HomeMy WebLinkAbout20193774.tiffa
COLORADO
Department of Public
Health b Environment
Weld County - Clerk to the Board
1150 O St
PO Box 758
Greeley, CO 80632
July 15, 2019
Dear Sir or Madam:
RECEIVED
JUL 19 201
WELD COUNTY
COMMISSIONERS
On July 18, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Public
Service Company of Colorado - Ft. Lupton Combustion Turbines. 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 a Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director
(olic Review
Ogrfl
CG PLCTP), aH(3T). OC,C 3m).
RI) I"UM/£RICH(CK)
5/2I /19
2019-3774
Air Pollution Control Division
Notice Of A Proposed Renewal Title V Operating Permit
Warranting Public Comment
Website Title: Public Service Company of Colorado - Ft. Lupton Combustion Turbines - Weld County
Notice Period Begins: July 18, 2019
NOTICE is hereby given that an application to renew an Operating Permit has been submitted to the
Colorado Air Pollution Control Division, 4300 Cherry Creek Drive South, Denver, Colorado 80246-1530, for
the following source of air pollution:
Applicant: Public Service Company of Colorado
1800 Larimer Street
Denver, CO, 80202
Facility: Ft. Lupton Combustion Turbines
15002 Weld County Road 16
Ft. Lupton, CO, 80621
Public Service Company of Colorado has applied to renew the Operating Permit for the Ft. Lupton
Combustion Turbines in Weld County, CO. This facility is an unmanned electric power generation station
with two single cycle turbines. This was a standard renewal. The only major change was the addition of
Colorado Regulation No. 7, Section XVI requirements for emission units in the ozone non attainment area.
There were no changes to emission limits as a result of this permit renewal. A copy of the application,
including supplemental information, the Division's analysis, and a draft of the Renewal Operating Permit
96OPWE154 have been filed with the Weld County Clerk's office. A copy of the draft permit and the
Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-
permit-public-notices. The Division has made a preliminary determination of approval of the application.
Based on the information submitted by the applicant, the Division has prepared the draft renewal operating
permit for approval. Any interested person may contact Nicholas Dummer, P.E. of the Division at 303-692-
3125 to obtain additional information. Any interested person may submit written comments to the Division
concerning 1) the sufficiency of the preliminary analysis, 2) whether the permit application should be
approved or denied, 3) the ability of the proposed activity to comply with applicable requirements, 4) the
air quality impacts of, alternatives to, and control technology required on the source or modification, and 5)
any other appropriate air quality considerations. Any interested person may submit a written request to the
Division for a public comment hearing before the Colorado Air Quality Control Commission (Commission) to
receive comments regarding the concerns listed above as well as the sufficiency of the preliminary analysis
and whether the Division should approve or deny the permit application. If requested, the hearing 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.
Comments may be submitted using the following options:
(COLORADO
Department at Public
Health a Environment
• 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:
Nicholas Dummer, P.E.
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.
2 I eel
COLORADO
Department of Public
Health & Environment
Colorado Department
of Public Health
and Environment
OPERATING PERMIT
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
First Issued: May 20, 1997
Renewed: DRAFT
AIR POLLUTION CONTROL DIVISION
COLORADO OPERATING PERMIT
FACILITY NAME:
FACILITY ID:
ISSUED:
EXPIRATION DATE:
MODIFICATIONS:
Ft. Lupton
Combustion Turbines
123/0014
DATE_ISSUED
DATE_EXPIRES
See Appendix F of Permit
OPERATING PERMIT NUMBER
96OPWE154
Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et
seq. and applicable rules and regulations.
ISSUED TO:
Public Service Company of Colorado
1800 Larimer Street
Denver, CO 80202
PLANT SITE LOCATIONS:
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
15002 Weld County Road 16
Ft. Lupton, CO 80621
INFORMATION RELIED UPON
Operating Permit Renewal Applications Received: July 28, 2017
And Additional Information Received: N/A
Nature of Business:
Primary SIC:
Electric Services — Power Generation
4911
RESPONSIBLE OFFICIAL
Name: Jeffrey West
Title: Sr. Director Environmental
Services
Phone: (303) 571-2762
FACILITY CONTACT PERSON
Name: Chad Campbell
Title: Manager, Environmental Services
Phone: (303) 294-2177
SUBMITTAL DEADLINES -
First Semi -Annual Monitoring Period:
Subsequent Semi -Annual Monitoring Periods:
Semi -Annual Monitoring Reports:
First Annual Compliance Period:
Subsequent Annual Compliance Periods:
Annual Compliance Certification:
January 1 — June 30, 2019
July 1 — December 31 & January 1 — June 30
Due July 31, 2019 & January 31, 2020 & subsequent years
January 1 — December 31, 2019
January 1 — December 31
Due January 31, 2020 & subsequent years
Note that the Semi -Annual Monitoring Reports and Annual Compliance report 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.
TABLE OF CONTENTS:
SECTION I - General Activities and Summary 1
1. Permitted Activities 1
2. Alternative Operating Scenarios (AOS) 1
3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant Deterioration
(PSD) 2
4. Accidental Release Prevention Program (112(r)) 2
5. Compliance Assurance Monitoring (CAM) 2
6. Summary of Emission Units 3
SECTION II - Specific Permit Terms 4
1. TOOL & T002 - General Electric Combustion Turbines - Natural Gas Fired 4
2. T001 & T002 - General Electric Combustion Turbines — Nos. 1 and/or 2 Fuel Oil Fired 6
3. T001 & T002 - General Electric Combustion Turbines - Natural Gas and Nos. 1 and/or 2 Fuel
Oil Fired. 9
4. Colorado Regulation No. 7, Section XVI — Control of Emissions from Stationary and Portable
Combustion Equipment in the 8 -Hour Ozone Control Area 10
SECTION III - Permit Shield 17
1. Specific Non -Applicable Requirements 17
2. General Conditions 17
3. Stream -lined Conditions 18
SECTION I - General Permit Conditions (version 8/28/2018) 19
A. Appendix A - Inspection Information 33
A.I. Directions to Plant: 33
A.II. Safety Equipment Required: 33
A.III. Facility Plot Plan: 33
A.IV. List of Insignificant Activities- 33
B. Appendix B — Reporting Requirements and Definitions 36
B.I. Appendix B — Monitoring and Permit Deviation Report - Part I 40
B.II. Appendix B — Monitoring and Permit Deviation Report - Part II 42
B.III. Appendix B — Monitoring and Permit Deviation Report - Part III 44
C. Appendix C — Required Format for Annual Compliance Certification Reports 45
D. Appendix D — Notification Addresses 48
D.I. Air Pollution Control Division 48
D.II. United States Environmental Protection Agency 48
E. Appendix E — Permit Acronyms 49
F. Appendix F — Permit Modifications 51
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
1. Permitted Activities
1.1
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 1
SECTION I - General Activities and Summary
The Public Service Company of Colorado — Ft. Lupton Combustion Turbines (herein, Source) is
an unmanned electric power generating station that consists of two (2) simple cycle combustion
turbines nameplate rated at 100 megawatts of power on a gross basis (total for both turbines).
These turbines are fueled by natural gas, Nos. 1 and/or 2 fuel oil, or combination.
The facility is located approximately 2 miles east of Ft. Lupton in Weld county. This facility is
located in an area classified as attainment for all pollutants except ozone. It is classified as non -
attainment for ozone and is part of the 8 -hr Ozone Control Area as defined in Regulation No. 7,
Section II.A.1.
There are no affected states within 50 miles of the plant. Rocky Mountain National Park and
Rawah National Wilderness Area, both Federal Class I designated areas, are within 100
kilometers of the plant.
1.2 Until such time as this permit expires or is modified or revoked, the Source is allowed to
discharge air pollutants from this facility in accordance with the requirements, limitations, and
conditions of this permit.
1.3 The 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 Colorado 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 permit incorporates the
applicable requirements (except as noted in Section II) from the following construction permits:
P-10, 779.
1.4 All conditions in this permit are enforceable by the United States Environmental Protection
Agency (EPA), 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 IV, Conditions 3.g (last paragraph), 14 & 18.
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 IV of this permit. Either electronic or hard copy records are acceptable. All records
required by General Condition 22 are to be retained at Public Service Company's Ft. St. Vrain
Station; either electronic or hard copy records are acceptable.
2. Alternative Operating Scenarios (AOS)
2.1 There are no alternative operating scenarios associated with permitted activities at the facility.
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colora o
Ft. Lupton Combustion Turbin s
Page 2
3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant Deterioratio
(PSD)
3.1 This facility is categorized as a PSD major stationary source (potential to emit of PM, PM10, SO*
NOx and CO ≥ 250 tons per year). Future modifications at this facility resulting in a significant
net emissions increase (see Colorado Regulation No. 3, Part D, Sections II.B.27 and 44) or a
modification which is major by itself (potential to emit > 250 tons per 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 per 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 Source, this facility is not subject to the provisions of
the Accidental Release Prevention Program in Section 112(r) of the Federal Clean Air Act
(CAA).
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: none.
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
6. Summary of Emission Units
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 3
6.1 The emissions units regulated by this permit are the following:
Emission
Unit
Number
AIRS
Point
Number
Facility
Identifier
Description
Startup Date
Pollution
Control
Device
T001
001
T001
General Electric Combustion Turbine, Model
MS7000B, Serial No. 217708, rated at 662.6
MMBtu/hr (NG) and 656 MMBtu/hr (FO). Fueled
by Natural Gas, Nos. 1 and/or 2 Fuel Oil, or
Combination.
April 1972,
Modified 1975
to Burn NG and
Distillate Oil
Uncontrolled
T002
002
T002
General Electric Combustion Turbine, Model
MS7000C, Serial No. 217709, rated at 662.6
MMBtu/hr (NG) and 656 MMBtu/hr (FO). Fueled
by Natural Gas, Nos. 1 and/or 2 Fuel Oil, or
Combination.
April 1972,
Modified 1975
to Burn NG and
Distillate Oil
Uncontrolled
Table 1 - Ft. Lupton Combustion Turbines Emission Unit Summary
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 4
SECTION II - Specific Permit Terms
1. T001 & T002 - General Electric Combustion Turbines - Natural Gas Fired
Parameter
Permit
Condition
Number
Emission
Calculation
1.1
Natural Gas
Usage
1.2
Particulate
Matter (PM)
1.3
SO2
1.4
Btu Content of
Natural Gas
1.5
Opacity
1.6
Limitations
Short Term
Long Term
0.8 lbs/M1V1Btu
No more than 20%
No more than 30% during
certain operations
Compliance
Emission Factor
(lbs/MMBtu)
Monitoring
Method
Interval
PM 2.1 x 10
PMIo-2.1x10-3
S02 -3.8x103
NOx - 0.35
CO - 0.091
VOC-2.3x10-3
Recordkeeping and
Calculation
Annually
Recordkeeping
Annually
Fuel Restriction
Whenever
Natural Gas is
Used as Fuel
ASTM Methods
Annually
Fuel Restriction
Whenever
Only Natural
Gas is Used as
Fuel
1.1
Table 2 — T001 & T002 (Natural Gas Fired) Emissions and Requirements Summary
The emission factors in Table 2 have been approved by the Division and shall be used to
calculate emissions from these turbines (from AP -42, April 2000, Section 3.1, corrected to a
lower heating value basis) when natural gas is used as fuel. Annual emissions, from each
turbine, for the purposes of APEN reporting and the payment of annual fees, shall be calculated
using the Table 2 emission factors, the annual natural gas consumption (as determined by
Condition 1.2), and the heat content of the gas (as determined by Condition 1.5) in the following
equation:
Tons lb MMBtu MMscf 1 ton
= Emission Factor l * Fuel Heat Content f l * Annual Fuel Use f* year MMBtuI LMMScf J L year l 2000 lb
1.2 Natural gas usage, for each unit, shall be monitored annually, and recorded and maintained to be
made available to the Division upon request. Annual natural gas usage will be used to calculate
annual emissions as required by Condition 1.1.
1.3 Particulate matter (PM) emissions from each turbine shall not exceed 0.1 lbs/MMBtu
(Colorado Regulation No. 1, Section III.A.1.c., Colorado Construction Permit P-10,779). In the
absence of credible evidence to the contrary, compliance with the particulate matter limitation is
presumed when only natural gas is used as fuel in the turbines. The Source shall maintain records
that verify that when only natural gas is used as fuel.
Operating Permit # 96OPWE154
First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 5
1.4 Sulfur dioxide (SO2) emissions from each turbine shall not exceed 0.8 lbs/MMBtu (Colorado
Regulation 1, Section VI.A.3.c.(ii)). In the absence of credible evidence to the contrary,
compliance with the sulfur dioxide limitation is presumed whenever natural gas is used as fuel in
the turbines. The Source shall maintain records that verify when only natural gas is used as fuel.
1.5 The Btu content of the natural gas burned shall be determined annually using ASTM Methods, or
equivalent as approved by the Division in advance. Calculation of annual emissions outlined
under Condition 1.1 shall be based on the most recent Btu analysis. The Btu content shall be
based on the lower heating value of the fuel.
1.6 Opacity
1.6.1 Except as provided in Condition 1.6.2, 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, Colorado Construction Permit P-
10,779).
1.6.2 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, any process modification, 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).
1.6.3 In the absence of credible evidence to the contrary, compliance with the 20% and
30% opacity limits shall be presumed when only natural gas is combusted. The
Source shall maintain records that verify when only natural gas is used as fuel.
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 6
2. T001 & T002 - General Electric Combustion Turbines — Nos. 1 and/or 2 Fuel Oil Fired
Parameter
Permit
Condition
Number
Limitations
Compliance Emission
Factor (lbs/M Btu)
Monitoring
Short Term
Long Term
Method
Interval
Emission
Calculations
2.1
�
-
PM 4.3 x 10.3
PMio 4.3 x 10-3
SO2 1.015 (where S is
sulfur content of fuel)
NOx 0.88
CO3.3x10-3
VOC 4.1 x 10-4
Recordkeeping
and Calculation
Annually
Nos. 1 and/or 2
Fuel Oil Usage
2.2.
�r�
"���
1,
�� _e
o
i
Recordkeeping
Annually
Particulate
Matter (PM)
2.3
0.1 lbs/MMBtu
Fuel Restriction
Whenever Nos.
1 and/or 2 Fuel
SO2
2.4
0.8 lbs/MMBtu
Oil is Used as
Fuel
Btu Content of
Nos. 1 and/or 2
Fuel Oil
2.5
g
' ' �9' �'�'"I
ASTM Methods
Opacity
2.6
Not to Exceed 20%
Not to exceed 30% during
certain operations
EPA Reference
Method 9
See Condition 2.5.
Opacity
Table 3— T001 & T002 (Nos. 1 and/or 2 Fuel Oil Fired) Emissions and Requirements Summary
2.1 The emission factors in Table 3 have been approved by the Division and shall be used to
calculate emissions from these turbines (from AP -42, April 2000, Section 3.1) when either Nos.
1 and/or 2 fuel oil are used as fuel. Annual emissions, from each turbine, for the purposes of
APEN reporting and the payment of annual fees, shall be calculated using the Table 3 emission
factors, the annual natural gas consumption (as determined by Condition 2.2), and the heat
content of the gas (as determined by Condition 2.5) in the following equation:
Tons r
lb r Btu l [gallon] 1 ton 1 MMBtu
= Emission Factor * Fuel Heat Content L ! * Annual Fuel Use L J
year MMBtu gallon year 2000 lb 106Btu
2.2 Natural gas usage, for each unit, shall be monitored annually, and recorded and maintained to be
made available to the Division upon request. Annual natural gas usage will be used to calculate
annual emissions as required by Condition 2.1.
2.3 Particulate matter (PM) emissions from each turbine shall not exceed 0.1 lbs/MMBtu
(Colorado Regulation No. 1, Section III.A.1.c., Colorado Construction Permit P-10,779). In the
absence of credible evidence to the contrary, compliance with the particulate matter limitation is
presumed whenever Nos. 1 and/or 2 fuel oil is used as fuel in the turbines.
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 7
2.4 Sulfur dioxide (SO2) emissions from each turbine shall not exceed 0.8 lbs/MMBtu (Colorado
Regulation 1, Section VI.A.3.c.(ii)). In the absence of credible evidence to the contrary,
compliance with the sulfur dioxide limitation is presumed whenever Nos. 1 and/or 2 fuel oil is
used as fuel in the turbines.
Note that this presumption is based on Nos. 1 and/or 2 fuel oil having a sulfur content no greater
than 0.5 weight percent and a heat content no less than 88,125 Btu/gallon. The Source must
maintain records of the sulfur content for Division inspection upon request (the Btu content shall
be monitored per the provisions of Condition 2.5).
2.5 The Btu content of the fuel oil burned shall be determined annually using ASTM Methods, or
equivalent as approved by the Division in advance. Calculation of annual emissions outlined
under Condition 2.1 shall be based on the most recent Btu analysis. The Btu content shall be
based on the lowest gross heating value of the fuel. If no fuel oil is delivered to the facility in the
annual period no fuel sampling is required. The Source shall maintain records of fuel delivery for
Division inspection upon request.
2.6 Opacity — The following requirements apply only when Nos. 1 and/or 2 fuel oil are combusted in
the turbines. These requirements apply to each turbine individually.
2.6.1 Except as provided in Condition 2.6.2, 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, Colorado Construction Permit P-
10,779).
2.6.1.1 An EPA Reference Method 9 opacity observation shall be performed on
each turbine at least once per calendar year of operation. A visible
emissions observation is not required for any annual period where no fuel
oil is burned, where fuel oil is not burned for a period of at least six
minutes, or when fuel oil is not burned during daylight hours.
2.6.1.2 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.
2.6.1.3 All Method 9 observations shall be performed by a certified observer. A
clear, readable copy of the opacity observer's certification shall be kept
with the records of the Method 9 observation. These records and the copy
of the certification shall be made available to the Division for review upon
request.
2.6.2 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, any process modification, or adjustment or occasional
cleaning of control equipment, which is in excess of 30% opacity for a period or
Operating Permit # 96OPWE154
First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 8
periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes
(Colorado Regulation No. 1, Section II.A.4).
2.6.2.1 Compliance with the opacity standard in Condition 2.6.2 shall be
monitored by conducting visible emission observations in accordance with
EPA Method 9, annually. This opacity observation shall be taken within
one (1) hour of the commencement of any of the specific activities
identified in Condition 2.6.2 and every 24 hours thereafter until that
activity is completed.
A visible emission observation is not required for any annual period where
no Nos. 1 and/or 2 fuel is not burned. In addition, a visible emission
observation is not required for any annual period where no specific
activities identified in Condition 2.6.2 have occurred when Nos. 1 and/or 2
fuel oil is burned.
2.6.2.2 A record shall be kept of the type, date, and time of the commencement
and completion of each and every condition subject to Regulation No. 1,
II.A.4. that results in an opacity exceedance. The records shall be made
available to the Division upon request for review.
2.6.2.3 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 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.
2.6.2.4 All Method 9 observations shall be performed by a certified observer. A
clear, readable copy of the opacity observer's certification shall be kept
with the records of the Method 9 observations. The records and the copy
of the certification shall be made available for to the Division upon request
for review.
2.6.3 An opacity reading is not required for a turbine when Nos. 1 and/or 2 fuel is not
burned in the turbine during the calendar year period.
Operating Permit # 96OPWE154
First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 9
3. T001 & T002 - General Electric Combustion Turbines - Natural Gas and Nos. 1 and/or 2 Fuel Oil
Fired.
3.1 Any combination of the fuels identified in this permit (natural gas and/or Nos. 1 and/or 2 fuel oil)
may be burned in the turbine. Monitoring, recordkeeping, and recording requirements for each
fuel must be followed; in the event that requirements overlap (wherein one requirement is more
stringent than another; e.g., fuel oil opacity is more stringent than natural gas opacity), the most
stringent requirements and periodic monitoring shall be followed for the combination of fuels
burned. The most stringent periodic monitoring requirements are for Nos. 1 and/or 2 fuel oil,
followed by natural gas.
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 10
4. Colorado Regulation No. 7, Section XVI — Control of Emissions from Stationary and Portable
Combustion Equipment in the 8 -Hour Ozone Control Area
The combustion turbines covered in this Operating Permit are subject to the following requirements of
Colorado Regulation No. 7, Section XVI.
4.1 The following stationary combustion equipment is exempt from the emission limitation
requirements of Section XVI.D.4., the compliance demonstration requirements in Section
XVI.D.5., and the related recordkeeping and reporting requirements of Sections XVI.D.7.a.-e
and XVI.D.8., but must maintain any and all records necessary to demonstrate that this
exemption applies. These records must be maintained for a minimum of five years and made
available to the Division upon request. Qualifying for an exemption in this section does not
preclude the combustion process adjustment requirements of Section XVI.D.6. (Condition 4.4),
when required by XVI.D.6.a.
Once stationary combustion equipment no longer qualifies for any exemption, the Source must
comply with the applicable requirements of Section XVI.D. (this condition) as expeditiously as
practicable, but no later than 36 months after any exemption no longer applies. Additionally,
once stationary combustion equipment that is not equipped with CEMS or CERMS no longer
qualifies for any exemption, the Source must conduct a performance test using EPA test methods
within 180 days and notify the Division of the results and whether emission controls will be
required to comply with the emission limitations of Section XVI.D.4. (Colorado Regulation No.
7, Section XVI.D.2.).
4.1.1 Any stationary combustion turbine whose utilization is less than 10% of its capacity
factor on an annual average basis over a 3 -year rolling period (Colorado Regulation
No. 7, Section XVI.D.2.a.(ii)).
4.2 Emission limitations. By October 1, 2021, no owner or operator of stationary combustion
equipment may cause, allow or permit NOX to be emitted in excess of the following emission
limitations. When demonstrating compliance using continuous emission monitoring pursuant to
Section XVI.D.5.a.(i), the following emission limitations are on a 30 -day rolling average basis
(Colorado Regulation No. 7, Section XVI.D.4.).
4.2.1 Stationary combustion turbines with a maximum design heat input capacity equal to
or greater than 10 MMBtu/hr and which commenced construction on or before
February 18, 2005 must comply with the applicable NOX emission limits in 40 CFR
Part 60, Subpart GG (July 1, 2017) (Colorado Regulation No. 7, Section
XVI.D.4.b.(i)). The following requirements from Subpart GG apply:
4.2.1.1 Electric utility stationary gas turbines with a heat input at peak load
greater than 100 MMBtu/hr based on the lower heating vale of the fuel
fired shall comply with the provisions of §60.332(a)(1) (40 CFR Part 60,
§60.332(b)), as follows:
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 11
a. No owner or operator shall cause to be discharged into the atmosphere
from any stationary gas turbine, any gases which contain NO. in
excess of:
STD = 0.0075 (14.4) +F
Y
Where:
STD = allowable ISO corrected (if required as given in 60.335(b)(1))
NO. emission concentration (percent by volume at 15 percent oxygen
and on a dry basis),
Y = manufacturer's rated heat rate at manufacturer's rated load
(kilojoules per watt hour) or, actual measured heat rate based on lower
heating value of fuel as measured at actual peak load for the facility.
The value of Y shall not exceed 14.4 kilojoules per watt hour, and
F = NO. emission allowance for fuel bound nitrogen as defined in
§60.332(a)(4).
4.2.2 Stationary combustion turbines must comply with the combustion process adjustment
requirements contained in Section XVI.D.6. while burning gaseous fuel, liquid fuel,
or any combination thereof, when required by Section XVI.D.6.a. (Colorado
Regulation No. 7, Section XVI.D.4.b.(iii)).
4.3 Compliance Demonstration. By October 1, 2021, the owner or operator of an affected unit
must determine compliance with the applicable emission limitations contained in Section
XVI.D.4. according to the applicable methods contained in this Section XVI.D.5. (Colorado
Regulation No. 7, Section XVI.D.5.).
4.3.1 Continuous emission monitoring (Colorado Regulation No. 7, Section XVI.5.a.(i))
4.3.1.1 Owners or operators of affected units subject to a NO. emission limit in
Section XVI.D.4.b. may install, operate and maintain a NO. CEMS or
CERMS to monitor compliance with the applicable emission limit in
accordance with this Section XVI.D.5.a.(i) in lieu of performance testing
pursuant to Section XVI.D.5.a.(ii). (Colorado Regulation No. 7, Section
XVI.D.5.a.(i)).
a. The owner or operator of an affected unit that is subject to or becomes
subject to the monitoring requirements of 40 CFR part 75 and 40 CFR
part 75, Appendices A to I, must use those monitoring methods and
specifications for monitoring NO. emissions for purposes of this
Section XVI.D.5. and for demonstrating compliance with Section
XVI.D.4. The missing data substitution procedures and bias
adjustment requirements of 40 CFR Part 75 do not apply for purposes
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 12
of demonstrating compliance with Section XVI.D.4. or this Section
XVI.D.5. (Colorado Regulation No. 7, Section XVI.D.5.a.(i)(A)(1)).
b. For an affected unit that is not equipped with a NO, CEMS or CERMS
for purposes of demonstrating compliance with 40 CFR Part 60 or Part
75, the owner or operator must install, operate, and maintain a NO),
CEMS or CERMS that measures emissions in terms of the applicable
emission limitation and must calibrate, maintain, and operate the
CEMS or CERMS and validate emissions data according to the
applicable provisions of 40 CFR Part 60, Section 60.13, the
performance specifications in 40 CFR Part 60, Appendix B, and the
quality assurance procedures of 40 CFR Part 60, Appendix F. The
owner or operator must use the following methodology for purposes of
demonstrating compliance with an applicable 30 -day rolling average
emission limit in Section XVI.D.4. (Colorado Regulation No. 7,
Section XVI.D.5.a.(i)(A)(3)):
(i) A unit operating day is a calendar day when any fuel is combusted
in the affected unit (Colorado Regulation No. 7, Section
XVI.D.5.a.(i)(A)(3)(a)).
(ii) 30 -day rolling average emission rates must be calculated as the
arithmetic average emissions rates determined by the CEMS or
CERMS for all hours the affected unit combusted any fuel from
the current unit operating day and the prior 29 unit operating days
(Colorado Regulation No. 7, Section XVI.D.5.a.(i)(A)(3)(b)).
4.3.2 Initial and periodic performance testing (Colorado Regulation No. 7, Section
XVI.D.5.a.(ii))
4.3.2.1 Except as otherwise provided for in Section XVI.D.5.a.(ii)(A), the owner
or operator of an affected unit subject to a NOx emission limitation
contained in Section XVI.D.4.b. that is not equipped with NOx CEMS or
CERMS, must conduct an initial performance test and subsequent
performance tests every 2 years thereafter, according to the following
requirements, as applicable, to determine the affected unit's NOx emission
rate for each fuel fired in the affected unit. A performance test is not
required for a fuel used only for startup or for a fuel constituting less than
2% of the unit's annual heat input, as determined at the end of each
calendar year (Colorado Regulation No. 7, Section XVI.D.5.a.(ii)(B)).
a. Initial performance test must include a determination of the capacity
load point of the unit's maximum NOx emissions rate based on one 30
minute test run at each capacity load point for which the unit is
operated, other than for startup and shutdown, in the load ranges of 20
to 30%, 45 to 55%, and 70 to 100%. Subsequent performance tests
must be performed within the capacity load range determined to result
Operating Permit # 96OPWE154
First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 13
in the maximum NOx emissions rate (Colorado Regulation No. 7,
Section XVI.D.5.a.(ii)(B)(1)).
b. Performance tests must determine compliance with Section XVI.D.4.
based on the average of three 60 -minute test runs performed at the
capacity load determined in XVI.D.5.a.(ii)(B)(1) (Colorado Regulation
No. 7, Section XVI.D.5.a.(ii)(B)(2)).
4.3.2.2 All performance tests must be conducted in accordance with EPA test
methods and a test protocol submitted to the Division for review at least
thirty (30) days prior to testing and in accordance with AQCC Common
Provisions Regulation Section II.C. (Colorado Regulation No. 7, Section
XVI.D.5.a.(ii)(C)).
4.3.3 Where measuring fuel use is necessary to calculate an emission rate in the units of the
applicable standard, fuel flowmeters must be installed, calibrated, maintained, and
operated according to manufacturer's instructions for measuring and recording heat
input in terms of the applicable emission limitation. Alternatively, fuel flowmeters
that meet the installation, certification, and quality assurance requirements of 40 CFR
Part 75, Appendix D are acceptable for demonstrating compliance with this section.
The installation of fuel flowmeters is not required where emissions of NOx in terms
of the applicable standard can be calculated in accordance with applicable provisions
of EPA Method 19 or where the standard is concentration based (e.g. parts per million
dry volume corrected for oxygen) (Colorado Regulation No. 7, Section
XVI.D.5.a.(iv)).
4.4 Combustion process adjustment (Colorado Regulation No. 7, Section XVI.D.6.) Note that this
section, in accordance with Section XVI.D.6.a., applies to turbines with uncontrolled actual
emissions of NO,, equal to or greater than five (5) tons per year.
4.4.1 The owner or operator of a stationary combustion turbine must conduct the following
inspections and adjustments, as applicable (Colorado Regulation No. 7, Section
XVI.D.6.b.(iii)):
4.4.1.1 Inspect turbine inlet systems and align, repair, or replace components as
necessary (Colorado Regulation No. 7, Section XVI.D.6.b.(iii)(A)).
4.4.1.2 Inspect the combustion chamber components, combustion liners, transition
pieces, and fuel nozzle assemblies and clean, repair, or replace
components as necessary (Colorado Regulation No. 7, Section
XVI.D.6.b.(iii)(B)).
4.4.1.3 When burning the fuel that provides the majority of the heat input since
the last combustion process adjustment and when operating at a firing rate
typical of normal operation, confirm proper setting and calibration of the
combustion controls (Colorado Regulation No. 7, Section
XVI.D.6.b.(iii)(C)).
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 14
4.4.2 The Source must operate and maintain the stationary combustion turbines consistent
with manufacturer's specifications, if available, or good engineering and maintenance
practices (Colorado Regulation No. 7, Section XVI.D.6.b.(v)).
4.4.3 Frequency (Colorado Regulation No. 7, Section XVI.D.6.b.(vi))
4.4.3.1 The owner or operator must conduct the initial combustion process
adjustment by April 1, 2017. An owner or operator may rely on a
combustion process adjustment conducted in accordance with applicable
requirements and schedule of a New Source Performance Standard in 40
CFR Part 60 or National Emission Standard for Hazardous Air Pollutants
in 40 CFR Part 63 to satisfy the requirement to conduct an initial
combustion process adjustment by April 1, 2017 (Colorado Regulation
No. 7, Section XVI.D.6.b.(vi)(A)).
4.4.3.2 The owner or operator must conduct subsequent combustion process
adjustments at least once every twelve (12) months after the initial
combustion adjustment, or on the applicable schedule according to
Sections XVI.D.6.c.(i) and (ii) (Colorado Regulation No. 7, Section
XVI.D.6.b.(vi)(B)).
4.4.4 As an alternative to the requirements described in Sections XVI.D.6.b.(i) through
XVI.D.6.b.(v) (Colorado Regulation No. 7, Section XVI.D.6.c.):
4.4.4.1 The owner or operator may conduct the combustion process adjustment
according to the manufacturer recommended procedures and schedule
(Colorado Regulation No. 7, Section XVI.D.6.c.(i)); or
4.4.4.2 The owner or operator of combustion equipment that is subject to and
required to conduct a period tune-up or combustion adjustment by the
applicable requirements of a New Source Performance Standard in 40
CFR Part 60 or National Emission Standard for Hazardous Air Pollutants
in 40 CFR Part 63 may conduct tune-ups or adjustments according to the
schedule and procedures of the applicable requirements of 40 CFR Part 60
or 40 CFR Part 63 (Colorado Regulation No. 7, Section XVI.D.6.c.(ii)).
4.5 Recordkeeping. The following records must be kept for a period of five years and made
available to the Division upon request (Colorado Regulation No. 7, Section XVI.D.7.):
4.5.1 The applicable emission limit and calculated heat input weighted emission limit for
stationary combustion equipment demonstrating compliance for multiple fuels
(Colorado Regulation No. 7, Section XVI.D.7.a.).
4.5.2 The 30 -day rolling average emission rate calculated on a daily basis for sources using
CERMS to comply with Section XVI.D (Colorado Regulation No. 7, Section
XVI.D.7.b.).
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 15
4.5.3 The type and amount of fuel used (Colorado Regulation No. 7, Section XVI.D.7.c.).
4.5.4 The stationary combustion equipment's annual capacity factor on a calendar year
basis (Colorado Regulation No. 7, Section XVI.D.7.d.).
4.5.5 All records generated to comply with the reporting requirements contained in Section
XVI.D.8 (Colorado Regulation No. 7, Section XVI.D.7.e.).
4.5.6 For stationary combustion equipment subject to the combustion process adjustment
requirements in Section XVI.D.6., the following recordkeeping requirements apply
(Colorado Regulation No. 7, Section XVI.D.7.f.):
4.5.6.1 The owner or operator must create a record once every calendar year
identifying the combustion equipment at the source subject to Section
XVI.D. and including for each combustion equipment (Colorado
Regulation No. 7, Section XVI.D.7.f.(i)):
a. The date of the adjustment (Colorado Regulation No. 7, Section
XVI.D.7.f.(i)(A));
b. Whether the combustion process adjustment under Sections
XVI.D.6.b.(i) through XVI.D.6.b.(v) was followed, and what
procedures were performed (Colorado Regulation No. 7, Section
XVI.D.7.f.(i)(B));
c. Whether a combustion process adjustment under Sections XVI.D.6.a.
and XVI.D.6.b. was followed, what procedures were performed, and
what New Source Performance or National Emission Standard for
Hazardous Air Pollutants applied, if any (Colorado Regulation No. 7,
Section XVI.D.7.f.(i)(C)); and
d. A description of any corrective action taken (Colorado Regulation No.
7, Section XVI.D.7.f.(i)(D)).
e. If the owner or operator conducts the combustion process adjustment
according to the manufacturer recommended procedures and schedule
and the manufacturer specifies a combustion process adjustment on an
operation time schedule, the hours of operation (Colorado Regulation
No. 7, Section XVI.D.7.f.(i)(E)).
f. If multiple fuels are used, the type of fuel burned and heat input
provided by each fuel (Colorado Regulation No. 7, Section
XVI.D.7.f.(i)(F)).
4.5.6.2 The owner or operator must retain manufacturer recommended
procedures, specifications, and maintenance schedule if utilized under
Section XVI.D.6.a. for the life of the equipment (Colorado Regulation No.
7, Section XVI.D.7.f.(ii)).
4.5.6.3 As an alternative to the requirements described in Section XVI.D.7.f.(i),
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 16
the owner or operator may comply with applicable recordkeeping
requirements related to combustion process adjustments conducted
according to a New Source Performance Standard in 40 CFR Part 60 or
National Emission Standard for Hazardous Air Pollutants in 40 CFR Part
63 (Colorado Regulation No. 7, Section XVI.D.7.f.(iii)).
4.5.7 All sources qualifying for an exemption under Section XVI.D.2. must maintain all
records necessary to demonstrate that an exemption applies (Colorado Regulation No.
7, Section XVI.D.7.g.).
4.6 Reporting (Colorado Regulation No. 7, Section XVI.D.8.)
4.6.1 For affected units demonstrating compliance with Section XVI.D.4. using CEMS or
CERMS in accordance with Section XVI.D.5.a.(i)(A), the owner or operator must
submit to the Division the following information (Colorado Regulation No. 7, Section
XVI.D.8.a.):
4.6.1.1 Quarterly or semi-annual excess emissions reports no later than the 30th
day following the end of each semi-annual or quarterly period, as
applicable. Excess emissions means emissions that exceed the applicable
limitations contained in Section XVI.D.4. Excess emission reports must
include the information specified in 40 CFR Part 60, Section 60.7(c) (July
1, 2018) (Colorado Regulation No. 7, Section XVI.D.8.a.(i)).
4.6.2 For affected units demonstrating compliance with Section XVI.D.4 using
performance testing pursuant to Section XVI.D.5.a.(ii)(C), the owner or operator
must submit to the Division the following information (Colorado Regulation No. 7,
Section XVI.D.8.b.):
4.6.2.1 Performance test reports within 60 days after completion of the
performance test program. All performance test reports must determine
compliance with the applicable emission limitations set by Section
XVI.D.4. (Colorado Regulation No. 7, Section XVI.D.8.b.(i)).
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
SECTION III - Permit Shield
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 17
Regulation No. 3, 5 CCR 1001-5, Part C, §& I.A.4, V.D. & XIII.B; § 25-7-114.4(3)(a), C.R.S.
1. Specific Non -Applicable Requirements
Based on the information available to the Division and supplied by the applicant, the following
parameters and requirements have been specifically identified as non -applicable to the facility to which
this permit has been issued. This shield does not protect the source from any violations that occurred
prior to or at the time of permit issuance. In addition, this shield does not protect the source from any
violations that occur as a result of any modifications or reconstruction on which construction
commenced prior to permit issuance.
Emission Unit
Description & Number
Applicable Requirement
Justification
Facility
Colorado Regulation 7, Subsection
V.B
This regulation does not apply as the source does not
store or dispense gasoline.
Facility
Colorado Regulation 7, Paragraphs
VI.B.1 and 2
This regulation is not applicable as the source stores
Nos. 1 and/or 2 fuel oil and is exempt (per
VI.B.1.a.(ii)) from these requirements.
Facility
Colorado Regulation 7, Subsection
VII.C
This regulation does not apply as the source does not
store crude oil.
Facility
40 CFR Part 60, Subpart GG (as
adopted by reference in Colorado
Regulation 6)
This regulation is not applicable as the turbines were
constructed prior to October 3, 1977.
Facility
Prevention of Significant
Deterioration Requirements -
Colorado Regulation 3, Part D,
Section VI
These requirements are not applicable as the facility
was constructed prior to August 7, 1977.
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 # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 18
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. Stream -lined 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.
No conditions have been streamlined in this Operating Permit.
Operating Permit # 96OPWE154
First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 19
SECTION I - General Permit Conditions (version 8/28/2018)
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.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.
b. Emission Monitoring Requirements
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 20
The Division may require owners or operators of stationary air pollution sources to install, maintain, and use
instrumentation to monitor and record emission data as a basis for periodic reports to the Division.
c. Performance Testing
The owner or operator of any air pollution source shall, upon request of the Division, conduct performance test(s)
and furnish the Division a written report of the results of such test(s) in order to determine compliance with
applicable emission control regulations.
Performance test(s) shall be conducted and the data reduced in accordance with the applicable reference test
methods unless the Division:
(i) specifies or approves, in specific cases, the use of a test method with minor changes in methodology;
(ii) approves the use of an equivalent method;
(iii) approves the use of an alternative method the results of which the Division has determined to be adequate
for indicating where a specific source is in compliance; or
(iv) waives the requirement for performance test(s) because the owner or operator of a source has demonstrated
by other means to the Division's satisfaction that the affected facility is in compliance with the standard.
Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to
require testing under the Colorado Revised Statutes, Title 25, Article 7, and pursuant to regulations
promulgated by the Commission.
Compliance test(s) shall be conducted under such conditions as the Division shall specify to the plant operator based
on representative performance of the affected facility. The owner or operator shall make available to the Division
such records as may be necessary to determine the conditions of the performance test(s). Operations during period of
startup, shutdown, and malfunction shall not constitute representative conditions of performance test(s) unless
otherwise specified in the applicable standard.
The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance
test to afford the Division the opportunity to have an observer present. The Division may waive the thirty day notice
requirement provided that arrangements satisfactory to the Division are made for earlier testing.
The owner or operator of an affected facility shall provide, or cause to be provided, performance testing facilities as
follows:
(i) Sampling ports adequate for test methods applicable to such facility;
(ii) Safe sampling platform(s);
(iii) Safe access to sampling platform(s); and
(iv) Utilities for sampling and testing equipment.
Each performance test shall consist of at least three separate runs using the applicable test method. Each run shall be
conducted for the time and under the conditions specified in the applicable standard. For the purpose of determining
compliance with an applicable standard, the arithmetic mean of results of at least three runs shall apply. In the event
that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of
forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other
circumstances beyond the owner or operator's control, compliance may, upon the Division's approval, be
determined using the arithmetic mean of the results of the two other runs.
Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s) if so warranted.
Operating Permit # 96OPWE154
First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 21
d. Affirmative Defense Provision for Excess Emissions during Malfunctions
An affirmative defense to a claim of violation under these regulations is provided to owners and operators for civil
penalty actions for excess emissions during periods of malfunction. To establish the affirmative defense and to be
relieved of a civil penalty in any action to enforce an applicable requirement, the owner or operator of the facility
must meet the notification requirements below in a timely manner and prove by a preponderance of evidence that:
(i)
The excess emissions were caused by a sudden, unavoidable breakdown of equipment, or a sudden,
unavoidable failure of a process to operate in the normal or usual manner, beyond the reasonable control of
the owner or operator;
(ii) The excess emissions did not stem from any activity or event that could have reasonably been foreseen and
avoided, or planned for, and could not have been avoided by better operation and maintenance practices;
(iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being
exceeded;
(iv) The amount and duration of the excess emissions (including any bypass) were minimized to the maximum
extent practicable during periods of such emissions;
(v) All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air
quality;
(vi) All emissions monitoring systems were kept in operation (if at all possible);
(vii) The owner or operator's actions during the period of excess emissions were documented by properly
signed, contemporaneous operating logs or other relevant evidence;
(viii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation, or
maintenance;
(ix) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions.
This section is intended solely to be a factor in determining whether an affirmative defense is available to
an owner or operator, and shall not constitute an additional applicable requirement; and
(x) During the period of excess emissions, there were no exceedances of the relevant ambient air quality
standards established in the Commissions' Regulations that could be attributed to the emitting source.
The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division
verbally as soon as possible, but no later than noon of the Division's next working day, and shall submit written
notification following the initial occurrence of the excess emissions by the end of the source's next reporting period.
The notification shall address the criteria set forth above.
The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief.
The Affirmative Defense Provision does not apply to failures to meet federally promulgated performance standards
or emission limits, including, but not limited to, new source performance standards and national emission standards
for hazardous air pollutants. The affirmative defense provision does not apply to state implementation plan (sip) limits
or permit limits that have been set taking into account potential emissions during malfunctions, including, but not
necessarily limited to, certain limits with 30 -day or longer averaging times, limits that indicate they apply during
malfunctions, and limits that indicate they apply at all times or without exception.
e. Circumvention Clause
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
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 22
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
g.
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.
Affirmative Defense Provision for Excess Emissions During Startup and Shutdown
An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during
periods of startup and shutdown. To establish the affirmative defense and to be relieved of a civil penalty in any
action to enforce an applicable requirement, the owner or operator of the facility must meet the notification
requirements below in a timely manner and prove by a preponderance of the evidence that:
(i)
The periods of excess emissions that occurred during startup and shutdown were short and infrequent and
could not have been prevented through careful planning and design;
(ii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation or
maintenance;
(iii) If the excess emissions were caused by a bypass (an intentional diversion of control equipment), then the
bypass was unavoidable to prevent loss of life, personal injury, or severe property damage;
(iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum
extent practicable;
(v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality;
(vi) All emissions monitoring systems were kept in operation (if at all possible);
(vii) The owner or operator's actions during the period of excess emissions were documented by properly
signed, contemporaneous operating logs or other relevant evidence; and,
(viii) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions.
This subparagraph is intended solely to be a factor in determining whether an affirmative defense is
available to an owner or operator, and shall not constitute an additional applicable requirement.
The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the
Division verbally as soon as possible, but no later than two (2) hours after the start of the next working day, and shall
submit written quarterly notification following the initial occurrence of the excess emissions. The notification shall
address the criteria set forth above.
The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief
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
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 23
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:
g.
(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.
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.
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
5. Emergency Provisions
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 24
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.
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
Operating Permit # 96OPWE154
First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 25
Regulation No. 1, 5 CCR 1001-3, § III.D.1.
The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate
emissions into the atmosphere, in accordance with the provisions of Regulation No. 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, §§ X. & XI.
The permittee shall submit an application for a minor permit modification before making the change requested in the
application. The permit shield shall not extend to minor permit modifications.
12. New Source Review
Regulation No. 3, 5 CCR 1001-5, Parts B & D
The permittee shall not commence construction or modification of a source required to be reviewed under the New Source
Review provisions of Regulation No. 3, Parts B and/or D, as applicable, without first receiving a construction permit.
13. No Property Rights Conveyed
Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.11.d.
This permit does not convey any property rights of any sort, or any exclusive privilege.
14. Odor
Regulation No. 2, 5 CCR 1001-4, Part A
As a matter of state law only, the permittee shall comply with the provisions of Regulation No. 2 concerning odorous emissions.
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.
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 26
16. Opacity
Regulation No. 1, 5 CCR 1001-3, §§ I., II.
The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1, §§ I.- II.
17. Open Burning
Regulation No. 9, 5 CCR 1001-11
The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions
of Regulation No. 9.
18. Ozone Depleting Compounds
Regulation No. 15, 5 CCR 1001-19
The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds.
Sections I., II.C., ILD., III. IV., and V. of Regulation No. 15 shall be enforced as a matter of state law only.
19. Permit Expiration and Renewal
Regulation No. 3, 5 CCR 1001-5, Part C, §§ III.B.6., IV.C., V.C.2.
a. The permit term shall be five (5) years. The permit shall expire at the end of its term. Permit expiration terminates
the permittee's right to operate unless a timely and complete renewal application is submitted.
b. Applications for renewal shall be submitted at least twelve months, but not more than 18 months, prior to the
expiration of the Operating Permit. An application for permit renewal may address only those portions of the permit
that require revision, supplementing, or deletion, incorporating the remaining permit terms by reference from the
previous permit. A copy of any materials incorporated by reference must be included with the application.
20. Portable Sources
Regulation No. 3, 5 CCR 1001-5, Part C, § II.D.
Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in location.
21. Prompt Deviation Reporting
Regulation No. 3, 5 CCR 1001-5, Part C, & V.C.7.b.
The permittee shall promptly report any deviation from permit requirements, including those attributable to malfunction
conditions as defined in the permit, the probable cause of such deviations, and any corrective actions or preventive measures
taken.
"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;
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorad
Ft. Lupton Combustion Turbin s
Page 27
(ii) For emissions of any regulated air pollutant, excluding a hazardous air pollutant or a toxic air pollutant tha
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 avoid
enforcement actions.
22. Record Keeping and Reporting Requirements
Regulation No. 3, 5 CCR 1001-5, Part A, .* II.; Part C, §§ V.C.6., V.C.7.
a. Unless otherwise provided in the source specific conditions of this Operating Permit, the permittee shall maintain
compliance monitoring records that include the following information:
(i) date, place as defined in the Operating Permit, and time of sampling or measurements;
(ii) date(s) on which analyses were performed;
(iii) the company or entity that performed the analysis;
(iv) the analytical techniques or methods used;
(v) the results of such analysis; and
(vi) the operating conditions at the time of sampling or measurement.
b. The permittee shall retain records of all required monitoring data and support information for a period of at least fiv4
(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 ever
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, §
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 28
II.C.2., occurs; whenever there is a change in owner or operator of any facility, process, or activity; whenever new
control equipment is installed; whenever a different type of control equipment replaces an existing type of control
equipment; whenever a permit limitation must be modified; or before the APEN expires. An APEN is valid for a
period of five years. The five-year period recommences when a revised APEN is received by the Air Pollution
Control Division. Revised APENs shall be submitted no later than 30 days before the five-year term expires.
Permittees submitting revised APENs to inform the Division of a change in actual emission rates must do so by
April 30 of the following year. Where a permit revision is required, the revised APEN must be filed along with a
request for permit revision. APENs for changes in control equipment must be submitted before the change occurs.
Annual fees are based on the most recent APEN on file with the Division.
23. Reopenings for Cause
Regulation No. 3, 5 CCR 1001-5, Part C, § XIII.
a. The Air Pollution Control Division shall reopen, revise, and reissue Operating Permits; permit reopenings and
reissuance shall be processed using the procedures set forth in Regulation No. 3, Part C, § III., except that
proceedings to reopen and reissue permits affect only those parts of the permit for which cause to reopen exists.
b. The Division shall reopen a permit whenever additional applicable requirements become applicable to a major
source with a remaining permit term of three or more years, unless the effective date of the requirements is later than
the date on which the permit expires, or unless a general permit is obtained to address the new requirements;
whenever additional requirements (including excess emissions requirements) become applicable to an affected
source under the acid rain program; whenever the Division determines the permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other terms or conditions of the permit;
or whenever the Division determines that the permit must be revised or revoked to assure compliance with an
applicable requirement.
c. The Division shall provide 30 days' advance notice to the permittee of its intent to reopen the permit, except that a
shorter notice may be provided in the case of an emergency.
d. The permit shield shall extend to those parts of the permit that have been changed pursuant to the reopening and
reissuance procedure.
24. Requirements for Major Stationary Sources
Regulation No. 3, 5 CCR 1001-5, Part D, §§ V.A.7.c & d, VI.B.5 & VI.B.6
The following provisions apply to projects at existing emissions units at a major stationary source (other than projects at a
source with a PAL) that are not part of a major modification and where the owner or operator relies on projected actual
emissions. The definitions of baseline actual emissions, major modification, major stationary source, PAL, projected actual
emissions, regulated NSR pollutant and significant can be found in Regulation No. 3, Part D, § II.A.
a. Before beginning actual construction of the project, the owner or operator shall document and maintain a record of
the following information:
(i) a description of the project;
(ii) identification of the emissions unit(s) whose emissions of a regulated NSR pollutant could be affected by
the project; and
(iii) a description of the applicability test used to determine the project is not a major modification for any
regulated NSR pollutants, including the baseline actual emissions, the projected actual emissions, the
amount of emissions excluded and an explanation for why such amount was excluded, and any netting
calculations, if applicable.
Operating Permit # 96OPWE154
First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 29
b. The owner or operator shall monitor emissions of any regulated NSR pollutant that could increase as a result of the
project from any emissions units identified in paragraph a.(ii) and calculate and maintain a record of the annual
emissions, in tons per year on a calendar year basis, for a period of five (5) years following resumption of regular
operation after the change, or for a period of ten (10) years following resumption of regular operation after the
change if the project increases the design capacity or potential to emit of that regulated NSR pollutant at such
emissions unit.
c. For existing electric utility steam generating units the following requirements apply:
(i)
Before beginning actual construction, the owner or operator shall provide a copy of the information
required by paragraph a above to the Division. The owner or operator is not required to obtain a
determination from the Division prior to beginning actual construction.
(ii) The owner or operate shall submit a report to the Division within sixty days after the end of each year
during which records must be generated under paragraph b above setting out the unit's annual emissions
during the calendar year that preceded submission of the report.
d. For existing emissions units that are not electric utility steam generating units, the owner or operator shall submit a
report to the Division if the annual emissions from the project, in tons per year, exceed the baseline actual emissions
(documented and maintained per paragraph a(iii)) by a significant amount for that regulated NSR pollutant, and if
such emissions differ from the preconstruction projection (documented and maintained per paragraph a.(iii)). Such
report shall be submitted to the Division within sixty days after the end of such year. The report shall contain the
following:
(i) The name, address and telephone number of the owner or operator;
(ii) The annual emissions as calculated per paragraph b; and
(iii) Any other information that the owner or operator wishes to include in the report.
e. The owner of operation of the source shall make the information in paragraph a available for review upon request to
the Division or the general public.
25. Section 502(b)(10) Changes
Regulation No. 3, 5 CCR 1001-5, Part C, $ XII.A.
The permittee shall provide a minimum 7 -day advance notification to the Air Pollution Control Division and to the
Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permittee shall attach a copy of
each such notice given to its Operating Permit.
26. 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.
27. Significant Permit Modifications
Regulation No. 3, 5 CCR 1001-5, Part C, . III.B.2.
The permittee shall not make a significant modification required to be reviewed under Regulation No. 3, Part B ("Construction
Permit" requirements) without first receiving a construction permit. The permittee shall submit a complete Operating Permit
application or application for an Operating Permit revision for any new or modified source within twelve months of
commencing operation, to the address listed in Item 1 in Appendix D of this permit. If the permittee chooses to use the
Operating Permit # 96OPWE154
First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 30
"Combined Construction/Operating Permit" application procedures of Regulation No. 3, Part C, then the Operating Permit
must be received prior to commencing construction of the new or modified source.
28. Special Provisions Concerning the Acid Rain Program
Regulation No. 3, 5 CCR 1001-5, Part C, §§ V.C.1.b. & 8
a. Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations
promulgated under Title IV of the federal act, 40 Code of Federal Regulations (CFR) Part 72, both provisions shall
be incorporated into the permit and shall be federally enforceable.
b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal act or the
regulations promulgated thereunder, 40 CFR Part 72, are expressly prohibited.
29. Transfer or Assignment of Ownership
Regulation No. 3, 5 CCR 1001-5, Part C, II.C.
No transfer or assignment of ownership of the Operating Permit source will be effective unless the prospective owner or
operator applies to the Air Pollution Control Division on Division -supplied Administrative Permit Amendment forms, for
reissuance of the existing Operating Permit. No administrative permit shall be complete until a written agreement containing
a specific date for transfer of permit, responsibility, coverage, and liability between the permittee and the prospective owner or
operator has been submitted to the Division.
30. Volatile Organic Compounds
Regulation No. 7, 5 CCR 1001-9, §§ 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.
31. Wood Stoves and Wood burning Appliances
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 96OPWE154
Public Service Company of Colorado
Ft. Lupton Combustion Turbines
Page 31
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 # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Appendices
Operating Permit Appendices
Appendix A — Inspection Information
Appendix B — Monitoring and Permit Deviation Report
Appendix C — Compliance Certification Report
Appendix D — Notification Addresses
Appendix E — Permit Acronyms
Appendix F — Permit Modifications
Platte River Power Authority
Rawhide Energy Station Turbines
Page 32
DISCLAIMER: None of the information found in these Appendices shall be considered to be State or
Federally enforceable, except as otherwise provided in the permit, and is presented to assist the source,
permitting authority, inspectors, and citizens.
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Inspection Information
Appendix A
Page 33
A. Appendix A - Inspection Information
A.I. Directions to Plant:
From Interstate 76, take highway 85 north past Fort Lupton to Weld County Road 16. Turn east on
Road 16 and travel 2 miles to the substation, on the south side of Road 16.
A.II. Safety Equipment Required:
Eye Protection; Hard Hat; Hearing Protection; Safety Shoes
A.III. Facility Plot Plan:
Figure 1 (following page) shows the plot plan as submitted on October 30, 2012 with the source's
Title V Renewal Operating Permit Application.
A.IV. 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.
For insignificant activities marked with an asterisk (*) the owner or operator must maintain
sufficient recordkeeping to verify that the exemption applies (i.e., annual throughput is less than
400,000 gallons). Such records shall be made available for Division review upon request (Colorado
Regulation No. 3, Part C, Section II.E).
A.IV.1. Units with emission less than APEN de minimis (Reg 3, Part C.II.E.3.a)*
A.IV.I.i. Natural gas venting and equipment leaks (VOC emissions < 1 ton/yr)
A.IV.1.ii. Use of cleaners and solvents in equipment maintenance (VOC emissions < 1
ton/yr)
A.IV.1.iii. Fugitive emissions from roads (PM emissions < 1 ton/yr)
A.IV.2. Fuel burning equipment less than 10 MMBtu/hr - for heating (Reg 3, Part C.II.E.3.ggg)
A.IV.2.i. Office space heater
A.IV.3. Storage tanks with annual throughput less than 400,000 gal (Reg 3 Part C.II.E.3.fff)*
A.IV.3.i. Diesel fuel storage tank (216,000 gal aboveground)
A.IV.4. Not an emission source and/or not a source of regulated/reportable emissions
A.IV.4.i. Three (3) spill containment underground tanks (1,000 gal each)
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed: 'J
Air Pollution Control Division
Colorado Operating Permit
Inspection Information
A.IV.4.ii. Two (2) water tanks (approx. 20,000 gal aboveground, each)
A.IV.4.iii. Turbine lube oil vents
Appendix A
Page 34
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Inspection Information
89
Figure 1: Facility Piot Plan
Ft. Lupton Combustion Turbines
Appendix A
Page 3i5
Operating Permit # 96OPWE154
First Issued: May 20, 1997
Renewed Il iil' °ltr7["
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix B
Page 36
B. Appendix B — Reporting Requirements and Definitions
Version 8/20/2014, with codes
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 Source must comply with all conditions of this operating permit. Any permit noncompliance
constitutes a violation of the Act and is grounds for enforcement action; for permit termination,
revocation and reissuance, or modification; or for denial of a permit renewal application.
The Part 70 Operating Permit program requires three types of reports to be filed for all permits. All
required reports must be certified by a responsible official.
Report #1: Monitoring Deviation Report (due at least every six months)
For purposes of this operating permit, the Division is requiring that the monitoring reports are due
every six months unless otherwise noted in the permit. All instances of deviations from permit
monitoring requirements must be clearly identified in such reports.
For purposes of this operating permit, monitoring means any condition determined by observation, by
data from any monitoring protocol, or by any other monitoring which is required by the permit as well
as the recordkeeping associated with that monitoring. This would include, for example, fuel use or
process rate monitoring, fuel analyses, and operational or control device parameter monitoring.
Report #2: Permit Deviation Report (must be reported "promptly")
In addition to the monitoring requirements set forth in the permits as discussed above, each and every
requirement of the permit is subject to deviation reporting. The reports must address deviations from
permit requirements, including those attributable to malfunctions as defined in this Appendix, the
probable cause of 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.
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix B
Page 37
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:
2 = Process:
3 = Monitor:
4 = Test:
5 = Maintenance:
6 = Record:
7 = Report:
8 = CAM:
9 = Other:
When the requirement is an emission limit or standard
When the requirement is a production/process limit
When the requirement is monitoring
When the requirement is testing
When required maintenance is not performed
When the requirement is recordkeeping
When the requirement is reporting
A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the
Compliance Assurance Monitoring (CAM) Rule) has occurred.
When the deviation is not covered by any of the above categories
Report #3: Compliance Certification (annually, as defined in the permit)
Submission of compliance certifications with terms and conditions in the permit, including emission
limitations, standards, or work practices, is required not less than annually.
Compliance Certifications are intended to state the compliance status of each requirement of the permit
over the certification period. They must be based, at a minimum, on the testing and monitoring
methods specified in the permit that were conducted during the relevant time period. In addition, if the
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix B
Page 38
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.
' 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 # 96OPWE154
First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix B
Page 39
Startup, Shutdown, Malfunctions and Emergencies,
Understanding the application of Startup, Shutdown, Malfunctions and Emergency Provisions, is very important
in both the deviation reports and the annual compliance certifications.
Startup, Shutdown, and Malfunctions
Please note that exceedances of some New Source Performance Standards (NSPS) and Maximum Achievable
Control Technology (MACT) standards that occur during Startup, Shutdown or Malfunctions may not be
considered to be non-compliance since emission limits or standards often do not apply unless specifically stated
in the NSPS. Such exceedances must, however, be reported as excess emissions per the NSPS/MACT rules and
would still be noted in the deviation report. In regard to compliance certifications, the permittee should be
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 # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
B.I. Appendix B — Monitoring and Permit Deviation Report - Part I
B.I.1.
Appendix B
Page 40
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.
B.I.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. Lupton Combustion Turbines
OPERATING PERMIT NO: 96OP WE 154
REPORTING PERIOD: (see first page of the permit for specific reporting period and dates)
Emission Unit
Facility ID
Unit Description
Deviations noted
During Period?�
Deviation Code 2
Malfunction/Emergency
Condition Reported
During Period?
YES
NO
r ' mr_
YES
NO
T001
General Electric Combustion Turbine,
Model MS7000B, Serial No. 217708,
rated at 662.6 MMBtu/hr (NG) and 656
MMBtu/hr (FO). Fueled by Natural
Gas, Nos. 1 and/or 2 Fuel Oil, or
Combination.
T002
General Electric Combustion Turbine,
Model MS7000C, Serial No. 217709,
rated at 662.6 MMBtu/hr (NG) and 656
MMBtu/hr (FO). Fueled by Natural
Gas, Nos. 1 and/or 2 Fuel Oil, or
Combination.
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.
2 Use the following entries, as appropriate
1= Standard:
2 = Process:
3 = Monitor:
4 = Test:
When the requirement is an emission limit or standard
When the requirement is a production/process limit
When the requirement is monitoring
When the requirement is testing
Operating Permit # 96OPWE154
First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
5 = Maintenance:
6 = Record:
7 = Report:
8=CAM:
9 = Other:
Appendix B
Page 41
When required maintenance is not performed
When the requirement is recordkeeping
When the requirement is reporting
A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the
Compliance Assurance Monitoring (CAM) Rule) has occurred.
When the deviation is not covered by any of the above categories
Operating Permit # 96OPWE154
First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
B.II. Appendix B — Monitoring and Permit Deviation Report - Part II
Appendix B
Page 42
FACILITY NAME: Public Service Company of Colorado — Ft. Lupton Combustion Turbines
OPERATING PERMIT NO: 96OPWE 154
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 # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
EXAMPLE
FACILITY NAME: U.S.S. Enterprise
OPERATING PERMIT NO: 64OPZZXXX
REPORTING PERIOD: 1/1/2369 - 6/30/2369
Appendix B
Page 43
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:
Holodeck generator with nanobot-repaired filtration system — Unit TNG
Operating Permit Condition Number Citation
Section II, Condition 3.1 - Opacity Limitation
Explanation of Period of Deviation
Tribbles in the console
Duration
START- 1730 4/10/2369
END- 1800 4/10/2369
Action Taken to Correct the Problem
Transported Tribbles to Klingon vessel.
Measures Taken to Prevent Reoccurrence of the Problem
Permanent ban of Tribbles as pets. Increased structural integrity of console.
Dates of Malfunction/Emergencies Reported (if applicable)
5/30/2369 to J.L. Picard, APCD
Deviation Code Division Code QA:
Operating Permit # 96OPWE154
First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix B
Page 44
B.III. Appendix B — Monitoring and Permit Deviation Report - Part III
REPORT CERTIFICATION
SOURCE NAME: Public Service Company of Colorado — Ft. Lupton Combustion Turbines
FACILITY IDENTIFICATION NUMBER: 123/0014
PERMIT NUMBER: 96OPWE 154
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 # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix C
Page 45
C. Appendix C — Required Format for Annual Compliance Certification
Reports
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. Lupton Combustion Turbines
OPERATING PERMIT NO: 96OP WE 154
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.
Emission Unit
Facility ID
Unit Description
Deviations
Reported 1
Mopitoring
Method per
Permit?2
Was compliance
continuous or
intermittent?3
Previous
Current
YES
NO
YES
NO
T001
General Electric Combustion Turbine,
Model MS7000B, Serial No. 217708,
rated at 662.6 MMBtu/hr (NG) and 656
MMBtu/hr (FO). Fueled by Natural
Gas, Nos. 1 and/or 2 Fuel Oil, or
Combination.
T002
General Electric Combustion Turbine,
Model MS7000C, Serial No. 217709,
rated at 662.6 MMBtu/hr (NG) and 656
MMBtu/hr (FO). Fueled by Natural
Gas, Nos. 1 and/or 2 Fuel Oil, or
Combination.
General Conditions
Insignificant Activities4
1 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.
Operating Permit # 96OPWE154
First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix C
Page 46
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.
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
requirements of section 112(r).
is is not in compliance with all the
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
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix C
Page 47
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 # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix D
Page 48
D. Appendix D — Notification Addresses
D.I. Air Pollution Control Division
Colorado Department of Public Health and Environment
Air Pollution Control Division
Operating Permits Unit
APCD-SS-Bl
4300 Cherry Creek Drive S.
Denver, CO 80246-1530
ATTN: Matt Burgett
D.II. United States Environmental Protection Agency
Compliance Notifications:
Office of Enforcement and Compliance Assurance
Mail Code 8ENF-AT
U.S. Environmental Protection Agency, Region VIII
1595 Wynkoop Street
Denver, CO 80202-1129
502(b)(10) Changes, Off Permit Changes:
Air and Radiation Division
Mail Code 8P -AR
U.S. Environmental Protection Agency, Region VIII
1595 Wynkoop Street
Denver, CO 80202-1129
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit Acronyms
Appendix E
Page 49
E. Appendix E — Permit Acronyms
Listed Alphabetically:
AIRS - Aerometric Information Retrieval System
AP -42 - EPA Document Compiling Air Pollutant Emission Factors
APEN - Air Pollution Emission Notice (State of Colorado)
APCD - Air Pollution Control Division (State of Colorado)
ASTM - American Society for Testing and Materials
BACT - Best Available Control Technology
BTU - British Thermal Unit
CAA - Clean Air Act (CAAA = Clean Air Act Amendments)
CCR - Colorado Code of Regulations
CEM - Continuous Emissions Monitor
CF - Cubic Feet (SCF = Standard Cubic Feet)
CFR - Code of Federal Regulations
CO - Carbon Monoxide
COM - Continuous Opacity Monitor
CRS - Colorado Revised Statute
EF - Emission Factor
EPA - Environmental Protection Agency
FI - Fuel Input Rate in MMBtu/hr
FR - Federal Register
G - Grams
Gal - Gallon
GPM - Gallons per Minute
HAPs - Hazardous Air Pollutants
HP - Horsepower
HP -HR Horsepower Hour (G/HP-HR = Grams per Horsepower Hour)
LAER - Lowest Achievable Emission Rate
LBS - Pounds
M - Thousand
MM - Million
MMscf - Million Standard Cubic Feet
MMscfd - Million Standard Cubic Feet per Day
N/A or NA Not Applicable
NOx - Nitrogen Oxides
NESHAP - National Emission Standards for Hazardous Air Pollutants
NSPS - New Source Performance Standards
P - Process Weight Rate in Tons/Hr
PE - Particulate Emissions
PM - Particulate Matter
PMio - Particulate Matter Under 10 Microns
PSD - Prevention of Significant Deterioration
PTE - Potential To Emit
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit Acronyms
Appendix E
Page 50
RACT -
SCC -
SCF -
SIC -
SO2 -
TPY -
TSP -
VOC-
Reasonably Available Control Technology
Source Classification Code
Standard Cubic Feet
Standard Industrial Classification
Sulfur Dioxide
Tons Per Year
Total Suspended Particulate
Volatile Organic Compounds
Operating Permit # 96OPWE154 First Issued: May 20, 1997
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit Modifications
Appendix K
Page 51
F. Appendix F — Permit Modifications
DATE OF
REVISION
TYPE OF
REVISION
SECTION NUMBER,
CONDITION NUMBER
DESCRIPTION OF REVISION
Operating Permit # 96OPWE154
First Issued: May 20, 1997
Renewed:
TECHNICAL REVIEW DOCUMENT
For
RENEWAL OF OPERATING PERMIT 96OPWE154
Public Service Company of Colorado — Ft. Lupton Combustion Turbines
Weld County
Source ID 123/0014
Operating Permit Engineer:
Operating Permit Supervisor review:
Compliance Unit review:
I. Purpose
Nicholas Dummer
Matt Burgett
Grant McKercher
This document establishes the basis for decisions made regarding the applicable
requirements, emission factors, monitoring plan and compliance status of emission
units covered by the renewed Operating Permit for the Public Service Company of
Colorado — Ft. Lupton Combustion Turbines (herein, Source). The previous Operating
Permit for this facility was issued on August 1, 2013 and expired on August 1, 2018.
However, since a timely and complete renewal application was submitted, under
Colorado Regulation No. 3, Part C, Section IV.C all of the terms and conditions of the
existing permit shall not expire until the renewal Operating Permit is issued and any
previously extended permit shield continues in full force and operation.
This document is designed for reference during the review of the proposed permit by
the EPA, the public, and other interested parties. The conclusions made in this report
are based on information provided in the original application submitted on July 28,
2017, comments on the draft permit submitted on July 10, 2019, previous inspection
reports and various email correspondence, as well as telephone conversations with
the applicant. Please note that copies of the Technical Review Document for the
original permit and any Technical Review Documents associated with subsequent
modifications of the original Operating Permit may be found in the Division files as well
as on the Division website at www.colorado.qov/cdphe/airTitleV. This narrative is
intended only as an adjunct for the reviewer and has no legal standing.
Any revisions made to the underlying construction permits associated with this facility
made in conjunction with the processing of this operating permit application have been
reviewed in accordance with the requirements of Regulation No. 3, Part B,
Construction Permits, and have been found to meet all applicable substantive and
procedural requirements. This operating permit incorporates and shall be considered
to be a combined construction/operating permit for any such revision, and the
permittee shall be allowed to operate under the revised conditions upon issuance of
this operating permit without applying for a revision to this permit or for an additional or
revised construction permit.
II. Description of Source
123/0014 Page 1 of 6
Public Service Company of Colorado — Ft. Lupton Combustion Turbines
Operating Permit No. 96OPWE154
Technical Review Document —Operating Permit — Renewal No. 4
The Public Service Company of Colorado — Ft. Lupton Combustion Turbines (herein,
Source) is an unmanned electric power generating station that consists of two (2)
simple cycle combustion turbines nameplate rated at 100 megawatts of power on a
gross basis (total for both turbines). These turbines are fueled by natural gas, Nos. 1
and/or 2 fuel oil, or combination.
The facility is located approximately 2 miles east of Ft. Lupton in Weld county. This
facility is located in an area classified as attainment for all pollutants except ozone. It
is classified as non -attainment for ozone and is part of the 8 -hr Ozone Control Area as
defined in Regulation No. 7, Section II.A.1.
There are no affected states within 50 miles of the plant. Rocky Mountain National
Park and Rawah National Wilderness Area, both Federal Class I designated areas,
are within 100 kilometers of the plant.
This facility is categorized as a PSD major stationary source (potential to emit of PM,
PMio, SO2 NOx and CO > 250 tons per year). Future modifications at this facility
resulting in a significant net emissions increase (see Colorado Regulation No. 3, Part
D, Sections II.B.27 and 44) or a modification which is major by itself (potential to emit
> 250 tons per 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.
This source is categorized as a NANSR major stationary source (potential to emit of
NOx > 100 tons per 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.
There are no other Operating Permits associated with this facility for purposes of
determining applicability of NANSR and PSD review regulations.
Potential and actual emissions from the facility are as follows:
Pollutant
Potential to Emit —
100% Natural Gas
Potential to Emit —
100% Nos. 1 and/or 2
Fuel Oil
Actual Emissions —
Combination3
PM'
580
575
0.05
PMio1
580
575
0.05
SO22
4,644
4,597
0.11
NOx
2,032
5,057
9.2
CO
528
19
1.52
VOC
13.4
2.4
0.04
Total HAPS
5.94
2.13
De minimis
Highest Single
HAP4
4.12
1.61
De minimis
123/0014
Page 2 of 6
Public Service Company of Colorado — Ft. Lupton Combustion Turbines
Operating Permit No. 96OPWE154
Technical Review Document —Operating Permit — Renewal No. 4
'PTE, when burning any fuel, is based on the PM limit (0.1 Ibs/mmBtu) x design heat rate x 8760 hrs/yr.
PMto is assumed to equal PM. Heat input when burning NG is 662.6 mmBtu/hr and when burning FO is
656 mmBtu/hr.
2PTE, when burning any fuel, is based on the Reg 1 SO2 limit (0.8 lbs/mmBtu) x design heat rate x 8760
hrs/yr.
3Actual emissions identified in the table are for both turbines together and include both natural gas and fuel
oil combustion. These numbers were taken from the most recent inspection performed on May 7, 2019.
4Highest single HAP is formaldehyde.
Ill. Applicable Requirements
Accidental Release Program — 112(r)
Section 112(r) of the Clean Air Act mandates a new federal focus on the prevention of
chemical accidents. Sources subject to these provisions must develop and implement
risk management programs that include hazard assessment, a prevention program,
and an emergency response program. They must prepare and implement a Risk
Management Plan (RMP) as specified in the Rule
Based on the information provided by the Source, this facility is not subject to the
provisions of Section 112(r) of the Federal Clean Air Act.
Hazardous Air Pollutants (HAP)
The facility is a true minor source of HAP. See the Table above for the HAP potential
to emit.
Compliance Assurance Monitoring
The CAM provisions of 40 CFR Part 64 do not apply to sources in this Operating
Permit since there are no emission units with control devices used to achieve
compliance with an emissions limitation or standard and have pre -control emissions
over the major source threshold.
40 CFR Part 60, Subpart GG — Standards of Performance for Stationary Gas Turbines
The requirements of NSPS GG do not apply to the combustion turbines at the facility
because they were constructed in 1972 and modified in 1975; the applicability date for
NSPS GG is October 3, 1977. As such the turbines are exempt from NSPS GG.
40 CFR Part 60, Subpart KKKK — Standards of Performance for Stationary
Combustion Turbines
The requirements of NSPS KKKK do not apply to the combustion turbines at the
facility because they were constructed in 1972 and modified in 1975; the applicability
date for NSPS KKKK is February 18, 2005. As such the turbines are exempt from
NSPS KKKK.
Colorado Regulation No. 7, Section XVI
Since the Source facility is in an area designated as non -attainment for the 8 -hour
ozone standard, the requirements of Section XVI apply to the turbines, as appropriate.
123/0014 Page 3 of 6
Public Service Company of Colorado - Ft. Lupton Combustion Turbines
Operating Permit No. 96OPWE154
Technical Review Document —Operating Permit — Renewal No. 4
These regulations have changed since the last issuance of this Operating Permit. The
State of Colorado State Implementation Plan (SIP) was required to be updated due to
the area's redesignation to moderate non -attainment for ozone with respect to the
1997 Federal 75 ppb (parts per billion) ozone standard; the area had previously been
designated as marginal as of 2007. Note that this designation is separate from the
2015 Federal 70 ppb ozone standard for which there have yet to be non -attainment
designations.
As a result of the SIP changes, Section XVI was drastically modified after a long
stakeholder process during which major sources of NOx and VOC in the ozone non -
attainment area were required to assist in defining new RACT requirements for
various equipment and processes; these have now been adopted into Section XVI.
Combustion turbines were one of the types of equipment for which new RACT
requirements were put into place. These have been included in the new Condition 4 of
the Operating Permit. Note that the main emission requirement is that the Source
must comply with the NOx limit from NSPS GG, although not being actually subject to
the requirement. Additionally, compliance demonstration must be made by either initial
and periodic performance testing, or the installation of a CEMS (continuous emission
monitoring system) or CERMS (continuous emission rate monitoring system).
At the time of publication of this Operating Permit, the turbines at the Source facility
qualify for the exemption under Section XVI.D.2.a.(ii) because they are below the 10%
capacity factor on an annual basis over a 3 -year rolling period. This exemption
removes many of the requirements in Section XVI from applying until the exemption is
lost, at which time the Source will have no more than 3 years (or as expeditiously as
practicable) to come into compliance with the requirements outlined in Condition 4.
The Source is still required to maintain records demonstrating that they still qualify for
the exemption under Section XVI.D.2.a.(ii). Further, the Source is also still required to
perform the process adjustment requirements in Section XVI.D.6., as appropriate.
IV. Modifications Requested by the Source
Since the previous issuance of the Operating Permit, the Source requested the
following modifications; unless otherwise noted, all requests were incorporated into
the Operating Permit.
Section I — General Activities and Summary
• The Source requested that Chad Campbell be added as the facility contact.
Section II — Specific Permit Terms
• The Source requested that the requirements of Colorado Regulation No. 7 be
added to the permit, as appropriate. These requirements have been added as
new Condition 4; see discussion above for more information related to this
change.
V. Other Modifications
123/0014 Page 4 of 6
Public Service Company of Colorado — Ft. Lupton Combustion Turbines
Operating Permit No. 96OPWE154
Technical Review Document —Operating Permit — Renewal No. 4
In addition to the source requested modifications, the Division has included changes
to make the permit more consistent with recently issued permits, include comments
made by EPA on other Operating Permits, as well as correct errors or omissions
identified during inspections and/or discrepancies identified during review of this
renewal. These changes are as follows:
Page Following Cover Page
• It should be noted that the monitoring and compliance periods and report and
certification due dates are shown as examples. The appropriate monitoring and
compliance periods and report and certification due dates will be filled in after
permit issuance and will be based on permit issuance date. Note that the
source may request to keep the same monitoring and compliance periods and
report and certification due dates as were provided in the original permit.
However, it should be noted that with this option, depending on the permit
issuance date, the first monitoring period and compliance period may be short
(i.e. less than 6 months and less than 1 year).
• Modified the language concerning postmarked dates for report submittals to
reflect the Division's current standard language.
• Updated the Facility Contact to reflect the application submitted on July 28,
2017.
• Updated the description of the SIC to better match the listed SIC description.
Section I — General Activities and Summary
• Formatted Section I to be more consistent with recently issued Title V permits.
Section II — Specific Permit Terms
• Condition 1.3 — The citation for Colorado Regulation No. 1, Section III.A.1.c.
was added to this requirement.
• The previous opacity condition was expanded to make Condition 1.6 which now
includes the Colorado Regulation No. 1, 30% opacity requirement. The
presumed compliance language was updated to explicitly say that compliance
with the opacity limits is presumed when only natural gas is combusted. This
change is to prevent confusion because the turbines are permitted under
Condition 3 to combust any combination of the permitted fuels. As such, the
previous permit implied that whenever natural gas was combusted in the
turbines, compliance would be presumed, which indicated that compliance
would be presumed if natural gas were being combusted in combination with
the other permitted fuel types. The requirement to maintain records of when
only natural gas is combusted was added to monitor when compliance with the
opacity requirements can be presumed.
• Condition 2.4 — The requirement for the Source to maintain records of the sulfur
content of the fuel was added to verify the presumptive compliance as
described in the condition.
123/0014 Page 5 of 6
Public Service Company of Colorado — Ft. Lupton Combustion Turbines
Operating Permit No. 96OPWE154
Technical Review Document —Operating Permit — Renewal No. 4
• Condition 2.5 — The requirement for the Source to maintain records of fuel
deliveries was made explicit.
• The opacity requirements were reformatted and expanded to reflect more
current Division Title V permits; this was done under new Condition 2.6. The
Colorado Regulation No. 1, Section II.A.4. 30% requirement was added to the
permit, as appropriate. The language related to how the EPA Method 9 opacity
observations are to be performed was made more explicit, as were the
associated recordkeeping requirements. Added a note to the front of the
opacity requirements which makes explicit that the opacity requirements are
only applicable when fuel oil is combusted in the turbines, and that the opacity
requirements apply to each turbine individually.
• Condition 3 — This requirement was reworded for clarity to outline that
monitoring, recordkeeping and recording requirements must be followed for
each fuel combusted, but in the event of overlapping requirements, the most
stringent must be followed.
• Condition 4 was added to address the requirements of Colorado Regulation No.
7, Section XVI related to stationary turbines. See the discussion in Section III of
this TRD, above, for more information related to these requirements.
Section III — Permit Shield
• There were no changes to the permit shield.
Section IV — General Permit Conditions
• The General Permit Conditions were updated to the most recent version
(8/28/2018). The most significant change was the addition of new major source
requirements in Condition 24.
Appendices
• The formatting of the Appendices was updated for consistency and clarity.
• Appendices B and C were updated to the 2014 version to reflect the current
standard Division format and content.
• Appendix D was updated with current contact information.
• The insignificant activities list was updated to reflect the Colorado Regulation
No. 3, Part C, Section II.E. requirements to maintain records of certain
insignificant activities to verify that they ought to remain on the list, as
appropriate.
123/0014 Page 6 of 6
Xcel Energy -
Environmental Services
1800 Larimer Street, Suite 1300
Denver, CO 80202
July 26, 2017
Mr. Nicholas Dummer
Colorado Department of Public Health & Environment
Air Pollution Control Division, APCD-SS-B 1
Operating Permit Unit
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Re: Public Service Company of Colorado - Fort Lupton Combustion Turbines
Permit #96OPWE154
Operating Permit Renewal Application
Dear Mr. Dummer:
In accordance with the requirements of Colorado Air Quality Control Commission Regulation No. 3, Part
C, Section III.B.6, Public Service Company of Colorado (PSCo) is hereby submitting a renewal application
for the PSCo Fort Lupton Combustion Turbines Title V Operating Permit #96OPWE154. This submittal
includes a re-evaluation of the Compliance Assurance Monitoring (CAM) applicability and the required
Colorado operating permit application forms (Form 2000-100 and Form 2000-800).
Compliance Assurance Monitoring Assessment
Each emission source at the Fort Lupton Combustion Turbine facility was evaluated for CAM applicability
as part of the December 1, 2008 permit renewal. The evaluation during that process identified that there are
no emission sources at the facility that use a control device to achieve compliance with an emission
limitation or standard and thus the provisions of CAM do not apply. That same evaluation and conclusion
are valid for this renewal as there have been no new sources or control devices added at the facility.
Requested Changes
No changes are being requested for the operating permit except as identified below or attached.
PSCo requests that the permit be updated to show Chad Campbell as the "Facility Contact Person" for this
facility. The contact information for Mr. Campbell should be listed as:
Title: Manager, Environmental Services
Phone: (303) 294-2177
This change in information has been reflected on Form 2000-100 that is included with this submittal.
PSCo requests that the applicable sections of Colorado Regulation 7 for the recently added combustion
adjustment requirements be incorporated during this permit renewal.
If you have any questions concerning the attached permit application forms or require additional
information, please contact Josh Korth of Xcel Energy's Environmental Services staff, at (303) 294-2187.
Sincerely,
711 0,( -707c
Mark Fox
General Manager — Power Generation, Colorado
Attachments:
As Stated
cc:
M. Maes — Fort Lupton
J. Bell — Fort Lupton
ES Electronic File
Operating Permit Application FACILITY IDENTIFICATION
Colorado Department of Public Health and Environment
Air Pollution Control Division
SEE INSTRUCTIONS ON REVERSE SIDE
FORM 2000-100
Rev 06-95
1. Facility name and
mailing address
Name
Street or Route
City, State, Zip Code
Public Service Company of Colorado - Fort Lupton Combustion
Turbines
15002 Weld County Road 16
Ft. Lupton, CO 80621
2. Facility location
(No P.O. Box)
Street Address
City, County, Zip Code
15002 Weld County Road 16
Ft. Lupton, CO 80621
3. Parent corporation
Name
Street or Route
City, State, Zip Code
Country (if not U.S.)
Public Service Company of Colorado
1800 Larimer Street
Denver, CO 80802
4. Responsible
official
Name
Title
Telephone
Mark Fox
General Manager — Power Generation, Colorado
(303) 425-3779
5. Permit contact person
(If Different than 4)
Name
Title
Telephone
Chad Campbell
Manager, Environmental Services
(303) 294-2177
6. Facility SIC code: 4911
7. Facility identification code: CO 1230014
8. Federal Tax I. D. Number: 84-6015506
9. Primary activity of the operating establishment: Natural Gas -Fired Electric Generating Station
10. Type of operating permit O New
O Modified
CI Renewal
11. Is the facility located in a "nonattainment" area: 0 Yes O No
If "Yes", check the designated "non -attainment" pollutant(s):
O Carbon Monoxide
El Ozone
❑ PM10
O Other (specify)
12. List all (Federal and State) air pollution permits (including grandfathered units), plan approvals and exemptions issued to
this facility. List the number, date and what unit/process is covered by each permit. For a Modified Operating Permit, do not
complete this item.
Operating Permit Application
Colorado Department of Health
Air Pollution Control Division
Facility Name: Fort Lupton Combustion Turbines
TABULATION OF PERMIT APPLICATION FORMS
09-94
Facility Identification Code: CO 1230014
FORM 2000-800
I. ADMINISTRATION
This application contains the following forms:
❑x
Form 2000-100, Facility Identification
❑
Form 2000-101, Facility Plot Plan
❑
Forms 2000-102, -102A, and -102B, Source and Site Descriptions
II. EMISSIONS SOURCE
DESCRIPTION
Total Number
of This Form
This application contains the following forms
(one form for each facility boiler. nrintine
0
Form 2000-200, Stack Identification
❑
Form 2000-300, Boiler or Furnace Operation
❑
Form 2000-301, Storage Tanks
❑
Form 2000-302, Internal Combustion Engine
❑
Form 2000-303, Incineration
❑
Form 2000-304, Printing Operations
❑
Form 2000-305, Painting and Coating Operations
❑
Form 2000-306, Miscellaneous Processes
❑
Form 2000-307, Glycol Dehydration Unit
III. AIR POLLUTION CONTROL
SYSTEM
Total Number
of This Form
This application contains the following forms:
0
Form 2000-400, Miscellaneous
❑
Form 2000-401, Condensers
❑
Form 2000-402, Adsorbers
❑
Form 2000-403, Catalytic or Thermal Oxidation
❑
Form 2000-404, Cyclones/Settling Chambers
❑
Form 2000-405, Electrostatic Precipitators
❑
Form 2000-406, Wet Collection Systems
❑
Form 2000-407, Baghouses/Fabric Filters
IV. COMPLIANCE
DEMONSTRATION
Total Number
of This Form
This application contains the following forms
(one for each facility boiler. nrintine operation_
0
Form 2000-500, Compliance Certification - Monitoring and Reporting
❑
Form 2000-501, Continuous Emission Monitoring
❑
Form 2000-502, Periodic Emission Monitoring Using Portable Monitors
❑
Form 2000-503, Control System Parameters or Operation Parameters of a Process
❑
Form 2000-504, Monitoring Maintenance Procedures
•
Form 2000-505, Stack Testing
❑
Form 2000-506, Fuel Sampling and Analysis
❑
Form 2000-507, Recordkeeping
❑
Form 2000-508, Other Methods
2
i V. EMISSION SUMMARY AND
COMPLIANCE CERTIFICATION
Total Number
of This Form
This application contains the following forms
quantifying emissions, certifying compliance
with applicable requirements, and developing a
compliance plan
O
Form 2000-600, Emission Unit Hazardous Air Pollutants
❑
Form 2000-601, Emission Unit Criteria Air Pollutants
❑
Form 2000-602, Facility Hazardous Air Pollutants
❑
Form 2000-603, Facility Criteria Air Pollutants
❑
Form 2000-604, Applicable Requirements and Status of Emission Unit
❑
Form 2000-605, Permit Shield Protection Identification
❑
Form 2000-606, Emission Unit Compliance Plan - Commitments and Schedule
❑
Form 2000-607, Plant -Wide Applicable Requirements
❑
Form 2000-608, Plant -Wide Compliance Plan - Commitments and Schedule
VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS
A. STATEMENT OF COMPLETENESS
I have reviewed this application in its entirety and, based on information and belief
the statements and information contained in this application are true, accurate and
B. CERTIFICATION OF FACILITY COMPLIANCE STATUS - FEDERAL/STATE
0 I certify that the facility described in this air pollution permit application
requirements.
O I certify that the facility described in this air pollution permit application
requirements, except for the following emissions unit(s):
formed after reasonable inquiry, I certify that
complete.
CONDITIONS (check one box only)
is fully in compliance with all applicable
is fully in compliance with all applicable
any false material statement, representation,
misdemeanor and may be punished in
(list all non -complying units)
WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes
or certification in, or omits material information from this application is guilty of a
accordance with the provisions of § 25-7 122.1, C.R.S.
Printed or Typed Name
Mark Fox
Title
General Manager — Power Generation, Colorado
Signature
706-1.
2
Date Signed
3
Operating Permit Application
Colorado Department of Health
Air Pollution Control Division
CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 2000-800
09-94
Facility Name: Fort Lupton Combustion Turbines
Facility Identification Code: CO 1230014
VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY CONDITIONS
A. STATEMENT OF COMPLETENESS
I have reviewed this application in its entirety and, based on information and belief
the statements and information contained in this application are true, accurate and
B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE -ONLY
t] I certify that the facility described in this air pollution permit application
requirements.
O I certify that the facility described in this air pollution permit application
requirements, except for the following emissions unit(s):
formed after reasonable inquiry, I certify that
complete.
CONDITIONS (check one box only)
is fully in compliance with all applicable
is fully in compliance with all applicable
any false material statement, representation,
misdemeanor and may be punished in
(list all non -complying units)
WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes
or certification in, or omits material information from this application is guilty of a
accordance with the provisions of § 25-7 122.1, C.R.S.
Printed or Typed Name
Mark Fox
Title
General Manager — Power Generation, Colorado
Signature
14°*""4 -7,7C`
Date Signed
4- Ziv-ii-
SEND ALL MATERIALS TO:
COLORADO DEPARTMENT OF HEALTH
APCD-SS-B 1
4300 CHERRY CREEK DRIVE SOUTH
DENVER, CO 80246-1530
4
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