HomeMy WebLinkAbout20203345.tiff Cy,,,,,.,,- COLORADO
Department of Public
Health&Environment
RECEIVED
OCT 3 0 2020
Weld County - Clerk to the Board WELD COUNTY
1150 o St COMMISSIONERS
PO Box 758
Greeley, CO 80632
October 26, 2020
Dear Sir or Madam:
On October 27, 2020, the Air Pollution Control Division will begin a 30-day public notice period for
Public Service Company of Colorado - Ft. St. Vrain. A copy of this public notice and the public
comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
Enclosure
or_cot-
4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe �-/ - �
"i `r ) I
Jared Polis,Governor I Jill Hunsaker Ryan,MPH, Executive Director *;
Publ Ca-view F-IG.(OS), OGC�t»), 2020-3345
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C .MRYM Air Pollution Control Division
Notice Of A Proposed Renewal Title V Operating Permit
CDPHE Warranting Public Comment
Website Title: Public Service Company of Colorado - Ft. St. Vrain - Weld County
Notice Period Begins: October 27, 2020
NOTICE is hereby given that an application to renew an Operating Permit has been submitted to the
Colorado Air Pollution Control Division, 4300 Cherry Creek Drive South, Denver, Colorado 80246-1530, for
the following source of air pollution:
Applicant: Public Service Company of Colorado
1800 Lorimer Street
Suite 1300
Denver, CO 80202
Facility: Ft. St. Vrain
16805 County Road 19 'h
Platteville, CO 80651
Public Service Company of Colorado has applied to renew the Operating Permit for the Ft. St. Vrain in Weld
County, CO. This facility consists of five natural gas-fired combustion turbines used to generate electricity A
copy of the application, including supplemental information, the Division's analysis, and a draft of the
Renewal Operating Permit 97OPWE180 have been filed with the Weld County Clerk's office. A copy of the
draft permit and the Division's analysis are available on the Division's website at
https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. The Division has made a preliminary
determination of approval of the application. Based on the information submitted by the applicant, the
Division has prepared the draft renewal operating permit for approval. Any interested person may contact
Jacqueline Joyce of the Division at 303-692-3267 to obtain additional information. Any interested person
may submit written comments to the Division concerning 1) the sufficiency of the preliminary analysis, 2)
whether the permit application should be approved or denied, 3) the ability of the proposed activity to
comply with applicable requirements, 4) the air quality impacts of, alternatives to, and control technology
required on the source or modification, and 5) any other appropriate air quality considerations. Any
interested person may submit a written request to the Division for a public comment hearing before the
Colorado Air Quality Control Commission (Commission) to receive comments regarding the concerns listed
above as well as the sufficiency of the preliminary analysis and whether the Division should approve or deny
the permit application. If requested, the hearing wilt be held before the Commission within 60 days of its
receipt of the request for a hearing unless a longer time period is agreed upon by the Division and the
applicant. The hearing request must: 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.
Comments may be submitted using the following options:
• Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
-,:Tr COLORADO
1 - Department at Public
I CDF4' Health 6 E wironmerit
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Jacqueline Joyce
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-55-B1
Denver, Colorado 80246-1530
Hearing requests may be submitted to the email address or the mailing address noted above.
COLORADO
440
Department of Public
2 I °°"E Health&Environment
i
,.,t,. COLORADO
Department of Public
C.
Public
Health&Environment
October 15, 2020
Ms. Sabrina Williams
Environmental Services
Xcel Energy
1800 Larimer Street
Suite 1300
Denver, CO 80202
REF: Public Service Company of Colorado - Ft. St. Vrain Station, FID # 1230023, OP #
97OPWE180
SUBJECT: Response to Comments on Draft Operating Permit
Dear Ms. Williams:
The comments you provided on the draft renewal Operating Permit (97OPWE180) and Technical
Review Document (TRD) for your facility were received on September 28, 2020 via email. The
Division has reviewed and addressed your comments as follows:
Comment: Page 13 in the Technical Review Document (TRD) references language changes to
Permit Condition 1.6.4 and an emissions factor update in Permit Condition
1.6.4.1. The correct references to these Permit Conditions are 1.6.3 and 1.6.3.1,
respectively.
Response: Page 9 of the TRD indicates that the discussion related to modifications is with
respect to the current Title V permit (renewed January 1, 2016) and notes that it
reflects the condition numbers in the current permit and because some condition
numbers may be removed, reorganized and/or reformatted, the condition numbers
in the TRD may not reflect the condition numbers in the draft Title V permit.
Based on the language in the TRD on page 9, references to Condition 1.6.4 and
1.6.4.1 are correct. Nevertheless in order to add further clarification, the TRD has
been revised to note the conditions have also been renumbered.
Comment: Page 13 in the TRD references language changes to Permit Condition 1.12 related
to the emissions limits and performance testing. The correct reference should to
be to Permit Condition 1.13.
Response: As discussed in the above comment, page 9 of the TRD indicates that the condition
numbers referenced reflect the condition numbers in the current permit and
Condition 1.12 is the correct reference.
.04'Gato\
4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe iy�`':, -.4);
Jared Polls, Governor I Jill Hunsaker Ryan,MPH, Executive Director ,*V MI .„,
Ms. Sabrina Williams, Xcel Energy October 15, 2020
Application for Renewal of Title V Operating Permit Page 2
As discussed in the above comment, the Division will add clarifying language to
make it clear when condition numbers have been renumbered, including those for
which Xcel did not comment on (e.g. Condition 1.11.1 on page 13 and 2.11.1 on
page 14).
Comment: Page 17 in the TRD references language changes to Permit Condition 8.18 related
to the NANSR thresholds. This should be corrected to reference Permit Condition
8.19.
Response: As discussed in the above comments, page 9 of the TRD indicates that the
condition numbers referenced reflect the condition numbers in the current permit
and Condition 8.18 is the correct reference.
Also as discussed in the above comments, the Division will add clarifying language
to make it clear when condition numbers have been renumbered, including those
for which Xcel did not comment on (e.g. Condition 8.11.1 on page 17).
Comment: Section II, Condition 6.1: The table in this Permit Condition should be updated to
reflect the turbine rating change from 1,531 mmbtu/hr to 1,701 mmbtu/hr, as
well as the overall rating after adding the duct burner is 2,126 mmbtu/hr
following the modifications made during the Unit 4 rotor replacement project.
Response: As discussed in follow-up email correspondence, the turbine 4 heat input rate was
revised to 1,704 MMBtu/hr and overall Unit 4 (turbine plus duct burner) heat input
rate was revised to 2,126 MMBtu/hr.
Comment: Section II, Permit Condition 2.2.1: Suggest that this condition for Unit 4 be
revised to match Permit Condition 1.6.3.1 for T002 and T003 in which the
particulate emissions use the monthly heat input to the turbine/HRSG/duct
burner that are determined using the data acquisition and handling system (DAHS)
for the CEMS required by Condition Error!Reference source not found. instead
of the fuel use and heat content of the gas. This would also make it consistent
with what is required for T005 and T006.
Response: The change has been made as requested.
Response to Supplemental Information Request in Transmittal Letter
Item 1: The requirements in Colorado Regulation No. 7, Section II.E and Section II.F do not
apply to this facility. The cold solvent cleaner is currently in storage and rarely
used, even during outages. Total combined actual, uncontrolled VOC emission
from industrial solvent cleaning operations would not meet or exceed 2 tons in
any calendar year given that the amount of solvent consumption, even during a
routine outage, is minimal.
Response: Thank you for providing this information. The TRD will indicate that the
requirements in Regulation No. 7, Part C, Sections II.E and F do not apply.
Item 2: The Turbine 4 Rotor Replacement Project does trigger a modification under 40
CFR Part 60 Section 60.14 once the project is complete. The Turbine 4 Rotor
Replacement Project is scheduled for completion in November 2020, at which time
the requirements of 40 Part 60 Subpart KKKK would become applicable.
Ms. Sabrina Williams, Xcel Energy October 15, 2020
Application for Renewal of Title V Operating Permit Page 3
Response: Thank you for providing this information. The permit will be revised to indicate
that Turbine 4 is now subject to the requirements in NSPS KKKK, rather than NSPS
GG.
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 wilt 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 format
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 contact
me at (303) 692-3267 or jackie.joyce®state.co.us if you have any further questions.
Sincerely,
Jacqueline Joyce
Operating Permit Unit
Stationary Sources Program
Air Pollution Control Division
r <r:
°`� - STATE OF
Joyce -CDPHE,Jackie<jackie.joyce@state.co.us>
COLORADO
RE: FSV 2019 Title V Comment Letter
1 message
Williams, Sabrina M <Sabrina.M.Williams@xcelenergy.com> Wed, Oct 7, 2020 at 3:53 PM
To: "Joyce-CDPHE, Jackie"<jackie.joyce@state.co.us>
Cc: "Campbell, Chad E"<Chad.Campbell@xcelenergy.com>
Sorry, I should have clarified better.The new turbine rating for unit 4 is 1,704 MMBtu/hr and the duct burner heat rate is
422 MMBtu/hr for a total of 2,126 MMBtu/hr. I apologize for the typo in the comment letter.
Thanks,
Sabrina
From: Joyce -CDPHE, Jackie <jackie.joyce@state.co.us>
Sent: Wednesday, October 7, 2020 3:40 PM
To:Williams, Sabrina M <Sabrina.M.Williams@xcelenergy.com>
Subject: Re: FSV 2019 Title V Comment Letter
EXTERNAL -STOP &THINK before opening links and attachments.
Ok, thanks.
Jackie Joyce
Permit Writer
Operating Permit Unit, Stationary Sources Program
P 303.692.3267 I F 303.782.0278
4300 Cherry Creek Drive South, Denver, CO 80246
Jackie.Joyce@state.co.us www.colorado.gov/cdphe/aped
On Wed, Oct 7, 2020 at 3:38 PM Williams, Sabrina M <Sabrina.M.Williams@xcelenergy.com>wrote:
Hi Jackie,
The duct burner heat rate shown in Table 6.1 is correct, but the turbine rating is incorrect.The correct turbine rating is
1,704 MMBtu/hr. Let me know if you have any questions.
Thanks,
f
,
Sabrina
From: Joyce-CDPHE, Jackie <jackie.joyce@state.co.us>
Sent:Tuesday, October 6, 2020 3:53 PM
To: Williams, Sabrina M <Sabrina.M.Williams@xcelenergy.com>
Subject: Re: FSV 2019 Title V Comment Letter
EXTERNAL-STOP&THINK before opening links and attachments.
Hi Sabrina,
I had a question on one of the comments and wanted some feedback. Xcel asked that that higher heat input rate for
Turbine 4 be included in the table in Section I, Condition 6.1 of the permit. The new turbine rating is 1,701
MMBtu/hr and the letter indicates the total heat input rate should be 2,126 MMBtu/hr but the permit lists the duct
burner heat rate at 422 MMBtu/hr, so I calculate the total at 2,123 MMBtu/hr. I was wondering if there was a typo in
the comment letter or the duct burner heat rate shown in the table in Condition 6.1 is incorrect?
Thanks,
Jackie Joyce
Permit Writer
Operating Permit Unit, Stationary Sources Program
P 303.692.3267 I F 303.782.0278
4300 Cherry Creek Drive South, Denver, CO 80246
Jackie.Joyce@state.co.us I www.colorado.gov/cdphe/apcd
On Mon, Sep 28, 2020 at 8:31 AM Williams, Sabrina M <Sabrina.M.Williams@xcelenergy.com>wrote:
Hello Jackie,
i
Attached are PSCo's comments on the draft Fort St.Vrain Title V permit. Please let me know if you have any
questions.
Thanks,
Sabrina Williams
Xcel Energy
IEnvironmental Analyst V, Environmental Services
1800 Larimer, Denver, CO 80202
I Office: 303.294.2187 Cell: 303.883.8956
E: sabrina.m.williams@xcelenergy.com
yr
STATE of Joyce -CDPHE,Jackie<jackie.joyce@state.co.us>
Fs.:v
RE: FSV 2019 Title V Comment Letter
1 message
Campbell,Chad E <Chad.Campbell@xcelenergy.com> Wed, Oct 7, 2020 at 6:46 AM
To: "Joyce-CDPHE, Jackie" <jackie.joyce@state.co.us>
Cc: "Williams, Sabrina M" <Sabrina.M.Williams@xcelenergy.com>,"Ayala,Jessi M" <Jessica.M.Ayala@xcelenergy.com>
Hi Jackie. You are correct on SO2. Based on the Appendix D calculation for SO2 lb/hr, since there is the ability to burn
more gas then there is the potential to have a change in lb/hr. Taking a second look at information provided from the
vendor it isn't doing a proper comparison in that regard. Also,that makes sense on it being a "combined cycle"unit
versus a"simple cycle"unit. I would agree with a 30-day limit determination.
Chad
From: Joyce-CDPHE, Jackie<jackie.joyce@state.co.us>
Sent: Tuesday, October 6, 2020 9:52 AM
To: Campbell, Chad E <Chad.Campbell@XCELENERGY.COM>
Cc: Williams, Sabrina M <Sabrina.M.Williams@xcelenergy.com>;Ayala, Jessi M <Jessica.M.Ayala@xcelenergy.com>
Subject: Re: FSV 2019 Title V Comment Letter
EXTERNAL -STOP 8,THINK before opening links and attachments.
Hi Chad,
So I was curious as to the analysis that determined the Turbine 4 rotor replacement triggered a modification for NOX
but not for SO2. Can you provide more explanation on that? I know a while back I was asking whether the design heat
input rate to the Turbine 4 would increase with the project, and if it does, I don't know why there would not be an
increase in S02 emissions (if the unit is capable of burning more fuel on an hourly basis, then I would think the S02
emission rate would also increase).
I had some discussions with Sara Heald to see if she had done research on NSPS KKKK and how it might be applied to
units that can operate in both simple cycle and combined cycle mode. She was also of the opinion that if the unit is
capable of operating in combined cycle mode, then the 30-day averaging time would apply. That is the direction the
Reg 7 requirements for turbines are expected to go (units with heat recovery and CEMS would demonstrate
compliance on a 30-day rolling average).
Although the preamble to NSPS KKKK does not address this issue, the language in 60.4350 regarding the averaging time
(paragraphs (g) and (h)) applies to the unit, i.e. a simple cycle unit or a combined cycle unit, not the mode it is
operating in. Even though Turbine 4 is capable of bypassing the HRSG and operating in simple cycle mode, it is a
combined cycle unit (see definition below), so the 30-day averaging period would apply. I am going to revise the
permit to include the NSPS KKKK NOx limits and specify a 30-day averaging period for Turbine 4.
Combined cycle combustion turbine means any stationary combustion turbine which recovers heat from the •
combustion turbine exhaust gases to generate steam that is only used to create additional power output in a
steam turbine.
I do have a question in to EPA on this issue. I don't know when (or if) they will respond, but I am going to move ahead
with what I think for now. If they come back with a different answer (i.e. that the 4-hr average applies when a
combined cycle unit operates in simple cycle mode), then I will revise the permit. I am not particularly hopeful that
they will respond.
Feel free to contact me if you have any questions.
Thanks,
Jackie Joyce
Permit Writer
Operating Permit Unit, Stationary Sources Program
P 303.692.3267 I F 303.782.0278
4300 Cherry Creek Drive South, Denver, CO 80246
Jackie.Joyce@state.co.us www.colorado.gov/cdphe/apcd
On Mon, Sep 28, 2020 at 6:59 PM Campbell, Chad E <Chad.Campbell@xcelenergy.com>wrote:
Hi Jackie. Correct,we trigger due to NOx. SO2 doesn't show an impact. We can certainly discuss this further, but my
take on the applicability is that simple cycle operation would be treated just as a simple cycle turbine. With that I'd see
U4 getting the same requirement for simple cycle operation as is written for the KKKK limits for U5 and U6. What
might be a good idea though is for you to connect with Sarah Held. She did a complete review of the KKKK
applicability in preparation for major source RACT for non-attainment when looking at applying KKKK to units only
covered by GG. We should probably be consistent with how she is applying it under that rule effort. Let me know what
comes out of the discussion and we can go from there.
Chad
From: Joyce-CDPHE,Jackie<jackie.joyce@state.co.us>
Sent: Monday, September 28, 2020 3:18 PM
To: Williams, Sabrina M <Sabrina.M.Williams@xcelenergy.com>
Cc: Campbell, Chad E<Chad.Campbell@XCELENERGY.COM>;Ayala, Jessi M <Jessica.M.Ayala@xcelenergy.com>
Subject: Re: FSV 2019 Title V Comment Letter
EXTERNAL -STOP&THINK before opening links and attachments.
I have a couple of questions re triggering NSPS KKKK for Turbine 4 that I could use some input on in order to make
the changes in the permit. I may have discussed these issues to some extent with Chad but have forgotten what, if
.
any, conclusions we may have come to and we may not have even discussed these issues (I could have just dreamed
it).
NSPS modifications can be triggered for just some pollutants (those pollutants for which there is an increase in the
hourly emission rate). I assume a modification was triggered for both NOX and SO2 emissions. Is that correct?
I am wondering whether Turbine 4 would have to comply with the NOx limit on a 4-hr rolling average, when
operating in simple cycle mode. It's the same turbine but just not operating in combined cycle mode - so I am
leaning towards the thought that regardless of how it is operated, that compliance with the NOX limit would be on a
30-day rolling average. I wonder if when Turbine 4 is operated in simple cycle mode, it would even meet the
definition of a simple cycle unit. See the definition below, specifically the first part (in bold):
Simple cycle combustion turbine means any stationary combustion turbine which does not recover
heat from the combustion turbine exhaust gases to preheat the inlet combustion air to the
combustion turbine, or which does not recover heat from the combustion turbine exhaust gases for
purposes other than enhancing the performance of the combustion turbine itself.
I am wondering whether you guys have done any research re this issue of simple vs combined cycle mode with
respect to Turbine 4 and the averaging time for the NOX limit and if so, what are your thoughts? Since Cherokee
units 5 E 6 can't operate in simple cycle mode and FSV 5 and 6 aren't combined cycle units, I haven't run into this
before, so I would like your thoughts on this.
Thanks,
Jackie Joyce
Permit Writer
Operating Permit Unit, Stationary Sources Program
P 303.692.3267 I F 303.782.0278
4300 Cherry Creek Drive South, Denver, CO 80246
Jackie.Joyce@state.co.us I www.colorado.gov/cdphe/apcd
On Mon, Sep 28, 2020 at 9:49 AM Joyce-CDPHE, Jackie<jackie.joyce@state.co.us>wrote:
Thanks,
I should get to this in the next week or two...
Jackie Joyce
1 Permit Writer
Operating Permit Unit, Stationary Sources Program
P 303.692.3267 I F 303.782.0278
4300 Cherry Creek Drive South, Denver, CO 80246
Jackie.Joyce@state.co.us I www.colorado.gov/cdphelapcd
1
jJ
On Mon, Sep 28, 2020 at 8:31 AM Williams, Sabrina M <Sabrina.M.Williams@xcelenergy.com>wrote:
Hello Jackie,
Attached are PSCo's comments on the draft Fort St.Vrain Title V permit. Please let me know if you have any
questions.
Thanks,
Sabrina Williams
Xcel Energy
Environmental Analyst V, Environmental Services
1800 Larimer, Denver, CO 80202
Office: 303.294.2187 Cell: 303.883.8956
E: sabrina.m.williams@xcelenergy.com
c '6( 9- /zvo
Xcel Energy-
Environmental Services Department
1800 Larimer Street,Suite 1300
Denver,CO 80202
September 28, 2020
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 Generating Station
Operating Permit No. 97OPWE180
Draft Permit Renewal Comments
Dear Ms. Joyce:
Included below are the Public Service Company of Colorado comments and questions regarding
the Draft Fort St.Vrain Generating Station Title V renewal permit. The requested changes from
the application have been reviewed and found to be acceptable as written. The comments are
mostly editorial in nature or for clarification as the limits and requirements from the past permit
have been carried forward properly in the draft renewal version.
1) Page 13 in the Technical Review Document(TRD) references language changes to
Permit Condition 1.6.4 and an emissions factor update in Permit Condition 1.6.4.1. The
correct references to these Permit Conditions are 1.6.3 and 1.6.3.1, respectively.
2) Page 13 in the TRD references language changes to Permit Condition 1.12 related to the
emissions limits and performance testing.The correct reference should to be to Permit
Condition 1.13.
3) Page 17 in the TRD references language changes to Permit Condition 8.18 related to the
NANSR thresholds.This should be corrected to reference Permit Condition 8.19.
4) Section II, Condition 6.1: The table in this Permit Condition should be updated to reflect
the turbine rating change from 1,531 mmbtu/hr to 1,701 mmbtu/hr, as well as the overall
rating after adding the duct burner is 2,126 mmbtu/hr following the modifications made
during the Unit 4 rotor replacement project.
5) Section II, Permit Condition 2.2.1: Suggest that this condition for Unit 4 be revised to
match Permit Condition 1.6.3.1 for T002 and T003 in which the particulate emissions use
the monthly heat input to the turbine/HRSG/duct burner that are determined using the
data acquisition and handling system (DAHS)for the CEMS required by Condition Error!
Reference source not found. instead of the fuel use and heat content of the gas. This
would also make it consistent with what is required for T005 and T006.
Below is the response to the request for supplemental information that you included in the
transmittal letter with the draft permit.
1. The requirements in Colorado Regulation No. 7, Section II.E and Section II.F do not
apply to this facility.The cold solvent cleaner is currently in storage and rarely used,
even during outages. Total combined actual, uncontrolled VOC emission from
industrial solvent cleaning operations would not meet or exceed 2 tons in any
calendar year given that the amount of solvent consumption, even during a routine
outage, is minimal.
2. The Turbine 4 Rotor Replacement Project does trigger a modification under 40 CFR
Part 60 Section 60.14 once the project is complete. The Turbine 4 Rotor
Replacement Project is scheduled for completion in November 2020, at which time
the requirements of 40 Part 60 Subpart KKKK would become applicable.
If you have any questions please contact me at 303-294-2187 or
Sabrina.m.williams@xcelenergy.com.
Sincerely,
.14\t^
Sabrina Williams
Environmental Services
Xcel Energy
cc: Chad Campbell
Fort St.Vrain Generating Station
;lM4M COLORADO
Department of Public
Health&Environment
August 20, 2020
Ms. Sabrina Williams
Environmental Services
Xcel Energy
1800 Larimer Street
Suite 1300
Denver, CO 80202
SUBJECT: Draft Renewal Operating Permit for Public Service Company of Colorado -
Ft. St. Vrain Station
. Dear Ms. Williams:
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 December 6, 2019. The permit was also revised to be more
consistent with recently issued permits, correct errors, omissions and discrepancies
identified during inspections and/or review of the renewal application and incorporate
EPA comments made on other operating permits for similar sources. The changes are
summarized in the technical review document for the renewal permit.
While you are reviewing this permit, please be aware of the following:
1. Since November 2016, the Colorado Air Quality Control Commission (ACQQ) has adopted
revisions to Regulation No. 7 to address additional solvent operations. In order to determine if
any of these new requirements apply to operations at Ft. St. Vrain Station, please respond to
the following items.
a. Provisions were included in Colorado Regulation No. 7, Part C, Section II.E for industrial
solvent cleaning operations. These requirements potentially apply to your facility if total
combined actual, uncontrolled VOC emission from industrial solvent cleaning operations
meet or exceed 3 tons in any calendar year. While we consider this is unlikely under
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ;g:F/
iy�'� O}
Jared Polis,Governor I Jill Hunsaker Ryan,MPH, Executive Director a *},:
*j876,t,
Ms. Sabrina Williams, Xcel Energy August 20, 2020
Draft Renewal Permit for Ft. St. Vrain Station Page 2
normal operations, it may be possible during a routine outage. Please indicate whether
the requirements in Colorado Regulation No. 7, Part C, Section II.E apply to this facility. If
not subject, please indicate whether non-applicability is based on emissions below the
threshold or a specific exemption.
b. Provisions were included in Colorado Regulation No. 7, Part C, Section II.F for general
solvent use. These requirements potentially apply to operations at your facility that use
solvents with actual, uncontrolled VOC emissions greater than or equal to 2 tons per year.
Please indicate whether the requirements in Section II.F apply.
i. If so, do actual, uncontrolled VOC emissions from general solvent use exceed or are
anticipated to exceed 25 tons per year?
ii. If not, please indicate whether non-applicability is based on emissions below the
threshold or a specific exemption.
2. A modification application was submitted on June 22, 2020, with supporting information
submitted on July 6, 2020 to address the replacement of the Turbine 4 rotor, as well as other
components. While processing the modification, the Division considered that changes made to
Turbine 4 may have triggered a modification or possibly a reconstruction under the provisions
in 40 CFR Part 60 §§ 60.14 and 60.15, respectively but did not come to a final conclusion. If
the Turbine 4 rotor project triggered either a modification or reconstruction, the provisions in
40 CFR Part 60 Subpart KKKK would apply. Therefore, please provide information indicating
whether the Turbine 4 rotor replacement project triggered a modification or reconstruction.
We would like you to review this permit by September 28, 2020. Feel free to contact me
at (303) 692-3267 or jackie.joyce@state.co.us if you have any questions or concerns.
Sincerely,
c 94/84—
Jacqueline Joyce,
Permit Engineer, Operating Permit Unit
Stationary Sources Program
Air Pollution Control Division
cc: Chad Campbell, Xcel Energy - via email
Xcel Energy-
Environmental Services
1800 Larimer Street,Suite 1300
Denver,CO 80202
December 6,2019
Ms.Jacqueline Joyce
Colorado Department of Public Health&Environment
Air Pollution Control Division,APCD-SS-B 1
Operating Permit Unit
4300 Cherry Creek Drive South
Denver,CO 80246-1530
Re: Fort Saint Vrain
Permit#97OPWE180
Title V Operating Permit Renewal Application
Dear Ms.Joyce:
In accordance with the requirements of Colorado Air Quality Control Commission Regulation
No. 3,Part C, Section BI.B.6,Public Service Company of Colorado(PSCo)is hereby submitting
a renewal application for the Public Service Company of Colorado (PSCo)Fort St.Vrain Station
Title V Operating Permit#97OPWE180. This submittal package includes:
• This cover letter signed by the Company's Responsible Official which contains,
• Identification of the facility's status for greenhouse(GHG)emissions
• Non-applicability confirmation of the Federal Compliance Assurance Monitoring(CAM)
provisions,and
• Summary of changes being requested during this renewal process
• Attachment of the required Colorado operating permit application forms(Forms 2000-100 and
2000-800)
• Attachment of the Acid Rain Program Permit Application
Greenhouse Gas Status Assessment
An evaluation of the emission sources at the Fort St.Vrain Station facility was done to assess the
potential to emit(PTE)for greenhouse gas(GHG)emissions. Based on the analysis,Fort St.
Vrain is major for GHG emissions. The evaluation was based on Acid Rain Program data and
calculations according to the requirements of Title 40 Part 98 Subpart C and D.
Compliance Assurance Monitoring Review
Each emission source at the Fort St.Vrain Station facility was evaluated for CAM applicability
as part of the May 18, 2009 permit renewal application. The evaluation during that renewal
process determined that there were no sources at Fort St.Vrain which were subject to CAM
requirements. No new sources or additional control devices have been installed since that
application was submitted so the determination from that evaluation remains appropriate.
Requested Changes
No changes are being requested for the operating permit except as identified below.
PSCo is requesting that the applicable requirements for stationary combustion turbines found in Colorado
Regulation 7,Section XVI.D be included in this permit renewal.
PSCo is requesting updates to Appendix A insignificant activities with this permit renewal. A redline
markup of the current Appendix A is included with this application to identify the changes.
PSCo is requesting updates to the Responsible Official and Facility Contact Person listed for this facility.
This change in information has been reflected on Form 2000-100 that is included with this submittal.
Responsible Official
Name: Jeffrey West
Title: Sr.Director—Environmental Services
Phone: (303)571-2762
Facility Contact Person
Name: Chad Campbell
Title: Manager,Environmental Services—Air&Water Quality Compliance
Phone: (303)294-2177
If you have any questions concerning the attached permit application forms or information provided,please
contact Chad Campbell of Xcel Energy's Environmental Services staff,at chad.campbell@xcelenergy.com
or(303)294-2177.
Sincerely,
fr7
Jeffrey West
Sr.Director—Environmental Services
att: As Stated
cc: M.Maes—Director,Fort Saint Vrain
J.Ayala—Environmental Analyst,Fort Saint Vrain
C.Campbell—Manager,Air&Water Quality Compliance
RAES-ESG-ES\ENV-FortStVrain\Air\Permitting\Title V\Modifications\2019 Renewal Documentation
ti
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 1 . The facility address is 16805 County Road 4-9-2 19'.
Safety Equipment Required:
Eye Protection
Hard Hat
Safety Shoes
Hearing Protection
Gloves
Facility Plot Plan:
Figure 1 (following page) shows the plot plan as submitted on August 12, 2010 to support
the source's Title V Renewal Operating Permit(second renewal, issued January 1, 2011).
List of Insignificant Activities:
The following list of insignificant activities was provided by the source to assist in the
understanding of the facility layout. Since there is no requirement to update such a list,
activities may have changed since the last filing.
The asterisk (*) denotes an insignificant activity source category based on the size of the
activity, emissions levels from the activity or the production rate of the activity. The
owner or operator of individual emission points in insignificant activity source categories
marked with an asterisk (*) must maintain sufficient record keeping verifying that the
exemption applies. Such records shall be made available for Division review upon
request. (Colorado Regulation No. 3, Part C, Section II.E)
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/PMIo)
Units with emissions less than APEN de minimis - non-criteria pollutants (Reg 3, Part
C.II.E.3.b)*
Two (2) One (1) sulfuric acid storage tanks; 20,000 gal and 750 gal above ground
(emissions less than 500 lbs/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.II.E.3.g)
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)
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)
Welding, soldering, and brazing operations using no lead-based compounds (Reg 3, Part
C.II.E.3.r)
Maintenance welding machine
Battery recharging areas (Reg 3, Part C.II.E.3.t)
Battery storage area
Landscaping and site housekeeping devices< 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
Salt tank(3,500 gal) above ground tank
Bleach tank(5,500 gal) above ground tank
Defoam(350 gal) above ground tank
Scale inhibitor(410 gal) above ground tank
Corrosion inhibitor(2,000 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)
Storage of butane,propane or LPG in tanks<60,000 gal (Reg 3 Part C.II.E.3.zz)
Storage of propane gas in small portable tanks
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)
Five (5) 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), 1,000 gal above ground
Diesel fuel tank for refueling captive vehicles (warehouse), 560 gal above ground
Forklifts (Reg 3 Part C.II.E.3.kkk)
Two ( (2) gasoline powered forklifts
Sandblast equipment where blast media is recycled and blasted material is collected (Reg
3,Part C.II.E.3.www)
Sandblasting machine
Surface water storage impoundment of non-potable water and storm water evaporation
ponds (Reg 3, Part C.II.E.3.yyy)
Two (2)raw water ponds
One (1) stormwater retention pond
Seal and lubricating oil systems for steam turbine electric generators (Reg 3, Part
C.II.E.3.cccc)
Not Sources of Emissions
Aqueous ammonia(29% mixture) storage tank(14,230 gal, above ground) and associated
piping(closed system)
•
Operating Permit Application FACILITY IDENTIFICATION FORM 2000-100
Colorado Department of Public Health and Environment Rev 06-95
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
1. Facility name and Name Fort St.Vrain Station
mailing address Street or Route 16805 County Road 19'/2
City,State,Zip Code Platteville,CO 80651
2. Facility location Street Address 16805 County Road 19 1/2
(No P.O.Box) City,County,Zip Code Platteville,CO 80651
3. Parent corporation Name Public Service Company of Colorado
Street or Route 1800 Larimer Street, Suite 1300
City,State,Zip Code Denver,CO 80802
Country(if not U.S.)
4. Responsible Name Jeffrey West
official Title Sr.Director,Environmental Services
Telephone (303)571-2762
5. Permit contact person Name Chad Campbell
Title Manager,Air&Water Quality Compliance
(If Different than 4) Telephone (303)294-2177
6. Facility SIC code: 4911 7. Facility identification code: CO 1230023
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 O New O Modified ID Renewal
11. Is the facility located in a"nonattainment"area: El Yes O No
If"Yes",check the designated"non-attainment"pollutant(s):
O Carbon Monoxide E Ozone ❑ PM10 O Other(specify)
12. List all(Federal and State)air pollution permits(including grandfathered units),plan approvals and exemptions issued to
this facility.List the number,date and what unit/process is covered by each permit. For a Modified Operating Permit,do not
complete this item.
Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800
Colorado Department of Health 09-94
Air Pollution Control Division
Facility Name: Fort St Vrain Station Facility Identification Code: CO 1230023
I. ADMINISTRATION
This application contains the following forms: ❑x Form 2000-100,Facility Identification
❑ Form 2000-101,Facility Plot Plan
❑ Forms 2000-102,-102A,and-102B,Source and Site Descriptions
II. EMISSIONS SOURCE Total Number
DESCRIPTION of This Form
This application contains the following forms O Form 2000-200,Stack Identification
(one form for each facility boiler.printing
❑ Form 2000-300,Boiler or Furnace Operation
❑ Form 2000-301,Storage Tanks
❑ Form 2000-302,Internal Combustion Engine
❑ Form 2000-303,Incineration
❑ Form 2000-304,Printing Operations
❑ Form 2000-305,Painting and Coating Operations
❑ Form 2000-306,Miscellaneous Processes
❑ Form 2000-307,Glycol Dehydration Unit
III. AIR POLLUTION CONTROL Total Number
SYSTEM of This Form
This application contains the following forms: O Form 2000-400,Miscellaneous
❑ Form 2000-401,Condensers
❑ Form 2000-402,Adsorbers
❑ Form 2000-403,Catalytic or Thermal Oxidation
❑ Form 2000-404,Cyclones/Settling Chambers
❑ Form 2000-405,Electrostatic Precipitators
❑ Form 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,printing operation. •
❑ Form 2000-501,Continuous Emission Monitoring
❑ Form 2000-502,Periodic Emission Monitoring Using Portable Monitors
❑ Form 2000-503,Control System Parameters or Operation Parameters of a Process
❑ Form 2000-504,Monitoring Maintenance Procedures
❑ Form 2000-505,Stack Testing
❑ Form 2000-506,Fuel Sampling and Analysis
❑ Form 2000-507,Recordkeeping
❑ Form 2000-508,Other Methods
2
V. EMISSION SUMMARY AND Total Number
COMPLIANCE CERTIFICATION of This Form
This application contains the following forms O Form 2000-600,Emission Unit Hazardous Air Pollutants
quantifying emissions,certifying compliance
with applicable requirements,and developing a
compliance plan
❑ Form 2000-601,Emission Unit Criteria Air Pollutants
❑ Form 2000-602,Facility Hazardous Air Pollutants
❑ Form 2000-603,Facility Criteria Air Pollutants
❑ Form 2000-604,Applicable Requirements and Status of Emission Unit
❑ Form 2000-605,Permit Shield Protection Identification
❑ Form 2000-606,Emission Unit Compliance Plan-Commitments and Schedule
❑ Form 2000-607,Plant-Wide Applicable Requirements
❑ Form 2000-608,Plant-Wide Compliance Plan-Commitments and Schedule
VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS
A. STATEMENT OF COMPLETENESS
I have reviewed this application in its entirety and,based on information and belief formed after reasonable inquiry,I certify that
the statements and information contained in this application are true,accurate and complete.
B. CERTIFICATION OF FACILITY COMPLIANCE STATUS-FEDERAL/STATE CONDITIONS(check one box only)
❑x I certify that the facility described in this air pollution permit application is fully in compliance with all applicable
requirements.
O I certify that the facility described in this air pollution permit application is fully in compliance with all applicable
requirements,except for the following emissions unit(s):
(list all non-complying units)
WARNING: Any person who knowingly,as defined in§18-1-501(6),C.R.S.,makes any false material statement,representation,
or certification in,or omits material information from this application is guilty of a misdemeanor and may be punished in
accordance with the provisions of§25-7 122.1,C.R.S.
Printed or Typed Name Title
Jeffrey West Sr.Director,Environmental Services
Signature Date Signed
/31,5
3
Operating Permit Application CERTIFICATION FOR STATE-ONLY CONDITIONS FORM 2000-800
Colorado Department of Health 09-94
Air Pollution Control Division
Facility Name: Fort St.Vrain Station Facility Identification Code: CO 1230023
VI. SIGNATURE OF RESPONSIBLE OFFICIAL-STATE ONLY CONDITIONS
A. STATEMENT OF COMPLETENESS
I have reviewed this application in its entirety and,based on information and belief formed after reasonable inquiry,I certify that
the statements and information contained in this application are true,accurate and complete.
B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE-ONLY CONDITIONS(check one box only)
El I certify that the facility described in this air pollution permit application is fully in compliance with all applicable
requirements.
O I certify that the facility described in this air pollution permit application is fully in compliance with all applicable
requirements,except for the following emissions unit(s):
(list all non-complying units)
WARNING: Any person who knowingly,as defined in§18-1-501(6),C.R.S.,makes any false material statement,representation,
or certification in,or omits material information from this application is guilty of a misdemeanor and may be punished in
accordance with the provisions of§25-7122.1,C.R.S.
Printed or Typed Name Title
Jeffrey West Sr.Director,Environmental Services
Sid ,"ure Date Signed
la\/ 5//9
SEND ALL MATERIALS TO:
COLORADO DEPARTMENT OF HEALTH
APCD-SS-B 1
4300 CHERRY CREEK DRIVE SOUTH
DENVER,CO 80246-1530
4
United States
Environmental Protection Agency OMB No.2060-0258
firEpA Acid Rain Program Approval expires 11/30/2012
Acid Rain Permit Application
For more information,see instructions and 40 CFR 72.30 and 72.31.
This submission is: CINew ElRevised X for ARP permit renewal
STEP 1
Identify the facility name, Fort St.Vrain Station CO 6112
State, and plant(ORIS) Facility(Source)Name State Plant Code
code.
STEP 2 a b
Enter the unit ID# Unit ID# Unit Will Hold Allowances
for every affected in Accordance with 40 CFR 72.9(c)(1)
unit at the affected
source in column"a." 2 Yes
3 Yes
4 Yes
5 Yes
6 Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
EPA Form 7610-16(Revised 7-2014)
•
Fort St.Vrain Station Page 2
Facility(Source)Name(from STEP 1)
Permit Requirements
STEP 3 (1) The designated representative of each affected source and each affected
unit at the source shall:
Read the standard (i) Submit a complete Acid Rain permit application (including a compliance
requirements. plan) under 40 CFR part 72 in accordance with the deadlines specified in
40 CFR 72.30; and
(ii) Submit in a timely manner any supplemental information that the
permitting authority determines is necessary in order to review an Acid
Rain permit application and issue or deny an Acid Rain permit;
(2)The owners and operators of each affected source and each affected unit
at the source shall:
(i) Operate the unit in compliance with a complete Acid Rain permit
application or a superseding Acid Rain permit issued by the permitting
authority; and
(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(Revised 7-2014)
• Fort St.Vrain Station Page 3
Facility(Source)Name(from STEP 1)
Sulfur Dioxide Requirements, Cont'd.
STEP 3,Cont'd. (4) Allowances shall be held in, deducted from, or transferred among
Allowance Tracking System accounts in accordance with the Acid Rain
Program.
(5) An allowance shall not be deducted in order to comply with the
requirements under paragraph (1) of the sulfur dioxide requirements prior to
the calendar year for which the allowance was allocated.
(6)An allowance allocated by the Administrator under the Acid Rain Program
is a limited authorization to emit sulfur dioxide in accordance with the Acid
Rain Program. No provision of the Acid Rain Program, the Acid Rain permit
application, the Acid Rain permit, or an exemption under 40 CFR 72.7 or 72.8
and no provision of law shall be construed to limit the authority of the United
States to terminate or limit such authorization.
(7)An allowance allocated by the Administrator under the Acid Rain Program
does not constitute a property right.
Nitrogen Oxides Requirements
The owners and operators of the source and each affected unit at the source
shall comply with the applicable Acid Rain emissions limitation for nitrogen
oxides.
Excess Emissions Requirements
(1) The designated representative of an affected source that has excess
emissions in any calendar year shall submit a proposed offset plan, as
required under 40 CFR part 77.
(2) The owners and operators of an affected source that has excess
emissions in any calendar year shall:
(i) Pay without demand the penalty required, and pay upon demand the
interest on that penalty, as required by 40 CFR part 77; and
(ii) Comply with the terms of an approved offset plan, as required by 40
CFR part 77.
Recordkeepinq and Reporting Requirements
(1) Unless otherwise provided, the owners and operators of the source and
each affected unit at the source shall keep on site at the source each of the
following documents for a period of 5 years from the date the document is
created. This period may be extended for cause, at any time prior to the end
of 5 years, in writing by the Administrator or permitting
authority:
(i) The certificate of representation for the designated representative for
the source and each affected unit at the source and all documents that
demonstrate the truth of the statements in the certificate of representation,
in accordance with 40 CFR 72.24; provided that the certificate and
documents shall be retained on site at the source beyond such 5-year
period until such documents are superseded because of the submission
EPA Form 7610-16(Revised 7-2014)
Fort St.Vrain Station Page 4
Facility(Source)Name(from STEP 1)
of a new certificate of representation changing the designated
representative;
STEP 3, Cont'd. Recordkeepinq and Reporting Requirements. 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
EPA Form 7610-16(Revised 7-2014)
Fort St.Vrain Station Page 5
Facility(Source)Name(from STEP 1)
any other provision of the Act, including the provisions of title I of the Act
relating
STEP 3, Cont'd.
Effect on Other Authorities, Cont'd.
to applicable National Ambient Air Quality Standards or State
Implementation Plans;
(2) Limiting the number of allowances a source can hold; provided, that the
number of allowances held by the source shall not affect the source's
obligation to comply with any other provisions of the Act;
(3) Requiring a change of any kind in any State law regulating electric utility
rates and charges, affecting any State law regarding such State regulation,
or limiting such State regulation, including any prudence review requirements
under such State law;
(4) Modifying the Federal Power Act or affecting the authority of the Federal
Energy Regulatory Commission under the Federal Power Act; or,
(5) Interfering with or impairing any program for competitive bidding for power
supply in a State in which such program is established.
STEP 4
Read the
certification Certification
statement,
sign, and date. 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
made. I certify under penalty of law that I have personally examined, and
am familiar with, the statements and information submitted in this document
and all its attachments. Based on my inquiry of those individuals with primary
responsibility for obtaining the information, I certify that the statements and
information are to the best of my knowledge and belief true, accurate, and
complete. I am aware that there are significant penalties for submitting false
statements and information or omitting required statements and information,
including the possibility of fine or imprisonment.
Jeffrey West,Designated Representative
Name
Signature Date la
EPA Form 7610-16(Revised 7-2014)
-<,11
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1876
Colorado Department
of Public Health
and Environment
OPERATING PERMIT
Public Service Company of Colorado — 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 97OPWE180
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 of Colorado 16805 County Road 19'/z
1800 Larimer Street Platteville, CO 80651
Weld County
Denver, CO 80202
INFORMATION RELIED UPON
Operating Permit Renewal Application
Received: December 6, 2019
And Additional Information Received:
Nature of Business: Combustion Gas Turbine Electric Generating Station
Primary SIC: 4911
RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON
Name: Jeffrey West Name: Chad Campbell
Title: Senior Director, Environmental Title: Manager, Environmental Services—Air
Services & Water Quality Compliance
Phone: (303) 571-2762 Phone: (303) 294-2177
SUBMITTAL DEADLINES
Semi-Annual Monitoring Periods: EXAMPLE(January 1 —June 30, July 1 —December 31)
Semi-Annual Monitoring Report: EXAMPLE (Due on Aug. 1 2016 & Feb. 1, 2017 & subsequent years)
Annual Compliance Period: EXAMPLE (January 1 —December 31)
Annual Compliance Certification: EXAMPLE (Due on February 1, 2017 & 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 22
3. B001 -Auxiliary Boiler 42
4. M001 - Cooling Water and Service Water Towers 47
5. Continuous Emission Monitoring Systems (CEMS) 49
6. M002 - Gasoline Storage Tank, 500 gallons aboveground 55
7. M003 —Cold Cleaner Solvent Vats 58
8. T005 & T006—Two (2) Simple Cycle Combustion Turbines 59
9. M004 - Diesel Fuel Fired Internal Combustion Engines 70
10. Colorado Regulation No. 7, Part E, Sections II.A.6 and 7.f—Combustion Process Adjustment
and Associated Recordkeeping Requirements 79
SECTION III -Acid Rain Requirements 83
1. Designated Representative and Alternate Designated Representative 83
2. Sulfur Dioxide Emission Allowances and Nitrogen Oxide Emission Limitations 83
3. Standard Requirements 84
4. Reporting Requirements 87
5. Comments,Notes and Justifications 88
SECTION IV- Permit Shield 89
1. Specific Non-Applicable Requirements 89
2.. General Conditions 89
3. Streamlined Conditions 90
SECTION V- General Permit Conditions 92
1. Administrative Changes 92
2. Certification Requirements 92
3. Common Provisions 92
4. Compliance Requirements 96
5. Emergency Provisions 97
6. Emission Controls for Asbestos 97
7. Emissions Trading, Marketable Permits, Economic Incentives 97
8. Fee Payment 97
9. Fugitive Particulate Emissions 98
10. Inspection and Entry 98
11. Minor Permit Modifications 98
12. New Source Review 98
TABLE OF CONTENTS:
13. No Property Rights Conveyed 98
14. Odor 98
15. Off-Permit Changes to the Source 99
16. Opacity 99
17. Open Burning 99
18. Ozone Depleting Compounds 99
19. Permit Expiration and Renewal 99
20. Portable Sources 99
21. Prompt Deviation Reporting 99
22. Record Keeping and Reporting Requirements 100
23. Reopenings for Cause 101
24. Requirements for Major Stationary Sources 101
25. Section 502(b)(10) Changes 102
26. Severability Clause 103
27. Significant Permit Modifications 103
28. Special Provisions Concerning the Acid Rain Program 103
29. Transfer or Assignment of Ownership 103
30. Volatile Organic Compounds 103
31. Wood Stoves and Wood burning Appliances 104
APPENDIX A- Inspection Information 1
Directions to Plant: 1
Safety Equipment Required: 1
Facility Plot Plan• 1
List of Insignificant Activities: 1
APPENDIX B 1
Reporting Requirements and Definitions 1
Monitoring and Permit Deviation Report- Part I 5
Monitoring and Permit Deviation Report- Part II 7
Monitoring and Permit Deviation Report - Part III 9
APPENDIX C 1
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
VOC Correlation Equations 1
APPENDIX H 1
Prevention of Significant Deterioration (PSD) Review and Non-Attainment Area New Source
Review(NANSR) Applicability Tests 1
Air Pollution Control Division Public Service Company of Colorado
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.!) 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 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. 7, Part A, Section II.A.1. The 8-hr Ozone Control
Area has been classified as a serious non-attainment area effective January 27, 2020.
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 of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE1 80 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 1.14, 2.15 and 8.17 (Opacity) and Section V - Conditions 3.g (last
paragraph), 14, 18 (as noted) and 30 (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. Either electronic or hard copy records are acceptable.
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 of Colorado
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, PMio,
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.
3.2 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.
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 II, Condition 2.10 for compliance assurance monitoring requirements.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
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./ Point 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 1,323 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 2,126 MMBtu/hr(turbine Low NOx
1,704 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 Fall 2015 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: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 5
Emission AIRS Description Startup Date Pollution Control
Unit No./ Point Device
Facility Number
ID.
M004 N/A' Two(2)Caterpillar,Model No. SP321P00,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.
'An APEN is not required as long as actual,uncontrolled emissions do not exceed the APEN de minimis level(see Regulation No. 3,
Part A,Section II.D.1.a, 1 ton/year of VOC or NOx,2 tpy of other criteria pollutants).
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
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 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):
100 ppmvd @ 15%O2 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 of Colorado
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 for
turbines T002,T003&T004
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 1-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 for
turbines T002,T003&T004
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-Hour Rolling Quality Natural
Average Gas is Used as
For Each Combustion Turbine: Fuel
150 ppmvd @ 15%O2 or Use of Fuel
Which Contains Less than 0.8 Weight
%Sulfur
For Each Duct Burner:
0.20 Ibs/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 of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 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 lbs/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
N/A 39.4 tons/yr See Condition Recordkeeping, Monthly,Every
1.6 Calculation and Five(5)Years
Compliance
Testing
PMio 1.7 9 lbs/hr 39.4 tons/yr See Condition Recordkeeping, Monthly,Every
1.7 Calculation and Five(5)Years
Compliance
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
Fuel Flow Meter 1.11 N/A N/A N/A See Condition 1.11
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
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 1.12 N/A N/A N/A As Required by Subject to
Provisions NSPS General NSPS General
Provisions Provisions
Performance 1.13 N/A N/A N/A EPA Reference See Condition
Test Methods 1.13
Requirements
Opacity-State 1.14 Not to Exceed 20% N/A Fuel Restriction Only Pipeline
Only Quality Natural
Gas is Used as
Fuel
Opacity 1.15 Not to Exceed 20%Except as N/A
Provided for in 1.16 Below
Opacity 1.16 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 1.17 See Section III of this Permit Certification Annually
Requirements
Regulation No. 1.18 Maintain Records of Capacity Factor Calculation Annually
7,Part E, (Calendar Year)
Section II.A Combustion Process Adjustment and Recordkeeping See Condition 1.18
Requirements 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 PMio). 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).
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 10
1.1.1.4 BACT for PM and PMio has been determined to be use of pipeline quality
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 ours 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 these turbines begins when fuel is first
combusted in the turbine or when commencing a combined cycle startup
from simple cycle operation (turbine drops out of Mode 6) and ends 30
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 30 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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 11
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 1.2.1.9, 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 one-hour 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.
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 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
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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 12
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.
Specifically hourly mass NOx emissions (in lb/hr) shall be calculated by multiplying
the hourly NOx lb/MMBtu value (which includes replaced or bias-adjusted data, as
applicable) by the hourly heat input value (MMBtu/hr) (which includes replaced data
from the fuel flow measurement, as applicable). The hourly NOx lb/MMBtu and heat
input values shall be determined using equations F-5 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 lbs value. Hourly NOx mass emissions (lbs) shall be summed and
divided by 2000 lb/ton to determine monthly NOx emissions (in tons).
Monthly emissions (in tons) from each 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 (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
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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 13
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 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 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.
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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 14
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(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. 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 lb/MMBtu value (which includes replaced date in accordance with the
provisions in Part 75 for NOx replacement, as applicable) by the hourly heat input
value (MMBtu/hr) (which includes replaced data from the stack flow measurement,
as applicable). The hourly CO lb/MMBtu and heat input values shall be determined
using equations F-5 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 lbs 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
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).
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 15
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.
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 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 (Colorado Construction Permit 94WE609 PSD).
Compliance with the VOC limitation shall be monitored using the VOC correlation
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 16
(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 lbs/MMBtu, the average of three (3) 1-hr tests (Colorado Regulation No. 1,
Section III.A.I.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 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 FIDB
FIT+FIDB
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
1.6.3 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). 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:
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 17
Emission Factor Source of Emission Factor
(Ib/MMBtu)
Unit PM I PMio
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
[update the above table as necessary once the 2019 test is approved]
Tons/month=[EF(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.
1.6.3.2 Performance testing shall be conducted in accordance with the
requirements in Condition 1.13.
1.7 Particulate Matter less than 10 microns (PMio) 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). 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 PMio shall be calculated using the emission factors identified in
the table in Condition 1.6.3.1 in the following equation:
Tons/month=JEF(lbs/MMBtu)x monthly heat input to turbine(MMBtu/mo)I
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 1.13.
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 of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 18
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, certified, calibrated, maintained and operated for measuring NOx
(including diluent gas either CO2 or O2) and CO emissions (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 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 1.2.2 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 (Colorado Construction Permit 94WE609 PSD, as modified under the
provisions of Section I, Condition 1.3 and 40 CFR Part 75).
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:
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 19
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. (Colorado
Construction Permit 94WE609 PSD and 40 CFR Part 60 Subpart A § 60.12)
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 (Colorado Construction Permit 94WE609
PSD and 40 CFR Subpart A § 60.11(d)).
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 PMio 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 [update below
table when 2019 performance test is approved]:
Unit Performance Test Date
Unit 2—Simple Cycle February 28,2019
Unit 2—Combined Cycle February 27&28,2019
Unit 3—Simple Cycle March 6,2019
Unit 3—Combined Cycle March 5,2019
The compliance test must be conducted in accordance with the APCD Compliance Test Manual
(as updated and amended by the Division, see at
https://www.colorado.,ov/pacific/cdphe/inspections-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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 20
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
(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.
1.16 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 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.
1.18 The turbines and duct burners are subject to the requirements in Colorado Regulation No. 7, Part
E, Section II.A as follows:
Note that on September 18, 2020, the Division requested that the Colorado Air Quality Control
Commission (AQCC) schedule a hearing in December to consider revisions to Colorado
Regulation No. 7. If these revisions are adopted prior to permit issuance, they will be included in
the issued permit. Based on the proposed revisions, Turbines 2 and 3 would be subject to NOx
limits of 15 ppmv at 15% O2, except that when operating at less than 75% of peak load or at
temperatures less than 0 °F, the NOx limits are 96 ppmv at 15% O2. Since these units are
equipped with HRSGs and NOx CEMS, compliance with the limits would be on a 30-day rolling
average and the compliance date would remain the same (October 1, 2021). These requirements
would be included in the permit. In general, the monitoring requirements remain the same (and
will remain streamlined (included in the table in Section IV.3 of this permit)), although the
proposed revisions include some additional monitoring requirements and/or operating
requirements and it is expected that these requirements would also be streamlined (included in
the table in Section IV.3 of this permit).
1.18.1 The following records must be kept for a period of five years and made available to
the Division upon request(Regulation No. 7, Part E, Section II.A.7):
1.18.1.1 The stationary combustion equipment's (turbines) annual capacity factor
on a calendar year basis. (Regulation No. 7, Part E, Section II.A.7.d)
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 21
1.18.2 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. 7, Part E,
Section II.A.6.a.(i))
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 22
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
lbs/MMBtu and Calculation
Combustion Turbine: N/A Fuel Restriction Only Pipeline
0.1 lbs/MMBtu,the average of Quality Natural
three(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
PM,o 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
SO2 2.4 N/A 4.7 tons/yr N/A Continuous Continuously
Monitoring
System
Combustion Turbine and Duct N/A Fuel Restriction See Condition
Burner: 2.4
0.06 lb/MMBtu
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
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
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 for
turbines T002,T003&T004
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 for
turbines T002,T003&T004
combined):
100 ppmvd @ 15%O2 on a 1-hr
average
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 during each
hour
N/A 199.1 tons/yr
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
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
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 1-hr
average and 2,060 lbs/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 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 1-hr
average and 2,060 lbs/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 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
Fuel Flow Meter 2.9 N/A N/A N/A See Condition 2.9
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWEI80 Page 25
Parameter Permit Limitations Compliance Monitoring
Condition Emission
Number Short Term Long Term Factor Method Interval
Compliance 2.10 N/A N/A N/A See Condition 2.10
Assurance
Monitoring
Requirements—
For Combined
Cycle Operation
Sulfur Content of 2.11 N/A N/A N/A See Condition 2.11.
Natural Gas
NSPS General 2.12 N/A N/A N/A As required by Subject to NSPS
Provisions NSPS General General
Provisions Provisions
Opacity 2.13 Not to Exceed 20%Except as N/A Fuel Restriction Only Pipeline
Provided for in 2.14 Quality Natural
Gas is Used as
Fuel
Opacity 2.14 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 2.15 Not to Exceed 20% N/A
Opacity
Acid Rain 2.16 See Section III of this Permit Certification Annually
Requirements
Regulation No.7, 2.17 Maintain Records of Capacity Factor) Calculation Annually
Part E,Section (Calendar Year)
II.A
Requirements Combustion Process Adjustment and Recordkeeping See Condition 2.17
Requirements
NSPS Subpart 2.18 N/A NA N/A See Condition 2.18
KKKK General
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
PMlo). BACT has been determined as follows:
2.1.1.1 BACT for NOx has been determined to be Dry Low NOx combustion
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 26
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
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 PMio emissions are subject to the following requirements:
2.2.1 Emissions of PM and PMio from the combustion turbine/HRSG/duct burner shall
not exceed 54 tons/yr (Colorado Construction Permit 99WE0762 PSD). The annual
emission limitations include both filterable and condensable particulate matter.
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=jEF(lbs/MMBtu)x(monthly heat input to turbine(MMBtu/mo)
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 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.
2.2.2 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:
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 27
PE (turbine+duct burner) =PET x FIT+PEDB x FIDB
FIT+FIDB
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
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 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.
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 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 SO2/J (0.060 lb
SO2/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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE1 80 Page 28
as fuel in the turbine. The natural gas used as fuel shall meet the requirements in
Condition 2.11.
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 turbines T002, T003 and T004
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" 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.
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 and shall also include testing and tuning
of the selective catalytic reduction (SCR) system.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit#97OPWE180 Page 29
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 one-hour 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. 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 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 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 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 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 For purposes of 40 CFR Part 60 Subpart KKKK, NOx emissions from the
combustion turbine/HRSG/duct burner are subject to the following requirements:
The requirements in this Condition 2.5.2, as well as Conditions 2.4.2 and 2.18 reflect
the rule language in 40 CFR Part 60 Subpart KKKK as of the latest revisions to 40
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 30
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:
2.5.2.1 Except as provided for below, NOx emissions shall not exceed 15 ppm at
15 %O2.
2.5.2.2 When operating at less than 75% of the peak load, NOx emissions shall
not exceed 96 ppm at 15% O2.
2.5.2.3 When operating at temperatures less than on 0 °F, NOx emissions shall
not exceed 96 ppm at 15% O2.
2.5.2.4 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 2.5.2 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 NS1 S KKKK NOx emission shall be monitored using the
continuous emission monitoring systems (CEMS) required by Condition 2.8, as
follows:
2.5.2.5 All CEMS data must be reduced to hourly averages as specified in
§60.13(h). (60.4350(a))
2.5.2.6 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 lb/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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 31
average CO2 concentration is less than 1.0 percent CO2), a diluent cap
value of 19.0 percent O2 or 1.0 percent CO2 (as applicable) may be used in
the emission calculations. (60.4350(b))
2.5.2.7 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))
2.5.2.8 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))
2.5.2.9 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))
2.5.2.10 Further provisions regarding reporting excess emissions are provided for
in Condition 5.6.3.
Initial Performance Test Requirements
2.5.2.11 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))
2.5.2.12 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))
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 32
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 lb/MWh, does not
exceed the emission limit. (60.4405(d))
2.5.3 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. 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.
Monthly emissions (in tons) from the combustion turbine/HRSG/duct burner shall
be used in 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
of CO shall not exceed 9 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.
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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 33
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 and shall also include testing and tuning
of the selective catalytic reduction (SCR) system.
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 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 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 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 limitation in Condition 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 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 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.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 34
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. 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 lb/MMBtu value (which includes replaced date in accordance with the
provisions in Part 75 for NOx replacement, as applicable) by the hourly heat input
value (MMBtu/hr) (which includes replaced data from the stack flow measurement,
as applicable). The hourly CO lb/MMBtu and heat input values shall be determined
using equations F-5 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 lbs value.
Hourly CO mass emissions (lbs) shall be summed and divided by 2000 lb/ton to
determine monthly CO emissions (in tons).
Monthly emissions (in tons) from the combustion turbine/HRSG/duct burner shall
be used in 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.
2.7 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 For each combustion turbine/HRSG/duct burner, continuous emission monitoring systems
(CEMS) shall be installed, certified, calibrated, maintained and operated for measuring NOx
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 35
(including diluent gas either CO2 or O2) and CO emissions (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 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 2.5.3 and 2.6.2 to monitor compliance with the annual
NOx and CO emission limitations.
2.9 Each turbine/HRSG/duct burner shall be equipped with an in-line fuel flow meter that meets
the requirements in 40 CFR Part 75 Appendix D to measure fuel combusted in each turbine.
Fuel flow data shall be recorded on a data acquisition and handling system as specified in 40
CFR Part 75 Appendix D (Colorado Construction Permit 99WE762, as modified under the
provisions of Section I, Condition 1.3 and 40 CFR Part 75).
2.10 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:
2.10.1 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.
2.10.2 Operation of Approved Monitoring
2.10.2.1 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).
2.10.2.2 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
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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).
2.10.2.3 Response to excursions or exceedances
a. Upon detecting an excursion or exceedance, the owner or operator
shall restore operation of the pollutant-specific emissions unit
(including the control device and associated capture system) to its
normal or usual manner of operation as expeditiously as
practicable in accordance with good air pollution control practices
for minimizing emissions. The response shall include minimizing
the period of any startup, shutdown or malfunction and taking any
necessary corrective actions to restore normal operation and
prevent the likely recurrence of the cause of an excursion or
exceedance (other than those caused by excused startup or
shutdown conditions). Such actions may include initial inspection
and evaluation, recording that operations returned to normal
without operator action (such as through response by a
computerized distribution control system), or any necessary
follow-up actions to return operation to within the indicator range,
designated condition, or below the applicable emission limitation
or standard, as applicable (40 CFR Part 64 § 64.7(d)(1), as adopted
by reference in Colorado Regulation No. 3, Part C, Section XIV).
b. Determination of whether the owner of operator has used
acceptable procedures in response to an excursion or exceedance
will be based on information available, which may include but is
not limited to, monitoring results, review of operation and
maintenance procedures and records, and inspection of the control
device, associated capture system, and the process (40 CFR Part 64
§ 64.7(d)(2), as adopted by reference in Colorado Regulation No.
3, Part C, Section XIV).
2.10.2.4 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
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reference in Colorado Regulation No. 3, Part C, Section XIV).
2.10.3 Quality Improvement Plan (QIP) Requirements
2.10.3.1 Based on the results of a determination made under the provisions of
Condition 2.10.2.3.b, the Division may require the owner or operator to
develop and implement a QIP (40 CFR Part 64 § 64.8(a), as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV).
2.10.3.2 The owner or operator shall maintain a written QIP, if required, and have
it available for inspection (40 CFR Part 64 § 64.8(b)(1), as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV).
2.10.3.3 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 2.10.3.3.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).
2.10.3.4 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).
2.10.3.5 Following implementation of a QIP, upon any subsequent determination
pursuant to Condition 2.10.2.3.b, the Division or the U.S. EPA may
require that an owner or operator make reasonable changes to the QIP if
the QIP is found to have:
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
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Colorado Operating Permit Ft. St. Vrain Station
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a. Failed to address the cause of the control device performance
problems (40 CFR Part 64 § 64.8(d)(1), as adopted by reference in
Colorado Regulation No. 3, Part C, Section XIV); or
b. Failed to provide adequate procedures for correcting control device
performance problems as expeditiously as practicable in
accordance with good air pollution control practices for
minimizing emissions (40 CFR Part 64 § 64.8(d)(2), as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV).
2.10.3.6 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).
2.10.4 Reporting and Recordkeeping Requirements
2.10.4.1 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 2.10.3 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).
2.10.4.2 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 2.10.3 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
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maintenance or corrective actions) (40 CFR Part 64 § 64.9(b)(1),
as adopted by reference in Colorado Regulation No. 3, Part C,
Section XIV).
b. Instead of paper records, the owner or operator may maintain
records on alternative media, such as microfilm, computer files,
magnetic tape disks, or microfiche, provided that the use of such
alternative media allows for expeditious inspection and review,
and does not conflict with other applicable recordkeeping
requirements (40 CFR Part 64 § 64.9(b)(2), as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV).
2.10.5 Savings Provisions
2.10.5.1 Nothing in these CAM requirements shall excuse the owner or operator of
a source from compliance with any existing emission limitation or
standard, or any existing monitoring, testing, reporting or recordkeeping
requirement that may apply under federal, state, or local law, or any other
applicable requirements under the federal clean air act. These CAM
requirements shall not be used to justify the approval of monitoring less
stringent than the monitoring which is required under separate legal
authority and are not intended to establish minimum requirements for the
purposes of determining the monitoring to be imposed under separate
authority under the federal clean air act, including monitoring in permits
issued pursuant to title I of the federal clean air act. The purpose of the
CAM requirements is to require, as part of the issuance of this Title V
operating permit, improved or new monitoring at those emissions units
where monitoring requirements do not exist or are inadequate to meet the
requirements of CAM (40 CFR Part 64 § 64.10(a)(1), as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV).
2.10.5.2 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).
2.10.5.3 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).
2.11 The permittee shall maintain records demonstrating that the natural gas burned has a total sulfur
content less than 0.5 grains/100 SCF. Natural gas that meets this sulfur limitation is considered
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
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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.
2.12 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:
2.12.1 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. (40 CFR Part
60 Subpart A § 60.12, as adopted in Colorado Regulation No. 6, Part A)
2.12.2 At all times, including periods of startup, shutdown, and malfunction, owners and
operators shall to the extent practicable, maintain and operate any affected facility
including associated air pollution control equipment in a manner consistent with good
air pollution control practice for minimizing emissions. Determination of whether
acceptable operating and maintenance procedures are being used will be based on
information available to the Division which may include, but is not limited to
monitoring results, opacity observations, review of operating and maintenance
procedures, and inspection of the source (40 CFR Subpart A § 60.11(d), as adopted
by reference in Colorado Regulation N. 6, Part A).
2.13 Except as provided for in Condition 2.14 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.
2.14 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. 1, 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.
2.15 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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
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Colorado Operating Permit Ft. St. Vrain Station
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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.
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).
2.16 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.
2.17 The turbine and duct burner are subject to the requirements in Colorado Regulation No. 7, Part
E, Section II.A as follows:
2.17.1 The following records must be kept for a period of five years and made available to
the Division upon request(Regulation No. 7, Part E, Section II.A.7):
2.17.1.1 The stationary combustion equipment's (turbines) annual capacity factor
on a calendar year basis. (Regulation No. 7, Part E, Section II.A.7.d)
2.17.2 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. 7, Part E,
Section II.A.6.a.(i))
2.18 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))
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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 lbs/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 Condition 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 as
Periods Aggregating More than Fuel
Six(6)Minutes in Any Sixty
Consecutive Minutes
Regulation No. 3.6 NOx emissions not to exceed 0.2 N/A Performance Every Two(2)
7,Part E, Ib/MMBtu,on a 30-day rolling - Test Years
Section II.A average
Requirements Combustion Process Adjustment See Condition Annually
Requirements 3.6
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=[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 I, 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.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
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Colorado Operating Permit Ft. St. Vrain Station
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3.3 Particulate Matter (PM) emissions shall not exceed the limitation above (Colorado Regulation
No. 1, Section II.A.1.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.
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.
3.6 The boiler is subject to the requirements in Colorado Regulation No. 7, Part E, Section II.A as
follows:
Note that the language below is from Colorado Regulation No. 7, adopted by the Colorado Air
Quality Control Commissions (AQCC) on September 23, 2020 (effective November 14, 2020).
However, if revisions to Colorado Regulation No. 7, Part E, 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.
Note that on September 18, 2020, the Division requested that the AQCC schedule a hearing in
December to consider revisions to Colorado Regulation No. 7. If these revisions are adopted
prior to permit issuance, they will be included in the issued permit. Based on the proposed
revisions, the NOx limit in Condition 3.6.3.1 for this unit will be reduced to 0.1 lb/MMBtu or 83
ppmv corrected to 3% O2.
3.6.1 Applicability. (Regulation No. 7, Part E, Section II.A)
3.6.1.1 Except as provided in Section II.A.2. (Condition 3.6.2), 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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
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Colorado Operating Permit Ft. St. Vrain Station
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Control Area. (Regulation No. 7, Part E, Section II.A.1.a)
3.6.1.2 Except as provided in Section II.A.2. (Condition 3.6.2), the requirements
of 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
50 tpy NOx) as of [January 27, 2020], located in the 8-Hour Ozone
Control Area, that is not already subject as provided under Section
II.A.1.a. (Regulation No. 7, Part E, Section II.A.I.b)
3.6.2 Exemptions. (Regulation No. 7, Part E, Section II.A.2)
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.8, 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. 7, Part E,
Section II.A.2)
3.6.2.1 Any stationary combustion equipment whose utilization is less than 20%
of its capacity factor on an annual average basis over a 3-year rolling
period for boilers. (Regulation No. 7, Part E, Section II.A.2.a.(i))
3.6.2.2 Any stationary combustion equipment with total uncontrolled actual
emissions less than 5 tpy NOx on a calendar year basis. (Regulation No. 7,
Part E, Section II.A.2.d)
3.6.3 Emission Limitations. By July 20, 2021, no owner or operator of stationary
combustion equipment specified in Section II.A.1.b. 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. (Regulation
No. 7, Part E, Section II.A.4, 2nd paragraph).
3.6.3.1 For a liquid or gaseous fuel-fired boiler at a major source of NOx (greater
than or equal to 50 tpy NOx as of [January 27, 2020]) with a maximum
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
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Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
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design heat input capacity equal to or greater than 50 MMBtu/hr but less
than 100 MMBtu/hr, 0.2 lb/MMBtu of heat input or less than 165 parts per
million dry volume corrected to 3% oxygen. (Regulation No. 7, Part E,
Section II.A.4.a.(iv))
3.6.3.2 Boilers subject to the categorical limits in Section II.A.4.a.(i) through (iv)
or boilers with a maximum design heat input capacity less than 100
MMBtu/hr must comply with the combustion process adjustment
requirements contained in Section II.A.6 (see Conditions 3.6.5 and 10.1).
while burning gaseous fuel, liquid fuel, or any combination thereof, when
required by Section II.A.6.a (Condition 10.1.1). (Regulation No. 7, Part E,
Section II.A.4.a.(v)
3.6.4 Compliance Demonstration. (Regulation No. 7, Part E, Section II.A.5)
3.6.4.1 By July 20, 2021, for stationary combustion equipment specified in
Section II.A.I.b. (Condition 3.6.1.2), 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 Sections II.A.5. (Regulation No. 7, Part E, Section II.A.5.b)
3.6.4.2 Emissions monitoring requirements for major source RACT limits
(Regulation No. 7, Part E, Section II.A.5.c)
a. Except as otherwise provided for in Section II.A.5.c.(ii)(A), the
owner or operator of an affected unit subject to a NOx emission
limitation contained in Sections II.A.4.a.(iv) (Condition 3.6.3.1),
4.b., or 4.e. that is not equipped with NOx CEMS or CERMS, must
conduct an initial performance test and subsequent performance
tests every 2 years thereafter, according to the following
requirements, as applicable, to determine the affected unit's NOx
emission rate for each fuel fired in the affected unit. A
performance test is not required for a fuel used only for startup or
for a fuel constituting less than 2% of the unit's annual heat input,
as determined at the end of each calendar year. (Regulation No. 7,
Part E, Section II.A.5.c.(ii)(B))
(i) Initial performance test must include a determination of the
capacity load point of the unit's maximum NOx emissions
rate based on one 30 minute test run at each capacity load
point for which the unit is operated, other than for startup
and shutdown, in the load ranges of 20 to 30%, 45 to 55%,
and 70 to 100%. Subsequent performance tests must be
performed within the capacity load range determined to
result in the maximum NOx emissions rate. (Regulation
No. 7, Part E, Section II.A.5.c.(ii)(B)(1))
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
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Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
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(ii) Performance tests must determine compliance with Section
II.A.4. based on the average of three 60-minute test runs
performed at the capacity load determined in
II.A.5.c.,(ii)(B)(1). (Regulation No. 7, Part E, Section
II.A.5.c.(ii)(B)(2))
b. All performance tests must be conducted in accordance with EPA
test methods and a test protocol submitted to the Division for
review at least thirty (30) days prior to testing and in accordance
with AQCC Common Provisions Regulation Section II.C.
(Regulation No. 7, Part E, Section II.A.5.c.(ii)(C))
3.6.5 Combustion Process Adjustment (Colorado Regulation No. 7, Part E, Section
II.A.6)
The combustion process adjustment requirements in Section II.A.6 as set forth in
Condition 10.1 apply to the boiler provided actual, uncontrolled emissions are equal
to or greater than 5 tons per year of NOx.
3.6.6 Recordkeeping (Regulation No. 7, Part E, 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. 7, Part E, Section II.A.7):
3.6.6.1 The stationary combustion equipment's annual capacity factor on a
calendar year basis. (Regulation No. 7, Part E, Section II.A.7.d)
3.6.6.2 All records generated to comply with the reporting requirements contained
in Section II.A.8. (Regulation No. 7, Part E, Section II.A.7.e)
3.6.6.3 The recordkeeping requirements for combustion process adjustments
(Regulation No. 7, Part B, Section II.A.7.f) are set forth in Condition 10.2.
3.6.6.4 All sources qualifying for an exemption under Section II.A.2. (Condition
3.6.2) must maintain all records necessary to demonstrate that an
exemption applies. (Regulation No. 7, Part E, Section II.A.7.g)
3.6.7 Reporting (Regulation No. 7, Part E, Section II.A.8)
3.6.7.1 For affected units demonstrating compliance with Section II.A.4 using
performance testing pursuant to Section II.A.5.c.(ii)(C), the owner or
operator must submit to the Division the following information
(Regulation No. 7, Part E, Section II.A.8.b(:
a. Performance test reports within 60 days after completion of the
performance test program. All performance test reports must
determine compliance with the applicable emission limitations set
by Section II.A.4. (Regulation No. 7, Part E, Section II.A.8.b.(i))
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit#97OPWE180 Page 47
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
PMio 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-Annually
Concentration Analysis
Opacity 4.4 Not to Exceed 20% N/A See Condition 4.4
4.1 Particulate Matter (PM and PM to) 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=PKo(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/106 lbs water) - to be determined by Condition 4.3. The most
recent analysis shall be used in the monthly calculation.
VOC=CHC13(tons/month)=Q x EF x(1 mmgal/106 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
summed together and used in a twelve month rolling total to monitor compliance with the annual
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 48
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. A copy of operating and maintenance procedures, schedules for maintenance and/or
inspection activities and records related to maintenance of the drift eliminators and good
engineering practices such as records of inspection, repair or replacement shall be made available
to the Division upon request.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 49
5. Continuous Emission Monitoring Systems (CEMS)
The following requirements apply to the NOx, CO and diluent (either O2 or CO2) continuous emission
monitoring systems (CEMS) required by Conditions 1.10, 2.8 and 8.10. Note that the continuous
emission monitoring requirements identified in this Condition, are in addition to the continuous emission
monitoring requirements required by the Acid Rain Program, which are identified in Section III of this
permit
5.1 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 (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; and
5.1.7 Operating mode—startup, shutdown and/or standard operation.
5.2 Equipment and QA/QC Requirements
5.2.1 The Continuous Emission Monitoring Systems are subject to the following
requirements:
5.2.1.1 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 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.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE1 80 Page 50
a. The CO CEMS data shall meet the applicable "primary equipment
hourly operating requirements" for hourly average calculation
methodology specified in 40 CFR Part 75 Subpart B § 75.10(d).
b. Annual CO monitor relative accuracy (RA) testing will be
performed in ppm @ 15% O2 measurement units, and will be
performed according to 40 CFR Part 60, Appendix B, Performance
Specification 4A.
c. Relative accuracy test audit (RATA) frequency will be determined
according to 40 CFR Part 75 Appendix B.
5.2.1.2 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.
5.2.1.3 The NOx and CO CEMS are subject to the following requirements:
a. Relative Accuracy Test Audits (RATAs): RATAs shall be
conducted in the units (e.g., lb/MMBtu, ppm) of the emission
limitation for all of the emission limitations that are applicable to
the emissions unit. The RATAs for emissions units that have
annual emission limitations (tons/yr)will be conducted in terms of
pounds per hour(lb/hr).
b. The DAHS shall be able to record and manipulate the data in the
units (e.g., lb/MMBtu,ppm) of the emission limitation and meet
the reporting requirements for all for the emissions limitations that
are applicable to the emissions unit.
5.2.2 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.
5.2.2.2 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.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit#97OPWE180 Page 51
5.3 General Provisions
5.3.1 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)).
5.3.2 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)).
5.3.3 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.
5.3.4 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.
5.3.5 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.
5.3.6 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 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).
5.4 Data Replacement Requirements
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 52
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 (Colorado Construction 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). 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.
5.5 Recordkeeping and Reporting Requirements
5.5.1 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. The source requested quarterly reporting to be consistent
with the Acid Rain reporting requirements). 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))
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. (§ 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 (§ 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(§ 60.7(c)(4)).
5.5.2 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))
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWEI 80 Page 53
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))
5.6 Specific Provisions for NSPS Subpart KKKK
The following requirements apply to Turbines 5 and 6 only.
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.
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) (Condition 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.
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 NOx
emission rate" is the arithmetic average of the average NOx emission rate
in ppm or ng/J (lb/MWh) measured by the continuous emission
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 54
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. (§ 60.43 80(b)(1), includes just the language
for 4-hr rolling averages, as that applies to these turbines)
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. (§ 60.43 80(b)(2))
5.6.3.3 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)(2))
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit#97OPWE180 Page 55
6. M002 - Gasoline Storage Tank, 500 gallons aboveground
Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
40 CFR Pat 63 6.1 Work Practice Standards N/A See Condition 6.1
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, as long as actual, uncontrolled emissions do not exceed the APEN de minimis level
(see Regulation No.3,Part A,Section II.D.1.a).
6.1 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:
The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63
Subpart CCCCCC published in the Federal Register on January 24, 2011. However, if revisions
to this Subpart are published at a later date, the owner or operator is subject to the requirements
contained in the revised version of 40 CFR Part 63 Subpart CCCCCC.
These requirements have not been adopted into Colorado Regulation No. 8, Part E as of the date
of this permit issuance [DATE], and are therefore not state-enforceable. In the event that these
requirements are adopted into Colorado Regulations, they will become state-enforceable.
Am I subject to the requirements in this subpart? 0 63.11111)
6.1.1 If your GDF has a monthly throughput of less than 10,000 gallons of gasoline, you
must comply with the requirements in §63.11116 (Conditions 6.1.8 through 6.1.11).
(§ 63.11111(b)).
6.1.2 An affected source shall, upon request by the Administrator, demonstrate that their
monthly throughput is less than the 10,000-gallon or the 100,000-gallon threshold
level, as applicable. For new or reconstructed affected sources, as specified in
§63.11112(b) and (c), recordkeeping to document monthly throughput must begin
upon startup of the affected source. For existing sources, as specified in
§63.11112(d), recordkeeping to document monthly throughput must begin on January
10, 2008. For existing sources that are subject to this subpart only because they load
gasoline into fuel tanks other than those in motor vehicles, as defined in §63.11132,
recordkeeping to document monthly throughput must begin on January 24, 2011.
Records required under this paragraph shall be kept for a period of 5 years. (§
63.11111(e)).
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 56
6.1.3 If your affected source's throughput ever exceeds an applicable throughput threshold,
the affected source will remain subject to the requirements for sources above the
threshold, even if the affected source throughput later falls below the applicable
throughput threshold. (§ 63.11111(i))
6.1.4 The dispensing of gasoline from a fixed gasoline storage tank at a GDF into a
portable gasoline tank for the on-site delivery and subsequent dispensing of the
gasoline into the fuel tank of a motor vehicle or other gasoline-fueled engine or
equipment used within the area source is only subject to §63.11116 of this subpart.
(Conditions 6.1.8 through 6.1.11). (§ 63.11111(j))
When do I have to comply with this subpart? ((63.11113)
6.1.5 If you start up your affected source after January 10, 2008, you must comply with the
standards in this subpart upon startup of your affected source (§ 63.11113(a)(1)).
What are my general duties to minimize emissions? ('63.11115)
6.1.6 You must, at all times, 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.
Determination of whether such operation 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, review of operation and maintenance procedures,
review of operation and maintenance records, and inspection of the source. (§
63.11115(a))
6.1.7 You must keep applicable records and submit reports as specified in §63.11125(d)
and §63.11126(b). (§ 63.11115(b)) Records and reports noted in this permit
condition are related to malfunctions. Note that since this source is not subject to any
emission limitations and is specifically exempt from reporting requirements as
specified in Condition 6.1.9, the reporting requirements in § 63.1125(d) do not apply
to this source. (§ 63.11115(b))
Requirements for facilities with monthly throughput of less than 10,000 gallons of gasoline. (.
63.11116)
6.1.8 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(§ 63.11116(a)):
6.1.8.1 Minimize gasoline spills;
6.1.8.2 Clean up spills as expeditiously as practicable;
6.1.8.3 Cover all open gasoline containers and all gasoline storage tank fill-pipes
with a gasketed seal when not in use;
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 57
6.1.8.4 Minimize gasoline sent to open waste collection systems that collect and
transport gasoline to reclamation and recycling devices, such as oil/water
separators;
6.1.9 You are not required to submit notifications or reports as specified in §63.11125,
§63.11126, or subpart A of this part, but you must have records available within 24
hours of a request by the Administrator to document your gasoline throughput. (§
63.11116(b)). Records shall be kept as required by Section V, General Conditions
22.b and c of this permit.
6.1.10 You must comply with the requirements of this subpart by the applicable date
specified in Condition 6.1.5. (§ 63.11116(c)).
6.1.11 Portable gasoline containers that meet the requirements of 40 CFR part 59, subpart F,
are considered acceptable for compliance with Condition 6.1.8.3. (§ 63.11116(d))
What are my recordkeeping requirements? ('63.11125)
6.1.12 Each owner or operator of an affected source under this subpart shall keep records as
specified below. (§ 63.11125(d))
6.1.12.1 Records of the occurrence and duration of each malfunction of operation
(i.e., process equipment) or the air pollution control and monitoring
equipment. (§ 63.11125(d)(1))
6.1.12.2 Records of actions taken during periods of malfunction to minimize
emissions in accordance with §63.11115(a) (Condition 6.1.6), including
corrective actions to restore malfunctioning process and air pollution
control and monitoring equipment to its normal or usual manner of
operation. (§ 63.11125(d)(2))
What parts of the General Provisions apply to me? 63.11125)
6.1.13 Table 3 to this subpart shows which parts of the General Provisions apply to you. (§
63.11130) The general provisions that apply to this GDF include, but are not limited
to the following:
6.1.13.1 Prohibited activities in § 63.4(a).
6.1.13.2 Circumvention in § 63.4(b).
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 58
7. M003—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, as long as actual, uncontrolled emissions do not exceed the APEN de minimis level
(see Regulation No.3,Part A, Section II.D.1.a).
7.1 Operation of the cold cleaner solvent vats shall meet the standards defined in Colorado
Regulation 7, Part C, Section II.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, Part C, Section II.B and shall be made 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, Part C, Section
II.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, Part C, Section II.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 of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 59
8. T005 & T006—Two (2) Simple Cycle Combustion Turbines
Unless otherwise specified,the limitations apply to both turbines together
Parameter 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 below Monitoring
During Combustion Tuning and System
Testing(not to exceed 60 hrs/yr for
turbines T005&T006 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 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 4-hour rolling.
For periods when multiple standards
apply,the applicable standard is the
average of applicable standards during
each hour
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 of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 60
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 lb/MMBtu,the average of three Restriction Quality
(3) 1-hr tests Natural Gas is
Used as Fuel
N/A 8.9 tons/yr T005: Recordkeeping Monthly
0.004 lb/MMBtu and
T006: Calculation
_ 0.003 Ib/MMBtu
PMio 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
Fuel Flow Meter 8.11 N/A N/A N/A See Condition 8.11
NSPS Subpart 8.12 N/A N/A N/A See Condition 8.12
KKKK General
Requirements
NSPS General 8.13 N/A N/A N/A As Required Subject to
Provisions by NSPS NSPS General
General Provisions
Provisions
NOx Emissions 8.14 N/A N/A N/A See Condition 8.14
from
Insignificant
Activities
Opacity 8.15 Not to Exceed 20%Except as N/A Fuel Only Pipeline
Provided for in 8.16 Below Restriction Quality
Opacity 8.16 For Certain Operational Activities- N/A Natural Gas is
Not to Exceed 30%,for a Period or Used as Fuel
Periods Aggregating More than Six
(6)Minutes in any 60 Consecutive
Minutes
Opacity—State 8.17 Not to Exceed 20% N/A
Only
Acid Rain 8.18 See Section III of this Permit Certification Annually
Requirements
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit • Ft. St. Vrain Station
Permit# 97OPWE180 Page 61
Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
Restrictions on 8.19 See Condition 8.19 N/A Certification Annually
Relaxing
Emission
Limitations
Regulation No. 8.20 Maintain Records of Capacity Factor) N/A Calculation Annually
7,Part E, (Calendar
Section ILA Year)
Requirements Combustion Process Adjustment and See Condition 8.20
Recordkeeping Requirements
8.1 The combustion turbines are subject to the Reasonably Available Control Technology
Requirements (RACT) for NOx (Colorado Construction Permit 07WE1100 and Colorado
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 1-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 Turbines T005 and T006
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.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 62
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, as follows:
8.2.1.7 Except as provided for in Condition 8.2.1.8, 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 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 8.2.1.1 and 8.2.1.2 as appropriate.
8.2.1.8 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.
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 average NOx concentration shall be compared to the
limitations in Conditions 8.2.1.1 and 8.2.1.2 as appropriate.
8.2.1.9 The emission limits in Condition 8.2.1.2 apply to any clock hour in which
combustion tuning and testing activities occur.
8.2.2 For purposes of 40 CFR Part 60 Subpart KKKK, NOx emissions from each turbine
shall not exceed the following:
The requirements in this Condition 8.2.2, as well as Conditions 8.4.1 and 8.12 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.
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:
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 63
8.2.2.1 Except as provided for below, NOx emissions shall not exceed 15 ppm at
15 % O2.
8.2.2.2 When operating at less than 75% of the peak load, NOx emissions shall
not exceed 96 ppm at 15% O2,
8.2.2.3 When operating at temperatures less than on 0 °F, NOx emissions shall
not exceed 96 ppm at 15% O2.
(Colorado Construction Permit 07WE1100 and 40 CFR Part 60 Subpart
KKKK § 60.4320(a))
8.2.2.4 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. (40 CFR Part 60 Subpart KKKK §
60.4380(b)(3))
Compliance with the above NSPS KKKK NOx emission shall be monitored using the
continuous emission monitoring systems (CEMS) required by Condition 8.10, as
follows:
8.2.2.5 All CEMS data must be reduced to hourly averages as specified in
§60.13(h). (§ 60.4350(a))
8.2.2.6 For each unit operating hour in which a valid hourly average 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 lb/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 CO2
concentration is less than 1.0 percent CO2), a diluent cap value of 19.0
percent O2 or 1.0 percent CO2 (as applicable) may be used in the emission
calculations. (§ 60.4350(b))
8.2.2.7 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) (Condition 5.5). (§ 60.4350(d))
8.2.2.8 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))
8.2.2.9 For simple cycle units without heat recovery, use the calculated hourly
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 64
average emission rates to assess excess emissions on a 4-hour rolling
average basis, as described in §60.4380(b)(1) (Condition 5.6.3.1). (§
60.4350(g))
8.2.2.10 Further provisions regarding reporting excess emissions are provided for
in Condition 5.6.3.
Note that the NOx emission limits in this Condition 8.2.2 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.
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. 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.
Specifically hourly mass NOx emissions (in lb/hr) shall be calculated by multiplying
the hourly NOx lb/MMBtu value (which includes replaced or bias-adjusted data, as
applicable) by the hourly heat input value (MMBtu/hr) (which includes replaced data
from the fuel flow measurement, as applicable). The hourly NOx lb/MMBtu and heat
input values shall be determined using equations F-5 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 lbs value. Hourly NOx mass emissions (lbs) shall be summed and
divided by 2000 lb/ton to determine monthly NOx emissions (in tons).
Monthly emissions (in tons) from each turbine 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.
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. 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.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 65
Specifically hourly mass CO emissions (in lb/hr) shall be calculated by multiplying the hourly
CO lb/MMBtu value (which includes replaced date in accordance with the provisions in Part 75
for NOx replacement, as applicable) by the hourly heat input value (MMBtu/hr) (which includes
replaced data from the stack flow measurement, as applicable). The hourly CO lb/MMBtu and
heat input values shall be determined using equations F-5 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 lbs value.
Hourly CO mass emissions (lbs) shall be summed and divided by 2000 lb/ton to determine
monthly CO emissions (in tons).
Monthly emissions (in tons) from each turbine 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.
8.4 Sulfur Dioxide (SO2) emissions shall not exceed the following limitations:
8.4.1 For purposes of 40 CFR Part 60 Subpart KKKK, SO2 emissions from each
combustion turbine are subject to the following requirements (Colorado
Construction Permit 07WE1100):
If your turbine is located in a continental area, you must comply with 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 SO2/J (0.060 lb
SO2/MMBtu) heat input. (§ 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
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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 66
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.1.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). The annual
emission limitation includes both filterable and condensable particulate matter.
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 PMio 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). The annual emission limitation includes both
filterable and condensable particulate matter. 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.
8.8 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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 67
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/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. 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, certified, calibrated, maintained and operated for measuring NOx(including diluent gas
either CO2 or O2) and CO emissions (Colorado Construction Permit 07WE1100 and 40 CFR Part
75). The continuous emission monitoring systems shall meet the requirements in Condition 5 of
this permit. Monthly emissions of NOx and CO from the continuous emission monitoring system
shall be used as specified by Conditions 8.2.3 and 8.3 to monitor compliance with the annual
NOx and CO emission limitations.
8.11 Each turbine shall be equipped with an in-line fuel flow meter that meets the requirements in 40
CFR Part 75 Appendix D to measure fuel combusted in each turbine. Fuel flow data shall be
recorded on a data acquisition and handling system as specified in 40 CFR Part 75 Appendix D
(Colorado Construction Permit 07WE1100, as modified under the provisions of Section I,
Condition 1.3).
8.12 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))
8.13 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:
8.13.1 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. (40 CFR §
60.12)
8.13.2 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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 68
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)).
8.14 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.
8.15 Except as provided for in Condition 8.16 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
(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.
8.16 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 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.
8.17 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).
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 69
8.18 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.
8.19 The requirements of Colorado Regulation No. 3, Part D shall apply to these turbines at such time
that any stationary source or modification becomes a major stationary source or major
modification solely by virtue of a relaxation in any enforceable limitation that was established
after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant
such as a restriction on hours of operation (Colorado Construction Permit 07WE1100 and
Colorado Regulation No. 3, Part D, Sections VI.B.4 and V.A.7.B).
With respect to this Condition 8.19, Colorado Regulation No. 3, Part D requirements may apply
to future modifications if the emission limitations are modified to equal or exceed the following
thresholds:
Emissions(tons/yr)
Pollutant Program Comment/Explanation
Threshold Current Permit Limit
PM PSD 25 8.9
PM,o PSD 15 8.9
NOx NANSR 40' 39.9
NOx PSD 40 39.9
CO PSD 100 20
'Represents the NANSR significance level at the time these units were permitted (initial approval construction
permit(07WE1100)issued February 6,2008).
8.20 The turbines are subject to the requirements in Colorado Regulation No. 7, Part E, Section II.A
as follows:
8.20.1 The following records must be kept for a period of five years and made available to
the Division upon request (Regulation No. 7, Part E, Section II.A.7):
8.20.1.1 The stationary combustion equipment's (turbines) annual capacity factor
on a calendar year basis. (Regulation No. 7, Part E, Section II.A.7.d)
8.20.2 The combustion process adjustment and associated recordkeeping requirements in
Condition 10 apply any turbine with actual, uncontrolled emissions equal to or greater
than 5 tons per year of NOx. (Colorado Regulation No. 7, Part E, Section II.A.6.a.(i))
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 70
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 lbs/M1vIBtu N/A Fuel Only Diesel
Restriction 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
Regulation No. 9.4 Maintain Records N/A See Condition 9.4
7,Part E, Demonstrating Exemption
Section II.A
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,as long as actual,uncontrolled emissions do not exceed the APEN de minimis level
(see Regulation No.3,Part A,Section II.D.1.a).Based on the AP-42 Emission Factors(emergency generators: Section 3.4,dated
10/96,Table 3.4-1 (NOx-0.024 lb/hp-hr)and emergency fire pump: Section 3.3,dated 10/96,Table 3.3-1 (NOx-0.031 lb/hp-hr))
and design rate(emergency generators: 1800 hp,each and emergency fire pump: 255 hp)emissions exceed the APEN de minimis
level at 46 hr/yr(each emergency generator)and 232 hrs/yr(emergency fire pump)..
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:
The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63
Subpart ZZZZ published in the Federal Register on January 30, 2013 (including the corrections
published March 6, 2013 and revisions to test methods published February 27, 2014). 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 63 Subpart ZZZZ.
The D. C. Circuit Court issued a mandate on May 4, 2016 for vacatur for certain requirements
allowing emergency engines to operate for limited hours for demand response. Upon issuance of
the mandate § 63.6640(f)(2)(ii)-(iii) (Conditions 9.1.11.2.b and 9.1.11.2.c) have no legal effect.
Operation of emergency engines is limited to emergency situations specified in 63.6640(0(1)
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
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(Condition 9.1.11.1); maintenance checks and readiness testing for a limited number of hours
per year as specified in 63.6640(f)(2)(i) (Condition 9.1.11.2.a); and certain non-emergency
situations for a limited number of hours per year as specified in 63.6640(f)(3)—(4) (Condition
9.1.11.3). See EPA memorandum dated April 15, 2016 regarding "Guidance on Vacatur of RICE
NESHAP and NSPS Provisions for Emergency Engines" for more information.
It should be noted that additional revisions to the requirements in 40 CFR Part 63 Subpart ZZZZ
are expected to be made in response to issues related to legal action associated with the allowable
hours of operation provisions for emergency engines regarding engines used for demand
response. Therefore,the requirements below may change in the future.
As of the date of this permit issuance [DATE], the requirements in 40 CFR Part 63 Subpart
ZZZZ promulgated after July 1, 2007 have not been adopted into Colorado Regulation No. 8,
Part E and are therefore not state-enforceable. In the event that these requirements are adopted
into Colorado Regulations, they will become state-enforceable.
When do I have to comply with this subpart(sr 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, operating limitations and other requirements must I meet if I own or
operate an existing CI RICE located at an area source of HAP emissions (sr 63.6603)
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, and replace as necessary. (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 9.1.9 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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
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Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 72
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 fuel requirements must I meet if I own or operate a stationary CI RICE? (§63.6604)
9.1.3 Beginning January 1, 2015, if you own or operate an existing emergency CI
stationary RICE with a site rating of more than 100 brake HP and a displacement of
less than 30 liters per cylinder that uses diesel fuel and operates or is contractually
obligated to be available for more than 15 hours per calendar year for the purposes
specified in Conditions 9.1.11.2.b and 9.1.11.2.c or that operates for the purpose
specified in §63.6640(f)(4)(ii), you must use diesel fuel that meets the requirements in
40 CFR 80.510(b) for nonroad diesel fuel, except that any existing diesel fuel
purchased (or otherwise obtained) prior to January 1, 2015, may be used until
depleted. . (§ 63.6604(b))
What are my general requirements for complying with this subpart? (§63.6605)
9.1.4 You must be in compliance with the emission limitations, operating limitations, and
other requirements in this subpart that apply to you at all times. (§ 63.6605(a))
9.1.5 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 Administrator which may include, but is
not limited to, monitoring results, review of operation and maintenance procedures,
review of operation and maintenance records, and inspection of the source. (§
63.6605(b))
What are my monitoring, installation, collection, operation, and maintenance requirements? (§
63.6625)
9.1.6 If you own or operate an existing emergency or black start stationary RICE located at
an area source of HAP emissions, you must operate and maintain the stationary RICE
and after-treatment control device (if any) according to the manufacturer's emission-
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit#97OPWE180 Page 73
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) and (e)(3))
9.1.7 If you own or operate an existing emergency stationary RICE with a site rating of less
than or equal to 500 brake HP located at a major source of HAP emissions or an
existing emergency stationary RICE located at an area source of HAP emissions, you
must install a non-resettable hour meter if one is not already installed. (§ 63.6625(f))
9.1.8 If you operate a new, reconstructed, 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 1 a, 2a, 2c, and 2d to this subpart apply. (§ 63.6625(h))
9.1.9 If you own or operate a stationary CI engine that is subject to the work, operation or
management practices in Condition 9.1.2, 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 within 2 business days of receiving the results of the analysis; if the
engine is not in operation when the results of the analysis are received, the engine
owner or operator must change the oil within 2 business days or before commencing
operation, whichever is later. The owner or operator must keep records of the
parameters that are analyzed as part of the program, the results of the analysis, and
the oil changes for the engine. The analysis program must be part of the maintenance
plan for the engine. (§ 63.6625(i))
How do I demonstrate continuous compliance with the emission limitations, operating
limitations and other requirements? 63.6640)
9.1.10 You must demonstrate continuous compliance with each emission limitation,
operating limitation, and other requirements in Tables 1a and 1 b, Tables 2a and 2b,
Table 2c, and Table 2d [Condition 9.1.2] to this subpart that apply to you according to
methods specified in Table 6 to this subpart. (§ 60.6640(a)) The methods specified in
Table 6 of Subpart ZZZZ are as follows:
9.1.10.1 Operating and maintaining the stationary RICE according to the
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 74
manufacturer's emission-related operation and maintenance instructions
(Table 6, Item 9.a.i); or
9.1.10.2 Develop and follow your own maintenance plan which must provide to the
extent practicable for the maintenance and operation of the engine in a
manner consistent with good air pollution control practice for minimizing
emissions. (Table 6, Item 9.a.ii)
9.1.11 If you own or operate an emergency stationary RICE, you must operate the
emergency stationary RICE according to the requirements in Conditions 9.1.11.1
through 9.1.11.3. In order for the engine to be considered an emergency stationary
RICE under this subpart, any operation other than emergency operation, maintenance
and testing, emergency demand response, and operation in non-emergency situations
for 50 hours per year, as described in Conditions 9.1.11.1 through 9.1.11.3, is
prohibited. If you do not operate the engine according to the requirements in
Conditions 9.1.11.1 through 9.1.11.3, the engine will not be considered an emergency
engine under this subpart and must meet all requirements for non-emergency engines.
(§ 63.6640(f))
9.1.11.1 There is no time limit on the use of emergency stationary RICE in
emergency situations. (§ 63.6640(f)(1))
9.1.11.2 You may operate your emergency stationary RICE for any combination of
the purposes specified below for a maximum of 100 hours per calendar
year. Any operation for non-emergency situations as allowed by Condition
9.1.11.3 as part of the 100 hours per calendar year allowed by this
Condition 9.1.11.2. (§ 63.6640(f)(2))
a. Emergency stationary RICE may be operated for maintenance
checks and readiness testing, provided that the tests are
recommended by federal, state or local government, the
manufacturer, the vendor,the regional transmission organization or
equivalent balancing authority and transmission operator, or the
insurance company associated with the engine. 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
calendar year. (§ 63.6640(f)(2)(i))
b. Emergency stationary RICE may be operated for emergency
demand response for periods in which the Reliability Coordinator
under the North American Electric Reliability Corporation
(NERC) Reliability Standard EOP-002-3, Capacity and Energy
Emergencies (incorporated by reference, see §63.14), or other
authorized entity as determined by the Reliability Coordinator, has
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 75
declared an Energy Emergency Alert Level 2 as defined in the
NERC Reliability Standard EOP-002-3. (§ 63.6640(f)(2)(ii))
c. Emergency stationary RICE may be operated for periods where
there is a deviation of voltage or frequency of 5 percent or greater
below standard voltage or frequency. (§ 63.6640(f)(2)(iii))
9.1.11.3 Emergency stationary RICE located at area sources of HAP may be
operated for up to 50 hours per calendar year in non-emergency situations.
The 50 hours of operation in non-emergency situations are counted as part
of the 100 hours per calendar year for maintenance and testing and
emergency demand response provided in Condition 9.1.11.2. Except as
provided in paragraphs (f)(4)(i) and (ii) of this section, the 50 hours per
year for non-emergency situations cannot be used for peak shaving or non-
emergency demand response, or to generate income for a facility to an
electric grid or otherwise supply power as part of a financial arrangement
with another entity. (§ 63.6640(0(4))
What reports must I submit and when? (sC 63.6650)
9.1.12 If you own or operate an emergency stationary RICE with a site rating of more than
100 brake HP that operates or is contractually obligated to be available for more than
15 hours per calendar year for the purposes specified in Conditions 9.1.11.2.b and
9.1.11.2.c or that operates for the purpose specified in §63.6640(f)(4)(ii), you must
submit an annual report according to the requirements in paragraphs (h)(1) through
(3) of this section. (§ 63.6650(h))
What records must I keep? (sC 63.6655)
9.1.13 You must keep records of the maintenance conducted on the stationary RICE in order
to demonstrate that you operated and maintained the stationary RICE and after-
treatment control device (if any) according to your own maintenance plan if you own
or operate an existing stationary emergency RICE. (§ 63.6655(e) and (e)(2))
9.1.14 If you own or operate an existing emergency stationary 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 engine is used for the purposes specified in Conditions
9.1.11.2.b or 9.1.11.2.c or §63.6640(f)(4)(ii),the owner or operator must keep records
of the notification of the emergency situation, and the date, start time, and end time of
engine operation for these purposes.. (§ 63.6655(f) and (f)(2))
In what form and how long must I keep my records? (sC 63.6660)
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE1 80 Page 76
9.1.15 Records shall be kept in the form and for the duration specified in § 63.6660.
What parts of the General Provisions apply to me? ('63.6665)
9.1.16 Table 8 of Subpart ZZZZ shows which parts of the General Provisions in §§63.1
through 63.15 apply to you. (§ 63.6665) The general provisions that apply to these
engines include, but are not limited to the following:
9.1.16.1 Prohibited activities in § 63.4(a).
9.1.16.2 Circumvention in § 63.4(b)
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 these engines shall not exceed the following:
9.3.1 Except as provided for in Condition 9.3.2 below, no owner or operator of a source shall
allow or cause the emission into the atmosphere of any air pollutant which is in excess of
20% opacity (Colorado Regulation No. 1, Section II.A.1).
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 As specified in Condition 9.1.8 engine startup shall not exceed 30 minutes. An engine
startup period of less than 30 minutes shall not require an opacity observation to monitor
compliance with the opacity limit in Condition 9.3.2. A record shall be kept of the date
and time each engine was started and when it was shutdown.
9.3.4 An opacity observation shall be conducted annually (calendar year period) on each
engine to monitor compliance with the opacity limit in Condition 9.3.1. Annual opacity
observations for and individual engine shall be separated by a period of four(4) months.
If an engine is operated more than 250 hours in any calendar year period, a second
opacity observation shall be conducted for that engine. If two opacity readings are
conducted in the annual (calendar year) period, such readings shall be conducted at least
thirty days apart.
9.3.5 If an engine is not operated during the annual (calendar year) period, then no opacity
observation is required.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit#97OPWE180 Page 77
9.3.6 Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to
the contrary, exceedance of the opacity limit shall be considered to exist from the time a
Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9
reading is taken that shows the opacity is less than the opacity limit.
9.3.7 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 The emergency generator engines are subject to requirements in Colorado Regulation No. 7,
Part E, Section II.A, requirements for combustion equipment located at major sources of NOx, as
follows:
Note that the language below is from Colorado Regulation No. 7, adopted by the Colorado Air
Quality Control Commissions (AQCC) on September 23, 2020 (effective November 14, 2020).
However, if revisions to Colorado Regulation No. 7, Part E, 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.
Note that on September 18, 2020, the Division requested that the AQCC schedule a hearing in
December to consider revisions to Colorado Regulation No. 7. If these revisions are adopted
prior to permit issuance, they will be included in the issued permit. There are no substantive
changes proposed for the requirements included in this Condition 9.4.
9.4.1 Applicability (Regulation No. 7, Part E, Section II.A.1)
9.4.1.1 Except as provided in Section II.A.2. (Condition 9.4.2), 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. 7, Part E, Section II.A.1.a)
9.4.2 Exemptions (Regulation No. 7, Part E, Section II.A.2)
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.8, 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.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 78
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. 7, Part E,
Section II.A.2)
9.4.2.1 Any stationary combustion equipment whose utilization is less than
(Regulation No. 7, Part E, Section II.A.2.a)
a. 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. 7, Part E, Section II.A.2.a.(ii))
9.4.2.2 Any stationary combustion equipment with total uncontrolled actual
emissions less than 5 tpy NOx on a calendar year basis. (Regulation No. 7,
Part E, Section II.A.2.d)
9.4.3 Recordkeeping (Regulation No. 7, Part E, 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. 7, Part E, Section II.A.7):
9.4.3.1 All sources qualifying for an exemption under Section II.A.2. (Condition
9.4.2) must maintain all records necessary to demonstrate that an
exemption applies. (Regulation No. 7, Part E, Section II.A.7.g)
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit#97OPWE180 Page 79
10. Colorado Regulation No. 7, Part E, Sections II.A.6 and 7.f—Combustion Process Adjustment and
Associated Recordkeeping Requirements
These requirements apply to any combustion equipment that are referred to this Condition throughout
this permit and have actual, uncontrolled NOx emissions greater than or equal to 5 tons/yr(calendar year
basis).
Note that the language below is from Colorado Regulation No. 7, adopted by the Colorado Air Quality
Control Commissions (AQCC) on September 23, 2020 (effective November 14, 2020). However, if
revisions to Colorado Regulation No. 7, Part E, 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.
Note that on September 18, 2020, the Division requested that the AQCC schedule a hearing in
December to consider revisions to Colorado Regulation No. 7. If these revisions are adopted prior to
permit issuance, they will be included in the issued permit. There are no substantive changes proposed
for the requirements included in this Condition 10.
10.1 Combustion Process Adjustment Requirements (Regulation No. 7, Part E, Section II.A.6)
10.1.1 Applicability (Regulation No. 7, Part E, Section II.A.6.a)
10.1.1.1 As of January 1, 2017, this Section II.A.6. applies to boilers; duct burners,
process heaters, stationary combustion turbines, and stationary
reciprocating internal combustion engines with uncontrolled actual
emissions of NOx equal to or greater than five (5) tons per year that
existed at major sources of NOx (greater than or equal to 100 tpy NOx) as
of June 3, 2016. (Regulation No. 7, Part E, Section II.A.6.a.(i))
10.1.2 Combustion Process Adjustment(Regulation No. 7, Part E, Section II.A.6.b)
10.1.2.1 When burning the fuel that provides the majority of the heat input since
the last combustion process adjustment and when operating at a firing rate
typical of normal operation, the owner or operator must conduct the
following inspections and adjustments of boilers and process heaters, as
applicable (Regulation No. 7, Part E, Section II.A.6.b.(i)):
a. Inspect the burner and combustion controls and clean or replace
components as necessary. (Regulation No. 7, Part E, Section
II.A.6.b.(i)(A))
b. Inspect the flame pattern and adjust the burner or combustion
controls as necessary to optimize the flame pattern. (Regulation
No. 7, Part E, Section II.A.6.b.(i)(B))
c. Inspect the system controlling the air-to-fuel ratio and ensure that it
is correctly calibrated and functioning properly. (Regulation No. 7,
Part E, Section II.A.6.b.(i)(C))
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE1 80 Page 80
d. Measure the concentration in the effluent stream of carbon
monoxide and nitrogen oxide in ppm, by volume, before and after
the adjustments in Sections II.A.6.b.(i)(A) through (C).
Measurements may be taken using a portable analyzer. (Regulation
No. 7, Part E, Section II.A.6.b.(i)(D))
10.1.2.2 The owner or operator of a duct burner must inspect duct burner
elements, baffles, support structures, and liners and clean, repair, or
replace components as necessary. (Regulation No. 7, Part E, Section
II.A.6.b.(ii))
10.1.2.3 The owner or operator of a stationary combustion turbine must conduct
the following inspections and adjustments, as applicable (Regulation No.
7, Part E, Section II.A.6.b.(iii)):
a. Inspect turbine inlet systems and align, repair, or replace
components as necessary. (Regulation No. 7, Part E, Section
II.A.6.b.(iii)(A))
b. Inspect the combustion chamber components, combustion liners,
transition pieces, and fuel nozzle assemblies and clean, repair, or
replace components as necessary. (Regulation No. 7, Part E,
Section II.A.6.b.(iii)(B))
c. When burning the fuel that provides the majority of the heat input
since the last combustion process adjustment and when operating
at a firing rate typical of normal operation, confirm proper setting
and calibration of the combustion controls. (Regulation No. 7, Part
E, Section II.A.6.b.(iii)(C))
10.1.2.4 The owner or operator must operate and maintain the boiler, duct burner,
process heater, stationary combustion turbine, stationary internal
combustion engine, dryer, furnace, or ceramic kiln consistent with
manufacturer's specifications, if available, or good engineering and
maintenance practices. (Regulation No, 7, Part E, Section II.A.6.b.(vii))
10.1.2.5 Frequency (Regulation No, 7, Part E, Section II.A.6.b.(viii))
a. The owner or operator of boilers, duct burners, process heaters,
stationary combustion turbines, and stationary reciprocating
internal combustion engines with uncontrolled actual emissions of
NOx equal to or greater than five (5) tons per year that existed at
major sources of NOx (greater than or equal to 100 tpy NOx) as of
June 3, 2016, must conduct the initial combustion process
adjustment by April 1, 2017. An owner or operator may rely on a
combustion process adjustment conducted in accordance with
applicable requirements and schedule of a New Source
Performance Standard in 40 CFR Part 60 (November 17, 2016) or
National Emission Standard for Hazardous Air Pollutants in 40
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit#97OPWE180 Page 81
CFR Part 63 (November 17, 2016) to satisfy the requirement to
conduct an initial combustion process adjustment by April 1, 2017.
(Regulation No, 7, Part E, Section II.A.6.b.(viii)(A))
b. The owner or operator must conduct subsequent combustion
process adjustments at least once every twelve (12) months after
the initial combustion adjustment, or on the applicable schedule
according to Sections II.A.6.c.(i). or II.A.6.c.(ii). (Regulation No,
7, Part E, Section II.A.6.b.(viii)(C))
10.1.3 As an alternative to the requirements described in Sections II.A.6.b.(i) through
II.A.6.b.(viii) (Regulation No, 7, Part E, Section II.A.6.c):
10.1.3.1 The owner or operator may conduct the combustion process adjustment
according to the manufacturer recommended procedures and schedule
(Regulation No, 7, Part E, Section II.A.6.c.(i)); or
10.1.3.2 The owner or operator of combustion equipment that is subject to and
required to conduct a periodic tune-up or combustion adjustment by the
applicable requirements of a New Source Performance Standard in 40
CFR Part 60 (December 19, 2019) or National Emission Standard for
Hazardous Air Pollutants in 40 CFR Part 63 (December 19, 2019) may
conduct tune-ups or adjustments according to the schedule and procedures
of the applicable requirements of 40 CFR Part 60 (December 19, 2019) or
40 CFR Part 63 (December 19, 2019). (Regulation No, 7, Part E, Section
II.A.6.c.(ii))
10.2 Recordkeeping (Regulation No. 7, Part E, 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. 7, Part E, Section II.A.7):
10.2.1 For stationary combustion equipment subject to the combustion process adjustment
requirements in Section II.A.6., the following recordkeeping requirements apply
(Regulation No. 7, Part E, Section II.A.7.f):
10.2.1.1 The owner or operator must create a record once every calendar year
identifying the combustion equipment at the source subject to Section
II.A. and including for each combustion equipment (Regulation No. 7,
Part E, Section II.A.7.f.(i)):
a. The date of the, adjustment (Regulation No. 7, Part E, Section
II.A.7.f.(i)(A));
b. Whether the combustion process adjustment under Sections
II.A.6.b.(i) through II.A.6.b.(vi) was followed, and what
procedures were performed (Regulation No. 7, Part E, Section
II.A.7.f.(i)(B));
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 82
c. Whether a combustion process adjustment under Sections
II.A.6.c.(i). and II.A.6.c.(ii). was followed, what procedures were
performed, and what New Source Performance or National
Emission Standard for Hazardous Air Pollutants applied, if any
(Regulation No. 7, Part E, Section II.A.7.f.(i)(C)); and
d. A description of any corrective action taken. (Regulation No. 7,
Part E, Section II.A.7.f.(i)(D))
e. If the owner or operator conducts the combustion process
adjustment according to the manufacturer recommended
procedures and schedule and the manufacturer specifies a
combustion process adjustment on an operation time schedule, the
hours of operation. (Regulation No. 7, Part E, Section
II.A.7.f.(i)(E))
10.2.1.2 The owner or operator must retain manufacturer recommended
procedures, specifications, and maintenance schedule if utilized under
Section II.A.6.c.(i). for the life of the equipment. (Regulation No. 7, Part
E, Section II.A.7.f.(ii))
10.2.1.3 As an alternative to the requirements described in Section II.A.7.f.(i), the
owner or operator may comply with applicable recordkeeping
requirements related to combustion process adjustments conducted
according to a New Source Performance Standard in 40 CFR Part 60
(November 17, 2016) or National Emission Standard for Hazardous Air
Pollutants in 40 CFR Part 63 (November 17, 2016). (Regulation No. 7,
Part E, Section II.A.7.f.(iii))
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWEI 80 Page 83
SECTION III - Acid Rain Requirements
1. Designated Representative and Alternate Designated Representative
Designated Representative Alternate Designated Representative
Name: Jeffrey West Name: Chad Campbell
Title: Senior Director, Title: Manager, Environmental
Environmental Services Services, Air& Water Quality
Compliance
Phone: (303) 571-2762 Phone: (303) 294-2177
2. Sulfur Dioxide Emission Allowances and Nitrogen Oxide Emission Limitations
I 2020 I 2021 I 2022 2023 I 2024 I 2025
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 Has No Title IV NOx Limits(see Section 5)
Turbine No.5
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)
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE1 80 Page 84
2020 2021 2022 2023 2024 2025
Turbine No.6
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)
* 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 (from Acid Rain Permit Application, EPA
Form 7610-16 (Revised 8-2019), with some clarifying language added (e.g. "permitting authority"
replaced with "Division" and"Act" replaced with "Federal Clean Air Act").
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 the source or unit 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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 85
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.
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:
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 86
(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.
(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.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 87
(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.
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.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 88
Changes to the Designated Representative or Alternate Designated Representative shall be made in accordance
with 40 CFR 72.23.
5. Comments,Notes and Justifications
Combustion Turbines 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 of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 89
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,Part B, These requirements are not applicable as the petroleum liquids at this
Sections IV.B.1 &2 facility are stored in tanks that are less than 40,000 gallons.
Facility Colorado Regulation No.7,Part B,Section This requirement is not applicable as crude oil is not stored in tanks
V.C 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;
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.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 90
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 II.D.3.b[SO2 emissions shall not exceed 0.35 lbs/MN'IBtu]
1.4.1 (Turbines 2 and 3), -State-only requirement
Error!Reference
source not found.
(Turbine 4)and 8.4.1
(Turbines 5 and 6).
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 [NOx emissions shall not exceed 105.4 ppmvd,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 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 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 II,Conditions Colorado Construction Permit 99WE0762 PSD, Conditions 7.d & i and 4 [continuous emission
5.3 and 5.2 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
5.3 and 5.2 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 Colorado Regulation No. 1, Section VI.B.4.c.(ii) and VI.B.2 [SO2 emissions shall not exceed 0.35
2.4.2(Turbine 4)and lbs/MMBtu on a 3-hr rolling average]
8.4.1 (Turbines 5 and 6)
Section II,Conditions 40 CFR Part 60 Subpart KKKK§ 60.6340(b)(1),as adopted by referenced in Colorado Regulation No.
2.8(Turbine 4)and 8.10 6,Part A[use a NOx CEMS]
(Turbines 5 and 6)
Section II,Condition 40 CFR Part 60 Subpart KKKK § 60.4345(a), as adopted by reference in Colorado Regulation No. 6,
5.2.1.2 Part A [performance specification requirements]-with respect to Turbines 4,5 and 6.
Section II,Conditions 40 CFR Part 60 Subpart KKKK §§ 60.4345(b),as adopted by reference in Colorado Regulation No. 6,
5.2 and 5.3 Part A[valid hour]-with respect to Turbines 4,5 and 6.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 91
Permit Condition(s) Streamlined(Subsumed)Requirements
Section II,Conditions 40 CFR Part 60 Subpart KKKK § 60.4345(c), as adopted by reference in Colorado Regulation No. 6,
2.9(Turbine 4)and 8.11 Part A[fuel flow meter]
(Turbines 5 and 6)
Section II,Condition 40 CFR Part 60 Subpart KKKK § 60.4345(e), as adopted by reference in Colorado Regulation No. 6,
5.2.2.2 Part A [QA/QC plan]-with respect to Turbines 4,5 and 6.
Section II,Conditions 40 CFR Part 60 Subpart KKKK § 60.4365(a)and(b), as adopted by reference in Colorado Regulation
2.11 (Turbine 4)and 8.9 No. 6, Part A [use purchase contract/tariff sheet or sampling to demonstration sulfur monitoring not
(Turbines 5 and 6) required]
Section II,Condition 5.5 40 CFR Part 60 Subpart KKKK§60.4395,as adopted by reference in Colorado Regulation No.6,Part
A [submit reports semi-annually]-with respect to Turbines 4,5 and 6.
Section II,Conditions Regulation No. 7, Part E, Sections II.A.4.b.(i) and II.A.5.a[turbines must meet NSPS GG NOx limit,
1.2.1 comply with limit by October 1,2021]
Section II,Conditions Regulation No. 7, Part E, Sections II.A.4.b.(ii) and II.A.5.a [turbines must meet NSPS KKKK NOx
2.5.2(Turbine 4)and limit,comply with limit by October 1,2021]
8.2.2(Turbines 5 and 6)
Section II,Conditions Regulation No. 7, Part E, Sections II.A.5.c.(i)(A) and II.A.5.c.(i)(A)(1) [turbines may use CEMS to
1.2.1 & 1.10(Turbines 2 monitor compliance w/emission limit,if subject to Part 75 must use Part 75 CEMS]
and 3),2.5.1 &2.8
(Turbine 4)and 8.2.2&
8.10(Turbines 5 and 6)
Section II,Conditions Regulation No.7,Part E,Section II.A.5.c.(iv)[fuel flow meter]
1.11 (Turbines 2 and 3),
2.9(Turbine 4)&8.11
(Turbines 5 and 6)
Section II,Conditions Regulation No.7,Part E, Section II.A.7.c[keep records of type and amount of fuel used]
1.8(Turbines 2 and 3),
2.7(Turbine 4),3.2(Aux
Boiler)and 8.8(Turbines
5 and 6)
Section V,Conditions Regulation No. 7, Part E, Section II.A.7.e [maintain all records generated to comply with reporting
22.b and c requirements for 5 years]
Section II,Condition 5.5 Regulation No. 7, Part E, Sections II.A.8.a and a.(i) [sources using a CEMS shall submit quarterly or
semi-annual excess emission reports]
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 92
SECTION V- General Permit Conditions
1/21/2020 version
1. Administrative Changes
Regulation No.3,5 CCR 1001-5,Part A, &III.
The permittee shall submit an application for an administrative permit amendment to the Division for those permit changes
that are described in Regulation No.3,Part A, §I.B.1. The permittee may immediately make the change upon submission of
the application to the Division.
2. Certification Requirements
Regulation No.3,5 CCR 1001-5,Part C, &&III.B.9.,V.C.16.a.&e.and V.C.17.
a. Any application,report,document and compliance certification submitted to the Air Pollution Control Division
pursuant to Regulation No.3 or the Operating Permit shall contain a certification by a responsible official of the
truth,accuracy and completeness of such form,report or certification stating that,based on information and belief
formed after reasonable inquiry,the statements and information in the document are true,accurate and complete.
b. All compliance certifications for terms and conditions in the Operating Permit shall be submitted to the Air Pollution
Control Division at least annually unless a more frequent period is specified in the applicable requirement or by the
Division in the Operating Permit.
c. Compliance certifications shall contain:
(i) the identification of each permit term and condition that is the basis of the certification;
(ii) the compliance status of the source;
(iii) whether compliance was continuous or intermittent;
(iv) method(s)used for determining the compliance status of the source,currently and over the reporting
period;and
(v) such other facts as the Air Pollution Control Division may require to determine the compliance status of the
source.
d. All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental
Protection Agency at the addresses listed in Appendix D of this Permit.
e. If the permittee is required to develop and register a risk management plan pursuant to § 112(r)of the federal act,the
permittee shall certify its compliance with that requirement;the Operating Permit shall not incorporate the contents
of the risk management plan as a permit term or condition.
3. Common Provisions
Common Provisions Regulation,5 CCR 1001-2 §§ II.A.,II.B.,II.C.,II,.E.,II.F.,II.I,and II.J
a. To Control Emissions Leaving Colorado
When emissions generated from sources in Colorado cross the State boundary line,such emissions shall not cause
the air quality standards of the receiving State to be exceeded,provided reciprocal action is taken by the receiving
State.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit#97OPWE180 Page 93
b. Emission Monitoring Requirements
The Division may require owners or operators of stationary air pollution sources to install,maintain,and use
instrumentation to monitor and record emission data as a basis for periodic reports to the Division.
c. Performance Testing
The owner or operator of any air pollution source shall,upon request of the Division,conduct performance test(s)
and furnish the Division a written report of the results of such test(s)in order to determine compliance with
applicable emission control regulations.
Performance test(s)shall be conducted and the data reduced in accordance with the applicable reference test
methods unless the Division:
(i) specifies or approves,in specific cases,the use of a test method with minor changes in methodology;
(ii) approves the use of an equivalent method;
(iii) approves the use of an alternative method the results of which the Division has determined to be adequate
for indicating where a specific source is in compliance;or
(iv) waives the requirement for performance test(s)because the owner or operator of a source has demonstrated
by other means to the Division's satisfaction that the affected facility is in compliance with the standard.
Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to
require testing under the Colorado Revised Statutes,Title 25,Article 7,and pursuant to regulations
promulgated by the Commission.
Compliance test(s)shall be conducted under such conditions as the Division shall specify to the plant operator based
on representative performance of the affected facility.The owner or operator shall make available to the Division
such records as may be necessary to determine the conditions of the performance test(s).Operations during period of
startup,shutdown,and malfunction shall not constitute representative conditions of performance test(s)unless
otherwise specified in the applicable standard.
The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance
test to afford the Division the opportunity to have an observer present.The Division may waive the thirty day notice
requirement provided that arrangements satisfactory to the Division are made for earlier testing.
The owner or operator of an affected facility shall provide,or cause to be provided,performance testing facilities as
follows:
(i) Sampling ports adequate for test methods applicable to such facility;
(ii) Safe sampling platform(s);
(iii) Safe access to sampling platform(s);and
(iv) Utilities for sampling and testing equipment.
Each performance test shall consist of at least three separate runs using the applicable test method.Each run shall be
conducted for the time and under the conditions specified in the applicable standard.For the purpose of determining
compliance with an applicable standard,the arithmetic mean of results of at least three runs shall apply.In the event
that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of
forced shutdown,failure of an irreplaceable portion of the sample train,extreme meteorological conditions,or other
circumstances beyond the owner or operator's control,compliance may,upon the Division's approval,be
determined using the arithmetic mean of the results of the two other runs.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 94
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
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.
e. Circumvention Clause
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 95
A person shall not build,erect,install,or use any article,machine,equipment,condition,or any contrivance,the use
of which,without resulting in a reduction in the total release of air pollutants to the atmosphere,reduces or conceals
an emission which would otherwise constitute a violation of this regulation.No person shall circumvent this
regulation by using more openings than is considered normal practice by the industry or activity in question.
f. Compliance Certifications
For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in
violation of any standard in the Colorado State Implementation Plan,nothing in the Colorado State Implementation
Plan shall preclude the use,including the exclusive use,of any credible evidence or information,relevant to whether
a source would have been in compliance with applicable requirements if the appropriate performance or compliance
test or procedure had been performed.Evidence that has the effect of making any relevant standard or permit term
more stringent shall not be credible for proving a violation of the standard or permit term.
When compliance or non-compliance is demonstrated by a test or procedure provided by permit or other applicable
requirement,the owner or operator shall be presumed to be in compliance or non-compliance unless other relevant
credible evidence overcomes that presumption.
g. Affirmative Defense Provision for Excess Emissions During Startup and Shutdown
An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during
periods of startup and shutdown.To establish the affirmative defense and to be relieved of a civil penalty in any
action to enforce an applicable requirement,the owner or operator of the facility must meet the notification
requirements below in a timely manner and prove by a preponderance of the evidence that:
(i) The periods of excess emissions that occurred during startup and shutdown were short and infrequent and
could not have been prevented through careful planning and design;
(ii) The excess emissions were not part of a recurring pattern indicative of inadequate design,operation or
maintenance;
(iii) If the excess emissions were caused by a bypass(an intentional diversion of control equipment),then the
bypass was unavoidable to prevent loss of life,personal injury,or severe property damage;
(iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum
extent practicable;
(v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality;
(vi) All emissions monitoring systems were kept in operation(if at all possible);
(vii) The owner or operator's actions during the period of excess emissions were documented by properly
signed,contemporaneous operating logs or other relevant evidence;and,
(viii) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions.
This subparagraph is intended solely to be a factor in determining whether an affirmative defense is
available to an owner or operator,and shall not constitute an additional applicable requirement.
The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the
Division verbally as soon as possible,but no later than two(2)hours after the start of the next working day,and shall
submit written quarterly notification following the initial occurrence of the excess emissions. The notification shall
address the criteria set forth above.
The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit#97OPWE180 Page 96
The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements
that derive from new source performance standards or national emissions standards for hazardous air pollutants, or
any other federally enforceable performance standard or emission limit with an averaging time greater than twenty-
four hours. In addition, an affirmative defense cannot be used by a single source or small group of sources where
the excess emissions have the potential to cause an exceedance of the ambient air quality standards or Prevention of
Significant Deterioration(PSD)increments.
In making any determination whether a source established an affirmative defense,the Division shall consider the
information within the notification required above and any other information the Division deems necessary,which
may include,but is not limited to,physical inspection of the facility and review of documentation pertaining to the
maintenance and operation of process and air pollution control equipment.
4. Compliance Requirements
Regulation No.3,5 CCR 1001-5,Part C,&& III.C.9.,V.C.11.& 16.d.and$25-7-122.1(2),C.R.S.
a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to
federally-enforceable terms or conditions constitutes a violation of the federal act,as well as the state act and
Regulation No.3. Any permit noncompliance relating to state-only terms or conditions constitutes a violation of the
state act and Regulation No.3,shall be enforceable pursuant to state law,and shall not be enforceable by citizens
under§304 of the federal act. Any such violation of the federal act,the state act or regulations implementing either
statute is grounds for enforcement action,for permit termination,revocation and reissuance or modification or for
denial of a permit renewal application.
b. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a
permit termination,revocation or modification action or action denying a permit renewal application that it would
have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of
the permit.
c. The permit may be modified,revoked,reopened,and reissued,or terminated for cause. The filing of any request by
the permittee for a permit modification,revocation and reissuance,or termination,or any notification of planned
changes or anticipated noncompliance does not stay any permit condition,except as provided in§§X.and XI.of
Regulation No.3,Part C.
d. The permittee shall furnish to the Air Pollution Control Division,within a reasonable time as specified by the
Division,any information that the Division may request in writing to determine whether cause exists for modifying,
revoking and reissuing,or terminating the permit or to determine compliance with the permit. Upon request,the
permittee shall also furnish to the Division copies of records required to be kept by the permittee,including
information claimed to be confidential. Any information subject to a claim of confidentiality shall be specifically
identified and submitted separately from information not subject to the claim.
e. Any schedule for compliance for applicable requirements with which the source is not in compliance at the time of
permit issuance shall be supplemental,and shall not sanction noncompliance with,the applicable requirements on
which it is based.
f. For any compliance schedule for applicable requirements with which the source is not in compliance at the time of
permit issuance,the permittee shall submit,at least every 6 months unless a more frequent period is specified in the
applicable requirement or by the Air Pollution Control Division,progress reports which contain the following:
(i) dates for achieving the activities,milestones,or compliance required in the schedule for compliance,and
dates when such activities,milestones,or compliance were achieved;and
(ii) an explanation of why any dates in the schedule of compliance were not or will not be met,and any
preventive or corrective measures adopted.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 97
g. The permittee shall not knowingly falsify,tamper with,or render inaccurate any monitoring device or method
required to be maintained or followed under the terms and conditions of the Operating Permit.
5. Emergency Provisions
Regulation No.3,5 CCR 1001-5,Part C, $VII.
An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the
source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that
causes the source to exceed the technology-based emission limitation under the permit due to unavoidable increases in
emissions attributable to the emergency. "Emergency" does not include noncompliance to the extent caused by improperly
designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. An emergency
constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology-based emission
limitation if the permittee demonstrates,through properly signed,contemporaneous operating logs,or other relevant evidence
that:
a. an emergency occurred and that the permittee can identify the cause(s)of the emergency;
b. the permitted facility was at the time being properly operated;
c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that
exceeded the emission standards,or other requirements in the permit;and
d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the
next working day following the emergency,and followed by written notice within one month of the time when
emissions limitations were exceeded due to the emergency. This notice must contain a description of the
emergency,any steps taken to mitigate emissions,and corrective actions taken.
This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement.
6. Emission Controls for Asbestos
Regulation No. 8,5 CCR 1001-10,Part B
The permittee shall not conduct any asbestos abatement activities except in accordance with the provisions of Regulation No.
8,Part B,"asbestos control."
7. Emissions Trading,Marketable Permits,Economic Incentives
Regulation No.3,5 CCR 1001-5,Part C, S V.C.13.
No permit revision shall be required under any approved economic incentives, marketable permits, emissions trading and
other similar programs or processes for changes that are specifically provided for in the permit.
8. Fee Payment
C.R.S. §&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 of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE1 80 Page 98
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, S III.D.1.
The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate
emissions into the atmosphere,in accordance with the provisions of Regulation No. 1,§III.D.1.
10. Inspection and Entry
Regulation No.3,5 CCR 1001-5,Part C,$V.C.16.b.
Upon presentation of credentials and other documents as may be required by law,the permittee shall allow the Air Pollution
Control Division,or any authorized representative,to perform the following:
a. enter upon the permittee's premises where an Operating Permit source is located,or emissions-related activity is
conducted,or where records must be kept under the terms of the permit;
b. have access to,and copy,at reasonable times,any records that must be kept under the conditions of the permit;
c. inspect at reasonable times any facilities,equipment(including monitoring and air pollution control equipment),
practices,or operations regulated or required under the Operating Permit;
d. sample or monitor at reasonable times,for the purposes of assuring compliance with the Operating Permit or
applicable requirements,any substances or parameters.
11. Minor Permit Modifications
Regulation No.3,5 CCR 1001-5,Part C, 'S$X.&XI.
The permittee shall submit an application for a minor permit modification before making the change requested in the
application. The permit shield shall not extend to minor permit modifications.
12. New Source Review
Regulation No.3,5 CCR 1001-5,Parts B&D
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,Parts B and/or D,as applicable,without first receiving a construction permit.
13. No Property Rights Conveyed
Regulation No.3,5 CCR 1001-5,Part C,§V.C.11.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 of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 99
15. Off-Permit Changes to the Source
Regulation No.3,5 CCR 1001-5,Part C,&XII.B.
The permittee shall record any off-permit change to the source that causes the emissions of a regulated pollutant subject to an
applicable requirement, but not otherwise regulated under the permit,and the emissions resulting from the change, including
any other data necessary to show compliance with applicable ambient air quality standards. The permittee shall provide
contemporaneous notification to the Air Pollution Control Division and to the Environmental Protection Agency at the
addresses listed in Appendix D of this Permit. The permit shield shall not apply to any off-permit change.
16. Opacity
Regulation No. 1,5 CCR 1001-3, §§I.,II.
The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1, §§I.-II.
17. Open Burning
Regulation No.9,5 CCR 1001-11
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 1001-19
The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds.
Sections I.,II.C.,II.D.,III.IV.,and V.of Regulation No. 15 shall be enforced as a matter of state law only.
19. Permit Expiration and Renewal
Regulation No.3,5 CCR 1001-5,Part C,§§III.B.6.,IV.C.,V.C.2.
a. The permit term shall be five(5)years. The permit shall expire at the end of its term. Permit expiration terminates
the permittee's right to operate unless a timely and complete renewal application is submitted.
b. Applications for renewal shall be submitted at least twelve months,but not more than 18 months,prior to the
expiration of the Operating Permit. An application for permit renewal may address only those portions of the permit
that require revision,supplementing,or deletion, incorporating the remaining permit terms by reference from the
previous permit. A copy of any materials incorporated by reference must be included with the application.
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 of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 100
"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 speck that this notification is a deviation report for an Operating Permit.] A
written notice,certified consistent with General Condition 2.a.above(Certification Requirements),shall be
submitted within 10 working days of the occurrence.All deviations reported under this section shall also be
identified in the 6-month report required above.
"Prompt reporting" does not constitute an exception to the requirements of "Emergency Provisions" for the purpose of
avoiding enforcement actions.
22. Record Keeping and Reporting Requirements
Regulation No.3,5 CCR 1001-5,Part A, § II.;Part C, $$ V.C.6.,V.C.7.
a. Unless otherwise provided in the source specific conditions of this Operating Permit,the permittee shall maintain
compliance monitoring records that include the following information:
(i) date,place as defined in the Operating Permit,and time of sampling or measurements;
(ii) date(s)on which analyses were performed;
(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 of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit#97OPWE180 Page 101
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 or as provided
for in Regulation No.3,Part A,§II.A.2 for oil and gas well production facilities.A revised APEN shall be filed
annually whenever a significant change in emissions,as defined in Regulation No.3,Part A,§ II.C.2.,occurs;
whenever there is a change in owner or operator of any facility,process,or activity;whenever new control
equipment is installed;whenever a different type of control equipment replaces an existing type of control
equipment;whenever a permit limitation must be modified;or before the APEN expires. An APEN is valid for a
period of five years.The five-year period recommences when a revised APEN is received by the Air Pollution
Control Division.Revised APENs shall be submitted no later than 30 days before the five-year term expires.
Permittees submitting revised APENs to inform the Division of a change in actual emission rates must do so by
April 30 of the following year. Where a permit revision is required,the revised APEN must be filed along with a
request for permit revision.APENs for changes in control equipment must be submitted before the change occurs,
except an APEN shall be filed once per year for control equipment at condensate storage tanks located at oil and gas
exploration and production facilities subject to Regulation No.7,Part D§ I.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. Requirements for Major Stationary Sources
Regulation No.3,5 CCR 1001-5,Part D, §§ V.A.7.c&d,VI.B.5&VI.B.6
The following provisions apply to projects at existing emissions units at a major stationary source (other than projects at a
source with a PAL) that are not part of a major modification and where the owner or operator relies on projected actual
emissions. The definitions of baseline actual emissions, major modification, major stationary source, PAL, projected actual
emissions,regulated NSR pollutant and significant can be found in Regulation No.3,Part D, §II.A.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 102
a. Before beginning actual construction of the project,the owner or operator shall document and maintain a record of
the following information:
(i) a description of the project;
(ii) identification of the emissions unit(s)whose emissions of a regulated NSR pollutant could be affected by
the project;and
(iii) a description of the applicability test used to determine the project is not a major modification for any
regulated NSR pollutants, including the baseline actual emissions,the projected actual emissions,the
amount of emissions excluded and an explanation for why such amount was excluded,and any netting
calculations,if applicable.
b. The owner or operator shall monitor emissions of any regulated NSR pollutant that could increase as a result of the
project from any emissions units identified in paragraph a.(ii)and calculate and maintain a record of the annual
emissions,in tons per year on a calendar year basis,for a period of five(5)years following resumption of regular
operation after the change,or for a period of ten(10)years following resumption of regular operation after the
change if the project increases the design capacity or potential to emit of that regulated NSR pollutant at such
emissions unit.
c. For existing electric utility steam generating units the following requirements apply:
(i) Before beginning actual construction,the owner or operator shall provide a copy of the information
required by paragraph a above to the Division.The owner or operator is not required to obtain a
determination from the Division prior to beginning actual construction.
(ii) The owner or operate shall submit a report to the Division within sixty days after the end of each year
during which records must be generated under paragraph b above setting out the unit's annual emissions
during the calendar year that preceded submission of the report.
d. For existing emissions units that are not electric utility steam generating units,the owner or operator shall submit a
report to the Division if the annual emissions from the project, in tons per year,exceed the baseline actual emissions
(documented and maintained per paragraph a.(iii))by a significant amount for that regulated NSR pollutant,and if
such.emissions differ from the preconstruction projection(documented and maintained per paragraph a.(iii)). Such
report shall be submitted to the Division within sixty days after the end of such year.The report shall contain the
following:
(i) The name,address and telephone number of the owner or operator;
(ii) The annual emissions as calculated per paragraph b;and
(iii) Any other information that the owner or operator wishes to include in the report.
e. The owner of operation of the source shall make the information in paragraph a available for review upon request to
the Division or the general public.
25. 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 of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 103
26. Severability Clause
Regulation No.3,5 CCR 1001-5,Part C, V.C.lo.
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.
27. 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.
28. Special Provisions Concerning the Acid Rain Program
Regulation No.3,5 CCR 1001-5,Part C,§§_V.C.1.b.&8
a. Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations
promulgated under Title IV of the federal act,40 Code of Federal Regulations(CFR)Part 72,both provisions shall
be incorporated into the permit and shall be federally enforceable.
b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal act or the
regulations promulgated thereunder,40 CFR Part 72,are expressly prohibited.
29. 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.
30. Volatile Organic Compounds
Regulation No.7,5 CCR 1001-9,Part B,&&I&III.
The requirements in paragraphs a, b and e apply to sources located in the Denver 1-hour ozone attainment/maintenance area,
any nonattainment area for the 1-hour ozone standard and to the 8-hour Ozone Control Area and on a state-only basis to
sources located in any ozone nonattainment area, which includes areas designated nonattainment for either the 1-hour or 8-
hour ozone standard,unless otherwise specified in Regulation No. 7,Part A, Section I.A.1.c.The requirements in paragraphs
c and d apply statewide.
a. All storage tank gauging devices,anti-rotation devices,accesses,seals,hatches,roof drainage systems,support
structures,and pressure relief valves shall be maintained and operated to prevent detectable vapor loss except when
opened,actuated,or used for necessary and proper activities(e.g.maintenance). Such opening,actuation,or use
shall be limited so as to minimize vapor loss.
Detectable vapor loss shall be determined visually, by touch, by presence of odor,or using a portable hydrocarbon
analyzer. When an analyzer is used, detectable vapor loss means a VOC concentration exceeding 10,000 ppm.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 104
Testing shall be conducted as in Regulation No.7,Part B,Section VI.C.3.
b. Except as otherwise provided by Regulation No.7,all volatile organic compounds,excluding petroleum liquids,
transferred to any tank,container,or vehicle compartment with a capacity exceeding 212 liters(56 gallons),shall be
transferred using submerged or bottom filling equipment.For top loading,the fill tube shall reach within six inches
of the bottom of the tank compartment. For bottom-fill operations,the inlet shall be flush with the tank bottom.
c. No person shall 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,Part B,Sections IV.C.2.,IV.C.3.and VII.A.3.,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.
31. 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 - VOC CORRELATION EQUATIONS
H - PREVENTION OF SIGNIFICANT DETERIORATION (PSD)
REVIEW AND NON-ATTAINMENT AREA NEW SOURCE
REVIEW (NANSR) APPLICABILITY TESTS
*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: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix A
Inspection Information Page 1
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 191 . The facility
address is 16805 County Road 191 .
Safety Equipment Required:
Eye Protection
Hard Hat
Safety Shoes
Hearing Protection
Gloves
Facility Plot Plan:
Figure 1 (following page) shows the plot plan as submitted on August 12, 2010 to support the source's
Title V Renewal Operating Permit(second renewal, issued January 1, 2011).
List of Insignificant Activities:
The following list of insignificant activities was provided by the source to assist in the understanding of
the facility layout. Since there is no requirement to update such a list, activities may have changed since
the last filing.
The asterisk (*) denotes an insignificant activity source category based on the size of the activity,
emissions levels from the activity or the production rate of the activity. The owner or operator of
individual emission points in insignificant activity source categories marked with an asterisk (*) must
maintain sufficient record keeping verifying that the exemption applies. Such records shall be made
available for Division review upon request. (Colorado Regulation No. 3,Part C, Section II.E)
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/PMio)
Units with emissions less than APEN de minimis - non-criteria pollutants (Reg 3, Part C.II.E.3.b)
One (1) sulfuric acid storage tank, 20,000 gal above ground (emissions less than 500 lbs/yr)
Air conditioning or ventilation systems not designed to remove air pollutants (Reg 3, Part C.II.E.3.c)
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix A
Inspection Information Page 2
Plant air conditioning and ventilation system
Agricultural operations (Reg 3, Part C.II.E.3.g)
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)
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)
Welding, soldering, and brazing operations using no lead-based compounds (Reg 3, Part C.II.E.3.r)
Maintenance welding machine
Battery recharging areas (Reg 3, Part C.II.E.3.t)
Battery storage area
Landscaping and site housekeeping devices< 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)
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix A
Inspection Information Page 3
Wastewater treatment operations (no VOC emissions)
Salt tank(3,500 gal) above ground tank
Bleach tank(5,500 gal) above ground tank
Defoam (350 gal) above ground tank
Scale inhibitor(410 gal) above ground tank
Corrosion inhibitor(2,000 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)
Storage of butane, propane or LPG in tanks <60,000 gal (Reg 3 Part C.II.E.3.zz)
Storage of propane gas in small portable tanks
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)
Five (5) 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), 1,000 gal above ground
Diesel fuel tank for refueling captive vehicles (warehouse), 560 gal above ground
Forklifts (Reg 3 Part C.II.E.3.kkk)
Two (2) gasoline powered forklifts
Sandblast equipment where blast media is recycled and blasted material is collected (Reg 3, Part
C.II.E.3.www)
Sandblasting machine
Surface water storage impoundment of non-potable water and storm water evaporation ponds (Reg 3,
Part C.II.E.3.yyy)
Two (2) raw water ponds
One (1) stormwater retention pond
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix A
Inspection Information Page 4
Seal and lubricating oil systems for steam turbine electric generators (Reg 3, Part C.II.E.3.cccc)
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
Air Pollution Control Division
Colorado Operating Permit Appendix A
Inspection Information Page 5
I 3 r =!
•
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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 1
APPENDIX B
Reporting Requirements and Definitions
with codes ver 8/20/14
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 of Colorado—Ft. St. Vrain Station
OPERATING PERMIT NO: 97OPWE180
REPORTING PERIOD: (see first page of the permit for specific reporting period and dates)
Deviations noted Deviation Malfunction/Emergency
During Period?' Code2 Condition Reported
Operating During Period?
Permit Unit
ID Unit Description YES NO YES NO
T002 General Electric Combustion Turbine,Model
No.GE Frame 7FA,Serial No.296677,rated at
1773 MMBtu/hr(turbine 1,323 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(1)Vogt-NEM Natural Gas Fired Duct
Burner.
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 6
Deviations noted Deviation Malfunction/Emergency
During Period?' Codez Condition Reported
Operating During Period?
Permit Unit
ID Unit Description YES NO YES NO
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(1)Marley Cooling Water Tower,Model
no.Cross-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 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.
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 7
Monitoring and Permit Deviation Report- Part II
FACILITY NAME: Public Service Company of Colorado—Ft. St. Vrain Station
OPERATING PERMIT NO: 97OPWE180
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 8
EXAMPLE
FACILITY NAME: Acme Corp.
OPERATING PERMIT NO: 96OPZZXXX
REPORTING PERIOD: 1/1/04 - 6/30/06
Is the deviation being claimed as an: Emergency Malfunction XX N/A
(For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction
Normal Operation
OPERATING PERMIT UNIT IDENTIFICATION:
Asphalt Plant with a Scrubber for Particulate Control - Unit XXX
Operating Permit Condition Number Citation
Section II, Condition 3.1 - Opacity Limitation
Explanation of Period of Deviation
Slurry Line Feed Plugged
Duration
START- 1730 4/10/06
END- 1800 4/10/06
Action Taken to Correct the Problem
Line Blown Out
Measures Taken to Prevent Reoccurrence of the Problem
Replaced Line Filter
Dates of Malfunction/Emergencies Reported (if applicable)
5/30/06 to A. Einstein, APCD
Deviation Code Division Code QA:
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 9
Monitoring and Permit Deviation Report-Part III
REPORT CERTIFICATION
SOURCE NAME: Public Service Company of Colorado—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. 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: 97OPWE180 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 8/20/14
Following is the format for the Compliance Certification report to be submitted to the Division and the U.S.
EPA annually based on the effective date of the permit. The Table below must be completed for all equipment
or processes for which specific Operating Permit terms exist.
FACILITY NAME: Public Service Company of Colorado—Ft. 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?3
Unit ID Permit?'
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 1,323 MMBtu/hr
and duct burner 450 MMBtu/hr),
Natural Gas Fired. Turbine May be
Operated in Conjunction with a
I-IRSG(combined cycle operation)
Equipped with Natural Gas Fired
Duct Burners.
Operating Permit Number: 97OPWE180 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
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(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(1)Marley Cooling Water
Tower,Model no.Cross-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 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 I Method per or Intermittent?3
Unit ID Permit?2
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 4
If deviations were noted in a previous deviation report , put an "X" under "previous". If deviations were noted in the current
deviation report(i.e. for the last six months of the annual reporting period),put an"X" under"current". Mark both columns if both
apply.
2 Note whether the method(s)used to determine the compliance status with each term and condition was the method(s)specified in the
permit. If it was not,mark "no"and attach additional information/explanation.
3 Note whether the compliance status with of each term and condition provided was continuous or intermittent. "Intermittent
Compliance" can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance
only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance
has occurred.
NOTE:
The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the
absence of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance
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.
4 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. 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
January 27,2020 version
1. Air Pollution Control Division
Colorado Department of Public Health and Environment
Air Pollution Control Division
Operating Permits Unit
APCD-SS-B 1
4300 Cherry Creek Drive S.
Denver, CO 80246-1530
ATTN: Title V Permit Unit Supervisor
2. United States Environmental Protection Agency
Compliance Notifications:
Enforcement and Compliance Assurance Division
Air and Toxics Enforcement Branch
Mail Code 8ENF-AT
U.S. Environmental Protection Agency, Region VIII
1595 Wynkoop Street
Denver, CO 80202-1129
502(b)(10) Changes, Off Permit Changes:
Air and Radiation Division
Air Permitting and Monitoring Branch
Mail Code 8ARD-PM
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: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix G
VOC Correlation Equations Page 1
APPENDIX G
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(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= 0.51302
b= 0.555636
c= -0.004311
d= 29.75011
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix G
VOC Correlation Equations Page 2
Simple Cycle, lbs/hr
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
Turbine 4
For all Turbine 4 equations
y=VOC(Ib/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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix G
VOC Correlation Equations Page 3
All Turbines—Combined Cycle Operation
For all turbines, all equations
y=VOC ppm @ 15%O2
x=Duct Burner Heat Input(MMBtu/hr)
Unit 2
y= 1.88E-08x3- 1.83E-05x2 +3.90E-03x+2.30E-01
Unit 3
y=-5.18E-06x2+ 1.86E-03x+ 1.72E-01
Unit 4
y=-6.55E-07x2-2.30E-04x+2.16E-01
VOC lb/hr Calculation:
VOC= VOC ppm @ 15%O2* CF * Fd* 20.9 * Total Unit Heat Input
(20.9— 15)
Where:
VOC=lb/hr emission rate for VOC
VOC ppm @ 15%O2=dry concentration(ppmvd)of VOC at 15%O2, as determined by the VOC correlation equations.
CF=is the VOC as propane correction= 1.44 lb/scf
Fd=8710 for natural gas
Total Heat Input =total combustion turbine and duct burner heat input as reported in the DAHS.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix H
Prevention of Significant Deterioration (PSD) Review and Non-Attainment Area New Source Review
(NANSR)Applicability Tests Page 1
APPENDIX H
Prevention of Significant Deterioration (PSD) Review and Non-Attainment Area New Source Review
(NANSR)Applicability Tests
An owner or operator of a major stationary source must determine whether a project will trigger major
stationary source permitting requirements (i.e., PSD and/or NANSR) by conducting an applicability test using
the procedures in Colorado Regulation No. 3, Part D, Section I.B. Sources that conduct the actual-to-projected
actual test for a project that requires a minor permit modification in accordance with Section X. of Part C,
requires a significant permit modification in accordance with Section I.A.3. of Part C, a modification as defined
in Section I.B.28. of Part A or that requires a minor source permit under Part B are required to submit the
information in Colorado Regulation No. 3, Part D, Section I.B.4.a through d and that information shall be
included in an appendix of the Title V Operating permit or as a permit note in the construction permit (see
Colorado Regulation No. 3, Part D, Section I.B.4)
An owner or operation is also required to monitor emissions of any NSR regulated pollutant that could increase
as a result of the project for a period of five years or ten years (if the project increases the design capacity or the
potential to emit) following resumption of regulation operations after the project is completed and to submit
reports, if applicable, as required by Colorado Regulation No. 3, Part D, Section V.A.7.c and b and Section
VI.B.5 and 6. If actual emissions from the sources affected by the project exceed baseline emissions by a
significant amount and are different from projected actual emissions presented in this Appendix within the five
or ten year period following completion of the project, the project may need to be re-evaluated to determine
whether the project resulted in a significant emissions increase or a significant net emissions increase at a major
stationary source.
This Appendix H includes the PSD and/or NANSR applicability tests submitted for this facility.
Turbine 4 Rotor Project
This project includes the installation of a new rotor, gas path and front-end compressor parts, and controls
system all set to occur during the Hot Gas Path Major Inspection Outage scheduled for September to December
2020 to address the normal scheduled maintenance program for Turbine 4. The replacement parts are the same
parts (like-kind replacement) but some are a newer version of the part. The newer version of the parts is coming
from a General Electric (GE) Model 7FA.04 combustion turbine, while Turbine 4 is a GE Model 7FA.03
combustion turbine. It is expected that with the newer parts there will be an estimated 2.9% heat rate
improvement and up to a nominal 20 MW output increase, depending on ambient conditions. The increase in
output is not anticipated to significantly increase emissions as the newer parts provide for more efficient
operation of the turbine (more output with less fuel combusted). Due to the rotor replacement, the definition of
"start-up" in the permit for this unit needed to be revised.
After completion of the project, the turbine will be capable of burning more fuel, although less fuel is need to
generate power. The Division considers that this is an increase in the design rate (heat input), so projected actual
emissions are based on the ten-year period following completion of the project. Since the affected unit for this
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix H
Prevention of Significant Deterioration (PSD) Review and Non-Attainment Area New Source Review
(NANSR) Applicability Tests Page 2
project is an existing electric utility steam-generating unit, the source is required to submit annual reports as
required by Colorado Regulation No. 3, Part D, Sections V.A.7.c.(iv) and VI.B.5.d for ten years after
completion of the project.
Baseline actual emissions (BAE) and projected actual emissions (PAE) are shown in the table below. BAE is
based on 2018 and 2019 emissions. The maximum annual rate (PAE), in tons/yr, at which Turbine 4 is
anticipated to operate over the ten years following completion of the project occurs in 2021, annual emissions
after that are expected to decline as more renewable energy sources are utilized. PAE were calculated by
multiplying lb/MMBtu emissions factors times projected heat input. The emission factors were calculated by
dividing baseline actual emissions by baseline total heat input.
Fort St. Vrain Unit
Unit 4
Baseline and Projected Actual Emissions for PSD Applicability Analysis
Total PM/
Total Heat PM10/PM2.5
Input(MMBtu) NOx(Tons) S02(Tons) (Tons) CO (Tons VOC (Tons)
Baseline Actual v. 3
Emissions ..
2016 6,943,978.8 53.4 2.0 17.6 54.2 3.2
2017 7,712,681.0 53.5 2.3 19.3 22.5 3.7
2018 10,059,076.9 59.0 3.0 25.6 18.9 4.3
2019 10,632,449.3 68.9 3.2 26.2 25.6 4.6
Baseline (2018- 10,345,763.1 63.9 3.1 25.9 22.2 4.5
2019 average)
Projected Actual Total Heat Total PM/
Emissions Input(MMBtu) NOx(Tons) S02(Tons) PM10/PM2.5 CO (Tons) VOC (Tons)
2021 10,514,000.0 65.0 3.1 26.3 22.6 4.5
Projected change
in actual emissions 1.0 0.1 0.4 0.4 0.1
compared to
baseline
Cfit5 25.0 40.0 25.0/15.0/ 100.0 25.0
10.0
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: DRAFT
TECHNICAL REVIEW DOCUMENT
For
RENEWAL TO OPERATING PERMIT 97OPAD180
Public Service Company of Colorado — Ft. St. Vrain Station
Weld County
Source ID 1230023
Prepared by Jacqueline Joyce
April 2020
Revised August and October 2020
Reviewed by:
Operating Permit Supervisor: Blue Parish
Compliance Monitoring Unit: Travis Harder
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 January 1, 2016. The expiration date for the permit is January 1,
2021.
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 received on December 6,
2019, comments on the draft permit and technical review document received on
September 28, 2020, 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
www.colorado.gov/cdphe/airTitleV. 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.
123-0023 Page 1
Public Service Company of Colorado—Ft. St.Vrain Station Operating Permit No. 97OPWE180
Technical Review Document—Fourth Renewal
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, T003 (turbine No. 3) is the
No. 2 combustion turbine, 1004 (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 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, 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.
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
previous issuance of the operating permit (January 1, 2016).
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 the 8-hr ozone standard and is part of the 8-hr
Ozone Control Area as defined in Regulation No. 7, Part A, Section II.A.1. The 8-hr
Ozone Control Area has been classified as a serious non-attainment area effective
January 27, 2020.
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.
123-0023 Page 2
Public Service Company of Colorado—Ft. St. Vrain Station Operating Permit No. 97OPWE180
Technical Review Document—Fourth Renewal
The summary of emissions that was presented in the Technical Review Document
(TRD) for the third renewal of this permit (issued January 1, 2016) has been revised to
correct HAP emissions. An error was found in the original HAP estimates and the
methodology for estimating HAP emissions was revised slightly. Emissions (in tons/yr)
at the facility are as follows:
Table 1 -Potential to Emit (PTE)
Emission Unit PM I PM,o SO2 I NOx I CO I VOC HAPS
Turbine (T002) 39.4 39.4 4.7 496.1 465.4 21.4 See
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 28
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 19.83
*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 28 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 combined cycle (with
supplemental fuel) throughput limit (16,090 MMscf/yr) and an assumed natural gas heat
content of 1020 Btu/scf. The performance tests were conducted while the units were in
combined cycle mode with the duct burners burning fuel.
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
simple cycle throughput limit (12,507 MMscf/yr) and an assumed natural gas heat
content of 1020 Btu/scf.
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 hexane
emission factor is from an EPRI paper (5/00), the difference between the simple cycle
and combined cycle (with supplemental fuel) throughput limits (16,090 — 12,507 = 4,033
MMscf/yr) and an assumed natural gas heat content of 1020 Btu/scf.
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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 (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 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 the 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 Ib/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 29 of this document.
National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source
Categories
As indicated in the above table summarizing potential to emit, the facility is not a major
source for HAPS. The applicability of various NESHAPs (also referred to as "MACT
requirements") that apply to area sources was discussed in the TRD to support the third
renewal permit (issued January 1, 2016). That discussion has been updated to reflect
changes to the various MACT standards and the promulgation of any new standards
that may apply.
Paint Stripping and Miscellaneous Surface Coating at Area Sources (40 CFR Part 63
Subpart HHHHHH)
As discussed in the TRD to support the third renewal (issued January 1, 2016), these
requirements do not apply for the following reasons. The Division considers that any
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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)
The requirements in 40 CFR Part 63 Subpart CCCCCC, "National Emission Standards
for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities" apply
to gasoline dispensing facilities (GDF) located at area sources. As indicated in the TRD
to support the third renewal permit (issued January 1, 2016), there is a 500 gallon
gasoline storage tank that is subject to the requirements in 40 CFR Part 63 Subpart
CCCCCC. If necessary, the requirements in Subpart CCCCCC will be updated to reflect
any revisions.
Reciprocating Internal Combustion Engines (RICE) (40 CFR Part 63 Subpart ZZZZ)
Three diesel fuel-fired emergency engines (two driving an emergency generator and
one driving a fire pump) are subject to requirements in the RICE MACT and are
included in Section II of the current Title V permit (renewed January 1, 2016). If
necessary, the requirements in Subpart ZZZZ will be updated to reflect any revisions.
Industrial, Commercial and Institutional Boilers at Area Sources (40 CFR Part 63
Subpart JJJJJJ)
Gas fired boilers are not subject to the requirements in 40 CFR Part 63 Subpart JJJJJJ
in accordance with § 63.11195(e). In addition, unlike the NESHAP for major sources (40
CFR Part 63 Subpart DDDDD), these requirements only apply to boilers, not process
heaters. The only boiler at this facility is natural gas-fired, therefore, the requirements in
40 CFR Part 63 Subpart JJJJJJ do not apply.
New Source Performance Standards (NSPS)
EPA has promulgated NSPS requirements for new source categories since the
issuance of the first renewal permit for this facility. NSPS requirements generally only
apply to new or modified equipment and the Division is not aware of any modifications
to existing equipment or additions of new equipment that would render equipment at this
facility subject to NSPS requirements. The EPA does also promulgate guidelines for
states to submit plans to establish standards of performance for existing sources under
Section 111(d) of the Federal Clean Air Act. Section 111(d) of the CAA requires states
to develop plans for existing sources of non-criteria pollutants (i.e., a pollutant for which
there is no national ambient air quality standard) whenever EPA promulgates a
standard for a new source type.
Because the recently promulgated NSPS requirements address equipment that may not
be subject to APEN reporting or minor source construction permit requirements and
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EPA has promulgated emission guidelines for existing sources, the applicability of some
of the newly promulgated or proposed requirements is being addressed here.
NSPS Subpart JJJJ — Stationary Spark Ignition Engines
NSPS Subpart JJJJ applies to stationary spark ignition engines that commenced
construction, reconstruction or modification after June 12, 2006 and were manufactured
after specified dates. The date the engine commenced construction is the date the
engine was ordered by the owner/operator. There are no spark ignition engines located
at this facility, therefore, the requirements in Subpart JJJJ do not apply.
NSPS Subpart 1111 —— Stationary Compression Ignition Engines
NSPS Subpart 1111 applies to stationary compression ignition engines that commenced
construction, reconstruction or modification after July 11, 2005 and were manufactured
after specified dates. The date the engine commenced construction is the date the
engine was ordered by the owner/operator. The only compression ignition engines that
are located at this facility are the two engines driving the emergency generator and the
emergency fire pump engine, all of which commenced operation prior to July 11, 2005
and therefore, the requirements in Subpart 1111 do not apply.
NSPS Subpart TTTT— Standards of Performance for Greenhouse Gas Emissions for
Electric Generating Units
These requirements apply to any steam generating unit, IGCC, or stationary combustion
turbine that commenced construction after January 8, 2014 or commenced modification
or reconstruction after June 18, 2014 that has a base load rating of more than 250
MMBtu/hr and serves a generator greater than 25 MW.
Construction commenced on the combustion turbines prior to January 8, 2014 thus
these units do not meet the applicability date in Subpart TTTT and are not subject to
these requirements.
NSPS Subparts UUUU and UUUUa — Emission Guidelines for Greenhouse Gas (GHG)
for Existing Electric Utility Generating Unit (EGU)
EPA proposed guidelines for states to develop plans to establish emission standards for
limiting GHG emissions from existing EGUs, referred to as the Clean Power Plan
(CPP). These proposed guidelines were published in the Federal Register on June 18,
2014 and included requirements in 40 CFR Part 60 Subpart UUUU (Emission
Guidelines for Greenhouse Gas (GHG) and Compliance Times for Existing Electric
Utility Generating Units). Final guidelines for EGUs were published in the Federal
Register on October 23, 2015. The guidelines applied to EGUs that commenced
construction on or before January 8, 2014 thus the combustion turbines would qualify as
existing EGUs and potentially be subject to these requirements. A proposal to repeal
these guidelines for EGUs was published in the Federal Register on October 16, 2017.
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A proposed replacement for the Subpart UUUU guidelines, referred to as the Affordable
Clean Energy (ACE) rule, was signed by EPA on August 20, 2018 (published in the
Federal Register on August 31, 2018) and sets forth requirements in NSPS Subpart
UUUUa — Emission Guidelines for Greenhouse Gas Emissions and Compliance
Timelines for Electric Utility Generating Units. The CPP repeal and replacement rule
(ACE) was finalized on June 19, 2019 (published in the Federal Register on July 8,
2019). These guidelines apply to EGUs that commenced construction on or before
August 31, 2018, however, the proposed rule excludes both simple and combined cycle
combustion turbines from the requirements. Therefore, at this time it appears that the
combustion turbines would not be subject to these requirements.
Compliance Assurance Monitoring (CAM) requirements
CAM applies to any emission unit that is subject to an emission limitation, uses a control
device to achieve compliance with that emission limitation and has potential pre-control
emissions greater than major source levels. The current Title V permit includes CAM
requirements for Turbine 4 with respect to NOx emissions. As indicated in the TRD 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). As indicated in
the TRD to support the second renewal of the Title V permit (issued January 1, 2011),
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.
Colorado Regulation No. 7 Requirements
Revisions have been made to Colorado Regulation No. 7, since the current permit
(renewed January 1, 2016) was issued, therefore, the applicability of the revised
requirements are discussed here.
Revisions to Regulation No. 7 were adopted by the Colorado Air Quality Control
Commission (AQCC) on December 19, 2019 (effective February 14, 2020). The
revisions include a reorganization of Regulation No. 7. The regulation was reorganized
into parts and the various sections are renumbered and assigned to a part (e.g. Part B).
Except for newly added sections and as otherwise noted, the below discussion utilizes
the numbering prior to the December 19, 2019 revisions.
Also, as part of the December 19, 2019 revisions two new sections were included that
are applicable state-wide (Part D, Sections V (requirements for natural gas transmission
and storage facilities) and VI (requirements for emission inventories from oil and natural
gas operations)) but these sections do not apply to this facility.
Colorado Regulation No. 7, Section X.E — Industrial Solvent Cleaning Operations
(Renumbered as Part C, Section II.E in December 19, 2019 revisions)
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The Colorado AQCC adopted provisions in Regulation No. 7 on November 17, 2016
(effective January 14, 2017) to address requirements that were triggered from the
bump-up from Marginal to Moderate nonattainment for the 8-hour ozone control area
(also referred to as the Denver Metro/North Front Range (DMNFR) area).
These revisions to Reg 7 included requirements for industrial solvent cleaning
operations in Section X.E that could potentially apply at this facility. The requirements in
Section X.E apply to industrial solvent cleaning operations with total combined
uncontrolled actual VOC emissions equal to or greater than 3 tons per calendar year.
Colorado Regulation No. 7, Part C, Section II.F — General Solvent Use
This was a new section included in the December 19, 2019 revisions adopted by the
Colorado AQCC and in accordance with Section II.F.1.a applies to operations within the
8-hour ozone control area that use solvents with uncontrolled, actual VOC emissions
greater than or equal to two (2) tons per year that existed at a major source of VOC
emissions (50 tons/yr or greater) as of January 27, 2020 (date of re-classification to
serious non-attainment).
In their September 28, 2020 comments on the draft permit and technical review
document, the source indicated that solvent use was minimal, even during a routine
outage, and that actual, uncontrolled emissions from solvent use would not meet or
exceed 2 tons/yr of VOC. Therefore, the requirements in Part C, Sections II.E and II.F
do not apply.
Colorado Regulation No. 7, Section XVI.D - Requirements for Stationary and Portable
Combustion Equipment in the 8-Hour Ozone Control Area and Colorado Regulation No.
7, Section XIX — Requirements for Major Sources of NOx and VOC
The AQCC adopted provisions in Regulation No. 7 on November 17, 2016 (effective
January 14, 2017) to address requirements that were triggered from the bump-up from
Marginal to Moderate nonattainment for the 8-hour ozone control/DMNFR area.
The combustion process adjustment requirements in Section XVI.D apply to boilers,
duct burners, process heaters, engines and combustion turbines thus these
requirements apply to equipment at this facility. Under Section XIX.B, PSCo was
required to submit a RACT analysis for the combustion turbines by December 31, 2017.
PSCo submitted the required RACT analysis on December 29, 2017.
The AQCC adopted revisions in Regulation No. 7 on July 19, 2018 (effective September
14, 2018) to address the RACT analyses for combustion equipment that major sources
submitted as required by Section XIX.B. As part of the July 19, 2018 revisions, Section
XIX and XVI.D were revised.
The requirements in Section XVI.D apply to stationary combustion equipment that
existed at a major source of NOx as of June 3, 2016 located in the 8-hour ozone control
area. Sources subject to emission limitations in Section XVD.4 must comply with those
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limits by October 1, 2021. This facility was a major source of NOx as of June 3, 2016
and has combustion equipment (five combustion turbines, three duct burners a boiler
and three engines) that existed as of June 3, 2016, therefore, the requirements in
Section XVI.D potentially apply. The emission limitations apply to turbines greater than
10 MMBtu/hr, boilers greater than or equal to 100 MMBtu/hr and compression ignition
engines greater than or equal to 500 hp but do not apply to duct burners. Therefore the
emission limits do not apply to the auxiliary boiler (rated at 70.23 MMBtu/hr) and the
emergency fire pump engine (rated at 255 hp) and potentially apply to the five turbines
and two engines (each rated at 1,800 hp) driving the emergency generator.
The AQCC adopted revisions to Regulation No. 7 on November 15, 2018 (effective
January 14, 2019) to include RACT requirements for breweries and wood furniture
manufacturing, correct some EPA concerns regarding metal furniture surface coating,
miscellaneous metal surface coating and industrial solvent cleaning operations. In
addition, typographical, grammatical, and formatting errors were corrected. The
November 15, 2018 revisions have minimal effect on the requirements for combustion
equipment at this facility.
The December 19, 2019 revisions expanded the applicability of these requirements to
sources that existed at a major sources of NOx (greater than or equal to 50 tons/yr of
NOx) as of the serious designation date [January 27, 2020] and included emission
limitations for boilers with a maximum design heat input capacity greater than or equal
to 50 MMBtu/hr and less than 100 MMBtu/hr located at a major source of NOx (greater
than or equal to 50 tons/yr of NOx) as of the serious designation date [January 27,
2020]. Therefore, these requirements potentially apply to the auxiliary boiler.
The AQCC adopted revisions to Regulation No. 7 on September 23, 2020 (effective
November 14, 2020) to revise some of the oil and gas provisions in Part D, as well
revisions to the requirements for natural gas-fired engines in Part E, Section I. The
primary revisions to the engine requirements was to reduce emissions from natural gas-
fired engines greater than 1,000 hp. The September 2020 revisions do not affect the
equipment at Ft. St. Vrain, as the facility is not engaged in oil and natural gas
operations, nor are there any natural gas-fired engines at the facility.
December 2020 Proposed Revisions
On September 18, 2020, the Division requested that the AQCC schedule a hearing in
December to consider revisions to Colorado Regulation No. 7. These revisions are
intended to address some of the major source RACT requirements in Part E, Section
II.A (formerly Section XVI.D). Since these revisions are likely to be adopted by the
AQCC prior to permit issuance, the Division is addressing these proposed revisions now
with the intent to include the adopted revisions in the issued permit. The proposed
revisions that affect the equipment at Ft. St. Vrain and the draft permit are as follows:
Requirements for Major Sources of NOx and VOC (Part E, Section II.A)
•
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The proposed revisions include changes to the emission limits for boilers greater than
50 MMBtu/hr but less than 100 MMBtu/hr located at major sources of NOx (greater than
or equal to 50 tpy of NOx) as of January 27, 2020 (Section II.A.4.b.(iv)) and combustion
turbines that commenced construction on or before February 18, 2005.
The proposed revisions reduce the NOx limits for boilers greater than 50 MMBtu/hr but
less than 100 MMBtu/hr to 0.1 lb/MMBtu or 83 parts per million dry volume, corrected to
2% 02. These requirements apply to the auxiliary boiler.
The proposed revisions include NOx emissions limits consistent with the requirements
in NSPS KKKK for turbines that commenced construction on or before February 18,
2005 (Section II.A.4.b.(i)). In addition, the revisions add some requirements for excess
emission reporting and operating practices, with minor revisions to monitoring
requirements. Turbines 5 and 6 commenced construction after February 18, 2005 thus
the revisions don't apply to those turbines and as discussed later in this document, the
requirement do not apply to Turbine 4 as this unit was modified after February 18, 2005
and would be subject to the requirements in Section II.A.4.b.(i). However, the proposed
revisions would apply to Turbines 2 and 3.
Ill. Discussion of Modifications Made
The following discussion related to modifications is with respect to the current active
permit (renewed January 1, 2016) and unless specifically noted as "new", the condition
numbers identified in this document reflect the condition numbers in the current permit
(renewed January 1, 2016). Because some permit conditions in the current Title V
permit have been removed, reorganized and/or reformatted as part of this permitting
process, the condition numbers discussed in this document may not reflect the condition
numbers in the draft Title V permit.
Source Requested Modifications
December 6, 2019 Renewal Application
Page following cover page
The source asked that the responsible official and permit contact be revised. The
change was made as requested.
Regulation No. 7, Part E, Section 11.A Requirements (formerly Regulation No. 7, Section
XVI.D requirements)
In the renewal application the source requested that the requirements in Section XVI.D
applicable to the combustion turbines be included in the permit.
Turbines 2, 3 and 4 are greater than 10 MMBtu/hr, commenced construction prior to
February 18, 2005, are subject to the NOx emission limits in 40 CFR Part 60 Subpart
GG per Section II.A.4.b.(i) and are required to meet the emission limits by October 1,
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2021 (per Section II.A.5.a). Monitoring for the II.A.4.b.(i) emission limits may be via
either a CEMS or performance testing.
Note: As discussed later under "September 28, 2020 Comments on the Draft Permit
and Technical Review Document" (page 14), the June 22, 2020 application to replace
the Turbine 4 rotor (processed with the [DATE] revision to the permit), triggered a new
source performance modification for NSPS KKKK with respect to both NOx and S02
emissions. The appropriate Reg 7, Part E, Section II.A requirements associated with
Turbine 4 are discussed beginning on page 14.
Turbines 2 and 3 are already complying with a more stringent NOx BACT limit (the
NSPS GG limits were streamlined in favor of the more stringent requirements) and are
using a part 75 CEMS to monitor compliance with those NOx limits in accordance with
their Title V permit. For this reason the requirements in Sections II.A.4.b.(i) (NSPS GG
NOx limit), II.A.5.a (comply with NSPS GG by October 1, 2021), II.A.5.c.(i)(A) (turbines
may use NOx CEMS), II.A.5.c.(i)(A)(1) (if subject to part 75 must use those
requirements) and II.A.5.c.(iv) (fuel flow meter) will be streamlined in favor of the NOx
BACT limits and/or 40 CFR Part 75 requirements. Streamlined conditions are included
in the permit shield for streamlined conditions (Section IV.3).
Turbines 5 and 6 are greater than 10 MMBtu/hr, commenced construction after
February 18, 2005, are subject to the NOx emission limits in NSPS KKKK per Section
II.A.4.b.(ii) and are required to meet the emission limits by October 1, 2021 (per Section
II.A.5.a). Monitoring for the II.A.4.b.(ii) emission limits may be via either a CEMS or
performance testing.
Turbines 5 and 6 are already complying with the NSPS KKKK NOx limits, as well as
more stringent RACT limits and are using a part 75 CEMS to monitor compliance with
those NOx limits in accordance with their Title V permit. In addition, the turbines have a
combined fuel limit that restricts the capacity factor to less than10%, which would likely
qualify these turbines for an exemption under Section II.A.2.(a).(ii).
Although it is unlikely that either of these turbines would fail to qualify for an exemption,
since Turbines 5 and 6 are already complying with the NSPS KKKK NOx limits, the
requirements in Sections II.A.4.b.(ii) (NSPS KKKK NOx limit), II.A.5.a (comply with
NSPS KKKK by October 1, 2021), II.A.5.c.(i)(A) (turbines may use NOx CEMS),
II.A.5.c.(i)(A)(1) (if subject to part 75 must use those requirements) and II.A.5.c.(iv) (fuel
flow meter) will be streamlined in favor of the NSPS KKKK and/or 40 CFR Part 75
requirements already in the current permit (renewed January 1, 2016). Streamlined
conditions are included in the permit shield for streamlined conditions (Section IV.3).
In addition, the turbines, as well as the duct burners, are also subject to the combustion
process adjustment requirements (Section II.A.6), as well as recordkeeping and
reporting requirements. Since the facility was a major source of NOx (greater than or
equal to 100 tpy NOx) as of June 3, 2016 and no additional combustion equipment have
been added to the facility since then, the provisions in Sections II.A.6.a.(ii) and
II.A.6.b.(viii)(B) were not included. The Division considers that the recordkeeping
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requirements in Sections II.A.7.c (record type and amount of fuel used) and II.A.7.e
(retain records to comply with reporting requirements) and the reporting requirements in
Section II.A.8.a and a.(i) will be streamlined and included in the permit shield for
streamlined conditions (Section IV.3). The recordkeeping requirements in Section
II.A.7.d (capacity factor) and f(combustion process adjustment recordkeeping
requirements) apply and will be included in the permit. Note that the requirements in
Sections II.A.7.a (applicable emission limit when using multiple fuels), II.A.7.b (sources
using CERMS), II.A.7.f.(i)(F) (recordkeeping for combustion process adjustment - if
multiple fuels, the type of fuel and heat input of fuels burned) and II.A.7.g
(recordkeeping for exemptions) do not apply and were not included.
December 2020 Proposed Revisions
On September 18, 2020, the Division requested that the AQCC schedule a hearing in
December to consider revisions to Colorado Regulation No. 7. These revisions are
intended to address some of the major source RACT requirements in Part E, Section
II.A. Since these revisions are likely to be adopted by the AQCC prior to permit
issuance, the Division is addressing these proposed revisions now with the intent to
include the adopted revisions in the issued permit. The proposed revisions include
revised emission limits for turbines that commenced construction prior on or before
February 18, 2005, which affects Turbine 2 and 3. As discussed above, since Turbine 4'
was modified after February 18, 2005 these revisions don't apply to Turbine 4.
Based on the proposed revisions, Turbines 2 and 3 would be subject to NOx limits of 15
ppmv at 15% 02, except that when operating at less than 75% of peak load or at
temperatures less than 0 °F, the NOx limits are 96 ppmv at 15% 02. Since these units
are equipped with HRSGs and NOx CEMS, compliance with the limits would be on a
30-day rolling average and the compliance date would remain the same (October 1,
2021). Numerically, the current NOx BACT limits for Turbines 2 and 3 are as stringent
as the proposed Reg 7 requirements except during combined cycle operation with the
duct burners firing and during periods of startup, shutdown and combustion tuning and
testing, although the NOx BACT limits have a shorter averaging time (1-hr vs. 30 day).
The Proposed Statement of Basis and Purpose indicates that the proposed Reg 7
RACT limits will be implemented as NSPS KKKK, which considers that the NOx limits
do not apply during periods of startup, shutdown and malfunction (see discussion on
page 15). Although the NOx BACT limits are likely more stringent than the proposed
Reg 7 limit, due to the shorter averaging time, if approved, the Division will include the
proposed Reg 7 limits in the permit. In general, the monitoring requirements in Reg 7,
Section II.A.5 remain the same and will remain streamlined (except for the provisions in
I I.A.5.a (comply by October 1, 2021).
The proposed revisions include new monitoring requirements indicating that turbines
that were constructed on or before February 18, 2005 must comply with the applicable
monitoring requirements in NSPS GG. NSPS GG does not include any monitoring
provisions for turbines without water or steam injection, other than a one-time
performance test, although it says that such turbines may use a NOx CEMS. Therefore,
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the proposed new monitoring requirements (comply with NSPS GG monitoring
requirements) will be streamlined in favor of the Part 75 monitoring requirements
included in the current permit (renewed January 1, 2016)
The proposed revisions also include some good operating practice requirements, these
requirements will be streamlined in favor of the NSPS good operating practices
requirement.
Permit Revisions
The following changes were made to the permit to address this request.
Section 11.1, 2 and 8 — Combustion Turbines
• Added "new" Conditions 1.18, 2.17 and 8.20 to include the combustion process
adjustment requirements.
"New" Section 11.10 — Regulation No. 7, Part E, Section II.A.6 and 7.f Requirements
• The combustion process adjustment and associated recordkeeping requirements
were included in this new condition.
Section VI — Permit Shield
• The following requirements were included in the table in Section IV.3 (permit shield
for streamlined condition):
o Regulation No. 7, Part E, Sections II.A.4.b.(i) (NSPS GG NOx limit), II.A.4.b.(ii)
(NSPS KKKK NOx limit), II.A.5.a (comply by October 1, 2021), II.A.5.c.(i)(A)
(turbines may use a NOx CEMS), II.A.5.c.(i)(A)(1) (if subject to part 75 must use
those requirements), and II.A.5.c.(iv) (fuel flow meter) requirements for the
turbines.
o Regulation No. 7, Part E, Sections II.A.7.c (keep records of type and amount of
fuel used), II.A.7.e (maintain records generated for reports for 5 years) and
II.A.8.a and a.(i) (sources using a CEMS submit either quarterly or semi-annual
excess emission reports).
Appendix A
The source requested revisions to "Directions to the Plant" to change "192" to "19 1/2".
The changes were made as requested.
The source requested changes to the insignificant activity list. The changes made to the
permit to address this request are as follows:
• Revised the description of the sulfuric acid storage tanks under category Reg 3, Part
C.II.E.3.b to indicate there is just one (1) 20,000 gallon tank (the 750 gal tank was
removed).
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• Removed the Calgon 403 tank (4,000 gal) from the Reg 3, Part C.II.E.3.000
category.
• Corrected the description under category Reg 3, Part C, II.E.3.kkk) to indicate there
are just 2 forklifts.
September 28, 2020 Comments on the Draft Permit and Technical Review
Document
The sources September 28, 2020 comments on the draft permit and technical review
document were addressed as follows:
Section l — General Activities and Summary
• The heat input rate for Turbine 4 was increased from 1,521 MMBtu/hr to 1,704
MMBtu/hr and overall rating (turbine plus duct burner) was increase to 2,126
MMBtu/hr. The design heat input rate for Turbine 4 increased with the Unit 4 rotor
replacement project (addressed in the significant modification application received
on June 22, 2020).
Section 11.2 —Turbine 4
• The language in Condition 2.2.1 (annual PM and PM() emissions) was revised to
require that emissions be calculated using the monthly heat input to the unit as
determined by the data acquisition and handling system (DAHS).
NSPS KKKK Requirements
The source submitted a significant modification application on June 22, 2020 to replace
the rotor on Turbine 4. This modification was processed as a significant modification on
its own, with the revised permit issued on [DATE]. During the processing of that
modification, the Division failed to address whether the project triggered a modification
under the new source performance standards (40 CFR Part 60). Therefore, during the
pre-public comment review period, the Division asked the source to address the issue.
In their September 28, 2020 comments on the draft permit and technical review
document, the source indicated that NSPS KKKK was triggered and in follow-up email
conversations, the source confirmed that NSPS KKKK was triggered for both NOx and
S02 emissions.
Note that as indicated in 60.4305(b), stationary combustion turbines regulated under
this part are exempt from the requirements of Subpart GG and HRSGs and duct burner
regulated under this part are exempt from the requirements in NSPS Da, Db and Dc of
this this part.
NSPS KKKK
Turbine 4 will be subject to NOx and S02 emission limits. In addition to the primary NOx
limit (15 ppm NOx at 15% 02), there are alternative limits when the turbine is operated
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at less than 75 percent of peak load and at temperatures less than 0 °F and all of these
emission limitations will be included in the permit. Note that the alternative limit for heat
recovery units operating independent of the combustion turbine has not been included
as the HRSG cannot be operated without the combustion turbine.
Compliance with the NOx limit will be monitored using the NOx CEMS. For sources
using a NOx CEMS, compliance with the standard is based on a 30-day rolling average
for combined cycle units. Although Turbine 4 can be operated in simple cycle mode, the
turbine is equipped with heat recovery and thus it is a combined cycle unit and the 30-
day average applies.
Unless otherwise specified in the specific subpart, the Division has generally considered
that NSPS emission limitations do not apply during periods of startup, shutdown and
malfunction, unless specifically stated in the specific subpart (although any excess
emissions during these periods must be reported with the excess emission reports).
Specifically, EPA has indicated (4/18/75, determination control no. A007) that when 40
CFR Part 60 Subpart A § 60.11(d) was developed "...it was recognized that sources
which ordinarily comply with the standards may during periods of startup, shutdown and
malfunction unavoidably release pollutants in excess of the standards". In addition,
EPA has also indicated (5/15/74, determination control number D034) that "[s]ection
60.11(a) makes it clear that the data obtained from these reports are not used in
determining violations of the emission standards. Our purpose in requiring the submittal
of excess emissions is to determine whether affected facilities are being operated and
maintained 'in a manner consistent with good air pollution control practices for
minimizing emissions' as required by 60.11(d)." In addition, the preamble to the final
rule (published in the federal register on July 6, 2006) addresses the applicability of the
limitations during startup and shutdown specifically as follows (pg 38487, 3rd column,
last paragraph):
The final rule states that excess emissions and deviations must be
recorded during periods of startup, shutdown, and malfunction. We
recognize that even for well-operated units with efficient NOx emission
controls, excess emission "spikes" during unit startup and shutdown are
inevitable, and malfunctions of emission controls and process equipment
occasionally occur. However, at all times, including periods of startup,
shutdown, and malfunction, 40 CFR 60.11(d) requires affected units to be
operated in a manner consistent with good air pollution control practice for
minimizing emissions. Excess emissions data may be used to determine
whether a facility's operation and maintenance procedures are consistent
with 40 CFR 60.11(d). While continuous compliance is not required,
excess emissions during startup, shutdown, and malfunction must be
reported.
Further evidence that the NSPS KKKK limits do not apply during periods of startup,
shutdown and malfunction can be found in the August 29, 2012 proposed revisions to
NSPS KKKK which proposed that the emission standards would apply at all times
including periods of startup and shutdown. The proposed revisions to require the
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emission standards to apply during periods of startup, shutdown and malfunction only
applies to units that commenced construction, modification or reconstruction on an after
August 30, 2012, which confirms that prior to the proposed revisions, the NSPS KKKK
emission standards did not apply during those periods. Since the August 29, 2012
proposed revisions have not been finalized, the NSPS KKKK emission limits do not
apply during periods of startup, shutdown and malfunction.
Therefore, the Division has added a note to the permit indicating that the NOx limits do
not apply during periods of startups, shutdowns and malfunctions; however,
exceedances during those periods must be reported on the excess emissions reports.
The following discussion provides an explanation regarding why certain NSPS KKKK
requirements were not included in the permit.
SO2 Monitoring Requirements
For units that opt to comply with the SO2 limit in 60.4330(a)(2) (sulfur content of fuel
burned not to exceed 0.060 lb/MMBtu), sources do not have to conduct sulfur
monitoring if it is demonstrated that the fuel sulfur limit is not exceeded. This turbine are
burning natural gas, so that demonstration has been made, sulfur monitoring is not
required and those provisions in NSPS KKKK related to sulfur monitoring have not been
included in the permit. This includes §§ 60.4360 (determine sulfur content), 60.4370
(sulfur content frequency), 63.4385 (excess SO2 emissions defined) and 60.4415 (initial
and subsequent performance tests for sulfur).
In regards to the requirements in 60.4365 which address the exemption for sulfur
monitoring, the current Title V permit (renewed January 1, 2016) requires that Turbine 4
burn only pipeline quality natural gas. Thus the permit includes a requirement for the
natural gas to meet the sulfur limits for pipeline quality (0.5 grains per 100 SCF) and the
permit allows the source to use the methods in 40 CFR Part 75 Appendix D, Section
2.3.1.4 which provides options to use a purchase contract or tariff sheet or to perform
sampling. As a result the Division will streamline the provisions in 60.4365 since these
options both are allowed under Appendix D, Section 2.3.1.4.
NOx Monitoring Requirements
In addition since the source will use a NOx CEMS to assess compliance with the limits,
requirements related to performance testing and/or parameter monitoring will not be
included in the permit. This includes §§ 60.4340(a) (annual performance test),
60.4340(b)(2) (continuous parameter monitoring), 60.4355 (parameter monitoring
plans), 60.4400 (initial and subsequent performance tests), except for 60.4400(b)(5)
and 60.4410 (establish a valid parameter range).
With respect to the NOx 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 current permit
(renewed January 1, 2016) requires a Part 75 NOx CEMS for the BACT limits the
source will follow the Part 75 requirements.
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To that end, some of the NSPS KKKK requirements related to the NOx CEMS will be
streamlined, some will be included in the permit and some will not.
o The following requirements in NSPS KKKK have been included in the permit:
• 60.4350(a) (calculate hourly averages per 60.13(h))
• 60.4400(b)(5) (CEMS performance evaluation can be conducted separately
or as part of the initial test per 60.4405)
• 60.4405 (initial test with NOx CEMS)
o The following requirements in NSPS KKKK have been streamlined (included in
the permit shield for streamlined conditions, Section IV.3):
• 60.4340(b)(1) (use a NOx CEMS)
• 60.4345(a) (performance spec), 60.4345(b) (valid hour), 60.4345(c) (fuel flow
meter) and 60.4345(e) (QA/QC plan)
o The following requirements will not be included in the permit.
• 63.4345(d) (watt and steam flow meters and temperature or pressure
monitoring device) was not included since the source will monitor compliance
with the ppm limits.
• 60.4350(c) (correction to 15 percent 02 not allowed) was not included in the
permit as this seems to be an error. The ppm limits included in Table 1 of
NSPS KKKK are at 15% 02, so it is not clear why correction to 15 percent 02
is not allowed, since that defines the limit.
• 60.4350(g) (simple cycle unit averaging time) was not included as this
turbine is a combined cycle unit (i.e. equipped with heat recovery).
Other Requirements
Requirements related to burning distillate oil, turbines using water or steam injection or
requirements for complying with the output based standards (lb/MWhr) were not
included as Turbine 4 does not burn distillate oil or use water or steam-injection and the
source is complying with the concentration based limits (ppm). This includes §§ 60.4325
(limits for turbines burning distillate oil and natural gas) and 60.4335 (demonstrate NOx
compliance if using water/steam injection).
Miscellaneous other requirements were not included in the permit for the reasons
discussed below:
o 60.4320(b) (2 turbines connected to a single generator) was not included, since
Turbine 4 does not share a generator.
o 60.4330(a)(1) and (3) were not included as 60.4330(a)(2) was chosen as the SO2
limit. 60.4330(b) was not included as the turbines are located in a continental
area.
o 60.4333(b) was not included since Turbine 4 has a dedicated HRSG and stack.
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o 60.4380(a) and (c) were not included as these requirements are for turbines
using water or steam to fuel rate monitoring or other parametric monitoring.
o The requirements in § 63.4390 were not included as these are not emergency or
R & D turbines.
o The requirements in § 60.4395 (timing for reports) was streamlined (included in
the permit shield for streamlined conditions, Section IV.3), as frequency of
reports will be quarterly to be consistent with Acid Rain reporting.
Reg 7, Part E, Section II.A Requirements
Turbine 4 will have to comply with the NSPS KKKK NOx limits upon startup after the
rotor replacement (November 2020) and will use their Part 75 CEMS to comply with
those requirements. Turbine 4 is currently complying with the more stringent BACT
limits and are using a part 75 CEMS in accordance with their Title V permit.
Since Turbine 4 will be complying with the NSPS KKKK NOx limits by the October 1,
2021 compliance date, the requirements in Sections II.A.4.b.(ii) (NSPS KKKK NOx
limit), II.A.5.a (comply with NSPS KKKK by October 1, 2021), II.A.5.c.(i)(A) (turbines
may use NOx CEMS), II.A.5.c.(i)(A)(1) (if subject to part 75 must use those
requirements) and II.A.5.c.(iv) (fuel flow meter) will be streamlined in favor of the NSPS
KKKK and/or 40 CFR Part 75 requirements already in the current permit (renewed
January 1, 2016). Streamlined conditions are included in the permit shield for
streamlined conditions (Section IV.3).
Miscellaneous
Turbine 4 is now subject to the NSPS KKKK requirements, which includes a fuel sulfur
limit of 0.06 lb/MMBtu S02, which is less stringent than the Reg 1 SO2 limit of 0.35
lb/MMBtu, therefore, the Reg 1 SO2 limit will be streamlined in favor of the NSPS KKKK
limit.
Permit Revisions
The following changes were made to the permit to address the NSPS KKKK
requirements:
Section 11.2 —Turbine 4
• Removed Conditions 2.2.4 (PM limits for duct burner), 2.4.4 (S02 limits for duct
burner) and 2.15 (opacity) as these requirements are from NSPS Da. Note that in
general the current Title V permit (renewed January 1, 2016) indicates these
requirements as originating from Construction Permit 99WE0762 PSD and the
construction permit clearly indicates they originate from NSPS Da. Conditions that
follow were renumbered.
• The NSPS GG SO2 provisions in Condition 2.4.2 were replaced with the NSPS
KKKK SO2 provisions.
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• Removed Condition 2.4.3 (Reg 1 SO2 limit) and included it in the table for
streamlined conditions (Section IV.3).
• The NSPS KKKK NOx emission limits were included in "new" Condition 2.5.2 (note
that "old" Condition 2.5.2 (annual NOx limit) was renumbered as Condition 2.5.3).
• The general requirements in 60.4333(a) were included as "new" Condition 2.18.
Section IV— Permit Shield
• The following changes were made to the table in Section IV.3 (shield for streamlined
conditions):
o Removed Turbine 4 permit condition references for the NSPS Da and GG
requirements.
o The provisions in 60.4345(a), (c) and (e), 60.4365(a) and (b) and 60.4395 were
included.
o Included Turbine 4 permit condition references for Colorado Regulation No. 1,
Sections VI.B.4.c.(ii) and VI.B.2 (Reg 1 SO2 limit), 60.6340(b)(1) (use NOx
CEMS) and Reg 7, Part E, Section II.A.4.b.(ii) and II.A.5.a (meet NSPS KKKK
NOx limit by October 1, 2021) to indicate they are also streamlined with respect
to Turbine 4.
o Removed Turbine 4 permit condition references for Reg 7, Part E, Section
II.A.4.b.(i) and II.A.5.a (meet NSPS GG NOx limit by October 1, 2021).
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
• 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 previous 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).
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• Minor revisions were made to the address under"issued to".
Section l — General Activities and Summary
• The citation for the definition of 8-hour ozone control area in Condition 1.1 was
revised and a sentence was added indicating the 8-hr ozone control area has been
classified as a serious non-attainment area.
• Included "Section IV Condition 30 (as noted)" to the list of state-only requirements in
Condition 1.4. Portions of General Condition 30 (volatile organic compounds) are
state-only in certain areas (new nonattainment areas for either the 1-hr or 8-hr ozone
standard).
• Revised the major stationary source threshold for NANSR in Condition 3.2 to 50
tons/yr. The threshold was lowered when the area was re-designated as a serious
non-attainment area.
• The following changes were made to the table in Condition 6.1:
o Added a footnote to explain the N/A under the "AIRS point number column."
Section 11.1 —Turbines 2 and 3
• Added "new" Conditions 1.2.1.11 and 1.3.1.11 and a statement to Condition 1.5 to
clarify that the limits for combined cycle operation with supplemental fuel applies to
any hour in which fuel was fired in the duct burner. The Division had indicated to
PSCo that this change would be made with the third renewal (issued January 1,
2016) but it was overlooked and this clarification is being made with this renewal.
• Conditions 1.3.1.8 and 1.3.1.9 were revised to remove the phrase "nor shall the data
be bias-adjusted". The changes were made because the CO CEMS is subject to the
requirements in Part 60, which does not require bias-adjustment.
• Removed the NSPS Da PM and opacity requirements in Conditions 1.6.3 and 1.16.
Conditions that follow are renumbered. In the February 16, 2012 revisions to NSPS
Da, EPA included language indicating that affected facilities that burn natural gas
are not subject to the PM and opacity requirements (see §§ 60.42Da(b)(2) and (f)),
therefore, those requirements were removed.
• Added language to clarify that the emission limits in Conditions 1.6.4 and 1.7 include
both filterable and condensable particulate matter. Condition 1.6.4 was renumbered
as Condition 1.6.3.
• Revised the emission factors in Condition 1.6.4.1 to include the latest PM
performance test results. Condition 1.6.4.1 was renumbered as Condition 1.6.3.1.
• Added a "new" Condition 1.11 to include the requirement for a fuel flow meter.
Conditions that follow are renumbered. Currently the permit includes continuous
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monitoring system requirements in Condition 1.10, which refers to Condition 5.
Condition 5.1.7 includes a requirement to continuously monitor flow of pipe line
quality natrual gas. It is more consistent with other PSCo permits to include a
separate requirement for a continuous fuel flow meter, rather than to include it in the
general CEMS section, hence this change was made.
• Revised the language in Condition 1.11.1 to be consistent with language in the
regulation. Condition 1.11.1 was renumbered as Condition 1.12.1.
• Revisions were made to Condition 1.12 to clarify the emission limits (included
Condition number) for which the performance test is required and revised the table
for previous performance tests. In addition, the paragraph regarding the test protocol
and report was revised to reflect current language and "performance test" was
replaced with "compliance test". Condition 1.12 was renumbered as Condition 1.13.
Section 11.2 —Turbine 4
• Added language to clarify that the emission limit in Condition 2.2.1 includes both
filterable and condensable particulate matter.
• Conditions 2.6.1.8 and 2.6.1.9 were revised to remove the phrase "nor shall the data
be bias-adjusted". The changes were made because the CO CEMS is subject to the
requirements in Part 60, which does not require bias-adjustment.
• Added a "new" Condition 2.9 to include the requirement for a fuel flow meter.
Conditions thereafter are renumbered. Currently the permit includes continuous
monitoring system requirements in Condition 1.10, which refers to Condition 5.
Condition 5.1.7 includes a requirement to continuously monitor flow of pipe line
quality natural gas. It is more consistent with other PSCo permits to include a
separate requirement for a continuous fuel flow meter, rather than to include it in the
general CEMS section, hence this change was made.
• Revised the language in Condition 2.11.1 to be consistent with language in the
regulation. Condition 2.11.1 was renumbered as Condition 2.12.1.
Section 11.3 Auxiliary Boiler
Regulation No. 7, Part E, Section II.A Requirements (formerly Regulation No. 7 Section
XVI.D requirements)
With the December 19, 2019 revisions to Regulation No. 7, the auxiliary boiler became
potentially subject to the requirements in Regulation No. 7, Part E, Section II.A (formerly
Section XVI.D). As previously indicated, with the December 19, 2019 revisions,
emission limits were included in Section II.A.4 for boilers greater than or equal to 50
MMBtu/hr and less than 100 MMBtu/hr, thus the auxiliary boiler is potentially subject to
both the emission limit and the combustion process adjustment requirements. Note that
the emission limits for these smaller boilers apply to boilers located at a major source of
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NOx (greater than or equal to 50 tpy of NOx) as of January 27, 2020, thus the
compliance date for the emission limitations is July 20, 2021.
The latest APEN on file (received April 27, 2017) for the auxiliary boiler indicates actual,
uncontrolled NOx emission above 5 tons per year. In addition, based on data provided
for the 2018 inspection, the annual capacity factor (calendar year basis) indicates that
the auxiliary boiler was operated above a 20% capacity factor in 2015, 2016 and 2017,
thus the Division does not believe the boiler qualifies for an exemption under Regulation
No. 7, Part E, Section II.A.2 and that the unit is subject to both the emission limit and
combustion process adjustment requirements.
December 2020 Proposed Revisions
On September 18, 2020, the Division requested that the AQCC schedule a hearing in
December to consider revisions to Colorado Regulation No. 7. These revisions are
intended to address some of the major source RACT requirements in Part E, Section
II.A. Since these revisions are likely to be adopted by the AQCC prior to permit
issuance, the Division is addressing these proposed revisions now with the intent to
include the adopted revisions in the issued permit. The proposed revisions would
change the NOx limit for boilers greater than or equal to 50 MMBtu/hr and less than 100
MMBtu/hr from 0.2 Ib/MMBtu to 0.1 lb/MMBtu.
Therefore, the requirements in Regulation No. 7, Part E, Section II.A that apply have
been included in "new" Condition 3.6 as follows:
• Exemptions, emission limits, compliance demonstration, recordkeeping and
reporting requirement (Sections II.A.1, 2, 4, 5, 7 & 8).
o The exemption language in Section II.A.2 and relevant exemptions in II.A.2.a.(i)
and d were included in the event that they apply to future operations of the unit.
o The second paragraph in Section II.A.4 was included, since the earlier
compliance date (July 20, 2021) applies as discussed above. The emission limits
in Section II.A.4.a.(iv), as well as the combustion process adjustment
requirement in Section II.A.4.(v) were included.
o The compliance demonstration requirements in Section II.A.5.c.(ii)(B) and (C)
were included.
o The recordkeeping requirements in Sections II.A.7.a (calculate limit when
multiple fuels used) and II.A.7.b (use CERMS) do not apply and were not
included. Since the permit already requires the source to record fuel use, the
requirements in Section II.A.7.c (keep records of type and amount of fuel) were
streamlined. Streamlined conditions are included in the permit shield for
streamlined conditions (Section IV.3). Subsequently, the requirements in
Sections II.A.7.d (annual capacity factor), II.A.7.e (records to comply with
reporting requirements) and II.A.7.g (exemptions) were included. Note that the
recordkeeping requirements associated with combustion process adjustment are
discussed below.
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o The requirements in Section II.A.8.b were included.
• combustion process adjustment and associated recordkeeping requirements
(Section II.A.6 and II.A.7.f)
o Note that Condition 3.6 references Section II, Condition 10.1 for the combustion
process adjustment requirements in Section II.A.6 and Section II, Condition 10.2
for the recordkeeping requirements related to combustion process adjustments in
Section II.A.7.f.
o The requirements in Section II.A.6.a.(ii) and II.A.6.b.(viii)(B) (comply by May 1,
2020 ) and Section II.A.7.f.(i)(E) (recordkeeping requirement if multiple fuels
burned) do not apply and were not included.
Section 11.4 — Cooling Towers
• Based on EPA's response to a petition on another Title V operating permit, language
changes were made to Condition 4.4 to require that records be maintained since this
condition relies on good engineering practices (GEP).
Section 11.5 — Continuous Emission Monitoring System Requirements
• As discussed previously, Condition 5.1.7 was removed, since a specific condition for
a fuel flow meter was included in each for the sections for the turbines (Sections 11.1,
11.2 and 11.8).
• Included "operating mode — startup, shutdown and/or standard operation" as "new"
Condition 5.1.7. Monitoring operating mode is important and is monitored in other
PSCo permits, was included in the construction permit for Turbines 5 and 6
(07WE1100), and should be included here.
• The language in Condition 5.3.2 was revised to be consistent with the language in
the regulation.
• Minor revisions were made to the language in Condition 5.3.5.
• Added language to the beginning of Condition 5.6 to indicate the version of the
NSPS Subpart KKKK requirements and made cosmetic revisions to the citations.
• Minor corrections and clarifications were made to Conditions 5.6.2 and 5.6.3.1.
Section 11.6 — Gasoline Storage Tank
• The requirements in 40 CFR Part 63 Subpart CCCCCC § 63.11111(j) was included
as "new" Condition 6.1.4. Conditions that follow are renumbered.
• Revisions were made to the Subpart CCCCCC citations in Conditions 6.1.4 and
6.1.9 to make them more consistent. Condition 6.1.9 was renumbered as Condition
6.1.10.
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Section 11.7 — Cold Cleaner Solvent Vats
• Corrected the error in the section title (M002 should be M003).
• Due to the December 19, 2019 revisions to Regulation No. 7 (effective February 14,
2020), the Reg 7 citations were revised.
Section 11.8 —Turbines 5 and 6
• The following changes were made to the NSPS KKKK NOx requirements in
Condition 8.2.2:
o Added language to Condition 8.2.2 that indicates the version of the NSPS KKKK
requirements that are included and made cosmetic revisions to the citations. This
also references other conditions within this section that include NSPS KKKK
requirements.
o Condition 8.2.2.5 was replaced with language in § 60.4350(a).
o Condition 8.2.2.8 was replaced with the language in § 60.4350(d) and was
renumbered as Condition 8.2.2.7.
o Condition 8.2.2.7 was revised to correct the citation (should be 60.4350(g)) and
was renumbered as Condition 8.2.2.9.
o Included the provisions in § 60.4350(f) as "new" Condition 8.2.2.8.
o Added a "new" condition 8.2.2.10 to refer to additional requirements related to
excess emission reporting.
• Minor revisions were made to Condition 8.4.1.
• Added language to clarify that the emission limits in Conditions 8.6.2 and 8.7 include
both filterable and condensable particulate matter.
• Added a "new" Condition 8.11 to include the requirement for a fuel flow meter.
Conditions that follow are renumbered. Currently the permit includes continuous
monitoring system requirements in Condition 8.10, which refers to Condition 5.
Condition 5.1.7 includes a requirement to continuously monitor flow of pipe line
quality natural gas. It is more consistent with other PSCo permits to include a
separate requirement for a continuous fuel flow meter, rather than to include it in the
general CEMS section, hence this change was made.
• Revised the language in Condition 8.12.1 to be consistent with language in the
regulation. Condition 8.12.1 was renumbered as Condition 8.13.1.
• Added a footnote to the table in Condition 8.18 to indicate that threshold for NOx for
the NANSR program is based on the significance level at the time the units were
permitted. Condition 8.18 was renumbered as Condition 8.19.
Section 11.9 — Diesel Fuel-Fired Internal Combustion Engines
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• Revised the note under the summary table to indicate when the engines would no
longer be APEN exempt (i.e. how many hours of operation to exceed 1 ton/yr of
NOx).
• Revised the note under Condition 9.1 to reflect the version date of the MACT ZZZZ
requirements. In addition language was added to address the vacatur of certain
requirements. The vacated requirements apply to the use of emergency generators
for demand response.
Regulation No. 7, Part E, Section 11.A Requirements (formerly Regulation No. 7, Section
XVI.D requirements)
The requirements for diesel fuel-fired engines in Regulation No. 7, Part E, Section II.A
include NOx emission limitations for engines equal to or greater than 500 hp and
combustion adjustment requirements for all engines, regardless of size. The emergency
generators are each rated at 1800 hp and the emergency fire pump is rated at 255 hp.
The diesel fuel-fired engines are APEN exempt (actual, uncontrolled emissions less
than 1 tons per year of VOC), thus the emergency generators are exempt from the
emission limitations, as well as the monitoring, reporting and most recordkeeping
requirements per Sections II.A.2.d and none of the engines are subject to the
combustion process adjustment requirements per II.A.6.a.(i) (combustion process
adjustment requirements only apply to sources with actual, uncontrolled emissions
equal to or greater than 5 tons per year of NOx).
Emissions from the engines would exceed 5 tons/yr of NOx at 253 hours per year for
each emergency generator and 1,265 hours per year for the emergency fire pump
engine. These values are based on AP-42 emission factors and design rate (hp). AP-42
emission factors for the emergency generators are from Section 3.4, dated 10/1996,
Table 2.4-1 (0.024 lb/hp-hr) and Section 3.3, dated 10/1996, Table 3.3.-1 for the
emergency fire pump (0.031 lb/hp-hr). It is unlikely that any of the engines would have
actual, uncontrolled NOx emissions equal to or greater than 5 tons/yr.
Sources that claim an exemption under Section II.A.2, are required to maintain records
that an exemption applies (per Sections II.A.2 and II.A.7.g), so the recordkeeping
requirements will be included in the permit for the emergency generators. These
requirements will be included in "new" Condition 9.4
Note Section II.A does not require that records be kept for sources that are not subject
to the combustion process adjustment requirement because their actual, uncontrolled
emissions are below 5 tons per year of NOx.
Section III —Acid Rain Requirements'
• Revised the designated and alternate designated representatives.
• Revised the table in Section 2 to include calendar years corresponding to the
relevant permit term for the renewal.
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Public Service Company of Colorado—Ft. St.Vrain Station Operating Permit No. 97OPWE180
Technical Review Document—Fourth Renewal
• Minor revisions were made to the standard requirements (Section 111.3) and revised
the date for these requirements.
• Removed the language regarding submitting quarterly opacity reports pursuant to §
75.65 in Section 4. Gas fired units are not required to monitor opacity under Part 75
so the reporting requirements in 75.65 do not apply.
• Added a statement under Section 4 regarding changes to the designated
representative or alternate designated representative.
• Removed the statement in Section 4 indicating reports shall be submitted to the
addresses identified in Appendix D as the Acid Rain reports are submitted
electronically.
Section IV— Permit Shield
• The following changes were made to the table in Section IV.1 (shield for non-
applicable requirements):
o Removed Reg 7, Section V.B, since this facility has a gasoline storage tank for
dispensing gasoline to plant vehicles and the provisions in Section V.B are
included in the General Conditions (Section V, Condition 29.).
o The Reg 7 citations were corrected to reflect the December 19, 2019 revisions
(effective February 14, 2020).
• The following changes were made to the table in Section IV.3 (shield for streamlined
conditions):
o Removed the requirements in 40 CFR Part 60 Subpart KKKK § 60.4350(a), since
this requirement was included in the permit.
o The provisions in 40 CFR Part 60 Subpart KKKK§§ 60.4345(a), (c) and (e),
60.4365(a) and (b) and 60.4395, were included and noted to apply to Turbines 5
and 6. These requirements were not streamlined when Turbines 5 and 6 were
first included in the permit as discussed in the TRD for the second renewal
(issued January 1, 2011). During this renewal they were included for Turbine 4
and so are being included for Turbines 5 and 6 as well.
Section V— General Conditions
• The version date was revised.
• Revised General Condition 12 to include requirements in Reg 3, Part D.
• Corrected the citation in Condition 18 (changed from "CCR 1001-17" to "CCR 1001-
19").
• Revised the language in Condition 22.e to reference Reg 3, Part A, Section II.A and
to indicate that an APEN shall be filed once per year for control equipment changes
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Public Service Company of Colorado—Ft. St. Vrain Station Operating Permit No. 97OPWE180
Technical Review Document—Fourth Renewal
at condensate storage tanks subject to Reg 7, Part D, Section I (previously Reg 7
Section XII).
• Added major stationary source monitoring, recordkeeping and reporting
requirements in "new" Condition 24. Conditions that follow are renumbered.
• Revised Condition 29 (VOC) to reflect the December 19, 2019 Reg 7 revisions
(correct citations) and to note in the introductory paragraph that portions are state-
only in certain areas (new nonattainment areas for either the 1-hr or 8-hr ozone
standard).
Appendices
• Removed the asterisk (*) from the category Reg 3, Part C.II.E.3.b in the insignificant
activity list (Appendix A) as there is no * in Reg 3, Part C for this category.
• Revised Appendix D to include a version date, update EPA info (compliance
notifications and permit mods), and replace "Matt Burgett" with "Title V Unit
Supervisor".
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Public Service Company of Colorado—Ft. St. Vrain Station Operating Permit No. 97OPWE180
Technical Review Document—Fourth Renewal
PSCo - Ft. St. Vrain —Total HAP Emissions (tons/yr)
Emission formaldehyde acetaldehyde toluene benzene acrolein xylene chloroform hexane Dichloro- nickel cadmium manganese chromium Total
Unit benzene
Unit 2- 2.61 0.58 0.83 0.08 0.04 0.41 0.73 0.51 5.79
turbine
Unit 2- 0.01 3.76E-03 7.70E-04 2.15E-03 3.76E-03 1.97E-03 2.51E-03 0.02
DB
Unit 3- 1.52 0.58 0.83 0.08 0.04 0.41 0.73 0.51 4.70
turbine
Unit 3- 0.01 3.76E-03 7.70E-04 2.15E-03 3.76E-03 1.97E-03 2.51E-03 0.02
DB
Unit 4- 2.42 0.55 0.78 0.07 0.04 0.39 0.69 0.48 5.43
turbine
Unit 4- 0.01 3.25E-03 6.66E-04 1.86E-03 3.25E-03 1.70E-03 2.17E-03 0.02
DB
Units 5& 0.79 0.10 0.14 1.33E-02 0.01 0.07 1.28E-01 0.09 1.34
6
B001 0.14 0.00 6.84E-04 1.40E-04 3.91E-04 6.84E-04 3.58E-04 4.56E-04 0.14
M001 2.37 2.37
Total 7.47 1.81 2.61 0.25 0.13 1.27 2.37 2.35E-03 6.55E-03 2.30 6.00E-03 1.60 7.64E-03 19.83
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Public Service Company of Colorado—Ft. St.Vrain Station Operating Permit No. 97OPWE180
Technical Review Document—Fourth Renewal
PSCo-Ft. St.Vrain -Actual Emissions (tons/yr)
Unit Data Year PM PM,o/PM2.s SO2 NOx CO VOC HAPs Ammonia
Turbine (T002) 2018 18.51 18.51 2.84 128.39 28.05 4.7 3.91
Turbine (T003) 2018 11.8 11.8 2.44 132.86 25.09 2.7 3.32
Turbine (T004) 2018 25.55 25.55 2.97 58.95 18.88 4.3 4.33 11.88
Auxiliary Boiler 2016 0.3 0.3 0.1 13.7 11.5 0.8 0.001
Cooling/Service Water Towers 2018 3.15 3.15 2.19 2.19
Turbine (T005) 2018 0.64 0.64 0.07 5.25 3.16 0.03 0.001
Turbine T006 2018 0.46 0.46 0.06 5.22 2.37 0.02 0.00'
Total 60.41 60.41 8.48 344.37 89.05 14.74 13.75 11.88
'Actual HAP emissions below the reportable level(250 Ib/yr)
actual emissions from data year 2018 based on the APEN submitted on 4/30/2019
actual emissions from data year 2016 are based on the APEN submitted on 4/27/2017
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