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COLORADO
Department of Public
Health 8 Environment
Weld County - Clerk to the Board
1150 O St
PO Box 758
Greeley, CO 80632
May 7, 2025
To Whom It May Concern:
RECEIVED
MAY 0 7 2025
WELD COUNTY
COMMISSIONERS
On May 7, 2025, the Colorado Air Pollution Control Division will begin a 3O -day public
comment period for Public Service Company of Colorado - Ft. St. Vrain Station. A copy
of this public notice is enclosed.
Thank you for assisting the division by posting a copy of this notice in your office. A
public copy of this notice is required by Colorado Air Quality Control Commission
regulations. The notice must be available for public inspection for a period of thirty
(30) days from the beginning of the public comment period. Please reference the
public notice for instructions on submitting comments.
\90 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.Qov/cdphe
j°) Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director
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2025-1241
DRAFT
Colorado Department
of Public Health
and Environment
Public Service Company of Colorado
Ft. St. Vrain
CONSTRUCTION PERMIT 94WE609
Initial Approval / Modification 2
Date Issued: TBD
COLORADO
Air Pollution Control Division
Depanment of Pubdc Health b Bmronment
Page 1 of 41
DRAFT
AIR POLLUTION CONTROL DIVISION
COLORADO CONSTRUCTION PERMIT
FACILITY NAME:
FACILITY ID:
Ft. St. Vrain Station CONSTRUCTION PERMIT NUMBER
123/0023 94WE609
ISSUE DATE: Initial Approval/ Modification 2
ISSUED TO:
Public Service Company of Colorado
1800 Larimer Street
Suite 1300
Denver, Co 80202
Nature of Business:
Primary SIC:
PLANT SITE LOCATION:
Ft. St. Vrain Station
16805 County Road 19 Y:
Platteville, CO 80651
Weld County
Combustion Turbine Electric Generating Station
4911
Description of Modification 2:
Modification 2 adds and SCR on to turbine 002 (AIRS ID 004) to control NOx.
COLORADO
Air Pollution Control Division
Department of Publx Health 6 Environment
Page 2 of 41
DRAFT
TABLE OF CONTENTS:
Section 1— General Activities and Summary
1. Permitted Activities
2. Alternative Operating Scenarios
3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant Deterioration (PSD)
4. Summary of Emission Units
Section II — Specific Permit Terms
1. T002 & T003 —Two (2) Combustion Turbines Capable of Simple or Combined Cycle Operation
2. Continuous Emission Monitoring Systems (CEMS)
Section III — Additional Requirements & General Conditions
Appendix A
Permit Acronyms
Appendix B
VOC Correlation Equations
COLORADO
Air Pollution Control Division
Department of Public Health b Enwotment
Page 3 of 41
DRAFT
Section I — General Activities and Summary
1. Permitted Activities
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. T002 (Turbine No. 2) is controlled by a
selective catalytic reduction (SCR) control. 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 fuel -fired engines driving an emergency generator and one (1) diesel fuel -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 the 8 -hr ozone standard and is part of the 8 -hr
Ozone Control Area as defined in Regulation No. 26, Part A. The 8 -hr Ozone Control Area has
been classified as a serious non -attainment area effective January 27, 2020.
COLORADO
An Pollution Control Division
Department of public Health ft Environment
Page 4 of 41
DRAFT
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.
b. Until such time as this permit 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.
2. Alternative Operating Scenarios
a. The permittee shall be allowed to make the following changes to its method of operation
without applying for a revision of this permit.
i. Turbines No. 2, and 3 may be operated as follows:
1. The combustion turbines may be operated as simple cycle combustion
turbines as specified under Section II.
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.
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.
b. 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).
3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant
Deterioration (PSD)
a. 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.27 and 44) 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.44 for which the area is in attainment or
attainment/maintenance may result in the application of the PSD review requirements.
b. This source is categorized as a NANSR major stationary source (Potential to Emit of NOX > 50
tons/year). Future modifications at this facility resulting in a significant net emissions
increase (see Regulation No. 3, Part D, Sections II.A.27 and 44) for VOC or NOX or a
modification which is major by itself (Potential to Emit > 50 tons/year of either VOC or NOX)
may result in the application of the NANSR review requirements.
4. Summary of Emission Units
a. The emission units regulated by this permit are the following:
4.4
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Page 5 of 41
DRAFT
Emission Unit
No./Facility
ID.
AIRS
Point
Number
Description
Startup Date
Pollution Control
Device
T002
004
General Electric Combustion
Turbine, Model No. GE Frame 7FA,
Serial No. 299480, rated at 1,899
MMBtu/hr (turbine 1,477
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 Natural Gas Fired
Duct Burners.
February 1996
(simple cycle
operation)
March 1998
(combined cycle
operation)
Turbine was
modified Spring
2022 (Triggered
NSPS KKKK)
Dry Low NOx
Burners
&
SCR
T003
005
General Electric Combustion
Turbine, Model No. GE Frame 7FA,
Serial No. 297096, rated at 1,834
MMBtu/hr (turbine 1,412
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 Natural Gas Fired
Duct Burners.
January 1999
(simple cycle
operation)
April 1999
(combined cycle
operation)
Turbine was
modified Fall
2021 (triggered
NSPS KKKK)
Dry Low NOx
Burners
ISO
COLORADO
Air Pollution Control Division
Department of Public Health h Environment
Page 6 of 41
DRAFT
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
Condition
Number
Limitations
Short Term
Limitations
Long Term
Compliance
Emission
Factor
Monitoring
Method
Monitoring
Interval
BACT
Requirements
1.1
N/A
N/A
N/A
See Condition
1.1
See Condition
1.1
NOx
1.2
Simple Cycle Mode or Combined
Cycle Mode — No Supplemental Fuel:
15 ppmvd @ 15%O2 on a 1 -hr
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 for
turbines T002, T003 & T004
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 1 -hr
average
During Combustion Tuning and
Testing (not to exceed 90 hrs/yr for
turbines T002, T003 & T004
combined):
See Short
Term
Limitations,
AIRS Point
004 (Turbine
2) is limited
by 85.01
tons/yr
AIRS Point
005 (Turbine
3) is limited
by 496.1
tons/yr
N/A
Continuous
Emission
Monitoring
System
Continuously
COLORADO
Air Pollution Control Division
Department of Public Health fr Hm onment.
Page 7 of 41
DRAFT
Parameter
Permit
Condition
Number
Limitations
Short Term
Limitations
Long Term
Compliance
Emission
Factor
Monitoring
Method
Monitoring
Interval
100 ppmvd @ 15% O2 on a 1 -hr
average
On and After Modifications
Applies to Both Simple and
Combined Cycle Modes:
15 ppm @ 15% O2, except as
provided for below:
96 ppm @ 15% O2 when operating at
less than 75% of peak load
96 ppm @ 15% O2 when operating at
temperatures less than 0°F
Averaging time is 30 -day rolling.
For periods when multiple standards
apply, the applicable standard is the
average of applicable standards
CO
1.3
Simple Cycle Mode or Combined
Cycle Mode — No Supplemental Fuel:
15 ppmvd @ 15% O2 on a 1 -hr
average, except as provided for
below
During Startup and Shutdown:
1000 ppmvd @ 15% O2 on a 1 -hr
average and 2,060 Ibs/hr
During Combustion Tuning and
Testing (not to exceed 90 hrs/yr for
turbines T002, T003 & T004
combined):
1000 ppmvd @ 15% O2 on a 1 -hr
average and 2,060 Ibs/hr
Combined Cycle Mode — With
Supplemental Fuel:
48 ppmvd @ 15% O2 on a 1 -hr
average, except as provided for
below
During Startup and Shutdown:
1000 ppmvd @ 15% O2 on a 1 -hr
average and 2,060 Ibs/hr
During Combustion Tuning and
Testing (not to exceed 90 hrs/yr for
turbines T002, T003 & T004
combined):
1000 ppmvd @ 15% O2 on a 1 -hr
average and 2,060 Ibs/hr
See Short
Term
Limitations,
Also limited
by 465.4
tons/yr
N/A
Continuous
Emission
Monitoring
System
Continuously
COLORADO
Air Pollution Control Division
Department of Public Health fr. Famronment
Page 8 of 41
DRAFT
Parameter
Permit
Condition
Number
Limitations
Short Term
Limitations
Long Term
Compliance
Emission
Factor
Monitoring
Method
Monitoring
Interval
SO2
1.4
For Each Combustion Turbine:
0.35 Ibs/MMBtu, on a 3 -Hour Rolling
Average
On and After Modifications:
For Each Combustion Turbine and
Duct Burner:
0.06 Ib/MMBtu
See Short
Term
Limitations,
Also limited
by 4.7 tons/yr
N.A
Fuel
Restriction
& Continuous
Monitoring
System
Only Pipeline
Quality
Natural Gas is
Used as fuel
&
Continuously
VOC
1.5
Simple Cycle and Combined Cycle —
No Supplemental Fuel:
1.4 ppmvd @ 15% O2, on a 1 -Hour
Average
Combined Cycle — With
Supplemental Fuel:
1.7 ppmvd @ 15% O2, on a 1 -Hour
Average
See Short
Term
Limitations,
Also limited
by 21.4
tons/yr
N/A
Continuous
Monitoring
System
Continuously
PM
1.6
For Each Combustion Turbine:
0.1 Ibs/MMBtu, the average of three
(3) 1 -hr tests
For Each Combustion Turbine and
Duct Burner Together:
0.1 Ibs/MMBtu, the average of three
(3) 1 -hr tests
See Short
Term
Limitations,
Also limited
by 39.4
tons/yr
See
Condition
1.6
Recordkeeping
Calculation
and
Compliance
Testing
Monthly,
Every Five (5)
Years
PM10
1.7
9 Ibs/hr
39.4 tons/yr
See
Condition
1.7
Recordkeeping
Calculation
and
Compliance
Testing
Monthly,
Every Five (5)
Years
Natural Gas
Usage
1.8
N/A
For AIRS Point
004 (Turbine
002):
10,899.75
MMscf/yr.
For AIRS Point
005 (Turbine
003):
Simple Cycle
and/or
Combined
Cycle Without
Supplemental
Fuel:
N/A
Recordkeeping
Monthly
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Page 9 of 41
DRAFT
Parameter
Permit
Condition
Number
Limitations
Short Term
Limitations
Long Term
Compliance
Emission
Factor
Monitoring
Method
Monitoring
Interval
12,507
M Mscf/yr
Combined
Cycle With
Supplemental
Fuel:
16,090
M Mscf/yr
Sulfur Content
of Natural Gas
1.9
N/A
N/A
N/A
See Condition
1.9
See Condition
1.9
Continuous
Emission
Monitoring
System
Requirements
1.10
N/A
N/A
N/A
See Condition
1.10
See Condition
1.10
Fuel Flow
Meter
1.11
N/A
N/A
N/A
See Condition
1.11
See Condition
1.11
NSPS General
Provisions
1.12
N/A
N/A
N/A
As Required
by NSPS
General
Provisions
As Required
by NSPS
General
Provisions
Performance
Test
Requirements
1.13
N/A
N/A
N/A
EPA Reference
Method
See Condition
1.13
Opacity— State
Only
1.14
Not to Exceed 20%
See Short
Term
Limitations
N/A
Fuel
Restriction
Only Pipeline
Quality
Natural Gas is
Used as Fuel
Opacity
1.15
Not to Exceed 20% Except as
Provided for in 1.16 Below
See Short
Term
Limitations
N/A
Fuel
Restriction
Only Pipeline
Quality
Natural Gas is
Used as Fuel
Opacity
1.16
For Certain Operational Activities —
Not to Exceed 30%, for a Period of
Periods Aggregating More than Six
(6) Minutes in any 60 Consecutive
Minutes
See Short
Term
Limitations
N/A
Fuel
Restriction
Only Pipeline
Quality
Natural Gas is
Used as Fuel
Regulation No.
26, Part B,
Section II.A
Requirements
1.17
NOX Emissions from Each Turbine
Not to Exceed:
When burning natural gas (NG): 15
ppm @ 15% O2
When operating at < 75% peak load:
96 ppm @ 15% O2
When operating at temperatures <
0°F: 96 ppm @ 15% O2
See Short
Term
Limitations
N/A
Continuous
Emission
Monitoring
System for
Nox Emission
&
Calculation
&
See Condition
1.18
Continuously
For NOx
Emissions and
Annually
(Calendar
Year) for
Maintain
Records of
Capacity
Factor
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Page 10 of 41
DRAFT
Parameter
Permit
Condition
Number
Limitations
Short Term
Limitations
Long Term
Compliance
Emission
Factor
Monitoring
Method
Monitoring
Interval
Compliance is based on a 30 -day
rolling average as noted in Condition
1.18.3.1.d
Maintain Records of Capacity Factor
Combustion Process Adjustment and
Recordkeeping Requirements
NSPS Subpart
KKKK General
Requirements
1.18
See Condition 1.19
See Short
Term
Limitations
N/A
See Condition
1.19
See Condition
1.19
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. 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
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
1.1.1.4 BACT for PM and PM10 has been determined to be use of pipeline
quality natural gas.
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: 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.
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Page 11 of 41
DRAFT
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 turbines T002, T003 and T004 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 this turbine begins when fuel is first
combusted in the turbine or when commencing a combined cycle startup from
simple cycle operation (turbine drops out of L30 -Out combustion configuration)
and ends 30 minutes after the turbine clears L30 -Out. L30 -Out refers to the
condition where the unit is operating above the emissions compliance
combustion reference temperature (CRT) curve and the L52G breaker is closed.
The station control system and the 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 L30 -Out combustion
configuration plus 30 minutes is achieved is stored in the 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.
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 1.2.1.10, 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 one -flour average NOX
concentration in accordance with the requirements in 40 CFR Part 75 and
Condition 5.2.1.3.b of this permit. Data used to generate the one -hour average
NOX concentration shall not include replaced data, nor shall the data be bias -
adjusted. Replaced data shall be reported as monitor down time in the quarterly
reports required by Condition 5.5. 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.
COLORADO
Air Pollution Control Division
Department of Puhlk Health ft Environment
Page 12 of 41
DRAFT
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 in accordance with the requirements
in 40 CFR Part 75 and Condition 5.2.1.3.b of this permit.
Data used to generate the average NOX concentration shall not include replaced
data, nor shall the data be bias -adjusted. Replaced data shall be reported as
monitor down time in the quarterly reports required by Condition 5.5. Each
clock hour average NOX concentration shall be compared to the limitation in
Condition 1.2.1.3.
In the event that the startup ends within a clock hour or the shutdown begins
within a clock hour, all non -startup and/or non -shutdown concentration (ppm)
data points within that clock hour shall be averaged together to generate the
average NOX concentration in accordance with the requirements in 40 CFR Part
75 and Condition 5.2.1.3.b of this permit 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.
1.2.1.11 The emission limitation in Condition 1.2.1.2 applies to any clock hour in which
fuel is fired in the duct burner.
1.2.2 For purposes of 40 CFR Part 60 Subpart KKKK, NOX emissions from each combustion
turbine/HRSG/duct burner are subject to the following requirements:
The requirements in this Condition 1.2.2, as well as Conditions 1.4.4 and 1.19 reflect the
rule language in 40 CFR Part 60 Subpart KKKK as of the latest revisions to 40 CFR Part 60
Subpart KKKK published in the Federal Register on March 20, 2009 (including the
revisions to test methods published October 7, 2020). However, if revisions to this
Subpart are promulgated at a later date, the owner or operator is subject to the
requirements contained in the revised version of 40 CFR Part 60 Subpart KKKK.
Please note that proposed revisions to 40 CFR Part 63 Subpart KKKK were published in
the Federal Register on August 29, 2012 to address a petition for reconsideration filed
by the Utility Air Regulatory Group (UARG) on September 5, 2006 regarding the July
2006 final rule and to address other technical and editorial issues. Therefore, the
requirements below may change in the future.
You must meet the emission limits for NOX specified in Table 1 to this subpart. (§
60.4320(a)). The requirements in Table 1 that apply to these units are as follows:
1.2.2.1 Except as provided for below, NOX emissions shall not exceed 15 ppm at
15 % O2.
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Page 13 of 41
DRAFT
1.2.2.2 When operating at less than 75% of the peak load, NOX emissions shall
not exceed 96 ppm at 15% O2.
1.2.2.3 When operating at temperatures less than on 0 °F, NOX emissions shall
not exceed 96 ppm at 15% O2.
1.2.2.4 For operating periods during which multiple emissions standards apply,
the applicable standard is the average of the applicable standards
during each hour. For hours with multiple emissions standards, the
applicable limit for that hour is determined based on the condition that
corresponded to the highest emissions standard. (§ 60.4380(b)(3))
Note that the NOX emission limits in this Condition 1.2.2 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.
Compliance with the above NSPS KKKK NOX emission shall be monitored using the
continuous emission monitoring systems (CEMS) required by Condition 1.10, as follows:
1.2.2.5 All CEMS data must be reduced to hourly averages as specified in
§60.13(h). (60.4350(a))
1.2.2.6 For each unit operating hour in which a valid hourly average, as
described in §60.4345(b), is obtained for both NOX and diluent
monitors, the data acquisition and handling system must calculate and
record the hourly NOX emission rate in units of ppm or Ib/MMBtu, using
the appropriate equation from method 19 in appendix A of this part. For
any hour in which the hourly average O2 concentration exceeds 19.0
percent O2 (or the hourly average C02 concentration is less than 1.0
percent C02), a diluent cap value of 19.0 percent O2 or 1.0 percent C02
(as applicable) may be used in the emission calculations. (60.4350(b))
1.2.2.7 If you have installed and certified a NOX diluent CEMS to meet the
requirements of part 75 of this chapter, states can approve that only
quality assured data from the CEMS shall be used to identify excess
emissions under this subpart. Periods where the missing data
substitution procedures in subpart D of part 75 are applied are to be
reported as monitor downtime in the excess emissions and monitoring
performance report required under §60.7(c). (60.4350(d))
1.2.2.8 Calculate the hourly average NOX emission rates, in units of the
emission standards under §60.4320, using either ppm for units
complying with the concentration limit or the equations in §60.4350(f)
for units complying with the output based standard. (60.4350(f))
SG
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Page 14 of 41
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1.2.2.9 For combined cycle and combined heat and power units with heat
recovery, use the calculated hourly average emission rates from
60.4350(f) to assess excess emissions on a 30 unit operating day rolling
average basis, as described in §60.4380(b)(1). (60.4350(h))
1.2.2.10 Further provisions regarding reporting excess emissions are provided for
in Condition 5.6.3.
Initial Performance Test Requirements
1.2.2.11 If you elect to install a CEMS, the performance evaluation of the CEMS
may either be conducted separately or (as described in §60.4405) as
part of the initial performance test of the affected unit. (60.4400(b)(5))
1.2.2.12 If you elect to install and certify a NOX-diluent CEMS under §60.4345,
then the initial performance test required under §60.8 may be
performed in the following alternative manner (60.4405): a. Perform a
minimum of nine RATA reference method runs, with a minimum time
per run of 21 minutes, at a single load level, within plus or minus 25
percent of 100 percent of peak load. The ambient temperature must be
greater than 0 °F during the RATA runs. (60.4405(a))
b. For each RATA run, concurrently measure the heat input to the
unit using a fuel flow meter (or flow meters) and measure the
electrical and thermal output from the unit. (60.4405(b))
c. Use the test data both to demonstrate compliance with the
applicable NOX emission limit under §60.4320 and to provide
the required reference method data for the RATA of the CEMS
described under §60.4335. (60.4405(c))
d. Compliance with the applicable emission limit in §60.4320 is
achieved if the arithmetic average of all of the NOX emission
rates for the RATA runs, expressed in units of ppm or Ib/MWh,
does not exceed the emission limit. (60.4405(d))
1.2.3 Nitrogen Oxide (NOX) emissions from AIRS point 004 (T002) shall not
exceed 85.01 tons/yr while Nitrogen Oxide (NOX) emissions from AIRS
point 005 (T003) shall not exceed 496.1 tons/yr. Compliance with
annual emission limitation shall be monitored using the Continuous
Emission Monitoring System (CEMS) required by Condition 1.10. For any
hour in which fuel is combusted in the turbines, including periods of
startup, shutdown and malfunction, the permittee shall program the
DAHs to calculate lb/hr NOX emissions in accordance with the
requirements in Condition 5.2.1.3.b of this permit and 40 CFR Part 75,
including any replaced data and the data shall be bias -adjusted, if
warranted.
Ate
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Page 15 of 41
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For AIRS point 004 (T002), the rolling twelve (12) -month emission total
for compliance with annual process limits shall be restarted post SCR
installation and operation. Therefore, SCR installation and operation will
mark the separation of the previous rolling twelve (12) -month emission
total record and will begin a new rolling twelve (12) -month emission
total. The previous rolling twelve (12) -month emission total will not
include any months post SCR installation and operation. Historical
records of pre -SCR emission records must still be maintained to ensure
compliance with previous emission limits that were pre -SCR installation
and operation.
Airs Point 004 shall have an SCR (selective catalytic reduction) to reduce
the NOX emissions. The SCR must be maintained and operated to
ensure satisfactory performance. The owner or operator must monitor
compliance with this condition through the results of approved
compliance tests (when required), compliance with the Operating and
Maintenance Plan, compliance records, and other methods as approved
by the Division. (Reference: Regulation Number 3, Part B, Section III.E.)
Specifically hourly mass NOX emissions (in lb/hr) shall be calculated by
multiplying the hourly NOX Ib/MMBtu value (which includes replaced or
bias -adjusted data, as applicable) by the hourly heat input value
(MMBtu/hr) (which includes replaced data from the fuel flow
measurement, as applicable). The hourly NOX Ib/MMBtu and heat input
values shall be determined using equations F-5 or F-6, as appropriate for
the diluent monitored by the CEMS and F-20 in Appendix F of 40 CFR
Part 75. The resulting NOX lb/hr value is then multiplied by the unit
operating time for that hour to produce a NOX Ibs value. Hourly NOX
mass emissions (lbs) shall be summed and divided by 2000 lb/ton to
determine monthly NOX emissions (in tons).
Monthly emissions (in tons) from each combustion turbine/HRSG/duct
burner shall be used in a twelve month rolling total of emissions to
monitor compliance with the annual emission limitation. Each month a
new twelve month total shall be calculated using the previous twelve
months 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:
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.
�4
COLORADO
Air Pollution Control Division
Department of Pal. He. b Environment
Page 16 of 41
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1.3.1.2 Except as provided for in Conditions 1.3.1.3 and 1.3.1.4 below,
emissions 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 Ibs/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 Ibs/hr and not a violation if emissions are less than or
equal to 2,060 Ibs/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
Ibs/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 Ibs/hr and not a violation if emissions are less
than or equal to 2,060 Ibs/hr. Use of this CO emission limit for purposes
of combustion tuning and testing shall not exceed 90 hours in any
calendar year for turbines T002, T003 and T004 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 definitions as provided for in Conditions
1.2.1.5 and 1.2.1.6.
1.3.1.6 "Shutdown" shall have the same definition as provided for in Condition
1.2.1.7.
1.3.1.7 "Combustion Tuning and Testing" shall have the same definition as
provided for in Condition 1.2.1.8.
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 in accordance with the requirements in 40 CFR Part 75
and Condition 5.2.1.3.b of this permit. Data used to generate the one -
hour average CO concentration shall not include replaced data.
Replaced data shall be reported as monitor down time in the quarterly
reports required by Condition 5.5. 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.
COLORADO
Air Pollution Control Division
Department of Public Health 6 Emnronment
Page 17 of 41
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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 in accordance
with the requirements in 40 CFR Part 75 and Condition 5.2.1.3.b of this
permit. Data used to generate the average CO concentration shall not
include replaced data. Replaced data shall be reported as monitor down
time in the quarterly reports required by Condition 5.5. 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
(ppm) data points within that clock hour shall be averaged together to
generate the average CO concentration in accordance with the
requirements in 40 CFR Part 75 and Condition 5.2.1.3.b of this permit
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.
1.3.1.11 The emission limitation in Condition 1.3.1.2 applies to any clock hour in
which fuel is fired in the duct burner.
1.3.2 Carbon Monoxide (CO) emissions from each combustion turbine/HRSG/duct
burner shall not exceed 465.4 tons/yr. Compliance with this requirement shall
be monitored using the Continuous Emission Monitoring System (CEMS)
required by Condition 1.10. For any hour in which fuel is combusted in the
turbines, including periods of startup, shutdown and malfunction, the permittee
shall program the DAHs to calculate lb/hr CO emissions in accordance with the
requirements in Condition 5.2.1.3.b of this permit and 40 CFR Part 75, including
any replaced data, if warranted.
Specifically hourly mass CO emissions (in lb/hr) shall be calculated by
multiplying the hourly CO Ib/MMBtu value (which includes replaced date in
accordance with the provisions in Part 75 for NOX replacement, as applicable)
by the hourly heat input value (MMBtu/hr) (which indudes replaced data from
the stack flow measurement, as applicable). The hourly CO Ib/MMBtu and heat
input values shall be determined using equations F-5 or F-6 (for NOX), as
appropriate for the diluent monitored by the CEMS and F-20 in Appendix F of 40
CFR Part 75. The resulting CO lb/hr value is then multiplied by the unit operating
time for that hour to produce a CO Ibs value. Hourly CO mass emissions (lbs)
shall be summed and divided by 2000 lb/ton to determine monthly CO
emissions (in tons).
Monthly emission (in tons) from each combustion turbine/HRSG/duct burner
shall be used in a twelve month rolling total of emissions will be maintained to
COLORADO
Air Pollution Control Division
Department of Public Health 6 Enwonment
Page 18 of 41
DRAFT
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 (S02) emissions shall not exceed the following limitations:
1.4.1 Sulfur Dioxide (S02) emissions from each combustion turbine shall not exceed
0.35 Ibs/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.
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.
1.4.4 For purposes of 40 CFR Part 60 Subpart KKKK, the combustion
turbine/HRSG/duct burner is subject to the following requirements:
If your turbine is located in a continental area, you must comply with either
60.4330(a)(1), (a)(2), or (a)(3). (60.4330(a))
You must not burn in the subject stationary combustion turbine any fuel which
contains total potential sulfur emissions in excess of 26 ng S02/J (0.060 lb
S02/MMBtu) heat input. If your turbine simultaneously fires multiple fuels, each
fuel must meet this requirement. (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 permitted
to be used as fuel in the turbine. The natural gas used as fuel shall meet the
requirements in Condition 1.9.
1.4.5 Sulfur Dioxide (S02) emissions from each combustion turbine/HRSG/duct
burner shall not exceed 4.7 tons/yr. 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:
tag
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Page 19 of 41
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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 operatitg 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 emission limits in Condition 1.5.1.2 apply to
any clock hour in which fuel is fired in the duct burner. The equations used in
the VOC correlation are included in Appendix G of this permit.
1.5.2 Volatile Organic Compounds emissions from each combustion
turbine/HRSG/duct burner shall not exceed 21.4 tons/yr. 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 G 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 Ibs/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 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 Ibs/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:
a to
COLORADO
Air Pollution Control Division
Department of Public Health b Emnronmenc
Page 20 of 41
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PE (turbine + duct burner) = PET x FIT+ PEDB x FIDB
FIT+ FIDB
Where PE = particulate standard in Ibs/MMBtu
PEDB = 0.5 x (F0-0.26 Ibs/MMBtu
PET = 0.1 Ibs/MMBtu
Fl = fuel input in MMBtu/hr
1.6.3 Particulate Matter (PM) emissions from each combustion turbine/HRSG/duct
burner shall not exceed 39.4 tons/yr. The annual emission limitation includes
both filterable and condensable particulate matter. Compliance with this
limitation shall be monitored as follows:
1.6.3.1 Monthly emissions of PM shall be calculated using the emission factors
identified in the table below in the following equation:
Unit
Emission Factor
(Ib/MMBtu) for PM
Emission Factor
(Ib/MMBtu) for PM10
Source of Emission
Factor
Unit 2 —Simple Cycle
0.003
0.003
February 28, 2019
Unit 2 —Combined
Cycle
0.004
0.004
February 26 & 27, 2019
Unit 3- Simple Cycle
0.002
0.002
March 6, 2019
Unit 3 — Combined
Cycle
0.002
0.002
March 5. 2019
Tons/month = (EF (Ibs/MMBtu) x monthly heat input to turbine (MMBtu/mo)l
2000 Ibs/to n
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.
1.6.3.2 Performance testing shall be conducted in accordance with the
requirements in Condition 1.13.
1.7 Particulate Matter less than 10 microns (PM10) emissions from each combustion
turbine/HRSG/duct burner shall not exceed 9 Ibs/hr and 39.4 tons/yr. The hourly and annual
emission limitations include both filterable and condensable particulate matter. Compliance
with these limitations shall be monitored as follows:
1.7.1 Monthly emissions of PM10 shall be calculated using the emission factors
identified in the table in Condition 1.6.3.1 in the following equation:
Tons/month = (EF (Ibs/MMBtu) x monthly heat input to turbine (MMBtu/mo)l
COLORADO
Air Pollution Control Division
Department of Pub. Health b Environment.
Page 21 of 41
DRAFT
2000 Ibs/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 1.13.
1.8 Natural Gas Consumption for each T002 (AIRS 004) turbine/HRSG/duct burner shall not exceed
the following limitations:
1.8.1 The total fuel consumption shall not exceed exceed 10,889.75 MMscf/yr.
Natural Gas Consumption for each T003 (AIRS 005) turbine/HRSG/duct burner shall not exceed
the following limitations:
1.8.2 When operating in either simple cycle mode or combined cycle mode without
supplemental fuel natural gas consumption shall not exceed 12,507 MMscf/yr.
1.8.3 When operating in combined cycle mode with supplemental fuel natural gas
consumption shall not exceed 16,090 MMscf/yr.
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 for T003 (AIRS 005),
while the 10,889.75 MMscf/yr natural gas consumption limit shall continue to apply for T002
(AIRS 004). 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, certified, calibrated, maintained and operated for measuring NOX
(including diluent gas either C02 or O2) and CO emissions. The CEMS shall meet the
COLORADO
Air Pollution Control Division
Department of Public Health b Ermronment
Page 22 of 41
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requirements in Condition 5 of this permit. Monthly emissions of NOX and CO from the
continuous emission monitoring system shall be used as specified by Conditions 1.2.3 and 1.3.2
to monitor compliance with the annual NOX and CO emission limitations.
1.11 Each turbine/HRSG/duct burner shall be equipped with an in -line fuel flow meter that meets
the requirements in 40 CFR Part 75 Appendix D to measure fuel combusted in each turbine. Fuel
flow data shall be recorded on a data acquisition and handling system as specified in 40 CFR Part
75 Appendix D.
1.12 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:
1.12.1 No owner or operator subject to the provisions of this part shall build, erect,
install, or use any article, machine, equipment or process, the use of which
conceals 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.
1.12.2 At all times, including periods of startup, shutdown, and malfunction owners
and operators shall to the extent practicable, maintain and operate any affected
facility including associated air pollution control equipment in a manner
consistent with good air pollution control practice for minimizing emissions.
Determination of whether acceptable operating and maintenance procedures
are being used will be based on information available to the Division which may
include, but is not limited to monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection of the source.
1.13 The source shall conduct compliance 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 PM10 emission limitations in Conditions
1.6.3 and 1.7. The compliance tests 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 compliance tests for these units were completed as follows:
Unit
Source of Emission
Factor
Unit 2 —Simple Cycle
February 28, 2019
Unit 2 — Combined
February 26 & 27, 2019
Cycle
Unit 3- Simple Cycle
March 6, 2019
Unit 3 — Combined
March 5. 2019
Cycle
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Page 23 of 41
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The compliance test must be conducted in accordance with the APCD Compliance Test Manual
(as updated and amended by the Division, see at https://cdphe.colorado.gov/compliance-and-
enforcement), including deadlines for preparation and submittal of the protocol for Division
review and approval and for submittal of the test report. All compliance testing must be
approved by the Division prior to conducting the test.
1.14 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 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 Except as provided for in Condition 1.16 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.
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 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.
1.17 The turbines and duct burners are subject to the requirements in Colorado Regulation No. 26,
Part B, Section II.A as follows:
Note that the language below is from Colorado Regulation No. 26, adopted by the Colorado Air
Quality Control Commissions (AQCC) on December 2, 2024 (effective February 14, 2025).
However, if revisions to Colorado Regulation No. 26, Part B, Section II.A are published at a later
date, the owner or operator is subject to the requirements contained in the revised version of
Section II.A.
1.18.1 Applicability (Regulation No. 26, Part B, Section II.A.1)
1.18.1.1 Except as provided in Section II.A.2., the requirements of this Section II.
apply to owners and operators of any stationary combustion equipment
that existed at a major source of NOx (greater than or equal to 100 tpy
NOx) as of June 3, 2016, located in the 8 -Hour Ozone Control Area.
(Regulation No. 26, Part E, Section II.A.1.a)
1.18.2 Exemptions (Regulation No. 26, Part B, Section II.A.2)
COLORADO
Air Pollution Control Division
Department of Pubic Health b Ermronment
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The following stationary combustion equipment are exempt from the emission
limitation requirements of Section II.A.4., the compliance demonstration
requirements in Section II.A.5., and the related recordkeeping and reporting
requirements of Sections II.A.7.a-e. and II.A.B, but these sources must maintain
any and all records necessary to demonstrate that an exemption applies. These
records must be maintained for a minimum of five years and made available to
the Division upon request. Qualifying for an exemption in this section does not
preclude the combustion process adjustment requirements of Section II.A.6.,
when required by II.A.6.a.
Once stationary combustion equipment no longer qualifies for any exemption,
the owner or operator must comply with the applicable requirements of this
Section II.A. as expeditiously as practicable but no later than 36 months after
any exemption no longer applies. Additionally, once stationary combustion
equipment that is not equipped with CEMS or CERMS no longer qualifies for any
exemption, the owner or operator must conduct a performance test using EPA
test methods within 180 days and notify the Division of the results and whether
emission controls will be required to comply with the emission limitations of
Section II.A.4. (Regulation No. 26, Part B, Section II.A.2)
1.18.2.1 Any stationary combustion equipment whose utilization is less
than 10% of its capacity factor on an annual average basis over
a 3 -year rolling period for stationary combustion turbines and
compression ignition reciprocating internal combustion engines.
(Regulation No. 26, Part B, Section II.A.2.a.(ii))
1.18.2.2 Any stationary combustion equipment with total uncontrolled
actual emissions less than 5 tpy NOx on a calendar year basis.
(Regulation No. 26, Part B, Section II.A.2.d)
1.18.3 Emission Limitations (Regulation No.26, Part B, Section II.A.4)
By October 1, 2021, no owner or operator of stationary combustion equipment
specified in Section II.A.1.a. may cause, allow, or permit NOx to be emitted in
excess of the following emission limitations. When demonstrating compliance
using continuous emissions monitoring pursuant to Section II.A.5.c.(i), the
following emission limitations are on a 30 -day rolling average basis, unless
otherwise specified. (Regulation No. 26, Part B, Section II.A.4. 1st paragraph)
1.18.3.1 Stationary combustion turbines with a maximum design heat
input capacity equal to or greater than 10 MMBtu/hr and which
commenced construction on or before February 18, 2005 must
comply with the following NOx emission limits (Regulation No.
26, Part B, Section II.A.4.b.(i))
a. 15 ppm at 15 percent O2 or 54 ng/J of useful output
(0.43 Ib/MWh).
COLORADO
Air Poilution Control Division
Department of Public Health b Environment
Page 25 of 41
DRAFT
b. Turbines operating at less than 75 percent of peak load
96 ppm at 15 percent O2 or 590 ng/1 of useful output
(4.7 Ib/MWh).
c. Turbines operating at temperatures less than 0 °F 96
ppm at 15 percent O2 or 590 ng/J of useful output (4.7
Ib/MWh).
d. For units with heat recovery and CEMS, determine
compliance on a 30 -day rolling average. (Regulation No.
26, Part B, Section II.A.4.b.(i)(A))
e. For operating periods during which multiple emissions
standards apply, the applicable standard is the average
of the applicable standards during each hour. For hours
with multiple emissions standards, the applicable limit
for that hour is determined based on the condition that
corresponded to the highest emissions standard.
(Regulation No. 26, Part B, Section II.A.4.b.(i)(C))
f. Emissions exceeding the NOx emission limits in Section
II.A.4.b.(i) at any time, including during times of startup,
shutdown, malfunction, fuel switching, tuning, and
testing must be reported as specified in Section
II.A.8.a.(i). (Regulation No. 26, Part B, Section
II.A.4.b.(i)(D))
1.18.3.2 Stationary combustion turbines subject to the categorical limits
in Section II.A.4.b.(i) or (ii) (Condition 1.18.3.1) above and
stationary combustion turbines with a maximum design heat
input capacity less than 10 MMBtu/hr must comply with the
combustion process adjustment requirements contained in
Section II.A.6. while burning gaseous fuel, liquid fuel, or any
combination thereof, when required by Section II.A.6.a.
(Regulation No. 26, Part B, Section II.A.4.b.(iii))
1.18.4 Compliance (Regulation No. 26, Part B, Section II.A.5) 1.18.4.1 By
October 1, 2021, for stationary combustion equipment that existed at a
major source of NOx (greater than or equal to 100 tpy NOx) as of June 3,
2016, the owner or operator of an affected unit must determine
compliance with the applicable emission limitations contained in
Section II.A.4. according to the applicable methods contained in this
Section II.A.5. (Regulation NO. 26, Part B, Section II.A.5.a)
1.18.4.2 Compliance with the NOX limits in Condition 1.18.3.1 shall be
monitored using the NOX CEMS required by Condition 1.10.
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Page 26 of 41
L DRAFT J
1.18.5 The combustion process adjustment and associated recordkeeping
requirements in Condition 10 apply to any turbine or duct burner with
actual, uncontrolled emissions equal to or greater than 5 tons per year
of NOX. (Colorado Regulation No. 26, Part B, Section II.A.6.a.(i))
1.18.6 Recordkeeping. (Regulation No. 26, Part B, Section II.A.7)
The following records must be kept for a period of five years and made
available to the Division upon request (Regulation No, 26, Part B,
Section II.A.7):
1.18.6.1 The stationary combustion equipment's (turbines) annual
capacity factor on a calendar year basis. (Regulation No. 26, Part
B, Section II.A.7.d)
1.18.6.2 All sources qualifying for an exemption under Section II.A.2.
must maintain all records necessary to demonstrate that an
exemption applies. (Regulation No. 26, Part B, Section II.A.7.g)
1.18 You must operate and maintain your stationary combustion turbine, air pollution control
equipment, and monitoring equipment in a manner consistent with good air pollution control
practices for minimizing emissions at all times including during startup, shutdown, and
malfunction. (60.4333(a))
COLORADO
Air Pollution Control Division
Department of PuCdc Health b Environment.
Page 27 of 41
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2. Continuous Emission Monitoring Systems (CEMS)
The following requirements apply to the NOX, CO and diluent (either O2 or C02) continuous
emission monitoring systems (CEMS) required by Conditions 1.10, 2.8 and 8.10.
2.1 Monitoring Requirements
For each turbine (i.e., combustion turbine or combustion turbine/HRSG/duct burner), a
continuous emission monitoring system shall be installed, calibrated, and operated on
the exhaust stack to determine and record the following.
2.1.1 Concentration of Oxides of Nitrogen; ppmvd corrected to 15% O2,
hourly average and 24 -hour average (Turbine 4 only), in the exhaust;
2.1.2 Emissions of Oxides of Nitrogen; tons/month, rolling twelve month;
2.1.3 Concentration of Carbon Monoxide; ppmvd corrected to 15% O2, hourly
average, in the exhaust;
2.1.4 Emissions of Carbon Monoxide; Ibs/hr, tons/month, rolling twelve
month;
2.1.5 Average combustion turbine load;
2.1.6 Load at which steam turbine is operating; and
2.1.7 Operating mode — startup, shutdown and/or standard operation.
2.2 Equipment and QA/QC Requirements
2.2.1 The Continuous Emission Monitoring Systems are subject to the
following requirements:
2.2.1.1 Except as provided for below, the CO monitors are subject to
the applicable requirements of 40 CFR Part 60. The monitoring
systems shall meet the equipment, installation and
performance specifications of 40 CFR Part 60 Appendix B,
Performance Specification 4/4A. These CEMS are subject to the
quality assurance/quality control requirements in 40 CFR Part
60 Appendix F and Subpart A § 60.13 and Condition 5.2.1.3 of
this permit.
a. The CO CEMS data shall meet the applicable "primary
equipment hourly operating requirements" for hourly
average calculation methodology specified in 40 CFR
Part 75 Subpart B § 75.10(d).
b. Annual CO monitor relative accuracy (RA) testing will be
performed in ppm @ 15% O2 measurement units, and
COPHE
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Page 28 of 41
DRAFT
will be performed according to 40 CFR Part 60,
Appendix B, Performance Specification 4A.
c. Relative accuracy test audit (RATA) frequency will be
determined according to 40 CFR Part 75 Appendix B.
2.2.1.2 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
Condition 5.2.1.3 of this permit.
2.2.1.3 The NOX and CO CEMS are subject to the following
requirements:
Relative Accuracy Test Audits (RATAs): RATAs shall be
conducted in the units (e.g., Ib/MMBtu, ppm) of the
emission limitation for all of the emission limitations
that are applicable to the emissions unit. The RATAs for
emissions units that have annual emission limitations
(tons/yr) will be conducted in terms of pounds per hour
(lb/hr).
b. The DAHS shall be able to record and manipulate the
data in the units (e.g., Ib/MMBtu, ppm) of the emission
limitation and meet the reporting requirements for all
for the emissions limitations that are applicable to the
emissions unit.
2.2.2 Quality assurance/quality control plans shall be prepared for the
continuous emission monitoring systems as follows: 5.2.2.1 The quality
assurance/quality control plan for the CO monitors shall be prepared in
accordance with the applicable requirements in 40 CFR Part 60,
Appendix F, except that gas cylinder audit (GCA) testing is not required
during quarters with less than 168 hours of operating time.
2.2.2.2 The quality assurance /quality control plan for the NOX (and
diluent) monitors shall be prepared in accordance with the
applicable requirements in 40 CFR Part 75, Appendix B.
The quality assurance/quality control plans shall be made available to the
Division upon request. Revisions shall be made to the plans at the request of the
Division.
COLORADO
Air Pollution Control Division
Department of Public Health 6 DIVOOnntertt
Page 29 of 41
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2.3 General Provisions
2.3.1 NOX (and diluent) monitors: The permittee shall ensure that all
continuous emission monitoring systems required are in operation and
monitoring unit emissions at all times that the 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)).
2.3.2 CO monitors: Except for system breakdowns, repairs, calibration checks,
and zero and span adjustments required under § 60.13(d), all
continuous monitoring systems shall be in continuous operation and
shall meet minimum frequency of operation requirements as set forth
in § 60.13(e)(2). (40 CFR Part 60 Subpart A § 60.13(e)).
2.3.3 Alternative monitoring systems, alternative reference methods, or any
other alternatives for the required continuous emission monitoring
systems shall not be used without having obtained prior written
approval from the appropriate agency, either the Division or the U.S.
EPA, depending on which agency is authorized to approve such
alternative under applicable law. Any alternative continuous emission
monitoring systems must be certified in accordance with the
requirements of 40 CFR Part 75 prior to use.
2.3.4 All test and monitoring equipment, methods, procedures and reporting
shall be subject to the review and approval by the appropriate agency,
either the Division or the U.S. EPA, depending on which agency is
authorized to approve such 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.
2.3.5 A file suitable for inspection shall be maintained of all measurements,
including continuous monitoring system, monitoring device, and
performance testing measurements; all continuous monitoring system
performance evaluations; all continuous monitoring system or
monitoring device calibration checks; adjustments and maintenance
performed on these systems or devices; and all other information
required by applicable portions of 40 CFR Part 60 Subpart A and
Appendices B and F and 40 CFR Part 75.
2.3.6 Records shall be maintained of the occurrence and duration of any
startup, shutdown, or malfunction in the operation of the source; any
malfunction of the air pollution control equipment; or any periods
COLORADO
Air Pollution Control Division
Department of Pubt. Health b Enwonment
Page 30 of 41
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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).
2.4 Data Replacement Requirements
For periods when quality assured data is not available from the continuous
emission monitoring systems the data replacement procedures in 40 CFR Part
75 Subpart D shall be used for determining the total (annual) emissions.
Although 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. For purposes of monitoring compliance with the annual
emission limitations (tons/yr) replaced and bias -adjusted data shall be included
when assessing compliance with the annual limitations. Note that since CO
emissions are not subject to requirements in 40 CFR Part 75 the CO emission
data is not required to be bias -adjusted.
2.5 Recordkeeping and Reporting Requirements
2.5.1 Each owner or operator required to install a continuous monitoring
device shall submit excess emissions and monitoring systems
performance report (excess emissions are defined in applicable subparts
and this permit) and/or summary report form (see Condition 5.5.2) to
the Division quarterly. All reports shall be postmarked by the 30th day
following the end of each calendar quarter. (§ 60.7(c), revised to
stipulate quarterly reporting. Written reports of excess emissions shall
include the following information: 5.5.1.1 The magnitude of excess
emissions computed in accordance with 40 CFR Part 60 Subpart A §
60.13(h) and Division guidelines, as applicable, 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. (§ 60.7(c)(1))
2.5.1.2 Specific identification of each period of excess emissions that
occurs during startups, shutdowns, and malfunctions of the
affected facility. The nature and cause of any malfunction (if
known), the corrective action taken or preventative measures
adopted. (§ 60.7(c)(2))
2.5.1.3 The date and time identifying each period during which the
continuous monitoring system was inoperative except for zero
and span checks and the nature of the system repairs or
adjustments (§ 60.7(c)(3)).
2.5.1.4 When no excess emissions have occurred or the continuous
monitoring system(s) have not been inoperative, repaired, or
48
COLORADO
Air Pollution Control Division
Department of public Health & Emnronment
Page 31 of 41
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adjusted, such information shall be stated in the report (§
60.7(c)(4)).
2.5.2 The summary report form shall contain the information and be in the
format shown in figure 1 of § 60.7 unless otherwise specified by the
Division. One summary report form shall be submitted for each
pollutant monitored at each affected facility. (§ 60.7(d))
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
CMS downtime for the reporting period is less than 5 percent of the
total operating time for the reporting period, only the summary report
form shall be submitted and the excess emission report described in
Condition 5.5.1 need not be submitted unless requested by the Division.
(§ 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. (§ 60.7(d)(2))
2.6 Specific Provisions for NSPS Subpart KKKK
The requirements in this Condition 5.6 reflect the rule language in 40 CFR Part
60 Subpart KKKK as of the latest revisions to 40 CFR Part 60 Subpart KKKK
published in the Federal Register on March 20, 2009. However, if revisions to
this Subpart are promulgated at a later date, the owner or operator is subject to
the requirements contained in the revised version of 40 CFR Part 60 Subpart
KKKK.
Please note that proposed revisions to 40 CFR Part 63 Subpart KKKK were
published in the Federal Register on August 29, 2012 to address a petition for
reconsideration filed by the Utility Air Regulatory Group (UARG) on September
5, 2006 regarding the July 2006 final rule and to address other technical and
editorial issues. Therefore, the requirements below may change in the future.
2.6.1 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 Ib/MMBtu basis.
2.6.2 As specified in 40 CFR Part 60 Subpart KKKK § 60.4350(d) (Conditions
2.5.2.7 and 8.2.2.7) and approved by the Division, only quality assured
data from the CEMS shall be used to identify 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.
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Page 32 of 41
DRAFT
2.6.3 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 An excess emissions is any unit operating
period in which the 4 -hour or 30 -day rolling average NOX emission rate
exceeds the applicable emission limit in §60.4320. For the purposes of
this subpart, a "4 -hour rolling average NOX emission rate" is the
arithmetic average of the average NOX emission rate in ppm or ng/J
(Ib/MWh) measured by the continuous emission monitoring equipment
for a given hour and the three unit operating hour average NOX
emission rates immediately preceding that unit operating hour.
Calculate the rolling average if a valid NOX emission rate is obtained for
at least 3 of the 4 hours. For the purposes of this subpart, a "30 -day
rolling average NOX emission rate" is the arithmetic average of all
hourly NOX emission data in ppm or ng/J (Ib/MWh) measured by the
continuous emission monitoring equipment for a given day and the
twenty-nine unit operating days immediately preceding that unit
operating day. A new 30 -day average is calculated each unit operating
day as the average of all hourly NOX emissions rates for the preceding
30 unit operating days if a valid NOX emission rate is obtained for at
least 75 percent of all operating hours. (§ 60.4380(b)(1))
2.6.3.2 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. (§ 60.4380(b)(2))
2.6.3.3 For operating periods during which multiple emissions
standards apply, the applicable standard is the average of the
applicable standards during each hour. For hours with multiple
emissions standards, the applicable limit for that hour is
determined based on the condition that corresponded to the
highest emissions standard. (§ 60.4380(b)(3))
Section III — Additional Requirements & General Conditions
ADDITIONAL REQUIREMENTS
1. All previous versions of this permit are superseded upon issuance of this permit.
2. The permit number and AIRS ID number must be marked on the subject equipment for ease of
identification. (Reference: Regulation Number 3, Part B, Section III.E.) (State -only enforceable)
3. A Revised Air Pollutant Emission Notice (APEN) must be filed: (Reference: Regulation Number
3, Part A, Section II.C.)
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Air Pollution Control Division
Department or Public Health b Ermronment
Page 33 of 41
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a. By April 30 of the year following a significant increase in emissions. A significant
increase in emissions is defined as follows:
For any criteria pollutant:
For sources emitting less than one hundred (100) tons per year, a change in actual
emissions of five (5) tons per year or more, above the level reported on the last APEN
submitted; or
For volatile organic compounds (VOC) and nitrogen oxide (NOx) sources in an ozone
non -attainment area emitting less than one hundred (100) tons of VOC or nitrogen
oxides per year, a change in actual emissions of one (1) ton per year or more or five
percent (5%), whichever is greater, above the level reported on the last APEN
submitted; or
For sources emitting one hundred (100) tons per year or more of a criteria pollutant, a
change in actual emissions of five percent (5%) or fifty (50) tons per year or more,
whichever is less, above the level reported on the last APEN submitted; or
For sources emitting any amount of lead, a change in actual emissions, above the level
reported on the last APEN submitted, of fifty (50) pounds of lead
For any non -criteria reportable pollutant:
If the emissions increase by fifty percent (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.
c. Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment.
d. Whenever a permit limitation must be modified.
e. No later than thirty (30) days before the existing APEN expires.
4. The permit holder must construct and maintain exhaust stack heights as listed in the table
below.
Facility
Equipment ID
AIRS
Point
Minimum stack height
above ground level (m)
T007
014
30.48
T008
015
30.48
T002_CC
004
53.34
T002_SC
004
31.7
T003_CC
005
53.34
T003_SC
005
31.7
T004_CC
008
53.34
T004_SC
008
31.7
T005
010
41.15
T006
011
41.15
AUXBLR
001
31.09
COLORADO
Air Pollution Control Division
Department of Public Heaiut b Environment
Page 34 of 41
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ENG01
N/A
31.39
ENG02
N/A
5.18
5. Public access must be precluded in all areas within the modeling receptor exclusion zone as
submitted with the modeling in the application. The exclusion zone must be fenced and posted
with no trespassing signs. (Reference: Regulation Number 3, Part B, Section III.6.5.)
6. All equipment currently covered by an existing Title V permit must comply with all monitoring,
reporting, and record keeping requirements outlined in the current Title V Operating Permit.
(Reference: Regulation Number 3, Part B, Section III.E.)
General Terms and Conditions
7. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the Division as provided in Regulation
Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a
revised APEN and the required fee.
8. If this permit specifically states that final approval has been granted, then the remainder of
this condition is not applicable. Otherwise, the issuance of this construction permit is
considered initial approval and does not provide "final" approval 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 Number 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. Once self -certification of all points has been reviewed and approved by the
Division, it will provide written documentation of such final approval. Details for obtaining final
approval to operate are located in the "Requirements to Self -Certify for Final Approval"
section of this permit. The operator must retain the permit final approval letter issued by the
Division after completion of self -certification with the most current construction permit.
9. 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(ies) specifically identified in this permit. If subsequent operations or testing at the
source indicate the information supplied to obtain this permit and relied upon in the creation
and issuance of this permit is inaccurate, the source must submit an application to modify the
permit to address the inaccuracy(ies). (Reference: Regulation Number 3, Part B, Section III.E.)
Permit Histo
Issuance
Date
Description
Issuance 1
May 26, 1995
Issued to Public Service Company of Colorado.
Issuance 2
This Issuance
Addition of SCR to turbine 002 (AIRS ID 004) to
control NOx. Updating permit to incorporate title V
operating permit language since all updates for this
source have gone through title V before this
modification.
NOTES TO PERMIT HOLDER (AS OF DATE OF PERMIT ISSUANCE)
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
6 -
COLORADO
Air Pollution Control Division
Department of Fabric Health 6 Enwonment
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DRAFT
may be revised upon request of the permittee providing there is no exceedence of any specific
emission control regulation or any ambient air quality standard. A revised air pollutant emission
notice (APEN) and application form must be submitted with a request for a permit revision.
(Reference: Regulation Number 3, Part B, Section II.A.4.)
2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The permittee must 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 noon of the next working day,
followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1.
of the Common Provisions Regulation.
3) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of
the Division's analysis of the specific compounds emitted if the souroe(s) operate at the
permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emission Rate
(lb/year)
Are the
emissions
reportable?
Controlled
Emission Rate
(lb/year)
004 a
005
Acetaldehyde
75070
2320
YES
N/A
004 a
005
Formaldehyde
50000
8260
YES
N/A
004 R
005
Toluene
108883
3360
YES
N/A
004 5
005
Xylene
1300207
1640
YES
N/A
004 it
005
Nickel
N/A
2920
YES
N/A
004 EtManganese
00505
N/A
2040
YES
N/A
4) The emission levels contained in this permit are based on the following emission factors:
Emission Factors for AIRS Point 004 Ft 005:
CAS
Pollutant
Uncontrolled
Unit
Source
PM, . 8
PM25
0.0066
lb/MMBTU
AP -42
SO2
0.0034
lb/MMBTU
AP -42
CO
0.082
lb/MMBTU
AP -42
VOC
0.0021
lb/MMBTU
AP -42
75070
Acetaldehyde
0.0000912
lb/MMBTU
ICCR
50000
Formaldehyde
0.000318
lb/MMBTU
Stack
Test
108883
Toluene
0.00013
lb/MMBTU
AP -42
1300207
Xylene
0.000064
lb/MMBTU
AP -42
5) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated
with this permit is valid for a term of five (5) years from the date it was received by the
Division. A revised APEN must be submitted no later than thirty (30) days before the five-year
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
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term expires. Please refer to the most recent annual fee invoice to determine the APEN
expiration date for each emissions point associated with this permit. For any questions
regarding a specific expiration date call the Division at (303)-692-3150.
6) This facility is classified as follows:
Applicable Requirement
Status
Operating Permit
Major Source: NOx, VOC
NANSR
Major Source: NOx, VOC
7) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can
be found at the Code of Federal Regulations Website.
Part 60: Standards of Performance for New Stationary Sources
Regulation Type
CFR Citation
Subpart Name
NSPS
60.1 -End
Subpart A - Subpart KKKK
8) The permit holder is required to pay fees for the processing time for this permit. An invoice for
The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. Failure to pay the invoice will result in
revocation of this permit. The permit holder must pay the invoice within thirty (30) days of
receipt of the invoice. (Reference: Regulation Number 3, Part A, Section VI.B.)
9) Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the Division to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
10) 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 must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Division on grounds
set forth in the Colorado Air Pollution Prevention and Control Act and regulations of the 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. (Reference: Regulation Number 3, Part B, Section
III.F.)
11) Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollutant
Emission Notice (APEN) must pay an annual emission fee. 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.
12) 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.
COLORADO
Air Pollution Control Division
Department of Public Health Fr Enwonment
Page 37 of 41
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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
PPM Parts Per Million
PPMV Parts Per Million, by Volume
COLORADO
Air Pollution Control Division
Department of Public Health 6 frmronment
Page 38 of 41
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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
fte
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Page 39 of 41
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APPENDIX C
VOC Correlation Equations
Turbine 2
Revision 1- May 2000
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
MMF Model: y=(a*b+c*x^d)/(b+x^d)
Coefficient Data:
a = -10.70408
b = 29.46769
c= 1.859911
d = 0.808016
Simple Cycle, lbs/hr
MMF Model: y=(a*b+c*x^d)/(b+x^d)
Coefficient Data:
a=-17013.15
b = 934.6225
c = 7.491049
d = 2.20199
Turbine 3
Revision 1 — May 2000
For all Turbine 3 equations:
y= VOC (Ib/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= 0.51302
b = 0.555636
c = -0.004311
d = 29.75011
Simple Cycle, lbs/hr
a
COLORADO
Air Pollution Control Division
Department of public Health b Enwonment
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MMF Model: y=(a*b+c*x^d)/(b+x^d)
Coefficient Data:
a = -849.1986
b = 228.2923
c = 3.014795
d = 1.807953
ate
COLORADO
Air Pollution Control Division
Department of Public Health b Dweonment
Page 41 of 41
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