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Home My WebLink About20192381.tiffaNto COLORADO Department of Public Health & Environment Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 June 17, 2019 Dear Sir or Madam: RECEIVED WELD COUNTY COMMISSIONERS On June 20, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Public Service Company of Colorado - Yosemite Air Blend Plant. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: 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 Polis, Governor I Jill Hunsaker Ryan, MPH, Executive Director P bliC View OCOracc>/19 cc'PL cTRIC_-ICHi3M/cK) oCo/atit(9 2019-2381 a Air Pollution Control Division Notice Of A Proposed Renewal Title V Operating Permit Warranting Public Comment Website Title: Public Service Company of Colorado - Yosemite Air Blend Plant - Weld County Notice Period Begins: June 20, 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: Yosemite Air Blend Plant 934 Weld County Road 19 Brighton, CO 80601 - Weld County Public Service Company of Colorado has applied to renew the Operating Permit for the Yosemite Air Blend Plant in Weld County, CO. This facility consists of six gas -fired air compressors used for compressed air natural gas blending, under Standard Industrial Classification 4922. The permit was updated to the most current state and federal rules and regulations. No emission changes were requested. A copy of the application, including supplemental information, the Division's analysis, and a draft of the Renewal Operating Permit 02OPWE247 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 Thang Nghiem of the Division at 303.692.3256 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: 1,* COLORADO Department of Public Health 6 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: Thang Nghiem 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 SC COLORADO Department of Public Health b Environment Colorado Department of Public Health and Environment OPERATING PERMIT Public Service Company of Colorado Yosemite Air Blend Plant First Issued: September 1, 2003 Renewed: DATE AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: FACILITY ID: RENEWED: EXPIRATION DATE: MODIFICATIONS: Yosemite Air Blend Plant 123/0141 September 1, 2013 September 1, 2018 See Appendix F of Permit OPERATING PERMIT NUMBER 02OPWE247 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: PLANT SITE LOCATION: Public Service Company of Colorado 1800 Larimer Street Denver, CO 80202 Yosemite Air Blend Plant 934 Weld County Road 19 Brighton, CO 80601 - Weld County INFORMATION RELIED UPON Operating Permit Renewal Application Received: And Additional Information Received: June 27, 2017 April 4, 2019 & May 3, 2019 Nature of Business: Air Compression and Processing Primary SIC: 4922 RESPONSIBLE OFFICIAL Name: Title: Phone: Luke Litteken Senior Vice President - Gas (303) 571-3993 FACILITY CONTACT PERSON Name: Chad Campbell Title: Environmental Services Phone: (303) 294-2177 RESPONSIBLE OFFICIAL'S AUTHORIZED REPRESENTATIVE Name: Title: Phone: Eric Kirkpatrick Area Vice President - Gas (303) 571-3223 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: TBD based on issuance date September 1 - February 28 (29), March 1 - August 31 TBD based on issuance date TBD based on issuance date September 1 - August 31 Due on October 1, 2014 & 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 3 1. Permitted Activities 3 2. Alternative Operating Scenarios (ver 10/12/2012 — updated to reflect changes to Colorado Regulation No. 7, NSPS, and MACT rules) 3 3. Prevention of Significant Deterioration 9 4. Accidental Release Prevention Program (1 1 2(r)) 10 5. Compliance Assurance Monitoring (CAM) 10 6. Summary of Emission Units 11 SECTION II - Specific Permit Terms 12 1. Compressor Engines 001, 002, 004, 005, 008 & 007 (E001 - E006)• 12 2. Portable Monitoring (6/26/14 version) 17 3. Insignificant Activities 18 4. E008 & E009 - Natural Gas -Fired Emergency Generators 19 5. M001 - Cold Cleaner Solvent Vats 25 SECTION III - Permit Shield 27 1. Specific Non -Applicable Requirements 27 2. General Conditions 27 3. Stream -lined Conditions 28 SECTION IV - General Permit Conditions (ver 8/28/18) 29 1. Administrative Changes 29 2. Certification Requirements 29 3. Common Provisions 29 4. Compliance Requirements 33 5. Emergency Provisions 34 6. Emission Controls for Asbestos 34 7. Emissions Trading, Marketable Permits, Economic Incentives 34 8. Fee Payment 34 9. Fugitive Particulate Emissions 35 10. Inspection and Entry 35 11. Minor Permit Modifications 35 12. New Source Review 35 13. No Property Rights Conveyed 35 14. Odor 35 15. Off -Permit Changes to the Source 36 16. Opacity 36 17. Open Burning 36 18. Ozone Depleting Compounds 36 19. Permit Expiration and Renewal 36 20. Portable Sources 36 21. Prompt Deviation Reporting 36 22. Record Keeping and Reporting Requirements 37 23. Reopenings for Cause 38 24. Requirements for Major Stationary Sources 38 25. Section 502(b)(10) Changes 39 TABLE OF CONTENTS: 26. Severability Clause 40 27. Significant Permit Modifications 40 28. Special Provisions Concerning the Acid Rain Program 40 29. Transfer or Assignment of Ownership 40 30. Volatile Organic Compounds 40 31. Wood Stoves and Wood burning Appliances 41 APPENDIX A - Inspection Information 43 1. Directions to Plant: 43 2. Safety Equipment Required: 43 3. Facility Plot Plan: 43 4. List of Insignificant Activities• 43 APPENDIX B 48 Reporting Requirements and Definitions 48 APPENDIX C 57 Required Format for Annual Compliance Certification Reports 57 APPENDIX D 60 Notification Addresses (ver 2/5/2014) 60 APPENDIX E 61 Permit Acronyms 61 APPENDIX F 63 Permit Modifications 63 APPENDIX G 64 Engine AOS Applicability Reports 64 Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 1. Permitted Activities 1.1 Public Service Company of Colorado Yosemite Air Blend Plant Page 3 SECTION I - General Activities and Summary This facility consists of six gas -fired air compressors used for compressed air natural gas blending, under Standard Industrial Classification 4922. In addition, the other significant emission units included in Section II of this permit include two emergency generators. The facility is located at 934 Weld County Road 19, Brighton, 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. The following Federal Class I designated area is within 100 kilometers of the plant: Rocky Mountain National Park. 1.2 Until such time as this permit expires or is modified or revoked, the permittee is allowed to discharge air pollutants from this facility in accordance with the requirements, limitations, and conditions of this permit. 1.3 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 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: 87WE006-1, 87WE006-2, 95WE461, 96WE379, 00WE804 and 01WE0929. 1.4 All conditions in this permit are enforceable by US Environmental Protection Agency, Colorado Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless otherwise specified. State -only enforceable conditions are: Permit Condition Number(s): Section IV - Conditions 3.g (last paragraph), 14 & 18 (as noted). 1.5 All information gathered pursuant to the requirements of this permit is subject to the Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions in Section IV of this permit. Either electronic or hard copy records are acceptable. 2. Alternative Operating Scenarios (ver 10/12/2012 — updated to reflect changes to Colorado Regulation No. 7, NSPS, and MACT rules) The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 4 found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the permittee shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 -day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping), and shall be subject to any shield afforded by this permit. The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The permittee shall maintain a log on -site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, date of manufacture, model number, horsepower, and serial number of the replacement engine. In addition to the log, the permittee shall maintain a copy of all Applicability Reports required under Section 2.1.2 and make them available to the Division upon request. 2.1.1 The permittee may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in Section 2.2. The permittee may temporarily replace a grandfathered or permit exempt engine or an engine that is not subject to emission limits without modifying this permit. In this circumstance, potential annual emissions of NOx and CO from the temporary replacement engine must be less than or equal to the potential annual emissions of NOx and CO from the original grandfathered Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 5 or permit exempt engine or for the engine that is not subject to emission limits, as determined by applying appropriate emission factors (e.g. AP -42 or manufacturer's emission factors). 2.1.2 The permittee may permanently replace the existing compressor engine for the emission points specified in Table 1 with the manufacturer, model, and horsepower engines listed in Table 1 without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in Section 2.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the permittee is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found in Appendix A. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The permittee shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The permittee may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The permittee shall measure nitrogen oxide (NO,) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 6 All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: https://www.colorado.gov/pacific/cdphe/portable-analyzer-mon itoring-protocol. Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. For comparison with a short-term limit that is either input based (Ib/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above -mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NO,t and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NO, and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NO, or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NO, and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § III.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NO, are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PMio attainment/maintenance area, RACT applies to PMio at any level of emissions and to NO, and SO2, as precursors to PMio, if the potential to emit of NO,t or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural-gas fired reciprocating internal combustion engines: Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 7 VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOR: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PMio: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State -Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non -selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII.E — State -only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Max Engine HP Construction or Relocation Date Emission Standards in G/hp-hr NOx CO VOC 100<Hp<500 January 1, 2008 2.0 4.0 1.0 January 1, 2011 1.0 2.0 0.7 500<Hp July 1, 2007 2.0 4.0 1.0 July 1, 2010 1.0 2.0 0.7 Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 8 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for spark ignition internal combustion engines: 40 CFR 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6, Part B, Section I.C., upon adoption of NSPS JJJJ into Regulation No. 6, Part A an internal combustion engine relocated from outside of the State of Colorado into the State of Colorado shall meet the most recent emission standard required in NSPS JJJJ. Engines with a manufacturer's rated horsepower of less than 500 and with a relocation date no later than 5 years after the manufacture date are exempt from this requirement per Regulation No. 6, Part B, Section I.C.2.a. Relocation is defined in Section I.C.I.a. However, as of August 20, 2015 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 2.3.5 Additional Sources Public Service Company of Colorado Yosemite Air Blend Plant Page 9 The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. Table 1 Internal Combustion Engine Information for the AOS Emission Point Replacement Engine Periodic Monitoring? Subject to CAM? 001 Waukesha, Model No. L5108GL, site rated at 720 HP, 4 -cycle lean burn natural gas fired internal combustion engine. Quarterly No 002 Waukesha, Model No. L5108GL, site rated at 720 HP, 4 -cycle lean burn natural gas fired internal combustion engine. 004 Waukesha, Model No. 7042GL, four-cycle, 4 -cycle lean burn, natural gas fired internal combustion engine, site rated at 1148 HP. 005 Waukesha, Model No. 7042GL, four-cycle, 4 -cycle lean burn, natural gas fired internal combustion engine, site rated at 1 148 HP. 008 Caterpillar, Model No. 3608, 4 -cycle lean burn natural gas fired internal combustion engine, site heat input rated at 16,008,000 BTU per hour, site output rated at 2368 HP. 007 Caterpillar, Model No. G3612, 4 -cycle lean burn natural gas fired internal combustion engine, site heat input rated at 24,683,000 BTU per hour, site output rated at 3550 HP. 3. Prevention of Significant Deterioration 3.1 Based on the information provided by the applicant, this source is categorized as a minor stationary source for PSD as of the issue date of this permit. Any future modification which is major by itself (Potential to Emit of> 250 TPY) for any pollutant listed in Regulation No. 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 facility is categorized as a NANSR major stationary source (Potential to Emit of NO, ≥ 100 tons/year). Future modifications at this facility resulting in a significant net emissions increase (see Regulation No. 3, Part D, Sections 1LA.27 and 44) for NO, or a modification which is major by itself Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 10 (Potential to Emit ≥ 100 tons/year of NOR) 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 Prevention of Significant Deterioration regulations. 4. Accidental Release Prevention Program (112(r)) 4.1 Based on the information provided by the applicant, this facility is not subject to the provisions of the Accidental Release Prevention Program (section 112(r)) of the Federal Clean Air Act. 5. Compliance Assurance Monitoring (CAM) 5.1 The following emission points at this facility use a control device to achieve compliance with an emission limitation or standard to which they are subject and have pre -control emissions that exceed or are equivalent to the major source threshold. They are therefore subject to the provisions of the CAM program as set forth in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV: None. Although engines E001 through E006 are equipped with control devices, the control devices are not necessary to achieve compliance with the emission limitations for these units; therefore, CAM does not apply to the engines. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 6. Summary of Emission Units 6.1 The emissions units regulated by this permit are the following: Public Service Company of Colorado Yosemite Air Blend Plant Page 11 Emission Unit No./ Facility ID AIRS Point No. Description Startup Date Construction Permit Number Pollution Control Device E001/ S001 001 Waukesha, Model No. L5108GL, S/N 398630, site rated at 720 HP, 4 -cycle lean burn natural gas fired internal combustion engine. Air Compressor #1 November 20, 1987 87WE006-1 Low NOx Desi gn Oxidation Catalyst Installed March 2005 E002/November S002 002 Waukesha, Model No. L5108GL, S/N 398631 site rated at 720 HP, 4 -cycle lean burn natural gas fired internal combustion engine. Air Compressor #2 20, 1987 87WE006-2 Low NOx Design Oxidation Catalyst Installed March 2005 E003/ S003 004 Waukesha, Model No. 7042GL, S/N C-10336/1, four-cycle, 4 -cycle lean burn, natural gas fired internal combustion engine, site rated at 1148 HP. Air Compressor #3 November 4, 1995 95WE461 Low NOx Design Oxidation Catalyst Installed March 2005 E004/ S004 005 Waukesha, Model No. 7042GL, S/N C-11373/1, 4 -cycle lean burn natural gas fired internal combustion engine, site rated at 1148 HP. Air Compressor #4 1996 96WE379 Low NOx Design Oxidation Catalyst Installed March 2005 E005/ S005 008 Caterpillar, Model No. 3608, S/N 4WF00199, 4- cycle lean burn natural gas fired internal combustion engine, site heat input rated at 16,008,000 BTU per hour, site output rated at 2368 HP. Air Compressor #6 October 1, 2001 00WE0804 Low NOx Design Oxidation Catalyst Installed April 2005 E006/ S006 007 Caterpillar, Model No. G3612, S/N BKE00197, 4 - cycle lean burn natural gas fired internal combustion engine, site heat input rated at 24,683,000 BTU per hour, site output rated at 3550 HP. Air Compressor #7 October 1, 2002 01WE0929 Low NOx Design Oxidation Catalyst Installed March 2005 E008 & E009 N/A South Emergency Generator: Caterpillar, Model No. 3306SINA, S/N 07Y02652, 4 -cycle lean burn natural gas fired internal combustion engine, rated at 5500 Btu/hp-hr and 145 hp. North Emergency Generator: Caterpillar, Model No. G3508LE, S/N CTN00169, 4 -cycle lean burn natural gas fired internal combustion engine, rated at 5500 Btu/hp-hr and 487 hp. E008 - 1987 E009 - 2002 N/A None M001 N/A Cold Cleaner Solvent Vats N/A None * permitted as combined construction /operating permit. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 12 SECTION II - Specific Permit Terms 1. Compressor Engines 001, 002, 004, 005, 008 & 007 (E001 - E006): Point 001 (E001) and Point 002 (E002) - Waukesha, L5108GL, site rated at 720 HP, natural gas fired internal combustion reciprocating engines - Air Compressors #1 & 2 Point 004 (E003) and Point 005 (E004) - Waukesha, 7042GL, site rated at 1,148 HP, natural gas fired internal combustion reciprocating engines - Air Compressors #3 & 4 Point 008 (E005) - Caterpillar, Model 3608, site rated at 2,368 HP, natural gas fired internal combustion reciprocating engine - Air Compressor #6 Point 007 (E006) - Caterpillar, Model G3612, site rated at 3,550 HP, natural gas fired internal combustion reciprocating engine - Air Compressor #7 Unless otherwise specified, requirements apply to each engine Parameter Permit Condition Number Limitation Compliance Emission Factor Monitoring Method Interval Emission & Consumption Limits (for each engine) HP) Compressor Engines (#1 & 2) Points 001 & 002: Two (2) Waukesha L5108GL (720 NOx 1.1 10.4 tons/yr 0.46 lb/MMBtu Recordkeeping & Calculation Portable Flue Gas Analyzer Monthly Quarterly CO 18.4 tons/yr 0.81 lb/MMBtu VOC 7.0 tons/yr 0.31 lb/MMBtu Natural Gas Consumption 1.2 45.5 MMscf/yr Fuel Meter Monthly Emission & Consumption Limits (for each engine) HP) Compressor Engines (#3 & 4) Points 004 & 005: Two (2) Waukesha 7042GL (1,148 NOx 1.1 16.7 tons/yr 0.46 lb/MMBtu Recordkeeping & Calculation Portable Flue Gas Analyzer Monthly Quarterly CO 29.5 tons/yr 0.81 lb/MMBtu VOC 11.1 tons/yr 0.31 lb/MMBtu Natural Gas Consumption 1.2 73.1 MMscf/yr Fuel Meter Monthly Emission & Consumption Limits (2,368 HP) Compressor Engine (#6) Point 008: One (1) Caterpillar 3608 NOx 1.1 34.3 tons/yr 0.49 lb/MMBtu Recordkeeping & Calculation Portable Flue Gas Analyzer Monthly Quarterly CO 57.1 tons/yr 0.82 lb/MMBtu VOC 11.4 tons/yr 0.16 lb/MMBtu Natural Gas Consumption 1.2 147.5 MMscf/yr Fuel Meter Monthly Emission & Consumption Limits Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 1.1 Public Service Company of Colorado Yosemite Air Blend Plant Page 13 Parameter Permit Condition Number Limitation Compliance Emission Factor Monitoring Method Interval Point 007: One (1) Caterpillar G3612 (3,550 HP) Compressor Engine (#7) NOx 1.1 34.3 tons/yr 0.32 lb/MMBtu Recordkeeping & Calculation Portable Flue Gas Analyzer Monthly Quarterly CO 85.7 tons/yr 0.79 Ib/MMBtu VOC 17.2 tons/yr 0.16 lb/MMBtu Natural Gas Consumption 1.2 229.8 MMscf/yr Fuel Meter Monthly Other Requirements (for each engine) Opacity 1.3 Not to exceed 20% Restriction Only Natural Gas Used Used as Fuel Engine Operation and Maintenance 1.4 See Condition 1.4 Btu Content of Natural Gas 1.5 ASTM Methods Semi -Annually Colorado Regulation No. 7 Requirements Control 1.6 Install and Operate Oxidation Catalyst See Condition 1.6 Nitrogen Oxides (NO,), Carbon Monoxide (CO) and Volatile Organic Compounds (VOC) emissions for each engine shall not exceed the limitations stated above (Colorado Construction Permits 87WE006-1, 87WE006-2, 95WE461, 96WE379, 00WE0804, & 01WE0929). Compliance with the emission limitations shall be monitored as follows: 1.1.1 Except as provided for below, the emission factors listed above (manufacturer's emission factor, converted to lbs/MMBtu based on engine heat rates in table below, as indicated in the Title V permit applications submitted on August 19, 2002) have been approved by the Division and shall be used to calculate emissions from these engines. Engine Description Engine Heat Rate Points 001 & 002: Two (2) Waukesha L5108GL (720 HP) Compressor Engines (#1 & 2) 7,175 Btu/hp-hr Points 004 & 005: Two (2) Waukesha 7042GL (1,148 HP) Compressor Engines (#3 & 4) 7,180 Btu/hp-hr Point 008: One (1) Caterpillar 3608 (2,368 HP) Compressor Engine (#6) 6,760 Btu/hp-hr Point 007: One (1) Caterpillar G3612 (3,550 HP) Compressor Engine (#7) 6,953 Btu/hp-hr Monthly emissions shall be calculated by the end of the subsequent month using the above emission factor, the monthly natural gas consumption and the lower heating value of the fuel in the equation below: Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Emissions Public Service Company of Colorado Yosemite Air Blend Plant Page 14 EF ( lbs 1 x NG Consumption (Mit4scf) x LHV (MMBtu) (t0flS) MMBtuI moJJ MMscf lbs mo 2000 ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual emission limitation. Each month, a new twelve month total shall be calculated using the previous twelve months data. If the results of the portable analyzer testing conducted under the provisions of Condition 1.1.2 show that either the NOx or CO emission rates/factors are greater than the emission rates/factors listed above, and in the absence of subsequent testing results to the contrary (as approved by the Division), the permittee shall apply for a modification to this permit to reflect, at a minimum, the higher emission rates/factors within 60 days of the completion of the test. 1 1.2 Portable Monitoring shall be conducted quarterly in accordance with the requirements in Condition 2. 1.2 Natural gas consumption from these engines shall not exceed the limitations listed above (Colorado Construction Permits 87WE006-1, 87WE006-2, 95WE461, 96WE379, 00WE0804, & 01WE0929). Natural gas use shall be recorded monthly using each engine's fuel meter. Monthly natural gas use shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months' data. 1.3 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). In the absence of credible evidence to the contrary, compliance with the 20% opacity requirement will be presumed since only natural gas is permitted to be used as fuel in these engines. 1.4 The engines and oxidation catalysts shall be operated and maintained in accordance with manufacturer's recommendations and good engineering practices at all times, including periods of start-up, shutdown, and malfunction. The oxidation catalysts shall be monitored as follows: Monitoring Requirement Monitoring Frequency Pre -catalyst Temperature Weekly Catalyst Differential Pressure Monthly 1.4.1 The inlet temperature to the catalyst shall be maintained within the range of 450°F to 1350°F. Catalyst inlet temperature shall be monitored and recorded on a weekly basis. If the temperature is outside of this range then appropriate maintenance activities shall be performed. 1.4.2 The pressure drop across the catalyst shall be monitored and recorded monthly. The pressure drop across the catalyst shall not exceed 2 inches of water column from the baseline value Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 15 established by the source when the engine is operating at maximum achievable load. This baseline pressure drop shall be established by the source during each portable monitoring event required by Condition 1.1.2 or as noted below. If the pressure is outside this range then the appropriate maintenance shall be performed to bring the pressure back into range. In lieu of maintenance the source may choose to perform a portable analyzer test of the engine to establish a new pressure drop value. If the test demonstrates that the engine is in compliance with its emission limits, the pressure drop value at which the engine is tested shall become the new baseline. 1.4.3 When portable monitoring is scheduled, the above parameters in Condition 1.4.1 and 1.4.2 shall be recorded during the portable monitoring event. 1.4.4 The engine exhaust oxygen content shall be monitored and recorded during the portable monitoring events required by Condition 1.1.2. 1.5 The Btu content of the natural gas used to fuel these engines shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the natural gas shall be based on the lower heating value of the fuel. Calculations of monthly emissions shall be made using the heat content derived from the most recent required analysis. 1.6 These engines are subject to the requirements in Colorado Regulation No. 7, Section XVI, as follows: 1.6.1 Any existing natural gas -fired stationary or portable reciprocating internal combustion engine with a manufacturer's design rate greater than 500 horsepower, which existing engine was operating in the 8 -hour Ozone Control Area prior to June 1, 2004, shall employ air pollution control technology on and after May 1, 2005, as provided for in Condition 1.6.2 (Colorado Regulation No. 7, Section XVI.A.2). 1.6.2 For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. A lean burn reciprocating internal combustion engine is one with a normal exhaust oxygen concentration of 2% by volume, or greater (Colorado Regulation No. 7, Section XVI.B.2). 1.6.3 The emission control equipment required by Condition 1.6.2 shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications (Colorado Regulation No. 7, Section XVI.B.3). 1.6.4 As of January 1, 2017, Section XVI.D.6. - Combustion Process Adjustment applies to stationary reciprocating internal combustion engines with uncontrolled actual emissions of NOX equal to or greater than five (5) tons per year that existed at major sources of NO, as of June 3, 2016 (Colorado Regulation No. 7, Section XVI.D.6.a): 1.6.4.1 The owner or operator of a stationary internal combustion engine must conduct the following inspections and adjustments, as applicable (Colorado Regulation No. 7, Section XVI.D.6.b.(iv)): Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 16 a. Change oil and filters as necessary (Colorado Regulation No. 7, Section XVI.D.6.b.(iv)(A)). b. Inspect air cleaners, fuel filters, hoses, and belts and clean or replace as necessary (Colorado Regulation No. 7, Section XVI.D.6.b.(iv)(B)). c. Inspect spark plugs and replace as necessary (Colorado Regulation No. 7, Section XVI.D.6.b.(iv)(C)). 1.6.4.2 The owner or operator must operate and maintain the stationary internal combustion engine consistent with manufacturer's specifications, if available, or good engineering and maintenance practices (Colorado Regulation No. 7, Section XVI.D.6.b.(v)). 1.6.4.3 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) (Colorado Regulation No. 7, Section XVI.D.6.b.(vi)(B)). 1.6.4.4 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.(i)): a. The owner or operator may conduct the combustion process adjustment according to the manufacturer recommended procedures and schedule. 1.6.5 All sources qualifying for an exemption under Section XVI.D.2. (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-f. and XVI.D.8) must maintain all records necessary to demonstrate that an exemption applies (Colorado Regulation No. 7, Section XVI.D.7.g). Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 2. Portable Monitoring (6/26/14 version) Public Service Company of Colorado Yosemite Air Blend Plant Page 17 Emission measurements of nitrogen oxides (NOx) and carbon monoxide (CO) shall be conducted quarterly using a portable flue gas analyzer. At least one calendar month shall separate the quarterly tests. Note that if the engine is operated for less than 100 hrs in any quarterly period, then the portable monitoring requirements do not apply. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's website at: https://www.colorado.gov/pacific/cdphe/portable-analyzer-monitoring-protocol Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual or short term emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. For comparison with the emission rates/factors, the emission rates/factors determined by the portable analyzer tests and approved by the Division shall be converted to the same units as the emission rates/factors in the permit. If the portable analyzer tests shows that either the NOX or CO emission rates/factors are greater than the relevant ones set forth in the permit, and in the absence of subsequent testing results to the contrary (as approved by the Division), the permittee shall apply for a modification to this permit to reflect, at a minimum, the higher emission rate/factor within 60 days of the completion of the test. Results of all tests conducted shall be kept on site and made available to the Division upon request. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 3. Insignificant Activities Public Service Company of Colorado Yosemite Air Blend Plant Page 18 A potential to emit (PTE) analysis of CO emissions from insignificant activities shall be conducted and retained on site. The CO PTE from insignificant activities shall be summed together with the CO PTE from the significant emission units (included in Section II of this permit) to determine the facility wide PTE and retained on site to be made available to the Division upon request. Based on the information available as of the renewal permit issuance [®], the insignificant activities to be included in the above analysis are the space heating boiler, the hot water heater, radiant heater, and the two emergency generators (Section II.4). The above analysis shall be updated if any new insignificant activities that can potentially emit CO emissions are added to the facility. In the event that the revised analysis indicates that the facility wide PTE of CO equals or exceeds 250 tons per year, the permittee shall submit, within thirty (30) days, an application to modify this permit to revise Section I, Condition 3.1 to appropriately categorize this source as a major stationary source for purposes of PSD review requirements. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 4. E008 & E009 - Natural Gas -Fired Emergency Generators Public Service Company of Colorado Yosemite Air Blend Plant Page 19 Parameter Permit Condition Limitations Compliance Emission Monitoring Number Factor Method Interval MACT ZZZZ Requirements 4.1 Change Oil and Filter Inspect Spark Plugs Inspect all Hoses and Belts Opacity 4.2 Not to Exceed 20% Except as Provided for Below See Condition 4.1 Fuel Restriction Only Natural Gas is Used as Fuel Note that these emission units are exempt from the APEN reporting requirements in Regulation No. 3, Part A and the construction permit requirements in Regulation No. 3, Part B as long as actual, uncontrolled emissions do not exceed the APEN de minimis level. 4.1 These engines are subject to the requirements in 40 CFR Part 63 Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", as follows: The requirements below reflect the rule language in 40 CFR Part 63 Subpart ZZZZ as of the latest revisions to 40 CFR Part 63 Subpart ZZZZ published in the Federal Register on February 27, 2014. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63 Subpart ZZZZ. The D.C. Circuit Court issued a mandate on May 4, 2016 for vacatur for certain requirements allowing emergency engines to operate for limited hours for demand response. Upon issuance of the mandate, 40 CFR Part §63.6640(f)(2)(ii) - (iii) (Conditions 4.1.9.2.b and 4.1.9.2.c) have no legal effect. Operation of emergency engines is limited to emergency situations specified in §63.6640(0(1) (Condition 4.1.9.1); maintenance checks and readiness testing for a limited number of hours per year as specified in §63.6640(0(2)(i) (Condition 4.1.9.2.a); and certain non -emergency situations for a limited number of hours per year as specified in §63.6640(O(3) (Condition 4.1.9.3). See EPA memorandum dated April 15, 2016 regarding "Guidance on Vacatur of RICE NESHAP and NSPS Provisions for Emergency Engines" for more information. It should be noted that additional revisions to the requirements to 40 CFR Part 63 Subpart ZZZZ are expected to be made in response to issues related to legal action associated with the allowable hours of operation provisions for emergency engines regarding engines used for demand response. If such revisions are finalized prior to issuance of the permit, they will be included in the permit. As of the date of this permit issuance [ ], the requirements in 40 CFR Part 63 Subpart ZZZZ promulgated after July 1, 2007 have not been adopted into Colorado Regulation No. 8, Part E and are therefore not state -enforceable. In the event that these requirements are adopted into Colorado Regulations, they will become state -enforceable. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 20 What emission limitations and other requirements must I meet if I own or operate an existing Stationary RICE located with a site rating of equal to or less than 500 brake hp located at a major source of HAP emissions (sC 63.6602) 4.1.1 If you own or operate an existing stationary RICE with a site rating of equal to or less than 500 brake HP located at a major source of HAP emissions, you must comply with the emission limitations and other requirements in Table 2c to this subpart which apply to you. Compliance with the numerical emission limitations established in this subpart is based on the results of testing the average of three 1 -hour runs using the testing requirements and procedures in § 63.6620 and Table 4 to this subpart. (63.6602) The requirements in Table 2c that apply to these emergency engines are as follows: You must meet the following requirements, except during periods of startup: 4.1.1.1 Change oil and filter every 500 hours of operation or annually whichever comes first. (Table 2c, item 6.a) 4.1.1.2 Inspect spark plugs every 1,000 hours of operation or annually whichever comes first, and replace as necessary. (Table 2c, item 6.b) 4.1.1.3 Inspect all hoses and belts every 500 hours of operation or annually whichever comes first, and replace as necessary. (Table 2c, item 6.c) During periods of startup you must: 4.1.1.4 Minimize the engine's time spent at idle and minimize the engine's startup time at startup to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the non -startup emission limitations apply. (Table 2c) Notwithstanding the above requirements, the following applies: 4.1.1.5 If an emergency engine is operating during an emergency and it is not possible to shut down the engine in order to perform the work practice requirements on the schedule required in Table 2c of this subpart, or if performing the work practice on the required schedule would otherwise pose an unacceptable risk under Federal, State, or local law, the work practice can be delayed until the emergency is over or the unacceptable risk under Federal, State, or local law has abated. The work practice should be performed as soon as practicable after the emergency has ended or the unacceptable risk under Federal, State, or local law has abated. Sources must report any failure to perform the work practice on the schedule required and the Federal, State or local law under which the risk was deemed unacceptable. (Table 2c, footnote 1) 4.1.1.6 Sources have the option to utilize an oil analysis program as described in Condition 4.1.7 in order to extend the specified oil change requirement in Condition 4.1.1.1. (Table 2c, footnote 2) 4.1.1.7 Sources can petition the Administrator pursuant to the requirements of 40 CFR 63.6(g) for alternative work practices. (Table 2c, footnote 3) Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 21 What are my general requirements for complying with this subpart? (' 63.6605) 4.1.2 You must be in compliance with the emission limitations, operating limitations and other requirements in this subpart that apply to you at all times. (63.6605(a)) 4.1.3 At all times you must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Division which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. (63.6605(b)) What are my monitoring, installation, collection, operation, and maintenance requirements? 63.6625) 4.1.4 If you own or operate any of the following stationary RICE, you must operate and maintain the stationary RICE and after -treatment control device (if any) according to the manufacturer's emission -related written instructions or develop your own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. (63.6625(e)) As noted in § 63.6625(e)(2), an existing emergency or black start stationary RICE with a site rating of less than or equal to 500 hp located at a major source of HAP emissions is subject to the requirements in this paragraph. 4.1.5 If you own or operate an existing emergency stationary RICE with a site rating of less than or equal to 500 brake HP located at a major source of HAP emissions or an existing emergency stationary RICE located at an area source of HAP emissions, you must install a non-resettable hour meter if one is not already installed. (63.6625(f)) 4.1.6 If you operate a new or existing stationary engine, you must minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the emission standards applicable to all times other than startup in Tables 1 a, 2a, 2c, and 2d to this subpart apply. (63.6625(h)) 4.1.7 If you own or operate a stationary SI engine that is subject to the work, operation or management practices in Condition 4.1.1, you have the option of utilizing an oil analysis program in order to extend the specified oil change requirement in Condition 4.1.1.1. The oil analysis must be performed at the same frequency specified for changing the oil in Condition 4.1.1.1. The analysis program must at a minimum analyze the following three parameters: Total Acid Number, viscosity, and percent water content. The condemning limits for these parameters are as follows: Total Acid Number increases by more than 3.0 milligrams of potassium hydroxide (KOH) per Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 22 gram from Total Acid Number of the oil when new; viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or percent water content (by volume) is greater than 0.5. If all of these condemning limits are not exceeded, the engine owner or operator is not required to change the oil. If any of the limits are exceeded, the engine owner or operator must change the oil within 2 days of receiving the results of the analysis; if the engine is not in operation when the results of the analysis are received, the engine owner or operator must change the oil within 2 days or before commencing operation, whichever is later. The owner or operator must keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes for the engine. The analysis program must be part of the maintenance plan for the engine. (63.6625(j)) How do I demonstrate continuous compliance with the emission limitations and operating limitations? (. 63.6640) 4.1.8 You must demonstrate continuous compliance with each emission limitation, operating limitation and other requirements in Tables la and lb, Tables 2a and 2b, Table 2c, and Table 2d [Condition 4.1.1 ] to this subpart that apply to you according to methods specified in Table 6 to this subpart. (63.6640(a)) The methods specified in Table 6 of Subpart ZZZZ are as follows: 4.1.8.1 Operating and maintaining the stationary RICE according to the manufacturer's emission -related operation and maintenance instructions (Subpart ZZZZ, Table 6, item 9.a.i); or 4.1.8.2 Develop and follow your own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. (Subpart ZZZZ, Table 6, item 9.a.ii) 4.1.9 If you own or operate an emergency stationary RICE, you must operate the emergency stationary RICE according to the requirements in Conditions 4.1.9.1 through 4.1.9.3. In order for the engine to be considered an emergency stationary RICE under this subpart, any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non -emergency situations for 50 hours per year, as described in Conditions 4.1.9.1 through 4.1.9.3, is prohibited. If you do not operate the engine according to the requirements in Conditions 4.1.9.1 through 4.1.9.3, the engine will not be considered an emergency engine under this subpart and must meet all requirements for non -emergency engines. (63.6640(f)) 4.1.9.1 There is no time limit on the use of emergency stationary RICE in emergency situations. (63.6640(f)(1)) 4.1.9.2 You may operate your emergency stationary RICE for any combination of the purposes specified below for a maximum of 100 hours per calendar year. Any operation for non - emergency situations as allowed by Condition 4.1.9.3 counts as part of the 100 hours per calendar year allowed by this Condition 4.1.9.2. (63.6640(f)(2)) Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 23 a. Emergency stationary RICE may be operated for maintenance checks and readiness testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The owner or operator may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the owner or operator maintains records indicating that federal, state, or local standards require maintenance and testing of emergency RICE beyond 100 hours per calendar year. (63.6640(f)(2)(i)) b. Emergency stationary RICE may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see § 63.14), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-002-3. (63.6640(0(2)(ii)) c. Emergency stationary RICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency. (63.6640(f)(2)(iii)) 4.1.9.3 Emergency stationary RICE located at major sources of HAP may be operated for up to 50 hours per calendar year in non -emergency situations. The 50 hours of operation in non -emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in paragraph (0(2) of this section. The 50 hours per year for non -emergency situations cannot be used for peak shaving or non -emergency demand response, or to generate income for a facility to supply power to an electric grid or otherwise supply power as part of a financial arrangement with another entity. (63.6640(0(3)) What reports must I submit and when (5C 63.6650) 4.1.10 If you own or operate an emergency stationary RICE with a site rating of more than 100 brake HP that operates or is contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in § 63.6640(0(2)(ii) and (iii) (Conditions 4.1.9.2.b and c) or that operates for the purpose specified in § 63.6640(0(4)(ii), you must submit an annual report according to the requirements in 63.6650(h)(1) through (3). (63.6650(h)) What records must I keep? (' 63.6655) 4.1.1 1 You must keep records of the maintenance conducted on the stationary RICE in order to demonstrate that you operated and maintained the stationary RICE and after -treatment control device (if any) according to your own maintenance plan if you own or operate an existing stationary emergency. (63.6655(e) and (e)(2)) Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 24 4.1.12 If you own or operate an existing emergency stationary RICE with a site rating of less than or equal to 500 brake HP located at a major source of HAP emissions that does not meet the standards applicable to non -emergency engines., you must keep records of the hours of operation of the engine that is recorded through the non-resettable hour meter. The owner or operator must document how many hours are spent for emergency operation, including what classified the operation as emergency and how many hours are spent for non -emergency operation. If the engine is used for the purposes specified in § 63.6640(f)(2)(ii) or (iii) (Conditions 4.1.9.2.b or c) or § 63.6640(f)(4)(ii), the owner or operator must keep records of the notification of the emergency situation, and the date, start time, and end time of engine operation for these purposes. (63.6655(f) and 63.6655(f)(1)) In what form and how long must I keep my records? (sC 63.6660) 4.1.13 Records shall be kept in the form and for the duration specified in § 63.6660. What parts of the General Provisions apply to me? (sC 63.6665) 4.1.14 Table 8 of Subpart ZZZZ shows which parts of the General Provisions in §§63.1 through 63.15 apply to you. (63.6665) The general provisions that apply to this engine are as follows: 4.1.14.1 Prohibited activities in § 63.4(a). 4.1.14.2 Circumvention in § 63.4(b) 4.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). In the absence of credible evidence to the contrary, compliance with the 20% opacity requirement will be presumed since only natural gas is permitted to be used as fuel for these engines. The permittee shall maintain records that verify that only natural gas is used as fuel. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 5. M001 - Cold Cleaner Solvent Vats Public Service Company of Colorado Yosemite Air Blend Plant Page 25 Parameter Permit Condition Number Limitations Compliance Emission Factor Monitoring Method Interval Work Practice Standards 5.1 Internal Audit Annually Transfer and Storage of Waste/Used Solvents 5.2 Certification Annually Note that these emission units are exempt from the APEN reporting requirements in Regulation No. 3, Part A and the construction permit requirements in Regulation No. 3, Part B. 5.1 Operation of the cold cleaner solvent vats shall meet the standards defined in Colorado Regulation 7, Section X.B. as follows: 5.1.1 Control Equipment (Colorado Regulation No. 7, Section X.B.1.): 5.1.1.1 Covers (Colorado Regulation No. 7, Section X.B.1.a.): a. All cold -cleaners shall have a properly fitting cover (Colorado Regulation No. 7, Section X.B.I .a.(i)). b. Covers shall be designed to be easily operable with one hand under any of the following conditions (Colorado Regulation No. 7, Section X.B.I .a.(ii)): (i) The solvent is agitated by an agitating mechanism (Section X.B.I .a.(ii)(B)). (ii) The solvent is heated (Section X.B.1.a.(ii)(C)). 5.1.1.2 Drainage Facility (except for requirements that are applicable to solvent which has a vapor pressure greater than 32 torr (0.62 psia) measured at 38°C (100°F)) (Colorado Regulation No. 7, Section X.B.1.b.): a. All cold -cleaners shall have a drainage facility that captures the drained liquid solvent from the cleaned parts (Colorado Regulation No. 7, Section X.B.1.b.(i)). 5.1.1.3 A permanent, clearly visible sign shall be mounted on or next to the cold -cleaner. The sign shall list the operating requirements (Colorado Regulation No. 7, Section X.B.I.c.). 5.1.2 Solvent spray apparatus shall not have a splashing, fine atomizing, or shower type action but rather should produce a solid, cohesive stream. Solvent spray shall be used at a pressure that does not cause excessive splashing (Colorado Regulation No. 7, Section X.B.1.d.). Compliance shall be monitored by following the work practices defined in Public Service Company's Policy Manual regarding operation, maintenance and design of the cold cleaner solvent vats. The Policy Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 26 Manual shall include, at a minimum the requirements defined in Colorado Regulation 7, Section X.B above, and shall be available to the inspector upon request. Audits of the vat operations and/or the policy manual shall be performed annually to ensure that operations are performed within the requirements of the policy manual and that the policy manual incorporates the requirements of Regulation 7, Section X.B. Audit reports are to be maintained and made available to the Division upon request. 5.2 The transfer and storage of waste and used solvents from the cold cleaner solvent vats are subject to the following requirements (Colorado Regulation No. 7, Section X.A.3 and 4): 5.2.1 In any disposal or transfer of waste or used solvent, at least 80 percent by weight of the solvent/waste liquid shall be retained (i.e., no more than 20 percent of the liquid solvent/solute mixture shall evaporate or otherwise be lost during transfers). 5.2.2 Waste or used solvents shall be stored in closed containers unless otherwise required by law. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 SECTION III - Permit Shield Public Service Company of Colorado Yosemite Air Blend Plant Page 27 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 -Wide Reg 1.III.A. — Particulate emissions from fuel - burning equipment Reg 1.VI.B. - Sulfur dioxide emissions from fuel- burning equipment Internal combustion engines and incinerators are not considered fuel burning equipment for the applicable requirements of Regulation 1. Reg. 7, IV.B - Storage of Petroleum Liquids Facility does not store petroleum liquids Reg. 7, VII — Crude Oil Facility does not store crude oil 40 CFR Part 60, Subpart KKK, as adopted by reference in Colorado Regulation No. 6, Part A This facility is not a natural gas processing plant. Colorado Regulation No. 3, Part D, Section VI — Prevention of Significant Deterioration requirements This source is a minor stationary source based on the potential to emit of the source as determined by information provided by the applicant. 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 25-7-1 13, 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; Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 28 2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to §25-7- 111(2)(1), C.R.S., or the ability of the Administrator to obtain information pursuant to § 114 of the federal act; 2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit for cause pursuant to Regulation No. 3, Part C, § XIII. 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. Permit Condition(s) Streamlined (Subsumed) Requirements Section II, Condition 1.6 Colorado Regulation No. 7, Section XVII.B. l.a and E.3.b [general provisions for air pollution control equipment and requirement to install oxidation catalyst on 4 -cycle lean burn engines greater than 500 hp] Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 29 SECTION IV - General Permit Conditions (ver 8/28/18) 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, §§111.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 § [I.A., 11.B., ILC., lI E., lIP., 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 Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 30 The Division may require owners or operators of stationary air pollution sources to install, maintain, and use instrumentation to monitor and record emission data as a basis for periodic reports to the Division. c. Performance Testing The owner or operator of any air pollution source shall, upon request of the Division, conduct performance test(s) and furnish the Division a written report of the results of such test(s) in order to determine compliance with applicable emission control regulations. Performance test(s) shall be conducted and the data reduced in accordance with the applicable reference test methods unless the Division: (i) specifies or approves, in specific cases, the use of a test method with minor changes in methodology; (ii) approves the use of an equivalent method; (iii) approves the use of an alternative method the results of which the Division has determined to be adequate for indicating where a specific source is in compliance; or (iv) waives the requirement for performance test(s) because the owner or operator of a source has demonstrated by other means to the Division's satisfaction that the affected facility is in compliance with the standard. Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to require testing under the Colorado Revised Statutes, Title 25, Article 7, and pursuant to regulations promulgated by the Commission. Compliance test(s) shall be conducted under such conditions as the Division shall specify to the plant operator based on representative performance of the affected facility. The owner or operator shall make available to the Division such records as may be necessary to determine the conditions of the performance test(s). Operations during period of startup, shutdown, and malfunction shall not constitute representative conditions of performance test(s) unless otherwise specified in the applicable standard. The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance test to afford the Division the opportunity to have an observer present. The Division may waive the thirty day notice requirement provided that arrangements satisfactory to the Division are made for earlier testing. The owner or operator of an affected facility shall provide, or cause to be provided, performance testing facilities as follows: (i) Sampling ports adequate for test methods applicable to such facility; (ii) Safe sampling platform(s); (iii) Safe access to sampling platform(s); and (iv) Utilities for sampling and testing equipment. Each performance test shall consist of at least three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specified in the applicable standard. For the purpose of determining compliance with an applicable standard, the arithmetic mean of results of at least three runs shall apply. In the event that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other circumstances beyond the owner or operator's control, compliance may, upon the Division's approval, be determined using the arithmetic mean of the results of the two other runs. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 31 Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s) if so warranted. d. Affirmative Defense Provision for Excess Emissions during Malfunctions An affirmative defense to a claim of violation under these regulations is provided to owners and operators for civil penalty actions for excess emissions during periods of malfunction. To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement, the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of evidence that: (i) The excess emissions were caused by a sudden, unavoidable breakdown of equipment, or a sudden, unavoidable failure of a process to operate in the normal or usual manner, beyond the reasonable control of the owner or operator; (ii) The excess emissions did not stem from any activity or event that could have reasonably been foreseen and avoided, or planned for, and could not have been avoided by better operation and maintenance practices; (iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being exceeded; (iv) The amount and duration of the excess emissions (including any bypass) were minimized to the maximum extent practicable during periods of such emissions; (v) All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation (if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed, contemporaneous operating logs or other relevant evidence; (viii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation, or maintenance; (ix) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions. This section is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator, and shall not constitute an additional applicable requirement; and (x) During the period of excess emissions, there were no exceedances of the relevant ambient air quality standards established in the Commissions' Regulations that could be attributed to the emitting source. The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division verbally as soon as possible, but no later than noon of the Division's next working day, and shall submit written notification following the initial occurrence of the excess emissions by the end of the source's next reporting period. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. The Affirmative Defense Provision does not apply to failures to meet federally promulgated performance standards or emission limits, including, but not limited to, new source performance standards and national emission standards for hazardous air pollutants. The affirmative defense provision does not apply to state implementation plan (sip) limits or permit limits that have been set taking into account potential emissions during malfunctions, including, but not necessarily limited to, certain limits with 30 -day or longer averaging times, limits that indicate they apply during malfunctions, and limits that indicate they apply at all times or without exception. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 e. Circumvention Clause Public Service Company of Colorado Yosemite Air Blend Plant Page 32 A person shall not build, erect, install, or use any article, machine, equipment, condition, or any contrivance, the use of which, without resulting in a reduction in the total release of air pollutants to the atmosphere, reduces or conceals an emission which would otherwise constitute a violation of this regulation. No person shall circumvent this regulation by using more openings than is considered normal practice by the industry or activity in question. f. Compliance Certifications 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. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 33 The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements that derive from new source performance standards or national emissions standards for hazardous air pollutants, or any other federally enforceable performance standard or emission limit with an averaging time greater than twenty-four hours. In addition, an affirmative defense cannot be used by a single source or small group of sources where the excess emissions have the potential to cause an exceedance of the ambient air quality standards or Prevention of Significant Deterioration (PSD) increments. In making any determination whether a source established an affirmative defense, the Division shall consider the information within the notification required above and any other information the Division deems necessary, which may include, but is not limited to, physical inspection of the facility and review of documentation pertaining to the maintenance and operation of process and air pollution control equipment. 4. Compliance Requirements Regulation No. 3, 5 CCR 1001-5, Part C, III.C.9., V.C.11. & 16.d. and § 25-7-122.1(2), C.R.S. a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to federally -enforceable terms or conditions constitutes a violation of the federal act, as well as the state act and Regulation No. 3. Any permit noncompliance relating to state -only terms or conditions constitutes a violation of the state act and Regulation No. 3, shall be enforceable pursuant to state law, and shall not be enforceable by citizens under § 304 of the federal act. Any such violation of the federal act, the state act or regulations implementing either statute is grounds for enforcement action, for permit termination, revocation and reissuance or modification or for denial of a permit renewal application. b. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a permit termination, revocation or modification action or action denying a permit renewal application that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. c. The permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of any request by the permittee for a permit modification, revocation and reissuance, or termination, or any notification of planned changes or anticipated noncompliance does not stay any permit condition, except as provided in §§ X. and XI. of Regulation No. 3, Part C. d. The permittee shall furnish to the Air Pollution Control Division, within a reasonable time as specified by the Division, any information that the Division may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit or to determine compliance with the permit. Upon request, the permittee shall also furnish to the Division copies of records required to be kept by the permittee, including information claimed to be confidential. Any information subject to a claim of confidentiality shall be specifically identified and submitted separately from information not subject to the claim. e. Any schedule for compliance for applicable requirements with which the source is not in compliance at the time of permit issuance shall be supplemental, and shall not sanction noncompliance with, the applicable requirements on which it is based. f. For any compliance schedule for applicable requirements with which the source is not in compliance at the time of permit issuance, the permittee shall submit, at least every 6 months unless a more frequent period is specified in the applicable requirement or by the Air Pollution Control Division, progress reports which contain the following: (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 Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 g. Public Service Company of Colorado Yosemite Air Blend Plant Page 34 (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. 5. Emergency Provisions Regulation No. 3, 5 CCR 1001-5, Part C, § VII An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed the technology -based emission limitation under the permit due to unavoidable increases in emissions attributable to the emergency. "Emergency" does not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. An emergency constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology -based emission limitation if the permittee demonstrates, through properly signed, contemporaneous operating logs, or other relevant evidence that: a. an emergency occurred and that the permittee can identify the cause(s) of the emergency; b. the permitted facility was at the time being properly operated; c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards, or other requirements in the permit; and d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the next working day following the emergency, and followed by written notice within one month of the time when emissions limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement. 6. Emission Controls for Asbestos Regulation No. 8, 5 CCR 1001-10, Part B The permittee shall not conduct any asbestos abatement activities except in accordance with the provisions of Regulation No. 8, Part B, "asbestos control." 7. Emissions Trading, Marketable Permits, Economic Incentives Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.I3. No permit revision shall be required under any approved economic incentives, marketable permits, emissions trading and other similar programs or processes for changes that are specifically provided for in the permit. 8. Fee Payment C.R.S §§ 25-7-114.1(6) and 25-7-114.7 a. The permittee shall pay an annual emissions fee in accordance with the provisions of C.R.S. § 25-7-114.7. A 1% per month late payment fee shall be assessed against any invoice amounts not paid in full on the 91st day after the date of invoice, unless a permittee has filed a timely protest to the invoice amount. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 35 b. The permittee shall pay a permit processing fee in accordance with the provisions of C.R.S. § 25-7-114.7. If the Division estimates that processing of the permit will take more than 30 hours, it will notify the permittee of its estimate of what the actual charges may be prior to commencing any work exceeding the 30 hour limit. c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S. § 25-7-114.1(6) for each APEN or revised APEN filed. 9. Fugitive Particulate Emissions Regulation No. 1, 5 CCR 1001-3, § 1II_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.I . 10. Inspection and Entry Regulation No. 3, 5 CCR 1001-5, Part C, V.C.16.b. Upon presentation of credentials and other documents as may be required by law, the permittee shall allow the Air Pollution Control Division, or any authorized representative, to perform the following: a. enter upon the permittee's premises where an Operating Permit source is located, or emissions -related activity is conducted, or where records must be kept under the terms of the permit; b. have access to, and copy, at reasonable times, any records that must be kept under the conditions of the permit; c. inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under the Operating Permit; d. sample or monitor at reasonable times, for the purposes of assuring compliance with the Operating Permit or applicable requirements, any substances or parameters. 11. Minor Permit Modifications Regulation No. 3, 5 CCR 1001-5, Part C, §§ X. & Xl. The permittee shall submit an application for a minor permit modification before making the change requested in the application. The permit shield shall not extend to minor permit modifications. 12. New Source Review Regulation No. 3, 5 CCR 1001-5, 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 Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 36 Regulation No. 2, 5 CCR 1001-4, Part A As a matter of state law only, the permittee shall comply with the provisions of Regulation No. 2 concerning odorous emissions. 15. Off -Permit Changes to the Source Regulation No. 3, 5 CCR 1001-5, Part C, XII.B. The permittee shall record any off -permit change to the source that causes the emissions of a regulated pollutant subject to an applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from the change, including any other data necessary to show compliance with applicable ambient air quality standards. The permittee shall provide contemporaneous notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permit shield shall not apply to any off -permit change. 16. Opacity Regulation No. 1, 5 CCR 1001-3, §§ I., II. The permittee shall comply with the opacity emissions limitation set forth in Regulation No. I, §§ I.- II. 17. Open Burning Regulation No. 9, 5 CCR 1001-11 The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions of Regulation No. 9. 18. Ozone Depleting Compounds Regulation No. 15, 5 CCR 1001-19 The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds. Sections I., II.C., II.D., III. IV., and V. of Regulation No. 15 shall be enforced as a matter of state law only. 19. Permit Expiration and Renewal Regulation No. 3, 5 CCR 1001-5, Part C, §§ III.B.6., IV.C., V.C.2. a. The permit term shall be five (5) years. The permit shall expire at the end of its term. Permit expiration terminates the permittee's right to operate unless a timely and complete renewal application is submitted. b. Applications for renewal shall be submitted at least twelve months, but not more than 18 months, prior to the expiration of the Operating Permit. An application for permit renewal may address only those portions of the permit that require revision, supplementing, or deletion, incorporating the remaining permit terms by reference from the previous permit. A copy of any materials incorporated by reference must be included with the application. 20. Portable Sources Regulation No. 3, 5 CCR 1001-5, Part C, § II.D. Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in location. 21. Prompt Deviation Reporting Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 37 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; (ii) For emissions of any regulated air pollutant, excluding a hazardous air pollutant or a toxic air pollutant that continue for more than two hours in excess of permit requirements, the report shall be made within 48 hours; and (iii) For all other deviations from permit requirements, the report shall be submitted every six (6) months, except as otherwise specified by the Division in the permit in accordance with paragraph 22.d. below. c. If any of the conditions in paragraphs b.i or b.ii above are met, the source shall notify the Division by telephone (303-692-3155) or facsimile (303-782-0278) based on the timetables listed above. [Explanatory note: Notification by telephone or facsimile must specs that this notification is a deviation report for an Operating Permit.] A written notice, certified consistent with General Condition 2.a. above (Certification Requirements), shall be submitted within 10 working days of the occurrence. All deviations reported under this section shall also be identified in the 6 - month report required above. "Prompt reporting" does not constitute an exception to the requirements of "Emergency Provisions" for the purpose of avoiding enforcement actions. 22. Record Keeping and Reporting Requirements Regulation No. 3, 5 CCR 1001-5, Part A, § II.; Part C, §§ V.C.6., V.C.7. a. Unless otherwise provided in the source specific conditions of this Operating Permit, the permittee shall maintain compliance monitoring records that include the following information: (i) date, place as defined in the Operating Permit, and time of sampling or measurements; (ii) date(s) on which analyses were performed; (iii) the company or entity that performed the analysis; (iv) the analytical techniques or methods used; (v) the results of such analysis; and (vi) the operating conditions at the time of sampling or measurement. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 38 b. The permittee shall retain records of all required monitoring data and support information for a period of at least five (5) years from the date of the monitoring sample, measurement, report or application. Support information, for this purpose, includes all calibration and maintenance records and all original strip -chart recordings for continuous monitoring instrumentation, and copies of all reports required by the Operating Permit. With prior approval of the Air Pollution Control Division, the permittee may maintain any of the above records in a computerized form. c. Permittees must retain records of all required monitoring data and support information for the most recent twelve (12) month period, as well as compliance certifications for the past five (5) years on -site at all times. A permittee shall make available for the Air Pollution Control Division's review all other records of required monitoring data and support information required to be retained by the permittee upon 48 hours advance notice by the Division. d. The permittee shall submit to the Air Pollution Control Division all reports of any required monitoring at least every six (6) months, unless an applicable requirement, the compliance assurance monitoring rule, or the Division requires submission on a more frequent basis. All instances of deviations from any permit requirements must be clearly identified in such reports. e. The permittee shall file an Air Pollutant Emissions Notice ("APEN") prior to constructing, modifying, or altering any facility, process, activity which constitutes a stationary source from which air pollutants are or are to be emitted, unless such source is exempt from the APEN filing requirements of Regulation No. 3, Part A, § II.D. A revised APEN shall be filed annually whenever a significant change in emissions, as defined in Regulation No. 3, Part A, § II.C.2., occurs; whenever there is a change in owner or operator of any facility, process, or activity; whenever new control equipment is installed; whenever a different type of control equipment replaces an existing type of control equipment; whenever a permit limitation must be modified; or before the APEN expires. An APEN is valid for a period of five years. The five-year period recommences when a revised APEN is received by the Air Pollution Control Division. Revised APENs shall be submitted no later than 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 Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Regulation No. 3, 5 CCR 1001-5, Part D, §§ V.A.7.c & d, VI.B.5 & VI.B.6 Public Service Company of Colorado Yosemite Air Blend Plant Page 39 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. 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 Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 40 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 "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, l V.C.I .b. & 8 a. Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations promulgated under Title IV of the federal act, 40 Code of Federal Regulations (CFR) Part 72, both provisions shall be incorporated into the permit and shall be federally enforceable. b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal act or the regulations promulgated thereunder, 40 CFR Part 72, are expressly prohibited. 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. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 41 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 Regulation No. 415 CCR 1001-6 The permittee shall comply with the provisions of Regulation No. 4 concerning the advertisement, sale, installation, and use of wood stoves and wood burning appliances. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit # 02OPWE247 Public Service Company of Colorado Yosemite Air Blend Plant Page 42 OPERATING PERMIT APPENDICES A - INSPECTION INFORMATION B - MONITORING AND PERMIT DEVIATION REPORT C - COMPLIANCE CERTIFICATION REPORT D - NOTIFICATION ADDRESSES E - PERMIT ACRONYMS F - PERMIT MODIFICATIONS G - ENGINE AOS APPLICABILITY REPORTS *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 Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Inspection Information APPENDIX A - Inspection Information 1. Directions to Plant: Appendix A Page 43 The facility is located at 934 Weld County Road 19, Brighton. Travel West from Brighton, 3.2 miles on Highway 7 to County Road 2. Turn west and travel 0.1 miles to County Road 19. Turn north and travel 1 mile to the compressor station. 2. Safety Equipment Required: Eye Protection, Hard Hat, Safety Shoes and Hearing Protection 3. Facility Plot Plan: The attached figures (following pages) shows the plot plan as submitted in the August 19, 2002 Title V Operating Permit Application. 4. List of Insignificant Activities: The following list of insignificant activities was provided by the source to assist in the understanding of the facility layout. Since there is no requirement to update such a list, activities may have changed since the last filing. The asterisk (*) denotes an insignificant activity source category based on the size of the activity, emissions levels from the activity or the production rate of the activity. The owner or operator of individual emission points in insignificant activity source categories marked with an asterisk (*) must maintain sufficient record keeping verifying that the exemption applies. Such records shall be made available for Division review upon request. (Colorado Regulation No. 3, Part C, Section II.E) Insignificant activities and/or sources of emissions identified by the permittee are as follows: Units with emission less than APEN de minimis (Reg 3, Part C.II.E.3.a)* Natural gas leaks from valves and flanges (VOC emissions < 1 ton/yr) Natural gas venting during system blowdowns (VOC emissions < 1 ton/yr) North and South evaporation ponds for liquids (VOC emissions < 1 ton/yr) Particulate emissions from travel along unpaved surfaces (PM and PMio emissions < 2 ton/yr) Fuel (gaseous) burning equipment < 5 mmBtu/hr (Reg 3 Part C.II.E.3.k)* Hot water heater (0.04 mmBtu/hr), space heating for office Chemical storage tanks or containers < 500 gal (Reg 3 Part C.Il.E.3.n)* Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed. Air Pollution Control Division Colorado Operating Permit Inspection Information Coolant (ethylene glycol) — sixteen (1 6) 55 gal drums and two (2) 300 gal totes Methanol — four (4) 55 gal drums Coolant (ethylene glycol) — one (1) 150 gal tank Chemical storage areas < 5,000 gal capacity (Reg 3 Part C.II.E.3.mm)* Appendix A Page 44 Odorant tanks (above ground mercaptan storage) — four (4) tanks 1,000 gal, ea; one (1) tank 60 gal, and two (2) tanks 1,990 gal, ea. Lubricating/Waste oil storage tanks < 40,000 gal (Reg 3 Part C.II.E.3.aaa) Four (4) lube oil tanks, 300 gal aboveground One (1) used lube oil tank, 420 gal aboveground Five (5) lube oil tanks, 500 gal aboveground Three (3) used lube oil tanks, 450 gal aboveground One (1) lube oil tank, 200 gal aboveground Twenty three (23) 55 gal drums Fuel burning equipment < 10 MMBtu/hr used for comfort heat (Reg 3, Part C.II.E.ggg) Space heating boiler (0.215 mmBtu/hr), heats office, shop and compressor building Radiant heaters, 0.075 and 0.150 MMBtu/hr heaters for compressor buildings Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Inspection Information U Figure 1: Facility Plot Plan Yosemite Air Blend Plant — North Site Appendix A Page 45 Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Inspection Information Figure 2: Facility Plot Plan Yosemite Air Blend Plant — South Site 1 Appendix A Page 46 Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: I Air Pollution Control Division Colorado Operating Permit Inspection Information uI w zcn 2oLLI 17-1 1— >-ccoz ,1 man i ININI Li 1 Figure 3: Facility Plot Plan Yosemite Air Blend Plant — Entire Site Appendix A Page 47 Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Reporting Requirements Appendix B Page 48 APPENDIX B Reporting Requirements and Definitions with codes ver 8/20/14 Please note that, pursuant to 113(c)(2) of the federal Clean Air Act, any person who knowingly: (A) makes any false material statement, representation, or certification in, or omits material information from, or knowingly alters, conceals, or fails to file or maintain any notice, application, record, report, plan, or other document required pursuant to the Act to be either filed or maintained (whether with respect to the requirements imposed by the Administrator or by a State); (B) fails to notify or report as required under the Act; or (C) falsifies, tampers with, renders inaccurate, or fails to install any monitoring device or method required to be maintained or followed under the Act shall, upon conviction, be punished by a fine pursuant to title 18 of the United States Code, or by imprisonment for not more than 2 years, or both. If a conviction of any person under this paragraph is for a violation committed after a first conviction of such person under this paragraph, the maximum punishment shall be doubled with respect to both the fine and imprisonment. The permittee must comply with all conditions of this operating permit. Any permit noncompliance constitutes a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. The Part 70 Operating Permit program requires three types of reports to be filed for all permits. All required reports must be certified by a responsible official. Report #1: Monitoring Deviation Report (due at least every six months) For purposes of this operating permit, the Division is requiring that the monitoring reports are due every six months unless otherwise noted in the permit. All instances of deviations from permit monitoring requirements must be clearly identified in such reports. For purposes of this operating permit, monitoring means any condition determined by observation, by data from any monitoring protocol, or by any other monitoring which is required by the permit as well as the recordkeeping associated with that monitoring. This would include, for example, fuel use or process rate monitoring, fuel analyses, and operational or control device parameter monitoring. Report #2: Permit Deviation Report (must be reported "promptly") In addition to the monitoring requirements set forth in the permits as discussed above, each and every requirement of the permit is subject to deviation reporting. The reports must address deviations from permit requirements, including those attributable to malfunctions as defined in this Appendix, the probable cause of Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Reporting Requirements Appendix B Page 49 such deviations, and any corrective actions or preventive measures taken. All deviations from any term or condition of the permit are required to be summarized or referenced in the annual compliance certification. For purposes of this operating permit, "malfunction" shall refer to both emergency conditions and malfunctions. Additional discussion on these conditions is provided later in this Appendix. For purposes of this operating permit, the Division is requiring that the permit deviation reports are due as set forth in General Condition 21. Where the underlying applicable requirement contains a definition of prompt or otherwise specifies a time frame for reporting deviations, that definition or time frame shall govern. For example, quarterly Excess Emission Reports required by an NSPS or Regulation No. 1, Section IV. In addition to the monitoring deviations discussed above, included in the meaning of deviation for the purposes of this operating permit are any of the following: (1) A situation where emissions exceed an emission limitation or standard contained in the permit; (2) A situation where process or control device parameter values demonstrate that an emission limitation or standard contained in the permit has not been met; (3) A situation in which observations or data collected demonstrates noncompliance with an emission limitation or standard or any work practice or operating condition required by the permit; or, (4) A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. (only if the emission point is subject to CAM) For reporting purposes, the Division has combined the Monitoring Deviation Report with the Permit Deviation Report. All deviations shall be reported using the following codes: 1 = Standard: When the requirement is an emission limit or standard 2 = Process: When the requirement is a production/process limit 3 = Monitor: When the requirement is monitoring 4 = Test: When the requirement is testing 5 = Maintenance: When required maintenance is not performed 6 = Record: When the requirement is recordkeeping 7 = Report: When the requirement is reporting 8 = CAM: A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. 9 = Other: When the deviation is not covered by any of the above categories Report #3: Compliance Certification (annually, as defined in the permit) Submission of compliance certifications with terms and conditions in the permit, including emission limitations, standards, or work practices, is required not less than annually. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Reporting Requirements Appendix B Page 50 Compliance Certifications are intended to state the compliance status of each requirement of the permit over the certification period. They must be based, at a minimum, on the testing and monitoring methods specified in the permit that were conducted during the relevant time period. In addition, if the owner or operator knows of other material information (i.e. information beyond required monitoring that has been specifically assessed in relation to how the information potentially affects compliance status), that information must be identified and addressed in the compliance certification. The compliance certification must include the following: • The identification of each term or condition of the permit that is the basis of the certification; • Whether or not the method(s) used by the owner or operator for determining the compliance status with each permit term and condition during the certification period was the method(s) specified in the permit. Such methods and other means shall include, at a minimum, the methods and means required in the permit. If necessary, the owner or operator also shall identify any other material information that must be included in the certification to comply with section 113(c)(2) of the Federal Clean Air Act, which prohibits knowingly making a false certification or omitting material information; • The status of compliance with the terms and conditions of the permit, and whether compliance was continuous or intermittent. The certification shall identify each deviation and take it into account in the compliance certification. Note that not all deviations are considered violations.' • Such other facts as the Division may require, consistent with the applicable requirements to which the source is subject, to determine the compliance status of the source. The Certification shall also identify as possible exceptions to compliance any periods during which compliance is required and in which an excursion or exceedance as defined under 40 CFR Part 64 (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 Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Reporting Requirements Appendix B Page 51 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 Number: 02OPWE247 First Issued: 9/1/03 Renewed: l_, Air Pollution Control Division Colorado Operating Permit Reporting Requirements Appendix B Page 52 APPENDIX B: Monitoring and Permit Deviation Report - Part I 1. Following is the required format for the Monitoring and Permit Deviation report to be submitted to the Division as set forth in General Condition 21. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. 2. Part II of this Appendix B shows the format and information the Division will require for describing periods of monitoring and permit deviations, or malfunction or emergency conditions as indicated in the Table below. One Part II Form must be completed for each Deviation. Previously submitted reports (e.g. EER's or malfunctions) may be referenced and the form need not be filled out in its entirety. FACILITY NAME: Public Service Company of Colorado — Yosemite Air Blend Plant OPERATING PERMIT NO: 02OPWE247 REPORTING PERIOD:_ (see first page of the permit for specific reporting period and dates) Operating Permit Unit ID Unit Description Deviations noted During Period?' Deviation Code 2 Malfunction/Emergency Condition Reported During Period? YES NO YES NO E001 Waukesha Model No. L5108GL, Natural Gas Fired Combustion Engine, S/N 398630 E002 Waukesha, Model No. L5108GL, Natural Gas Fired Combustion Engine, S/N 398631 E003 Waukesha, Model No. 7042GL, Natural Gas Fired Combustion Engine, S/N C-10336/1 E004 Waukesha, Model No. 7042GL, Natural Gas Fired Combustion Engine, S/N C-11373/1 E005 Caterpillar, Model No. 3608, Natural Gas Fired Combustion Engine, S/N 4WF00199 E006 Caterpillar, Model No. G3612, Natural Gas Fired Combustion Engine, S/N BKE00197 E008 & E009 South Emergency Generator (Caterpillar, Model No. 3306SINA, S/N 07Y02652) North Emergency Generator (Caterpillar Model No. 3508LE, S/N CTN00169) M001 Cold Cleaner Solvent Vats 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: When the requirement is an emission limit or standard When the requirement is a production/process limit Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Reporting Requirements Appendix B Page 53 3 = Monitor: 4 = Test: 5 = Maintenance: 6 = Record: 7 = Report: 8=CAM: 9 = Other: 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 Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: __ Air Pollution Control Division Colorado Operating Permit Reporting Requirements Appendix B Page 54 APPENDIX B: Monitoring and Permit Deviation Report - Part II FACILITY NAME: Public Service Company of Colorado — Yosemite Air Blend Plant OPERATING PERMIT NO: 02OPWE247 REPORTING PERIOD: Is the deviation being claimed as an: Emergency Malfunction N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Operating Permit Condition Number Citation Explanation of Period of Deviation Duration (start/stop date & time) Action Taken to Correct the Problem Measures Taken to Prevent a Reoccurrence of the Problem Dates of Malfunctions/Emergencies Reported (if applicable) Deviation Code Division Code QA: SEE EXAMPLE ON THE NEXT PAGE Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: 1. ;" Air Pollution Control Division Colorado Operating Permit Reporting Requirements Appendix B Page 55 EXAMPLE FACILITY NAME: Acme Corp. OPERATING PERMIT NO: 96OPZZXXX REPORTING PERIOD: 1/1/04 - 6/30/06 Is the deviation being claimed as an: Emergency Malfunction XX N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Asphalt Plant with a Scrubber for Particulate Control - Unit XXX Operating Permit Condition Number Citation Section II, Condition 3.1 - Opacity Limitation Explanation of Period of Deviation Slurry Line Feed Plugged Duration START- 1730 4/10/06 END- 1800 4/10/06 Action Taken to Correct the Problem Line Blown Out Measures Taken to Prevent Reoccurrence of the Problem Replaced Line Filter Dates of Malfunction/Emergencies Reported (if applicable) 5/30/06 to A. Einstein, APCD Deviation Code Division Code QA: Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Reporting Requirements Appendix B Page 56 APPENDIX B: Monitoring and Permit Deviation Report - Part III REPORT CERTIFICATION SOURCE NAME: Public Service Company of Colorado — Yosemite Air Blend Plant FACILITY IDENTIFICATION NUMBER: 1230141 PERMIT NUMBER: 02OPWE247 REPORTING PERIOD:_ (see first page of the permit for specific reporting period and dates) All information for the Title V Semi -Annual Deviation Reports must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B. This signed certification document must be packaged with the documents being submitted. STATEMENT OF COMPLETENESS I have reviewed the information being submitted in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this submittal are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in Sub -Section 18- 1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of Sub -Section 25-7 122.1, C.R.S. Printed or Typed Name Title Signature of Responsible Official Date Signed Note: Deviation reports shall be submitted to the Division at the address given in Appendix D of this permit. No copies need be sent to the U.S. EPA. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Compliance Certification Reports Appendix C Page 57 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— Yosemite Blend Air Plant OPERATING PERMIT NO: 02OPWE247 REPORTING PERIOD: I. Facility Status During the entire reporting period, this source was in compliance with ALL terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference. The method(s) used to determine compliance is/are the method(s) specified in the Permit. With the possible exception of the deviations identified in the table below, this source was in compliance with all terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference, during the entire reporting period. The method used to determine compliance for each term and condition is the method specified in the Permit, unless otherwise indicated and described in the deviation report(s). Note that not all deviations are considered violations. Operating Permit Unit ID Unit Description Deviations Reported I Monitoring Method per Permit?' Was compliance continuous or intermittent?3 Previous Current YES NO Continuous Intermittent E001 Waukesha Model No. L5108GL, Natural Gas Fired Combustion Engine, S/N 398630 E002 Waukesha, Model No. L5108GL, Natural Gas Fired Combustion Engine, S/N 398631 E003 Waukesha, Model No. 7042GL, Natural Gas Fired Combustion Engine, S/N C-10336/1 E004 Waukesha, Model No. 7042GL, Natural Gas Fired Combustion Engine, S/N C-11373/1 E005 Caterpillar, Model No. 3608, Natural Gas Fired Combustion Engine, S/N 4WF00199 E006 Caterpillar, Model No. G3612, Natural Gas Fired Combustion Engine, S/N BKE00197 Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Compliance Certification Reports Appendix C Page 58 Operating Permit Unit ID Unit Description Deviations Reported' Monitoring Method per Permit?' Was compliance continuous or intermittent?3 Previous Current YES NO Continuous Intermittent E008 & E009 South Emergency Generator (Caterpillar, Model No. 3306SINA, S/N 07Y02652) North Emergency Generator (Caterpillar Model No. 3508LE, S/N CTN00169) M001 Cold Cleaner Solvent Vats General Conditions Insignificant Activities 4 If deviations were noted in a previous deviation report , put an "X" under "previous". If deviations were noted in the current deviation report (i.e. for the last six months of the annual reporting period), put an "X" under "current". Mark both columns if both apply. Note whether the method(s) used to determine the compliance status with each term and condition was the method(s) specified in the permit. If it was not, mark "no" and attach additional information/explanation. 3 Note whether the compliance status with of each term and condition provided was continuous or intermittent. "Intermittent Compliance" can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance has occurred. NOTE: The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the absence of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance for the duration of the reporting period. Therefore, if a source 1) conducts all of the monitoring and recordkeeping required in its permit, even if such activities are done periodically and not continuously, and if 2) such monitoring and recordkeeping does not indicate non- compliance, and if 3) the Responsible Official is not aware of any credible evidence that indicates non-compliance, then the Responsible Official can certify that the emission point(s) in question were in continuous compliance during the applicable time period. 'Compliance status for these sources shall be based on a reasonable inquiry using readily available information. II. Status for Accidental Release Prevention Program: A. This facility is subject is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act) B. If subject: The facility is is not in compliance with all the requirements of section 112(r). 1. A Risk Management Plan will be has been submitted to the appropriate authority and/or the designated central location by the required date. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: l . Air Pollution Control Division Colorado Operating Permit Compliance Certification Reports Appendix C Page 59 III. Certification All information for the Annual Compliance Certification must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B. This signed certification document must be packaged with the documents being submitted. I have reviewed this certification in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this certification are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Title Signature Date Signed NOTE: All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix D Page 60 APPENDIX D Notification Addresses (ver 2/5/2014) 1. Air Pollution Control Division Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit APCD-SS-B 1 4300 Cherry Creek Drive S. Denver, CO 80246-1530 ATTN: Matt Burgett 2. United States Environmental Protection Agency Compliance Notifications: Office of Enforcement, Compliance and Environmental Justice Mail Code 8ENF-T U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, Colorado 80202-1129 502(b)(10) Changes, Off Permit Changes: Office of Partnerships and Regulatory Assistance Mail Code 8P -AR U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, Colorado 80202-1129 Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit Acronyms Appendix E Page 61 APPENDIX E Permit Acronyms Listed Alphabetically: AIRS - Aerometric Information Retrieval System AP -42 - EPA Document Compiling Air Pollutant Emission Factors APEN - Air Pollution Emission Notice (State of Colorado) APCD - Air Pollution Control Division (State of Colorado) ASTM - American Society for Testing and Materials BACT - Best Available Control Technology BTU - British Thermal Unit CAA - Clean Air Act (CAAA = Clean Air Act Amendments) CCR - Colorado Code of Regulations CEM - Continuous Emissions Monitor CF - Cubic Feet (SCF = Standard Cubic Feet) CFR - Code of Federal Regulations CO - Carbon Monoxide COM - Continuous Opacity Monitor CRS - Colorado Revised Statute EF - Emission Factor EPA - Environmental Protection Agency FI - Fuel Input Rate in MMBtu/hr FR - Federal Register G - Grams Gal - Gallon GPM - Gallons per Minute HAPs - Hazardous Air Pollutants HP - Horsepower HP -HR Horsepower Hour (G/HP-HR = Grams per Horsepower Hour) LAER Lowest Achievable Emission Rate LBS - Pounds M - Thousand MM - Million MMscf - Million Standard Cubic Feet MMscfd - Million Standard Cubic Feet per Day N/A or NA Not Applicable NOx - Nitrogen Oxides NESHAP - National Emission Standards for Hazardous Air Pollutants NSPS - New Source Performance Standards P - Process Weight Rate in Tons/Hr PE - Particulate Emissions PM - Particulate Matter Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit Acronyms Appendix E Page 62 PMio - PSD - PTE - RACT - SCC - SCF - SIC - SO2 - TPY - TSP - VOC- Particulate Matter Under 10 Microns Prevention of Significant Deterioration Potential To Emit 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 Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix F Page 63 APPENDIX F Permit Modifications DATE OF REVISION TYPE OF REVISION SECTION NUMBER, CONDITION NUMBER DESCRIPTION OF REVISION Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Engine AOS Applicability Reports Appendix G Page 64 APPENDIX G Engine AOS Applicability Reports ver 10/12/12 (with updated web links and Reg 3 citations as of 8/20/2014) Note: A MS Word version of this Appendix can be found at: https://www.colorado.gov/pacific/cdphe/alternate-operating-scenario-aos-reporting-forms DISCLAIMER: These are only example reports and do not cover all possible requirements. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Engine AOS Applicability Reports Appendix G Page 65 Engine AOS Applicability Report Certification Language All information for the Applicability Reports must be certified by either 1) for Operating Permits, a Responsible Official as defined in Colorado Regulation No. 3, Part A, Section I.B.40) for Construction and General Permits, the person legally authorized to act on behalf of the source. 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. Further, I agree that by signing and submitting these documents I agree that any new requirements identified in the Applicability Report(s) shall be considered to be Applicable Requirements as defined in Colorado Regulation No. 3, Part A, Section I.B.9., and that such requirements shall be enforceable by the Division and its agents and shall be considered to be revisions to the underlying permit(s) referenced in the Report(s) until such time as the Permit is revised to reflect the new requirements. Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Title Signature Date Signed Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Engine AOS Applicability Reports Appendix G Page 66 Colorado Regulation No. 7 Sections XVI and XVILE DISCLAIMER: This is only an example report and does not cover all possible Reg 7 requirements. Company: Acme Gas Processing Source ID: 9991234 Permit #: 93OPXX999 Date: October 1, 2008 Determination of compliance and reporting requirements for a Manufacturer: BestEngineCompany Model: 777 LowNox Nameplate HP: 1340 Construction date: July 1, 2007 Note: If the engine is exempt from a requirement due to construction date or was relocated from within Colorado, supporting documentation must be provided. Determination of Regulation No. 7 requirements: Regulation No. 7, § XVI n Does not apply to this engine. Engine is not located in the ozone nonattainment area or does not have a manufacturer's design rate greater than 500 horsepower or did not commence operation on or after June 1, 2004. Does apply to this engine and applicable emissions controls have been installed. Regulation No. 7, § XVH.E n Does not apply to this engine. Engine does not have a maximum horsepower greater than 100 or the construction or relocation date precedes the applicability dates. Does apply to this engine. The following emission limits apply to the engine: NOx (g/hp-hr): CO (g/hp-hr): VOC (g/hp-hr): 2.0 4.0 1.0 Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: �_ Air Pollution Control Division Colorado Operating Permit Engine AOS Applicability Reports Appendix G Page 67 Max Engine HP Construction or Relocation Date Emission Standards in g/hp-hr NOx CO VOC 100<Hp<500 January 1, 2008 2.0 4.0 1.0 January 1, 2011 1.0 2.0 0.7 500≤Hp July 1, 2007 2.0 4.0 1.0 July 1, 2010 1.0 2.0 0.7 Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Engine AOS Applicability Reports Appendix G Page 68 NSPS JJJJ Example Report Format DISCLAIMER: This is only an example report and does not cover all possible JJJJ requirements. Note that as of August 20, 2015 that the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS JJJJ will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § I.C, upon adoption of NSPS JJJJ into Regulation No. 6, Part A, an internal combustion engine relocated from outside the State of Colorado into the Date of Colorado shall meet the most recent emission standard required in NSPS JJJJ. Engines with a manufacturer's rated horsepower of less than 500 and with a relocation date no later than 5 years after the manufacture date are exempt from this requirement per Regulation No. 6, Part B, Section I.C.2.a. Relocation is defined in Section I.C.I.a. NSPS Subpart JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines Company: Acme Gas Processing Source ID: 9991234 Permit #: 93OPXX999 Date: October 1, 2008 Manufacturer: BestEngineCompany Model: 777 LowNox Nameplate HP: 1340 Engine Type: 2 Stroke Lean Burn Manufacture Date: July 1, 2007 Date Engine Ordered: April 1, 2007 Note: If the engine is exempt from a requirement due to construction/manufacture date, supporting documentation must be provided. Upon adoption of NSPS Subpart JJJJ into Colorado Regulation No. 6, Part A, if the engine is exempt because the engine was relocated within the state of Colorado, supporting documentation must be provided. ❑ NSPS JJJJ does not apply to this engine. NSPS JJJJ does apply to this engine. Note: Using the format below, the source must submit to the Division an analysis of all of the NSPS JJJJ applicable requirements that apply to this specific engine. The analysis below is an example only, based on a hypothetical engine that is a rich burn engine, greater than 500 HP, with a manufacture date after July 1, 2007. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Engine AOS Applicability Reports Appendix G Page 69 Determination of NSPS JJJJ requirements: 60.4230 Applicability (a)(4)(i) Applies to this engine since it is a rich burn engine, greater than 500 HP, with a manufacture date after July 1, 2007. 60.4233 Emission Standards for Owners and Operators (e) Owners and operators of stationary SI ICE with a maximum engine power greater than 100 HP must comply with the standards in Table 1. Non -Emergency SI, Natural Gas, HP>500, Manufactured after 7/1/2007 NOX 2.0 g/HP-hr or 160 ppmvd@15% O2 CO 4.0 g/HP-hr or 540 ppmvd@ 15% O2 VOC 1.0 g/HP-hr or 86 ppmvd@15% O2 Other Requirements for Owners and Operators 60.4234 Emission standards must be met for the lifetime of the engine. 60.4235 N/A - Sulfur content of gasoline. 60.4236 N/A (for now) - After July 1, 2009 owners and operators may not install engines with a power rating > 500HP that do not meet the emissions standards in 60.4233. 60.4237 N/A - Emergency Engines. 60.4238 - 60.4242 Compliance Requirements for Manufacturers — (Not Applicable) 60.4243 Compliance Requirements for Owners and Operators (b)(2)(ii) To maintain compliance with the emission limits in 60.4233, owners of SI ICE > 500HP must: • Keep a maintenance plan; • Keep records of conducted maintenance; • Maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions; • Conduct an initial performance test; and • Conduct subsequent performance tests every 8,760 hours or every three years, which ever comes first, in order to demonstrate compliance with the emission limits. (g) Air to fuel ratio controllers (AFRCs) must be maintained and operated appropriately in order to ensure proper operation of the engine and control device to minimize emissions at all times. 60.4244 Testing Requirements for Owners and Operators (a) Each performance test must be conducted within 10% of the highest achievable load and must comply with the testing requirements listed in 60.8 and Table 2 of NSPS JJJJ. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Engine AOS Applicability Reports Appendix G Page 70 (b) Performance tests may not be conducted during periods of startup, shutdown, or malfunction, as specified in 60.8(c). If the engine is non -operational when a performance test is due, the engine does not need to be started up just to test it, but will need to be tested immediately upon startup. (c) Three separate test runs must be conducted for each performance test as specified by 60.8(f). Each run must be within 10% of max load and be at least 1 hour in duration. (d) To determine compliance with the NOR, CO, and VOC mass per unit output emission limitations, the measured concentration must be converted using the equations outlined in this section of NSPS JJJJ. 60.4245 Notification, Reports, and Records for Owners and Operators (a) Owners of all stationary SI ICE must keep records of the following: (1) All notifications submitted to comply with this subpart; (2) Maintenance conducted on the engine; (3) N/A - Manufacturer information for certified engines, and (4) Documentation that shows non -certified engines are in compliance with the emission standards. (b) N/A — For emergency engines only. (c) Owners of non -certified engines > 500HP must submit an initial notification as required in 60.7(a)(1) which includes the following information: (1) Name and address of the owner or operator; (2) The address of the affected source; (3) Engine information including make, model, engine family, serial number, model year, maximum engine power, and engine displacement; (4) Emission control equipment; and (5) Fuel used. CONCLUSION OF FINDINGS (EXAMPLE ONLY) In general, Acme's 1,235HP, Waukesha 7042 GSI engine is subject to the emissions limitations summarized in Table 1 of NSPS JJJJ. ACME will meet these emission limitations using an AFRC and a non -selective catalytic converter (NSCR). These emission rates will be met throughout the life of the engine. A maintenance plan will be kept and all maintenance activities will be recorded. Compliance with the emission limits will be confirmed by the initial performance tests, which shall be conducted following the procedures outlined in 60.4244. Copies of performance test results will be submitted within 60 days of the completion of each test. Since this is an uncertified engine, an initial notification will be submitted including all of the requested information in 40.4245 within 30 days of startup. ACME will keep records of all compliance related materials. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Engine AOS Applicability Reports Appendix G Page 71 MACT ZZZZ Example Report Format DISCLAIMER: This is only an example report and does not cover all possible ZZZZ requirements. MACT Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Company: Acme Gas Processing Source ID: 9991234 Permit #: 93OPXX999 Date: October 1, 2008 Manufacturer: BestEngineCompany Model: 777 LowNox Nameplate HP: 1340 Engine Type: 2 Stroke Lean Burn Manufacture Date: July 1, 2007 Date Engine Ordered: April 1, 2007 Note: If the engine is exempt from a requirement due to construction/reconstruction date, supporting documentation must be provided. ❑ MACT ZZZZ does not apply to this engine. MACT ZZZZ does apply to this engine. Note: Using the format below, the source must submit to the Division an analysis of all of the MACT ZZZZ applicable requirements that apply to this specific engine. The analysis below is an example only, based on a hypothetical new engine located at an area source of HAP emissions. Determination of MACT ZZZZ requirements: 63.6585 Applicability This subpart is applicable to Acme's engine since they are going to be operating a new stationary reciprocating internal combustion engine (RICE) at a major source of HAP emissions. 63.6590 What Parts of My Plant Does This Subpart Cover? This subpart covers Acme's new stationary reciprocating internal combustion engine. 63.6595 When do I have to comply with this Subpart? Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: ;. _` Air Pollution Control Division Colorado Operating Permit Engine AOS Applicability Reports Appendix G Page 72 (a)(5) The engine must comply with the applicable emission limitations and operating limitations upon startup. 63.6600 Emission and operating limitations for RICE site rated at more than 500 hp (a) The engine is subject to the emission limits in table la and the operating limits in table lb. ACME will meet the emission limitations by reducing formaldehyde emissions by 76 percent and will maintain the catalyst such that the pressure drop does not change by more than 2 inches of H2O at 100 % load plus or minus 10 percent from the pressure drop measured during the initial performance test and will maintain the temperature of the engine exhaust so that the catalyst inlet temperature is greater than or equal to 750 ° F and less than or equal to 1250 ° F. The engine will be equipped with non -selective catalytic reduction and an air fuel controller to meet the emission limitations. 63.6601 & 63.6611 Requirements for 4SLB engines between 250 and 500 hp These requirements do not apply. 63.6605 General Requirements (a) (b) The engine will comply with the emission and operating limitations at all times, except during periods of startup, shutdown and malfunction (SSM) The engine, including air pollution control and monitoring equipment shall be operating in a manner consistent with good air pollution control practices for minimizing emissions at all times, including during SSM. 63.6610 Initial performance test (a) The performance tests specified in Table 4 (select sampling port and measure O2, moisture and formaldehyde at inlet and outlet of the control device) shall be conducted within 180 days of startup. (b) & (c) Not applicable. Construction did not commence between 12/19/02 and 6/15/04. (d) Previous performance tests have not been conducted on this unit within two years, therefore, this provision does not apply. 63.6615 Subsequent performance tests Subsequent tests will be conducted as specified in Table 3. No additional testing is required for 4SRB engines meeting the formaldehyde percent reduction requirements. 63.6620 Performance test procedures (b) Tests must be conducted at 100 % load plus or minus 10% Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Engine AOS Applicability Reports Appendix G Page 73 (c) Tests may not be conducted during periods of SSM. (d) Must conduct three 1 -hr test runs (e) Equation (e)(1) shall be used to determine compliance with the percent reduction requirement. (f), (g) & (h) Not applicable (i) Engine load during test shall be determined as specified in this paragraph. 63.6625 Monitoring, installation, operation and maintenance requirements (a), (c) & (d) Not applicable (b) A continuous parameter monitoring system (CPMS) shall be installed to measure the catalyst inlet temperature. The CPMS will meet the requirements in § 63.8 63.6630 Demonstrating initial compliance (a) Initial compliance shall be determined in accordance with Table 5 (initial performance test must indicate formaldehyde reduction of 76 percent or more, a CPMS must be installed to measure inlet temperature of the catalyst and the pressure drop and catalyst inlet temperature must be recorded during the initial performance test). (b) Pressure differential will be established during the initial performance test. (c) Notification of compliance status will be submitted and will contain the results of the initial compliance demonstration. 63.6635 Monitoring to demonstrate continuous compliance (b) (c) Except for monitor malfunctions, associated repairs, and required QA/QC activities monitoring must be continuous at all time the engine is operating. Data recorded during monitoring malfunctions, associated repairs and required QA/QC activities must not be used in data averages and calculations to report operating levels, however, all the valid data collected during other periods shall be used. 63.6640 Demonstrating continuous compliance (a) (b) 63.6645 Notifications Continuous compliance will be demonstrated as specified in Table 6 (collect catalyst inlet temperature data, reduce that data to 4 -hr rolling average and maintain the 4 -hr rolling averages to within the operating limitation and measuring the pressure drop across the catalyst once per month and demonstrating that the pressure drop meets the operating limitation). Deviations from the emission and operating limitations must be reported per § 63.6550. If catalyst is changed the operating parameters established during the initial performance test must be re-established. When operating parameters re-established a performance test must also be conducted. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Engine AOS Applicability Reports Appendix G Page 74 (a) Submit notifications in §§ 63.7(b) & (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) thru (e) & (g) & (h) that apply by dates specified. (b) Not applicable. Acme unit started after effective dated for Subpart ZZZZ. (c) Submit initial notification within 120 days after becoming subject to Subpart ZZZZ. (d) thru (0 Not applicable. Acme engine greater than 500 hp and subject to requirements in Subpart ZZZZ. (g) & (h) Submit notification of intent to conduct performance test and notification of compliance status. 63.6650 Reports (a) Submit reports required by Table 7 (compliance report and SSM reports (if actions inconsistent with SSM plan) (b) Not applicable, an alternate schedule for report submittal has been approved. Reports will be submitted with Title V reports (c) Compliance reports to contain the following information: company name and address, statement by responsible official certifying accuracy, date of report and beginning and end of reporting period, if SSM the information in 63.10(d)(5)(i), if no deviations a statement saying that, if no periods when CPMS out of control a statement saying that. (d) Not applicable, using CPMS (e) For each deviation the information in (e)(1) thru (e)(12) shall be provided. (0 Applicable. Compliance reports are submitted with title v reports. Compliance reports under Subpart ZZZZ include all necessary info for title v deviation report with respect to Subpart ZZZZ requirements. (g) Not applicable. Acme engine not firing landfill or digester gas. 63.6655 Recordkeeping (a) Retain records as follows: copy of each notification and report (including all documentation supporting any initial notification or notification of compliance status), records in 63.6(e)(iii) thru (v) related to SSM, and records of performance tests and evaluations. (b) CPMS records including records in 63.10(b)(2)(vi) thru (xi), previous versions of the performance evaluation plan required by 63.8(d)(3) and requests for alternatives to the relative accuracy test for CPMS as required by 63.8(f)(6)(i). (c) Not applicable. Acme engine not firing landfill or digester gas. (d) Will keep records required in Table 6 (monthly pressure drop readings, 4 -hr averages of catalyst inlet temperature) to show continuous compliance with emission and operating limits. 63.6660 Form and length of records (a) Records must be in a form suitable and readily available for expeditious review. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: Air Pollution Control Division Colorado Operating Permit Engine AOS Applicability Reports Appendix G Page 75 (b) (c) Records must be retained for five years. Records must be retained on -site for first 2 years, may be retained off -site for the remaining 3 years. 63.6665 General Provisions This engine must comply with the general provisions as indicated in Table 8. CONCLUSION OF FINDINGS (EXAMPLE ONLY) Since this engine is subject to the requirements of MACT Subpart ZZZZ. The engine will be installed with a non -selective catalyst to meet the formaldehyde reduction requirement of 76% or more. An initial performance test will be conducted within 180 days of startup to demonstrate compliance with the formaldehyde percent reduction requirement. During the initial performance test, the pressure drop across the catalyst will be measured. A CPMS will be installed to measure the catalyst inlet temperature. Continuous compliance will be demonstrated by keeping the 4 -hr rolling averages of catalyst inlet temperature within the operating limitations and recording the pressure drop across the catalyst monthly and demonstrating that the pressure drop is within the operating limitation. Records, notifications and reports will be submitted as required. To that end required reports and notifications include initial notification, notice of intent to conduct performance test, notification of compliance status, SSM reports (if required) and semi-annual compliance reports. Operating Permit Number: 02OPWE247 First Issued: 9/1/03 Renewed: TECHNICAL REVIEW DOCUMENT For RENEWAL OF OPERATING PERMIT 02OPWE247 Public Service Company of Colorado - Yosemite Air Blend Plant Weld County Source ID 123/0141 Issued: Operating Permit Engineer: Operating Permit Supervisor review: Field Services Unit review: I. Purpose Thang Nghiem Blue Parish Ashley Jones 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 Yosemite Air Blend Plant. The previous Operating Permit for this facility was issued on September 1, 2003, was renewed on September 1, 2013 and was last revised on August 4, 2014 and expired on September 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 renewal application submitted on June 27, 2017, comments on the draft permit submitted on May 3, 2019, previous inspection reports and various email correspondence. 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. 123/0141 Page 1 of 10 Public Service Company of Colorado — Yosemite Air Blend Plant Operating Permit No. 02OPWE247 Technical Review Document — Renewal Operating Permit II. Description of Source Overview This facility consists of six gas -fired air compressors used for compressed air natural gas blending, under Standard Industrial Classification 4922. In addition, the other significant emission units included in Section II of this permit include two emergency generators. The facility is located at 934 Weld County Road 19, Brighton, 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. The following Federal Class I designated area is within 100 kilometers of the plant: Rocky Mountain National Park. Prevention of Significant Deterioration and Non -attainment New Source Review Based on the information provided by the applicant, this source is categorized as a minor stationary source for PSD as of the issue date of this permit. Any future modification which is major by itself (Potential to Emit of ≥ 250 TPY) for any pollutant listed in Regulation No. 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 facility is categorized as a NANSR major stationary source (Potential to Emit of NOR ≥ 100 tons/year). Future modifications at this facility resulting in a significant net emissions increase (see Regulation No. 3, Part D, Sections II.A.27 and 44) for NOR or a modification which is major by itself (Potential to Emit ≥ 100 tons/year of either VOC or NOR) may result in the application of the NANSR review requirements. Emissions (in tons/yr) at the facility are as follows: Potential to Emit (PTE), in tons/yr Emission Unit PM/PM10/PM2.52 SO2 NOx CO VOC HAP E001 0.22 1.27E-02 10.4 18.4 7.0 2.3 E002 0.22 1.27E-02 10.4 18.4 7.0 2.3 E003 0.35 2.04E-02 16.7 29.5 11.1 3.6 E004 0.35 2.04E-02 16.7 29.5 11.1 3.6 E005 0.70 4.12E-02 34.3 57.1 11.4 7.4 E006 1.09 6.42E-02 34.4 85.7 17.2 11.2 Smart Ash Incinerator' 0.01 0.01 0.05 0.04 Total 2.91 0.17 122.81 238.65 64.84 30.4 Actual Emissions3 0.009 0.07 50.9 95.2 26.05 7.49 'Permitted emissions from the incinerator are below the APEN de minimis level and therefore the emission limits are not included in the Title V permit. However, APENs and permits are required for all incinerators in accordance with Colorado Regulation No. 3, Part A, Section III.D.2 and Part B, Section II.D.6. 2PM/PM1o/PM2.5 actual emissions are based on AP -42 emission factors and actual fuel consumption reported on the APENs. Only filterable PM/PM1o/PM2.5 emissions were reported on the APENs. 3Actual emissions are based on APENs submitted in 2017. HAP emission details are included at the end of this document. See previous TRDs for more discussions on PTE. 123/0141 Page 2 of 10 Public Service Company of Colorado — Yosemite Air Blend Plant Operating Permit No. 02OPWE247 Technical Review Document — Renewal Operating Permit 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 applicant, this facility is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act). Compliance Assurance Monitoring (CAM) 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 into Colorado Regulation No. 3, Part C, Section XIV: None. Although engines E001 through E006 are equipped with control devices, the control devices are not necessary to achieve compliance with the emission limitations for these units; therefore, CAM does not apply to the engines. Hazardous Air Pollutants (HAPs) This facility is a major source for HAPs, for both single HAP (formaldehyde) ≥ 10 tpy, and total HAPs ≥ 25 tpy. See last page of this document for HAPs emissions. Subpart ZZZZ—National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Engines E001 through E006 are considered existing (commenced construction prior to December 19, 2002) 4 -stroke lean burn engines > 500 hp and are not required to meet the requirements in 40 CFR Part 63 Subparts A and ZZZZ, including the initial notification requirements (see § 63.6590(b)(3)(ii)). Engines E008 & E009 (two emergency generators) are existing engines (commenced construction prior to June 12, 2006), and are subject to work practice requirements in MACT Subpart ZZZZ. See previous TRDs for more ZZZZ discussions. Natural Gas Transmission and Storage (NGTS) Facility MACT (40 CFR Part 63 Subpart HHH) The provisions in 40 CFR Part 63 Subpart HHH apply to glycol dehydrators located at major sources of HAPs. Since there is no glycol dehydrator at this facility, the requirements in Subpart HHH do not apply. 123/0141 Page 3 of 10 Public Service Company of Colorado — Yosemite Air Blend Plant Operating Permit No. 02OPWE247 Technical Review Document — Renewal Operating Permit Organic Liquid Distribution (Non -Gasoline) MACT (40 CFR Part 63 Subpart EEEE) No organic liquids are generated or distributed at this facility. Nevertheless, under 40 CFR Part 63 Subpart EEE §§ 63.2334(c)(2), organic liquid distribution operations do not include activities and equipment at NGTS facilities; therefore, the organic liquid distribution MACT requirements do not apply. Boiler MACT for Major Sources (40 CFR Part 63 Subpart DDDDD) The requirements of Subpart DDDDD apply to boilers and process heaters that are located at major sources of HAPs and as such these requirements might apply. There is no de minimis level specified in the requirements and there is fuel -burning equipment identified in the insignificant activity list that is potentially subject to these requirements. The fuel burning equipment included in the insignificant activity list includes a space heating boiler and a hot water heater. The definition of process heater in 63.7575, excludes units used for comfort heat or space heat. In addition, as indicated in 63.7491(d) hot water heaters are not subject to the requirements in Subpart DDDDD. Therefore these units are not subject to requirements of 40 CFR Part 63 Subpart DDDDD. In a February 25, 2013 email, the source indicated that they have no equipment at the facility that meets the definition of a boiler or process heater. NSPS Subpart JJJJ — Stationary Spark Ignition Engines NSPS Subpart JJJJ applies to stationary spark ignition engines that commenced construction, reconstruction or modification after June 12, 2006 and were manufactured after specified dates. The air compressor engines E001 through E006 commenced operation between 1987 and 2002 and while oxidation catalysts have been installed on these engines, the installation of a control device is not considered a modification as specified in 60.14(e)(5). As discussed under the RICE MACT, the emergency generators commenced construction (on -site construction) prior to June 12, 2006. Therefore, the requirements in NSPS Subpart JJJJ do not apply to any of the engines at this facility. NSPS Subpart IIII — Stationary Compression Ignition Engines NSPS Subpart 1111 applies to stationary compression ignition engines that commenced construction, reconstruction or modification after July 11, 2005 and were manufactured after specified dates. There are no compression ignition engines located at the Yosemite Air Blend Plant, therefore, the requirements in NSPS Subpart 1111 do not apply. NSPS Subpart OOOO — Crude Oil and Natural Gas Production, Transmission and Distribution The provisions in NSPS Subpart OOOO apply to several affected facilities at crude oil and natural gas production, transmission and distribution facilities that commenced construction, modification or reconstruction after August 23, 2011. There are no Subpart OOOO affected facilities located at the Yosemite Air Blend Plant so the 123/0141 Page 4 of 10 Public Service Company of Colorado — Yosemite Air Blend Plant Operating Permit No. 02OPWE247 Technical Review Document — Renewal Operating Permit requirements in Subpart OOOO do not apply. See previous TRDs for more in-depth OOOO discussions. Colorado Regulation No. 7, Sections XII and XVIII — Requirements for Oil and Gas Operations in the 8 -hour Ozone Control Area Section XII applies to exploration and production operations, compressor stations or drip stations located upstream of a natural gas -processing plant. The Yosemite Blend facility transmits pipeline quality natural gas (i.e. gas that has been processed) to end users; therefore, the facility is located downstream of a natural gas processing plant, and is not subject to the requirements of Section XII. Section XVIII were adopted in December 2008 and apply to natural gas -actuated pneumatic controllers associated with natural gas operations in the 8 -hour ozone control area or any ozone nonattainment or attainment maintenance area. These requirements specifically apply to pneumatic controllers located at or upstream of a natural gas processing plant. Note that Section XVIII specifically states that upstream activities include oil and gas exploration and production operations, natural gas compressor stations and/or natural gas drip stations. As previously stated, this facility is located downstream of a natural gas processing plant, therefore, these requirements do not apply. Colorado Regulation No. 7 - Engine Requirements The requirements in Regulation No. 7, Section XVI apply to engines located in the 8 - hour ozone control area and sets control requirements for engines greater than 500 hp. This facility is located in the 8 -hour ozone control area and these engines are all greater than 500 hp. The provisions in Section XVI specify that lean burn engines operating in the 8 -hour ozone control area prior to June 1, 2004 must install oxidation catalysts by May 1, 2005. Oxidation catalysts were installed on engines E001 through E006 by May 1, 2005. The installation of oxidation catalysts also satisfy requirements in Section XVII.E.3. This section was stream -lined out for Section XVI. Colorado Regulation No. 7, Section XVI - Control of Emissions from Stationary and Portable Combustion Equipment in the 8 -Hour Ozone Control Area Section XVI.D.6. - Combustion Process Adjustment applies to boilers, duct burners, process heaters, and stationary reciprocating internal combustion engines with uncontrolled actual emissions of NOX equal to or greater than five (5) tons per year that existed at major sources of NOX as of June 3, 2016. Compressor engines 001, 002, 004, 005, 008 & 007 (S001 - S006) have uncontrolled actual emissions of NOX equal to or greater than five (5) tons per year that existed at major sources of NOX as of June 3, 2016 and are subject to these requirements, as specified in the operating permit. Equipment identified in the Appendix A - List of Insignificant Activities (listed below) is not subject to the requirements of Section XVI.D.6: • Hot water heater (0.04 mmBtu/hr) • Space heating boiler (0.215 mmBtu/hr) 123/0141 Page 5 of 10 Public Service Company of Colorado — Yosemite Air Blend Plant Operating Permit No. 02OPWE247 Technical Review Document — Renewal Operating Permit • Radiant heaters, 0.075 and 0.150 MMBtu/hr Colorado Requlation No. 7, Section XVII - Statewide Requirements for Oil and Gas Operations The requirements in Section XVII include requirements for condensate tanks, glycol dehydrators and natural gas fired engines. The requirements for natural gas fired engines are stream -lined out, as explained above. There are no condensate tanks or glycol dehydrators at this facility. Therefore, the requirements in Section XVII do not apply to this facility. Colorado Regulation No. 7, Section XIX - Control of Emissions from Specific Major Sources of VOC and/or NOx in the 8 -hour Ozone Control Area Reg 7 now includes new requirements in Section XIX, and none of them apply to this facility. Colorado Regulation No. 7, Section X- Use of Cleaning Solvents Section X applies to cold cleaners, non-conveyorized vapor degreasers, conveyorized degreasers, or industrial cleaning solvent operations as defined in Section X.A.2. The Yosemite Air Blend Plant operates unit M001 - Cold Cleaner Solvent Vats that qualify as cold cleaner solvent degreasers. In 2016, Colorado Regulation 7 added requirements for "Industrial Cleaning Solvents" in Section X.E. An "Industrial Cleaning Solvent" as defined in X.A.2.f means a VOC- containing liquid used to perform industrial cleaning solvent operations. The M001 - Cold Cleaner Solvent Vats could also fall under the definition of industrial cleaning solvent as they use a VOC based solvent to clean parts. Section X.E.2 and X.E.3: The Exemptions Section in X.E.4.A states that Industrial cleaning solvent operations are not subject to Section X.E. if they are subject to a work practice or emission control requirement in another federally enforceable section of Regulation Number 7 that establishes RACT. The Statement of Basis (Section XXI.O) in Regulation 7 reads: "If an industrial cleaning solvent operation is subject to a work practice or emission control requirement contained in another, federally approved section of Regulation Number 7, including but not limited to Sections IX. (surface coating operations), X.B. through X.D. (solvent cold cleaners, non-conveyorized degreasers, and conveyorized degreasers), and XIII. (graphic arts and printing), then that operation would not also be subject to the requirements of Section X.E.4." Therefore, since the M001 - Cold Cleaner Solvent Vats have already been permitted as cold cleaner subject to the requirements of X.B, the unit is exempt from the industrial cleaning solvent provisions of X.E. The applicable requirements of Section X.A. and X.B. are included in the Operating Permit. 123/0141 Page 6 of 10 Public Service Company of Colorado — Yosemite Air Blend Plant Operating Permit No. 02OPWE247 Technical Review Document — Renewal Operating Permit Compliance History Case No. 1998-007: A stack test conducted on March 18, 1998 found NOx emissions. exceeded the permitted limit, violating Condition 3 of permit 87WE006-1. The Division did not issue a Notice of Violation; however, the Division did send a letter of settlement to the Company on July 7, 1998 with a civil penalty of $21,675. The settlement required the Company to submit information on present compliance and how future compliance would be ensured. Following several meetings, the Division issued a compliance order on consent (COC), signed on October 28 -November 2, 1998. The COC required the Company to perform testing on the engine with a portable analyzer on a set schedule. Future violations of permit limits will require further testing and possible stack testing. Of the original civil penalty of $25,500, The Division dismissed $24,500 and the Company paid $1,000.00 on November 20, 1998. The case is considered closed. Case No. 2012-130: A full compliance evaluation of the facility was completed on July 3, 2012. The Division determined that the Company failed to conduct the required portable monitoring on Air Compressor #3 for the second quarter of 2012. The Company also failed to limit the waste burned in the incinerator to 501b/hr on three days in June 2011. Additionally, the Company failed to timely file six revised APENs. A settlement in the amount of $8,050 was paid on January 4, 2013. The case is considered closed. During an inspection on July 29, 2010, the Division determined the Company failed to complete portable monitor testing of Eng-4 on a quarterly basis and failed to maintain records for the Smart Ash incinerator on a rolling twelve-month basis. The Division issued a verbal warning to the Company to resolve the non-compliance issue. The most recent Inspection Report (August 20, 2018) indicated that this facility is in compliance. IV. Modifications Requested by the Source The renewal application received on June 27, 2017 requested the following modifications: • Updates and revisions to the insignificant source list. • Update Responsible Official's Authorized Representative. The source's requested modifications were addressed as follows: Page Following Cover Page • Updated Responsible Official's Authorized Representative as per source request. Appendices • Appendix A - List of Insignificant Activities was updated as per source request. V. Other Modifications 123/0141 Page 7 of 10 Public Service Company of Colorado — Yosemite Air Blend Plant Operating Permit No. 02OPWE247 Technical Review Document — Renewal Operating Permit 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). Section I — General Activities and Summary • Updated NANSR and PSD languages, with revised Reg 3 condition references. • Updated Table 1 - Internal Combustion Engine Information for the AOS in Condition 2. Section II — Specific Permit Terms • Conditions 1 through 6: the specifications and requirements for all compressor engines at this facility are identical, except for emission and natural gas consumption limits, and emission factors. Conditions 1 through 6 were combined into one single new Condition 1. All of the modifications below apply to all six compressor engines, and languages modified to reflect the combination. • Condition 1.1.1: revised condition to add different engine heat rates; updated equation format; and revised "Fuel" to "NG" (natural gas) as only natural gas is permitted to be used as fuel in these engines. • Condition 1.3: corrected reference Reg 1, Section A.11.1 to I I.A.1. • Condition 1.4: added monitoring requirements for oxidation catalysts. o In draft permit source comments received on May 3, 2019, the source requested that the Pre -catalyst Temperature be monitored and recorded on a weekly basis instead of a weekly basis because the facility is unmanned. The Division has approved this request. • Condition 1.6: updated Colorado Regulation No. 7, Section XVI requirements o Applied new Section XVI.D.6. - Combustion Process Adjustment for stationary internal combustion engines. 123/0141 Page 8 of 10 Public Service Company of Colorado — Yosemite Air Blend Plant Operating Permit No. 02OPWE247 Technical Review Document — Renewal Operating Permit o Note: the Reg 7 reference in Condition 1.5.4.3 should be XVI.D.6.c.(i), not XVI.D.6.c.(1) as in the regulation text (typo). • Condition 8 (now Condition 3): removed "and the engine used to compress gas for tank loading". This engine was removed from site on 02/15/2013. • Condition 9.1 (now Condition 4.1): o Revised to include language for the D.C. Circuit Court's May 4, 2016 mandate for vacatur for certain requirements allowing emergency engines to operate for limited hours for demand response. o Changed 40 CFR Part 63 Subpart ZZZZ latest revision from January 30, 2013 to February 27, 2014. o Removed § 60.6595 - When do I have to comply with this subpart (Condition 4.1.1). The compliance date is October 19, 2013 and this requirement is no longer relevant. • Condition 10.1 (now Condition 5.1): expanded languages for Colorado Regulation 7, Section X.B. for ease of inspection. Section III — Permit Shield • Condition 3 - Stream -lined Conditions: removed "2.6, 3.6, 4.6, 5.6 and 6.6" in table. These conditions have now been combined into one condition 1.6. Section IV — General Permit Conditions • Updated the general permit conditions to the current version (8/28/2018) Appendices • Appendix A: revised as per source request. • Cleared the list of modifications from Appendix F related to the previous issuance. 123/0141 Page 9 of 10 Public Service Company of Colorado — Yosemite Air Blend Plant Operating Permit No. 02OPWE247 Technical Review Document — Renewal Operating Permit VL Miscellaneous Maximum HAP Emissions from Engines (based on Published Emission Factors) Unit acetaldehyde Acrolein benezene toluene ethylbenzene HAP Emissions (tons/yr) Xylene formaldehyde n -hexane 2,2,4- trimethylpentane methanol total E001 1.92E-01 1.23E-01 9.96E-02 1.87E-01 6.26E-02 1.49E-00 2.51E-02 8.95E-02 2.27 E002 1.92E-01 1.23E-01 9.96E-02 1.87E-01 6.26E-02 1.49E-00 2.51E-02 8.95E-02 2.27 E003 3.06E-01 1.96E-01 1.58E-01 2.98E-01 9.98E-02 2.38E-00 3.99E-02 1.43E-01 3.62 E004 3.06E-01 1.96E-01 1.58E-01 2.98E-01 9.98E-02 2.38E-00 3.99E-02 1.43E-01 3.62 E005 6.31E-01 4.05E-01 3.09E-01 6.15E-01 2.06E-01 4.92E-00 7.78E-02 2.94E-01 7.45 E006 9.46E-01 6.07E-01 4.76E-01 9.22E-01 3.09E-01 7.37E-00 1.20E-01 4.41E-01 11.19 Total 2.57 1.65 1.30 2.51 0.00 0.84 20.04 0.33 0.00 1.20 30.44 ngine emissions are based on most conservative emission factor from either AP -42 (4SLB), or GRI HAPCaIc V 3.01 (4SLB or 4SCB) for each pollutant. 123/0141 Page 10 of 10 DRAFT TECHNICAL REVIEW DOCUMENT For RENEWAL OF OPERATING PERMIT 02OPWE247 Public Service Company of Colorado - Yosemite Air Blend Plant Weld County Source ID 123/0141 Issued: Date Operating Permit Engineer: Operating Permit Supervisor review: Field Services Unit review: I. Purpose Thang Nghiem Blue Parish Ashley Jones 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 Yosemite Air Blend Plant. The previous Operating Permit for this facility was issued on September 1, 2003, was renewed on September 1, 2013 and was last revised on August 4, 2014 and expired on September 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 renewal application submitted on June 27, 2017, comments on the draft permit submitted on May 3, 2019, previous inspection reports and various email correspondence. Please note that copies of the Technical Review Document for the original permit and any Technical Review Documents associated with subsequent modifications of the original Operating Permit may be found in the Division files as well as on the Division website at www.colorado.gov/cdphe/airTitleV. This narrative is intended only as an adjunct for the reviewer and has no legal standing. Any revisions made to the underlying construction permits associated with this facility made in conjunction with the processing of this operating permit application have been reviewed in accordance with the requirements of Regulation No. 3, Pad B, Construction Permits, and have been found to meet all applicable substantive and procedural requirements. This operating permit incorporates and shall be considered to be a combined construction/operating permit for any such revision, and the permittee shall be allowed to operate under the revised conditions upon issuance of this operating permit without applying for a revision to this permit or for an additional or revised construction permit. 123/0141 Page 1 of 10 Public Service Company of Colorado — Yosemite Air Blend Plant Operating Permit No. 02OPWE247 Technical Review Document — Renewal Operating Permit II. Description of Source Overview This facility consists of six gas -fired air compressors used for compressed air natural gas blending, under Standard Industrial Classification 4922. In addition, the other significant emission units included in Section II of this permit include two emergency generators. The facility is located at 934 Weld County Road 19, Brighton, 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. The following Federal Class I designated area is within 100 kilometers of the plant: Rocky Mountain National Park. Prevention of Significant Deterioration and Non -attainment New Source Review Based on the information provided by the applicant, this source is categorized as a minor stationary source for PSD as of the issue date of this permit. Any future modification which is major by itself (Potential to Emit of ≥ 250 TPY) for any pollutant listed in Regulation No. 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 facility is categorized as a NANSR major stationary source (Potential to Emit of NOx ≥ 100 tons/year). Future modifications at this facility resulting in a significant net emissions increase (see Regulation No. 3, Part D, Sections II.A.27 and 44) for NOx or a modification which is major by itself (Potential to Emit ≥ 100 tons/year of either VOC or NON) may result in the application of the NANSR review requirements. Emissions (in tons/yr) at the facility are as follows: Potential to Emit (PTE), in tons/yr Emission Unit PM/PM1o/PM2.52 SO2 NOx CO VOC HAP E001 0.22 1.27E-02 10.4 18.4 7.0 2.3 E002 0.22 1.27E-02 10.4 18.4 7.0 2.3 E003 0.35 2.04E-02 16.7 29.5 11.1 3.6 E004 0.35 2.04E-02 16.7 29.5 11.1 3.6 E005 0.70 4.12E-02 34.3 57.1 11.4 7.4 E006 1.09 6.42E-02 34.4 85.7 17.2 11.2 Smart Ash Incinerator' 0.01 0.01 0.05 0.04 Total 2.91 0.17 122.81 238.65 64.84 30.4 Actual Emissions3 0.009 0.07 50.9 95.2 26.05 7.49 'Permitted emissions from the incinerator are below the APEN de minimis level and therefore the emission limits are not included in the Title V permit. However, APENs and permits are required for all incinerators in accordance with Colorado Regulation No. 3, Part A, Section III.D.2 and Part B, Section II.D.6. 2PM/PM1o/PM2.5 actual emissions are based on AP -42 emission factors and actual fuel consumption reported on the APENs. Only filterable PM/PM1o/PM2.5emissions were reported on the APENs. 3Actual emissions are based on APENs submitted in 2017. HAP emission details are included at the end of this document. See previous TRDs for more discussions on PTE. 123/0141 Page 2 of 10 Public Service Company of Colorado — Yosemite Air Blend Plant Operating Permit No. 02OPWE247 Technical Review Document — Renewal Operating Permit 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 applicant, this facility is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act). Compliance Assurance Monitoring (CAM) 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 into Colorado Regulation No. 3, Part C, Section XIV: None. Although engines E001 through E006 are equipped with control devices, the control devices are not necessary to achieve compliance with the emission limitations for these units; therefore, CAM does not apply to the engines. Hazardous Air Pollutants (HAPs) This facility is a major source for HAPs, for both single HAP (formaldehyde) ≥ 10 tpy, and total HAPs ≥ 25 tpy. See last page of this document for HAPs emissions. Subpart ZZZZ—National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Engines E001 through E006 are considered existing (commenced construction prior to December 19, 2002) 4 -stroke lean burn engines > 500 hp and are not required to meet the requirements in 40 CFR Part 63 Subparts A and ZZZZ, including the initial notification requirements (see § 63.6590(b)(3)(ii)). Engines E008 & E009 (two emergency generators) are existing engines (commenced construction prior to June 12, 2006), and are subject to work practice requirements in MACT Subpart ZZZZ. See previous TRDs for more ZZZZ discussions. Natural Gas Transmission and Storage (NGTS) Facility MACT (40 CFR Part 63 Subpart HHH) The provisions in 40 CFR Part 63 Subpart HHH apply to glycol dehydrators located at major sources of HAPs. Since there is no glycol dehydrator at this facility, the requirements in Subpart HHH do not apply. 123/0141 Page 3 of 10 Public Service Company of Colorado — Yosemite Air Blend Plant Operating Permit No. 02OPWE247 Technical Review Document — Renewal Operating Permit Organic Liquid Distribution (Non -Gasoline) MACT (40 CFR Part 63 Subpart EEEE) No organic liquids are generated or distributed at this facility. Nevertheless, under 40 CFR Part 63 Subpart EEE §§ 63.2334(c)(2), organic liquid distribution operations do not include activities and equipment at NGTS facilities; therefore, the organic liquid distribution MACT requirements do not apply. Boiler MACT for Major Sources (40 CFR Part 63 Subpart DDDDD) The requirements of Subpart DDDDD apply to boilers and process heaters that are located at major sources of HAPs and as such these requirements might apply. There is no de minimis level specified in the requirements and there is fuel -burning equipment identified in the insignificant activity list that is potentially subject to these requirements. The fuel burning equipment included in the insignificant activity list includes a space heating boiler and a hot water heater. The definition of process heater in 63.7575, excludes units used for comfort heat or space heat. In addition, as indicated in 63.7491(d) hot water heaters are not subject to the requirements in Subpart DDDDD. Therefore these units are not subject to requirements of 40 CFR Part 63 Subpart DDDDD. In a February 25, 2013 email, the source indicated that they have no equipment at the facility that meets the definition of a boiler or process heater. NSPS Subpart JJJJ — Stationary Spark Ignition Engines NSPS Subpart JJJJ applies to stationary spark ignition engines that commenced construction, reconstruction or modification after June 12, 2006 and were manufactured after specified dates. The air compressor engines E001 through E006 commenced operation between 1987 and 2002 and while oxidation catalysts have been installed on these engines, the installation of a control device is not considered a modification as specified in 60.14(e)(5). As discussed under the RICE MACT, the emergency generators commenced construction (on -site construction) prior to June 12, 2006. Therefore, the requirements in NSPS Subpart JJJJ do not apply to any of the engines at this facility. NSPS Subpart1111— — Stationary Compression Ignition Engines NSPS Subpart 1111 applies to stationary compression ignition engines that commenced construction, reconstruction or modification after July 11, 2005 and were manufactured after specified dates. There are no compression ignition engines located at the Yosemite Air Blend Plant, therefore, the requirements in NSPS Subpart 1111 do not apply. NSPS Subpart OOOO — Crude Oil and Natural Gas Production, Transmission and Distribution The provisions in NSPS Subpart OOOO apply to several affected facilities at crude oil and natural gas production, transmission and distribution facilities that commenced construction, modification or reconstruction after August 23, 2011. There are no Subpart OOOO affected facilities located at the Yosemite Air Blend Plant so the 123/0141 Page 4 of 10 Public Service Company of Colorado — Yosemite Air Blend Plant Operating Permit No. 02OPWE247 Technical Review Document — Renewal Operating Permit requirements in Subpart OOOO do not apply. See previous TRDs for more in-depth OOOO discussions. Colorado Regulation No. 7, Sections XII and XVIII — Requirements for Oil and Gas Operations in the 8 -hour Ozone Control Area Section XII applies to exploration and production operations, compressor stations or drip stations located upstream of a natural gas -processing plant. The Yosemite Blend facility transmits pipeline quality natural gas (i.e. gas that has been processed) to end users; therefore, the facility is located downstream of a natural gas processing plant, and is not subject to the requirements of Section XII. Section XVIII were adopted in December 2008 and apply to natural gas -actuated pneumatic controllers associated with natural gas operations in the 8 -hour ozone control area or any ozone nonattainment or attainment maintenance area. These requirements specifically apply to pneumatic controllers located at or upstream of a natural gas processing plant. Note that Section XVIII specifically states that upstream activities include oil and gas exploration and production operations, natural gas compressor stations and/or natural gas drip stations. As previously stated, this facility is located downstream of a natural gas processing plant, therefore, these requirements do not apply. Colorado Regulation No. 7 - Engine Requirements The requirements in Regulation No. 7, Section XVI apply to engines located in the 8 - hour ozone control area and sets control requirements for engines greater than 500 hp. This facility is located in the 8 -hour ozone control area and these engines are all greater than 500 hp. The provisions in Section XVI specify that lean burn engines operating in the 8 -hour ozone control area prior to June 1, 2004 must install oxidation catalysts by May 1, 2005. Oxidation catalysts were installed on engines E001 through E006 by May 1, 2005. The installation of oxidation catalysts also satisfy requirements in Section XVII.E.3. This section was stream -lined out for Section XVI. Colorado Regulation No. 7, Section XVI - Control of Emissions from Stationary and Portable Combustion Equipment in the 8 -Hour Ozone Control Area Section XVI.D.6. - Combustion Process Adjustment applies to boilers,,duct burners, process heaters, and stationary reciprocating internal combustion engines with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year that existed at major sources of NOx as of June 3, 2016. Compressor engines 001, 002, 004, 005, 008 & 007 (S001 - S006) have uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year that existed at major sources of NOx as of June 3, 2016 and are subject to these requirements, as specified in the operating permit. Equipment identified in the Appendix A - List of Insignificant Activities (listed below) is not subject to the requirements of Section XVI.D.6: • Hot water heater (0.04 mmBtu/hr) • Space heating boiler (0.215 mmBtu/hr) 123/0141 Page 5 of 10 Public Service Company of Colorado — Yosemite Air Blend Plant Operating Permit No. 02OPWE247 Technical Review Document — Renewal Operating Permit • Radiant heaters, 0.075 and 0.150 MMBtu/hr Colorado Regulation No. 7, Section XVII - Statewide Requirements for Oil and Gas Operations The requirements in Section XVII include requirements for condensate tanks, glycol dehydrators and natural gas fired engines. The requirements for natural gas fired engines are stream -lined out, as explained above. There are no condensate tanks or glycol dehydrators at this facility. Therefore, the requirements in Section XVII do not apply to this facility. Colorado Regulation No. 7, Section XIX - Control of Emissions from Specific Major Sources of VOC and/or NOx in the 8 -hour Ozone Control Area Reg 7 now includes new requirements in Section XIX, and none of them apply to this facility. Colorado Regulation No. 7, Section X- Use of Cleaning Solvents Section X applies to cold cleaners, non-conveyorized vapor degreasers, conveyorized degreasers, or industrial cleaning solvent operations as defined in Section X.A.2. The Yosemite Air Blend Plant operates unit M001 - Cold Cleaner Solvent Vats that qualify as cold cleaner solvent degreasers. In 2016, Colorado Regulation 7 added requirements for "Industrial Cleaning Solvents" in Section X.E. An "Industrial Cleaning Solvent" as defined in X.A.2.f means a VOC- containing liquid used to perform industrial cleaning solvent operations. The M001 - Cold Cleaner Solvent Vats could also fall under the definition of industrial cleaning solvent as they use a VOC based solvent to clean parts. Section X.E.2 and X.E.3: The Exemptions Section in X.E.4.A states that Industrial cleaning solvent operations are not subject to Section X.E. if they are subject to a work practice or emission control requirement in another federally enforceable section of Regulation Number 7 that establishes RACT. The Statement of Basis (Section XXI.O) in Regulation 7 reads: "If an industrial cleaning solvent operation is subject to a work practice or emission control requirement contained in another, federally approved section of Regulation Number 7, including but not limited to Sections IX. (surface coating operations), X.B. through X.D. (solvent cold cleaners, non-conveyorized degreasers, and conveyorized degreasers), and XIII. (graphic arts and printing), then that operation would not also be subject to the requirements of Section X.E.4." Therefore, since the M001 - Cold Cleaner Solvent Vats have already been permitted as cold cleaner subject to the requirements of X.B, the unit is exempt from the industrial cleaning solvent provisions of X.E. The applicable requirements of Section X.A. and X.B. are included in the Operating Permit. 123/0141 Page 6 of 10 Public Service Company of Colorado — Yosemite Air Blend Plant Operating Permit No. 02OPWE247 Technical Review Document — Renewal Operating Permit Compliance History Case No. 1998-007: A stack test conducted on March 18, 1998 found NOx emissions exceeded the permitted limit, violating Condition 3 of permit 87WE006-1. The Division did not issue a Notice of Violation; however, the Division did send a letter of settlement to the Company on July 7, 1998 with a civil penalty of $21,675. The settlement required the Company to submit information on present compliance and how future compliance would be ensured. Following several meetings, the Division issued a compliance order on consent (COC), signed on October 28 -November 2, 1998. The COC required the Company to perform testing on the engine with a portable analyzer on a set schedule. Future violations of permit limits will require further testing and possible stack testing. Of the original civil penalty of $25,500, The Division dismissed $24,500 and the Company paid $1,000.00 on November 20, 1998. The case is considered closed. Case No. 2012-130: A full compliance evaluation of the facility was completed on July 3, 2012. The Division determined that the Company failed to conduct the required portable monitoring on Air Compressor #3 for the second quarter of 2012. The Company also failed to limit the waste burned in the incinerator to 501b/hr on three days in June 2011. Additionally, the Company failed to timely file six revised APENs. A settlement in the amount of $8,050 was paid on January 4, 2013. The case is considered closed. During an inspection on July 29, 2010, the Division determined the Company failed to complete portable monitor testing of Eng-4 on a quarterly basis and failed to maintain records for the Smart Ash incinerator on a rolling twelve-month basis. The Division issued a verbal warning to the Company to resolve the non-compliance issue. The most recent Inspection Report (August 20, 2018) indicated that this facility is in compliance. IV. Modifications Requested by the Source The renewal application received on June 27, 2017 requested the following modifications: • Updates and revisions to the insignificant source list. • Update Responsible Official's Authorized Representative. The source's requested modifications were addressed as follows: Page Following Cover Page • Updated Responsible Official's Authorized Representative as per source request. Appendices • Appendix A - List of Insignificant Activities was updated as per source request. V. Other Modifications 123/0141 Page 7 of 10 Public Service Company of Colorado — Yosemite Air Blend Plant Operating Permit No. 02OPWE247 Technical Review Document — Renewal Operating Permit 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). Section I — General Activities and Summary • Updated NANSR and PSD languages, with revised Reg 3 condition references. • Updated Table 1 - Internal Combustion Engine Information for the AOS in Condition 2. Section II — Specific Permit Terms • Conditions 1 through 6: the specifications and requirements for all compressor engines at this facility are identical, except for emission and natural gas consumption limits, and emission factors. Conditions 1 through 6 were combined into one single new Condition 1. All of the modifications below apply to all six compressor engines, and languages modified to reflect the combination. • Condition 1.1.1: revised condition to add different engine heat rates; updated equation format; and revised "Fuel" to "NG" (natural gas) as only natural gas is permitted to be used as fuel in these engines. • Condition 1.3: corrected reference Reg 1, Section A.lI.1 to II.A.1. • Condition 1.4: added monitoring requirements for oxidation catalysts. o In draft permit source comments received on May 3, 2019, the source requested that the Pre -catalyst Temperature be monitored and recorded on a weekly basis instead of a weekly basis because the facility is unmanned. The Division has approved this request. • Condition 1.6: updated Colorado Regulation No. 7, Section XVI requirements o Applied new Section XVI.D.6. - Combustion Process Adjustment for stationary internal combustion engines. 123/0141 Page 8 of 10 Public Service Company of Colorado — Yosemite Air Blend Plant Operating Permit No. 02OPWE247 Technical Review Document — Renewal Operating Permit o Note: the Reg 7 reference in Condition 1.5.4.3 should be XVI.D.6.c.(i), not XVI.D.6.c.(1) as in the regulation text (typo). • Condition 8 (now Condition 3): removed "and the engine used to compress gas for tank loading". This engine was removed from site on 02/15/2013. • Condition 9.1 (now Condition 4.1): o Revised to include language for the D.C. Circuit Court's May 4, 2016 mandate for vacatur for certain requirements allowing emergency engines to operate for limited hours for demand response. o Changed 40 CFR Part 63 Subpart ZZZZ latest revision from January 30, 2013 to February 27, 2014. o Removed § 60.6595 - When do I have to comply with this subpart (Condition 4.1.1). The compliance date is October 19, 2013 and this requirement is no longer relevant. • Condition 10.1 (now Condition 5.1): expanded languages for Colorado Regulation 7, Section X.B. for ease of inspection. Section III — Permit Shield • Condition 3 - Stream -lined Conditions: removed "2.6, 3.6, 4.6, 5.6 and 6.6" in table. These conditions have now been combined into one condition 1.6. Section IV — General Permit Conditions • Updated the general permit conditions to the current version (8/28/2018) Appendices • Appendix A: revised as per source request. • Cleared the list of modifications from Appendix F related to the previous issuance. 123/0141 Page 9 of 10 Public Service Company of Colorado — Yosemite Air Blend Plant Operating Permit No. 02OPWE247 Technical Review Document — Renewal Operating Permit VI. Miscellaneous Maximum HAP Emissions from Engines (based on Published Emission Factors) Unit acetaldehyde Acrolein benezene toluene ethylbenzene HAP Emissions (tons/yr) Xylene formaldehyde n -hexane 2,2,4- trimethylpentane methanol total E001 1.92E-01 1.23E-01 9.96E-02 1.87E-01 6.26E-02 1.49E-00 2.51E-02 8.95E-02 2.27 E002 1.92E-01 1.23E-01 9.96E-02 1.87E-01 6.26E-02 1.49E-00 2.51E-02 8.95E-02 2.27 E003 3.06E-01 1.96E-01 1.58E-01 2.98E-01 9.98E-02 2.38E-00 3.99E-02 1.43E-01 3.62 E004 3.06E-01 1.96E-01 1.58E-01 2.98E-01 9.98E-02 2.38E-00 3.99E-02 1.43E-01 3.62 E005 6.31E-01 4.05E-01 3.09E-01 6.15E-01 2.06E-01 4.92E-00 7.78E-02 2.94E-01 7.45 E006 9.46E-01 6.07E-01 4.76E-01 9.22E-01 3.09E-01 7.37E-00 1.20E-01 4.41E-01 11.19 Total 2.57 1.65 1.30 2.51 0.00 0.84 20.04 0.33 0.00 1.20 30.44 Engine emissions are based on most conservative emission factor from either AP -42 (4SLB), or GRI HAPCalc V 3.01 (4SLB or 4SCB) for each pollutant. 123/0141 Page 10 of 10 Xcel Energy RESPONSIBLE BY NATURE' 1800 Larimer St. Suite 1300 Denver, Colorado 80202 June 22, 2017 Mr. Thang Nghiem Colorado Dept. of Public Health and Environment APCD-SS-B1 4300 Cherry Creek Drive S. Denver, CO 80246-1530 RE: Yosemite Air Blend Plant — Operating Permit No. 02OPWE247 Title V Permit Renewal Application Dear Mr. Nghiem: PY Enclosed are an original plus three unbound copies of the Title V permit renewal application for the Public Service Company of Colorado (PSCo) Yosemite Air Blend Plant. No changes are being requested for the operating permit except as identified below or attached. This permit renewal application contains the following information: • Form 2000-100 is enclosed. Updates and revisions to the insignificant source list are being requested, and this information is provided on Foitii 2000-102B and Foini 2000-700 which are enclosed. • Form 2000-800 is enclosed. Additionally, please update the Responsible Official's Authorized Representative contact information on the summary page of the permit as follows: Responsible Official's Authorized Representative Name: Luke Litteken Title: Area Vice President, Gas Operations Phone: (303 571-3249 An evaluation was completed to determine if the sources at the Yosemite Air Blend Plant have the potential to emit greenhouse gasses. Based on this evaluation it has been determined that the facility is not a major source for greenhouse gas emissions. If you have any questions regarding this renewal application, please contact Josh Korth with Xcel Energy's Environmental Services staff at Joshua.R.Korth@xcelenergy.com or (303) 294-2187. Sincer Ch ry1 F. Campbell Senior Vice President, Gas Enclosures (3) cc: Gary Magno Lauren Gilliland Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division FACILITY IDENTIFICATION SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-100 Rev 06-95 1. Facility name and Name mailing address Street or Route City, State, Zip Code Public Service Company of Colorado Yosemite Air Blend Plant 12466 Weld County Road 2.25 Brighton, CO 80603 2. Facility location Street Address (No P.O. Box) City,County, Zip Code 934 Weld County Road 19 Brighton Colorado, Weld, 80601 3. Parent corporation Name Street or Route City, State, Zip Code Country (if not U.S.) Public Service Company of Colorado 1800 Larimer Street, Suite 1300 Denver, CO 80202 4. Responsible official Name Title Telephone Cheryl F. Campbell Senior Vice President, Gas 303-294-2071 5. Permit contact person Name Title (If Different than 4) Telephone Chad Campbell Manager, Environmental Services, Air and Water Quality Compliance 303-294-2177 6. Facility SIC code: 4922 7. Facility identification code: CO 1230141 8. Federal Tax I. D. Number: 84-6015506 9. Primary activity of the operating establishment: Air Compression and Processing 10. Type of operating permit New Modified CRenewal 11. Is the facility located in a "nonattainment" area: es No If "Yes", check the designated "non -attainment" pollutant(s): Carbon Monoxide Ozone T) PM10 Other (specify) 12. List all (Federal and State) air pollution permits (including grandfathered units), plan approvals and exemptions issued to this facility. List the number, date and what unit/process is covered by each permit. For a Modified Operating Permit, do not complete this item. FACILITY IDENTIFICATION -- Form 2000-100 AIR POLLUTION CONTROL OPERATING PERMIT APPLICATION INSTRUCTIONS NOTE: The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permit applications. The Division will not consider or act upon your application unless each form used has been entirely completed. Use "NA" where necessary to identify an information request that does not apply. One form should be included with each application. Item 1 Provide full business name and address of corporation, company, association, society, firm, partnership, individual or political subdivision of the state submitting the application. Item 2 Street address where the air pollution sources are or will be located. For remote locations, land plat descriptions (Township, Range, Section, Subsection location) are acceptable. Item 3 If wholly or partly owned by another entity, identify that entity. Item 4 The responsible official is a person legally responsible for the operation of the permitted air pollution sources. For a corporation, this person must be the president, vice-president, secretary or treasurer, or other person with a similar level of responsibility in the company. for to filing the application, if you want the Division to approve your choice of responsible official you may send a letter to the Division describing that rson's authority in the company and requesting the Division's approval. Item 5 Individual to contact during the permitting process for additional information concerning the air pollution sources. Item 6 The primary Standard Industrial Classification (SIC) code for the facility where the source(s) are located. Item 7 Provide the facility identification (FID) code. The Division has assigned a unique code to your facility. The code begins with "CO" (Colorado) and has 7 digits. Item 8 Provide the Facility Federal Tax Number. This is a nine -digit number. Item 9 Provide a short statement about your facility's activities such as "lead -acid battery manufacture" or "sulfite paper mill." Item 10 Indicate the type of permit application being submitted. An applicant may at any time request an operating permit that is otherwise not required. Item 11 Indicate whether the facility is located in a nonattainment areaeven if your facility does not emit the pollutant. Please refer to the instruction booklet and Appendix G of the instruction book. If the area is attainment for all pollutants, enter "Attainment for all Pollutants". Item 12 Identify all facility air pollution permits, plan approvals (fugitive dust), and exemptions issued by U.S. EPA or Colorado APCD that are still in effect. Include grandfathered emission units. Please do not list old permits, exemptions, etc. that have expired or been superseded by more recent approvals. List the permit number, date, and unit or operation covered by the permit. Example: 88DE189 May 15, 1989 Incinerator Fugitive Dust Sept 1, 1992 Gravel Pit Grandfathered Feb 2, 1972 Smith Boiler Operating Pennit Application SOURCE DESCRIPTION - INSIGNIFICANT ACTIVITIES Colorado Department of Public Health and Environment Air Pollution Control Division FORM 2000-102B Rev 06-95 Facility Name: Yosemite Air Blend Plant Facility Identification Code: CO 1230141 NOTE: The operating permit must be prepared and submitted on forms supplied by the Division. This is a supplemental form for use only when necessary to provide complete information in the operating pernut application.The Division will not consider or act upon your application unless each form used has been entirely completed. Certain categories of sources and activities are considered to be insignificant contributors to air pollution and are listed below. A source solely comprised of one or more of these activities is not required to obtain an operating permit pursuant to Regulation 3, unless the source's emissions trigger the major source threshold as defined in Part A, Section I.B.58 of Regulation 3. For the facility, mark all insignificant existing or proposed air pollution emission units, operations, and activities listed below. (a) noncommercial (in-house) experimental and analytical laboratory equipment which is bench scale in nature including quality control/quality assurance laboratories, process support laboratories, environmental laboratories supporting a manufacturing or industrial facility, and research and development laboratories. (b) research and development activities which are of a small pilot scale and which process less than 10,000 pounds of test material per year. (c) small pilot scale research and development projects less than six months in duration with controlled actual emissions less than 500 pounds of any criteria pollutant or 10 pounds of any non -criteria reportable pollutant. Disturbance of surface areas for purposes of land development, which do not exceed 25 contiguous acres and which do not exceed six months in duration. (This does not include mining operations or disturbance of contaminated soil). Each individual piece of fuel burning equipment, other than smokehouse generators and internal combustion engines, which uses gaseous fuel, and which has a design rate less than or equal to 5 million Btu per hour. (See definition of fuel burning equipment, Common Provisions Regulation). Petroleum industry flares, not associated with refineries, combusting natural gas containing no H2S except in trace (less than 500 ppmw) amounts, approved by the Colorado Oil and Gas Conservation Commission and having uncontrolled emissions of any pollutant of less than five tons per year. Chemical storage tanks or containers that hold less than 500 gallons, and which have a daily throughput less than 25 gallons. Landscaping and site housekeeping devices equal to or less than 10 H.P. in size (lawnmowers, trimmers, snow blowers, etc.). Crude oil or condensate loading truck equipment at crude oil production sites where the loading rate does not exceed 10,000 gallons per day averaged over any 30 day period. Chemical storage areas where chemicals are stored in closed containers, and where total storage capacity does not exceed 5000 gallons. This exemption applies solely to storage of such chemicals. This exemption does not apply to transfer of chemicals from, to, or between such containers. Oil production wastewater (produced water tanks), containing less than 1% by volume crude oil, except for commercial facilities which accept oil production wastewater for processing. (Continues on other side) Storage of butane, propane, or liquified petroleum gas in a vessel with a capacity of less than 60,000 gallons, provided the requirements of Regulation No. 7, Section IV are met, where applicable. Storage tanks of capacity < 40,000 gallons of lubricating oils. Venting of compressed natural gas, butane or propane gas cylinders, with a capacity of 1 gallon or less. Fuel storage and dispensing equipment in ozone attainment areas operated solely for company -owned vehicles where the daily fuel throughput is no more than 400 gallons per day, averaged over a 30 day period. Crude oil or condensate storage tanks with a capacity of 40,000 gallons or less. Storage tanks meeting all of the following criteria: (i) annual throughput is less than 400,000 gallons; and (ii) the liquid stored is one of the following: (A) diesel fuels 1-D, 2-D, or 4-D; (B) fuel oils #1 through #6; (C) gas turbine fuels 1-GT through 4-GT; (D) an oil/water mixture with a vapor pressure lower than that of diesel fuel (Reid vapor pressure of .025 PSIA). Each individual piece of fuel burning equipment which uses gaseous fuel, and which has a design rate less than or equal to 10 million Btu per hour, and which is used solely for heating buildings for personal comfort. Stationary Internal Combustion Engines which: (i) power portable drilling rigs; or (ii) are emergency power generators which operate no more than 250 hours per year; or (iii) have actual emissions less than five tons per year or rated horsepower of less than 50. Surface mining activities which mine 70,000 tons or fewer of product material per year. A fugitive dust control plan is required for such sources. Crushers, screens and other processing equipment activities are not included in this exemption. Air pollution emission units, operations or activities with emissions less than the appropriate de minimis reporting level. NOTE: Material Data Safety Sheets (MSDS) do not have to be submitted for any insignificant activities. USE FORM 2000-700 TO PROVIDE AN ITEMIZED LIST OF THE SOURCES OR ACTIVITIES BEING IDENTIFIED AS INSIGNIFICANT ACTIVITIES. DO NOT ITEMIZE INDIVIDUAL PIECES OF LANDSCAPING EQUIPMENT. THE LIST IS NEEDED TO ACCURATELY ACCOUNT FOR ALL ACTIVITIES AT THE FACILITY Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE SUPPLEMENTAL INFORMATION FORM 2000-700 09-94 1. Facility name: Yosemite Air Blend Plant 2. Facility identification code: CO _1210141 3. This form supplements Form 2000 - 102 B for Emission Unit (e.g. B001, P001, etc.) Additional Information, Diagrams Item Number Insignificant activities to be added to the operating permit Chemical storage tanks or containers < 500 gal (Reg 3 Part C.II.E.3.n) - Coolant (ethylene glycol) - one (1) 150 gallon tank Chemical storage areas < 5,000 gal capacity (Reg 3 Part C.II.E.3.mm) - Odorant tanks (above ground mercaptan storage) - two (2) tanks 1,990 each Lubricating/Waste oil storage tanks < 40,000 gal (Reg 3 Part C.II.E.3.aaa) - Lube oil twenty-three (23) 55 gal drums Insignificant activities to be updated in the operating permit Chemical storage tanks or containers < 500 gal (Reg 3 Part C.II.E.3.n) - Change the volume of the two (2) collant totes from 250 gal to 300 gal Chemical storage areas < 5,000 gal capacity (Reg 3 Part C.II.E.3.mm) - Change the volume of the four (4) odorant tanks from 900 gal to 1,000 gal Lubricating/Waste oil storage tanks < 40,000 gal (Reg 3 Part C.II.E.3.aaa) - Change five (5) lube oil tanks, 287 gal aboveground to four (4) lube oil tanks, 300 gal aboveground. - Change one (1) used lube oil tank, 360 gal aboveground to one (1) used lube oil tank, 420 gal aboveground. - Change one (1) lube oil tank, 175 gal aboveground to one (1) lube oil tank, 200 gal aboveground. Fuel burning equipment < 10 MMBtu/hr used for comfort heat (Reg 3 Part C.II.E.ggg) - Change the heat rating on the space heating unit from 0.433 mmBtu/hr to 0.215 mmBtu/ hr. Insignificant activities to be removed from the operating permit Stationary internal combustion engines < 50 hp or with actual, uncontrolled emissions < 5 tons/yr (Reg 3 Part C.II.E.nnn.(ii) - Cummins, Model NO. GTA855, S/N 25322795, 4 -cycle lean burn natural gas fired internal combustion engine used for tank loading. This engine was removed from the site on 2/15/2013. 90 Operating Permit Application Colorado Department of Health Air Pollution Control Division Facility Name: Yosemite Air Blend Plant I. ADMINISTRATION TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 09-94 Facility Identification Code: CO 1230141 This application contains the following forms: Form 2000-100, Facility Identification Form 2000-101, Facility Plot Plan Forms 2000-102, -102A, and -102B, Source and Siie Descriptions II. EMISSIONS SOURCE DESCRIPTION Total Number of This Form This application contains the following forms (one form for each facility boiler, printing operation, etc.): 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: Form 2000-400, Miscellaneous Form 2000-401, Condensers Form 2000-402, Adsorbers Form 2000-403, Catalytic or Thermal Oxidation Fonn 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, printing operation, etc.): 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 92 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 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 formed and information contained in this application are true, accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS - FEDERAL/STATE CONDITIONS X I certify that the facility described in this air pollution permit application is fully I certify that the facility described in this air pollution permit application is fully for the following emissions unit(s): after reasonable inquiry, I certify that the statements (check one box only) in compliance with all applicable requirements. in compliance with all applicable requirements, except material statement, representation, or certification be punished in accordance with the provisions of § 25- (list all noncomplying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false in, or omits material information from this application is guilty of a misdemeanor and may 7 122.1, C.R.S. Printed or Typed Name CheryA Campbell Title Senior Vice President, Gas Signa e , } Date Signed(-°//4:,Aq. 93 Operating Permit Application Colorado Department of Health Air Pollution Control Division Facility Name: Yosemite Air Blend Plant CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 2000-800 09-94 Facility Identification Code: CO 1230141 VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief formed and information contained in this application are true, accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE -ONLY CONDITIONS FKI I certify that the facility described in this air pollution permit application is fully I certify that the facility described in this air pollution permit application is fully for the following emissions unit(s): after reasonable inquiry, I certify that the statements (check one box only) in compliance with all applicable requirements. in compliance with all applicable requirements, except material statement, representation, or certification be punished in accordance with the provisions of § 25- (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false in, or omits material information from this application is guilty of a misdemeanor and may 7 122.1, C.R.S. Printed or Typed Name Cheryl F. Cam ell Title Senior Vice President, Gas Sign \ Date Signed /?c -:;7/1/ r SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B 1 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 94 Xcel Energy® RESPONSIBLE BY NATURE'M 1800 Larimer St. Suite 1300 Denver, Colorado 80202 May 3,2019 Thang Nghiem Colorado Department of Public Health and Environment Title V Operating Permit Unit Stationary Sources Program 4300 Cherry Creek Drive S. Denver, CO 80246-1530 RE: Yosemite Title V Draft Permit Review- 02OPWE247 Comments Dear Thang, Please see below the comments for the Yosemite Title V permit renewal. 1) Contact information needs to be updated- this has changed since the application was filed. • RO: Luke Litteken, SVP — Gas, 303-571-3993 • RO Authorized Rep: Eric Kirkpatrick, AVP — Gas, 303-571-3223 • Facility Contact: Chad Campbell, Manager — Environmental Services, 303-294- 2177 2) Xcel wishes to keep the same compliance periods as the previous permits and asks that the permit be issued as final on the next semi-annual period start date after public and EPA comment are completed. 3) Section II condition 1- Please update Point 008 to read air compressor #6 and P007 to read Air compressor #7 (instead of 5 and 6) this is consistent with the rest of the permits numbering. Point 008 (S005) - Caterpillar, Model 3608, site rated at 2,368 HP, natural gas fired internal combustion reciprocating engine - Air Compressor #5 Point 007 (S006) - Caterpillar, Model G3612, site rated at 3,550 HP, natural gas fired internal combustion reciprocating engine - Air Compressor #6 4) Section II condition 1.4: We are requesting to keep the current requirements of weekly checks for the pre - catalyst temperatures. Currently we complete catalyst temperature monitoring and recording weekly, which is consistent with most of our other facilities requirements. This facility is not manned 24/7. Monitoring Requirement Monitoring Frequency Pre -catalyst Temperature Daily Catalyst Differential Pressure Monthly The inlet temperature to the catalyst shall be maintained within the range of 450°F to 1350°F. Catalyst inlet temperature shall be monitored and recorded on a daily basis. Should you have any questions please feel free to contact Paige Buczek at 303-294-2039 or paige.buczek@xcelenergy.com. Sincerely, Paige Buczek Environmental Analyst Xcel Energy Hello