STATE OF COLORADO CONSTRUCTION PERMIT. Black Hills Electric Generation, LLC

Transcription

1 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVI AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) PERMIT NO: STATE OF COLORADO CONSTRUCTION PERMIT 09PB0591 DATE ISSUED: JULY 22, 2010 ISSUED TO: Black Hills Electric Generation, LLC NT THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Nominal 480 megawatt (MW) gross combustion turbine power plant, known as the Pueblo Airport Generating Station (PAGS), located at Section 11, T20S R54W in Pueblo County, Colorado. Colorado PUC E-Filings System THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: The facility equipment covered under this permit includes three (3) General Electric (GE) LMS 100, simple cycle natural gas-fired combustion turbine generators (CTGs), four (4) GE, LM6000, combined cycle natural gas-fired CTGs with four (4) HRSGs, as listed by points AIRS identification numbers below. The Statement of Basis for air pollutant emissions, the Details of Equipment descriptions, Specific Unit Process Rates, Control Devices and other facility Activities covered under this facility-wide permit are as listed in Attachment A. AIRS ID No. Table 1 Equipment Listing By Point Identification Number Points Description 001 One (1) GE, LMS100PA, natural gas-fired, simple cycle CTG rated at MMBtu per hour,based on HHV (CT01) 002 One (1) GE, LMS100PA, natural gas-fired, simple cycle CTG rated at MMBtu per hour,based on HHV (CT02) 003 One (1) GE, LMS100PA, natural gas-fired, simple cycle CTG rated at MMBtu per hour,based on HHV (CT03) 004 One (1) GE, LMS6000 PF, natural gas-fired, combined cycle CTG, rated at 373 MMBtu per hour, based on HHV and one (1) HRSG with no Duct Burners (CT04) 005 One (1) GE, LMS6000 PF, natural gas-fired, combined cycle CTG, rated at 373 MMBtu per hour, based on HHV and one (1) HRSG with no Duct Burners (CT05) 006 One (1) GE, LMS6000 PF, natural gas-fired, combined cycle CTG, rated at 373 MMBtu per hour, based on HHV and one (1) HRSG with no Duct Burners (CT06) 007 One (1) GE, LMS6000 PF, natural gas-fired, combined cycle CTG, rated at 373 MMBtu per hour, based on HHV and one (1) HRSG with no Duct Burners (CT07) Facility AIRS ID: 101/1160 Page 1 of 18

2 THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. ( et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: 1. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Opacity shall be measured by EPA Method 9. (Reference: Regu lation 1, Section II.A.1.& 4.) 2. The permit number shall be marked on the subject equipment for ease of identification. (Reference: Regulation No. 3, Part B, Ill. E.) (State only enforceable) 3. If multiple provisions are applicable, the most stringent provision shall apply (For example, BACT is more stringent than NSPS. Therefore, if BACT requirements are met, it will be presumed that NSPS requirements for the same pollutants have been met as well). 4. This source shall be limited to a maximum process and fuel consumption rates as listed in Attachment A and all other activities, operational rates and numbers of equipment as stated in the application. Monthly records of the actual fuel consumption rates shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regu lation No. 3, Part B, II.A.4) Compliance with the annual limits shall be determined on a rolling (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. Monthly records of the actual emissions shall be maintained by the applicant and made available to the Division for inspection upon request. The heat input and fuel consumption for the turbines (AIRS emission points 001 through 007) shall be monitored and recorded monthly using the data acquisition and handling systems (DAHS) for the continuous emission monitoring systems (CEMs) required by Condition No. 12 below. 5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis): (Reference: Regulation No. 3, Part B, II.A.4) Particulate Matter < 10 IJm (PM 10 ) : tons per year Particulate Matter (TSP): tons per year Sulfur Dioxide (S0 2 ): 17.5 tons per year Nitrogen Oxides (NOx): tons per year Volatile Organic Compounds (VOC): 70.0 tons per year Carbon Monoxide (CO): tons per year Compliance with the annual limits shall be determined on a rolling (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. Monthly records of the actual emissions shall be maintained by the applicant and made available to the Division for inspection upon request. NOx and CO emissions from the turbines (AIRs emission points 001 through 007) shall be determined using the CEMs required in Condition No. 12 below. Other emissions from these units shall be determined by the appropriate emission factors listed under "Note to permit holder" and the actual fuel usage. Facility AIRS ID: 101/1160 Page 2 of 18

3 6. This emission source is subject to the Prevention of Significant Deterioration (PSD) provisions and Best Available Control Technology (BACT) shall be applied for the control of emissions of: Particulate Matter less than 10 micrometers aerodynamic diameter (PM 10 ), Total Suspended Particulate (TSP), Nitrogen Oxides (NOx), Volatile Organic Compounds (VOC), and Carbon Monoxide (CO). The following air pollution control strategies and emission limits as shown in Tables 6.1 through 6.3 below have been determined as BACT for this facility, and the applicable limits shall be complied with at all times: AIRS POINT ID #s: 001, 002 & 003: BACT for each of the three (3) GE, LMS1 OOPA, natural gas-fired, simple cycle CTGs CT01, CT02 and CT03 shall be as follows: Table 6.1.A- LMS100PA Steady State Stack Emissions: Air Firing Control Technology Short Term Emission Limits (Per Pollutant Configuration (BACT Applied) Stack) Pipeline TSP I PM 10 quality natural Good combustor design gas (PONG) 6.6 lbs/hour, based on the average of three test runs Good combustor design, NOx PONG Water Injection and Selective Catalytic Reduction (SCR) voc co PONG PONG Good Combustion Control and Catalytic Oxidation (CatOx) Good Combustion Control and Catalytic Oxidation (CatOx) % Oxygen (0 2 ) and at 1-hour average 15.5 lbs/hour, 30-day rolling average 2.5 ppmvd@ 15% Oxygen, based on the average of three test runs % Oxygen and at a 1-hour average 19.8 lbs/hour, 30-day rolling average Table 6.1.B- LMS 1 OOPA Startup/Shutdown Stack Emissions: Startup and Shutdown emissions of air pollutants from each of the three (3) simple cycle combustion turbines CT01, CT02 & CT03 shall not exceed the following limits during startup and shutdown events ("Event" is defined as the period between the beginning of startup to the end of startup, or the beginning of shutdown to the end of shutdown, as described in Table 6.4 below): Air Pollutant Firing Configuration Control Technology Emission Limits (lbs/event) Startup Limits Shutdown Limits NOx PONG Good combustor design 12.0 lbs/event 18.0 lbs/event co PONG Good combustor design 28.0 lbs/event 36.0 lbs/event Paae 3 of 18

4 AIRS POINT ID #s: & 007 BACT for each of the four (4) GE, LM 6000 PF, natural gas-fired, combined cycle CTGs, CT04, CT05, CT06, and CTO?, and the associated, non-duct firing HRSG shall be as follows: Table 6.2.A- LM 6000 PF Steady State Stack Emissions: Air Firing Control Technology Short Term Emission Limits (Per Pollutants Configuration (BACT Applied) Unit) TSP I PM10 PONG Good Combustor design Dry Low NOx (DLN) NOx PONG Combustor and Selective Catalytic Reduction (SCR) 4.3 lb/hr, based on the average of three test runs 3.0 ppmvd@ 15% Oxygen and at 1-hour average 4.1 lbs/hour 30-day rolling average voc PONG Good Combustion Control and Catalytic Oxidation 4.0 ppmvd@ 15% Oxygen, based on the average of three test runs co PONG Good Combustion Control and Catalytic Oxidation % Oxygen and at a 1-hour average 3.3 lbs/hour 30-day rolling average Table 6.2.B- LM 6000 PF Startup/Shutdown Stack Emissions: Startup and Shutdown emissions of air pollutants from each of the four (4) combined cycle combustion turbines CT04, CT05, CT06 & CT07 shall not exceed the following limits during startup and shutdown events: Air Pollutant Firing Configuration Control Technology Startup Limits Emission Limits (Lbs/Event) Shutdown Limits NOx PONG Good combustor design 30.0 Lbs/Event 5.0 Lbs/Event co PONG Good combustor design, CatOx Lbs/Event 15.0 Lbs/Event Paae 4 of 18

5 Table 6.3: Definitions Startup Beginning: Begins when the combustion starts as detected by the Fireye (i.e. the turbine flame detection system). or The restart of a Unit following a Unit trip or an aborted startup constitutes a new startup period. End of Startup: The LMS 100 combustion turbine startup period ends when 30 minutes has elapsed, or The LM 6000 Combustion turbine startup period ends when 95 minutes has elapsed for a hot or warm startup, or 220 minutes has elapsed for a cold startup. Startup Period: Shutdown Beginning: End of Shutdown: Shutdown Period: Steady State: The time that elapsed between the beginning and end of startup as defined above, subject to conditions listed in Item 7 below for a LMS 100 combustion turbine, and Item 8 for LM 6000 combined cycle combustion turbine operation. Begins when the operator initiates the shutdown of the simple cycle or combined cycle system The shutdown period ends when all combustion has ceased (i.e. fuel is no longer being introduced in that combustion turbine). Is the time that elapsed between the beginning and end of shutdown as defined above, and is of duration of 30 minutes. Normal combustion turbine system operation, not including those periods of startup, shutdown, testing/tuning, or malfunction. Trip or Aborted Startup: In the event of a Unit trip or an aborted startup, shutdown begins when the combustion turbine ceases steady state operation. Cold Start: Warm Start: Hot Start: Is the initial startup or any startup that begins when the combined cycle turbine has been shutdown for greater than 48 hours. Is any startup that begins when the combined cycle turbine has been shutdown for greater than 8 hours but less than 48 hours. Is any startup that begins within 8 hours of the combined cycle turbine has been shutdown. 7. Startup and shutdown events for all four of the LM 6000 combined cycle units shall be limited to the following number of events, event durations and types: a. Cold Startup shall not exceed 100 events per year at 220 minutes per event, b. Hot and Warm Startups shall not exceed 1,460 events per year at 95 minutes per event, c. Shutdown shall not exceed 1,560 events per year at 30 minutes per event. Paae 5 of 18

6 8. Startup and shutdown events for all of the LMS 100 simple cycle units shall be limited to a total of 2,190 startup and 2,190 shutdown events per year. The maximum LMS 100 event duration shall be limited to the following : a. Startup duration shall not exceed 30 minutes per event. 9. The permit holder shall maintain records of startups and shutdowns by type, number and durations; and keep a compliance record on site for Division review. (Reference: Regulation No. 3, Part B, Section II.A.4). 10. At all times, all the combustion turbines shall demonstrate continuous compliance with Condition No. 6 limits above using NOx and CO continuous emission monitors (GEMs) that meet the following requirements: 40 CFR, Part 60, Appendix B, Performance Specification 4 or 4A, and 40 CFR, Part 60, Appendix F, Quality Assurance Procedures. 11. Compliance with the NOx and CO BACT limitations shall be monitored as follows: During the Steady State operations, compliance with the NOx and CO BACT emission limitation in Condition No. 6 above shall be monitored using the GEMs required in Condition No. 12 below. Except as provided for below, all the GEMs concentration (ppmvd) data shall, at the end of each clock hour, be summarized to generate the average NOx and CO concentrations. For each averaging and rolling period, the average calculated concentrations shall be compared to the limitations in Condition No. 6 above. During the Startup and Shutdown operations, compliance with the NOx and CO BACT emission limitations in Condition 6 above shall be monitored using the GEMs required in Condition No. 12 below. All mass emissions (lbs) data within the startup or shutdown period shall be summed together to generate the total NOx and CO emissions for a given startup or shutdown period. The total NOx and CO emissions for each startup or shutdown period shall be compared to the limitation in Condition No. 6 above. Minute measurements (ppmvd at 15% 0 2) calculated with diluent concentrations greater than 19.0 percent 0 2 can be excluded from the startup and/or shutdown duration averaged value. 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 (ppmvd) data within that clock hour shall be averaged together to generate the average NOx and CO concentrations. That average concentrations shall be included in the averaging period and compared to the limitation in Condition No. 6 above. During periods of combustion tuning and testing emissions of CO and NOx shall not exceed 100 ppmvd at 15% 0 2, on a 1-hour average. Use of this CO and NOx emission limit for pu rposes of combustion tuning and testing shall not exceed 210 hours in any calendar year for all seven turbines 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. As a part of compliance with Particulate Matter (TSP and PM 10 ) BACT limitations, the following shall apply: a. Use of pipeline quality natural gas (as defined by Acid Rain Provisions, 40 CFR Part 72). b. The owner or the operator shall maintain records demonstrating that the natural gas burned meets the definition of pipeline quality natural gas as defined in 40 CFR Part 72. Specifically, the owner or the operator shall demonstrate that the natural gas burned has total sulfur content less than 0.5 grains/100 SCF. The demonstration shall be made using any of the methods identified in 40 CFR Part 75 Appendix D, Section These records shall be made available to the Division upon request. Paae 6 of 18

7 12. Continuous emission monitoring systems (CEMs) shall be installed on the turbine exhaust stacks (AIRs emission points 001 through 007), calibrated, and operated to determine and record the following: a. Concentration of NOx, ppmvd, corrected to 15% 0 2, 1-hour average; b. Emissions of Oxides of Nitrogen, pounds per hour, 30-day rolling average; c. Concentration of Carbon Monoxide, ppmvd hourly average, corrected to 15% 0 2, 1-hour average; d. Emissions of Carbon Monoxide, pounds per hour, 30-day rolling average; e. Concentration of Oxygen (0 2 ), percent hourly average; f. Operating mode- startup, shutdown, combustion tuning/testing or standard operation; g. Load in gross MW, at which the turbine is operating; and h. Fuel flow rate, hundreds of standard cubic feet per hour (hscf/hour), and Heat Input, MMBtu/hour and total MMBtu/year. The CEMs shall provide emission data to estimate the necessary hourly, 30-day ro lling average, monthly and annual (12-month rolling basis) emission rates of NOx and CO to be used in determining compliance with NOx and CO emission limits (Condition No. 5 above) and NOx and CO BACT limits (Condition No. 6 above). When quality assured data are not available from the pounds per hour CEMs, the missing data substitution procedures set forth in 40 CFR Part 75, Subpart D shall be followed. Although CO emissions are not specifically referenced in the Subpart D procedures, the CEMs data acquisition system shall be programmed to substitute CO emissions using the same procedures specified for NOx. This missing data substitution requirement will only be used for determining compliance with the 12-month rolling mass emission limits. Compliance with shorter term limitations of concentration and emission rates shall not be based upon substituted data. Except where noted below, the fuel flow monitor and NOx and diluent CEMs shall meet the applicable requirements in 40 CFR Part 75, the performance specification requirements in 40 CFR Part 75 Appendix A, the quality assurance quality control requirements in 40 CFR Part 75 Appendix 8 and D, the conversion procedures of Appendix F and the traceability products of Appendix H. In addition for the initial certification, NOx monitor relative accuracy (RA) testing will be performed in 15% 0 2 and lbs/hr measurement units, and will be performed according to 40 CFR Part 60, Appendix B, Specifications 2 and 6. The QA/QC testing frequency of the fuel flow monitor, NOx and diluent CEMs will be in accordance with Part 75, Appendix B and D Except where noted below, the CO CEMs shall meet the applicable requirements in 40 CFR Part 60 Subpart A 60.13, the performance specification requirements in 40 CFR Part 60 Appendix 8 and the quality assurance/quality control requirements in 40 CFR Part 60 Appendix F, except that cylinder gas audit (CGA) testing will be performed according to 40 CFR Part 75, Appendix B schedule requirements for a primary monitor. CO CEMS relative accuracy (RA) testing will be performed in 15% 0 2 measurement units, and will be performed according to 40 CFR Part 60, Appendix 8, Performance Specifications 4A. In addition for the initial certification, the CO monitor relative accuracy (RA) testing will be performed in lbs/hr measurement units, and will be performed according to 40 CFR Part 60, Appendix B, Performance Specifications 4A and 6. RA testing will be performed every four operating quarters according to 40 CFR Part 75, Appendix B requirements for a primary monitor. Paae 7 of 18

8 NOx and 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). When determining compliance with the NOx startup and shutdown BACT limit in Condition No. 6 above, minute measurements (ppmvd at 15% 0 2 ) calculated with diluent concentrations greater than 19.0 percent 0 2 can be excluded from the startup or shutdown duration averaged value. 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. The initial RA testing required by this condition shall occur within 180 days after commencement of operation of each source listed in Table 1 above. 13. At all times, various emission sources as identified below are subject to Regulation No. 6-Standards of Performance for New Stationary Sources, including, but not limited to, the following: Part A-Federal Register Regulations (Chapter 1, Title 40 CFR Part 60) Adopted By Reference: Table 13.1: NSPS Subpart KKKK NSPS Subpart KKKK Standards of Performance for Stationary Combustion Turbines Each of the three (3) simple cycle combustion turbines (AIRS Points 001 through 003) and four (4) combined cycle combustion turbines (AIRS Points 004 through 007) is subject to NSPS Subpart KKKK ( (a)) The turbines are exempt from NSPS Subpart GG, and the HRSG units are exempted from NSPS Subparts Da, Db, and De( (b)) Future changes in NSPS Subpart KKKK shall supersede the specific provisions of this permit and the applicant or operator shall comply with only the latest NSPS Subpart KKKK provisions as applicable. Pollutants Standards /Requirements/ Citation(s) Emission Limits (Table 1 to this Subpart) Compliance Requirements Concentration of NOx in the turbines' exhaust shall not exceed: 25 15% 0 2 or 1.2 lb/mwh of useful output per , (a) and (b) For unit sources 001, 002 and 003 compliance with the NOx emission limits shall be monitored using either: (a) a continuous emission monitoring system and record the fuel consumption and the ratio of water to fuel being fired in the turbine or a. NOx (b) and a NOx.continuous emission monitoring system. For unit sources 004 through 007 compliance with the NOx emission limits shall be monitored using either: (a) a routine performance test or (b)(2) a continuous parameter monitoring system or (b)(1) a NOx CEMS that meets the requirements of (b) and if demonstrating compliance with a NOx CEMS, owner or operator shall install, certify, maintain, and operate a continuous emission monitoring system (CEMS) consisting of a NOx monitor and a diluents gas Paae 8 of 18

9 (0 2 or C0 2 ) monitor and, if demonstrating compliance with an output-based standard, install, calibrate, maintain and operate a fuel flow meter to continuously measure the heat input to the affected unit. The NOx CEMS must meet the requirements of Emission Limits You must not cause to be discharged into the atmosphere from the subject stationary combustion turbine any gases which contain S0 2 in excess of 0.90 pounds per megawatt-hour (lb/mwh} gross output, per and (a)(1) or You must not burn in the subject stationary combustion turbine any fuel wh ich contains total potential sulfur emissions in excess of lb S0 2 per MMBtu heat input. (Each fuel must meet this requirement) per (a)(2) b. so2 Compliance Compliance with the fuel sulfur content limit shall be presumed when burning Requirements pipeline quality natural gas. The methods specified in 40 CFR Part 60 Subpart KKKK shall be used to demonstrate that the natural gas meets the definition of pipeline quality natural gas by either (a) purchase contract or tariff documentation, or (b).monitor total sulfur content of combusted fuel or demonstrate that the potential to emit S0 2 is< lb S0 2 per MMBtu per 40CFR75 Appendix D Section or c. General Requirements: 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 (a)). d. Continuous Emission System Monitoring Requirements (if a CEMS is used) (i) The continuous emission monitoring system (CEMS) shall meet the requirements specified in accordance with (ii) Data from the CEMS shall be used to identify excess emissions as specified in e. Performance Testing Requirements (if a CEMS is used) (i) An initial performance test shall be conducted in accordance with the provisions in 40 CFR Part 60 Subpart KKKK Paae 9 of 18

10 f. Reporting Requirements (i) For each affected unit required to continuously monitoring parameters or emissions, or to periodically determine the fuel sulfur content under this subpart, you must submit reports of excess emissions and monitor downtime in accordance with 40 CFR Part 60 Subpart A, 60.7(c). Excess emissions must be reported for all periods of unit operation, including start-up, shutdown and malfunction (40 CFR Part 60 Subpart KKKK (a)). Note that the source is exempted from monitoring the sulfur content of the fuel as provided for in 40 CFR Part 60 Subpart KKKK (ii) Excess emissions and monitor downtime for NOx are defined in 40 CFR Part 60 Subpart KKKK (b). (iii) All reports required under 60. 7(c) must be postmarked by the 30 1 h day following the end of each 6-month period. (40 CFR Part 60 Subpart KKKK ). Table 13.2: Regulation No. 6 Part B - Colorado State NSPS Applied to Specific Facilities and Sources f-irs Emission Source Pollutants Standards /Requirements/Citation Combustion turbines so lbs per MMBtu of heat input per II.D.3.b. Opacity 20% Opacity per II.C All Stacks so2, PM & Stack Tests are required to show compliance PM10 per II.D.E or as allowed by 40 CFR Part 75. In addition, the following requirements of Regulation No. 6, Part A, Subpart A, General Provisions, apply. a. At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not 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. (Reference: Regulation No. 6, Part A. General Provisions from 40 CFR 60.11) b. No article, machine, equipment or process shall be used to conceal an emission that 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 that is based on the concentration of a pollutant in the gases discharged to the atmosphere. ( 60.12) c. Written notification of construction and initial startup dates shall be submitted to the Division as required under d. Records of startups, shutdowns, and malfunctions shall be maintained, as required under e. Written notification of continuous monitoring system demonstrations shall be submitted to the Division as required under Paae 10 of 18

11 f. Written notification of opacity observation or monitor demonstrations shall be submitted to the Division as required under g. Excess Emission and Monitoring System Performance Reports shall be submitted as required under h. Performance tests shall be conducted as required under i. Compliance with opacity standards shall be demonstrated according to j. Continuous monitoring systems shall be maintained and operated as required under In respect to any pollutant that is not specifically covered under the BACT condition above, BACT requirements shall apply to the pollutant at any such time that the pollutant's emissions meet or exceed its PSD significance level solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential emissions of the pollutant above the applicable PSD threshold will require a full PSD review for the pollutant as though construction had not yet commenced on the source. The source shall not exceed the PSD threshold for the pollutant until a new PSD permit is granted. (Reference: Regulation No.3, Part D, Section VI. B. 4.) 15. Various emission sources shall be equipped with emission control systems or device(s), as specified in Attachment A, capable of reducing the uncontrolled pollutant emissions to the levels identified in the tables above. These control systems and device(s) shall be inspected, monitored, maintained, renewed, and operated as per the recommendations of the manufacturers to ensure ongoing satisfactory performance. Records of such inspection, monitoring, maintenance, and operation shall be maintained, and made available to the Division for inspection upon request. 16. Within one hundred and eighty days (180) after commencement of operation, initial relative accuracy test shall be performed on all continuous emissions monitors (CEMS) and the owner or operator shall conduct performance test(s) and furnish the Division a written report of the results of such performance test(s). All CEMS are subject to annual relative accuracy test audits, daily calibrations requirements of 40 CFR, Part 60, Appendix B, Performance Specification 4 or 4A, Appendix F, Quality Assurance Procedures, and 60.8, Performance Specifications. 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Reg.3, Part A,II.C) a. Annually whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five tons per year or more, above the level reported on the last APEN; or b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. Facility AIRS 10:101/1160 Paae 11 of 18

12 18. This source is subject to the provisions of Regulation No. 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be incorporated into the operating permit. The application for the Operating Permit is due within one year of commencing operation of the equipment covered by this permit. (Reference Reg. 3, Part C, ) 19. A source compliance test shall be conducted to measure the emission rate(s) for the pollutants listed below to show compliance with the emission limits in Attachment A, condition numbers 6.1.A and 6.2.A above, and condition number 13 above for the stacks from the combustion turbines (AIRs emission points 001 through 007). The test protocol must be in accordance with the requ irements of the Compliance Test Manual and shall be submitted to the Division for review and approval at least 30 days prior to testing. No test shall be conducted without prior approval from the Division. Any stack test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time. (Reference: Regulation 3, Part B.III.G.3) Particulate Matter (includes condensables) using EPA approved methods Oxides of Nitrogen (NOx) using EPA approved methods. Volatile Organic Compounds (VOC) using EPA approved methods. Carbon Monoxide (CO) using EPA approved methods. 20. This sou rce shall be equipped with control devices as appropriate in other to meet PSD and other standards' requirements. Operating parameters of the control equipment shall be identified in the operation and maintenance plan to be submitted with the compliance certification within one hundred and eighty days (180) after commencement of operation. The identified operating parameters will replace the control efficiency requirement on the final permit. (Reference: Regulation No.3, Part B, Section III.E.) 21. Proper operating temperature of the oxidation catalyst and SCR systems shall be identified in the operation and maintenance plan to be submitted with the compliance certification within one hundred and eighty days (180) after commencement of operation. The identified operating parameters will replace the control efficiency requirement on the final permit. (Reference: Regulation No.3, Part B, Section III.E.) 22. The manufacturer, model number and serial number of the subject equipment shall be provided to the Division prior to Final Approval. (Reference: Regulation No. 3, Part B, Section Ill. E.) 23. Within one hundred and eighty days (180) after commencement of operation, compliance with the conditions contained on this permit shall be demonstrated to the Division. It is the permittee's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, II.G.2). 24. Within one hundred and eighty days (180) after commencement of operation, the applicant shall submit to the Division for approval an operating and maintenance plan for all control equipment and control practices, and a proposed record keeping format that will outline how the applicant will maintain compliance on an ongoing basis with the requirements of all the conditions of this permit. The operating and maintenance plan shall commence at startup. (Reference: Regulation No. 3, Part B, Section III.G.7.) Paae 12 of 18

13 25. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either the date of issuance of this initial approval permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; or (iii) does not complete construction within a reasonable time of the estimated completion date (See General Condition No. 6., Item 1.). Upon a showing of good cause by the permittee, the Division may grant extensions of the permit. (Reference: Regulation No. 3, Part B, Section III.F.4.) 26. This facility shall be completely enclosed by the installation and maintenance of a continuous physical barrier (such as a fence with secured gates) and posted with no trespassing signs that preclude public access to this site as described in the modeling analysis for this facility. This requirement is imposed as a result of the modeled ambient air impacts that result from facility operations. (Reference: Regulation No. 3, Part B, Section II.A.4) 27. The combustion turbine generators' stack heights (as-built, above ground level) shall be at least equal to or higher than the respective minimum heights listed as follows (Reference: Regulation No. 3, Part B, Section II.A.4): 1) 2) The GE LMS 100PA Turbines, CT01, CT02 and CT03: The GE LM 6000PF Turbines with HRSGs, CT04, CT05, CT06 & CT07: 71.9 feet 76.1 feet 28. Post-construction ambient monitoring shall be conducted for a minimum of twelve (12) months and shall begin within three (3) months, or within another period approved in writing by the Division, after commencement of operation of this source. Additional post-construction monitoring beyond the twelve (12) month period may be necessary to determine the effect emissions from this source have, or may have, on air quality in any area. With the submittal of data for the minimum twelve (12) month period, the permittee may request that further monitoring be waived. The Division will consider such request in the context of the data for the aforementioned purposes of post-construction monitoring, and if appropriate grant such a waiver. Locations of monitoring stations and procedures for data collection, compilation and reporting shall be submitted to, and approved by, the Division. Postconstruction monitoring is required for nitrogen dioxide, ozone, and meteorology. (Reference: Regulation No. 3, Part D, Sections VI.A.4 and VIAS.) 29. For the equipment covered under this permit and according to a Division-approved protocol, the owner or operator shall conduct performance tests to determine in-stack N0 2 /NOx ratios for a range of operating conditions. The results shall be furnished in a written report to the Division. By: ~~~ ~ Sunday \lbeyi, P.E. Permit Engineer Ntff!& Unit Leader Paae13of18

14 Notes to permit holder: 1 ). The fuel use limit and emission limits contained in this permit are based on the fuel use rate requested in the permit application. These limits may be revised upon request of the permittee providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and application form must be submitted with a request for a permit revision. 2). This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II. E.1. of the Common Provisions Regulation cdphe. state. co. us/regulations/airregs/ aqcccommonprovisionsreg. pdf. 3). This source is subject to the requirements of Regulation No. 8, PartE, III.EEEE: National Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines (Subpart YYYY) including, but not limited to, the following: Compliance with the Initial Notification requirements set forth in is required. The source need not comply with any other requirement of this subpart until EPA takes final action to require compliance and publishes a document in the Federal Register. 4). The following emissions of non-criteria reportable air pollutants (NCRPs) are estimated based upon the fuel consumption as listed above. This information is listed to inform the operator of the Division's analysis of the specific compounds. This information is listed on the Division's emission inventory system. C.A.S. # SUBSTANCE (BIN) Acetaldehyde (BIN A): Ammonia (B): Benzene (BIN A) : Propylene Oxide (BIN A): EMISSIONS 683 pounds per year 227,200 pounds per year 126 pounds per year 494 pounds per year 5). This source is classified as a: At a: Major source for the Title V Operating Permit and PSD Major facility. 6). The emission levels contained in this permit are based on the following emission factors: AIRS POINT ID #s: & 003: Simple Cycle Combustion Turbines CT01, CT02 & CT03- Natural gas combustion Pollutants Emission Controls Emission Factors (Steady State Only) Steady Operation Startup Shutdown Control Eft. (%) (lbs/mmscf) (lbs/event) (lbs/event) Device Filterable PM Filterable TSP Condensable PM1o Condensable TSP Sulfur Dioxide (S0 2 ) Paae 14 of 18

15 Nitrogen Oxides (NOx) voc Carbon Monoxide (CO) Acetaldehyde Ammonia Benzene Propylene Oxide SCR 80.0 CatOx 0.00 Cat Ox A IRS POINT ID #s: 004, & 007: Combined Cycle Combustion Turbines CT04, CT05, CT06 & CT07- Natural gas combustion Pollutants Emission Factors Steady Operation Startup Shutdown Control (lbs/mmscf) (lbs/event) (lbs/event) Device Emission Controls (Steady State Only) Eff. (%) Filterable TSP Filterable PM1o Condensable TSP Condensable PM1o Sulfur Dioxide (S0 2 ) Nitrogen Oxides (NOx) SCR 88.0 voc CatOx 0.00 Carbon Monoxide (CO) CatOx 84.0 Acetaldehyde Ammonia Benzene Propylene Oxide Paae 15 of 18

16 ATTACHMENT A STATEMENT OF BASIS DETAILS OF EQUIPMENT & ACTIVITIES COVERED UNDER THIS PERMIT AIRS Process/Equipment Description Remarks /Specific Provisions 001, 002 & Three (3) GE, LMS100PA, natural gas-fired, simple Good combustion and 003 cycle combustion turbine generators (CTGs), each design; Use only pipeline rated at MMBtu per hour and equipped with SCR quality natural gas fuel. and CatOx control devices (CT01, CT02 & CT03) Subject to BACT Process Rate Limit Per Unit: requirements Natural gas consumption: 6,897.6 MMscf per year Subject to NSPS Subpart (based on NG heat value of 1, 016 BTU per set) KKKK, & Reg. No. 6.B.II.3. Startup/Shutdown: 1,460 Events per year per unit Continuous emission monitoring (CEM) used to Emission Limits (Stead~ State Ogeration): monitor NOx & CO PM 1o: 28.9 tons per year per unit emissions. TSP: SOx: NOx: VOC: CO: 28.9 tons per year per unit 3.6 tons per year per unit 62.2 tons per year per unit 12.4 tons per year per unit 79.5 tons per year per unit Emission Limits (Startug/Shutdown Events): NOx: CO: 8.4 tons per year per unit 19.9 tons per year per unit 004, 005, Four (4), LM 6000 PF, natural gas-fired, combined Good combustion and 006 & 007 cycle CTGs, each rated at 373 MMBtu per hour and design; Use only pipeline equipped with DLN, SCR and CatOx control devices quality natural gas fuel. (CT04, CT05, CT06 & CT07) Subject to BACT Process Rate Limit Per Unit: requ irements Natural gas: 3,216.0 MMscf per year per unit Subject to NSPS Subpart (based on NG heat value of 1,016 BTU per set) KKKK, & Reg. No. 6.B.II.D.3. Startup/Shutdown: 780 Events per year per unit Continuous emission Emission Limits (Stead~ State Ogeration): monitoring (CEM) used to PM1o: 18.8 tons per year per unit monitor NOx & CO emissions. TSP: 18.8 tons per year per unit SOx: 1. 7 tons per year per unit Paae 16 of 18

17 ATTACHMENT A STATEMENT OF BASIS DETAILS OF EQUIPMENT & ACTIVITIES COVERED UNDER THIS PERMIT (contd.) AIRS Process/Equipment Description Remarks /Specific Provisions 004, 005, NOx: 16.1 tons per year per unit 006 & 007 (contd.) VOC: 8.2 tons per year per unit CO: 13.0 tons per year per unit Emission Limits (StartuQ/Shutdown Events}: NOx: 3.4 tons per year per unit CO: 15.4 tons per year per unit End of Attachment A Paae 17 of 18

18 GENERAL TERMS AND CONDITIONS: (IMPORTANT! READ ITEMS 5,6,7 AND 8) 1. This permit is issued in reliance upon the accuracy and completeness of information supplied by the applicant and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the applicant or applicant's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 2. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section (7)(a), C.R.S. 3. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of, a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to final approval by the (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the applicant, or the Division revokes a permit, the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 4. This permit and any required attachments must be retained and made available for inspection upon request at the location set forth herein. With respect to a portable source that is moved to a new location, a copy of the Relocation Notice (required by law to be submitted to the APCD whenever a portable source is relocated) should be attached to this permit. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 5. Issuance (initial approval) of an emission permit does not provide "final" authority for this activity or operation of this source. Final approval of the permit must be secured from the APCD in writing in accordance with the provisions of (12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final approval cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. If the APCD so determines, it will provide written documentation of such final approval, which does constitute "final" authority to operate. Compliance with the permit conditions must be demonstrated within 180 days after commencement of operation. 6. THIS PERMIT AUTOMATICALLY EXPIRES IF you (1) do not commence construction or operation within 18 months after either the date of issuance of this permit or the date on which such construction or activity was scheduled to commence as set forth in the permit, whichever is later; (2) discontinue construction for a period of 18 months or more; or (3) do not complete construction within a reasonable time of the estimated completion date. Extensions of the expiration date may be granted by the APCD upon a showing of good cause by the permittee prior to the expiration date. 7. YOU MUST notify the APCD no later than thirty days after commencement of the pennitted operation or activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup (NOS) form may be downloaded online at Failure to do so is a violation of AQCC Regulation No. 3, Part B, Section III.G.1., and can result in the revocation of the permit. You must demonstrate compliance with the permit conditions within 180 days after commencement of operation as stated in condition Section {2){a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 9. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections (enforcement), -121 (injunctions), -122 (civil penalties), (criminal penalties), C.R.S. Paae 18 of 18