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Home My WebLink About20161161 4, CGPHE COLORADO CO Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 0 St PO Box 758 Greeley, CO 80632 RECEIVED March 22, 2016 MAR 3 0 2016 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On March 23, 2016, the Air Pollution Control Division will begin a 30-day public notice period for Thermo Cogeneration Partnership, L. P. - JM Shafer Generating Station . A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, 1 Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure • C RL 3130 2016-1161 4-11-01D/4, _11_ n//_ 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe (Sr `��s. FJ if ff �-�� ohn W. Hickenlooper,Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer 1 *„ A CDPHE Air Pollution Control Division CO ,. ` Notice Of A Proposed Renewal Title V Operating Permit Warranting Public Comment Website Title: Thermo Cogeneration Partnership, L. P. - JM Shafer Generating Station - Weld County Notice Period Begins: March 23, 2016 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: Thermo Cogeneration Partnership, L. P. 1100 W 116th Avenue Westminster, CO 80234 Facility: JM Shafer Generating Station 6811 Weld County Road 31 Ft. Lupton, CO 80621 Thermo Cogeneration Partnership, L. P. has applied to renew the Operating Permit for the JM Shafer Generating Station in Weld County, CO. This facility consists of five (5) combustion turbine/duct burner packages that are used to produce electricity for sale. A minor modification application is being processed in conjunction with the renewal permit. The purpose of the modification is to reflect a sixth turbine that is used as a permanent spare for the facility. The modification does not result in any change in emissions. A copy of the application, including supplemental information, the Division's analysis, and a draft of the Renewal Operating Permit 95OPWE096 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. The Division has made a preliminary determination of approval of the application. Based on the information submitted by the applicant, the Division has prepared the draft renewal operating permit for approval. Any interested person may contact Jacqueline Joyce of the Division at 303-692-3267 to obtain additional information. Any interested person may submit written comments to the Division concerning 1) the sufficiency of the preliminary analysis, 2) whether the permit application should be approved or denied, 3) the ability of the proposed activity to comply with applicable requirements, 4) the air quality impacts of, alternatives to, and control technology required on the source or modification, and 5) any other appropriate air quality considerations. Any interested person may submit a written request to the Division for a public comment hearing before the Colorado Air Quality Control Commission (Commission) to receive comments regarding the concerns listed above as well as the sufficiency of the preliminary analysis and whether the Division should approve or deny the permit application. If requested, the hearing 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 q Y for any hearing for thirty calendar days after the date of this Notice. 1..I M `= OV ' Car.)44; A 'eP • ift" O crl at& SME NUM�� I876 4` Colorado Department of Public Health and Environment OPERATING PERMIT Thermo Cogeneration Partnership, L. P. JM Shafer Generating Station First Issued: January 1 , 1999 Renewed: DRAFT AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: JM Shafer OPERATING PERMIT NUMBER Generating Station FACILITY ID: 1230250 95OPWE096 RENEWED: EXPIRATION DATE: MODIFICATIONS: See Appendix F of Permit Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et sec. and applicable rules and regulations. ISSUED TO: PLANT SITE LOCATION: Thermo Cogeneration Partnership, L. P., JM Shafer Generating Station A wholly owned subsidiary of Tri-State Generation and Transmission Association, Inc. 6811 Weld County Road 31 1100 W. 116th Avenue Ft. Lupton, CO 80621 Westminster, CO 80234 Weld County INFORMATION RELIED UPON Operating Permit Renewal Application Received: December 23, 2014 And Additional Information Received: April 6, 2015 Nature of Business: Cogeneration Primary SIC: 4911 RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON Name: Barbara A. Walz Name: Daniel Salgado Title: Senior Vice President, Policy and Title: Senior Engineer, Environmental Services Compliance/Chief Compliance Officer Phone: (303)452-6111 Phone: (303) 254-3393 SUBMITTAL DEADLINES Semi-Annual Monitoring Periods: EXAMPLE (January 1 —June 30,July 1 —December 31) Semi-Annual Monitoring Reports: EXAMPLE (Due on Aug. 1, 2011 & Feb. 1, 2012 & subsequent years) Annual Compliance Period: EXAMPLE (January 1 —December 31) Annual Compliance Certification: EXAMPLE (Due on February 1, 2012 & subsequent years) Note that the Semi-Annual Monitoring Reports and Annual Compliance Certifications must be received at the Division office by 5:00 p.m. on the due date. Postmarked dates will not be accepted for the purposes of determining the timely receipt of those reports/certifications. TABLE OF CONTENTS: SECTION I- General Activities and Summary 1 1. Permitted Activities 1 2. Alternative Operating Scenarios (1/23/13 version) 2 3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant Deterioration(PSD) 5 4. Accidental Release Prevention Program (112(r)) 5 5. Compliance Assurance Monitoring(CAM) 5 6. Summary of Emission Units 6 SECTION II-Specific Permit Terms 7 1. S001-S005—Five(5) Turbine/Duct Burner Packages 7 Six(6)Natural Gas Fired Turbines (400 MMBtu/hr(HHV) each) 7 Five (5)Duct Burners (2 @ 240 MMBtu/hr(HHV)and 3 @ 180 MMBtu/hr(HHV)) 7 2. S006 - One (1)Diesel Fired Emergency Generator(8.57 MMBtu/hr(65 gal/hr) and 1,232 hp) 22 3. S007 - One (1)Diesel Fired Emergency Fire Pump(2.28 MMBtu/hr(17.3 gal/yr) and 310 hp) 24 4. S011 - One (1)Forced Draft Water Cooling Tower w/Drift Eliminators 26 5. Continuous Emission Monitoring Requirements 27 6. National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (40 CFR Part 63 Subpart ZZZZ) 31 7. Cold Cleaner Solvent Vat 37 SECTION III-Acid Rain Requirements 38 1. Designated Representative and Alternate Designated Representative 38 2. Sulfur Dioxide Emission Allowances and Nitrogen Oxide Emission Limitations 38 3. Standard Requirements 39 4. Reporting Requirements 42 5. Comments,Notes and Justifications 43 SECTION IV-Permit Shield 44 1. Specific Non-Applicable Requirements 44 2. General Conditions 44 3. Streamlined Conditions 45 SECTION V-General Permit Conditions 46 1. Administrative Changes 46 2. Certification Requirements 46 3. Common Provisions 46 4. Compliance Requirements 50 5. Emergency Provisions 51 6. Emission Controls for Asbestos 51 7. Emissions Trading, Marketable Permits, Economic Incentives 51 8. Fee Payment 51 9. Fugitive Particulate Emissions 52 10. Inspection and Entry 52 11. Minor Permit Modifications 52 12. New Source Review 52 13. No Property Rights Conveyed 52 14. ; Odor 52 TABLE OF CONTENTS: 15. Off-Permit Changes to the Source 53 16. Opacity 53 17. Open Burning 53 18. Ozone Depleting Compounds 53 19. Permit Expiration and Renewal 53 20. Portable Sources 53 21. Prompt Deviation Reporting 53. 22. Record Keeping and Reporting Requirements 54 23. Reopenings for Cause 55 24. Section 502(b)(10)Changes 55 25. Severability Clause 56 26. Significant Permit Modifications 56 27. Special Provisions Concerning the Acid Rain Program 56 28. Transfer or Assignment of Ownership 56 29. Volatile Organic Compounds 56 30. Wood Stoves and Wood burning Appliances 57 APPENDIX A-Inspection Information 1 Directions to Plant: 1 Safety Equipment Required: 1 Facility Plot Plan• 1 List of Insignificant Activities: 1 APPENDIX B 1 Reporting Requirements and Definitions 1 Startup, Shutdown,Malfunctions and Emergencies 3 Monitoring and Permit Deviation Report -Part I 5 Monitoring and Permit Deviation Report-Part II 7 Monitoring and Permit Deviation Report -Part III 9 APPENDIX C 1 Format for Annual Compliance Certification Reports 1 APPENDIX D 1 Notification Addresses 1 APPENDIX E 1 Permit Acronyms 1 APPENDIX F 1 Permit Modifications 1 Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 1 SECTION I - General Activities and Summary 1. Permitted Activities 1.1 This facility consists of a cogeneration facility defined under Standard Industrial Classification 4911. Electricity for sale is produced by five (5) combustion turbine/duct burner packages. There are six combustion turbines any one of which may operate in any one of the turbine/duct burner packages. A maximum of five combustion turbines can be operating at any time. Each combustion turbine serves a generator rated at 57.412 MW (name-plate), however, each turbine only generates enough horsepower to produce about 37 MW. Exhaust gas from the combustion turbine, which may be heated further by a duct burner, is used to either generate electricity or to heat a nearby tomato greenhouse. There are two steam turbines, each rated at 52.220 MW (name-plate). Other significant emission units at this facility are a cooling tower, emergency back-up generator and fire pump and a cold cleaner solvent vat. The facility is located in Weld County at 6811 Weld County Road 31, in Ft. Lupton, CO. The area in which the plant operates is designated as attainment for all criteria pollutants except ozone. It is classified as non-attainment for ozone and is part of the 8-hour Ozone Control Area as defined in Colorado Regulation No. 7, Section II.A.1. There are no affected states within 50 miles of the plant. The following Federal Class I designated areas are 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 This Operating Permit incorporates the applicable requirements contained in the underlying construction permits, and does not affect those applicable requirements, except as modified during review of the application or as modified subsequent to permit issuance using the modification procedures found in Regulation No. 3, Part C. These Part C procedures meet all applicable substantive New Source Review requirements of Part B. Any revisions made using the provisions of Regulation No. 3, Part C shall become new applicable requirements for the 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: 91WE667 and 96WE075. 1.4 All conditions in this permit are enforceable by US Environmental Protection Agency, Colorado Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless otherwise specified. State-only enforceable conditions are: Permit Condition Number(s): Section II - Condition 1.12.1 (opacity), Section V - Conditions 3.g(last paragraph), 14 and 18 (as noted). 1.5 All information gathered pursuant to the requirements of this permit is subject to the Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions in Section V of this permit. Either electronic or hard copy records are acceptable. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership,L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 2 2. Alternative Operating Scenarios(1/23/13 version) The following Alternative Operating Scenario (AOS) for the temporary replacement of combustion turbines and turbine components 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 found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any turbine or turbine component replacement performed in accordance with this AOS, and the permittee shall be allowed to perform such turbine or turbine component replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Routine Turbine Component Replacements 2.1.1 The following physical or operational changes to the turbines in this permit are not considered a modification for purposes of NSPS GG, major stationary source NSR/PSD, or Regulation No. 3, Part B. Note that the component replacement provisions apply ONLY to those turbines subject to NSPS GG. Neither pre-GG turbines nor post GG turbines (i.e. KKKK turbines) can use those provisions. In the event that EPA promulgates amendments to Subparts GG and/or KKKK that further define or alter the defmition of component replacements that will not trigger modifications, the provisions of those rules shall supersede the component replacement provisions listed below. 2.1.1.1 Replacement of stator blades, turbine nozzles, turbine buckets, fuel nozzles, combustion chambers, seals, and shaft packings, provided that they are of the same design as the original. 2.1.1.2 Changes in the type or grade of fuel used, if the original gas turbine installation, fuel nozzles, etc.were designed for its use. 2.1.1.3 An increase in the hours of operation (unless limited by a permit condition). 2.1.1.4 Variations in operating loads within the turbine design specification. 2.1.1.5 Any physical change constituting routine maintenance, repair or replacement. 2.1.2 Turbines undergoing any of the above changes 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. If replacement of any of the components listed in Conditions 2.1.1.1 through 2.1.1.5 above results in a change in serial number for the turbine, a letter explaining the action as well as a revised APEN and appropriate filing fee shall be submitted to the Division within 30 days of the replacement. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 3 2.1.3 Note that the repair or replacement must be genuinely the same design. Except in accordance with the Alternative Operating Scenario set forth below,the Division does not consider that this allows for the entire replacement (or reconstruction) of an existing turbine with an identical new one or one similar in design or function. Rather, the Division considers the repair or replacements to encompass the repair or replacement of components at a turbine with the same (or functionally similar) components. 2.2 General Requirements for Turbine Replacements The following AOS is incorporated into this permit in order to deal with a turbine breakdown or periodic routine maintenance and repair of an existing onsite turbine that requires the use of a temporary replacement turbine. The definitions of "Temporary" and "Permanent" for each permitted unit are defined in Condition 2.7. The compliance demonstrations required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement turbines 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. 2.3 Monitoring Requirements for Turbine Replacements Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, data from the CEM shall be evidence of enforceable compliance or noncompliance of the replacement turbine with any short-term NOx and CO emissions limitations of the original turbine. For comparison with an annual NOx and CO emissions limit, data from the CEM shall be used to calculate the actual NOx and CO emissions as set forth in this permit. If the data from the CEM 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 turbine is in compliance with both the NOx and CO emission limitations for the relevant time period. If the CEM data fails to demonstrate compliance with any of the NOx or CO emission limitations, and in the absence of credible evidence to the contrary,the turbine will be considered to be out of compliance for the relevant time periods(s). All data that indicates noncompliance shall be submitted to the Division within 14 calendar days after the data is collected. 2.4 Recordkeeping Requirements for Turbine Replacements The permittee shall maintain a log on-site to contemporaneously record the start and stop date of any turbine replacement, the manufacturer and serial number of the turbine(s) that are replaced during the term of this permit, and the manufacturer and serial number of the replacement turbine. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership,L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 4 2.5 Specific Requirements for Temporary Replacements The permittee may temporarily replace an existing turbine covered by this permit as specified in Condition 2.7 with the exact make and model turbine without modifying this permit so long as the replacement turbine complies with the emission limitations and other requirements applicable to the original turbine as well as any new applicable requirements for the replacement turbine. The permittee may temporarily replace a grandfathered or permit exempt turbine or a turbine 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 turbine as projected by the CEM must be less than or equal to the potential annual emissions of NOx and CO from the original grandfathered or permit exempt turbine or for the turbine that is not subject to emission limits, as determined by applying appropriate emission factors (e.g. AP-42 or manufacturer's emission factors). 2.6 Additional Sources The replacement of an existing turbine with a new turbine 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; a turbine that is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing onsite turbine has to go through the appropriate Construction/Operating permitting process prior to installation. 2.7 Allowable Replacements Table 1 —Turbine Replacements Allowed by the AOS Permitted Turbine Allowable Replacements' Point Make/Model Temporary replacement units may operate up to 270 days in any 12 — (AIRS points 001 General Electric month period2 —005) LM6000 Permanent replacement units: not allowed (new permit or permit modification required) Note 1: Replacement unit must be of the same make and model as the permitted unit. Note 2: The temporary replacement period is the total number of operating days that the replacement unit may operate in the same service. If the temporary replacement turbine operates only part of a day, that day counts toward the total. Temporary replacement units shall comply with all requirements in Conditions 2.2, 2.3 and 2.4, and with the specific requirements for temporary replacements in Condition 2.5. • Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 5 3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) 3.1 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 VOC or NOx or a modification which is major by itself(Potential to Emit ≥ 100 tons/year or either VOC or NOx) may result in the application of the NANSR review requirements. 3.2 This facility is categorized as a PSD major stationary source (Potential to Emit≥ 100 tons/yr) for NOx and CO. Future modifications at this facility resulting in a significant net emissions increase (see Regulation 3, Part D, Section II.A.27 and 44) for any pollutant as listed in Regulation No. 3, Part D, Section II.A.44 for which the area is in attainment or attainment/maintenance or a modification which is major by itself may result in the application of the PSD review requirements. 3.3 There are no other Operating Permits associated with this facility for purposes of determining applicability of NANSR and PSD review regulations. 4. Accidental Release Prevention Program (112(r)) 4.1 Based on the information provided by the applicant, this facility is not subject to the provisions of the Accidental Release Prevention Program (section 112(r) of the Federal Clean Air Act). 5. Compliance Assurance Monitoring (CAM) 5.1 The following emission points at this facility use a control device to achieve compliance with an emission limitation or standard to which they are subject and have pre-control emissions that exceed or are equivalent to the major source threshold. They are therefore subject to the provisions of the CAM program as set forth in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV: The turbines are not subject to CAM since at the time the CAM plan was required the Title V permit specified a continuous compliance determination method(40 CFR Part 64 § 64.2(b)(1)(vi), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 6 6. Summary of Emission Units 6.1 The emissions units regulated by this permit are the following: Emission AIRS Description Startup Date Pollution Control Unit Point Device No. Number S001- 001-005 Five(5)turbine/duct burner packages. May 1994 Steam Injection S005 Six (6) General Electric LM6000 Natural Gas Combustion Technology Turbines,Rated at 400 MMBtu/hr(HHV)Each, SN's: 185-130, (Turbines) 185-126, 185-135, 185-136, 185-137 and 185-238, Equipped with Five(5)Coen 12408-1 Duct Burners,Two(2)Rated at 240 MMBtu/hr (HHV) and Three (3) Rated at 180 MMBtu/hr (HHV). Only five combustion turbines are permitted to operate at any time. S006 006 One Detroit Diesel 8163-7416 Emergency Back-up Engine, May 1994 Uncontrolled Rated at 8.57 MMBtu/hr (65 gal/hr) and 1,232 hp , SN: Unknown. S007 007 One Clark DDFP-T6AT Emergency Diesel Fired Fire Pump, May 1994 Uncontrolled Rated at 2.28 MMBtu/hr(17.3 gal/hr)and 310 hp,SN:Unknown S011 009 One Custom Forced Draft Industrial Cooling Tower Equipped May 1994 Drift Eliminators with Munters D15 Drift Eliminators. M001 N/A Cold Cleaner Solvent Vat Uncontrolled Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT I _ Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 7 SECTION II- Specific Permit Terms 1. S001-S005—Five(5)Turbine/Duct Burner Packages Six(6) Natural Gas Fired Turbines (400 MMBtu/hr(HHV) each) Five (5)Duct Burners (2 @ 240 MMBtu/hr(HHV) and 3 @ 180 MMBtu/hr(HHV)) 1 _. Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number BACT 1.1 N/A N/A N/A See Condition 1.1 Requirements PM 1.2 N/A Each Package Turbine: Recordkeeping Monthly (turbine plus 0.0066 lb/MMBtu and Calculations duct burner): Duct Burner: 16.81 tons/year 0.005 lb/M Btu All Packages Combined: 84.05 tons/year Each Turbine: 0.105 lb/mmBtu N/A Fuel Restriction Only Pipeline Each Turbine/Duct Burner(240 Natural Gas mmBtu/hr)Package: is Used as 0.111 lb/mmBtu Fuel Each Turbine/Duct Burner(180 mmBtu/hr)Packge: 0.113 lb/mmBtu PM10 N/A Each Package Turbine: Recordkeeping Monthly (turbine plus 0.0066 lb/MNIBtu and Calculation duct burner): Duct Burner: 16.81 tons/year 0.005 lb/MMBtu All Packages Combined: 84.05 tons/year SO2 1.3 NA Each Package. N/A 40 CFR Part 75, As specified (turbine plus Appendix D in 40 CFR duct burner): Part 75, 2.00 tons/year Appendix D All Package Combined: 10.00 tons/year Each Turbine: N/A Fuel Restriction See 150 ppmvd @ 15%O2 OR Use of Condition 1.3 Fuel Which Contains Less than 0.8 Weight%Sulfur Each Turbine: N/A 0.35 lbs/MMBtu Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership,L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 8 Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number NOx 1.4 NA Each Package N/A Continuous Continuously (turbine plus Emission duct burner): Monitoring 146.5 tons/year System All Packages Combined: 589.0 tons/year 25 ppmvd @ 15%O2,on a daily average,except as provided for below: During Startup and Shutdown: 38 lbs per event During Combustion Tuning and Testing(not to exceed 150 hrs/yr for all five packages combined): 115 ppmvd @ 15%O2,on a 1-hr average Each Turbine Only: 126.9 ppmvd at 15%O2 CO 1.5 NA Each Package N/A Continuous Continuously (turbine plus Emissions duct burner): Monitoring 90.51 tons/year System All Packages Combined: 452.55 tons/year 25 ppmvd @ 15%O2,on a daily average,except as provided for below: During Startup and Shutdown: 25 lbs per event During Combustion Tuning and Testing(not to exceed 150 hrs/yr for all five packages combined): 115 ppmvd @ 15%O2,on a 1-hr average VOC 1.6 Each Package Each Package Turbine: See Condition 1.6 (turbine plus (turbine plus 0.00564 duct burner): duct burner): lb/MMBtu 3.63 lbs/hr 9.64 tons/year Duct Burner: All Packages 0.00564 Combined: lb/MMBtu 48.2 tons/year Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 9 Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number Natural Gas 1.7 N/A All Turbines N/A Fuel Meters Monthly Consumption Combined: 10,375 MMscf/year All Duct Burners Combined: 4,575 MMscf/year Continuous 1.8 N/A N/A N/A See Condition 1.8 Emission Monitoring System Requirements Sulfur Content 1.9 N/A N/A NA See Condition 1.9 of Fuel Btu Content of 1.10 NA NA NA ASTM Analysis Semi- Fuel Method Annually NSPS General 1.11 NA NA NA As required in the Subject to Provisions NSPS General NSPS Provisions General Provisions Opacity 1.12 State Only Requirement: Not to N/A See Condition 1.12 Exceed 20% Not to Exceed 20%,Except as Provided for Below For Certain Operational Activities- Not to Exceed 30%,for a Period or Periods Aggregating More than Six (6)Minutes in any 60 Consecutive Minutes Acid Rain 1.13 See Section HI of this Permit Certification Annually Requirements Operating 1.14 Only Five(5)Combustion Turbines Can Operate at Any Recordkeeping See Restrictions One Time Condition 1.14 1.1 The combustion turbines and duct burners are subject to the requirements of the Prevention of Significant Deterioration (PSD) Program. Best Available Control Technology(BACT) shall be applied for control of Nitrogen Oxides (NOx), Carbon Monoxide (CO), Particulate Matter Emissions (PM and PM10) and Volatile Organic Compounds (VOC). BACT has been determined as follows: 1.1.1 BACT for NOx has been determined to be enhanced steam injection technology and emission limits as identified in Condition 1.4.2 (Colorado Construction Permit 91 WE667). Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership,L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 10 1.1.2 BACT for CO has been determined to be use of good combustion practices and the emission limits as identified in Condition 1.5.2 (Colorado Construction Permit 91 WE667). 1.1.3 BACT for PM and PMI()has been determined to be use of pipeline natural gas as fuel, as defmed in Condition 1.9(Colorado Construction Permit 91WE667). 1.1.4 BACT for VOC has been determined to be use of good combustion practices, use of pipeline natural gas as fuel, as defmed in Condition 1.9, and the emission limits identified in Condition 1.6.2 (Colorado Construction Permit 91 WE667, as modified under the provisions of Section I, Condition 1.3 to identify VOC BACT determination). 1.2 Particulate Matter Emissions are subject to the following requirements: 1.2.1 Annual emissions of PM and PM1e from each turbine/duct burner package AND from all turbine/duct burner packages combined shall not exceed the limitations stated above (Colorado Construction Permit 91WE667). Emissions from each emission unit shall be calculated by the end of the subsequent month using the above emission factors (for turbine, from AP-42, Section 3.1 (dated April 2000), Table 3.1- 2a, for duct burners, from manufacturer, as indicated in September 13, 1991 memo from Nooter/Eriksen Cogeneration Systems, Inc.), the monthly natural gas consumption and the higher heating value of the fuel (see Condition 1.10) in the following equations: Turbine: tons/month=(EF.lbs/MMBtu)x(Fuel Use.MMSCF/mo)x(Heat Content of Fuel.MMBtu/MMSCF) 2000 lbs/ton Duct Burner: tons/month=(EF.lbs/MMBtu)x(Fuel Use.MMSCF/mo)x(Heat Content of Fuel.MMBtu/MMSCF) 2000 lbs/ton Monthly emissions from each turbine and duct burner will be summed together and used in a twelve month rolling total to monitor compliance with the individual package (turbine/duct burner) annual emission limitation. Each month a new twelve month rolling total shall be calculated using the previous twelve months' data. Monthly emissions from each turbine/duct burner package will be summed together and used in a twelve month rolling total to monitor compliance with the annual emission limitation for all packages combined. Each month a new twelve month rolling total shall be calculated using the previous twelve months' data. 1.2.2 Particulate Matter (PM) emissions from each turbine and each turbine/duct burner package shall not exceed the above limitations (Colorado Regulation No. 1, Section III.A.1.b). In the absence of-credible evidence to the contrary, compliance with the particulate matter emission limits is presumed since only pipeline natural gas Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 11 that meets the requirements in Condition 1.9 is permitted to be used as fuel in the turbines and the duct burners. The numeric PM standards were determined as follows: For simple cycle operation or combined cycle operation without supplemental fuel (turbine only) the standard was determined using the design heat input for the turbine (400 mmBtu/hr) in the following equation: PE=0.5 x(FI)-°26' where: PE=particulate standard in lbs/mmBtu FI=fuel input in mmBtu/hr For combined cycle operation with supplemental fuel (turbine and duct burner), the standard was determined using the design heat input for the turbine (400 mmBtu/hr) and the duct burner(240 mmBtu/hr or 180 mmBtu/hr) in the following equation: PE(turbine/duct burner)=PET x FIT+PE B x FInB FIT+FIDB 1.3 Sulfur Dioxide (SO2) emissions shall not exceed the following limitations: 1.3.1 Annual emissions of SO2 from each turbine/duct burner package AND from all turbine/duct burner packages combined shall not exceed the limitations stated above (Colorado Construction Permit 91WE667). Compliance with the annual SO2 emission limitations shall be monitored using the monitoring method specified in 40 CFR Part 75 Appendix D. Monthly emissions from each turbine/duct burner package will be summed together and used in a twelve month rolling total to monitor compliance with the individual package (turbine/duct burner) annual emission limitation. Each month a new twelve month rolling total shall be calculated using the previous twelve months' data. Monthly emissions from each turbine/duct burner package will be summed together and used in a twelve month rolling total to monitor compliance with the annual emission limitation for all packages combined. Each month a new twelve month rolling total shall be calculated using the previous twelve months' data. 1.3.2 Each turbine shall meet one of the following requirements: 1.3.2.1 Sulfur Dioxide (SO2) emissions from the turbine shall not exceed 150 ppmvd at 15% O2, OR 1.3.2.2 No fuel, which contains sulfur in excess of 0.8 percent by weight, shall be used in this combustion turbine (40 CFR Part 60 Subpart GG §§ 60.333(a) & (b), as adopted by reference in Colorado Regulation No. 6, Part A). Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership,L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 12 In the absence of credible evidence to the contrary, compliance with the above requirements is presumed since only pipeline natural gas is permitted to be used as fuel. The pipeline natural gas used as fuel shall meet the requirements in Condition 1.9. 1.3.3 Sulfur Dioxide (SO2) emissions from each turbine shall not exceed 0.35 lbs/MMBtu, on a 3-hr rolling average (Colorado Regulation No. 1, Section VI.B.4.c.(ii) and VI.B.2). In the absence of credible evidence to the contrary, compliance with the SO2 limitations is presumed since only pipeline natural gas that meets the requirements in Condition 1.9 is permitted to be used as fuel in each turbine. 1.4 Nitrogen Oxide(NOx)emissions shall not exceed the following: 1.4.1 Annual emissions of NOx from each turbine/duct burner package AND from all turbine/duct burner packages combined shall not exceed the limitations stated above (Colorado Construction Permit 91WE667). Monthly emissions from each turbine/duct burner package shall be determined using the continuous emission monitoring system required by Condition 1.8. For any hour in which fuel is combusted in the turbine/duct burner package, including periods of startup, shutdown and malfunction, the permittee shall program the DAHs to calculate lb/hr NOx emissions in accordance with the requirements in Condition 5.1.1.3.b of this permit and 40 CFR Part 75, including any replaced data and the data shall be bias-adjusted, if warranted. Specifically hourly mass NOx emissions (in lb/hr) shall be calculated by multiplying the valid hourly NOx lb/MMBtu values (which includes replaced or bias-adjusted data, as applicable) by the hourly heat input value (M vIBtu/hr) (which includes replaced data from the fuel flow measurement, as applicable). The hourly NOx lb/MMBtu and heat input values shall be determined using equations F-5 or F-6, as appropriate for the diluents monitored by the CEMS and equation F-20 in Appendix F of 40 CFR Part 75. The resulting NOx lb/hr value is then multiplied by the unit operating time for that hour to produce a NOx lbs value. Hourly NOx mass emissions (lbs) shall be summed and divided by 2000 lb/ton to determine monthly NOx emissions(in tons). Monthly emissions from each turbine/duct burner package shall be used in a twelve month rolling total to monitor compliance with the individual package annual emission limitation. Each month a new twelve month rolling total shall be calculated using the previous twelve months' data. Monthly emissions from each turbine/duct burner package will be summed together and used in a twelve month rolling total to monitor compliance with the annual emission limitation for all packages combined. Each month a new twelve month rolling total shall be calculated using the previous twelve months' data. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 13 1.4.2 For BACT purposes, NOx emissions from each turbine/duct burner package shall not exceed the following limitations (Colorado Construction Permit 91WE667, as modified under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Sections I.A.7 and III.B.7 to include alternate BACT limits for periods of startup and shutdown and combustion tuning and testing): 1.4.2.1 Except as provided for in Conditions 1.4.2.2 and 1.4.2.3, NOx emissions shall not exceed 25 ppmvd at 15%O2, on a daily average. 1.4.2.2 During periods of startup and shutdown, NOx emissions shall not exceed 38 lbs during each startup and/or shutdown event. 1.4.2.3 During periods of combustion tuning and testing,NOx emissions shall not exceed 115 ppmvd at 15% O2, on a 1-hour average. Use of this NOx emission limit for purposes of combustion tuning and testing shall not exceed 150 hours in any calendar year for all five turbine/duct burner packages combined. Records of the number of hours the package undergoes combustion tuning and testing shall be recorded and maintained and made available to the Division upon request. 1.4.2.4 "Startup" means the setting in operation of any air pollution source for any purpose. Setting in operation for these turbines begins when fuel is injected into the turbine. Setting in operation for these turbines ends when the turbine reaches 15 MW or steam injection is initiated, whichever comes first. 1.4.2.5 "Shutdown" means the cessation of operation of any air pollution source for any purpose. The cessation of operation for these turbines begins when the command signal is initiated by the turbine operator to shutdown the unit and ends when fuel is no longer being fired in the turbine. 1.4.2.6 "Combustion Turning and Testing" means the operation of the package for the purpose of performing combustion tuning and testing operations after a unit overhaul or as part of routine maintenance operations. Combustion tuning and testing can occur throughout the range of the operating conditions. Compliance with these NOx limitations shall be monitored using the continuous emission monitoring system (CEMS) required by Condition 1.8, as follows: 1.4.2.7 Except as provided for in Conditions 1.4.2.8 and 1.4.2.9, all valid CEMS concentration (ppm) data points, excluding startup, shutdown and combustion turning and testing data points shall, at the end of each clock hour, be summarized to generate the one-hour average NOx concentration in accordance with the requirements in 40 CFR Part 75 and Condition 5.1.1.3.b of this permit. Data used to generate the one-hour average NOx concentration shall not include replaced data, nor shall the data be bias- adjusted. Replaced data shall be reported as monitor down time in the quarterly reports required by Condition 5.4. Compliance with the Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership,L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 14 limitation in Condition 1.4.2.1 shall be based on a daily average. All valid operating hours from every midnight to midnight period shall be used to calculate the daily average. This includes any partial hours as described in Conditions 1.4.2.8 and 1.4.2.9 below. Each daily average NOx concentration shall be compared to the limitation in Condition 1.4.2.1 to assess compliance. 1.4.2.8 All valid CEMS data points within the startup and/or shutdown period shall be summed together to determine the NOx emissions(in lbs)for each startup and/or shutdown event. Data used to generate the NOx mass emissions for startup and/or shutdown event shall not include replaced data,nor shall the data be bias-adjusted. Replaced data shall be reported as monitor down time in the quarterly reports required by Condition 5.4. Specifically, mass NOx emissions (in lb/event) shall be calculated by multiplying the NOx lb/MMBtu value for the event(excluding replaced or bias-adjusted data, as applicable) by the heat input value (MMBtu) for the event (which excludes replaced data from the fuel flow measurement, as applicable). The NOx lb/MMBtu and heat input values shall be determined using equations F-5 or F-6, as appropriate for the diluents monitored by the CEMS and equation F-20 in Appendix F of 40 CFR Part 75. Mass emissions from each startup and shutdown event shall be compared with the limitation in Condition 1.4.2.2 to assess compliance. In the event that the startup ends within a clock hour or the shutdown begins within a clock hour, all non-startup and/or non-shutdown concentration (ppm) data points within that clock hour shall be averaged together to generate the average NOx concentration in accordance with the requirements in 40 CFR Part 75 and Condition 5.1.1.3.b of this permit and that average concentration shall be included in the daily average required by Condition 1.4.2.7. 1.4.2.9 During periods of combustion tuning and testing, all valid CEMS concentration (ppm) data points shall, at the end of each clock hour, be summarized to generate the one-hour average NOx concentration in accordance with the requirements in 40 CFR Part 75 and Condition 5.1.1.3.b of this permit. Data used to generate the one-hour average NOx concentration shall not include replaced data, nor shall the data be bias- adjusted. Replaced data shall be reported as monitor down time in the quarterly reports required by Condition 5.4. Each clock hour average NOx concentration shall be compared to the limitation in Condition 1.4.2.3 to assess compliance. In the event that the tuning and testing period ends within a clock hour, all non-tuning and testing concentration (ppm) data points within that clock hour shall be averaged together to generate the average NOx concentration in accordance with the requirements in 40 CFR Part 75 and Condition Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 15 5.1.1.3.b of this permit and that average concentration shall be included in the daily average required by Condition 1.4.2.7. 1.4.3 Nitrogen Oxide (NOx) Emissions from each turbine shall not exceed 126.9 ppmvd at 15% O2, on a 4-hour rolling average (40 CFR Part 60 Subparts GG §§ 60.332(a)(1) and 60.334(j)(1)(iii)(A), as adopted by reference in Colorado Regulation No. 6, Part A). The permittee has elected to not correct emissions to International Organization for Standardization(ISO) standard day conditions as allowed in Condition 5.3.2. Compliance with the above NSPS GG NOx limitation shall be monitored using the continuous emission monitoring system required by Condition 1.8, as follows: 1.4.3.1 All valid CEMS concentration (ppm) data points, including startup, shutdown and malfunction data points, shall at the end of each clock hour, be summarized to generate the average NOx concentration in accordance with the requirements in 40 CFR Part 75 and Condition 5.1.1.3.b of this permit. 1.4.3.2 Data used to generate the one-hour average NOx concentration shall not include replaced data, nor shall the data be bias-adjusted. Replaced data shall be reported as monitor down time in the quarterly reports required by Condition 5.4. 1.4.3.3 Excess emissions shall be reported for all periods of unit operation, including startup, shutdown and malfunction (40 CFR Part 60 Subpart GG § 60.334(j)). Note that the NOx emission limitations are not applicable during times of startup, shutdown and malfunction. However, as noted above those instances during startup, shutdown and malfunction when the NOx limitation is exceeded shall be identified in the Excess Emission Report required in Condition 5.4. 1.4.3.4 An hour of excess emissions shall be any unit operating hour (any clock hour during which fuel is combusted) in which the 4-hour rolling average NOx concentration exceeds the applicable emission limit in Condition 1.4.3. For the purposes of 40 CFR Part 60 Subpart GG, a "4-hour rolling average NOx concentration" is the arithmetic average of the average NOx concentration measured by the CEMS for a given hour (corrected to 15 percent O2) and the three unit operating hour average NOx concentrations immediately preceding that unit operating hour (40 CFR Part 60 Subpart GG § 60.334(j)(1)(iii)(A)). 1.4.3.5 A period of monitor downtime shall be any unit operating hour in which sufficient data are not obtained to validate the hour, for either NOx concentration or diluent (or both) (40 CFR Part 60 Subpart GG § 60.334(j)(1)(iii)(B)). 1.4.3.6 The permittee has elected to not correct emissions to ISO standard Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership,L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 16 ambient conditions, as allowed in Condition 5.3.2, therefore, ambient conditions at the time of the excess emission period do not have to be reported as specified in 40 CFR Part 60 Subpart GG § 60.334(j)(1)(iii)(C). 1.5 Emissions of Carbon Monoxide(CO)shall not exceed the following limitations: 1.5.1 Annual emissions of CO from each turbine/duct burner package AND from all turbine/duct burner packages combined shall not exceed the limitations stated above (Colorado Construction Permit 91WE667). Monthly emissions from each turbine/duct burner package shall be determined using the continuous emission monitoring system required by Condition 1.8. For any hour in which fuel is combusted in the turbines, including periods of startup, shutdown and malfunction, the permittee shall program the DAHs to calculate lb/hr CO emissions in accordance with the requirements in Condition 5.1.1.3.b of this permit using the procedures in 40 CFR Part 75, including any replaced data, if warranted. Specifically hourly mass CO emissions (in lb/hr) shall be calculated by multiplying the valid hourly CO lb/MMBtu values (which includes replaced data in accordance with the requirements in Condition 5.5.2, as applicable) by the hourly heat input values(MMBtu/hr) (which includes replaced data from the fuel flow measurement, as applicable). The hourly CO lb/MIviBtu and heat input values shall be determined using equations F-5 or F-6 (where K = 7.272 x 10.8 for CO), as appropriate for the diluent monitored by the CEMS and equation F-20 in Appendix F of 40 CFR Part 75. The resulting CO lb/hr value is then multiplied by the unit operating time for that hour to produce a CO lbs value. Hourly CO mass emissions (lbs) shall be summed and divided by 2000 lb/ton to determine monthly CO emissions(in tons). Monthly emissions from each turbine/duct burner package shall be used in a twelve month rolling total to monitor compliance with the individual package annual emission limitation. Each month a new twelve month rolling total shall be calculated using the previous twelve months' data. Monthly emissions from each turbine/duct burner package will be summed together and used in a twelve month rolling total to monitor compliance with the annual emission limitation for all packages combined. Each month a new twelve month rolling total shall be calculated using the previous twelve months' data. 1.5.2 For BACT purposes, CO emissions from each turbine/duct burner package shall not exceed the following (Colorado Construction Permit 91WE667, as provided for under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Sections I.A.7 and III.B.7 to include alternate BACT limits for periods of startup and shutdown and combustion tuning and testing): 1.5.2.1 Except as provided for in Conditions 1.5.2.2 and 1.5.2.3, CO_emissions shall not exceed 25 ppmvd at 15%O2, on a daily average. 1.5.2.2 During periods of startup and shutdown, CO emissions shall not exceed 25 Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 17 lbs during each startup and/or shutdown event. 1.5.2.3 During periods of combustion tuning and testing, CO emissions shall not exceed 115 ppmvd at 15% O2, on a 1-hour average. Use of this CO emission limit for purposes of combustion tuning and testing shall not exceed 150 hours in any calendar year for all five turbine/duct burner packages combined. Records of the number of hours the package undergoes combustion tuning and testing shall be recorded and maintained and made available to the Division upon request. 1.5.2.4 "Startup" shall have the same definition as provided for in Condition 1.4.2.4. 1.5.2.5 "Shutdown" shall have the same definition as provided for in Condition 1.4.2.5. 1.5.2.6 "Combustion Tuning and Testing" shall have the same definition as provided for in Condition 1.4.2.6. Compliance with these CO BACT limits shall be monitored using the continuous emission monitoring system required by Condition 1.8. 1.5.2.7 Except as provided for in Conditions 1.5.2.8 and 1.5.2.9, all valid CEMS concentration (ppm) data points, excluding startup, shutdown and combustion turning and testing data points shall, at the end of each clock hour, be summarized to generate the one-hour average CO concentration in accordance with the requirements in Conditions 5.1.1.1.d and 5.1.1.3.b of this permit using the procedures in 40 CFR Part 75. Data used to generate the one-hour average CO concentration shall not include replaced data, nor shall the data be bias-adjusted. Replaced data shall be reported as monitor down time in the quarterly reports required by Condition 5.4. Compliance with the limitation in Condition 1.5.2.1 shall be based on a daily average. All valid operating hours from every midnight to midnight period shall be used to calculate the daily average. This includes any partial hours as described in Conditions 1.5.2.8 and 1.5.2.9 below. Each daily average CO concentration shall be compared to the limitation in Condition 1.5.2.1 to assess compliance. 1.5.2.8 All valid CEMS data points within the startup and/or shutdown period shall be summed together to determine the CO emissions for each startup and/or shutdown event. Data used to generate the CO mass emissions for startup and/or shutdown event shall not include replaced data, nor shall the data be bias-adjusted. Replaced data shall be reported as monitor down time in the quarterly reports required by Condition 5.4. Specifically hourly mass CO emissions (in lb/hr) shall be calculated by multiplying the hourly CO lb/MMBtu value (excluding replaced data) by the hourly heat input value (MMBtu/hr) (which excludes replaced data from the fuel flow measurement, as applicable). The hourly CO lb/MMBtu and heat input Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership,L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 18 values shall be determined using equations F-5 or F-6 (where K = 7.27 x 10-8 for CO), as appropriate for the diluent monitored by the CEMS and equation F-20 in Appendix F of 40 CFR Part 75. Mass emissions from each startup and shutdown event shall be compared with the limitation in Condition 1.5.2.2 to assess compliance. In the event that the startup ends within a clock hour or the shutdown begins within a clock hour, all non-startup and/or non-shutdown concentration (ppm) data points within that clock hour shall be averaged together to generate the average CO concentration in accordance with the requirements in Conditions 5.1.1.1.d and 5.1.1.3.b of this permit using the procedures in 40 CFR Part 75 and that average concentration shall be included in the daily average required by Condition 1.5.2.7. 1.5.2.9 During periods of combustion tuning and testing, all valid CEMS concentration (ppm) data points shall, at the end of each clock hour, be summarized to generate the one-hour average CO concentration in accordance with the requirements in Conditions 5.1.1.1.d and 5.1.1.3.b of this permit using the procedures in 40 CFR Part 75. Data used to generate the one-hour average CO concentration shall not include replaced data, nor shall the data be bias-adjusted. Replaced data shall be reported as monitor down time in the quarterly reports required by Condition 5.4. Each clock hour average CO concentration shall be compared to the limitation in Condition 1.5.2.3 to assess compliance. In the event that the tuning and testing period ends within a clock hour, all non-tuning and testing concentration (ppm) data points within that clock hour shall be averaged together to generate the average CO concentration in accordance with the requirements in Conditions 5.1.1.1.d and 5.1.1.3.b of this permit using the procedures in 40 CFR Part 75 and that average concentration shall be included in the daily average required by Condition 1.5.2.7. 1.6 Volatile Organic Compound(VOC)emissions shall not exceed the following limitations: 1.6.1 Annual emissions of VOC from each turbine/duct burner package AND from all turbine/duct burner packages combined shall not exceed the limitations stated above (Colorado Construction Permit 91WE667). Emissions from each emission unit shall be calculated by the end of the subsequent month using the above emission factors (for turbines and duct burners,from turbine manufacturer,the November 1997 performance test indicates emissions from both the turbine alone and the turbine and duct burner together are well below this emission factor), the monthly natural gas consumption and the higher heating value of the fuel (see Condition 1.10) in the equations in Condition 1.2.1 of this permit. Monthly emissions from each turbine and duct burner will be summed together and used in a twelve month rolling total to monitor compliance with the individual Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 19 package annual emission limitation. Each month a new twelve month rolling total shall be calculated using the previous twelve months' data. Monthly emissions from each turbine/duct burner package will be summed together P g g and used in a twelve month rolling total to monitor compliance with the annual emission limitation for all packages combined. Each month a new twelve month rolling total shall be calculated using the previous twelve months' data. 1.6.2 For BACT purposes, VOC emissions from each turbine/duct burner package shall not exceed 3.63 lbs/hr (Colorado Construction Permit 91WE667). In the absence of credible evidence to the contrary, compliance with the VOC BACT limit is presumed provided that the turbines and duct burners are operated and maintained in accordance with manufacturer's recommendations and good engineering practices and that the natural gas used as fuel meets the requirement in Condition 1.9. 1.7 Natural Gas consumption for the turbines and duct burners shall not exceed the limitations stated above (Colorado Construction Permit 91 WE667). Natural gas consumed by the turbines will be monitored and recorded monthly using fuel meters and other records as necessary. Natural gas consumed by the duct burners shall be recorded monthly, as provided for in 40 CFR Part 60 Subpart Db § 60.49b(d)(2), as adopted by reference in Colorado Regulation No. 6, Part A. Monthly quantities of natural gas consumed by the turbines and duct burners shall be used in rolling twelve month totals to monitor compliance with the annual limitations. Each month a new twelve month rolling total shall be calculated using the previous twelve months' data. 1.8 Each exhaust stack shall be equipped with a continuous emission monitoring system to measure and record the following: 1.8.1 Concentration of Oxides of Nitrogen corrected to 15 % oxygen, hourly average, 4-hr rolling average (including periods of startup, shutdown, malfunction and combustion tuning and testing), daily average (excluding periods of startup and shutdown and combustion tuning and testing) and hourly average for periods of combustion tuning and testing; 1.8.2 Emission rate of Oxides of Nitrogen,pounds per hour, pounds per startup, pounds per shutdown, tons per month; 1.8.3 Concentration of Carbon Monoxide corrected to 15 % oxygen, hourly average, daily average (excluding periods of startup and shutdown and combustion tuning and testing) and hourly average for periods of combustion tuning and testing; • 1.8.4 Emission rate of Carbon Monoxide, pounds per hour, pounds per startup, pounds per shutdown,tons per month; 1.8.5 Gross Turbine Output, in MW; and Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership,L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 20 1.8.6 Operating mode — startup, shutdown, combustion tuning and testing and/or standard operation. The continuous emission monitoring systems shall meet the requirements in Condition 5 of this permit. Monthly emissions of NOx and CO from the continuous emission monitoring system shall be used as specified in Conditions 1.4.1 and 1.5.1 to monitor compliance with the annual NOx and CO limitations. 1.9 The permittee shall maintain records demonstrating that the natural gas burned has a total sulfur content less than 0.5 grains/100 SCF. Natural gas that meets this sulfur limitation is considered pipeline natural gas as defined in 40 CFR Part 72. The demonstration shall be made using any of the methods identified in 40 CFR Part 75 Appendix D, Section 2.3.1.4.(a). These records shall be made available to the Division upon request. 1.10 The Btu content of natural gas used to fuel the turbines and duct burners shall be determined. semi-annually using the appropriate ASTM Methods or equivalent, if approved by the Division in advance. Calculation of annual emissions outlined under Conditions 1.2.1, 13.1 and 1.6.1 shall be based on the most recent Btu analysis. The Btu content shall be based on the higher heating value (HHV) of the fuel. In lieu of semi-annual sampling and analysis, the Btu content of the gas may be determined based on the monthly average of the supplier's analyses, provided that the analyses were conducted using the appropriate ASTM Methods, or equivalent, if approved by the Division in advance. 1.11 Regulation No. 6,Part A, Subpart A, General Provisions apply as follows: 1.11.1 No article,machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to,the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gasses discharged to the atmosphere. (40 CFR Part 60 Subpart A § 60.12, as adopted by reference in Colorado Regulation No. 6,Part A). 1.11.2 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Division which may include, but is not limited to monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source (40 CFR Part 60 Subpart A § 60.11(d), as adopted by reference in Colorado Regulation No. 6,Part A). 1.12 The turbines and duct burners are subject to the following opacity requirements: 1.12.1 State-Only Requirement: No owner or operator may discharge, or cause the discharge into the atmosphere of any particulate matter which is greater than 20% Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 21 opacity (Colorado Regulation No. 6, Part B, Section II.C.3). This opacity standard applies to each stack. This opacity standard applies at all times except during periods of startup, shutdown and malfunction (40 CFR Part 60 Subpart A § 60.11(c), as adopted by reference in Colorado Regulation No. 6, Part B, Section I.A). Note that this opacity requirement is more stringent than the opacity requirement in Condition 1.12.3 during periods of building of a new fire, cleaning of fire boxes, soot blowing, process modifications and adjustment or occasional cleaning of control equipment. 1.12.2 Except as provided for in Condition 1.12.3 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). This opacity standard applies to each stack. 1.12.3 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment which is in excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). This opacity standard applies to each stack. In the absence of credible evidence to the contrary, each turbine/duct burner package shall be presumed to be in compliance with the above opacity requirements since only pipeline natural gas is permitted to be used as fuel. 1.13 Each turbine/duct burner package is subject to the Title IV Acid Rain Requirements. As specified in 40 CFR Part 72.72(b)(1)(viii), the acid rain permit requirements shall be a complete and segregable portion of the Operating Permit. As such the requirements are found in Section III of this permit. 1.14 This facility consists of five (5) combustion turbine/duct burner packages. Each package exhausts to a separate stack. Six (6) combustion turbines are permitted for use except that only five (5) combustion turbines may be operated together at any one time. The permittee shall maintain records of the turbine operating in each turbine/duct burner package such that a list of equipment currently at the facility and in operation is readily available at the site. (Colorado Construction Permit 91 WE667, as modified under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part B, Section II.A.6 and Part C, Section X to include the "sixth" turbine as a permanent spare as requested in an April 6, 2015 modification application) Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 22 2. S006-One(1)Diesel Fired Emergency Generator(8.57 MMBtu/hr(65 gal/hr)and 1,232 hp) Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number Hours of 2.1 NA NA NA Recordkeeping Monthly Operation SO2 2.2 Not to Exceed 0.8 lbs/mmBtu N/A Fuel Restriction Only Diesel Fuel is Used as Fuel MACT 777Z 2.3 Change Oil and Filter N/A See Condition 2.3. Requirements Inspect Air Cleaner Inspect all Hoses and Belts Opacity 2.4 Not to Exceed 20%Except as N/A EPA Method 9 See Provided for Below Condition 2.4 For Startup—Not to Exceed 30%, for a Period or Periods Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes Note that this emission unit is exempt from the APEN reporting requirements in Regulation No. 3, Part A and the minor source construction permit requirements provided actual,uncontrolled emissions do not exceed the APEN de minimis level(1 ton/yr of NOx) per Colorado Regulation No.3,Part A,Section II.D.I.a and Part B,Section II.D.l.a.Based on AP-42 Emission Factors(Section 3.4), and design rate(8.57 MMBtu/hr),emissions exceed the APEN de minimis level at 73 hrs/yr. 2.1 Hours of operation shall be monitored monthly and recorded in a log to be made available to the Division upon request. Monthly hours of operation shall be used in a rolling twelve month total for hours of operation. If hours of operation exceed 73 hours in a calendar year, the permittee shall determine if an APEN is required to be filed for this engine and if so shall file an APEN. If hours of operation exceed 250 in any annual period, the permittee shall determine if the construction permit exemption level in Colorado Regulation No. 3, Part B, Section II.D.1.c.(ii) has been exceeded and if so the permittee shall file an application to revise this permit within 30 days in order to include fuel consumption and emission limits for this engine. 2.2 Emissions of SO2 from the engine shall not exceed the limitation stated above (Colorado Regulation No. 1, Section VI.B.4.b.(i)). In the absence of credible evidence to the contrary, compliance with the SO2 emission limitation shall be presumed since only diesel fuel is permitted to be used as fuel in this engine. The permittee shall maintain records that verify that only diesel fuel is used as fuel in this engine. 2.3 This engine is subject to the requirements in 40 CFR Part 63 Subpart ZZZZ,"National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines." The specific applicable requirements are included in Section II, Condition 6 of this permit. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 23 2.4 Opacity of emissions from this engine shall not exceed the following 2.4.1 Except as provided for in Condition 2.4.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20%opacity(Colorado Regulation No. 1, Section II.A.1). 2.4.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from startup which is in excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes(Colorado Regulation No. 1, Section II.A.4). Compliance with these limitations shall be determined by conducting visual emission observations in accordance with EPA Reference Method 9 as follows: 2.4.3 As specified in Condition 6.8 engine startup shall not exceed 30 minutes. An engine startup period of less than 30 minutes shall not require an opacity observation to monitor compliance with the opacity limit in Condition 2.4.2. A record shall be kept of the date and time each engine was started and when it was shutdown. 2.4.4 An opacity observation shall be conducted annually (calendar year period) on this engine to monitor compliance with the opacity limit in Condition 2.4.1. Annual opacity observations shall be separated by a period of four(4)months. If the engine is operated more than 250 hours in any calendar year period, a second opacity observation shall be conducted for the engine. If two opacity readings are conducted in the annual (calendar year) period, such readings shall be conducted at least thirty days apart. 2.4.5 If the engine is not operated during the annual (calendar year)period, then no opacity observation is required. 2.4.6 Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the opacity limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. 2.4.7 All opacity observations shall be performed by an observer with current and valid Method 9 certification. Results of Method 9 readings and a copy of the certified Method 9 reader's certificate shall be kept on site and made available to the Division upon request. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership,L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 24 3. S007-One(1)Diesel Fired Emergency Fire Pump(2.28 MMBtu/hr(17.3 gal/yr)and 310 hp) Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number Hours of 3.1 N/A NA N/A Recordkeeping Monthly Operation SO2 3.2 Not to Exceed 0.8 lbs/mmBtu NA Fuel Restriction Only Diesel Fuel is Used as Fuel MACT ZZZZ 3.3 Change Oil and Filter N/A See Condition 3.3. Requirements Inspect Air Cleaner Inspect all Hoses and Belts Opacity 3.4 Not to Exceed 20%Except as N/A EPA Method 9 See Provided for Below Condition 3.4 For Startup—Not to Exceed 30%, for a Period or Periods Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes Note that this emission unit is exempt from the APEN reporting requirements in Regulation No. 3, Part A and the minor source construction permit requirements provided actual,uncontrolled emissions do not exceed the APEN de minimis level(1 ton/yr of NOx) per Colorado Regulation No.3,Part A,Section II.D.1.a and Part B,Section II.D.1.a.Based on AP-42 Emission Factors(Section 3.3), and design rate(2.28 MMBtu/hr),emissions exceed the APEN de minimis level at 199 hrs/yr. 3.1 Hours of operation shall be monitored monthly and recorded in a log to be made available to the Division upon request. Monthly hours of operation shall be used in a rolling twelve month total for hours of operation. If hours of operation exceed 199 hours in a calendar year, the permittee shall determine if an APEN is required to be filed for this engine and if so shall file an APEN. If hours of operation exceed 994 in any annual period, the permittee shall determine if the construction permit de minimis level in Colorado Regulation No. 3, Part B, Section II.D.1.c.(iii) has been exceeded and if so the permittee shall file an application to revise this permit within 30 days in order to include fuel consumption and emission limits for this engine. 3.2 Emissions of SO2 from the engine shall not exceed the limitation stated above (Colorado Regulation No. 1, Section VI.B.4.b.(i)). In the absence of credible evidence to the contrary, compliance with the SO2 emission limitation shall be presumed since only diesel fuel is permitted to be used as fuel in this engine. The permittee shall maintain records that verify that only diesel fuel is used as fuel in this engine. 3.3 This engine is subject to the requirements in 40 CFR Part 63 Subpart ZZZZ,"National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines." The specific applicable requirements are included in Section II, Condition 6 of this permit. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 25 3.4 Opacity of emissions from this engine shall not exceed the following 3.4.1 Except as provided for in Condition 3.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20%opacity(Colorado Regulation No. 1, Section II.A.1). 3.4.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from startup which is in excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). Compliance with these limitations shall be determined by conducting visual emission observations in accordance with EPA Reference Method 9 as follows: 3.4.3 As specified in Condition 6.8 engine startup shall not exceed 30 minutes. An engine startup period of less than 30 minutes shall not require an opacity observation to monitor compliance with the opacity limit in Condition 3.4.2. A record shall be kept of the date and time each engine was started and when it was shutdown. 3.4.4 An opacity observation shall be conducted annually (calendar year period) on this engine to monitor compliance with the opacity limit in Condition 3.4.1. Annual opacity observations shall be separated by a period of four(4)months. If the engine is operated more than 250 hours in any calendar year period, a second opacity observation shall be conducted for the engine. If two opacity readings are conducted in the annual (calendar year) period, such readings shall be conducted at least thirty days apart. 3.4.5 If the engine is not operated during the annual (calendar year) period, then no opacity observation is required. 3.4.6 Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the opacity limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. 3.4.7 All opacity observations shall be performed by an observer with current and valid Method 9 certification. Results of Method 9 readings and a copy of the certified Method 9 reader's certificate shall be kept on site and made available to the Division upon request. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 26 4. S011 -One(1)Forced Draft Water Cooling Tower w/Drift Eliminators Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number PM 4.1 N/A 9.5 tons/yr See Condition 4.1 Recordkeeping Monthly PMto N/A 9.5 tons/yr and Calculations Water 4.2 N/A 46,680 N/A Pump Run Time Monthly Circulation MMgal/yr Total Dissolved 4.3 N/A NA N/A Laboratory Monthly Solids Analysis Analysis Opacity 4.4 Not to Exceed 20% N/A See Condition 4.4 4.1 PM and PMIo emissions the cooling tower shall not exceed the limitations stated above (Colorado Construction Permit 96WE075, as modified under the provisions of Section I, Condition 1.3 to remove short-term (lbs/hr) emission limits). Monthly emissions shall be calculated by the end of the subsequent month using the following equation: PM=PMIo(Tons/mo)=O x d x%drift x 31.3%drift dispersed x Total Solids Concentration 2000 lbs/ton Where: Q=water circulated,gal/yr-to be determined by Condition 4.2 d=density of water,lbs/gal(from APCD preliminary analysis for const.permit d=8.34 lbs/gal) %drift=0.003%(from APCD preliminary analysis for const.permit) 31.3% drift dispersed (from EPA-600/7-79-251a, November 1979, "Effects of Pathogenic and Toxic Materials Transported Via Cooling Device Drift—Volume 1 -Technical Report",Page 63) Total Solids Concentration=total solids concentration, in ppm (lbs solids/106 lbs water) -to be determined by Condition 4.3. Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 4.2 Circulation of water shall not exceed the limitations above (Colorado Construction Permit 96WE075 as modified under the provisions of Section I, Condition 1.3 to remove short-term (gal/hr)throughput limits). Water circulation shall be determined each month by multiplying the hours of operation of each pump by the design flow rate of each pump as follows: Water Circulation Rate=hours of operation(hrs/yr)x Design Flow Rate(Gal/min)x 60 min/hr Monthly quantities of water circulated shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month rolling total shall be calculated using the previous twelve months data. 4.3 Samples of water circulated through the tower shall be taken and analyzed monthly to determine the total solids concentration (Colorado Construction Permit 96WE075). Calculation of Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 27 emissions outlined under Condition 4.1 shall be based on the most recent total solids concentration analysis. A copy of the procedures used to obtain and analyze samples shall be maintained and made available to the Division upon request. 4.4 Opacity of emissions from the cooling tower shall not exceed 20% (Colorado Regulation No. 1, Section II.A.1). In the absence of credible evidence to the contrary, compliance with the opacity standard shall be presumed, provided the cooling tower and drift eliminators on the tower are operated and maintained in accordance with the manufacturers' recommendations, if any, and good engineering practices. A copy of operating and maintenance procedures, schedules for maintenance and/or inspection activities and records related to maintenance of the drift eliminators and/or cooling tower and good engineering practices such as records of inspection, repair or replacement shall be made available to the Division upon request. 5. Continuous Emission Monitoring Requirements The following requirements apply to the NOx, CO and diluent (either O2 or CO2) continuous emission monitoring systems (CEMS) required by Condition 1.8. Note that the continuous emission monitoring requirements identified in this Condition are in addition to the continuous emission monitoring requirements required by the Acid Rain Program, which are identified in Section III of this permit. 5.1 Equipment and QA/QC Requirements 5.1.1 The continuous emission monitoring systems are subject to the following requirements: 5.1.1.1 Except as provided for below, the CO monitors are subject to the applicable requirements of 40 CFR Part 60 (Colorado Construction Permit 91WE667). The monitoring systems shall meet the equipment, installation and performance specifications of 40 CFR Part 60 Appendix B, Performance Specification 4/4A. These CEMS are subject to the quality assurance/quality control requirements in 40 CFR Part 60 Appendix F and Subpart A § 60.13 and Condition 5.1.1.3 of this permit. a. The CO CEMS data shall meet the applicable "primary equipment hourly operating requirements" for hourly average calculation methodology specified in 40 CFR Subpart B § 75.10(d)(1). b. Annual CO monitor relative accuracy (RA) testing will be performed in ppm @ 15% O2 (ppmvdc) measurement units, and will be performed according to 40 CFR Part 60, Appendix B, Performance Specification 4/4A. c. Relative accuracy test audit (RATA) frequency will be determined according to 40 CFR Part 60, Appendix B, Performance Specification 4/4A. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit#950PWE096 Page 28 d. For CO CEMS concentration conversions, a 19.0 percent O2 diluent cap will be used when the measured O2 concentration is greater than 19.0 percent. 5.1.1.2 The NOx (and diluents) monitors are subject to the applicable requirements of 40 CFR Part 75. The monitoring systems shall meet the equipment, installation and performance specification requirements in 40 CFR Part 75, Appendix A. These CEMS shall meet the quality assurance/quality control requirements in 40 CFR Part 75, Appendix B and the conversion procedures of Appendix F and Condition 5.1.1.3 of this permit. a. Annual NOx monitor RA testing will be performed in ppm @ 15% O2 (ppmvdc) measurement units, and will be performed according to 40 CFR Part 60,Appendix B, Specification 2. b. RATA testing frequency will be determined according to 40 CFR Part 75,Appendix B. 5.1.1.3 The NOx and CO CEMS are subject to the following requirements: a. Relative Accuracy Test Audits(RATAs): The RATAs for emission units that have short term concentration emission limitations will be conducted in measurement units that are applicable to the emission unit (e.g., lb/MMBtu, ppmvdc). The RATAs for emissions units that have mass emission limitations (e.g. lb/event) will be conducted in terms of pounds per hour(lb/hr). b. The DAHS shall be able to record and manipulate the data in the units (e.g., lb/MMBtu, ppmvdc) of the emission limitation and meet the reporting requirements for all for the emissions limitations that are applicable to the emissions unit. 5.1.2 Quality assurance/quality control plans shall be prepared for the continuous emission monitoring systems as follows: 5.1.2.1 The quality assurance/quality control plan for the CO monitors shall be prepared in accordance with the applicable requirements in 40 CFR Part 60,Appendix F. 5.1.2.2 The quality assurance/quality control plan for the NOx (and diluent) monitors shall be prepared in accordance with the applicable requirements in 40 CFR Part 75,Appendix B. The quality assurance/quality control plans shall be made available to the Division upon request. Revisions necessary to comply with applicable requirements shall be made to the plans at the request of the Division. 5.2 General Provisions Operating Permit Number: 950PWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 29 5.2.1 CO monitors: Except for system breakdowns, repairs, calibration checks, and zero and span adjustments required under § 60.13(d), all continuous monitoring systems shall be in continuous operation and shall meet minimum frequency of operation requirements as set forth in § 60.13(e)(2). (40 CFR Part 60 Subpart A § 60.13(e), as adopted by reference in Colorado Regulation No. 6, Part A) 5.2.2 NOx (and diluents) monitors: The permittee shall ensure that all continuous emission monitoring systems required are in operation and monitoring unit emissions at all times that the affected units combusts any fuel except as provided for in 40 CFR § 75.11(e) and during periods of calibration, quality assurance, or preventative maintenance performed pursuant to 40 CFR Part 75 § 75.21 and Appendix B, periods of repair, periods of backups of data from the data acquisition and handling system or recertification performed pursuant to 40 CFR § 75.20 (40 CFR part 75 § 75.10(d)). 5.2.3 Other than "Like Kind" monitor replacement, alternative monitoring systems, alternative reference methods, or any other alternatives for the required continuous emission monitoring systems shall not be used without having obtained prior written approval from the appropriate agency, either the Division or the U. S. EPA, depending on which agency is authorized to approve such alternative under applicable law. Any alternative continuous emission monitoring systems must be certified in accordance with the requirements of 40 CFR Part 60 or 40 CFR Part 75 prior to use. 5.2.4 All test and monitoring equipment, methods, procedures and reporting shall be subject to the review and approval by the appropriate agency, either the Division or the U. S. EPA, depending on which agency is authorized to approve such item under applicable law, prior to any official use. The Division shall have the right to inspect such equipment, methods and procedures and data obtained at any time. The Division may provide a witness(s) for any and all tests as Division resources permit. 5.2.5 A file suitable for inspection shall be maintained of all measurements, including continuous monitoring system, monitoring device, and performance testing measurements; all continuous monitoring system performance evaluations; all continuous monitoring system or monitoring device calibration checks; adjustments and maintenance performed on these systems or devices; and all other information required by applicable portions of 40 CFR Part 60 Subpart A and Appendices B and F. 5.2.6 Records shall be maintained of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the source; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative (40 CFR Part 60 Subpart A § 60.7(b), as adopted by reference in Colorado Regulation No. 6,Part A). 5.3 Specific Provisions for NSPS Subpart GG Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership,L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 30 5.3.1 If the owner or operator has installed a NOx CEMS to meet the requirements of part 75 of this chapter, and is continuing to meet the ongoing requirements of part 75 of this chapter,the CEMS may be used to meet the requirements of this section(40 CFR Part 60 Subpart GG), except that the missing data substitution methodology provided for at 40 CFR part 75, subpart D, is not required for purposes of identifying excess emissions. Instead, periods of missing CEMS data are to be reported as monitor downtime in the excess emissions and monitoring performance report required in Condition 5.4(40 CFR Part 60 Subpart GG§ 60.334(b)(3)(iii)). 5.3.2 Use of the ISO correction equation is optional for units used in association with heat recovery steam generators equipped with duct burners (40 CFR Part 60 Subpart GG § 60.335(b)(1)). The permittee has elected to not correct emissions to ISO standard ambient conditions. 5.4 Recordkeeping and Reporting Requirements 5.4.1 Each owner or operator required to install a continuous monitoring device shall submit excess emissions and monitoring systems performance report (excess emissions are defined in applicable subparts) and/or summary report form (see Condition 5.4.2)to the Division quarterly.All reports shall be postmarked by the 30th day following the end of each calendar quarter. (§ 60.7(c), revised to stipulate quarterly reporting. The source requested quarterly reporting. This is consistent with the Acid Rain reporting requirements.) Written reports of excess emissions shall include the following information: 5.4.1.1 The magnitude of excess emissions computed in accordance with 40 CFR Part 60 Subpart A § 60.13(h) and Division guidelines, as applicable, any conversion factor(s) used, and the date and time of commencement and completion of each time period of excess emissions and the process operating time during the reporting period. (§ 60.7(c)(1)) 5.4.1.2 Specific identification of each period of excess emissions that occurs during startups, shutdowns, and malfunctions of the affected facility. The nature and cause of any malfunction (if known), the corrective action taken or preventative measures adopted. (§ 60.7(c)(2)). 5.4.1.3 The date and time identifying each period during which the continuous monitoring system was inoperative except for zero and span checks and the nature of the system repairs or adjustments(§ 60.7(c)(3)). 5.4.1.4 When no excess emissions have occurred or the continuous monitoring system(s) have not been inoperative, repaired, or adjusted, such information shall be stated in the report(§ 60.7(c)(4)). 5.4.2 The summary report form shall contain the information and be in the format shown in figure 1 of § 60.7 unless otherwise specified by the Division. One summary report form shall be submitted for each pollutant monitored at each affected facility. (§ 60.7(d)) Operating Permit Number: 95OPWE096 • First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 31 If the total duration of excess emissions for the reporting period is less than 1 percent of the total operating time for the reporting period and CMS downtime for the reporting period is less than 5 percent of the total operating time for the reporting period, only the summary report form shall be submitted and the excess emission report described in Condition 5.4.1 need not be submitted unless requested by the Division. (§ 60.7(d)(1)). If the total duration of excess emissions for the reporting period is 1 percent or greater of the total operating time for the reporting period or the total CMS downtime for the reporting period is 5 percent or greater of the total operating time for the reporting period, the summary report form and the excess emission report described in Condition 5.4.1 shall both be submitted. (§ 60.7(d)(2)) 5.5 Data Replacement Requirements For periods when quality assured data is not available from the continuous emission monitoring systems the following data replacement procedures shall be used for determining the total (annual) emissions: 5.5.1 For NOx,the procedures in 40 CFR Part 75 Subpart D shall be used. 5.5.2 For CO, the procedures in 40 CFR Part 75 Subpart D for SO2 shall be used (Colorado Construction Permit 91WE667, as modified under the provisions of Section I, Condition 1.3 to rely on Part 75 data replacement provisions). For purposes of monitoring compliance with the annual emission limitations (tons/yr) replaced and bias-adjusted data shall be included when assessing compliance with the annual limitations. Note that since CO emissions are not subject to requirements in 40 CFR Part 75 the CO emission data is not required to be bias-adjusted. 6. National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (40 CFR Part 63 Subpart ZZZZ) The diesel-fired emergency generator and fire pump engines are subject to the requirements in 40 CFR Part 63 Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", as follows: The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart ZZZZ published in the Federal Register on January 30, 2013 (including the corrections published March 6, 2013). However, if revisions to this Subpart are promulgated at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63 Subpart ZZZZ. It should be noted that additional revisions to the requirements in 40 CFR Part 63 Subpart ZZZZ are expected to be made in response to issues related to legal action associated with the allowable hours of operation provisions for emergency engines regarding engines used for demand response. If such Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 32 revisions are fmalized prior to issuance of the permit,they will be included in the permit. [check on this before permit issuance] As of the date of this permit issuance [DATE], the requirements in 40 CFR Part 63 Subpart ZZZZ promulgated after July 1, 2007 have not been adopted into Colorado Regulation No. 8, Part E and are therefore not state-enforceable. In the event that these requirements are adopted into Colorado Regulations,they will become state-enforceable. When do I have to comply with this subpart((60.6595) 6.1 If you have an existing stationary CI RICE located at an area source of HAP emissions,you must comply with the applicable emission limitations and operating limitations no later than May 3, 2013. (§ 63.6595(a)(1)) What emission limitations, operating limitations, and other requirements must I meet if I own or operate an existing CI RICE located at an area source of HAP emissions ((63.6603) 6.2 If you own or operate an existing stationary CI RICE located at an area source of HAP emissions, you must comply with the requirements in Table 2d to this subpart and the operating limitations in Table 2b to this subpart which apply to you. (§ 63.6603(a)) The requirements in Table 2d that apply to these emergency CI RICE are as follows: 6.2.1 Change oil and filter every 500 hours of operation or annually whichever comes first. (Table 2d, item 4.a) 6.2.2 Inspect air cleaner every 1,000 hours of operation or annually whichever comes first, and replace as necessary. (Table 2d, item 4.b) 6.2.3 Inspect all hoses and belts every 500 hours of operation or annually whichever comes first, and replace as necessary. (Table 2d, item 4.c) Notwithstanding the above requirements,the following applies: 6.2.4 Sources have the option to utilize an oil analysis program as described in Condition 6.9 in order to extend the specified oil change requirement in Condition 6.2.1. (Table 2d, footnote 1) 6.2.5 If an emergency engine is operating during an emergency and it is not possible to shut down the engine in order to perform the management practice requirements on the schedule required in Conditions 6.2.1 through 6.2.3, or if performing the,management practice on the required schedule would otherwise pose an unacceptable risk under Federal, State, or local law, the management practice can be delayed until'the emergency is over or the unacceptable risk under Federal, State, or local law has abated. The management practice should be performed as soon as practicable after the emergency has ended or the unacceptable risk under Federal, State, or local law has abated. Sources must report any failure to perform the management practice on the Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 33 schedule required and the Federal, State or local law under which the risk was deemed unacceptable. (Table 2d, footnote 2) What fuel requirements must I meet if I own or operate a stationary CI RICE? ((63.6604) 6.3 Beginning January 1, 2015, if you own or operate an existing emergency CI stationary RICE with a site rating of more than 100 brake HP and a displacement of less than 30 liters per cylinder that uses diesel fuel and operates or is contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in Conditions 6.11.2.2 and 6.11.2.3 or that operates for the purpose specified in §63.6640(f)(4)(ii), you must use diesel fuel that meets the requirements in 40 CFR 80.510(b) for nonroad diesel fuel, except that any existing diesel fuel purchased (or otherwise obtained) prior to January 1, 2015, may be used until depleted. (63.6604(b)) What are my general requirements for complying with this subpart? ((63.6605) 6.4 You must be in compliance with the emission limitations, operating limitations, and other requirements in this subpart that apply to you at all times. (§ 63.6605(a)) 6.5 At all times you must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. (§ 63.6605(b)) What are my monitoring, installation, collection, operation, and maintenance requirements? ((63.6625) 6.6 If you own or operate an existing emergency or black start stationary RICE located at an area source of HAP emissions, you must operate and maintain the stationary RICE and after- treatment control device (if any) according to the manufacturer's emission-related written instructions or develop your own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions (§ 63.6625(e)and (e)(3)) 6.7 If you own or operate an existing emergency stationary RICE with a site rating of less than or equal to 500 brake HP located at a major source of HAP emissions or an existing emergency stationary RICE located at an area source of HAP emissions, you must install a non-resettable hour meter if one is not already installed. (§ 63.6625(f)) 6.8 If you operate a new, reconstructed, or existing stationary engine, you must minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership,L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 34 the emission standards applicable to all times other than startup in Tables la, 2a, 2c, and 2d to this subpart apply. (§ 63.6625(h)) 6.9 If you own or operate a CI engine that is subject to the work, operation or management practices in Condition 6.2, you have the option of utilizing an oil analysis program in order to extend the specified oil change requirement in Condition 6.2.1. The oil analysis must be performed at the same frequency specified for changing the oil in Condition 6.2.1. The analysis program must at a minimum analyze the following three parameters: Total Base Number, viscosity, and percent water content. The condemning limits for these parameters are as follows: Total Base Number is less than 30 percent of the Total Base Number of the oil when new; viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or percent water content (by volume) is greater than 0.5. If all of these condemning limits are not exceeded, the engine owner or operator is not required to change the oil. If any of the limits are exceeded, the engine owner or operator must change the oil within 2 business days of receiving the results of the analysis; if the engine is not in operation when the results of the analysis are received, the engine owner or operator must change the oil within 2 business days or before commencing operation,whichever is later.The owner or operator must keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes for the engine. The analysis program must be part of the maintenance plan for the engine. (§ 63.6625(i)) How do I demonstrate continuous compliance with the emission limitations, operating limitations and other requirements? ('63.6640) 6.10 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 6.2] 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: 6.10.1 Operating and maintaining the stationary RICE according to the manufacturer's emission-related operation and maintenance instructions(Table 6, Item 9.a.i); or 6.10.2 Develop and follow your own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. (Table 6, Item 9.a.ii) 6.11 If you own or operate an emergency stationary RICE,you must operate the emergency stationary RICE according to the requirements in Conditions 6.11.1 through 6.11.3. In order for the engine to be considered an emergency stationary RICE under this subpart, any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 hours per year, as described in Conditions 6.11.1 through 6.11.3, is prohibited. If you do not operate the engine according to the requirements in Conditions 6.11.1 through 6.11.3, the engine will not be considered an emergency engine under this subpart and must meet all requirements for non-emergency engines. (§ 63.6640(f)) Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 35 6.11.1 There is no time limit on the use of emergency stationary RICE in emergency situations. (§ 63.6640(O(1)) 6.11.2 You may operate your emergency stationary RICE for any combination of the purposes specified below for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by Condition 6.11.3 counts as part of the 100 hours per calendar year allowed by this Condition 6.11.2. (§ 63.6640(O(2)) 6.11.2.1 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(O(2)(i)) 6.11.2.2 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(O(2)(ii)) 6.11.2.3 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(O(2)(iii)) 6.11.3 Emergency stationary RICE located at area sources of HAP may be operated for up to 50 hours per calendar year in non-emergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in Condition 6.11.2. Except as provided in paragraphs (O(4)(i) and (ii) of this section, the 50 hours per year for non-emergency situations cannot be used for peak shaving or non- emergency demand response, or to generate income for a facility to an electric grid or otherwise supply power as part of a financial arrangement with another entity. (§ 63.6640(O(4)) What reports must I submit and when? ('63.6650) 6.12 If you own or operate an emergency stationary RICE with a site rating of more than 100 brake HP that operates or is contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in Conditions 6.11.2.2 and 6.11.2.3 or that operates for the Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership,L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 36 purpose specified in §63.6640(f)(4)(ii), you must submit an annual report according to the requirements in paragraphs(h)(1)through(3)of this section. (§ 63.6650(h)) What records must I keep? ('63.6655) 6.13 You must keep records of the maintenance conducted on the stationary RICE in order to demonstrate that you operated and maintained the stationary RICE and after-treatment control device (if any) according to your own maintenance plan if you own or operate an existing stationary emergency RICE. (§ 63.6655(e)and(e)(2)) (§ 63.6655(e)and(e)(2)) 6.14 If you own or operate an existing,emergency stationary RICE located at an area source of HAP emissions that does not meet the standards applicable to non-emergency engines., you must keep records of the hours of operation of the engine that is recorded through the non-resettable hour meter. The owner or operator must document how many hours are spent for emergency operation, including what classified the operation as emergency and how many hours are spent for non-emergency operation. If the engine is used for the purposes specified in Conditions 6.11.2.2 and 6.11.2.3 or §63.6640(f)(4)(ii), the owner or operator must keep records of the notification of the emergency situation, and the date, start time, and end time of engine operation for these purposes. (§ 63.6655(f)and(f)(2)) In what form and how long must I keep my records? ('63.6660) 6.15 Records shall be kept in the form and for the duration specified in § 63.6660. What parts of the General Provisions apply to me? ((63.6665) 6.16 Table 8 of Subpart ZZZZ shows which parts of the General Provisions in §§63.1 through 63.15 apply to you. (§ 63.6665) The general provisions that apply to these engines include,but are not limited to the following: • 6.16.1 Prohibited activities in § 63.4(a). 6.16.2 Circumvention in § 63.4(b) Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 37 7. Cold Cleaner Solvent Vat Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number Work Practice 7.1 N/A N/A N/A Certification Annually Standards Transfer and 7.2 N/A N/A N/A Certification Annually Storage of Waste/Used Solvents Note that this emission unit is exempt from the APEN reporting requirements in Regulation No. 3,Part A and the construction permit requirements in Regulation No. 3, Part B, as long as actual, uncontrolled emissions do not exceed the APEN de minimis level (see Regulation No.3,Part B,Section II.D.1.a). 7.1 The design and operation of the cold cleaner solvent degreaser shall meet the standards defined in Colorado Regulation 7, Section X.B. The permittee's operating procedures for solvent cleaning shall include these requirements. 7.2 The transfer and storage of waste and used solvents from the cold cleaner solvent vats are subject to the following requirements (Colorado Regulation No. 7, Section X.A.3 and 4): 7.2.1 In any disposal or transfer of waste or used solvent, at least 80 percent by weight of the solvent/waste liquid shall be retained (i.e., no more than 20 percent of the liquid solvent/solute mixture shall evaporate or otherwise be lost during transfers). 7.2.2 Waste or used solvent shall be stored in closed containers unless otherwise required by law. The permittee's operating procedures for the solvent vats and contracts and/or agreements with contractors to service these vats shall include these requirements. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership,L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 38 SECTION III- Acid Rain Requirements 1. Designated Representative and Alternate Designated Representative Designated Representative Alternate Designated Representative Name: Barbara A. Walz Name: Barry Ingold Title: Senior Vice President,Policy Title: Senior Vice President and Compliance/Chief Generation Compliance Officer Phone: (303)452-6111 Phone: (303)254-3133 2. Sulfur Dioxide Emission Allowances and Nitrogen Oxide Emission Limitations UnitS001 2016 2017 2018 2019 2020 SO2 Allowances, 0* 0* 0* 0* 0* per 40 Cr'R Part 73.10(b),Table 2 NOX Limits This Unit Has No NOx Limits(see Section 5) * Under the provisions of§ 72.84(a) any allowance allocations to, transfers to and deductions from an affected unit's Allowance Tracking System account is considered an automatic permit amendment and as such no revision to the permit is necessary.Numerical allowances shown in this table are from the 1996 edition of the CFR. Unit S002 I 2016 2017 2018 2019 2020 SO2 Allowances, 0* 0* 0* 0* per 40 CFR Part 73.10(b),Table 2 NOX Limits This Unit Has No NOX Limits(see Section 5) * Under the provisions of§ 72.84(a) any allowance allocations to, transfers to and deductions from an affected unit's Allowance Tracking System account is considered an automatic permit amendment and as such no revision to the permit is necessary.Numerical allowances shown in this table are from the 1996 edition of the CFR. Unit S003 2016 2017 2018 f 2019 2020 SO2 Allowances, 0* 0* 0* 0* 0* per 40 CFR Part 73.10(b),Table 2 NOX Limits This Unit Has No NOX Limits(see Section 5) * Under the provisions of§ 72.84(a) any allowance allocations to, transfers to and deductions from an affected unit's Allowance Tracking System account is considered an automatic permit amendment and as such no revision to the permit is necessary.Numerical allowances shown in this table are from the 1996 edition of the CFR. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 39 Unit S004 I 2016 I 2017 I 2018 I 2019 I 2020 SO2 Allowances, 0* 0* 0* 0* 0* per 40 CFR Part 73.10(b),Table 2 NOx Limits This Unit Has No NOx Limits(see Section 5) * Under the provisions of§ 72.84(a) any allowance allocations to, transfers to and deductions from an affected unit's Allowance Tracking System account is considered an automatic permit amendment and as such no revision to the permit is necessary.Numerical allowances shown in this table are from the 1996 edition of the CFR. Unit S005 I 2016 I 2017 I 2018 I 2019 2020 SO2 Allowances, 0* 0* 0* 0* 0* per 40 CFR Part 73.10(b),Table 2 NOx Limits This Unit Has No NOx Limits(see Section 5) * Under the provisions of§ 72.84(a) any allowance allocations to, transfers to and deductions from an affected unit's Allowance Tracking System account is considered an automatic permit amendment and as such no revision to the permit is necessary.Numerical allowances shown in this table are from the 1996 edition of the CFR. 3. Standard Requirements Units S001 through S005 of this facility are subject to and the source has certified that they will comply with the following standard,conditions (from Acid Rain Permit Application, EPA Form 7610-16 (Revised 7-2014), with some clarifying language added (e.g. "permitting authority" replaced with "Division" and"Act"replaced with"Federal Clean Air Act") Permit Requirements. (1) The designated representative of each affected source and each affected unit at the source shall: (i) Submit a complete Acid Rain permit application (including a compliance plan) under 40 CFR part 72 in accordance with the deadlines specified in 40 CFR 72.30; and (ii) Submit in a timely manner any supplemental information that the Colorado Air Pollution Control Division determines is necessary in order to review an Acid Rain permit application and issue or deny an Acid Rain permit; (2) The owners and operators of each affected source and each affected unit at the source shall: (i) Operate the unit in compliance with a complete Acid Rain permit application or a superseding Acid Rain permit issued by the Division; and (ii) Have an Acid Rain Permit. Monitoring Requirements. (1) The owners and operators and, to the extent applicable, designated representative of each affected source and each affected unit at the source shall comply with the monitoring requirements as provided in 40 CFR part 75. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership,L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 40 (2) The emissions measurements recorded and reported in accordance with 40 CFR part 75 shall be used to determine compliance by the source or unit, as appropriate,with the Acid Rain emissions limitations and emissions reduction requirements for sulfur dioxide and nitrogen oxides under the Acid Rain Program. (3) The requirements of 40 CFR part 75 shall not affect the responsibility of the owners and operators to monitor emissions of other pollutants or other emissions characteristics at the unit under other applicable requirements of the Federal Clean Air Act and other provisions of the operating permit for the source. Sulfur Dioxide Requirements. (1) The owners and operators of each source and each affected unit at the source shall: (i) Hold allowances, as of the allowance transfer deadline, in the source's compliance account(after deductions under 40 CFR 73.34(c))not less than the total annual emissions of sulfur dioxide for the previous calendar year from the affected units at the source; and (ii) Comply with the applicable Acid Rain emissions limitations for sulfur dioxide. (2) Each ton of sulfur dioxide emitted in excess of the Acid Rain emissions limitations for sulfur dioxide shall constitute a separate violation of the Federal Clean Air Act. (3) An affected unit shall be subject to the requirements under paragraph (1) of the sulfur dioxide requirements as follows: (i) Starting January 1,2000, an affected unit under 40 CFR 72.6(a)(2); or (ii) Starting on the later of January 1, 2000 or the deadline for monitor certification under 40 CFR part 75, an affected unit under 40 CFR 72.6(a)(3). (4) Allowances shall be held in, deducted from, or transferred among Allowance Tracking System accounts in accordance with the Acid Rain Program. (5) An allowance shall not be deducted in order to comply with the requirements under paragraph (1) of the sulfur dioxide requirements prior to the calendar year for which the allowance was allocated. (6) An allowance allocated by the Administrator under the Acid Rain Program is a limited authorization to emit sulfur dioxide in accordance with the Acid Rain Program. No provision of the Acid Rain Program,the Acid Rain permit application, the Acid Rain permit,or an exemption under 40 CFR 72.7 or 72.8 and no provision of law shall be construed to limit the authority of the United States to terminate or limit such authorization. (7) An allowance allocated by the Administrator under the Acid Rain Program does not constitute a property right. Nitrogen Oxides Requirements. The owners and operators of the source and each affected unit at the source shall comply with the applicable Acid Rain emissions limitation for nitrogen oxides. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 41 Excess Emissions Requirements. (1) The designated representative of an affected source that has excess emissions in any calendar year shall submit a proposed offset plan to the Administrator of the U. S. EPA, as required under 40 CFR part 77. (2) The owners and operators of an affected source that has excess emissions in any calendar year shall: (i) Pay without demand, to the Administrator of the U. S. EPA,the penalty required, and pay upon demand the interest on that penalty, as required by 40 CFR part 77; and (ii) Comply with the terms of an approved offset plan, as required by 40 CFR part 77. Recordkeeping and Reporting Requirements. (1) Unless otherwise provided, the owners and operators of the source and each affected unit at the source shall keep on site at the source each of the following documents for a period of 5 years from the date the document is created. This period may be extended for cause, at any time prior to the end of 5 years, in writing by the Administrator or the Division: (i) The certificate of representation for the designated representative for the source and each affected unit at the source and all documents that demonstrate the truth of the statements in the certificate of representation, in accordance with 40 CFR 72.24; provided that the certificate and documents shall be retained on site at the source beyond such 5-year period until such documents are superseded because of the submission of a new certificate of representation changing the designated representative; (ii) All emissions monitoring information, in accordance with 40 CFR part 75; provided that to the extent that 40 CFR part 75 provides for a 3-year period for recordkeeping, the 3- year period shall apply. (iii) Copies of all reports, compliance certifications, and other submissions and all records made or required under the Acid Rain Program; and, (iv) Copies of all documents used to complete an Acid Rain permit application and any other submission under the Acid Rain Program or to demonstrate compliance with the requirements of the Acid Rain Program. (2) The designated representative of an affected source and each affected unit at the source shall submit the reports and compliance certifications required under the Acid Rain Program, including those under 40 CFR part 72 subpart I and 40 CFR part 75. Liability. (1) Any person who knowingly violates any requirement or prohibition of the Acid Rain Program, a complete Acid Rain permit application, an Acid Rain permit, or an exemption under 40 CFR 72.7 or 72.8, including any requirement for the payment of any penalty owed to the United States, shall be subject to enforcement pursuant to section 113(c) of the Federal Clean Air Act. (2) Any person who knowingly makes a false, material statement in any record, submission, or report under the Acid Rain Program shall be subject to criminal enforcement pursuant to section 113(c) of the Federal Clean Air Act and 18 U.S.C. 1001. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 42 (3) No permit revision shall excuse any violation of the requirements of the Acid Rain Program that occurs prior to the date that the revision takes effect. (4) Each affected source and each affected unit shall meet the requirements of the Acid Rain Program. (5) Any provision of the Acid Rain Program that applies to an affected source (including a provision applicable to the designated representative of an affected source) shall also apply to the owners and operators of such source and of the affected units at the source. (6) Any provision of the Acid Rain Program that applies to an affected unit (including a provision applicable to the designated representative of an affected unit) shall also apply to the owners and operators of such unit. (7) Each violation of a provision of 40 CFR parts 72, 73,74, 75, 76, 77, and 78 by an affected source or affected unit, or by an owner or operator or designated representative of such source or unit, shall be a separate violation of the Federal Clean Air Act. Effect on Other Authorities. No provision of the Acid Rain Program, an Acid Rain permit application, an Acid Rain permit, or an exemption under 40 CFR 72.7 or 72.8 shall be construed as: (1) Except as expressly provided in title IV of the Federal Clean Air Act,exempting or excluding the owners and operators and, to the extent applicable, the designated representative of an affected source or affected unit from compliance with any other provision of the Federal Clean Air Act, including the provisions of title I of the Federal Clean Air Act relating to applicable National Ambient Air Quality Standards or State Implementation Plans; (2) Limiting the number of allowances a unit can hold;provided,that the number of allowances held by the unit shall not affect the source's obligation to comply with any other provisions of the Federal Clean Air Act; (3) Requiring a change of any kind in any State law regulating electric utility rates and charges, affecting any State law regarding such State regulation, or limiting such State regulation, including any prudence review requirements under such State law; (4) Modifying the Federal Power Act or affecting the authority of the Federal Energy Regulatory Commission under the Federal Power Act; or, (5) Interfering with or impairing any program for competitive bidding for power supply in a State in which such program is established. 4. Reporting Requirements Reports shall be submitted to the addresses identified in Appendix D. Pursuant to 40 CFR Part 75.64 quarterly reports and compliance certification requirements shall be submitted to the Administrator within 30 days after the end of the calendar quarter. The contents of these reports shall meet the requirements of 40 CFR 75.64. • Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 43 Pursuant to 40 CFR Part 75.65 excess emissions of opacity shall be reported to the Division. These reports shall be submitted in a format approved by the Division. Revisions to this permit shall be made in accordance with 40 CFR Part 72, Subpart H, §§ 72.80 through 72.85 (as adopted by reference in Colorado Regulation 18). Permit modification requests shall be submitted to the Division at the address identified in Appendix D. Changes to the Designated Representative or Alternate Designated Representative shall be made in accordance with 40 CFR 72.23. 5. Comments,Notes and Justifications Units S001 through S005 are not subject to the NOx limitations since they burn natural gas. The NOx limitations in 40 CFR Part 76 are only applicable to coal-fired units. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership,L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 44 SECTION IV- Permit Shield Regulation No. 3, 5 CCR 1001-5,Part C, §§ I.A.4,V.D., &XIII.B and § 25-7-114.4(3)(a), C.R.S. 1. Specific Non-Applicable Requirements Based 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 modification or reconstruction on which construction commenced prior to permit issuance. Emission Unit Non-Applicable Requirement Justification Description& Number S011 40 CFR 61, Subpart Q (Adopted by The cooling tower does not operate with chromium-based water Reference,Colorado Regulation No.8) treatment chemicals. Facility 40 CFR 60, Subparts K, Ka, Kb (Colorado All tanks at the facility are smaller than the threshold limits in Regulation No. 6, Part A, Subpart K, Ka, these subparts. Kb) 2. General Conditions Compliance with this Operating Permit shall be deemed compliance with all applicable requirements specifically identified in the permit and other requirements specifically identified in the permit as not applicable to the source. This permit shield shall not alter or affect the following: 2.1 The provisions of §§ 25-7-112 and 25-7-113, C.R.S., or § 303 of the federal act, concerning enforcement in cases of emergency; 2.2 The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance; 2.3 The applicable requirements of the federal Acid Rain Program, consistent with § 408(a) of the federal act; 2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to § 25-7-111(2)(I), C.R.S., or the ability of the Administrator to obtain information pursuant to § 114 of the federal act; 2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit'for cause pursuant to Regulation No. 3,Part C, § XIII. 2.6 Sources are not shielded from terms and conditions that become applicable to the source subsequent to permit issuance. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 45 3. Streamlined Conditions The following applicable requirements have been subsumed within this operating permit using the pertinent streamlining procedures approved by the U.S. EPA. For purposes of the permit shield, compliance with the listed permit conditions will also serve as a compliance demonstration for purposes of the associated subsumed requirements. Permit Condition I Streamlined(Subsumed)Requirements Section II,Condition Regulation No.6,Part B,Section II.C.2(particulate matter standard) 1.2.2 Section II,Condition Regulation No.6,Part B,Section II.D.3.b(sulfur dioxide standard) 1.3.3 Section II, Condition 40 CFR Part 60 Subpart Db §§ 60.44b(a)(4)(i), (h) & (i), as adopted by reference in Colorado 1.4.2 Regulation No. 6, Part A [NOx emissions shall not exceed 0.20 lb/mmBtu, on a 30-day rolling average,applies at all times,including periods of startup,shutdown and malfunction] Section V, 40 CFR Part 60 Subpart Db§60.48c(i)(retain records for 2 yrs) Conditions 22.b&c Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership,L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 46 SECTION V- General Permit Conditions 5/22/12 version 1. Administrative Changes Regulation No.3,5 CCR 1001-5.Part A.§III. The permittee shall submit an application for an administrative permit amendment to the Division for those permit changes that are described in Regulation No.3,Part A,§I.B.1. The permittee may immediately make the change upon submission of the application to the Division. 2. Certification Requirements Regulation No.3.5 CCR 1001-5.Part C,&&III.B.9.,V.C.16.a.&e.and V.C.17. a. Any application,report,document and compliance certification submitted to the Air Pollution Control Division pursuant to Regulation No.3 or the Operating Permit shall contain a certification by a responsible official of the truth,accuracy and completeness of such form,report or certification stating that,based on information and belief formed after reasonable inquiry,the statements and information in the document are true,accurate and complete. b. All compliance certifications for terms and conditions in the Operating Permit shall be submitted to the Air Pollution Control Division at least annually unless a more frequent period is specified in the applicable requirement or by the Division in the Operating Permit. c. Compliance certifications shall contain: (i) the identification of each permit term and condition that is the basis of the certification; (ii) the compliance status of the source; (iii) whether compliance was continuous or intermittent; (iv) method(s)used for determining the compliance status of the source,currently and over the reporting period;and (v) such other facts as the Air Pollution Control Division may require to determine the compliance status of the source. d. All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. e. If the permittee is required to develop and register a risk management plan pursuant to§ 112(r)of the federal act,the permittee shall certify its compliance with that requirement;the Operating Permit shall not incorporate the contents of the risk management plan as a permit term or condition. 3. Common Provisions Common Provisions Regulation,5 CCR 1001-2§§ILA..II.B.,II.C.,II,.E.,B.F.,EL and II.J a. To Control Emissions Leaving Colorado When emissions generated from sources in Colorado cross the State boundary line, such emissions shall not cause the air quality standards of the receiving State to be exceeded,provided reciprocal action is taken by the receiving State. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 47 b. Emission Monitoring Requirements The Division may require owners or operators of stationary air pollution sources to install,maintain,and use instrumentation to monitor and record emission data as a basis for periodic reports to the Division. c. Performance Testing The owner or operator of any air pollution source shall,upon request of the Division,conduct performance test(s) and furnish the Division a written report of the results of such test(s)in order to determine compliance with applicable emission control regulations. Performance test(s)shall be conducted and the data reduced in accordance with the applicable reference test methods unless the Division: (i) specifies or approves,in specific cases,the use of a test method with minor changes in methodology; (ii) approves the use of an equivalent method; (iii) approves the use of an alternative method the results of which the Division has determined to be adequate for indicating where a specific source is in compliance;or (iv) waives the requirement for performance test(s)because the owner or operator of a source has demonstrated by other means to the Division's satisfaction that the affected facility is in compliance with the standard. Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to require testing under the Colorado Revised Statutes,Title 25,Article 7,and pursuant to regulations promulgated by the Commission. Compliance test(s)shall be conducted under such conditions as the Division shall specify to the plant operator based on representative performance of the affected facility.The owner or operator shall make available to the Division such records as may be necessary to determine the conditions of the performance test(s).Operations during period of startup,shutdown,and malfunction shall not constitute representative conditions of performance test(s)unless otherwise specified in the applicable standard. The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance test to afford the Division the opportunity to have an observer present. The Division may waive the thirty day notice requirement provided that arrangements satisfactory to the Division are made for earlier testing. The owner or operator of an affected facility shall provide,or cause to be provided,performance testing facilities as follows: (i) Sampling ports adequate for test methods applicable to such facility; (ii) Safe sampling platform(s); (iii) Safe access to sampling platform(s);and (iv) Utilities for sampling and testing equipment. Each performance test shall consist of at least three separate runs using the applicable test method.Each run shall be conducted for the time and under the conditions specified in the applicable standard.For the purpose of determining compliance with an applicable standard,the arithmetic mean of results of at least three runs shall apply.In the event that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of forced shutdown,failure of an irreplaceable portion of the sample train,extreme meteorological conditions,or other circumstances beyond the owner or operator's control,compliance may,upon the Division's approval,be determined using the arithmetic mean of the results of the two other runs. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership,L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 48 Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s)if so warranted. d. Affirmative Defense Provision for Excess Emissions during Malfunctions An affirmative defense to a claim of violation under these regulations is provided to owners and operators for civil penalty actions for excess emissions during periods of malfunction.To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement,the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of evidence that: (i) The excess emissions were caused by a sudden,unavoidable breakdown of equipment,or a sudden, unavoidable failure of a process to operate in the normal or usual manner,beyond the reasonable control of the owner or operator; (ii) The excess emissions did not stem from any activity or event that could have reasonably been foreseen and avoided,or planned for,and could not have been avoided by better operation and maintenance practices; (iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being exceeded; (iv) The amount and duration of the excess emissions(including any bypass)were minimized to the maximum extent practicable during periods of such emissions; (v) All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation(if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed,contemporaneous operating logs or other relevant evidence; (viii) The excess emissions were not part of a recurring pattern indicative of inadequate design,operation,or maintenance; (ix) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions. This section is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator,and shall not constitute an additional applicable requirement;and (x) During the period of excess emissions,there were no exceedances of the relevant ambient air quality standards established in the Commissions'Regulations that could be attributed to the emitting source. The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division verbally as soon as possible, but no later than noon of the Division's next working day, and shall submit written notification following the initial occurrence of the excess emissions by the end of the source's next reporting period. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. The Affirmative Defense Provision does not apply to failures to meet federally promulgated performance standards or emission limits,including,but not limited to,new source performance standards and national emission standards for hazardous air pollutants.The affirmative defense provision does not apply to state implementation plan(sip) limits or permit limits that have been set taking into account potential emissions during malfunctions,including,but not necessarily limited to,certain limits with 30-day or longer averaging times,limits that indicate they apply during malfunctions,and limits that indicate they apply at all times or without exception. e. Circumvention Clause Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit Al Shafer Generating Station Permit# 95OPWE096 Page 49 A person shall not build,erect,install,or use any article,machine,equipment,condition,or any contrivance,the use of which,without resulting in a reduction in the total release of air pollutants to the atmosphere,reduces or conceals an emission which would otherwise constitute a violation of this regulation. No person shall circumvent this regulation by using more openings than is considered normal practice by the industry or activity in question. f. Compliance Certifications For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any standard in the.Colorado State Implementation Plan,nothing in the Colorado State Implementation Plan shall preclude the use,including the exclusive use,of any credible evidence or information,relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed.Evidence that has the effect of making any relevant standard or permit term more stringent shall not be credible for proving a violation of the standard or permit term. When compliance or non-compliance is demonstrated by a test or procedure provided by permit or other applicable requirement,the owner or operator shall be presumed to be in compliance or non-compliance unless other relevant credible evidence overcomes that presumption. g. Affirmative Defense Provision for Excess Emissions During Startup and Shutdown An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during periods of startup and shutdown. To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement, the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of the evidence that: (i) The periods of excess emissions that occurred during startup and shutdown were short and infrequent and could not have been prevented through careful planning and design; (ii) The excess emissions were not part of a recurring pattern indicative of inadequate design,operation or maintenance; (iii) If the excess emissions were caused by a bypass(an intentional diversion of control equipment),then the bypass was unavoidable to prevent loss of life,personal injury,or severe property damage; (iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum extent practicable; (v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation(if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed,contemporaneous operating logs or other relevant evidence;and, (viii) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions. This subparagraph is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator,and shall not constitute an additional applicable requirement. The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the Division verbally as soon as possible,but no later than two(2)hours after the start of the next working day,and shall submit written quarterly notification following the initial occurrence of the excess emissions. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 50 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, V.C.11.& 16.d.and.5 25-7-122.1(2),C.R.S. a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to federally-enforceable terms or conditions constitutes a violation of the federal act,as well as the state act and Regulation No.3. Any permit noncompliance relating to state-only terms or conditions constitutes a violation of the state act and Regulation No.3,shall be enforceable pursuant to state law,and shall not be enforceable by citizens under§304 of the federal act. Any such violation of the federal act,the state act or regulations implementing either statute is grounds for enforcement action,for permit termination,revocation and reissuance or modification or for denial of a permit renewal application. b. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a permit termination,revocation or modification action or action denying a permit renewal application that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. c. The permit may be modified,revoked,reopened,and reissued,or terminated for cause. The filing of any request by the permittee for a permit modification,revocation and reissuance,or termination,or any notification of planned changes or anticipated noncompliance does not stay any permit condition,except as provided in§§X.and XI.of Regulation No.3,Part C. d. The permittee shall furnish to the Air Pollution Control Division,within a reasonable time as specified by the Division,any information that the Division may request in writing to determine whether cause exists for modifying, revoking and reissuing,or terminating the permit or to determine compliance with the permit. Upon request,the permittee shall also furnish to the Division copies of records required to be kept by the permittee,including information claimed to be confidential. Any information subject to a claim of confidentiality shall be specifically identified and submitted separately from information not subject to the claim. e. Any schedule for compliance for applicable requirements with which the source is not in compliance at the time of permit issuance shall be supplemental,and shall not sanction noncompliance with,the applicable requirements on which it is based. f. For any compliance schedule for applicable requirements with which,the source is not in compliance at the time of permit issuance,the permittee shall submit,at least every 6 months unless a more frequent period is specified in the applicable requirement or by the Air Pollution Control Division,progress reports which contain the following: (i) dates for achieving the activities,milestones,or compliance required in the schedule for compliance,and dates when such activities,milestones,or compliance were achieved;and (ii) an explanation of why any dates in the schedule of compliance were not or will not be met,and any preventive or corrective measures adopted. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 51 g. The permittee shall not knowingly falsify,tamper with,or render inaccurate any monitoring device or method required to be maintained or followed under the terms and conditions of the Operating Permit. 5. Emergency Provisions Regulation No.3,5 CCR 1001-5,Part C, VII. An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed the technology-based emission limitation under the permit due to unavoidable increases in emissions attributable to the emergency. "Emergency" does not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. An emergency constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology-based emission limitation if the permittee demonstrates,through properly signed,contemporaneous operating logs,or other relevant evidence that: a. an emergency occurred and that the permittee can identify the cause(s)of the emergency; b. the permitted facility was at the time being properly operated; c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards,or other requirements in the permit;and d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the next working day following the emergency,and followed by written notice within one month of the time when emissions limitations were exceeded due to the emergency. This notice must contain a description of the emergency,any steps taken to mitigate emissions,and corrective actions taken. This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement. 6. Emission Controls for Asbestos Regulation No.8,5 CCR 1001-10,Part B The permittee shall not conduct any asbestos abatement activities except in accordance with the provisions of Regulation No. 8,Part B,"asbestos control." 7. Emissions Trading,Marketable Permits,Economic Incentives Regulation No.3,5 CCR 1001-5,Part C, §V.C.13. No permit revision shall be required under any approved economic incentives, marketable permits, emissions trading and other similar programs or processes for changes that are specifically provided for in the permit. 8. Fee Payment C.R.S. 25-7-114.1(6)and 25-7-114.7 a. The permittee shall pay an annual emissions fee in accordance with the provisions of C.R.S. §25-7-114.7. A 1% per month late payment fee shall be assessed against any invoice amounts not paid in full on the 91st day after the date of invoice,unless a permittee has filed a timely protest to the invoice amount. b. The permittee shall pay a permit processing fee in accordance with the provisions of C.R.S. §25-7-114.7. If the Division estimates that processing of the permit will take more than 30 hours,it will notify the permittee of its estimate of what the actual charges may be prior to commencing any work exceeding the 30 hour limit. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership,L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 52 c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S.§25-7-115.1(6)for each APEN or revised APEN filed. 9. Fugitive Particulate Emissions Regulation No. 1,5 CCR 1001-3,§IIJ.D.1. The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate emissions into the atmosphere,in accordance with the provisions of Regulation No. 1,§III.D.1. 10. Inspection and Entry Regulation No.3,5 CCR 1001-5,Part C. V.C.16.b. Upon presentation of credentials and other documents as may be required by law,the permittee shall allow the Air Pollution Control Division,or any authorized representative,to perform the following: a. enter upon the permittee's premises where an Operating Permit source is located,or emissions-related activity is conducted,or where records must be kept under the terms of the permit; b. have access to,and copy,at reasonable times,any records that must be kept under the conditions of the permit; c. inspect at reasonable times any facilities,equipment(including monitoring and air pollution control equipment), practices,or operations regulated or required under the Operating Permit; d. sample or monitor at reasonable times,for the purposes of assuring compliance with the Operating Permit or applicable requirements,any substances or parameters. 11. Minor Permit Modifications Regulation No.3,5 CCR 1001-5.Part C.&§X.&XI. The permittee shall submit an application for a minor permit modification before making the change requested in the application. The permit shield shall not extend to minor permit modifications. 12. New Source Review Regulation No.3,5 CCR 1001-5.Part B The permittee shall not commence construction or modification of a source required to be reviewed under the New Source Review provisions of Regulation No.3,Part B,without first receiving a construction permit. 13. No Property Rights Conveyed Regulation No.3.5 CCR 1001-5.Part C.§V.C.11.d. This permit does not convey any property rights of any sort,or any exclusive privilege. 14. Odor Regulation No.2,5 CCR 1001-4,Part A As a matter of state law only, the permittee shall comply with the provisions of Regulation No. 2 concerning odorous emissions. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 53 15. Off-Permit Changes to the Source Regulation No.3,5 CCR 1001-5,Part C, $XII.B. The permittee shall record any off-permit change to the source that causes the emissions of a regulated pollutant subject to an applicable requirement,but not otherwise regulated under the permit, and the emissions resulting from the change,including any other data necessary to show compliance with applicable ambient air quality standards. The permittee shall provide • contemporaneous notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permit shield shall not apply to any off-permit change. 16. Opacity Regulation No. 1,5 CCR 1001-3, §,*I.,II. The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1, §§I.-II. 17. Open Burning Regulation No.9,5 CCR 1001-11 The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions of Regulation No.9. 18. Ozone Depleting Compounds Regulation No. 15,5 CCR 1001-17 The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds. Sections I.,II.C.,II.D.,III.IV.,and V.of Regulation No. 15 shall be enforced as a matter of state law only. 19. Permit Expiration and Renewal Regulation No.3,5 CCR 1001-5,Part C,§$III.B.6.,IV.C.,V.C.2. a. The permit term shall be five(5)years. The permit shall expire at the end of its term. Permit expiration terminates the permittee's right to operate unless a timely and complete renewal application is submitted. b. Applications for renewal shall be submitted at least twelve months,but not more than 18 months,prior to the expiration of the Operating Permit. An application for permit renewal may address only those portions of the permit that require revision,supplementing,or deletion,incorporating the remaining permit terms by reference from the previous permit. A copy of any materials incorporated by reference must be included with the application. 20. Portable Sources Regulation No.3,5 CCR 1001-5,Part C,&II.D. Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in location. 21. Prompt Deviation Reporting Regulation No.3,5 CCR 1001-5,Part C, §V.C.7.b. The permittee shall promptly report any deviation from permit requirements, including those attributable to malfunction conditions as defined in the permit,the probable cause of such deviations, and any corrective actions or preventive measures taken. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 54 "Prompt"is defined as follows: a. Any definition of"prompt"or a specific timeframe for reporting deviations provided in an underlying applicable requirement as identified in this permit;or b. Where the underlying applicable requirement fails to address the time frame for reporting deviations,reports of deviations will be submitted based on the following schedule: (i) For emissions of a hazardous air pollutant or a toxic air pollutant(as identified in the applicable regulation) that continue for more than an hour in excess of permit requirements,the report shall be made within 24 hours of the occurrence; (ii) For emissions of any regulated air pollutant,excluding a hazardous air pollutant or a toxic air pollutant that continue for more than two hours in excess of permit requirements,the report shall be made within 48 hours;and (iii) For all other deviations from permit requirements,the report shall be submitted every six(6)months, except as otherwise specified by the Division in the permit in accordance with paragraph 22.d.below. c. If any of the conditions in paragraphs b.i or b.ii above are met,the source shall notify the Division by telephone (303-692-3155)or facsimile(303-782-0278)based on the timetables listed above. [Explanatory note: Notification by telephone or facsimile must speck that this notification is a deviation report for an Operating Permit.] A written notice,certified consistent with General Condition 2.a.above(Certification Requirements),shall be submitted within 10 working days of the occurrence. All deviations reported under this section shall also be identified in the 6-month report required above. "Prompt reporting" does not constitute an exception to the requirements of "Emergency Provisions" for the purpose of avoiding enforcement actions. 22. Record Keeping and Reporting Requirements Regulation No.3,5 CCR 1001-5,Part A,&II.;Part C. V.C.6.,V.C.7. a. Unless otherwise provided in the source specific conditions of this Operating Permit,the permittee shall maintain compliance monitoring records that include the following information: (i) date,place as defined in the Operating Permit,and time of sampling or measurements; (ii) date(s)on which analyses were performed; (iii) the company or entity that performed the analysis; (iv) the analytical techniques or methods used; (v) the results of such analysis;and (vi) the operating conditions at the time of sampling or measurement. b. The permittee shall retain records of all required monitoring data and support information for a period of at least five (5)years from the date of the monitoring sample,measurement,report or application. Support information,for this purpose,includes all calibration and maintenance records and all original strip-chart recordings for continuous monitoring,instrumentation,and copies of all reports required by the Operating Permit. With prior approval of the Air Pollution Control Division,the permittee may maintain any of the above records in a computerized form. c. Permittees must retain records of all required monitoring data and support information for the most recent twelve (12)month period,as well as compliance certifications for the past five(5)years on-site at all times. A permittee Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 55 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. Section 502(b)(10)Changes Regulation No.3,5 CCR 1001-5,Part C, The permittee shall provide a minimum 7-day advance notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permittee shall attach a copy of each such notice given to its Operating Permit. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership,L.P Colorado Operating Permit JM Shafer Generating Station Permit#95OPWE096 Page 56 25. Severability Clause Regulation No.3,5 CCR 1001-5,Part C.§V.C.10. In the event of a challenge to any portion of the permit, all emissions limits, specific and general conditions, monitoring, record keeping and reporting requirements of the permit,except those being challenged,remain valid and enforceable. 26. Significant Permit Modifications Regulation No.3,5 CCR 1001-5,Part C.§III.B.2. The permittee shall not make a significant modification required to be reviewed under Regulation No. 3, Part B ("Construction Permit" requirements)without first receiving a construction permit. The permittee shall submit a complete Operating Permit application or application for an Operating Permit revision for any new or modified source within twelve months of commencing operation,to the address listed in Item 1 in Appendix D of this permit. If the permittee chooses to use the "Combined Construction/Operating Permit" application procedures of Regulation No. 3,Part C,then the Operating Permit must be received prior to commencing construction of the new or modified source. 27. Special Provisions Concerning the Acid Rain Program Regulation No.3,5 CCR 1001-5,Part C,§§V.C.1.b.&8 a. Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations promulgated under Title IV of the federal act,40 Code of Federal Regulations(CFR)Part 72,both provisions shall be incorporated into the permit and shall be federally enforceable. 'b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal act the regulations promulgated thereunder,40 CFR Part 72,are expressly prohibited. 28. Transfer or Assignment of Ownership Regulation No.3,5 CCR 1001-5,Part C.§11.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. 29. Volatile Organic Compounds Regulation No.7,5 CCR 1001-9,&§III&V. The requirements in paragraphs a, b and e apply to sources located in an ozone non-attainment area or the Denver 1-hour ozone attahunent/maintenance area. The requirements in paragraphs c and d apply statewide. a. All storage tank gauging devices,anti-rotation devices,accesses,seals,hatches,roof drainage systems,support structures,and pressure relief valves shall be maintained and operated to prevent detectable vapor loss except when opened,actuated,or used for necessary and proper activities(e.g.maintenance). Such opening,actuation,or use shall be limited so as to minimize vapor loss. Detectable vapor loss shall be determined visually,by touch,by presence of odor,or using a portable hydrocarbon analyzer. When an analyzer is used, detectable vapor loss means a VOC concentration exceeding 10,000 ppm. Testing shall be conducted as in Regulation No.7,Section VIII.C.3. b. Except when otherwise provided by Regulation No.7,all volatile organic compounds,excluding petroleum liquids, transferred to any tank,container,or vehicle compartment with a capacity exceeding 212 liters(56 gallons),shall be Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Thermo Cogeneration Partnership, L.P Colorado Operating Permit JM Shafer Generating Station Permit# 95OPWE096 Page 57 transferred using submerged or bottom filling equipment. For top loading,the fill tube shall reach within six inches of the bottom of the tank compartment. For bottom-fill operations,the inlet shall be flush with the tank bottom. c. The permittee shall not dispose of volatile organic compounds by evaporation or spillage unless Reasonably Available Control Technology(RACT)is utilized. d. No owner or operator of a bulk gasoline terminal,bulk gasoline plant,or gasoline dispensing facility as defined in Colorado Regulation No.7,Section VI,shall permit gasoline to be intentionally spilled,discarded in sewers,stored in open containers,or disposed of in any other manner that would result in evaporation. e. Beer production and associated beer container storage and transfer operations involving volatile organic compounds with a true vapor pressure of less than 1.5 PSIA actual conditions are exempt from the provisions of paragraph b, above. 30. Wood Stoves and Wood burning Appliances Regulation No.4,5 CCR 1001-6 The permittee shall comply with the provisions of Regulation No. 4 concerning the advertisement, sale, installation, and use of wood stoves and wood burning appliances. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendices OPERATING PERMIT APPENDICES A - INSPECTION INFORMATION B - MONITORING AND PERMIT DEVIATION REPORT C - COMPLIANCE CERTIFICATION REPORT D - NOTIFICATION ADDRESSES E - PERMIT ACRONYMS F - PERMIT MODIFICATIONS *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: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix A Compliance Monitoring Report Page 1 APPENDIX A-Inspection Information Directions to Plant: The plant is located at 6501 Weld County Road 31 in the town of Fort Lupton. Safety Equipment Required: Eye Protection, Hard Hat, Safety Shoes, Hearing Protection Gloves Facility Plot Plan: Figure 1 (following page) shows the plot plan as submitted on December 8, 1995 with the source's Title V Operating Permit Application. List of Insignificant Activities: The following list of insignificant activities was provided by the source to assist in the understanding of the facility layout. Since there is no requirement to update such a list, activities may have changed since the last filing. The asterisk (*) denotes an insignificant activity source category based on the size of the activity, emissions levels from the activity or the production rate of the activity. The owner or operator of individual emission points in insignificant activity source categories marked with an asterisk (*) must maintain sufficient record keeping verifying that the exemption applies. Such records shall be made available for Division review upon request. (Colorado Regulation No. 3, Part C, Section II.E) Units with emissions less than APEN de minimis — criteria and non-criteria pollutants (Reg 3, Part C.II.E.3.a&b)* Aqueous sulfuric acid storage tank, 1,500 gallon Fuel (gaseous)burning equipment<5 MMBtu/hr(Reg 3, Part C.II.E.3.k)* Portable propane heating units, < 1 MMBtu/hr Natural Gas space heaters, combined total heat< 6 MMBtu/hr Chemical storage tanks or containers < five hundred gallons & annual average throughput <twenty-five gallons per day(Reg 3, Part C.II.E.3.n)* Temporary waste oil storage drums, 55 gallon Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix A Compliance Monitoring Report Page 2 Emissions of air pollutants which are not criteria or non-criteria reportable pollutants (Reg 3 Part C.II.E.3.00) Sodium hypochlorite storage tank, 2,500 gallon Lubricating/waste oil storage tanks<40,000 gal(Reg 3, Part C.II.E.3.aaa) Generator lube oil service tanks,<3,000 gallons Waste oil storage tank, 300 gallons Storage tanks with annual throughput less than 400,000 gal and meeting content specifications (Reg 3, Part C.II.E.3.fff)* #2 diesel fuel oil service tanks, <500 gallons Forklifts(Reg 3 Part C.II.E.3.1dck) Forklift Non-road Engines Gasoline powered pressurized water parts washer,<5 HP Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix A Compliance Monitoring Report Page 3 • _ .� .FENGCrIiNE-�----•-._._ ... .-.--.—...... .�-13'L'-L l pow—,-40-!.—I---�T- c c I , Z4✓� / f .li i .,*1 IL Lip___t i-.7)I.: .,_,, ---,--r-t -, was fI k I4,. . l S..... 111- ..1, :.P'�-2 * —p..ii. .r 0 I --_is• - 5-x--.i J�.i ij ,w. l a s.» d2 51-�� P,1)1,4 a s lF iS k „ 00: •1 3 2 t ('4 . a ._t 1 `"1:: 7.._. �e� \ _I Y��i i s TI - Oa"�„rµ' S .. {= t s. r. 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Vie`.= f _ —_ 1 P, :s iA Sn _}4 es .,. 111 —_— i7 !I 2 =f x.en.7 �'e1...»r __=_--___ ,_:.....,:„...,„.............., •i= Y 3 a = x, z Hoittvi #P ei €1 c_. i2(lit ,:, t.; .,,',I G a ' '_ ti t=_ till 44 1 1 i ! t ;:,1, ire i FY'' 4 Pt 1 NKNb tAabora[,r1[. ,--. ----- _ NRI,NC wdK0e[5:wC QCO214ERATIf.141 MI 7 r>, 3?41' CRAYewi:++nn �..... � s�... �...N` �- Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 1 APPENDIX B Reporting Requirements and Definitions with codes ver 8/20/14 Please note that,pursuant to 113(c)(2)of the federal Clean Air Act, any person who knowingly: (A) makes any false material statement, representation, or certification in, or omits material information from, or knowingly alters, conceals, or fails to file or maintain any notice, application, record, report, plan, or other document required pursuant to the Act to be either filed or maintained (whether with respect to the requirements imposed by the Administrator or by a State); (B) fails to notify or report as required under the Act; or (C) falsifies,tampers with,renders inaccurate, or fails to install any monitoring device or method required to be maintained or followed under the Act shall, upon conviction, be punished by a fine pursuant to title 18 of the United States Code, or by imprisonment for not more than 2 years, or both. If a conviction of any person under this paragraph is for a violation committed after a first conviction of such person under this paragraph, the maximum punishment shall be doubled with respect to both the fine and imprisonment. The permittee must comply with all conditions of this operating permit. Any permit noncompliance constitutes • a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. The Part 70 Operating Permit program requires three types of reports to be filed for all permits. All required reports must be certified by a responsible official. Report#1: Monitoring Deviation Report(due at least every six months) For purposes of this operating permit, the Division is requiring that the monitoring reports are due every six months unless otherwise noted in the permit. All instances of deviations from permit monitoring requirements must be clearly identified in such reports. For purposes of this operating permit,monitoring means any condition determined by observation,by data from any monitoring protocol, or by any other monitoring which is required by the permit as well as the recordkeeping associated with that monitoring. This would include, for example, fuel use or process rate monitoring, fuel analyses, and operational or control device parameter monitoring. Report#2: Permit Deviation Report(must be reported "promptly") In addition to the monitoring requirements set forth in the permits as discussed above, each and every requirement of the permit is subject to deviation reporting. The reports must address deviations from permit requirements, including those attributable to malfunctions as defined in this Appendix, the probable cause of Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 2 such deviations, and any corrective actions or preventive measures taken. All deviations from any term or condition of the permit are required to be summarized or referenced in the annual compliance certification. For purposes of this operating permit, "malfunction" shall refer to both emergency conditions and malfunctions. Additional discussion on these conditions is provided later in this Appendix. For purposes of this operating permit, the Division is requiring that the permit deviation reports are due as set forth in General Condition 21. Where the underlying applicable requirement contains a definition of prompt or otherwise specifies a time frame for reporting deviations, that definition or time frame shall govern. For example, quarterly Excess Emission Reports required by an NSPS or Regulation No. 1, Section IV. In addition to the monitoring deviations discussed above, included in the meaning of deviation for the purposes of this operating permit are any of the following: (1) A situation where emissions exceed an emission limitation or standard contained in the permit; (2) A situation where process or control device parameter values demonstrate that an emission limitation or standard contained in the permit has not been met; (3) A situation in which observations or data collected demonstrates noncompliance with an emission limitation or standard or any work practice or operating condition required by the permit; or, (4) A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring(CAM) Rule)has occurred. (only if the emission point is subject to CAM) For reporting purposes, the Division has combined the Monitoring Deviation Report with the Permit Deviation Report. All deviations shall be reported using the following codes: 1 = Standard: When the requirement is an emission limit or standard 2=Process: When the requirement is a production/process limit 3=Monitor: When the requirement is monitoring 4=Test: When the requirement is testing 5=Maintenance: When required maintenance is not performed 6=Record: When the requirement is recordkeeping 7=Report: When the requirement is reporting 8=CAM: A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring(CAM)Rule)has occurred. 9=Other: When the deviation is not covered by any of the above categories Report#3: Compliance Certification (annually,as defined in the permit) Submission of compliance certifications with terms and conditions in the permit, including emission limitations, standards, or work practices, is required not less than annually. Compliance Certifications are intended to state the compliance status of each requirement of the permit over the certification period. They must be based, at a minimum, on the testing and monitoring methods specified in the Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 3 permit that were conducted during the relevant time period. In addition,if the owner or operator knows of other material information(i.e. information beyond required monitoring that has been specifically assessed in relation to how the information potentially affects compliance status),that information must be identified and addressed in the compliance certification. The compliance certification must include the following: • The identification of each term or condition of the permit that is the basis of the certification; • Whether or not the method(s) used by the owner or operator for determining the compliance status with each permit term and condition during the certification period was the method(s) specified in the permit. Such methods and other means shall include, at a minimum,the methods and means required in the permit. If necessary, the owner or operator also shall identify any other material information that must be included in the certification to comply with section 113(c)(2)of the Federal Clean Air Act,which prohibits knowingly making a false certification or omitting material information; • The status of compliance with the terms and conditions of the permit, and whether compliance was continuous or intermittent. The certification shall identify each deviation and take it into account in the compliance certification. Note that not all deviations are considered violations.' • Such other facts as the Division may require, consistent with the applicable requirements to which the source is subject,to determine the compliance status of the source. The Certification shall also identify as possible exceptions to compliance any periods during which compliance is required and in which an excursion or exceedance as defined under 40 CFR Part 64 (the Compliance Assurance Monitoring(CAM)Rule)has occurred. (only for emission points subject to CAM) Note the requirement that the certification shall identify each deviation and take it into account in the compliance certification. Previously submitted deviation reports, including the deviation report submitted at the time of the annual certification,may be referenced in the compliance certification. Startup,Shutdown,Malfunctions and Emergencies Understanding the application of Startup, Shutdown,Malfunctions and Emergency Provisions, is very important in both the deviation reports and the annual compliance certifications. Startup,Shutdown,and Malfunctions Please note that exceedances of some New Source Performance Standards (NSPS) and Maximum Achievable Control Technology (MACT) standards that occur during Startup, Shutdown or Malfunctions may not be considered to be non-compliance since emission limits or standards often do not apply unless specifically stated in the NSPS. Such exceedances must,however,be reported as excess emissions per the NSPS/MACT rules and would still be noted in the deviation report. In regard to compliance certifications, the permittee should be ' For example, given the various emissions limitations and monitoring requirements to which a source may be subject, a deviation from one requirement may not be a deviation under another requirement which recognizes an exception and/or special circumstances relating to that same event. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed:DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 4 confident of the information related to those deviations when making compliance determinations since they are subject to Division review. The concepts of Startup, Shutdown and Malfunctions also exist for Best Available Control Technology(BACT) sources, but are not applied in the same fashion as for NSPS and MACT sources. Emergency Provisions Under the Emergency provisions of Part 70 certain operational conditions may act as an affirmative defense against enforcement action if they are properly reported. DEFINITIONS Malfunction (NSPS) means any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions. Malfunction (SIP) means any sudden and unavoidable failure of air pollution control equipment or process equipment or unintended failure of a process to operate in a normal or usual manner. Failures that are primarily caused by poor maintenance, careless operation, or any other preventable upset condition or preventable equipment breakdown shall not be considered malfunctions. Emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology-based emission limitation under the permit, due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 5 Monitoring and Permit Deviation Report -Part I 1. Following is the required format for the Monitoring and Permit Deviation report to be submitted to the Division as set forth in General Condition 21. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. 2. Part II of this Appendix B shows the format and information the Division will require for describing periods of monitoring and permit deviations, or malfunction or emergency conditions as indicated in the Table below. One Part II Form must be completed for each Deviation. Previously submitted reports (e.g.EER's or malfunctions)may be referenced and the form need not be filled out in its entirety. FACILITY NAME: Thermo Cogeneration Partnership,L.P.-JM Shafer Generating Station OPERATING PERMIT NO: 95OPWE096 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) Deviations Noted Deviation Malfunction/ During Period?' Code2 Emergency Condition Operating Reported During Permit Unit Period? ID Unit Description YES NO YES NO S001-S005 Five turbine/duct burner packages. Six(6)General Electric LM6000 Natural Gas Combustion Turbines,Each Rated at 296 MMBtu/hr,Serial Nos. 185-130, 185-126,185-135, 185-136,185-137 and 185-238 and Five(5)Coen 12408-1 Duct Burners,Two(2)Rated at 240 MMBtu/hr,Each and Three(3)Rated at 180 MMBtu/hr,Each. The Turbines are Equipped with Steam Injection for NOx Control. Only five combustion turbines are permitted to operate at any time. S006 One(1)Detroit Diesel,Diesel Fired Internal Combustion Engine,Model No.8163-7416,Rated at 8.57 MMBtu/hr(65 gal/hr)and 1,232 hp,Serial No. Unknown. Emergency Generator. S007 One(1)Clark,Model No.DDFP-T6At,Diesel Fired Internal Combustion Engine,Rated at 2.28 MMBtu/hr(17.3 gal/hr)and 310 hp,Serial No. Unknown. Emergency Fire Pump. S011 One Custom Forced Draft Industrial Cooling Tower Equipped with Munters D15 Drift Eliminators. M001 Cold Cleaner Solvent Vat 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. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 6 2Use the following entries as appropriate: 1=Standard: When the requirement is an emission limit or standard 2=Process: When the requirement is a production/process limit 3=Monitor: When the requirement is monitoring 4=Test: When the requirement is testing 5=Maintenance: When required maintenance is not performed 6=Record: When the requirement is recordkeeping 7=Report: When the requirement is reporting 8=CAM: A situation in which an excursion or exceedance as defined in 40 CFR Part 64(the Compliance Assurance Monitoring(CAM)Rule)has occurred. 9=Other: When the deviation is not covered by any of the above categories Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 7 Monitoring and Permit Deviation Report-Part II FACILITY NAME: Thermo Cogeneration Partnership,L.P.—JM Shafer Generating Station OPERATING PERMIT NO: 95OPWE096 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: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 8 EXAMPLE FACILITY NAME: Acme Corp. OPERATING PERMIT NO: 96OPZZXXX REPORTING PERIOD: 1/1/04 - 6/30/06 Is the deviation being claimed as an: Emergency Malfunction XX N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Asphalt Plant with a Scrubber for Particulate Control -Unit XXX Operating Permit Condition Number Citation Section II, Condition 3.1 - Opacity Limitation Explanation of Period of Deviation Slurry Line Feed Plugged Duration START- 1730 4/10/06 END- 1800 4/10/06 Action Taken to Correct the Problem Line Blown Out Measures Taken to Prevent Reoccurrence of the Problem Replaced Line Filter Dates of Malfunction/Emergencies Reported (if applicable) 5/30/06 to A. Einstein,APCD Deviation Code Division Code QA: Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 9 Monitoring and Permit Deviation Report -Part III REPORT CERTIFICATION SOURCE NAME: Thermo Cogeneration Partnership,L.P. JM Shafer Generating Station FACILITY IDENTIFICATION NUMBER: 1230250 PERMIT NUMBER: 95OPWE096 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: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 1 APPENDIX C Format for Annual Compliance Certification Reports ver 8/20/14 Following is the format for the Compliance Certification report to be submitted to the Division and the U.S. EPA annually based on the effective date of the permit. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. FACILITY NAME: Thermo Cogeneration Partnership, L.P.-JM Shafer Generating Station OPERATING PERMIT NO: 95OPWE096 REPORTING PERIOD: I. Facility Status During the entire reporting period, this source was in compliance with ALL terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference. The method(s) used to determine compliance is/are the method(s) specified in the Permit. _With the possible exception of the deviations identified in the table below, this source was in compliance with all terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference, during the entire reporting period. The method used to determine compliance for each term and condition is the method specified in the Permit, unless otherwise indicated and described in the deviation report(s). Note that not all deviations are considered violations. Operating Unit Description Deviations Monitoring Was compliance continuous Permit Reported 1 Method per or intermittent?3 Unit ID Permit?Z Previous I Current YES I NO Continuous I Intermittent S001— Five turbine/duct burner packages. S005 Six(6)General Electric LM6000 Natural Gas Combustion Turbines,Each Rated at 296 MMBtu/hr,Serial Nos. 185-130, 185-126, 185-135, 185-136, 185-137 and 185-238 and Five(5)Coen 12408-1 Duct Burners,Two(2)Rated at 240 MMBtu/hr,Each and Three(3)Rated at 180 MMBtu/hr,Each. The Turbines are Equipped with Steam Injection for NOx Control. Only five combustion turbines are permitted to operate at any time. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 2 Operating Unit Description Deviations Monitoring Was compliance continuous Permit Reported I Method per or intermittent?3 Unit ID Permit?2 Previous Current YES NO Continuous Intermittent - S S006 One(1)Detroit Diesel,Diesel Fired Internal Combustion Engine,Model No. 8163-7416,Rated at 8.57 MMBtu/hr(65 gal/hr)and 1,232 hp,Serial No. Unknown. Emergency Generator. S007 One(1)Clark,Model No.DDFP-T6At, Diesel Fired Internal Combustion Engine, Rated at 2.28 MMBtu/hr(17.3 gal/hr)and 310 hp,Serial No.Unknown. Emergency Fire Pump. S011 One Custom Forced Draft Industrial Cooling Tower Equipped with Munters D15 Drift Eliminators. M001 Cold Cleaner Solvent Vat General Conditions Insignificant Activities 4 1 If deviations were noted in a previous deviation report , put an "X" under"previous". If deviations were noted in the current deviation report(i.e. for the last six months of the annual reporting period),put an"X"under"current". Mark both columns if both apply. 2 Note whether the method(s)used to determine the compliance status with each term and condition was the method(s)specified in the permit. If it was not,mark "no"and attach additional information/explanation. 3 Note whether the compliance status with of each term and condition provided was continuous or intermittent. "Intermittent Compliance"can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance has occurred. NOTE: The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the absence of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance for the duration of the reporting period. Therefore, if a source 1) conducts all of the monitoring and recordkeeping required in its permit, even if such activities are done periodically and not continuously, and if 2) such monitoring and recordkeeping does not indicate non-compliance,and if 3)the Responsible Official is not aware of any credible evidence that indicates non-compliance,then the Responsible Official can certify that the emission point(s)in question were in continuous compliance during the applicable time period. 4 Compliance status for these sources shall be based on a reasonable inquiry using readily available information. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 3 II. Status for Accidental Release Prevention Program: A. This facility is subject is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act) B. If subject: The facility is is not in compliance with all the requirements of section 112(r). 1. A Risk Management Plan will be has been submitted to the appropriate authority and/or the designated central location by the required date. III. Certification All information for the Annual Compliance Certification must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B. This signed certification document must be packaged with the documents being submitted. I have reviewed this certification in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this certification are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of§25-7 122.1, C.R.S. Printed or Typed Name Title Signature Date Signed NOTE: All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix D Notification Addresses Page 1 APPENDIX D Notification Addresses 1. Air Pollution Control Division Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit APCD-SS-B 1 4300 Cherry Creek Drive S. Denverr.CO 80246-1530 ATTN:Matt Burgett 2. United States Environmental Protection Agency Compliance Notifications: Office of Enforcement, Compliance and Environmental Justice Mail Code 8ENF-AT U.S.Environmental Protection Agency,Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 502(b)(10)Changes, Off Permit Changes: Office of Partnerships and Regulatory Assistance Air and Radiation Programs, 8P-AR U.S. Environmental Protection Agency,Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix E Permit Acronyms Page 1 APPENDIX E Permit Acronyms Listed Alphabetically: AIRS - Aerometric Information Retrieval System AP-42 - EPA Document Compiling Air Pollutant Emission Factors APEN - Air Pollution Emission Notice (State of Colorado) APCD - Air Pollution Control Division (State of Colorado) ASTM - American Society for Testing and Materials BACT- Best Available Control Technology BTU- British Thermal Unit CAA- Clean Air Act(CAAA = Clean Air Act Amendments) CCR- Colorado Code of Regulations CEM - Continuous Emissions Monitor CF - Cubic Feet(SCF = Standard Cubic Feet) CFR- Code of Federal Regulations CO - Carbon Monoxide COM- Continuous Opacity Monitor CRS - Colorado Revised Statute EF - Emission Factor EPA- Environmental Protection Agency FI- Fuel Input Rate in MMBtu/hr FR- Federal Register G- Grams Gal - Gallon GPM- Gallons per Minute HAPs - Hazardous Air Pollutants HP - Horsepower HP-HR- Horsepower Hour(G/HP-HR=Grams per Horsepower Hour) LAER- Lowest Achievable Emission Rate LBS - Pounds M - Thousand MM- Million MMscf- Million Standard Cubic Feet MMscfd- Million Standard Cubic Feet per Day N/A or NA- Not Applicable NOx - Nitrogen Oxides NESHAP - National Emission Standards for Hazardous Air Pollutants NSPS - New Source Performance Standards P - Process Weight Rate in Tons/Hr PE- Particulate Emissions PM- Particulate Matter PMIo - Particulate Matter Under 10 Microns Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix E Permit Acronyms Page 2 PPM Parts Per Million PPMV Parts Per Million,by Volume PPMVD Parts Per Million,by Volume,Dry PSD - Prevention of Significant Deterioration PTE- Potential To Emit RACT- Reasonably Available Control Technology SCC- Source Classification Code SCF - Standard Cubic Feet SIC - Standard Industrial Classification SO2 - Sulfur Dioxide TPY- Tons Per Year TSP - Total Suspended Particulate VOC - Volatile Organic Compounds Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix F Permit Modifications Page 1 APPENDIX F Permit Modifications DATE OF TYPE OF SECTION DESCRIPTION OF REVISION REVISION MODIFICATION NUMBER, CONDITION NUMBER Operating Permit Number: 95OPWE096 First Issued: 1/1/99 Renewed: DRAFT TECHNICAL REVIEW DOCUMENT For RENEWAL / MODIFICATION of OPERATING PERMIT 95OPWE096 Thermo Cogeneration Partnership, L. P., a Delaware Limited Partnership JM Shafer Generating Station Weld County Source ID 1230250 Prepared by Jacqueline Joyce October 2015 Revised January and March 2016 Reviewed by: Operating Permit Supervisor: Matt Burgett Field Services Unit: Jeremy Neustifter I. Purpose: This document will establish the basis for decisions made regarding the applicable requirements, emission factors, monitoring plan and compliance status of emission units covered by the renewed operating permit proposed for this site. The current Operating Permit was issued January 1, 2011. The renewal application was submitted on December 23, 2014. The expiration date for the permit is January 1, 2016. Since a timely and complete renewal application was submitted, under Colorado Regulation No. 3, part C, Section IV.C the terms and conditions shall not expire until the renewal Operating Permit is issued and any previously extended permit shield continues in full force and operation. In addition, the source submitted an application on April 6, 2015 to revise the permit to appropriately address the sixth turbine at the facility. 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 pp provided in the renewal application submitted December 23, 2014, the modification application submitted on April 6, 2015, comments on the draft permit and technical review document received on February 23, 2016, previous inspection reports and various e-mail correspondence, as well as telephone conversations with the applicant. Please note that copies of the Technical Review Document for the original permit and any Technical Review Documents associated with subsequent modifications of the original Operating Permit may be found in the Division files as well as on the Division website at www.colorado.gov/cdphe/airTitleV. This narrative is intended only as an adjunct for the reviewer and has no legal standing. Any revisions made to the underlying construction permits associated with this facility made in conjunction with the processing of this operating permit application have been reviewed in accordance with the requirements of Regulation No. 3, Part B, Construction Permits, and have been found to meet all applicable substantive and procedural Page 1 requirements. This operating permit incorporates and shall be considered to be a combined construction/operating permit for any such revision, and the permittee shall be allowed to operate under the revised conditions upon issuance of this operating permit without applying for a revision to this permit or for an additional or revised construction permit. • II. Description of Source This facility consists of a cogeneration facility defined under Standard Industrial Classification 4911. Electricity for sale is produced by five (5) combustion turbine/duct burner packages. There ale six combustion turbines any one of which may operate in any one of the turbine/duct burner packages. A maximum of five combustion turbines can be operating at any time. Each combustion turbine serves a generator rated at 57.412 MW (name-plate). Exhaust gas from the combustion turbine, which may be heated further by a duct burner, is used to either generate electricity or to heat a nearby tomato greenhouse. There are two steam turbines, each rated at 52.220 MW(name- plate). Other significant emission units at the facility are a cooling tower, emergency back-up generator and fire pump. The facility is located in Weld County at 6811 Weld County Road 31, in Ft. Lupton, CO. 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 facility. Rocky Mountain National Park, a federal Class I area is within 100 km of this facility. Based on the information provided in the renewal application, no changes have been made to any of the significant emission units. The summary of emissions that was presented in the Technical Review Document (TRD) for the previous renewal permit has been modified to indicate revised potential emissions from the emergency engines. Emissions (in tons/yr) at the facility are as follows: Potential to Emit(tons/yr) Emission Unit PM PM10 SO2 NOx1 CO VOC HAPS Turbine/Duct Burner 1 (S001) 16.81 16.81 2 90.51 9.64 See Turbine/Duct Burner 2(S002) 16.81 16.81 2 589. 90.51 9.64 Table on Turbine/Duct Burner 3(S003) 16.81 16.81 2 90.51 9.64 Page 19 Turbine/Duct Burner 4(S004) 16.81 16.81 2 90.51 9.64 Turbine/Duct Burner 5(S005) 16.81 16.81 2 90.51 9.64 Emergency Gen. (S006)2 0.15 0.12 0.11 6.86 1.82 0.19 Fire-Pump(S007)2 0.18 0.18 0.17 2.52 0.54 0.21 Cooling Tower(S011)3 9.5 9.5 1.23 Total 93.88 93.85 10.28 598.38 454.91 49.83 10.55 Page 2 'Each turbine/duct burner has individual NOx limits, however,the total NOx limits for all units is more restrictive,so the total limit is shown in the table. 2Emissions shown are based on AP-42 emission factors,design rate(MMBtu/hr)and 500 hrs per year of operation. Since actual, uncontrolled emissions are below the APEN de minimis level,the APEN and underlying construction permits were cancelled. VOC emissions are based on an emission factor of 0.0527 lb/MMgal for chloroform.The construction permit for the cooling tower did not include a limit on VOC emissions. The criteria pollutant PTE shown above is based on permitted emission limits for the turbines, duct burners and cooling tower. Criteria pollutants for the emergency engines are based on AP-42 emission factors (Section 3.3 (dated 10/96), Table 3.3-1 for the fire pump engine and Section 3.4 (dated 10/96), Tables 3.4-1 (for SO2, S = 0.05) and 3.4-2 for the emergency generator,), design rate (MMBtu/hr) and 500 hours per year of operation (in accordance with the September 6, 1995 EPA Memo, "Calculating Potential to Emit (PTE) for Emergency Generators"). Although the September 6, 1995 memo only addresses emergency generators, the Division considers that it is appropriate to use 500 hours per year to estimate PTE for any emergency engine. The construction permits for these engines were cancelled since actual, uncontrolled emissions are below the APEN de minimis level and PTE for these engines is below the significance level. The breakdown of HAP emissions by emission unit and individual HAP is provided on page 19 of this document. The PTE for HAP emissions is based on AP-42 emission factors, permitted fuel consumption limits and a heat value of 1020 Btu/SCF for natural gas for the turbines and duct burners. For the engines, PTE for HAP emissions is based on AP-42 emission factors, design rate (MMBtu/hr) and 500 hours per year of operation. Actual Emissions are typically less than PTE and are shown in the table below. Unit Data PM/PM10/P SO2 NOx CO VOC HAPs Year M2.5 S001 -Turbine 2013 4.74 0.43 62.81 28.87 4.07 0.51 S002-Turbine 2013 3.97 0.36 53.64 27.76 3.41 0.43 S003-Turbine 2013 4 0.37 56.77 27.31 3.51 0.44 S004 Turbine 2013 4.11 0.38 55.45 29.86 3.57 0.45 S005-Turbine 2013 4.59 0.42 61.86 30.3 3.96 0.5 S006-Emergency 2009 0.22 Generator _ S009-Cooling 2012 4.94 Tower Total 26.35 1.96 290.75 144.1 18.52 2.33 For data year 2013, actual emissions are based on APENs submitted on 4/3/14 For data year 2012, actual emissions are based on APENs submitted 4/4/13 For data year 2010, actual emissions are based on APENs submitted 3/31/10 Only HAPS reported were formaldehyde. Page 3 National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source Categories As indicated in the above table summarizing potential to emit, the facility is not a major source for HAPS. The applicability of various NESHAPs (also referred to as "MACT requirements") that apply to area sources was discussed in the technical review document to support the second renewal permit (issued January 1, 2011). That discussion has been updated to reflect changes to the various MACT standards and the promulgation of any new standards that may apply. Paint Stripping and Miscellaneous Surface Coating at Area Sources (40 CFR Part 63 Subpart HHHHHH) As discussed in the technical review document for the second renewal permit (issued January 1, 2011), these requirements do not apply for the following reasons. The Division considers that any spray coatings of motor vehicles and mobile equipment and spray application of coatings that contain the target HAP at this facility would meet the definition of facility maintenance and none of the paint stripping chemicals used at the facility contain methylene chloride. Reciprocating Internal Combustion Engines (RICE) (40 CFR Part 63 Subpart 7777) Final revisions to the RICE MACT were published in the Federal Register on March 3, 2010 and these revisions address existing (commenced construction prior to June 12, 2006) compression ignition engines at area sources. Two diesel fuel-fired emergency engines (one driving an emergency generator and one driving a fire pump) are subject to requirements in the RICE MACT and are included in Section II of the current Title V permit (last revised August 8, 2012). Revisions were made on January 30, 2013 to the RICE MACT and these revisions primarily changed the requirements for engines greater than 500 hp located at area sources and the operating requirements for emergency engines. The revisions to the RICE MACT that are applicable to these engines will be included in the renewal permit. New Source Performance Standards (NSPS) EPA has promulgated NSPS requirements for new source categories since the issuance of the second renewal permit (issued January 1, 2011) for this facility. NSPS requirements generally only apply to new or modified equipment and the Division is not aware of any modifications to existing equipment or additions of new equipment that would render equipment at this facility subject to NSPS requirements. However, because the recently promulgated NSPS requirements address equipment that may not be subject to APEN reporting or minor source construction permit requirements, the applicability of some of the newly promulgated requirements is being addressed here. NSPS Subpart JJJJ —Stationary Spark Ignition Engines Page 4 NSPS Subpart JJJJ applies to stationary spark ignition engines that commenced construction, reconstruction or modification after June 12, 2006 and were manufactured after specified dates. The date the engine commenced construction is the date the engine was ordered by the owner/operator. There are no spark ignition engines located at this facility, therefore, the requirements in Subpart JJJJ do not apply. NSPS Subpart IIII — Stationary Compression Ignition Engines NSPS Subpart IIII applies to stationary compression ignition engines that commenced construction, reconstruction or modification after July 11, 2005 and were manufactured after specified dates. The date the engine commenced construction is the date the engine was ordered by the owner/operator. The only compression ignition engines that are located at this facility are the engines driving the emergency generator and the emergency fire pump, all of which commenced operation prior to July 11, 2005 and therefore, the requirements in Subpart 1111 do not apply. New and/or Revised Colorado Regulations The following Colorado Regulations have been revised since the issuance of the first renewal permit (issued January 1, 2011), thus the applicability of these requirements is being addressed here Colorado Regulation No. 7, Sections XII — Requirements for Oil and Gas Operations in the 8-hour Ozone Control Area or any Ozone Non-Attainment or Attainment/Maintenance Areas and Section XVIII - Natural Gas-Actuated Pneumatic Controllers Associated with Oil and Gas Operations (Statewide) These requirements do not apply since oil and gas operations do not occur at this facility. Colorado Regulation No. 7, Section XVI - Requirements for Engines in the 8-Hour Ozone Control Area and Section XVII — Statewide Requirements for Oil and Gas Operations and Natural Gas-Fired Engines The requirements in Section XVI were adopted in March 2004 and apply to the 8-hour ozone control area. The requirements in Section XVII were first adopted in December 2006 (last revised February 2014) and apply statewide. The requirements in Section XVI apply to natural gas fired engines. The requirements in Section XVII include requirements for storage tanks, leak detection and repair programs, glycol dehydrators and well operations at oil and gas facilities and natural gas fired engines. Requirements for storage tanks, leak detection and repair programs, well operations and glycol dehydrators at oil and gas facilities These requirements do not apply since oil and gas operations do not occur at this facility. Page 5 Engine requirements These requirements do not apply since there are no natural gas-fired engines at this facility. Repealed APEN Exemptions Since the second Title V renewal permit was processed (issued January 1, 2011) the APEN exemptions for engines— limited size and hours (Reg 3, Part A, Section II.D.1.sss) and emergency generators— limited size and hours (Reg 3, Part A, Section II.D.1.ttt) was repealed. There is a diesel fuel-fired engine driving an emergency generator and a diesel fuel-fired engine driving an emergency fire pump included in Section II of the permit. The permit does not indicate that these engines are APEN exempt, nor have APEN cancellation requests been received for these engines. Revised APENs are not required for emergency generators located at electric utilities (see Colorado Regulation No. 3, Part A, Section II.C.1.g and h), although submittal of an initial APEN is required for emergency generators that are ancillary to the main units at electric utility facilities (see Colorado Regulation No. 3, Part A, Section II.D.3). The source submitted information indicating that actual, uncontrolled emissions from these engines were below the APEN de minimis level and submitted a request on December 28, 2015 to cancel the APEN and underlying construction permit. The emergency fire pump engine would be exempt from the APEN reporting requirements if actual uncontrolled emissions are below the APEN de minimis level (1 ton/yr of NOx or VOC and 2 tons/yr of CO, SO2 and PM/PM1o/PM2.5). The source submitted information indicating that actual, uncontrolled emissions from these engines were below the APEN de minimis level and submitted a request on December 28, 2015 to cancel the APEN and underlying construction permit. It should be noted that potential to emit from both the emergency generator and fire pump engine are below the significance level (based on 500 hours per year of operation per September 6, 1995 EPA memo). Compliance Assurance Monitoring (CAM)Applicability CAM applies to any emission unit that is subject to an emission limitation, uses a control device to achieve compliance with that emission limitation and has potential pre-control emissions equal to or greater than major source levels. CAM was reviewed for this facility during the first renewal (issued October 1, 2006). At that time it was determined that CAM did not apply to the turbines, since the Title V permit specified a continuous monitoring method for NOx (per 40 CFR Part 64 § 64.2(b)(1)(vi)) and there were no other emission units equipped with a control device. Page 6 In their April 6, 2015 modification application, the source requested that a sixth turbine be addressed in the permit. As discussed later in this document, the source has requested that a sixth turbine be permitted as a "spare". The facility consists of five combustion turbine/duct burner packages, each with a separate stack. Only five combustion turbines may be operated at any one time. The five packages have been in p p g the Title V permit since initial issuance (January 1, 1999) with the requirement to continuously monitor NOx emissions. Although the serial number of the turbine in the package may change from time to time, due to the need to replace a turbine that requires periodic maintenance, the CAM determination does not change, since continuous NOx monitoring has been required for the package since initial Title V permit issuance. Greenhouse Gases The potential-to-emit of greenhouse gas (GHG) emissions from this facility is greater than 100,000 TPY CO2e. Future modifications greater than 75,000 tons per year CO2e may be subject to regulation (Regulation No. 3, Part A, I.B.44). Ill. Discussion of Modifications Made The following discussion related to modifications is with respect to the current active permit (last revised August 8, 2012) and unless specifically noted as "new", the condition numbers identified in this document reflect the condition numbers in the current permit (last revised August 8, 2012). Because some permit conditions in the current Title V permit have been removed, reorganized and/or reformatted as part of this permitting process, the condition numbers discussed in this document may not reflect the condition numbers in the draft Title V permit. Source Requested Modifications December 23, 2014 Renewal Application Based on the sources requested changes included in their renewal application, the following changes were made to the permit. Page Following Cover Page • The title for the responsible official was revised as requested. Section 11.1 — Combustion Turbines In the renewal application, the source requested alternate BACT limits for the turbines during periods of combustion tuning and testing. In general most other natural gas-fired turbines used to generate electricity include alternate BACT (or RACT) limits during periods of combustion tuning and testing. The requested alternate limits for NOx and CO and the 1-hour averaging time are consistent with the combustion tuning and testing limits for other similar turbines and the requested NOx limit is lower than the NSPS Page 7 Subpart GG limit that applies to the turbines. The alternate BACT limits for combustion tuning and testing also include limits on the number of hours the alternate limit may be used in a year and the source did not include a limit on allowable hours in their draft permit language. The Division is setting the allowable hours as 150 hours per year for all turbines combined (this would equate to 30 hours per year per turbine assuming all five turbines undergo tuning and testing in the same year) and is consistent with the limits set for other facilities. For many of the other facilities that have alternate BACT (or RACT) limits for combustion tuning and testing, such limits were not included in the original PSD (or minor source) permit but were included in a later permitting action. Combustion tuning and testing is a normal activity required for routine maintenance of the units in which the turbine and associated controls may not operate in typical or optimal manner such that an alternate BACT limit is necessary. Given that the combustion tuning and testing limits are only allowed for a limited period of time per year(150 hours per year(or the equivalent of 30 hours per year per turbine if all five turbines undergo tuning and testing in the same year)), it is not expected that the ambient impact analysis conducted for the original PSD permit would be negatively affected, nor would a new analysis be warranted. Thus the Division considers that including the alternate BACT limits for periods of combustion tuning and testing during this renewal is acceptable. Conditions 1.4 and 1.5 were revised to include the alternate combustion tuning and testing limits, with a limit of 150 hours per year for use of the limit for all turbines combined. The language included in the draft permit is similar to the language proposed by the source in the renewal application but some minor revisions were made. Conditions 1.8.1, 1.8.2 and 1.8.6 were revised to address combustion tuning and testing. Section 11.5— Continuous Emission Monitoring Requirements In the renewal application, the source requested that a diluent cap of 19.0 % O2 be allowed for CO. The source requested that the language regarding the diluent cap be included in Section II, Condition 1.8, however, the Division considers that it would be more appropriate to include this language in the GEMS specific section in Section II, Condition 5 and has included the requested language in that location. Section 11.6—40 CFR Part 63 Subpart 7777 Requirements In their renewal application, the source requested that the requirements in 40 CFR Part 63 Subpart 7777 be updated to reflect the latest revisions. Condition 11.6 was revised to include the latest version of the rule, which may include more changes than suggested in the changes noted in the renewal application. It should be noted that additional revisions to Subpart 7777 are expected to be made in response to issues related to legal action associated with the allowable hours of Page 8 • 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. April 6, 2015 Modification Application The purpose of the April 6, 2015 modification is to address a sixth turbine as a permanent spare or replacement turbine. The facility is currently and has always been permitted to allow the operation of five combustion turbine/duct burner combinations or packages and this modification does not seek to change that. The modification application requests that the six turbines be listed as "permitted" turbines with the stipulation that only five turbine/duct burner packages can be operated at any time. Modification Type The application indicates that this modification qualifies as a minor modification and requested that it be processed under the minor modification procedures. Colorado Regulation No. 3, Part C, Section X.A identifies those modifications that can be processed under the minor permit modification procedures. The source indicated in the application that this modification does not violate any applicable requirements, does not involve significant changes to existing monitoring, reporting or record keeping requirements, does not require or change a case-by-case emission limitation or other standard, is based on underlying applicable requirements and is not otherwise required to be processed as a significant modification (e.g., does not increase emissions) therefore, the revision to identify six "permitted" turbines can be process as a minor modification. The Division agrees that this modification qualifies as a minor modification. More information supporting the determination that the modification does not require or change a case-by-case emission limitation is included under"Discussion". Modeling Requirements No physical changes to any emissions units were made with this modification, nor does this modification result in an increase in emissions, therefore, modeling is not required for this modification. Discussion As specified in Colorado Regulation No. 3, Part C, Section X.A.3, permit modifications that do not require or change a case-by-case determination of an emission limitation or other standard may be processed as a minor modification. This modification requests that a sixth turbine be identified as a "permitted" turbine, subject to the same emissions limitations, including BACT limitations, for the five turbines currently identified in the permit. Note that as indicated previously, the sixth turbine would be a "spare", only five turbines would be allowed to operate at a time. The Division considered if permitting this Page 9 sixth turbine at this time would trigger a BACT review for the sixth turbine. The Division has concluded that the sixth turbine may be identified as a "permitted" turbine, without trigging a "new" BACT review. The following discussion addresses this issue and provides the reasoning for which the Division has made this conclusion. The turbines used at this facility, GE model LM6000s, are aeroderivative turbines which require periodic maintenance to be performed off-site at qualified maintenance centers. Thus since the facility was constructed it was always anticipated that the turbines would have to be replaced from time to time in order to conduct the periodic maintenance. When the initial construction permits (91WE667(1) through (5)) were issued on February 19, 1992, there were implications that replacement of turbines would be allowed. A statement in the initial approval construction permits indicated that "[a]ny turbine that is brought on line without DLN shall use steam injection technology to control NOx emissions until such time that DLN is installed." It isn't completely clear from the language in the permit if this applies to the turbine addressed in the specific permit or any potential replacement turbines. The construction permit (91WE667) was revised on July 26, 1996 in order to consolidate the five permits into one and to reconsider BACT. The initial construction permit required the turbines to be equipped with dry low NOx (DLN) technology but it was not feasible to install DLN on the turbines, thus in the revised permit BACT was determined to be enhanced steam injection. The revised permit also included a condition that stipulated that the permit conditions shall apply to "replacement turbines placed in service from time to time as part of normal maintenance practices, provided such replacement turbines are GE LM6000 combustion turbines and further provided such replacement turbines are operated in full compliance with all conditions of this permit." When the initial Title V permit was issued on January 1, 1999, an alternative operating scenario (AOS) was included that allowed for the temporary or permanent replacement of turbines, provided that such replacements were GE LM6000 turbines and that such turbines were operated in compliance with the provisions of the permit. Early versions of the Division's AOS for turbine replacement allowed for permanent replacement of a turbine that either went through PSD review or was located at a major stationary source. However, beginning with the June 1, 2000 revised AOS for turbine replacement the Division determined that permanent replacement of turbines could not be provided for major stationary sources, since a permanent replacement turbine would be considered a "new" unit subject to PSD review if permitted emissions were above the significance level, unless the source could "net-out". In the first renewal of the Title V permit for this source (issued October 1, 2006) the AOS for permanent turbine replacement was removed and temporary replacement was defined as 270 days. In a June 3, 2008 email, an inspector for the Division requested information regarding replacement of turbines at the facility. The source responded to the request in a letter Page 10 dated July 17, 2008. The July 17, 2008 submittal addressed turbine replacements beginning on January 1, 1999 (conducted in accordance with the AOS in the Title V permit) and from 1994 through December 31, 1998 (conducted in accordance with the requirements in construction permit 91WE667). According to the information in the July 17, 2008 submittal, the sixth turbine (S/N 185-238) was first used at the facility on May 15, 1998. During the period of 1994 through December 31, 1998, a few leased turbines were used at the facility, in addition to the sixth turbine. However, in the period from January 1, 1999 through May 5, 2008 (the last date indicated in the July 17, 2008 submittal), only the five permitted turbines (S/Ns 185-130, 185-126, 185-135, 185-136 and 185-137) and the sixth turbine (S/N 185-328) have been used at the facility. It isn't clear whether the source intended to purchase a "spare" turbine when the July 26, 1996 revised construction permit (91WE667) was issued (this revision reconsidered BACT for the five turbines and included language allowing replacement of turbines) but it was clear that turbine replacements would be necessary to conduct periodic maintenance. The spare turbine was purchased around May 15, 1998, which is within two years of issuance of the revised construction permit. If, at the time of this revised construction permit issuance, the Division had determined that replacement of turbines at major stationary sources was not appropriate, provisions for a "spare" turbine could have been included in the construction permit, rather than the general turbine replacement language. If the "spare" turbine had been addressed in the construction permit at the time it was purchased (May 15, 1998), rather than when the revised construction permit was issued (July 26, 1996), it is unlikely that the BACT determination would have changed. This is particularly true since this turbine would be used as a "spare" in a turbine/duct burner package, which would require that the same or similar turbine be used. Since the BACT reconsideration conducted for the July 26, 1996 revised construction permit concluded that DLN (the "cleaner" technology at that time) could not be installed on the GE LM6000 turbines, it would be unlikely that in May 1998, when the "spare" turbine was purchased, that the conclusion would be any different. The Division considers that since the sixth turbine has been used almost exclusively as a "spare" turbine since it was purchased in May 1998 and thus could and should have been appropriately permitted as a spare, that the purpose of this modification is to rectify that situation. Thus the Division considers that this modification does not require or change a case-by-case emission limitation or other standard and can be processed as a minor modification. The "spare" turbine has been operated in accordance with the provisions specified for the "permitted" turbines during the times when the "spare" has been in operation. Revisions to Permit The following revisions were made to the permit to address this modification Section I — General Activities and Summary Page 11 • Language was added to Condition 1.1 to indicate that there are five combustion turbine/duct burner packages and there are six combustion turbines but only five combustion turbines can operate at any time. • The table in Condition 6.1 was revised to indicate there are five combustion turbine/duct burner packages and six combustion turbines but only five combustion turbines can operate at any time. Section 11.1 —Turbines and Duct Burners • Revised the summary table to note "packages", rather than "unit" for the turbine/duct burner combination. • Revised the text notations and replaced "combination"with "package" in reference to the turbine and duct burner together. • Included a requirement stipulating that only five combustion turbines may be operated at any time and that the source maintain records indicating which turbines are operating at any one time. Appendices • Language was added to the tables in Appendices B and C to indicate that there are five combustion turbine/duct burner packages and there are six combustion turbines but only five combustion turbines can operate at any time. February 23, 2016 Comments on the Draft Permit and Technical Review Document Section 11.5— Continuous Emission Monitoring Requirements In their February 23, 2016 comments on the draft permit and technical review document the source requested the following changes: • The source requested that the language in the second sentence in the last paragraph in Condition 5.1.2 (QA/QC plan) be revised to indicate that revisions necessary to comply with applicable requirements would be made to the plans at the request of the Division. The change was made as requested • The source requested that the data replacement provisions for CO in Condition 5.5.2 (replace with highest reading in the previous 30-day period) be revised to rely on the data replacement procedures in 40 CFR Part 75. The change was made as requested. Page 12 Other Modifications In addition to the modifications requested by the source, the Division has included changes to make the permit more consistent with recently issued permits, include comments made by EPA on other Operating Permits, as well as correct errors or omissions identified during inspections and/or discrepancies identified during review of this renewal. The Division has made the following revisions, based on recent internal permit processing decisions and EPA comments, to the Thermo Cogeneration Partnership, LP — JM Shafer Generating Station Renewal Operating Permit with the source's requested modifications. These changes are as follows: Page Following Cover Page • 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 previous permit. However, it should be noted that with this option, depending on the permit issuance date, the first monitoring period and compliance period may be short (i.e. less than 6 months and less than 1 year). Section I — General Activities and Summary • The cold cleaner solvent vat was added to the sentence regarding other significant emission units in Condition 1.1 • The construction permit numbers for the emergency generator and emergency fire pump were removed from Condition 1.3 since a construction permit cancellation form was submitted on December 28, 2015 • Added a statement to Condition 1.5 indicating that either electronic or hard copy records are acceptable. • The AOS for temporary turbine replacement in Condition 2 was updated to the most recent language. • Revised the reg citations for the definitions of"net emissions increase" and "significant" in Conditions 3.1 and 3.2. These citations were revised due to revisions to Reg 3. • The following revisions were made to the table in Condition 6.1: Page 13 o The second column was labeled "AIRS point number" as that is more appropriate. o The third column (facility identifier) was removed. These identifiers are not used elsewhere in the permit. o The horsepower ratings for the emergency generator and emergency fire pump engines were included. o The cold cleaner solvent vat was included. Section 11.1 —Turbines and Duct Burners • Slight revisions were made to the language in the second paragraph of Condition 1.3 since emissions are not determined separately for the turbine and duct burner but are based on stack emissions from the sulfur continuous monitoring system. • Revised the monitoring language for the NOx and CO BACT limits (Conditions 1.4.1 and 1.5.1) to indicate that replaced and bias-adjusted data are not used in assessing compliance with BACT limits. • Revised the monitoring language for the NOx and CO annual emission limitations (Conditions 1.4.2 and 1.5.2) to specify how lbs/hr emission rates are calculated and to indicate that replaced data is used to assess compliance with the annual limitations. • Condition 1.4.3 (NSPS GG NOx limit)was reformatted slightly and some additional language was added to address replaced and biased data. • Revised the frequency of recording natural gas combustion from the duct burner in Condition 1.7 from daily to monthly to reflect revisions to NSPS Db made January 28, 2009. The Division considers that 60.49b(d)(1) (monthly recording of fuel, no requirement for annual capacity factor calculation) applies in lieu of 60:49b(d)(1) (daily recording,calculate annual capacity factor) because the duct burners are restricted to burn only natural gas and are not required to continuously monitor any emissions (duct burners are not required to be equipped with CEMS per 60.48b(h)). • Removed the condition to calculate the annual capacity factor of the duct burners in Condition 1.9 to reflect revisions to NSPS Db made January 28, 2009. As discussed above, the Division considers that the requirements in 60.49b(d)(2) apply and thus calculating the annual capacity factor is not necessary. • Clarified that the opacity requirements in Condition 1.13 to state that the opacity limits apply to each stack. Section 11.2 and 3— Emergency Generator and Fire Pump Engine • Added a note indicating that the emergency generator is exempt from APEN reporting and construction permit requirements. The note indicates the level of Page 14 operation for which the engines would trigger APEN reporting and construction permit requirements. • The fuel and emissions limitations (Conditions 2.1, 2.2 and 3.1) were removed and replaced with a requirement to record hours of operation since the construction permit has been cancelled (actual, uncontrolled emissions below the APEN de minimis level). At the time construction permits were issued for the diesel engines (emergency generator and fire pump engine), permits were issued to make the operating levels federally enforceable to keep emissions below the significance level. Applications for the diesel engines (and some water chillers which have since been removed from the facility) were submitted in November 1992, which was after the construction permits were issued for the turbines (February 19, 1992) and thus PSD review was considered to have been triggered for a project if emissions from the engines and chillers were above the significance level. For initial permitting of the diesel engines potential to emit for the emergency engines was based on design rate and 8760 hours per year of operation. After issuance of these permits EPA came out with guidance specifying that for emergency generators potential to emit could be based on 500 hours per year of operation (September 6, 1995, "Calculating Potential to Emit (PTE) for Emergency Generators"). Although the September 6, 1995 memo was written to address PTE for purposes of Title V and Section 112 applicability, the Division considers that it is also appropriate to use for PSD purposes. The Division also considers that for any emergency engine, that it is appropriate to use 500 hours per year of operation to determine PTE. At 500 hours per year of operation, emissions from both emergency engines are below the significance level (highest emissions are NOx at approx. 10 tons/yr). Therefore, cancelling the APENs and permits is acceptable since PTE for these units are less than the significance level. It should be noted that it does not appear that the diesel engines (and since removed chillers) were considered part of the original project to install the turbines. If the engines (and since removed chillers) had been considered part of the project, it would not have been necessary to limit emissions from this equipment below the significance level but PSD review would have applied to the equipment, which would result in a BACT analysis, although it is unlikely that BACT would have been determined to be add-on control equipment. • The fuel sampling requirements (Conditions 2.4 and 3.3) were removed. In order for the diesel engine to exceed the SO2 emission limit, the diesel used as fuel would need to have a diesel fuel content of 0.79% by weight. This is highly unlikely, since typically only ultra low diesel fuel (15 ppm sulfur) is available for purchase and while the source may have some older diesel fuel on hand, it is unlikely to have a sulfur content above 0.05 weight percent. Page 15 • Revisions were made to the monitoring language for the SO2 requirements (Conditions 2.3 and 3.2) to reflect that no fuel sampling is required. • The MACT general provisions (Conditions 2.6 and 3.5) were removed. The MACT general provisions are included with the MACT 7777 requirements in Condition 6. • The opacity monitoring requirements (Condition 2.7 and 3.6) were simplified. • The good operating practices requirements (Conditions 2.8 and 3.7)were removed. The MACT 7777 provisions include requirements for good operating practices. Section 11.4— Cooling Tower • Based on EPA's response to a petition on another Title V operating permit, language was added to Condition 4.4 to require that records be maintained since this condition relies on "good engineering practices" (GEP). • Condition 4.5 was removed, as appropriate operation and maintenance of the cooling towers and drift eliminators are addressed in Condition 4.4. Section 11.5— Continuous Emission Monitoring Requirements • Added a statement under Condition 5 that indicates the requirements apply to the CEMS required by Condition 1.8. Some minor reformatting was done this Condition 5. • The language in Condition 5.1.1.1.c (CO monitor RATA frequency) was revised to refer to Part 60 performance specification 4/4A and Condition 5.1.1.1.b was revised to refer to specification 4/4A (rather than just 4A). • Added language ("new" Condition 5.2.1.3) to clarify that the data acquisition and handling system (DAHS) shall be able to manipulate data in the units of all emission limitations and to require that relative accuracy test audits (RATAs) be conducted in units of all emission limitations. • The paragraphs in Condition 5.3 were numbered. • The reporting requirements in Condition 5.5 (NSPS reporting) were revised to reflect the language in 40 CFR Part 60 Subpart A § 60.7(c) and (d). Frequency of report submittal was changed to semi-annual as provided,for in 60.7(c). • Added language to Condition 5.5 (data replacement requirements) to make it clear that replaced and bias-adjusted data are used to monitor compliance with the annual limitations. Section 11.6—40 CFR Part 60 Subpart 7777 Requirements Page 16 • The numbering in this condition was changed slightly (the paragraph labeled 6.1 is not numbered, so the number hierarchy changed): • Added language indicating that the source is subject to the most recent requirements in Subpart ZZZZ and noted the version of Subpart 777Z requirements that have been included. • Added a note indicating that the requirements in Subpart 777Z are expected to be revised in the future to address issues related to legal action associated with the allowable hours of operation provisions for emergency engines regarding those engine used for demand response. If such changes are made prior to permit issuance they will be included in the permit. • Removed the note indicating that if the Division adopts the March 3, 2010 requirements in Subpart ZZZZ that the engines will be subject to APEN reporting . and minor source construction permit requirements as the "catch-all" in Regulation No. 3, Parts A and B has been removed. • In addition to updating the Subpart ZZZZ language, the general provisions that apply to these engines were included in this Condition 6 per 40 CFR Part 63 Subpart Z777 § 63.6665 and Table 8. "New" Section 11.7— Cold Cleaner Solvent Vat During a review of the insignificant activities, it became apparent that there is a solvent cold cleaner located at the facility. Colorado Regulation No. 7 was revised on December 12, 2008 (effective January 30, 2009) to cover all ozone nonattainment areas (previously Reg 7 applied to the Denver 1-hr ozone attainment maintenance area and to any non-attainment area for the 1-hr ozone standard) and as a result the solvent cold cleaner is subject to requirements in Colorado Regulation No. 7, Section X. Although emissions from the solvent vat are below the APEN de minimis level and therefore exempt from both APEN reporting and construction permit requirements, under the "catch-all" provisions in Regulation No. 3, Part C, Section II.E (2nd paragraph) the solvent vat cannot be considered an insignificant activity because it is subject to specific requirements in Regulation No. 7. Since the solvent vat cannot be considered an insignificant activity, it will be included in the Operating Permit as a significant emission unit. The applicable requirements from Regulation No. 7 for these units are as follows: • Transfer and storage of waste solvent and used solvent (Reg 7, Sections X.A.3 and 4) • Solvent Cold Cleaner Requirements (Reg 7, Section X.B) o Control Equipment - covers, drainage, labeling and spray apparatus requirements (Reg 7, Section X.B.1) Page 17 4 o Operating Requirements (Reg 7, Section X.B.2) Section III —Acid Rain Requirements • Revised the designated representative's title and revised the alternate designated representative. • Revised the table in Section 2 to include calendar years corresponding to the relevant permit term for the renewal. • Added the source and date for the standard requirements. Appendices • The following changes were made to the insignificant activity list in Appendix A: o The insignificant activities in this list were grouped into categories identified in Reg 3, Part C, Section II.E.3. o Language was added to indicate those insignificant activity categories for which records should be available to verify insignificant activity status. • The Reg 3 citation for the Responsible Official on the certifications in Appendices B and C were revised (the version date was also changed). • The following changes were made to the table in Appendices B and C: o The horsepower ratings for the emergency generator and emergency fire pump engines were included in the both tables. o The cold cleaner solvent vat was included in the tables in Appendices B and C. o The water chillers were removed from the table in Appendix C. • Revised Appendix D to correct EPA address (compliance notifications) and to clarify permit mods sent to EPA. • Cleared the table in Appendix F. Page 18 Total HAP Emissions(tons/yr)from Thermo Cogeneration Partnership-Ft.Lupton Facility Emission Unit formaldehyde acetaldehyde toluene benzene acrolein xylene chloroform hexane dichlorobenzene nickel cadmium chromium Total All Turbines 3.76 0.21 0.69 0.06 0.03 0.34 5.09 All DBs 0.17 7.61E-03 4.70E-03 4.03 2.69E-03 4.70E- 2.46E-03 3.13E-03 4.22 03 Emerg.Gen 1.69E-04 5.40E-05 6.02E-04 1.66E-03 1.69E-05 4.14E-04 2.92E-03 Fire Pump 6.73E-04 4.38E-04 2.33E-04 5.32E-04 5.26E-05 1.63E-04 2.09E-03 Cool Twr 1.23 1 23 Total 3.93 0.21 0.70 0.07 0.03 0.34 1.23 4 03 2.69E-03 4.70E- 2.46E-03 3.13E-03 10.55 03 The heating value of natural gas was presumed to be 1020 Btu/scf HAP emissions for the turbines and duct burners are based on the total fuel consumption limit. HAP emissions for emergency generator and fire pump engine based on AP-42 emissions factors,design rate and 500 hrs/yr of operation per 9/6/1995 EPA memo. Page 19 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION OPERATING PERMIT RENEWAL SUMMARY PERMIT NUMBER: 95OPWE096 AIRS ID#: 1230250 DATE: March 17, 2016 APPLICANT: Thermo Cogeneration Partnership, L. P., JM Shafer Generating Station REVIEW ENGINEER: Jacqueline Joyce SOURCE DESCRIPTION Thermo Cogeneration Partnership, L. P. has applied for renewal of their Operating Permit issued for the JM Shafer Generating Station located at 6811 Weld County Road 31 in Ft. Lupton, Colorado in Weld County. Electricity for sale is produced by five(5)combustion turbine/duct burner packages and the facility is classified under SIC 4911. There are six combustion turbines any one of which may operate in any one of the turbine/duct burner packages. A maximum of five combustion turbines can be operating at any time. 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. This source is a major stationary source with respect to Prevention of Significant Deterioration (PSD) review and non-attainment area new source review(NANSR) requirements. There are no affected states within 50 miles of this facility. Rocky Mountain National Park, a Federal Class I designated area, is within 100 km of this facility. This source is not subject to the Accidental Release provisions of section 112(r) of the Federal Clean Air Act. In addition, although the combustion turbines are equipped with steam injection to control NOx emissions they are exempt from the compliance assurance monitoring (CAM) requirements in 40 CFR Part 64 because at the time the CAM plan was required the Title V permit specified a continuous compliance determination method (§64.2(b)(1)(vi)). FACILITY EMISSION SUMMARY Potential to Emit(tons/yr) Emission Unit PM PM1a SO2 NOx' CO VOC HAPS Turbine/Duct Burner 1 (S001) 16.81 16.81 2 90.51 9.64 All Turbine/Duct Burner 2 (S002) 16.81 16.81 2 589. 90.51 9.64 turbines— Turbine/Duct Burner 3 (S003) 16.81 16.81 2 90.51 9.64 5.09 Turbine/Duct Burner 4 (S004) 16.81 16.81 2 90.51 9.64 All duct burners— Turbine/Duct Burner 5 (S005) 16.81 16.81 2 90.51 9.64 4.22 Emergency Gen. (S006)2 0.15 0.12 . 0.11 6.86 1.82 0.19 2.92E-03 Fire-Pump (S007)2 0.18 0.18 0.17 2.52 0.54 0.21 2.09E-03 Cooling Tower(S011)3 9.5 9.5 1.23 1.23 .... .> « R_: "'0 ..4=`'. z . . :.�k,, �P�'.r fy fia�K• ??� '�' v,.`�"y �a «.& £��{ ' ,a� '�" ""�' Total 93.88 93.85 10.28 598.38 454.91 49.83 10.55 Each turbine/duct burner has individual NOx limits, however,the total NOx limits for all units is more restrictive, so the total limit is shown in the table. 2Emissions shown are based on AP-42 emission factors,design rate(MMBtu/hr)and 500 hrs per year of operation. Since actual, uncontrolled emissions are below the APEN de minimis level,the APEN and underlying construction permits were cancelled. 3 VOC emissions are based on an emission factor of 0.0527 lb/MMgal for chloroform.The construction permit for the cooling tower did not include a limit on VOC emissions. EMISSION SOURCES The following discussion identifies the more significant changes that were made in the renewal permit. Other minor language changes were made to other permit conditions. Turbines and Duct Burners (Section 11.1)—The source requested alternate BACT limits for the turbine/duct burner packages for periods of combustion tuning and testing. This alternate BACT limit has been consistently approved for other utility turbines. The alternate BACT limits may be used for 150 hours per year for all turbines combined. The permit language was revised to note that there are five(5)combustion turbine/duct burner packages and six(6)combustion turbines (one is used as a permanent"spare")and to specify that only five(5)combustion turbine/duct burner packages can operate at any one time. Minor language changes were made to the monitoring language for the NOx and CO BACT limits to indicate that replaced and bias-adjusted data are not included and to indicate how the mass emission rates are calculated. Emergency Generator and Emergency Fire Pump Engine(Section 11.2 and 3)—The fuel and emission limits were removed and replaced with a requirement to record hours of operation since the construction permits have been cancelled because actual, uncontrolled emissions are below the APEN de minimis level. The fuel sampling requirements were also removed. The MACT general provisions were removed since these are included in the RICE MACT(40 CFR Part 63 Subpart 7777) requirements(Condition 6). The good practices requirements were removed since the RICE MACT requirements include operating requirements and the opacity monitoring language was simplified. Cooling Tower(Section 11.4)—The general operating requirement(Condition 4.5)was removed as this language is included in Condition 4.4. Language was added to Condition 4.4 to require that records of"good operating practices"be kept. Continuous Emission Monitoring Systems(Section 11.5)—Language was added to clarify that the data acquisition and handling system shall be able manipulate data in the units of all emissions limitations and that relative accuracy test audits be conducted in units of all emissions limitations. The data replacement requirements for CO were revised to rely on the Part 75 data replacement requirements for SO2. 40 CFR Part 63 Subpart 7777 Requirements(Section 11.6)—The requirements in this condition were revised to reflect revisions made to 40 CFR Part 63 Subpart 7777. In addition,the relevant MACT general provisions(40 CFR Part 63 Subpart A)were included in this condition(under 63.6655). Cold Cleaner Solvent Vat(Section 11.7)—A cold cleaner solvent vat is located at the facility and is subject to requirements in Colorado Regulation No. 7, Section X, therefore it was included in the permit. ALTERNATIVE OPERATING SCENARIOS The alternative operating scenario for temporary combustion turbine replacement was updated to the latest version. INSIGNIFICANT ACTIVITY LIST The insignificant activities were grouped by the categories identified in Colorado Regulation No. 3, Part C,Section II.E.3. Language was added to indicate those insignificant activity categories for which records should be available to verify insignificant activity status. In addition, some activities have been added, removed or the descriptions revised. � CDP.fE COLORADO . ra Department of Public .K' Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado March 17, 2016 Mr. Daniel Salgado Environmental Services Tri-State Generation and Transmission Assoc., Inc. P. O. Box 33695 Denver, CO 80233-0695 REF: Thermo Cogeneration Partnership LP - JM Shafer Generating Station, FID # 1230250, OP # 95OPWE096 SUBJECT: Response to Comments on Draft Operating Permit Dear Mr. Salgado: The comments you provided on the draft renewal Operating Permit (96OPWE096) and Technical Review Document for your facility were received on February 23, 2016. The draft permit and technical review document were revised as requested in your comments, with the following exceptions: Draft Permit Comment: Page 12, Section II, Condition 1.4.1, Paragraph 2 - Currently the condition requires hourly mass NOx emissions to be calculated and summed to determine monthly NOx emissions in tons. Tri-State requests that the emissions be calculated monthly by multiplying the monthly average of all valid hourly NOx lb/MMBtu values by the total monthly heat input (MMBtu/month) and converting to tons by changing the requirement as follows. "Specifically hourly Jt mass NOx emissions (in lb/ #r) shall be calculated by multiplying the monthlyy eraeo hourly NOx lb/MMBtu values (which includes replaced or bias-adjusted data, as applicable) by the monthly cumulative hourly heat input value (MMBtu/#r th) (which includes replaced data from the fuel flow measurement, as applicable). The hourly NOx lb/MMBtu and heat input values shall be determined using equations F-_.5 or F -6, as appropriate for the diluents monitored by the CEMS and equates ates F-20 in Appendix F of 40 CFR Part 75. The resulting NOx lb/#r*AA value is then multiplied by the unit operating time for that hour to produce a NOx lbs value. Hourly NOx mass emissions (lbs) shall be summed and divided by 2000 lb/ton to determine monthly NOx emissions (in tons)." 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe lye o� John W. Hickenlooper, Governor I Larry Wolk,MD, MSPH, Executive Director and Chief Medical Officer ,\*;f 'r ,,*,/,� 1876 si Mr. Daniel Salgado, Tri-State Generation Ft Transmission Assoc., Inc. March 17, 2016 Response to Comments on Draft Permit Page 2 Response: Based on a conference call we had on March 10, 2016, the language specifying that hourly mass emissions shall be calculated and summed to determine monthly emissions will remain in the permit. However, the minor language corrections suggested, such as including "equation" in front of "F-20" will be made. Comment: Page 16, Section II, Condition 1.5.1, Paragraph 1- The last sentence in the paragraph states that the permittee shall program the DAHs to - calculate lb/hr CO emissions in accordance with 40 CFR Part 75. CO is not regulated by Part 75. Is the requirement to calculate CO emissions using the procedures in Part 75? Response: The Division is aware that the requirements in 40 CFR Part 75 do not apply to CO emission and you are correct that the intent of this requirement is to calculate CO emissions using the procedures in 40 CFR Part 75. Therefore the phrase "and 40 CFR Part 75" was replaced with "using the procedures in 40 CFR Part 75". Comment: Page 16, Section II, Condition 1.4.2.811.5.1], Paragraph 2- Similarly to condition 1.4.1 for NOx Tri-State requests that the paragraph be reworded as follows. "Specifically hourly mass CO emissions (in lb/ ,,,71:111 hr) shall be calculated by multiplying the hourly CO lb/MMBtu value.] (which includes replaced slate- . in accordance with the requirements in Condition 5.5.2, as applicable) by the hourly heat input value (MMBtu/#r IL TV: (which includes replaced data from the stack flow measurement, as applicable). The hourly CO lb/MMBtu and heat input values shall be determined using equations F-5 or F-6 (where for NON), as appropriate for the diluents monitored by the CEMS and '1, F-20 in Appendix F of 40 CFR Part 75. The resulting CO lb/hr value is then multiplied by the unit operating time for that hour to produce a CO lbs value. Hourly CO mass emissions (lbs) shall be summed and divided by 2000 lb/ton to determine monthly CO emissions (in tons)." Response: Based on a conference call we had on March 10, 2016, the language specifying that hourly mass emissions shall be calculated and summed to determine monthly emissions will remain in the permit. However, the k factor for CO will be included and the minor language corrections suggested, such as including "equation" in front of "F-20" will be made. Comment: Page 17, Section II, Condition 1.5.2.7, Sentence 1- Similar to Condition 1.5.1 referenced above, Condition 1.5.2.7 states that all valid CEMS concentration data points shall be summarized to generate one- hour average CO concentrations in accordance with the requirements in 40 CFR Part 75. CO is not regulated by Part 75. Is the requirement to Mr. Daniel Salgado, Tri-State Generation it Transmission Assoc., Inc. March 17, 2016 Response to Comments on Draft Permit Page 3 generate one-hour average CO concentrations using the procedures in Part 75? Page 18, Section 11, Condition 1.5.2.9, Paragraph 1, Sentence 1 and Sentence [sic] and Sentence 4 - The condition states that average CO concentration be generated in accordance with the requirements in 40 CFR Part 75 in the first sentence. CO is not regulated by Part 75. Is the requirement to generate one-hour average CO concentrations using the procedures in Part 75 (the comment also applies to the next paragraph)? In the fourth sentence it references NOx concentration. Should this be CO concentration? " ... Each clock hour average NOX CO concentration shall be ... ". Response: The Division has revised the last part of noted sentences to read as follows: "..in accordance with the requirements in Conditions 5.1.1.1.d and 5.1 .1.3.b of this permit using the procedures in 40 CFR Part 75. Comment: Page 28, Section 11, Condition 5. 1.13.a- Please change the text to read: RATAs shall be conducted in the units (e.g., lb/MMBtu, ppm) of the emission limitations for all of the for did �e short tern co centration conducted in measuremen u�tha(are applicablearth a on �� e.g., lb MMBtu, ipravdc) that are applicable to the emissions unit. The yr RATAs for emissions units that have annual or terr me emission limitations (tons/yr lbs en ) will be conducted in terms of pounds per hour (lb/hr). Response: The change to Condition 5.1 .1.3.a was made as requested, except that "short term mass" was replaced with "mass" and "e.g." was inserted prior to "lbs/event". Paragraph- Please change Comment: Page 28, Section 11, Condition 5.1.2, Lastg the language as follows: "The quality assurance/quality control plans shall be made available to the Division upon request. Revisions shall be made to the plans at the requests of the Division." Tri-State will make revisions to the QA/QC plans that are required by regulation or that are otherwise necessary, but this language is overly broad and appears to remove any allowance for negotiating changes. Response: As discussed in our conference call on March 10, 2016, Tri-State's intent was not to strike the noted sentence but to revise the language. The second sentence in this paragraph was replaced with the following: "Revisions necessary to comply with applicable requirements shall be made to the plans at the request of the Division". Comment: Page 29, Section 11, Condition 5.2.1, Sentence 1 -Because there is no continuous opacity monitoring system at the JM Shafer station, please change the language as follows: The permittee shall ensure that all Mr. Daniel Salgado, Tri-State Generation Ft Transmission Assoc., Inc. March 17, 2016 Response to Comments on Draft Permit Page 4 continuous emission monitoring systems required are in operation and monitoring unit emissions or opacity at all times except for monitoring system .. Response: The language in this Condition 5.2:1 is cited as originating from §60.13(e) but unfortunately does not reflect the current language in §60.13(e). Therefore, the language was revised to reflect the current language in §60.13(e) and there is no reference to monitoring opacity. Since §60.13(e) does not include the phrase "that the affected units combust any fuel" that phrase has not been included. The next step for this draft renewal permit will be to put it out for a 30-day Public Comment period. After that, the proposed permit will go to EPA Region VIII for a 45- day review period. The regulations also require that the applicant receive written notice of their right to a formal hearing before the Air Quality Control Commission at the same time that the Public Comment packet goes out. You will receive a separate letter containing that information. We appreciate that you took the time to thoroughly review this draft. Please feel free tocontact me at (303) 692-3267 or jackie.jovice@state.co.us if you have any further questions. Sincerely, Jacqueline Joyce Operating Permit Unit Stationary Sources Program Air Pollution Control Division • TRI-STATE GENERATION AND TRANSMISSION ASSOCIATION, INC. HEADQUARTERS: P.O. BOX 33695 DENVER, COLORADO 80233-0695 303-452-6111 February 18, 2016 Ms. Jacqueline Joyce Colorado Department of Public Health and Environment r 3=` Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 RE: Tri-State Comments on Draft Operating Permit Renewal and Modification for JM Shafer Generating Station Permit Number 95OPWE096 Dear Ms. Joyce: Tri-State Generation and Transmission Association, Inc (Tri-State) is the parent of Thermo Cogeneration Partnership, L.P. Tri-State received the draft Title 5 operating permit renewal and modification for the JM Shafer Generating Station from the Colorado Department of Public Health and Environment—Air Pollution Control Division(CDPHE-APCD) on January 8, 2016. The enclosed document details Tri-State's comments to the draft permit Number 95OPWE096. An electronic copy of the suggested changes (in track changes) will be sent to you via e-mail. If you have any questions concerning Tri-State's comments, please contact Dan Salgado at 303-452-6111. Sincerely, 13/arbara A. Wal Senior Vice President Policy and Compliance Chief Compliance Officer BAW:DS: dbr Enclosure AN CFFCR-.7\11-7I Ai7=T 1.4.47'VR.-1C77CAI,'FL r" CRAIG STATION ESCALANTE STATION NUCLA STATION P.O.BOX 1307 P.O.BOX 577 P.O.BOX 698 A Touchstone Energy'Cooperative CRAIG,CO 81626-1307 PREWITT,NM 87045 NUCLA,CO 81424-0698 970-824-4411 505-972-5200 970-864-7316 Ir I • AF,; JM SHAFER GENERATING STATION OPERATING PERMIT 95OPWE096 DRAFT OPERATING PERMIT RENEWAL/MODIFICATION AND TECHNICAL REVIEW DOCUMENT COMMENTS Draft Permit Page 1,Operating Permit Number—The operating permit number is listed as 96OPWE096.This should be changed to 95OPWE096. Page 1,Section I,Condition 1.1,Sentence 4-Each turbine/duct burner package is only equipped with one duct burner,so the"s"on"duct burners"should be deleted and"a"added: "Exhaust gas from the combustion turbine,which may be heated further by a duct burners..." Page 12, Section II,Condition 1.4.1,Paragraph 2—Currently the condition requires hourly mass NOx emissions to be calculated and summed to determine monthly NOx emissions in tons.Tri-State requests that the emissions be calculated monthly by multiplying the monthly average of all valid hourly NOx 1b/MMBtu values by the total monthly heat input(1191VIBtu/month)and converting to tons by changing the requirement as follows."Specifically hourly monthly mass NOx emissions(in lb/al-Oil-di bf)shall be calculated by multiplying the monthly average of all valid hourly NOx lb/MMBtu values(which includes replaced or bias-adjusted data,as applicable)by the monthlycamalat ve hourly heat input value (MMBtu/lc month)(which includes replaced data from the fuel flow measurement,as applicable). The hourly NOx lb/MMBtu and heat input values shall be determined using equations F-5 or F-6,as appropriate for the diluents monitored by the CEMS and equation F-20 in Appendix F of 40 CFR Part 75.The resulting NOx lb/lm]value is then multiplied by the unit operating time for that hour to 'vided by 2000 lb/ton to determine monthly NOx emissions(in tons)." Page 14,Section II,Condition 1.4.2.8,Paragraph 1,Sentence 5 and 6—There appears to be two typos. Sentence 5 of the above referenced condition it should state"...by the CEMS and "" anon F-20...".In the next sentence it should read"...and shutdown event even shall be...". Page 16,Section II,Condition 1.5.1,Paragraph 1—The last sentence in the paragraph states that the permittee shall program the DAHs to calculate lb/hr CO emissions in accordance with 40 CFR Part 75. CO is not regulated by Part 75.Is the requirement to calculate CO emissions using the procedures in Part 75? Page 16,Section II,Condition 1.4.2.8,Paragraph 2—Similarly to condition 1.4.1 for NOx Tri-State requests that the paragraph be reworded as follows."Specifically hourly mo mass CO emissions(in lb/np�onth lam)shall be calculated by multiplying the monthly average of valid hourly CO lb/MMBtu values(which includes replacede-data in accordance with the requirements in Condition 5.5.2,as applicable)by the monthly cumulative hourly heat input value(MMBtu/hr mouth)(which includes replaced data from the stack flow fuel flow measurement,as applicable). The hourly CO lb/MMBtu and heat input values shall be determined using equations F-5 or F-6(where K-7.272 z 10-8 for CO€ec NOx),as appropriate for the diluents monitored by the CEMS and equation F-20 in Appendix F of 40 CFR Part 75.The resulting CO lb/m month value is then multiplied by the unit operating time for that -- — vided by 2000 lb/ton to determine monthly CO emissions(in tons)." Page 17,Section II,Condition 13.2.7,Sentence 1—Similar to Condition 1.5.1 referenced above, Condition 1.5.2.7 states that all valid CEMS concentration data points shall be summarized to generate one-hour average CO concentrations in accordance with the requirements in 40 CFR Part 75. CO is not t regulated by Part 75.Is the requirement to generate one-hour average CO concentrations using the procedures in Part 75? Page 17-18, Section II,Condition 1.5.2.8 Paragraph 1, Sentence 1,Sentence 4 and Sentence 5—Tri- State requests that the word"valid"be inserted after the word"All"for clarification in the first sentence as follows. "All valid CEMS data points...".The fourth sentence references stack flow measurements. Tri-State does not measure stack flow and believes this should read"...from the stack fuel flow measurement...".Tri-State requests that the fifth sentence be changed as follows for clarity. "...shall be determined using equations F-5 or F-6 ((where K=7.272`x 10-8 for CO for NON), as appropriate for the diluent monitored by the CEMS and equation F-20 in Appendix F of 40 CFR Part 75. Page 18, Section II,Condition 1.5.2.9,Paragraph 1,Sentence 1 and Sentence and Sentence 4- The condition states that average CO concentration be generated in accordance with the requirements in 40 CFR Part 75 in the first sentence. CO is not regulated by Part 75.Is the requirement to generate one-hour average CO concentrations using the procedures in Part 75 (the comment also applies to the next paragraph)?In the fourth sentence it references NOx concentration. Should this be CO concentration? "...Each clock hour average Is19x CO concentration shall be...". Page 22, Section II,Condition 2.1—The emergency generator is generally tested at low or no load, therefore,the AP-42 emission factors are very conservative. Tri-State generally estimates emissions based on fuel usage which results in a more accurate estimate. However, it makes sense to use the hours of operations as a trigger to determine if an APEN or permit is required.Please change the language to allow for the use of,new,model-specific or fuel based emission factors to calculate emissions by changing the language for Paragraph 1 as follows: "If hours of operation exceed 73 hours in a calendar year,the permittee shall determine if an APEN(hall is required to be filed for this engine and if so shall file an APEN. Please change paragraph 2 to read: "If hours or operation exceed 250 in any annual period,the permittee shall determine if the construction permit exemption level in Colorado Regulation No.3,Part B, Section II.D.1.c.(ii)will be has been exceeded and if so the permittee..." Page 24, Section II,Condition 3.1—Similar to the changes requested to Condition 2.1 above,the emergency fire pump engine also is tested at low to no load. Please change the condition to read: "...If hours of operation"If hours or operation exceed 199 hours in a calendar year,the permittee shall determine if an APEN(hall is required to be filed for this engine and if so shall file an APEN." "If hours or operation exceed 994 in any annual period,the permittee shall determine,if the construction permit de minimis level in Colorado Regulation No.3,Part B, Section II.D.l.c.(iii)will be has been exceeded and if so the permittee..." Page 27, Section II,Condition 4.4, Sentence 2—Please add the shaded text to this sentence: "are operated and maintained in accordance with manufacturers' recommendations,if any,and good engineering practices." Page 27, Section II,Condition 5.1.1.1.b-Please add the shaded text to this sentence: "Annual CO monitor relative accuracy(RA)testing will be performed in ppm @ 15%O2(ppmvdc)measurement units..." Page 28, Section II,Condition 5.1.1.2.a—Please add the shaded text to this sentence: "Annual NOx monitor RA testing will be performed in ppm @ 15%O2(ppmvdc)measurement units..." Page 28, Section II,Condition 5.1.13.a—Please change the text to read: The RATAs shall be conducted in the units(e.g., lb/MMBtu,ppm)of the emission limitation for all of the for emission units that have short term concentration emission limitations will be conducted in measurement units that are applicable to the emissions unit. (e.g.,lbIMMBtu,ppmvdc).that are applicable to the emissions unit. The RATAs for emissions units that have annual short term mass emission limitations(tons/yr lbs/event)will be conducted in terms of pounds per hour(lb/hr). Page 28, Section II,Condition 5.1.1.3.b-Please change the text to this sentence: "The DAHS shall be able to record and manipulate the data in the units (e.g., lb/MIVIBtu,ppmvdc )of the emission limitation..." l Page 28, Section II,Condition 5.1.2,Last Paragraph—Please change the language as follows: "The quality assurance/quality control plans shall be made available to the Division upon request.Revisions shall be made to the plans at the requests of the Division." Tri-State will make revisions to the QA/QC plans that are required by regulation or that are otherwise necessary,but this language is overly broad and appears to remove any allowance for negotiating changes. Page 29, Section II,Condition 5.2.1,Sentence 1—Because there is no continuous opacity monitoring system at the JM Shafer station,please change the language as follows: The permittee shall ensure that all continuous emission monitoring systems required are in operation and monitoring unit emissions er opacity at all times that the affected units combust any fuel except for monitoring system..." Page 29,Section II,Condition 5.2.3-Please change the first sentence to add the following: "Other than"like kind"monitor replacement alternative monitoring systems..." Please change the last sentence to read:"Any alternative continuous emission monitoring systems er continuous opacity monitoring systems must be certified..." There are no continuous opacity monitoring systems at the JM Shafer Station. Page 31,Section II,Condition 5.5.2—Because the highest reading recorded during the previous 30 day period could likely result in significant overestimation of emissions we propose that that the procedures in 40 CFR Part 75 Subpart D for SO2 be used for data replacement for CO and that the condition be changed bP r_ _...� _._ ems._-. as follows: "For CO,theprocedures u 40 CFR Part 75ySubpartDD for SO2 shall be rased For CO,the highest reading recorded during the previous 30 day period shall be used(Colorado Construction Permit 91WE667). Technical Review Document Page 1,Section L Paragraph 1,Sentence 4—The word"off'after the regulatory citation appears to be inadvertent and should be deleted: "Colorado Regulation No. 3,part C, Section IV.C eff the terms..." Page 2,Section II,Paragraph 1,Sentence 1 - The SIC code for the facility is listed as 4931 and should be 4911 as indicated in the permit. Page 2,Section II. Paragraph 1,Sentence 4—Each turbine/duct burner package is only equipped with one duct burner,so the"s"on"duct burners"should be deleted: "Exhaust gas from the combustion turbine,which may be heated further by's duct burners..." Page 8,Section III,Source Requested Modifications,Section II.1—Combustion Turbines, Paragraph 1,last sentence,and paragraph 2, Sentence 2—In two places the tuning and testing hours limit is indicated as equivalent to 30 hours/year/turbine. As the permit only includes the 150 hours per year limit and there is no hourly limit that applies on an individual turbine basis,to avoid confusion the following wording changes are requested: (this would equates to a limit of 30 hours per year per turbine assuming all_five turbines undergo tuning aid testingin the same year) (150 hour per year(er the equivalent of 30 hours per year per turbine if all five._turbines undergo tuning and testing in the same year),which) Page 13, Section III,Other Modifications,Section I—General Activities and Summary,Bullet 1— The word"regarding"is misspelled. Page 16,Section III,Other Modifications,Section II.7-Cold Cleaner Solvent Vat,Sentence 1— This sentence appears to be missing some words. The following revision is suggested: "DuringA a review of the insignificant activities at this facility,it became apparent that there is a solvent cold cleaners located at the facility. CI4 TRI-STATE GENERATION AND TRANSMISSION ASSOCIATION, INC. HEADQUARTERS: P.O. BOX 33695 DENVER, COLORADO 80233-0695 303-452-6111 December 17, 2015 Ms. Jackie Joyce —Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SSP-B 1 4300 Cherry Creek Drive South Denver,CO 80246-1530 RE: Air Pollutant Emission Permit/APEN Cancellation Requests Tri-State Generation and Transmission Association,JM Shafer Generating Station Permit No. 95OPWE096 Dear Ms.Joyce: Enclosed are two Emission Permit/Air Pollutant Emission Notice(APEN)cancellation requests for the emergency generator and emergency fire pump located at JM Shafer Generating Station. JM Shafer is owned by Thermo Cogeneration Partnership,LP,a wholly owned subsidiary of Tri-State Generation and Transmission Association,Inc. The Emission Permit/APEN cancellation requests for units S006 and S007 are being submitted because the potential to emit(based on 500 hours of operation annually)for each unit is below the significance threshold for each criteria pollutant,and the actual uncontrolled emissions for each unit is below one ton per year for each criteria pollutant. An APEN is not required for sources in nonattainment areas that have uncontrolled emissions of any criteria pollutant less than one ton per year for which the area is nonattainment, and uncontrolled actual emissions of any criteria pollutant in an attainment area of less than two tons per year in accordance with Section II.B.3.a of Part A,Reg 3,which is the case for each of these units. In addition, a construction permit is not required for emergency power generators that operate no more than two hundred and fifty hours per year(S006) in accordance with Section ll.D.1.c.(ii) of Part B,Reg 3, and a construction permit is also not required for stationary internal combustion engines that have uncontrolled actual emissions less than five tons per year(S007) in accordance with Section ll.D.1.C.(iii)of Part B,Reg 3. If you have any questions,please contact Daniel Salgado at 303-452-6111. Sincerely, 'it // Barbara A. Walz Senior Vice President Policy&Compliance Chief Compliance Officer BAW:DS:pvt Enclosures AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER CRAIG STATION ESCALANTE STATION NUCLA STATION P.O.BOX 1307 P.O.BOX 577 P.O.BOX 698 A Touchstone Energy°Cooperative CRAIG,CO 81626-1307 PREWITT,NM 87045 NUCLA,CO 81424-0698 970-824-4411 505-972-5200 970-864-7316 o *4; _,P): <-^ +1876 Colorado Department of Public Health and Environment Colorado Air Pollution Control Division EMISSION PERMIT/APEN CANCELLATION REQUEST Permit Number 95OPWE096 and/or AIRS ID: 123-0250-007 Source or Equipment Name: Diesel Fired Emergency Fire Pump Source or Equipment Address: 6811 Weld County Rd, Ft. Lupton, CO This cancellation request is based on the following: Please circle the appropriate item. 1. The facility and/or source addressed by the permit or APEN no longer exists. 2. The facility has been sold to another party and I do not wish to transfer the permit. New owners name: New owners address: New owners phone number: 41) The emissions from the permitted source no longer is above the threshold required for maintaining an APEN or permit with the Division and the source does not want to maintain an active APEN or permit with the Division. 4. The APEN and/or permit were previously required solely because the emission unit was subject to NSPS or NESHAP requirements that were adopted into Colorado Regulations (see PS Memo 14-01 for more info). Cancellation request is for (check appropriate boxes) ❑ APEN ❑ Permit 5. Other: Date Equipment or Operations Ceased/Sold or Below Reporting Thresholds: 12 /31 / 14 Thermo Cogeneration Partnership,L.P. Company Name:A wholly owned subsidiary of Tn-State Generation and Transmission Association Phone Number:303-452-6111 Company Address: 1100 W. 116th Avenue City: Westminster State: CO Zip: 80234 t 12/ 172015 Signature of Legally Authorized Person Date Barbara A. Wail Sr.Vice President,Policy and Compliance/Chief Compliance Officer Print Name Title PLEASE RETURN COMPLETED FORM TO: CDPHE-Air Pollution Control Division APCD-SSP-B1 4300 Cherry Creek Dr.S. Denver,CO 80246-1530 For DepartmentUse'Only T �� _�{ -rte Sent to dministration Scanned h. 1876{ Colorado Department of Public Health and Environment Colorado Air Pollution Control Division EMISSION PERMIT/APEN CANCELLATION REQUEST Permit Number 95OPWE096 and/or AIRS ID: 123-0250-006 Source or Equipment Name: Diesel Fired Emergency Generator 6811 Weld County Rd, Ft. Lupton, CO Source or Equipment Address. This cancellation request is based on the following: Please circle the appropriate item. 1. The facility and/or source addressed by the permit or APEN no longer exists. 2. The facility has been sold to another party and I do not wish to transfer the permit. New owners name: New owners address: New owners phone number: ® The emissions from the permitted source no longer is above the threshold required for maintaining an APEN or permit with the Division and the source does not want to maintain an active APEN or permit with the Division. 4. The APEN and/or permit were previously required solely because the emission unit was subject to NSPS or NESHAP requirements that were adopted into Colorado Regulations (see PS Memo 14-01 for more info). Cancellation request is for(check appropriate boxes) ❑ APEN ❑ Permit 5. Other: Date Equipment or Operations Ceased/Sold or Below Reporting Thresholds: 12 /31 / 14 Thermo Cogeneration Partnership,L.P. 303-452-6111 Company Name: A wholly owned subsidiary of Tri-State Generation and Transmission Association Phone Number: Company Address: 1 100 W. 116th Avenue City. estminste State: CO Zip: 80234 14(47/.4, 12, 17/2015 Signature of Legally uthoriz Person Date Barbara A. WaIZ Sr.Vice President,Policy and Compliance/Chief Compliance Officer Print Name Title PLEASE RETURN COMPLETED FORM TO: CDPHE-Air Pollution Control Division APCD-SSP-B1 4300 Cherry Creek Dr.S. Denver,CO 80246-1530 For Department Use Only = Sent to 17[ j Administration Scanned;,;; �.[r] Inventory t ��. .11/9/2015 State.co.us Executive Branch Mail-RE:JM Shafer T5 permit rn. .;`7 '��tiS STATE OF '� S"fI • JCOLORADO Joyce-CDPHE, Jackie <jackie.joyce@state.co.us> RE: JM Shafer T5 permit Salgado, Dan <dsalgado@tristategt.org> Mon, Nov 9, 2015 at 10:59 AM To: "Joyce - CDPHE, Jackie" <jackie.joyce@state.co.us> Jackie, Thank you for your time this morning. Attached is the MSDS for the parts washer solvent that we use in the parts washer we have on site. The parts washer consists of a 35-gallon drum with a sink/sprayer mounted on top. It has an electric motor which pumps the fluid up into the sink/sprayer which has a lid. As you can see the VOC content of the fluid is listed at 0%. I have included answers to your questions as we discussed below in red. Please let me know if you have any additional questions. Thanks, Dan Dan Salgado O:303-254-3393/M: 303-349-7581 Privilege and Confidentiality Notice. The electronic message above contains information that should be treated as confidential or privileged. This message and any attached documents are intended only for the use of the individual(s)or entity to which they are addressed and may contain information that is privileged, confidential, and exempt from disclosure under applicable lain/. If you are not the intended recipient, be aware that any disclosure, copying,distribution or use of the contents of this message is prohibited. If you have received this electronic message in error, please notify us immediately by telephone at(303)-254-3393. From: Joyce - CDPHE, Jackie [mailto:jackie.joyce@state.co.us] Sent: Wednesday, October 28, 2015 12:49 PM To: Salgado, Dan Subject: JM Shafer T5 permit Dan, https://mail.google.com/mail/u/0/?ui=2&ik=4cf2986dc4&view=pt&search=inbox&msg=150ed67a5909906a&sim1=150ed67a5909906a 1/3 11/9/2015 State.co.us Executive Branch Mail-RE:JM Shafer T5 permit I have been working on the T5 renewal permit for JM Shafer and I have a few questions. If possible, please respond to these questions by Nov. 13, 2015. • Have any additional stationary internal combustion engines been installed at the facility that are not already identified in the Title V permit? If so, please indicate the dates each engine was manufactured, relocated into Colorado, commenced construction and commenced operation. In addition, if applicable, please provide the manufacturer, model and serial number, and design rating (hp and fuel consumption) for the engine(s). No additional stationary internal combustion engines have been installed at the facility that are not already identified in the Title V permit. • Our database indicates that an APEN has not been filed for the emergency fire pump. engine for some time. If actual, uncontrolled emissions are below the APEN de minimis level (1 tpy NOX), then an APEN is not required and the APEN and construction permit may be canceled. Note that the engine would still have to be included in Section II of the permit.The Division is not aware that an APEN/permit cancellation request has ever been received. It appears that this unit does qualify as APEN exempt, however, I'll run the calculations again using hours to double check. If the emissions based on hours look good I will complete a cancellation request and send it to you. • From previous email correspondence I believe you weren't going to file a revised APEN for the emergency generator as provided by Reg 3, Part A, Sections I I.C.1.g and/or h. If actual, uncontrolled emissions from the emergency generator are below the APEN de minimis level (1 tpy NOX), you may also be able to cancel the APEN and construction permit. This situation is a little different than the emergency fire pump engine, since Reg 3, Part A, Section II.D.3 says that an APEN must be filed for it but Reg 3 Part A, Section II.C.1.g says that a revised APEN does not need to filed - so depending on emissions, if APEN exempt, I will see if the APEN and construction permit can be cancelled. I'll run the calculations based on hours the same as the fire pump to see how that looks. If the numbers look good I'll also send a cancellation request for the emergency generator. • There is a gasoline pressurized water parts washer listed in the insignificant activity list. The following questions are related to that: - I assume this is powered by an internal combustion engine - is the engine a stationary engine or does it qualify as a non-road engine? If non-road, please explain (e.g. the unit is truck-mounted and taken around the site) This is a pressure washer that uses a small internal combustion engine to pressurize water and is used to wash down equipment. It is mounted on wheels and is used throughout the facility. - Since the facility is in an ozone nonattainment area, I want to make sure that the requirements in Reg 7, Section X do not apply. Based on the brief description, I don't think the Reg 7 requirements would apply but please confirm that is the case. While the pressurized water parts washer isn't subject to the requirements in Reg 7 we do have a parts washer as described above. However, as we discussed we use a non-VOC containing solvent so I'm not clear on whether Reg 7, Section X applies. • The renewal application states that the requested combustion tuning and testing limit for NOX is 100 ppm but the draft permit language lists it as 115 ppm. I was planning on including a NOX limit of 100 ppm - it seems more appropriate. Let me know if you have have any issues with that. I apologize for the confusion in the application. We are requesting a NOX limit of 115 ppm for the combustion tuning and testing limit. • I am changing the frequency of EER submittals to semi-annual to be consistent with NSPS since there is no other underlying requirement for quarterly EER submittals. If you prefer to keep submitting EERs quarterly, let me know. As I indicated in a separate email we would like to retain the quarterly submittal of the EERs. Jackie Joyce Permit Writer Operating Permit Unit, Stationary Sources Program httpsJ/mal.google.cam/mail/u/Onui=2&ik=4cf2986dc4&view=pt&smirch=inbox&ms�150ed67a5909906a&sim1=150ed67a5909906a 2/3 .11/9/2015 State.co.us Executive Branch Mail-RE:JM Shafer T5 permit CDPHE COLORADO CO % Air Pollution Control Division Department of Public Health&Environment P 303.692.3267 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246 Jackie.Joyce@state.co.us I www.ccloradc.gov/cdphe/apcd As of January 1, 2014, the Colorado Air Pollution Control Division no longer accepts blank or incomplete APENs. Additional fees may apply if an APEN is submitted without the necessary information. An application with missing information may result in longer processing times. Please note that all APEN submissions should be completed using forms currently supplied by the Division (See Reg. 3, Part A, Section II.A). Current APEN forms can be found at https://www.colorado.cov/cdohe/APENforms an Evergreen Solutions-Biosol Synthesol SDS.PDF 1052K https://mail.google.com/mail/u/0/?ui=2&ik=4cf2986dc4&view=pt&search=inbox&msg=150ed67a5909906a&simI=150ed67a5909906a 3/3 • • nor MATERIAL SAFETY DATA SHEET << N/E= Not Established N/AP= Not Applicable N/AV= Not Available >> SECTION I: MATERIAL IDENTIFICATION AND USE Material Name/ Identifier: SYNTHESOL SDS Material Intended Use: Synthetic Heavy Duty Degreasing Solvent TDG/DOT Classification: Not regulated Chemical Family: Synthetic Hydrocarbon (Non-distillate) Supplier's Name: EvergreerV olutions Inc. Address: 9606-40 Street SE City& Province: Calgary,Alberta T2C 2P3 Emergency Telephone: 1-800-610-5907 SECTION II: INGREDIENT DATA Ingredients: CAS No. LD>50 LC>50 Synthetic hydrocarbon mixture > 10,000 mg/kg oral, rat >1,000mg/I, fathead minnow, 96hr. > 1260 mg/kg dermal, rabbit > 0.9 mg/I, rat, inhalation 6hr* '(highest atmospheric concentration achievable) SECTION III: PHYSICAL DATA Physical State: Liquid Odour: Bubble gum Appearance: Colorless Odour Threshold: n/e Specific Gravity 0.88 Vapour Pressure:(psi @ 38°C.) <0.05 Viscosity(@ 3$"C.); 0.97 centistokes Evaporation rate•(H2O= 1) n/av Boiling Point:( C.) 251° Freezing Point: (oC) -10 Solubility in Water: Insoluble pH factor: n/ap Flash Point/Method:(°C.) 110 TCC VOC content(%): 0 SECTION IV: FIRE AND EXPLOSION HAZARD DATA Flammable: Yes: No: X Combustible: Yes: No: X If yes: -Lower Explosive Limit(%vol)component: n/ap -Upper Explosive Limit(% vol)component: n/ap -Means of Extinction: Foam,dry chemical or CO2 Special Fire Hazards: None SECTION V: REACTIVITY DATA Chemical Stability: Stable: X Unstable: Incompatibility to Other Substances? Yes: X No: If so, which ones? Strong oxidizing materials Hazardous Decomposition Products: n/av Hazardous polymerization: Will not occur /CONT'D a Alm trj L SYNTHESOL SDS, -MATERIAL SAFETY DATA SHEET- SECTION VI: TOXICOLOGICAL PROPERTIES Route of Entry: X Eye/Skin Contact X Skin Absorption X Ingestion X Inhalation Eye: May cause slight irritation,redness,watering. Skin: Prolonged contact may cause slight irritation. Ingestion: Nausea,vomiting, possible stomach cramps. Inhalation: Under normal use conditions this product is not an inhalation hazard. Cardnogenicity: nlap Mutagenicity: n/ap Ecological Information: This product was evaluated for biodegradation in the natural water microcosms and shake flask carbon dioxide evolution assay. The shake flask study indicated that this product Is biodegraded in natural water,and continues to complete mineralization under aerobic conditions. SECTION VII: PRECAUTIONS FOR SAFE HANDLING AND USE Protective Handwear: Rubber gloves recommended Protective Eyewear: Safety glasses or goggles recommended if risk of eye contact Other protective equipment: As required by employer code Respiratory Apparatus: Not required under normal use conditions Local/mechanical exhaust: Not required Work/hygienic practices: As required by employer code Leak or Spillage: Floors may be slippery. Avoid falls. Absorb with sand,towel or mop. Place in suitable container. Prevent large spills from entering waterways. Waste Disposal: Review federal,state or provincial regulations prior to disposal. Storage and Handling: Store in closed container. Store away from incompatible materials. Other Precautions: When product is used in confined space, the use of proper ventilation is required. SECTION VIII: FIRST AID MEASURES Eyes: Remove contact lenses. Flush with water for 15 minutes. Skin: Wash with soap and water. Call physician if irritation develops. Launder clothing before re-use. Ingestion: If swallowed,call a physician. Do not induce vomiting. Drink large quantities of water to dilute. Inhalation: Remove to fresh air. SECTION IX: ADDITIONAL INFORMATION IlMIS Ratfna Information for this Material Safety Data Sheet was prepared from sources considered Health: I reliable. While every effort has been made to ensure full disclosure of product hazards, Flammability: 0 data is not available in some cases and is so stated where applicable. The manufacturer Reactivity: 0 assumes no liability or responsibility, and no warranty is expressed or implied, in cases PPE: B where products are mishandled, misused or instructions are not strictly observed. Each recipient of this MSDS is encouraged to study it carefully to fully understand this product. WHMI S N/A SECTION X: PREPARATION INFORMATION Prepared by: Telephone: Date: Replaces: Evergreen Solutions 1-800-610-5907 01-JAN-04 01-JAN-03 TRI-STATE GENERATION AND TRANSMISSION ASSOCIATION, INC. HEADQUARTERS: P.O. BOX 33695 DENVER, COLORADO 80233-0695 303-452-6111 March 31, 2015 $ Ms.Jacqueline Joyce Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 RE: Operating Permit Minor Permit Modification Application for JM Shafer Generating Station Permit Number 95OPWE096 Dear Ms. Joyce: Tri-State Generation and Transmission Association,Inc(Tri-State) is submitting a minor permit modification application requesting clarifying wording changes to JM Shafer Generating Station, Operating Permit 95OPWE096. The requested changes are the result of Tri-State's review of the Station's operations and records,the meeting to discuss the permit with you and other Division personnel, and subsequent phone conversations with you. The requested wording changes meet the criteria for use of the minor permit modification procedures in Regulation 3,Part C, Section X, and it is requested that those procedures be used for this permit modification. If you have any questions concerning this renewal application,please contact Dan Salgado at 303-452-6111. Sincerely, Barbara A. Walz Senior Vice Presiden Policy and Compliance Chief Compliance Officer BAW:DPS:pvt Enclosure L;L ^a=; 2 : ;, 'j 2 !t' �::.:.','cth� a'c CRAIG STATION ESCALANTE STATION NUCLA STATION `_ P.O.BOX 1307 P.O.BOX 577 P.O.BOX 698 A Touchstone Energy'Cooperative i CRAIG,CO 81626-1307 PREWITT,NM 87045 NUCLA,CO 81424-0698 970-824-4411 505-972-5200 970-864-7316 MINOR PERMIT MODIFICATION APPLICATION TRI-STATE GENERATION & TRANSMISSION ASSOCIATION, INC. JM SHAFER GENERATING STATION OPERATING PERMIT No. 95OPWE096 PERMIT CLARIFICATIONS Tri-State Generation &Transmission Association, Inc. 1100 W. 116th Avenue Westminster, Colorado 80234 March 31, 2015 1.0 INTRODUCTION This minor permit modification application for the JM Shafer Station is submitted to request clarifying revisions to Operating Permit 95OPWE096.Tri-State Generation&Transmission Association,Inc. (Tri-State) conducted a detailed review of Station operations,records,and historic permits to understand and ensure compliance with Operating Permit 95OPWE096. Interviews were conducted with long-time Station employees and with Kevin Lewis,Air Sciences,Inc.,who provided air quality permitting and compliance assistance to the facility dating back to the original construction permit application. The review identified a need to more fully describe the facility emission units and operations in Operating Permit 95OPWE096,to synchronize terminology used at the Station and in the permit,and to clarify some of the requirements in the permit. This application is submitted to request those revisions. No increase in emission or operating limits nor any changes to existing monitoring,recordkeeping,or reporting conditions-are requested. The following sections of this document provide a description of the Station's configuration and operation to provide context for the permit revisions, a listing of the requested permit changes,and a demonstration that the, requested changes meet the requirements for use of the minor permit modification provisions. Operating Permit application forms and copies of the Station's most recent APENs are provided in Appendix A. Supporting documentation is provided in Appendix B. 2.0 STATION CONFIGURATION AND OPERATION The primary emission units at the JM Shafer Generating Station are five combustion turbine/duct burner packages. Each of the combustion turbine/duct burner packages exhausts to a separate stack equipped with continuous emissions monitoring systems for oxides of nitrogen(NO,)and carbon monoxide(CO). Six General Electric LM6000 natural gas-fired combustion turbines are used in the five turbine/duct burner packages. A maximum of five combustion turbines can be in the packages at any one time,with the sixth turbine either off site for maintenance or stored at the Station as a spare. The combustion turbines are not assigned to a particular turbine/duct burner package,but are moved among the packages as turbines are removed for maintenance and returned to operation. A July 17,2008 letter from Thermo Cogeneration Partnership,L.P.,the owner of the Station at that time,to Matthew Parks,CEM Coordinator,Field Services Section,Colorado Department of Public Health and Environment(see Appendix B), sent following an inspection and a request for information from Mr.Parks, describes this operation of the turbine/duct burner packages and provides tables showing the location of the combustion turbines in the packages from original operation through the date of the letter. A construction permit(91WE667,PSD,Initial Approval,Modification-1)was issued on July 26, 1996. This permit applied to the five original LM6000 combustion turbines and to replacement turbines placed into service as part of normal maintenance practices,provided the replacement turbines operated in full compliance with the conditions of the permit. Records of the use of replacement turbines was required. Kevin Lewis,Air Sciences,Inc.,was consulted to provide a history of turbine maintenance replacement practices and • compliance with the associated permit conditions(see Appendix B). Station turbine replacement records were reviewed and show that several leased turbines were used as maintenance replacement turbines through January 1999. After that time,the same six turbines,the original five LM600 combustion turbines and a sixth turbine purchased for use as a maintenance replacement turbine, have been used. A review of Air Pollutant Emission Notices and air quality reports show that submissions have been on a per package basis rather than an individual combustion turbine basis. 1 3.0 REVISED PERMIT CONDITIONS Station personnel refer to each of the turbine/duct burner units as a"package." In the permit conditions in Operating Permit 95OPWE096, differentiation between the turbine/duct burner packages and the individual LM6000 combustion turbines is not always clear. In addition,the serial number for the sixth turbine is not included,nor is there a condition requiring tracking of the movement and use of the turbines. The following permit condition additions and revisions are requested to more fully reflect Station operations, synchronize the terms used at the Station with those used in the permit,and to clarify the condition that apply to the turbine/duct burner packages. . Additions are shown in bold italic. Page 1 SECTION I- General Activities and Summary 1. Permitted Activities 1.1 This facility consists of a cogeneration facility defined under Standard Industrial Classification 4911. Electricity for sale is produced by five (5) combustion turbin nipped ni-duct burn oCneratell! an one act,tiknee pa ages,Amapmum,of live com-bus&on jurbines.cane oper eat p. Each combustion turbine serves a generator rated at 57.412 MW (name-plate), however each turbine only generates enough horsepower to produce about 37 MW. Exhaust gas from the combustion turbine, which may be heated further by duct burners, is used to either generate electricity or to heat a nearby greenhouse. There are two steam turbines, each rated at 52.220 MW (name-plate). Other significant emission units at the facility are a cooling tower, emergency back-up generator and fire pump. Page 5 SECTION I-General Activities and Summary 6. Summary of Emission Units 6.1 The emissions units regulated by this permit are the following: Emission AIRS Facility Description Startup Date Pollution Unit Stack Identifier Control Device Number Number S001- 001-005 G001- Five(5) tin r b i.n e/d u c tt burner packages, May 1994 Steam Injection S005 G005 S'ix' (6) General Electric LM6000 Natural Gas Technology Combustion Turbines,Rated at 400 MMBtu/hr (Turbines) (HHV)Each,SN's: 185-130, 185-126, 185-135, 185-136&-185-137, p1:d 185-238, quipped with Five (5) Coen 12408-1 Duct Burners,Two(2)Rated at 240 MMBtu/hr(HHV)and Three(3)Rated at 180 MMBtu/hr (HHV). S006 006 P006 One Detroit Diesel 8163-7416 Emergency Back-up May 1994 Uncontrolled Engine,Rated at 8.57 MMBtu/hr, SN:Unknown. S007 007 P007 One Clark DDFP-T6AT Emergency Diesel Fired May 1994 Uncontrolled Fire Pump,Rated at 2.28 MMBtu/hr, SN:Unknown SO 1l 009 POll One Custom Forced Draft Industrial Cooling Tower May 1994 Drift Equipped with Munters D15 Drift Eliminators. Eliminators 2 ' 7 Page 6 Section II—Specific Permit Terms 1. S001-S005 — ' 1 ^F>> f; Natural Gas Fired Turbines 16 -1 (400 MMBtu/hr (HHV) each) W/Duct Burners (2 @ 240 M1VIBtu/hr(SHY)and 3 @ 180 MMBtu/hr(HHV)) Page 9 1.2 Particulate Matter Emissions are subject to the following requirements: 1.2.1 Annual emissions of PM and PM,o from each turbine/duot burner �; y,_ ._.AND from all turbine/duct burner _ combined_ - r shall not exceed the limitations stated above (Colorado Construction Permit 91WE667). Emissions from each emission unit shall be calculated by the end of the subsequent month using the above emission factors(for turbine,from AP-42, Section 3.1 (dated April 2000), Table 3.1-2a, for duct burners, from manufacturer as indicated in September 13, 1991 memo from Nooter/Eriksen Cogeneration Systems, Inc.), the monthly natural gas consumption and the higher heating value of the fuel (see Condition 1.11)in the following equations Turbine: tons/month=(EF,lbs/MMBtu)x(Fuel Use,MMSCF/mo)x(Heat Content of Fuel,MMBtu/MMSCF) 2000 lbs/ton Duct Burner: tons/month=(EF,lbs/MMBtu)x(Fuel Use.MMSCF/mo)x(Heat Content of Fuel,MMBtu/MMSCF) 2000 lbs/ton Monthly emissions from each turbine and duct burner e <_ will be summed together and used in a twelve month rolling total to monitor compliance with the individual unit annual emission limitation. Each month a new twelve month rolling total shall be calculated using the previous twelve months' data. Monthly emissions from each turbine and duct burner °"": r •e will be summed together and used in a twelve month rolling total to monitor compliance with the annual emission limitation for all units combined. Each month a new twelve month rolling total shall be calculated using the previous twelve month's data. Page 10 1.2.2 Particulate Matter(PM)emissions from each turbine and each turbine/duct burner * a -e shall not exceed the above limitations (Colorado Regulation No. 1, Section III.A.1.b). In the absence of credible evidence to the contrary, compliance with the particulate matter emission limits is presumed since only pipeline natural gas that meets the requirement in Condition 1.10 is permitted to be used as fuel in the turbines and the duct burners. 1.3 Sulfur Dioxide(SO2)emissions shall not exceed the following limitations: 1.3.1 Annual emissions of SO2 from each turbine/duct burner on e AND from all turbine duct burner ices combined shall not exceed the limitations stated above (Colorado Construction Permit 91 WE667). 3 Compliance with the annual SO2 emission limitations shall be monitored using the monitoring method specified in 40 CFR 75 Appendix D. Monthly emissions from each turbine/duct burner imckage will be summed together and used in a twelve month rolling total to monitor compliance with the individual unit annual emission limitation. Each month a new twelve month rolling total shall be calculated using the previous twelve months' data. Monthly emissions from each turbine/duct burner iciin1 hoa;'p�acka a will be summed together and used in a twelve month rolling total to monitor compliance with the annual emission limitation for all units combined. Each month a new twelve month rolling total shall be calculated using the previous twelve months' data. Page 11 1.4 Nitrogen Oxide(NOX) emissions shall not exceed the following: 1.4.1 Annual emissions of NO„ from each turbine/duct burner on package AND from all turbine/duct burner Fombi afi no s pack ss combined shall not exceed the limitations stated above (Colorado Construction Permit 91WE667). Monthly emissions from each turbine/duct burner fide age shall be determined using the continuous emission monitoring system required by Condition 1.8. Monthly emissions from each turbine/duct burner Fombmatoa packa`%e shall be used in a twelve month rolling total to monitor compliance with the individual unit annual emission limitation. Each month a new twelve month rolling total shall be calculated using the previous twelve months' data. Monthly emissions from each turbine/duct burner Fra'binatiCiicliiiickeile will be summed together and used in a twelve month rolling total to monitor compliance with the annual emission limitation for all units combined. Each month a new twelve month rolling total shall be calculated using the previous twelve months' data. 1.4.2 For BACT purposes, NO„ emissions from each turbine/duct burner combination gZiargle shall not exceed the following limitations (Colorado Construction Permit 91WE667, as modified under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Sections I.A.7 and III.B.7 to include alternate BACT limits for periods of startup and shutdown): Page 13 1.5 Emissions of Carbon Dioxide(CO) shall not exceed the following limitations: 1.5.1 Annual emissions of CO from each turbine/duct burner combination package AND from all turbine/duct burner o s packages combined shall not exceed the limitations stated above(Colorado Construction Permit 91WE667). Monthly emissions from each turbine/duct burner combination package shall be determined using the continuous emission monitoring system required by Condition 1.8. Monthly emissions from each turbine/duct burner _ombmation package shall be used in a twelve month rolling total to monitor compliance with the individual unit annual emission limitation. Each month a new twelve month rolling total shall be calculated using the previous twelve months' data. 4 Monthly emissions from each turbine/duct burner i 4 will be summed together and used in a twelve month rolling total to monitor compliance with the annual emission limitation for all units combined. Each month a new twelve month rolling total shall be calculated using the previous twelve months' data. 1.5.2 For BACT purposes, CO emissions from each tarbine/duct burner tr , •, •• shall not exceed the following limitations (Colorado Construction Permit 91WE667, as provided for under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Sections IA.7 and IILB.7 to include alternate BACT limits for periods of startup and shutdown): Page 14 1.6 Volatile Organic Compound(VOC)emissions shall not exceed the following limitations: 1.6.1 Annual emissions of VOC from each turbine/duct burner combination package AND from all turbine/duct burner r combined shall not exceed the limitations stated above (Colorado Construction Permit 91WE667). Emissions from each emission unit shall be calculated by the end of the subsequent month using the above emission factors (for turbines and duct burners, from turbine manufacturer, the November 1997 performance test indicates emissions from both the turbine alone and the turbine and duct burner together are well below this emission factor), the monthly natural gas consumption and the higher heating value of the fuel (see Condition 1.11)in the equations in Condition 1.2.1 of this permit. Monthly emissions from each turbine/duct burner 3-rq,t ; will be summed together and used in a twelve month rolling total to monitor compliance with the individual unit annual emission limitation. Each month a new twelve month rolling total shall be calculated using the previous twelve months' data. Monthly emissions from each turbine/duct burner `� " � _ will be summed together and used in a twelve month rolling total to monitor compliance with the annual emission limitation for all units combined. Each month a new twelve month rolling total shall be calculated using the previous twelve months' data. 1.6.2 For BACT purposes, VOC emissions from each turbine/duct burner 'rift" - _, shall not exceed 3.63 lbs/hr(Colorado Construction Permit 91WE667). In the absence of credible evidence to the contrary, compliance with the VOC BACT limit is presumed provided that the turbines and duct burners are operated and maintained in accordance with manufacturer's recommendations and good engineering practices and that the natural gas used as fuel meets the requirement in Condition 1.10. Page 17 1.14 Each turbine/duct burner � 'm' "�aefaeu�pac�iige is subject to the Title IV Aid Rain Requirements. As specified in 40 CFR Part 72.72(b)(1)(viii), the acid rain permit requirements shall be a complete and segregable portion of the Operating Permit. As such the requirements are found in Section III of this permit. IS, i"e ittee-T han maintain records a f the a ui each.tutvb�ianelduct C at a first a .curtenort a and to ioperaton . , t ble atr heteConstrucrian prm"ttA'Eb6 . , 5 APPENDIX B Reporting Requirements and Definitions Page 5 Monitoring and Permit Deviation Report—Part I FACILITY NAME: Thermo Cogeneration Partnership,L.P.-TM Shafer Generating Station OPERATING PERMIT NO: 95OPWE096 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates). Deviation Noted Deviation Malfunction/ During Period?' Code2 Emergency Condition Operating Reported During Permit Unit Period? lD Unit Descr ption YES NO YES I NO S001-S005 Five(5) a=btia uci` z'flier pc iuges'°Siz U General Electric LM6000 Natural Gas Combustion Turbines,Each Rated at 296 MMBtu/hr, Serial Nos. 185-130, 185-126, 185-135, 185-136, -185-137, ad WA and Five(5)Coen 12408-1 Duct Burners,Two(2)Rated at 240 MMBtu/hr, Each and Three(3)Rated at 180 MMBtu/hr,Each. The Turbines are Equipped with Steam Injection for NOx Control. S006 One(1)Detroit Diesel,Diesel Fired Internal Combustion Engine,Model No. 8163-7416,Rated at 8.57 MMBtu/hr,Serial No.Unknown.Emergency Generator. S007 One(1)Clark,Model No.DDFP-T6At,Diesel Fired Internal Combustion Engine,Rated at 2.28 MMBtu/hr,Serial No.Unknown. Emergency Fire Pump. SO11 One Custom Forced Draft Industrial Cooling Tower Equipped with Munters D15 Drift Eliminators. General Conditions Insignificant Activities 'See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation has occurred shall be based on a reasonable inquiry using readily available information. 2Use the following entries as appropriate: 1=Standard: When the requirement is an emission limit or standard 2=Process: When the requirement is a production/process limit 3=Monitor: When the requirement is monitoring 4=Test: When the requirement is testing 5=Maintenance: When required maintenance is not performed 6=Record: When the requirement is recordkeeping 7=Report: When the requirement is reporting 8=CAM: A situation in which an excursion or exceedance as defined in 40 CFR Part 64(Compliance Assurance Monitoring(CAM Rule)has occurred. 9=Other: When the deviation is not covered by any of the above categories 6 ' r 4.0 MINOR PERMIT MODIFICATION REQUIREMENTS Table 1 is provided to demonstrate that the requested permit changes meet the requirements of the minor permit modification provisions. Table 1. Minor Permit Modification Requirements Operating Permit Minor Modification Requirements - Regulation 3,Part C, Section LA Subsection Requirement Project X.A.1. Does not violate any applicable requirements The requested wording changes will not trigger any new applicable requirements and will not alter compliance with any existing applicable requirement. X.A.2. Does not involve significant changes to existing No changes to existing monitoring,reporting,or monitoring,reporting,or recordkeeping recordkeeping requirements are requested. requirements in a permit X.A.3. Does not require or change a case-by-case No changes to emission limitations or standards are determination of an emission limitation or other requested. The requested revisions are not associated standard or a source-specific determination for with temporary sources. No changes to visibility or temporary sources of ambient impacts,or a increment analyses are requested. visibility or increment analysis X.A.4. Does not seek to establish or change a permit term The requested changes do not seek to establish or or condition for which there is no corresponding change a permit term or condition assumed to avoid underlying applicable requirement and that the an applicable requirement to which the source would source has assumed to avoid an applicable otherwise be subject. requirement to which the source would otherwise be subject. X.A.5. Is exempted from the definition of modification in See next section of this table. Part C,Section I.A.3 of Part C. X.A.6. Is not otherwise required by the Division to be See last section of this table processed as a significant modification. Operating Permit Definition of Permit Modification - Regulation 3, Part C, Section I.A.3 I.A.3. Any revision that cannot be accomplished under Requested changes do not meet this definition as they the administrative permit amendment procedures qualify for the minor modification procedures of in Section III.of Part A or the minor modification Section X of Part C. See other sections of this table. procedures in Section X of Part C. _ Operating Permit Definition of Permit Modification - Regulation 3, Part C, Section I.A.7 I.A.7.a. Any change that causes a significant increase in The requested revisions will not cause an increase in the rate of emissions as described by any permit the rate of emissions described by any permit term or term or condition. condition. I.A.7.b. Any change that is considered a modification The requested revisions are not a modification under under Title I of the Federal Act. Title I. I.A.7.c. Any change that requires or changes a case-by- The requested revisions do not trigger the need for or case determination of an emission limitation or change a case-by case determination of an emission other standard. limitation or other standard. I.A.7.d. Any change that requires or changes a source- The requested revisions are not associated with a specific determination for temporary sources of temporary source. ambient impacts. I.A.7.e. Any change that requires or changes a visibility or No changes to visibility or increment analyses are increment analysis. required. I.A.7.f. Every significant change in existing monitoring No changes to monitoring permit terms or conditions permit terms or conditions. are requested. 7 Table 1. Continued Requirements for Minor Permit Modification Application-Operating Permit Definition of Modification - Regulation 3, Part C, Section I.A.7 (continued) I.A.7.g. Every relaxation of reporting or record keeping No relaxation of reporting or recordkeeping permit permit terms or conditions. terms or conditions is requested. I.A.7.h. Every change that seeks to establish or change a The requested changes do not seek to establish or permit term or condition for which there is no change a permit term or condition assumed to avoid corresponding underlying applicable requirement an applicable requirement to which the source would and that the source has assumed to avoid an otherwise be subject. applicable requirement to which the source would otherwise be subject. Requirements for Minor Permit Modification Application - Regulation 3, Part C, Section X.D X.D. Signature of Responsible Official. Provided in cover letter. X.D.1. Description of the change,the emissions resulting The requested revisions are described in Section 2 of from the change,and any new applicable this application. There are no emissions resulting requirements that will apply if the change occurs. from the requested revisions. No new applicable requirement will apply as a result of the requested revisions. X.D.2. Suggested draft permit. Provided in Section 2 of this application. X.D.3. Certification by a responsible official that the Provided in cover letter. proposed modification meets the criteria for use of minor permit modification procedures and a request that such procedures be used. X.D.4. Completed forms supplied by the Division. Provided in Appendix A X.D.5. Data necessary to allow the Division to determine The requested revisions do not trigger or change the whether the source complies with all applicable applicability of any emissions control or luwardous emission control regulations,applicable air pollutant control requirements. No changes to regulations for the control of hazardous air emissions are associated with the requested revisions, pollutants,the requirements of the nonattainment so the requirements of the nonattainment and and attainment programs(Sections V. and VI.of attainment programs do not apply and there will be Part D),and any applicable ambient air quality no impacts to ambient air. standards. X.D.6. Copies of APEN(s)on file with the Division,or,if Provided in Appendix A. APEN(s)have not been previously filed,a new APEN(s)shall be submitted. 8 �' �' .� xS •- ta; ,. w.-8� ..".""�r- ter•''` hg't: "z,rr�+ M APPENDIX A FORMS Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 `Colorado Department of Health 09-94 Air Pollution Control Division Facility Name: JM Shafer Generating Station Facility Identification Code: CO 1230250 I. ADMINISTRATION 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 Site Descriptions II. EMISSIONS SOURCE Total Number DESCRIPTION of This Form This application contains the following forms (one form for each facility boiler,printing ❑ Form 2000-200,Stack Identification operation,etc.): ❑ Form 2000-300,Boiler or Furnace Operation O Form 2000-301,Storage Tanks ❑ Form 2000-302,Internal Combustion Engine O Form 2000-303,Incineration ❑ Form 2000-304,Printing Operations O Form 2000-305,Painting and Coating Operations ❑ Form 2000-306,Miscellaneous Processes ❑ Form 2000-307,Glycol Dehydration Unit III. AIR POLLUTION CONTROL Total Number SYSTEM of This Form This application contains the following forms: ❑ Form 2000-400,Miscellaneous ❑ Form 2000-401,Condensers ❑ Form 2000-402,Adsorbers ❑ Form 2000-403,Catalytic or Thermal Oxidation ❑ Form 2000-404,Cyclones/Settling Chambers ❑ Form 2000-405,Electrostatic Precipitators ❑ Form 2000406,Wet Collection Systems ❑ Form 2000-407,Baghouses/Fabric Filters IV. COMPLIANCE Total Number of This Form DEMONSTRATION This application contains the following forms ❑ Form 2000-500,Compliance Certification-Monitoring and (one for each facility boiler,printing operation, Reporting etc.): ❑ Form 2000-501,Continuous Emission Monitoring ❑ Form 2000-502,Periodic Emission Monitoring Using Portable Monitors O 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 El Form 2000-508,Other Methods V. EMISSION SUMMARY AND Total Number COMPLIANCE CERTIFICATION of This Form ' This application contains the following forms quantifying emissions,certifying compliance O Form 2000-600,Emission Unit Hazardous Air Pollutants with applicable requirements,and developing a compliance plan ❑ Form 2000-601,Emission Unit Criteria Air Pollutants ❑ Form 2000-602,Facility Hazardous Air Pollutants ❑ Form 2000-603,Facility Criteria Air Pollutants ❑ Form 2000-604,Applicable Requirements and Status of Emission Unit ❑ Form 2000-605,Permit Shield Protection Identification I ❑ Form 2000-606,Emission Unit Compliance Plan- Commitments and Schedule ❑ Form 2000-607,Plant-Wide Applicable Requirements ❑ Form 2000-608,Plant-Wide Compliance Plan- Commitments and Schedule VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and,based on information and belief formed after reasonable inquiry,I certify that the statements and information contained in this application are true, accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS -FEDERAL/STATE CONDITIONS (check one box only) ® I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. n I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements,except for the following emissions unit(s): (list all non-complying units) WARNING: Any person who knowingly,as defined in§ 18-1-501(6),C.R.S.,makes any false material statement,representation,or certification in,or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of§25-7122.1,C.R.S. Printed or Typed Name Title Barbara A.Walz Senior Vice President,Policy and Compliance/Chief Compliance Officer g Sign Signed / Operating Permit Application CERTIFICATION FOR STATE-ONLY CONDITIONS FORM 2000-800 Colorado Department of Health 09-94 Air Pollution Control Division Facility Name: 3M Shafer Generating Station Facility Identification Code: CO_1230250 VI. SIGNATURE OF RESPONSIBLE OFFICIAL- STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and,based on information and belief formed after reasonable inquiry,I certify that the statements and information contained in this application are true, accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE-ONLY CONDITIONS (check one box only) ® I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. ❑ I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements, except for the following emissions unit(s): (list all non-complying units) WARNING: Any person who knowingly,as defined in§ 18-1-501(6), C.R.S.,makes any false material statement,representation,or certification in,or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of§ 25-7122.1, C.R.S. 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O. ° z. 0) (J O C. .p fn W 2 ¢ a) o N D O S m N •p co c U 0 b coo O t N Q 0 0 'D : 6 Z ) - o 2UJ UJ m a) en 0 m �, O ' Q t Ill a m rn E V <` \ To- < N 9 _ C a°ii ¢ Z .. .4 c. —• �o ° c m c`o • a co 0 O o 2 E C c cA co W N flj Z U •o ¢ V.0 yi ° 'O N E a) J C Q v — 0 ° O ai Ea c o m Ei a�i Z o c 1: ° o✓ E a) E rj 9 .O E € aciaaw 0 0 0 u) mz ti • APPENDIX B Supporting Documentation THERMO COGENERATION PARTNERSHIP, L.P. 681 1 WELD COUNTY ROAD 31 P.O. Box 208 FORT LUPTON, CO 80621 Vo►cE: (303)857-8040 FAX: (303) 857-8058 July 17,2008 Sent Via E-Mail:mjparks@smtpgate.dphe.state.co.us Matthew Parks CEM Coordinator,Field Services Section Colorado Department of Public Health and Environment APCD-SS-B1 4300 Cherry Creek South Drive Denver,CO 80246 Subject Response to Inspection Items,Thermo Ft. Lupton Cogeneration Partnership, L.P.,Ft. Lupton Cogeneration Station Dear Mr. Parks: Thermo Ft.Lupton Cogeneration Partnership,L.P.,Ft.Lupton Cogeneration Station (Thermo Ft. Lupton) is pleased to provide the below responses to your June 3,2008,e- mail. Each inspection item from your e-mail is restated herein followed by our response. 1. Section I, Condition 2.1.2 of the Operating Permit requires the facility to notify the Division and submit a revised APEN within 30 days of a temporary turbine replacement resulting in a serial number change. Records provided by the facility indicate that nine such temporary replacements were performed between 1994 and the present without the required Division notification. Thermo Ft.Lupton believes it has complied with all APEN notifications regarding to routine turbine replacement. The notification requirements are stated in our operating permit under Alternative Operating Scenarios. APEN notification requirements for turbine replacements were first introduced in Operating Permit No. 95OPWE096,issued January 1,1999. The requirements were later changed when this operating permit was renewed on October 1,2006. The requirements of these two permits are provided below: 95OPWE096,issued January 1,1999: 2.1.Turbine Replacement The following AOS may be incorporated into a permittee's operating permit in order to deal with a turbine breakdown or periodic routine maintenance and repair which requires the use of either a temporary or permanent replacement turbine. Note that the compliance Mr.Matthew Parks July 17,2008 Page 2 of 15 demonstrations made as part of this AOS are in addition to any compliance demonstrations required by the permit. 2.1.1.The permittee may replace an existing turbine provided such replacement turbines are GE LM6000 combustion turbines. 2.1.2.Replacement turbines 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. 2.1.3.The permittee shall maintain a log on-site to contemporaneously record the date of any turbine replacement and the manufacturer,model number,and serial number of the turbine(s) • that are replaced during the term of this permit and the manufacturer,model number,and serial number of the replacement turbine. All records related to any testing shall be maintained on-site for five(5)years and made available to the Division upon request 2.1.4.An Air Pollutant Emissions Notice(APEN)(that includes the specific manufacturer, • model and serial number of the permanent replacement turbine)shall be filed with the Division for the permanent replacement turbine within 14 calendar days of commencing operation of the replacement The APEN shall be accompanied by the appropriate APEN filing fee and a cover letter explaining that the permittee is exercising an alternative operating scenario and is installing a permanent replacement turbine. 95OPWE096,issued October 1,2006: 2.1 Routine Turbine Component Replacements I � 2.1.1 The following physical or operational changes to the turbines in this permit are not considered a modification for purposes of NSPS GG,NSR/PSD,or Regulation No.3: 2.1.1.1 Replacement of stator blades,turbine nozzles,turbine buckets,fuel nozzles,combustion chambers,seals,and shaft packings,provided that they are of the same design as the original. 2.1.1.2 Changes in the type or grade of fuel used,if the original gas turbine installation,fuel nozzles,etc.were designed for its use. 2.1.1.3 An increase in the hours of operation(unless limited by a permit condition). 2.1.1.4 Variations in operating loads within the turbine design specification. 2.1.1.5 Any physical change constituting routine maintenance,repair or replacement 2.1.2 Turbines undergoing any of the above changes 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 if replacement of any of the components listed in Conditions 2.1.1.1 or 2.1.15 above results in a change in serial number for the turbine,a letter explaining the action as well as a revised APEN and appropriate filing fee shall be submitted to the Division within 30 days of the replacement • 2.1.3 Note that the repair or replacement must be genuinely the same design.Except in accordance with the Alternative Operating Scenario set forth below,the Division does not consider that this allows for the entire replacement(or reconstruction)of an existing turbine with an identical new one or one similar in design or function.Rather,the Division considers the repair or replacements to encompass the repair or replacement of components at a turbine with the same(or functionally similar)components. 2.2 Temporary Turbine Replacement Mr. Matthew Parks July 17,2008 Page 3 of 15 The following AOS is incorporated into this permit in order to deal with a turbine breakdown or periodic routine maintenance and repair of an existing onsite turbine that requires the use of a temporary replacement turbine. "Temporary"is defined as in the same service for 270 operating days or less in any 12 month period. The 270 days is the total number of days that the turbine is in operation.If the turbine operates only part of a day,that day counts towards the 270 day total. Note that the compliance demonstrations made as part of this AOS are in addition to any compliance demonstrations required by this permit. 2.2.1 The permittee may temporarily replace an existing permitted turbine provided such replacement turbines are General Electric,Model No.LM6000 combustion turbines without modifying this permit,so long as the emissions from the temporary replacement turbine comply with the emission limitations for the existing permitted turbine as determined below. In the absence of credible evidence to the contrary,data from the continuous emission monitoring systems(CEMS)shall be evidence of enforceable compliance or noncompliance of the replacement turbine with any short-term NOx and CO emissions limitations of the original turbine. For comparison with an annual NOx and CO emissions limit,data from the CEMS shall be used to calculate the actual NOx and CO emissions as set forth in this permit. If the data from the CEMS indicates compliance with both the NOx and CO emission limitations,in the absence of credible evidence to the contrary,the source may certify that the turbine is in compliance with both the NOx and CO emission limitations for the relevant time period. If the CEMS data fails to demonstrate compliance with any of the NOx or CO emission limitations, and in the absence of credible evidence to the contrary,the turbine will be considered to be out of compliance for the relevant time periods(s). All data that indicates noncompliance shall be submitted to the Division within 14 calendar days after the data is collected. 2.2.2 Temporary replacement turbines 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. 2.2.3 The permittee shall maintain a log on-site to contemporaneously record the start and stop date of any temporary turbine replacement,the manufacturer and serial number of the turbine(s)that are temporarily replaced during the term of this permit,and the manufacturer and serial number of the replacement turbine. From January 1,1999,through September 30,2006,Thermo Ft. Lupton was required to submit an APEN for a"permanent"turbine replacement within 14 calendar days of commencing operation of the replacement. [950PWE096, issued January 1, 1999, Section I, Condition 2.1.4]. No APEN was required for temporary replacements. However,a log of all turbine replacements (temporary and permanent) during the term of the permit was required to be maintained. [950PWE096, issued January 1, 1999, Section I, Condition 2.1.3] Starting October 1,2006, (and to date)Thermo Ft. Lupton was no longer allowed to make permanent turbine replacements. Only temporary replacements were allowed. Consistent with the previous operating permit (950PWE096,issued January 1,1999), the renewal operating permit(950PWE096,issued October 1,2006) does not require APENs to be filed for temporary replacements. The renewal operating permit does,however, require an APEN filing if the"replacement of any of the components listed in Conditions 2.1.1.1 or 2.1.1.5 above results in a change in serial number for the [permanent] turbine" [emphasis added]. [95OPWE096, issued October 1, 2006, Section I, Mr.Matthew Parks July 17,2008 Page 4 of 15 Condition 2.1.21. In addition,the renewal operating permit requires that a log of the start and stop date of any temporary turbine replacement during the term of the permit be maintained. [95OPWE096, issued October 1,2006, Section I, Condition 2.2.31. A summary of the turbine replacement logs and the APEN filings from January 1,1999, (the issuance date of the first operating permit)to date is provided below: • • Mr. Matthew Parks July 17,2008 Page 5 of 15 Table 1: Turbine Replacement Log and APEN Filing for January 1, 1999,to Date Engines in Service Days (Package/No.)* Lease or L=GE-LM6000 Lease Unit Repair of Action Spare in ApEN A B CD E Spare Permanent Date Action** Service Date Configuration as of 12/31/98. See Table 2 L5 126 137 135p 238s I 130,136 1 Operating under 95OPWE096,issued January 1,1999(APEN required for permanent replacements) 136 130,135p 1/1/99 136 Return N/A 130 135p 1/13/99 130 Return L5:262 N/A 135p 130 8/18/99 135p Return N/A 130 238s 1/18/00 130 Return 238s:613 N/A 238s 135p 7/5/00 Temp.of 135p Not Req. 7/6/00 238p 135s 3/18/01 Perm.of 135p 2/14/01 135s 126 11/1/01 Temp.of 126 Not Req. 126 136 4/6/02 126 Return N/A 136 130 6/8/02 136 Return N/A 238p 7/18/02 N/A 130 7/27/02 130 Return 238p 137 7/29/02 238p Return N/A 137 238p 10/15/02 137 Return N/A 238p 137 10/29/02 238p Return N/A _ 137 238p 12/6/02 137 Return N/A 238E_ 136 1/17/03 238p Return N/A 136 130 2/27/03 136 Return N/A 130 135s 5/28/03 130 Return 135s:573 N/A 135s 130 10/6/03 Temp.of 130 Not Req_ 130 136 3/3/04 130 Return N/A 136- 135s 5/26/04 136 Return 135s:233 N A 135p 238s 1/21/05 Perm.of 238p 1/18/05 136 6/24/06 Not Req. 238s 6/25/06 Temp.of 136 238s 8/5/06 238s:41 N/A 136 8/14/06 136 Return Operating under 95OPWE096,issued October 1,2006(APEN required for serial no.changes to permanent turbines). 238s 130 11/20/06 Temp.of 130 Not Req. 11/21/06 238s 12/15/06 238s:24 N/A 130 12/16/06 130 Return 238s 135p 7/26/07 Temp.of 135p Not Req. 135p_ 238s I 10/11/07 135p Return 238s:77 N/A 238s 130 I 5/5/08 Temp.of 130 * For 238s,238p, 135s,and 135p,the"s"and the"p"indicate when the unit functioned as a spare unit or a permanent unit, respectively. ** "P.R."=permanent replacement;"T.R."=temporary replacement;"Return=permanent unit returned. Mr.Matthew Parks July 17,2008 Page 6 of 15 As shown by Table 1,Thermo Ft Lupton has made two permanent replacements after the issuance of the January 1,1999 operating permit and submitted the required APENs in accordance with this permit. On February 14,2001,an APEN was submitted to notify the Colorado Department of Public Health and Environment(CDPHE)that Unit 238 would become a permanent replacement upon return of Unit 135. Unit 135 was returned on March 14,2001,and became a spare unit. On January 18,2005,an APEN was submitted for Unit 135. Three days later,Unit 135 was placed back into permanent service,and Unit 238 became the spare unit All other turbine replacements shown in Table 1 have been temporary replacements, which do not require an APEN submittal. As of October 1,2006,"Temporary"was defined as in service for"270 operating days or less in any 12-month period." 195OPWE096, issued October 1,2006, Section 1, Condition 2.21. Since October 1,2006,there have been no temporary replacements that exceeded 270 operating days. See Table 1. There have also been no turbine component changes since the issuance of the October 1, 2006,renewal operating permit,which have resulted in a change to the engine serial number. The engine numbers shown in Table 1 are the last three digits of the engine serial numbers(i.e.,185-130,185-136,185-137,185-126,185-135,and 185-238[spare]). These serial numbers are the same serial numbers provided in the current renewal operating permit shown below: Pollution Emission Unit AIRS Facility Control Number Stack Number Identifier Description Device S001-5005 001-005 0001-0005 Five(5)General Electric Steam LM6000 Natural Gas Injection Combustion Turbines,Rated Technology at 400 MMBtu/hr(HHV) (Turbines) Each,SN's:185-130,185-126, 185-135,185-136 and 185-137, Equipped with Five(5)Coen 12408-1 Duct Burners,Two(2) Rated at 240 MMBtu/hr (HHV)and Three(3)Rated at 180 MMBtu/hr(HHV). [95OPWE096,issued October 1, 2006, Section I, Condition 6.11. Thus,no APEN submittals have been required for a serial number change pursuant to Section I,Condition 2.1.2 of 95OPWE096,issued October 1,2006. Prior to January 1,1999,Thermo Ft.Lupton operated under Construction Permits 91WE667(1)-(5)issued February 19,1992,and September 3,1993,and 91WE667 issued • Mr. Matthew Parks July 17,2008 Page 7 of 15 July 26,1996. These permits did not contain APEN notification requirements for turbine replacements. The turbine replacement and APEN requirements of these permits are provided below: 91WE667(1)-(5)issued February 19,1992,and September 3,1993,Condition 14: A revised Air Pollution Emission Notice shall be filed when a significant change in emissions occurs,as required by Regulation No.3.II.B. 91WE667 issued July 26,1996: Condition 14: A revised Air Pollution Emission Notice(APEN)shall be filed when a significant change in actual emissions occurs(above the level reported on the last APEN, submitted to the Divisions,as required by Regulation No.3 Part A.B.C.2. Condition 15: In accordance with C.R.S.25-7-114.1,the Air Pollution Notices(APEN) associated with this permit are valid for a term of five years. Revise APENs shall be submitted no later than 30 days before the five year term expires. Condition 16: This permit shall apply to replacement turbines placed in service from time to time as part of normal maintenance practices,provided such replacement are GE LM6000 combustion turbines and further provided such replacement turbines are operated in full compliance with all conditions of this permit. Records of each replacement shall be maintained such that a list of equipment currently at site is readily available at site,and such records shall be made available for inspection upon request. APENs submitted prior to 2004 contained the maximum allowed annual emission rates. Because the actual emissions never exceeded these APEN report emission values (i.e., the allowable rates),the APEN reporting requirements shown above were never triggered. However,records of turbines replacements have been maintained in accordance with Condition 16 of Construction Permit 91WE667,issued July 26,1996. See Table 2. In conclusion,APENs were not required for turbine replacements from 1994 to January 1,1999;and as shown by Table 2,no APENs were submitted. From January 1,1999,to October 1,2006,APENs were required for permanent turbine replacements. As shown by Table 1,the two instances of permanent replacements were accompanied by APEN submittals within the require timeframe. After October 1,2006,APENs were required for turbine serial number changes,permanent turbine replacements were prohibited, and temporary turbine replacements were limited to 270 days. Since October 1,2006, there have been no turbine modifications which have resulted in a change to the serial number,there have been no permanent turbine replacements,and there have been no temporary turbine replacements lasting longer than 270 days. See Table 1. Therefore, Thermo Ft.Lupton believes it has complied with all turbine replacement APEN notification requirements since 1994. • Mr.Matthew Parks July 17,2008 Page 8 of 15 Table 2: Turbine Replacement Log and APEN Filing for 1994 through December 31,1998 Engines in Service Days (Package/No.)* Lease or L=GE-LM6000 Lease Unit Repair of Action Spare in ADEN A B CD E Spare Permanent Date Action** Service Date Construction Permits 91WE667(1)-(5)issued February 19,1992,and September 3,1993,and 91WE667 issued July 26,1996. 130 126 137 136 135p 1994 Original Installation Ll L2 L3 126,130,137 Jan-95 Temp.of Not Req. 130,126,137 126• 130° 135p,136,137 Jan-95 126,130 Return . N/A 135p ' 136,137 Jan-95 135p Return L2<31 N/A 136 • 137. 126,130 Apr-95 136,137 Return N/A 130 • 126 Oct-95 130 Return L1:<303 N/A 126 . 135p Mar-96 126 Return N/A 135p 130 _ Jun-96 135p Return N/A Construction Permit 91WE667 issued July 26,1996. 130 ' Jul-96 130 Return L3:<577 N/A IA 126 Apr-97 Temp.126 Not Req. 126• Jun-97 126 Return L4:<90 N/A L5 135p 4/26/98 Temp.of 135p Not Req. 135p,137 5/5/98 Not Req. 238s 5/15/98 238s 5/15/98 Temp.of 137 135p t 136,137 6/5/98 135p Return N/A 137. 130,136 6/24/98 137 Return N/A * For 238s,238p, 135s,and 135p,the"s'and the"p indicate when the unit functioned as a spare unit or a permanent unit,respectively. ** 'P.R.'=permanent replacement'T.R.'=temporary replacement;'Return=permanent unit returned. 2. Section I, Condition 2.2 of the Operating Permit allows the facility to temporarily replace any of the turbines. "Temporary" is defined by the permit as "270 operating days or less in any twelve month period." Records provided by the facility indicate that on four occasions turbine replacements lasted longer than 270 operating days and thus did not qualify as temporary. As discussed in the response to Item 1,the new definition of"Temporary,"which included a limit of 270 operating days,did not become effective until October 1,2006. [950PWE096,issued October 1,2006, Section I, Condition 2.2]. The previous operating permit did not contain such a time limit. (950PWE096, issued January 1, 1999,Section I, Condition 2.11 Since October 1,2006,Thermo Ft.Lupton has not put into service a replacement turbine for more than 270 operating days. See Table 1. • Mr. Matthew Parks July 17,2008 Page 9 of 15 3. Section II, Condition 1.3.1 requires the facility to maintain rolling twelve-month SO2 emission totals for the individual turbine/duct burners and rolling twelve- month 5O2 emission totals for the combined units. A review of the facility emission spreadsheet indicated that SO2 emissions from Turbines B, C, D and E were being calculated incorrectly. Because individual turbine emissions were underreported, the facility total SO2 emissions were also underreported. The formulas in our emissions compliance spreadsheet have been corrected for all past records. A review of the past records,after making the formula corrections,has shown that all the 12-month rolling total SO2 emission values are below the annual SO2 emission limit of 2.0 torts per year per unit. 4. Section II, Condition 1.4.2 imposes a BACT NOx emission limit of 25 ppm 15% O2 (daily average) from each turbine and duct burner combination. Daily average NOx emissions are to be determined using all unit operating hours, including periods of startup, shutdown and malfunction. The BACT emission limit has been applicable since June 30, 1997. Facility personnel indicated that NOx emissions during startup were not included in reported BACT emissions until April of 2007. Accordingly, the facility was out of compliance with the BACT monitoring requirement from June 1997 to April 2007. Further, the CEMSs do not report the full range of actual turbine NOx emissions,as required by Condition 1.8 below. The BACT limit for NOx of 25 ppmvd @ 15%O2 was initially established in Permit 91WE667(1)-(5)issued February 19,1992,and September 3,1993. This BACT determination was revised in Permit 91WE667 issued July 26,1996. The revised BACT determination retained the emission limit of 25 ppmvd @ 15% O2,but redefined the controls as"enhanced steam injection." The first operating permit was later issued on January 1,1999, (95OPWE096). This permit incorporated the NO.BACT limit from Permit 91WE667 issued July 26,1996,and cites this permit as the authority for the NO. BACT emission limit. None of these permits included startup or shutdown periods as part of the 25 ppmvd BACT limit. The NO.BACT limits from these permits are provided below: 91WE667(1)-(5)issued February 19,1992,and September 3,1993,Condition 6: Nitrogen Oxide emissions from this turbine shall not exceed 25 ppm*(26 ppm*with the duct burner also in use.) Based on the results of testing of the turbines with dry low NOx technology (DLN),if NOx emission rates lower than 25 ppm are obtained,then the lower emission rate achieved will be the enforceable limit. *ppm limitations are ppmvd at 15%oxygen and ISO standard day conditions. 91WE667 issued July 26,1996,Condition 2: These turbines and duct burners are subject to the Prevention of Significant Deterioration(PSI))provisions. Requirement of Best Available Control Technology(BACT)is applicable for control of Oxides of Nitrogen,Carbon Monoxide, Mr.Matthew Parks July 17,2008 Page 10 of 15 and Particulate Matter. Considering the information presented,the commitment to enhanced steam injection,and the request for reconsideration of BACT,the following is now determined as BACT: Oxides of Nitrogen: Enhance steam injection technology shall be adopted to control emissions of Oxides of Nitrogen. The permittee is taking steps to remove the constraints in the present steam supply system. The permittee shall expeditiously implement the enhance steam injection technology, and all five turbine shall operate with this technology no later than June 30,1997. The allowable concentration of oxides of nitrogen in the exhaust gases shall be based on the actual optimized performance during the lust six months of normal operation with enhance steam injection technology. However,these allowable concentrations shall not be greater than 25 ppmvd,average on a daily basis,at 15%oxygen. 95OPWE096,issued January 1,1999,Section II,Condition 1.1: NOx<25 ppmvd®15% oxygen(24-hr average). Concentrations of NOx and CO shall not exceed the limitations above (Construction Permit 91WE667 as modified under the provisions of Section I,Condition 1.3). The exhaust stack shall be equipped with a continuous emission monitor(CEM)to record exhaust gas NOx and CO concentrations(ppmvd at 15%oxygen averaged on a daily basis) and emissions rates(tons per 12-month period)from the turbine. Monitor operation availability shall be a least 90%.During the periods of time when the CEM is not operational, the highest reading recorded during the previous 30 day period shall be used for determining NOx and CO emissions. On October 1,2006,the CDPHE issued the renewal operating permit(95OPWE096). In this permit,CDPHE modified the NO.concentration limit of 25 ppmvd @ 15%O2,daily average,to include periods of startup,shutdown,and malfunction. As discussed above, the previous Thermo Ft. Lupton permits did not included startup or shutdown periods as part of this 25 ppmvd BACT limit. In fact,Permit 91WE667 specifically states that i the NO.BACT limit shall be based on"normal operation with enhanced steam injection technology" [emphasis added]. [91WE667 issued July 26, 1996, Condition 2]. As is to be expected,there were and will continue to be higher NO.concentrations during periods of startup and shutdown of the combustion turbines. During these periods,higher concentrations of NO.are inherent to the design of combustion turbines and,therefore,cannot be prevented. Once the combustion turbine reaches a sufficient load(soon after startup),steam injection to reduce NO.can be engaged. To resolve this matter,Thermo Ft.Lupton has met with the appropriate CDPHE representatives to discuss emission exceedances during engine startups and shutdowns and has submitted an application to revise the air permit to include appropriate emissions limits during engine startups and shutdowns. Until the permit is modified, Thermo Ft.Lupton has agreed to submit quarterly excess emission reports to include any startup or shutdown periods when NO.concentrations exceed the 25 ppmvd limit. These reports have been submitted for all calendar quarters since the issuance of the renewal operating permit on October 1,2006(95OPWE096). Prior to October 1,2006, Mr.Matthew Parks July 17,2008 Page 11 of 15 the NO.concentration limit of 25 ppmvd did not include startup and shutdown periods, and this limit was never exceeded. The issue of the CEMS range is discussed under Item 9. (5 Section II, Condition 1.4.3 requires the facility to calculate rolling 30-day average duct burner NOx (lb/MMBtu) emissions in accordance with NSPS Subpart Db. The facility does not maintain records as required. Thermo Ft. Lupton will add to its reports the 30-day average NO.emission rates in units of lb/MMBtu of heat input. These emission rates will be calculated at the end of each steam generating unit operating day from the measured or predicted hourly NO. emission rates for the preceding 30 steam generating unit operating days per 40 CFR§ 60.49b(g)(3). The calculations will include periods of startup, shutdown,or malfunction per 40 CFR R§60.44b(h). Thermo Ft. Lupton currently maintains CEMS records of hourly NO.emissions in ppmvd @ 15 percent oxygen,which is analogous to lb/MMBtu,pursuant to 40 CFR§ 60.48b(d). At the end of each operating day defined as the 24-hour period between 12:00 midnight and the following midnight per 40 CFR 60.41b,the daily average NOx emissions are computed in units of ppmvd @ 15 percent oxygen. These units can be directly converted to lb/MMBtu by multiplying by 0.003683,and 25 ppmvd @ 15%O2 is equal to 0.092 lb/MMBtu). [40 CFR 60,Appendix A,Method 19]. To date,the daily average NO.emissions from the turbines and duct burners have not exceeded 0.092 lb/MMBtu (25 ppmvd @ 15% O2)for any operating day,excluding turbine startup and shutdown hours. Because the duct burners are only operated during periods when the turbine is not in startup or shutdown mode (i.e.,normal operation),these daily averages serve as demonstration of past compliance with the 40 CFR 60,Subpart Db,NO.limit of 0.2 lb/MMBtu,based on a 30-day rolling average. Section II, 1.4.4 requires the facility to calculate rolling four-hour average turbine Ox (ppm @ 15% O2, ISO) emissions in accordance with NSPS Subpart GG. The facility does not maintain records as required. Thermo Ft.Lupton will add to its reports the four-hour average NO.concentrations in units of ppmvd @ 15% O2. The four-hour rolling average NO.concentration will be calculated as the arithmetic mean of the average NO.concentration measured by the CEMS for a given hour (not corrected to ISO standard conditions per 40 CFR §60.335(b)(1)) and the three unit operating hour average NO.concentrations immediately preceding that unit operating hour. The calculations will include periods of startup,shutdown,or malfunction per 40 CFR§60.3346). Note that the inclusion of startup,shutdown,or malfunction periods is a new requirement that became effective with the July 8,2004,rule revision. [69 Fed. Reg. 41346 (2004)]. • Mr.Matthew Parks July 17,2008 Page 12 of 15 • Thermo Ft Lupton has conducted startup NO.emissions monitoring to determine the NO.emission concentrations during these periods. This monitoring has shown that emissions do not exceed 65rpn1. During normal operation,emissions are below 25 ppmvd @ 15%O2. Therefore,Thermal Ft Lupton believes it has never exceeded the NSPS Subpart GG limit of 126.9 ppmvd @ 15%O2. OSection II, Condition 1.5.1 requires the facility to maintain rolling twelve-month CO emission totals for the combined turbine/duct burner units. A review of the facility emission spreadsheet indicated that individual CO emissions from the . turbines were being summed incorrectly, resulting in incorrect facility CO emission totals. The formulas in our emissions compliance spreadsheet have been corrected for all past records. A review of the past records,after making the formula corrections,has shown that all the 12-month rolling total CO emission values are below the annual CO emission limit of 90.51 tons per year per unit O Section II, Condition 1.5.2 imposes a BACT CO emission limit of 25 ppm @ 15% • O2 (daily average)from each turbine and duct burner combination. Daily average CO emissions are to be determined using all unit operating hours, including periods of startup, shutdown and malfunction. The BACT emission limit has been applicable since June 30, 1997. Facility personnel indicated that CO emissions during startup were not included in reported BACT emissions until April of 2007. Accordingly, the facility was out of compliance with the BACT monitoring requirement from June 1997 to April 2007. Further, the CEMSs do not report the • full range of actual turbine CO emissions,as required by Condition 1.8 below. The BACT limit for CO of 30/25 ppmvd @ 15%O2 was initially established in Permit 91WE667(1)-(5)issued February 19,1992,and September 3,1993. This BACT determination was revised in Permit 91WE667 issued July 26,1996. The revised BACT determination lowered the emission limit of 25 ppmvd @ 15%O2 after implementation of"enhanced steam injection." The first operating permit was later issued on January 1, 1999(95OPWE096). This permit incorporated the CO BACT limit from Permit 91WE667 issued July 26,1996,and cites this permit as the authority for the CO BACT emission limit. None of these permits included startup or shutdown periods as part of the 25 ppmvd BACT limit. The CO BACT limits from these permits are provided below: 91WE667(1)-(5)issued February 19,1992,and September 3,1993,Condition 6: Carbon monoxide emissions from this turbine(with or without the duct burner in use)shall not exceed 25 ppm*when using Dry-Low NO.technology. Carbon monoxide emissions from this turbine(with or without the duct burner in use)shall not exceed 30 ppm*when using steam injection technology. *ppm limitations are ppmvd at 15%oxygen and ISO standard day conditions. • Mr. Matthew Parks July 17,2008 Page 13 of 15 91WE667 issued July 26,1996,Condition 2: These turbines and duct burners are subject to the Prevention of Significant Deterioration(PSD)provisions. Requirement of Best Available Control Technology(BACT)is applicable for control of Oxides of Nitrogen,Carbon Monoxide, and Particulate Matter. Considering the information presented,the commitment to enhanced steam injection,and the request for reconsideration of BACT,the following is now determined as BACT: Carbon Monoxide: Good combustion control and sustained operation at consistently high load levels shall be practiced to minimize emissions of carbon monoxide. With the implementation of enhanced steam injection technology,the concentration of carbon monoxide in the exhaust gases shall not exceed 25 ppmvd,average on a daily basis,at 15%oxygen. 95OPWE096,issued January 1,1999,Section II,Condition 1.1: CO<25 ppmvd @ 15% oxygen(24-hr average). Concentrations of NOx and CO shall not exceed the limitations above (Construction Permit 91WE667 as modified under the provisions of Section I,Condition 1.3). The exhaust stack shall be equipped with a continuous emission monitor(CEM)to record exhaust gas NOx and CO concentrations(ppmvd at 15%oxygen averaged on a daily basis) and emissions rates(tons per 12-month period)from the turbine. Monitor operation availability shall be a least 90%.During the periods of time when the CEM is not operational, the highest reading recorded during the previous 30 day period shall be used for determining NOx and CO emissions. As discussed under Item 4,the CO BACT concentration limit of 25 ppmvd @ 15% O2, daily average,was modified to include periods of startup,shutdown,and malfunction with the issuance of the renewal operating permit on October 1,2006. The previous Thermo Ft.Lupton permits did not included startup or shutdown periods as part of this 25 ppmvd BACT limit. In fact,Permit 91WE667 specifically states that the following as part of CO BACT: "Good combustion control and sustained operation at consistently high-load levels shall be practiced to minimize emissions of carbon monoxide" [emphasis added]. [91WE667 issued July 26, 1996, Condition 2J. The reference to high- load levels indicates non-startup and non-shutdown periods where optimal combustion (resulting in 25 ppmvd of CO or less)can be achieved. To resolve this matter,Thermo Ft.Lupton has met with the appropriate CDPHE representatives to discuss emission exceedances during engine startups and shutdowns and has submitted an application to revise the air permit to include appropriate emissions limits during engine startups and shutdowns. Until the permit is modified, Thermo Ft. Lupton has agreed to submit quarterly excess emission reports to include any startup or shutdown periods when CO concentrations exceed the 25 ppmvd limit. These reports have been submitted for all calendar quarters since the issuance of the renewal operating permit on October 1,2006 (95OPWE096). Prior to October 1,2006, the CO concentration limit of 25 ppmvd did not include startup and shutdown periods, and this limit was never exceeded. The issue of the CEMS range is discussed under Item 9. r Mr.Matthew Parks July 17,2008 Page 14 of 15 6 Section II, Condition 1.8 requires the facility to maintain NOx and CO CEMSs on each exhaust stack. CEMSs are installed as required, but a review of facility emission records indicates that NOx emissions never exceed 50 ppm, and CO emissions never exceed 51.5 ppm from any of the turbines. Facility representatives indicated that the CEMSs are operated on a range of 0-50 ppm, and that higher emissions during startup and shutdown are not quantified. Because the monitors do not report the full range of turbine emissions, they are inadequate to determine compliance with the NOx and CO limits listed in Conditions 1.4 and 1.5 above. The CEMS data acquisition system range is currently set to 0-50 ppm. To determine how to adjust this range,Thermo Ft.Lupton has conducted startup emissions monitoring. This monitoring has shown that NO.emissions do not exceed 65 ppm. Thermo Ft.Lupton has contacted Monitor Labs to determine if the NO.CEMS can be reprogrammed to a larger range while maintaining sufficient accuracy at the normal operating level of less than 25 ppmvd CO 15%02 of NO.. Based on these discussions, Thermo Ft. Lupton believes that the CEMS can be set to a span of 0-500 ppm. This span will more than cover the full range of NO.emissions. Thermo Ft. Lupton will attempt to make these changes prior to its upcoming RATA. The CO CEMS will also be adjusted to a span of between 0 to 100 and 0 to 500 ppm. Thermo Ft. Lupton will likely start with 0 to 100 ppm,then monitor emissions to see if this range is sufficient. If not,the span will be increased. 10. Section II, Condition 1.9 requires the facility to calculate the annual capacity of each duct burner for each calendar month and to maintain 12-month rolling averages in accordance with NSPS Subpart Db. The facility does not maintain records as required. Thermo Ft.Lupton will add to its reports the annual capacity factor of each duct burner on a 12-month rolling average basis with a new annual capacity factor calculated at the end of each calendar month. The annual capacity factor will be calculated as the ratio between the actual heat input(HHV) to each duct burner for the preceding 12 months and the potential heat input(HHV)to each duct burner calculated as follows: 8,760 hours multiplied by 180 MMBtu/hr for the three smaller units and 8,760 hours multiplied by 240 MMBtu/hr for the two larger units. [40 CFR 60.49b(d)and 40 CFR 60.4114. ri). Section H, Condition 5.6 requires the facility to submit quarterly excess emission reports for the limits imposed by NSPS Subparts Db and GG. The facility submits EERs for BACT limits only. Mr. Matthew Parks July 17,2008 Page 15 of 15 Thermo Ft. Lupton will add excess emissions reporting for the limits imposed by NSPS Subparts Db and GG (discussed above under Items 5 and 6)in its quarterly excess emission reports. Please feel free to contact me at 303-914-7610 or Kevin Lewis at(303) 988-2960,Ext. 213, if you have any questions. Sincerely, /s/ L.Milton McBride Plant Manager Q:\PROJECTS\42\13-Lupton\07-Tide_V_renewal\Inspections\2008\2008 Inspection responses3.doc rte• A1R SCIENCES INC. October 20,2014 DINYCR. POCTIAND Project No. 310-1-1 Dan Salgado Senior Engineer,Environmental Services Tri-State Generation and Transmission Association,Inc. 1100 W.116th Avenue Westminster,CO 80234 Subject: JM Shafer Generating Station(formerly Ft. Lupton Cogeneration Facility)- Turbine Maintenance Program and Air Permit History Dear Mr.Salgado: Per your request,this letter provides the historical background of the turbine maintenance program and related air quality permit requirements for the JM Shafer Generating Station,formerly the Ft. Lupton Cogeneration Facility(Power Plant). In summary,replacement LM6000 turbines have been used at the Power Plant as part of the normal General Electric(GE) LM6000 maintenance program since startup of the facility in 1994. Originally,the Power Plant relied on lease turbines,but later purchased a spare unit (Unit 185-238)for this maintenance program. The spare unit has been on site since before the first Title V operating permit was issued and has served as the replacement unit for routine LM6000 maintenance. As we discussed,these GE aeroderivative combustion turbines are high precision turbines,which require periodic maintenance to be performed off-site at qualified maintenance centers. This is an inherent part of normal operation of these aeroderivative combustion turbines. It has always been my understanding that the construction permits (and BACT1 reviews) allowed for the use of replacement turbines of the same model(LM6000)for this maintenance program. The original construction permits specified only the model of the turbines. Under these permits,model LM6000 turbines at the Power Plant were routinely replaced with 1 Best Available Control Technology. 1301 WASHINGTON AVENUE, SUITE 200 GOLDEN, COLORADO 80401 303 .988 .2960 FAQ, 303.988.2968 Dan Salgado October 20,2014 Page 2 AIR SCIENCES INC. niwvIk.rn1rierun identical model units,and the only permit requirement was for the facility to maintain records of the replacements so that inspectors could assure that the replacement units were indeed LM6000 models.'This operational practice was specified in Construction Permit No. 91WE667 PSD Modification 1(Condition 16),issued July 26,1996: This permit shall apply to replacement turbines placed in service from time to time as part of normal maintenance practices, provided such replacement turbines are GE LM6000 combustion turbines and further provided such replacement turbines operate in full compliance with all conditions of this permit. Records of each such replacement shall be maintained such that a list of equipment currently at site is readily available at site, and such records shall be made available for inspection upon request. The issuance of this construction permit included a BACT review of the LM6000 turbines,which revised the BACT requirements from phase-in DLN2 to enhanced steam injection due to the non-availability on the DLN technology for the LM6000 model. This BACT review(as with the original review)established annual NOx and CO limits for each individual turbine stack(five total)and for the facility as a whole. Discussions with APCD,3 at the time,regarding the BACT review and these emission limits included the turbine replacement practice. The key point here was that the Power Plant had installed CEMS for directly measuring NOx and CO emission to demonstrate compliance with the BACT limits. Because of the CEMS,NOx and CO emissions could be tracked from each turbine package(five total)regardless of which LM6000 happened to be in each package. This addressed any potential issue with replacement LM6000 turbines possibly having slightly different emissions. Note that these CEMS were not required for any other applicable requirement.4 In summary,the operational practice of using replacement turbines of the same model(LM6000)for normal maintenance was considered in the BACT review and,thus,allowed under Condition 16 of Permit No. 91WE667 PSD Modification 1. Starting in 1999 with the first Title V operating permit,the APCD decided to add the serial numbers of each turbine. This created a need to develop specific language in the 2 Dry low NOx. 3 Air Pollution Control Division. 4 GEMS were later required in 2009 to meet the Acid Rain Program Dan Salgado October 20,2014 Page 3 AIR SCIENCES INC. p1 k116 . iul[IIAht] permit to address turbine replacements,so the APCD added AOS5 language in the Title V operating permit allowing for both permanent and temporary replacements. On October 1,2006,the first Title V renew was issued. In this permit,the AOS language was revised to only allow temporary replacements. APCD`s policy on the AOS was revised again in January 23,2013.6 As previously mentioned, Unit 185-238 has been on site and used as a maintenance replacement turbine since before the first Title V operating permit (and before the first AOS turbine replacement conditions contained in this permit). The use of this turbine as a replacement unit was detailed in a letter to APCD(Matthew Parks)dated July 17, 2008. It is my understanding that it continues to be used as a replacement unit today. If you have any questions,please feel free to call me at 720-389-4213. Sincerely, Kevin Lewis Principal Air Quality Engineer Air Sciences Inc. 5 Alternate Operating Scenario. 6 CDPHE(Colorado Department of Public Health and Environment). 2013. Permit Section Memo 98-07A. Turbine Alternate Operating Scenarios:Turbines with CEM. CDPHE Air Pollution Control Division, Stationary Sources Program Memo from Matt Burgett to Permit Engineers. January 23,2013. TRI-STATE GENERATION AND TRANSMISSION ASSOCIATION, INC. HEADQUARTERS: P.O. BOX 33695 DENVER, COLORADO 80233-0695 303-452-6111 December 19,2014 Ms.Jacqueline Joyce Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver,CO 80246-1530 RE: Operating Permit Renewal Application for JM Shafer Generating Station Permit Number 95OPWE096 Dear Ms.Joyce: This cover letter and attachment constitute the Operating Permit renewal application for the JM Shafer Generating Station,Operating Permit Number 95OPWE096. Three copies of this letter and attachment are enclosed. Requested changes to the permit are described in the attachment by permit section and condition number. A signed Operating Permit application form 2000-800 and copies of the most recent Air Pollutant Emission Notices submitted for the facility are included. Renewal of the Acid Rain portion of the permit is requested and a signed Acid Rain application form is enclosed. The JM Shafer units are not subject to the Acid Rain oxides of nitrogen(NOr) limitations in 40 Code of Federal Regulations 76,and a NO„compliance plan is not required. The facility's greenhouse gas(GHG)potential emissions have been calculated and the facility is a major source of GHG. The List of Insignificant Activities in Appendix A of the permit has been reviewed and no changes or additions are required. Compliance Assurance Monitoring(CAM) requirements have previously been addressed for this facility. If you have any questions concerning this renewal application,please contact Dan Salgado at 303-452-6111. Sincerely, 4.40/a/1 Barbara A.Walz Senior Vice President Policy and Compliance Chief Compliance Officer BAW:DS:pvt Enclosure AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER CRAIG STATION ESCALANTE STATION NUCLA STATION ��//// P.O.BOX 1307 P.O.BOX 577 P.O.BOX 698 A Touchstone Energy'Cooperative j CRAIG,CO 81626-1307 PREWITT,NM 87045 NUCLA,CO 81424-0698 `�.,� 970-824-4411 505-972-5200 970-864-7316 JM SHAFER GENERATING STATION OPERATING PERMIT 95OPWE096 RENEWAL APPLICATION This application for renewal of Operating Permit 95OPWE096 for the JM Shafer Generating Station is submitted in accordance with Regulation 3,Part C, Section V.C. A signed Operating Permit Application Form 2000-800,the most recent Air Pollutant Emission Notices(APENs)for the facility and an Acid Rain Permit Renewal Application form are provided in Appendix A. As part of the renewal process,the following changes and additions to the operating permit are requested: Page Following Cover Page-Update Responsible Official's title; Section II,Conditions 1.4.2.1 and 1.5.2.1 -Add tuning and testing best available control technology(BACT)limits. Section II,Condition 1.8.2—Add diluent cap to CO monitoring provisions; Section II,Conditions 6.—Update of 40 Code of Federal Regulations(CFR)63, Subpart ZZZZ requirements. These requested changes are discussed in more detail below. Suggested additions to permit conditions are shaded in throughout this application. Page Following Cover Page - Responsible Official's Title Update Barbara Walz title is now Senior Vice President,Policy and Compliance/Chief Compliance Officer. It is requested that this change be reflected in the permit. Section II, Conditions 1.4.2.1 and 1.5.2.1 - Tuning and Testing BACT Limit The BACT limits for oxides of nitrogen(NOX)and carbon monoxide(CO)are listed in Section II, Conditions 1.4.2.1 and 1.5.2.1. Startup and shutdown periods are excluded and separate startup and shutdown limits have been established in Section II,Conditions 1.4.2.2 and 1.5.2.2. In addition to startup and shutdown,excess emissions can occur when a turbine undergoes tuning and testing following an overhaul or as part of routine maintenance. It is requested that periods of tuning and testing be excluded from Section II,Condition 1.4.2.1 and 1.5.2.1 and NOx and CO BACT limits for tuning and testing be included in the permit. To determine appropriate tuning and testing limits,recent facility experience with tuning and testing and a review of other Colorado tuning and testing limits for aero-derivative turbines were reviewed. The following Colorado limits for tuning and testing of aero-derivative turbines have been identified: Operating Permit 01OPBO238, SWG Colorado,LLC,Valmont Combustion Turbine Facility, Section II, Condition 1.1.1.4—"During periods of combustion tuning and testing,emissionsof15% average." NO„shall not exceed 117.8 ppmvd at O2 on a 1-hour Construction Permit Number 09PB0591,Black Hills Electric Generation,LLC, Pueblo Airport Generating Station,Condition 11 —"During periods of combustion tuning and 1 77, testing emissions of CO and NO.shall not exceed 100 ppmvd at 15%O2,on a 1-hour average." Based on the review conducted,a tuning and testing NO.limit of 100 parts per million by volume,dry (ppmvd)at 15%oxygen(O2)on a 1-hour average and a tuning and testing CO limit of 10015 ppmvd at 15%O2 on a one-hour average are requested. The following permit condition revisions and additions are suggested to implement these limits. Section II,Condition 1: Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number NOx 1.4 NA Each Unit(turbine plus N/A Continuous Continuously duct burner): Emission 146.5 tons/year Monitoring All Units Combined: System 589.0 tons/year 25 ppmvd @ 15%O2,on a daily average,except as provided for below: During Startup and Shutdown: 38 lbs er event Each turbine only: 126.9 ppmvd at 15%O2 CO 1.5 NA Each Unit(turbine plus N/A Continuous Continuously duct burner): Emission 90.51 tons/year Monitoring All Units Combined: System 452.55 tons/year 25 ppmvd @ 15%O2,on a daily average,except as provided for below: During Startup and Shutdown" 25 lbs er event 1.4.2.1 Except as provided for in Condition" 1.4.2.2 .NOx emissions shall not exceed 25 ppmvd at 15%O2,on a daily average. Compliance with the NO.BACT limit shall be monitored using the CEMS b Condition 1.8. Except as provided for in Condition'1.4.2.2 the daily average shall be determined using all operating hours during every midnight to midnight period. This includes any partial hours as described in Conditio 1.4.2.2 below. 2 1.5.2.1 Except as provided for in Condition" 1.5.2.2-,CO emissions shall not exceed 25 ppmvd at 15%O2,on a daily average. Compliance with the CO BACT limit shall be monitored using the continuous emission monitoring system required by Condition 1.8. Except as provided for in Condition' 1.5.2.2 the daily average shall be determined using all operating hours during every midnight to midnight period. This includes any partial hours as described in Condition' 1.5.2.2 below. 1.8.1 Concentration of Oxides of Nitrogen corrected to 15%oxygen,hourly average,4-hr rolling average(including periods of startu•,shutdown and malfunction),daily average (excludin: startu•"and-shutdow periods), 1.8.2 Concentration of Carbon Monoxide corrected to 15%ox .en,hourly avera.e,dail average(excluding startups and-shutdo periods), 3 • 1.8.6 Operating mode-startup,shutdown..-and/or standard operation. Section II, Condition 1.8.2-CO Diluent Cap Addition It is requested that language be added to Section II to allow oxygen(O2)values above 19%to be diluent capped at 19%when calculating carbon monoxide(CO)emissions. A diluent cap is included in 40 Code of Federal Regulations(CFR)60,Subpart GG and 40 CFR 75 because it was recognized that the use of measured diluent concentrations during transitory operations such as startup and shutdown or during low load operations overestimate pound per million British thermal unit(1b/mmBtu)emissions. This is apparent when the equation used to calculate emissions in lb/mmBtu is examined. The equation used to calculate CO lbs/mmBtu is as follows: CO(lb/mmBTU)= 7.25E-8(lbs/scf/ppm))*(MeasureaiCOppm)* 20.9 (209—%02 ) Given that oxygen(O2)is subtracted from 20.9,high O2 values cause a small denominator and large CO lbs/mmBtu values even when low ppm values of CO are detected. This conversion equation does not work well for transitory and low load operations because it was developed assuming complete combustion and normal operation. CO emissions are not regulated by either 40 CFR 60,Subpart GG or 40 CFR 75 and therefore,the diluent cap is not specifically identified for use in calculating lb/mmBtu CO emissions. It is requested that a provision be added to the Operating Permit for use of the diluent cap for CO emissions. The following addition of a diluent cap for CO emissions could be added to Section II,Condition 1.8.2 as follows: 1.8.2 Concentration of Carbon Monoxide corrected to 15%ox en,hourly avera e,dail avers a excludin strati' aad shutdo periods), Section II, Condition 6. -Update of 40 CFR 63, Subpart ZZZZ Requirements The provisions of 40 CFR 63, Subpart 77.7.7,have changed since the last issuance of Operating Permit 95OPWE096. It is requested that the permit conditions be revised to reflect the current wording in 40 CFR 63, Subpart 7.7.7,2. The following changes are suggested: 6.1.8 If you own or operate a stationary engine that is subject to the work,operation or management practices in Condition 6.1.2.1,you have the option of utilizing an oil analysis program in order to extend the specified oil change requirement in Condition 6.1.2.1. The oil analysis must be performed at the same frequency specified 4 for changing the oil in Condition 6.1.2.1. The analysis program must at a minimum analyze the following three parameters: Total Base Number,viscosity,and percent water content. The condemning limits for these parameters are as follows: total Base Number is less than 30 percent of the Total Base Number of the oil when new;viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new;or percent water content(by volume)is greater than 0.5. If all of these condemning limits are not exceeded,the engine owner or operator is not required to change the oil. If any of the limits are exceeded,the engine owner or o•erator must change the oil before continuing The owner or operator must keep records of the parameters that are analyzed as part of the program,the results of the analysis,and the oil changes for the engine. The analysis program must be part of the maintenance plan for the engine. (§63.6625(i)) 6.1.9 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,a new emergency stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions that was installed on or after June 12,2006,-or an existing emergency station RICE located at an area source of HAP emissions,you must operate the engine according to the conditions described below.(§63.6640(f)) 6.1.9.1 - - - •. _ ... . . . ,� ,_,..,-,. iiit= • = , any o•eration other than emer ency operation,maintenance and testing, and operation in non-emergency situation for 50 hours per year,as permitted in this section,is prohibited (§63.6640(f)f) 6.1.9.2 There is no time limit on the use of emergency stationary RICE in emergency situations.(§63.6640(f)( )) 6.1.9.34 You may operate your emergency stationary RICE for the purpose of maintenance checks and readiness testing,provided that the tests are recommended b Federal,State or local :overnment,the manufacturer, the vendor, 5 • ,or the insurance company associated with the engine. Maintenance checks and readiness testing of such units is limited to 100 hours per year. 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 testim of emergency RICE beyond 100 hours per year.(§63.6640(f) 1111111111111111 6.1.9.4 You may operate your emergency stationary RICE up to 50 hours per year in non-emergency situation,but those 50 hours are counted towards the 100 hours r*,, rovided for maintenance and testing II . The 50 hours year for non-emer ency situations cannot be Used for peak shaving 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;except that owners and operations may operate the emergency engine for a maximum of 15 hours per year as part of a for • blackout,such as unusually low frequency,equipment overload, capacity,or energy deficiency,or unacceptable voltage level. The engine may not be operated for more than 30 minutes prior to the time when the emergency condition is expected to occur,and the engine • • that the emergency condition is no longer imminent. The 15 hours per operation per year provided for non emergency situations. The supply of emergency power to another entity or entities pursuant to financial • • • , �...... t?/° ' • _ •■ 6 (§63.6640(0(4) 6.1.11 If you own or operate an existing emergency stationary CI RICE located at an area source of HAP emissions that does not meet the standards applicable to non-emergency engines, you must keep records of the hours of operation of the engine that is recorded through the non-resettable hour meter. The owner or operation 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-emer ency o eration. If the engines are used for demand response operation �.� ®, the owner or o erator must ke records of the notification of the emergency situation, and the tim the-engine was operatedion as part of demand response . (§63.6655(f)and§63.6655(0(2)) 7 FORMS • Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 Colorado Department of Health 09-94 Air Pollution Control Division Facility Name: JM Shafer Generatin¢Station Facility Identification Code:CO 1230250 I. ADMINISTRATION This application contains the following forms: 0 Form 2000-100,Facility Identification ❑ Form 2000-101,Facility Plot Plan ❑ Forms 2000-102,-102A,and-102B,Source and Site Descriptions II. EMISSIONS SOURCE DESCRIPTION Total Number of This Form This application contains the following forms (one form for each facility boiler,printing ❑ 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 Total Number SYSTEM of This Form This application contains the following forms: 0 Form 2000-400,Miscellaneous ❑ Form 2000-401,Condensers ❑ Form 2000-402,Adsorbers ❑ Form 2000-403,Catalytic or Thermal Oxidation ❑ Form 2000-404,Cyclones/Settling Chambers ❑ Form 2000-405,Electrostatic Precipitators ❑ Form 2000-406,Wet Collection Systems ❑ Form 2000-407,Baghouses/Fabric Filters IV. COMPLIANCE DEMONSTRATION Total Number of This Form This application contains the following forms 0 Form 2000-500,Compliance Certification-Monitoring and (one for each facility boiler,printing operation, 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 V. EMISSION SUMMARY AND Total Number COMPLIANCE CERTIFICATION of This Form This application contains the following forms quantifying emissions,certifying compliance with applicable requirements,and developing a O Form 2000-600,Emission Unit Hazardous Mr Pollutants compliance plan ❑ Form 2000-601,Emission Unit Criteria Air Pollutants ❑ Form 2000-602,Facility Hazardous Air Pollutants ❑ Form 2000-603,Facility Criteria Air Pollutants ❑ Form 2000-604,Applicable Requirements and Status of Emission Unit ❑ Form 2000-605,Permit Shield Protection Identification ❑ Form 2000-606,Emission Unit Compliance Plan- Commitments and Schedule ❑ Form 2000-607,Plant-Wide Applicable Requirements ❑ Form 2000-608,Plant-Wide Compliance Plan- Commitments and Schedule VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and,based on information and belief formed after reasonable inquiry,I certify that the statements and information contained in this application are true,accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS-FEDERAL/STATE CONDITIONS(check one box only) ►�� I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. O I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements,except for the following emissions unit(s): (list all non-complying units) WARNING: Any person who knowingly,as defined in§18-1-501(6),C.R.S.,makes any false material statement, representation,or certification in,or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of§25-7122.1,C.R.S. Printed or Typed Name Title Barbara A.Walz Senior Vice President,Policy and Compliance/Chief Compliance Officer Signa 4G,, , Date Signed /g J / Operating Permit Application CERTIFICATION FOR STATE-ONLY CONDITIONS FORM 2000-800 Colorado Department of Health 09-94 Air Pollution Control Division Facility Name: JM Shafer Generating Station Facility Identification Code:CO_1230250 VI. SIGNATURE OF RESPONSIBLE OFFICIAL-STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and,based on information and belief formed after reasonable inquiry,I certify that the statements and information contained in this application are true,accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE-ONLY CONDITIONS(check one box only) ® I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. ❑ I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements,except for the following emissions unit(s): (list all non-complying units) WARNING: Any person who knowingly,as defined in§ 18-1-501(6),C.R.S.,makes any false material statement,representation,or certification in,or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of§25-7122.1,C.R.S. Printed or Typed Name Title Barbara A.Walz Senior Vice President,Policy and Compliance/Chief Compliance Officer Signature /l/ Date S=' ,,,d7( ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B 1 4300 CHERRY CREEK DRIVE SOUTH DENVER,CO 80246-1530 United States Environmental Protection Agency OMB No.2060-0258 efravk Acid Rain Program Approval expires 11/30/2012 Acid Rain Permit Application For more information,see instructions and 40 CFR 72.30 and 72.31. This submission is: O new ❑ revised ®for Acid Rain permit renewal STEP 1 Identify the facility name, JM Shafer Station Colorado 50707 State, and plant(ORIS) Facility(Source)Name State Plant Code code. STEP 2 a b Enter the unit ID# Unit ID# Unit Will Hold Allowances for every affected in Accordance with 40 CFR 72.9(cX1) unit at the affected source in column"a." S001 Yes S002 Yes S003 Yes S004 Yes S005 Yes Permit Requirements STEP 3 (1) The designated representative of each affected source and each affected unit at the Read the standard source shall: requirements. (i) Submit a complete Acid Rain permit application (including a compliance plan) under 40 CFR part 72 in accordance with the deadlines specified in 40 CFR 72.30; and (ii)Submit in a timely manner any supplemental information that the permitting authority determines is necessary in order to review an Acid Rain permit application and issue or deny an Acid Rain permit; (2)The owners and operators of each affected source and each affected unit at the source shall: (i) Operate the unit in compliance with a complete Acid Rain permit application or a superseding Acid Rain permit issued by the permitting authority; and (ii) Have an Acid Rain Permit. Monitoring Requirements (1) The owners and operators and, to the extent applicable, designated representative of each affected source and each affected unit at the source shall comply with the monitoring requirements as provided in 40 CFR part 75. (2) The emissions measurements recorded and reported in accordance with 40 CFR part 75 shall be used to determine compliance by the source or unit, as appropriate, with the Acid Rain emissions limitations and emissions reduction requirements for sulfur dioxide and nitrogen oxides under the Acid Rain Program. (3) The requirements of 40 CFR part 75 shall not affect the responsibility of the owners and operators to monitor emissions of other pollutants or other emissions characteristics at the unit under other applicable requirements of the Act and other provisions of the operating permit for the source. Sulfur Dioxide Requirements (1)The owners and operators of each source and each affected unit at the source shall: (i) Hold allowances, as of the allowance transfer deadline, in the source's compliance account (after deductions under 40 CFR 73.34(c)), not less than the total annual emissions of sulfur dioxide for the previous calendar year from the affected units at the source; and (ii)Comply with the applicable Acid Rain emissions limitations for sulfur dioxide. (2) Each ton of sulfur dioxide emitted in excess of the Acid Rain emissions limitations for sulfur dioxide shall constitute a separate violation of the Act. (3)An affected unit shall be subject to the requirements under paragraph (1) of the sulfur dioxide requirements as follows: (i)Starting January 1, 2000, an affected unit under 40 CFR 72.6(a)(2);or (ii) Starting on the later of January 1, 2000 or the deadline for monitor certification under 40 CFR part 75, an affected unit under 40 CFR 72.6(a)(3). ,.. . u, ,vf;E ..,c� _f$"' ry"?fln _ p:. t ;:d ,+.,., a,5'..'.' x.:1,"'' �,m�s�x TA,T\."E' t';Y Sulfur Dioxide Requirements,Cont'd. STEP 3,Cont'd. (4)Allowances shall be held in, deducted from, or transferred among Allowance Tracking System accounts in accordance with the Acid Rain Program. (5) An allowance shall not be deducted in order to comply with the requirements under paragraph (1) of the sulfur dioxide requirements prior to the calendar year for which the allowance was allocated. (6) An allowance allocated by the Administrator under the Acid Rain Program is a limited authorization to emit sulfur dioxide in accordance with the Acid Rain Program. No provision of the Acid Rain Program, the Acid Rain permit application, the Acid Rain permit, or an exemption under 40 CFR 72.7 or 72.8 and no provision of law shall be construed to limit the authority of the United States to terminate or limit such authorization. (7) An allowance allocated by the Administrator under the Acid Rain Program does not constitute a property right. Nitrogen Oxides Requirements The owners and operators of the source and each affected unit at the source shall comply with the applicable Acid Rain emissions limitation for nitrogen oxides. Excess Emissions Requirements (1)The designated representative of an affected source that has excess emissions in any calendar year shall submit a proposed offset plan,as required under 40 CFR part 77. (2) The owners and operators of an affected source that has excess emissions in any calendar year shall: (i)Pay without demand the penalty required, and pay upon demand the interest on that penalty, as required by 40 CFR part 77;and (ii)Comply with the terms of an approved offset plan,as required by 40 CFR part 77. Recordkeeping and Reporting Requirements (1) Unless otherwise provided, the owners and operators of the source and each affected unit at the source shall keep on site at the source each of the following documents for a period of 5 years from the date the document is created. This period may be extended for cause, at any time prior to the end of 5 years, in writing by the Administrator or permitting authority: (i)The certificate of representation for the designated representative for the source and each affected unit at the source and all documents that demonstrate the truth of the statements in the certificate of representation, in accordance with 40 CFR 72.24; provided that the certificate and documents shall be retained on site at the source beyond such 5-year period until such documents are superseded because of the submission of a new certificate of representation changing the designated representative; STEP 3, Cont'd. Recordkeeping and Reporting Requirements. Cont'd. (ii) All emissions monitoring information, in accordance with 40 CFR part 75, provided that to the extent that 40 CFR part 75 provides for a 3-year period for recordkeeping, the 3-year period shall apply. (iii) Copies of all reports, compliance certifications, and other submissions and all records made or required under the Acid Rain Program;and, (iv) Copies of all documents used to complete an Acid Rain permit application and any other submission under the Acid Rain Program or to demonstrate compliance with the requirements of the Acid Rain Program. (2) The designated representative of an affected source and each affected unit at the source shall submit the reports and compliance certifications required under the Acid Rain Program, including those under 40 CFR part 72 subpart I and 40 CFR part 75. Liability (1) Any person who knowingly violates any requirement or prohibition of the Acid Rain Program, a complete Acid Rain permit application, an Acid Rain permit, or an exemption under 40 CFR 72.7 or 72.8, including any requirement for the payment of any penalty owed to the United States, shall be subject to enforcement pursuant to section 113(c) of the Act. (2) Any person who knowingly makes a false, material statement in any record, submission, or report under the Acid Rain Program shall be subject to criminal enforcement pursuant to section 113(c)of the Act and 18 U.S.C. 1001. (3) No permit revision shall excuse any violation of the requirements of the Acid Rain Program that occurs prior to the date that the revision takes effect. (4) Each affected source and each affected unit shall meet the requirements of the Acid Rain Program. (5) Any provision of the Acid Rain Program that applies to an affected source (including a provision applicable to the designated representative of an affected source) shall also apply to the owners and operators of such source and of the affected units at the source. (6) Any provision of the Acid Rain Program that applies to an affected unit (including a provision applicable to the designated representative of an affected unit)shall also apply to the owners and operators of such unit. (7) Each violation of a provision of 40 CFR parts 72, 73, 74, 75, 76, 77, and 78 by an affected source or affected unit, or by an owner or operator or designated representative of such source or unit, shall be a separate violation of the Act. Effect on Other Authorities No provision of the Acid Rain Program, an Acid Rain permit application, an Acid Rain permit, or an exemption under 40 CFR 72.7 or 72.8 shall be construed as: (1) Except as expressly provided in title IV of the Act, exempting or excluding the owners and operators and, to the extent applicable, the designated representative of an affected source or affected unit from compliance with any other provision of the Act, including the provisions of title I of the Act relating STEP 3, Cont'd. TN, ' er," a5„> ,x., k7r. .7A 7a 46;•. V' "`T :-tf Effect on Other Authorities, Cont'd. to applicable National Ambient Air Quality Standards or State Implementation Plans; (2) Limiting the number of allowances a source can hold; provided, that the number of allowances held by the source shall not affect the source's obligation to comply with any other provisions of the Act; (3) Requiring a change of any kind in any State law regulating electric utility rates and charges, affecting any State law regarding such State regulation, or limiting such State regulation, including any prudence review requirements under such State law; (4) Modifying the Federal Power Act or affecting the authority of the Federal Energy Regulatory Commission under the Federal Power Act;or, (5) Interfering with or impairing any program for competitive bidding for power supply in a State in which such program is established. STEP 4 Read the certification Certification statement, sign, and date. 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