HomeMy WebLinkAbout20202678.tiff C=. X COLORADO
Department of Public
Health&Environment
RECEIVED
Weld County - Clerk to the Board AUG 0 6 2020
11500 St
PO Box 758 WELD COUNTY
Greeley, CO 80632 COMMISSIONERS
August 3, 2020
Dear Sir or Madam:
On August 4, 2020, the Air Pollution Control Division will begin a 30-day public notice period for
Public Service Company of Colorado - Ft. St. Vrain Station. 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
bk co0-,,
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe mac,
Jared Potis, Governor I Jill Hunsaker Ryan,MPH, Executive Director lt;
?u b t ;G Rev;e c J cc:QL(tP) 14 1—O5),P(.4(TK/ER/cH/ow) 2020-2678
0°I/o9 /20 oe(s►-t)
Dv3(/20
.r:41 Air Pollution Control Division
`'Yr
Notice of a Proposed Title V Operating Permit
CDPHE Modification Warranting Public Comment
Website Title: Public Service Company of Colorado - Ft. St. Vrain Station - Weld County
Notice Period Begins: August 4, 2020
NOTICE is hereby given that an application to modify 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 Station
16805 County Road 19%
Platteville, CO 80651
Public Service Company of Colorado has requested to modify their Operating Permit for the Ft. St. Vrain
Station in Weld County, CO. This facility consists of five natural gas-fired combustion turbines used to
generate electricity. The purpose of this modification is to revise the definition of startup for turbine 4 and
to include the major stationary source applicability test in "new" Appendix H. There is no increase in
permitted emissions associated with this modification. A copy of the application, including supplemental
information, the Division's analysis, and a draft of the modified 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 modified 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. Only those portions of the permit affected by the modification are subject to
Public Comment. Those portions of the permit affected by the modification are summarized in Appendix F
of the permit. 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 will 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.
Ale_ y_di-z-v-:. COLORADO
Department of Public
1 � "' Health&Environment
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
• 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-SS-B1
Denver, Colorado 80246-1530
Hearing requests may be submitted to the email address or the mailing address noted above.
440—, COLOR COLORADO
2 Department of Puhlie
come Health @ Envtrpner;t
CQZ(
E*" O
T � SME Nt1M���
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: January 1 , 2016
Last Revised: DRAFT
AIR POLLUTION CONTROL DIVISION
COLORADO OPERATING PERMIT
FACILITY NAME: Ft. St. Vrain Station OPERATING PERMIT NUMBER
FACILITY ID: 1230023 97OPWE180
RENEWED: January 1, 2016
EXPIRATION DATE: January 1, 2021
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'/2
1800 Larimer Street Platteville, CO 80651
Denver, CO 80202 Weld County
INFORMATION RELIED UPON
Operating Permit Renewal Application
Received: December 17, 2014
And Additional Information Received: December 17, 2014 and September 3, 2015
Nature of Business: Combustion Gas Turbine Electric Generating Station
Primary SIC: 4911
RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON
Name: Mark Fox Name: Gary Magno
Title: General Manager—Power Title: Manager, Environmental Services—Air
Generation, Colorado Quality Compliance
Phone: (303)425-3779 Phone: (303) 294-2177
SUBMITTAL DEADLINES
Semi-Annual Monitoring Periods: January 1 —June 30, July 1 —December 31
Semi-Annual Monitoring Report: Due on August 1 2016 and February 1, 2017 & subsequent years
Annual Compliance Period: January 1 —December 31
Annual Compliance Certification: 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 21
3. B001 - Auxiliary Boiler 39
4. M001 - Cooling Water and Service Water Towers 41
5. Continuous Emission Monitoring Systems (CEMS) 43
6. M002 - Gasoline Storage Tank, 500 gallons aboveground 49
7. M002—Cold Cleaner Solvent Vats 52
8. T005 &T006—Two (2) Simple Cycle Combustion Turbines 53
9. M004 - Diesel Fuel Fired Internal Combustion Engines 63
SECTION III-Acid Rain Requirements 70
1. Designated Representative and Alternate Designated Representative 70
2. Sulfur Dioxide Emission Allowances and Nitrogen Oxide Emission Limitations 70
3. Standard Requirements 71
4. Reporting Requirements 74
5. Comments,Notes and Justifications 75
SECTION IV-Permit Shield 76
1. Specific Non-Applicable Requirements 76
2. General Conditions 76
3. Streamlined Conditions 77
SECTION V- General Permit Conditions 79
1. Administrative Changes 79
2. Certification Requirements 79
3. Common Provisions 79
4. Compliance Requirements 83
5. Emergency Provisions 84
6. Emission Controls for Asbestos 84
7. Emissions Trading, Marketable Permits, Economic Incentives 84
8. Fee Payment 85
9. Fugitive Particulate Emissions 85
10. Inspection and Entry 85
11. Minor Permit Modifications 85
12. New Source Review 85
13. No Property Rights Conveyed 86
14. Odor 86
TABLE OF CONTENTS:
15. Off-Permit Changes to the Source 86
16. Opacity 86
17. Open Burning 86
18. Ozone Depleting Compounds 86
19. Permit Expiration and Renewal 86
20. Portable Sources 87
21. Prompt Deviation Reporting 87
22. Record Keeping and Reporting Requirements 87
23. Reopenings for Cause 88
24. Section 502(b)(10) Changes 89
25. Severability Clause 89
26. Significant Permit Modifications 89
27. Special Provisions Concerning the Acid Rain Program 89
28. Transfer or Assignment of Ownership 89
29. Volatile Organic Compounds 90
30. Wood Stoves and Wood burning Appliances 90
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 8
Monitoring and Permit Deviation Report-Part III 10
APPENDIX C 1
Required Format for Annual Compliance Certification Reports 1
APPENDIX D 1
Notification Addresses 1
APPENDIX E 1
Permit Acronyms 1
APPENDIX F 1
Permit Modifications 1
APPENDIX G 1
VOC Correlation Equations 1
APPENDIX H 1
Prevention of Significant Deterioration (PSD) Review and Non-Attainment Area New Source
Review(NANSR) Applicability Test 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-fired engines driving an emergency generator and one (1) diesel-fired engine
driving an emergency fire pump.
The facility is located approximately three miles north and west of Platteville, Colorado. The
area in which the plant operates is designated as attainment for all criteria pollutants except
ozone. It is classified as non-attainment for ozone and is part of the 8-hr Ozone Control Area as
defined in Regulation No. 7, Section II.A.1.
There are no affected states within 50 miles of the plant. Rocky Mountain National Park,
Eagle's Nest National Wilderness Area and Rawah National Wilderness Area, Federal Class I
designated areas, are within 100 kilometers of the plant.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 2
1.2 Until such time as this permit expires or is modified or revoked, the permittee is allowed to
discharge air pollutants from this facility in accordance with the requirements, limitations, and
conditions of this permit.
1.3 This Operating Permit incorporates the applicable requirements contained in the underlying
construction permits, and does not affect those applicable requirements, except as modified
during review of the application or as modified subsequent to permit issuance using the
modification procedures found in Regulation No. 3, Part C. These Part C procedures meet all
applicable substantive New Source Review requirements of Part B. Any revisions made using
the provisions of Regulation No. 3, Part C shall become new applicable requirements for
purposes of this Operating Permit and shall survive reissuance. This Operating Permit
incorporates the applicable requirements (except as noted in Section II) from the following
Colorado Construction Permits: 94WE609 (PSD), 97WE0189, 99WE0762 PSD and 07AD1100.
1.4 All conditions in this permit are enforceable by US Environmental Protection Agency, Colorado
Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless
otherwise specified. State-only enforceable conditions are: Permit Condition Number(s):
Section II - Conditions 1.13, 2.14 and 8.16 (Opacity) and Section V - Conditions 3.g (last
paragraph), 14 and 18 (as noted).
1.5 All information gathered pursuant to the requirements of this permit is subject to the
Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions
in Section V of this permit. 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: 1/1/2016
Last Revised: 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, PM10,
NOx and CO > 100 tons/year). Future modifications at this facility resulting in a significant net
emissions increase (see Colorado Regulation No. 3, Part D, Sections II.A.27 and 44) or a
modification which is major by itself(Potential to Emit ≥ 100 tons/year) for any pollutant listed
in Colorado Regulation 3, Part D, Section II.A.44 for which the area is in attainment or
attainment/maintenance may result in the application of the PSD review requirements.
3.2 This source is categorized as a NANSR major stationary source (Potential to Emit of NOx ≥100
tons/year). Future modifications at this facility resulting in a significant net emissions increase
(see Regulation No. 3, Part D, Sections II.A.27 and 44) for VOC or NOx or a modification which
is major by itself(Potential to Emit > 100 tons/year of either VOC or NOx) may result in the
application of the NANSR review requirements.
3.3 There are no other Operating Permits associated with this facility for purposes of determining
applicability of NANSR and PSD review regulations.
4. Accidental Release Prevention Program (112(r))
4.1 Based on the information provided by the applicant, this facility is not subject to the provisions
of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act).
5. Compliance Assurance Monitoring (CAM)
5.1 The following emission points at this facility use a control device to achieve compliance with an
emission limitation or standard to which they are subject and have pre-control emissions that
exceed or are equivalent to the major source threshold. They are therefore subject to the
provisions of the CAM program as set forth in 40 CFR Part 64, as adopted by reference in
Colorado Regulation No. 3, Part C, Section XIV:
Unit T004—Combustion Turbine
See Section II, Condition 2.9 for compliance assurance monitoring requirements.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: 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.
1002 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)
1004 008 General Electric Combustion Turbine,Model PG7241 April 2001 Turbine-Dry
(FA),Serial No.297457,rated at 1953 MMBtu/hr(turbine Low NOx
1,531 MMBtu/hr and duct burner 422 MMBtu/hr),Natural HRSG—
Gas Fired. Turbine May be Operated in Conjunction with a Selective
HRSG(combined cycle operation)Equipped with One(1) Catalytic
Vogt-NEM Natural Gas Fired Duct Burner. Reduction(SCR)
B001 001 Babcock and Wilcox,Model FM-1656,External 1969,modified Uncontrolled
Combustion Auxiliary Boiler, Serial No.NB22845,Rated September 1997 to
at 70.23 MMBtu/hr. Natural Gas Fired. burn only natural
gas
M001 006 One(1)Marley Cooling Water Tower,Model No.Cross- 1976 Drift Eliminators
Flow DF-664,Design Rate of 156,000 gpm and One(1)
Marley Service Water Tower,Model No.6-48-3-02,
Design Rate of 15,000 gpm.
M002 N/A Gasoline Storage Tank,500 gallons,aboveground 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 Ol 1 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: 1/1/2016
Last Revised: 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.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: 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: 1/1/2016
Last Revised: 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 lbs/MMBtu,on a 30-Day Rolling
Average
N/A 4.7 tons/yr Continuous Continuously
Monitoring
System
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: 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
For Each Duct Burner:
0.03 lbs/MMBtu,the average of three
(3)2-hr tests
N/A 39.4 tons/yr See Condition Recordkeeping, Monthly,Every
1.6 Calculation and Five(5)Years
Performance
Testing
PMio 1.7 9 lbs/hr 39.4 tons/yr See Condition Recordkeeping, Monthly,Every
1.7 Calculation and Five(5)Years
Performance
Testing
Natural Gas 1.8 N/A Simple Cycle N/A Recordkeeping Monthly
Usage and/or Combined
Cycle Without
Supplemental
Fuel:
12,507 MMscf/yr
Combined Cycle
With
Supplemental
Fuel:
16,090 MMscf/yr
Sulfur Content 1.9 N/A N/A N/A See Condition 1.9
of Natural Gas
Continuous 1.10 N/A N/A N/A See Condition 1.10
Emission
Monitoring
System
Requirements
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: 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 1.11 N/A N/A N/A As Required by Subject to
Provisions NSPS General NSPS General
Provisions Provisions
Performance 1.12 N/A N/A N/A EPA Reference See Condition
Test Methods 1.12
Requirements
Opacity-State 1.13 Not to Exceed 20% N/A Fuel Restriction Only Pipeline
Only Quality Natural
Gas is Used as
Fuel
Opacity 1.14 Not to Exceed 20%Except as N/A
Provided for in 1.15 Below
Opacity 1.15 For Certain Operational Activities- N/A
Not to Exceed 30%,for a Period or
Periods Aggregating More than Six
(6)Minutes in any 60 Consecutive
Minutes
NSPS Opacity 1.16 Not to Exceed 20%(6-minute N/A
Applies to Duct average),Except for One Six Minute
Burner Only Average Not to Exceed 27%Per Hour
Acid Rain 1.17 See Section III of this Permit Certification Annually
Requirements
1.1 These combustion turbines/HRSGs/duct burners are subject to the requirements of the
Prevention of Significant Deterioration (PSD)Program.
1.1.1 Best Available Control Technology (BACT) shall be applied for control of Nitrogen
Oxides (NOx), Carbon Monoxide (CO), Volatile Organic Compounds (VOC) and
Particulate Matter(PM and PM10). BACT has been determined as follows:
1.1.1.1 BACT for NOx has been determined to be Dry Low NOx (DLN)
Combustion Systems with emission limits as identified in Condition 1.2.1
(Colorado Construction Permit 94WE609 PSD, as modified under the
provisions of Section I, Condition 1.3). The DLN combustion systems
shall be operated and maintained in accordance with manufacturer's
recommendations and good engineering practices.
1.1.1.2 BACT for CO has been determined to be good combustion
practices/monitoring systems capable of meeting the emission limitations
in Condition 1.3.1 (Colorado Construction Permit 94WE609 PSD).
1.1.1.3 BACT for VOC has been determined to be good combustion
practices/monitoring systems capable of meeting the emission limitations
in Condition 1.5.1 (Colorado Construction Permit 94WE609 PSD).
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: 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 vurposes of combustion tuning and testing shall not
exceed 90 hours in any calendar year for turbines T002, T003 and T004
combined. Records of the number of hours each turbine undergoes
combustion tuning and testing shall be recorded and maintained and made
available to the Division upon request.
1.2.1.5 "Startup" means the setting in operation of any air pollution source for any
purpose. Setting in operation for 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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 11
unit overhaul or as part of routine maintenance operations. Combustion
tuning and testing can occur throughout the range of the operating
conditions.
Compliance with these NOx limitations shall be monitored using the continuous
emission monitoring system(CEMS) required by Condition 1.10, as follows:
1.2.1.8 Except as provided for in Condition 1.2.1.9, 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.
1.2.2 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: 1/1/2016
Last Revised: 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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit#97OPWE180 Page 13
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
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, 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 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, 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 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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 14
which combustion tuning and testing activities occur.
1.3.2 Carbon Monoxide (CO) emissions from each combustion turbine/HRSG/duct
burner shall not exceed 465.4 tons/yr(Colorado Construction Permit 94WE609 PSD,
as modified under the provisions of Section I, Condition 1.3). Compliance with this
requirement shall be monitored using the Continuous Emission Monitoring System
(CEMS) required by Condition 1.10. 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: 1/1/2016
Last Revised: 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 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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 16
correlation (VOC emissions vs. heat input) that has been approved by the Division
and programmed into the data acquisition and handling system (DAHS). The
equations used in the VOC correlation are included in Appendix G of this permit.
A twelve month rolling total of emissions will be maintained to monitor compliance
with the annual emission limitations. Each month a new twelve month total shall be
calculated using the previous twelve months data.
1.6 Particulate Matter(PM) emissions shall not exceed the following limitations:
1.6.1 Particulate Matter (PM) emissions from each combustion turbine shall not exceed
0.1 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 duct burner shall not exceed 0.03
lbs/MMBtu, average of three (3) 2-hr tests (Colorado Construction Permit 94WE609
PSD). In the absence of credible evidence to the contrary, compliance with the
particulate matter limitation is presumed since only pipeline quality natural gas is
permitted to be used as fuel in the duct burners.
The PM emission limits are not applicable during times of startup, shutdown and
malfunction (40 CFR Part 60 Subpart Da § 60.46Da(c), as adopted by reference in
Colorado Regulation No. 6, Part A).
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 17
1.6.4 Particulate Matter (PM) emissions from each combustion turbine/HRSG/duct
burner shall not exceed 39.4 tons/yr (Colorado Construction Permit 94WE609 PSD,
as modified under the provisions of Section I, Condition 1.3). Compliance with this
limitation shall be monitored as follows:
1.6.4.1 Monthly emissions of PM shall be calculated using the emission factors
identified in the table below in the following equation:
Emission Factor Source of Emission Factor
(1b/MIMBtu)
Unit PM I PM10
Unit 2—Simple Cycle 0.004 0.004 May 2,2014
Unit 2—Combined Cycle 0.002 0.002 March 28,2014
Unit 3—Simple Cycle 0.003 0.003 March 26,2014
Unit 3—Combined Cycle 0.002 0.002 March 27,2014
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 1.10. A twelve month rolling total of
emissions will be maintained to monitor compliance with the annual
emission limitation. Each month a new twelve month total shall be
calculated using the previous twelve months data.
1.6.4.2 Performance testing shall be conducted in accordance with the
requirements in Condition 1.12.
1.7 Particulate Matter less than 10 microns (PM10) emissions from each combustion
turbine/HRSG/duct burner shall not exceed 9 lbs/hr and 39.4 tons/yr (Colorado Construction
Permit 94WE609 PSD, as modified under the provisions of Section I, Condition 1.3).
Compliance with these limitations shall be monitored as follows:
1.7.1 Monthly emissions of PM to shall be calculated using the emission factors identified in
the table in Condition 1.6.4.1 in the following equation:
Tons/month=JEF(lbs/MMBtu)x monthly heat input to turbine(MMBtu/mo)1
2000 lbs/ton
The monthly heat input to the turbine/duct burner shall be determined using the data
acquisition and handling systems (DAHS) for the CEMS required by Condition 1.10.
A twelve month rolling total of emissions will be maintained to monitor compliance
with the annual emission limitations. Each month a new twelve month total shall be
calculated using the previous twelve months data. Compliance with the hourly
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 18
limitation shall be monitored by dividing the monthly emissions by the number of
hours operated each month.
1.7.2 Performance testing shall be conducted in accordance with the requirements in
Condition 1.12.
1.8 Natural Gas Consumption for each combustion turbine/HRSG/duct burner shall not exceed
the following limitations:
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.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit#97OPWE180 Page 19
1.11 These combustion turbines/HRSGs/duct burners are subject to 40 CFR Part 60, Subpart A -
General Provisions, as adopted by reference in Colorado Regulation No. 6, Part A. Specifically,
these units are subject to the following requirements:
1.11.1 No article, machine, equipment or process shall be used to conceal an emission which
would otherwise constitute a violation of an applicable standard. Such concealment
includes, but is not limited to, the use of gaseous diluents to achieve compliance with
an opacity standard or with a standard which is based on the concentration of a
pollutant in the gasses discharged to the atmosphere (Colorado Construction Permit
94WE609 PSD and 40 CFR Part 60 Subpart A § 60.12)
1.11.2 At all times, including periods of startup, shutdown, and malfunction owners and
operators shall to the extent practicable, maintain and operate any affected facility
including associated air pollution control equipment in a manner consistent with good
air pollution control practice for minimizing emissions. Determination of whether
acceptable operating and maintenance procedures are being used will be based on
information available to the Division which may include, but is not limited to
monitoring results, opacity observations, review of operating and maintenance
procedures, and inspection of the source (Colorado Construction Permit 94WE609
PSD and 40 CFR Subpart A § 60.11(d)).
1.12 The source shall conduct performance tests for each combustion turbine/HRSG/duct burner,
when operating in simple cycle mode and combined cycle mode with supplemental fuel every
five (5) years to monitor compliance with the PM and PMio emission limitations. This
performance test shall be conducted in accordance with the requirements of 40 CFR Part 60
Subpart A § 60.8 using EPA Test Methods 5 and 202.
Note that the previous performance tests for these units were completed as follows:
Unit Performance Test Date
Unit 2—Simple Cycle May 2,2014
Unit 2—Combined Cycle March 28,2014
Unit 3—Simple Cycle March 26,2014
Unit 3—Combined Cycle March 27,2014
The test protocol, test, and test report must be in accordance with the requirements of the APCD
Compliance Test Manual (https://www.colorado.gov/pacific/cdphe/inspections-and-
enforcement). A stack testing protocol shall be submitted for Division approval at least forty-five
(45) calendar days prior to any performance of the test required under this condition. No stack
test required herein shall be performed without prior approval of the protocol by the Division.
The Division reserves the right to witness the test. In order to facilitate the Division's ability to
make plans to witness the test, notice of the date(s) for the stack test shall be submitted to the
Division at least thirty (30) calendar days prior to the test. The Division may for good cause
shown, waive this thirty (30) day notice requirement. In instances when a scheduling conflict is
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 20
presented,the Division shall immediately contact the permittee in order to explore the possibility
of making modifications to the stack test schedule. The compliance test results shall be
submitted to the Division within forty-five (45) calendar days of the completion of the test unless
a longer period is approved by the Division.
1.13 State-only Requirement: No owner or operator may discharge, or cause the discharge into the
atmosphere of any particulate matter which is greater than 20% opacity (Colorado Regulation
No. 6, Part B, Section II.C.3). This opacity standard applies to each combustion
turbine/HRSG/duct burner. In the absence of credible evidence to the contrary, compliance
with the opacity limitation shall be presumed since only pipeline quality natural gas is permitted
to be used as fuel in the turbines and duct burners.
1.14 Except as provided for in Condition 1.15 below, no owner or operator of a source shall allow or
cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity
(Colorado Construction Permit 94WE609 PSD and Colorado Regulation No. 1, Section II.A.1).
This opacity standard applies to each combustion turbine/HRSG/duct burner. In the absence
of credible evidence to the contrary, compliance with the opacity limitation shall be presumed
since only pipeline quality natural gas is permitted to be used as fuel in the turbines and duct
burners.
1.15 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air
pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up,
process modifications, or adjustment or occasional cleaning of control equipment which is in
excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty
(60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). This opacity standard
applies to each combustion turbine/HRSG/duct burner. In the absence of credible evidence
to the contrary, compliance with the opacity limitation shall be presumed since only pipeline
quality natural gas is permitted to be used as fuel in the turbines and duct burners.
1.16 No owner or operator of a source shall cause to be discharged into the atmosphere from any
affected facility any gases which exhibit greater than 20 percent opacity (6-minute average),
except for one 6-minute period per hour of not more than 27 percent opacity ((40 CFR Part 60
Subpart Da § 60.42Da(b), as adopted by reference in Colorado Regulation No. 6, Part A). This
opacity standard applies to each duct burner. In the absence of credible evidence to the
contrary, compliance with the opacity limit shall be presumed since only pipeline quality natural
gas is permitted to be used as fuel for these units.
This opacity standard applies at all times except during periods of startup, shutdown and
malfunction (40 CFR Part 60 Subpart A § 60.11(c), as adopted by reference in Colorado
Regulation No. 6, Part A).
1.17 These units are subject to the Title IV Acid Rain Requirements. As specified in 40 CFR Part
72.72(b)(1)(viii), the acid rain permit requirements shall be a complete and segregable portion of
the Operating Permit. As such the requirements are found in Section III of this permit.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 21
2. T004—Combustion Turbine Capable of Simple or Combined Cycle Operation
Simple Cycle- Combustion Turbine Only
Combined Cycle(No Supplemental Fuel) - Combustion Turbine& Heat Recovery Steam
Generator(HRSG)with No Fuel Fired in Duct Burner
Combined Cycle (With Supplemental Fuel)—Combustion Turbine& Heat Recovery Steam
Generator(HRSG)with Fuel Fired in Duct Burner
Parameter Permit Limitations Compliance Monitoring
Condition Emission
Number Short Term Long Term Factor Method Interval
BACT 2.1 N/A N/A N/A See Condition 2.1
Requirements
PM 2.2 N/A 54 tons/yr 0.005 Recordkeeping Monthly
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 Ibs/MMBtu,the average of
three(3), 1-hr tests
Duct Burner:
0.03 Ibs/MilVIBtu,the average of
three(3),2-hr tests
PMIo N/A 54 tons/yr 0.005 Recordkeeping Monthly
Ibs/MMBtu and Calculation
VOC 2.3 N/A 33.1 tons/yr N/A Continuous Continuously
Monitoring
System
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 22
Parameter Permit Limitations Compliance Monitoring
Condition Emission
Number Short Term Long Term Factor Method Interval
SO2 2.4 N/A 4.7 tons/yr N/A Continuous Continuously
Monitoring
System
Combustion Turbine: N/A Fuel Restriction See Condition
150 ppmvd @ 15%O2 OR Use of 2.4
Fuel Which Contains Less than 0.8
Weight%Sulfur
Combustion Turbine:
0.35 lbs/MIVfBtu,on a 3-hour
rolling average
Duct Burner:
0.20 lbs/MMBtu on a 30-day
rolling average
NOx 2.5 Simple Cycle Mode N/A Continuous Continuously
9 ppmvd @ 15%O2 on a 24-hr Emission
rolling average,except as provided Monitoring
for below System
During Startup and Shutdown:
100 ppmvd @ 15%O2 on a 1-hr
average
During Combustion Tuning and
Testing(not to exceed 90 hrs/yr 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
N/A 199.1 tons/yr
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: 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
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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: 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
Compliance 2.9 N/A N/A N/A See Condition 2.9
Assurance
Monitoring
Requirements—
For Combined
Cycle Operation
Sulfur Content of 2.10 N/A N/A N/A See Condition 2.10.
Natural Gas
NSPS General 2.11 N/A N/A N/A As required by Subject to NSPS
Provisions NSPS General General
Provisions Provisions
Opacity 2.12 Not to Exceed 20%Except as N/A Fuel Restriction Only Pipeline
Provided for in 2.13 Quality Natural
Gas is Used as
Fuel
Opacity 2.13 For Certain Operational Activities- N/A
Not to Exceed 30%,for a Period or
Periods Aggregating More than Six
(6)Minutes in any 60 Consecutive
Minutes
State-Only 2.14 Not to Exceed 20% N/A
Opacity
NSPS Opacity — 2.15 Not to Exceed 20%(6-minute N/A
Applies to Duct average),Except for One Six
Burner Only Minute Average Not to Exceed
27%Per Hour
Acid Rain 2.16 See Section III of this Permit Certification Annually
Requirements
2.1 The combustion turbine/HRSG/duct burner is subject to the requirements of the Prevention of
Significant Deterioration (PSD) Program.
2.1.1 Best Available Control Technology (BACT) shall be applied for control of Nitrogen
Oxides (NOx), Carbon Monoxide (CO) and Particulate Matter Emissions (PM and
PM10). BACT has been determined as follows:
2.1.1.1 BACT for NOx has been determined to be Dry Low NOx combustion
system for the turbine and Selective Catalytic Reduction (SCR) for the
HRSG with the emission limits as identified in Condition 2.5.1 (Colorado
Construction Permit 99WE0762 PSD).
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit#97OPWE180 Page 25
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 PMKo emissions are subject to the following requirements:
2.2.1 Emissions of PM and PMto from the combustion turbine/HRSG/duct burner shall
not exceed 54 tons/yr (Colorado Construction Permit 99WE0762 PSD). Monthly
emissions from the combustion turbine/HRSG/duct burner shall be calculated by the
end of the subsequent month using the emission factors (EF) identified in the above
table (from performance test conducted May 10-12, 2001) in the following equation:
tons/month=(EF, lbs/MMBtu)x(Fuel Use,MMscf/mo)x heat content of gas(MMBtu/MMscf)
2000 lbs/ton
Monthly emissions shall be used in a twelve month rolling total to monitor
compliance with the annual limitations. Each month a new twelve month total shall
be calculated using the previous twelve months data.
2.2.2 Particulate Matter (PM) emissions from the combustion turbine shall not exceed 0.1
lbs/MMBtu, the average of three (3) 1-hr tests (Colorado Regulation No. 1, Section
III.A.1.c). In the absence of credible evidence to the contrary, compliance with the
particulate matter emission limitation is presumed since only pipeline quality natural
gas is permitted to be used as fuel in the turbine.
2.2.3 Particulate Matter (PM) emissions from the combustion turbine and duct burner
together shall not exceed 0.1 lbs/MMBtu, the average of three (3) 1-hr tests
(Colorado Regulation No. 1, Sections III.A.1.b,c and d). In the absence of credible
evidence to the contrary, compliance with the particulate matter emission limitation is
presumed since only pipeline quality natural gas is permitted by be used as fuel in the
turbine and duct burner.
Note that the numeric PM standards for combined cycle operation were determined
using the design heat input for the turbine (1,531 MMBtu/hr) and the duct burner
(each 422 MMBtu) in the following equation:
PE (turbine +duct burner)=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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 26
FI= fuel input in MMBtu/hr
2.2.4 Particulate Matter (PM) emissions from the duct burner shall not exceed 0.03
lbs/MMBtu, the average of three (3) 2-hr tests (Colorado Construction Permit
99MR0762 PSD). In the absence of credible evidence to the contrary, compliance
with the particulate matter limitations shall be presumed since only pipeline quality
natural gas is permitted to be used as fuel in the duct burner.
The PM emission limits are not applicable during times of startup, shutdown and
malfunction (40 CFR Part 60 Subpart Da § 60.46Da(c), as adopted by reference in
Colorado Regulation No. 6, Part A).
2.3 Volatile Organic Compound emissions from the combustion turbine/HRSG/duct burner shall
not exceed 33.1 tons/yr (Colorado Construction Permit 99WE0762 PSD). Compliance with the
VOC limitations shall be monitored using the VOC correlation (VOC emissions vs. heat input)
that has been approved by the Division and programmed into the data acquisition and handling
system (DAHS). The VOC correlation was approved by the Division on February 6, 2002, with
written approval provided in the Division's letter dated March 26, 2008 to the permittee. The
equations used in the VOC correlation are included in Appendix 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 The combustion turbine shall meet one of the following requirements:
2.4.2.1 Sulfur Dioxide (SO2) emissions shall not exceed 150 ppmvd at 15% O2
OR
2.4.2.2 No fuel, which contains sulfur in excess of 0.8 percent by weight, shall be
used in this combustion turbine (40 CFR Part 60 Subpart GG §§ 60.33(a)
& (b), as adopted by reference in Colorado Regulation No. 6, Part A).
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 27
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 in the turbine. The natural gas used as fuel shall meet the requirements in
Condition 2.10.
2.4.3 Sulfur Dioxide (SO2) emissions from the combustion turbine shall not exceed 0.35
lbs/MMBtu, on a 3-hr rolling average (Colorado Regulation No. 1, Section
VI.B.4.c.(ii) and VI.B.2). In the absence of credible evidence to the contrary,
compliance with the SO2 limitations is presumed since only pipeline quality natural
gas is permitted to be used as fuel in the turbine.
2.4.4 Sulfur Dioxide (SO2) emissions from the duct burner shall not exceed 0.20
lbs/MMBtu, on a 30-day rolling average (Colorado Construction Permit 99WE0762
PSD). In the absence of credible evidence to the contrary, compliance with the SO2
limitations is presumed since only pipeline quality natural gas is permitted to be used
as fuel in the duct burner.
2.5 Emissions of Nitrogen Oxides (NOx) shall not exceed the following limitations:
2.5.1 The BACT emission limits for the combustion turbine/HRSG/duct burner are as
follows (Colorado Construction Permit 99WE0762 PSD, as modified under the
provisions of Section I, Condition 1.3):
2.5.1.1 Except as provided for in Conditions 2.5.1.3 and 2.5.1.4 below, emissions
of NOx shall not exceed 9 ppmvd at 15 % O2, on a 24-hour average. This
standard applies when operating in simple cycle mode.
2.5.1.2 Except as provided for in Conditions 2.5.1.3 and 2.5.1.4 below, emissions
of NOx shall not exceed 4 ppmvd at 15 % O2, on a 24-hour average. This
standard applies when operating in combined cycle mode.
2.5.1.3 During periods of startup and shutdown emissions of NOx shall not
exceed 100 ppmvd at 15%O2, on a 1-hr average.
2.5.1.4 During periods of combustion tuning and testing emissions of NOx shall
not exceed 100 ppmvd at 15% O2, on a 1-hour average. Use of this NOx
emission limit for purposes of combustion tuning and testing shall not
exceed 90 hours in any calendar year for 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-
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 28
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.
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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWEI 80 Page 29
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 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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 30
not exceed 1,000 ppmvd at 15% O2, on a 1-hour average. In the event that
CO emissions exceed 1,000 ppmvd at 15% O2, it shall be considered a
violation if CO emissions exceed 2,060 lbs/hr and not a violation if
emissions are less than or equal to 2,060 lbs/hr. Use of this CO emission
limit for purposes of combustion tuning and testing shall not exceed 90
hours in any calendar year for all three turbines combined. Records of
the number of hours the turbine undergoes combustion tuning and testing
shall be recorded and maintained and made available to the Division upon
request.
2.6.1.5 "Startup" shall have the same definition as provided for in Condition
1.2.1.5.
2.6.1.6 "Shutdown" shall have the same definition as provided for in Condition
1.2.1.6.
2.6.1.7 "Combustion Tuning and Testing" shall have the same definition as
provided for in Condition 1.2.1.7 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, 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 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, 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 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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit#97OPWE180 Page 31
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.
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).
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 32
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
(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 2.5.2 and 2.6.2 to monitor compliance with the annual
NOx and CO emission limitations.
2.9 The Compliance Assurance Monitoring (CAM) requirements in 40 CFR Part 64, as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV, apply to when operating in
combined cycle mode, with respect to the NOx limitations identified in Conditions 2.5.1.2 as
follows:
2.9.1 The permittee shall monitor the exhaust gas NOx concentration (ppmvd at 15% O2)
using the continuous emission monitoring system required by Condition 2.8. The
NOx concentrations will be reduced to hourly averages and used to calculate 24-hour
averages. Exceedances, for purposes of CAM, shall be any 24-hour period that the
NOx concentration exceeds the limit identified in Condition 2.5.1.2. Exceedances of
these limitations shall be reported as required by Section II, Condition 5.5 and
Section V, Conditions 21 and 22.d of this permit.
2.9.2 Operation of Approved Monitoring
2.9.2.1 At all times, the owner or operator shall maintain the monitoring,
including but not limited to, maintaining necessary parts for routine
repairs of the monitoring equipment(40 CFR Part 64 § 64.7(b), as adopted
by reference in Colorado Regulation No. 3, Part C, Section XIV).
2.9.2.2 Except for, as applicable, monitoring malfunctions, associated repairs, and
required quality assurance or control activities (including, as applicable,
calibration checks and required zero and span adjustments), the owner or
operator shall conduct all monitoring in continuous operation (or shall
collect data at all required intervals) at all times that the pollutant-specific
emissions unit is operating. Data recorded during monitoring
malfunctions, associated repairs, and required quality assurance or control
activities shall not be used for purposes of these CAM requirements,
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 33
including data averages and calculations, or fulfilling a minimum data
availability requirement, if applicable. The owner or operator shall use all
the data collected during all other periods in assessing the operation of the
control device and associated control system. A monitoring malfunction
is any sudden, infrequent, not reasonably preventable failure of the
monitoring to provide valid data. Monitoring failures that are caused in
part by poor maintenance or careless operation are not malfunctions (40
CFR Part 64 § 64.7(c), as adopted by reference in Colorado Regulation
No. 3, Part C, Section XIV).
2.9.2.3 Response to excursions or exceedances
a. Upon detecting an excursion or exceedance, the owner or operator
shall restore operation of the pollutant-specific emissions unit
(including the control device and associated capture system) to its
normal or usual manner of operation as expeditiously as
practicable in accordance with good air pollution control practices
for minimizing emissions. The response shall include minimizing
the period of any startup, shutdown or malfunction and taking any
necessary corrective actions to restore normal operation and
prevent the likely recurrence of the cause of an excursion or
exceedance (other than those caused by excused startup or
shutdown conditions). Such actions may include initial inspection
and evaluation, recording that operations returned to normal
without operator action (such as through response by a
computerized distribution control system), or any necessary
follow-up actions to return operation to within the indicator range,
designated condition, or below the applicable emission limitation
or standard, as applicable (40 CFR Part 64 § 64.7(d)(1), as adopted
by reference in Colorado Regulation No. 3, Part C, Section XIV).
b. Determination of whether the owner of operator has used
acceptable procedures in response to an excursion or exceedance
will be based on information available, which may include but is
not limited to, monitoring results, review of operation and
maintenance procedures and records, and inspection of the control
device, associated capture system, and the process (40 CFR Part 64
§ 64.7(d)(2), as adopted by reference in Colorado Regulation No.
3, Part C, Section XIV).
2.9.2.4 After approval of the monitoring required under the CAM requirements, if
the owner or operator identifies a failure to achieve compliance with an
emission limitation or standard for which the approved monitoring did not
provide an indication of an excursion or exceedance while providing valid
data, or the results of compliance or performance testing document a need
to modify the existing indicator ranges or designated conditions, the owner
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 34
or operator shall promptly notify the Division and, if necessary submit a
proposed modification for this permit to address the necessary monitoring
changes. Such a modification may include, but is not limited to,
reestablishing indicator ranges or designated conditions, modifying the
frequency of conducting monitoring and collecting data, or the monitoring
of additional parameters (40 CFR Part 64 § 64.7(e), as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV).
2.9.3 Quality Improvement Plan (QIP) Requirements
2.9.3.1 Based on the results of a determination made under the provisions of
Condition 2.9.2.3.b, the Division may require the owner or operator to
develop and implement a QIP (40 CFR Part 64 § 64.8(a), as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV).
2.9.3.2 The owner or operator shall maintain a written QIP, if required, and have
it available for inspection (40 CFR Part 64 § 64.8(b)(1), as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV).
2.9.3.3 The QIP initially shall include procedures for evaluating the control
performance problems and, based on the results of the evaluation
procedures, the owner or operator shall modify the plan to include
procedures for conducting one or more of the following actions, as
appropriate:
a. Improved preventative maintenance practices (40 CFR Part 64 §
64.8(b)(2)(i), as adopted by reference in Colorado Regulation No.
3, Part C, Section XIV).
b. Process operation changes (40 CFR Part 64 § 64.8(b)(2)(ii), as
adopted by reference in Colorado Regulation No. 3, Part C,
Section XIV).
c. Appropriate improvements to control methods (40 CFR Part 64 §
64.8(b)(2)(iii), as adopted by reference in Colorado Regulation No.
3, Part C, Section XIV).
d. Other steps appropriate to correct control performance (40 CFR
Part 64 § 64.8(b)(2)(iv), as adopted by reference in Colorado
Regulation No. 3, Part C, Section XIV).
e. More frequent or improved monitoring (only in conjunction with
one or more steps under Conditions 2.9.3.3.a through d above) (40
CFR Part 64 § 64.8(b)(2)(v), as adopted by reference in Colorado
Regulation No. 3, Part C, Section XIV).
2.9.3.4 If a QIP is required, the owner or operator shall develop and implement a
QIP as expeditiously as practicable and shall notify the Division if the
period for completing the improvements contained in the QIP exceeds 180
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit#97OPWE180 Page 35
days from the date on which the need to implement the QIP was
determined (40 CFR Part 64 § 64.8(c), as adopted by reference in
Colorado Regulation No. 3, Part C, Section XIV).
2.9.3.5 Following implementation of a QIP, upon any subsequent determination
pursuant to Condition 2.9.2.3.b, the Division or the U.S. EPA may require
that an owner or operator make reasonable changes to the QIP if the QIP is
found to have:
a. Failed to address the cause of the control device performance
problems (40 CFR Part 64 § 64.8(d)(1), as adopted by reference in
Colorado Regulation No. 3, Part C, Section XIV); or
b. Failed to provide adequate procedures for correcting control device
performance problems as expeditiously as practicable in
accordance with good air pollution control practices for
minimizing emissions (40 CFR Part 64 § 64.8(d)(2), as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV).
2.9.3.6 Implementation of a QIP shall not excuse the owner or operator of a
source from compliance with any existing emission limitation or standard,
or any existing monitoring, testing, reporting or recordkeeping
requirement that may apply under federal, state, or local law, or any other
applicable requirements under the federal clean air act (40 CFR Part 64 §
64.8(e), as adopted by reference in Colorado Regulation No. 3, Part C,
Section XIV).
2.9.4 Reporting and Recordkeeping Requirements
2.9.4.1 Reporting Requirements: The reports required by Section V, Condition
22.d, shall contain the information specified in Appendix B of the permit
and the following information, as applicable:
a. Summary information on the number, duration and cause
(including unknown cause, if applicable), for monitor downtime
incidents (other than, downtime associated with zero and span or
other daily calibration checks, if applicable) ((40 CFR Part 64 §
64.9(a)(2)(ii), as adopted by reference in Colorado Regulation No.
3, Part C, Section XIV); and
b. The owner or operator shall submit, if necessary, a description of
the actions taken to implement a QIP during the reporting period as
specified in Condition 2.9.3 of this permit. Upon completion of a
QIP, the owner or operator shall include in the next summary
report documentation that the implementation of the plan has been
completed and reduced the likelihood of similar levels of
excursions or exceedances occurring (40 CFR Part 64 §
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 36
64.9(a)(2)(iii), as adopted by reference in Colorado Regulation No.
3, Part C, Section XIV).
2.9.4.2 General Recordkeeping Requirements: In addition to the recordkeeping
requirements in Section V, Condition 22.a through c.
a. The owner or operator shall maintain records of any written QIP
required pursuant to Condition 2.9.3 and any activities undertaken
to implement a QIP, and any supporting information required to be
maintained under these CAM requirements (such as data used to
document the adequacy of monitoring, or records of monitoring
maintenance or corrective actions) (40 CFR Part 64 § 64.9(b)(1),
as adopted by reference in Colorado Regulation No. 3, Part C,
Section XIV).
b. Instead of paper records, the owner or operator may maintain
records on alternative media, such as microfilm, computer files,
magnetic tape disks, or microfiche, provided that the use of such
alternative media allows for expeditious inspection and review,
and does not conflict with other applicable recordkeeping
requirements (40 CFR Part 64 § 64.9(b)(2), as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV).
2.9.5 Savings Provisions
2.9.5.1 Nothing in these CAM requirements shall excuse the owner or operator of
a source from compliance with any existing emission limitation or
standard, or any existing monitoring, testing, reporting or recordkeeping
requirement that may apply under federal, state, or local law, or any other
applicable requirements under the federal clean air act. These CAM
requirements shall not be used to justify the approval of monitoring less
stringent than the monitoring which is required under separate legal
authority and are not intended to establish minimum requirements for the
purposes of determining the monitoring to be imposed under separate
authority under the federal clean air act, including monitoring in permits
issued pursuant to title I of the federal clean air act. The purpose of the
CAM requirements is to require, as part of the issuance of this Title V
operating permit, improved or new monitoring at those emissions units
where monitoring requirements do not exist or are inadequate to meet the
requirements of CAM (40 CFR Part 64 § 64.10(a)(1), as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV).
2.9.5.2 Nothing in these CAM requirements shall restrict or abrogate the authority
of the U.S. EPA or the Division to impose additional or more stringent
monitoring, recordkeeping,testing or reporting requirements on any owner
or operator of a source under any provision of the federal clean air act,
including but not limited to sections 114(a)(1) and 504(b), or state law, as
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 37
applicable (40 CFR Part 64 § 64.10(a)(2), as adopted by reference in
Colorado Regulation No. 3, Part C, Section XIV).
2.9.5.3 Nothing in these CAM requirements shall restrict or abrogate the authority
of the U.S. EPA or the Division to take any enforcement action under the
federal clean air act for any violation of an applicable requirement or of
any person to take action under section 304 of the federal clean air act (40
CFR Part 64 § 64.10(a)(2), as adopted by reference in Colorado
Regulation No. 3, Part C, Section XIV).
2.10 The permittee shall maintain records demonstrating that the natural gas burned has a total sulfur
content less than 0.5 grains/100 SCF. Natural gas that meets this sulfur limitation is considered
pipeline quality natural gas as defined in 40 CFR Part 72. The demonstration shall be made
using any of the methods identified in 40 CFR Part 75 Appendix D, Section 2.3.1.4.(a). These
records shall be made available to the Division upon request.
2.11 These combustion turbine/HRSG/duct burner is subject to 40 CFR Part 60, Subpart A -
General Provisions, as adopted by reference in Colorado Regulation No. 6, Part A. Specifically,
these units are subject to the following requirements:
2.11.1 No article, machine, equipment or process shall be used to conceal an emission which
would otherwise constitute a violation of an applicable standard. Such concealment
includes, but is not limited to, the use of gaseous diluents to achieve compliance with
an opacity standard or with a standard which is based on the concentration of a
pollutant in the gasses discharged to the atmosphere. (40 CFR Part 60 Subpart A §
60.12, as adopted in Colorado Regulation No. 6, Part A)
2.11.2 At all times, including periods of startup, shutdown, and malfunction, owners and
operators shall to the extent practicable, maintain and operate any affected facility
including associated air pollution control equipment in a manner consistent with good
air pollution control practice for minimizing emissions. Determination of whether
acceptable operating and maintenance procedures are being used will be based on
information available to the Division which may include, but is not limited to
monitoring results, opacity observations, review of operating and maintenance
procedures, and inspection of the source (40 CFR Subpart A § 60.11(d), as adopted
by reference in Colorado Regulation N. 6, Part A).
2.12 Except as provided for in Condition 2.13 below, no owner or operator of a source shall allow or
cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity
(Colorado Construction Permit 99WE0762 PSD and Colorado Regulation No. 1, Section II.A.1).
This opacity standard applies to the combustion turbine/HRSG/duct burner. In the absence of
credible evidence to the contrary, compliance with the 20%opacity limit shall be presumed since
only pipeline quality natural gas is permitted to be used as fuel in the turbine and duct burner.
2.13 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air
pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up,
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 38
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.
2.14 State-Only Requirement: No owner or operator may discharge, or cause the discharge into the
atmosphere of any particulate matter which is greater than 20% opacity (Colorado Regulation
No. 6, Part B, Section II.C.3). This opacity standard applies to the combustion
turbine/HRSG/duct burner. In the absence of credible evidence to the contrary, compliance
with the 20% opacity requirement is presumed since only pipeline quality natural gas is
permitted to be used as fuel in the turbine and duct burner.
This opacity standard applies at all times except during periods of startup, shutdown and
malfunction (40 CFR Part 60 Subpart A § 60.11(c), as adopted by reference in Colorado
Regulation No. 6, Part B, Section I.A).
2.15 No owner or operator of a source shall cause to be discharged into the atmosphere from any
affected facility any gases which exhibit greater than 20 percent opacity (6-minute average),
except for one 6-minute period per hour of not more than 27 percent opacity ((40 CFR Part 60
Subpart Da § 60.42Da(b), as adopted by reference in Colorado Regulation No. 6, Part A and
Colorado Construction Permit 99WE0762 PSD). This opacity standard applies to the duct
burner. In the absence of credible evidence to the contrary, compliance with the opacity limit
shall be presumed since only pipeline quality natural gas is permitted to be used as fuel for the
duct burner.
This opacity standard applies at all times except during periods of startup, shutdown and
malfunction (40 CFR Part 60 Subpart A § 60.11(c), as adopted by reference in Colorado
Regulation No. 6, Part A).
2.16 This unit is subject to the Title IV Acid Rain Requirements. As specified in 40 CFR Part
72.72(b)(1)(viii), the acid rain permit requirements shall be complete and segregable portion of
the Operating Permit. As such the requirements are found in Section III of this permit.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 39
3. B001 -Auxiliary Boiler
Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
NOx 3.1 N/A 32.6 tons/yr 100 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 Ibs/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
Periods Aggregating More than as Fuel
Six(6)Minutes in Any Sixty
Consecutive Minutes
3.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) shall not exceed the above
limitations (as provided for under the provisions of Section I, condition 1.3, with as requested on
the APEN submitted 4/23/99). Monthly emissions shall be calculated by the end of the
subsequent month using the above emission factors (EPA's Compilation of Emission Factors,
dated March 1998, Section 1.4) in the following equation:
tons/month= F EF (lbs/MMscf) x monthly fuel usage (MMscf/month)1
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.
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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 40
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.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 41
4. M001 - Cooling Water and Service Water Towers
Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
PM 4.1 N/A 14.9 tons/yr See Condition 4.1 Recordkeeping Monthly
PMio N/A 14.9 tons/yr and Calculation
VOC N/A 2.4 tons/yr 0.0527 lbs/mmgal(as
CHC13)
Water Circulated 4.2 N/A 89,878 N/A Recordkeeping Monthly
mmgal/yr
Total Solids 4.3 N/A N/A N/A Laboratory Semi-
Concentration Analysis Annually
Opacity 4.4 Not to Exceed 20% N/A See Condition 4.4
4.1 Particulate Matter (PM and 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=PM,()(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=CHCl3(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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 42
summed together and used in a twelve month rolling total to monitor compliance with the annual
limitation. Each month a new twelve month total shall be calculated using the previous twelve
months data.
4.3 Samples of water circulated from each tower shall be taken and analyzed semi-annually to
determine the total solids concentration. The total solids concentration shall be used to calculate
particulate matter emissions as required by Condition 4.1. A copy of the procedures used to
obtain and to analyze samples shall be maintained and made available to the Division upon
request.
4.4 Opacity of emissions from the cooling water tower shall not exceed 20% (Colorado Regulation
No. 1, Section II.A.1). In the absence of credible evidence to the contrary, compliance with the
opacity standard shall be presumed, provided the drift eliminators on the tower are operated and
maintained in accordance with the manufacturers' recommendations and good engineering
practices.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 43
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;
5.1.7 Flow rate of pipe line quality natural gas;
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: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 44
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: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 45
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: The permittee shall ensure that all continuous emission monitoring
systems required are in operation and monitoring unit emissions at all times except
for monitoring system breakdowns, repairs, calibration checks and zero and span
adjustments required under 40 CFR Part 60 Subpart A § 60.13(d) (40 CFR Part 60
Subpart A § 60.13(e)).
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 shall be maintained of all measurements, including continuous monitoring
system, monitoring device, and performance testing measurements; all continuous
monitoring system performance evaluations; all continuous monitoring system or
monitoring device calibration checks; adjustments and maintenance performed on
these systems or devices; and all other information required by applicable portions of
40 CFR Part 75 recorded in a permanent form suitable for inspection.
5.3.6 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).
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 46
5.4 Data Replacement Requirements
For periods when quality assured data is not available from the continuous emission monitoring
systems the data replacement procedures in 40 CFR Part 75 Subpart D shall be used for
determining the total (annual) emissions. Although carbon monoxide emissions are not
specifically referenced in the Subpart D procedures, the CEM data acquisition system will be
programmed to substitute carbon monoxide emissions using the same procedures specified for
oxides of nitrogen (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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 47
form shall be submitted for each pollutant monitored at each affected facility. (§
60.7(d))
If the total duration of excess emissions for the reporting period is less than 1 percent
of the total operating time for the reporting period and CMS downtime for the
reporting period is less than 5 percent of the total operating time for the reporting
period, only the summary report form shall be submitted and the excess emission
report described in Condition 5.5.1 need not be submitted unless requested by the
Division. (§ 60.7(d)(1)).
If the total duration of excess emissions for the reporting period is 1 percent or greater
of the total operating time for the reporting period or the total CMS downtime for the
reporting period is 5 percent or greater of the total operating time for the reporting
period, the summary report form and the excess emission report described in
Condition 5.5.1 shall both be submitted. (§ 60.7(d)(2))
5.6 Specific Provisions for NSPS Subpart KKKK
The following requirements apply to Turbines 5 and 6 only.
5.6.1 As specified in 40 CFR Part 60 Subpart KKKK § 60.4345(a), if a Part 75 NOx CEMS
is used, the RATA shall be performed on a lb/MMBtu basis.
5.6.2 As specified in 40 CFR Part 60 Subpart KKKK § 60.4350(d) and approved by the
Division, only quality assured data from the CEMS shall be used to identified excess
emissions. Periods where the missing data substitution procedures in Subpart D of
Part 75 are applied are to be reported as monitor downtime in the excess emission
reports specified in Condition 5.5.
5.6.3 For the purpose of reports required under Condition 5.5, periods of excess emissions
and monitor downtime that must be reported are defined as follows:
5.6.3.1 Excess emissions is any unit operating period in which the 4-hour rolling
average NOx emission rate exceeds the applicable emission limit in
§60.4320. For the purposes of this subpart, a "4-hour rolling average
NOxe mission rate" is the arithmetic average of the average NOx emission
rate in ppm or ng/J (lb/MWh) measured by the continuous emission
monitoring equipment for a given hour and the three unit operating hour
average NOx emission rates immediately preceding that unit operating
hour. Calculate the rolling average if a valid NOx mission rate is obtained
for at least 3 of the 4 hours. (40 CFR Part 60 Subpart KKKK §
60.4380(b)(1))
5.6.3.2 A period of monitor downtime is any unit operating hour in which the data
for any of the following parameters are either missing or invalid: NOx
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 48
concentration, CO2 or O2 concentration, fuel flow rate, steam flow rate,
steam temperature, steam pressure, or megawatts. The steam flow rate,
steam temperature, and steam pressure are only required if you will use
this information for compliance purposes. (40 CFR Part 60 Subpart
KKKK § 60.4380(b)(2))
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. (40 CFR Part 60 Subpart KKKK §
60.4380(b)(2))
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 49
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 B,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 [January 1, 2016], 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? (sC 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 6.1.7 through 6.1.10).
(§ 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: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 50
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(j))
When do I have to comply with this subpart? (sC 63.11113)
6.1.4 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 (40 CFR Part 63
Subpart CCCCCC § 63.11113(a)(1)).
What are my general duties to minimize emissions? ('63.11115)
6.1.5 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))
6.1.6 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 6.1.8, 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. (5C
63.11116)
6.1.7 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)):
6.1.7.1 Minimize gasoline spills;
6.1.7.2 Clean up spills as expeditiously as practicable;
6.1.7.3 Cover all open gasoline containers and all gasoline storage tank fill-pipes
with a gasketed seal when not in use;
6.1.7.4 Minimize gasoline sent to open waste collection systems that collect and
transport gasoline to reclamation and recycling devices, such as oil/water
separators;
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 51
6.1.8 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.
6.1.9 You must comply with the requirements of this subpart by the applicable date
specified in Condition 6.1.4. (40 CFR Part 63 Subpart CCCCCC § 63.11116(c)).
6.1.10 Portable gasoline containers that meet the requirements of 40 CFR part 59, subpart F,
are considered acceptable for compliance with Condition 6.1.7.3. (§ 63.11116(d))
What are my recordkeeping requirements? ('63.11125)
6.1.11 Each owner or operator of an affected source under this subpart shall keep records as
specified below. (§ 63.11125(d))
6.1.11.1 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))
6.1.11.2 Records of actions taken during periods of malfunction to minimize
emissions in accordance with §63.11115(a) (Condition 6.1.5), 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? (5C 63.11125)
6.1.12 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:
6.1.12.1 Prohibited activities in § 63.4(a).
6.1.12.2 Circumvention in § 63.4(b).
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 52
7. M002—Cold Cleaner Solvent Vats
Parameter Permit Limitations Compliance Emission Monitoring
Condition Factor
Number Short Term Long Term Method Interval
Work Practice 7.1 N/A N/A N/A Internal Audit Annually
Standards
Transfer and 7.2 N/A N/A N/A Certification Annually
Storage of
Waste/Used
Solvents
Note that these emission units are exempt from the APEN reporting requirements in Regulation No. 3, Part A and the construction
permit requirements in Regulation No. 3, Part B,as long as actual, uncontrolled emissions do not exceed the APEN de minimis level
(see Regulation No.3,Part B,Section II.D.1.a).
7.1 Operation of the cold cleaner solvent vats shall meet the standards defined in Colorado
Regulation 7, Section X.B. Compliance shall be monitored by following the work practices
defined in Public Service Company's Policy Manual regarding operation, maintenance and
design of the cold cleaner solvent vats. The Policy Manual shall include, at a minimum the
requirements defined in Colorado Regulation 7, Section X.B and shall be available to the
inspector upon request. Audits of the vat operations and/or the policy manual shall be performed
annually to ensure that operations are performed within the requirements of the policy manual
and that the policy manual incorporates the requirements of Regulation 7, Section X.B. Audit
reports are to be maintained and made available to the Division upon request.
7.2 The transfer and storage of waste and used solvents from the cold cleaner solvent vats are subject
to the following requirements (Colorado Regulation No. 7, Section X.A.3 and 4):
7.2.1 In any disposal or transfer of waste or used solvent, at least 80 percent by weight of
the solvent/waste liquid shall be retained (i.e., no more than 20 percent of the liquid
solvent/solute mixture shall evaporate or otherwise be lost during transfers).
7.2.2 Waste or used solvents shall be stored in closed containers unless otherwise required
by law.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 53
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 Calculation
T006:
0.0001 lb/MMBtu
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 54
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 Restriction Only Pipeline
0.1 lb/MMBtu,the average of three Quality
(3) 1-hr tests Natural Gas is
Used as Fuel
N/A 8.9 tons/yr 1005: Recordkeeping Monthly
0.004 Ib/MMBtu and Calculation
T006:
0.003 lb/MMBtu
PMio 8.7 N/A 8.9 tons/yr T005: Recordkeeping Monthly
0.004 lb/MMBtu and Calculation
T006:
0.003 lb/MMBtu
Natural Gas 8.8 N/A 2,178 MMscf/yr N/A Recordkeeping Monthly
Usage
Sulfur Content 8.9 N/A N/A N/A See Condition 8.9
of Natural Gas
Continuous 8.10 N/A N/A N/A See Condition 8.10
Emission
Monitoring
System
Requirements
NSPS Subpart 8.11 N/A N/A N/A See Condition 8.11
KKKK General
Requirements
NSPS General 8.12 N/A N/A N/A As Required by Subject to
Provisions - NSPS General NSPS General
Provisions Provisions
NOx Emissions 8.13 N/A N/A N/A See Condition 8.13
from
Insignificant
Activities
Opacity 8.14 Not to Exceed 20%Except as N/A Fuel Restriction Only Pipeline
Provided for in 8.15 Below Quality
Opacity 8.15 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 8.16 Not to Exceed 20% N/A
Only
Acid Rain 8.17 See Section III of this Permit Certification Annually
Requirements
Restrictions on 8.18 See Condition 8.18 N/A Certification Annually
Relaxing
Emission
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 55
Parameter Permit Limitations Compliance Monitoring
Condition Short Term Long Term Emission Factor Method Interval
Number
Limitations
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.
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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 56
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:
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 valid CEMS concentration (ppm) data points, including startup,
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 57
shutdown and malfunction 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.
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. (40 CFR Part 60 Subpart KKKK § 60.4350(b))
8.2.2.7 For simple cycle units without heat recovery, use the calculated hourly
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). (40
CFR Part 60 Subpart KKKK § 60.4350(b))
8.2.2.8 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. Further provisions regarding reporting excess emissions are
provided for in Condition 5.6.
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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 58
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.
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 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. (40 CFR Part 60 Subpart KKKK § 60.4330(a)(2)) In the
absence of credible evidence to the contrary, compliance with the fuel gas sulfur limit
is presumed since only pipeline quality natural gas is used as fuel in these turbines.
The natural gas used as fuel shall meet the requirements in Condition 8.9.
8.4.2 Annual Sulfur Dioxide (SO2) emissions from both turbines together shall not
exceed the above limitations (Colorado Construction Permit 07WE1100, as modified
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 59
under the provisions of Section I, Condition 1.3 to remove the monthly limitations).
Compliance with the annual SO2 emission limitations shall be monitored using the
monitoring method specified in 40 CFR Part 75 Appendix D.
Monthly emissions from each turbine shall be summed together and used in a twelve
month rolling total to monitor compliance with the annual limitations. Each month a
new twelve month total shall be calculated using the previous twelve months data.
8.5 Annual VOC emissions from both turbines together shall not exceed the above limitations
(Colorado Construction Permit 07WE1100, as modified under the provisions of Section I,
Condition 1.3 to remove the monthly limitations). Monthly emissions from each turbine shall be
calculated by the end of the subsequent month using the emission factors in the above table
(from performance tests conducted May 20 & 21, 2009) and the heat input for the month as
recorded on the data acquisition and handling system (DAHS) for the continuous emission
monitoring system (required by Condition 8.10) in the following equation:
tons/mo=(EF,lbs/MMBtu)x heat input(MNIBtu/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). 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 PMto emissions from both turbines together shall not exceed the above limitations
(Colorado Construction Permit 07WE1100, as modified under the provisions of Section I,
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 60
Condition 1.3 to remove the monthly limitations). Monthly emissions from each turbine shall be
calculated by the end of the subsequent month using the emission factors in the above table
(from performance tests conducted May 20 & 21, 2009) and the heat input for the month as
recorded on the data acquisition and handling system (DAHS) for the continuous emission
monitoring system (required by Condition 8.10) in the equation in Condition 8.5. Monthly
emissions from each turbine shall be summed together and used in a twelve month rolling total to
monitor compliance with the annual limitations. Each month a new twelve month total shall be
calculated using the previous twelve months data.
8.8 Natural gas consumption for both turbines together shall not exceed the above limitations
(Colorado Construction Permit 07WE1100, as modified under the provisions of Section I,
Condition 1.3 to remove the monthly limitations). The natural gas consumption for each
combustion turbine shall be monitored using the data acquisition and handling systems (DAHS)
for the continuous emission monitoring system (CEMS) required by Condition 8.10. Monthly
natural gas fuel consumption for each turbine shall be summed together and used in a rolling
twelve month total to monitor compliance with the annual limitation. Each month new twelve
month rolling total shall be calculated using the previous twelve months data for that fuel.
8.9 The permittee shall maintain records demonstrating that the natural gas burned has a total sulfur
content less than 0.5 grains/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 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))
8.12 Each turbine is subject to the NSPS Subpart A, General Provisions requirements (Colorado
Regulation No. 6, Part A, Federal 40 CFR 60.1 through 60.19). Specifically, these units are
subject to the following:
8.12.1 No article, machine, equipment or process shall be used to conceal an emission which
would otherwise constitute a violation of an applicable standard. Such concealment
includes, but is not limited to, the use of gaseous diluents to achieve compliance with
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 61
an opacity standard or with a standard which is based on the concentration of a
pollutant in the gasses discharged to the atmosphere. (40 CFR § 60.12)
8.12.2 At all times, including periods of startup, shutdown, and malfunction, owners and
operators shall, to the extent practicable, maintain and operate any affected facility
including associated air pollution control equipment in a manner consistent with good
air pollution control practice for minimizing emissions. Determination of whether
acceptable operating and maintenance procedures are being used will be based on
information available to the Administrator which may include, but is not limited to,
monitoring results, opacity observations, review of operating and maintenance
procedures, and inspection of the source. (40 CFR § 60.11(d)).
8.13 NOx emissions from all insignificant activities associated with these turbines shall be included in
monitoring compliance with the annual NOx emission limitation in Condition 8.2.3 (Colorado
Construction Permit 07WE1100). The permittee shall track emissions from all NOx emitting
insignificant activities associated with these turbines on a monthly basis and include those
emissions in the annual emission calculations specified in Condition 8.2.3. This information
shall be kept on site and made available to the Division upon request. For the purposes of this
condition, insignificant activities shall be defined as any activity or equipment, which emits any
amount but does not require an Air Pollution Emission Notice (APEN).
Based on the information available as of permit issuance [January 1, 2011] there are no
insignificant activities associated with turbines 5 and 6 that are a source of NOx emissions.
8.14 Except as provided for in Condition 8.15 below, no owner or operator of a source shall allow or
cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity
(Colorado Construction Permit 07WE1100 and Colorado Regulation No. 1, Section II.A.1). This
opacity standard applies to each combustion turbine. In the absence of credible evidence to the
contrary, compliance with the 20% opacity limit shall be presumed since only pipeline quality
natural gas is permitted to be used as fuel in the turbines.
8.15 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air
pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up,
process modifications, or adjustment or occasional cleaning of control equipment which is in
excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty
(60) consecutive minutes (Colorado Construction Permit 07WE1100 and Colorado Regulation
No. 1, Section II.A.4). This opacity standard applies to each combustion turbine. In the
absence of credible evidence to the contrary, compliance with the 30% opacity limit shall be
presumed since only pipeline quality natural gas is permitted to be used as fuel in the turbines.
8.16 State-Only Requirement: No owner or operator may discharge, or cause the discharge into the
atmosphere of any particulate matter which is greater than 20% opacity (Colorado Regulation
No. 6, Part B, Section II.C.3). This opacity standard applies to each combustion turbine. In the
absence of credible evidence to the contrary, compliance with the 20% opacity requirement is
presumed since only pipeline quality natural gas is permitted to be used as fuel in the turbines.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 62
This opacity standard applies at all times except during periods of startup, shutdown and
malfunction (40 CFR Part 60 Subpart A § 60.11(c), as adopted by reference in Colorado
Regulation No. 6, Part B, Section I.A).
8.17 This unit is subject to the Title IV Acid Rain Requirements. As specified in 40 CFR Part
72.72(b)(1)(viii), the acid rain permit requirements shall be complete and segregable portion of
the Operating Permit. As such the requirements are found in Section III of this permit.
8.18 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 8.18, 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:
Pollutant Program Emissions(tons/yr) Comment/Explanation
Threshold Current Permit Limit
PM PSD 25 8.9
PM,a PSD 15 8.9
NOx NANSR 40 39.9
NOx PSD 40 39.9
CO PSD 100 20
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 63
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/MMBtu N/A Fuel Restriction Only Diesel
Fuel is Used
as Fuel
Opacity 9.3 Not to Exceed 20%Except as N/A EPA Method 9 See Condition
Provided for Below 9.3
For Startup—Not to Exceed
30%,for a Period or Periods
Aggregating More than Six(6)
Minutes in any 60 Consecutive
Minutes
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 B,Section II.D.1.a).
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). 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.
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 [January 1, 2016], 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.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 64
When do I have to comply with this subpart(§60.6595)
9.1.1 If you have an existing stationary CI RICE located at an area source of HAP
emissions, you must comply with the applicable emission limitations and operating
limitations no later than May 3, 2013. (§ 63.6595(a)(1))
What emission limitations, 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 (§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
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)
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 65
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? 0 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? 0
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-
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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit#97OPWE180 Page 66
minutes, after which time the emission standards applicable to all times other than
startup in Tables la, 2a, 2c, and 2d to this subpart apply. (§ 63.6625(h))
9.1.9 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 la 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
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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 67
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
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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 68
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(O(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(O(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. 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(O and (f)(2))
In what form and how long must I keep my records? (sC 63.6660)
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? (5C 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)
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 69
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.
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.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 70
SECTION III - Acid Rain Requirements
1. Designated Representative and Alternate Designated Representative
Designated Representative Alternate Designated Representative
Name: Mark Fox Name: Gary Magno
Title: General Manager — Power Title: Manager Environmental
Generation, Colorado Services, Air Quality
Compliance
Phone: (303)425-3779 Phone: (303) 294-2177
2. Sulfur Dioxide Emission Allowances and Nitrogen Oxide Emission Limitations
2015 2016 2017 2018 2019 2020
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)
Turbine No.6 I I I I I
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 71
2015 I 2016 I 2017 I 2018 I 2019 I 2020
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 7-2014), 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 source or the 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: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 72
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: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 73
(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: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 74
(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.
Pursuant to 40 CFR Part 75.65 excess emissions of opacity shall be reported to the Division. These reports
shall be submitted in a format approved by the Division.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 75
Revisions to this permit shall be made in accordance with 40 CFR Part 72, Subpart H, §§ 72.80 through 72.85
(as adopted by reference in Colorado Regulation 18). Permit modification requests shall be submitted to the
Division at the address identified in Appendix D.
5. Comments, Notes and Justifications
Combustion Turbines No. 2, 3, 4, 5 and 6 burn only natural gas as fuel. The NOx limitations in 40 CFR Part 76
are only applicable to coal-fired utility units.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 76
SECTION IV- Permit Shield
Regulation No. 3, 5 CCR 1001-5, Part C, 4,* I.A.4, V.D., & XIII.B and § 25-7-114.4(3)(a), C.R.S.
1. Specific Non-Applicable Requirements
Based upon the information available to the Division and supplied by the applicant, the following
parameters and requirements have been specifically identified as non-applicable to the facility to which
this permit has been issued. This shield does not protect the source from any violations that occurred
prior to or at the time of permit issuance. In addition, this shield does not protect the source from any
violations that occur as a result of any modification or reconstruction on which construction commenced
prior to permit issuance.
Emission Unit Applicable Requirement Justification
Description&
Number
Facility Colorado Regulation No. 7, Section V.B This requirement is not applicable since the facility is not a bulk
gasoline terminal,bulk gasoline plant or gas dispensing facility.
Facility Colorado Regulation No.7,Sections These requirements are not applicable as the petroleum liquids at this
VI.B.1 &2 facility are stored in tanks that are less than 40,000 gallons.
Facility Colorado Regulation No.7,Section VII.C This requirement is not applicable as crude oil is not stored in tanks
exceeding 40,000 gallons.
Cooling 40 CFR Part 63, Subpart Q(as adopted by These requirements are not applicable because the cooling towers do
Towers reference in Colorado Regulation No. 8, not use chromium-based water treatment chemicals.
Section E)
2. General Conditions
Compliance with this Operating Permit shall be deemed compliance with all applicable requirements
specifically identified in the permit and other requirements specifically identified in the permit as not
applicable to the source. This permit shield shall not alter or affect the following:
2.1 The provisions of §§ 25-7-112 and 25-7-113, C.R.S., or § 303 of the federal act, concerning
enforcement in cases of emergency;
2.2 The liability of an owner or operator of a source for any violation of applicable requirements
prior to or at the time of permit issuance;
2.3 The applicable requirements of the federal Acid Rain Program, consistent with § 408(a) of the
federal act;
2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to
§ 25-7-111(2)(I), C.R.S., or the ability of the Administrator to obtain information pursuant to §
114 of the federal act;
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 77
2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit for cause
pursuant to Regulation No. 3, Part C, § XIII.
2.6 Sources are not shielded from terms and conditions that become applicable to the source
subsequent to permit issuance.
3. Streamlined Conditions
The following applicable requirements have been subsumed within this operating permit using the
pertinent streamlining procedures approved by the U.S. EPA. For purposes of the permit shield,
compliance with the listed permit conditions will also serve as a compliance demonstration for purposes
of the associated subsumed requirements.
Permit Condition(s) Streamlined(Subsumed)Requirements
Section II,Conditions Colorado Regulation No.6,Part B, Section II.D.3.b [SO2 emissions shall not exceed 0.35 lbs/MMBtu]
1.4.1,2.4.3 and 8.4.1. -State-only requirement
Section II,Condition 40 CFR Part 60 Subpart Da § 60.44Da(aX2), 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)(l), as adopted by reference in Colorado Regulation No. 6,
1.2.1.2 Part A[NOx emissions shall not exceed 0.20 lbs/MMBtu]
Section II,Conditions 40 CFR Part 60 Subpart GG§ 60.332(a),as adopted by reference in Colorado Regulation No.6,Part A
1.2.1 (Turbines 2 and 3) [NOx emissions shall not exceed 105.4 ppmvd(for Turbines 2 and 3)and 112 ppmvd(for Turbine 4),
and 2.5.1 (Turbine 4) each at 15%O2 and ISO standard ambient conditions]
Section II,Conditions 40 CFR Part 60 Subpart GG § 60.334(h)(3), as adopted by reference in Colorado Regulation No. 6,
1.9 and 2.10 Part A[source shall monitor the sulfur content of the fuel]
Section II,Conditions 40 CFR Part 60 Subpart GG § 60.334(j)(1)(iii),as adopted by reference in Colorado Regulation No.6,
1.10 and 2.8 Part A [NOx excess emission reporting]
Section II,Condition 1.9 Colorado Construction Permit 94WE609 PSD, only the following portion of Condition 9"an automatic
natural gas sampler shall be installed in the gas supply line that automatically samples each 40 MMscf,
and shall be analyzed monthly"
Section 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,Condition 40 CFR Part 60 Subpart Da § 60.44Da(d)(1), as adopted by reference in Colorado Regulation No. 6,
2.5.1.2 Part A [NOx emissions shall not exceed 1.6 lbs/MW-hr]
Section II,Condition Colorado Regulation No. 1, Section VI.B.4.c.(ii) and VI.B.2 [SO2 emissions shall not exceed 0.35
8.4.1 lbs/MMBtu on a 3-hr rolling average]
Section II,Condition 40 CFR Part 60 Subpart KKKK§ 60.6340(b)(1),as adopted by referenced in Colorado Regulation No.
8.10 6,Part A[use a NOx CEMS]
Section II,Condition 40 CFR Part 60 Subpart KKKK §§ 60.4345(b), as adopted by reference in Colorado Regulation No.6,
5.2.1 Part A[valid hour]
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 78
Permit Condition(s) I Streamlined(Subsumed)Requirements
Section II,Condition 40 CFR Part 60 Subpart KKKK § 60.4350(a), as adopted by reference in Colorado Regulation No. 6,
8.2.2.5 Part A[reduce CEMS data to hourly averages per 60.13(h)]
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 79
SECTION V- General Permit Conditions
5/22/12 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: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 80
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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit#97OPWE180 Page 81
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.
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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 82
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
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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit#97OPWE180 Page 83
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.
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:
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 84
(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.
g. The permittee shall not knowingly falsify,tamper with,or render inaccurate any monitoring device or method
required to be maintained or followed under the terms and conditions of the Operating Permit.
5. Emergency Provisions
Regulation No. 3,5 CCR 1001-5,Part C,§ VII.
An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the
source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that
causes the source to exceed the technology-based emission limitation under the permit due to unavoidable increases in
emissions attributable to the emergency. "Emergency" does not include noncompliance to the extent caused by improperly
designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. An emergency
constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology-based emission
limitation if the permittee demonstrates,through properly signed, contemporaneous operating logs,or other relevant evidence
that:
a. an emergency occurred and that the permittee can identify the cause(s)of the emergency;
b. the permitted facility was at the time being properly operated;
c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that
exceeded the emission standards,or other requirements in the permit;and
d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the
next working day following the emergency,and followed by written notice within one month of the time when
emissions limitations were exceeded due to the emergency. This notice must contain a description of the
emergency,any steps taken to mitigate emissions,and corrective actions taken.
This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement.
6. Emission Controls for Asbestos
Regulation No. 8,5 CCR 1001-10,Part B
The permittee shall not conduct any asbestos abatement activities except in accordance with the provisions of Regulation No.
8,Part B,"asbestos control."
7. Emissions Trading,Marketable Permits,Economic Incentives
Regulation No.3,5 CCR 1001-5,Part C, & V.C.13.
No permit revision shall be required under any approved economic incentives, marketable permits, emissions trading and
other similar programs or processes for changes that are specifically provided for in the permit.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 85
8. Fee Payment
C.R.S. §§25-7-114.1(6)and 25-7-114.7
a. The permittee shall pay an annual emissions fee in accordance with the provisions of C.R.S. §25-7-114.7. A 1%
per month late payment fee shall be assessed against any invoice amounts not paid in full on the 91st day after the
date of invoice,unless a permittee has filed a timely protest to the invoice amount.
b. The permittee shall pay a permit processing fee in accordance with the provisions of C.R.S. §25-7-114.7. If the
Division estimates that processing of the permit will take more than 30 hours,it will notify the permittee of its
estimate of what the actual charges may be prior to commencing any work exceeding the 30 hour limit.
c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S. §25-7-114.1(6)for each APEN or
revised APEN filed.
9. Fugitive Particulate Emissions
Regulation No. 1,5 CCR 1001-3,& III.D.I.
The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate
emissions into the atmosphere,in accordance with the provisions of Regulation No. 1,§III.D.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,$'S X.&XI.
The permittee shall submit an application for a minor permit modification before making the change requested in the
application. The permit shield shall not extend to minor permit modifications.
12. New Source Review
Regulation No.3,5 CCR 1001-5,Part B
The permittee shall not commence construction or modification of a source required to be reviewed under the New Source
Review provisions of Regulation No. 3, Part B, without first receiving a construction permit.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 86
13. No Property Rights Conveyed
Regulation No. 3,5 CCR 1001-5,Part C, § V.C.11.d.
This permit does not convey any property rights of any sort,or any exclusive privilege.
14. Odor
Regulation No.2,5 CCR 1001-4,Part A
As a matter of state law only, the permittee shall comply with the provisions of Regulation No. 2 concerning odorous
emissions.
15. Off-Permit Changes to the Source
Regulation No.3,5 CCR 1001-5,Part C,$ 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, 'S$ 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 1001-17
The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds.
Sections I.,II.C.,II.D.,III. IV.,and V.of Regulation No. 15 shall be enforced as a matter of state law only.
19. Permit Expiration and Renewal
Regulation No.3,5 CCR 1001-5,Part C, $& III.B.6.,IV.C.,V.C.2.
a. The permit term shall be five(5)years. The permit shall expire at the end of its term. Permit expiration terminates
the permittee's right to operate unless a timely and complete renewal application is submitted.
b. Applications for renewal shall be submitted at least twelve months, but not more than 18 months,prior to the
expiration of the Operating Permit. An application for permit renewal may address only those portions of the permit
that require revision,supplementing,or deletion, incorporating the remaining permit terms by reference from the
previous permit. A copy of any materials incorporated by reference must be included with the application.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 87
20. Portable Sources
Regulation No.3,5 CCR 1001-5,Part C, 'S 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,'S V.C.7.b.
The permittee shall promptly report any deviation from permit requirements, including those attributable to malfunction
conditions as defined in the permit,the probable cause of such deviations,and any corrective actions or preventive measures
taken.
"Prompt"is defined as follows:
a. Any definition of"prompt"or a specific timeframe for reporting deviations provided in an underlying applicable
requirement as identified in this permit;or
b. Where the underlying applicable requirement fails to address the time frame for reporting deviations,reports of
deviations will be submitted based on the following schedule:
(i) For emissions of a hazardous air pollutant or a toxic air pollutant(as identified in the applicable regulation)
that continue for more than an hour in excess of permit requirements,the report shall be made within 24
hours of the occurrence;
(ii) For emissions of any regulated air pollutant,excluding a hazardous air pollutant or a toxic air pollutant that
continue for more than two hours in excess of permit requirements,the report shall be made within 48
hours;and
(iii) For all other deviations from permit requirements,the report shall be submitted every six(6)months,
except as otherwise specified by the Division in the permit in accordance with paragraph 22.d.below.
c. If any of the conditions in paragraphs b.i or b.ii above are met,the source shall notify the Division by telephone
(303-692-3155)or facsimile(303-782-0278)based on the timetables listed above. [Explanatory note: Notification
by telephone or facsimile must sped that this notification is a deviation report for an Operating Permit.] A
written notice,certified consistent with General Condition 2.a.above(Certification Requirements),shall be
submitted within 10 working days of the occurrence. All deviations reported under this section shall also be
identified in the 6-month report required above.
"Prompt reporting" does not constitute an exception to the requirements of "Emergency Provisions" for the purpose of
avoiding enforcement actions.
22. Record Keeping and Reporting Requirements
Regulation No.3,5 CCR 1001-5,Part A, 'S II.;Part C, 'S&V.C.6.,V.C.7.
a. Unless otherwise provided in the source specific conditions of this Operating Permit,the permittee shall maintain
compliance monitoring records that include the following information:
(i) date,place as defined in the Operating Permit,and time of sampling or measurements;
(ii) date(s)on which analyses were performed;
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 88
(iii) the company or entity that performed the analysis;
(iv) the analytical techniques or methods used;
(v) the results of such analysis;and
(vi) the operating conditions at the time of sampling or measurement.
b. The permittee shall retain records of all required monitoring data and support information for a period of at least five
(5)years from the date of the monitoring sample,measurement,report or application. Support information,for this
purpose,includes all calibration and maintenance records and all original strip-chart recordings for continuous
monitoring instrumentation,and copies of all reports required by the Operating Permit. With prior approval of the
Air Pollution Control Division,the permittee may maintain any of the above records in a computerized form.
c. Permittees must retain records of all required monitoring data and support information for the most recent twelve
(12)month period,as well as compliance certifications for the past five(5)years on-site at all times. A permittee
shall make available for the Air Pollution Control Division's review all other records of required monitoring data
and support information required to be retained by the permittee upon 48 hours advance notice by the Division.
d. The permittee shall submit to the Air Pollution Control Division all reports of any required monitoring at least every
six(6)months,unless an applicable requirement,the compliance assurance monitoring rule,or the Division requires
submission on a more frequent basis. All instances of deviations from any permit requirements must be clearly
identified in such reports.
e. The permittee shall file an Air Pollutant Emissions Notice("APEN")prior to constructing,modifying,or altering
any facility,process,activity which constitutes a stationary source from which air pollutants are or are to be emitted,
unless such source is exempt from the APEN filing requirements of Regulation No.3,Part A, §II.D. A revised
APEN shall be filed annually whenever a significant change in emissions,as defined in Regulation No.3,Part A, §
II.C.2.,occurs;whenever there is a change in owner or operator of any facility,process,or activity;whenever new
control equipment is installed;whenever a different type of control equipment replaces an existing type of control
equipment;whenever a permit limitation must be modified;or before the APEN expires. An APEN is valid for a
period of five years. The five-year period recommences when a revised APEN is received by the Air Pollution
Control Division. Revised APENs shall be submitted no later than 3D days before the five-year term expires.
Permittees submitting revised APENs to inform the Division of a change in actual emission rates must do so by
April 30 of the following year. Where a permit revision is required,the revised APEN must be filed along with a
request for permit revision. APENs for changes in control equipment must be submitted before the change occurs.
Annual fees are based on the most recent APEN on file with the Division.
23. Reopenings for Cause
Regulation No. 3,5 CCR 1001-5,Part C, §XIII.
a. The Air Pollution Control Division shall reopen,revise,and reissue Operating Permits;permit reopenings and
reissuance shall be processed using the procedures set forth in Regulation No.3,Part C, §III.,except that
proceedings to reopen and reissue permits affect only those parts of the permit for which cause to reopen exists.
b. The Division shall reopen a permit whenever additional applicable requirements become applicable to a major
source with a remaining permit term of three or more years,unless the effective date of the requirements is later than
the date on which the permit expires,or unless a general permit is obtained to address the new requirements;
whenever additional requirements(including excess emissions requirements)become applicable to an affected
source under the acid rain program;whenever the Division determines the permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other terms or conditions of the permit;
or whenever the Division determines that the permit must be revised or revoked to assure compliance with an
applicable requirement.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 89
c. The Division shall provide 30 days'advance notice to the permittee of its intent to reopen the permit,except that a
shorter notice may be provided in the case of an emergency.
d. The permit shield shall extend to those parts of the permit that have been changed pursuant to the reopening and
reissuance procedure.
24. Section 502(b)(10)Changes
Regulation No.3,5 CCR 1001-5,Part C, XII.A.
The permittee shall provide a minimum 7-day advance notification to the Air Pollution Control Division and to the
Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permittee shall attach a copy of
each such notice given to its Operating Permit.
25. Severability Clause
Regulation No.3,5 CCR 1001-5,Part C, V.C.10.
In the event of a challenge to any portion of the permit, all emissions limits, specific and general conditions, monitoring,
record keeping and reporting requirements of the permit,except those being challenged,remain valid and enforceable.
26. Significant Permit Modifications
Regulation No.3,5 CCR 1001-5,Part C&III.B.2.
The permittee shall not make a significant modification required to be reviewed under Regulation No. 3, Part B
("Construction Permit" requirements) without first receiving a construction permit. The permittee shall submit a complete
Operating Permit application or application for an Operating Permit revision for any new or modified source within twelve
months of commencing operation, to the address listed in Item 1 in Appendix D of this permit. If the permittee chooses to
use the "Combined Construction/Operating Permit" application procedures of Regulation No. 3, Part C, then the Operating
Permit must be received prior to commencing construction of the new or modified source.
27. Special Provisions Concerning the Acid Rain Program
Regulation No.3,5 CCR 1001-5,Part C, §§ V.C.1.b.&8
a. Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations
promulgated under Title IV of the federal act,40 Code of Federal Regulations(CFR)Part 72,both provisions shall
be incorporated into the permit and shall be federally enforceable.
b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal act or the
regulations promulgated thereunder,40 CFR Part 72,are expressly prohibited.
28. Transfer or Assignment of Ownership
Regulation No. 3,5 CCR 1001-5,Part C, § ILC.
No transfer or assignment of ownership of the Operating Permit source will be effective unless the prospective owner or
operator applies to the Air Pollution Control Division on Division-supplied Administrative Permit Amendment forms,for
reissuance of the existing Operating Permit. No administrative permit shall be complete until a written agreement containing
a specific date for transfer of permit,responsibility,coverage,and liability between the permittee and the prospective owner
or operator has been submitted to the Division.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division Public Service Company of Colorado
Colorado Operating Permit Ft. St. Vrain Station
Permit# 97OPWE180 Page 90
29. Volatile Organic Compounds
Regulation No. 7,5 CCR 1001-9,&§III&V.
The requirements in paragraphs a, b and e apply to sources located in an ozone non-attainment area or the Denver 1-hour
ozone attainment/maintenance area. The requirements in paragraphs c and d apply statewide.
a. All storage tank gauging devices,anti-rotation devices,accesses,seals,hatches,roof drainage systems,support
structures,and pressure relief valves shall be maintained and operated to prevent detectable vapor loss except when
opened,actuated,or used for necessary and proper activities(e.g. maintenance). Such opening,actuation,or use
shall be limited so as to minimize vapor loss.
Detectable vapor loss shall be determined visually, by touch, by presence of odor, or using a portable hydrocarbon
analyzer. When an analyzer is used, detectable vapor loss means a VOC concentration exceeding 10,000 ppm.
Testing shall be conducted as in Regulation No.7,Section VIII.C.3.
b. Except when otherwise provided by Regulation No. 7,all volatile organic compounds,excluding petroleum liquids,
transferred to any tank,container,or vehicle compartment with a capacity exceeding 212 liters(56 gallons),shall be
transferred using submerged or bottom filling equipment. For top loading,the fill tube shall reach within six inches
of the bottom of the tank compartment. For bottom-fill operations,the inlet shall be flush with the tank bottom.
c. The permittee shall not dispose of volatile organic compounds by evaporation or spillage unless Reasonably
Available Control Technology(RACT)is utilized.
d. No owner or operator of a bulk gasoline terminal,bulk gasoline plant,or gasoline dispensing facility as defined in
Colorado Regulation No. 7, Section VI,shall permit gasoline to be intentionally spilled,discarded in sewers,stored
in open containers,or disposed of in any other manner that would result in evaporation.
e. Beer production and associated beer container storage and transfer operations involving volatile organic compounds
with a true vapor pressure of less than 1.5 PSIA actual conditions are exempt from the provisions of paragraph b,
above.
30. Wood Stoves and Wood burning Appliances
Regulation No.4,5 CCR 1001-6
The permittee shall comply with the provisions of Regulation No. 4 concerning the advertisement, sale, installation, and use
of wood stoves and wood burning appliances.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: 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 TEST
*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: 1/1/2016
Last Revised: 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 192. The facility
address is 16805 County Road 192.
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/PM10)
Units with emissions less than APEN de minimis - non-criteria pollutants (Reg 3, Part C.II.E.3.b)*
Two (2) sulfuric acid storage tanks, 20,000 gal and 750 gal above ground (emissions less than 500
lbs/yr)
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix A
Inspection Information Page 2
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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix A
Inspection Information Page 3
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 (3) 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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix A
Inspection Information Page 4
Surface water storage impoundment of non-potable water and storm water evaporation ponds (Reg 3,
Part C.II.E.3.yvy)
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 Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix A
Inspection Information Page 5
, r
I
I I ,
j
Figure 1: Facility Plot Plan
t I Ft St.Vrain Station l sl
84 ;
I J V - z a 4
9 i x S II1
PI y
j
gg S
IG 'l
C ^' \FI I I% z
` ;,� Ili ( II g2 e 3- 3r
� IR I 4 � 3a ,_
- _ Q't{ �' s =` , ri, Ill f n
9
. .•ter.. MO* [11
�.. ill� i, ki lit -- Ilimt iir�n* iI `it g
t
tl
II 7(-----) ------,-111 q j i ,I 1 I it
If
_jj
a a_;_
I I i I
vi
z411
II
I if f
- I 'x I. i I '^ I 0 I I e I-`r. j
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: 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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 2
requirements, including those attributable to malfunctions as defined in this Appendix, the probable cause of
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.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 3
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
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
' 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: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 4
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
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: 1/1/2016
Last Revised: 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?' Codez 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: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 6
Deviations noted Deviation Malfunction/Emergency
During Period?' Code2 Condition Reported
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.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 7
9=Other: When the deviation is not covered by any of the above categories
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 8
Monitoring and Permit Deviation Report-Part II
FACILITY NAME: Public Service Company 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: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 9
EXAMPLE
FACILITY NAME: Acme Corp.
OPERATING PERMIT NO: 96OPZZXXX
REPORTING PERIOD: 1/1/04 - 6/30/06
Is the deviation being claimed as an: Emergency Malfunction XX N/A
(For NSPS/MACT)Did the deviation occur during: Startup Shutdown Malfunction
Normal Operation
OPERATING PERMIT UNIT IDENTIFICATION:
Asphalt Plant with a Scrubber for Particulate Control - Unit XXX
Operating Permit Condition Number Citation
Section II, Condition 3.1 - Opacity Limitation
Explanation of Period of Deviation
Slurry Line Feed Plugged
Duration
START- 1 730 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: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 10
Monitoring and Permit Deviation Report-Part III
REPORT CERTIFICATION
SOURCE NAME: Public Service Company of Colorado—Ft. St. Vrain Station
FACILITY IDENTIFICATION NUMBER: 1230023
PERMIT NUMBER: 97OPWE 180
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: 1/1/2016
Last Revised: 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 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 45D MMBtu/hr),
Natural Gas Fired. Turbine May be
Operated in Conjunction with a
HRSG(combined cycle operation)
Equipped with Natural Gas Fired
Duct Burners.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: 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: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix C
Compliance Certification Report Page 3
Operating Unit Description Deviations Monitoring Was Compliance Continuous
Permit Reported ` Method per or Intermittent?3
Unit ID Permit?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.
Note whether the compliance status with of each term and condition provided was continuous or intermittent. "Intermittent
Compliance"can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance
only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance
has occurred.
NOTE:
The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the
absence of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance
for the duration of the reporting period. Therefore, if a source 1) conducts all of the monitoring and recordkeeping required in its
permit, even if such activities are done periodically and not continuously, and if 2) such monitoring and recordkeeping does not
indicate non-compliance, and if 3)the Responsible Official is not aware of any credible evidence that indicates non-compliance,then
the Responsible Official can certify that the emission point(s) in question were in continuous compliance during the applicable time
period.
'Compliance status for these sources shall be based on a reasonable inquiry using readily available information.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: 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: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix D
Notification Addresses Page 1
APPENDIX D
Notification Addresses
1. Air Pollution Control Division
Colorado Department of Public Health and Environment
Air Pollution Control Division
Operating Permits Unit
APCD-SS-B 1
4300 Cherry Creek Drive S.
Denver, CO 80246-1530
ATTN: Matt Burgett
2. United States Environmental Protection Agency
Compliance Notifications:
Office of Enforcement, Compliance and Environmental Justice
Mail Code 8ENF-AT
U.S. Environmental Protection Agency, Region VIII
1595 Wynkoop Street
Denver, CO 80202-1129
502(b)(10) Changes, Off Permit Changes:
Office of Partnerships and Regulatory Assistance
Air and Radiation Programs, 8P-AR
U.S. Environmental Protection Agency, Region VIII
1595 Wynkoop Street
Denver, CO 80202-1129
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: 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
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: DRAFT
Air Pollution Control Division
Colorado Operating Permit Appendix E
Permit Acronyms Page 2
PMio - Particulate Matter Under 10 Microns
PPM Parts Per Million
PPMV Parts Per Million, by Volume
PPMVD Parts Per Million, by Volume, Dry
PSD - Prevention of Significant Deterioration
PTE - Potential To Emit
RACT- Reasonably Available Control Technology
SCC - Source Classification Code
SCF - Standard Cubic Feet
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: 1/1/2016
Last Revised: 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
DRAFT Significant Section II.1 The last sentence in Condition 1.2.1.5 was revised to specify 30 minutes
Modification rather than 15.For the third renewal permit,the source requested that
the startup definition be revised to end 30 minutes after reaching Mode
6 and while that was done in Condition 1.2.15,the last sentence of that
condition still indicated 15 minutes.In addition,clarifying language
was added to Condition 1.2.1.5 to address commencing a combined
cycle startup from simple cycle operation(turbine drops below Mode
6).The combined cycle startup from simple cycle operation was first
included in the September 9,2011 revised permit.
Section 11.2 Revised Condition 2.5.1.5 to include a"startup"definition that is
different from the other turbines.Prior to this modification,all turbines
had the same startup definition.
Appendices Included the PSD and NANSR applicability test in Appendix H.
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: 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: 1/1/2016
Last Revised: 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(lb/hr or ppm)
x=Heat Input(MMBtu, CT: simple cycle, Duct Burners: combined cycle)
Simple Cycle, lbs/hr
y=ax^2-bx+c
Coefficient Data:
a= 8 x 10-6
b= 0.0156
c= 9.5178
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: 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: 1/1/2016
Last Revised: 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 G 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: 1/1/2016
Last Revised: 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) SO2(Tons) (Tons) CO (Tons) VOC(Tons)
Baseline Actual
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) SO2 (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
0/
0/ 15 25. .
25.0 40.0 100.0 25.0
10.0
Operating Permit Number: 97OPWE180 First Issued: 1/1/2000
Renewed: 1/1/2016
Last Revised: 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
July 2020
Permit Reviewed by:
Compliance Monitoring Unit: Travis Harder
I. Purpose:
This document establishes the decisions made regarding the requested modification to
the Operating Permit for Public Service Company's Ft. St. Vrain Station. This document
provides information describing the type of modification and the changes made to the
permit as requested by the source and the changes made due to the Division's analysis.
This document is designed for reference during review of the proposed permit by EPA
and for future reference by the Division to aid in any additional permit modifications at
this facility. The conclusions made in this report are based on the information provided
in the request for modification submitted to the Division on June 22, 2020, the
applicability analysis submitted on July 6, 2020 and subsequent revisions to that
analysis, e-mail correspondence and telephone conversations with the source. 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.
II. Description of Permit Modification Request/Modification Type
The Operating Permit for Ft. St. Vrain was first issued on January 1, 2000 and was
renewed on January 1, 2016. The purpose of the June 22, 2020 modification is to revise
the definition of"startup" for Turbine 4. Turbine 4 was subject to Prevention of
Significant Deterioration (PSD) review requirements when it was built and is subject to
best available control technology (BACT) requirements. Turbine 4 is subject to
alternative BACT limits during periods of startup, shutdown and combustion tuning and
123-0023 Page 1
Public Service Company of Colorado—Ft. St. Vrain Station Operating Permit No. 97OPWE180
Technical Review Document—Third Renewal, Modification No. 1
testing, as well as BACT limits during steady state operation. Public Service Company
of Colorado (PSCo) is planning to replace the rotor and other parts on Turbine 4 during
an outage in the fall of 2020. The replacement parts are "like-kind" replacements but
some parts are newer versions. 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. With the rotor replacement project a minor change to the
definition of startup for turbine 4 is necessary. Since the definition of startup is used in
conjunction with a "case-by-case" limitation, the Division considers that this modification
must be processed as a significant modification in accordance with Colorado Regulation
No. 3, Part C, Section I.A.7.c.
On July 6, 2020, PSCo submitted the applicability analysis for the rotor replacement
project as required by Colorado Regulation No. 3, Part D, Section I.B.4. 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 1.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 1.6.4).
At the request of the Division changes were made to the July 6, 2020 applicability
analysis to address projected actual emissions on the basis of heat input (fuel) rather
than net output (MW).
III. Discussion of Modifications Made
Source Requested Modifications
The following changes were made to the permit to address the application:
Section 11.1 —Turbines 2 and 3
• The last sentence in Condition 1.2.1.5 was revised to specify 30 minutes rather than
15. For the third renewal permit, the source requested that the startup definition be
revised to end 30 minutes after reaching Mode 6 and while that was done in
Condition 1.2.15, the last sentence of that condition still indicated 15 minutes.
• Added clarifying language to Condition 1.2.1.5 to address commencing a combined
cycle startup from simple cycle operation (turbine drops below Mode 6). The
combined cycle startup from simple cycle operation was first included in the
September 9, 2011 revised permit.
Section 11.2 —Turbine 4
123-0023 Page 2
Public Service Company of Colorado—Ft. St.Vrain Station Operating Permit No. 97OPWE180
Technical Review Document—Third Renewal, Modification No. 1
• Revised Condition 2.5.1.5 to include a "startup" definition that is different from the
other turbines. Prior to this modification, all turbines had the same startup definition.
Appendices
• Included the PSD and NANSR applicability test in "new" Appendix H.
•
123-0023 Page 3
7/3 /2020 State.co.us Executive Branch Mail-RE:Responses to FSV Unit 4 Rotor Project-NSR Evaluation
• s CO,
IS STATE OF
7W1 COLORADO Joyce-CDPHE, Jackie<jackie.joyce@state.co.us>
RE: Responses to FSV Unit 4 Rotor Project - NSR Evaluation
1 message
Campbell, Chad E<Chad.Campbell@xcelenergy.com> Fri, Jul 31, 2020 at 10:36 AM
To: "Joyce-CDPHE, Jackie"<jackie.joyce@state.co.us>
Cc: "Williams, Sabrina M" <Sabrina.M.Williams@xcelenergy.com>
Hi Jackie. Sorry about that. Now I understand better what you were asking. See below. At this point I don't think we
need a call.
Thanks,
Chad
From: Joyce-CDPHE,Jackie <jackie.joyce@state.co.us>
Sent: Thursday, July 30, 2020 12:14 PM
To: Campbell, Chad E <Chad.Campbell@XCELENERGY.COM>
Subject: Re: Responses to FSV Unit 4 Rotor Project- NSR Evaluation
EXTERNAL - STOP &THINK before opening-links and attachments.
Hi Chad,
So I have to include the applicability test for this project in an appendix of the permit, so I am trying to wrap up the
questions and issues before I get this permit to public comment (that is the next step now). I think the timing is stilt
fine but want to get this to public comment as soon as possible.
I am quitting early today (around 12:30) because I have an appt this afternoon but will be in the office tomorrow, so if
you want to have a call tomorrow we can do that, you can just call me on the office phone.
This doesn't address my questions and concerns completely.
1. Baseline NOX emissions. There is no reason that baseline NOX emissions should change, except to account for
non-compliant emissions (adjusted downward) and it appears there was only 1-hr of non-compliant emissions in 2017
which was not used for the 2-yr average. For some reason when I asked for the analysis based on heat input, baseline
NOX emissions went up. This should not happen. You should use an emission rate in lb/MMBtu to calculate projected
emissions, there is no reason to recalculate baseline NOX emissions. I confirmed for the most part that baseline
emissions used in the initial applicability analysis (7/6/2020 email to Matt Burgett) matched the values reported on
APENS and to CAMD. Below shows the difference in baseline emissions. You should be using the values in the initial
submittal (7/6/2020) as these appear to be the actual emissions from those years (per APENs and CAMD).
https://mai l.goog le.com/mail/u/0?ik=4cf2986dc4&view=pt&search=a ll&permthid=thread-f%3A1673372505931302670%7Cmsg-f%3A16737513771671... 1/8
7/31/2020 State.co.us Executive Branch Mail•-RE:Responses to FSV Unit 4 Rotor Project-NSR Evaluation
NOX from NOX from 7/27&
7/6/2020 30/2020
Year submittal) submittals
2016 53.3 72.9
2017 53.5 61.7
2018 58.9 65.4
2019 68.9 74.4
baseline (2018-
2019 63.9 69.9
1These values are consistent with emissions reported on APENS and CAMD.
You are correct. This was an error in our calculation method that got carried into this version of the spreadsheet. I have
link the NOx tons to the historical generation tab to properly reflect the tonnages.
2. Please confirm the 2.9% heat rate improvement means that the heat input rate for the turbine is increased. So I
assume the design rate of the turbine is increased from 1,531 MMBtu/hr to 1,575 MMBtu/yr (this is 1,531 MMBtu/hr x
1.029 = 1,575 MMBtu/hr). If this is correct, I will change the table in Section I, Condition 6.1. In addition, that means
you need to look forward 10 years for Turbine 4 (change in the design rate). So is the 2021 projected heat input rate
the maximum expected heat input rate in the 10 years following completion of the project?
Actually the 2.9% improvement means that the overall heat input rate actually decreases per megawatt. This is due to
the fact that we are doing better air management through increased air flow. Combining the heat rate improvement and
increased megawatts the new calculated heat input rate is 1,704 mmbtu/hr.
•
Yes, based on the information that has been provided to me to-date, 2021 is the maximum projected heat input rate
looking out 10 year. But with that adjustment I am having the group that provided that do a second confirmation and will
let you know if something changes.
Thanks for answering the question on the gross output (MW) on CAMD. I know it wasn't relevant to the analysis since I
asked you to use heat input, rather than the net output that was used in the initial submittal but I was just curious.
If you have questions on any of this, just send me an email and we can discuss this tomorrow. I am usually in the office
from 7 am to 3:30 pm, so just give me a time.
Thanks,
Jackie Joyce
Permit Writer
https://mai I.google.com/m ail/u/0?i k=4cf2986d c4&view=pt&search=a II&permth id=th read-f%3A 1673372505931302670%7C msg-f%3A16737513771671... 2/8
7/3i/2020 State.co.us Executive Branch Mail-RE:Responses to FSV Unit 4 Rotor Project-NSR Evaluation
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 Thu, Jul 30, 2020 at 10:20 AM Campbell, Chad E<Chad.Campbell@xcelenergy.com>wrote:
Hi Jackie. See our responses to your follow-up questions below and let me know if you need anything further. I'm not
sure how this is impacting the processing of the permit modification, but my guess is that we need to tie everything up
here as quickly as possible in order to support that side of the effort. To support that we can also get on the phone with
a few of our folks to make sure you have everything you need.
Thanks,
Chad
•
From: Joyce - CDPHE;Jackie <jackie.joyce@state.co.us>
Sent: Tuesday,July 28, 2020 4:05 PM
To: Campbell, Chad E <Chad.Campbell@XCELENERGY.COM>
Cc: Williams, Sabrina M <Sabrina.M.Williams@xcelenergy.com>
Subject: Re: Responses to FSV Unit 4 Rotor Project-NSR Evaluation
EXTERNAL -STOP &T I-IiNK before opening finks and attachments.
Hi Chad,
I have a few additional questions based on the responses and I noticed some problems with the
spreadsheet/applicability analysis.
• What is meant by"2.9% heat rate improvement"? Does this mean that the turbine will have an increased heat
input capacity or something else? If it means an increase in heat input capacity, the 10 year look forward for
projected emissions would apply (this would indicate an increase in design capacity or potential to emit).
Yes. Because some of the parts are from a newer model,there will be up to an estimated 2.9% heat rate improvement
and up to a nominal 20 MW output increase depending on ambient conditions—even though NOx performance will be
better.
• When I asked how projected actual emissions were estimated, I was primarily wondering how was the future
new generation and heat input determined?. Is this based on Xcel forecasts for future use or is this from
equipment specifications from the manufacturer? If from manufacturer, can you provide that documentation?
The projected actual emissions were estimated using future heat input projections based on Xcel's forecasts for future
use of this unit. We have a group that conducts extensive modeling runs for projected future operations and they
accounted for the impact of this project in their runs to provide an accurate estimate of future operations.
httos://mai I.aooa le.com/mail/u/0?ik=4cf2986dc4&view=pt&search=a II&permthid=thread-f%3A1673372505931302670%7Cmsg-f%3A16737513771671... 3/8
7/31/2020 State.co.us Executive Branch Mail-RE: Responses to FSV Unit 4 Rotor Project-NSR Evaluation
• The following items are related to the spreadsheet and/or calculations:
o Baseline actual emissions from NOX should not be different. They should be consistent with actual
emissions quantified and reported during those time period, unless required to adjust for non-
compliant emissions. The lb/MMBtu emission factor for NOX can be calculated by dividing baseline
emissions by the baseline heat input to Turbine 4, as was done for other pollutants.
The formula was changed in cell E12 to calculate a baseline NOx lb/mmbtu by dividing the baseline NOx tons by the
baseline Total Heat Input. The result remains at 0.014 lb/mmbtu. I made this change to the other pollutants as well in
the"FSV Unit 4 Turbine Upgrade Emissions Spreadsheet—Division v2" (and v3)file. Results were not impacted.
o The NOX emission rate (factor) based on MW is calculated incorrectly. This appears to be based on
the baseline (2018-2019 average) NOX emission factor 0.014 lb/MMBtu divided by baseline net
generation (0.014/827,172.5 = 1.632 x 10-8).
Yes this was an error. Cell B21 has been revised to correctly calculate a tons/MW-hr rate using the baseline NOx tons
"FSV Unit 4 Turbine Upgrade Emissions Spreadsheet—Division v2"file. Note that the factors in the MWhr based table
were not used in any of the calculations. All of the calculations were revised to be based on fuel and the lb/mmbtu
values following the Division's request. To help in avoiding confusion I have also included a spreadsheet that only
reflects the relevant heat input calculations for this evaluation and removes the Generation Based information as it is
irrelevant. See "FSV Unit 4 Upgrade Emissions Spreadsheet—Division v3".
• Out of curiosity, I was wondering why there is such a big difference in the annual gross generation shown on
the spreadsheet (historical generation tab) compared to the data on EPA's Clean Air Markets Division (CAMD)
site. For example, per the spreadsheet in 2019 gross generation is 864,377 MW (net generation is 852,726
MW) but per the CAMD web site it is 1,366,150 MW.
The generation in the CAMD website includes generation that is created from the Unit 1 steam turbine using exhaust
heat/steam that is being sent from the Unit 4's portion of combined cycle HRSG operation. FSV Units 2 and 3 also
send steam to the Unit 1 steam turbine. The gross generation represented in the spreadsheet only includes
generation that is generated from Unit 4 proper and reflects the MW that are generated as a result of operating the Unit
4 CT and not the generation from Unit 1. Note that at this point the generation numbers are not used in any of the
PSD applicability analysis, only the heat input information is used. The heat input from fuel combusted in the CT and
duct burners are accounted for in the Total Heat Input values. Again, it may be best to use the"FSV Unit 4 Upgrade
Emissions Spreadsheet—Division v3"to focus the discussion on the relevant heat input based calculations.
Feel free to contact me if you have any questions.
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, Jul 27, 2020 at 10:51 AM Campbell, Chad E <Chad.Campbell@xcelenergy.com>wrote:
Thanks Jackie.
Chad
https://mei I.gong le.com/mail/u/0?ik=4cf2986dc4&view=pt&search=all&permth id=thread-f%3A1673372505931302670%7Cmsg-f%3A16737513771671... 4/8
7/3x/2020 State.co.us Executive Branch Mail-RE:Responses to FSV Unit 4 Rotor Project-NSR Evaluation
From: Joyce-CDPHE, Jackie <jackie.joyce@state.co.us>
Sent: Monday, July 27, 2020 10:48 AM
To: Campbell, Chad E <Chad.Campbell@XCELENERGY.COM>
Subject: Re: Responses to FSV Unit 4 Rotor Project-NSR Evaluation
EXTERNAL -STOP &THINK before opening links and attachments. •
Thank you!
I am planning to be in the office on Friday and I should get this to our public comment coordinator then. I wasn't
going to send the permit to you again to review the new appendix (which will include the applicability test), you
will get a chance to review that during the public comment period. For the most part I will be including your
submittal, unless I find an error, so there shouldn't be any issues with it.
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/aped
On Mori, Jul 27, 2020 at 10:18 AM Campbell, Chad E <Chad.Campbell@xcelenergy.com>wrote:
Hi Jackie. Here you go.
Chad
From: Joyce-CDPHE, Jackie <jackie.joyce@state.co.us>
Sent: Monday, July 27;2020 9:23 AM
To: Campbell, Chad E <Chad.Campbell@XCELENERGY.COM>
Cc: Williams, Sabrina M <Sabrina.M.Williams@xcelenergy.com>
Subject: Re: Responses to FSV Unit 4 Rotor Project- NSR Evaluation
EXTERNAL -STOP ° THINK before opening links and attachments.
I I Thanks Chad.
Can I get a copy of the spreadsheet? I need to put the applicability test into an appendix of the permit and it
would be a little easier to do this with a spreadsheet, rather than a pdf.
httos://mai l.400ale.com/mail/u/0?ik=4cf2986dc4&view=pt&search=a II&permthid=thread-f%3A1673372505931302670%7Cmsg-f%3A16737513771671... 5/8
7/31/2020 State.co.us Executive Branch Mail-RE: Responses to FSV Unit 4 Rotor Project-NSR Evaluation
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, Jul 27, 2020 at 6:19 AM Campbell, Chad E <Chad.Campbell@xcelenergy.com>wrote:
Hi Jackie. I am sending responses to your email on Sabrina's behalf. She will be back in the office on
Wednesday. In addition, I have attached a revised Reg 3 Part D submittal due to the direction to evaluate
based on fuel versus output as well as reflect a correction made to our model that was used in the projections.
Responses to Questions from your Email(s):
At any rate, just from a cursory look at the document I may have a few issues, as noted below. Since this is
from a brief look, these concerns may change once I review in depth but I just wanted to give you a heads
up on some potential issues. I will send an email once I complete my review. Also, it would be helpful to
have a copy of the spreadsheet.
• The July 6, 2020 submittal only lists projected actual generation (MW) and emissions for 2021.
Projected actual emissions are to be the maximum annual emission rate for the 5 year or 10 year
period following the project. Are projected emissions from 2021 expected to be the maximum annual
emissions over the 5 or 10 year period? If not emissions should be projected for 2022 - 2025 (assuming
the 5 year period applies). Since baseline generation has seen increases year by year, we would
likely want an explanation of why generation is expected to decrease after 2021.
Projected emissions are proportional to generation and heat input, which were forecasted for 2021-
2025. Emissions occurring in 2021 are the projected maximum annual emissions for this period as this
is when the unit is predicted to be used the most heavily. Emissions are less than 2021 levels in future
years due to changes in system-wide operations, such as increases in renewable generation.
• I'm sure Chad and I have discussed this but more information regarding the rotor replacement should
be provided so that information is part of the application. Specifically is it a like kind-replacement
or an upgrade? Is it anticipated that the design rate (either heat input (MMBtu/hr) or output (MW))
will be increased?These questions would determine whether the 5 or 10 year timeline following
project completion apply.
The project includes the installation of a new rotor, gas path and front-end compressor parts, and
controls system all to occur during the Hot Gas Path Major Inspection Outage scheduled for
September to December of this year to address the normal scheduled maintenance program
requirements for this turbine. The replacement parts are the same parts but some of them are a
newer version of the part. The newer version of parts that will be used are coming from a 7FA.04 CT
while FSV Unit 4 is a 7FA.03 CT. The result of the addition of the newer version of parts is an
estimated 2.9% heat rate improvement and up to a nominal 20 MW output increase depending on
https://mai I.goog le.com/m a iwu/0?ik=4cf2986dc4&view=pt&search=a II&permthid=thread-f%3A1673372505931302670%7Cmsq-f%3A 16737513771671... 6/8
7/31'/2020 State.co.us Executive Branch Mail-RE:Responses to FSV Unit 4 Rotor Project-NSR Evaluation
ambient conditions. This is offset by an overall reduction in the NOx lb/mmbtu rate due to improved
efficiency.
• Most of the permit emission factors are in units of lb/MMBtu and emissions are generated from fuel
consumption. The evaluation is based on output (MW) and emission factors are generated by dividing
baseline emissions by baseline output. I think we would want you to evaluate based on the fuel use
(heat input). This will likely make some difference in the projected emissions estimate but probably
not a significant change.
j
I '
Xcel agrees, for this application it is more appropriate to base projected emissions on fuel
consumption. Thus,Xcel has performed the analysis using the historical NOx Ib/MMBtu emission rate
reported electronically to USEPA under Part 75. A representative baseline rate was determined, and
post project emissions calculated based on forecasted dispatch and using the historical baseline NOx
lb/MMBtu emission rate. The analysis shows a slight increase from baseline in total tonnages due to
increased utilization in 2021. Decrease in utilization is forecasted due to the projected increase in
renewable generation available. See the attached spreadsheet for projected emissions increase
calculations based on heat input and baseline emission rates.
• Should have an explanation of how emissions were projected, e.g. is there as assumed percentage
increase or some other forecast method.
The changes in emissions rates are projected from the equipment specification provided by the
manufacturer(GE). The project is expected to amount to either no-change, or slight decrease in
emission rates on a Ib/MMBtu basis. For purposes of this analysis, projected emissions were
calculated based on the baseline emission rates to conservatively estimate emissions. Due to the
efficiency gains of the project, more megawatts will be generated from a lower heat input. For this
reason total NOx tons were calculated (as you suggested)using the heat input approach, as the
lb/MWhr approach does not account for these efficiency gains, and over-estimates the impact the
project has on emissions.
• Did you have to adjust baseline annual emissions for non-compliant emissions? The annual emission
limitations have been met but were there any periods of non-compliance for short-term emissions?
It's not likely that exceedances of short term limits would change the annual emissions that much but
! i
it is a requirement to adjust baseline emissions downward if there are any noncompliant emissions.
During the 2017-2018 baseline period there was only one exceedance on 11-18-2017 at hour 13:00.
During this hour NOx rate was 106 ppm.The single hourly exceedance does not affect the baseline
emissions.
• The evaluation should also look at PM and PM2.5 emissions as there are significance levels for these
pollutants and PSD review can be triggered for these pollutants. Since we typically'consider PM=
PM10 = PM2.5 for natural gas fired turbines it isn't a big deal as far as calculations go but the
significance levels are different for each. Technically PM is defined differently than PM10 and PM2.5
in Reg 3, Part D, Section II.A.40.g (PM doesn't include condensables ) but considering them to all be
the same for this analysis simplifies the calculations.
The calculations contained in the attached Reg 3 Part D submittal have been revised to consider
potential increases for all criteria pollutants.
k++n..rr..,•mUi,..,.,rtio Awn/mail/Iiinmk=arf9gRRric4&view=ot&search=all&oermthid=thread-f%3A1673372505931302670%7Cmsg-f%3A16737513771671... 7/8
7/31/2020 State.co.us Executive Branch Mail-RE:Responses to FSV Unit 4 Rotor Project-NSR Evaluation
• I reviewed the submittal in detail last week. I generally got the values you did, for the most part I
expect the differences are probably due to rounding. With an electronic copy of the spreadsheet, I
can confirm that. After reviewing the calculation I did have a couple of additional questions/issues.
o As I mentioned above, I could pretty much confirm the calculations with one exception. I
couldn't reproduce projected NOX emissions. I assumed the NOX projected emissions were
estimated based on the calculated emission factor multiplied by 2021 projected generation.
However, when I do that calculation, I get 66.7 tpy, not 74.7 tpy. (863,050 MW x 7.730 x 10-5
lb/MW-hr= 66.7 tpy)
When converting the spreadsheet to pdf the post-project emissions rates were inadvertently not
copied. The post-project calculation is:
(10,514,000 MMBtu x 0.014 NOx lb/MMBtu)/2000 = 71.0 tpy
• The last table is titled "post project emission rates (note changes from baseline in bold)". There
didn't seem to be any changes from baseline and I am not sure if there should be (if the rotor
replacement is essentially like-kind and doesn't increase the emission rate; then baseline and
projected emission factors should probably be the same. Can you explain that note for me?
While there is an increase in design capacity with the project there is an overall reduction in the NOx
lb/mmbtu rate due to improved efficiency. After reevaluating using fuel heat input emission rates
versus MW output,we agree that there is not a significant change from baseline.
Thanks,
Chad
Chad Campbell
Xcel Energy
Manager, Environmental Services—Air&Water
1800 Larimer, Denver, CO 80202
Office: 303.294.2177 Cell: 970.231.1433
E: chad.campbeil@xcelenergy.com
Lup FSV Unit 4 Turbine Upgrade Emissions Spreadsheet-Divisionv4.xlsx
39K
https://mail.google.com/mail/u/0?ik=4cf2986dc4&view=pt&search=all&permthid=thread-f%3A1673372505931302670%7Cmsq f%3A16737513771671... 8/8
Fort St.Vraln Unit
Unit 4
Baseline and Projected Actual Emissions for PSD Applicability Analysis
Total Heat Input NOx 302 Total PM PM10 PMIO PM2.5 PM2.5 CO CO VOC
(MMBtu) NOx(Tons) (lb/MMBtu) SO2(Tons) (IbIMMBtu) Total PM(Tons) (lb/MMBtu) (Tons) (lb/MMBtu) (Tons) (lb/MMBtu) (Tons) (lb/MMBtu)) VOC(Tons) (lb/MMBtu)
Baseline Actual Emissions s'sw;.P ,n fu a 1^ F 'z',c .,? .. /, s ;y",::°,n s1 ¢,:'. I ..av, v:riV .e:3 t h, M : p*'"6e't ` T
2016 6,943,978.8 53.4 0.021 2.0 0.001 17.6 0.005 17.6 0.005 17.6 0.005 54.2 0.0156 3.2 0.0009
2017 7,712,681.0 53.5 0.016 2.3 0.001 19.3 0.005 19.3 0.005 19.3 0.005 22.5 0.0058 3.7 0.0010
2018 10,059,076.9 59.0 0.013 3.0 0.001 25.6 0.005 25.6 0.005 25.6 0.005 18.9 0.0038 4.3 0.0009
2019 10,632,449.3 68.9 0,014 3.2 0.001 26.2 0.005 26.2 0.005 26.2 0.005 25.6 0.0048 4.6 0.0009
Baseline(2018-2019 average) 10,345,763.1 63.9 0.012 3.1 0.001 25.9 0.005 25.9 0.005 25.9 0.005 22.2 0.0043 4.5 0.0009
Total Heat Input Total PM
Projected Actual Emissions (MMBtu) NOx(Tons) S02(Tons) (Tons) PM10(Tons) PM2.5(Tons) CO(Tons) VOC(Tons)
2021 10,514,000.0 65.0 3.1 26.3 26.3 26.3 22.6 4.5
Projected change in aclual emissions compared to r
_ 1.0 0.1 0.4 0.4 0.4 0.4 0.1
baseline
'4,7'4. 6"''°'',`T, n"'NSRSIgnifidankLevel Threshold 25.0 40.0 25.0 15.0 10.0 100.0 25.0
Baseline Emission Rates(Heat Input based)
Pollutant Rate Units Data Source
NOn 0.0124 Ib/MMBtu CEMS
S02 5.953E-0416/MMBtu CEMs
Total PM 5.005E-03 lb/MMBtu N/A-see PM10
PM10 5.005E-03 lb/MMBtu Stack Test data
PM2.5 5.005E-03 lb/MMEltu N/A-see PM10
CO 4.300E-03 lb/MMBtu CEMs
Pb 0.000E+001b/MMBtu N/A
VOCs 8.603E-04 lb/MMBtu Stack Test data
Sulfuric Acid 0.000E+00 lb/MMBtu N/A
r'\,,`•,
C---,
I"
:7,..;t
Cam\
r,
(....
cc C7/ - /2„) 7,t_-),
}C� e
Xcel Energy-
Environmental Services
1800 Larimer Street,Suite 1300
Denver, CO 80202
July 27,2020
Electronic Mail
1blr.Matt Burgett
Operating Permit Unit
Stationary Sources Program
Colorado Air Pollution Control Division
4300 Cherry Creek Drive South
Denver,CO 80246
Re: Fort St.Vrain Generating Plant,Platteville, CO
Permit No.97OPWE180
Revised NSR Data Submittal—Unit 4 Turbine Upgrade Project
Mr.Burgett;
On July 2,2020 Public Service Company of Colorado (PSCo) submitted notice that it will install a
new rotor,gas path,front-end compressor parts,and controls system on Unit 4(EU T004) at the
Fort St.Vrain Generating Plant during the Hot Gas Path Major Inspection Outage scheduled for
September to December of 2020 to address the normal scheduled maintenance program
requirements for this turbine along with the associated NSR data review. The information was
submitted in accordance with Colorado Air Quality Control Commission Regulation 3 Part D
V.A.7.C and VLB.5 to confirm that the project will not be a major modification under New Source
Review(NSR).
This revised submittal is being made to reflect a correction made to the analysis and to reflect future
emissions estimations based on fuel versus output per the Division's request. PSCo has determined
that,under any emissions increase test,the project will not result in a significant emissions increase.
Therefore,NSR will not be triggered. Please find attached a copy of the updated information
specified in 40 CFR 51.165.
Please contact me at 3030-294-2177 or chad.campbell a Ncelenergy.com,or Sabrina Williams at
303-294-2187 or Sabrina.M.Ay'itliarns(ii. cclener gv.cotn if you have questions.
Sincerely,
Chad Campbell
Environmental Services
Enclosure
CC: File
•
Fort St.Vrain Unit
Unit 4
Baseline and Projected Actual Emissions for PSD Applicability Analysis
Total Net Generation Total Heat Input NOx 502 Total PM PM10 PM10 PM2.5 MI5 CO CO VOC VOC
IMW-hrs) (MMBtu) NOx(Tans) itb/MMBtu) 502(Tons) (IbtMMBtu) Total PM(Tons) (ibiMMBfu) (Tons) (lb/MMBtu) (Tons) (ibiMMBlu) (Tons) (Ib)MMBIu)) (Tons) (76/MMBtu)
Baseline Actual Emissions - - -
2016 563,036.0 6,943,978.6 72.9 0.021 2.0 0.001 17.6 0.005 17.6 0.005 17.6 0.005 54.2 0.0156 3,2 0,0009
2017 624,237.0 7,712,681.0 61.7 0.016 2.3 0,001 19.3 0,005 19.3 0.005 19.3 0.005 22.5 5.0058 3.7 D.0010
2018 801,619.0 10.059,076.9 65.4 0.013 3,0 0,001 25.6 0.005 25.6 0.005 25.6 0.005 18.9 0.0038 4.3 5.0009
2019 852,726.0 10,632,449.3 74.4 0.014 3,2 0,001 26,2 0.005 26.2 0.005 26.2 0.005 25.6 D.0048 4.6 0.0000
Baseline(2010-2019 average) 827,172.5 10,345,763.1 69.9 0.014 3.1 0,001 25.9 0,005 25.9 0.005 25,9 0.005 22.2 0.0043 4,5 0.0009
Total Net Generation Total Heat Input Total PM
Projected Actual Emissions (MW-hrs) (MMBIu) NOx(Tons) 502(Tons) (Tons) PM10(Tons) PM2,5(Tons) CO(Tons) VOC(Tons)
2021 945,000,0 10,514,000,0 71.0 3,1 26,3 26.3 26.3 22,6 4.5
.Pro)ecle4 change M actual emissions oontpared t5
baseline 1.1 0.0 DA 0.4 0.4 0.4 0.1
NSR Significant Level Threshold 20.0 40.0 25.0 15.0 10.0 100.0 25.0
Baseline Emission Rates(MWhr based) Baseline Emission Rates(Heat In_put based)
Pollutant Rale Linda Data Source Posulent Rnle Tines Onto Santee
NOx 1,632E-08 tent/MW-hr GEMS NOx 0,0136 N/MMStu GEMS
SO2 3,723E-06 lans/AIW-hr OEMs 502 6.963E-04 NIMMBtu C6Ms
Total PM 3.130E-05 Ions1MW-hr N/A-see PMIO Total PM 5.005E-03 lb/MMEllu N/A-see PM10
PM10 3.130E-05 IonsIMW-hr Slack Test dela PMIO 5.00,5E-03 b/MMBIu Slack Teat data
PM2,5 3.130E-05 1onalMW-hr N/A-see PM10 PM2.6 6,005E-03 b/MM61u N/A-sue PM10
Co 2.600E-05 lons/MW-hr CEMs CO 4,300E-02 b/MM5tu CEMa
Pb 0.000E+00 lons/MIN-hr N/A Pb 0.000E+00 b/MM01u NIA
VOCs 5,300E-06 IanslMW-hr Slack Test data VOCs 8.003E-04 N/MMBIu Slack Teal data
6ulfurb Acid 0.000E+00 tonsIMW-hr N/A Sulfuric Acki 0.000E+00 ib/MMBIu N/A
7/13/2020 State.co.us Executive Branch Mail-Fwd:Fort St.Vrain Unit 4 Rotor Project Reg 3 Part D Submittal
h - A
' \z STATE OF
Joyce-, Jackie<jackie.joyce@state.co.us>
COLORADO
7A.
Fwd: Fort St. Vrain Unit 4 Rotor Project Reg 3 Part D Submittal
1 message
Burgett-CDPHE, Matt<matt.burgett@state.co.us> Wed, Jul 15,2020 at 11:35 AM
To: Jackie Joyce<jackie.joyce@state.co.us>
Cc: Blue Parish-<blue.parish@state.co.us>
Hi Jackie,
Can you please review this and make sure a copy gets filed? Let me know if you discover any issues. Thank you!
Matt Burgett, P.E.
Permit Program Manager
CAM. COLORADO
Mr Pollution Control Division
Department of Public Health E.Eno,ronment
P 303.692.3183
4300 Cherry Creek Drive South, Denver, CO 80246-1530
matt.burgett@state.co.us I www.colorado.gov/cdphe/apcd
Questions on Air Pollution Control Division operations during COVID-19 response? Visit our FAQ Q Page.
Are you curious about ground-level ozone in Colorado?Visit our ozone webpage to learn more.
Forwarded message
From: Williams, Sabrina M <Sabrina.M.Williams@xcelenergy.com>
Date: Mon, Jul 6, 2020 at 7:50 AM
Subject: Fort St.Vrain Unit 4 Rotor Project Reg 3 Part D Submittal
To: matt.burgett@state.co.us <matt.burgett@state.co.us>
Cc: Campbell, Chad E<Chad.Campbell@xcelenergy.com>
• Hello,
Attached is PSCo's Submittal to comply with Reg 3 Part D for our rotor project for Fort St.Vrain Unit 4. Based on our
baseline and projected emissions calculations this project does not trigger NSR for any pollutants. Please do not hesitate
to contact me with any questions.
Thank you,
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
https://mail.google.com/mail/u/0?ik=4cf2986dc4&view=pt&search=all&permthid=thread-f%3A1672305214677414498%7Cmsg-f%3A16723052146774... 1/2
7/17/2020 State.co.us Executive Branch Mail-Fwd: Fort St.Vrain Unit 4 Rotor Project Reg 3 Part D Submittal
'1 FSV Unit 4 Rotor project Reg 3 Part D Submittal.pdf
588K
https://mai I.google.com/mail/u/0?ik=4cf2986dc4&view=pt&search=all&permthid=thread-f%3A1672305214677414498%7Cmsg-f%3A16723052146774... 2/2
d
L✓ `f'l\f_i
Xcel Energy-
,
Environmental Services
1800 Larimer Street,Suite 1300
Denver,CO 80202
July 6,2020
Electronic Mail
Mr. Matt Burgett
Operating Permit Unit
Stationary Sources Program
Colorado Air Pollution Control Division
4300 Cherry Creek Drive South
Denver,CO 80246
Re: Fort St. Vrain Generating Plant,Platteville, CO
Permit No. 97OPWE180
NSR Data Submittal—Unit 4 Turbine Upgrade Project
Mr. Burgett:
Public Service Company of Colorado (PSCo) will install a new rotor,gas path, front-end compressor
parts,and controls system on Unit 4 (EU T004) at the Fort St.Vrain Generating Plant during the
Hot Gas Path Major Inspection Outage scheduled for September to December of 2020 to address
the normal scheduled maintenance program requirements for this turbine.This project description,
as well as corresponding emissions data,are being submitted in accordance with Colorado Air
Quality Control Commission Regulation 3 Part D V.A.7.C and VI.B.5 to confirm that the project will
not be a major modification under New Source Review(NSR).
PSCo has determined that,under any emissions increase test, the project will not result in a
significant emissions increase. Therefore,NSR will not be triggered. To assure proper
documentation that the project does not result in an emissions increase greater than significant levels,
PSCo is providing a copy of the information specified in 40 CFR 51.165.
Please contact me at 303-294-2187 or Sabrina.M.Williams@xcelenergv.com if you have questions.
Sincerely,
Sabrina M.Williams
Environmental Services
Enclosure •
Fort St.Vrain Unit 4
2020 Turbine Upgrade
Baseline and Projected Actual Emissions for NSR Applicability Analysis
Sulfuric
Total Net Generation(MW- Total PM PM10 VOC Acid
hrs) NOx(Tons) SO2(Tons) (Tons) (Tons) PM2.5(Tons) CO(Tons) Pb(tons) (Tons) (tons)
Baseline Actual Emissions
2016 563,036 53.3 2.0 17.6 54.2 3.2
2017 624,237 53.5 2.3 19.3 22.5 3.7
2018 801,619 58.9 3.0 25.6 18.9 4.3
2019 852,726 68.9 3.2 26.2 25.6 4.6
Baseline(2018-2019 average) 827,173 63.9 3.1 - 25.9 - 22.2 - 4.5 -
Projected Actual Emissions
2021 "t'i`t x863;050 74.7 3.2 - 27.0 23.2 - 4.6
Projected change in actual emissions compared to
baseline 10.8 0.1 0.0 1.1 0.0 1.0 0.0 0.2 0.0
Non-attainment NSR Significant Level Threshold(5 year) 25`0 " 25.0
Baseline Emission Rates
Pollutant Rate Units Data Source
NOx 7.730E-05 tons/MW-hr GEMS
SO2 3.723E-06 tons/MW-hr CEMs
Total PM 0.000E+00 tons/MW-hr N/A-see PM10
PM10 3.130E-05 tons/MW-hr Stack Test data
PM2.5 0.000E+00 tons/MW-hr N/A-see PM10
CO 2.689E-05 tons/MW-hr CEMs
Pb 0.000E+00 tons/MW-hr N/A
VOCs 5.380E-06 tons/MW-hr Stack Test data
Sulfuric Acid 0.000E+00 tons/MW-hr N/A
Post Project Emission Rates(Note changes from Baseline in Bold) _
Pollutant Baseline Rate Units Data Source
NOx 7.730E-05 tons/MW-hr GEMS
SO2 3.723E-06 tons/MW-hr CEMs
Total PM 0.000E+00 tons/MW-hr Stack Test data
PM10 3.130E-05 tons/MW-hr Stack Test data _
PM2.5 0.000E+00 tons/MW-hr Stack Test data
CO 2.689E-05 tons/MW-hr CEMs
Pb 0.000E+00 tons/MW-hr N/A
VOCs 5.380E-06 tons/MW-hr Stack Test data
Sulfuric Acid 0.000E+00 tons/MW-hr N/A
•
Xcel Energysu
Environmental Services
1800 Lorimer Street,Suite 1300
Denver,CO 80202
June 17,2020
Ms.Jacqueline Joyce
Colorado Department of Public Health&Environment
Air Pollution Control Division,APCD-SS-Bl
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:
This submittal is being made to request a modification to Title V Operating Permit Number
97OPWE180. The current rotor in Fort St.Vrain Unit 4 is being upgraded from a 7FA.03 to a
7FA.04 and with this change the way the startup sequence is defined will change_ As a result,
this modification request is being made to revise the definition of startup included in Condition
1.2.1.5.
Please find included with this submittal:
• A summary identifying the change being requested to Condition 1.2.1.5
• A completed Form OP-50
• Copy of the most recent APEN submittal for Fort St.Vrain Unit 4
Summary of Requested Change
Permit Condition 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 and ends 30
minutes after the turbine reaches Mode 6 operation for Units 2,3,5,and 6. Mode 6
refers to the condition when all six burner nozzles are being fired, For Unit 4 "startup"
ends 30 minutes after the turbine reaches L30-Out. The station control system and each
unit's data acquisition and handling system(DAHS)utilized by the continuous emission
monitoring systems indicates which Mmode the turbine is operating in, A record of
when Mode 6 or L30-Out combustion configuration plus-1430 minutes is achieved is
stored in each unit's DAHS.
•
If you have any questions concerning this request,please contact Chad Campbell of Xcel
Energy's Environmental Services staff, at chad.campbell@xcelenergy.com or(303)294-2177.
Sincerely,
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
File
•
{ COLORADO Form OP-50
Air Pollution Control Division
,)l�'uh=[K;)airr y Er:n.cr^rw
Title V Operating Permit Application Form
This form must be included with any application submittal to the Title V Operating Permit Unit
Title V Operating Plant AIRS ID
Permit Number: 97OPWE180 Number: - 123/0023/008
1. Instructions
Included on the Colorado Air Pollution Control Division Website is an instruction sheet (Form OP-50A) for this
application form. Refer to the instruction sheet or contact the Division with questions. Attach a cover letter
describing the purpose of the application package if more room is needed. Any form with missing information
may be determined administratively incomplete and may result in inability to grant the application shield of
Regulation No, 3, Part C, Section II.B. Note that if using copy and paste; the applicant must paste as plain
text. See "General Instructions" document for more details.
2.- Permit Application Type (check all that apply)
Initial Renewal - Identify any requested changes below or
in a cover letter,
O Significant Modification o Administrative Modification (e,g. transfer of
ownership, correct typographical error, etc,)
Minor Modification The Minor Modification worksheet (Form OP-201) must also be completed if a
source wishes to use the procedures under Colorado Regulation No, 3, Part C, Section X.
Notification of Construction Permit Exempt Title V Billing Contact Update
Unit (APCD PS Memo 09.01, Scenario 7)
• Responsible Official Update — Supplemental Information (describe):
Click here to enter text.
• Other (describe): Click rare to enter text.
3.- General Description - Include brief description describing the purpose of the application package. If more
detail is needed, provide in cover letter.
The current rotor in FSV Unit 4 is being upgraded from a 7FA.03 to a 7FA,04. With this change
General
Descriptiol the way the startup sequence is defined will change. As a result, this modification request is
of package being made to revise the definition of startup included in Condition 1,2,1.5 in Operating Permit
Number 97OPWE180.
Form Revised March 2020 ak COLORADO
Page 11of3 k. ,,. ,
�.._ btvbp
-r COLORAIQ Form OP-50
Au Pollution Control Division
4: Additional information
A. Initial and Renewal Applications
O Check this box if you are submitting an initial or renewal application. For all other application types,
proceed to Section 4.8.
If you are submitting an initial or renewal application, provide the application due date. See Colorado PS-
Memo 09=01 for help with Title V Operating Permit application due dates.
Application Due Date: Click here to enter text .
Basis for Application Due Date (Initial Permits Only): click here to enter text.
B. APEN Attachments
Enclose a copy of the most current complete Air Pollution Emission Notice(s) (APENs) on file with the Division.
New/revised APENs are required if the facility is requesting a modification that requires a new APEN or
changes information on a previously submitted APEN,
O New or Revised APENs have been included with this submittal (filing fees must be included)
O Required = Copies of all applicable APENs have been included (no filing fees are needed for these APEN
copies).
C. Confidential/Trade Secret information
Check the following box if any confidential/trade secret information has been submitted with this application.
The pages including confidential information must clearly be labeled as confidential.
See PS Memo 98.01 for acceptable confidential information submittals.
• This application includes confidential information on the following pages; Click here to enter text.
D. Submittal
The Division is requiring one hardcopy submittal mailed to the APCD (with any wet signatures required; see
instruction documents for details) and one electronic copy submittal emailed to APCD. The electronic
submittal MUST be submitted in word format (either ,doc or .docx) to cdphe apcd title V®state.co.us. For
legal purposes, the date the signed hardcopy is received by the Division is considered the date
received, not when the electronic copy is emailed.
C. Oil and Gas Sources
if this facility is associated with Oil Et Gas activities, Form OP=202 must be completed if the facility is
submitting an initial application or the facility is requesting changes to oil and gas equipment and must be
submitted for the application to be considered complete. Oil and Gas SIC codes include, but are not limited
to, 1311, 1321, and 4922.
O Form OP-202 has been included with this application.
0 This facility is not an oil and gas facility, and/or the facility is not requesting any changes to the oil and gas
equipment.
F. Modeling --- ------------
If an emission unit will have to go through modeling as part of a permit action, OP-204 must be completed and
attached to the corresponding OP=300 series form, if the applicant has already filled out the optional air
quality modeling form as part of the modeling process, the applicant may attach that form in Lieu of OP-204.
For information about the modeling process, see the page titled "Air Quality Modeling Guidance for Permits"
on the Division webpage.
O Form OP-204 has been completed and attached.
O A copy of the optional air quality modeling form has been attached.
o This facility did not trigger modeling requirements.
Form Revised March 2020 Page 12 of 3 C O L Q R A D O
. •
CQ6i RAP4 Form OP-50
Mr Palliation Cs+nTra!Division
ErN1,0.n7ne..
5. Signature of Responsible Official
A. Statement of Completeness
O 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 With Federal and State Enforceable Conditions
g I certify that the facility described in this air pollution permit application is fully in compliance with
all applicable requirements, including compliance certification requirements and any applicable
compliance assurance monitoring.
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) identified below:
Click here to enter text.
C. Certification of Facility Compliance Status With State-Only Enforceable Conditions
O i certify that the facility described in this air pollution permit application is fully in compliance with
all applicable requirements:
c I certify that the facility described in this air pollution permit application is fully in compliance with
alt applicable requirements, except for the following emissions unit(s) identified below:
Click here to enter text.
WARNING: Any person who knowingly, as defined in 5 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 5 25.7 122.1, C.R.S.
Responsible Official Jeff West
Name or Other'
Title Senior Director, Environmental Services
Signature&
Date Click 6:ef p7t r text.
'For the following applications, a signature of a Legally Authorized Person (not a vendor or consultant) is
acceptable: Notification of Construction Permit Exempt Unit, billing contact update, Responsible Official
update, and Supplemental Information submittal. For these application types, a Legally Authorized Person
must only certify with Section 5.A (5.8 and 5.C certifications are not needed).
This document requires a "wet signature," electronic signatures wilt not be accepted.
SEND MATERIALS TO:
Colorado Dept. of Public Health & Environment
APCD-5S=81
ATTN: Title V Unit Supervisor
4300 Cherry Creek Drive South
Denver, CO 80246.1530
cdphe apcd=titte_Vestate.co,us
Form Revised March 2020 Page 3 of 3 iVrt.1--'. COLORADO
ti�
1020
!le Ceneral ADEN - Form APCD-200 '''`' c .=
- 44•6,-----17:-41 Air Pollutant Emission Notice (ADEN) and s S;u: �`
CDPH€ Application for Construction Permit
is
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment
for a new filing fee.
There may be a more specific APEN for your source (e.g. boiler, mining operations,engines,etc.). A list of all
available APEN forms can be found on the Air Pollution Control Division (APCD)website.
This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
•
Permit Number: 97OPWE180 AIRS ID Number: 123 /0023 /008
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 1 - Administrative Information
Company Name: Public Service Company of Colorado
Site Name: Fort St. Vrain Station
Site Location
Site Location: 16805 County Rd 19 1/2 Weld
County:
Platteville, CO 80651
NAICS or SIC Code: 4911
Maili"g Address: 1800 Larimer Street, Suite 1300
(Include •
Tip Code)
Denver, CO 80202 Contact Person: Chad Campbell
Phone Number: 303-294-2177
Portable Source E-Mail Address2: chad.campbell@xcelenergy.com
Home Base: _ _
•
1 Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD.Any changes will require additional paperwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
432700
CCADC
Form APCD-2OO - General APEN - Revision 12/2019 1 1 � &CR
Permit Number: 97OPWE180 AIRS ID Number: 123 /0023/008
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 2 - Requested Action
❑ NEW permit OR newly-reported emission source(check one below)
❑ STATIONARY source O PORTABLE source
-OR-
❑ MODIFICATION to existing permit(check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3 O Add point to existing permit
❑ Change permit limit O Transfer of ownership's O Other(describe below)
-OR-
APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
❑ Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
❑ APEN submittal for permit exempt/grandfathered source
Additional Info a Notes: Emissions Update. No permit action requested.
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106)must be submitted.
4 For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: Gas Turbine Electric Generator and duct burners
Manufacturer: General Electric Model No.: PG7241 (FA) Serial No.: 297457
Company equipment Identification No. TOO4
(optional):
For existing sources, operation began on: 2001
For new or reconstructed sources, the projected start-up date is:
0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day days/week weeks/year
Seasonal use percentage: Dec-Feb: Mar-May: Jun-Aug: Sep-Nov:
COLORADO
Form APCD-200 - General APEN - Revision 12/2019 2 I �I
•
Permit Number: 97OPWE180 180 AIRS ID Number: 123 /0023/008
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 4 - Processing/Manufacturing Information Ft Material Use
l]Check box if this information is not applicable to source or process
From what year is the actual annual amount?
Design Process Actual Annual Requested Annual
Description Rate Amount Permit Limit§
(Specify Units) (Specify Units) (Specify Units)
Material - ---
Consumption= — --— — —
Finished
Product(s): —_ —
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider
future process growth.Requested values are required on all APENs,including APEN updates.
• Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40°14'47.08"N/104°52'19.32"W
O Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Di charge height' •, Temp Fl W o Rat
Qperator e Velocity
St clf lD No Le Above round yel (=�) •(A FM) (ftI ec)
•
- T004 175 180 998,397 94
Indicate the direction of the stack outlet: (check one)
❑� Upward ❑Downward ❑ Upward with obstructing raincap
❑Horizontal ❑Other(describe):
Indicate the stack opening and size: (check one)
Q✓ Circular Interior stack diameter(inches): 180
o Square/rectangle Interior stack width (inches): interior stack depth(inches):
o Other(describe):
all, "
Form APCD-200 - General APEN - Revision 12/2019 " " ^'
•
Permit Number: 97OPWE180 180 AIRS ID Number: 123 /0023/008
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 6 - Combustion Equipment &t Fuel Consumption Information
O Check box if this information is not applicable to the source (e.g.there is no fuel-burning equipment associated
with this emission source)
Design input Rate Actual Annual Fuel Use Requested Annual Permit Limits
(MMBi'.'IU/hr) (Sp€cify Units) (Specify Unite)
Natural Gas - 1,953 9,554.1 mmscf 15,224,164 mmbtu/yr
From what year is the actual annual fuel use data? 2019
Indicate the type of fuel used6:
❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF)
❑Field Natural Gas Heating value: BTU/SCF
❑ Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon)
❑ Propane (assumed fuel heating value of 2,300 BTU/SCF)
❑Coal Heating value: BTU/lb Ash content: Sulfur content:
p Other(describe): Natural Gas Heating value (give units): 1,113.8 btu/scf
5 Requested values wilt become permit limitations or will be evaluated for exempt status,as applicable,and should consider
future process growth. Requested values are required on alt APENs,including APEN updates.
6 If fuel heating value is different than the listed assumed value,provide this information in the"Other"field.
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑� Yes ❑No
If yes, describe the control equipment AND state the collection and control efficiencies:
Control Equipment Collection Efficiency •Control Efficiency
Pollutant (%of total emissions'captured by (%reduction of captured
De riptipn control equipment) emissions)
TSP (PM)
PM10
PM2.5
SOX• NOX SCR measured by CEMS
co
VOC
Other:
4 I '
Form APCD-200 - General APEN - Revision 12/2019 �
Permit Number: 97OPWE180 AIRS ID Number: 123 /0023/008
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
2019
From what year is the following reported actual annual emissions data?
Use the following table to report the criteria pollutant emissions from source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
Emission Requested Annual Permit
Uncontrolled Actual Annual Emissions ,,k t 5
Emission Factor Emission Limit(s) ,_',
Pollutant Source
trolled
(verify Units) (�etc.)-42 Mf-` Uncontrolle(tons/year)a (tons/year) Uncontrolled n
cans ear) (tons/year)
TSP (PM) 0.005Ib/mmbtu Permit 26.23 54
PMto 0.005 lb/mmbtu Permit 26.23 54
PM2.5 0.005 Ib/mmbtu Permit 26.23 Not Applicable
so. -- --- —
— - CEMS --- 3.19 4.7
NOx CEMS 68.99 68.99 199.1 199.1
co CEMS 25.61 2379
—--
voc -- CEMS
4.6 331
Other--- — — — --
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider
future process growth.Requested values are required on all APENs,including APEN updates.
7 Annual emission fees wilt be based on actual controlled emissions reported.If source has not yet started operating,provide
projected emissions.
Section 8 - Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteria El Yes ❑ No
pollutants (e.g. HAP - hazardous air pollutant)equal to or greater than 250 lbs/year?
If yes, use the following table to report the non-criteria pollutant (HAP)emissions from source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
Uncontrolled Uncontrolled Controlled
Overall Emission Factor
CAS Chemical Emission Actual Actual
Control Source 7
Humber Name Efficiency Factor (AP-42,Mfg.,etc.) Emissions Emissions
(Specify'-Units) (Ibs/year) (lbs/year)
76-07-0 Acetaldehyde 0.0000912lb/mmbtu ICCR 941
50-00-0 Formaldehyde 0.000148Ib/mmbtu Stack Test 1,576
7439-96-5 Manganese 0.00008021b/mmbtu FIRE 854
7440-02-0 Nickel 0.000115 Ib/mmbtu FIRE 1,225
110-54-3 Hexane 0.259 lb/mmscf AP-42 2,475
75-56-9 Propylene Oxide 0.0478 lb/mmscf AP-42 457
7 Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,provide
projected emissions.
,ate °pro
Form APCD-2OO - General APEN - Revision 12/2019 '"b�""a"'"'"'
•
Permit Number: 97OP VE180 AIRS ID Number: 123 /0023/003 • _
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
From what year is the following reported actual annual emissions data?
Use the following table to report the criteria pollutant emissions from source;
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
Emission Nequeste Annual Perms
1)nconiroUed Factor Actual Artn�+al Em�$sions Emission l=imit(s)§
Emission ,.. �
PollutantSource
(Sam ifY units) OP-42,et .Mfg., Uncontrolled onr Mans/year)7 Uncontrolled(to s/ye r Cons/year)
`TSP (PM)
PMio
PMY.s
SOx - ---
NOx
CO
VOC — --
Other;
s Requested values will become permit limitations or will be evaluated for exempt status,as appli€able,and should consider
future process growth.Requested values are required on all APENs,including APEN updates,
Annual emission fees will be based on actual controlled emissions reported. if source has not yet started operating,provide
projected emissions.
Section 8 -Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteria o yes No
pollutants (e.g. HAP-hazardous air pollutant) equal to or greater than 250 Ws/year?
If yes, use the following table to report the non-criteria pollutant (HAP) emissions from source;
(Use the data reported in Sections 4 and 6 to calculate these emissions.) —Uncontrolled Uncontrolled Controlled
Overall Emission Factor CAS Chemical Emission Actual Actual
Control source
Number Name, Factor Emissions Emissions
Effict+ency (Specify Units), (41::42,Mfg•,etc.) (lbs/year) (lbs/year)
108-88-3 Toluene 0.071 ib/mmscf AP-42 678
7664-41-7 Ammonia - — 3.0 lb/hr Stack Test 23,346
7 Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,provide
projected emissions.
COLORADO
Form APCD-200 - General APEN - Revision 12/2019 5 I I � �
Section 9 -Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
Chad Campbell .*" a 4/30/2020
mtnne by C.zMb�sr.oar�n,e�sue.
Signature of Legally Authorized Person (not a vendor or consultant) Date
Chad Campbell Manager, Environmental Services
Name(print) Title
Check the appropriate box to request a copy of the:
❑ Draft permit prior to issuance
❑ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with$191.13 to: For more information or assistance call:
Colorado Department of Public Health and Environment Small Business Assistance Program
Air Pollution Control Division (303) 692-3175
APCD-SS-B1 OR
4300 Cherry Creek Drive South (303) 692-3148
Denver, CO 80246-1530
APCD Main Phone Number
Make check payable to: (303)692-3150
Colorado Department of Public Health and Environment
C@LORAD0
Form APCD-200 - General APEN - Revision 12/2019 6 I > �I t7 �
aMtFb€nrrenfFeH
Hello