. 3, Part D, Section V is achieved. (Reference:
Regulation No. 3, Part D, Section V.A.7.b.)
7. Except as provided for in Condition 8, 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.
EPA Method 9 shall be used to measure opacity. (Reference: Colorado Regulation No. 1, Section
• II.A.1).
8. 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 (Reference: Colorado Regulation No. 1, Section II.A.4).
9. This source is subject to the requirements of Reasonably Available Control Technology(RACT).
The following emission limitations shall be complied with (Reference: Regulation No. 3, Part B,
Section III.D.2.a.(i))
Nitrogen Oxides (NOx)
RACT for NOx has been determined to be Advanced Dry Low NOx(DLN) Combustion Systems
with the following emission limits:
Except as provided for below, emissions of NOx shall not exceed 9 ppmvd at 15 %O2, on
a 1-hr average.
During periods of combustion tuning and testing, emissions of NOx shall not exceed 100
ppmvd at 15%O2, on a 1-hr average.
Use of this NOx emission limit for purposes of combustion tuning and testing shall not
exceed 60 hours in any calendar year for both turbines combined. Records of the
number of hours each turbine undergoes combustion tuning and testing shall be recorded
and maintained and made available to the Division upon request.
Compliance with the RACT limit shall be monitored using the continuous emission monitoring
system required by Condition 16.
Startup and Shutdown Exemption for NOx Emission Limitations
Pollutant concentration limits are not applicable during startup and shutdown. However, the
emissions during startup and shutdown must be included for determination of compliance with
quarterly/yearly limits specified in Condition 11.
123/0023/010&011 ver. 2/00
Public Service Company of Colorado
Permit No. 07WE1100
Initial Approval, Modification No. 1 Colorado Department of Public Health and Environment
page 3 Air Pollution Control Division
"Startup" means the setting in operation of any air pollution source for any purpose. Setting in
operation for these turbines is defined as the time period between initial fuel firing to combustion
configuration Mode 6. Mode 6 refers to the condition when all six burner nozzles are being fired.
The station control system indicates which Mode the turbine is operating in.A record of when
Mode 6 combustion configuration is achieved is stored in the station control system.
"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.
"Combustion Tuning and Testing"means the operation of the unit for the purpose of performing
combustion tuning and testing operations after a unit overhaul or as part of routine maintenance
operations. Combustion tuning and testing can occur throughout the range of the operating
conditions.
10. Both turbines together shall be limited to the fuel use rates as listed below and all other
activities, operational rates and numbers of equipment as stated in the application. Monthly
records of the actual consumption rate shall be maintained by the applicant and made available to
the Division for inspection upon request. (Reference: Colorado Regulation No. 3, Part B, Il.A.4)
Natural Gas consumption, in mmscf, shall not exceed the following limitations:
Period 151 Month of 1st 2 Months of 1st 3 Months 1St 12 Months Annual
Operation Operation of Operation of Operation (12-Month
Rolling Total)
1089 1,633.5 2,178 2,178 2,178
During the first twelve (12) months of operation, compliance with both the periodic and annual
consumption limitations shall be required. After the first twelve(12)months of operation,compliance
with only the annual limitation shall be required. Compliance with the annual consumption limits shall
be determined on a rolling twelve(12)month total.
11. Emissions of air pollutants from both turbines together shall not exceed the following limitations
(as calculated in the Division's preliminary analysis). Compliance with the annual limits shall be
determined on a rolling twelve(12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months'data. The permit holder shall calculate
monthly emissions and keep a compliance record on site for Division review. (Reference:
Colorado Regulation No. 3, Part B, II.A.4)
Emissions of air pollutants, in tons, shall not exceed the following limitations:
Period I 1st Month of 1812 Months 1St 3 Months 1St 12 Months Annual
Pollutant Operation of Operation of Operation of Operation (12-Month
Rolling Total)
PM 4.45 6.68 8.9 8.9 8.9
PM10 4.45 6.68 8.9 8.9 8.9
SO2 1.85 2.77 3.7 3.7 3.7
NOx 19.95 29.93 39.9 39.9 39.9
CO 10.0 15.0 20.0 20.0 20.0
VOC 1.15 1.73 2.3 2.3 2.3
123/0023/010& 011 ver. 2/00
Public Service Company of Colorado
Permit No. 07WE1100
Initial Approval, Modification No. 1 Colorado Department of Public Health and Environment
page 4 Air Pollution Control Division
NOx and CO emission shall be determined using the CEMS required by Condition 16. SO2
emissions shall be determined using the continuous monitoring system required by 40 CFR Part 75,
as adopted by reference in Colorado Regulation No. 18. PM, PM10, and VOC emissions shall be
determined using the emission factors indicated in the permit notes. During the first twelve (12)
months of operation, compliance with both the periodic and annual emission limitations shall be
required. After the first twelve(12)months of operation, compliance with only the annual limitation
shall be required.
12. NOx emissions from all insignificant activities associated with these turbines shall be included
in monitoring compliance with the 39.9 tons/year emission limit in Condition 11 of this permit. The
applicant shall track emissions from all NOx emitting insignificant activities associated with these
turbines on a monthly basis and include those emissions in the daily(or periodic)and annual
emission calculations specified in Condition 11. This information shall be kept on site and made
available to the Division upon request. For the purposes of this condition, insignificant activities
shall be defined as any activity or equipment,which emits any amount but does not require an Air
Pollution Emission Notice(APEN)_ (Reference: Colorado Regulation No. 3, Part B Part B, II.A.4)
13. Particulate matter emissions from each turbine shall not exceed 0.1 Ib/mmBtu (Reference:
Colorado Regulation No. 1, Section III.A.1.c).
14. Each turbine is subject to Colorado Regulation No. 6-Standards of Performance for New
Stationary Sources, Part B-Specific Facilities and Sources, Non-Federal NSPS, II-Standards of
Performance for New Fuel-Burning Equipment, as follows(State-only enforceable):
a. Opacity of emissions from this unit shall not exceed 20%
b. Sulfur dioxide emissions not exceed 0.35 lbs/mmBtu
15. The turbines are subject to the provisions in 40 CFR Part 60 Subpart KKKK, "Standards of
Performance for Stationary Gas Turbines for Which Construction is Commenced After February
18, 2005", as adopted by reference in Colorado Regulation No. 6, Part A, including, but not limited
to, the following.
a. Nitrogen Oxides
Concentration of Nitrogen Oxides in the turbine exhaust shall not exceed 15 ppmvd at 15
%02, on a 4-hr rolling average(40 CFR Part 60 Subpart KKKK§60.4325)
Note that the NOx emission limits 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 reports
required by Condition 15.1.
Compliance with the NOx emission limits shall be monitored using the NOx continuous
emission monitoring system required by 40 CFR Part 60 Subpart KKKK§60.4340(b)(1).
b. Sulfur Dioxide
The permittee must not burn in the subject stationary combustion turbine any fuel which
contains total potential sulfur emissions in excess of 0.060 lb SO2/MMBtu heat input. If
the turbine simultaneously fires multiple fuels,each fuel must meet this requirement(40
CFR Part 60 Subpart KKKK§60.4330(a)(2)).
12310023/010&011 ver. 2/00
Public Service Company of Colorado
Permit No. 07WE1100
Initial Approval, Modification No. 1 Colorado Department of Public Health and Environment
page 5 Air Pollution Control Division
Compliance with the fuel sulfur content limit shall be presumed when burning natural gas.
The methods specified in 40 CFR Part 60 Subpart KKKK§ 60.4365 shall be used to
demonstrate the natural gas meets the definition of natural gas.
c. General Requirements
The permittee must operate and maintain the stationary combustion turbine, air pollution
control equipment, and monitoring equipment in a manner consistent with good air
pollution control practices for minimizing emissions at all times including during startup,
shutdown, and malfunction (40 CFR Part 60 Subpart KKKK§60.4333(a)).
d. Continuous Emission System Monitoring Requirements
{i) The continuous emission monitoring system (CEMS) shall meet the requirements
in §60.4345.
(ii) Data from the CEMS shall be used to identify excess emissions as specified in §
60.4350.
e. Performance Testing Requirements
(I) An initial performance test shall be conducted in accordance with the provisions
in 40 CFR Part 60 Subpart KKKK§60.4400.
(ii) As an alternative to the initial performance test methodology specified in 40 CFR
Part 60 Subpart KKKK§60.4400, you may conduct the initial performance test as
specified in § 60.4405.
f. Reporting Requirements
(I) For each affected unit required to continuously monitoring parameters or
emissions, or to periodically determine the fuel sulfur content under this subpart,
you must submit reports of excess emissions and monitor downtime in
accordance with 40 CFR Part 60 Subpart A, §60.7(c). Excess emissions must
be reported for all periods of unit operation, including start-up, shutdown and
malfunction (40 CFR Part 60 Subpart KKKK§60.4375(a)).
Note that the source is exempted from monitoring the sulfur content of the fuel as
provided for in 40 CFR Part 60 Subpart KKKK§ 60.4365.
(ii) Excess emissions and monitor downtime for NOx are defined in 40 CFR Part 60
Subpart KKKK§60.4380(b).
In addition, the following requirements of Colorado Regulation No. 6, Part A, Subpart A, General
Provisions, apply to this unit.
g. At all times, including periods of start-up, shutdown, and malfunction, the facility and
control equipment shall, to the extent practicable, be maintained and operated in a
manner consistent with good air pollution control practices for minimizing emissions.
Determination of whether or not acceptable operating and maintenance procedures are
being used will be based on information available to the Division, which may include, but
is not limited to, monitoring results, opacity observations, review of operating and
maintenance procedures, and inspection of the source. (§60.11(d))
h. 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
123/0023/010& 011 ver. 2/00
Public Service Company of Colorado
Permit No. 07WE1100
Initial Approval, Modification No. 1 Colorado Department of Public Health and Environment
page 6 Air Pollution Control Division
opacity standard or with a standard which is based on the concentration of a pollutant in
the gases discharged to the atmosphere. (§60.12)
Written notification of construction and initial startup dates shall be submitted to the
Division as required under§§60.7(a)(1)and (3).
j. Records of startups, shutdowns, and malfunctions shall be maintained, as required under
§60.7(b).
k. Written notification of continuous monitoring system demonstrations shall be submitted to
the Division as required under§60.7(a)(5).
Excess Emission and Monitoring System Performance Reports shall be submitted as
required under§§60.7(c)and (d). Note that excess emission reports shall be
submitted quarterly.
m. Performance tests shall be conducted as required under§60.8.
16. For each turbine, continuous emission monitoring systems (CEMs)shall be Installed, calibrated,
and operated to determine and record:
a. Concentration of Oxides of Nitrogen, ppmvd hourly average, corrected to 15% O2
b. Emissions of Oxides of Nitrogen, lbs/hr, tons/month.
c. Concentration of Carbon Monoxide, ppmvd hourly average, corrected to 15%O2.
d. Emissions of Carbon Monoxide, tons/month.
e. Operating mode-startup, shutdown and/or standard operation
f. Load, in MW, at which turbine is operating
Monthly emissions from the GEMS shall be used in twelve month rolling totals, as specified in
Condition 11, to monitor compliance with the annual emission limitations in Condition 11.
Except where noted below, the NOx and diluent(either O2 or CO2)GEMS shall meet the
applicable requirements in 40 CFR Part 75, the performance specification requirements in 40
CFR Part 75 Appendix A and the quality assurance quality control requirements in 40 CFR Part 75
Appendix B.
Except where noted blow, the CO CEMS shall meet the applicable requirements in 40 CFR Part
60 Subpart A§60.13, the performance specification requirements in 40 CFR Part 60 Appendix A
and the quality assurance/quality control requirements in 40 CFR Part 60 Appendix F.
NOx and CO CEMS data shall meet the applicable"primary equipment hourly operating
requirements"for hourly average calculation methodology specified in 40 CFR Part 75 Subpart B
§75.10(d).
For periods when quality assured data is not available from the continuous emission monitoring
systems the data replacement procedures in 40 CFR Part 75 Subpart D shall be used for
determining the total (annual)emissions. Although CO emissions are not specifically referenced
in the Subpart D procedures, the GEMS data acquisition system is programmed to substitute CO
emissions using the same procedures specified for NOx.
123/0023/010 &011 ver. 2/00
Public Service Company of Colorado
Permit No. 07WE1100
Initial Approval, Modification No. 1 Colorado Department of Public Health and Environment
page 7 Air Pollution Control Division
Note that the replaced data shall be used to monitor compliance with the NOx and CO annual
emission limitations.
17. In addition to the performance test required by Condition 15, performance tests shall be
conducted to measure the emission rate(s) for the pollutants listed below in order to demonstrate
compliance with the emission and pollutant concentration limits in the turbine exhaust.
(Reference: Regulation 3, Part B.III.G.3)
Particulate Matter(filterable and condensable)using EPA approved Methods
Oxides of Nitrogen using EPA approved methods.
Carbon Monoxide using EPA approved methods
Volatile Organic Compounds using EPA approved methods
A stack testing protocol shall be submitted for Division approval at least thirty(30)calendar days
prior to any performance of the test required under this condition. No stack test required herein
shall be performed without prior written approval of the protocol by the Division. The Division
reserves the right to witness the test. In order to facilitate the Division's ability to make plans to
witness the test, notice of the date(s)for the stack test shall be submitted to the Division at least
thirty(30) calendar days prior to the test. The Division may for good cause shown, waive this
thirty(30)day notice requirement. In instances when a scheduling conflict is presented, the
Division shall immediately contact the permittee in order to explore the possibility of making
modifications to the stack test schedule. The required number of copies of the compliance test
results shall be submitted to the Division within forty-five(45) calendar days of the completion of
the test unless a longer period is approved by the Division.
Any stack test conducted to show compliance with a quarterly or annual emission limitation shall
have the results projected up to the quarterly or annual averaging time by multiplying the test
results by the allowable number of operating hours for that averaging time.
NOTE: The emission limitations in this permit are based on each turbine operating for 736.5
hours per year at 100% load.
18. This source is subject to the provisions of Regulation No. 3. Part C, Operating Permits(Title V of
the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be
incorporated into the operating permit. The application for the modification to the Operating
Permit is due within one year of commencing operation of the equipment covered by this permit.
(Reference: Colorado Regulation No. 3, Part C, 111.8.2).
19. Prior to issuance of final approval, the applicant shall submit to the Division for approval an
operating and maintenance plan for all control equipment and control practices and a proposed
recordkeeping format for demonstrating compliance on an ongoing basis. The applicant shall then
follow the current Division—approved Operating and Maintenance Plan. (Reference: Colorado
Regulation No. 3, Part B, III.G.7)
20. Within one hundred and eighty days(180)after commencement of operation, compliance with the
conditions contained on this permit shall be demonstrated to the Division. It is the permittee's
responsibility to self certify compliance with the conditions. Failure to demonstrate compliance
within 180 days may result in revocation of the permit(Reference: Colorado Regulation No. 3,
Part B, III.G.2). Information on how to certify compliance was mailed with the permit or can be
obtained from the Division at 303-692-3209.
123/0023/010&011 ver. 2/00
Public Service Company of Colorado
Permit No. 07WE1100
Initial Approval, Modification No. 1 Colorado Department of Public Health and Environment
page 8 _ Air Pollution Control Division
21. A revised Air Pollutant Emission Notice (APEN) shall be filed. (Reference: Reg.3, Part A,II.C)
a. Annually whenever a significant increase in emissions occurs as follows:
For any criteria pollutant
For sources emitting less than 100 tons per year, a change in actual emissions of five tons
per year or more, above the level reported on the last APEN; or
For volatile organic compound and nitrogen oxides sources in ozone non-attainment
areas emitting less than 100 tons of VOC per year, a change in actual emissions of one
ton per year or more or five percent,whichever is greater, above the level reported on the
last APEN submitted; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more,whichever is less, above the level reported on the last
APEN submitted; or
A change in actual emissions, above the level reported on the last APEN submitted, of 50
pounds.of lead.
For any non-criteria reportable pollutant:
If the emissions increase by 50%or five(5)tons per year,whichever is less,above the level
reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or activity;or
c. Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
J cquefire Joyce R K Hancock, Ill, P.E.
Permit Reviewer Construction Permit Unit Supervisor
Stationary Sources Program
Air Pollution Control Division
Permit History:
Date Action Description
This Issuance IA Modification 1 Revise PM and PMio emission limitations in Condition 11.
Revised PM and PM10 emission factors in permit notes.
February 6, 2008 IA Initial Approval.
123/0023/010 &011 ver. 2/00
Public Service Company of Colorado
Permit No. 07WE1100
Initial Approval, Modification No. 1 Colorado Department of Public Health and Environment
page 9 Air Pollution Control Division
Notes to Permit Holder:
1) The production or raw material processing limits and emission limits contained in this permit are
based on the production/processing rates requested in the permit application. These limits may
be revised upon request of the permittee providing there is no exceedance of any specific
emission control regulation or any ambient air quality standard. A revised air pollution emission
notice (APEN) and application form must be submitted with a request for a permit revision.
2) These emission units are classified as a: Synthetic minor source for Title V applicability
True minor source for HAPs
Synthetic minor for a major modification with
respect to PSD and NANSR
The facility is classified as: Major source for Title V applicability
Synthetic minor source for HAPS
Major stationary source for PSD applicability
3) This source is subject to the Common Provisions Regulation Part II, Subpart E,Affirmative
Defense Provision for Excess Emissions During Malfunctions. The permittee shall notify the
Division of any malfunction condition which causes a violation of any emission limit or limits stated
in this permit as soon as possible, but no later than two(2) hours after the start of the next
working day, followed by written notice to the Division explaining the cause of the occurrence and
that proper action has been or is being taken to correct the conditions causing said violation and
to prevent such excess emission in the future.
4) The emission levels contained in this permit are based on the following emission factors:
Pollutant Emission Factor Emission Factor Source
NOx 54 lbs/hr Manufacturer's data, at 5°F, 100%load(9 ppmvd
@ 15% O2 converted to lbs/hr)
CO 27 lbs/hr Manufacturer's data at 5°F, 100% load (9 ppmvd
@ 15%O2 converted to lbs/hr).
VOC 2.1 x 10'3 lb/mmBtu AP-42,Section 3.1 (dated 4/00),Table 3.1-2a(for
SO2 3.4 x 10'3 lb/mmBtu SO2 per footnote h)
PM/PM,o(includes 12 lbs/hr Manufacturer's data sheet for filterable(9 lbs/hr),
condensables) at all loads and temperatures. Total PM and PM1a
emission rate requested by source. Testing for
the same model turbines indicate that this
emission rate can be met.
5) The following emissions of non-criteria reportable air pollutants are established based upon the
activities as indicated in this permit and exceed the threshold for APEN reporting. This
information is listed to inform the operator of the Division's analysis of the specific compounds.
This information is listed on the Division's emission inventory system.
Pollutant CAS No. Emission Factor' (lb/mmBtu) Emissions2(Ibs/yr)
Formaldehyde 50-00-0 1.30 x 10-3 1538.6
'Emission factors are from AP-42 (Section 3.10, dated April 2000, Table 3.1-3.
2Emissions are based on the above emission factors, the permitted fuel consumption limit of 1089
mmscf/yr and a natural gas heat content of 995 Btu/scf.
123/0023/010&011 ver. 2/00
Public Service Company of Colorado
Permit No. 07WE1100
Initial Approval, Modification No. 1 Colorado Department of Public Health and Environment
page 10 Air Pollution Control Division
6) In accordance with C.R.S. 25-7-115.1,the Air Pollutant Emission Notice(APEN) associated with
this permit is valid for a term of five years. The five-year term for this APEN expires on November
7, 2012. A revised APEN shall be submitted no later than 30 days before the five-year term
expires.
123/0023/010&011 ver. 2/00
•
Public Service Company of Colorado
Permit No. 07WE1100
Initial Approval, Modification No. 1 Colorado Department of Public Health and Environment
page 11 _ Air Pollution Control Division
GENERAL TERMS AND CONDITIONS: (IMPORTANT! READ ITEMS 5,6,7 AND 8)
1. This permit is issued in reliance upon the accuracy and completeness of information supplied by the
applicant and is conditioned upon conduct of the activity,or construction,installation and operation of the
source,in accordance with this information and with representations made by the applicant or applicant's
agents. It is valid only for the equipment and operations or activity specifically identified on the permit.
2. Unless specifically stated otherwise,the general and specific conditions contained in this permit have been
determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-
114.5(7)(a), C.R.S.
3. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or
appeal of,a condition hereof shall constitute a rejection of the entire permit and upon such occurrence,this
permit shall be deemed denied ab inilio. This permit may be revoked at any time prior to final approval by
the Air Pollution Control Division(APCD)on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission(AQCC),including failure to meet any express term or
condition of the permit. If the Division denies a permit,conditions imposed upon a permit are contested by
the applicant,or the Division revokes a permit,the applicant or owner or operator of a source may request
a hearing before the AQCC for review of the Division's action.
4. This permit and any required attachments must be retained and made available for inspection upon
request at the location set forth herein. With respect to a portable source that is moved to a new location,
a copy of the Relocation Notice(required by law to be submitted to the APCD whenever a portable source
is relocated)should be attached to this permit. The permit may be reissued to a new owner by the APCD
as provided in AQCC Regulation No.3,Part B,Section II.B.upon a request for transfer of ownership and
the submittal of a revised APEN and the required fee.
5. Issuance (initial approval) of an emission permit does not provide "final" authority for this activity or
operation of this source. Final approval of the permit must be secured from the APCD in writing in
accordance with the provisions of 25-7-114.5(12)(a)C.R.S.and AQCC Regulation No.3,Part B,Section
11I.G. Final approval cannot be granted until the operation or activity commences and has been verified by
the APCD as conforming in all respects with the conditions of the permit. If the APCD so determines,it will
provide written documentation of such final approval,which does constitute"final"authority to operate.
Compliance with the permit conditions must be demonstrated within 180 days after commencement
of operation.
6. THIS PERMIT AUTOMATICALLY EXPIRES IF you(1)do not commence construction or operation within
18 months after either the date of issuance of this permit or the date on which such construction or activity
was scheduled to commence as set forth in the permit,whichever is later;(2)discontinue construction for a
period of 18 months or more;or(3)do not complete construction within a reasonable time of the estimated
completion date. Extensions of the expiration date may be granted by the APCD upon a showing of good
cause by the permittee prior to the expiration date.
7. YOU MUST notify the APCD at least thirty days (fifteen days for portable sources) prior to
commencement of the permitted operation or activity. Failure to do so is a violation of Section 25-7-
114.5(12)(a),C.R.S.and AQCC Regulation No.3,Part B,Section 111.0.1.,and can result in the revocation
of the permit. You must demonstrate compliance with the permit conditions within 180 days after
commencement of operation as stated in condition 5.
8. Section 25-7-114.7(2)(a),C.R.S.requires that all sources required to file an Air Pollution Emission Notice
(APEN)must pay an annual fee to cover the costs of inspections and administration. If a source or activity
is to be discontinued,the owner must notify the Division in writing requesting a cancellation of the permit.
Upon notification, annual fee billing will terminate.
9. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and control
Act or the regulations of the AQCC may result in administrative,civil or criminal enforcement actions under
Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties),
C.R.S.
123/0023/010& 011 ver. 2/00
Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606
Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
1. Facility name: Fort St. Vrain Station 2. Facility identification code: CO 1230023
3. Stack identification code: S010 4. Unit identification code: CT004
5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance
certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments
are part of the application for operating permits.
x We will continue to operate and maintain this Unit in compliance with all applicable requirements.
i 7 Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will
meet such requirements on a timely basis.
6. For Units not presently fully in compliance, complete the following.
❑ This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve
compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700):
Applicable
Requirement Corrective Actions Deadline
1.
2.
3.
Progress reports will be submitted:
Start date: and every six (6) months thereafter
85
•
Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606
Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
1. Facility name: Fort St. Vrain Station 2. Facility identification code: CO 1230023
3. Stack identification code: S011 4. Unit identification code: CT005
5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance
certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments
are part of the application for operating permits.
x We will continue to operate and maintain this Unit in compliance with all applicable requirements.
Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will
meet such requirements on a timely basis.
6. For Units not presently fully in compliance, complete the following.
This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve
compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700):
Applicable
Requirement Corrective Actions Deadline
1.
2.
3.
Progress reports will be submitted:
Start date: and every six (6) months thereafter
85
Operating Permit'Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800
Colorado Department of Health 09-94
Air Pollution Control Division
Facility Name: Fort St. Vrain Station Facility Identification Code: CO 1230023_
ADMINISTRATION
This application contains the following forms: X Form 2000-100,Facility Identification -
Form 2000-101,Facility Plot Plan
• Forms 2000-102,-102A,and-10213,Source and Site Descriptions
IL EMISSIONS SOURCE Total Number
DESCRIPTION of This Form
This application contains the following forms C Form 2000-200,Stack Identification
(one form for each facility boiler.orintine
X Form 2000-300,Boiler or Furnace Operation 2
• Form 2000-301,Storage Tanks
❑ Form 2000-302,Internal Combustion Engine
❑ Form 2000-303,Incineration
H Form 2000-304,Printing Operations
❑ Form 2000-305,Painting and Coating Operations
7 Form 2000-306,Miscellaneous Processes
❑ Form 2000-307,Glycol Dehydration Unit
IIL AIR POLLUTION CONTROL Total Number
SYSTEM
of This Form
This application contains the following forms: X Form 2000400,Miscellaneous 2
7 Form 2000-401,Condensers
❑ Form 2000-402,Adsorbers
❑ Form 2000-403,Catalytic or Thermal Oxidation
• Form 2000-404,Cyclones/Settling Chambers
❑ Form 2000405,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
C Form 2000-503,Control System Parameters or Operation Parameters of a Process
❑ Form 2000-504,Monitoring Maintenance Procedures
:7 Form 2000-505,Stack Testing
7 Form 2000-506,Fuel Sampling and Analysis
❑ Form 2000-507,Recordkeeping
❑ Form 2000-508,Other Methods
93
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