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Home My WebLink About20153045.tiff A E CDPH 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 1150O St PO Box 758 Greeley, CO 80632 RECEIVED September 14, 2015 SEP 1 7 2015 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On September 16, 2015, the Air Pollution Control Division will begin a 30-day public notice period for Public Service Company of Colorado - Ft. St. Vrain Station. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure RIU C C l�L ' J�O; L 9 /7 2015-3045 l�4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ,.. �r *,. John W. Hickenlooper, Governor i Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer „ CDPHE Air Pollution Control Division CO Al Notice Of A Proposed Renewal Title V Operating Permit Warranting Public Comment Website Title: Public Service Company of Colorado - Ft. St. Vrain Station - Weld County Notice Period Begins: September 16, 2015 NOTICE is hereby given that an application to renew an Operating Permit has been submitted to the Colorado Air Pollution Control Division, 4300 Cherry Creek Drive South, Denver, Colorado 80246-1530, for the following source of air pollution: Applicant: Public Service Company of Colorado 1800 Larimer Street Suite 1300 Denver, CO 80202 Facility: Ft. St. Vrain Station 16805 County Road 19 %z Platteville, CO 80651 Public Service Company of Colorado has applied to renew the Operating Permit for the Ft. St. Vrain Station in Weld County, CO. This facility consists of five natural gas-fired combustion turbines used to generate electricity. A minor modification application is being processed in conjunction with the renewal permit. The purpose of the modification is to simplify the opacity monitoring language for the diesel-fired emergency engines. 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 97OPWE180 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public- notices. The Division has made a preliminary determination of approval of the application. Based on the information submitted by the applicant, the Division has prepared the draft renewal operating permit for approval. Any interested person may contact Jacqueline Joyce of the Division at 303-692-3267 to obtain additional information. Any interested person may submit written comments to the Division concerning 1) the sufficiency of the preliminary analysis, 2) whether the permit application should be approved or denied, 3) the ability of the proposed activity to comply with applicable requirements, 4) the air quality impacts of, alternatives to, and control technology required on the source or modification, and 5) any other appropriate air quality considerations. Any interested person may submit a written request to the Division for a public comment hearing before the Colorado Air Quality Control Commission (Commission) to receive comments regarding the concerns listed above as well as the sufficiency of the preliminary analysis and whether the Division should approve or deny the permit application. If requested, the hearing will be held before the Commission within 60 days of its receipt of the request for a hearing unless a longer time period is agreed upon by the Division and the applicant. The hearing request must: 1) identify the individual or group requesting the hearing, 2) state his or her address and phone number, and 3) state the reason(s) for the request, the manner in which the person is affected by the proceedings, and an explanation of why the person's interests are not already adequately represented. The Division will receive and consider the written public comments and requests for any hearing for thirty calendar days after the date of this Notice. orn DrjIOR�DO 1 I CQtr- 4c,; A -- 17,c3 O Snve eHud'�� '� 1876 Colorado Department of Public Health and Environment OPERATING PERMIT Public Service Company of Colorado — Ft. St. Vrain Station First Issued: January 1 , 2000 Renewed: DRAFT AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: Ft. St. Vrain Station OPERATING PERMIT NUMBER FACILITY ID: 1230023 97OPWE180 RENEWED: EXPIRATION DATE: MODIFICATIONS: See Appendix F of Permit Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et sec. and applicable rules and regulations. ISSUED TO: PLANT SITE LOCATION: Public Service Company of Colorado 16805 County Road 19% 1800 Larimer Street Platteville, CO 80651 Denver, CO 80202 Weld County INFORMATION RELIED UPON Operating Permit Renewal Application Received: December 17, 2014 And Additional Information Received: December 17, 2014 and September 3, 2015 Nature of Business: Combustion Gas Turbine Electric Generating STation Primary SIC: 4911 RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON Name: Mark Fox Name: Gary Magno Title: General Manager— Power Title: Manager, Environmental Services—Air Generation, Colorado Quality Compliance Phone: (303) 425-3779 Phone: (303) 294-2177 SUBMITTAL DEADLINES Semi-Annual Monitoring Periods: EXAMPLE (January 1 —June 30, July 1 — December 31) Semi-Annual Monitoring Report: EXAMPLE (Due on Aug. 1 2011 and Feb. 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. FOR ACID RAIN SUBMITTAL DEADLINES SEE SECTION IIL4 OF THIS PERMIT TABLE OF CONTENTS: SECTION I - General Activities and Summary 1 1. Permitted Activities 1 2. Alternative Operating Scenarios 2 3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) 3 4. Accidental Release Prevention Program (112(r)) 3 5. Compliance Assurance Monitoring (CAM) 3 6. Summary of Emission Units 4 SECTION II - Specific Permit Terms 6 1. T002 & T003 — Two (2) Combustion Turbines Capable of Simple or Combined Cycle Operation 6 2. T004—Combustion Turbine Capable of Simple or Combined Cycle Operation 21 3. B001 - Auxiliary Boiler 38 4. M001 - Cooling Water and Service Water Towers 40 5. Continuous Emission Monitoring Systems (CEMS) 41 6. M002 - Gasoline Storage Tank, 500 gallons aboveground 46 7. M002 —Cold Cleaner Solvent Vats 49 8. T005 & T006—Two (2) Simple Cycle Combustion Turbines 50 9. M004 - Diesel Fuel Fired Internal Combustion Engines 60 SECTION III -Acid Rain Requirements 67 1. Designated Representative and Alternate Designated Representative 67 2. Sulfur Dioxide Emission Allowances and Nitrogen Oxide Emission Limitations 67 3. Standard Requirements 68 4. Reporting Requirements 71 5. Comments,Notes and Justifications 72 SECTION IV- Permit Shield 73 1. Specific Non-Applicable Requirements 73 2. General Conditions 73 3. Streamlined Conditions 74 SECTION V - General Permit Conditions 75 1. Administrative Changes 75 2. Certification Requirements 75 3. Common Provisions 75 4. Compliance Requirements 79 5. Emergency Provisions 80 6. Emission Controls for Asbestos 80 7. Emissions Trading, Marketable Permits, Economic Incentives 80 8. Fee Payment 80 9. Fugitive Particulate Emissions 81 10. Inspection and Entry 81 11. Minor Permit Modifications 81 12. New Source Review 81 13. No Property Rights Conveyed 81 14. Odor 81 TABLE OF CONTENTS: 15. Off-Permit Changes to the Source 82 16. Opacity 82 17. Open Burning 82 18. Ozone Depleting Compounds 82 19. Permit Expiration and Renewal 82 20. Portable Sources 82 21. Prompt Deviation Reporting 82 22. Record Keeping and Reporting Requirements 83 23. Reopenings for Cause 84 24. Section 502(b)(10) Changes 84 25. Severability Clause 85 26. Significant Permit Modifications 85 27. Special Provisions Concerning the Acid Rain Program 85 28. Transfer or Assignment of Ownership 85 29. Volatile Organic Compounds 85 30. Wood Stoves and Wood burning Appliances 86 APPENDIX A- Inspection Information 1 Directions to Plant: 1 Safety Equipment Required: 1 Facility Plot Plan- 1 List of Insignificant Activities: 1 APPENDIX B 1 Reporting Requirements and Definitions 1 Monitoring and Permit Deviation Report - Part I 5 Monitoring and Permit Deviation Report -Part II 7 Monitoring and Permit Deviation Report -Part III 9 APPENDIX C 1 Required Format for Annual Compliance Certification Reports 1 APPENDIX D 1 Notification Addresses 1 APPENDIX E 1 Permit Acronyms 1 APPENDIX F 1 Permit Modifications 1 APPENDIX G 1 VOC Correlation Equations 1 Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 1 SECTION I - General Activities and Summary 1. Permitted Activities 1.1 This facility is a decommissioned nuclear power generating facility. Nuclear operations ceased at this facility in 1989 and decommissioning was completed in 1996. The repowering of this facility utilized a large portion of the non-nuclear assets such as the steam turbine, the cooling water system, condensate and feed water system, water treatment systems, and a substation. This facility consists of five (5) natural gas fired combustion turbines and three (3) heat recovery steam generators (HRSG). The capacity of the steam turbine is 330 megawatts (MW). The output rating of the entire plant varies based on ambient temperature with more generation in the winter and less generation in the summer. The facility generates approximately 965 MW (summer rating) of electricity. The turbines are numbered as follows: T001 (turbine No.1) is the steam turbine, T002 (turbine No. 2) is the No. 1 combustion turbine, T003 (turbine No. 3) is the No. 2 combustion turbine, T004 (turbine No. 4) is the No. 3 combustion turbine, T005 (turbine No. 5) is the No. 4 combustion turbine and T006 (turbine No. 6) is the No. 5 combustion turbine. Combustion turbines 2 and 3 each generate approximately 135 MW of electricity and each HSRG, which includes duct burners for supplemental firing, will add approximately 100 MW of electrical capacity. Combustion turbine 4, which commenced operation in April 2001, generates approximately 135 MW of electricity and the HRSG, which includes a duct burner for supplemental firing, will add approximately 100 MW of electrical capacity. These combustion turbines and HRSG combinations can be run in three modes: simple cycle (combustion turbine only), combined cycle (combustion turbine with HRSG) with no fuel fired in the duct burners and combined cycle (combustion turbine with HRSG) with fuel fired in the duct burners. In simple cycle operation, exhaust from the combustion turbine is discharged through the bypass stack. In combined cycle operation, the exhaust gas from the turbine passes through the HRSG first and then exits out the HRSG stack. Combustion turbines No. 5 and 6, which commenced operation in April 2009, each generate approximately 146 MW. Turbines 5 and 6 can only operate in simple cycle mode. In addition to the combustion turbines, significant emission units at this facility consist of an auxiliary boiler fueled by natural gas, one cooling water tower, one service water tower, a 500 gal gasoline tank, cold cleaner solvent vats, two (2) diesel-fired engines driving an emergency generator and one (1) diesel-fired engine driving an emergency fire pump. The facility is located approximately three miles north and west of Platteville, Colorado. The area in which the plant operates is designated as attainment for all criteria pollutants except ozone. It is classified as non-attainment for ozone and is part of the 8-hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1. There are no affected states within 50 miles of the plant. Rocky Mountain National Park, Eagle's Nest National Wilderness Area and Rawah National Wilderness Area, Federal Class I designated areas, are within 100 kilometers of the plant. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 2 1.2 Until such time as this permit expires or is modified or revoked, the permittee is allowed to discharge air pollutants from this facility in accordance with the requirements, limitations, and conditions of this permit. 1.3 This Operating Permit incorporates the applicable requirements contained in the underlying construction permits, and does not affect those applicable requirements, except as modified during review of the application or as modified subsequent to permit issuance using the modification procedures found in Regulation No. 3, Part C. These Part C procedures meet all applicable substantive New Source Review requirements of Part B. Any revisions made using the provisions of Regulation No. 3, Part C shall become new applicable requirements for purposes of this Operating Permit and shall survive reissuance. This Operating Permit incorporates the applicable requirements (except as noted in Section II) from the following Colorado Construction Permits: 94WE609 (PSD), 97WE0189, 99WE0762 PSD and 07AD1100. 1.4 All conditions in this permit are enforceable by US Environmental Protection Agency, Colorado Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless otherwise specified. State-only enforceable conditions are: Permit Condition Number(s): Section II - Conditions 1.13, 2.14 and 8.16 (Opacity) and Section V - Conditions 3.g (last paragraph), 14 and 18 (as noted). 1.5 All information gathered pursuant to the requirements of this permit is subject to the Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions in Section V of this permit. Either electronic or hard copy records are acceptable. 2. Alternative Operating Scenarios P g 2.1 The permittee shall be allowed to make the following changes to its method of operation without applying for a revision of this permit. 2.1.1 Turbines No. 2, 3 and 4 may be operated as follows: 2.1.1.1 The combustion turbines may be operated as simple cycle combustion turbines as specified under Section II. 2.1.1.2 The combustion turbines may be operated as combined cycle combustion turbines with no supplemental fuel being fired in the duct burners as specified under Section II. 2.1.1.3 The combustion turbines may be operated as combined cycle combustion turbines with supplemental fuel being fired in the duct burners as specified under Section II. 2.2 The facility must contemporaneously with making a change from one operating scenario to another, maintain records at the facility of the scenario under which it is operating (Colorado Regulation No. 3, Part A, Section IV.A.1). Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 3 3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) 3.1 This facility is categorized as a PSD major stationary source (potential to emit of PM, PM:o, NOx and CO > 100 tons/year). Future modifications at this facility resulting in a significant net emissions increase (see Colorado Regulation No. 3, Part D, Sections II.A.27 and 44) or a modification which is major by itself(Potential to Emit > 100 tons/year) for any pollutant listed in Colorado Regulation 3, Part D, Section II.A.44 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. 3.2 This source is categorized as a NANSR major stationary source (Potential to Emit of NOx >100 tons/year). Future modifications at this facility resulting in a significant net emissions increase (see Regulation No. 3, Part D, Sections II.A.27 and 44) for VOC or NOx or a modification which is major by itself (Potential to Emit > 100 tons/year of either VOC or NOx) may result in the application of the NANSR review requirements. 3.3 There are no other Operating Permits associated with this facility for purposes of determining applicability of NANSR and PSD review regulations. 4. Accidental Release Prevention Program (112(r)) 4.1 Based on the information provided by the applicant, this facility is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act). 5. Compliance Assurance Monitoring (CAM) 5.1 The following emission points at this facility use a control device to achieve compliance with an emission limitation or standard to which they are subject and have pre-control emissions that exceed or are equivalent to the major source threshold. They are therefore subject to the provisions of the CAM program as set forth in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV: Unit T004—Combustion Turbine See Section II, Condition 2.9 for compliance assurance monitoring requirements. Operating Permit Number: 97OPW E180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 4 6. Summary of Emission Units 6.1 The emissions units regulated by this permit are the following: Emission AIRS Description Startup Date Pollution Control Unit No./ Point Device Facility Number ID. T002 004 General Electric Combustion Turbine,Model No.GE February 1996 Dry Low NOx Frame 7FA,Serial No.296677,rated at 1773 MMBtu/hr (simple cycle Burners (turbine 1,223 MMBtu/hr and duct burner 450 MMBtu/hr), operation) Natural Gas Fired. Turbine May be Operated in March 1998 Conjunction with a HRSG(combined cycle operation) (combined cycle Equipped with Natural Gas Fired Duct Burners. operation) T003 005 General Electric Combustion Turbine,Model No.GE January 1999 Dry Low NOx Frame 7FA,Serial No.297096,rated at 1823 MMBtu/hr (simple cycle Burners (turbine 1,373 MMBtu/hr and duct burner 450 MMBtu/hr), operation) Natural Gas Fired. Turbine May be Operated in April 1999 Conjunction with a HRSG(combined cycle operation) (combined cycle Equipped with Natural Gas Fired Duct Burners. operation) T004 008 General Electric Combustion Turbine,Model PG7241 April 2001 Turbine-Dry (FA), Serial No.297457,rated at 1953 MMBtu/hr(turbine Low NOx 1,531 MMBtu/hr and duct burner 422 MMBtu/hr),Natural HRSG— Gas Fired. Turbine May be Operated in Conjunction with a Selective HRSG(combined cycle operation)Equipped with One(1) Catalytic Vogt-NEM Natural Gas Fired Duct Burner. Reduction(SCR) B001 001 Babcock and Wilcox,Model FM-1656,External 1969,modified Uncontrolled Combustion Auxiliary Boiler,Serial No.NB22845,Rated September 1997 to at 70.23 MMBtu/hr. Natural Gas Fired. burn only natural gas M001 006 One(1)Marley Cooling Water Tower,Model No. Cross- 1976 Drift Eliminators Flow DF-664,Design Rate of 156,000 gpm and One(1) Marley Service Water Tower,Model No.6-48-3-02, Design Rate of 15,000 gpm. M002 N/A Gasoline Storage Tank,500 gallons,aboveground Fall 2015 Uncontrolled M003 N/A Cold Cleaner Solvent Vats Uncontrolled T005 010 General Electric Combustion Turbine,Model No.7FA, April 2009 Advanced Dry Serial Number 298106,rated at 1,467 MMBtu/hr,Natural Low NOx Gas Fired. Combustion System T006 011 General Electric Combustion Turbine,Model No.7FA, April 2009 Advanced Dry Serial Number 298107,rated at 1,467 MMBtu/hr,Natural Low NOx Gas Fired. Combustion System Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE 180 Page 5 Emission AIRS Description Startup Date Pollution Control Unit No./ Point Device Facility Number ID. M004 N/A Two(2)Caterpillar,Model No. SP321P00, Serial Nos. Uncontrolled 126906 and 126907,diesel-fired engines,each rated at 1,800 hp,with a combined fuel rate of 200 gal/hr.The engines are run together to drive an emergency generator. One(1)Cummins,Model No. 6BTA5.963,Serial No. 46927201,rated at 255 hp with fuel rate of 3 gal/hr. The engine runs an emergency fire pump. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 6 SECTION II- Specific Permit Terms 1. T002 & T003—Two (2) Combustion Turbines Capable of Simple or Combined Cycle Operation Simple Cycle-Two (2) Combustion Turbines Combined Cycle(No Supplemental Fuel) - Two (2) Combustion Turbines & Two (2) Heat Recovery Steam Generators (HRSG)with No Fuel Fired in Duct Burners Combined Cycle (With Supplemental Fuel)—Two (2) Combustion Turbines & Two (2)Heat Recovery Steam Generators (HRSG)with Fuel Fired in Duct Burners Unless otherwise specified, the limitations identified are per combustion turbine/HRSG Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number BACT 1.1 N/A N/A N/A See Condition 1.1 Requirements NOx 1.2 Simple Cycle Mode or Combined N/A Continuous Continuously Cycle Mode—No Supplemental Emission Fuel: Monitoring 15 ppmvd @ 15%O2 on a 1-hr System average,except as provided for below During Startup and Shutdown: 100 ppmvd @ 15%O2 on a 1-hr average During Combustion Tuning and Testing(not to exceed 90 hrs/yr per for turbines T002,T003&T004 combined): 100 ppmvd @ 15%O2 on a 1-hr average Combined Cycle Mode—With Supplemental Fuel: 17 ppmvd @ 15%O2 on a 1-hr average,except as provided for below During Startup and Shutdown: 100 ppmvd @ 15%O2 on a 1-hr average During Combustion Tuning and Testing(not to exceed 90 hrs/yr per for turbines T002,T003&T004 combined): 100 ppmvd @ 15%O2 on a 1-hr average N/A I 496.1 tons/yr Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 7 Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number CO 1.3 Simple Cycle Mode or Combined N/A Continuous Continuously Cycle Mode—No Supplemental Emission Fuel: Monitoring 15 ppmvd @ 15%O2 on a 1-hr System average,except as provided for below During Startup and Shutdown: 1000 ppmvd @ 15%O,on a 1-hr average and 2,060 lbs/hr During Combustion Tuning and Testing(not to exceed 90 hrs/yr per for turbines T002,T003&T004 combined): 1000 ppmvd @ 15%O2 on a 1-hr average and 2,060 lbs/hr Combined Cycle Mode—With Supplemental Fuel: 48 ppmvd @ 15%O,on a 1-hr average,except as provided for below During Startup and Shutdown: 1000 ppmvd @ 15%O2 on a 1-hr average and 2,060 lbs/hr During Combustion Tuning and Testing(not to exceed 90 hrs/yr per for turbines T002,T003&T004 combined): 1000 ppmvd @ 15%O2 on a 1-hr average and 2,060 lbs/hr N/A I 465.4 tons/yr SO2 1.4 For Each Combustion Turbine: N/A Fuel Restriction Only Pipeline 0.35 lbs/MMBtu,on a 3-Hour Rolling Quality Natural Average Gas is Used as For Each Combustion Turbine: Fuel 150 ppmvd @ 15%O2 or Use of Fuel Which Contains Less than 0.8 Weight %Sulfur For Each Duct Burner: 0.20 lbs/MMBtu,on a 30-Day Rolling Average N/A 4.7 tons/yr Continuous Continuously Monitoring System Operating Permit Number: 97OPWF180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 8 Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number VOC 1.5 Simple Cycle and Combined Cycle N/A Continuous Continuously —No Supplemental Fuel: Monitoring 1.4 ppmvd @ 15%O2,on a 1-Hour System Average Combined Cycle—With Supplemental Fuel: 1.7 ppmvd @ 15%O2,on a 1-Hour Average N/A I 21.4 tons/yr PM 1.6 For Each Combustion Turbine: N/A Fuel Restriction Only Pipeline 0.1 lbs/MMBtu,the average of three Quality Natural (3) 1-hr tests Gas is Used as For Each Combustion Turbine and Fuel Duct Burner Together: 0.1 lbs/MMBtu,the average of three (3) 1-hr tests For Each Duct Burner: 0.03 lbs/M1v[Btu,the average of three (3)2-hr tests N/A 39.4 tons/yr See Condition Recordkeeping, Monthly,Every 1.6 Calculation and Five(5)Years Performance Testing PKo 1.7 9 lbs/hr 39.4 tons/yr See Condition Recordkeeping, Monthly,Every 1.7 Calculation and Five(5)Years Performance Testing Natural Gas 1.8 N/A Simple Cycle N/A Recordkeeping Monthly Usage and/or Combined Cycle Without Supplemental Fuel: 12,507 MMscf/yr Combined Cycle With Supplemental Fuel: 16,090 MMscf/yr Sulfur Content 1.9 N/A N/A N/A See Condition 1.9 of Natural Gas Continuous 1.10 N/A N/A N/A See Condition 1.10 Emission Monitoring System Requirements Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 9 Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number NSPS General 1.11 N/A N/A N/A As Required by Subject to Provisions NSPS General NSPS General Provisions Provisions Performance 1.12 N/A N/A N/A EPA Reference See Condition Test Methods 1.12 Requirements Opacity-State 1.13 Not to Exceed 20% N/A Fuel Restriction Only Pipeline Only Quality Natural Gas is Used as Fuel Opacity 1.14 Not to Exceed 20%Except as N/A Provided for in 1.15 Below Opacity 1.15 For Certain Operational Activities- N/A Not to Exceed 30%,for a Period or Periods Aggregating More than Six (6)Minutes in any 60 Consecutive Minutes NSPS Opacity 1.16 Not to Exceed 20%(6-minute N/A Applies to Duct average).Except for One Six Minute Burner Only Average Not to Exceed 27%Per Hour Acid Rain 1.17 See Section III of this Permit Certification Annually Requirements 1.1 These combustion turbines/HRSGs/duct burners are subject to the requirements of the Prevention of Significant Deterioration (PSD) Program. 1.1.1 Best Available Control Technology (BACT) shall be applied for control of Nitrogen Oxides (NOx), Carbon Monoxide (CO), Volatile Organic Compounds (VOC) and Particulate Matter (PM and PM10). BACT has been determined as follows: 1.1.1.1 BACT for NOx has been determined to be Dry Low NOx (DLN) Combustion Systems with emission limits as identified in Condition 1.2.1 (Colorado Construction Permit 94WE609 PSD, as modified under the provisions of Section I, Condition 1.3). The DLN combustion systems shall be operated and maintained in accordance with manufacturer's recommendations and good engineering practices. 1.1.1.2 BACT for CO has been determined to be good combustion practices/monitoring systems capable of meeting the emission limitations in Condition 1.3.1 (Colorado Construction Permit 94WE609 PSD). 1.1.1.3 BACT for VOC has been determined to be good combustion practices/monitoring systems capable of meeting the emission limitations in Condition 1.5.1 (Colorado Construction Permit 94WE609 PSD). 1.1.1.4 BACT for PM and PKo has been determined to be use of pipeline quality Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 10 natural gas (Colorado Construction Permit 94WE609 PSD). 1.2 Nitrogen Oxide (NOx) emissions shall not exceed the following limitations: 1.2.1 The BACT emission limits for each combustion turbine/HRSG/duct burner are as follows (Colorado Construction Permit 94WE609 PSD, as modified under the provisions of Section I, Condition 1.3): 1.2.1.1 Except as provided for in Conditions 1.2.1.3 and 1.2.1.4 below, emissions of NOx shall not exceed 15 ppmvd at 15 % O2, on a 1-hour average. This standard applies when operating in either simple cycle mode or combined cycle mode without supplemental fuel. 1.2.1.2 Except as provided for in Conditions 1.2.1.3 and 1.2.1.4 below, emissions of NOx shall not exceed 17 ppmvd at 15 % O2, on a 1-hour average. This standard applies when operating in combined cycle mode with supplemental fuel. 1.2.1.3 During periods of startup and shutdown emissions of NOx shall not exceed 100 ppmvd at 15% O2, on a 1-hr average. 1.2.1.4 During periods of combustion tuning and testing emissions of NOx shall not exceed 100 ppmvd at 15% O2, on a 1-hour average. Use of this NOx emission limit for purposes of combustion tuning and testing shall not exceed 90 hours in any calendar year for turbines T002, T003 and T004 combined. Records of the number of hours each turbine undergoes combustion tuning and testing shall be recorded and maintained and made available to the Division upon request. 1.2.1.5 "Startup" means the setting in operation of any air pollution source for any purpose. Setting in operation for these turbines begins when fuel is first combusted in the turbine or when commencing a combined cycle startup from simple cycle operation and ends 30 minutes after the turbine reaches Mode 6 operation. Mode 6 refers to the condition when all six burner nozzles are being fired. The station control system and each unit's data acquisition and handling system (DAHS) utilized by the continuous emission monitoring systems indicates which Mode the turbine is operating in. A record of when Mode 6 combustion configuration plus 15 minutes is achieved is stored in each unit's DAHS. 1.2.1.6 "Shutdown" means the cessation of operation of any air pollution source for any purpose. The cessation of operation for these turbines begins when the command signal is initiated to shutdown the unit and ends when fuel is no longer being fired in the turbine. 1.2.1.7 "Combustion Tuning and Testing" means the operation of the unit for the purpose of performing combustion tuning and testing operations after a unit overhaul or as part of routine maintenance operations. Combustion tuning and testing can occur throughout the range of the operating Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit # 97OPWE180 Page 11 conditions. Compliance with these NOx limitations shall be monitored using the continuous emission monitoring system (CEMS) required by Condition 1.10, as follows: 1.2.1.8 Except as provided for in Condition 1.2.1.9, all valid CEMS concentration (ppm) data points, excluding startup and shutdown data points shall, at the end of each clock hour, be summarized to generate the one-hour average NOx concentration in accordance with the requirements in 40 CFR Part 75 and Condition 5.2.1.3.b of this permit. Data used to generate the one-hour average NOx concentration shall not include replaced data, nor shall the data be bias-adjusted. Replaced data shall be reported as monitor down time in the quarterly reports required by Condition 5.5. Each clock hour average NOx concentration shall be compared to the limitations in Conditions 1.2.1.1, 1.2.1.2 or 1.2.1.4, as appropriate. 1.2.1.9 All valid CEMS concentration (ppm) data points, excluding non-startup and non-shutdown data points shall, at the end of each clock hour be summarized to generate the average NOx concentration in accordance with the requirements in 40 CFR Part 75 and Condition 5.2.1.3.b of this permit. Data used to generate the average NOx concentration shall not include replaced data, nor shall the data be bias-adjusted. Replaced data shall be reported as monitor down time in the quarterly reports required by Condition 5.5. Each clock hour average NOx concentration shall be compared to the limitation in Condition 1.2.1.3. In the event that the startup ends within a clock hour or the shutdown begins within a clock hour, all non-startup and/or non-shutdown concentration (ppm) data points within that clock hour shall be averaged together to generate the average NOx concentration in accordance with the requirements in 40 CFR Part 75 and Condition 5.2.1.3.b of this permit and that average concentration shall be compared to the limitations in Conditions 1.2.1.1, 1.2.1.2 or 1.2.1.4, as appropriate. 1.2.1.10 The emission limitation in Condition 1.2.1.4 applies to any clock hour in which combustion tuning and testing activities occur. 1.2.2 Nitrogen Oxide (NOx) emissions from each combustion turbine/HRSG/duct burner shall not exceed 496.1 tons/yr(Colorado Construction Permit 94WE609 PSD, as modified under the provisions of Section I, Condition 1.3). Compliance with annual emission limitation shall be monitored using the Continuous Emission Monitoring System (CEMS) required by Condition 1.10. For any hour in which fuel is combusted in the turbines, including periods of startup, shutdown and malfunction, the permittee shall program the DAHs to calculate lb/hr NOx emissions in accordance with the requirements in Condition 5.2.1.3.b of this permit and 40 CFR Part 75, including any replaced data and the data shall be bias-adjusted, if warranted. Operating Permit Number: 97OPWEI 80 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 12 Specifically hourly mass NOx emissions (in lb/hr) shall be calculated by multiplying the hourly NOx lb/MMBtu value (which includes replaced or bias-adjusted data, as applicable) by the hourly heat input value (MMBtu/hr) (which includes replaced data from the fuel flow measurement, as applicable). The hourly NOx lb/MMBtu and heat input values shall be determined using equations F-5 or F-6, as appropriate for the diluent monitored by the CEMS and F-20 in Appendix F of 40 CFR Part 75. The resulting NOx lb/hr value is then multiplied by the unit operating time for that hour to produce a NOx lbs value. Hourly NOx mass emissions (lbs) shall be summed and divided by 2000 lb/ton to determine monthly NOx emissions (in tons). Monthly emissions (in tons) from each combustion turbine/HRSG/duct burner shall be used in a twelve month rolling total of emissions to monitor compliance with the annual emission limitation. Each month a new twelve month total shall be calculated using the previous twelve months data. 1.3 Carbon Monoxide (CO)emissions shall not exceed the following limitations: 1.3.1 The BACT Carbon Monoxide (CO) emission limit for each combustion turbine/HRSG/duct burner is as follows (94WE609 PSD, as modified under the provisions of Section I, Condition 1.3): 1.3.1.1 Except as provided for in Conditions 1.3.1.3 and 1.3.1.4 below, emissions of CO shall not exceed 15 ppmvd at 15% O2, on a 1-hour average. This standard applies when operating in either simple cycle mode or combined cycle mode without supplemental fuel. 1.3.1.2 Except as provided for in Conditions 1.3.1.3 and 1.3.1.4 below, emissions of CO shall not exceed 48 ppmvd at 15% O2, on a 1-hour average. This standard applies when operating in combined cycle mode with supplemental fuel. 1.3.1.3 During periods of startup and shutdown emissions of CO shall not exceed 1,000 ppmvd at 15% O2, on a 1-hr average and 2,060 lbs/hr. In the event that emissions of CO exceed 1,000 ppmvd at 15% O2, it shall be considered a violation of the CO BACT emission limit if CO emissions exceed 2,060 lbs/hr and not a violation if emissions are less than or equal to 2,060 lbs/hr. 1.3.1.4 During periods of combustion tuning and testing emissions of CO shall not exceed 1,000 ppmvd at 15% O2, on a 1-hour average and 2,060 lbs/hr. In the event that emissions of CO exceed 1,000 ppmvd at 15% O2, it shall be considered a violation of the CO BACT emission limit if CO emissions exceed 2,060 lbs/hr and not a violation if emissions are less than or equal to 2,060 lbs/hr. Use of this CO emission limit for purposes of combustion tuning and testing shall not exceed 90 hours in any calendar year for turbines T002, T003 and T004 combined. Records of the number of hours each turbine undergoes combustion tuning and testing shall be Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 13 recorded and maintained and made available to the Division upon request. 1.3.1.5 "Startup" shall have the same definition as provided for in Condition 1.2.1.5. 1.3.1.6 "Shutdown" shall have the same definition as provided for in Condition 1.2.1.6. 1.3.1.7 "Combustion Tuning and Testing" shall have the same definition as provided for in Condition 1.2.1.7. Compliance with these CO limitations shall be monitored using the continuous emission monitoring system (CEMS)required by Condition 1.10, as follows: 1.3.1.8 Except as provided for in Condition 1.3.1.9, all valid CEMS concentration (ppm) data points, excluding startup and shutdown data points shall, at the end of each clock hour be summarized to generate the average CO concentration in accordance with the requirements in 40 CFR Part 75 and Condition 5.2.1.3.b of this permit. Data used to generate the one-hour average CO concentration shall not include replaced data, nor shall the data be bias-adjusted. Replaced data shall be reported as monitor down time in the quarterly reports required by Condition 5.5. Each clock hour average CO concentration shall be compared to the limitations in Conditions 1.3.1.1, 1.3.1.2 or 1.3.1.4, as appropriate. 1.3.1.9 All valid CEMS concentration (ppm) data points, excluding non-startup and non-shutdown data points shall, at the end of each clock hour be summarized to generate the average CO concentration in accordance with the requirements in 40 CFR Part 75 and Condition 5.2.1.3.b of this permit. Data used to generate the average CO concentration shall not include replaced data, nor shall the data be bias-adjusted. Replaced data shall be reported as monitor down time in the quarterly reports required by Condition 5.5. Each clock hour average CO concentration shall be compared to the limit in Condition 1.3.1.3. In the event that a startup ends within a clock hour or shutdown begins within a clock hour, all non-startup and/or non-shutdown concentration (ppm) data points within that clock hour shall be averaged together to generate the average CO concentration in accordance with the requirements in 40 CFR Part 75 and Condition 5.2.1.3.b of this permit and that average concentration shall be compared to the limitations in Conditions 1.3.1.1, 1.3.1.2 or 1.3.1.4, as appropriate. 1.3.1.10 The emission limitation in Condition 1.3.1.4 applies to any clock hour in which combustion tuning and testing activities occur. 1.3.2 Carbon Monoxide (CO) emissions from each combustion turbine/HRSG/duct burner shall not exceed 465.4 tons/yr(Colorado Construction Permit 94WE609 PSD, as modified under the provisions of Section 1, Condition 1.3). Compliance with this Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 14 requirement shall be monitored using the Continuous Emission Monitoring System (CEMS) required by Condition 1.10. For any hour in which fuel is combusted in the turbines, including periods of startup, shutdown and malfunction, the permittee shall program the DAHs to calculate lb/hr CO emissions in accordance with the requirements in Condition 5.2.1.3.b of this permit and 40 CFR Part 75, including any replaced data, if warranted. Specifically hourly mass CO emissions (in lb/hr) shall be calculated by multiplying the hourly CO lb/MMBtu value (which includes replaced date in accordance with the provisions in Part 75 for NOx replacement, as applicable) by the hourly heat input value (MMBtu/hr) (which includes replaced data from the stack flow measurement, as applicable). The hourly CO lb/MMBtu and heat input values shall be determined using equations F-5 or F-6 (for NOR), as appropriate for the diluent monitored by the CEMS and F-20 in Appendix F of 40 CFR Part 75. The resulting CO lb/hr value is then multiplied by the unit operating time for that hour to produce a CO lbs value. Hourly CO mass emissions (lbs) shall be summed and divided by 2000 lb/ton to determine monthly CO emissions (in tons). Monthly emission (in tons) from each combustion turbine/HRSG/duct burner shall be used in a twelve month rolling total of emissions will be maintained to monitor compliance with the annual emission limitation. Each month a new twelve month total shall be calculated using the previous twelve months data. 1.4 Sulfur Dioxide (SO2) emissions shall not exceed the following limitations: 1.4.1 Sulfur Dioxide (SO2) emissions from each combustion turbine shall not exceed 0.35 lbs/MMBtu, on a 3-hour rolling average (Colorado Regulation No. 1, Section VI.B.4.c.(ii) and VI.B.2). In the absence of credible evidence to the contrary, compliance with the sulfur dioxide limitation is presumed since only pipeline quality natural gas is permitted to be used as fuel in the turbines. 1.4.2 Each combustion turbine shall meet one of the following requirements: 1.4.2.1 Sulfur Dioxide (SO2) emissions from each combustion turbine shall not exceed 150 ppmvd at 15% O2 measured at ISO Standard Ambient Conditions (Colorado Construction Permit 94WE609 PSD) OR 1.4.2.2 No fuel, which contains sulfur in excess of 0.8 percent by weight, shall be used in these combustion turbines (40 CFR Part 60, Subpart GG § 60.333(b), as adopted by reference in Colorado Regulation No. 6, Part A). In the absence of credible evidence to the contrary, compliance with the above requirements is presumed since only pipeline quality natural gas is permitted to be used as fuel. The natural gas used as fuel shall meet the requirements in Condition 1.9. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit # 97OPWE180 Page 15 1.4.3 Sulfur Dioxide (SO2) emissions from each duct burner shall not exceed 0.20 lbs/MMBtu on a 30-day rolling average (40 CFR Part 60 Subpart Da § 60.43Da(b)(2), as adopted by reference in Colorado Regulation No. 6, Part A). In the absence of credible evidence to the contrary, compliance with the sulfur dioxide limitations is presumed since only pipeline quality natural gas is permitted to be used as fuel in the duct burners. 1.4.4 Sulfur Dioxide (SO2) emissions from each combustion turbine/HRSG/duct burner shall not exceed 4.7 tons/yr (Colorado Construction Permit 94WE609 PSD, as modified under the provisions of Section I, Condition 1.3). Compliance with the annual limitation shall be monitored using the continuous monitoring system required by 40 CFR Part 75, as adopted by reference in Colorado Regulation No. 18 A twelve month rolling total of emissions will be maintained to monitor compliance with the annual emission limitation. Each month a new twelve month total shall be calculated using the previous twelve months data. 1.5 Volatile Organic Compound(VOC) emissions shall not exceed the following limitations: 1.5.1 The BACT Volatile Organic Compound (VOC) emission limit for each combustion turbine/HRSG/duct burner is as follows (Colorado Construction Permit 94WE609 PSD, as modified under the provisions of Section I, Condition 1.3): 1.5.1.1 Emissions of VOC shall not exceed 1.4 ppmvd at 15% O2, on a 1-hour average. This standard applies when operating in either simple cycle mode or combined cycle mode without supplemental fuel. 1.5.1.2 Emissions of VOC shall not exceed 1.7 ppmvd at 15% O2, on a 1-hour average. This standard applies when operating in combined cycle mode with supplemental fuel. Compliance with the VOC limitations shall be monitored using the VOC correlation (VOC emissions vs. heat input) that has been approved by the Division and programmed into the data acquisition and handling system (DAHS). The data in the DAHS shall at the end of each hour, be summarized to generate the average VOC concentration. The equations used in the VOC correlation are included in Appendix G of this permit. 1.5.2 Volatile Organic Compounds emissions from each combustion turbine/HRSG/duct burner shall not exceed 21.4 tons/yr (Colorado Construction Permit 94WE609 PSD). Compliance with the VOC limitation shall be monitored using the VOC correlation (VOC emissions vs. heat input) that has been approved by the Division and programmed into the data acquisition and handling system (DAHS). The equations used in the VOC correlation are included in Appendix G of this permit. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 16 A twelve month rolling total of emissions will be maintained to monitor compliance with the annual emission limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 1.6 Particulate Matter (PM) emissions shall not exceed the following limitations: 1.6.1 Particulate Matter (PM) emissions from each combustion turbine shall not exceed 0.1 lbs/MMBtu, the average of three (3) 1-hr tests (Colorado Regulation No. 1, Section III.A.1.c). In the absence of credible evidence to the contrary, compliance with the particulate matter limitation is presumed since only pipeline quality natural gas is permitted to be used as fuel in the turbines. 1.6.2 Particulate Matter (PM) emissions from each combustion turbine and duct burner together shall not exceed 0.1 lbs/MMBtu, the average of three (3) 1-hr tests (Colorado Regulation No. 1, Sections II.A.1.b, c and d). In the absence of credible evidence to the contrary, compliance with the particulate matter limitation is presumed since only pipeline quality natural gas is permitted to be used as fuel in the turbines and duct burners. Note that the numeric PM standards for combined cycle operation were determined using the design heat input for the turbines (1,323 MMBtu/hr for Turbine 2 and 1,373 MMBtu/hr for Turbine 3) and duct burners (each 450 MMBtu) in the following equation: PE (turbine +duct burner) = PET x FIT+13EDBIDB FIT+FIDB Where PE=particulate standard in lbs/MMBtu PEDB = 0.5 x (FI)-°'26 lbs/MMBtu PET= 0.1 lbs/MMBtu FI= fuel input in MMBtu/hr 1.6.3 Particulate Matter (PM) emissions from each duct burner shall not exceed 0.03 lbs/MMBtu, average of three (3) 2-hr tests (Colorado Construction Permit 94WE609 PSD). In the absence of credible evidence to the contrary, compliance with the particulate matter limitation is presumed since only pipeline quality natural gas is permitted to be used as fuel in the duct burners. The PM emission limits are not applicable during times of startup, shutdown and malfunction (40 CFR Part 60 Subpart Da § 60.46Da(c), as adopted by reference in Colorado Regulation No. 6, Part A). 1.6.4 Particulate Matter (PM) emissions from each combustion turbine/HRSG/duct burner shall not exceed 39.4 tons/yr (Colorado Construction Permit 94WE609 PSD, as modified under the provisions of Section I, Condition 1.3). Compliance with this limitation shall be monitored as follows: Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 17 1.6.4.1 Monthly emissions of PM shall be calculated using the emission factors identified in the table below in the following equation: Emission Factor Source of Emission Factor (lb/MMBtu) Unit PM I PMto Unit 2—Simple Cycle 0.004 0.004 May 2,2014 Unit 2—Combined Cycle 0.002 0.002 March 28,2014 Unit 3—Simple Cycle 0.003 0.003 March 26,2014 Unit 3—Combined Cycle 0.002 0.002 March 27,2014 Tons/month=[EF(lbs/MMBtu)x monthly heat input to turbine(MMBtu/mo)l 2000 lbs/ton The monthly heat input to the turbine/HRSG/duct burner shall be determined using the data acquisition and handling system (DAHS) for the CEMS required by Condition 1.10. A twelve month rolling total of emissions will be maintained to monitor compliance with the annual emission limitation. Each month a new twelve month total shall be calculated using the previous twelve months data. 1.6.4.2 Performance testing shall be conducted in accordance with the requirements in Condition 1.12. 1.7 Particulate Matter less than 10 microns (PMio) emissions from each combustion turbine/HRSG/duct burner shall not exceed 9 lbs/hr and 39.4 tons/yr (Colorado Construction Permit 94WE609 PSD, as modified under the provisions of Section I, Condition 1.3). Compliance with these limitations shall be monitored as follows: 1.7.1 Monthly emissions of PM 10 shall be calculated using the emission factors identified in the table in Condition 1.6.4.1 in the following equation: Tons/month=[EF(lbs/MMBtu)x monthly heat input to turbine(MMBtu/mo)1 2000 lbs/ton The monthly heat input to the turbine/duct burner shall be determined using the data acquisition and handling systems (DAHS) for the CEMS required by Condition 1.10. A twelve month rolling total of emissions will be maintained to monitor compliance with the annual emission limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. Compliance with the hourly limitation shall be monitored by dividing the monthly emissions by the number of hours operated each month. 1.7.2 Performance testing shall be conducted in accordance with the requirements in Condition 1.12. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado P Y Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 18 1.8 Natural Gas Consumption for each combustion turbine/HRSG/duct burner shall not exceed the following limitations: 1.8.1 When operating in either simple cycle mode or combined cycle mode without supplemental fuel natural gas consumption shall not exceed 12,507 MMscf/yr (Colorado Construction Permit 94WE609 PSD, as modified under the provisions of Section I, Condition 1.3). 1.8.2 When operating in combined cycle mode with supplemental fuel natural gas consumption shall not exceed 16,090 MMscf/yr (Colorado Construction Permit 94WE609 PSD, as modified under the provisions of Section I, Condition 1.3). The natural gas consumption for each combustion turbine/duct burners shall be monitored using the data acquisition and handling systems (DAHS) for the continuous emission monitoring system (CEMS) required by Condition 1.10. Monthly natural gas consumption from each turbine/duct burner shall be used in rolling twelve month total to monitor compliance with the annual natural gas consumption limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. Note that if any time during the 12-month rolling period natural gas has been fired in the duct burners, the 16,090 MMscf/yr natural gas consumption limit shall apply. The permitteee shall maintain records of the operating mode (simple cycle or combined cycle without fuel fired in the duct burners versus combined cycle with fuel fired in the duct burners) of each turbine/HRSG/duct burner. 1.9 The permittee shall maintain records demonstrating that the natural gas burned has a total sulfur content less than 0.5 grains/100 SCF. Natural gas that meets this sulfur limitation is considered pipeline quality natural gas as defined in 40 CFR Part 72. The demonstration shall be made using any of the methods identified in 40 CFR Part 75 Appendix D, Section 2.3.1.4.(a). These records shall be made available to the Division upon request. 1.10 For each combustion turbine/HRSG/duct burner, continuous emission monitoring systems (CEMS) shall be installed, certified, calibrated, maintained and operated for measuring NOx (including diluent gas either CO2 or O2) and CO emissions (Colorado Construction Permit 94WE609 PSD, as modified under the provisions of Section I, Condition 1.3 and 40 CFR Part 75). The CEMS shall meet the requirements in Condition 5 of this permit. Monthly emissions of NOx and CO from the continuous emission monitoring system shall be used as specified by Conditions 1.2.2 and 1.3.2 to monitor compliance with the annual NOx and CO emission limitations. 1.11 These combustion turbines/HRSGs/duct burners are subject to 40 CFR Part 60, Subpart A - General Provisions, as adopted by reference in Colorado Regulation No. 6, Part A. Specifically, these units are subject to the following requirements: 1.1 1.1 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 Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 19 includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gasses discharged to the atmosphere (Colorado Construction Permit 94WE609 PSD and 40 CFR Part 60 Subpart A § 60.12) 1.11.2 At all times, including periods of startup, shutdown, and malfunction owners and operators shall to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Division which may include, but is not limited to monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source (Colorado Construction Permit 94WE609 PSD and 40 CFR Subpart A § 60.11(d)). 1.12 The source shall conduct performance tests for each combustion turbine/HRSG/duct burner, when operating in simple cycle mode and combined cycle mode with supplemental fuel every five (5) years to monitor compliance with the PM and PM10 emission limitations. This performance test shall be conducted in accordance with the requirements of 40 CFR Part 60 Subpart A § 60.8 using EPA Test Methods 5 and 202. Note that the previous performance tests for these units were completed as follows: Unit Performance Test Date Unit 2—Simple Cycle May 2,2014 Unit 2—Combined Cycle March 28,2014 Unit 3—Simple Cycle March 26,2014 Unit 3—Combined Cycle March 27,2014 The test protocol, test, and test report must be in accordance with the requirements of the APCD Compliance Test Manual (https://www.colorado.gov/pacific/cdphe/inspections-and- enforcement). A stack testing protocol shall be submitted for Division approval at least forty-five (45) calendar days prior to any performance of the test required under this condition. No stack test required herein shall be performed without prior approval of the protocol by the Division. The Division reserves the right to witness the test. In order to facilitate the Division's ability to make plans to witness the test, notice of the date(s) for the stack test shall be submitted to the Division at least thirty (30) calendar days prior to the test. The Division may for good cause shown, waive this thirty (30) day notice requirement. In instances when a scheduling conflict is presented, the Division shall immediately contact the permittee in order to explore the possibility of making modifications to the stack test schedule. The compliance test results shall be submitted to the Division within forty-five (45) calendar days of the completion of the test unless a longer period is approved by the Division. 1.13 State-only Requirement: No owner or operator may discharge, or cause the discharge into the atmosphere of any particulate matter which is greater than 20% opacity (Colorado Regulation Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 20 No. 6, Part B, Section II.C.3). This opacity standard applies to each combustion turbine/HRSG/duct burner. In the absence of credible evidence to the contrary, compliance with the opacity limitation shall be presumed since only pipeline quality natural gas is permitted to be used as fuel in the turbines and duct burners. 1.14 Except as provided for in Condition 1.15 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Construction Permit 94WE609 PSD and Colorado Regulation No. 1, Section II.A.1). This opacity standard applies to each combustion turbine/HRSG/duct burner. In the absence of credible evidence to the contrary, compliance with the opacity limitation shall be presumed since only pipeline quality natural gas is permitted to be used as fuel in the turbines and duct burners. 1.15 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment which is in excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). This opacity standard applies to each combustion turbine/HRSG/duct burner. In the absence of credible evidence to the contrary, compliance with the opacity limitation shall be presumed since only pipeline quality natural gas is permitted to be used as fuel in the turbines and duct burners. 1.16 No owner or operator of a source shall cause to be discharged into the atmosphere from any affected facility any gases which exhibit greater than 20 percent opacity (6-minute average), except for one 6-minute period per hour of not more than 27 percent opacity ((40 CFR Part 60 Subpart Da § 60.42Da(b), as adopted by reference in Colorado Regulation No. 6, Part A). This opacity standard applies to each duct burner. In the absence of credible evidence to the contrary, compliance with the opacity limit shall be presumed since only pipeline quality natural gas is permitted to be used as fuel for these units. This opacity standard applies at all times except during periods of startup, shutdown and malfunction (40 CFR Part 60 Subpart A § 60.11(c), as adopted by reference in Colorado Regulation No. 6, Part A). 1.17 These units are subject to the Title IV Acid Rain Requirements. As specified in 40 CFR Part 72.72(b)(1)(viii), the acid rain permit requirements shall be a complete and segregable portion of the Operating Permit. As such the requirements are found in Section III of this permit. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 21 2. T004—Combustion Turbine Capable of Simple or Combined Cycle Operation Simple Cycle - Combustion Turbine Only Combined Cycle (No Supplemental Fuel) - Combustion Turbine & Heat Recovery Steam Generator (HRSG)with No Fuel Fired in Duct Burner Combined Cycle (With Supplemental Fuel)—Combustion Turbine& Heat Recovery Steam Generator (HRSG) with Fuel Fired in Duct Burner Parameter Permit Limitations Compliance Monitoring Condition Emission Number Short Term Long Term Factor Method Interval BACT 2.1 N/A N/A N/A See Condition 2.1 Requirements PM 2.2 N/A 54 tons/yr 0.005 Recordkeeping Monthly lbs/MMBtu and Calculation Combustion Turbine: N/A Fuel Restriction Only Pipeline 0.1 lbs/MMBtu,the average of Quality Natural three(3), 1-hr tests Gas is Used as Fuel Combustion Turbine and Duct Burner Together: 0.1 lbs/MMBtu,the average of three(3), 1-hr tests Duct Burner: 0.03 lbs/MMBtu,the average of three(3),2-hr tests PM10 N/A 54 tons/yr 0.005 Recordkeeping Monthly lbs/MMBtu and Calculation VOC 2.3 N/A 33.1 tons/yr N/A Continuous Continuously Monitoring System Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 22 Parameter Permit Limitations Compliance Monitoring Condition Emission Number Short Term Long Term Factor Method Interval SO2 2.4 N/A 4.7 tons/yr N/A Continuous Continuously Monitoring System Combustion Turbine: N/A Fuel Restriction See Condition 150 ppmvd @ 15%O2 OR Use of 2.4 Fuel Which Contains Less than 0.8 Weight%Sulfur Combustion Turbine: 0.35 lbs/MMBtu,on a 3-hour rolling average Duct Burner: 0.20 lbs/MMBtu on a 30-day rolling average NOx 2.5 Simple Cycle Mode N/A Continuous Continuously 9 ppmvd @ 15%O2 on a 24-hr Emission rolling average,except as provided Monitoring for below System During Startup and Shutdown: 100 ppmvd @ 15%O2 on a 1-hr average During Combustion Tuning and Testing(not to exceed 90 hrs/yr per for turbines T002,T003&T004 combined): 100 ppmvd @ 15%O2 on a 1-hr average Combined Cycle Mode 4 ppmvd @ 15%O2 on a 24-hr rolling average,except as provided for below During Startup and Shutdown: 100 ppmvd @ 15%O2 on a 1-hr average During Combustion Tuning and Testing(not to exceed 90 hrs/yr per for turbines T002,T003&T004 combined): 100 ppmvd @ 15%O2 on a 1-hr average N/A 199.1 tons/yr Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 23 Parameter Permit Limitations Compliance Monitoring Condition Emission Number Short Term Long Term Factor Method Interval CO 2.6 Simple Cycle Mode or Combined N/A Continuous Continuously Cycle Mode—No Supplemental Emission Fuel: Monitoring 9 ppmvd @ 15%O2 on a 1-hr System average,except as provided for below During Startup and Shutdown: 1000 ppmvd @ 15%O2 on a 1-hr average and 2,060 lbs/hr During Combustion Tuning and Testing(not to exceed 90 hrs/yr per for turbines T002,T003&T004 combined): 1000 ppmvd @ 15%O2 on a 1-hr average and 2,060 lbs/hr Combined Cycle Mode—With Supplemental Fuel: 20 ppmvd @ 15%O,on a 1-hr average,except as provided for below During Startup and Shutdown: 1000 ppmvd @ 15%O,on a 1-hr average and 2,060 lbs/hr During Combustion Tuning and Testing(not to exceed 90 hrs/yr per for turbines T002,T003&T004 combined): 1000 ppmvd @ 15%O2 on a 1-hr average and 2,060 lbs/hr N/A 237.9 tons/yr Heat Input from 2.7 N/A Combustion N/A Recordkeeping Monthly Natural Gas Turbine: 12,066,462 MMBtu/yr Duct Burner: 3,157,702 M MBtu/yr Continuous 2.8 N/A N/A N/A See Condition 2.8 Emission Monitoring System Requirements Operating Permit Number: 97OPWEl80 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 24 Parameter Permit Limitations Compliance Monitoring Condition Emission Number Short Term Long Term Factor Method Interval Compliance 2.9 N/A N/A N/A See Condition 2.9 Assurance Monitoring Requirements— For Combined Cycle Operation Sulfur Content of 2.10 N/A N/A N/A See Condition 2.10. Natural Gas NSPS General 2.11 N/A N/A N/A As required by Subject to NSPS Provisions NSPS General General Provisions Provisions Opacity 2.12 Not to Exceed 20%Except as N/A Fuel Restriction Only Pipeline Provided for in 2.13 Quality Natural Gas is Used as Fuel Opacity 2.13 For Certain Operational Activities- N/A Not to Exceed 30%,for a Period or Periods Aggregating More than Six (6)Minutes in any 60 Consecutive Minutes State-Only 2.14 Not to Exceed 20% N/A Opacity NSPS Opacity — 2.15 Not to Exceed 20%(6-minute N/A Applies to Duct average),Except for One Six Burner Only Minute Average Not to Exceed 27%Per Hour Acid Rain 2.16 See Section III of this Permit Certification Annually Requirements 2.1 The combustion turbine/HRSG/duct burner is subject to the requirements of the Prevention of Significant Deterioration (PSD)Program. 2.1.1 Best Available Control Technology (BACT) shall be applied for control of Nitrogen Oxides (NOx), Carbon Monoxide (CO) and Particulate Matter Emissions (PM and PM10). BACT has been determined as follows: 2.1.1.1 BACT for NOx has been determined to be Dry Low NOx combustion system for the turbine and Selective Catalytic Reduction (SCR) for the HRSG with the emission limits as identified in Condition 2.5.1 (Colorado Construction Permit 99WE0762 PSD). 2.1.1.2 BACT for CO has been determined to be good combustion Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 25 practices/monitoring systems capable of meeting the emission limits identified in Condition 2.6.1 (Colorado Construction Permit 99WE0762 PSD). 2.1.1.3 BACT for PM and PM10 has been determined to be use of pipeline quality natural gas (Colorado Construction Permit 99WE0762 PSD). 2.2 PM and PM10 emissions are subject to the following requirements: 2.2.1 Emissions of PM and PM B) from the combustion turbine/HRSG/duct burner shall not exceed 54 tons/yr (Colorado Construction Permit 99WE0762 PSD). Monthly emissions from the combustion turbine/HRSG/duct burner shall be calculated by the end of the subsequent month using the emission factors (EF) identified in the above table (from performance test conducted May 10-12, 2001) in the following equation: tons/month=(EF,lbs/MMBtu)x(Fuel Use,MMscf/mo)x heat content of gas(MMBtu/MMscf) 2000 lbs/ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 2.2.2 Particulate Matter(PM) emissions from the combustion turbine shall not exceed 0.1 lbs/MMBtu, the average of three (3) 1-hr tests (Colorado Regulation No. 1, Section III.A.I.c). In the absence of credible evidence to the contrary, compliance with the particulate matter emission limitation is presumed since only pipeline quality natural gas is permitted to be used as fuel in the turbine. 2.2.3 Particulate Matter (PM) emissions from the combustion turbine and duct burner together shall not exceed 0.1 lbs/MMBtu, the average of three (3) 1-hr tests (Colorado Regulation No. 1, Sections III.A.1.b,c and d). In the absence of credible evidence to the contrary, compliance with the particulate matter emission limitation is presumed since only pipeline quality natural gas is permitted by be used as fuel in the turbine and duct burner. Note that the numeric PM standards for combined cycle operation were determined using the design heat input for the turbine (1,531 MMBtu/hr) and the duct burner (each 422 MMBtu) in the following equation: PE (turbine + duct burner) =PET x FIT+ PEDB x FIn13 FIT+ Firm Where PE= particulate standard in lbs/MMBtu PEDB = 0.5 x (FI)-°26 lbs/MMBtu PET=0.1 lbs/MMBtu Fl= fuel input in MMBtu/hr Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado P Y Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 26 2.2.4 Particulate Matter (PM) emissions from the duct burner shall not exceed 0.03 lbs/MMBtu, the average of three (3) 2-hr tests (Colorado Construction Permit 99MR0762 PSD). In the absence of credible evidence to the contrary, compliance with the particulate matter limitations shall be presumed since only pipeline quality natural gas is permitted to be used as fuel in the duct burner. The PM emission limits are not applicable during times of startup, shutdown and malfunction (40 CFR Part 60 Subpart Da § 60.46Da(c), as adopted by reference in Colorado Regulation No. 6, Part A). 2.3 Volatile Organic Compound emissions from the combustion turbine/HRSG/duct burner shall not exceed 33.1 tons/yr (Colorado Construction Permit 99WE0762 PSD). Compliance with the VOC limitations shall be monitored using the VOC correlation (VOC emissions vs. heat input) that has been approved by the Division and programmed into the data acquisition and handling system (DAHS). The VOC correlation was approved by the Division on February 6, 2002, with written approval provided in the Division's letter dated March 26, 2008 to the permittee. The equations used in the VOC correlation are included in Appendix G of this permit. A twelve month rolling total of emissions will be maintained to monitor compliance with the annual emission limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 2.4 Sulfur Dioxide (SO2) emissions shall not exceed the following limitations: 2.4.1 Sulfur Dioxide (SO2) emissions from the combustion turbine/HRSG/duct burner shall not exceed 4.7 tons/yr (Colorado Construction Permit 99WE0762 PSD, as modified under the provisions of Section I, Condition 1.3, based on the requested SO2 limits identified on the APEN received on February 27, 2002). Compliance with the annual SO2 emission limitations shall be monitored using the monitoring method specified in 40 CFR Part 75 Appendix D. A twelve month rolling total of emissions shall be maintained to monitor compliance with the annual emission limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 2.4.2 The combustion turbine shall meet one of the following requirements: 2.4.2.1 Sulfur Dioxide (SO2) emissions shall not exceed 150 ppmvd at 15% O2 OR 2.4.2.2 No fuel, which contains sulfur in excess of 0.8 percent by weight, shall be used in this combustion turbine (40 CFR Part 60 Subpart GG §§ 60.33(a) & (b), as adopted by reference in Colorado Regulation No. 6, Part A). In the absence of credible evidence to the contrary, compliance with the above requirements is presumed since only pipeline quality natural gas is permitted to be Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit#97OPWE180 Page 27 used as fuel in the turbine. The natural gas used as fuel shall meet the requirements in Condition 2.10. 2.4.3 Sulfur Dioxide (SO2) emissions from the combustion turbine shall not exceed 0.35 lbs/MMBtu, on a 3-hr rolling average (Colorado Regulation No. 1, Section VI.B.4.c.(ii) and VI.B.2). In the absence of credible evidence to the contrary, compliance with the SO2 limitations is presumed since only pipeline quality natural gas is permitted to be used as fuel in the turbine. 2.4.4 Sulfur Dioxide (SO2) emissions from the duct burner shall not exceed 0.20 lbs/MMBtu, on a 30-day rolling average (Colorado Construction Permit 99WE0762 PSD). In the absence of credible evidence to the contrary, compliance with the SO2 limitations is presumed since only pipeline quality natural gas is permitted to be used as fuel in the duct burner. 2.5 Emissions of Nitrogen Oxides (NOx) shall not exceed the following limitations: 2.5.1 The BACT emission limits for the combustion turbine/HRSG/duct burner are as follows (Colorado Construction Permit 99WE0762 PSD, as modified under the provisions of Section I, Condition 1.3): 2.5.1.1 Except as provided for in Conditions 2.5.1.3 and 2.5.1.4 below, emissions of NOx shall not exceed 9 ppmvd at 15 % O2, on a 24-hour average. This standard applies when operating in simple cycle mode. 2.5.1.2 Except as provided for in Conditions 2.5.1.3 and 2.5.1.4 below, emissions of NOx shall not exceed 4 ppmvd at 15 % O2, on a 24-hour average. This standard applies when operating in combined cycle mode. 2.5.1.3 During periods of startup and shutdown emissions of NOx shall not exceed 100 ppmvd at 15% O2, on a 1-hr average. 2.5.1.4 During periods of combustion tuning and testing emissions of NOx shall not exceed 100 ppmvd at 15% O2, on a 1-hour average. Use of this NOx emission limit for purposes of combustion tuning and testing shall not exceed 90 hours in any calendar year for turbines T002, T003 and T004 combined. Records of the number of hours the turbine undergoes combustion tuning and testing shall be recorded and maintained and made available to the Division upon request. 2.5.1.5 "Startup" shall have the same definition as provided for in Condition 1.2.1.5. 2.5.1.6 `'Shutdown" shall have the same definition as provided for in Condition 1.2.1.6. 2.5.1.7 "Combustion Tuning and Testing" shall have the same definition as provided for in Condition 1.2.1.7 and shall also include testing and tuning of the selective catalytic reduction (SCR) system. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 28 Compliance with these NOx limitations shall be monitored using the continuous emission monitoring system (CEMS) required by Condition 2.8, as follows: 2.5.1.8 Except as provided for in Condition 2.5.1.9, all valid CEMS concentration (ppm) data points, excluding startup and shutdown data points shall, at the end of each clock hour, be summarized to generate the one-hour average NOx concentration in accordance with the requirements in 40 CFR Part 75 and Condition 5.2.1.3.b of this permit. Data used to generate the one-hour average NOx concentration shall not include replaced data, nor shall the data be bias-adjusted. Replaced data shall be reported as monitor down time in the quarterly reports required by Condition 5.5. Compliance with the limitations in Conditions 2.5.1.1 and 2.5.1.2 shall be based on a 24- hour rolling average, except that compliance with the limitations cannot be assessed until 24 hours of operation have occurred. It is not necessary for hours of operation to be consecutive (i.e. the rolling 24-hour average would resume after the unit has shutdown and is re-started and/or between switches in operating mode (simple cycle to combined cycle)) in order for those hours to be included in the 24-hour rolling averages. 2.5.1.9 All valid CEMS concentration (ppm) data points, excluding non-startup and non-shutdown data points shall, at the end of each clock hour be summarized to generate the average NOx concentration in accordance with the requirements in 40 CFR Part 75 and Condition 5.2.1.3.b of this permit. Data used to generate the average NOx concentration shall not include replaced data, nor shall the data be bias-adjusted. Replaced data shall be reported as monitor down time in the quarterly reports required by Condition 5.5. Each clock hour average NOx concentration shall be compared to the limitation in Condition 2.5.1.3. In the event that a startup ends within a clock hour or shutdown begins within a clock hour, all non-startup and/or non-shutdown concentration (ppm) data points within that clock hour shall be averaged together to generate the average NOx concentration in accordance with the requirements in 40 CFR Part 75 and Condition 5.2.1.3.b of this permit and that average concentration shall be included in the 24-hour rolling averages to monitor compliance with the limitations in either Conditions 2.5.1.1 or 2.5.1.2 or compared to the limitation in Condition 2.5.1.4, as appropriate. 2.5.1.10 The emission limitation in Condition 2.5.1.4 applies to any clock hour in which combustion tuning and testing activities occur. 2.5.2 Nitrogen Oxides (NOx) emissions from the combustion turbine/HRSG/duct burner shall not exceed 199.1 tons/yr (Colorado Construction Permit 99WE0762 PSD). Compliance with the annual limitation shall be monitored using the CEMS required by Condition 2.8. For any hour in which fuel is combusted in the turbines, including periods of startup, shutdown and malfunction, the permittee shall program Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 29 the DAHs to calculate lb/hr NOx emissions in accordance with the requirements in Condition 5.2.1.3.b of this permit and 40 CFR Part 75, including any replaced data and the data shall be bias-adjusted, if warranted. Specifically hourly mass NOx emissions (in lb/hr) shall be calculated by multiplying the hourly NOx lb/MMBtu value (which includes replaced or bias-adjusted data, as applicable) by the hourly heat input value (MMBtu/hr) (which includes replaced data from the fuel flow measurement, as applicable). The hourly NOx lb/MMBtu and heat input values shall be determined using equations F-5 or F-6, as appropriate for the diluents monitored by the CEMS and F-20 in Appendix F of 40 CFR Part 75. The resulting NOx lb/hr value is then multiplied by the unit operating time for that hour to produce a NOx lbs value. Hourly NOx mass emissions (Ibs) shall be summed and divided by 2000 lb/ton to determine monthly NOx emissions (in tons). Monthly emissions (in tons) from the combustion turbine/HRSG/duct burner shall be used in a twelve month rolling total of emissions shall be maintained to monitor compliance with the annual emission limitation. Each month a new twelve month total shall be calculated using the previous twelve months total. 2.6 Emissions of Carbon Monoxide (CO) shall not exceed the following limitations: 2.6.1 The BACT CO emission limits for the combustion turbine/HRSG/duct burner are as follows (Colorado Construction Permit 99WE0762, as modified under the provisions of Section I, Condition 1.3): 2.6.1.1 Except as provided for in Conditions 2.6.1.3 and 2.6.1.4 below, emissions of CO shall not exceed 9 ppmvd at 15% O2, on a 1-hour average. This standard applies when operating in either simple cycle mode or combined cycle mode without supplemental fuel. 2.6.1.2 Except as provided for in Conditions 2.6.1.3 and 2.6.1.4 below, emissions of CO shall not exceed 20 ppmvd at 15% O2, on a 1-hour average. This standard applies when operating in combined cycle mode with supplemental fuel. 2.6.1.3 During periods of startup and shutdown emissions of CO shall not exceed 1,000 ppmvd at 15% O2, on a 1-hr average and 2,060 lbs/hr. In the event that CO emissions exceed 1,000 ppmvd at 15% O2, it shall be considered a violation if CO emissions exceed 2,060 lbs/hr and not a violation if emissions are less than or equal to 2,060 lbs/hr. 2.6.1.4 During periods of combustion tuning and testing emissions of CO shall not exceed 1,000 ppmvd at 15% O2, on a 1-hour average. In the event that CO emissions exceed 1,000 ppmvd at 15% O2, it shall be considered a violation if CO emissions exceed 2,060 lbs/hr and not a violation if emissions are less than or equal to 2,060 lbs/hr. Use of this CO emission limit for purposes of combustion tuning and testing shall not exceed 90 Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 30 hours in any calendar year for all three turbines combined. Records of the number of hours the turbine undergoes combustion tuning and testing shall be recorded and maintained and made available to the Division upon request. 2.6.1.5 "Startup" shall have the same definition as provided for in Condition 1.2.1.5. 2.6.1.6 "Shutdown" shall have the same definition as provided for in Condition 1.2.1.6. 2.6.1.7 "Combustion Tuning and Testing" shall have the same definition as provided for in Condition 1.2.1.7 and shall also include testing and tuning of the selective catalytic reduction (SCR) system.. Compliance with these CO limitations shall be monitored using the continuous emission monitoring system (CEMS) required by Condition 2.8, as follows: 2.6.1.8 Except as provided for in Condition 2.6.1.9, all valid CEMS concentration (ppm) data points, excluding startup and shutdown data points shall, at the end of each clock hour be summarized to generate the average CO concentration in accordance with the requirements in 40 CFR Part 75 and Condition 5.2.1.3.b of this permit. Data used to generate the one-hour average CO concentration shall not include replaced data, nor shall the data be bias-adjusted. Replaced data shall be reported as monitor down time in the quarterly reports required by Condition 5.5. Each clock hour average CO concentration shall be compared to the limitations in Conditions 2.6.1.1, 2.6.1.2 or 2.6.1.4, as appropriate. 2.6.1.9 All valid CEMS concentration (ppm) data points, excluding non-startup and non-shutdown data points shall, at the end of each clock hour be summarized to generate the average CO concentration in accordance with the requirements in 40 CFR Part 75 and Condition 5.2.1.3.b of this permit. Data used to generate the average CO concentration shall not include replaced data, nor shall the data be bias-adjusted. Replaced data shall be reported as monitor down time in the quarterly reports required by Condition 5.5. Each clock hour average CO concentration shall be compared to the limitation in Condition 2.6.1.3. In the event that a startup ends within a clock hour or shutdown begins within a clock hour, all non-startup and/or non-shutdown concentration (ppm) data points within that clock hour shall be averaged together to generate the average CO concentration in accordance with the requirements in 40 CFR Part 75 and Condition 5.2.1.3.b of this permit and that average concentration shall be compared to the limitations in Conditions 2.6.1.1, 2.6.1.2 or 2.6.1.4, as appropriate. 2.6.1.10 The emission limitation in Condition 2.6.1.4 applies to any clock hour in which combustion tuning and testing activities occur. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 31 2.6.2 Carbon Monoxide (CO) emissions from the combustion turbine/HRSG/duct burner shall not exceed 237.9 tons/yr (Colorado Construction Permit 99WE0762 PSD). Compliance with the annual limitation shall be monitored using the CEMS required by Condition 2.8. For any hour in which fuel is combusted in the turbines, including periods of startup, shutdown and malfunction, the permittee shall program the DAHs to calculate lb/hr CO emissions in accordance with the requirements in Condition 5.2.1.3.b of this permit and 40 CFR Part 75, including any replaced data, if warranted. Specifically hourly mass CO emissions (in lb/hr) shall be calculated by multiplying the hourly CO lb/MMBtu value (which includes replaced date in accordance with the provisions in Part 75 for NOx replacement, as applicable) by the hourly heat input value (MMBtu/hr) (which includes replaced data from the stack flow measurement, as applicable). The hourly CO lb/MMBtu and heat input values shall be determined using equations F-5 or F-6 (for NOx), as appropriate for the diluent monitored by the CEMS and F-20 in Appendix F of 40 CFR Part 75. The resulting CO lb/hr value is then multiplied by the unit operating time for that hour to produce a CO lbs value. Hourly CO mass emissions (lbs) shall be summed and divided by 2000 lb/ton to determine monthly CO emissions (in tons). Monthly emissions (in tons) from the combustion turbine/HRSG/duct burner shall be used in a twelve month rolling total of emissions shall be maintained to monitor compliance with the annual emission limitation. Each month a new twelve month total shall be calculated using the previous twelve months total. 2.7 The Heat Input from Natural Gas to the combustion turbine and duct burner shall not exceed the following limitations: 2.7.1 The heat input to the combustion turbine shall not exceed 12,066,462 MMBtu/yr (Colorado Construction Permit 99WE0762 PSD, as modified under the provisions of Section I, Condition 1.3, based on the requested turbine gas consumption limits identified on the APEN received on February 27, 2002). 2.7.2 The heat input to the duct burner shall not exceed 3,157,702 mmBty/yr (Colorado Construction Permit 99WE0762 PSD). The heat input for the combustion turbine and the duct burner shall be monitored using the data acquisition and handling systems (DAHS) for the continuous emission monitoring system (CEMS) required by Condition 2.8. Monthly heat input shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 2.8 For each combustion turbine/HRSG/duct burner, continuous emission monitoring systems (CEMS) shall be installed, certified, calibrated, maintained and operated for measuring NOx Operating Permit Number: 97OPWEI 80 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 32 (including diluent gas either CO2 or O2) and CO emissions (Colorado Construction Permit 99WE762 PSD, as modified under the provisions of Section I, Condition 1.3 and 40 CFR Part 75). The continuous emission monitoring systems shall meet the requirements in Condition 5 of this permit. Monthly emissions of NOx and CO from the continuous emission monitoring system shall be used as specified by Conditions 2.5.2 and 2.6.2 to monitor compliance with the annual NOx and CO emission limitations. 2.9 The Compliance Assurance Monitoring (CAM) requirements in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV, apply to when operating in combined cycle mode, with respect to the NOx limitations identified in Conditions 2.5.1.2 as follows: 2.9.1 The permittee shall monitor the exhaust gas NOx concentration (ppmvd at 15% O2) using the continuous emission monitoring system required by Condition 2.8. The NOx concentrations will be reduced to hourly averages and used to calculate 24-hour averages. Exceedances, for purposes of CAM, shall be any 24-hour period that the NOx concentration exceeds the limit identified in Condition 2.5.1.2. Exceedances of these limitations shall be reported as required by Section II, Condition 5.5 and Section V, Conditions 21 and 22.d of this permit. 2.9.2 Operation of Approved Monitoring 2.9.2.1 At all times, the owner or operator shall maintain the monitoring, including but not limited to, maintaining necessary parts for routine repairs of the monitoring equipment (40 CFR Part 64 § 64.7(b), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 2.9.2.2 Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), the owner or operator shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant-specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of these CAM requirements, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. The owner or operator shall use all the data collected during all other periods in assessing the operation of the control device and associated control system. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions (40 CFR Part 64 § 64.7(c), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 2.9.2.3 Response to excursions or exceedances Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 33 a. Upon detecting an excursion or exceedance, the owner or operator shall restore operation of the pollutant-specific emissions unit (including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion or exceedance (other than those caused by excused startup or shutdown conditions). Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow-up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable (40 CFR Part 64 § 64.7(d)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). b. Determination of whether the owner of operator has used acceptable procedures in response to an excursion or exceedance will be based on information available, which may include but is not limited to, monitoring results, review of operation and maintenance procedures and records, and inspection of the control device, associated capture system, and the process (40 CFR Part 64 § 64.7(d)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 2.9.2.4 After approval of the monitoring required under the CAM requirements, if the owner or operator identifies a failure to achieve compliance with an emission limitation or standard for which the approved monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing indicator ranges or designated conditions, the owner or operator shall promptly notify the Division and, if necessary submit a proposed modification for this permit to address the necessary monitoring changes. Such a modification may include, but is not limited to, reestablishing indicator ranges or designated conditions, modifying the frequency of conducting monitoring and collecting data, or the monitoring of additional parameters (40 CFR Part 64 § 64.7(e), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 2.9.3 Quality Improvement Plan (QIP) Requirements 2.9.3.1 Based on the results of a determination made under the provisions of Condition 2.9.2.3.b, the Division may require the owner or operator to develop and implement a QIP (40 CFR Part 64 § 64.8(a), as adopted by Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 '� Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 34 reference in Colorado Regulation No. 3, Part C, Section XIV). 2.9.3.2 The owner or operator shall maintain a written QIP, if required, and have it available for inspection (40 CFR Part 64 § 64.8(b)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 2.9.3.3 The QIP initially shall include procedures for evaluating the control performance problems and, based on the results of the evaluation procedures, the owner or operator shall modify the plan to include procedures for conducting one or more of the following actions, as appropriate: a. Improved preventative maintenance practices (40 CFR Part 64 § 64.8(b)(2)(i), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). b. Process operation changes (40 CFR Part 64 § 64.8(b)(2)(ii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). c. Appropriate improvements to control methods (40 CFR Part 64 § 64.8(b)(2)(iii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). d. Other steps appropriate to correct control performance (40 CFR Part 64 § 64.8(b)(2)(iv), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). e. More frequent or improved monitoring (only in conjunction with one or more steps under Conditions 2.9.3.3.a through d above) (40 CFR Part 64 § 64.8(b)(2)(v), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 2.9.3.4 If a QIP is required, the owner or operator shall develop and implement a QIP as expeditiously as practicable and shall notify the Division if the period for completing the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined (40 CFR Part 64 § 64.8(c), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 2.9.3.5 Following implementation of a QIP, upon any subsequent determination pursuant to Condition 2.9.2.3.b, the Division or the U.S. EPA may require that an owner or operator make reasonable changes to the QIP if the QIP is found to have: a. Failed to address the cause of the control device performance problems (40 CFR Part 64 § 64.8(d)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV); or b. Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 35 accordance with good air pollution control practices for minimizing emissions (40 CFR Part 64 § 64.8(d)(2), as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV). 2.9.3.6 Implementation of a QIP shall not excuse the owner or operator of a source from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply under federal, state, or local law, or any other applicable requirements under the federal clean air act (40 CFR Part 64 § 64.8(e), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 2.9.4 Reporting and Recordkeeping Requirements 2.9.4.1 Reporting Requirements: The reports required by Section V, Condition 22.d, shall contain the information specified in Appendix B of the permit h following information, as applicable: andt e PP a. Summary information on the number, duration and cause (including unknown cause, if applicable), for monitor downtime incidents (other than downtime associated with zero and span or other daily calibration checks, if applicable) ((40 CFR Part 64 § 64.9(a)(2)(ii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV); and b. The owner or operator shall submit, if necessary, a description of the actions taken to implement a QIP during the reporting period as specified in Condition 2.9.3 of this permit. Upon completion of a QIP, the owner or operator shall include in the next summary report documentation that the implementation of the plan has been completed and reduced the likelihood of similar levels of excursions or exceedances occurring (40 CFR Part 64 § 64.9(a)(2)(iii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 2.9.4.2 General Recordkeeping Requirements: In addition to the recordkeeping requirements in Section V, Condition 22.a through c. a. The owner or operator shall maintain records of any written QIP required pursuant to Condition 2.9.3 and any activities undertaken to implement a QIP, and any supporting information required to be maintained under these CAM requirements (such as data used to document the adequacy of monitoring, or records of monitoring maintenance or corrective actions) (40 CFR Part 64 § 64.9(b)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). b. Instead of paper records, the owner or operator may maintain records on alternative media, such as microfilm, computer files, Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 36 magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements (40 CFR Part 64 § 64.9(b)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 2.9.5 Savings Provisions 2.9.5.1 Nothing in these CAM requirements shall excuse the owner or operator of a source from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply under federal, state, or local law, or any other applicable requirements under the federal clean air act. These CAM requirements shall not be used to justify the approval of monitoring less stringent than the monitoring which is required under separate legal authority and are not intended to establish minimum requirements for the purposes of determining the monitoring to be imposed under separate authority under the federal clean air act, including monitoring in permits issued pursuant to title I of the federal clean air act. The purpose of the CAM requirements is to require, as part of the issuance of this Title V operating permit, improved or new monitoring at those emissions units where monitoring requirements do not exist or are inadequate to meet the requirements of CAM (40 CFR Part 64 § 64.10(a)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 2.9.5.2 Nothing in these CAM requirements shall restrict or abrogate the authority of the U.S. EPA or the Division to impose additional or more stringent monitoring, recordkeeping,testing or reporting requirements on any owner or operator of a source under any provision of the federal clean air act, including but not limited to sections 1 14(a)(1) and 504(b), or state law, as applicable (40 CFR Part 64 § 64.10(a)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 2.9.5.3 Nothing in these CAM requirements shall restrict or abrogate the authority of the U.S. EPA or the Division to take any enforcement action under the federal clean air act for any violation of an applicable requirement or of any person to take action under section 304 of the federal clean air act (40 CFR Part 64 § 64.10(a)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 2.10 The permittee shall maintain records demonstrating that the natural gas burned has a total sulfur content less than 0.5 grains/100 SCF. Natural gas that meets this sulfur limitation is considered pipeline quality natural gas as defined in 40 CFR Part 72. The demonstration shall be made using any of the methods identified in 40 CFR Part 75 Appendix D, Section 2.3.1.4.(a). These records shall be made available to the Division upon request. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 37 2.11 These combustion turbine/HRSG/duct burner is subject to 40 CFR Part 60, Subpart A - General Provisions, as adopted by reference in Colorado Regulation No. 6, Part A. Specifically, these units are subject to the following requirements: 2.11.1 No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gasses discharged to the atmosphere. (40 CFR Part 60 Subpart A § 60.12, as adopted in Colorado Regulation No. 6, Part A) 2.11.2 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Division which may include, but is not limited to monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source (40 CFR Subpart A § 60.11(d), as adopted by reference in Colorado Regulation N. 6, Part A). 2.12 Except as provided for in Condition 2.13 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Construction Permit 99WE0762 PSD and Colorado Regulation No. 1, Section II.A.1). This opacity standard applies to the combustion turbine/HRSG/duct burner. In the absence of credible evidence to the contrary, compliance with the 20% opacity limit shall be presumed since only pipeline quality natural gas is permitted to be used as fuel in the turbine and duct burner. 2.13 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment which is in excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Construction Permit 99WE0762 PSD and Colorado Regulation No. 1, Section II.A.4). This opacity standard applies to the combustion turbine/HRSG/duct burner. In the absence of credible evidence to the contrary, compliance with the 30% opacity limit shall be presumed since only pipeline quality natural gas is permitted to be used as fuel in the turbine and duct burner. 2.14 State-Only Requirement: No owner or operator may discharge, or cause the discharge into the atmosphere of any particulate matter which is greater than 20% opacity (Colorado Regulation No. 6, Part B, Section II.C.3). This opacity standard applies to the combustion turbine/HRSG/duct burner. In the absence of credible evidence to the contrary, compliance with the 20% opacity requirement is presumed since only pipeline quality natural gas is permitted to be used as fuel in the turbine and duct burner. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 38 This opacity standard applies at all times except during periods of startup, shutdown and malfunction (40 CFR Part 60 Subpart A § 60.11(c), as adopted by reference in Colorado Regulation No. 6, Part B, Section I.A). 2.15 No owner or operator of a source shall cause to be discharged into the atmosphere from any affected facility any gases which exhibit greater than 20 percent opacity (6-minute average), except for one 6-minute period per hour of not more than 27 percent opacity ((40 CFR Part 60 Subpart Da § 60.42Da(b), as adopted by reference in Colorado Regulation No. 6, Part A and Colorado Construction Permit 99WE0762 PSD). This opacity standard applies to the duct burner. In the absence of credible evidence to the contrary, compliance with the opacity limit shall be presumed since only pipeline quality natural gas is permitted to be used as fuel for the duct burner. This opacity standard applies at all times except during periods of startup, shutdown and malfunction (40 CFR Part 60 Subpart A § 60.11(c), as adopted by reference in Colorado Regulation No. 6, Part A). 2.16 This unit is subject to the Title IV Acid Rain Requirements. As specified in 40 CFR Part 72.72(b)(1)(viii), the acid rain permit requirements shall be complete and segregable portion of the Operating Permit. As such the requirements are found in Section III of this permit. 3. B001 -Auxiliary Boiler Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number NOx 3.1 N/A 32.6 tons/yr 100 lbs/MMscf Recordkeeping Monthly CO N/A 27.4 tons/yr 84 lbs/MMscf and Calculation Natural Gas 3.2 N/A 651.7 N/A Fuel Meter and Monthly Usage MMscf/yr Recordkeeping Particulate 3.3 0.1661bs/MMBtu N/A Fuel Restriction Only Natural Matter(PM) Gas is Used as Fuel Opacity 3.4 Not to 20%Except as Provided N/A Fuel Restriction Only Natural for in Condition 3.5 Below Gas is Used as Fuel Opacity 3.5 Special Conditions-Not to N/A Fuel Restriction Only Natural Exceed 30%for a Period or Gas is Used Periods Aggregating More than as Fuel Six(6)Minutes in Any Sixty Consecutive Minutes 3.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) shall not exceed the above limitations (as provided for under the provisions of Section I, condition 1.3, with as requested on the APEN submitted 4/23/99). Monthly emissions shall be calculated by the end of the Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 39 subsequent month using the above emission factors (EPA's Compilation of Emission Factors, dated March 1998, Section 1.4) in the following equation: tons/month = 1 EF (lbs/MMscf) x monthly fuel usage (MMscf/month)l 2000 lbs/ton A twelve month rolling total of emissions will be maintained to monitor compliance with the annual emission limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 3.2 Natural Gas Usage for this boiler shall not exceed the limitation stated above (as provided for under the provisions of Section 1, condition 1.3, with natural gas consumption as requested in the source's comments on the draft permit submitted 5/25/99). On the first working day of each month natural gas usage shall be recorded using the boiler fuel meter. Monthly natural gas use shall be used in a twelve month rolling total to monitor compliance with annual limitations. Each month a new twelve month total shall be calculated using the previous months data. 3.3 Particulate Matter (PM) emissions shall not exceed the limitation above (Colorado Regulation No. 1, Section II.A.1.b). In the absence of credible evidence to the contrary, compliance with the particulate matter limitations is presumed since only natural gas is permitted to be used as fuel in the boiler. Note that the numeric PM standard was determined using the design heat input for the boiler (70 MMBtu/hr) in the following equation: PE= 0.5 x (FI)-°26' where: PE=particulate standard in lbs/MMBtu FI= fuel input in MMBtu/hr 3.4 Except as provided for in Condition 3.5 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). In the absence of credible evidence to the contrary, compliance with the opacity limitation is presumed since only natural gas is permitted to be used as fuel in the boiler. 3.5 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment which is in excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). In the absence of credible evidence to the contrary, compliance with the opacity limitation is presumed since only natural gas is permitted to be used as fuel in the boiler. Operating Permit Number: 97OPW E 180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 40 4. M001 - Cooling Water and Service Water Towers Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number PM 4.1 N/A 14.9 tons/yr See Condition 4.1 Recordkeeping Monthly PM10 N/A 14.9 tons/yr and Calculation VOC N/A 2.4 tons/yr 0.0527 lbs/mmgal (as CHC13) Water Circulated 4.2 N/A 89,878 N/A Recordkeeping Monthly mmgal/yr Total Solids 4.3 N/A N/A N/A Laboratory Semi- Concentration Analysis Annually Opacity 4.4 Not to Exceed 20% N/A See Condition 4.4 4.1 Particulate Matter (PM and PMio) and Volatile Organic Compound (VOC) emissions shall not exceed the limitations above (Colorado Construction Permit 97WE0189, as modified under the provisions of Section I, Condition 1.3). Emissions shall be calculated monthly for each tower using the following equations: PM=PKo(tons/month)=Q x d x%drift x 31.3%drift dispersed x total solids 2000 lbs/ton Where: Q=water circulated,gal/month d=density of water,lbs/gal(from T5 application d=8.34 lbs/gal) %drift=0.001%(from T5 application) 31.3% drift dispersed (from EPA-600/7-79-251a, November 1979, AEffects of Pathogenic and Toxic Materials Transported Via Cooling Device Drift-Volumel -Technical Report@,Page 63) Total solids = in ppm (lbs solids/106 lbs water) - to be determined by Condition 4.3. The most recent analysis shall be used in the monthly calculation. VOC=CHC13(tons/month)=Q x EF x(1 mmgal/106 gal) 2000 lbs/ton Where: Q=water circulated,gal/month EF=0.0527 lbs/mmgal (from letter from Wayne C. Micheletti to Ed Lasnic, dated November 11, 1992) Monthly emissions from each tower shall be summed together and used in a twelve month rolling total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months data. 4.2 The Water Circulated through both the service water tower and the cooling water tower shall not exceed the limitation above (Colorado Construction Permit 97WE0189, as modified under the provisions of Section I, Condition 1.3). The quantity of water circulated in each tower shall be monitored and recorded monthly. Monthly quantities of water from each tower shall be summed together and used in a twelve month rolling total to monitor compliance with the annual Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT r Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 41 limitation. Each month a new twelve month total shall be calculated using the previous twelve months data. 4.3 Samples of water circulated from each tower shall be taken and analyzed semi-annually to determine the total solids concentration. The total solids concentration shall be used to calculate particulate matter emissions as required by Condition 4.1. A copy of the procedures used to obtain and to analyze samples shall be maintained and made available to the Division upon request. 4.4 Opacity of emissions from the cooling water tower shall not exceed 20% (Colorado Regulation No. 1, Section II.A.1). In the absence of credible evidence to the contrary, compliance with the opacity standard shall be presumed, provided the drift eliminators on the tower are operated and maintained in accordance with the manufacturers' recommendations and good engineering practices. 5. Continuous Emission Monitoring Systems (CEMS) The following requirements apply to the NOx, CO and diluent (either O2 or CO2) continuous emission monitoring systems (CEMS) required by Conditions 1.10, 2.8 and 8.10. Note that the continuous emission monitoring requirements identified in this Condition, are in addition to the continuous emission monitoring requirements required by the Acid Rain Program, which are identified in Section III of this permit 5.1 Monitoring Requirements For each turbine (i.e., combustion turbine or combustion turbine/HRSG/duct burner), a continuous emission monitoring system shall be installed, calibrated, and operated on the exhaust stack to determine and record the following (Colorado Construction Permits 94WE609 PSD, 99WE0762 PSD and 07WE1100, as modified under the provisions of Section 1, Condition 1.3): 5.1.1 Concentration of Oxides of Nitrogen; ppmvd corrected to 15% O2, hourly average and 24-hour average (Turbine 4 only), in the exhaust; 5.1.2 Emissions of Oxides of Nitrogen; tons/month, rolling twelve month; 5.1.3 Concentration of Carbon Monoxide; ppmvd corrected to 15% O2, hourly average, in the exhaust; 5.1.4 Emissions of Carbon Monoxide; lbs/hr, tons/month, rolling twelve month; 5.1.5 Average combustion turbine load; 5.1.6 Load at which steam turbine is operating; 5.1.7 Flow rate of pipe line quality natural gas; 5.2 Equipment and QA/QC Requirements Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 42 5.2.1 The Continuous Emission Monitoring Systems are subject to the following requirements: 5.2.1.1 Except as provided for below, the CO monitors are subject to the applicable requirements of 40 CFR Part 60 (94WE609 PSD and 07WE1100). The monitoring systems shall meet the equipment, installation and performance specifications of 40 CFR Part 60 Appendix B, Performance Specification 4/4A. These CEMS are subject to the quality assurance/quality control requirements in 40 CFR Part 60 Appendix F and Subpart A § 60.13 and Condition 5.2.1.3 of this permit. a. The CO CEMS data shall meet the applicable "primary equipment hourly operating requirements" for hourly average calculation methodology specified in 40 CFR Part 75 Subpart B § 75.10(d). b. Annual CO monitor relative accuracy (RA) testing will be performed in ppm @ 15% O2 measurement units, and will be performed according to 40 CFR Part 60, Appendix B, Performance Specification 4A. c. Relative accuracy test audit (RATA) frequency will be determined according to 40 CFR Part 75 Appendix B. 5.2.1.2 Except as provided for below, the NOx (and diluent) monitors are subject to the applicable requirements of 40 CFR Part 75. The monitoring systems shall meet the equipment, installation and performance specification requirements in 40 CFR Part 75, Appendix A. These CEMS shall meet the quality assurance/quality control requirements in 40 CFR Part 75, Appendix B, the conversion procedures of Appendix F and Condition 5.2.1.3 of this permit. 5.2.1.3 The NOx and CO CEMS are subject to the following requirements: a. Relative Accuracy Test Audits (RATAs): RATAs shall be conducted in the units (e.g., lb/MMBtu, ppm) of the emission limitation for all of the emission limitations that are applicable to the emissions unit. The RATAs for emissions units that have annual emission limitations (tons/yr) will be conducted in terms of pounds per hour(lb/hr). b. The DAHS shall be able to record and manipulate the data in the units (e.g., lb/MMBtu, ppm) of the emission limitation and meet the reporting requriements for all for the emissions limitations that are applicable to the emissions unit. 5.2.2 Quality assurance/quality control plans shall be prepared for the continuous emission monitoring systems as follows: 5.2.2.1 The quality assurance/quality control plan for the CO monitors shall be prepared in accordance with the applicable requirements in 40 CFR Part Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 43 60, Appendix F, except that gas cylinder audit (GCA) testing is not required during quarters with less than 168 hours of operating time. 5.2.2.2 The quality assurance /quality control plan for the NOx (and diluent) monitors shall be prepared in accordance with the applicable requirements in 40 CFR Part 75, Appendix B. The quality assurance/quality control plans shall be made available to the Division upon request. Revisions shall be made to the plans at the request of the Division. 5.3 General Provisions 5.3.1 NOx (and diluent) monitors: The permittee shall ensure that all continuous emission monitoring systems required are in operation and monitoring unit emissions at all times that the unit combusts any fuel except as provided in 40 CFR Part 75 § 75.11(e) and during periods of calibration, quality assurance, or preventative maintenance performed pursuant to 40 CFR Part 75 § 75.21 and Appendix B, periods of repair, periods of backups of data from a data acquisition and handling system or recertification performed pursuant to 40 CFR Part 75 § 75.20. (40 CFR Part 75 § 75.10(d)). 5.3.2 CO monitors: The permittee shall ensure that all continuous emission monitoring systems required are in operation and monitoring unit emissions at all times except for monitoring system breakdowns, repairs, calibration checks and zero and span adjustments required under 40 CFR Part 60 Subpart A § 60.13(d) (40 CFR Part 60 Subpart A § 60.13(e)). 5.3.3 Alternative monitoring systems, alternative reference methods, or any other alternatives for the required continuous emission monitoring systems shall not be used without having obtained prior written approval from the appropriate agency, either the Division or the U.S. EPA, depending on which agency is authorized to approve such alternative under applicable law. Any alternative continuous emission monitoring systems must be certified in accordance with the requirements of 40 CFR Part 75 prior to use. 5.3.4 All test and monitoring equipment, methods, procedures and reporting shall be subject to the review and approval by the appropriate agency, either the Division or the U.S. EPA, depending on which agency is authorized to approve such alternative under applicable law, prior to any official use. The Division shall have the right to inspect such equipment, methods and procedures and data obtained at any time. The Division may provide a witness(s) for any and all tests as Division resources permit. 5.3.5 A file shall be maintained of all measurements, including continuous monitoring system, monitoring device, and performance testing measurements; all continuous monitoring system performance evaluations; all continuous monitoring system or monitoring device calibration checks; adjustments and maintenance performed on Operating Permit Number: 97OPW E l 80 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 44 these systems or devices; and all other information required by applicable portions of 40 CFR Part 75 recorded in a permanent form suitable for inspection. 5.3.6 Records shall be maintained of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the source; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative (40 CFR Part 60 Subpart A § 60.7(b), as adopted by reference in Colorado Regulation No. 6, Part A). 5.4 Data Replacement Requirements For periods when quality assured data is not available from the continuous emission monitoring systems the data replacement procedures in 40 CFR Part 75 Subpart D shall be used for determining the total (annual) emissions. Although carbon monoxide emissions are not specifically referenced in the Subpart D procedures, the CEM data acquisition system will be programmed to substitute carbon monoxide emissions using the same procedures specified for oxides of nitrogen (Colorado Construction Permit 94WE609 PSD, as modified under the provisions of Section I, Condition 1.3, as requested by letter received June 23, 1999 and Colorado Construction Permit 07WE1100). For purposes of monitoring compliance with the annual emission limitations (tons/yr) replaced and bias-adjusted data shall be included when assessing compliance with the annual limitations. Note that since CO emissions are not subject to requirements in 40 CFR Part 75 the CO emission data is not required to be bias-adjusted. 5.5 Recordkeeping and Reporting Requirements 5.5.1 Each owner or operator required to install a continuous monitoring device shall submit excess emissions and monitoring systems performance report (excess emissions are defined in applicable subparts and this permit) and-or summary report form (see Condition 5.5.2) to the Division quarterly. All reports shall be postmarked by the 30th day following the end of each calendar quarter. (§ 60.7(c), revised to stipulate quarterly reporting. The source requested quarterly reporting to be consistent with the Acid Rain reporting requirements). Written reports of excess emissions shall include the following information: 5.5.1.1 The magnitude of excess emissions computed in accordance with 40 CFR Part 60 Subpart A § 60.13(h) and Division guidelines, as applicble, any conversion factor(s) used, and the date and time of commencement and completion of each time period of excess emissions and the process operating time during the reporting period (§ 60.7(c)(1)). 5.5.1.2 Specific identification of each period of excess emissions that occurs during startups, shutdowns, and malfunctions of the affected facility. The nature and cause of any malfunction (if known), the corrective action taken or preventative measures adopted (§ 60.7(c)(2)). 5.5.1.3 The date and time identifying each period during which the continuous monitoring system was inoperative except for zero and span checks and Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 45 the nature of the system repairs or adjustments (§ 60.7(c)(3)). 5.5.1.4 When no excess emissions have occurred or the continuous monitoring system(s) have not been inoperative, repaired, or adjusted, such information shall be stated in the report (§ 60.7(c)(4)). 5.5.2 The summary report form shall contain the information and be in the format shown in figure 1 of § 60.7 unless otherwise specified by the Division. One summary report form shall be submitted for each pollutant monitored at each affected facility. (§ 60.7(d)) If the total duration of excess emissions for the reporting period is less than 1 percent of the total operating time for the reporting period and CMS downtime for the reporting period is less than 5 percent of the total operating time for the reporting period, only the summary report form shall be submitted and the excess emission report described in Condition 5.5.1 need not be submitted unless requested by the Division. (§ 60.7(d)(1)). If the total duration of excess emissions for the reporting period is 1 percent or greater of the total operating time for the reporting period or the total CMS downtime for the reporting period is 5 percent or greater of the total operating time for the reporting period, the summary report form and the excess emission report described in Condition 5.5.1 shall both be submitted. (§ 60.7(d)(2)) 5.6 Specific Provisions for NSPS Subpart KKKK The following requirements apply to Turbines 5 and 6 only. 5.6.1 As specified in 40 CFR Part 60 Subpart KKKK § 60.4345(a), if a Part 75 NOx CEMS is used, the RATA shall be performed on a lb/MMBtu basis. 5.6.2 As specified in 40 CFR Part 60 Subpart KKKK § 60.4350(d) and approved by the Division, only quality assured data from the CEMS shall be used to identified excess emissions. Periods where the missing data substitution procedures in Subpart D of Part 75 are applied are to be reported as monitor downtime in the excess emission reports specified in Condition 5.5. 5.6.3 For the purpose of reports required under Condition 5.5, periods of excess emissions and monitor downtime that must be reported are defined as follows: 5.6.3.1 Excess emissions is any unit operating period in which the 4-hour rolling average NOx emission rate exceeds the applicable emission limit in §60.4320. For the purposes of this subpart, a ''4-hour rolling average NOxe mission rate" is the arithmetic average of the average NOx emission rate in ppm or ng/J (lb/MWh) measured by the continuous emission monitoring equipment for a given hour and the three unit operating hour average NOx emission rates immediately preceding that unit operating Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 46 hour. Calculate the rolling average if a valid NOx mission rate is obtained for at least 3 of the 4 hours. (40 CFR Part 60 Subpart KKKK § 60.4380(b)(1)) 5.6.3.2 A period of monitor downtime is any unit operating hour in which the data for any of the following parameters are either missing or invalid: NOx concentration, CO2 or O2 concentration, fuel flow rate, steam flow rate, steam temperature, steam pressure, or megawatts. The steam flow rate, steam temperature, and steam pressure are only required if you will use this information for compliance purposes. (40 CFR Part 60 Subpart KKKK § 60.4380(b)(2)) 5.6.3.3 For operating periods during which multiple emissions standards apply, the applicable standard is the average of the applicable standards during each hour. For hours with multiple emissions standards, the applicable limit for that hour is determined based on the condition that corresponded to the highest emissions standard. (40 CFR Part 60 Subpart KKKK § 60.4380(b)(2)) 6. M002 - Gasoline Storage Tank, 500 gallons aboveground Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number 40 CFR Pat 63 6.1 Work Practice Standards N/A See Condition 6.1 Subpart CCCCCC Requirements Note that these emission units are exempt from the APEN reporting requirements in Regulation No. 3, Part A and the construction permit requirements in Regulation No. 3,Part B, as long as actual, uncontrolled emissions do not exceed the APEN de minimis level (see Regulation No.3,Part B,Section II.D.1.a). 6.1 This tank is subject to the requirements in 40 CFR Part 63 Subpart CCCCCC, "National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities", as follows: The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart CCCCCC published in the Federal Register on January 24, 2011. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63 Subpart CCCCCC. These requirements have not been adopted into Colorado Regulation No. 8, Part E as of the date of this permit issuance [DATE], and are therefore not state-enforceable. In the event that these requirements are adopted into Colorado Regulations, they will become state-enforceable. Am I subject to the requirements in this subpart? 0 63.11111) Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 47 6.1.1 If your GDF has a monthly throughput of less than 10,000 gallons of gasoline, you must comply with the requirements in §63.11116 (Conditions 6.1.7 through 6.1.10). (§ 63.11111(b)). 6.1.2 An affected source shall, upon request by the Administrator, demonstrate that their monthly throughput is less than the 10,000-gallon or the 100,000-gallon threshold level, as applicable. For new or reconstructed affected sources, as specified in §63.11112(b) and (c), recordkeeping to document monthly throughput must begin upon startup of the affected source. For existing sources, as specified in §63.11112(d), recordkeeping to document monthly throughput must begin on January 10, 2008. For existing sources that are subject to this subpart only because they load gasoline into fuel tanks other than those in motor vehicles, as defined in §63.11132, recordkeeping to document monthly throughput must begin on January 24, 2011. Records required under this paragraph shall be kept for a period of 5 years. (§ 63.11111(e)). 6.1.3 If your affected source's throughput ever exceeds an applicable throughput threshold, the affected source will remain subject to the requirements for sources above the threshold, even if the affected source throughput later falls below the applicable throughput threshold. (§ 63.11111(j)) When do I have to comply with this subpart? 0'63.11113) 6.1.4 If you start up your affected source after January 10, 2008, you must comply with the standards in this subpart upon startup of your affected source (40 CFR Part 63 Subpart CCCCCC § 63.11113(a)(1)). What are my general duties to minimize emissions? (.'63.11115) 6.1.5 You must, at all times, operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. (§ 63.11115(a)) 6.1.6 You must keep applicable records and submit reports as specified in §63.11125(d) and §63.11126(b). (§ 63.11I15(b)) Records and reports noted in this permit condition are related to malfunctions. Note that since this source is not subject to any emission limitations and is specifically exempt from reporting requirements as specified in Condition 6.1.8, the reporting requirements in § 63.1125(d) do not apply to this source. (§ 63.11115(b)) Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 48 Requirements for facilities with monthly throughput of less than 10,000 gallons of gasoline. (' 63.11116) 6.1.7 You must not allow gasoline to be handled in a manner that would result in vapor releases to the atmosphere for extended periods of time. Measures to be taken include, but are not limited to,the following (§ 63.11116(a)): 6.1.7.1 Minimize gasoline spills; 6.1.7.2 Clean up spills as expeditiously as practicable; 6.1.7.3 Cover all open gasoline containers and all gasoline storage tank fill-pipes with a gasketed seal when not in use; 6.1.7.4 Minimize gasoline sent to open waste collection systems that collect and transport gasoline to reclamation and recycling devices, such as oil/water separators; 6.1.8 You are not required to submit notifications or reports as specified in §63.11125, §63.11126,or subpart A of this part, but you must have records available within 24 hours of a request by the Administrator to document your gasoline throughput. (§ 63.11116(b)). Records shall be kept as required by Section V, General Conditions 22.b and c of this permit. 6.1.9 You must comply with the requirements of this subpart by the applicable date specified in Condition 6.1.4. (40 CFR Part 63 Subpart CCCCCC § 63.11116(c)). 6.1.10 Portable gasoline containers that meet the requirements of 40 CFR part 59, subpart F, are considered acceptable for compliance with Condition 6.1.7.3. (§ 63.11116(d)) What are my recordkeeping requirements? ('63.11125) 6.1.11 Each owner or operator of an affected source under this subpart shall keep records as specified below. (§ 63.11125(d)) 6.1.11.1 Records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control and monitoring equipment. (§ 63.11 125(d)(1)) 6.1.11.2 Records of actions taken during periods of malfunction to minimize emissions in accordance with §63.11115(a) (Condition 6.1.5), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation. (§ 63.11125(d)(2)) What parts of the General Provisions apply to me? ((63.11125) Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 49 6.1.12 Table 3 to this subpart shows which parts of the General Provisions apply to you. (§ 63.11130) The general provisions that apply to this GDF include, but are not limited to the following: 6.1.12.1 Prohibited activities in § 63.4(a). 6.1.12.2 Circumvention in § 63.4(b). 7. M002—Cold Cleaner Solvent Vats Parameter Permit Limitations Compliance Emission Monitoring Condition Factor Number Short Term Long Term Method Interval Work Practice 7.1 N/A N/A N/A Internal Audit Annually Standards Transfer and 7.2 N/A N/A N/A Certification Annually Storage of Waste/Used Solvents Note that these emission units are exempt from the APEN reporting requirements in Regulation No. 3, Part A and the construction permit requirements in Regulation No. 3, Part B, as long as actual, uncontrolled emissions do not exceed the APEN de minimis level (see Regulation No.3,Part B, Section II.D.I.a). 7.1 Operation of the cold cleaner solvent vats shall meet the standards defined in Colorado Regulation 7, Section X.B. Compliance shall be monitored by following the work practices defined in Public Service Company's Policy Manual regarding operation, maintenance and design of the cold cleaner solvent vats. The Policy Manual shall include, at a minimum the requirements defined in Colorado Regulation 7, Section X.B and shall be available to the inspector upon request. Audits of the vat operations and/or the policy manual shall be performed annually to ensure that operations are performed within the requirements of the policy manual and that the policy manual incorporates the requirements of Regulation 7, Section X.B. Audit reports are to be maintained and made available to the Division upon request. 7.2 The transfer and storage of waste and used solvents from the cold cleaner solvent vats are subject to the following requirements (Colorado Regulation No. 7, Section X.A.3 and 4): 7.2.1 In any disposal or transfer of waste or used solvent, at least 80 percent by weight of the solvent/waste liquid shall be retained (i.e., no more than 20 percent of the liquid solvent/solute mixture shall evaporate or otherwise be lost during transfers). 7.2.2 Waste or used solvents shall be stored in closed containers unless otherwise required by law. Operating Permit Number: 97OPWF.180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 50 8. T005 & T006—Two (2) Simple Cycle Combustion Turbines Unless otherwise specified, the limitations apply to both turbines together Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number RACT 8.1 N/A N/A N/A See Condition 8.1 Requirements NOx 8.2 For Each Combustion Turbine: N/A Continuous Continuously 9 ppmvd @ 15%O2 on a 1-hr Emission average,except as provided for below Monitoring During Combustion Tuning and System Testing(not to exceed 60 hrs/yr per for turbines T005&T006 combined): 100 ppmvd @ 15%O2 on a 1-hr average Note that the above limits do not apply during periods of startup and • shutdown. For Each Combustion Turbine: 15 ppm @ 15%O2,except as provided for below: 96 ppm @ 15%O2 when operating at less than 75%of peak load 96 ppm @ 15%O2 when operating at temperatures less than 0°F Averaging time is 4-hour rolling. For periods when multiple standards apply,the applicable standard is the average of applicable standards during each hour N/A 39.9 tons/yr CO 8.3 N/A 20 tons/yr N/A Continuous Continuously Emission Monitoring System SO2 8.4 For Each Combustion Turbine: N/A See Condition 8.4 0.06 lb/MMBtu N/A 3.7 tons/yr Continuous Continuously Monitoring System VOC 8.5 N/A 2.3 tons/yr T005: Recordkeeping Monthly 0.0002 lb/MMBtu and Calculation T006: 0.0001 lb/MMBtu Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT i Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE1 80 Page 51 Parameter Permit Limitations Compliance Monitoring Condition Short Term Long Term Emission Factor Method Interval Number PM 8.6 For Each Combustion Turbine: N/A Fuel Restriction Only Pipeline 0.1 lb/MMBtu,the average of three Quality (3) 1-hr tests Natural Gas is Used as Fuel N/A 8.9 tons/yr T005: Recordkeeping Monthly 0.004 lb/MMBtu and Calculation T006: 0.003 lb/MMBtu PMia 8.7 N/A 8.9 tons/yr T005: Recordkeeping Monthly 0.004 lb/MMBtu and Calculation T006: 0.003 lb/MMBtu Natural Gas 8.8 N/A 2,178 MMscf/yr N/A Recordkeeping Monthly Usage Sulfur Content 8.9 N/A N/A N/A See Condition 8.9 of Natural Gas Continuous 8.10 N/A N/A N/A See Condition 8.10 Emission Monitoring System Requirements NSPS Subpart 8.11 N/A N/A N/A See Condition 8.11 KKKK General Requirements NSPS General 8.12 N/A N/A N/A As Required by Subject to Provisions NSPS General NSPS General Provisions Provisions NOx Emissions 8.13 N/A N/A N/A See Condition 8.13 from Insignificant Activities Opacity 8.14 Not to Exceed 20%Except as N/A Fuel Restriction Only Pipeline Provided for in 8.15 Below Quality Opacity 8.15 For Certain Operational Activities- N/A Natural Gas is Not to Exceed 30%,for a Period or Used as Fuel Periods Aggregating More than Six (6)Minutes in any 60 Consecutive Minutes 0 Opacity—State 8.16 Not to Exceed 20% N/A Only Acid Rain 8.17 See Section III of this Permit Certification Annually Requirements Restrictions on 8.18 See Condition 8.18 N/A Certification Annually Relaxing Emission Limitations Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 52 8.1 The combustion turbines are subject to the Reasonably Available Control Technology Requirements (RACT) for NOx (Colorado Construction Permit 07WE1100 and Colorado Regulation No. 3, Part B, Section III.D.2.a). RACT has been determined to be advanced dry low NOx (DLN) combustion systems with the emission limitations specified in Condition 8.2.1. 8.2 Emissions of Nitrogen Oxides (NOx) shall not exceed the following limitations: 8.2.1 For purposes of RACT, Nitrogen Oxide (NOx) emissions from each turbine shall not exceed the following limitations (Colorado Construction Permit 07WE1100): 8.2.1.1 Except as provided for below, emissions of NOx shall not exceed 9 ppmvd at 15% O2, on a 1-hour average. 8.2.1.2 During periods of combustion tuning and testing, emissions of NOx shall not exceed 100 ppmvd at 15% O2, on a 1-hour average. Use of this NOx emission limit for purposes of combustion tuning and testing shall not exceed 60 hours in any calendar year for Turbines T005 and T006 combined. Records of the number of hours each turbine undergoes combustion tuning and/or testing shall be recorded and maintained and made available to the Division upon request. 8.2.1.3 The emission limitations above do not apply during periods of startup and shutdown; however, emissions during startup and shutdown shall be included in determining compliance with the annual limitation in Condition 8.2.3. 8.2.1.4 "Startup" shall have the same definition as provided for in Condition 1.2.1.5. 8.2.1.5 "Shutdown" shall have the same definition as provided for in Condition 1.2.1.6. 8.2.1.6 "Combustion Tuning and Testing" shall have the same definition as provided for in Condition 1.2.1.7. Compliance with the NOx RACT emission limitations in Conditions 8.2.1.1 and 8.2.1.2 shall be monitored using the continuous emission monitoring systems (CEMS)required by Condition 8.10, as follows: 8.2.1.7 Except as provided for in Condition 8.2.1.8, all valid CEMS concentration (ppm) data points, excluding startup and shutdown data points, shall at the end of each clock hour, be summarized to generate the average NOx concentration in accordance with the requirements in 40 CFR Part 75 and Condition 5.2.1.3.b of this permit. Data used to generate the one-hour average NOx concentration shall not include replaced data, nor shall the data be bias-adjusted. Replaced data shall be reported as monitor down time in the quarterly reports required by Condition 5.5. Each clock hour average NOx concentration shall be compared to the limitations in Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 53 Conditions 8.2.1.1 and 8.2.1.2 as appropriate. 8.2.1.8 In the event that the startup ends within a clock hour or the shutdown begins within a clock hour, all non-startup and/or non-shutdown concentration (ppm) data points within that clock hour shall be averaged together to generate the average NOx concentration in accordance with the requirements in 40 CFR Part 75 and Condition 5.2.1.3.b of this permit. Data used to generate the one-hour average NOx concentration shall not include replaced data, nor shall the data be bias-adjusted. Replaced data shall be reported as monitor down time in the quarterly reports required by Condition 5.5. Each average NOx concentration shall be compared to the limitations in Conditions 8.2.1.1 and 8.2.1.2 as appropriate. 8.2.1.9 The emission limits in Condition 8.2.1.2 apply to any clock hour in which combustion tuning and testing activities occur. 8.2.2 For purposes of 40 CFR Part 60 Subpart KKKK, NOx emissions from each turbine shall not exceed the following: 8.2.2.1 Except as provided for below, NOx emissions shall not exceed 15 ppm at 15 % O2. 8.2.2.2 When operating at less than 75% of the peak load, NOx emissions shall not exceed 96 ppm at 15% O2, 8.2.2.3 When operating at temperatures less than on 0 °F, NOx emissions shall not exceed 96 ppm at 15% O2. (Colorado Construction Permit 07WE1100 and 40 CFR Part 60 Subpart KKKK § 60.4320(a)) 8.2.2.4 For operating periods during which multiple emissions standards apply, the applicable standard is the average of the applicable standards during each hour. For hours with multiple emissions standards, the applicable limit for that hour is determined based on the condition that corresponded to the highest emissions standard. (40 CFR Part 60 Subpart KKKK § 60.4380(b)(3)) Compliance with the above NSPS KKKK NOx emission shall be monitored using the continuous emission monitoring systems (CEMS) required by Condition 8.10, as follows: 8.2.2.5 All valid CEMS concentration (ppm) data points, including startup, shutdown and malfunction data points, shall at the end of each clock hour, be summarized to generate the average NOx concentration in accordance with the requirements in 40 CFR Part 75 and Condition 5.2.1.3.b of this permit. 8.2.2.6 For each unit operating hour in which a valid hourly average is obtained for both NOx and diluent monitors, the data acquisition and handling Operating Permit Number: 97OPW E180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 54 system must calculate and record the hourly NOx emission rate in units of ppm or lb/MMBtu, using the appropriate equation from method 19 in appendix A of this part. For any hour in which the hourly average O2 concentration exceeds 19.0 percent O2 (or the hourly average CO2 concentration is less than 1.0 percent CO2), a diluent cap value of 19.0 percent O2 or 1.0 percent CO2 (as applicable) may be used in the emission calculations. (40 CFR Part 60 Subpart KKKK § 60.4350(b)) 8.2.2.7 For simple cycle units without heat recovery, use the calculated hourly average emission rates to assess excess emissions on a 4-hour rolling average basis, as described in §60.4380(b)(1) (Condition 5.6.3.1). (40 CFR Part 60 Subpart KKKK § 60.4350(b)) 8.2.2.8 Data used to generate the one-hour average NOx concentration shall not include replaced data, nor shall the data be bias-adjusted. Replaced data shall be reported as monitor down time in the quarterly reports required by Condition 5.5. Further provisions regarding reporting excess emissions are provided for in Condition 5.6. Note that the NOx emission limits in this Condition 8.2.2 are not applicable during times of startup, shutdown and malfunction. However, those instances during startup, shutdown and malfunction when the NOx limitation is exceeded shall be identified in the excess emission reports required by Condition 5.5. 8.2.3 Annual emissions of NOx from both turbines together shall not exceed the above limitation (Colorado Construction Permit 07WE1100, as modified under the provisions of Section I, Condition 1.3 to remove the monthly limitations). Monthly emissions from each turbine shall be determined using the continuous emission monitoring system required by Condition 8.10. For any hour in which fuel is combusted in the turbines, including periods of startup, shutdown and malfunction, the permittee shall program the DAHs to calculate lb/hr NOx emissions in accordance with the requirements in Condition 5.2.1.3.b of this permit and 40 CFR Part 75, including any replaced data and the data shall be bias-adjusted, if warranted. Specifically hourly mass NOx emissions (in lb/hr) shall be calculated by multiplying the hourly NOx lb/MMBtu value (which includes replaced or bias-adjusted data, as applicable) by the hourly heat input value (MMBtu/hr) (which includes replaced data from the fuel flow measurement, as applicable). The hourly NOx lb/MMBtu and heat input values shall be determined using equations F-5 or F-6, as appropriate for the diluent monitored by the CEMS and F-20 in Appendix F of 40 CFR Part 75. The resulting NOx lb/hr value is then multiplied by the unit operating time for that hour to produce a NOx lbs value. Hourly NOx mass emissions (lbs) shall be summed and divided by 2000 lb/ton to determine monthly NOx emissions (in tons). Monthly emissions (in tons) from each turbine shall be summed together and used in a twelve month rolling total to monitor compliance with the annual emission Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT 1 Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 55 limitation. Each month a new twelve month total shall be calculated using the previous twelve months total. 8.3 Annual emissions for CO from both turbines together shall not exceed the above limitation (Colorado Construction Permit 07WE1100, as modified under the provisions of Section I, Condition 1.3 to remove the monthly limitations). Monthly emissions from each turbine shall be determined using the continuous emission monitoring system required by Condition 8.10. For any hour in which fuel is combusted in the turbines, including periods of startup, shutdown and malfunction, the permittee shall program the DAHs to calculate lb/hr CO emissions in accordance with the requirements in Condition 5.2.1.3.b of this permit and 40 CFR Part 75, including any replaced data, if warranted. Specifically hourly mass CO emissions (in lb/hr) shall be calculated by multiplying the hourly CO lb/MMBtu value (which includes replaced date in accordance with the provisions in Part 75 for NOx replacement, as applicable) by the hourly heat input value (MMBtu/hr) (which includes replaced data from the stack flow measurement, as applicable). The hourly CO lb/MMBtu and heat input values shall be determined using equations F-5 or F-6 (for NON), as appropriate for the diluent monitored by the CEMS and F-20 in Appendix F of 40 CFR Part 75. The resulting CO lb/hr value is then multiplied by the unit operating time for that hour to produce a CO lbs value. Hourly CO mass emissions (lbs) shall be summed and divided by 2000 lb/ton to determine monthly CO emissions (in tons). Monthly emissions (in tons) from each turbine shall be summed together and used in a twelve month rolling total to monitor compliance with the annual emission limitation. Each month a new twelve month total shall be calculated using the previous twelve months total. 8.4 Sulfur Dioxide (SO2) emissions shall not exceed the following limitations: 8.4.1 You must not bum in the subject stationary combustion turbine any fuel which contains total potential sulfur emissions in excess of 26 ng SO2/J (0.060 lb SO2/MMBtu) heat input. (40 CFR Part 60 Subpart KKKK § 60.4330(a)(2)) In the absence of credible evidence to the contrary, compliance with the fuel gas sulfur limit is presumed since only pipeline quality natural gas is used as fuel in these turbines. The natural gas used as fuel shall meet the requirements in Condition 8.9. 8.4.2 Annual Sulfur Dioxide (SO2) emissions from both turbines together shall not exceed the above limitations (Colorado Construction Permit 07WE1100, as modified under the provisions of Section I, Condition 1.3 to remove the monthly limitations). Compliance with the annual SO2 emission limitations shall be monitored using the monitoring method specified in 40 CFR Part 75 Appendix D. Monthly emissions from each turbine shall be summed together and used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 56 8.5 Annual VOC emissions from both turbines together shall not exceed the above limitations (Colorado Construction Permit 07WE1100, as modified under the provisions of Section I, Condition 1.3 to remove the monthly limitations). Monthly emissions from each turbine shall be calculated by the end of the subsequent month using the emission factors in the above table (from performance tests conducted May 20 & 21, 2009) and the heat input for the month as recorded on the data acquisition and handling system (DAHS) for the continuous emission monitoring system (required by Condition 8.10) in the following equation: tons/mo=(EF,lbs/NMBtu)x heat input(MMBtu/mo) 2000 lbs/ton Monthly emissions from each turbine shall be summed together and used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 8.6 Particulate matter(PM) emissions shall not exceed the following limitations: 8.6.1 Particulate Matter (PM) emissions from each turbine shall not exceed 0.1 lbs/MMBtu (Colorado Construction Permit 07WE1100 and Colorado Regulation No. 1, Section III.A.1.c). In the absence of credible evidence to the contrary, compliance with the particulate matter emission limits is presumed since only pipeline natural gas is permitted to be used as fuel in the turbines. 8.6.2 Annual PM emissions from both turbines together shall not exceed the above limitations (Colorado Construction Permit 07WE1100, as modified under the provisions of Section I, Condition 1.3 to remove the monthly limitations). Monthly emissions from each turbine shall be calculated by the end of the subsequent month using the emission factors in the above table (from performance tests conducted May 20 & 21, 2009) and the heat input for the month as recorded on the data acquisition and handling system (DAHS) for, the continuous emission monitoring system (required by Condition 8.10) in the equation in Condition 8.5 Monthly emissions from each turbine shall be summed together and used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 8.7 Annual PMI° emissions from both turbines together shall not exceed the above limitations (Colorado Construction Permit 07WE1100, as modified under the provisions of Section I, Condition 1.3 to remove the monthly limitations). Monthly emissions from each turbine shall be calculated by the end of the subsequent month using the emission factors in the above table (from performance tests conducted May 20 & 21, 2009) and the heat input for the month as recorded on the data acquisition and handling system (DAHS) for the continuous emission monitoring system (required by Condition 8.10) in the equation in Condition 8.5. Monthly emissions from each turbine shall be summed together and used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 57 8.8 Natural gas consumption for both turbines together shall not exceed the above limitations (Colorado Construction Permit 07WE1100, as modified under the provisions of Section I, Condition 1.3 to remove the monthly limitations). The natural gas consumption for each combustion turbine shall be monitored using the data acquisition and handling systems (DAHS) for the continuous emission monitoring system (CEMS) required by Condition 8.10. Monthly natural gas fuel consumption for each turbine shall be summed together and used in a rolling twelve month total to monitor compliance with the annual limitation. Each month new twelve month rolling total shall be calculated using the previous twelve months data for that fuel. 8.9 The permittee shall maintain records demonstrating that the natural gas burned has a total sulfur content less than 0.5 grains/100 SCF. Natural gas that meets this sulfur limitation is considered pipeline quality natural gas as defined in 40 CFR Part 72. The demonstration shall be made using any of the methods identified in 40 CFR Part 75 Appendix D, Section 2.3.1.4. These records shall be made available to the Division upon request. 8.10 For each combustion turbine, continuous emission monitoring systems (CEMS) shall be installed, certified, calibrated, maintained and operated for measuring NOx(including diluent gas either CO2 or O2) and CO emissions (Colorado Construction Permit 07WE1100 and 40 CFR Part 75). The continuous emission monitoring systems shall meet the requirements in Condition 5 of this permit. Monthly emissions of NOx and CO from the continuous emission monitoring system shall be used as specified by Conditions 8.2.3 and 8.3 to monitor compliance with the annual NOx and CO emission limitations. 8.11 You must operate and maintain your stationary combustion turbine, air pollution control equipment, and monitoring equipment in a manner consistent with good air pollution control practices for minimizing emissions at all times including during startup, shutdown, and malfunction. (40 CFR Part 60 Subpart KKKK § 60.4333(a)) 8.12 Each turbine is subject to the NSPS Subpart A, General Provisions requirements (Colorado Regulation No. 6, Part A, Federal 40 CFR 60.1 through 60.19). Specifically, these units are subject to the following: 8.12.1 No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gasses discharged to the atmosphere. (40 CFR § 60.12) 8.12.2 At all times, including periods of startup, shutdown, and malfunction, owners and g p, operators shall, to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (40 CFR § 60.11(d)). Operating Permit Number: 97OPW E 180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 58 8.13 NOx emissions from all insignificant activities associated with these turbines shall be included in monitoring compliance with the annual NOx emission limitation in Condition 8.2.3 (Colorado Construction Permit 07WE1100). The permittee shall track emissions from all NOx emitting insignificant activities associated with these turbines on a monthly basis and include those emissions in the annual emission calculations specified in Condition 8.2.3. This information shall be kept on site and made available to the Division upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN). Based on the information available as of permit issuance [January 1, 2011] there are no insignificant activities associated with turbines 5 and 6 that are a source of NOx emissions. 8.14 Except as provided for in Condition 8.15 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Construction Permit 07WE1100 and Colorado Regulation No. 1, Section II.A.1). This opacity standard applies to each combustion turbine. In the absence of credible evidence to the contrary, compliance with the 20% opacity limit shall be presumed since only pipeline quality natural gas is permitted to be used as fuel in the turbines. 8.15 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications, or adjustment or occasional cleaning of control equipment which is in excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Construction Permit 07WE1100 and Colorado Regulation No. 1, Section II.A.4). This opacity standard applies to each combustion turbine. In the absence of credible evidence to the contrary, compliance with the 30% opacity limit shall be presumed since only pipeline quality natural gas is permitted to be used as fuel in the turbines. 8.16 State-Only Requirement: No owner or operator may discharge, or cause the discharge into the atmosphere of any particulate matter which is greater than 20% opacity (Colorado Regulation No. 6, Part B, Section II.C.3). This opacity standard applies to each combustion turbine. In the absence of credible evidence to the contrary, compliance with the 20% opacity requirement is presumed since only pipeline quality natural gas is permitted to be used as fuel in the turbines. This opacity standard applies at all times except during periods of startup, shutdown and malfunction (40 CFR Part 60 Subpart A § 60.11(c), as adopted by reference in Colorado Regulation No. 6, Part B, Section I.A). 8.17 This unit is subject to the Title IV Acid Rain Requirements. As specified in 40 CFR Part 72.72(b)(1)(viii), the acid rain permit requirements shall be complete and segregable portion of the Operating Permit. As such the requirements are found in Section III of this permit. 8.18 The requirements of Colorado Regulation No. 3, Part D shall apply to these turbines at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 59 such as a restriction on hours of operation (Colorado Construction Permit 07WE1100 and Colorado Regulation No. 3, Part D, Sections VI.B.4 and V.A.7.B). With respect to this Condition 8.18, Colorado Regulation No. 3, Part D requirements may apply to future modifications if the emission limitations are modified to equal or exceed the following thresholds: Emissions(tons/yr) Pollutant Program Comment/Explanation Threshold Current Permit Limit PM PSD 25 8.9 PM,o PSD 15 8.9 NOX NANSR 40 39.9 NOX PSD 40 39.9 CO PSD 100 20 Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 60 9. M004 - Diesel Fuel Fired Internal Combustion Engines Emergency Generator(2 engines, each 1,800 hp) and Emergency Fire Pump (255 hp) Unless otherwise specified,the requirements apply to each engine Parameter Permit Limitations Compliance Monitoring Condition Emission Factor Number Short Term Long Term Method Interval MACT ZZZZ 9.1 Change Oil and Filter N/A See Condition 9.1 Requirements Inspect Air Cleaner Inspect all Hoses and Belts SO2 9.2 0.8 lbs/MMBtu N/A Fuel Restriction Only Diesel Fuel is Used as Fuel Opacity 9.3 Not to Exceed 20%Except as N/A EPA Method 9 See Condition Provided for Below 9.3 For Startup—Not to Exceed 30%,for a Period or Periods Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes Note that these emission units are exempt from the APEN reporting requirements in Regulation No. 3, Part A and the construction permit requirements in Regulation No. 3, Part B, as long as actual, uncontrolled emissions do not exceed the APEN de minimis level (see Regulation No.3,Part B,Section II.D.1.a). 9.1 These engines are subject to the requirements in 40 CFR Part 63 Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", as follows: The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart ZZZZ published in the Federal Register on January 30, 2013 (including the corrections published March 6, 2013). However, if revisions to this Subpart are promulgated at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63 Subpart ZZZZ. [address vacated requirements for demand response—once mandate is issued] 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) 9.1.1 If you have an existing stationary CI RICE located at an area source of HAP emissions, you must comply with the applicable emission limitations and operating limitations no later than May 3, 2013. (§ 63.6595(a)(1)) Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 61 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 0 63.6603) 9.1.2 If you own or operate an existing stationary CI RICE located at an area source of HAP emissions, you must comply with the requirements in Table 2d to this subpart and the operating limitations in Table 2b to this subpart which apply to you. (§ 63.6603(a)) The requirements in Table 2d that apply to these emergency CI RICE are as follows: 9.1.2.1 Change oil and filter every 500 hours of operation or annually whichever comes first. (Table 2d, item 4.a) 9.1.2.2 Inspect air cleaner every 1,000 hours of operation or annually whichever comes first, and replace as necessary. (Table 2d, item 4.b) 9.1.2.3 Inspect all hoses and belts every 500 hours of operation or annually whichever comes first, and replace as necessary. (Table 2d, item 4.c) Notwithstanding the above requirements, the following applies: 9.1.2.4 Sources have the option to utilize an oil analysis program as described in Condition 9.1.9 in order to extend the specified oil change requirement in Condition 9.1.2.1. (Table 2d, footnote 1) 9.1.2.5 If an emergency engine is operating during an emergency and it is not possible to shut down the engine in order to perform the management practice requirements on the schedule required in Conditions 9.1.2.1 through 9.1.2.3, or if performing the management practice on the required schedule would otherwise pose an unacceptable risk under Federal, State, or local law, the management practice can be delayed until the emergency is over or the unacceptable risk under Federal, State, or local law has abated. The management practice should be performed as soon as practicable after the emergency has ended or the unacceptable risk under Federal, State, or local law has abated. Sources must report any failure to perform the management practice on the schedule required and the Federal, State or local law under which the risk was deemed unacceptable. (Table 2d, footnote 2) What fuel requirements must I meet if I own or operate a stationary CI RICE? 0 63.6604) 9.1.3 Beginning January 1, 2015, if you own or operate an existing emergency CI stationary RICE with a site rating of more than 100 brake HP and a displacement of less than 30 liters per cylinder that uses diesel fuel and operates or is contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in Conditions 9.1.11.2.b and 9.1.11.2.c or that operates for the purpose specified in §63.6640(f)(4)(ii), you must use diesel fuel that meets the requirements in 40 CFR 80.510(b) for nonroad diesel fuel, except that any existing diesel fuel Operating Permit Number: 97OPW E 1 80 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 62 purchased (or otherwise obtained) prior to January 1, 2015, may be used until depleted. . (§ 63.6604(b)) What are my general requirements for complying with this subpart? 0 63.6605) 9.1.4 You must be in compliance with the emission limitations, operating limitations, and other requirements in this subpart that apply to you at all times. (§ 63.6605(a)) 9.1.5 At all times you must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. (§ 63.6605(b)) What are my monitoring, installation, collection, operation, and maintenance requirements? 0 63.6625) 9.1.6 If you own or operate an existing emergency or black start stationary RICE located at an area source of HAP emissions, you must operate and maintain the stationary RICE and after-treatment control device (if any) according to the manufacturer's emission- - related written instructions or develop your own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. (§ 63.6625(e) and (e)(3)) 9.1.7 If you own or operate an existing emergency stationary RICE with a site rating of less than or equal to 500 brake HP located at a major source of HAP emissions or an existing emergency stationary RICE located at an area source of HAP emissions, you must install a non-resettable hour meter if one is not already installed. (§ 63.6625(f)) 9.1.8 If you operate a new, reconstructed, or existing stationary engine, you must minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the emission standards applicable to all times other than startup in Tables la, 2a, 2c, and 2d to this subpart apply. (§ 63.6625(h)) 9.1.9 If you own or operate a stationary CI engine that is subject to the work, operation or management practices in Condition 9.1.2, you have the option of utilizing an oil analysis program in order to extend the specified oil change requirement in Condition 9.1.2.1. The oil analysis must be performed at the same frequency specified for changing the oil in Condition 9.1.2.1. The analysis program must at a minimum Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 63 analyze the following three parameters: Total Base Number, viscosity, and percent water content. The condemning limits for these parameters are as follows: Total Base Number is less than 30 percent of the Total Base Number of the oil when new; viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or percent water content (by volume) is greater than 0.5. If all of these condemning limits are not exceeded, the engine owner or operator is not required to change the oil. If any of the limits are exceeded, the engine owner or operator must change the oil within 2 business days of receiving the results of the analysis; if the engine is not in operation when the results of the analysis are received, the engine owner or operator must change the oil within 2 business days or before commencing operation, whichever is later. The owner or operator must keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes for the engine. The analysis program must be part of the maintenance plan for the engine. (§ 63.6625(i)) How do I demonstrate continuous compliance with the emission limitations, operating limitations and other requirements? (§63.6640) 9.1.10 You must demonstrate continuous compliance with each emission limitation, operating limitation, and other requirements in Tables la and lb, Tables 2a and 2b, Table 2c, and Table 2d [Condition 9.1.2] to this subpart that apply to you according to methods specified in Table 6 to this subpart. (§ 60.6640(a)) The methods specified in Table 6 of Subpart ZZZZ are as follows: 9.1.10.1 Operating and maintaining the stationary RICE according to the manufacturer's emission-related operation and maintenance instructions (Table 6, Item 9.a.i); or 9.1.10.2 Develop and follow your own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. (Table 6, Item 9.a.ii) 9.1.11 If you own or operate an emergency stationary RICE, you must operate the emergency stationary RICE according to the requirements in Conditions 9.1.11.1 through 9.1.11.3. In order for the engine to be considered an emergency stationary RICE under this subpart, any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 hours per year, as described in Conditions 9.1.11.1 through 9.1.11.3, is prohibited. If you do not operate the engine according to the requirements in Conditions 9.1.11.1 through 9.1.11.3, the engine will not be considered an emergency engine under this subpart and must meet all requirements for non-emergency engines. (§ 63.6640(f)) 9.1.11.1 There is no time limit on the use of emergency stationary RICE in emergency situations. (§ 63.6640(f)(1)) Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 64 9.1.11.2 You may operate your emergency stationary RICE for any combination of the purposes specified below for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by Condition 9.1.11.3 as part of the 100 hours per calendar year allowed by this Condition 9.1.11.2. (§ 63.6640(O(2)) a. Emergency stationary RICE may be operated for maintenance checks and readiness testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The owner or operator may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the owner or operator maintains records indicating that federal, state, or local standards require q maintenance and testing of emergency RICE beyond 100 hours per calendar year. (§ 63.6640(O(2)(i)) b. Emergency stationary RICE may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see §63.14), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-002-3. (§ 63.6640(O(2)(ii)) c. Emergency stationary RICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency. (§ 63.6640(f)(2)(iii)) 9.1.11.3 Emergency stationary RICE located at area sources of HAP may be operated for up to 50 hours per calendar year in non-emergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in Condition 9.1.11.2. Except as provided in paragraphs (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? (sC 63.6650) 9.1.12 If you own or operate an emergency stationary RICE with a site rating of more than 100 brake HP that operates or is contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in Conditions 9.1.11.2.b and Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 65 9.1.11.2.c or that operates for the purpose specified in §63.6640(f)(4)(ii), you must submit an annual report according to the requirements in paragraphs (h)(1) through (3) of this section. (§ 63.6650(h)) What records must I keep? (sC 63.6655) 9.1.13 You must keep records of the maintenance conducted on the stationary RICE in order to demonstrate that you operated and maintained the stationary RICE and after- treatment control device (if any) according to your own maintenance plan if you own or operate an existing stationary emergency RICE. (§ 63.6655(e) and (e)(2)) 9.1.14 If you own or operate an existing emergency stationary RICE located at an area source of HAP emissions that does not meet the standards applicable to non- emergency engines, you must keep records of the hours of operation of the engine that is recorded through the non-resettable hour meter. The owner or operator must document how many hours are spent for emergency operation, including what classified the operation as emergency and how many hours are spent for non- emergency operation. If the engine is used for the purposes specified in Conditions 9.1.11.2. or 9.1.11.2.c or §63.6640(f)(4)(ii), the owner or operator must keep records of the notification of the emergency situation, and the date, start time, and end time of engine operation for these purposes.. (§ 63.6655(f) and(f)(2)) In what form and how long must I keep my records? (sC 63.6660) 9.1.15 Records shall be kept in the form and for the duration specified in § 63.6660. What parts of the General Provisions apply to me? (sC 63.6665) 9.1.16 Table 8 of Subpart ZZZZ shows which parts of the General Provisions in §§63.1 through 63.15 apply to you. (§ 63.6665) The general provisions that apply to these engines include, but are not limited to the following: 9.1.16.1 Prohibited activities in § 63.4(a). 9.1.16.2 Circumvention in § 63.4(b) 9.2 Sulfur Dioxide (SO2) emissions shall not exceed 0.8 lbs/MMBtu (Colorado Regulation No. 1, Section VI.B.4.b.(i)). In the absence of credible evidence to the contrary, compliance with the SO2 emission limitation shall be presumed since only diesel fuel is permitted to be used as fuel in these engines. 9.3 Opacity of emissions from these engines shall not exceed the following: 9.3.1 Except as provided for in Condition 9.3.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 66 9.3.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from startup which is in excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). Compliance with these limitations shall be monitored by conducting opacity observations in accordance with EPA Reference Method 9 as follows: 9.3.3 As specified in Condition 9.1.8 engine startup shall not exceed 30 minutes. An engine startup period of less than 30 minutes shall not require an opacity observation to monitor compliance with the opacity limit in Condition 9.3.2. A record shall be kept of the date and time each engine was started and when it was shutdown. 9.3.4 An opacity observation shall be conducted annually (calendar year period) on each engine to monitor compliance with the opacity limit in Condition 9.3.1. Annual opacity observations for and individual engine shall be separated by a period of four(4) months. If an engine is operated more than 250 hours in any calendar year period, a second opacity observation shall be conducted for that engine. If two opacity readings are conducted in the annual (calendar year) period, such readings shall be conducted at least thirty days apart. 9.3.5 If an engine is not operated during the annual (calendar year) period, then no opacity observation is required. 9.3.6 Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the opacity limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. 9.3.7 All opacity observations shall be performed by an observer with current and valid Method 9 certification. Results of Method 9 readings and a copy of the certified Method 9 reader's certificate shall be kept on site and made available to the Division upon request. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 67 SECTION III - Acid Rain Requirements 1. Designated Representative and Alternate Designated Representative g P g P Designated Representative Alternate Designated Representative Name: Mark Fox Name: Gary Magno Title: General Manager — Power Title: Manager Environmental Generation, Colorado Services, Air Quality Compliance Phone: (303) 425-3779 Phone: (303) 294-2177 2. Sulfur Dioxide Emission Allowances and Nitrogen Oxide Emission Limitations 2015 2016 2017 2018 2019 2020 Turbine No.2 SO2 0* 0* 0* 0* 0* 0* Allowances,per 40 CFR Part 73.10(b),Table 2 NOx Limits This Unit Has No Title IV NOx Limits(see Section 5) Turbine No.3 SO2 0* 0* 0* 0* 0* 0* Allowances, per 40 CFR Part 73.10(6),Table 2 NOx Limits This Unit Has No Title IV NOx Limits(see Section 5) Turbine No.4 SO2 0* 0* 0* 0* 0* 0* Allowances, per 40 CFR Part 73.10(b),Table 2 NOx Limits This Unit Has No Title IV NOx Limits(see Section 5) Turbine No.5 SO2 0* 0* 0* 0* 0* 0* Allowances, per 40 CFR Part 73.10(b),Table 2 NOx Limits This Unit Has No Title IV NOx Limits(see Section 5) Turbine No.6 I I I I I Operating Permit Number: 97OP W E 180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 68 2015 2016 2017 2018 2019 2020 SO2 0* 0* 0* 0* 0* 0* Allowances,per , 40 CFR Part 73.10(b),Table 2 NOX Limits This Unit Has No Title IV NOX Limits(see Section 5) * Under the provisions of§ 72.84(a) any allowance allocations to, transfers to and deductions from an affected unit's Allowance Tracking System account is considered an automatic permit amendment and as such no revision to the permit is necessary. This is a new unit and allowances were not included in 40 CFR Part 73,Table 2(1997 version of CFR). 3. Standard Requirements Units T002, T003, T004, T005 and T006 of this facility are subject to and the source has certified that they will comply with the following standard conditions (from Acid Rain Permit Application, EPA Form 7610-16 (Revised 7-2014), with some clarifying language added (e.g. "permitting authority" replaced with "Division" and "Act"replaced with "Federal Clean Air Act"). Permit Requirements. (1) The designated representative of each affected source and each affected unit at the source shall: (i) Submit a complete Acid Rain permit application (including a compliance plan) under 40 CFR part 72 in accordance with the deadlines specified in 40 CFR 72.30; and i in timely mannerany infrm i n i ii Subm t a a e o at o that the Division determines is ( ) necessary in order to review an Acid Rain permit application and issue or deny an Acid Rain permit; (2) The owners and operators of each affected source and each affected unit at the source shall: (i) Operate the unit in compliance with a complete Acid Rain permit application or a superseding Acid Rain permit issued by the Division; and (ii) Have an Acid Rain Permit. Monitoring Requirements. (1) The owners and operators and, to the extent applicable, designated representative of each affected source and each affected unit at the source shall comply with the monitoring requirements as provided in 40 CFR part 75. (2) The emissions measurements recorded and reported in accordance with 40 CFR part 75 shall be used to determine compliance by source or the unit with the Acid Rain emissions limitations and emissions reduction requirements for sulfur dioxide and nitrogen oxides under the Acid Rain Program. (3) The requirements of 40 CFR part 75 shall not affect the responsibility of the owners and operators to monitor emissions of other pollutants or other emissions characteristics at the unit under other applicable requirements of the Federal Clean Air Act and other provisions of the operating permit for the source. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 69 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) StartingJanuary on the later of 1, 2000 or the deadline for monitor certification under 40 CFR part 75, an affected unit under 40 CFR 72.6(a)(3). (4) Allowances shall be held in, deducted from, or transferred among Allowance Tracking System accounts in accordance with the Acid Rain Program. (5) An allowance shall not be deducted in order to comply with the requirements under paragraph (1) of the sulfur dioxide requirements prior to the calendar year for which the allowance was allocated. (6) An allowance allocated by the Administrator under the Acid Rain Program is a limited authorization to emit sulfur dioxide in accordance with the Acid Rain Program. No provision of the Acid Rain Program, the Acid Rain permit application, the Acid Rain permit, or an exemption under 40 CFR 72.7 or 72.8 and no provision of law shall be construed to limit the authority of the United States to terminate or limit such authorization. (7) An allowance allocated by the Administrator under the Acid Rain Program does not constitute a property right. Nitrogen Oxides Requirements. The owners and operators of the source and each affected unit at the source shall comply with the applicable Acid Rain emissions limitation for nitrogen oxides. Excess Emissions Requirements. (1) The designated representative of an affected source that has excess emissions in any calendar year shall submit a proposed offset plan to the Administrator of the U. S. EPA, as required under 40 CFR part 77. (2) The owners and operators of an affected source that has excess emissions in any calendar year shall: (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. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 70 Recordkeeping and Reporting Requirements. (1) Unless otherwise provided, the owners and operators of the source and each affected unit at the source shall keep on site at the source each of the following documents for a period of 5 years from the date the document is created. This period may be extended for cause, at any time prior to the end of 5 years, in writing by the Administrator or the Division: (i) The certificate of representation for the designated representative for the source and each affected unit at the source and all documents that demonstrate the truth of the statements in the certificate of representation, in accordance with 40 CFR 72.24; provided that the certificate and documents shall be retained on site at the source beyond such 5-year period until such documents are superseded because of the submission of a new certificate of representation changing the designated representative; (ii) All emissions monitoring information, in accordance with 40 CFR part 75, provided that to the extent that 40 CFR part 75 provides for a 3-year period for recordkeeping, the 3- year period shall apply. (iii) Copies of all reports, compliance certifications, and other submissions and all records made or required under the Acid Rain Program; and, (iv) Copies of all documents used to complete an Acid Rain permit application and any other submission under the Acid Rain Program or to demonstrate compliance with the requirements of the Acid Rain Program. (2) The designated representative of an affected source and each affected unit at the source shall submit the reports and compliance certifications required under the Acid Rain Program, including those under 40 CFR part 72 subpart I and 40 CFR part 75. Liability. (1) Any person who knowingly violates any requirement or prohibition of the Acid Rain Program, a complete Acid Rain permit application, an Acid Rain permit, or an exemption under 40 CFR 72.7 or 72.8, including any requirement for the payment of any penalty owed to the United States, shall be subject to enforcement pursuant to section 113(c) of the Federal Clean Air Act. (2) Any person who knowingly makes a false, material statement in any record, submission, or report under the Acid Rain Program shall be subject to criminal enforcement pursuant to section 113(c) of the Federal Clean Air Act and 18 U.S.C. 1001. (3) No permit revision shall excuse any violation of the requirements of the Acid Rain Program that occurs prior to the date that the revision takes effect. (4) Each affected source and each affected unit shall meet the requirements of the Acid Rain Program. (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. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 71 (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: (I) Except as expressly provided in title IV of the Federal Clean Air Act, exempting or excluding the owners and operators and, to the extent applicable, the designated representative of an affected source or affected unit from compliance with any other provision of the Federal Clean Air Act, including the provisions of title I of the Federal Clean Air Act relating to applicable National Ambient Air Quality Standards or State Implementation Plans; (2) Limiting the number of allowances a unit can hold;provided, that the number of allowances held by the unit shall not affect the source's obligation to comply with any other provisions of the Federal Clean Air Act; (3) Requiring a change of any kind in any State law regulating electric utility rates and charges, affecting any State law regarding such State regulation, or limiting such State regulation, including any prudence review requirements under such State law; (4) Modifying the Federal Power Act or affecting the authority of the Federal Energy Regulatory Commission under the Federal Power Act; or, (5) Interfering with or impairing any program for competitive bidding for power supply in a State in which such program is established. 4. Reporting Requirements Reports shall be submitted to the addresses identified in Appendix D. Pursuant to 40 CFR Part 75.64 quarterly reports and compliance certification requirements shall be submitted to the Administrator within 30 days after the end of the calendar quarter. The contents of these reports shall meet the requirements of 40 CFR 75.64. Pursuant to 40 CFR Part 75.65 excess emissions of opacity shall be reported to the Division. These reports shall be submitted in a format approved by the Division. Revisions to this permit shall be made in accordance with 40 CFR Part 72, Subpart H, §§ 72.80 through 72.85 (as adopted by reference in Colorado Regulation 18). Permit modification requests shall be submitted to the Division at the address identified in Appendix D. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 72 5. Comments, Notes and Justifications Combustion Turbines No. 2, 3, 4, 5 and 6 burn only natural gas as fuel. The NOx limitations in 40 CFR Part 76 are only applicable to coal-fired utility units. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 73 SECTION IV- Permit Shield Regulation No. 3, 5 CCR 1001-5,Part C, I.A.4, V.D., & XIII.B and § 25-7-114.4(3)(a), C.R.S. 1. Specific Non-Applicable Requirements Based upon the information available to the Division and supplied by the applicant, the following parameters and requirements have been specifically identified as non-applicable to the facility to which this permit has been issued. This shield does not protect the source from any violations that occurred prior to or at the time of permit issuance. In addition, this shield does not protect the source from any violations that occur as a result of any modification or reconstruction on which construction commenced prior to permit issuance. Emission Unit Applicable Requirement Justification Description& Number Facility Colorado Regulation No. 7,Section V.B This requirement is not applicable since the facility is not a bulk gasoline terminal,bulk gasoline plant or gas dispensing facility. Facility Colorado Regulation No.7,Sections These requirements are not applicable as the petroleum liquids at this VI.B.1 &2 facility are stored in tanks that are less than 40,000 gallons. Facility Colorado Regulation No.7, Section VII.C This requirement is not applicable as crude oil is not stored in tanks exceeding 40,000 gallons. Cooling 40 CFR Part 63, Subpart Q(as adopted by These requirements are not applicable because the cooling towers do Towers reference in Colorado Regulation No. 8, not use chromium-based water treatment chemicals. Section E) 2. General Conditions Compliance with this Operating Permit shall be deemed compliance with all applicable requirements specifically identified in the permit and other requirements specifically identified in the permit as not applicable to the source. This permit shield shall not alter or affect the following: 2.1 The provisions of §§ 25-7-112 and 25-7-113, C.R.S., or § 303 of the federal act, concerning enforcement in cases of emergency; 2.2 The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance; 2.3 The applicable requirements of the federal Acid Rain Program, consistent with § 408(a) of the federal act; 2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to § 25-7-111(2)(1), C.R.S., or the ability of the Administrator to obtain information pursuant to § 114 of the federal act; Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 74 2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit for cause pursuant to Regulation No. 3, Part C, § XIII. 2.6 Sources are not shielded from terms and conditions that become applicable to the source subsequent to permit issuance. 3. Streamlined Conditions The following applicable requirements have been subsumed within this operating permit using the pertinent streamlining procedures approved by the U.S. EPA. For purposes of the permit shield, compliance with the listed permit conditions will also serve as a compliance demonstration for purposes of the associated subsumed requirements. Permit Condition(s) Streamlined(Subsumed)Requirements Section II,Conditions Colorado Regulation No. 6,Part B, Section II.D.3.b [SO2 emissions shall not exceed 0.35 lbs/MMBtu] 1.4.1,2.4.3 and 8.4.1. -State-only requirement Section II,Condition 40 CFR Part 60 Subpart Da § 60.44Da(a)(2), as adopted by reference in Colorado Regulation No. 6, 1.2.1.2 Part A[NOx emissions shall be reduced by 25 percent of the potential combustion concentration] Section II,Condition 40 CFR Part 60 Subpart Da § 60.44Da(a)(1), as adopted by reference in Colorado Regulation No. 6, 1.2.1.2 Part A[NOx emissions shall not exceed 0.20 lbs/MMBtu] Section II,Conditions 40 CFR Part 60 Subpart GG§ 60.332(a),as adopted by reference in Colorado Regulation No.6,Part A 1.2.1 (Turbines 2 and 3) [NOx emissions shall not exceed 105.4 ppmvd(for Turbines 2 and 3)and 112 ppmvd(for Turbine 4), and 2.5.1 (Turbine 4) each at 15%O2 and ISO standard ambient conditions] Section II,Conditions 40 CFR Part 60 Subpart GG § 60.334(h)(3), as adopted by reference in Colorado Regulation No. 6, 1.9 and 2.10 Part A[source shall monitor the sulfur content of the fuel] Section II,Conditions 40 CFR Part 60 Subpart GG§ 60.334(j)(1)(iii),as adopted by reference in Colorado Regulation No. 6, 1.10 and 2.8 Part A[NOx excess emission reporting] Section II,Condition 1.9 Colorado Construction Permit 94WE609 PSD,only the following portion of Condition 9"an automatic natural gas sampler shall be installed in the gas supply line that automatically samples each 40 MMscf, and shall be analyzed monthly" Section II,Conditions Colorado Construction Permit 99WE0762 PSD, Conditions 7.d & i and 4 [continuous emission 5.3 and 5.2 monitoring systems shall meet the requirements in 40 CFR Part 60] for the NOx and diluent continuous emission monitoring systems only. Section II,Conditions Colorado Construction Permit 94WE609 PSD, Conditions 3.i & n [Notification of demonstration of 5.3 and 5.2 continuous emission monitoring system (CEMS) and CEMS quality assurance and quality control requirements]for the NOx and diluent continuous emission monitoring systems only. Section II,Condition 40 CFR Part 60 Subpart Da § 60.44Da(d)(1), as adopted by reference in Colorado Regulation No. 6, 2.5.1.2 Part A[NOx emissions shall not exceed 1.6 lbs/MW-hr] Section II,Condition Colorado Regulation No. 1, Section VI.B.4.c.(ii) and VI.B.2 [SO2 emissions shall not exceed 0.35 8.4.1 Ibs/MMBtu on a 3-hr rolling average] Section II,Condition 40 CFR Part 60 Subpart KKKK § 60.6340(b)(1),as adopted by referenced in Colorado Regulation No. 8.10 6,Part A[use a NOx CEMS] Section II,Condition 40 CFR Part 60 Subpart KKKK §§ 60.4345(b),as adopted by reference in Colorado Regulation No. 6, 5.2.1 Part A[valid hour] Section II,Condition 40 CFR Part 60 Subpart KKKK § 60.4350(a), as adopted by reference in Colorado Regulation No. 6, 8.2.2.5 Part A[reduce CEMS data to hourly averages per 60.13(h)] Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit # 97OPWE180 Page 75 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.I. 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., 11.C., I1,.E.,ILF., 11.1,and II.J a. To Control Emissions Leaving Colorado When emissions generated from sources in Colorado cross the State boundary line, such emissions shall not cause the air quality standards of the receiving State to be exceeded,provided reciprocal action is taken by the receiving State. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 76 b. Emission Monitoring Requirements The Division may require owners or operators of stationary air pollution sources to install,maintain,and use instrumentation to monitor and record emission data as a basis for periodic reports to the Division. c. Performance Testing The owner or operator of any air pollution source shall,upon request of the Division,conduct performance test(s) and furnish the Division a written report of the results of such test(s)in order to determine compliance with applicable emission control regulations. Performance test(s)shall be conducted and the data reduced in accordance with the applicable reference test methods unless the Division: (i) specifies or approves,in specific cases,the use of a test method with minor changes in methodology; (ii) approves the use of an equivalent method; (iii) approves the use of an alternative method the results of which the Division has determined to be adequate for indicating where a specific source is in compliance;or (iv) waives the requirement for performance test(s)because the owner or operator of a source has demonstrated by other means to the Division's satisfaction that the affected facility is in compliance with the standard. Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to require testing under the Colorado Revised Statutes,Title 25,Article 7,and pursuant to regulations promulgated by the Commission. Compliance test(s)shall be conducted under such conditions as the Division shall specify to the plant operator based on representative performance of the affected facility.The owner or operator shall make available to the Division such records as may be necessary to determine the conditions of the performance test(s).Operations during period of startup,shutdown,and malfunction shall not constitute representative conditions of performance test(s)unless otherwise specified in the applicable standard. The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance test to afford the Division the opportunity to have an observer present.The Division may waive the thirty day notice requirement provided that arrangements satisfactory to the Division are made for earlier testing. The owner or operator of an affected facility shall provide,or cause to be provided,performance testing facilities as follows: (i) Sampling ports adequate for test methods applicable to such facility; (ii) Safe sampling platform(s); (iii) Safe access to sampling platform(s);and (iv) Utilities for sampling and testing equipment. Each performance test shall consist of at least three separate runs using the applicable test method.Each run shall be conducted for the time and under the conditions specified in the applicable standard.For the purpose of determining compliance with an applicable standard,the arithmetic mean of results of at least three runs shall apply.In the event that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of forced shutdown,failure of an irreplaceable portion of the sample train,extreme meteorological conditions,or other circumstances beyond the owner or operator's control,compliance may,upon the Division's approval,be determined using the arithmetic mean of the results of the two other runs. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT r Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWEI80 Page 77 Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s)if so warranted. d. Affirmative Defense Provision for Excess Emissions during Malfunctions An affirmative defense to a claim of violation under these regulations is provided to owners and operators for civil penalty actions for excess emissions during periods of malfunction.To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement,the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of evidence that: (i) The excess emissions were caused by a sudden, unavoidable breakdown of equipment,or a sudden, unavoidable failure of a process to operate in the normal or usual manner,beyond the reasonable control of the owner or operator; (ii) The excess emissions did not stem from any activity or event that could have reasonably been foreseen and avoided,or planned for,and could not have been avoided by better operation and maintenance practices; (iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being exceeded; (iv) The amount and duration of the excess emissions(including any bypass)were minimized to the maximum extent practicable during periods of such emissions; (v) All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation(if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed,contemporaneous operating logs or other relevant evidence; (viii) The excess emissions were not part of a recurring pattern indicative of inadequate design,operation,or maintenance; (ix) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions. This section is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator,and shall not constitute an additional applicable requirement; and (x) During the period of excess emissions,there were no exceedances of the relevant ambient air quality standards established in the Commissions' Regulations that could be attributed to the emitting source. The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division verbally as soon as possible, but no later than noon of the Division's next working day, and shall submit written notification following the initial occurrence of the excess emissions by the end of the source's next reporting period. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. The Affirmative Defense Provision does not apply to failures to meet federally promulgated performance standards or emission limits, including, but not limited to, new source performance standards and national emission standards for hazardous air pollutants. The affirmative defense provision does not apply to state implementation plan (sip) limits or permit limits that have been set taking into account potential emissions during malfunctions, including, but not necessarily limited to,certain limits with 30-day or longer averaging times, limits that indicate they apply during malfunctions,and limits that indicate they apply at all times or without exception. e. Circumvention Clause Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 78 A person shall not build,erect,install,or use any article,machine,equipment,condition,or any contrivance,the use of which,without resulting in a reduction in the total release of air pollutants to the atmosphere,reduces or conceals an emission which would otherwise constitute a violation of this regulation.No person shall circumvent this regulation by using more openings than is considered normal practice by the industry or activity in question. f. Compliance Certifications For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any standard in the Colorado State Implementation Plan,nothing in the Colorado State Implementation Plan shall preclude the use,including the exclusive use,of any credible evidence or information,relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed.Evidence that has the effect of making any relevant standard or permit term more stringent shall not be credible for proving a violation of the standard or permit term. When compliance or non-compliance is demonstrated by a test or procedure provided by permit or other applicable requirement,the owner or operator shall be presumed to be in compliance or non-compliance unless other relevant credible evidence overcomes that presumption. g. Affirmative Defense Provision for Excess Emissions During Startup and Shutdown An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during periods of startup and shutdown.To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement,the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of the evidence that: (i) The periods of excess emissions that occurred during startup and shutdown were short and infrequent and could not have been prevented through careful planning and design; (ii) The excess emissions were not part of a recurring pattern indicative of inadequate design,operation or maintenance; (iii) If the excess emissions were caused by a bypass(an intentional diversion of control equipment),then the bypass was unavoidable to prevent loss of life,personal injury,or severe property damage; (iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum extent practicable; (v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation(if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed,contemporaneous operating logs or other relevant evidence;and, (viii) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions. This subparagraph is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator,and shall not constitute an additional applicable requirement. The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the Division verbally as soon as possible,but no later than two(2)hours after the start of the next working day,and shall submit written quarterly notification following the initial occurrence of the excess emissions. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 79 The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements that derive from new source performance standards or national emissions standards for hazardous air pollutants, or any other federally enforceable performance standard or emission limit with an averaging time greater than twenty- four hours. In addition, an affirmative defense cannot be used by a single source or small group of sources where the excess emissions have the potential to cause an exceedance of the ambient air quality standards or Prevention of Significant Deterioration(PSD)increments. In making any determination whether a source established an affirmative defense,the Division shall consider the information within the notification required above and any other information the Division deems necessary,which may include,but is not limited to,physical inspection of the facility and review of documentation pertaining to the maintenance and operation of process and air pollution control equipment. 4. Compliance Requirements Regulation No. 3,5 CCR 1001-5,Part C, III.C.9.,V.C.11.& 16.d.and 25-7-122.1(2),C.R.S. a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to federally-enforceable terms or conditions constitutes a violation of the federal act,as well as the state act and Regulation No.3. Any permit noncompliance relating to state-only terms or conditions constitutes a violation of the state act and Regulation No.3,shall be enforceable pursuant to state law,and shall not be enforceable by citizens under§ 304 of the federal act. Any such violation of the federal act,the state act or regulations implementing either statute is grounds for enforcement action,for permit termination,revocation and reissuance or modification or for denial of a permit renewal application. b. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a permit termination,revocation or modification action or action denying a permit renewal application that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. c. The permit may be modified,revoked,reopened,and reissued,or terminated for cause. The filing of any request by the permittee for a permit modification,revocation and reissuance,or termination,or any notification of planned changes or anticipated noncompliance does not stay any permit condition,except as provided in§§X.and XI.of Regulation No.3,Part C. d. The permittee shall furnish to the Air Pollution Control Division,within a reasonable time as specified by the Division,any information that the Division may request in writing to determine whether cause exists for modifying, revoking and reissuing,or terminating the permit or to determine compliance with the permit. Upon request,the permittee shall also furnish to the Division copies of records required to be kept by the permittee,including information claimed to be confidential. Any information subject to a claim of confidentiality shall be specifically identified and submitted separately from information not subject to the claim. e. Any schedule for compliance for applicable requirements with which the source is not in compliance at the time of permit issuance shall be supplemental,and shall not sanction noncompliance with,the applicable requirements on which it is based. f. For any compliance schedule for applicable requirements with which the source is not in compliance at the time of permit issuance,the permittee shall submit,at least every 6 months unless a more frequent period is specified in the applicable requirement or by the Air Pollution Control Division,progress reports which contain the following: (i) dates for achieving the activities,milestones,or compliance required in the schedule for compliance,and dates when such activities,milestones,or compliance were achieved;and (ii) an explanation of why any dates in the schedule of compliance were not or will not be met,and any preventive or corrective measures adopted. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 80 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: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 81 c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S. §25-7-114.1(6)for each APEN or revised APEN filed. 9. Fugitive Particulate Emissions Regulation No. 1,5 CCR 1001-3, § III.D.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: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 82 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: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 83 "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 spec( 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, 1 V.C.6.,V.C.7. a. Unless otherwise provided in the source specific conditions of this Operating Permit,the permittee shall maintain compliance monitoring records that include the following information: (i) date, place as defined in the Operating Permit,and time of sampling or measurements; (ii) date(s)on which analyses were performed; (iii) the company or entity that performed the analysis; (iv) the analytical techniques or methods used; (v) the results of such analysis;and (vi) the operating conditions at the time of sampling or measurement. b. The permittee shall retain records of all required monitoring data and support information for a period of at least five (5)years from the date of the monitoring sample, measurement,report or application. Support information,for this purpose, includes all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation,and copies of all reports required by the Operating Permit. With prior approval of the Air Pollution Control Division,the permittee may maintain any of the above records in a computerized form. c. Permittees must retain records of all required monitoring data and support information for the most recent twelve (12)month period, as well as compliance certifications for the past five(5)years on-site at all times. A permittee Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 84 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, XII.A. The permittee shall provide a minimum 7-day advance notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permittee shall attach a copy of each such notice given to its Operating Permit. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 85 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.I.b. & 8 a. Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations promulgated under Title IV of the federal act,40 Code of Federal Regulations(CFR)Part 72,both provisions shall be incorporated into the permit and shall be federally enforceable. b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal act or the regulations promulgated thereunder,40 CFR Part 72,are expressly prohibited. 28. Transfer or Assignment of Ownership Regulation No.3,5 CCR 1001-5,Part C, §II.C. No transfer or assignment of ownership of the Operating Permit source will be effective unless the prospective owner or operator applies to the Air Pollution Control Division on Division-supplied Administrative Permit Amendment forms, for reissuance of the existing Operating Permit. No administrative permit shall be complete until a written agreement containing a specific date for transfer of permit, responsibility, coverage, and liability between the permittee and the prospective owner or operator has been submitted to the Division. 29. Volatile Organic Compounds Regulation No. 7,5 CCR 1001-9, §§ Ill&V. The requirements in paragraphs a, b and e apply to sources located in an ozone non-attainment area or the Denver 1-hour ozone attainment/maintenance area. The requirements in paragraphs c and d apply statewide. a. All storage tank gauging devices,anti-rotation devices,accesses,seals,hatches,roof drainage systems,support structures,and pressure relief valves shall be maintained and operated to prevent detectable vapor loss except when opened, actuated,or used for necessary and proper activities(e.g. maintenance). Such opening,actuation,or use shall be limited so as to minimize vapor loss. Detectable vapor loss shall be determined visually, by touch, by presence of odor, or using a portable hydrocarbon analyzer. When an analyzer is used, detectable vapor loss means a VOC concentration exceeding 10,000 ppm. Testing shall be conducted as in Regulation No. 7, Section VIII.C.3. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Public Service Company of Colorado Colorado Operating Permit Ft. St. Vrain Station Permit# 97OPWE180 Page 86 b. Except when otherwise provided by Regulation No.7,all volatile organic compounds,excluding petroleum liquids, transferred to any tank,container,or vehicle compartment with a capacity exceeding 212 liters(56 gallons),shall be transferred using submerged or bottom filling equipment. For top loading,the fill tube shall reach within six inches of the bottom of the tank compartment. For bottom-fill operations,the inlet shall be flush with the tank bottom. c. The permittee shall not dispose of volatile organic compounds by evaporation or spillage unless Reasonably Available Control Technology(RACT)is utilized. d. No owner or operator of a bulk gasoline terminal,bulk gasoline plant,or gasoline dispensing facility as defined in Colorado Regulation No.7,Section VI,shall permit gasoline to be intentionally spilled,discarded in sewers,stored in open containers,or disposed of in any other manner that would result in evaporation. e. Beer production and associated beer container storage and transfer operations involving volatile organic compounds with a true vapor pressure of less than 1.5 PSIA actual conditions are exempt from the provisions of paragraph b, above. 30. Wood Stoves and Wood burning Appliances Regulation No.4,5 CCR 1001-6 The permittee shall comply with the provisions of Regulation No. 4 concerning the advertisement, sale, installation, and use of wood stoves and wood burning appliances. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendices OPERATING PERMIT APPENDICES A - INSPECTION INFORMATION B - MONITORING AND PERMIT DEVIATION REPORT C - COMPLIANCE CERTIFICATION REPORT D - NOTIFICATION ADDRESSES E - PERMIT ACRONYMS F - PERMIT MODIFICATIONS G - VOC CORRELATION EQUATIONS *DISCLAIMER: None of the information found in these Appendices shall be considered to be State or Federally enforceable, except as provided for in the permit, and is presented to assist the source, permitting authority, inspectors, and citizens. Operating Permit Number: 97OPW E 180 First Issued: I/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 1 APPENDIX A-Inspection Information Directions to Plant: Traveling north on Interstate 25 exit at Highway 66 (exit 243)and head east. Turn left(north) on county road 19. Turn right (east) on County road 34 and then left (north) on county road 192. The facility address is 16805 County Road 192. Safety Equipment Required: Eye Protection Hard Hat Safety Shoes Hearing Protection Gloves Facility Plot Plan: Figure 1 (following page) shows the plot plan as submitted on August 12, 2010 to support the source's Title V Renewal Operating Permit(second renewal, issued January 1, 2011). List of Insignificant Activities: The following list of insignificant activities was provided by the source to assist in the understanding of the facility layout. Since there is no requirement to update such a list, activities may have changed since the last filing. The asterisk (*) denotes an insignificant activity source category based on the size of the activity, emissions levels from the activity or the production rate of the activity. The owner or operator of individual emission points in insignificant activity source categories marked with an asterisk (*) must maintain sufficient record keeping verifying that the exemption applies. Such records shall be made available for Division review upon request. (Colorado Regulation No. 3, Part C, Section II.E) Units with emissions less than APEN de minimis - criteria pollutants (Reg 3, Part C.II.E.3.a)* Venting of natural gas and leaks (emissions less than 1 tpy VOC) Cooling water blowdown cooling tower(emissions less than 2 tpy PM/PMIo) Units with emissions less than APEN de minimis -non-criteria pollutants (Reg 3, Part C.II.E.3.b)* Two (2) sulfuric acid storage tanks, 20,000 gal and 750 gal above ground (emissions less than 500 lbs/yr) Air conditioning or ventilation systems not designed to remove air pollutants (Reg 3, Part C.II.E.3.c) Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 2 Plant air conditioning and ventilation system Agricultural operations (Reg 3,Part C.II.E.3.g) In-house experimental and analytical laboratory equipment (Reg 3, Part C.II.E.3.i) Plant laboratory Fuel (gaseous) burning equipment< 5 MMBtu/hr (Reg 3,Part C.II.E.3.k)* Propane portable heaters Two (2) gas line heaters (4.6 MMBtu/hr, each) Chemical storage tanks or containers (Reg 3, Part C.II.E.3.n)* Small chemical tanks/containers Unpaved public and private roads - not haul roads (Reg 3,Part C.II.E.3.o) Welding, soldering, and brazing operations using no lead-based compounds (Reg 3,Part C.II.E.3.r) Maintenance welding machine Battery recharging areas (Reg 3, Part C.II.E.3.t) Battery storage area Landscaping and site housekeeping devices < 10 hp (Reg 3, Part C.II.E.3.bb)* Mowers, snowblowers, etc.. Fugitive emissions from landscaping activities (Reg 3, Part C.II.E.3.cc) Emergency events such as accidental fires (Reg 3, Part C.II.E.3.ff) Operations involving acetylene, butane,propane, or other flame cutting torches (Reg 3,Part C.II.E.3.kk) Portable welding torches Chemical storage areas < 5,000 gal capacity (Reg 3, Part C.II.E.3.mm)* Oil drum storage area Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 3 Emissions of air pollutants which are not criteria or non-criteria reportable pollutants (Reg 3, Part C.II.E.3.00) Wastewater treatment operations (no VOC emissions) Calgon 403 (4,000 gal) above ground tank Salt tank (3,500 gal) above ground tank Bleach tank (5,500 gal) above ground tank Defoam (350 gal) above ground tank Scale inhibitor(410 gal) above ground tank Corrosion inhibitor(2,000 gal) above ground tank Janitorial activities and products (Reg 3, Part C.II.E.3.pp) Office emissions including cleaning, copying, and restrooms (Reg 3, Part C.II.E.3.tt) Storage of butane,propane or LPG in tanks <60,000 gal (Reg 3 Part C.II.E.3.zz) Storage of propane gas in small portable tanks Lubricating oil storage tanks <40,000 gal (Reg 3, Part C.II.E.3.aaa) T-5401, Turbine lube oil dual compartment storage tank(8,000 gal per compartment, above ground) T-5401X, Turbine lube oil reservoir(6,000 gal above ground) 55106X, Turbine generator EHC lube oil tank(650 gal above ground) Five (5) combustion turbine lube oil tanks Storage tanks with annual throughput less than 400,000 gal and meeting content specifications (Reg 3, Part C.II.E.3.fff)* T-4503, Emergency diesel fire pump tank, 850 gal, above ground Emergency diesel generator tank(System 92EDG), 1,000 gal above ground Diesel fuel tank for refueling captive vehicles (warehouse), 560 gal above ground Forklifts (Reg 3 Part C.II.E.3.kkk) Two (3) gasoline powered forklifts Sandblast equipment where blast media is recycled and blasted material is collected (Reg 3, Part C.II.E.3.www) Sandblasting machine Surface water storage impoundment of non-potable water and storm water evaporation ponds (Reg 3, Part C.II.E.3.yyy) Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 4 Two (2)raw water ponds One (1) stormwater retention pond Seal and lubricating oil systems for steam turbine electric generators (Reg 3, Part C.II.E.3.cccc) Not Sources of Emissions Aqueous ammonia(29% mixture) storage tank(14,230 gal, above ground) and associated piping (closed system) Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 5 I - I S N Figure 1: Facility Pion Plan ` - Ft.St.Vrain Station I 1 ; , ti a - ' it a t k# , 1 I l 1_ i r � � 'I"' i ?g PJ 11 ,; E ,+' F if TA F, lri .,, i1 %. .� t Tt Z J 3..-„,----------------r'"3 Iu L. on ;3 y '- � , < ^a Iii � r`1 i l..C. _— __ ,,,r �f Y t� z i : .`.. ....I i of .' IR t �RIRT(I4 j ,i I j2 t 5,1 Ty O E ,1 # , IBI wj k L___, ,_„:„., , LT,, ,i . - ____ , }, _ i3 . L, i -" ,. \ ( ___ i i yj _ i I — i I # J �'— Tai ,.` I ! ,_. ft E # _ ti.(/5\ i L II # m fI s r w # i t ,il Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 1 APPENDIX B Reporting Requirements and Definitions with codes ver 8/20/14 Please note that, pursuant to 113(c)(2) of the federal Clean Air Act, any person who knowingly: (A) makes any false material statement,representation, or certification in, or omits material information from, or knowingly alters, conceals, or fails to file or maintain any notice, application, record, report, plan, or other document required pursuant to the Act to be either filed or maintained (whether with respect to the requirements imposed by the Administrator or by a State); (B) fails to notify or report as required under the Act; or (C) falsifies, tampers with, renders inaccurate, or fails to install any monitoring device or method required to be maintained or followed under the Act shall, upon conviction,be punished by a fine pursuant to title 18 of the United States Code, or by imprisonment for not more than 2 years, or both. If a conviction of any person under this paragraph is for a violation committed after a first conviction of such person under this paragraph, the maximum punishment shall be doubled with respect to both the fine and imprisonment. The permittee must comply with all conditions of this operating permit. Any permit noncompliance constitutes a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. The Part 70 Operating Permit program requires three types of reports to be filed for all permits. All required reports must be certified by a responsible official. Report#1: Monitoring Deviation Report (due at least every six months) For purposes of this operating permit, the Division is requiring that the monitoring reports are due every six months unless otherwise noted in the permit. All instances of deviations from permit monitoring requirements must be clearly identified in such reports. For purposes of this operating permit, monitoring means any condition determined by observation, by data from any monitoring protocol, or by any other monitoring which is required by the permit as well as the recordkeeping associated with that monitoring. This would include, for example, fuel use or process rate monitoring, fuel analyses, and operational or control device parameter monitoring. Report#2: Permit Deviation Report (must be reported "promptly") In addition to the monitoring requirements set forth in the permits as discussed above, each and every requirement of the permit is subject to deviation reporting. The reports must address deviations from permit requirements, including those attributable to malfunctions as defined in this Appendix, the probable cause of Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 2 such deviations, and any corrective actions or preventive measures taken. All deviations from any term or condition of the permit are required to be summarized or referenced in the annual compliance certification. For purposes of this operating permit, "malfunction" shall refer to both emergency conditions and malfunctions. Additional discussion on these conditions is provided later in this Appendix. For purposes of this operating permit, the Division is requiring that the permit deviation reports are due as set forth in General Condition 21. Where the underlying applicable requirement contains a definition of prompt or otherwise specifies a time frame for reporting deviations, that definition or time frame shall govern. For example, quarterly Excess Emission Reports required by an NSPS or Regulation No. 1, Section IV. In addition to the monitoring deviations discussed above, included in the meaning of deviation for the purposes of this operating permit are any of the following: (1) A situation where emissions exceed an emission limitation or standard contained in the permit; (2) A situation where process or control device parameter values demonstrate that an emission limitation or standard contained in the permit has not been met; (3) A situation in which observations or data collected demonstrates noncompliance with an emission limitation or standard or any work practice or operating condition required by the permit; or, (4) A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring (CAM)Rule)has occurred. (only if the emission point is subject to CAM) For reporting purposes, the Division has combined the Monitoring Deviation Report with the Permit Deviation Report. All deviations shall be reported using the following codes: 1 = Standard: When the requirement is an emission limit or standard 2=Process: When the requirement is a production/process limit 3=Monitor: When the requirement is monitoring 4=Test: When the requirement is testing 5=Maintenance: When required maintenance is not performed 6=Record: When the requirement is recordkeeping 7=Report: When the requirement is reporting 8=CAM: A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule)has occurred. 9=Other: When the deviation is not covered by any of the above categories Report#3: Compliance Certification (annually,as defined in the permit) Submission of compliance certifications with terms and conditions in the permit, including emission limitations, standards, or work practices, is required not less than annually. Compliance Certifications are intended to state the compliance status of each requirement of the permit over the certification period. They must be based, at a minimum, on the testing and monitoring methods specified in the Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 3 permit that were conducted during the relevant time period. In addition, if the owner or operator knows of other material information (i.e. information beyond required monitoring that has been specifically assessed in relation to how the information potentially affects compliance status), that information must be identified and addressed in the compliance certification. The compliance certification must include the following: • The identification of each term or condition of the permit that is the basis of the certification; • Whether or not the method(s) used by the owner or operator for determining the compliance status with each permit term and condition during the certification period was the method(s) specified in the permit. Such methods and other means shall include, at a minimum, the methods and means required in the permit. If necessary, the owner or operator also shall identify any other material information that must be included in the certification to comply with section 113(c)(2) of the Federal Clean Air Act, which prohibits knowingly making a false certification or omitting material information; • The status of compliance with the terms and conditions of the permit, and whether compliance was continuous or intermittent. The certification shall identify each deviation and take it into account in the compliance certification. Note that not all deviations are considered violations.' • Such other facts as the Division may require, consistent with the applicable requirements to which the source is subject, to determine the compliance status of the source. The Certification shall also identify as possible exceptions to compliance any periods during which compliance is required and in which an excursion or exceedance as defined under 40 CFR Part 64 (the Compliance Assurance Monitoring(CAM)Rule)has occurred. (only for emission points subject to CAM) Note the requirement that the certification shall identify each deviation and take it into account in the compliance certification. Previously submitted deviation reports, including the deviation report submitted at the time of the annual certification, may be referenced in the compliance certification. Startup, Shutdown, Malfunctions and Emergencies Understanding the application of Startup, Shutdown, Malfunctions and Emergency Provisions, is very important in both the deviation reports and the annual compliance certifications. Startup, Shutdown, and Malfunctions Please note that exceedances of some New Source Performance Standards (NSPS) and Maximum Achievable Control Technology (MACT) standards that occur during Startup, Shutdown or Malfunctions may not be considered to be non-compliance since emission limits or standards often do not apply unless specifically stated in the NSPS. Such exceedances must, however, be reported as excess emissions per the NSPS/MACT rules and would still be noted in the deviation report. In regard to compliance certifications, the permittee should be ' For example, given the various emissions limitations and monitoring requirements to which a source may be subject, a deviation from one requirement may not be a deviation under another requirement which recognizes an exception and/or special circumstances relating to that same event. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 4 confident of the information related to those deviations when making compliance determinations since they are subject to Division review. The concepts of Startup, Shutdown and Malfunctions also exist for Best Available Control Technology(BACT) sources, but are not applied in the same fashion as for NSPS and MACT sources. Emergency Provisions Under the Emergency provisions of Part 70 certain operational conditions may act as an affirmative defense against enforcement action if they are properly reported. DEFINITIONS Malfunction (NSPS) means any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions. Malfunction (SIP) means any sudden and unavoidable failure of air pollution control equipment or process equipment or unintended failure of a process to operate in a normal or usual manner. Failures that are primarily caused by poor maintenance, careless operation, or any other preventable upset condition or preventable equipment breakdown shall not be considered malfunctions. Emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology-based emission limitation under the permit, due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 5 Monitoring and Permit Deviation Report - Part I 1. Followingisthe required format for the Monitoring and Permit Deviation report to be submitted to the Division as set forth in General Condition 21. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. 2. Part II of this Appendix B shows the format and information the Division will require for describing periods of monitoring and permit deviations, or malfunction or emergency conditions as indicated in the Table below. One Part II Form must be completed for each Deviation. Previously submitted reports (e.g. EER's or malfunctions) may be referenced and the form need not be filled out in its entirety. FACILITY NAME: Public Service Company of Colorado—Ft. St. Vrain Station OPERATING PERMIT NO: 97OPWE180 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) Deviations noted Deviation Malfunction/Emergency During Period?' Code2 Condition Reported Operating During Period? Permit Unit ID Unit Description YES NO YES NO T002 General Electric Combustion Turbine,Model No.GE Frame 7FA, Serial No.296677,rated at 1773 MMBtu/hr(turbine 1,223 MMBtu/hr and duct burner 450 MMBtu/hr),Natural Gas Fired. Turbine May be Operated in Conjunction with a HRSG(combined cycle operation)Equipped with Natural Gas Fired Duct Burners. T003 General Electric Combustion Turbine,Model No.GE Frame 7FA,Serial No.297096,rated at 1823 MMBtu/hr(turbine 1,373 MMBtu/hr and duct burner 450 MMBtu/hr),Natural Gas Fired. Turbine May be Operated in Conjunction with a HRSG(combined cycle operation)Equipped with Natural Gas Fired Duct Burners. T004 General Electric Combustion Turbine,Model PG7241 (FA), Serial No.297457,rated at 1953 MMBtu/hr(turbine 1,531 MMBtu/hr and duct burner 422 MMBtu/hr),Natural Gas Fired. Turbine May be Operated in Conjunction with a HRSG(combined cycle operation)Equipped with One(I)Vogt-NEM Natural Gas Fired Duct Burner. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 6 Deviations noted Deviation Malfunction/Emergency During Period?' Code2 Condition Reported Operating During Period? Permit Unit ID Unit Description YES NO YES NO B001 Babcock and Wilcox,Model FM-1656,External Combustion Auxiliary Boiler,Serial No. NB22845,Rated at 70.23 MMBtu/hr. Natural Gas Fired. M001 One(1)Marley Cooling Water Tower,Model no.Cross-Flow DF-664,Design Rate of 156,000 gpm and One(1)Marley Service Water Tower, Model NO.6-48-3-02,Design Rate of 14,000 gpm. M002 Gasoline Storage Tank,500 gallons aboveground M003 Cold Cleaner Solvent Vats T005 General Electric Combustion Turbine,Model No.7FA,Serial Number 298106,rate at 1,467 MMBtu/hr,Natural Gas Fired. 1006 General Electric Combustion Turbine,Model No.7FA,Serial Number 298107,rate at 1,467 MMBtu/hr,Natural Gas Fired. M004 Two(2)Caterpillar,Model No. SP321P00, Serial Nos. 126906 and 126907,diesel-fired engines,each rated at 1,800 hp,with a combined fuel rate of 200 gal/hr. The engines are run together to drive an emergency generator. One(1)Cummins,Model No. 6BTA5.963, Serial No.46927201,rated at 255 hp with fuel rate of 3 gal/hr. The engine runs an emergency fire pump. General Conditions Insignificant Activities See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation has occurred shall be based on a reasonable inquiry using readily available information. 2Use the following entries as appropriate: 1=Standard: When the requirement is an emission limit or standard 2=Process: When the requirement is a production/process limit 3=Monitor: When the requirement is monitoring 4=Test: When the requirement is testing 5=Maintenance: When required maintenance is not performed 6=Record: When the requirement is recordkeeping 7=Report: When the requirement is reporting 8=CAM: A situation in which an excursion or exceedance as defined in 40 CFR Part 64(the Compliance Assurance Monitoring(CAM)Rule)has occurred. 9=Other: When the deviation is not covered by any of the above categories Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 7 Monitoring and Permit Deviation Report-Part II FACILITY NAME: Public Service Company of Colorado—Ft. St. Vrain Station OPERATING PERMIT NO: 97OPWE180 REPORTING PERIOD: Is the deviation being claimed as an: Emergency Malfunction N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Operating Permit Condition Number Citation Explanation of Period of Deviation Duration (start/stop date &time) Action Taken to Correct the Problem Measures Taken to Prevent a Reoccurrence of the Problem Dates of Malfunctions/Emergencies Reported (if applicable) Deviation Code Division Code QA: SEE EXAMPLE ON THE NEXT PAGE Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 8 EXAMPLE FACILITY NAME: Acme Corp. OPERATING PERMIT NO: 96OPZZXXX REPORTING PERIOD: 1/1/04 - 6/30/06 Is the deviation being claimed as an: Emergency Malfunction XX N/A (For NSPS/MACT)Did the deviation occur during: Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Asphalt Plant with a Scrubber for Particulate Control - Unit XXX Operating Permit Condition Number Citation Section II, Condition 3.1 - Opacity Limitation Explanation of Period of Deviation Slurry Line Feed Plugged Duration START- 1730 4/10/06 END- 1800 4/10/06 Action Taken to Correct the Problem Line Blown Out Measures Taken to Prevent Reoccurrence of the Problem Replaced Line Filter Dates of Malfunction/Emergencies Reported(if applicable) 5/30/06 to A. Einstein, APCD Deviation Code Division Code QA: Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 9 Monitoring and Permit Deviation Report- Part III REPORT CERTIFICATION SOURCE NAME: Public Service Company of Colorado—Ft. St. Vrain Station FACILITY IDENTIFICATION NUMBER: 1230023 PERMIT NUMBER: 97OPWE180 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) All information for the Title V Semi-Annual Deviation Reports must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B. This signed certification document must be packaged with the documents being submitted. STATEMENT OF COMPLETENESS I have reviewed the information being submitted in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this submittal are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in Sub-Section 18- 1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of Sub-Section 25-7 122.1, C.R.S. Printed or Typed Name Title Signature of Responsible Official Date Signed Note: Deviation reports shall be submitted to the Division at the address given in Appendix D of this permit. No copies need be sent to the U.S. EPA. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 1 APPENDIX C Required Format for Annual Compliance Certification Reports ver 8/20/14 Following is the format for the Compliance Certification report to be submitted to the Division and the U.S. EPA annually based on the effective date of the permit. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. FACILITY NAME: Public Service Company of Colorado—Ft. St. Vrain Station OPERATING PERMIT NO: 97OPWE180 REPORTING PERIOD: I. Facility Status During the entire reporting period, this source was in compliance with ALL terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference. The method(s) used to determine compliance is/are the method(s) specified in the Permit. With the possible exception of the deviations identified in the table below, this source was in compliance with all terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference, during the entire reporting period. The method used to determine compliance for each term and condition is the method specified in the Permit, unless otherwise indicated and described in the deviation report(s). Note that not all deviations are considered violations. Operating Unit Description Deviations Monitoring Was Compliance Continuous Permit Reported I Method per or Intermittent?3 Unit ID Permit?2 Previous Current YES NO Continuous Intermittent T002 General Electric Combustion Turbine,Model No.GE Frame 7FA, Serial No.296677,rated at 1773 MMBtu/hr(turbine 1,223 MMBtu/hr and duct burner 450 MMBtu/hr), Natural Gas Fired. Turbine May be Operated in Conjunction with a HRSG(combined cycle operation) Equipped with Natural Gas Fired Duct Burners. a Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 2 Operating Unit Description Deviations Monitoring Was Compliance Continuous Permit Reported ' Method per or Intermittent?' Unit ID Permit?2 Previous Current YES NO Continuous Intermittent T003 General Electric Combustion Turbine, Model No.GE Frame 7FA, Serial No.297096,rated at 1823 MMBtu/hr(turbine 1,373 MMBtu/hr and duct burner 450 MMBtu/hr), Natural Gas Fired. Turbine May be Operated in Conjunction with a HRSG(combined cycle operation) Equipped with Natural Gas Fired Duct Burners. T004 General Electric Combustion Turbine,Model PG7241 (FA), Serial No.297457,rated at 1953 MMBtu/hr (turbine 1,531 MMBtu/hr and duct burner 422 MMBtu/hr),Natural Gas Fired. Turbine May be Operated in Conjunction with a HRSG (combined cycle operation)Equipped with One(1)Vogt-NEM Natural Gas Fired Duct Burner. B001 Babcock and Wilcox,Model FM- 1656,External Combustion Auxiliary Boiler,Serial No. NB22845,Rated at 70.23 MMBtu/hr. Natural Gas Fired. M001 One(1)Marley Cooling Water Tower,Model no.Cross-Flow DF- 664,Design Rate of 156,000 gpm and One(1)Marley Service Water Tower,Model NO.6-48-3-02, Design Rate of 14,000 gpm. M002 Gasoline Storage Tank,500 gallons aboveground M003 Cold Cleaner Solvent Vats T005 General Electric Combustion Turbine,Model No.7FA, Serial Number 298106,rate at 1,467 MMBtu/hr,Natural Gas Fired. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 3 Operating Unit Description Deviations Monitoring Was Compliance Continuous Permit Reported ' Method per or Intermittent?3 Unit ID Permit?2 Previous Current YES NO Continuous Intermittent T006 General Electric Combustion Turbine,Model No.7FA, Serial Number 298107,rate at 1,467 MMBtu/hr,Natural Gas Fired. M004 Two(2)Caterpillar,Model No. SP321P00, Serial Nos. 126906 and 126907,diesel-fired engines,each rated at 1,800 hp,with a combined fuel rate of 200 gal/hr. The engines are run together to drive an emergency generator. One(1)Cummins,Model No. 6BTA5.963,Serial No.46927201, rated at 255 hp with fuel rate of 3 gal/hr. The engine runs an emergency fire pump. General Conditions Insignificant Activities 4 ' If deviations were noted in a previous deviation report , put an "X" under "previous". If deviations were noted in the current deviation report(i.e. for the last six months of the annual reporting period),put an"X" under"current". Mark both columns if both apply. 2 Note whether the method(s)used to determine the compliance status with each term and condition was the method(s)specified in the permit. If it was not,mark "no"and attach additional information/explanation. 3 Note whether the compliance status with of each term and condition provided was continuous or intermittent. "Intermittent Compliance" can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance has occurred. NOTE: The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the absence of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance for the duration of the reporting period. Therefore, if a source 1) conducts all of the monitoring and recordkeeping required in its permit, even if such activities are done periodically and not continuously, and if 2) such monitoring and recordkeeping does not indicate non-compliance, and if 3)the Responsible Official is not aware of any credible evidence that indicates non-compliance,then the Responsible Official can certify that the emission point(s) in question were in continuous compliance during the applicable time period. 4 Compliance status for these sources shall be based on a reasonable inquiry using readily available information. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 4 II. Status for Accidental Release Prevention Program: A. This facility is subject is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act) B. If subject: The facility is is not in compliance with all the requirements of section 112(r). 1. A Risk Management Plan will be has been submitted to the appropriate authority and/or the designated central location by the required date. III. Certification All information for the Annual Compliance Certification must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B. This signed certification document must be packaged with the documents being submitted. I have reviewed this certification in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this certification are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of§ 25-7 122.1, C.R.S. Printed or Typed Name Title Signature Date Signed NOTE: All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix D Notification Addresses Page 1 APPENDIX D Notification Addresses 1. Air Pollution Control Division Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit APCD-SS-B1 4300 Cherry Creek Drive S. Denver, CO 80246-1530 ATTN: Matt Burgett 2. United States Environmental Protection Agency Compliance Notifications: Office of Enforcement, Compliance and Environmental Justice Mail Code 8ENF-AT U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 502(b)(10) Changes, Off Permit Changes: Office of Partnerships and Regulatory Assistance Air and Radiation Programs, 8P-AR U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: 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 PM10 - Particulate Matter Under 10 Microns Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix E Permit Acronyms Page 2 PPM Parts Per Million PPMV Parts Per Million, by Volume PPMVD Parts Per Million, by Volume,Dry PSD - Prevention of Significant Deterioration PTE - Potential To Emit RACT- Reasonably Available Control Technology SCC - Source Classification Code SCF - Standard Cubic Feet SIC - Standard Industrial Classification SO2 - Sulfur Dioxide TPY- Tons Per Year TSP - Total Suspended Particulate VOC - Volatile Organic Compounds Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix F Permit Modifications Page 1 APPENDIX F Permit Modifications DATE OF TYPE OF SECTION DESCRIPTION OF REVISION REVISION REVISION NUMBER, CONDITION NUMBER Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H VOC Correlation Equations Page 1 APPENDIX G VOC Correlation Equations Turbine 2 Revision 1-May 2000 For all Turbine 2 Equations: y=VOC (lb/hr or ppm) x=Heat Input(MMBtu,CT: simple cycle,Duct Burners: combined cycle) Simple Cycle,ppm MMF Model: y=(a*b+c*x^d)/(b+x^d) Coefficient Data: a= -10.70408 b= 29.46769 c= 1.859911 d= 0.808016 Simple Cycle, lbs/hr MMF Model: y=(a*b+c*x^d)/(b+x^d) Coefficient Data: a= -17013.15 b= 934.6225 c= 7.491049 d= 2.20199 Turbine 3 Revision 1 —May 2000 For all Turbine 3 equations: y= VOC(lb/hr or ppm) x=Heat Input(MMBtu, CT: simple cycle,Duct Burners: combined cycle) Simple Cycle,ppm Richards Model: y=a/(1+exp(b-cx)^(1/d)) Coefficient Data: a= 0.51302 b= 0.555636 c= -0.004311 d= 29.75011 Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H VOC Correlation Equations Page 2 Simple Cycle, lbs/hr MMF Model:y=(a*b+c*x^d)/(b+x^d) Coefficient Data: a= -849.1986 b= 228.2923 c= 3.014795 d= 1.807953 Turbine 4 For all Turbine 4 equations y=VOC (lb/hr or ppm) x=Heat Input(MMBtu, CT: simple cycle,Duct Burners: combined cycle) Simple Cycle, lbs/hr y=ax^2-bx+c Coefficient Data: a= 8 x 10-6 b= 0.0156 c= 9.5178 Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H VOC Correlation Equations Page 3 All Turbines—Combined Cycle Operation For all turbines,all equations y=VOC ppm @ 15%O2 x=Duct Burner Heat Input(MMBtu/hr) Unit 2 y= 1.88E-08x3- 1.83E-05x2+3.90E-03x+2.30E-01 Unit 3 y=-5.18E-06x2+ 1.86E-03x+ 1.72E-01 Unit 4 y=-6.55E-07x2-2.30E-04x+2.16E-01 VOC lb/hr Calculation: VOC=VOC ppm a 15%O, * CF * Fd * 20.9 * Total Unit Heat Input (20.9— 15) Where: VOC=lb/hr emission rate for VOC VOC ppm @ 15%O2=dry concentration(ppmvd)of VOC at 15%O2,as determined by the VOC correlation equations. CF =is the VOC as propane correction= 1.44 lb/scf Fd=8710 for natural gas Total Heat Input =total combustion turbine and duct burner heat input as reported in the DAHS. Operating Permit Number: 97OPWE180 First Issued: 1/1/2000 Renewed: DRAFT TECHNICAL REVIEW DOCUMENT For RENEWAL / MODIFCATION TO OPERATING PERMIT 97OPWE180 Public Service Company of Colorado — Ft. St. Vrain Station Weld County Source ID 1230023 Prepared by Jacqueline Joyce April and May 2015 Revised June and September 2015 Reviewed by: Operating Permit Supervisor: Matt Burgett Field Services Unit: Jeremy Neustifter I. Purpose: The current Operating Permit was issued January 1, 2011. The expiration date for the permit is January 1, 2016. The renewal application was submitted on pp December 17, 2014. In addition, the source submitted an application on December 17, 2014 to revise the opacity monitoring requirements in the permit for the emergency diesel fuel-fired engines. This document is designed for reference during the review of the proposed permit by the EPA, the public, and other interested parties. The conclusions made in this report are based on information provided in the renewal application submitted December 17, 2014, the modification application submitted on December 17, 2014, comments on the draft permit and technical review document received on September 3, 2015, previous inspection reports and various e-mail correspondence, as well as telephone conversations with the applicant. Please note that copies of the Technical Review Document for the original permit and any Technical Review Documents associated with subsequent modifications of the original Operating Permit may be found in the Division files as well as on the Division website at www.colorado.gov/cdphe/airTitleV. This narrative is intended only as an adjunct for the reviewer and has no legal standing. Any revisions made to the underlying construction permits associated with this facility made in conjunction with the processing of this operating permit application have been reviewed in accordance with the requirements of Regulation No. 3, Part B, Construction Permits, and have been found to meet all applicable substantive and procedural requirements. This operating permit incorporates and shall be considered to be a combined construction/operating permit for any such revision, and the permittee shall be allowed to operate under Page 1 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 classified as an electric services facility under Standard Industrial Classification 4911. This facility consists of five (5) natural gas fired combustion turbines and three (3) heat recovery steam generators (HRSG). The capacity of the steam turbine is 330 megawatts (MW). The output rating of the entire plant varies based on ambient temperature with more generation in the winter and less generation in the summer. The facility generates approximately 965 MW (summer rating) of electricity. The turbines are numbered as follows: T001 (turbine No.1) is the steam turbine, 1002 (turbine No. 2) is the No. 1 combustion turbine, 1003 (turbine No. 3) is the No. 2 combustion turbine, 1004 (turbine No. 4) is the No. 3 combustion turbine, T005 (turbine No. 5) is the No. 4 combustion turbine and T006 (turbine No. 6) is the No. 5 combustion turbine. Combustion turbines 2 and 3 each generate approximately 135 MW of electricity and each HSRG, which includes duct burners for supplemental firing, will add approximately 100 MW of electrical capacity. Combustion turbine 4, which commenced operation in April 2001, generates approximately 135 MW of electricity and the HRSG, which includes a duct burner for supplemental firing, will add approximately 100 MW of electrical capacity. These combustion turbines and HRSG combinations can be run in three modes: simple cycle (combustion turbine only), combined cycle (combustion turbine with HRSG) with no fuel fired in the duct burners and combined cycle (combustion turbine with HRSG) with fuel fired in the duct burners. In simple cycle operation, exhaust from the combustion turbine is discharged through the bypass stack. In combined cycle mode, the exhaust gas from the turbine passes through the HRSG first and then exits out the HRSG stack. Combustion turbines No. 5 and 6, which commenced operation in April 2009, each generate approximately 146 MW. Turbines 5 and 6 can only operate in simple system mode. In addition to the combustion turbines, significant emission units at this facility consist of an auxiliary boiler fueled by natural gas, • one cooling water tower, one service water tower, a 500 gallon gasoline tank, cold cleaner solvent vats, two (2) diesel-fired engines driving an emergency generator and one (1) diesel-fired engine driving an emergency fire pump. Based on the information available to the Division and provided by the applicant, it appears that no modifications to the significant emission units have occurred since the original issuance of the operating permit. The facility is located approximately three miles north and west of Platteville, Colorado. This facility is located in an area classified as attainment for all pollutants except ozone. It is classified as non-attainment for ozone and is part of the 8-hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1 . Page 2 There are no affected states within 50 miles of the plant. Rocky Mountain National Park, Eagle's Nest National Wilderness Area and Rawah National Wilderness Area, Federal Class I designated areas, are within 100 kilometers of the plant. The summary of emissions that was presented in the Technical Review Document (TRD) for the second renewal of thispermit (issued January 1, 2011) is shown here as the potential to emit has not changed. Emissions (in tons/yr) at 9 Y ) the facility are as follows: Potential to Emit(PTE) Emission Unit PM PM10 SO2 NOX CO VOC HAPS Turbine(T002) 39.4 39.4 4.7 496.1 465.4 21.4 See Turbine (T003) 39.4 39.4 4.7 496.1 465.4 21.4 Table on Turbine (T004) 54 54 4.7 199.1 237.9 33.1 Page 18 Turbine (T005)* 4.45 4.45 1.85 . 19.95 10 1.15 Turbine (T006)* 4.45 4.45 1.85 19.95 10 1.15 Auxiliary Boiler 0.6 0.6 0.2 32.6 27.4 1.8 (B001) Cooling/Service 14.9 14.9 2.4 Water Towers (M001) Total 157.2 157.2 18 1,263.8 1,216.1 82.4 18.82 *permitted emission limits are for both turbines together, emissions are assumed to be split between the 2 units. Potential to emit for criteria pollutants is based on permitted emission limits. The breakdown of HAP emissions for each emission unit is provided for in the table on page 18 of this document. HAPs were estimated as follows: Turbines 2 and 3: Formaldehyde emissions from the turbines and duct burners are based on emission factors determined from performance tests conducted on these units (performance test results were multiplied by 1.7), the design heat input rate (turbine plus duct burner) and 8760 hours per year of operation. The test results were conducted while the units were in combined cycle mode with the duct burners on. Emissions of other pollutants from the turbines are based on AP-42 emission factors (Section 3.1 (dated 4/00), Table 3.1-4), except that the acetaldehyde emission factor is from the ICCR and the manganese and nickel emission factors are from FIRE, the design heat input rate of the turbine and 8760 hours per year of operation. Emissions of other pollutants from the duct burners are based on AP-42 emission factors (Section 1.4 (dated 3/98), Tables 1.4-3 and 1.4-4), except that the formaldehyde emission factor is from EPRI handbook (4/02) and the hexane emission factor is from an EPRI paper (5/00), the design heat input rate and 8760 hours per year of operation. Page 3 Turbine 4: Formaldehyde emissions from the turbine and duct burner are based on the Turbine 2 performance test (test results were multiplied by 1.7) and the permitted heat input rates for the turbine and duct burner. Emissions of other pollutants from the turbine are based on AP-42 emission factors (Section 3.1 (dated 4/00), Table 3.1-4), except that the acetaldehyde emission factor is from the ICCR and the manganese and nickel emission factors are from FIRE and the permitted heat input rate for the turbine. Emissions of other pollutants from the duct burner are based on AP-42 emission factors (Section 1.4 (dated 3/98), Tables 1.4-3 and 1.4-4), except that the formaldehyde emission factor is from EPRI handbook (4/02) and the hexane emission factor is from an EPRI paper (5/00), and the permitted heat input rate for the duct burner. Turbines 5 and 6: HAP emissions are based on AP-42 emission factors (Section 3.1 (dated 4/00), Table 3.1-4), except that the acetaldehyde emission factor is from the ICCR and the manganese and nickel emission factors are from FIRE, the permitted fuel consumption rate and an assumed natural gas heat content of 1020 Btu/scf. Auxiliary Boiler: HAP emissions are based on AP-42 emission factors (Section 1.4 (dated 3/98), Tables 1.4-3 and 1.4-4), except that the formaldehyde emission factor is from EPRI handbook (4/02) and the hexane emission factor is from an EPRI paper (5/00), the permitted fuel consumption rate and an assumed natural gas heat content of 1020 Btu/scf. Cooling and Service Water Towers: HAP emissions are based on a chloroform emission factor of 0.05 Ib/MMgal (from letter from Wayne C. Micheletti to Ed Lasnic, dated November 11, 1992) and the permitted water circulation rate Note that actual emissions are typically less than potential emissions and actual emissions are shown on page 19 of this document. National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source Categories As indicated in the above table summarizing potential to emit, the facility is not a major source for HAPS. The applicability of various NESHAPs (also referred to as "MACT requirements") that apply to area sources was discussed in the 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 August 12, 2008 revised Title V permit, these requirements do not apply for the following reasons. The Page 4 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. Gasoline Dispensing Facilities (40 CFR Part 63 Subpart CCCCCC) These requirements apply to each gasoline dispensing facility (any stationary facility which dispenses gasoline into the fuel tank of a motor vehicle) located at an area source of HAPs. The requirements in 40 CFR Part 63 Subpart CCCCCC apply to any gasoline dispensing facility (GDF) located at this facility the relevant requirements are included in the current Title V permit (last revised September 9, 2011) to address an existing GDF. The existing tank/GDF was believed to be 500 gallons but after further investigation by the source, it was determined that the tank was 560 gallons, thus the source opted to replace the tank with a new 500 gallon tank. The requirements in Subpart CCCCCC still apply to the new tank, thus the Subpart CCCCCC requirements remain in the permit. The only revision to these requirements to address the new tank is the compliance date (tank must comply upon startup). Reciprocating Internal Combustion Engines (RICE) (40 CFR Part 63 Subpart ZZZZ) 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. Three diesel fuel-fired emergency engines (two driving an emergency generator and one driving a fire pump) are subject to requirements in the RICE MACT and are included in Section II of the current Title V permit (last revised September 9, 2011). 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 this engine will be included in the renewal permit. Industrial, Commercial and Institutional Boilers at Area Sources (40 CFR Part 63 Subpart JJJJJJ) Gas fired boilers are not subject to the requirements in 40 CFR Part 63 Subpart JJJJJJ in accordance with § 63.11195(e). In addition, unlike the NESHAP for major sources (40 CFR Part 63 Subpart DDDDD), these requirements only apply to boilers, not process heaters. The only boiler at this facility is natural gas-fired, therefore, the requirements in 40 CFR Part 63 Subpart JJJJJJ do not apply. Page 5 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 are being addressed here. NSPS Subpart JJJJ — Stationary Spark Ignition Engines NSPS Subpart JJ'JJ 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 1111 applies to stationary compression ignition engines that commenced construction, reconstruction or modification after July 11, 2005 and were manufactured after specified dates. The date the engine commenced construction is the date the engine was ordered by the owner/operator. The only compression ignition engines that are located at this facility are the two engines driving the emergency generator and the emergency fire pump engine, all of which commenced operation prior to July 11, 2005 and therefore, the requirements in Subpart 1111 do not apply. 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. Page 6 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. 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 are two diesel fuel-fired engines driving an emergency generator and one diesel fuel-fired engine driving an emergency fire pump included in Section II of the permit that are APEN exempt. The source submitted information indicating that actual, uncontrolled emissions from these engines were below the APEN de minimis level. Compliance Assurance Monitoring (CAM) requirements CAM applies to any emission unit that is subject to an emission limitation, uses a control device to achieve compliance with that emission limitation and has potential pre-control emissions greater than major source levels. The current Title V permit includes CAM requirements for Turbine 4. As indicated in the technical review document to support the first renewal of the Title V permit (issued July 1, 2005), Turbines 2 and 3 were not subject to CAM because they are not equipped with a control device (dry low NOx combustion systems are considered inherent process equipment). As indicated in the technical review document to support the second renewal of the Title V permit (issued January 1, 2011), Turbines 5 and 6 are also equipped with dry low NOx combustion systems and as such they are not equipped with control devices and CAM does not apply to those turbines. Page 7 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 September 9, 2011) and unless specifically noted as "new", the condition numbers identified in this document reflect the condition numbers in the current permit (last revised September 9, 2011). 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 17, 2014 Renewal Application Based on the source's requested changes included in their renewal application, the following changes were made to the permit: Page Following Cover Page • The Responsible Official and Permit Contact were revised. Section 11.1, 2, and 8 — Turbines 2, 3, 4, 5 and 6 • The statements regarding reprogramming of the data acquisition and handling system (DAHS) in Conditions 1.2.1.10, 1.3.1.10, 2.5.1.10, 2.6.1.10 and 8.2.1 be removed since the changes to the DAHS have been made. Section 11.1 —Turbines 2 and 3 • Conditions 1.6.4.1 and 1.12 were revised to reflect the results of the 2014 performance test for PM emissions. Section 11.2 —Turbine 4 • Condition 2.5.1.7 (definition of combustion tuning and testing) was revised to include testing and tuning of the SCR unit. Section 11.5 — CEMS Requirements Page 8 • Condition 5.3.3.1 (CO QA/QC plan requirements) was revised to stipulate that cylinder gas audit testing is not required during quarters with less than 168 hours of operating time. December 17, 2014 Modification Application The purpose of this modification is to revise the opacity monitoring requirements for the emergency generator and fire pump engines to be more consistent with the monitoring requirements for emergency diesel fuel-fired engines in other Public Service Company of Colorado (PSCo) Title V permits. Modification Type The source indicated that this modification would qualify as a minor modification. Colorado Regulation No. 3, Part C, Section X.A identifies those modifications that can be processed under the minor permit modification procedures. Specifically, minor permit modifications "do not involve significant changes to existing monitoring, reporting, or record keeping requirements in a permit" (Colorado Regulation No. 3, Part C, Section X.A.2). The monitoring in the current permit (last revised September 9, 2011) specifies that no opacity reading for the 30% opacity standard is required for an engine startup less than 60 minutes and requires opacity readings every 4 hours during startup, if it extends beyond 60 minutes. The permit also requires monthly opacity readings for the 20% opacity standard for continued operation of the engine beyond the startup period, except that if the period of operation lasts less than 4 hours no opacity observation is required. However, at least one annual opacity observation for the 20% opacity standard is required. The requested opacity monitoring language specifies one 20% opacity observation in any calendar year and stipulates no startup opacity observation (for the 30% opacity standard) since startup is limited to 30 minutes. While it may seem that the requested opacity language may be a significant change in the existing monitoring, since more opacity observations may be required under the current language, it is not actually a significant change. The operation of emergency engines is typically for short durations for readiness testing and continued operation for more than 4 hours is unlikely. Therefore, the requested language is consistent with the language in the current permit and is more straightforward. In addition, the requested language includes provisions for a second opacity observation in the event that an engine runs more than 250 hours in any calendar year period. Therefore, the Division agrees that the requested modification qualifies as a minor modification. Revisions to Permit Page 9 The following changes were made to the permit to reflect the December 17, 2014 modification: Section 11.9 — Diesel Fuel-Fired Engine • The opacity monitoring requirements in Conditions 9.3.3 through 9.3.5 were revised to reflect PSCo' suggested language. September 3, 2015 Comments on the Draft Permit and Technical Review Document The following changes were made to the permit based on the comments on the draft permit and technical review document submitted by the source on September 3, 2015: Sections 11.1, 2 and 8 —Turbines 2, 3, 4, 5 and 6 • The definition of startup in Condition 1.2.1 .5 was revised to 30 minutes after achieving Mode 6 operation. The source was interested in extending the time period after the "trigger condition" in the permit in order to address situations where startup begins late in the clock hour (this just leaves a few minutes of non-startup time to generate the 1-hr average to compare with the NOx limits) and have not stabilized. The change to allow 30 minutes after the trigger event is consistent with the startup definition for PSCo's Rocky Mountain Energy Center turbines and consistent with the requested change to the startup definition to PSCo's Blue Spruce Energy Center turbines. Thus this change will be consistent with the startup definitions for other PSCo combustion turbines. Section 11.5 — Continuous Emissions Monitoring Systems (CEMS) • Removed "or opacity" from Condition 5.3.2. NSPS KKKK Requirements for Turbines 5 and 6 During some email discussions and a meeting regarding the draft permit, the source indicated that the permit did not seem to appropriately address startup and shutdown periods for the NSPS KKKK limitations. The source specifically noted in an email that the language in 60.4380(b)(3), which addresses operating periods during which multiple standards may apply, was an item for discussion (the requirements in 60.4380(b)(3) were not included in the permit). As a result of these discussions, it was apparent that the permit had not included alternate limits provided in NSPS KKKK for the turbines during certain operating periods (lower loads and temperatures). In their comments, the source requested that these issues be addressed. The following changes were made to the permit to address the source's concerns: Page 10 Section 11.5 — Continuous Emissions Monitoring Systems (CEMS) • The language in 60.4380(b)(3) was included as "new" Condition 5.6.3.3. Section 11.8 — Turbines 5 and 6 • Condition 8.2.2 was reformatted and revised to include the alternate NOx emissions limitations in NSPS KKKK. In addition, the language in 60.4380(b)(3) was also included in Condition 8.2.2. Although not specifically noted in the source's comments regarding NSPS KKKK or discussed in the meeting regarding NSPS KKKK issues, the Division reviewed the NSPS KKKK requirements and made the following changes to the permit. • The provisions in 60.4350(b) were included in Condition 8.2.2. The technical review document for the second renewal (issued January 1, 2011) indicated that this requirement was not included since the source would rely on a Part 75 GEMS. It seems now that this requirement probably should have been included in the permit. • The technical review document for the second renewal (issued January 1, 2011) listed several requirements that would not be included since the source is required to use a Part 75 CEMS (per Acid Rain and Construction Permit 07WE1100). These requirements will be included in the permit shield for streamlined conditions (Section IV.3). The requirements that will be included in the streamlined conditions table include the following: 60.4340(b)(1) (use a NOx CEMS), 60.4345(b) (valid hour) and 60.4350(a) (calculate hourly averages per 60.13(h)). Note that the requirements in 60.435(a) (performance spec) and (e) (QA/QC requirements) and 60.4350(d) (not relying on replaced data) are not included in the permit shield for streamlined conditions because these sections specifically say that Part 75 CEMS requirements may be utilized and thus do not need to be streamlined. Note that some language from 60.435(a) and 60.4350(d) are included in the permit in Condition 5.6. Appendix A— Inspection Information • Gloves were added to the list of safety equipment. • The following changes were made to the insignificant activity list: o The following categories and/or equipment were added: - Section II.E.3.zz (small portable propane tanks) - Section II.E.3.kkk (two gasoline fueled forklifts) - Section II.E.3.cccc (steam turbine seal and lubricating oil system) Page 11 - Section II.E.3.yyy (two (2) raw water ponds and one (1) stormwater retention pond) o The following corrections were made to Section II.E.3.00: - Corrected salt tank capacity to 3,500 gal - Corrected bleach tank capacity to 5,500 gal - Added the following to the water treatment chemicals tanks: defoam (350 gal), scale inhibitor (410 gal) and corrosion inhibitor (2,00 gal) o The entry under Section II.E.3.aaa for combustion turbine lube oil tanks was changed to indicate there are five (5) tanks. o The following corrections were made to Section II.E.3.fff: - Corrected the emergency diesel generator tank to 1,000 gal - Corrected the captive vehicle refueling tank to 560 gal Other Modifications In addition to the source requested modifications, the Division has included changes to make the permit more consistent with recently issued permits, include comments made by EPA on other Operating Permits, as well as correct errors or omissions identified during inspections and/or discrepancies identified during review of this renewal. The Division has made the following revisions, based on recent internal permit processing decisions and EPA comments to the Ft. St. Vrain Renewal Operating Permit. These changes are as follows: Page Following Cover Page • The monitoring and compliance periods and report and certification due dates are shown as examples. The appropriate monitoring and compliance periods and report and certification due dates will be filled in after permit issuance and will be based on permit issuance date. Note that the source may request to keep the same monitoring and compliance periods and report and certification due dates as were provided in the original permit. However, it should be noted that with this option, depending on the permit issuance date, the first monitoring period and compliance period may be short (i.e. less than 6 months and less than 1 year). Section I — General Activities and Summary • Condition 1.4 was revised to remove Section IV, Condition 3.d as a state-only requirement, since EPA approved these provisions into Colorado's SIP effective October 6, 2008. • Added a statement to Condition 1.5 indicating that either electronic or hard copy records are acceptable. Page 12 • 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 second column in the table in Condition 6.1 was labeled "AIRS point number" as that is more appropriate. • Included the startup date of the gasoline storage tank in the table in Condition 6.1. Section 11.1 - Turbines T002 and T003 • Conditions 1.2 and 1.3 (summary table) and Conditions 1.2.1.4 and 1.3.1.4 (text) were revised to specify three turbines (T002, T004 and T004), since there are more than three combustion turbines. • Revised the monitoring language for the NOx and CO BACT limits (Conditions 1.2.1 and 1.3.1) 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 1.2.2 and 1.3.2) 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 1.10 was revised to remove the references to the various portions of Condition 5 (CEMS requirements). The language in this condition now simply references Condition 5, rather than the various subsections of Condition 5. In addition, language was added to identify the GEMS (NOx, CO and diluents) and to state that monthly emissions from the CEMS will be used to assess compliance with the annual emission limitations. • Revised the performance test language in Condition 1 .12 to reflect current language. Section 11.2 —Turbine 4 • Conditions 2.5 and 2.6 (summary table and Conditions 2.5.1.4 and 2.6.1.4 (text) were revised to specify three turbines (T002, T004 and T004), since there are more than three combustion turbines. • Revised the monitoring language for the NOx and CO BACT limits (Conditions 2.5.1 and 2.6.1) 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 2.5.2 and 2.6.2) to specify how lbs/hr emission rates Page 13 are calculated and to indicate that replaced data is used to assess compliance with the annual limitations. • Condition 2.8 was revised to remove the references to the various portions of Condition 5 (GEMS requirements). The language in this condition now simply references Condition 5, rather than the various subsections of Condition 5. In addition, language was added to identify the CEMS (NOx, CO and diluents) and to state that monthly emissions from the CEMS will be used to assess compliance with the annual emission limitations. Section 11.5 — Continuous Emission Monitoring Systems (GEMS) • The requirements in this section were reorganized to be more consistent with other permits. A statement was added to the beginning of this section to indicate that these requirements are in addition to the Acid Rain monitoring requirements. • Condition 5.1 was revised to indication that a "turbine" is a combustion turbine or combustion turbine/HRSG/duct burner. • Removed the phrase "and the traceability protocols of Appendix H" from Condition 5.3.2, since Appendix H of the current version of 40 CFR Part 75 is "reserved". • 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. • Added language to Condition 5.4 (data replacement requirements) to make it clear that replaced and bias-adjusted data are used to monitor compliance with the annual limitations. • The reporting requirements in Condition 5.5 (NSPS reporting) was revised to reflect the language in 40 CFR Part 60 Subpart A § 60.7(c) and (d). Note that as requested by the source, reports will be required quarterly rather than semi-annual as noted in 60.7(c). Section 11.6 — Gasoline Storage Tank • Minor changes were made to the short note directly under the summary table. • The longer note under the summary table was removed. Information regarding the enforceability of the requirements in 40 CFR Part 63 Subpart CCCCCC will be addressed in Condition 6.2 Page 14 • The requirement to record the amount of gasoline dispensed (Condition 6.1) was removed since 40 CFR Part 63 Subpart CCCCCC requires that records of gasoline dispensed be maintained. • The following changes were made to Condition 6.2 (40 CFR Part 63 Subpart CCCCCC requirements: o Added language indicating that the source is subject to the most recent requirements in Subpart CCCCCC and noted the version of Subpart CCCCCC requirements that have been included. o A note was added indicating that the requirements in Subpart CCCCCC are only federally enforceable until they are adopted into Colorado Regulation No. 8, Part E. o Revisions to the requirements in 40 CFR Part 63 Subpart CCCCCC were made and these changes were reflected in the revised permit. Note that the changes are not substantive. o Added the general provisions. Note that since this unit is just subject to work practice standards, the only general provisions that are considered to apply are the prohibited activities and circumvention requirements in 63.4. • During the source's review of the draft permit, the source became aware that the existing gasoline storage tank located at the facility was not 500 gallons as noted in the permit but was 560 gallons. A 560 gallon gasoline storage tank would have been subject to the requirements in Colorado Regulation No. 7, Section VI.B.3; therefore, the source opted to replace the existing gasoline storage tank with a 500 gallon tank. The new tank is expected to be in operation prior to the end of 2015. Since this tank qualifies as a "new" tank under 40 CFR Part 63 Subpart CCCCCC, the compliance date for"new" affected sources was included in Condition 6.2 of the permit. Section 11.7 — Cold Cleaner Solvent Vats • Minor changes were made to the note under the summary table. Section 11.8 —Turbine 5 & 6 • Condition 8.2 (summary table) and Condition 8.2.1.2 (text) were revised to specify the two turbines (T005 and T006). • Revised the monitoring language for the NOx RACT limits (Condition 8.2.1) to indicate that replaced and bias-adjusted data are not used in assessing compliance with RACT limits. • Revised the monitoring language for the NOx and CO annual emission limitations (Conditions 8.2.2 and 8.3) to specify how lbs/hr emission rates are Page 15 calculated and to indicate that replaced data is used to assess compliance with the annual limitations. • Condition 8.10 was revised to remove the references to the various portions of Condition 5 (CEMS requirements). The language in this condition now simply references Condition 5, rather than the various subsections of Condition 5. In addition, language was added to identify the CEMS (NOx, CO and diluents) and to state that monthly emissions from the CEMS will be used to assess compliance with the annual emission limitations. • A "new" condition 8.18 was added to address the relaxation of emission limitations for the turbines. The initial construction permit (07WE1100) was issued on February 6, 2008. At that time the area in which the facility was located was designated non-attainment for ozone but attainment for all other criteria pollutants and that designation has not changed. Conditions were included in the construction permit stipulating that emissions could not be relaxed above the significance level unless PSD and/or NANSR requirements were met. These requirements were not included in the Title V permit since no actual requirements applied unless the emission limitations for the turbine were revised. At this time the Division considers that these requirements regarding relaxation of permit conditions should be addressed in the permit. The language for this condition will address certain pollutants and the levels above which emissions cannot be relaxed without triggering major stationary source permitting requirements (i.e., PSD or NANSR). Based on the emission rates included in the preliminary analysis for the initial construction permit (issued February 6, 2008) and the default SO2 emission factor in Part 75, Appendix D for units firing pipeline quality natural gas (0.0006 lb/MMBtu) and assuming each turbine operates for 8760 hours per year, NOx, CO, PM and PM10 emissions would exceed the significance levels. Therefore, the relaxation condition will only address these pollutants. Section 11.9 — Emergency Compression Ignition Engines • Minor changes were made to the note under the summary table. • The following changes were made to Condition 9.1 (40 CFR Part 63 Subpart ZZZZ requirements): o Added language indicating that the source is subject to the most recent requirements in Subpart ZZZZ and noted the version of Subpart ZZZZ requirements that have been included. Page 16 o 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. o The language was updated to include the revisions for Subpart ZZZZ. • Condition 9.4 (40 CFR Part 63 Subpart A— general provisions) was removed, these requirements have been included in Condition 9.1. Section III —Acid Rain Permit • Revised the Designated Representative and 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 (Section 111.3). Section IV— Permit Shield • Removed Condition 2.9 (CAM requirements) from the first column in the Table in Section 11.3.(streamlined condition) for the NSPS Da NOx limit in 60.44Da(d)(1) (1.6 lb/MW-hr) in the second to the last row, as only the more stringent NOx BACT limit (Condition 2.5.1.2) need be listed. Section V— General Conditions • Revised the version date. • The paragraph in Condition 3.d indicating that the requirements are state- only has been removed, since EPA approved these provisions into Colorado's SIP effective October 6, 2008. Appendices • Language was added to the insignificant activity list in Appendix A 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). • Revised Appendix D to correct EPA address (compliance notifications) and to clarify permit mods sent to EPA. • Cleared the table in Appendix F. Page 17 PSCo-Ft.St.Vrain—Total HAP Emissions(tons/yr) Emission Unit formaldehyde acetaldehyde toluene benzene acrolein xylene chloroform hexane dichlorobenzene nickel cadmium manganese chromium Total Unit 2- turbine 2.33 0.49 0.70 0.06 0.03 0.34 0.62 0.43 5.00 Unit 2- DB 0.01 4.06E-03 8.31E-04 2.32E-03 4.06E-03 2.13E-03 2.71E-03 0.02 Unit 3- turbine 1.48 0.55 0.78 0.07 0.04 0.38 0.69 0.48 4.48 Unit 3- DB 0.01 4.06E-03 8.31E-04 2.32E-03 4.06E-03 2.13E-03 2.71E-03 0.02 Unit 4- turbine 2.42 0.55 0.78 0.07 0.04 0.39 0.69 0.48 5.43 Unit 4- DB 0.01 3.25E-03 6.66E-O4 1.86E-03 3.25E-03 1.70E-03 2 17E-03 0.02 Units 5 8 6 0.79 0.10 0.14 1.33E-02 0.01 0.07 1.28E-01 0.09 1.34 8001 0.14 0.00 6.84E-04 1.40E-04 3.91E-04 6.84E-04 3.58E-04 4.56E-04 0.14 M001 2.37 2.37 a ,. . • Total 7.15 1.69 2.43 0.23 0.12 1.18 2.37 2.47E-03 6.89E-03 2.14 6.31E-03 1.48 8.03E-03 18.82 Page 18 PSCo-Ft.St.Vrain—Actual Emissions (tons/yr) Emissions(tons/yr) Unit Data Year PM PM10/PM25 SO2 NOx CO VOC HAPs Ammonia Turbine(T002) 2013 19.2 19.2 2.9 155.2 18.1 6.1 2.30 Turbine(T003) 2013 10 10 2 105.9 29.2 3 1.75 Turbine(T004) 2013 18.2 18.2 2.2 47.1 40.5 3.5 1.72 8.4 Auxiliary Boiler 2012 0.17 0.17 0.05 8.74 7.34 0.48 Cooling/Service Water 2010 3.1 3.1 2.2 2.2 Towers Turbine(T005) 2013 2 2 0.30 14.14 6.24 0.10 0.36 Turbine(T006) 2013 1.3 1.3 0.25 12.06 5.5 0.04 0.30 Total 53.97 53.97 7.70 343.14 106.88 15.42 8.63 8.4 actual emissions from data year 2010 based on the APEN submitted on 4/29/11 actual emissions from data year 2012 are based on the APEN submitted on 4/24/13 actual emissions from data year 2013 are based on the APENS submitted on 4/29/14 Page 19 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION OPERATING PERMIT RENEWAL SUMMARY PERMIT NUMBER: 97OPWE180 AIRS ID#: 1230023 DATE: September 10, 2015 APPLICANT: Public Service Co—Ft. St. Vrain Station REVIEW ENGINEER: Jacqueline Joyce SOURCE DESCRIPTION Public Service Co has applied for renewal of their Operating Permit issued for Ft. St. Vrain Station, located at 16805 County Road 19 '/ in Weld County. This facility classified as an electric services facility under Standard Industrial Classification 4911. This facility consists of five (5) natural gas fired combustion turbines and three (3) heat recovery steam generators (HRSG). The capacity of the steam turbine is 330 megawatts (MW). The output rating of the entire plant varies based on ambient temperature with more generation in the winter and less generation in the summer. The facility generates approximately 965 MW (summer rating)of electricity. 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. Rocky Mountain National Park and Eagles Nest and Rawah National Wilderness Areas, all Federal Class I designated areas, are 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. Turbine 4 is equipped with non-selective catalytic reduction to reduce NOx emissions and is subject the Compliance Assurance Monitoring (CAM) requirements in 40 CFR Part 64. FACILITY EMISSION SUMMARY Potential to Emit(PTE) Emission Unit PM I PM,o I SO2 I NOx I CO I VOC I HAPS Turbine(T002) 39.4 39.4 4.7 496.1 465.4 21.4 5.02 Turbine(T003) 39.4 39.4 4.7 496.1 465.4 21.4 4.50 Turbine(T004) 54 54 4.7 199.1 237.9 33.1 5.45 Turbine(T005)* 4.45 4.45 1.85 19.95 10 1.15 0.67 Turbine (T006)* 4.45 4.45 1.85 19.95 10 1.15 0.67 Auxiliary Boiler(B001) 0.6 0.6 0.2 32.6 27.4 1.8 0.14 Cooling/Service Water 14.9 14.9 2.4 2.37 Towers(M001) Total 157.2 157.2 18 1,263.8 1,216.1 82.4 18.82 *permitted emission limits are for both turbines together, emissions are assumed to be split between the 2 units. 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 2 and 3 (Section 11.1)—The definition of startup was revised to allow for 30 minutes after reaching Mode 6. This startup definition applies to all combustion turbines (Turbines 2, 3, 4, 5&6). 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 lb/hr emissions rates, which are used to estimate monthly mass emissions, are calculated. Turbine 4 (Section 11.2)—The definition of combustion tuning and testing was revised to include testing and tuning of the selective catalytic reduction (SCR) unit. 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 lb/hr emissions rates, which are used to estimate monthly mass emissions, are calculated. Continuous Emission Monitoring Systems (Section 11.5)—The reporting requirements were revised to require quarterly submittal. 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. Gasoline Storage Tank (Section 11.6) -The 40 CFR Part 63 Subpart CCCCCC requirements were revised to reflect revisions to the regulation. In addition, the compliance date in Subpart CCCCCC was revised to reflect that the gasoline tank will be replaced prior to permit issuance. Turbines 5 &6 (Section 11.8)—The alternate NOx limits in 40 CFR Part 60 Subpart KKKK for operating at loads less than 75% and temperatures less than 0 °F were included in the permit, as well as some other monitoring requirements that had not previously been included in the permit. Minor language changes were made to the monitoring language for the NOx and CO RACT limits to indicate that replaced and bias-adjusted data are not included and to indicate how the lb/hr emissions rates,which are used to estimate monthly mass emissions, are calculated. A condition was added to address the relaxation of emissions limitations above the significance level. Emergency Generator Engines and Emergency Fire Pump Engine (Section 11.9)-The opacity monitoring language was revised to simplify the requirements. The 40 CFR Part 63 Subpart ZZZZ requirements were revised to reflect revisions to the regulation. ALTERNATIVE OPERATING SCENARIOS No new alternative operating scenarios or revisions to existing alternative operating scenarios were requested with the renewal permit. INSIGNIFICANT ACTIVITY LIST 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. PERMIT SHIELD No additional non-applicable requirements were included in the permit shield. Some monitoring requirements from 40 CFR Part 60 Subpart KKKK were included in the permit shield for streamlined condisions. CDPHE COLORADO CO V Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado September 9, 2015 Mr. Josh Korth Environmental Services Xcel Energy 1800 Larimer Street Suited 1300 Denver, CO 80202 REF: Public Service Company of Colorado - Ft. St. Vrain Station, FID # 1230023, OP # 97OPWE180 SUBJECT: Response to Comments on Draft Operating Permit Dear Mr. Korth: The comments you provided on the draft renewal Operating Permit (97OPWE180) and Technical Review Document for your facility were received on September 3, 2015. The Division has reviewed and addressed your comments as follows: Comments Related to Technical Review Document Comment 1: Page 9, Section 11. 1: The condition requested to be revised by the source should be 1.6.4. 1, not 6.4. 1. Response: The change will be made as requested. Comment 2: Page 10, Section 11.1, First Bullet: 1 believe this should state ...three turbines (T002, T003 and T004)... Response: The change will be made as requested. Comment 3: Page 11, Section 11.2, First Bullet: Same comment as Section 11. 1. Response: The change will be made as requested. Comment 4: Page 12, Section 11.6, Second Bullet: I believe the reference here should be 6.1 as there is no 6.2 in the draft renewal permit. Response: As discussed in the Technical Review Document directly under "Section III. Discussion of Modifications Made" the discussion related to modifications is with respect to the current active permit (issued September 9, 2011). The Technical Review Document also notes directly under "Section III Discussion of Modifications Made" that "because some permit conditions in the current Title 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ; John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer h !`- Mr. Josh Korth, Xcel Energy September 9, 2015 s Response to Comments on Draft Permit Page 2 V permit have been removed, reorganized and/or reformatted...the condition numbers in this document (technical review document] may not reflect the condition numbers in the draft Title V permit." To this end, the current Title V permit (issued September 9, 2011) includes a Condition 6.2 (this condition was renumbered to Condition 6.1 in the draft Title V permit) and the bullet refers to changes made to Condition 6.2 (MACT CCCCCC requirements) included in the September 9, 2011 permit (the current permit). Therefore, no changes will be made to the technical review document based on this comment. Comments Related to Draft Renewal Permit Comment 5: Section II, Condition 1.2.1.5: PSCo requests that the definition of startup be modified to be 30 minutes after achieving Mode 6 Operation to make the startup definition consistent among all PSCo combustion turbine facilities. Response: The change will be made as requested. Comment 6: Section 11, Conditions 1.2.1.8, 1.2.1.9, 1.3.1.8, 1.3.1.9, 2.5.1.8, 2.5.1.9, 2.6.1.8, 2.6.1.9, 8.2.1.7, and 8.2.1.8: These conditions should state that the frequency is quarterly to match referenced condition 5.5. Response: The changes will be made as requested. Comment 7: Section II, Condition 1.2.2, 1.3.2, 2.5.2, 2.6.2, 8.2.3 and 8.3: As written, these conditions assume a CO2 diluent by referencing Equation F5. Please revise F-5 to say "...F-5 or F-6, as appropriate for the diluent monitored by the CEMS and F-20...". Currently Turbine 4 uses 02 as the diluent and the other 4 turbines use CO2. For future CEMS replacement projects we need to maintain the flexibility to use either diluent, as allowed by the Acid Rain program. Response: The changes will be made as requested. Comment 8: Section II, Condition 5.3: This condition incorrectly states "or opacity" after unit emissions in the second row. Please remove the reference to opacity. Response: The change will be made as requested. Comment 9: Section II, Condition 8.11: As discussed during our meeting on 8/20, please revise this condition to be consistent with the latest revisions to the 40CFR60, Subpart KKKK language that take into account the unit operating level for the hourly limits and calculation of a rolling 4-hour KKKK limit. Response: Section II, Condition 8.2.2 was reformatted and revised to include the alternate limits in NSPS KKKK when operating at loads less than 75% of peak load and when operating at temperatures less than 0 °F. In addition, the language in 60.4380(b)(3) was included in Section II, Conditions 5.6 and 8.2.2. The Division also took this opportunity to review how the NSPS KKKK requirements were included in the permit and additional changes were made. These are addressed in the technical review document with the September 3, 2015 comments. If PSCo has issues with the additional changes were made, feel free to comment during the public comment period. Comment 10: Appendix A, Safety Equipment Required: Please add Gloves to the list. Mr. Josh Korth, Xcel Energy September 9, 2015 Response to Comments on Draft Permit Page 3 Response: The change will be made as requested. Insignificant Activity List Comment 11: Finally, these were suggested by the plant analyst as additions and corrections to the insignificant activity list: a. II.E.3.zz. Storage of butane, propane, or liquefied petroleum gas in a vessel with a capacity of less than sixty thousand gallons, provided the requirements of Regulation Number 7, Section IV. are met, where applicable. We have small portable propane tanks onsite to fuel the heaters. b. II.E.3.kkk. Forklifts. There are two gasoline fueled forklifts onsite. c. II.E.3.cccc. Seal and lubricating oil systems for steam turbine electric generators. Our steam turbine has a seal and lubricating oil system. d. Corrections to List of Insignificant Activities Page 3, at the top of the page, items listed under Reg 3, Part C.II.E.00. • Salt tank capacity should be 3,500 gal, not 5,000 gal. • Bleach tank capacity should be 5,500 gal, not 5,000 gal. • The other water treatment chemicals tanks that should be in this list: 1. Defoam 350 gal 2. Scale Inhibitor 410 gal 3. Corrosion Inhibitor 2,000 gal e. Lubricating Oil Storage Tanks (Reg 3, Part C.II.E.3.aaa). There are five (5) combustion turbine tube oil tanks, not three (3). f. II.E.3.yyy. Surface water storage impoundment of non-potable water and storm water evaporation ponds. We have two raw water ponds and a stormwater detention pond onsite. g. Storage tanks with annual throughput less than 400, gal... (Reg 3, Part C.II.E.3.fff) 3.fff) • The capacity of the Emergency diesel generator tank is 1,000 gal, not 550 gal. • The capacity of the diesel fuel tank for refueling captive vehicles is 560 gal, not 500 gal. Response: The changes will be made as requested. In addition, thank you for providing responses to the two questions noted in the transmittal letter. No changes are necessary to the Technical Review Document to note that no additional stationary internal combustion engines are located at this facility and that actual emissions from the emergency generator and fire pump engines are below the APEN de minimis level. 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 Mr. Josh Korth, Xcel Energy September 9, 2015 Response to Comments on Draft Permit Page 4 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 to contact me at (303) 692-3267 or jackie.joyce@state.co.us if you have any further questions. Sincerely, Ciiefra44_926frL_ Jacqueline Joyce Operating Permit Unit Stationary Sources Program Air Pollution Control Division Xcel Energys~ SEP-3 2015 Environmental Services Department 1800 Larimer Street,Suite 1300 Denver, CO 80202 September 3,2015 Ms. Jacqueline Joyce Colorado Department of Public Health&Environment Air Pollution Control Division,APCD-SS-B1 Operating Permit Unit 4300 Cherry Creek Drive South Denver, CO 80246-1530 RE: Fort St.Vrain Station Operating Permit No. 97OP WE 180 Draft Permit Renewal Comments Dear Ms. Joyce: Included below are the Public Service Company of Colorado comments and questions regarding the Draft Fort St. Vrain Title V renewal permit. The requested changes from the application have been reviewed and found to consistent with the requested changes. The following comments are mostly editorial in nature or for clarification as the limits and requirements from the past permit have been carried forward properly in the draft renewal version. Comments and Questions related to the Technical Review Document: 1) Page 9, Section 11.1: The condition requested to be revised by the source should be 1.6.4.1,not 6.4.1. 2) Page 10, Section 11.1,First Bullet: I believe this should state ...three turbines (T002, T003 and T004)... 3) Page 11, Section 11.2,First Bullet: Same comment as Section II.1. 4) Page 12, Section II.6, Second Bullet: I believe the reference here should be 6.1 as there is no 6.2 in the draft renewal permit. Comments related to the draft renewal permit language: 5) Section II,Condition 1.2.1.5: PSCo requests that the definition of startup be modified to be 30 minutes after achieving Mode 6 Operation to make the startup definition consistent among all PSCo combustion turbine facilities. 6) Section II,Conditions 1.2.1.8, 1.2.1.9, 1.3.1.8, 1.3.1.9,2.5.1.8,2.5.1.9,2.6.1.8,2.6.1.9, 8.2.1.7,and 8.2.1.8: These conditions should state that the frequency is quarterly to match referenced condition 5.5. 7) Section II,Condition 1.2.2, 1.3.2,2.5.2,2.6.2, 8.2.3 and 8.3: As written,these conditions assume a CO2 diluent by referencing Equation F5. Please revise F-5 to say "...F-5 or F-6, as appropriate for the diluent monitored by the CEMS and F-20...". Currently Turbine 4 uses O2 as the diluent and the other 4 turbines use CO2. For future CEMS replacement projects we need to maintain the flexibility to use either diluent, as allowed by the Acid Rain program. 8) Section II,Condition 5.3: This condition incorrectly states "or opacity"after unit emissions in the second row. Please remove the reference to opacity. 9) Section II,Condition 8.11: As discussed during our meeting on 8/20,please revise this condition to be consistent with the latest revisions to the 40CFR60, Subpart KKKK language that take into account the unit operating level for the hourly limits and calculation of a rolling 4-hour KKKK limit. 10) Appendix A,Safety Equipment Required: Please add Gloves to the list. Finally,these were suggested by the plant analyst as additions and corrections to the insignificant activity list: a.II.E.3.zz. Storage of butane,propane,or liquefied petroleum gas in a vessel with a capacity of less than sixty thousand gallons,provided the requirements of Regulation Number 7, Section IV. are met,where applicable. We have small portable propane tanks onsite to fuel the heaters. b.II.E.3.kkk.Forklifts. There are two gasoline fueled forklifts onsite. c.II.E.3.cccc. Seal and lubricating oil systems for steam turbine electric generators. Our steam turbine has a seal and lubricating oil system. d.Corrections to List of Insignificant Activities Page 3,at the top of the page,items listed under Reg 3,Part C.II.E.00 • Salt tank capacity should be 3,500 gal,not 5,000 gal. • Bleach tank capacity should be 5,500 gal,not 5,000 gal. • The other water treatment chemicals tanks that should be in this list: 1. Defoam 350 gal 2. Scale Inhibitor 410 gal 3. Corrosion Inhibitor 2,000 gal e.Lubricating Oil Storage Tanks (Reg 3,Part C.H.E.3.aaa) There are five(5)combustion turbine lube oil tanks, not three (3). 1.ll.E.3.yyy. Surface water storage impoundment of non-potable water and storm water evaporation ponds. We have two raw water ponds and a stormwater detention pond onsite. g.Storage tanks with annual throughput less than 400,gal... (Reg 3,Part C.II.E.3.fff) • The capacity of the Emergency diesel generator tank is 1,000 gal,not 550 gal. • The capacity of the diesel fuel tank for refueling captive vehicles is 560 gal,not 500 gal. Below are the responses to the two questions that you included in the transmittal letter with the draft permit. 1) No additional stationary internal combustion engines are located at this facility. 2) 2014 Emissions from the Emergency Fire Pump and Emergency Generator engines were all below APEN de minimis levels. FORT ST.VRAIN EGI Emergency Generator(M004) TSP 0.01 PM-10 0.01 PM-2.5 0.01 SOx 0.03 NOx 0.20 CO 0.05 VOC 0.01 a FORT ST.VRAIN EGl Emergency Generator(M004) TSP 0.01 PM-10 0.01 PM-2.5 0.01 SOx 0.03 NOx 0.20 CO 0.05 VOC 0.01 FORT ST.VRAIN Emergency Fire Pump Engine(M004) TSP 0.00 PM-10 0.00 PM-2.5 0.00 SOx 0.00 NOx 0.03 CO 0.01 If you have any questions q son the information above, please contact me at 303-294-2187 or joshua.r.korth@xcelenergy.com. Sincerely, Josh Korth Environmental Services Xcel Energy cc: Fort St.Vrain Electronic Files 9/1/2015 State.co.us Executive Branch Mail-RE:FSV F9 V • r+ � e�rslt STATE OF �= Co�C�RAa� Joyce -CDPHE, Jackie <jackie.joyce@state.co.us> ,� � RE: FSV 1 message Korth,Joshua R <Joshua.R.Korth@xcelenergy.com> Tue, Sep 1, 2015 at 12:25 PM To: "Joyce - CDPHE, Jackie" <jackie.joyce@state.co.us> January 1 would be great for both. That will keep the semi-annual and annual reports on the same timeline and be a good start to the new year. Josh From: Joyce - CDPHE, Jackie [mailto:jackie.joyce@state.co.us] Sent: Tuesday, September 01, 2015 12:23 PM To: Korth, Joshua R Subject: Re: FSV That sounds fine. Now we only publish public notices on Wednesdays (unless the permit is really time sensitive) so I think I should be able to get the public notice issued on Sept. 12. I was kind of planning on issuing FSV with a Jan 1 date (it will then be on track with the current permit), even if I can issue it earlier. I was thinking of doing the same with BSEC. I could issue BSEC on November 1 but I was thinking of putting a Jan 1 issuance date on it. If you would prefer the earlier date, let me know. Jackie Joyce Permit Writer Operating Permit Unit, Stationary Sources Program P 303.692.3267 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246 Jackie.Joyce@state.co.us I www.colorado.gov/cdphe/apcd https://m ai I.google.com/m ai I/u/0/?ui=2&i k=4cf2986dc4&vi ew=pt&search=i nbox&th=14f8a27e6789b46d&si m l=14f8a27e6789b46d 1/2 9/1/2015 State.co.us Executive Branch Mail-RE:FSV 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.govfcdphe/APENforms On Tue, Sep 1, 2015 at 12:11 PM, Korth, Joshua R <Joshua.R.Korth@xcelenergy.com> wrote: The plant manager decided yesterday that they will buy a new tank that is 500 gallons and delivery time on that is 4-6 weeks so it will be installed before the next version of the permit is issued. I'm working on finalizing my comments and will email the word version to you later today or first thing tomorrow. Josh https://mail.google.com/mail/u/0/?ui=2&ik=4cf2986dc4&view=pt&search=inbox&th=14f8a27e6789b46d&siml=14f8a27e6789b46d 2/2 9/9/20131State.co.us Executive Branch Mail-RE:Quick Meeting Thursday? 4'e.7 E STAT of STATE Joyce -CDPHE, Jackie <jackie.joyce@state.co.us> COLO ADC3 • 7kl�. RE: Quick Meeting Thursday? 1 message Korth, Joshua R <Joshua.R.Korth@xcelenergy.com> Tue, Aug 18, 2015 at 1:40 PM To: "Joyce - CDPHE, Jackie" <jackie.joyce@state.co.us> I was hoping to run the reports down to the state between 10 and 12 but can also do it in the afternoon so p g p really any time that works well for you and you can find a room I can make work on my end. The item in KKKK that I want to discuss is 60.4380(b). I've attached the section that I am struggling with below and added in my own thoughts within the brackets. Table 1 lists standards based on unit size but also for a couple of operating scenarios and the way that I read it, when a unit is operating below 75% of peak load, the 96 ppm value applies and when the unit is above 75% load then the 15 ppm value would apply. The compliance limit that applies to a given time period would be the rolling average of the hourly values just like how the CEMS rolling average is calculated, Our DAS vendor is able to program the software to do this and has done it for clients of theirs in other states. 60.4380(b) For turbines using continuous emission monitoring, as described in §§60.4335(b) and 60.4345: (3) For operating periods during which multiple emissions standards apply, the applicable standard is the average of the applicable standards during each hour [i.e. 4-hr rolling limit value]. For hours with multiple emissions standards, the applicable limit for that hour is determined based on the condition that corresponded to the highest emissions standard [i.e.15 ppm if above 75% CT load for the entire hour or 96 ppm if below 75 % turbine load at any time during the hour]. Josh From: Joyce - CDPHE, Jackie [mailto:jackie.joyce@state.co.us] Sent: Tuesday, August 18, 2015 1:18 PM To: Korth, Joshua R Subject: Re: Quick Meeting Thursday? I have time for a meeting on Thus - I'm usually in btwn 7:30 and 3:30, so within that time would work for me. It you can give me a heads up on the time, then I can try to arrange a conference room. https://maiI.google.com/mail/u/0/?ui=2&ik=4cf2986dc4&view=pt&as from=Joshua.R.Korth%40xcel energy.com&as_sizeoperator=s_sl&as_sizeunit=s_smb&a... 1/3 9/9/2015 State.co.us Executive Branch Mail-RE:Quick Meeting Thursday? It would be helpful to know specifically what the KKKK issue is up front, that way I can do some research before we meet and then hopefully address it, in the meeting. • Jackie Joyce Permit Writer Operating Permit Unit, Stationary Sources Program P 303.692.3267 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246 Jackie.Joyce@state.co.us I www.colorado.gov/cdphe/apcd 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.gov/cdphe/APENforms On Tue, Aug 18, 2015 at 1:09 PM, Korth, Joshua R<Joshua.R.Korth@xcelenergy.com> wrote: Jackie, Do you have 30 minutes to an hour sometime on Thursday to meet? I will be bringing a bunch of reports down to the state offices and was hoping maybe you would have a few minutes to chat regarding the FSV renewal. I'd like to get a better understanding of the CAM item mentioned in draft comments I sent to you and if needed, remove that comment based on the discussion. I also want discuss in more detail the NSPS KKKK requirements. We completed RATA last week on the Cherokee turbines and the way those construction permits and the FSV permits handle KKKK doesn't seem to be consistent. As I read (and re-read) KKKK I'm not sure either of them completely capture how to handle startup and shutdown periods the way KKKK specifies. With FSV and Cherokee being our only two plants subject to those rules right now, I want to make sure they are both correct and consistent while we have this opportunity. Thanks, Josh httos://mail.aooale.com/mail/u/0/?ui=2&ik=4cf2986dc4&view=pt&as from=Joshua.R.Korth%40xcelenergy.com&as_sizeoperator=s sl&as_sizeunit=s smb&a... 2/3 9/8/26, State.co.us Executive Branch Mail-RE:Draft comments for FSV Permit Renewal `n`,..\'' STATE OF ► CO ORAdC1 Joyce -CDPHE, Jackie <jackie.joyce@state.co.us> 8F%t• RE: Draft comments for FSV Permit Renewal 1 message Korth, Joshua R <Joshua.R.Korth@xcelenergy.com> Fri, Aug 14, 2015 at 1:58 PM To: "Joyce - CDPHE, Jackie" <jackie.joyce@state.co.us> Yes, I can send you the word version...I just back from a meeting with Chad up at Rocky Mountain. He was headed back to FSV and was going to check on the tank size again. He wasn't sure what Jason gave me was correct. I have a call from 2:00 to 2:30 and then him and I are going to talk about this. Josh From: Joyce - CDPHE, Jackie [mailto:jackie.joyce@state.co.us] Sent: Friday, August 14, 2015 8:53 AM To: Korth, Joshua R Subject: Re: Draft comments for FSV Permit Renewal Josh, There is no blanket exemption from CAM for units that use CEMS to directly measure emissions. The CAM exemption related to continuous monitoring is in 64.2(b)(1)(vi), which states the following (emphasis added): Emission limitations or standards for which a part 70 or 71 permit specifies a continuous compliance determination method, as defined in 564.1. Turbine 4 was not in the original Title 5 permit issued on January 1, 2000. It was incorporated into the T5 permit via a significant modification in 2003. Since Turbine 4 was a large pollutant specific emission unit (controlled emissions above the major source level), a CAM plan was required to be submitted with the application to roll the turbine into the T5 (see 64.5(a)(2)). CAM is use of the CEMS for direct emissions measurement, thus there is no CAM plan per se in the permit but the CAM requirements do apply. Since Unit 4 is a large pollutant specific emission unit, the frequency for monitoring is essentially continuous (4 or more data values equally spaced over an hour) per 64.3(b)(4). One important thing about CAM is the timing for when the requirements need to be addressed. For large pollutant specific emission units (emissions above major source level with controls), CAM needs to be addressed in the initial T5 application or with a significant modification (If submitted on or after 4/20/98). https://mail.google.com/mail/u/0/?ui=28jk=4cf2986dc4&view=pt&as from=Joshua.R.Korth%40xcelenergy.com&as_sizeoperator=s_sl&as_sizeunit=s_smb&a... 1/3 9/8/2015 State.co.us Executive Branch Mail-RE:Draft comments for FSV Permit Renewal Thus large pollutant specific emissions units will generally never get to take the exemption for continuous monitoring (because they don't have a T5 permit that requires continuous monitoring). For small pollutant specific emissions units (emissions below the major source level with controls), CAM isn't addressed until the T5 renewal, thus if the unit is equipped with a CEMS to monitor direct compliance they are exempt from CAM because their T5 permit specifies a continuous compliance demonstration method per 64.2(b)(1)(vi)). We can still discuss this next week if you like, but I wanted to give you an explanation. Jackie Joyce Permit Writer Operating Permit Unit, Stationary Sources Program CDPHE (COLORADO co Air Pollution Control Division �r v i Department of Public Health 7 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.colorado.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.gov/cdphe/APENforms On Fri, Aug 14, 2015 at 8:23 AM, Korth, Joshua R <Joshua.R.Korth@xcelenergy.com> wrote: Jackie, Attached are the comments I'll be dropping of this afternoon for the FSV permit renewal. I do want to find some time in the next week or two to discuss the CAM requirements as I am not understanding the background of why they are in there for Unit 4 since NOX is directly monitored. Thanks, Josh https://mail.google.com/mail/u/0/?ui=2&ik=4cf2986dc4&view=pt&as from=Joshua.R.Korth%40xcelenergy.corn&as_sizeoperator=s_sl&as_sizeunit=s_smb&a... 2/3 9/8/2C1E„ State.co.us Executive Branch Mail-RE:Draft comments for FSV Permit Renewal josh Korth Xcel Energy I Responsible By Nature Environmental Analyst V 1800 Larimer Street, Suite 1300 Denver, CO 80202 P: 303-294-2187 C: 303-596-0244 joshua.r.korth@xcelenergy.com XCELENERGY.COM Please consider the environment before printing this email This e-mail, and any attachments, may contain confidential or private material for the sole use of the intended recipient(s). If you are not the intended recipient, please contact the sender by reply mail and delete all copies of this message and any attachments. https://m ai I.google.com/m ai I/u/0/?ui=2&i k=4cf2986dc4&view=pt&as_from=Joshua.R.Korth%40xcelenergy.com&as_sizeoperator=s_s I&as_si zeunit=s_sm b&a... 3/3 9/8/2015 State.co.us Executive Branch Mail-Re:Draft comments for FSV Permit Renewal tf�n r r.r " STATE OF . COLORADO Joyce -CDPHE, Jackie <jackie.joyce@state.co.us> Re: Draft comments for FSV Permit Renewal 1 message Joyce -CDPHE, Jackie <jackie.joyce@state.co.us> Fri, Aug 14, 2015 at 9:33 AM To: "Korth, Joshua R" <Joshua.R.Korth@xcelenergy.com> Josh, Is it possible to get a copy of your comments in Word? In my response to comments I usually include the comment and follow up with our response - so it is quicker and easier if I can cut and paste your comments. Also, I noticed that the gasoline tank is slightly larger than previously thought. Since the tank is over 550 gallons, then the requirements in Reg 7, Section VI.B.3 apply (submerged fill and stage I vapor recovery) and I will include those. The exemption levels for these Reg 7 requirements is 550 gallons (if installed after Nov. 7, 1973) and 2,000 gal (if installed before Nov. 7, 1973). Jackie Joyce Permit Writer Operating Permit Unit, Stationary Sources Program A CDPHE COLORADO CO • Air Pollution Control Division Department of Public Health h 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.colorado.gov/cdphe/aped 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.gov/cdphe/APENforms On Fri, Aug 14, 2015 at 8:23 AM, Korth, Joshua R <Joshua.R.Korth@xcelenergy.com> wrote: Jackie, Attached are the comments I'll be dropping of this afternoon for the FSV permit renewal. I do want to find some time in the next week or two to discuss the CAM requirements as I am not understanding the background of why they are in there for Unit 4 since NOX is directly monitored. Thanks, Josh https://mail.google.com/mail/u/0/?ui=2&ik=4cf2986dc4&view=pt&as to=Joshua.R.Korth%40xcelenergy.com&as_sizeoperator=s_sl&as_sizeunit=s_smb&as_s... 1/2 9/8/2015 State.co.us Executive Branch Mail-Re:Draft comments for FSV Permit Renewal josh Xorth Xcel Energy I Responsible By Nature Environmental Analyst V 1800 Larimer Street, Suite 1300 Denver, CO 80202 P: 303-294-2187 C: 303-596-0244 joshua.r.korth@xcelenergy.com XCELENERGY.COM Please consider the environment before printing this email This e-mail, and any attachments, may contain confidential or private material for the sole use of the intended recipient(s). If you are not the intended recipient, please contact the sender by reply mail and delete all copies of this message and any attachments. https://m ail.google.com/mail/u/0/?ui=2&ik=4cf2986dc4&view=pt&as to=Joshua.R.Korth%40xcelenergy.com&as_sizeoperator=s sl&as_sizeunit=s smb&as_s... 2/2 A CDPHE COLORADO CO "V Department vironmeofPublicnt Dedicated to protecting and improving the health and environment of the people of Colorado June 26, 2015 Mr. Josh Korth Environmental Services Xcel Energy 1800 Larimer Street Suite 1300 Denver, CO 80202 SUBJECT: Draft Renewal Operating Permit for Public Service Company of Colorado — Ft. St. Vrain Station Dear Mr. Korth: Enclosed please find a draft of the renewal operating permit for your facility as well as a copy of the technical review summary document. Please review and submit any comments you may have concerning the modified draft operating permit. Following our review of your comments, we will send the draft permit out for a 30-day Public Comment period and then to EPA for their 45-day review period. The regulations also require that the applicant receive written notice of their right to a formal hearing before the Colorado Air Quality Control Commission at the same time that the Public Comment packet goes out. You will receive a separate letter containing that information. This draft renewal permit contains the modifications that you requested in your renewal application received on December 17, 2014. The permit was also revised to be more consistent with recently issued permits, correct errors, omissions and discrepancies identified during inspections and/or review of the renewal application and incorporate EPA comments made on other operating permits for similar sources. The changes are summarized in the technical review document for the renewal permit. While you are reviewing this permit, please be aware of the following: 1. 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). .,-;a 1c76 A.4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe < y'' John W. Hickenlooper, Governor I Larry Wolk,MD, MSPH, Executive Director and Chief Medical Officer * '*1 Mr. Josh Korth, Xcel Energy June 26, 2015 Draft Renewal Permit for Ft. St. Vrain Station Page 2 2. Please confirm that actual, uncontrolled emissions from the emergency fire pump and emergency generator engines are below the APEN de minimis level (1 ton/yr of NOX and 2 tons/year of CO). We would like you to review this permit and respond to the items identified above by July 31, 2015. Feel free to give me a call at (303) 692-3267 if you have any questions or concerns. Sincerely, C'-:14214A-14L9298-(-- Jacqueline Joyce, Permit Engineer Operating Permit Unit Stationary Sources Program Air Pollution Control Division Enclosures • Xcel Energy- Environmental Services Department 1800 Larimer Street,Suite 1300 Denver,CO 80202 December 17, 2014 Ms. Jacqueline Joyce Colorado Department of Public Health & Environment Air Pollution Control Division, APCD-SS-B1 Operating Permit Unit 4300 Cherry Creek Drive South Denver, CO 80246-1530 RE: Fort St. Vrain Station Permit#97OPWE180 Minor Permit Modification Dear Ms. Joyce: In accordance with the requirements of Colorado Air Quality Control Commission Regulation No. 3, Part C.X, Public Service Company of Colorado (PSCo) is hereby submitting this application for a minor modification to the Fort St. Vrain Station Title V operating permit, No. 97OPWE180. This modification request is being submitted in order to gain approval from the Division to update the hour tracking methodology and requirements for a second annual Method 9 observation beginning on January 1, 2015. PSCo requests that the language in Section II, Conditions 9.3.3 through 9.3.5 be modified to be consistent with language in other recently issued permits that define when a second opacity observation is required. Per the requirements of Colorado Air Quality Control Commission Regulation No. 3, Part C.X.D, attached is a copy of the Fort St. Vrain Station Title V permit conditions that will require changes resulting from this modification request. By way of my signature below as the responsible official for this facility, I certify that the proposed modifications meet the criteria of a minor permit modification and request that the procedures set forth in Colorado Air Quality Control Commission Regulation No. 3, Part C.X be used to process this minor permit modification. If you have any questions concerning this request, please contact Josh Korth of Xcel Energy's Environmental Services staff, at 303-294-2187 orjoshua.r.korth@xcelenergy.com. Sincerely, • (2----71:3 Mark Fox General Manager— Power Generation, Colorado att: As Stated cc: M. Maes— Director, Fort St. Vrain Station J. Arellano— Environmental Analyst, Fort St. Vrain Station G. Magno—Manager, Air Quality Compliance Proposed Revisions to Permit 97OPWE180 9.3.3 An engine startup period of less than 60 minutes shall not require a startup opacity observation. If the engine startup period is greater than 60 minutes, one opaeity observation shall be made for eaeh conseeutive 4 hour period of startup during daylight hours. In addition, a reeord shall be kept of the date and time the engine started and when it was shutdown. As specified in Condition 9.1.7, engine startup shall not exceed 30 minutes. An engine startup period of less than 30 minutes shall not require an opacity observation to monitor compliance with the opacity limit in Condition 9.3.2. A record shall be kept of the date and time each engine was started and when it was shutdown. 9.3.4 Continued operation of the engine after the completion of the startup period shall require monthly opacity observations. If the startup and operation of the engine lasts less than a total of 4 hours from engine start to engine stop, in any one day no opacity observations arc required for that day. (a)An opacity observation shall be conducted annually (calendar year period) on each engine to monitor compliance with the opacity limit in Condition 9.3.1. Annual opacity observations for shall be separated by a period of four (4) months. (b)If the engine is operated more than 250 hours in any calendar year period, a second opacity observation shall be conducted. If two opacity readings are conducted in the annual (calendar year) period, such readings shall be conducted at least thirty days apart. 9.3.5 If no opacity observations arc made pursuant to Coaditiens 9.3.3 and 9.3.4 above, then an opacity observation shall be condueted annually. If the engine is not operated during the annual (calendar year) period, then no opacity observation is required. 9.3.6 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. 166 Xcel Energy= .. Environmental Services 1800 Larimer Street,Suite 1300 Denver,CO 80202 December 17, 2014 Ms. Jacqueline Joyce Colorado Department of Public Health&Environment Air Pollution Control Division,APCD-SS-B1 Operating Permit Unit 4300 Cherry Creek Drive South Denver, CO 80246-1530 Re: Fort St.Vrain Station Permit#97OPWE180 Title V Operating Permit Renewal Application Dear Ms. Joyce: In accordance with the requirements of Colorado Air Quality Control Commission Regulation No. 3, Part C, Section III.B.6, Public Service Company of Colorado(PSCo) is hereby submitting a renewal application for the Public Service Company of Colorado(PSCo)Fort St. Vrain Station Title V Operating Permit#97OPWE180. This submittal package includes: • This cover letter signed by the Company's Responsible Official which contains, • Identification of the facility's status for greenhouse(GHG) emissions • Non-applicability confirmation of the Federal Compliance Assurance Monitoring(CAM)provisions, and • Summary of changes being requested during this renewal process • Attachment of the required Colorado operating permit application forms (Forms 2000- 100 and 2000-800) • Attachment of the Acid Rain Program Permit Application Greenhouse Gas Status Assessment An evaluation of the emission sources at the Fort St. Vrain Station facility was done to assess the potential to emit(PTE)for greenhouse gas(GHG)emissions. Based on the analysis,Fort St. Vrain is major for GHG emissions. The evaluation was based on Acid Rain Program data and calculations according to the requirements of Title 40 Part 98 Subpart C and D. Compliance Assurance Monitoring Review Each emission source at the Fort St.Vrain Station facility was evaluated for CAM applicability as part of the May 18, 2009 permit renewal application. The evaluation during that renewal process determined that there were no sources at Fort St. Vrain which were subject to CAM requirements. No new sources or additional control devices have been installed since that application was submitted so the determination from that evaluation remains appropriate. Requested Changes PSCo requests that the language in Section II, Conditions 9.3.3 through 9.3.5 be modified to be consistent with language in other recently modified permits to define when a second opacity observation is required. The proposed revisions are being submitted as a minor modification request along with this renewal application. PSCo requests that Section II, Condition 5.3.3.1 be updated with the language that is similar in the Blue Spruce Energy Center permit, 04OPAD270, Section 2, Condition 2.1.2.1 to clarify CO monitor CGA frequency. The revised language would state: The quality assurance/quality control plan for the CO monitors shall be prepared in accordance with the applicable requirements in 40 CFR Part 60,Appendix F, except that gas cylinder audit(CGA)testing is not required during quarters with less than 168 hours of operating time for a monitored stack. PSCo requests that an additional sentence be added at the end of Section II, Condition 2.5.1.7. That addition would read, "Testing and tuning of the Selective Catalytic Reduction system shall also be allowed under this condition and the hours included in the annual total." PSCo requests that information from the 2014 particulate matter compliance tests be included in Section II, Conditions 1.6.4.1 and 1.12. Testing results for each of the stacks are as follows: Unit 2 Bypass: 5/2/2014 -PM=0.004, PM10=0.004 Unit 2 HRSG: 3/28/2014-PM= 0.002, PM10=0.002 Unit 3 Bypass: 3/26/2014-PM= 0.003,PM10=0.003 Unit 3 HRSG: 3/27/2014-PM=0.002, PM10=0.002 PSCo requests that Section II, Conditions 1.2.1.10, 1.3.1.10, 2.5.1.10, 2.6.1.10, 8.2.1 (the 2nd to last paragraph)be removed. These are requirements from 2011 related to reprogramming the data acquisition system for revised compliance calculations. All of these changes have been implemented in the data acquisition system to split the hours into startup/shutdown and mode 6 averages. PSCo is requesting updates to the Responsible Official and Facility Contact Person listed for this facility. This change in information has been reflected on Form 2000-100 that is included with this submittal. Responsible Official Name: Mark Fox Title: General Manager—Power Generation, Colorado Phone: (303)425-3779 Facility Contact Person Name: Gary Magno Title: Manager, Environmental Services—Air Quality Compliance Phone: (303)294-2177 If you have any questions concerning the attached permit application forms or information provided, please contact Josh Korth of Xcel Energy's Environmental Services staff, at joshua.r.korth@xcelenergy.com or(303)294-2187. Sincerely, 71:11 Mark Fox General Manager—Power Generation, Colorado att: As Stated cc: M. Maes—Director, Fort St. Vrain Station J. Arellano—Environmental Analyst, Fort St. Vrain Station G. Magno—Manager, Air Quality Compliance Operating Permit Application FACILITY IDENTIFICATION FORM 2000-100 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name and Name Fort St.Vrain Station mailing address Street or Route 16805 County Road 19 'h City, State,Zip Code Platteville, CO 80651 2. Facility location Street Address 16805 County Road 19 'h (No P.O.Box) City, County,Zip Code Platteville, CO 80651 3. Parent corporation Name Public Service Company of Colorado Street or Route 1800 Larimer Street, Suite 1300 City, State,Zip Code Denver,CO 80802 Country(if not U.S.) 4. Responsible Name Mark Fox official Title General Manager—Power Generation, Colorado Telephone (303)425-3779 5. Permit contact person Name Gary Magno Title Manager,Air Quality Compliance (If Different than 4) Telephone (303)294-2177 6. Facility SIC code: 4911 7. Facility identification code: CO 1230023 8. Federal Tax I.D.Number: 84-6015506 9. Primary activity of the operating establishment: Combustion Gas Turbine Electric Generating Station 10. Type of operating permit 0 New 0 Modified [] Renewal 11. Is the facility located in a"nonattainment" area: E Yes O No "Yes", check the designated"non-attainment" Ifb ❑ Carbon Monoxide E Ozone ❑ PM10 0 Other(specify) 12. List all(Federal and State)air pollution permits(including grandfathered units),plan approvals and exemptions issued to this facility.List the number,date and what unit/process is covered by each permit. For a Modified Operating Permit, do not complete this item. Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 Colorado Department of Health 09-94 Air Pollution Control Division Facility Name: Fort St Vrain Station Facility Identification Code: CO 1230023 L ADMINISTRATION This application contains the following forms: E Form 2000-100,Facility Identification ❑ Form 2000-101,Facility Plot Plan ❑ Forms 2000-102,-102A,and-102B,Source and Site Descriptions II. EMISSIONS SOURCE Total Number DESCRIPTION of This Form This application contains the following forms O Form 2000-200,Stack Identification (one form for each facility boiler.orintine El Form 2000-300,Boiler or Furnace Operation ❑ Form 2000-301,Storage Tanks ❑ Form 2000-302,Internal Combustion Engine ❑ Form 2000-303,Incineration O Form 2000-304,Printing Operations ❑ Form 2000-305,Painting and Coating Operations O 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 El Form 2000-401,Condensers El Form 2000-402,Adsorbers ❑ Form 2000-403,Catalytic or Thermal Oxidation ❑ Form 2000-404,Cyclones/Settling Chambers El Form 2000-405,Electrostatic Precipitators El Form 2000-406,Wet Collection Systems ❑ Form 2000-407,Baghouses/Fabric Filters IV. COMPLIANCE Total Number DEMONSTRATION of This Form This application contains the following forms ❑ Form 2000-500,Compliance Certification-Monitoring and Reporting (one for each facility boiler.orintine operation. ❑ Form 2000-501,Continuous Emission Monitoring ❑ Form 2000-502,Periodic Emission Monitoring Using Portable Monitors ❑ Form 2000-503,Control System Parameters or Operation Parameters of a Process ❑ Form 2000-504,Monitoring Maintenance Procedures O Form 2000-505,Stack Testing ❑ Form 2000-506,Fuel Sampling and Analysis ❑ Form 2000-507,Recordkeeping ❑ Form 2000-508,Other Methods 2 . � Number V. EMISSION SUMMARY AND of Total N umber COMPLIANCE CERTIFICATION is Form This application contains the following forms 0 Form 2000-600,Emission Unit Hazardous Air Pollutants quantifying emissions,certifying compliance with applicable requirements,and developing a compliance plan ❑ Form 2000-601,Emission Unit Criteria Air Pollutants ❑ Form 2000-602,Facility Hazardous Air Pollutants ❑ Form 2000-603,Facility Criteria Air Pollutants ❑ Form 2000-604,Applicable Requirements and Status of Emission Unit ❑ Form 2000-605,Permit Shield Protection Identification 0 Form 2000-606,Emission Unit Compliance Plan-Commitments and Schedule ❑ Form 2000-607,Plant-Wide Applicable Requirements 0 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) Ex I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. 0 I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements,except for the following emissions unit(s): (list all non-complying units) WARNING: Any person who knowingly,as defined in § 18-1-501(6),C.R.S.,makes any false material statement,representation, or certification in,or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of§25-7 122.1,C.R.S. Printed or Typed Name Title Mark Fox General Manager—Power Generation,Colorado Signature ,� , 7 Date Signed 3 Operating Permit Application CERTIFICATION FOR STATE-ONLY CONDITIONS FORM 2000-800 Colorado Department of Health 09-94 Air Pollution Control Division Facility Name: Fort St. Vrain Station Facility Identification Code: CO 1230023 VI. SIGNATURE OF RESPONSIBLE OFFICIAL-STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and,based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this application are true,accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE-ONLY CONDITIONS(check one box only) 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§25-7 122.1,C.R.S. Printed or Typed Name Title Mark Fox General Manager—Power Generation,Colorado Signature Date Signed SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B 1 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 II 4 United States Environmental Protection Agency OMB No.2060-0258 EPA Acid Rain Program Acid Rain Permit Application For more information,see instructions and 40 CFR 72.30 and 72.31. This submission is: • view • Tevised •Xvor Acid Rain permit renewal STEP 1 Identify the facility name, Fort St. Vrain Station CO 6112 State, and plant(ORIS) Facility(Source)Name State Plant Code code. STEP 2 a b Enter the unit ID# very affected Unit ID# Unit Will Hold Allowances for e the affected in Accordance with 40 CFR 72.9(c)(1) unit v source in column "a." 2 Yes 3 Yes 4 Yes 5 Yes 6 Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes EPA Form 7610-16(rev.07-08) Fort St . Vrain Station Acid Rain - Page 2 Facility(Source)Name(from STEP 1) Permit Requirements STEP 3 (1)The designated representative of each affected source and each affected unit at the source shall: Read the standard (i) Submit a complete Acid Rain permit application (including a compliance requirements. plan) under 40 CFR part 72 in accordance with the deadlines specified in 40 CFR 72.30; and (ii) Submit in a timely manner any supplemental information that the permitting authority determines is necessary in order to review an Acid Rain permit application and issue or deny an Acid Rain permit; (2)The owners and operators of each affected source and each affected unit at the source shall: (i) Operate the unit in compliance with a complete Acid Rain permit application or a superseding Acid Rain permit issued by the permitting authority; and (ii) Have an Acid Rain Permit. Monitoring Requirements (1) The owners and operators and, to the extent applicable, designated representative of each affected source and each affected unit at the source shall comply with the monitoring requirements as provided in 40 CFR part 75. (2) The emissions measurements recorded and reported in accordance with 40 CFR part 75 shall be used to determine compliance by the source or unit, as appropriate, with the Acid Rain emissions limitations and emissions reduction requirements for sulfur dioxide and nitrogen oxides under the Acid Rain Program. (3) The requirements of 40 CFR part 75 shall not affect the responsibility of the owners and operators to monitor emissions of other pollutants or other emissions characteristics at the unit under other applicable requirements of the Act and other provisions of the operating permit for the source. Sulfur Dioxide Requirements (1) The owners and operators of each source and each affected unit at the source shall: (i) Hold allowances, as of the allowance transfer deadline, in the source's compliance account (after deductions under 40 CFR 73.34(c)), not less than the total annual emissions of sulfur dioxide for the previous calendar year from the affected units at the source; and (ii) Comply with the applicable Acid Rain emissions limitations for sulfur dioxide. (2) Each ton of sulfur dioxide emitted in excess of the Acid Rain emissions limitations for sulfur dioxide shall constitute a separate violation of the Act. (3) An affected unit shall be subject to the requirements under paragraph (1) of the sulfur dioxide requirements as follows: (i) Starting January 1, 2000, an affected unit under 40 CFR 72.6(a)(2); or (ii) Starting on the later of January 1, 2000 or the deadline for monitor certification under 40 CFR part 75, an affected unit under 40 CFR 72.6(a)(3). EPA Form 7610-16(rev.07-08) Fort St . Vrain Station Acid Rain - Page 3 Facility(Source)Name(from STEP 1) Sulfur Dioxide Requirements, Cont'd. STEP 3, Cont'd. Allowance Allowances shall be held in, deducted from, or transferred among Allowance Tracking System accounts in accordance with the Acid Rain Program. (5) An allowance shall not be deducted in order to comply with the requirements under paragraph (1) of the sulfur dioxide requirements prior to the calendar year for which the allowance was allocated. (6)An allowance allocated by the Administrator under the Acid Rain Program is a limited authorization to emit sulfur dioxide in accordance with the Acid Rain Program. No provision of the Acid Rain Program, the Acid Rain permit application, the Acid Rain permit, or an exemption under 40 CFR 72.7 or 72.8 and no provision of law shall be construed to limit the authority of the United States to terminate or limit such authorization. (7)An allowance allocated by the Administrator under the Acid Rain Program does not constitute a property right. Nitrogen Oxides Requirements The owners and operators of the source and each affected unit at the source shall comply with the applicable Acid Rain emissions limitation for nitrogen oxides. Excess Emissions Requirements (1) The designated representative of an affected source that has excess emissions in any calendar year shall submit a proposed offset plan, as required under 40 CFR part 77. (2)The owners and operators of an affected source that has excess emissions in any calendar year shall: (i) Pay without demand the penalty required, and pay upon demand the interest on that penalty, as required by 40 CFR part 77; and (ii) Comply with the terms of an approved offset plan, as required by 40 CFR part 77. Recordkeepinq and Reporting Requirements (1) Unless otherwise provided, the owners and operators of the source and each affected unit at the source shall keep on site at the source each of the following documents for a period of 5 years from the date the document is created. This period may be extended for cause, at any time prior to the end of 5 years, in writing by the Administrator or permitting authority: (i)The certificate of representation for the designated representative for the source and each affected unit at the source and all documents that demonstrate the truth of the statements in the certificate of representation, in accordance with 40 CFR 72.24; provided that the certificate and documents shall be retained on site at the source beyond such 5-year period until such documents are superseded because of the submission of a new certificate of representation changing the designated representative; EPA Form 7610-16(rev.07-08) Fort St . Vrain Station Acid Rain - Page 4 Facility(Source)Name(from STEP 1) Recordkeepinq and Reporting Requirements, Cont'd. STEP 3, 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 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 EPA Form 7610-16(rev.07-08) Fort St . Vrain Station Acid Rain - Page 5 Facility(Source)Name(from STEP 1) Effect on Other Authorities, Cont'd. to applicable National Ambient Air Quality Standards or State Implementation STEP 3, Cont'd. 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. Certification STEP 4 I am authorized to make this submission on behalf of the owners and Read the operators of the affected source or affected units for which the submission is certification made. I certify under penalty of law that I have personally examined, and am statement, familiar with, the statements and information submitted in this document and sign, and date. all its attachments. Based on my inquiry of those individuals with primary responsibility for obtaining the information, I certify that the statements and information are to the best of my knowledge and belief true, accurate, and complete. I am aware that there are significant penalties for submitting false statements and information or omitting required statements and information, including the possibility of fine or imprisonment. Mark Fox Designated Representative Name d Signature )11L✓ , Date 2—it --1 1+ EPA Form 7610-16(rev.07-08) EPAInstructions for the Acid Rain Program Permit Application The Acid Rain Program requires the designated representative to submit an Acid Rain permit application for each source with an affected unit. A complete Certificate of Representation must be received by EPA before the permit application is submitted to the title V permitting authority. A complete Acid Rain permit application, once submitted, is binding on the owners and operators of the affected source and is enforceable in the absence of a permit until the title V permitting authority either issues a permit to the source or disapproves the application. Please type or print. If assistance is needed, contact the title V permitting authority. STEP 1 A Plant Code is a 4 or 5 digit number assigned by the Department of Energy's (DOE) Energy Information Administration(EIA)to facilities that generate electricity. For older facilities,"Plant Code"is synonymous with"ORISPL"and"Facility"codes. If the facility generates electricity but no Plant Code has been assigned, or if there is uncertainty regarding what the Plant Code is, contact EIA at(202) 586-4325 or(202)586-2402. STEP 2 In column "a,"identify each unit at the facility by providing the appropriate unit identification number, consistent with the identifiers used in the Certificate of Representation and with submissions made to DOE and/or EIA. Do not list duct burners. For new units without identification numbers,owners and operators must assign identifiers consistent with EIA and DOE requirements. Each Acid Rain Program submission that includes the unit identification number(s) (e.g., Acid Rain permit applications, monitoring plans,quarterly reports,etc.)should reference those unit identification numbers in exactly the same way that they are referenced on the Certificate of Representation. Submission Deadlines For new units, an initial Acid Rain permit application must be submitted to the title V permitting authority 24 months before the date the unit commences operation. Acid Rain permit renewal applications must be submitted at least 6 months in advance of the expiration of the acid rain portion of a title V permit, or such longer time as provided for under the title V permitting authority's operating permits regulation. Submission Instructions Submit this form to the appropriate title V permitting authority. If you have questions regarding this form,contact your local, State, or EPA Regional Acid Rain contact, or call EPA's Acid Rain Hotline at(202)343-9620. Paperwork Burden Estimate The public reporting and record keeping burden for this collection of information is estimated to average 8 hours per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain,or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information;adjust the existing ways to comply with any previously applicable instructions and requirements;train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor,and a person is not required to respond to,a collection of information unless it displays a currently valid OMB control number. Send comments on the Agency's need for this information,the accuracy of the provided burden estimates,and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques to the Director, Collection Strategies Division, U.S. Environmental Protection Agency(2822T), 1200 Pennsylvania Ave.,NW.,Washington,D.C.20460. Include the OMB control number in any correspondence. Do not send the completed form to this address. Hello